1/17/2020 |
Matthew |
Genaze |
Activist |
Cambridge |
Massachusetts |
I request that your state formally join the plan to reduce emissions.
We have scientific data and long standing evidence of the damage that will be caused by allowing such an action... read more I request that your state formally join the plan to reduce emissions.
We have scientific data and long standing evidence of the damage that will be caused by allowing such an action to occur. One of the key roles of government is to preserve public safety. Willfully ignoring clear evidence of an impending catastrophe is a dereliction of duty. Scientists have worked for decades to assemble an incontrovertible body of evidence related to our changing climate, and ignoring that information is insidious. Future generations' resources, health and prosperity is dependent on us acting immediately, significantly and broadly.
I demand that the policy has a strong component of equity by prioritizing clean investments in areas overburdened by pollution and/or for those who don't have access. |
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1/19/2020 |
Kevin |
McAleer |
Activist |
Manhasset |
New York |
The transportation sector is the largest source of planet warming greenhouse gas emissions both regionally and nationally. As such, it is imperative that we reduce emissions from this sector as... read more The transportation sector is the largest source of planet warming greenhouse gas emissions both regionally and nationally. As such, it is imperative that we reduce emissions from this sector as quickly as possible to insure this planet is safe and livable for generations to come. I request that the state of New York heavily collaborate with other states in the region and the District of Columbia to accomplish the goals of this initiative as it will help our economy adapt to the 21st century and improve the quality of our environment. I am grateful that this initiative enjoys broad support across the political spectrum and hope to see more examples of this in the future. Finally, it is extremely important that the investments and actions created by this initiative benefit overlooked communities that are often hit the hardest by pollution and other forms of environmental degradation. |
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1/19/2020 |
Karen |
Carlisle |
Activist |
NY |
New York |
I am a jewelry designer and an activist, clean water and clean air is a human right. I have suffered from allergies my entire life, so it’s a health issue for me also. As a NY resident I’m... read more I am a jewelry designer and an activist, clean water and clean air is a human right. I have suffered from allergies my entire life, so it’s a health issue for me also. As a NY resident I’m imploring all of my NY representatives to please join the plan to reduce emissions.we must support policies with strong components of equity by prioritizing clean investments. I appreciate the bipartisan nature of this project. Please take a look at what is happening in Australia, living in DENIAL is no longer an option, a cleaner future is the only solution at this point. Let us not pretend and act like the mainstream media , the reality show bores me! The game is up! |
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2/18/2020 |
Temistocles |
Ferreira |
Activist / Artist/ Parent/ Voter / Amherst MA Public Schools |
Hadley |
Massachusetts |
We need to stop cap these emissions for the sake of our children and planet We can cut poverty and pollution at the same time. I urge you to move forward with a regional program that prioritizes... read more We need to stop cap these emissions for the sake of our children and planet We can cut poverty and pollution at the same time. I urge you to move forward with a regional program that prioritizes the needs of communities overburdened with pollution and underserved in mobility options |
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2/27/2020 |
Mike |
Winslow |
Addison County Regional Planning Commission |
Middlebury |
Vermont |
The following comments are on behalf of the Addison County Vermont Regional Planning Commission’s Transportation Advisory Committee to offer public input on the draft Transportation Climate... read more The following comments are on behalf of the Addison County Vermont Regional Planning Commission’s Transportation Advisory Committee to offer public input on the draft Transportation Climate Initiative (TCI) Memorandum of Understanding (MOU) for a regional program to establish a cap on global warming pollution from transportation fuels. We support the goal of limiting greenhouse gas emissions from the transportation sector, and offer the following comments to improve the draft MOU.
In apportioning the regional cap to TCI jurisdictions, the final MOU must take into account existing efforts to curb transportation related greenhouse gas emissions. For example, jurisdictions that already invest heavily in mass transit should not be penalized for prior investments that have reduced emissions.
Section 3 of the MOU discussing Investments and Equity lacks detail. The costs of the program are fairly clear, but the benefits, which should be spelled out in this section, are still vague. It will be extremely important in building political support for the MOU that constituents have a better idea of how the revenue raised will make an impact in their lives.
