8/13/2021 |
Michael |
Walz |
POET LLC |
Washington |
District of Columbia |
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... read more 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
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POET TCI Model Rule Comment Letter.pdf |
8/13/2021 |
Paul |
Wierenga |
Independent Fuel Terminal Operators Association |
Washington |
District of Columbia |
Please see enclosed comments Please see enclosed comments |
Comments of IFTOA on Draft Framework for Public Engagement_Model Implementation Plan_Regional Collaboration Strategies (8.13.2021).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 |
8/13/2021 |
Bill |
Pugh |
Coalition for Smarter Growth |
Washington, DC |
District of Columbia |
See attached comments by the Coalition for Smarter Growth on the draft TCI-P documents released June 10, 2020.
In summary, we recommend that TCI-P track and report on Vehicle Miles... read more See attached comments by the Coalition for Smarter Growth on the draft TCI-P documents released June 10, 2020.
In summary, we recommend that TCI-P track and report on Vehicle Miles Traveled (VMT) by jurisdiction to gauge accountability and progress (in addition to air quality monitoring), and that the region coordination strategies include land use strategies, such as encouraging and coordinating transit-oriented development and affordable housing near transit. |
CSG TCI-P document comments Aug 13 2021.pdf |
5/4/2021 |
faith |
bieler |
Vt. citizen |
waterbury center |
Vermont |
Please...invest in cleaner more equitable transportation...putting a brake on carbon emissions!!
Thanks you,
Faith Please...invest in cleaner more equitable transportation...putting a brake on carbon emissions!!
Thanks you,
Faith |
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4/27/2021 |
William |
April |
VPIRG |
Waterbury Ctr |
Vermont |
We need the TCI-P to create and manage a more equitable and inexpensive public transit system. We need to add more electric powered vehicles- vans, buses, and cars. We need to cut down the green... read more We need the TCI-P to create and manage a more equitable and inexpensive public transit system. We need to add more electric powered vehicles- vans, buses, and cars. We need to cut down the green house gases for all our health. |
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5/4/2021 |
William |
April |
VPIRG |
Waterbury Ctr |
Vermont |
I support the TCI-P because WE will not reap the regional benefits if WE are not part of it. This program will keep the region in its' best position to control pricing and distribution of... read more I support the TCI-P because WE will not reap the regional benefits if WE are not part of it. This program will keep the region in its' best position to control pricing and distribution of funds. Please support it. |
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5/7/2021 |
Edward |
Long |
Longhill Technologies |
Waynesboro |
Virginia |
As a Ph.D. Physicist I am technically aware of the burdensome cost and technically ineffectiveness of the Transportation Climate Initiative (TCI.)
Virginia should not join the TCI because... read more As a Ph.D. Physicist I am technically aware of the burdensome cost and technically ineffectiveness of the Transportation Climate Initiative (TCI.)
Virginia should not join the TCI because the people of Virginia can not afford the burdens the TCI would impose.
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5/7/2021 |
Edward |
Long |
Longhill Technologies |
Waynesboro |
Virginia |
As a Ph.D. Physicist I am technically aware of the burdensome cost and technically ineffectiveness of the Transportation Climate Initiative (TCI.)
Virginia should not join the TCI because... read more As a Ph.D. Physicist I am technically aware of the burdensome cost and technically ineffectiveness of the Transportation Climate Initiative (TCI.)
Virginia should not join the TCI because the people of Virginia can not afford the burdens the TCI would impose.
