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Public Comments to Support Cleaner Buses in Illinois

On June 17th, 2021 Dream Corps Green For All submitted a public comment to the Illinois Environmental Protection Agency (EPA) to ensure the state distributes VW settlement funds in a way that achieves multiple community benefits including enhanced mobility and reduced pollution.

Dear Illinois Environmental Protection Agency,

Green For All is a program of the national social justice nonprofit Dream Corps. We help
advance solutions that address pollution and build a green economy strong enough to lift people
out of poverty. Our Fuel Change campaign works to deploy clean cars, buses, and trucks to
neighborhoods that face disproportionate pollution burden and lack quality mobility options.
We write to express significant support of the overarching goals, priority areas, and clean
transportation funding percentages outlined in the draft revised Beneficiary Mitigation Plan
(BMP) released on April 29, 2021.

First, we support the fund distribution goals to reduce NOx emissions, transition Illinois’
transportation system to zero emission technology, and improve public transportation. Together,
these goals can help to ensure that the state distributes VW settlement funds in a way that
achieves multiple community benefits including enhanced mobility and reduced pollution.
We also support the allocation of 45% of funds toward electric public transit buses, 38% of funds
toward electric school buses, and 15% of funds toward light duty charging infrastructure. While
heavy duty vehicles like transit buses make up only 10% of vehicles on the road, they contribute
28% of greenhouse gas emissions, 45% of NOx, and 57% of PM2.5.1 Exhaust from diesel
fueled vehicles can increase the risk of mortality, cancer, and respiratory illness. This pollution
exposure is especially concerning for youth. Ninety-five percent of America’s school buses run
on diesel2. Children are more susceptible to the health impacts of diesel pollution because their
lungs are still forming and they breathe at faster rates than adults3. This exposure can contribute
to impaired lung function, asthma, and even reduced IQ in children4. Therefore, prioritizing
considerable investments toward heavy duty vehicles like zero emission transit and school buses
is essential to improving public health for the most vulnerable populations.

We strongly support the targeted deployment of VW settlement funds in areas with
disproportionate pollution burden and non-attainment for ozone. This prioritization is key to help
ensure that the benefits of cleaner medium and heavy duty technologies reach low income
communities and communities of color on the front lines of pollution in Illinois.
We recommend the following adjustments to the BMP to ensure a fair process and equitable
outcomes:

• We support leveraging a portion of funds toward light duty ZEV supply equipment and
also recommend that these funds be prioritized for multi unit dwellings within priority
areas in order to ensure increased accessibility for low income households.

• The BMP should allow for joint applications from more than one stakeholder. Given the
steep price of new electric buses, which can cost $120,000 more than diesel buses5,
joint applications may encourage bulk purchase savings and help spur the adoption of
these cleaner vehicles.

• We support offering the same cost share for non-governmental and governmental
entities applying for funding to ensure that students living in pollution burdened areas
can access cleaner air and the benefits of electric vehicle deployment regardless of
whether publicly or privately run school buses serve their district.

Moving forward, it will be critical that IL EPA continues to engage disproportionately impacted
residents throughout this process to ensure meaningful benefits for those who need it most. IL
EPA should actively solicit public comment on the RFP process and application selection. This
outreach and engagement may include posting online all relevant materials far in advance of
any comment deadline, working directly with community based organizations to publicize open
comment periods through various channels including listening sessions, and ensuring
accessibility for limited English proficient individuals, people with disabilities, and people with
different educational backgrounds.

In sum, we encourage the IL EPA to make these changes in order to lower barriers to
participation and access to funding for zero emission vehicle technology. We actively support
the BMP’s prioritization of funds toward bus electrification with a focus on allocating funds in
neighborhoods facing the worst pollution burden in the state.

Sincerely,
Nicole Wong
Fuel Change Campaign Manager
Dream Corps Green For All


  1. O’Dea, Jimmy. “Zero-Emissions Technology for Freight: Heavy-Duty Trucks.” Moving Forward Network, Oct. 2020.
  2. Frontier Group, NJPIRG, Environment New Jersey, 2018, Electric Buses, environmentnewjerseycenter.org/sites/environment/files/reports/Electric%20Buses%20-%20NJ%20-%20May%202018%20web.pdf.
  3. Solomon, Gina M, et al. NRDC, 2001, No Breathing in the Aisles, www.nrdc.org/sites/default/files/schoolbus.pdf.
  4. Liu, Norrice M, and Jonathan Grigg. “Diesel, Children and Respiratory Disease.” BMJ Paediatrics Open,vol. 2, no. 1, 24 May 2018, doi:http://dx.doi.org/10.1136/bmjpo-2017-000210.
  5. Frontier Group, NJPIRG, Environment New Jersey, 2018, Electric Buses,
  6. environmentnewjerseycenter.org/sites/environment/files/reports/Electric%20Buses%20-%20NJ%20-%20
  7. May%202018%20web.pdf.

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