DEC, DOT and NYSERDA continue to seek input regarding New York State’s potential participation in a regional program developed by the Transportation and Climate Initiative (TCI), a regional collaboration of Northeast and Mid-Atlantic states and the District of Columbia that seeks to reduce carbon emissions from the transportation sector and develop the clean energy economy while improving transportation systems.

The TCI is looking for public comments on their Draft Memorandum of Understanding to implement a regional cap and invest program. The details of the program are outlined here. In summary, the program will create a cap and invest system to encourage the electrification of vehicle fleets and discourage use of fossil-fuel fueled motor vehicles.

The draft framework states participants, “may choose to pursue complementary policies and programs to further enable GHG emission reductions from transportation.” This is the only reference to active transportation in the draft summary document.

We believe a reduction in total vehicle miles traveled, e.g., how many miles we collectively travel per year, is the best metric for measuring outcomes of a climate mitigation program. Under the proposed cap-and-invest program, only fossil fuel combustion energy consumption will be monitored, allowing unrestricted consumption of electric vehicle energy. As we’ve written previously, unrestricted electric vehicle use will likely result in increased vehicle miles traveled, thus amplifying the negative social, physical and economic effects of cars, specifically congestion, obesity and urban areas designed solely to accommodate cars.

Though electrifying our fleet applies to reducing emissions in the transportation sector, we must also build complete streets to ensure the safety, comfort and efficacy of all modes. The world’s best thinkers on this subject have long ago moved beyond the personal motor vehicle and are instead devising transportation strategies that right-size transportation options by embracing micromobility, public transit and active transportation, and encouraging human use of our streets once again.

We encourage you to weigh in on the plan. Please provide your feedback here.

Questions can be directed to