TCI Regional Policy Design Stakeholder Submissions

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.

It is critical to look at, and act on the Climate Emergency from a holistic perspective. Transportation is an important sector to address, so is access to the local food system. Food Hubs are one solution to address food and transportation together. Funding from TCI could help support the creation of food hubs based on population density, demographics and relationship to food producing areas. Food Hubs that are decentralized but well planned shorten distance of travel from production of food to consumer, thus reducing miles traveled and fuel used. Hubs become spaces for building relationships, strong communities and encourage business enterprise development (i.e. value added products, or incubator accelerators). Hubs could be placed near population centers, thus addressing issues of food access and social equity. Food Hubs that prioritize regenerative, organic and soil building agriculture businesses can help accelerate soil as a carbon sequestering, or carbon drawdown opportunity. Food Hubs are a good investment for both reducing carbon use, capturing carbon, and supporting business development and community health and well being.

Please do not raise taxes. Massachusetts residents are overburdened with high taxes and a generally high cost of living. Additional tax burdens will harm individuals financially. I ask you, in the name of decency, please do not burden us with additional taxes.

The Transportation and Climate Initiative
The Transportation and Climate Initiative (TCI) is a 12- state regional effort to impose a stealthy and steadily increasing carbon tax on gasoline without requiring the politically perilous step of calling it either a carbon tax or a gas tax. The proceeds would be used to subsidize electric cars, increase public support for climate change policies favored by Governor Mills, the Natural Resources Council of Maine, the environmental left and other assorted climate alarmists. In Maine, in addition to protecting Democrats from risky electoral consequences, TCI is also constitutionally suspect. Article IX, Section 19 of the Maine Constitution restricts the use of fuel taxes to highway and bridge construction and associated costs:
Article IX, Section 19. Limitation on expenditure of motor vehicle and motor vehicle fuel revenues. All revenues derived from fees, excises and license taxes relating to registration, operation and use of vehicles on public highways, and to fuels used for propulsion of such vehicles shall be expended solely for cost of administration, statutory refunds and adjustments, payment of debts and liabilities incurred in construction and reconstruction of highways and bridges, the cost of construction,reconstruction, maintenance and repair of public highways and bridges under the direction and supervision of a state department having jurisdiction over such highways and bridges and expense for state enforcement of traffic laws and shall not be diverted for any purpose, provided that these limitations shall not apply to revenue from an excise tax on motor vehicles imposed in lieu of personal property tax.
The model for TCI is the Regional Greenhouse Gas Initiative (RGGI or “Reggie”). RGGI places a carbon tax on electric power generation and uses the proceeds to fund energy efficiency and promote climate alarmism. In Maine, RGGI revenues are directed to Efficiency Maine, governed by an independent board established by the environmental left under Gov. Baldacci. In addition to subsiding solar power, LED light bulbs and heat pumps, Efficiency Maine has consistently underwritten (as in bought advertising on) Maine Public Broadcasting and the Maine Housing Authority, both strong promoters of climate alarmism.
RGGI and TCI are multistate “agreements” which never received congressional approval as required under Article 1, section 10 of the US Constitution (the Compact Clause):
“No State shall, without the Consent of Congress, lay any Duty of Tonnage, keep Troops, or Ships of War in time of Peace, enter into any Agreement or Compact with another State, or with a foreign Power, or engage in War, unless actually invaded, or in such imminent Danger as will not admit of delay.” (My italics).
RGGI was never congressionally approved because Democrats did not ask and Republicans did not insist, and objectors like myself did not have standing to sue (although I did look into it). The environmental left insisted that RGGI was “voluntary” and did not require Congressional approval. Senators King and Collins, recognizing the potential problems with this approach, have introduced legislation approving regional climate change policy compacts like TCI, which at least opens the door to court challenges if Congressional approval does not pass.
In the meantime, bi-partisan objections to TCI and carbon/gas taxes are increasing, just as they did in France with the yellow vest protests. Governors from Connecticut (Ned Lamont-D), New Hampshire (Chris Sununu-R), Vermont (Phil Scott-R) and Rhode Island (Gina Raimundo-D) have expressed reservations/opposition (D). Governor Mills has been non-committal, although her climate alarmism would suggest support.
Interested Mainers can submit public comment on the design of the TCI by filling out the TCI Stakeholder Input Form, available at https://www.transportationandclimate.org/main-menu/tci-regional-policy-design-stakeholder-input-form. Public comments are due by February 28, 2020.

IT TOOK ME HAVING TO LOSE 3 JEEP VEHICLES TO FLOODS TO GET THE MESSAGE? TODAY DESPITE PROMISES FOR PUBLIC ALL-ELECTRIC VEHICLES I HAVE SEEN 2 GM VOLTS; FedEx. US POST OFFICE, UPS, EMTs, BUSES & TRUCKS ALL STILL DRIVE ON DIESEL? TODAY MARSHALL MADOFF DEVELOPED ZYCANE TO POWER "ALL" VEHICLES WHICH CUTS CO2 CONTAMINANTS @ 77% PER AN EPISODE ONDEMAND "60 MINUTES"?

Please be forward thinking and adopt measures now which will build a better future.
It is better to invest NOW, to bring us on to a path to a more sustainable future, than to have to pay an even bigger bill in the future to try and repair a past filled with inaction.

Please design a regional low-carbon transportation policy proposal that would cap and reduce carbon emissions from the combustion of transportation fuels through a cap-and-invest program or other pricing mechanism… [and]… to complete the policy development process within one year, after which each jurisdiction will decide whether to adopt and implement the policy. Thank You !

Obviously a huge problem and the solution will only come from government. Please act as quickly as possible.

The 44 undersigned members of Our Transportation Future and additional partners believe the Framework Policy Proposal offers an encouraging path forward for a modern, low-carbon, equitable transportation system.

Thank you for the opportunity to comment. Please see the attached recommendations on program design.