TCI Regional Policy Design Stakeholder Submissions

This makes no sense for the people of Maine! It will be an oppressive burden on all the citizens that depend on reasonable prices on goods and the ability to heat their homes They also need be able to get to a job or store. For many of us this will be the breaking point to force us from our homes and seek a new state to live in. We the citizens of Maine can't afford anymore added taxation and be able to survive here!

Certainly a great idea not only do we need efficient well run alternative fuel public transportation but it must Be superbly well run reliable pick up or scheduled stops
Something akin to Go Go Grandparent managed by a super logarithm for rural or small town densities reliably well run
It’s a huge challenge
Yes our elders as well as youth need it
Good luck
May the best young brains be engaged in designing it

I am a long time Geo Metro driver with my husband operating all electric cars for 10 years. I know poor people in Lewiston who want to work in Portland, but have no way to get there. I volunteer at the Gathering Place in Brunswick where many people need cheap transportation to Lewiston, via bus or train, but it's not available. The public needs regular bus routes between Lewiston and Brunswick so L/A residents have access to the major job source and services in Portland. Maine must reactivate the train line between Auburn and Portland to connect the two major urban areas of the state. Middle class workers will use this line, since it's much pleasanter, more affordable, and lower Carbon impact to ride instead of drive that distance.
I live in Topsham and support Governor Mills participation in the regional planning for greener public transportation in Maine. This plan must incorporate the most recent and best science on climate emissions from transportation. Transportation policy must be fair and inclusive for elderly, poor and handicapped people in Maine. This large group of Maine residents do not have private transportation and many need regular, affordable transport between Lewiston, Brunswick, and Portland to help meet their basic needs for essential services.
I am delighted and thankful that this policy planning includes both Republicans and Democrats, since it will work out compromises of cost, and practicality that will best serve Maine people and have support in the legislature to be enacted.
I am in the process of moving from 14 miles south of Bath to center of Topsham in order to reduce my driving time, climate impact, and costs. I am still able to walk the 1.4 miles to downtown Brunswick, yet will be working for cooperation between Topsham and Brunswick to extend Brunswick's good bus system to Topsham. This is one urban area which is only half connected via public transportation. Traffic congestion is moderate and growing both bypassing Brunswick and from Topsham to Brunswick and could be alleviated with an extended bus system. A regular bus system between Bath and Brunswick is greatly needed, since affordable housing in Brunswick is unavailable and very limited in Bath. Low income people who have no cars cannot get to work or housing between those two cities. The Brunswick Explorer bus has adapted and responded to need to transport students and refugees to and from the old Navy base at Cook's Corner.
Lanes for bicycle traffic should be established between urban areas and along scenic routes, as this can be both affordable transportation, good for people's health and reduce congestion, air pollution, and carbon emissions. Topsham has started this process of making a safe walking/biking path along the bypass connector between Rt 1 in Brunswick and Rt 196. When completed many Topsham residents will be able to walk and bike to the Topsham Fair Mall.
For decades I have wanted a dial in ride sharing system to be created using people's smart phones to schedule shared rides to work. The state and BIW have done this with vans for some of their workers. This concept could be applied to private vehicles with thought given to screening people in the system for criminal records. The state cannot guarantee safety of people using such a system, yet the potential to reduce gas miles driven is huge. Perhaps towns could create a register of screened drivers with insurance who are willing to share rides. Maine can build on our small town culture of looking after one another, and take better care of our isolated elderly and poor residents with such a service. I am part of a volunteer network of drivers with New Mainers who take non English speaking residents of Brunswick to their twice weekly English classes in Topsham. this involves scheduling about 15 drivers with 20 or more residents and setting up phone communication for cancelations. Such transportation is also provided, or connections to the bus systems, for people to attend essential meetings in Portland. BIcycles have also been given to every adult at Brunswick Landing who wants one, and training provided in bike safety and practice biking to the library.
Mostly I would like to see commuters sharing rides to minimize Carbon emissions, reduce traffic congestion and free up parking in urban areas. Thank you for this long needed subcommittee to design sensible transportation systems. Please look at European rail, and other public transport systems for adaptation to Maine's transport needs.

