Cap and Trade Program Implementation
As previously mentioned, three dedicated programs support the Cap and Trade opportunities for transit: the LCTOP, the TIRCP, and the AHSCP. Since the enactment of the Budget Act, the Association has been working to influence the rollout of each of these programs. To focus our efforts, In July 2014, the Association’s Executive Committee established the Subcommittee on Cap and Trade (Subcommittee), created to participate in, and respond to, the development of guidelines by state agencies as required by SB 862. The Association’s Subcommittee consists of representatives from 14 transit agencies throughout the state, including: San Francisco Municipal Transportation Agency; Southern California Regional Rail Authority (Metrolink); Solano Transportation Authority; San Mateo County Transit District; Santa Cruz Metropolitan Transit District; Monterey-Salinas Transit; Santa Clara Valley Transportation Authority; Bay Area Rapid Transit; Orange County Transportation Authority; Sacramento Regional Transit District; Capitol Corridor Joint Powers Board (Capitol Corridor); Los Angeles County Metropolitan Transportation Authority; Antelope Valley Transit Authority; and San Diego Metropolitan Transit System.
As part of its efforts to influence the outcome of the Cap and Trade programs, the Association’s Subcommittee on Cap and Trade engaged ICF International to develop three Memos related to Cap and Trade, specifically the way in which transit agencies identify good GHG-reducing projects and proposed methodologies for quantifying the emissions reductions.
- Task 1 Memo – Identification of Public Transit Projects Eligible for State Cap and Trade Funds
- Task 2 Memo – Document Justification for and Revisions Needed to APTA’s 2009 Methodology
- Task 3 Memo – Develop and Document Possible Centralized GHG Evaluation Methodology
Each of the above Memos is designed to assist the Association as it continues to engage with CARB on how best to quantify GHG reductions from transit projects. CARB is still developing its methodologies for both the LCTOP and the TIRCP. While the AHSCP has selected a tool for measuring reductions, we feel there are refinements that could be made.
On January 2015, the Association hosted a webinar with ICF for members of the Association to provide a status update on each of the programs and to give ICF an opportunity to present the three Memos.
Where do we go from here?
In February 2015, the last of the guidelines for the three programs was finalized for the coming year. Throughout the guideline develop process, the administering agencies (CARB, CalSTA, Caltrans, SGC) have stated that these initial guidelines will be subject to much revision as the programs move forward. Essentially, FY 2014-15 was a year of learning. This is why it is important that the Association stay engaged. Our members need to document their experiences with each of the programs as they apply for funding. This will provide Association staff with the information they need to advocate for changes to the guidelines when the revision process begins.
Additionally, the Association must continue to make the case for more funding from Cap and Trade for transit. As we all would agree, 5 percent on a formula program is insufficient as transit agencies work to implement Sustainable Communities Strategies. The Association and its members need to work grow the LCTOP as the Cap and Trade program grows. Finally, the Association may need to run cleanup legislation to address the exclusion of bus operators as applicants in the TIRCP under SB 862, as well as issues related to the expenditure of funds (e.g. Letters of No Prejudice).
For detailed program information, see "Cap and Trade Program Information."