2/28/2020 |
Andrew |
Dick |
Electrify America, LLC |
Reston |
Virginia |
Please find attached Electrify America's comments to TCI on the draft MOU and proposed program framework.
Regards,
Andrew Dick
State Government Affairs Manager... read more Please find attached Electrify America's comments to TCI on the draft MOU and proposed program framework.
Regards,
Andrew Dick
State Government Affairs Manager
Electrify America, LLC |
2020-02-28 Electrify America Comments to TCI.pdf |
2/28/2020 |
Jen |
Roberton |
City of New York |
New York |
New York |
The City of New York offers the attached comments in response to the Transportation and Climate Initiative’s (“TCI”) December 17, 2019 request for public input on its draft Memorandum of... read more The City of New York offers the attached comments in response to the Transportation and Climate Initiative’s (“TCI”) December 17, 2019 request for public input on its draft Memorandum of Understanding (“draft MOU”) and initial projections of the potential economic and health benefits of a regional cap and invest program. |
TCI_Comment_Letter_NYC_Signed_2.28.2020.pdf |
2/28/2020 |
Drew |
Stilson |
Environmental Defense Fund |
Washington |
District of Columbia |
Environmental Defense Fund (EDF) appreciates the opportunity to provide the attached comments on the Draft MOU for the Transportation and Climate Initiative.
Thank you,
Drew... Environmental Defense Fund (EDF) appreciates the opportunity to provide the attached comments on the Draft MOU for the Transportation and Climate Initiative.
Thank you,
Drew Stilson |
EDF Comments on Draft TCI MOU.pdf |
2/28/2020 |
Doulas |
Kantor |
NACS/NATSO/SIGMA |
Washington |
District of Columbia |
Please see the attached file. Please see the attached file. |
Association Comments on TCI Draft MOU.pdf |
2/28/2020 |
Amelia |
Miller |
Middlebury College |
Middlebury |
Vermont |
According to the IPCC report from 2018, human activities have already resulted in a 1°C rise in global temperatures. They estimate that we have at most 10 years to get our act together. And by “... read more According to the IPCC report from 2018, human activities have already resulted in a 1°C rise in global temperatures. They estimate that we have at most 10 years to get our act together. And by “get our act together” I mean make thoughtful, definitive changes to make sure we have our best chance at a livable future. As a young adult who will be around for that future regardless, I urge you to sign on to the Transportation and Climate Initiative. I don’t feel the need to list off facts about why climate change is an issue or about how transportation is Vermont’s biggest contributor to greenhouse gases. You already know this. There is no longer a question of whether we need to do something to combat climate change, but rather, what should be done?
In human time, 10 years can seem like a lot, but in government, 10 years is not much time at all. As it is, the TCI will not be enacted until January 2022. The truth of the matter is that time is of the essence and TCI has great potential. Its formation and structure have many similarities to the Regional Greenhouse Gas Initiative, in which Vermont has had great success. Since 2008, Vermont has received $21.4 million from RGGI and has been able to turn this into $95 million in energy savings for its people. It has also allowed Vermont to avoid more than 200,000 tons of CO2 in emissions. RGGI has given Vermont experience with cap-and-invest programs in cooperation with other states so that TCI will not be some experiment, but rather a proven system for success.
There are areas of TCI, however, that still need more consideration and solidification. Based on the proposed system of fuel suppliers purchasing allowances in TCI, it is understood that this cost will be passed on to consumers through roughly an 8-10 cent increase in price per gallon of gasoline. Because this will in many ways act as a regressive tax, it is important to understand and mitigate the impact it will have on low-income individuals in Vermont, specifically those living in rural areas that rely more heavily on cars. This could come through priority status in receiving rebates or increased rebates on electric vehicle purchases. Another option to consider is reducing gas prices for individuals that fall below a certain income and live in areas where their cars are their main form of transportation. This could be done through methods similar to gas promotions that many companies run where an input of a code or a sliding of a card can take 4-5 cents off of the gas price. Ultimately, while there is a valid concern that TCI will put a strain on lower income Vermonters, environmental destruction caused by climate change will have a greater impact on these individuals as well. Because of this, it is important that we look out for each other not only in the short term by considering ways to reduce financial burdens, but also in the long run by implemented systems like TCI to reduce the emissions that would lead to greater environmental destruction.
