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.

we do not want it. it will have major effect on small business owners, employees and over economy.

This will have a serious negative impact on our industry, including all of our employees and their families. Please do not adopt this policy!

As a small business owner in the fuel sales industry, I am NOT in favor of TCI as it is currently proposed because I believe the negative impacts will outweigh the positive impacts. People's jobs, livelihood, and families will be incredibly adversely affected by the aggressiveness of the proposed plan. Such severe caps and reductions within the proposed time frame are unreasonable without an acceptable alternative for sellers and consumers. Moreover, I wholeheartedly believe that this plan will NOT bring us any closer to accomplishing the overarching objective of creating a major reduction in carbon emissions. This can ONLY be accomplished by targeting the largest sources of carbon emissions, namely agriculture, coal mining, deforestation, jet fuel emissions, and burning fossil fuels for heat and electricity. In an already densely populated region that continues to rapidly expand, reduction of fuel for transportation will wreak havoc. It should not go unmentioned that we have an incredibly unreliable public transportation system that CANNOT be considered an alternative nor a method by which we can reduce emissions in our area. A positive global impact on emissions should be the ultimate objective since your efforts will be for naught without global participation and buy-in; we all share the same atmosphere. To really address the issue of carbon emissions, you need to look at the biggest state emitters, such as China, Japan, and India. Until there is action on a global scale, our climate will continue to be adversely affected, no matter what the TCI does. There are "bigger fish to fry," so to speak, and TCI is NOT the appropriate answer because its positive impact, IF ANY, will be negligible when compared to the biggest, real threats to our environment. However, its negative impact on jobs, families, and communities will be astounding and immediately felt. People will associate TCI with the jobs they lost, the money wasted on a failed initiative, and the ensuing chaos it created, not for its impact on the environment and our climate because it will have none that are lasting.

When polled consistently the majority state that the amount of regulations and goals are not worth the cost

It is essential that the USA be able to continue transportation in a era when climate change is a crisis. A carbon neutral transportation system is essential to that goal.

With our federal government abdicating leadership on climate issues - and, in fact, acting in openly destructive ways - it is up to states to take the lead. Economists have consensus, similar to the scientific consensus on climate change, that appropriate carbon-pricing strategies could significantly reduce emissions.