TCI Regional Policy Design Stakeholder Submissions

The Sierra Club is sharing the attached 561 comments from our members and supporters in Maryland supporting finalizing the Draft Memorandum of Understanding (MOU) of the Transportation and Climate Initiative (TCI). Thank you for helping to design a regional policy to limit climate pollution from motor fuels and invest in a modern, clean, transportation future. The evidence is clear: the more we limit pollution from motor fuels, the more jobs are created, the more the economy grows, and the more lives we save. Please sign on to the agreement to implement a strong, equitable regional climate protection policy through TCI. Invest in the communities that have suffered the most from burning gasoline and have the least access to clean transportation options. Stop sending our hard-earned dollars out of the state to oil companies, and choose to create jobs, grow the economy, and save lives for families and businesses. Thank you.

The Sierra Club is sharing the attached 102 comments from our members and supporters in Delaware supporting finalizing the Draft Memorandum of Understanding (MOU) of the Transportation and Climate Initiative (TCI). Thank you for helping to design a regional policy to limit climate pollution from motor fuels and invest in a modern, clean, transportation future. The evidence is clear: the more we limit pollution from motor fuels, the more jobs are created, the more the economy grows, and the more lives we save. Please sign on to the agreement to implement a strong, equitable regional climate protection policy through TCI. Invest in the communities that have suffered the most from burning gasoline and have the least access to clean transportation options. Stop sending our hard-earned dollars out of the state to oil companies, and choose to create jobs, grow the economy, and save lives for families and businesses. Thank you.

The Sierra Club is sharing the attached 320 comments from our members and supporters in Connecticut supporting finalizing the Draft Memorandum of Understanding (MOU) of the Transportation and Climate Initiative (TCI). Thank you for helping to design a regional policy to limit climate pollution from motor fuels and invest in a modern, clean, transportation future. The evidence is clear: the more we limit pollution from motor fuels, the more jobs are created, the more the economy grows, and the more lives we save. Please sign on to the agreement to implement a strong, equitable regional climate protection policy through TCI. Invest in the communities that have suffered the most from burning gasoline and have the least access to clean transportation options. Stop sending our hard-earned dollars out of the state to oil companies, and choose to create jobs, grow the economy, and save lives for families and businesses. Thank you.

Transforming Rural Transportation to Benefit All Vermonters with TCI

The status quo of transportation in Vermont isn’t serving the best interests of our communities. Instead, it’s hurting our environment, health, and wallets. With Vermont’s rural geography, Vermonters drive 20 percent more than the national average to get to work and spend a large part of their incomes on gasoline and car maintenance. Our cars and trucks make up over half of our state’s greenhouse gas emissions, and the tailpipe pollution spewing from them contributes to an influx of health problems, drives hospital visits and burdens Vermonters with healthcare costs.

The good news is that Governor Scott has an immediate opportunity to shift us away from the dirty status quo and invest in Vermont’s future. It’s called the Transportation and Climate Initiative, or TCI for short. TCI would establish a multi-state program that caps emissions from motor fuels in the Northeast and invests in clean transportation solutions as early as 2022.

Multiple polls in Vermont and across the region have shown broad, bipartisan support for a cleaner, safer, healthier, more equitable and modern transportation system. Legislative and business leaders, urban and rural communities, and stakeholders across the political spectrum are all on board to reduce transportation pollution, create thousands of new jobs and save consumers billions of dollars in healthcare costs. (If this sounds good to you, take action: Residents from across the region can offer their comments on the draft plan at the online portal through February 28th.)

Opponents of TCI are mostly dirty energy companies and well-funded allies that are happy to keep profiting off Vermonters, polluting our communities and climate as they take hard-earned dollars out of state. (In Vermont, 80 cents out of every dollar spent on motor fuels is sent out of state.). Imagine instead if we kept that money in Vermont: How many jobs could we create, how many electric vehicles could we adopt, and how many transit services could we expand and improve?

Given the urgency of intertwined climate and public health crises, clean transportation policies must be even more ambitious than what states have proposed so far. Reducing pollution from motor fuels only 20 to 25 percent by 2032, what the current TCI plan has modeled, falls far short of Vermont’s climate protection goals. A stronger program would mean more emissions reduced, more jobs and wealth for communities, less childhood asthma, and more lives saved.

The states’ draft plan for TCI already projects big benefits; a 25 percent reduction in motor fuels could prevent over 1,000 premature deaths and 1,300 asthma attacks per year in the region and raise up to $23 million dollars for Vermont to start. Imagine the benefits under a stronger pollution reduction target, such as 45 percent.

