2/28/2020 |
David |
Mankiewicz |
CenterState CEO |
Syracuse |
New York |
CenterState CEO is an independent and forward thinking economic development strategist, business leadership organization and chamber of commerce dedicated to the success of its members and the... read more CenterState CEO is an independent and forward thinking economic development strategist, business leadership organization and chamber of commerce dedicated to the success of its members and the prosperity of the region. CenterState CEO is headquartered in Syracuse, New York and has 2,000 members. You can see more information about us on our website: www.centerstateceo.com. We undertake programs in economic development/business development, economic inclusion, research, policy and planning, as well as innovation and entrepreneurial development to achieve our goals.
We are closely following the development of the Transportation and Climate Initiative (TCI). We have participated in the public information meetings sponsored by the New York State Department of Conservation on November 7, and the TCI webinar of December 17. We thank New York State and the TCI for making those opportunities possible and look forward to continuing to engage in the process as it moves forward.
We are well aware of the climate issues you are seeking to address with this program. We applaud the states for working together to address a problem on this scale, and recognize that the leadership being taken by the states together can have a significant impact on the problem. We urge you to keep the flow of communication open as we are concerned that the general public, and business community awareness of the TCI is not very great at this point. Ultimately the participating states will be asked to pass legislation to implement the TCI proposals, by that time it will be critical to have greater public understanding of what is being proposed and why it is being proposed. The TCI will increase the cost of doing business for New York State employers, it will be critical that you clearly articulate the benefit that will be generated by the actions you propose.
At this point we have more questions, and as an organization we have not taken any position on the TCI. We would ask you to consider several factors as you design this program.
Our employers frequently must compete for customers in national and international markets. We understand that your market model indicated a positive economic impact for the region as a whole. The region’s economic vulnerability is not really caused by whether some customers drive over a state line to buy a tank of gas in another state, but rather when a business in Central New York has to compete for a contract against a competitor in another part of the country whose fuel prices may be lower to produce and transport a product to market. These types of decisions can often be driven by fractions of a cent per unit differences between one plant and another.
The Central New York economy is very vulnerable to changes in transportation costs. We are heavily dependent on trucking to move our products to market. We do not have competitive rail service that major rail centers possess, we are largely the captive of a single railroad. This is not an uncommon situation for middle sized cities in the TCI region. If a CNY business is seeking to sell products to international market, it actually costs more to move goods 300 miles from Syracuse to the Port of New York/New Jersey by truck than it then costs to move that same product from the Port of New York/New Jersey to an international market (such as China) by ship. Therefore, we are very sensitive to increases in fuel prices. If you do follow the “cap and invest” strategy, then some of that investment should be dedicated to alternative modes of transportation in order to avoid significant adverse consequences to a region like ours. Central New York produces a significant amount of agricultural products, lumber, paperboard, and consumer products that are relatively low priced goods that will be very sensitive to an increase in the cost of transportation. To the degree that there would be a shift from truck to rail as a means of goods movement, there should also be a reduction in greenhouse gas emissions, as rail is a much more environmentally efficient way to move products.
It seems that the results from your economic model indicate that the rise in impact on CO2 emissions was generating diminishing returns as you raised the price; i.e. a 5 cent per gallon increase led to a 20% reduction in CO2 emissions, raising that to 9 cents per gallon only generated a 22% reduction and a 17 cent per gallon decrease only generated a 25% reduction. It appears most of the cap and invest strategy’s return came from the initial increase in fuel price, and it is possible that the marginal increase in additional CO2 reduction would not be worth the potential economic damage of continuing to raise the price.
Part of that diminishment of return may be linked to the nature of the opportunities in which the TCI invests. At the public meeting many of the advocates were recommending projects that while they may be meritorious in their own right might not be particularly effective at the scale of the problem that you are trying to solve. Adding a rural bus route to help a hand full of customers get to a center city is not likely to contribute much to the major CO2 reductions you are seeking to achieve. The investment projects need to be about systemic change and you need projects that will change human behavior. We would recommend that you identify large and bold initiatives that can make a difference such as building out electric car infrastructure across the states, investing in the electrification of transit, upgrading electric generation and transmission to make sure that the utility systems can actually serve the increase desired in the sales of electric vehicles, or investing in infrastructure such as inland ports that will move significant amount of freight movements from truck to rail.
