TCI Regional Policy Design Stakeholder Submissions

Just saw on the Boston herald that based on this program/plan, Governor of MA will increase the green tax. https://www.bostonherald.com/2019/11/01/green-gas-tax-bid-could-push-prices-close-to-5-a-gallon/

Also, can you make the form anonymous so that people who may not have an address or affiliation can submit their input/feedback? Equity is a big part of it and right now, this does not feel like it can reach those who are uncomfortable with such form or may not have an email.

On behalf of nearly 300 supporters in the TCI region, we submit the following petition with signatures attached.

Dear Decision makers:

We applaud your efforts to design a regional carbon pricing program for the transportation sector across the Northeast and Mid-Atlantic Region. There is no question, we must take steps to cut pollution from this sector and invest in solutions.

We must simultaneously take specific, measurable, and meaningful steps to ensure the communities hit first and worst by pollution, or who have inadequate access to mobility options, can fully participate and benefit from a clean, modern, reliable, and affordable transportation system.

This commitment should be expressed in any regional commitment (such as an MOU), and should not be left to individual states to determine whether or how they will address the needs of our most impacted communities.

Last summer, organizations representing racial, economic, transit, and environmental justice communities delivered a set of 9 principles for policy design to ensure the regional program builds in the guardrails that will ensure protections and guarantees for communities most impacted. Each of these equity principles, especially a clear process for ensuring communities are at the table, must be baked into the regional program, committed to by each state that plans to adopt the program, in order to ensure that some communities don’t get left behind.

I echo and support the voices of those who are directly impacted determining what they need to see as part of the program design. I urge you to commit to specific steps for each of the 9 principles for policy design in any regional MOU.

Thank you,
(Signatures attached)

Link to 9 principles for equitable policy design, previously submitted July 26th, 2019:
https://www.transportationandclimate.org/sites/default/files/webform/tci_2019_input_form/Regional%20Policy%20Design%20Principles%20for%20Equity.pdf

On behalf of the undersigned 357 scientists, researchers, health professionals and doctors from across the Northeast and Mid-Atlantic region, attached is a letter in support of a strong regional transportation policy that will reduce carbon emissions and equitably address dangerous local air pollution.

While generally supportive of the TCI framework, many of my reservations concerning equity and climate justice have already been expressed and received by you in the on-line and community meetings.

However, unspoken is the fact that the eventual burden of all 'cap and trade' or 'cap and invest' schemes is born by consumers who bear the cost through passed-through price increases, while those who have historically benefited greatly are the extractive industries themselves which have actively pursued policies deliberately designed to deny, deceive and distort the political process for decades concerning the cause and scope of global climate change. The cost of addressing climate change today is considerably more than it would be had we not been subjected to decades of delay perpetrated by the fossil fuel industry itself. Nothing in the TCI framework addresses this gross injustice. Nowhere in the TCI framework is there any mechanism for the extraction industries to bear or to share the "externalized" costs resulting from the sale and use of their products, or to provide compensation for the damage they have already done.

Thank you for the opportunity to comment on the TCI Framework for a Draft Regional Policy Proposal. The National Consumer Law Center (NCLC) is a non-profit organization that works for economic justice for low-income and other disadvantaged people in the U.S. through policy analysis and advocacy, publications, litigation, and training. NCLC submits these comments on behalf of our low-income clients. Our comments focus on equity issues, program design, and other elements that may directly affect low-income consumers. Please see attached comments, in PDF format.

