TCI Regional Policy Design Stakeholder Submissions

Maryland Motor Truck Association (MMTA) is a non-profit trade association that has represented the trucking industry since 1935. In service to our 1,000 members, MMTA submits the following comments in response to the Draft Regional Policy Proposal by the Transportation Climate Initiative of the Northeast and Mid-Atlantic States.

Over the past decade, MMTA has worked closely with the Maryland Department of the Environment and the Maryland Energy Administration to design a series of programs to voluntarily reduce commercial motor vehicle emissions. These include grant programs for the purchase of alternative power units, financial assistance to help companies replace older model diesel trucks with clean diesel, natural gas and electric powered vehicles, and the “Idle Free MD” outreach campaign encouraging drivers to turn off their engines and avoid idling whenever possible. Yet the question remains, “How do we achieve the goals in Maryland law – a 40% reduction in greenhouse gas emissions by 2030 – as well as the other stated goals of TCI without major disruptions to business?”

There is clearly no silver bullet that will achieve these goals. To that end, MMTA encourages a multi-faceted strategy that includes:

• A continued focus on voluntary measures backed by financial incentives to assist companies with adoption of cleaner technologies, such as the Port of Baltimore Dray Truck Replacement Program. This program not only helps to reduce air pollution and greenhouse gases associated with the transport of goods to and from the Port of Baltimore, but also supports TCI’s stated goals of equity and environmental justice.
• An approach that considers all fuel options – including some continuation of fossil fuel use, such as clean diesel, natural gas, and biofuels as bridge fuels while other technologies are enhanced to meet the operational needs of the trucking industry. Both biodiesel and renewable diesel fuel are capable of significantly reducing greenhouse gas emissions without the major infrastructure investment that is required for other fuel sources.
• Bid preferences on state contracts for motor carriers that are partners in the Environmental Protection Agency’s SmartWay program and have taken steps to reduce their greenhouse gas emissions voluntarily.
• Investment in transportation infrastructure improvements that promote free flowing mobility of goods. Traffic congestion results in wasted fuel and increased greenhouse gas emissions. Last year the American Transportation Research Institute updated its “Cost of Congestion to the Trucking Industry” report. On the National Highway System alone, traffic delays cost the industry almost 1.2 billion hours, or the equivalent of 425,533 commercial truck drivers sitting idle in traffic without moving for an entire year.
• A focus on the development of more fuel-efficient vehicles. After all, it is pollution, not traveling, that is the concern.

The TCI framework proposes to establish a system to “cap emissions of carbon dioxide from the combustion of the fossil component of finished motor gasoline and on-road diesel fuel in the region.” A “cap and invest” program poses significant challenges for the trucking industry. Our industry is fuel neutral; however, we must have access to a readily available, affordable and reliable fuel supply. This means:

• There must be no negative operational impacts on our equipment.
• The fuel supply must be reasonable in cost and marketplace ready.
• There must be no disruption in availability of supply that prevent us from delivering the products people need.

While new fuel options that meet these criteria may become viable in the future, today the industry relies on ultra-low sulfur diesel. A cap and invest (or it’s closely related cousin, a “carbon tax”) typically attempts to discourage people from driving by imposing increased costs on them for doing so. These programs only impact those who have a driving choice (e.g. passenger car drivers). Trucking is a non-discretionary user of the highways, delivering the food, clothing, medical supplies and other goods citizens need in support of the manufacturing, agricultural, and retail industries. In Maryland, 93% of communities are solely dependent on trucks to get their goods.

MMTA is also concerned that the cap and invest programmed described in the TCI framework states, “Affected fuel would include fuel destined for final sale or consumption in a TCI jurisdiction.” Maryland is a small geographic state, with well over 50% of all trucks passing through from another jurisdiction. Given our state’s small size, trucking companies do not have to purchase fuel in Maryland. A cap and invest program does not address emissions from the thousands of trucks from other states that travel through Maryland. It only places the economic burden on those local companies that purchase fuel in the state or those states within TCI.

