5/23/2019 |
Chandra |
Parasa |
LVPC (Lehigh Valley Planning Commission) |
Allentown |
Pennsylvania |
This is a great policy development initiative by TCI (Transportation & Climate Initiative). This policy development initiative for the northeastern states helps in spreading awareness among... read more This is a great policy development initiative by TCI (Transportation & Climate Initiative). This policy development initiative for the northeastern states helps in spreading awareness among sub regions. The goals of this initiative in reducing carbon foot print, reducing greenhouse gas emissions, would need support of local and regional entities. Having local regions adopt this policy (once it is developed) would help in multi-state regional goals. Measuring existing conditions is the key to this initiative. Your approach is commendable on to how to measure CO2 emissions. This measurement may also be accomplished perhaps by placing measuring instruments in various locations in region. These measuring instruments will help monitor over a period of time. Data on health is also a key to support monitoring the emissions. Validating existing data with measurements would help forecasts. Traffic counts, GPS data are also helpful in measuring VMT. Implementation strategies can be many: ranging from fuel technologies, to multi modal transportation system, land use density, preservation of farm land. VMT data combined with fuel technologies is a key variable in emissions reduction strategy. Complete streets policy implementation also helps in emissions reductions. Increased density of land use, with mixed land use development result in shorter daily commuting trip lengths, this in turn would help reduce emissions. Some of the MPO’s in the region already has VMT computed, as well as Ozone and PM 2.5 pollutants emissions are documented. Good to use these resources, that way consistency in the data is accomplished. |
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5/28/2019 |
g |
h |
j |
g |
Pennsylvania |
We need to price carbon in transportation high so it causes big changes to our transportation. We also need to move all the federal and state money now funding the problem... like subsidies to oil... read more We need to price carbon in transportation high so it causes big changes to our transportation. We also need to move all the federal and state money now funding the problem... like subsidies to oil, building more new roads, expanding airports, etc. ... this money all needs to be moved to funding the solutions like high speed rail, metros, light rail, bicycles networks, bikeshare, etc. |
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10/2/2019 |
John |
Smith |
PA Citizen |
Plymouth Meeting |
Pennsylvania |
Why don't you just skip all of the complication and add a tax directly on the price of gasoline/jet/diesel/nat gas/coal rather than trying to hide the cost that will ultimately be passed on... read more Why don't you just skip all of the complication and add a tax directly on the price of gasoline/jet/diesel/nat gas/coal rather than trying to hide the cost that will ultimately be passed on to the consumer in some nonsensical program? The tax would be based on carbon from a nonrenewable source (i.e if gasoline has 10% ethanol content then 90% of the gasoline is taxable). All of these "programs" are just taxes to try to incentivize the consumer to find an alternative. Make sure the money collected from the tax actually goes to renewable r&d and isn't diverted somewhere else. Forget the rebates for using renewables. If the tax is high enough people would go buy more efficient cars and renewable electricity sources would become more economical. Or, make the tax low enough so it doesn't have an impact on the local economy and the r&d from the taxes would eventually bring the price of renewables down enough that people will choose to buy it on their own. |
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10/28/2019 |
Dillon |
Talley |
PPA |
Annville |
Pennsylvania |
I'm opposed to the proposal because it would unfairly burden the residents of Pennsylvania who already pay some of the highest gasoline taxes in the country. read more I'm opposed to the proposal because it would unfairly burden the residents of Pennsylvania who already pay some of the highest gasoline taxes in the country. |
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10/28/2019 |
James |
Deiter |
