2/28/2020 |
Sharon |
Moulton |
personal |
Leeds |
Massachusetts |
I have attached my personal comments. I have attached my personal comments. |
TCI Stakeholder Comments.pdf |
2/28/2020 |
Jordan |
Giaconia |
Vermont Businesses for Social Responsibility |
Burltington |
Vermont |
February 28, 2020
To: Governor Ned Lamont, Governor John Carney, Governor Janet Mills, Governor Larry Hogan, Governor Charlie Baker, Governor Chris Sununu, Governor Phil Murphy,... read more February 28, 2020
To: Governor Ned Lamont, Governor John Carney, Governor Janet Mills, Governor Larry Hogan, Governor Charlie Baker, Governor Chris Sununu, Governor Phil Murphy, Governor Andrew Cuomo, Governor Tom Wolf, Governor Gina Raimondo, Governor Phil Scott, Governor Ralph Northam and Mayor Muriel Bowser.
On behalf of Vermont Businesses for Social Responsibility (VBSR), I am writing to express strong support for the Transportation and Climate Initiative (TCI) and comment on the draft Memorandum of Understanding (MOU.)
Vermont Businesses for Social Responsibility is a business association representing over 730 business members in every industry and every county across the state; united in our shared mission to advance an ethic that protects the natural, human, and economic environments of Vermont as a business thrives.
From global brands like Ben & Jerry’s and Burton to small startups like Mamava, VBSR members are some of the most successful and iconic businesses in our state, who together shape the Vermont brand. Of the top 25 companies in Vermont, 13 are VBSR members – including our champion members Green Mountain Power and National Life Group. Those 13 companies together earned over 9 billion dollars in revenue in 2012, according to Vermont Business Magazine.
In 2018, we surveyed our members on annual revenues – just under 50%, or about 185 companies, earn less than $500,000 a year. About 16% earn between $500,000 and $1 million a year, 9% earn $1 to 5 million a year, 7% earn $5-20 million a year, and 10%, or about 70 companies, earn over $20 million a year in revenue.
No matter their size our businesses recognize that our continued reliance on fossil fuels is triggering a climate crisis and stifling our economy. The longer we delay in taking action the more exacerbated these impacts become. For Vermont, the transportation sector accounts for nearly half of our carbon emissions and so it is imperative that we seize this rare opportunity to decarbonize our region’s transportation system with a strong, equitable TCI cap-and-invest program.
The potential benefits of this carbon pricing system make it a far cry from the gas tax opponents claim it will be. A cap and invest system would establish a limit on carbon emissions and a regional auction for participating states to sell their emissions allowances. They can then invest those revenues into cost-saving programs designed to reduce prices at the pump such as electric vehicle (EV) incentives, rural broadband to support remote work and telemedicine, bike and pedestrian infrastructure, public transit, and more. Conversely, a gas tax means higher costs at the pump without any palpable transportation or environmental benefit.
VBSR urges the working group to develop a program that will not only decrease climate pollution but use program revenues to address the needs of rural, low-income communities who are overburdened by vehicular pollution, transportation costs, and a lack of clean transportation options. These communities are often those most directly impacted by the adverse effects of climate change and as such should enjoy the strongest benefits of this program. Considering the different challenges each state faces in our region, we also call for strategic, state-by-state investments to be made to ensure equity.
The challenges rural, working Vermonters face are far different than those living in Boston, Baltimore, or Burlington, so it is essential that we give states the flexibility to invest program revenues into transportation solutions that serve their respective communities rather than take a one-size-fits-all approach.
The urgency to develop and implement TCI cannot be overstated and VBSR is pleased to see that the timeline outlined in the draft MOU reflects this. The initial compliance period launch on January 1, 2022 recognizes the need to take swift action while providing states with adequate time to elevate the program and prepare for participation.
Along that same line, we strongly urge that the working group adopt an emissions cap on transportation pollution at a pace and scale in line with science by requiring no less than a 25% pollution reduction in the first ten years from the program’s 2022 adoption. There is a clear consensus within the scientific community that significant, rapid pollution reductions are needed, and we implore you to consider pursuing even more ambitious greenhouse gas reductions moving forward as well as continuous programmatic evaluation of TCI to ensure its continued progression and efficacy.
Climate change is without question the single greatest threat to Vermont's communities, ecosystems, and shared way of life. Spring is arriving earlier, heavy rainstorms are becoming commonplace, and our summers are hotter and drier than ever. Meanwhile more frequent and severe storms cause floods that cost us millions in damaged property and infrastructure. From winter recreation and local food driven tourism to manufacturing and service industries, these changes disrupt nearly every facet of our state’s economy— and we can no longer afford half measures.
