TCI Regional Policy Design Stakeholder Submissions

Two recent experiences that solidified my regard for public transportation:
In the Netherlands well maintained, clean public buses are valued above bicycles, pedestrians, and, most importantly, cars, so much so that they control traffic lights by pressing a button on the dashboard! This system makes using buses desirable for their reliability, efficiency, economy, and climate sensitivity. Impressive!
I live in a rural, isolated setting and would need transportation home after an outpatient procedure, for example. Since here in the USA we lack deserved regard for pervasive public transportation, nothing exists to accommodate my needs let alone any national sentiment that invites and supports all economic classes to see the vitality of public transportation as an obviously convenient, obviously responsible, and obviously ecologically sound commodity. I personally have cancelled or missed medical needs and job related demands. Let's invest already!

Following the release on October 1 of the Framework for a Draft Regional Policy Proposal, and ahead of the release of a multi-state draft memorandum of understanding (MOU) to advance the policy design process, our coalition of vehicle manufacturers, fuel providers, and industry groups wishes to express our support for the development and implementation of a coordinated regional cap-and-invest program to hasten an equitable transition toward a cleaner transportation economy and healthier communities throughout the region. Please find our full comments on the Framework attached.

Maine’s largest source of climate pollution is our antiquated mid-20th centrury transportation system. It is inefficient and inadequately meets the needs of Maine people.
Maine people deserve clean, modern, affordable transportation options that deliver economic, health, and climate benefits to local communities.
It makes sense for Maine to work with neighboring states through TCI’s bipartisan, proven policy model.

Our Commonwealth can lead the way forward on Transportation, thanks to the plan Governor Baker would like to put into effect. If we can’t dramatically reduce the amount of pollution from our transportation industry, we will be in even worse shape regarding Climate Change. Please take the need to dramatically reduce CO2 levels seriously and use this initiative to get us to Net Zero in the Transportation Sector by 2030. Please prioritize our State’s “environmental justice” neighborhoods because with this issue, as usual, those contributing the least to the problem are impacted the most- in this case, we need public transportation that is clean and renewable.

The New York State Association of Metropolitan Planning Organizations (NYSAMPO) is a consortium of the Executive Directors of fourteen Metropolitan Planning Organizations (MPOs) in New York State who work together toward best practices and common goals. The Directors lead a diverse group of organizations that represent very large, urban regions like the New York City metropolitan area as well as small metropolitan regions such as Ithaca and Elmira. Regardless of size and complexity, the Directors understand the value of working together to help their organizations provide high quality transportation planning support to their member agencies and to the public throughout the State.
The NYSAMPO Directors have determined that the overall goals of the Transportation & Climate Initiative’s (TCI) low carbon transportation policy proposal are consistent with the strategic goals and planning programs of the NYSAMPO MPOs, as represented in their long-range regional transportation plans and the projects, programs and studies that are funded through their planning processes. The NYSAMPO Directors applaud New York State for its leadership in the effort to establish the TCI. NYSAMPO MPO staff has attended and participated in listening sessions throughout New York State and the Directors appreciate the opportunity to offer the following comment on the design of the proposed program.
Equity
As organizations which plan for the use of transportation funding authorized by Congress, MPOs must comply with Title VI of the Civil Rights Act of 1964 which prohibits discrimination based upon race, color, and national origin. The NYSAMPO MPOs are committed to ensuring traditionally underserved and underrepresented communities receive a fair share of the regional transportation system’s benefits and are not subject to undue burdens. MPOs maintain information and data related to the locations of protected populations within each metropolitan area in order to comply with Title VI and the Executive Order on Environmental Justice. MPOs consider transportation barriers and needs within these communities. The TCI’s community outreach and project planning related to the investment of cap-and-invest proceeds should be coordinated with the NYSAMPO MPOs to ensure consistency with their equity efforts related to Title VI.
Mobile Source Emissions
Reducing emissions from transportation is a common strategic theme in the NYSAMPO MPOs’ regional transportation plans. Additionally, several of the NYSAMPO MPOs must comply with requirements under the Clean Air Act Amendments of 1990 as they develop their plans and programs. More recently, federal transportation legislation establishes performance measures for on-road mobile source emissions, which require that emission reduction targets be established for the ozone precursors nitrogen oxides (NOX) and volatile organic compounds (VOC). Targets are also required for carbon monoxide (CO) and particulate matter (PM10 and PM2.5).

