2/28/2020 |
Judith |
Dieckmann |
Citizen |
Brooklyn |
New York |
I live in NYC where most people travel by public transportation but where there is also a severe car crisis. I would propose making it a cost to drive recreationally, institute residential parking... read more I live in NYC where most people travel by public transportation but where there is also a severe car crisis. I would propose making it a cost to drive recreationally, institute residential parking permits, put idling spots in every neighborhood so the e-economy of having *everything* delivered results in less pollution and traffic issues, upgrade and increase public transportation so it's less unpleasant/unpredictable, mandate regular car care with subsidies for those with lower incomes, make it cheaper not more expensive to get a hybrid/electric car, and create delivery windows for large trucks so they aren't causing constant backlog traffic choking fuel belching pollution fests. |
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2/28/2020 |
Jane |
Dilley |
Ms. |
West Grove |
Pennsylvania |
I believe the proposed TCI is a useful starting point for action on carbon reduction but not nearly aggressive enough. To actually effect a critical reduction in VMT the "price at the pump... read more I believe the proposed TCI is a useful starting point for action on carbon reduction but not nearly aggressive enough. To actually effect a critical reduction in VMT the "price at the pump" needs to start higher with assurances it will go even higher.
There should be explicit measures to address the inequitable hardship on low-income and rural households using some portion of the auction income to cushion this inequity. I hope Pennsylvania will join in this regional effort. |
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2/28/2020 |
Christine |
Erb |
Citizen |
Lanesborough |
Massachusetts |
Please limit pollution from motor fuels and keep our air cleaner. Please limit pollution from motor fuels and keep our air cleaner. |
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2/28/2020 |
James |
Rooney |
Greater Boston Chamber of Commerce |
Boston |
Massachusetts |
Dear Governors of the Northeast and Mid-Atlantic States,
I am writing on behalf of the Greater Boston Chamber of Commerce regarding the Draft Memorandum of Understanding of the... read more Dear Governors of the Northeast and Mid-Atlantic States,
I am writing on behalf of the Greater Boston Chamber of Commerce regarding the Draft Memorandum of Understanding of the Transportation and Climate Initiative (TCI). The Chamber shares TCI’s goal of reducing greenhouse gas emissions in the transportation sector and supports the broad framework that has been proposed. Accordingly, our comments are intended to inform the development of the final TCI program design. The Chamber urges you to develop TCI so the region sees emissions reductions that are substantially lower than business-as-usual (BAU) projections, to include a secondary market for emissions allowance trading, and so that the program design does not include perverse incentives to maintain high emissions in order to preserve a revenue source.
Projected Emissions Reductions
To rationalize the development of TCI, it is imperative that the benefit of creating a new regional market on transportation emissions is significant enough to justify the cost, both real and administrative. The final TCI program design should result in emissions reductions that are substantially lower than BAU projections. The 2019 TCI modeling and sensitivity analysis project emissions reductions of 6% to 19% under a BAU scenario between 2022 and 2032. Meanwhile, the three proposed caps for the TCI program would result in emissions reductions for that time span of 20%, 22%, or 25%, including the anticipated BAU reductions. As structured, the program would result in a potentially minor reduction in emissions that may not make the cost increase seem worthwhile.
Secondary Market
The draft MOU briefly describes the monitoring of the proposed carbon market and the administration of allowance auctions; however, no reference is made to a secondary market for emission allowance trading outside of the auctions. Other market-based cap-and-invest programs, including the Regional Greenhouse Gas Initiative (RGGI), allow for trading of emissions allowances on a secondary market. The Chamber strongly urges the TCI framers to include a set of provisions in the final MOU and the model rule for a secondary market permitting the sale of emissions allowances among regulated entities and third parties.
Including a secondary market in the TCI program is important for multiple reasons. First, a secondary market increases program flexibility by allowing regulated entities to purchase additional allowances to meet program obligations or to sell excess allowances. In addition, a secondary market provides the ability to sell or obtain allowances in between auctions, ensuring that allowances are liquid, and the carbon market remains stable. Finally, a secondary market will promote innovation among regulated entities by incentivizing firms to increase efficiency or upgrade technology in order to reduce emissions. Doing so will allow them to sell and profit from the unused allowances they purchased at auction.
