TCI Regional Policy Design Stakeholder Submissions

To Whom it May Concern: I am opposed to the Transportation and Climate Initiative because it is not the role of government to protect us from climate change. The purpose of government is to protect our individual rights as the Declaration of Independence says. One does not have a right to an unchanging climate.

Also, the TCI is unjust. Why should people from Springfield pay to protect the people of Boston from rising sea levels? Why should Massachusetts residents pay to protect say, Floridians from more hurricanes? Why should anyone sacrifice for others - shouldn't people take responsibility for their own lives and move to a better place or otherwise protect themselves from climate change. TCI is the exact opposite of personal responsibility - by forcing responsible people to sacrifice for irresponsible people it makes it harder for responsible people to protect themselves!

The government should not play any role in the climate change debate. If people want to protect themselves from climate change there's nothing stopping them. Please don't force us to sacrifice to somehow stop climate change.

The TCI is nothing but a tax grab by Baker and The Commonwealth. What are they going to do with the money, build windmills? I voted for Baker because of his party affiliation; now I know that he is nothing but a RINO and (so) I have no representation in this state for my political views.

In order for the regional plan of the Transportation and Climate Initiative to work, governors of these states and the mayor of Washington, D.C., must ensure that the transportation plan is bold enough to cut harmful transportation pollution at the scale needed to avert the climate crisis. We, the people of New York need a plan that holds large transportation polluters accountable for the pollution they create and invests in clean transportation solutions including:
--More public transit and electric vehicle infrastructure in rural areas
--Expansion of commuter rail, electric vehicles, and streets in the suburbs that are safe, walkable, and bikeable
--Sustainable and equitable housing near transit and electric bus fleets in urban communities
We want to see a bold and ambitious plan to cut transportation pollution in New York State and in the Hudson Valley bioregion and beyond.
Thanks for your attention and hoped for positive action.

Another tax on the working class while the politicians fly around on private jets

Nuclear Power to Power Etrains, Ecars and Synthetic Fuels made by Nuclear Power to Power Trucks and Planes. Closing Indian Point Nuclear is a HUGE mistake, as it is equal to the 580 Windmills projected off New Jersey. BIOFuels added to Gas and Diesel, provide NO benefit to decarbonation, as growing corn and soybeans uses fossil fuels to produce it, at a huge Enviro Footprint.
https://www.youtube.com/watch?v=SlvpYyyya_Q
Titans of Nuclear-United Nations hosts Bret Kugelmass on Energy, Climate Change, and Nuclear Power
322,549 views•Nov 15, 2019 Titans of Nuclear=Bret Kugelmass challenges the orthodoxy of both Climate Change and Nuclear Energy across 3 dimensions: Evaluation, Mathematical & Communication.

We need a much faster and efficient means of getting from one state to another, especially in the Northeast part of our country. In doing so we will also be able to help save our planet by creating these forms of transportation so they will use the most earth friendly forms of energy. The science exists to accomplish this goal - and we will also create many high-paying jobs in the process! My husband and I recently took the Amtrak train from Rochester to Richmond, VA to visit our son. It took an entire day each way which is crazy! Many other countries all over the world have wonderful high speed trains - we can too! We need to make the investment NOW so we can begin to reap the benefits ASAP. This also is possible for other forms of transportation - our cars, buses and airplanes also need to make use of the new green technologies!

Hello, Transportation and Climate Initiative team,

I very much appreciate Virginia’s efforts to reduce transportation emissions, which are a major contributor to climate change. And as a mom and fellow Virginian, I would implore lawmakers to consider more aggressive targets, which are essential for us to be able to reduce emissions enough to decarbonize before climate change is irreversible. Please consider at least a 25% reduction target over 10 years for all registered vehicles.

Please make zero tailpipe emission investments a priority. We all want our kids to grow up in with healthy air to breathe and a stable, healthy climate. Please act aggressively while we still have a window of opportunity to turn the tide on climate change.

Thank you.
Sincerely,
Kay Campbell
Albemarle County resident

Maryland Motor Truck Association (MMTA) is a non-profit trade association that has represented the trucking industry since 1935. In service to our 1,000 members, MMTA submits the following comments in response to the Draft Regional Policy Proposal by the Transportation Climate Initiative of the Northeast and Mid-Atlantic States.

Over the past decade, MMTA has worked closely with the Maryland Department of the Environment and the Maryland Energy Administration to design a series of programs to voluntarily reduce commercial motor vehicle emissions. These include grant programs for the purchase of alternative power units, financial assistance to help companies replace older model diesel trucks with clean diesel, natural gas and electric powered vehicles, and the “Idle Free MD” outreach campaign encouraging drivers to turn off their engines and avoid idling whenever possible. Yet the question remains, “How do we achieve the goals in Maryland law – a 40% reduction in greenhouse gas emissions by 2030 – as well as the other stated goals of TCI without major disruptions to business?”