Deiter Bros. Heating Cooling Energy |
Bethlehem |
Pennsylvania |
I am adamantly opposed to this as it would unfairly burden consumers and business in the State of Pennsylvania who already pay the highest fuel taxes in the Country! I am adamantly opposed to this as it would unfairly burden consumers and business in the State of Pennsylvania who already pay the highest fuel taxes in the Country! |
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10/28/2019 |
Tim |
Naylor |
Edris Oil |
York |
Pennsylvania |
I am opposed to the proposal because it would unfairly burden consumers and businesses in Pennsylvania who already pay the highest gasoline taxes in the country I am opposed to the proposal because it would unfairly burden consumers and businesses in Pennsylvania who already pay the highest gasoline taxes in the country |
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10/28/2019 |
douglas |
whitmoyer |
business owner |
TURBOTVILLE |
Pennsylvania |
as a owner of new emission truck that has already cost me 25000.00 dollar in repairs in the first 65000 miles the regulation is just going to increase my cost that i will pass along to the end... read more as a owner of new emission truck that has already cost me 25000.00 dollar in repairs in the first 65000 miles the regulation is just going to increase my cost that i will pass along to the end user of my product . |
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10/28/2019 |
JOSEPH |
CLEMENSON |
JC HEATING INC |
LEVITTOWN |
Pennsylvania |
I MA OPPOSE TO THIS PROGRAM AS IT WOILD RAISE THE PRICE OF GASOLINE BY 10 TO 20 CENTS PER GALLON. I MA OPPOSE TO THIS PROGRAM AS IT WOILD RAISE THE PRICE OF GASOLINE BY 10 TO 20 CENTS PER GALLON. |
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10/28/2019 |
Thomas |
McKenzie |
Penn Mar Oil |
Waynesboro |
Pennsylvania |
I strongly oppose the proposed plan of cap and trade in Pennsylvania. This is an unfair burden to Pennsylvania taxpayers and businesses especially since we already pay a substantially larger... read more I strongly oppose the proposed plan of cap and trade in Pennsylvania. This is an unfair burden to Pennsylvania taxpayers and businesses especially since we already pay a substantially larger amount of fuel taxes over other surrounding states. |
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10/28/2019 |
Steve |
Oehlert |
Oehlert Bros. Inc. |
Royersford |
Pennsylvania |
I am opposed to this initiative. It will unfairly burden PA residents and businesses with higher motor fuel prices in a state that already has nearly the highest motor fuel prices in the country... I am opposed to this initiative. It will unfairly burden PA residents and businesses with higher motor fuel prices in a state that already has nearly the highest motor fuel prices in the country. |
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10/28/2019 |
Quincy |
Longacre |
Better Home Heat Council of the Lehigh Valley |
Emmaus |
Pennsylvania |
To Whom It May Concern,
I am opposed to this proposal because it would unfairly burden consumers and businesses in Pennsylvania who already pay the highest gasoline taxes in the... read more To Whom It May Concern,
I am opposed to this proposal because it would unfairly burden consumers and businesses in Pennsylvania who already pay the highest gasoline taxes in the country.
Thank You,
Quincy Longacre |
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10/28/2019 |
Jerry |
Mc Aveney |
distributor |
shohola |
Pennsylvania |
Once again Gov't trying to KILL small business . Luckily we live near the N.J. border so we buy all our gas there . Unfortunately that doesn't help small businesses where we live . When... read more Once again Gov't trying to KILL small business . Luckily we live near the N.J. border so we buy all our gas there . Unfortunately that doesn't help small businesses where we live . When these LIBTARD IDIOTS a decade ago decided a Carbon Cap and Trade policy was the fix for their so called Climate Change I new it was a HOAX and a SCAM just so they could make money on Wall Street . Look at that fat slob Al Gore flying around the world on his private jet telling us how we should conserve on energy . Carbon Dioxide is what plants need to produce oxygen (DAAH) . The weather is cyclical ,all you have to do is go back over the last hundred years and look . LIBTARDS only look back thirty years . I guess it's to hard for them to look further .
