TCI Regional Policy Design Stakeholder Submissions

If gas is taxes more or increased, then Maine economy will collapse. Most people drive from very rural areas to make the living they need to survive. This would largely impact everyone. Including mine your families. I think this could lead us down a very expensive road. We are already the most taxed state in the union with a depleted work force and aging population. There are better ways to combat what is trying to be fought by this ideas. Hurting the lively hood of avergae Mainers is like cutting your feet off. If you don't have your feet, how can you walk. The lower end of Mainers keeps this economy running. Just my thought. Please don't do this. Also the research shows electric cars are not feasible in this climate nor are they in our geo-eco nomical sense

Transportation and Climate Initiative -Less pollution, healthier lives
Reducing Pollution and Transforming Our Transportation System
Transportation is now the largest source of climate disrupting carbon pollution in Maryland and across the country. The Transportation and Climate Initiative (TCI) is a collaboration between Washington D.C. and 12 Mid-Atlantic and Northeast states to reduce greenhouse gas emissions and air pollution from transportation modes like cars, buses, and trucks and accelerate clean, modern and multimodal forms of transportation. Maryland and other states are engaged in ongoing conversations and gathering of public input, with the facilitation of Georgetown Climate Center, to determine a regional policy that would reduce transportation pollution.
One policy that has been widely discussed is a cap and invest program, similar to a program that exists in the electric power sector. This policy could set a declining cap on the amount of carbon pollution released by the use of transportation fuels by requiring entities like wholesale fuel distributors that sell gasoline and other fuels to retail outlets (i.e., gas stations) to purchase emission permits available under the cap (2). The proceeds from sale by states of those permits could then be invested in clean alternatives like electric vehicles and charging infrastructure, public transportation, walking and biking projects, and other smart growth initiatives, speeding up the must needed transition to a clean, equitable, 21st century transportation system.Mirroring a partnership that works.This partnership could closely mirror an effort the region has taken through the Regional Greenhouse Gas Initiative (RGGI), which sets a declining cap on the amount of carbon dioxide power plants can emit and generates dedicated funds for clean energy programs through states’ sale of emission permits under the cap to power plants. The program has helped cut regional emissions nearly in half and invested over $616 million (3) in Maryland mostly for energy efficiency, consumer benefit, and clean energy projects. Participating Governments CT, D.C., DE, ME, MD, MA, NH, NJ, NY, PA, RI, VI, VA.
WHAT WOULD INVESTING IN CLEAN TRANSPORTATION GET US?
A recent analysis by the Georgetown Climate Center found that investing $3 billion annually in the Northeast states to reduce vehicle GHG emissions would (4):
Save thousands of lives in the region in 2030. Create more than 113,000 jobs in D.C. and Maryland through 2030 Put $11.81 billion in D.C. and Marylanders pockets through 2030. 73% of Marylanders support a policy to limit transportation pollution (5)
Who makes the decisions?
The Maryland Departments of Environment and Transportation makes decisions on adopting this policy in collaboration with other agencies, states, and D.C. The Maryland General Assembly passed a law affirming the state's direction in this program in 2019.
Recommendations for policy solutions
Maryland should make a make a firm commitment to adopt a regional transportation policy that achieves a minimum 40 percent reduction in transportation sector climate pollution by 2030, to keep us on track to meet the climate goals updated by the General Assembly in 2016.
Investment and policy decisions should be made based on pollution reduction and equity goals, as well as robust engagement opportunities from the public‒particularly those most overburdened by transportation pollution and undeserved by our current transportation system.

Reducing pollution from transportation is a key component to reducing New Jersey's emissions. Public transit investments that could be made with TCI proceeds would be valuable. Leaders need to choose the aggressive greenhouse gas reduction target that the most recent climate science tells us we need!
Please prioritize clean investments in areas overburdened by pollution and/or for those who don’t have access to transportation choices!

I'm in support of the Transportation and Climate Initiative to provide cleaner transportation that I believe is necessary to address the issue of climate change.

February 28, 2020

To: Governor Ned Lamont, Governor John Carney, Governor Janet Mills, Governor Larry Hogan, Governor Charlie Baker, Governor Chris Sununu, Governor Phil Murphy, Governor Andrew Cuomo, Governor Tom Wolf, Governor Gina Raimondo, Governor Phil Scott, Governor Ralph Northam and Mayor Muriel Bowser.

