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WASHINGTON, Jan. 24 -- Schneider Electric has issued a public comment to the U.S. Environmental Protection Agency. The comment was written on Jan. 18, 2023, and posted on Jan. 19, 2023.

The comment was on Docket No. EPA-HQ-OAR-2022-0874-0001.

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Thank you for the opportunity to respond to this Request for Information (RFI). Schneider Electric (Schneider) as a company and the people who comprise our innovative teams are encouraged by the significant Federal investment in ports in the Infrastructure Investment and Jobs Act (IIJA) and the Inflation Reduction Act (IRA). As a company committed to the greening, electrification, and modernization of our U.S. ports, we believe programs like the IRA Clean Ports program will accelerate the transformation of our nation's system. Below, we have provided background on our company, our work to help ports, and recommendations that will help fulfill the intent of the Clean Ports program.

Background:

Schneider is actively engaging in creating strategic, innovative electrical and digital solutions designed to aid ports and terminals in reducing emissions and their reliance on fossil fuels. We believe that actions speak louder than words and are honored to share that we were named the most sustainable company in the world in 2021./1

We electrify, digitalize, and help manage energy use and consumption for homes, buildings, ports, airports, and water facilities. The bottom-line proof of our commitment is that all products we offer address the distribution, storing, or monitoring of energy with an overarching commitment to sustainability, resiliency, and improving energy use efficiencies.

Schneider Electric(TM) manufactures connected products and solutions that help ensure safer and more energy-efficient homes and businesses. Our connected products and world-class software work together to create more reliable and efficient residential and commercial buildings, data centers, and industrial plants. Our products and solutions are in one million buildings worldwide, including half of all hospitals, and 36,000+ water and wastewater installations. Whether we're investing in the electrification of our nation's highways, deploying resiliency solutions to combat grid disruptions, or reducing the energy consumption at the Ports of Los Angeles and Long Beach, we are actively shaping the new "energy + digital" landscape. This new landscape requires modernized supply chains and technologies. Our U.S. manufacturing hubs feature a best-in-class Smart Factory in Lexington, KY, with other hubs in El Paso, TX (expanding this year); Columbia, MO; Columbia, SC; Lincoln, NE; Smyrna, TN; and Seneca, SC - as well our global R+D facility in Andover, MA and our first smart distribution center in Athens, TX.

Ranked by Navigant as a best-in-class resilience provider, we are extremely encouraged and trust that microgrids, monitoring and control technologies, electrical equipment, battery storage, and demand-side/distributed energy resources (DERs) qualify as eligible solutions...

1 https://www.se.com/ww/en/about-us/newsroom/news/press-releases/world's-most-sustainable-corporation- 2021-60097a67785e6528940953a4

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...within the IRA Clean Ports program. We believe that our approach to grid-edge modernization, and our experience providing energy efficiency solutions, distribution management, and deployment of over 300+ microgrids across the country will fulfill the strategic goals of the IRA --facilitating clean energy deployment, advancing resiliency for the transport sector, and leveraging capital for infrastructure deployment for overall system resilience.

Port of Los Angeles

We are proud to have helped green some of our nation's largest ports and are actively seeking to help more midsize and small ports achieve these same carbon reductions. For example, we have supplied electrical distribution and control system infrastructure to the Port of Angeles (POLA) for over a decade.

In addition:

* Designing and implementing Shore-to-Ship Power; POLA documented as being the first in the world to implement such undertaking, significantly cutting emissions in ports by almost half. POLA's AMP System has been the baseline standard for designing green ports, not just in the US but also around the globe.

* Helping design a Test Project that involves Electric Truck Charging Infrastructure with Battery Energy Storage System for Load Shedding and Peak Shaving to compensate for peak demand during normal operating hours. This project could turn out to be a major capital project and could potentially be used as a baseline design for other ports.

* Introducing smart digital systems and automation, including monitoring technology and SCADA, allowing the port to monitor their power demand and make smart decisions with its operational expenditures.