Additionally, just as with RGGI and Vermont’s investment in Efficiency Vermont, it will be important that the state invests the money received from TCI in an effective manner. Because of the success of Efficiency Vermont, I have full confidence in the state to repeat this behavior, but urge the state to look into sustainable transportation beyond just electric vehicles. While EVs will most likely play a big part in reducing transportation-based emissions, it will also be important to improve public transportation and increase bike paths and accessibility as alternative methods to achieving Vermont’s goals.
The jurisdictions involved with TCI will be remembered as pioneers in the fight for our future. And cooperation within this region of America will serve as a valuable reminder to our country and the world that together, we can achieve more. I urge Vermont to sign on to the Transportation and Climate Initiative and be a part of a cleaner, brighter future.
Thank you for your time.
Bibliography:
Gillis, Justin. “Would You Pay Higher Gas Prices to Slow the Climate Crisis?” The New York Times, 26 Feb. 2020.
IPCC. “Summary for Policymakers.” Global Warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty. World Meteorological Organization, Geneva, Switzerland, 2018.
RGGI, Inc. “The Investment of RGGI Proceeds in 2017.” The Regional Greenhouse Gas Initiative: An Initiative of the New England and Mid-Atlantic States of the US, 2019.
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2/28/2020 |
Sarah |
Lesher |
individual |
Silver Spring |
Maryland |
I urge support of the TCI commitment to design a regional low-carbon transportation policy to reduce carbon emissions through a cap-and-invest or similar pricing mechanism possibly analogous to... read more I urge support of the TCI commitment to design a regional low-carbon transportation policy to reduce carbon emissions through a cap-and-invest or similar pricing mechanism possibly analogous to the RGGI cap on power plant emissions.
Because any increase in transportation costs will hurt poor and rural residents disproportionately I urge that mechanisms to help these groups be put in place, loosely analogous to the federal Earned Income Tax Credit.
I also support substantial increases in gas taxes at the pump, provided similar provision is made to help those who can least afford such taxes.
And once the percentage of private electric and hybrid vehicles is more than a certain percentage of total private vehicles, I support an alternative tax based on annual miles traveled to pay for upkeep of roads. However until then I support incentives for purchase of electric vehicles and E.V. hybrids (until charging stations everywhere).
I had to move from Honda Fit to Subaru Outback because small Fit wheels were repeatedly damaged in potholes. (Wanted a Prius wagon but it lacked electronic assist features of Prius sedan and Outback.)
However I would want to block using these funds (or any, especially public private partnerships) for expansion of highways, because that simply drives induced demand.
Sarah Lesher
9728 Hedin Dr., Silver Spring, MD 20903 |
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2/28/2020 |
Brendan |
Williams |
PBF Energy |
Washington |
District of Columbia |
Attached are PBF Energy's comments in response to the draft Memorandum of Understanding (“MOU”) regarding the Transportation & Climate Initiative (“TCI”), as proposed by the Georgetown... read more Attached are PBF Energy's comments in response to the draft Memorandum of Understanding (“MOU”) regarding the Transportation & Climate Initiative (“TCI”), as proposed by the Georgetown Climate Center (“GCC”).
Regards,
Brendan Williams
PBF Energy |
20200228 PBF TCI Cmts FINAL.pdf |
2/28/2020 |
Steve |
Banashek |
Virginia Resident |
Alexandria |
Virginia |
The Transportation and Climate Initiative (TCI) is an opportunity for Virginia and the Washington, DC metro region to reduce fossil fuel emissions and invest in clean transportation options... read more The Transportation and Climate Initiative (TCI) is an opportunity for Virginia and the Washington, DC metro region to reduce fossil fuel emissions and invest in clean transportation options including electric cars and buses, electric vehicle (EV) charging infrastructure, EV purchase tax credits, sidewalks/bike lanes, and regional rail. I strongly support and urge Virginia to move forward with and join the TCI as well as require that the revenue generated by the program be used to expand clean transportation. There are simply too many cars on the road contributing to our warming climate and adding to air pollution related health problems including asthma rates.
