Written Public Comments Table of Contents December 5, 2017

Commenter Affiliation Date 1. Julie Brooks Orange EV 11/3/2017 2. Frank Podgwaite MedicAire, LLC 11/3/2017 3. Katherine Wurtz Martin Marietta 11/6/2017 4. Dean Stapleton Penske Truck Leasing 11/10/2017 5. Phil Squair et al. Alternative Fuel Stakeholders 11/20/2017 6. Nick D'Andrea UPS 11/30/2017 7. Allison Wilder - 11/30/2017 8. Paula Laney - 12/1/2017 9. Micha Keyan Tulsa EV Coalition 12/2/2017 10. Kurt Krans - 12/3/2017 11. Randolf Wollgiehn CNG Cylinders International 12/4/2017 12. Larry Hopper COTPA 12/4/2017 13. Lauren Izzi/ Kevin Lagge OG&E 12/4/2017 14. Britta Gross General Motors 12/4/2017 15. Sherrie Merrow NGV America 12/4/2017 16. Kylah McNabb/ Mark Faulkenberry WFEC 12/4/2017 17. Jeff Brown/ Kerry Rowland PSO 12/5/2017 18. Isabel Villa-Garcia Global Automakers 12/5/2017 19. Eric Pollard ACOG 12/5/2017 20. Eric McCarthy Proterra Inc. 12/5/2017 21. Don Ford Organization of Rural Schools 12/5/2017 22. Jaime Longacre/ Ronnie Lane Caterpillar Inc. 12/5/2017 23. Norman Herrera Sparq Natural Gas 12/5/2017 24. Tom Bogdanowicz OMES 12/5/2017 25. Shawn O'Leary/ Anthony Francisco City of Norman 12/5/2017 26. Bob Ford Navistar 12/5/2017 27. Ryan Kenny Clean Energy Fuels 12/5/2017 28. Jason Ferbrache City of Oklahoma City 12/5/2017 29. Cory Hubert City of Oklahoma City 12/5/2017 30. Nancy Graham INCOG 12/5/2017 31. Gerald Parks Calera Public Schools 12/5/2017 32. John Sheridan Coleman Public Schools 12/5/2017 33. Kate McDonald Silo Public Schools 12/5/2017 34. Keith Buehler Tinker Air Force Base 12/5/2017 35. Mark Hogan City of Tulsa 12/5/2017 36. Julia Herrera Enervee 12/5/2017

From: Julie Brooks To: Heather Lerch Cc: Mike Saxton; Kylah McNabb Subject: New comments from Orange EV re Oklahoma"s VW Beneficiary Mitigation Plan Date: Friday, November 03, 2017 12:38:59 PM Attachments: Comments from Orange EV re VW Beneficiary Mitigation Plan 11-2-17.pdf

Heather,

Please see the attached letter for updated comments from Orange EV. Thank you for requesting and considering input as you develop your state Volkswagen Beneficiary Mitigation Plan.

As you evaluate how to allocate VW funds, please note that heavy duty electric yard truck projects are highly cost effective, providing significant emissions reductions for the money spent.

The attached letter provides new information not contained in previous Orange EV submissions. Items that may be of particular interest include:

Owner/operator complexities: There is a complex tapestry of ownership and operations associated with third party logistics and yard management companies. Frequently, several parties pay for different aspects of one project creating a need for: 1) separate incentive funding for all aspects of a project (truck, charging, and infrastructure); and 2) a unique incentive funding structure allowing multiple contracts under one project umbrella. Cost parity calculations: We provide a detailed table comparing the cost of an Orange EV pure electric yard truck vs. the cost of a Tier 4 diesel refurbishment, including the incentive level required to achieve cost parity. Greater emissions reductions: A 2017 analysis found that in diesel trucks with significant idling, low speeds, or low loads, the engine temperatures do not reach levels that support sustained selective catalytic reduction (SCR) performance, resulting in emissions up to 10x higher than the 2010 EPA NOx standard. Current emissions calculations for yard trucks estimate average reductions of 1-2 tons of NOx per truck per year, but given that yard trucks typically operate 10-15 mph, actual reductions may be far higher.

Each of these topics is discussed in more detail in the attached letter, along with other requests and recommendations.

Orange EV has 100% electric Class 8 terminal trucks deployed and operating in fleets from California to New York. From these deployments, we have gathered a wealth of experience and data. Please consider us a resource and contact us if we can be of assistance. We would be happy to set up a conference call to answer questions and/or provide further information.

Thank you, -Julie

Julie Brooks Orange EV, Pure Electric Terminal Trucks "Spend 90% Less in Fuel to Haul the Same Load with No Diesel and No Emissions” Address: 500 NW Business Park Lane, Riverside, Missouri 64150 (10 minutes from Kansas City) Phone: 503-544-8694 Office: 866-688-5223 x720 eMail: [email protected] Website: www.OrangeEV.com

November 2, 2017

Subject: Developing the state’s Volkswagen Beneficiary Mitigation Plan

Thank you for considering these comments regarding the development of your Volkswagen Beneficiary Mitigation Plan (VW BMP).

The detailed comments in this document are grouped into four main sections: Guiding Principles, Process for Administering Projects, Benefits to Low-Income and Disadvantaged Communities, and Eligible Mitigation Action Categories to Consider.

In this letter we provide broadly applicable recommendations and emissions information, along with data and requests that are specific to yard trucks. When developing the VW BMP, please ensure that:

1) All components of yard truck projects (trucks, charging, and infrastructure) are individually eligible for funding under one project umbrella, 2) Electric yard truck projects are funded at the maximum allowable, and 3) Yard trucks in all operating environments are eligible for funding.

Thank you for your consideration and partnership in the mission to deploy emission-free technologies.

Respectfully,

Mike Saxton Orange EV, Chief Commercial Officer [email protected] 816-210-9669

OrangeEV.com 500 NW Business Park Lane, Riverside, MO 64150 866-688-5223

Background

Orange EV manufactures heavy-duty (Class 8) pure-electric terminal trucks also know as yard trucks, drayage trucks, hostlers, spotters, and more - they can all refer to the same vehicle. Yard truck replacements/repowers are ideal VW mitigation projects given that retiring just one diesel engine typically results in calculated NOx emissions reductions of 1-2 tons per year depending on usage, and real-world reductions may be far greater. New studies have shown that diesel emissions control devices do not operate as designed at lower speeds; since yard trucks operate under 25 mph and often 10-15 mph, they lie squarely in the worst-case scenario for diesel emissions control systems.

Orange EV provides the first - and still only - commercially deployed Class 8, 100%-electric vehicles. The trucks have been commercially deployed since 2015, and most fleet customers have required incentive funding to offset higher up-front capital costs and to overcome the perceived “risk premium” associated with newer technology and the cost of change that comes with testing and deploying new equipment. Orange EV trucks meet the demands of even the harshest environments (e.g. Chicago rail intermodal) and 75% of fleet customers have re-ordered within 6 months of receiving their first truck. The hurdles remain, however, and to accelerate deployment of heavy duty electrics, significant incentives are required.

Guiding Principles

The following list is not exhaustive but provides a framework for the decision and planning processes. We respectfully request that the VW BMP: 1) Supports projects to accelerate and/or enhance commercial adoption of zero-emission vehicles. 2) Augments existing private and public incentives and grants at a project level. 3) Focuses investment in locations to benefit disadvantaged communities. 4) Demonstrates sustainability of zero emission fleets and projects. 5) Avoids interfering with or undermining emerging and existing businesses. 6) Encourages innovation and speed-to-market for additional zero emission vehicles. 7) Incents users to transition fleets more quickly.

Process for Administering Projects

The VW BMP provides a rare opportunity to fund projects in a way that is complementary and additional to current state and federal incentive programs. Currently even the most successful programs for heavy duty yard trucks (such as California’s Carl Moyer program which funds up to 85% of truck cost) have limitations in that they cannot address the complex tapestry of ownership and operations associated with third party logistics and yard management companies.

Fund multiple projects under one umbrella

Due to the typical business models utilized in freight handling, there are frequently several parties paying for different aspects of one project. Quite often, yard trucks are owned by a yard management company who has a contract to move freight at a customer site. When moving to all-electric, the yard management company purchases the vehicles, while the facility

OrangeEV.com 500 NW Business Park Lane, Riverside, MO 64150 866-688-5223

or site owner is responsible for utility costs as well as the cost of installing infrastructure and charging equipment. For a project to move forward, all parties must work together and agree to individual costs. For the business case to make sense for all parties, all components of the project - vehicle acquisition, charging, and infrastructure - must be eligible for incentive funding.

To address this all-too-common scenario, please develop a funding structure that allows for multiple contracts (with multiple entities) under one project umbrella. This unique approach will remove roadblocks, incent all parties who shoulder project costs, and speed adoption of zero emission vehicles.

Fund electric projects at the maximum allowable

For Class 8 all-electric solutions, the Volkswagen trust agreement allows up to 75% of the project to be funded for private fleets and 100% for public; this funding applies to repower or replacement projects and includes charging and infrastructure. To accelerate deployments of heavy duty electrics and to achieve cost parity, incentive amounts should be set at this maximum allowable. These benefits should also allow for augmentation by other private or public funding programs.

Cost parity vs. emissions parity

The following table provides a comparison of Orange EV yard truck acquisition costs vs. the cost of a Tier 4 diesel refurbishment, and also highlights the incentive level required to achieve cost parity. What the data doesn’t quantify is the “emissions parity” or perhaps better the “emissions advantage” delivered with zero-emission projects. When a pure electric vehicle replaces a diesel, emissions are completely eliminated (i.e. there are no Tier 4 emissions) and the emissions advantage is permanently captured.

When analyzing the table, it’s important to note that in most cases fleets are not looking to buy a new Tier 4 diesel, but rather extend the life of a current truck or buy a refurbished vehicle that meets emission standards. The purchase decision boils down to three alternatives: 1) use incentives to move quickly and purchase a pure-electric vehicle; 2) purchase an acceptable refurbished diesel; or 3) wait until the normal replacement cycle to purchase a new Tier 4 diesel.

OrangeEV.com 500 NW Business Park Lane, Riverside, MO 64150 866-688-5223

Basic Cost Comparison: Orange EV Pure-Electric Terminal Truck Solution vs. Diesel

REPLACEMENT REPOWER NEW Extended REMAN Standard NEW Extended Duty (160kWh) REMAN Extended Duty (80kWh) Duty (160kWh) w/Standard Duty (160kWh) w/Standard w/Fast Charge Onboard w/Fast Charge Onboard Costs Cabinet Charging Cabinet Charging Orange EV truck, base price1 $284,950 $284,950 $239,950 $199,950 Orange EV charging $49,950 $0 $49,950 $0 Electrical infrastructure2 $20,000 $6,000 $20,000 $6,000 Taxes (estimated 8%) $28,392 $23,276 $24,792 $16,476 Total electric vehicle solution: $383,292 $314,226 $334,692 $222,426 Comparable diesel truck w/8% tax (refurb)3: $54,000 $54,000 $54,000 $54,000

Cost difference: $329,292 $260,226 $280,692 $168,426 Percent incentive required to achieve cost parity: 86% 83% 84% 76%

Note 1: The costs shown are for the base price of an Orange EV yard truck. Most fleets pay additional cost to install air conditioning, trailer stops, galvanizing, etc. These are optional costs, but in many places are necessary given the operating environment and/or stipulations in union contracts. For a remanufacture, the fleet must also supply an acceptable donor vehicle. Note 2: Infrastructure is built out and paid for by the fleet (or site owner if the fleet is contracting services to the site); costs can vary dramatically by site. Costs are typically less for “standard onboard” charging due to lower voltage and amperage, and more readily available capacity. Factors that increase the cost of infrastructure include running cabling over long distances, installing a transformer, and hiring outside contractors (not as necessary for the standard onboard charging solution). Note 3: Cost for diesel trucks can range from $25,000 to $120,000 based on refurbished vs. new, and the fleet's buying power. In most cases, fleets are not looking to buy a new Tier 4 diesel, but rather extend the life of a current truck or buy a refurbished vehicle that meets emission standards.

In Orange EV’s experience, fleets are making capital last as long as they can and the alternative to a pure-electric solution is usually as stated in the table above. But for the scenario where fleets must purchase a new vehicle (i.e. life extension or purchasing refurbished aren’t viable options), and assuming $100,000 per diesel with 8% taxes, fleets would still require 72%, 66%, 68%, or 51% incentive funding (respectively, left to right on the table above) to achieve cost parity.

Offering maximum incentive levels increases the likelihood of replacing diesels with zero emission vehicles, accelerating widespread adoption, and achieving statewide emission reductions targets.

OrangeEV.com 500 NW Business Park Lane, Riverside, MO 64150 866-688-5223

Utilize max percentages, OEM product approval, and a first-come first-approved model

We request that maximum funding levels are set utilizing percentages rather than fixed dollar amounts. Infrastructure costs are site dependent and highly variable and new technology is more expensive by nature. If assigning a fixed maximum dollar amount, the state risks discouraging innovation for the larger and more expensive zero emission vehicles and stifling projects that have increased infrastructure costs. Maximum percentages create a more robust environment for developing and implementing new technologies.

In our experience, the most effective incentive programs (such as California’s HVIP, Chicago’s Drive Clean Chicago, and New York’s NYSEV-VIF) utilize OEM product approvals and a first- come, first-approved basis. This model simplifies the application, streamlines the process, and provides greater certainty for fleet managers, site managers, and manufacturers regarding the order/manufacture/delivery timeline.

While projects will be funded across categories, allocations should be technologically neutral and support viable technologies that meet the intended NOx reduction standards.

Benefits to Low-Income and Disadvantaged Communities

Focus and priority should be given for projects at freight facilities located in non-attainment or disproportionately impacted communities. Funding projects in these locations (at least 25% across each category, as appropriate) will result in dramatically reduced emissions in disadvantaged communities, potentially much larger than current calculations estimate.

Studies show high diesel emissions at idle, low speed, and low load

Yard trucks typically operate in highly impacted areas in goods movement operations such as waste transfer stations, warehouses, distribution centers, manufacturing plants, rail intermodal yards, seaports, and more. Replacing diesel with 100% electric eliminates a calculated estimate of 1-2 tons of NOx per truck annually. Real world emissions may be significantly higher, though, according to a 2017 Wells to Wheels analysis (“Environmental implications of natural gas as a transportation fuel”, Hao Cai et al).

In this analysis, multiple studies found that performance of a diesel’s selective catalytic reduction (SCR) system is highly dependent on the duty cycle. In high-speed duty cycles, the SCR system performs well and diesel trucks have relatively low NOx emissions. In duty cycles with significant idling, low speeds, or low loads, however, diesel engine temperatures do not reach levels that support sustained SCR performance. This results in very high NOx emissions, up to 10x higher than the 2010 EPA NOx emission standard.

Given that yard trucks typically operate 10-15 mph, diesels may emit far more NOx than currently estimated, along with other criteria pollutants. Replacing diesels with 100% electric will eliminate yard truck emissions and improve air quality.

OrangeEV.com 500 NW Business Park Lane, Riverside, MO 64150 866-688-5223

Eligible Mitigation Action Categories to Consider

The VW Mitigation Trust Consent Decree outlines ten eligible categories for funding. The focus of our comments will relate to Category 1 (Class 8 Local Freight Trucks and Port Drayage Trucks) and Category 8 (Forklifts and Port Cargo Handling Equipment).

Allow functionally “similar-for-similar” replacement

Allowing “similar-for-similar” replacement in Categories 1 and 8 (and perhaps others) has the potential to be transformative, focusing on the operational needs of a facility rather than strictly requiring “like-for-like” replacement. As an example, the role of a yard truck is often performed less efficiently by an over-the-road drayage truck. If the functionality of a diesel on- road drayage truck can be replaced with an all-electric yard truck, program goals are met, and the community and environment benefit.

Define “port” in broad terms

Yard trucks are specifically identified both Categories 1 and 8. Note, however, that in each Category, the word “port” is attached. In Category 1, drayage trucks are defined as “trucks hauling cargo to and from ports and intermodal rail yards” while Category 8 applies to port cargo handling equipment. Using the word "port" is potentially limiting since it evokes the image of a traditional seaport. In the broadest sense, ports are terminals which move cargo, and more and more, these terminals are clustered at inland transportation hubs in disadvantaged communities.

If mitigation fund projects under Categories 1 and 8 are limited to those located in traditional seaports, approximately 80% of yard truck operations will be eliminated; just 20% work in seaport operations. The Consent Decree does not define the word port, however, which gives states the flexibility to consider all yard truck projects that meet the overarching goal to reduce NOx emissions in impacted areas.

In discussions with other states, regulators have agreed that the Consent Decree provides leeway to define port to include all freight facilities. If a broad “port” definition is not adopted, then allocations of funds between categories should address the more restrictive number of opportunities in Categories 1 and 8, and prioritize funds to projects like these that result in greater environmental benefit.

OrangeEV.com 500 NW Business Park Lane, Riverside, MO 64150 866-688-5223

Summary

To realize cost effective emissions reductions in the state’s Volkswagen Beneficiary Mitigation Plan, please ensure that all aspect of yard truck projects (vehicle, charging and infrastructure) are eligible for funding in all operating environments and at the maximum level allowed.

In today’s market, pure-electric yard trucks can be “gateway” vehicles to heavy-duty electrics. Although yard trucks generally operate out of the public eye, word spreads quickly between yard operators and fleet companies. Successful deployments generate interest in a way that overcomes pre- conceived notions and speeds adoption of green technologies.

OrangeEV.com 500 NW Business Park Lane, Riverside, MO 64150 866-688-5223 From: [email protected] To: Heather Lerch Subject: FW: Comments - VW settlement environmental mitigation plan Date: Friday, November 03, 2017 12:53:28 PM

From: [email protected] [mailto:[email protected]] Sent: Sunday, October 08, 2017 3:36 PM To: '[email protected]' Cc: '[email protected]' Subject: Comments - VW settlement environmental mitigation plan

Kylah McNabb Office of Secretary of Energy & Environment State of Oklahoma

Beneficiary Mitigation Plan for Volkswagen Settlement Comments: October 8, 2017 Use of Volkswagen settlement funds for Medidocks to advance Ambulance/Emergency Vehicle Idle Reduction: Idling of ambulances is a significant contributor to air pollution, particularly as the majority of the idling occurs adjacent to healthcare facilities with their sensitive populations exposed. Reducing this idling provides a direct air quality improvement. Problematic to not idling the ambulance is the fact that interior temperatures and medical equipment must be maintained in a state of readiness, requiring power. My firm’s product, the Medidock, provides a real solution to this problem by allowing an ambulance to remain ‘mission-ready’ without idling. Our system is a kiosk, installed at Emergency Departments and other medical facilities and at remote locations where ambulances are ‘posted’ to improve response times and improve air quality. The Medidock requires no special equipment to be installed onboard the vehicle – any & all ambulances can use it. In addition to electrical power for the onboard emergency medical equipment it also provides vehicle interior climate control - without the need to run the engine. Our units ease of operation encourages EMT’s to actually use the machines, resulting in fuel and maintenance savings for the vehicle operators and environmental benefits for everyone. On our website www.medicaire.net you will find a study done by the Ozone Transport Commission (OTC) which indicates a significant NOx reduction as noted from sites in VT & NH. Medidocks are presently successfully operating in northern New England and locations in the Midwest. While vehicle idle reduction is not specifically indicated in the settlement, augmentation of DERA is, allowing a pathway for funding this important public health/air quality improvement. I urge you to consider earmarking funding for the Medidock in the final Beneficiary Mitigation Plan. Thank you for your consideration.

Frank Podgwaite MedicAire, LLC Medidock North Haven, CT 06473 203-887-0209 cell [email protected] www.medicaire.net “The ambulance idle reduction solution” “Exclusive Distributors of the Medidock”

From: Katherine Wurtz To: Heather Lerch Cc: Allison Wurtz Subject: VW Mitigation Project Proposal Date: Monday, November 06, 2017 3:00:01 PM

Martin Marietta in Davis, OK is interested in utilizing VW Mitigation funds to replace their current locomotive with an all-electric freight switcher.

The proposed project will replace one unregulated / uncontrolled freight locomotive to Nordco’s all-electric Shuttlewagon (freight switcher). The locomotive operates over 1,000 hours annually in switching operations at Martin Marietta in Davis. The existing freight switcher is 3000 bhp and utilizes, on average, 19,408 gallons of fuel per year. Unregulated / uncontrolled baseline emissions levels are 17.4 g/bhp-hr NOx, .44 g/bhp-hr PM, and 2.84 g/bhp-hr ROG respectively. Unregulated emissions levels reflect the U.S. EPA Locomotive Emissions Standards, Regulatory Support Document, April 1998. Reduced emissions levels reflect zero-emissions.

