3/5/2020 |
Clem |
Dinsmore |
Climate & Energy Committee, Sierra Club DE chapter |
Wilmington |
Delaware |
My initial thoughts/questions are attached in the file upload. I welcome discussion of them. My initial thoughts/questions are attached in the file upload. I welcome discussion of them. |
QUESTIONS RETRANSPORTATION_0.pdf |
3/24/2020 |
Ruth |
Evans |
1960 |
Newark |
Delaware |
YES !! PLEASE give us a future with transportation that supports the climate initiative . YES !! PLEASE give us a future with transportation that supports the climate initiative . |
- |
4/5/2020 |
john |
sykes |
Delaware Interfaith Power & Light |
Lewes |
Delaware |
Please expand passenger rail service to central and lower Delaware. Please expand passenger rail service to central and lower Delaware. |
- |
5/14/2019 |
Mark |
Kresowik |
Sierra Club |
Washington |
District of Columbia |
Thank you, please find attached comments from 39 environmental, health, scientific, transportation, social service, and business organizations committed to advancing modern, clean, accessible, and... read more Thank you, please find attached comments from 39 environmental, health, scientific, transportation, social service, and business organizations committed to advancing modern, clean, accessible, and low-carbon transportation in the Northeast and Mid-Atlantic on the first workshop held on April 30th. |
Advocate Group Comments on 4_30 TCI Workshop.pdf |
5/20/2019 |
Daniel |
Gage |
NGVAmerica |
Washington |
District of Columbia |
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... read more 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.
|
NGVA TCI comments FINAL 5 20 19.pdf |
5/23/2019 |
Connor |
Dolan |
Fuel Cell and Hydrogen Energy Assoc |
Washington |
District of Columbia |
Attached are some references and studies related to fuel cell vehicles and hydrogen that I believe would be valuable as this initiative continues.
I also wanted to direct you to the... read more Attached are some references and studies related to fuel cell vehicles and hydrogen that I believe would be valuable as this initiative continues.
I also wanted to direct you to the following Department of Energy presentation and program records on fuel cell cost projections for automotive and medium-duty vehicles.
https://www.hydrogen.energy.gov/pdfs/17008_levelized_cost_driving_future_icev.pdf
https://www.hydrogen.energy.gov/pdfs/16009_life-cycle_costs_midsize_ldv.pdf
https://www.energy.gov/sites/prod/files/2018/04/f51/fcto_webinarslides_2018_costs_pem_fc_autos_trucks_042518.pdf
Our Association and its members would be happy to provide your team with an in-depth briefing on fuel cell vehicles and hydrogen infrastructure to ensure that this program is as comprehensive as possible. Our members include the largest automakers investing and deploying fuel cell vehicles, industrial gas companies developing hydrogen stations and large-scale production plans, as well as other fuel cell and hydrogen manufacturers.
Should you have any further questions regarding fuel cells or hydrogen, please feel free to contact me at any time. |
TCI Research 2019-2-27.docx |
5/31/2019 |
Andrea |
Lubawy |
Toyota Motor North America |
Washington |
District of Columbia |
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... read more 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. |
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8/7/2019 |
Mark |
Kresowik |
Sierra Club |
Washington |
District of Columbia |
August 7, 2019
To: Governor Baker, Mayor Bowser, Governor Carney, Governor Hogan, Governor Lamont, Governor Murphy, Governor Northam, Governor Raimondo, Governor Scott, and Governor... read more August 7, 2019
To: Governor Baker, Mayor Bowser, Governor Carney, Governor Hogan, Governor Lamont, Governor Murphy, Governor Northam, Governor Raimondo, Governor Scott, and Governor Wolf
Re: 2019 Transportation and Climate Initiative (TCI) Regional Policy Design Process
Sent via: https://www.transportationandclimate.org/main-menu/tci-regional-policy-design-stakeholder-input-form
The Sierra Club is sharing with you the attached 2,435 comments from our members and supporters in your states and the District of Columbia (DC) regarding the 2019 TCI Regional Policy Design Process. More than 700 of those members and supporters across the 9 states and DC have included personal messages, often encouraging swift action to modernize our transportation system, reduce climate pollution from burning motor fuels, and ensure equitable access to the benefits of clean transportation, particularly for those communities that have been overburdened and under-resourced by our current system. Many have also provided specific recommendations and requests for investments and clean transportation projects in their communities.
