8/30/2019 |
Marc |
Breslow |
Climate XChange |
Boston |
Massachusetts |
Please find attached joint comments from Climate XChange and Health Care Without Harm concerning the planned modeling scenarios for TCI, directed to the Technical Analysis Workgroup. Please find attached joint comments from Climate XChange and Health Care Without Harm concerning the planned modeling scenarios for TCI, directed to the Technical Analysis Workgroup. |
CXC-HCWH Modeling Comment Letter 8.30.19.pdf |
12/4/2019 |
Marc |
Breslow |
Climate XChange |
Boston |
Massachusetts |
Massachusetts Campaign for a Clean Energy Future
December 3, 2019
Response to Transportation and Climate Initiative
Framework for a Draft Regional Policy... read more Massachusetts Campaign for a Clean Energy Future
December 3, 2019
Response to Transportation and Climate Initiative
Framework for a Draft Regional Policy Proposal
Dear state government TCI officials:
This statement responds to your call for comments on the “Framework for a Draft Regional Policy Proposal.” We greatly appreciate your openness to public input on the proposal, and the depth of discussion in your draft.
We represent the Massachusetts Campaign for a Clean Energy Future (MCCEF), which is a coalition of organizations advocating for an economy-wide carbon pricing policy in the state. As such, we support the development of a robust and equitable cap-and-invest program for the transportation sector through TCI, but also recognize that TCI and RGGI only get us two-thirds of the way toward an economy-wide system, and urge states to extend carbon pricing to the heating fuels sector. Only by implementing carbon-reduction strategies throughout all the major fossil fuel-consuming sectors can the states achieve their goals to reduce emissions by 80 percent by 2050 -- or the more ambitious goals now being implemented in many states, such as 100 percent clean energy. Given the severity of the climate crisis, we cannot wait to take action to reduce carbon emissions from all sectors.
We support the points put forward by the Our Transportation Future (OTF) coalition, and some of our groups are members of that coalition. We will add here only points that are additional to OTF’s, or that we need to additionally emphasize.
Attached along with this statement we are attaching our Statement of Principles, which gives our criteria for a carbon pricing policy that is sufficiently strong to move our economy toward zero emissions. Our two basic principles state that carbon pricing must:
Achieve, in combination with other policies, the state’s GHG reduction mandates;
Ensure that the vast majority of low-income, and most moderate-income, people come out ahead or even from the combination of carbon pollution charges and use of the resulting revenues for rebates/tax cuts and reinvestment.
Beyond those two principles, below are our comments specific to the plan for TCI:
Cap levels - the cap must be set, initially and in future years, so that it will achieve in the transportation sector the reduction in emissions called for by the Massachusetts Global Warming Solutions Act and by similar acts in other states, which is at least 80 percent by 2050. Given that the transportation sector constitutes the largest portion of our emissions, we believe that this requires a 40 to 45 percent reduction below 1990 levels by 2030. As calculated by OTF, this would require beginning with a cap level of 250 MMT in 2022 and declining by 40 percent to just over 150 MMT by 2032.
Recent scientific evidence indicates that greater reductions are needed, and we would urge the TCI states to set the caps according to this evidence. We would further urge the states not to set the cap levels higher in order to prevent allowance prices from rising above a predetermined level. While such prices may cause motor fuel prices to rise significantly, the depth of the climate crisis means that we cannot avoid such price rises - which can be mitigated through use of the proceeds.
Use of the proceeds - We understand that use of the proceeds will be up to the individual state governments, but we believe that TCI should set standards for their use, just as was done under RGGI. Most carbon revenues should be allocated to investments that reduce GHG emissions, while also meeting essential public needs and creating jobs. This includes projects that support low-carbon transportation, including public transit and electric vehicles, and resilience to climate change impacts. The burdens of higher fuel prices can be mitigated by using the proceeds from allowances in ways that reduce transportation costs for environmental justice communities, low-income populations, and other vulnerable groups. In addition to investment spending, proceeds returned as cash benefits to low and moderate income consumers may be necessary to ensure that low- and moderate-income populations benefit from the program.