The TCI will have to work with the region’s utility providers to assure that they have the capability to deliver the clean electric power that the TCI needs to reduce carbon emissions. For example, in New York State, Upstate New York already has a significant base of non-fossil fueled power sources including wind, hydro, and nuclear. Seventy percent of our power comes from those sources. Downstate, the supply is closer to 70% from fossil fuels, and only 30% from non-fossil fueled sources. A wise investment, while not necessarily a transportation one, would be to increase the capacity of the New York State electric grid to move non-fossil fuel
dependent electricity from Upstate to downstate, or to convert or replace the fossil fuel plants that supply New York City with clean power. There will also be a need to make sure that there is sufficient generation to support the widespread adoption of electric vehicles, and given the challenges in siting and permitting utility generation, this could be a problem that could undermine your efforts.
Another issue the TCI should address is to encourage states to change their transportation investment policies. For example, NYSDOT is currently close to a final decision on replacement of I-81 through Syracuse. This will represent a minimum of a $2.5 billion investment in highways around Syracuse. While this is a good investment, being done in an environmentally responsible manner, the investments that the TCI are proposing will pale in comparison to the amount of money which will have to be spent on roads and highways. You may need to convince member states, and the federal government, to reconsider their own transportation investment policies and put more emphasis on transit or non-highway investments. With the aging of the interstate system, many states will be in the position to consider whether they can turn their transportation investments to replace some of the demand for automobile transportation with other forms of moving people.
We appreciate your willingness to engage the business community on this important and complex issue. We look forward to be engaged in the process, and hope that we can make progress in addressing this problem.
Sincerely,
David A. Mankiewicz
Senior Vice President
CenterState CEO
115 West Fayette Street
Syracuse, New York, 13202
Phone: (315)-470-1942
Email: dmankiewicz@centerstateceo.com
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TCI Comment Letter 2-27-2020 with sig..doc |
2/28/2020 |
John |
Carlson |
Ceres |
Boston |
Massachusetts |
To Whom It May Concern:
Attached please find comments of support for TCI from the undersigned businesses, universities, health systems, institutions, and large employers. To Whom It May Concern:
Attached please find comments of support for TCI from the undersigned businesses, universities, health systems, institutions, and large employers. |
Business Support for TCI MOU.pdf |
2/28/2020 |
Johanna |
Miller |
Vermont Natural Resources Council |
Montpelier |
Vermont |
Dear Honorable Governors, Mayor Bowser and Transportation & Climate Initiative Workgroup Members,
As organizations representing Vermont’s leading low income, business,... read more Dear Honorable Governors, Mayor Bowser and Transportation & Climate Initiative Workgroup Members,
As organizations representing Vermont’s leading low income, business, environmental, public health, and faith organizations, we thank you for the opportunity to comment on the draft Memorandum of Understanding for the Transportation and Climate Initiative (TCI), and for your continued leadership in exploring and advancing the development of a robust and equitable regional clean transportation policy.
The science could not be more clear: Our collective combustion of fossil fuels is warming our planet, and we risk severe costs and consequences from delayed or insufficient climate action. Swift, strategic solutions that reduce emissions in the transportation sector in particular – the largest source of our region’s carbon pollution – are imperative. There is a tremendous opportunity before us to design and implement a strong, equitable TCI cap-and-invest program.
As you embark on crafting a final MOU, we offer the following comments for consideration as critical components of a well-designed program that drives down climate-warming pollution, while also protecting and prioritizing underserved communities and other communities that are disproportionately burdened by vehicular pollution, the costs of the current transportation system, the lack of access to clean transportation options, and at highest risk for experiencing the negative impacts of a changing climate.
We offer the following comments and recommendations on the draft TCI MOU:
• Time is of the essence. We support the launch timeline outlined in the draft MOU, with the first compliance period for a regional TCI policy commencing no later than January 1, 2022.
• Ensure the program aligns with the science. We strongly urge the adoption of a regional transportation carbon emissions cap that requires at least a 25 percent reduction in carbon pollution over 10 years, starting with the program launch in 2022. Current climate science makes clear that serious pollution reductions are required, swiftly. Considering the urgency, we also urge considering more ambitious cap reduction levels that would provide even greater greenhouse gas reduction results, as well as other economic, equity, and public health benefits beyond those calculated in the modeling scenarios thus far.
• Enable strategic state-by-state investments and ensure equity. The ability for participating jurisdictions to have significant responsibility for determining how auction revenues are expended based on their unique needs is critical. Vermont is a very rural state. The needs of rural-living Vermonters are very different than for those living in Burlington or Boston. The ability for states to direct auction proceeds to support investments in transportation efficiency solutions that serve particular constituencies – such as rural Vermonters, low-to-moderate income earners or constituencies with unique transportation challenges – is essential. This kind of flexibility is important to help ensure equity and access to clean transportation solutions for everyone, which could range from direct incentives for vehicle electrification to innovative micro-transit pilots, bike and pedestrian investments, housing in and around our transit hubs and far more.
