2/28/2020 |
will |
cembalest |
Middlebury College Student |
brooklyn |
New York |
To Whom it May Concern,
I appreciate being given the chance to provide my own feedback to the TCI. My name is Will Cembalest and I am an environmental economics major at Middlebury... read more To Whom it May Concern,
I appreciate being given the chance to provide my own feedback to the TCI. My name is Will Cembalest and I am an environmental economics major at Middlebury College, spending this spring term assessing the environmental, social and economic dynamics of Vermont’s transportation systems. I am commenting on behalf of myself, and holding true to the best interests of the Addison County region. Vermont’s largest source of greenhouse gas emissions is the transportation sector, so this program can effectively catalyze positive change in Vermont, and across the northeast region.
I would like to draw attention to MOU section I.3, Offsets, which addresses the regulations on the entity compliance and flexibility. The language used to discuss this directive is too tolerant of the state fuel suppliers. Engaging in carbon offset programs allows the state fuel suppliers to generally maintain their status quo operations, and fund alternative projects which may not most effectively support burdening low-income communities. This carbon offset procedure must set forth very stringent regulations to best support the rural communities in Vermont.
Carbon offset programs are very effective where certain carbon-mitigating, progressive projects are unable to attract the capital input necessary; the revenues from the offsets can decrease the technological and financial risk associated with the project. However, in many cases, fuel suppliers will engage in carbon offsets because they can be cheaper than using their own internal funds to invest in cutting their in-house greenhouse gas emissions. The largest issue with this scheme is that the carbon offset project would have been “implemented anyway”, which was found in a study conducted in 2010 looking at the Specified Gas Emitters Regulation in Alberta, Canada. In this case, a project such as switching fuels from diesel to natural gas, or installing energy efficient commercial heaters when the dilapidated burners needed replacement anyway, qualified as a GHG offset. This did not shift their emissions from their business as usual scenario, and failed to uphold the overall goal of the regulation: forcing polluters to make innovative changes to decrease emissions from the business as usual case.
If the program proves successful in the short run, it should eliminate the availability to purchase carbon offsets as an alternative, and make it an additional expenditure which state fuel providers can engage in if they wish. Under the RGGI program, which has proven successful by decreasing power plant emissions by 90% relative to the rest of the U.S, Massachusetts, Rhode Island and New Hampshire have all disbanded the ability to purchase offsets, described on the RGGI website. This indicates their intentions to decrease the polluter’s agency in dodging internal emissions reduction investments. For the time being, the offset program can exist only if the revenues from the project financially assist the residents within the TCI regions in transitioning towards a green fuel economy. Nowhere in the MOU is it specifically stated what kind of emissions offset projects they wish to engage in, nor the direct intention to positively impact low-income citizens. There must be several criteria for the offset project, recommended by the National Resource Defense Council. First, the offset project should be verified before the implementation of the project, not after a group collects the proceeds. Then, the project must be enforceable, where a third-party ensures its execution. Lastly, the offset must be permanent, guaranteeing that the positive impacts from project persist into the future.
Since it is the citizens of the states who are bearing the consequences of increased gas prices under the TCI and face future burdens of climate change in these regions, the proceeds are needed to support them in the transition towards a greener fuel economy. This would include initiatives like electric vehicle charging stations or subsidies for purchasing electric vehicles. Nowhere is it mentioned that the offset projects will remain within the premises of the states.
If this offset program were to exist, they must truly limit the amount of carbon offsets the state fuel supplier is able to purchase over the lifespan of the program, and additionally, the proceeds must be allocated towards specifically assisting in electrifying the fuel economy.
Thank you for your consideration.
