TCI Regional Policy Design Stakeholder Submissions

Hi - I’d support any and all efforts to quickly transition CT over to clean energy. I think we should build more electric car charging stations, switch public transit (buses etc.) to electric, and limit the sales of gas guzzling cars in the state ASAP. Such a program in conjunction with other states (NY, NJ, etc) will promote cleaner air and water in the region.

Thank you for your consideration of this comment.
Vinod

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.

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:

• TCI needs to be very cautious about advantaging regulated electric monopolies that already benefit from antitrust protection and a guaranteed rate of return. According to the website Utility Dive (https://www.utilitydive.com/news/california-new-england-will-significantly-miss-2050-carbon-targets-at-curr/564726/), "Just to meet this load that comes from electrifying transportation and buildings, you have to add an electricity sector that's equal to the current electricity sector" – which is a huge gift to utility investors. Are utilities doing such a great job that they deserve these government handouts (Eversource is rated below California’s PG&E in 2019 by the American Customer Satisfaction Index)? Our business cannot compete with utilities coddled and protected by government unless, we get equivalent protection and subsidies to create a level, competitive playing field.

• 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.”

• Connecticut motorists are already paying the highest gasoline taxes in New England and the 11th highest tax in America. Connecticut also has the highest diesel tax in New England and the 9th highest tax in America. Any proposal that increases the cost of fuel in our state will disproportionally harm low-income motorists and businesses when compared to states that do not participate in TCI. According to the Natural Resources Defense Council "Low-income, households of color, multifamily and renting households spend a much larger percentage of their income on energy bills than the average family." An across-the-board energy tax is therefore "regressive," i.e. "African-American and Latino households and renters in multifamily buildings who pay a disproportionate amount of their income for energy" will be greater impacted by such a tax than average- or high-income earners. Moreover, low-income families will have less means to change their energy use to lower-taxed fuels, which are prohibitively expensive to convert to. TCI needs to consider the impact of their program on low- and fixed-income families who will not be able convert to EV’s.

• Presumably, the purpose of TCI is to change consumption behavior in Connecticut and the region. But we’ve seen huge variations in energy commodity prices that haven’t affected consumption. EIA, for example, shows that gasoline consumption in Connecticut in 2015 was the same as in 2011, despite prices being more than $1/gallon less. Energy consumption is inelastic. Even if TCI is successful in increasing cost of fuel, the data clearly demonstrate that people will be paying higher prices for fuel and not curb consumption. Further inflation will result as the price of every product sold in Connecticut increases as merchants and manufacturers increase prices to account for TCI. Either that, or people will vote with their feet and leave the state or region.

Finally, even if TCI resulted in changes in consumption behavior in Connecticut, such changes will have no impact on climate change. As reported in U.S. News & World Report, the Intergovernmental Panel on Climate Change (IPCC) Assessment Report claims that even if the U.S. as a whole stopped emitting all carbon dioxide emissions immediately, the ultimate impact on projected global temperature rise would be a reduction of only about 0.08°C by the year 2050. China and India will dominate global carbon emissions for the next century, and there’s little the U.S., let alone Connecticut can do, to affect this. A Princeton University study likewise predicted that even if all countries stopped emitting CO2 entirely, the Earth would continue to gradually warm, before cooling off.
I ask that TCI take all of these issues into consideration before they decide to move forward.

"AUGUSTA – Governor Janet Mills is negotiating a multi-state agreement that could sharply increase the cost of gasoline and diesel for Maine people, and Mainers should take the opportunity to weigh in with their comments, says a group that advocates for Maine’s taxpayers and consumers."

As the people in the State of Maine are already the 3rd highest taxed population in the nation, and because Maine's economy is still struggling (even after the tremendous advances made by Governor LePage) the last thing we need is an increase in taxes based on junk science about climate change! These political scares about the impending devastation of our planet have been circulating for more than 120 years, and they are no more credible now than they were back then.

The climate crisis is upon us all. We have to reduce our carbon footprint fast and forever. Public transportation is a good answer. Using electric vehicles and other hybrid vehicles in cities and rural areas would reduce the need for people to drive their cars. It would be a win for the planet.

I care deeply about reducing pollution from transportation, which is our largest source of global warming emissions (regionally and nationally). Every State in our country should participate and do everything it can to clean up and maintain our environment not only for us but for the health of the entire planet. The policy should have a strong component of equity by prioritizing clean investments in areas overburdened by pollution and/or for those who don't have access.

Thank you for the bipartisan nature of this project, moving us forward while the federal government takes us backward!!!!! Your work is greatly appreciated.

As an environmental biologist, I support the Transportation and Climate Initiative. Actions need to be taken to lower carbon emissions to establish a healthy environment. This initiative can potentially reduce emissions significantly and contribute to reducing air pollution.

This proposal is not good for the state of Maine. It might work for the city of Portland but in a state that has such a huge rural, farming, logging and dependency on tourism both summer and winter it will be disastrous. Gas prices in this state are already with imposed taxes 30-50 cents more per gallon than southern states, mid west and south west. Many of the people in this state live not only on fixed incomes but below the poverty level. Many of those same people won't be able to afford to get back and forth to work with what is proposed in this initiative, and very likely won't be high on the list to recieve the fuels if this goes through with the proposed "rationing". Many of us are indeed taxpayers who have homes and families here we don't want to loose what we have had our entire lives but this initiative is coming across as just another means for government to end up taking everything we worked our entire lives for.

A D behind anyone's name equals DISQUALIFIED because of idiotic policies like deliberately making energy costs higher. Leave me alone. I can spend the money I earn more efficiently than the State can. The State is wasteful and abusive of liberty. No more taxes. Taxed Enough (Too much) Already.