TCI Regional Policy Design Stakeholder Submissions

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.

NO MORE TAXES!! NO TAXES DISGUISED AS SOME SORT OF FEEL-GOOD INITIATIVE! WE VOTED THE GAS TAX OUT, STOP TRYING TO BRING IT BACK!

The goal of reducing the carbon footprint of transportation is increasingly evident as we try to meet or exceed the Paris agreement. Despite the Trump Administration's refusal to participate in the Paris goals, it is abundantly clear the the scientists are correct and that CO2 and methane are potent greenhouse gases that are warming the planet and causing enormous climate disasters across the globe.

We are very much as risk of excess flooding that threaten vital infrastructure. Our sea level rise can increase the risk of flooding at Philadelphia International Airport, the water treatment plant for Philadelphia and flooding in parts of South Philadelphia and the river wards near Fishtown. Salt water can encroach on the intake valve of the Delaware River jeopardizing the water supply of the city. And that is just Philadelphia. Other East Coast cities are in even more precarious postiions. Heat levels that are dangerous for workers and the vulnerable, elderly unable to escape their homes for air conditioning. I could go on and on.

That is the end result of too much carbon in our atmosphere. We strongly support the TCI effort and we believe the money should be used to transform electrifying automobiles, creating charging stations widely, solar panel garages at workplaces and public spaces, and allowing EVs to be plugged into the electric grid at night which can then act as both a charger, but also a source of electricity at night when the sun and wind are not present. More incentives need to be considered moving toward heat pumps and induction stoves as how we heat our homes and cook our food.

In short we need to stop burning fossil fuels and dramatically fund the electrification of everything.

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

Warner Shedd

I haven't had time to check out everyone's comments, but I have a suggestion for our states. We should have some now and many in the future electric car and truck charging stations at every state service center along the highways. If they are in front of the restaurant (etc.) buildings, maybe covered by EV paneled roofs, they would have at least five benefits:
• help those of us who live in the state to travel with electric cars and trucks,
• encourage people with plug in cars to travel to our states,
• encourage others who see the charging stations to consider electric vehicles,
• of course help offset some of the intense pollution caused by fossil fuel vehicles,
• and encourage people to stop and have a rest or meal for a half hour or more as their vehicle charges.
All of these reasons would help all of us directly and indirectly.

Climate change is a man made situation caused by increased CO2 in the earth's atmosphere and reducing consumption of fossil fuels plays an integral part of the solution. Having a good public transportation system can reduce carbon emissions.

As a physician, I am fully in support of this initiative to reduce greenhouse emissions & invest in public & private transportation that does not emit carbon. The infrastructure to support this can be funded through a cap and invest program. The benefits of “clean” transportation will decrease expenditures in health costs. Recent research reveals a correlation between hospitalizations and deaths attributable to local levels of air pollution. The benefits of this initiative are well beyond just greenhouse emissions.