TCI Regional Policy Design Stakeholder Submissions

see attached document (corrections to previous document)
28FEB20_BTBCoaltion_01a.pdf

Please forward this to Governor Scott

Dear Governor,

I ask that you bring Vermont into the Transportation and Climate Initiative (TCI).
My household of 3 voters believes TCI provides a bold path forward for reducing climate pollution in the transportation sector and spurring investment in public transportation and other much-needed transportation infrastructure.
Climate change has become our most important political/social/spiritual action and should be bipartisan.

The legislature is using global warming as a way to install oppressive and unfair taxation on the lower and middle classes. Dr. Patrick Moore, founder of Greenpeace , Has presented evidence that CO2 is not harming the earth. The cause of global warming is solo weather in a change in the earths magnetic fields and poles. There is a Geo political movement connected to agenda 21/30
It is being used by the elite ruling class to create a new world order. Americans are waking up to this far. Stop this tax now the population of Massachusetts is not going to stand for this money grab we’ve had enough.

TCI costs are a non-solution for rural Vermonters and targets us with unnecessary and unequitable costs. My family has no options but to use our vehicles for obtaining work, school, and basic life necessities. Mass transportation is neither effective nor efficient in a rural environment. I cannot walk or bike with my young children along the rural Town roads as a main source of transportation due to having no distinguishable shoulder for safe traversing. When a vehicle approaches as we walk on these roads, we must leave the road and enter the long grass and weeds which are ripe with ticks and yellow or poison parsnip and the occasional used syringe. For as many as 6-7 months of the year the plowed snow debris leaves no options for getting off the road and out of the way of traffic. Vermont’s State roads are no better than the rural roads regarding accessible shoulder space in our area.
I would also like to point out that the State of Vermont is the largest contributor to transportation generated pollution. The State of Vermont is the largest employer in the State, all those State employees have to commute to and from work, increasing transportation generated pollution. Additionally, the State of Vermont by far, has the largest inventory of vehicles of any entity in the State, which are used by the State Employees to perform State functions such as policing, forestry, fish and game enforcement, highway maintenance, parks management, DMV enforcement, and many other entities and purposes. I am not debating the necessity of these transportation assets, my transportation requirements are as necessary to me and my family as they State’s requirements are necessary to the State. My family should not be penalized financially to meet our needs to subsidize the only growing transportation generated pollution caused by the State of Vermont.
If you want to reduce transportation generated pollution in the State of Vermont, you must first look to the largest generator of such pollution, the State’s Government and Agencies.

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

I am writing as a concerned citizen, mother and grandmother who believes we must do all we can to keep the planet safe for our families and future generations. Therefore we must concentrate on reducing carbon emissions now. Transportation is Vermont’s weakest sector, which is why Vermont especially needs to join TCI and help lead the northeast to a cleaner energy future.
Cap and invest programs are not new to Vermont. Since Gov. Douglas signed Vermont on to RGGI in 2008, Vermont’s cap and invest program has successfully reduced consumer costs and carbon pollution from the power sector by 40%, and its revenues have raised $2 million annually for weatherization programs to help Vermonters stop wasting energy and save money. Given that we know this type of project works, adopting TCI makes perfect sense. As I grow older I want to be able to age in place, and having greener options for transportation is the only way I’ll be able to do it. I am urging you on behalf of Vermonters like me and my aging friends as well as generations of future Vermonters to make sure that Vermont formally joins TCI. We must use every opportunity to create a clean energy future that works better for everyone, especially our most vulnerable. Thank you for the work you’ve done so far to advance TCI across the region. 

Our State Environmental Quality Review (SEQR) in New York currently focuses on a project's effect on automobile delay (Vehicle Level of Service [LOS]). The State of California, however, has determined LOS does not constitute a significant environmental impact. They are instead now using criteria for determining the significance of transportation impacts to promote: (1) a reduction in greenhouse gas emissions; (2) development of multimodal transportation networks; and (3) a diversity of land uses. A precedent that New York State should follow.

In addition, due to their vastly increased risk of serious injury and fatality, the safety of vulnerable road users (pedestrians and bicyclists) should be given relatively more attention. Improving safety is key to complying with policy and planning priorities that encourage multimodal and low-carbon travel.

The fundamental relationship between VMT and safety is summarized by Yeo et al. (2014): “Multiple traffic safety studies showed that higher VMT was positively associated with the occurrence of traffic crashes or fatalities. The causal relationship between the mileage of total vehicle trips and crash occurrences can be explained by probability. With higher VMT, it is more likely that more crashes will occur.” With pedestrian and bicycle injuries and fatalities at a 30 year high, any investments made towards reducing greenhouse gas emissions should also consider safety.

I WANT:
A cap on carbon emissions of at least 25% by 2032
An increase in the minimum investment in overburdened and underserved communities (>35%)
Investments put towards active transportation like better sidewalks, bicycle infrastructure, and high quality public transit