TCI Regional Policy Design Stakeholder Submissions

As a senior Conservation Biology major at Middlebury College, this semester I am taking a class that focuses on transportation in Vermont. Over my time in college, I have learned from an array of courses the dangers that vehicle pollution poses on human and non-human ecosystems. Fortunately for Vermonters, we have some of the best air quality in the country, with the American Lung Association ranking Burlington as one of the cleanest cities for year-round particle pollution.

Yet, we’ve all had a moment rolling down the window of a car, walking down the street in town, or just sitting peacefully outside, when we get a big mouthful of vehicle exhaust and think to ourselves, Ooh, that might not have been great for my lungs. And although we don’t always have these upsetting realizations each time a car goes by, every day we are exposed to some level of unavoidable air pollution. Tailpipe emissions, from passenger cars to 18-wheelers, send a variety of pollutants into the air that we all breath - nitrogen oxide, carbon monoxide, and particulate matter, to name a few.

Study after study shows that air pollution caused by motor vehicle exhaust has been directly linked to a variety of human health issues, including asthma, bronchitis, stunted lung development, and in more serious cases, premature death. Furthermore, this increased risk of health issues drags with it an increased medical bill for millions of Americans. With transportation responsible for emitting about 40% of Vermont’s GHGs and, as a result, impacting human health, it’s about time that the industry takes a look at what it is costing all of us, and takes action to change that for everyone.

In short, the Transportation and Climate Initiative (TCI) seems to be proposing two things, both of which could improve our air quality, and thus our health. The first is to decrease motor vehicle emissions, and the second is to change behavior and incentivizing a move toward low-carbon / electric vehicles. In the Draft Memorandum of Understanding (MOU), the TCI recognizes that “accelerating the transition to cleaner, more efficient transportation sector will improve public health… for all communities.” (p.3). This last piece is a necessary component of the TCI - that the “public” whose health will be improved is not solely the young, healthy, middle and upper class, but it is the low-income, disadvantaged, and disproportionately afflicted citizens as well.

Therefore, it is important to address where the TCI has room to improve. The Draft MOU resolves that Signatory Jurisdictions will be enabled to, “strategically invest in programs to help their residents transition to affordable, low-carbon transportation options that provide substantial public health benefits, reduce congestion, and increase economic and job opportunities.” The pursuit of a cap-and-invest program, rather than a cap-and-trade program, is promising (despite the quite blurry lines on buying offsets). However, the section that speaks to these investments, Appendix 3A, is upsettingly unclear. Wording such as, “invest the proceeds from the auction of allowances as determined appropriate by each Participating Jurisdiction to achieve TCI Program goals” and “to achieve CO2 emission reductions and other related TCI Program goals” (Appendix 3A), does not provide citizens much insight into what these investments might be. Citizens should be able to understand the investment process, as we are the ones electing the legislature that will then decide how the revenue from allowances will be invested.

In order to have a more robust TCI, it is necessary for the document to outline what investment options look like. As the TCI is pushing a movement towards electric vehicles, it must be responsible for supporting this movement. Therefore, investments should be made in infrastructure that provides charging stations to make the use of EVs feasible for Vermonters. Another solution is for the TCI jurisdiction to provide subsidies on electric vehicles in order to help and incentivize all citizens, particularly lower-income and disadvantaged community members, to transition to cleaner transportation alternatives.

The current TCI, however vague, does recognize the impact that it could have on improving public health of all Vermonters, yet it has much room to grow in defining a solution to get to that endpoint. What is important is that the TCI has the potential to be a step in the right direction towards stronger human and environmental health, as a future electric transportation sector would eliminate the tailpipe and GHG emissions that negatively impact our communities and the non-human entities that inhabit our ecosystems.


Sources:

Draft Memorandum of Understanding of the Transportation and Climate Initiative. (2019).

Brugge D, Durant JL, Rioux C. Near-highway pollutants in motor vehicle exhaust: a review of epidemiologic evidence of cardiac and pulmonary health risks. Environ Health 2007; 6: 23.

Gauderman WJ, Vora H, McConnell R, Berhane K, Gilliland F, Thomas D, Lurmann F, Avol E, Kunzli N, Jerrett M, Peters J. Effect of exposure to traffic on lung development from 10 to 18 years of age: a cohort study. Lancet 2007; 369: 571-577.

Meo, S. A., et al. Effect of motor vehicle pollution on lung function, fractional exhaled nitric oxide and cognitive function among school adolescents. European review for medical and pharmacological sciences 2019; 23: 8678-8686.

https://www.ucsusa.org/resources/vehicles-air-pollution-human-health

Governor Charlie Baker
Office of the Governor
24 Beacon Street Room 280
Boston, MA 02133


Dear Governor Baker:

The Massachusetts Campaign for a Clean Energy Future is a coalition of environmental, public health, labor, and civic organizations working to establish equitable carbon pricing policy for Massachusetts.