In order to calculate the tons of emissions reduced per project the unregulated emissions levels in g/bhp-hr are first converted to grams per year by multiplying the pollutant rate in g/bhp-hr by the fuel consumption rate factor of 20.8 and taking the resulting figure and multiplying by the number of diesel fuel gallons used per year. The new tier pollutant levels in g/year are then subtracted from the baseline tier pollutant levels in g/year. This figure in grams is then converted to tons by dividing by 907,200. The life of the replacement all-electric freight switcher is 15 years. After converting to tons, the figure is then multiplied by 15 to reflect emission reductions over the entire project life. Compared to unregulated / uncontrolled locomotive emissions, Nordco’s all-electric Shuttlewagon / freight switcher reduces NOx, PM, and ROG emissions by 100%.

By replacing one unregulated switch locomotives with Nordco’s all-electric Shuttlewagon, this project reduces annually 7.7 tons of NOx, 1.3 tons of ROG, and .2 tons of PM. Over a 15- year project life, over 115.5 tons of NOx, 19.5 tons of ROG, and 3 tons of PM are eliminated from the atmosphere in Davis.

The cost of an all-electric Shuttlewagon/freight switcher is $1,272,000 including the cost of charging infrastructure. Under funding guidelines, 75% of the costs of a replacement all- electric freight switcher is offered under VW.

On behalf of Martin Marietta, KEW Grant Services is asking that this freight switcher project be taken into consideration for ODEQ's Beneficiary Mitigation Plan.

-- Katherine Wurtz Data Analyst | Partner e: [email protected] c: 815.530.2097

November 10, 2017

Heather Lerch Oklahoma Department of Environmental Quality PO Box 1677 Oklahoma City, OK 73101

Re: Penske Comments on VW Funding Planning

Dear Ms. Lerch:

Penske would like to thank the Oklahoma Department of Environmental Quality (DEQ) for the opportunity to provide comments on the Volkswagen settlement funding plan for the state. The Oklahoma DEQ has consistently provided an opportunity for stakeholder engagement and feedback to shape and refine programs to ensure they are meeting their intended purposes—a process we strongly respect and admire.

Penske remains committed to reducing vehicular emissions and accelerating deployment of cleaner vehicle technology and can be a natural partner with the state in achieving some of its goals to reduce emissions from transportation. Penske’s average customer size is between 8 and 12 trucks and is able to provide comprehensive vehicle services to companies that do not have the financial capital and necessary experience to purchase and maintain alternative fueled vehicles. Leasing with Penske provides the following benefits to fleets:  No upfront purchase costs and concerns about vehicle residual/resale  No costs to modify maintenance facilities  No maintenance training costs and investment in special tools  No fueling anxiety as Penske will help with vehicle routing and fueling contracts  24/7 Roadside assistance & nationwide service network  Cost savings from Penske’s purchasing power for fuels and vehicles that can be passed onto customers

In order to provide alternative fuel vehicles at competitive rates with their diesel and gasoline counterparts, Penske leverages incentives, such as grant programs and tax credits. Since Penske accesses these programs throughout the U.S., we have come to understand the programs that work best to incentivize clean vehicle deployment for small, mid-sized and large fleets alike. We are providing this insight to you so that you may consider it as you work to create funding programs from the VW settlement but also in your efforts to create future incentive programs to deploy cleaner and more advanced vehicle technology within the state. Specifically, we would recommend the following:

1. Treat vehicle leasing like any other financing mechanism and allow fleets the opportunity to have equal access to program funding regardless of the financing mechanism. Programs can be created in ways that allow you to achieve your objectives in terms of the certain number of years in operation; requirements to hold onto the vehicle for a certain length of time; and targets on mileage/area operation. This can all be done with leasing—just like it can be done with vehicle loans directly by the fleet. We would encourage that you develop programs that do

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not differentiate between the financing mechanisms used and instead focus on the specific objectives you are trying to achieve, regardless of the financing mechanism utilized to get there. 2. Create a priority list versus a wait list that will allow for you to rank projects that achieve better emissions reductions through replacement of vehicle miles travelled of traditional diesel or gasoline. 3. If you do create a waiting list mechanism for an ongoing program, provide waiting list and application funding transparency. Funds for clean vehicle programs frequently become oversubscribed almost immediately upon program opening for popular funding programs. A simple email list that lets people know weeks before the date it will open will allow for transparency in the program. 4. Ability to move between weight classes and increase number of vehicles once awarded. From the period of application to award, things change. Maintaining programmatic flexibility while ensuring that projects are still held to their allocated dollar amount and program effectiveness (e.g., meeting emissions requirements) is key. 5. Simple contracting mechanisms are key to ensure faster deployment. We have seen that purchase order formats with terms and conditions in a 1-2 page format on the back of a purchase order, such as that in Colorado, work really well and are easy to understand and follow. 6. Simple reporting templates are key to encourage and receive timely reporting. We recommend 2-4 times a year and have it specific to fuel use, mileage and listing of any project challenges encountered. 7. Quick payment periods are essential, especially for smaller fleets, so they do not have to carry expenses for too long without reimbursement. 8. Scrappage alternatives are very helpful as frequently companies will see this as a barrier to entry. Many fleets know that their 10 year old truck, for example, carries more value than what can be achieved when just sending it to a dismantler and collecting scrap value. Yet we recognize the state might not want these vehicles to reenter the state. Allow for flexibility here to dispose of the vehicles in ways other than outright scrappage—perhaps an export option like that allowed in Texas or even the opportunity to sell the vehicle to a fleet who has much older units in operation as a 10 year diesel vehicle would be cleaner than a 20 or 30 year old unit that is in operation. Another key opportunity area is to provide a way for an entity like Penske to apply for the funding but for the end user (the actual fleet) to turn in one of their vehicles.

We are eager to work with you and your team to advance cleaner vehicle technology and to reduce emissions in the state. When fleets choose Penske for their clean vehicle needs, it is analogous to hiring an experienced in-house alternative fuel team, and the fleets we work with in your state are eager to replace some of their older vehicles with cleaner and more fuel efficient, less polluting options.

Sincerely,

Dean Stapleton, Senior Manager of Alternative Fuels Penske Truck Leasing

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November 20, 2017

Executive Director Scott Thompson Oklahoma Department of Environmental Quality 707 North Robinson Avenue Oklahoma City, OK 73102

RE: Volkswagen Settlement Emissions Mitigation Plan

Dear Director Thompson:

We the undersigned represent an array of alternative fuel vehicle and renewable fuel stakeholders united by a common desire for the development of an effective and equitable emissions mitigation plan under the Volkswagen Settlement (Settlement) in the State of Oklahoma. We submit the following two recommendations for your consideration.

1. All vehicles that are certified to one of CARB’s low NOx emissions standards, CARB’s near-zero emission standard or have zero tailpipe emissions should be eligible for an equal percentage of funding per vehicle.

The main directive of the mitigation plan is to reduce NOx emissions. Vehicles certified to CARB’s standards produce 50 to 100 percent fewer NOx tailpipe emissions than the current federal standard and thus 50-100 percent less than new diesel vehicles. One of the newest engines in this class of certifications is the low-NOx 6.8 liter propane engine from Roush announced in June of this year. Given the significant improvement that all vehicles with these certifications present and the varying needs of both public and private fleets, which require different sizes and engine capabilities, we encourage equal treatment in terms of funding.

Under the Settlement all private sector vehicle grants are capped at 25 percent of the total vehicle cost, except those for electric vehicles (EVs), which can receive up to 75 percent. There is no basis for skewing the funding in favor of EVs. While EVs have zero tailpipe emissions, emissions are created in generating the electricity which powers them. Let us be clear; we are not against electric vehicles. Rather, the array of technologies and fuels deserve equal treatment given the clear goal of the mitigation plan to reduce NOx emissions.

The South Coast Air Quality Management District of California views the new heavy duty near-zero natural gas engines from Cummins-Westport to be zero-emission equivalent based on the district’s mix of electric generation supplying their grid. It is important to note that they have one of the cleanest grids in the country. Therefore, the new near-zero natural gas engine is likely even cleaner than an EV in Oklahoma since the state produces nearly a quarter of its electricity from coal and over 75 percent from fossil fuels.

We encourage Oklahoma to create a level playing field for all sources of alternative fuel by funding all private sector low-NOx, near-zero and zero tailpipe emission vehicles at 25 percent of the total vehicle cost under the Settlement.

2. A majority of Oklahoma’s mitigation funds should be used for low NOx, near-zero and zero-emission vehicle grants.

Out of all the eligibility categories under the Settlement, Class 4-8 vehicles are the largest contributors of NOx emissions. Furthermore, unlike rail and marine applications, medium and heavy-duty vehicles operate throughout Oklahoma. Therefore, reduction of emissions in vehicles will provide a benefit for all areas: urban, suburban and rural alike. Concentrating funding in this category will accelerate the transition by a wide variety of fleets to these cleaner lower NOx engines, thereby multiplying the positive effect well beyond the grant program.

Thank you for considering our recommendations and we look forward to continuing the conversation.

Phil Squair, Senior Vice-President Marcus Gillette Public and Government Affairs Director of Public and Government Affairs National Propane Association Coalition for Renewable Natural Gas [email protected] [email protected]

Jeffrey L. Clarke Kathryn Clay Legal Counsel Vice-President, Policy Strategy NGVAmerica American Gas Association [email protected] [email protected]

Dan Jameson, Vice President Susan Robinson Government and Regulatory Affairs Federal Public Affairs Director Republic Services Waste Management [email protected] [email protected]

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William A. Zobel, Vice President Bill Bliem Market Development and Strategy Senior Vice President Fleet Services Trillium CNG NFI Trucking, Inc. [email protected] [email protected]

Chelsea Jenkins Charles Musgrove Executive Director, Government Affairs Vice-President Roush Dillon Transport, Inc. [email protected] [email protected]

Brett Barry Gary Maresca Senior Policy Advisor Senior Director-Transportation Services Clean Energy Bimbo Bakeries USA [email protected] [email protected]

Mike Goscinski Director, Government Relations American Bakers Association [email protected]

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November 30, 2017

Ms. Heather Lerch Air Quality Division PO Box 1677 Oklahoma City, OK 73101

Thank you for the opportunity to provide comments on Oklahoma’s VW Settlement Mitigation Plan.

UPS was founded almost 110 years ago as messenger service and has turned into one of the largest package delivery companies in the world. We currently operate in 220 countries and deliver over 4.7 billion packages each year. With a fleet of over 110,000 vehicles, efficiency is key to our operational success. At the same time, UPS is committed to reducing greenhouse gas emissions. UPS began with electric vehicles in New York City in the 1930s. We have now grown to over 8,000 alternative fuel vehicles that run on compressed natural gas, liquefied natural gas, propane, electric and even e-bicycles. To date our alternative fueled vehicles have driven over 1 billion miles. These vehicles don’t just reduce greenhouse gas emissions but ensure UPS is being more efficient; thus, more sustainable.

The VW Settlement provides an opportunity for UPS and other carriers to make an investment in alternative fuel technologies because the funds will help drive down the cost differential for the equipment. While equipment prices have come down some, natural gas and electric vehicles are sometimes two or three times the cost of a gasoline or diesel vehicle. This is why the VW Settlement funds will provide much needed incentives to those wishing to switch to a cleaner burning vehicle.

UPS recommendations on Oklahoma’s VW Settlement Mitigation Plan:

Recommendation #1: Funding for government entities should be the same as those for non- government entities.

UPS believes that states can have a bigger impact, dollar for dollar, by deploying as many low emitting vehicles on the road as possible. If government entities use all of the funds, the impact will be muted as opposed to allowing more cost-share and maximizing vehicles deployed.

Recommendation #2: While the VW Settlement states electric vehicles can receive up to 75% reimbursement and 25% for natural gas, that doesn’t mean it can’t be negotiated.

UPS and other carriers who can make a large impact on air quality and have the capital to deploy large quantities of vehicles should have the ability to negotiate with the State of Oklahoma on an arrangement that benefits the state and the private companies wishing to make the investment. For example, a company that wants to deploy both natural gas vehicles and electric vehicles could negotiate with the state for 50% reimbursement on electric vehicles and a 20% reimbursement for natural gas or some other variation. This would allow for the state to fund large scale projects while preserving money for other smaller projects. This would also be more manageable than providing a generic number and being held to it for all projects. Projects that have the biggest impact and reduce the most of amount of NOx, per dollar spent, should get the largest amount of incentives. Recommendation #3: Entities who have experience with alternative fuel vehicles should be given first priority for funding.

Entities who already have deployed alternative fuel vehicles such as natural gas and electric vehicles understand how to maximize their efficiency. Many have also worked out the issues with bringing online a new fleet of vehicles. In addition, many of these entities already have the infrastructure in place making those “shovel ready” projects which can be executed more quickly over those entities who are non-experienced.

Thanks again for the opportunity to provide comments and we look forward to working with the State of Oklahoma to use these funds in a manner that will reduce the most amount of NOx while maximizing Oklahoma’s VW settlement funds.

Sincerely,

Nick D’Andrea

Vice President, Public Affairs

UPS

From: [email protected] To: DEQ VW Settlement Subject: Emissions Mitigation Rules that Need to be Changed Date: Thursday, November 30, 2017 10:58:52 AM

The following message has been sent by Alison Wilder

It is OUTRAGEOUS to use pollution mitigation settlement money to give ANY vehicle owner a re-powered or new DIESAL ENGINE. This money MUST go ONLY to non Fossil Fuel sources of CLEAN power. PLEASE take out that part of all 10 beneficiaries of this money. This state MUST give up our addiction to Fossil Fuels and Big Oil!! From: [email protected] To: DEQ VW Settlement Subject: More benefit per dollar: Propane powered buses Date: Friday, December 01, 2017 1:18:04 PM

The following message has been sent by Paula Laney

Propane powered school buses provide multiple benefits to the State of OK, school districts, and our children: Lower upfront costs than CNG for both the vehicle and the infrastructure, benefits OK schools saving them money on fluids, filters, and fuel while reducing NOx. Many programs have assisted other fleets yet our schools have been left out. Propane as an alternative fuel would allow many rural and suburban districts that often run older buses to not only upgrade, improve the environment but save money in the long run as well. December 2, 2017

Ms. Heather Lerch Air Quality Division PO Box 1677 Oklahoma City, OK 73101

Ms. Lerch,

As an electric vehicle owner, I’d like to encourage ODEQ to utilize the full 15% of the settlement funding eligible for public electric vehicle charging throughout the state. This will position the State of Oklahoma to serve residents and visitors who choose to purchase one of the growing number of fully-electric vehicles. Furthermore, I believe this investment will help promote tourism and traffic through Oklahoma since this infrastructure would be favorable for EV-driving tourists.

To move Oklahoma forward and proactively prepare for the coming increase in EV and PHEVs, I recommend developing an accessible, user-friendly EV charging network. The network should focus primarily on strategically located DC Fast charging near highway interchanges, and Turnpike travel plazas, at 50-mile intervals, providing easy charging access to EVs traveling longer distances, which will increase as battery ranges get longer and longer.

In addition to DC Fast Charging, strategic Level 2 charging at destinations with regional draws should also be considered. For example, Level 2 charging near the Chesapeake and BOK arenas will allow out-of-town visitors to charge during a concert or event, and have a full charge to drive home without the need to stop at a DC Fast charger.

This network will show Oklahoma’s commitment to providing EV charging options to customers and visitors who choose to purchase electric vehicles, and enable more Oklahomans to choose electric vehicles when they make their next car purchase.

Sincerely, Micah Keyan Tu l s a EV C oa l i t i on From: Kurt Krans To: Heather Lerch Subject: VW Settlement Fund Date: Sunday, December 03, 2017 7:37:29 PM

December 3, 2017

Mrs. Heather Lerch Air Quality Division PO Box 1677 Oklahoma City, OK 73101

Ms. Lerch,

As an electric vehicle driver, I encourage ODEQ to utilize the full 15% of the settlement funding eligible for public electric vehicle charging throughout the state. This will position the State of Oklahoma to better serve residents and visitors who choose to purchase one of the growing number of electric vehicles.

In addition to DC Fast Charging, strategic Level 2 charging at destinations with regional draws should also be considered. For example, Level 2 charging near the Chesapeake and BOK arenas will allow out of town visitors to charge during a concert or event, and have a full charge to drive home without the need to stop at a DC Fast charger.

Sincerely, Kurt Krans 10651 S. 70th. E. Ave Tulsa, Ok. 74133 2331 Sturgis Road Oxnard, CA 93030 • USA Tel: +1 (805) 278-8060 Fax: +1 (805) 278-8090 [email protected] • www.cng.us.com

December 4, 2017 Mrs. Heather Lerch Department of Environmental Quality Air Quality Division PO Box 1677 Oklahoma City, OK 73101

Dear Ms. Lerch:

CNG Cylinders International (CNGci) is pleased to submit these comments to the State of Oklahoma on using Oklahoma’s Mitigation Trust funds under the Volkswagen 2.0L Vehicle Partial Consent Decree, Appendix D. These comments should inform the decision-making process as Oklahoma is developing the state’s Environmental Mitigation Plan as required by the Environmental Mitigation Trust (EMT).

CNGci provides complete compressed natural gas (CNG) fuel system solutions for back-of-cab and frame rail applications for heavy duty and vocational vehicles. Vehicle applications include vocational trucks (heavy haulers, cement mixers, dump trucks, snow plows, off-road and mining), drayage trucks at shipping ports, roll-off / refuse trucks, quarry trucks, and over-the-road trucks. CNGci designs and manufactures large Type 3, carbon fiber-on-aluminum cylinders, for superior heat dissipation when fueling which allows for significantly more gas and thus more usable diesel gallon equivalent (DGE) in the cylinder under fast-fill conditions, which is an industry game-changer. CNGci offers a modular fuel system design with over 6,000 units / systems operating on medium- and heavy-duty vehicles.

Funding from the VW EMT provides an extraordinary and unprecedented opportunity for the State of Oklahoma to put significantly cleaner, lower-polluting vehicles on the road in public and private fleets. This funding can and should be used by the State of Oklahoma to continue its commitment to accelerating the use of cleaner, alternative fuels as a cost-effective alternative to funding diesel vehicles. Superior nitrogen oxide (NOx) emission reduction of natural gas compared to diesel engines supports the tenets of the partial consent decree to mitigate local NOx emissions.

The latest natural gas engines offer a 90% reduction in nitrogen oxide (NOx) emissions over the strictest EPA emission standards, providing a clean commercially available technology to reduce pollution from diesel engines. These modern natural gas engines are certified to perform at 0.02 g/bhp-hr of NOx as

The largest diameter Type 3 cylinders in the world! compared with the diesel engines certified to the 2010 EPA standard of 0.2 g/bhp-hr NOx. It is the lowest level currently recognized under California’s optional Low-NOx Standard for engines. With the EMT created to mitigate excess NOx emissions, we urge prioritizing EMT funds towards impactful, cost- effective technologies such as CNG medium- and heavy-duty vehicles.

Today’s natural gas vehicles are proven technologies that can uniquely, immediately, and cost-effectively transform our nation’s medium- and heavy-duty transportation sector. The advantages of natural gas as a transportation fuel include its domestic availability, widespread distribution infrastructure, low cost, and inherently clean-burning qualities.

In-use emission benefits of natural gas engines could be even more significant. A recent report published in Environmental Science and Technology1, evaluated in- use emissions of earlier model year natural gas vehicles and found that natural gas engines performed much better in real world conditions (i.e., operating within city limits in low-speed, high-idling situations), registering NOx levels 96% lower than levels produced by tested diesel engines equipped with the latest emissions controls. The study found that diesel NOx emissions operating in similar conditions produced emissions that were 5 -7 times higher than diesel in-use certification limits in some cases.

Recommendations

• Provide a larger incentive and greater overall funding for medium- and heavy-duty engines that deliver greater NOx reductions than currently required for new vehicles and engines. • Provide the highest level of funding to applications that produce the largest share of NOx emissions (in most regions this means prioritizing for short-haul, regional-haul, heavy-duty vocational vehicles and refuse trucks). • Prioritize funding for clean vehicles rather than fueling infrastructure. • Scale funding to incentivize the cleanest engines available. • Ensure that funding incentivizes adoption by both public and private fleets. • Accelerate the funding in the early years to maximize the NOx reduction benefits • Given that the EMT was created because of NOx pollution associated with non-compliant diesel vehicles, the funding should be set aside for clean, alternative fuel vehicle projects that focus on maximizing NOx reduction for the funds spent.

