TCI Regional Policy Design Stakeholder Submissions

I'd like to see policies that encourage consumers to choose electric vehicles over internal combustion engines. This could be done through carbon pricing, tax incentives, or perks given to drivers of EVs (preferred parking, discounted tolls, HOV lanes, etc.)

•I am a concerned citizen who would like my grandchildren to inherit a livable earth & climate.
•The carbon price must be high enough to have the desired effect of reducing carbon emissions.
•There should be a strong component of social equity
•I think it is excellent that this project is bipartisan.

I am writing today to express my support for a strong carbon pricing policy in the transportation sector.
As a mother of three, I am very concerned if we can turn around and take action on climate change in time to avert the worst effects on our kids and grandkids. Having lived in Europe for a long time, I follow their efforts to reign in green house gas emissions closely, and I am glad that in the US, states and cities are finally getting on board and taking regional initiatives of their own.

I am thrilled to hear that the Transportation Climate Initiative is developing a policy that would put a price on carbon for our transportation sector. I am grateful and very optimistic for this policy, as it is a bipartisan endeavor.
In order for the Mid-Atlantic and Northeastern states to achieve our necessary climate goal, pricing Carbon is a genial first step. The policy needs to
- put a price on carbon high enough to effectively decrease emissions (new technology enables higher efficiency, less consumption, but only if the old way gets more inconvenient or too expensive), and this price needs to be based on the latest science.
- Furthermore, the new policy needs to make sure that rural or low income populations are not hurt disproportionately.
The Citizens’ Climate Lobby has been working in a similar carbon pricing nation wide for years now. Please inquire how their model (clear, transparent pricing over 10 years, with the dividend distributed to all Americans equally) can inspire the new policy to be adopted by the TCI.
Thank you for taking my comments,
Adelheid Koepfer
35 Whiffle Tree Road
Wallingford, CT 06492

Putting a price on carbon has been the main suggestion of many leading economists as a means of reducing carbon emissions. The price should be high enough to have the desired effect of curbing carbon emissions. In addition, the price should be increased over time in order to encourage people to move to renewable energy sources. The bi-partisan nature of this initiative illustrates that this is a universal problem that affects us all throughout the world and we must all work together to resolve this crisis.

Thank you for soliciting input and for working together and hard on this super-important issue. Aileen Nowlan at the Environmental Defense Fund can provide up-to-the-minute information on this topic and about hyper-local pollution measurement. Please contact her.

Modeling greenhouse gas reduction from the adoption of electric vehicles without including in that model the life cycle greenhouse gas emissions due to the production (raw materials, manufacturing, shipping to end user, and eventual disposal/recycling) of those EV's is an incomplete model. The first model presented in Aug 2018 only showed GHG reduction from on-road emissions, without presenting the significant GHG emissions from the production of those new EV's. Accounting for and modeling only on-road emissions reductions will also bias the investments toward EV's when other investments may be more effective interventions.

Another concern that I have with bookkeeping of (car-like) EV emissions reductions is that the concept of a low occupancy motor vehicle supports several system level inefficiencies that increase GHG emissions. For example, EV's (with lower operating and fuel costs) are likely to support and perhaps expand sprawling single family housing development, increasing that type of GHG heavy development while also wiping out more GHG absorption due to development of forests and open space. If there was a way to model VMT-increase (or decrease) and the correlation to sprawling development and associated emissions, the model could more completely capture the GHG impacts of low-occupancy vehicle trips.

Keep up the great work!

As a mom, what comes to mind first are the school busses. Please include in the MOU and work towards replacing ALL diesel school busses with electric busses, and support school districts in doing so! Diesel stinks, makes the kids sick, is expensive, and wrecks havoc to the environment and the busses are loud. It is of utmost urgency to finally replace all busses with healthy, quiet, emission-“free” alternatives.

As financing system, I propose the “fee & dividend” model as exemplified by Citicens’ Climate Lobby in Congress, HR 763. Fee on carbon is raised at the source (well, or port of entry), and dividend is reimbursed to the people. Cap and trade has not yielded enough results in the last decade or so, we need a more comprehensive model. With distribution of dividends to the people, everyone can keep up with raising costs, especially lower income families. Business could “earn” dividend in relation to number of employees, see the bill that was proposed in CT General Assembly.
Fee and dividend has been accepted by Nobel prize winners and countless other economists as the best, quickest, most transparent and most effective way to reduce emissions. It works for transportation as well.
Other issues: push EV charging infrastructure, make public transit more attractive (eg New Haven-Springfield line has no commuter trains for morning rush hour, how silly is that?), get freight off the roads and on the tracks, decrease truck traffic, incentivize car pools and car sharing, support local electric bus lines!, stop sprawling parking lots, push better efficiency in air and sea traffic...

Pay now or pay much more later!! Our region is warming at an alarming rate (Sept. was the hottest month on record). We must do ALL we can to mitigate the effects of climate change the impact of which is becoming more and more dire. If it means some sacrifice on all our parts, it is worth it. Please implement the TCI recommendations.

I am submitting comments for you to consider as a resident and taxpayer in Connecticut to express my concern about the potential that a cap and trade program will have on our customers, employees, business and the environment.

The plan seems to be geared toward converting millions of gasoline and diesel-powered vehicles to electric vehicles (EVs).

While EVs may be an apparently attractive way to lower emissions, we urge that greater consideration needs to be given to a number of factors that will have an impact on jobs, the economy, property values, electric reliability, emissions and family-owned businesses.

