TCI Regional Policy Design Stakeholder Submissions

The Transportation and Climate Initiative (TCI) seeks input from stakeholders regarding specific considerations that ought to be factored into the Model Rule and starting level for a regional cap, compliance structure, and stability mechanisms. As a Master of Public Health student in the Environmental Health Department at Boston University School of Public Health, I offer my comments and recommendations based on my understanding of Environmental Health, Environmental Justice communities, and Environmental Policy.

The TCI aims to implement a program with four main objectives: reduce greenhouse gas emissions, improve air quality and public health, enhance transportation options, and alleviate the burden environmental justice communities bear in regards to poor air quality and limited mobility. TCI states that transportation contributes to 40% of GHG emissions in the Northeast and Mid-Atlantic region; the proposed MOU is therefore appropriate to address issue of GHG emissions from the transportation sector, not only in an attempt to mitigate climate change but also to improve public health by reducing harmful co-pollutants like SO2 and NOx and increasing mobility in congested, urbanized areas. (See attachment for references)

STABILITY MECHANISMS
TCI seeks input on which factors it should consider when designing stability mechanisms for managing uncertainties in future emissions and allowance prices. The rate of reduction in emissions is critical to ensuring the sustainability of revenue needed for investment. Successful reduction from the fuel sector, and consequently fewer allowances being purchased, may cause a decline in generated revenue. The Model Rule must control the rate of reductions in order to sustain reliable revenue from fuel suppliers to invest in clean transportation alternatives. A dynamic allowance structure would provide additional stability in response to uncertainty in future emissions.
The Memorandum of Understanding (MOU) provides strategies to respond to unpredictable changes in market costs and demand in section “G. Stability Mechanisms”.

Suppliers trying to maximize profits will purchase allowances, bringing in more revenue for alternative transportation initiatives. As alternative transportation options become available, consumer demand for fuel drops. To maintain pressure on suppliers to continue reducing emissions, the cap will continue to drop over time. However, if this drop occurs too quickly, suppliers will not be inclined to buy allowances and revenues will fall. In addition to the CCR and ECR mechanisms proposed, TCI should implement a minimum cost for allowances that increases annually. This dynamic floor cost would compensate for expected long-term trends in lower demand for fuel. It also de-incentivizes industries to buy allowances, thus reducing emissions further, yet still maintains a revenue margin that allows TCI to reach its objectives. The Climate Law and Policy Project make similar recommendations in their comment under the “Accelerating Reductions” section. (See attachment for reference)

Predicting market trends and consumer behavior requires accurate models. These models can be very good, but are seldom completely accurate. To ensure the success of a TCI program, the Signatory Jurisdiction should consider additional strategies to maintain a controlled reduction rate.

COMPLIANCE
TCI also seeks input on how the compliance period should be structured to provide needed flexibility, while ensuring environmental integrity. As discussed above, the time period for compliance is closely interconnected to market dynamics. I suggest that the period ought to be stringent enough so the emissions are enforced in a reasonable time frame, though not so stringent to compromise the economy and solvency of suppliers. Too stringent and narrow of a compliance period may accelerate reductions and lead to a rapid drop in demand, which could destabilize the revenue structure needed for TCI to be successful. Allowing for offsets and allowance purchase should be permitted, but limited. The role of allowances and offsets should be primarily to control the rate of reduction, and encourage reduction rates to reflect those of development and utilization of alternative transportation measures.

I support the implementation of TCI. The initiative has four equally important objectives, three of which exist independent of the politics surrounding climate change. TCI not only reduces GHG, but also improves air quality and public health, reduces congestion and improves mobility in urban areas, and rightfully address environmental pollution issues that disproportionately burden Environmental Justice communities. All jurisdictions should support and participate in the Transportation Climate Initiative to protect individuals’ rights to a clean environment, ensure effective transportation for all, and promote health that is not burdened by the consumption behaviors of the “haves” against the “have nots”.

Respectfully,
Emily Hammel
Jamaica Plain, MA 02130
MPH Student, Boston University School of Public Health

My name is Shelby Grantham. I’d like to reduce my personal carbon footprint and help reduce climate change. But I am a senior resident of Norwich, VT, living alone seven miles outside the business center of Norwich. There is no public transportation out here except the school buses, which I am not allowed to ride. I wish I didn’t have to take my car into town to get groceries and do errands.
Transportation is Vermont’s highest source of carbon emissions. As an otherwise proud citizen of Vermont, I hope the state government sees fit to join the Transportation and Climate Initiative (TCI) that aims to develop within one year a regional policy to cap and reduce carbon emissions from transportation fuels through a cap-and-invest program that would also earn funds to help us tackle our high emissions and implement transportation solutions statewide.
Cap-and-invest programs are not new. Our Regional Greenhouse Gas Initiative (RGGI) instituted in 2008 has reduced carbon pollution and raised funds to invest in improved weatherization that makes Vermont homes warmer and more energy efficient. With TCI, we can do the same in the transportation sector.
Across the country, cap reduction scenarios have led to environmental, health, and economic benefits. Some Vermonters may see TCI as merely a gas tax, but frankly I’m willing to pay a little more at the pumps when the outcomes are so critical and the long-term benefits so far-reaching.
Being at the table with the other TCI states will allow us to craft a VT policy that is equitable and could help us create a climate in which we can all thrive.