Program Integrity
TCI is dependent on a declining cap for transportation emissions and the associated allowances that are auctioned to regulated entities. Because states’ allowance proceeds derive from these auctions, it is important that the final MOU and model rule account for the perverse incentive to maintain high emissions to sustain a revenue source. TCI proceeds can result in substantial and beneficial public investment but should not viewed as a permanent or increasing source of revenue.
Thank you for your consideration. We urge you to continue working collectively as a regional coalition and look forward to assisting you as you develop the final iteration of TCI. Please do not hesitate to contact me if you have any questions.
Sincerely,
James E. Rooney
President and CEO
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02-28-20 TCI Comment Letter.pdf |
2/28/2020 |
Nathan |
McFarland |
Generation180 |
Charlottesville |
Virginia |
I'm grateful that Virginia is working on reducing transportation emissions—it's time to make bold moves. Given that transportation is Virginia's top source of greenhouse gas... read more I'm grateful that Virginia is working on reducing transportation emissions—it's time to make bold moves. Given that transportation is Virginia's top source of greenhouse gas emissions, we should consider more aggressive goals (i.e. greater than 25% reduction) and prioritize zero tailpipe emissions investments. Let's make it happen! |
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2/28/2020 |
Samantha |
Gill |
Miss |
East Falmouth |
Massachusetts |
I support the idea of reducing carbon emissions. We need to take better care of our air to stay healthy, and reduce our negative impact on the environment. I support the idea of reducing carbon emissions. We need to take better care of our air to stay healthy, and reduce our negative impact on the environment. |
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2/28/2020 |
Dannielle |
Lipinski |
Maryland LCV |
Annapolis |
Maryland |
This is a letter from 147 Maryland LCV Supporters who signed a petition in support of TCI and the following: attached are their names and cities.
To Whom it May Concern: ... read more This is a letter from 147 Maryland LCV Supporters who signed a petition in support of TCI and the following: attached are their names and cities.
To Whom it May Concern:
I am a strong supporter of the The Transportation and Climate Initiative (TCI), a collaboration of twelve states and D.C. that would cap transportation emissions and auction emissions allowances. This is a once in a generation opportunity to reduce greenhouse gas emissions and raise much needed revenue to modernize our transportation system on a regional scale.
As a Marylander, I thank Governor Hogan for his leadership in supporting TCI and request that Maryland formally join the program. We ask that leaders of the TCI choose the most aggressive greenhouse gas reduction targets- as current scientific studies show that we need.
We also urge that the policy prioritizes clean investments in all of Maryland's communities overburdened by pollution and for those who do not have access to transportation choices.
Thank you for your time,
Supporter |
Maryland LCV Supporters for TCI.pdf |
2/28/2020 |
Richard |
Reis |
Mr. |
Silver Spring |
Maryland |
TCI is very important for Maryland and for the world, because climate change is real and it's having an increasingly negative impact on our lives and on the environment. Because... read more TCI is very important for Maryland and for the world, because climate change is real and it's having an increasingly negative impact on our lives and on the environment. Because transportation is the leading emitter of greenhouse gases, it's really essential that we work collaboratively through TCI to reduce greenhouse gases and to leave a sustainable world for future generations. |
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2/28/2020 |
Patrick |
Mckenzie |
none |
milton |
Vermont |
Support TCI. We need to do everything possible to protect our planet. Support TCI. We need to do everything possible to protect our planet. |
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2/28/2020 |
Mary |
Slaughter |
Ms |
Silver Spring |
Maryland |
I vehemently oppose the proposed widening of I495, I270, and building a third Bay Bridge. As a native Californian, I have repeatedly experienced the increased congestion that inevitably follows... read more I vehemently oppose the proposed widening of I495, I270, and building a third Bay Bridge. As a native Californian, I have repeatedly experienced the increased congestion that inevitably follows road expansion. Let's learn from their experience and build our public transportation.