• Design for program performance. To ensure the program works well with a minimum level of performance and generation of auction proceeds in the early years of the program – affordably reducing transportation emissions – a minimum reserve price, or a price floor, is critical. We recommend setting a price floor consistent with allowance prices modeled in the 20 percent cap scenario, beginning at $6 per ton in 2022.
• Incorporate opportunities for program review and adaptation. Regular, rigorous program reviews are essential to maintain a strong program that enables flexibility and adaptability that considers current science, as well as other potential indicators that might warrant adjustments to the program design. We recommend that the first program review take place within three years of the program start, which, if commencing in 2022, would mean a program review in 2025 and every three years thereafter.
The Need for Complementary Policies
While a well-designed TCI program could help reduce the region’s collective carbon emissions significantly, far more work will be required. Identifying and implementing other complementary policies will be essential to aligning our emissions with what the science says is needed for a safe, habitable planet. We look forward to continuing to work with other TCI states, diverse and key constituencies, and all Vermonters to identify and advance that suite of additional strategies to complement TCI, finally putting us on the path to meet science-based climate pollution reduction targets we so desperately need to meet.
Conclusion:
Ongoing climate inaction puts our economies, public health, and quality of life at significant risk. TCI offers one of the most promising opportunities to make much needed pollution-reducing progress in the transportation sector. We thank you for considering this input and for continuing your work to refine and advance a strong, equitable, and flexible program that puts this region on a path to a 21st century, clean, affordable transportation system.
Sincerely,
Audubon Vermont
Capstone Community Action
Conservation Law Foundation
Lake Champlain Committee
Toxics Action Center
Vermont Businesses for Social Responsibility
Vermont Climate and Health Alliance
Vermont Conservation Voters
Vermont Interfaith Power and Light
Vermont Natural Resources Council
Vermont Public Interest Research Group
Vermont Yankee Decommissioning Alliance
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TCI MOU-Joint VT Comments-2-28-2020.pdf |
2/28/2020 |
Marcia |
Hart |
350MA/Elders Climate Action |
Gloucester |
Massachusetts |
I am for a regional transportation initiative but with reservations, as the devil is always in the details. Since 40% of emissions come from this sector, it is critically important to develop... read more I am for a regional transportation initiative but with reservations, as the devil is always in the details. Since 40% of emissions come from this sector, it is critically important to develop smart, clean and efficient transportations systems that are designed to reduce emissions to the greatest extent possible. Accountability, through frequent benchmarking and 3rd party review are needed to ensure that TCI investments deliver actual pollution reduction, improved air quality, increased sustainable transportations options and are being done in an equitable manner that protects vulnerable populations, rural areas, small businesses, good jobs and good workplace standards. I support the most ambitious emissions reduction of 25% by 2030 with funds going to green transportation infrastructure, not highway expansion or road maintenance. Transparency is very important. I would like to be informed of the actual emission reduction this program will garner, separate from the reductions that are already anticipated from measures already in place and that we already count on to allow us to reach net zero by 2050 or sooner. We do not have time and cannot afford misinformation or overinflation of benefits when we discuss programs that influence taxes and create or fail to truly create solutions for a viable future. A regional transportation system that uses our best green technology and initiatives, that is grounded in the importance of our collective health, safety and future, rooted in honestly, not fraud, embellishment or self-dealing is what I want to pay for. I want this for myself, my children and grandchildren and for you and yours.
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2/28/2020 |
Maxwell |
Rye |
Middlebury College |
Middlebury |
Vermont |
See Attached See Attached |
Maxwell Rye TCI Public Comment.pdf |
2/28/2020 |
Marcy |
Murray |
South Burlington Energy Committee |
South Burlington |
Vermont |
As a city energy committee volunteer and concerned citizen, I urge Vermont leaders to join the Transportation and Climate Initiative (TCI) instead of falling victim to short-term thinking.... read more As a city energy committee volunteer and concerned citizen, I urge Vermont leaders to join the Transportation and Climate Initiative (TCI) instead of falling victim to short-term thinking. Regarding the latter, I respect those who fear any initiative that could potentially increase the daily expenses of people who are already finding it hard to make ends meet. However, if we don’t fervently harness the state government to explore opportunities--such as TCI--to address the climate crisis, people with fewer resources will be the primary victims of the resulting economic, health and safety-related suffering over the medium- to long-term timeframe.
Joining TCI will enable Vermont officials to continue to help design the program in a way that can potentially minimize the short-term effects on people with low incomes by, for example, making sure that the subsequent investments made possible by the logic-based carbon-related revenue are sound.
TCI is the single most important climate policy that Vermont can support in 2020 to help address Vermont’s largest source of climate pollution, i.e., transportation-related emissions. In addition to building upon the success of RGGI (Regional Greenhouse Gas Initiative), which was joined by Republican Governor Douglas, the collaborative TCI effort would align with Governor Scott's previously stated desire of not having Vermont act alone on climate issues.