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10/29/2019 |
steven |
ohl |
R.F. Ohl Fuel Oil inc |
Lehighton |
Pennsylvania |
I opposed the proposal because it would unfairly burden consumers and businesses in Pennsylvania who already pay the highest gasoline taxes in the country I opposed the proposal because it would unfairly burden consumers and businesses in Pennsylvania who already pay the highest gasoline taxes in the country |
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10/29/2019 |
Michael |
Hinds |
Hinds Oil Co., Inc. |
Montrose |
Pennsylvania |
We are opposed to the proposal, Pennsylvania already pays the highest gasoline tax in the country. This proposal would unfairly burden the consumers and businesses of Pennsylvania and elsewhere... We are opposed to the proposal, Pennsylvania already pays the highest gasoline tax in the country. This proposal would unfairly burden the consumers and businesses of Pennsylvania and elsewhere. |
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10/29/2019 |
Tom |
Keenan |
Hannabery HVAC |
Allentown |
Pennsylvania |
I feel that by increasing the cost of fuel would have a negative affect on customers and vendors as the additional cost would have to be passed on to the end user. I feel that by increasing the cost of fuel would have a negative affect on customers and vendors as the additional cost would have to be passed on to the end user. |
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10/29/2019 |
Jonathan |
Ferro |
Ferro Fuel Oil, Inc. |
Boothwyn |
Pennsylvania |
The last thing we need in Pennsylvania is more regulations. Call Harrisburg to get an answer on sales tax or motor fuel taxes. There are so many rules at this point the state employees can not... read more The last thing we need in Pennsylvania is more regulations. Call Harrisburg to get an answer on sales tax or motor fuel taxes. There are so many rules at this point the state employees can not even follow them. Simplify the laws and regulations, let the market dictate fuel usage. Electrics are coming, sooner than later the tides will shift. |
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11/5/2019 |
Ted |
Harris |
Pennsylvania Petroleum Association |
Harrisburg |
Pennsylvania |
The Pennsylvania Petroleum Association represents over 400 companies who operate in the petroleum industry throughout the state. Our association opposes the Transportation Climate Initiative which... read more The Pennsylvania Petroleum Association represents over 400 companies who operate in the petroleum industry throughout the state. Our association opposes the Transportation Climate Initiative which would create an upstream tax for Pennsylvania motorists who already pay the highest gasoline taxes in the country. Independent motor fuel marketers who employee tens of thousands of jobs in Pennsylvania will be forced to operate in a marketplace that is purposely designed to put them out of business.
The Transportation Climate Initiative does not appear to benefit all Pennsylvanians the same way. Fixed and low-income residents will be forced to pay higher prices at the pump. They are also less likely afford an electric vehicle regardless of the potential subsidies that could be available to them. The large number of residents who live in the rural communicates across the state will not be able to benefit from public transportation efficiencies in the same way as those who live in Philadelphia, Pittsburgh, and other populated areas.
Our membership and industry support a cleaner environment. We welcome the opportunity to work with the Georgetown Climate Center, policy makers, and other stakeholders to achieve this goal. We however do not support the current version of the Framework for a Draft Regional Policy Proposal. We ask that more consideration is taken before potentially introducing a policy that is unfair and has massive ramifications for our membership, citizens, and economy.
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11/5/2019 |
Morgan |
Folger |
Environment America |
Philadelphia |
Pennsylvania |
Emissions from our cars, buses and trucks have overtaken electric power plants as the number one source of global warming emissions in the United States. Our nation’s top scientists warned in the... read more Emissions from our cars, buses and trucks have overtaken electric power plants as the number one source of global warming emissions in the United States. Our nation’s top scientists warned in the update to the National Climate Assessment that regions across the country are already experiencing the impacts of climate change. If we keep burning fossil fuels, those impacts -- from massive wildfires to extreme weather -- will get worse.
To stave off the worst impacts of global warming, we need to cut carbon pollution as quickly as possible, get clean energy on the grid, and tackle what is now the region’s largest emitter of greenhouse gases -- our transportation system. We use massive amounts of fossil fuels to move people and goods around the region, and that needs to change. We have the technology to replace this dirty system with clean, electric cars, trucks, and buses powered by the sun and the wind.
The Transportation and Climate Initiative is yet another step forward for the Northeast and Mid-Atlantic to reduce the harmful effects of climate change and global warming on our communities. We need to accelerate the transition to zero-emission transportation. With an absence of leadership at the federal level, state and local action is more important than ever.
