View Public Input on TCI-P

Please understand that I offer my comments in the spirit of someone who really wants the TCI-P to be successful and to make a big difference in our climate emissions. We need it to be successful! But, as proposed, it is an embarrassment. 1) The claims of on the order of 25% reductions of transportation emissions over 10 years is based, by your own admission, on overly optimistic projections of the effect of other transportation policies. TCI-P itself will have a miniscule effect on transportation emissions. The over-selling of TCI-P is totally transparent and will only lead to effective opposition. 2) The amount of funding produced by TCI-P pales in comparison with the funds that will be needed to address transportation climate emissions in the member states. 3) Limiting transportation fuel price increases to levels that will be undetectable within the normal fluctuations of fuel prices reveals the lack of political will on the part of TCI-P states to step out and lead on climate change. The proposal is an embarrassment from the point of view someone who is rooting for NE states to address climate emissions. It is time for TCI-P participants to look in the mirror and decide if they have the courage to lead at a time when we need honest leadership or if they can, with a clear conscience, continue to sell a failure of leadership with deceptive claims of wonderful results.

August 13, 2021

Transportation and Climate Initiative Program
via the TCI-P Public Portal

Re: Comments of POET LLC on the Transportation and Climate Initiative’s Model Rule

POET, LLC (POET) hereby submits these comments on the Transportation and Climate Initiative Program’s (TCI_P) Model Rule, which furthers TCI-P’s efforts to develop a regional low-carbon transportation policy for jurisdictions in the Northeast and Mid-Atlantic.

POET’s mission is to be good stewards of the Earth by converting renewable resources to energy and other valuable goods as effectively as humanly possible. POET owns and operates an industry-leading 33 bioethanol plants, and is the world’s largest producer of plant-based biofuels, with three billion gallons of annual production capacity. Started in 1987, the company today operates in eight states, and markets biofuels and renewable co-products here in the U.S. and across the globe. In 2019, Fast Company recognized POET on its annual list of “Most Innovative Companies” for transportation and FORTUNE recognized POET on its list of companies that are changing the world. While the scope of our vision has grown, POET remains focused on reducing reliance on petroleum products, revitalizing global agriculture, and providing a cleaner, affordable alternatives to fossil fuels.

POET is deeply committed to decarbonizing transportation and developing cleaner, affordable alternatives to fossil fuels. POET writes in support of the Model Rule. The Model Rule has the potential to encourage greater use of renewable biofuels for transportation in the Northeast and Mid-Atlantic, which supports TCI-P’s goals of delivering a cleaner and more resilient transportation system, reducing greenhouse gases (GHGs) and other harmful pollutants, and benefiting those communities that are disproportionately burdened by air pollution.

I. The Role of Renewable Biofuels in Reducing Transportation Sector GHG Emissions

The increased use of renewable biofuels can significantly reduce GHG emissions from the transportation sector in the near term. Virtually all gasoline sold today contains 10% ethanol (“E10”). Almost all of the existing fleet of cars and trucks (those not designed to run on diesel or electricity) can use 15% ethanol (“E15”). E15 increases the biofuel content of gasoline by 50% above E10. E15 is EPA-approved for all gasoline vehicles model year 2001 and newer, which cumulatively represent more than 9 out of 10 cars, trucks, and SUVs on the road and more than 97% of vehicle miles traveled. Moreover, as of 2017, there are more than 21 million flex-fuel vehicles (FFVs) on the road in the United States, which can support up to 85% ethanol (“E85”). Of that number, approximately 4.4 million FFVs are in use in the 13 states collaborating on the Transportation and Climate Initiative.

CO2 reduction benefits increase in proportion to the increased share of renewable biofuels blended into gasoline, and higher-level ethanol blends are readily suited for today’s vehicles. Indeed, ethanol is the most affordable and readily available means to significantly decarbonize fuels for internal-combustion passenger vehicle engines.

