Application No.: 18-01-012

Exhibit No.: ______

Witnesses: J. O’Dea D. Niemeier E. Avol

DIRECT TESTIMONY OF JAMES O’DEA ON BEHALF OF UNION OF CONCERNED SCIENTISTS AND DIRECT TESTIMONY OF DEB NIEMEIER AND ED AVOL ON BEHALF OF CENTER FOR COMMUNITY ACTION AND ENVIRONMENTAL JUSTICE AND EAST YARD COMMUNITIES FOR ENVIRONMENTAL JUSTICE

ADRIANO L. MARTINEZ JAMES O’DEA SARA GERSEN Union of Concerned Scientists PAUL CORT 500 12th St., Suite 340 Earthjustice Oakland, CA 94607 800 Wilshire Blvd., Suite 1000 Los Angeles, CA 90017

Attorneys for Center for Community Action Representative for Union for Concerned And Environmental Justice and East Yard Scientists Communities for Environmental Justice

August 17, 2018 TABLE OF CONTENTS

I. INTRODUCTION ...... 1 II. MEDIUM- AND HEAVY-DUTY EMISSIONS BENEFITS, READINESS, AND ADOPTION – DR. JAMES O’DEA, UNION OF CONCERNED SCIENTISTS ...... 1 A. Medium- and Heavy-Duty Electric Vehicles Offer Significant Benefits for Air Quality and Climate Change ...... 2 B. Electric Truck and Bus Technology is Rapidly Becoming Available ...... 8 C. San Diego Gas & Electric Company’s Medium-Duty/Heavy-Duty Electric Vehicle Charging Infrastructure Program ...... 25 III. CAPITAL BUDGETS FOR MEDIUM- AND HEAVY-DUTY INFRASTRUCTURE PROGRAM SCENARIOS; FREIGHT ACTIVITY IN SAN DIEGO COUNTY’S DISADVANTAGED COMMUNITIES – PROFESSOR DEB NIEMEIER, UNIVERSITY OF CALIFORNIA DAVIS ...... 28 A. Program Options ...... 29 B. Mapping Disadvantaged Communities and Freight Activity in SDG&E’s Service Territory ...... 35 C. SDG&E’s Methodology...... 38 IV. HEALTH BENEFITS OF MEDIUM- AND HEAVY-DUTY VEHICLE ELECTRIFICATION – PROFESSOR ED AVOL, UNIVERSITY OF SOUTHERN CALIFORNIA ...... 43 A. Air Pollution Summary ...... 44 1. Ozone ...... 45

2. PM2.5 ...... 50 3. Diesel Exhaust ...... 52 4. Ultra-fine Particles ...... 54

5. Nitrogen Dioxide (NO2) ...... 55 B. Air Quality in San Diego County...... 56 C. Health Impacts of Air Pollution Sources in San Diego County ...... 66 D. Transportation Electrification ...... 80 E. SDG&E’s Medium-Duty/Heavy-Duty Electric Vehicle (“MD/HD EV”) Charging Infrastructure Program ...... 82

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LIST OF FIGURES Figure JO-1: Plotting California’s Path Forward ...... 3 Figure JO-2: Life cycle global warming emissions of transit buses powered by diesel, natural gas, hydrogen, and electricity ...... 6 Figure JO-3: Reduction of particulate matter and nitrogen oxide emissions compared to diesel buses meeting 2010 emissions standards ...... 6 Figure JO-4: Today’s battery and charging technology could meet the needs of many medium- and heavy-duty vehicles operating within California ...... 9 Figure JO-5: Range and charging times of battery and fuel cell electric transit buses (as of August 2018) ...... 10 Figure JO-6: Transit agencies operating, ordering, and commitments to zero-emission transit buses ...... 12 Figure JO-7: Incentive funding available for transit buses under California’s HVIP program ...... 12 Figure JO-8: Incentive funding available for school buses under California’s HVIP program ...... 14 Figure JO-9: Battery electric transit buses perform similarly, if not better than, combustion technologies across several categories, including noise, acceleration, fuel efficiency, and gradeability (left to right) ...... 24 Figure JO-10: Everett M. Rogers’ Adopter Categorization on the Basis of Innovativeness ...... 26 Figure DN-1: Disadvantaged Communities Identified with ROI ...... 36 Figure DN-2: Disadvantaged Communities Identified with SB 535 Index ...... 37 Figure DN-3: Disadvantaged Communities Identified with CalEnviroScreen ...... 38 Figure EA-1: Area Designations for State Ambient Air Quality Standards, Ozone ...... 58 Figure EA-2: Area Designations for State Ambient Air Quality Standards, PM2.5 ...... 59 Figure EA-3: Unhealthy Air Quality Days for San Diego County (2000-2017) ...... 61 Figure EA-4: Map of Southern San Diego County ...... 65 Figure EA-5: Environmentally Impacted Communities of Southern San Diego County . 66 Figure EA-6: Southern San Diego, from Downtown San Diego to Mexican Border (~14 miles)...... 73

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Figure EA-7: Risk Isopleth for Near-Source Cancer Risk at BNSF San Diego Railyard 75 Figure EA-8: San Diego Area Surrounding San Diego International Airport (Lindbergh Field) ...... 79

LIST OF TABLES Table DN-1: Capital Budget for ICF “In-Between” Scenario ...... 30 Table DN-2: Capital Budget for ICF “In-Between” Scenario Plus 3 Percent Electrification of Medium- and Heavy-Duty Vehicles ...... 31 Table DN-3: Vehicle Registration Data SDG&E Produced in Discovery ...... 40 Table DN-4: Comparison of SDG&E Data and EMFAC Data ...... 41

Table EA-1: Summary of O3 causal determinations by exposure duration and health outcome ...... 48 Table EA-2: Weight of evidence for causal determination ...... 49 Table EA-3: From the 2018 Lung Association “State of the Air” ...... 61 Table EA-4: Emission Inventory of Ozone Precursors in San Diego County and South Coast Air Basin, Combined for 2012 and 2017 (tons per day) ...... 68 Table EA-5: Emissions in San Diego County (tons per year) from the 2012 Maritime Emissions inventory report, released from the Port of San Diego in June 2014. Inventory emissions for on-road vehicle and locomotives estimated to include “…entire trip length within San Diego County, whether the trips stopped within San Diego County or further…” ...... 69 Table EA-6: Estimated Impacted Areas and Exposed Population Associated with Different Cancer Risk Levels (Assumes a 70-Year Exposure) ...... 75 Table EA-7: San Diego International Airport Emissions (REF21, Attachment C) ...... 78

LIST OF ATTACHMENTS Attachment A – Statements of Qualifications and CVs Attachment B – Selected SDG&E Responses to Data Requests Attachment C – Details Regarding the Data Sources and Methodology for Creating Maps of Disadvantaged Communities and Freight Activity in SDG&E’s Service Territory Attachment D – List of References Cited in Ed Avol’s Direct Testimony

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1 I. INTRODUCTION

2 The following expert testimony relates to San Diego Gas & Electric Company’s 3 (SDG&E) Medium-Duty and Heavy-Duty Electric Vehicle Charging Infrastructure Program. 4 First, Dr. James O’Dea of the Union of Concerned Scientists describes the emissions benefits 5 and technological readiness of medium- and heavy-duty electric vehicles and the scale of 6 SDG&E’s proposed program (MD/HD program). In the next section, Professor Deb Niemeier 7 testifies on behalf of East Yard Communities for Environmental Justice and Center for 8 Community Action and Environmental Justice. Professor Niemeier provides two scenarios for 9 the California Public Utilities Commission (CPUC) to consider in approving a capital budget for 10 an SDG&E medium- and heavy-duty vehicle program, and provides maps showing the 11 connection between freight activity and disadvantaged communities in SDG&E’s territory. 12 Finally, the testimony of Professor Ed Avol on behalf of East Yard Communities for 13 Environmental Justice and Center for Community Action and Environmental Justice provides a 14 primer on air pollution, discusses the health benefits of electrifying medium- and heavy-duty 15 vehicles and freight equipment, and recommendation strategies for maximizing public health 16 benefits from transportation electrification.

17 II. MEDIUM- AND HEAVY-DUTY EMISSIONS BENEFITS, READINESS, AND 18 ADOPTION – DR. JAMES O’DEA, UNION OF CONCERNED SCIENTISTS

19 Q. Please introduce yourself. 20 A. My name is Dr. James O’Dea. I am a Senior Vehicles Analyst at the Union of Concerned 21 Scientists (UCS). I have been an analyst at UCS for 2½ years. My area of research at UCS 22 includes analysis of vehicles’ life cycle emissions and monitoring industry trends surrounding 23 medium- and heavy-duty electric vehicles. Prior to joining UCS, I spent over 10 years studying 24 materials to improve the durability and performance of hydrogen fuel cells at Cornell University, 25 University of California, Santa Barbara, and the U.S. Department of Energy’s National 26 Renewable Energy Laboratory. Immediately before joining UCS, I was a Science and 27 Engineering Congressional Fellow for U.S. Senator Brian Schatz, where I advised the senator on 28 issues surrounding climate change.

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1 Q. Have you submitted testimony to the CPUC before? 2 A. Yes. I submitted testimony on behalf of UCS in the consolidated proceedings A.17-01- 3 020, A.17-01-021, and A.17-01-022 as well as in the consolidated proceedings A.17-10-007 and 4 A.17-10-008.

5 Q. What is the purpose of your testimony? 6 A. I will provide an overview of the life cycle emissions associated with diesel, natural gas, 7 hydrogen fuel cell, and battery electric trucks and buses and provide an overview of the 8 deployment and availability of medium- and heavy-duty electric vehicles.

9 A. Medium- and Heavy-Duty Electric Vehicles Offer Significant Benefits for Air 10 Quality and Climate Change

11 Q. Please describe California’s greenhouse gas reduction trajectory. 12 A. By law, statewide global warming emissions must be reduced to 1990 levels by 2020, and 13 to 40 percent below 1990 levels by 2030.1 Executive Order S-3-05 further calls for emission 14 reductions of 80 percent below 1990 levels by 2050.2 As illustrated in the following figure from 15 the California Air Resources Board (CARB) 2017 Climate Change Scoping Plan Update, 16 California’s 2030 global warming emissions standard significantly accelerates the needed pace 17 of greenhouse gas emission reductions as compared to the reductions needed to meet the 2020 18 target.

1 Assembly Bill 32 (2006), http://www.leginfo.ca.gov/pub/05-06/bill/asm/ab 0001- 0050/ab 32 bill 20060927 chaptered.pdf; Senate Bill 32 (2016), https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill id=201520160SB32. 2 Executive Order S-3-05 (June 1, 2005), https://web.archive.org/web/20110602181729/http:/gov.ca.gov/news.php?id=1861. 2

1 Figure JO-1: Plotting California’s Path Forward3

2 3 The 2030 emissions standard is not an endpoint, but a mid-term step toward meeting the 2050 4 goal of reducing emissions to 80 percent below 1990 levels by 2050.4 These reductions are 5 consistent with what scientific analyses indicate is necessary to limit the most severe 6 consequences of our already warming world.5 Indeed, the 2050 target should be viewed as 7 conservative. Consistent with the Paris Climate Agreement, the 2017 Climate Change Scoping 8 Plan recognizes that reaching the 2050 target sooner than called for by Executive Order S-3-05 9 would reduce the severity of climate impacts, finding that accelerated reductions “would have a 10 greater chance of preventing global warming of 2°C.”6

3 CARB, 2017 Climate Change Scoping Plan at 18 (Nov. 2017), https://www.arb.ca.gov/cc/scopingplan/scoping plan 2017.pdf (2017 Climate Change Scoping Plan). 4 Executive Order S-3-05, supra fn. 2; 2017 Climate Change Scoping Plan at 6. 5 2017 Climate Change Scoping Plan at ES-3 (explaining that these targets “represent benchmarks, consistent with prevailing climate science, charting an appropriate trajectory forward that is in line with California’s role in stabilizing global warming below dangerous thresholds”). See also Joeri Rogelj et al., Differences between carbon budget estimates unravelled, Nature Climate Change, Vo l . 6 , pp. 245-252 (Feb. 24, 2016), https://www nature.com/articles/nclimate2868; Intergovernmental Panel on Climate Change, Fourth Assessment Report, Section 13.3.3.3 (Implications of regime stringency: linking goals, participation and timing), http://www.ipcc.ch/publications and data/ar4/wg3/en/ch13-ens13-3-3-3.html (greenhouse gas emissions reductions below 90% of 1990 levels by 2050 necessary to avoid catastrophic climate impacts). 6 2017 Climate Change Scoping Plan at 18. See also United Nations, Paris Agreement, Article 2 ¶ 1(a) (2015), https://unfccc.int/sites/default/files/english paris agreement.pdf. 3

1 Q. What is the contribution of medium- and heavy-duty vehicles to California’s global 2 warming emissions? 3 A. By sector, transportation is the largest source of global warming emissions in California, 4 contributing 39 percent of the state’s total global warming emissions in 2016.7 Including the 5 production and refining of petroleum and natural gas, emissions from the transportation sector 6 are even larger. 7 Medium- and heavy-duty vehicles represent 21 percent of global warming emissions 8 from California’s transportation sector, or 8 percent of the state’s total emissions in 2016.8

9 Q. Please describe the contribution of medium- and heavy-duty vehicles to air pollution 10 in California.

11 A. Medium- and heavy-duty vehicles are the largest source of nitrogen oxides (NOx) across 12 all sectors in California—emitting 33 percent of the state’s total.9 Medium- and heavy-duty 13 vehicles also produce more particulate matter than all of the state’s power plants combined (23 14 tons per day versus 7 tons per day, respectively).10 The large contributions of medium- and 15 heavy-duty vehicles to global warming emissions and air pollution in California come despite 16 these vehicles comprising just 7 percent of vehicles in the state.11

17 Q. How do the emissions of battery electric trucks and buses compare to diesel and 18 natural gas vehicles? 19 A. The life cycle emissions of battery electric trucks and buses on today’s grid in California 20 are significantly lower than life cycle emissions from diesel and natural gas vehicles. On behalf 21 of UCS, I coauthored a study that analyzed the life cycle emissions from transit buses as a 22 representative example of heavy-duty vehicles. Buses resemble other heavy-duty vehicles in 23 many ways, including weight, size, fuel efficiency, emissions, urban routes, and central vehicle

7 CARB, California Greenhouse Gas Inventory for 2000-2016, https://www.arb.ca.gov/cc/inventory/data/tables/ghg inventory scopingplan sum 2000-16.pdf (last updated June 22, 2018). 8 Id. 9 CARB, Almanac Emission Projection Data: 2012 Estimated Annual Average Emissions (2013), https://www.arb.ca.gov/app/emsinv/2013/emssumcat query.php?F YR=2012&F DIV- =0&F SEASON=A&SP=2013&F AREA=CA. 10 Id. 11 CARB, Emissions Factors (EMFAC) 2017 Web Database (v1.0.2), https://www.arb.ca.gov/emfac/2017/ (last visited Aug. 15, 2018). 4

1 depots. The life cycle analysis considered both the tailpipe emissions and “upstream” emissions 2 from producing the fuel. Upstream emissions were based on fuels and electricity used in 3 California. It is important to consider both upstream and tailpipe emissions in policymaking to 4 not inadvertently shift pollution from one community to another. The analysis included global

5 warming emissions, NOx emissions, and particulate matter emissions for different fuel types, and 6 found the following:

7 • Life cycle global warming emissions from battery electric buses on today’s grid in 8 California (2016) are more than 70 percent lower than both compressed natural gas 9 (CNG) and diesel buses (Figure JO-2).

10 • Battery electric buses have more than 50 percent lower life cycle NOx emissions than

11 diesel and standard CNG buses and more than 30 percent lower NOx emissions than

12 CNG buses with engines certified to meet California’s voluntary low-NOx standards

13 (0.02 g NOx/brake horsepower-hour) (Figure JO-3).

14 • Battery electric buses also have lower life cycle particulate matter emissions than diesel 15 buses. Electric buses powered by electricity from sources representative of California’s 16 current power mix (e.g., natural gas, solar, wind, hydroelectric) show less dramatic 17 reductions in particulate matter due to electricity generation from coal and biomass power 18 plants. Particulate matter emissions from electricity generation will greatly decrease as 19 California’s sources of power become cleaner as required by state law (including no new 20 contracts for electricity generated with coal) (Figure JO-3).12

12 California Energy Commission (CEC), California’s Declining Reliance on Coal – Overview, https://www.energy.ca.gov/renewables/tracking progress/documents/current expected energy from coal.pdf (last updated Dec. 2017). 5

1 Figure JO-2: Life cycle global warming emissions of transit buses powered by diesel, 2 natural gas, hydrogen, and electricity13

3 4 Figure JO-3: Reduction of particulate matter and nitrogen oxide emissions 5 compared to diesel buses meeting 2010 emissions standards14

6 7 Since the release of the report in October 2016, we have updated our analysis to reflect 8 the final global warming emissions from the California grid in 2016. The updated numbers show

13 Sara Chandler, Joel Espino, and Jimmy O’Dea, Delivering Opportunity: How Electric Buses and Trucks Can Create Jobs and Improve Public Health in California, Union of Concerned Scientists and The Greenlining Institute, at 16 (May 2017), https://www.ucsusa.org/sites/default/files/attach/2016/10/UCS-Electric-Buses-Report.pdf. 14 Id. at 18. 6

1 battery electric buses have 77 percent lower global warming emissions than diesel and CNG 2 buses (compared to 70 percent lower in our original analysis). The updated numbers reflect that 3 California’s electricity grid is getting cleaner every year. This progress is reflected in the most 4 recent assessment of California’s renewable portfolio standard, California utilities were several 5 percentage points ahead of the standard’s 2016 target.15

6 Q. Please explain why electric vehicles offer lower emissions than combustion vehicles. 7 A. The emissions benefits of battery electric vehicles result from both low-carbon sources of 8 grid electricity and the greater efficiency of electric drivetrains compared to combustion engines. 9 On-road testing by the Federal Transit Administration of the same make of transit buses across 10 diesel, natural gas, and battery electric models revealed the battery electric model is nearly four 11 times more efficient than the diesel and natural gas models.16 Recent on-road testing by the 12 National Renewable Energy Laboratory of battery electric transit buses operated by Foothill 13 Transit in the San Gabriel Valley also found the fuel economy of battery electric buses was four 14 times better than CNG buses and up to eight times better on certain routes.17 15 The greater fuel efficiency of an electric vehicle means that for the same amount of fuel, 16 electric vehicles produce fewer life cycle emissions for the same distance traveled as a 17 combustion vehicle. For example, a battery electric bus powered by electricity produced 18 exclusively from a natural-gas power plant will travel twice as far as a CNG bus using the same 19 amount of natural gas, accounting for the efficiency of a natural gas power plant (51 percent), 20 losses in the transmission and distribution of electricity (6.5 percent), and vehicle efficiencies 21 (18.3 miles per gallon diesel equivalent for a battery electric bus and 4.5 miles per gallon diesel 22 equivalent for a CNG bus).18 The U.S. Department of Energy (DOE) found similar results when 23 comparing natural gas and battery electric light-duty vehicles.19 The greater efficiency of 24 electric vehicles compared to combustion vehicles is due to the laws of thermodynamics: natural

15 CPUC, Renewables Portfolio Standard Annual Report at 10 (Nov. 2017), http://www.cpuc.ca.gov/uploadedFiles/CPUC Website/Content/Utilities and Industries/Energy/Reports and White Papers/Nov%202017%20-%20RPS%20Annual%20Report.pdf. 16 Chandler et al., supra fn. 13, at 2, 24. 17 Leslie Eudy and Matthew Jeffers, Foothill Transit Battery Electric Bus Demonstration Results: Second Report, NREL, at 13-14, 16-17 (June 2017), https://www.nrel.gov/docs/fy17osti/67698.pdf. 18 Chandler et al., supra fn. 13, at 16. 19 U.S. DOE, Using Natural Gas for Vehicles: Comparing Three Technologies at 2 (Dec. 2015), https://www nrel.gov/docs/fy16osti/64267.pdf. 7

1 gas and diesel engines generate heat during combustion, and heat represents wasted energy that 2 is not converted into mechanical energy to propel the vehicle.

3 B. Electric Truck and Bus Technology is Rapidly Becoming Available

4 Q. Please provide an overview of medium- and heavy-duty vehicle sectors that could be 5 electrified. 6 A. Battery electric medium- and heavy-duty vehicles meet the specifications of many 7 applications including but not limited to transit buses, school buses, urban delivery and service 8 trucks, on- and off-road port and railyard trucks, forklifts, airport shuttle buses, transportation 9 refrigeration units, power take-off units, and truck stop electrification. Reaching the goal set by 10 seven California departments and agencies in the Sustainable Freight Action Plan of deploying 11 100,000 zero-emission freight vehicles and equipment by 2030 will require deployment of 12 electric vehicles across many medium- and heavy-duty applications.20

13 Q. Please describe the suitability of battery electric vehicles’ range for medium- and 14 heavy-duty vehicle applications. 15 A. Many medium- and heavy-duty vehicles drive short urban routes with frequent stopping 16 and idling. These vehicles are well suited to electrification with today’s technology, which 17 includes battery electric trucks and buses with ranges of more than 100 miles per charge. In 18 California, more than two-thirds of all heavy-duty trucks operating in the state have a range 19 (maximum trip distance) of less than 100 miles; more than half have an operating range of less 20 than 50 miles (see Figure JO-4). These distances are well within the range of existing heavy- 21 duty electric vehicles on a single charge. Depending on how a vehicle’s daily driving distance 22 matches with the range of the battery, the electric vehicle may need to be charged throughout the 23 day. Especially well-suited for electric vehicles are fleet vehicles operating on defined routes 24 with predictable stops and housed at central depot locations where vehicles can be recharged. 25 Compared with passenger cars, charging infrastructure in electric vehicle fleets can be 26 concentrated at depots or at strategic on-road locations.

20 California Department of Transportation, CARB, CEC, and the Governor’s Office of Business and Economic Development, California Sustainable Freight Action Plan (July 2016), http://www.casustainablefreight.org/documents/PlanElements/FINAL 07272016.pdf. 8

1 Figure JO-4: Today’s battery and charging technology could meet the needs of 2 many medium- and heavy-duty vehicles operating within California21

3 4 A summary of the range and charging times of battery electric transit buses compiled 5 from manufacture’s websites is shown in Figure JO-4. Buses with ranges of up to 425 miles on a 6 single charge are now offered; on-route charging of transit buses can yield up to 87 miles of 7 range in 23 minutes.

21 U.S. Census Bureau, California 2002 Economic Census: Vehicle Inventory and Use Survey (Aug. 2004), https://www.census.gov/prod/ec02/ec02tv-ca.pdf. These data exclude pickup trucks, minivans, SUVs, and other light vans. 9

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2 Battery electric transit buses are readily available today, with 22 models offered from eight 3 manufacturers.25 Over 100 electric transit buses have been deployed in California and more than 4 655 additional electric buses are on order,26 including 285 zero-emission transit buses recently 5 awarded to California transit agencies from the California State Transportation Agency (Figure 6 JO-6).27 CARB’s plan for allocating the Volkswagen Environmental Mitigation Trust, approved 7 on May 25, will fund approximately 525 zero-emission transit, school, and shuttle buses.28 8 Importantly, the Volkswagen Environmental Mitigation Trust solicitations will be on a first come, 9 first serve basis.29 California’s Hybrid and Zero Emission Bus and Truck Voucher Incentive 10 Project (HVIP) program also offers incentive funding of $80,000 to $190,000 for transit buses 11 depending on the size of the bus and if it is operated in a disadvantaged community (Figure JO- 12 7).30 HVIP also provides an additional incentive up to $30,000 for the first three vehicles a fleet 13 purchases to offset the cost of charging equipment.

