TCI Regional Policy Design Stakeholder Submissions

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

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.

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

Please see the attached comments from The Nature Conservancy on the TCI Draft MOU.

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.

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!