To that point, it is very important to our constituents that efforts be made to mitigate the impacts of the TCI on low-income populations in rural areas. In rural areas like Addison County, our poorest community members often live far from populations centers. In purchasing vehicles, they rely upon second-hand cars and trucks, and the availability of fuel-efficient vehicles at a low price point in that market is constrained. Some of the revenue raised by the TCI should go to assist this population in transitioning to low emission vehicles and to offset the economic hardship they will face when the cost of fuel increases.
The draft MOU lacks detail on how a Participating Jurisdiction would leave the TCI (Section 5B) and what would happen to allowances auctioned on their behalf. Would those allowances still be honored as in Section 2J – “Participating Jurisdictions shall accept allowances sold or originated in other Participating Jurisdictions”?
We thank you for the opportunity to comment on the draft MOU.
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8/19/2019 |
Joanne |
Ivancic |
Advanced Biofuels USA |
Frederick |
Maryland |
Advanced Biofuels USA has two items to share. One is suggestions for fleet operators (city, county, state, region, businesses, organizations, universities, etc.) to defossilize fuel use as soon... read more Advanced Biofuels USA has two items to share. One is suggestions for fleet operators (city, county, state, region, businesses, organizations, universities, etc.) to defossilize fuel use as soon as possible in the fleets and equipment that they currently have. It includes descriptions of renewable fuels such as ethanol and biodiesel blends, as well as renewable diesel and prioritized patronage of airlines that use renewable fuels. |
Fleets article v3 AdvancedBiofuelsUSA comments to TCI 2019.pdf |
8/19/2019 |
Joanne |
Ivancic |
Advanced Biofuels USA |
Frederick |
Maryland |
Continuing Advanced Biofuels USA comments: our proposal for a Disappearing Carbon Tax on the non-renewable portions of transportation fuel with proceeds prioritized to increasing the availability... read more Continuing Advanced Biofuels USA comments: our proposal for a Disappearing Carbon Tax on the non-renewable portions of transportation fuel with proceeds prioritized to increasing the availability of cleaner, less polluting, less expensive renewable and bio-fuel in low income and high pollution areas. |
Carbon-User-Fee-Proposal-January-2019-v1-FINAL.pdf |
12/4/2019 |
Joanne |
Ivancic |
Advanced Biofuels USA |
Frederick |
Maryland |
I would like to submit a PowerPoint and text from Advanced Biofuels USA’s recent presentation about biofuels as the quickest way to reduce the greatest amount of greenhouse gases for the lowest... read more I would like to submit a PowerPoint and text from Advanced Biofuels USA’s recent presentation about biofuels as the quickest way to reduce the greatest amount of greenhouse gases for the lowest expense at a presentation for the Nov19 Meeting of Maryland Commission on Climate They can be found at: https://advancedbiofuelsusa.info/advanced-biofuels-usas-presentation-to-marylands-commission-on-climate-change-mitigation-work-group-on-benefits-of-biofuels-in-climate-change-mitigation-plan/
I will also attach the files one (the PowerPoint) in this submission and the text that goes with it in the next.
Essentially, these ideas address the 89% of vehicles in 2030 that, according to materials provided in the Draft Greenhouse Gas Reduction Plan, will still require liquid fuels. It also addresses fueling vehicles that are passing through Maryland on major highways that will also require liquid fuels. |
AdvancedBiofuelsPresentationMCCC Mitigation WG 19 1119 Short Form.pdf |
12/4/2019 |
Joanne |
Ivancic |
Advanced Biofuels USA |
Frederick |
Maryland |
I would like to submit a PowerPoint and text from Advanced Biofuels USA’s recent presentation about biofuels as the quickest way to reduce the greatest amount of greenhouse gases for the lowest... read more I would like to submit a PowerPoint and text from Advanced Biofuels USA’s recent presentation about biofuels as the quickest way to reduce the greatest amount of greenhouse gases for the lowest expense at a presentation for the Nov19 Meeting of Maryland Commission on Climate They can be found at: https://advancedbiofuelsusa.info/advanced-biofuels-usas-presentation-to-marylands-commission-on-climate-change-mitigation-work-group-on-benefits-of-biofuels-in-climate-change-mitigation-plan/
I will also attach the files. Attached is the text that goes with the Power Point slides that were sent in a previous submission in this submission.
