April 5th 2022

Environmental Protection Agency 1200 Pennsylvania Ave, N.W. Washington, DC 20460

To Whom It May Concern,

I am writing on behalf of the Greater Washington Clean Cities Coalition (GWRCCC) to comment on the EPA’s Clean Bus funding program. Our Coalition is one of the 90+ Clean Cities Coalitions around the country supported by the US Department of Energy. GWRCCC is a public-private partnership composed of representatives of the Metropolitan Washington Council of Governments, the District government, regional governments, national trade associations, public and private companies and public utility companies including Washington Gas. We are headquartered in the District of Columbia and have programmatic responsibility for the region including District of Columbia, Northern Virginia and Maryland. The mission of our Coalition is to promote the use of clean domestic fuels to assure our nation’s and region’s climate security, energy independence and clean air by reducing our dependence on gasoline and diesel transportation fuels.

Firstly, increasing federal funding for clean school buses is a critical objective in protecting the health and wellness of children, especially in underserved communities. Bus depots are more likely to be located in underserved communities, and consequently it is in these neighborhoods that buses spend a disproportionate amount of time idling, driving, and emitting toxic exhaust. Therefore, the health consequences of diesel school buses fall largely on children in underserved communities. Additionally, children in underserved communities are more likely to ride the bus to school as opposed to being dropped off by their parents. A study published by the Natural Resources Defense Council (NRDC) in 2001–over two decades ago–found that children riding in diesel school buses are exposed to four times the level of toxic exhaust as children riding in a car, and that because of these exhaust levels children riding diesel school buses are subject to 23-46 times the cancer risk considered significant under federal law. Children from low-income families also have an elevated prevalence of asthma (11% in families below the poverty threshold compared to 9% in families above the threshold and 6.8% in families making twice the threshold), which increases susceptibility to respiratory problems caused by air pollution exposure. Students with asthma missed 13.8 million days of school in 2013, making uneven asthma prevalence not only an issue of health equity but an issue of education equity.

Secondly, the GWRCCC seeks not only to underscore the NRDC study’s recommendation that federal, state, and local governments make significant additional funding available for the purchase of cleaner alternative fuel school buses, but also to emphasize that these governments must ensure that the underserved communities which are most in need and suffer the greatest consequences of air pollution are the beneficiaries of this funding. From an equity lens, the neglect of this point compounds the injustices long borne by underserved communities, most notably the impacts of air pollution from highways which were systemically sited in poor and minority communities. Electric school buses represent the cutting edge of green technology, and equitable access to this technology must also be considered as a contributor to equitable access to health and education.

Finally, by focusing funding efforts on retrofitting diesel buses (to electric)–which costs one-third to one-half the price of new buses– governments can deliver the benefits of better environmental health to a greater number of communities and help underserved communities reach sustainability goals sooner, thus accelerating improvements to the health and wellness of kids, families and communities.

Thank you for considering our comments. For further questions, please contact me at 202-671-1580.

Antoine M. Thompson
Executive Director
Greater Washington Clean Cities Coalition (GWRCCC)


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