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11/5/2019 |
Christian |
Herb |
Connecticut Energy Marketers Association |
Cromwell |
Connecticut |
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... read more 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. |
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11/5/2019 |
Lawrence |
D'Arco |
Private citizen |
Albany |
New York |
I would like to submit the following comments for the Transportation and Climate Initiative (TCI).
Studies have shown that employer paid subsidies, for employee transit costs,... read more I would like to submit the following comments for the Transportation and Climate Initiative (TCI).
Studies have shown that employer paid subsidies, for employee transit costs, increases employee transit ridership. When the DEC moved to downtown Albany an Upstate Transit (Saratoga County bus service) transit subsidy program was offered. About 20% of the people who lived in the Upstate Transit service area participated and took the bus to work.
The IRS rules for employer paid transit subsidies have changed. It appears that employer paid transit subsidies are exempt from employer payroll taxes and are not taxable as income for the employee. Consideration should be given to the following:
1) engaging employers to encourage employer paid transit subsidies,
2) a statewide regulation, like NY City, Washington, DC, and San Francisco, who all have requirements for employers of a certain size to provide transit subsidies to their employees,
3) providing state tax benefits to employers who provide transit benefits, telecommuting and carpool and bicycling incentives.
Create a credit system, which allows tradable credits, for companies or organizations that provide employee commuter benefits such as transit subsidies, telecommuting, vanpooling and also housing cost assistance to employees that live close to work. Location efficiency mortgages (LEMs) provide mortgage assistance to people who live near transit lines and have lower automobile costs, if any. LEMs and employer grants for living near work have been offered in the Capital District. When people live close to work and other amenities, vehicular pollution is reduced. Any company or organization could also get credits if they contribute to a transit fund that would help pay for transit passes for low income individuals. There are models for calculating emissions reductions for transportation demand management strategies.
Engage with California and all California emissions standards states for the following proposals:
1) All new vehicles should have idle-stop technology,
2) credits should be allowed for conventional hybrids. Many people do not have the ability to have home-charging for plug-in EVs, so they can only own conventional hybrids which are less polluting then gasoline or diesel vehicles.
3) Increase credits for plug-in hybrids. Most people will not buy a battery electric vehicle due to the limited battery range. Americans drive less than 40 miles per day on average. Plug-in hybrids, with a 50 mile electric range, will therefore be almost completely electric for the majority of trips each day.
Explore the possibility of biofuel from industrial hemp which is not a food crop and is now legal to grow in the US. The irrigation, pesticide, herbicide and fertilizer needs of industrial hemp are minimal. Such a biofuel comes close to carbon neutrality.
Institute a small tax on parking and direct that money toward subsidizing transit passes and improving transit systems. The tax could be added to private parking facilities and would work like hotel occupancy taxes or utility taxes for energy conservation purposes. Companies that offer free parking to their employees could be taxed on the value of their parking spaces. This would encourage employers to charge for parking which would encourage transit usage and carpooling.
There has been a significant increase in truck delivery traffic due to increased internet purchases. Institute a tax on internet purchase deliveries and direct that money to the same transit fund that is funded by parking taxes.
Transit bus systems need to have more express services, both intraurban and suburbs to city service. The ridership on the express buses on Central Ave in the Capital District has proven the need for more express service. Non-express bus lines in the Capital District have too many stops, which slows down service. In NY City, bus stops are spaced to at least two blocks distance. There also needs to be increased service between the suburbs and downtown businesses in upstate cities. In the Capital District, the highest volume of daily commuters is from Saratoga County to downtown Albany.
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11/5/2019 |
Gail |
Presley |
Maine Audubon |
Rockland |
Maine |
I strongly support strategies to reduce our carbon footprint and improve the lives of Mainers through actions to improve public transportation options. In the midcoast, we have almost no public... read more I strongly support strategies to reduce our carbon footprint and improve the lives of Mainers through actions to improve public transportation options. In the midcoast, we have almost no public transportation options, with only a very limited local option. This makes everyone reliant on their car, which keeps us pumping out pollutants that are affecting our global climate. It is wise to work with our neighboring states and communities on a regional, bipartisan solution to provide clean, affordable, and accessible public transportation to our communities. Applying a “cap and invest” approach to transportation, as was used in the Regional Greenhouse Gas Initiative, would help Maine redirect some of the $5 billion a year we send out of state to fossil fuel companies into our local communities and sustainable transportation solutions.
