TCI Regional Policy Design Stakeholder Submissions

Transportation planning for the future should take into account environmental as well as societal considerations. Electric vehicles should begin to replace fossil fuel-reliant vehicles. Planning should take into consideration both local and regional commuting and travel characteristics.

New York City is able to function as a viable metropolis only with its expansive public transit system. I have lived here my entire life. It is especially concerning to see climate crisis events including tornadoes, earthquakes, and super storms all occurring in our area in the last 10 years. Believe me these events are new and must be addressed as warnings. We need viable energy sources to run New York City public transportation that will not add to our climate crisis. Replacing gas fueled buses with electric ones would be the first step.

I believe strongly in this initiative. It provides a means for enhancing infrastructure, streamlining regional transportation initiatives, and, most importantly, pushing for a low carbon future and fighting climate change.

The Regional Greenhouse Gas Initiative has been hugely successful and this plan builds on that model. If we are to achieve significant reductions in carbon emissions, transportation will need to fall under a similar framework to power generation. With the accelerating advent of electric cars and vehicles, the cap imposed by this initiative will be less costly than anticipated. Further there are substantial public health benefits to reducing traffic, removing diesel and gasoline based trucks, and having distribution centers be less polluting.

I want to submit my extremely vocal support for this initiative.

To Whom it May Concern,

I appreciate being given the chance to provide my own feedback to the TCI. My name is Will Cembalest and I am an environmental economics major at Middlebury College, spending this spring term assessing the environmental, social and economic dynamics of Vermont’s transportation systems. I am commenting on behalf of myself, and holding true to the best interests of the Addison County region. Vermont’s largest source of greenhouse gas emissions is the transportation sector, so this program can effectively catalyze positive change in Vermont, and across the northeast region.

I would like to draw attention to MOU section I.3, Offsets, which addresses the regulations on the entity compliance and flexibility. The language used to discuss this directive is too tolerant of the state fuel suppliers. Engaging in carbon offset programs allows the state fuel suppliers to generally maintain their status quo operations, and fund alternative projects which may not most effectively support burdening low-income communities. This carbon offset procedure must set forth very stringent regulations to best support the rural communities in Vermont.

Carbon offset programs are very effective where certain carbon-mitigating, progressive projects are unable to attract the capital input necessary; the revenues from the offsets can decrease the technological and financial risk associated with the project. However, in many cases, fuel suppliers will engage in carbon offsets because they can be cheaper than using their own internal funds to invest in cutting their in-house greenhouse gas emissions. The largest issue with this scheme is that the carbon offset project would have been “implemented anyway”, which was found in a study conducted in 2010 looking at the Specified Gas Emitters Regulation in Alberta, Canada. In this case, a project such as switching fuels from diesel to natural gas, or installing energy efficient commercial heaters when the dilapidated burners needed replacement anyway, qualified as a GHG offset. This did not shift their emissions from their business as usual scenario, and failed to uphold the overall goal of the regulation: forcing polluters to make innovative changes to decrease emissions from the business as usual case.
If the program proves successful in the short run, it should eliminate the availability to purchase carbon offsets as an alternative, and make it an additional expenditure which state fuel providers can engage in if they wish. Under the RGGI program, which has proven successful by decreasing power plant emissions by 90% relative to the rest of the U.S, Massachusetts, Rhode Island and New Hampshire have all disbanded the ability to purchase offsets, described on the RGGI website. This indicates their intentions to decrease the polluter’s agency in dodging internal emissions reduction investments. For the time being, the offset program can exist only if the revenues from the project financially assist the residents within the TCI regions in transitioning towards a green fuel economy. Nowhere in the MOU is it specifically stated what kind of emissions offset projects they wish to engage in, nor the direct intention to positively impact low-income citizens. There must be several criteria for the offset project, recommended by the National Resource Defense Council. First, the offset project should be verified before the implementation of the project, not after a group collects the proceeds. Then, the project must be enforceable, where a third-party ensures its execution. Lastly, the offset must be permanent, guaranteeing that the positive impacts from project persist into the future.
Since it is the citizens of the states who are bearing the consequences of increased gas prices under the TCI and face future burdens of climate change in these regions, the proceeds are needed to support them in the transition towards a greener fuel economy. This would include initiatives like electric vehicle charging stations or subsidies for purchasing electric vehicles. Nowhere is it mentioned that the offset projects will remain within the premises of the states.

If this offset program were to exist, they must truly limit the amount of carbon offsets the state fuel supplier is able to purchase over the lifespan of the program, and additionally, the proceeds must be allocated towards specifically assisting in electrifying the fuel economy.

Thank you for your consideration.

Sincerely,
Will Cembalest

It is critical to look at, and act on the Climate Emergency from a holistic perspective. Transportation is an important sector to address, so is access to the local food system. Food Hubs are one solution to address food and transportation together. Funding from TCI could help support the creation of food hubs based on population density, demographics and relationship to food producing areas. Food Hubs that are decentralized but well planned shorten distance of travel from production of food to consumer, thus reducing miles traveled and fuel used. Hubs become spaces for building relationships, strong communities and encourage business enterprise development (i.e. value added products, or incubator accelerators). Hubs could be placed near population centers, thus addressing issues of food access and social equity. Food Hubs that prioritize regenerative, organic and soil building agriculture businesses can help accelerate soil as a carbon sequestering, or carbon drawdown opportunity. Food Hubs are a good investment for both reducing carbon use, capturing carbon, and supporting business development and community health and well being.

I appreciate this effort and it’s bipartisan nature. I am concerned about climate change, but also concerned that any new policy to drive down emissions be carefully crafted. In Maine, emissions from transportation constitute our largest source of climate change causing pollution. We are largely a rural state, and many of our citizens are not well off. Yet a culture here has evolved where driving large heavy vehicles such as pickup trucks and SUVs is common practice. I believe one measure with potential is to incentivize the purchase of smaller and lighter vehicles without penalizing those who drive larger and heavier ones. If a carbon fee on fuels used for transportation is instituted, it will be important to avoid the kind of backlash we have seen in France. The fee must be large enough to cause a change in consumer habits, but should not be punitive to those who feel they must have a big vehicle. Consumer freedom of choice should prevail, but with attractive savings accruing to those who downsize. Some sort of break for low income people might be one way of achieving emissions reductions without causing a major backlash.

Initiatives like this would absolutely devistate a rural state like Maine. I'm a hybrid plug-in owner; I believe in conservation, but slamming through crippling taxes on a state that naturally already struggles to compete economically (I say naturally, but how much is from decades of willful disdain of economic realities?) is short sighted at best, if not just down right cruel. Please THINK about the repercussions of your actions, not just your long term pipe dreams (or nightmares as the case may be, despite that those have so consistently been proven to be not entirely well founded). Maine does not need this, and outside of insular bastions in the state, DOES NOT WANT IT.

This is a crucial step forward to halting carbon emissions....and we must move forward NOW.