TCI Regional Policy Design Stakeholder Submissions

First, I'm very pleased that you are implementing this initiative and that Governor Baker is onboard with the idea.

1. Offsets -- the offsets should be very strictly defined and regulated. E.g. when I fly to Canada I can buy a CO2 offset for only about $6, but a researcher at St. Mary's University in Halifax claims this offset is a lie. It can't be guaranteed in the long term to really offset the emissions. The offsets clause sounds like a potentially huge loophole. I'm sure I'm not the only one saying this. Who judges what's a real offset?

2. Stability Mechanisms -- I like that there is a feedback mechanism either way -- if costs go too high or if costs are unexpectedly low. However, I think there should be language that allows for having more ambition before 2032 in terms of how much we're willing to pay for reductions and how high our reductions must be. 25% by 2032 may seem good in today's political climate in the U.S. But right now leaders in Denmark are being criticized for planning overall reductions of 60% by 2030 IIRC, criticized for that being not ambitious enough that is. In five years, if the TCI is working well, I'd hope political will would exist for more realistic targets. By more realistic I mean more realistic in terms of what is necessary to avert climate crisis, i.e. higher reduction targets. The news from the scientists both about climate CO2 sensitivity and about its dangerous effects seems only to be getting worse each passing year and never better.

3. Maybe I'm feeling spiteful, thinking particularly about Governor Sununu, but I'd like it, if possible, if we could be good to those in the TCI with us and bad to those not. E.g. if Rhode Island is in, let's make Providence a good commuting community for jobs in Boston and make Nashua less so.

4. Compliance period - I'd defer to those experienced with the electric power supplier cap and trade programs, but it strikes me that three years is a long time out for the first trading/compliance date. People are talking about 2030 as a critical target date for reducing our emissions significantly. 2025 would be the first date where we really see this initiative acting, if I'm understanding correctly. That leaves a very narrow window if the initiative doesn't immediately have much effect. People who are critical about cap and trade/invest programs tend to be critical about them having caps that are too high to bring about much effect. With electric power emission cap and trade we got a bit of a gift from natural gas supply, right? Transportation may not get such a gift, so this program might have to be more rigorous to do as well.

Regards and thanks again for this plan,
Mike Small

We need to act now on Carbon emissions to ensure a livable planet for our children. Massachusetts has always been a progressive leader and we should continue to do so by joining this coalition, we owe it to the next generation!

We can cut poverty and pollution at the same time. We urge you to move forward with a regional program that prioritizes the needs of communities overburdened with pollution and underserved in mobility options.

Creating a strong initiative that reduces transportation pollution, including smog and greenhouse gases, as quickly as possible is vital to public health, a resilient economy and a sustainable environment. Copying from the successful Regional Greenhouse Gas Initiative on power plants to cap transportation emissions and invest in communities and clean resilient infrastructure is one promising approach. Improved mass transit and inter-city rail is also essential since we cannot solve congestion simply by building more roads or lanes. Population growth will add further pressure to this issue. Electric buses are already more cost-effective, not to mention healthier, cleaner and quieter, than diesel ones; a strong push to procure only electric buses going forward is a big winner. Electric vehicles are widely forecast to be price competitive (without incentives) with combustion ones within the next 4 to 5 years. We need to more quickly get the charging infrastructure underway to support the likely surge in demand for EVs.

TCI is not nearly ambitious enough given the scale of the climate emergency. However, if specific policies are clearly defined by TCI it will provide a start in the right direction. Given that Vermont gets all of our fossil fuels from other states, we should clearly join TCI, but must create policy that ensures equity for lower-income and rural Vermonters.

Vermont TCI should include:

-A mechanism to mitigate the impacts of TCI on low-income populations in rural areas with acknolwedgment that rural consumers must use more fossil fuels in order to get to work and commerce centers

-Higher EV and renewable energy rebates for low-income residents

-Increased weatherization funding for low and moderate income Vermonters and access to renewable energy sources via community solar development

-Development of safe roads for biking and walking, and focus on smart growth centers

-Investment in agricultural and natural responses to the climate emergency including carbon farming and forest health, acknowledging the impact of higher fuel rates on farmers, sugarmakers and others who work in agricultural and forestry professions


-Investment of TCI funds in clean energy, energy efficiency, and more robust public transportation to expand career opportunities and make jobs more accessible. The Vermont Green New Deal aims to do this, and is an essential part of all Vermont climate legislation.

Transportation is the country’s and region’s leading source of carbon emissions.
Stop listening to the fossil fools and get with it!
I'm a crossing and I'm tired of breathing obnoxious truck exhaust for 45 minutes straight.

I strongly urge the State of Maine to remove itself from the TCI.
Poor, rural, hard working Mainers will be hit especially hard.
All taxes must originate in the Maine House of Representatives.
Any fees, fines, or assessments are actually a hidden tax and require legislative approval.
Maine's involvement in the TCI is contrary to Maine law.