Essentially, these ideas address the 89% of vehicles in 2030 that, according to materials provided in the Draft Greenhouse Gas Reduction Plan, will still require liquid fuels. It also addresses fueling vehicles that are passing through Maryland on major highways that will also require liquid fuels. |
Presentation for Nov19 Meeting of Maryland Commission on Climate Change Mitigation Working Group Advanced Biofuels USA v4.pdf |
12/20/2019 |
Joanne |
Ivancic |
Advanced Biofuels USA |
Frederick |
Maryland |
We am pleased to hear from the TCI webinar that only the fossil component of motor gasoline and diesel combustion would be counted; not the renewable portion; and that you are working on... read more We am pleased to hear from the TCI webinar that only the fossil component of motor gasoline and diesel combustion would be counted; not the renewable portion; and that you are working on incorporating into the models a more accurate reflection of the source of the power for electric vehicles (coal, natural gas, renewable natural gas, hydropower, solar, wind, etc.) taking into account the various state programs. We also appreciate that you will be factoring in the additional demand for electricity that achieving the electrification goals will produce.
We note, however, that the list used for modeling investment did not include investment in infrastructure for cleaner renewable fuels such as high blends of high octane ethanol or biodiesel, renewable natural gas or renewable diesel. These options, although not included in the investment-related modeling, could be an option as member states determine how they design their programs and should be a variable that you take into account. It appears that the modeling also does not factor in variables related to the potential adoption of renewable transportation fuels and the effect that would have on reducing the greenhouse gas emissions and other pollution caused by fossil fuel combustion. We hope that you seek out experts in this field as you and, the states and DC continue to revise and improve materials being used to discuss and implement climate smart transportation improvements. |
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10/29/2019 |
Mark |
Smith |
Advanced Fuel Solutions, Inc |
Newark, |
Delaware |
Engine manufactures continue to refine and improve the entire fuel system to meet the US EPA air quality mandates set forth for particulate and greenhouse gases emissions. These improvements... read more Engine manufactures continue to refine and improve the entire fuel system to meet the US EPA air quality mandates set forth for particulate and greenhouse gases emissions. These improvements include technologies in both gasoline and diesel vehicles engines.
I am not opposed to electric vehicles as a matter of an individuals choice of options for transportation. However, I am opposed to subsidizing only electric vehicles at the expense of other fuel efficient modes of transportation.
Bio Fuels must play an important role in reducing the carbon foot print of gasoline and diesel to further reduce both NOX and particulate matter. Bio Fuels are readily available in the supply chain today while the electric vehicle charging stations are far from being available.
If a tax is charged on gasoline and diesel, an equal amount of the monies collected must be proportionally allocated to electric, gasoline, diesel, and renewable energy sources.
Thank You
Mark Smith |
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11/8/2019 |
Rebecca |
Hill |
Adventures at Yankee Fleet |
Gloucester |
Massachusetts |
To Whom It May Concern: TCI is nothing more than a backdoor attempt to institute a carbon tax without a vote by our lawmakers. Your aim is clear. You want to make fuel so expensive that... read more To Whom It May Concern: TCI is nothing more than a backdoor attempt to institute a carbon tax without a vote by our lawmakers. Your aim is clear. You want to make fuel so expensive that taxpayers will be forced to walk and bike to work. Consumers will soon be paying more at the pump to support increased government spending. For normal people, this is a tax. State Rep. William Straus, the House chairman of the Transportation Committee, recently described TCI as a gas tax, saying “All states raise their gas tax the same amount at the same time and agree not to call it a gas tax, but I think the public is smarter than that.” According to the Massachusetts state constitution, all state taxes must originate from the House. Gov. Charlie Baker does not have authority to unilaterally raise taxes. There must be an open and transparent legislative process. on the details of the agreement. |
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10/14/2020 |
Jennifer |
Valentine |
advocate |
Massapequa Park |
New York |
please include:
A cap on carbon emissions of at least 25% by 2032
An increase in the minimum investment in overburdened and underserved communities (>35%)
Investments be... read more please include:
A cap on carbon emissions of at least 25% by 2032
An increase in the minimum investment in overburdened and underserved communities (>35%)
Investments be put towards active transportation like better sidewalks, bicycle infrastructure, and high quality public transit |
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3/4/2020 |
Amy |
Jones |
Affected Community Resident |
New Castle |
Delaware |
Involve the community in any decision-making processes FIRST! — and that the community will be the FIRST!
