TCI Regional Policy Design Stakeholder Submissions

Reducing greenhouse gas emissions in order to address climate change is one of the most urgent tasks facing our governments and our communities. Emissions due to transportation are one of the largest contributors to overall emissions and therefore urgent to address. I strongly support the Transportation and Climate Initiative, along with other efforts to reduce carbon dioxide emissions regionally in the Northeast by adapting and improving our transportation infrastructure.

The Transportation and Climate Initiative (TCI) seeks input from stakeholders regarding specific considerations that ought to be factored into the Model Rule and starting level for a regional cap, compliance structure, and stability mechanisms. As a Master of Public Health student in the Environmental Health Department at Boston University School of Public Health, I offer my comments and recommendations based on my understanding of Environmental Health, Environmental Justice communities, and Environmental Policy.

The TCI aims to implement a program with four main objectives: reduce greenhouse gas emissions, improve air quality and public health, enhance transportation options, and alleviate the burden environmental justice communities bear in regards to poor air quality and limited mobility. TCI states that transportation contributes to 40% of GHG emissions in the Northeast and Mid-Atlantic region; the proposed MOU is therefore appropriate to address issue of GHG emissions from the transportation sector, not only in an attempt to mitigate climate change but also to improve public health by reducing harmful co-pollutants like SO2 and NOx and increasing mobility in congested, urbanized areas. (See attachment for references)

STABILITY MECHANISMS
TCI seeks input on which factors it should consider when designing stability mechanisms for managing uncertainties in future emissions and allowance prices. The rate of reduction in emissions is critical to ensuring the sustainability of revenue needed for investment. Successful reduction from the fuel sector, and consequently fewer allowances being purchased, may cause a decline in generated revenue. The Model Rule must control the rate of reductions in order to sustain reliable revenue from fuel suppliers to invest in clean transportation alternatives. A dynamic allowance structure would provide additional stability in response to uncertainty in future emissions.
The Memorandum of Understanding (MOU) provides strategies to respond to unpredictable changes in market costs and demand in section “G. Stability Mechanisms”.

Suppliers trying to maximize profits will purchase allowances, bringing in more revenue for alternative transportation initiatives. As alternative transportation options become available, consumer demand for fuel drops. To maintain pressure on suppliers to continue reducing emissions, the cap will continue to drop over time. However, if this drop occurs too quickly, suppliers will not be inclined to buy allowances and revenues will fall. In addition to the CCR and ECR mechanisms proposed, TCI should implement a minimum cost for allowances that increases annually. This dynamic floor cost would compensate for expected long-term trends in lower demand for fuel. It also de-incentivizes industries to buy allowances, thus reducing emissions further, yet still maintains a revenue margin that allows TCI to reach its objectives. The Climate Law and Policy Project make similar recommendations in their comment under the “Accelerating Reductions” section. (See attachment for reference)

Predicting market trends and consumer behavior requires accurate models. These models can be very good, but are seldom completely accurate. To ensure the success of a TCI program, the Signatory Jurisdiction should consider additional strategies to maintain a controlled reduction rate.

COMPLIANCE
TCI also seeks input on how the compliance period should be structured to provide needed flexibility, while ensuring environmental integrity. As discussed above, the time period for compliance is closely interconnected to market dynamics. I suggest that the period ought to be stringent enough so the emissions are enforced in a reasonable time frame, though not so stringent to compromise the economy and solvency of suppliers. Too stringent and narrow of a compliance period may accelerate reductions and lead to a rapid drop in demand, which could destabilize the revenue structure needed for TCI to be successful. Allowing for offsets and allowance purchase should be permitted, but limited. The role of allowances and offsets should be primarily to control the rate of reduction, and encourage reduction rates to reflect those of development and utilization of alternative transportation measures.

I support the implementation of TCI. The initiative has four equally important objectives, three of which exist independent of the politics surrounding climate change. TCI not only reduces GHG, but also improves air quality and public health, reduces congestion and improves mobility in urban areas, and rightfully address environmental pollution issues that disproportionately burden Environmental Justice communities. All jurisdictions should support and participate in the Transportation Climate Initiative to protect individuals’ rights to a clean environment, ensure effective transportation for all, and promote health that is not burdened by the consumption behaviors of the “haves” against the “have nots”.

Respectfully,
Emily Hammel
Jamaica Plain, MA 02130
MPH Student, Boston University School of Public Health

I strongly support the goals of TCI and the leadership the New England and East Coast states have assumed in energy efficiency and development and use of clean energy. If TCI is implemented, it will build on that leadership, helping to keep our regions' air clean and ensure the sustainability of our resources; it will also continue building the clean economy, thereby providing high-paying jobs throughout the region....Our country is at its best when we work together, building a coalition of people with like-minded goals from different places and different backgrounds; by reducing carbon emissions from the transportation sector—as is possible with TCI—we can help keep clean the air, forests, and waters that hunters and fishermen, boaters and waterskiers, snowmobilers and hikers, skiers and rock climbers depend upon for their outdoor enjoyment. This in turn will ensure that the tourist industry—which provides a significant number of jobs throughout our states—remains robust. Thus, for environmental reasons, for financial reasons, and for employment-related reasons, I fervently hope the 12 states currently participating in designing TCI will be able to finalize plans and move forward, fully implementing TCI, and that if some of the current TCI states decide to drop out, the remaining states will move forward on their own. Thank you.

