TCI Regional Policy Design Stakeholder Submissions

I feel that further taxing fossil fuels is very counter productive. I think the US and the world would be much better served if we simply eliminated incentives and tax cuts for the production and exploration of fossil fuel.

On behalf of Environment America, I am submitting the attached comments from 1,834 of our members and supporters across the jurisdictions considering this regional climate policy.

The Transportation and Climate Initiative is an opportunity for the region to reduce fossil fuel emissions and invest in clean transportation, like electric cars and buses, charging infrastructure, sidewalks/bike lanes, and regional rail.
We urge you to move forward with TCI and require that the revenue generated by the program is used to expand clean transportation. There are simply too many cars on the road contributing to our warming climate, not to mention our asthma rates and traffic congestion problems.
In particular, we’d like TCI funds to go towards zero-emission electric buses, EV charging infrastructure, expanded and improved bike lanes and regional rail, as well as tax rebates toward private EV ownership.

Dear Honorable Governors, Mayor Bowser and Transportation & Climate Initiative Workgroup Members,

As organizations representing Vermont’s leading low income, business, environmental, public health, and faith organizations, we thank you for the opportunity to comment on the draft Memorandum of Understanding for the Transportation and Climate Initiative (TCI), and for your continued leadership in exploring and advancing the development of a robust and equitable regional clean transportation policy.
The science could not be more clear: Our collective combustion of fossil fuels is warming our planet, and we risk severe costs and consequences from delayed or insufficient climate action. Swift, strategic solutions that reduce emissions in the transportation sector in particular – the largest source of our region’s carbon pollution – are imperative. There is a tremendous opportunity before us to design and implement a strong, equitable TCI cap-and-invest program.

As you embark on crafting a final MOU, we offer the following comments for consideration as critical components of a well-designed program that drives down climate-warming pollution, while also protecting and prioritizing underserved communities and other communities that are disproportionately burdened by vehicular pollution, the costs of the current transportation system, the lack of access to clean transportation options, and at highest risk for experiencing the negative impacts of a changing climate.

We offer the following comments and recommendations on the draft TCI MOU:
• Time is of the essence. We support the launch timeline outlined in the draft MOU, with the first compliance period for a regional TCI policy commencing no later than January 1, 2022.
• Ensure the program aligns with the science. We strongly urge the adoption of a regional transportation carbon emissions cap that requires at least a 25 percent reduction in carbon pollution over 10 years, starting with the program launch in 2022. Current climate science makes clear that serious pollution reductions are required, swiftly. Considering the urgency, we also urge considering more ambitious cap reduction levels that would provide even greater greenhouse gas reduction results, as well as other economic, equity, and public health benefits beyond those calculated in the modeling scenarios thus far.
• Enable strategic state-by-state investments and ensure equity. The ability for participating jurisdictions to have significant responsibility for determining how auction revenues are expended based on their unique needs is critical. Vermont is a very rural state. The needs of rural-living Vermonters are very different than for those living in Burlington or Boston. The ability for states to direct auction proceeds to support investments in transportation efficiency solutions that serve particular constituencies – such as rural Vermonters, low-to-moderate income earners or constituencies with unique transportation challenges – is essential. This kind of flexibility is important to help ensure equity and access to clean transportation solutions for everyone, which could range from direct incentives for vehicle electrification to innovative micro-transit pilots, bike and pedestrian investments, housing in and around our transit hubs and far more.
• Design for program performance. To ensure the program works well with a minimum level of performance and generation of auction proceeds in the early years of the program – affordably reducing transportation emissions – a minimum reserve price, or a price floor, is critical. We recommend setting a price floor consistent with allowance prices modeled in the 20 percent cap scenario, beginning at $6 per ton in 2022.
• Incorporate opportunities for program review and adaptation. Regular, rigorous program reviews are essential to maintain a strong program that enables flexibility and adaptability that considers current science, as well as other potential indicators that might warrant adjustments to the program design. We recommend that the first program review take place within three years of the program start, which, if commencing in 2022, would mean a program review in 2025 and every three years thereafter.

The Need for Complementary Policies
While a well-designed TCI program could help reduce the region’s collective carbon emissions significantly, far more work will be required. Identifying and implementing other complementary policies will be essential to aligning our emissions with what the science says is needed for a safe, habitable planet. We look forward to continuing to work with other TCI states, diverse and key constituencies, and all Vermonters to identify and advance that suite of additional strategies to complement TCI, finally putting us on the path to meet science-based climate pollution reduction targets we so desperately need to meet.

Conclusion:
Ongoing climate inaction puts our economies, public health, and quality of life at significant risk. TCI offers one of the most promising opportunities to make much needed pollution-reducing progress in the transportation sector. We thank you for considering this input and for continuing your work to refine and advance a strong, equitable, and flexible program that puts this region on a path to a 21st century, clean, affordable transportation system.

