Traffic in DC by Morten M Wiken licensed under Creative Commons.

On December 21, the District of Columbia was among the first to sign a Memorandum of Understanding (MOU) committing to the Transportation Climate Initiative Program (TCI-P). Massachusetts, Connecticut, and Rhode Island also joined the initiative, which promises to put a price on transportation fuels that spew greenhouse gases into the atmosphere, with money raised going to clean transportation. As a co-benefit, regional air will be cleaner.

Yet controversy remains over just how much the TCI-P will help underserved and overburdened communities that have faced the brunt of air pollution and suffer from insufficient transit access.

What is TCI and how we got here?

TCI is a coalition of 3 Mid-Atlantic and Northern states along with DC—with the goal of encompassing an additional eight states, or even more—that aims to reduce carbon emissions within the transportation sector while improving accessibility and helping to create the clean air economy.

The program was inspired by the Regional Greenhouse Gas Initiative (RGGI), in which eleven northeastern states have banded together to cut down on emissions from power plants using a “cap and trade” system. That allows energy companies to essentially sell the right to pollute, but capped at a certain level, with the cap shrinking each year. RGGI states reduced emissions from power plants over 40% between 2005 and 2015, even while the economy grew.

Now the TCI wants to target the transportation sector, which accounts for nearly 40% of carbon emissions in the Northeast and Mid-Atlantic region.

Who’s in and who’s not in yet?

Beginning in 2023, DC and the three states that have signed on are expected to generate some $300 million annually in funds for clean transportation that could go toward electric vehicles, public transit, and improved bikeability and walkability. If all interested states do participate, funds could exceed $2 billion a year.

Eight states that helped to develop the TCI-P have not yet signed on to the Memorandum of Understanding (MOU), although they remain involved: Delaware, Maryland, New Jersey, New York, North Carolina, Pennsylvania, Vermont, and Virginia.

Increased gasoline prices—estimated at 5 to 9 cents per gallon according to the New York Times—is one reason many states have not yet joined. New Hampshire governor Christopher Sununu pulled the state out of the TCI-P, announcing he “would not force Granite Staters to pay more for their gas just to subsidize other states’ crumbling infrastructure.” Conversely, states such as New Jersey have also faced pressure from skeptical environmental justice organizations not to sign the agreement, according to the New York Times.

Still, more state signatures on the TCI-P may be just a matter of time. “Virginia looks forward to continuing to engage with TCI-P to develop regional solutions to reduce transportation pollution,” Amy Wight, Virginia’s Assistant Secretary of Transportation, told me.

Currently, though, Virginia and Maryland have not signed the initiative. Still, Ramon Palencia-Calvo, Deputy Executive Director of the Maryland League of Conservation Voters, explained that “as economies improve over the next few months”—coming out of the COVID-19 crisis—”we are confident that more states will be likely to sign on.”

What TCI-P could mean for the region

Reducing air pollution in communities already affected by respiratory conditions will be a critical part of a successful TCI-P. In the region, officials express a commitment to funneling TCI-P funds to underserved, overburdened communities. Virginia’s “commitment to inclusivity begins with our planning processes, which are informed by input from local environmental justice communities and other members of the public,” said Wight.

TCI-P will have clean air benefits estimated at saving about 1,000 lives annually in 2032 if fully implemented, according to a Harvard study that shows air quality benefits particularly to urban areas, including DC, with slightly higher benefits to Black and Hispanic communities. Historically overburdened communities already suffer disproportionately from asthma and other respiratory conditions.

For instance, the average African-American in DC is about twice as likely to suffer from asthma as the average white person, according to a study of potential benefits from an earlier clean-air program. Low-income adults and those without a high school degree also suffer disproportionately.

In the District, Wards 7 and 8 have asthma rates of around 17%, compared to rates of between 6 and 10% for more affluent wards. Children in the District below 18 years old also suffer asthma at nearly twice the rate of children nationwide. Urban and vulnerable communities thus stand to benefit most from TCI-P, particularly if emissions reductions are targeted where most needed.

Eleanor Fort, deputy director of the environmental and social-justice group Green for All, said using TCI-P funds for electrification of transportation was a critical piece of the puzzle in improving air quality so that, for instance, high emitting vehicles no longer travel through the most affected neighborhoods. Implementation must “make sure that the dirtiest, oldest diesel trucks and buses are targeted for transitioning to electric,” she said. Deployment of electric trucks and buses needs to be “in the communities that are already breathing the dirtiest air.”

Beyond the environmental benefits, TCI-P funds could help socially isolated communities that lack transportation options. They could jumpstart programs “to connect folks and communities to better jobs, to better educational opportunities, to better health clinics and hospitals,” as well as shopping and groceries, said Palencia-Calvo. Fort mentioned complete streets, separate bike lanes, and bus lanes as high priorities, as well as transit passes for low-income people. All of these could simultaneously improve transportation connections and contribute to cleaner air.

It will also be important to make sure that TCI-P money goes to quality jobs in the communities that need it most. “One big piece that was left out is strong labor standards and workforce protections,” said Fort. For instance, funding could help teach local mechanics to maintain electric buses.

