TCI Regional Policy Design Stakeholder Submissions

Transportation & Climate Initiative Regional Policy Workgroup,

Thank you for the opportunity to comment on the “Framework for a Draft Regional Policy Proposal” released on October 1, 2019. We – the undersigned organizations – view the Transportation and Climate Initiative (TCI) as an important opportunity for regional collaboration on a pressing problem. We also believe that robust public input into both the regional and state decision-making process is essential to ensure an equitable policy design and the best program possible.

We face an existential crisis when it comes to climate change. Our collective greenhouse gas (GHG) emissions – largely from the combustion of fossil fuels and, in our region, largely coming from the transportation sector – are putting our economies, public health, and quality of life at great risk. Strategies that are carefully designed to reduce carbon pollution as swiftly as possible, in an equitable manner, are essential. TCI offers one of those opportunities. Getting it right, but getting it done, is essential. And, then we will need to do more.

Vermont is far from meeting its long-standing climate goals, with most of our GHG emissions increases coming from our most carbon-intensive sector: transportation. A strong program – including a strong cap – will be important to put Vermont and the region on track to start meeting our carbon pollution reduction commitments.

In these comments we offer some high-level input on our hopes for a strong program that could take our states, and our region collectively, one big step forward to reducing carbon pollution and, importantly, helping to create a cleaner, more diverse, more accessible 21st century transportation system. We appreciate the direction it appears TCI states are moving on several fronts and the opportunity to highlight some of the key characteristics we believe are essential to a strong, equitable program.

Thank you in advance for your consideration of this input and, more so, for your hard work to date – and the important work to come – to shape the design of a program that works for our planet and all people.

Equity
The prioritization of equity in the design of this program is key to its success, and we commend your recognition of it as a top priority. This program must – and, we believe, can – be designed to begin to dramatically reduce greenhouse gas emissions while also improving access, mobility, and public health for vulnerable and disproportionately impacted populations in particular. Ensuring this outcome will require an ongoing, inclusive, and strong public process, in particular for getting input on where any revenues would best be directed. Considering the differences among and within each state, utilizing potential TCI proceeds to address and prioritize equity, mobility, and access for more rural, low income, vulnerable and disproportionately impacted populations is essential.

In rural Vermont, transportation is a huge equity issue. It is a barrier to accessing and retaining a job and meeting basic needs such as getting to medical appointments, the grocery store and the pharmacy. The lack of transportation options leave many Vermonters isolated and alone, specifically the 1/3 of Vermonters who do not drive (this includes one in five adults over 65 years of age, people with a disability, children and those who choose not to drive). It is also a tremendous economic burden for low income households, where transportation accounts for approximately 50 percent of their energy bills. Strategies that serve a rural region well and enable Vermonters access to more clean, diverse transportation solutions are needed, and TCI revenues could serve as an important means to spur the investments required to make this transition.

Affected Fuels and Emissions
We support the TCI states’ proposal to cap carbon emissions from the combustion of motor gasoline and on-road diesel fuel in the region, as these fuels account for the vast majority of emissions from the transportation sector. We also urge that in the future other fossil fuels, such as Compressed Natural Gas (CNG), be considered for coverage as well, to avoid them being falsely viewed as a solution to transportation sector emissions.

Program Design: Auctions, Allocation, Regional Caps and Allowance Budgets
The Intergovernmental Panel on Climate Change (IPCC) has concluded that we have about a decade to substantially reduce emissions if we are to avoid the worst impacts of climate
disruption. As such, it is essential that states set a regional emissions cap at the outset of the program that is sufficiently ambitious to align both with states’ climate targets and with scientific imperatives. To ensure TCI serves as the strongest tool possible to reduce emissions, the cap should start low and drop as quickly as possible, in line with the latest climate science. Further, to achieve the GHG outcomes needed, states should also auction all allowances.

Investment of Proceeds
For the TCI program to succeed – and for states and the region to begin to reduce emissions in our most intensive sector – how revenues are invested is critical. Any TCI revenues must be reinvested in solutions that reduce pollution – as quickly as possible in the short term – as well as set the stage for avoided emissions in the long term, by giving people options for getting where they need to go by walking, biking, and taking transit, and well as the option to live in compact communities close to jobs, services, and amenities.