On behalf of Vermont Businesses for Social Responsibility (VBSR), I am writing to express strong support for the Transportation and Climate Initiative (TCI) and comment on the draft Memorandum of Understanding (MOU.)

Vermont Businesses for Social Responsibility is a business association representing over 730 business members in every industry and every county across the state; united in our shared mission to advance an ethic that protects the natural, human, and economic environments of Vermont as a business thrives.

From global brands like Ben & Jerry’s and Burton to small startups like Mamava, VBSR members are some of the most successful and iconic businesses in our state, who together shape the Vermont brand. Of the top 25 companies in Vermont, 13 are VBSR members – including our champion members Green Mountain Power and National Life Group. Those 13 companies together earned over 9 billion dollars in revenue in 2012, according to Vermont Business Magazine.

In 2018, we surveyed our members on annual revenues – just under 50%, or about 185 companies, earn less than $500,000 a year. About 16% earn between $500,000 and $1 million a year, 9% earn $1 to 5 million a year, 7% earn $5-20 million a year, and 10%, or about 70 companies, earn over $20 million a year in revenue.

No matter their size our businesses recognize that our continued reliance on fossil fuels is triggering a climate crisis and stifling our economy. The longer we delay in taking action the more exacerbated these impacts become. For Vermont, the transportation sector accounts for nearly half of our carbon emissions and so it is imperative that we seize this rare opportunity to decarbonize our region’s transportation system with a strong, equitable TCI cap-and-invest program.

The potential benefits of this carbon pricing system make it a far cry from the gas tax opponents claim it will be. A cap and invest system would establish a limit on carbon emissions and a regional auction for participating states to sell their emissions allowances. They can then invest those revenues into cost-saving programs designed to reduce prices at the pump such as electric vehicle (EV) incentives, rural broadband to support remote work and telemedicine, bike and pedestrian infrastructure, public transit, and more. Conversely, a gas tax means higher costs at the pump without any palpable transportation or environmental benefit.

VBSR urges the working group to develop a program that will not only decrease climate pollution but use program revenues to address the needs of rural, low-income communities who are overburdened by vehicular pollution, transportation costs, and a lack of clean transportation options. These communities are often those most directly impacted by the adverse effects of climate change and as such should enjoy the strongest benefits of this program. Considering the different challenges each state faces in our region, we also call for strategic, state-by-state investments to be made to ensure equity.

The challenges rural, working Vermonters face are far different than those living in Boston, Baltimore, or Burlington, so it is essential that we give states the flexibility to invest program revenues into transportation solutions that serve their respective communities rather than take a one-size-fits-all approach.

The urgency to develop and implement TCI cannot be overstated and VBSR is pleased to see that the timeline outlined in the draft MOU reflects this. The initial compliance period launch on January 1, 2022 recognizes the need to take swift action while providing states with adequate time to elevate the program and prepare for participation.

Along that same line, we strongly urge that the working group adopt an emissions cap on transportation pollution at a pace and scale in line with science by requiring no less than a 25% pollution reduction in the first ten years from the program’s 2022 adoption. There is a clear consensus within the scientific community that significant, rapid pollution reductions are needed, and we implore you to consider pursuing even more ambitious greenhouse gas reductions moving forward as well as continuous programmatic evaluation of TCI to ensure its continued progression and efficacy.

Climate change is without question the single greatest threat to Vermont's communities, ecosystems, and shared way of life. Spring is arriving earlier, heavy rainstorms are becoming commonplace, and our summers are hotter and drier than ever. Meanwhile more frequent and severe storms cause floods that cost us millions in damaged property and infrastructure. From winter recreation and local food driven tourism to manufacturing and service industries, these changes disrupt nearly every facet of our state’s economy— and we can no longer afford half measures.

TCI offers one of the most promising opportunities to advance solutions that recognize our shared responsibility to take action, strengthen our economy and bring Vermont’s most vulnerable along in our climate future by reducing pollution from the transportation sector. We appreciate the opportunity to comment and your continued work to improve and implement a strong, equitable program.