We support the potential of a well-structured regional Transportation Climate Initiative and want to ensure that the Commonwealth develops carbon reduction plans that are both effective and centered around equitable protections and investments. To that end, the organizations listed below, all of whom are members of Massachusetts Campaign for a Clean Energy Future, support the statement of principles developed and submitted by the Massachusetts TCI Table.

Please note that the nine organizations that are signatories to this letter represent thousands of engaged Massachusetts residents from Cape Cod to Western Massachusetts.
Environmental Ambition
We commend Governor Baker and members of the Baker-Polito administration for their regional leadership on TCI. As the participating jurisdictions work to develop a final Memorandum of Understanding (MOU), we encourage Massachusetts to provide continued leadership by encouraging other states to commit to TCI, to invest proceeds in clean transportation efforts, and to minimize negative impacts to low-income drivers while maximizing benefits to communities that lack affordable, reliable, and safe transportation.
The MA TCI Table asks the Baker-Polito administration to ensure that the TCI jurisdictions establish an emissions cap that aligns with Governor Baker’s recently announced commitment to net-zero emissions by 2050 and the Massachusetts Senate’s proposed requirement of a 50 percent emissions reduction by 2030.
Of the three cap levels analyzed by the TCI jurisdictions, the cap that most closely approaches that level of ambition is the cap that declines by 25 percent from 2022 to 2032; that cap level also delivers the greatest health, economic, and job-creation benefits. For those reasons, the undersigned support an emissions cap that declines by at least 25 percent from 2022 to 2032. We also recommend that the Administration conduct modeling of deeper reductions. The cap and other program design elements should be reviewed after the program’s first three years and every three years thereafter to ensure that the program is working as intended to reduce CO2 emissions and other harmful co-pollutants and is improved over time.
Investment of TCI Proceeds
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. This should include attention to good jobs standards.
The investment of TCI proceeds in Massachusetts should provide greater access to affordable, low-carbon transportation options throughout all geographic regions of the Commonwealth. Investments that benefit environmental justice communities, low-income populations, rural families, low-wage workers, and other populations that have been historically burdened by transportation pollution are necessary. The Commonwealth should prioritize these communities as they have faced disproportionate burdens from transportation pollution and unequal access to mobility options. TCI proceeds must minimize and mitigate cost impacts to low-income households and maximize expanded clean transportation benefits for low-income communities and other transit-dependent populations.
The Commonwealth’s share of proceeds from TCI allowance auctions should be managed transparently, with input from a stakeholder advisory council. Massachusetts should work directly with communities across the Commonwealth to identify investments that will deliver CO2 reductions, improved air quality, resilient infrastructure, and improved sustainable transportation options. TCI-funded investments should be highly visible through clear reporting of investments and investment impacts.
Complementary Policies
In addition to a cap-and-invest framework, complementary policies are needed to achieve the Commonwealth’s climate mandates, economic development, and public health goals. These should include policies such as reduced public transit fares, road pricing, zoning reform, public-private partnerships, improved governance and coordination of the MBTA, RTAs, human service transit, and other state and local agencies. Further, the undersigned agree with the Commission on the Future of Transportation that we need to phase out the sale of internal combustion engine vehicles by or before 2040, and that all MBTA and RTA bus purchases must be electric by 2030.
The following member organizations of the Massachusetts Campaign for a Clean Energy Future look forward to working with you to ensure that Massachusetts participates in an environmentally ambitious and equitable TCI.
Sincerely,
Acadia Center
Cape and Islands Self-Reliance
Clean Water Action
Climate Action Now Western Massachusetts
Elder Climate Action Massachusetts
Greater Boston Interfaith Organization Climate Justice Task Force
Healthlink
League of Women Voters-Massachusetts
Salem Alliance for the Environment

As detailed in the attached comments, the primary objective that TCI should strive to achieve is to reduce transportation emissions as much as possible (meaning a 25% reduction from the Reference Case, instead of a 20 or 22% reduction which are also under consideration). To accomplish this, TCI should aim for the adoption of as high a variable cost to driving and parking as feasible, enabled politically by converting fixed and hidden driving and parking costs to usage pricing, where total costs to most drivers will actually go down. Incentives applied at the level of the individual driver are critical to meeting TCI’s carbon reduction goal. A transportation re-pricing policy bundle is specified in the submission and then modeled. It was found to reduce year-2030 vehicle miles traveled and carbon emissions by 23.2%. Polling results on transportation re-pricing were also presented and it was found to be more acceptable to the public (including those in the Northeast) than hiking fuel taxes, even if fuel tax revenues are refunded through other tax rebates.

Please see the attached file for comments on the Draft MOU, and the modeling results webinar in December 2019. Thank you for the opportunity to provide feedback.

Attached are Toyota's comments regarding the TCI Draft MOU. Please let us know if you have any questions. Kind regards.