Transportation is responsible for nearly half (46 percent) of Virginia's greenhouse gas emissions. If Virginians want to do our part to slow climate change, we definitely need to tackle transportation emissions. In many ways, transportation presents one of the greatest obstacles to tackling climate change, as well as one of the biggest opportunities to address some of Virginia’s challenges.
TCI takes a regional approach. Virginia’s transportation systems are intimately connected to Washington, D.C., Maryland and the entire region, so a real solution to transportation challenges must be regional as well. Additionally, as a coastal state Virginia is already experiencing the impact of climate change more than most—and scientists have made it clear that we must dramatically scale up efforts to reduce GHG emissions if we are to mitigate the worst impacts of a warming world.
We must act now to implement thoughtful and collaborative solutions like TCI that will help address the climate challenge while also driving investments in a clean transportation future. Virginia’s state leaders need to join with our neighbors and build a clean and efficient transportation system that we can all benefit from. |
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2/28/2020 |
Mary Anne |
Nulty |
National Association of Social Workers |
Culpeper |
Virginia |
I am 100% in favor of adopting such a policy. I am 100% in favor of adopting such a policy. |
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2/28/2020 |
Heather |
Takle |
PowerOptions |
Boston |
Massachusetts |
PowerOptions fully supports the TCI draft MOU to establish a regional cap-and-invest program to reduce carbon dioxide (“CO2”) emissions from transportation, and to invest proceeds from the program... read more PowerOptions fully supports the TCI draft MOU to establish a regional cap-and-invest program to reduce carbon dioxide (“CO2”) emissions from transportation, and to invest proceeds from the program in measures designed to further reduce CO2 emissions and provide incentives for low-carbon and more resilient transportation.
PowerOptions is the largest energy-buying consortium in New England, with more than 450 non-profits and public entity members across Massachusetts, Connecticut and Rhode Island. Our members use 1 billion kWh of electricity and 10 million dekatherms of natural
gas annually and include hospitals and healthcare systems, colleges and universities, community and human service agencies, K-12 public and private schools, museums, as well as municipalities and housing authorities. In addition to our core business of electricity and natural gas supply, we are at the forefront of working with our Members to implement cost-effective clean energy initiatives. Our additional program offerings include: a solarplus storage program, with more than 70 MWs of solar developed or underway; a newly launched electric vehicle charging station program with more than 10 stations installed with our Members; and access to energy efficiency services and incentives in partnership with our local utilities while offering opportunities for on-bill financing through our electricity supply program. Recently, we have also begun current discussions with numerous Members about programs for clean transportation.
Our Members cross the TCI Region include more than 140 municipal entities and 44 colleges and universities, many who are adopting goals for zero emissions. A regional transportation cap-and invest program will be instrumental in supporting their efforts to meet these goals as well as contribute to the Region’s efforts to reduce transportation emissions. Our most important comment and recommendation is that the TCI program should look to create stable investments and incentives over long durations that Members can rely on. Without such, as happens in other clean energy programs, investment by our Members in clean transportation to meet their emissions reduction goals becomes challenging.
The TCI program takes the best of the successful Regional Greenhouse Gas Initiative and applies it to transportation. Over the past 10 years, RGGI has been instrumental in cutting power plant carbon emissions in half across the Northeast while growing the region’s economy and creating jobs. According to a report1 published by RGGI, Inc. in October 2019, RGGI investments in 2017 are estimated to return $1.4 billion in lifetime energy bill savings to nearly 300,000 households and 3,000 businesses that participated in programs funded by RGGI proceeds, and to more than 100,000 households that received direct bill assistance. By pulling together a potentially even larger group of states than RGGI, TCI can be even more powerful in providing significant reductions in our most carbon-intensive sector, transportation, while providing investment in clean transportation infrastructure across our region. The opportunity to tap into these investments will be critical to our Members in reducing their transportation emissions and reaching their clean energy and climate goals, thereby multiplying the reductions set by the TCI program. PowerOptions looks forward to following the developments of TCI and the opportunities for our Members to contribute to the Regions reduction of transportation emissions. |
TCIDraftMOU_PowerOptionsComments.pdf |
2/28/2020 |
Patrick |
Kelly |
API |
Washington |
District of Columbia |
See attachment See attachment |
