2/26/2020 |
John |
Dodge |
One person |
Homer |
Alaska |
We need carbon neutral transportation options starting immediately. Climate catastrophe is imminent and must be mitigated now or global civilizations will unstoppably collapse. We need carbon neutral transportation options starting immediately. Climate catastrophe is imminent and must be mitigated now or global civilizations will unstoppably collapse. |
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10/14/2020 |
Gary |
Gover |
Earth Day Mobile Bay, Inc. |
Fairhope |
Alabama |
I fully endorse the mission to design a regional low-carbon transportation policy proposal that would cap and reduce carbon emissions from the combustion of transportation fuels through a cap-and-... read more I fully endorse the mission to design a regional low-carbon transportation policy proposal that would cap and reduce carbon emissions from the combustion of transportation fuels through a cap-and-invest program or other pricing mechanism and to complete the policy development process within one year, after which each jurisdiction will decide whether to adopt and implement the policy
I endorse the requiremens to cap carbon emissions of at least 25% by 2032, increase the minimum investment in overburdened and underserved communities by at least 35%, and to invest in active transportation like better sidewalks, bicycle infrastructure, and high quality public transit.
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2/27/2020 |
Tom |
Wenzel |
citizen |
Prescott |
Arizona |
Communities of color breathe air that is 66% more polluted from tailpipe emissions than white communities in the Northeast & Mid-Atlantic region. Communities of color breathe air that is 66% more polluted from tailpipe emissions than white communities in the Northeast & Mid-Atlantic region. |
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11/5/2019 |
Sam |
Wade |
Coalition for Renewable Natural Gas |
Sacramento |
California |
Please see our attached comment letter. Please see our attached comment letter. |
191105 RNGC Comments on TCI Program Design Framework.pdf |
11/5/2019 |
Ashley |
Remillard |
Agility Fuel Solutions |
Costa Mesa |
California |
Please see attached for Agility Fuel Solutions' comments on the draft framework. read more Please see attached for Agility Fuel Solutions' comments on the draft framework. |
Agility Fuel Solutions - Comment Letter re TCI Framework (Nov 5 2019).pdf |
11/18/2019 |
Colin |
Murphy |
UC Davis Policy Institute for Energy, Environment & the Economy |
Davis |
California |
Please find attached the ITS-Davis comment on the preliminary design framework. Our apologies for the late submission. Please let us know if we can clarify or add to any part of this submission.... Please find attached the ITS-Davis comment on the preliminary design framework. Our apologies for the late submission. Please let us know if we can clarify or add to any part of this submission. |
ITS Davis - TCI Preliminary Design Comment.pdf |
11/22/2019 |
Kenji |
Tabery |
Paired Power |
Campbell |
California |
Please find below Paired Power's comments as it pertains to TCI jurisdictions policy measures to implement low-carbon transportation models. As TCI jurisdictions have designed a workplan with... read more Please find below Paired Power's comments as it pertains to TCI jurisdictions policy measures to implement low-carbon transportation models. As TCI jurisdictions have designed a workplan with the goal of developing a policy that accelerates the transition to a low-carbon transportation future and delivers a better, cleaner, more resilient transportation system that benefits all communities, while making significant reductions in greenhouse gases and other harmful air pollution across the mid-Atlantic and Northeastern region, Paired Power would like to comment that renewable energy, such as on-site solar systems, can be deployed to support electric vehicle charging infrastructure for resilient multi-modal transportation needs (e-bike, passenger vehicle, private and public fleets, electric buses, etc.). Please see World Resource Institute working paper attachment titled "Using Renewables For Electric Vehicle Demand" for more information on this cost-effective policy measure to achieve low-carbon transportation goals and eliminate GHG pollution for the region. Please let us know if we can clarify or add to any part of this submission. Thank you. |
USING RENEWABLES FOR ELECTRIC VEHICLE DEMAND_World Resource Institute Working Paper.pdf |
1/16/2020 |
Lawrence |
Sullivan |
Retired, Department of Public Health, City & County of San Francisco |
Emeryville |
California |
The rapid climate change due in large part to rapidly increasing human fossil fuel use is an existential threat to all life on earth. Thus all ways of reducing fossil fuel use are urgently needed... read more The rapid climate change due in large part to rapidly increasing human fossil fuel use is an existential threat to all life on earth. Thus all ways of reducing fossil fuel use are urgently needed. Improving publicly available mass transit and regional transit systems is an excellent way to do this. In addition, it will make affordable transportation readily available to many more people. I have traveled extensively in other parts of the world, many of which have far better public transit systems then does the United States. The city of Budapest, Hungary is an excellent example. As a city of 2 million people, not wealthy, it has nonetheless built extensive, readily available subway, light rail, and electric bus mass transit that is affordable. Even large cities in India are rapidly developing local and regional affordable mass transit such as light rail systems. Where available they are preferred transport given how difficult it is to drive automobiles. I grew up in the Boston, Massachusetts area and so was used to one of the earliest and most extensive subway and light rail public transit systems in the United States. It is still very effective. |