Over the last decade the trucking industry has made incredible strides in reducing all types of vehicle emissions. Under federal law, without any future actions taken by the TCI states, those reductions are slated to continue. For example:

• Over the last 10 years, emissions from heavy-duty diesel trucks and buses have been reduced by 99% for NOx - an ozone precursor - and 98% for particulate emissions.
• New commercial trucks being manufactured today reduce fuel consumption and GHGs by approximately 20% when compared to a truck manufactured just in 2010. This is a savings of four gallons of fuel for every 100 miles traveled.
• Going forward, three additional rounds of increasingly stringent federal engine and vehicle GHG emissions standards are slated for new commercial trucks sold nationwide between 2021 and 2027.
• By 2027, commercial trucks will further reduce fuel consumption and greenhouse gas emissions by an additional 25%. Improvements to the trailers pulled by these trucks will provide an additional 9% reduction.

Per the Maryland Department of the Environment’s Greenhouse Gas Emissions Reduction Act Draft Plan of October 2019, emissions from on-road diesel use accounted for only 19% of total transportation emissions in the state in 2014. Given the tremendous strides that have been made, coupled with the cost of fleet replacement and the lack of viable fuel alternatives – particularly for the long-haul, heavy duty trucking industry sector – Maryland Motor Truck Association believes that any cap and invest program should exclude on-road diesel fuel until viable alternative fuel options exist.

Cockerham Energy, a third-generation family business which currently employs approximately 115 people and has employed hundreds of others throughout its 70+ years serving Southwest Virginia, is 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, small business 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.

• Cockerham Energy believes this would provide regulated utilities an unfair competitive advantage that Virginia based small businesses simply cannot compete with. Our company 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, whereby the state government starts pushing one form of power (electric) over others, instead of letting the competitive marketplace work under capitalism.

• As a propane and heating oil 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 and heating oil 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?

Cockerham Energy opposes the TCI plan to ration, tax and ultimately eliminate fossil fuels.

This plan is bad for Maine and does not, in any way, take into account the needs of the People of Maine.

1) Maine is a Rural State with limited Public transportation. This Plan would needlessly punish people for simply going grocery shopping or going to the doctor due to high fuel costs.

2) Maine has a depressed economy. Wages in the State are consistently lower than the other States in this group. This plan would force people to have to spend more of what they make on fuel costs.

3) Most people in Maine cannot the afford Electric Vehicles that this Plan appears to want to force them to purchase.

4) This Plan does not, in any way, take into account that, even if people wanted to purchase an Electric Vehicle, a vehicle that performs the task currently being done by a Petroleum Fueled vehicle does not exist (Tractor, Combine, Dump Truck, etc). Those that need to use these vehicles will be needlessly burdened by artificially inflated fuel costs.

5) The Elderly and Disabled on fixed incomes will be needlessly burdened by artificially inflated fuel costs. Many are currently finding it difficult to pay for needed medication as is. This will only make it even more difficult for them.

In short, The TCI should be opposed as a Bad Idea.

Thank you,

Guy Brandenstein

Maine has the oldest population and that means fixed income. This legislation on gasoline will make the cost of goods and services increase. People cannot afford the increase in cost due to this tax. Please do not pass this legislation! Thank you!

Mainers cannot afford such a drastic increase in gas. The state is mostly rural and public transportation is not an option. This initiative will create unnecessary stress and financial hardships. Please consider the toll finances have on family dynamics...and how social service systems will need a staggering amount of financing to deal with the fallout. No thanks.

I am fully supportive of TCI and believe this initiative has the potential to help
Maine tackle its transportation-related GHG contributions. I also am excited for the discussion around how the funds could be invested to support a just transition to a clean energy economy.

I'm writing to voice my strong support for the Transportation and Climate Initiative, which I learned about through the Maine Conservation Voters. In my own town of Kennebunk, I see tremendous opportunities for improved transportation. We have an old train station which, if reactivated, could bring tourism dollars to the community and could allow workers and students to commute to Portland or Boston and access the opportunities in those cities without the aggravation of driving personal vehicles. Other mass transit options such as buses or trolleys would also be welcome. In terms of individual vehicles, we own a plug-in Toyota Prius which is a delight to drive and competes with the best of the fossil-fuel powered vehicles. I wrote a grant a number of years ago to bring two electric vehicle charging stations to town, and I'm delighted to see the stations are in regular use by residents and tourists! I strongly support this initiative to improve Maine's transportation infrastructure in a way that helps address global climate change.