View Public Input on TCI-P

Clean Energy greatly appreciates the opportunity to comment on the (TCI) Draft Model Rule for the TCI-Program (TCI-P). We also applaud your dedication to this long-term effort to meaningfully address transportation sector emissions and their negative effects on both air quality and climate change.

THE LOWEST CARBON FUEL AVAILABLE

As North America’s largest provider of carbon negative vehicle fuel, Clean Energy is proud to deliver renewable natural gas (RNG) to the country’s leading fleets such as UPS, Waste Management, NYMTA, and Amazon. In 2020, the California Air Resources Board certified RNG as the first and only carbon negative fuel (-17.95 gCO2e/MJ ), based on the weighted average under the state’s Low Carbon Fuel Standard (LCFS). Individual RNG fuel pathways have been certified with carbon intensity scores as low as -532 gCO2e/MJ . It is important to note that the weighted average of battery electric power has a carbon intensity score in California of 16.6 gCO2e/MJ , thereby making RNG the lowest carbon fuel available.

With similar operational performance benefits as diesel trucks, in terms or range and payload, RNG vehicles are the leading technology for reducing carbon emissions from the medium and heavy-duty vehicle sector. In addition to providing climate change benefits, vehicles powered by near-zero engines and fueled with RNG can reduce NOx emissions by 90-99 percent and eliminate diesel particulate matter emissions.

LARGE-SCALE DEPLOYMENT CAPABLE

Whether its mass transit buses or long-haul trucks, renewable natural gas vehicles surpass all other alternative fuels in terms of operational deployment in the heavy-duty sector. For example, in early 2021 New York MTA, the nation’s largest mass transit authority, signed a contract to fuel 800 of their buses with RNG. LA Metro, the nations’ second largest mass transit authority operates over 2,300 RNG buses and recently placed an order for 300 more. In contrast, Toronto currently operates the largest electric-battery bus fleet in North America with a total of 60 buses. While every industry has their own studies, the proof is in the deployments.

EV technology has advanced over the past decade but is still not deployable on a large-scale. This is due to cost, performance, infrastructure, and upstream energy issues that may or may not be renewable. Additionally, the lack of availability for heavy duty applications is not expected to resolve itself in the near to mid-term.

PROVIDING RELIEF TO ENVIRONMENTAL JUSTICE COMMUNITIES NOW

The Draft Model Rule specifically addresses environmental justice communities by mandating 35 percent of the funds collected address air quality in said neighborhoods. This is a powerful and necessary policy. Many environmental justice communities are located around heavily industrialized areas which are often plagued by heavy diesel truck traffic. Clean Energy’s vast network of over 530 refueling stations are enabling trucking fleets to provide these communities immediate and effective relief today. National trucking fleets have taken the lead in deploying thousands of RNG trucks across the country with the most recent development being Amazon’s announcement to deploy over 700 RNG trucks across its national operations. Local and regional fleets in these communities also have independently started to adopt RNG, as evidenced by our Hunts Point station in the South Bronx where small fleets such as a local concrete company utilize this green fuel.

CONCLUSION

TCI can be a great success if states implement a program which focuses on results by not restricting the means. Electrification is a part of the solution, but electrification alone could guarantee diesel’s domination for decades along with the associated air pollution and carbon emissions. Large-scale deployments of RNG vehicles by leading national fleets provide clear evidence that to achieve significant emissions reductions now, RNG must play a significant role in the TCI-P. We look forward to continued participation in the process and request that the TCI organization place greater emphasis on the important role that renewable fuels play in our carbon free future.

Clean Energy greatly appreciates the opportunity provide comments on the TCI-P supporting materials. Our comments are attached.

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.

An increased and robust ability for the public to have transparency available to them regarding public works projects they fund seems a stellar notion. The more transparency the better!

The purchase of 'allowances' does not adequately serve the purpose of reducing emissions. This cost is simply passed down to the consumer; ultimately wreaking havoc on GDP. There needs to be major tax 'incentives' to produce cleaner energy and reduce GHG. If 'clean energy' becomes synonymous with 'profitability', then the stated goals of this plan are much more likely to succeed. Simply incorporating additional costs only hurts the very people you're trying to protect and is not really an equitable solution on its own. There are many who do wish to 'go green', but the startup is simply too cost prohibitive. Please add financial INCENTIVES to this plan, as the money made from 'allowances' (over the course of inflation that comes with this type of activity) will ultimately end up being next to worthless. The fact is, we should have cut out GHG a LONG time ago. We are already overdue and the fact that corporations can just pay-up and that somehow makes it ok is an insult to our planet, voting citizens and our children. The earth doesn't work that way. 'Paid-for emissions' are still emissions. Greener energy should be a REQUIREMENT, at this point. Gas stations change their pricing constantly, and drivers who commute are not going to stop driving. Since, COVID, driving has even become many individuals full-time job. And electric vehicles provide no benefit to our environment if the electricity they use still comes from the burning of fossil fuels. Consumers still require energy. Added costs, simply get passed down to the end-users who have even less means to make an impact. Ultimately, change rests in the hands of the producers of that energy. As such, clean energy production should be mandated, if not strongly encouraged through credits and tax incentives. Simply taxing emissions, as we've already witnessed over the years, does absolutely NOTHING to produce the desired change this policy lays out. Please provide the 'carrot' AND 'the stick' to ensure our children have a habitable world to live in.