We believe parameters around the use of these proceeds are essential. These dollars should go to transportation-related solutions or solutions that reduce the need for transportation. TCI proceeds should not be spent to backfill budgets for roads, bridges, general funds, or, even, other needed climate solutions like weatherization or thermal fuel switching. We must find other means to meet these needs, but TCI proceeds should be harnessed to reduce carbon pollution from transportation and help to create a more connected, diverse, resilient, clean, and affordable transportation system.

Specifically, we believe any TCI revenues should prioritize low- and moderate-income and rural Vermonters without access to public transportation. The types of solutions we’d like to see prioritized include electrification of cars, buses, and bikes; transit; transportation demand management strategies like carpool, vanpool, and other creative ride-sharing techniques; safe walking and biking infrastructure; smart growth land use solutions; housing in downtowns and community centers and more.

We appreciate and support the flexibility envisioned for states to identify the best strategies and investments to meet their unique needs. We also hope to see in Vermont – but also potentially to help drive innovation more broadly – the ability for all states to spend some TCI proceeds to fund innovative pilots such as micro-transit, high-efficiency vehicle incentive programs (especially to serve low income earners), or other creative strategies that could drive reductions, enable access, and help to fill in the gaps where more traditional strategies might fall short. This includes enabling the flexibility for geo-targeted investment strategies that could serve specific regions well, considering that the best solutions for bigger cities and towns might not be the best or most-needed strategies to serve smaller communities and rural areas.

Complementary Policies
No one climate policy, including TCI, will accomplish all of the climate pollution reductions we need. We will need a diverse suite of significant, complementary policies to get the job done. We look forward to working with other TCI states, with diverse constituencies in Vermont and beyond and with policy makers to identify and advance that suite of other strategies to complement TCI, finally putting us on the path to meet science-based reduction targets we so desperately need to meet.

Conclusion
This regional effort presents the most promising opportunity at this time to tackle emissions reductions in our heavily carbon-intensive transportation sector. Shaping a strong program in line with the climate science, while also prioritizing strategies and solutions to serve low-income, rural, and disproportionately impacted communities is imperative.

As noted above, even a strong TCI will not be sufficient to do all that we must to reduce pollution. That is why we also strongly encourage you to design an equitable TCI program that could, one day, potentially link to other carbon markets – if that made sense. We know that reducing carbon pollution in our heating sector is also a climate imperative. The ability for a well-structured TCI program to link to successful programs like California and Quebec’s Western Climate Initiative would provide the flexibility for the region (or states in the region) to participate in this economy-wide market. We urge you to enable that kind of design and flexibility in the program.

Thank you again for your hard work, your ongoing commitment to designing a science-based, equitable, and flexible program, and for your consideration of our input.

Sincerely,

Audubon Vermont
Capstone Community Action
Transportation for Vermonters
Vermont Conservation Voters
VEIC
Vermont Natural Resources Council
Vermont Public Interest Research Group



CC:
Julie Moore, Secretary of the Agency of Natural Resources
Peter Walke, Deputy Secretary of the Agency of Natural Resources
Michelle Boomhauer, Director of Policy and Planning, Vermont Agency of Transportation
Curt McCormack, Chair, Vermont House Transportation Committee
Dick Mazza, Chair, Vermont Senate Transportation Committee
Vermont Senate President Pro Tempore Tim Ashe
Vermont Speaker of the House Mitzi Johnson

Governor Scott, please ignore what those folks across the CT river might do and get Vt solidly behind the REGGI transportation initiative. We need you to get us there! Thank you, Gus Speth

Please consider the value of drawing down carbon by building soil health in the discussion about how to allocate funds to be received from TCI. This also can contribute to improved water quality, climate resilience, and food production. Compensating farmers and other land managers for building soil carbon and water storage is one important part of Vermont's climate objectives. The Payment for Ecosystem Services Working Group is currently working on ways to measure ecosystem services provided by farmers and land managers, and identify sources of funding to reward them for this work. Perhaps TCI could provide part of the revenue needed to compensate farmers for drawing down carbon.

Another readily measurable way to reduce our GHG emissions is to encourage substitution of biological methods such as compost application and cover cropping for use of synthetic nitrogen fertilizers. Support for farmers to replace synthetic nitrogen with compost to provide crop nutrients will serve to sequester carbon in addition to reducing nitrous oxide emissions. Nitrogen synthesis currently consumes vast quantities of natural gas in an energy intensive process. As a bonus, implementation of the solid waste recycling requirement would be supported by market incentives for community based compost production--a win-win for both environment and farm economy.