Given that Vermont’s current climate-crisis-related plans, though positive, aren’t significant enough to address the scope of the climate problem, it is crucial that Vermont participate in the next phase of TCI and work collaboratively to harness the power inherent in this regional effort.
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2/28/2020 |
Morgan |
Folger |
Environment America |
Philadelphia |
Pennsylvania |
On behalf of Environment America, I am submitting the attached comments from 1,834 of our members and supporters across the jurisdictions considering this regional climate policy.
... read more On behalf of Environment America, I am submitting the attached comments from 1,834 of our members and supporters across the jurisdictions considering this regional climate policy.
The Transportation and Climate Initiative is an opportunity for the region to reduce fossil fuel emissions and invest in clean transportation, like electric cars and buses, charging infrastructure, sidewalks/bike lanes, and regional rail.
We urge you to move forward with TCI and require that the revenue generated by the program is used to expand clean transportation. There are simply too many cars on the road contributing to our warming climate, not to mention our asthma rates and traffic congestion problems.
In particular, we’d like TCI funds to go towards zero-emission electric buses, EV charging infrastructure, expanded and improved bike lanes and regional rail, as well as tax rebates toward private EV ownership. |
EA Member Comments - TCI.pdf |
2/28/2020 |
Tom |
Van Heeke |
General Motors |
Detroit |
Michigan |
See uploaded attachment for the comments of General Motors on the Transportation and Climate Initiative's Draft Memorandum of Understanding. read more See uploaded attachment for the comments of General Motors on the Transportation and Climate Initiative's Draft Memorandum of Understanding. |
TCI_GMComment_FINAL.pdf |
2/28/2020 |
PAUL |
SIPPLE |
NECCO Inc. |
WAITSFIELD |
Vermont |
I feel that further taxing fossil fuels is very counter productive. I think the US and the world would be much better served if we simply eliminated incentives and tax cuts for the production and... read more I feel that further taxing fossil fuels is very counter productive. I think the US and the world would be much better served if we simply eliminated incentives and tax cuts for the production and exploration of fossil fuel. |
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2/28/2020 |
Ellen |
Valentino |
Mid-Atlantic Petroleum Distributors Assn. |
Annapolis |
Maryland |
The TCI draft MOU and plan is ill-conceived and will negatively impact consumers and businesses as well as the larger economies of Maryland and Delaware. We believe the northeast governors should... read more The TCI draft MOU and plan is ill-conceived and will negatively impact consumers and businesses as well as the larger economies of Maryland and Delaware. We believe the northeast governors should reject the MOU and disband the Initiative. The TCI plan structure:
• restricts the amount of gasoline and diesel that can be sold in the Northeast region
• imposes a tax on gasoline and diesel, and
• establishes a regional non-profit government entity to oversee the whole TCI Plan, including how billions of dollars in new tax revenue can be spent and how much gasoline a state can receive without penalty.
Restricting the amount of gasoline that can be sold is a bad idea.
The stakes are too high to give complete control over gasoline sales to a newly created non-profit entity that must juggle the competing concerns of 12 states. The TCI proposal leaves many questions unanswered. What happens when a state hits the allowed allotment of gasoline? Who determines if they can get more? Who will control the price? And more importantly, how will the political environment in the Northeast play into decisions? Will Maryland and Delaware be forced to adhere to policies from other states?
Consumers will pay more for gasoline.
The draft plan clearly anticipates $.05 - $.17 per gallon increase in gasoline prices, explaining that money will go to poor and marginalized communities for clean transportation projects. Today, those communities are most reliant on gas-powered vehicles because the transportation infrastructure has lagged. Electric vehicles are commonly purchased by affluent consumers. The per gallon increase set out by the plan will hit poor and rural communities hardest.
State road projects will suffer.
The draft plan requires states to follow rules developed by the newly created multistate non-profit as to how this new gasoline tax can be spent. So far, the initiatives set forth by the plan are suggested spending on bike lines and tax breaks to purchase electric vehicles. Electric vehicles don’t support maintenance of roads and bridges – the current gasoline taxes do.
Businesses will be burdened.
The draft proposal imposes a new regulatory and inspection scheme on thousands of businesses. And, as drafted, the proposal would subject Maryland and Delaware’s business owners to the whim of this newly created multistate entity and tax collector.
Maryland and Delaware’s economy will be hit hard.