1 Environ. Sci. Technol., 2015, 49 (8), pp 5236–5244 (Emission Rates of Regulated Pollutants from Current Technology Heavy-Duty Diesel and Natural Gas Goods Movement Vehicles).

The largest diameter Type 3 cylinders in the world! CNG powered vehicles are the clear champions effective in maximizing pollution cost reduction effectiveness since dollar-for-dollar, NGVs deliver the most cost- effective NOx emissions reductions.

NGVs are commercially available from traditional truck OEMs with established sales and service networks. Retrofit and repower options are also available from a variety of manufacturers. Funding natural gas vehicles is the logical choice and will lead to the largest total reduction in NOx emissions.

Thank you for the opportunity to provide comments on the State of Oklahoma, DEQ’s Environmental Mitigation Plan for the VW 2.0L Vehicle Partial Consent Decree programs.

We look forward to continuing to work together to help carry out the goals and initiatives of the Environmental Mitigation Trust. Please contact me directly at (805) 278-8060 or [email protected].

Sincerely,

Randolf H. Wollgiehn Marketing Manager CNG cylinders international

The largest diameter Type 3 cylinders in the world!

Comments for Oklahoma’s Beneficiary Mitigation Plan for the Volkswagen Environmental Mitigation Trust Funding

The Central Oklahoma Transportation and Parking Authority (COTPA) is pleased to submit these comments to the Oklahoma Department of Environmental Quality (ODEQ) regarding Oklahoma’s Beneficiary Mitigation Plan for Volkswagen Environmental Mitigation Trust funding. COTPA staff will be present tomorrow at the December 5, 2017 meeting. COTPA, dba EMBARK, is the largest transit agency in our region and serves many municipalities in central Oklahoma. Considering our numerous CNG buses, winning a grant in September for the State’s first electric bus and our new streetcar system to start carrying passengers in 2018, EMBARK’s commitment to air quality, the environment and alternatively fueled vehicles is strong.

Our comments are brief and listed below and we will be glad to assist with more information and data in the months to come to assist the ODEQ with preparation of the Mitigation Plan.

COTPA suggests that the Mitigation Plan address transit vehicles (both fleet expansion buses and fleet replacement buses), CNG, “repowering,” the trust fund timeline, charging infrastructure, and reasonable cost sharing (local match rates) for eligible categories.

Comment for Transit Vehicles:

It should be noted that transit bus replacements with CNG buses or all-electric buses can have positive multiplier effects beyond just the buses’ effects. The multiplier is on NOX and other emissions levels and in reducing vehicle miles traveled (VMT) via how transit facilitates fewer cars and other vehicles being on the road, and due to people taking fewer of the high-polluting short trips in their cars and trucks. Not only does the replacement of a higher-emission bus help air quality, but so does the absence of vehicles on the road otherwise used by the numerous transit passengers. The increasing ridership trends at EMBARK further reinforce the promise of multiplier benefits. The ODEQ is urged to try to find an avenue for buses that expand a fleet to be eligible for trust funding.

Comment on CNG

CNG buses are eligible under number two of the ten categories in the nationwide “Attachment A” eligibility parameters, even though CNG supply (fueling) equipment is apparently not to be eligible nationwide. EMBARK and many entities are quite familiar with CNG technology and vehicles. CNG vehicles have a substantially more affordable purchase price than comparable electric buses. The State is urged to allow for the purchase of CNG medium and heavy duty transit and other vehicles, perhaps up to 30% to 50% of the allowed expenditures trust expenditures. To have a set-aside earmarked for transit only (not to include school buses) is urged, especially in light of transit’s multiplier effects.

Comment on Repowering

The funds should be allowed to be used to repower (replace engines of) medium and heavy duty vehicles and ferry boat vessels for transit that meet the national age, class, and other national parameters. If nationally eligible, the addition of retrofit diesel particulate filter (DPF) equipment on post-2008 diesel vehicles that had none should be allowed. In COTPA’s case it appears that repowering (engine replacement) of even our older 2011 model CNG buses can be done at 100% of the cost. This should be eligible and that and the DPF retrofits are great, inexpensive ways to extend the life of those buses which need to be operable through at least 2023 (the CNG buses) while achieving or maintaining lower emissions.

Comment on the Timeline for Trust Funds

Please help the public know when the trust funds may start being approved and how many years a grantee will have to expend the trust funds. Regarding buses, it can take 15-24 months to actually get delivery on a bus once the manufacturer has been issued a notice to proceed. Once the buses are delivered and are in service, the old buses’ engines can be made permanently inoperable.

Comment on Charging Infrastructure

The bus charging infrastructure is eligible, and can be quite expensive. EV supply equipment for medium and heavy duty fleets such as transit buses should be eligible as part of the electric bus purchase cost as specified in the national Appendix Two. This need not be part of the “up-to” 15% light-duty vehicle supply equipment allowance.

Comment on Match Rates

While the VW settlement allows new buses to be bought at 100% cost, it seems too early to suggest a local match percentage. COTPA can assist in that consideration. Each category of the ODEQ program should require some match rate for applicants to furnish. Match rates should be low enough to make trust fund grants attractive.

December 4, 2017 OGE Energy Corp PO Box 321 Oklahoma City, Oklahoma 73101-0321 405-553-3000 www.oge.com

December 5, 2016

Oklahoma Department of Environmental Quality Air Quality Division P.O. Box 1677 Oklahoma City, Oklahoma 73101 Attention: Heather Lerch

Re: Comments for Development of the Oklahoma Volkswagen Beneficiary Mitigation Plan

Dear Ms. Lerch:

Oklahoma Gas and Electric Company (“OG&E”), respectfully submits these comments to the Oklahoma Department of Environmental Quality (“ODEQ”) in response to the request for public input as DEQ drafts the Oklahoma Volkswagen Beneficiary Mitigation Plan (“BMP”). OG&E, the largest electric utility in Oklahoma, is keenly aware of technological and market developments related to electric vehicles (“EV”), and supports the development of a BMP which would direct funds toward increasing the deployment of EV technology in the state of Oklahoma. A BMP which contemplates widespread utilization of EVs and associated infrastructure technology in Oklahoma would support air quality improvements and advance the State’s ability to adapt to the widely- anticipated future public adoption of EVs. OG&E would be happy to assist DEQ in developing the BMP.

1. Background on VW Settlement In January of 2016, the United States filed a claim on behalf of the U.S. EPA (“EPA”) alleging Volkswagen sold over 500,000 vehicles between 2009 and 2016 equipped with “defeat devices” in the form of computer software designed to cheat on federal emissions tests. The major topic in this case is the excess pollution from nitrogen oxides (NOx) which is a key contributor to the formation of ground level ozone. The Court approved 2.0 and 3.0-liter partial settlements that require Volkswagen to fund a $2.7 billion and $225 million mitigation trust fund, respectively. The intent of the fund is to implement actions that replace vehicle emission sources with cleaner technology to reduce NOx emissions and to promote the development and use of alternative fuel vehicle technologies, including electric zero emission vehicles (“ZEV”). Oklahoma currently attains the National Ambient Air Quality Standards (NAAQS) set by EPA for all criteria pollutants. Nevertheless, the settlement funds provide an opportunity for Oklahoma to further mitigate vehicle emissions and improve air quality with respect to NOx, ozone, and fine particulate matter (PM). This funding can help state and local agencies and schools replace relatively higher emitting vehicles with electric ZEVs and install infrastructure and equipment needed to support the new electric vehicles.

2. Available Funding and Eligible Project Types Oklahoma is initially eligible to receive $20,922,485.12 from the trust1 and may fund any of the following eligible mitigation actions in any proportion with the exception that no more than 15% of the funds may be used for light duty zero emissions vehicle supply equipment (“EVSE”, i.e., EV charging infrastructure): • On-Road Heavy Duty Vehicles o Class 8 local freight trucks and port drayage trucks o Class 4-7 local freight trucks o Class 4-8 school bus, shuttle bus, or transit bus • Non-Road Equipment o Airport ground support equipment o Railroad freight switchers o Forklifts o Ferries, tugs, and shore power for ocean-going vessels • Light duty zero emission vehicle supply equipment acquisition, installation, operation and maintenance • Matching funds for projects eligible under the Diesel Emission Reduction Act (the “DERA option”) • States may use up to 15% of the total cost of the project for eligible administrative costs

3. Oklahoma Air Quality There are currently no areas in Oklahoma categorized as non-attainment with the Ozone standard however; continuing to attain the ozone NAAQS, especially in larger urban areas where mobile sources can be a significant contributor, may be increasingly difficult. In 2015, EPA strengthened the ozone NAAQS, reducing the standard to 70 ppb from 75 ppb. Ambient monitoring routinely conducted by the DEQ demonstrates that ambient ozone levels can approach the NAAQS, particularly in metro areas.2 DEQ also periodically issues public health advisories when levels of ozone and PM are elevated. An EPA breakdown of NOx emissions by source category in the 2014 National Emission Inventory (“NEI”) shows that approximately 35% of NOx emissions in Oklahoma are from mobile sources; generally, the proportion of NOx emissions in the metro areas are also weighted toward the mobile source category.3 Intuitively, an emission source of this magnitude would be expected to negatively affect air quality. However, states, including Oklahoma, have little authority under the federal Clean Air Act to regulate emissions from mobile sources. OG&E believes that the ability for DEQ to reduce emissions from vehicle traffic with zero-emission EVs represents a unique, not-to-be-missed opportunity for the utilization of trust funds. The BMP should be developed to take full advantage of this opportunity.

1 Volkswagen Settlement Beneficiary Mitigation Plan Toolkit, source: http://www.naseo.org/Data/Sites/1/naseo-vw-beneficiary- mitigation-plan-toolkit-final.pdf 2 2016 Air Data Report, source: http://www.deq.state.ok.us/aqdnew/monitoring/index.htm 3 Nitrogen Oxides Emissions by Source Sector, source: https://www3.epa.gov/cgi- bin/broker?_service=data&_debug=0&_program=dataprog.state_1.sas&pol=NOX&stfips=40

4. Transportation Industry Solutions There has been a significant shift in the landscape of the transportation industry in recent years driven by a number of pressures on vehicle emissions, advancements in battery technologies, and changes in consumer demand. As a result, auto manufacturers continue to increase investments in and availability of fuel-efficient and alternative fuel vehicles, with an emphasis on electrification. However, there are also barriers to electric vehicles becoming mainstream in the car market. Education and awareness are the most common barriers to consumer adoption of electric vehicles. Local efforts to address these issues in Oklahoma include educational outreach, dealership engagement, and public “ride & drive” events. Charging infrastructure is the next most prominent issue and there is currently no universal way it is being addressed across the country. This is due to the variances in regulatory and political climates in different regions. Regardless, continued increases in charging availability will support and incentivize widespread plug-in electric vehicle (“PEV”) adoption; research shows that available public fast charging reduces range anxiety and increases electric vehicle miles traveled.4 As this market for electrified transportation continues to increase, states and organizations planning for charging station infrastructure should focus efforts on providing consumers with adequate charging coverage to keep pace with the growing electrification trend. Other barriers related to the driving range and upfront cost of the vehicles are beginning to diminish as technology advances and the batteries become capable of storing more energy and are less expensive to produce. As these barriers are overcome, electric vehicles will become especially attractive alternative fuel vehicles. Businesses will see electric vehicles as an opportunity to lower operation and maintenance costs and improve their environmental footprint. Some countries and states see them as an important element of their long-term strategy to meet environmental, economic, and energy security goals. At least eight countries will have a ban on combustion engine vehicles by 2040 and several states are increasing their targets for emissions reduction. Assessments of original equipment manufacturer (“OEM”) announcements and scenarios on electric car deployment confirm that availability of electric vehicles will continue. Ford, GM, Volvo and many other major car manufacturers are committing to an electric future through recent announcements that a portion of, or all, passenger vehicle models will be electric by 2025.5 Increasing availability and affordability of electric vehicles coupled with emissions mandates will continue to drive the demand for EVs and their associated need for the charging infrastructure. This transformation is not only happening in the smaller passenger vehicle segment but also with large commercial vehicles, especially buses. Manufacturers BYD, Proterra and New Flyer currently have electric trucks and buses available. A recent report from Navigant Research indicates battery electric bus sales are up 40 percent from 2016 to 2017.6 The United States currently has over 300 zero emission buses running in various transit agencies throughout the

4 QER Transforming the Nations Electricity System Full Report, source: https://www.energy.gov/sites/prod/files/2017/01/f34/QER%20Transforming%20the%20Nations%20Electricity%20System%20Full %20Report.pdf 5 General Motors is Going All Electric, source: https://www.wired.com/story/general-motors-electric-cars-plan-gm/ 6 Sales of Plug-In Electric Buses Increased 40 Percent from 2016 to 2017, source: https://www.navigantresearch.com/newsroom/sales-of-plug-in-electric-buses-increased-40-percent-from-2016-to-2017 country and the numbers are continuing to increase.7 The Transit Authority of River City in Louisville replaced diesel-powered trolley buses with 10 battery electric buses and utilizes two charging stations that can fully charge one bus in 10-15 minutes.8 The Kansas City Airport is integrating electric shuttles for passenger service with four BYD transit buses.9 Cummins, Tesla and Daimler will bring electric powertrains to all their heavy-duty vehicles in the coming years. Oklahoma City’s Streetcar project is a positive step in the future of electric transportation, as it will introduce six street cars powered by overhead electrical wires and connect passengers across a 4.6-mile route to downtown, Bricktown, Midtown, the Arts District and Automobile Alley. Cities, states, and public and private entities should coordinate their efforts and work together on the deployment of electrified transportation and the necessary supporting infrastructure to keep up with these industry trends. From an emissions perspective, electric buses will provide a significant beneficial impact when compared to tailpipe emissions of other common bus types. These vehicles are commercially available and complement OKC Streetcar project. Replacing transit buses with electric alternatives also aligns with the goals of the trust to reduce NOx emissions and improve air quality in areas that bear a disproportionate share of the air pollution burden within Oklahoma.

5. Recommendation for Mitigation

Current AFV Infrastructure Oklahoma has a record of facilitating public-private partnerships to quickly expand access to alternative fuels. Alternative fuel infrastructure tax credits passed by the State legislature in 2009 led to Oklahoma having more public CNG stations per capita than any other state in the country. There is at least one CNG station every 100 miles on the State’s interstate highways (Image 1).10 However, the number of available public charging stations for electric vehicles is significantly less than the quantity that the U.S. Department of Energy (“DOE”) projects will be needed. For example, the Oklahoma City metro area contains only 13 public electric vehicle charging stations within a 50-mile radius of downtown (Image 2). Recent electric vehicle infrastructure analysis from the DOE suggests that Oklahoma will need at least 230 public DC fast charging plugs and a mix of 4,800 workplace and public level 2 plugs by 2030 to provide a minimum level of charging coverage for projected electric vehicles.11

7 Zero Emissions Bus Operators, source: https://www.transportation.gov/r2ze/fleets-zero-emission-buses-us-and-china 8 Zero Emissions Bus Operators, source: https://www.transportation.gov/r2ze/fleets-zero-emission-buses-us-and-china 9 Kansas City Airport Deploys BYD Fully Electric Buses For Passenger Service, source: https://cleantechnica.com/2017/10/26/byd/ 10 CNG Stations in Oklahoma, source: http://www.cngnow.com/stations/Pages/information.aspx 11 NREL Evaluates National Charging Infrastructure Needs for Growing Fleet of Plug-In Electric Vehicles, source: https://www.nrel.gov/news/press/2017/nrel_evaluates_national_charging_infrastructure_needs.html

Image 1: Current and Planned CNG Stations in Oklahoma

Active Stations

Planned Stations

Image 2: Quantity of EV Charging Stations in Oklahoma

The quantity of charging stations identified on PlugShare might suggest there is a vast network of infrastructure already available for electric vehicles. However, these stations do not accommodate the fast charging needs of commuters, are restricted for use based on the type of vehicle able to charge at them, are only accessible during the business hours of where the equipment is located, and may just be an outlet rather than an actual charging station. A further analysis of these stations indicates there are only two DC fast charging stations and approximately four level 2 stations that are available to the public 24/7 and will accommodate any type of electric vehicle, denoted by the black locations in the image above. Based on the current electric vehicle charging infrastructure, and trends of the auto industry OG&E recommends that the DEQ utilizes a majority (70-80%) of the 15% allocation on the deployment of DC fast charging stations and the remaining light duty equipment allocation (20-30%) on level 1 and level 2 charging stations.

Table 1: DC Fast Charging Stations Open 24/7 for all EV Models Current Electrify America Potential from Trust DOE Estimate Funds Estimate* 2 4 ≥40 230 Note: DC fast chargers needed by 2030 to provide a minimum level of coverage (Source: DOE)

Recommendations for EV Infrastructure Investments In November 2016, all of Oklahoma’s Interstate highways were designated as projected electric vehicle corridors by the Federal Highway Administration (FHA). There is a separate portion of VW Funds that Electrify America is using to install DC infrastructure across the country. Based on recent conversations with Electrify America representatives, OG&E believes that Oklahoma will receive a total of four DC fast charging stations, potential locations include: Bristow, Vinita, Ardmore, and Moore. While this helps lay the foundation for a fast charging network in the state, it is still not sufficient for the current (or future) needs of the EV drivers. Fast charging stations can provide vehicles with over 70 miles of range in approximately 20 minutes which allows ZEV drivers to quickly recharge their vehicles during longer trips, serves as an emergency charging option, and is necessary for electric vehicles with longer ranges. However, it is not cost effective for ideal site hosts, like gas stations, to incur the high upfront costs of installing these stations. The FHA corridor designation, the limited stations Oklahoma will receive from Electrify America, and the cost barriers that potential site hosts face further support utilizing a majority of the 15% allocation on DC fast-charging stations. Traffic flow data, registration data, emissions levels data and future vehicle projections can help to identify strategic areas along Oklahoma’s highways for the placement of the equipment. OG&E can also provide data to the State that identifies locations where the necessary electrical infrastructure already exists. Charging stations along major corridors and highways will form a well-connected network of fast charging infrastructure to serve Oklahoma and surrounding states while meeting the objective of the Trust Funds.

Table 2: Proposed DC Fast Charging Stations

Installation Corridor Brief Description Spacing

Interstate 40 is one of the most travelled highways in the Interstate 40 ≤ 100 miles country and provides excellent visibility, convenience, and accessibility drivers. Interstate 35 is one of the most travelled highways in the Interstate 35 ≤ 100 miles country and provides excellent visibility, convenience, and accessibility drivers. Interstate 44 serves as a highly visible, convenient, and accessible corridor connecting Oklahoma to Wichita Falls, Interstate 44 ≤ 100 miles Texas and Missouri as well as Tulsa, Oklahoma City, Lawton, and many other communities within Oklahoma. US 75/Indian US-75/INT makes up most of the route between Tulsa and Nation ≤ 100 miles Dallas. The corridor also intersects with three other corridors: Turnpike US-69, I-40 and I-44. (INT) US-69 is a major trucking route from Dallas, through Oklahoma US 69 ≤ 100 miles toward Kansas City, St. Louis, Chicago, and Indianapolis. It intersects with three other corridors: US-75/INT, I-40, and I-44. US 270, 62, & ≤ 50-100 These routes connect rural areas of Oklahoma with major 412 miles cities and surrounding states.

An investment in lower levels of charging station equipment ensures that there are a variety of convenient places to charge a vehicle away from home by providing the necessary coverage between DC fast chargers. Level 2 charging, which can replenish approximately 20 miles of range per hour, is most suitable at retail locations or tourism destinations. Airports, hotels and workplaces are suitable places for level 1 charging because it provides between four to six miles of range per hour and these are locations where vehicles will be parked overnight or for long durations of time. There is no current plan for the state to expand the deployment of charging stations nor is there a large presence of third party equipment providers actively installing charging stations in Oklahoma. The trust funds present an opportunity for the State to partner with potential site hosts to install level 1 and 2 charging stations. Site hosts within areas of high levels of commuter traffic or businesses that have electric fleets are prime candidates in the early stages of infrastructure development. Once there is a foundational network of charging stations for public use, accessible 24/7, OG&E believes the market will take over and the business case for site hosts will be proven. Potential locations are described in the following table.

Table 3: Recommendations for Level 1 and Level 2 Charging Stations

Location Brief Description

Retailers that attract or would like to attract customers fitting EV adopter profile can deploy EVSE to aid their marketing and branding efforts. Food Retail markets, shopping malls, and other operations with longer customer dwell times will experience the best opportunities for EVSE. EVSE availability increases an institution’s marketability to prospective Higher Education applicants, faculty, and donors. College towns are well positioned as ideal early adopter communities and destination charging locations.

