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2/24/2020 |
Eleanor |
Fort |
Green for All |
Boston |
Massachusetts |
Attached is a slide deck to accompany Green For All's "Designing an Equitable Cap-and-Invest Policy for Transportation" toolkit. read more Attached is a slide deck to accompany Green For All's "Designing an Equitable Cap-and-Invest Policy for Transportation" toolkit. |
GFA TCI Toolkit slide deck.pdf |
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2/24/2020 |
Eleanor |
Fort |
Green for All |
Boston |
Massachusetts |
Attached is a slide deck that provides case studies of three cap-and-invest policies that have included equitable guardrails and guarantees, in California, Oregon, and New York, to serve as models... read more Attached is a slide deck that provides case studies of three cap-and-invest policies that have included equitable guardrails and guarantees, in California, Oregon, and New York, to serve as models for equity provisions in a TCI Model Rule. |
Case Studies for Carbon Pricing Equity & Investments (3).pdf |
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2/24/2020 |
Sherrie |
Merrow |
NGVAmerica |
Washington |
District of Columbia |
Please see uploaded NGVAmerica comment letter.
Thank you,
Sherrie Merrow
Director, NGVAmerica State Affairs Please see uploaded NGVAmerica comment letter.
Thank you,
Sherrie Merrow
Director, NGVAmerica State Affairs |
NGVA Comments on TCI MOU - Feb 24 2020.pdf |
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2/24/2020 |
Susan |
Smiley |
Householder |
NEW HAVEN |
Vermont |
I SUPPORT VERMONT'S JOINING THE TRANSPORTATION AND CLIMATE INITIATIVE. WE MUST NOT MISS THIS COLLECTIVE OPPORTUNITY TO RAISE REVENUES FOR CLIMATE ACTION IN OUR STATE. REFUSING TO JOIN AND... read more I SUPPORT VERMONT'S JOINING THE TRANSPORTATION AND CLIMATE INITIATIVE. WE MUST NOT MISS THIS COLLECTIVE OPPORTUNITY TO RAISE REVENUES FOR CLIMATE ACTION IN OUR STATE. REFUSING TO JOIN AND EXPERIENCING THE COSTS AND NO BENEFITS WOULD BE A TRAVESTY |
ACORN CandidatesForum.doc |
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2/24/2020 |
Ashley |
Duckman |
Maryland Chamber of Commerce |
Annapolis |
Maryland |
POLICY STATEMENT
Transportation & Climate Initiative (TCI)
The Transportation & Climate Initiative (TCI) is a regional collaboration of 12 states in the Northeast and Mid-... read more POLICY STATEMENT
Transportation & Climate Initiative (TCI)
The Transportation & Climate Initiative (TCI) is a regional collaboration of 12 states in the Northeast and Mid-Atlantic regions that’s intended purpose is to reduce carbon dioxide emissions from the transportation sector. Specifically, the goal of TCI is to create a “regional, low-carbon transportation policy proposal that would cap and reduce carbon emissions from the combustion of transportation fuels.” Maryland announced participation in the coalition in December 2018, and since that time there have been a number of regional stakeholder meetings seeking input on overall regional transportation priorities, potential emissions reductions goals, and policy proposals to meet those targets.
As this process continues to move forward, the Maryland Chamber of Commerce (MDCC) urges that the following principles be taken into account as Maryland and policymakers work toward a regional transportation policy proposal:
1) Transparency. An open and public process is critical to the formation of sound public policy. The MDCC urges that any proposals brought forward to achieve the goals laid out by TCI be subject to rigorous analysis that recognizes both the benefits and costs to the public and the business community. As well, proposals should be subject to a thorough and public vetting process while being considered as potential pathways to meeting TCI’s targets.
2) Market-Based. Market-based solutions have proven to be successful in providing the level of flexibility needed to meet environmental goals cost-effectively. The MDCC believes that any proposal put forward should be market-based, as these types of policies are most cost-effective and spur the innovation necessary to achieve positive outcomes.
3) Dedicated Revenue. Many market-based policies have the potential of generating revenue. The MDCC advocates that any revenue generated from TCI be dedicated to programs and initiatives that contribute to cost-effective energy and environmental solutions rather than returned to the General Fund or used for other purposes.