It’s simple geography. Delaware and Maryland’s citizens and business owners are on the periphery of the Northeast region. The disadvantages of the cap, tax and spend program on gasoline may be diluted in northern states that are surrounded by other states in the compact. Our region is the southernmost tip of the participating states, meaning Maryland, Delaware and DC are most vulnerable to consumers and businesses choosing to go where they can find less expensive fuels.
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TCI Comments MOU 2-28.pdf |
2/28/2020 |
Gabriel |
Desmond |
Middlebury College |
Middlebury |
Vermont |
I’m a young person. I’m afraid of climate change. It’s time to do something.
The Transportation Climate Initiative (TCI) is Vermont’s chance to do just that: take a meaningful... read more I’m a young person. I’m afraid of climate change. It’s time to do something.
The Transportation Climate Initiative (TCI) is Vermont’s chance to do just that: take a meaningful stance against climate change. It is great to see that Green Mountain Power will have 100% renewable energy in the next decade. This, in and of itself, however, is not enough. According to the TCI webinar hosted on December 17, 2019, 43% of the carbon dioxide emissions from the TCI region come from transportation. That is almost twice as much as from electrical power. Most Vermonters cannot afford an electric car, with or without subsidies from the government. That means the 43% of our emissions that come from transportation will continue to be emitted even if we have a carbon-free electrical grid.
But TCI is more than just a way to do something. It has the potential to be an effective policy. As per the executive summary, the TCI locks us into making a significant reduction in emissions. While these reduction goals are theoretically feasible without TCI, the initiative would eliminate any uncertainty. Given the volatility in our federal government, it is important that Vermont takes a stand and does not rely on federal policy to make these changes.
Additionally, by entering into TCI with an entire region of states, Vermont significantly reduces the potential for a harm to the economy. Look no further than the Regional Greenhouse Gas Initiative (RGGI) a similar cap-and-trade program which Vermont is already involved in. RGGI has already contributed 44,700 years of additional full-time employment, $5.7 billion in public health benefits, and saved customers a combined $773 million in energy bills, according to a report by economists at Analysis Group. RGGI, however, does not cover the emissions from transportation. As mentioned above, 43% of carbon emissions in the region come from transportation, making TCI an effective plan to address emissions not captured by RGGI.
As per the TCI Memorandum of Understanding (MOU), the program will invest its proceeds into a variety of programs such as “air quality, public health, resilience, and more affordable access to clean transportation alternatives.” Investments in these sectors all have the potential to positively impact the community and economy. Pollution from cars can contribute to asthma attacks and other health issues. Healthier people have lower medical bills and miss fewer workdays, which can help bolster Vermont’s economy.
All of this is not to say that TCI is perfect. There is a completely valid fear that gas companies will simply offload the increased cost of operation onto the consumers. The MOU mentions the importance of ensuring that the program benefits those who “disproportionately bear the costs of the current transportation system” or “impacts of vehicular pollution and climate change.” Still, without more concrete plans for benefitting these communities, I fear that TCI will only be an additional burden on those who are already struggling with climate change. As such, when Vermont agrees to sign on to TCI, it is critical to have a robust plan to help these communities, including provisions such as rebates and investments in public services. There are ways to make sure that TCI is equitable and given that equity is a listed priority (3b) of the MOU, I do not think fear of increased gas prices should be an impediment to joining TCI.
Like many of my peers at Middlebury College, I was drawn to Vermont for its beautiful scenery and landscape. Climate change has the potential to change our state forever through warmer weather and increased flooding. I hope that when I have children, they will have the opportunity to see Vermont as I see it: vibrant and full of natural beauty. TCI is Vermont’s chance to act on climate before it’s too late, protecting our state for the next generation.
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2/28/2020 |
Scott |
Bates |
Fuel Company Owner |
Stacyville |
Maine |
I own and operate a small business in Maine. To service our customers we travel many miles per year on our fleet of vehicles. Maine is already at a competitive disadvantage due to our... read more I own and operate a small business in Maine. To service our customers we travel many miles per year on our fleet of vehicles. Maine is already at a competitive disadvantage due to our geographical make-up, high cost of electricity and one of the highest overall tax rates in the Union.
We have limited public transportation which require most folks from Maine to commute via vehicle to and from work. In addition, we have to rely on our vehicles to purchase groceries, visit local clothing stores, transport our children to school events, etc.. This list goes on and on. We cannot simply park our vehicles and chose another mode of transportation.
To include Maine in this initiative will be catastrophic to our economy. As a business owner I will be forced to pass this cost on to my Customers. They in turn will have less disposable income to fuel the economy in Maine. My Customers already have a struggle to pay their fuel bills. I cannot speak to how this will impact other states, but I suspect outside of the large cities (Which already have large participation rates in public transportation) the rural areas will be in a similar situation as many of us in Maine.
