2/28/2020 |
Shai |
Sahay |
POET, LLC |
Washington |
District of Columbia |
On behalf of POET, LLC, I am submitting the attached comments on the TCI Draft Memorandum of Understanding and Prospective Model Rule. Please let us know if you have any questions or need... read more On behalf of POET, LLC, I am submitting the attached comments on the TCI Draft Memorandum of Understanding and Prospective Model Rule. Please let us know if you have any questions or need additional information. |
POET February 2020 Comments on TCI MOU and Prospective Model Rule.pdf |
2/28/2020 |
Stewart |
Schwartz |
Coalition for Smarter Growth |
Washington |
District of Columbia |
See attached file See attached file |
2020.02.28 CSG Comments on TCI MOU.pdf |
2/28/2020 |
Paul |
Wierenga |
IFTOA |
Washington |
District of Columbia |
Please see enclosed comments. Please see enclosed comments. |
IFTOA Comments on the Proposed Transportation and Climate Initiative (Feb. 28, 2020).pdf |
2/28/2020 |
Drew |
Stilson |
Environmental Defense Fund |
Washington |
District of Columbia |
Environmental Defense Fund (EDF) appreciates the opportunity to provide the attached comments on the Draft MOU for the Transportation and Climate Initiative.
Thank you,
Drew... Environmental Defense Fund (EDF) appreciates the opportunity to provide the attached comments on the Draft MOU for the Transportation and Climate Initiative.
Thank you,
Drew Stilson |
EDF Comments on Draft TCI MOU.pdf |
2/28/2020 |
Doulas |
Kantor |
NACS/NATSO/SIGMA |
Washington |
District of Columbia |
Please see the attached file. Please see the attached file. |
Association Comments on TCI Draft MOU.pdf |
2/28/2020 |
Brendan |
Williams |
PBF Energy |
Washington |
District of Columbia |
Attached are PBF Energy's comments in response to the draft Memorandum of Understanding (“MOU”) regarding the Transportation & Climate Initiative (“TCI”), as proposed by the Georgetown... read more Attached are PBF Energy's comments in response to the draft Memorandum of Understanding (“MOU”) regarding the Transportation & Climate Initiative (“TCI”), as proposed by the Georgetown Climate Center (“GCC”).
Regards,
Brendan Williams
PBF Energy |
20200228 PBF TCI Cmts FINAL.pdf |
2/28/2020 |
Patrick |
Kelly |
API |
Washington |
District of Columbia |
See attachment See attachment |
TCI Draft MOU and Modeling API Comments.pdf |
2/28/2020 |
Allen |
Greenberg |
Self |
Washington |
District of Columbia |
As detailed in the attached comments, the primary objective that TCI should strive to achieve is to reduce transportation emissions as much as possible (meaning a 25% reduction from the Reference... read more As detailed in the attached comments, the primary objective that TCI should strive to achieve is to reduce transportation emissions as much as possible (meaning a 25% reduction from the Reference Case, instead of a 20 or 22% reduction which are also under consideration). To accomplish this, TCI should aim for the adoption of as high a variable cost to driving and parking as feasible, enabled politically by converting fixed and hidden driving and parking costs to usage pricing, where total costs to most drivers will actually go down. Incentives applied at the level of the individual driver are critical to meeting TCI’s carbon reduction goal. A transportation re-pricing policy bundle is specified in the submission and then modeled. It was found to reduce year-2030 vehicle miles traveled and carbon emissions by 23.2%. Polling results on transportation re-pricing were also presented and it was found to be more acceptable to the public (including those in the Northeast) than hiking fuel taxes, even if fuel tax revenues are refunded through other tax rebates. |
PAYD_Pricing_CarbonEmissions_TCI_Comments.docx |
2/28/2020 |
Stephen |
Soule |
WGL |
Washington |
District of Columbia |
Washington Gas, which has about 765 vehicles in its fleet, supports the growth and development of − and transition to − low-carbon transportation fuels, including geologic and renewable natural... read more Washington Gas, which has about 765 vehicles in its fleet, supports the growth and development of − and transition to − low-carbon transportation fuels, including geologic and renewable natural gas (RNG).