Sports stadiums, parks, botanical gardens, museums, science centers and other major cultural institutions offer growing EV early adopter demand and good EV Destination exposure. Siting EVSE at these locations extends vehicle range throughout the region, promotes EV awareness in potential EV buyers within similar demographic profiles and supports the interests of the site hosts.

Residents will drive demand for residential charging however, new Multi-Unit construction offers opportunities for low cost EVSE deployment and increases Dwelling marketability to potential tenants.

Offices can offer EVSE usage as a non-fringe benefit to employees while also representing themselves as a cutting-edge firm. Workplace charging is the Workplace second most important opportunity for EV drivers. Workplace charging will also serve businesses with electric fleet vehicles, which can be charged overnight at company locations or at public stations along vehicle routes.

Recommendations for Heavy Duty Vehicle Investments Heavy duty vehicles represent a significant opportunity to maximize the impact of the funds for emissions reductions. Many cities across the U.S. are currently considering or are in the process of changing their fleets over to electric buses. In addition to those mentioned in Section 4, the cities of Albuquerque, Chicago, and Kansas City are also incorporating electric buses into their fleets due to their significant impact on improving air quality and contribution towards emissions goals.1213 EMBARK of Oklahoma City plans to have one electric bus in operation by the Spring of 2019 and has expressed the desire to incorporate more as its existing fleet is ready to be retired. Due to the commercial availability of electric buses and their significant beneficial impact to air quality, OG&E recommends that the DEQ funds projects that accelerate the implementation of electric buses and the necessary infrastructure to support them in the first phase(s) of funding. In future phases, the State should fund other electric heavy-duty vehicles, such as freight trucks and delivery trucks as they become commercially available. Finally, the State should consider installing a 320 kW DC fast charger for demonstration and testing. Battery technology is rapidly advancing and the demand for quicker charging is leading auto manufacturers and EVSE providers to pursue higher power charging. A 320 kW DC fast

12 $16M Federal Grant Will Increase Chicago's Electric Fleet, source: https://www.usnews.com/news/best- states/illinois/articles/2017-10-11/16m-federal-grant-will-increase-chicagos-electric-fleet 13 Electric Vehicles, source: https://www.pnm.com/ev-fleet charger will provide about 19 miles of range per minute.14 These faster charging speeds are necessary to refuel the next generation of electric vehicles that have larger batteries.

6. Anticipated Environmental Benefits Transportation electrification can lead to widespread air quality and other environmental benefits. Some of the benefits to be realized from the implementation of the mitigation actions discussed in this plan include:

• Reduction in urban area vehicle emissions over the lifetime of the vehicles • Reduced public exposure to vehicle exhaust, noise, and visible tailpipe emissions. It is important to note that the range of emission benefits for individual engines and actual NOx emissions reductions will vary based on the type of projects received for funding consideration, and the eligible mitigation projects ultimately funded.

7. Conclusion As the state deliberates on how to utilize the funds awarded by the Trust, OG&E respectfully recommends that the state invest the maximum allowable portion of the funds (initially, 15%, which is equivalent to $2,862,979) towards light duty zero emission vehicle supply equipment (charging stations) and invest the remaining funds towards heavy duty vehicle replacement, such as transit buses.

To achieve the goal of the Plan, OG&E believes it is a priority for the DEQ to fund sizeable and/or transformative projects designed to achieve the greatest emission reduction for the dollar (i.e. capital cost effectiveness in dollars/ton).

Recommended investments include: • Allocate the full 15% of funds allowed for light duty ZEV supply equipment (charging stations) o Majority towards DC fast charging stations o Remaining balance towards level 1 and level 2 charging stations in communities • Direct the remaining 85% of the funds to the deployment of heavy duty, zero emission vehicles and the associated charging infrastructure

EV charging infrastructure investments are critical to putting zero emission vehicles on the road in Oklahoma. In the BMP, the DEQ should allocate the maximum amount of trust funds allowed, 15%, to light duty zero emission vehicle infrastructure. Leveraging the settlement funds for infrastructure projects will help fulfill Governor Fallin’s First Energy Plan to strategically expand EV charging infrastructure in a similar manner as CNG infrastructure. OG&E also recommends that the State allocate the remaining trust funds to replace heavy duty electric ZEVs

14 Cycle 1 National ZEV Investment Plan, source: https://www.electrifyamerica.com/our-plan as they become commercially available. Doing so will support widespread deployment of electrified transportation options, advance the State’s efforts for continued ozone attainment through transportation-related NOx emission reductions, and mitigate common barriers to electric vehicle adoption such as range anxiety from a lack of sufficient charging infrastructure.

We appreciate the opportunity to provide input to the ODQ on this very important undertaking and look forward to participating in the next. More information on OG&E’s EV initiative can also be found at www.oge.com/ev

Should you have any questions, please contact Kevin Lagge at (405) 553 -3000

Sincerely,

Kevin Lagge Director, Development, Innovation & Strategy

Cc: Usha-Maria Turner: Director, Environmental Affairs and Federal Public Policy Oklahoma and the VW Environmental Mitigation Trust Agreement

December 2017 Settlement Milestones October 25, 2016 • Settlement Effective Date

October 2, 2017 • Trust Effective Date (TED)

December 1, 2017 • Oklahoma Beneficiary Certification Filing Deadline

December 5, 2017 • State of Oklahoma Public Meeting

January 30, 2018 • Trustee issues Notice of Beneficiary Designation

30 Days before Initial Funding Request • Oklahoma Beneficiary Mitigation Plan Deadline

1 Source: Oklahoma Department of Environmental Quality VW Settlement Trust Fundamentals

• Trust Objective: Reduce Emission of NOx where the 2.0 & 3.0L Subject Vehicles were, are, or will be operated • Beneficiary Mitigation Plan (BMP) Requirements: i. Overall goal for the use of the funds ii. Recommendation of the categories of Eligible Mitigations Actions (EMA) that the Beneficiary anticipates will be appropriate to achieve the stated goals and the preliminary assessment of the percentages of funds anticipated to be used for each type of EMA iii. Description of how the Beneficiary will consider the potential beneficial impact of the selected Actions on air quality in areas that bear a disproportionate share of air pollution burden within its jurisdiction iv. A general description of the expected ranges of emission benefits the Beneficiary estimates would be realized by implementation of the Plan • Other BMP Details: i. BMP only needs to provide the level of detail “reasonably ascertainable” at the time of submission ii. Beneficiaries may adjust their goals and specific spending plans at their discretion, but must provide Trustee with updates to BMP iii. The Beneficiary shall explain the process by which the Beneficiary shall seek and consider public input on its BMP

2 Eligible Mitigation Actions cover a variety of potential transportation projects

• Class 7-8 School Shuttle or Transit • Freight Switchers Buses • Light Duty ZEV • Ferries/Tugs Supply Equipment • Up to 15% of

GoingVessels allocation of Road Vehicles Road Road Vehicles Road - - - Trust Funds on acquisition, On • Class 8 Local installation, Freight/Port Drayage Non • Airport Ground operation and

Trucks Ocean Service Equipment maintenance of EVSE

ZEV Supply Equipment • Includes L1, L2, DCFC located in • Shore Power public place, workplace, or • Class 4-7 Medium Multi-Unit Local Freight Trucks • Forklifts Dwellings

• DERA - can be utilized for non-federal match or overmatch pursuant to Title BII, Subtitle G, Section 793 of the DERA Program in the Energy Policy Act of 2005 3 Recommended Eligible Mitigating Actions

1. Allocate the full 15% of funds allowed for light duty ZEV equipment (charging stations)

2. Direct the remaining 85% of the funds to the deployment of heavy duty, zero emission vehicles and the associated charging infrastructure

4 Eligible Mitigating Action Plan Recommendation for Light Duty ZEV Equipment (Charging Stations)

• Develop and implement an electric highway corridor deployment plan for the installation of DC fast charging stations throughout Oklahoma

• Develop and implement an urban area deployment plan for the installation of level 1 and level 2 charging stations at highly-utilized commuter locations and high- density urban areas

5 Problems Addressed by the Light Duty ZEV Equipment Plan Recommendation

Highway Corridor Issues • There is no existing plan for open access charging station deployment in the state of Oklahoma • Only Tesla vehicles can charge at Tesla DC fast charging stations Urban Area Issues • Per PlugShare, there are over 100 charging stations in Oklahoma, however a majority of these level 2 charging stations are located at dealerships so they are only available during hours of operation and may only be for vehicle models sold by that dealership • Additional restrictions prohibit use of level 2 charging stations at RV parks and Tesla Fast Charging Station hotels Open to Public 24/7 Non-Restricted

Source: PlugShare 6 Benefits of the Light Duty ZEV Equipment Plan Recommendation

Highway Corridor Benefits • Enables long-range vehicles travel along the major highway corridors • Aligns with the Federal Highway Administration’s designation of major transportation corridors as electric corridors and Governor Fallin’s First Energy Plan Urban Area Benefits • Prime the market to generate an increase in demand for additional level 1 and level 2 charging stations • Focus on areas affected by emissions and which are highly Tesla Fast Charging Station Recommendation for Additional DC Fast utilized commuter and traveler Charging Stations locations (not pictured on the map) Open to Public 24/7 Non-Restricted 7 Source: PlugShare Eligible Mitigating Action Plan for Heavy Duty Vehicle Replacement

• Develop and implement a fleet replacement plan for the deployment of commercially available zero emission vehicles • Phase 1 – electric transit buses (commercially available) • Phase 2 – other heavy duty, high-use vehicles (when available e.g. delivery/freight trucks) • Because reducing NOx emissions tends to reduce ozone pollution, focus should be on areas in Oklahoma with relatively high levels of ozone pollution

8 According to the DOT Race to Zero Emissions challenge, electric buses have the following characteristics Removes 10 tons of NOx and 350 pounds of diesel particulate matter

One electric bus Eliminates 1,690 tons of CO2 over 12 year lifespan

Is equivalent to removing 27 conventional vehicles off the road

Source: US Department of Transportation 9 Appendix

10 Methodology for Potential DC Fast Charing Sites (see map on next slide)

• Draw a circle around the center of downtown Oklahoma City radius of 50 miles • Draw subsequent circles in each direction using the same 50 mile radius until the borders of the state are reached • Use registration, traffic flow and emissions levels data, existing stations/availability, and projected demand to: • Mark a potential DC fast charging site at the intersections of the circles along highway corridors • Indicate clusters of level 2 stations within cities

11 12

Britta K. Gross Director Advanced Vehicle Commercialization Policy Environment, Energy & Safety Policy

General Motors Global Headquarters MC: 482-C30-C76 300 Renaissance Center Detroit, MI 48265-3000

4 December, 2017

Ms. Heather Lerch Oklahoma Air Quality Division PO Box 1677 Oklahoma City, OK 73101 [email protected]

Subject: GM Comments relative to Oklahoma’s VW Environmental Mitigation Trust (EMT) Fund

General Motors LLC (GM) appreciates the opportunity to provide input on the use of funding in the state’s Environmental/Beneficiary Mitigation Plan and would like to encourage Oklahoma to use the maximum allowed 15% of the fund (equating to about $3mil) to increase the availability of critically- needed electric vehicle (EV) charging stations. There are currently about 2,000 EVs registered in Oklahoma, and in order to grow the EV market and attract even more advanced transportation technologies to the state, such as self-driving EVs, Oklahoma needs to invest in a charging infrastructure network that addresses consumer and industry concerns.

Automakers have made enormous investments in the electrification of transportation – GM alone has invested billions of dollars to develop electrification technologies, including the state-of-the-art Chevrolet Volt and Chevrolet Bolt EV, which has swept the industry’s most prestigious car awards, including North America Car of the Year, Motor Trend’s® 2017 Car of the Year, MotorWeek’s 2017 Drivers’ Choice “Best of the Year” Award, and Green Car Journal’s Green Car of the Year. The Bolt EV is the industry’s first affordable, long-range EV with an EPA estimated range of 238 miles-per-charge. Last month, after 8 months of continual sales growth, the Bolt EV was the top-selling EV in the United States. This advanced technology will require more widespread charging infrastructure to convince consumers that EVs can be driven anywhere they need to go. Thus, the urgency to rapidly expand EV charging infrastructure in Oklahoma.

While the majority of all EV charging today is done at the home, there are still critical infrastructure needs not met by single-family home charging. And to maximize the impact of limited state funds, it is important to invest strategically. GM would prioritize today’s key infrastructure needs as follows:

1. Highway corridor DC fast-charging most visibly inspires consumer confidence in the driving range, and practicality, of EVs. A 2016 survey of 2,500 consumers by Altman Vilandrie &

Company found the top reason customers gave for not wanting to purchase a plug-in electric vehicle was a perceived lack of charging stations (85%). Highly visible corridor EV charging (SAE industry standard) can help address this consumer perception issue. 2. Workplace EV charging creates an EV “showroom” that very effectively grows EV awareness among corporations, and employees of these corporations. According to US DOE data, workplace charging results in employees 6X more likely to purchase an EV than employees at companies not offering workplace charging. 3. Multi-unit dwelling EV charging provides an important opportunity to expand EV adoption to consumers residing in townhomes, condominiums, and apartments, who may not have access to a “home” charger every evening. This is currently an untapped segment of potential EV buyers. This need can be met by Level 1 or Level 2 charging directly at the multi-unit dwellings, or by neighborhood DC fast-charge hubs that can serve these residents. 4. Public EV charging at key destinations is also important to increase the practicality of EVs and the number of places an EV can go, with a special focus on destinations typically outside a consumer’s normal daily driving patterns (e.g. airports, beaches, hotels, resorts, etc.).

EV charging infrastructure is vital to the growth of the EV market and will lead to long-lasting emissions reductions that increase over time as the market expands. And Oklahoma’s low electricity prices mean that electric vehicles are an important economic driver for Oklahoma. Finally, we encourage the state to directly engage all electric utilities in the strategic planning of EV infrastructure to ensure the most cost-effective and grid-responsible EV charging solutions.

The VW Environmental Mitigation Trust is an opportunity to invest in forward-looking infrastructure that lays a much-needed foundation for EV market growth and will help attract even more advanced transportation technologies to Oklahoma. GM greatly appreciates Oklahoma’s commitment to support the strategic transition to transportation electrification and all efforts to help drive this emerging market.

Sincerely,

Britta K. Gross, Director Advanced Vehicle Commercialization Policy [email protected] (586) 596-0382

May 11, 2017

The Honorable Mary Fallin Governor State of Oklahoma 2300 N. Lincoln Blvd. Room 212 Oklahoma City, OK 73105

RE: NGVAmerica Comments on the Volkswagen Diesel Emissions Settlement and the Environmental Mitigation Trust Implementation for the States

Dear Governor Fallin:

Natural Gas Vehicles for America (NGVAmerica), the national trade association for the natural gas vehicle industry, respectfully submits the following comments on how the State of Oklahoma can best use the Environmental Mitigation Trust (EMT or Trust) funds ($20.9 million) that the state will receive as part of the Volkswagen (VW) diesel emission settlement. These comments are intended to inform the decision-making process as Oklahoma begins to consider and develop the Environmental Mitigation Plan required by the Trust.

The VW EMT funds provide an extraordinary opportunity for Oklahoma and other states to put significantly cleaner, lower-polluting vehicles on the road in public and private fleets. Oklahoma has a strong achievement record of providing significant incentives for such vehicles and this funding will provide Oklahoma with additional resources to continue its commitment to accelerating the use of cleaner, alternative fuels that offer a cost-effective alternative to funding diesel vehicles.

The latest natural gas engines are the only “near-zero” engines that are certified to perform at 0.02 g/bhp-hr of nitrogen oxide (NOx) emissions or better and should not be confused with diesel engines certified to the 2010 EPA standard of 0.2 g/bhp-hr NOx standard.1 The 0.02 g/bhp-hr NOx standard requires that engines outperform the federal standard by 90 percent and is the cleanest heavy-duty engine standard today. It also is the lowest level currently recognized under California’s Optional Low-NOx Standard (OLNS) for engines.

NGVAmerica’s comments rely on data generated by evaluating the latest commercially available technology when comparing emissions benefits between natural gas, diesel and electric vehicle and engine types. Natural gas engines are the only available internal combustion engines that have been certified to California’s 0.02 OLNS and thus are the only true Near Zero engines available in the marketplace today. Additionally, if renewable natural gas (RNG) is used, life cycle emissions from NGVs are reduced further. Putting more NGVs on the road today provides a strong customer base for the growing RNG market.

1 See SCAQMD press release from June 3, 2016 providing details on the petition filed by state authorities urging the U.S. EPA to adopt the 0.02 NOx standard (http://www.aqmd.gov/home/library/public-information/2016-news-archives/nox- petition-to-epa) (Today’s action follows a March 4 vote by the SCAQMD’s Governing Board to formally petition the U.S. EPA to adopt a so-called “near-zero” or “ultra-low” emissions standard for heavy-duty truck engines that is 90 percent cleaner than the current standard).

Compared to other alternative fuels and to diesel vehicles, natural gas vehicles that are commercially available today, offer the best solution for addressing the goals of the EMT and delivering the most nitrogen oxide (NOx) emission reductions for the lowest cost.

The following pages outline key facts related to vehicle emissions, total cost of ownership, and current availability, and NGVAmerica's recommendations on how EMT funds can be allocated effectively for reducing emissions.

The Need to Take Meaningful Action Today

The funding available through Volkswagen's Environmental Mitigation Trust comes at a time when it is critical to address transportation emissions. The American Lung Association's "State of the Air 2016" report found that air pollution continues to be a pressing concern with more than half of all Americans—166 million people—living in counties where they are exposed to unhealthful levels of ozone and particulate pollution.

Medium- and heavy-duty on-road vehicles are the number one source of ozone-forming emissions of nitrogen oxides (NOx) in almost every metropolitan region in the U.S., therefore there is considerable opportunity to develop and deploy funding programs that make an immediate and tangible impact on air quality and related public health issues.

Approximately Medium- and 50% of Americans heavy-duty live in vehicles are the areas with air that #1 source of is unhealthy to smog breathe

Sustainable, Responsible, Available: Natural Gas Vehicles

Today's natural gas vehicles (NGVs) are proven technologies that can uniquely, immediately, and cost-effectively transform our nation’s medium- and heavy-duty transportation sector. The advantages of natural gas as a transportation fuel include its domestic availability, widespread distribution infrastructure, low cost, and inherently clean-burning qualities.

In these comments NGVAmerica presents the compelling reasons that states should prioritize funding for NGVs to maximize the impact of the available funding. As your organization is aware, the EMT was set up to fund projects that make an impactful reduction on NOx emissions to mitigate the excess emissions currently in our air from the non- compliant light-duty diesel vehicles VW sold. NGVAmerica strongly believes that NGVs are the best solution to meet the core goals put forth by the Volkswagen EMT funding. NGVs are:

1. Sustainable: NGVs maximize long-term emission reductions 2. Responsible: NGVs extend the funding and foster economic development 3. Available: NGVS meet the diverse operating requirements of every fleet application

1. Sustainable: NGVs Maximize Long-Term Emission Reductions

 Key Point: Today’s natural gas medium- and heavy-duty engines provide unmatched reductions of smog- forming emissions of nitrogen oxides (NOx).

“Near Zero-Emissions”: EPA and CARB Certified a Heavy-Duty Natural Gas Engine to 0.02 g Standard Today's natural gas

engines offer a 90% In September 2015, the U.S. Environmental NOx reduction over Protection Agency (EPA) and the California Air the EPA’s strictest Resources Board (CARB) certified the world’s emission standards, first heavy-duty engine that emits oxides of making them the nitrogen (NOx) at levels so low that they are cleanest commercially considered at “near-zero” (0.02g NOx/bhp-hr). available technology This is the cleanest commercially available heavy-duty truck engine available in the market today, offering the ability to reduce emissions 90% below even the most stringent U.S. EPA standards.

NGVs Have Lower NOx Emissions Than All-Electric Trucks

The emission benefits of the new “Near-Zero” engine are well documented in the 2016 Game Changer report issued by 2 Gladstein, Neandross and Associates (GNA) . The GNA report The “Game Changer” report indicates that a truck or bus equipped with a natural gas shows that “Near-Zero” NGVs engine that has been certified to the 0.02 g/bhp‐hr Optional are cleaner than “Zero-Emission” Low NOx Standard has tailpipe NOx emissions that are All-Electric trucks comparable to – or possibly lower than – the amount of NOx emitted to produce electricity used to charge a comparable heavy-duty All-Electric Truck.

2 Gladstein, Neandross & Associates, Game Changer Technical White Paper (2016) http://ngvgamechanger.com/, Section 6.4 and Appendix 1. Emissions of low‐NOx natural gas engines produce NOx emissions that are comparable to or lower than similar electric drive vehicles in all 50 U.S. states when considering upstream NOx.