II. The Model Rule Appropriately Exempts Biofuels from Allowance Obligations

POET supports the approach taken in the Model Rule’s exemption of biofuels from allowance obligations. Subpart XX-8 of the Model Rule appropriately imposes allowance surrender obligations on fuel providers only for emissions attributable to the combustion of the fossil fuel content of fuel. Subpart XX-8 specifically exempts the combustion of the biomass-derived content of fuel from CO2 emission allowance obligations.

This approach is consistent with other programs that recognize that, when combusted, biomass-derived fuel can be viewed as carbon neutral because of the relatively fast uptake of CO2 emissions by biomass growth. For example, the Environmental Protection Agency’s (EPA) Greenhouse Gas Reporting Program regulations treat combusted biomass as carbon neutral. The Regional Greenhouse Gas Initiative, a cap-and-trade program for power plants in which multiple TCI-P jurisdictions participate, treats power generated from eligible biomass to be carbon neutral and exempt from allowance surrender obligations. Similarly, the California GHG reporting and cap-and-trade programs exempt certain biomass-derived fuels from compliance requirements.

Exempting biomass-derived fuel from allowance surrender obligations creates an incentive for the increased use of such renewable fuel, which will result in increased environmental and economic benefits. Substituting biomass-derived fuels for conventional gasoline and diesel results in substantial and near-term CO2 emission reductions and reduces conventional air pollutants. Even measured on a life-cycle basis, biofuels have substantially lower emissions than gasoline. A recent and comprehensive peer-reviewed study found that the life-cycle GHG emissions attributable to ethanol use are 46% lower than those from conventional gasoline.

Additionally, a program that encourages the use of renewable biofuels ultimately furthers the TCI-P’s mission to achieve equitable outcomes. Increased blending of biofuels into gasoline reduces vehicle pollution, which disproportionately burdens communities of color. It also can help mitigate price increases at the pump that may result from the TCI-P, as ethanol has historically been sold at a discount to gasoline.

III. Conclusion

POET appreciates the opportunity to comment on the Model Rule. Renewable biofuels can significantly reduce CO2 emissions from cars and trucks in TCI-P jurisdictions, benefit vulnerable communities disproportionally impacted by pollution, and help moderate the impact of the CO2 cap on prices at the pump to further the TCI-P’s environmental and equity objectives. POET looks forward to continuing to be part of the TCI-P stakeholder discussion.

If you have any questions or would like additional information, please contact me at michael.walz@poet.com.

Sincerely,

Michael Walz
Director of State Policy
POET LLC

We support the TCI-P Rule giving more support to challenged and undeserved communities and to environmental safeguards.

This seems like a terrible idea to me and will only serve to punish average citizens who do not want nor can they afford an electric vehicle. My job is 5 miles north, my kids go to school 10 miles east and my husband works 50 miles away in DC. How exactly is increased transit going to efficiently and effectively deliver us all where we need to be? It won't, and the increased tax to purchase gasoline due to the TCI will be a huge burden to my family and others like us. The worst part is that the science is clear that electric vehicles are not the environmental panacea that the media would have us believe. They are carbon-intensive to produce and leave behind toxic used batteries. The most disgusting part of this is that it will yield so little positive impacts and seems to be just be yet another government overreach intended to control the way people live and take away any sort of individual decision-making.

Transportation emissions account for almost half of climate pollution in Vermont. In order to meet our requirements under the Global Warming Solutions Act, we must substantially decrease emissions in this sector.
One area where the TCI-P could be stronger is its emphasis on equity.
Governor Scott please Support an Equitable TCI-P

I am totally opposed to Virginia joining the TCI. This has been a devastating year for Virginia families and businesses, and most are just now beginning to regain a somewhat normal life again. The financial impact of this last year on both individuals and businesses has also been very difficult, and the last thing we need are rising gas prices, that will further negatively impact family incomes, trucking transportation prices, making the cost of goods and services escalate. Please do not join.

Virginians cannot afford to join the TCI. This is all well and good on paper--save the planet, etc. But in reality it's to line the pockets of certain people at the expense of the average citizens. It will cost the regular Virginians too much at the pump, when we're already struggling. You serve us! Think of the cost/benefit and don't join.