It is also time for the Federal government to stop pushing out compliance with EPA mileage etc. to our domestic car manufacturers. Ford , Chevy 7GM need to ramp it up or get left behind.

If Japan can build the Leaf then by God the American auto plants should be kicking their hind ends. To the big 3 stop putting us behind the eight ball and be innovative instead.

Where are the details concerning the CMAQ project? Is there a possibility of revising the terms of this demonstration project to allow for the use of the VOLT? If the end goal of the project is the reduction of particulate matter / greenhouse gas by less use of a gasoline engine, then this would depend more on the routes / distance expected as to whether the VOLT would suffice. If the Leaf has only 100 miles to a charge, and the VOLT has ~40, perhaps the charging behavior could be modified? I appreciate the consideration.

Dear Mr. Wiseman, Thank you for your comment on 5/12/2011 and your interest in our project. Currently, there are no all electric vehicles available for fleet purchases that are produced in the U.S. with U.S. made iron and steel, and other manufactured components. Therefore the proposed initiative qualifies for a waiver under the Buy America code Section 5323(j) of Title 49, subpart B. Furthermore, the proposed initiative qualifies for a waiver under section j subsection 1. The Local Government EV Fleet National Demonstration project aims to reduce transportation related greenhouse gas emissions from local government fleets and reduce particulate matter associated with those emissions to improve regional air quality. In order to achieve these goals, we must purchase all-electric vehicles to replace older, gasoline powered vehicles. It is in the public’s interest to reduce greenhouse gas emissions and reduce particulate matter in the air we breathe. The San Francisco Bay Area is in a non-attainment zone for particulate emissions. Particulate emissions have been associated with high rates of asthma, frequent emergency room and health care visits, and therefore contribute to higher operating costs for local governments providing health services. By reducing greenhouse gas emissions from government fleets through purchase of all electric vehicles and through installation of charging infrastructure this initiative will broadly and significantly serve the public’s interest.

Dear Mr. Putman, Thank you for your comment on 5/12/2011 and your interest in our project. You are correct that the federal government has supplied funding assistance to Nissan to encourage domestic production of their all electric vehicles and Nissan plans to manufacture the Leaf at their new Tennessee based plant in late 2012. Our efforts to purchase all electric vehicles with federal funding are completely in line with the Federal government and Obama Administrations’ environmental and economic goals. In 2008, President Obama announced the ambitious goals of putting 1 million advanced technology vehicles, including both hybrid and electric vehicles, on the road in the U.S. by 2015 and reducing U.S. crude oil imports by one-third by 2025. Again, we appreciate your interest and support.

Dear Mr. Pappas, Thank you for your comments and questions on 5/13/2011. The purpose of this project is to demonstrate the use of all-electric vehicles and charging stations in our government fleets to gather valuable user data and best practices for charging station location strategies to build the U.S. electric vehicle market. While the up-front cost of the vehicle is an important factor, it isn’t the only factor we consider. We take the complete life cycle cost into account when we are determining the most economical vehicles to run in our fleets. In order to accurately assess the “cost of ownership” of a vehicle one needs to include more than just the purchase price. You also need to look at the fuel and maintenance costs over the life of the vehicle. The EPA rated the Nissan Leaf’s combined fuel economy at 99 MPG gasoline equivalent, and experts have estimated that the Leaf’s maintenance cost will be less than that of the conventional gasoline vehicle. Through this demonstration project, we plan to have local government employees utilize these all electric fleet vehicles during working hours and then charge the vehicles at the end of the work day during off-peak hours. We estimate that the cost per kWh to charge the Nissan Leaf and Ford Transit Connect vans will be 0.08 cents per kWh (off peak) or .019 cents per mile. Therefore, to fully charge the Nissan Leaf for 100 miles of range, we will spend approximately $1.92. Looking at the full life cycle costs, the Leaf will have a lower cost than a conventional gasoline vehicle. The cost of wiring each charging station varies greatly based on the location of each station installation and the type of equipment that each partner chooses to install. Through our local government partnership, we will achieve economies of scale when purchasing charging stations at lower than retail costs. We plan to employ local government workers to install and wire the stations when possible further reducing our costs. Additionally, the Nissan Leaf will help to reduce our dependence on foreign oil. Local governments participating in this demonstration project want to invest in fuel efficient, low maintenance cost vehicles and replace older more expensive to maintain, fuel inefficient and/or high greenhouse gas emitting vehicles.