25 CARB, Innovative Clean Transit, Slide 12 (Dec. 15, 2017), https://arb.ca.gov/msprog/ict/meeting/mt171215/171215presentation.pdf. A recent CARB discussion document explains several changes in the market for zero-emission buses since early 2016, including multiple zero-emission bus models and configurations becoming available, several manufacturers now offering battery electric buses with a nominal range exceeding 200 miles and at least one with 300 miles per charge, and Cummins announcing it would produce electric drivetrains for transit buses by 2019 and for trucks by 2020. CARB, Public Workshop on the Proposed Innovative Clean Transit Regulation Discussion Document at 12 (Dec. 15, 2017), https://arb.ca.gov/msprog/ict/meeting/mt171215/171215ictconcept.pdf. 26 CARB, Status of Battery and Fuel Cell Electric Buses in California Transit Agencies (May 2018), https://arb.ca.gov/msprog/ict/faqs/zbusmap.pdf. 27 California State Transportation Agency, Transit and Intercity Rail Capital Program 2018 Awards (2018), https://calsta.ca.gov/wp-content/uploads/sites/12/2018/04/Transit-and-Intercity-Rail-Capital-Program-2018- Awards.pdf. 28 CARB, Beneficiary Mitigation Plan for the Volkswagen Environmental Mitigation Trust at 21 (June 28, 2018), https://www.arb.ca.gov/msprog/vw info/vsi/vw-mititrust/documents/bmp jun2018.pdf. 28 CARB, Beneficiary Mitigation Plan for the Volkswagen Environmental Mitigation Trust at 21 (June 28, 2018), https://www.arb.ca.gov/msprog/vw info/vsi/vw-mititrust/documents/bmp jun2018.pdf. 29 Id. 30 CARB, Implementation Manual for the Hybrid and Zero-Emission Truck and Bus Voucher Incentive Project (HVIP) and Low NOx Engine Incentives Implemented through HVIP at 22 (Jan. 10, 2018), https://www.californiahvip.org/wp-content/uploads/2018/01/Final-IM-01172018.pdf. 11

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&$5%6WDWXVRI%DWWHU\DQG)XHO&HOO(OHFWULF%XVHVLQ&DOLIRUQLD7UDQVLW$JHQFLHV 0D\  KWWSVDUEFDJRYPVSURJLFWIDTV]EXVPDSSGI ,G  1 Twelve transit agencies in California, representing 43 percent of transit buses,33 have committed 2 to fully electrifying their fleets and 39 transit agencies in the state have deployed or are in the 3 process of deploying a battery or fuel cell electric bus, including San Diego Metropolitan Transit 4 System and North County Transit District in SDG&E’s service territory.34 King County Metro, 5 which operates in the Seattle-area and is the second largest transit agency on the West Coast with 6 1,400 buses in its fleet, recently found it is feasible from both a cost and technology perspective 7 to transition its entire fleet to zero-emission vehicles by 2034, with today’s technology capable 8 of meeting 70 percent of its current operations.35 9 Similarly, the California Air Resources Board found battery electric buses have a total 10 cost of ownership that is similar if not lower than diesel and natural gas buses in most of the 11 utility service territories the agency examined.36 The only incentive included in this analysis was 12 revenue from the Low Carbon Fuel Standard. Transit buses in SDG&E territory had a higher 13 total costs of ownership due to higher electricity rates in SDG&E’s territory.

14 School buses

15 Over 60 battery electric school buses across 19 school districts in the Los Angeles and 16 Sacramento regions have recently been approved for deployment in California.37 There are 17 currently five manufacturers providing battery electric school buses and two of the largest school 18 bus manufacturers (Navistar and Thomas) will offer battery electric school buses in 2019.38 19 Battery electric school buses have ranges up to 155 miles39 and can charge between morning and 20 afternoon runs and/or overnight.

33 Federal Transit Administration, National Transit Database: 2016 Vehicles (2016), https://www.transit.dot.gov/ntd/data-product/2016-vehicles. 34 CARB, Status of Battery and Fuel Cell Electric Buses in California Transit Agencies (May 2018), https://arb.ca.gov/msprog/ict/faqs/zbusmap.pdf. 35 King County Metro, Feasibility of Achieving a Carbon-Neutral or Zero-Emission Fleet at 2 (Mar. 2017), https://kingcounty.gov/~/media/elected/executive/constantine/news/documents/Zero Emission Fleet.ashx?la=en. 36 CARB, 5th Innovative Clean Transit Workgroup Meeting at slide 40 (June 26, 2017) https://arb.ca.gov/msprog/ict/meeting/mt170626/170626 wg pres.pdf. 37 Sacramento Metropolitan Air Quality Management District, Media Advisory: Largest deployment of electric school buses in the nation taking place in Sacramento (2017), www.airquality.org/Communications/Documents/Sac%20EV%20School%20Bus%20Advisory%20FINAL.pdf; South Coast Air Quality Management District, SCAQMD Awards $8.8 Million for Electric School Buses (June 2, 2017), www.aqmd.gov/docs/default-source/news-archive/2017/scaqmd-awards-$8-8-million-for-electric-school- buses---june-2-2017.pdf. 38 CARB, School Bus Fleet Webinar (Apr. 20, 2018), https://www.arb.ca.gov/msprog/truckstop/video/carbschoolbuswebinarpresentation.pdf. 39 The Lion Electric Co., Electric School Bus, https://thelionelectric.com/en/products/electric. 13

1 California’s Volkswagen Environmental Mitigation Plan will provide up to $400,000 for 2 the purchase of battery electric school buses; this amount will cover the entire cost of the bus plus 3 most of the charging equipment.40 The state’s HVIP program also offers significant incentives, 4 ranging from $25,000 to $235,000 depending on vehicle weight rating and whether the vehicle is 5 operated in a disadvantaged community.41

6 Figure JO-8: Incentive funding available for school buses under California’s HVIP 7 program42

8

9 Class 2 (6,0001–10,000 lbs gross vehicle weight rating, “GVWR”): Light trucks43

10 The Workhorse W-15 (7,200 lbs GVWR) is a battery electric plug-in hybrid truck similar 11 to the Ford 150, Chevrolet 1500, and Dodge 1500 in terms of size, weight, payload capacity, 12 towing capacity, and seating capacity.44 The W-15 has an all-electric range of 80 miles and a 13 hybrid range of 310 miles per tank of gasoline.45 The W-15 also features a 7.2 kW power

40 CARB, Beneficiary Mitigation Plan for the Volkswagen Environmental Mitigation Trust at 20-21 (June 28, 2018) https://www.arb.ca.gov/msprog/vw info/vsi/vw- mititrust/documents/bmp jun2018.pdf. 41 CARB, Implementation Manual for the Hybrid and Zero-Emission Truck and Bus Voucher Incentive Project (HVIP) and Low NOx Engine Incentives Implemented through HVIP at 23 (Jan. 10, 2018), https://www.californiahvip.org/wp-content/uploads/2018/01/Final-IM-01172018.pdf. 42 Id. 43 U.S. DOE, Vehicle Weight Classes and Categories, https://www.afdc.energy.gov/data/10380 (last updated June 2012). 44 See Workhorse, W-15 Pickup, http://workhorse.com/pickup/ (last visited May 10, 2018). 45 Id. 14

1 exporter that can power tools and equipment without the truck running. Over 5,000 orders have 2 been placed for the W-15 by fleet owners, including utility companies.46 Workhorse advertises 3 the W-15 as having a total cost of ownership lower than the Ford 150 due to fuel and 4 maintenance savings.47 Workhorse is an original equipment manufacturer and is expected to 5 deliver ordered vehicles at the end of 2018.48 6 Additionally, XL Hybrids offers a battery electric plug-in hybrid version of the Ford 150, 7 offering an advertised increase in fuel efficiency of 50 percent.49 This vehicle is eligible for a 8 $2,000 purchase incentive from CARB’s HVIP.50 The vehicle is a standard Ford 150 upfitted by 9 XL Hybrids with plug-in hybrid components. The plug-in hybrid option is offered on a range of 10 Ford 150 configurations.51 The plug-in hybrid system consists of a 15 kWh battery,52 which is 11 similar to the 20 kWh effective capacity and range of the Workhorse W-15.53

12 Class 3 through Class 6 (10,001–26,000 lbs GVWR): Medium-duty trucks, vans, and shuttle 13 buses

14 Numerous electric vehicle options are currently available in the medium-duty truck, van, 15 and shuttle bus categories, and 400 battery electric delivery trucks have already been deployed in 16 California.54 Workhorse has deployed the N-Gen electric light vans (10,001–14,500 lbs 17 GVWR), currently being tested by a customer in San Francisco. The van has 100 miles of range 18 on the battery and farther in an extended-range hybrid version of the vehicle. Workhorse says 19 the N-Gen vans can earn back their cost premium in less than three years through fuel and

46 CleanTechnica, Workhorse W-15 Orders Now Open To The Public (Jan. 11, 2018), https://cleantechnica.com/2018/01/11/workhorse-w-15-orders-now-open-public/. 47 Workhorse, The Workhorse W-15: The Electric Truck With A Lower Total Cost Of Ownership Than A Ford F 150 (May 3, 2017), http://workhorse.com/newsroom/2017/05/workhorse-w-15-electric-truck-lower-total-cost- ownership-ford-f-150. 48 Emme Hall, Workhorse W-15 electric pickup truck comes to CES 2018, CNET (Jan. 9, 2018), https://www.cnet.com/roadshow/news/workhorse-brings-its-w-15-electric-pick-up-truck-to-ces-2018/. 49 XLFleet, XLP Plug-in Hybrid Electric Upfit (Feb. 26, 2018), http://www.xlfleet.com/content/assets/Uploads/XL- XLP-F150-Flyer-8.5x11-LR.pdf. 50 California HVIP, Eligible Technologies: Your Clean Vehicles, https://www.californiahvip.org/eligible- technologies/#your-clean-vehicles (last visited Aug. 15, 2018) (California HVIP’s Your Clean Vehicles). 51 XLFleet, supra fn. 49. 52 Id. 53 Fred Lambert, Workhorse unveils its plug-in electric W-15 pickup truck: $52,000 and 60 kWh battery pack, Electrek (May 3, 2017), https://electrek.co/2017/05/03/workhorse-plug-in-electric-pickup-truck/. 54 CARB, Proposed Fiscal Year 2016–17 Funding Plan for Low Carbon Transportation and Fuels Investments and the Air Quality Improvement Program (May 20, 2016), www.arb.ca.gov/msprog/aqip/fundplan/proposed fy16- 17 fundingplan full.pdf; E-mail from Ryan Murano, Air Pollution Specialist, CARB (Aug. 9, 2018). 15

1 maintenance savings.55 UPS is leasing 50 larger versions of the N-Gen, some of which will be 2 deployed in Los Angeles and recently ordered an additional 950 N-Gen vans, contingent on the 3 performance of the first 50 deployed.56 UPS has said the purchase cost of these vehicles will be 4 comparable – without incentives – to similarly equipped combustion vehicles.57 UPS has said its 5 goal is “to make the new electric vehicles a standard selection, where appropriate, in its fleet of 6 the future.”58 7 Workhorse also offers the E-Gen plug-in hybrid electric step van with 60 miles of range 8 on the battery and 120 miles of total range. Companies that use step vans with the Workhorse 9 chassis (electric motor, batteries, etc.) include the United States Postal Service, DHL, Frito-Lay, 10 Cintas, Aramark, and others.59 11 Chanje offers the battery electric V8100 Panel Van with a 150-mile range (16,535 lbs 12 GVWR), 6,000 lbs payload capacity, and 675 cubic feet of storage space.60 Truck leasing and 13 rental company Ryder has ordered 625 panel vans from Chanje.61 Chanje panel vans are eligible 14 for $80,000 incentive funding from HVIP.62 15 Zenith Motors also offers a battery electric cargo van (10,050 lbs GVWR) with 530 cubic 16 feet of cargo space, a 3,800 lbs payload capacity, and up to 135 miles in range.63 This cargo van 17 is eligible for $50,000 incentive funding from HVIP.64 Zenith also offers a larger battery electric 18 step van (22,000 lbs GVWR) with a 6,000 lbs payload capacity and up to 95 miles per charge.65

55 Eric Walz, Workhorse Group to Deploy N-Gen Electric Delivery Vans in San Francisco, FutureCar (Mar. 30, 2018), http://www.futurecar.com/article-2097-1.html; Workhorse, Step Van, http://workhorse.com/stepvans (last visited Aug. 15, 2018). 56 Clarissa Hawes, UPS Places Order for 950 Workhorse Electric Delivery Trucks, Trucks.com (June 14, 2018), https://www.trucks.com/2018/06/14/ups-order-950-workhorse-electric-delivery-trucks/; UPS, UPS To Deploy First Electric Truck To Rival Cost Of Conventional Fuel Vehicles (Feb. 22, 2018), https://pressroom.ups.com/pressroom/ContentDetailsViewer.page?ConceptType=PressReleases&id=1519225541368 -230. 57 UPS, supra fn. 56. 58 Id. 59 Workhorse, supra fn. 55. 60 Chanje, Vehicles, https://chanje.com/vehicles/ (last visited Aug. 15, 2018). 61 Aaron Marsh, Another notch forward for electric commercial vans, FleetOwner (June 13, 2018), https://www.fleetowner.com/hd-pickup-van/another-notch-forward-electric-commercial-vans. 62 California HVIP, Your Clean Vehicles, https://www.californiahvip.org/eligible-technologies/#your-clean-vehicles (last visited May 10, 2018). 63 Zenith Motors, 100% Electric Vans & Buses (Dec. 2017), http://www.zenith-motors.com/wp- content/uploads/2013/05/Brochure122017.pdf. 64 California HVIP Your Clean Vehicles. 65 Zenith Motors, 100% Electric Vans & Buses (Dec. 2017), http://www.zenith-motors.com/wp- content/uploads/2013/05/Brochure122017.pdf. 16

1 Zenith’s customers include major hotel chains, local governments, and delivery companies.66 2 Zenith advertises over $100,000 in operations savings over the life of their vans.67 3 Motiv Power Systems offers a battery electric powertrain for the Ford E450, which is 4 eligible for $80,000 incentive funding from HVIP.68 Motiv’s electric Ford E450 is offered as a 5 walk-in van, box truck, work truck, shuttle bus, and school bus with ranges up to 75 miles.69 6 Motiv also offers an all-electric powertrain for the Ford F59 and F53 platforms with up to 90 7 miles in range.70 Motiv’s vehicles are eligible for HVIP incentives of $80,000 to $95,000.71 8 Phoenix Motor Cars also offers a battery electric powertrain for the Ford E450. Phoenix 9 Motor Cars has provided 16 battery electric shuttle buses built on the Ford E450 chassis to Wally 10 Park, an airport parking company serving LAX.72 The electric Ford E450 has a range of 100 11 miles and is also sold as a flatbed truck and a utility truck (14,500 lbs GVWR).73 These trucks 12 are eligible for $50,000 to $80,000 in incentives from HVIP.74 13 Lightning Systems also offers a battery electric version of the Ford Transit 350HD cargo 14 and passenger van with a range up to 150 miles and a payload capacity of 2,200–4,000 lbs.75 15 Deliveries of these vans were made in March of 2018, and CARB vehicle testing showed the 16 Lightning Systems cargo van has 61 mpg-equivalent on city routes compared to 13 mpg for the 17 gasoline version of the van.76 Lightning Systems is adding a hydrogen fuel cell range extender 18 to the van that will provide over 200 miles in range. The battery/fuel cell version will be 19 available in California in September of 2018.77 Lightning Systems also offers an electric shuttle 20 bus and cab chassis on a Ford E-450 chassis (14,500 lbs GVWR) and a range of up to 100

66 Zenith Motors, Our Customers, http://www.zenith-motors.com/our-customers/ (last visited Aug. 15, 2018). 67 Zenith Motors, Home, http://www.zenith-motors.com/ (last visited Aug. 15, 2018). 68 California HVIP Your Clean Vehicles. 69 Motiv Power Systems, Epic 4 Dearborn, http://www motivps.com/motivps/portfolio-items/epic4series/ (last visited Aug. 15, 2018). 70 Motiv Power Systems, Epic 6 Dearborn, http://www motivps.com/motivps/portfolio-items/epic6dearborn/ (last visited Aug. 15, 2018). 71 California HVIP Your Clean Vehicles. 72 Larry E. Hall, WallyPark Deploys Electric Shuttle Buses at LAX Airport, HybridCars (Apr. 12, 2017), http://www hybridcars.com/wallypark-deploys-electric-shuttle-buses-at-lax-airport/. 73 Phoenix Motor Cars, Products, http://www.phoenixmotorcars.com/products/#1505308785414-38579dc5-df17 (last visited Aug. 15, 2018). 74 California HVIP Your Clean Vehicles 75 Lightning Systems, Products: Lightning Electric, https://lightningsystems.com/vans (last visited August 15, 2018). 76 Lightning Systems, Lightning Systems Showcases All-Electric Ford Transit on Road Show and Announces Industry-Leading Efficiency Results (Apr. 3, 2018), https://lightningsystems.com/news-posts/lightning-systems- showcases-all-electric-ford-transit-on-road-show-and-announces-industry-leading-efficiency-results. 77 Id. 17

1 miles.78 Lightning Systems also offers a Class 6 low-cab forward truck (25,950 lbs GVWR) and 2 range up to 110 miles.79 3 BYD, the largest electric carmaker in the world,80 offers the 5F box truck, a Class 5 4 (19,500 lbs GVWR) battery electric truck with a 155-mile range. This truck is eligible for 5 $80,000 incentive funding from HVIP. BYD also offers the 6F box truck, a Class 6 (26,000 lbs 6 GVWR) battery electric truck with a 124-mile range. The 6F is eligible for $90,000 in HVIP 7 funding.81 BYD also offers the 6D, a Class 6 (23,000 lbs GVWR) step van with 100 miles in 8 range.82 9 Mitsubishi FUSO, under the parent company Daimler Group, offers the eCanter, a Class 10 4 (15,995 lbs GVWR) battery electric box truck with a range of up to 80 miles. Fleets with 11 eCanters include Habitat for Humanity, UPS, and University of California, Irvine.83 The eCanter 12 has been deployed since 2017, and a full product launch is scheduled for 2019.84 13 Thor Trucks is developing a Class 6 step-van with 50 miles of range that will be 14 commercially available in 2019.85 UPS is testing a version of this van with 100 miles of range 15 and 60-minute charging time.86

16 Class 7 and Class 8 (26,001 lbs + GVWR): Heavy-duty trucks

17 Electric options are also emerging in the heaviest truck classes. BYD currently offers the 18 8TT, a Class 8 battery electric tractor with 100 miles in range.87 Over 30 of these trucks have

78 Lightning Systems, Products: Lightning Electric, https://lightningsystems.com/ford-e450-shuttle-bus (last visited August 15, 2018). 79 Lightning Systems, Products: Lightning Electric, https://lightningsystems.com/class6-low-cab-forward (last visited August 15, 2018). 80 John Voelcker, China’s BYD tops global electric-car production for third year in a row, Green Car Reports (Feb. 21, 2018), https://www.greencarreports.com/news/1115398 chinas-byd-tops-global-electric-car-production-for- third-year-in-a-row. 81 California HVIP Your Clean Vehicles. 82 According to one new report, “[t]he BYD 6D Step Van is expected to hit the streets by early 2019.” Green Car Congress, BYD introducing battery-electric Class 6 stepvan in US (July 6, 2018), http://www.greencarcongress.com/2018/07/20180706-byd.html. 83 John O’Dell, Daimler Launches eCanter Electric Truck, UPS Among First Customers, Trucks.com (Sept. 14, 2017), https://www.trucks.com/2017/09/14/daimler-ecanter-electric-truck-launches/. 84 Mitsubishi Fuso, eCanter (2017), http://www.mitfuso.com/files/FUSO-eCANTER-Datasheet-EN-US.pdf. 85 Alan Adler, UPS Will Test Thor Medium-Duty Electric Truck in Los Angeles, Trucks.com (July 31, 2018), https://www.trucks.com/2018/07/31/ups-tests-thor-medium-duty-electric-truck/. 86 Id. 87 BYD Product Brochure, Spring 2018. 18

1 been ordered.88 This truck is eligible for $150,000 in HVIP incentives.89 Urban delivery, refuse, 2 drayage (i.e., moving cargo containers a short distance such as from a port to a nearby 3 warehouse), and yard hostlers (i.e., moving cargo containers within a port or railyard) are the 4 most immediate applications for heavy-duty electric trucks. Announced battery ranges of more 5 than 200 miles have suggested regional and possibly long-haul applications are within the 6 feasibility of the electric truck technology. 7 Many companies are developing Class 7 and 8 battery electric tractors that are nearing 8 production, including: Tesla, offering a truck with an announced range of 300–500 miles and 9 production beginning in 2019;90 Thor Trucks, offering the ET1, a Class 8 truck with up to 300 10 miles of range, expected to begin production in 2019;91 engine maker Cummins, demonstrating a 11 Class 7 electric day cab truck;92 Daimler Group, developing the E-FUSO Vision One (Mitsubishi 12 Fuso), a Class 8 truck with range up to 217 miles;93 Lion, offering a Class 8 electric tractor with 13 up to 480 kWh of batteries;94 Peterbilt (subsidiary of Paccar), producing an electric version of its 14 Model 579 (Class 8) truck with a 200 mile range that is being tested at the Port of Long Beach;95 15 and Volvo Trucks, beginning sale and production of electric versions of its FL (Class 7 with 187 16 mile range) and FE (Class 8 with 125 mile range) trucks in Europe in 2019 and intending to 17 bring these trucks to the U.S. market at a later date.96

88 Personal communication with Zach Kahn, Director of Government Relations & Director of Business Development, BYD (Apr. 30, 2018). BYD delivered the first 8TT in 2018 for operating at the Port of Oakland. See FleetOwner, BYD delivers first battery-electric truck to Port of Oakland (May 25, 2018), https://www fleetowner.com/running-green/byd-delivers-first-battery-electric-truck-port-oakland. 89 California HVIP Your Clean Vehicles. 90 Tesla, Semi, https://www.tesla.com/semi (last visited Aug. 15, 2018). 91 Thor Trucks, ET-One, http://www.thortrucks.com/et-one/ (last visited Aug. 15, 2018); Ryan ZumMallen, Thor Trucks Storming Into Heavy-Duty EV Market, Trucks.com (Dec. 13, 2017), https://www.trucks.com/2017/12/13/startup-thor-trucks-electric-truck-market/. 92 John O’Dell, Diesel Giant Cummins Unveils Class 7 Electric Truck Prototype, Trucks.com (Aug. 30, 2017), https://www.trucks.com/2017/08/30/cummins-unveils-electric-truck-prototype/. 93 Daimler, Electric Vision. The E-FUSO Vision One, https://www.daimler.com/innovation/case/electric/efuso-2 html (last visited Aug. 15, 2018). 94 Lion, Urban Class 8 Truck, https://thelionelectric.com/en/products/electric truck class8 (last visited Aug. 15, 2018). 95 Transport Topics, Peterbilt Displays All-Electric Class 8 Truck (May 8, 2018), https://www.ttnews.com/articles/peterbilt-displays-all-electric-class-8-truck. 96 Seth Clevenger, Volvo Pushes Forward With Electric Trucks, Transport Topics (June 21, 2018), https://www.ttnews.com/articles/volvo-pushes-forward-electric-trucks; Jerry Hirsch, Volvo Adds Refuse Truck to its Electric Vehicle Lineup, Trucks.com (May 8, 2018), https://www.trucks.com/2018/05/08/volvo-refuse-truck- electric-vehicle/. 19