I believe it is vitally important that we move very quickly to reduce pollution from transportation, our largest source of global-warming emissions, both regionally and nationally. In a state like Maine, with vast stretches of rural areas with almost no transportation options other than private automobile, figuring out how to provide low-emission transportation and discourage the use of private cars should be of paramount importance. The benefits would go beyond slowing climate change catastrophe; Maine's older population needs the security of being able to get to appointments and to be socially active once individuals are no longer able to drive.

Whatever policies are put in place should strive to be equitable, prioritizing clean investments in areas overburdened by pollution and/or for those who don't have access.

It is imperative that Maine formally join the plan to reduce emissions. How much of our storied coastline can we afford to have changed by rising waters and more frequent an intense storms?

I applaud the bipartisan nature of this project within our region. It is time to move forward!

I think it's vital that we do all we can to mitigate, and work toward stopping climate change by any means. Lives are being lost. Pollution is the cause, has been taking lives for a long time and the acceleration is ugly to see. Because it isn't yet so near to us doesn't mean we won't be feeling effects of all kinds as our fellow human beings, and living things in general are forced to flee pr perish.
I have a grown daughter in California who was extremely lucky to escape being burned to death/ It truly brings the situation home and into focus. The costs of paying a carbon tax could be budgeted for by giving up a bad habit or two, also helpful.
I'm wondering what % of VTs Carbon emissions come from that new Burlington airport and the military in general and if they can be made to pay for their emissions as well. I 'm hoping that New Hampshire will get a chance to reformulate their position on this. I think we should carry ahead no matter what.
Thanks for the opportunity to comment.

IETA SUBMISSION TO TRANSPORTATION & CLIMATE INITIATIVE (TCI)
The International Emissions Trading Association (IETA) appreciates this opportunity to share input on the Transportation & Climate Initiative (TCI) Draft Memorandum of Understanding (MOU) (the MOU). On behalf of our 130+ multi-sector business membership worldwide, we believe that flexible market instruments – including trading, broad access to natural climate solutions, and cross-border cooperation – must form the backbone to any jurisdiction’s successful climate policy effort. We welcome the TCI’s climate leadership, cooperation, and support for flexible market instruments.

IETA's comments are a result of deep experience and lessons learned across North American and international carbon markets. Our policy and market insights are a testament to the iterative – yet increasingly robust and aligned – nature of carbon pricing system design; an evolutionary process where jurisdictions are not only identifying best practices, but also seeking to embed and operationalize these elements into new or modified program improvements.


OVERVIEW & COMMENTS
IETA’s comments are structured around the sections in the MOU, with detailed comments on: program design elements; applicability; compliance and enforcement; flexibility, allowance allocation and stringency; regional program administration; and additional program design elements.


1. Goals and Schedule
IETA commends TCI’s ambitious objective of releasing a regionally coordinated Model Rule by 31 December 2020, with the intention of commencing the first compliance period as early as 1 January 2022.


2. Model Rule for Establishment of the TCI Program
2A. Affected Fuel.
IETA agrees that the fuels proposed to be covered by TCI’s proposed program, on-road diesel and motor gasoline, are the appropriate ones. In general, IETA and its membership believe the program should cover as much of the fuel in the region as possible while taking account of the renewable components.

2B-C. Regulated Entities & Other Entities.
In order to make the TCI program as efficient as possible, the compliance point should be set such that compliance entities can take full advantage of existing tax and tracking systems. IETA members support the proposal to set the compliance point at the terminal rack, with an alternative for any fuel that moves into the region directly. While there is not a directly comparable pricing and tracking system already in place, the terminal rack is the point from which most of the fuel is distributed in the region; it also upstream of the smallest distributors and allows for a manageable number of entities. IETA recognizes that there are suppliers that import fuel directly into the TCI region and believes that those imports can be incorporated into the program without creating an undue burden on small suppliers.

