TCI Regional Policy Design Stakeholder Submissions

There are several reasons why I am in favor of implementing TCI:
1) As a resident in the Boston metropolitan area, I am deeply aware of the traffic at all times of day and night. It is becoming a true detriment to work, play, and everyday life. TCI will provide revenues to help incentivize residents out of their cars and into public transit.
2) By improving public transit, we would be reducing emissions and GHGs helping both health related illnesses and the climate.
3) TCI can deeply address the inequities of both the income divide and rural transportation needs. Why can't there be affordable rural public transit, incentives for electric vehicles and getting old and dirty trucks off the road? EV rebates for turning in a gas guzzling truck, school bus, or municipal fleets? Why not?

TCI can address these and other transportation related concerns if implemented as soon as possible.

I applaud the leadership of Gov. Charlie Baker on this issue and encourage him and other governors to act in sync with courage and responsibility to extend whatever means we can for the next generation.

Thank you,
Jenny Russell

I support the Transportation and Climate Change Initiative as a positive step toward combating global warming.

Reducing greenhouse gas emissions in order to address climate change is one of the most urgent tasks facing our governments and our communities. Emissions due to transportation are one of the largest contributors to overall emissions and therefore urgent to address. I strongly support the Transportation and Climate Initiative, along with other efforts to reduce carbon dioxide emissions regionally in the Northeast by adapting and improving our transportation infrastructure.

Thank you for trying to address the climate crisis in a bipartisan way by pricing carbon. I hope you will ensure that any carbon price is high enough to create sufficient incentive to reduce carbon levels substantially, and that the policy will have a mechanism for minimizing impacts on low income folks.
Thanks.

The TCI framework proposes to implement a “regional cap to reduce CO2 emissions, from on-road diesel and finished motor gasoline.” 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 goods that 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 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. What will happen if supply or price are impacted so greatly that trucks cannot deliver the medicine or food that people need?

Richard B. Rudy, Inc. is concerned that a regional cap and invest program cannot work in a small 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.

One only needs to look at California to see the impacts on fuel costs of a cap and invest program. According to the Energy Information Administration, the cost of diesel fuel during the week of January 13, 2020 in the state was $3.87 per gallon. The combined average of all other western states during the same week was $3.24 per gallon.

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:
o 99% for NOx - an ozone precursor
o 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 in the heavy duty trucking industry sector, we believe that any cap and invest program should exclude on-road diesel fuel until viable alternative fuel options exist.

I support the Transportation and Climate initiative. Maine is in great need of workable transportation solutions. We need public transportation through out the state but we do not want to increase the pollution caused by fossil fuel driven vehicles. We need creative solutions to get people where they need to go without everyone having to have a car themselves. This probably means a subsidized system since the rural nature of Maine means that often there are not enough people in one place to make a profit making system viable. Transportation however is key to providing jobs and getting people to medical appointments and should not be seen as a privilege of those who can afford it or live in a place which can support a profit making enterprise. Moreover, private enterprise is less likely to want to ensure a system that does not add to the pollution of the atmosphere. Plese come up with new and creative public options.

I plan to attend the upcoming stakeholder event on May 15 in Newark, New Jersey. I recommend that the states and Georgetown Climate Center invite Ironbound Community Corporation and the New Jersey Environmental Justice Alliance to present. At the April 30, 2019 event in Boston and preceding events, we heard comments about the need for environmental justice leaders to be at the table and leading the TCI discussions. To facilitate that vision, I hope that the stakeholder event organizers compensate speakers from environmental justice communities for their time, not just their travel, to participate on May 15.

Thank you for considering my recommendation.
Staci Rubin
Senior Attorney
Conservation Law Foundation

New York State politicians seem to not want to really support electric vehicles. They have been bought and paid for buy the fossil fuel automobile dealers. Here's why I believe this to be true. First, recent sales figures, nationally, indicate Tesla is selling 77% of battery electric vehicles. New York subsidized charging stations support the 23%, not the 77%. It seems to me that all viable vehicles should be supported by states subsidized charging stations. The argument that Tesla doesn't support existing standards is bogus, since there were no standards when Tesla started selling cars and providing a bare bones charging network. Second, the adoption of electric vehicles should be made as easy and convenient as possible. NYS should require NEMA 14-50 electrical outlets in the parking area of all new construction, especially single family homes with garages or driveways. A dedicated charging station should be acceptable as an alternative. Third, there should be no artificial barriers to the sale of electric vehicles. Placing restrictions on non-dealer sales clearly indicates the lack of commitment to improving the environment. If the current auto dealers offer a superior experience to people wanting to buy an electric vehicle, people would shop at the dealers. Currently indications are that fossil fuel auto dealers are not really prepared to sell electric vehicles. For the near future, and to enhance the adoption of electric vehicles, no artificial restrictions should be imposed on their sale. The prohibition of manufacturer owned sales outlets competing with their dealers should be continued for the sake of fairness. Fourth, I propose a very generous subsidy for electric vehicles that support "Vehicle to Grid" (V2G) capability. If you do the numbers, drawing 10 KW from 1 million electric vehicles when needed is equivalent to a 10 gigawatt battery backup. Ultimately, this should reduce or eliminate the need for utility scale battery backup, since the wind doesn't always blow and the sun doesn't always shine. Battery manufacturers probably oppose this capability since they will sell fewer utility scale battery systems. Once this technology is kick started by a generous subsidy for a few thousand cars, the capability will become common and useful.