TCI Regional Policy Design Stakeholder Submissions

Reducing pollution from transportation is a key component to reducing New Jersey's emissions.
Public transit investments that could be made with TCI proceeds would be valuable.
Choose the aggressive greenhouse gas reduction target that the most recent climate science tells us we need.
The policy must prioritize clean investments in areas overburdened by pollution and/or for those who don’t have access to transportation choices.

Maryland Motor Truck Association (MMTA) is a non-profit trade association that has represented the trucking industry since 1935. In service to our 1,000 members, MMTA submits the following comments in response to the Draft Regional Policy Proposal by the Transportation Climate Initiative of the Northeast and Mid-Atlantic States.

Over the past decade, MMTA has worked closely with the Maryland Department of the Environment and the Maryland Energy Administration to design a series of programs to voluntarily reduce commercial motor vehicle emissions. These include grant programs for the purchase of alternative power units, financial assistance to help companies replace older model diesel trucks with clean diesel, natural gas and electric powered vehicles, and the “Idle Free MD” outreach campaign encouraging drivers to turn off their engines and avoid idling whenever possible. Yet the question remains, “How do we achieve the goals in Maryland law – a 40% reduction in greenhouse gas emissions by 2030 – as well as the other stated goals of TCI without major disruptions to business?”

There is clearly no silver bullet that will achieve these goals. To that end, MMTA encourages a multi-faceted strategy that includes:

• A continued focus on voluntary measures backed by financial incentives to assist companies with adoption of cleaner technologies, such as the Port of Baltimore Dray Truck Replacement Program. This program not only helps to reduce air pollution and greenhouse gases associated with the transport of goods to and from the Port of Baltimore, but also supports TCI’s stated goals of equity and environmental justice.
• An approach that considers all fuel options – including some continuation of fossil fuel use, such as clean diesel, natural gas, and biofuels as bridge fuels while other technologies are enhanced to meet the operational needs of the trucking industry. Both biodiesel and renewable diesel fuel are capable of significantly reducing greenhouse gas emissions without the major infrastructure investment that is required for other fuel sources.
• Bid preferences on state contracts for motor carriers that are partners in the Environmental Protection Agency’s SmartWay program and have taken steps to reduce their greenhouse gas emissions voluntarily.
• Investment in transportation infrastructure improvements that promote free flowing mobility of goods. Traffic congestion results in wasted fuel and increased greenhouse gas emissions. Last year the American Transportation Research Institute updated its “Cost of Congestion to the Trucking Industry” report. On the National Highway System alone, traffic delays cost the industry almost 1.2 billion hours, or the equivalent of 425,533 commercial truck drivers sitting idle in traffic without moving for an entire year.
• A focus on the development of more fuel-efficient vehicles. After all, it is pollution, not traveling, that is the concern.

The TCI framework proposes to establish a system to “cap emissions of carbon dioxide from the combustion of the fossil component of finished motor gasoline and on-road diesel fuel in the region.” 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 products 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 (or it’s closely related cousin, a “carbon tax”) 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.

MMTA is also concerned that the cap and invest programmed described in the TCI framework states, “Affected fuel would include fuel destined for final sale or consumption in a TCI 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.

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 99% for NOx - an ozone precursor - and 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 – particularly for the long-haul, heavy duty trucking industry sector – Maryland Motor Truck Association believes that any cap and invest program should exclude on-road diesel fuel until viable alternative fuel options exist.

Earth is being exploited by those who are fracking, drilling for oil, and removing other natural resources. It is imperative that the carbon emissions be capped as soon as possible and other means of transportation developed as well as other sources of natural energy. I fully support the initiatives and goals of TCI.

Maryland should make a make a firm
commitment to adopt a regional transportation
policy that achieves a minimum 40 percent
reduction in transportation sector climate
pollution by 2030, to keep us on track to meet
the climate goals updated by the General
Assembly in 2016.
Investment and policy decisions should be
made based on pollution reduction and
equity goals, as well as robust engagement
opportunities from the public‒particularly
those most overburdened by transportation
pollution and undeserved by our current
transportation system. Please support the Transportation and Climate Initiative.

You cannot clean up the air by taking money from the drivers of relatively clean cars and diverting it to pay for trains and buses that generate more pollution per unit of productivity (passenger miles) than the cars. If you really want to reduce pollution, you need to reduce congestion. Clearly, buses and trains don’t lower highway congestion. The technology exists today to reduce congestion AND enhance personal mobility, without killing the economy. The best tool in our toolbox is congestion pricing.

https://www.concordmonitor.com/Trains-and-clean-air-29076184

I am strongly in favor of the TCI and urge Massachusetts to implement it regardless of how many other states join now vs. join later.

The TCI should apply to ALL transportation fossil fuels including for personal cars, company cars and vans, corporate fleets, on-demand transportation (taxis, etc.), delivery vans, trucking, freight trains, municipal and state-owned vehicles, federal vehicles within the geographic scope of the TCI, mass transit vehicles -- including ferries and school buses -- whether public or private, personal watercraft, fishing boats, cruise ships, freight shipping, other freshwater and saltwater transportation, aircraft of all kinds including drones, and all other fossil fuel use for transportation.

The goal of the TCI isn't to stop people from traveling, but rather to shift people toward lower carbon transportation. Many people currently have no alternative to driving. As a matter of equity, it's important for much of the monies raised by TCI to be applied to rebates and subsidies for electric or plug-in hybrids especially in rural areas, for public transit everywhere, and where possible, for small businesses both on-shore and in local waters. As a further matter of equity, we should take some of the cost savings from improved health due to reduced fossil pollution and apply it to further assist people who are hit hardest by fuel price increases due to the TCI, whether through additional support for greener transportation and mass transportation, or in other ways such as increased health care subsidies.

Climate change is a huge problem. The TCI is just one part of the solution. We should implement the TCI while also implementing many other solutions. Preferably some that bear fruit faster than the TCI, since Massachusetts is faltering right now due to slow and failing transportation.