Program Design Elements
Equity
We support expanding low-carbon and clean mobility options in urban, suburban, and rural communities. We support transparency by reporting the changes in transportation emissions over time, which will allow us to track our progress to reduce global warming pollution throughout the region. The program should limit any impacts it may have on the most vulnerable.
Applicability
Affected Fuels and Emissions
We support the point of regulation laid out in the framework. While traditional fuels like diesel and gasoline account for the majority of transportation emissions, alternative transportation fuels like biofuels also contribute to climate change and should be regulated. Corn-based ethanol, has little to no net greenhouse gas benefit and brings with it other environmental concerns. One model approach is the low-carbon fuel standard adopted by California, which sets targets for lifecycle greenhouse gas emission reductions from transportation fuels. The LCFS has the benefits of being explicitly targeted at reducing carbon pollution and incorporating all fuels, helping to drive not only the adoption of sustainable biofuels, but also the use of electricity and oil-based fuels from sources with lower carbon emissions.
Regulated Entities
We support regulating emissions from Prime Suppliers. Fuel supply infrastructure should also be regulated to ensure that we do not continue to invest in infrastructure for fossil fuels. We need to stop burning virtually all fossil fuels in order to preserve a livable climate, and that means implementing a moratorium on oil and gas pipelines, gas plants, and any other new fossil fuel infrastructure.
Compliance and Enforcement
Emissions reporting requirements
Reporting is an important part of the program to ensure fuel suppliers are held accountable to their emissions. This will also ensure that year over year, the program is truly reducing emissions from transportation fuels.
Monitoring and Verification
A third party verification of emissions reporting will ensure accountability and consistency across the region, rather than relying on each state to verify their own reporting. Emissions should be reported monthly.
Flexibility, Allowance Allocation, and Stringency
Flexibility and Cost Containment
While flexibility allows for a more nimble program, cost-containment provisions should be limited by issuing additional allowances at a set price. Cost-containment can significantly relax the emissions cap and weaken the program’s ability to reduce global warming pollution quickly and effectively. Any cost-containment mechanism should be set at a high trigger price that increases over time.
Auctions and Allocation
We strongly support auctioning 100% of allowances. This will mean most of the proceeds can be allocated directly to climate solutions.
Regional Caps and Allowance Budgets for Each Jurisdiction
We support a strong initial emissions cap and establishing a descending cap on transportation-sector emissions. We recommend that the emissions reduction goals are at the very least consistent with the goals of the Paris Agreement and incorporate all transportation fuels. We also recommend maintaining a “floor price” for allowances to assure a stable flow of revenue into carbon-cutting transportation programs if emissions dip below the level of the cap.
Regional Program Administration
Market Monitoring and Auction Administration
Much like RGGI, Inc., a regional organization is an effective way to administer the program, with representatives from each of the states engaged in the program.
Additional Program Design Elements
Investment of Proceeds
There should be more specific direction for states to invest proceeds. While it is true that every jurisdiction has unique transportation needs, there should be a menu of options they can pick and choose from, and we should limit investments that won’t achieve significant emissions reductions. This program is about addressing global warming pollution, and the proceeds from the program should go to doing just that. Improved air quality and more affordable access to transportation go hand in hand with cleaning up our transportation system. Ultimately we need to decide how to invest these proceeds in a way that will best address climate change. Leaving that decision up to the jurisdictions without specific parameters would result in missed opportunities to cut global warming pollution. TCI must reinvest auction revenue in programs to reduce carbon pollution from the transportation sector and limit any impacts the program may have on the most vulnerable.
We recommend that proceeds from TCI go to projects such as:
Replacement of fossil fuel vehicles with those using electricity or other fuels with zero tailpipe emissions - including vehicles used for personal travel, freight movement and public transportation.
Expansion of public transportation service and infrastructure; incentives for carpooling, vanpooling, and other forms of shared and active transportation; and investment in “transportation demand management” efforts to reduce vehicle travel.
Investments in infrastructure to support low- or zero-carbon transportation, including rail, bike paths, sidewalks, electric vehicle charging, etc.
