TCI Regional Policy Design Stakeholder Submissions

There should be no taxation without representation. Period. This initiative should be D.O.A

Comments on TCI MOU document:
1.A.(4) Does ‘Regional Organization’ need to be a ‘new’ entity created and maintained by the Participating Jurisdiction? Can an existing agency/organization be named the Regional Organization?

2.B. Define “State Fuel Suppliers”

2.B.(2) Hard to understand this section. Be ready to interpret.

2.C Consider changing ‘may’ to ‘will’

2.H. Regarding - “Compliance obligations shall be calculated based on the CO2 emissions that occur when the Affected Fuel is combusted, using standard emission factors developed by the United States Environmental Protection Agency or other similar sources.” - All Participating Jurisdictions should use the same standard emissions factors in order to have comparable results.

4. What is the geographic boundary of a Regional Organization? Are these envisioned to be statewide agencies, multi-state, multi-county within a state, individual towns/cities/villages?

5. Similar to above, what is the effective ‘size’ of a Participating Jurisdiction – statewide, regions, counties, towns? As written, any municipality could be a Participating Jurisdiction, however, it seems unlikely that a small town or village would be able to meet the requirements of the proposed initiative.

This is an essential initiative because New York State's transportation emissions are rising at a time they should be fast moving in the opposite direction... thus, we need a giant U-turn on this, and soon. This reversal and reduction is key to the accomplishment of the goals set in the CLCPA. While I have accepted that people are going to drive and that we need electric and other alternative vehicles, I still think that the best car trip is no car trip, and that electric cars are still cars, machines that create too much direct and indirect pollution and perils regardless of their fuel type and emissions levels. With this said, I believe that land use and development planning that makes it easier (and safer and more pleasant) to choose walking, cycling, and transit modes, or LOCATION EFFICIENCY, is absolutely critical to this initiative and should be prioritized as much if not more than alternative fuel vehicles. Also, better incentives for getting more people into each vehicle is key. We need not only alternative fuels, we need fewer vehicles miles traveled, and more people in each vehicle.

I am extremely opposed to any additional gas tax for MA residents!! This state is becoming exceptionally unappealing and unaffordable to live in for the citizens of MA.

Watching other states falter on TPI has been a huge disappointment. Massachusetts can lead the way, and I've never been more proud of my elected officials in this state for sticking by it. To my state representative (rep. Gentile) and senator Rausch - thank you for doing what you can. Thank you for looking past the short term economics of the situation and doing what's right. We're proud to be here.

The TCI framework proposes to implement a “regional cap to reduce CO2 emissions, from on-road diesel and finished motor gasoline.” 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 goods that 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 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. What will happen if supply or price are impacted so greatly that trucks cannot deliver the medicine or food that people need?

Richard B. Rudy, Inc. is concerned that a regional cap and invest program cannot work in a small 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.

One only needs to look at California to see the impacts on fuel costs of a cap and invest program. According to the Energy Information Administration, the cost of diesel fuel during the week of January 13, 2020 in the state was $3.87 per gallon. The combined average of all other western states during the same week was $3.24 per gallon.

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:
o 99% for NOx - an ozone precursor
o 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 in the heavy duty trucking industry sector, we believe that any cap and invest program should exclude on-road diesel fuel until viable alternative fuel options exist.

TCI is a great idea, and a great start towards getting us to carbon neutrality in the next 20 years. This is so important. Be courageous, and unstintingly generous in your thinking about the generations to come - give them a chance! Help the TCI get put into law!

While the goal is wonderful, the proposed action of raising the gasoline tax substantially does not fully consider the impact on retirees, and the elderly who are not capable of walking to the store for groceries, or bringing them home in a backpack. Ditto for riding a bike , electric bike or scooter, or a motorcycle. Income is limited, and the ability to drive to appointments, for ourselves or friends, is critical.
In addition, the cost of electricity is rising as wind power is added to the required mix of electricity sources. Please reconsider!

As a Rhode Island business owner and resident I completely disagree with this "tax" as a terrible added financial burden in one the worst business friendly states in the entire country. Additionally, I personally will join and and all organizations I feel will assist me in fighting passage of this burdensome tax.