TCI Draft MOU and Modeling API Comments.pdf |
2/28/2020 |
Deborah |
Cohn |
constituent |
Bethesda |
Maryland |
See attachment See attachment |
RGGI transportation cap and invest system comments.docx |
2/28/2020 |
Andrew |
Kambour |
The Nature Conservancy |
Arlington |
Virginia |
Please see the attached comments from The Nature Conservancy on the TCI Draft MOU. Please see the attached comments from The Nature Conservancy on the TCI Draft MOU. |
TNC Comments - TCI Draft MOU 2-28-20.pdf |
2/28/2020 |
Jenifer |
Bosco |
National Consumer Law Center |
Boston |
Massachusetts |
Please see the attached comments of the National Consumer Law Center on behalf of our low-income clients, Pennsylvania Utility Law Project on behalf of our low-income clients, Public Citizen and... read more Please see the attached comments of the National Consumer Law Center on behalf of our low-income clients, Pennsylvania Utility Law Project on behalf of our low-income clients, Public Citizen and the Public Utility Law Project of New York, advocating for the further inclusion of equity in the TCI MOU and program design. |
TCI MOU comments Feb2020.pdf |
2/28/2020 |
Jack |
Clarke |
Mass Audubon |
Boston |
Massachusetts |
Please see attached. Please see attached. |
draft TCI comments 2-28-2020.pdf |
2/28/2020 |
Edmond |
Young |
Toyota Motor North America, Inc. |
Plano |
Texas |
TOYOTA's comments regarding Draft TCI MOU are attached. read more TOYOTA's comments regarding Draft TCI MOU are attached. |
TOYOTA Comments - Draft TCI MOU 2020-02-28.pdf |
2/28/2020 |
Sidra |
Pierson |
Middlebury College |
Middlebury |
Vermont |
Vermont’s Participation in the Transportation and Climate Initiative Has the Potential to Improve Equity While Protecting the Planet
Coming off of the recent decision to pass the... read more Vermont’s Participation in the Transportation and Climate Initiative Has the Potential to Improve Equity While Protecting the Planet
Coming off of the recent decision to pass the Global Warming Solutions Act, Vermont has the opportunity to further its environmental commitment by supporting the Transportation and Climate Initiative (TCI), a regional effort to reduce carbon dioxide (CO2) emissions and improve sustainable transportation. The state must be a part of this undertaking, for the good of both the planet and its residents.
I chose to attend college in Vermont, over 3,000 miles from my home, because of the environment. I was not only drawn to the incredible natural beauty of the state, but also to the Environmental Studies program and Middlebury College. In my third year in the major, I’m spending a semester in an Engaged Community Practicum, thinking critically about public transit in the age of climate crisis. This perspective and sustained engagement with local stakeholders inform my understanding of the TCI, as does my childhood in an urban area where I depended on a (deeply flawed) public transit system.
The beauty of the TCI is that it takes the theories behind environmental justice and puts them into practice. The initiative holds the potential to provide incredible benefits to those who need them the most. The goal is to use a cap to reduce vehicle emissions (specifically on-road diesel and finished motor gasoline) and then invest the proceeds in measures to further reduce emissions and improve the quality and resilience of transportation. By targeting transportation, which contributes 43% of CO2 emissions in the TCI region, the program will combat climate change, which disproportionately impacts poor and marginalized groups.
The Draft Memorandum of Understanding for Stakeholder Input (MOU) highlights the program’s equity implications, pointing to increased accessibility and mobility as one key example. However, it must be acknowledged that the MOU is merely a sketch of what needs to become a much more robust plan. How exactly this outline is fleshed out has critical implications. When it comes to thinking about equity and the TCI, we must consider two dimensions: participation in process and distributive justice. Addressing these elements will alleviate most concerns about the TCI, but this has yet to be done sufficiently.
The Investments and Equity section of the MOU highlights the importance of thoughtful investment, of allowance proceeds, and of prioritizing transportation improvements for underserved communities. Significant concerns have been put forth about the potential for regressive effects of the TCI, and the writers of the MOU are right that proper investment can ensure that costs do not fall disproportionately on vulnerable groups. This is the case because Vermont’s low-income and aging populations share similar transportation obstacles, such as less access to personal vehicles. Therefore, investment in improved public transit options and pedestrian and cyclist safety will present benefits. Policy makers must make clear to the public exactly how they will invest proceeds in order to ensure that this program is progressive rather than regressive. In particular, this should include less emphasis on electric vehicles, which under the current investment scenario receive the largest share (30%). Rather than promoting infrastructures and ideologies centered around reliance on personal vehicles, the TCI must be more ambitious in investing in public transit. This is especially important considering the uncertainty around electric vehicle technology in rural, rugged landscapes.