February 27, 2020

Testimony to TCI by Mary Jo Maffei
Chair Carbon Pollution Fee and Rebate Group
TCI can be an important way to reduce emissions of transportation. I am glad there is an effort to do this through TCI. Whatever we do, though, has to be effective and based on science, has to be equitable and must require an honest assessment of the challenges ahead.
Integrity in the Process
The current proposals are described as cutting transportation emissions by between 20% and 25%. A quick look at supporting TCI documents shows that this analysis is based on a state’s business-as-usual transportation emissions that is expected to drop 19% over a decade. Thus, TCI will only contribute at most a 6% drop in emissions. In Massachusetts, where I live, transportation is 40% of emissions, so TCI will reduce total emissions by 2.4%. And these estimates are using the best or most rosy assumptions.
It is important that TCI be transparent and honest. In this era of misinformation and given the seriousness of the effects of climate change, we cannot afford to be less than honest with ourselves about the potential results of different efforts to address climate change.
Effectiveness
The TCI process must provide policy options that address science-based requirements for climate mitigation which limits global warming to 1.5C over pre-industrial levels. That will require emissions reductions around the globe and in Massachusetts on the order of 40% of current emissions levels per decade. The TCI process is only considering efforts to reduce transportation climate emissions by 1%, 3% or 6% over business-as-usual emissions reductions, over a decade. And we have no assurance at all that business-as-usual emissions reductions will be significant. I urge the TCI group to be more ambitious; we need to have much steeper emissions reductions if we are going to slow down the terrible effects of climate change.
Additionally, the Transportation Climate Initiative has assumed that this would be a cap program instead of a fee program. I believe this should be revisited. Fee programs are much less complicated than cap programs, much less expensive to run, more predictable, much easier to design for effectiveness, equity, and transparency. A market such as being proposed is also more likely to be open to fraud. I believe that a fee process is more honest and if this is coupled with payments to residents more acceptable.
Equity
The TCI process must assure that policy options that address transportation needs in each state are equitable for low-income communities, environmental justice communities and other disproportionately affected groups. Policies must address equity regarding access to public transportation, cost-effectiveness of public transportation, traffic congestion and its effects, the reduction of transportation climate emissions and related health impacts, impacts on access to new jobs, access to greener transportation options, and access to greener automobile technologies. TCI can’t leave these as decisions to be made on a state-by- state basis. TCI must include strong value statements about how equity will be created for low and moderate income residents and for vulnerable communities. Certainly direct investment in green infrastructure in low income communities is important. This money must be primarily used in projects that reduce CO2 pollution and only a small portion of it should be used for adaptation to climate change. I recommend at least 80% percent of the funds go to projects that reduce pollution. However, these projects will only help some low-income and middle income residents with a significant delay between when residents need to pay more for fossil fuel and when they receive benefits from these projects. The best way to protect low and moderate income individuals is to provide them with direct payments that for the vast majority of low income residents and for most moderate income residents are larger than their increase payments for fossil fuel.
We need to be honest about the magnitude of the problem, the effort needed to solve it and the impact that our policies are having. That TCI has created a consortium of states trying to act in concert to address climate emissions from transportation is laudable. Now you need to step up to the challenge and design effective and equitable policies to address it.
A regional carbon pollution program is an excellent idea, but for us to safeguard our children’s future it must be aggressive and happen rapidly. Thank you.
Mary Jo Maffei

We appreciate the need for each TCI jurisdiction to independently determine how to invest TCI proceeds to best meet the unique needs of their residents, workers, and businesses. However, we also believe that the draft MOU should include principles to ensure that investments deliver pollution reduction, improved air quality, increased sustainable transportation options in an equitable manner, and good jobs standards.

Having recently seen The Human Element, I am even more aware of the chemicals our atmosphere is infused with at our hands. Little kids are breathing through face masks made to look like elephant faces multiple times a day at home and in school to stay alive. They explain that it feels like drowning when their damaged lungs fail to deliver adequate oxygen due to the pollution from the convenience of using fossil fuels. Our definition of fossil fuel necessity has been smothered by the scientific data that shows how we are destroying our life support systems. Shame on us for complaining that we don't like an additional gas tax. Our first responsibility is to life. We have lost our way as we minimize its fragility and our necessary stewardship. All around us we see the consequences accrue and the death of species; plants, animals and loved ones. My concern is that this legislation is as vetted and as extreme in its effectiveness as is humanly possible. I believe the team assembled and the sponsors behind this initiative are taking their moral role as shapers of our children's futures seriously. I thank you. Sign. Enact. Better our futures.

I have attached joint comments on the Transportation and Climate Initiative Draft MOU from U.S. PIRG, Environment America, and their state affiliates in the Northeast/Mid-Atlantic region.

As all common sense people would do, they would balance their budgets and control their spending to ensure that they can maintain their homes, autos, children's education, etc. We the citizens expect the same from our elected officials. We did not consciously vote for Representatives to take it upon themselves to spend, spend, and spend. We elected our Representatives to work in our best interest. No candidate was voted into office with a carte blanche credit card. Our expectation is that our Representatives work diligently to reduce unnecessary costs and balance the state budget. The citizens of Massachusetts elected NOBODY to fall in line behind any Senate or House leaders. It was our intent to elect independent thinkers who ensured us that they have our backs. Continually raising taxes is not what was expected. If I want to buy a new house, or car, I reduce spending and save in order to do so! I expect the same from my Representatives.