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11/5/2019 |
Paulina |
Muratore |
Union of Concerned Scientists |
Cambridge |
Massachusetts |
On behalf of the undersigned 357 scientists, researchers, health professionals and doctors from across the Northeast and Mid-Atlantic region, attached is a letter in support of a strong regional... read more On behalf of the undersigned 357 scientists, researchers, health professionals and doctors from across the Northeast and Mid-Atlantic region, attached is a letter in support of a strong regional transportation policy that will reduce carbon emissions and equitably address dangerous local air pollution. |
Letter from 357 Scientists.pdf |
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11/5/2019 |
Brian |
Moran |
New England Convenience Store & Energy Marketers Association |
Stoughton |
Massachusetts |
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TCI Framework Comments 11-5-19 FNL.pdf |
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11/5/2019 |
Lisa |
McNeilly |
Baltimore Office of Sustainability |
Baltimore |
Maryland |
The Baltimore Office of Sustainability appreciates the opportunity to provide input and feedback on the framework for a draft regional policy proposal prepared by the Transportation Climate... read more The Baltimore Office of Sustainability appreciates the opportunity to provide input and feedback on the framework for a draft regional policy proposal prepared by the Transportation Climate Initiative. The City of Baltimore has committed to achieving reductions similar to goals set by the Paris agreement: 25 percent reduction by 2020 and 30 percent by 2025 (relative to 2007). Our most recent inventory showed that emissions have dropped by 15-20 percent, but more work still needs to be done to ensure that all residents are able to breathe cleaner air and face reduced risks of natural disasters. About 30 percent of our city’s greenhouse emissions come from the transportation sector.
Our 2019 Sustainability Plan lays out strategies and actions around climate change, transportation, and equity (among other topics), and is the basis for our comments:
Program Design Elements: Equity
• We applaud the emphasis on historic inequities in the development of programmatic outcomes. We recommend that a shared definition of equity be developed and included in the final framework, and that the framework also reflect how equity will also be included in the process moving forward. Will there be shared standards around community engagement and involvement as TCI is implemented and as decisions are made about investment of proceeds.
• The commitment to working with low-income communities, communities of color, and communities with limited mobility options (not just soliciting feedback from) should be strengthened.
• Seemingly absent from this framework is any discussion of how to make the impact of the TCI program less regressive, in terms of mitigating the impact on low-income individuals of the upward pressure on gasoline prices.
• Equity concerns are also central to the “additional program design elements” and more discussion of equity in these sections would improve the framwork and the eventual program.
Program Design Elements: Regulated Entities
• We would like to see clarification about the definition of a ‘supplier’ – will there be a minimum threshold of gallons sold? Is it expected that a City that dispenses fuel only to its own fleet vehicles would be a regulated entity?
• Will there be any industries or categories of entities that are exempted from regulation? If so, the process for determining these exemptions should be public and transparent and include an analysis of the impacts of these exemptions on the cost of the program.
Flexibility, Allowance Allocation, and Stringency
• We would like to see more information in the framework to address the possibility of leakage, or describing why this is not expected to be a problem.
• A risk that TCI is likely already considering is the potential for black market sales of product obtained in non-participant states. This represents a particular risk for poorer communities, insomuch as black market activities might concentrate in those areas.
• The TCI must also be considering border effects for fuel sales. Wealthier, more mobile individuals are more likely to be able to travel to non-regulated jurisdictions to obtain less expensive product.
Additional Program Design Elements: Investment of Proceeds
• We recommend that investment guidelines be jointly developed by member states. At a minimum, these guidelines should cover the process that each jurisdiction should use to get community input into decisions about how to invest proceeds. A preferred hierarchy or proportion of project types would also be beneficial. For example, should a set percentage of proceeds be used to mitigate or offset the impact on low-income households of any price increases?
• Similarly, a proactive emphasis on complementary policies would be valuable. For example, coordinated policy fora might be established to address complementary policies in the area of land use, infrastructure, etc.
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TCI Draft Framework comments Baltimore Office of Sustainability November 2019.pdf |
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11/5/2019 |
Stephen |
Malagodi |
350 Mass: Better Future Project |
Lowell |
Massachusetts |
While generally supportive of the TCI framework, many of my reservations concerning equity and climate justice have already been expressed and received by you in the on-line and community meetings... read more While generally supportive of the TCI framework, many of my reservations concerning equity and climate justice have already been expressed and received by you in the on-line and community meetings.
