5/7/2021 |
Erin |
Parker |
Citizen |
Blacksburg |
Virginia |
Investing in clean energy would not only be good for our environment and preserving our local nature tourism industry but it will help create jobs for the future, not jobs destined for the dust... read more Investing in clean energy would not only be good for our environment and preserving our local nature tourism industry but it will help create jobs for the future, not jobs destined for the dust bin. Please do not cave in to the monied interests of the fossil-fuel lobbyists who do not care about local economies, just their own personal profits. |
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5/7/2021 |
Eric |
Goplerud |
Faith Alliance for climate Solutions |
Fairfax |
Virginia |
It’s essential that we have Strong transportation leadership to address climate change It’s essential that we have Strong transportation leadership to address climate change |
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5/8/2021 |
Eric |
Goplerud |
Unitarian Universalist Congregation of Fairfax (VA) |
RESTON |
Virginia |
For a decade, the UU Congregation of Fairfax has acted to address climate change and environmental injustice. We believe that climate change is the moral, ethical and spiritual challenge of our... read more For a decade, the UU Congregation of Fairfax has acted to address climate change and environmental injustice. We believe that climate change is the moral, ethical and spiritual challenge of our age that must be confronted -- not only for the health and welfare of ourselves, our children and grandchildren, but also for the whole interconnected web of life that is threatened by humanity's burning of fossil fuels. Transportation accounts for a huge proportion of greenhouse gases. To sharply curtail this pollution that is forcing climate chaos already, governments must act to disincentivize carbon pollution and incentivize alternative, non-polluting transportation.
Consequently, I strongly urge Virginia's adoption of the TCl. It will reduce carbon emissions in the transportation sector in Mid-Atlantic and New England states, and the TCI-P will establish a “cap-and-invest” program. TCI-P will decrease air pollution and greenhouse gas emissions, improve public health, and generate substantial revenues to promote environmental justice and enable swifter progress toward a clean-energy economy. I understand that there may be small increases in gasoline prices. Those small increases will be more than offset by the benefits of the TCI-P in moving the commonwealth off fossil fuels and into a non-polluting economy. |
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4/6/2021 |
Ellen |
Kennedy |
none |
San Diego |
California |
Please see the attached letter. Please see the attached letter. |
TCI-P-Comment Letter-Kennedy.docx |
4/20/2021 |
Ellen |
Benitez |
MAPDA |
Annapolis |
Maryland |
The proposed Transportation Climate Initiative (TCI) Model Rule is unlikely to reduce carbon dioxide emissions from motor vehicles by a targeted 66 million tons a year by 2032. In fact, using... read more The proposed Transportation Climate Initiative (TCI) Model Rule is unlikely to reduce carbon dioxide emissions from motor vehicles by a targeted 66 million tons a year by 2032. In fact, using real-world examples from California, the Rule may have no impact at all on emissions. It is clear, however, that gasoline and diesel fuel prices will rise under the Model Rule. Fuel distributors must buy emission allowances under the Model Rule, and the cost will be passed onto consumers at the pump. TCI’s Model Rule is actually a regressive tax costing all families about the same. TCI will cost each family thousands of dollars over the next decade, and those in poverty are least able to absorb those costs. In addition, the Model Rule establishes a fixed budget of available allowances by year (pg. 44) and fuel can’t be delivered without an allowance. If TCI estimates of program success are wrong, and fuel demand doesn’t fall as expected, needed fuel can’t be delivered. TCI could plunge the region into motor fuel shortages and 1970’s style lines at the pump.
The Model Rule also moves motor fuel taxing authority from states to a non-governmental regional authority. We believe that ceding authority in this way is always a bad idea. Unlike traditional gasoline taxes, the revenue raised from allowance auctions will not go to maintaining and building highways in the local area. TCI plans to spend most of the money raised subsidizing electric vehicles, public transportation, and walking and biking trails. Electric vehicles weigh an extra thousand pounds, which adds more strain on highways, but pay no tax toward highway trust funds. States will have to raise gas taxes to make up for this revenue shortfall.
TCI claims 35% of funds will be spent on projects to bring more equity for low income communities (pg. 41), but the Model Rule is short on specifics. Urban areas already rely on public transportation. Subways and trains already run on electricity. Much of the nation’s bus fleet has already been transitioned from diesel to lower emitting natural gas and propane1. Replacing buses with electric versions that cost two to three times as much provides little additional value. Plans to add walking and biking trails in urban areas will likely find recreational use, but are unlikely to reduce commuting travel, especially in cold, wet weather.
