TCI Regional Policy Design Stakeholder Submissions

The benefits of reducing greenhouse gas emissions cannot ultimately be fiscally quantified, as these include protecting biodiversity and human well-being. Nonetheless, the TCI’s first-decade regional benefits include (1) increases in GDP, disposable personal income (DPI), and employment, (2) better public health from cleaner air valued at $3 – $10 billion, and (3) a 20 – 25% reduction in greenhouse gas pollution from cars and trucks; while the VT-specific benefits include (1) $18 - $80 million in annual revenues to invest in low-carbon transportation options, (2) more money from the program each year than Vermonters contribute, and (3) the opportunity to make the state more affordable for low-income and rural Vermonters by lessening dependence on imported, polluting and expensive fossil fuels.

THERE IS NO CLIMATE CRISIS!!! There is ample evidence that CO2 cannot cause warming and does not cause warming. The global temperatures have not risen by more than 1 degree C in the last 100 years. The numbers have been manipulated to fit the IPCC agenda. Michael Mann was defeated in Canadian court because he wouldn't provide the data to prove his "hockey stick graph" was not a fraud. 500 scientist from all over the world have sent a letter to the UN asking for a debate with their scientists regards their data. This is absolutely not settled science.

I support TCI. Fossil fuel companies have been too slow to research and develop alternative fuels and this could help that process. I also think that we have a lot to gain from the investment of funds that Vermont will receive. Developing alternative transportation modalities, improving the ability to live closer to town centers and helping Vermonters to see the benefits of driving more fuel efficient vehicles are critical and can be assisted by TCI.

I have problems with my property here Vt. Ticks, poison ivy, 7 invasive species of plants, 4 invasive species of bugs. And my state is going to loose much more now this coming spring to more things caused by climate change .
Also we lose ski and our maple syrup industry’s and tourism because people don’t want to go outside to get ticks and poison ivy. Try fly fishing near those areas lots of times the better the fishing the worse those two problems are ( ticks and poison ivy google the facts please) Fly poles and reels go for thousands of dollars and well to do tourists that own them want to stay in nice bed and and breakfasts and hotels. That bring money to this state along with restaurants.
We simply most charge as much as we can for gas and oil from fossil fuels. Those companies that sell gas and propane can start selling electricity and hydrogen to make up for the lost sales . In the end the private sector will thank us all , for saving their businesses and jobs.
If Killington sky area can have 51 EV charging stations. So can other private sector businesses it will bring more money in then lose money.
It’s simple math . Let’s use simple math

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

As a city energy committee volunteer and concerned citizen, I urge Vermont leaders to join the Transportation and Climate Initiative (TCI) instead of falling victim to short-term thinking. Regarding the latter, I respect those who fear any initiative that could potentially increase the daily expenses of people who are already finding it hard to make ends meet. However, if we don’t fervently harness the state government to explore opportunities--such as TCI--to address the climate crisis, people with fewer resources will be the primary victims of the resulting economic, health and safety-related suffering over the medium- to long-term timeframe.

Joining TCI will enable Vermont officials to continue to help design the program in a way that can potentially minimize the short-term effects on people with low incomes by, for example, making sure that the subsequent investments made possible by the logic-based carbon-related revenue are sound.

TCI is the single most important climate policy that Vermont can support in 2020 to help address Vermont’s largest source of climate pollution, i.e., transportation-related emissions. In addition to building upon the success of RGGI (Regional Greenhouse Gas Initiative), which was joined by Republican Governor Douglas, the collaborative TCI effort would align with Governor Scott's previously stated desire of not having Vermont act alone on climate issues.

Given that Vermont’s current climate-crisis-related plans, though positive, aren’t significant enough to address the scope of the climate problem, it is crucial that Vermont participate in the next phase of TCI and work collaboratively to harness the power inherent in this regional effort.

I’m a young person. I’m afraid of climate change. It’s time to do something.

The Transportation Climate Initiative (TCI) is Vermont’s chance to do just that: take a meaningful stance against climate change. It is great to see that Green Mountain Power will have 100% renewable energy in the next decade. This, in and of itself, however, is not enough. According to the TCI webinar hosted on December 17, 2019, 43% of the carbon dioxide emissions from the TCI region come from transportation. That is almost twice as much as from electrical power. Most Vermonters cannot afford an electric car, with or without subsidies from the government. That means the 43% of our emissions that come from transportation will continue to be emitted even if we have a carbon-free electrical grid.

But TCI is more than just a way to do something. It has the potential to be an effective policy. As per the executive summary, the TCI locks us into making a significant reduction in emissions. While these reduction goals are theoretically feasible without TCI, the initiative would eliminate any uncertainty. Given the volatility in our federal government, it is important that Vermont takes a stand and does not rely on federal policy to make these changes.

Additionally, by entering into TCI with an entire region of states, Vermont significantly reduces the potential for a harm to the economy. Look no further than the Regional Greenhouse Gas Initiative (RGGI) a similar cap-and-trade program which Vermont is already involved in. RGGI has already contributed 44,700 years of additional full-time employment, $5.7 billion in public health benefits, and saved customers a combined $773 million in energy bills, according to a report by economists at Analysis Group. RGGI, however, does not cover the emissions from transportation. As mentioned above, 43% of carbon emissions in the region come from transportation, making TCI an effective plan to address emissions not captured by RGGI.

