TCI Regional Policy Design Stakeholder Submissions

EDF respectfully offers the attached comments and recommendations to the Transportation and Climate Initiative in response to the information presented on the September 16 webinar. Thank you for your consideration of these comments.

I took the time to prepare this comment because I don’t want this program to repeat the implementation problems associated with the Acid Rain Program’s emissions monitoring system. I was involved in the EPA reporting from the start of that program and would not wish that experience on anyone. My advice is to keep the requirements as simple as possible and minimize the total level of effort needed to submit and track emissions.

I would be willing to discuss this topic with appropriate staff if there are questions or comments.

Thank you.

Our team is sharing an emission-free technology with France, Germany, Great Britian, Costa Rica and many more countries seeking to reduce the pollution and particle matter in their environment.

Please see the petition below and attached 196 signatures from across the TCI region. These can be added to the previous 298 signatures we submitted in November which had signed onto the same request, for a total of 494 signatures from Green For All supporters.

Dear Transportation & Climate Initiative:

We applaud your efforts to design a regional carbon pricing program for the transportation sector across the Northeast and Mid-Atlantic Region. There is no question, we must take steps to cut pollution from this sector and invest in solutions.

We must simultaneously take specific, measurable, and meaningful steps to ensure the communities hit first and worst by pollution, or who have inadequate access to mobility options, can fully participate and benefit from a clean, modern, reliable, and affordable transportation system. This commitment should be expressed in any regional commitment (such as an MOU), and should not be left to individual states to determine whether or how they will address the needs of our most impacted communities.

Last summer, organizations representing racial, economic, transit, and environmental justice communities delivered a set of 9 principles for policy design to ensure the regional program builds in the guardrails that will ensure protections and guarantees for communities most impacted. Each of these equity principles, especially a clear process for ensuring communities are at the table, must be baked into the regional program, committed to by each state that plans to adopt the program, in order to ensure that some communities don’t get left behind.

I echo and support the voices of those who are directly impacted determining what they need to see as part of the
program design. I urge you to commit to specific steps for each of the 9 principles for policy design in MOU.

Thank you,
(Signatures attached)

Apologies for the late submission. The comments from Consumer Reports are provided at a file attachment. Thank you for the opportunity to comment, and for considering our input.
- Adam Winer, Consumer Reports

Transportation sector hydrocarbon reduction to date has been based on a lack of a mass-produced electric vehicles of the types people need. The lack of vehicles is not because no one wants the vehicles or because the manufacturers do not want to produce them, but because the battery technology is still immature and the supply chains for mass-produced batteries and rare earth permanent magnets is early stage development. The cost-benefit for consumers even with tax incentives is not there because the vehicles are more expensive for less capability. All major manufacturers have announced $300 billion in electric vehicle manufacturing investments over the next few years with large scale production starting in 2021. That said it will take until 2030 for mass production to be fully realized. Consumers and businesses with a new ICE technology vehicle are not going to run out and buy a new electric car until their current ICE vehicle reaches its end of useful service (8-10 years). At that point consumers will have a choice and will make the choice based on the advantages of the future EV's, not because of TCI. TCI does not help us move forward only adds consumer costs. TCI does nothing to solve that and all rigorous studies show that it does not reduce hydrocarbon consumption, does nothing to enhance transportation sector electrification and adds no funding for desperately needed highway repairs.
https://ljfo.vermont.gov/assets/Uploads/a5e545b014/rap-carbon-management-VT-JFO-february-2019-updated.pdf
https://www.nrel.gov/docs/fy18osti/71500.pdf
https://graphics.reuters.com/AUTOS-INVESTMENT-ELECTRIC/010081ZB3HD/index.html
https://www.iea.org/reports/global-ev-outlook-2019
https://www.jpmorgan.com/global/research/electric-vehicles
https://www.eei.org/resourcesandmedia/newsroom/Pages/Press%20Releaseshttps://www.eei.org/resourcesandmedia/newsroom/Pages/Press%20Releases/EEI%20Celebrates%201%20Million%20Electric%20Vehicles%20on%20U-S-%20Roads.aspx
https://www.iso-ne.com/static-assets/documents/2019/12/draft_2020_transpElectr_fx.pdf

see attached document (corrections to previous document)
28FEB20_BTBCoaltion_01a.pdf