The Model Rule establishes target emission allowance prices where allowances will be added or removed from the auction to control the auction price (pgs. 9-10). That is an engineered exercise to manipulate the price of emission allowances rather than a market-rate auction. TCI forecasts an average price that would add 11 cents to a gallon of gasoline in 2022, rising to 27 cents by 2032. TCI’s own worst case estimate pegs a surcharge as high as 41 cents2. At a minimum, TCI will cost a typical household $2,000 over the next decade, or about $187 a year3. The worst case scenario could cost households $414 in 2032, and total $4,550 by 2032. Low income rural families will be hurt the most, and the Model Rule offers no relief for those families.
Adding to the economic injustice, much of the money raised from the emission allowances will be used for subsidies for electric vehicles. Many studies show that electric vehicles are often bought by wealthy individuals for access to High Occupancy Vehicle lanes as a single occupant. The national Renewable Energy Laboratory estimates 86% of EVs are bought by people making over $60,000 a year4. TCI money will also be given as subsidies for public and private electric vehicle charging stations so those wealthy families can recharge their vehicles anywhere. Since over 80% of charging occurs overnight at home4, utilities are offering lower electric rates after 8 PM saving these wealthier families even more money.
TCI documents2 target a 6% reduction in emissions from an expected 2022 forecast level of 253 million tons, or 15 million tons per year emission savings by 2032 for twelve states and the District of Columbia. An emission allowance budget is established for each state. In the appendix of the September, 2020 TCI webinar a study by ICF International indicates only 11.8 million tons will be saved annually and that is partially offset by increased emission of 3.7 million tons from increased electric generation to power the increased number of electric vehicles. The actual emissions savings may only be 8 million tons per year, or 3%.
TCI is partially counting on higher prices to discourage driving, but travel necessity makes fuel use inelastic. A study by the U.S. Energy Information Agency5 found motor fuel prices would need to increase 25 to 50 percent to reduce driving by 1 percent, or to about $3.72/gallon in today’s dollars. The Model Rule forecasts a maximum price of 27 cent/per gallon which might only reduce emissions by about 0.2%, or 0.5 million tons.
Another flawed TCI assumption is a planned $4,000 subsidy per electric vehicle against a premium purchase price of $12,000 will stimulate sales by 10 million vehicles by 20322. This will use up to 80% of the expected emissions allowance auction revenue. TCI’s assumption does not connect with actual experience. Currently, there is a more generous federal subsidy of $7,500 per vehicle which has only stimulated sales of about 300,000 vehicles a year6. This translates to 3 million vehicles over ten years, for a CO2 reduction of about 2 to 5 million tons a year by 2032.
Considering the low impact of higher fuel prices on the miles people drive, and likely lower electric vehicle sales than forecasted, direct emission savings from TCI might only be about 2.5 to 5.5 million tons per year, a fraction of the 15 million ton forecast.
The big TCI forecast savings, 51 million tons, is supposed to come from federal programs for higher mile per gallon standards and alternative fuels. The US Energy Information Agency released its 2021 Annual Energy Outlook and only expects a 4% reduction in petroleum based transportation emissions between 2022 and 2032 equaling only a 10 million ton reduction in the TCI region by 20327.
In addition, transportation emissions in the TCI region in 2018 were 347 million tons so reaching the 2022 target of 253 million tons would require a 27% reduction, or 94 million tons8. Between 2012 and 2018 emissions actually increased 9.5% as miles per gallon improvement was eclipsed by more miles traveled, and more vehicles on the road. It is unlikely the TCI region will meet the starting goal of 253 million tons by 2022.
Taking into account a higher emission starting point in 2022 and a slower contribution to emission reductions from federal programs by 2032, we believe the expected 51 million ton 2032 TCI target is a pipe dream. Based on TCI’s own documents it is actually possible there will be zero emissions reductions by 2032 even if all the regional target jurisdictions adopt TCI. Yet the number of allowances allowing fuel delivery will be reduced in lockstep with the TCI plan which assumes the 66 million ton TCI forecast reduction. The imbalance in available allowances compared to actual demand could lead to massive shortages of motor fuel.
In conclusion, TCI will likely fail to significantly reduce carbon dioxide emissions from motor fuels, but will raise fuel prices hurting the poor the most, while leaving states short of highway trust funds, and out of the loop in controlling taxes. Worst case, the plan may result in fuel shortages leading to panic and long lines at the pump. This is a bad idea for Maryland and Delaware.
