Electric School Bus Coalition sends public comments to the EPA

US EPA Clean School Bus Program
1200 Pennsylvania Ave
Mail Code 6406A
Room 5358K
Washington, DC 20450

To Whom It May Concern:

The Electric School Bus Coalition (ESBC) is comprised of an unparalleled diverse stakeholder network of bus manufacturers/providers, electric utilities, NGOs, and material providers that provides critical solutions towards zero emissions by accelerating the expansion of electric school bus fleets for a cleaner, healthier economy and nation.

The Coalition (https://eschoolbus.org/) was launched in June 2021 with 17 founding members. Since its launch, Coalition membership has grown to over 30 members and helped influence passage of the Infrastructure Investment and Jobs Act (IIJA). The ESBC agrees with the importance of and need for federal investment in clean school buses for several important reasons including:

Cleaner Transportation Fleet & Healthier Air for Our Kids

Electric school buses are a primary solution for improving U.S. fuel economy and reducing tailpipe emissions, which reduces local air pollution and greenhouse gases emissions simultaneously.

Electric school buses are a naturally equitable solution across American communities that bring significant health benefits to children who ride school buses every day, especially those in vulnerable communities where pollution levels and public bus reliance are the highest.

Economic Growth Potential

With approximately 480,000 school buses on the road today, accelerating the deployment of electric school buses and electric vehicle charging infrastructure creates robust economic opportunities while simultaneously advancing a cleaner economy.

Global Competitiveness

The global electric school bus market is expected to grow 19% annually over the coming years from just over $9 billion in 2018 to almost $32 billion by the end of 2025. All four major school bus manufacturers serving the North American market are manufacturing domestically, which makes school bus electrification a chance for American manufacturing leadership.

Electric Grid Support

  • Electric school buses provide utilities and grid managers with an important new tool for supporting the national electrical grid during times of stress. The vehicle battery storage provides the opportunity to manage load on grid, tools for soaking up low-cost overnight or midday power while discharging it during grid-stressed evening peaks, protecting fuel independence and accelerating the integration of renewable resources

As EPA begins the process of crafting the outlines and rules around the funding included in the IIJA, I wanted to share with you several overarching principles that the entire diverse membership of our coalition have agreed upon:

  • Ā $25B in funding for electric school buses and associated charging infrastructure is needed over a 10-year period in a manner that spreads the investment across the entire United States.
  • Coordination between EPA, DOE, and DOT as well as with State Energy Offices.
  • Priority considered for low-income, environmental justice, and rural communities, including those where public-private partnerships may spur increased electric school bus adoption.
  • 100% funding for low-income communities, with cost-share otherwise to maximize the leverage of federal funding.
  • Equal treatment across school districts, regardless of whether they own and operate their own fleets or use a third-party fleet operator, so all districts have fair access to the funding and ability to integrate electric school buses.
  • Ā Consider the use of point-of-sale rebates since they are the most efficient approach for school districts.
  • Ensure that any scrappage (removing internal combustion engine buses from service) requirement provides school districts with some flexibility to execute the vehicle scrappage so they have sufficient time to plan and execute fleet transition while still guaranteeing that polluting buses are removed from use.

As EPA works through the details of the Clean School Bus Program, please feel free to use the ESBC, myself, and our members (https://eschoolbus.org/our-members/) as a resource.

Sincerely,

John Hipchen
Executive Director
Electric School Bus Coalition
(212) 251-7208

About the Electric School Bus Coalition

The Electric School Bus Coalition (ESBC) brings together bus manufacturers and providers, electric utilities, NGOs and material providers to provide critical solutions geared toward zero emissions and to accelerate the expansion of electric school bus fleets for a cleaner, healthier economy and nation. The coalition supports a series of phased initiatives that coordinate agencies at the federal and state levels to make it easy and cost effective for school districts and municipalities to transition, with funding priority for low-income, rural and environmental-justice communities, and with equal treatment for all school districts. For more information, or to become a coalition member, visit ESBC at www.eschoolbus.org.

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