TCI Regional Policy Design Stakeholder Submissions

Sadler Brothers Oil Company which employs 87 people and provides petroleum for other companies that employ hundreds of employees in Virginia is strongly opposed to the "framework for a draft regional policy proposal" which seeks to expropriate the petroleum marketing industry. Over time this plan proposes to move Virginia from simple rationing and new taxes to the ultimate prohibition of fossil fuels.
This plan does not assess the collateral damage it will inflict on state revenue, local tax collections, Virginia's Transportation Trust fund, and consumers.
Many of the advocates of these policies support regulation to electrify transportation. Those advocates somehow forget to mention that a major component of batteries powering these vehicles is cobalt, 90 percent of which is mined in third world countries under unfavorable working conditions.
As the number of electric vehicles grows, petroleum marketers will likely have to battle for a share of the electric vehicle charging market with utility companies that see EV charging as a new business opportunity without cost. When utility companies install charging stations, they may seek the ability to include that cost as part of their capital investment. When these costs are approved by governmental regulatory agencies, they can then be passed on to all ratepayers as part of their monthly electric bills.
Sadler Brothers Oil Company believes this would provide regulated utilities an unfair competitive advantage that Virginia based small businesses simply cannot compete with. I must economically justify and self-fund at risk investments in new equipment like EV charging stations and so should my competition.
Another likely competitor under this scheme is the state government itself. This is not a concept, as just this past session the General Assembly passed legislation to allow the Departments of Conservation and Recreation, General Services, and Transportation to install electric chargers. Fortunately our association was able to narrow this initiative considerably by limiting the number of state agencies involved and mitigating the threat of unfair competition by requiring the state to sell the power at prevailing market rates including taxes.
All Virginians, particularly the petroleum marketing and convenience industries, support a clean environment. There are many ways to achieve this without rationing. Incentivizing the sale of electric vehicles does nothing to meet your stated goals of "equity, environmental justice, and non-discrimination." As one example, the stated goals could be achieved far faster and cheaper via efforts to assist low-income Virginians to purchase more fuel efficient vehicles that meet current and future CAFÉ standards.
History has proven that rationing followed by prohibition - the ultimate goal of TCI - has led to black markets, unregulated and untaxed sales, and undue burdens on law enforcement.
The impact of these proposals will not be solely on fuel sellers and convenience stores - what about the auto repair industry, muffler shops, service facilities at new car dealers, quick lubes etc.? What about agriculture, construction, Loggers and watermen who will be forced to scrap present equipment or pay artificially high prices due to rationing? What about the consumer who will experience not only higher prices to operate their personal vehicles, but higher prices for consumer goods and services?
The impact of these proposals will completely devastate Virginia’s economics. Recent information predicts an alternative fuel source for Commercial Trucks are 15 to 20 years out, Trucking companies have utilized Virginia interstates I95, I85 and I81 for years which allowed the state and individual companies to benefit from them stopping and doing business on these popular travel routes. The proposals will cause most companies to route the trucks around the state devastating businesses.
Sadler Brothers Oil Company opposes the TCI plan to ration, tax and ultimately eliminate fossil fuels.

