TCI Regional Policy Design Stakeholder Submissions

Hi,

I am a resident of Vermont and I am opposed to the creation of the TCI. I attended a meeting, one of several held around the state, where we were told that this regional compact was based on another successful regional compact, the Regional Greenhouse Gas Initiative (RGGI). We were lead to believe that RGGI was successful in it's mission and that TCI would be as well by building off these successes. In fact, RGGI has failed to reduce greenhouse gas emissions but instead has created a tax that emitters pay to emit greenhouse gases. Like most corporate taxes these days the tax ends up being pushed onto consumers, while the benefit of the tax is to support home upgrades to reduce energy usage for heating and cooling, the end result is a failure of it's promoted mission. From the presentation given, it was clear that TCI would do a similar thing by taxing those who import gasoline and diesel into the participating states which would then cause the price at the pump to increase. So the tax on the importers would be passed directly onto consumers. While the mission of TCI is commendable, to reduce the impacts of climate change in the transportation sector and to use the funds raised by the tax to support battery powered and other vehicle purchases by consumers to lower the amount of emissions from the transportation sector. This is an important goal to have and to realize. I am not convinced that creating a bureaucracy to increase taxes which may or not be successful in it's goals is the best solution. Are there alternatives to this approach that can have the same effects? A direct tax at the pumps that is designated for the support of transitioning our vehicle choices away from low mpg and high emissions ones? I am asking for a better and more well-thought out solution or an honest approach to the citizens of those states attempting to join this compact. This is a tax that will be directed onto consumers. Can we accomplish the same things with a direct tax on gasoline and diesel that is set aside in a fund to support this work? The gasoline and diesel market in our state is already a mess with prices much higher in the Chittenden County area even after the main owners of gas stations were sued by the state for price-fixing. Can we trust these people to not price fix when they are passing on a tax to us? A region-wide tax at the pump that is protected for its desired use is a much better way to accomplish our goals and doesn't try and pass off the plan as not a tax when it clearly is a direct tax to anyone who drives a vehicle.

Please oppose TCI until the plan is modified to be truthful to consumers and nullifies any possibility that the monopolies that already cheat consumers to do so in the name of minimizing the impacts of climate change. We must shift our transportation sector away from the use of fossil fuels which will not last forever and have negative impacts on our environment, TCI as it was laid out to the public is not the best way to do this.

To whom it may concern:

I would like to express my support for a regional policy for low-carbon transportation that will encourage better public transportation options and reduce the production of transportation-related pollution. The contribution of carbon emissions from to climate change is indisputable at this point, and public investment in the Transportation and Climate Initiative (TCI) is an important step in reducing our greenhouse gas production. More and better public transportation options will take more vehicles off the road, and will help not only the environment but also improve the health of Pennsylvanians. Carbon emissions contribute to respiratory health problems in adults but especially children, increasing rates of asthma. In fact, the rise in asthma in children in the US has paralleled the rise in carbon emissions. This would be another benefit of the TCI.

Thank you,
Dr. Levon Utidjian, MD, MBI

I am thrilled to anticipate the joining of the states in our region (in cooperation with whatever organizations that can help) to implement the reduction of carbon emissions. Way to go!

As a resident scientist in PA, I submit that reducing pollution from transportation is a key component to reducing Pennsylvania's air-pollution emissions. As one of our leaders, I ask that you choose the most aggressive greenhouse-reduction target that climate scientists urge us to adopt. We must do this as the clock is ticking. Public policy must also prioritize clean investments in areas, particularly our cities, that are overburdened by pollution and/or for those communities that don’t have access to transportation choices like mass transit. I believe that public transit investments should be made with TCI proceeds.

TCI is a critical measure to address the climate emergency. The affordability argument from Governor Scott is a blindered understanding of the financial and human trauma that will result from inaction on the climate. TCI helps bring our energy money home by reinvesting it in green local alternatives and provides the financial wherewithal to address our biggest challenge, transportation. That it is a multi-state initiative means it will be of significant impact and will put VT in line with all our neighbors, except Governor Sununu. Pass this now.

