TCI Regional Policy Design Stakeholder Submissions

Thank you for the opportunity to offer my comments and concerns about the Transportation and Climate Initiative MOU among Northeast and Mid-Atlantic jurisdictions. I applaud the Baker Administration for working to reduce emissions related to transportation and for collaborating with other states in our region to do so. In order to build the clean, safe, and accessible transportation system that Massachusetts requires, and to address the climate emergency we are faced with, the TCI must be equitable, visionary and ambitious. The current TCI proposal has areas that need to be addressed.

The emissions reduction estimate of the current TCI proposal is flawed. It does not take into account a 19% drop in emissions caused by the more fuel-efficient vehicles that will be used over the next decade. The TCI proposal would not reduce emissions from transportation in the region from 20-25% over 10 years as stated; it would reduce emissions by 1-6%. In Massachusetts, as transportation is responsible for 40% of emissions, the TCI would reduce total emissions by only 2.4%. In addition, climate change mitigation calls for emissions reduction to be approximately 40% of current emissions levels per decade. The TCI only aspires to reduce transportation climate emissions by 1%, 3% or 6% over a decade. This is clearly inadequate. The TCI targets and calculations must be reconsidered and revised.

It is critical that the TCI proposal protects moderate and low-income and rural residents from bearing an inequitable financial burden as transportation emissions are reduced. Funds generated from the TCI should be distributed to cover added energy expenses over time. In addition, the TCI should include policy regulations that:

1. Provide funding to rural residents to cover the added gasoline costs incurred from longer driving distances and from extremely limited public transportation options.
2. Allocate funds to public transportation, municipal energy efficiency and renewable energy projects, EV charging stations in rural areas and urban areas with rental properties, rebates for electric vehicles, including used EVs, and higher EV rebates for low-income residents, to make EVs more accessible to residents of all income levels.
3. Target funding for the development of community solar for moderate- and low-income residents.
4. Include large emissions from jet fuel.

TCI funds should be invested in clean energy, energy efficiency, and more robust public transportation. This would improve our economy by increasing employment opportunities, improving public transportation, and making jobs more accessible. Clean transportation will improve the quality of life throughout our region by lowering pollution related health issues and giving us hope for the future.

I strongly support the Transportation Climate Initiative. The quicker we get behind clean energy, energy efficiency, and mass transportation the better off we will be as a state. Investing in these areas will create jobs, help reduce carbon emissions and clean the air. Thank you

As a senior Conservation Biology major at Middlebury College, this semester I am taking a class that focuses on transportation in Vermont. Over my time in college, I have learned from an array of courses the dangers that vehicle pollution poses on human and non-human ecosystems. Fortunately for Vermonters, we have some of the best air quality in the country, with the American Lung Association ranking Burlington as one of the cleanest cities for year-round particle pollution.

Yet, we’ve all had a moment rolling down the window of a car, walking down the street in town, or just sitting peacefully outside, when we get a big mouthful of vehicle exhaust and think to ourselves, Ooh, that might not have been great for my lungs. And although we don’t always have these upsetting realizations each time a car goes by, every day we are exposed to some level of unavoidable air pollution. Tailpipe emissions, from passenger cars to 18-wheelers, send a variety of pollutants into the air that we all breath - nitrogen oxide, carbon monoxide, and particulate matter, to name a few.

Study after study shows that air pollution caused by motor vehicle exhaust has been directly linked to a variety of human health issues, including asthma, bronchitis, stunted lung development, and in more serious cases, premature death. Furthermore, this increased risk of health issues drags with it an increased medical bill for millions of Americans. With transportation responsible for emitting about 40% of Vermont’s GHGs and, as a result, impacting human health, it’s about time that the industry takes a look at what it is costing all of us, and takes action to change that for everyone.

In short, the Transportation and Climate Initiative (TCI) seems to be proposing two things, both of which could improve our air quality, and thus our health. The first is to decrease motor vehicle emissions, and the second is to change behavior and incentivizing a move toward low-carbon / electric vehicles. In the Draft Memorandum of Understanding (MOU), the TCI recognizes that “accelerating the transition to cleaner, more efficient transportation sector will improve public health… for all communities.” (p.3). This last piece is a necessary component of the TCI - that the “public” whose health will be improved is not solely the young, healthy, middle and upper class, but it is the low-income, disadvantaged, and disproportionately afflicted citizens as well.

Therefore, it is important to address where the TCI has room to improve. The Draft MOU resolves that Signatory Jurisdictions will be enabled to, “strategically invest in programs to help their residents transition to affordable, low-carbon transportation options that provide substantial public health benefits, reduce congestion, and increase economic and job opportunities.” The pursuit of a cap-and-invest program, rather than a cap-and-trade program, is promising (despite the quite blurry lines on buying offsets). However, the section that speaks to these investments, Appendix 3A, is upsettingly unclear. Wording such as, “invest the proceeds from the auction of allowances as determined appropriate by each Participating Jurisdiction to achieve TCI Program goals” and “to achieve CO2 emission reductions and other related TCI Program goals” (Appendix 3A), does not provide citizens much insight into what these investments might be. Citizens should be able to understand the investment process, as we are the ones electing the legislature that will then decide how the revenue from allowances will be invested.

In order to have a more robust TCI, it is necessary for the document to outline what investment options look like. As the TCI is pushing a movement towards electric vehicles, it must be responsible for supporting this movement. Therefore, investments should be made in infrastructure that provides charging stations to make the use of EVs feasible for Vermonters. Another solution is for the TCI jurisdiction to provide subsidies on electric vehicles in order to help and incentivize all citizens, particularly lower-income and disadvantaged community members, to transition to cleaner transportation alternatives.

