View Public Input on TCI-P

As stated in a recent Fredericksburg Free Lance Star article, this initiative is "all pain and no gain" for the citizens of Virginia. Imposing a significant tax on gas-powered vehicles while not taxing EVs, which actually cause a greater carbon deficit during their manufacture, is absurd.

Studies and research project that this initiative (TCI) will only reduce global temperature by a minute amount; while costing Virginians an exorbitant (regressive) carbon tax on the fuel they need to travel all the while - reducing the revenue needed to maintain our roads. Electric vehicles' manufacturing process result in its own pollutants for a long time, and EV batteries are toxic and currently not being disposed of safely. There is no 'cost-benefit' to this proposed rule. As always, any increases in costs to companies will simply be passed along to their consumers. I am against this proposed rule and TCI. It flies in the face of logic.

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.

This is one of the worst ideas dreamed up. The cost is extremely high and the return is nil. Virginia should not participate.

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?

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.

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.