4/20/2021 |
Ellen |
Benitez |
MAPDA |
Annapolis |
Maryland |
The proposed Transportation Climate Initiative (TCI) Model Rule is unlikely to reduce carbon dioxide emissions from motor vehicles by a targeted 66 million tons a year by 2032. In fact, using... read more The proposed Transportation Climate Initiative (TCI) Model Rule is unlikely to reduce carbon dioxide emissions from motor vehicles by a targeted 66 million tons a year by 2032. In fact, using real-world examples from California, the Rule may have no impact at all on emissions. It is clear, however, that gasoline and diesel fuel prices will rise under the Model Rule. Fuel distributors must buy emission allowances under the Model Rule, and the cost will be passed onto consumers at the pump. TCI’s Model Rule is actually a regressive tax costing all families about the same. TCI will cost each family thousands of dollars over the next decade, and those in poverty are least able to absorb those costs. In addition, the Model Rule establishes a fixed budget of available allowances by year (pg. 44) and fuel can’t be delivered without an allowance. If TCI estimates of program success are wrong, and fuel demand doesn’t fall as expected, needed fuel can’t be delivered. TCI could plunge the region into motor fuel shortages and 1970’s style lines at the pump.
The Model Rule also moves motor fuel taxing authority from states to a non-governmental regional authority. We believe that ceding authority in this way is always a bad idea. Unlike traditional gasoline taxes, the revenue raised from allowance auctions will not go to maintaining and building highways in the local area. TCI plans to spend most of the money raised subsidizing electric vehicles, public transportation, and walking and biking trails. Electric vehicles weigh an extra thousand pounds, which adds more strain on highways, but pay no tax toward highway trust funds. States will have to raise gas taxes to make up for this revenue shortfall.
TCI claims 35% of funds will be spent on projects to bring more equity for low income communities (pg. 41), but the Model Rule is short on specifics. Urban areas already rely on public transportation. Subways and trains already run on electricity. Much of the nation’s bus fleet has already been transitioned from diesel to lower emitting natural gas and propane1. Replacing buses with electric versions that cost two to three times as much provides little additional value. Plans to add walking and biking trails in urban areas will likely find recreational use, but are unlikely to reduce commuting travel, especially in cold, wet weather.
The Model Rule establishes target emission allowance prices where allowances will be added or removed from the auction to control the auction price (pgs. 9-10). That is an engineered exercise to manipulate the price of emission allowances rather than a market-rate auction. TCI forecasts an average price that would add 11 cents to a gallon of gasoline in 2022, rising to 27 cents by 2032. TCI’s own worst case estimate pegs a surcharge as high as 41 cents2. At a minimum, TCI will cost a typical household $2,000 over the next decade, or about $187 a year3. The worst case scenario could cost households $414 in 2032, and total $4,550 by 2032. Low income rural families will be hurt the most, and the Model Rule offers no relief for those families.
Adding to the economic injustice, much of the money raised from the emission allowances will be used for subsidies for electric vehicles. Many studies show that electric vehicles are often bought by wealthy individuals for access to High Occupancy Vehicle lanes as a single occupant. The national Renewable Energy Laboratory estimates 86% of EVs are bought by people making over $60,000 a year4. TCI money will also be given as subsidies for public and private electric vehicle charging stations so those wealthy families can recharge their vehicles anywhere. Since over 80% of charging occurs overnight at home4, utilities are offering lower electric rates after 8 PM saving these wealthier families even more money.
TCI documents2 target a 6% reduction in emissions from an expected 2022 forecast level of 253 million tons, or 15 million tons per year emission savings by 2032 for twelve states and the District of Columbia. An emission allowance budget is established for each state. In the appendix of the September, 2020 TCI webinar a study by ICF International indicates only 11.8 million tons will be saved annually and that is partially offset by increased emission of 3.7 million tons from increased electric generation to power the increased number of electric vehicles. The actual emissions savings may only be 8 million tons per year, or 3%.