In addition, widening and building roads will removed huge numbers of trees that help to mitigate climate change. We should be planting trees instead of cutting them down. Let's get out of our cars and go public! |
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2/28/2020 |
Andrea |
Ferguson |
None |
Granby |
Massachusetts |
I am concerned about reducing pollution from transportation. I am grateful to Governor Baker for his leadership and request that Massachusetts formally join the program. I ask that leadership... read more I am concerned about reducing pollution from transportation. I am grateful to Governor Baker for his leadership and request that Massachusetts formally join the program. I ask that leadership chooses the most aggressive greenhouse gas reduction target that the most recent climate science tells us we need. I urge that the policy prioritizes clean investments in areas overburdened by pollution and/or for those who don’t have access to transportation choices. |
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2/28/2020 |
Terry |
Williams |
Rutland Regional Planning Commission |
Poultney |
Vermont |
I agree with the Transpiration Climate Initiative in concept, but not with the timing of it. Vermont is one of the most environmentally clean states already and will struggle to meet the goals... read more I agree with the Transpiration Climate Initiative in concept, but not with the timing of it. Vermont is one of the most environmentally clean states already and will struggle to meet the goals set by this plan. I include the following comments:
I. In Rural Vermont, this tax (that you say is not a tax) is discriminatory and will place an undue burden upon most lower and middle class citizens who are already working two jobs to make ends meet and pay their taxes. This initiative will drive more businesses and people out of Vermont.
II. Even with the incentive that Governor Scott has added to his budget to enable Vermonters to purchase an electric or hybrid vehicle, most Vermonters will not be able to afford to get out of their current car payment (usually a car with 150K miles on it that they are working another job to pay for) and purchase a new, electric vehicle. Also, there are no used electric or hybrid vehicles on the market now.
III. There is not an adequate mass transportation system available to enable people to get to Rutland to work an off shift. Even if there were, if someone was required to work an additional shift to provide additional funding support for their family, the current system doesn’t operate after 8:00 PM.
IV. Now that NH has dropped out of the regional initiative and NY has not committed to it, when the price of gasoline and diesel goes up because of TCI, Vermonters will simply go to those states to buy their fuels. You are naive to think that you will be able to force people to comply with your initiative. You probably haven’t noticed that fuel stations in the states along the Vermont border have been adding more gasoline pumps in anticipation of this CARBON TAX!
V. I understand that there is a plan for Vermont to sell carbon credits for businesses who don’t comply with this initiative. I also understand that the forests of our state which sequester the carbon will be used to calculate this carbon off-set. 89% of Vermont forest land is privately owned. You can’t sell carbon credits from trees that you don’t own. I own 250 acres of timber land. I asked the question last night; “Will the state pay me for my trees and the carbon they sequester” and was told that I didn’t own enough to be considered. I was also told that maybe if I joined with adjacent property owners to combine our acreage, that maybe the initiative would provide some offset to me. This seizure of property rights in unconstitutional and will not be allowed.
In 35 years we will run out of fossil fuel and we will have developed the technology to be mobile and competitive in a new world economy. Why do we have to comply with an unreasonable, futuristic standard now? We have already cut emissions and found alternative methods of going to meeting through advances of the internet. Workers are now able to telecommute to work and stay at home, work and care for their young children in the process.
Why don’t we develop a plan for phasing out the internal combustion engine over the next 10 years and let technology advance along the way so that when we get to the point of no fossil fuel, we can have everyone on board with the new plan? We can do this for the next 10 years as technology advance and our forests continue to sequester carbon from the other pollution sources in the world.
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2/28/2020 |
john |
phipps |
Environmental Advocate |
Southbridge |
Massachusetts |
My normal response to anyone who is not Environmentalist is to become an Environmentalist, then you will truly see how endangered our once beautiful Planet is and what we should do to make our... read more My normal response to anyone who is not Environmentalist is to become an Environmentalist, then you will truly see how endangered our once beautiful Planet is and what we should do to make our Planet's Environment clean and safe again. |
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2/28/2020 |
Brydon |
Ross |
Consumer Energy Alliance |
Louisville |
Kentucky |
To whom it may concern,
Attached are comments on behalf of Consumer Energy Alliance concerning the Draft MOU of the Transportation Climate Initiative. We appreciate the opportunity to... read more To whom it may concern,
Attached are comments on behalf of Consumer Energy Alliance concerning the Draft MOU of the Transportation Climate Initiative. We appreciate the opportunity to provide our feedback. |
CEA TCI Draft MOU Comments 2.28.20.pdf |
2/28/2020 |
NK |
Acevedo |
none |
Boston |
Massachusetts |
