View Public Input on TCI-P

Dear TCI Leadership,

The Coalition for Renewable Natural Gas (RNG Coalition) offers this letter in continued support of the Transportation and Climate Initiative (TCI). We appreciate the chance to provide input on the Draft Framework for Public Engagement (Guiding Principles), Draft TCI-P Model Implementation Plan for Low Carbon Transportation, and Draft Proposed Strategies for Regional Collaboration (Draft Materials) released on June 10, 2021.

The RNG Coalition would like to thank the TCI for the opportunity to provide comments on the Draft Materials.

Sincerely,

Vincent Morales
Manager of Legislative and Regulatory Affairs
Coalition for Renewable Natural Gas
T: 916.588.3033 | vincent@rngcoalition.com
RNGCoalition.com

Climate Economy Action Center of Addison County (CEAC) is developing a Climate Action Plan and reducing transportation-related emissions is a key element. We need the TCI-P to help us reach our goals.

I strongly support TCI-P. Transportation emissions are a major contributor to climate change and in Virginia, amount to nearly half of Virginia’s carbon output. The science is clear and the clock is ticking. We must aggressively address emissions from this sector if we hope to make real progress on combatting climate change.

TCI-P will also help reduce harmful air pollutants emitted by transportation sources. Accordingly to the American Lung Association, while these pollutants impact the health of everyone, they have a disproportionate impact on low-income populations and communities of color.

TCI-P generated funding will allow Virginia to invest in a modern, sustainable transportation system. It will support ongoing efforts to increase the electric vehicles and ensure adequate and equitably distributed charging infrastructure throughout the Commonwealth.

I urge you to support for this critical framework to help stave off the worst of the climate crisis, allow us to invest in a modern cleaner transportation system, and improve the health in communities hurt the most by transportation related pollution.

Thank you,
Sharon Shutler

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.

Virginia should not join TCI. It will impact average citizens, truckers and businesses alike.

The Transportation and Climate Initiative will NOT be good for Virginia or Virginians. Do not join this iniative.

Transportation emissions are a huge driver of climate change, accounting for nearly half of Virginia’s carbon output, while also emitting toxic air pollution that falls disproportionately on low-income populations and communities of color.

The Transportation and Climate Initiative Program (TCI-P) is a welcome step forward to addressing this major source of pollution, while steering needed investments in a modern, sustainable transportation system.

Funding provided by the TCI-P could help with ongoing efforts to put more electric vehicles on the road in Virginia along with equitably distributed charging infrastructure across the state.

The TCI-P also presents the opportunity to drive investments in a cleaner transportation system in the communities that have suffered the most from vehicle pollution. While the model rule calls for at least 35 percent of TCI proceeds to go toward frontline, impacted communities, here in Virginia I would hope we go above and beyond that benchmark, investing at least half of our TCI revenue in programs and infrastructure that will lower this disproportionate pollution burden.

I hope this important framework moves forward for the good of our climate, our health and our future.

TCI-P- must strengthen the Vermont economy, reduce carbon pollution, and address equity – specifically the needs of communities that are overburdened by fossil fuel pollution and under-served by cleaner transportation options.
Vermont averages $2 billion a year in fossil fuel spending, and roughly 75%, or $1.5 billion, leaves our state’s economy. Conversely, investing in renewable energy and efficiency solutions keeps a much higher portion of our energy dollars here in Vermont, creates family-sustaining jobs, and spurs economic growth.

TCI-P offers an historic opportunity to advance solutions that recognize our shared responsibility to take climate action, improve our ailing transportation infrastructure, stimulate our economy, and strengthen our most vulnerable communities.