5/7/2021 |
Patrick |
Kelly |
API |
Washington |
District of Columbia |
See attached. See attached. |
API Comment TCI 5.7.21.pdf |
5/7/2021 |
Mark |
Morgan |
Energy Marketers of America |
Arlington |
Virginia |
EMA Comments EMA Comments |
EMA_TCI_Comments (2).pdf |
5/7/2021 |
Jordan |
Cohen |
Brownstein Hyatt Farber Schreck, LLP |
Denver |
Colorado |
On behalf of Nacero, Inc., please find the attached comment letter. On behalf of Nacero, Inc., please find the attached comment letter. |
5.7.21 TCI-P Comment Letter.pdf |
5/7/2021 |
Katie |
Sullivan |
IETA |
Washington DC |
District of Columbia |
The International Emissions Trading Association (IETA) appreciates this opportunity to share input on the Transportation and Climate Initiative Program (TCI-P) Engagement Process and Draft Model... read more The International Emissions Trading Association (IETA) appreciates this opportunity to share input on the Transportation and Climate Initiative Program (TCI-P) Engagement Process and Draft Model Rule. |
IETA Comments_TCI-P Draft Model Rule and Equity_7May.pdf |
5/7/2021 |
Jeff |
Schafer |
None |
Everett |
Washington |
TCI-P,
"According to soil scientists, at current rates of soil destruction (i.e. decarbonization,.....),....we will literally no longer have enough arable topsoil to feed ourselves.... read more TCI-P,
"According to soil scientists, at current rates of soil destruction (i.e. decarbonization,.....),....we will literally no longer have enough arable topsoil to feed ourselves."
DECARBONIZATION is causing Soil Destruction!!!
What we NEED is to take the extra Carbon out of the air & put it directly into the ground, where it is needed.
We do not need to fully decarbonize the transportation sector, nor is it desirable as it will CREATE other severe problems like Soil Destruction.
We need to cut-out the middlemen, like the transportation sector, & simply use Carbon Capture to take excess CO2 out of the air & inject it into the soil where it is needed most.
Way too much emphasis has been put on Carbon in the atmosphere (which is very benign) & not enough focus on gases far more dangerous to Climate Change, from refrigerant used in Air Conditioners to Methane Gas (Methane's "global warming potential is 86 times higher than carbon dioxide when averaged over 20 years").
We NEED Energy Diversity, & not rely on just 1 type of energy (like electricity), to have a BALANCED approach to a Healthy Environment while meeting our Energy Needs in a Common-Sense Clean manner (like with Renewable Gasoline, Renewable Diesel, & other Biofuels for transportation, ALL of which are made from recycled EXISTING CO2).
We should NOT be wasting Time nor Money "reinventing the wheel", which creates additional unnecessary pollution.
Nor should we go to the extremes of fully decarbonization which will lead to other More Severe Environmental problems.
Keep in mind "The current industrial food system is responsible for 44 to 57% of all global greenhouse gas emissions." (The "current industrial food system", NOT transportation.) https://regenerationinternational.org/why-regenerative-agriculture
Regards,
Jeff |
'DECARBONIZATION' is causing 'SOIL DESTRUCTION' (from Regenerative Agriculture site) [WORD version].docx |
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 |
5/7/2021 |
Staci |
Rubin |
Conservation Law Foundation |
Boston |
Massachusetts |
Please see the attached comments of Conservation Law Foundation regarding the Draft Model Rule and Public Engagement. Please see the attached comments of Conservation Law Foundation regarding the Draft Model Rule and Public Engagement. |
Comments on TCI Model Rule, Public Engagement Planning 5.7.21.pdf |
5/7/2021 |
Paul |
Wierenga |
Independent Fuel Terminal Operators Association |
Washington |
District of Columbia |
Please see enclosed comments. Please see enclosed comments. |
Comments of IFTOA on TCI Draft Model Rule (5.7.2021).pdf |
5/7/2021 |
Stanley |
Wong |
NACS, NATSO, and SIGMA |
Washington |
District of Columbia |
Please see attached comments from the National Association of Convenience Stores (NACS), the National Association of Truckstop Operators (NATSO), and the Society of Independent Gasoline Marketers... read more Please see attached comments from the National Association of Convenience Stores (NACS), the National Association of Truckstop Operators (NATSO), and the Society of Independent Gasoline Marketers of America (SIGMA), regarding the Draft Model Rule for the Transportation and Climate Initiative. |
NACS NATSO SIGMA TCI Draft Model Rule - Comment Letter.pdf |
5/7/2021 |
Molly |
Morabito |
Dream Corps Green For All |
Pittsburgh |
Pennsylvania |
We need a Transportation and Climate Initiative Program (TCI-P) that prioritizes program benefits for communities hit hardest by COVID-19, poverty, and pollution. The model rule sets a crucial... read more We need a Transportation and Climate Initiative Program (TCI-P) that prioritizes program benefits for communities hit hardest by COVID-19, poverty, and pollution. The model rule sets a crucial regional baseline for how states can achieve this.