make our communities healthier and more prosperous. make our communities healthier and more prosperous. |
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2/28/2020 |
Lola |
Chaisson |
Ms. |
CONCORD |
Massachusetts |
I want to thank Gov. Baker for his support to date in this area and urge that we formally join the regional initiative. I am a regular user of the bike trails around me, and wish there were one... read more I want to thank Gov. Baker for his support to date in this area and urge that we formally join the regional initiative. I am a regular user of the bike trails around me, and wish there were one that connected my house and my studio. There are places however with much greater need in the state, where cars sit unmoving in traffic but there is no safe alternative for walking or biking. Think of how much you can improve the finances of a family if a car is not a necessity while also improving air quality and lessening detrimental environmental impacts. Every small step in the right direction is a good thing. |
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2/28/2020 |
Dennis |
Casey |
Casey & Associates |
Groton |
Vermont |
I support TCI. Fossil fuel companies have been too slow to research and develop alternative fuels and this could help that process. I also think that we have a lot to gain from the investment of... read more I support TCI. Fossil fuel companies have been too slow to research and develop alternative fuels and this could help that process. I also think that we have a lot to gain from the investment of funds that Vermont will receive. Developing alternative transportation modalities, improving the ability to live closer to town centers and helping Vermonters to see the benefits of driving more fuel efficient vehicles are critical and can be assisted by TCI. |
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2/28/2020 |
Peter |
Caesar |
Raise Up |
Newburyport |
Massachusetts |
Emphasize conservation replacement of fossil fuel use, adhere to Obama Era mileage standards, shift resources to public transit upgrades Emphasize conservation replacement of fossil fuel use, adhere to Obama Era mileage standards, shift resources to public transit upgrades |
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2/28/2020 |
David |
Fitzpatrick |
Voting citizen |
Wayland |
Massachusetts |
Climate change is a pressing issue being ignored at the Federal level. It is critical that state, communities, corporations, and individuals take action. Climate change is a pressing issue being ignored at the Federal level. It is critical that state, communities, corporations, and individuals take action. |
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2/28/2020 |
Christian |
Herb |
Connecticut Energy Marketers Association |
Naugatuck |
Connecticut |
February 28, 2020
The Connecticut Energy Marketers Association’s (CEMA) motor fuels members own, operate and distribute gasoline to approximately 1,000 convenience stores in the... read more February 28, 2020
The Connecticut Energy Marketers Association’s (CEMA) motor fuels members own, operate and distribute gasoline to approximately 1,000 convenience stores in the state. Our members own property in virtually every municipality, pay local and state taxes, employ thousands of people, and play a vital role in Connecticut’s economy.
While electric vehicles (EV’s) may be an attractive way to lower emissions, it appears that more consideration needs to be given to several factors that will have an impact on jobs, the economy, property values, electric reliability, emissions and family owned businesses. But, it is essential that TCI does not pick winners and losers by allowing regulated utilities to unfairly use their monopolistic status to overpower private businesses that depend on free market forces to support economically viable alternatives to electricity. Allowing massive (and in some cases foreign owned) utilities to do this would be unfair, it would destroy competition, and drive local family owned companies out of business taking with them thousands of jobs.
Allowing monopolies with a guaranteed rate of return to control EV charging would not only discourage private companies from investing in future alternative fuels, but it would also have a detrimental effect on their ability to maintain the current infrastructure that motorists depend on.
Over the past decade, federal policies such as the Renewable Fuel Standard (RFS), the Biodiesel Blenders Tax Credit, and others, have created incentives for fuel retailers to invest in infrastructure necessary to bring cleaner burning fuels to the market. Our members support policies that encourage a vibrant and competitive market that will deliver the most efficient prices to the public, but if electric utilities are allowed to exercise TCI and government granted power in the motor fueling space, private businesses will not be able to compete.
TCI needs to examine a regulatory landscape which encourages fuel retailers to invest in alternative fuels before generations of investment in thousands of locations throughout the state are irreparably harmed. We have one chance to get this right, or a major segment of the economy will be decimated.
While utilities need to play a role as EV’s enter the market, they should be focused on grid enhancements, distribution upgrades (ie. line extensions), cyber security and other issues to ensure that the “lights stay on” as demand for electricity grows - these are fundamental to the reason that they have been granted monopoly status. TCI should seek and support pathways that leverage the current fueling
network that has been privately developed to bring alternative fuels to consumers - not tip the scale in favor of electricity.
TCI also needs to be cognizant of the impact that the “electrify everything” policy that the state is pursuing will have on grid reliability, the cost electricity, and emissions.