2D-F. Regional Emissions Cap, Budgets & Scheduled Reductions.
IETA supports a system that sets strong science-based caps on emissions reductions, in line with meeting domestic and international climate targets. IETA generally supports the MOU’s approach to setting the regional emissions cap, and we strongly support a regional base annual emissions cap that declines over time in a transparent and predictable manner to allow for medium and long-term planning by facilities and stakeholders. IETA supports the apportionment of the regional base annual CO2 emissions budget to the participating jurisdictions annual budgets, along with the revision of budgets as jurisdictions enter into or withdraw from the program.

2G. Stability Mechanisms.
IETA strongly supports the potential inclusion of a Cost Containment Reserve (CCR) and Emissions Containment Reserve (ECR) in the TCI program. We look forward to more details as the program continues to develop and encourage TCI to look to other regions for examples of successful CCR and ECR mechanisms.
We are encouraged by the framework’s consideration of price-based flexibility mechanisms, including linking as a mechanism to add flexibility and contain costs. Moving forward, the TCI must look beyond its borders to ensure that the rules and systems are complementary and readily adaptable to the world’s quickly changing carbon landscapes. We urge officials to closely track developments that may affect both regional or global “stringency” acceptance of TCI’s approach to carbon rules, pricing and trade. Now is an ideal time for the TCI to be aware of, and account for, any challenges that could emerge down the line. IETA is well-positioned to support this information exchange with TCI and state officials on carbon policy and trade developments and outlooks. We welcome the opportunity to help ensure that the TCI regularly has access to this latest policy information, analyses and outlooks.
Final regulation should see more prescriptive, enabling language to more easily recommend and adopt future market linkage opportunities. For example, international market programs under development (e.g., Article 6/ITMOs, voluntary, international aviation etc.) and existing domestic market programs (e.g., Quebec-California cap and trade programs).

2H. Emission Reporting Requirements.
The proposed requirement for covered facilities to submit a report and supporting information in an electronic emissions reporting system appears sound and defensible. We also support independent third-party verification of the report, recognizing the importance of transparency and verification in ensuring environmental integrity of the system. IETA strongly supports drawing upon lessons and standards from existing greenhouse gas programs in the design of the monitoring reporting and verification (MRV) requirements.

2I. Regulated Entity Compliance and Flexibility.
IETA strongly supports the framework’s inclusion of allowance banking, multi-year compliance periods, and offsets. These instruments should be available to compliance entities to meet full regulatory obligations across these jurisdictions. We hope to see these principles of flexibility and cost containment continue as core principles, guiding the finalization of TCI regional program rules and frameworks.

2J. Auctioning and Alignment.
IETA encourages the TCI jurisdictions to use auctions as the primary method of distributing allowances. Auctioning allowances and allowing a strong market-based approach will incentivize reductions and allow for appropriate price-setting. IETA encourages TCI to collaborate closely with near-term jurisdictional linkage partners (i.e., RGGI, and Quebec and California). Harmonizing and aligning core design rules, standards, joint market infrastructure (e.g., auction platforms, tracking systems etc.) across priority partners are foundational steps towards building broad, linked markets. Cross-border collaboration also allow business, particularly those with regulatory exposure across multiple regions, to more efficiently and cost-effectively plan and invest.


3. Investments and Equity
3A. Investment of Proceeds.
Proceeds from a pollution pricing program can play a dramatic role in supporting TCI jurisdictions’ climate mitigation actions over time. Other jurisdictions – in North America and internationally – earmark and disburse revenue from their pollution pricing programs to support clean technology, innovation, and emissions reductions initiatives. IETA is pleased to learn that the TCI is considering a range of options for investing auction proceeds, and encourages further examination of existing successful programs, including the New York Green Bank, the Australia ERF, and the UK Low-Carbon Innovation Fund (LCIF). In particular, we support investments made towards helping TCI jurisdictions reach their climate policy objectives while supporting regional businesses and consumers to transition to carbon constraints and economic decarbonization.

3B. Equity Shared Priority.
IETA strongly supports the goals of equity, environmental justice, and non-discrimination – and encourages TCI to continue to pursue these goals, including working with disadvantaged communities to assess the impacts of the program.


4. Regional Organization
IETA supports the proposed structure of the regional organization, including its functions, authorities and limits on authorities.


