CLIMATE AND ENERGY POLICY
Truck stops, travel centers, and off-highway transportation energy providers are an indispensable asset to lowering the carbon footprint of transportation energy in the United States.
Much of the industry’s focus in recent years has been on navigating the energy transition in a way that responds to consumer demand while responsibly and proactively doing its part to lower carbon emissions.
ºÚÁÏÉçÇøthinks it is best for the American consumer and America’s industrial and geopolitical position in the world marketplace to have reasonably low and stable energy prices.
As the refueling landscape evolves, truck stops, and travel centers are investing in many alternative fuels, including biodiesel, renewable diesel, hydrogen, natural gas, and electricity.
Over the past few decades, federal policies such as the Renewable Fuel Standard (RFS) and the Biodiesel Tax Credit have created a strong incentive for fuel retailers to invest in the infrastructure necessary to bring cleaner fuels to market.
ºÚÁÏÉçÇøworks with policymakers to pursue market-oriented, consumer-focused policies that:
- Enhance the fuel supply;
- Lower fuel prices for consumers, and
- Improve the environmental attributes of transportation energy.
A) Renewable Volume Obligations: The implementation of the Renewable Fuel Standard (RFS) represents the best opportunity to prompt tangible, immediate carbon reductions in transportation energy. There is no other policy that can result in immediate carbon reductions in the fuel supply. ºÚÁÏÉçÇøencourages the Environmental Protection Agency to send unambiguous signals to the market that investments in lower carbon fuels will be rewarded by setting ambitious targets for advanced biofuel blending and through ambitious growth in ethanol.
B) Biodiesel Tax Credit: Since 2004, the biodiesel tax credit has fostered growth in the domestic biodiesel market by spurring fuel retailers to invest in the necessary infrastructure to sell low-carbon alternative fuels and offer them to the public at the lowest possible cost. The $1.00 per gallon biodiesel blenders’ tax credit helps fuel retailers to sell biodiesel at a price that is cost competitive with gasoline and diesel, thereby advancing consumer consumption. Biodiesel plays a critical role in reducing carbon emissions while reducing the costs of all goods moved by truck.
The U.S. biodiesel and renewable diesel market has grown to approximately 3 billion gallons in 2020 from roughly 100 million gallons in 2005. Biodiesel and renewable diesel eliminated 15 million metric tons of CO2 in California alone in 2020, the equivalent of taking more than 3 million passenger cars off the roads. Compared with petroleum-based diesel, renewable diesel and biodiesel reduce greenhouse gas emissions by up to 80 percent. The California Air Resources Board recently underscored their important role in reducing carbon emissions, announcing that renewable diesel and biodiesel constitute more than half of the diesel supply in California.
C) eRINS: ºÚÁÏÉçÇøthinks that the Renewable Fuel Standard’s existing incentive framework should evolve to incentivize EV charging investment as well as investments in renewable liquid fuels. The Environmental Protection Agency (EPA) has proposed a framework for how electric Renewable Identification Numbers (eRINs) would be permitted under the Renewable Fuel Standard (RFS). The proposal would allow automakers to generate a RIN when electricity is produced from qualifying renewable biomass. ºÚÁÏÉçÇøopposes placing the value of eRINs at other segments of the value chain, such as with automakers. Doing so would not incentivize private investment in charging stations or consumer investment in EVs because the eRINs’ value would not be shared throughout the value chain. Rather, it would provide additional incentives to an industry already encouraged to invest in EVs via separate federal policies. For charging station owners and operators, eRINs represent an opportunity to offset costs for fuel retailers so that they can make investments in electric vehicle charging stations.
ELECTRIC VEHICLE CHARGING
Truck stops, travel centers and off-highway fuel retailers, represent the fastest, most efficient way to build out a reliable and safe network of electric vehicle charging stations provided they can compete in a fair and competitive market.
Policies to advance the adoption of electric vehicles should foster a dynamic and competitive marketplace that encourages private sector investment in electric vehicle charging infrastructure, and avoids harming those businesses best positioned to accelerate EVs in the market.