Just Transition - We believe that a Just Transition to a clean energy future requires addressing the possible losses that will occur to workers who lose jobs and to communities that face losses to their economies and tax revenues due to shrinkage of fossil fuel industries. We therefore support the provision of transition benefits and training for workers and communities who are affected. We also urge that all employment provided with carbon pricing revenue be at union-scale wage levels.
Integrity of the cap - The various design aspects of the program should be
transparently constructed and limited in order to ensure the program’s effectiveness. In particular, measures taken to moderate the costs of the program, such as offsets, price ceilings, and banking must only allow the cap to be exceeded in extreme circumstances and for limited time periods.
Baseline emissions must be transparently calculated and the initial cap must be stringent enough to avoid a future surplus of “banked” allowances.
If offsets are allowed they must meet the requirements currently used by the Regional Greenhouse Gas Initiative, including that offset projects should take place only within the regulated territory covered by TCI.
If a Cost Containment Reserve (CCR) is included, the trigger price must be set sufficiently high so that additional allowances are only made available under exceptional circumstances. If CCR allowances are purchased, the cap should further be reduced over the following five years by a quantity equal to or greater than the amount of CCR allowances purchased.
A price floor must be included that ensures stability of revenues and allowance prices in the range anticipated in the policy design.
Thank you for allowing us to provide our comments concerning the design of TCI. We look forward to further discussions on how best to reduce transportation sector emissions and to improve the functioning of the region’s transportation systems.
Yours truly,
Mary Ann Ashton, Co-President, League of Women Voters of Massachusetts
Marc Breslow, Policy and Research Director, Climate XChange
Nancy Goodman, Vice President for Policy, Environmental League of Massachusetts
Kristin Kelleher, Programs Director, Climate Action Business Association
Cindy Luppi, New England Director, Clean Water Action
Bill Ravanesi, Senior Director, Green Building & Energy Program, Health Care Without Harm
Jordan Stutt, Carbon Programs Director, Acadia Center
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MA carbon pricing coalition TCI comments 12.3.19.pdf |
12/4/2019 |
Marc |
Breslow |
Climate XChange |
Boston |
Massachusetts |
Attached are the principles for carbon pricing from the Massachusetts Campaign for a Clean Energy Future; in conjunction with our comments on the TCI Framework for a Draft Regional Policy Proposal... Attached are the principles for carbon pricing from the Massachusetts Campaign for a Clean Energy Future; in conjunction with our comments on the TCI Framework for a Draft Regional Policy Proposal. |
MCCEF Carbon pricing principles 9.12.19.pdf |
2/20/2020 |
Michael |
Green |
climate xchange |
Woodstock |
Vermont |
The business community understands the importance of taking action on climate change. This initiative creates the opportunity to invest in our local community transportation systems while also... read more The business community understands the importance of taking action on climate change. This initiative creates the opportunity to invest in our local community transportation systems while also addressing the climate crisis. Living in central Vermont, we have no access to public transportation. We have back-and-rides in almost all of our communities but nothing connecting them. In the winter, we have thousands of people driving each day between Rt 4, 100, and 107 between hotels ski resorts and different tourist destinations. We could alleviate the traffic, congestion in our small town, and restore our broken roads.
