TCI Regional Policy Design Stakeholder Submissions

Please see attached from CT Green Bank, Climate Neutral Business Network, and U-GO Stations, Inc.

We know that in order to make our contribution to mitigating climate change, we need to start reducing our dependence on gasoline and diesel powered vehicles. This is not something that can occur overnight. TCI will allow participating states to take a tax from sales of fossil fuels and use that to invest in alternatives that are greener - rail, buses, and bike/pedestrian infrastructure. These investments will benefit us in other ways as well - improving bus transit, especially around our cities, will provide more options for working class people without cars, as well as for middle class people who might choose to leave their car home, but currently lack viable options. A shift away from private cars will relieve congestion in our towns. Building bike/ped infrastructure will make our streets safer for all.

We write from the Collaborative Center for Justice, which is a faith-based advocacy organization based in Hartford, CT. We are sponsored by six congregations of Women Religious around the state. Environmental justice has been one of our priority areas for our education and advocacy work over the years.

We support the development of a strong multi-state Transportation and Climate Initiative and we urge Governor Lamont to fully support participating in this critical initiative. Transportation is the largest source of greenhouse gas emissions, and emissions will continue to grow if timely action is not taken to transform our transportation system. This initiative is a critically important opportunity to make changes that will lead to an increase in clean transportation and reduced greenhouse gas emissions.

We urge leaders to include provisions to prioritize investments in frontline communities that have already disproportionately borne the burdens of environmental injustices. Low-income communities and communities of color already face greater exposure to pollution from vehicle emissions, fossil fuel plants and incinerators in and near their communities. These communities need to be prioritized in the transition to clean energy. We also call upon the leaders of this initiative to meaningfully include voices from directly impacted communities in each step of the development and implementation processes.

We urge you to ensure the inclusion of the following components when developing the final program: commitment to utilizing investments to improve and expand public transportation in the state; increasing and improving bike lanes and sidewalks; and investing in expanded rail service across the state and region. This is an opportunity to make it safer, more affordable, and more possible for people to take public transportation to school and work from where they live. Increasing the frequency of buses and trains and expanding their routes are two important components to make these changes possible. It is also important to increase the availability of bike lanes so that people can safely commute from a public transit stop to another location by bike. Investment in fixing potholes, particularly on busy city streets, is also an important component of improving biker safety.

Residents who already commute to school and work by public transportation face challenges with our current system too. Many bus routes do not have frequent enough schedules to meet the needs of the residents who depend on them. In many cases, taking a bus to school or work is very time consuming because routes and connection points are limited. Bus routes need to be expanded in cities and to neighboring suburbs in order to better address this problem.

We also recommend that investments be used to transition school and public buses to electric buses. Increasing the number and expanding the locations of charging stations around the state would support the transition to electric buses and cars. Transitioning to electric buses will have important public health benefits for the children and adults who ride the buses, as well as for the wider community.

As people of faith, we concerned about the health and wellbeing of all people and our planet. We are particularly concerned about the impacts of environmental injustices on low-income communities and communities of color. We believe that there is an urgency to our actions to implement climate change mitigation and adaptation strategies. As a state and region, we have a collective responsibility to make changes to our transportation sector that will address and end these injustices, and move our society toward cleaner and more equitable transportation options in the most immediate way possible. We look forward to Governor Lamont’s leadership and commitment to this critically important initiative.


Respectfully submitted,

Dwayne David Paul – Director
Rachel Lea Scott, MSW – Associate Director

I strongly support the Transportation and Climate Initiative TCI) because we have an urgent need to reduce our greenhouse gas (GHG) emissions in order to slow the devastating impacts of climate change. Connecticut and other states have set goals and made some progress, but we cannot meet this challenge by working separately. The success of the Regional Greenhouse Gas Initiative (RGGI) shows the power of regional cooperation.

Transportation is now the largest source of GHG in Connecticut, accounting for 43% of GHG emissions, most of this coming from non-diesel light vehicles, in other words, our cars! Each year, American passenger cars and trucks, through vehicle tailpipe and oil extraction and transport emissions, spew upwards of three trillion tons of carbon pollution into the air by burning about 121 billion gallons of gasoline. In Connecticut, GHG emissions have risen since 2012, mostly in the transportation sector, likely due to lower gas prices, increased driving and increased popularity of inefficient vehicles (e.g., SUVs). TCI would support a switch to plug-in electric vehicles (EVs), which require no gasoline and emit no tailpipe pollution, presents a critical opportunity to slash pollution, create American jobs, reduce oil dependence, and benefit our state and regional economies.