Port of Long Beach

The Port of Long Beach (POLB) and Schneider have begun construction on a $12.2M microgrid project that will provide reliable, zero-emissions electricity for the port's Joint Command and Control Center. More information on this project can be found here. As noted in the article, microgrids provide a way for ports to minimize use of diesel generators, ports most common form of power backup.

We appreciate the opportunity to address the issues raised below and committed to the decarbonization of our port ecosystems. We look forward to connecting with EPA around these topics in the future and applaud its leadership towards the energy efficiency and renewable energy goals of the Inflation Reduction Act of 2022. We actively participate in clean energy advocacy as a member of the American Association of Ports (AAPA), Gridwise Alliance, National Electrical Manufacturers' Association (NEMA), Microgrid Resources Coalition (MRC), Business Council for Sustainable Energy (BCSE), Rewiring America, Digital Climate Alliance, and the Alliance to Save Energy (ASE).

Grants to Reduce Air Pollution at Ports [60102]

1. How can EPA structure this program to reduce air pollution in port communities and accelerate long-term trends to decarbonize the nation's ports?

Two ways may be considered: 1) make this a Program Grant initiative vs a Discretionary Grant initiative2 and 2) define eligible applicants as including private port terminal operators. Doing so can accelerate results and benefits across many regions of the United States. While awarding competitive grants to public ports and other entities is common among discretionary grant programs, doing so encourages regional competitions. For example, a public applicant may have to choose which of its private marine terminal tenants to work with, or a State may have to prioritize one regional port over another when applying grant award funds (many states such as California, Louisiana, Texas, and Florida have more than 10 ports within their borders). Our nation has 150 significant ports at which less than 30 large private marine terminal companies operate. Permitting eligible applicants for this grant program to include private marine terminal operators who lease land from public entities will more efficiently address multiple locations across the nation. For a map of significant ports in our nation, and the terminals operators located there, see each State in the Congressional Map at: https://nawe.us/nawe-member- congressional-district-map/#

2. How do you see the IRA ports program complementing other programs (e.g., at EPA and the Department of Transportation) that can support efforts to reduce emissions at ports? What funding gaps can this program fill (e.g., specific zero emissions technologies or related planning support)?

Many of the USDOT programs have minimum award limits, which do not permit smaller projects to be addressed. For example, of the $703M awarded through the Port Infrastructure Development Program, only five were for amounts below $5M. In addition to technology and...

2 Program Grant: A program grant is any grant awarded to fund a specific project, initiative, or service. These are typically competitive and may be awarded to regional, State, or local government agencies, nonprofits, or private companies. Program grants are often considered a subset of categorical grants.

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...service gaps covered by other programs, a portion of the program should be dedicated to smaller funding needs. Development of a detailed and strategic plan that establishes goals, implementation strategies, and accounting and inventory practices to reduce greenhouse gas emissions and other air pollutants at one or more ports can cost between $75,000 and $250,000. We are hopeful that the Clean Ports program can incentivize ports to think long-term in their planning needs and pair existing DOT program money and application with carbon reduction investments.

3. The Inflation Reduction Act ports program can fund the development of climate action plans as well as zero emissions port technology, equipment, and related planning and permitting. How would you like to see the action plans and infrastructure funding work together? Should they be sequenced or combined?

Both options should be offered. While some applicants may already have a plan in place or may be able to fund both the planning and infrastructure necessary to bring a plan to life, it may be that an applicant will need to phase the implementation of a plan due to funding, permitting, or other external requirements. In addition, EPA should provide technical assistance in helping small and midsize ports develop initial climate action plans.

Climate action plans must address resiliency, especially as our nation's ports and port communities are disproportionally impacted by severe weather. We appreciate that a port can include resiliency measures, but believe this must be required as part of a qualified climate action plan. Even if a port achieves zero emissions, equipment and grid equipment must have backup power and resiliency if and when the larger grid experiences cybersecurity attacks, power outages, or damage from extreme weather. Back-up power and weatherization of equipment are needed when a freeze immobilizes the grid in Texas (as happened in the Winters of 2020 and 2021), when wildfires impact the grid in California, when hurricanes shut down the grids in the Southwest and the Gulf, when artic bombs hit the Northwest, and when droughts hit the Midwest. Each of these has shut down one or more ports for multiple days at a cost to regional economies of up to $1B per day. We respectfully suggest EPA allow for resiliency planning so ports and terminals can reach zero-emission goals while sustaining the capability to continue operations if the grid fails.