441 constituents [listed in the attached document] have voiced their support for adding the following four policy recommendations to ensure that center equity is better centered in the final model rule for the implementation of TCI-P.
1. Uplift community decision-making power by ensuring equity advisory bodies are made up of disproportionately impacted communities, have expanded responsibilities, and receive capacity support.
2. Ensure direct and meaningful investments for disproportionately impacted communities at a percentage that is significantly greater than their share of the population.
3. Promote access to quality jobs and training by incorporating high road labor and workforce development standards.
4. Commit to localized air pollution reduction and expanded air quality monitoring in pollution burdened communities.
The potential benefits of TCI-P are not guaranteed without detailed guardrails and targeted benefits. Please adopt these four policy recommendations to center equity in the final model rule to invest in the health, leadership, and economic opportunity of communities who need it the most. |
#FuelChange TCI Model Rule Petition Delivery_5_2021_MM - Sheet1.pdf |
5/7/2021 |
Sam |
Wade |
Coalition for Renewable Natural Gas |
Sacramento |
California |
Please see our attached comment letter on the Draft Model Rule. Please see our attached comment letter on the Draft Model Rule. |
210507 RNGC Comments on TCI Draft Model Rule.pdf |
5/7/2021 |
Dan |
Bowerson |
Alliance for Automotive Innovation |
Southfield |
Michigan |
Please find attached supportive comments for the TCI-P Model Rule from the Alliance for Automotive Innovation. Please find attached supportive comments for the TCI-P Model Rule from the Alliance for Automotive Innovation. |
Auto Innovators Comments_TCI-P Model Rule_200507.pdf |
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 |
Brian |
O'Malley |
On behalf of 14 signatories including the Central Maryland Transportation Alliance |
Baltimore |
Maryland |
Please see the attached letter signed by 14 organizations in Maryland. Please see the attached letter signed by 14 organizations in Maryland. |
Joint Comments_ TCI-P Draft Model Rule and Public Engagement - Maryland Advocates.pdf |
5/7/2021 |
Mike |
O'Connor |
Virginia Petroleum & Convenience Marketers Assocation |
RIchmond |
Virginia |
Document attached Document attached |
TCI MOU May 7 comments.docx |
5/7/2021 |
Brett |
Vassey |
Virginia Manufacturers Association |
Richmond |
Virginia |
Please see attached file. Please see attached file. |
VMA - TCI Comments - 5-7-21 - Final.pdf |
5/7/2021 |
Rebekah |
Whilden |
Sierra Club |
Washington |
District of Columbia |
See comments attached. See comments attached. |
TCI Model Rule comments Sierra Club 5.7.2021.pdf |
5/7/2021 |
Brian |
Moran |
New England Convenience Store & Energy Marketers Association |
Stoughton |
Massachusetts |
New England Convenience Store & Energy Marketers Association New England Convenience Store & Energy Marketers Association |
NECSEMA Comments TCI Model Rule 5-07-21 (FNL).pdf |
5/7/2021 |
elise |
miller |
ACT Commodities |
New York City |
New York |
Thank you for the opportunity to share comments. Thank you for the opportunity to share comments. |
ACT Commodities - TCI-P Model Rule Comments 05.05.2021.pdf |
5/7/2021 |
Alexandra |
Wyatt |
GRID Alternatives |
Washington |
District of Columbia |
Please see attached comments. Please see attached comments. |
2021-05-07 GRID Alternatives TCI-P Draft Model Rule Comments.pdf |