I truly believe all transportation should be environmentally safer than gasoline run, but if we use hybrid vehicles as I do, then we need to create natural energy to fuel them as I do. If we don't then somewhere we are creating just as much pollution as we would if driving gasoline engines. Propane buses are another alternative that has done well in Acadia National Park in part because it takes many gasoline engines out of the park. Public transport is very much needed in the USA but it is not without its own problems.

Let the market place take a natural course. It is unfair to penalize the use of one product to subsidize another. Also electric and natural or propane vehicles are not paying a tax.

We can't survive without clean water, land and air. We must protect our resources at all costs.

Dear TCI Initiative:

This is not a new topic for me, stuck in traffic, and Neoliberal austerity preventing the public funding of serious mass transit alternatives. The solution is the Green New Deal at the National Level, because the sums your proposals put forth in the trading regime will not be enough to build out the missing rail connections which stopped with the Purple and Silver lines in the Metro Area.
So I support your work as a holding action and interim step, better than Governor Hogan's privatization plan to build more highway lanes. That's not what we need.

I've attached my essay and publication here at the Daily Kos: https://www.dailykos.com/stories/2018/9/8/1794256/-Maryland-Hogan-s-Highways-will-still-leave-us-Stuck-in-Traffic-on-the-road-to-Global-Warming

The full text of my essay from January of 2008, "A Citizen's Guide to the Missing Green Rail Visions for the Metro MD/DC Region" exceeds your submission file limit of 100 MB's so you will have to rely on the full text in the link above, which was kindly published at the Daily Kos.

Of course, we both know that the America of the Trumpian Republican Right, more traditional Republican Conservatives like Gov. Larry Hogan and the Clintonian-Biden Democratic Centrist fiscally cannot imagine anything of the scope needed to combat climate change/chaos in time, anything approaching even the scale needed to build an effective modern rail system.

To do that, we do need change beyond these self-imposed limits. That's why I am a Green New Deal Supporter and support Bernie Sanders in the coming elections.

Consider practical aspects as to each of the program elements and additional elements including:

Safe roads for biking and walking: Delineated bike lanes and sidewalks on one or both sides with traffic calming elements such as trees, traffic circles, etc. – see FHWA Traffic Calming course

More frequent and reliable public transportation: Shuttles on regular routes and schedules between neighborhoods and between neighborhoods and immediate destinations; extended busways and light rail in concert with shuttles to do medium length trips

Greater access to electric vehicles: Charging stations at regular gas stations

More equitable system: Penalties for/ laws to preclude idling such as in Philadelphia; surcharges for passenger car commuting; higher license fees for passenger cars; incentives for small and electric car purchases; incentives/disincentives for trip consolidation and vehicles with single person; remove tolls for electric and multi passenger vehicles and increase tolls for other traffic

Cleaner transportation options for everyone in the region: All electric/natural gas buses and rail; fully developed and connected networks with functional interface between modes.

Additional Elements:

ITS – Intelligent Transportation Systems e.g. smart signals, etc.

The following comments are on behalf of the Addison County Vermont Regional Planning Commission’s Transportation Advisory Committee to offer public input on the draft Transportation Climate Initiative (TCI) Memorandum of Understanding (MOU) for a regional program to establish a cap on global warming pollution from transportation fuels. We support the goal of limiting greenhouse gas emissions from the transportation sector, and offer the following comments to improve the draft MOU.

In apportioning the regional cap to TCI jurisdictions, the final MOU must take into account existing efforts to curb transportation related greenhouse gas emissions. For example, jurisdictions that already invest heavily in mass transit should not be penalized for prior investments that have reduced emissions.

Section 3 of the MOU discussing Investments and Equity lacks detail. The costs of the program are fairly clear, but the benefits, which should be spelled out in this section, are still vague. It will be extremely important in building political support for the MOU that constituents have a better idea of how the revenue raised will make an impact in their lives.

To that point, it is very important to our constituents that efforts be made to mitigate the impacts of the TCI on low-income populations in rural areas. In rural areas like Addison County, our poorest community members often live far from populations centers. In purchasing vehicles, they rely upon second-hand cars and trucks, and the availability of fuel-efficient vehicles at a low price point in that market is constrained. Some of the revenue raised by the TCI should go to assist this population in transitioning to low emission vehicles and to offset the economic hardship they will face when the cost of fuel increases.

The draft MOU lacks detail on how a Participating Jurisdiction would leave the TCI (Section 5B) and what would happen to allowances auctioned on their behalf. Would those allowances still be honored as in Section 2J – “Participating Jurisdictions shall accept allowances sold or originated in other Participating Jurisdictions”?

We thank you for the opportunity to comment on the draft MOU.

Please do not enact this policy. It’s nothing more than a tax to fund electric vehicles.