There are several market impediments that make it challenging for travel centers to make a return on their electric vehicle charging station investments. Most of these impediments involve an electricity market structure that was not designed with EV charging in mind.
For the private market to work:
- Fuel retailers must be able to buy electricity at wholesale prices without incurring punitive demand charges from the utility provider;
- Investor-owned utility companies should be discouraged from raising capital to invest in EV charging stations by increasing the monthly electric bills of all their customers, a practice known as rate-basing; and
- Fuel retailers must be permitted to sell electricity to EV users without being subject to regulation as a utility.
Policies that allow electric vehicle charging stations at rest areas or permit utility companies to increase rates to all ratepayers to offset their consumer-facing EV charging station investments will discourage the private sector from investing in electric vehicle charging.
IIJA requires grant recipients to show collaborative engagement with stakeholders, including fuel providers and fuel station owners, and operators. Notably, states are encouraged to consider the availability of onsite amenities such as restrooms and food offerings when disbursing grant funds. The legislation also created a separate grant program focused solely on installing EV charging stations at locations within one mile of Interstate exits.
ºÚÁÏÉçÇøcontinues to work with its members to ensure that they can partner with their state departments of transportation to access available funds while also educating state DOTs about the policy changes necessary to ensure that the private sector can profitably invest in electric vehicle charging stations.
TRUCK PARKING
As the home-away-from-home for America’s professional truck drivers, nearly 7,000 truck stops and travel centers provide 90 percent of the nation’s commercial truck parking spaces. Several thousand more refueling locations provide additional truck parking capacity under a different retail format.
In most geographic areas, there are significantly more open parking spaces at nearby private truck stops than the total number of spaces at public rest areas on a highway.
Truck stops and travel centers operate under a business model that allows truck drivers the ability to meet their federally mandated rest requirements as well as the ability to access restaurants, restrooms, showers, travel centers, convenience stores, medical services and a host of other services that drivers typically can’t access elsewhere when operating a commercial vehicle due to its size.
The industry’s supply of truck parking, coupled with the amenities and services that truck drivers need, makes truck stops and travel centers the stopping location of choice for the nation’s professional truck drivers.
The private sector is best suited to provide truck parking. To the extent that policymakers want taxpayers to subsidize truck parking expansion, such investments should be undertaken in partnership with the private sector to ensure that federal funds are maximized. Funds should not enable states, localities, or others to provide truck parking in a manner that directly competes with off-highway businesses, which would undermine the industry’s incentives to expand truck parking capacity.
Highway and Infrastructure Policy
REST AREA COMMERCIALIZATION
Current law prohibits commercial services in rest areas on the Interstate right-of-way, including the prohibition of electric vehicle (EV) charging or other automotive services.
When Congress created the Interstate Highway System in the 1950s, community leaders feared that local businesses, jobs, and tax bases would shrink as truck drivers and motorists bypassed their cities and towns. As a result, Congress prohibited states from offering commercial services, such as food and fuel, at commercial rest areas on Interstates built after January 1, 1960.
While at first glance, rest area commercialization seems like an easy and convenient way for states to generate revenue, in reality, it would jeopardize private businesses, especially small businesses. Due to their advantageous locations, state-owned commercial rest areas would establish virtual monopolies on services to highway travelers. Commercial activity will be diverted from off-highway communities to on-Interstate locations, redirecting tax revenue away from localities.
Moreover, installing EV charging infrastructure at Interstate rest areas would require overturning the rest area commercialization ban that has been in place for more than 60 years. If Congress were to allow rest area commercial services, it would undercut other congressional objectives, such as increasing truck parking capacity, which is aided by participation from travel centers and retail fuel stations that are not financially battered by unfair competition from the government.
Tolling: ºÚÁÏÉçÇøopposes tolling existing Interstate Highways as a means of generating infrastructure revenues. ºÚÁÏÉçÇøeducates policymakers about the negative consequences of placing tolls on existing federal interstate lanes.
Tolls unfairly burden drivers who rely on the Interstate Highway System, create safety concerns and congestion on secondary roads, and have disastrous effects on businesses located on interstate routes.