TCI Regional Policy Design Stakeholder Submissions

I live in NJ. My husband and I will be moving soon to CT to be near our older son and his family. Our other son lives in DC. I would LOVE for train travel to be more convenient and more frequent, as it is in Europe. For day trips into NYC, short vacations in New England, PA, DE, MD and visits to DC, train travel is (or should be) much safer and better for the environment than traveling by car. Yet it just isn't simple. Even now, living just outside NYC, we find it easier to drive into Manhattan for restaurants, museums and entertainment, than taking the train. More expensive, but not to be stuck in one of the Penn Stations for an hour, because the trains are so infrequent (if they are even running at all...hello Uber!). This just shouldn't be our reality in the "greatest country."

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.

Retired here in south western Pennsylvania which has some of the dirtiest air in the country. I worked for the Air Pollution Control Bureau back in the early seventies and attended Duquesne University on an EPA Fellowship earning a MS in chemisty. We had poor air quality then and still have poor air quality. I would like to think that we have better air quality fifty years later but that doesn't seem to be the case. I have two grown children that are both asthmatic, most likely to the poor air quality when they were growing up. The general health of most citizens here in western Pennsylvania could be better if the air quality would improve.

Mass Governor must bring this to the people. He must stop acting like a dictator. Passing this tax on businesses like the one I own will kill any further growth and adding workers. There is no way of passing on these exsorbant added cost in the industry. Governor Baker stop acting like a dictator, we are a government of the people, you work for us! Stop wiping out industries that you don't care about. We can not all be in BioMed and IT that continue to get massive Taxes Breaks.

General statement: Transportation is the largest source of air pollution in the region, and we need to build a modern, clean, safe, and accessible transportation system for the 21st century. The more we limit pollution from motor fuels, the more jobs we create, the more the economy grows, the healthier our air becomes, and the more lives we save. Massachusetts should join TCI to fund better transportation infrastructure, reduce traffic, and make my community a cleaner, safer place to live.

Public Health: It is clear that air pollution from cars, trucks, and buses have become a huge detriment to my community’s health. Air pollution has been linked to a variety of health problems, including asthma, heart disease, and lung cancer, and the more ambitious TCI is, the more our community stands to benefit from a cleaner transportation system. I urge my Governor to join TCI and push it to be as ambitious as possible, for the sake of my community’s health and livelihood.

Rural areas: As a person living in a rural area, I think that TCI is extremely important. When states join TCI, they have the opportunity to invest in rural communities where transportation options are limited. Joining TCI would allow Massachusetts to ensure that rural communities aren’t left behind in the green transition and stuck behind the wheel of costly, inefficient vehicles. Governor Baker should push for an ambitious TCI program so that rural communities like mine get the solutions they need.

We can cut poverty and pollution at the same time. We urge you to move forward with a regional program that prioritizes the needs of communities overburdened with pollution and underserved in mobility options

The growing evidence of the dangerous impacts of climate change in the United States and across the globe means that is in our own self-interest to follow through on the commitment now to implement a regional low-carbon transportation policy proposal that will cap and reduce carbon emissions from the combustion of transportation fuels through a cap-and-invest program or other pricing mechanism. This should work in tandem with Virginia's participation in the Regional Greenhouse Gas Initiative.

Maine should use TCI as an opportunity to invest in local transportation solutions that help Maine people get to where they need to go in an affordable way that’s good for our environment. We need to stop sending Maine money to oil companies; let’s reinvest our money into our communities and local clean energy.

James Smith

I attended the 11/4 session at Holyoke community college, and want to put some thoughts in writing.

Instead of emission caps and selling these to providers who would then pass the cost on to consumers and create a whole unneeded bureaucracy, it makes much more sense for to raise the tax on gasoline throughout the region. Selling permits to cap emissions sets the stage for widespread abuse and huge profits to middle men rather than benefit the publi.

The Regional policy should provide an analysis of what level of gas/carbon tax would result in the desired reductions in green-house gases, and couple that with how the revenue would be used to improve public transportation, infrastructure, promote a green economy, and other public good in each state.

In addition, revenue from a carbon tax (at the Regional and federal level) could help support health care costs. The cost to consumers of a gas tax could be much less than the tax due to reduced demand leading to reduced pre-tax gas cost and thus reduced profits to oil producers.

There should be support for efforts at the federal level to markedly increase the gasoline tax and return funds to states to support infrastructure/public transportation/health care. Some of the funds could help transition our country to Medicare for all.

There should be a whole-hearted endorsement of supporting increased fuel efficiency standards including California's proposals, and stand against Trump and Republican efforts to raise the use of fossil fuels.

In 2008 I advocated the following and had my legislator Byron Rushing file a bill the raise the Massachusetts gas tax by 25 cents a gallon. "A tax on gasoline is among the best type of taxes - unless you are an oil producer. The tax is largely offset by reduced oil producer profits, so a $1 a gallon tax might only raise the pump price 25 or 50 cents. If the tax had been adopted last year, it likely would have lowered the pump price. By promoting energy conservation and alternative energy use, the tax helps address global warming and take into account the hidden cost of CO2 emissions. A lower crude oil price will reduce the cost of home heating oil. The tax would improve our national security by reducing our dependence on Middle Eastern oil. The tax would bolster the economy by keeping American dollars in the US, markedly reducing our foreign deficit, and stimulating "green" jobs. The tax could overnight help turn the bear market into one of optimism for the US economy.
With states in financial crisis, states should raise their gasoline tax by 50 cents a gallon. That would raise $1.5 billion a year in Massachusetts, and $2.8 billion a year in New York - which would cover most of the projected drop in revenue. Congress should raise the federal gasoline tax by $1 a gallon. The revenue from an increased gas tax could go a long way towards funding our upcoming national priorities - health care coverage for all, investments in education, and new energy sources."