5/7/2021 |
Alison |
Bennett |
Saint Mark Presbyterian Church |
Potomac |
Maryland |
I am a Presbyterian elder who cares deeply for God’s creation. A stable climate is the most fundamental determinant of health. With our pollution, we are contributing to more and earlier deaths... read more I am a Presbyterian elder who cares deeply for God’s creation. A stable climate is the most fundamental determinant of health. With our pollution, we are contributing to more and earlier deaths and disability. Transportation is the biggest source of greenhouse gas emissions in Virginia and the region, as well as dangerous particulates that cause health problems like asthma. We have not only a health issue, but a moral issue because particulate emissions especially impact people living near major roads, which are often lower income and minority communities. We need a clean transportation system, and a clean-energy economy. Because I live just across the river, everything Virginia does to affect its air affects me.
TCI-P will greatly help Virginia and the region do this. I support a strong TCI-P Model Rule that (1) ensures meaningful climate action to address Virginia's largest driver of our climate crisis, (2) directs significant investments to correcting historic inequities in overburdened and underserved communities; and (3) affords Virginia the opportunity for a cleaner, healthier transportation system. |
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5/7/2021 |
Phoebe |
Antrim |
Richmond Friends Meeting |
Henrico county |
Virginia |
The TCI-P Model Rule should should include a minimum investment to ensure an expanded proportion of investments for the. Underserved and overburdened populations.
The Rule should... read more The TCI-P Model Rule should should include a minimum investment to ensure an expanded proportion of investments for the. Underserved and overburdened populations.
The Rule should mandate integration of air quality comments across Virginia. Finally, the Rule should ensure an effective role for Virginia’s Equity Advisory Body.
Sincerely,
Phoebe Antrim |
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5/7/2021 |
Cindy |
Speas |
Lewinsville Faith in Action |
Falls Church |
Virginia |
I am a Fairfax County resident working to reduce greenhouse gas emissions through the Countywide Energy and Climate Action Plan. It is critical that we all urgently work to reduce the biggest... read more I am a Fairfax County resident working to reduce greenhouse gas emissions through the Countywide Energy and Climate Action Plan. It is critical that we all urgently work to reduce the biggest source of GHG emissions in our Commonwealth – transportation. TCI-P will help our county and all of Virginia improve air quality near roads and highways, lower health problems like asthma, lower healthcare costs and generate revenue for many environmental initiatives! This will particularly correct historic inequities in overburdened and underserved communities that are more greatly impacted by environmental pollution. We must have a vision to move toward a future using clean, renewable energy. TCI-P can help us do that. |
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5/7/2021 |
Joanne |
Ivancic |
Advanced Biofuels USA |
Frederick |
Maryland |
Comments from Advanced Biofuels US
on the
Transportation & Climate Initiative (TCI)
TRANSPORTATION AND CLIMATE INITIATIVE PROGRAM DRAFT Model Rule
Having... read more Comments from Advanced Biofuels US
on the
Transportation & Climate Initiative (TCI)
TRANSPORTATION AND CLIMATE INITIATIVE PROGRAM DRAFT Model Rule
Having participated in many of the in-person and online meetings and stakeholder events related to developing the Transportation and Climate Initiative Program, Advanced Biofuels USA is pleased to see that the proposed TCI-P emissions calculations focus on the fossil fuel component of fuel in the Emissions and Allowance Tracking System (EATS)
(Emissions and Allowance Tracking System (EATS). A system comprised of the Allowance Tracking Sub-system, by which the REGULATORY AGENCY or its agent records allocations, deductions, and transfers of CO2 allowances under the TCI-P, and the Emissions Tracking Sub-system, by which a JURISDICTION fuel supplier or reporting-only entity reports CO2 emissions from the combustion of fossil fuel and other data as required in Subparts XX-8 and XX-9.)
We note that the initial focus is on-road fuel use; however, the immediate benefits of transitioning away from fossil power for existing planes, trains, automobiles and equipment can be realized by expanding this approach and the limited application in the TCI-P should not only be retained, but broadened.
The TCI-P clearly recognizes that use of non-fossil fuels should be encouraged as a beneficial substitute for fossil fuels in transportation. They are the quickest, least expensive, most effective way to reduce GHG emissions and other pollution for the greatest number of people and with the most immediate environmental justice impact.
However, the TCI-P only covers “motor gasoline or on-road diesel fuel” defined as:
Motor gasoline. Any fuel, except for aviation gasoline, that:
(1) Is commonly or commercially known as gasoline, including blendstocks CBOB and RBOB;
(2) Is intended or used to power a vehicle or engine designed to operate on gasoline; or
(3) Conforms to the specifications of ASTM D4814 and is made available for use in a vehicle or engine designed to operate on gasoline
On-road diesel fuel. Any fuel that is delivered to a filling station for use in a diesel-powered highway vehicle and:
(1) Is commonly or commercially known as diesel fuel;
(2) Is intended or used to power a vehicle or engine that is designed to operate using diesel fuel; or
(3) Conforms to the specifications of ASTM D975 and is made available for use in a vehicle or engine designed to operate using diesel fuel.
