May 3, 2021
Dear Climate Action Council Member,
On behalf of the Clean Fuels NY Coalition, the signatories listed below respectfully ask you to include a Clean Fuel Standard (CFS), also known as a Low Carbon Fuel Standard, in the list of policy tools recommended to be included in the Climate Action Plan to meet the Climate Leadership and Community Protection Act’s (CLCPA) emission reduction requirements as they relate to transportation.
A CFS is a technology-neutral, performance-based standard that requires fuel manufacturers and importers to reduce the carbon intensity of their fuels by a set amount, which in New York could be scaled to an aggressive enough target to help achieve the CLCPA’s statutory requirements. California and Oregon’s CFS has successfully reduced transportation emissions at negligible cost to consumers and no cost to the State government other than administering the program. In 2019 alone, the California CFS resulted in the reduction of 2.5 billion gallons of fossil fuels with 20 percent of the credits awarded to the electric sector despite accounting for a small share of transportation fuels.[1]
Transportation is the number one source of greenhouse gas (GHG) emissions in New York. Achieving the CLCPA mandate of reducing GHG emissions by 85% by 2050 will require eliminating almost all transportation emissions. Indeed, the pathways analysis presented to the Climate Action Council and Transportation Advisory Panel indicates that we must reduce transportation emissions by 31-33% by 2030 and 86-97% by 2050 in order to comply with the CLCPA. If we are to meet this target, we must begin reducing transportation emissions as soon as possible. However, it seems unlikely given the COVID-19 recession that the State will be able to allocate much, if any, new funding for clean transportation in the near term; even with the funding made available to the state pursuant to the American Recovery Act, the recent state budget included only $20 million for electrifying mass transit bus fleets and $3 million for municipal EVs and EVSE – nowhere near the investment needed to move the needle on cleaning New York’s transportation sector. A CFS can accelerate the transition off fossil fuels and ensure that we remain on track even without new budgetary programs. Based on the value of credits in California and fuel use in New York, we project the CFS would generate $1-$1.4 billion annually for clean transportation, paid for by fossil fuel providers.[2]
The New York CFS, modeled on current legislation sponsored by Assemblywoman Carrie Woerner and Senator Kevin Parker (A. 862-A/S. 2952-A), would require manufacturers and importers of high-carbon intensity fuels like fossil gasoline and diesel to either reduce the carbon intensity of their fuels or purchase credits from low-carbon intensity fuel manufacturers and importers, such as operators of electric bus fleets like public transit agencies. The CFS provides meaningful support, paid by polluters, for public transit agencies, school busses, delivery vans, and for-hire vehicle fleet operators to switch to electric vehicles.
We expect electrification to be the primary beneficiary of a CFS, especially as the cap on carbon intensity is ratcheted down over time and as the grid gets greener. However, technology is not currently available or cost-prohibitive for the widespread transition of medium- and heavy-duty fleets, such as sanitation trucks and tractor-trailers, to electric engines. The elegance of a CFS as a performance-based standard is that it would still produce immediate and significant emission and air pollution reductions from these vehicles by providing them with an incentive to switch to renewable alternatives that can be readily dropped into existing engines to replace harmful fossil fuels. As the CFS carbon intensity cap is lowered over the duration of the program, these vehicle types would be provided with an economic incentive to switch to fully zero emission ahead of CLCPA mandates that they do so.
A Clean Fuel Standard would reduce transportation emissions by at least 20% over the next decade at no cost to the State of New York. This would mean significant progress toward meeting our obligations under the CLCPA, helping mass transit agencies across the state switch 100% of their bus fleets to zero emission by 2040, and reducing air pollution. This is an ambitious but achievable program that will reduce emissions, improve air quality, and create new jobs at no cost to the State.
Thank you,
Julie Tighe
President
New York League of Conservation Voters
Ryan Gallentine
Policy Director, Electrifying Transportation
Advanced Energy Economy
Dan Bowerson
Senior Director, Energy & Environment
Alliance for Automotive Innovation
Anne Reynolds
Executive Director
Alliance for Clean Energy New York
Heidi Sickler
Director of Policy
AMPLY Power
Richard DiGia
President & CEO
Aria Energy
W. Spencer Reeder
Director, Government Affairs & Sustainability
Audi of America
John Hroncich
Regional Sales Manager
BAE Systems
Martin Ryan
President
BerQ RNG USA, Inc.
