11/5/2019 |
Meghan |
McGuinness |
National Grid |
Waltham |
Massachusetts |
Please see attachment. Please see attachment. |
TCI comments 1105.pdf |
11/5/2019 |
Andrew |
Kambour |
The Nature Conservancy |
Arlington |
Virginia |
Please see the attached comments from The Nature Conservancy on the framework for a draft regional policy proposal. Please see the attached comments from The Nature Conservancy on the framework for a draft regional policy proposal. |
TNC Comments - TCI Draft Framework 11-5-19.pdf |
11/5/2019 |
Johanna |
Miller |
Vermont Natural Resources Council |
Montpelier |
Vermont |
Transportation & Climate Initiative Regional Policy Workgroup,
Thank you for the opportunity to comment on the “Framework for a Draft Regional Policy Proposal” released on... read more Transportation & Climate Initiative Regional Policy Workgroup,
Thank you for the opportunity to comment on the “Framework for a Draft Regional Policy Proposal” released on October 1, 2019. We – the undersigned organizations – view the Transportation and Climate Initiative (TCI) as an important opportunity for regional collaboration on a pressing problem. We also believe that robust public input into both the regional and state decision-making process is essential to ensure an equitable policy design and the best program possible.
We face an existential crisis when it comes to climate change. Our collective greenhouse gas (GHG) emissions – largely from the combustion of fossil fuels and, in our region, largely coming from the transportation sector – are putting our economies, public health, and quality of life at great risk. Strategies that are carefully designed to reduce carbon pollution as swiftly as possible, in an equitable manner, are essential. TCI offers one of those opportunities. Getting it right, but getting it done, is essential. And, then we will need to do more.
Vermont is far from meeting its long-standing climate goals, with most of our GHG emissions increases coming from our most carbon-intensive sector: transportation. A strong program – including a strong cap – will be important to put Vermont and the region on track to start meeting our carbon pollution reduction commitments.
In these comments we offer some high-level input on our hopes for a strong program that could take our states, and our region collectively, one big step forward to reducing carbon pollution and, importantly, helping to create a cleaner, more diverse, more accessible 21st century transportation system. We appreciate the direction it appears TCI states are moving on several fronts and the opportunity to highlight some of the key characteristics we believe are essential to a strong, equitable program.
Thank you in advance for your consideration of this input and, more so, for your hard work to date – and the important work to come – to shape the design of a program that works for our planet and all people.
Equity
The prioritization of equity in the design of this program is key to its success, and we commend your recognition of it as a top priority. This program must – and, we believe, can – be designed to begin to dramatically reduce greenhouse gas emissions while also improving access, mobility, and public health for vulnerable and disproportionately impacted populations in particular. Ensuring this outcome will require an ongoing, inclusive, and strong public process, in particular for getting input on where any revenues would best be directed. Considering the differences among and within each state, utilizing potential TCI proceeds to address and prioritize equity, mobility, and access for more rural, low income, vulnerable and disproportionately impacted populations is essential.
In rural Vermont, transportation is a huge equity issue. It is a barrier to accessing and retaining a job and meeting basic needs such as getting to medical appointments, the grocery store and the pharmacy. The lack of transportation options leave many Vermonters isolated and alone, specifically the 1/3 of Vermonters who do not drive (this includes one in five adults over 65 years of age, people with a disability, children and those who choose not to drive). It is also a tremendous economic burden for low income households, where transportation accounts for approximately 50 percent of their energy bills. Strategies that serve a rural region well and enable Vermonters access to more clean, diverse transportation solutions are needed, and TCI revenues could serve as an important means to spur the investments required to make this transition.
Affected Fuels and Emissions
We support the TCI states’ proposal to cap carbon emissions from the combustion of motor gasoline and on-road diesel fuel in the region, as these fuels account for the vast majority of emissions from the transportation sector. We also urge that in the future other fossil fuels, such as Compressed Natural Gas (CNG), be considered for coverage as well, to avoid them being falsely viewed as a solution to transportation sector emissions.
Program Design: Auctions, Allocation, Regional Caps and Allowance Budgets
The Intergovernmental Panel on Climate Change (IPCC) has concluded that we have about a decade to substantially reduce emissions if we are to avoid the worst impacts of climate
disruption. As such, it is essential that states set a regional emissions cap at the outset of the program that is sufficiently ambitious to align both with states’ climate targets and with scientific imperatives. To ensure TCI serves as the strongest tool possible to reduce emissions, the cap should start low and drop as quickly as possible, in line with the latest climate science. Further, to achieve the GHG outcomes needed, states should also auction all allowances.
