TCI Regional Policy Design Stakeholder Submissions

How do I access public input once Mou is released Dec 17th? Can you put me on notification of actions list?

The t c initiative would help reduce pollution, expand local and regional transport options, allow for more and cleaner options in transport, and choosing aggressive greenhouse options would significantly help address climate deterioration.

The TCI framework proposes to implement a “regional cap to reduce CO2 emissions, from on-road diesel and finished motor gasoline.” A “cap and invest” program poses significant challenges for the trucking industry. Our industry is fuel neutral; however, we must have access to a readily available, affordable and reliable fuel supply. This means:

• There must be no negative operational impacts on our equipment.
• The fuel supply must be reasonable in cost and marketplace ready.
• There must be no disruption in availability of supply that prevent us from delivering the goods that people need.

While new fuel options that meet these criteria may become viable in the future, today the industry relies on ultra-low sulfur diesel. A cap and invest typically attempts to discourage people from driving by imposing increased costs on them for doing so. These programs only impact those who have a driving choice (e.g. passenger car drivers). Trucking is a non-discretionary user of the highways, delivering the food, clothing, medical supplies and other goods citizens need in support of the manufacturing, agricultural, and retail industries. In Maryland, 93% of communities are solely dependent on trucks to get their goods. What will happen if supply or price are impacted so greatly that trucks cannot deliver the medicine or food that people need?

Richard B. Rudy, Inc. is concerned that a regional cap and invest program cannot work in a small jurisdiction. Maryland is a small geographic state, with well over 50% of all trucks passing through from another jurisdiction. Given our state’s small size, trucking companies do not have to purchase fuel in Maryland. A cap and invest program does not address emissions from the thousands of trucks from other states that travel through Maryland. It only places the economic burden on those local companies that purchase fuel in the state or those states within TCI.

One only needs to look at California to see the impacts on fuel costs of a cap and invest program. According to the Energy Information Administration, the cost of diesel fuel during the week of January 13, 2020 in the state was $3.87 per gallon. The combined average of all other western states during the same week was $3.24 per gallon.

Over the last decade the trucking industry has made incredible strides in reducing all types of vehicle emissions. Under federal law, without any future actions taken by the TCI states, those reductions are slated to continue. For example:

• Over the last 10 years, emissions from heavy-duty diesel trucks and buses have been reduced by:
o 99% for NOx - an ozone precursor
o 98% for particulate emissions
• New commercial trucks being manufactured today reduce fuel consumption and GHGs by approximately 20% when compared to a truck manufactured just in 2010. This is a savings of four gallons of fuel for every 100 miles traveled.
• Going forward, three additional rounds of increasingly stringent federal engine and vehicle GHG emissions standards are slated for new commercial trucks sold nationwide between 2021 and 2027.
• By 2027, commercial trucks will further reduce fuel consumption and greenhouse gas emissions by an additional 25%. Improvements to the trailers pulled by these trucks will provide an additional 9% reduction.

Per the Maryland Department of the Environment’s Greenhouse Gas Emissions Reduction Act Draft Plan of October 2019, emissions from on-road diesel use accounted for only 19% of total transportation emissions in the state in 2014. Given the tremendous strides that have been made, coupled with the cost of fleet replacement and the lack of viable fuel alternatives in the heavy duty trucking industry sector, we believe that any cap and invest program should exclude on-road diesel fuel until viable alternative fuel options exist.

I support TCI because transportation is the largest source of carbon emissions in my state and we have to act on climate.

Asking the TCI to consider Two specific thematics:
1] IT is important to be wary of becoming isolated to one strategic domain: decarbonize the transportation sector through transitioning to an electric powered car bus system etc. This is an important part of the solution though it in effect adds to the GHG emission profile of those places where electric vehicles are manufacturing and transported and where the energy sources for our electric grid is produced. And for the foreseeable immediate future this still will be fossil-fueled.

A society governed by electric-powered vehicles does not automatically enhance smart growth/development, complete streets, dense development, safe pedestrian and bike modes nor will such a paradigm improve transportation equity for currently undeserved and economically marginalized populations. Nothing changes as well in the built environment that even as the GHG emission profile does indeed improve it will manifestly reinforce the mandate that produces more highways and parking lots, parking garages and transit numbing congestion and location and land use development that optimizes access to the single user vehicle.

