TCI Regional Policy Design Stakeholder Submissions

The earth has had warmer and colder seasons always. Check with the Univ of Maine and their core samples from Sebasticook Lake in Newport. They concluded that the earth was hotter and drier than now 6000 to 8000 years ago. God is in charge of the climate/atmosphere/universe and He would never allow us even the smallest charge over it. Please keep in mind while you are reducing carbon use that everything on earth uses carbon dioxide and it is necessary for life.

It is not right to try to Push this Gas Tax without the Peoples Vote

On behalf of the Advanced Energy Economy Institute and its affiliate in New York State, the Alliance for Clean Energy New York, we are writing to express our general support for the Framework for a Draft Regional Policy Proposal that was released on October 1.

Before commenting on individual components of the framework, we would like to underscore the importance, timeliness, and wisdom of a multi-state initiative to tackle greenhouse gas emissions from the transport sector. In New York, the recent passage of the Climate Leadership and Community Protection Action demonstrates that New Yorkers are ready for action on climate change, including measures addressing transportation. In contrast to the electricity sector, emissions from transportation are on the rise and are making up a larger and larger percentage of state and regional greenhouse gas emissions. Therefore, it is imperative that states take quick action to cap and gradually reduce these emissions.

Further, just like our states are connected by numerous roads and railways, our policies should be coordinated among states whenever possible, to maximize the beneficial impact and minimize unintended consequences. For this reason, we fully support the initiative for multiple states to work together to align policies.

Some further points:
-- We agree that equity is an important consideration of the Framework for a Draft Regional Policy Proposal. Including this perspective from the outset will lead to a stronger and more sustainable program.

-- At the present time, we believe it is correct to have the program apply to wholesale motor vehicle fuels that are delivered for use into a TCI jurisdiction or removed from storage in a TCI jurisdiction. This scope tackles an important emissions sector in a way that is efficient, targeted, and defined. It is appropriate to tackle the transportation sector independently. The electricity sector is already covered by RGGI and a suite of complementary policies, and the building heating sector, which does need to be addressed more affirmatively, will need a different set of complementary policies than the transportation sector. Further, the alternatives for the transportation sector are commercially available and ready to be phased in over time.

-- The emissions reporting, monitoring, and verification components of the framework also make sense; it is important to include these design elements early in the process.

-- Inclusion of a gradually declining cap is critical to the success of the program. It sends a clear market signal that can stimulate private investment in research, development, and deployment, which will lead to lower costs.

-- Finally, the reinvestment of proceeds is an absolutely critical component of this framework. Proceeds should be reinvested by states into transit and vehicle electrification. The importance of a long-term and enduring dedicated funding source for these initiatives cannot be overstated. It has been crucial to the success and progress on the electricity side in New York and elsewhere, and it needs to be created and maintained for the transportation sector as well.

Thank you for the opportunity to submit these comments in support of the Transportation Climate Initiative Framework for a Draft Regional Policy Proposal. We look forward to TCI continuing to request and reflect public comments as this regional policy evolves.

Respectfully submitted,
Anne Reynolds, Alliance for Clean Energy New York
Matt Stanberry, Advanced Energy Economy Institute

The New York State Association of Metropolitan Planning Organizations (NYSAMPO) is a consortium of the Executive Directors of fourteen Metropolitan Planning Organizations (MPOs) in New York State who work together toward best practices and common goals. The Directors lead a diverse group of organizations that represent very large, urban regions like the New York City metropolitan area as well as small metropolitan regions such as Ithaca and Elmira. Regardless of size and complexity, the Directors understand the value of working together to help their organizations provide high quality transportation planning support to their member agencies and to the public throughout the State.
The NYSAMPO Directors have determined that the overall goals of the Transportation & Climate Initiative’s (TCI) low carbon transportation policy proposal are consistent with the strategic goals and planning programs of the NYSAMPO MPOs, as represented in their long-range regional transportation plans and the projects, programs and studies that are funded through their planning processes. The NYSAMPO Directors applaud New York State for its leadership in the effort to establish the TCI. NYSAMPO MPO staff has attended and participated in listening sessions throughout New York State and the Directors appreciate the opportunity to offer the following comment on the design of the proposed program.
Equity
As organizations which plan for the use of transportation funding authorized by Congress, MPOs must comply with Title VI of the Civil Rights Act of 1964 which prohibits discrimination based upon race, color, and national origin. The NYSAMPO MPOs are committed to ensuring traditionally underserved and underrepresented communities receive a fair share of the regional transportation system’s benefits and are not subject to undue burdens. MPOs maintain information and data related to the locations of protected populations within each metropolitan area in order to comply with Title VI and the Executive Order on Environmental Justice. MPOs consider transportation barriers and needs within these communities. The TCI’s community outreach and project planning related to the investment of cap-and-invest proceeds should be coordinated with the NYSAMPO MPOs to ensure consistency with their equity efforts related to Title VI.
Mobile Source Emissions
Reducing emissions from transportation is a common strategic theme in the NYSAMPO MPOs’ regional transportation plans. Additionally, several of the NYSAMPO MPOs must comply with requirements under the Clean Air Act Amendments of 1990 as they develop their plans and programs. More recently, federal transportation legislation establishes performance measures for on-road mobile source emissions, which require that emission reduction targets be established for the ozone precursors nitrogen oxides (NOX) and volatile organic compounds (VOC). Targets are also required for carbon monoxide (CO) and particulate matter (PM10 and PM2.5).