Critical Insight: Study Finds that Natural Gas Engines Outperform Diesel Engines in Real World Situations

Natural gas (NG) engines today meet an optional Low NOx standard that is ten times cleaner than the standard required for new diesel and natural gas engines. However, the in-use emission benefits of NG engines could be even more significant.

A recent report published in Environmental Science and Technology3, evaluated in-use emissions of earlier model year NG vehicles and found that NG engines performed much better in real world conditions (i.e., operating within city limits in low-speed, high-idling Heavy-duty drayage trucks: situations), registering NOx levels that were 96% lower than levels produced by tested diesel engines equipped with the latest Diesel trucks tested in study emissions controls. The study found that diesel NOx emissions exceed certification level operating in similar conditions produced emissions that were 5 -7 times higher than in-use certification limits in some cases.

Related Recommendations for EMT Funding  Provide a higher level of funding for technologies that are proven to exceed federal emission levels for nitrogen oxides . Vehicles with engines certified to California’s Optional Low‐NOx Standard should receive the highest level of funding (e.g., 25% in the case of private sector vehicle replacements) . Use the state's approved DERA plan to fund low-NOx natural gas trucks (i.e., 35% of the replacement cost for private vehicles equipped with low-NOx engines)

 Provide the highest level of funding to applications that will reduce the largest share of NOx emissions . Evaluate the main mobile source(s) of NOx emissions in urban and non-attainment areas (Note: In most regions, this means prioritizing funding for short-haul, regional-haul, and refuse trucks) . Do not segment the funding – fund the projects that best achieve the most NOx reductions

3 Environ. Sci. Technol., 2015, 49 (8), pp 5236–5244 (Emission Rates of Regulated Pollutants from Current Technology Heavy-Duty Diesel and Natural Gas Goods Movement Vehicles).

2. Responsible: NGVs Extend the Funding and Foster Economic Development

 Key Point: NGVs are far more cost-effective in delivering emission reductions than other alternative fuel options, such as hybrid and electric vehicles. NGVs Offer a Fast Return on Investment

While NGVs typically cost more than gasoline or diesel vehicles upfront (largely due to the cost of high-pressure and insulated fuel tanks which are necessary to store CNG or LNG), owners and operators of high mileage vehicles typically see a pay back in as little as 18–24 months.

This is due to:

 Lower Fuel Costs: Natural gas fuel prices have historically had a significant discount relative to gasoline and diesel and Due to lower fuel and maintenance offer more stability compared to the costs of petroleum based costs, NGVs offer an 18 to 24 month fuels. Lower oil prices have recently reduced the differential in payback. As production increases and price, but according to the Energy Information Agency, the long- fuel tank prices come down, vehicles term outlook is for natural gas prices to remain stable and low, will become less expensive and enjoy a while volatility and higher prices return for gasoline and diesel shorter payback period fuels. For many users, the savings in fuel costs can translate into significant savings over the life of a vehicle, depending on fuel efficiency and the number of miles driven. The greatest savings are currently being seen in heavy-duty, high mileage fleets.

 Lower Maintenance Costs: NGVs are easier and cheaper to maintain than diesel trucks because they have: o No diesel particulate filter (DPF) o No DPF regeneration or waste disposal o No selective catalytic reduction (SCR) o No diesel emission fluid (DEF)

NGVs Have Been Road-Tested by Leading Fleets

There are more than 160,000 NGVs on U.S. roads today, spanning all weight classes and vehicle applications. The adoption of NGVs has been pioneered by several high-profile fleet operators, including UPS, Anheuser-Busch, Kroger, FedEx, Frito Lay, Waste Management, LA Metro, all of which performed exhaustive analysis to determine the best vehicle and fueling options for their fleet based on application, range, duty cycle, and payload.

Given the significant fuel and emission reductions realized by early

adopters, the popularity of NGVs has continued to build in the U.S., with High-profile fleets across the U.S. are using natural gas vehicles in their 20% of all U.S. transit buses now running on CNG or LNG, 35 airports everyday operations, transporting operating NGVs in their private fleets or championing policies that passengers, and hauling waste, encourage use by private fleets, and more than 50% of new refuse trucks packages, beverages, and other goods running on natural gas.

To fuel these vehicles, natural gas infrastructure is rapidly expanding with more than 1,640 CNG and 123 LNG fueling stations operating today.

Dollar-for-Dollar Natural Gas Delivers Greater Numbers of Total Vehicles and Greater Total Tons of NOx Emission Reductions

This is illustrated by the chart below which looks at several different funding options for natural gas and electric vehicles including providing 100% of the cost of new, replacement vehicles for public fleets, using the maximum funding levels specified in the settlement for natural gas and electric vehicles purchased by private fleets, or funding only the incremental cost of new, replacement vehicles. In each case, the deployment of natural gas vehicles (e.g., regional haul trucking, refuse trucks, and transit buses) will provide the most NOx emissions reduction to comply with the EPA’s latest national ozone standards.

Chart: Heavy-Duty Truck Deployment & NOx Reduction Comparisons Under Different Funding Scenarios

Critical Insight: Comparable All-Electric Vehicles Cost 2-3x More Than an NGV

While actual cost depends on the application, an all‐electric medium- or heavy‐ duty vehicle usually costs two to three times the amount of a comparable vehicle powered by a 0.02 g NOx natural gas engine. As noted above, funding heavy-duty NGVs delivers greater emission reductions than similar projects involving all- electric trucks, and they offer the best ability to reduce emissions on a large scale because the funding will extend further.

Related Recommendations for EMT Funding  Ensure that funding incentivizes adoption by both public and private fleets . While it might be tempting to fund public vehicles at the 100% level, this will limit the total number of deployed vehicles and therefore lessen the overall emission reductions . Funding levels should be large enough to offset the incremental cost (as compared to cost of a new diesel vehicle) of new, cleaner vehicles, as well as to address the fact that replaced vehicles must be scrapped . For private fleets, use available state funding sources to supplement the Volkswagen funds to ensure that new, cleaner trucks are truly incentivized by covering the full incremental cost (compared to baseline diesel vehicles) and to address economic loss associate with scrappage

 Prioritize funding for clean vehicles rather than fueling infrastructure . Funding should be used to incentivize fleets and vehicle acquisitions where existing fueling infrastructure exists to better support investments that have already been made . If fueling infrastructure needs to be developed, funding should be secured as part of private- public partnerships. Using the funding in this way will encourage additional economic development in the state and increase the availability of stations for future deployments

3. Available: NGVs Meet the Diverse Operating Requirements of Every Fleet Application

 Key Point: Dozens of models of medium- and heavy-duty low-emission natural gas vehicles and engines are commercially available from reputable, world-known OEMs with established sales and service networks.

Wide Array of NGV Options Commercially Available

There are many natural gas vehicle options available from several original equipment manufacturers (OEM). These vehicles can be purchased from the dealership through a process that has been streamlined for the customer.

Many other medium- and heavy-duty vehicle options are available through small vehicle modifiers (SVM). These companies manufacture conversion systems that have been certified and approved by the U.S. Environmental Protection Agency and/or the California Air Resources Board. These approved systems can be installed on new and used vehicles to run on natural gas.

Additionally, Cummins Westport currently offers the 6.7L ISB-G, 8.9L ISL-G and the 11.9L ISX-G natural gas engines. These spark-ignited engines are used in a variety of

applications, including refuse trucks, transit buses, cement trucks, short- and regional-haul tractors, delivery trucks, school buses, and shuttles. Roush offers a school bus engine that is certified to the Low-NOx standard of 0.10. Retrofit and repower options are also available from a variety of manufacturers.

For a full list of EPA and CARB certified engines, visit www.ngvamerica.org/vehicles/vehicle-availability. A list of available NGV manufacturers and conversion companies follows.

HD Vocational OEMs HD Bus OEMs MD Retrofits Autocar Truck Blue Bird Bus AGA Systems Capacity DesignLine Altech-Eco Crane Carrier El Dorado Crazy Diamond Performance Elgin Gillig Greenkraft Johnston New Flyer/NABI Bus Landi Renzo USA/Baytech Kalmar NOVA Bus M-Tech Solutions McNeilus Motor Coach Industries NAT G Mack Thomas Built Bus NGV Motori USA Peterbilt PowerFuel Conversions Power Solutions Int’l. HD Retrofit/ Roush CleanTech Schwarze Repowers STAG Tymco Westport Fuel Systems American Power Group Zavoli Clean Air Power

HD Truck OEMs Diesel 2 Gas Cummins Westport Fyda Energy Solutions Fuel Systems Freightliner NGV Motori Agility Fuel Systems Kenworth Omnitek Engineering Mainstay Mack Momentum Fuel Peterbilt Technologies Volvo

Critical Insight: Heavy-Duty Electric and Fuel Cell Vehicles are Not Commercially Available

As of today, three unique fuel-technology combinations hold the most promise to successfully transform America’s HDV transportation sector to zero and near-zero emissions:

1. Near-zero-emission internal combustion engines fueled by conventional or renewable natural gas 2. Zero-emission battery-electric-drive systems 3. Zero-emission hydrogen fuel cell systems

While battery-electric and hydrogen fuel cell systems can offer extremely low emissions profiles, the lack of commercially available heavy-duty and limited medium-duty products and charging/fuel distribution networks makes implementation in the near future impractical. Furthermore, these vehicles are being developed by niche, start-up companies and have only been used in early test programs; comparatively, medium- and heavy-duty NGVs from major OEMs have been widely, commercially available in dozens of applications for over two decades. Near- zero-emission internal combustion engines fueled by conventional or renewable natural gas are the only option to immediately and cost-effectively provide extremely low NOx and GHG emissions in high-impact HDV sectors.

Related Recommendations for EMT Funding  Prioritize funding for commerically available products . Given that the NOx emissions from Volkwagen vehicles are already in the air, funding should be concentrated to projects that allow us to deploy the cleanest vehicles available today (i.e., not pre- commercial or research and development projects)

 Scale funding to incentivize the cleanest engines available . Provide greater funding for medium- and heavy-duty engines that deliver NOx reductions over and above what is currently required for new diesel vehicles . Given that the EMT was created because of NOx pollution associated with non-compliant diesel vehicles, we believe that the funding should be set aside for clean, alternative fuel vehicle projects and should not be used to fund more diesel fueled vehicles

Let’s Transform Clean Transportation Together

NGVAmerica and its members are eager to serve as a resource to assist the State of Oklahoma in its evaluation and development of the state’s Beneficiary Mitigation Plan. We strongly encourage the state to recognize the superior and unmatched role that natural gas vehicles can play in delivering nitrogen oxide (NOx) emissions reductions required by the settlement and Trust.

NGVAmerica welcomes the opportunity to meet with you to provide further information and analysis on the economic and environmental benefits of natural gas vehicles in Oklahoma. Please contact Jeff Clarke, NGVAmerica General Counsel & Director Regulatory Affairs at 202.824.7364 or [email protected], or Sherrie Merrow, NGVAmerica State Government Advocacy Committee Chair at 303.883.5121 or [email protected] to set up a meeting and for additional information.

Sincerely,

Matthew Godlewski President

Summary of NGVAmerica’s Recommendations for EMT Funding

 Provide a larger incentive and greater overall funding for medium- and heavy-duty engines that deliver greater NOx reductions than currently required for new vehicles and engines  Target funding for technologies that have demonstrated the ability to deliver actual lower in-use emissions when operated in real-world conditions  Provide the highest level of funding to applications that produce the largest share of NOx emissions (in most regions this means prioritizing for short-haul, regional-haul and refuse trucks)  Prioritize funding for commercially available products that are ready to begin  Prioritize funding for clean vehicles rather than fueling infrastructure  Scale funding to incentivize the cleanest engines available  Ensure that funding incentivizes adoption by both public and private fleets  Accelerate the funding in the early years to maximize the NOx reduction benefits  Given that the EMT was created because of NOx pollution associated with non-compliant diesel vehicles, we believe that the funding should be set aside for clean, alternative fuel vehicle projects that focus on maximizing NOx reduction for the funds spent

December 4, 2017

Ms. Heather Lerch Department of Environmental Quality Air Quality Division P.O. Box 1677 Oklahoma City, OK 73101

RE: NGVAmerica Comments on Oklahoma’s Implementation of the Environmental Mitigation Trust Funds Provided by the VW Settlement

Dear Ms. Lerch:

Natural Gas Vehicles for America (NGVAmerica), the national trade association for the natural gas vehicle industry, respectfully submits the following comments and recommendations to the Oklahoma Air Quality Bureau. These comments are in addition to the NGVAmerica comments submitted to Gov. Fallin on May 11, 2017 (attached) regarding NGVAmerica’s recommendations on how states can best use the Environmental Mitigation Trust (EMT or Trust) funds that each state will receive as part of the Volkswagen (VW) diesel emission settlement.

The VW EMT funds provide an extraordinary opportunity for Oklahoma to cost-effectively transition to cleaner fuels and lower emission vehicles. Whether regional trucking, waste hauling, medium duty delivery, transit or school buses, commercially-available natural gas vehicles offer the best solutions for addressing the goals of the EMT, delivering the most nitrogen oxide (NOx) emission reductions for the least cost. NGVA’s May comment letter detailed the value of natural gas in fulfilling the goals of the VW EMT, illustrating that commercially available natural gas vehicles offer the best solutions by providing the most cost-effective option for reducing nitrogen oxide (NOx) emissions.

Current State Beneficiary Mitigation Plans

Twelve states have released draft VW Mitigation Plans and NGVAmerica has reviewed these plans and offered comments to these states. NGVAmerica believes the Colorado Plan provides an excellent model for other states that wish to segment their funding, maximize the use of alternative fuels, and provide parity among alternative fuels. However, Colorado has $68 million in VW funding and states with less funding may want to follow Nevada’s VW Plan that takes 80% of the funding and will approve projects that meet the goals of the EMT and the State of Nevada, using a subset of the eligible project categories. Links to the two Plans follow:

NV Draft VW Plan

https://ndep.nv.gov/uploads/air-vwset-docs/draft-bmp.pdf

CO Draft VW Plan

https://www.colorado.gov/pacific/sites/default/files/AP_VW_Beneficiary_Mitigation_Plan.pdf

Colorado’s VW Plan goals are well-stated, and the Plan maximizes the deployment of current successful technologies to reduce NOx emissions for the lowest cost, and essentially creates equity among fuels for incentive funding. The stated goals of the CO Plan are those that NGVAmerica agrees with and are as follows:

o Maximize the trust's air quality benefits in Colorado (reduce NOx, GHG, other pollutants) o Catalyze the adoption of zero emission and alternative fuel vehicles o Distribute funds quickly (within 5 years) - emphasis is on ready projects and will be "first come, first served" o Appropriately balance the cost of the project and emission reduction benefits o Focus on but not limited to areas of non-attainment, location of VWs and environmental justice communities

The CO Plan funding details (vehicles are OEM only and require scrappage) are summarized as follows:

o $18M Alt Fuel Trucks/School and Shuttle Buses (pages 12-14) . New diesel only allowed for fleets of 9 trucks or less . Government and public entities funded at about 40% of total vehicle cost with caps . Private funded at about 25% of total vehicle cost with caps

o $18M Alt Fuel/EV Class 4-8 Transit Buses (pages 14-16) . VW funding to be combined with existing funds . Applicant per bus portion to be less than $100,000

o $12.2M Flex Funds to be used in response to market demand for eligible mitigation actions - to be spent after the initial allocations to other programs

o $5M DERA option

o $10.3M EV Chargers/infrastructure

o $5.2M Administrative Costs

In allocating the funds above, Colorado did not pick a preferred fuel and kept the categories simple and broad. The $18M for Alt Fuel Trucks/School and Shuttle Buses, CO funds all alternative fuels at 40% of the vehicle cost for government and public entities, while private vehicles are funded at 25% of the vehicle cost (not the 75% allowed for EVs because that would use the funds for a smaller number of vehicles (reducing less NOx) and there are other sources for EV funding).

Colorado has other funding they can apply to Transit, so they created a structure to augment the funding provided by the $18M segment. The $12.2M in Flex Funds is a good idea because these funds may be used to support projects in the segments that are successful and oversubscribed. For the DERA option, LNG drilling rig and hydraulic fracturing engines, mining trucks and locomotives are potential projects.

Also, Colorado also has indicated that they will use their Alt Fuels CO Vehicle Grant Program application tool to manage this segment and they are very willing to share this tool with other states. The link to the Alt Fuels Colorado Grant Program is: http://cleanairfleets.org/programs/alt-fuels-colorado.

NGVAmerica also recommends that states consider the following factors in developing Mitigation Plans:

o Increase the options for scrappage beyond a strict replacement of a current fleet vehicle (allow another fleet to provide a vehicle for scrappage; purchase a vehicle for scrappage; etc.)

o Since the Trust does not specify the fuel of the scrappage vehicle, allow natural gas vehicles that meet the year criteria to be scrapped and replaced with new NGVs

o Use the Argonne National Laboratory’s AFLEET tool to calculate vehicle / fuel type emissions since this tool has recently been updated to include current data on all vehicles and fuels including in use emissions data. The AFLEET Tool 2017 updates include:

 Added low-NOx engine option for CNG and LNG heavy-duty vehicles  Added diesel in-use emissions multiplier sensitivity case  Added Idle Reduction Calculator to estimate the idling petroleum use, emissions, and costs for light-duty and heavy-duty vehicles  Added well-to-pump air pollutants and vehicle cycle petroleum use, GHGs, and air pollutants  Added more renewable fuel options  AFLEET Tool Version History.pdfAFLEET Tool spreadsheet and user manual at: http://greet.es.anl.gov/afleet_tool and tool link is: http://www.afdc.energy.gov/tools

Summary of NGVAmerica’s Recommendations for EMT Funding

 Given that the EMT was created because of NOx pollution associated with non-compliant diesel vehicles, we believe that the funding should be set aside for clean, alternative fuel vehicle projects that focus on maximizing NOx reduction for the funds spent  Provide a larger incentive and greater overall funding for medium- and heavy-duty engines that deliver greater NOx reductions than currently required for new vehicles and engines  Target funding for technologies that have demonstrated the ability to deliver actual lower in-use emissions when operated in real-world conditions  Provide the highest level of funding to applications that produce the largest share of NOx emissions (in most regions this means prioritizing for short-haul, regional-haul and refuse trucks)  Prioritize funding for commercially available products that are ready to begin  Prioritize funding for clean vehicles rather than fueling infrastructure  Scale funding to incentivize the cleanest engines available – at a minimum, provide parity among alternative fuels by following a version of the Colorado VW Plan that funds non-diesel alternative vehicles in the private sector at 25% of the cost of the vehicle and public sector vehicles at 40%  Ensure that funding incentivizes adoption by both public and private fleets  Prioritize projects that include partnerships that provide a match such as a CNG or LNG station being built in locations with appropriate pressure natural gas to fuel the vehicles that will receive the VW funding  Accelerate the funding in the early years to maximize the NOx reduction benefits  Use vehicles emissions measurement tools that reflect current technologies and performance under real world operation duty cycles – Argonne National Laboratory’s AFLEET tool is the most current

NGVAmerica and its members are eager to serve as a resource to assist Oklahoma in its evaluation and development of the state’s Mitigation Plan. We strongly encourage the state to recognize the unmatched role that natural gas vehicles can play in delivering NOx emissions reductions required by the settlement and Trust.

NGVAmerica welcomes the opportunity to meet with you to provide further information and analysis on the economic and environmental benefits of natural gas vehicles in Oklahoma. Please contact Jeff Clarke, NGVAmerica General Counsel & Director of Regulatory Affairs at 202.824.7364 or [email protected], or me at 303.883.5121 or [email protected] to set up a meeting and for additional information.

Sincerely,

Sherrie Merrow Director, NGVAmerica State Government Advocacy [email protected] 303.883.5121

Volkswagen Diesel Settlement Funding Opportunity Make a Bold Impact on Air Quality Today Allocating funds to deploy low-NOx natural gas vehicles provides the best way to deliver immediate and cost-effective NOx reductions and air quality benefit. Nearly 40% of Americans are exposed to unhealthful levels of ozone and particulate pollution. Volkswagen’s $2.9 billion Environmental Mitigation Trust fund provides each state an incredible opportunity to make an immediate and tangible impact on air quality by targeting medium- and heavy-duty vehicles, the leading source of these toxic air contaminants in almost every metropolitan area.

Natural gas vehicles (NGVs) are transforming the medium- and heavy-duty transportation sector.