Sincerely,
Will Cembalest
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TCIPublicComment_Cembalest.pdf |
2/28/2020 |
Roger |
Joslin |
Real Estate Broker |
North Concord |
Vermont |
THERE IS NO CLIMATE CRISIS!!! There is ample evidence that CO2 cannot cause warming and does not cause warming. The global temperatures have not risen by more than 1 degree C in the last 100... read more THERE IS NO CLIMATE CRISIS!!! There is ample evidence that CO2 cannot cause warming and does not cause warming. The global temperatures have not risen by more than 1 degree C in the last 100 years. The numbers have been manipulated to fit the IPCC agenda. Michael Mann was defeated in Canadian court because he wouldn't provide the data to prove his "hockey stick graph" was not a fraud. 500 scientist from all over the world have sent a letter to the UN asking for a debate with their scientists regards their data. This is absolutely not settled science. |
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2/28/2020 |
Barbara |
Hegedus |
n/a |
Parkesburg |
Pennsylvania |
IT IS SHAMEFUL THAT PENNSYLVANIA IS AT THE TOP OF POLLUTING STATES IN THE U.S.! I THINK WE'RE #3, BUT WITH A LITTLE MORE EFFORT, GOVERNOR WOLF AND OTHER POLITICIANS CAN PUSH US UP TO #1 -... read more IT IS SHAMEFUL THAT PENNSYLVANIA IS AT THE TOP OF POLLUTING STATES IN THE U.S.! I THINK WE'RE #3, BUT WITH A LITTLE MORE EFFORT, GOVERNOR WOLF AND OTHER POLITICIANS CAN PUSH US UP TO #1 - AND IT SEEMS THEY'RE TRYING TO DO THIS! |
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2/28/2020 |
Kasia |
Hart |
Metropolitan Area Planning Council |
Boston |
Massachusetts |
Please see the attached letter. Please see the attached letter. |
2020-02-28_MAPC TCI MOU Comment Letter_Final.pdf |
2/28/2020 |
WF |
Clement |
Citizen |
Gaithersburg |
Maryland |
Please partner with states and regions nationally to reduce pollution - modernize and transform transportation systems with clean, equitable solutions - there is no Plan(et) B. Please partner with states and regions nationally to reduce pollution - modernize and transform transportation systems with clean, equitable solutions - there is no Plan(et) B. |
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2/28/2020 |
Kasia |
Hart |
Metropolitan Area Planning Council |
Boston |
Massachusetts |
Please see the attached letter. Please see the attached letter. |
2020-02-27_COG MPO TCI MOU Letter_Final.pdf |
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 |
2/28/2020 |
Tara |
Santi |
Middlebury College |
Middlebury |
Vermont |
As a student currently working on transportation concerns in Middlebury, I was very curious to read the Memorandum of Understanding put forward by the Transportation and Climate Initiative (TCI... read more As a student currently working on transportation concerns in Middlebury, I was very curious to read the Memorandum of Understanding put forward by the Transportation and Climate Initiative (TCI). The TCI proposes the establishment of a regional program composed of 12 states and Washington, D.C., all committing to transition to a low-carbon, sustainable transportation sector through the implementation of a regional cap-and-invest program.
I agree with the TCI’s emphasis on cleaning up the transportation sector. If we’re going to act on climate change, we need to act fast. The 2018 IPCC report gave us twelve years (now ten) to cut global greenhouse gas emissions 45% below 2010 levels to have any hope of limiting warming beyond 1.5C. The recent ratification of the Global Warming Solutions Act (H.688) by the Vermont House is a promising start to what will hopefully be decisive, thoughtful, and socially-just continued action by the Vermont government to curb emissions.
The TCI is another step forward for Vermont, one unique in that it specifically tackles transportation, which makes up nearly half of the state’s current climate pollution. Curbing transportation emissions is a must if Vermont seeks to meet our commitment to the 2015 Paris Climate Accord by 2025. So yes, let’s join the TCI…BUT…
It MUST fully center the needs and rights of low income and working-class Vermonters in a just transition to a renewable energy-powered transportation future.
This is the question I always want to ask when considering climate legislation: who is going to be squeezed? Implementing a cap-and-invest system with a declining cap certainly puts the pressure on fuel suppliers, but that pressure is in part passed off to Vermonters filling up their tanks at the gas station. For some, the TCI will help lower the cost of transitioning to an electric vehicle (EV) and make it more feasible with rural electrification. But what about those Vermonters who simply do not have the budget for a new vehicle, whether or not it’s electric and whether or not the cost is lowered?
More accessible to some does not mean accessible to all.
This is the very issue the Vermont legislature hesitated on last session with a carbon tax proposal. House Speaker Mitzi Johnson said she can’t see a “straight-up carbon tax” being viable without already having a better public transportation system in rural areas. Isn’t that the same problem we see in the TCI, that putting a cap on carbon allowances might ultimately hurt rural and working-class Vermonters the most? The difference being that the TCI hides behind hopes of EV incentives and electric charging stations that simply do not make sense for many Vermonters.
To its credit, the TCI does include a clause on equity:
“BE IT FURTHER RESOLVED, that Signatory Jurisdictions will work with communities to ensure that the benefits of a cap-and-invest program flow equitably to communities that are underserved by clean transportation alternatives, disproportionately bear the costs of the current transportation system, or suffer disproportionate impacts of vehicular pollution and climate change”
I’m glad that there is recognition of the disproportionate costs of transportation to vulnerable groups, but I would hope to see social and community justice front and center of Vermont’s implementation of the TCI, rather than relegated to a side note.