Sales of electric cars are growing every year, but we need more EV-friendly policies to encourage a faster transition to an electrified transportation system. I own a fully electric vehicle and can attest to the benefits and savings, however we needed to add a level 2 charger to our garage to make charging faster and convenient. Many people, apartment dwellers and renters, cannot make these kinds of modifications to their residence. Of course, initial expense is also a barrier to adopting EVs for residents, municipalities and businesses. We must act now to remove barriers and make electric vehicles less expensive and more convenient. Connecticut should ensure long term funding for our successful EV incentive program, expand EV charging infrastructure, and encourage electrification of public transportation, school bus fleets, trucks and ships.

TCI will help us achieve our clean transportation goals by working cooperatively and will create a large regional market resulting in cost savings. We can achieve success by working regionally through the TCI to set goals and implement a cap on CO2 emissions from transportation, and fund clean transportation efforts by limiting, pricing, and reducing carbon pollution from transportation fuels.

February 28, 2020

The Connecticut Energy Marketers Association’s (CEMA) motor fuels members own, operate and distribute gasoline to approximately 1,000 convenience stores in the state. Our members own property in virtually every municipality, pay local and state taxes, employ thousands of people, and play a vital role in Connecticut’s economy.

While electric vehicles (EV’s) may be an attractive way to lower emissions, it appears that more consideration needs to be given to several factors that will have an impact on jobs, the economy, property values, electric reliability, emissions and family owned businesses. But, it is essential that TCI does not pick winners and losers by allowing regulated utilities to unfairly use their monopolistic status to overpower private businesses that depend on free market forces to support economically viable alternatives to electricity. Allowing massive (and in some cases foreign owned) utilities to do this would be unfair, it would destroy competition, and drive local family owned companies out of business taking with them thousands of jobs.

Allowing monopolies with a guaranteed rate of return to control EV charging would not only discourage private companies from investing in future alternative fuels, but it would also have a detrimental effect on their ability to maintain the current infrastructure that motorists depend on.

Over the past decade, federal policies such as the Renewable Fuel Standard (RFS), the Biodiesel Blenders Tax Credit, and others, have created incentives for fuel retailers to invest in infrastructure necessary to bring cleaner burning fuels to the market. Our members support policies that encourage a vibrant and competitive market that will deliver the most efficient prices to the public, but if electric utilities are allowed to exercise TCI and government granted power in the motor fueling space, private businesses will not be able to compete.

TCI needs to examine a regulatory landscape which encourages fuel retailers to invest in alternative fuels before generations of investment in thousands of locations throughout the state are irreparably harmed. We have one chance to get this right, or a major segment of the economy will be decimated.

While utilities need to play a role as EV’s enter the market, they should be focused on grid enhancements, distribution upgrades (ie. line extensions), cyber security and other issues to ensure that the “lights stay on” as demand for electricity grows - these are fundamental to the reason that they have been granted monopoly status. TCI should seek and support pathways that leverage the current fueling


network that has been privately developed to bring alternative fuels to consumers - not tip the scale in favor of electricity.

TCI also needs to be cognizant of the impact that the “electrify everything” policy that the state is pursuing will have on grid reliability, the cost electricity, and emissions.
Attached is a spreadsheet the looks at the need to add electricity supply if EV’s replace gasoline and diesel fuel for transportation purposes and the replacement of heating oil and natural gas for heating. In Connecticut, Governor Lamont’s Executive Order number three seeks to achieve zero emissions in the electric sector by 2040, coupled with the need for additional electricity capacity to meet the demand that EV’s and electric heat pumps will add to the grid is going to place immense pressure on the need for renewable energy generation.

To do that we need to look at what it would take for wind and solar to meet this goal. It is a fact that solar and wind electric power farms are much more land intensive than oil, gas, or nuclear power plants. For example: “Wind farms require up to 360 times as much land area to produce the same amount of electricity as a nuclear energy facility, a Nuclear Energy Institute analysis has found. Solar photovoltaic (PV) facilities require up to 75 times the land area.” https://www.nei.org/news/2015/land-needs-for-wind-solar-dwarf-nuclear-plants. It’s simply the nature of the science and engineering behind wind and solar plants that they are land intensive.

