View Public Input on TCI-P

Transportation emissions are a huge driver of climate change, accounting for nearly half of Virginia’s carbon output, while also emitting toxic air pollution that falls disproportionately on low-income populations and communities of color.

The Transportation and Climate Initiative Program (TCI-P) is a welcome step forward to addressing this major source of pollution, while steering needed investments in a modern, sustainable transportation system.

Funding provided by the TCI-P could help with ongoing efforts to put more electric vehicles on the road in Virginia along with equitably distributed charging infrastructure across the state.

The TCI-P also presents the opportunity to drive investments in a cleaner transportation system in the communities that have suffered the most from vehicle pollution. While the model rule calls for at least 35 percent of TCI proceeds to go toward frontline, impacted communities, here in Virginia I would hope we go above and beyond that benchmark, investing at least half of our TCI revenue in programs and infrastructure that will lower this disproportionate pollution burden.

I hope this important framework moves forward for the good of our climate, our health and our future.

Bridget McGregor

I'm sharing my input here because I support a strong TCI-P Model Rule that ensures meaningful climate action to address Virginia's largest driver of our climate crisis. Unfortunately, we no longer have the luxury of wasting time on the climate crisis. Luckily, a TCI-P Model Rule can actually benefit us in more ways than just addressing climate action. it also can direct significant investments to correcting historic inequities in overburdened and underserved communities and affords Virginia the opportunity for a cleaner, healthier transportation system. Any calls to reject or weaken the TCI Program are direct calls to ignore climate change and promote pollution.


I also support the TCI-P Model Rule to include a minimum investment amount to ensure overburdened and underserved communities in Virginia receive a greater-then-proportional share of investments from the program, integration of air quality commitments across Virginia, and robust empowerment of Virginia's Equity Advisory Body.

This is an opportunity for Virginia to take care of its most underserved and unprotected citizens.

Clean Energy greatly appreciates the opportunity to comment on the (TCI) Draft Model Rule for the TCI-Program (TCI-P). We also applaud your dedication to this long-term effort to meaningfully address transportation sector emissions and their negative effects on both air quality and climate change.

THE LOWEST CARBON FUEL AVAILABLE

As North America’s largest provider of carbon negative vehicle fuel, Clean Energy is proud to deliver renewable natural gas (RNG) to the country’s leading fleets such as UPS, Waste Management, NYMTA, and Amazon. In 2020, the California Air Resources Board certified RNG as the first and only carbon negative fuel (-17.95 gCO2e/MJ ), based on the weighted average under the state’s Low Carbon Fuel Standard (LCFS). Individual RNG fuel pathways have been certified with carbon intensity scores as low as -532 gCO2e/MJ . It is important to note that the weighted average of battery electric power has a carbon intensity score in California of 16.6 gCO2e/MJ , thereby making RNG the lowest carbon fuel available.

With similar operational performance benefits as diesel trucks, in terms or range and payload, RNG vehicles are the leading technology for reducing carbon emissions from the medium and heavy-duty vehicle sector. In addition to providing climate change benefits, vehicles powered by near-zero engines and fueled with RNG can reduce NOx emissions by 90-99 percent and eliminate diesel particulate matter emissions.

LARGE-SCALE DEPLOYMENT CAPABLE

Whether its mass transit buses or long-haul trucks, renewable natural gas vehicles surpass all other alternative fuels in terms of operational deployment in the heavy-duty sector. For example, in early 2021 New York MTA, the nation’s largest mass transit authority, signed a contract to fuel 800 of their buses with RNG. LA Metro, the nations’ second largest mass transit authority operates over 2,300 RNG buses and recently placed an order for 300 more. In contrast, Toronto currently operates the largest electric-battery bus fleet in North America with a total of 60 buses. While every industry has their own studies, the proof is in the deployments.

EV technology has advanced over the past decade but is still not deployable on a large-scale. This is due to cost, performance, infrastructure, and upstream energy issues that may or may not be renewable. Additionally, the lack of availability for heavy duty applications is not expected to resolve itself in the near to mid-term.

PROVIDING RELIEF TO ENVIRONMENTAL JUSTICE COMMUNITIES NOW

The Draft Model Rule specifically addresses environmental justice communities by mandating 35 percent of the funds collected address air quality in said neighborhoods. This is a powerful and necessary policy. Many environmental justice communities are located around heavily industrialized areas which are often plagued by heavy diesel truck traffic. Clean Energy’s vast network of over 530 refueling stations are enabling trucking fleets to provide these communities immediate and effective relief today. National trucking fleets have taken the lead in deploying thousands of RNG trucks across the country with the most recent development being Amazon’s announcement to deploy over 700 RNG trucks across its national operations. Local and regional fleets in these communities also have independently started to adopt RNG, as evidenced by our Hunts Point station in the South Bronx where small fleets such as a local concrete company utilize this green fuel.

CONCLUSION

TCI can be a great success if states implement a program which focuses on results by not restricting the means. Electrification is a part of the solution, but electrification alone could guarantee diesel’s domination for decades along with the associated air pollution and carbon emissions. Large-scale deployments of RNG vehicles by leading national fleets provide clear evidence that to achieve significant emissions reductions now, RNG must play a significant role in the TCI-P. We look forward to continued participation in the process and request that the TCI organization place greater emphasis on the important role that renewable fuels play in our carbon free future.

I do not appreciate your efforts to increase my cost of living by eliminating cheap energy is favor so called "clean" energy. by making fossil fuels more expensive using cap and trade policies that run the price of gas up at the pump. electric cars are expensive and the batteries don't last. The climate has been changing since the beginning of time innovation not rigging the economy with cap and trade is what we need.

Individual choices for driving electric are good, but states need to work together to make bigger, better choices for our collective future. The electrification of transportation in the TCI region and the pricing of pollution will go a long way to cleaning the air and combating climate change.

I’m opposed to Virginia joining the TCI. It will cost consumers and businesses too much at the gas pump.

The Southern Environmental Law Center supports the general concept and framework that has been established for the TCI program (TCI-P), as we have stated in previous joint comment letters that we have signed onto as well as comments we have submitted on our own behalf throughout the development of TCI-P.

The regional approach reflected in TCI-P offers significant potential to reduce the outsized climate impact of our transportation system by redirecting investments and policies toward cleaner vehicles, less auto-dependent development patterns, and more accessible and equitable transportation alternatives. As noted in the April 7, 2021 joint comment letter that SELC and more than 80 other transportation, health, environmental, business, labor, and community groups signed onto, there are aspects of the draft Model Rule that need to be strengthened to ensure TCI-P delivers an ambitious and equitable program. To be successful, TCI-P must result in meaningful emissions reductions and public health benefits while simultaneously redressing persistent inequities built into our current transportation system, inequities that too often result in a disproportionate distribution of transportation services—and pollution—among different communities based on race and income levels. In addition to strengthening the draft Model Rule, these aspects will also need to be squarely addressed in the state-specific implementation programs that each participating jurisdiction develops.

We look forward to continuing to participate in the development of TCI-P, both at the regional level and in the individual states within SELC’s region that are considering signing the Memorandum of Understanding.

I wholeheartedly support the collaborative effort by TCI-P to reduce carbon emissions and invest in cleaner, more equitable and sustainable transportation systems. Multi-jurisdictional programs can help assure that projects are implemented and funded. We urgently need this kind of collaboration to save our earth and way of life.

Virginia should join the TCI because the program is focused to decrease the harmful effects of climate change that humanity is inflicting on the earth. It is really that simple.