While the state advances incentives for electric vehicles (which just started and must be increased), we have massive room for improvement to clean up our transportation system in an equitable way that benefits all residents, including a statewide shift to electric buses, infrastructure to enable more telecommuting, more affordable housing near work and transportation hubs, and more accessible and affordable transit with new innovations such as micro-transit. These policies will set us on a course to reach our goals and save Vermonters money. Funding generated from the TCI — the top fuel distributors would need to purchase pollution permits — can help make them happen.

Throughout this process, we must ensure that Vermont’s rural and low-income communities that are underserved and have the least access to clean and safe transportation options are first in line for investment and benefits.

We need to look towards our future, bettering our transportation and moving forward on climate progress. We can’t let dirty energy interests continue to pollute our communities and hold Vermonters hostage to the whims of oil barons. Given federal attacks on clean car standards, 2020 is the year that state leaders must work together on regional solutions to transform our transportation systems. Governor Scott should join his fellow governors to finalize a strong and just regional Transportation and Climate Initiative to limit climate pollution from motor fuels this spring.

Robb Kidd
Conservation Program Manager
Sierra Club Vermont
Montpelier
robb.kidd@sierraclub.org

February 24, 2020

Ms. Kathleen Theoharides, Chair
Transportation & Climate Initiative of the Northeast and Mid-Atlantic States
Georgetown Climate Center
600 New Jersey Avenue, NW
Washington, DC 20001

Dear Secretary Theoharides:

My name is Rita Hansen and I am the CEO of Onboard Dynamics, Inc., an early phase company and a spinout from Oregon State University that provides novel compression technology to enable the use of natural gas and renewable natural gas as a transportation fuel. I appreciate the opportunity to comment on the Transportation & Climate Initiative (TCI) Draft Memorandum of Understanding of the Transportation and Climate Initiative and I commend TCI’s goals of equity, environmental justice, non-discrimination and meaningful public participation as it develops and implements a regional policy for transportation emissions reductions.

Onboard Dynamics endorses strategies that support the transition to low-carbon transportation fuels, including geologic and renewable natural gas. Converting the Northeast and Mid-Atlantic regions’ heavy- and medium-duty freight and transit transportation network to natural gas provides a readily available, proven and cost-effective solution to accelerate the transition to a low-carbon transportation future. Further, 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 trucks and buses, including those higher emitting vehicles that operate in communities that are underserved by current transportation options and overburdened by urban pollution.
Cleaner Air Starts with Cleaner Trucks and Buses

Increased use of natural gas as a transportation fuel provides immediate and significant criteria and toxic air pollutant reductions. Fact: the cleanest commercially available heavy-duty engine in the world is powered by natural gas now and for the foreseeable future. Designed, built, and manufactured in America by Cummins Westport, this engine is certified to a 0.02 g/bhp-hr. standard, making it 90 percent cleaner than the EPA’s current NOx emissions requirement and 90 percent cleaner than the cleanest diesel engine. And in real-life study, these engines emitted lower NOx emissions than certified.

Replacing just one traditional diesel-burning heavy-duty truck with one new Ultra Low-NOx natural gas truck is the emissions equivalent of removing 119 traditional combustion engine cars off our roads. Heavy-duty equals heavy impact.

Carbon-Neutral/Negative Freight with RNG

Natural gas engines offer significant climate change benefits. Compared to diesel, natural gas engines fueled with geologic natural gas reduce CO2 and greenhouse gas emissions by at least 12 percent. When fueled with renewable natural gas (RNG or biomethane) captured from agricultural, food, landfill or wastewater, even greater CO2 and greenhouse gas benefits are achieved, up to 331 percent lower than diesel. Fueling with RNG is carbon-neutral, even carbon-negative, depending on the feed stock as shown below. No better commercially available and deployable alternative fuel option currently exists for the heavy-duty sector.

CARBON INTENSITY of TRANSPORTATION FUELS (EER-Adjusted)
<Please see the attachment for the chart inserted here.>

Address Noise Pollution

Natural gas vehicle technology affordably addresses noise pollution in urban neighborhoods. A U.S. Department of Energy study identified significant noise reduction benefits as a motivator for many refuse collection truck operators in accepting the technology, citing up to 10 decibels quieter than their diesel counterparts. A 2016 in-use study of diesel and CNG urban transit buses in Serbia found considerable reductions in noise pollution when powered by CNG.

Invest Impactfully – Emissions Reductions using Cost Effective Solutions

Investments in Ultra Low-NOx Near Zero emission natural gas vehicle technologies greatly impact communities, especially the underserved and marginalized communities in metropolitan and industrial areas. With vehicle costs close to that of diesel and fuel price differentials of up to $1.50 less than diesel per DGE, natural gas transportation provides the largest and most cost-effective reductions in transportation-related pollutants than any other powertrain option commercially available today or near-term.