Incentives/assistance for local governments to encourage accommodating new growth in walkable/compact areas.
Cars account for 60 percent of our transportation pollution. If we make it easier, more affordable, and more pleasant to take a train or bus, to share rides, or to bike or walk, then more of us will choose to travel without a car or even not own a car at all.
We urge you to exclude certain projects from investment. The program should not invest in highway expansion and conventional road maintenance expenditures that have traditionally been paid for through gas taxes and other “user fees” or general revenues. Our car-dependent transportation system is dangerous, harms our communities, and is the nation’s leading source of global warming pollution. Highway expansion fuels additional driving that contributes to climate change, doesn’t solve congestion, and is expensive. Highway expansion can also cause irreparable harm to communities – forcing the relocation of homes and businesses, widening “dead zones” alongside highways, severing street connections for pedestrians and cars, and reducing the city’s base of taxable property.
Complementary Policies
TCI is a step in the right direction to reduce pollution from transportation. Participating jurisdictions should continue to be ambitious and forward-thinking as they shape the future of transportation in the Northeast and Mid-Atlantic.
TCI states should adopt complementary policies designed to further reduce transportation emissions and build a more modern, cleaner and healthier transportation system. TCI states should:
Require that all new cars sold after 2035 be electric. To accelerate this transition, states should adopt California’s zero-emission vehicle program, pass legislation expanding EV tax rebates, develop a robust network of charging infrastructure.
Require that all transit and school buses be electric by 2030. To accelerate this transition, states should dedicate new resources and technical assistance to help bus operators go electric.
Set a goal of doubling the number of people who walk, bike or take public transportation by 2030. To get there, states should increase investment in public transportation systems, redesign streets to improve safety and accessibility for pedestrians and cyclists, adopt policies to support transit-oriented development and sustainable living, and shift away from policies that prioritize the type of transportation projects, like new highway construction, that have contributed to the problems with our current system.
In summation, we must do all we can as fast as we can. The longer we wait to cut carbon pollution, the more rapidly the planet will warm, robbing our kids and grandkids of the stable climate that we have taken for granted.
Sincerely,
ConnPIRG
Environment America
Environment Connecticut
Environment Maine
Environment Maryland
Environment Massachusetts
Environment New Jersey
Environment New Hampshire
Environment New York
Environment Rhode Island
Environment Virginia
Maryland PIRG
MassPIRG
New Jersey PIRG
New Hampshire PIRG
PennEnvironment
PennPIRG
Rhode Island PIRG
U.S. PIRG |
USPIRG Environment America TCI 2019 Comments.pdf |
12/23/2019 |
robert |
McAfee |
Independent |
pittsburgh |
Pennsylvania |
Taxing gasoline is a very repressive tax. Get rich sponsors like Bloomberg to contribute. Less taxes, less government regulation will stimulate innovation. Renewables do not produce enough... read more Taxing gasoline is a very repressive tax. Get rich sponsors like Bloomberg to contribute. Less taxes, less government regulation will stimulate innovation. Renewables do not produce enough power for the cost. Nuclear is the way.
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12/23/2019 |
William |
Davis |
Citizen |
Greensburg |
Pennsylvania |
I strongly appose this initiative. Pennsylvania already has one of the highest fuel taxes in the nation. We have been throwing money at public transportation for decades with no added results.... read more I strongly appose this initiative. Pennsylvania already has one of the highest fuel taxes in the nation. We have been throwing money at public transportation for decades with no added results. The problem is we citizens like our cars, adding another tax to pay for something that isn't fully used now is ridiculous, it is also already heavily subsidized with the current fuel taxes. If you're a politician that votes for this, don't expect to stay in office, this tax will hurt the average taxpayer and we remember. This idea sounds like the elites that have the largest carbon footprint, stating they buy credits to be carbon neutral, which makes no sense, since their actual footprint did not change. If they were serious about (or believed) this issue, they would just reduce their actual carbon footprint, basically do as I say, not as I do. |
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