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MAPDA Model Rule comments final .pdf |
8/13/2021 |
Ellen |
Valentino |
Mid-Atlantic Petroleum Distributors Assn. |
Annapolis |
Maryland |
See enclosed document See enclosed document |
Comments on TCI Aug 2021.pdf |
4/1/2021 |
Elizabeth |
Cerceo |
Cooper Hospital |
Cherry Hill |
New Jersey |
As a physician, it is critically important that we make rapid changes in our infrastructure in favor of a carbon neutral future. The toll on our residents particularly the poor and disenfranchised... read more As a physician, it is critically important that we make rapid changes in our infrastructure in favor of a carbon neutral future. The toll on our residents particularly the poor and disenfranchised cannot be underestimated and impacts increase year after year. I would encourage quickly implementing the initiative as we are losing time to reverse the worst effects of climate change. |
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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 |
elise |
miller |
ACT Commodities |
New York City |
New York |
Thank you for the opportunity to share comments. Thank you for the opportunity to share comments. |
ACT Commodities - TCI-P Model Rule Comments 05.05.2021.pdf |
4/13/2021 |
Eleanor |
Fort |
Dream Corps Green For All |
Boston |
Massachusetts |
Please see Green For All's attached public comment in response to the Draft TCI-P Model Rule and Update on Public Engagement Planning documents. Thank you for your consideration. read more Please see Green For All's attached public comment in response to the Draft TCI-P Model Rule and Update on Public Engagement Planning documents. Thank you for your consideration. |
GFA Model Rule and Update on Public Engagement Planning Comment Letter 4_13_21 (1).pdf |
5/7/2021 |
Eldon |
Boes |
NA |
Alexandria |
Virginia |
I strongly support Virginia's participation in a regional transportation and climate initiative. Virginia must move forward to do its share in reducing global greenhouse gas emissions, and... read more I strongly support Virginia's participation in a regional transportation and climate initiative. Virginia must move forward to do its share in reducing global greenhouse gas emissions, and regional compacts are a smart and economically sound tool to help with that. So, my bottom line is that VIRGINIA'S PARTICIPATION is essential. The exact nature of it isn't nearly as important as making sure we are participating. |
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5/7/2021 |
Elaine |
Becker |
citizen |
Roanoke |
Virginia |
We ALL need Clean Air!
Please cap carbon from transportation exhaust. Manufacturers of polluting fuels MUST be held accountable for the damage they cause! We ALL need Clean Air!
Please cap carbon from transportation exhaust. Manufacturers of polluting fuels MUST be held accountable for the damage they cause! |
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5/15/2021 |
Elaine |
Fischer |
citizen |
Roanoke |
Virginia |
We ALL need Clean Air!
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-... read more We ALL need Clean Air!
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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4/27/2021 |
Eesha |
Williams |
New Leaf CSA farm |
Dummerston |
Vermont |
to VT governor Scott: join the Transportation and Climate Initiative Program now! to VT governor Scott: join the Transportation and Climate Initiative Program now! |
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5/4/2021 |
Edwin |
LaBarre |
Virginia resident and tax payer |
Stafford |
Virginia |
Based on articles I have read and other research the TCI would cost Virginians hundreds of millions of dollars per year and billions of dollars over the coming decades. The projected benefit is... read more Based on articles I have read and other research the TCI would cost Virginians hundreds of millions of dollars per year and billions of dollars over the coming decades. The projected benefit is about hundred-thousandth of a degree over the remainder of this century. There is absolutely no way I can support the extremely high cost of this climate initiative for such an infinitesimally small benefit. |
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5/4/2021 |
Edward |
Darling |
retired |
South Burlington |
Vermont |
Support this inititiative. Support this inititiative. |
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5/5/2021 |
Edward |
Heys |
Vermont resident |
Bennington |
Vermont |
I urge Vermont Governor Phil Scott and state legislators to support and join our fellow Northeastern states in the TCI-P. It is critical to our area and our country. We must all do what we can to... read more I urge Vermont Governor Phil Scott and state legislators to support and join our fellow Northeastern states in the TCI-P. It is critical to our area and our country. We must all do what we can to reduce carbon emissions, as we do with our PHEV. |
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5/5/2021 |
Edward |
Darling |
retired |
South Burlington |
Vermont |
Please pass this long-awaited and much-needed initiative! Please pass this long-awaited and much-needed initiative! |
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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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