Attached is a spreadsheet the looks at the need to add electricity supply if EV’s replace gasoline and diesel fuel for transportation purposes and the replacement of heating oil and natural gas for heating. In Connecticut, Governor Lamont’s Executive Order number three seeks to achieve zero emissions in the electric sector by 2040, coupled with the need for additional electricity capacity to meet the demand that EV’s and electric heat pumps will add to the grid is going to place immense pressure on the need for renewable energy generation.
To do that we need to look at what it would take for wind and solar to meet this goal. It is a fact that solar and wind electric power farms are much more land intensive than oil, gas, or nuclear power plants. For example: “Wind farms require up to 360 times as much land area to produce the same amount of electricity as a nuclear energy facility, a Nuclear Energy Institute analysis has found. Solar photovoltaic (PV) facilities require up to 75 times the land area.” https://www.nei.org/news/2015/land-needs-for-wind-solar-dwarf-nuclear-plants. It’s simply the nature of the science and engineering behind wind and solar plants that they are land intensive.
Given TCI goals and that the state of Connecticut wants to move entirely to renewable power plants, specifically wind and solar, for electricity generation, it’s reasonable to ask how much land such plants would consume.
SOLAR
Let’s look at solar first. Connecticut has a large solar farm currently in Somers, CT. https://en.wikipedia.org/wiki/Somers_Solar_Center It has a capacity of 5 MW of electricity, and covers 50 acres of land. According to ISO-New England, Connecticut power plants have a nameplate capacity of 8,700 MW https://iso-ne.com › grid_mkts › key_facts › final_ct_profile_2013_14
Doing the math, Connecticut would require some 1,740 solar farms the size of the one in Somers to replace all existing electric power capacity in the state, and doing another calculation, this would require some 87,000 of land use. This land area is equivalent to the total sum of all the land taken up by the cities of Hartford (11,490 acres), Bridgeport (12,400 acres), New Haven (12,870 acres), Waterbury (18,530 acres), New Britain (8,576 acres), New London (6,886 acres) and Meriden (15,440 acres).
WIND
Wind power plants come in two forms, onshore and offshore.
- Onshore
For our onshore example, we look at the Sheperds Flat wind farm in Oregon, the world’s fifth largest onshore wind farm. https://www.power-technology.com/projects/shepherds-flat-wind-farm-oregon/
This wind farm has a capacity of 845 MW and covers some 80 square kilometers. We calculate that 10.3 such wind farms would be needed to replace CT’s 8,700 nameplate capacity, and these would span some 823.7 square kilometers. As Connecticut consists of 14,360 km in area, more than twice the area of the solar plant described above.
- Offshore
Since solar and onshore wind power plants take up so much land space, perhaps an offshore wind plant in Long Island Sound would be preferable. After all, there are no homes or businesses to disrupt out in the Sound.
The world’s largest offshore wind power plant is the Walney Extension wind farm off the coast of England. https://www.power-technology.com/features/largest-offshore-windfarm-world/ Unfortunately, as we shall see, the news isn’t good. The British wind farm has a capacity of 659 MW and is spread over 145 sq. kilometers in the North Sea. To replace CT’s 8,700 nameplate capacity, we’d need some 13.2 Walney-sized windfarms which would cover an expanse of 1,914 sq km of Long Island Sound. But the Sound only covers 3,056 sq km. In other words, this huge wind farm would choke off Long Island Sound, covering 62.6% of its entire surface area. This would mean a wind farm covering every square meter of Long Island Sound from the New York border to Rhode Island, and penetrating from a few miles into the sound at its narrowest point, to over 100 miles at its widest point.
Connecticut and TCI should be cautious before committing to entirely replacing Connecticut’s current power capacity with wind and solar power plants to accommodate EV’s. There are physical constraints to making such wholesale conversion possible. In the meantime, Connecticut can transition to a net-carbon zero energy source in the heating sector, elevating the need to put any additional burden on the existing electric power grid, through the use of biodiesel. Why further burden the grid by adding electric heat pumps, when electrons can be saved with liquid fuels that can deliver on emissions reductions that help the state comply with the greenhouse gas reductions required under the Global Warming Solutions Act? Since biodiesel and renewable diesel can be used as a transportation fuel (along with other low carbon fuels), the state can significantly reduce demand on the grid and significantly lowering emissions by utilizing the potential of local businesses to sell low/net zero liquid fuel to the public.