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2/28/2020 |
Sam |
Swanson |
Ascension Lutheran Church, Vermont Interfaith Power & Light, volunteer for So.Burlington Energy Committee |
South Burlington |
Vermont |
I recommend that Vermont join the Transportation Climate Initiative (TCI) that is being developed for states in this northeast region of our country.
We now know that climate... read more I recommend that Vermont join the Transportation Climate Initiative (TCI) that is being developed for states in this northeast region of our country.
We now know that climate emissions in Vermont have been increasing in the last two or three years despite a clear legislative and policy commitment to reduce these emissions. We also know that climate emissions from transportation account for the largest share of recent climate emission increases. We also know that transportation is an activity that may be addressed most effectively on multi-state, regional basis. And we have seen that the Regional Greenhouse Gas Initiative has proven to be an effective tool for reducing climate emissions from electricity generation.
I am a member of a church in South Burlington that sees the climate crisis as a moral crisis for all mankind and that we all have a responsibility to do what we can to reduce climate emissions. We have been at work for several years to walk our talk by reducing the climate emissions we contribute. Our church has with its own resources taken steps which, with help from Efficiency Vermont and Vermont Gas, enables us to reduce our carbon emissions associated with natural gas and electricity use by more than 50 percent. We want to address climate emissions from driving our personal vehicles but this requires support, just as Efficiency Vermont and Vermont Gas helped us with improving the energy performance of our church building and our individual home.
The TCI offers Vermont a potential source of revenues to support steps to reduce transportation emissions and to do so in way that will help most the people least able to afford newer, more fuel efficient, lower emission cars and trucks.
I ask that Vermont join in the emerging new TCI and to endorse actions by the TCI program that will help all Vermonters to reduce climate emissions resulting from our transportation activities.
It is now obvious that climate change is happening and causing very big impacts that include significant increases in annual rainfall in Vermont, warmer winters in Vermont which threaten the future of skiing in Vermont, accelerate the incidence of lime disease, and threaten the long term viability of our maple syrup industry. These impacts are the obvious ones that confront us in easy to observe ways. Scientists tell us that the Vermont forests, lakes, and wildlife communities are all being transformed by these changes in very negative ways.
It is also important to recognize that the TCI program can make big positive contributions to the State's economy. This has happened with energy efficiency activity, which is now a big Vermont employer, and the solar industry, which had until recently been a fast growing business in Vermont that provided jobs and produced income for Vermonters across the State. The Vermont Clean Energy Development Fund finances annual economic assessments of the clean energy sector and has with these annual studies has documented the large direct employment and income benefits of these clean energy businesses. The TCI can and should be harnessed to build upon this progress.
I urge that Vermont sign the TCI memorandum of understanding and commit the policy and program leadership needed to build an effective program. Such new programs require hard work to make them work and to avoid pitfalls. I plead for the Governor and the Legislature to do the hard work of negotiating an effective TCI program that will benefit Vermont and serve Vermont's stated commitment to achieving the Paris Climate Goals, which will benefit all mankind.
Thank you for this opportunity to comment.
Sam Swanson
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2/28/2020 |
Olga |
Kostreski |
Nursing student |
Silver Spring |
Maryland |
The global warming has become a big change that is noticed all over the world! My family in Europe, completely agrees that each year it just keeps getting warmer and warmer. Random storms appear... read more The global warming has become a big change that is noticed all over the world! My family in Europe, completely agrees that each year it just keeps getting warmer and warmer. Random storms appear that never used to take place. It is scary how fast the changes are moving! We human kind caused it, and we must stop it before it is too late!!! |
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2/28/2020 |
Ellen |
Lourie |
International Emissions Trading Association (IETA) |
Toronto |
Other-International |
IETA SUBMISSION TO TRANSPORTATION & CLIMATE INITIATIVE (TCI)
The International Emissions Trading Association (IETA) appreciates this opportunity to share input on the Transportation... read more IETA SUBMISSION TO TRANSPORTATION & CLIMATE INITIATIVE (TCI)
The International Emissions Trading Association (IETA) appreciates this opportunity to share input on the Transportation & Climate Initiative (TCI) Draft Memorandum of Understanding (MOU) (the MOU). On behalf of our 130+ multi-sector business membership worldwide, we believe that flexible market instruments – including trading, broad access to natural climate solutions, and cross-border cooperation – must form the backbone to any jurisdiction’s successful climate policy effort. We welcome the TCI’s climate leadership, cooperation, and support for flexible market instruments.
IETA's comments are a result of deep experience and lessons learned across North American and international carbon markets. Our policy and market insights are a testament to the iterative – yet increasingly robust and aligned – nature of carbon pricing system design; an evolutionary process where jurisdictions are not only identifying best practices, but also seeking to embed and operationalize these elements into new or modified program improvements.
