TCI Regional Policy Design Stakeholder Submissions

Gasoline and diesel powered vehicles are collectively the largest source of carbon dioxide emissions in this country. In as much as our federal government apparently believes that excessive amounts of carbon dioxide being released into the atmosphere is a good thing, it is incumbent on state governments to take action to reduce the emissions. I am in favor of the TCI states developing a regional transportation policy to address this problem. Responsible government action is desperately needed at the state level in light of the federal government's abysmal environmental record. Thank you.

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.

We need cleaner air for everyone!
We also need better transportation in the state of DE.

Why oh why does central Vermont get left out of the hearings again. A hearing could very easily be held at VTC in Randolph or any number of places in Montpelier. All of the locations are an hour or more from where I live in Tunbridge. On school nights this makes it nigh on to impossible to attend. I would be happy to help you find a location.

Read my lips. NO NEW TAXES. A tax, in my opinion, includes the proposed “Transportation Climate Initiative” cloaked as a carbon fee.

I’m a young person. I’m afraid of climate change. It’s time to do something.

The Transportation Climate Initiative (TCI) is Vermont’s chance to do just that: take a meaningful stance against climate change. It is great to see that Green Mountain Power will have 100% renewable energy in the next decade. This, in and of itself, however, is not enough. According to the TCI webinar hosted on December 17, 2019, 43% of the carbon dioxide emissions from the TCI region come from transportation. That is almost twice as much as from electrical power. Most Vermonters cannot afford an electric car, with or without subsidies from the government. That means the 43% of our emissions that come from transportation will continue to be emitted even if we have a carbon-free electrical grid.

But TCI is more than just a way to do something. It has the potential to be an effective policy. As per the executive summary, the TCI locks us into making a significant reduction in emissions. While these reduction goals are theoretically feasible without TCI, the initiative would eliminate any uncertainty. Given the volatility in our federal government, it is important that Vermont takes a stand and does not rely on federal policy to make these changes.

Additionally, by entering into TCI with an entire region of states, Vermont significantly reduces the potential for a harm to the economy. Look no further than the Regional Greenhouse Gas Initiative (RGGI) a similar cap-and-trade program which Vermont is already involved in. RGGI has already contributed 44,700 years of additional full-time employment, $5.7 billion in public health benefits, and saved customers a combined $773 million in energy bills, according to a report by economists at Analysis Group. RGGI, however, does not cover the emissions from transportation. As mentioned above, 43% of carbon emissions in the region come from transportation, making TCI an effective plan to address emissions not captured by RGGI.

As per the TCI Memorandum of Understanding (MOU), the program will invest its proceeds into a variety of programs such as “air quality, public health, resilience, and more affordable access to clean transportation alternatives.” Investments in these sectors all have the potential to positively impact the community and economy. Pollution from cars can contribute to asthma attacks and other health issues. Healthier people have lower medical bills and miss fewer workdays, which can help bolster Vermont’s economy.

All of this is not to say that TCI is perfect. There is a completely valid fear that gas companies will simply offload the increased cost of operation onto the consumers. The MOU mentions the importance of ensuring that the program benefits those who “disproportionately bear the costs of the current transportation system” or “impacts of vehicular pollution and climate change.” Still, without more concrete plans for benefitting these communities, I fear that TCI will only be an additional burden on those who are already struggling with climate change. As such, when Vermont agrees to sign on to TCI, it is critical to have a robust plan to help these communities, including provisions such as rebates and investments in public services. There are ways to make sure that TCI is equitable and given that equity is a listed priority (3b) of the MOU, I do not think fear of increased gas prices should be an impediment to joining TCI.

Like many of my peers at Middlebury College, I was drawn to Vermont for its beautiful scenery and landscape. Climate change has the potential to change our state forever through warmer weather and increased flooding. I hope that when I have children, they will have the opportunity to see Vermont as I see it: vibrant and full of natural beauty. TCI is Vermont’s chance to act on climate before it’s too late, protecting our state for the next generation.

It is of the utmost importance that we expand and modernize public transportation. Private transportation with one person per automobile is a major contributor to greenhouse gases. Inter-city and inter-town public transportation is extremely slow and unreliable. Commuter rail needs to be converted from diesel to electric. Battery electric buses need to replace gas buses. Municipal fleets need to be electrified. Fares need to be accessible to the people who need affordable transit the most, without expectation of public transit paying for itself. People need to get to work. Please make the public transit element of climate justice your highest priority. Thank you, Denis Dettling Kalthofer

By changing the transportation industry we can help mitigate the Climate Emergency. Hopefully more and better transportation will be accessible to people where it was not before.

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.