2] Affected fuels and emission sources. TCI is excluding ocean and waterway shipping, and air transport were to be exempt. It might be timely to include water way shipping in that there is an emerging policy infrastructure emerging for this domain. To Wit:

90,000 ships carry 90% of global trade burning 2 billion barrels of the heaviest—and dirtiest crude. Fuels used in shipping have about 3500 times greater concentrations of sulphur dioxide SO(2) than automotive diesel. Though much shipping is seaborne in international waters much travels through harbors and waterways and ports in RI, NY, MASS, and other TCI signatories. Shipping contributes about 2-3% of global carbon dioxide CO(2). Currently the shipping sector must meet (beginning in 2020) limitations on SO (2) and Nitrogen Oxides NO and particulates as mandated by the UN International Maritime Agency. This is propelling the introduction of using lower sulphur fuels and scrubbers. In order to meet this mandate IMP’s marine environment protection committee proposed slow-steaming an approach that could collaterally cut 750 millions of tons of CO(2) or 2% of CO(2) emission by 2050, according to the International Council on Clean Transportation. Electric battery-powered ferries have operated on a small scale and wind assisted propulsion—(sailing) is an increasing option as well. And Hydrogen technologies are also being considered. Carbon Dioxide CO(2) levels will be the International Maritime Agency’s next focus as the SO(2), NO and PM regulations take hold. So it would be prudent to include this sector in the TCI deliberations.
In order to meet this mandate IMP’s marine environment protection committee.

Ships often use their own engines while they are docked: one study reported by the US EPA noted that a single cruise ship docked for one day emits as much diesel as 34,400 idling tractor trailers. Shore electric power stations were pioneered by the US Navy years ago. In 2007 California diesel emissions regulation requires 70%^ of ships to connect to shore electric power setups. (In 2018 a Swiss shipping firm was fined $650,000 for violations of this rule.) Seattle is allocating $30 mission to expand its shore power stations. China will require all cruise ships to hook up to shore power stations by 2021

Much has been touted about the success of RGGI and I am grateful the region has this in place. However, it has its limitations and TCI is an excellent opportunity to do much better by:
1) The states should pursue an ambitious emissions reduction policy in line with current science, going beyond the modeling scenarios presented. Model and plan for 7.6% reduction in greenhouse gases implemented each year.
2) The states should center their framework and investment strategies in climate justice and social equity to ensure emissions reductions are specifically targeted in communities most impacted by the effects of pollution and climate change.
3) That TCI investments will not only reduce emissions and improve the local environment, but will also result in improved mobility for all with complete streets that allow for safe walking and bicycling, 21st century mass transit, economic growth through green jobs, and increasing health benefits.

Raising gas prices will adversely affect many Rhode Islanders. Most of live paycheck to paycheck and rely on automobiles to get to work. RI has had years to improve public transportation and not done much. I don't see how this will help. This quote sums it up “From a practical standpoint, the RGGI program’s contribution to directly reducing the global accumulation of GHG emissions in the atmosphere is arguably negligible,” wrote researchers of the nonpartisan U.S. Congressional Research Service in a recently updated report about RGGI."

Mainers can not afford a 20 cent tax on fuel. We are already heavily taxed in every way. People have fixed incomes, and most people struggle already to pay for home heating oil. This proposed tax does not benefit anyone other then the state of Maine. The citizen will not get any thing from it. No fuel tax!

The rapid climate change due in large part to rapidly increasing human fossil fuel use is an existential threat to all life on earth. Thus all ways of reducing fossil fuel use are urgently needed. Improving publicly available mass transit and regional transit systems is an excellent way to do this. In addition, it will make affordable transportation readily available to many more people. I have traveled extensively in other parts of the world, many of which have far better public transit systems then does the United States. The city of Budapest, Hungary is an excellent example. As a city of 2 million people, not wealthy, it has nonetheless built extensive, readily available subway, light rail, and electric bus mass transit that is affordable. Even large cities in India are rapidly developing local and regional affordable mass transit such as light rail systems. Where available they are preferred transport given how difficult it is to drive automobiles. I grew up in the Boston, Massachusetts area and so was used to one of the earliest and most extensive subway and light rail public transit systems in the United States. It is still very effective.