TCI Regional Policy Design Stakeholder Submissions

Please see comments from the Metropolitan Area Planning Council and the Delaware Valley Regional Planning Commission attached. Thank you for the opportunity to provide feedback.

Alician Quinlan, Ph.D., P.E.
Falmouth MA
1 December 2019

I oppose implementation of the Transportation and Climate Initiative [TCI].

Claims of catastrophic warming of Massachusetts, New England, and the contiguous 48 States, now or soon, are not supported by temperature data collected by NOAA's United States Climate Reference Network [USCRN] and United States Regional Climate Reference Network [USRCRN], which are the sources of the most accurate and unbiased climate data available for the United States. Network description, data, and graphs are available for public scrutiny via:
https://www.ncdc.noaa.gov/data-access/land-based-station-data/land-based-datasets/us-climate-reference-network-uscrn
http://www.ncdc.noaa.gov/crn/ - national scale
http://www.ncdc.noaa.gov/crn/usrcrn/ - regional scale
http://www.ncdc.noaa.gov/crn/qcdatasets.html - access to datasets and graphs of datasets

According to these websites: USCRN and USRCRN programs aim to maintain sustainable high-quality climate observation networks that 50 years from now can with the highest degree of scientific confidence answer the question: How has USA climate changed over the past 50 years? USCRN is NOAA's premiere land-surface temperature observation network. It is managed by NOAA's National Climatic Data Center and operated in partnership with NOAA's Atmospheric Turbulence and Diffusion Division. It consists of a network completed in 2008 of 114 stations distributed across the 48 contiguous states, two stations in Hawaii, and a network of 29 stations in Alaska begun in 2009 and still being deployed. These stations were designed with climate science in mind. Three independent measurements of temperature and precipitation are made at each station, insuring continuity of a well-calibrated, highly accurate observation record. The stations are placed in pristine environments that are expected to be free of development for many decades. Stations are monitored and maintained to high standards and calibrated on an annual basis. In addition to temperature and precipitation, these stations also measure solar radiation, surface ‘skin’ temperature, and surface winds. They also include triplicate measurements of soil moisture and soil temperature at five depths, as well as atmospheric relative humidity for most of the 114 contiguous U.S. stations. Stations in Alaska and Hawaii provide network experience and observations in polar and tropical regions, respectively. Regional-scale USRCRN maintains the same high quality of climate science measurements as national-scale USCRN, but its stations are spaced more closely and focus solely on temperature and precipitation. Beginning with a pilot project in the Southwest that was completed in 2011, USRCRN stations will be deployed at an 80-mile [130 km] spatial resolution across the United States to provide for the detection of regional climate change signals.

So far, 15 years of USCRN data have been collected. These data do not support claims that temperature is rising inexorably and catastrophically, or even moderately, in the United States. For an example, see the plot in the attached PDF of USCRN temperature data for the contiguous 48 states from 2004-2019., one out of many data-plots available via http://www.ncdc.noaa.gov/crn/qcdatasets.html. This plot reveals, contrary to computer climate model predictions, that during the past fifteen years there has been, in fact, no inexorable, catastrophic rise in temperature across the 48 contiguous states. As a consequence, there is no factual scientific basis justifying the Transportation and Climate Initiative. For that reason, the it must be abandoned.

State and Federal government officials should be relying on USCRN and USRCRN observations such as those plotted in the attached PDF to formulate rational fact-based policies, regulations, and legislation rather than on computer model predictions that are known to conflict substantially with observed temperatures. A computer model is merely a hypothesis stated in the language of mathematics. The scientific method requires that the predictions of hypotheses be compared with observations. If predictions and observations conflict, the scientific method deems the hypothesis [e.g., the computer model] to have been falsified. The scientific method further requires that falsified hypotheses be discarded or re-formulated and re-tested, over and over again. The scientific method is an iterative process that can tell us with certainty only what is not true, never what is absolutely true, because the next observation might conflict with a prediction and thereby reveal the falsity of the hypothesis. As a consequence of the substantial discrepancies between temperature observations and climate computer model predictions, belief that climate models speak truth is an act of faith rather than of science, making the Transportation and Climate Initiative a faith-based initiative, not a science-based initiative. Faith should never be the basis for environmental regulations, legislation, and fees. They should be grounded in scientific fact [observation and measurement], not discrepancy-laden computer model predictions [make-believe].

Massachusetts Campaign for a Clean Energy Future

December 3, 2019

Response to Transportation and Climate Initiative
Framework for a Draft Regional Policy Proposal

Dear state government TCI officials:

This statement responds to your call for comments on the “Framework for a Draft Regional Policy Proposal.” We greatly appreciate your openness to public input on the proposal, and the depth of discussion in your draft.