As a person living in a rural area, I think that TCI is extremely important. When states join TCI, they have the opportunity to invest in rural communities where transportation options are limited. Joining TCI would allow Vermont to ensure that rural communities aren’t left behind in the green transition and stuck behind the wheel of costly, inefficient vehicles. Our Governor should push for an ambitious TCI program so that rural communities like mine get the solutions they need. |
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2/24/2020 |
Sudhanshu |
Mathur |
Climate XChange |
Boston |
Massachusetts |
Given the grave challenge of climate change that we have been facing, it is absolutely imperative that we adopt the necessary mandates to do what's necessary to save our people and our planet... read more Given the grave challenge of climate change that we have been facing, it is absolutely imperative that we adopt the necessary mandates to do what's necessary to save our people and our planet. TCI can be a critical step on the path to more expansive carbon pricing mechanisms, so TCI has my full support, as well as the support of our communities, to be implemented. We need to think about the long-term arc of our society - in terms of public health, transportation, and environment - and carbon pricing is the most effective way of shaping a stronger future for our children. Let us not forget that TCI idealizes sustainable development, by improving the environment with the benefit of economic growth. Those that oppose TCI fail to understand how it gives us the chance of not only rectifying persevering injustices, but also positively and meaningfully reaping substantial benefits for all our communities. I'd like to call upon the governors of ALL the states to commit to TCI, in the best interests for their constituents. But more importantly, I'd like to wholeheartedly urge the leaders of TCI to clearly communicate the impressive possibilities of such a program, in a way that creates the broad support needed to successfully advance climate change policy. |
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10/15/2020 |
Jonah |
Kurman-Faber |
Climate XChange |
Somerville |
Massachusetts |
Please see attached for a technical memo by Climate XChange that responds to the TCI state's first listed equity provision on the September 29th equity webinar. In particular, this memo... read more Please see attached for a technical memo by Climate XChange that responds to the TCI state's first listed equity provision on the September 29th equity webinar. In particular, this memo focuses on what level of detail in the regional MOU, vs subsequent state model rules, can help ensure that percentage-based equity requirements for investment function as intended.
The two essential language provisions we outline are: 1) Ensure that proportionately higher revenue goes to overburdened and underserved communities that the percentage of the population that qualifies; and 2) require investment dollars be located within and directly benefit overburdened and underserved communities in order to count towards equity requirements.
The memo also proposes two additional measures to improve the program's ability to deliver on equitable investment: 1) Comprehensive state screening tools as the census tract level or smaller that bring together socioeconomic and environmental metrics; and 2) New capacity-building and ground-up governance structures to control TCI revenue. |
CXC Technical Memo - TCI Investment Equity.pdf |
3/13/2020 |
Michael |
Moehringer |
Clintons Ditch Cooperative Co., Inc. |
Cicero |
New York |
I am adamantly opposed to this initiative. For the reasons well summarized in your email.
We will be placed at an economic disadvantage relative to those that choose not to... read more I am adamantly opposed to this initiative. For the reasons well summarized in your email.
We will be placed at an economic disadvantage relative to those that choose not to participate, small businesses like ours will be hurt by rising costs. The infrastructure built will not benefit my business, but will but force us to pay more for fuel that is pretty much not optional for my business. Central New York also has a large economic base in distribution and logistics, manufacturing, and agriculture that could be adversely affected by fuel price increases.
Centerstate CEO should NOT advocate for such an intiative, our state is already at a competitive disadvantage due to burdensome tax and regulation, this would further exacerbate that condition. It would add yet another cost burden to doing business here that would have to be passed on to the consumer. And in the end, I don't believe it would have any real impact on "health benefits and economic benefits". |
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1/28/2020 |
Pat |
Galvin |
CMS |
Marshfield |
Massachusetts |
I would like to suggest if you will really wish to make a difference in transportation North-South-East & West of Boston, please consider the development of a monorail system. After 20 years... read more I would like to suggest if you will really wish to make a difference in transportation North-South-East & West of Boston, please consider the development of a monorail system. After 20 years of traveling the expressway to and from my job, I use to sit in my car and try to decide what would it take for me to leave this driving nightmare and yet arrive at work timely and efficiently. I had to ask myself what would incentivize me and others to change our daily driving habit of getting to Boston? The only answer I could arrive at was a full-service monorail system that would be elevated right down the center of the expressway with strategically placed stops and parking nearby. The monorail would have wires included in the railing that would prevent the buildup of ice and snow allowing an enhanced speed without the danger and delay to the drivers that they are constantly subjected too. Putting such a system down the middle of this highway would serve as a constant reminder to drivers and motivation that there exists a better way to get to and/or from town most expeditiously. This project could put in place in phases and probably attract both private and federal funding. This would solve our current dilemma of convincing our drivers to leave their cars in more strategic locations and/or at home.
