Trenton, NJ — As a probable December decision deadline for northeast governors approaches, opposition from environmental justice (EJ), environmental and social justice groups in New Jersey and around the country continues to expand against the regional Transportation and Climate Initiative (TCI). TCI is currently being proposed by the Georgetown Climate Center for thirteen states in the Northeast and the District of Columbia to create a regional cap and trade system for the transportation sector that will not ensure emissions reductions in EJ communities and will act as a regressive tax on transportation fuel.

Several prominent groups including the Midwest Environmental Justice Network, WE ACT for Environmental Justice in New York City, the Environmental Justice and Health Alliance for Chemical Policy Reform and several others released a letter (see attached or linked) prepared by the New Jersey Environmental Justice Alliance (NJEJA) that states strong opposition to TCI. It notes TCI focuses on carbon trading while relegating EJ and equity to “‘complimentary” status.

The letter points out that TCI does not guarantee emissions reductions in EJ communities and states that “EJ advocates have consistently and persistently requested that the carbon trading system be replaced with policies that ensure such reductions while fighting climate change. However, these suggestions have fallen on deaf ears.”

NJEJA is joined by the Ironbound Community Corporation and Clean Water Action in leading the opposition to New Jersey joining TCI. The NAACP New Jersey State Conference, Teamsters Local 469, NJ Citizen Action, UU Faith Action NJ, and Westfield 2020 have also joined the growing chorus of concern over TCI.

The opposition in New Jersey and nationally is led by EJ communities that critique TCI for not guaranteeing life saving emissions reductions in the communities that need it most. At a time of growing concern over the multiple impacts from COVID on the health and economic well being of the most overburdened and vulnerable, Of Color and low income communities, EJ groups believe their constituents cannot afford an investment in a strategy like TCI that falls far short of both environmental as well as equity and justice goals.

A critical EJ concern with TCI is that it uses a framework, carbon-trading, that does not guarantee emissions reductions in the communities with the most pollution. Market mechanisms like TCI, that allow for diffuse emissions reductions across the region mean that pollution, like diesel emissions, that are both a climate change inducing pollutant and deadly for residents, are not necessarily reduced at the locations that suffer from the highest pollution levels. There are no guaranteed emissions reductions in the places that need it most such as EJ communities already overburdened with pollution. Our state and region need a climate mitigation policy for mobile sources that centers EJ and equity while reducing GHG emissions.

TCI’s proposed cap and trade framework will also lead to an increase in fuel prices that represent a regressive tax on low and moderate-income households. These increases will be an additional burden for those communities that are already suffering economic hardships and living with the greatest pollution burden. It is also true that the communities who are the least responsible for transportation emissions are often the ones who benefit insufficiently from climate mitigation policies that are carbon-centric and that focus primarily on investments in electric cars. Subsidizing Teslas for the middle and upper class on the backs of poor, working class and Of Color communities while they choke on deadly diesel is not only unfair, it lacks a truly transformative vision of what our transportation sector could be . We need a more comprehensive and justice centered approach that can deliver better transportation and public transit access while targeting health harming transportation emissions and climate mitigation in EJ communities. New Jersey has already led the way on advancing innovative approaches to EJ with the recently passed Environmental Justice legislation (S232) and the signing of the Zero Emissions MHDV MOU. Our State can continue building this legacy in partnership with frontline communities by turning away from TCI towards a more just and equitable transportation climate strategy.

“At a time when many in our nation are determined to make a positive difference on racial and social justice issues we need to ensure that climate change mitigation policy prioritizes these matters while fighting climate change. TCI fails this test,” stated Nicky Sheats, Esq., Ph.D., NJEJA; Director, Center for the Urban Environment of the John S. Watson Institute for Public Policy at Thomas Edison State University.

“The only two children in my family who have asthma both lived along a truck route in the port-adjacent Ironbound neighborhood in Newark”, said Melissa Miles, Executive Director of the New Jersey Environmental Justice Alliance, a steering committee member of the Coalition for Healthy Ports. “Every year we counted trucks on our corner as part of a community initiative, while also being exposed to heavy emissions from off-road sources like freight trains. New Jersey needs to address the most serious contributors to transportation emissions like trucks and trains, not just passenger vehicles which are the low hanging fruit.”