It also must be clarified that distributional equity does not mean that benefits and burdens are evenly distributed across a population, but that those with the most constraints receive the most support. Furthermore, moving forward, policymakers must also demonstrate understanding of another core tenant of transportation equity, which is ensuring meaningful public involvement in the planning process.
Another key element regarding equity will be participation in the process. Policymakers must prioritize sustained public outreach to diverse demographics, and break down documents like the MOU in plain language to improve accessibility. Additionally, public transit programs and investments must be need-based, not demand-based. This may seem like semantics but the distinction means prioritizing justice and working towards accessibility by overcoming isolation.
Climate change demands rapid and expansive action to reduce emissions and adapt to exacerbated vulnerabilities. The scale of the TCI promises to do just that, harnessing technological and political tools already easily available. However, policymakers must sustain and expand upon their commitment to equity, proving to Vermonters and other residents in the region that the program will help rural, poor, and underserved communities.
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2/28/2020 |
Peggy |
Schultz |
individual comments |
Newark |
Delaware |
I wholeheartedly endorse the Memorandum of Understanding presented by the Transportation Climate Initiative.
First and foremost, Delaware and our nation are woefully behind what... read more I wholeheartedly endorse the Memorandum of Understanding presented by the Transportation Climate Initiative.
First and foremost, Delaware and our nation are woefully behind what should be our obligation to mitigate the effects of climate change. We need to do absolutely everything possible to spare our state and our nation from disaster. We are told here in Delaware that we will lose 10% of our land by 2100. This is an untenable situation. Adding a fee to gasoline and diesel fuels as they enter our state for re-sale would go far in alleviating the stress on our climate due to transportation-generated emissions.
I urge that the administrators of the auction returns give special attention to the advantages of reducing vehicle miles traveled (VMT) by means of supportive land use policies...possibly paying for appropriate pedestrian and bicycle infrastructure in a new Delaware phenomenon, Complete Communities Enterprise Districts.
Some critics of the TCI claim that poor people will be unfairly targeted by policies which will probably add additional cost to gasoline. Although the situation is not ideal, underserved populations may, and probably will, receive a disproportionate (and appropriate) share of the benefits accrued from the auction process. If climate change sets in even more severely than it is now, it is the poor who are left with fewer options in turns of moving to higher ground or using other means to avoid the brunt of the changing climate’s fury. In order to protect the poor we must do everything possible to reduce carbon emissions.
Right now the cost of gasoline is fairly low, so costs added to gasoline under current conditions would not be even as noticeable as normal fluctuations in the gas price. Germans pay regulatory taxes of 65.45 cents per liter of gas, plus 19 cents per liter in a value added, or sales tax. Since there are more than three liters in a gallon, this would equate to added fees of more than $2 per gallon, yet the German economy has not crumbled and people still manage to travel.
I beg our governmental officials to adopt this Memorandum of Understanding.
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2/28/2020 |
Sarah |
Ganga |
Ms. |
Norwalk |
Connecticut |
TCI is a once in a generation opportunity to reduce greenhouse gas emissions and re-invest funds to much needed transit improvements, including safe and reliable public transportation, electric... read more TCI is a once in a generation opportunity to reduce greenhouse gas emissions and re-invest funds to much needed transit improvements, including safe and reliable public transportation, electric vehicle infrastructure, and "Complete Streets" for bikers and pedestrians. Unreliable transit is taking time residents should be spending at work or with their families. Please fight for TCI! |
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2/28/2020 |
Lauren |
Bailey |
New Jersey TCI Coalition |
Trenton |
New Jersey |
Please find attached comments on the TCI Initiative from a coalition of environment and transportation advocates from New Jersey. Please find attached comments on the TCI Initiative from a coalition of environment and transportation advocates from New Jersey. |
NJ TCI Coalition Comments Draft MOU 2.28.20 .pdf |