TCI Regional Policy Design Stakeholder Submissions

Tax everyone back to the stone age, that's the answer to everything in Massachusetts. I have two words for you. EXCISE TAX. Remember that scam placed on ever vehicle owner years ago? Maybe if the towns didn't STEAL that money and spend it wherever they want the roads and infrastructure would be in better shape. Massachusetts has never had a REVENUE problem but has always had a SPENDING problem.

I would urge Governor Scott to support the TCI.

The impacts of the climate crisis are getting more profound. We have a responsibility to our grandchildren to take meaningful action now. Joining with other states involved in TCI will reduce transportation emissions in a way that will keep us economically competitive with our neighboring states and create structures to to meet stricter goals than we would did not join. If we don’t join we will lose the economic benefits but we will continue to be in the same markets as states who are involved in TCI. Although Vermont actions such as increasing EV charging stations are important they would not have the same impact As joining TCI.

There many seniors living in Bellows Falls, VT senior housing facilities. Many no longer drive and depend on calling for rides with local organizations. People living in close access to town shops, library, post office, grocery stores can not walk very far so they take their cars. If we invested in small electric scooters with convienent baskets on them I think a town the size of Bellows Falls could cut down on our carbon footprint quite bit. Personally I would buy a scooter and use it in good weather rather than my car. I could charge my scooter at home however those living in housing would need charging stations and parking space.

The TCI is designed to force a massive change on American standard of living under the phony guise of climate change. It's an illegal tax on Americans to force them to give up cars. And without cars, they'll be forced to live in crowded urban cities in very small quarters due to the lack of supply and overregulations. This is part of the UN's Agenda 2030 where “governments, international organizations, the business sector and other non-state actors and individuals must contribute to changing unsustainable consumption and production patterns … to move towards more sustainable patterns of consumption and production.” And how to interpret that? Well, we have this quote from the late billionaire Maurice Strong, an UN environmental guru. “It is clear that current lifestyles and consumption patterns of the affluent middle-class … involving high meat intake, consumption of large amounts of frozen and ‘convenience’ foods, ownership of motor vehicles, numerous electrical appliances, home and workplace air-conditioning ... expensive suburban housing … are not sustainable.” And there you have it, the real reason why these initiatives are being implemented.

Local govts have devolved into ideological idiocracies, incapable of coherent, logical planning. Instead of destroying the middle class, how about finally tackling pension reform, shrinking govt, eliminating waste and fraud to find money to spend on infrastruture projects? Massachusetts is spending millions on illegal immigrants, too, money that could be used for far better purposes. We reject any effort to impoverish us to suit the globalists' agenda.

This is an excellent and comprehensive bottom-up regional initiative, but it cannot supplant the necessary comprehensive and overarching national clean transportation policy and regulations. States must continue to press Congress and the Administration to recognize and address the acute and interlinked climate change, energy and transportation crisis. More emphasis is needed on a smooth transition to clean energy sources for transportation vehicles and to rebuilding decayed infrastructure, or developing and deploying new infrastructure, such as chargers for electric buses and cars.

I feel strongly that as a society, Americans and global citizens need to move away from fossil fuel dependence and towards sustainable alternatives. I am excited to see a high-impact, regional approach to tackling carbon emissions. Its time that big businesses take some of the responsibility for the products (and related waste) they bring to market. They have plenty of profit - much more than the average citizen especially as the wealth inequality gap continues to grow. It would be great if public transit in MA could become more reliable and expansive as an alternative to cars and if electric cars could become more affordable to middle and lower class families who want to do something about climate change but can't afford some of the big initiatives like hybrid and electric cars.

I have been experimenting with public transportation as an alternitive to driving and I find mass transportation is not a practical way to travel. To get people to get out of there cars, public transportation has become simpler and faster. In the Washington DC area buses to the Metro Stations would need to come more frequently and there need to be more bus routes that take people from one suburb to another. It takes me between 1.5 to two hours and several transfersto go from Beltsville to Bethesda (a half hour trip by car) via mass transit. Perhaps a bus lane could be added to the beltway (495) and a circute bus route could go around the beltway with stops at each beltway exit. Bike share stations should be available at all metro stations to take commuters the "last mile home." In the DC metro area bus ridership is down and subway ridership is down. If buses came as frequently as subway trains I am sure bus ridership would increase.