Thank you,

Jordan Giaconia
Public Policy Manager
Vermont Businesses for Social Responsibility
Jordang@vbsr.og
860-304-2251(mobile)

Thank you for the opportunity to provide the attached comments.

Regards,

Brett Barry

February 28, 2020

Transportation & Climate Initiative
Draft Memorandum of Understanding of the Transportation and Climate Initiative (TCI)
Comments from the Port Authority of New York and New Jersey


The Port Authority of New York & New Jersey (Port Authority) builds, operates and maintains infrastructure critical to the New York/New Jersey region's trade and transportation network. These facilities include the country's busiest airport system, marine terminals and ports, the PATH rail transit system, six tunnels and bridges between New York and New Jersey, the Port Authority Bus Terminal in Manhattan, and the World Trade Center site. For more than eight decades, the Port Authority has worked to improve the quality of life for the more than 18 million people who live and work in the New York and New Jersey Metropolitan Region - a region that supports 9.2 million jobs.

In October 2018, the Port Authority embraced the Paris Climate Agreement, making it the first US transportation agency to do so. The Port Authority is committed to reducing emissions associated with our facilities and improving air quality for neighboring communities. This includes a variety of innovative programs and initiatives to conserve energy, increase our use of renewable energy, and transition vehicles and equipment from fossil-fuel to zero-emissions models.

The Port Authority wishes to reiterate its support of the Transportation & Climate Initiative and encourage both New York and New Jersey to participate in the program as Signatory Jurisdictions. As a bi-state transportation agency that enables the movement of people and goods throughout the region, we believe there is a strong need for regional, collaborative solutions to address transportation-related emissions. Furthermore, given the significant impact that Ports and Airports have in environmental justice communities and our focus on reducing emissions from these facilities, we have a deep understanding of how TCI proceeds can be used to address emissions that impact these communities.

The Port Authority respectfully submits the following comments on the Draft Memorandum of Understanding for the Transportation and Climate Initiative.

1. Affected fuel: Significant emissions stem from equipment at the seaports and airports that operate on off-road diesel. Given the overwhelming presence of these facilities in environmental justice neighborhoods, we believe that both diesel and gasoline emissions should be capped to equally treat fuels that have significant on and off-road utilization. Also, as noted in our November 5, 2019 comment letter on the TCI framework, it should be noted that some off-road equipment at the airports run on gasoline and thus the emissions cap on gasoline and on-road diesel may unequally impact equipment types and owners within the same category.

2. Support for emissions sources that face the greatest challenges to decarbonize: The impact of emissions from vehicles and equipment that do not have a viable electric option in the near future should not be overlooked in the determination of how proceeds should be used. Even if an electric model is commercially available, the barriers to conversion for off-road equipment and heavy-duty trucks are higher than they are for passenger EVs or even buses, due to the increased cost premium, usage needs, and round-the-clock operations of specialty equipment. Again, given the overwhelming concentration of these types of equipment in environmental justice communities, enabling emissions reductions in this sector will provide the most impact to EJ community residents. Supporting low-carbon liquid fuels, funding demonstrations of newly introduced electric equipment, and funding charging infrastructure at seaports and airports are essential tools for addressing emissions from these sources. Given the cross-jurisdictional nature of TCI and emissions from air, rail and marine people and goods movement, it makes sense for TCI proceeds to be used to accelerate decarbonization in these sectors of the economy.

3. Targeted support for conversion to electric for-hire vehicles: For-hire vehicles have higher levels of utilization than most passenger vehicles. These vehicles are among the biggest sources of emissions at Port Authority facilities - second only to aircraft at our airports. Independent drivers are more likely to convert their vehicles to electric if they have financial support to cover the higher up-front cost of EVs, and strategic investment in fast-charging infrastructure to support these fleets - for example at airports - would achieve meaningful GHG reductions and improve air quality and reduce noise in surrounding communities, many of which are environmental justice communities.

The Port Authority commends both New York and New Jersey for their stakeholder engagement on TCI, and strongly encourages both States to participate in the cap-and-invest program. We look forward to continued collaboration to make this program as effective as possible in catalyzing the transition to a low-carbon economy.

Sincerely,


Christine Weydig, Director
Environmental and Energy Programs
The Port Authority of New York and New Jersey