TCI Regional Policy Design Stakeholder Submissions

Outrageous! Since when is Massachusetts taxed without representation! We are so overburdened with taxes as is and this tax will hit the middle class the hardest. Where are our tax dollars spent? Not on transportation? Another train derailed today! Infrastructure? Nope. It's so old that I'm shocked that the lights come on when I flip the switch. Road maintenance. The potholes in Boston have yet to be fixed on our major highways since last winter. Encore is paying a large amount of taxes..where's it going? We "fined" them for an extra $35 million. Where is that money going? Who is running the show? State taxes originate in the House of Representatives. "Carbon fee"?? Who do you think you're kidding??????

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

I believe this is doomed to fail in reducing admissions, will disproportionately hurt low income citizens and is being advanced without appropriate legislative action in the various states it has been proposed in. I vehemently oppose this being enacted without legislative approval.

Taxing motorists in the name of the climate is ridiculous. In fact, the thought that paying more taxes to the Government will affect the weather in any way is ludicrous. Especially considering that these money grabs in the name of climate change are typically squandered away via big money contracts awarded to environmental companies to pay themselves to "make a difference". Keep your hands out of our pockets and let the working class continue to spend their hard earned money on what they deem important.

Our transportation system is stuck in the dark ages. Traffic congestion from millions of cars and trucks are polluting our lungs and planet more than ever before. But as we enter this new decade, we have an opportunity modernize how we get from point A to point B.

Dear Madam/Sir,

As a professor at Boston University who lives south of the city, I utilize the Commuter rail several times each week to get to work. In other instances, I travel to East Coast cities for conferences and presentations. I appreciate public transportation because it allows me to more efficiently work during travel, and it allows me to keep my personal and work carbon footprint smaller. I am deeply frustrated that there are not more options for public transportation on the East Coast. While I am grateful for what does exist, I think that the population density in the region warrants a massive expansion and updating of the current system. This would have the benefit of reducing harmful pollution in the area, especially for children and the elderly who have more vulnerable health. Because pollution is linked to mental health ills, it seems extremely important to address the pollution in the area given we are in a climate of mass shootings and and increase in public violence. In my opinion, not acting to improve our transportation system would an act of neglect of our citizens. On a personal level, I do not appreciate breathing in the harmful fumes released by the commuter trains. Electric trains would be a very welcome improvement.

Additionally, we are in the midst of a climate crisis!!! High speed electric trains powered by renewable energy would allow us to make an important step towards reducing our carbon emissions which is a goal of many cities and agencies in the area. Most of all, we must act with haste to ensure a livable future for all persons and species on the planet!

I fully support an effort to expand and update the public transportation in the East Coast region!!!

With hope for a speedy and positive result,

Dr. Tawnya D. Smith, PhD

As a health professional-trainee, and concerned resident, I am submitting this commenting support of an aggressive carbon reduction schedule in regards to designing a low-carbon transportation policy. There are a multitude of benefits from adopting such a schedule for the involved states, including but not limited to, public health benefits from reducing gas burning for children, the elderly, and those with lung conditions - all of whom are among my patients, in lieu of upward trending (rather than downward trending) usage in the last decade. Furthermore, this policy change will enable the further development of electric car infrastructure, which will keep this region economically strong and vibrant in the near future and beyond. Strong rules are necessary to change our direction, and along with many of my peers and community members, I am in favor of this region taking active steps to formulate regulations that take us into a low-carbon future as fast as possible.

I strongly support the Transportation Climate Initiative. The United States has the resources and technology to implement clean energy solutions on a massive scale. Therefore, the US should be setting an example of sustainable development--we should be a beacon of hope, proving that it is possible to make the change from fossil fuels to clean energy. Americans should not be suffering from lung disease and other health issues as a result of our dependence on fossil fuels when we very well have the resources and technology to improve our system.

Sadly, what we've seen from the current administration is a step in the wrong direction. Over 60 rollbacks on environmental regulations have been completed with more under attack each day. In 2017, the Trump administration began the formal process to withdraw from the Paris Climate Agreement, in which nearly every country on Earth was coming together to implement climate solutions across the globe.

Living in Boston, I am no stranger to the inefficient commuter lifestyle that so many are forced to participate in. In Massachusetts, 40% of greenhouse gas emissions are caused by the transportation sector. I hope to one day see Boston become a city where the public transportation is so easy, clean, and accessible that fossil-fuel burning cars are not as necessary. The Transportation Climate Initiative is a step in the right direction to reach this goal.