TCI Regional Policy Design Stakeholder Submissions

To: TCI
From: Ellen Valentino
Subject: Proposed Draft Regional Policy
Date: November 5, 2019

The members of the Mid-Atlantic Petroleum Distributors Association (MAPDA) respectfully submit comments regarding the TCI framework and proposal released this fall. Our members are deeply concerned that the framework is moving ahead to foregone conclusions that are not substantiated by the real-world experience of other states.

The Transportation Climate Initiative sets out a framework that imposes an unfair burden on all vehicle owners and thousands of businesses, including those of our members. The proposal outlines a program that will cap the sale of gasoline, tax it, and then require the revenue generated to be spent on new government programs and projects that will further reduce the sale of gasoline. Some of the projects envisioned have ramifications that have not been verified or well thought out.

Electric vehicles are not the only answer.
The framework pins emissions reduction on electric vehicles, or EVs to reduce gasoline sales. EVs are not the magic bullet to solving greenhouse gas emissions. An EV's massive battery must be charged with electricity, which requires power generated from another source such as coal, natural gas or even nuclear power, and has an adverse environmental impact upon disposal. Pushing consumers to electric vehicles has not been shown to lessen environmental impact due to the environmental costs of EV batteries and manufacture of new vehicles. Further, programs such as incentives to EV purchase often favor wealthier individuals while the new taxes on gasoline will disproportionate affect poor and rural communities.

Our members are at a geographic disadvantage.
The northeast compact has a greater impact on Maryland and Delaware than the other Northeast states. Geographically, Maryland and Delaware retailers will suffer the most because consumers may more easily choose to go elsewhere for fuel. It won’t just be gasoline prices that rise to meet the TCI demands. The Northeast is a major trucking corridor and this proposal will essentially raise prices on transported goods. California’s Cap and Trade program, upon which the TCI framework is based, has led to a surge in gasoline prices, which affects all aspects of the economy.

All voices are not being heard.
Although this proposal has been pitched as a consensus document, in fact, it is not. There have been only three work sessions and less than a handful of webinars to solicit public feedback and comment. The framework is not ready for adoption by the states as too many points have not been clarified and fleshed out. No one really knows the full detail of the proposal. More outreach and public input needs to happen to shift this to a consensus. At the present, the framework appears to be a predisposed outcome. I urge that the participating Governors be required personally to attend and hold public hearings throughout their states. Our members are willing to work with others on this issue to create a true collaborative plan.

The current proposal will not achieve its goals.
California enacted a similar program recently, and, by most accounts, their gasoline costs have skyrocketed while the environmental impact has struggled to show a true measurable benefit. We welcome the opportunity to create a realistic policy proposal that provides a more balanced solution.

Respectfully submitted,

Ellen Valentino

While generally supportive of the TCI framework, many of my reservations concerning equity and climate justice have already been expressed and received by you in the on-line and community meetings.

However, unspoken is the fact that the eventual burden of all 'cap and trade' or 'cap and invest' schemes is born by consumers who bear the cost through passed-through price increases, while those who have historically benefited greatly are the extractive industries themselves which have actively pursued policies deliberately designed to deny, deceive and distort the political process for decades concerning the cause and scope of global climate change. The cost of addressing climate change today is considerably more than it would be had we not been subjected to decades of delay perpetrated by the fossil fuel industry itself. Nothing in the TCI framework addresses this gross injustice. Nowhere in the TCI framework is there any mechanism for the extraction industries to bear or to share the "externalized" costs resulting from the sale and use of their products, or to provide compensation for the damage they have already done.

I strongly support strategies to reduce our carbon footprint and improve the lives of Mainers through actions to improve public transportation options. In the midcoast, we have almost no public transportation options, with only a very limited local option. This makes everyone reliant on their car, which keeps us pumping out pollutants that are affecting our global climate. It is wise to work with our neighboring states and communities on a regional, bipartisan solution to provide clean, affordable, and accessible public transportation to our communities. Applying a “cap and invest” approach to transportation, as was used in the Regional Greenhouse Gas Initiative, would help Maine redirect some of the $5 billion a year we send out of state to fossil fuel companies into our local communities and sustainable transportation solutions.

