TCI Regional Policy Design Stakeholder Submissions

Attached, please find a letter from the Metropolitan Area Planning Council regarding the proposed equity provisions for TCI.

Please see attached for a technical memo by Climate XChange that responds to the TCI state's first listed equity provision on the September 29th equity webinar. In particular, this memo focuses on what level of detail in the regional MOU, vs subsequent state model rules, can help ensure that percentage-based equity requirements for investment function as intended.

The two essential language provisions we outline are: 1) Ensure that proportionately higher revenue goes to overburdened and underserved communities that the percentage of the population that qualifies; and 2) require investment dollars be located within and directly benefit overburdened and underserved communities in order to count towards equity requirements.

The memo also proposes two additional measures to improve the program's ability to deliver on equitable investment: 1) Comprehensive state screening tools as the census tract level or smaller that bring together socioeconomic and environmental metrics; and 2) New capacity-building and ground-up governance structures to control TCI revenue.

CT STAKEHOLDER INPUT ON OCTOBER 1, 2019
FRAMEWORK FOR A DRAFT REGIONAL POLICY PROPOSAL

October 12, 2020

Dear Transportation Climate Initiative Regional Policy Workgroup,

Thank you for the opportunity to provide input on the “Framework for a Draft Regional Policy Proposal” released on October 1, 2019. I support a regional policy to reduce transportation pollution and believe robust and meaningful public input into both the regional and state decision-making on the Transportation and Climate Initiative (TCI) is necessary to ensure a just and equitable policy design for Connecticut. I offer feedback on the proposal’s sections below.

Our current transportation system in Connecticut and throughout the Northeast is inequitable, prioritizing car ownership and ridership over all other forms of transportation. This has, in turn, created pollution of many kinds and has resulted in transportation as the largest sector of greenhouse gas emissions.

Equity advisory committees
These committees are necessary to ensure accountability at all levels. It is essential that these committees have true decision-making power and include members from the relevant communities. To ensure participation from underserved and impacted communities, financial compensation for attending should be provided.

Dedicated investments for disproportionately impacted communities
At least 35% of investments, and ideally more than 50%, must be in disproportionately impacted communities to adequately address racial and economic justice issues. Antiracist discrimination, that is discriminating against people who are White in favor of Black and Latinx, is needed to make TCI an antiracist policy. More money must go to communities long left out of investment decisions to create equity. The Center for Latino Progress’s 2019 survey on TCI further indicates high support (82%) for prioritization of equity and environmental justice in investments, with 67% also supporting a dedicated percentage of investments going to address disproportionately impacted communities.

Air quality monitoring as complementary policy
Air quality monitoring is a necessary first step, but is the bare minimum needed. California’s model is a precedent for Connecticut, setting air quality improvement targets and strategies in individual communities and, through grants, empowers community organizations to facilitate this process. Because air quality is often worst in low-income communities and those with high percentages of Black and Latinx residents, the MOU should commit to lowering pollution in these communities.

Workforce training and employment
Creating good jobs in environmentally beneficial sectors is one of the most promising aspects of TCI. It is essential that strong labor standards are upheld and that job preference is given to those in environmental justice communities. Especially in this current age of COVID, well-paying and stable jobs are in short supply; TCI opens opportunities for high-quality jobs. TCI can and should also encourage apprenticeship and training programs.


Sincerely,

Jennifer G. Kleindienst
241 West St.
Middletown, CT 06457

Partnership for the Public Good (PPG) is a community-based think tank that provides research and advocacy support to over 300 partners in Buffalo, NY. Each year, we hear from our partners that lack of investment in public transit is a major concern for them and the clients they serve. Our public transit system varies in quality depending on where you live in our city, and often the poorest, most vulnerable residents in our city, those who rely on public transit the most, are the same residents who have the least access to public transportation. We need a significant source of additional income for our public transit system, and this is especially true given the climate crisis and the need to reduce vehicle miles traveled. The revenue generated from this cap and invest program would be the perfect source for public transit funding.

Funding our public transit system will make our city more equitable by making jobs, healthcare visits, and other necessary trips more accessible to all in our city, especially for the most economically vulnerable. It will also constitute major strides toward a more environmentally just city as we mitigate the effects of climate change by reducing GHG emissions and invest in communities that have historically faced (and continue to face) environmental racism. Further, this investment is especially critical in this period of COVID-19 as our public transportation system faces extreme financial uncertainty and will likely have to cut service. This is unacceptable for our city, but especially for our most vulnerable populations.

Please take action on this cap and invest program immediately, and funnel the revenues from the program into our public transportation systems with an emphasis on serving those who have been disproportionately impacted by transportation-generated pollution and other systemic inequities.

Here is PPG's report on Race, Employment and Public Transportation in Erie County: https://ppgbuffalo.org/files/documents/working_toward_equalityfinal.pdf

Comments on Program Design as Outlined on Sept. 16 and 29, 2020 TCI Webinars – Modeled 2032 Max Mileage Reductions from Reference Case of Only 2.0% is a Program Failure