Also could private companies be encoured to use vans or buses to make private bus lines to augment publicly funded mass transit?

February 24, 2020

Ms. Kathleen Theoharides, Chair
Transportation & Climate Initiative of the Northeast and Mid-Atlantic States
Georgetown Climate Center
600 New Jersey Avenue, NW
Washington, DC 20001

Dear Secretary Theoharides:

My name is Rita Hansen and I am the CEO of Onboard Dynamics, Inc., an early phase company and a spinout from Oregon State University that provides novel compression technology to enable the use of natural gas and renewable natural gas as a transportation fuel. I appreciate the opportunity to comment on the Transportation & Climate Initiative (TCI) Draft Memorandum of Understanding of the Transportation and Climate Initiative and I commend TCI’s goals of equity, environmental justice, non-discrimination and meaningful public participation as it develops and implements a regional policy for transportation emissions reductions.

Onboard Dynamics endorses strategies that support the transition to low-carbon transportation fuels, including geologic and renewable natural gas. Converting the Northeast and Mid-Atlantic regions’ heavy- and medium-duty freight and transit transportation network to natural gas provides a readily available, proven and cost-effective solution to accelerate the transition to a low-carbon transportation future. Further, cap-and-invest program resources invested in natural gas technologies would significantly and immediately benefit all communities by maximizing the displacement of older, higher emitting trucks and buses, including those higher emitting vehicles that operate in communities that are underserved by current transportation options and overburdened by urban pollution.
Cleaner Air Starts with Cleaner Trucks and Buses

Increased use of natural gas as a transportation fuel provides immediate and significant criteria and toxic air pollutant reductions. Fact: the cleanest commercially available heavy-duty engine in the world is powered by natural gas now and for the foreseeable future. Designed, built, and manufactured in America by Cummins Westport, this engine is certified to a 0.02 g/bhp-hr. standard, making it 90 percent cleaner than the EPA’s current NOx emissions requirement and 90 percent cleaner than the cleanest diesel engine. And in real-life study, these engines emitted lower NOx emissions than certified.

Replacing just one traditional diesel-burning heavy-duty truck with one new Ultra Low-NOx natural gas truck is the emissions equivalent of removing 119 traditional combustion engine cars off our roads. Heavy-duty equals heavy impact.

Carbon-Neutral/Negative Freight with RNG

Natural gas engines offer significant climate change benefits. Compared to diesel, natural gas engines fueled with geologic natural gas reduce CO2 and greenhouse gas emissions by at least 12 percent. When fueled with renewable natural gas (RNG or biomethane) captured from agricultural, food, landfill or wastewater, even greater CO2 and greenhouse gas benefits are achieved, up to 331 percent lower than diesel. Fueling with RNG is carbon-neutral, even carbon-negative, depending on the feed stock as shown below. No better commercially available and deployable alternative fuel option currently exists for the heavy-duty sector.

CARBON INTENSITY of TRANSPORTATION FUELS (EER-Adjusted)
<Please see the attachment for the chart inserted here.>

Address Noise Pollution

Natural gas vehicle technology affordably addresses noise pollution in urban neighborhoods. A U.S. Department of Energy study identified significant noise reduction benefits as a motivator for many refuse collection truck operators in accepting the technology, citing up to 10 decibels quieter than their diesel counterparts. A 2016 in-use study of diesel and CNG urban transit buses in Serbia found considerable reductions in noise pollution when powered by CNG.

Invest Impactfully – Emissions Reductions using Cost Effective Solutions

Investments in Ultra Low-NOx Near Zero emission natural gas vehicle technologies greatly impact communities, especially the underserved and marginalized communities in metropolitan and industrial areas. With vehicle costs close to that of diesel and fuel price differentials of up to $1.50 less than diesel per DGE, natural gas transportation provides the largest and most cost-effective reductions in transportation-related pollutants than any other powertrain option commercially available today or near-term.