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2/13/2020 |
Maria |
Van Dusen |
ELM |
Berkeley |
California |
I support this initiative as a practical and needed way to reduce dependence on fossil fuels. I am now using an electric bike for my errands and buses and subways for longer distances. I am... read more I support this initiative as a practical and needed way to reduce dependence on fossil fuels. I am now using an electric bike for my errands and buses and subways for longer distances. I am pleased to not need to buy another car and hope changes in transportation infrastructure will make this possible for others as well. |
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2/26/2020 |
IRVIN |
DAWID |
Planetizen.com |
BURLINGAME |
California |
Very supportive of the plan. We need to end the "carbon externalithy." However, adding to the price of gasoline and diesel can be politically a tough sell. I hope you will allow those... read more Very supportive of the plan. We need to end the "carbon externalithy." However, adding to the price of gasoline and diesel can be politically a tough sell. I hope you will allow those states that opt to implement the initiative to do so, and those states that opt not to will have the option to join later, perhaps when political changes occur, and climate change becomes more of a concern and action item. |
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2/26/2020 |
Dan |
Esposito |
Individual |
Manhattan Beach |
California |
Please reduce emissions, and invest in a cleaner transportation system. Thank you. Please reduce emissions, and invest in a cleaner transportation system. Thank you. |
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2/26/2020 |
LONNA |
RICHMOND |
concerned resident |
Muir Beach |
California |
We need polluters to pay their fair share for the damage they are causing, and we need to act now!
Please join the plan to reduce transportation emissions.
It is important that the... read more We need polluters to pay their fair share for the damage they are causing, and we need to act now!
Please join the plan to reduce transportation emissions.
It is important that the states take action on the climate crisis now.
We demand a strong program that invests in public transportation, biking, walking, and prioritizes equity. |
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2/26/2020 |
Claire |
Perricelli |
Mrs. |
Eureka |
California |
We MUST refigure our methods of transportation to account for emissions. I hope we are embracing all possible solutions. More charging stations, more mass transit, electric buses, rail, etc... read more We MUST refigure our methods of transportation to account for emissions. I hope we are embracing all possible solutions. More charging stations, more mass transit, electric buses, rail, etc. |
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2/26/2020 |
Stevie |
Sugarman |
Earth Evolution |
Malibu |
California |
I support the Transportation and Climate Intiative.
I support the Transportation and Climate Intiative.
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2/26/2020 |
Rudy |
Stefenel |
Thorium Energy Alliance |
Milpitas |
California |
As you know, most Republicans are climate-crisis deniers and most Democrats think that “renewables” especially wind and solar can solve our worsting climate-crisis. A little over a decade ago, I... read more As you know, most Republicans are climate-crisis deniers and most Democrats think that “renewables” especially wind and solar can solve our worsting climate-crisis. A little over a decade ago, I agreed with those Democrats. Since then, I have learned a lot and changed my mind. I have become convinced that the world's climate-crisis CANNOT be solved by phasing out nuclear reactors and moving to mainly “renewables”. But, I am all for phasing out fossil fuels ASAP. By the way, I absolutely won't vote for Trump. Here are two short web addresses to YouTube videos that go into more detail. I encourage you to view them for the facts. They are:
https://tinyurl.com/mqzod9f
and
https://tinyurl.com/w687uwr
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2/26/2020 |
Tara |
Strand |
Concerned resident |
North Hollywood |
California |
As someone who feels burdened every day by the ecological crisis we've brought upon ourselves and all living things, I am so grateful to hear about this initiative. My biggest dream is that... read more As someone who feels burdened every day by the ecological crisis we've brought upon ourselves and all living things, I am so grateful to hear about this initiative. My biggest dream is that we might turn what could be our greatest doom into our greatest opportunity, and it's all about steps like this done the right way. Still, there have a been a lot of half (and less than half) measures taken towards addressing this emergency, so I urge you to take big, bold, science-guided, community-guided steps that meet the level that this emergency demands. Also, as justly and equitably as possible, and covering as many facets as possible.
