TCI Regional Policy Design Stakeholder Submissions

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.

1) As an affected rural Vermont resident, I am interested in monitoring emissions reduction progress. For example, where could I find cubic models including baseline and changing air quality statistics that can be viewed by zip code or other measures?

2) I joined yesterday's webinar but found the scope and focus to be about social injustices. Is there a local organization that can address less complex but effective complimentary initiatives for emissions reduction at a local level?

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

Please make sure that this process is guided by those most impacted by the issues at hand and that TCI revenues is dedicated to transit funding.

1. need a dedicated source of funding for this initiative.
2. Need more fast charging stations, with standardized hookups, distributed in strategic locations.
3. Need to move quickly in providing incentives for electric busses and medium commercial vehicles.
4. Need to move much more quickly with onshore wind, solar pv, solar hot water, and energy efficiency’s.
5. Above all, we need to proceed quickly with a variety of initiatives. We don’t have decades, we have a few years at best. Please convey to the decision makers that we act quickly.