8/27/2019 |
Bruce |
Ho |
Natural Resources Defense Council |
Annapolis |
Maryland |
Please find attached joint comments from 13 organizations on the reference case modeling results presented on the August 8th TCI webinar and on the TCI states' next steps in modeling. Thank... read more Please find attached joint comments from 13 organizations on the reference case modeling results presented on the August 8th TCI webinar and on the TCI states' next steps in modeling. Thank you. |
Joint Comments on 8_8 TCI Webinar.pdf |
8/22/2019 |
Connor |
Dolan |
FCHEA |
Washington |
District of Columbia |
Please see the attached comment sent on behalf of the Fuel Cell and Hydrogen Energy Association (FCHEA). Please see the attached comment sent on behalf of the Fuel Cell and Hydrogen Energy Association (FCHEA). |
TCI Comments August 2019.docx |
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 |
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 |
8/14/2019 |
Ramon |
Palencia-Calvo |
Maryland League of Conservation Voters - Chispa Maryland |
Annapolis |
Maryland |
The signatories of the attached letter respectfully request that the Maryland Department of the Environment (MDE) and the Maryland Department of Transportation (MDOT) designs and fosters a public... read more The signatories of the attached letter respectfully request that the Maryland Department of the Environment (MDE) and the Maryland Department of Transportation (MDOT) designs and fosters a public engagement process to provide residents opportunities to participate in a meaningful way in the policy design and implementation of the Transportation and Climate Initiative (TCI). Additionally, we offer recommendations to ensure the process is inclusive.
We believe it is important for Maryland to perform this process and integrate feedback from communities and we look forward to working with you to make this community engagement process robust, inclusive and transparent.
|
20190809_TCI_PublicEngagementLetter.pdf |
8/7/2019 |
Mark |
Kresowik |
Sierra Club |
Washington |
District of Columbia |
August 7, 2019
To: Governor Baker, Mayor Bowser, Governor Carney, Governor Hogan, Governor Lamont, Governor Murphy, Governor Northam, Governor Raimondo, Governor Scott, and Governor... read more August 7, 2019
To: Governor Baker, Mayor Bowser, Governor Carney, Governor Hogan, Governor Lamont, Governor Murphy, Governor Northam, Governor Raimondo, Governor Scott, and Governor Wolf
Re: 2019 Transportation and Climate Initiative (TCI) Regional Policy Design Process
Sent via: https://www.transportationandclimate.org/main-menu/tci-regional-policy-design-stakeholder-input-form
The Sierra Club is sharing with you the attached 2,435 comments from our members and supporters in your states and the District of Columbia (DC) regarding the 2019 TCI Regional Policy Design Process. More than 700 of those members and supporters across the 9 states and DC have included personal messages, often encouraging swift action to modernize our transportation system, reduce climate pollution from burning motor fuels, and ensure equitable access to the benefits of clean transportation, particularly for those communities that have been overburdened and under-resourced by our current system. Many have also provided specific recommendations and requests for investments and clean transportation projects in their communities.
The Sierra Club continues to support your efforts through this process. We further recommend that you and your teams transparently and inclusively develop an understanding of which communities in the region are overburdened by pollution from motor fuels and under-resourced when it comes to access to clean, affordable, and rapid transportation, and to move forward by modeling and sharing the impacts for those communities of both a cap and invest policy for climate pollution from motor fuels consistent with meeting state climate protection targets and other complementary policies as discussed in the state and regional workshops and listening sessions. We also encourage more engagement by individual states and DC with such overburdened and under-resourced communities, by partnering with and supporting community representatives in the planning and hosting of workshops and listening sessions during the evening or on the weekend, accessible by public transportation, and with services for people with disabilities, limited English proficiency, and children and other care duties.
As demonstrated by the more than 300 participants at the in-person regional workshop on July 30th and these thousands of comments from Sierra Club members and supporters, a robust and inclusive clean and modern transportation policy design process this year is vitally important for the future prosperity of our communities.
