TCI Regional Policy Design Stakeholder Submissions

Material submitted through the TCI Public Input form from April 2019-February 2021 is viewable here. View input submitted from March 1, 2021 forward here. All material submitted on this page informed the participating jurisdictions in the 2019-2020 TCI regional policy design process. Click on the column headings to sort the submissions.

Date	First	Last	Affiliation	City	State	Input	File
1/16/2020	Rob	White	Dr. (Mr.)	Silver Spring	Maryland	I Request that your MD formally join the plan to reduce emissions. I Demand that the policy has a strong component of equity by prioritizing clean investments in areas overburdened by... read more I Request that your MD formally join the plan to reduce emissions. I Demand that the policy has a strong component of equity by prioritizing clean investments in areas overburdened by pollution and/or for those who don't have access. I have gratitude for the bipartisan nature of this project, moving us forward while the federal government takes us backward.	-
2/28/2020	ROB	UNDERWOOD	PMAA	ARLINGTON	Virginia	On behalf of the Petroleum Marketers Association of America (PMAA), I would like to offer our comments on the draft Memorandum of Understanding (MOU) for the Transportation Climate Initiative (TCI... read more On behalf of the Petroleum Marketers Association of America (PMAA), I would like to offer our comments on the draft Memorandum of Understanding (MOU) for the Transportation Climate Initiative (TCI). Please see attached. Sincerely, Rob Underwood PMAA President	PMAA_TCI_Draft_MOU_Comments.pdf
11/2/2020	Rob	Underwood	Energy Marketers of America	ARLINGTON	Virginia	Please see attached comments from the Energy Marketers of America regarding TCI. Please see attached comments from the Energy Marketers of America regarding TCI.	EMA_TCI_Comments.pdf
10/31/2019	Rita	Buttery	Democrat	Passadumkeag	Maine	Mainers cannot afford any more increases in taxes on gas and fuel..We can barely afford the prices now... Mainers cannot afford any more increases in taxes on gas and fuel..We can barely afford the prices now...	-
11/2/2019	Rita	Hansen	Onboard Dynamics, Inc.	Bend	Oregon	Please see attached letter - Onboard Dynamics TCI Comments on Framework - Nov 4 2019. Thank you, Rita Hansen Please see attached letter - Onboard Dynamics TCI Comments on Framework - Nov 4 2019. Thank you, Rita Hansen	Onboard Dynamics TCI Comments on Framework - Nov 4 2019.pdf
2/27/2020	Rita	Hansen	Onboard Dynamics, Inc.	Bend	Oregon	February 24, 2020 Ms. Kathleen Theoharides, Chair Transportation & Climate Initiative of the Northeast and Mid-Atlantic States Georgetown Climate Center 600... read more February 24, 2020 Ms. Kathleen Theoharides, Chair Transportation & Climate Initiative of the Northeast and Mid-Atlantic States Georgetown Climate Center 600 New Jersey Avenue, NW Washington, DC 20001 Dear Secretary Theoharides: My name is Rita Hansen and I am the CEO of Onboard Dynamics, Inc., an early phase company and a spinout from Oregon State University that provides novel compression technology to enable the use of natural gas and renewable natural gas as a transportation fuel. I appreciate the opportunity to comment on the Transportation & Climate Initiative (TCI) Draft Memorandum of Understanding of the Transportation and Climate Initiative and I commend TCI’s goals of equity, environmental justice, non-discrimination and meaningful public participation as it develops and implements a regional policy for transportation emissions reductions. Onboard Dynamics endorses strategies that support the transition to low-carbon transportation fuels, including geologic and renewable natural gas. Converting the Northeast and Mid-Atlantic regions’ heavy- and medium-duty freight and transit transportation network to natural gas provides a readily available, proven and cost-effective solution to accelerate the transition to a low-carbon transportation future. Further, 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 trucks and buses, including those higher emitting vehicles that operate in communities that are underserved by current transportation options and overburdened by urban pollution. Cleaner Air Starts with Cleaner Trucks and Buses Increased use of natural gas as a transportation fuel provides immediate and significant criteria and toxic air pollutant reductions. Fact: the cleanest commercially available heavy-duty engine in the world is powered by natural gas now and for the foreseeable future. Designed, built, and manufactured in America by Cummins Westport, this engine is certified to a 0.02 g/bhp-hr. standard, making it 90 percent cleaner than the EPA’s current NOx emissions requirement and 90 percent cleaner than the cleanest diesel engine. And in real-life study, these engines emitted lower NOx emissions than certified. Replacing just one traditional diesel-burning heavy-duty truck with one new Ultra Low-NOx natural gas truck is the emissions equivalent of removing 119 traditional