Investment of Proceeds
For the TCI program to succeed – and for states and the region to begin to reduce emissions in our most intensive sector – how revenues are invested is critical. Any TCI revenues must be reinvested in solutions that reduce pollution – as quickly as possible in the short term – as well as set the stage for avoided emissions in the long term, by giving people options for getting where they need to go by walking, biking, and taking transit, and well as the option to live in compact communities close to jobs, services, and amenities.
We believe parameters around the use of these proceeds are essential. These dollars should go to transportation-related solutions or solutions that reduce the need for transportation. TCI proceeds should not be spent to backfill budgets for roads, bridges, general funds, or, even, other needed climate solutions like weatherization or thermal fuel switching. We must find other means to meet these needs, but TCI proceeds should be harnessed to reduce carbon pollution from transportation and help to create a more connected, diverse, resilient, clean, and affordable transportation system.
Specifically, we believe any TCI revenues should prioritize low- and moderate-income and rural Vermonters without access to public transportation. The types of solutions we’d like to see prioritized include electrification of cars, buses, and bikes; transit; transportation demand management strategies like carpool, vanpool, and other creative ride-sharing techniques; safe walking and biking infrastructure; smart growth land use solutions; housing in downtowns and community centers and more.
We appreciate and support the flexibility envisioned for states to identify the best strategies and investments to meet their unique needs. We also hope to see in Vermont – but also potentially to help drive innovation more broadly – the ability for all states to spend some TCI proceeds to fund innovative pilots such as micro-transit, high-efficiency vehicle incentive programs (especially to serve low income earners), or other creative strategies that could drive reductions, enable access, and help to fill in the gaps where more traditional strategies might fall short. This includes enabling the flexibility for geo-targeted investment strategies that could serve specific regions well, considering that the best solutions for bigger cities and towns might not be the best or most-needed strategies to serve smaller communities and rural areas.
Complementary Policies
No one climate policy, including TCI, will accomplish all of the climate pollution reductions we need. We will need a diverse suite of significant, complementary policies to get the job done. We look forward to working with other TCI states, with diverse constituencies in Vermont and beyond and with policy makers to identify and advance that suite of other strategies to complement TCI, finally putting us on the path to meet science-based reduction targets we so desperately need to meet.
Conclusion
This regional effort presents the most promising opportunity at this time to tackle emissions reductions in our heavily carbon-intensive transportation sector. Shaping a strong program in line with the climate science, while also prioritizing strategies and solutions to serve low-income, rural, and disproportionately impacted communities is imperative.
As noted above, even a strong TCI will not be sufficient to do all that we must to reduce pollution. That is why we also strongly encourage you to design an equitable TCI program that could, one day, potentially link to other carbon markets – if that made sense. We know that reducing carbon pollution in our heating sector is also a climate imperative. The ability for a well-structured TCI program to link to successful programs like California and Quebec’s Western Climate Initiative would provide the flexibility for the region (or states in the region) to participate in this economy-wide market. We urge you to enable that kind of design and flexibility in the program.
Thank you again for your hard work, your ongoing commitment to designing a science-based, equitable, and flexible program, and for your consideration of our input.
Sincerely,
Audubon Vermont
Capstone Community Action
Transportation for Vermonters
Vermont Conservation Voters
VEIC
Vermont Natural Resources Council
Vermont Public Interest Research Group
CC:
Julie Moore, Secretary of the Agency of Natural Resources
Peter Walke, Deputy Secretary of the Agency of Natural Resources
Michelle Boomhauer, Director of Policy and Planning, Vermont Agency of Transportation
Curt McCormack, Chair, Vermont House Transportation Committee
Dick Mazza, Chair, Vermont Senate Transportation Committee
Vermont Senate President Pro Tempore Tim Ashe
Vermont Speaker of the House Mitzi Johnson
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Joint Comments-TCI-Nov. 5.docx |
11/5/2019 |
Lance |
Boucher |
American Lung Association |
Augusta |
Maine |
On behalf of the American Lung Association, I am writing to express our support for moving forward with a thoughtful program design that affords the greatest benefits to local community health.... read more On behalf of the American Lung Association, I am writing to express our support for moving forward with a thoughtful program design that affords the greatest benefits to local community health. The Transportation and Climate Initiative (TCI) is an important regional effort to maintain progress in the fight for healthy air and a healthy climate, and one that must place community health and climate protection at the forefront.
