Central Florida Clean Cities News Volume 2, Issue 1 April 2019
August 2019 Special: Florida Releases VW Settlement Draft Plan
Summary of Proposed Allocation of $166 million in funds:
$116 million (70%) - School, Transit and Shuttle Buses (Electric or Clean Fuel)
$25 million (15%) - Electric Vehicle Charging Infrastructure (maximum allowable)
$25 million (15%) - Diesel Emissions Reduction Act (DERA) (used as matching for existing federally funded program)
July 17th - The Florida Department of Environmental Protection has published a draft Beneficiary Mitigation Plan for a public comment period of 30 days. Florida’s draft Beneficiary Mitigation Plan fulfills the required elements listed in the Volkswagen Settlement’s Environmental Mitigation Trust for State Beneficiaries (Final Trust Agreement) and outlines how Florida will spend the $166 million allotted to the state. This money will go toward projects to mitigate the excess emissions caused by certain Volkswagen vehicles operating without the legally required emissions controls.
“Public input is an important part of our process,” said DEP Division of Air Resource Management Director Jeff Koerner. “The Department has made an effort to be transparent throughout the development of the Beneficiary Mitigation Plan. We have previously held public meetings and webinars, and sought public input through requests for information, a public survey, and now by requesting feedback on the draft Beneficiary Mitigation Plan. Through this commitment to public outreach, we look forward to finalizing the Beneficiary Mitigation Plan and identifying projects which will benefit Florida’s air quality.”
The primary goal of Florida’s mitigation plan is to reduce mobile sources of emissions in areas where people live, work and visit. To achieve this goal, Florida’s mitigation plan will prioritize projects that replace eligible units with electric-powered and/or alternative fueled units; identify the areas in Florida where the largest number of people are impacted by higher levels of emissions from diesel-powered vehicles and equipment; and identify mitigation projects that achieve the lowest cost per ton of pollutants reduced.
All public comments must be submitted via email to VWMitigation@FloridaDEP.gov by 5:00 p.m. EST, Friday, August 16, 2019. At that time, the Department will consider all public comments and then finalize the plan for submittal to the Trustee.
For more information about the Volkswagen Settlement, the Department’s activities related to the settlement, and the draft Beneficiary Mitigation Plan, please go to the Department’s dedicated webpage.
CFLCC Beneficiary Mitigation Comments
On August 1st, the Board of Directors approved the following comments for submission to FDEP.
August 1, 2019
To: Florida Department of Environmental Protection, Division of Air Resource Management
From: USDOE Central Florida Clean Cities Coalition
Re: Comments Addressing the State of Florida’s Draft Beneficiary Mitigation Plan of July 2019
The U.S. Department of Energy’s Central Florida Clean Cities Coalition (CFLCCC) has actively supported clean transportation fuel use in our ten-county region for the past 20 years. Our stakeholders include the National Labs, fleets, fuel providers, vehicle manufacturers, government organizations, support industries and individuals.
The eligible use of funds provided through the MTA includes vehicle replacement, repowering and conversions using alternative fuels and technologies advanced through the efforts of the Clean Cities Coalitions, including natural gas, propane, and electric vehicles. The Volkswagen settlements provide an enormous opportunity to deploy advanced clean transportation and infrastructure technologies in Florida.
Central Florida Clean Cities would like to compliment the Florida Department of Environmental Protection (FDEP) on its excellent Draft Beneficiary Mitigation Plan and we appreciate this and previous opportunities to comment.
Strong Points
Recognizes and conforms to public response recommendations
Recognizes the potential of electric transportation and infrastructure
Addresses geographic areas in greatest need of NOx, particulate, and pollutant reductions
Considers the needs of communities with a disproportionate air pollution burden, and provides an opportunity for improved air quality at schools and in underserved communities
Establishes an opportunity to sustain Florida’s ability to remain compliant with air quality requirements
Allows an efficient use of settlement funds, in combination with DERA, to address mitigation actions for organizations and instances that fall outside of the stated eligible priorities
Concerns
The use of alternative fuels such as Propane and CNG are not specifically addressed
The overall tone of the document seems to favor Clean Diesel, particularly Figure 13.
Cost/benefit analysis (Figure 13) overstates electric school and transit bus cost, which produces an overstated Cost/Ton/Year
Total Cost of Ownership (TCO) for eligible replacement vehicles is not considered, which can result in understated benefits and less efficient long-term use of settlement funds
Does not address the use of private or public matching funds to improve Cost/Ton/Year calculations to enhance program funding efficiency
Infrastructure to support electric buses is an eligible mitigation action that is not addressed in the draft
EPA emissions tools have the potential to overstate clean diesel emissions benefits. Specifically, the use of EPA’s Diesel Emissions Qualifier (DEQ) will result in an understatement of NOx emissions reductions from alternative fuel and zero emissions options, while diesel-to-diesel impacts would be overvalued.1
A clearer understanding of the internal and external modeling tools FDEP plans to use is needed
Timing for events and actions (other than response to the Draft) is not addressed
Recommendations
FDEP’s Draft Mitigation Plan is the result of an exceptional effort to gather public input, recognition of electric transportation technology’s potential, and thoughtful consideration of the efficient use of funds to benefit Florida and those who are overburdened by air quality and health issues. The Central Florida Clean Cities Coalition and its stakeholders encourage FDEP to give careful consideration to all of our stated concerns to improve the efficient use of settlement funds. We strongly suggest that FDEP re-evaluate the use of EPA’s tools to ensure a level playing field for mitigation actions and the most efficient and long-term use of settlement funds.
We thank you for this opportunity to provide input, please let us know if we can be of further assistance.
1 Wells to wheels: Environmental implications of natural gas as a transportation fuel
Hao Cai, Andrew Burnham, Rui Chen, Michael Wang – Systems Assessment Group, Energy Systems Division,Argonne National Laboratory, United States
Central Florida Clean Cities Board of Directors
Our Coalition is a 501(c)(3) non-profit organization governed by a Board of Directors (BOD). The BOD consists of volunteers that are actively involved with alternative fuels and technology; they use their experience and insight to provide guidance to our coalition. We gratefully acknowledge their dedication to the use of alternative fuels and the time they devote to the coalition. Our BOD members are:
Chair - David Dunn City of Orlando Fleet and Facilities Division Manager Vice-Chair - Dick Johnson VP AutoPort Secretary – Doug Kettles Central Florida Clean Cities Coalition Coordinator Director – Helda Rodriguez President, NovaCharge
Director – Lyn Cacella Florida Public Utilities Growth and Retention Manager Director – Cornelius Willingham Nissan S.E. Electric Vehicle Strategy & Business Development Manager Director – Horacio Cervantes Peoples Gas Business Development Manager
This e-newsletter is published by the Central Florida Clean Cities Coalition, under contract with
the U.S. Department of Energy. For additional information please contact Doug Kettles at doug@cflccc.org
Central Florida Clean Cities Coalition
cflccc.org
(321) 300-4555
