5/8/2021 |
Timothy |
Howe |
farmer land conservation |
East Calais |
Palau |
This must be supported for it is our responsibility to undo the damage done to the atmosphere for our families future and for the future of many species.This is one important step to... read more This must be supported for it is our responsibility to undo the damage done to the atmosphere for our families future and for the future of many species.This is one important step to be followed by much else, and we must not be sidetracked by big business which has much to do in creating the problem. Clean transportation is essential for a sustainable economic survival ! |
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5/8/2021 |
Timothy |
Howe |
farmer land conservation |
East Calais |
Palau |
This must be supported for it is our responsibility to undo the damage done to the atmosphere for our families future and for the future of many species.This is one important step to... read more This must be supported for it is our responsibility to undo the damage done to the atmosphere for our families future and for the future of many species.This is one important step to be followed by much else, and we must not be sidetracked by big business which has much to do in creating the problem. Clean transportation is essential for a sustainable economic survival ! |
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5/5/2021 |
Jesse |
Huddleston |
Retired |
Barboursville |
Virginia |
Virginia cannot afford to join the TCI.
The cost to the energy sector will trickle
down and impact all Virginians using fuel. Virginia cannot afford to join the TCI.
The cost to the energy sector will trickle
down and impact all Virginians using fuel. |
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5/12/2021 |
Lisa |
Huffman |
Virginia resident |
Charlottesville |
Virginia |
I am against Virginia joining the Transportation Climate Initiative. I believe it would have a negative impact on consumers and especially small businesses. I am against Virginia joining the Transportation Climate Initiative. I believe it would have a negative impact on consumers and especially small businesses. |
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5/4/2021 |
Barbara |
Huibregtse |
Vermont resident |
Danville |
Vermont |
I support a strong TCI as a response to the climate crisis and the need to decarbonize the economy in a time when transportation shares such a high contribution to emissions. In addition,... read more I support a strong TCI as a response to the climate crisis and the need to decarbonize the economy in a time when transportation shares such a high contribution to emissions. In addition, resources should be allocated in a way that achieves other benefits, too, such as improving air quality in the communities with the worst air now, typically low-income and minority communities, and saving overall healthcare costs for low-income communities, and potentially reducing public health costs as well. |
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3/9/2021 |
JAMES |
INGALLS |
Transportation Finance |
BROOKLYN |
Connecticut |
Consider outreach initiatives to car dealerships, service garages and the public to educate on the merits and workings of Electric Vehicles;
Partner with electric service providers to... read more Consider outreach initiatives to car dealerships, service garages and the public to educate on the merits and workings of Electric Vehicles;
Partner with electric service providers to upgrade power grid and allow for off-peak rates to consider EV charging impact to power grid;
Prioritize maintenance of EV charging network - charge stations have a high rate of down time. Install fast chargers at every highway service area.
Require all dealerships which sell or lease EV's to install a fast charger. Bear in mind dealerships are slow to accept EV promotion as low maintenance translates into lower revenue for them.
Governments have to consider loss of revenue from gas taxes as more EV's are on the road. Possibly consider transportation tax based on miles driven. |
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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.
|
21 0507 TCI comments FINAL.pdf |
5/7/2021 |
Jeffrey |
Jacobs |
EVA/DC |
Herndon |
Virginia |
Virginia should join the TCI-P, we need energy independence and security and we can do that no better than moving to electric cars and driving them on clean domestic fuel. What’s more, we need to... read more Virginia should join the TCI-P, we need energy independence and security and we can do that no better than moving to electric cars and driving them on clean domestic fuel. What’s more, we need to mind the Atmosphere so our power should be clean for our cars and our houses. This is why we need to be part of the TCI-P. |
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5/7/2021 |
Cale |
Jaffe |
Environmental Law and Community Engagement Clinic at UVA Law |
Charlottesville |
Virginia |
I strongly support the TCI-P Model Rule as an essential next step on the road to decarbonization.
