TCI Regional Policy Design Stakeholder Submissions

I am impressed that this is a pi-partisan effort! We need to use clean, modern, transportation here in the densely-populated North East. I know that our greatest source of air pollution comes from transportation, so this is a practical way to reduce emissions in a large area with one grand effort! I hope New York State has formally joined the plan, and if not, that it will. And that the plan will particularly meet the needs of areas with a lot of pollution right now. I hate to think of the little children growing up in those areas, when this effort could provide at least part of the solution! We must reduce climate change, and this is one chance to start to do so in this area. Perhaps we can become a model for other areas if we do it well!

Hello:
We are writing to urge Maryland to join the regional transportation climate initiative and to further urge Maryland to commit to reducing its greenhouse gas emissions from the transportation sector by 60% over its 2006 emissions by 2030. This is the minimum Maryland must achieve in order to avert a climate disaster. A regional initiative is a sound way to move forward with achieving that objective and can be modeled after the useful Regional Greenhouse Gas Initiative.

As a Maryland resident, environmental policy professional, and father, I believe that Maryland should make a make a firm commitment to adopt a regional transportation policy that achieves a minimum 40 percent reduction in transportation sector climate pollution by 2030, to keep us on track to meet the climate goals updated by the General Assembly in 2016.
Investment and policy decisions should be made based on pollution reduction and equity goals, as well as robust engagement opportunities from the public‒particularly those most overburdened by transportation pollution and undeserved by our current transportation system.

I strongly support this initiative, and urge the working group to consider high-speed rail between Albany and NYC.

If we make sustainable transportation more accessible, more people are likely to take advantage of it.

CenterState CEO is an independent and forward thinking economic development strategist, business leadership organization and chamber of commerce dedicated to the success of its members and the prosperity of the region. CenterState CEO is headquartered in Syracuse, New York and has 2,000 members. You can see more information about us on our website: www.centerstateceo.com. We undertake programs in economic development/business development, economic inclusion, research, policy and planning, as well as innovation and entrepreneurial development to achieve our goals.

We are closely following the development of the Transportation and Climate Initiative (TCI). We have participated in the public information meetings sponsored by the New York State Department of Conservation on November 7, and the TCI webinar of December 17. We thank New York State and the TCI for making those opportunities possible and look forward to continuing to engage in the process as it moves forward.

We are well aware of the climate issues you are seeking to address with this program. We applaud the states for working together to address a problem on this scale, and recognize that the leadership being taken by the states together can have a significant impact on the problem. We urge you to keep the flow of communication open as we are concerned that the general public, and business community awareness of the TCI is not very great at this point. Ultimately the participating states will be asked to pass legislation to implement the TCI proposals, by that time it will be critical to have greater public understanding of what is being proposed and why it is being proposed. The TCI will increase the cost of doing business for New York State employers, it will be critical that you clearly articulate the benefit that will be generated by the actions you propose.

At this point we have more questions, and as an organization we have not taken any position on the TCI. We would ask you to consider several factors as you design this program.
Our employers frequently must compete for customers in national and international markets. We understand that your market model indicated a positive economic impact for the region as a whole. The region’s economic vulnerability is not really caused by whether some customers drive over a state line to buy a tank of gas in another state, but rather when a business in Central New York has to compete for a contract against a competitor in another part of the country whose fuel prices may be lower to produce and transport a product to market. These types of decisions can often be driven by fractions of a cent per unit differences between one plant and another.

The Central New York economy is very vulnerable to changes in transportation costs. We are heavily dependent on trucking to move our products to market. We do not have competitive rail service that major rail centers possess, we are largely the captive of a single railroad. This is not an uncommon situation for middle sized cities in the TCI region. If a CNY business is seeking to sell products to international market, it actually costs more to move goods 300 miles from Syracuse to the Port of New York/New Jersey by truck than it then costs to move that same product from the Port of New York/New Jersey to an international market (such as China) by ship. Therefore, we are very sensitive to increases in fuel prices. If you do follow the “cap and invest” strategy, then some of that investment should be dedicated to alternative modes of transportation in order to avoid significant adverse consequences to a region like ours. Central New York produces a significant amount of agricultural products, lumber, paperboard, and consumer products that are relatively low priced goods that will be very sensitive to an increase in the cost of transportation. To the degree that there would be a shift from truck to rail as a means of goods movement, there should also be a reduction in greenhouse gas emissions, as rail is a much more environmentally efficient way to move products.