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.

Thank you for your thoughtful initial framework for TCI.

I strongly support the equity and environmental justice aspects of this proposal because of the disproportionate impact that fossil fuel burning has on minority, lower income, and rural communities.

Living in Franklin County, MA, a rural region with a great deal of poverty, I would like to see Massachusetts think broadly and with specifics about how to use the TCI funds to increase access to affordable and viable public transportation to rural and low-income residents. For example, our county needs additional and more affordable public transportation to make it possible for people without cars to get to places of employment throughout the week, for night shifts, and on weekends. People in communities without a commercial district also need the ability to get to food shopping, get to medical facilities, etc. with some sort of public transit. Current public transportation here is extremely limited. Perhaps TCI would expand funds for a pilot program in the county--service on demand in small vehicles rather than buses. As our county's population ages, expanded public transportation will be that much more essential.

Thinking outside the box, TCI funds could be used to increase accessibility and expand equity to underserved rural populations by funding the full buildout of broadband. Reliable and up-to-date Internet service could help residents with applying for jobs, professional development, telecommuniting, accessing educational resources and online classes, and accessing support systems and medical professionals, without the need for transportation. Some of our communities and portions of them do not have broadband Internet access; rather they have only satellite or antiquated dial-up connections. This puts these residents at a significant disadvantage.

Lastly, these funds should be used primarily to reverse our greenhouse gases, not for adaptations to the impacts of climate change. We are in a race against time to reverse the devasting affects of climate change, and we must reach beyond the modest climate goals manadated by the Global Warming Solutions Act to avoid the disasterous predictions in the latest IPCC report.

Thank you for considering these comments as you look at finalizing the TCI design.

To Whom It May Concern:
I am a Horseheads to Ithaca commuter and something needs to be done about the congestion during rush hour at the southern end of Ithaca on NYS Route 13, specifically where NYS Rte. 13 and NYS Rtes. 34/96 come together just before reaching the NYS Rte. 327 intersection. That whole stretch from there to the first red light near Dunkin' Donuts, Home Depot, etc., is a hazard and heavily congested just before 8AM Mon.-Fri. Just before 9AM can be just as bad, but I'm more familiar with just before 8AM. TCAT only services Newfield near Rte. 13 and the discounted CTRAN (not free) bus runs only once to/from Elmira and Cornell in the morning and then again in the evening. It picks up at 6:15am (Elmira) and 6:30am (Horseheads) in Chemung County. They also stop at Alpine Junction in Schuyler County. Another later bus option would be nice as more people may ride the bus if they know there is a later bus option. My schedule got weird so riding the bus became inconvenient. There are a ton of people who commute from the Southern Tier because good paying jobs are scarce in that area but real estate is cheap. So they commute to their jobs in Ithaca and live in the Southern Tier. I am one of them. Tompkins County is an expensive place to live.

TCAT lost funding a few years ago so I gave up even parking in the free lot on Cornell campus. They became too unreliable with the unpredictable traffic delays I get in the morning. If I leave earlier, the Newfield Schools have a school bus that stops at almost every driveway. This bus runs from the Schuyler County line just before the roundabout in Newfield. This bus no longer pulls to the side of the road to let traffic go by like they used to. It used to pull over twice, then once, and now not at all. So I still end up in the congested mess if I leave earlier from Horseheads. If I leave earlier than 7am, I've gotten behind a slow moving tractor trailer going literally 35 MPH in a 55 MPH zone through the flat, straight section of the road. This lasted for about 5 miles with a line of traffic trying to get around it. Therefore, I still got into this mess again and got to work at the same time.

Attached is a .pdf with some pictures with additional concerns about the lack of left turning lanes and lack of early road closure signs that would reduce chaos and congestion.

Thank you for your time and consideration.

The urgency of climate change necessitates that we make strong, positive choices now that mitigate the cumulative negative effects that are already here and will only get worse if we continue to operate in a fossil-fuel based transportation system. Creating a regional low-carbon transportation initiative in collaboration with neighboring states would provide much needed improved transportation in Maine. I support Maine working with neighboring states through TCI’s bipartisan, proven policy model.