Please see the attached letter for our full comments on the proposal. |
TCI Submission 110519.pdf |
11/5/2019 |
Andrea |
Grant |
Independent Fuel Terminal Operators Association |
Washington |
District of Columbia |
Please find the attached comments. Please find the attached comments. |
Comments of IFTOA on Proposed Transportation and Climate Initiative.pdf |
11/5/2019 |
Shailesh |
Sahay |
POET LLC |
Washington |
District of Columbia |
POET appreciates the opportunity to comment on the TCI Framework. Our comments are attached. POET appreciates the opportunity to comment on the TCI Framework. Our comments are attached. |
POET TCI Framework Comment-11.5.2019.pdf |
11/5/2019 |
David |
Pringle |
Mr. |
Cranford |
New Jersey |
Especially in light of the clarion call by 11,258 scientists earlier today, Clean Water Action submits the attached comments urging TCI mandate reductions in climate and co-pollutant emissions in... read more Especially in light of the clarion call by 11,258 scientists earlier today, Clean Water Action submits the attached comments urging TCI mandate reductions in climate and co-pollutant emissions in all jurisdictional areas especially overly burdened environmental justice communities, meaningful fully inclusive public input at the decision-making table, and funding to follow policy with all proceeds dedicated to climate and co-pollutant emission reductions. |
Nov.15.19 TCI Comments.pdf |
11/5/2019 |
Patrick |
Kelly |
API |
Washington |
District of Columbia |
|
API TCI Comment Nov 2019.pdf |
11/5/2019 |
Bryan |
Rubio |
Port Authority of New York and New Jersey |
New York |
New York |
Please see attached. Please see attached. |
PANYNJ Comments TCI Framework 2019.pdf |
11/5/2019 |
Brydon |
Ross |
Consumer Energy Alliance |
Louisville |
Kentucky |
Attached, please find CEA's comments on the Draft Framework of the TCI. read more Attached, please find CEA's comments on the Draft Framework of the TCI. |
CEA TCI Draft Framework Comments.pdf |
11/5/2019 |
Jordan |
Stutt |
Acadia Center |
Boston |
Massachusetts |
The 44 undersigned members of Our Transportation Future and additional partners believe the Framework Policy Proposal offers an encouraging path forward for a modern, low-carbon, equitable... read more The 44 undersigned members of Our Transportation Future and additional partners believe the Framework Policy Proposal offers an encouraging path forward for a modern, low-carbon, equitable transportation system.
Thank you for the opportunity to comment. Please see the attached recommendations on program design. |
Joint Comments on TCI Framework 11_5_2019.pdf |
11/5/2019 |
Morgan |
Folger |
Environment America |
Philadelphia |
Pennsylvania |
Emissions from our cars, buses and trucks have overtaken electric power plants as the number one source of global warming emissions in the United States. Our nation’s top scientists warned in the... read more Emissions from our cars, buses and trucks have overtaken electric power plants as the number one source of global warming emissions in the United States. Our nation’s top scientists warned in the update to the National Climate Assessment that regions across the country are already experiencing the impacts of climate change. If we keep burning fossil fuels, those impacts -- from massive wildfires to extreme weather -- will get worse.
To stave off the worst impacts of global warming, we need to cut carbon pollution as quickly as possible, get clean energy on the grid, and tackle what is now the region’s largest emitter of greenhouse gases -- our transportation system. We use massive amounts of fossil fuels to move people and goods around the region, and that needs to change. We have the technology to replace this dirty system with clean, electric cars, trucks, and buses powered by the sun and the wind.
The Transportation and Climate Initiative is yet another step forward for the Northeast and Mid-Atlantic to reduce the harmful effects of climate change and global warming on our communities. We need to accelerate the transition to zero-emission transportation. With an absence of leadership at the federal level, state and local action is more important than ever.
Program Design Elements
Equity
We support expanding low-carbon and clean mobility options in urban, suburban, and rural communities. We support transparency by reporting the changes in transportation emissions over time, which will allow us to track our progress to reduce global warming pollution throughout the region. The program should limit any impacts it may have on the most vulnerable.
