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January 13, 2020

Honorable Andrew M. Cuomo

Governor of New York State
New York State Capitol
Albany, NY 12224

Dear Governor Cuomo,

On behalf of the Clean Fuels NY Coalition, we write to congratulate you on your robust
2020 State of the State address, beginning with addressing climate change. We
applaud your four-part initiative to accelerate investment in electric vehicles, charging
stations and mass transit.

As you know, the transportation sector is the largest contributor to New York’s
greenhouse gas emissions. We need big solutions to modernize such a large sector,
and we are pleased the State is taking measures to electrify our bus fleets and expand
charging opportunities.

We recognize your call to transition the upstate public transit fleets to 25% electric
buses by 2025 and 100% by 2035 and significant expansion of the charging network.
However, the reality is that transit agencies will seek state assistance to fund the
transition of more than 1,400 buses to all-electric at a time when the State is facing
budget shortfalls. We’ve already heard concerns about how the transit agencies will
fund this initiative from the Senate Transportation Committee and New York Public
Transit Association.

As such, we urge you to include legislation to establish a Low Carbon Fuel

Standard (LCFS) in your executive budget. This is an approach that could help
meet your ambitious goals – starting almost immediately – without impacting the
state’s finances while also creating a dependable market for cleaner fuels.

The LCFS is a budget-neutral, technology neutral-solution that promotes clean energy

options for New York’s transportation industry. An LCFS would set performance
standards that require fuel manufacturers and importers to reduce greenhouse gas
emissions associated with the petroleum-based fuels they make and sell, rightfully
shifting the burden to the companies who are profiting from these polluting products.

The LCFS would require high carbon intensity fuel providers to buy credits from those
producing and using low carbon intensity fuels such as electricity and renewable

biofuels. This provides a new revenue stream for the electrification of the state’s bus
and charging fleets and would further accelerate New York’s shift to clean forms of
energy across the transportation sector.

An LCFS will also spur a steady investment into non-petroleum fuels and renewable
technology, which is necessary to achieve economywide emissions reductions of 40%
by 2030 and 85% by 2050, as set out in the historic Climate Leadership and Community
Protection Act. Finally, an LCFS would significantly upgrade our air quality, improving
our environment and the lives of New Yorkers across the state, while creating in-state
jobs, supporting regional economic development and reducing out-of-state payments.

A New York LCFS program would create a dependable market for cleaner fuels, which
drives steady investment and innovation in the production and use of non-petroleum
fuel sources. The LCFS is a valuable tool to substantially reduce pollution and
emissions from the transportation sector. With the adoption of an LCFS, New York will
be well positioned to join other jurisdictions that already have adopted a similar policy,
including California, Oregon and British Columbia.

It will take a number of policy tools to achieve New York’s clean transportation future.
We urge you to advance an LCFS in the Executive Budget that will enable us to rapidly
reach our bold climate goals and provide resources necessary to push these goals


Julie Tighe Liz Hamlin

President Director of Advocacy in NY
New York League of Conservation American Lung Association
Nina Kapoor
Vignesh Gowrishankar Director of State Government Affairs
Assoc. Dir., Climate and Clean Energy Coalition for Renewable Natural Gas
Matt Tomich
Natural Resources Defense Council President
Energy Vision
Jeremy Martin
Senior Scientist and Director of Fuels Policy
Union of Concerned Scientists

Dan Bowerson Barry P. Carr

Director of Vehicle Electrification & Executive Director
Fuels Clean Communities of Central NY
Alliance for Automobile Innovation
Brett Barry
Anne Reynold Senior Policy Advisor
Executive Director Clean Energy
Alliance for Clean Energy New York
Jason France
Mbago Kaniki President, Founder, Sole Owner
CEO ClipperCreek, Inc.
Alva Charge
Ben Morris
Chris Kennedy CEO & Founder
Vice President of Marketing Coaster Cycles
Attis Innovations
Brad Carson
W. Spencer Reeder Sales and Marketing Director
Director, Government Affairs Complete Coach Works
Audi of America
Muffi Ghadiali
Steve Trichka Founder and CEO
VP/General Manager Electriphi, Inc.
BAE Systems
Joy Gardner
Ashley Beaty Clean Cities Coordinator
Vice President, Partnerships Empire Clean Cities
BTR Energy
John K. Bartow, Jr.
Vincent Pellecchia Executive Director
Strategic Account Manager Empire State Forest Products Assoc.
BYD Motors
Sara Rafalson
Eileen Wenger Tutt Director of Market Development
Executive Director EVgo
California Electric Transportation
Coalition Jigar Shah
President and Co-Founder
John Boesel Generate Capital
President and CEO
CALSTART Graham Noyes
Executive Director
Kevin George Miller Low Carbon Fuels Coalition
Director, Public Policy

Shelby Neal Senior VP, Gvnt. Relations & Legal

Director of State Government Affairs Affairs
National Biodiesel Board Proterra Inc.

Jeremy Baines Scott Hedderich

President Executive Director
Neste U.S., Inc. Renewable Energy Group, Inc.

Elizabeth Fretheim Steven Eisenberg

Head of Business Development CEO
Nikola Motor Company SRECTrade

Elizabeth Fretheim Kevin Neumaier

Head of Business Development & Managing Partner
National Accounts Sustainable Dairy Technologies
Nikola Corporation
Albert Gore
Daniel Gage Policy and Business Development
President Tesla
Mike Koel
Leonard Lincoln President
Director of Sales U.S. Gain
Odyne Systems, LLC
William Jorgenson
Mike Saxton Co-Founder and Counselor
Chief Commercial Officer Vanguard Renewables
Orange EV
Jeff McDaniel
Tom Koehler VP New Projects
Co-Founder Velocys
Pacific Ethanol
Michael Masquelier
Tom McCalmont CEO
Paired Power, Inc.
Dakota Semler
Gerald Conway CEO
General Counsel Xos Trucks
Plug Power
Paul Gioupis
Shailesh Sahay CEO
Senior Regulatory Counsel Zeem Solutions

Eric McCarthy