TCI Regional Policy Design Stakeholder Submissions

We support the Transportation and Climate Initiative. When we heard you had received mostly negative feedback, we wanted to write and assure you there are plenty of us out that that appreciate your courageous lead on this issue despite the vocal opposition. It's time we take this emergency seriously.
Alison Leschen and Scott Lindell
Falmouth

TCI seems to be an effective way to help us reduce Greenhouse Gas Emissions while providing important funds to invest in clean transportation initiatives.

Please be sensible and responsible and protect the underserved and overburdened communities that would be
affected by this. Also, please include state advisory boards and allow for community involvement and review.
This is a very important initiative and must be carried out with care. Thank you.

A cap on carbon emissions of at least 25% by 2032
An increase in the minimum investment in overburdened and underserved communities (>35%)
Request that investments be put towards active transportation like better sidewalks, bicycle infrastructure, and high quality public transit

“…design a regional low-carbon transportation policy proposal that would cap and reduce carbon emissions from the combustion of transportation fuels through a cap-and-invest program or other pricing mechanism… [and]… to complete the policy development process within one year, after which each jurisdiction will decide whether to adopt and implement the policy.”

As detailed in the attached comments, the primary objective that TCI should strive to achieve is to reduce transportation emissions as much as possible (meaning a 25% reduction from the Reference Case, instead of a 20 or 22% reduction which are also under consideration). To accomplish this, TCI should aim for the adoption of as high a variable cost to driving and parking as feasible, enabled politically by converting fixed and hidden driving and parking costs to usage pricing, where total costs to most drivers will actually go down. Incentives applied at the level of the individual driver are critical to meeting TCI’s carbon reduction goal. A transportation re-pricing policy bundle is specified in the submission and then modeled. It was found to reduce year-2030 vehicle miles traveled and carbon emissions by 23.2%. Polling results on transportation re-pricing were also presented and it was found to be more acceptable to the public (including those in the Northeast) than hiking fuel taxes, even if fuel tax revenues are refunded through other tax rebates.

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

TCI could be well served to consider climate implications of a range of currently utilized U.S. transportation fuels and fuel switch solutions, based on Department of Energy, Department of Transportation, EPA and California longstanding efforts to reduce transportation emissions and reduce greenhouse gas emissions from transportation. In the absence of metrics, the solutions proposed or modeled may be high cost and low impact. If TCI would like help there are a range of technologies that could be considered that could reduce emissions far greater than 19% over a decade. With transportation carbon targeting solutions looking at bang-for-the-buck or taking a greenhouse gas reduction as a metric strategy, deeper cuts could be seen on a faster timescale. Public sources of information from California Low Carbon Fuel Standard is a good peer-state guide. The federal Renewable Fuel Standard is the other long evaluated public tool tracking real metrics. Consider goal of tracking and reducing transportation greenhouse gas emissions with a wider all hands on deck approach rather than limited strategies and see if a TCI model can seek larger benefit for the public good. Consider a policy that has a larger emissions reduction strategy in the region such as 25% and continual evaluation. TCI materials miss a lot of science of transportation emission studies and additional advisors could help the TCI team. Clean transportation investment options seem pretty limited and could use peer review from state clean transportation programs. In Virginia our clean fuel program at Virginia Clean Cities reduces 175,000,000 tons annually and TCI should revisit 2032 goals of 62 total possible million metric tons reduced in 25% scenario to see if this regulatory action could meet or far exceed current single state voluntary annual emission reductions programs - considering the baseline of clean fuel programs goals could be increased with full coordination with DOT and Energy agencies or checking back at assumptions.