1 Yard hostlers are a specific type of Class 8 tractors that shuttle cargo containers within 2 ports and railyards. Four manufacturers currently offer battery electric yard hostlers including 3 BYD’s terminal tractor,97 Kalmar’s Ottawa electric terminal tractor,98 Orange EV’s T-Series 4 trucks,99 and Terberg’s YT202-EV.100 Dole Fresh Fruit recently deployed electric yard hostlers 5 at the Port of San Diego.101 CARB’s Volkswagen mitigation plan will fund approximately 450 6 zero-emission Class 8 yard hostlers and drayage trucks, providing a maximum incentive of 7 $200,000 per truck.102 8 Refuse trucks are also a category of heavy-duty vehicles where electric options are being 9 tested and deployed. BYD recently took an order for 500 electric refuse trucks in Shenzhen, 10 China and received an order for two electric refuse trucks in Seattle in addition to one already 11 operating in Palo Alto.103 BYD’s electric refuse truck has a range up to 75 miles.104 Motiv 12 Power Systems has developed electric drivetrain demonstrations of four electric refuse trucks in 13 Chicago, Sacramento, and Los Angeles.105 Mack Trucks (part of Volvo Group) will demonstrate 14 an electric version of its LR refuse truck in New York City in 2019.106 And Peterbilt announced 15 it will produce three Model 520 electric refuse trucks with a range of up to 80 miles.107

97 BYD, Electric Tough, http://en.byd.com/usa/truck/ (last visited Aug. 15, 2018). 98 Kalmar, Kalmar Ottawa Electric Terminal Tractor, https://www kalmarglobal.com/equipment/terminal- tractors/all-terminal-tractors/kalmar-ottawa-electric-terminal-tractor/ (last visited Aug. 15, 2018). 99 Orange EV, T-Series, https://orangeev.com/t-series-new/ (last visited Aug. 15, 2018). 100 Terberg Benschop, Yard/Port Tractor Fully Electric, https://www.terbergbenschop nl/en/products/tractors/yard- tractors/yt202-ev/ (last visited Aug. 15, 2018). 101 Port of San Diego, Port and San Diego Port Tenants Association Celebrate New, Innovative Sustainable-Freight Vehicles to be used for Dole Cargo (July 26, 2018), https://www.portofsandiego.org/press-releases/general-press- releases/port-and-san-diego-port-tenants-association-celebrate-new. 102 CARB, supra fn. 28, at 24, A-3, A-7. 103 Kyle Field, BYD Lands Deal For 500 Electric Refuse Trucks With Two Companies in Shenzhen, Clean Technica (May 16, 2018), https://cleantechnica.com/2018/05/16/byd-lands-deal-for-500-electric-refuse-trucks-with-two- companies-in-shenzhen/; Mark Kane, BYD Will Deliver First Electric Garbage Trucks in Seattle, Inside EVs (July 28, 2018), https://insideevs.com/byd-will-deliver-first-electric-garbage-trucks-in-seattle/. 104 Kane, supra fn. 103. 105 John O’Dell, Motiv Poised to Profit as Demand Grows for Electric Trucks, Buses, Trucks.com (May 30, 2018), https://www.trucks.com/2018/05/30/motiv-profits-demand-electric-trucks-buses/. 106 Truckinginfo, Mack Plans for Electric Refuse Truck in NYC by 2019 (Apr. 24, 2018), https://www.truckinginfo.com/288080/mack-plans-for-electric-refuse-truck-in-nyc-by-2019. 107 Fred Lambert, Peterbilt becomes latest truck maker to work on all-electric class 8 truck to complete with Tesla Semi, Electrek (May 2, 2018), https://electrek.co/2018/05/02/peterbilt-truck-maker-all-electric-class-8-tesla-semi/; Clarissa Hawes, Freightliner Unveils its New Diesel-Powered Refuse Truck at WasteExpo (Apr. 24, 2018), https:/www.trucks.com/2018/04/24/freightliner-diesel-refuse-truck-wasteexpo/. 20

1 Wrightspeed offers a plug-in hybrid electric power train (Route 1000) for refuse trucks capable 2 of 24 miles on the vehicle’s battery.108

3 Q. What trends do you see in the deployment of medium- and heavy-duty electric 4 vehicles? 5 A. Hundreds of electric trucks and buses have already been deployed in California. I have 6 observed increased orders of and commitment to electric vehicles by fleet operators and expect 7 this trend to continue. For example, the Los Angeles County Metropolitan Transportation 8 Authority (LA Metro) approved contracts for 95 electric buses and adopted a motion endorsing a 9 plan to transition to a 100 percent zero-emission bus fleet by 2030.109 LA Metro has the second 10 largest transit bus fleet in the United States. The largest— the Metropolitan Transportation 11 Authority in the New York City metro area—recently indicated its intention to transitioning to an 12 all zero-emission fleet.110 13 CARB is developing standards for electric trucks and buses, driving the transition to 14 zero-emission vehicles. CARB’s proposed standards include: the Innovative Clean Transit 15 standard (all zero-emission transit bus purchases by 2029);111 the Zero-Emission Airport Shuttle 16 Bus standard (all zero-emission fleet by 2035);112 the Advanced Clean Local Truck standard 17 (zero-emission trucks comprise 15 percent of manufacturer sales by 2030);113 and recently- 18 proposed action for a zero-emission drayage truck standard, for implementation in the years

108 Wrightspeed Powertrains, The Route Powertrain, https://www.wrightspeed.com/the-route-powertrain (last visited Aug. 15, 2018). 109 LA Metro, Metro Leads the Nation in Setting Ambitious 2030 Zero Emission Bus Goal; Takes First Step with Purchase of 100 Electric Buses (Aug. 2, 2017), https://www.metro.net/news/simple pr/metro-leads-setting-2030- zero-emission-bus-goal/. 110 Metropolitan Transit Authority, Bus Plan at17 (Apr. 2018), http://web mta.info/nyct/service/bus plan/bus plan.pdf. 111 CARB, Public Workshop on the Proposed Innovative Clean Transit Regulation Discussion Document at 10 (Dec. 15, 2017), https://arb.ca.gov/msprog/ict/meeting/mt171215/171215ictconcept.pdf. In 2015, CARB Staff conducted the first technical evaluation of zero-emission bus technology and concluded that the technology was in the early commercialization stage. Id. at 2. The 2017 discussion document explains that several changes have occurred since 2016, including dozens of transit fleets purchasing zero-emission buses and committing to convert their fleets, and multiple zero-emission bus models and configurations becoming available from several manufacturers. Id. 112 CARB, Zero-Emission Airport Shuttle Bus Regulatory Language Outline at 4 (Mar. 6, 2018) https://www.arb.ca.gov/msprog/asb/workshop/asbdraftreglanguage.pdf. CARB held the first workshop in this rulemaking process on February 24, 2017. See CARB, Past Meetings and Events, https://www.arb.ca.gov/msprog/asb/asbmtgs.htm (last visited Aug. 15, 2018). 113 CARB, Advanced Clean Local Trucks, Second Workgroup Meeting, Slide 3 (Aug. 30, 2017), https://www.arb.ca.gov/msprog/actruck/mtg/170830arbpresentation.pdf. CARB held the first workshop in this rulemaking process on November 1, 2016. See CARB, Advanced Clean Trucks Meetings and Workshops, https://www.arb.ca.gov/msprog/actruck/actruckmtgs htm (last reviewed May 31, 2018). 21

1 2026-2028.114 CARB’s development of standards for zero-emission forklifts, cargo handling 2 equipment, and airport ground support equipment also point to the transition to zero-emission 3 off-road vehicles and equipment.115 As described earlier, the California Sustainable Freight 4 Action Plan, calling for the deployment of over 100,000 zero-emission heavy-duty vehicles and 5 equipment by 2030, represents a multi-agency commitment to zero-emission vehicles.116 6 The constant stream of announcements and commitments from private sector fleets and 7 manufacturers around zero-emission trucks point to the transition to battery and fuel cell electric 8 vehicles. Such announcements include Anheuser-Busch announcing its plans to replace its entire 9 long-haul truck fleet in the U.S. (800 trucks) with zero-emission vehicles by 2025;117 more than 10 400 orders placed by 20 companies for the Tesla electric semi-truck;118 major truck maker Mack 11 Trucks advertising “[t]he future is electric” when it recently rolled out an electric refuse truck;119 12 the electric school bus maker Lion Electric Co., which has 40 electric school buses operating in 13 California, recently announcing it will sell Class 5–8 electric trucks;120 major truck maker 14 Peterbilt announcing it is developing Class 8 electric drayage and refuse trucks;121 major truck 15 makers Navistar and Volkswagen announcing they will launch medium-duty electric trucks and 16 buses in the United States in 2019 or 2020;122 major diesel engine maker Cummins expecting 17 delivery of its electric powertrain in 2019;123 Daimler developing the eActros (under its 18 Mercedes-Benz brand), an urban delivery truck with up to 124 miles of range, currently being

114 CARB, Concepts to Reduce the Community Health Impacts from Large Freight Facilities, Slide 21 (Presented at March 2018 Board Meeting) https://www.arb.ca.gov/board/books/2018/032218/18-2-6pres.pdf. 115 CARB, 2016 State Strategy for the State Implementation Plan, Slides 44, 47 (Sept. 1, 2016), https://www.arb.ca.gov/planning/sip/2016sip/090116wkshp slides.pdf; CARB, supra fn. 114 at Slide 21. 116 California Department of Transportation et al., supra fn. 20, Attachment B at B-3. 117 John O’Dell, Anheuser-Busch Makes Record Order of 800 Nikola Fuel Cell Trucks, Trucks.com (May 3, 2018), https://www.trucks.com/2018/05/03/anheuser-busch-nikola-truck-order/. 118 Mark Matousek, Tesla has a new customer for its electric Semi — here are all the companies that have ordered the big rig, Business Insider (Apr. 25, 2018), https://www.businessinsider.com/companies-that-ordered-tesla-semi- 2017-12. 119 Mack Trucks (@MackTrucks), Twitter (Apr. 25, 2018), https://twitter.com/MackTrucks/status/989239753403977733. 120 Carly Schaffner, Lion Plans Electric Truck Line, Deploys School Buses, Trucks.com (May 2, 2018), https://www.trucks.com/2018/05/02/lion-electric-truck-line-school-buses/. 121 CDL Life, Peterbilt is at work on an all-electric Class 8 trucks (May 2, 2018), https://cdllife.com/2018/peterbilt- is-at-work-on-an-all-electric-class-8-truck/. 122 Emma Hurt, Navistar CEO to Tesla: We’ll Have More Electric Trucks Than You (Jan. 2, 2018), https://www.trucks.com/2018/01/02/navistar-versus-tesla-electric-trucks/. 123 Mark Kane, Cummins Outlines Plans for Electric Powertrains By 2019, Inside EVs (July 4, 2017), https://insideevs.com/cummins-outlines-plans-for-electric-powertrains-by-2019/. 22

1 tested by customers in Europe and expected for series production in 2021;124 and Daimler 2 announcing it will test electric versions of its Freightliner Cascadia (Class 8 with 250 mile range) 3 and eM2 (Class 5 with 230 mile range) in Southern California this year and will begin 4 production in 2021.125 5 Finally, the rapid progress made on electric vehicles outside of the United States points to 6 the readiness of electric vehicle technology today. Such progress includes over 300,000 electric 7 buses on the road in China,126 including the entire 16,000 bus fleet in Shenzhen;127 for reference, 8 there are 11,000 transit buses in all of California.128 One manufacturer alone in China— 9 Dongfeng Motor Corporation—has more than 64,000 electric trucks in operation today.129 The 10 German parcel service Deutsche Post alone expects to have 2,500 medium-duty electric postal 11 vans deployed in Germany by the end of 2018.130 Battery electric vehicle technology is ready 12 today and will become increasingly available in the United States in the coming months and 13 years.

14 Q. How does the performance of electric vehicles compare to combustion technologies?

15 A. In addition to better fuel economy, electric vehicles are comparable to, if not better than, 16 combustion technologies in other important measures of on-road performance: acceleration 17 times, gradeability, and torque. Gradeability refers to the vehicle’s ability to climb a hill and is 18 defined as the maximum grade a vehicle can climb at a given speed. As with acceleration, 19 different routes necessitate different amounts of gradeability. Another important on-road metric 20 for heavy-duty vehicles is torque, which is a measure of a vehicle’s ability to move from a

124 Daimler, All-electric Mercedes-Benz trucks for the heavy-duty distribution sector: Sustainable, fully electric and quiet: Mercedes-Benz eActros to roll out to customer (Feb. 21, 2018), https://media.daimler.com/marsMediaSite/en/instance/ko/All-electric-Mercedes-Benz-trucks-for-the-heavy-duty- distribution-sector-Sustainable-fully-electric-and-quiet-Mercedes-Benz-eActros-to-roll-out-to-customers-in- 2018.xhtml?oid=33451264. 125 Gabrielle Coppola and Olga Kharif, Daimler Adds Two Electric Trucks in Race Against Tesla, VW (June 6, 2018), https://www.bloomberg.com/news/articles/2018-06-06/daimler-adds-two-electric-trucks-in-race-against-tesla-vw. 126 Tim Dixon, China 100% Electric Bus Sales Drop to ~89,546 in 2017, EV Obsession (Jan. 25, 2018), https://evobsession.com/china-100-electric-bus-sales-drop-to-89546-in-2017/. 127 Linda Poon, How China Took Charge of the Electric Bus Revolution, City Lab (May 8, 2018), https://www.citylab.com/transportation/2018/05/how-china-charged-into-the-electric-bus-revolution/559571/. 128 Federal Transit Administration, 2016 Vehicles, https://www.transit.dot.gov/ntd/data-product/2016-vehicles (last visited Aug. 15, 2018). 129 John O’Dell, U.S. Hybrid Powers World’s First Fuel Cell Street Sweeper, Trucks.com (May 2, 2018), https://www.trucks.com/2018/05/02/us-hybrid-first-fuel-cell-street-sweeper/. 130 John Voelcker, Deutsche Post and Ford to build Transit-based electric van, Green Car Reports (June 16, 2017), www.greencarreports.com/news/1111053 deutsche-post-and-ford-to-build-transit-based-electric-van. 23

1 standstill. Electric Class 8 trucks have torques of more than 2,000 foot-pounds, which is higher 2 than the 1,200 to 1,800 foot-pounds of traditional diesel engines.131 Electric vehicles are also 3 significantly quieter than combustion technologies. Figure JO-9 compares noise, acceleration, 4 fuel economy, and gradeability of the 40-foot Xcelsior transit bus manufactured by New Flyer 5 across CNG, diesel, diesel hybrid, and battery electric models.132

6 Figure JO-9: Battery electric transit buses perform similarly, if not better than, 7 combustion technologies across several categories, including noise, acceleration, fuel 8 efficiency, and gradeability (left to right)

9

131 Andrew Papson and Michael Ippoliti, Key Performance Parameters for Drayage Trucks Operating at the Ports of Los Angeles and Long Beach at 16, CALSTART (Nov. 15, 2013), http://www.calstart.org/Libraries/I- 710 Project/Key Performance Parameters for Drayage Trucks Operating at the Ports of Los Angeles and Lo ng Beach.sflb.ashx; BYD, Class 8 Day Cab Brochure, http://en.byd.com/usa/wp- content/uploads/2018/07/8tt redesign6-23-18.pdf. 132 Chandler et al., supra fn. 13, at 25 (citing Altoona Bus Research and Testing Center at Pennsylvania State University’s Thomas D. Larson Pennsylvania Transportation Institute, http://altoonabustest.psu.edu/buses). 24

1 C. San Diego Gas & Electric Company’s Medium-Duty/Heavy-Duty Electric 2 Vehicle Charging Infrastructure Program

3 Q. Have you reviewed SDG&E’s proposal for a Medium-Duty/Heavy-Duty Electric 4 Vehicle Charging Infrastructure Program? 5 A. Yes, I have read the Medium-Duty/Heavy-Duty Electric Vehicle Charging Infrastructure 6 Program testimony offered by Hannon J. Rasool on behalf of SDG&E (Chapter 2) before the 7 CPUC on January 22, 2018.

8 Q. What are your observations about SDG&E’s proposal? 9 A. The proposed program would support the electrification of medium- and heavy-duty 10 electric vehicles, which offer significant emissions benefits. Life cycle emissions from electric 11 vehicles on today’s grid are already lower than combustion technologies and will only get lower 12 as more electricity is generated by renewable energy. 13 A broad range of medium- and heavy-duty electric vehicles are already on the market 14 today, enabling a variety of SDG&E’s customers to participate in the program. Electric vehicles 15 are also becoming increasingly available in medium- and heavy-duty applications, a trend I 16 expect will continue over the course of SDG&E’s five-year proposal.

17 Q. SDG&E states that its “program targets a small fraction of the population – 18 approximately 3% of SDG&E service territory population.”133 How did SDG&E arrive at 19 this target? 20 A. In discovery, SDG&E explained how it arrived at the target of about 3 percent adoption, 21 stating “Adoption curves show that the first 2.5% of technology adopters are ‘innovators.’ They 22 are followed by the next 13.5%, known as ‘early adopters.’ SDG&E’s program size of 3% helps 23 move the San Diego region market out of the innovators group into the early adopters group.”134

133 Chapter 2, Prepared Testimony of Hannon J. Rasool on behalf of San Diego Gas & Electric Company at HJR- 9:5-6. 134 SDG&E Response to TURN-SDG&E-DR-01, Q.11. All discovery responses cited in this testimony are included in Attachment B. 25

1 Q. What kind of adoption curve quantifies innovators, early adopters, and other 2 categories of technology adopters? 3 A. When SDG&E uses the term “adoption curves,” the Company may refer to Everett M. 4 Rogers’ research on the diffusion of innovation. In 1962, Rogers developed the following curve 5 to classify adopters of innovation:

6 Figure JO-10: Everett M. Rogers’ Adopter Categorization on the Basis of 7 Innovativeness135

8 9 Q. Does Rogers’ research on innovators and early adopters support limiting SDG&E’s 10 program to the first 3 percent of medium- and heavy-duty electric vehicles in the San Diego 11 region? 12 A. No. According to Rogers, early adopters are opinion leaders who play a critical role in 13 spreading new ideas and practices:

14 Early adopters are a more integrated part of the local social system than are 15 innovators. . . . This adopter category, more than any other, has the highest degree 16 of opinion leadership in most systems. Potential adopters look to early adopters 17 for advice and information about an innovation. The early adopter is conserved 18 by many to be “the individual to check with” before adopting a new idea. This 19 adopter category is generally sought by change agents as a local missionary for 20 speeding the diffusion process. Because early adopters are not too far ahead of 21 the average individual in innovativeness, they serve as a role model for many 22 other members of a social system. Early adopters help trigger the critical mass 23 when they adopt an innovation.136

24 Rogers’ findings suggest that early adopters of medium- and heavy-duty electric vehicles are 25 critical for achieving widespread transportation electrification. Therefore, SDG&E’s program

135 Everett M. Rogers, Diffusion of Innovations (5th ed. 2003) at 281 (Figure 7-3). 136 Id. at 283 (emphasis added). 26

1 should support a greater fraction of the early adopter population. A program that only electrifies 2 about 3 percent of medium- and heavy-duty vehicles would not be sufficient to ensure 3 widespread transportation electrification.

27

1 III. CAPITAL BUDGETS FOR MEDIUM- AND HEAVY-DUTY 2 INFRASTRUCTURE PROGRAM SCENARIOS; FREIGHT ACTIVITY IN 3 SAN DIEGO COUNTY’S DISADVANTAGED COMMUNITIES – 4 PROFESSOR DEB NIEMEIER, UNIVERSITY OF CALIFORNIA DAVIS

5 Q. Please introduce yourself. 6 A. My name is Debra (Deb) Niemeier and I am submitting this testimony on behalf of 7 Center for Community Action and Environmental Justice and East Yard Communities for 8 Environmental Justice. 9 I am a Professor in the Department of Civil and Engineering and the School of Education 10 at University of California, Davis, where my research focuses on integrating models for 11 estimating mobile source emissions with transportation modeling. My primary research has been 12 on developing highly accurate, accessible processes and emissions modeling and travel behavior 13 models that policymakers and agencies can use, including the identification and modeling of 14 environmental health disparities and improved understanding of formal and informal governance 15 processes in urban planning. In 2014, I was named a Fellow of the American Association for the 16 Advancement of Science for “distinguished contributions to energy and environmental science 17 study and policy development.” In 2015, I was named a Guggenheim Fellow for foundational 18 work on pro bono service in engineering. In 2017, I was elected to the National Academy of 19 Engineering. 20 I received my B.S. in civil engineering from the University of Texas (1982), and Ph.D. 21 in civil engineering from the University of Washington (1994). I have included my CV in 22 Attachment A.

23 Q. What is the purpose of your testimony? 24 A. I present an array of options for the California Public Utilities Commission (CPUC) to 25 consider in approving a budget for a medium- and heavy-duty electrification program for San 26 Diego Gas and Electric Company (SDG&E or Company). Specifically, I provide capital budgets 27 for make-ready infrastructure in three scenarios: to support electrification under (1) ICF and E3’s

28

1 California Transportation Electrification Assessment (TEA Study)137 “in-between” case; and (2) 2 a scenario reflecting the 3% fleet electrification SDG&E proposes. 3 I also provide maps that show many of the disadvantaged communities are located in 4 regions that are either heavily impacted by traffic or have seriously reduced accessibility (e.g., 5 heavily rural). 6 Finally, I discuss SDG&E’s basis for designing a program that would electrify about 7 3,100 vehicles. Based on my analysis, SDG&E’s proposed program would not achieve the 8 company’s stated goal of supporting electrification of 3% of the medium- and heavy-duty 9 vehicle population in its service territory. To reach that goal, the CPUC would need to expand 10 the scale of SDG&E’s proposed program. I have provided a scenario that shows the level of 11 program expansion that would have to occur to support 3% fleet electrification.

12 A. Program Options

13 Q. Please provide the two medium- and heavy-duty program scenarios you developed. 14 A. In the first scenario, SDG&E provides infrastructure to support the medium- and heavy- 15 duty vehicles and equipment deployed in its service territory consistent with the TEA Study’s 16 “in-between” case. As illustrated in Table DN-1, SDG&E could provide make-ready 17 infrastructure at 262 sites, with a capital budget of $42.6 million. This scenario supports the 18 electrification of a total of 3,392 vehicles and equipment, with significant electrification inroads 19 on forklifts and airport ground support equipment. At full implementation, the program reduces

20 tailpipe emissions by approximately 15.5 tons per year of PM2.5, NOx emissions by 440.7 tons

21 per year, and CO2 emissions by 57,514 tons per year (assuming 261 working days per year). As 22 with all scenarios, the final overall reduction for greenhouse gases will be a function of the 23 yearly power mix used by SDG&E to produce electricity.

137 ICF International and Energy+Environmental Economics, California Transportation Electrification Assessment, Phase 1: Final Report (Aug. 2014; updated Sept. 2014), http://www.caletc.com/wp- content/uploads/2016/08/CalETC TEA Phase 1-FINAL Updated 092014.pdf (TEA Study). 29

1 Table DN-1: Capital Budget for ICF “In-Between” Scenario

Category Est. Total No. Sites No. Veh- Reduction in Pollutants (tpd) Capital Budget Sector Cost/Site Equip PM2.5 NOx CO2 Off-Road $ 22,106,492 Forklifts (Class 1) $132,613 $ 15,011,792 113 1132 0.0157 0.2150 23.4 Truck Stop Elect. (TSE) $99,038 -- (no data avail.) ------Transp Refrig Units (TRUs) $185,539 $ 4,609,179 25 472 0.0031 0.0982 2.0 Port Cargo Handling Equip $334,565 $ 1,226,738 4 11 0.00008 0.0025 0.9 Airport GSE $133,913 $ 1,258,782 9 188 0.0028 0.0455 5.5 On-Road $ 20,525,910 Transit Bus $341,071 $ 6,821,420 20 480 0.0336 0.8517 158.1 School Bus $146,730 $ 3,301,425 23 270 0.0034 0.4675 12.8 Med. Duty Veh $148,097 $ 10,033,572 68 813 0.0006 0.0080 17.1 Heavy Duty Veh* $341,071 $ 369,494 1 26 0.0000 0.0003 0.5 2 TOTAL FUNDING $ 42,632,402

3 In the second scenario, SDG&E provides infrastructure to support the medium- and 4 heavy-duty vehicles and equipment deployed in its service territory at the level of 3% fleet 5 electrification. As illustrated in Table DN-2, SDG&E could provide make-ready infrastructure at 6 1,069 sites, with a capital budget of $185.9 million. This scenario supports the electrification of 7 a total of 14,553 vehicles and equipment, with 3% electrification on medium and heavy-duty 8 vehicles. At full implementation, the program reduces tailpipe emissions by approximately 17.5

9 tons per year of PM2.5, NOx emissions by 469.4 tons per year, and CO2 emissions by 112,527 10 tons per year.