Table 1. NYS On-Road Mobile Source Emissions Targets
Target Year VOC (KG) CO (KG) NOX (KG) PM10 (KG) PM10 (KG)
2020 22,979 437,781 58,591 9,312 3,920
2022 42,765 839,633 107,713 18,132 7,482

Proposed caps to emissions from gasoline, on-road diesel fuel, and potential biofuels, should meet or exceed these agreed upon targets to help states New York State meet its goals.
Investment of Proceeds
Transportation improvements proposed through the TCI should be coordinated with the NYSAMPO MPOs to achieve emission reductions and other policy goals within the long-range regional transportation plans. This coordination will maximize the efficiency and leverage investment in the transportation system which will ensure greater benefits to users. It is important that revenues generated by the initiative be used to advance active transportation, public transit, cleaner vehicles, and other activities that have large-scale positive impacts on environmental quality and public health through the reduction of GHG emissions. The NYSAMPO MPOs regularly use analytical and policy tools that assist in the prioritization of transportation projects for federal funding which could be modeled for determining how cap-and-invest proceeds are invested.


Complementary Policies
Coordination with the NYSAMPO MPOs will support the goals of the low carbon transportation system framework as each organization works within metropolitan areas of New York State to develop and implement complementary policies in long-range regional transportation plans. MPOs can supplement the work of TCI by assisting municipalities within the metropolitan areas with coordinating infrastructure planning and land use planning that supports reducing emissions. For more information on NYSAMPO please visit our website at https://www.nysmpos.org/ or contact Michael Franchini at (518)458-2161 with any questions. We look forward to working with TCI and NYS in planning for a low carbon future.

I live in Shutesbury, MA and am working to pass carbon pollution fee and rebate legislation in Massachusetts. I am the chair of the Carbon Pollution Fee and Rebate Group of Climate Action Now and work as part of the Coalition for a Clean Energy Future, a group that is solely dedicated to passing carbon pollution pricing in MA. We are supporting Representative Jennifer Benson’s bill - H2810 “An Act to Promote Green Infrastructure and Reduce Carbon Emissions.”

We are also very much in support of TCI as an important piece of the climate change solution. It will be so helpful to develop regional plans like this one to price carbon pollution. As you contemplate how to put together the best possible plan, we would stress the importance of charging a significantly high price on carbon pollution and ramping that price up yearly until CO2 goals are met. Without such pricing the bill will not be sufficiently motivating to effect the needed changes in consumer spending. It is also crucial to structure the bill in such a way that it protects low- and moderate-income people from an unsupportable burden.

We also believe that it is imperative that multiple approaches to climate change are enacted in this time of crisis, not just one. The carbon pricing bill our organization supports in MA will cover emissions from heating, cooling, and powering buildings as well as from transportation, and it is supported by climate justice groups. As a fee and rebate bill, it is transparent and has low administrative costs. It’s structure is similar to the fee and rebate bill supported by Citizens Climate Lobby and recently introduced at the federal level. Thus, H2810 will serve as a model for the other states and will support the regional and federal effort.

H2810 is written to be completely compatible with TCI or other carbon pollution pricing proposals. It will subtract the price that TCI charges for a ton of pollution from the price charged by H2810. We need both TCI and H2810. We request that the TCI planning group acknowledge the importance of multiple approaches to cover multiple sources of carbon pollution and that the group advocate for state carbon bills, as well this regional one.

Thank you for all the good work you are doing planning for a regional TCI. We need the TCI bill as well as other local, state, regional, and federal action to successfully and swiftly address climate change, the most significant challenge of our time.

We are in support of all efforts to reduce carbon emissions and feel that any action taken in that direction is a step towards collectively caring for our planet.

My company operates in Maryland as well as parts of Delaware, Virginia and Pennsylvania. I am Not in favor of the Transportation Climate Initiative as it sets out a framework that imposes an unfair burden on all vehicle owners and thousands of businesses including my own.There have only been a handful of solicitations for feedback. No one knows the full detail of this proposal. The claims for a positive environmental impact have not been proven. This proposal places the burden of new taxes in a disproportionate way onto the poor and rural communities.