Thank you for considering these suggestions, submitted on behalf of the Vermont Healthy Soils Coalition - www.vermonthealthysoilscoalition.org

Vermont Energy Education Program (VEEP) works with students and teachers from schools around Vermont. Young people around the state (our newest and soon-to-be voters) are worried about climate change and looking for positive action to reduce carbon emissions and increase resiliency. With 44% of Vermont's climate pollution coming from Transportation, it is clear to me, and to our youth, that we need to be making positive changes in our transportation system. I urge Vermont to participate in the Transportation and Climate Initiative.

Vermont needs new funding source to be able to create transportation that will work for all, including families and young people. Because it is regional, and it's burden on individual households is low, TCI is the best tool we have in the near future to provide this funding.

The RGGI model provides an excellent example of how this sort of programming can create a positive change for our state. As you know Vermont has been able to weatherize many, many more low and moderate income homes than would have been possible without RGGI's $2 million dollars each year. Similar strategic funding for transportation from a regional initiative would make a very noticeable difference for our transportation system.

Our young people are asking us to make real change on climate. They deserve to have programs like TCI put into place. New forward-thinking programming and action funded by TCI will make Vermont the kind of place where young people choose to stay to raise their families.

Please forward this to Governor Scott

Dear Governor,

I ask that you bring Vermont into the Transportation and Climate Initiative (TCI).
My household of 3 voters believes TCI provides a bold path forward for reducing climate pollution in the transportation sector and spurring investment in public transportation and other much-needed transportation infrastructure.
Climate change has become our most important political/social/spiritual action and should be bipartisan.

To Whom It May Concern:
I want to express my enthusiastic support for this multi-state initiative. It is past time to be taking concrete steps - aggressive steps - to address climate change. I hope those involved will move ahead quickly and a clear sense of the narrowing window we have to prevent the worst effects of global warming.
Sincerely,
Hillary Twining

PLEASE, Governor Scott, join the Transportation and climate initiative. First of all, it addresses the main problem our generation must solve for our descendants and the world. We should be willing to spend big to solve it, but I believe that this particular initiative will actually pay for itself, that the structure of TCI will return any increase in fuel prices back to all of us ten-fold – through initiatives that promote low emitting transportation and by helping low income Vermonters – just as RGGI has done. So you need not fear it will damage Vermont's economy. In fact, NOT solving our climate crisis would eventually ruin it entirely.

February 28, 2020

To: Governor Ned Lamont, Governor John Carney, Governor Janet Mills, Governor Larry Hogan, Governor Charlie Baker, Governor Chris Sununu, Governor Phil Murphy, Governor Andrew Cuomo, Governor Tom Wolf, Governor Gina Raimondo, Governor Phil Scott, Governor Ralph Northam and Mayor Muriel Bowser.

On behalf of Vermont Businesses for Social Responsibility (VBSR), I am writing to express strong support for the Transportation and Climate Initiative (TCI) and comment on the draft Memorandum of Understanding (MOU.)

Vermont Businesses for Social Responsibility is a business association representing over 730 business members in every industry and every county across the state; united in our shared mission to advance an ethic that protects the natural, human, and economic environments of Vermont as a business thrives.

From global brands like Ben & Jerry’s and Burton to small startups like Mamava, VBSR members are some of the most successful and iconic businesses in our state, who together shape the Vermont brand. Of the top 25 companies in Vermont, 13 are VBSR members – including our champion members Green Mountain Power and National Life Group. Those 13 companies together earned over 9 billion dollars in revenue in 2012, according to Vermont Business Magazine.

In 2018, we surveyed our members on annual revenues – just under 50%, or about 185 companies, earn less than $500,000 a year. About 16% earn between $500,000 and $1 million a year, 9% earn $1 to 5 million a year, 7% earn $5-20 million a year, and 10%, or about 70 companies, earn over $20 million a year in revenue.

No matter their size our businesses recognize that our continued reliance on fossil fuels is triggering a climate crisis and stifling our economy. The longer we delay in taking action the more exacerbated these impacts become. For Vermont, the transportation sector accounts for nearly half of our carbon emissions and so it is imperative that we seize this rare opportunity to decarbonize our region’s transportation system with a strong, equitable TCI cap-and-invest program.