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TCI POLICY STATEMENT 10 7 19.pdf |
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2/24/2020 |
Christopher |
Pearson |
VT Legislature |
Burlington |
Vermont |
Please see attached comments Please see attached comments |
TCI comments.pdf |
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2/24/2020 |
Bruce |
Ho |
Natural Resources Defense Council |
Annapolis |
Maryland |
In support of TCI jurisdictions' efforts to develop a robust and equitable regional clean transportation policy, please find comments attached from 62 organizations, including members of the... read more In support of TCI jurisdictions' efforts to develop a robust and equitable regional clean transportation policy, please find comments attached from 62 organizations, including members of the Our Transportation Future coalition and additional partners, on the draft TCI Memorandum of Understanding. Our organizations strongly support TCI jurisdictions’ continued work to develop a regional clean transportation policy, which we believe is an important component of achieving a 21st-Century regional transportation system that is cleaner; offers more varied, accessible, and affordable transportation options; and serves the needs of everyone. |
Joint Comments on Draft TCI MOU and Modeling 2-24-20.pdf |
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2/25/2020 |
Richard |
McNutt |
tidewaters gateway partnership |
Pipersville |
Pennsylvania |
Hello, we are seventh grade students from Florence M. Gaudineer Middle School in Springfield New Jersey. We have created a policy to help the issue of unsafe drinking water in New Jersey. Please... read more Hello, we are seventh grade students from Florence M. Gaudineer Middle School in Springfield New Jersey. We have created a policy to help the issue of unsafe drinking water in New Jersey. Please support our policy by signing our petition to help protect everyone in the state of New Jersey from dangerous chemicals in their water. Our policy is (YPSWI) The Yearly Public School Water Inspection. This policy insures that all public schools will have clean water, and a water test would be conducted annually. Some disadvantages are that it would cost a lot of money, and this policy is only regulated for public schools and tax-supported charter schools in the state in New Jersey. The advantages are that it would protect students from harmful chemicals at schools, no matter what the town’s financial stance is. The level of government responsible for carrying out this law is State government. State government is responsible because it is supporting all of the tax-funded schools in New Jersey. We would ask Senator Kean to represent New Jersey and propose this policy in the state Senate. If that law gets passed through the General Assembly and gets to Governor Christie and he signs it into law, it would then be up to Kimberly Harrington; Commissioner of Education; and Bob Martin; Commissioner of Natural resources; to enforce this policy in the state. As said in the New Jersey Constitution, “All political power is inherent in the people. Government is instituted for the protection, security, and benefit of the people, and they have the right at all times to alter or reform the same, whenever the public good may require it.” Everyone should be entitled to the benefit of clean drinking water and it is up to our government to protect this natural resource. Clean drinking water is something that the public needs.
A Trump administration aide said in an email that releasing a water contamination report would cause a “public relations nightmare.” So they buried it. |
children water poisoning.txt |
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2/26/2020 |
David |
Wood |
American |
Norwalk |
Connecticut |
The Transportation Climate Initiative has proposed using a cap-and-invest approach to reduce pollution from the transportation sector.This is a carbon pricing approach. While theoretically... read more The Transportation Climate Initiative has proposed using a cap-and-invest approach to reduce pollution from the transportation sector.This is a carbon pricing approach. While theoretically attractive, there are a number of practical reasons that carbon pricing will not work as theorized: In addition, The Regulatory Analysis Project (RAP) recently completed a relevant study: "Economic Benefits and Energy Savings through Low-Cost Carbon Management for Vermont" that raises additional relevant concerns. Other relevant concerns are discussed in the well-written attachment provided. I implore you to read it thoroughly, incorporating the points raised in your planning process. |
caiazza-tci-comments-february-2020.pdf |
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2/26/2020 |
Joseph |
Zagrobelny |
Nine-AI |
Boston |
Massachusetts |
We would love to help you deliver the Next Generation of Infrastructure in the middle of our $4 Trillion U.S.-Canada-Africa-Global ecosystem - eliminate traffic congestion, a $43B/year Northeast... read more We would love to help you deliver the Next Generation of Infrastructure in the middle of our $4 Trillion U.S.-Canada-Africa-Global ecosystem - eliminate traffic congestion, a $43B/year Northeast ROI, Radicaally reduce carbon, and delier a 400% ROI in a Next Gen P4 Finance model.