The Sierra Club continues to support your efforts through this process. We further recommend that you and your teams transparently and inclusively develop an understanding of which communities in the region are overburdened by pollution from motor fuels and under-resourced when it comes to access to clean, affordable, and rapid transportation, and to move forward by modeling and sharing the impacts for those communities of both a cap and invest policy for climate pollution from motor fuels consistent with meeting state climate protection targets and other complementary policies as discussed in the state and regional workshops and listening sessions. We also encourage more engagement by individual states and DC with such overburdened and under-resourced communities, by partnering with and supporting community representatives in the planning and hosting of workshops and listening sessions during the evening or on the weekend, accessible by public transportation, and with services for people with disabilities, limited English proficiency, and children and other care duties.
As demonstrated by the more than 300 participants at the in-person regional workshop on July 30th and these thousands of comments from Sierra Club members and supporters, a robust and inclusive clean and modern transportation policy design process this year is vitally important for the future prosperity of our communities.
Sincerely,
Mark Kresowik
Deputy Director, Eastern Region
Sierra Club |
Sierra Club Member and Supporter Comments 8-7-19.pdf |
8/19/2019 |
Stewart |
Schwartz |
Coalition for Smarter Growth |
Washington |
District of Columbia |
To reduce emissions from transportation we need a strong focus on the land use/transportation connection. We need to focus growth in cities and towns and in walkable, mixed-use, mixed-income,... read more To reduce emissions from transportation we need a strong focus on the land use/transportation connection. We need to focus growth in cities and towns and in walkable, mixed-use, mixed-income, transit-oriented centers and corridors. Funding transit alone will not be enough - it must be connected to compact, walkable development. Universal adoption of electric vehicles while not addressing sprawling development will mean continued long-distance driving and highway construction, while also risking the conversion of vast acreage of farms and forest to solar arrays just to supply longer distance vehicle travel. So land use must be a primary focus. As for investments to be made - they should include transit tied to land use, reduction in transit fares, affordable housing close to transit, jobs and services, and other infrastructure that supports transit-oriented communities.
The Coalition for Smarter Growth is a 22-year-old non-profit working in DC, Maryland and Virginia and the leading organization promoting walkable, transit-oriented communities (TOD) as the best way for the DC region to grow. We have convinced the Metropolitan Washington Council of Governments to make TOD the core framework for regional growth in their Region Forward Plan and in their Visualize2045 long range transportation plan, however, spending practices by state and local government still include massive highway and arterial road expansion. Meanwhile the region must do more to advance public and private investment in TOD at Metrorail stations and other high capacity transit. We received the MWCOG Regional Partnership Award in 2017. |
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8/22/2019 |
Connor |
Dolan |
FCHEA |
Washington |
District of Columbia |
Please see the attached comment sent on behalf of the Fuel Cell and Hydrogen Energy Association (FCHEA). Please see the attached comment sent on behalf of the Fuel Cell and Hydrogen Energy Association (FCHEA). |
TCI Comments August 2019.docx |
8/30/2019 |
Patrick |
Kelly |
American Petroleum Institute |
Washington |
District of Columbia |
Please see attached. Please see attached. |
TCI Comment API.pdf |
9/25/2019 |
Paul |
Allen |
M. J. Bradley & Associates |
Washington |
District of Columbia |
On behalf of the signatory companies, please find the attached statement of support for, and expression of perspectives on the Transportation Climate Initiative’s efforts to develop a cap-and-... read more On behalf of the signatory companies, please find the attached statement of support for, and expression of perspectives on the Transportation Climate Initiative’s efforts to develop a cap-and-invest policy for transportation.
|
LetterofSupport_TCI_ElectricCompanies_FINAL.pdf |
10/31/2019 |
Sherrie |
Merrow |
NGVAmerica |
Washington |
District of Columbia |
Please see attached letter as comments from NGVAmerica on the TCI Framework.