The potential benefits of this carbon pricing system make it a far cry from the gas tax opponents claim it will be. A cap and invest system would establish a limit on carbon emissions and a regional auction for participating states to sell their emissions allowances. They can then invest those revenues into cost-saving programs designed to reduce prices at the pump such as electric vehicle (EV) incentives, rural broadband to support remote work and telemedicine, bike and pedestrian infrastructure, public transit, and more. Conversely, a gas tax means higher costs at the pump without any palpable transportation or environmental benefit.

VBSR urges the working group to develop a program that will not only decrease climate pollution but use program revenues to address the needs of rural, low-income communities who are overburdened by vehicular pollution, transportation costs, and a lack of clean transportation options. These communities are often those most directly impacted by the adverse effects of climate change and as such should enjoy the strongest benefits of this program. Considering the different challenges each state faces in our region, we also call for strategic, state-by-state investments to be made to ensure equity.

The challenges rural, working Vermonters face are far different than those living in Boston, Baltimore, or Burlington, so it is essential that we give states the flexibility to invest program revenues into transportation solutions that serve their respective communities rather than take a one-size-fits-all approach.

The urgency to develop and implement TCI cannot be overstated and VBSR is pleased to see that the timeline outlined in the draft MOU reflects this. The initial compliance period launch on January 1, 2022 recognizes the need to take swift action while providing states with adequate time to elevate the program and prepare for participation.

Along that same line, we strongly urge that the working group adopt an emissions cap on transportation pollution at a pace and scale in line with science by requiring no less than a 25% pollution reduction in the first ten years from the program’s 2022 adoption. There is a clear consensus within the scientific community that significant, rapid pollution reductions are needed, and we implore you to consider pursuing even more ambitious greenhouse gas reductions moving forward as well as continuous programmatic evaluation of TCI to ensure its continued progression and efficacy.

Climate change is without question the single greatest threat to Vermont's communities, ecosystems, and shared way of life. Spring is arriving earlier, heavy rainstorms are becoming commonplace, and our summers are hotter and drier than ever. Meanwhile more frequent and severe storms cause floods that cost us millions in damaged property and infrastructure. From winter recreation and local food driven tourism to manufacturing and service industries, these changes disrupt nearly every facet of our state’s economy— and we can no longer afford half measures.

TCI offers one of the most promising opportunities to advance solutions that recognize our shared responsibility to take action, strengthen our economy and bring Vermont’s most vulnerable along in our climate future by reducing pollution from the transportation sector. We appreciate the opportunity to comment and your continued work to improve and implement a strong, equitable program.

Thank you,

Jordan Giaconia
Public Policy Manager
Vermont Businesses for Social Responsibility
Jordang@vbsr.og
860-304-2251(mobile)

Hello,

I'm listening to the 5/23 webinar, and mostly watching the TCI process somewhat from the periphery. Here are my comments and my interest.

Comments:
I support how the analysis of baseline transportation looked at EIA's NEM as well as other sources. My impression is that EIA's predictions have been very poor, missing some big trends, especially longer-term trends, like growth of renewable energy.
Given my interest in heavy-duty fleets (see below), I look forward to hearing more about something other than EVs, and how those non-EV options would be monetized in TCI. Looking at modeling done for Vermont's Comprehensive Energy Plan, climate goals are reached with biofuels, not just electrification. I assume that GHG emissions from heavy-duty and medium-duty fleets are non-trivial in the Northeast, and electrification in these fleets seems immature compared to passenger EVs and light-duty EVs. What can you do to model this the medium-duty and heavy-duty sector?? E.g. what are the recent history and trends for natural gas and RNG, in usage and in which types of vehicles? I assume DOE's AFDC has the data.

My Interest:
Being in the agricultural sector, and with Vermont's biogas potential from dairy manure, I am intent on getting RNG produced and used as a way to support farms and offset GHG emissions. The Agency of Agriculture and others will analyze the statewide potential, using existing digesters, which process only 10% of Vermont's dairy manure, and new digesters. Back of the envelope, I estimate 500-1000 Class 8 trucks could be operated on RNG from Vermont's dairy manure.
Please remember that the global warming potential of methane is ~25x of CO2 in the 100-year time frame, but it is ~85x CO2 in the 25-year timeframe. Used in transportation, RNG from dairy manure is strongly carbon-negative: -276 gCO2e per MJ. Electricity is 20-40 gCO2e/MJ (see slides 7-9 of the attached presentation).

I'm glad to discuss as necessary.

I appreciate the opportunity, thank you.

Alex