Dear Mr. Schwartz, Thank you for your comment on 5/13/2011 and your interest in our project. These types of modifications would void manufacturer’s warranties and potentially compromise the safe use of the vehicle. Dear Ms. Hasper, Thank you for your comment on 5/16/2011 and your interest in our project. Section 5323(j) of Title 49 of the United States Code describes the Buy America provisions that are applied to transit related procurements valued over US $100,000, including grants administered by the Federal Transit Authority (FTA) or Federal Highway Administration (FHWA). Buy America provisions are a condition of U.S. federal government grants to state, municipal or other organizations including transit authorities. The Buy America provision in this case is for a 100% domestic iron and steel content requirement for the vehicles being purchased. The relevant section of the Code is as follows: (j) Buy America. - (1) The Secretary of Transportation may obligate an amount that may be appropriated to carry out this chapter for a project only if the steel, iron, and manufactured goods used in the project are produced in the United States.(2) The Secretary of Transportation may waive paragraph (1) of this subsection if the Secretary finds that - (A) applying paragraph (1) would be inconsistent with the public interest; (B) the steel, iron, and goods produced in the United States are not produced in a sufficient and reasonably available amount or are not of a satisfactory quality; (C) when procuring rolling stock (including train control, communication, and traction power equipment) under this chapter - (i) the cost of components and subcomponents produced in the United States is more than 60 percent of the cost of all components of the rolling stock; and (ii) final assembly of the rolling stock has occurred in the United States; or (D) including domestic material will increase the cost of the overall project by more than 25 percent. The Buy America U.S. Government code is separate and distinct from the Buy American provisions in the 1933 Buy American Act; Sections 10 (a-d) of Title 41 of the United States Code. Currently, there are no all electric vehicles that are produced in the U.S. with U.S. made iron and steel components and available for fleet purchases. Therefore the proposed initiative qualifies for a waiver under the Buy America code Section 5323(j) of Title 49, subpart B. The Chevy Volt is a plug-in hybrid electric vehicle with a limited 40 mile all electric range which, when depleted, reverts to a gasoline powered engine. The VOLT has a 9.3 gallon gas tank and an estimated extended range of 300 miles when the fuel tank is full. The Chevy Volt does not meet the requirements of the demonstration program because it is not an all-electric vehicle. The goal of this demonstration project is to showcase all electric vehicle technology in local government fleets to build the domestic market for these vehicles which will create jobs through new electric vehicle infrastructure development and domestic manufacturers’ response to this increased market demand. Through this project, local government employees will drive and perform routine maintenance on all electric vehicles (EV) and will utilize the domestically manufactured charging infrastructure that will be procured and installed as part of this project. Additionally, local residents of the Bay Area region will have access to some of the associated charging infrastructure and will learn about this new technology through the project’s EV outreach and awareness raising campaign. In order for the U.S. alternative fuel vehicle industry to grow and thrive, sufficient infrastructure must be strategically implemented along with focused public education and outreach detailing the benefits of these new technologies. Local governments are in a unique position to leverage our collective purchasing capabilities to incorporate all electric vehicles into our fleets to generate valuable local visibility for this new technology. Additionally, we plan to leverage our ability as fleet managers to gather valuable user data and feedback to document best practices regarding all electric charging infrastructure location citing and user behavior. The project will also provide on-site training for our employees who will be utilizing both the vehicles and charging infrastructure leading to increased knowledge of this new technology and invaluable hand-on experience with a focus on building domestic demand for these vehicles. Increased public and local government demand for all electric vehicles and associated infrastructure will send a clear message to domestic manufacturers to expand their production of alternative fuel vehicles to meet this demand. Dear Ms.Carpenter, Thank you for your comment on 5/16/2011 and your interest in our project. Please see my comment above to Ms. Hasper regarding why the Chevy VOLT does not meet our specific project requirements. Please note one of the goals of our demonstration project is to significantly stimulate U.S. demand for electric vehicles and associated charging infrastructure. Through extensive outreach and education throughout the Bay Area region, we hope to increase public knowledge and awareness of advanced technology vehicles that will ultimately expand the domestic EV market demand and support domestic manufacturers of both electric and plug-in electric vehicles.

Dear Mr. Moultrie, Thank you for your comment on 5/16/2011 and your interest in our project. Please see my comments above to Ms. Hasper and Ms Carpenter for further information.

Dear Mr. Robson, Thank you for your comment on 5/16/2011 and your interest in our project. Please see my comments above to Ms. Hasper and Ms Carpenter for further information.

Dear Mr. Bradley, Thank you for your comment on 5/16/2011 and your interest in our project. Please see my comments above to Ms. Hasper and Ms Carpenter for further information.

Dear Mr. Scramling, Thank you for your comment on 5/16/2011 and your interest in our project. Please see my comments above to Ms. Hasper and Ms Carpenter for further information.