Sincerely,
Mark Kresowik
Deputy Director, Eastern Region
Sierra Club |
Sierra Club Member and Supporter Comments 8-7-19.pdf |
8/2/2019 |
Chris |
Dempsey |
Our Transportation Future |
Many |
Massachusetts |
Our Transportation Future (OTF) is a coalition of local, state, regional, and national environmental, health, scientific, transportation, and business organizations committed to modernizing... read more Our Transportation Future (OTF) is a coalition of local, state, regional, and national environmental, health, scientific, transportation, and business organizations committed to modernizing transportation across the Northeast and Mid-Atlantic region. We are sending the attached letters to the Governors of the TCI states and Mayor Bowser in support of the important work that you are your colleagues are doing at the intersection of transportation and the environment. This letter is signed by 59 organizations from across the TCI states. We ask that you please share this letter electronically with your colleagues who are part of the TCI process, as well as any others who may be interested in reading it. |
Our Transportation Future _ Letter to TCI Governors_7.29.2019.pdf |
8/2/2019 |
Laureen |
Boles |
New Jersey Environmental Justice Alliance |
Trenton |
New Jersey |
Transportation Electrification: Developing High Impact Policies for NJ's Most Environmentally Burdened Communities read more Transportation Electrification: Developing High Impact Policies for NJ's Most Environmentally Burdened Communities |
Final Draft of NJEJA Transportation Electrification (4).pdf |
7/29/2019 |
Phillip |
Ludvigsen |
First Environmnet, Inc. |
Boonton |
New Jersey |
Financing Green Infrastructure moving toward a low-carbon economy is key. Green Bonds and loans are becoming a major market. Unfortunately many municipalities and corporations know very little... read more Financing Green Infrastructure moving toward a low-carbon economy is key. Green Bonds and loans are becoming a major market. Unfortunately many municipalities and corporations know very little about these financial instruments and the emerging global standards. The initiative should add information sharing on this topic to its existing workshops, especially energy and transportation.
Attached is a rather dated article on De-risking Green Bond Deals written for Environmental Law in New York. This article is being updated with green Muni bonds in mind.
Phil Ludvigsen, Ph.D. |
Green Bonds De-Risking Deals NYLJ Oct 2016.pdf |
7/26/2019 |
Eleanor |
Fort |
Green for All |
Boston |
Massachusetts |
On behalf of eight racial, economic, environmental, and transit justice organizations, we submit the attached letter "Policy Design Principles for an Equitable Clean Transportation Program... read more On behalf of eight racial, economic, environmental, and transit justice organizations, we submit the attached letter "Policy Design Principles for an Equitable Clean Transportation Program". |
Regional Policy Design Principles for Equity.pdf |
6/24/2019 |
Elizabeth |
Henry |
Environmental League of MA |
Boston |
Massachusetts |
Dear Governor Baker, Secretary Theoharides, and Secretary Pollack,
An uncommon alliance has emerged between five diverse Massachusetts organizations with business constituencies.... read more Dear Governor Baker, Secretary Theoharides, and Secretary Pollack,
An uncommon alliance has emerged between five diverse Massachusetts organizations with business constituencies. We are united by a once-in-a-generation opportunity to modernize and decarbonize our transportation system.
We express strong support for the 18 recommendations developed by the Commission on the Future of Transportation. Specifically, we applaud the Transportation & Climate Initiative (TCI).
If properly structured, TCI could achieve several of our shared goals concurrently: mitigating greenhouse gas emissions from transportation, investing in much-needed public transit, and alleviating congestion. While TCI isn’t the solution to all of our transportation and climate problems, it is a proven and effective policy tool to move us toward a cleaner, less congested transportation system.
We would welcome the chance to speak with you. We also stand in service to help shape the program and build support for TCI among other stakeholders in Massachusetts and across the other TCI states.
Thank you for your early leadership in TCI. We are looking forward to working with your Administration to implement a strong, effective program.
Sincerely,
Robert Rio, Associated Industries of Massachusetts
Mindy Lubber, Ceres
Elizabeth Turnbull Henry, Environmental League of Massachusetts
JD Chesloff, Massachusetts Business Roundtable
Eileen McAnneny, Massachusetts Taxpayers Foundation |
Letter to Gov. Baker from Business & Environmental Leaders (June 20, 2019).pdf |
5/29/2019 |
Bruce |
Ho |
Natural Resources Defense Council |
New York |
New York |
Please find attached comments from 16 environmental, health, scientific, transportation, and business organizations on the Reference Case assumptions presented on the May 23rd TCI webinar. Thank... read more Please find attached comments from 16 environmental, health, scientific, transportation, and business organizations on the Reference Case assumptions presented on the May 23rd TCI webinar. Thank you. |
Advocate Group Comments on 5_23 TCI Webinar.pdf |
5/29/2019 |
Tony |
Dutzik |
Frontier Group |
Boston |
Massachusetts |
Please accept the attached comments regarding forecasting of vehicle-miles traveled in the reference case scenario. Please accept the attached comments regarding forecasting of vehicle-miles traveled in the reference case scenario. |
Frontier Group comments to TCI re reference case 052919.pdf |
5/29/2019 |
Jason |
Frost |
Synapse Energy Economics |
Cambridge |
Massachusetts |
Please see the attached document. Please see the attached document. |
TCI Reference Case Assumptions Comments.pdf |
5/29/2019 |
Clifford |
Strawitch |
Citizens Climate Lobby |
Ellicott City |
Maryland |
I attach the PDF file of my response since it failed to upload yesterday (5/28) after many attempts. Please attach this to my response from yesterday. Thanks. I attach the PDF file of my response since it failed to upload yesterday (5/28) after many attempts. Please attach this to my response from yesterday. Thanks. |
Cliff Strawitch Response.pdf |
5/23/2019 |
Connor |
Dolan |
Fuel Cell and Hydrogen Energy Assoc |
Washington |
District of Columbia |
Attached are some references and studies related to fuel cell vehicles and hydrogen that I believe would be valuable as this initiative continues.
