TCI Regional Policy Design Stakeholder Submissions

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.

• 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.

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.

Just saw on the Boston herald that based on this program/plan, Governor of MA will increase the green tax. https://www.bostonherald.com/2019/11/01/green-gas-tax-bid-could-push-prices-close-to-5-a-gallon/

Also, can you make the form anonymous so that people who may not have an address or affiliation can submit their input/feedback? Equity is a big part of it and right now, this does not feel like it can reach those who are uncomfortable with such form or may not have an email.

this would shut down small business like us , which are the backbone of the comminity

Please see attached Alliance of Automobile Manufacturers' comments on TCI's Draft Regional Policy Framework.

My attached comments address multiple concerns. I believe that costs must be addressed before any jurisdiction can decide whether to join the TCI. Contrary to the statements saying that there has been “extensive” public input to this process I show that the only segment of the public that is even aware of this process has some sort of vested interest in transportation and climate planning. I addressed each of the components of the framework and finally discuss some implementation issues based on my extensive background in cap and trade programs.

This will have a serious negative impact on our industry, including all of our employees and their families. Please do not adopt this policy!