TCI Regional Policy Design Stakeholder Submissions

Mass Governor must bring this to the people. He must stop acting like a dictator. Passing this tax on businesses like the one I own will kill any further growth and adding workers. There is no way of passing on these exsorbant added cost in the industry. Governor Baker stop acting like a dictator, we are a government of the people, you work for us! Stop wiping out industries that you don't care about. We can not all be in BioMed and IT that continue to get massive Taxes Breaks.

Retired here in south western Pennsylvania which has some of the dirtiest air in the country. I worked for the Air Pollution Control Bureau back in the early seventies and attended Duquesne University on an EPA Fellowship earning a MS in chemisty. We had poor air quality then and still have poor air quality. I would like to think that we have better air quality fifty years later but that doesn't seem to be the case. I have two grown children that are both asthmatic, most likely to the poor air quality when they were growing up. The general health of most citizens here in western Pennsylvania could be better if the air quality would improve.

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.

I live in NJ. My husband and I will be moving soon to CT to be near our older son and his family. Our other son lives in DC. I would LOVE for train travel to be more convenient and more frequent, as it is in Europe. For day trips into NYC, short vacations in New England, PA, DE, MD and visits to DC, train travel is (or should be) much safer and better for the environment than traveling by car. Yet it just isn't simple. Even now, living just outside NYC, we find it easier to drive into Manhattan for restaurants, museums and entertainment, than taking the train. More expensive, but not to be stuck in one of the Penn Stations for an hour, because the trains are so infrequent (if they are even running at all...hello Uber!). This just shouldn't be our reality in the "greatest country."

I ask that tyou give urgent consideration to Transportation anc Climate initiave. Toady we are seeing and feeling and experiencing the negative impacts of climate change. As a mother with children who will inheret this climate, I must ask to to give full consideration to deviloing low carbo initiative for transportation. We have had the technology for many years and we are way too late to be at this stage. Please put action above greed in our current system. These initiatvies should also give us an oportunity for new businesses and education avenues for the future.

While AGC/VT is interested in working towards solutions regarding our climate and environment we believe that more thought be put into this program. Specifically we oppose adding the tax to diesel fuels. We have been told that dyed diesel and diesel used in heavy equipment like excavators are not intended to fall into the TCI tax, but its not clear how it would be avoided. The diesel used by the construction industry is typically delivered in bulk and is "dyed diesel". Currently there are requirements from ANR in some cases to identify total uses of those fuels and the reason is for potential future carbon taxation according the ANRs clean air division. It is important for agencies and TCI advocates to understand that these fees/taxes will be passed on to individuals and government agencies employing services from the private sector. This will either increase costs of roads, bridges and buildings, or provide an opportunity for organizations outside of TCI districts to step in and under bid for services which could kill local economies. At the very least adding a 30 tax to diesel would result in an additional cost of approx $16.20 for a truck to run from White River to just Montpelier or $7000-10000+ per construction vehicles annual usage. These costs multiplied by the sheer volume of commercial and government work would have a major effect the state and private consumers in the multi millions. This new expense would be a heavy lift for the already challenged appropriations of our state.

If/When TCI comes to be, Vermont is expected to benefit from $30-60 million per year depending on the source I have spoken with. It is imperative that any monies gained by this transportation program have a nexus to transportation. The majority of the fuel taxes we pay already go to general fund projects while our road and bridge infrastructure continue to age and have been level funded at approximately 1/3 of VTRANS budget requests. This is an emerging crisis as the state depends of federal funds which are based on "grades" of our road maintenance. TCI funds should not go in the general fund, clean water fund or go to unfunded pension liabilities. It should stay in transportation whether it would be used to modernize our roads, or improve public transportation so more people use it.

I recommend that Vermont join the Transportation Climate Initiative (TCI) that is being developed for states in this northeast region of our country.

We now know that climate emissions in Vermont have been increasing in the last two or three years despite a clear legislative and policy commitment to reduce these emissions. We also know that climate emissions from transportation account for the largest share of recent climate emission increases. We also know that transportation is an activity that may be addressed most effectively on multi-state, regional basis. And we have seen that the Regional Greenhouse Gas Initiative has proven to be an effective tool for reducing climate emissions from electricity generation.

I am a member of a church in South Burlington that sees the climate crisis as a moral crisis for all mankind and that we all have a responsibility to do what we can to reduce climate emissions. We have been at work for several years to walk our talk by reducing the climate emissions we contribute. Our church has with its own resources taken steps which, with help from Efficiency Vermont and Vermont Gas, enables us to reduce our carbon emissions associated with natural gas and electricity use by more than 50 percent. We want to address climate emissions from driving our personal vehicles but this requires support, just as Efficiency Vermont and Vermont Gas helped us with improving the energy performance of our church building and our individual home.

The TCI offers Vermont a potential source of revenues to support steps to reduce transportation emissions and to do so in way that will help most the people least able to afford newer, more fuel efficient, lower emission cars and trucks.

I ask that Vermont join in the emerging new TCI and to endorse actions by the TCI program that will help all Vermonters to reduce climate emissions resulting from our transportation activities.

It is now obvious that climate change is happening and causing very big impacts that include significant increases in annual rainfall in Vermont, warmer winters in Vermont which threaten the future of skiing in Vermont, accelerate the incidence of lime disease, and threaten the long term viability of our maple syrup industry. These impacts are the obvious ones that confront us in easy to observe ways. Scientists tell us that the Vermont forests, lakes, and wildlife communities are all being transformed by these changes in very negative ways.

It is also important to recognize that the TCI program can make big positive contributions to the State's economy. This has happened with energy efficiency activity, which is now a big Vermont employer, and the solar industry, which had until recently been a fast growing business in Vermont that provided jobs and produced income for Vermonters across the State. The Vermont Clean Energy Development Fund finances annual economic assessments of the clean energy sector and has with these annual studies has documented the large direct employment and income benefits of these clean energy businesses. The TCI can and should be harnessed to build upon this progress.

I urge that Vermont sign the TCI memorandum of understanding and commit the policy and program leadership needed to build an effective program. Such new programs require hard work to make them work and to avoid pitfalls. I plead for the Governor and the Legislature to do the hard work of negotiating an effective TCI program that will benefit Vermont and serve Vermont's stated commitment to achieving the Paris Climate Goals, which will benefit all mankind.

Thank you for this opportunity to comment.

Sam Swanson

I believe Vermont needs to coordinate with our neighboring states to get our emissions from transportation under control. I live on the Connecticut River. I own a car, but try to drive as little as possible. I take the Amtrak occasionally if I have business in Northern Vermont. I would take the train more often if it ran more frequently. We need more light rail in our state and in New Hampshire. Once upon a time, there were trolleys connecting small towns. Light rail could fill that same niche.
We need additional funding to provide creative non-polluting transportation initiatives tailored to the needs of small towns and rural lifestyles.

I feel we need to move fast on lessening the impact of climate chaos. One way is to remove fossil fuels from all vehicles, particularly busses and
trucks. We need facilities to promote this and to do this as quickly as possible. We are moving far too slowly while the planet is warming up much too quickly. If we think it is expensive now, watch the future.