TCI is partially counting on higher prices to discourage driving, but travel necessity makes fuel use inelastic. A study by the U.S. Energy Information Agency5 found motor fuel prices would need to increase 25 to 50 percent to reduce driving by 1 percent, or to about $3.72/gallon in today’s dollars. The Model Rule forecasts a maximum price of 27 cent/per gallon which might only reduce emissions by about 0.2%, or 0.5 million tons.
Another flawed TCI assumption is a planned $4,000 subsidy per electric vehicle against a premium purchase price of $12,000 will stimulate sales by 10 million vehicles by 20322. This will use up to 80% of the expected emissions allowance auction revenue. TCI’s assumption does not connect with actual experience. Currently, there is a more generous federal subsidy of $7,500 per vehicle which has only stimulated sales of about 300,000 vehicles a year6. This translates to 3 million vehicles over ten years, for a CO2 reduction of about 2 to 5 million tons a year by 2032.
Considering the low impact of higher fuel prices on the miles people drive, and likely lower electric vehicle sales than forecasted, direct emission savings from TCI might only be about 2.5 to 5.5 million tons per year, a fraction of the 15 million ton forecast.
The big TCI forecast savings, 51 million tons, is supposed to come from federal programs for higher mile per gallon standards and alternative fuels. The US Energy Information Agency released its 2021 Annual Energy Outlook and only expects a 4% reduction in petroleum based transportation emissions between 2022 and 2032 equaling only a 10 million ton reduction in the TCI region by 20327.
In addition, transportation emissions in the TCI region in 2018 were 347 million tons so reaching the 2022 target of 253 million tons would require a 27% reduction, or 94 million tons8. Between 2012 and 2018 emissions actually increased 9.5% as miles per gallon improvement was eclipsed by more miles traveled, and more vehicles on the road. It is unlikely the TCI region will meet the starting goal of 253 million tons by 2022.
Taking into account a higher emission starting point in 2022 and a slower contribution to emission reductions from federal programs by 2032, we believe the expected 51 million ton 2032 TCI target is a pipe dream. Based on TCI’s own documents it is actually possible there will be zero emissions reductions by 2032 even if all the regional target jurisdictions adopt TCI. Yet the number of allowances allowing fuel delivery will be reduced in lockstep with the TCI plan which assumes the 66 million ton TCI forecast reduction. The imbalance in available allowances compared to actual demand could lead to massive shortages of motor fuel.
In conclusion, TCI will likely fail to significantly reduce carbon dioxide emissions from motor fuels, but will raise fuel prices hurting the poor the most, while leaving states short of highway trust funds, and out of the loop in controlling taxes. Worst case, the plan may result in fuel shortages leading to panic and long lines at the pump. This is a bad idea for Maryland and Delaware.
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MAPDA Model Rule comments final .pdf |
5/7/2021 |
Kirk |
McCauley |
WMDA/CAR |
Bowie |
Maryland |
I have uploaded comments I have uploaded comments |
Comments on Proposed TCI Model Rule.pdf |
5/7/2021 |
Brian |
O'Malley |
On behalf of 14 signatories including the Central Maryland Transportation Alliance |
Baltimore |
Maryland |
Please see the attached letter signed by 14 organizations in Maryland. Please see the attached letter signed by 14 organizations in Maryland. |
Joint Comments_ TCI-P Draft Model Rule and Public Engagement - Maryland Advocates.pdf |
5/7/2021 |
Alison |
Bennett |
Saint Mark Presbyterian Church |
Potomac |
Maryland |
I am a Presbyterian elder who cares deeply for God’s creation. A stable climate is the most fundamental determinant of health. With our pollution, we are contributing to more and earlier deaths... read more I am a Presbyterian elder who cares deeply for God’s creation. A stable climate is the most fundamental determinant of health. With our pollution, we are contributing to more and earlier deaths and disability. Transportation is the biggest source of greenhouse gas emissions in Virginia and the region, as well as dangerous particulates that cause health problems like asthma. We have not only a health issue, but a moral issue because particulate emissions especially impact people living near major roads, which are often lower income and minority communities. We need a clean transportation system, and a clean-energy economy. Because I live just across the river, everything Virginia does to affect its air affects me.
