TCI Regional Policy Design Stakeholder Submissions

Please see the attached file for comments on the Draft MOU, and the modeling results webinar in December 2019. Thank you for the opportunity to provide feedback.

As a physician, I am fully in support of this initiative to reduce greenhouse emissions & invest in public & private transportation that does not emit carbon. The infrastructure to support this can be funded through a cap and invest program. The benefits of “clean” transportation will decrease expenditures in health costs. Recent research reveals a correlation between hospitalizations and deaths attributable to local levels of air pollution. The benefits of this initiative are well beyond just greenhouse emissions.

The TCI Would be Beneficial for Vermonters With a Grain of Salt
As an environmental studies student in Vermont, I have learned extensively about the climate crisis happening today while experiencing what transportation is like in a rural state. I believe that this transportation initiative, while not a final or extensive enough solution for all of the issues regarding climate change, would begin to make a difference so long as marginalized communities are taken into account properly. According to the U.S. Energy Information Center data collected in 2017, transportation is the leading emitter of CO2 from the area encompassed by the TCI proposal, making this an important sector to target as they have bee left out of past initiatives, such as RGGI. Simply by taking a step to reduce these emissions, these areas can demonstrate a clear commitment to the mitigation of climate change and make a significant difference. This plan may be extremely helpful in actively participating in the climate change movement, but it needs to keep in mind the idea of environmental justice while doing so in order to be an effective and beneficial program.
The section in the TCI Memorandum of Understanding regarding “equity” and the language around disadvantaged communities are minimal, leading to reasonable concern that the vagueness of this initiative will lead to further marginalization of low-income or underprivileged communities. While this plan of “cap and invest” could be extremely helpful in discouraging the emission of CO2 and collecting money to use for other climate change mitigation tactics and improvements to infrastructure, there can be concern that those who are the least able to pay would be bearing the brunt of this fee. However, because of the invest concept, these groups of Vermonters could experience great rewards in addition to climate change mitigation if the investments are used for things such as increased public transport or other programs that improve life quality.
The California Climate Investments project, which enacted a similar cap and investment policy in 2015, was able to invest $690 million dollars in priority populations in 2019 alone. These investments went into projects including affordable housing, zero-emission vehicles, and “improved mobility options;” all of these concepts could be extremely helpful to people who would be subject to higher prices for gas due to the cap portion of this plan. The affordable housing options could help create more urbanized centers that would allow for easier mobility, which is a goal emphasized in Vermont’s plans for transportation improvement. Increased access to zero-emission vehicles and improved transit systems would directly assist people who may already be suffering from lack of transportation access.
Because Vermont is such a rural state, many individuals rely on private transportation methods to go to work or school. A report in 2015, however, by the Vermont Transportation Board, reported that driving habits in Vermont decreased by 8.4% from 2007 to 2015, showing that the number of people driving single occupancy vehicles has been decreasing. While there may be varying reasons for this decline, it indicates that there may be a need for an increase in public transportation infrastructure, including extended bus routes. The investment aspect of the TCI plan could be extremely beneficial in providing this needed increase in public transportation. Therefore, a key aspect of making this initiative successful and equitable would be requiring these beneficial investments to be made within a reasonable time from when people begin to be impacted by the increasing prices.
Because transportation is a huge emitter of CO2 in the proposed TCI region, targeting this aspect of infrastructure is key to both making a difference and demonstrating commitment to climate change mitigation. However, this is where the grain of salt comes in as I believe that this proposal would benefit from a more specific policy regarding the use of funds raised by the cap and investment proposal. If the TCI or the states involved in the agreement were to specify options for where the funds would be used and determine how to best mitigate the time-lag that could occur between increased prices and providing funding for beneficial programs, then the TCI would be a much stronger proposal that could help people in more ways than one. Overall, this program should be supported with the understanding that the vague language leaves room for and also a need for an environmental justice aspect.

In theory this would work great to cut down unnecessary travel in cities but as a family that lives in northern Maine-where everything is distance related-then this adds a cost that a lot of us can’t afford. My husband works a job that requires him to drive from our home in Lincoln to all areas of northern Maine up to the Canadian border. He does this on average 4 days a week. We bought a car with good gas mileage to help with the costs but an extra 17 cents/gallon will be a huge expense for us and an electric car is not practical for our area and the distance he travels. Most of the people making these suggestions have never lived where everything is not readily accessible by a short jaunt or a bus ride. Public transportation is nonexistent where we are and you can’t just “walk” to the nearest store. Please consider this as you make decisions for the ENTIRE state-we’re not all city folk!

Attached are Toyota's comments regarding the TCI Draft MOU. Please let us know if you have any questions. Kind regards.

Washington Gas, which has about 765 vehicles in its fleet, supports the growth and development of − and transition to − low-carbon transportation fuels, including geologic and renewable natural gas (RNG).

There are several factors that motivate the company’s support. For one, medium and heavy-duty vehicles contribute a disproportionate amount of pollution in urban areas throughout the country, and in many cases are the most significant contributors to ozone pollution and smog. (footnote 1) This is not because cleaner technology does not exist, but rather because cleaner technology is not being deployed in effective numbers.

Converting medium and heavy-duty vehicles to natural gas can bend the emissions curve immediately, providing a ready-now, proven and highly cost-effective solution for a low-carbon transportation future. Compared to diesel, for example, natural gas engines fueled with geologic natural gas reduce CO2 and GHG emissions by at least 12%. (footnote 2)

When fueled by RNG, CO2 and GHG emissions can be reduced by up to 331%. (footnote 2)

Cap-and-invest program resources invested in natural gas technologies would significantly and immediately benefit all communities by maximizing the displacement of older, higher emitting medium and heavy-duty vehicles.

Washington Gas knows firsthand the value of NGV in its ongoing commitment to implementing sustainable business practices in how it manages its own operations, and that includes adopting NGV for its fleet.

In fact, in 2011, four years prior to the Paris Agreement, Washington Gas set 2020 targets for GHG reductions for its fleet and facilities, and to lower the carbon intensity of the gas it delivers. The company exceeded those goals in 2016. Washington Gas then announced new, updated targets for 2025, including carbon neutrality for its fleet and facilities by 2025.

Currently, the company has 289 NGVs, which equates to 38% of its current fleet. By adding dedicated Compressed Natural Gas (CNG) and bi-fuel CNG vehicles to the fleet, and by taking active measures to manage fleet emissions, Washington Gas has significantly reduced the annual per vehicle emissions intensity for its fleet.

Washington Gas also monitors liquid fuel usage in bi-fuel vehicles to ensure drivers are utilizing CNG as their primary fuel source, and it monitors the liquid fuel gallons that are displaced by CNG usage each year. The company has seen an increase in this displacement as its CNG fleet has grown and CNG fuel usage awareness has gained traction throughout the company.

1 https://www.ngvamerica.org/environment.
2 Dependent upon RNG source. Reductions of 45% up to 331% compared to diesel; values based on CARB LCFS program data under CA-GREET 3.0.

As a father of 3 children and a concerned citizen, I am urging you to consider reducing green house gas emissions by adopting the strongest TCI Regional Policy initiative. Climate change affects all of us and is the number one challenge facing everyone on this planet. It is everyone's responsability, from each individual to local to national governments to ensure a reduction of green house gases. This initiative if implemented will help in this respect. I wish to thank Governor Baker for his leadership in making Massachusetts one of the greenest state and urge him to adopt this policy. This initiative will also help the most needy that don't have access to a good transportation system.
Thank you for your consideration.
Sincerely.
Olivier Resca