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Comment 88 for Transportation Comments for the GHG Scoping Plan (sp-transport-ws) - 1st Workshop.


First Name: Carolyn
Last Name: Casavan
Email Address: ccasavan@wcenviro.com
Affiliation: West Coast Environmental and Engineering

Subject: Proposed GHG Emissions Reporting for Passenger Vehicles
Comment:
This suggestion promotes the involvement of individuals in reducing
greenhouse gas (GHG) emissions in the state.

According to the Draft Plan, transportation accounts for 38% of
GHG emissions in the state.  A major problem with regard to
priority pollutant regulations is that business has been required
to shoulder the bulk of the responsibility and reduction.  As a
result, while business has been reducing emissions, vehicle miles
traveled (VMT) and vehicle size have been increasing.  One of the
best things we can do is to have the residents of the state
understand their contribution and responsibility. 

This proposal involves reporting vehicle GHG emissions through the
Department of Motor Vehicles (DMV) registration process.  The way
this could be done is that vehicle owners would report their
odometer readings annually as part of the registration process. 
The GHG emissions can be calculated from this information and a
fee could be charged to reflect total GHG emissions contribution
or GHG emissions in excess of a standard. The data could be put
directly into a statewide database.


Following is an example of how this process could work.  On
registration renewal:
1.  The odometer reading would be reported on the renewal form. 
This could be verified by the DMV once every 3 years and on sale
of vehicle.  (Eventually this information may be available
electronically from the vehicle’s data system.)

2.  Calculate GHG emissions based on total miles for the year and
mpg rating for the vehicle make and model.

3.  Calculate the fee based on a tiered fee rate similar to water
and electricity.
    a.	Tier 1 – Target mpg * 12,000 miles * base rate factor.
    b.	Tier 2 – GHG in excess of Tier 1 * higher rate
    c.	Tier 3 – Can add a second incremental tier rate if 
desired.
4.  Consider adding provisions for public transportation vouchers
for households that are substantially under.

The program can be revenue neutral or can be revenue neutral with
regard to Tier 1 and revenue enhancing for Tier 2 and 3.  Excess
revenues collected from the program could be invested in public
transportation projects.

There are many advantages of this system.  Individuals have
control over their fee.  Someone with a high mpg vehicle and low
VMT may be able to avoid any fee increase.  Whereas taxing
gasoline, taxes everyone.  Individuals will see exactly what their
emissions are per year and understand what they can do to reduce
those emissions.  For every household, automobile use makes up the
major portion of the per person emissions.  Educational programs
can be designed to encourage people to achieve a certain GHG
emission per person.  Low income individuals can control their
fees by reducing their VMT or switching to higher mpg vehicles.

The database will provide the state with important information
regarding vehicle emissions tied to location.  This information
can be used to compare VMT/GHG emissions for various land use
locations and types.  Also, the effects of land use and regulatory
changes can be tracked to a certain extent.  Most importantly, the
system makes individuals responsible for their emissions.  A tax
on fuel does not raise awareness of personal contribution.  Rather
it transfers blame to the oil companies and this disconnect in
accountability results in unplanned increases in emissions.


Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2008-09-02 12:12:18



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