TCI offers one of the most promising opportunities to advance solutions that recognize our shared responsibility to take action, strengthen our economy and bring Vermont’s most vulnerable along in our climate future by reducing pollution from the transportation sector. We appreciate the opportunity to comment and your continued work to improve and implement a strong, equitable program.
Thank you,
Jordan Giaconia
Public Policy Manager
Vermont Businesses for Social Responsibility
Jordang@vbsr.og
860-304-2251(mobile)
|
TCI comment letter VBSR.pdf |
2/28/2020 |
will |
cembalest |
Middlebury College Student |
brooklyn |
New York |
To Whom it May Concern,
I appreciate being given the chance to provide my own feedback to the TCI. My name is Will Cembalest and I am an environmental economics major at Middlebury... read more To Whom it May Concern,
I appreciate being given the chance to provide my own feedback to the TCI. My name is Will Cembalest and I am an environmental economics major at Middlebury College, spending this spring term assessing the environmental, social and economic dynamics of Vermont’s transportation systems. I am commenting on behalf of myself, and holding true to the best interests of the Addison County region. Vermont’s largest source of greenhouse gas emissions is the transportation sector, so this program can effectively catalyze positive change in Vermont, and across the northeast region.
I would like to draw attention to MOU section I.3, Offsets, which addresses the regulations on the entity compliance and flexibility. The language used to discuss this directive is too tolerant of the state fuel suppliers. Engaging in carbon offset programs allows the state fuel suppliers to generally maintain their status quo operations, and fund alternative projects which may not most effectively support burdening low-income communities. This carbon offset procedure must set forth very stringent regulations to best support the rural communities in Vermont.
Carbon offset programs are very effective where certain carbon-mitigating, progressive projects are unable to attract the capital input necessary; the revenues from the offsets can decrease the technological and financial risk associated with the project. However, in many cases, fuel suppliers will engage in carbon offsets because they can be cheaper than using their own internal funds to invest in cutting their in-house greenhouse gas emissions. The largest issue with this scheme is that the carbon offset project would have been “implemented anyway”, which was found in a study conducted in 2010 looking at the Specified Gas Emitters Regulation in Alberta, Canada. In this case, a project such as switching fuels from diesel to natural gas, or installing energy efficient commercial heaters when the dilapidated burners needed replacement anyway, qualified as a GHG offset. This did not shift their emissions from their business as usual scenario, and failed to uphold the overall goal of the regulation: forcing polluters to make innovative changes to decrease emissions from the business as usual case.
If the program proves successful in the short run, it should eliminate the availability to purchase carbon offsets as an alternative, and make it an additional expenditure which state fuel providers can engage in if they wish. Under the RGGI program, which has proven successful by decreasing power plant emissions by 90% relative to the rest of the U.S, Massachusetts, Rhode Island and New Hampshire have all disbanded the ability to purchase offsets, described on the RGGI website. This indicates their intentions to decrease the polluter’s agency in dodging internal emissions reduction investments. For the time being, the offset program can exist only if the revenues from the project financially assist the residents within the TCI regions in transitioning towards a green fuel economy. Nowhere in the MOU is it specifically stated what kind of emissions offset projects they wish to engage in, nor the direct intention to positively impact low-income citizens. There must be several criteria for the offset project, recommended by the National Resource Defense Council. First, the offset project should be verified before the implementation of the project, not after a group collects the proceeds. Then, the project must be enforceable, where a third-party ensures its execution. Lastly, the offset must be permanent, guaranteeing that the positive impacts from project persist into the future.
Since it is the citizens of the states who are bearing the consequences of increased gas prices under the TCI and face future burdens of climate change in these regions, the proceeds are needed to support them in the transition towards a greener fuel economy. This would include initiatives like electric vehicle charging stations or subsidies for purchasing electric vehicles. Nowhere is it mentioned that the offset projects will remain within the premises of the states.
If this offset program were to exist, they must truly limit the amount of carbon offsets the state fuel supplier is able to purchase over the lifespan of the program, and additionally, the proceeds must be allocated towards specifically assisting in electrifying the fuel economy.
Thank you for your consideration.