30

1 Table DN-2: Capital Budget for ICF “In-Between” Scenario Plus 3 Percent 2 Electrification of Medium- and Heavy-Duty Vehicles

Category Est. Total No. Sites No. Veh- Reduction in Pollutants (tpd) Capital Budget Sector Cost/Site Equip PM2.5 NOx CO2 Off-Road $ 22,106,492 Forklifts (Class 1) $132,613 $ 15,011,792 113 1132 0.0157 0.2150 23.4 Truck Stop Elect. (TSE) $99,038 -- (no data avail.) ------Transp Refrig Units (TRUs) $185,539 $ 4,609,179 25 472 0.0031 0.0982 2.0 Port Cargo Handling Equip $334,565 $ 1,226,738 4 11 0.00008 0.0025 0.9 Airport GSE $133,913 $ 1,258,782 9 188 0.0028 0.0455 5.5 On-Road $ 163,829,470 Transit Bus $341,071 $ 6,821,420 20 480 0.0336 0.8517 158.1 School Bus $146,730 $ 3,301,425 23 270 0.0034 0.4675 12.8 Med. Duty Veh $148,097 $ 111,072,750 750 9000 0.0066 0.0887 188.8 Heavy Duty Veh* $341,071 $ 42,633,875 125 3000 0.0022 0.0296 62.9 3 TOTAL FUNDING $ 185,935,962

4 Q. Please describe how you developed program options for supporting medium- and 5 heavy-duty vehicles in SDG&E’s service territory. 6 A. First, for each scenario, I estimated the number of electric vehicles in each of the vehicle 7 and equipment categories that the scenario would support. Second, I calculated a capital budget 8 for providing make-ready infrastructure for those vehicles. Finally, I estimated the emission 9 reductions that would result from each scenario.

10 Q. How did you estimate the number of vehicles and equipment each scenario would 11 support? 12 A. For the first scenario, my method started with the TEA Study’s in-between forecast for 13 electric vehicle and equipment adoption. The TEA Study forecasts statewide adoptions under 14 each scenario for 2020 and 2030 for several categories of electric vehicles and equipment.138 I 15 estimated statewide adoption figures in 2023 using a Compound Annual Growth Rate (CAGR) 16 for vehicle and equipment categories that Pacific Gas and Electric Company (PG&E) included in 17 its FleetReady program. CAGR calculates the rate of growth between two data points in a given 18 time period. 19 Next, I estimated the proportion of the 2023 statewide vehicles and equipment 20 attributable to SDG&E territory. I used the California Air Resources Board’s (CARB)

138 TEA Study at 15 (Table 8), 19 (Table 12). 31

1 EMFAC2014139 mobile source emissions model and the 2017 off-road diesel analysis ORION 2 database140 for San Diego County, which closely approximates the SDG&E service area, to 3 derive fleet population and pollutant data.141 The EMission FACtors (EMFAC) model was 4 developed and is used by the CARB to calculate emissions from on-road vehicles. The ORION 5 web database is the CARB online inventory tool that includes emissions and population data for 6 off-road diesel vehicles. For the buses, I calculated the proportion of buses electrified by the 7 allocated funding in the CPUC decision and applied that same proportion to the bus fleet in 8 SDG&E’s service area. For the second scenario, I simply increased the vehicle medium- and 9 heavy-duty vehicle fleet in the first scenario such that it achieved the 3% fleet electrification. 10 This conservative method underestimates the vehicle population in SDG&E’s territory because 11 the company’s service territory is bigger than San Diego County, extending into parts of Orange 12 County.

13 Q. How does this method for estimating electric vehicle adoption differ from the 14 methods PG&E and Southern California Edison (SCE) used to develop their medium- and 15 heavy-duty vehicle infrastructure program proposals? 16 A. PG&E and SCE also relied on the TEA Study as the basis of their estimates for medium- 17 and heavy-duty electric vehicle adoption in their service territories. However, both utilities used 18 a unique method for estimating their service territory’s share of the electric vehicle population. 19 For medium-duty vehicles and most heavy-duty vehicles, PG&E estimated that its service 20 territory would represent 43% of statewide electric vehicle adoption because its service territory 21 is 43% of California’s area.142 For both medium- and heavy-duty vehicles, SCE applied a 38% 22 scaling factor “derived from SCE’s share of commercial and industrial activity” to the TEA 23 Study’s statewide data.143

139 CARB, Mobile Source Emissions Inventory – Categories, https://www.arb.ca.gov/msei/categories htm#onroad motor vehicles (last visited Aug. 17, 2018). 140 CARB, Mobile Source Emissions Inventory – Off-Road Diesel Vehicles, https://www.arb.ca.gov/msei/ordiesel.htm (last visited Aug. 17, 2018). 141 EMFAC2014 is the U.S. Environmental Protection Agency (U.S. EPA) approved mobile source emissions model; EMFAC2017 is the updated version, but has not yet been approved by U.S. EPA. 142 A.17-01-022, Transportation Electrification SB 350 Prepared Testimony at 3-18, 3-19 (Jan. 20, 2017) (PG&E Testimony). 143 A-17-01-021, Testimony of Southern California Edison Company in Support of its Application of Southern California Edison Company (U 338-E) For Approval of its 2017 Transportation Electrification Proposals at D-4 (Jan. 20, 2017). 32

1 I believe that relying on EMFAC’s vehicle population data for San Diego County is 2 preferable to either PG&E or SCE’s approaches because it directly relates to the fleet and fleet 3 composition in SDG&E’s service area. Comparable methods were not available to PG&E or 4 SCE. Unlike SDG&E, the EMFAC database does not allow users to search for a geographic area 5 that closely coincides with their service territories.

6 Q. How did you calculate capital budgets for each scenario? 7 A. First, I determined the number of sites for each category of vehicle and equipment, 8 relying on PG&E’s method for estimating site numbers from vehicle numbers. PG&E used the 9 following to calculate the total numbers of sites for different fleets,144

10 . = # 𝑉𝑉𝑉𝑉ℎ𝑖𝑖𝑖𝑖𝑖𝑖𝑖𝑖 𝑝𝑝𝑜𝑜𝑜𝑜𝑜𝑜𝑜𝑜𝑜𝑜𝑜𝑜𝑜𝑜𝑜𝑜𝑜𝑜 𝑁𝑁𝑁𝑁 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 � � ∗ 𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴ℎ 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 𝐶𝐶ℎ𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎 𝑃𝑃𝑃𝑃𝑃𝑃 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 11 By re-expressing the formula, we can calculate the vehicle population as,

. # 12 =

𝑁𝑁𝑁𝑁 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 ∗ 𝐶𝐶ℎ𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎 𝑃𝑃𝑃𝑃𝑃𝑃 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 𝑉𝑉𝑉𝑉ℎ𝑖𝑖𝑖𝑖𝑖𝑖𝑖𝑖 𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃 13 I used PG&E’s estimated number of chargers per site and𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴 attach𝐴𝐴ℎ 𝑅𝑅 𝑅𝑅𝑅𝑅𝑅𝑅rates145 to calculate the number 14 of vehicles for each sector. 15 Then, I based the capital budget on the budget the CPUC approved for PG&E’s 16 FleetReady Program.146 Specifically, I assumed that the per-site capital costs for each type of 17 vehicle and equipment would be the same as the estimated costs the CPUC approved for 18 PG&E’s FleetReady budget.147

19 Q. How did you estimate the pollution reductions in each scenario? 20 A. Using the fleet data from EMFAC, I was able to calculate an emission rate for each 21 vehicle category (lbs per day). I then applied this rate to the number of vehicles targeted for

144 PG&E Testimony at 3-23. 145 Id. at 3-23, Table 3-7. 146 D.18-05-040, Decision on the Transportation Electrification Standard Review Projects, A.17-01-020/021/022 (June 6, 2018). 147 Id. at Appendix C, Table 6. 33

1 electrification in each vehicle category. This approach likely over-estimates emissions reductions 2 because it does not take into account power generation emissions.

3 Q. Are there any limitations to this methodology for developing an infrastructure 4 budget for an electric vehicle program? 5 A. Yes, the CPUC should consider the following limitations in the methodology I used to 6 develop program budgets when it determines a program budget for SDG&E. 7 First, the budgets I developed only include capital costs of make-ready infrastructure. 8 My budgets rely on the capital budget the CPUC approved for PG&E’s FleetReady program and 9 do not include any items in PG&E’s expense budget. The CPUC approved a program budget for 10 PG&E that included other costs, including rebates for Electric Vehicle Supply Equipment and 11 education. The capital budgets I provide are a building block for creating a program budget— 12 not a total program budget. 13 Second, I relied on the TEA Study, which was published in 2014 and may underestimate 14 the demand for electric medium- and heavy-duty vehicles. In his testimony, Dr. James O’Dea 15 addresses more recent market trends and regulatory activity affecting the deployment of 16 medium- and heavy-duty vehicles. 17 Third, I did not estimate a capital budget to support the electrification of Class 2 18 vehicles, even though it would be reasonable for the CPUC to approve a program with an 19 increased capital budget to support Class 2 vehicles. Class 2 vehicles are light-duty vehicles 20 such as maintenance vans and pickup trucks. SDG&E proposed including Class 2 vehicles in its 21 MD/HD program. If the CPUC approves a program that includes Class 2 vehicles, the program 22 would require a greater budget than I have indicated in the program options above. 23 Fourth, I estimate aggregate emission reductions. As Ed Avol discusses in his 24 testimony, the public health benefits of emission reductions will depend in part on where those 25 reductions occur. My emission reduction estimates are aggregate figures and, as such, do not 26 indicate if they will occur in the communities that are most overburdened by pollution. 27 However, by targeting certain locations, SDG&E should be able to reduce pollutants in 28 disadvantaged areas.

34

1 B. Mapping Disadvantaged Communities and Freight Activity in SDG&E’s 2 Service Territory

3 Q. Please describe the maps you developed of disadvantaged communities in SDG&E’s 4 territory. 5 A. We created three maps showing the census tracts of disadvantaged communities. The 6 maps show the census tract using the Regional Opportunity Index (ROI), the Senate Bill (SB) 7 535 criteria, and CalEnviroScreen. Each of the indicators targets slightly different population. 8 The ROI reflects both a “people” and “place” component, integrating economic, environmental, 9 infrastructure, and social indicators into a single index (Figure DN-1). The SB 535 10 disadvantaged communities are those that have been designated by the California Environmental 11 Protection Agency and are targeted for cap and trade expenditures (Figure DN-2). Finally, 12 CalEnviroScreen deploys a set of indicators that identify the highest scoring 25% of census tracts 13 on these indicators as disadvantaged (Figure DN-3). 14 While these individual indices produce some overlap in the census tracts that they 15 identify, because they target different factors, these mapping exercises provide additional 16 locations for SDG&E to target investments. I have included additional details regarding the data 17 sources and methodology for creating the maps in Attachment C.

18 Q. How do the disadvantaged communities in SDG&E’s service territory correlate with 19 traffic in the freight sector? 20 A. We overlaid significant truck, rail, and port corridors. From these maps, it is clear that 21 SDG&E should be able to identify specific areas and truck movement on specific corridors for 22 electrification that will benefit disadvantaged communities.

35

1 Figure DN-1: Disadvantaged Communities Identified with ROI

2

36

1 Figure DN-2: Disadvantaged Communities Identified with SB 535 Index

2

37

1 Figure DN-3: Disadvantaged Communities Identified with CalEnviroScreen

2

3 C. SDG&E’s Methodology

4 Q. How did SDG&E develop the scale of its proposed program? 5 A. SDG&E witness Hannon J. Rasool states:

6 The scope and size of the Program is based on the number of commercial vehicles 7 in SDG&E’s service territory, fleet sizes and California’s goals. These factors 8 shaped the Program in a manner that takes into consideration San Diego’s 9 customer base and one which begins the process of enabling these market 10 segments. There are approximately 103,000 Class 2 – Class 8 commercial

38

1 vehicles in SDG&E’s service territory. SDG&E’s program targets a small fraction 2 of the population – approximately 3% of SDG&E service territory population.148

3 Mr. Rasool’s pre-filed testimony cites “Proprietary IHS/Polk Data (June 2016)” to 4 support its conclusion that there are about 103,000 Class 2–8 vehicles in SDG&E’s service 5 territory.149

6 Q. Did you verify the data underlying SDG&E’s approach? 7 A. No. I do not have access to the IHS/Polk data SDG&E relied on because I have not 8 purchased it, and SDG&E could not provide it to parties in discovery because the Company’s 9 license to the data has expired. The Utility Reform Network (TURN) requested the analysis and 10 workpapers that SDG&E used to determine the scope and size of its proposed MD/HD electric 11 vehicle program. SDG&E’s response stated, in part:

12 SDG&E used the state’s goals and the local commercial fleet population to 13 determine the size of the program. SDG&E’s annual license for the IHS/Polk 14 Data has expired. Under the license agreement, SDG&E was required to dispose 15 of the source data at the expiration of the license. However, SDG&E was allowed 16 to retain information derived from the source data.150

17 SDG&E’s response included the following chart to show its calculation of 103,115 18 vehicles in Class 2–8:

148 Chapter 2, Prepared Testimony of Hannon J. Rasool on Behalf of San Diego Gas & Electric Company at HJR-9 (footnote omitted). 149 Id. at HJR-9, fn. 10 150 SDG&E Response to TURN-SDG&E-DR-01, Q.4. 39

1 Table DN-3: Vehicle Registration Data SDG&E Produced in Discovery151

2 3 Q. Is SDG&E’s conclusion that there about 103,000 Class 2–8 vehicles in its service 4 territory consistent with publicly available data? 5 A. No. The figures SDG&E provided in discovery are much lower than the vehicle 6 population data in EMFAC for San Diego County. In Table DN-4, I compare the data SDG&E 7 relied on with the vehicle population data in the EMFAC database for San Diego County.

151 Id. 40

1 Table DN-4: Comparison of SDG&E Data and EMFAC Data

Class SDG&E derived EMFAC 2016, from IHS/Polk San Diego County data

2 68068 163284 3 6837 503038 4 4825 333190 5 4168 67039 6 5176 14085 7 2899 21831 8 11142 14928 TOTAL 103115 1117395

2 EMFAC includes a reputable data set on vehicle populations, which CARB maintains 3 and relies on. As I have explained, I expect the EMFAC data for vehicle populations in San 4 Diego County to be a reasonable but conservative approximation of vehicle populations within 5 SDG&E territory.

6 Q. What might explain the differences between the data SDG&E relied on and the data 7 in CARB’s EMFAC model? 8 A. It is possible that the data SDG&E relied on was the “[m]onthly new registration data” 9 that IHS offers on its website.152 The number of new registrations in SDG&E’s territory in 2016 10 would be much smaller than the number total vehicle populations in SDG&E territory during that 11 year.

152 IHS Markit, Vehicle Market Analysis: Registrations and Vehicles-in-Operation, https://ihsmarkit.com/products/automotive-market-data-analysis html. 41

1 Q. For SDG&E to support the electrification of 3% of the Class 2–8 vehicles in its 2 service territory, how many vehicles would the Company need to support? 3 A. Based on the data in Table DN-4, there are about 1,117,395 Class 2–8 vehicles in 4 SDG&E’s territory. Therefore, a program designed to support 3% of the Class 2–8 vehicles in 5 SDG&E territory should support about 33,522 vehicles.

6 Q. For SDG&E to support the electrification of 3% of the medium- and heavy-duty 7 vehicles in its territory, how many vehicles would the Company need to support? 8 A. Medium-duty vehicles are Class 3 vehicles, while heavy-duty vehicles include vehicles in 9 Classes 4 through 8. Based on the data in Table DN-4, there are about 954,111 Class 3–8 10 vehicles in SDG&E’s territory. Therefore, a program designed to support 3% of the Class 3–8 11 vehicles in SDG&E territory should support about 28,623 vehicles. 12 Class 2 vehicles are light-duty vehicles under the U.S. Department of Energy’s (U.S. 13 DOE) system for vehicle classification. SDG&E confirmed in discovery that it uses the same 14 weight thresholds as the U.S. DOE to identify Class 1–8 vehicles.153 The Company explained 15 that its application focused on Classes 2 through 8 to support “vehicles used to support a wide 16 range of commercial and fleet purposes,” including a landscaper’s light truck that can be Class 17 2.154

18 Q. What do you conclude? 19 A. The CPUC has many options for modifying the scale of SDG&E’s proposed MD/HD 20 program to achieve state policy goals. Widespread electrification of MD/HD vehicles will help 21 alleviate the disproportionate pollution burdens in disadvantaged communities, where many 22 MD/HD vehicles operate in SDG&E territory.

153 SDG&E Response to ORA-SDG&E-DR-02, Q.9. 154 Id. 42

1 IV. HEALTH BENEFITS OF MEDIUM- AND HEAVY-DUTY VEHICLE 2 ELECTRIFICATION – PROFESSOR ED AVOL, UNIVERSITY OF 3 SOUTHERN CALIFORNIA

4 Q. Please introduce yourself. 5 A. My name is Ed Avol. I am a Professor of Clinical Preventive Medicine in and Acting 6 Director of the Environmental Health Division of the Department of Preventive Medicine at the 7 University of Southern California (USC). I have been a professor at USC for 26 ½ years. My 8 area of research is understanding airborne exposure and its impacts, especially the long-term 9 impacts of air pollution on children and other affected populations. I have published over 150 10 peer-reviewed articles in assorted professional journals, participated in or led numerous 11 competitive-grant research studies, lectured on these topics locally, nationally and 12 internationally, and participated (and continue to participate) as a member of several advisory 13 committees at other universities, regional commissions, and national committees. I was an 14 invited member of three previous United States Environmental Protection Agency (EPA) Clean 15 Air Scientific Advisory Committee Expert Panels that reviewed and made recommendations to 16 the EPA Administrator regarding the National Ambient Air Quality Standards (NAAQS) for 17 particulate matter, nitrogen oxides, sulfur oxides, and ozone. Among several achievements, I 18 was awarded the 2017 Mehlman Award from the International Society of Exposure Science for 19 helping to shape National or State policy with exposure analysis leading to a reduction or 20 prevention of human exposure. I have provided more information about my qualifications in 21 Attachment A. 22 I will provide a brief overview regarding some of the public and personal health and 23 exposure issues associated with current and future air quality in the San Diego region. The scope 24 of this discussion and my testimony will be purposely limited. A more complete discussion of 25 regional air quality might include multiple elements, such as: (1) a discussion of primary 26 emissions (sometimes called direct emissions, because they come directly from the mobile or 27 stationary sources); (2) a discussion of secondary pollution production (that is, pollution formed 28 in the exhaust system or atmosphere due to chemical reactions that create chemical compounds 29 in the air not originally emitted from specific sources); (3) a discussion of greenhouse gas 30 emissions. My testimony will focus on the first two items, primary and secondary pollution (and

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1 their associated chemical reaction by-products). The list of references cited in my testimony is 2 included in Attachment D. 3 I will comment on both the issues of exposure to pollutants associated with regional air 4 quality and health impacts of exposures to those pollutants and pollution by-products. 5 Understanding these issues is important because outdoor air pollution continues to affect the 6 health of millions of people in ways that impact their daily and long-term health, their quality of 7 life, and how long they live. Air pollution is a societal health and quality-of-life issue that we 8 can do something about, and there are reasonable and feasible alternatives available to reduce 9 pollution emissions. This is especially important in communities already stressed by socio- 10 economic and environmental issues that lead to disproportionately-impacted communities. As I 11 will discuss in my declaration, reducing pollution emissions can have real and substantial effects 12 on human health.

13 Q. Have you submitted testimony to the California Public Utilities Commission before? 14 A. Yes. I submitted testimony on behalf of Center for Community Action and 15 Environmental Justice and East Yard Communities for Environmental Justice in the consolidated 16 proceedings A.17-01-020, A.17-01-021, and A.17-01-022.

17 A. Air Pollution Summary

18 Q. Who is most at risk from exposure to air pollution? 19 A. Those most susceptible to exposure from air pollution have historically been identified as 20 the young, the old, the ill, and pregnant mothers (to protect fetal development). As our 21 understanding of exposure and risk has improved, other segments of the public have also been 22 identified as being at increased risk by virtue of their residential, activity, or work locations. 23 Those who live, work, or play near busy roadways have been shown to be at increased risk, due 24 to heightened exposures associated with close proximity to direct pollution emissions. Those 25 who regularly exercise near elevated exposure sources (for example, in recreational green spaces 26 near busy roads, on playing fields alongside freeways, or along roadways during times of traffic 27 congestion) have been shown to be at increased risk for a wide range of negative health effects. 28 Workers who spend extended periods of time outdoors, at high breathing rates (due to heavy 29 physical labor), are also considered to be at increased risk from air pollution. Additionally, there

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1 is a substantial segment of the population who may be genetically pre-disposed to air pollution 2 sensitivity by virtue of the presence or absence of certain inheritable traits (REF1). 3 Perhaps most significantly (because their options for reducing their personal exposure are 4 few), those who live in under-served or low-socio-economic-status (SES) or disadvantaged 5 communities (DACs) tend to be at increased risk. Often, these communities are close to or 6 interspersed with industrial, manufacturing, or mixed-use zoning activities that may lower 7 property values compared to other neighborhoods. Since financial resources in DACs are more 8 limited, DACs residents lack the potential for relocating or seeking substantive remediation if 9 something in the neighborhood is concerning to their health or welfare. They may lack political 10 power to contest questionable living or working conditions, and typically cannot afford legal 11 counsel or representation to challenge authority. For all these reasons DACs, which are often 12 communities of color, can be at increased risk for exposure to air pollution.

13 1. Ozone

14 Q. What is ground-level ozone? 15 A. Ground-level ozone is a clear and colorless gas present in the troposphere, which is the 16 lowest level of Earth’s atmosphere closest to where we live and breathe—hence the term 17 “ground level.” At the highest reaches of our atmosphere, ozone is very important as a filter to 18 protect the Earth from incoming ultra-violet radiation from the sun. In the troposphere and at 19 ground level, however, ozone is considered to be an air contaminant with substantial negative

20 health, vegetation, material, and aesthetic effects (REF2). Its chemical formula is O3, which 21 connotes the fact that an ozone molecule is made up of three oxygen atoms chemically bound 22 together. Ozone is one of six specifically identified air pollutants named under the United States 23 (U.S.) Clean Air Act, in which there are specified federal standards (National Ambient Air 24 Quality Standards, or “NAAQS”) established to protect the public health. Because the Clean Air 25 Act allows individual states to establish more restrictive standards if those respective states 26 believe that the scientific information warrants such a position, there is also a State of California 27 ozone air quality standard. The state ozone standard has historically differed somewhat from the 28 federal standards in effect at any given time. Historically, the California ozone standard has 29 often been more stringent than the federal standard.

