TCI Regional Policy Design Stakeholder Submissions

I fundamentally support a declining cap on the production and burning of fossil fuels uniformly across all carbon-based fuel types, liquid, gaseous and solid, each having a similar trajectory to zero, or near zero.

I prefer a uniform declining cap on the fuel itself rather on the carbon emissions inherent to each fuel type. Natural gas (methane) and bio-diesel are have equal or higher global warming forcing relative to oil and coal and should not be considered environmentally safe or “bridge” fuels. Allowing them to replace or extend the life of petroleum fuels presents issues of extending infrastructure life for carbon-based fuels and extending the related CO2 emissions. It is delusional to think any mix of lower-carbon-intensive fuels will achieve the required urgent results.

If I am reading the text correctly, it appears that the intention to force a predetermined reduction in emissions is compromised by the provisions in Section G. Stability Mechanism in the draft MOU. Making additional allowances available for sale or allowances to be withhold from circulation if emission reduction costs are higher or lower than projected, respectively, violates the purpose of achieving a steady decline of emissions, as I understand it. I believe that cost containment is irrelevant and the auction price (“emissions reduction cost”) should be allowed to seek its unfettered market level irrespective of what the AEI model happens to project.

G. Stability Mechanisms.
(1) Cost Containment Reserve. The Model Rule may include a Cost Containment Reserve (“CCR”), consisting of a quantity of allowances in addition to the annual CO2 emissions budget which are held in reserve. The CCR allowances are only made available for sale if emission reduction costs are higher than projected. The CCR is replenished at the start of each calendar year.
(2) Emissions Containment Reserve. The Model Rule may include an Emissions Containment Reserve (“ECR”) that allows the Participating Jurisdictions to withhold allowances from circulation if CO2emission reductions costs are lower than projected.

The urgency to achieve emissions reductions and lowering atmospheric CO2 concentrations and oceanic acidity and warming should instruct language and preclude loop holes like this.

I suggest that a significant portion of the revenues from the allowance auction be designated to support methane and CO2 removal as the technologies are tested and implemented in the next year or two. Several projects are in operation already or will soon be implemented at small scale. Drawing down methane and CO2 actually provide 10-fold to 100-fold greater climate benefits than simply reducing emissions, i.e., reducing atmospheric concentrations and oceanic acidity and heat. A group of 21 scientists, engineers, inventors and other subject matter experts led by two individuals in Australia and two scientist in Germany and France have been working on a solution to mitigate the imminent runaway release of Arctic sub-sea methane and the “blue water” loss of the Arctic ice cap using a natural chemical and biological process that mimics the effects of dust storms that have for millions of years dispersed nutrients across the Atlantic to the Amazon, both of which rely on the dust to fertilize and promote healthy fisheries and rain forests. Google Franz Dietrich Oeste, Renaud de Richter, Peter Wadhams and John Nissen.

My views on climate priorities have changed over the past decade, and the following are a few examples of what has informed my evolving perspective.

As a former petroleum engineer (1970-1972) and as an Air Pollution Engineer at the California Environmental Protection Agency Air Resources Board (2005-2012) having participated on a team of 13 writing and implementing a regulation “Energy Efficiency and Co-Benefits Audits for Large Industrial Sources,” I associated with many fuels and pollution experts as well as oil field and refinery engineers and management.

The final six years of my career were many times more instructive to my understanding of petroleum production and operations than my college training and initial assignments at Humble Oil & Refining Co. (now ExxonMobil). The issues and conundrums of global warming and industrial operations synthesized with me beginning on December 22, 2004. I heard Al Gore present his 35mm slide show on National Public Radio ("It's your World" on KQED, San Francisco) and that awakening led me to the Air Resources Board a year later. Between 1972 and 2005, my career involved corporate planning and various engineering, project management and mid-level management positions.

In January 2007, I was trained by Al Gore to present his slide show (the subject of the movie "An Inconvenient Truth").

Since 2005, my climate activism and professional employment presented opportunities to meet and discuss climate science with (notably) NASA Goddard Institute for Space Studies director Dr. James Hansen, Woods Hole Oceanographic Institution founder Dr. George Woodwell and IPCC Chairman Rajendra Pachauri early on (2008-2014) and more recently Iron Salt Aerosol and Arctic scientists and professors Dr. Franz Dietrich Oeste, Dr. Renaud de Richter, Peter Wadhams, John Nissen and many other engineers, inventors, scientists and subject matter experts working on Arctic ice and permafrost thawing, resulting methane release, and mitigation technologies.

In December 2008, Dr. Hansen told me that “350ppm is actually insufficient, but an initial target of 450ppm (or 350ppm) is okay—the precise level is irrelevant—as long as we start very soon to reduce emissions, the make an adjustment to the target mid-course. It is the getting started without deal that is imperative.”