Sustainable: Responsible: NGVs Offer the Cleanest Heavy-Duty Dollar-for-Dollar, NGVs Deliver the Most Cost- Truck Engines in the World Effective NOx Emissions Reductions

Comparing EPA Engine Certifications The calculations shown below assume the deployment of the cleanest

commercially available model for each application. Funding natural gas 0.2 vehicles will lead to the largest total reduction in NOx emissions. 9 0% Short/Regional Haul Trucks C le $ $ $ ane 39 54 85 r per lb of NOx per lb of NOx per lb of NOx

0.02 Natural Gas Diesel Electric Technology Cost $150,000 Technology Cost $100,000 Technology Cost $324,000 EPA Engine Certiﬁcation 0.0 NOx Reduced 3,810 lbs NOx Reduced 1,858 lbs NOx Reduced 3,810 lbs Cleanest Diesel Cleanest Natural Engine Gas Engine EPA NOx Emission Standard Refuse Trucks New Ultra-Low NOx Natural Gas Heavy-Duty Vehicle Emissions $140 $190 $313 Natural gas medium- and heavy-duty engines provide per lb of NOx per lb of NOx per lb of NOx unmatched reductions of smog-forming emissions of nitrogen oxides (NOx). In 2015, a revolutionary natural gas engine was certified by the U.S. Environmental Protection Agency and California Air Resources Board to a level 90% below the Natural Gas Diesel Electric Technology Cost $300,000 Technology Cost $270,000 Technology Cost $670,000 EPA’s current exhaust standard and 90% below the cleanest NOx Reduced 2,141 lbs NOx Reduced 1,417 lbs NOx Reduced 2,141 lbs diesel engine. A truck with this engine has an emission profile equivalent to that of a heavy-duty battery electric truck. School Buses $220 $291 Not Commercially Available: per lb of NOx per lb of NOx Available NGVs are Commercially Available Today Across All Applications Natural Gas Diesel Electric Technology Cost $148,000 Technology Cost $115,000 Qualified for Funding NOx Reduced 671 lbs NOx Reduced 396 lbs NGVs are commercially available from traditional truck and bus Transit Buses OEMs with established sales and service networks. Retrofit and repower options are also available from a variety of manufacturers. $273 $540 $569 per lb of NOx per lb of NOx per lb of NOx Applications Include: • Heavy Semi Tractor • Single Axle Van • Cement Mixer • Large Walk In Van • School Bus • City Delivery Truck • Motor Coach • Shuttle Bus • Conventional Van • Rack Truck • Transit Bus Natural Gas Diesel Electric • Dump Truck • Refrigerated Van • Tow Truck Technology Cost $360,000 Technology Cost $300,000 Technology Cost $750,000 • Fuel Truck • Refuse Truck • Utility Truck NOx Reduced 1,318 lbs NOx Reduced 555 lbs NOx Reduced 1,318 lbs

For more information visit: www.ngvamerica.org/vwsettlement # Natural Gas Producer in the World Continual supply by harnessing 90+ renewable sources years supply of recoverable natural gas 2.5+ The U.S.’ expansive natural gas pipeline system is well poised to support a national network of million natural gas fueling stations. Nearly 2,000 CNG miles of U.S. pipeline and LNG fueling stations are operating today, infrastructure with continual expansion underway. Source: U.S. Energy Information Administration

Natural gas is a clean, low-cost, and domestically abundant transportation fuel.

Natural Gas Provides Long-Term Fuel Natural Gas Reduces WTW Price Stability and Cost Savings Greenhouse Gas Emissions

$8 Diesel Compared to Diesel: $7 Gasoline GHG $6 Projected Natural Gas $5 LNG 11% reduction Fuel-Price $4

Differentials $3 (prices per $DGE) CNG 17% reduction $2

$1 2020 2030 2040 RNG 115% reduction Source U.S. nergy nformation dministration Source: NGVAmerica Fleets Run Cleaner on Natural Gas White Paper 2016 Natural Gas Currently, natural gas prices can be $0.75 to $1 or more lower than diesel at the pump, with a firm price Volkswagen 23% advantage expected to remain for EMT Funding decades as shown in the chart above. 77% Recommendations Beyond the fuel-price differential, the Fund alternative fuel vehicle projects that cost pump price of natural gas remains effectively maximize NOx reductions for both relatively stable for two reasons. First, public and private fleets Diesel it is domestically sourced. Second, the Provide higher funding levels for medium- commodity cost of natural gas only and heavy-duty engines that deliver NOx makes up 23% of the pump price so reductions greater than current EPA standards price fluctuations have minimal impact. 40% Target funding for technologies that have 60% demonstrated lower in-use emissions In contrast, approximately 60% of the price of diesel fuel is impacted by Prioritize funding for commercially available the market cost of crude oil, which products and projects that are ready to begin is largely sourced from politically Stay flexible in plans and leverage private unstable, high-conflict regions. When Distribution & Processing investment to stretch dollars and get more crude oil prices increase, diesel prices Natural Gas Commodity Cost alternative vehicles on the road follow suit which can lead to significant Crude Oil Commodity Cost swings in a fleet’s fuel costs. Natural gas vehicles can fulfill all of these recommendations today!

For more information visit: www.ngvamerica.org/vwsettlement

White Paper

The Volkswagen Settlement’s Nitrogen Oxide Mitigation Trust By Jeffrey Ang-Olson, Ira Dassa, and Gustavo Collantes, ICF

Executive Summary In late October, a federal district court in California formally approved a partial settlement between Volkswagen (VW) and the federal government and State of California concerning allegations that VW violated the Clean Air Act by selling nearly 500,000 diesel vehicles that were equipped with computer software designed to cheat on automotive emissions tests. Among other things, the partial settlement requires VW to pay $2.7 billion into an environmental mitigation trust that “is intended to fully mitigate the total, lifetime excess NOx [nitrogen oxide] emissions from the [affected] vehicles.”1 The $2.7 billion trust will be administered by a court-appointed trustee. Importantly, all 50 states, as well as Puerto Rico, the District of Columbia, and Indian tribes, are slated to receive funds under the trust in proportion to the number of noncompliant vehicles sold and registered in each jurisdiction. The funds are to be used for “eligible [NOx] mitigation actions” as delineated in Appendix D-2 of the settlement.2

1 U.S. Environmental Protection Agency, “Volkswagen Clean Air Act Partial Settlement,” available at https://www.epa.gov/enforcement/volkswagen-clean-air-act-partial-settlement#health. 2 A complete version of the settlement can be found at http://www.cand.uscourts.gov/ filelibrary/2869/Order-Granting-Entry-of-Consent-Decree.pdf. Appendix D appears on pp. 194–237 of the pdf file.

Although a trustee has yet to be appointed and the final trust agreement has not been filed with the court, states should move quickly to familiarize themselves with the NOx portion of the VW settlement (i.e., Appendix D) and begin taking steps to consider and analyze the potential mitigation actions they can undertake with their anticipated NOx mitigation funds. As detailed below, ICF is well equipped to assist states and others in these regards. What the Settlement Means for States Once a trustee has been selected and the final trust agreement has been filed with the court (thus establishing the trust’s effective date), states will have 60 days to file a certification form (set forth in Appendix D-3 of the settlement) and thereby become a “Beneficiary” under the trust. The certification form must be provided by the governor’s office and identify the state agency that will be the lead agency within the state for purposes of the trust. Within 120 days of the effective date, the court-appointed trustee will publish a list of the designated beneficiaries. This official designation, in turn, will trigger the start of a 90-day period during which states and other beneficiaries must prepare and submit to the trustee a nonbinding “Beneficiary Mitigation Plan” that provides the public with information about the state’s general vision for its intended use of its NOx mitigation funds. The following figure illustrates these milestones.

Trustee selected and State must file State must submit final trust agreement Trustee publishes list certification form to “beneficiary mitigation filed with court: Trust of beneficiaries become a beneficiary plan” Effective Date (TED)

60 days after TED 120 days after TED 90 days after list

Source: ICF At a minimum, the beneficiary mitigation plan should address the following: a) the state’s overall goal for the use of the funds; b) a list of the eligible mitigation actions that are anticipated and a preliminary estimation of the allocation of funds to each of these; c) a description of how the state will consider the beneficial impact of these actions on air quality in areas that bear a disproportionate share of air pollution; and d) a general description of the ranges of emissions benefits expected from the implementation of these actions. Mitigation actions allowed under the settlement include projects to reduce NOx emissions from both on-road and off-road diesel emission sources. Within this broad scope, states have the latitude to focus on those technologies and programs that make the most sense for them. Eligible projects include those targeting: §§Large freight trucks and port drayage trucks (Class 8) §§Local freight trucks (Classes 4–7) §§School, shuttle, and transit buses

§§Switcher locomotives §§Tugs and ferries §§Shore power for ocean-going vessels §§Airport ground-support equipment §§Forklifts and port cargo handling equipment §§Light-duty zero emission vehicle supply equipment The initial state-specific allocation amounts appear in Appendix D-1 of the settlement. Note that these amounts may increase once VW and the federal government and California reach a widely expected settlement regarding an additional 80,000 (larger) diesel vehicles. States beneficiaries must submit requests for eligible mitigation action funds to the trustee. Multiple state beneficiaries can submit joint requests, which enables collaboration across jurisdictional boundaries on programs that, for example, address emission sources that have significant impacts at the regional level. Every eligible mitigation action funding request must include the following: 1. A description of how the funding request/proposed action fits into the beneficiary’s mitigation plan. 2. A thorough description of the proposed action that includes the air quality benefits and community benefits more broadly. 3. The expected NOx reductions that would result from the proposed action. 4. A project management plan for the proposed action, including a detailed budget and an implementation timeline. 5. A certification that the selection of any vendor was or will be performed in accordance with applicable state public contracting laws. 6. A detailed cost estimate from prospective vendors for all expenditures in excess of $25,000. 7. A thorough description of how the beneficiary will oversee implementation of the action. 8. A description of any cost share requirements associated with the proposed action. 9. A description of how the beneficiary complied with the requirement to provide notice of the availability of mitigation action funds to relevant federal agencies. 10. A description of the benefits that the proposed action is expected to have on communities that have historically borne a disproportionate share of the adverse impacts of NOx emissions. 11. A plan for reporting on the implementation of the proposed action.

Within 60 days of submission of a request for funds, the trustee will notify the beneficiary by approving, denying, or seeking a modification of the funding request (and associated eligible mitigation action). The trustee will start disbursing mitigation funds within 15 days of the approval of the eligible mitigation action funding request. Maximizing Program Effectiveness Given the breadth of equipment types and projects eligible for NOx mitigation funds, states should design their programs carefully to maximize air quality and public health benefits. States should expect active stakeholder engagement and participation from proponents for specific industries and technologies. This can put pressure on states’ capacity to process incoming information efficiently and implement programs that deliver the maximum possible return on investment. NOx emissions vary widely depending on the type, age, and usage of vehicles. Many of these vehicles are also large sources of fine particulate matter (PM2.5)

and carbon dioxide (CO2) emissions. Understanding the current and future emission sources in a state—as well as trends in technologies and fuels—will be critical to an evaluation of program effectiveness. Table 1 shows typical annual emissions for representative vehicle and equipment types. TABLE 1. TYPICAL ANNUAL EMISSIONS BY EQUIPMENT TYPE Typical Emissions per Year

Equipment Type NOx (lbs) PM2.5 (lbs) CO2 (tons) Port drayage truck 880 20 10

Class 8 large freight truck 765 13 216

Class 5 medium freight truck 43 4 41

School bus 21 1 20

Switcher locomotive 16,510 460 560

Tug boat 109,820 3,000 3,440

Ferry 69,060 1,650 1,780

Forklift 790 40 20

Port yard tractor 1,640 80 80

Port rubber tire gantry crane 5,410 170 170

Port container handler 3,530 110 110

Source: ICF

Some of the largest NOx reduction opportunities under the settlement will come from the electrification of vehicles, equipment, and terminals. Ports may provide some of the largest NOx reduction potential because they are concentrated hubs of activity for large diesel engines. As an example, Table 2 shows typical emission

reductions resulting from the installation of shore power at a single port terminal. The emission reductions will vary depending on the type of ships served and the frequency of ship calls, among other factors.

TABLE 2. ANNUAL EMISSION REDUCTION FROM SHORE POWER INSTALLATION AT A PORT TERMINAL

Terminal Type Annual Emission Reduction (tons)

NOx PM2.5 CO2 Container terminal—50 ship calls per year 24 0.5 807

Container terminal—300 ship calls per year 144 2.8 4,844

Reefer terminal—50 ship calls per year 37 0.7 1,241

Reefer terminal—300 ship calls per year 221 4.3 7,445

Cruise ship terminal—50 ship calls per year 41 0.7 1,150

Cruise ship terminal—300 ship calls per year 245 4.0 6,901

Source: ICF

Public transit can also offer large NOx reductions through electrification. For government-owned bus fleets, funds from the NOx mitigation trust can cover up to 100% of the cost of a new all-electric vehicle, including the necessary charging infrastructure. Table 3 shows illustrative emission reduction estimates for different scenarios of transit bus electrification. Electrification technologies are evolving rapidly, and such evolutions should be accounted for in state programs that span multiple years. The innovation in this area will continue at a faster pace not only in the technology itself, but also in how to integrate electrified vehicles with the broader transportation system and the electric grid. TABLE 3. ANNUAL EMISSION REDUCTION FOR THREE SCENARIOS OF BUS ROUTE ELECTRIFICATION

NOx PM2.5 CO2 Route Minimum Overnight Emissions Emissions Emissions Length Fleet Size Charging Reduced Reduced Reduced (miles) Needed Candidate (lbs/year) (lbs/year) (tons/year)

Route 1 8 6 Yes 2,011 13 241

Route 2 15 6 No 4,564 22 570

Route 3 25 10 No 4,405 26 575

Source: ICF

The cost effectiveness of mitigation actions can also vary widely and needs to be assessed carefully. Emission reduction cost effectiveness will depend on the emission rates, activity levels, and remaining useful life of the old equipment being targeted. For example, Table 4 shows the impacts of scrapping and

replacing three different short-haul combination trucks with a new vehicle. Although replacing the oldest truck (model year 2001) will produce the largest annual emission reduction in the short term, better lifetime emission reductions and cost effectiveness result from targeting the model year 2005 or 2009 truck, since these vehicles have a longer remaining useful life.

TABLE 4. EXAMPLES OF EMISSIONS IMPACTS FROM REPLACING A SHORT-HAUL COMBINATION TRUCK

Old Truck Being NOx Reduced Lifetime NOx Cost Effectiveness Replaced per Year (tons) Reduced (tons) ($/ton lifetime NOx reduced)

Model Year 2009 0.21 2.21 $45,330

Model Year 2005 0.30 2.01 $49,690

Model Year 2001 0.66 1.71 $58,340

Source: ICF Once states have identified the mitigation actions that will yield the greatest emission reductions for the lowest cost, they will need to consider how to structure a program effectively. To generate adequate interest from commercial fleets, state programs should minimize the administrative burden for applicants and ensure that funds are disbursed in a timely and predictable manner. At the same time, states have an obligation to build in appropriate program checks so that mitigation funds are targeted to the most worthy projects. The following table lists program parameters to consider.

Program Parameter Common Alternatives Incentive Type §§Full equipment replacement §§Cost share §§Rebate incentives §§Voucher incentives Disbursement §§First come, first served §§Ranking of applications Returns §§Financial sustainability §§Innovation/transformation impact Eligibility §§Vehicle/equipment owners §§Vehicle/equipment suppliers §§Partnerships Source: ICF How ICF Can Help ICF can help states design and implement a NOx mitigation program that complies with the settlement terms and maximizes benefits to the state’s residents and businesses. Our staff have deep technical knowledge of NOx emission control

strategies for on-road and off-road vehicles and equipment. We have helped About ICF federal, state, and local agencies with evaluating candidate control strategies to maximize the cost effectiveness of emission reductions. Our staff have helped to ICF (NASDAQ:ICFI) is a global consulting and technology services provider with develop clean vehicle incentive programs for state agencies (such as California’s more than 5,000 professionals focused Hybrid Truck and Bus Voucher Incentive Program) and for national programs on making big things possible for our funded through legal settlements (such as the Clean Buses for Kids Program). clients. We are business analysts, policy We have also supported more than 15 electric utilities with assessment or specialists, technologists, researchers, implementation of transportation electrification programs. digital strategists, social scientists, and creatives. Since 1969, government and ICF’s consulting services can be covered by NOx mitigation funds. The list of commercial clients have worked with ICF eligible mitigation actions in the settlement agreement expressly includes to overcome their toughest challenges contracted services for consulting and evaluation. on issues that matter profoundly to their success. Come engage with us at icf.com. About the Authors Jeffrey Ang-Olson, Vice President, leads ICF’s transportation For more information, contact: practice. He is a transportation engineer and planner, and Jeffrey Ang–Olson an expert in diesel emission reduction strategies for on- and jeffrey.ang–[email protected] +1.916.231.7674 off-road vehicles. Ira Dassa [email protected] +1.443.573.0551 Gustavo Collantes [email protected] +1.916.231.7607 Ira Dassa, a Technical Director at ICF, is an environmental and energy lawyer and policy expert who specializes  facebook.com/ThisIsICF/ in alternative transportation fuels and all sectors of the  twitter.com/ICF automotive industry.  youtube.com/icfinternational  plus.google.com/+icfinternational  linkedin.com/company/icf-international  instagram.com/thisisicf/ Gustavo Collantes, Ph.D., is a Senior Technical Specialist at ICF. He is a recognized expert on clean transportation innovation.

Any views or opinions expressed in this white paper are solely those of the author(s) and do not necessarily represent those of ICF. This white paper is provided for informational purposes only and the contents are subject to change without notice. No contractual obligations are formed directly or indirectly by this document. ICF MAKES NO WARRANTIES, EXPRESS, IMPLIED, OR STATUTORY, AS TO THE INFORMATION IN THIS DOCUMENT. No part of this document may be reproduced or transmitted in any form, or by any means (electronic, mechanical, or otherwise), for any purpose without prior written permission. ICF and ICF INTERNATIONAL are registered trademarks of ICF and/or its affiliates. Other names may be trademarks of their respective owners.

December 5, 2017

The Honorable Michael Teague Secretary Office of the Secretary of Environment 204 N. Robinson Suite1010 Oklahoma City, OK 73102

CC: Heather Lerch Air Quality Division PO Box 1677 Oklahoma City, OK 73101

Dear Secretary Teague:

RE: Maximizing Settlement Fund Allocation for Charging and Hydrogen Refueling Infrastructure

The Association of Global Automakers (Global Automakers) represents the U.S. operations of international motor vehicle manufacturers, original equipment suppliers, and other automotive-related trade associations. In 2016, international automakers manufactured 43% of all new motor vehicles and 82% of green technology vehicles sold in Oklahoma.

Global Automakers and our members have a longstanding commitment to improving air quality, reducing greenhouse gas emissions, and increasing fuel efficiency. Our members are investing heavily in alternative fuel and green technologies, including being the first to successfully launch hybrid electric vehicles 20 years ago and since then plug-in and fuel cell electric vehicles. We are proud that the number of electric-drive vehicles, in a variety of options and price points, are increasing every year.

Under Appendix D of the Volkswagen settlement, Oklahoma is due to receive $21 million, which can be used for a variety of environmental-based projects. A maximum of 15% of this money, or $3.15 million, can be used for the acquisition, installation, operation, and maintenance of electric vehicle infrastructure.

Global Automakers urges the State of Oklahoma to allocate the full 15% towards this effort and to support all electric vehicle infrastructure – charging stations and hydrogen refueling stations. The state needs to establish a strong foundation for electric vehicles by expanding its network of charging and building out a network of hydrogen refueling stations to support sales of electric vehicles. Increasing available infrastructure is critical to the state’s ability to advance electrification. Range anxiety is a significant impediment to sale of electric vehicles. Investment in electric vehicle infrastructure responds to this problem while furthering air quality and supporting customers in your state that choose to buy an electric vehicle.

Should you have any questions, please do not hesitate to contact us. Thank you for your consideration of our request, and your continued support of electrification.

Sincerely,

Damon Shelby Porter Julia M. Rege Director Director State Government Affairs Environment and Energy

Eric Pollard Clean Cities Coordinator Community & Economic Development [email protected]

Comments to ODEQ regarding Volkswagen Environmental Mitigation Fund

For decades, The Association of Central Oklahoma Governments (ACOG), in partnership with the Oklahoma Department of Environmental Quality (ODEQ) and other state agencies, has identified, encouraged, and invested in pollution mitigation strategies directed toward keeping the region in-attainment of EPA air quality standards. Additionally, ACOG has hosted the Central Oklahoma Clean Cities Coalition, a U.S. Department of Energy (DOE) designated Clean Cities Coalition since 1996. ACOG’s affiliation with DOE through the Clean Cities program does not require ACOG to take any position on VW settlement funding. Central Oklahoma Clean Cities Coalition is a fuel neutral and does not advocate for the use of one alternative fuel over another. ACOG staff recommend the following principles for distribution of funds as well as questions for the State of Oklahoma to consider in the development of the beneficiary mitigation plan.

