TCI Regional Policy Design Stakeholder Submissions

VPCMA Comments in Opposition to TCI Framework for a Draft Regional Policy Proposal

Have become sick & tired of hearing carefully reasoned, public interventions to address market failures WRT unpriced externalities (think: TCI, Essex Plan) framed as nothing more than taxes. Both of these proposals included side payments to the vulnerable to soften their landing in a bumpy future. Is no one able to think and talk in terms of net outcomes? You're better than that.

Try to think analogously about this. You acted on gun control legislation because , God forbid, a mass shooting should happen on your watch. The next Irene IS out there, you and I just don't know when and how bad. Trust me, you want to be on record as having excercised some vision and initiative on this one.

I think this climate change initiative is an important first step, and urge Governor Scott to make Vermont a participating state.

Warner Shedd

I support the TCI proposal. Carbon-based fuels are accelerating the climate crisis and their use must be curtailed. Increasing the costs of fossil fuels will help reduce their use and is an appropriate method of raising money for investments in better transportation. Since Vermont is a mostly-rural state our primary need is to replace gasoline and diesel vehicles with electric vehicles. Our distribution of houses and patterns of travel are not easily handled by mass transit except in a few regions. Incentives for individuals and companies to switch from fossil fuel cars to electric cars, more investments in charging stations and more investments in electric school and commuter buses are all needed. Commuter rail should be considered as an option on existing tracks. More bicycle paths should be created as a transportation option and also for recreation by both residents and our economically important visitors.

Governor Scott- It is critical that Vermont join the TCI. It is a good deal for Vermont economically, and a key step in reducing Vermont's transportation CO2 emissions, which have been rising despite our green image and good efforts. Cap-and-invest programs like TCI are proven to work; lowering CO2 emissions and actually increasing GDP. Please, please, please do the right thing for all of us and Vermont join the TCI.
Sincerely,

Hannah Dreissigacker

Hello,

I'm listening to the 5/23 webinar, and mostly watching the TCI process somewhat from the periphery. Here are my comments and my interest.

Comments:
I support how the analysis of baseline transportation looked at EIA's NEM as well as other sources. My impression is that EIA's predictions have been very poor, missing some big trends, especially longer-term trends, like growth of renewable energy.
Given my interest in heavy-duty fleets (see below), I look forward to hearing more about something other than EVs, and how those non-EV options would be monetized in TCI. Looking at modeling done for Vermont's Comprehensive Energy Plan, climate goals are reached with biofuels, not just electrification. I assume that GHG emissions from heavy-duty and medium-duty fleets are non-trivial in the Northeast, and electrification in these fleets seems immature compared to passenger EVs and light-duty EVs. What can you do to model this the medium-duty and heavy-duty sector?? E.g. what are the recent history and trends for natural gas and RNG, in usage and in which types of vehicles? I assume DOE's AFDC has the data.

My Interest:
Being in the agricultural sector, and with Vermont's biogas potential from dairy manure, I am intent on getting RNG produced and used as a way to support farms and offset GHG emissions. The Agency of Agriculture and others will analyze the statewide potential, using existing digesters, which process only 10% of Vermont's dairy manure, and new digesters. Back of the envelope, I estimate 500-1000 Class 8 trucks could be operated on RNG from Vermont's dairy manure.
Please remember that the global warming potential of methane is ~25x of CO2 in the 100-year time frame, but it is ~85x CO2 in the 25-year timeframe. Used in transportation, RNG from dairy manure is strongly carbon-negative: -276 gCO2e per MJ. Electricity is 20-40 gCO2e/MJ (see slides 7-9 of the attached presentation).

I'm glad to discuss as necessary.

I appreciate the opportunity, thank you.

Alex

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)

Cutting gasoline will become a matter of life or death. We will keep using it as long as it's cheap and convenient. That's human nature. We MUST make it more expensive, so people will choose ways to NOT use it. This is life or death for our children's children. Implement this or a simpler carbon tax, and use the revenue progressively to help those hurt most by it, by returning the money straight back to them. Do not use the money for pet climate projects. Because the most effective and fairest measures are chosen by each of us individually.

Vermont, having one of the lowest carbon footprint in the United States, does not need to participate in this program in anyway. This will only increase the cost of living for Vermonters. We can no longer afford any more increased taxation in any method. This will only seriously increase the cost of living and negatively impact low and moderate income Vermonters. We cannot afford this. And there is no need. I respectfully request that Vermont not participate in this initiative whatsoever!