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The minutes of the March 20, 2013 EVADC meeting incorrectly stated that Nabil Bedewi was organizing the EV Grand Prix. Nabih Bedewi (nbedewi@globaleee.org) was in fact organizing the EV Grand Prix.

Electric Vehicle Supporters,

UPDATE: Over 80% of the TCI comments were positive! There is broad support for taking action. Well done, folks!

You may have heard in the news about a proposal from the Transportation and Climate Initiative (TCI)  for a regional policy to clean up transportation carbon emissions through a cap-and-invest approach.  This would be a system similar to the Regional Greenhouse Gas Initiative (RGGI) in which a carbon emission budget is established and emitters obtain allowances to emit a certain amount of carbon.  Once in place, the number of available carbon allowances is gradually reduced, giving emitters time to find the cheapest market-based solutions for decreasing their emissions (i.e. their need for allowances). 

In the current proposal, the gasoline and diesel wholesale fuel suppliers and others who bring fossil fuels into the regional distribution system would be treated as the emitters.  Allowances can be traded among emitters, so, for example, if Company A reduces its emissions by a large amount, it would then have allowances it could sell to Company B, which needs them.  The net effect is that the marketplace itself finds the most cost-effective places to reduce carbon emissions, thereby achieving emissions while  minimizing costs.

For additional background on allowance trading, EVADC recommends the first 24 minutes of TCI’s tutorial “Cap and Invest 101”. 

This is the central location to keep track of everything related to this proposal.  The current stage of the process is the collection of public comments on the draft of the Memorandum of Understanding (MOU).  For those interested in the specific details, the MOU was well-explained at the TCI webinar on Dec. 17.  The slides from the webinar are here.  For those in a hurry, we recommend minutes 15:00 to 53:00 of the webinar, and/or slides 4, 5, 16-21, 23, 25-27 and 45-49.

Comments on the draft MOU are due February 28, 2020, and are filed at the TCI web site. 

In order to get your bearings, it’s best to start by reading some of the recent comments.  Comments can be as detailed or broad as you want.  However, having commented on things in the past, EVADC suspects that highly detailed comments would simply be categorized as “for” or “against”, thus brevity, succinctness and impact are probably what you should strive for if you want your entire comment to be read.   

We suggest addressing the need for action (carbon emission must be reduced), analogies with RGGI (which is successfully reducing emissions), the benefits that will come to states, transit, low-moderate income families, and public health, and ways everyone benefits, even those not currently driving an EV  (via less air pollution, a healthier climate, downward pressure on electric rates by large amounts of off-peak charging, increased national energy security) and ways EV drivers benefit directly (saving money).

Anyone who supports electric vehicles needs to be heard!  As one would expect, those opposed to taking action on climate are not being shy weighing in.  We can’t be shy either!  Already, the Mid-Atlantic Petroleum Distributors Association folks (who testify against every EV-related bill in Annapolis) have posted talking points for their members to use for comments.  TCI needs to hear from folks who want to take action and be part of the solution.

The deadline for comments if February 28, 2020.  Comments are filed at the TCI web site.   You are limited to 10,000 characters including spaces (this is about three pages of 11 point font).  You can also have attachments up to 100 MB.  We recommend first reviewing comments that have already been submitted for context.  We also recommend writing your comments offline first, preparing a file if needed, then pasting your comments into the comments field, after which you can preview your submission.

Sample opponent comments, opponent positions.

Business Groups Tout Poll Showing Opposition to Gas Tax Hikes to Fight Climate Change

https://www.golocalprov.com/live/mike-stenhouse-tci-december

https://www.forbes.com/sites/patrickgleason/2019/12/21/new-hampshires-governor-rejects-regional-gas-price-hike-while-other-governors-are-being-urged-to-do-the-same/#4cfff8fd7585

https://www.masslive.com/opinion/2020/02/at-its-core-the-transportation-climate-initiative-represents-a-gas-tax-guest-viewpoint.html

Below, we give a summary of, and flaws in, some of the most common contrarian arguments:

1) Gas prices will skyrocket. Slide 27 shows the anticipated effect on gas prices relative to the prior decade of gas price fluctuations.  In reality, any increases will be lost in the noise.  Price increases due to TCI will be less than normal fluctuations we see every day.  There will also be a cost-containment reserve that will limit unexpected or unacceptable price increases.  And, though it may not seem like it, gas prices are low, which gives us freedom to act.  If gas prices were high, there would be even more opposition to action.

2) This is nothing more than an extra tax on gasoline.  This is the most common argument, since it’s so simple.  “Tax” often appears in media headlines as well.  It’s not a tax, it is more a reduction in the free-ride gas and diesel has been getting for years, or equivalently, a more accurate accounting of the true costs of gas and diesel.  The funds gathered won’t just vanish into a black hole either, they will be invested in further improvements in transportation.  Slide 23 gives an example scenario of possible investments.  In any case, as shown above, the anticipated increase in cost at the pump is well below normal price fluctuations, and will be unnoticeable. 

3) It will have negligible effect on reducing carbon emissions compared with doing nothing.  This is a more insidious argument, since it relies on a purposefully selective interpretation.  The TCI analysis begins with the Reference Case, which projects future emissions, fuel use, and other aspects in the absence of an TCI “cap and invest” program (slide 16).  The reference case makes the assumptions on slide 17, and assumes rather optimistic anticipated EV sales growth (slide 47).

On slide 20, the Reference Case result is a 19% reduction in carbon emissions due to increased fuel economy (current CAFE mileage law, not proposed Trump rollback) and optimistic increased light-duty vehicle EV market share.

Slide 25 then shows the extra reduction gained by a range of TCI cap reductions.  25% is the worst (or best depending on your point of view) case.

The opponent argument then goes, “if we’re getting 19% anyway with no cap, why should we then have the proposed program (with the alleged taxes and skyrocketing gas price) only to get another 6%?”. 

Three responses: First, we need every ton of carbon reduction we can get our hands on, so 25% is better than 19%. 

Second, the Reference Case 19% assumes a very optimistic growth rate for EV’s.  Since the TCI cap revenue would be used in part for EV incentives, having the cap in place can guarantee we get the reductions we’re looking for.  The Reference Case relies on hope, but a TCI cap would put real meat on the bones.

Third, a TCI cap would be good insurance against policy setbacks or price undercutting.  Slide 21 shows what happens to the Reference Case given lower oil prices (leading to more driving) and CAFE mileage standard rollbacks (as proposed by Trump).  Under those assumptions, no cap might change our 19% reduction to only 6% reduction, so a TCI cap becomes even more critical.  In essence, if mileage standards get dialed back or oil prices drop, or both, having a TCI cap means we will still get needed GHG reductions.

Summary: TCI needs to hear from EV supporters!  At a minimum, review some of the comments already submitted and frame your own.  You can also explore the information given above.  Comments are due by February 28. 

UPDATE: Space has opened up the Pepco Panorama array!  You can sign up at Neighborhood Sun and let start driving carbon free.

We’ve created a web page for folks who have a plug-in car and want to charge it with solar electricity, or who want solar electricity anyway for their home.  You can even get it for less than standard offer!  Learn more at EV’s & Solar