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5 Ways US States Can Get More Electric School Buses on the Road




This is the first article in a three-part series examining the ways stakeholders — including state policymakers, school districts, and electric utilities — can build on recent federal actions to accelerate the equitable transition to electric school buses across the U.S.

Originally published on WRI’s Resource Institute.
By Katrina McLaughlin and Justin Balik 

The recent enactment of the bipartisan Infrastructure Investment and Jobs Act in the United States is an important step on the path to cleaner school bus rides for the more than 20 million children who rely on an iconic yellow bus every day and a chance for states to follow with bold action.

The new law makes an unprecedented investment in electric school buses (ESBs), appropriating $2.5 billion to help school districts adopt zero-emission school buses, such as ESBs, and another $2.5 billion toward zero- and low-emission school buses — which includes both ESBs and alternative fuel vehicles.

Under the new Clean School Bus Program, to run between 2022 and 2026, the U.S Environmental Protection Agency (EPA) will cover up to 100% of the costs of replacing existing school buses, including vehicles and charging or fueling infrastructure. It’s critical that the EPA use the flexibility provided by Congress to prioritize electric school buses over alternative fuel vehicles under the second portion of the program.

The Clean School Bus Program offers a bold new effort to begin phasing out diesel school buses, which account for 95% of the U.S. fleet. Diesel school buses contribute to climate change and expose children, drivers, and the surrounding community to unhealthy levels of air pollution, with impacts on health and learning.

Moreover, traditionally underserved communities — including communities of color and low-income communities — are more likely to rely on school buses for transporting their children to school and to suffer from vehicle-based air pollution. And according to one analysis, federal investment through the Clean School Bus Program could also provide major economic benefits, including creating approximately 46,000 job-years.

Although the Clean School Bus Program is the largest amount of funding ever established to electrify school buses, this investment is still not enough to transition the entire fleet of 480,000 school buses to electric vehicles — especially when each electric bus currently costs school districts more than three times their diesel counterparts. States will play a critical role in bridging the current upfront cost gap.

A Critical Time for All States to Act

The year ahead presents a unique opportunity for states to focus on equitable school bus electrification. Federal grant programs often reward applicants that leverage other funding. This makes 2022 the perfect time for states to invest their own resources in electric school buses by providing incentives, financing, technical assistance and regulatory support.

The good news, outlined in a previous WRI article, is that many school districts are already working to electrify their school buses, and as of August 2021 33 states have at least one ESB announced, procured, delivered or in operation. Now, it’s time for all U.S. states to get onboard and move to scale.

Interactive version of this map available here.

How States Can Bring the Benefits of Electric School Buses to Their Communities

Here are five specific ways that state leaders can position their school districts for a successful, equitable transition to electric school buses:

1. Set Ambitious Goals and Build a Supportive Policy Environment

Policymakers should consider how electric school buses fit within a state’s broader transportation electrification goals. On the regulatory and legislative fronts, states can set targets that help propel the market forward.

State policymakers should move immediately to adopt California’s Advanced Clean Trucks rule (ACT), which includes school buses. The ACT sets increasing zero-emission vehicle sales requirements for medium- and heavy-duty vehicle (MHDV) manufacturers beginning in 2024. Massachusetts, New Jersey, New York, Oregon and Washington adopted the rule in 2021, and more states are considering adoption in 2022.

State adoption of the ACT will bring cleaner air to impacted communities while bringing zero-emission trucks and buses to scale. Adopting the ACT is an important first step to codifying the goals of a memorandum-of-understanding signed by 16 states and the District of Columbia.

This agreement established a shared goal of cleaning up MHDV fleets, including school buses, by reaching 30% zero-emission MHDV sales by 2030 and 100% zero-emission MHDV sales by 2050. In addition to these efforts on new sale requirements, state leaders should review procurement laws and other state regulations and modify them as needed to bolster ESB deployment.

Within these broader transportation electrification efforts, school buses offer a promising ground and a place to move more quickly, as over 90% of school bus routes can be served with today’s electrification technology. ESB deployment can be a catalyst for broader MHDV electrification and a down payment towards cleaning up the entire sector.

Recognizing this potential, Governor Kathy Hochul recently announced a nation-leading proposal for New York, aiming to achieve the electrification of the state’s entire school bus fleet by 2035. If enacted, it would represent the first statewide transition plan to achieve a 100% ESB fleet in the country.

