TCI Regional Policy Design Stakeholder Submissions

I attach the PDF file of my response since it failed to upload yesterday (5/28) after many attempts. Please attach this to my response from yesterday. Thanks.

You are doing good work on the modeling, thanks! I have misgivings about one particular section- 8% growth in VMT per decade, and would ask you to review that part better. The citation ("state predictions") was pretty vague. Most reading I've seen report that VMT needs to decrease, via walk/bike/bus/rail or density, and surely some TCI returns will be spent on making this happen (much like your concerns for state EV incentives and ZEV mandates being a feed back loop affecting fleet makeup). You should probably include a mechanism for higher share prices to offset lower VMT to maintain level funding for state programs.

To our concerned lawmakers,

I am a Massachusetts resident who has been closely following climate change issues over many years. I am a strong believer in the pricing of carbon to reflect its cost to our communities, our health and our economy. I applaud your efforts to develop a low-carbon transportation policy as an effective method to encourage innovative alternatives to fossil fuel in the transportation sector. To that end, it is critical that the policy include a price on carbon and that the price is high enough to effectively reduce emissions according to the latest science. However, I am also aware that past policies have sometimes unduly and unfairly burdened vulnerable communities. Therefore, I also support a policy that includes a strong component of social equity and that doesn't hurt rural or low/moderate income people.
Most importantly, I am thankful for the extraordinary effort of this group and of the bipartisan nature of the undertaking. It is a significant accomplishment in today's political climate to put aside party differences and come together to work on such an important issue.

Dr. Mary Rose Scozzafava

Please find attached comments from 16 environmental, health, scientific, transportation, and business organizations on the Reference Case assumptions presented on the May 23rd TCI webinar. Thank you.

I live in Shutesbury, MA and am working to pass carbon pollution fee and rebate legislation in Massachusetts. I am the chair of the Carbon Pollution Fee and Rebate Group of Climate Action Now and work as part of the Coalition for a Clean Energy Future, a group that is solely dedicated to passing carbon pollution pricing in MA. We are supporting Representative Jennifer Benson’s bill - H2810 “An Act to Promote Green Infrastructure and Reduce Carbon Emissions.”

We are also very much in support of TCI as an important piece of the climate change solution. It will be so helpful to develop regional plans like this one to price carbon pollution. As you contemplate how to put together the best possible plan, we would stress the importance of charging a significantly high price on carbon pollution and ramping that price up yearly until CO2 goals are met. Without such pricing the bill will not be sufficiently motivating to effect the needed changes in consumer spending. It is also crucial to structure the bill in such a way that it protects low- and moderate-income people from an unsupportable burden.

We also believe that it is imperative that multiple approaches to climate change are enacted in this time of crisis, not just one. The carbon pricing bill our organization supports in MA will cover emissions from heating, cooling, and powering buildings as well as from transportation, and it is supported by climate justice groups. As a fee and rebate bill, it is transparent and has low administrative costs. It’s structure is similar to the fee and rebate bill supported by Citizens Climate Lobby and recently introduced at the federal level. Thus, H2810 will serve as a model for the other states and will support the regional and federal effort.

H2810 is written to be completely compatible with TCI or other carbon pollution pricing proposals. It will subtract the price that TCI charges for a ton of pollution from the price charged by H2810. We need both TCI and H2810. We request that the TCI planning group acknowledge the importance of multiple approaches to cover multiple sources of carbon pollution and that the group advocate for state carbon bills, as well this regional one.

Thank you for all the good work you are doing planning for a regional TCI. We need the TCI bill as well as other local, state, regional, and federal action to successfully and swiftly address climate change, the most significant challenge of our time.

Alternative fuel vehicles, including hydrogen fuel cell electric vehicles, will play an important role in decreasing transportation CO2 emissions in the Northeast and Mid-Atlantic. Ensuring access to reliable and affordable hydrogen fueling infrastructure will play a key role in supporting consumer adoption of fuel cell electric vehicles, thereby reducing CO2.

To that end, TMNA supports efforts by TCI to ensure that the Reference Case accurately represents the need for this fueling infrastructure. NEMS’ fuel availability methodology is based on the historical relationship between vehicle stock and refueling stations. However, given the historical shortfall in hydrogen refueling stations, a Reference Case based on this historical relationship could lead to further underinvestment in hydrogen stations.

If improved to address this problem, NEMS could be used as a tool to assist in projecting how much overall hydrogen infrastructure will be needed to support a growing population of fuel cell vehicles in the TCI Regions, and this infrastructure requirement could be communicated to the states as part of investment planning in infrastructure. It should be noted, however, that hydrogen infrastructure works best when taking into account travel patterns, local vehicle adoption, station redundancy, etc., rather than distributed evenly across all regions. Industry can provide the best guidance for specific placement and number of hydrogen stations needed. It should also be noted that hydrogen stations currently require up to 2 years from planning to opening in order to find land, obtain permits, and complete construction.

I applaud the members of TCI for working together to price carbon on transportation. I believe that global warming is the most important problem to address right now, affecting, as it does, the continued existence of our planet and humans' ability to remain on it.
The price you put on carbon must be high enough to reduce emissions successfully, but it must include subsidies for low-income people and those in rural areas so that the burden of the higher fuel cost is equitably shared.
We need this carbon pricing to happen. Please do all you can to make it so. Thank you.

Can we look into instituting similar programs on federal, state, or local levels similar to what California is doing?
http://www.baaqmd.gov/~/media/files/communications-and-outreach/publications/news-releases/2019/ccfa_190501_2019_017-pdf.pdf?la=en
a sort of cash for clunkers type program for lower income citizens to encourage trading in ICE cars for plug ins.

Dear Governor Baker, Secretary Theoharides, and Secretary Pollack,

An uncommon alliance has emerged between five diverse Massachusetts organizations with business constituencies. We are united by a once-in-a-generation opportunity to modernize and decarbonize our transportation system.

We express strong support for the 18 recommendations developed by the Commission on the Future of Transportation. Specifically, we applaud the Transportation & Climate Initiative (TCI).

If properly structured, TCI could achieve several of our shared goals concurrently: mitigating greenhouse gas emissions from transportation, investing in much-needed public transit, and alleviating congestion. While TCI isn’t the solution to all of our transportation and climate problems, it is a proven and effective policy tool to move us toward a cleaner, less congested transportation system.

We would welcome the chance to speak with you. We also stand in service to help shape the program and build support for TCI among other stakeholders in Massachusetts and across the other TCI states.

Thank you for your early leadership in TCI. We are looking forward to working with your Administration to implement a strong, effective program.

Sincerely,

Robert Rio, Associated Industries of Massachusetts
Mindy Lubber, Ceres
Elizabeth Turnbull Henry, Environmental League of Massachusetts
JD Chesloff, Massachusetts Business Roundtable
Eileen McAnneny, Massachusetts Taxpayers Foundation