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1 Q. How is ozone formed? 2 A. Ozone is formed through a complex series of chemical reactions in the atmosphere, 3 driven by the photochemical energy provided in sunlight through ultraviolet radiation. Ozone is a 4 secondary pollutant; it is not directly emitted from any tailpipe, smokestack, or power plant. It is 5 the result of chemical reactions that take place in the outdoor air during long days of intense 6 sunlight (primarily during daylight hours) between directly-emitted gases (primary pollutants) 7 from both anthropogenic (“man-made”) and naturally-occurring processes. Man-made emissions 8 of primary pollutants include direct emissions of nitrogen oxides from incomplete combustion 9 processes (such as vehicle exhaust), volatile organic compounds (also known as VOCs, from 10 carbon-containing gases and vapors such as fossil fuels and solvents), and carbon monoxide 11 (REF2). Naturally-occurring emissions sources include vegetation, burning biomass (forest or 12 wild fires), and lightning (REF2). 13 Incomplete combustion of fossil fuels (be it gasoline, diesel, natural gas, coal, or 14 biomass) results in airborne emissions. These include nitrogen oxides, VOCs, carbon monoxide, 15 and particles that are important in chemical reactions that lead to the formation of ozone. In 16 most urban areas, emissions associated with assorted combustion processes, especially vehicle 17 emissions, are of paramount importance in ambient photochemical ozone production. Ozone 18 levels tend to be higher away from busy roads and immediate sources of nitrogen oxides. This is 19 due to shifts in chemical reactions due to competition for certain chemical species present in 20 limited amounts in the atmosphere. 21 It is often the case that the highest observed ozone levels will be downwind of, rather 22 than in, large metropolitan areas (in other words, far away from primary nitrogen oxides 23 emissions). Meteorological and topological conditions (wind and temperature, as well as 24 mountains and valleys) help to shape the movement of gases and particles across regional areas. 25 Because of this, less-urbanized areas downwind of large cities can often be impacted by plumes 26 of pollution from upwind communities many miles away.

27 Q. What are the current state and federal ozone standards? 28 A. In California, there is currently both a one-hour and an eight-hour ozone standard. The 29 one-hour California Ambient Air Quality Standard for ozone is 0.09 parts per million (90 parts 30 per billion), measured by ultra-violet photometry (REF3). The eight-hour California Ambient 31 Air Quality Standard for ozone is 0.070 parts per million (70 parts per billion), measured by 46

1 ultra-violet photometry (REF3). At the national (NAAQS) level, the one-hour ozone level was 2 revoked in 1997 in favor of a more protective eight-hour standard (although regions are still 3 required to attain the standard). The eight-hour NAAQS for ozone is 0.070 parts per million (70 4 parts per billion), measured by ultra-violet photometry.

5 Q. What are the health consequences of ozone pollution? 6 A. As of June 19, 2018, there were over 3,480 peer-reviewed publications identified on a 7 PubMed web search of the health effects of ozone. PubMed is a computer search resource 8 developed and maintained by the National Center for Biotechnology Information at the National 9 Institutes of Health. 10 Under the federal Clean Air Act, the EPA is required to review the latest science and 11 information available regarding the NAAQS pollutants every five years and make a 12 determination as to whether the respective NAAQS for each pollutant is protective of the public 13 health with “an adequate margin of safety” (REF6). A summary table from the most recent 14 ozone review document is shown below (see Table EA-1). This table summarizes the health 15 consequences of ozone pollution, for both short-term (minutes, hours, days) exposure and long- 16 term (months, years) exposure. Short-term health effects have been documented for respiratory, 17 cardiovascular (heart-and-circulatory related), central nervous system (brain and motor function), 18 and total mortality (death). Long-term health effects have been documented for respiratory, 19 cardiovascular (heart-and-circulatory related), reproductive and developmental effects, central 20 nervous system (brain and motor function) effects, and total mortality (death). There has also 21 been some suggestion of an association between ozone exposure and lung cancer, but at this 22 point in time, the evidence for that relationship has been judged to be inadequate and in need of 23 additional research. 24 For each of these health endpoints, the EPA documentation provides some judgment 25 regarding the strength of evidence for a specific health outcome (REF2). A tabulation of the 26 criteria for the weight of evidence is provided below (see Table EA-2, from REF2). 27 Respiratory effects cover a wide range of outcomes, including increased airway 28 inflammation, airway hyper-responsiveness, lowered lung function, increased symptoms, 29 increased asthma medication usage, increased hospital admissions for asthma and chronic 30 obstructive pulmonary disease (COPD), the development of new disease (asthma), and death 31 (REF2). Cardiovascular outcomes include hypertension (high blood pressure), arrhythmias, 47

1 myocardial infarctions (heart attacks), and increased emergency room visits or hospital 2 admissions, and death (REF2). Central nervous system effects include effects on short-term and 3 long-term memory, sleep patterns, and behavior (REF2).

4 Table EA-1

5

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1 Table EA-2

2

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1 2. PM2.5

2 Q. What is fine particulate matter (PM2.5)? 3 A. Particulate matter can be thought of as being very small pieces of dirt or droplets floating 4 around in the air. Particles exist in a very wide range of sizes, from those barely visible (such as 5 grains of sand or wind-blown dust) to those on the sub-microscopic or molecular level. Fine 6 Particle Matter is the designation for particles with a nominal particle diameter of 2.5 microns

7 (two-and-a-half millionths of a meter) or less, herein referred to as PM2.5. This working 8 definition of an air pollutant by physical size is an acknowledgement that particles can come 9 from many different sources, be made of many different chemicals, and have different weight, 10 shape, surface roughness and area, as well as different toxicological properties.

11 Q. How is PM2.5 formed?

12 A. PM2.5 can be the result of either primary emissions (such as a direct release from a 13 tailpipe, smokestack, wind-blown field, spray can, or wildfire) or secondary processes (through 14 chemical reactions in the atmosphere, leading to new particle formation or particle growth from

15 very small particles – called ultra-fine particles – up into the PM2.5 size range). Direct emissions 16 come from either natural or man-made sources. Natural sources include wind-blown dust, sea- 17 spray aerosol, volcanic emissions, and vegetative burning. Man-made sources include vehicle 18 emissions, boiler operations, power-plant or industrial emissions, and any abrasion, grinding, or 19 frictional-force (like braking) operations (REF6). In the atmosphere, gases can also combine to 20 create small particles or can condense or react on pre-existing smaller particles that “grow” into 21 larger particles by accumulation of material (REF7). The sources present in a given region 22 (sources such as vehicle traffic, vegetation, and industrial operations), the gases present in the air 23 (gases such as nitrogen or sulfur oxides, oxygen, volatile organics, and solvents), the 24 meteorology of the area (including wind, heat, and atmospheric mixing) and the topology of the 25 region (such as bodies of water or open land, and tall mountains, deep canyons, or broad valleys) 26 all affect the extent to which particles can and will form, collect, or be trapped in a given 27 geographical location.

28 Q. What are the current state and federal PM2.5 standards?

29 A. The California ambient air quality standard and NAAQS for PM2.5 are based on the 30 arithmetic mean (or what we commonly describe as the “average” or mean value) of micrograms

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3 1 of PM2.5 per cubic meter of air matter (ug/m ). The annual arithmetic mean California ambient 3 2 air quality standard for PM2.5 is 20 ug/m , measured by gravimetric or beta attenuation methods

3 (REF3). There currently is no 24-hour average California ambient air quality standard for PM2 5. 4 Under the U.S. Clean Air Act, Primary Standards are those set with an adequate margin 5 of safety to protect the public health. Secondary Standards are those set to protect the public 6 welfare from adverse effects. Welfare effects under the Clean Air Act include effects on soils, 7 water, wildlife, vegetation, visibility, weather, climate, materials, economic values, and personal 3 8 comfort and well-being (REF3). The current 24-hour average NAAQS for PM2.5 is 35ug/m 9 (with both primary and secondary standards being the same) (REF3). The current annual 3 3 10 arithmetic mean NAAQS for PM2.5 is 12 ug/m for the primary NAAQS, and 15 ug/m for the 11 secondary NAAQS (REF3).

12 Q. What are the health consequences of exposure to PM2.5? 13 A. As of June 19, 2018, there were over 2500 peer-reviewed publications identified during a

14 PubMed web search on the topic of health effects of PM2.5.

15 A summary of the known science regarding the health effects of PM2.5 was provided in 16 the EPA Integrated Science Assessment for Particulate Matter, and this document was last 17 reported in December 2009. (An updated ISA for PM is currently in preparation in 2018 by 18 EPA.) At the time of the last NAAQS review for PM, a broad array of health consequences of 19 exposure was reported, including cardiovascular (heart and circulatory-system related),

20 respiratory, and death associated with short-term exposure to PM2 5 (REF6). Long-term 21 exposures were shown to be associated with cardiovascular, respiratory, mortality, 22 reproductive/developmental, and cancer/mutagenicity/genotoxicity endpoints (REF6). Since that 23 time, additional data has steadily become available, strengthening the concern for negative health

24 outcomes associated with short or long-term exposures to PM2.5. In 2013, the International 25 Agency for Research on Cancer listed outdoor air pollution, especially PM, as a human 26 carcinogen, based on the review of over 1,000 research articles. Subsequent research that 27 combined the results of several large population studies (REF8) or involved very large sample

28 sizes (over 60 million Americans, REF9) have reported that PM2.5 is associated with increased 29 cancer risk and death.

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1 3. Diesel Exhaust

2 Q. What is diesel exhaust? 3 A. Diesel exhaust is a combination of gases and particles that are produced during 4 incomplete combustion of diesel fuel. (It should be noted that all engine combustion processes 5 are less than 100% efficient, so any combustion process leads to incomplete combustion and 6 potential release of particles.) Most of the particles associated with diesel exhaust are 7 characteristically very small in diameter. More than 90% of diesel exhaust particles are less than 8 1 micron in diameter, or one-millionth of a meter (REF10), with most of these less than 0.1 9 micron, or one-tenth of one-millionth of a meter, in a size range known as ultra-fine particles. 10 The particles themselves are composed of a solid elemental carbon core, with the surface of the 11 particle coated with a number of organic carbon compounds and other chemicals and compounds 12 associated with diesel exhaust (REF10). The gases emitted in diesel exhaust include thousands 13 of different chemicals, and several air pollutants of health and regulatory concern. Some of these 14 include acetaldehyde, acrolein, benzene, 1,3-butadiene, formaldehyde, and an assortment of 15 gases collectively known as polycyclic aromatic hydrocarbons (PAHs) (REF11). 16 Diesel engines, by nature of their operation, also emit a substantial amount of carbon 17 monoxide and nitrogen oxides along with the other gases and particles (REF12). The reduction 18 of nitrogen oxides and particles emissions are especially challenging, as manufacturers seek to 19 optimize engine operating and vehicle performance conditions to minimize particle soot 20 formation (which occurs at lower engine combustion temperatures) and nitrogen oxides 21 production (which occurs at higher engine combustion chamber temperatures) (REF12).

22 Q. How is diesel exhaust formed? 23 A. Diesel exhaust is formed during and after the combustion process that takes place within 24 a functioning diesel engine. Diesels operate by mixing fuel and air in the combustion 25 compartment, and then compressing the mixture under high pressure. The high pressure leads to 26 high temperature, which causes the fuel mixture to spontaneously ignite. The chemical energy of 27 this explosion is then converted into mechanical energy, turning the engine and moving the 28 vehicle. However, there are many variables that affect this activity, including air-fuel ratio, 29 combustion chamber turbulence, air-fuel concentration, and combustion temperature, so 30 incomplete combustion occurs, and variations in diesel exhaust occur (REF13). The gases and

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1 particles are exhausted from the engine, and react with each other as well as with other gases and 2 particles in the air.

3 Q. What are the health consequences of exposure to diesel exhaust? 4 A. Diesel exhaust has been identified as a Toxic Air Contaminant by the State of California 5 (in 1998) and as a known human carcinogen by the International Agency for Research on Cancer 6 in 2012 (REF14,15). These determinations have been made on the basis of numerous published 7 health studies, especially those involving long-term occupational exposure in the railroad, 8 mining, and trucking industries.

9 Diesel particles are just one of the many kinds of particles present in PM2 5, so many of

10 the negative health outcomes associated with generic PM2.5 have also been ascribed to diesel 11 exhaust. Diesel exhaust in and of itself has also been identified with many health effects 12 (REF14). These include cardiovascular effects (arrhythmia, heart rate variability, blood pressure 13 changes, systemic inflammation, thrombosis, myocardial infarction, and death), respiratory 14 effects (pulmonary function, allergic responses), central nervous system effects, 15 reproductive/developmental/prenatal/neonatal outcomes, mutagenic and genotoxic effects 16 (REF6,14). 17 In addition to the particle component, several of the gases associated with diesel exhaust 18 (nitrogen oxides, PAHs, benzene, and 1,3 butadiene) have also been associated with negative 19 health outcomes. Nevertheless, the focus of health concern has generally been on the particle 20 phase, since diesel particles contain both a solid carbon core and adsorbed gases on its surface. 21 At the current time, there are no state or national air quality standards for diesel particulate 22 matter or diesel exhaust.

23 Q. How is diesel particulate matter (diesel PM) different from PM2.5?

24 A. Diesel PM is a subset of PM2.5. PM2.5 is a class of pollutants defined by their physical 25 size, and diesel PM is one of many types of PM pollution that falls within that physical size 26 category. However, diesel PM contains many known carcinogens and has been specifically

27 identified as a known human carcinogen. There are many other contributors to the PM2.5 28 category, such as fossil fuel combustion, fugitive dust from paved and unpaved roads and fields, 29 prescribed or inadvertent burning, mobile source exhaust from fuels other than diesel,

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1 bioaerosols (portions of pollen, plant and insect fragments), and secondary formation of particles 2 in the atmosphere through photochemistry (REF6).

3 4. Ultra-fine Particles

4 Q. What are ultrafine particles, and how are they formed? 5 A. Ultrafine particles are a special segment of the overall particle size spectrum and 6 comprise very small particles whose mean diameters are less than 0.1 micron (or one-tenth of 7 one-millionth of a meter). These particles are so small that they behave like gases, moving along 8 on the airstream. They are so small that they can stay suspended in air for long periods of time, 9 because they have very little mass and are not substantively affected by gravity. They are not 10 easily captured by general filter technologies in widespread use, and they have very large surface 11 areas for their relative size, making them important in ambient air photochemistry because they 12 provide lots of common space for chemicals to interact. Ultra-fine particles are considered to be 13 quite reactive, for example downwind of urban sources such as vehicle traffic on or near busy 14 roadways (REF16), or near the exhaust coming from refineries or smokestacks. Ultra-fine 15 particles can react with gasses in the air or with other particles, to “grow” into a larger size range,

16 becoming particles in the PM2.5 mode. They can vary quite dramatically from location to 17 location, and are often quite high in concentration close to their source, decreasing dramatically 18 in concentration within a few hundred meters. Ultra-fine particles are generally formed from 19 combustion processes (i.e., the burning of wood, biomass, or fossil fuels such as coal, gasoline, 20 or diesel oil), from condensation of gases, and as a result of ambient photochemistry (REF6,16).

21 Q. What are the health consequences of exposure to ultrafine particles? 22 A. The health consequences of exposure to ultrafine particles are an active area of research. 23 Their extremely small size and dynamic behavior makes ultra-fine particles both interesting to 24 study and potentially concerning. Because of their small size, they can cross the air-blood 25 barrier in the lung and enter the bloodstream. Once in the circulatory system, they can travel to 26 virtually any organ system in the body, and even find their way into cell mitochondria. There, 27 disruption of normal cell function can occur, leading to inflammation, up or down-regulation of 28 enzymes and endocrine function, and triggering a pathway of stress and functional changes in 29 cellular systems. Ultra-fine particles have also been documented to enter the body through the 30 nasal olfactory bulb, and travel to the brain, raising concerns regarding central nervous system

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1 and executive motor function processes (REF17,18). Ultrafine particles have also been linked to 2 negative cardiovascular health outcomes (REF6). At the current time, there are no state 3 standards or NAAQS for ultrafine particles.

4 5. Nitrogen Dioxide (NO2)

5 Q. What is Nitrogen Dioxide (NO2)?

6 A. Nitrogen dioxide (NO2) is a common air pollutant often associated with the incomplete 7 combustion of fossil fuels (coal, oil, gas, diesel).

8 Q. How is NO2 formed? 9 A. Whenever combustion takes place (for example, burning of wood for heating; use of 10 gasoline or diesel fuels in motor vehicles, locomotives, or ships for transportation or goods 11 movement; fossil fuels in power plants; industrial boilers for energy production), oxygen and 12 nitrogen combine at high temperature in a chemical reaction to form nitric oxide (NO), which

13 quickly reacts with additional oxygen to form nitrogen dioxide (NO2). With continued chemical 14 reaction and energy from sunlight (ultra-violet radiation), the nitrogen species can go on to form 15 other gases and particles (the particles constituting a group known as particulate nitrates, which

16 are a subset of PM2.5). Nitrogen oxides are important in terms of their own health impacts, but 17 they also are involved in chemical reactions leading to formation of ozone in the atmosphere.

18 Accordingly, knowing about the concentrations of NO2 in the air and effective reduction

19 strategies for ambient NO2 also helps to reduce some of the important precursors for ozone and 20 particulate matter formation in the atmosphere (REF1).

21 Q. What are the current state and federal NO2 standards? 22 A. The current California Ambient Air Quality Standard for nitrogen dioxide is in the form 23 of a one-hour and an annual arithmetic mean. The one-hour California standard is 0.18 parts per 24 million (equivalent to 180 parts per billion), measured by gas-phase chemiluminescence (REF3). 25 The annual arithmetic mean is 0.03 parts per million (equivalent to 30 parts per billion), 26 measured by gas-phase chemiluminescence. The federal primary standard is also in two forms, a 27 one-hour value of 100 parts per billion (which is the same as 0.100 parts per million), and an 28 arithmetic annual mean value of 0.053 parts per million, or 53 parts per billion.

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1 Q. What are the health consequences of NO2 pollution?

2 A. Exposure to NO2 has been shown to affect several organ systems and lead to a variety of 3 negative health outcomes. The evidence for respiratory effects is quite strong and the

4 relationship between NO2 and respiratory effects was determined to be “likely causal” in the 5 2016 review of the health literature under the Clean Air Act NAAQS process (REF1). Exposure

6 to NO2 has been linked to increases in risk of respiratory infections, symptoms, exacerbation of 7 asthma, and development of asthma (REF1). Lowered lung function performance among 8 children and increased risk for asthma exacerbation have also been repeatedly observed (REF1). 9 Although the mechanisms are not well-understood, there is evidence to suggest associations

10 between NO2 exposure and cardiovascular effects, including myocardial infarctions (heart 11 attacks) (REF1). Recent research also provides increasing evidence that NO2 exposures are 12 associated with diabetes (REF1, 19). There is some data to suggest that long-term exposures 13 could be associated with mortality and lung cancer, but these conclusions are complicated by co-

14 exposure with diesel exhaust which makes it difficult to attribute the effects observed to NO2 15 alone.

16 B. Air Quality in San Diego County

17 Q. You have described health-based state and federal standards for air quality. Does 18 the air quality in San Diego County meet these standards? 19 A. The air quality in San Diego County meets several of the State and National standards, 20 but fails to meet other key health-based air quality standards established to protect the public 21 health. Specifically, San Diego County has failed to meet health-based standards for ozone, 22 which is a photochemically-produced airborne pollutant (created in the atmosphere) most- 23 commonly present at elevated levels between May and October (the so-called “smog season”).

24 Q. How does the air quality in San Diego County compare to the ozone standard? 25 A. Air quality in San Diego County is designated as being in “non-attainment” for ozone by 26 the State of California (REF3). Non-attainment means that the regions in question do not meet 27 the state ambient air quality standard for the pollutant in question. Under the NAAQS, the San 28 Diego region is designated as being in “moderate non-attainment” for ozone (REF3, 4, 20). A 29 six-tier classification scheme (marginal, moderate, serious, severe15, severe17, extreme) is used

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1 by the EPA, with “extreme” being the most egregious (REF4). In the federal instance, attainment 2 is based on a comparison of the fourth-highest eight-hour concentration measured at each site 3 during the year and averaged over three years. A summary figure of the State Area designation 4 area is provided below, from the California Air Resources Board website (see Figure EA-1 5 below).

6 Q. How does the air quality in San Diego County compare to the PM2.5 standard?

7 A. Outdoor PM2.5 concentrations across the San Diego region have been designated as “in

8 attainment” with the NAAQS for PM2.5 (see Figure EA-2 below, which displays California area

9 designations for the PM2.5 national ambient air quality standard, REF20). Although measured

10 PM2.5 levels in the San Diego region are currently below designated California State PM2.5 11 ambient standards (REF3), data-capture threshold requirements (specifically, the requirement to 12 successfully capture at least 75% of the possible data in each complete month and three complete 13 months in each complete quarter of the year) have prevented the region from being officially

14 designated as in PM2.5 attainment (REF20).

15 Q. How does the air quality in San Diego County compare to the NO2 standard?

16 A. Air quality for NO2 in San Diego County has been determined to be in attainment with 17 both California state standards and federal NAAQS.

18 Q. Describe the major air pollution issues in San Diego County. 19 A. The major air pollution issues in San Diego County primarily revolve around continued 20 urban growth, sustained cargo goods movement through the region, and the proximity and 21 impositions these activities and their supporting infrastructures (such as highways, airports, 22 seaports, and international port-of-entry border crossings) create for the numerous 23 disproportionately-burdened communities in the county. The regional air quality agency 24 responsible for regulating and monitoring air quality in San Diego is the San Diego Air Pollution 25 Control District (SDAPCD). In terms of sources, emissions inventories conducted for and by the 26 SDAPCD suggest that major air pollution sources in San Diego County include pollution created 27 by emissions from motor vehicles, emissions associated with the use of heavy-duty diesel trucks 28 to transfer and move cargo and materials through and around the region, cross-border transport 29 of pollutants from Mexico, pollution associated with military operations at multiple bases in the

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1 region, and chemical reactions between these emissions and other molecules in the atmosphere 2 (often described as atmospheric photochemistry). I discuss emissions from military bases below, 3 in Section IV.C.

4 Figure EA-1

29

58

1 Figure EA-2

2

3 Chemical reactions in the air across the San Diego region lead to elevated ozone levels, placing 4 San Diego County in the designation of “non-attainment” with regard to compliance with both 5 State of California and US federal ambient air quality guidelines. According to monitoring data 6 provided by the San Diego Air Pollution Control District (SDAPCD), state and federal ozone 7 standards are periodically exceeded at two specific monitoring locations across the San Diego

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1 region - east of downtown San Diego along Interstate Highway 8 in and around Alpine, and 2 northeast of downtown up Interstate 15 by Escondido (REF20-22). 3 Based on ozone exceedances of the NAAQS, San Diego earned the dubious achievement 4 of being among the top cities in the country in violation of the ozone NAAQS, according to the 5 American Lung Association’s 2018 “State of the Air” report (see Table EA-3 below, from 6 REF24, listing the San Diego-Carlsbad metropolitan area sixth in the nation). A recent Quality 7 of Life assessment reported that unhealthy air days (based on air quality indices as recorded in 8 the EPA Air Quality Index report, which in San Diego primarily means ozone exceedances) 9 increased from 42 days in 2016 to 62 days in 2017 (see Figure EA-3 below, REF25). On these 10 days, EPA advises people belonging to the following sensitive groups to avoid prolonged or 11 heavy outdoor exertion: people with asthma and other lung diseases, children, older adults, and 12 people who are active outdoors. In addition, EPA advises that everyone else limit prolonged 13 outdoor exertion on unhealthy air days.

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1 Table EA-3: From the 2018 Lung Association “State of the Air”

2

3 Figure EA-3: Unhealthy Air Quality Days for San Diego County (2000-2017)

4

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1 Without changes in public policy, pollution from medium- and heavy-duty vehicles threatens to 2 increase in the San Diego region. Increased cargo movement, airport and seaport operations, 3 border crossing operations, and expanded regional bus access (for school, mass transportation, 4 tourism, and travel support at airport and train venues), will likely heighten health-based 5 concerns regarding diesel emission, unless alternative energy technologies are applied.

