TCI Regional Policy Design Stakeholder Submissions

MASSACHUSETTS is not California !!! The working poor cannot afford another tax. We pay enough. If this state needs more money for hack jobs, get it from some else. Try cutting some of the overpaid government bureaucrats. Not everybody can drive a bike to work.

I strongly support the Transportation and Climate Initiative as we need to do as much as possible to shift now to a low or zero carbon emission transportation system.

I believe that a regional transportation system is crucial for the Northeast. I live in NYC next to a bridge and experience the ramifications of excessive car transport in and out of City. Traffic, car fumes and noise pollution are a common occurrence in midtown. I personally experience sinus and respiratory symptoms due to the idling of cars and fumes that pollute the air. Europe has a stellar public transportation system that makes travel easy and more environmentally friendly, and the Northeast can only benefit from a similar network. We have a densely populated area where roads and infrastructure are not suited to the volume, and too many individual vehicles using the roadways. As traffic increases, idling increases and Co2 emissions increase, making the air quality poor and accelerating environmental fallout.

1) The states should pursue an ambitious emissions reduction policy and go beyond the modeling scenarios presented.
2) The states should center their framework and investment strategies on equity of process and outcome to ensure emissions reductions are specifically targeted in the communities most impacted by the effects of pollution and climate change. The framework should do more to center the needs and voices of frontline communities, including making sure that the impacts of the framework do not further harm low-income people and communities of color with a regressive financial instrument. The framework should also include requirements around ethical sourcing and supply chain transparency for producing the solar panels powering clean energy and to build batteries for electric vehicles, especially to prevent the continuation of human and environmental abuses in mines (https://www.theguardian.com/global-development/2019/sep/05/most-renewable-energy-companies-claims-mines).

If the extra money is REALLY GUARANTEED BY LAW to be used ONLY to fight climate change by building infrastructure near existing gas stations & on highways to charge electric cars, it would be worth it. If the money were used to take our electric grid off fossil fuels by building a grid that runs on a combo of solar/wind (and other new green sources), it would be worth it.

Please find attached comments from Green For All Dream Corps in response to the proposed TCI equity commitments and additional TCI concerns.

The world is facing a climate emergency. TCI has the potential to have a very large and beneficial impact in reducing GHG emissions from a highly populated region of the US. The Cap and Invest model is a proven and effective model to achieve these reductions but only if it’s done right. The cap must be set at a level that creates financial incentives to reduce emissions. In simple terms it means the price of carbon should be high. This will translate to higher fuel costs and incentivize use of lower carbon fuels. If the cost of carbon is high TCI will generate substantial funds to invest in GHG reductions. That basic framework is well thought out and sound.

However, TCI is based on the model of RGGI. A historical look at RGGI shows that it has not been nearly ambitious enough. RGGI has accomplished a lot but could have accomplished much more. The targets of TCI should be ambitious. The cap should be set aggressively low. As the US is pulling out of the Paris climate accord it is up to subnational jurisdictions like the TCI states to create policies that will lead to the emissions reductions we need to avoid the worst impacts of climate change. California has been aggressive about this for more than 10 years. New York recently passed S.6599 which has aggressive climate targets. Other TCI states should follow suit to be at least as aggressive.

My firm helps dairy farms with methane digesters generate revenue by selling environmental commodities like carbon offsets, RINs and LCFS credits. Over the past several years the price of carbon in California’s Low Carbon Fuel Standard (LCFS) has been ~$190/mtCO2e. Dairy digester projects that are connected to common carrier pipelines around the US can sell renewable natural gas into California’s LCFS market. This market provides substantial incentives to digester projects and many are being built to access this market. These projects provide a very low carbon fuel. By avoiding methane emissions that would otherwise be released to the atmosphere and turning that methane into RNG the projects create substantial climate benefits and can have co-benefits that help dairy farms improve water quality and nutrient utilization. In addition, RNG can be used in heavy duty vehicle fleets (trucks, buses, etc) for which electrification is not as viable as it is for passenger cars. TCI should provide incentives for methane digesters to produce renewable low carbon fuels in the TCI states.

At a recent TCI workshop state staff leading the TCI process said that they were considering biofuels but that they have limited resources, and developing TCI at all is “a very heavy lift”. TCI states should commit more employees to development of TCI. This is a prudent investment in the long term health and viability of the people and ecosystems of TCI states. State staff should not be stretched so thin that they cannot devote the time required to thoroughly develop such a necessary program. Of course the vast majority of TCI auction revenues should go to investments in the states, but states will also need staff to manage and implement the program. Speaking from 10+ years in carbon markets we encourage TCI states to make sure that their programs are well staffed with enough highly trained people. This is crucial to having the markets function well to achieve their goals.

Biomethane (aka RNG produced from methane digesters) is a unique form of biofuel. Unlike most ethanol and some forms of biodiesel it is produced from a waste and it’s production does not lead to land use change or impacts to the food supply. Biomethane is produced by dairy, swine and poultry farms of which there are many in TCI states. These segments of the livestock agriculture industry have a major impact on the rural communities (human and environmental) in TCI states. TCI’s model rule should provide specific incentives for production of biomethane from livestock manure. This would help achieve the necessary GHG reductions while supporting a growing industry in TCI states that provides economic benefits to the people and ecosystem service benefits to the environment in the TCI region.