It is especially egregious that the TCI-P specifically excludes “aviation gasoline” defined as “A complex mixture of relatively volatile hydrocarbons, with or without small quantities of additives, blended to form a fuel suitable for use in aviation reciprocating engines and meeting ASTM Specification D910 or Military Specification MIL-G-5572.” Not only should D910 fuel be included in the TCI-P to encourage transition to renewable fuel, but also because it is a leaded fuel (for which there exist alternatives). Environmental justice benefits would also accrue to communities located near airfields that sell and use this fuel to prevent lead poisoning.
In addition, there is no mention of aviation fuel that meets the standard of ASTM D1655-20d, the Standard Specification for Aviation Turbine Fuels. With many airports both large and small in the region, it seems that incentives to convert away from fossil fuel for air transport should also be a part of the TCI-P.
Another sector left out of this program is the agricultural sector. Diesel-powered farming equipment should not be overlooked as a source of GHG emissions. The carbon footprint of farming could be reduced with use of renewable fuels such as drop-in renewable diesel, biodiesel blends and renewable natural gas.
It appears that fossil diesel use in trains has also been omitted from this program. Some train systems are in the process of converting to renewable fuel. Such conversion should also be encouraged by the TCI-P, especially for the non-electric commuter train systems.
In addition, use of fossil compressed natural gas and liquid natural gas are omitted from the program and should be included.
Of greater import, marine/maritime fuels are also left out of this program. For a region that is situated along the East Coast of the US, transition to renewable fuels for the shipping sector should be encouraged as a way to also motivate using renewable fuels to comply with International Maritime Organization standards.
Also, the region has space launch facilities and the greenhouse gas emissions from fossil fuel used in missiles and rockets should also be included in the TCI-P in order to provide incentives for transition to renewable or otherwise low GHG emission missile/rocket fuels. Investment in research conducted in this area would benefit from recognition of the need for this sector to transition away from fossil fuel.
In addition, it might be a good idea to use a term like “non-fossil-derived fuel” instead of “biomass-derived”. For example, in “Biomass-derived content as a percent (i.e., percent of the total fuel volume that is not derived from any fossil fuel).” This would accommodate future fuels that are made from recycled carbon such as industrial waste gases and from green/renewable hydrogen and captured carbon dioxide or other non-biomass substances.
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21 0507 TCI comments FINAL.pdf |
5/7/2021 |
JOHN |
CRUICKSHANK |
Sierra Club |
EARLYSVILLE |
Virginia |
We must reduce greenhouse gas emissions. We must reduce greenhouse gas emissions. |
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5/7/2021 |
Margaret |
Arbogast |
Peaked Mountain Farm |
Harrisonburg |
Virginia |
Virginia cannot afford to join the TCI. The cost to the energy sector will trickle down and impact all Virginians using fuel including farmers who produce your food. Thank you, Margaret Arbogast... Virginia cannot afford to join the TCI. The cost to the energy sector will trickle down and impact all Virginians using fuel including farmers who produce your food. Thank you, Margaret Arbogast |
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5/7/2021 |
Dan |
Bowerson |
Alliance for Automotive Innovation |
Southfield |
Michigan |
Please find attached supportive comments for the TCI-P Model Rule from the Alliance for Automotive Innovation. Please find attached supportive comments for the TCI-P Model Rule from the Alliance for Automotive Innovation. |
Auto Innovators Comments_TCI-P Model Rule_200507.pdf |
5/7/2021 |
Darleen |
Rudnick |
self |
Williamsburg |
Virginia |
I'm opposed to Virginia joining the TCI. It will cost consumers and businesses too much at the gas pump. read more I'm opposed to Virginia joining the TCI. It will cost consumers and businesses too much at the gas pump. |
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5/7/2021 |
Laura |
Hartman |
RAISE (Roanoke Area Interfaith Stewards of the Earth) |
Roanoke |
Virginia |
I call for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and underserved communities in Virginia receive a greater-than-proportional share of investments... read more I call for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and underserved communities in Virginia receive a greater-than-proportional share of investments from the program, (2) integration of air quality commitments across Virginia, and (3) robust empowerment of Virginia's Equity Advisory Body. |
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5/7/2021 |
Edward |
Long |
Longhill Technologies |
Waynesboro |
Virginia |
As a Ph.D. Physicist I am technically aware of the burdensome cost and technically ineffectiveness of the Transportation Climate Initiative (TCI.)
Virginia should not join the TCI because... read more As a Ph.D. Physicist I am technically aware of the burdensome cost and technically ineffectiveness of the Transportation Climate Initiative (TCI.)
Virginia should not join the TCI because the people of Virginia can not afford the burdens the TCI would impose.
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5/7/2021 |
Edward |
Long |
Longhill Technologies |
Waynesboro |
Virginia |
As a Ph.D. Physicist I am technically aware of the burdensome cost and technically ineffectiveness of the Transportation Climate Initiative (TCI.)
Virginia should not join the TCI because... read more As a Ph.D. Physicist I am technically aware of the burdensome cost and technically ineffectiveness of the Transportation Climate Initiative (TCI.)