Applicability
Affected Fuels and Emissions
We support the point of regulation laid out in the framework. While traditional fuels like diesel and gasoline account for the majority of transportation emissions, alternative transportation fuels like biofuels also contribute to climate change and should be regulated. Corn-based ethanol, has little to no net greenhouse gas benefit and brings with it other environmental concerns. One model approach is the low-carbon fuel standard adopted by California, which sets targets for lifecycle greenhouse gas emission reductions from transportation fuels. The LCFS has the benefits of being explicitly targeted at reducing carbon pollution and incorporating all fuels, helping to drive not only the adoption of sustainable biofuels, but also the use of electricity and oil-based fuels from sources with lower carbon emissions.
Regulated Entities
We support regulating emissions from Prime Suppliers. Fuel supply infrastructure should also be regulated to ensure that we do not continue to invest in infrastructure for fossil fuels. We need to stop burning virtually all fossil fuels in order to preserve a livable climate, and that means implementing a moratorium on oil and gas pipelines, gas plants, and any other new fossil fuel infrastructure.
Compliance and Enforcement
Emissions reporting requirements
Reporting is an important part of the program to ensure fuel suppliers are held accountable to their emissions. This will also ensure that year over year, the program is truly reducing emissions from transportation fuels.
Monitoring and Verification
A third party verification of emissions reporting will ensure accountability and consistency across the region, rather than relying on each state to verify their own reporting. Emissions should be reported monthly.
Flexibility, Allowance Allocation, and Stringency
Flexibility and Cost Containment
While flexibility allows for a more nimble program, cost-containment provisions should be limited by issuing additional allowances at a set price. Cost-containment can significantly relax the emissions cap and weaken the program’s ability to reduce global warming pollution quickly and effectively. Any cost-containment mechanism should be set at a high trigger price that increases over time.
Auctions and Allocation
We strongly support auctioning 100% of allowances. This will mean most of the proceeds can be allocated directly to climate solutions.
Regional Caps and Allowance Budgets for Each Jurisdiction
We support a strong initial emissions cap and establishing a descending cap on transportation-sector emissions. We recommend that the emissions reduction goals are at the very least consistent with the goals of the Paris Agreement and incorporate all transportation fuels. We also recommend maintaining a “floor price” for allowances to assure a stable flow of revenue into carbon-cutting transportation programs if emissions dip below the level of the cap.
Regional Program Administration
Market Monitoring and Auction Administration
Much like RGGI, Inc., a regional organization is an effective way to administer the program, with representatives from each of the states engaged in the program.
Additional Program Design Elements
Investment of Proceeds
There should be more specific direction for states to invest proceeds. While it is true that every jurisdiction has unique transportation needs, there should be a menu of options they can pick and choose from, and we should limit investments that won’t achieve significant emissions reductions. This program is about addressing global warming pollution, and the proceeds from the program should go to doing just that. Improved air quality and more affordable access to transportation go hand in hand with cleaning up our transportation system. Ultimately we need to decide how to invest these proceeds in a way that will best address climate change. Leaving that decision up to the jurisdictions without specific parameters would result in missed opportunities to cut global warming pollution. TCI must reinvest auction revenue in programs to reduce carbon pollution from the transportation sector and limit any impacts the program may have on the most vulnerable.
We recommend that proceeds from TCI go to projects such as:
Replacement of fossil fuel vehicles with those using electricity or other fuels with zero tailpipe emissions - including vehicles used for personal travel, freight movement and public transportation.
Expansion of public transportation service and infrastructure; incentives for carpooling, vanpooling, and other forms of shared and active transportation; and investment in “transportation demand management” efforts to reduce vehicle travel.
Investments in infrastructure to support low- or zero-carbon transportation, including rail, bike paths, sidewalks, electric vehicle charging, etc.
Incentives/assistance for local governments to encourage accommodating new growth in walkable/compact areas.
Cars account for 60 percent of our transportation pollution. If we make it easier, more affordable, and more pleasant to take a train or bus, to share rides, or to bike or walk, then more of us will choose to travel without a car or even not own a car at all.
We urge you to exclude certain projects from investment. The program should not invest in highway expansion and conventional road maintenance expenditures that have traditionally been paid for through gas taxes and other “user fees” or general revenues. Our car-dependent transportation system is dangerous, harms our communities, and is the nation’s leading source of global warming pollution. Highway expansion fuels additional driving that contributes to climate change, doesn’t solve congestion, and is expensive. Highway expansion can also cause irreparable harm to communities – forcing the relocation of homes and businesses, widening “dead zones” alongside highways, severing street connections for pedestrians and cars, and reducing the city’s base of taxable property.