Sincerely,
Will Cembalest
|
TCIPublicComment_Cembalest.pdf |
2/28/2020 |
Kris |
DeLair |
Empire State Energy Association, Inc. (ESEA) |
Troy |
New York |
See attached. See attached. |
TCI Comments.pdf |
2/28/2020 |
Shai |
Sahay |
POET, LLC |
Washington |
District of Columbia |
On behalf of POET, LLC, I am submitting the attached comments on the TCI Draft Memorandum of Understanding and Prospective Model Rule. Please let us know if you have any questions or need... read more On behalf of POET, LLC, I am submitting the attached comments on the TCI Draft Memorandum of Understanding and Prospective Model Rule. Please let us know if you have any questions or need additional information. |
POET February 2020 Comments on TCI MOU and Prospective Model Rule.pdf |
2/28/2020 |
Brydon |
Ross |
Consumer Energy Alliance |
Louisville |
Kentucky |
To whom it may concern,
Attached are comments on behalf of Consumer Energy Alliance concerning the Draft MOU of the Transportation Climate Initiative. We appreciate the opportunity to... read more To whom it may concern,
Attached are comments on behalf of Consumer Energy Alliance concerning the Draft MOU of the Transportation Climate Initiative. We appreciate the opportunity to provide our feedback. |
CEA TCI Draft MOU Comments 2.28.20.pdf |
2/28/2020 |
James |
Rooney |
Greater Boston Chamber of Commerce |
Boston |
Massachusetts |
Dear Governors of the Northeast and Mid-Atlantic States,
I am writing on behalf of the Greater Boston Chamber of Commerce regarding the Draft Memorandum of Understanding of the... read more Dear Governors of the Northeast and Mid-Atlantic States,
I am writing on behalf of the Greater Boston Chamber of Commerce regarding the Draft Memorandum of Understanding of the Transportation and Climate Initiative (TCI). The Chamber shares TCI’s goal of reducing greenhouse gas emissions in the transportation sector and supports the broad framework that has been proposed. Accordingly, our comments are intended to inform the development of the final TCI program design. The Chamber urges you to develop TCI so the region sees emissions reductions that are substantially lower than business-as-usual (BAU) projections, to include a secondary market for emissions allowance trading, and so that the program design does not include perverse incentives to maintain high emissions in order to preserve a revenue source.
Projected Emissions Reductions
To rationalize the development of TCI, it is imperative that the benefit of creating a new regional market on transportation emissions is significant enough to justify the cost, both real and administrative. The final TCI program design should result in emissions reductions that are substantially lower than BAU projections. The 2019 TCI modeling and sensitivity analysis project emissions reductions of 6% to 19% under a BAU scenario between 2022 and 2032. Meanwhile, the three proposed caps for the TCI program would result in emissions reductions for that time span of 20%, 22%, or 25%, including the anticipated BAU reductions. As structured, the program would result in a potentially minor reduction in emissions that may not make the cost increase seem worthwhile.
Secondary Market
The draft MOU briefly describes the monitoring of the proposed carbon market and the administration of allowance auctions; however, no reference is made to a secondary market for emission allowance trading outside of the auctions. Other market-based cap-and-invest programs, including the Regional Greenhouse Gas Initiative (RGGI), allow for trading of emissions allowances on a secondary market. The Chamber strongly urges the TCI framers to include a set of provisions in the final MOU and the model rule for a secondary market permitting the sale of emissions allowances among regulated entities and third parties.
Including a secondary market in the TCI program is important for multiple reasons. First, a secondary market increases program flexibility by allowing regulated entities to purchase additional allowances to meet program obligations or to sell excess allowances. In addition, a secondary market provides the ability to sell or obtain allowances in between auctions, ensuring that allowances are liquid, and the carbon market remains stable. Finally, a secondary market will promote innovation among regulated entities by incentivizing firms to increase efficiency or upgrade technology in order to reduce emissions. Doing so will allow them to sell and profit from the unused allowances they purchased at auction.
Program Integrity
TCI is dependent on a declining cap for transportation emissions and the associated allowances that are auctioned to regulated entities. Because states’ allowance proceeds derive from these auctions, it is important that the final MOU and model rule account for the perverse incentive to maintain high emissions to sustain a revenue source. TCI proceeds can result in substantial and beneficial public investment but should not viewed as a permanent or increasing source of revenue.
Thank you for your consideration. We urge you to continue working collectively as a regional coalition and look forward to assisting you as you develop the final iteration of TCI. Please do not hesitate to contact me if you have any questions.