However, unspoken is the fact that the eventual burden of all 'cap and trade' or 'cap and invest' schemes is born by consumers who bear the cost through passed-through price increases, while those who have historically benefited greatly are the extractive industries themselves which have actively pursued policies deliberately designed to deny, deceive and distort the political process for decades concerning the cause and scope of global climate change. The cost of addressing climate change today is considerably more than it would be had we not been subjected to decades of delay perpetrated by the fossil fuel industry itself. Nothing in the TCI framework addresses this gross injustice. Nowhere in the TCI framework is there any mechanism for the extraction industries to bear or to share the "externalized" costs resulting from the sale and use of their products, or to provide compensation for the damage they have already done. |
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11/5/2019 |
William |
Driscoll |
Associated Industries of Vermont |
Montpelier |
Vermont |
As currently proposed, TCI would result in a potentially significant effective tax on highway gasoline and diesel. This would increase costs for manufacturers, retailers, dairy, forestry, mineral... read more As currently proposed, TCI would result in a potentially significant effective tax on highway gasoline and diesel. This would increase costs for manufacturers, retailers, dairy, forestry, mineral, and other businesses dependent on highway transportation for moving supplies and goods, as well as construction and other contractors dependent on vehicles, both through direct costs and the cost of transportation service providers.
Unlike residential drivers, who might respond to higher costs by adjusting driving habits and potentially converting to more efficient vehicles, and for whom states could fund programs supporting such changes with revenues allocated from TCI, the commercial transportation noted above is already driven to be as efficient as possible in terms of both logistical planning and transportation technology owing to regulatory requirements and the high costs of transportation generally, compounded by the competitive pressures businesses already face.
Without meaningful options to reduce exposure to the effective tax impact of TCI through behavioral or technology changes, or options for states to fund programs supporting such changes with revenues allocated from TCI, this cost impact could only be mitigated by moving production or operations out of the impacted region, or businesses would be left facing the consequences of trying to absorb or pass on costs to consumers.
TCI would therefore appear to promise little if any change in commercial transportation carbon emissions unless produced by reduced business operations, with resulting loss of employment and economic activity. This would be both fundamentally inequitable and highly cost ineffective.
The most efficient way to address the concerns outlined above while proceeding with TCI would be to exclude diesel from the program and focus on highway gasoline and related transportation issues and opportunities. This would protect the overwhelming majority of commercial transportation, and states could still work to assist businesses with smaller, gasoline fueled vehicle options.
Nevertheless, even focusing on highway gasoline could still lead to other economic and social consequences, particularly in rural areas. These potential consequences should be fully explored, explained, and opened to public review and comment before states take formal steps forward on the TCI proposal.
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11/5/2019 |
Ellen |
Valentino |
Mid-Atlantic Petroleum Distributors Assn. |
Annapolis |
Maryland |
To: TCI
From: Ellen Valentino
Subject: Proposed Draft Regional Policy
Date: November 5, 2019
The members of the Mid-Atlantic Petroleum Distributors... read more To: TCI
From: Ellen Valentino
Subject: Proposed Draft Regional Policy
Date: November 5, 2019
The members of the Mid-Atlantic Petroleum Distributors Association (MAPDA) respectfully submit comments regarding the TCI framework and proposal released this fall. Our members are deeply concerned that the framework is moving ahead to foregone conclusions that are not substantiated by the real-world experience of other states.
The Transportation Climate Initiative sets out a framework that imposes an unfair burden on all vehicle owners and thousands of businesses, including those of our members. 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. Some of the projects envisioned have ramifications that have not been verified or well thought out.
Electric vehicles are not the only answer.
The framework pins emissions reduction on electric vehicles, or EVs to reduce gasoline sales. EVs are not the magic bullet to solving greenhouse gas emissions. An EV's massive battery must be charged with electricity, which requires power generated from another source such as coal, natural gas or even nuclear power, and has an adverse environmental impact upon disposal. Pushing consumers to electric vehicles has not been shown to lessen environmental impact due to the environmental costs of EV batteries and manufacture of new vehicles. Further, programs such as incentives to EV purchase often favor wealthier individuals while the new taxes on gasoline will disproportionate affect poor and rural communities.
Our members are at a geographic disadvantage.
The northeast compact has a greater impact on Maryland and Delaware than the other Northeast states. Geographically, Maryland and Delaware retailers will suffer the most because consumers may more easily choose to go elsewhere for fuel. It won’t just be gasoline prices that rise to meet the TCI demands. The Northeast is a major trucking corridor and this proposal will essentially raise prices on transported goods. California’s Cap and Trade program, upon which the TCI framework is based, has led to a surge in gasoline prices, which affects all aspects of the economy.
All voices are not being heard.
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. I urge that the participating Governors be required personally to attend and hold public hearings throughout their states. Our members are willing to work with others on this issue to create a true collaborative plan.
The current 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 struggled to show a true measurable benefit. We welcome the opportunity to create a realistic policy proposal that provides a more balanced solution.