I fully endorse the comments previously submitted by Roger Caiazza, which can be found at https://pragmaticenvironmentalistofnewyork.files.wordpress.com/2020/02/caiazza-tci-comments-february-2020.pdf
He concludes his comments with the following:
Due to the lack of sufficient detail on the TCI modeling results I was unable to provide substantive comments based on that information. My comments and recommendations are instead based on my experience and evaluation of carbon pricing programs in general and RGGI in particular. Any carbon pricing program limited to certain jurisdictions and sectors will have unavoidable leakage problems. The investment dollars per ton of CO2 reduced for New York programs in RGGI have not been able to meet the SCC cost effectiveness threshold of $50/ton.
The fact that the EPA emission numbers for an average gasoline vehicle indicate that any rebate over $259.98 exceeds the $50 SCC cost effectiveness threshold suggests that TCI investments will be even less effective. Another problem with any carbon pricing scheme is that revenues over time go down at the same time the reduction implementation costs go up. There is a fundamental problem with carbon pricing schemes because there are not many control options available for existing sources. I believe this will be even more of a problem for the TCI affected sources. There should be concerns that the TCI carbon pricing theory will not match reality especially because the affected sources have no prior experience with this pollution control approach. As a result of those concerns, I recommend a cautious, measured approach for the cap, trajectory and stability mechanisms.

I certainly understand the desire for all public servants associated with the TCI to act with the best of intentions and I appreciate your willingness to serve the public to the best of your abilities. I ask you to please consider that I am a PhD Chemist with decades of experience and knowledge about the effects of CO2 concentrations on climate change. I have applied to the IPCC as an editor for the Assessment Report 6, I have spoken about the chemistry behind CO2 driven climate change all over the country, and I have a level of expertise in this area that stems from decades of research, educational training and experience.

I am commenting here to make sure that you are made aware that main stream media accounts of CO2 and climate change are not accurate. It is a scientific fact that CO2 both absorbs and radiates infra red energy. The extent that this particular attribute of CO2 influences global temperatures is still a matter of considerable debate - despite what you are being told and what you read in the media. Climate change predictions rely on secondary feedbacks to account for the vast majority of predicted warming. These feedbacks are controversial amongst those of us who look at the issue with complete intellectual honesty. The feedbacks may lead to more warming, but they may not. When we hear statements like the science is settled and 97% of scientists agree that CO2 causes warming, these statements are only true for the RELATIVE impact of CO2 on temperature and climate. The absolute influence of atmospheric CO2 concentration is absolutely NOT settled, NOT quantified and NOT well understood. How the impact of CO2 concentration on temperature compares with periodic changes in ocean circulation, solar activity, and geothermal fluctuations is still very much a matter for debate. The coming decades may see warming due to increasing CO2 concentrations, but they may also see cooling due to ocean and solar effects despite rapidly increasing CO2 concentrations in the atmosphere. There is absolutely not a scientific consensus on this point, and when people try to extend the scientific consensus from a relative impact of CO2 to an absolute impact, they are being disingenuous.

Given this situation, I ask you to abandon plans to limit CO2 emissions. Doing so only limits the ability of our society to live prosperous lives. The societal benefits from this initiative are insignificant, but the societal detriments are very significant. I see a high likelihood of unintended consequences that end up doing far more damage to the environment than business as usual CO2 emissions. For this reason I urge you to abandon this plan.

Have become sick & tired of hearing carefully reasoned, public interventions to address market failures WRT unpriced externalities (think: TCI, Essex Plan) framed as nothing more than taxes. Both of these proposals included side payments to the vulnerable to soften their landing in a bumpy future. Is no one able to think and talk in terms of net outcomes? You're better than that.

Try to think analogously about this. You acted on gun control legislation because , God forbid, a mass shooting should happen on your watch. The next Irene IS out there, you and I just don't know when and how bad. Trust me, you want to be on record as having excercised some vision and initiative on this one.

Please vote for Vermont inclusion in the TCI.

Increases in gross domestic product (GDP), disposable personal income (DPI) and employment;
Public health benefits from cleaner air valued at $3 billion - $10 billion; and
A 20-25% reduction in greenhouse gas pollution from cars and trucks.
The Vermont-specific benefits include:2

$18 to $80 million in annual revenues to invest in low-carbon transportation options;
More money from the program each year than Vermonters contribute; and
The opportunity to make the state more affordable for low-income and rural Vermonters by lessening dependence on imported, polluting and expensive fossil fuels.