Dear Mr. Pappas, Thank you for your comments and questions on 5/17/2011. The vehicles we purchase need to be all electric to meet the requirements of our grant and to achieve both our economic and environmental goals of reduced transportation related emissions, reduction in fuel use and improved air quality for the region. Additionally, as noted in my comment above to Ms. Hasper, each local government project partner will gather and document valuable EV user data that will provide best practices and effective strategies for further development of the U.S. EV market infrastructure that will benefit domestic manufacturers of both all electric and plug-in hybrid electric vehicles.

Dear Mr. Japowicz, Thank you for your comment on 5/17/2011 and your interest in our project, your comment is noted.

Dear Ms. Cook, Thank you for your comment on 5/17/2011 and your interest in our project. Please see my comments above to Ms. Hasper, Ms Carpenter, and Mr. Pappas for further information.

Dear Mr. Pita, Thank you for your comment on 5/17/2011 and your interest in our project. Please see my comments above to Ms. Hasper, Ms Carpenter, and Mr. Pappas for further information.

Dear Mr. Langan, Thank you for your comment on 5/17/2011 and your interest in our project. Please see my comments above to Ms. Hasper, Ms Carpenter, and Mr. Pappas for further information.

Dear Mr. Strock, Thank you for your comment on 5/18/2011 and your interest in our project. Section 5323(j) of Title 49 of the United States Code describes the Buy America provisions that are applied to transit related procurements valued over US $100,000, including grants administered by the Federal Transit Authority (FTA) or Federal Highway Administration (FHWA). Buy America provisions are a condition of U.S. federal government grants to state, municipal or other organizations including transit authorities. The Buy America provision in this case is for a 100% domestic iron and steel content requirement for the vehicles being purchased. The relevant section of the Code is as follows: (j) Buy America. - (1) The Secretary of Transportation may obligate an amount that may be appropriated to carry out this chapter for a project only if the steel, iron, and manufactured goods used in the project are produced in the United States.(2) The Secretary of Transportation may waive paragraph (1) of this subsection if the Secretary finds that - (A) applying paragraph (1) would be inconsistent with the public interest; (B) the steel, iron, and goods produced in the United States are not produced in a sufficient and reasonably available amount or are not of a satisfactory quality; (C) when procuring rolling stock (including train control, communication, and traction power equipment) under this chapter - (i) the cost of components and subcomponents produced in the United States is more than 60 percent of the cost of all components of the rolling stock; and (ii) final assembly of the rolling stock has occurred in the United States; or (D) including domestic material will increase the cost of the overall project by more than 25 percent. The Buy America U.S. Government code is separate and distinct from the Buy American provisions in the 1933 Buy American Act; Sections 10 (a-d) of Title 41 of the United States Code. Dear Mr. Swanberg, Thank you for your comment on 5/18/2011 and your interest in our project, your comment is noted. In 2011 Census Year to Date data, Japan ranks as the U.S.’s 4th most significant trading partner with $ 16.1 Billion worth of U.S. goods exported to Japan. Legislation that imposes barriers on products imported from Japan hurts U.S. consumers of those products, and impacts our significant export industries and U.S. jobs. The vehicles procured under this initiative are currently made in Japan by Nissan and in Turkey by Ford. In 2012 Nissan will open a U.S. manufacturing plant for the all-electric Leaf and employ 1300 U.S. workers. Demonstrations projects such as this will make the public more aware of the benefits of electric vehicles and help create a demand that will be met by other manufacturers’ including U.S. companies.

Dear Mr. Kowalske, Thank you for your comment on 5/18/2011 and your interest in our project. Please see my comments above to Ms. Hasper, Ms Carpenter, and Mr. Pappas for further information. Dear Mr. Piscopo, Thank you for your comment on 5/19/2011 and your interest in our project. As noted above, our demonstration project will stimulate and expand the domestic EV market by introducing all electric vehicles into local government fleets and through the procurement and installation of domestically manufactured charging infrastructure. Our project will create local, U.S. jobs in vehicle maintenance and management as well as multiple positions associated with installing and maintaining charging infrastructure (electricians, planners, building inspectors etc.) Additionally, the education and outreach components of our project will increase public awareness of EV technologies which will further stimulate domestic demand for electric vehicles. Please see my comments above to Ms. Hasper, Ms Carpenter, and Mr. Pappas for further information.

Dear Mr. Rummel, Thank you for your comment on 5/19/2011 and your interest in our project. Please see my comments above to Ms. Hasper, Ms Carpenter, and Mr. Pappas for further information.