Respectfully submitted,
Ellen Valentino
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MAPDA TCI comment letter.pdf |
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11/5/2019 |
Christine |
Lyman |
--None-- |
Brunswick |
Maine |
I am proud that our Governor, Janet Mills, is in support of this low carbon transportation policy planning initiative. After working in the field of public health for over 25 years, 17 of which... read more I am proud that our Governor, Janet Mills, is in support of this low carbon transportation policy planning initiative. After working in the field of public health for over 25 years, 17 of which were in Maine's state public health agency, I've watched the evidence emerge that we must address the social determinants of health, i.e. the factors that protect and improvce population health, and not just focus on access to medical care. A sustainable low carbon transportation plan can help mitigate the impact of climate change, and improve regional air quality. It will support improved quality of life in our communities, and especially so for vulnerable populations such as those affected by low income, the very old and the very young, and those experiencing heath inequities. In our rural state, this policy process will extend to attracting a workforce that seeks to work and reside in liveable communities. It will contribute to economic development when more viable alternatives are available to all in our very rural state where the demand for access to affordable transportation is so huge. Public health also recognizes that while community health happens on the ground, strategically it is efficient to develop policies, especially those which are deployed at the regional level. As a member of the Maine Public Health Association, I'm proud that our organization representing over 700 public health professionals, recently won an award for environmental health advocacy; I am sure many of my colleagues would agree with me. |
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11/5/2019 |
Anne |
Germain |
National Waste & Recycling Association |
Arlington |
Virginia |
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NWRA comments TCI.pdf |
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11/5/2019 |
Eben |
Bein |
Our Climate |
Cambridge |
Massachusetts |
Dear TCI Team,
Our Climate is so grateful for your hard work to expand regional carbon pricing to a new sector of the economy and to do so in an inclusive, collaborative,... read more Dear TCI Team,
Our Climate is so grateful for your hard work to expand regional carbon pricing to a new sector of the economy and to do so in an inclusive, collaborative, bipartisan manner. On the whole, we stand by the comments submitted by the larger Massachusetts Campaign for a Clean Energy Future, particularly their two fundamental values that a carbon price must be science-based and equitable. However, we’d like to note several additional areas of concern:
1. Both the current TCI draft and the Massachusetts campaign document refer to RGGI as an effective precedent to emulate in several ways. We would like to reiterate that, for all the revenue RGGI has generated, we have yet to find a single economist who argues that the RGGI price ($5.20/ton at the Sept 2019 auction) has been high enough to drive the emission reductions needed to mitigate the climate crisis. This argument is further spelled out in this article from Vox <https://www.vox.com/science-and-health/2017/2/28/14741384/rggi-explained>
When it comes to setting a cap, we think TCI should set an aggressive maximum of carbon neutrality by 2050, with interim targets of 45% emission reductions by 2030 that all participating states must adhere to. States can then individually choose to be more ambitious if they wish, but we must provide states where industry is strong the legal mandate to fight the climate crisis.
We are also very concerned about the language around “cap flexibility” and “set asides.” A responsible system must plan for what history has taught us--that industry will fight tooth and nail to dodge its financial responsibilities. The MA campaign critiques on limiting cap flexibility and banking of permits are correct but don’t go far enough. In a climate emergency, we should not allow for flexibility, set asides, or banking, period. Industry must not be given wiggle room.
2. In MA, we are very proud of the design of H.2810 which uniquely proposes redistribution of 70% of its funds directly to families to financially equip them to make greener decisions. These rebates are weighted by income to ensure financial protections for the low-income communities most affected by climate change. This is the only carbon pricing bill to my knowledge that has received explicit support from Environmental Justice organizations in MA, and we must consider whether a progressive rebate structure is possible in TCI to ensure that no family is left in a difficult situation.
Meanwhile, our team in New York is quite concerned that New York Renews Coalition which just passed the CLCPA and is designing the CCIA, will face similar complications to MA. The careful work to build relationships with EJ communities for our state level prices does not seem to be transferring to the TCI process. This is partially why NY’s participation in TCI is currently tenuous.
In my previous commentary, I mentioned the concerns of our partners at the Climate Justice Alliance. Since that time, they have released another set of criticisms on use of Cap and Invest as a structure <https://climatejusticealliance.org/climate-justice-alliance-disappointed-disingenuous-policy-design-principles-proposed-transportation-climate-initiative-tci/>. TCI must provide specific allowances and guidelines for the equitable use of funds that it invests and will give local Green Justice communities the power to design a way to use those resources that meets their needs as they see them, not as the TCI administrators perceive them.