TCI-P funding thus has the potential to jump-start accessible transportation to neighborhoods that need it most while helping clean the air in those same neighborhoods. Without oversight, though, the funds could be diverted to mostly serve affluent neighborhoods, as has happened previously. It’s a matter of continual monitoring and pressure from grassroots groups, along with good-faith efforts from jurisdictions to fulfill equity promises that so far exist largely in the realm of rhetoric.

On environmental justice, controversy lingers

Responding to pressure from grassroots environmental justice organizations about earlier versions of the agreement, the TCI-P added a provision that 35% of funds raised go to overburdened and underserved communities. The revised agreement also calls for advisory bodies from these communities to help decide how the money is spent.

Fort explained to me why her organization has flipped from opposing TCI-P to supporting it: “We were pleased to see a number of the equity provisions that Green for All and our community partners had advocated” added to the final agreement. The Maryland League of Conservation Voters also supports the TCI-P, although Palencia-Calvo and Fort agree on the need to keep pushing on environmental justice.

Importantly, 35% is a floor, not a ceiling. Because many states now have strong equity goals—at least on paper—jurisdictions might choose to spend substantially more than 35% to make up for decades of underinvestment in communities with a legacy of heavy pollution and inadequate transportation.

For instance, the moveDC transportation plan notes “disparate access to safe, affordable and efficient transportation” that has “disproportionately and negatively impacted environmental and health outcomes in our underserved communities.” The plan aspires “to overcome existing disparities and achieve transportation equity,” words that justify disproportionate allocation of TCI-P funds to burdened communities.

The TCI-P does include abundant opportunity for environmental justice initiatives. Palencia-Calvo pointed to TCI-P provisions for air monitoring in communities as “a very positive development that has not happened widely.” Gathering data, however, is just the first step; it will be critical to “not just monitor air quality but actually reduce pollution,” said Fort. The TCI-P opens a window for environmental justice programs, but taking advantage of this requires continuing commitment.

Not every environmental organization is on board. The national Sierra Club has backed out of support for the TCI-P, citing solidarity with environmental justice partners, lack of early public outreach to the most affected communities, and insufficient CO2 emission reductions, which are estimated at 26%.

Many grass-roots environmental justice organizations remain skeptical about the effectiveness of cap-and-trade systems, such as TCI-P, in which companies pay for the right to pollute, although with a shrinking allowance over time. “The position of the Climate Justice Alliance is that market mechanisms do not address the root causes of the climate crisis by keeping fossil fuels in the ground, they merely (at best) shift economic incentives a little bit to make it somewhat more expensive to pollute,” said Basiv Sen, Climate Policy Project Director at the Institute for Policy Studies.

He added that “Emissions trading systems such as TCI have a history of not addressing (and sometimes worsening) geographic disparities in emissions of co-pollutants such as particulate matter and NOx.” Sen cited a study of California cap-and-trade that overburdened communities often faced higher emissions after the state’s energy-based program went into effect.

Sen further noted that existing problems with energy-based cap-and-trade programs are likely to be replicated with transportation, “because highways, warehouses, trucking terminals, and other polluting transportation facilities are disproportionately located in close proximity to communities of color and low-wealth communities.” Because cap-and-trade reductions cover a wide geographic area, Sen explained, and because underserved communities have relatively little political power, pollution reductions are likely to take place in more affluent areas.

Finally, Sen expressed concern that too many TCI funds would go to fuel efficiency and electric vehicles, leaving out the most neglected Americans. “Only 12.5% of white households do not own any vehicles, compared to 22.4% of Latinx households and almost 33% of Black households,” he explained. In other words, TCI-P funds should be used for transit and other improvements with widespread public benefits, not individual vehicles. Instead of TCI-P, Sen therefore argued for quadrupling federal investment in public transportation.

Still, TCI-P’s MOU does call for major investment in overserved, unburdened communities as well as a strong voice by these communities in deciding how funds are actually spent. Moving forward, the question is how much the advisory bodies will represent the most vulnerable communities and how much actual power these bodies will have.

TCI-P will reduce air pollution, but the devil is in the details

Despite its endorsement, Green for All does have reservations about TCI-P, Fort explained, but thinks the likely benefits outweigh the problems. The basic issue is whether the advisory bodies would give real representation and real power to the communities most affected by air pollution and transportation poverty. “We’re going to pay attention to how states establish their equity advisory bodies,” said Fort. “We did get the clarification that a majority of seats on those bodies will be representing overburdened and underserved communities.” She also pointed to the need for stronger workforce and labor protections than are currently in the MOU.

Similarly, the Maryland League of Conservation Voters has endorsed TCI-P with reservations. “The MOU is a first step with, of course, room for improvement,” said Palencia-Calvo. “We also want to make sure that reduction in emissions takes place in those communities” disproportionately harmed by poor air quality. The crucial step to be worked out by the jurisdictions is the model rule, expected in 2021. Meanwhile, environmental justice groups need to keep pushing for equity and transparency, said Palencia-Calvo.

Ethan Goffman is an environmental and transit writer. A part-time teacher at Montgomery College, Ethan lives in Rockville, Maryland. His first book of poetry, Words for Things Left Unsaid, is just out, from Kelsay Books.





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