TCI Regional Policy Design Stakeholder Submissions

Please see the petition below and attached 196 signatures from across the TCI region. These can be added to the previous 298 signatures we submitted in November which had signed onto the same request, for a total of 494 signatures from Green For All supporters.

Dear Transportation & Climate Initiative:

We applaud your efforts to design a regional carbon pricing program for the transportation sector across the Northeast and Mid-Atlantic Region. There is no question, we must take steps to cut pollution from this sector and invest in solutions.

We must simultaneously take specific, measurable, and meaningful steps to ensure the communities hit first and worst by pollution, or who have inadequate access to mobility options, can fully participate and benefit from a clean, modern, reliable, and affordable transportation system. This commitment should be expressed in any regional commitment (such as an MOU), and should not be left to individual states to determine whether or how they will address the needs of our most impacted communities.

Last summer, organizations representing racial, economic, transit, and environmental justice communities delivered a set of 9 principles for policy design to ensure the regional program builds in the guardrails that will ensure protections and guarantees for communities most impacted. Each of these equity principles, especially a clear process for ensuring communities are at the table, must be baked into the regional program, committed to by each state that plans to adopt the program, in order to ensure that some communities don’t get left behind.

I echo and support the voices of those who are directly impacted determining what they need to see as part of the
program design. I urge you to commit to specific steps for each of the 9 principles for policy design in MOU.

Thank you,
(Signatures attached)

Our team is sharing an emission-free technology with France, Germany, Great Britian, Costa Rica and many more countries seeking to reduce the pollution and particle matter in their environment.

I took the time to prepare this comment because I don’t want this program to repeat the implementation problems associated with the Acid Rain Program’s emissions monitoring system. I was involved in the EPA reporting from the start of that program and would not wish that experience on anyone. My advice is to keep the requirements as simple as possible and minimize the total level of effort needed to submit and track emissions.

I would be willing to discuss this topic with appropriate staff if there are questions or comments.

Thank you.

EDF respectfully offers the attached comments and recommendations to the Transportation and Climate Initiative in response to the information presented on the September 16 webinar. Thank you for your consideration of these comments.

Comments on Program Design as Outlined on Sept. 16 and 29, 2020 TCI Webinars – Modeled 2032 Max Mileage Reductions from Reference Case of Only 2.0% is a Program Failure

Comments on Program Design as Outlined on Sept. 16 and 29, 2020 TCI Webinars – Modeled 2032 Max Mileage Reductions from Reference Case of Only 2.0% is a Program Failure

Partnership for the Public Good (PPG) is a community-based think tank that provides research and advocacy support to over 300 partners in Buffalo, NY. Each year, we hear from our partners that lack of investment in public transit is a major concern for them and the clients they serve. Our public transit system varies in quality depending on where you live in our city, and often the poorest, most vulnerable residents in our city, those who rely on public transit the most, are the same residents who have the least access to public transportation. We need a significant source of additional income for our public transit system, and this is especially true given the climate crisis and the need to reduce vehicle miles traveled. The revenue generated from this cap and invest program would be the perfect source for public transit funding.

Funding our public transit system will make our city more equitable by making jobs, healthcare visits, and other necessary trips more accessible to all in our city, especially for the most economically vulnerable. It will also constitute major strides toward a more environmentally just city as we mitigate the effects of climate change by reducing GHG emissions and invest in communities that have historically faced (and continue to face) environmental racism. Further, this investment is especially critical in this period of COVID-19 as our public transportation system faces extreme financial uncertainty and will likely have to cut service. This is unacceptable for our city, but especially for our most vulnerable populations.

Please take action on this cap and invest program immediately, and funnel the revenues from the program into our public transportation systems with an emphasis on serving those who have been disproportionately impacted by transportation-generated pollution and other systemic inequities.

Here is PPG's report on Race, Employment and Public Transportation in Erie County: https://ppgbuffalo.org/files/documents/working_toward_equalityfinal.pdf

CT STAKEHOLDER INPUT ON OCTOBER 1, 2019
FRAMEWORK FOR A DRAFT REGIONAL POLICY PROPOSAL

October 12, 2020

Dear Transportation Climate Initiative Regional Policy Workgroup,

Thank you for the opportunity to provide input on the “Framework for a Draft Regional Policy Proposal” released on October 1, 2019. I support a regional policy to reduce transportation pollution and believe robust and meaningful public input into both the regional and state decision-making on the Transportation and Climate Initiative (TCI) is necessary to ensure a just and equitable policy design for Connecticut. I offer feedback on the proposal’s sections below.

Our current transportation system in Connecticut and throughout the Northeast is inequitable, prioritizing car ownership and ridership over all other forms of transportation. This has, in turn, created pollution of many kinds and has resulted in transportation as the largest sector of greenhouse gas emissions.

Equity advisory committees
These committees are necessary to ensure accountability at all levels. It is essential that these committees have true decision-making power and include members from the relevant communities. To ensure participation from underserved and impacted communities, financial compensation for attending should be provided.

Dedicated investments for disproportionately impacted communities
At least 35% of investments, and ideally more than 50%, must be in disproportionately impacted communities to adequately address racial and economic justice issues. Antiracist discrimination, that is discriminating against people who are White in favor of Black and Latinx, is needed to make TCI an antiracist policy. More money must go to communities long left out of investment decisions to create equity. The Center for Latino Progress’s 2019 survey on TCI further indicates high support (82%) for prioritization of equity and environmental justice in investments, with 67% also supporting a dedicated percentage of investments going to address disproportionately impacted communities.

Air quality monitoring as complementary policy
Air quality monitoring is a necessary first step, but is the bare minimum needed. California’s model is a precedent for Connecticut, setting air quality improvement targets and strategies in individual communities and, through grants, empowers community organizations to facilitate this process. Because air quality is often worst in low-income communities and those with high percentages of Black and Latinx residents, the MOU should commit to lowering pollution in these communities.

Workforce training and employment
Creating good jobs in environmentally beneficial sectors is one of the most promising aspects of TCI. It is essential that strong labor standards are upheld and that job preference is given to those in environmental justice communities. Especially in this current age of COVID, well-paying and stable jobs are in short supply; TCI opens opportunities for high-quality jobs. TCI can and should also encourage apprenticeship and training programs.


Sincerely,

Jennifer G. Kleindienst
241 West St.
Middletown, CT 06457