Our Tower-based design can deliver a triple return for Transit, 5G Communications, and Power T&D – tying in all the renewable sources and making the Power Grid MUCH more Resilient. This is the BIG breakthrough needed (as pointed out by Bill Gates and Breakthrough Energy) to allow us to supply the power grid with clean energy even during windless days, cloudy weather, and nighttime.
More than 40% of all carbon emissions come from the transportation sector and our iSAIL Energy-Fin-Transit can do root-cause fixes while making the U.S. a leader in Climate Change Resiliency and Carbon Reduction …….. iSAIL Energy-Fin-Transit is Towers, Guides and Pods that Fly for 80-100mph intracity/250 mph intercity at the cost of asphalt, $2M-3M/mile and 1/100th the cost of even light rail that can $250M/mile, $1B/mile for hyperloop (IF it works) and up to $5B/mile for heavy rail. iSAIL is based on decades of R&D at DARPA, NASA and MIT with AI proven to work where other methods failed. iSAIL Transit will open up a whole new world of urban-rural and land use optimization, turn commutes and freight delivery from hours to minutes, and Radically Reduce GHG emissions.
Our public–private framework enables a New Financial Model with private investors who are patient and risk tolerant, global corporations, and financial institutions with the capital necessary to finance the world’s largest infrastructure projects as we fill the $90 trillion global void and deliver the 400% return.
With humanity in the “race of our lives,” sea level rise accelerating faster than thought (The Guardian, Feb 3, 2020), together, we can deliver the Breakthrough solutions needed at 1/100th the cost of “dinosaur infrastructure” and deliver the URGENT and Bold Solutions to Climate Change the world is looking for, fill voids in the $90 Trillion infrastructure market, minimize the financial burden, especially in developing countries, maximize Revenue to municipalities, and set the Gold Standard for Resilient Transit, Cities, and world infrastructure.
Can you please let me know if we could schedule some time in the next few days to discuss how, together, we can accelerate delivery for ambitious carbon neutral goal? ….. And fix (much of) the brokenness, that will accelerate with the looming global recession?
Thank you very much!
Joe
Joseph Zagrobelny
Founder & CEO, Nine-AI | www.nine-ai.com | M: 781.825.3267 | joseph@nine-ai.com
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iSAIL TP5.pdf |
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2/26/2020 |
Norma |
Kline |
Retired Conservation Biologist |
Meadville |
Pennsylvania |
The Transportation and Climate Initiative needs to consider and implement a comprehensive transportation initiative program now that includes but is not limited to improved transportation options... read more The Transportation and Climate Initiative needs to consider and implement a comprehensive transportation initiative program now that includes but is not limited to improved transportation options, as well as for polluters to pay for their share and responsibility for the climate crisis. To this end I strongly recommend the initiative review, consider and incorporate these documents into its transportation initiative program: 1) 2018 Fourth National Climate Assessment Chapter 12: Transportation (.pdf attached), and 2) the 2019 International Monetary Fund approach to pricing carbon that holds fossil fuel producers economically accountable while directly compensating the citizen's via a carbon rebate. The IMF approach is summarized and the full pdf file can be downloaded can be downloaded here: https://www.imf.org/external/pubs/ft/fandd/2019/12/the-case-for-carbon-taxation-and-putting-a-price-on-pollution-parry.htm. |
NCA4_Ch12_Transportation_Full.pdf |
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2/26/2020 |
Jordan |
McGillis |
Institute for Energy Research |
Washington |
District of Columbia |
The Institute for Energy Research opposes the Transportation and Climate Initiative (TCI).
The justification offered for TCI is that greenhouse gas emissions constitute a threat to... read more The Institute for Energy Research opposes the Transportation and Climate Initiative (TCI).
