TCI Regional Policy Design Stakeholder Submissions

I vehemently oppose the proposed widening of I495, I270, and building a third Bay Bridge. As a native Californian, I have repeatedly experienced the increased congestion that inevitably follows road expansion. Let's learn from their experience and build our public transportation.

In addition, widening and building roads will removed huge numbers of trees that help to mitigate climate change. We should be planting trees instead of cutting them down. Let's get out of our cars and go public!

TCI is very important for Maryland and for the world, because climate change is real and it's having an increasingly negative impact on our lives and on the environment. Because transportation is the leading emitter of greenhouse gases, it's really essential that we work collaboratively through TCI to reduce greenhouse gases and to leave a sustainable world for future generations.

I support the idea of reducing carbon emissions. We need to take better care of our air to stay healthy, and reduce our negative impact on the environment.

Dear Governors of the Northeast and Mid-Atlantic States,

I am writing on behalf of the Greater Boston Chamber of Commerce regarding the Draft Memorandum of Understanding of the Transportation and Climate Initiative (TCI). The Chamber shares TCI’s goal of reducing greenhouse gas emissions in the transportation sector and supports the broad framework that has been proposed. Accordingly, our comments are intended to inform the development of the final TCI program design. The Chamber urges you to develop TCI so the region sees emissions reductions that are substantially lower than business-as-usual (BAU) projections, to include a secondary market for emissions allowance trading, and so that the program design does not include perverse incentives to maintain high emissions in order to preserve a revenue source.

Projected Emissions Reductions
To rationalize the development of TCI, it is imperative that the benefit of creating a new regional market on transportation emissions is significant enough to justify the cost, both real and administrative. The final TCI program design should result in emissions reductions that are substantially lower than BAU projections. The 2019 TCI modeling and sensitivity analysis project emissions reductions of 6% to 19% under a BAU scenario between 2022 and 2032. Meanwhile, the three proposed caps for the TCI program would result in emissions reductions for that time span of 20%, 22%, or 25%, including the anticipated BAU reductions. As structured, the program would result in a potentially minor reduction in emissions that may not make the cost increase seem worthwhile.

Secondary Market
The draft MOU briefly describes the monitoring of the proposed carbon market and the administration of allowance auctions; however, no reference is made to a secondary market for emission allowance trading outside of the auctions. Other market-based cap-and-invest programs, including the Regional Greenhouse Gas Initiative (RGGI), allow for trading of emissions allowances on a secondary market. The Chamber strongly urges the TCI framers to include a set of provisions in the final MOU and the model rule for a secondary market permitting the sale of emissions allowances among regulated entities and third parties.

Including a secondary market in the TCI program is important for multiple reasons. First, a secondary market increases program flexibility by allowing regulated entities to purchase additional allowances to meet program obligations or to sell excess allowances. In addition, a secondary market provides the ability to sell or obtain allowances in between auctions, ensuring that allowances are liquid, and the carbon market remains stable. Finally, a secondary market will promote innovation among regulated entities by incentivizing firms to increase efficiency or upgrade technology in order to reduce emissions. Doing so will allow them to sell and profit from the unused allowances they purchased at auction.

Program Integrity
TCI is dependent on a declining cap for transportation emissions and the associated allowances that are auctioned to regulated entities. Because states’ allowance proceeds derive from these auctions, it is important that the final MOU and model rule account for the perverse incentive to maintain high emissions to sustain a revenue source. TCI proceeds can result in substantial and beneficial public investment but should not viewed as a permanent or increasing source of revenue.

Thank you for your consideration. We urge you to continue working collectively as a regional coalition and look forward to assisting you as you develop the final iteration of TCI. Please do not hesitate to contact me if you have any questions.

Sincerely,


James E. Rooney
President and CEO

I believe the proposed TCI is a useful starting point for action on carbon reduction but not nearly aggressive enough. To actually effect a critical reduction in VMT the "price at the pump" needs to start higher with assurances it will go even higher.
There should be explicit measures to address the inequitable hardship on low-income and rural households using some portion of the auction income to cushion this inequity. I hope Pennsylvania will join in this regional effort.

First of all, I want to thank Governor Lamont for his part in this initiative. His leadership is so important to achieving a significant reduction in greenhouse gases in our region. With transportation in the state contributing nearly 40% of these climate endangering emissions, we need to make a commitment to regional planning. Greenhouse gases and air pollution do not take much notice of political boundaries. We need to make our cities more livable, especially for those low income residents who don't have the luxury of moving out to the suburbs to escape polluted air and often have to rely on spotty and inadequate public transportation services to get to work and take care of ordinary chores. Electric vehicles are becoming more common, but we need to increase their use by both the public and by state government, and we need to make sure the infrastructure is there to encourage their adoption by putting charging stations in convenient locations at libraries and government parking areas and ensuring that renters and condo owners also have access to them. We should encourage ev sharing ventures in communities where owning a car is prohibitive. We should shoot high, adopt an ambitious goal with across the board examination of every aspect of transportation to make significant progress. Such progress will not only cut our greenhouse gas emissions but bring improvements in the health of our cities' residents.

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

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 in terms of reducing air pollution, improving transportation, and propelling our clean energy economy. I ask that leaders choose the aggressive greenhouse gas reduction target that the most recent climate science tells us we need. I also urge for policy that prioritizes clean investments in areas overburdened by pollution and for those who don’t have access to transportation choices.

I strongly support Vermont signing on to the Transportation and Climate Initiative. It is clear that if we are going to meet our climate commitments (which we must for the future of the state and the next generations) that we must address transportation climate pollution by increasing housing density in our cities, and supporting non-fossil fuel infrastructure including that for bicycles, pedestrians, trains, and electric vehicles, as well as increasing transportation options including on evenings and weekends so that families and individuals can truly go carfree. The Transportation and Climate Initiative is a good vehicle for helping us reduce carbon and meet our goals and will bring revenues to the state to build the needed infrastructure to replace a car-dependent and fossil-fuel dependent population.