I also wanted to direct you to the... read more Attached are some references and studies related to fuel cell vehicles and hydrogen that I believe would be valuable as this initiative continues.
I also wanted to direct you to the following Department of Energy presentation and program records on fuel cell cost projections for automotive and medium-duty vehicles.
https://www.hydrogen.energy.gov/pdfs/17008_levelized_cost_driving_future_icev.pdf
https://www.hydrogen.energy.gov/pdfs/16009_life-cycle_costs_midsize_ldv.pdf
https://www.energy.gov/sites/prod/files/2018/04/f51/fcto_webinarslides_2018_costs_pem_fc_autos_trucks_042518.pdf
Our Association and its members would be happy to provide your team with an in-depth briefing on fuel cell vehicles and hydrogen infrastructure to ensure that this program is as comprehensive as possible. Our members include the largest automakers investing and deploying fuel cell vehicles, industrial gas companies developing hydrogen stations and large-scale production plans, as well as other fuel cell and hydrogen manufacturers.
Should you have any further questions regarding fuel cells or hydrogen, please feel free to contact me at any time. |
TCI Research 2019-2-27.docx |
5/23/2019 |
Alex |
DePillis |
Vermont Agency of Agriculture |
Montpelier |
Vermont |
Hello,
I'm listening to the 5/23 webinar, and mostly watching the TCI process somewhat from the periphery. Here are my comments and my interest.
Comments:... read more Hello,
I'm listening to the 5/23 webinar, and mostly watching the TCI process somewhat from the periphery. Here are my comments and my interest.
Comments:
I support how the analysis of baseline transportation looked at EIA's NEM as well as other sources. My impression is that EIA's predictions have been very poor, missing some big trends, especially longer-term trends, like growth of renewable energy.
Given my interest in heavy-duty fleets (see below), I look forward to hearing more about something other than EVs, and how those non-EV options would be monetized in TCI. Looking at modeling done for Vermont's Comprehensive Energy Plan, climate goals are reached with biofuels, not just electrification. I assume that GHG emissions from heavy-duty and medium-duty fleets are non-trivial in the Northeast, and electrification in these fleets seems immature compared to passenger EVs and light-duty EVs. What can you do to model this the medium-duty and heavy-duty sector?? E.g. what are the recent history and trends for natural gas and RNG, in usage and in which types of vehicles? I assume DOE's AFDC has the data.
My Interest:
Being in the agricultural sector, and with Vermont's biogas potential from dairy manure, I am intent on getting RNG produced and used as a way to support farms and offset GHG emissions. The Agency of Agriculture and others will analyze the statewide potential, using existing digesters, which process only 10% of Vermont's dairy manure, and new digesters. Back of the envelope, I estimate 500-1000 Class 8 trucks could be operated on RNG from Vermont's dairy manure.
Please remember that the global warming potential of methane is ~25x of CO2 in the 100-year time frame, but it is ~85x CO2 in the 25-year timeframe. Used in transportation, RNG from dairy manure is strongly carbon-negative: -276 gCO2e per MJ. Electricity is 20-40 gCO2e/MJ (see slides 7-9 of the attached presentation).
I'm glad to discuss as necessary.
I appreciate the opportunity, thank you.