OVERVIEW & COMMENTS
IETA’s comments are structured around the sections in the MOU, with detailed comments on: program design elements; applicability; compliance and enforcement; flexibility, allowance allocation and stringency; regional program administration; and additional program design elements.
1. Goals and Schedule
IETA commends TCI’s ambitious objective of releasing a regionally coordinated Model Rule by 31 December 2020, with the intention of commencing the first compliance period as early as 1 January 2022.
2. Model Rule for Establishment of the TCI Program
2A. Affected Fuel.
IETA agrees that the fuels proposed to be covered by TCI’s proposed program, on-road diesel and motor gasoline, are the appropriate ones. In general, IETA and its membership believe the program should cover as much of the fuel in the region as possible while taking account of the renewable components.
2B-C. Regulated Entities & Other Entities.
In order to make the TCI program as efficient as possible, the compliance point should be set such that compliance entities can take full advantage of existing tax and tracking systems. IETA members support the proposal to set the compliance point at the terminal rack, with an alternative for any fuel that moves into the region directly. While there is not a directly comparable pricing and tracking system already in place, the terminal rack is the point from which most of the fuel is distributed in the region; it also upstream of the smallest distributors and allows for a manageable number of entities. IETA recognizes that there are suppliers that import fuel directly into the TCI region and believes that those imports can be incorporated into the program without creating an undue burden on small suppliers.
2D-F. Regional Emissions Cap, Budgets & Scheduled Reductions.
IETA supports a system that sets strong science-based caps on emissions reductions, in line with meeting domestic and international climate targets. IETA generally supports the MOU’s approach to setting the regional emissions cap, and we strongly support a regional base annual emissions cap that declines over time in a transparent and predictable manner to allow for medium and long-term planning by facilities and stakeholders. IETA supports the apportionment of the regional base annual CO2 emissions budget to the participating jurisdictions annual budgets, along with the revision of budgets as jurisdictions enter into or withdraw from the program.
2G. Stability Mechanisms.
IETA strongly supports the potential inclusion of a Cost Containment Reserve (CCR) and Emissions Containment Reserve (ECR) in the TCI program. We look forward to more details as the program continues to develop and encourage TCI to look to other regions for examples of successful CCR and ECR mechanisms.
We are encouraged by the framework’s consideration of price-based flexibility mechanisms, including linking as a mechanism to add flexibility and contain costs. Moving forward, the TCI must look beyond its borders to ensure that the rules and systems are complementary and readily adaptable to the world’s quickly changing carbon landscapes. We urge officials to closely track developments that may affect both regional or global “stringency” acceptance of TCI’s approach to carbon rules, pricing and trade. Now is an ideal time for the TCI to be aware of, and account for, any challenges that could emerge down the line. IETA is well-positioned to support this information exchange with TCI and state officials on carbon policy and trade developments and outlooks. We welcome the opportunity to help ensure that the TCI regularly has access to this latest policy information, analyses and outlooks.
Final regulation should see more prescriptive, enabling language to more easily recommend and adopt future market linkage opportunities. For example, international market programs under development (e.g., Article 6/ITMOs, voluntary, international aviation etc.) and existing domestic market programs (e.g., Quebec-California cap and trade programs).
2H. Emission Reporting Requirements.
The proposed requirement for covered facilities to submit a report and supporting information in an electronic emissions reporting system appears sound and defensible. We also support independent third-party verification of the report, recognizing the importance of transparency and verification in ensuring environmental integrity of the system. IETA strongly supports drawing upon lessons and standards from existing greenhouse gas programs in the design of the monitoring reporting and verification (MRV) requirements.
2I. Regulated Entity Compliance and Flexibility.
IETA strongly supports the framework’s inclusion of allowance banking, multi-year compliance periods, and offsets. These instruments should be available to compliance entities to meet full regulatory obligations across these jurisdictions. We hope to see these principles of flexibility and cost containment continue as core principles, guiding the finalization of TCI regional program rules and frameworks.
2J. Auctioning and Alignment.
IETA encourages the TCI jurisdictions to use auctions as the primary method of distributing allowances. Auctioning allowances and allowing a strong market-based approach will incentivize reductions and allow for appropriate price-setting. IETA encourages TCI to collaborate closely with near-term jurisdictional linkage partners (i.e., RGGI, and Quebec and California). Harmonizing and aligning core design rules, standards, joint market infrastructure (e.g., auction platforms, tracking systems etc.) across priority partners are foundational steps towards building broad, linked markets. Cross-border collaboration also allow business, particularly those with regulatory exposure across multiple regions, to more efficiently and cost-effectively plan and invest.