Complementary Policies
TCI is a step in the right direction to reduce pollution from transportation. Participating jurisdictions should continue to be ambitious and forward-thinking as they shape the future of transportation in the Northeast and Mid-Atlantic.
TCI states should adopt complementary policies designed to further reduce transportation emissions and build a more modern, cleaner and healthier transportation system. TCI states should:
Require that all new cars sold after 2035 be electric. To accelerate this transition, states should adopt California’s zero-emission vehicle program, pass legislation expanding EV tax rebates, develop a robust network of charging infrastructure.
Require that all transit and school buses be electric by 2030. To accelerate this transition, states should dedicate new resources and technical assistance to help bus operators go electric.
Set a goal of doubling the number of people who walk, bike or take public transportation by 2030. To get there, states should increase investment in public transportation systems, redesign streets to improve safety and accessibility for pedestrians and cyclists, adopt policies to support transit-oriented development and sustainable living, and shift away from policies that prioritize the type of transportation projects, like new highway construction, that have contributed to the problems with our current system.
In summation, we must do all we can as fast as we can. The longer we wait to cut carbon pollution, the more rapidly the planet will warm, robbing our kids and grandkids of the stable climate that we have taken for granted.
Sincerely,
ConnPIRG
Environment America
Environment Connecticut
Environment Maine
Environment Maryland
Environment Massachusetts
Environment New Jersey
Environment New Hampshire
Environment New York
Environment Rhode Island
Environment Virginia
Maryland PIRG
MassPIRG
New Jersey PIRG
New Hampshire PIRG
PennEnvironment
PennPIRG
Rhode Island PIRG
U.S. PIRG |
USPIRG Environment America TCI 2019 Comments.pdf |
11/5/2019 |
Sean |
Burke |
Northeast Clean Energy Council |
Boston |
Massachusetts |
|
Joint Comments on TCI Framework.pdf |
11/5/2019 |
Morgan |
Butler |
Southern Environmental Law Center |
Charlottesville |
Virginia |
Please see the attached comments from the Southern Environmental Law Center on the TCI Framework for a Draft Regional Policy Proposal. Thank you for your consideration of our comments. Please see the attached comments from the Southern Environmental Law Center on the TCI Framework for a Draft Regional Policy Proposal. Thank you for your consideration of our comments. |
2019-11-05 SELC comments on TCI Framework.pdf |
11/5/2019 |
Ashley |
Remillard |
Agility Fuel Solutions |
Costa Mesa |
California |
Please see attached for Agility Fuel Solutions' comments on the draft framework. read more Please see attached for Agility Fuel Solutions' comments on the draft framework. |
Agility Fuel Solutions - Comment Letter re TCI Framework (Nov 5 2019).pdf |
11/5/2019 |
Alex |
DePillis |
Vermont Agency of Agriculture, Food & Markets |
Montpelier |
Vermont |
Attached please find the joint comments of the Vermont Agency of Agriculture and the Vermont Clean Cities Coalition (https://vtccc.w3.uvm.edu/).
These comments were developed in... read more Attached please find the joint comments of the Vermont Agency of Agriculture and the Vermont Clean Cities Coalition (https://vtccc.w3.uvm.edu/).
These comments were developed in coordination and consultation with Vermont Fuel Dealers Association, Dairy Farmers of America, Agrimark Coop, Vermont Department of Public Service, and Energy Vision. We have also shared a draft with the Agency of Natural Resources, and had the benefit of their assistance to understand how the eventual rules might work.
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Comments on framework final.docx |
11/5/2019 |
Georgia |
Murray |
Appalachian Mountain Club |
Gorham |
New Hampshire |
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11-5-2019_AMC_TCI_comments.pdf |
11/5/2019 |
Lindsey |
Mendelson |
Maryland Sierra Club |
College Park |
Maryland |
The comment attached has been endorsed by 779 members and supporters of the Maryland Sierra Club as of November, 5th 2019. Maryland Sierra Club members and supporters sent this comment along with... read more The comment attached has been endorsed by 779 members and supporters of the Maryland Sierra Club as of November, 5th 2019. Maryland Sierra Club members and supporters sent this comment along with individualized messages directly to Governor Hogan. The comment attached is for the record. |
TCI framework Comment from Maryland Sierra Club members and supporters.pdf |
11/5/2019 |
Eric |
DeGesero |
Fuel Merchants Association of New Jersey |
Cranford |
New Jersey |
|
TCI Draft Framework Comments.pdf |
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 |