combustion engine cars off our roads. Heavy-duty equals heavy impact. Carbon-Neutral/Negative Freight with RNG Natural gas engines offer significant climate change benefits. Compared to diesel, natural gas engines fueled with geologic natural gas reduce CO2 and greenhouse gas emissions by at least 12 percent. When fueled with renewable natural gas (RNG or biomethane) captured from agricultural, food, landfill or wastewater, even greater CO2 and greenhouse gas benefits are achieved, up to 331 percent lower than diesel. Fueling with RNG is carbon-neutral, even carbon-negative, depending on the feed stock as shown below. No better commercially available and deployable alternative fuel option currently exists for the heavy-duty sector. CARBON INTENSITY of TRANSPORTATION FUELS (EER-Adjusted) <Please see the attachment for the chart inserted here.> Address Noise Pollution Natural gas vehicle technology affordably addresses noise pollution in urban neighborhoods. A U.S. Department of Energy study identified significant noise reduction benefits as a motivator for many refuse collection truck operators in accepting the technology, citing up to 10 decibels quieter than their diesel counterparts. A 2016 in-use study of diesel and CNG urban transit buses in Serbia found considerable reductions in noise pollution when powered by CNG. Invest Impactfully – Emissions Reductions using Cost Effective Solutions Investments in Ultra Low-NOx Near Zero emission natural gas vehicle technologies greatly impact communities, especially the underserved and marginalized communities in metropolitan and industrial areas. With vehicle costs close to that of diesel and fuel price differentials of up to $1.50 less than diesel per DGE, natural gas transportation provides the largest and most cost-effective reductions in transportation-related pollutants than any other powertrain option commercially available today or near-term. UPS, Waste Management, Republic Services, Los Angeles World Airports Buses, City of Los Angeles, City of Fresno Transit, LA Metro Transit, New York’s Hunts Point fleet Industries and many other fleets recognize the exponential impact of using RNG for emissions reductions and their improving business’ bottom line. In May of 2019 UPS announced that it will purchase 170 million gallon equivalents over 7 years that will reduce GHG emissions by more than 1 million metric tons, and in October UPS announced the order of 6000 heavy duty NGV RNG trucks to double the size of their NGV fleet. In February 2020, UPS increased their RNG commitment to a total of 250 million-gallon equivalents over 7 years. Meanwhile, Waste Management has converted approximately 9,000 of its 17,000 collection vehicles to natural gas, resulting in the largest heavy-duty natural gas truck fleet of its kind in North America. Over 40 percent of Waste Management’s natural gas fleet currently is fueled with RNG produced from landfill biogas, supporting its long-term strategy of creating a near-zero emissions collection fleet. RNG already fuels more than 32% of the over 175,000 NGVs in the U.S. today, and a growing number of fleets are taking advantage of vehicles that are available now at comparable life cycle costs to diesel vehicles and that provide transformational GHG and tailpipe emissions reductions. As such, investments in RNG-fueled trucks and transit buses accessing ports, cities, and densely populated neighborhoods are the most immediate and fiscally responsible investment to clean our air and combat climate change. Communities get more clean vehicles having greater clean air and climate impact for the money with natural gas than with any other alternative fuel option, especially electric. No other transportation fuel is as sustainable, adaptive, and competitive across all applications and vehicle classes. And heavy-duty natural gas trucks are not demonstration science projects; they are proven, scalable, and on U.S. roads today. We will not meet emissions reduction goals or time frames without using natural gas. Natural Gas Pays Its Way and Provides Economic Opportunity Natural gas fueling pays into the federal highway trust fund and is ready-right-now technology. It is road-tested and backed by a mature network of manufacturers, servicers, and suppliers coast-to-coast. An established refueling infrastructure of 2,000 stations already exists. It is also important to note that while 34 U.S. states produce geologic natural gas, the potential to produce RNG exists in every U.S. state and the District of Columbia by taking the problem of fugitive methane gas created from organic waste, capturing it, then using it to fuel traditionally heavy-carbon freight and transit transportation applications. In addition to its clean air and climate benefits, the development of RNG facilities also supports the agriculture industry with new revenue streams, addresses many cities’ solid waste issues, and impacts watershed management efforts and nitrogen runoff concerns. With these positives, the demand for RNG production is growing and new RNG facility development projects are increasing rapidly. 