TCI Regional Policy Design Stakeholder Submissions

Attached please find Joint Comments from the Northeast Clean Energy Council, the Alliance for Clean Energy New York, and Renewable Energy Vermont

Virginia Conservation Network is the partnership of 125 groups across the Commonwealth working to protect our natural resources. We have a 50 year history of working for state level policy changes to protect and restore our air, water, and natural landscapes.

Climate change is the biggest environmental threat we face here in Virginia and across the globe. All levels of government must step up to address this threat by putting policies in place that reduce carbon emissions. Virginia is on a path to joining the Regional Greenhouse Gas Initiative to ratchet down our carbon pollution from electricity generation with a statewide goal of getting to a carbon free power grid by 2050. However, the utility sector is only on fifth of our greenhouse gas emissions, forty-six percent of our state’s carbon pollution derives from the transportation sector. It is time for Virginia, our neighboring states, and the nation to tackle this source of pollution.

VCN is excited about the solutions the Transportation and Climate Initiative (TCI) could offer our Commonwealth. TCI would not only put in place a system to reduce carbon pollution from transportation, the resulting revenue streams from TCI could allow us to expand our transit networks and transition our vehicle fleets—from police cruisers to school buses—to all-electric. The potential for revenues to be invested in cleaner and more accessible transportation solutions in communities that suffer disproportionately from transportation pollution and a lack of mobility options can not be overstated. It is important that while we look towards transportation solutions we look not only to electrification but also to smart land-use including walkable, bikeable communities. We look forward to working with TCI and our neighboring states to tackle this problem from all angles.

There are many co-benefits to cleaning up our transportation system; however, the benefits for public health would prove especially significant. Virginia’s rate of asthma and related deaths is well above the national average. Richmond in particular has more deaths linked to asthma than any other U.S. city, and childhood asthma is a top reason that Richmond children miss school. Cleaner vehicles would mean cleaner air for our kids to breathe.

We are excited to support this endeavor to simultaneously tackle the climate crisis, enhance our region's mobility and make a significant shift towards cleaner, healthier communities.

I'm asking you to design a regional low-carbon transportation policy proposal that would cap and reduce carbon emissions from the combustion of transportation fuels through a cap-and-invest program or other pricing mechanism… [and]… to complete the policy development process within one year, after which each jurisdiction will decide whether to adopt and implement the policy.”

Please see the attached comments from Exelon Corporation and Public Service Enterprise Group.

TCI Public Comment
Kevin Ellicks
2/26/20
As an environmental science student at Middlebury College, topics raised and discussed in class are often specific to Vermont and nearby areas. This semester, I am participating in a seminar concerning sustainable transportation in Vermont and its relation to accessibility, participation, and independence. Clearly then, the Transportation Climate Initiative is of particular relevance to my coursework.
The effects of climate change are becoming increasingly visible in Vermont and across the world. If the general population continues living out our lifestyles without enacting significant change, climate-related occurrences will only increase in severity and frequency. The Transportation Climate Initiative posits measures to reduce the pollution stemming from the transportation sector across the Upper South Atlantic, Mid Atlantic, and North Eastern states, more specifically, from Virginia to Maine. As the transportation sector accounts for 43% of carbon pollution in this TCI region, clearly efforts to reduce transportation pollution will coincidingly reduce carbon pollution. In that sense, I support the TCI’s initiative to address such a considerable contributor to pollution and climate change.
Given the current trajectory of climate change, the TCI is an important undertaking, yet it is far from a perfect plan of action. In the case of Vermont, a state with an extensive rural population, sustainable public transportation is often inaccessible or inconvenient to the point of irrelevance. Thus, much of the rural population of Vermont is left to its own devices to achieve mobility, which often leads to increased vehicle travel and carbon dioxide emissions. Coupled with the prevalence of poverty in rural Vermont, the increased cost of gasoline put forth by the TCI stands to leave low-income Vermonters unable to afford the gasoline that many rely on for transportation. This outcome must be avoided; therefore, the TCI must incorporate measures to ensure a just and equitable transition for impoverished Vermonters and those disproportionately affected by climate change, characteristics that are often in direct correlation to one another.
Prior to enacting the TCI, the Vermont government must ensure that rural populations will have access to transportation and that transportation will be increasingly sustainable to mitigate our current climate trajectory. As we strive to reduce vehicle miles travelled per person and emissions stemming from transportation, public transport must be made accessible to rural populations that are already disproportionately bearing the effects of climate change. Alternate modes of transport, like electric vehicles (EVs), allow a person to maintain their independence while also reducing polluting emissions. Incentives are in place to make EVs more obtainable, yet these incentives do not go far enough to make EVs available to Vermonters living in poverty.
The aspect of the TCI that I find most exciting is the potential for developing feedback loops that continually invest the profits generated from the TCI into sustainable transportation, leading to the continued decreasing of pollution from the transportation sector. The potential for an exponential process is encouraging as even initial small steps can snowball into a continued reduction of carbon dioxide emissions. Therefore, I recommend easing into the TCI to avoid jeopardizing the access of impoverished populations in Vermont to the gasoline that many have come to rely on for mobility via personal vehicles. If an abrupt transition to the TCI occurs, rural Vermonters that are unable to afford the increased prices stand to be isolated with no means of mobility, similar to the aftermath of Hurricane Irene.
Furthermore, those working to implement the TCI ought to take more measures to increase the accessibility of the document itself. Even if Vermonters are aware of the TCI and have access to related documents, the language of the TCI Memoriam of Understanding is dense and difficult to understand. The potential for storytelling and graphic representation as effective ways to communicate data is immense and can prove to be an effective means of garnering support for the TCI. As we watch states such as New Hampshire decline to participate in the TCI, it is imperative that efforts to increase public support are intensified.
The TCI represents a great opportunity to generate funding for increased accessibility to public transport, greater incentives for EVs to those that need more financial assistance, and the bettering of sustainable transportation infrastructure. It would be unjust to price rural populations out of purchasing the gasoline that many rely on, yet it would also be unjust to not enact change and continue to let rural communities bear the brunt of the impacts of climate change. Careful consideration of the impacts of the TCI, especially on rural populations, will allow for a just transition towards a more sustainable future.

I think it is very important to join regionally to make an effective, low-carbon, diverse policy. All of the areas involved are connected so any transportation planning should be done jointly to ensure it is as well integrated as it can be. I applaud the Transportation and Climate Initiative and look forward to seeing it implemented. Thank you.