TCI Regional Policy Design Stakeholder Submissions

Establishing permit laws for gas transport is only creating hardships for poor citizens who will be forced to pay higher gas prices. We cannot simply go out and purchase fuel saving vehicles. Many of us rely on older cars for transport as we cannot afford anything else. Similarly a mileage tax will harm everyone. Maine is a huge state and long commutes are often unavoidable. I am educated and commute an hour to a specialized worksite. Would you like us to leave the state? My rural community does not offer any jobs in my field. I do not know what the solution is but what is so far proposed will do great harm to our state.

• 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.

The TCI is a “reactionary liberalism” dream: extract millions of dollars from people who can’t figure out why their motor fuel bills are steadily creeping up, and spread the revenues around to pay for “carbon reduction investments”.
The TCI is astoundingly, one might even say diabolically, complex. The details, not yet finalized, will emerge in a draft Memorandum of Understanding (MOU) scheduled to appear in December. After public input, the MOU will go to Gov. Phil Scott. His signature would put Vermont into the 12-state deal.
Then either the Regulated Terminals that supply motor fuel to eighty Vermont distributors, or the distributors themselves, will have to purchase “allowances”, the cost of which will be inconspicuously added into the price paid by consumers.
The TCI’s administrative body will decide how many allowances must be issued to sufficiently drive up the price of motor fuel, thus reducing the amount of motor fuel consumed, thus reducing to below an arbitrary TCI-set cap those awful carbon dioxide emissions that are driving the planet toward Al Gore’s heat death.
Did I mention that no legislator will ever vote on this stealth carbon tax? Governor Phil Scott, alone, can plunge Vermont into this mega-scheme to sock Vermonters with a carbon tax that the TCI backers hope they’ll never figure out.
But Gov. Scott has repeatedly voiced his opposition to a carbon tax. What if he refuses to sign on to the MOU? Here’s another diabolical feature. If he doesn’t sign the MOU, Vermont motorists will still be forced to pay for the cost of the allowances hidden back up the supply chain in Massachusetts and New York. But Vermont would not be eligible to receive its assigned share of the net revenues (after enormous enforcement and legal costs) from the TCI allowance sales.
Here’s the short takeaway. The TCI MOU is designed to make Vermont consumers pay a steadily increasing carbon tax on their gasoline and diesel fuel. No legislator will ever vote on imposing this tax. It will just happen, courtesy of the Rockefeller Brothers Fund and the climate change warriors like VPIRG who extol its benefits. After ten years of increasing motor fuel prices, the TCI will have produced no detectable effect whatever on climate change.

Please find attached comments from the New England Power Generators Association on the Transportation and Climate Initiative's Framework for a Draft Policy Proposal.

The urgency of climate change necessitates that we make strong, positive choices now that mitigate the cumulative negative effects that are already here and will only get worse if we continue to operate in a fossil-fuel based transportation system. Creating a regional low-carbon transportation initiative in collaboration with neighboring states would provide much needed improved transportation in Maine. I support Maine working with neighboring states through TCI’s bipartisan, proven policy model.

To Whom It May Concern:
I am a Horseheads to Ithaca commuter and something needs to be done about the congestion during rush hour at the southern end of Ithaca on NYS Route 13, specifically where NYS Rte. 13 and NYS Rtes. 34/96 come together just before reaching the NYS Rte. 327 intersection. That whole stretch from there to the first red light near Dunkin' Donuts, Home Depot, etc., is a hazard and heavily congested just before 8AM Mon.-Fri. Just before 9AM can be just as bad, but I'm more familiar with just before 8AM. TCAT only services Newfield near Rte. 13 and the discounted CTRAN (not free) bus runs only once to/from Elmira and Cornell in the morning and then again in the evening. It picks up at 6:15am (Elmira) and 6:30am (Horseheads) in Chemung County. They also stop at Alpine Junction in Schuyler County. Another later bus option would be nice as more people may ride the bus if they know there is a later bus option. My schedule got weird so riding the bus became inconvenient. There are a ton of people who commute from the Southern Tier because good paying jobs are scarce in that area but real estate is cheap. So they commute to their jobs in Ithaca and live in the Southern Tier. I am one of them. Tompkins County is an expensive place to live.

TCAT lost funding a few years ago so I gave up even parking in the free lot on Cornell campus. They became too unreliable with the unpredictable traffic delays I get in the morning. If I leave earlier, the Newfield Schools have a school bus that stops at almost every driveway. This bus runs from the Schuyler County line just before the roundabout in Newfield. This bus no longer pulls to the side of the road to let traffic go by like they used to. It used to pull over twice, then once, and now not at all. So I still end up in the congested mess if I leave earlier from Horseheads. If I leave earlier than 7am, I've gotten behind a slow moving tractor trailer going literally 35 MPH in a 55 MPH zone through the flat, straight section of the road. This lasted for about 5 miles with a line of traffic trying to get around it. Therefore, I still got into this mess again and got to work at the same time.

Attached is a .pdf with some pictures with additional concerns about the lack of left turning lanes and lack of early road closure signs that would reduce chaos and congestion.

Thank you for your time and consideration.

Thank you for your thoughtful initial framework for TCI.

I strongly support the equity and environmental justice aspects of this proposal because of the disproportionate impact that fossil fuel burning has on minority, lower income, and rural communities.

Living in Franklin County, MA, a rural region with a great deal of poverty, I would like to see Massachusetts think broadly and with specifics about how to use the TCI funds to increase access to affordable and viable public transportation to rural and low-income residents. For example, our county needs additional and more affordable public transportation to make it possible for people without cars to get to places of employment throughout the week, for night shifts, and on weekends. People in communities without a commercial district also need the ability to get to food shopping, get to medical facilities, etc. with some sort of public transit. Current public transportation here is extremely limited. Perhaps TCI would expand funds for a pilot program in the county--service on demand in small vehicles rather than buses. As our county's population ages, expanded public transportation will be that much more essential.

Thinking outside the box, TCI funds could be used to increase accessibility and expand equity to underserved rural populations by funding the full buildout of broadband. Reliable and up-to-date Internet service could help residents with applying for jobs, professional development, telecommuniting, accessing educational resources and online classes, and accessing support systems and medical professionals, without the need for transportation. Some of our communities and portions of them do not have broadband Internet access; rather they have only satellite or antiquated dial-up connections. This puts these residents at a significant disadvantage.

Lastly, these funds should be used primarily to reverse our greenhouse gases, not for adaptations to the impacts of climate change. We are in a race against time to reverse the devasting affects of climate change, and we must reach beyond the modest climate goals manadated by the Global Warming Solutions Act to avoid the disasterous predictions in the latest IPCC report.

Thank you for considering these comments as you look at finalizing the TCI design.