Planning sessions for the Transportation and Climate Initiative (TCI) are underway. I attended one public conference on it last month and another took place about a week ago. It’s important to get the design of this multi-state low-carbon transportation program right. A big emphasis right now is on ensuring equity: how can the program support the transportation needs of low-income and vulnerable populations, which is vital. Today, I submitted comments to the program managers, led by the Georgetown Climate Center, stressing not only equity — but also asking them to ensure that the cap-and-invest program leads to a price of carbon that approximates the social cost of carbon. Otherwise, the program would be all for naught.