5. Addition or Withdrawal of Participating Jurisdictions
IETA supports the TCI’s approach to new participating jurisdictions and withdrawal from the TCI program. We are pleased to see that the participating jurisdictions will encourage other jurisdictions to the program with the goal of expanding the geographic reach of the regional program. IETA believes that the expansion of this program will benefit all participating jurisdictions by expanding the market. IETA also supports the approach to withdrawal, and that the program can be adjusted based on jurisdictions leaving and entering the program.


6. Program Monitoring and Review
IETA strongly supports continued monitoring of the progress of the program. We urge TCI to undertake ongoing and frequent reviews. Frequent reviews, which are clearly defined and communicated to all stakeholders, will ensure that program parameters remain relevant and reasonable within the context of changing industries, trade and broader macro-economic conditions.


CONCLUSION
Transportation stands out in the TCI region – not only because the sector is now the number one source of carbon emissions, but also because those emissions are increasing. Once again, we applaud the TCI for moving forward – in a cooperative, transparent manner – to harness the power of markets to tackle this challenge in practical and cost-effective manner.
IETA appreciates this opportunity to record our comments on the TCI’s MOU. Our community looks forward to close engagement with the TCI through 2020. If you have questions or follow-up regarding this submission, please contact Justin Johnson at johnson@ieta.org.

We must end fossil fuel use and increase safe renewables. Delaware must allow homeowners to produce more than %10 over their electric usage so we can retire fossil fuel power plants. We must provide incentives for individuals to install electric storage capabilities to provide power after dark or during windless times. Power companies must be incentivized to install systems that uses excess power to break down water into hydrogen and oxygen. They can sell the oxygen for medical or commercial uses and store the hydrogen to use as fuel when renewables are unable to provide sufficient power to the grid. No greenhouse gases would be produced and all the fuel to provide the electricity would be free.
Delaware must increase the use of electric public transit vehicles. Most routes are short enough to allow this, and longer routes could have charging stations at each end of the route. Drivers would park and charge the vehicle they drove into the end of route station, and move to another vehicle that has been charging. It may require a few more vehicles, but the cost would be partially offset by the lower maintenance costs of the electric vehicles.
We must also initiate a fee for internal combustion vehicles bases on fuel mileage figures. The lower the miles per gallon the higher the fee. This would cause the more polluting vehicles to pay their fair share of the cost of their emissions.
We must encourage more electric vehicle purchases. Businesses must be incentivized to install charging stations for employee electric vehicles and encouraged to use solar or wind power to provide the electricity. They could receive a one time tax rebate for the installation of the chargers and solar or wind facilities. They could also receive tax rebates if the installed power storage facilities.
Delaware must also require that a certain percentage of vehicles from each manufacturer are all electric powered vehicles. We have been trying to purchase a Hyundai Kona electric from a Delaware dealer for almost 2 years now. Despite Delaware being a state that qualifies for them, local Hyundai dealers do not carry them and when we inquire about them, are told that they are not available within 200 miles of the state. We know this is untrue because we have seen them for sale in dealerships within 50 miles in MD and 20 miles in N.J. We don't want to have to deal with a dealership so far away and in a different state.
Delaware must also enact a carbon tax on industries. The fees could be used to pay for health care for individuals harmed by industrial carbon.

The US public transportation system is antiquated, unsafe, untimely, polluting and fails to appropriately serve the public at large. It is time to develop an electrified high speed comfortable rail system serving long distance, as well as well connected metropolitan light rails, metro, and electrified bus systems that serve all zip codes. This is allow children to attend school on time, will broaden access to food for underserved communities, and expand access to job opportunities while decongesting roads. Americans spend more than a month yearly behind the wheel. This increases stress, pollution, and decreases family time which is already abysmal compared to other developed countries.

I wonder how this could affect rural communities like my own. Perhaps by developing a ride share program that would actually function? (We have had many discussions and a few failures over the years.) People have to drive up to 30-45 minutes just to buy groceries, or even gasoline! And we all drive vehicles that are far too large but can handle the extreme weather and rough road conditions. So much room for improvement!