There is clearly no silver bullet that will achieve these goals. To that end, MMTA encourages a multi-faceted strategy that includes:

• A continued focus on voluntary measures backed by financial incentives to assist companies with adoption of cleaner technologies, such as the Port of Baltimore Dray Truck Replacement Program. This program not only helps to reduce air pollution and greenhouse gases associated with the transport of goods to and from the Port of Baltimore, but also supports TCI’s stated goals of equity and environmental justice.
• An approach that considers all fuel options – including some continuation of fossil fuel use, such as clean diesel, natural gas, and biofuels as bridge fuels while other technologies are enhanced to meet the operational needs of the trucking industry. Both biodiesel and renewable diesel fuel are capable of significantly reducing greenhouse gas emissions without the major infrastructure investment that is required for other fuel sources.
• Bid preferences on state contracts for motor carriers that are partners in the Environmental Protection Agency’s SmartWay program and have taken steps to reduce their greenhouse gas emissions voluntarily.
• Investment in transportation infrastructure improvements that promote free flowing mobility of goods. Traffic congestion results in wasted fuel and increased greenhouse gas emissions. Last year the American Transportation Research Institute updated its “Cost of Congestion to the Trucking Industry” report. On the National Highway System alone, traffic delays cost the industry almost 1.2 billion hours, or the equivalent of 425,533 commercial truck drivers sitting idle in traffic without moving for an entire year.
• A focus on the development of more fuel-efficient vehicles. After all, it is pollution, not traveling, that is the concern.

The TCI framework proposes to establish a system to “cap emissions of carbon dioxide from the combustion of the fossil component of finished motor gasoline and on-road diesel fuel in the region.” A “cap and invest” program poses significant challenges for the trucking industry. Our industry is fuel neutral; however, we must have access to a readily available, affordable and reliable fuel supply. This means:

• There must be no negative operational impacts on our equipment.
• The fuel supply must be reasonable in cost and marketplace ready.
• There must be no disruption in availability of supply that prevent us from delivering the products people need.

While new fuel options that meet these criteria may become viable in the future, today the industry relies on ultra-low sulfur diesel. A cap and invest (or it’s closely related cousin, a “carbon tax”) typically attempts to discourage people from driving by imposing increased costs on them for doing so. These programs only impact those who have a driving choice (e.g. passenger car drivers). Trucking is a non-discretionary user of the highways, delivering the food, clothing, medical supplies and other goods citizens need in support of the manufacturing, agricultural, and retail industries. In Maryland, 93% of communities are solely dependent on trucks to get their goods.

MMTA is also concerned that the cap and invest programmed described in the TCI framework states, “Affected fuel would include fuel destined for final sale or consumption in a TCI jurisdiction.” Maryland is a small geographic state, with well over 50% of all trucks passing through from another jurisdiction. Given our state’s small size, trucking companies do not have to purchase fuel in Maryland. A cap and invest program does not address emissions from the thousands of trucks from other states that travel through Maryland. It only places the economic burden on those local companies that purchase fuel in the state or those states within TCI.

Over the last decade the trucking industry has made incredible strides in reducing all types of vehicle emissions. Under federal law, without any future actions taken by the TCI states, those reductions are slated to continue. For example:

• Over the last 10 years, emissions from heavy-duty diesel trucks and buses have been reduced by 99% for NOx - an ozone precursor - and 98% for particulate emissions.
• New commercial trucks being manufactured today reduce fuel consumption and GHGs by approximately 20% when compared to a truck manufactured just in 2010. This is a savings of four gallons of fuel for every 100 miles traveled.
• Going forward, three additional rounds of increasingly stringent federal engine and vehicle GHG emissions standards are slated for new commercial trucks sold nationwide between 2021 and 2027.
• By 2027, commercial trucks will further reduce fuel consumption and greenhouse gas emissions by an additional 25%. Improvements to the trailers pulled by these trucks will provide an additional 9% reduction.

Per the Maryland Department of the Environment’s Greenhouse Gas Emissions Reduction Act Draft Plan of October 2019, emissions from on-road diesel use accounted for only 19% of total transportation emissions in the state in 2014. Given the tremendous strides that have been made, coupled with the cost of fleet replacement and the lack of viable fuel alternatives – particularly for the long-haul, heavy duty trucking industry sector – Maryland Motor Truck Association believes that any cap and invest program should exclude on-road diesel fuel until viable alternative fuel options exist.

TCI allows a small rural state like Vermont to benefit in several ways.

Reducing GHG - a global problem that Vermonters care about and want addressed - can not be done state by state and especially by states as small as Vermont. Combining the markets and regulatory power of several states will mean real progress and be a model for other parts of the country.

TCI - while bringing much needed funding to transportation programs - will be tailored to an individual state's needs. For Vermont this might mean rural transit, ride share, and EV programs and making sure rural residents that have to drive long distances to access, jobs, food, school and other services be treated equitably.

Any direct economic effect of a market based solution will fall outside the state's borders. There is no drilling or refining in VT and region wide distribution systems are for the most part outside of the state. Estimates of the affects at the VT pump are highly variable yet fall well within the range of gas price fluctuations over the last decade as state officials explained at recent public forums.

It may be that if the rest of the region's large states participate and Vermont, a relatively tiny market, doesn't the price at VT pumps may still go up given regional energy markets. Meanwhile the state will fail to reap transportation funding benefits.

Finally RGGI has been a success for the state. Important low income weatherization programs have benefited. TCI is following a similar model. Like RGGI there would be much to be gained and little to lose if the state participates.