Thank you so much,
Our Climate
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11/5/2019 |
Ted |
Harris |
Pennsylvania Petroleum Association |
Harrisburg |
Pennsylvania |
The Pennsylvania Petroleum Association represents over 400 companies who operate in the petroleum industry throughout the state. Our association opposes the Transportation Climate Initiative which... read more The Pennsylvania Petroleum Association represents over 400 companies who operate in the petroleum industry throughout the state. Our association opposes the Transportation Climate Initiative which would create an upstream tax for Pennsylvania motorists who already pay the highest gasoline taxes in the country. Independent motor fuel marketers who employee tens of thousands of jobs in Pennsylvania will be forced to operate in a marketplace that is purposely designed to put them out of business.
The Transportation Climate Initiative does not appear to benefit all Pennsylvanians the same way. Fixed and low-income residents will be forced to pay higher prices at the pump. They are also less likely afford an electric vehicle regardless of the potential subsidies that could be available to them. The large number of residents who live in the rural communicates across the state will not be able to benefit from public transportation efficiencies in the same way as those who live in Philadelphia, Pittsburgh, and other populated areas.
Our membership and industry support a cleaner environment. We welcome the opportunity to work with the Georgetown Climate Center, policy makers, and other stakeholders to achieve this goal. We however do not support the current version of the Framework for a Draft Regional Policy Proposal. We ask that more consideration is taken before potentially introducing a policy that is unfair and has massive ramifications for our membership, citizens, and economy.
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11/5/2019 |
Jenifer |
Bosco |
National Consumer Law Center |
Boston |
Massachusetts |
Thank you for the opportunity to comment on the TCI Framework for a Draft Regional Policy Proposal. The National Consumer Law Center (NCLC) is a non-profit organization that works for economic... read more Thank you for the opportunity to comment on the TCI Framework for a Draft Regional Policy Proposal. The National Consumer Law Center (NCLC) is a non-profit organization that works for economic justice for low-income and other disadvantaged people in the U.S. through policy analysis and advocacy, publications, litigation, and training. NCLC submits these comments on behalf of our low-income clients. Our comments focus on equity issues, program design, and other elements that may directly affect low-income consumers. Please see attached comments, in PDF format. |
TCI Comments 11 05 2019 NCLC.pdf |
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11/5/2019 |
RAVINDER |
ANAND |
252 |
Upper Marlboro |
Maryland |
I am opposed to the TCI plan as outlined I am opposed to the TCI plan as outlined |
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11/5/2019 |
Barbara |
Kiss |
General Motors |
Detroit |
Michigan |
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TCI_GMComment_FINAL 1.pdf |
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11/5/2019 |
Sam |
Wade |
Coalition for Renewable Natural Gas |
Sacramento |
California |
Please see our attached comment letter. Please see our attached comment letter. |
191105 RNGC Comments on TCI Program Design Framework.pdf |
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11/5/2019 |
Rajesh |
Saxena |
252 |
Capitol Heights |
Maryland |
This TCI Plan does not seem to take into account the small businesses that employ thousands of unskilled and skilled workers. It seems they are bent upon killing the crux of small business... read more This TCI Plan does not seem to take into account the small businesses that employ thousands of unskilled and skilled workers. It seems they are bent upon killing the crux of small business community.
They should think of stopping issuance of new business licenses to big gas station companies like WAWA, Royal Farms, Seven Elevens who are just busy opening new gas stations like mushrooms in the name of development and counties are helping them without keeping anything like what TCI is trying to achieve.
I know at least five big gas stations having come up in one single zip code 20743 while at least 4 more are about to come. a curvy will reveal there are not only one but two or three stations on every corner of each road. Stop supporting big companies and help sustain the existing businesses. |
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11/5/2019 |
Eric |
DeGesero |
Fuel Merchants Association of New Jersey |
Cranford |
New Jersey |
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TCI Draft Framework Comments.pdf |
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11/5/2019 |
Maria |
Becker |
Retail fuel station and convenience store |
Parkville |
Maryland |
TCI I’m against this program and I feel that our government should practice what they preach it should start there,then present the numbers. Have All government officials use public transportation... read more TCI I’m against this program and I feel that our government should practice what they preach it should start there,then present the numbers. Have All government officials use public transportation and electric cars. We are not going to fix this with a tax. A tax will just give government more money to mismanage. Plus we contribute less green house gases then China.Europe and America contribute less greenhouse gasses then China ........ FIX CHINA. As a small business I’m still paying a delivery (gas fee) for every delivery I get that started when gas was over $4 per gallon and it was never removed from any delivery and our volume sales of gas didn’t go down. A small percentage of neighborhood people got rid of the gas guzzlers when cash for clunkers happened and that caused a shortage of used parts for older vehicles. I’m done ranting. |
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