There are several factors that motivate the company’s support. For one, medium and heavy-duty vehicles contribute a disproportionate amount of pollution in urban areas throughout the country, and in many cases are the most significant contributors to ozone pollution and smog. (footnote 1) This is not because cleaner technology does not exist, but rather because cleaner technology is not being deployed in effective numbers.
Converting medium and heavy-duty vehicles to natural gas can bend the emissions curve immediately, providing a ready-now, proven and highly cost-effective solution for a low-carbon transportation future. Compared to diesel, for example, natural gas engines fueled with geologic natural gas reduce CO2 and GHG emissions by at least 12%. (footnote 2)
When fueled by RNG, CO2 and GHG emissions can be reduced by up to 331%. (footnote 2)
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 medium and heavy-duty vehicles.
Washington Gas knows firsthand the value of NGV in its ongoing commitment to implementing sustainable business practices in how it manages its own operations, and that includes adopting NGV for its fleet.
In fact, in 2011, four years prior to the Paris Agreement, Washington Gas set 2020 targets for GHG reductions for its fleet and facilities, and to lower the carbon intensity of the gas it delivers. The company exceeded those goals in 2016. Washington Gas then announced new, updated targets for 2025, including carbon neutrality for its fleet and facilities by 2025.
Currently, the company has 289 NGVs, which equates to 38% of its current fleet. By adding dedicated Compressed Natural Gas (CNG) and bi-fuel CNG vehicles to the fleet, and by taking active measures to manage fleet emissions, Washington Gas has significantly reduced the annual per vehicle emissions intensity for its fleet.
Washington Gas also monitors liquid fuel usage in bi-fuel vehicles to ensure drivers are utilizing CNG as their primary fuel source, and it monitors the liquid fuel gallons that are displaced by CNG usage each year. The company has seen an increase in this displacement as its CNG fleet has grown and CNG fuel usage awareness has gained traction throughout the company.
1 https://www.ngvamerica.org/environment.
2 Dependent upon RNG source. Reductions of 45% up to 331% compared to diesel; values based on CARB LCFS program data under CA-GREET 3.0.
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3/6/2020 |
Adam |
Winer |
Consumer Reports |
Washington |
District of Columbia |
Apologies for the late submission. The comments from Consumer Reports are provided at a file attachment. Thank you for the opportunity to comment, and for considering our input.
- Adam... read more Apologies for the late submission. The comments from Consumer Reports are provided at a file attachment. Thank you for the opportunity to comment, and for considering our input.
- Adam Winer, Consumer Reports |
Consumer Reports Comments on Draft TCI MOU.pdf |
3/19/2020 |
Daniela |
Ochoa |
DC Sierra Club, Ecomadres Maryland |
Washington |
District of Columbia |
We desperately need a Climate Regional Policy. Now more than ever we need to LIVE, Live our values, take a LEAP and boost ASAP our smarth growht initiatives with clean energy transportation... read more We desperately need a Climate Regional Policy. Now more than ever we need to LIVE, Live our values, take a LEAP and boost ASAP our smarth growht initiatives with clean energy transportation systems, investing in electric vehicles and charging infrastructure, clean public, transportation, walking and biking mobility. Please let me know if you still receive this comment, thanks you! |
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9/30/2020 |
Drew |
Stilson |
Environmental Defense Fund |
Washington |
District of Columbia |
EDF respectfully offers the attached comments and recommendations to the Transportation and Climate Initiative in response to the information presented on the September 16 webinar. Thank you for... read more EDF respectfully offers the attached comments and recommendations to the Transportation and Climate Initiative in response to the information presented on the September 16 webinar. Thank you for your consideration of these comments. |
EDF Comments on September 16 TCI Webinar.pdf |
9/30/2020 |
Patrick |
Kelly |
API |
Washington |
District of Columbia |
See attached. See attached. |
API Comment to TCI 9.20.pdf |
10/15/2020 |
Tom |
Quinn |
na |
Washington |
District of Columbia |
Hi:
Please show leadership by taking the following measures:
1. A cap on carbon emissions of at least 25% by 2032
2. An increase in the minimum investment in... read more Hi:
Please show leadership by taking the following measures:
1. A cap on carbon emissions of at least 25% by 2032
2. An increase in the minimum investment in overburdened and underserved communities (>35%)
3. Request that investments be put towards active transportation like better sidewalks, bicycle infrastructure, and high quality public transit
Thank You,
Tom Quinn
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11/12/2020 |
Patrick |
Kelly |
API |
Washington |
District of Columbia |
See attached. See attached. |
API Comment to TCI 11.20.pdf |
11/20/2020 |
Peter |
La Fountain |
BlueGreen Alliance |
Washington |
District of Columbia |
Please find attached comments from the BlueGreen Alliance, the Labor Network for Sustainability, and the New Jersey Work Environment Council, regarding proposed TCI equity commitments. Please find attached comments from the BlueGreen Alliance, the Labor Network for Sustainability, and the New Jersey Work Environment Council, regarding proposed TCI equity commitments. |
BGA LNS NJWEC TCI Comments.pdf |
2/28/2020 |
Dallas |
Burtraw |
Resources for the Future |
Washington DC |
District of Columbia |
See attached file See attached file |
Comment - TCI and Electricity - RFF.pdf |
2/18/2020 |
Hugh |
Rogers |
Mr. |
WASHINGTON DEPOT |
Connecticut |
Dear Regional Leaders,
TCI will reduce transportation greenhouse gases, which is important because that will help mitigate global warming and improve our air quality. With the fees... read more Dear Regional Leaders,
TCI will reduce transportation greenhouse gases, which is important because that will help mitigate global warming and improve our air quality. With the fees collected from fossil fuel imports much needed improvements in our public transit system will be addressed including safe and reliable rail and bus service, electric vehicle infrastructure, and complete streets for bicycles and pedestrians. Those without choices have to drive and the resultant fuel consumption and traffic congestion damages our environment, public health, and quality of life.
Thank you, Governor Lamont for being involved in the regional design process; please have Connecticut formally sign on to TCI.
Please TCI leaders, sign on to the most aggressive greenhouse gas emissions cap.
I would also ask that a TCI policy has equity and investment in overburdened and under served communities as a first and foremost priority.
Sincerely, Hugh Rogers
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11/17/2019 |
Peter |
Cook |
Resident of NJ |
Washington Township |
New Jersey |
Of course reduction in GHG and related emissions is a worthwhile effort, however, I think this tax and trade policy will reduce the competitiveness of the states involved and result in more... read more Of course reduction in GHG and related emissions is a worthwhile effort, however, I think this tax and trade policy will reduce the competitiveness of the states involved and result in more businesses moving from the area. Already many of these states are losing population and is jobs leave the area, residents will soon follow. This could have the impact of reducing GHG emissions by having less people on the highways, but the goal should not be to do anything to leave the states.
In addition I feel this does not address the high polluting older vehicles that are on the road by focusing on the GHGs. Technology could be developed to identify the extremely high polluting vehicles and getting them off the road. Perhaps high polluting vehicles could be targeted for purchase or removal from the states by some other method. Many times these are low MPG vehicles as well which results in more carbon generation than more efficient vehicles.
Lastly, the efforts to improve the traffic flow such as improved traffic light timing using developing AI could increase quality of life as well as reduce GHG emissions. This could be a technology that would bring high tech jobs and engineers to the area. Using other modern technology e.g. through Waze or other apps, employers could be enticed to stagger their employee commute to minimize traffic delays due to rush hour. The technology today lends itself much more today than in the time of the old Employee Trip Reduction Program. Besides flex hours, employers could be encouraged to let employees work from home.
In summary, I am against the GHG tax and trade program because I believe it will make these states an even less attractive place to establish a business. |
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11/5/2019 |
Connor |
Dolan |
Fuel Cell and Hydrogen Energy Association |
Washington, D.C. |
District of Columbia |
|
Statement of Support for TCI Framework.pdf |