I’ve experienced firsthand the frustrations of working-class people facing rising fuel prices when I lived in Bordeaux, France during the beginning of the yellow vest protest movement in November 2018. The high price of gas and a high of living in general hit the French middle and working-classes the hardest, especially in rural and peri-urban areas. People across the country demonstrated for weeks calling for lower fuel taxes, a solidarity tax on wealth, and a minimum wage increase, among other demands. I can’t help but draw some, albeit limited, parallels to Vermont. The unrest in France is a stark example of what happens when governments enact climate legislation without fully considering and addressing the needs of those who are currently the most dependent on the system the way it is now. Vermonters are perhaps not numerous enough to pressure their government the way that French protesters did, which gives legislators here all the more responsibility to be proactive about the way they implement any new transportation legislation.
Vermont could benefit greatly from increased electrification, expanded and improved public transportation, and smart development. That’s why I’m saying yes to Vermont participating in the TCI…BUT doing so by centering the needs of low income and working-class Vermonters. I don’t pretend to know the perfect solution, but I do encourage those making the decisions to find ways to minimize the burdens placed on individuals and households and maximize their ability to lead a dignified life. |
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2/28/2020 |
Elana |
Katz |
Ms |
Sharon |
Massachusetts |
Please make climate change your top priority. Please make climate change your top priority. |
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2/28/2020 |
Rebecca |
Bennett |
LCV, NRDC, Very concerned citizen |
Somerville |
Massachusetts |
I would love to see: More choice of less expensive electric cars; advertising to shame rich people into stop driving huge, gas wasting cars; recharging stations at every rest stop on all major... read more I would love to see: More choice of less expensive electric cars; advertising to shame rich people into stop driving huge, gas wasting cars; recharging stations at every rest stop on all major highways.(A family could stop and have a snack while charging their car. Knowing charging stations stations would be available would make people more comfortable moving to all electric cars.)
I drove to the rich western suburbs of Boston on Feb. 20, 2020. I watched carefully as I drove. I saw 1 hybrid car and 1 Tesla. The rest of the cars were very expensive cars, some V6’s and some V8’s !! I see this as shameful !! How are these people so ignorant !!
Otherwise, we need to make all forms of public transportation buses, trains, and subways all electric ASAP. Thank you for all you do.
Sincerely, Rebecca Bennett |
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2/28/2020 |
Janet |
Kolodner |
Boston College |
Brookline |
Massachusetts |
I urge you to do everything within your power to participate in TCI's initiative to design a low-carbon transportation policy for the northeast that will truly have substantial impact on... read more I urge you to do everything within your power to participate in TCI's initiative to design a low-carbon transportation policy for the northeast that will truly have substantial impact on managing the temperature of our warming Earth. I urge you, as well, to do everything in your power to make Massachusetts a model for such policy-making and implementation, working towards putting into practice at least what the joint transportation policy suggests and going better in any ways that are necessary and possible. It is our responsibility to leave the world in habitable shape for our children and grandchildren and beyond. Thank you. |
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2/28/2020 |
Carl |
Martin |
Norwich U |
Montpelier |
Vermont |
The benefits of reducing greenhouse gas emissions cannot ultimately be fiscally quantified, as these include protecting biodiversity and human well-being. Nonetheless, the TCI’s first-decade... read more The benefits of reducing greenhouse gas emissions cannot ultimately be fiscally quantified, as these include protecting biodiversity and human well-being. Nonetheless, the TCI’s first-decade regional benefits include (1) increases in GDP, disposable personal income (DPI), and employment, (2) better public health from cleaner air valued at $3 – $10 billion, and (3) a 20 – 25% reduction in greenhouse gas pollution from cars and trucks; while the VT-specific benefits include (1) $18 - $80 million in annual revenues to invest in low-carbon transportation options, (2) more money from the program each year than Vermonters contribute, and (3) the opportunity to make the state more affordable for low-income and rural Vermonters by lessening dependence on imported, polluting and expensive fossil fuels. |
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2/28/2020 |
Sandra |
Gardiner |
Please Select |
Lexington |
Massachusetts |
If we want our planet to be a place for human beings can live healthy happy lives we must focus on reducing the effects of climate change. Transporting people and goods has a large effect on the... read more If we want our planet to be a place for human beings can live healthy happy lives we must focus on reducing the effects of climate change. Transporting people and goods has a large effect on the Atmosphere and thus the Climate. Transportation is just part of the Climate Change problem. -
It will not take many feet of sea level rise to put vast areas of our country Florida, Cape Cod, New Orleans, Parts of Washington DC, Boston and NYC under water. If we expect to be a "great country" we must take intelligent steps to combat this problem.