NY S.6599 is an ambitious cap and trade program that will exclude “biofuels” but include livestock anaerobic digestion projects. Since TCI states are home to many dairy and other types of livestock farms they can support their communities and achieve GHG reductions by providing specific incentives for production of biomethane.

TCI can draw on the model of the US EPA Renewable Fuel Standard (RFS) or the California Low Carbon Fuel Standard to develop mechanisms to incentivize production of biomethane from livestock manure digesters. EPA and the California Air Resources Board (CARB) have worked through many of the complications of providing incentives for low carbon fuels including the life cycle accounting that is the global standard for GHG accounting of fuels. TCI doesn’t need to reinvent the wheel on these subjects. In addition, using “standard EPA emissions factors” to assess the impact of different fuels doesn’t sounds like it would allow individual producers to benefit from innovations in reducing emissions. The RFS has multiple “buckets” of RIN credits which allow the producers of the lowest carbon fuels to benefit in the market. CARB’s LCFS has simplified Tier 1 fuel pathways for efficiency, but also allows producers to apply for a Tier 2 pathway when they think their production process provides additional GHG benefits. Both models could be adopted by TCI.

The Road to Transformative Action: Transportation Climate Initiative before Rainy Day Funds

“There’s nothing like 40+ degrees and raining to say Happy Holidays in New England!” Sadly, it has been a recurring family greeting of late. As someone who loves the outdoors in all seasons with a special affinity (some say obsession) to snow and skiing, this weather makes me cringe, and honestly, fight back tears of sorrow.
Growing up low-income in a small rural town, I was never able to afford the true luxury of skiing. At the time, I did not know what I was missing. Regardless I was still fortunate to spend endless hours playing outside – blossoming my intrinsic connection to the rural landscape as well as my fascination for all creatures. I didn’t need all that ‘stuff’ we couldn’t afford.
Without going into too much detail, I’ll just say it was not always easy. However, I’ve learned and continually work to embrace the powerful notion that vulnerability is bravery. My experiences have driven me to find work as an advocate for the communities and natural environments of Vermont.
Part of my work includes serving on the Board of Vermont Businesses for Social Responsibility (VBSR), a statewide, nonprofit business association whose mission centers on People, Planet, and Prosperity. After years taking action on climate in the energy efficiency and renewable energy sectors, I recently delved into the world of transportation, which makes up the majority of Vermont’s greenhouse gas emissions. Both energy expenditures as well as energy burden – or ones annual spending on energy as a percentage of income – for transportation, are higher in Vermont relative to money spent on thermal or electricity costs. Vermont is a rural state and people who live in rural communities have to drive farther to commute to work and school, for recreation, and for all of the regular daily tasks that are part of a full and vibrant life. Our long commutes mean higher household expenses and increased carbon emissions.
Rural public transportation can work, but there is no denying that it is a complex system in need of coordinated, systematic solutions – including providing viable clean transportation choices, affordably, to rural Vermonters. One opportunity for this comes from the Transportation Climate Initiative (TCI) – a chance to collaborate with up to 12 other northeastern and Mid-Atlantic States on a region-wide approach to make transportation cleaner and more accessible. TCI is a cap and invest system. Each participating state is afforded the flexibility to choose how to use the TCI revenues. In Vermont, we could support not only what we usually think about as transit, but innovative solutions to meet the mobility needs of ALL Vermonters, especially those in rural areas. This could include increased route frequency, more nimble services like on-call microtransit, smart growth planning, electrification, microgrids, and even rebates to help people get into cleaner, safer vehicles.
Moreover, TCI has the potential to help the very fabric of where I came from - low-income and rural towns - by shaping investments through a lens of equity and economic opportunity. As do too many Vermonters, I know what it is like to grow up hungry and/or with parents too proud to ask for help. When my older brother gave me rides in his car that had a completely rusted out floor where my feet were supposed to go, it was a bit scary but also kind of cool, then; still I was thankful merely having a ride!
With programs like TCI, we have an opportunity to do more than just business as usual. Vermonters deserve cleaner, safer, and more reliable transit options.
As a staunch climate advocate, I feel it critical to ensure that the most vulnerable are not left behind – particularly when they’re the least responsible for climate change yet bear the most burden, as we saw during Tropical Storm Irene. Equally, I feel it imperative for me to speak out as someone who has endured similar challenges. Many extremely loud voices are spreading extensive misinformation about how vulnerable populations will be most hurt by such a TCI framework. Again, it comes down to choices – in signing on we have an opportunity to design programs ensuring that rural, low-income Vermonters are not disproportionately disadvantaged as the goals of the initiative outline.
Shifting transportation in Vermont can’t be done with the flip of a switch. Like the water challenges we face here, we need a long but focused effort to transition a system that has developed over an expanse of time with significant financial contributions. So where do we start? Well, fervent action is needed now. TCI is by no means the complete answer as it will take time to implement and it will not sufficiently cover all transportation investment requirements. Vermont needs to start the engine of transformation to a cleaner, more accessible transportation system immediately by investing in all aspects of our transportation system – from buses, sidewalks and cleaner cars to supporting our downtowns, developing affordable housing in places where people can walk, and even wastewater infrastructure improvements to help our small villages thrive. Such actions will put Vermont ahead of the curve.
All of this requires a collective approach. Please join me in the statehouse and around the state in advocating for a future that is inclusive and healthy for all - humans, the environment, and other creatures alike. Let’s protect our winters, our magnificent landscape and ALL Vermonters so no one is left out in the rain.

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.