TCI Regional Policy Design Stakeholder Submissions

This comment is in response to the second panel discussion at today's Technical Workshop in Boston that discussed investments that could be made to the transportation system with revenue generated from a TCI program. There were several examples of electrifying the transportation sector as one type of investment that other regions (Quebec, California?) have made with funds from cap and trade programs. While electrifying the transportation sector decreases carbon emissions, so too does a reduction in VMT. Investments in active transportation infrastructure (walking, biking and transit) would not only reduce emissions, but would also make our roads safer for the most vulnerable users. Redesigning our road network to increase options for people to choose safe walking and biking opportunities would complement electrification and provide needed capital funding to make roads safer for all. It will be important to ensure that TCI revenue reinforces related, complementary policies and systems, as well as working to transition our fossil fuel-based transportation system to a more carbon neutral one.

I strongly support the Transportation and Climate Initiative. The transportation sector accounts for a third of all carbon emissions so we must make changes to this sector to avert the worst of climate change. We need a plan that holds large transportation polluters accountable for the pollution they create and invests in clean transportation solutions including:

- More public transit and electric vehicle infrastructure in rural areas,
- Expansion of commuter rail, electric vehicles, and streets in the suburbs that are safe, walkable, and bikeable,
- Sustainable and equitable housing near transit and electric bus fleets in urban communities.

Please see the attached comments of Conservation Law Foundation ("CLF") in support of the December 17, 2019 draft memorandum of understanding (“MOU”) of the Transportation and Climate Initiative (“TCI”) and recommending several changes for incorporation into the final MOU.

Xpress Markets, Inc., currently employs 90 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.

Xpress Markets, 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 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?

Xpress Markets, Inc opposes the TCI plan to ration, tax and ultimately eliminate fossil fuels.

We need to get as many people as possible out of automobiles. One way to do that is by developing a comprehensive bike trail network that allows commuters to get to and from where they need to go safely.

"AUGUSTA – Governor Janet Mills is negotiating a multi-state agreement that could sharply increase the cost of gasoline and diesel for Maine people, and Mainers should take the opportunity to weigh in with their comments, says a group that advocates for Maine’s taxpayers and consumers."

As the people in the State of Maine are already the 3rd highest taxed population in the nation, and because Maine's economy is still struggling (even after the tremendous advances made by Governor LePage) the last thing we need is an increase in taxes based on junk science about climate change! These political scares about the impending devastation of our planet have been circulating for more than 120 years, and they are no more credible now than they were back then.

I believe this is doomed to fail in reducing admissions, will disproportionately hurt low income citizens and is being advanced without appropriate legislative action in the various states it has been proposed in. I vehemently oppose this being enacted without legislative approval.

The key to wider adoption of electric vehicles is building out a robust fast-charging infrastructure. Until consumers see DC fast-charging stations as a practical alternative to gas stations, they will be reluctant to consider buying electric cars. TCI should incentive or subsidize installation of tens of thousands of fast-charging stations of minimum 150 kW -- and the signage and advertising necessary to give them visibility to the wider public. New regulations could even REQUIRE gas stations to provide space for charging vendors like EVgo, Electrify America, Tesla, or local power authorities, to install EV fast-charging stations.

Level 2 charging stations are far less useful in general - but would be very useful in urban areas if paired with parking spots where residents could leave their cars overnight or throughout the week. These should be special street parking areas with Level 2 charging stations and suitable enforcement to heavily penalize internal combustion cars from parking in those spots. In my location (Brooklyn, NY), where most people don't have driveways, I'm sure that more people would buy EV's if they would be assured of parking spots paired with Level 2 charging!

I own a Tesla Model 3. I charge it from my home when I can get the parking spot in front of my house, and I frequently use Tesla Superchargers when I travel. But not everyone can organize their lives around parking and charging; we need to make electric vehicle charging as plentiful as gas stations.

I attended one of the information meetings on the TCI that was held in Manchester, VT. It makes so much sense to me that we join forces with other states (following the example of REGGI) to make sure that we can make a serious impact on addressing the major contributor of our carbon footprint. No plan is perfect, but we mustn't let the perfect be the enemy of the good. At this critical juncture, without a plan at all, we would be signing away this planet's future. I refuse to do that to my children. Or anyone else's.