UPS, Waste Management, Republic Services, Los Angeles World Airports Buses, City of Los Angeles, City of Fresno Transit, LA Metro Transit, New York’s Hunts Point fleet Industries and many other fleets recognize the exponential impact of using RNG for emissions reductions and their improving business’ bottom line. In May of 2019 UPS announced that it will purchase 170 million gallon equivalents over 7 years that will reduce GHG emissions by more than 1 million metric tons, and in October UPS announced the order of 6000 heavy duty NGV RNG trucks to double the size of their NGV fleet. In February 2020, UPS increased their RNG commitment to a total of 250 million-gallon equivalents over 7 years.

Meanwhile, Waste Management has converted approximately 9,000 of its 17,000 collection vehicles to natural gas, resulting in the largest heavy-duty natural gas truck fleet of its kind in North America. Over 40 percent of Waste Management’s natural gas fleet currently is fueled with RNG produced from landfill biogas, supporting its long-term strategy of creating a near-zero emissions collection fleet. RNG already fuels more than 32% of the over 175,000 NGVs in the U.S. today, and a growing number of fleets are taking advantage of vehicles that are available now at comparable life cycle costs to diesel vehicles and that provide transformational GHG and tailpipe emissions reductions.

As such, investments in RNG-fueled trucks and transit buses accessing ports, cities, and densely populated neighborhoods are the most immediate and fiscally responsible investment to clean our air and combat climate change. Communities get more clean vehicles having greater clean air and climate impact for the money with natural gas than with any other alternative fuel option, especially electric. No other transportation fuel is as sustainable, adaptive, and competitive across all applications and vehicle classes. And heavy-duty natural gas trucks are not demonstration science projects; they are proven, scalable, and on U.S. roads today. We will not meet emissions reduction goals or time frames without using natural gas.

Natural Gas Pays Its Way and Provides Economic Opportunity

Natural gas fueling pays into the federal highway trust fund and is ready-right-now technology. It is road-tested and backed by a mature network of manufacturers, servicers, and suppliers coast-to-coast. An established refueling infrastructure of 2,000 stations already exists.

It is also important to note that while 34 U.S. states produce geologic natural gas, the potential to produce RNG exists in every U.S. state and the District of Columbia by taking the problem of fugitive methane gas created from organic waste, capturing it, then using it to fuel traditionally heavy-carbon freight and transit transportation applications. In addition to its clean air and climate benefits, the development of RNG facilities also supports the agriculture industry with new revenue streams, addresses many cities’ solid waste issues, and impacts watershed management efforts and nitrogen runoff concerns. With these positives, the demand for RNG production is growing and new RNG facility development projects are increasing rapidly.

100% Domestic Fuels

Geologic and renewable natural gas are 100 percent domestic fuels, unlike limited electric vehicle battery components that are controlled by foreign interests and mostly sourced from conflict countries like the Democratic Republic of the Congo and China. The U.S. EPA recognizes the value of RNG and includes it in the EPA Renewable Fuel Standard (RFS) federal incentive. Similarly, several states have implemented low carbon fuel standards (LCFS) that promote the use of RNG and other renewable fuels.

More than four in ten Americans live in communities with dangerously dirty air. According to the American Lung Association, that number continues to rise, from 125 million in 2017 to nearly 141.1 million today. Cap-and-invest program investments in natural gas vehicle technologies offer the most proven, cost-effective, and immediate way to promote a low carbon transportation future, clean our air, and provide more affordable, accessible, and reliable transportation opportunities for marginalized and underserved communities.

As the TCI states in the Draft MOU, a regional program “addresses the urgent need to mitigate greenhouse gas emissions and other harmful pollutants generated by the transportation sector” which I fully agree with and offer that natural gas vehicles, especially those using RNG must be a key component to any TCI strategy if these reductions are to occur in any reasonable time frame and improving the areas of greatest need.

Thank you for your consideration, and please contact me at rita.hansen@onboarddynamics.com or 206.291.3206 with any comments or questions.

Thank you for your consideration.

Sincerely,
Rita Hansen
CEO