View Public Input on TCI-P

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 effort is bad policy for Virginia to adopt. It penalizes those who communte long distance and offers no benefits to either the state's road systems. Studies indicate this regressive form of taxation will not have the desired effects on the enviornment, actually providing negligible benefits while disprapotionately imposing higher commuting costs on low and middle income families.

As noted in the Free Lance-Star, this is an "all pain and no gain" proposal for drivers, especially low income rural and those who commute distances because they can't afford to live in high cost cities. This proposal would take away critical funds needed to maintain roads that are still needed even if electric vehicle usage is increased, and cause hardship due to the prices increases passed on to consumers, all for .000018 degree C reduction in global warming (according to Dr. David Schnare, a 34 year veteran of the EPA). Add that to the madness of pushing electric vehicles which have a massive production impact on global warming and the environment that takes years to break even on from reduced emissions, and it is clear to see how the TCI-P is a bad idea.

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.

This is not a good idea. It is just the way to try to get more money from the citizens of Virginia to pay for miniscule environmental benefits. DO NOT APPROVE THIS. It is a terrible idea for Virginia in EVERY way possible.

TCI sounds nice, but won't work while hurting poor families and taking money from road repair.

NO Carbon Taxes. This concept is a fraud and does not help the environment or the consumer.

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.

Bridget McGregor