“I know what it means to live in a community where we can’t breathe,” stated Kim Gaddy, NJ Environmental Justice Organizer, Clean Water Action, a 4th generation Newarker and mother of 3 asthmatic children who lives near the port. “Trucks, busses, trains and the Port are a bigger problem than cars.”

“Now is a critical time for New Jersey to be a leader on environmental justice by turning away from false solutions like TCI and advancing much more ambitious and just transportation climate initiatives.” Ana Baptista, PhD, NJEJA

“Study after study confirms the fears our communities have of TCI being a false solution that doesn’t even begin to address transportation or climate change in meaningful ways. When we need bold, visionary action, TCI is barely a whimper. New Jersey must lead the way to real solutions that reduce emissions at source, include communities at every step and actually help New Jersey reach our climate targets during this crucial time,” said Maria Lopez-Nunez, Ironbound Community Corporation.


Environmental Justice Organizations Oppose the Transportation and Climate Initiative
Reducing emissions of air pollutants in environmental justice (EJ) communities, i.e. communities
Of Color and low-income communities, can be a matter of life and death since these
communities often suffer from elevated levels of pollution. As our society develops policies to
save the earth from climate change we should ensure they are crafted in a way that will also help
save EJ communities from local pollution. This means climate change mitigation policy should
guarantee air pollution emissions reductions in EJ communities. By doing so the amount of air
pollutants released simultaneously with greenhouse gases (GHG) that have detrimental local
health impacts would also be decreased. The Transportation and Climate Initiative (TCI), a
northeastern multi-state program that is being proposed to reduce GHG emissions from mobile
sources, does not accomplish this imperative. For this and several other reasons, the undersigned
EJ organizations want to make it clear that we oppose TCI. We join other EJ organizations in the
northeast and around the country, including the Climate Justice Alliance, in this opposition.
The primary reason TCI does not guarantee emissions reductions in EJ communities is because it
has a carbon trading system as its core policy. EJ advocates have consistently and persistently
requested that the carbon trading system be replaced with policies that ensure such reductions
while fighting climate change. However, these suggestions have fallen on deaf ears. We also
believe that TCI will not drive more ambitious climate mitigation goals that would at least make
the significant reduction of health harming air pollutants that are sorely needed in EJ and
overburdened communities somewhat more likely.

Over the years TCI has had many discussions and performed extensive modeling that have
produced the above-mentioned carbon trading system but have yet to yield any fully developed
EJ and equity policies. The initiative promises to address EJ and equity through
“complimentary” policies that will be developed by the states, eventually. But from an EJ, equity
and racial justice perspective this is not good enough. Addressing EJ and equity is too important
to be relegated to a “complimentary” status. Policies designed to yield emissions reductions in EJ
communities while decreasing GHG emissions should be at the center of a mobile source climate
mitigation program. These communities should not have to settle for whatever incidental
reductions are achieved by carbon trading or reductions that are highly uncertain because they
are to be produced by policies that have not been fully developed. We owe these communities
more. This is true especially at a time when our society is ready to move forward on racial justice
issues and especially because EJ communities contribute relatively less to this global problem
but experience relatively more of its negative consequences. The northeast region and the nation
need to move away from TCI and towards a strategy that will bring the progressive community
together instead of splitting it part. An Initiative must be created that intentionally maximizes the
number of lives saved and illnesses reduced in EJ communities while it reduces mobile GHG
emissions. EJ communities that have been mistreated in so many ways for so many years deserve
at least this much attention and much, much more; certainly, more than TCI is offering.

We oppose TCI.

Environmental Justice Organizations
Center for Earth, Energy and Democracy (Minneapolis)
Deep South Center for Environmental Justice (New Orleans)
Environmental Justice Health Alliance for Chemical Policy Reform (National)
Little Village Environmental Justice Organization (Chicago)
Los Jardines Institute (New Mexico)
Midwest Environmental Justice Network
New Jersey Environmental Justice Alliance
Michigan Environmental Justice Coalition
ReGenesis Community Development Corporation (South Carolina)
WE ACT for Environmental Justice (New York City)
Center for the Urban Environment of the John S. Watson Institute for Public Policy at Thomas
Edison State University
Tishman Environment and Design Center, The New School
December 3, 2020

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