A. NOx Mitigation ACOG staff proposes that the first guiding principle should be that projects be selected primarily by their NOx mitigation benefits to Oklahoma. The VW Environmental Mitigation Fund was developed to mitigate NOx emissions of vehicles that consumers and other stakeholders believed were lower than they really were. Proposed projects should be evaluated for likelihood that they will mitigate NOx pollution, and the State should require that each project show an estimated amount of NOx emissions reduced.

B. Sectors with Higher Levels of NOx Emissions When possible, projects in sectors identified in EPA’s 2014 National Emissions Inventory (NEI) that have a higher proportion of NOx emissions should receive higher priority.

C. Priority Geographic Areas Geographic areas with higher NOx pollution levels should receive a higher level of priority in project selection than areas with lower NOx pollution levels. These areas could be identified using EPA NEI data or more recent monitoring data..

D. Cost Eligibility While drafting the Beneficiary Mitigation Plan, the State should actively seek input from both public and private fleets in regard to the cost-effectiveness of certain cost reimbursement percentages. For many fleets, seeking VW trust funding will not be cost effective at certain cost reimbursement percentages due in large part to lost revenue from vehicle scrappage versus auctioning of replaced vehicle(s).

E. Preference for Alternative Fuels With only specific exceptions, the State should only allocate funds to medium and heavy-duty vehicle replacement projects in which vehicles are replaced with alternative fuels.

F. EVSE Investment The State should elect to allocate at least 10 percent and up to the allowed 15 percent of VW Environmental Mitigation Trust funding to light duty zero emission vehicle (ZEV) supply equipment. While NOx benefits from these projects may be more difficult to quantify, the market for light-duty electric vehicles (EVs) is growing rapidly and EV’s provide a significant NOx mitigation benefit to Oklahoma. Additionally, more charging installation as allowed under the mitigation trust will accelerate market adoption of EV’s and provides an opportunity for exponential growth. Investment in charging could be very cost effective on NOx mitigation as individuals and fleets spend funds outside of VW settlement funds.

The State, in partnership with the Oklahoma Electric Vehicle Coalition should evaluate charging investment options under this category.

The Oklahoma Electric Vehicle Coalition is an informal working group of companies, governmental agencies, and organizations engaged in increasing EV adoption in Oklahoma. Coalition members can assist the State on technology and cost considerations under this category.

G. Comment on Final Draft of Beneficiary Mitigation Plan The public should be given 45-60 days to review and provide comment on the State’s final Beneficiary Mitigation Plan draft.

H. Additional Questions for the State of Oklahoma to consider:

a. What tools will the State use to analyze emissions benefits? For medium and heavy-duty vehicle replacement ACOG proposes the State seriously consider the Alternative Fuel Life-Cycle Environmental and Economic Transportation (AFLEET) Tool. ACOG can assist the State in identifying emissions calculators for other categories as well.

b. Will the State use a scoring system to evaluate projects?

c. How quickly does the State plan to spend the funds? Will the State allocate funding over certain phases? If so, will projects be submitted at each phase?

d. Will the State place priority on certain sectors?

e. How will the State conduct outreach to fleets, businesses, governments?

NOTES:

association of central oklahoma governments 4205 N. Lincoln Blvd. | Oklahoma City, OK 73105 | 405.234.2264 | Fax: 234.2200 | acogok.org

Electrify Oklahoma

A Proposal by Oklahoma Electric Vehicle Coalition (OEVC) January 16, 2017

Table of Contents Contacts...... 2 Why should Electrify America Invest in Oklahoma? ...... 3 Oklahoma Investment Opportunities for Electrify America ...... 3 Background ...... 3 Oklahoma Electric Vehicle Coalition ...... 4 High-speed Cross Country Network of Charging Stations ...... 5 Oklahoma: America’s Alternative Fuels Crossroads ...... 6 Potential Partners & Charging Locations ...... 7 Planned/Projected EV Corridor Designations ...... 6 Tulsa Metropolitan Area Overview ...... 9 Planned Tulsa Area EV Projects ...... 9 Tulsa EV Market Overview ...... 9 Oklahoma City Metropolitan Area Overview ...... 11 Recent Oklahoma City EV Projects ...... 11 Education & Awareness ...... 11 Increased Promotion, Funding, and Availability for EV Ride and Drive events ...... 12 Develop an EV Showroom in a High-Traffic Location ...... 12 Collaborate with Oklahoma Career Techs on EV Service Technology Training ...... 12 Create a local “EV Ambassador” ...... 13 Develop Nationwide Curriculum for EV Education ...... 13 Appendix I: Interstate Traffic Count Projections ...... 14 Existing and Projected Usage of the I-40 Corridor ...... 14 Existing and Projected Usage of the I-35 Corridor ...... 14 Existing and Projected Usage of the I-44 Corridor ...... 14 Appendix II: Map of Oklahoma Alternative Fuel Corridors ...... 15 Appendix III: Potential Muscogee (Creek) Nation EVSE Sites ...... 16 Appendix IV: Potential Kum & Go EVSE Sites ...... 17 Appendix V: EV Stations by State (Including Tesla) ...... 18 Appendix VI: EV Stations by State (Excluding Tesla) ...... 19

Electrify Oklahoma Page 1

Contacts Eric Pollard Coordinator, Central Oklahoma Clean Cities Coalition Energy Programs Coordinator, ACOG Director, Oklahoma EV Coalition [email protected] 405.778.6175

Adriane Jaynes Coordinator, Tulsa Area Clean Cities Coalition Energy Programs Coordinator, INCOG [email protected] 918.587.9494

Daniel Jeffries Energy Programs Specialist, INCOG [email protected] 918.587.9434

Chris Grider Product Development Manager – Electric Vehicles, OGE Energy Corp. [email protected] 405.553.3851 Micah Burdge, CEM Customer Service Engineer, AEP-PSO [email protected] 918.599.2293

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Why should Electrify America Invest in Oklahoma? 1. Electrify America investments will be leveraged by Oklahoma Electric Vehicle Coalition members A highly motivated diverse group of members dedicated to advancing electric vehicles in Oklahoma. Led by utilities, auto dealerships, Clean Cities Coalitions, convenience store companies, local governments, and EV drivers. Members of the coalition are investing $2-3 million toward increased electric vehicle adoption over the next two years. 2. Potential for Impact Because of Oklahoma’s lower EV adoption rankings, investments by Electric America would have a greater effect than they would in other markets.

3. State Tax Credits Attractive 75% state tax credit for public EVSE leverages Electrify America’s investment in Oklahoma due to increased EV adoption. Oklahoma Investment Opportunities for Electrify America Background Oklahoma ranks 34th for electric vehicle (EV) adoption in the United States with over 1,500 EVs deployed state wide as of September 2016. As such, Oklahoma currently has very few charging stations, known as Electric Vehicle Supply Equipment, or EVSE, emplaced with 39 public chargers across the state. The Tulsa area has nine public Level 2 chargers; two at local grocery stores, one at a local university; and six at car dealerships. There is also a Tesla Supercharger (accessible only by Tesla owners) on the eastern edge of the metro area. The Oklahoma City area is progressing slightly faster than Tulsa, with fourteen public chargers; one Level 2 charger at a local grocery store, seven at car dealerships, two DC Fast Chargers (DCFC’s), and a Tesla Supercharger site. Another DCFC location is set to open in early 2017. At least four electric vehicle charging station projects are planned for 2017. For comparison, Dallas presently has a network of thirty-three DCFC’s with a vast network of Level 1 and Level 2. Kansas City has fifteen DCFC’s and a very large network of Level 2 chargers due to an ongoing aggressive EVSE build-out by Kansas City Power & Light. The Association of Central Oklahoma Governments (ACOG) & the Indian Nations Council of Governments (INCOG), the Metropolitan Planning Organizations for their respective regions, house the state’s two U.S. Department of Energy (DOE) designated Clean Cities Coalitions which have both been in operation since 1996 & 1997 respectively. Both coalitions are working aggressively to increase EV adoption Increasing availability and affordability of electric vehicles is driving new demand for charging infrastructure. Oklahoma has a record of facilitating public-private partnerships to quickly expand access to alternative fuels.

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Thanks in large part to alternative fuel infrastructure tax credits passed by our state legislature in 2009, Oklahoma has more public CNG stations per capita than any other state in the country, with at least one CNG station at least every 100 miles on our interstate highways. The availability and structure of these credits led to the rapid expansion of CNG as a transportation fuel in this state. Because of this, we stand ready to leverage the lessons learned, infrastructure, and tax credits to do the same with EVSE. In fact, the coalition believes that convenience stores and travel centers with CNG stations are strategic locations for EV charging because electrical upgrades required for CNG compressors will also meet electrical supply needs for DC Fast Charging.

Oklahoma Electric Vehicle Coalition Nearly forty companies, local and tribal governments, and nonprofit organizations make up the Oklahoma Electric Vehicle Coalition (OEVC). The coalition meets every other month to discuss ways to increase the number of registered electric vehicles in Oklahoma, facilitate the deployment of EVSE, and conduct marketing and event outreach to increase public knowledge about electric vehicles. It is the assumption of coalition members that increased EV adoption will lead to better energy, economic, and environmental security of the state. Coalition members currently plan to invest between two and three million dollars over the next two years to increase EV adoption in Oklahoma, though we expect this number to increase substantially as we add new members and as EVs gain market share throughout the state. Investments include targeted marketing to commuters and early adopters, ride and drive events, promotional incentives, and fleet investments. Additionally, members are identifying and investigating policy, legislative and regulatory opportunities to support EV adoption.

To ensure drivers can test drive and shop for electric vehicles, dealership coalition members are stocking more electric vehicles or working toward certifications that will allow them to sell EVs.

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Another major objective of the coalition is to identify and educate the workforce and industries needed to facilitate the wider adoption of EVs in the state (e.g. vehicle technicians/mechanics, first responders, car dealers, real estate developers, policymakers, etc.) OEVC stakeholders are meeting with airports, hospitals, universities, parking garage owners, hotels, libraries, entertainment attractions, and multi-family housing complexes to discuss the benefits of installation of public and workplace charging EV charging. The coalition is committed to an all-of-the-above approach to levels of charging in which the primary interest is identifying the most cost-effective charging solution for station owners and hosts. The coalition will be meeting with companies in Oklahoma about workplace charging, holding on-site ride & drives, and potentially will be able to offer special EV lease rates through local dealerships. Additionally, in 2017, OG&E (a major electric utility in Oklahoma) plans to provide a promotional rebate for companies who choose to install workplace charging equipment. The coalition connects charging station owners and hosts with the U.S. Department of Energy’s (DOE) Workplace Charging Challenge. The Challenge works with partners to set a minimum goal of providing charging for a portion of plug-in electric vehicle (PEV) driving employees and a best practice goal of meeting all employee demand. According to the DOE, more than 250 employers have joined as Challenge partners and the installation of workplace charging as a sustainable business practice is growing across the country. Partner efforts have resulted in more than 600 workplaces with over 5,500 charging stations accessible to nearly one million employees.1

High-speed Cross Country Network of Charging Stations Oklahoma’s central geographic location and position within the Interstate Highway System, which includes Interstate 40 (California to North Carolina), Interstate 35 (Texas to Minnesota) and Interstate 44 (Wichita Falls, TX to St. Louis, Missouri), make the state a critical location for EV drivers making cross country trips. The Oklahoma Electric Vehicle Coalition is working to identify and construct strategic locations for DCFC’s and Level 2 charging that will ensure border-to-border charging within Oklahoma and connections to adjacent states.

1 http://energy.gov/eere/vehicles/workplace-charging-challenge-join-challenge

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Critical DCFC corridor needs for Oklahoma include centrally located charging stations in both Tulsa and Oklahoma City along Interstates, a connection on Interstate 44 between Oklahoma City and Tulsa, and Interstate 44 connection between Tulsa and Joplin (and St. Louis), and an Interstate 35 connection between Oklahoma City and Dallas. Additional locations will be needed along the east-west Interstate 40 corridor as well.

Oklahoma: America’s Alternative Fuels Crossroads In November 2016, all of Oklahoma’s Interstate corridors were designated as planned/projected electric vehicle corridors by the Federal Highway Administration (FHWA). Oklahoma was one of just a few states to have all of its interstate highways designated as such. The corridor was nominated by the Oklahoma Department of Transportation in partnership with ACOG and INCOG, and supported Governor Mary Fallin’s Oklahoma First Energy Plan2, which outlines how Oklahoma will continue to be a national and international energy and innovation leader. The plan outlines background, opportunities, challenges, and strategies for each energy sector (oil & gas, renewables, etc.). Another goal of the plan is to find synergies between the energy sector and the industrial sector, workforce development, and most importantly for the purposes of this input submission – the transportation sector. Planned/Projected EV Corridor Designations # of DC Number of Fast Distance Additional Nominated Charger Between Planned/ Visibility, Convenience, & Accessibility Corridor Stations Planned Projected Along Facilities Facilities Corridor Interstate 40 is one of the most travelled highways in the country ≤ 100 Interstate 40 2 3-4 and provides excellent visibility, convenience, and accessibility to Miles users of the corridor. Interstate 35 is one of the most travelled highways in the country ≤ 100 Interstate 35 1 3-4 and provides excellent visibility, convenience, and accessibility to Miles users of the corridor. Interstate 44 serves as a highly travelled, visible, convenient, and ≤ 100 accessible corridor connecting Oklahoma to Wichita Falls, Texas Interstate 44 1 3-4 Miles and Missouri as well as Tulsa, Oklahoma City, Lawton, and many other communities within Oklahoma.

2 Oklahoma First Energy Plan (2011) https://www.ok.gov/governor/documents/Governor%20Fallin's%20Energy%20Plan%20- %20Jan%202012.pdf

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Potential Partners & Charging Locations Strategically expanded electric vehicle charging is a potential economic growth area across a number of sectors including two sectors critical to the Oklahoma economy – energy and transportation. The Coalition has consulted with several corporations about potentially being EV infrastructure project partners or EVSE host sites. The following companies have indicated a willingness to participate in this project, and support this application: American Electric Power / Public Service Company of Oklahoma – AEP- PSO serves more than 600,000 electricity customers in 232 communities across northeastern and southwestern Oklahoma. EZ GO – Lawton-based convenience store chain EZ GO operates two dozen stores in Oklahoma, Kansas, and Nebraska. In 2014, EZ GO installed CNG pumps at two of its locations along Oklahoma Turnpikes. Its turnpike/Interstate travel stop locations feature attached restaurants and other important traveler amenities. Hutch’s – This family-owned Oklahoma convenience store chain operates 15 locations in western Oklahoma and Kansas, one-third of which have CNG fueling capabilities. Hutch’s is committed to offering its customers the fuels and conveniences they want. Kum & Go – West Des Moines, Iowa-based Kum & Go operates more than 400 stores in 11 states. In addition to gasoline and diesel, K&G offers customers biodiesel, and various blends of Ethanol from E15 to E85. K&G also offers electric vehicle charging at six locations in Iowa. Its new store canopies are built solar-ready, with reinforced steel, larger footings, and conduit run to the store. K&G also participates in Clean Cities coalitions throughout the Midwest. K&G has already identified five specific sites within Oklahoma to jumpstart their EVSE activities in our area (see Appendix IV). Muscogee (Creek) Nation – The Creek Nation is committed to purchasing many EVs, and is interested in installing EVSE in several locations throughout eastern Oklahoma, including at travel stops, administrative offices, 8 health clinics, a hospital, 8 casinos, and a Margaritaville Resort- Hotel-Casino complex in Tulsa. A map of proposed locations may be found in Appendix III. OnCue Express – Another Oklahoma convenience store chain, OnCue is headquartered in Stillwater, and operates more than 65 stores across the state. Many of their stores offer CNG refueling, and OnCue has partnered with OG&E on a strategic EVSE rollout plan. The first installation was completed in 2016, and more are planned in 2017.

Oklahoma Associtaton of Electric Cooperatives – OAEC is a statewide association representing 27 Distribution Cooperatives and 3 Generation & Transmission Cooperatives. Collectively, Oklahoma’s electric cooperatives

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provide safe, reliable and affordable power to more than 550,000 consumers statewide. Co-ops serve and have infrastructure in each of Oklahoma’s 77 counties. Oklahoma Gas & Electric – OG&E serves more than 800,000 electricity customers in central Oklahoma and western Arkansas. OG&E is committed to making EVs and EVSE a reality in Oklahoma, partnering with multiple partners to install and test EVSE, and serving as a founding member of the Oklahoma EV Coalition.

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Tulsa Metropolitan Area Overview The Tulsa area (2015 CSA population: 1,151,172) has nine public Level 2 chargers; two at local grocery stores, one at a local university; and six at car dealerships. There is also a Tesla Supercharger (accessible only by Tesla owners) on the eastern edge of the metro area.

Planned Tulsa Area EV Projects INCOG, the federally designated Metropolitan Planning Organization for the Tulsa region, has committed $300,000 towards EVSE to be spent in 2017, and is aggressively seeking partnerships to further leverage that funding into what will be a strategically located charging network. The majority of these funds will be spent on DCFC’s. This funding will enable a very basic network to emerge, but to truly transform this market, larger investments are required. In addition, INCOG awarded $150,000 to the City of Tulsa and the Tulsa City-County Library System in 2016 to install EVSE. The Library has pre-wired eight parking stalls in its new downtown garage for EVSE, and INCOG is working with the City to identify the best locations for EVSE installations at city-owned attractions including the Tulsa Zoo, Gilcrease Museum, and other locations. In addition to funding and the comprehensive plan for EVSE, INCOG and Tulsa Area Clean Cities (TACC) are reaching out to a large number of entities to encourage EV and EVSE adoption. As a result, the City of Tulsa, Tulsa Parking Authority, Tulsa City-County Library System, Tulsa International Airport, a prominent local museum, parks, and a tribal government are all planning purchases of EVs or EVSE in early 2017. When the theses entities purchase the number of EVs and install the EVSE, which they have expressed intention to purchase as a direct result of the last few months of outreach, this alone will increase the number of EVs registered in our territory by 6% and the EVSE will be increased by 144%.

Tulsa EV Market Overview While there are many cities with more developed EVSE infrastructure, if Tulsa is chosen as one of the 15 metro areas for substantial EVSE investment, it will provide Electrify America with the opportunity to leverage a data driven approach to EVSE deployment, to truly put emerging theories regarding charging behavior to the test. In other cities, the investment from Electrify America might be lost in a sea of other EVSE investments. In Tulsa, with its current relative lack of EVSE, Electrify America can show how a strategically deployed EVSE network paired with education and outreach across a variety of platforms can transform a market to embrace EVs, even in a state with deep ties to the oil industry. Prior to Electrify America’s announcement of the ZEV initiatives, the Oklahoma EV Coalition, INCOG, ACOG, and the two largest regulated electric utilities in the state had already reached out to the National Renewable Energy Lab (NREL) for assistance on creating a state-wide plan for EVSE installations. By coordinating our efforts to strategically build out this network, we will enable EV drivers to take their cars across the state, and into neighboring states. This plan is leveraging the abundance of data generated over the last few years through the numerous studies of EV driving and charging behaviors, the framework pioneered by Tesla for its Supercharging network, and local data sets on traffic patterns, density, commuting trends, etc.

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Even in this oil-and-gas city, people are already beginning to embrace EVs. They will do so in even larger numbers once they see the infrastructure develop, see their friends and family driving them, understand that they can significantly reduce their transportation costs by driving electric, and hear the message that EVs contribute to American energy independence and security because electricity is a domestic fuel. Tulsans will embrace them in even greater numbers as EVs penetrate all market segments and they realize they can still drive a great car with fantastic performance without sacrificing luxury, convenience, or affordability to drive electric. In 2015, Tulsa Area Clean Cities worked with a land-use planning firm to develop a best practice guide for city planners with regard to alternative fuels. The guide included information on electric vehicle charging, and provisions for EVs and EVSE were included in a major overhaul of Tulsa’s zoning code. Tulsa Clean Cities has a 20-year history of working with local fleets to find fuel-saving projects with a good ROI. Most of its members were not early adopters of EVs because they were not willing to sacrifice functionality or pay a premium to be “green”. Now however, most understand that going “green” frequently saves money, and requires far less sacrifice of vehicle functionality. As the ROI and performance of alternative fuel projects have improved, so has the willingness of Tulsans to embrace these new technologies. A common theme among prospective EV drivers in the Tulsa area is that many are interested in driving EVs; many just do not believe that it is currently feasible to do so in the Tulsa area because there is so little EVSE. By investing in a well-designed, strategically located EVSE network, and engaging utility customers in a public awareness campaign, it is possible to significantly increase EV adoption in the Tulsa region.