2. Provide Dedicated Upfront Funding

States have already awarded over $480 million in funding for electric school buses and infrastructure, including approximately $180 million in 28 states through Volkswagen (VW) settlement funds. These VW settlement funds make up over one third of state public funding for electric school buses allocated to date and are the primary source of state funding for ESBs in most states. In 2021, updates to state spending plans for VW settlement funds allocated significant amounts to ESBs, including $33.6 million in Illinois, up to $27.2 million in North Carolina, $20 million in Virginia and $13 million in New Jersey.

However, VW settlement funds are a one-time funding source that many states have already exhausted or will soon deplete. Additional new sources of funding are needed to support school districts and school transportation providers to cover the cost of new ESBs while the market continues to mature and until total cost of ownership parity is achieved.

Supportive financing options, including through state green banks, are also critical parts of the funding and financing landscape that can help school districts leverage the lower operational and maintenance costs of ESBs. Funding and financing options for school districts will be further discussed in an upcoming WRI article. States should dedicate a significant amount of funding to electric school buses, with at least 40% of this funding supporting ESB deployment in traditionally underserved communities (such as low-income communities, communities of color, Indigenous communities, and communities facing disproportionate air pollution).

California currently offers the most robust state funding for ESBs through its Hybrid and Zero-Emission Truck and Bus Voucher Incentive Program. The state is allocating $130 million exclusively for electric school buses in 2022.

States should put in place generous incentives now to increase uptake and phase them out over the next few years as the market matures, production increases and prices decline. For example, Colorado Governor Jared Polis recently proposed a new six-year $150 million program for school bus electrification. The budget proposal, if approved, would secure the full funding amount this year, which would allow for effective long-term planning and program design. If the full funding amount is appropriated this legislative session, it would allow for the possibility that the incentives could be front-loaded to build increased demand and drive uptake, and then phase down the incentives gradually. Starting out with more generous funding levels that gradually phase down also sends a signal to school districts that it’s fiscally prudent to start electrifying their fleets immediately.

3. Incorporate Technical Assistance and Workforce Development Strategies

States should also provide technical assistance to school districts as they manage the transition of their fleets. School districts are navigating an unprecedented pandemic and managing the educational needs of their students during a challenging time — they will need guidance with this new transportation option and its complexities. States are well-positioned to step in and offer that guidance to school district staff and should incorporate technical assistance and proactive engagement to ensure program success.

New York recently launched a new Green Schools Initiative to assist schools on clean energy and energy efficiency initiatives with a focus on disadvantaged communities. Administered by the New York State Energy Research and Development Authority, this is a promising model that should also be applied to transportation electrification. Technical assistance should focus on both the nuts and bolts of implementation as well as assistance accessing all available funding sources.

Supporting school district staff and drivers must also be part of this technical assistance. The California Energy Commission’s Clean Transportation Program invests directly in workforce development and training entities to expand their current services and develop new programming specifically tailored to zero-emission vehicles.

States need to consider how best to prepare their workforce to thrive as the electric school bus industry continues to evolve including supporting programs at community colleges and investing in historically underserved communities.

4. Ensure Electric Utility Programs Adequately and Equitably Invest in Charging Infrastructure

State public utility commissions which regulate investor-owned electric distribution utilities have a key role to play in supporting ESB adoption and ensuring a fair and cost-effective transition. This includes oversight of utility rates, transportation electrification planning, and authorization of make-ready infrastructure programs for ESBs.

State regulators should use these authorities to support school bus electrification. Transitioning to electric school buses has the potential to provide benefits to the grid, in addition to reducing harmful emissions from diesel buses.

Some utility programs may view ESBs as grid assets offering the potential for load management to avoid high-cost system peaks and to better allow for the integration of renewable energy generation. These programs may allow ESBs to be used as distributed energy resources or managed load assets. When establishing utility electric school bus programs, regulators should consider best practices for rate design that limit increased costs and maximize equitable outcomes.

Public utilities commissions can explore these topics through open dockets and technical workshops. These proceedings may evaluate rate structures and equity considerations when electrifying MHDVs, potential emissions benefits, and promising use cases for Vehicle Grid Integration.

One example is the Illinois Commerce Commission, which is assessing transportation electrification opportunities through a series of open workshops as directed under the Climate and Equity Jobs Act.

5. Incorporate Equity into All Aspects of ESB Program Design and Implementation

It is essential that all the above approaches place equity and environmental justice at the forefront. ESBs represent an opportunity to address the disproportionate burden of pollution experienced by people in traditionally underserved communities across the U.S.

Equity should be incorporated into all facets of state ESB policy, programs and outcomes, including procedural equity that centers community input into program design, as well as distributional equity that ensures that disproportionately impacted communities and students in underserved districts receive sufficient funding and technical assistance.