Hastings Holdings, LLC which employs 29 people and provides petroleum for other companies that employ hundreds of employees in Virginia is strongly opposed to the "framework for a draft regional policy proposal" which seeks to expropriate the petroleum marketing industry. Over time this plan proposes to move Virginia from simple rationing and new taxes to the ultimate prohibition of fossil fuels.
This plan does not assess the collateral damage it will inflict on state revenue, local tax collections, Virginia's Transportation Trust fund, and consumers.
Many of the advocates of these policies support regulation to electrify transportation. Those advocates somehow forget to mention that a major component of batteries powering these vehicles is cobalt, 90 percent of which is mined in third world countries under unfavorable working conditions.
As the number of electric vehicles grows, petroleum marketers will likely have to battle for a share of the electric vehicle charging market with utility companies that see EV charging as a new business opportunity without cost. When utility companies install charging stations, they may seek the ability to include that cost as part of their capital investment. When these costs are approved by governmental regulatory agencies, they can then be passed on to all ratepayers as part of their monthly electric bills.
Hastings Holdings, LLC believes this would provide regulated utilities an unfair competitive advantage that Virginia based small businesses simply cannot compete with. I must economically justify and self-fund at risk investments in new equipment like EV charging stations and so should my competition.
Another likely competitor under this scheme is the state government itself. This is not a concept, as just this past session the General Assembly passed legislation to allow the Departments of Conservation and Recreation, General Services, and Transportation to install electric chargers. Fortunately our association was able to narrow this initiative considerably by limiting the number of state agencies involved and mitigating the threat of unfair competition by requiring the state to sell the power at prevailing market rates including taxes.
All Virginians, particularly the petroleum marketing and convenience industries, support a clean environment. There are many ways to achieve this without rationing. Incentivizing the sale of electric vehicles does nothing to meet your stated goals of "equity, environmental justice, and non-discrimination." As one example, the stated goals could be achieved far faster and cheaper via efforts to assist low-income Virginians to purchase more fuel efficient vehicles that meet current and future CAFÉ standards.
History has proven that rationing followed by prohibition - the ultimate goal of TCI - has led to black markets, unregulated and untaxed sales, and undue burdens on law enforcement.
The impact of these proposals will not be solely on fuel sellers and convenience stores - what about the auto repair industry, muffler shops, service facilities at new car dealers, quick lubes etc.? What about agriculture, construction, Loggers and watermen who will be forced to scrap present equipment or pay artificially high prices due to rationing? What about the consumer who will experience not only higher prices to operate their personal vehicles, but higher prices for consumer goods and services?
The impact of these proposals will completely devastate Virginia’s economics. Recent information predicts an alternative fuel source for Commercial Trucks are 15 to 20 years out, Trucking companies have utilized Virginia interstates I95, I85 and I81 as a major travel corridor for years which allowed the state and individual companies to benefit from them stopping and doing business on these popular travel routes. The proposals will cause the majority of companies to route their trucks around the state devastating businesses.
Hastings Holdings, LLC opposes the TCI plan to ration, tax and ultimately eliminate fossil fuels.

Sadler Investments Corporation which helps employ numerous people is strongly opposed to the "framework for a draft regional policy proposal" which seeks to expropriate the petroleum marketing industry. Over time this plan proposes to move Virginia from simple rationing and new taxes to the ultimate prohibition of fossil fuels.
This plan does not assess the collateral damage it will inflict on state revenue, local tax collections, Virginia's Transportation Trust fund, and consumers.
Many of the advocates of these policies support regulation to electrify transportation. Those advocates somehow forget to mention that a major component of batteries powering these vehicles is cobalt, 90 percent of which is mined in third world countries under unfavorable working conditions.
As the number of electric vehicles grows, petroleum marketers will likely have to battle for a share of the electric vehicle charging market with utility companies that see EV charging as a new business opportunity without cost. When utility companies install charging stations, they may seek the ability to include that cost as part of their capital investment. When these costs are approved by governmental regulatory agencies, they can then be passed on to all ratepayers as part of their monthly electric bills.
Sadler Investments Corporation believes this would provide regulated utilities an unfair competitive advantage that Virginia based small businesses simply cannot compete with. I must economically justify and self-fund at risk investments in new equipment like EV charging stations and so should my competition.
Another likely competitor under this scheme is the state government itself. This is not a concept, as just this past session the General Assembly passed legislation to allow the Departments of Conservation and Recreation, General Services, and Transportation to install electric chargers. Fortunately our association was able to narrow this initiative considerably by limiting the number of state agencies involved and mitigating the threat of unfair competition by requiring the state to sell the power at prevailing market rates including taxes.
All Virginians, particularly the petroleum marketing and convenience industries, support a clean environment. There are many ways to achieve this without rationing. Incentivizing the sale of electric vehicles does nothing to meet your stated goals of "equity, environmental justice, and non-discrimination." As one example, the stated goals could be achieved far faster and cheaper via efforts to assist low-income Virginians to purchase more fuel efficient vehicles that meet current and future CAFÉ standards.
History has proven that rationing followed by prohibition - the ultimate goal of TCI - has led to black markets, unregulated and untaxed sales, and undue burdens on law enforcement.
The impact of these proposals will not be solely on fuel sellers and convenience stores - what about the auto repair industry, muffler shops, service facilities at new car dealers, quick lubes etc.? What about agriculture, construction, Loggers and watermen who will be forced to scrap present equipment or pay artificially high prices due to rationing? What about the consumer who will experience not only higher prices to operate their personal vehicles, but higher prices for consumer goods and services?
The impact of these proposals will completely devastate Virginia’s economics. Recent information predicts an alternative fuel source for Commercial Trucks are 15 to 20 years out, Trucking companies have utilized Virginia interstates I95, I85 and I81 as a major travel corridor for years which allowed the state and individual companies to benefit from them stopping and doing business on these popular travel routes. The proposals will cause the majority of companies to route their trucks around the state devastating businesses.
Sadler Investments Corporation opposes the TCI plan to ration, tax and ultimately eliminate fossil fuels.

