TCI Regional Policy Design Stakeholder Submissions

It is essential that we clean up transportation all across this great country, but particularly in the crowded heavily trafficked Northeast corridor.
Incentives (or requirements) that encourage electric vehicles, more reliable charging network, transitioning to renewables as the primary energy source. Battery capacity is now much improved.
Also, keep supporting good public transportation options, including for the last mile.
Thank you!

We need to increase investment and ridership on public transportation which would reduce wear on highway infrastructure, decrease emissions, and save citizens money needed for car-care expenses.

The "Framework for a Draft Regional Policy Proposal" released on Oct 1st does not include natural gas / methane in affected fossil fuels that will be included in the cap-and-invest program. --- "The proposed program would cap emissions of carbon dioxide from the combustion of the fossil component of finished motor gasoline and on-road diesel fuel in the region."

Natural gas / methane used as a motor vehicle fuel is not sustainable and contributes to greenhouse gas emissions from on-road use.
The methane leaks from transmission pipelines, well heads, and fueling must be considered and is a significant greenhouse gas emission in addition to on-road tailpipe emissions. Environmental impacts from fracked gas wells and wastewater disposal (including earthquakes) are problematic and create widespread rural environmental justice issues. Natural gas / methane transportation fuels are already in use and may increase if they are given a lower cost of operation from being excluded from the Transportation Climate Initiative framework.

It smells funny that methane / natural gas utilized for transportation fuel was not included in this draft framework document. An outside observer might think that the natural gas industry is influencing the process to give themselves a competitive benefit despite negative environmental and ghg emissions impacts.

https://www.nrdc.org/onearth/natural-gas-industry-has-methane-problem

Climate change is going to happen and you cannot alter Mother Nature! Nothing we do is going to slow or alter it without bankrupting the country, and that is an unacceptable option. The TCI is a coalition to implement a stealth tax on an unsuspecting and ignorant public, and like all politicians and bureaucrats, once you set an agenda there will never be an admission of error. The problem of climate change will never be ameliorated to your satisfaction, and you will continue to seek funding to fill the rathole. I am strongly urging my legislators to reject the TCI.

And keep that whiny, holier-than-thou, little brat from Sweden out of the region.

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.

Please don't make a long term decision on the SHORT TERM view that EV's are the best option for the climate. HUGE investments may prove to have been foolish down the road. There are always new technologies developing especially those in the renewable world that do NOT rely on fossil fuels AT ALL! To convert to EV's which rely mainly on Natural Gas is a short term view!! Think of future generations not just a short term feel good plan.

Thank you.

We must move forward in the attempt to protect our air and waters with the low carbon transportation policy. States must initiate these important projects as we await sanity in Washington.

We Mainers simply can not afford another rise in taxes, let alone in the area that we utilize the absolute most here in central Maine! Being a disabled, full time care taker for my 3 grandchildren, we are always on a very tight budget. One of our children is an autistic child that requires we keep the house quite warm and has appts very often that require us to drive frequently. We absolutely could not afford to provide the special accommodations that we do for him of the taxes are passed. We would literally have to make cuts on things like groceries, medications etc in order to survive. This proposal would not benefit anyone other than the people of Portland-

We face a climate emergency and cannot win unless we start immediately. The Cap and Trade can be a valuable tool but it must be done soon and aggressively. If gasoline stays cheap and plentiful, we will fail to save the climate. So thanks for implementing this legislation.