100% Domestic Fuels Geologic and renewable natural gas are 100 percent domestic fuels, unlike limited electric vehicle battery components that are controlled by foreign interests and mostly sourced from conflict countries like the Democratic Republic of the Congo and China. The U.S. EPA recognizes the value of RNG and includes it in the EPA Renewable Fuel Standard (RFS) federal incentive. Similarly, several states have implemented low carbon fuel standards (LCFS) that promote the use of RNG and other renewable fuels. More than four in ten Americans live in communities with dangerously dirty air. According to the American Lung Association, that number continues to rise, from 125 million in 2017 to nearly 141.1 million today. Cap-and-invest program investments in natural gas vehicle technologies offer the most proven, cost-effective, and immediate way to promote a low carbon transportation future, clean our air, and provide more affordable, accessible, and reliable transportation opportunities for marginalized and underserved communities. As the TCI states in the Draft MOU, a regional program “addresses the urgent need to mitigate greenhouse gas emissions and other harmful pollutants generated by the transportation sector” which I fully agree with and offer that natural gas vehicles, especially those using RNG must be a key component to any TCI strategy if these reductions are to occur in any reasonable time frame and improving the areas of greatest need. Thank you for your consideration, and please contact me at rita.hansen@onboarddynamics.com or 206.291.3206 with any comments or questions. Thank you for your consideration. Sincerely, Rita Hansen CEO	Onboard Dynamics TCI MOU - 24FEB2020.pdf
11/1/2019	Rick	Bologna	Westmore Fuel Co., Inc.	Greenwich	Connecticut	My name is Rick Bologna, I own and operate Westmore Fuel Co., Inc. in Greenwich, CT. We are a multi-generational family owned business that was established 81 years ago. I... read more My name is Rick Bologna, I own and operate Westmore Fuel Co., Inc. in Greenwich, CT. We are a multi-generational family owned business that was established 81 years ago. I currently am the Vice President and have been with Westmore Fuel Co., Inc. for the last 29 years. I am submitting comments for you to consider as a resident and taxpayer in Connecticut to express my concern about the potential that a cap and trade program will have on our customers, employees, business and the environment. The plan seems to be geared toward converting millions of gasoline and diesel-powered vehicles to electric vehicles (EVs). While EVs may be an apparently attractive way to lower emissions, we urge that greater consideration needs to be given to a number of factors that will have an impact on jobs, the economy, property values, electric reliability, emissions and family-owned businesses. Please consider the following points and recommendations so that they can be incorporated into the final draft of the TCI: • With the goal of putting million’s EVs on the road, TCI should have ISO New England and the other grid operators fully evaluate the impact that this would have on the electric grid. An article published by the Massachusetts Institute of Technology (MIT) indicates that one EV can consume as much electricity as a home does. And as noted, we need to double power generation to meet the state’s carbon goals, an unlikely feat that will result only in supply shortages. The unintended consequence of the government heedlessly jumping onto the EV bandwagon will be rolling blackouts, with power loss to critical infrastructure such as schools, businesses, emergency responders, hospitals and nursing homes. • The ISO’s should add to their evaluation the impact of state policies promoting electric heat pumps on the electric grid, which could require an additional 17 million MWH of power annually. TCI must understand the impact that their program has on other initiatives also looking to utilize more electricity. TCI is not operating in isolation and has the responsibility not to operate in the dark either, and ensure that electric reliability is not compromised. • Although EVs are considered a low- or zero-emission vehicles, they are only as clean as the electricity that charges them. Connecticut is heavily reliant on natural gas to generate electricity and becoming more dependent on it as nuclear generation in the region is retired. Natural gas (methane) is more than seventy times as potent a greenhouse gas than carbon dioxide, and combusting natural gas also emits carbon dioxide. According to the Department of Energy, an EV produces 4,362 lbs of CO2e per year (https://afdc.energy.gov/vehicles/electric_emissions.html)– that’s almost two tons – hardly emissions-free, and that doesn’t even consider the CO2 resulting from their manufacture. TCI needs to fully understand the lifecycle impact of EVs and the source of