Given TCI goals and that the state of Connecticut wants to move entirely to renewable power plants, specifically wind and solar, for electricity generation, it’s reasonable to ask how much land such plants would consume.

SOLAR
Let’s look at solar first. Connecticut has a large solar farm currently in Somers, CT. https://en.wikipedia.org/wiki/Somers_Solar_Center It has a capacity of 5 MW of electricity, and covers 50 acres of land. According to ISO-New England, Connecticut power plants have a nameplate capacity of 8,700 MW https://iso-ne.com › grid_mkts › key_facts › final_ct_profile_2013_14

Doing the math, Connecticut would require some 1,740 solar farms the size of the one in Somers to replace all existing electric power capacity in the state, and doing another calculation, this would require some 87,000 of land use. This land area is equivalent to the total sum of all the land taken up by the cities of Hartford (11,490 acres), Bridgeport (12,400 acres), New Haven (12,870 acres), Waterbury (18,530 acres), New Britain (8,576 acres), New London (6,886 acres) and Meriden (15,440 acres).




WIND
Wind power plants come in two forms, onshore and offshore.

- Onshore
For our onshore example, we look at the Sheperds Flat wind farm in Oregon, the world’s fifth largest onshore wind farm. https://www.power-technology.com/projects/shepherds-flat-wind-farm-oregon/
This wind farm has a capacity of 845 MW and covers some 80 square kilometers. We calculate that 10.3 such wind farms would be needed to replace CT’s 8,700 nameplate capacity, and these would span some 823.7 square kilometers. As Connecticut consists of 14,360 km in area, more than twice the area of the solar plant described above.


- Offshore
Since solar and onshore wind power plants take up so much land space, perhaps an offshore wind plant in Long Island Sound would be preferable. After all, there are no homes or businesses to disrupt out in the Sound.

The world’s largest offshore wind power plant is the Walney Extension wind farm off the coast of England. https://www.power-technology.com/features/largest-offshore-windfarm-world/ Unfortunately, as we shall see, the news isn’t good. The British wind farm has a capacity of 659 MW and is spread over 145 sq. kilometers in the North Sea. To replace CT’s 8,700 nameplate capacity, we’d need some 13.2 Walney-sized windfarms which would cover an expanse of 1,914 sq km of Long Island Sound. But the Sound only covers 3,056 sq km. In other words, this huge wind farm would choke off Long Island Sound, covering 62.6% of its entire surface area. This would mean a wind farm covering every square meter of Long Island Sound from the New York border to Rhode Island, and penetrating from a few miles into the sound at its narrowest point, to over 100 miles at its widest point.

Connecticut and TCI should be cautious before committing to entirely replacing Connecticut’s current power capacity with wind and solar power plants to accommodate EV’s. There are physical constraints to making such wholesale conversion possible. In the meantime, Connecticut can transition to a net-carbon zero energy source in the heating sector, elevating the need to put any additional burden on the existing electric power grid, through the use of biodiesel. Why further burden the grid by adding electric heat pumps, when electrons can be saved with liquid fuels that can deliver on emissions reductions that help the state comply with the greenhouse gas reductions required under the Global Warming Solutions Act? Since biodiesel and renewable diesel can be used as a transportation fuel (along with other low carbon fuels), the state can significantly reduce demand on the grid and significantly lowering emissions by utilizing the potential of local businesses to sell low/net zero liquid fuel to the public.


We know that Connecticut is concerned about increasing what are already the highest electricity rates in America, and as business owners we are troubled about the impact that potentially billions of dollars in ratepayer investment that will be needed to upgrade the grid to accommodate TCI goals, subsidizing new clean electric generation sources to accommodate those goals, the subsidization of EV infrastructure, and EV incentives will have on rates. We believe that TCI should put as much effort into finding low carbon/zero carbon liquid fuels, that utilize existing infrastructure that has been privately developed, as they are into electrification of the transportation sector.

