TCI Regional Policy Design Stakeholder Submissions

Transportation is the country’s and region’s leading source of carbon emissions so it is imperative that Pennsylvania join the Transportation Climate Initiative (TCI) to clean this sector up. Joining TCI is critical step to improving transportation and addressing the climate crisis in Pennsylvania.

If designed correctly, this program could help to create safe roads for biking and walking, more frequent and reliable public transportation, greater access to electric vehicles, and a more equitable system with cleaner transportation options for everyone in the region.

TCI is a key initiative for the future of our region. We need a plan that holds large transportation polluters accountable for the pollution they create and invests in clean transportation solutions including:
- More public transit and electric vehicle infrastructure in rural areas
- Expansion of commuter rail, electric vehicles, and streets in the suburbs that are safe, walkable, and bikeable
- Sustainable and equitable housing near transit and electric bus fleets in urban communities

Dear TCI Team,

Our Climate is so grateful for your hard work to expand regional carbon pricing to a new sector of the economy and to do so in an inclusive, collaborative, bipartisan manner. On the whole, we stand by the comments submitted by the larger Massachusetts Campaign for a Clean Energy Future, particularly their two fundamental values that a carbon price must be science-based and equitable. However, we’d like to note several additional areas of concern:

1. Both the current TCI draft and the Massachusetts campaign document refer to RGGI as an effective precedent to emulate in several ways. We would like to reiterate that, for all the revenue RGGI has generated, we have yet to find a single economist who argues that the RGGI price ($5.20/ton at the Sept 2019 auction) has been high enough to drive the emission reductions needed to mitigate the climate crisis. This argument is further spelled out in this article from Vox <https://www.vox.com/science-and-health/2017/2/28/14741384/rggi-explained>

When it comes to setting a cap, we think TCI should set an aggressive maximum of carbon neutrality by 2050, with interim targets of 45% emission reductions by 2030 that all participating states must adhere to. States can then individually choose to be more ambitious if they wish, but we must provide states where industry is strong the legal mandate to fight the climate crisis.

We are also very concerned about the language around “cap flexibility” and “set asides.” A responsible system must plan for what history has taught us--that industry will fight tooth and nail to dodge its financial responsibilities. The MA campaign critiques on limiting cap flexibility and banking of permits are correct but don’t go far enough. In a climate emergency, we should not allow for flexibility, set asides, or banking, period. Industry must not be given wiggle room.

2. In MA, we are very proud of the design of H.2810 which uniquely proposes redistribution of 70% of its funds directly to families to financially equip them to make greener decisions. These rebates are weighted by income to ensure financial protections for the low-income communities most affected by climate change. This is the only carbon pricing bill to my knowledge that has received explicit support from Environmental Justice organizations in MA, and we must consider whether a progressive rebate structure is possible in TCI to ensure that no family is left in a difficult situation.

Meanwhile, our team in New York is quite concerned that New York Renews Coalition which just passed the CLCPA and is designing the CCIA, will face similar complications to MA. The careful work to build relationships with EJ communities for our state level prices does not seem to be transferring to the TCI process. This is partially why NY’s participation in TCI is currently tenuous.

In my previous commentary, I mentioned the concerns of our partners at the Climate Justice Alliance. Since that time, they have released another set of criticisms on use of Cap and Invest as a structure <https://climatejusticealliance.org/climate-justice-alliance-disappointed-disingenuous-policy-design-principles-proposed-transportation-climate-initiative-tci/>. TCI must provide specific allowances and guidelines for the equitable use of funds that it invests and will give local Green Justice communities the power to design a way to use those resources that meets their needs as they see them, not as the TCI administrators perceive them.


Thank you so much,
Our Climate

Electric vehicles offer many advantages:

*No polluting emissions of CO2 (and CO!), no oxides of Nitrogen, carbon soot or oily “blow-by.”
*Less maintenance: fewer moving parts, no oil changes or tune-ups
*Inherently quiet; no muffler necessary or catalytic converter
*Lower energy cost per mile
*Charging rates now faster than you can consume a sandwich or visit a restroom.
*Charging often can be integrated with the vagaries of solar and wind.

**I’ll repeat the greatest value: EVs can make a significant contribution to mitigating climate warming.

In short What’s not to like!

We trust you folks to make the decisions that will leave a livable world for your grandchildren.
Thank you.

The framework looks good. The cap and invest program won't be enough to meet climate targets. Starting in early 2022 is not soon enough. Can you pilot this next year on a smaller level to work out kinks and answer questions? Thank you

TCI I’m against this program and I feel that our government should practice what they preach it should start there,then present the numbers. Have All government officials use public transportation and electric cars. We are not going to fix this with a tax. A tax will just give government more money to mismanage. Plus we contribute less green house gases then China.Europe and America contribute less greenhouse gasses then China ........ FIX CHINA. As a small business I’m still paying a delivery (gas fee) for every delivery I get that started when gas was over $4 per gallon and it was never removed from any delivery and our volume sales of gas didn’t go down. A small percentage of neighborhood people got rid of the gas guzzlers when cash for clunkers happened and that caused a shortage of used parts for older vehicles. I’m done ranting.

We ALL need Clean Air! I developed asthma while living in a smoggy area. Lost productivity and increased healthcare needs are FAR more expensive than good transportation planning!

We can cut poverty and pollution at the same time. We urge you to move forward with a regional program that prioritizes the needs of communities overburdened with pollution and underserved in mobility options