Comments:
- Seattle’s trip reduction rule and programs are the best in the nation. Learn and copy as much as possible. The analysis only mentioned.
- SanFrancisco, NewYorkCity, programs requiring employers to provide commuter pre‐tax benefits and Portland, OR program where employers must provide commute alternatives to employees designed to minimize cars driven to work. WA State’s successful program requires employers to set commute trip reduction goals. The city of Seattle has a program under which employers with more than 100 employees appoint and maintain an Employee Transportation Coordinator who tracks and reports employee commute behavior. Seattle has decreased drive alone from 35% to 25% between 2010 and 2017 in a multi-prong program.
- Is Denver’s/RAQCs only asking for baseline measurement from employers with 250 or more employees? How much is this really going to reduce?
- DOT GHG Standard – Can you pass along examples of other state DOTs that have a GHG Pollution Standard? Can that produce a 26% GHG reduction in 4 years?
- Reprogram funds! The state needs to invest in connected, protected bikeways INDEPENDENT of road projects for cars. Streets need to be made safe and comfortable for people. All bus stops should have benches and shelters. If the state is not closing coal by 2025 then this sector needs to be reducing 26% GHG by 2025, right? That is more than would be achieved by requiring any NEW vehicle registration to be EVs. It’s time to set a phase out date, at least for new ICE vehicle registrations at least in the metro area. Also, ICE and non-local traffic should probably be re-routed/disallowed by I-70 by EJ communities for the foreseeable future. They are over the top on pollution exposure, amid a city that is 4th worst among large cities in the country for air pollution, and air pollution is causing 1 in 5 deaths. https://denver.cbslocal.com/2020/01/28/denver-brown-cloud-air-pollution/ and https://www.hsph.harvard.edu/c-change/news/fossil-fuel-air-pollution-responsible-for-1-in-5-deaths-worldwide/.
- All school buses should be made electric! https://bit.ly/AirPollutionDamagesEveryCell and research links at http://bit.ly/AQheadlines
Colorado state government is seeking public input on an upcoming rule to reduce greenhouse gas (GHG) emissions and other air pollutants from transportation in Colorado. This rule is part of an ambitious effort to address climate change and meet the state’s science-based climate targets of 26% by 2025, 50% by 2030% and 90% by 2050 from 2005 levels, outlined in the state Greenhouse Gas Pollution Reduction Roadmap.
Main Rule Components
Employee Traffic Reduction Program (ETRP) (RAQC Resources)
The Air Pollution Control Division (Division) will be proposing an Employee Traffic Reduction Program (ETRP) rule before the Air Quality Control Commission Commission) in May 2021 and request a hearing for the rulemaking be set for August 2021. Since fall 2020, the Regional Air Quality Council (RAQC) has worked with stakeholders to develop and refine a draft ETRP proposal for consideration by the RAQC Board . The Division is evaluating the RAQC’s efforts for the rule the Division will propose but the scope and requirements may evolve before the Commission considers the rule for adoption.
The ETRP rule would require entities that employ a certain number of people (threshold yet to be determined) to develop a plan to reduce vehicle miles traveled by employees who commute to and from a worksite through measures such as telecommuting, public transit, ridesharing and/or other methods that meet employers’ specific capabilities and business needs. These plans would reduce traffic congestion and associated vehicle emissions state-wide, and lead to a variety of other potential benefits, including financial savings and enhanced quality of life for employees, reduced overhead costs, along with improved employee recruitment and retention. There are at least 27 programs like these already working successfully throughout the United States.We want to make sure you are informed about this rulemaking process and the concepts currently under consideration. Your feedback is important and will be carefully considered during the development of this rule.Upcoming Informational and Listening Sessions:•Employee Traffic Reduction Program (ETRP) rule overview for businesses and organizations: Tuesday, March 9, 2021, 2:00 – 3:30 p.m
Employer Based Trip Reduction Program Resources
Drafts
Drafts have been prepared for the purpose of discussing frameworks for potential Employer Based Trip ReductionPrograms. They are for deliberative purposes only and not intended to represent formal regulatory proposals.
ETRP Draft Regulatory Approach – Rev. 6 (February 2021)
Documents
Initial White Paper Analysis (February 2020)
Draft Employer Based Trip Reduction Work Group Work Plan (April 2020)
Questions & Answers: Benefits of Employer-based Trip Reduction Programs in Our Region (October 2020)
Timeline & Processes: 2008 Ozone Standard, Potential Severe Reclassification and State-Only Flexible ETRP (October 2020)
ETRP Business Outreach Letter (March 2021)
Presentations
Regional Air Quality & the Role of Transportation (October 2020)
Denver South – Employer Transportation Champions (October 2020)
ETRP Overview and Updates (December 2020)
ETRP Potential Emissions Reductions (January 2021)
Commutifi ETRP Assessment (January 2021)
UrbanTrans ETRP Recommendations (February 2021)
Tiered and Phased In Approaches to ETRP (March 2021)
Greenhouse Gas Pollution Standard (CDOT resources)
One of the key recommendations stemming from the Governor’s Greenhouse Gas (GHG) Roadmap is the adoption of a new GHG Pollution Standard for the transportation sector. In addition to having an active role in the rule development, the Colorado Department of Transportation (CDOT) is also working to ensure this effort is fully informed by transportation stakeholders from around the state.