I would love to work on such a project as it is my opinion a WIN-WIN for all of us both for personal and businesses alike. |
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12/17/2019 |
Martin |
Touhey |
COA member |
Halifax |
Massachusetts |
The TCI will be an unfair tax on most seniors who are on a fixed income. The TCI will be an unfair tax on most seniors who are on a fixed income. |
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11/5/2019 |
Alex |
Kragie |
Coalition for Green Capital |
Washington |
District of Columbia |
Please see attached letter Please see attached letter |
TCI_Comment_Letter_Final.pdf |
11/5/2019 |
Sam |
Wade |
Coalition for Renewable Natural Gas |
Sacramento |
California |
Please see our attached comment letter. Please see our attached comment letter. |
191105 RNGC Comments on TCI Program Design Framework.pdf |
2/28/2020 |
Sam |
Wade |
Coalition for Renewable Natural Gas |
Sacramento |
California |
Attached please find our comments on the Draft MOU. Attached please find our comments on the Draft MOU. |
200228 RNGC Comments on TCI Draft MOU.pdf |
2/28/2020 |
Sam |
Wade |
Coalition for Renewable Natural Gas |
Sacramento |
California |
Attached please find a study by MJ Bradley describing the potential benefits of renewable natural gas to the TCI region. (This study is referred to in our comments submitted under a separate form... Attached please find a study by MJ Bradley describing the potential benefits of renewable natural gas to the TCI region. (This study is referred to in our comments submitted under a separate form.) |
MJBA_Role-of-Renewable-Biofuels-in-a-Low-Carbon-Economy.pdf |
8/19/2019 |
Stewart |
Schwartz |
Coalition for Smarter Growth |
Washington |
District of Columbia |
To reduce emissions from transportation we need a strong focus on the land use/transportation connection. We need to focus growth in cities and towns and in walkable, mixed-use, mixed-income,... read more To reduce emissions from transportation we need a strong focus on the land use/transportation connection. We need to focus growth in cities and towns and in walkable, mixed-use, mixed-income, transit-oriented centers and corridors. Funding transit alone will not be enough - it must be connected to compact, walkable development. Universal adoption of electric vehicles while not addressing sprawling development will mean continued long-distance driving and highway construction, while also risking the conversion of vast acreage of farms and forest to solar arrays just to supply longer distance vehicle travel. So land use must be a primary focus. As for investments to be made - they should include transit tied to land use, reduction in transit fares, affordable housing close to transit, jobs and services, and other infrastructure that supports transit-oriented communities.
The Coalition for Smarter Growth is a 22-year-old non-profit working in DC, Maryland and Virginia and the leading organization promoting walkable, transit-oriented communities (TOD) as the best way for the DC region to grow. We have convinced the Metropolitan Washington Council of Governments to make TOD the core framework for regional growth in their Region Forward Plan and in their Visualize2045 long range transportation plan, however, spending practices by state and local government still include massive highway and arterial road expansion. Meanwhile the region must do more to advance public and private investment in TOD at Metrorail stations and other high capacity transit. We received the MWCOG Regional Partnership Award in 2017. |
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2/28/2020 |
Stewart |
Schwartz |
Coalition for Smarter Growth |
Washington |
District of Columbia |
See attached file See attached file |
2020.02.28 CSG Comments on TCI MOU.pdf |
11/6/2019 |
bernardo |
alayza mujica |
coasap |
Sioux City |
Iowa |
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1/6/2020 |
Michael |
Riley |
COASTAL MANAGEMENT GROUP LLC |
Narragansett |
Rhode Island |
"The Moral Case for Fossil Fuels" by American energy theorist Alex Epstein argues that, although sometimes labeled as "immoral," the use of fossil fuels dramatically improves... read more "The Moral Case for Fossil Fuels" by American energy theorist Alex Epstein argues that, although sometimes labeled as "immoral," the use of fossil fuels dramatically improves the overall progress of humanity, and improves life expectancy and income. Senator Sheldon Whitehouse should also read "The Moral Case for Fossil Fuels." Rhode Island will not benefit by yet another tax on its citizens. |
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10/25/2019 |
Hannah |
McGhee |
Coastal Rivers Conservation Trust |
Newcastle |
Maine |
Maine needs to act now to begin reducing harmful climate-changing emissions, and to develop transportation solutions for people of all ages, abilities, and levels of income, especially in our... read more Maine needs to act now to begin reducing harmful climate-changing emissions, and to develop transportation solutions for people of all ages, abilities, and levels of income, especially in our rural areas. Working together with neighboring states to achieve this is a no-brainer. |
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11/5/2019 |
Tom |
Tietenberg |
Colby College |
