October 26, Dear Ms. Evanego:

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1 October 26, 2018 Melissa Evanego Chief Bureau of Mobile Sources Department for Environmental Protection State of New Jersey 401 E. State St.; 7th Floor, East Wing P.O. Box 402 Trenton, NJ By Dear Ms. Evanego: On behalf of the Diesel Technology Forum, I submit these comments regarding the draft Beneficiary Mitigation Plan ( Plan ) published by the New Jersey Department of Environmental Protection (DEP) concerning the use of the $24 million in Environmental Mitigation Trust revenue allocated for the first round of Trust funding. While we commend DEP in prioritizing projects according to cost effectivity in NOx reduction, the additional goal of seeking to maximize the introduction of all-electric technologies may dilute emission reduction benefits delivered to communities in need in New Jersey. We encourage you to take advantage of the DERA option as outlined in the draft Plan so as to reduce NOx emissions from off-road equipment that is responsible for generating 16 percent of mobile source NOx emissions in New Jersey. Today, clean diesel technologies are available across the entire spectrum of eligible project types outlined in the consent decree. Replacing older vehicles and equipment with the latest clean diesel models will deliver the most emission reductions at the least cost when compared to other emerging and sometimes unproven technologies. Existing and emerging alternative fuels require expensive investments in refueling or recharging infrastructure that is not funded by the Trust. By way of background, the Diesel Technology Forum represents manufacturers and suppliers of diesel engines, vehicles and equipment. The Forum is a not-for-profit educational organization dedicated to raising awareness of the clean air and economic benefits of clean diesel technology. More information on the Forum is available at The Draft Plan Dilutes NOx Emission Reduction by Choosing Expensive Technologies The goal of prioritizing all electric technologies and seeking to maximize NOx emission reductions are at competing odds. While the allure of all-electric technologies appears promising, these technologies, where they are available, are expensive and require significant additional charging infrastructure not funded by the Trust. Exclusively funding these high cost projects would result in many older and higher emitting trucks and buses left in service. A more technology neutral approach, that prioritizes the most cost-effective technology at reducing NOx emissions, would generate far greater emission reductions for those communities most in need Corporate Drive Suite 102 Frederick, MD Phone (301) Fax (301)

2 Comments of the Diesel Technology Forum on the VW Settlement Trust for NJ DEP, Page 2 How to Make the Most of a $24 million Investment for Immediate NOx # of Vehicles or Equipment Anticipated Total Cost to Exclusively Cost to Total NOx placed into NOx Reduction Fund a Remove (lbs) Price Per Application Service for $24 million per Year per Project Particular Project Each lb of Reduction NOx ($/lb) per year Transit Buses MY2000 bus with Clean Diesel $370, ,062 $24,000,000 $348 68,886 MY2000 bus replacement with Hydrogen $1,200, ,162 $24,000,000 $1,033 23,240 MY2000 bus replacement with Battery-Electric $880, ,162 $24,000,000 $757 31,691 Source: (1) "Clean Diesel Versus CNG Buses: Cost, Air Quality and Climate Impacts." Clean Air Task Force (2012). (2) "From Deceit to Transformation: How Connecticut Can Leverage Volkswagen Settlement Funds to Accelerate Progress to a Clean Transportation System. CONN PIRG. January 18, (3) "Consortium to Fund New Flyer Hydrogen Buses to ACTransit", Passenger Transport, February 24, As the table above indicates, many more older and higher emitting buses may be replaced for a $24 million investment with the clean diesel option. This cost effective and proven technology does not require additional expensive investments in recharging or refueling infrastructure. A clean diesel option is also widely available across the spectrum of eligible projects. All-electric applications are available today in smaller and relatively lower emitting commercial vehicle types. Among the category of commercial vehicles, larger Class 8 trucks are responsible for a greater share of NOx emission. These vehicles are powered by much larger engines than delivery trucks or buses and complete many more miles. Currently, there is not an all-electric option for Class 8 truck; a clean diesel option is available today. Replacing previous generation diesel technology with the latest clean diesel innovations that power a Class 8 truck on the road for 125,000 miles a year can eliminate over two tons of NOx emissions. Expanding Project Eligibility to Off-Road Applications Will Expand Benefits We encourage you to include as eligible for funding off-road equipment, including switchers and marine workboats that are responsible for 21 percent of mobile source NOx emissions as identified in the draft Plan. Expanding eligibility to these project types can greatly increase NOx emission reduction benefits for communities in need, particularly those sensitive communities located near freight facilities and port operations. Recent research confirms that replacing older engines that power marine workboats and switch locomotives are among the most cost-effective projects. A single marine engine replacement project can deliver as much NOx reductions as nearly 100 Class 8 truck replacements. These projects are the most cost-effective projects. Many switch locomotives and marine workboats operate nearly 24 hours a day for decades and are frequently in operation in areas in close proximity to disadvantaged communities. Replacing older engines that power these large applications will have a large and direct emission reduction benefit to these communities. A summary of the cost effectivity of these large engine replacements is included as an appendix to this comment. Leverage Additional Resources Offered Under the DERA Option We also encourage you to take advantage of the Diesel Emission Reduction Act (DERA) matching fund opportunity. The DERA option may be used to replace or repower the large variety of off-road equipment types that are responsible for 16 percent of mobile source NOx emissions as identified in the Plan. Allocating funding towards the DERA option would allow DEP to leverage additional resources to repower or replace a wide variety of off-road equipment types found in-use on construction sites and may generate further emission reductions. The Bayonne Bride raising project serves as a useful case study concerning the benefits of clean diesel off-road equipment. As part of the project, the Port Authority of New York New Jersey required the use of the latest

3 Comments of the Diesel Technology Forum on the VW Settlement Trust for NJ DEP, Page 3 clean diesel technologies on hundreds of pieces of equipment used to raise the deck of the massive bridge. As a result of the requirement, three out of every four pieces of off-road equipment met the latest near-zero emissions Tier 4 standard. Therefore, the off-road equipment did not result in a substantial increase in emissions, of concern to communities sometimes residing within several feet of this equipment. Conclusion While we congratulate DEP for prioritizing NOx reduction in the draft Plan we encourage you to prioritize projects based on cost effectivity. A technology neutral approach would award funding to the top technology types that deliver the most NOx reduction for a fixed investment and will deliver many more needed emission reduction benefits to communities across New Jersey. We also strongly encourage you to consider large engine replacement projects for which there is not an allelectric option, while also taking advantage of the DERA option that may leverage additional resources to maximize emission reduction benefits across the State. Very truly yours, Allen R. Schaeffer Executive Director /ARS ATTACHMENTS

4 Comments of the Diesel Technology Forum on the VW Settlement Trust for NJ DEP, Page 4

5 Comments of the Diesel Technology Forum on the VW Settlement Trust for NJ DEP, Page 5