Alex
|
a-new-energy-resource-for-america-organic-waste-to-biomethane.pdf |
5/14/2019 |
Donald M. |
Goldberg |
Climate Law & Policy Project |
Chevy Chase |
Maryland |
|
CLPP comments on TCI.pdf |
5/14/2019 |
Mark |
Kresowik |
Sierra Club |
Washington |
District of Columbia |
Thank you, please find attached comments from 39 environmental, health, scientific, transportation, social service, and business organizations committed to advancing modern, clean, accessible, and... read more Thank you, please find attached comments from 39 environmental, health, scientific, transportation, social service, and business organizations committed to advancing modern, clean, accessible, and low-carbon transportation in the Northeast and Mid-Atlantic on the first workshop held on April 30th. |
Advocate Group Comments on 4_30 TCI Workshop.pdf |
5/16/2019 |
Marc |
Breslow |
Climate XChange |
Boston |
Massachusetts |
see same attached as a PDF, with graphics
HOW TO SIMULTANEOUSLY REACH EMISSION TARGETS
AND ADVANCE EQUITY IN THE
TRANSPORTATION & CLIMATE INITIATIVE ... read more see same attached as a PDF, with graphics
HOW TO SIMULTANEOUSLY REACH EMISSION TARGETS
AND ADVANCE EQUITY IN THE
TRANSPORTATION & CLIMATE INITIATIVE
Marc Breslow, Ph.D., Policy and Research Director
Jonah Kurman-Faber, Research Associate
SUMMARY
STRICT CAP LEVELS: Most TCI states have adopted goals to achieve an 80 percent reduction in emissions by 2050, compared to 1990 levels. The cap levels for 2030 and beyond must be sufficient to reach this goal, which means at least a 40 percent reduction in transportation emissions by 2030.
UNSUPPRESSED ALLOWANCE PRICES: Allowance prices must be allowed to reach whatever levels are necessary to achieve this reduction, except under extraordinary circumstances. To suppress the allowance price, either through an oversupply of allowances or an unreasonably low-price ceiling, is to threaten the environmental integrity of the program.
PROTECT VULNERABLE POPULATIONS: In order to justify price containment mechanisms that are sufficiently high that they do not allow the cap to be violated, TCI states should concentrate on returning revenue to low and moderate-income households, as well as environmental justice (EJ) communities, in order to ameliorate the impacts of the program on their cost of living. This can be done by (1) targeting investments to address the needs of their communities for low-carbon transportation and to reduce health impacts from fossil-fuel transport, and (2) returning a portion of the money to them through rebates and tax cuts.
HIGHER ALLOWANCE PRICES WILL CAUSE EMISSIONS TO DROP: Higher allowance prices will by themselves, apart from the impact of investments, cause emissions to drop, over ten years or more.
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CAP LEVEL MUST BE SET AT A 40% REDUCTION OR MORE BY 2030
Our coalition, the Massachusetts Campaign for a Clean Energy Future, has two basic principles for an acceptable carbon pricing policy:
• Achieve, in combination with other policies, the state’s GHG reduction mandates;
• Ensure that the vast majority of low-income, and most moderate-income, people come out ahead or even from the combination of carbon pollution charges and use of the resulting revenues for rebates/tax cuts and reinvestment.
Massachusetts, as with most of the states that are part of the TCI, has a legally-mandated target to reduce emissions by at least 80 percent by 2050. To keep on track to get to 80 percent these states must reduce emissions by 40 to 45 percent by 2030.
Figure 1: Massachusetts Percent Emission Cuts from 1990
As the leading source of greenhouse gas emissions, transportation must get on the same track as electricity, building, and industrial fuels and cut emissions by at least 40 percent by 2030, and by about two-thirds by 2040.
Thus, Climate XChange proposes that the TCI adopt a cap of at least a 40 percent reduction in transportation emissions for 2030, compared to 1990 levels. Since TCI is only expected to cover ground transport, other sectors such as air travel must be addressed with complementary policies.
Given the state of the global warming crisis worldwide, any reduction of less than 40 percent as a target, and as the level to which the TCI emissions cap is set, is simply unacceptable.
ALLOWANCE PRICES MUST REFLECT WHATEVER PRICE IS NECESSARY TO STAY UNDER THE CAP TRAJECTORY
The objection to a tight cap level is that it could lead to higher than acceptable allowance prices. Typically, cap-and-trade systems have suppressed allowance prices by setting the initial cap excessively high and allowing polluters to bank excess allowances for future years. Alternatively, program designers can choose to suppress costs by setting a cost containment reserve and/or price ceiling very low. Both decisions could compromise the program’s ability to achieve a 40 percent reduction by 2030.
