TCI Regional Policy Design Stakeholder Submissions

I support the TCI but would suggest a few modifications/enhancements:
1. Do not exclude non-fossil fuels from the cap. Ethanol and biodiesel have a large CO2 production component from fossil fuels.
2. It is important to let the public know how the revenue will be used to be able to sell the TCI. The revenue should not be used only for changing our transportation modes. More CO2 reduction may be possible by supporting buttoning up lower income resident's houses for example.

To whom it may concern,

Please see the attached comments on the TCI Framework for a Draft for a Regional Policy from the Berkshire Environmental Action Team and No Fracked Gas in Mass.

Warm regards,
Logan Malik
Advocacy Coordinator, Berkshire Environmental Action Team
Program Director, No Fracked Gas in Mass

While I lack the expertise to suggest "the how", I urge that we collectively work for the reduction of emissions. The heavy truck traffic on the interstate highway passing along the eastern boundary of our township noticeably affects our air quality. Personally, it seems obvious to me that a large part of the solution must include the shift of an increasing percentage of goods, particularly those travelling long distances, from truck to rail.

Thank you both for your efforts and consideration of the needs of rural, as well as urban, populations.

Seriously? This is nothing but a money grab.
Will increase the velocity of our State going down the toilet.

Please support the TCI (Transportation and Climate Initiative, which will set a cap on carbon emissions to reduce pollution from gas-guzzling cars, buses, and trucks. We feel it is very important for us to transition away from dirty fossil fuels while at the same time invest in clean reliable public transportation options. We need to clean up our air!

The Baltimore Office of Sustainability appreciates the opportunity to provide input and feedback on the framework for a draft regional policy proposal prepared by the Transportation Climate Initiative. The City of Baltimore has committed to achieving reductions similar to goals set by the Paris agreement: 25 percent reduction by 2020 and 30 percent by 2025 (relative to 2007). Our most recent inventory showed that emissions have dropped by 15-20 percent, but more work still needs to be done to ensure that all residents are able to breathe cleaner air and face reduced risks of natural disasters. About 30 percent of our city’s greenhouse emissions come from the transportation sector.

Our 2019 Sustainability Plan lays out strategies and actions around climate change, transportation, and equity (among other topics), and is the basis for our comments:

Program Design Elements: Equity

• We applaud the emphasis on historic inequities in the development of programmatic outcomes. We recommend that a shared definition of equity be developed and included in the final framework, and that the framework also reflect how equity will also be included in the process moving forward. Will there be shared standards around community engagement and involvement as TCI is implemented and as decisions are made about investment of proceeds.
• The commitment to working with low-income communities, communities of color, and communities with limited mobility options (not just soliciting feedback from) should be strengthened.
• Seemingly absent from this framework is any discussion of how to make the impact of the TCI program less regressive, in terms of mitigating the impact on low-income individuals of the upward pressure on gasoline prices.
• Equity concerns are also central to the “additional program design elements” and more discussion of equity in these sections would improve the framwork and the eventual program.

Program Design Elements: Regulated Entities

• We would like to see clarification about the definition of a ‘supplier’ – will there be a minimum threshold of gallons sold? Is it expected that a City that dispenses fuel only to its own fleet vehicles would be a regulated entity?
• Will there be any industries or categories of entities that are exempted from regulation? If so, the process for determining these exemptions should be public and transparent and include an analysis of the impacts of these exemptions on the cost of the program.

Flexibility, Allowance Allocation, and Stringency

• We would like to see more information in the framework to address the possibility of leakage, or describing why this is not expected to be a problem.
• A risk that TCI is likely already considering is the potential for black market sales of product obtained in non-participant states. This represents a particular risk for poorer communities, insomuch as black market activities might concentrate in those areas.
• The TCI must also be considering border effects for fuel sales. Wealthier, more mobile individuals are more likely to be able to travel to non-regulated jurisdictions to obtain less expensive product.

Additional Program Design Elements: Investment of Proceeds

• We recommend that investment guidelines be jointly developed by member states. At a minimum, these guidelines should cover the process that each jurisdiction should use to get community input into decisions about how to invest proceeds. A preferred hierarchy or proportion of project types would also be beneficial. For example, should a set percentage of proceeds be used to mitigate or offset the impact on low-income households of any price increases?
• Similarly, a proactive emphasis on complementary policies would be valuable. For example, coordinated policy fora might be established to address complementary policies in the area of land use, infrastructure, etc.