As per the TCI Memorandum of Understanding (MOU), the program will invest its proceeds into a variety of programs such as “air quality, public health, resilience, and more affordable access to clean transportation alternatives.” Investments in these sectors all have the potential to positively impact the community and economy. Pollution from cars can contribute to asthma attacks and other health issues. Healthier people have lower medical bills and miss fewer workdays, which can help bolster Vermont’s economy.

All of this is not to say that TCI is perfect. There is a completely valid fear that gas companies will simply offload the increased cost of operation onto the consumers. The MOU mentions the importance of ensuring that the program benefits those who “disproportionately bear the costs of the current transportation system” or “impacts of vehicular pollution and climate change.” Still, without more concrete plans for benefitting these communities, I fear that TCI will only be an additional burden on those who are already struggling with climate change. As such, when Vermont agrees to sign on to TCI, it is critical to have a robust plan to help these communities, including provisions such as rebates and investments in public services. There are ways to make sure that TCI is equitable and given that equity is a listed priority (3b) of the MOU, I do not think fear of increased gas prices should be an impediment to joining TCI.

Like many of my peers at Middlebury College, I was drawn to Vermont for its beautiful scenery and landscape. Climate change has the potential to change our state forever through warmer weather and increased flooding. I hope that when I have children, they will have the opportunity to see Vermont as I see it: vibrant and full of natural beauty. TCI is Vermont’s chance to act on climate before it’s too late, protecting our state for the next generation.

According to the IPCC report from 2018, human activities have already resulted in a 1°C rise in global temperatures. They estimate that we have at most 10 years to get our act together. And by “get our act together” I mean make thoughtful, definitive changes to make sure we have our best chance at a livable future. As a young adult who will be around for that future regardless, I urge you to sign on to the Transportation and Climate Initiative. I don’t feel the need to list off facts about why climate change is an issue or about how transportation is Vermont’s biggest contributor to greenhouse gases. You already know this. There is no longer a question of whether we need to do something to combat climate change, but rather, what should be done?
In human time, 10 years can seem like a lot, but in government, 10 years is not much time at all. As it is, the TCI will not be enacted until January 2022. The truth of the matter is that time is of the essence and TCI has great potential. Its formation and structure have many similarities to the Regional Greenhouse Gas Initiative, in which Vermont has had great success. Since 2008, Vermont has received $21.4 million from RGGI and has been able to turn this into $95 million in energy savings for its people. It has also allowed Vermont to avoid more than 200,000 tons of CO2 in emissions. RGGI has given Vermont experience with cap-and-invest programs in cooperation with other states so that TCI will not be some experiment, but rather a proven system for success.
There are areas of TCI, however, that still need more consideration and solidification. Based on the proposed system of fuel suppliers purchasing allowances in TCI, it is understood that this cost will be passed on to consumers through roughly an 8-10 cent increase in price per gallon of gasoline. Because this will in many ways act as a regressive tax, it is important to understand and mitigate the impact it will have on low-income individuals in Vermont, specifically those living in rural areas that rely more heavily on cars. This could come through priority status in receiving rebates or increased rebates on electric vehicle purchases. Another option to consider is reducing gas prices for individuals that fall below a certain income and live in areas where their cars are their main form of transportation. This could be done through methods similar to gas promotions that many companies run where an input of a code or a sliding of a card can take 4-5 cents off of the gas price. Ultimately, while there is a valid concern that TCI will put a strain on lower income Vermonters, environmental destruction caused by climate change will have a greater impact on these individuals as well. Because of this, it is important that we look out for each other not only in the short term by considering ways to reduce financial burdens, but also in the long run by implemented systems like TCI to reduce the emissions that would lead to greater environmental destruction.
Additionally, just as with RGGI and Vermont’s investment in Efficiency Vermont, it will be important that the state invests the money received from TCI in an effective manner. Because of the success of Efficiency Vermont, I have full confidence in the state to repeat this behavior, but urge the state to look into sustainable transportation beyond just electric vehicles. While EVs will most likely play a big part in reducing transportation-based emissions, it will also be important to improve public transportation and increase bike paths and accessibility as alternative methods to achieving Vermont’s goals.
The jurisdictions involved with TCI will be remembered as pioneers in the fight for our future. And cooperation within this region of America will serve as a valuable reminder to our country and the world that together, we can achieve more. I urge Vermont to sign on to the Transportation and Climate Initiative and be a part of a cleaner, brighter future.

Thank you for your time.

Bibliography:
Gillis, Justin. “Would You Pay Higher Gas Prices to Slow the Climate Crisis?” The New York Times, 26 Feb. 2020.
IPCC. “Summary for Policymakers.” Global Warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty. World Meteorological Organization, Geneva, Switzerland, 2018.
RGGI, Inc. “The Investment of RGGI Proceeds in 2017.” The Regional Greenhouse Gas Initiative: An Initiative of the New England and Mid-Atlantic States of the US, 2019.