Sincerely,


Audubon Vermont
Capstone Community Action
Conservation Law Foundation
Lake Champlain Committee
Toxics Action Center
Vermont Businesses for Social Responsibility
Vermont Climate and Health Alliance
Vermont Conservation Voters
Vermont Interfaith Power and Light
Vermont Natural Resources Council
Vermont Public Interest Research Group
Vermont Yankee Decommissioning Alliance

CenterState CEO is an independent and forward thinking economic development strategist, business leadership organization and chamber of commerce dedicated to the success of its members and the prosperity of the region. CenterState CEO is headquartered in Syracuse, New York and has 2,000 members. You can see more information about us on our website: www.centerstateceo.com. We undertake programs in economic development/business development, economic inclusion, research, policy and planning, as well as innovation and entrepreneurial development to achieve our goals.

We are closely following the development of the Transportation and Climate Initiative (TCI). We have participated in the public information meetings sponsored by the New York State Department of Conservation on November 7, and the TCI webinar of December 17. We thank New York State and the TCI for making those opportunities possible and look forward to continuing to engage in the process as it moves forward.

We are well aware of the climate issues you are seeking to address with this program. We applaud the states for working together to address a problem on this scale, and recognize that the leadership being taken by the states together can have a significant impact on the problem. We urge you to keep the flow of communication open as we are concerned that the general public, and business community awareness of the TCI is not very great at this point. Ultimately the participating states will be asked to pass legislation to implement the TCI proposals, by that time it will be critical to have greater public understanding of what is being proposed and why it is being proposed. The TCI will increase the cost of doing business for New York State employers, it will be critical that you clearly articulate the benefit that will be generated by the actions you propose.

At this point we have more questions, and as an organization we have not taken any position on the TCI. We would ask you to consider several factors as you design this program.
Our employers frequently must compete for customers in national and international markets. We understand that your market model indicated a positive economic impact for the region as a whole. The region’s economic vulnerability is not really caused by whether some customers drive over a state line to buy a tank of gas in another state, but rather when a business in Central New York has to compete for a contract against a competitor in another part of the country whose fuel prices may be lower to produce and transport a product to market. These types of decisions can often be driven by fractions of a cent per unit differences between one plant and another.

The Central New York economy is very vulnerable to changes in transportation costs. We are heavily dependent on trucking to move our products to market. We do not have competitive rail service that major rail centers possess, we are largely the captive of a single railroad. This is not an uncommon situation for middle sized cities in the TCI region. If a CNY business is seeking to sell products to international market, it actually costs more to move goods 300 miles from Syracuse to the Port of New York/New Jersey by truck than it then costs to move that same product from the Port of New York/New Jersey to an international market (such as China) by ship. Therefore, we are very sensitive to increases in fuel prices. If you do follow the “cap and invest” strategy, then some of that investment should be dedicated to alternative modes of transportation in order to avoid significant adverse consequences to a region like ours. Central New York produces a significant amount of agricultural products, lumber, paperboard, and consumer products that are relatively low priced goods that will be very sensitive to an increase in the cost of transportation. To the degree that there would be a shift from truck to rail as a means of goods movement, there should also be a reduction in greenhouse gas emissions, as rail is a much more environmentally efficient way to move products.

It seems that the results from your economic model indicate that the rise in impact on CO2 emissions was generating diminishing returns as you raised the price; i.e. a 5 cent per gallon increase led to a 20% reduction in CO2 emissions, raising that to 9 cents per gallon only generated a 22% reduction and a 17 cent per gallon decrease only generated a 25% reduction. It appears most of the cap and invest strategy’s return came from the initial increase in fuel price, and it is possible that the marginal increase in additional CO2 reduction would not be worth the potential economic damage of continuing to raise the price.

Part of that diminishment of return may be linked to the nature of the opportunities in which the TCI invests. At the public meeting many of the advocates were recommending projects that while they may be meritorious in their own right might not be particularly effective at the scale of the problem that you are trying to solve. Adding a rural bus route to help a hand full of customers get to a center city is not likely to contribute much to the major CO2 reductions you are seeking to achieve. The investment projects need to be about systemic change and you need projects that will change human behavior. We would recommend that you identify large and bold initiatives that can make a difference such as building out electric car infrastructure across the states, investing in the electrification of transit, upgrading electric generation and transmission to make sure that the utility systems can actually serve the increase desired in the sales of electric vehicles, or investing in infrastructure such as inland ports that will move significant amount of freight movements from truck to rail.

The TCI will have to work with the region’s utility providers to assure that they have the capability to deliver the clean electric power that the TCI needs to reduce carbon emissions. For example, in New York State, Upstate New York already has a significant base of non-fossil fueled power sources including wind, hydro, and nuclear. Seventy percent of our power comes from those sources. Downstate, the supply is closer to 70% from fossil fuels, and only 30% from non-fossil fueled sources. A wise investment, while not necessarily a transportation one, would be to increase the capacity of the New York State electric grid to move non-fossil fuel

dependent electricity from Upstate to downstate, or to convert or replace the fossil fuel plants that supply New York City with clean power. There will also be a need to make sure that there is sufficient generation to support the widespread adoption of electric vehicles, and given the challenges in siting and permitting utility generation, this could be a problem that could undermine your efforts.

