TCI Regional Policy Design Stakeholder Submissions

My name is Rick Bologna, I own and operate Westmore Fuel Co., Inc. in Greenwich, CT. We are a multi-generational family owned business that was established 81 years ago.

I currently am the Vice President and have been with Westmore Fuel Co., Inc. for the last 29 years.

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:

• 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.”


A real time solution that can be implemented immediately is the use of a low carbon renewable liquid fuel (LCRLF) such as Biodiesel. Biodiesel is blended today with traditional diesel distillate and is used for transportation and heating across the country. As the technology for this fuel advances, higher and higher blends of Biodiesel will be used and traditional diesel distillate will be phased out. By phasing over to LCRLFs, we can use the current liquid fuel transportation systems in place across the country (pipelines, barges, trucks, retail outlets, etc.). Also, US truck manufacturers already have diesel trucks that run on Biodiesel blends, so there wont be a need to convert trucks and future cars over to a new fuel. In fact, Biodiesel is the only fuel currently that can get us to carbon neutrality in the future, all of the other current forms of energy we have today, including natural gas, cannot do that. For more information on Biodiesel please see: https://www.biodiesel.org/

I ask that TCI take all of these issues into consideration before they decide to move forward.

Thank you.

Rick Bologna

I concur with my friends who oppose any attempt at revenue increases, i.e. taxes, without MA House approval. I will let my legislators know my thoughts on this also. Furthermore, spending some time in California, with their exorbitant gas taxes, and other "penalties" for owning combustible engine vehicles, I see these moves as nothing more than crushing expenses to everyone, which particularly hit lower income more (gasoline tops $4/gallon, a very large increase vis a vis current MA gas taxes.

Tax credits, desirability for EV, and cost reductions as the market finds ways to deliver at lower costs are doing much to reduce vehicle emissions. Though it doesn't matter what taxes or carbon exchange fees you charge, the average worker can not afford an EV yet.

If you want to focus your energies, somewhere, help India, China and other fast growing economies to reduce their carbon emissions. MA is flatulence in the breeze compared to the real global polluters. or you could try the US agriculture/meat industries. And let the MA House focus on taxes.

Thank you,

Chris Grande

Transportation is the largest source of air pollution in the region, and we need to build a modern, clean, safe, and accessible transportation system for the 21st century. The more we limit pollution from motor fuels, the more jobs we create, the more the economy grows, the healthier our air becomes, and the more lives we save. Maryland should join TCI to fund better transportation infrastructure, reduce traffic, and make my community a cleaner, safer place to live.
It is clear that air pollution from cars, trucks, and buses have become a huge detriment to my community’s health. Air pollution has been linked to a variety of health problems, including asthma, heart disease, and lung cancer, and the more ambitious TCI is, the more our community stands to benefit from a cleaner transportation system. I urge Governor Hogan to join TCI and push it to be as ambitious as possible, for the sake of my community’s health and livelihood.
As a person living in a rural area, I think that TCI is extremely important. When states join TCI, they have the opportunity to invest in rural communities where transportation options are limited. Joining TCI would allow Maryland to ensure that rural communities aren’t left behind in the green transition and stuck behind the wheel of costly, inefficient vehicles. Governor Hogan should push for an ambitious TCI program so that rural communities like mine get the solutions they need.

I am newly settled in Massachusetts and both my husband and I support creative, robust activism on behalf of the climate. To that end, we will not hesitate to "put our money where our mouth is." If the cost of preserving this amazing planet is a few more pennies out of our paychecks, then I will be the first to volunteer those funds. Although I have come to realize that making changes to protect the climate cannot rest solely on government as a mechanism (and must rest more squarely on my own shoulders) I nonetheless, support all initiatives whose goal is to preserve and protect our natural world. We only have one place to call home and I want to see us all become better stewards of this incredible planet - For my children, for your children and their children. There will be no absolution for our generation if we get it wrong. We must act now.

The Transportation and Climate Initiative (TCI) should design a program that will reduce carbon emissions from the transportation sector.

It should include:
- A minimum of 35% of investments from the program will go to underserved and overburdened communities
- The creation of state advisory boards and community outreach
- An annual review of the program to ensure transparency
- Complementary policies determined by each state

I am writing with deep concern about the proposal put forward by the Transportation Climate Initiative.

The proposal outlines a program that will cap the sale of gasoline, tax it, and then require the revenue generated to be spent on new government programs and projects that will further reduce the sale of gasoline. Rather than use the existing motor fuel tax structure in the states, the tax has been intentionally proposed at a point of “prime suppliers” so that it will be hidden from consumers. I believe that the TCI planners feel that it must be done this way because if the general public knew the costs of this plan they would soundly reject this and other proposals like it. If the energy provided by petroleum to move people and goods in the economy is removed by reduced gasoline consumption, it either must be replaced by more expensive and less efficient forms of energy or the movement of people and goods must be reduced. Either scenario will have devastating effects on the economy in the northeast and will continue to push people and businesses away from these states.

Although this proposal has been pitched as a consensus document, in fact, it is not. There have been only three work sessions and less than a handful of webinars to solicit public feedback and comment. The framework is not ready for adoption by the states as too many points have not been clarified and fleshed out. No one really knows the full detail of the proposal. More outreach and public input needs to happen to shift this to a consensus. At the present, the framework appears to be a predisposed outcome. The general public in the member states has little or no knowledge of this plan to massively increase the cost of their transportation fuels.

I reject this framework – and I urge that the participating Governors be required personally to attend and hold public hearings throughout their states. This proposal will not achieve its goals. California enacted a similar program recently, and, by most accounts, their gasoline costs have skyrocketed while the environmental impact has had no true measurable benefit.

Thankfully, Governor Baker has shown leadership in bringing officials from many states together to work together to improve regional transportation. I now urge him and the Mass. House and Senate to formally join this effort and push for the strongest policies and regulations
recommended by climate scientists and transportation experts.

Greenhouse gas and particulate pollution from automobiles are major contributors to global warming and respiratory disorders. We must immediately begin to drastically reduce these pollutants and, in the process, make affordable public transportation available to underserved people who must drive to work and other necessary activities.

We must forge ahead at full speed if we have any hope of staving off climate disaster. The TCI proposal won't fix everything, but it's a darn good start. Let's do it. Now.