Agency goals should be to establish ways to talk more directly with... read more Involve the community in any decision-making processes FIRST! — and that the community will be the FIRST!
Agency goals should be to establish ways to talk more directly with environmental justice communities, which can be “co-opted” by outside groups pushing their own agendas. “We need to peel past that and really get to the communities themselves and make sure that they’re hearing us—and, as importantly or more importantly, we’re hearing them.” Garvin says individuals DNREC has interacted previously with on issues of environmental justice. The event was not promoted publicly, but that it is not a closed meeting.
Please stand up for fence-line communities in the TCI process in the Mid-Atlantic.
Why am I and others just hearing about this Policy in the community after the fact?
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2/28/2020 |
Don |
Thoren |
AFPM |
Washington |
District of Columbia |
AFPM is a trade association representing high-tech American manufacturers of nearly 90% of U.S. supply of gasoline, diesel, jet fuel, other fuels and home heating oil, as well as nearly all the... read more AFPM is a trade association representing high-tech American manufacturers of nearly 90% of U.S. supply of gasoline, diesel, jet fuel, other fuels and home heating oil, as well as nearly all the petrochemicals used as building blocks for thousands of vital products in daily life. AFPM members make modern life possible and keep America moving and growing as they meet the needs of our nation and local communities, strengthen economic and national security, and support more than three million American jobs. |
AFPM Comments to Georgetown Climate Center.pdf |
2/20/2020 |
Mark |
Smith |
AFS |
Newark |
Delaware |
Truck and cars purchasing fuel supply road taxes to maintain the infrastructure of our Nations Roads and Bridges. I am not in favor of subsidizing the purchase of EV's with Cap Dollars from... read more Truck and cars purchasing fuel supply road taxes to maintain the infrastructure of our Nations Roads and Bridges. I am not in favor of subsidizing the purchase of EV's with Cap Dollars from the TCI program.
Renewable fuels must play a part in this program and should be given equal portion of the Cap Dollars that are collected.
Thank You |
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2/25/2020 |
Lori |
Sveda |
AFSCME |
Albrightsville |
Pennsylvania |
“…design a regional low-carbon transportation policy proposal that would cap and reduce carbon emissions from the combustion of transportation fuels through a cap-and-invest program or other... read more “…design a regional low-carbon transportation policy proposal that would cap and reduce carbon emissions from the combustion of transportation fuels through a cap-and-invest program or other pricing mechanism… [and]… to complete the policy development process within one year, after which each jurisdiction will decide whether to adopt and implement the policy.” |
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11/5/2019 |
Patrick |
Wood |
Ag Methane Advisors |
Montpelier |
Vermont |
The world is facing a climate emergency. TCI has the potential to have a very large and beneficial impact in reducing GHG emissions from a highly populated region of the US. The Cap and Invest... read more The world is facing a climate emergency. TCI has the potential to have a very large and beneficial impact in reducing GHG emissions from a highly populated region of the US. The Cap and Invest model is a proven and effective model to achieve these reductions but only if it’s done right. The cap must be set at a level that creates financial incentives to reduce emissions. In simple terms it means the price of carbon should be high. This will translate to higher fuel costs and incentivize use of lower carbon fuels. If the cost of carbon is high TCI will generate substantial funds to invest in GHG reductions. That basic framework is well thought out and sound.
However, TCI is based on the model of RGGI. A historical look at RGGI shows that it has not been nearly ambitious enough. RGGI has accomplished a lot but could have accomplished much more. The targets of TCI should be ambitious. The cap should be set aggressively low. As the US is pulling out of the Paris climate accord it is up to subnational jurisdictions like the TCI states to create policies that will lead to the emissions reductions we need to avoid the worst impacts of climate change. California has been aggressive about this for more than 10 years. New York recently passed S.6599 which has aggressive climate targets. Other TCI states should follow suit to be at least as aggressive.