And as a Californian who is frustrated at those half-measures taken by our Governor, I urge our state to implement programs like this as well. And immediately! We've already lost too much time to make this steady and easy, and inaction will make things even harder than that very soon.
Thank you for your efforts and your consideration,
Tara Strand |
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2/27/2020 |
Doug |
Smith |
n/a |
Fort Bragg |
California |
This is a good start. Please also invest in and build infrastructure that reduces carbon emissions radically. There is no time to lose. Thank you This is a good start. Please also invest in and build infrastructure that reduces carbon emissions radically. There is no time to lose. Thank you |
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2/27/2020 |
joe |
smith |
n/a |
el cajon |
California |
the
Transportation
and Climate Initiative (TCI). Clean Air Council and
other
advocates across the region believe this is a critical step to improving transportation... read more the
Transportation
and Climate Initiative (TCI). Clean Air Council and
other
advocates across the region believe this is a critical step to improving transportation and addressing the climate
crisis.
If designed correctly, this program could help
to create safe roads for biking and walking, more frequent and reliable public transportation, greater access to electric vehicles, and a more equitable system with cleaner transportation options for everyone in the region.
Transportation is the country’s and region’s
leading source of carbon emissions. Clean Air Council believes TCI will help to clean this sector up, but
we need your help to move it forward.
Fossil fuel companies are hard at work getting opponents to leave negative feedback in the program’s public comment portal, and we need environmentalists like you to help counteract that. |
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2/27/2020 |
Rene |
McIntyre |
Democrat |
San Francisco |
California |
Please remember that we are not the only species on this planet. We share the Earth with other species, and we should be mindful of that. Please remember that we are not the only species on this planet. We share the Earth with other species, and we should be mindful of that. |
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2/27/2020 |
Evan |
Neyland |
ChargePoint, Inc. |
San Francisco |
California |
ChargePoint offers the following comments on the draft Memorandum of Understanding (MOU) regarding the Transportation Climate Initiative (TCI). We recognize all the work put into this initiative... read more ChargePoint offers the following comments on the draft Memorandum of Understanding (MOU) regarding the Transportation Climate Initiative (TCI). We recognize all the work put into this initiative thus far and appreciate the efforts to develop this MOU and the opportunity to provide comments.
ChargePoint is the world’s largest electric vehicle (“EV”) charging network with more than 108,000 Level 2 and direct current fast charging (“DCFC”) EV charging spots. ChargePoint designs, develops, and deploys residential and commercial AC Level 2 and DCFC charging stations, cloud-based software applications, data analytics, and related customer and driver services aimed at creating a robust, scalable, and grid-friendly EV charging ecosystem.
ChargePoint supports the adoption of a regional cap-and-invest program across the Northeast and Mid-Atlantic in order to reduce greenhouse gas emissions, improve air quality, and promote cleaner transportation solutions within the region. The transportation sector now presents the biggest threat to long-term state and regional greenhouse gas reduction targets, and transportation emissions are likely to continue to rise should policymakers not take action to address this trend. A well designed cap-and-invest program will help gradually and cost-effectively decarbonize transportation, improve local air quality and public health in the region, promote energy security and the use of low-carbon alternative fuels, and create economic and job opportunities in the region for local businesses offering cleaner, more efficient transportation solutions.
Similar clean fuels policies at the state level have proven to be environmental and economic successes where adopted. In California, the Low Carbon Fuel Standard has led to a doubling of alternative fuel use since 2011(1) and a 10% reduction in CO2 emissions from transportation(2). In British Columbia, the Renewable and Low Carbon Fuel Requirements Regulation is credited with 25% of the province’s emissions reductions between 2007 and 2011. Both B.C. and California have seen some of the highest economic growth relative to their respective national averages over the same time period(3)(4). To this end, we offer comments on several aspects of the policy’s design in line with the Initiative’s key policy objective to stimulate transportation emissions reductions in a least-cost and equitable way.