Virginia should not join the TCI because the people of Virginia can not afford the burdens the TCI would impose.
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5/7/2021 |
Carolyn |
Lyle |
VA resident |
Alexandria |
Virginia |
"[I call for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and underserved communities in Virginia receive a greater-then-proportional share of... read more "[I call for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and underserved communities in Virginia receive a greater-then-proportional share of investments from the program, (2) integration of air quality commitments across Virginia, and (3) robust empowerment of Virginia's Equity Advisory Body."
Please submit a comment today before it's too late!
Thank you for improving the TCI-P Model Rule,
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5/7/2021 |
Lisa |
McLaughlin |
VCN |
MIDLOTHIAN |
Virginia |
I call for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and underserved communities in Virginia receive a greater-then-proportional share of investments... read more I call for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and underserved communities in Virginia receive a greater-then-proportional share of investments from the program, (2) integration of air quality commitments across Virginia, and (3) robust empowerment of Virginia's Equity Advisory Body. |
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5/7/2021 |
Lisa |
McLaughlin |
VCN |
MIDLOTHIAN |
Virginia |
I call for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and underserved communities in Virginia receive a greater-then-proportional share of investments... read more I call for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and underserved communities in Virginia receive a greater-then-proportional share of investments from the program, (2) integration of air quality commitments across Virginia, and (3) robust empowerment of Virginia's Equity Advisory Body. |
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5/7/2021 |
JeVerna |
Haynes |
private citizen |
Fredericksburg |
Virginia |
Transportation & Climate Initiative Program (TCI-P) This program must go forward. This area has so much traffic, thus so much pollution, that my grandmother was afraid to even go outside in... read more Transportation & Climate Initiative Program (TCI-P) This program must go forward. This area has so much traffic, thus so much pollution, that my grandmother was afraid to even go outside in the 1980s. We made improvements, then Trump took us backward, when we hadn't gone nearly far enough as it was. We must, must, must see this happen. |
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5/7/2021 |
Elizabeth |
Ende |
Virginia Democracy Forward |
McLean |
Virginia |
I am writing to support a strong TCI-P Model Rule that can make a sizeable difference towards climate action since transportation is one of the largest sources of greenhouse gas emissions and... read more I am writing to support a strong TCI-P Model Rule that can make a sizeable difference towards climate action since transportation is one of the largest sources of greenhouse gas emissions and particulate pollution in Virginia and the DMV area. The TCI-P Model Rule addresses racial injustice as it invests in underserved communities and will help provide a cleaner, healthier transportation system for Virginia. Investing in a clean economy for Virginia, is a win as it will improve air quality, lower health care costs, reduce greenhouse gas emissions, and generate revenue for other environmental initiatives to further accelerate our progress. |
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5/7/2021 |
Cynthia |
Wackerbarth |
Knox Presbyterian Church |
Falls Church |
Virginia |
I call for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and underserved communities in Virginia receive a greater-then-proportional share of investments... read more I call for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and underserved communities in Virginia receive a greater-then-proportional share of investments from the program, (2) integration of air quality commitments across Virginia, and (3) robust empowerment of Virginia's Equity Advisory Body. Thank you for your consideration of this important issue for our future generations.
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5/7/2021 |
Steve |
Banashek |
Self |
Alexandria |
Virginia |
Transportation is the largest source of greenhouse gas emissions and a significant source of particulate pollution in Virginia and that is why I support a strong TCI-P Model Rule that (1) ensures... read more Transportation is the largest source of greenhouse gas emissions and a significant source of particulate pollution in Virginia and that is why I support a strong TCI-P Model Rule that (1) ensures meaningful climate action to address Virginia's largest driver of our climate crisis, (2) directs significant investments to correcting historic inequities in overburdened and underserved communities; and (3) affords Virginia the opportunity for a cleaner, healthier transportation system.
Overburdened and underserved communities have historically borne a disproportionate burden from transportation emission impacts including diesel exhaust from heavy duty vehicles that traverse their communities. As such, I would like for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and underserved communities in Virginia receive a greater-then-proportional share of investments from the program, (2) integration of air quality commitments across Virginia, and (3) robust empowerment of Virginia's Equity Advisory Body.
Thank you for your consideration. |
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5/7/2021 |
David |
Peabody, FAIA |
Alexandria Citizen |
Alexandria |
Virginia |
It is time that Virginia, long crippled by special interest lobbies manipulating people to vote against their own best interests, finally steps up on the existential threat posed by a changing... read more It is time that Virginia, long crippled by special interest lobbies manipulating people to vote against their own best interests, finally steps up on the existential threat posed by a changing climate. I strongly support the TIC-P Model Rule, with its focus upon the largest driver of greenhouse gas emissions and upon underserved communities. It is time to come together to think about our children and grandchildren and forget about politics. |
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5/7/2021 |
jennifer |
schutt |
na |
henrico |
Virginia |
put a brake on carbon emissions while investing in cleaner, more equitable and resilient transportation systems put a brake on carbon emissions while investing in cleaner, more equitable and resilient transportation systems |
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