3. Investments and Equity
3A. Investment of Proceeds.
Proceeds from a pollution pricing program can play a dramatic role in supporting TCI jurisdictions’ climate mitigation actions over time. Other jurisdictions – in North America and internationally – earmark and disburse revenue from their pollution pricing programs to support clean technology, innovation, and emissions reductions initiatives. IETA is pleased to learn that the TCI is considering a range of options for investing auction proceeds, and encourages further examination of existing successful programs, including the New York Green Bank, the Australia ERF, and the UK Low-Carbon Innovation Fund (LCIF). In particular, we support investments made towards helping TCI jurisdictions reach their climate policy objectives while supporting regional businesses and consumers to transition to carbon constraints and economic decarbonization.
3B. Equity Shared Priority.
IETA strongly supports the goals of equity, environmental justice, and non-discrimination – and encourages TCI to continue to pursue these goals, including working with disadvantaged communities to assess the impacts of the program.
4. Regional Organization
IETA supports the proposed structure of the regional organization, including its functions, authorities and limits on authorities.
5. Addition or Withdrawal of Participating Jurisdictions
IETA supports the TCI’s approach to new participating jurisdictions and withdrawal from the TCI program. We are pleased to see that the participating jurisdictions will encourage other jurisdictions to the program with the goal of expanding the geographic reach of the regional program. IETA believes that the expansion of this program will benefit all participating jurisdictions by expanding the market. IETA also supports the approach to withdrawal, and that the program can be adjusted based on jurisdictions leaving and entering the program.
6. Program Monitoring and Review
IETA strongly supports continued monitoring of the progress of the program. We urge TCI to undertake ongoing and frequent reviews. Frequent reviews, which are clearly defined and communicated to all stakeholders, will ensure that program parameters remain relevant and reasonable within the context of changing industries, trade and broader macro-economic conditions.
CONCLUSION
Transportation stands out in the TCI region – not only because the sector is now the number one source of carbon emissions, but also because those emissions are increasing. Once again, we applaud the TCI for moving forward – in a cooperative, transparent manner – to harness the power of markets to tackle this challenge in practical and cost-effective manner.
IETA appreciates this opportunity to record our comments on the TCI’s MOU. Our community looks forward to close engagement with the TCI through 2020. If you have questions or follow-up regarding this submission, please contact Justin Johnson at johnson@ieta.org. |
IETA Comments_TCI MOU_28Feb2020.pdf |
2/28/2020 |
Mary |
Swedlund |
Franklin County Climate Crisis Committee |
Deerfield |
Massachusetts |
Good Afternoon, I take my responsibility to reduce the damage we are doing to this planet very seriously. And so I support transportation remediation since inefficient means of transportation... read more Good Afternoon, I take my responsibility to reduce the damage we are doing to this planet very seriously. And so I support transportation remediation since inefficient means of transportation are a major contributor to the climate crisis. I applaud the TCI as an important step forward.
I would like to Thank Governor Baker for his leadership in the TCI and strongly urge Massachusetts to formally sign on to the program.
Please choose the most aggressive greenhouse gas reduction target that the recent climate science tells us we need. And I urge that the policy prioritizes clean investments in areas overburdened by pollution and/or for those who don’t have access to transportation choices. |
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2/28/2020 |
Stewart |
Schwartz |
Coalition for Smarter Growth |
Washington |
District of Columbia |
See attached file See attached file |
2020.02.28 CSG Comments on TCI MOU.pdf |
2/28/2020 |
Richard |
Karel |
Sierra Club member |
Baltimore |
Maryland |
This initiative is critical if we are to make a real attempt to reduce greenhouse gases and air pollution from cars,
buses, and trucks and push the implementation of clean, modern,... read more This initiative is critical if we are to make a real attempt to reduce greenhouse gases and air pollution from cars,
buses, and trucks and push the implementation of clean, modern, multimodal forms of transportation. This partnership
could be based on the Regional Greenhouse Initiative which sets up a declining cap on the amount of carbon dioxide power plants
can emit. That program has helped cut regional emissions almost in half and has involved an investment of more than $600 million--
mainly for clean energy.
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2/28/2020 |
Matt |
Macunas |
Connecticut Green Bank |
Statewide |
Connecticut |
Please see the attached program design input, resubmitted from 2/27 with updated signatories. Please see the attached program design input, resubmitted from 2/27 with updated signatories. |
TCI Comment - CGB, CNBN, UGO, VC.pdf |
2/28/2020 |
Paul |
Wierenga |
IFTOA |
Washington |
District of Columbia |
Please see enclosed comments. Please see enclosed comments. |
IFTOA Comments on the Proposed Transportation and Climate Initiative (Feb. 28, 2020).pdf |