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RGGI Program Review Comments

     These comments were submitted to the Regional Greenhouse Gas Initiative’s (RGGI) Third Program Review. Learn about RGGI, and submit your own comments at: https://www.rggi.org/program-overview-and-design/program-review Peter K. Duval Underhill, VT November 1, 2023 RGGI Program Review Comments Thank you for the opportunity to comment on elements of the Regional Greenhouse Gas Initiative’s (RGGI) Model Rule as part of the Third Program Review. I am a concerned Vermont resident and a former project analyst for an independent energy developer. I participated in the Vermont Public Service Board’s (now Public Utility Commission) Docket 5611, an investigation into environmental externalities. In 1992, I developed a proposal for a low-temperature district heating system for Burlington, VT, based on heat taken at the cooling tower of McNeil Generating Station. I support Partnership for Policy Integrity’s (PFPI) January 2022 comments. (1) The distortions in the carbon trading program have w
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Lost Studies Might Have Saved Time & Money

The proposed steam transmission line between the McNeil Generating Station and the University of Vermont Medical Center (an organization and facility that is distinct from the University) is a train wreck of a project. We could anticipate its 2023 crash from way back in 1984, or 1994, or 2004, or 2014. It may not even be necessary to know or understand the three essential elements of a good district system to judge the proposed steam pipe project. Consider the long history of studies and reports, all of which have resulted in "No Go" outcomes. And then add the fact that Burlington Electric Department, the operator of McNeil on behalf of 9 other Vermont utilities, has lost track of most of those studies. That kind of knowledge management does not inspire confidence. BED is only able to find 4 of 14 historical thermal project studies related to McNeil. There should be several more studies published since 2018, as BED has been spending money liberally in support of the project -
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BDEC's district energy report gets a fresh preface -- a 30 year update

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There is a proposal being pushed by Burlington Electric Department (BED) to connect a steam transmission line between the J.C. McNeil Generating Station and the hospital. It's not good. Indeed, it's an idea that should have been stopped early at an internal BED meeting after about 10 minutes of discussion. In 1992, Dermot McGuigan and I developed a project proposal to serve Burlington with low-temperature district heat that would have taken heat from the cooling water at the McNeil Generating Station. It was a project for its time and the future, which is now here.  In 2023, district energy system supply temperatures in new systems are so low that uninsulated pipes can be used. (Lund, et.al., 2014,  https://doi.org/10.1016/j.energy.2014.02.089 ) created a widely reproduced graphic that illustrates the long-running temperature trend in district energy systems (also called district heating and cooling). The notion of using steam in a new system today is unfathomable. (Lund, et.al
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VT PUC Case No. 23-1870-PET, Public Comment

 My public comments ( PDF ) entered in Case No. 23-1870-PET : July 3, 2023  Vermont Public Utility Commission  Case No. 23-1870-PET  Dear Commissioners,  Thank you for the opportunity to comment on Case No. [ 2 ]23-1870-PET, as requested by the Commission’s Procedural Order of June 9, 2023.  Some time ago, I participated in the Public Service Board’s Docket #5611, an investigation into environmental externalities. There is one memory that I would like to share with you:  The investigation lasted many months and involve[d] utilities, environmental groups, and of course, the Department of Public Service (PSD, then DPS). Beginning in September 1992, Docket #5611 was a series of workshops on the general problem of environmental externalities and included greenhouse gas regulation. It was a thorough investigation using the best available information from the best universities and think tanks. I’ve lost track of the number of day-long meetings we had. It was a lot.  We met at the NECI confer
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Real-Time Ridesharing

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This is not that bold. And it is not Uber. It's more just looking at the facts and realizing it's way past time to act. Here are some facts: Vermonters drove many kilometers solo in their cars. Vermonters spent a lot of money on their cars. Vermonters spent many hours in traffic delays...solo in their cars. Vermont cars spend most of their time just taking up space and idly depreciating. Vermont has many lane kilometers (lane miles) of Interstate, Limited Access, State Highway; and, Class 1-4 Town Highway, which are empty most of the time. While we have been driving, other people around the world have been living lightly and more economically. We have a lot of catching up to do, and we can't if we are still driving cars. The goal for everyone -- in every measure -- is zero. Zero fatalities. Zero impact. Zero emissions. Zero combustion. If there is a bold idea here, it is the realization that zero combustion means eliminating all internal combustion engine vehicles from Verm
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They Just Don't Get It

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TL;DR: The insurmountable problem with electric cars is that they are cars. Phil Scott got a new truck. Brenda Siegel wants it too, and also wants everyone else to get an electric car. The F150 Lightning is a fine pickup truck, I'm sure. But will the planet survive 8 going on 10 billion people cruising around in electric vehicles? Clearly, no. Phil and Brenda just don't get it. It doesn't matter how green a car is. It could have zero embodied emissions from production and zero emission during its operating life. It could be free of mining, shipping, and casualty costs. It's the fact that it's an automobile with tires , one that takes up space and infrastructure, in a garage or rolling down a road -- fundamentally incompatible with a living planet.  Roads themselves are sufficiently damaging to make everything else associated with them unacceptably unsustainable. Vermont's rural road system is the worst of the worst. Vermont has 30% more lane miles per capita
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Ensuring a good start

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TL;DR: Parent or child stipends and paid family leave appear to be effective ways to ensure infants and toddlers get a good start. 'Fund the child, not the child care center' may be the catchphrase. Possible additional efforts include Grade 13, livable minimum wage, a 4-day workweek, and remote work. My campaign has been about changing the debate and uncovering underlying patterns that connect the issues. For every crisis, we must ask, "Is the question well-posed? Is it accurate framing? What are the alternative ways of looking at it? Is it a solution posed as a problem? Does it describe the bottom of the problem, or is there something deeper? What links it to other crises?" A report to the Legislature by Regenstein and Patel recommends creating "a new unit of state government that is focused entirely on early childhood." -- https://legislature.vermont.gov/assets/Legislative-Reports/Vermont-Child-Care-and-Early-Childhood-Education-Systems-Analysis-Final-Repo
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