TCI Regional Policy Design Stakeholder Submissions

Washington Gas, which has about 765 vehicles in its fleet, supports the growth and development of − and transition to − low-carbon transportation fuels, including geologic and renewable natural gas (RNG).

There are several factors that motivate the company’s support. For one, medium and heavy-duty vehicles contribute a disproportionate amount of pollution in urban areas throughout the country, and in many cases are the most significant contributors to ozone pollution and smog. (footnote 1) This is not because cleaner technology does not exist, but rather because cleaner technology is not being deployed in effective numbers.

Converting medium and heavy-duty vehicles to natural gas can bend the emissions curve immediately, providing a ready-now, proven and highly cost-effective solution for a low-carbon transportation future. Compared to diesel, for example, natural gas engines fueled with geologic natural gas reduce CO2 and GHG emissions by at least 12%. (footnote 2)

When fueled by RNG, CO2 and GHG emissions can be reduced by up to 331%. (footnote 2)

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 medium and heavy-duty vehicles.

Washington Gas knows firsthand the value of NGV in its ongoing commitment to implementing sustainable business practices in how it manages its own operations, and that includes adopting NGV for its fleet.

In fact, in 2011, four years prior to the Paris Agreement, Washington Gas set 2020 targets for GHG reductions for its fleet and facilities, and to lower the carbon intensity of the gas it delivers. The company exceeded those goals in 2016. Washington Gas then announced new, updated targets for 2025, including carbon neutrality for its fleet and facilities by 2025.

Currently, the company has 289 NGVs, which equates to 38% of its current fleet. By adding dedicated Compressed Natural Gas (CNG) and bi-fuel CNG vehicles to the fleet, and by taking active measures to manage fleet emissions, Washington Gas has significantly reduced the annual per vehicle emissions intensity for its fleet.

Washington Gas also monitors liquid fuel usage in bi-fuel vehicles to ensure drivers are utilizing CNG as their primary fuel source, and it monitors the liquid fuel gallons that are displaced by CNG usage each year. The company has seen an increase in this displacement as its CNG fleet has grown and CNG fuel usage awareness has gained traction throughout the company.

1 https://www.ngvamerica.org/environment.
2 Dependent upon RNG source. Reductions of 45% up to 331% compared to diesel; values based on CARB LCFS program data under CA-GREET 3.0.

I thank Gov. Baker for steering this project and I fully support MA joining the TCI program. Reducing pollution from motor vehicles will strongly help reduce CO2 pollution in the region, which I intensely hope for. I hope that the TCI leaders will go for the most aggressive greenhouse gas goals that will help us reach the target that current climate science tells us we need.. I ask that TCI in MA give priority to areas in which people don't have access to transportation choices and areas most highly burdened by pollution.

We need to create a new mode of transportation, one that is as low as possible in carbon emissions. Some examples are electric cars, electric trains and buses, bicycles, and even scooters. In order to do this, we will have to enact regulations and laws, provide incentives through rebates, taxes, grants, etc., and develop new infrastructures, such as charging stations, bike/scooter paths, and rails/stations. If we fail to do this, our planet is destined to become much more difficult to live in and we will be spending far more money just to survive than we would have had we developed new modes of transportation.

“…design a regional low-carbon transportation policy proposal that would cap and reduce carbon emissions from the combustion of transportation fuels through a cap-and-invest program or other pricing mechanism… [and]… to complete the policy development process within one year, after which each jurisdiction will decide whether to adopt and implement the policy.”, stop burning coal! youd be better of burning trash! we want solar and wind! electric cars must be made affordable!

I would very much like to see Maine participate in transportation solutions to cut carbon emissions and reduce climate impact.

Governor Charlie Baker
Office of the Governor
24 Beacon Street Room 280
Boston, MA 02133


Dear Governor Baker:

The Massachusetts Campaign for a Clean Energy Future is a coalition of environmental, public health, labor, and civic organizations working to establish equitable carbon pricing policy for Massachusetts.

We support the potential of a well-structured regional Transportation Climate Initiative and want to ensure that the Commonwealth develops carbon reduction plans that are both effective and centered around equitable protections and investments. To that end, the organizations listed below, all of whom are members of Massachusetts Campaign for a Clean Energy Future, support the statement of principles developed and submitted by the Massachusetts TCI Table.

