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2/24/2020 |
Sherrie |
Merrow |
NGVAmerica |
Washington |
District of Columbia |
Please see uploaded NGVAmerica comment letter.
Thank you,
Sherrie Merrow
Director, NGVAmerica State Affairs Please see uploaded NGVAmerica comment letter.
Thank you,
Sherrie Merrow
Director, NGVAmerica State Affairs |
NGVA Comments on TCI MOU - Feb 24 2020.pdf |
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2/26/2020 |
Zohal |
Khan |
DC |
Washington |
District of Columbia |
Climate change is the biggest issue of our time. Our current public transportation infrastructure in the US is quite lacking. We must build extensive public transportation networks and upgrade... read more Climate change is the biggest issue of our time. Our current public transportation infrastructure in the US is quite lacking. We must build extensive public transportation networks and upgrade existing networks to be carbon neutral. |
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2/26/2020 |
Jordan |
McGillis |
Institute for Energy Research |
Washington |
District of Columbia |
The Institute for Energy Research opposes the Transportation and Climate Initiative (TCI).
The justification offered for TCI is that greenhouse gas emissions constitute a threat to... read more The Institute for Energy Research opposes the Transportation and Climate Initiative (TCI).
The justification offered for TCI is that greenhouse gas emissions constitute a threat to the people of the region, but the Draft Memorandum’s assertions are overstated. The Draft Memorandum claims, “climate change poses a clear, present, and increasingly dangerous threat to the communities and economic security of each Signatory Jurisdiction.” But while some portions of the TCI region may be made worse off by climate change, other portions are likely to be made better off. It is widely accepted that cities at northerly latitudes, such as Buffalo, New York, may benefit from a warming climate. It is reasonable to speculate that Buffalo and other municipalities across the TCI region will become more attractive destinations for in-migration and will reap the rewards of increased human capital and weather more conducive to productivity.
Even taking the Draft Memorandum’s climate claims at face value, we must still ask: Will TCI provide relief to the region’s residents? The answer is a resounding “no.”
The numbers presented in the December 2019 TCI webinar show this failure. The TCI slides claim the proposal will reduce regional transportation-sector emissions by between 20 and 25 percent. The same documents cite a reference case—i.e., a scenario without the TCI emissions cap—in which emissions fall by 19 percent. In the no-cap reference case, emissions tally 206 million tons in 2032; in the scenario with the TCI cap set at a 20-percent reduction level, 2032 emissions are 202 million tons—just 4 million tons lower. In the context of the more than 30 billion tons of greenhouse gases emitted globally each year, the climate impact of TCI’s incremental reduction of 4 million tons is too small for measurement.
Meanwhile, the program will remove over $1 billion annually from the regional economy for allowance purchases. This will harm every resident of the region through increased transportation expenses. These costs will not only be seen by motorists in the form of higher fuel prices; urban residents who prefer public transit will also face higher prices, such as for goods transported to the region’s cities by truck. TCI will not confer measurable climate benefits, but it will result in immediate cost-of-living increases for millions of people.
Lastly, with its vague spending mandates, TCI will be fertile ground for corruption and waste. TCI jurisdictions will tax the general population only to dole out the proceeds to politically-favored firms that stand to benefit from TCI investments.
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TCI Regional Policy Design Stakeholder Input.pdf |
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2/27/2020 |
Connor |
Dolan |
Fuel Cell and Hydrogen Energy Association |
Washington |
District of Columbia |
Please see the attached document. Please see the attached document. |
TCI MOU Response FCHEA 2020-2-28.pdf |
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2/27/2020 |
Mark |
Kresowik |
Sierra Club |
Washington |
District of Columbia |
The Sierra Club is sharing the attached 38 comments from our members and supporters in the District of Columbia supporting finalizing the Draft Memorandum of Understanding (MOU) of the... read more The Sierra Club is sharing the attached 38 comments from our members and supporters in the District of Columbia supporting finalizing the Draft Memorandum of Understanding (MOU) of the Transportation and Climate Initiative (TCI). Thank you for helping to design a regional policy to limit climate pollution from motor fuels and invest in a modern, clean, transportation future. The evidence is clear: the more we limit pollution from motor fuels, the more jobs are created, the more the economy grows, and the more lives we save. Please sign on to the agreement to implement a strong, equitable regional climate protection policy through TCI. Invest in the communities that have suffered the most from burning gasoline and have the least access to clean transportation options. Stop sending our hard-earned dollars out of the state to oil companies, and choose to create jobs, grow the economy, and save lives for families and businesses. Thank you. |
DC TCI 38 signers 27 Feb 2020.pdf |
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2/28/2020 |
Mark |
Borowski |
BP America |
Washington |
District of Columbia |
BP America is happy to provide the attached letter as our input to the TCI draft memorandum of understanding. BP America is happy to provide the attached letter as our input to the TCI draft memorandum of understanding. |
BP Letter on TCI Draft MOU.pdf |
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2/28/2020 |
Paul |
Allen |
M.J. Bradley & Associates |
Washington |
District of Columbia |
Please see the attached comments from Exelon Corporation and Public Service Enterprise Group. Please see the attached comments from Exelon Corporation and Public Service Enterprise Group. |
Utility Comment Letter on TCI MOU FINAL.pdf |
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2/28/2020 |
Don |
Thoren |
AFPM |
Washington |
District of Columbia |
AFPM is a trade association representing high-tech American manufacturers of nearly 90% of U.S. supply of gasoline, diesel, jet fuel, other fuels and home heating oil, as well as nearly all the... read more AFPM is a trade association representing high-tech American manufacturers of nearly 90% of U.S. supply of gasoline, diesel, jet fuel, other fuels and home heating oil, as well as nearly all the petrochemicals used as building blocks for thousands of vital products in daily life. AFPM members make modern life possible and keep America moving and growing as they meet the needs of our nation and local communities, strengthen economic and national security, and support more than three million American jobs. |
AFPM Comments to Georgetown Climate Center.pdf |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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2/28/2020 |
Patrick |
Kelly |
API |
Washington |
District of Columbia |
See attachment See attachment |
TCI Draft MOU and Modeling API Comments.pdf |
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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 |
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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 |
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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 |
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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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