UPS, Waste Management, Republic Services, Los Angeles World Airports Buses, City of Los Angeles, City of Fresno Transit, LA Metro Transit, New York’s Hunts Point fleet Industries and many other fleets recognize the exponential impact of using RNG for emissions reductions and their improving business’ bottom line. In May of 2019 UPS announced that it will purchase 170 million gallon equivalents over 7 years that will reduce GHG emissions by more than 1 million metric tons, and in October UPS announced the order of 6000 heavy duty NGV RNG trucks to double the size of their NGV fleet. In February 2020, UPS increased their RNG commitment to a total of 250 million-gallon equivalents over 7 years.

Meanwhile, Waste Management has converted approximately 9,000 of its 17,000 collection vehicles to natural gas, resulting in the largest heavy-duty natural gas truck fleet of its kind in North America. Over 40 percent of Waste Management’s natural gas fleet currently is fueled with RNG produced from landfill biogas, supporting its long-term strategy of creating a near-zero emissions collection fleet. RNG already fuels more than 32% of the over 175,000 NGVs in the U.S. today, and a growing number of fleets are taking advantage of vehicles that are available now at comparable life cycle costs to diesel vehicles and that provide transformational GHG and tailpipe emissions reductions.

As such, investments in RNG-fueled trucks and transit buses accessing ports, cities, and densely populated neighborhoods are the most immediate and fiscally responsible investment to clean our air and combat climate change. Communities get more clean vehicles having greater clean air and climate impact for the money with natural gas than with any other alternative fuel option, especially electric. No other transportation fuel is as sustainable, adaptive, and competitive across all applications and vehicle classes. And heavy-duty natural gas trucks are not demonstration science projects; they are proven, scalable, and on U.S. roads today. We will not meet emissions reduction goals or time frames without using natural gas.

Natural Gas Pays Its Way and Provides Economic Opportunity

Natural gas fueling pays into the federal highway trust fund and is ready-right-now technology. It is road-tested and backed by a mature network of manufacturers, servicers, and suppliers coast-to-coast. An established refueling infrastructure of 2,000 stations already exists.

It is also important to note that while 34 U.S. states produce geologic natural gas, the potential to produce RNG exists in every U.S. state and the District of Columbia by taking the problem of fugitive methane gas created from organic waste, capturing it, then using it to fuel traditionally heavy-carbon freight and transit transportation applications. In addition to its clean air and climate benefits, the development of RNG facilities also supports the agriculture industry with new revenue streams, addresses many cities’ solid waste issues, and impacts watershed management efforts and nitrogen runoff concerns. With these positives, the demand for RNG production is growing and new RNG facility development projects are increasing rapidly.

100% Domestic Fuels

Geologic and renewable natural gas are 100 percent domestic fuels, unlike limited electric vehicle battery components that are controlled by foreign interests and mostly sourced from conflict countries like the Democratic Republic of the Congo and China. The U.S. EPA recognizes the value of RNG and includes it in the EPA Renewable Fuel Standard (RFS) federal incentive. Similarly, several states have implemented low carbon fuel standards (LCFS) that promote the use of RNG and other renewable fuels.

More than four in ten Americans live in communities with dangerously dirty air. According to the American Lung Association, that number continues to rise, from 125 million in 2017 to nearly 141.1 million today. Cap-and-invest program investments in natural gas vehicle technologies offer the most proven, cost-effective, and immediate way to promote a low carbon transportation future, clean our air, and provide more affordable, accessible, and reliable transportation opportunities for marginalized and underserved communities.

As the TCI states in the Draft MOU, a regional program “addresses the urgent need to mitigate greenhouse gas emissions and other harmful pollutants generated by the transportation sector” which I fully agree with and offer that natural gas vehicles, especially those using RNG must be a key component to any TCI strategy if these reductions are to occur in any reasonable time frame and improving the areas of greatest need.

Thank you for your consideration, and please contact me at rita.hansen@onboarddynamics.com or 206.291.3206 with any comments or questions.

Thank you for your consideration.

Sincerely,
Rita Hansen
CEO

I am very supportive of this initiative and what is being undertaken, I share the project goals and objectives. I would like to see 100% of the investment go directly into electric vehicle incentives and EV infrastructure. Growing mass transit is a very laudable objective, however it requires a very difficult public behavior change and is clearly not practical in much of NY State.

Please continue and expand the direct purchase rebate for EV's in all states, NY is currently $2,000, NJ is better, currently at $5,000, applied at vehicle acquisition.

Please use the investment funds to incentivize the build out of EV DC fast charging stations across NY. The lack of DCFC infrastructure is a significant hindrance to the rapid adoption of EVs. The convenience of charging at home is great, but we need the DCFC infrastructure to be put in place to win over the majority of drivers.

In summary, I recommend all the investment dollars be directed towards reducing acquisition cost of ZEVs and incentivizing a reliable, robust, dependable, and prolific DCFC network across NY and the entire northeastern US.

Please see attached for my full feedback.