The justification offered for TCI is that greenhouse gas emissions constitute a threat to the people of the region, but the Draft Memorandum’s assertions are overstated. The Draft Memorandum claims, “climate change poses a clear, present, and increasingly dangerous threat to the communities and economic security of each Signatory Jurisdiction.” But while some portions of the TCI region may be made worse off by climate change, other portions are likely to be made better off. It is widely accepted that cities at northerly latitudes, such as Buffalo, New York, may benefit from a warming climate. It is reasonable to speculate that Buffalo and other municipalities across the TCI region will become more attractive destinations for in-migration and will reap the rewards of increased human capital and weather more conducive to productivity.
Even taking the Draft Memorandum’s climate claims at face value, we must still ask: Will TCI provide relief to the region’s residents? The answer is a resounding “no.”
The numbers presented in the December 2019 TCI webinar show this failure. The TCI slides claim the proposal will reduce regional transportation-sector emissions by between 20 and 25 percent. The same documents cite a reference case—i.e., a scenario without the TCI emissions cap—in which emissions fall by 19 percent. In the no-cap reference case, emissions tally 206 million tons in 2032; in the scenario with the TCI cap set at a 20-percent reduction level, 2032 emissions are 202 million tons—just 4 million tons lower. In the context of the more than 30 billion tons of greenhouse gases emitted globally each year, the climate impact of TCI’s incremental reduction of 4 million tons is too small for measurement.
Meanwhile, the program will remove over $1 billion annually from the regional economy for allowance purchases. This will harm every resident of the region through increased transportation expenses. These costs will not only be seen by motorists in the form of higher fuel prices; urban residents who prefer public transit will also face higher prices, such as for goods transported to the region’s cities by truck. TCI will not confer measurable climate benefits, but it will result in immediate cost-of-living increases for millions of people.
Lastly, with its vague spending mandates, TCI will be fertile ground for corruption and waste. TCI jurisdictions will tax the general population only to dole out the proceeds to politically-favored firms that stand to benefit from TCI investments.
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TCI Regional Policy Design Stakeholder Input.pdf |
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2/27/2020 |
John |
Reese |
Shell Oil Products US |
Houston |
Texas |
Please find attached comments on the proposed MOU Please find attached comments on the proposed MOU |
Shell Comments on GTCI MOU 02-27-20.pdf |
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2/27/2020 |
David |
Reed |
NY State Resident |
Fairport |
New York |
I am very supportive of this initiative and what is being undertaken, I share the project goals and objectives. I would like to see 100% of the investment go directly into electric vehicle... read more I am very supportive of this initiative and what is being undertaken, I share the project goals and objectives. I would like to see 100% of the investment go directly into electric vehicle incentives and EV infrastructure. Growing mass transit is a very laudable objective, however it requires a very difficult public behavior change and is clearly not practical in much of NY State.
Please continue and expand the direct purchase rebate for EV's in all states, NY is currently $2,000, NJ is better, currently at $5,000, applied at vehicle acquisition.
Please use the investment funds to incentivize the build out of EV DC fast charging stations across NY. The lack of DCFC infrastructure is a significant hindrance to the rapid adoption of EVs. The convenience of charging at home is great, but we need the DCFC infrastructure to be put in place to win over the majority of drivers.
In summary, I recommend all the investment dollars be directed towards reducing acquisition cost of ZEVs and incentivizing a reliable, robust, dependable, and prolific DCFC network across NY and the entire northeastern US.
Please see attached for my full feedback. |
Project feedback 2020-02-27 - David Reed.pdf |
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2/27/2020 |
Emily |
Hammel |
Boston University School of Public Health |
Boston |
Massachusetts |
The Transportation and Climate Initiative (TCI) seeks input from stakeholders regarding specific considerations that ought to be factored into the Model Rule and starting level for a regional cap... read more The Transportation and Climate Initiative (TCI) seeks input from stakeholders regarding specific considerations that ought to be factored into the Model Rule and starting level for a regional cap, compliance structure, and stability mechanisms. As a Master of Public Health student in the Environmental Health Department at Boston University School of Public Health, I offer my comments and recommendations based on my understanding of Environmental Health, Environmental Justice communities, and Environmental Policy.
