View Public Input on TCI-P

I do not supoport this initiative that puts America's economic needs at risk while other nations are given a waiver because they claim some "developing" status. If we are going to make the World better for all of us, we need a comprehensive, no-waivers, all nations plan of attack.
American can not and should not go it alone on this issue. We will all be long gone before this planet is no longer habitable (if that ever happens). The science on this issue to too mushy to proceed at this time.

Dear sir:
We want to know the impact of low carbon renewable ethanol produced in the southeast may have in the TCI P.
1. Will there be an incentive per gallon for low carbon index ethanol produced like the Low Carbon Fuel Standard (LCFS) implemented in California?
2. Will the regulated fuel supplier be able to reduce their purchases allowances if they use lower carbon index ethanol or higher blending fuels such E15, E85?

Juan Briceno

We need (TCI-P Model) Rules for climate crisis action, repair EJ communities' harms done (some energy & health effects reparations). Also electric (NOT toward more vehicle methane) cleaner transport both more public (solar!) charging stations but focus on electrified public streetcars system. (see solutionaryrail.org)
We'd like a minimum investment amount to ensure overburdened communities get a bigger share of investments to match renewable resolutions across the state.

It's just another way/excuse to get money that can be spent recklessly. The Last thing Americans need is to have more or high taxes, this especially includes new taxes

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.

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.

This is not a tax on gasoline and diesel! This is a more accurate accounting of the true cost of gasoline and diesel. It is an elimination of the free-ride subsidy gasoline and diesel have enjoyed for years. It’s time for us to stop pretending that using gasoline and diesel has no cost: it does.

The funds collected don’t just vanish, either. The TCI proposal directs them in a productive way to clean up the transportation system, which benefits us all, and will begin paying off immediately.

Gas prices will not skyrocket! Any increases the distributors pass on will be well below the normal fluctuations we all live with. Even setting the highest cap with 25% reduction will be almost unnoticeable at the pump. Distributors will continue to compete with each other on price. Let the free market rule!

Some say this will have a negligible effect on reducing emissions. This argument assumes a baseline that already has a huge uptake of EV’s, which we are no where close to yet. We should think of TCI as insurance against the mischief and backsliding supported by fossil fuel interests.

It’s time to start being responsible for our actions.