The Sadler Barn, LLC which helps employ numerous people and is strongly opposed to the "framework for a draft regional policy proposal" which seeks to expropriate the petroleum marketing industry. Over time this plan proposes to move Virginia from simple rationing and new taxes to the ultimate prohibition of fossil fuels.
This plan does not assess the collateral damage it will inflict on state revenue, local tax collections, Virginia's Transportation Trust fund, and consumers.
Many of the advocates of these policies support regulation to electrify transportation. Those advocates somehow forget to mention that a major component of batteries powering these vehicles is cobalt, 90 percent of which is mined in third world countries under unfavorable working conditions.
As the number of electric vehicles grows, petroleum marketers will likely have to battle for a share of the electric vehicle charging market with utility companies that see EV charging as a new business opportunity without cost. When utility companies install charging stations, they may seek the ability to include that cost as part of their capital investment. When these costs are approved by governmental regulatory agencies, they can then be passed on to all ratepayers as part of their monthly electric bills.
The Sadler Barn, LLC believes this would provide regulated utilities an unfair competitive advantage that Virginia based small businesses simply cannot compete with. I must economically justify and self-fund at risk investments in new equipment like EV charging stations and so should my competition.
Another likely competitor under this scheme is the state government itself. This is not a concept, as just this past session the General Assembly passed legislation to allow the Departments of Conservation and Recreation, General Services, and Transportation to install electric chargers. Fortunately our association was able to narrow this initiative considerably by limiting the number of state agencies involved and mitigating the threat of unfair competition by requiring the state to sell the power at prevailing market rates including taxes.
All Virginians, particularly the petroleum marketing and convenience industries, support a clean environment. There are many ways to achieve this without rationing. Incentivizing the sale of electric vehicles does nothing to meet your stated goals of "equity, environmental justice, and non-discrimination." As one example, the stated goals could be achieved far faster and cheaper via efforts to assist low-income Virginians to purchase more fuel efficient vehicles that meet current and future CAFÉ standards.
History has proven that rationing followed by prohibition - the ultimate goal of TCI - has led to black markets, unregulated and untaxed sales, and undue burdens on law enforcement.
The impact of these proposals will not be solely on fuel sellers and convenience stores - what about the auto repair industry, muffler shops, service facilities at new car dealers, quick lubes etc.? What about agriculture, construction, Loggers and watermen who will be forced to scrap present equipment or pay artificially high prices due to rationing? What about the consumer who will experience not only higher prices to operate their personal vehicles, but higher prices for consumer goods and services?
The impact of these proposals will completely devastate Virginia’s economics. Recent information predicts an alternative fuel source for Commercial Trucks are 15 to 20 years out, Trucking companies have utilized Virginia interstates I95, I85 and I81 as a major travel corridor for years which allowed the state and individual companies to benefit from them stopping and doing business on these popular travel routes. The proposals will cause the majority of companies to route their trucks around the state devastating businesses.
The Sadler Barn, LLC opposes the TCI plan to ration, tax and ultimately eliminate fossil fuels.

Slip-in Food Marts, INC which employs 42 people is strongly opposed to the "framework for a draft regional policy proposal" which seeks to expropriate the petroleum marketing industry. Over time this plan proposes to move Virginia from simple rationing and new taxes to the ultimate prohibition of fossil fuels.
This plan does not assess the collateral damage it will inflict on state revenue, local tax collections, Virginia's Transportation Trust fund, and consumers.
Many of the advocates of these policies support regulation to electrify transportation. Those advocates somehow forget to mention that a major component of batteries powering these vehicles is cobalt, 90 percent of which is mined in third world countries under unfavorable working conditions.
As the number of electric vehicles grows, petroleum marketers will likely have to battle for a share of the electric vehicle charging market with utility companies that see EV charging as a new business opportunity without cost. When utility companies install charging stations, they may seek the ability to include that cost as part of their capital investment. When these costs are approved by governmental regulatory agencies, they can then be passed on to all ratepayers as part of their monthly electric bills.
Slip-in Food Marts, INC believes this would provide regulated utilities an unfair competitive advantage that Virginia based small businesses simply cannot compete with. I must economically justify and self-fund at risk investments in new equipment like EV charging stations and so should my competition.
Another likely competitor under this scheme is the state government itself. This is not a concept, as just this past session the General Assembly passed legislation to allow the Departments of Conservation and Recreation, General Services, and Transportation to install electric chargers. Fortunately our association was able to narrow this initiative considerably by limiting the number of state agencies involved and mitigating the threat of unfair competition by requiring the state to sell the power at prevailing market rates including taxes.
All Virginians, particularly the petroleum marketing and convenience industries, support a clean environment. There are many ways to achieve this without rationing. Incentivizing the sale of electric vehicles does nothing to meet your stated goals of "equity, environmental justice, and non-discrimination." As one example, the stated goals could be achieved far faster and cheaper via efforts to assist low-income Virginians to purchase more fuel efficient vehicles that meet current and future CAFÉ standards.
History has proven that rationing followed by prohibition - the ultimate goal of TCI - has led to black markets, unregulated and untaxed sales, and undue burdens on law enforcement.
The impact of these proposals will not be solely on fuel sellers and convenience stores - what about the auto repair industry, muffler shops, service facilities at new car dealers, quick lubes etc.? What about agriculture, construction, Loggers and watermen who will be forced to scrap present equipment or pay artificially high prices due to rationing? What about the consumer who will experience not only higher prices to operate their personal vehicles, but higher prices for consumer goods and services?
The impact of these proposals will completely devastate Virginia’s economics. Recent information predicts an alternative fuel source for Commercial Trucks are 15 to 20 years out, Trucking companies have utilized Virginia interstates I95, I85 and I81 as a major travel corridor for years which allowed the state and individual companies to benefit from them stopping and doing business on these popular travel routes. The proposals will cause the majority of companies to route their trucks around the state devastating businesses.
Slip-in Food Marts, INC opposes the TCI plan to ration, tax and ultimately eliminate fossil fuels.