The TCI aims to implement a program with four main objectives: reduce greenhouse gas emissions, improve air quality and public health, enhance transportation options, and alleviate the burden environmental justice communities bear in regards to poor air quality and limited mobility. TCI states that transportation contributes to 40% of GHG emissions in the Northeast and Mid-Atlantic region; the proposed MOU is therefore appropriate to address issue of GHG emissions from the transportation sector, not only in an attempt to mitigate climate change but also to improve public health by reducing harmful co-pollutants like SO2 and NOx and increasing mobility in congested, urbanized areas. (See attachment for references)
STABILITY MECHANISMS
TCI seeks input on which factors it should consider when designing stability mechanisms for managing uncertainties in future emissions and allowance prices. The rate of reduction in emissions is critical to ensuring the sustainability of revenue needed for investment. Successful reduction from the fuel sector, and consequently fewer allowances being purchased, may cause a decline in generated revenue. The Model Rule must control the rate of reductions in order to sustain reliable revenue from fuel suppliers to invest in clean transportation alternatives. A dynamic allowance structure would provide additional stability in response to uncertainty in future emissions.
The Memorandum of Understanding (MOU) provides strategies to respond to unpredictable changes in market costs and demand in section “G. Stability Mechanisms”.
Suppliers trying to maximize profits will purchase allowances, bringing in more revenue for alternative transportation initiatives. As alternative transportation options become available, consumer demand for fuel drops. To maintain pressure on suppliers to continue reducing emissions, the cap will continue to drop over time. However, if this drop occurs too quickly, suppliers will not be inclined to buy allowances and revenues will fall. In addition to the CCR and ECR mechanisms proposed, TCI should implement a minimum cost for allowances that increases annually. This dynamic floor cost would compensate for expected long-term trends in lower demand for fuel. It also de-incentivizes industries to buy allowances, thus reducing emissions further, yet still maintains a revenue margin that allows TCI to reach its objectives. The Climate Law and Policy Project make similar recommendations in their comment under the “Accelerating Reductions” section. (See attachment for reference)
Predicting market trends and consumer behavior requires accurate models. These models can be very good, but are seldom completely accurate. To ensure the success of a TCI program, the Signatory Jurisdiction should consider additional strategies to maintain a controlled reduction rate.
COMPLIANCE
TCI also seeks input on how the compliance period should be structured to provide needed flexibility, while ensuring environmental integrity. As discussed above, the time period for compliance is closely interconnected to market dynamics. I suggest that the period ought to be stringent enough so the emissions are enforced in a reasonable time frame, though not so stringent to compromise the economy and solvency of suppliers. Too stringent and narrow of a compliance period may accelerate reductions and lead to a rapid drop in demand, which could destabilize the revenue structure needed for TCI to be successful. Allowing for offsets and allowance purchase should be permitted, but limited. The role of allowances and offsets should be primarily to control the rate of reduction, and encourage reduction rates to reflect those of development and utilization of alternative transportation measures.
I support the implementation of TCI. The initiative has four equally important objectives, three of which exist independent of the politics surrounding climate change. TCI not only reduces GHG, but also improves air quality and public health, reduces congestion and improves mobility in urban areas, and rightfully address environmental pollution issues that disproportionately burden Environmental Justice communities. All jurisdictions should support and participate in the Transportation Climate Initiative to protect individuals’ rights to a clean environment, ensure effective transportation for all, and promote health that is not burdened by the consumption behaviors of the “haves” against the “have nots”.