We represent the Massachusetts Campaign for a Clean Energy Future (MCCEF), which is a coalition of organizations advocating for an economy-wide carbon pricing policy in the state. As such, we support the development of a robust and equitable cap-and-invest program for the transportation sector through TCI, but also recognize that TCI and RGGI only get us two-thirds of the way toward an economy-wide system, and urge states to extend carbon pricing to the heating fuels sector. Only by implementing carbon-reduction strategies throughout all the major fossil fuel-consuming sectors can the states achieve their goals to reduce emissions by 80 percent by 2050 -- or the more ambitious goals now being implemented in many states, such as 100 percent clean energy. Given the severity of the climate crisis, we cannot wait to take action to reduce carbon emissions from all sectors.

We support the points put forward by the Our Transportation Future (OTF) coalition, and some of our groups are members of that coalition. We will add here only points that are additional to OTF’s, or that we need to additionally emphasize.

Attached along with this statement we are attaching our Statement of Principles, which gives our criteria for a carbon pricing policy that is sufficiently strong to move our economy toward zero emissions. Our two basic principles state that carbon pricing must:
Achieve, in combination with other policies, the state’s GHG reduction mandates;
Ensure that the vast majority of low-income, and most moderate-income, people come out ahead or even from the combination of carbon pollution charges and use of the resulting revenues for rebates/tax cuts and reinvestment.
Beyond those two principles, below are our comments specific to the plan for TCI:

Cap levels - the cap must be set, initially and in future years, so that it will achieve in the transportation sector the reduction in emissions called for by the Massachusetts Global Warming Solutions Act and by similar acts in other states, which is at least 80 percent by 2050. Given that the transportation sector constitutes the largest portion of our emissions, we believe that this requires a 40 to 45 percent reduction below 1990 levels by 2030. As calculated by OTF, this would require beginning with a cap level of 250 MMT in 2022 and declining by 40 percent to just over 150 MMT by 2032.

Recent scientific evidence indicates that greater reductions are needed, and we would urge the TCI states to set the caps according to this evidence. We would further urge the states not to set the cap levels higher in order to prevent allowance prices from rising above a predetermined level. While such prices may cause motor fuel prices to rise significantly, the depth of the climate crisis means that we cannot avoid such price rises - which can be mitigated through use of the proceeds.

Use of the proceeds - We understand that use of the proceeds will be up to the individual state governments, but we believe that TCI should set standards for their use, just as was done under RGGI. Most carbon revenues should be allocated to investments that reduce GHG emissions, while also meeting essential public needs and creating jobs. This includes projects that support low-carbon transportation, including public transit and electric vehicles, and resilience to climate change impacts. The burdens of higher fuel prices can be mitigated by using the proceeds from allowances in ways that reduce transportation costs for environmental justice communities, low-income populations, and other vulnerable groups. In addition to investment spending, proceeds returned as cash benefits to low and moderate income consumers may be necessary to ensure that low- and moderate-income populations benefit from the program.

Just Transition - We believe that a Just Transition to a clean energy future requires addressing the possible losses that will occur to workers who lose jobs and to communities that face losses to their economies and tax revenues due to shrinkage of fossil fuel industries. We therefore support the provision of transition benefits and training for workers and communities who are affected. We also urge that all employment provided with carbon pricing revenue be at union-scale wage levels.

Integrity of the cap - The various design aspects of the program should be
transparently constructed and limited in order to ensure the program’s effectiveness. In particular, measures taken to moderate the costs of the program, such as offsets, price ceilings, and banking must only allow the cap to be exceeded in extreme circumstances and for limited time periods.
Baseline emissions must be transparently calculated and the initial cap must be stringent enough to avoid a future surplus of “banked” allowances.
If offsets are allowed they must meet the requirements currently used by the Regional Greenhouse Gas Initiative, including that offset projects should take place only within the regulated territory covered by TCI.
If a Cost Containment Reserve (CCR) is included, the trigger price must be set sufficiently high so that additional allowances are only made available under exceptional circumstances. If CCR allowances are purchased, the cap should further be reduced over the following five years by a quantity equal to or greater than the amount of CCR allowances purchased.
A price floor must be included that ensures stability of revenues and allowance prices in the range anticipated in the policy design.

Thank you for allowing us to provide our comments concerning the design of TCI. We look forward to further discussions on how best to reduce transportation sector emissions and to improve the functioning of the region’s transportation systems.

Yours truly,

Mary Ann Ashton, Co-President, League of Women Voters of Massachusetts
Marc Breslow, Policy and Research Director, Climate XChange
Nancy Goodman, Vice President for Policy, Environmental League of Massachusetts
Kristin Kelleher, Programs Director, Climate Action Business Association
Cindy Luppi, New England Director, Clean Water Action
Bill Ravanesi, Senior Director, Green Building & Energy Program, Health Care Without Harm
Jordan Stutt, Carbon Programs Director, Acadia Center

I would like to submit a PowerPoint and text from Advanced Biofuels USA’s recent presentation about biofuels as the quickest way to reduce the greatest amount of greenhouse gases for the lowest expense at a presentation for the Nov19 Meeting of Maryland Commission on Climate They can be found at: https://advancedbiofuelsusa.info/advanced-biofuels-usas-presentation-to-marylands-commission-on-climate-change-mitigation-work-group-on-benefits-of-biofuels-in-climate-change-mitigation-plan/

I will also attach the files one (the PowerPoint) in this submission and the text that goes with it in the next.