This mandate will affect my business. this is how we make ends meets. In the past decade, we have seen gas sales drop drastically as car became more efficient and with the introduction of electric cars. we understand that this is part of the innovation in life. However, which we don't understand, is the Government trying to impose more restrictions and taxes on our industry as if it is waging a war against it. A free economy will always find the best way in the most effective manner on its own. once you start trying to force it one way or another it will cause more harm than good. Please don't pass this mandate and let the free economy do its thing.

this would shut down small business like us , which are the backbone of the comminity

• AmeriGas Propane employees over 9,000+ people and we are strongly opposed to the "framework for a draft regional policy proposal" which seeks to expropriate the fossil fuel industry. Over time this plan proposes to move Virginia from simple rationing and new taxes to the ultimate prohibition of fossil fuels.
• This plan does not assess the collateral damage it will inflict on state revenue, local tax collections, Virginia's Transportation Trust fund, and consumers.
• Many of the advocates of these policies support regulation to electrify transportation. Those advocates somehow forget to mention that a major component of batteries powering these vehicles is cobalt, 90 percent of which is mined in third world countries under unfavorable working conditions.
• As the number of electric vehicles grows, petroleum marketers will likely have to battle for a share of the electric vehicle charging market with utility companies that see EV charging as a new business opportunity without cost. When utility companies install charging stations, they may seek the ability to include that cost as part of their capital investment. When these costs are approved by governmental regulatory agencies, they can then be passed on to all ratepayers as part of their monthly electric bills.
• AmeriGas believes this would provide regulated utilities an unfair competitive advantage that Virginia based small businesses simply cannot compete with. I must economically justify and self-fund at risk investments in new equipment like EV charging stations and so should my competition.
• Another likely competitor under this scheme is the state government itself. This is not a concept, as just this past session the General Assembly passed legislation to allow the Departments of Conservation and Recreation, General Services, and Transportation to install electric chargers. Fortunately our association was able to narrow this initiative considerably by limiting the number of state agencies involved and mitigating the threat of unfair competition by requiring the state to sell the power at prevailing market rates including taxes.
• As a propane marketer I support a clean environment. There are many ways to achieve this without rationing. Incentivizing the sale of electric vehicles does nothing to meet your stated goals of "equity, environmental justice, and non-discrimination." As one example, the stated goals could be achieved far faster and cheaper via efforts to assist low-income Virginians to purchase more fuel efficient vehicles that meet current and future CAFÉ standards.
• History has proven that rationing followed by prohibition - the ultimate goal of TCI - has led to black markets, unregulated and untaxed sales, and undue burdens on law enforcement.
• The impact of these proposals will not be solely on propane businesses such as mine - what about the auto repair industry, muffler shops, service facilities at new car dealers, quick lubes etc.? What about agriculture, construction and watermen who will be forced to scrap present equipment or pay artificially high prices due to rationing? What about the consumer who will experience not only higher prices to operate their personal vehicles, but higher prices for consumer goods and services?
• AmeriGas opposes the TCI plan to ration, tax and ultimately eliminate fossil fuels.

Please see the attached comments from the Southern Environmental Law Center on the TCI Framework for a Draft Regional Policy Proposal. Thank you for your consideration of our comments.