Upcoming Regional GHG Stakeholder Meetings
Friday April 9 – 1-2:30pm (Region 1 – Denver Metro Area)
Monday April 12 – 10:30-12pm (Region 2 – South/Southeast)
Monday April 12 – 1-2pm (Region 3 – Northwest)
Friday April 16 – 10:30-12pm (Region 4 – Northeast)
Friday April 16 – 1-2pm (Region 5 – Southwest)
Please send an email to Theresa Takushi (theresa.takushi@state.co.us) if you are interested in attending these regional meetings.
Vehicle Emission Inspection Program
The Division is also exploring ways to make Colorado’s vehicle inspection program more effective. Changes to the inspection program would likely be considered as part of the Air Commission’s broader GHG Transportation Rulemaking.
Rulemaking Process
- Stakeholder Engagement: ongoing
- May 20-21, 2021: Request for Rulemaking Hearing before the Air Quality Control Commission
- August 19-20, 2021: anticipated Rulemaking Hearing before the Air Quality Control Commission
Engagement Opportunities
- The Division will be hosting two virtual listening sessions on the upcoming Greenhouse Gas Reduction Transportation rulemakings:
- March 11 from 10:30am-12:00pm (REGISTRATION)
- March 18th from 6:00pm – 8:00pm (REGISTRATION)
Participants will be able to participate in either English or Spanish (ver formulario de registro en español a continuación).
- March 9th Employer Traffic Reduction Program Listening Sessions (REGISTRATION)
This listening session is intended for large employers and efforts to reduce employee commuting emissions.
- Written comments may be submitted here: GHG Transportation Comment Form
Or mailed to:
℅ Lauren McDonell
Colorado Department of Public Health and Environment
Air Pollution Control Division
4300 Cherry Creek Drive South
Denver, CO 80246
More information about CDPHE’s Climate Change Unit
Sign up to receive email notifications from the Division on greenhouse gas, climate equity, and other air quality issues HERE.
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Coordinated fiscal strategy can accelerate EV adoptionThe Biden Administration’s much needed infrastructure bill is being designed to “Build Back Better” by advancing job creation and the fight against climate change. We believe that accelerating the transition to zero- and near zero-emission vehicles is central to both goals.
This large and ambitious bill will likely need to pass the Congress via “reconciliation,” a legislative move that allows a bill focused on budget and tax policy to avoid a filibuster, and pass the Senate with a simple majority of votes. Experts working with 350 Silicon Valley are recommending an integrated program of measures we believe can put the nation on the path to a decarbonized economy, starting with the automotive sector.
Time is of the essence, both because the infrastructure package is no doubt coming together now, and because we know that it generally takes Americans 15 years to retire and replace their cars. We think a targeted set of incentives and disincentives can speed up the much needed transition away from gasoline-powered vehicles.
Please sign your organization on below, by Wednesday, March 10. If you have questions or comments, please send them to janet@350siliconvalley.org.
Thank you!
Janet Cox
Legislation Director
350 Silicon Valley
______________________________________________________________________________________________________________
March XX, 2021
To:
Secretary of Transportation Pete Buttigieg
Secretary of Energy Jennifer Granholm
White House National Climate Advisor Gina McCarthy
Dear Secretary Buttigieg, Secretary Granholm, and Advisor McCarthy,
Congratulations to all of you on joining the Biden Administration at the most important possible moment for the earth’s climate. The organizations signing on to this letter are grateful for your commitment to tackling this existential problem, and we look forward to working with you in the months and years ahead.
The topic of this letter is relatively narrow: how the anticipated infrastructure bill can be crafted to reduce carbon emissions in the transport sector. Specifically, we focus on an integrated program of strategies for accelerating adoption of electric vehicles. While the light vehicle EV market share in the US was only 2 percent in 2020, it could increase rapidly if a combination of more attractive incentives for purchasing EVs and new disincentives for purchasing gasoline- or diesel-powered vehicles were in place.
We think this program can help the US fulfill its obligations to meet the Intergovernmental Panel on Climate Change’s (IPCC’s) 1.5°C warming target. Perhaps just as important, we believe these measures—taxes, incentives, and subsidies, can all be passed by reconciliation. We hope to see at least some of the suggestions below in the infrastructure bill.
Surveys suggest that the purchase price differential between EVs and gasoline/diesel powered vehicles is one of the most important factors in determining whether buyers select EVs. Many European countries have adopted largely self-financing vehicle tax and subsidy programs that have helped to increase their EV adoption rates.* We believe the U.S. can, and indeed must, follow their lead in this area.
RECOMMENDED PROGRAMS TO INCREASE LIGHT VEHICLE EV MARKET SHARE
— Phase in a federal excise tax on the purchase of new gasoline or diesel-powered light vehicles, with the tax rate keyed to the EPA-estimated carbon emissions of the vehicle type or model, e.g. ranging from 10 to 30 percent. To protect lower-income buyers, initially apply the tax only to vehicles with carbon emissions greater than those of the smallest, most fuel efficient sedans. When EVs selling for $25,000 or less become available, the tax could apply to the smallest fossil fuel cars as well. (Currently the only federal excise tax on vehicles is 12 percent on heavy duty trucks, trailers and tractors.)