TCI-P will greatly help Virginia and the region do this. I support a strong TCI-P Model Rule that (1) ensures meaningful climate action to address Virginia's largest driver of our climate crisis, (2) directs significant investments to correcting historic inequities in overburdened and underserved communities; and (3) affords Virginia the opportunity for a cleaner, healthier transportation system. |
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5/7/2021 |
Joanne |
Ivancic |
Advanced Biofuels USA |
Frederick |
Maryland |
Comments from Advanced Biofuels US
on the
Transportation & Climate Initiative (TCI)
TRANSPORTATION AND CLIMATE INITIATIVE PROGRAM DRAFT Model Rule
Having... read more Comments from Advanced Biofuels US
on the
Transportation & Climate Initiative (TCI)
TRANSPORTATION AND CLIMATE INITIATIVE PROGRAM DRAFT Model Rule
Having participated in many of the in-person and online meetings and stakeholder events related to developing the Transportation and Climate Initiative Program, Advanced Biofuels USA is pleased to see that the proposed TCI-P emissions calculations focus on the fossil fuel component of fuel in the Emissions and Allowance Tracking System (EATS)
(Emissions and Allowance Tracking System (EATS). A system comprised of the Allowance Tracking Sub-system, by which the REGULATORY AGENCY or its agent records allocations, deductions, and transfers of CO2 allowances under the TCI-P, and the Emissions Tracking Sub-system, by which a JURISDICTION fuel supplier or reporting-only entity reports CO2 emissions from the combustion of fossil fuel and other data as required in Subparts XX-8 and XX-9.)
We note that the initial focus is on-road fuel use; however, the immediate benefits of transitioning away from fossil power for existing planes, trains, automobiles and equipment can be realized by expanding this approach and the limited application in the TCI-P should not only be retained, but broadened.
The TCI-P clearly recognizes that use of non-fossil fuels should be encouraged as a beneficial substitute for fossil fuels in transportation. They are the quickest, least expensive, most effective way to reduce GHG emissions and other pollution for the greatest number of people and with the most immediate environmental justice impact.
However, the TCI-P only covers “motor gasoline or on-road diesel fuel” defined as:
Motor gasoline. Any fuel, except for aviation gasoline, that:
(1) Is commonly or commercially known as gasoline, including blendstocks CBOB and RBOB;
(2) Is intended or used to power a vehicle or engine designed to operate on gasoline; or
(3) Conforms to the specifications of ASTM D4814 and is made available for use in a vehicle or engine designed to operate on gasoline
On-road diesel fuel. Any fuel that is delivered to a filling station for use in a diesel-powered highway vehicle and:
(1) Is commonly or commercially known as diesel fuel;
(2) Is intended or used to power a vehicle or engine that is designed to operate using diesel fuel; or
(3) Conforms to the specifications of ASTM D975 and is made available for use in a vehicle or engine designed to operate using diesel fuel.
It is especially egregious that the TCI-P specifically excludes “aviation gasoline” defined as “A complex mixture of relatively volatile hydrocarbons, with or without small quantities of additives, blended to form a fuel suitable for use in aviation reciprocating engines and meeting ASTM Specification D910 or Military Specification MIL-G-5572.” Not only should D910 fuel be included in the TCI-P to encourage transition to renewable fuel, but also because it is a leaded fuel (for which there exist alternatives). Environmental justice benefits would also accrue to communities located near airfields that sell and use this fuel to prevent lead poisoning.
In addition, there is no mention of aviation fuel that meets the standard of ASTM D1655-20d, the Standard Specification for Aviation Turbine Fuels. With many airports both large and small in the region, it seems that incentives to convert away from fossil fuel for air transport should also be a part of the TCI-P.
Another sector left out of this program is the agricultural sector. Diesel-powered farming equipment should not be overlooked as a source of GHG emissions. The carbon footprint of farming could be reduced with use of renewable fuels such as drop-in renewable diesel, biodiesel blends and renewable natural gas.
It appears that fossil diesel use in trains has also been omitted from this program. Some train systems are in the process of converting to renewable fuel. Such conversion should also be encouraged by the TCI-P, especially for the non-electric commuter train systems.
In addition, use of fossil compressed natural gas and liquid natural gas are omitted from the program and should be included.