One state that is leading the way on this front is New Jersey. The State Senate just passed legislation that would bolster and expand electric school bus grants administered by the Department of Environmental Protection. At least half of the grants would be awarded to school districts serving low-income or environmental justice communities.

Examples of Recent State Legislative Activity on Electric School Buses

Governors and state legislatures across the country are prioritizing electric school buses and in 2021, bills involving electric school buses were introduced in at least 11 states. Four of these bills were passed and signed into law. In the table below we share examples that illustrate a range of state legislative approaches.

Illustrative Examples of State Legislation on Electric School Buses

Policy approach
Example 2021 Legislation
State-administered ESB program
Establishes state grant or voucher programs administered by a state agency. May be a separate electric school bus program or integrated into existing program.
S4077 New Jersey;

HB 2118 Virginia

Utility ESB investment program
Establishes programs within state public utility commissions authorizing investor-owned utility programs. Key decision points include determining which expenses are eligible to be rate-based. If Vehicle Grid Integration is a component of the program, these proposals may specify whether the utility or school district owns the bus and/or battery.
HB 832 Maryland;

SB 1380 Virginia

Broader utility electrification transportation planning
Incorporates ESBs into broader utility electrification planning proposals, which may in turn be included as part of larger climate, clean energy, and transportation bills. These bills typically require utilities to submit transportation electrification investment plans and may also require public utility commissions to study or recommend best practices for rate design and use cases.
SB 21-260 Colorado;

SB 448 Nevada; Public Act 102-0662 Illinois

Sales tax, loan terms, and tax exemptions
Lowers the financial cost of ESBs by exempting school districts from certain costs associated with ESBs, including sales tax on a purchased bus or use tax on transportation fuel. These modifications may be made through amendments to existing education statutes or state education aid reimbursements.
S5268 New York; HB 2184 Oregon
Public fleet electrification
Requires public fleets within a state to electrify. May be targeted only at school districts or include all public fleets including transit and state government fleets.
LD 1579 Maine; S.2255 Massachusetts
Green schools
May address multiple elements of reducing energy usage at public schools, including installing renewable energy, building energy efficiency upgrades, and school bus electrification.
H942 North Carolina;

HB 4120 Texas

Note: Bolded text indicates bills that have been passed and enacted into law.

With a wide range of electric school bus policy and program options available, and a unique opportunity to leverage an historic federal investment, states have an unprecedented window in 2022 to accelerate an equitable transition to electric school buses. Now is the time for states to create new jobs, combat climate change and deliver cleaner commutes for kids.

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Tesla’s Policy Lead Testifies at PUCT Open Meeting As Tesla Focuses on Supporting the Texas Grid




Tesla’s US Energy Markets Policy Lead, Arushi Sharma Frank, was recently asked to testify at a Public Utility Commission of Texas Open Meeting. A photo of Frank wearing an LFDECARB tee shirt popped up on Twitter. The tee shirt itself is a message focused on decarbonization by the group Bros for Decarbonization. You can learn more about the group here.

Frank confirmed that it was an impromptu request to testify. She also shared exactly what she talked about.

The document Frank shared was a filing receipt for supplemental comments from Tesla signed by Frank. There’s also a video of her testimony which you can watch here. In the document, Tesla said that it appreciated the opportunity to share its comments regarding PUCT’s discussions that were held on June 16, 2022 — the open meeting regarding Tesla’s proposal OBDRR041 as well as its prior work demonstrating how virtual power plants (VPPs) work.

I recently published an article about Tesla’s VPP workshop, which was related to OBDRR041. Tesla also said that it appreciated the Commission’s comments related to its Distributed Energy Resource (DER) pilot projects. Tesla especially supported the conversation between Commission representatives and the staff at the Electric Reliability Council of Texas (ERCOT), as well as with the market participants. The conversation covered the real implementation of the system through a pilot as opposed to a task force approach. The latter, Frank noted, could unnecessarily create delays in implementing a grid service solution for DERs.

Looking At The Document & Tesla’s Statements

The Commission’s decision to encourage ERCOT to get stakeholders together and develop a pilot project allowing the market solution of exports from VPPs to be tested is also something Tesla expressed its appreciation for. This allowed for addressing issues raised by utilities and other market participants that have concerns about the potential impacts of site-exporting DERs on distribution facilities. It also allowed for a discussion of the net impact and benefits to the transmission grid.

Tesla also clarified and provided information as a response to a few discussion topics and questions that were raised at the open meeting. These topics included the OBDRR041 status, the ERCOT Pilot Proposal, and a question posed to Tesla by Chairman Lake at the open meeting.

OBDRR041 status

Tesla noted that since the OBDRR041 is currently tabled at the ERCOT Technical Advisory Committee, it would not seek a vote until there was further development of issues and positions from ERCOT and the potential members of the committee.