A 2018 report from the Intergovernmental Panel on Climate Change (IPCC) confirms... read more I strongly support the TCI-P Model Rule as an essential next step on the road to decarbonization.
A 2018 report from the Intergovernmental Panel on Climate Change (IPCC) confirms that meeting the Paris Agreement's 1.5-degree target will require cutting GHG emissions roughly in half by 2030, and achieving net zero emissions by 2050. See Bill McKibben, "How 1.5 Degrees Became the Key to Climate Progress," New Yorker (April 21, 2021), at https://www.newyorker.com/news/annals-of-a-warming-planet/how-15-degrees-became-the-key-to-climate-progress.
Achieving these reductions will be challenging. A recent forecast from the United Nations' World Meteorological Organization finds "a 20% chance that global temperatures will be 1.5 degrees Celsius (2.7 Fahrenheit) higher than the pre-industrial average in at least one year between 2020 and 2024." See Nadine Achoui-Lesage & Frank Jordans, "UN: World could hit 1.5-degree warming threshold by 2024, " Associated Press (July 9, 2020) at https://abcnews.go.com/Technology/wireStory/world-hit-15-degree-warming-threshold-years-71687896.
We simply no longer have the luxury of time. I respectfully encourage adoption of the TCI-P Model Rule now to ensure durable, sustained, and necessary reductions in GHG pollution. |
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5/5/2021 |
Kim |
Jemaine |
Chesapeake Climate Action Network |
Glen Allen |
Virginia |
We 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 We 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.
Overall, we support a rule which ensures meaningful climate action and sets forth significant investment in historically overburdened communities. |
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5/7/2021 |
Jim |
Jewett |
citizen |
Locust Dale |
Virginia |
I oppose Virginia joining the group. This will only add to consumer and business costs and have no impact on CO2 emissions. I oppose Virginia joining the group. This will only add to consumer and business costs and have no impact on CO2 emissions. |
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5/5/2021 |
Michael |
Johnson |
University of Virginia |
Kesxwick |
Virginia |
Virginians simply cannot afford to start this program at this time. Given COVID shutdowns and additional expenses many Virginians are in a very bad financial situation. Adding all the additional... read more Virginians simply cannot afford to start this program at this time. Given COVID shutdowns and additional expenses many Virginians are in a very bad financial situation. Adding all the additional expenses that this program will cause a major hardship on the people of Virginia. |
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5/7/2021 |
William |
Johnson |
Sierra Club, Rappahannock Group |
Fredericksburg |
Virginia |
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... read more 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.
I also 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.
We are at a crossroads in the climate crisis. One way ensures that the world will become a much more difficult place for our children and grandchildren to live in, if we continue spewing greenhouse gas emissions into the atmosphere. The other way gives us a chance to change the direction that our world is heading towards. How many creatures have to become extinct before we address greenhouse gases? How many ocean-front properties have to be sacrificed to rising seas? How will countries deal with millions of people migrating to neighboring countries that don't want them?
Time is quickly running out. We need to act NOW. We need to adopt the TCI-P Model Rule now to ensure durable, sustained, and necessary reductions in GHG pollution.
“The hottest places in hell are reserved for those who, in times of great moral crisis, maintain their neutrality.” Dante Alighieri. We are at that moral crisis now. What will you do? |
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4/28/2021 |
Candy |
Jones |
350 Rutland County |
Rutlaand |
Vermont |
With only 10 years to drastically reduce our co2 emissions, the TCI must invoke the strongest possible financial consequences for the heaviest emitters, engage in massive public transportation... read more With only 10 years to drastically reduce our co2 emissions, the TCI must invoke the strongest possible financial consequences for the heaviest emitters, engage in massive public transportation overhauls, and collaborate with city planners to shift our cities and towns from auto friendly to pedestrian and bicycle friendly places. Recognizing that marginalized people often bear the brunt of consequences created by our fossil fuel dependence, all planning must include just transition initiatives that benefit those of less economic resources and power. |
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5/5/2021 |
Heather |
Juliussen-Stevenson |
Not applicable - submitting as a private citizen |
Rutland |
Vermont |
I support TCI-P and believe that Vermont should join this initiative. It's essential to our survival in a growing climate emergency.
