TCI Regional Policy Design Stakeholder Submissions

I am writing in strong support of Vermont's participation in the Transportation and Climate Initiative.

Vermont has set aggressive, but entirely appropriate, goals for emissions reduction and the movement away from fossil fuels. These goals have been accepted by the state and by Governor Scott. But as things now stand those goals a like a fairy tale -- something that entertains the reader, but nothing that is actually real.

Our state is FAR behind on the goals it has set to help us fight climate change. Our country is FAR behind on taking positive steps to fight climate change. My and your children and grandchildren will end up paying the price for this inaction.

TCI would represent a significant step forward in turning Vermont's current climate change fairy tale into reality. This cap and invest program covers the electric sector in the Northeast. It has proven very successful, reducing consumer costs and carbon pollution from the power sector by 40%.

Transportation is the one area where we can make the biggest difference in the most important issue of our time.

On behalf of our children and grandchildren I hope Vermont will formally join TCI.

Thank you,

Duncan McDougall

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.

An increase in fuel tax, on an already overtaxed state like Maine is absurd. The state is bigger that the rest of new england, and very rural. Increasing the fuel tax will do nothing but further harm our lower income, scree the middle class, and make the state unbearable for our elderly and retired. Not smart. Stay out of this agreement!

Comments on Program Design as Outlined on Sept. 16 and 29, 2020 TCI Webinars – Modeled 2032 Max Mileage Reductions from Reference Case of Only 2.0% is a Program Failure

Comments on Program Design as Outlined on Sept. 16 and 29, 2020 TCI Webinars – Modeled 2032 Max Mileage Reductions from Reference Case of Only 2.0% is a Program Failure

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.

NGVAmerica is the national trade organization dedicated to the development of a growing, profitable, and sustainable market for vehicles and carriers powered by clean, affordable and abundant natural gas or biomethane. Our 200-plus member companies produce, distribute, and market natural gas and biomethane, manufacture and service natural gas vehicles, engines, and equipment, and operate fleets powered by clean-burning gaseous fuels across North America.

Several NGVAmerica member company representatives and I attended TCI’s April 30th Technical Workshop in Boston and participated via live stream in TCI’s May 15th Workshop in Newark. I provide these comments on behalf of our industry to compliment those discussions.

NGVAmerica 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 accelerates 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, particularly those underserved by current transportation options and overburdened by 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 engines 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 up to 17 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 125 percent lower than diesel. Fueling with RNG is carbon-neutral, even carbon-negative, depending on the feed stock. No better commercially-available and deployable alternative fuel option currently exists for the heavy-duty sector.

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
Investments in Ultra Low-NOx and Near Zero emission natural gas vehicle technologies greatly impact underserved and marginalized communities. 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.

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.

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 renewable natural gas 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 the Northeast’s solid waste issue, and impacts watershed management efforts and nitrogen runoff concerns.

Geologic and renewable natural gas is a 100 percent domestic fuel, 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.

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.

Thank you for your consideration.

Alternative fuel vehicles, including hydrogen fuel cell electric vehicles, will play an important role in decreasing transportation CO2 emissions in the Northeast and Mid-Atlantic. Ensuring access to reliable and affordable hydrogen fueling infrastructure will play a key role in supporting consumer adoption of fuel cell electric vehicles, thereby reducing CO2.

To that end, TMNA supports efforts by TCI to ensure that the Reference Case accurately represents the need for this fueling infrastructure. NEMS’ fuel availability methodology is based on the historical relationship between vehicle stock and refueling stations. However, given the historical shortfall in hydrogen refueling stations, a Reference Case based on this historical relationship could lead to further underinvestment in hydrogen stations.

If improved to address this problem, NEMS could be used as a tool to assist in projecting how much overall hydrogen infrastructure will be needed to support a growing population of fuel cell vehicles in the TCI Regions, and this infrastructure requirement could be communicated to the states as part of investment planning in infrastructure. It should be noted, however, that hydrogen infrastructure works best when taking into account travel patterns, local vehicle adoption, station redundancy, etc., rather than distributed evenly across all regions. Industry can provide the best guidance for specific placement and number of hydrogen stations needed. It should also be noted that hydrogen stations currently require up to 2 years from planning to opening in order to find land, obtain permits, and complete construction.