Sincerely,
Sherrie Merrow
Director, State Government Affairs
NGVAmerica... read more Please see attached letter as comments from NGVAmerica on the TCI Framework.
Sincerely,
Sherrie Merrow
Director, State Government Affairs
NGVAmerica
400 North Capitol Street N.W.
Suite 450
Washington, D.C. 20001
smerrow@ngvamerica.org | 303.883.5121 |
NGVA TCI Comments on Framework - Oct 31 2019.pdf |
11/2/2019 |
Lee |
Beck |
Global CCS Institute |
Washington |
District of Columbia |
To whom it may concern,
on behalf of the Global CCS Institute I am submitting the report "THE LCFS AND CCS PROTOCOL: AN OVERVIEW FOR POLICYMAKERS AND PROJECT DEVELOPERS... read more To whom it may concern,
on behalf of the Global CCS Institute I am submitting the report "THE LCFS AND CCS PROTOCOL: AN OVERVIEW FOR POLICYMAKERS AND PROJECT DEVELOPERS" which explains the protocol for carbon capture and storage (CCS) California's Low Carbon Fuel Standard (LCFS) was amended with in 2018. The protocol took effect in early 2019 and incentivizes CCS projects that reduce the lifecycle emissions from fuels consumed in California. Recognizing that climate change is a transnational problem, it also incentivizes direct air capture (DAC) projects reducing the stock of CO2 in the atmosphere. According to the International Energy Agency, to meet the Paris Agreement, CCS is expected to deliver 7 percent of cumulative emissions reductions by 2040, which translates into roughly 2000 operating facilities globally. Currently, there are 19 operating, large-scale CCS facilities globally, including in ethanol and hydrogen production, as well as on power production. While the technology is seen as deployment-ready, it has not been widely deployed due to a lack of policy confidence. However, the recently reformed 45Q tax credit and the LCFS CCS protocol are examples of a value on carbon providing policy confidence for CCS deployment. At least two planned facilities announced recently have cited the LCFS CCS protocol as a key enabling policy mechanism.
Thank you for your consideration.
Sincerely,
Lee Beck |
LCFS-and-CCS-Protocol_digital_version-2.pdf |
11/4/2019 |
Albert |
Gore |
Tesla |
Washington |
District of Columbia |
|
Tesla TCI Comment 11.4.2019.pdf |
11/5/2019 |
Connor |
Dolan |
Fuel Cell and Hydrogen Energy Association |
Washington, D.C. |
District of Columbia |
|
Statement of Support for TCI Framework.pdf |
11/5/2019 |
Alex |
Kragie |
Coalition for Green Capital |
Washington |
District of Columbia |
Please see attached letter Please see attached letter |
TCI_Comment_Letter_Final.pdf |
11/5/2019 |
Patrick |
Kelly |
API |
Washington |
District of Columbia |
|
API TCI Comment Nov 2019.pdf |
11/5/2019 |
Shailesh |
Sahay |
POET LLC |
Washington |
District of Columbia |
POET appreciates the opportunity to comment on the TCI Framework. Our comments are attached. POET appreciates the opportunity to comment on the TCI Framework. Our comments are attached. |
POET TCI Framework Comment-11.5.2019.pdf |
11/5/2019 |
Andrea |
Grant |
Independent Fuel Terminal Operators Association |
Washington |
District of Columbia |
Please find the attached comments. Please find the attached comments. |
Comments of IFTOA on Proposed Transportation and Climate Initiative.pdf |