Vermont is seeking specific input on how it should prioritize the funding of eligible projects with Vermont’s $18.7 million allocation of the Volkswagen Environmental Mitigation Trust. Please be as specific as possible in providing answers to the questions. Your answers will be submitted to ANR for their review and consideration. Feel free to submit any additional feedback as provided below or in a separate email to The public comment period will close on January 13, 2018. Please be sure to submit your answers to these questions before then. Thanks!
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1. If you own or operate a vehicle/piece of equipment that would be eligible for replacement/repowering, what are your preferences, considerations, and constraints for choosing between a new electric, diesel, or alternatively fueled vehicle?

2. If you own or operate a vehicle/piece of equipment that would be eligible for replacement/repowering, what type(s) of project(s) do you plan to apply for? See list of eligible projects here.

3. Should Vermont utilize the services of a third party to assist applicants with application development and feasibility issues, or to manage a portion of eligible project funding? What types of eligible projects should be managed by a third party?

4. How should Vermont calculate the emissions benefits/cost effectiveness of a project?

5. How, if at all, should Vermont prioritize the replacement or repower of eligible projects that, if funded, would occur earlier than they would have without funding?

6. How, if at all, should Vermont prioritize projects in eligible project categories that are limited to vehicles in certain model year ranges?

7. For eligible transit bus replacement or repower projects, how should Vermont prioritize these projects? For example, should Vermont prioritize projects that result in increased ridership, expanded routes, different schedules, and/or other factors?

8. In areas of Vermont where people are exposed to a disproportionate amount of air pollution, which of these areas should Vermont prioritize? For example, near-roads, school bus, etc.?

9. What is the maximum amount of time that Vermont should consider acceptable for implementation of eligible projects? Should the timeframe be different for different types of eligible projects?

10. How should Vermont prioritize projects with verified or leveraged funding? Specifically, what types of leveraged funding should be acceptable and/or prioritized?

11. How should Vermont consider an eligible project applicant’s experience, existing administrative/programmatic structure, technical expertise, and/or existing infrastructure necessary to ensure successful deployment of a project?

12. For eligible electric heavy-duty replacement or repower projects or light-duty electric vehicle supply equipment, how should project applicants be required to demonstrate coordination with local electric utilities? Should these types of project be required to show that electric charging will be managed to promote affordability of electricity and not add to peak demand?

13. For eligible electric heavy-duty replacement or repower projects or light-duty electric vehicle supply equipment, how should project applicants demonstrate that electric vehicles will be powered by the cleanest available energy sources?

14. How should Vermont measure the life-cycle emissions from proposed eligible projects?

15. How should Vermont consider eligible project feasibility or a project’s ability to actually result in the net emissions benefit if deployed as described in the project application?

16. The intent of the Environmental Mitigation Trust is the reduction of diesel air contaminants, including NOx and particulate matter, however Vermont is also seeking to achieve greenhouse gas reductions in funding eligible projects. How should Vermont evaluate greenhouse gas emission reductions as a co-benefit of a project?

17. Should Vermont limit the amount of cost share for an eligible heavy-duty electric replacement project to the amount that the technology is expected to cost in 5 years (given the fact that electric technology costs are expected to be lower in the future)? 10 years? Why or why not?

18. Considering that Vermont’s allocation of the Trust will be $18.7 million, and that Vermont is eligible to spend up to 15% of its allocation of light-duty EVSE, and another 15% on administration of the funds, what percentage of funds should Vermont spend on:
1. Heavy-duty electric replacement or repower projects (medium and heavy-duty freight trucks, transit buses, school buses)?
2. Heavy-duty diesel or alternative fuel (propane, CNG) replacement or repower projects?
3. Ferry repower projects?
4. Light-duty EVSE projects?
5. Administration costs?
6. Locomotive freight switcher replacement or repower projects?
7. Electric forklifts?
8. Electric airport ground support equipment?
9. Other DERA eligible projects (off-road mobile sources, idle reduction, etc.)?

19. Once Vermont is certified as a beneficiary (expected early 2018), it will have access to 1/3 of its funding allocation in the first year of the Trust ($6.23 million), 2/3 available in the second year, and then the full allocation in the third year. How should Vermont prioritize projects funded in the first year of the Trust given the availability of funding?

20. Should Vermont require government entities to provide some percentage of project cost share? If so, how much?

21. How should Vermont prioritize projects that align with state energy, environmental, and economic development goals?

22. Should Vermont require projects to meet a minimum size to be eligible for funding? If so, what should the minimum project size be and why?

23. Any other comments that you’d like to submit on the draft Beneficiary Mitigation Plan?