Please consider the following points and recommendations so that they can be incorporated into the final draft of the TCI:

• TCI needs to be very cautious about advantaging regulated electric monopolies that already benefit from antitrust protection and a guaranteed rate of return. According to the website Utility Dive (https://www.utilitydive.com/news/california-new-england-will-significantly-miss-2050-carbon-targets-at-curr/564726/), "Just to meet this load that comes from electrifying transportation and buildings, you have to add an electricity sector that's equal to the current electricity sector" – which is a huge gift to utility investors. Are utilities doing such a great job that they deserve these government handouts (Eversource is rated below California’s PG&E in 2019 by the American Customer Satisfaction Index)? Our business cannot compete with utilities coddled and protected by government unless, we get equivalent protection and subsidies to create a level, competitive playing field.

• With the goal of putting million’s EVs on the road, TCI should have ISO New England and the other grid operators fully evaluate the impact that this would have on the electric grid. An article published by the Massachusetts Institute of Technology (MIT) indicates that one EV can consume as much electricity as a home does. And as noted, we need to double power generation to meet the state’s carbon goals, an unlikely feat that will result only in supply shortages. The unintended consequence of the government heedlessly jumping onto the EV bandwagon will be rolling blackouts, with power loss to critical infrastructure such as schools, businesses, emergency responders, hospitals and nursing homes.

• The ISO’s should add to their evaluation the impact of state policies promoting electric heat pumps on the electric grid, which could require an additional 17 million MWH of power annually. TCI must understand the impact that their program has on other initiatives also looking to utilize more electricity. TCI is not operating in isolation and has the responsibility not to operate in the dark either, and ensure that electric reliability is not compromised.

• Although EVs are considered a low- or zero-emission vehicles, they are only as clean as the electricity that charges them. Connecticut is heavily reliant on natural gas to generate electricity and becoming more dependent on it as nuclear generation in the region is retired. Natural gas (methane) is more than seventy times as potent a greenhouse gas than carbon dioxide, and combusting natural gas also emits carbon dioxide. According to the Department of Energy, an EV produces 4,362 lbs of CO2e per year (https://afdc.energy.gov/vehicles/electric_emissions.html)– that’s almost two tons – hardly emissions-free, and that doesn’t even consider the CO2 resulting from their manufacture. TCI needs to fully understand the lifecycle impact of EVs and the source of the fuel that electricity is being generated from before EVs are designated as “clean”. It is intellectually and environmentally dishonest to claim that electricity is clean when ISO New England today (10/29/19) reports that just 8% of electric generation is renewable and 53% is generated with natural gas. Methane’s impact on climate change is an inconvenient truth. A recent study commissioned by the Connecticut Chapter of the Sierra Club (https://issuu.com/ctsierraclub/docs/hartford__ct_mobile_methane_leak_su) found that in Hartford, CT alone, gas pipelines leak approximately 43,000 cubic feet per day, or 313 metric tons per year. That is equivalent spilling and not cleaning up 320 gallons of diesel per day (or 117,000 gallons per year). Just because you can’t see natural gas leaks, it doesn’t mean that they are not there and that they are not doing environmental damage. According to Gale Ridge, PhD, a scientist and researcher on the Sierra Club study, “In a one month period, we found about 700 leaks in Hartford. Over a one-year period covering the same area, PURA reported 139 leaks. Even recognizing that some of the leaks we found are known to PURA, that’s about a 5-fold difference. We believe that CNG may be missing a large percentage of its leaks.”

• Connecticut motorists are already paying the highest gasoline taxes in New England and the 11th highest tax in America. Connecticut also has the highest diesel tax in New England and the 9th highest tax in America. Any proposal that increases the cost of fuel in our state will disproportionally harm low-income motorists and businesses when compared to states that do not participate in TCI. According to the Natural Resources Defense Council "Low-income, households of color, multifamily and renting households spend a much larger percentage of their income on energy bills than the average family." An across-the-board energy tax is therefore "regressive," i.e. "African-American and Latino households and renters in multifamily buildings who pay a disproportionate amount of their income for energy" will be greater impacted by such a tax than average- or high-income earners. Moreover, low-income families will have less means to change their energy use to lower-taxed fuels, which are prohibitively expensive to convert to. TCI needs to consider the impact of their program on low- and fixed-income families who will not be able convert to EV’s.

• Presumably, the purpose of TCI is to change consumption behavior in Connecticut and the region. But we’ve seen huge variations in energy commodity prices that haven’t affected consumption. EIA, for example, shows that gasoline consumption in Connecticut in 2015 was the same as in 2011, despite prices being more than $1/gallon less. Energy consumption is inelastic. Even if TCI is successful in increasing cost of fuel, the data clearly demonstrate that people will be paying higher prices for fuel and not curb consumption. Further inflation will result as the price of every product sold in Connecticut increases as merchants and manufacturers increase prices to account for TCI. Either that, or people will vote with their feet and leave the state or region.

Finally, even if TCI resulted in changes in consumption behavior in Connecticut, such changes will have no impact on climate change. As reported in U.S. News & World Report, the Intergovernmental Panel on Climate Change (IPCC) Assessment Report claims that even if the U.S. as a whole stopped emitting all carbon dioxide emissions immediately, the ultimate impact on projected global temperature rise would be a reduction of only about 0.08°C by the year 2050. China and India will dominate global carbon emissions for the next century, and there’s little the U.S., let alone Connecticut can do, to affect this. A Princeton University study likewise predicted that even if all countries stopped emitting CO2 entirely, the Earth would continue to gradually warm, before cooling off.
I ask that TCI take all of these issues into consideration before they decide to move forward.

Please don't make a long term decision on the SHORT TERM view that EV's are the best option for the climate. HUGE investments may prove to have been foolish down the road. There are always new technologies developing especially those in the renewable world that do NOT rely on fossil fuels AT ALL! To convert to EV's which rely mainly on Natural Gas is a short term view!! Think of future generations not just a short term feel good plan.

Thank you.