Sincerely,
James E. Rooney
President and CEO
|
02-28-20 TCI Comment Letter.pdf |
2/28/2020 |
Kasia |
Hart |
Metropolitan Area Planning Council |
Boston |
Massachusetts |
Please see the attached letter. Please see the attached letter. |
TCI Municipal Letter.pdf |
2/28/2020 |
Kasia |
Hart |
Metropolitan Area Planning Council |
Boston |
Massachusetts |
Please see the attached letter. Please see the attached letter. |
2020-02-28_MAPC TCI MOU Comment Letter_Final.pdf |
2/28/2020 |
Kasia |
Hart |
Metropolitan Area Planning Council |
Boston |
Massachusetts |
Please see the attached letter. Please see the attached letter. |
2020-02-27_COG MPO TCI MOU Letter_Final.pdf |
2/28/2020 |
Don |
Mathis |
Harford County Climate Action |
Havre De Grace |
Maryland |
Please see attached comments on the Transportation and Climate Initiative, submitted by Harford County Climate Action Please see attached comments on the Transportation and Climate Initiative, submitted by Harford County Climate Action |
Letter to Hogan on Transportation and Climate Initiative (1).pdf |
2/28/2020 |
Don |
Thoren |
AFPM |
Washington |
District of Columbia |
AFPM is a trade association representing high-tech American manufacturers of nearly 90% of U.S. supply of gasoline, diesel, jet fuel, other fuels and home heating oil, as well as nearly all the... read more AFPM is a trade association representing high-tech American manufacturers of nearly 90% of U.S. supply of gasoline, diesel, jet fuel, other fuels and home heating oil, as well as nearly all the petrochemicals used as building blocks for thousands of vital products in daily life. AFPM members make modern life possible and keep America moving and growing as they meet the needs of our nation and local communities, strengthen economic and national security, and support more than three million American jobs. |
AFPM Comments to Georgetown Climate Center.pdf |
2/28/2020 |
Brooke |
Lierman |
Maryland State Delegate |
Annapolis |
Maryland |
Please see a letter attached from members of the Transit Caucus in the Maryland General Assembly. Please see a letter attached from members of the Transit Caucus in the Maryland General Assembly. |
TCI letter_Transit Caucus_2_21_20.pdf |
2/28/2020 |
Michael |
O'Connor |
Virginia Petroleum & Convenience Marketers Association |
Richmond |
Virginia |
Virginia Petroleum and Convenience Marketers Association is a statewide trade association formed in 1948 representing the interests of the state’s petroleum and convenience industries. We are... read more Virginia Petroleum and Convenience Marketers Association is a statewide trade association formed in 1948 representing the interests of the state’s petroleum and convenience industries. We are pleased to submit comments on the Transportation and Climate Initiative’s draft Memorandum of Understanding. |
TCI MOU comments final.docx |
2/28/2020 |
Matt |
Butner |
Institute for Policy Integrity at New York University School of Law |
New York |
New York |
In these comments we outline TCI's program design and anticipated benefits before making four concrete recommendations to participating jurisdictions for consideration in the development of... read more In these comments we outline TCI's program design and anticipated benefits before making four concrete recommendations to participating jurisdictions for consideration in the development of the final MOU. |
Policy Integrity Comments for TCI Draft MOU.pdf |
2/28/2020 |
Paul |
Allen |
M.J. Bradley & Associates |
Washington |
District of Columbia |
Please see the attached comments from Exelon Corporation and Public Service Enterprise Group. Please see the attached comments from Exelon Corporation and Public Service Enterprise Group. |
Utility Comment Letter on TCI MOU FINAL.pdf |
2/28/2020 |
Sean |
Burke |
Northeast Clean Energy Council |
Boston |
Massachusetts |
Attached please find Joint Comments from the Northeast Clean Energy Council, the Alliance for Clean Energy New York, and Renewable Energy Vermont Attached please find Joint Comments from the Northeast Clean Energy Council, the Alliance for Clean Energy New York, and Renewable Energy Vermont |
Joint Comments on TCI Draft MOU.pdf |
2/28/2020 |
Sam |
Wade |
Coalition for Renewable Natural Gas |
Sacramento |
California |
Attached please find a study by MJ Bradley describing the potential benefits of renewable natural gas to the TCI region. (This study is referred to in our comments submitted under a separate form... Attached please find a study by MJ Bradley describing the potential benefits of renewable natural gas to the TCI region. (This study is referred to in our comments submitted under a separate form.) |
MJBA_Role-of-Renewable-Biofuels-in-a-Low-Carbon-Economy.pdf |
2/28/2020 |
Sam |
Wade |
Coalition for Renewable Natural Gas |
Sacramento |
California |
Attached please find our comments on the Draft MOU. Attached please find our comments on the Draft MOU. |
200228 RNGC Comments on TCI Draft MOU.pdf |
2/28/2020 |
Mark |
Borowski |
BP America |
Washington |
District of Columbia |
BP America is happy to provide the attached letter as our input to the TCI draft memorandum of understanding. BP America is happy to provide the attached letter as our input to the TCI draft memorandum of understanding. |
BP Letter on TCI Draft MOU.pdf |