Waterville |
Maine |
We know that reductions in emissions from the transportation sector are essential if we are to lower the threats posed by climate change. We also know that emissions reductions are considerably... read more We know that reductions in emissions from the transportation sector are essential if we are to lower the threats posed by climate change. We also know that emissions reductions are considerably cheaper than suffering the increases in damages that inaction brings. Further we know that the longer we wait to lower those emissions, the higher the cost will be. As someone who has studied these kinds of systems for my entire career I know of no more cost-effective and fairer approach than this type of system. I look forward to reading the comments of those who propose an alternative system capable of achieving achieve similar emissions reductions that can be demonstrated to be both fairer and more cost-effective than this proposal. |
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2/28/2020 |
Rachel |
Scott |
Collaborative Center for Justice |
Hartford |
Connecticut |
We write from the Collaborative Center for Justice, which is a faith-based advocacy organization based in Hartford, CT. We are sponsored by six congregations of Women Religious around the state... read more We write from the Collaborative Center for Justice, which is a faith-based advocacy organization based in Hartford, CT. We are sponsored by six congregations of Women Religious around the state. Environmental justice has been one of our priority areas for our education and advocacy work over the years.
We support the development of a strong multi-state Transportation and Climate Initiative and we urge Governor Lamont to fully support participating in this critical initiative. Transportation is the largest source of greenhouse gas emissions, and emissions will continue to grow if timely action is not taken to transform our transportation system. This initiative is a critically important opportunity to make changes that will lead to an increase in clean transportation and reduced greenhouse gas emissions.
We urge leaders to include provisions to prioritize investments in frontline communities that have already disproportionately borne the burdens of environmental injustices. Low-income communities and communities of color already face greater exposure to pollution from vehicle emissions, fossil fuel plants and incinerators in and near their communities. These communities need to be prioritized in the transition to clean energy. We also call upon the leaders of this initiative to meaningfully include voices from directly impacted communities in each step of the development and implementation processes.
We urge you to ensure the inclusion of the following components when developing the final program: commitment to utilizing investments to improve and expand public transportation in the state; increasing and improving bike lanes and sidewalks; and investing in expanded rail service across the state and region. This is an opportunity to make it safer, more affordable, and more possible for people to take public transportation to school and work from where they live. Increasing the frequency of buses and trains and expanding their routes are two important components to make these changes possible. It is also important to increase the availability of bike lanes so that people can safely commute from a public transit stop to another location by bike. Investment in fixing potholes, particularly on busy city streets, is also an important component of improving biker safety.
Residents who already commute to school and work by public transportation face challenges with our current system too. Many bus routes do not have frequent enough schedules to meet the needs of the residents who depend on them. In many cases, taking a bus to school or work is very time consuming because routes and connection points are limited. Bus routes need to be expanded in cities and to neighboring suburbs in order to better address this problem.
We also recommend that investments be used to transition school and public buses to electric buses. Increasing the number and expanding the locations of charging stations around the state would support the transition to electric buses and cars. Transitioning to electric buses will have important public health benefits for the children and adults who ride the buses, as well as for the wider community.
As people of faith, we concerned about the health and wellbeing of all people and our planet. We are particularly concerned about the impacts of environmental injustices on low-income communities and communities of color. We believe that there is an urgency to our actions to implement climate change mitigation and adaptation strategies. As a state and region, we have a collective responsibility to make changes to our transportation sector that will address and end these injustices, and move our society toward cleaner and more equitable transportation options in the most immediate way possible. We look forward to Governor Lamont’s leadership and commitment to this critically important initiative.
Respectfully submitted,
Dwayne David Paul – Director
Rachel Lea Scott, MSW – Associate Director
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