Of greater import, marine/maritime fuels are also left out of this program. For a region that is situated along the East Coast of the US, transition to renewable fuels for the shipping sector should be encouraged as a way to also motivate using renewable fuels to comply with International Maritime Organization standards.
Also, the region has space launch facilities and the greenhouse gas emissions from fossil fuel used in missiles and rockets should also be included in the TCI-P in order to provide incentives for transition to renewable or otherwise low GHG emission missile/rocket fuels. Investment in research conducted in this area would benefit from recognition of the need for this sector to transition away from fossil fuel.
In addition, it might be a good idea to use a term like “non-fossil-derived fuel” instead of “biomass-derived”. For example, in “Biomass-derived content as a percent (i.e., percent of the total fuel volume that is not derived from any fossil fuel).” This would accommodate future fuels that are made from recycled carbon such as industrial waste gases and from green/renewable hydrogen and captured carbon dioxide or other non-biomass substances.
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21 0507 TCI comments FINAL.pdf |
5/7/2021 |
Mark |
Eakin |
retired |
Silver Spring |
Maryland |
Transportation is the biggest source of greenhouse gas emissions in the region, as well as dangerous particulates that cause health problems like asthma. Particulate emissions especially impact... read more Transportation is the biggest source of greenhouse gas emissions in the region, as well as dangerous particulates that cause health problems like asthma. Particulate emissions especially impact those near major roads, which often include lower income and minority communities. To solve these problems we need to move to a clean transportation system, and a clean-energy economy. TCI-P will greatly help the region do this – it will improve air quality, lower health care costs, reduce greenhouse gas emissions, and generate revenue for other environmental initiatives to further accelerate our progress.
I support a strong TCI-P Model Rule that (1) ensures meaningful climate action to address the largest driver of our climate crisis, (2) directs significant investments to correcting historic inequities in overburdened and underserved communities; and (3) affords the opportunity for a cleaner, healthier transportation system. I call for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and underserved communities receive a greater-then-proportional share of investments from the program, (2) integration of air quality commitments across the region, and (3) robust empowerment of state equity advisory bodies |
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5/7/2021 |
Scott |
Wilson |
EV Driver |
Silver Spring |
Maryland |
This is not a tax on gasoline and diesel! This is a more accurate accounting of the true cost of gasoline and diesel. It is an elimination of the free-ride subsidy gasoline and diesel have enjoyed... read more This is not a tax on gasoline and diesel! This is a more accurate accounting of the true cost of gasoline and diesel. It is an elimination of the free-ride subsidy gasoline and diesel have enjoyed for years. It’s time for us to stop pretending that using gasoline and diesel has no cost: it does.
The funds collected don’t just vanish, either. The TCI proposal directs them in a productive way to clean up the transportation system, which benefits us all, and will begin paying off immediately.
Gas prices will not skyrocket! Any increases the distributors pass on will be well below the normal fluctuations we all live with. Even setting the highest cap with 25% reduction will be almost unnoticeable at the pump. Distributors will continue to compete with each other on price. Let the free market rule!
Some say this will have a negligible effect on reducing emissions. This argument assumes a baseline that already has a huge uptake of EV’s, which we are no where close to yet. We should think of TCI as insurance against the mischief and backsliding supported by fossil fuel interests.
It’s time to start being responsible for our actions. |
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5/8/2021 |
Ronald |
Kaltenbaugh |
EVADC |
Jefferson |
Maryland |
Enacting strong and robust TCI rules is critically important. This is an important tool in needed efforts to electrify all forms of ground transportation. Our fossil fuel vehicles are killing us... read more Enacting strong and robust TCI rules is critically important. This is an important tool in needed efforts to electrify all forms of ground transportation. Our fossil fuel vehicles are killing us in so many ways and this needs to stop. Climate change, poor air quality, and added healthcare costs, are just a few reasons why we need to act. TCI can ensure that we address these issues along with correcting historic inequities in overburdened and underserved communities. Also, our addiction to fossil fuels often provides funding to terrorist groups and unfriendly governments around the world. Any one of these reasons is enough to support vehicle electrification and TCI, added together, they make this an imperative with benefits for everyone. |
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5/8/2021 |
Bob |
Erdman |
Self |
Potomac |
Maryland |
The cost of climate change will be reduced by programs such as the TCI-P. The longer we wait to mitigate climate change, the more it will cost in the future.