Dear Ms. Hasper, Thank you for your comments and questions on 5/19/2011. This project will take place in the Bay Area region of California where we currently receive approximately 1% of our total electricity supply from coal burning power plants. The majority of our electricity is generated by natural gas, hydroelectric power and renewable energy sources. Please refer to the U.S. Department of Energy for more detailed information http://apps1.eere.energy.gov/states/electricity.cfm/state=CA#fuel. Conversely, about 50% of total U.S. electricity consumption is supplied by coal-fired power plants. Therefore, California’s relatively low emission electricity mix as well as the fact that transportation related emissions make up almost half of our total state emissions (38%), makes our state a key location for the deployment of all-electric vehicles. As a result of replacing 90 older, gasoline powered vehicles with all electric vehicles through this demonstration project, we anticipate that we will be able to reduce our fleet related greenhouse gas emissions by 440,000 lbs per year as well as to reduce particulate matter generation. Additionally, among our 11 local government project partners, we will be able to reduce fuel consumption by approximately 35,000 gallons each year leading to significant cost savings over the project lifetime. I cannot comment on your specific questions related to the cost of either building the Tennessee Nissan Leaf plant or the cost of the jobs generated from that project as I am not privy to this information.

Dear Ms. Shepherd Moore, Thank you for your comments on 5/19/2011 and your interest in our project. We were awarded funding for this EV demonstration project through the regional Metropolitan Transportation Commission’s (MTC) Climate Initiatives program. The funding source is Congestion Management and Air Quality funds (CMAQ) which you can find more information on here: http://www.fhwa.dot.gov/environment/air_quality/cmaq/ Ultimately, our project proposal sought to meet both CMAQ funding guidelines to support transportation projects that contribute to air quality improvements within specific regions, and MTC guidelines for innovative demonstration partnerships that would provide significant environmental benefit while demonstrating the use of all electric vehicles in local government fleets. More information on the MTC Climate Initiatives competitive grants program can be found here: http://www.mtc.ca.gov/planning/climate/climate_grant We were awarded this funding by the MTC based on our proposal to demonstrate and gather data on the use of all electric vehicles within 11 local government fleets and the associated environmental, educational and economic benefits that this project will achieve.

Dear Mr. Charbonneau, Thank you for your comment on 5/19/2011 and your interest in our project, your comment is noted. Dear Mr. Wilson, Thank you for your comment on 5/20/2011 and your interest in our project, your comment is noted.

Dear Roberta, Thank you for your comment on 5/24/2011 and your interest in our project. Please see my comments above to Ms. Hasper, Ms Carpenter, and Mr. Pappas for further information.

Dear Rhonda, Thank you for your comment on 5/25/2011 and your interest in our project. Please see my comments above to Ms. Hasper, Ms Carpenter, and Mr. Pappas for further information.

The County of Alameda has requested a Buy America waiver to use CMAQ funds for purchase and implementation of an all-Electric Vehicle (EV) fleet to be shared by a coalition of local public agencies. The San Francisco Bay Chapter of the Sierra Club, as home to at least 6 of the public agencies involved in the Local Government EV Fleet Demonstration project, supports Alameda County’s request for a Buy America waiver for this important project.

The Sierra Club, as the nation’s oldest and largest grassroots environmental organization, is very supportive of efforts to introduce electric vehicles into public and private fleets and to encourage consumers to switch to electric vehicles. According to a range of studies, electric vehicles are 35-60% less polluting than traditional vehicles, even when emissions from electricity are taken into account. We see electric vehicles as one important way to reduce carbon emissions and our dependence on oil. EV pilot projects, efforts to introduce public EV charging infrastructure, and public, private, and utility programs to incentivize and educate about EVs are all important.

It is in the public interest to use less polluting vehicles whenever possible, especially with the pending need in California to comply with the provisions of state climate change/greenhouse gas reduction legislation such as AB 32 and SB 375. Therefore, time is of the essence in implementing this multi-agency partnership.

Unfortunately, the Local Government EV Fleet Demonstration project will be difficult to achieve without a Buy America waiver, and impossible in the near future.

The Sierra Club values our working relationship with American labor, and we certainly wish that the state of the U.S. auto industry were such that a waiver request was not necessary. But at the current time, no U.S.-made vehicles are available, or in sufficient quantities, that will meet the “all electric” design of the project. There is only one American plug-in hybrid model currently available in limited quantities and at least one American-made model of an all-electric vehicle is expected to come on the market in the next year. We hope that our communities will seriously consider and have access to purchasing some of these vehicles, but we believe that in the meantime, greater variety and flexibility is needed in meeting our EV goals as we move towards reductions in emissions and oil dependence.

We look forward to continuing to work with Alameda County as this and other projects are implemented to enhance local climate protection efforts and as the current update of the Countywide Transportation Plan proceeds.

If there are any questions regarding our position in this matter, please contact me.

Sincerely,

Glenn R. Kirby Vice-Chair, San Francisco Bay Chapter Executive Committee Member, Southern Alameda County Group