I attended the Oct 24 Transportation Climate Initiative workshop at Massachusetts Maritime Academy. While I support transitioning automobile commuters to mass transit in order to reduce congestion and emissions, I am concerned about the effect of a drastically rising price of gasoline on working populations in our peripheral communities where people must commute to Boston for a living wage. TCI's mechanism -- raising the cost of gasoline for distributors and transferring the proceeds of fees on distributors to local communities -- will not prepare mass transit infrastructure for when it is needed, when automobile commuting suddenly becomes uneconomic due to the engineered price rise. For this, the State must invest in alternative mass transit now, before gasoline prices are artificially raised. Local communities cannot wisely invest in regional mass transit alternatives because it is above their level of operation: only the State can do this. The price rise in automobile commuting will disproportionately hurt lower income earners, for whom commuting costs are a higher ratio of earned income. This would not be a problem if reasonably priced mass transit alternatives existed. However, commuters in areas not served by MBTA commuter rail may not claim private express bus expenses on their Massachusetts income tax as a commuting expense. MBTA does not grant these private express bus commuters a free transfer to the Boston subway and bus system, as it grants to its own MBTA commuter rail commuters. Yet private express bus service is the only transportation alternative available to many suburban commuters who will be forced out of their automobiles by a TCI-engineered rise in gasoline prices.
TCI's mechanism must be analyzed economically by an objective, outside oversight body. While computer modelling is a useful and fun intellectual exercise, it does not replace serious economic analysis by professionals. Without serious preparation, policy changes and pre-investment in regional mass transit, TCI will devastate the working people of peripheral bedroom communities, reduce demand for our housing stock and force more marginal earners into metropolitan Boston, where high urban rents will further squeeze those on marginal incomes. I ask the Legislature to step in and exercise oversight over TCI.

Thank you for accepting my personal views, which do not represent the views of any official body. I am copying my response and sharing it with my State legislator.

Thank you for your leadership in this crucial conversation to rethink our transportation system so it becomes sustainable, accessible, and equitable for all people. MassBike is Massachusetts' statewide bicycle advocacy organization, and we are encouraged by the potential that TCI brings to the development of much needed bicycle infrastructure on a regional scale.

Too often bicycle infrastructure is thought of as a side-note to greater roadway projects, many of which are only within municipal boundaries -- this is especially true in Massachusetts. However, by engaging TCI we will be able to expand the scale of how these projects are designed and implemented, which affords us the ability to bring safe, attractive, and convenient bicycle infrastructure to all people throughout the Commonwealth, and especially to marginalized communities which are largely left of bicycle infrastructure improvements. Considering that the bicycle is a truly sustainable form of transportation, we have the potential to dramatically impact our emissions and exponentially grow everyday bicycle riding, but only if we build modern, connected, and seamless bikeways.

MassBike encourages the TCI to be a tool for bicycling to be integrated with all modes, and we encourage you to not to separate bicycling funding from the greater conversations of transit, roadway & bridge redesign, and electric vehicle infrastructure. Transportation needs to be thought of with a multi-disciplinary approach, and the future of transportation will be in providing options so that people do not rely solely on one mode. A person will one day take the train and bus, on another day need to drive, and on another day choose to bicycle. Thus, bicycling needs to be part of every conversation, and the challenge will be to balance the development of as many sustainable and equitable modes of transportation as possible.

We need to plan for people to ride their bikes to transit hubs, to integrate electric vehicles and electric bicycle charging stations, to pursue the development of long-distance bikeways like the Mass Central Rail Trail and the East Coast Greenway, and more, in order to make everyday bicycling a feasible option for our citizenry.

We also encourage the TCI to promote safer modes of transportation, as part of "sustainability" will also be to develop modes that do not injure and kill people. Part of this conversation will be to utilize the framework of the Highway Safety Improvement Program (HSIP) and the Transportation Alternatives Program (TAP), but also to build on these programs to allocate greater support toward bicycling and walking safety improvements, and to recognize that by shifting transportation modes away from automobiles and toward active transportation we will promote sustainability and equity for more people. HSIP and TAP arguably provide the bare minimum of what is acceptable in highway funding toward safer bicycling and walking. The TCI should be a tool to do much better than these programs, and we should seek to make a true impact to develop connected infrastructure that incentivize people to get out of their automobiles and choose safe, sustainable, and active transportation.

As the conversation develops, we strongly encourage that the program works hard to make sure marginalized communities, environmental justice communities, and people typically note engaged in transportation funding conversations know about TCI and how they can participate in the program. Along these lines, MassBike would appreciate the opportunity to be a continued part of this conversation going forward, as we can engage our membership statewide to make a robust contribution to the program. We thank you for this opportunity to comment on the program as it is being conceived.

Sincerely,
Galen Mook
Executive Director
Massachusetts Bicycle Coalition (MassBike)
www.massbike.org

This is nothing but a tax on the poorest amongst us. This is not the way to fix climate change. Free market solutions are a day better long term solution that will not harm the population.