TCI Regional Policy Design Stakeholder Submissions

I'm opposed to the proposal because it would unfairly burden the residents of Pennsylvania who already pay some of the highest gasoline taxes in the country.

Please find attached joint comments from 13 organizations on the reference case modeling results presented on the August 8th TCI webinar and on the TCI states' next steps in modeling. Thank you.

To: TCI
From: Ellen Valentino
Subject: Proposed Draft Regional Policy
Date: November 5, 2019

The members of the Mid-Atlantic Petroleum Distributors Association (MAPDA) respectfully submit comments regarding the TCI framework and proposal released this fall. Our members are deeply concerned that the framework is moving ahead to foregone conclusions that are not substantiated by the real-world experience of other states.

The Transportation Climate Initiative sets out a framework that imposes an unfair burden on all vehicle owners and thousands of businesses, including those of our members. The proposal outlines a program that will cap the sale of gasoline, tax it, and then require the revenue generated to be spent on new government programs and projects that will further reduce the sale of gasoline. Some of the projects envisioned have ramifications that have not been verified or well thought out.

Electric vehicles are not the only answer.
The framework pins emissions reduction on electric vehicles, or EVs to reduce gasoline sales. EVs are not the magic bullet to solving greenhouse gas emissions. An EV's massive battery must be charged with electricity, which requires power generated from another source such as coal, natural gas or even nuclear power, and has an adverse environmental impact upon disposal. Pushing consumers to electric vehicles has not been shown to lessen environmental impact due to the environmental costs of EV batteries and manufacture of new vehicles. Further, programs such as incentives to EV purchase often favor wealthier individuals while the new taxes on gasoline will disproportionate affect poor and rural communities.

Our members are at a geographic disadvantage.
The northeast compact has a greater impact on Maryland and Delaware than the other Northeast states. Geographically, Maryland and Delaware retailers will suffer the most because consumers may more easily choose to go elsewhere for fuel. It won’t just be gasoline prices that rise to meet the TCI demands. The Northeast is a major trucking corridor and this proposal will essentially raise prices on transported goods. California’s Cap and Trade program, upon which the TCI framework is based, has led to a surge in gasoline prices, which affects all aspects of the economy.

All voices are not being heard.
Although this proposal has been pitched as a consensus document, in fact, it is not. There have been only three work sessions and less than a handful of webinars to solicit public feedback and comment. The framework is not ready for adoption by the states as too many points have not been clarified and fleshed out. No one really knows the full detail of the proposal. More outreach and public input needs to happen to shift this to a consensus. At the present, the framework appears to be a predisposed outcome. I urge that the participating Governors be required personally to attend and hold public hearings throughout their states. Our members are willing to work with others on this issue to create a true collaborative plan.

The current proposal will not achieve its goals.
California enacted a similar program recently, and, by most accounts, their gasoline costs have skyrocketed while the environmental impact has struggled to show a true measurable benefit. We welcome the opportunity to create a realistic policy proposal that provides a more balanced solution.

Respectfully submitted,

Ellen Valentino

It is essential that we clean up transportation all across this great country, but particularly in the crowded heavily trafficked Northeast corridor.
Incentives (or requirements) that encourage electric vehicles, more reliable charging network, transitioning to renewables as the primary energy source. Battery capacity is now much improved.
Also, keep supporting good public transportation options, including for the last mile.
Thank you!

POLICY STATEMENT
Transportation & Climate Initiative (TCI)
The Transportation & Climate Initiative (TCI) is a regional collaboration of 12 states in the Northeast and Mid-Atlantic regions that’s intended purpose is to reduce carbon dioxide emissions from the transportation sector. Specifically, the goal of TCI is to create a “regional, low-carbon transportation policy proposal that would cap and reduce carbon emissions from the combustion of transportation fuels.” Maryland announced participation in the coalition in December 2018, and since that time there have been a number of regional stakeholder meetings seeking input on overall regional transportation priorities, potential emissions reductions goals, and policy proposals to meet those targets.
As this process continues to move forward, the Maryland Chamber of Commerce (MDCC) urges that the following principles be taken into account as Maryland and policymakers work toward a regional transportation policy proposal:
1) Transparency. An open and public process is critical to the formation of sound public policy. The MDCC urges that any proposals brought forward to achieve the goals laid out by TCI be subject to rigorous analysis that recognizes both the benefits and costs to the public and the business community. As well, proposals should be subject to a thorough and public vetting process while being considered as potential pathways to meeting TCI’s targets.

2) Market-Based. Market-based solutions have proven to be successful in providing the level of flexibility needed to meet environmental goals cost-effectively. The MDCC believes that any proposal put forward should be market-based, as these types of policies are most cost-effective and spur the innovation necessary to achieve positive outcomes.

3) Dedicated Revenue. Many market-based policies have the potential of generating revenue. The MDCC advocates that any revenue generated from TCI be dedicated to programs and initiatives that contribute to cost-effective energy and environmental solutions rather than returned to the General Fund or used for other purposes.

The Sierra Club is sharing the attached 561 comments from our members and supporters in Maryland supporting finalizing the Draft Memorandum of Understanding (MOU) of the Transportation and Climate Initiative (TCI). Thank you for helping to design a regional policy to limit climate pollution from motor fuels and invest in a modern, clean, transportation future. The evidence is clear: the more we limit pollution from motor fuels, the more jobs are created, the more the economy grows, and the more lives we save. Please sign on to the agreement to implement a strong, equitable regional climate protection policy through TCI. Invest in the communities that have suffered the most from burning gasoline and have the least access to clean transportation options. Stop sending our hard-earned dollars out of the state to oil companies, and choose to create jobs, grow the economy, and save lives for families and businesses. Thank you.

Anything to be done to combat climate change is imperative. Reducing carbon emissions with incentives is a good step in the right direction.

Please see a letter attached from members of the Transit Caucus in the Maryland General Assembly.

Climate change is an existential threat to our country, our civilization, our world. The carbon dioxide that we, collectively, pump into the atmosphere year after year is a major cause of climate change, and transportation is a main source of carbon emissions. Please take action now to price carbon emission from all sources, including transportation, to (1) incentivize people to reduce their carbon footprints, and (2) provide revenue that'll be used for both research into and projects based on non-carbon-based energy alternatives to coal and oil.