View Public Input on TCI-P

Please find attached supportive comments for the TCI-P Model Rule from the Alliance for Automotive Innovation.

We should take steps to be better stewards of the environment, but the Transportation Climate Initiative (TCI) is not an effective way to do that. The TCI would increase gas taxes to pay for corporate welfare handouts for favored industries and is not responsible public policy.

Our goal should be to remove barriers to innovation and empower people in communities and business to be better stewards of the environment. Subjecting consumers, businesses and entrepreneurs to taxes, mandates, and regulations will undermine the kind of ingenuity needed to achieve that goal.

Even if Virginia enters the TCI, the effect on transportation emissions would be negligible. In 2017, emissions from the transportation sector in Virginia were 15% lower than their peak in 2006. And even TCI proponents acknowledge that transportation-related emissions are set to decline an additional 19% in the TCI region without their regressive tax. Private sector innovation unhindered by government intervention and red tape is the better path forward to keep reducing our emissions.

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.

NO to Virginia joining TCI. The cost will be passed onto consumers, who ALWAYS are affected. Another tax would hurt the economy trying to get back. This tax will affect truckers which will then raise the cost of EVERYTHING!

No! No! No! to TCI

Please see the attached letter from members of Our Transportation Future and additional partners.

Virginia should not join TCI. Especially at this point in time with the recovery from Covid barely underway, it will impact average citizens, truckers and businesses alike.

This will certainly depress the economy in Virginia. There is no way this is helpful or useful. We cannot throw money at a vague concepts that are not understood and vastly overstated for some as yet undeclared purpose.

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.