the fuel that electricity is being generated from before EVs are designated as “clean”. It is intellectually and environmentally dishonest to claim that electricity is clean when ISO New England today (10/29/19) reports that just 8% of electric generation is renewable and 53% is generated with natural gas. Methane’s impact on climate change is an inconvenient truth. A recent study commissioned by the Connecticut Chapter of the Sierra Club (https://issuu.com/ctsierraclub/docs/hartford__ct_mobile_methane_leak_su) found that in Hartford, CT alone, gas pipelines leak approximately 43,000 cubic feet per day, or 313 metric tons per year. That is equivalent spilling and not cleaning up 320 gallons of diesel per day (or 117,000 gallons per year). Just because you can’t see natural gas leaks, it doesn’t mean that they are not there and that they are not doing environmental damage. According to Gale Ridge, PhD, a scientist and researcher on the Sierra Club study, “In a one month period, we found about 700 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.” A real time solution that can be implemented immediately is the use of a low carbon renewable liquid fuel (LCRLF) such as Biodiesel. Biodiesel is blended today with traditional diesel distillate and is used for transportation and heating across the country. As the technology for this fuel advances, higher and higher blends of Biodiesel will be used and traditional diesel distillate will be phased out. By phasing over to LCRLFs, we can use the current liquid fuel transportation systems in place across the country (pipelines, barges, trucks, retail outlets, etc.). Also, US truck manufacturers already have diesel trucks that run on Biodiesel blends, so there wont be a need to convert trucks and future cars over to a new fuel. In fact, Biodiesel is the only fuel currently that can get us to carbon neutrality in the future, all of the other current forms of energy we have today, including natural gas, cannot do that. For more information on Biodiesel please see: https://www.biodiesel.org/ I ask that TCI take all of these issues into consideration before they decide to move forward. Thank you. Rick Bologna	-
11/13/2019	Rick	Twomey	taxpayer	Dartmouth	Massachusetts	Another state tax coming our way, we just lost net pay from the medical and family tax. God controls the climate - not the politicians. Another state tax coming our way, we just lost net pay from the medical and family tax. God controls the climate - not the politicians.	-
12/1/2019	Rick	Stoehrer	Stakeholder	Reading	Massachusetts	THIS IS A GAS TAX. You can call it whatever you'd like but it's another TAX on gas. This question has been asked and answered at the ballot and was defeated. read more THIS IS A GAS TAX. You can call it whatever you'd like but it's another TAX on gas. This question has been asked and answered at the ballot and was defeated.	-
12/21/2019	Rick	Peterson	Atlantic Commercial RE	Marshfield	Massachusetts	This is horrible for us retirees on fixed incomes. This is horrible for us retirees on fixed incomes.	-
2/21/2020	Rick	Nepola	Democrat	Stamfoed	Connecticut	The mid and north Eastern Seaboard states need an alternativr system of transportation. Our current air, train, bus , truck and automobile transportation does not work effectively to provide... read more The mid and north Eastern Seaboard states need an alternativr system of transportation. Our current air, train, bus , truck and automobile transportation does not work effectively to provide efficient results given the expense, effort, land usage and energy expended. The mere congestion of traffic is only one of the myriad of problems which confront us. Given population growth our transportation modalities need complete change. With pollution, noise, accidents, stifling weather conditions and inefficiencies we must conceive a wholly changed system. There need to be new roads, bridges, railways. air trafficking, etc that can handle existing and growing needs. Because of climate change alternative energy sources and uses need to be deployed. Nothing short of trillions of dollars must be allocated to the massive undertaking necessary. Municipal, state, regional and federal agencies must coordinate with the private sector to bring about transportation systems of a completely new and innovative era	-
2/24/2020	Rick	Klein	Voter	Panton	Vermont	Please support the TCI and support for low income Vermonters. Please support the TCI and support for low income Vermonters.	-
2/28/2020	Rick	Klein	Voter	Panton	Vermont	Please support TIC. It's not all we need but it is a good first step in mitigating climate crisis. read more Please support TIC. It's not all we need but it is a good first step in mitigating climate crisis.	-