Peter Ettinger
Chief Development Officer
Bioenergy Devco
Gene Harrington
Director, State Government Affairs, Food & Agriculture
Biotechnology Innovation Organization
Frank Girardot
Sr. Director Communications
BYD
Eileen Wenger Tutt
Executive Director
California Electric Transportation Coalition
Benjamin Mandel
Northeast Regional Director
CALSTART
Rob Niven
CEO
CarbonCure
Kevin George Miller
Director, Public Policy
ChargePoint
Barry Carr
Executive Director
Clean Communities of CNY
Brett Barry
Senior Policy Advisor
Clean Energy
Dan Goldman
Managing Director
Clean Energy Ventures
BJ Johnson
CEO
ClearFlame Engine Technologies
Sam Wade
Director, State Regulatory Affairs
Coalition for Renewable Natural Gas
Shelby Neal
Vice President - Renewables and Energy Policy
Darling Ingredients
Eric Cerretani
Environmental Specialist
Disney Television Studios
Uchenna Bright
Northeast Advocate
E2 (Environmental Entrepreneurs)
Andrew E. Dick
State Government Affairs Manager
Electrify America, LLC
Angela Schwarz
Co-President and Chief Executive Officer
Element Markets
Joy Gardner
Executive Director
Empire Clean Cities
John K. Bartow, Jr.
Executive Director
Empire State Forest Products Association
Joel Harrington
Director of Public Policy & Institutional Affairs - Eastern U.S. Region
Enel X North America
Matthew P. Tomich
President
Energy Vision
Patrick Macdonald-King
Chief Operations Officer
EV Connect, Inc.
Carine Dumit
Director, Market Development & Public Policy
EVgo
Peter Olmsted
Director of Regulatory Affairs
FreeWire Technologies
Chris Grimaldi Regional
Director, State Government Relations
General Motors
John Dannon
Principal
Generate Capital
Erik Neandross
Chief Executive Officer
Gladstein, Neandross & Associates (GNA)
Graham Noyes
Executive Director
Low Carbon Fuels Coalition
Daniel Witt
Head of Public Policy
Lucid Motors
Sam Arons
Director, Sustainability
Lyft, Inc.
Paul Greene
Director of Projects
Montrose Environmental
Floyd V. Vergara
Director of State Governmental Affairs
National Biodiesel Board
Dr. Jack Brouwer
Director
National Fuel Cell Research Center
Echo Cartwright
Director Climate Mitigation
Nature Conservancy NY
Dayne Delahoussaye
Senior Advisor Public Affairs
Neste
Colleen Klein
Executive Director
New York Corn & Soybean Growers Association
Elizabeth Wolters
Deputy Director of Public Policy
New York Farm Bureau
Daniel J. Gage
President
NGVAmerica
Steve Ripp
COO/CFO
NIC Holding Corp.
Alana Langdon
Senior Manager, External Affairs and Public Policy
Nikola Corporation
Christopher Noble
Manager
Noblehurst Green Energy
John Dickinson
Chair
Northeast Dairy Producers Association
Gene M. Bernstein
Chairman
Northville Industries
Luke Tonachel
Director, Clean Vehicles and Fuels Group
NRDC (Natural Resources Defense Council)
Christopher Neidl
Advocacy Director
OpenAir
Jonathan T Patterson
Owner
Patterson Farms Inc
Gerry Conway
General counsel
Plug Power Inc
Scott Hedderich
Exec Dir. Corporate Affairs
Renewable Energy Group
Geoff Cooper
President & CEO
Renewable Fuels Association
Chris Nevers
Senior Director, Environmental Policy
Rivian
Chelsea Jenkins
VP of Government Affairs and Industry
ROUSH CleanTech
Randy Delbert Letang
President and CEO
S.G. Preston Company
Doug Young
Owner
Spruce Haven Farms
Evan Rosenberg
Senior Manager, Client Development & Policy
SRECTrade
Katrina M. Fritz
Executive Director
Stationary Fuel Cell Collaborative
Zachary Kahn
Senior Policy Advisor, Northeast
Tesla
Orville Thomas
Director of Government Relations
The Lion Electric Company
Ryan Lamberg
Principal
Tied Branch Consulting
Andrew Miller
Director of Project Finance
Velocys Inc.
Scott Mercer
Founder & CEO
Volta Charging
Nicole Barranco
Sr. Director Government Relations
Volkswagen Group of America
Timothy Winters
President & CEO
Western New York Energy, LLC
[1] https://ww3.arb.ca.gov/fuels/lcfs/lrtqsummaries.htm. “LCFS Quarterly Data Spreadsheet (updated January 29, 2021)”
[2] https://www.nyserda.ny.gov/about/publications/ea-reports-and-studies/patterns-and-trends
Download the full letter here.