The current TCI, however vague, does recognize the impact that it could have on improving public health of all Vermonters, yet it has much room to grow in defining a solution to get to that endpoint. What is important is that the TCI has the potential to be a step in the right direction towards stronger human and environmental health, as a future electric transportation sector would eliminate the tailpipe and GHG emissions that negatively impact our communities and the non-human entities that inhabit our ecosystems.


Sources:

Draft Memorandum of Understanding of the Transportation and Climate Initiative. (2019).

Brugge D, Durant JL, Rioux C. Near-highway pollutants in motor vehicle exhaust: a review of epidemiologic evidence of cardiac and pulmonary health risks. Environ Health 2007; 6: 23.

Gauderman WJ, Vora H, McConnell R, Berhane K, Gilliland F, Thomas D, Lurmann F, Avol E, Kunzli N, Jerrett M, Peters J. Effect of exposure to traffic on lung development from 10 to 18 years of age: a cohort study. Lancet 2007; 369: 571-577.

Meo, S. A., et al. Effect of motor vehicle pollution on lung function, fractional exhaled nitric oxide and cognitive function among school adolescents. European review for medical and pharmacological sciences 2019; 23: 8678-8686.

https://www.ucsusa.org/resources/vehicles-air-pollution-human-health

TCI is a once in a generation opportunity to reduce greenhouse gas emissions and re-invest funds to much needed transit improvements, including safe and reliable public transportation, electric vehicle infrastructure, and "Complete Streets" for bikers and pedestrians. Unreliable transit is taking time residents should be spending at work or with their families. Please fight for TCI!

Vermont’s Participation in the Transportation and Climate Initiative Has the Potential to Improve Equity While Protecting the Planet

Coming off of the recent decision to pass the Global Warming Solutions Act, Vermont has the opportunity to further its environmental commitment by supporting the Transportation and Climate Initiative (TCI), a regional effort to reduce carbon dioxide (CO2) emissions and improve sustainable transportation. The state must be a part of this undertaking, for the good of both the planet and its residents.
I chose to attend college in Vermont, over 3,000 miles from my home, because of the environment. I was not only drawn to the incredible natural beauty of the state, but also to the Environmental Studies program and Middlebury College. In my third year in the major, I’m spending a semester in an Engaged Community Practicum, thinking critically about public transit in the age of climate crisis. This perspective and sustained engagement with local stakeholders inform my understanding of the TCI, as does my childhood in an urban area where I depended on a (deeply flawed) public transit system.
The beauty of the TCI is that it takes the theories behind environmental justice and puts them into practice. The initiative holds the potential to provide incredible benefits to those who need them the most. The goal is to use a cap to reduce vehicle emissions (specifically on-road diesel and finished motor gasoline) and then invest the proceeds in measures to further reduce emissions and improve the quality and resilience of transportation. By targeting transportation, which contributes 43% of CO2 emissions in the TCI region, the program will combat climate change, which disproportionately impacts poor and marginalized groups.
The Draft Memorandum of Understanding for Stakeholder Input (MOU) highlights the program’s equity implications, pointing to increased accessibility and mobility as one key example. However, it must be acknowledged that the MOU is merely a sketch of what needs to become a much more robust plan. How exactly this outline is fleshed out has critical implications. When it comes to thinking about equity and the TCI, we must consider two dimensions: participation in process and distributive justice. Addressing these elements will alleviate most concerns about the TCI, but this has yet to be done sufficiently.
The Investments and Equity section of the MOU highlights the importance of thoughtful investment, of allowance proceeds, and of prioritizing transportation improvements for underserved communities. Significant concerns have been put forth about the potential for regressive effects of the TCI, and the writers of the MOU are right that proper investment can ensure that costs do not fall disproportionately on vulnerable groups. This is the case because Vermont’s low-income and aging populations share similar transportation obstacles, such as less access to personal vehicles. Therefore, investment in improved public transit options and pedestrian and cyclist safety will present benefits. Policy makers must make clear to the public exactly how they will invest proceeds in order to ensure that this program is progressive rather than regressive. In particular, this should include less emphasis on electric vehicles, which under the current investment scenario receive the largest share (30%). Rather than promoting infrastructures and ideologies centered around reliance on personal vehicles, the TCI must be more ambitious in investing in public transit. This is especially important considering the uncertainty around electric vehicle technology in rural, rugged landscapes.
It also must be clarified that distributional equity does not mean that benefits and burdens are evenly distributed across a population, but that those with the most constraints receive the most support. Furthermore, moving forward, policymakers must also demonstrate understanding of another core tenant of transportation equity, which is ensuring meaningful public involvement in the planning process.
Another key element regarding equity will be participation in the process. Policymakers must prioritize sustained public outreach to diverse demographics, and break down documents like the MOU in plain language to improve accessibility. Additionally, public transit programs and investments must be need-based, not demand-based. This may seem like semantics but the distinction means prioritizing justice and working towards accessibility by overcoming isolation.
Climate change demands rapid and expansive action to reduce emissions and adapt to exacerbated vulnerabilities. The scale of the TCI promises to do just that, harnessing technological and political tools already easily available. However, policymakers must sustain and expand upon their commitment to equity, proving to Vermonters and other residents in the region that the program will help rural, poor, and underserved communities.

Please see the attached comments from The Nature Conservancy on the TCI Draft MOU.