Northeast States Draft Regional Policy Proposal to Reduce Greenhouse Gas Pollution from Transportation Lacks Renewable Fuel Emphasis DEADLINE FOR COMMENTS: November 5, 2019
by Joanne Ivancic (Advanced Biofuels USA) “Nothing has been decided yet about the treatment of biofuels” or renewable fuels in the proposed program to cap transportation emissions in 13 Northeastern US jurisdictions, according to the chair of the Transportation and Climate Initiative (TCI) Leadership and Workgroup, Kathleen Theoharides, Secretary, Massachusetts Executive Office of Energy and Environmental Affairs. So now is the time for biofuels organizations and individuals with an interest in seeing the benefits of renewable fuels realized in this region.
The framework for the proposal released on October 1, 2019 says “The proposed program would cap emissions of carbon dioxide from the combustion of the fossil component of finished motor gasoline and on-road diesel fuel in the region. The TCI jurisdictions are evaluating whether and how to include and treat biofuels in the program. … Compliance obligations would be calculated based on the emissions that occur when the affected fuel is combusted,” yet forsees “separate reporting of fossil and biogenic components of blended fuels.”
No where in the framework is “electricity” or “power” mentioned. Carbon reduction appears only to apply to gasoline and diesel. With the many airports in the region, it seems a comprehensive transportation plan should also include avaition fuel for commercial and government use.
The framework is not yet finalized. The anticipated timeline allows for more written public input until November 5, 2019 via the online portal on the TCI website in preparation for a draft MOU in December that will be reviewed by the 13 TCI jurisdictions (Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont and Virginia and the District of Columbia).
Of concern to renewable and biofuels supporters is the lack of a “carbon intensity” analysis of the fuel that powers transportation in these states. If the only assessment of carbon footprint is calculated based on the emissions that occur when the affected fuel is combusted rather than calculated using the type of life cycle analysis developed in the California Low Carbon Fuel Standard, a great deal of carbon emissions may be ignored.
In addition, there is no indication that the source of the electricity used for transportation power is a concern for those drafting this model. It seems no assessment of the carbon footprint of fossil-based electricity factors into the calculations unless it is assessed “where the fuel is combusted” to make the electricity. This needs clarification.
It appears that the leaders of this project are intent on crafting a tax-and-dividend or tax-and-invest program with tradeable credits; however, they also seem to be ignoring some hard-earned lessons from California’s experience. Those who have been part of that learning curve might want to share their insights.
Advanced Biofuels USA has long proposed a different approach, a disappearing carbon tax, that is easy and economical to administer and encourages “where the rubber meets the road” environmentally conscientious decisions by those who have a choice about what kind of fuel they use with oppportunities for market-pressure to inform more sustainable investments. This proposal has been shared via the TCI portal.
Now is the time to address any faults and flaws in the proposed TCI framework.
* Joanne Ivancic serves as the executive director for Advanced Biofuels USA, a nonprofit educational organization dedicated to promoting understanding, development and use of advanced biofuels as an economic development, energy security, military flexibility, pollution control and climate change mitigation solution.
“Disappearing” Carbon Tax for Non-Renewable Fuels (Advanced Biofuels USA)
Framework for a Draft Regional Policy Proposal (Transportation and Climate Initiative)
TCI jurisdictions share updates on policy design process (Transportation and Climate Initiative)
Northeast states takes first step in effort to reduce transportation emissions (The Hill)
New England region must boost efforts to meet carbon reduction goals, study finds (Daily Energy Insider)
Achieving 80 Percent GHG Reduction in New England by 2050 (Brattle/Coalition for Community Solar Access)