It seems that the results from your economic model indicate that the rise in impact on CO2 emissions was generating diminishing returns as you raised the price; i.e. a 5 cent per gallon increase led to a 20% reduction in CO2 emissions, raising that to 9 cents per gallon only generated a 22% reduction and a 17 cent per gallon decrease only generated a 25% reduction. It appears most of the cap and invest strategy’s return came from the initial increase in fuel price, and it is possible that the marginal increase in additional CO2 reduction would not be worth the potential economic damage of continuing to raise the price.

Part of that diminishment of return may be linked to the nature of the opportunities in which the TCI invests. At the public meeting many of the advocates were recommending projects that while they may be meritorious in their own right might not be particularly effective at the scale of the problem that you are trying to solve. Adding a rural bus route to help a hand full of customers get to a center city is not likely to contribute much to the major CO2 reductions you are seeking to achieve. The investment projects need to be about systemic change and you need projects that will change human behavior. We would recommend that you identify large and bold initiatives that can make a difference such as building out electric car infrastructure across the states, investing in the electrification of transit, upgrading electric generation and transmission to make sure that the utility systems can actually serve the increase desired in the sales of electric vehicles, or investing in infrastructure such as inland ports that will move significant amount of freight movements from truck to rail.

The TCI will have to work with the region’s utility providers to assure that they have the capability to deliver the clean electric power that the TCI needs to reduce carbon emissions. For example, in New York State, Upstate New York already has a significant base of non-fossil fueled power sources including wind, hydro, and nuclear. Seventy percent of our power comes from those sources. Downstate, the supply is closer to 70% from fossil fuels, and only 30% from non-fossil fueled sources. A wise investment, while not necessarily a transportation one, would be to increase the capacity of the New York State electric grid to move non-fossil fuel

dependent electricity from Upstate to downstate, or to convert or replace the fossil fuel plants that supply New York City with clean power. There will also be a need to make sure that there is sufficient generation to support the widespread adoption of electric vehicles, and given the challenges in siting and permitting utility generation, this could be a problem that could undermine your efforts.

Another issue the TCI should address is to encourage states to change their transportation investment policies. For example, NYSDOT is currently close to a final decision on replacement of I-81 through Syracuse. This will represent a minimum of a $2.5 billion investment in highways around Syracuse. While this is a good investment, being done in an environmentally responsible manner, the investments that the TCI are proposing will pale in comparison to the amount of money which will have to be spent on roads and highways. You may need to convince member states, and the federal government, to reconsider their own transportation investment policies and put more emphasis on transit or non-highway investments. With the aging of the interstate system, many states will be in the position to consider whether they can turn their transportation investments to replace some of the demand for automobile transportation with other forms of moving people.

We appreciate your willingness to engage the business community on this important and complex issue. We look forward to be engaged in the process, and hope that we can make progress in addressing this problem.

Sincerely,



David A. Mankiewicz
Senior Vice President
CenterState CEO
115 West Fayette Street
Syracuse, New York, 13202
Phone: (315)-470-1942
Email: dmankiewicz@centerstateceo.com

We can cut poverty and pollution at the same time. We urge you to move forward with a regional program that prioritizes the needs of communities overburdened with pollution and underserved in mobility options.

We all should be doing everything possible to mitigate activities that contribute to climate change and the escalating climate crisis. The Transportation and Climate Initiative is a common sense, proven effective approach to this monumental problem that can make a real difference to the future health of our environment. There's no reason not to take this action unless all we care about is the profits of a handful of people.