In May 2009, Dr. Woodwell told me “we must abandon our reliance on the burning of carbon-based fuels—we are poisoning the earth.”

In March 2010, Rajendra Pachauri told me the atmospheric CO2 concentration was then 0.8°C and that it would get to 2°C by 2035, when 2 billion people or 30% of the world population would experience drought, crop failure, hunger, thirst, floods, sea level rise, increased disease and extinction of species, and that 2012 was the last year the world could afford a net rise in greenhouse gas emissions.

On December 3, 2013, Dr. Hansen et al published a paper “Assessing ‘Dangerous Climate Change’: Required Reduction of Carbon Emissions to Protect Young People, Future Generations and Nature” that suggested an annual decline of CO2 emissions beginning immediately (2014) at a rate of 6% per annum along with “storage in the biosphere, including the soil, via reforestation and improved agricultural and forestry practices.” (bit.ly/HansenPLOS)

On January 9, 2009, the German Advisory Council on Global Change published a paper “Solving the climate dilemma: The budget approach” that gave a set of possible emissions reduction trajectories depending on what year the reductions began—2011, 2015 or 2020. (bit.ly/WBGU9Jan09)

Unfortunately, humanity has missed the opportunities to save itself as suggested by these scientists, so we must “pull out all the stops” as they say, with all manner of aggressive emissions reduction and removal.

Please consider the value of drawing down carbon by building soil health in the discussion about how to allocate funds to be received from TCI. This also can contribute to improved water quality, climate resilience, and food production. Compensating farmers and other land managers for building soil carbon and water storage is one important part of Vermont's climate objectives. The Payment for Ecosystem Services Working Group is currently working on ways to measure ecosystem services provided by farmers and land managers, and identify sources of funding to reward them for this work. Perhaps TCI could provide part of the revenue needed to compensate farmers for drawing down carbon.

Another readily measurable way to reduce our GHG emissions is to encourage substitution of biological methods such as compost application and cover cropping for use of synthetic nitrogen fertilizers. Support for farmers to replace synthetic nitrogen with compost to provide crop nutrients will serve to sequester carbon in addition to reducing nitrous oxide emissions. Nitrogen synthesis currently consumes vast quantities of natural gas in an energy intensive process. As a bonus, implementation of the solid waste recycling requirement would be supported by market incentives for community based compost production--a win-win for both environment and farm economy.

Thank you for considering these suggestions, submitted on behalf of the Vermont Healthy Soils Coalition - www.vermonthealthysoilscoalition.org

The TCI is a critical initiative that will demonstrate the regional leadership we need to actually tackle the climate crisis. I'm a student, and increasingly growing frustrated with government inaction or moderation. The TCI is the first step, and it needs both complimentary legislation and language that will support low income residents who may be affected by the TCI. Attached is a joint letter by orgs in Vermont that demonstrate the urgency of this bill.

Thanks!

It is critical that we decarbonize transportation as quickly as possible as a state, region, nation and world. Please pass the Transportation and Climate Initiative for Vermont and the region! In rural areas people depend on their cars. I have been fortunate to drive an electric car for the last couple of years and will never go back. A small tax on gas when prices are low is a small price to pay to make progress on decarbonizing transportation and providing more public transportation options for all.

We need to take action to decrease carbon emissions now. Transportation is Vermont's largest source of carbon pollution, at 44% of the state's total emissions. These emissions are contributing to a changing climate, which here in Vermont is impacting farming practices, creating more intense storms, and increasing tickborne illnesses. While doing our part to reduce pollution in the transportation sector, Vermont could be at the forefront of strategically and equitably – demographically and geographically – investing those dollars in transportation solutions that serve Vermont and Vermonters well. Designing programs and solutions that serve rural regions well, as well as investing in bus, bike, pedestrian and housing solutions in and around downtowns, is possible and essential.

Please support TIC. It's not all we need but it is a good first step in mitigating climate crisis.

I don't have any answers or even the slightest suggestions for TCI. I can only say that we need to reduce our use of fossil fuels and create
other forms of transportation. Trains in Vermont seem limited, at least here in Vermont. Can we create electric trucks along with cars.
How committed are we?

Governor Scott- It is critical that Vermont join the TCI. It is a good deal for Vermont economically, and a key step in reducing Vermont's transportation CO2 emissions, which have been rising despite our green image and good efforts. Cap-and-invest programs like TCI are proven to work; lowering CO2 emissions and actually increasing GDP. Please, please, please do the right thing for all of us and Vermont join the TCI.
Sincerely,

Hannah Dreissigacker