TCI Regional Policy Design Stakeholder Submissions

I live in Bedford, Massachusetts. I am an engineer, a mother of two almost grown daughters, and a former Girl Scout leader. I am now someone who spends every spare moment trying to combat climate change for the sake of my children and all children, because I am horrified that we as a society are allowing devastation to become the norm when there are alternatives! I am very grateful for the bipartisanship of the TCI. Any TCI policy would need to price carbon emissions high enough to effectively reduce emissions according to the latest science. In order to not cause social upheaval with high prices, the policy would also need to
have a strong component of social equity and should not hurt rural or low/moderate income people. We don't want to have a yellow vest situation on our hands as they did in France! Our children need us to be as bold as possible as we build the just and peaceful world they deserve!

Thank you for the opportunity to comment on the TCI Framework for a Draft Regional Policy Proposal. The National Consumer Law Center (NCLC) is a non-profit organization that works for economic justice for low-income and other disadvantaged people in the U.S. through policy analysis and advocacy, publications, litigation, and training. NCLC submits these comments on behalf of our low-income clients. Our comments focus on equity issues, program design, and other elements that may directly affect low-income consumers. Please see attached comments, in PDF format.

We support strong climate policy. Don't be fooled by false narratives from the fossil fuel industry and other agents of the status quo. We need strong action and we need it now.

We completely support the adoption of TCI. Maine would realize important health, economic, and environmental benefits by transitioning to cleaner and more efficient transportation options through adoption of TCI.

1. It is unconstitutional to impose new taxes unless a bill is introduced in the House of Representatives. This is a tax imposed by fiat.
2. The voters of Massachusetts made it abundantly clear that they reject an increase in the gas tax by a referendum just a few years ago
3. Since the mass dpw spends 4 times as much per mile as New Hampshire and twice as much as New York it is unconscionable to ask for more money until the most basic of fiscal controls are placed on their expenditures

Affiliation can be concerned resident/parent/voter/etc.
Request your state join the plan to reduce transportation emissions.
Explain why it is important to you that the states take action on the climate crisis now.
Demand a strong program that invests in public transportation, biking, walking, and prioritizes equity.

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 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. 

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