Respectfully,
Emily Hammel
Jamaica Plain, MA 02130
MPH Student, Boston University School of Public Health |
TCI Comments_Hammel, Emily_Final.pdf |
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2/27/2020 |
Sal |
Risalvato |
New Jersey Gasoline, C-Store, Automotive Association |
Wall |
New Jersey |
Please review attached comments. Please review attached comments. |
NJGCA Letter on TCI 02-26-20.pdf |
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2/27/2020 |
Connor |
Dolan |
Fuel Cell and Hydrogen Energy Association |
Washington |
District of Columbia |
Please see the attached document. Please see the attached document. |
TCI MOU Response FCHEA 2020-2-28.pdf |
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2/27/2020 |
Brian |
Moran |
New England Convenience Store & Energy Marketers Association |
Stoughton |
Massachusetts |
New England Convenience Store & Energy Marketers Association New England Convenience Store & Energy Marketers Association |
NECSEMA TCI MOU Comments 2-27-20 FNL.pdf |
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2/27/2020 |
Morgan |
Butler |
Southern Environmental Law Center |
Charlottesville |
Virginia |
Attached please find comments from the Southern Environmental Law Center on the Draft Memorandum of Understanding. Attached please find comments from the Southern Environmental Law Center on the Draft Memorandum of Understanding. |
SELC comments on TCI Draft MOU 2-27-20.pdf |
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2/27/2020 |
Rita |
Hansen |
Onboard Dynamics, Inc. |
Bend |
Oregon |
February 24, 2020
Ms. Kathleen Theoharides, Chair
Transportation & Climate Initiative of the Northeast and Mid-Atlantic States
Georgetown Climate Center
600... read more February 24, 2020
Ms. Kathleen Theoharides, Chair
Transportation & Climate Initiative of the Northeast and Mid-Atlantic States
Georgetown Climate Center
600 New Jersey Avenue, NW
Washington, DC 20001
Dear Secretary Theoharides:
My name is Rita Hansen and I am the CEO of Onboard Dynamics, Inc., an early phase company and a spinout from Oregon State University that provides novel compression technology to enable the use of natural gas and renewable natural gas as a transportation fuel. I appreciate the opportunity to comment on the Transportation & Climate Initiative (TCI) Draft Memorandum of Understanding of the Transportation and Climate Initiative and I commend TCI’s goals of equity, environmental justice, non-discrimination and meaningful public participation as it develops and implements a regional policy for transportation emissions reductions.
Onboard Dynamics endorses strategies that support the transition to low-carbon transportation fuels, including geologic and renewable natural gas. Converting the Northeast and Mid-Atlantic regions’ heavy- and medium-duty freight and transit transportation network to natural gas provides a readily available, proven and cost-effective solution to accelerate the transition to a low-carbon transportation future. Further, 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 trucks and buses, including those higher emitting vehicles that operate in communities that are underserved by current transportation options and overburdened by urban pollution.
Cleaner Air Starts with Cleaner Trucks and Buses
Increased use of natural gas as a transportation fuel provides immediate and significant criteria and toxic air pollutant reductions. Fact: the cleanest commercially available heavy-duty engine in the world is powered by natural gas now and for the foreseeable future. Designed, built, and manufactured in America by Cummins Westport, this engine is certified to a 0.02 g/bhp-hr. standard, making it 90 percent cleaner than the EPA’s current NOx emissions requirement and 90 percent cleaner than the cleanest diesel engine. And in real-life study, these engines emitted lower NOx emissions than certified.
Replacing just one traditional diesel-burning heavy-duty truck with one new Ultra Low-NOx natural gas truck is the emissions equivalent of removing 119 traditional combustion engine cars off our roads. Heavy-duty equals heavy impact.
Carbon-Neutral/Negative Freight with RNG
Natural gas engines offer significant climate change benefits. Compared to diesel, natural gas engines fueled with geologic natural gas reduce CO2 and greenhouse gas emissions by at least 12 percent. When fueled with renewable natural gas (RNG or biomethane) captured from agricultural, food, landfill or wastewater, even greater CO2 and greenhouse gas benefits are achieved, up to 331 percent lower than diesel. Fueling with RNG is carbon-neutral, even carbon-negative, depending on the feed stock as shown below. No better commercially available and deployable alternative fuel option currently exists for the heavy-duty sector.
CARBON INTENSITY of TRANSPORTATION FUELS (EER-Adjusted)
<Please see the attachment for the chart inserted here.>
Address Noise Pollution
Natural gas vehicle technology affordably addresses noise pollution in urban neighborhoods. A U.S. Department of Energy study identified significant noise reduction benefits as a motivator for many refuse collection truck operators in accepting the technology, citing up to 10 decibels quieter than their diesel counterparts. A 2016 in-use study of diesel and CNG urban transit buses in Serbia found considerable reductions in noise pollution when powered by CNG.
Invest Impactfully – Emissions Reductions using Cost Effective Solutions
Investments in Ultra Low-NOx Near Zero emission natural gas vehicle technologies greatly impact communities, especially the underserved and marginalized communities in metropolitan and industrial areas. With vehicle costs close to that of diesel and fuel price differentials of up to $1.50 less than diesel per DGE, natural gas transportation provides the largest and most cost-effective reductions in transportation-related pollutants than any other powertrain option commercially available today or near-term.