Another issue the TCI should address is to encourage states to change their transportation investment policies. For example, NYSDOT is currently close to a final decision on replacement of I-81 through Syracuse. This will represent a minimum of a $2.5 billion investment in highways around Syracuse. While this is a good investment, being done in an environmentally responsible manner, the investments that the TCI are proposing will pale in comparison to the amount of money which will have to be spent on roads and highways. You may need to convince member states, and the federal government, to reconsider their own transportation investment policies and put more emphasis on transit or non-highway investments. With the aging of the interstate system, many states will be in the position to consider whether they can turn their transportation investments to replace some of the demand for automobile transportation with other forms of moving people.

We appreciate your willingness to engage the business community on this important and complex issue. We look forward to be engaged in the process, and hope that we can make progress in addressing this problem.

Sincerely,



David A. Mankiewicz
Senior Vice President
CenterState CEO
115 West Fayette Street
Syracuse, New York, 13202
Phone: (315)-470-1942
Email: dmankiewicz@centerstateceo.com

February 28, 2020

Transportation & Climate Initiative
Draft Memorandum of Understanding of the Transportation and Climate Initiative (TCI)
Comments from the Port Authority of New York and New Jersey


The Port Authority of New York & New Jersey (Port Authority) builds, operates and maintains infrastructure critical to the New York/New Jersey region's trade and transportation network. These facilities include the country's busiest airport system, marine terminals and ports, the PATH rail transit system, six tunnels and bridges between New York and New Jersey, the Port Authority Bus Terminal in Manhattan, and the World Trade Center site. For more than eight decades, the Port Authority has worked to improve the quality of life for the more than 18 million people who live and work in the New York and New Jersey Metropolitan Region - a region that supports 9.2 million jobs.

In October 2018, the Port Authority embraced the Paris Climate Agreement, making it the first US transportation agency to do so. The Port Authority is committed to reducing emissions associated with our facilities and improving air quality for neighboring communities. This includes a variety of innovative programs and initiatives to conserve energy, increase our use of renewable energy, and transition vehicles and equipment from fossil-fuel to zero-emissions models.

The Port Authority wishes to reiterate its support of the Transportation & Climate Initiative and encourage both New York and New Jersey to participate in the program as Signatory Jurisdictions. As a bi-state transportation agency that enables the movement of people and goods throughout the region, we believe there is a strong need for regional, collaborative solutions to address transportation-related emissions. Furthermore, given the significant impact that Ports and Airports have in environmental justice communities and our focus on reducing emissions from these facilities, we have a deep understanding of how TCI proceeds can be used to address emissions that impact these communities.

The Port Authority respectfully submits the following comments on the Draft Memorandum of Understanding for the Transportation and Climate Initiative.

1. Affected fuel: Significant emissions stem from equipment at the seaports and airports that operate on off-road diesel. Given the overwhelming presence of these facilities in environmental justice neighborhoods, we believe that both diesel and gasoline emissions should be capped to equally treat fuels that have significant on and off-road utilization. Also, as noted in our November 5, 2019 comment letter on the TCI framework, it should be noted that some off-road equipment at the airports run on gasoline and thus the emissions cap on gasoline and on-road diesel may unequally impact equipment types and owners within the same category.

2. Support for emissions sources that face the greatest challenges to decarbonize: The impact of emissions from vehicles and equipment that do not have a viable electric option in the near future should not be overlooked in the determination of how proceeds should be used. Even if an electric model is commercially available, the barriers to conversion for off-road equipment and heavy-duty trucks are higher than they are for passenger EVs or even buses, due to the increased cost premium, usage needs, and round-the-clock operations of specialty equipment. Again, given the overwhelming concentration of these types of equipment in environmental justice communities, enabling emissions reductions in this sector will provide the most impact to EJ community residents. Supporting low-carbon liquid fuels, funding demonstrations of newly introduced electric equipment, and funding charging infrastructure at seaports and airports are essential tools for addressing emissions from these sources. Given the cross-jurisdictional nature of TCI and emissions from air, rail and marine people and goods movement, it makes sense for TCI proceeds to be used to accelerate decarbonization in these sectors of the economy.

3. Targeted support for conversion to electric for-hire vehicles: For-hire vehicles have higher levels of utilization than most passenger vehicles. These vehicles are among the biggest sources of emissions at Port Authority facilities - second only to aircraft at our airports. Independent drivers are more likely to convert their vehicles to electric if they have financial support to cover the higher up-front cost of EVs, and strategic investment in fast-charging infrastructure to support these fleets - for example at airports - would achieve meaningful GHG reductions and improve air quality and reduce noise in surrounding communities, many of which are environmental justice communities.

The Port Authority commends both New York and New Jersey for their stakeholder engagement on TCI, and strongly encourages both States to participate in the cap-and-invest program. We look forward to continued collaboration to make this program as effective as possible in catalyzing the transition to a low-carbon economy.

Sincerely,


Christine Weydig, Director
Environmental and Energy Programs
The Port Authority of New York and New Jersey

Thank you for the opportunity to provide the attached comments.

Regards,

Brett Barry