Comment Log Display

PLEASE NOTE: Underline notation for suggested revisions to the
draft Investment Plan appear on the submitted PDF version of the
comment letter but do not appear when these comments are posted in
the "Message" box of the comment submittal web page. The substance
of the comments pasted in the "Message" feild are otherwise the
same as the attached PDF.

April 24, 2013

Chairwoman Mary Nichols
California Air Resources Board
Sacramento, California

Subject: Cap-and-Trade Auction Proceeds Investment Plan – Passenger
Vehicle Aftermarket Products Incentive Program		
Thank you for the opportunity to comment on the draft Cap and Trade
Auction Proceeds Investment Plan (or “Investment Plan”) released
April 16, 2013. 

We recommend broadening the Investment Plan’s “Infrastructure”
category to encompass additional measures that address the
efficiency of the in-use fleet, including fuel efficient
replacement tires and engine oil.  Such measures were included in
the AB32 Scoping Plan, but have not yet been implemented (see p.
51-2 and Appendix C-64). An incentive program in these areas could
achieve $750 million in net annual customer savings and reduce
greenhouse gases emission by roughly 2 million metric tons, as
noted in our February 25 testimony and March 8, 2013 detailed
written comments.  In addition, a replacement tire incentive
program will complement important efforts to potentially develop
labeling information and/or standards for low rolling resistance
passenger vehicle replacement tires.

We suggest the following revision on page B-3 of the Appendix to
the draft Investment Plan (proposed additions underlined) to
recognize the value of these types of programs:
 “Infrastructure and Tailpipe Emission Reductions (SB 391): Funding
for infrastructure for smooth/GHG pavements [sic], complete
streets, ramp meters/traffic management and for vehicle in-use
efficiency (such as fuel efficient tires and/or engine oil)
programs and incentives.”

Thank you for considering our comments. Please contact me or have
your staff contact me at epike@energy-solution.com or (510)
482-4420 x239 if you have any questions.

Sincerely,
 
Ed Pike, P.E.
Senior Project Manager