And we must expect MANY REFUGEES from other nations that are under water or in some way in climate distress to enter our country demanding help. We must be ready to help. |
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2/28/2020 |
Carole |
Plumb |
citizen |
Wayland |
Massachusetts |
I support the TCI both to attempt to brake humanities collision course with climate upheaval and to reduce congestion with sensible transportation options. I support the TCI both to attempt to brake humanities collision course with climate upheaval and to reduce congestion with sensible transportation options. |
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2/28/2020 |
Peter |
Duval |
Peter Duval |
Underhill |
Vermont |
I participated in Vermont Public Service Board's Docket 5611, an investigation into environmental externalities -- in the early 1990s. The need for a cross-sector framework for regulating... read more I participated in Vermont Public Service Board's Docket 5611, an investigation into environmental externalities -- in the early 1990s. The need for a cross-sector framework for regulating greenhouse gas emissions was identified during the investigative phase of the docket. Emission allowance auction was one of several approaches to regulation that was considered. It was an appealing, market-based approach well-suited for a period of utility restructuring.
The TCI helps establish firm limits on greenhouse gas emissions while allowing flexibility in meeting the limits. It is three decades too late, but late is better than never. That the TCI only covers the transportation sector is a disappointment, but too narrow is better than not at all.
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2/28/2020 |
Brooke |
Lierman |
Maryland State Delegate |
Annapolis |
Maryland |
Please see a letter attached from members of the Transit Caucus in the Maryland General Assembly. Please see a letter attached from members of the Transit Caucus in the Maryland General Assembly. |
TCI letter_Transit Caucus_2_21_20.pdf |
2/28/2020 |
Karen |
Saunders |
PhD candidate, Environmental Studies, Antioch University New England; also a resident of Brattleboro, Vermont |
Brattleboro |
Vermont |
I urge that Vermont participate in the Transportation and Climate Initiative as a step toward reducing our transportation carbon footprint. We may be a small state, but we do have an impact, and... read more I urge that Vermont participate in the Transportation and Climate Initiative as a step toward reducing our transportation carbon footprint. We may be a small state, but we do have an impact, and with 44% of our carbon emissions coming from transportation, this is a critically important step.
Traveling regularly to Keene, NH, I am constantly aware of the insufficiency of our public transportation system. If we had buses traveling between Brattleboro and Keene, I would be taking them. TCI could mean that all of us would have better public transportation infrastructure, and fewer of us would have cars on the road.
I'm aware that there is resistance to TCI because of the burden that increased prices on gas would put on poorer Vermonters, who often must drive to jobs that are often far from home, and who can't afford to buy an electric vehicle, even with incentives. If done right, TCI can ease these issues, rather than becoming an added burden for poor Vermonters. I urge that funds received by Vermont through TCI be directed into programs that help poor Vermonters with transportation needs. This means that public transportation should be treated as a public good and be free or very inexpensive, incentives for fuel efficient cars should be means-weighted enough so that someone who is driving a third-hand gas-guzzler can afford to replace it. Vermonters with accessibility needs (who are often among the poorest of us) must also have their needs put foremost, and accessibility should be a primary consideration in building out new transportation infrastructure.
Again, I urge that Vermont formally join TCI, and take this critically important step toward a cleaner energy future and an improved transportation infrastructure that will benefit us all.
Sincerely,
Karen Saunders
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2/28/2020 |
Andy |
Robinson |
Andy Robinson Consulting LLC |
Plainfield |
Vermont |
As the owner of a Vermont-based business with clients around the country, I strongly support the TCI. It's a big step toward reducing our carbon emissions and also makes economic sense... read more As the owner of a Vermont-based business with clients around the country, I strongly support the TCI. It's a big step toward reducing our carbon emissions and also makes economic sense because:
1. We import 100% of our gas, propane, and heating oil from outside of Vermont. Many of those states will join TCI and then pass the costs to consumers further down the line, including in Vermont. If we don't join, then we're stuck with the costs without receiving any of the benefits.
2. About a quarter of fossil fuels sold in Vermont are purchased by tourists and other travelers. TCI proceeds will be distributed based on fuel sales within each state, so we will receive back more in revenues than Vermonters contribute.
Note to Governor Scott: This is an opportunity to earn more than we spend and use that money to support the Vermonters who need it the most. You have often encouraged a regional approach to climate change -- well, this is it. It's a rational, thoughtful, equitable, and economically valid solution. I urge your support.
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2/28/2020 |
Tracey |
Katsouros |
Sierra club |
Waldorf |
Maryland |
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... read more 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. Maryland can lead the way and be an example for other states. Please make good decisions on our behalf to help fight climate change.
Thank you for your time and consideration on this matter.
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2/28/2020 |
Michael |
Duhigg |
N/A |
Boxborough |
Massachusetts |
Climate scientists tell us that we do not have much time to significantly impact the carbon pollution that is accelerating climate change on the planet. The technology exists and is proven for the... read more Climate scientists tell us that we do not have much time to significantly impact the carbon pollution that is accelerating climate change on the planet. The technology exists and is proven for the adoption of electric buses. We need to do this now. |
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