Transportation is... read more The cost of climate change will be reduced by programs such as the TCI-P. The longer we wait to mitigate climate change, the more it will cost in the future.
Transportation is the biggest source of greenhouse gas emissions in the region, as well as dangerous particulates that cause health problems like asthma. Particulate emissions especially impact those near major roads, which often include lower income and minority communities. To solve these problems we need to move to a clean transportation system, and a clean-energy economy. TCI-P will greatly help the region do this – it will improve air quality, lower health care costs, reduce greenhouse gas emissions, and generate revenue for other environmental initiatives to further accelerate our progress.
I support a strong TCI-P Model Rule that (1) ensures meaningful climate action to address the largest driver of our climate crisis, (2) directs significant investments to correcting historic inequities in overburdened and underserved communities; and (3) affords the opportunity for a cleaner, healthier transportation system. I call for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and underserved communities receive a greater-then-proportional share of investments from the program, (2) integration of air quality commitments across the region, and (3) robust empowerment of state equity advisory bodies |
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8/13/2021 |
Brian |
O'Malley |
On behalf of 13 signatories including the Central Maryland Transportation Alliance |
Baltimore |
Maryland |
Joint Comments: TCI-P Draft Policy Statements
August 13, 2021
To: TCI Leadership Team: Kathleen Theoharides, Secretary, Massachusetts Executive Office of Energy and... read more Joint Comments: TCI-P Draft Policy Statements
August 13, 2021
To: TCI Leadership Team: Kathleen Theoharides, Secretary, Massachusetts Executive Office of Energy and Environmental Affairs and R. Earl Lewis, Jr., Deputy Secretary, Maryland
Department of Transportation TCI Executive Policy Committee: Marty Suuberg, Commissioner, Massachusetts Department of Environmental Protection and Roger Cohen, Senior Advisor to the Secretary, Pennsylvania Department of Transportation
TCI Technical Analysis Workgroup: Christine Kirby, Assistant Commissioner, Massachusetts Department of Environmental Protection and Chris Hoagland, Economist, Climate Change Division, Maryland Department of the Environment
TCI Investment and Equity Workgroup: Garrett Eucalitto, Deputy Commissioner, Connecticut Department of Transportation, Kate Fichter, Assistant Secretary, Massachusetts Department of Transportation, Kirsten Rigney, Legal Director, Connecticut Department of Energy and Environmental Protection and Dan Sieger, Undersecretary of Environmental Affairs, Massachusetts Executive Office of Energy and Environmental Affairs
TCI Outreach and Communications Workgroup: Chris Bast, Chief Deputy, Virginia Department of Environmental Quality and Elle O'Casey, Director of Communications and Outreach, Vermont Agency of Natural Resources
Governors and Other State Officials: Connecticut, Delaware, New Hampshire, New Jersey, New York, North Carolina, Maryland, Massachusetts, Pennsylvania, Rhode Island, Vermont, Virginia
Mayor and Other City Officials: District of Columbia
The undersigned organizations and individuals are based in Maryland and have been following the process to develop the Transportation and Climate Initiative Program (TCI-P). We urge you to ensure that the TCI-P is effective and equitable. To those ends many of the undersigned individuals and organizations submitted comments individually and/or jointly on the Draft Model Rule in May. We also reviewed and discussed the package of updates and new materials released for public comment in June. We offer comments and recommendations on the following aspects of the program and ask you to revise the draft policy statements and/or the Model Rule to better address them.
Air Quality Goals and Air Quality Monitoring
Disadvantaged communities usually have the worst air quality; therefore, the guiding principle must be to improve the air in those communities first.