4. What types of zero-emission port technologies or related planning support do you see as most critical for delivering emissions reductions?

* Ship-to-shore technology (shore power for vessels at berth)

* Electric grid infrastructure, including substations, switchgear, building facility electrification Microgrid with clean energy sources as an integrated system (solar, storage, fuel cells, etc.)

* Electric vehicle infrastructure including software management of chargers and electrical support

* Software/digital technologies that track, manage, and eliminate energy waste and inefficiencies (Ecostruxure)

* Planning support: allowing Energy as a Service and other public-private partnerships to help with energy deployment

* Sustainability consulting to help develop net zero plans for ports

5. What do you see as the biggest hurdles to transitioning to zero-emission port equipment? In our experience as a trusted advisor for communities and businesses that provide solutions for zero-emission planned projects, we find these are the top hurdles:

(A) The definition of zero-emission as it relates to this new program is unclear and likely too stringent. We suggest that EPA examine and consider the definition in the US Code for airport equipment: (3) Zero-emission vehicle -- The term "zero- emission vehicle" means-- (A) a zero-emission vehicle as defined in section 88.102-94 of title 40, Code of Federal Regulations; or (B) a vehicle that produces zero exhaust emissions of any criteria pollutant (or precursor pollutant) under any possible operational modes and conditions. Could a port terminal that powers cargo handling equipment by electricity meet zero-emission goals if its utility generates electricity through natural gas, nuclear, or coal-fired powered plants? Many utilities that provide power to ports and terminals cannot accommodate the capacity needed to become a zero-emission facility or do not have policies yet incentivizing the move to a zero-emission system.

(B) Repowering existing equipment and vehicles is expensive - especially in this time of inflation, global supply chain issues, and the life cycle of existing equipment. Our recommendation is that EPA counsel interprets "zero emission port equipment and technology" to fully encompass the full panoply of human- maintained technology and fixed assets such as electric grid hardware and digital infrastructure. The clean energy transition is impossible without electrical grid upgrades, equipment, building automation systems, and integrating solar and storage resources such as microgrid systems. Moreover, digital technologies measure, monitor, and help decrease energy usage. Without a full digital port ecosystem (the port of the future) monitoring the massive energy consumption and use at a port, we cannot even determine if the port has achieved a net zero or carbon neutral status.

(C) Domestic Content Requirements/Buy America: Large, electrified cargo handling equipment such as ship to shore cranes, rubber-tired gantry cranes, and rail-mounted gantry cranes are not manufactured in the U.S. Strict enforcement of Buy American procurement rules would significantly hamper this program's ability to meet its objectives. Further, the Department of Transportation (USDOT) acknowledged the lack of domestic manufacturing when granting a waiver to the Port of Philadelphia to electrify their ship-to-shore cranes. Applying domestic preference requirements to this program would mean that ports could not use grant funds to replace their largest - and highest emission equipment with electrified equipment. We support the American Association of Port Authorities' request that the EPA refrains from or limits the application of domestic preference requirements for equipment purchases made under this program.

6. How can we help ensure this program addresses the concerns of near-port communities and advances environmental justice?

The top concerns of near-port communities include:

* high incidence of lung diseases such as asthma in children caused by emissions generated by equipment and vehicles used within a port,

* idling of trucks in a queue within a neighborhood while waiting to enter through port gates, and

* spotting (temporary parking) of containers or flatbeds with loads outside of port gates, thereby clogging streets and residential parking spaces.

* Ensure that environmental justice is a component of climate action plans.

We respectfully suggest that EPA set aside a portion of the funding to prioritize project applications that offer to address the top listed item. The other two items are addressed through several US Department of Transportation discretionary grant programs.

Thank you again for the opportunity to respond to this RFI. Please do not hesitate to contact us with any questions or comments on our response.

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Original text here: https://downloads.regulations.gov/EPA-HQ-OAR-2022-0874-0046/attachment_1.pdf