11/30/2019	Richie	spink	None	Plymouth	Massachusetts	TCI is just another tax on people who have to drive to work, grocery shop and just live their normal lives. Last time I checked that is probably everybody in the state. It just doesn’t end in... read more TCI is just another tax on people who have to drive to work, grocery shop and just live their normal lives. Last time I checked that is probably everybody in the state. It just doesn’t end in Massachusetts. Completely unconstitutional by the way. I just got a pay decrease in my paycheck thanks to the new deduction for paid leave that I have to chip in for and will never use. Leaving this state ASAP. In the words of Greta, “HOW DARE YOU!!!!!	-
11/13/2019	Richard e	Asselin	1940	Springfield	Massachusetts	If the governor wants to be like california let him move there. If the governor wants to be like california let him move there.	-
10/29/2019	Richard A	Berry Jr	Tax payer	Belfast	Maine	Queen of Maine mills has found perhaps another way of scamming the good people of Maine of hard earned money. Turning this great State into another California is not what the people here want.... Queen of Maine mills has found perhaps another way of scamming the good people of Maine of hard earned money. Turning this great State into another California is not what the people here want.	-
10/29/2019	Richard A	Berry Jr	Tax payer	Belfast	Maine	Queen of Maine mills has found perhaps another way of scamming the good people of Maine of hard earned money. Turning this great State into another California is not what the people here want.... Queen of Maine mills has found perhaps another way of scamming the good people of Maine of hard earned money. Turning this great State into another California is not what the people here want.	-
5/24/2019	Richard	Payne	Woods Hole Oceanographic Omstitution	Falmouth	Massachusetts	I am aretired physical oceanographer who has been following the science of climate change for nearly 40 years. I live on Cape cod and, in addition to concern about what sea level rise will do to... read more I am aretired physical oceanographer who has been following the science of climate change for nearly 40 years. I live on Cape cod and, in addition to concern about what sea level rise will do to the Cape I have an 18 year old grandson who will see the worst of climate change effects. I request that the TCI policy call for putting a high enough price on carbon to effectively reduce emission according to the latest science. I also request that the policy have a strong component of social equity and does not harm rural or low to moderate people. I very much appreciate the bipartisan nature of this project.	-
10/3/2019	Richard	Sprock	NJT Daily commuter	Morristown	New Jersey	I have been commuting via NJT to NY Penn daily for 15 years. There are an infinite number of improvements that should be prioritized over GHG emissions reductions. At the top of that list are new... read more I have been commuting via NJT to NY Penn daily for 15 years. There are an infinite number of improvements that should be prioritized over GHG emissions reductions. At the top of that list are new Hudson river tubes. Until that is done it is a massive misuse of funds to spend anything on anything else. This is a hidden gas tax, an incredibly regressive one at that, being pushed through under the radar for no public benefit while we still do not have system-wide PTC or ADA compliance and have switches and signals presumably designed and built to operate outdoors that fail to operate in the wind/rain/snow. Moreover, the AGW science is not settled, nothing is imminent nor catastrophic - see document upload. According to IPPC, the global average temperatures have increased about 1 degree C since 1850 and that is about half due to human emissions. Despite the hysteria, IPPC also reports no measured increase in frequency or severity of tropical cyclone activities, it is frankly fraudulent or at least negligent for anyone to promote use of public resources to solve this non-problem. Amtrak operates Penn, as well as the regional rail infrastructure, and it is about as incompetent as any large bureaucratic organization can be and is completely unaccountable to anyone. A monkey randomly picking balls with train numbers from a bucket could better organize the train arrivals and departures. Simply auctioning off its assets to private operators would save money and probably have such efficiency gains that a measurable GHG emission reduction would result.	ecd-letter-to-un.pdf
10/12/2019	Richard	Archer	ME	Turners falls	Massachusetts	I believe you people (climate change activists) are out of your god damn minds! Stop trying to eliminate fossil fuels! Electric cars will NEVER be a viable option. STOP taxing (yes a... read more I believe you people (climate change activists) are out of your god damn minds! Stop trying to eliminate fossil fuels! Electric cars will NEVER be a viable option. STOP taxing (yes a fee is a TAX) the consumer. Stop trying to force us to get rid of our automobiles. The Earth is going through a cycle, science PROVES this! I will fight to the very end to NOT let the TCI ever become law. You should be ashamed of yourself.	-

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