— To reduce upfront EV costs to individuals and small businesses, introduce a federal subsidy (applied to the purchase price at the time of sale) of up to $7500 for purchase of a new EV and up to $3000 for purchase of a used EV. Maintain the EV income tax credit for higher-income buyers who would not be eligible for these subsidies. Eliminate the current unit cap (based on a manufacturer’s sales) on the tax credit, and do not introduce any caps on the new subsidy. Provide an increased subsidy for low income people who scrap an older vehicle (15 years+) in conjunction with an EV purchase.
— Offer states matching grants to develop their EV charging networks. Make the federal government’s percentage share larger for states that further decrease the purchase price differential between EVs and gasoline/diesel powered vehicles. States could qualify for a higher federal matching grant share by
*introducing their own excise tax on the sale of gasoline- and diesel-fueled vehicles,
*exempting EV purchases from state and local sales taxes (as Washington state does), or
*offering rebates/subsidies for EV purchases (as California and several other states do).
— The sale of motorcycles and mid-size trucks should be subject to similar excise taxes. Electric motorcycles and electric trucks of all sizes should qualify for purchase subsidies and be exempt from federal excise taxes.
SUPPLEMENTAL SUGGESTIONS
— Consider increasing federal excise taxes on both gasoline (currently 18.4 cents per gallon) and diesel (currently 24.4 cents per gallon) by 50 cents over a period of 3 years. These federal excise taxes have not increased since 1993— inflation alone has increased 79 percent over those 28 years. The Highway Trust Fund has suffered because these excise tax amounts were not adjusted annually to keep up with changes in the cost of living. We note that In the EU the average tax on gasoline is $2.50 per gallon; and on diesel $2.00 per gallon.
— Plug-in-hybrid EVs could be exempt from excise taxes for several years, while receiving subsidies and tax credits at a lower rate than fully electric vehicles.
— After price parity has been achieved, EV subsidies should be reduced as battery prices decrease—to give manufacturers incentives to pass cost reductions on to their customers.
— The federal matching grant share for EV charging systems should increase if a state exempts EVs from annual registration/license fees. Currently many US states have been moving in the opposite direction, levying supplemental annual registration fees on EVs. The rationale for this increase has been that EV owners have not been paying their share of road maintenance costs since they pay no gasoline taxes. (This argument neglects the social cost of capital, i.e., the health and climate cost savings EVs provide.)
THE NORWEGIAN EXAMPLE
In 2020 Norway achieved an EV market share of over 50 percent—the largest in the world and a substantial increase over its 1 percent share 10 years earlier. Norway appears to be on track to fulfill its goal of banning the sale of new gasoline or diesel powered cars and light trucks by 2025. How has Norway done it? First, it has completely eliminated the price differential between EVs and most gasoline and diesel light vehicles. Second, it has taxed the most polluting vehicles quite heavily.
For several years the upfront costs of purchasing most EVs in Norway have been no greater (and often less) than the upfront costs of purchasing a gasoline or diesel powered vehicle. Unlike most other European countries, Norway has not made EVs more affordable by giving large grants or tax credits to buyers. Instead, Norway redesigned its tax structure for automobiles to make EV purchasing both competitive and user friendly. Norway exempted EVs from the 25 percent value added tax (VAT), the vehicle purchase tax (based on CO2 and NOx emissions and weight) that tends to be even greater than the VAT, and annual fees equivalent to our registration and licensing fees. The resulting simplicity in vehicle cost comparisons, and the consistency of exemptions over the years, have contributed to Norway’s success with EV adoption.
Other popular incentives for Norwegian EV drivers include substantially reduced tolls for bridges and roads, reduced fares for ferries, and reduced rates for municipal public parking. In national surveys of EV owners, many Norwegians claim they could not afford not to buy an EV. Norway’s high gasoline and diesel taxes have also helped. Because virtually all electricity produced in Norway is clean (98 percent hydropower), the switch to EVs is having an even greater impact on carbon emissions than in countries that rely on fossil fuels for much of their electricity production.
Other EV pricing programs are also worth studying. The French Bonus-Malus System applies either a penalty on gasoline and diesel powered cars or a subsidy on EVs at the time of sale. California’s Clean Cars 4 All program offers lower-income individuals generous EV rebates at the time of sale when a purchase is accompanied by the scrapping of an old gas guzzler.
We look forward to learning about your plans for accelerating the adoption of EVs throughout the country, and would appreciate your thoughts on the feasibility of implementing our policy suggestions.
Sincerely yours,
*Haugneland, P et al., “Put a Price on Carbon to fund EV incentives—Norwegian EV Policy Success”, EVS30 Symposium, Stuttgart, Germany, October 9-11, 2017.
Wappelhorst, S et al.,“Using Vehicle Taxation Policy to Lower Transport Emissions, An Overview for Passenger Cars in Europe “, International Council on Clean Transportation, December 2018.
