TCI Regional Policy Design Stakeholder Submissions

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.

I want more Transit Oriented Development (TOD) in our major cities. In my area of Baltimore, existing public transportation is poorly accessible. For example, many Light Rail stops in Baltimore County are surrounded by parking lots, which means many of the commuters drive there and then take the train into the city. As for the reserve side of it, many low-income residents from the city who work in the County, take Light Rail and then have to walk up to a mile (sometimes more) to their employer - mostly retail work in shopping centers or industrial yards. I have been told that there are too many Light Rail stops unlike other major cities; therefore, a mass transit line would be the most efficient option. Sometimes it is easier to get from Hunt Valley to Linthicum by car than riding the Light Rail. It also bypasses Towson - a major employer.

MARC train service to DC is limited to rush hour and again, it is heavily car dependent. Baltimore County residents who work in DC have to drive on MD-43 and MD-150 to get to Martins State Airport MARC station. There is no mixed-use or TOD around there. I firmly believe the Hawthorne neighborhood could be transformed and redeveloped to serve such purpose. There could also be station infill in the Eastpoint neighborhood of Dundalk and McElderberry Park in the City. Baltimore's buses are overcrowded. Commutes that would take 30 minutes on DC’s Metro system, take 2 hours by bus. Many of the bus stops are not disability accessible and are located on roads without sidewalks. Communities have little put, as the state operates the transit system and not a regional authority. While I recognize that mass train lines are expensive, there is a stepping stone of Bus Rapid Transit (BRT). This is under construction in Montgomery County to connect the Briggs Chaney Park & Ride to Downtown Silver Spring. If successfully, it could mean future construction of a planned Metro Brown Line.

Major cities need to rethink their zoning and urban planning laws. Cities like San Diego are reducing the minimum parking requirements, which in return is spurring urban infill and multifamily housing - both rentals and condos. Some cities are taking the extra step of eliminating vehicle dependent establishments to stop pollution and return the streets to pedestrians. For example, Minneapolis in August passed a law banning the development of new drive-thru banks and fast food establishments. In October, New York City banned car travel on 14th Street and allowed for BRT. It would be nice to see more walkable major cities, like our European counterparts. I want to make sure city planners are properly educated on the consequences of stormwater runoff and its impacts. Many existing communities are seeing properties destroyed by flooding and in extreme cases, uninhabitable. Notably, Ellicott City in Howard County, Frederick Ave in Southeast Baltimore, and Wiltondale in Baltimore County. Native plants provide excellent stormwater reduction and our wetlands mitigate carbon emissions. We need to strongly value these ecosystem services. I also believe we are doing a poor job of explaining that lawns are impervious surface, which is not reducing stormwater runoff, and should stop being considered as an environmental easement.

I respect many communities have architectural and historic significances. I am sure certain houses on an ad hoc basis have critical local historic significances; however, city planners and community members need to acknowledge that once affordable houses are no longer affordable. Certain lands can be converted into public spaces will respecting the local history. The Blair family property in Silver Spring being converted to a park is a prime example. Family dynamics have changed, purposes of residential spaces have changed (e.g. cutting the lawn), and the need for disability accessible space. Single family housing zoning laws are displacing low-income residents by pushing them further from employment areas as these houses have skyrocketing rises in value. Low-income residents are burdened with psychological stresses of traffic; unable to be prompt for school and/or work resulting in poor academic performance and losing jobs, respectively; providing income for car payments and auto insurance; and maintaining code enforcement rules by purchasing and maintaining a lawn mower. All contribute to rising carbon emissions. Cities should look to DC’s inclusionary zoning laws that create an opportunity zone around the new Streetcar Line and prevents displacement of low-income individuals and families.

Furthermore, I believe cities need to be better connected with bullet trains as an alternative to air travel which produces a lot of carbon emissions. There is no excuse as to why I cannot travel from DC to Boston - and all the cities within the Northeast Megalopolis – in a timely manner and inexpensively. I do not want any city in our region to make the same mistakes like the state of California that is price gouging the construction expenses of the bullet train and affordable housing in Los Angeles from unnecessary and unethical consulting fees and contracting on behalf of the taxpayers.

I am deeply and gravely concerned over this petition. By limiting the amount people will drive you are affecting an entire industry and workforce on the available cars to work on after the industry has already sustained raising workforce costs. We as an industry cannot sustain being attacked on both angles by our own government who is supposed to help foster small business instead of kill it. I voted for a Republican Governor in my state to help protect me from these issues.

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

The world is facing a climate emergency. TCI has the potential to have a very large and beneficial impact in reducing GHG emissions from a highly populated region of the US. The Cap and Invest model is a proven and effective model to achieve these reductions but only if it’s done right. The cap must be set at a level that creates financial incentives to reduce emissions. In simple terms it means the price of carbon should be high. This will translate to higher fuel costs and incentivize use of lower carbon fuels. If the cost of carbon is high TCI will generate substantial funds to invest in GHG reductions. That basic framework is well thought out and sound.