“At this time, Tesla believes that OBDRR041 may remain tabled at the Technical Advisory Committee pending consideration of the feasibility of a Virtual Power Plant pilot as the Commission proposed at the Open Meeting.”

ERCOT Pilot Proposal

Tesla expressed its views on the formal ERCOT Pilot Proposal that was introduced at the Open Meeting. Tesla noted that for a formal ERCOT pilot approach to be a feasible alternative to OBDRR041, a pilot should :

Have ERCOT’s support and the market’s acceptance and approval from ERCOT’s governing board.
Be amenable to commercialization in that sufficient participants could be aggregated across sufficient distribution service areas (more than one, but in capped quantities, in each service area as described in a proposed pilot framework).
Adequately capture data addressing clearly identified distribution utility concerns, in parallel to or as part of the pilot’s scope.
Have provisions to ensure market services compensation commensurate with grid services provided by pilot participants
Have an identified “start date” and “end date” which are technically feasible for involved parties.

In addition to that last point, Tesla added that the following are requirements in Section 25.361 (k) regarding pilot development and approval:

“ERCOT may conduct a pilot project upon approval of the scope and purposes of the pilot project by the governing board of ERCOT. Proposals for approval of pilot projects shall be made to the governing board only by ERCOT staff, after consultation with affected market participants and commission staff designated by the executive director.

“The ERCOT governing board shall ensure that there is an opportunity for adequate stakeholder review and comment on any proposed pilot project.”

Tesla noted that pilot  project proposals approved by the ERCOT governing board should include the following:

The scope and purposes of the pilot project;
The designation of temporary exceptions from ERCOT rules that ERCOT expects to authorize as part of the pilot project;
Criteria and reporting mechanisms to determine whether and when ERCOT should propose changes to ERCOT rules based on the results of a pilot project.
An estimate of costs ERCOT will incur attributable to the pilot project.
An estimated date of completion of the pilot project.

Tesla’s Response To Chairman Lake

Tesla expressed its appreciation for Chairman Lake, who stated that “nothing teaches like experience, so the sooner you get something in the field, the more you learn faster.”

Tesla also responded to a question posed by the chairman and said that it’s concerned that it will not be able to scope a pilot program in a Non-Opt-in-Entity (NOIE) area. Currently, Texas homeowners are unable to participate in VPPs due to the law. Tesla said:

“Primarily, this approach may not be economically rational as it could mean a substantial resource investment in a pilot that is not scalable to a commercial retail offer where Tesla could continue to directly serve those customers and grow the program’s strength and viability.

“The customers in a pilot should be able to continue to benefit from the value for their systems beyond the end-date of the pilot, in a commercially viable solution – but with a NOIE-only pilot, Tesla would have no control, legally or otherwise, over the continued participation of such customers once the pilot closes, even if a viable market participation framework is implemented following that pilot’ s conclusion.

“Any formal program participation of those customers would be solely at the option of the NOIE serving those customers. More simply, the purpose of a pilot is to study a solution that can be scaled following adoption of market rules based on pilot learnings. To build a program off the learnings of a pilot, the customer base involved in the pilot should be able to continue service under that formalized program, so that parties involved are not running the risk of raising a wholly new set of unstudied issues in a new distribution system type that was not part of the pilot.”

Frank also shared a link to over 60 pages of data from Tesla. Deep dive coming soon.

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Coalition Calls for EU Hydrogen Quota for Shipping




Energy providers, shipping companies and NGOs call on the EU to introduce a minimum quota of 6% sustainable and scalable hydrogen fuels by 2030

A broad coalition of energy providers, shipping companies and NGOs — including Siemens Energy, Viking Cruises, Green Power Denmark and Brussels-based organisations Hydrogen Europe and Transport & Environment (T&E) — has called on the EU to introduce a minimum quota of 6% sustainable and scalable hydrogen fuels by 2030.

Last year the European Commission, the EU’s executive body, proposed a shipping fuel law (FuelEU Maritime Regulation) aimed at increasing the uptake of alternative marine fuels. Unfortunately, the law fails to guarantee the competitiveness of sustainable and scalable e-fuels, and risks promoting cheaper, unsustainable fuels. The coalition therefore calls on the European Parliament and EU Council to improve the proposal by including a dedicated e-fuels sub quota in the proposed regulation.

