TCI Regional Policy Design Stakeholder Submissions

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

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

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.

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.

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!

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

Hi:

Please show leadership by taking the following measures:

1. A cap on carbon emissions of at least 25% by 2032
2. An increase in the minimum investment in overburdened and underserved communities (>35%)
3. Request that investments be put towards active transportation like better sidewalks, bicycle infrastructure, and high quality public transit

Thank You,
Tom Quinn