Thank you! read more I support TCI-P and believe that Vermont should join this initiative. It's essential to our survival in a growing climate emergency.
Thank you! |
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5/6/2021 |
Karen |
Jumisko |
Vermonter |
Randoloh |
Vermont |
I support the Transportation and Climate Initiative Program (TCI-P). We need to take action. I support the Transportation and Climate Initiative Program (TCI-P). We need to take action. |
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5/4/2021 |
Maja |
Jurkiewicz |
Vermont resident |
Montpelier |
Vermont |
I think Governor Scott needs to address all of the pollution that will come with the Covid-induced population boom. Why not tax these people who are outbidding local Vermonters on home sales and... read more I think Governor Scott needs to address all of the pollution that will come with the Covid-induced population boom. Why not tax these people who are outbidding local Vermonters on home sales and driving up the prices of housing, taking up all available rentals, good paying jobs, and bringing more vehicles and thereby emissions into the state? |
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5/5/2021 |
Jason |
Kaiser |
Northern Vermont University |
Lyndonville |
Vermont |
The XX-3.1 Equity investment commitment is critical. The "overburdened and underserved communities" that this subsection refers to -- receiving "no less than 35 percent of the... read more The XX-3.1 Equity investment commitment is critical. The "overburdened and underserved communities" that this subsection refers to -- receiving "no less than 35 percent of the proceeds from the auction of allowances to ensure that overburdened and underserved communities benefit equitably from clean transportation projects and programs" is not a high enough percentage for these communities. Instead, the percent of revenue dedicated to equity investments must exceed the percentage of overburdended and underserved (to later be defined) communities in the state. Unlike a flat percentage, this would ensure that there’s enough money to make meaningful investments in our most vulnerable communities.
I am concerned that there is economic risk if Governor Scott and the Vermont Legislature refuse to join TCI-P. Like RGGI, most of the facilities that will have to purchase allowances are located outside of Vermont and, according to Vermont’s lead TCI negotiator, it is “possible and very likely” these companies will pass on their compliance costs to Vermonters regardless if Vermont participates. So, to take advantage of TCI-P’s economic benefits and avoid a situation where Vermonters are paying for modern infrastructure in states outside of Vermont, I urge Governor Phil Scott and the Vermont Legislature to support participation in TCI-P from the get-go. |
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5/8/2021 |
Ronald |
Kaltenbaugh |
EVADC |
Jefferson |
Maryland |
Enacting strong and robust TCI rules is critically important. This is an important tool in needed efforts to electrify all forms of ground transportation. Our fossil fuel vehicles are killing us... read more Enacting strong and robust TCI rules is critically important. This is an important tool in needed efforts to electrify all forms of ground transportation. Our fossil fuel vehicles are killing us in so many ways and this needs to stop. Climate change, poor air quality, and added healthcare costs, are just a few reasons why we need to act. TCI can ensure that we address these issues along with correcting historic inequities in overburdened and underserved communities. Also, our addiction to fossil fuels often provides funding to terrorist groups and unfriendly governments around the world. Any one of these reasons is enough to support vehicle electrification and TCI, added together, they make this an imperative with benefits for everyone. |
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5/7/2021 |
Andrew |
Kambour |
The Nature Conservancy |
Arlington |
Virginia |
Please see the attached file for The Nature Conservancy's comments on the TCI-P Draft Model Rule read more Please see the attached file for The Nature Conservancy's comments on the TCI-P Draft Model Rule |
TNC Comments - TCI Draft Model Rule 5-7-21.pdf |