The air quality monitoring plans in the draft policy documents are vague. The use of technical experts and inclusion of experts on the Equity Advisory Bodies in each state are very important steps. We respectfully suggest that the planned air quality monitoring be hyperlocal. Studies such as one looking at mobile emissions in Newark, New Jersey (attached) have provided valuable information on sources and levels of pollution in communities. However, they must often rely on modeling due to the lack of sufficient air quality monitoring. An approach worth considering is an amendment to the INVEST in America Act introduced in the House this session that calls for detailed monitoring in communities where pollution hotspots are located (see press release from the House Select Committee on the Climate Crisis). It is unclear what will be included in the final reconciliation package in Congress, so it is important that TCI jurisdictions have their own detailed plans.
Additionally, not all sources of air pollution will be affected by the TCI-P proposal. This includes air pollution from energy generation and air pollution blown in from outside jurisdictions. What modeling has been done to estimate the regional reductions with time that are to be expected? This would greatly help inform the program review to be conducted at three years to assess whether goals are being achieved or if they should be ratcheted up.
We realize that the initial goals of TCI are a compromise to enhance chances for adoption. However, with the release of the IPCC press report (attached) on August 9, 2021 indicating that the climate crisis is proceeding at a more rapid clip and that more drastic action is necessary, we respectfully request that the goals be readjusted now from the inception to be in-line with what is needed to stave off disaster. From the IPCC: In model pathways with no or limited overshoot of 1.5°C, global net anthropogenic CO2 emissions decline by about 45% from 2010 levels by 2030 within 40–60% interquartile range (see report on Global Warming of 1.5° C from the IPCC Intergovernmental Panel on Climate Change).
Public Engagement
This section has several guiding principles. The overarching principle, to allow communities to have a stake in the TCI process and own parts of it, seems to be missing. While an Equity Advisory Body is an important first step, it cannot single-handedly ensure equity within the TCI-P. There are established ways to work towards more comprehensive public engagement and mitigation of discriminatory impacts. With that in mind, we offer the following feedback for strengthening public engagement in the TCI-P.
Though equality and equity are distinct goals, TCI-P has an obligation to work towards both as a means of addressing disparities. To achieve this purpose, the Model Rule must more explicitly include specific Title VI Public Participation Guidelines, as required by USDOT Federal Transit Administration. There are specific criteria, guidelines, and programs that distinguish successful agency programs in ensuring meaningful public participation (see California EPA’s Public Participation Manual). The Model Rule should use Title VI as an example of what TCI-P jurisdictions should and should not do in engaging the public.
Community members need to know the levels of pollutants to which they are exposed, and agencies need to learn from the community the public health impacts they are experiencing in order to address the harm.
Agencies need to have a clear understanding of the proactive strategies, procedures, and desired outcomes for their public participation activities. Their public participation plan should be guided by an internal review of how, when, and why public involvement is critical.
The Model Rule should not only recommend specific actions to ensure meaningful public participation in transportation emissions decision-making but also note that there are important indicators for when a public participation program is not successful. If one or more of these indicators is present, the underlying cause(s) should be examined because there are reasons that these circumstances might occur, even if the program itself is sound. It is critical to the success of the program that gaps that result in less meaningful public participation be quickly identified and corrected.
The goal of any public participation process must be to empower communities to advance local residents’ causes, to educate the public, and to influence local policymakers through the voices of the local community affected residents. The program must give communities the power to decide and empower grassroots leaders to develop actionable strategic plans for environmental equality within the affected frontline and fenceline communities.
Additionally, we offer the following responses to the questions posed in the draft framework for public engagement.
1. Is anything missing from this proposed public engagement approach that is important to you?
Under Principle number 1), labor and youth should be particularly included. Youth face specific problems when riding public transit to school, and the school bus system is often overlooked. Also, “meaningful and effective public engagement” should be spelled out, with definitions and/or examples of what would make public engagement meaningful and what would make it effective.
Under Principle number 2), it should be specified which channels of communication the TCI jurisdictions will be using to communicate with stakeholders, how they plan to communicate with non-English speakers, and what information they are planning to share with stakeholders besides where TCI proceeds will be spent.
Under Principle number 4), rather than simply recognizing a community's knowledge and expertise, they should also incorporate communities’ recommendations. This is key, as communities must have a say in the decisions that affect their lives.
Under Principle number 6), they should spell out what they mean by “build capacity” or how they plan on building this capacity.
