TCI Regional Policy Design Stakeholder Submissions

Dear TCI Team,

Our Climate is so grateful for your hard work to expand regional carbon pricing to a new sector of the economy and to do so in an inclusive, collaborative, bipartisan manner. On the whole, we stand by the comments submitted by the larger Massachusetts Campaign for a Clean Energy Future, particularly their two fundamental values that a carbon price must be science-based and equitable. However, we’d like to note several additional areas of concern:

1. Both the current TCI draft and the Massachusetts campaign document refer to RGGI as an effective precedent to emulate in several ways. We would like to reiterate that, for all the revenue RGGI has generated, we have yet to find a single economist who argues that the RGGI price ($5.20/ton at the Sept 2019 auction) has been high enough to drive the emission reductions needed to mitigate the climate crisis. This argument is further spelled out in this article from Vox <https://www.vox.com/science-and-health/2017/2/28/14741384/rggi-explained>

When it comes to setting a cap, we think TCI should set an aggressive maximum of carbon neutrality by 2050, with interim targets of 45% emission reductions by 2030 that all participating states must adhere to. States can then individually choose to be more ambitious if they wish, but we must provide states where industry is strong the legal mandate to fight the climate crisis.

We are also very concerned about the language around “cap flexibility” and “set asides.” A responsible system must plan for what history has taught us--that industry will fight tooth and nail to dodge its financial responsibilities. The MA campaign critiques on limiting cap flexibility and banking of permits are correct but don’t go far enough. In a climate emergency, we should not allow for flexibility, set asides, or banking, period. Industry must not be given wiggle room.

2. In MA, we are very proud of the design of H.2810 which uniquely proposes redistribution of 70% of its funds directly to families to financially equip them to make greener decisions. These rebates are weighted by income to ensure financial protections for the low-income communities most affected by climate change. This is the only carbon pricing bill to my knowledge that has received explicit support from Environmental Justice organizations in MA, and we must consider whether a progressive rebate structure is possible in TCI to ensure that no family is left in a difficult situation.

Meanwhile, our team in New York is quite concerned that New York Renews Coalition which just passed the CLCPA and is designing the CCIA, will face similar complications to MA. The careful work to build relationships with EJ communities for our state level prices does not seem to be transferring to the TCI process. This is partially why NY’s participation in TCI is currently tenuous.

In my previous commentary, I mentioned the concerns of our partners at the Climate Justice Alliance. Since that time, they have released another set of criticisms on use of Cap and Invest as a structure <https://climatejusticealliance.org/climate-justice-alliance-disappointed-disingenuous-policy-design-principles-proposed-transportation-climate-initiative-tci/>. TCI must provide specific allowances and guidelines for the equitable use of funds that it invests and will give local Green Justice communities the power to design a way to use those resources that meets their needs as they see them, not as the TCI administrators perceive them.


Thank you so much,
Our Climate

TCI is a key initiative for the future of our region. We need a plan that holds large transportation polluters accountable for the pollution they create and invests in clean transportation solutions including:
- More public transit and electric vehicle infrastructure in rural areas
- Expansion of commuter rail, electric vehicles, and streets in the suburbs that are safe, walkable, and bikeable
- Sustainable and equitable housing near transit and electric bus fleets in urban communities

Thank you for doing this work!

As someone who is deeply worried about the environmental costs of fossil fuel based transportation, I was excited to hear about this initiative. I hope TCI will pursue ambitious solutions that both reduce the impacts of human transportation, and make wise long-term investments in local economies.

Good luck with the project.

Transportation is the country’s and region’s leading source of carbon emissions so it is imperative that Pennsylvania join the Transportation Climate Initiative (TCI) to clean this sector up. Joining TCI is critical step to improving transportation and addressing the climate crisis in Pennsylvania.

If designed correctly, this program could help to create safe roads for biking and walking, more frequent and reliable public transportation, greater access to electric vehicles, and a more equitable system with cleaner transportation options for everyone in the region.

Seriously? This is nothing but a money grab.
Will increase the velocity of our State going down the toilet.

Transportation and Climate Initiative (TCI) states are developing a regional policy for low-carbon transportation following the December 18, 2018, statement by nine states and Washington DC committing to:

“…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.”

We have run out of time. Such a plan is beyond mandatory. There is no question in the mind of any reasonable person that Connecticut should be part of this initiative, and should be in a leadership role.

This is a TERRIBLE IDEA. We moved back to Maine from California because of things just like this. You cannot put your foot on someone's head and expect them not to drown while you hold them under water. Governor Mills needs to curb her spending and start listening to her constituents. Her term cannot end fast enough for me. She makes me miss the buffoon before her.

I would love to see: More choice of less expensive electric cars; advertising to shame rich people into stop driving huge, gas wasting cars; recharging stations at every rest stop on all major highways.(A family could stop and have a snack while charging their car. Knowing charging stations stations would be available would make people more comfortable moving to all electric cars.)
I drove to the rich western suburbs of Boston on Feb. 20, 2020. I watched carefully as I drove. I saw 1 hybrid car and 1 Tesla. The rest of the cars were very expensive cars, some V6’s and some V8’s !! I see this as shameful !! How are these people so ignorant !!
Otherwise, we need to make all forms of public transportation buses, trains, and subways all electric ASAP. Thank you for all you do.
Sincerely, Rebecca Bennett

As a senior on a fixed income I oppose this unfair tax. I will not support any politician including Gov. Baker that approves this rip off.