We know that Connecticut is concerned about increasing what are already the highest electricity rates in America, and as business owners we are troubled about the impact that potentially billions of dollars in ratepayer investment that will be needed to upgrade the grid to accommodate TCI goals, subsidizing new clean electric generation sources to accommodate those goals, the subsidization of EV infrastructure, and EV incentives will have on rates. We believe that TCI should put as much effort into finding low carbon/zero carbon liquid fuels, that utilize existing infrastructure that has been privately developed, as they are into electrification of the transportation sector.
Before Connecticut has even adopted any of the costly suggestions that have been made by EV industry advocates, Eversource customers will pay 15.8% more for electricity in 2020 and United Illuminating (UI) customers will realize 26.4% increase (which equates to average customer using 750 kilowatt hours a month paying $9.65 and $16.55 more per month with Eversource and UI respectively)! Connecticut needs to factor costs in and “right size” their electrification plans before fixed income and low-income families are disproportionally affected by the proliferation of EV’s and the infrastructure that comes with TCI’s plans. TCI needs to address the question of who benefits from all the costs that go into creating an EV future for Connecticut and the region, and needs to avoid the mistakes that have advantaged the wealthy over low and middle income families.
Of the 57,066 households that received the federal EV tax credit in 2016, 78% had at least a six-figure income and 7% reported more than $1 million in income, while less than 1% of all EV credits went to households earning less than $50,000 in 2014, meaning that about half of Americans receive virtually no benefit from the credit. EV manufactures data shows that EV’s are overwhelmingly benefit the wealthy. Tesla’s customers have an average household income of $293,200 while even the buyers of the more modestly-priced electric Ford Focus have an average income of $199,000. On top of the EV tax credit, electric cars owners don’t pay gas taxes to help support the roads they use, shifting more of the burden onto other drivers, contributing to a funding deficit that support our roads and bridges. PURA should not create incentives to purchase EV that will only benefit citizens who would be able to afford them without it.
TCI also, has to ask the question are we trading one type of pollution for another? Much of the literature noted that EV’s emit less CO2 than traditional internal combustion powered engines (ICE). However, the makeup of the electric grid plays a role in the release of other gaseous pollutants and particulates. According to Weeberb J.Requia’s “How Clean Are Electric Vehicles? Evidence-based Review of the Effects of Electric Mobility on Air Pollutants, Greenhouse Gas Emissions and Human Health”, in China, even with an electric grid largely powered by coal, EV’s decrease CO2 emissions by 20% compared to ICE’s. However, in the same study, emissions of PM10, PM2.5, NOx, and SO2 emissions increased 360%, 250%, 120% and 370%, respectively.
The environmental impact of EV batteries cannot be ignored and needs to be a part of PURA plan. Li-ion battery production primarily occurs in China and South Korea, whose electricity mix is generally carbon-
intensive. Han Hao’s “GHG Emissions from the Production of Lithium-Ion Batteries for Electric Vehicles in China.” (April 4, 2017) showed that the GHG emissions were nearly 30% higher than those for comparable ICE’s. EV battery materials impact the environment in different ways. Batteries that use large amounts of aluminum LiMnO2 and LiFePO4, for instance, have a greater impact on ozone depletion. At the end of the day, TCI needs to factor in the environmental impact of EV batteries and their disposal. A lifecycle analysis of EV and the infrastructure needed to support them needs to be done comparing them to low emissions liquid fuels before ratepayers are burdened with more costs and environmental issues.
Finally, the current electric grid is not clean and adding EV’s (and electric heat pumps) to it will only exacerbate the need for natural gas to ensure that we have enough power to support current demand and the additional demand that EV’s will create. According to Gale Ridge, PhD, a scientist and researcher, “In a one month period, we found about 700 [natural gas] leaks in Hartford. Over a one year period covering the same area, PURA reported 139 leaks. Even recognizing that some of the leaks we found are known to PURA, that’s about a 5 fold difference. We believe that CNG may be missing a large percentage of its leaks.” Current overreliance on natural gas is clearly causing greater methane and CO2 emissions and a massive expansion of EV’s in Connecticut will only drive more emissions for a grid that depends on natural gas to power the state. PURA should not move forward with any plan to electrify the transportation sector until they can verify that the electricity that is being use to power EV is truly emissions free.
We urge TCI to address all of these issues before a final plan is proposed to Connecticut.
Respectfully,
Christian A. Herb
President
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TCI Final Comments 2_28_20.pdf |