Delphine Gozillon, sustainable shipping officer at T&E, said:

“An ambitious shipping fuels law will be key to set the shipping sector on course for full decarbonisation. Sustainable e-fuels are currently too expensive compared to other alternatives such as fossil LNG and biofuels, holding back investments in production facilities, refuelling infrastructure in ports and zero-emission ships. However, with a bit of a push e-fuels produced from renewable hydrogen can be scalable. That’s why we need a quota to get the ball rolling and encourage companies to start investing in clean shipping fuels. Shipping does not need to be a dirty industry forever.”

A list of all the coalition’s demands can be found here.

Download the letter.

Courtesy of Transport & Environment.

Featured image courtesy of Maersk.

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Diving Into Tesla’s 60+ Pages of PUCT Filings (Mostly Data)




Tesla has over 60 pages of Public Utility Commission of Texas (PUCT) filings that have recently been shared publicly, and we’re about to dive into them. Grab some water and a coffee and let’s go.

Tesla and its team, including its US Energy Markets Policy Lead, Arushi Sharma Frank, have been working hard to help Texan Powerwall customers be able to take part in virtual power plant (VPP) pilot programs. In May, Tesla held a VPP workshop for the Electric Reliability Council of Texas (ERCOT) and Frank was one of the key leaders hosting the meeting.

Recently, Frank was asked to testify at an open meeting of the PUCT, and there she shared Tesla’s comments and statements addressing questions and other concerns relating to VPPs.

Frank tweeted a thank you to the PUCT for the opportunity of allowing Tesla to provide comments. In addition, she followed up with two more tweets, with one mentioning her favorite part of the filings — Tesla describing a phenomenon called “clumping.” Clumping is a reference to capturing the full value of distributed energy renewables capacity in an aggregate load resource (ALR).

63 Pages Of Data For PUCT

In total, there were 63 pages. I’m only going to go over some of the data briefly. I think it’s important to highlight Tesla’s hard work because if Texas allows its residents who own Powerwall batteries systems to participate in VPPs, this opens the door for other states in the Deep South to at least consider clean energy solutions for various problems, especially grid-related. Texas is well known for its grid instability, and if it allows Tesla Powerwall customers to take part in VPPs, this could mean saving lives during disasters.

Included in the filings were comments from Tesla, a request from Tesla that the Commission direct ERCOT to prioritize several actions such as allowing ALRs (Aggregated Load Resources) to provide injection capacity from individual sites in a framework by December 2022, an informal narrative of Tesla’s VPP demonstration in ERCOT, and 47 slide pages detailing the ERCOT/Tesla ancillary service demonstration.

I think the most important part for us outsiders observing here is the 47 slides, because they highlighted a lot of data that shows just how the Texas grid will benefit from VPPs. The 47 slides showed several key meetings between Tesla and ERCOT about the demo program.

Key Meeting Between Tesla & ERCOT Shows Tesla Has Been Working Hard Trying To Convince Texas To Allow VPPs

In March, there were four meetings in which Tesla defined clumping, Frank’s favorite part, as well as two telemetry signal approaches. Following that were weekly meetings around the demo results with the last demo result being April 15, 2022. On April 9, Tesla and ERCOT revisited clumping and the two telemetry signals approach.

This tells me and anyone paying close attention that Tesla has been quietly working with ERCOT to help the Texas grid for quite some time. This, I think, is a good thing, especially for Texas.

Tesla Seeks To Register The First ALR In ERCOT

According to the documents, Tesla wants to register the first ALR in ERCOT and participate in services that are currently unavailable. These services include non-spin and sCED load reduction dispatch. Tesla wants to do this with the full value of grid services that injecting devices can provide in an ALR.

Tesla said that it will lead efforts to modify the utility’s ALR Policy Other Binding Document to make it fit with practical operational, registration, and qualification issues. It clarified that ERCOT can exchange two telemetry points with an aggregation-qualified scheduling entity (QSE).

Tesla ERCOT Demo Tests

Tesla’s first demo looked at the comparison of battery and premise-level telemetry. Below is a chart showing the initial conditions, test steps, data collected, and pass criteria.

Table courtesy of Tesla

This first test results show that VPPs work beautifully in Texas. According to the results, the load decreased during the evening while in the morning it decreased while exporting to the grid. And during the daytime, the exporting of energy to the grid only increased. Tesla explained further:

“Discharging from the customer’s battery using a step function can clearly be identified in the premise-level data.

“At different times of day, premise-level data will look differently, depending on the current load:

1. Evening time: during the evening peak, user load is typically high, and discharging the battery will show up as a decrease in premise-level load.

2. Morning time: during the night/morning time, user load is typically lower, and discharging the battery will both decrease load, and export energy to the grid.

3. Daytime: during the daytime, solar is exporting to the grid, and discharging the battery will increase the export.”

You can view the full demo, test results, and all of Tesla’s comments here.

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