My firm helps dairy farms with methane digesters generate revenue by selling environmental commodities like carbon offsets, RINs and LCFS credits. Over the past several years the price of carbon in California’s Low Carbon Fuel Standard (LCFS) has been ~$190/mtCO2e. Dairy digester projects that are connected to common carrier pipelines around the US can sell renewable natural gas into California’s LCFS market. This market provides substantial incentives to digester projects and many are being built to access this market. These projects provide a very low carbon fuel. By avoiding methane emissions that would otherwise be released to the atmosphere and turning that methane into RNG the projects create substantial climate benefits and can have co-benefits that help dairy farms improve water quality and nutrient utilization. In addition, RNG can be used in heavy duty vehicle fleets (trucks, buses, etc) for which electrification is not as viable as it is for passenger cars. TCI should provide incentives for methane digesters to produce renewable low carbon fuels in the TCI states.
At a recent TCI workshop state staff leading the TCI process said that they were considering biofuels but that they have limited resources, and developing TCI at all is “a very heavy lift”. TCI states should commit more employees to development of TCI. This is a prudent investment in the long term health and viability of the people and ecosystems of TCI states. State staff should not be stretched so thin that they cannot devote the time required to thoroughly develop such a necessary program. Of course the vast majority of TCI auction revenues should go to investments in the states, but states will also need staff to manage and implement the program. Speaking from 10+ years in carbon markets we encourage TCI states to make sure that their programs are well staffed with enough highly trained people. This is crucial to having the markets function well to achieve their goals.
Biomethane (aka RNG produced from methane digesters) is a unique form of biofuel. Unlike most ethanol and some forms of biodiesel it is produced from a waste and it’s production does not lead to land use change or impacts to the food supply. Biomethane is produced by dairy, swine and poultry farms of which there are many in TCI states. These segments of the livestock agriculture industry have a major impact on the rural communities (human and environmental) in TCI states. TCI’s model rule should provide specific incentives for production of biomethane from livestock manure. This would help achieve the necessary GHG reductions while supporting a growing industry in TCI states that provides economic benefits to the people and ecosystem service benefits to the environment in the TCI region.
NY S.6599 is an ambitious cap and trade program that will exclude “biofuels” but include livestock anaerobic digestion projects. Since TCI states are home to many dairy and other types of livestock farms they can support their communities and achieve GHG reductions by providing specific incentives for production of biomethane.
TCI can draw on the model of the US EPA Renewable Fuel Standard (RFS) or the California Low Carbon Fuel Standard to develop mechanisms to incentivize production of biomethane from livestock manure digesters. EPA and the California Air Resources Board (CARB) have worked through many of the complications of providing incentives for low carbon fuels including the life cycle accounting that is the global standard for GHG accounting of fuels. TCI doesn’t need to reinvent the wheel on these subjects. In addition, using “standard EPA emissions factors” to assess the impact of different fuels doesn’t sounds like it would allow individual producers to benefit from innovations in reducing emissions. The RFS has multiple “buckets” of RIN credits which allow the producers of the lowest carbon fuels to benefit in the market. CARB’s LCFS has simplified Tier 1 fuel pathways for efficiency, but also allows producers to apply for a Tier 2 pathway when they think their production process provides additional GHG benefits. Both models could be adopted by TCI.
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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 |
1/16/2020 |
Robert |
Orgera |
AIA |
South Orange |
New Jersey |
My name is Robert Orgera, I am an architect and environmentalist also a member of my towns Environmental Commission.
As an architect/planner I am well trained in understanding the real... read more My name is Robert Orgera, I am an architect and environmentalist also a member of my towns Environmental Commission.
As an architect/planner I am well trained in understanding the real impact to local environments coastal, urban. Suburban and rural caused by bad land use planning and ignorance of climate change. I fully endorse this regional initiative and any similar measures considered to reduce carbon emissions. |
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