Also, working with community connectors is key to reaching out to some populations that are hard to reach and could benefit immensely from improving our transportation infrastructure and reducing emissions from this sector. These connectors are groups that have agency, social capital, and the infrastructure to act and disseminate information (faith groups, youth, community serving organizations, justice groups in general, health groups). These are groups that are engaged in the community in other social issues such as health or youth, have cultural competency, and can be connectors.
2. Are there any aspects of the proposed approach that are particularly relevant or important to you?
All the principles are very important. There are two that we would highlight: number 5 as access and representation are key, especially for communities that have historically been underrepresented or not represented at all. And number 6), as there is a need for building capacity in communities that have been underrepresented. Building long-term capacity is critical to ensure long-term participation in this and other opportunities.
3. How could TCI-P jurisdictions provide additional opportunities and entry points for environmental justice, equity, and other stakeholders to meaningfully engage in the implementation of TCI-P?
There is a need to map out different communities across Maryland to make sure there is an opportunity for them to participate. Often, the same communities or advocates dominate the conversation, so mapping out stakeholders and communities from the onset will ensure broader engagement.
4. Does anything need to be added to these principles to guide each jurisdiction’s implementation of TCI-P to effectively target benefits for environmental, climate, and transportation justice communities, tribal communities, and other equity stakeholders (e.g., air quality improvement, access to reliable, low-cost transportation options)?
No additional comments.
Prioritizing Investment in Overburdened and Underserved Communities
Our current transportation system is deeply inequitable. The overarching guiding principle for TCI is, therefore, to overcome existing inequities in transportation impacts (such as noise and pollution) and inequities in access. As research from the Union of Concerned Scientists shows, Black and Brown communities face disproportionate exposure to and health harms from transportation vehicle pollution.
Low-income families and individuals across urban, rural, and suburban areas struggle to obtain safe and affordable transportation to work, school, medical appointments, recreation, and other needs. Many of these same overburdened and underserved communities are on the front lines of and most vulnerable to the impacts of climate change.
Given the attention to overburdened and underserved communities in the Draft Framework for Public Engagement and Draft TCI-P Model Implementation Plan, as well as in the goal of investing at least 35% of TCI expenditures in said communities, the way that these communities are identified is very important. While each jurisdiction’s Equity Advisory Board will play a role in developing the criteria for this definition, the TCI-P should suggest multiple points in that process where opportunities for meaningful input by each Equity Advisory Board will be added and ensure that each Equity Advisory Board has sufficient authority to establish or revise the definition. Additionally, the TCI-P should recommend a few major categories to consider the cumulative impacts of, such as air pollution burdens; at-risk groups; socioeconomic factors; access to jobs, schools, healthy foods and other destinations via auto and non-auto modes of transportation; and communities where a high percentage of workers spend at least 45 minutes commuting to work . The TCI-P jurisdictions should also identify data gaps and strategies to address them (e.g., air quality monitoring, access to jobs from suburban communities) as a part of TCI implementation to ensure these communities are identified with enough accuracy and spatial specificity.
Sincerely,
Archplan Inc.