6 Q. Please describe the health consequences of exposure to air pollution in San Diego 7 County. 8 A. Outdoor air pollution levels periodically encountered across San Diego continue to have 9 substantial health impacts. These impacts affect respiratory, cardiovascular, neurological, 10 metabolic, and behavioral health outcomes, in both short-term (acute) reversible and longer-term 11 (chronic) domains) ways. Segments of the population at increased risk include identifiable sub- 12 groups across the entire life course (from pregnant mothers and developing fetuses, to infants, 13 children, adolescents, young adults, mature individuals, and elderly adults). In addition to life- 14 course considerations, those with pre-existing medical conditions, compromised health status, 15 outdoor working assignments, genetic pre-dispositions, or involvement in activities requiring 16 sustained levels of increased respiratory ventilation have also been shown to be at increased risk 17 (REF 1,2,6).

18 Q. How are these health burdens distributed in San Diego County? 19 A. Because there are both local and regional contributions to air pollution health effects 20 (REF26), the distribution of health burden associated with air pollution extends over a large area 21 of San Diego and is not uniformly distributed. 22 Local pollution concerns generally are dictated by proximity to a specific source, such as 23 a discrete industrial or commercial operation, or proximity to a line or area source. (The term 24 “line” source refers to a release of effluents along an extended and definable location, such as a 25 major roadway; the term “area” source refers to an emissions location comprised of possibly 26 many specific point and/or line sources, all operating within a defined discrete physical space, 27 such as a seaport, airport, manufacturing facility, or oil field.) Due to the high volume of heavy- 28 duty diesel truck traffic operating in and through San Diego County, many of the major freeways 29 and roads provide ample opportunities for near-roadway communities and neighborhoods to be 30 burdened by health impacts associated with vehicle emissions from those nearby major

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1 roadways. An additional source of local pollution is from residential wood burning, which can 2 occasionally create particle-related exposure issues of concern in the Escondido area of San 3 Diego (REF20). 4 Due to meteorological conditions, chemical reaction times, geographical/topological 5 considerations, and the movement of air masses over a region, elevated regional pollution peak 6 areas driven by atmospheric photochemistry tend to be located several miles inland. Two 7 monitored communities reporting exceedances of the ozone standards are (1) the Alpine/El 8 Cajon area east of downtown San Diego along Interstate Highway 8 (I-8), and (2) the Escondido 9 area, southeast of Oceanside off Interstate 15 (I-15). To improve air quality and health impacts 10 across the San Diego region, a focus on emissions reductions opportunities in the western (more 11 urban) portions of San Diego will be important.

12 Q. Describe the socioeconomic status of the communities that are bearing the burden of 13 air pollution in San Diego County. 14 A. Layered onto this physical dimension of proximity to local pollution sources is a socio- 15 economic one defined by multiple factors that combine to make certain neighborhoods and 16 communities more or less desirable locations in which to live and raise a family. These SES 17 factors include housing costs, school quality, degree of zoning for mixed industrial-residential- 18 commercial uses, access to food markets and restaurants offering fresh and/or healthy food 19 options, the presence of parks and recreational greenspace, perception of safety or violence 20 issues, local greenery, quality of street and infrastructure maintenance, general neighborhood 21 noise, and the amount of local street traffic. Due to the overlapping and inter-connected aspects 22 of some of these SES factors, less desirable communities of residence often are immediately 23 adjacent to or intentionally divided by major freeways, highways, or heavily-travelled road 24 corridors. These communities have been collectively described as “Environmental Justice” (EJ) 25 communities or DACs, and are often inhabited by populations of diverse color and culture with 26 substantially limited financial resources to voluntarily move out of or away from these impacted 27 geographical locations. 28 Using publicly-available databases and judgements about scoring approaches to 29 objectively compare these widely differing social and environmental variables, many of these 30 SES factors have been “quantified” and “mapped” to identify and rank areas of overlapping and 31 increased economic, social, and environmental disparities. The State of California Office of 63

1 Environmental Health Hazard Assessment (OEHHA) provides one such mapping tool, known as 2 “CalEnviroScreen” (REF27). As the website describes, “CalEnviroScreen is a screening tool 3 used to help identify communities disproportionately burdened by multiple sources of pollution 4 and with population characteristics that make them more sensitive to pollution.” Application of 5 CalEnviroScreen to the San Diego County region identified several EJ communities highly 6 impacted, as shown in Figures EA-4 and EA-5 below. A Google Map of the San Diego region 7 (Figure EA-4) is provided to orient the reader to geographical location of communities across 8 San Diego, followed by the CalEnviroScreen plot for the southern San Diego region (Figure EA- 9 5), where most of the EJ communities (denoted as DACs in the SDG&E testimony statements) 10 are located. (Additional DACs in San Diego County are located in more northern and eastern 11 parts of the county, in generally less urban locations, and are not discussed at this time.) The 12 orange and yellow hues on the CalEnviroScreen plot represent the most impacted communities, 13 as quantified in the figure legend. Disproportionately-burdened communities include Barrio 14 Logan, Logan Heights, and portions of Oceanside (not shown on expanded picture), Escondido 15 (not shown), Kearney Mesa (not shown), El Cajon, Lemon Grove, La Mesa, Chula Vista, 16 National City, San Ysidro, and Otay Mesa (REF27, and Figures EA-4 and EA-5 below).

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1 Figure EA-4: Map of Southern San Diego County

2

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1 Figure EA-5: Environmentally Impacted Communities of Southern San Diego 2 County

3 4 C. Health Impacts of Air Pollution Sources in San Diego County

5 Q. What are the primary sources of air pollution issues in San Diego County? 6 A. Based on SDAPCD staff interviews and the most recent district emissions inventory (for 7 2017), the majority of air pollution in San Diego County is from mobile source emissions 8 (REF20-22; see Table EA-4 below). “Mobile source emissions” includes cars, trucks,

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1 motorcycles, buses, aircraft, trains, ocean-going vessels, commercial harbor craft, recreational 2 boats and vehicles, off-road equipment, farm equipment, as well as fuel storage and handling. 3 The SDAPCD views heavy-duty diesel trucks as a potentially productive major focus for air 4 pollution reduction efforts, due to the high volume of cargo truck traffic passing in or through 5 San Diego and the potential for substantial emissions from the wide age range and emissions 6 maintenance status of heavy-duty diesel trucks in use (REF9, 23).

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1 T able EA-4

Emission Innntory of Ozone Precursors in San Diego CountJ and South Coast Air Basin, Combined for 2012 and 201 7 (tons per day)

~ '\JW!I c.l.!D ~ 2012 2017 2012 2017 J.."'fl••• ~.. - ::1r.1J:'6Y UGHT DUTY PASSENGER

3 Other large and identifiable sources of emissions in San Diego County include area source 4 contributions from San Diego International Airpo1i (Lindbergh Field) and the Po1i of San Diego. 5 A summaiy of emissions from the 2012 po1i emissions invento1y is summai·ized in Table EA-5 6 below (REF28).

68 1 Table EA-5: Emissions in San Diego County (tons per year) from the 2012 Maritime 2 Emissions inventory report, released from the Port of San Diego in June 2014. 3 Inventory emissions for on-road vehicle and locomotives estimated to include 4 “…entire trip length within San Diego County, whether the trips stopped within San 5 Diego County or further…” (REF28)

6

7 Q. What are the health risks of exposure to air pollution near roadways? 8 A. Studies of health impacts associated with proximity to freeways have reported a range of 9 detrimental effects on developing fetuses, including low birthweight (REF29), premature birth 10 (REF30), and increased risk of autism (REF31). Elevated levels of traffic-related emissions

11 (including PM2.5 and NO2) have been shown to affect children’s lung function performance,

12 respiratory symptoms, and asthma (REF26, 32-34). Near-roadway air pollution (including PM2.5 13 and elemental carbon, a key constituent of diesel exhaust) has been associated with increased 14 coronary heart disease and mortality across Southern California (REF35). Recently, a U.S.-wide 15 study of over 60 million Medicare beneficiaries demonstrated increased mortality associated

16 with increased ozone and PM2.5 exposures at concentrations below the current national and state 17 standards, especially among racial minorities and low-income populations (REF9). Another

18 study reported that long-term exposures to PM2.5 and NO2 were associated with decreased 19 cognitive function (reasoning, memory, learning, and language skills) (REF36). Therefore, for a 20 wide range of ages across the life spectrum and a broad array of negative health outcomes across 21 several target organ systems, there are negative consequences associated with exposure to air 22 pollution near busy roadways. 69

1 Q. Please describe the health risks of being a passenger on a diesel-fueled bus or living 2 near diesel bus traffic, and who bears those risks. 3 A. Several exposure studies in the last several years have considered the potential exposures 4 for passengers on buses. Monitoring data has revealed that passengers are exposed to elevated 5 levels of gases (including nitric oxides and polycyclic aromatic hydrocarbons [PAHs]) as well as 6 particles (including both very small [ultra-fine particles] and larger respirable particles) 7 associated with diesel exhaust in diesel-powered buses (REF37-39). The public health 8 implications of these measurements and studies are significant, given the added realizations that 9 (a) children (who are more sensitive to vehicle emissions exposure due to the developing and 10 immature status of their respiratory system) are a major population segment using school buses, 11 and (b) that a large proportion of the bus-riding public are low-to-middle-class socioeconomic- 12 status working-class people impacted by a number of other disproportionate environmental 13 issues that may make them susceptible to environmental exposures (REF6). Taken together, this 14 information raises concerns about environmental justice and environmental disparities as a 15 function of income, class, and color in and around communities where bus systems regularly 16 operate. 17 Adults are also at risk from diesel exposure. In addition to measurements onboard 18 operating buses over the past decade or two primarily focused on children and school-related 19 travel, a larger historical database relating diesel emissions to negative health outcomes exists 20 from train workers in the rail industry, miners in the mining industry, and truckers in the 21 commercial trucking industry (REF40-43). Dozens of studies involving thousands of workers 22 over decades of exposure under a variety of working conditions have linked repeated exposure to 23 diesel exhaust with a host of respiratory and cardiovascular health issues, including lung cancer 24 and chronic respiratory disease (REF44, 45). This substantial historical database provided the 25 factual basis for documented concerns about diesel emissions. 26 These cumulative studies led the State of California to identify diesel exhaust as a likely 27 human carcinogen in 1998 and the International Agency For Research on Cancer to declare 28 diesel as a known human carcinogen in 2012 (REF14, 15). The cumulative impacts of diesel 29 exposures have motivated the State of California and municipalities around the world to consider 30 and commit to transitioning from diesel buses to lower-polluting alternative fuel technologies 31 (REF14).

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1 Q. Please provide an assessment of the air pollution health impacts from operations at 2 the Port of San Diego. 3 A. The Port of San Diego operates over 34 miles of waterfront, covering 2403 acres of land 4 and 3535 acres of water (REF46). It includes nearly 800 businesses, two cargo terminals, and 5 two cruise terminals. Operations at the port include trucking and rail transfer of incoming cargo 6 (especially imported cars and bananas), largely through the use of diesel-powered equipment. 7 The California Air Resources Board Clean Trucks Program operates as a key element of the 8 port’s environmental control plan, but since access to several of the port’s key facilities is 9 through or by residential communities (several of which are identified in the CalEnviroScreen 10 plot previously shown), there is legitimate concern about assorted health impacts from port 11 operations. Vehicle emissions from trucks, and proximity to the emissions from those vehicles 12 as they pass through neighborhoods to access San Diego freeways and highways, are an ongoing 13 exposure concern. Noise associated with large vehicle movement through nearby communities 14 is also a significant neighborhood issue. Terminal operations, including in-yard movement of 15 materials and supplies, and offloading of bulk and containerized cargo, provide additional 16 emission sources. These vehicle emissions include both primary gases (such as oxides of 17 nitrogen and PAHs) as well as primary and secondary particles of varying sizes and composition 18 (including elemental carbon, ultra-fine particles, and respirable particles). As previously 19 described, both short-term and long-term exposures to these materials have been associated with 20 a wide range of negative health outcomes involving a number of organ systems (REF1,2,6).

21 Q. Please describe the communities that are bearing these health impacts from 22 operations at the Port of San Diego. 23 A. The Port of San Diego manages the San Diego Bay and waterfront (please see Figure 24 EA-4 above, which depicts the Port of San Diego operations area – essentially all of the gray 25 area touching San Diego Bay, between U.S. Interstate 5 (I-5) and California State Route 75 26 (SR75), located on the finger-like projection of land shown in the figure). Five member cities 27 (Chula Vista, Coronado, Imperial Beach, National City, and San Diego) are involved in various 28 port activities (see Figure EA-6 below). These include (1) direct terminal operations for loading 29 and unloading of cargo, (2) tourist, cruise, and ferry operations, and (3) commercial 30 redevelopment efforts to expand the economy and improve community recreational access to and 31 use of the waterfront (REF47). 71

1 Several adjacent and nearby communities are affected by Port activities, due to transport 2 of goods into and out of the Port terminals through these neighborhoods. A quick glance at 3 Figure EA-5 above, showing the CalEnviroScreen 3.0 assessment of highly-impacted 4 communities in the southern San Diego area, shows that virtually all of the communities adjacent 5 to the Port of San Diego operations are considered environmentally sensitive and 6 disproportionately impacted. Arguably most notable of these are the communities of Barrio 7 Logan and Logan Heights (Figure EA-7 below), which are the darkest red areas shown in the 8 CalEnviroScreen results shown in Figure EA-6, just south of downtown San Diego, by the 9 Coronado Bridge (SR75) connection. By the multiple criteria applied in CalEnviroScreen 10 evaluations, these communities are at extreme risk. They are low-socio-economic communities, 11 hemmed by a major roadway (I-5) carrying high volumes of motor vehicles. They are regularly 12 traversed by heavy-duty diesel trucks seeking access to and from the port terminals. They are in 13 the shadow of the Coronado Bridge (SR75), thereby subject to the deposition of particulates 14 associated with vehicle traffic overhead coming to and from Coronado (a substantive traffic 15 route, especially to support the North Island Air Station and Pacific Fleet military operations 16 described previously). Barrio Logan and Logan Heights are adjacent to terminal operations for 17 both the commercial ports of San Diego and the U.S. Navy. They are downwind of the Tenth 18 Avenue Marine Terminal operations and rank among the top 5% communities in 19 CalEnviroScreen statewide (REF48). These two communities are principally inhabited by 20 populations of color (>80% [Hispanic, Black, and Asian], according to the San Diego 21 Association of Governments [SANDAG] census data summary from the U.S. 2010 Census) 22 (REF49).

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1 Figure EA-6: Southern San Diego, from Downtown San Diego to Mexican Border 2 (~14 miles)

3

4 Q. Please provide an assessment of the air pollution health impacts from operations at 5 other large freight facilities like railyards and warehouses. 6 A. Large freight facilities such as railyards and warehouses can act as both sources and 7 effective “magnets” for pollution exposure, setting the stage for disproportionate air pollution 8 health impacts. Operations at these types of facilities include the use of diesel-powered 9 locomotives at railyards and diesel-powered trucks at railyards and warehouses. Therefore, 10 diesel emissions are a common occurrence at and near these facilities. In addition to being a 11 source of emissions through on-site operations, large freight facilities also effectively “attract” 12 emissions, by providing a central location for various mobile emissions sources (locomotives and 13 trucks) to congregate and concentrate. The specific exposures generated at these facilities 14 include many of the same exposures as those previously described above (exposures to primary 15 emissions of nitric oxides and PAHs, ultra-fine and respirable PM exposures).

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1 Q. Please describe the health risks that the California Air Resources Board found 2 related to the BNSF San Diego railyard. 3 A. In 2008, the California Air Resources Board released a health risk assessment of the 4 BNSF San Diego railyard (REF50). Health risk assessments (HRAs) involve collection of 5 available emissions inventory data for use in mathematical models to calculate potential health 6 impacts associated with emission from a given facility. Estimates of both cancer and non-cancer 7 health risks are made, based on the available data. These values are then used to provide some 8 judgement regarding potential health impacts for the general population in the surrounding area 9 of the facility. Interpretation of the provided data is based on several general assumptions, 10 including the idea that exposure to any given contaminant for adults will be in the form of a 11 continuous annual average concentration over a 70-year lifetime. By convention, exposures to 12 contaminants that result in predicted excess cancer developing at a rate of more than one chance 13 in a million are considered to be noteworthy and potentially actionable, with increasing concern 14 given as the calculated cancer risk increases in value. 15 Identified emission sources at the BNSF San Diego Railyard include locomotives, off- 16 road diesel-fueled equipment, on-road trucks, and transport refrigeration units (TRUs). 17 According to the report, 98% of facility total diesel emissions were assigned to locomotive 18 operations, with 88% of that value being associated with train arrivals and departures (REF50). 19 Although other known air toxics (such as benzene, formaldehyde, and 1,3 butadiene) were 20 identified in the site emissions, the relative importance of those cumulative emissions compared 21 to diesel emissions at the site were considered to be negligible. 22 The estimated cancer risk contribution for the BNSF San Diego facility (typically 23 represented by map plots of isopleths of decreasing risk) was calculated to be about 100 in a 24 million at the property boundary (REF50, see Figure EA-7 below)). The point of maximum 25 impact (PMI) was about 330 in a million, but no residents or people are in that theoretical 26 calculated location. The maximum individual cancer risk (MICR, the location at which actual 27 residents might be exposed to pollutant levels leading to the maximum risk) was calculated to be 28 about 70 in a million (REF50). 29 In their report, the State of California also estimated the size of the impacted area and the 30 population numbers involved, and those results are listed in Table EA-6 below. To put this into 31 perspective, the estimated regional cancer risk background for San Diego is about 600 in a

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1 million (REF50), so this single facility adds roughly ten percent or more to the total San Diego 2 cancer risk, on average.

3 Figure EA-7: Risk Isopleth for Near-Source Cancer Risk at BNSF San Diego 4 Railyard

5 6 Table EA-6

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1 Q. Please describe the communities that are bearing these health impacts from 2 operations at the BNSF railyard. 3 A. The BNSF San Diego Railyard is physically located on the northwestern edge of Barrio 4 Logan, one of the most disproportionately impacted communities in all of San Diego County. A 5 discussion of the surrounding communities bearing these disproportionate health impacts appears 6 above.

7 Q. Please describe the health impacts from goods movement related to the border 8 crossing between the United States and Mexico. 9 A. Goods movement related to the U.S.-Mexico border crossing involves vehicle emissions 10 at a few key sites in the San Diego region. Major border commerce crossings exist at San Ysidro 11 and Otay Mesa. According to the San Diego Association of Governments (SANDAG), Otay 12 Mesa is California’s largest port of entry with Mexico, with over 1,600,000 truck crossings 13 annually (REF51). There is some limited rail traffic (mostly trolley activity providing transit 14 services for people crossing the border), but the vast majority of traffic is on-road trucks. Due to 15 cross-border agreements allowing Mexican trucks to enter the U.S., there is a wide range of 16 engine ages, emission controls, and vehicle emissions associated with border crossings and U.S. 17 freight traffic. Health impacts from goods movement mirror those previously discussed with 18 regard to gas and particle emissions from on-road vehicles, especially diesel trucks.

19 Q. Please describe the communities that are bearing these health impacts from cross- 20 border goods movement. 21 A. Cross-border goods movement affects communities throughout the region, because the 22 cargo flows along and through freight corridors, freeways, railyards, rail lines, and warehouses 23 far beyond the actual physical border entry area. In San Diego County, the two primary border 24 crossing entry points are at San Ysidro and Otay Mesa. Both communities are highly Hispanic 25 (70-90%, based on the 2010 census), with a substantial number of residents (47% and 31%, 26 respectively) having less than a high school education. Poverty, English proficiency, primarily 27 service-sector jobs, and considerable traffic-related air pollution (due to high traffic volumes at 28 the border crossing ports of entry) round out the respective community profiles (REF51-54). As 29 the trucks and vehicle traffic extend beyond the immediate port of entry, emissions associated 30 with cargo goods movement become a contributing element of the regional pollution burden.

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1 Q. Please describe the health impacts from equipment operated at the San Diego 2 International Airport, and vehicles that move goods and people to and from the airport. 3 A. San Diego International Airport (Lindbergh Field) handles more than 160,000 aircraft 4 operations annually and is considered to be the busiest single-runway airport in the United States 5 (REF21). Emissions sources at the airport include aircraft engines, auxiliary power units 6 servicing aircraft, general ground support equipment, roadway/parking, construction activities, 7 and stationary sources (boilers, emergency diesel generators, fuel tank storage, and airfield 8 painting) (REF21). A summary of total airport emissions for the baseline modeling year (2012) 9 and for several growth-adjusted years into the future, is shown in Table EA-7:

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1 Table EA-7: San Diego International Airport Emissions (REF21, Attachment C)

2

3 The emissions values reported from the airport for 2017 in the above table are 4 substantially lower than the SDAPCD emission inventory data shown in Table EA-4. An 5 explanation of the difference in these emissions totals may have to do with the emissions 6 assignable to other aircraft in the San Diego region (including smaller commercial airports and 7 military operations). Regardless of the absolute emissions levels estimated by differing 8 inventories, both inventories indicate that San Diego International Airport is a significant source 9 of health-harming emissions. 10 The health impacts associated with these emissions have been previously described 11 above, with regard to both PM and gas-related exposures.

12 Q. Please describe the communities that are bearing the health impacts from these 13 airport-related vehicle operations. 14 A. San Diego International Airport (Lindbergh Field) is located on the edge of downtown 15 San Diego (see Figure EA-8 below). The typical approach pattern for daytime incoming flights 16 swoops in right over the Hillcrest and Balboa Park communities to the east. Recent research 17 have reported high numbers of ultra-fine particles depositing on communities in the landing 18 flight pattern approach immediately adjacent to airports (REF 55, 56). In addition, on-road 19 vehicle traffic associated with passenger pick-up and drop-off, as well as circulating shuttles and 20 buses to provide access and egress for flight crews, passengers, family, and workers, create 21 substantial sources of vehicle emissions. In the area surrounding Lindbergh Field, several of the

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1 immediate communities lie within the environmentally-burdened and elevated score components, 2 based on application of CalEnviroSccreen3.0 (see Figure EA-5 above). Therefore, mitigation 3 strategies that effectively reduce exposure burden in these affected communities are worthy of 4 consideration.

5 Figure EA-8: San Diego Area Surrounding San Diego International Airport 6 (Lindbergh Field)

7

8 Q. Please describe the health impacts from off-road, medium- and heavy-duty vehicles 9 used in military operations in San Diego County. 10 A. Another likely significant but currently unquantifiable air pollution issue in San Diego 11 County are emissions associated with multiple military base operations across the county. These 12 include Marine Corps Base Camp Pendleton (the prime amphibious training base on the West 13 Coast and home to the 1st Marine Expeditionary Force), Marine Corps Air Station Miramar 14 (home to the 3rd Marine Aircraft Wing, the aviation element of the 1st Marine Expeditionary 15 Force), Naval Base San Diego (the largest base on the West Coast and principal homeport of the 16 Pacific Fleet), and Naval Base Coronado (home to both the Naval Air Station North Island and 17 the Naval Amphibious Base Coronado; the Air Station is home to two aircraft carriers and 23 18 fixed and rotary-wing squadrons, while the Amphibious Base is the West Coast operations for

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1 SEAL teams and Special Boat Units, as well as the home to the U.S. Navy’s special and 2 expeditionary warfare training operations) (REF23). Although the physical presence of military 3 operations in San Diego County is substantial, security restrictions and federal exemptions 4 regarding emissions associated with operations-ready military equipment make access or use of 5 emissions information challenging to obtain and so was not included in this testimony. 6 However, given that (1) military operations are known to have some level of vehicle emissions 7 (including diesel) associated with operations, (2) that there are significant military operations in 8 San Diego County (especially in the downtown and surrounding areas with substantial numbers 9 of civilian residents), but that (3) documentation of the totality of military-related emissions does 10 not appear to be feasible, consideration for emissions reduction strategies in accessible civilian- 11 based categories should be identified in order to improve overall air quality and health in San 12 Diego. 13 Health impacts associated with emissions from military operations in San Diego County 14 would largely follow those described previously with regard to gaseous and particle-phase 15 pollution exposures. Actual assignment of specific quantities of emissions and source locations 16 are more challenging, given restrictions associated with details regarding military operations and 17 presumed issues of national security. Under California Air Resources Board actions, military 18 tactical vehicles are exempt from exhaust emission standards (REF21, Attachment D). 19 Nevertheless, SDG&E has confirmed in discovery that it provides electric service to 20 military facilities within its service territory, such as Naval Base Coronado and Naval Air Station 21 North Island, and that military customers are eligible to participate in its proposed medium- 22 duty/heavy-duty program.