However, TCI is based on the model of RGGI. A historical look at RGGI shows that it has not been nearly ambitious enough. RGGI has accomplished a lot but could have accomplished much more. The targets of TCI should be ambitious. The cap should be set aggressively low. As the US is pulling out of the Paris climate accord it is up to subnational jurisdictions like the TCI states to create policies that will lead to the emissions reductions we need to avoid the worst impacts of climate change. California has been aggressive about this for more than 10 years. New York recently passed S.6599 which has aggressive climate targets. Other TCI states should follow suit to be at least as aggressive.

My firm helps dairy farms with methane digesters generate revenue by selling environmental commodities like carbon offsets, RINs and LCFS credits. Over the past several years the price of carbon in California’s Low Carbon Fuel Standard (LCFS) has been ~$190/mtCO2e. Dairy digester projects that are connected to common carrier pipelines around the US can sell renewable natural gas into California’s LCFS market. This market provides substantial incentives to digester projects and many are being built to access this market. These projects provide a very low carbon fuel. By avoiding methane emissions that would otherwise be released to the atmosphere and turning that methane into RNG the projects create substantial climate benefits and can have co-benefits that help dairy farms improve water quality and nutrient utilization. In addition, RNG can be used in heavy duty vehicle fleets (trucks, buses, etc) for which electrification is not as viable as it is for passenger cars. TCI should provide incentives for methane digesters to produce renewable low carbon fuels in the TCI states.

At a recent TCI workshop state staff leading the TCI process said that they were considering biofuels but that they have limited resources, and developing TCI at all is “a very heavy lift”. TCI states should commit more employees to development of TCI. This is a prudent investment in the long term health and viability of the people and ecosystems of TCI states. State staff should not be stretched so thin that they cannot devote the time required to thoroughly develop such a necessary program. Of course the vast majority of TCI auction revenues should go to investments in the states, but states will also need staff to manage and implement the program. Speaking from 10+ years in carbon markets we encourage TCI states to make sure that their programs are well staffed with enough highly trained people. This is crucial to having the markets function well to achieve their goals.

Biomethane (aka RNG produced from methane digesters) is a unique form of biofuel. Unlike most ethanol and some forms of biodiesel it is produced from a waste and it’s production does not lead to land use change or impacts to the food supply. Biomethane is produced by dairy, swine and poultry farms of which there are many in TCI states. These segments of the livestock agriculture industry have a major impact on the rural communities (human and environmental) in TCI states. TCI’s model rule should provide specific incentives for production of biomethane from livestock manure. This would help achieve the necessary GHG reductions while supporting a growing industry in TCI states that provides economic benefits to the people and ecosystem service benefits to the environment in the TCI region.

NY S.6599 is an ambitious cap and trade program that will exclude “biofuels” but include livestock anaerobic digestion projects. Since TCI states are home to many dairy and other types of livestock farms they can support their communities and achieve GHG reductions by providing specific incentives for production of biomethane.

TCI can draw on the model of the US EPA Renewable Fuel Standard (RFS) or the California Low Carbon Fuel Standard to develop mechanisms to incentivize production of biomethane from livestock manure digesters. EPA and the California Air Resources Board (CARB) have worked through many of the complications of providing incentives for low carbon fuels including the life cycle accounting that is the global standard for GHG accounting of fuels. TCI doesn’t need to reinvent the wheel on these subjects. In addition, using “standard EPA emissions factors” to assess the impact of different fuels doesn’t sounds like it would allow individual producers to benefit from innovations in reducing emissions. The RFS has multiple “buckets” of RIN credits which allow the producers of the lowest carbon fuels to benefit in the market. CARB’s LCFS has simplified Tier 1 fuel pathways for efficiency, but also allows producers to apply for a Tier 2 pathway when they think their production process provides additional GHG benefits. Both models could be adopted by TCI.

Climate change is a pressing issue, and it makes sense for Maine to work with neighboring states through TCI’s bipartisan, proven policy model, to address contributing transportation factors in our region. The plan that states are developing can reduce pollution, expand public transportation, encourage use of electric cars, trucks and buses, and develop safe ways for people to walk and bike in small towns and rural areas through a clean transportation fund. We know this approach works because over the past 10 years, Northeastern states have done the same thing with the electric sector through RGGI. We created jobs, grew our economy, and reduced our pollution. Now, we have the same opportunity with TCI. The Maine Public Health Association supports this effort because Maine people deserve safe, clean, equitable, modern transportation solutions that are affordable, reliable, and reduce air pollution.

It's important that the policies we enact on climate change make sure that the big polluters pay the most money, and we need to ensure that we do everything we can to make sure that the people living in more rural areas (I know there are many in Vermont) are not dealt a horrendous blow in terms of rising costs they can't handle. Finally, we need to make sure that when we institute a cap that it's done to keep us on track to address climate change.

My two major concerns are Lake Champlain and other bodies of water, and air quality - particularly in Burlington.

The degradation of Lake Champlain due to road runoff, sewage spill, algae and farming practices, as well as Vermont's
lakes and rivers, is deeply concerning.

The concentration on roads and parking lots at the expense of solutions such as light rail and rail connecting Vermont is repeating
the past and compounding present problems.