TCI Regional Policy Design Stakeholder Submissions

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.

Thank you for the opportunity to provide written comments from stakeholders in Connecticut.

Please see attached comments from Electrify America, CT Green Bank, and Climate Neutral Business Network.

Please do not allow this to go through. It is another tax on us. If you want to push this through, please put it to a vote. Let the taxpayer decide.

This is another stupid idea to take money from ordinary citizens and give more money to the government. If history is a teacher the CT politicians will take the monies and spend it on other things. I live in northeast CT where there is no public transportation in my area. If this tax goes through the rural areas will be subsidizing the cities. The practical effect will be a huge increase in the cost of goods that are delivered by truck. This will mean prices on everything will go up for no real benefit to the general population.

Electric powered vehicles are most likely the future of private transportation. But there will be a huge surge in demand on the electrical grid. This will mean that more power plants will need to be built but the environmentalists are opposed to new power plants. Solar generated electricity has not developed enough to meet demand yet. So how are we going to produce more electricity?

In my opinion man made climate change is a hoax.

I have traveled a great deal, in the U.S., Europe, and less affluent countries. It always strikes me that in Europe the broad swath of the population feels comfortable taking the fast, clean, safe, and ubiquitous public transportation, whereas in third-world countries the public transportation is poor, filthy, slow, and often dangerous -- and the air is deeply polluted by the inefficient cars and trucks on the roads. The United States leans toward these latter conditions more than it does toward the former. Our roads are increasingly congested, our air is less safe to breathe, and we are contributing unconscionably to climate disaster. We need a complete overhaul of our transportation system and a public relations campaign to turn our citizens' minds toward using public transportation -- and toward that end, it needs to be fast, safe, reliable, and ubiquitous.

Unless we reduce pollution the planet is not going to survive. I will, I am old but my children and my grand children may not. Please do something!

The disaster is well under way. It's time for us to wake up and smell the burning in the air and take action before we all go up in a tremendous plume of carbon and lots of other irritants. Too many cars, trucks, vans, vehicles of all sorts with insufficient emissions control. Trump and his buddies will soon be the only remaining deniers of the disaster. PLEASE take action.

I deeply care, for my children and future generations, about reducing pollution from transportation, which is our largest source of global warming emissions. I hereby request that Connecticut formally join the plan to reduce emissions.
I demand that the policies have strong components of equity by prioritizing clean investments in areas overburdened by pollution and/or for those who don't have access. I express my support and gratitude for the bipartisan nature of this project, and the legislators who aren’t corrupted by the dirty fuel cartel. Thank you for moving us forward while the shameless Republican-led federal government betrays our nation on every level.