UPS, Waste Management, Republic Services, Los Angeles World Airports Buses, City of Los Angeles, City of Fresno Transit, LA Metro Transit, New York’s Hunts Point fleet Industries and many other fleets recognize the exponential impact of using RNG for emissions reductions and their improving business’ bottom line. In May of 2019 UPS announced that it will purchase 170 million gallon equivalents over 7 years that will reduce GHG emissions by more than 1 million metric tons, and in October UPS announced the order of 6000 heavy duty NGV RNG trucks to double the size of their NGV fleet. In February 2020, UPS increased their RNG commitment to a total of 250 million-gallon equivalents over 7 years.
Meanwhile, Waste Management has converted approximately 9,000 of its 17,000 collection vehicles to natural gas, resulting in the largest heavy-duty natural gas truck fleet of its kind in North America. Over 40 percent of Waste Management’s natural gas fleet currently is fueled with RNG produced from landfill biogas, supporting its long-term strategy of creating a near-zero emissions collection fleet. RNG already fuels more than 32% of the over 175,000 NGVs in the U.S. today, and a growing number of fleets are taking advantage of vehicles that are available now at comparable life cycle costs to diesel vehicles and that provide transformational GHG and tailpipe emissions reductions.
As such, investments in RNG-fueled trucks and transit buses accessing ports, cities, and densely populated neighborhoods are the most immediate and fiscally responsible investment to clean our air and combat climate change. Communities get more clean vehicles having greater clean air and climate impact for the money with natural gas than with any other alternative fuel option, especially electric. No other transportation fuel is as sustainable, adaptive, and competitive across all applications and vehicle classes. And heavy-duty natural gas trucks are not demonstration science projects; they are proven, scalable, and on U.S. roads today. We will not meet emissions reduction goals or time frames without using natural gas.
Natural Gas Pays Its Way and Provides Economic Opportunity
Natural gas fueling pays into the federal highway trust fund and is ready-right-now technology. It is road-tested and backed by a mature network of manufacturers, servicers, and suppliers coast-to-coast. An established refueling infrastructure of 2,000 stations already exists.
It is also important to note that while 34 U.S. states produce geologic natural gas, the potential to produce RNG exists in every U.S. state and the District of Columbia by taking the problem of fugitive methane gas created from organic waste, capturing it, then using it to fuel traditionally heavy-carbon freight and transit transportation applications. In addition to its clean air and climate benefits, the development of RNG facilities also supports the agriculture industry with new revenue streams, addresses many cities’ solid waste issues, and impacts watershed management efforts and nitrogen runoff concerns. With these positives, the demand for RNG production is growing and new RNG facility development projects are increasing rapidly.
100% Domestic Fuels
Geologic and renewable natural gas are 100 percent domestic fuels, unlike limited electric vehicle battery components that are controlled by foreign interests and mostly sourced from conflict countries like the Democratic Republic of the Congo and China. The U.S. EPA recognizes the value of RNG and includes it in the EPA Renewable Fuel Standard (RFS) federal incentive. Similarly, several states have implemented low carbon fuel standards (LCFS) that promote the use of RNG and other renewable fuels.
More than four in ten Americans live in communities with dangerously dirty air. According to the American Lung Association, that number continues to rise, from 125 million in 2017 to nearly 141.1 million today. Cap-and-invest program investments in natural gas vehicle technologies offer the most proven, cost-effective, and immediate way to promote a low carbon transportation future, clean our air, and provide more affordable, accessible, and reliable transportation opportunities for marginalized and underserved communities.
As the TCI states in the Draft MOU, a regional program “addresses the urgent need to mitigate greenhouse gas emissions and other harmful pollutants generated by the transportation sector” which I fully agree with and offer that natural gas vehicles, especially those using RNG must be a key component to any TCI strategy if these reductions are to occur in any reasonable time frame and improving the areas of greatest need.
Thank you for your consideration, and please contact me at rita.hansen@onboarddynamics.com or 206.291.3206 with any comments or questions.
Thank you for your consideration.
Sincerely,
Rita Hansen
CEO
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Onboard Dynamics TCI MOU - 24FEB2020.pdf |