23 D. Transportation Electrification

24 Q. How does transportation electrification relate to health outcomes? 25 A. Electrification of transportation across San Diego directly impacts health outcomes in 26 tangible and multiple ways. Most obviously, the replacement of fossil-fueled powered vehicles 27 with electric vehicles reduces the absolute exposure for those individuals in the local and 28 regional vicinity of the (formerly fossil-fueled-powered) emission sources. Reduction of those 29 emissions also reduces the photochemical potential and availability of primary pollutants to 30 participate in atmospheric chemical reactions that could lead to elevated levels of secondary

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1 pollution (pollutants such as ozone or certain particles composed of directly-emitted gases and 2 particles) many miles downwind of the emissions source. Conversion to electrification also 3 reduces exposures and emissions releases at fueling stations. 4 Electrification of transportation also represents a conscious policy statement for all those 5 who utilize the electrified modes of transport or see them pass through their neighborhoods, 6 which may promote healthy behaviors. This is because it can motivate spectators to think about 7 alternative options to fossil-fuels-based transportation and possibly accelerate the progression to 8 cleaner modes of transport and energy usage.

9 Q. Where in your assessment should transportation electrification be focused to 10 provide most health benefits? 11 A. In my opinion, the emphasis on transportation electrification should be in activities that 12 involve proximal exposure to susceptible populations and opportunities to leverage advantages 13 through transitional replacements. Children are an obvious sub-group at increased risk from 14 increased emissions. With all due haste, school bus fleets, public transit systems, and even 15 trash/refuse haulers who frequent neighborhoods and schools where large numbers of children 16 may be present would be substantive beneficiaries of electrification. Similarly, commercial 17 delivery vans and postal service vehicles would be likely targets for electrification. Transport 18 shuttles supporting airports, universities, and large public event venues (such as sports arenas, 19 border crossings, and theme parks) could also make substantive improvements in local air quality 20 by progressing as rapidly as possible to an all-electric fleet. Freight movement within defined 21 work areas (at port terminals, in company yards, within fence-line perimeters, on airport 22 property, and at border crossings) could all convert to electrification. Electrification of vehicle 23 operations in these areas, given the regional locations of the airport, seaport, border crossings, 24 schools, and recreational areas, would also achieve meaningful emissions reductions in several 25 San Diego census tracts currently identified as being at some of the highest environmental 26 burdens. Short-haul commercial trucking, for distances less than 100 miles, could readily 27 convert if and as vehicles are available that demonstrably conform to the needed work cycle.

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1 E. SDG&E’s Medium-Duty/Heavy-Duty Electric Vehicle (“MD/HD EV”) 2 Charging Infrastructure Program

3 Q. Have you reviewed SDG&E’s proposal for a MD/HD EV Charging Infrastructure 4 Program? 5 A. Yes, I have read the MD/HD EV Charging Infrastructure Program testimony offered by 6 Hannon J. Rasool on behalf of San Diego Gas and Electric Company (Chapter 2) before the 7 California Public Utilities Commission on January 22, 2018 (REF59).

8 Q. Will this proposal improve air quality and public health? 9 A. The proposed effort seeks to provide approximately 3,100 electric vehicles (and the 10 needed charging infrastructural support) in various operations categories (including buses, 11 forklifts, refrigeration units, and delivery trucks) to replace some of the estimated 103,000 12 commercial Class 2 through Class 8 vehicles (those weighing 6,001 pounds or more) operating 13 in the SDG&E service territory. SDG&E proposes to preferentially deploy these zero emissions 14 vehicles in areas of intensive public use (such as the San Diego International Airport, Otay Mesa 15 Port of Entry border crossing, and the San Diego Zoo) and in communities disproportionately 16 beset by substantial pollution impacts. SDG&E proposes identifying these DACs using the State 17 of California’s CalEnviroScreen screening tool. 18 On the microenvironmental level, these changes could have a measurable impact on 19 localized air pollution and possibly on perceptions about personal and public health (if not on 20 objective physiological measures of them). These transitions, from fossil-fuel-based operations 21 to electric, are important philosophical and policy actions to take and make, but in the immediate 22 near-term are unlikely to significantly change regional air quality or regional public health. This 23 is because the 3,100 vehicles under discussion and their related operations comprise only 3% of 24 the Class 2 through 8 vehicle fleet in San Diego and represent a small portion of the total 25 regional San Diego emissions inventory (REF49). Nevertheless, this proposal does begin an 26 important philosophical shift to move away from on-road vehicle combustion of fossil fuels 27 towards a cleaner and healthier electronic future. With some proposed modifications, this 28 proposal should be encouraged to move forward.

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1 Q. Explain who will benefit from the SDG&E proposal, and how. 2 A. Beneficiaries of the SDG&E proposal include a broad class of constituents. Specific 3 users (customers) of the electric vehicles deployed are likely to directly benefit through 4 decreased exposure to fossil fuel emissions, and possibly through psychological benefits 5 associated with acknowledging the environmental and personal health benefits of zero emissions 6 vehicles compared to those units being replaced. Operators (drivers and maintenance personnel) 7 are likely to benefit, through decreased exposure to fossil fuel emissions in the occupational 8 workplace, which could translate into improved worker health. Community residents and 9 passers-by may marginally benefit from the decrease in emissions compared to the previous 10 vehicles in use on the traffic routes employed, through decreased exposures and incremental 11 improvements in personal health. 12 The SDG&E proposal makes note of the potential impacts in DACs, through decreased 13 emissions and possibly the opportunity for employment if these vehicles are housed or 14 maintained in those identified DACs. However, there is little in the way of specific details in the 15 testimony provided with which to objectively evaluate these claims.

16 Q. Do you have specific recommendations on equipment that should be targeted 17 specifically for transportation electrification? 18 A. Emissions reductions both regionally and locally should translate into improved health 19 benefits for San Diego residents. To achieve that objective in an efficient and meaningful way, I 20 recommend the following:

21 1. A focus on replacement of heavier-duty older vehicles (i.e., vehicle classes with the 22 highest emissions). 23 2. A prioritized focus on exposure proximity – making fuel conversions and vehicle 24 replacements where such changes could proximally impact large numbers of people. 25 The California Public Utilities Commission should support rapid electrification in the 26 most heavily populated and impacted areas (such as in environmentally-burdened 27 communities) and/or in intensive areas of use (such as in public transport, airport 28 shuttles, or port-of-entry locations).

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1 Q. Do you have recommendations on targeting investments to those disproportionately 2 impacted by air pollution? 3 A. Targeting electrification investment to those disproportionately impacted by pollution is a 4 compelling one, but the specifics of precisely how SDG&E plans would do so are not clear in 5 this application. The SDG&E application raises this possibility but provides little detail as to 6 how this will actually be achieved. A program that is not carefully designed could lead to 7 unintended consequences. For instance, out-of-service-vehicle housing facilities in communities 8 could lead to increased, rather than decreased, emissions and exposures. This could occur 9 because additional conventional fossil-fuels-based vehicle traffic would be drawn into the area 10 by workers commuting to and from such facilities, and this increased directed traffic might offset 11 any net potential emissions decreases afforded by the facility. 12 The program could promote public-health benefits in DACs by prioritizing replacement 13 of heavy-duty vehicles currently in intensive use in and through these communities with electric 14 vehicles. Replacement vehicles could include: school bus fleets serving both public and private 15 schools, transit buses, refuse or trash-hauling trucks, and any other high-emitting commercial 16 and community service vehicles with intense operations in an overburdened community. The 17 freight-impacted communities of Barrio Logan and Logan Heights would benefit from 18 electrification of heavy-duty vehicles that are in intensive use at the Port of San Diego and the 19 BNSF railyard. 20 The focus on DACs raises the issue of objective identification of them. The SDG&E 21 proposal offers to apply the CalEnviroScreen screening tool approach to identify communities in 22 need, and this would certainly one useful approach. From the community 23 partnership/Environmental Justice perspective, one should note that direct input from the 24 communities themselves is another important means of information-gathering. Public comment 25 and input from environmental organizations, community service and social organizations, 26 neighborhood councils, and community governments would inform the remote screening tool 27 approach and potentially identify gaps in methodology for consideration in future screening tool 28 revisions.

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1 Q. SDG&E witness J.C. Martin discusses the net emission reductions from its MD/HD 2 EV Program. Did you review J.C. Martin’s testimony in this proceeding? 3 A. Yes, I have read the testimony offered by J.C. Martin on behalf of San Diego Gas and 4 Electric Company (Chapter 7) before the California Public Utilities Commission on January 22, 5 2018 (REF60).

6 Q. Is an analysis of net emission reductions adequate to understand the public health 7 impacts of the program? 8 A. As discussed above, any substantive emissions reductions achieved through this 9 electrification program would be welcomed and are needed to improve public health in general, 10 but the direct conversion of those reductions to discretely measurable public health 11 improvements in the San Diego service region would be more difficult to ascertain. 12 This is because the reduction calculations provided include “well-to-wheels” emissions (from 13 emissions associated with the generation of the needed power at the remote power plant to the 14 emissions of the vehicle on the street) (REF60). Accordingly, the emissions reductions are 15 spatially diluted, so benefits of emissions reductions at the power plant hundreds of miles away 16 may not be directly reflected by changes in health status of residents in San Diego. The 17 differential impact by vehicle class on net emissions appropriately identifies important 18 differences in annual and lifetime emissions reductions, but also raises the issue of emissions 19 reductions by spatial location. Regional air quality will improve in the context of absolute 20 reduction of pollutant emissions across the service area, but localized reductions, and their 21 interactions with localized direct health benefits, are not ascertainable with the available 22 information.

85

A.18-01-012

DIRECT TESTIMONY OF JAMES O’DEA ON BEHALF OF UNION OF CONCERNED SCIENTISTS AND DIRECT TESTIMONY OF DEB NIEMEIER AND ED AVOL ON BEHALF OF CENTER FOR COMMUNITY ACTION AND ENVIRONMENTAL JUSTICE AND EAST YARD COMMUNITIES FOR ENVIRONMENTAL JUSTICE

ATTACHMENT A A.18-01-012 Attachment A Page 1 of 6

Witness Qualifications of Dr. James R. O’Dea

My name is Dr. James R. O’Dea. My business address is 500 12th Street, Suite 340, Oakland, California 94607. I am currently a Senior Vehicles Analyst at the Union of Concerned Scientists (UCS), a national non-profit organization. I graduated magna cum laude with a Bachelors of Science in chemistry with Highest Honors from the University of Puget Sound. I earned a Ph.D. in chemistry at the University of California, Santa Barbara. I was then a postdoctoral research associate in chemistry at Cornell University. My undergraduate, graduate, and postdoctoral research focused on hydrogen fuel cells.

Before joining UCS, I was a Science and Engineering Congressional Fellow for US Senator Brian Schatz. My work at UCS focuses on clean vehicles, including technologies to reduce the emissions from medium- and heavy-duty vehicles. I have performed analysis regarding life cycle vehicle emissions and the availability of biomethane. I am also engaged in California policy conversations and decisions surrounding clean vehicles. I have previously testified before the Commission in SB 350. A.18-01-012 Attachment A Page 2 of 6

BIOGRAPHICAL SKETCH NAME: Avol, Edward L. POSITION TITLE: Professor EDUCATION/TRAINING DEGREE Completion (if Date FIELD OF STUDY INSTITUTION AND LOCATION applicable) MM/YYYY

University of California, San Diego, CA B.A. 06/73 Mathematics

California Institute of Technology M.S. 06/74 Environmental Engineering

A. Personal Statement My formal training and over 45 years in air quality research have provided me with the critical tools necessary to successfully guide our current and planned research center activities. My background in environmental engineering sciences, augmented by my job experiences in laboratory, project, and team leadership have positioned me with the guidance, oversight, and insights needed to effectively direct our NIEHS-funded environmental sciences center. I have been a member of our center since its inception, and I have actively participated in virtually every center core activity, including leading the integrative health science facility (IHSFC) and spatial exposure and analysis (SEAC) cores, being a participant in exposure assessment, administrative operations, pilot project review/selection/performance, and a leading or participating in a wide array of community engagement activities. I have served as the PI or co-PI on numerous competitive and funded projects from state, federal, non-profit, and private funding sources. I have led research teams of one to several dozen in size and of singular to multiple aims in scope. I have also served on several regional and national review panels, advisory boards, and study section project reviews. Through these invaluable participatory opportunities, I have observed effective and ineffective approaches, the importance of engaged oversight, and the delicate balance between technical skill directives and a larger directional vision for project goal attainment. I am confident that I can apply these developed skills for the betterment of our center operations and our research mission.

B. Positions and Honors Positions and Employment 1974-1976 Project Engineer, Rockwell International Air Monitoring Center, Newberry Park, CA 1976-1990 Research Associate, Senior Research Associate, and Director, Aerosol Chemistry Laboratory, Environmental Health Service, Rancho Los Amigos Medical Center, Downey, CA 1990-1992 Senior Project Manager, Engineering-Science, Inc., Berkeley, CA 1992 - Associate Professor and Professor, Department of Preventive Medicine, University of present Southern California, Los Angeles, CA July2018- Acting Director, Environmental Health Division, USC Department of Preventive Medicine present

Other Experience and Professional Membership Air and Waste Management Association (formerly Air Pollution Control Association) American Association for Aerosol Research (AAAR) International Society of Exposure Science (ISES) Member, Science Advisory Panel, Mickey Leland National Urban Air Toxics Research Center USEPA Clean Air Science Advisory Committee (CASAC) Review Panel, Primary Standards for NOx and SOx USEPA CASAC Review Panel, Primary Standards for Particulate Matter USEPA CASAC Review Panel, Primary Standards for Ozone Associate Editor, Journal of Exposure Science and Environmental Epidemiology (JESEE) (2011-2016) Ad-Hoc Member, IRAP, ONES, and Special Emphasis NIH Study Sections A.18-01-012 Attachment A Page 3 of 6 Member, Science Advisory Committee, Harvard University Clean Air Research Center (2009-2014) Member, External Advisory Committee, UC Berkeley Children’s Research Center (2015-present) Member, OEHHA Advisory Panel on Synthetic Turf Health Study (2016-present) Board of Directors, Harbor Community Benefits Foundation (2016-present)

C. Contribution to Science (with selections from over 150 peer-reviewed publications)

1. I am the Director of the Spatial Exposure and Analysis Core (SEAC) in the NIEHS-supported Southern California Environmental Health Sciences Center, Director of the Population Resources Core of the FDA-funded Tobacco Center of Regulatory Science (TCOR) at USC, and an advisor and mentor on several NIH and regionally-funded studies to assess the association of air pollution with children’s respiratory and cardiovascular health. 1. Gauderman WJ, Avol E, Gilliland F, Vora H, Thomas D, Berhane K, McConnell R, Künzli N, Lurmann F, Rappaport E, Margolia H, Bates D, Peters J. The effect of air pollution on lung function development in children aged 10 to 18 years. N Eng J Med 2004;351:1057-67. PMID: 15356303 2. Gilliland F, Avol E, Kinney P, Jerrett M, Dvonch T, Lurmann F, Buckley T, Breysse P, Keeler J, De Villiers T, McConnell R. Air pollution exposure assessment for epidemiologic studies of pregnant women and children: Lessons learned from the Centers for Children’s Environmental Health and Disease Prevention Research. Environ Health Perspect 2005; 113(10):1447-54. PMC1281294 3. Künzli N, Avol E, Wu J, Gauderman WJ, Rappaport E, Millstein J, Bennion J, McConnell R, Gilliland FD, Berhane K, Lurmann F, Winer A, Peters JM. Health effects of the 2003 southern California wildfire on children. Am J Respir Crit Care Med 2006; 174(11):1221–28. PMC2648104 4. Lurmann F, Avol E, Gilliland F. Emissions Reduction Policies and Recent Trends in Southern California’s Ambient Air Quality. J Air & Waste Management Assoc, 2015, 65:3, 324-335. PMID:25947128 5. Gauderman WJ, Urman R, Avol E, Berhane K, McConnell R, Rappaport E, Chang R, Lurmann F, Gilliland F. Association of Improved Air Quality with Lung Development in Children. N Engl J Med, 2015 Mar5:372(10):905-13. PMCID:PMC4430551 6. Berhane K, Chang C-C, McConnel R, Gauderman WJ, Avol E, Rappaport E, Urman R, Lurmann F, Gilliland F. Associatio93:543-552n of Changes in Air Quality with Bronchitic Symptoms in Children in California, 1993-2012. JAMA. 2016;315(14):1491-1501. Doi:10.1001/jama.2016.3444. 7. Tam E, Miike R, Labrenz S, Sutton AJ, Elias T, Davis J, Chen YL, Tantisira K, Dockery D, Avol E. Volcanic air pollution over the Island of Hawai'i: Emissions, dispersal, and composition. Association with respiratory symptoms and lung function in Hawai'i Island school children. Environ Int. 2016; 92- 93:543-552. doi: 10.1016/j.envint.2016.03.025. [Epub ahead of print]

2. I am actively involved in our NIH-funded centers' community outreach efforts, particularly with regard to the health and air quality impacts of the Los Angeles/Long Beach Port expansions. 1. Peters JM, Avol EL, Navidi W, London SJ, Gauderman WJ, Lurmann F, Linn W, Margolis H, Rappaport E, Gong H. Jr., Thomas D. A study of twelve Southern California communities with differing levels and types of air pollution. I. Prevalence of respiratory morbidity. Am J Respir Crit Care Med 1999; 159:760-7. PMID: 10051248 2. Avol EL, Gauderman WJ, Tan SM, London S, Peters JM. Respiratory effects of relocating to areas of differing air pollution levels. Am J Respir Crit Care Med 2001;164:2067-72. PMID:11739136 3. Künzli, N, McConnell R, Bates D, Bastain T, Hricko A, Lurmann F, Avol E, Gilliland F, Peters J. Breathless in Los Angeles: The exhausting search for clean air. Am J Public Health 2003; 93(9):1494-9. PMC1447999 4. Eiguren-Fernandez A, Miguel AH, Froines JR, Thurairatnam S, Avol EL. Seasonal and spatial variation of polycyclic aromatic hydrocarbons in vapor-phase and PM in southern California urban and rural communities. Aerosol Sci & Technol 2004; 38(5):447-55. A.18-01-012 Attachment A Page 4 of 6 5. Mueller-Anneling L, Avol E, Peters J, Thorne P. Ambient endotoxin concentrations in PM10 from southern California. Environ Health Perspect 2004; 112(5):583-8. PMC1241925 6. Fruin S, Urman R, Lurmann F, Gauderman J, Rappaport E, Franklin M, Gilliland FD, Shafer M, Gorski P, Avol E. Spatial Variation in Particulate Matter Components over a Large Urban Area. Atmos Environ, 2014 Feb1; 83:211-219. PMCID:PMC3932493

D. Research Supported Ongoing Research Support 5P50DA036106-04 (Samet, Pentz) 09/01/13–08/31/18 NIH/FDA USC Tobacco Center of Regulatory Science (TCORS) for Vulnerable Populations The USC Tobacco Center of Regulatory Science (TCORS) focuses on populations at high-risk for use of tobacco products and addiction in order to help the FDA reduce tobacco use and its disease burden. Addressing FDA priorities, researchers will examine social media and small retailers as ways that the tobacco industry reaches vulnerable populations, and how early smoking patterns predict tobacco product use and addiction. The TCORS will generate new research and training methods for regulatory science. Role: Core Director, TCORS Population Resources Core

2P30ES007048-21 (Gilliland) 04/1/97-03/31/21 National Institute of Environmental Health Sciences Environmental Exposures, Host Factors, and Human Disease Specific aims of project: To establish an Environmental Health Research Center whose main purposes are to study the effects of environmental exposure on humans and to determine host factors (genetic and other) influencing response to these exposures. Role: Core Director, Spatial Exposure and Analysis Core $5,012,607 total direct costs

1UG3OD023287-01 (Gilliland/Breton) 09/01/16 - 08/31/23 NIH Lifecourse Approach to Developmental Repercussions of Environmental Agents on Metabolic and Respiratory health (LA DREAMERs) The major goal of this proposal is to take a transgenerational life course approach to studying the contribution of the environment to the developmental origins of childhood and emerging adult respiratory and metabolic health. Role: Co-Investigator $3,849,686 total direct costs

1U2RTW010125-01 (Berhane/Kumie/Samet) 06/1/15-05/31/20 2/2 - GEOHealth Hub for Research and Training in eastern Africa - U.S This application proposes a progressive and tiered training program that will develop researchers and research teams able to carry out the research agenda of the Eastern Africa GEOHealth Hub and to facilitate the translation of the research findings into impactful actions by key stakeholders. Role: Co-Investigator

1R21ES027695-01 (Johnston) 07/01/16 - 06/30/18 NIH/NIEHS Health and Air Pollution Near Urban Oil Drilling Sites This project will take advantage of a natural experiment in South Los Angeles (the temporary shutdown of operations with a planned resumption of drilling activities) and provides a unique opportunity to objectively document the impact of urban oil drilling operations on the air quality and health of a community of color already stressed by issues of environmental injustice. Role: Advisor, Co-Investigator

A.18-01-012 Attachment A Page 5 of 6 Completed Research Support 4910-RFA11-1/12-4 (Gilliland, Avol) 05/01/12-07/31/14 Health Effects Institute (HEI) The Effects Policy-driven Air Quality Improvements on Children’s Respiratory Health This study directly addresses the overall objectives of the HEI Request for Applications by focusing on the health effects of regulatory actions taken to improve air quality in a previously-documented susceptible population (children). Role: co-PI

5P01ES011627-10 (Gilliland) 08/1/07-05/31/14 NIH/National Institute of Environmental Health Sciences Genetics, Air Pollution, and Respiratory Effects in Children and Young Adults This program project builds on the Children’s Health Study, an on-going cohort of 12,000 children, studying the health impacts of air pollution in Southern California schoolchildren. Role: Co-Investigator, Core Director, Integrative Health Sciences Facility Core

5R01ES014708-05 (Avol) 09/30/06-07/31/12 NIH/NIEHS Air Pollution, Intima-media Thickness, and Lung Function In College Students This project pursues the hypothesis that lifetime cumulative exposure to ambient air pollution is associated with sonographically measured carotid intima-media thickness (CIMT) in college students. Role: PI

5R01ES014447-04 (Avol) 05/1/06-02/28/12 NIH/NIEHS Air Pollution and Preclinical Atherosclerosis in Elementary School Children This project pursues the hypothesis that long-term exposure to local and regional air pollutants from outdoor origin promotes atherogenesis in early life, leading to differences in CIMT in 10-12 year old children. Role: PI

RD-83169701 (Kaufman) (Subcontract to Avol) 01/01/05-07/31/11 Environmental Protection Agency (EPA) Prospective Study of Atherosclerosis, Clinical Cardiovascular Disease, and Long-Term Exposure to Ambient Particulate Matter and Other Air Pollutants in a Multi-Ethnic Cohort ("MESA Air Pollution") Our participation in MESA Air is to provide exposure assessment support for the Los Angeles regional study of MESA subjects, as part of the national multi-center study. Community fixed-site, residential outdoor, residential indoor, and personal particle and gaseous samplers will be deployed to subjects recruited by UCLA clinical collaborators in a longitudinal study of cardiovascular disease progression. Role: Subcontract PI

5 R01 HL076647-05 (Gilliland) 08/15/05-06/30/11 NIH/National Heart, Lung, and Blood Institute Air Pollution, Inflammation, and New-Onset Asthma The project uses exhaled nitric oxide (eNO) to study the role of inflammation and oxidative/nitrosative stress in the pathobiology of new onset asthma, with a focus on air pollution and genetic susceptibility. Role: Co-Investigator

5P01ES009581-10 (NIEHS) / RD83186101 (EPA) (Gilliland) 05/07/04 – 10/31/08 National Institute of Environmental Health Sciences Environmental Protection Agency Children’s Environmental Health Center The goal of the Children's Environmental Health Center is to understand how host susceptibility and environmental exposure determine children’s respiratory disease. Role: Co-Investigator, Core co-Director

A.18-01-012 Attachment A Page 6 of 6

DEB NIEMEIER [email protected]

EDUCATION

Ph.D., University of Washington, Civil and Environmental Engineering, 1994. M.S., University of Maine, Civil and Environmental Engineering, 1991. B.S., University of Texas, Civil Engineering, 1982.

