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