Please note that the nine organizations that are signatories to this letter represent thousands of engaged Massachusetts residents from Cape Cod to Western Massachusetts.
Environmental Ambition
We commend Governor Baker and members of the Baker-Polito administration for their regional leadership on TCI. As the participating jurisdictions work to develop a final Memorandum of Understanding (MOU), we encourage Massachusetts to provide continued leadership by encouraging other states to commit to TCI, to invest proceeds in clean transportation efforts, and to minimize negative impacts to low-income drivers while maximizing benefits to communities that lack affordable, reliable, and safe transportation.
The MA TCI Table asks the Baker-Polito administration to ensure that the TCI jurisdictions establish an emissions cap that aligns with Governor Baker’s recently announced commitment to net-zero emissions by 2050 and the Massachusetts Senate’s proposed requirement of a 50 percent emissions reduction by 2030.
Of the three cap levels analyzed by the TCI jurisdictions, the cap that most closely approaches that level of ambition is the cap that declines by 25 percent from 2022 to 2032; that cap level also delivers the greatest health, economic, and job-creation benefits. For those reasons, the undersigned support an emissions cap that declines by at least 25 percent from 2022 to 2032. We also recommend that the Administration conduct modeling of deeper reductions. The cap and other program design elements should be reviewed after the program’s first three years and every three years thereafter to ensure that the program is working as intended to reduce CO2 emissions and other harmful co-pollutants and is improved over time.
Investment of TCI Proceeds
We appreciate the need for each TCI jurisdiction to independently determine how to invest TCI proceeds to best meet the unique needs of their residents, workers, and businesses. However, we also believe that the draft MOU should include principles to ensure that investments deliver pollution reduction, improved air quality, increased sustainable transportation options in an equitable manner. This should include attention to good jobs standards.
The investment of TCI proceeds in Massachusetts should provide greater access to affordable, low-carbon transportation options throughout all geographic regions of the Commonwealth. Investments that benefit environmental justice communities, low-income populations, rural families, low-wage workers, and other populations that have been historically burdened by transportation pollution are necessary. The Commonwealth should prioritize these communities as they have faced disproportionate burdens from transportation pollution and unequal access to mobility options. TCI proceeds must minimize and mitigate cost impacts to low-income households and maximize expanded clean transportation benefits for low-income communities and other transit-dependent populations.
The Commonwealth’s share of proceeds from TCI allowance auctions should be managed transparently, with input from a stakeholder advisory council. Massachusetts should work directly with communities across the Commonwealth to identify investments that will deliver CO2 reductions, improved air quality, resilient infrastructure, and improved sustainable transportation options. TCI-funded investments should be highly visible through clear reporting of investments and investment impacts.
Complementary Policies
In addition to a cap-and-invest framework, complementary policies are needed to achieve the Commonwealth’s climate mandates, economic development, and public health goals. These should include policies such as reduced public transit fares, road pricing, zoning reform, public-private partnerships, improved governance and coordination of the MBTA, RTAs, human service transit, and other state and local agencies. Further, the undersigned agree with the Commission on the Future of Transportation that we need to phase out the sale of internal combustion engine vehicles by or before 2040, and that all MBTA and RTA bus purchases must be electric by 2030.
The following member organizations of the Massachusetts Campaign for a Clean Energy Future look forward to working with you to ensure that Massachusetts participates in an environmentally ambitious and equitable TCI.
Sincerely,
Acadia Center
Cape and Islands Self-Reliance
Clean Water Action
Climate Action Now Western Massachusetts
Elder Climate Action Massachusetts
Greater Boston Interfaith Organization Climate Justice Task Force
Healthlink
League of Women Voters-Massachusetts
Salem Alliance for the Environment

A D behind anyone's name equals DISQUALIFIED because of idiotic policies like deliberately making energy costs higher. Leave me alone. I can spend the money I earn more efficiently than the State can. The State is wasteful and abusive of liberty. No more taxes. Taxed Enough (Too much) Already.

I will not be purchasing an electric car ever— impractical for someone traveling across the country — in Maine to raise gas tax and then not have electric car owners not pay similar tax for our damaged roads is plain stupid

As an environmental biologist, I support the Transportation and Climate Initiative. Actions need to be taken to lower carbon emissions to establish a healthy environment. This initiative can potentially reduce emissions significantly and contribute to reducing air pollution.