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9/17/2021 |
John |
McGannon |
TVSU |
Westbrook |
Connecticut |
TCI-P is a smart, proactive, fair and innovative piece of legislation that will create jobs & require that polluters do their share to create accountability, economic and environmental... read more TCI-P is a smart, proactive, fair and innovative piece of legislation that will create jobs & require that polluters do their share to create accountability, economic and environmental justice. We should be proud to support TCI-P. Do your homework -- you'll see! It is NOT a tax on gasoline. Businesses support it, 70% of CT residents support it, and we all should let our state senators and legislative leaders know that we want to make our state a leader in fighting climate change and supporting just solutions! |
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5/5/2021 |
Terry |
Bosworth |
democrat |
Westford |
Vermont |
Terrific plan! Reduce pollution, stimulate the economy, focus on the most needy, cooperate with other states. Please support TCI-P Terrific plan! Reduce pollution, stimulate the economy, focus on the most needy, cooperate with other states. Please support TCI-P |
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4/27/2021 |
SPENCER |
PUTNAM |
Climate Economy Action Center |
Weybridge |
Vermont |
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... read more 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. |
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4/12/2021 |
Juan |
Briceno |
Benchmark Renewable Energy |
Wilkesboro |
North Carolina |
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... read more 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 |
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5/7/2021 |
Leonard |
Scharf |
NTRA |
Williamsburg |
Virginia |
I call for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and under served communities in Virginia receive a greater-then-proportional share of investments... read more I call for the TCI-P Model Rule to include (1) a minimum investment amount to ensure overburdened and under served communities in Virginia receive a greater-then-proportional share of investments from the program, (2) integration of air quality commitments across Virginia, and (3) robust empowerment of Virginia's Equity Advisory Body." |
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5/7/2021 |
Darleen |
Rudnick |
self |
Williamsburg |
Virginia |
I'm opposed to Virginia joining the TCI. It will cost consumers and businesses too much at the gas pump. read more I'm opposed to Virginia joining the TCI. It will cost consumers and businesses too much at the gas pump. |
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4/27/2021 |
Ark |
Lemal |
? |
Williston |
Vermont |
The sooner we stop paying for fossil fuels to move ourselves around the state, the fewer dollars leave the state and less CO2 ends up in the atmosphere. It's a win-win for VT. Let's get... read more The sooner we stop paying for fossil fuels to move ourselves around the state, the fewer dollars leave the state and less CO2 ends up in the atmosphere. It's a win-win for VT. Let's get on this! Let simultaneously incentivize individual homeowners and communities putting up solar to feed our local grid the power we'll need. Homegrown is the VT way! |
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4/27/2021 |
Kathleen Voigt |
Walsh |
Resident of Vermont |
Winooski |
Vermont |
In any and all plans, it is a MUST that all communities be brought to the table. By this I mean, community-specific outreach must be made to communities whose voices in the past have been absent... read more In any and all plans, it is a MUST that all communities be brought to the table. By this I mean, community-specific outreach must be made to communities whose voices in the past have been absent due to inequities of income, class, education, occupation, race, and culture. In our community of Winooski, the most diverse in Vermont, it took Students to educate the Schools on racial equity, for example!
Attention to Equity in addressing Climate and Energy is essential for our country's future. Whether farmer, hourly service worker or caregiver, immigrant, tradesperson, or businessperson, educator, or what have you, some people will be more apt to show up in this kind of questionnaire. If groups of people are not being heard from, reach out to them. I believe this will result in the most effective and just changes going forward.
Thank you,
Kathleen Voigt Walsh
Winooski, VT 05404 |
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5/4/2021 |
Michael |
Gore |
Home Healthcare |
Worcester |
Vermont |
Many of the clients that I work with would benefit from this initiative. Many of the clients that I work with would benefit from this initiative. |
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5/5/2021 |
James |
O'Hanlon |
Business owner/EV owner |
Worcester |
Vermont |
Hello,
I am a business owner and environmentally minded resident of Vermont. I am also an EV driver and have been since 2014. Since I purchased my first EV 7 years ago I have seen the... read more Hello,
I am a business owner and environmentally minded resident of Vermont. I am also an EV driver and have been since 2014. Since I purchased my first EV 7 years ago I have seen the number of electric vehicle in Vermont increase substantially, yet the charging infrastructure has remained almost unchanged. How can the state claim to encourage EV ownership and use without providing the charging infrastructure to support that? Specifically, Level II chargers are good for park and ride and workplace locations only. Regular drivers need Level III chargers in locations near stores, restaurants or other facilities in order to make EV's a viable option. Level II chargers in easy to find locations with multiple chargers. This is what Tesla did from the beginning. The gas car companies that are producing the rest of the EV's on the road are apparently not interested in providing the charging infrastructure to support their products, so it must then fall to the state. Level III chargers. The state does not need to expend any more funds on Level II chargers. These are inexpensive and businesses can provide these as a courtesy to their employees. Level III chargers allow EV drivers the freedom and mobility to take longer trips and go more places without worrying about running out of charge. Level III chargers please, and at least 4 at each location. Thank you |
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5/4/2021 |
Kevin |
Leveret |
with all that is righteous |
wrj |
Vermont |
Why shouldn't agents of ecologic devastation (from litterbugs to corporations) be fined a sum commiserate with the cost of clean-up? Why hasn't such legislation already been enacted ...... read more Why shouldn't agents of ecologic devastation (from litterbugs to corporations) be fined a sum commiserate with the cost of clean-up? Why hasn't such legislation already been enacted ...what are we waiting for... a tipping point? Call or write your representatives, your town government, your governors, neighbors, kith and kin, and don’t forget your president! We Need Climate Action RIGHT NOW! |
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