Table 1. NYS On-Road Mobile Source Emissions Targets
Target Year VOC (KG) CO (KG) NOX (KG) PM10 (KG) PM10 (KG)
2020 22,979 437,781 58,591 9,312 3,920
2022 42,765 839,633 107,713 18,132 7,482

Proposed caps to emissions from gasoline, on-road diesel fuel, and potential biofuels, should meet or exceed these agreed upon targets to help states New York State meet its goals.
Investment of Proceeds
Transportation improvements proposed through the TCI should be coordinated with the NYSAMPO MPOs to achieve emission reductions and other policy goals within the long-range regional transportation plans. This coordination will maximize the efficiency and leverage investment in the transportation system which will ensure greater benefits to users. It is important that revenues generated by the initiative be used to advance active transportation, public transit, cleaner vehicles, and other activities that have large-scale positive impacts on environmental quality and public health through the reduction of GHG emissions. The NYSAMPO MPOs regularly use analytical and policy tools that assist in the prioritization of transportation projects for federal funding which could be modeled for determining how cap-and-invest proceeds are invested.


Complementary Policies
Coordination with the NYSAMPO MPOs will support the goals of the low carbon transportation system framework as each organization works within metropolitan areas of New York State to develop and implement complementary policies in long-range regional transportation plans. MPOs can supplement the work of TCI by assisting municipalities within the metropolitan areas with coordinating infrastructure planning and land use planning that supports reducing emissions. For more information on NYSAMPO please visit our website at https://www.nysmpos.org/ or contact Michael Franchini at (518)458-2161 with any questions. We look forward to working with TCI and NYS in planning for a low carbon future.

The New York Public Transit Association (NYPTA), which represents more than 100 transit systems throughout New York State, supports the goals of the TCI effort. The development of a cap and invest program is both consistent with the environmental and energy objectives of public transportation and is a way to increase funding for public transportation to transition to low emission transit vehicles and to expand transit service.

NYPTA offers the following comments on the TCI draft MOU:
• NYPTA supports the goals and objectives of the TCI cap and invest program proposal.
• NYPTA supports the intent to invest program proceeds in low carbon and clean mobility options in urban, suburban and rural communities, and specifically in public transportation.
• Greater investment to modernize and enhance public transportation throughout New York State supports the goals of the TCI program, particularly greater investment to support the transition to cleaner public transportation infrastructure and to increase public transportation services.
• In developing the program, TCI should consider the impact on transit systems in small communities and rural areas, which have fewer resources and where the transition to clean fuel vehicles may take much longer. The increased cost of diesel fuel and gasoline to transit systems in these areas that will result from the cap and invest program will be burdensome and could negatively impact the continuation of these essential transit services to customers who need them most. An exemption (or credit) from any increase in fuel prices for public transportation services resulting from a carbon cap should be considered in designing the program in order to mitigate any negative financial impacts.
• NYPTA strongly supports returning the proceeds generated from the cap and invest program to the state where they are generated or earned.

Thank you for the opportunity to comment on the draft MOU.

The Sierra Club is sharing the attached 1,463 comments from our members and supporters in New York supporting finalizing the Draft Memorandum of Understanding (MOU) of the Transportation and Climate Initiative (TCI). Thank you for helping to design a regional policy to limit climate pollution from motor fuels and invest in a modern, clean, transportation future. The evidence is clear: the more we limit pollution from motor fuels, the more jobs are created, the more the economy grows, and the more lives we save. Please sign on to the agreement to implement a strong, equitable regional climate protection policy through TCI. Invest in the communities that have suffered the most from burning gasoline and have the least access to clean transportation options. Stop sending our hard-earned dollars out of the state to oil companies, and choose to create jobs, grow the economy, and save lives for families and businesses. Thank you.

“…design a regional low-carbon transportation policy proposal that would cap and reduce carbon emissions from the combustion of transportation fuels through a cap-and-invest program or other pricing mechanism… [and]… to complete the policy development process within one year, after which each jurisdiction will decide whether to adopt and implement the policy.”

The science of climate change is real. Scientists agree, and it's bad. After procrastinating for decades we have a short period of time to start turning off the greenhouse gas faucet. We can leverage market forces to start reducing transportation emissions through TCI.

I request that the Commonwealth of Vermont. take our common climate wealth seriously and formally join the TCI to reduce emissions. I further ask that the policy prioritizes clean investments in areas overburdened by pollution and is financially affordable for poor families and individuals as possible.

Thank you.

1/24/2020