EXPERIENCE

Professor. Department of Civil and Environmental Engineering, University of California, Davis, 1994-Present Principal. Sustainable Systems Research, LLC, 2012-Present Recent Consulting. Natural Resources Defense Council, Review of Southern California International Gateway Project Recirculated Draft EIR, 2012 Natural Resources Defense Council, Coal Dust and Rail: Impacts of Coal Transport from the Powder River Basin, 2012 East Yard Communities for Environmental Justice and Natural Resources Defense Council, Review of the Transportation and Air Quality Analysis in the I-710 Draft EIR, 2012 Natural Resources Defense Council, Ports and Air Quality: Moving Toward Clean Cargo, 2012 TransForm, Looking Deeper: A detailed review of the project performance assessment being used to develop OneBayArea, 2011-2012 Resources Legacy Foundation, Complete Streets in California: Challenges and Opportunities, 2011 City of Davis, GHG Inventory, 2010 Transportation Project Manager. T.Y. Lin International, Falmouth, Maine, 1991-1994 Traffic Engineer. City of San Marcos, Texas, 1985-1987 Engineer. Texas Department of Highways, Austin, Texas, 1978-1987

PROFESSIONAL APPOINTMENTS

Editor-in-Chief, Sustainable Cities and Society, 2014-Present Editor-in-Chief, Transportation Research, Part A, 2007-2012 Editorial Advisory Board, Transportation Research, Part B, 2003-Present MARs Corp, Sustainable Science Board, 2009-Present National Academy of Science, Board on Energy and Environmental Systems, 2011-Present Fellow, AAAS, 2014 Guggenheim Fellow, 2015

SELECTED PUBLICATIONS (161 TOTAL)

Rouhani, O. G, Knittel, C., D. Niemeier (2014) Road supply in central London: Addition of an ignored social costs, Journal of Transportation Research Forum, 53(1):49-64. Rouhani, O., G D. Niemeier (2014) Resolving the property rights of transportation emissions through public- private partnerships, Journal of the Transportation Research, Part D, 31:48-60. Karner A., D. Niemeier (2013) Civil Rights Guidance and Equity Analysis Methods for Regional Transportation Plans: A Critical Review of Literature and Practice, Journal of Transport Geography,33:126-134 London, J., Karner, A., D. Rowan, D. Niemeier, J. Sze, G. Gambirazzio (2013) Racing Climate Change: Collaboration and Conflict in California's Global Climate Change Policy Arena, Global Environmental Change, 23(4):791-799 A.18-01-012

DIRECT TESTIMONY OF JAMES O’DEA ON BEHALF OF UNION OF CONCERNED SCIENTISTS AND DIRECT TESTIMONY OF DEB NIEMEIER AND ED AVOL ON BEHALF OF CENTER FOR COMMUNITY ACTION AND ENVIRONMENTAL JUSTICE AND EAST YARD COMMUNITIES FOR ENVIRONMENTAL JUSTICE

ATTACHMENT B A.18-01-012 Attachment B TURN DATA REQUEST Page 1 of 8 TURN-SDG&E-DR-01 SDG&E TRANSPORTATION ELECTRIFICATION MD/HD and V2G PROPOSALS (A.18-01-012) SDG&E RESPONSE DATE RECEIVED: January 30, 2018 DATE RESPONDED: 2/13/2018

Question 8: Has SDG&E conducted a cost-benefit analysis for its proposal? If yes, please provide the analysis and supporting workpapers. If no, please explain why not.

SDG&E Response: No, SDG&E did not conduct a cost-benefit analysis for its proposal. A cost-benefit analysis was not required by the Assigned Commissioner’s Ruling Regarding the Filing of the Transportation Electrification Applications Pursuant to Senate Bill 350 (September 2016). The Program is designed to support the goals of Senate Bill 350, encourage greenhouse gas reductions and accelerate transportation electrification.

Question 9: Please provide the expected incremental charging revenue for each class of vehicle (or like vehicles grouped together) for a ten-year period. Please provide a per vehicle estimate and total class estimate. Please provide all workpapers, calculations, assumptions, and sources.

SDG&E Response: SDG&E did not conduct this analysis in preparing the application and testimony. Incremental charging revenue will depend on vehicles adopted, size of battery, miles traveled per day and other factors.

Question 10: Please provide the annual cost reduction savings to the operator (host) due to reduced fuel, maintenance, and any other meaningful cost reductions by class of vehicle (or like vehicles grouped together). Please provide all workpapers, sources, and assumptions related to this response.

SDG&E Response: SDG&E has not calculated the annual cost reduction savings to the operator due to reduced fuel or maintenance costs.

Question 11: Chapter 2 testimony, page HJR-9, lines 5-6, state, “SDG&E’s program targets a small fraction of the population – approximately 3% of SDG&E service territory population.” a. Please provide all workpapers, sources, and an explanation of how this 3% target was arrived at. b. Please explain whether 3% of each class of vehicle was assumed or if it is of the total number of vehicles. Please provide all workpapers/calculations that support this response. c. Please provide the number of EVs by class currently in SDG&E’s territory, and/or whatever information is known to SDG&E regarding MD/HD and off-road EV adoption through 2017.

Page 4 of 6 A.18-01-012 Attachment B TURN DATA REQUEST Page 2 of 8 TURN-SDG&E-DR-01 SDG&E TRANSPORTATION ELECTRIFICATION MD/HD and V2G PROPOSALS (A.18-01-012) SDG&E RESPONSE DATE RECEIVED: January 30, 2018 DATE RESPONDED: 2/13/2018

SDG&E Response: a. Adoption curves show that the first 2.5% of technology adopters are “innovators.” They are followed by the next 13.5%, known as “early adopters.” SDG&E’s program size of 3% helps move the San Diego region market out of the innovators group into the early adopters group. b. 3% reflects the total number of vehicles targeted as part of the Program. It is not broken up by each class of vehicles. c. SDG&E does not have this information.

Question 12: Chapter 1 Testimony, page LPB-16, lines 9-10 state, “Additionally, SDG&E has vast knowledge and experience in administering programs and providing a positive customer experience.” Please explain and provide examples of the SDG&E programs referenced in this statement and provide any evidence demonstrating that they have resulted in a positive customer experience. Please share any other relevant documentation to support this response.

SDG&E Response:

One of the main areas where SDG&E provides a positive customer experience is through its Energy Efficiency programs. SDG&E is committed to energy efficiency and helping our customers manage their energy costs as their trusted energy advisor. Using the guiding principles of innovation, integration and comprehensiveness that SDG&E used in designing its program portfolio, SDG&E’s energy efficiency program portfolio achieved substantial annual energy savings. As stated in SDG&E’s Energy Efficiency Programs Annual Report 2016 Results, in 2016, SDG&E’s efforts resulted in savings of over 346 million kilowatt‐hours (kWh) and reduced energy demand by approximately 93 MW. In addition to helping customers save money and save energy, the energy efficiency programs helped reduce CO2 in support of the State’s goal of reducing greenhouse gas emissions.

SDG&E also continues to provide innovative and user‐friendly solutions to enable customers to take control of their energy use and reduce their bills. By signing up for My Account through SDG&E's website, customers can access the Energy Management Tool, which helps them manage their energy use by providing updates on how and where they use energy the most. Customers can conveniently access their consumption history via the Green Button process, and have the option to authorize a third party to review and analyze their energy use data through Green Button Connect My Data. In addition, SDG&E customers can borrow an in‐home display device from SDG&E at no cost to understand their home's energy use and identify high energy use appliances with near‐real time information and estimated energy costs. SDG&E’s Marketplace offers customers an easy way to review and purchase energy efficiency products. In 2016, SDG&E launched a new Marketplace feature that provides efficiency ratings to help customers make informed decisions.

Page 5 of 6 A.18-01-012 Attachment B TURN DATA REQUEST Page 3 of 8 TURN‐SDG&E‐DR‐01 SDG&E TRANSPORTATION ELECTRIFICATION MD/HD and V2G PROPOSALS (A.18‐01‐012) SDG&E RESPONSE DATE RECEIVED: February 13, 2018 DATE RESPONDED: February 27, 2018

Chapter 7:  MD-HD AQ Impacts (Final)  MD-HD-OffRd AQ Impacts (Final

Question 2: In SDG&E’s application, it states that, to minimize stranded assets, it will not deploy EV charging assets until the program participant commits to procure and operate EVs. How will SDG&E ensure the commitment of participants to procure and operate EVs?

SDG&E Response: Program participants will be required to provide proof that they intend to procure an electric vehicle. This will include such evidence as a purchase order or other legal form of commitment that the program participant is going to purchase or lease an electric vehicle as part of their operations. Regarding operation of the vehicle, as stated on HJR-15, lines 6 – 9, program participants are businesses who rely on their vehicles to keep their businesses running. Given that program participants will be making a significant investment in the vehicle, granting access to their property and paying the incremental cost above the EVSE allowance amount, it is unlikely that they would then abandon the assets.

Question 3: In SDG&E’s testimony, Ch. 2 HJR-20, SDG&E states that “The cost estimate was created using a given number of vehicles per vehicle class segment (e.g., Class 2-3, Class 4-5, etc).” Please explain the number of vehicles per vehicle weight class segment that SDG&E expected it would serve in developing its cost estimates for the MD/HD EV Charging Infrastructure Program.

SDG&E Response: For cost estimate purposes, SDG&E assumed the following electric vehicle supply equipment (EVSE) counts. Generally, a one for one ratio, EVSE to electric vehicle, is assumed. Note that actual uptake by vehicle class will be customer driven.

 Class 2 – 3: 1200  Class 4 – 5: 900  Class 6: 300  Class 7 – 8: 450  On-route transit chargers: 10  Forklifts and TRUs: 225 (capped)  3,085 EVSEs total for Program

Question 4: In SDG&E’s testimony, Ch. 2 HJR-9, SDG&E states that “The scope and size of the Program is based on the number of commercial vehicles in SDG&E’s service territory, fleet sizes

Page 2 of 4 A.18-01-012 Attachment B TURN DATA REQUEST Page 4 of 8 TURN‐SDG&E‐DR‐01 SDG&E TRANSPORTATION ELECTRIFICATION MD/HD and V2G PROPOSALS (A.18‐01‐012) SDG&E RESPONSE DATE RECEIVED: February 13, 2018 DATE RESPONDED: February 27, 2018

and California’s goals.” Please provide the analysis and workpapers that SDG&E used to determine the scope and size of its proposed MD/HD EV program.

SDG&E Response: Analysis included an examination of California’s goals such as those articulated in Senate Bill 350, Senate Bill 32, Executive Order B-32-15 and the California Sustainable Freight Action Plan. The last of which states: Transition to Zero Emission Technology Target - Deploy over 100,000 freight vehicles and equipment capable of zero emission operation and maximize near-zero emission freight vehicles and equipment powered by renewable energy by 2030.

Most recently, an executive order set more ambitious goals. Executive Order B-48-18 orders that all State entities work with the private sector and all appropriate levels of government to put at least 5 million zero-emission vehicles on California roads by 2030.

SDG&E used the state’s goals and the local commercial fleet population to determine the size of the program. SDG&E’s annual license for the IHS/Polk Data has expired. Under the license agreement, SDG&E was required to dispose of the source data at the expiration of the license. However, SDG&E was allowed to retain information derived from the source data.

IHS/Polk Data - Derived from Source Data

Commercial Vehicles in SDG&E Service Territory June 2016 Registrations

Class 1 49096 2 68068 3 6837 4 4825 5 4168 6 5176 7 2899 8 11142 TOTAL 152211

Class 2 - 8 103115

Question 5: In SDG&E’s testimony, Ch. 3 DMG-8, SDG&E states that it “will utilize a scheduling software platform to coordinate the scheduling of V2G operations with the CAISO.”

Page 3 of 4 A.18-01-012 Attachment B Page 5 of 8 ORA DATA REQUEST ORA-SDG&E-DR-02 SDG&E TRANSPORTATION ELECTRIFICATION MD/HD and V2G PROPOSALS (A.18-01- 012) SDG&E RESPONSE DATE RECEIVED: May 29, 2018 DATE RESPONDED: June 19, 2018

However, HVIP vouchers discount the cost of the electric vehicle (EV), rather than the cost of the electric vehicle supply equipment (EVSE) and related grid infrastructure.2

Response: HVIP reduces the upfront cost of the EV. For widespread transportation electrification to occur and to accelerate the adoption of EVs, electric vehicles and electric vehicle charging infrastructure must grow simultaneously. If they do not, you will continue to have “the chicken and the egg” problem which is often opined upon with regards to EV adoption. Electric vehicles and the infrastructure to support those vehicles are part and parcel of the same end goal of greenhouse gas reduction.

8. Please explain how incentive programs and funding sources targeting the EV rather than the EVSE and related grid infrastructure will have a beneficial impact on the MD/HD EV Charging Infrastructure Program. In your explanation, please focus on explaining how EV-targeting incentive programs and funding sources in general have beneficial impacts, rather than the beneficial impacts of HVIP in particular.

Response: Please see response to Q7.

9. The US Department of Energy has the following vehicle classifications:3

Gross Vehicle Weight Rating Vehicle GVWR (GVWR) (lbs) Class Category <6,000 1 6,001-10,000 2 10,001-14,000 3 14,000-16,000 4 16,001-19,500 5 19,501-26,000 6 26,001-33,000 7 >33,000 8

2 https://www.californiahvip.org/about/ 3 From https://www.afdc.energy.gov/data/10380 A.18-01-012 Attachment B Page 6 of 8 ORA DATA REQUEST ORA-SDG&E-DR-02 SDG&E TRANSPORTATION ELECTRIFICATION MD/HD and V2G PROPOSALS (A.18-01- 012) SDG&E RESPONSE DATE RECEIVED: May 29, 2018 DATE RESPONDED: June 19, 2018

Based on the above classifications, it appears that Class 2 vehicles are classified as light duty. However, SDG&E’s MD/HD EV Charging Infrastructure Program appears to target vehicles of all classes from 2-8. Please explain how SDG&E’s vehicle class categorization differs from the US Department of Energy. If SDG&E’s definition of Class 2 vehicles includes vehicles with a GVWR of 10,000 lbs or below, please explain SDG&E’s rationale for including such vehicles in its MD/HD program. Please provide the vehicle weights and axle numbers by which SDG&E defines Class 1, 2, 3, 4, 5, 6, 7, and 8 vehicles.

Response: SDG&E uses the same weight thresholds as the US DOE to identify Class 1 – 8.

The application focuses on Class 2 – 8 vehicles as described in Chapter 2 on page HJR-2. However, MD/HD was used generally to describe these vehicle classes. The intent is to support vehicles that are not generally driven by residential passenger vehicles such as Class 2 through Class 8 vehicles used to support a wide range of commercial and fleet purposes. For example, a light truck used by landscapers or maintenance vehicles can be Class 2. SDG&E’s MD/HD program would support those commercial applications by Class 2 vehicles. SDG&E used a definition that allows for broader participation by customers thus resulting in greater greenhouse gas reduction and reduction in tailpipe emissions.

10. In SDG&E’s testimony, Ch. 2 HJR – 16, SDG&E states that the program’s load management plans will efficiently integrate new load to the grid and generate “benefits to all ratepayers through grid optimization.” SDG&E further describes its load management plans in its response to Question 7 of ORA-SDG&E-DR-01, suggesting it could include “price signals through the electric rate selected, automation, physical acts such as unplugging vehicles and other strategies.” a. What electric rates is SDG&E including or considering for customers of this program? b. How will SDG&E leverage the networked capability of the EVSEs? c. In SDG&E’s testimony, Ch. 2 HJR – 20, SDG&E includes $15 million for transformer upgrades. What upgrades are eliminated by grid optimization and how does this compare to the $15 million in additional infrastructure needed to support the EVs?

Response: A.18-01-012 Attachment B Page 7 of 8 EYCEJ/CCAEJ DATA REQUEST EYCEJCCAEJ-SDG&E-DR-01 SDG&E TRANSPORTATION ELECTRIFICATION MD/HD and V2G PROPOSALS (A.18-01- 012) SDG&E RESPONSE DATE RECEIVED: June 26, 2018 DATE RESPONDED: July 10, 2018

c. How many transit buses operate in SDG&E’s service territory? How many of these buses serve DACs? What portion of transit buses operating in SDG&E’s service territory serve DACs? d. How many school buses operate in SDG&E’s service territory? How many of these buses serve DACs? What portion of school buses operating in SDG&E’s service territory serve DACs? e. Which transit agencies and/or school districts have communicated an interest to SDG&E about participating in a medium- and heavy-duty EV charging infrastructure program or sent inquiries to SDG&E related to charging infrastructure for electric buses? f. Which transit agencies and/or school districts has SDG&E directly contacted with information or inquiries regarding medium- and heavy-duty EV charging infrastructure.

SDG&E Response: a. The program cost estimate assumed an uptake of 450 vehicles in Class 7-8. It is expected that a large portion could potentially be electric transit buses due to the state of the technology and California efforts to transition to zero-emission buses. It is unknown how many of the buses will be housed in or travel through a DAC although the overall program target is 40% DACs. b. The program cost estimate assumed an uptake of 450 vehicles in Class 7-8. It is expected that a portion could potentially be electric school buses. It is expected that the uptake in electric school buses will lag behind transit due to the limited budget of school districts. It is unknown how many of the buses will be housed in or travel through a DAC although the overall program target is 40% DACs. c. According to MTS’s April 2015 fact sheet (https://www.sdmts.com/sites/default/files/attachments/BusOp FactSheet.pdf), MTS operates approximately 800 buses (includes paratransit buses). According to NCTD’s 2017 fact sheet(http://www.gonctd.com/wp-content/uploads/2017/08/NCTD-Fact-Sheets-Updated-2017- Final.pdf), NCTD operates approximately 160 buses. SDG&E does not know how many of the buses and routes serve DACs on a given day. d. SDG&E does not have a comprehensive count of the total number of school buses that operate in SDG&E’s service territory. e. The two transit agencies in SDG&E’s service territory have requested assistance from SDG&E to support their transition to electric buses. In addition, SDG&E has had discussions with other entities that utilize transit size buses including universities, the airport and others. SDG&E has engaged dozens of school districts through the K-12 Collaborative, which is a standing meeting that brings together school districts in the territory. Numerous schools have expressed interest in electric school buses. f. Please see response 10.e.

11. Please confirm that SDG&E provides electrical service to military facilities within its service territory, including Naval Base Coronado, Naval Air Station North Island, and Marine Corps Air A.18-01-012 Attachment B Page 8 of 8 EYCEJ/CCAEJ DATA REQUEST EYCEJCCAEJ-SDG&E-DR-01 SDG&E TRANSPORTATION ELECTRIFICATION MD/HD and V2G PROPOSALS (A.18-01- 012) SDG&E RESPONSE DATE RECEIVED: June 26, 2018 DATE RESPONDED: July 10, 2018

Station Miramar. Please identify each such military facilities that SDG&E serves. Please confirm that SDG&E’s military customers are eligible to participate in the Company’s proposed MD/HD EV Program.

SDG&E Response: Yes, SDG&E provides electric service to military facilities within its service territory including Naval Base Coronado, Naval Air Station North Island and Marine Corps Air Station Miramar in addition to Marine Corps Base Camp Pendleton, Naval Base Point Loma, Naval Base San Diego, Marine Corps Recruit Depot, etc. Military customers are eligible to participate in the MD/HD program. A.18-01-012

DIRECT TESTIMONY OF JAMES O’DEA ON BEHALF OF UNION OF CONCERNED SCIENTISTS AND DIRECT TESTIMONY OF DEB NIEMEIER AND ED AVOL ON BEHALF OF CENTER FOR COMMUNITY ACTION AND ENVIRONMENTAL JUSTICE AND EAST YARD COMMUNITIES FOR ENVIRONMENTAL JUSTICE

ATTACHMENT C A.18-01-012 Attachment C Page 1 of 2

MAP DETAILS 1. Data sources:

We deployed the following data sources to create each of the maps.

SDG&E service area boundary:

- GIS data from the California Energy Commission: http://www.energy.ca.gov/maps/serviceareas/Electric Utility Service Areas.html

Census data (tract level)

Population living in poverty

- C17002: At or below 0.99 ratio of income to poverty level in the last 12 months - Number of people - 5 year ACS 2016

Limited english households

- C16002: Called "Linguistic Isolation" in previous datasets. No one age 14 and over speaks English "very well" or speaks English only. Basically everyone over 14 has at least some trouble with English. - Number of households - 5 year ACS 2016

People of color

- P0050003: Not Hispanic or Latino – White alone - Number of people - 2010 Decennial Census (SF1)

All census data are at tract level. The maps cover Orange County (FIPS 059) and San Diego County (FIPS 073) and Riverside county (FIPS 065), which overlap the service area.

ROI data (tract level)

- 2014 version from: https://interact.regionalchange.ucdavis.edu/roi/index.html

CalEnviroScreen data (tract level)

- Version 3.0 (2018 update): https://oehha.ca.gov/calenviroscreen/maps-data

SB535 disadvantaged communities (tract level)

- Obtained from CalEnviroScreen data above. 2. Criteria used to define disadvantaged communities (DC):

SB 535 DCs were also used to define the share of the population in the SDG&E Service area that is a DC under SB535 (12.9%). We use that population share as a target when setting criteria for the other datasets as described below. A.18-01-012 Attachment C Page 2 of 2

For Census data – We first estimated the percent of the population in each tract living in poverty (as a percent of the population for which poverty has been determined), the percent of households that are limited english households (as a percent of households for which limited english status has been determined), and finally, the percent of the population that are people of color (as a percent of the population for which that was determined). We then convert the % poverty, % limited english, and % people of color to a population weighted z-score (weighting by the 2016 ACS population estimate for each tract). We average the three z-scores to get an index of demographic disadvantage and then identify the most disadvantaged tracts (highest average z scores), using a threshold to capture around 12.9% of the population.

For CRC data – we first average the “people” and “place” z scores provided in the ROI. We then identify the tracts with the least opportunity / most disadvantage (lowest average z score), setting a threshold to capture around 12.9% of the population.

For CalEnviroScreen data – we use the CES Percentile scores provided in the CES dataset. We identify the tracts with the highest CES scores (representing the most disadvantage), using a threshold to capture around 12.9% of the population.

The threshold used in these analyses is a standardly applied threshold.

A.18-01-012

DIRECT TESTIMONY OF JAMES O’DEA ON BEHALF OF UNION OF CONCERNED SCIENTISTS AND DIRECT TESTIMONY OF DEB NIEMEIER AND ED AVOL ON BEHALF OF CENTER FOR COMMUNITY ACTION AND ENVIRONMENTAL JUSTICE AND EAST YARD COMMUNITIES FOR ENVIRONMENTAL JUSTICE

ATTACHMENT D A.18-01-012 Attachment D Page 1 of 8

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