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Oklahoma City Metropolitan Area Overview The Oklahoma City area (2015 CSA population: 1,430,327) has more than a dozen public EV chargers; one Level 2 charger at local grocery store, seven Level 2s at car dealerships, two DCFC’s and a Tesla Supercharger site. Another DCFC charging station is set to open in early 2017.

Recent Oklahoma City EV Projects Recognizing that expanded charging infrastructure is a crucial aspect of increased adoption, OG&E has partnered with OnCue Express on a Direct-Current (DC) fast charging equipment pilot program. The first EVSE installation was completed in late 2016 in Yukon, OK, and more will follow in 2017. The first-of-its-kind project has introduced thousands of Oklahomans to the charging experience and provides customer fuel choice for drivers on Interstate 40. OG&E is in the process of identifying additional strategic charging locations in its territory. The City of Oklahoma City is developing parking policies that encourage growth of charging stations in the public right-of-way and at private businesses. It also has the largest public EV fleet in the state, currently at four BEVs (two Nissan LEAFs and two Ford Focus EVs) and two PHEVs (two Chevy Volts). A Chevy Bolt could be funded through a recent grant application. EMBARK, the OKC-metro’s transit agency, has indicated their possible interest in adding electric buses to their fleet. In July 2016, the University of Oklahoma opened its first public EV charging station, with two more slated for 2017 construction. Both a DCFC and Tesla Supercharger are available at the historic Skirvin Hotel in Downtown Oklahoma City. Oklahoma City is home to Spiers New Technologies, which performs battery life cycle management of advanced battery storage packs. Working with electric car manufacturers, Spiers New Technologies grades and remanufactures used high-performance batteries. The company remanufactures the batteries to go back into electric cars like the Nissan LEAF or the Chevy Volt, or to become energy storage systems which hold excess energy from renewable energy sources, like solar, to provide a constant source of power when the sun is not shining. A large amount of vehicle battery packs removed from EVs in North America come to Spiers in Oklahoma City, Oklahoma for repurposing or recycling. Spiers is an active member of the OEVC. The company provides solar-powered workplace EV charging to its growing workforce.

Education & Awareness The Oklahoma EV Coalition agrees with Electrify America that one of the largest barriers to EV adoption is the lack of education to both consumers, technicians, as well as the public at large. Thus, the Oklahoma EV Coalition charter lists as one of its main areas of focus as education and outreach events. In 2016, the Oklahoma EV Coalition partners conducted numerous public presentations educating Oklahomans on the benefits of EV ownership, as well as hosted multiple EV-centric public ride-and-drive events. With additional funding spent on EV education and awareness from Electrify America, the Oklahoma EV Coalition is looking to partner on either launching or expanding the following initiatives:

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Increased Promotion, Funding, and Availability for EV Ride and Drive events The Oklahoma EV Coalition (OEVC) believes that EV Ride and Drive events are one of the most beneficial outreach opportunities when it comes to educating the general public on the benefits of EVs. Based on our past experience, most of the attendees have never driven an EV before, and are instantly impressed with the driving dynamics (torque, low center of gravity) as well as the silence of the vehicle. Furthermore, by having an EV Coalition member riding as a passenger, they have a captive audience during the test drive to discuss the benefits of EV ownership, including low cost per mile to operate, eligible incentives, and provide a brief education on charging. While the EV Ride and Drive events hosted by OEVC members have continued to grow in attendance, there are currently limitations the Coalition faces when planning such events. Funding has limited the outreach of these events to social media, where different advertising mediums such as radio (both terrestrial and internet), online, and television may attract a larger audience. In addition, given the lack of EV availability in Oklahoma and reliance on Coalition members to bring their personal EVs to ride and drive events, we believe a national effort conducted in the same way as auto shows could showcase a majority of the EV options available in ZEV-compliance states, as well as the ones currently available in Oklahoma. By providing additional funding for publicizing these events along with greater EV selection, we believe that we can continue to increase the amount of exposure to EVs, and therefore, EV adoption. Develop an EV Showroom in a High-Traffic Location

Over the past decade, innovative companies such as Tesla Motors and Apple Inc. have shown the benefits of being able to display their products in a physical location, allowing potential customers to gain a sense of the look and feel of a product prior to making a decision to purchase. By co-locating these showrooms in a high-traffic location, many consumers who may not have been considering their products may stop by, and metaphorically plant the seed for the consumer to consider their product in the future. There are obvious similarities between market EVs and Tesla Motors’ products, and OEVC believes that a similar EV Showroom model could help further educate the market on other EVs available at a price point more attainable by the average consumer. Although leasing, building out, and staffing EV Showrooms is not currently a viable option for OEVC to manage, the Coalition would be willing to support this Showroom model by partnering with Electrify America to help locate viable sites, promote the Showroom model using EV Coalition member-provided advertising and incentives, and encourage local EV dealerships and Automotive Manufacturers who are currently a part of the Coalition to participate in such an endeavor as well. Collaborate with Oklahoma Career Techs on EV Service Technology Training Oklahoma has been at the forefront for career and technology education for over 100 years. The Oklahoma Department of Career and Technology Education oversees 29 technology center districts with an enrollment of nearly 500,000 students annually. Of these 29 districts, six locations currently feature an Alternative Fuel Training Center. While currently these Alternative Fuel Training Centers focus on Compressed Natural Gas (CNG) and Liquefied Petroleum Gas (LPG) vehicles, the Oklahoma Department of Labor (ODOL) believes this is a natural fit for EV education as well. In order for these locations to

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include EVs within their programs, they require curriculum, test equipment, and either an EV powertrain simulator or vehicle to provide hands-on training. As EV adoption continues to increase, the demand for technicians familiar with the system will be imperative for auto dealers to be able to support the products they sell. Therefore, the Oklahoma EV Coalition encourages Electrify America to assist in the development of this curriculum, provide the test equipment and simulator or vehicle, to Oklahoma Career Techs. In the event this is an area where Electrify America focuses its efforts, OEVC will commit to working with the Career Tech centers to encourage adoption of Electrify America’s EV curriculum and training materials in their Alternative Fuel programs. Create a local “EV Ambassador” The Oklahoma EV Coalition believes that word of mouth endorsements provide the longest-lasting effects in a consumer’s mind when it comes to their opinion of a product. While OEVC members work to provide a presence at many of the public events and spaces in Oklahoma, the Coalition does not currently have a dedicated resource to provide EV education to the public. The Coalition believes that with funding from Electrify America, a dedicated “EV Ambassador” would be able to expand educational opportunities beyond the existing audience of the Coalition, including in to such areas as college campuses, science museums, civic events, and neighborhood association meetings. In addition, this position could also be responsible for maintaining a social media presence targeted towards potential EV consumers in Oklahoma. In the event Electrify America is able to provide funding for this role, the Coalition would make a commitment to work closely with the EV Ambassador to support them in their endeavors, including cross-promotion of events where the EV Ambassador will be present, involving the EV Ambassador in OEVC events, and providing introductions to key civic stakeholders to expedite their integration in to the Oklahoma civic and educational circles. Develop Nationwide Curriculum for EV Education While there are multiple sources of information for EVs available, the Oklahoma EV Coalition has yet to find a central multi-faceted curriculum to convey the multiple aspects and benefits of EVs to public audiences of all ages. Not only would this curriculum cover the obvious benefits of individual EV ownership, but it could also cover the macroeconomic and environmental benefits of the widespread adoption of EVs. Having consistency in the curriculum would assist in resolving some of the misconceptions or confusion consumers today have when it comes to EVs. For example, in the event a Coalition member (or EV Ambassador) were to speak to either a neighborhood association or an elementary school audience, at a very basic level, applicable parts of the message would need to be conveyed and remain consistent. The Oklahoma EV Coalition sees value in Electrify America developing, maintaining, and distributing this curriculum on a national basis, with subsets for different groups depending on the venue and the audience. If this curriculum were to be developed, the Oklahoma EV Coalition members would partner with Electrify America in reviewing the draft collateral, piloting the curriculum with certain audiences and providing feedback to Electrify America, and pending acceptance of the collateral, utilizing the curriculum in EV outreach events.

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Appendix I: Interstate Traffic Count Projections Existing and Projected Usage of the I-40 Corridor Population Total Traffic, 2014-2040 Corridor Counties 2013 Avg. Annual (Listed West to East 2013 Daily Traffic Projected 2040 Along Corridor) Population (AADT) AADT Beckham 23,637 11,900 18,400 Washita 11,629 20,300 31,300 Custer 28,554 21,900 33,200 Caddo 29,680 26,300 40,000 Canadian 122,612 40,200 61,100 Oklahoma 742,509 85,700 130,200 Pottawatomie 70,706 37,900 57,700 Seminole 25,463 15,900 24,200 Okfuskee 12,377 16,300 23,100 Okmulgee 39,584 15,200 23,200 McIntosh 20,545 11,900 18,100 Muskogee 70,501 14,700 22,400 Sequoyah 41,396 18,300 29,400

Existing and Projected Usage of the I-35 Corridor Population Total Traffic, 2014-2040 Corridor Counties (Listed South to North 2012 2014 Avg. Annual Projected 2040 Along Corridor) Population Daily Traffic (AADT) AADT Love 9,582 45,400 60,000 Carter 48,035 35,000 53,200 Murray 13,655 27,800 42,300 Garvin 27,259 36,400 55,300 McClain 35,598 48,100 73,100 CLeveland 265,675 102,800 156,300 Oklahoma 742,509 87,500 133,000 Logan 43,692 39,300 59,700 Payne 78,282 22,100 33,600 Noble 11,546 19,100 29,000 Kay 45,779 17,200 56,200

Existing and Projected Usage of the I-44 Corridor Population Total Traffic, 2014-2040 Corridor Counties (Listed SW to NE 2012 2014 Avg. Annual Projected 2040 Along Corridor) Population Daily Traffic (AADT) AADT Cotton 6,154 11,600 17,700 Comanche 126,546 18,733 28,500 Caddo 29,680 N/A Grady 53,110 10,900 16,600 McClain 35,598 37,850 57,600 CLeveland 265,675 50,075 76,200 Oklahoma 742,509 110,029 167,200 Lincoln 34,201 13,165 20,000 Creek 70,583 25,200 38,300 Tulsa 614,163 65,000 99,000 Rogers 88,313 17,500 26,600 Mayes 41,096 8,245 12,600 Craig 14,726 10,258 15,600 Ottawa 32,252 19,600 29,800

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Appendix II: Map of Oklahoma Alternative Fuel Corridors

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Appendix III: Potential Muscogee (Creek) Nation EVSE Sites

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Appendix IV: Potential Kum & Go EVSE Sites

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Appendix V: EV Stations by State (Including Tesla)

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Appendix VI: EV Stations by State (Excluding Tesla)

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Oklahoma: America’s Alternative Fuels Crossroads

Oklahoma’s Alternative Fuel Corridor Nominations for the Federal Highway Administration (FHWA) Notice of Solicitation for Fixing America’s Surface Transportation Act – Designation of Alternative Fuel Corridors (81 FR 47850, FHWA Docket No. FHWA-2016-0017, Document Number 2016-17132)

Contents Letter of Support from the Oklahoma Department of Transportation ...... ii Introduction ...... 1 Corridor Nomination Overview, 1. Alternative Fuel Facilities, & 2. Corridor Scale/Impact ...... 3 Existing CNG Corridor ...... 3 Planned/Projected EV Corridor ...... 3 Corridor Information ...... 4 Nominated Corridors ...... 6 Interstate 40 – Existing CNG Corridor, Planned/Projected EV Corridor ...... 6 Interstate 35 – Existing CNG Corridor, Planned/Projected EV Corridor ...... 7 Interstate 44 – Existing CNG Corridor, Planned/Projected EV Corridor ...... 8 US-75/Indian Nations Turnpike Corridor – Existing CNG Corridor, Planned/Projected EV Corridor ...... 9 US-69 – Existing CNG Corridor, Planned/Projected EV Corridor ...... 10 3. Emissions Reductions ...... 11 4. Development of Team and Degree of Collaboration and Support ...... 11 Additional Information and Considerations ...... 13 Clean Cities Coalitions & Existing Alternative Fuel Markets ...... 13 Appendix ...... 15 Contact Information ...... 16

Letter of Support from the Oklahoma Department of Transportation OKLAHOMA DEPARTMENT OF TRANSPORTATION TRANSPORTATION

Introduction This document contains Oklahoma’s alternative fuel corridor nominations for the Federal Highway Administration (FHWA) Notice of Solicitation for Fixing America’s Surface Transportation Act – Designation of Alternative Fuel Corridors (81 FR 47850, FHWA Docket No. FHWA-2016-0017, Document Number 2016- 17132).

When the Federal Register solicitation for nominations of alternative fuel corridors was published in late July 2016, the Governor’s Office and the State Energy Office saw it as a great opportunity to showcase Oklahoma’s progress and continued leadership on advancing alternative fuels.

In 2011, Governor Fallin released the Oklahoma First Energy Plan1 which outlined how Oklahoma would continue to be a national and international energy and innovation leader. The plan outlines background, opportunities, challenges, strategies for each energy sector (oil & gas, renewables, etc.). Another goal of the plan is to find synergies between the energy sector and the industrial sector, workforce development, and most importantly for the purposes of this nomination – the transportation sector.

Two core strategies for creating synergy between the energy sectors and the transportation are to:

1. Make new compressed natural gas vehicle (CNG) purchases and conversions a viable and economic option for both the state and individual consumers 2. Strategically expand compressed natural gas and electric vehicle (EV) fueling and charging infrastructure

The state, in partnership with the private sector, has implemented these strategies to great success.

Drivers and fleets have increased compressed natural gas vehicle choices from original equipment manufacturers (OEM’s) or local conversion shops able to install Environmental Protection Agency (EPA) certified conversion kits. Governor Fallin and Colorado Governor John Hickenlooper joined together to develop a Memorandum of Understanding2 that stated a desire to purchase functional and affordable natural gas vehicles (NGV’s) for use in state fleets.

The Multi-State Natural Gas Vehicle Procurement MOU laid the groundwork for the formation of a Multi-State Request for Proposal, where the states prepared a formal request to automobile manufacturers to design NGV’s and sell in bulk to participating states. This aggregated purchasing model is now being replicated with other alternative fuels.3

Oklahoma now has the most CNG stations (per capita) in the nation with many more planned stations in the works. In 2009, the Oklahoma Legislature passed a number of natural gas vehicle bills including a legislative goal for the state to have a public CNG station on every 100 miles of Interstate within Oklahoma. In 2015, CNG retailers, bolstered by public and private fleet support, opened the station that moved Oklahoma past this goal. By the end of 2016, Oklahoma will have 100 public CNG stations.

While the state does have 34 electric vehicle public charging stations, many along interstate corridors, more stations are needed to connect Oklahoma communities. There are 1,385 electric vehicles registered in the state which is projected to grow exponentially over time.

The Association of Central Oklahoma Governments (ACOG) & the Indian Nations Council of Governments (INCOG), the Metropolitan Planning Organizations for their respective regions, house the state’s two U.S. Department of Energy (DOE) designated Clean Cities Coalitions which have both been in operation since 1996 & 1997 respectively. The Clean Cities coalition boundaries currently extend outside of the Oklahoma City and

1 Oklahoma First Energy Plan (2011) https://www.ok.gov/governor/documents/Governor%20Fallin's%20Energy%20Plan%20- %20Jan%202012.pdf 2 Multi-State Natural Gas Vehicle Procurement MOU https://www.ok.gov/governor/documents/Oklahoma-Colorado%20NGV%20MOU.pdf 3 The Energy Policy Act of 1992 (EPAct) identifies biodiesel, electricity, ethanol, hydrogen, natural gas, and propane as alternative fuels. Oklahoma: America’s Alternative Fuels Crossroads Page 1

Tulsa metropolitan areas to include fleet outreach and other benefits to communities in the surrounding counties, with plans to expand coverage throughout the state, as the above map indicates.

Increasing availability and affordability of electric vehicles is driving new demand for charging infrastructure in Oklahoma. Successful CNG public-private partnerships fostered by the state must now be replicated for EV’s. Electric utilities and auto dealerships are joining with public sector partners to identify strategic locations for EV charging. This work will be reflected in the corridor nominations outlined here.

In early 2016, the Clean Cities coalitions partnered with Oklahoma Gas & Electric, the largest electric utility in the state, and a number of other stakeholders, to develop an Oklahoma EV Coalition which is developing a strategic plan to increase adoption of EVs in the state. Recognizing that expanded charging infrastructure is a crucial aspect of increased adoption, OG&E is partnering with OnCue Express on a Direct-Current (DC) fast charging equipment installation in Yukon, OK, to enable rapid charging. The first-of-its-kind project will introduce thousands of Oklahomans to the charging experience and provide customer fuel choice for drivers on I-40. OG&E is in the process of identifying additional strategic charging locations in its territory.

The City of Oklahoma City is developing parking policies that encourage growth of charging stations in the public right-of-way and at private businesses, and the City of Tulsa included several provisions for EVs and EVSE in its new zoning code, updated in January 2016. In July 2016, the University of Oklahoma opened its first public EV charging station, with two more slated for 2016 construction. Electric vehicle charging is also available at the historic Skirvin Hotel in Downtown Oklahoma City.

Tulsa’s renovated downtown library, opening in October 2016, will have a number of public charging stations paid in part through CMAQ funding; the chargers will be partially powered by a solar array on the library’s roof.

Clean Cities coalition stakeholders are reaching out to airports, hospitals, and multi-family housing complexes about the benefits of electric vehicle charging as part of the U.S. Department of Energy’s Workplace Charging Challenge. The Challenge works with partners to set a minimum goal of providing charging for a portion of plug- in electric vehicle (PEV) driving employees and a best practice goal of meeting all employee demand. According to the DOE, more than 250 employers have joined as Challenge partners and the installation of workplace charging as a sustainable business practice is growing across the country. Partner efforts have resulted in more than 600 workplaces with over 5,500 charging stations accessible to nearly one million employees.4

Nationally, more than 42 million people live in metro areas along the highways nominated in this document, which means one in seven Americans is likely to use one of these highways to get to work, school, or travel. We fully support the nominations presented by states that border Oklahoma and along the routes of these nationally-significant highways.

4 http://energy.gov/eere/vehicles/workplace-charging-challenge-join-challenge Oklahoma: America’s Alternative Fuels Crossroads Page 2

Corridor Nomination Overview, 1. Alternative Fuel Facilities, & 2. Corridor Scale/Impact Existing CNG Corridor # of CNG Number of Distance Past Success Nominated Facilities Additional Between Visibility, Convenience, Replicability for Corridor Along Planned Existing & Accessibility Additional Corridor Facilities Facilities Facilities Interstate 40 17 2-4 ≤ 100 Interstate 40 is one of the most travelled Through public- Miles highways in the country and provides private- excellent visibility. partnerships Interstate 35 12 2-4 ≤ 100 Interstate 35 is one of the most travelled Oklahoma has built Miles highways in the country and provides a first-of-its-kind excellent visibility. CNG network along Interstate 44 12 2-4 ≤ 100 Interstate 44 serves as a highly visible, its interstates. Miles convenient, and accessible corridor connecting Oklahoma to Wichita Falls, Texas There is now a and Missouri as well as Tulsa, Oklahoma high-capacity public City, Lawton, and many other communities CNG station on within Oklahoma. every 100 miles of interstate within US 75 / 9 2-4 ≤ 100 US-75/INT comprises most of the main route Oklahoma. Indian Miles between Tulsa and Dallas. The corridor also Stakeholders will Nations intersects with three other corridors continue to identify Turnpike nominated in this application: I-40, I-44, and areas within the (INT) US-69, helping create a viable alternative state where there is fuels network throughout the state. demand for US 69 3 2-4 ≤ 100 US-69 is a major trucking route from Dallas, additional facilities. Miles through Oklahoma and northeast toward Kansas City, St. Louis, Chicago, and Indianapolis. It intersects with three other nominated corridors: US-75/INT, I-40, and I- 44. Together, these form a tightly connected network of alternative fuel corridors serving eastern Oklahoma and surrounding states.

Planned/Projected EV Corridor Number of # of EV Distance Additional Nominated Facilities Between Planned/ Visibility, Convenience, & Accessibility Corridor Along Planned Projected Corridor Facilities Facilities Interstate 40 7 1-2 ≤ 100 Interstate 40 is one of the most travelled highways in the country Miles and provides e