Essentially, these ideas address the 89% of vehicles in 2030 that, according to materials provided in the Draft Greenhouse Gas Reduction Plan, will still require liquid fuels. It also addresses fueling vehicles that are passing through Maryland on major highways that will also require liquid fuels.

Attached is an updated version of a letter submitted on August 29th, 2019 from Maryland organizations on principles that should be incorporated into the design of the Transportation & Climate Initiative. The letter has been updated with additional signatories.

Please find the attached letter regarding the role of hydrogen and fuel cells and the TCI Framework.

The New York State Association of Metropolitan Planning Organizations (NYSAMPO) is a consortium of the Executive Directors of fourteen Metropolitan Planning Organizations (MPOs) in New York State who work together toward best practices and common goals. The Directors lead a diverse group of organizations that represent very large, urban regions like the New York City metropolitan area as well as small metropolitan regions such as Ithaca and Elmira. Regardless of size and complexity, the Directors understand the value of working together to help their organizations provide high quality transportation planning support to their member agencies and to the public throughout the State.
The NYSAMPO Directors have determined that the overall goals of the Transportation & Climate Initiative’s (TCI) low carbon transportation policy proposal are consistent with the strategic goals and planning programs of the NYSAMPO MPOs, as represented in their long-range regional transportation plans and the projects, programs and studies that are funded through their planning processes. The NYSAMPO Directors applaud New York State for its leadership in the effort to establish the TCI. NYSAMPO MPO staff has attended and participated in listening sessions throughout New York State and the Directors appreciate the opportunity to offer the following comment on the design of the proposed program.
Equity
As organizations which plan for the use of transportation funding authorized by Congress, MPOs must comply with Title VI of the Civil Rights Act of 1964 which prohibits discrimination based upon race, color, and national origin. The NYSAMPO MPOs are committed to ensuring traditionally underserved and underrepresented communities receive a fair share of the regional transportation system’s benefits and are not subject to undue burdens. MPOs maintain information and data related to the locations of protected populations within each metropolitan area in order to comply with Title VI and the Executive Order on Environmental Justice. MPOs consider transportation barriers and needs within these communities. The TCI’s community outreach and project planning related to the investment of cap-and-invest proceeds should be coordinated with the NYSAMPO MPOs to ensure consistency with their equity efforts related to Title VI.
Mobile Source Emissions
Reducing emissions from transportation is a common strategic theme in the NYSAMPO MPOs’ regional transportation plans. Additionally, several of the NYSAMPO MPOs must comply with requirements under the Clean Air Act Amendments of 1990 as they develop their plans and programs. More recently, federal transportation legislation establishes performance measures for on-road mobile source emissions, which require that emission reduction targets be established for the ozone precursors nitrogen oxides (NOX) and volatile organic compounds (VOC). Targets are also required for carbon monoxide (CO) and particulate matter (PM10 and PM2.5).

Table 1. NYS On-Road Mobile Source Emissions Targets
Target Year VOC (KG) CO (KG) NOX (KG) PM10 (KG) PM10 (KG)
2020 22,979 437,781 58,591 9,312 3,920
2022 42,765 839,633 107,713 18,132 7,482

Proposed caps to emissions from gasoline, on-road diesel fuel, and potential biofuels, should meet or exceed these agreed upon targets to help states New York State meet its goals.
Investment of Proceeds
Transportation improvements proposed through the TCI should be coordinated with the NYSAMPO MPOs to achieve emission reductions and other policy goals within the long-range regional transportation plans. This coordination will maximize the efficiency and leverage investment in the transportation system which will ensure greater benefits to users. It is important that revenues generated by the initiative be used to advance active transportation, public transit, cleaner vehicles, and other activities that have large-scale positive impacts on environmental quality and public health through the reduction of GHG emissions. The NYSAMPO MPOs regularly use analytical and policy tools that assist in the prioritization of transportation projects for federal funding which could be modeled for determining how cap-and-invest proceeds are invested.


Complementary Policies
Coordination with the NYSAMPO MPOs will support the goals of the low carbon transportation system framework as each organization works within metropolitan areas of New York State to develop and implement complementary policies in long-range regional transportation plans. MPOs can supplement the work of TCI by assisting municipalities within the metropolitan areas with coordinating infrastructure planning and land use planning that supports reducing emissions. For more information on NYSAMPO please visit our website at https://www.nysmpos.org/ or contact Michael Franchini at (518)458-2161 with any questions. We look forward to working with TCI and NYS in planning for a low carbon future.