Bikemore
Central Maryland Transportation Alliance
Chesapeake Physicians for Social Responsibility
Climate Law & Policy Project
Coalition for Smarter Growth
Indivisible Howard County
Maryland Conservation Council
Maryland League of Conservation Voters - Chispa Maryland
Maryland Sierra Club
Oncologists United for Climate & Health
Rails-to-Trails Conservancy
Unitarian Universalist Legislative Ministry of Maryland, Climate Change Task Force
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Joint Comments_TCI-P draft Policy Statements_Aug 13 2021.pdf |
8/13/2021 |
Ellen |
Valentino |
Mid-Atlantic Petroleum Distributors Assn. |
Annapolis |
Maryland |
See enclosed document See enclosed document |
Comments on TCI Aug 2021.pdf |
8/18/2021 |
Brian |
O'Malley |
On behalf of 17 signatories including the Central Maryland Transportation Alliance |
Baltimore |
Maryland |
Please accept this updated version of the letter we originally submitted on August 13, 2021. It includes an added section titled “Promoting Local Economic Opportunity and Creating High Quality... read more Please accept this updated version of the letter we originally submitted on August 13, 2021. It includes an added section titled “Promoting Local Economic Opportunity and Creating High Quality Jobs: Recommendations to the Draft Model Implementation Plan (MIP) and Proposed Strategies for Regional Collaboration” and additional signatories. |
Updated Joint Comments_TCI-P draft Policy Statements_Aug 18 2021.pdf |
8/16/2021 |
Raymond |
Daskoski |
Republican/conservative |
Chelsea |
Maine |
It's just another way/excuse to get money that can be spent recklessly. The Last thing Americans need is to have more or high taxes, this especially includes new taxes
read more It's just another way/excuse to get money that can be spent recklessly. The Last thing Americans need is to have more or high taxes, this especially includes new taxes
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5/7/2021 |
Dan |
Bowerson |
Alliance for Automotive Innovation |
Southfield |
Michigan |
Please find attached supportive comments for the TCI-P Model Rule from the Alliance for Automotive Innovation. Please find attached supportive comments for the TCI-P Model Rule from the Alliance for Automotive Innovation. |
Auto Innovators Comments_TCI-P Model Rule_200507.pdf |
4/12/2021 |
Juan |
Briceno |
Benchmark Renewable Energy |
Wilkesboro |
North Carolina |
Dear sir:
We want to know the impact of low carbon renewable ethanol produced in the southeast may have in the TCI P.
1. Will there be an incentive per gallon for low carbon index... read more Dear sir:
We want to know the impact of low carbon renewable ethanol produced in the southeast may have in the TCI P.
1. Will there be an incentive per gallon for low carbon index ethanol produced like the Low Carbon Fuel Standard (LCFS) implemented in California?
2. Will the regulated fuel supplier be able to reduce their purchases allowances if they use lower carbon index ethanol or higher blending fuels such E15, E85?
Juan Briceno |
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4/14/2021 |
Will |
Scott |
NC Conservation Network |
Raleigh |
North Carolina |
See attached our comments on the Model Rule. See attached our comments on the Model Rule. |
2021.4.14 NC Conservation Network TCI_Model_Rule_Comments.docx |
5/8/2021 |
Maple |
Osterbrink |
TEVANC & NCWARN |
Chapel Hill |
North Carolina |
We need (TCI-P Model) Rules for climate crisis action, repair EJ communities' harms done (some energy & health effects reparations). Also electric (NOT toward more vehicle methane)... read more We need (TCI-P Model) Rules for climate crisis action, repair EJ communities' harms done (some energy & health effects reparations). Also electric (NOT toward more vehicle methane) cleaner transport both more public (solar!) charging stations but focus on electrified public streetcars system. (see solutionaryrail.org)
We'd like a minimum investment amount to ensure overburdened communities get a bigger share of investments to match renewable resolutions across the state. |
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4/1/2021 |
Elizabeth |
Cerceo |
Cooper Hospital |
Cherry Hill |
New Jersey |
As a physician, it is critically important that we make rapid changes in our infrastructure in favor of a carbon neutral future. The toll on our residents particularly the poor and disenfranchised... read more As a physician, it is critically important that we make rapid changes in our infrastructure in favor of a carbon neutral future. The toll on our residents particularly the poor and disenfranchised cannot be underestimated and impacts increase year after year. I would encourage quickly implementing the initiative as we are losing time to reverse the worst effects of climate change. |
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5/7/2021 |
JAMES |
STEVENS |
private citizen |
HENDERSON |
Nevada |
I do not supoport this initiative that puts America's economic needs at risk while other nations are given a waiver because they claim some "developing" status. If we are going to... read more I do not supoport this initiative that puts America's economic needs at risk while other nations are given a waiver because they claim some "developing" status. If we are going to make the World better for all of us, we need a comprehensive, no-waivers, all nations plan of attack.
American can not and should not go it alone on this issue. We will all be long gone before this planet is no longer habitable (if that ever happens). The science on this issue to too mushy to proceed at this time. |
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3/24/2021 |
Thomas |
Modzelewski |
Citizen |
New York |
New York |
Please see attached Comment Letter Please see attached Comment Letter |
TCI-P Comment Letter Submission_TJM.pdf |