TCI Regional Policy Design Stakeholder Submissions

No climate benefits will result from this tax. Any reduction in emissions will reduce future temperature increases by a minuscule amount. It's a regressive tax increase masquerading as a feel good measure.

The proposal outlines a program that will cap the sale of gasoline, tax it, and then require the revenue generated to be spent on new government programs and projects that will further reduce the sale of gasoline. Some of the projects envisioned have ramifications that have not been verified or well thought out. For instance, pushing consumers to electric vehicles has not been shown to lessen environmental impact due to the environmental costs of EV batteries and manufacture of new vehicles. Further, programs such as incentives to EV purchase often favor wealthier individuals while the new taxes on gasoline will disproportionate affect poor and rural communities.

The northeast compact has a greater impact on Maryland and Delaware than the other Northeast states. Geographically, Maryland and Delaware retailers will suffer the most because consumers may more easily choose to go elsewhere for fuel.

Although this proposal has been pitched as a consensus document, in fact, it is not. There have been only three work sessions and less than a handful of webinars to solicit public feedback and comment. The framework is not ready for adoption by the states as too many points have not been clarified and fleshed out. No one really knows the full detail of the proposal. More outreach and public input needs to happen to shift this to a consensus. At the present, the framework appears to be a predisposed outcome.

I reject this framework – and I urge that the participating Governors be required personally to attend and hold public hearings throughout their states. This proposal will not achieve its goals. California enacted a similar program recently, and, by most accounts, their gasoline costs have skyrocketed while the environmental impact has had no true measurable benefit.

Dear Madam/Sir,

As a professor at Boston University who lives south of the city, I utilize the Commuter rail several times each week to get to work. In other instances, I travel to East Coast cities for conferences and presentations. I appreciate public transportation because it allows me to more efficiently work during travel, and it allows me to keep my personal and work carbon footprint smaller. I am deeply frustrated that there are not more options for public transportation on the East Coast. While I am grateful for what does exist, I think that the population density in the region warrants a massive expansion and updating of the current system. This would have the benefit of reducing harmful pollution in the area, especially for children and the elderly who have more vulnerable health. Because pollution is linked to mental health ills, it seems extremely important to address the pollution in the area given we are in a climate of mass shootings and and increase in public violence. In my opinion, not acting to improve our transportation system would an act of neglect of our citizens. On a personal level, I do not appreciate breathing in the harmful fumes released by the commuter trains. Electric trains would be a very welcome improvement.

Additionally, we are in the midst of a climate crisis!!! High speed electric trains powered by renewable energy would allow us to make an important step towards reducing our carbon emissions which is a goal of many cities and agencies in the area. Most of all, we must act with haste to ensure a livable future for all persons and species on the planet!

I fully support an effort to expand and update the public transportation in the East Coast region!!!

With hope for a speedy and positive result,

Dr. Tawnya D. Smith, PhD

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

BP America is happy to provide the attached letter as our input to the TCI draft memorandum of understanding.