Before Connecticut has even adopted any of the costly suggestions that have been made by EV industry advocates, Eversource customers will pay 15.8% more for electricity in 2020 and United Illuminating (UI) customers will realize 26.4% increase (which equates to average customer using 750 kilowatt hours a month paying $9.65 and $16.55 more per month with Eversource and UI respectively)! Connecticut needs to factor costs in and “right size” their electrification plans before fixed income and low-income families are disproportionally affected by the proliferation of EV’s and the infrastructure that comes with TCI’s plans. TCI needs to address the question of who benefits from all the costs that go into creating an EV future for Connecticut and the region, and needs to avoid the mistakes that have advantaged the wealthy over low and middle income families.

Of the 57,066 households that received the federal EV tax credit in 2016, 78% had at least a six-figure income and 7% reported more than $1 million in income, while less than 1% of all EV credits went to households earning less than $50,000 in 2014, meaning that about half of Americans receive virtually no benefit from the credit. EV manufactures data shows that EV’s are overwhelmingly benefit the wealthy. Tesla’s customers have an average household income of $293,200 while even the buyers of the more modestly-priced electric Ford Focus have an average income of $199,000. On top of the EV tax credit, electric cars owners don’t pay gas taxes to help support the roads they use, shifting more of the burden onto other drivers, contributing to a funding deficit that support our roads and bridges. PURA should not create incentives to purchase EV that will only benefit citizens who would be able to afford them without it.

TCI also, has to ask the question are we trading one type of pollution for another? Much of the literature noted that EV’s emit less CO2 than traditional internal combustion powered engines (ICE). However, the makeup of the electric grid plays a role in the release of other gaseous pollutants and particulates. According to Weeberb J.Requia’s “How Clean Are Electric Vehicles? Evidence-based Review of the Effects of Electric Mobility on Air Pollutants, Greenhouse Gas Emissions and Human Health”, in China, even with an electric grid largely powered by coal, EV’s decrease CO2 emissions by 20% compared to ICE’s. However, in the same study, emissions of PM10, PM2.5, NOx, and SO2 emissions increased 360%, 250%, 120% and 370%, respectively.

The environmental impact of EV batteries cannot be ignored and needs to be a part of PURA plan. Li-ion battery production primarily occurs in China and South Korea, whose electricity mix is generally carbon-


intensive. Han Hao’s “GHG Emissions from the Production of Lithium-Ion Batteries for Electric Vehicles in China.” (April 4, 2017) showed that the GHG emissions were nearly 30% higher than those for comparable ICE’s. EV battery materials impact the environment in different ways. Batteries that use large amounts of aluminum LiMnO2 and LiFePO4, for instance, have a greater impact on ozone depletion. At the end of the day, TCI needs to factor in the environmental impact of EV batteries and their disposal. A lifecycle analysis of EV and the infrastructure needed to support them needs to be done comparing them to low emissions liquid fuels before ratepayers are burdened with more costs and environmental issues.

Finally, the current electric grid is not clean and adding EV’s (and electric heat pumps) to it will only exacerbate the need for natural gas to ensure that we have enough power to support current demand and the additional demand that EV’s will create. According to Gale Ridge, PhD, a scientist and researcher, “In a one month period, we found about 700 [natural gas] 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.” Current overreliance on natural gas is clearly causing greater methane and CO2 emissions and a massive expansion of EV’s in Connecticut will only drive more emissions for a grid that depends on natural gas to power the state. PURA should not move forward with any plan to electrify the transportation sector until they can verify that the electricity that is being use to power EV is truly emissions free.

We urge TCI to address all of these issues before a final plan is proposed to Connecticut.

Respectfully,


Christian A. Herb
President

Please see the attached program design input, resubmitted from 2/27 with updated signatories.

I've spent over 50 yrs in the Environmental Safety & Health services and back in 1968 the leading causes of air pollution were fossil fueled electrical generating plants, cars & trucks, and home/commercial heating. Nothing's changed, I'm sorry to say. At least we can do is knock the 1st and 2nd ones off the list by switching fuels and developing better transportation. Please support all means to help the climate and the air we breathe by supporting the Transportation and Climate Initiative.

As a young person, I know that the climate crisis threatens my future. Adjustment to climate change is no longer a choice, it's a necessity , and we must act immediately to avoid further damage to our planet. TCI will not only curb emissions from the companies most responsible, but the revenue received from the investment portion of the cap-and-invest plan will go into making clean public transportation a more attractive option than driving. Hopefully Connecticut and the rest of the TCI states will become an example of environmentally conscious policy done right.