Rather than threaten the integrity of the program, governments can spend their revenue in such a way that the allowance price can rise as high as needed, while holding vulnerable populations harmless. There are two ways to do this:
1. Invest the money in appropriate ways for both individual households and communities – via public transit, incentives for electric vehicles, charging stations, etc. California has established strong equity requirements in their investment program, and estimates that 57 percent of projects are benefiting disadvantaged communities. Whether this spending will fully counteract the impact of rising prices for fuels, address existing burdens from fossil-fuel based transportation, and address cross-sectional issues such as public health and improvement of mass transit is yet to be seen. Our organization is currently conducting a study on California’s equity requirements and spending programs. TCI must fully investigate to what degree investment spending can cover the increased costs of the program, rectify prior burdens of disadvantaged households, and improve equity for such communities.
2. To the degree that spending money on investments is not sufficient, for either low/moderate income or EJ families, the TCI states must return the money to households, with a higher proportion going to vulnerable populations, presumably via rebates, tax credits, or other methods. In California, about 35 percent of its total cap-and-trade allowance value is being returned to households (via equal rebates per household on electric and natural gas bills) and small businesses, while 15 percent is directly allocated to particular industries. About 36 percent of the total revenue goes to transportation investments and 9 percent to other climate-related investments. See Figure 2 below:
Figure 2: California’s Use of Allowance Value from Cap-and-Trade I
From: Regional Cap and Trade: Lessons from the Regional Greenhouse Gas Initiative and Western Climate Initiative, Jonah Kurman-Faber and Marc Breslow, Climate XChange, 2018
Given that TCI will only cover transportation, it would be appropriate to use a substantial portion of the revenues for rebates/tax cuts for low and moderate income households, and possibly for higher-income households – to the extent that their costs cannot be effectively covered by investments in their communities.
Such rebates/tax cuts would effectively negate the argument against higher allowance prices. A variety of studies have shown how this can be done at the state and federal level, including our own studies for Massachusetts and Maryland. See Figure 3 below, which shows the impacts on the bottom 20 percent of households from House Bill 1726 in Massachusetts, based solely on rebates.
Figure 3: Impacts on the bottom 20 percent of households from House Bill 1726 in Massachusetts, based solely on rebates
HIGHER ALLOWANCE PRICES WILL CUT EMISSIONS FURTHER
We understand that the primary purpose of TCI is to provide incentive money for clean transportation. But of course, as with all cap-and-trade systems, raising prices is expected to cut demand for fuel. Georgetown’s 2015 study, even with low allowance prices, estimated small cuts as higher prices induce drivers to buy more fuel-efficient cars, to switch to electric vehicles, and to drive less. With higher allowance prices the reductions in emissions will be greater.
Our own studies, and those done for other states, such as the Maryland Commission on Climate Change’s (MCCC), have estimated these changes. It is important to remember, that just as with mass transit investment, it takes a number of years for these impacts to show up, as they primarily influence the demand for new vehicles. Since it takes up to 15 years for vehicles to be discarded, it will take a long time for the impacts of higher prices to fully come into effect.
The study done for the MCCC, by Energy+Environmental Economics, estimated that higher carbon prices would cause a 9 percent reduction in energy consumption by 2030 and 35 percent by 2050.
CONCLUSIONS
To summarize, we conclude that:
STRICT CAP LEVELS: The cap levels for 2030 and beyond must be sufficient to reach the 80 percent or greater reductions in overall emissions that most TCI states have adopted; and this means a cap level for 2030 that is at least 40 percent below the 1990 level.
UNSUPPRESSED ALLOWANCE PRICES: Cost containment mechanisms must allow allowance prices to reach whatever levels are necessary to achieve the caps, except in extraordinary circumstances. With high allowance prices, a portion of the revenue should be returned to vulnerable customers to counteract the increase without violating the environmental integrity of the program.
PROTECT VULNERABLE POPULATIONS: In order to justify a strict cap and price containment mechanisms that are sufficiently high that they do not allow the cap to be violated, TCI states should concentrate on returning revenue to low and moderate-income households, as well as environmental justice communities, in order to ameliorate the impacts of the program on their cost of living and to reduce health impacts from fossil-fuel transport. This can be done by (1) targeting investments to address the needs of their communities and (2) returning a portion of the money to them through rebates and/or tax cuts.
HIGHER ALLOWANCE PRICES WILL CAUSE EMISSIONS TO DROP: Higher allowance prices will by themselves, apart from the impact of investments, cause emissions to drop, over ten years or more.
|
Climate XChange TCI Comment Letter 5.15.19.pdf |