Comments RE: Investment of Proceeds from Auction Allowances
ChargePoint recognizes the differences in each participating jurisdiction’s transportation market and policy objectives, and we therefore support the use of local criteria in investment decisions. However, we advocate for the adoption of common principles when reinvesting allowance proceeds, such as competitive bidding, long-term cost effectiveness, and customer choice. The investment of allowance proceeds will play a critical role in shifting behavior and stimulating low-carbon fuel switching which will in turn serve to lower transportation emissions in the region. The supply of low-carbon fuels in existing clean fuels programs has proven to respond positively to increased demand(5) and the ability to ramp up production when investment materializes. Because of this, it is important that there is transparency around allowance proceed reinvestment such that those price signals can be incorporated into business and consumer investment decisions.
In California, even where electricity prices are relatively high, research has found that EVs present the lowest-cost option for large-scale deep decarbonization of the transportation sector(6). In fact, as battery technology improves and the cost of EVs continues to decline, EVs have the potential to provide a negative abatement cost option (i.e. they offer consumer savings over traditional vehicles today). This forward view towards investing in scalable and cost-effective solutions will be key to achieving policy objectives, while recognizing the need for a comprehensive portfolio approach.
ChargePoint also proposes customer choice play a strong role in allowance proceed reinvestment. This stimulates competition in the market which drives innovation and benefits consumers in the long run. Allowing low-carbon fuel suppliers to compete for allowance proceeds will naturally drive efficiencies in how the proceeds are spent and help lower the cost of the policy.
Comments RE: Market Linking
Without more information on the rules and restrictions that may govern the potential linking mechanism between the TCI and other emissions markets, ChargePoint neither supports nor opposes linking at this stage. We would caution the Initiative to consider several key economic and environmental ramifications of linking, namely: 1) how allowances under different programs with varying degrees of stringency compare to one another in terms of incentivizing emissions reductions, 2) how linking to programs that cover non-transportation emissions may disincentivize emissions reductions within the transportation sector to the detriment of the overall goal of the TCI; and 3) the transfer of allowance proceeds between markets and how those proceeds are reinvested in transportation. While linking can be an effective tool to drive efficiencies and stabilize prices in a market, the unintended consequences of diluting the incentive to reduce transportation emissions within participating jurisdictions via linking must be carefully considered.
Comments RE: Offsets
ChargePoint supports the role of verifiable carbon offsets as a cost containment mechanism and urges the Initiative to consider offsets from eligible EV charging, such as those approved under the Verified Carbon Standard’s (VCS) approved methodology for electric vehicle charging systems(7). VCS methodologies are independently proven to yield verifiable, additional emissions reductions and allowing this specific pathway, or a locally adopted adaptation, would further support the policy’s overall goal of reducing emissions from transportation and catalyzing the use of low-carbon alternative fuels. A market for these verified emissions reductions and the supporting infrastructure already exists today and could easily be leveraged under the Initiative.
By establishing a strong cap-and-invest program across the transportation sector, the TCI will enable fuel producers to introduce an increasing mix of clean, alternative fuels, promote fuel switching and cost savings among consumers, diversify the region’s fuel mix and reduce its dependence on volatile global petroleum markets, and stimulate investment in homegrown clean transportation solutions.
For these reasons, we strongly support the TCI.
We greatly appreciate the opportunity to provide these comments. If you have any questions or seek further clarification, please contact Evan Neyland at evan.neyland@chargepoint.com.
Sincerely,
Evan Neyland
References:
(1) Alternative fuel supply increased 109% between 2011 and 2019 (CARB data dashboard, Feb 3, 2020).
(2) Huseynov S, Palma MA (2018). ‘Does California’s Low Carbon Fuel Standards reduce carbon dioxide emissions?’. PLoS ONE 13(9): e0203167.
(3) Bureau of Economic Analysis.
(4) Statistics Canada.
(5) Non-ethanol alternative fuel supply in California is highly correlated with LCFS credit prices in CA (r2 = 0.9), (CARB data dashboard, Feb 24, 2020).
(6) Fingerman et al, 2018. ‘California’s Low Carbon Fuel Standard: Modeling financial least-cost pathways to compliance in Northwest California’. Transportation Research, vol. D 63, pp. 320 – 332.
(7) Verified Carbon Standard (VCS) Methodology VM0038. |
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