Aq-Rule4-10Z4 Precisely the Type of Scenario the Legislature Envisioned When the Administrative Procedures Act Was Adopted

We, the 58 undersigned members of the Minnesota Legislature, offer the following comments in support of the Minnesota Pollution Control Agency’s Proposed Rules Adopting Vehicle Greenhouse Gas Emissions Standards—Clean Cars Minnesota, Minnesota Rules, chapter 7023.

We appreciate the opportunity to comment in these proceedings and encourage adoption of the rules as necessary and reasonable, and commensurate with the public interest and Minnesota law.

Clean Cars Minnesota has been the subject of significant public interest and discussion. As legislators, we have participated in robust ongoing dialogue regarding the merits of the proposed rules with our constituents, stakeholders, and each other. This careful and deliberate scrutiny has led us to the conclusion that the proposed rules will benefit Minnesotans and should be adopted.

Statutory Authority and Legislative Intent

As current members of the legislative branch, we are uniquely positioned to offer our perspective on the authority and responsibilities granted to the agency by the Legislature specific to vehicle emissions as well as the agency’s general rulemaking authority.

The powers and responsibilities of the Minnesota Pollution Control Agency (MPCA) are described in Minnesota Statutes Chapter 116. Of particular relevance to the proposed rules, Section 116.07, Subdivision 2, states “the agency shall also adopt standards of air quality, including maximum allowable standards of emission of air contaminants from motor vehicles…”. This provision demonstrates in very specific terms the Legislature’s intent that MPCA is expected to adopt standards of the exact type now proposed by the agency.

This language was adopted in 1967, which means that the Minnesota House and Senate have had 54 regular sessions in which we could have reconsidered and agreed upon a repeal or amendment of this section of law. We have not done so, and additionally note that the entire 2020 regular session as well as seven special sessions have occurred subsequently to MPCA’s initial request for comment on the proposed Clean Cars Minnesota rules in October 2019. The Legislature has had ample opportunity to enact statutory changes in response to this administrative action and has not done so.

Finally, MPCA’s statement of need and reasonableness (SONAR) correctly references Minnesota’s greenhouse gas reduction goals, passed by the Legislature in 2007 and now found in Minnesota Statutes 216H.02, Subdivision 1. The SONAR goes on to describe MPCA’s analysis that the transportation sector is Minnesota’s largest source of greenhouse gas emissions, and that adoption of the proposed rules would reduce these emissions. We submit that an agency adopting rules in response to rigorous evaluation of compliance with a legislatively mandated statewide goal is

aq-rule4-10z4 precisely the type of scenario the Legislature envisioned when the Administrative Procedures Act was adopted.

Need and Benefit of Clean Cars Minnesota

Pollution from motor vehicle emissions presents a very real and serious public policy concern. As elected officials, we are well aware of the strong public interest in reducing all forms of pollution that impact our climate and the public health of Minnesotans. Climate change is the source of extreme weather like heat waves and polar vortexes that not only stress our health but also our built infrastructure like roads and bridges. Air pollution wreaks havoc on our hearts and lungs, particularly for those communities living near busy roadways and who are often the most vulnerable among us. Reducing emissions from tailpipes through tried-and-true policies like clean car standards is not only reasonable, it’s very much needed.

The proposed rule will also improve choices for Minnesota consumers seeking to purchase an electric or very low emission vehicle. Manufacturers have consistently signaled – including on the record in legislative testimony – that the greatest volume and variety of the electric vehicles they produce will be distributed first to states that have adopted clean cars standards. We have heard this message repeated directly from Minnesotans who couldn’t find the electric models they wanted to buy in their home state and who shared their stories during the two-day public hearings held on Clean Cars Minnesota held at the end of February.

Finally, we recognize that adoption of these rules sends a clear market signal to the global automotive industry that Minnesota is ‘open for business’ as the electric vehicle manufacturing and distribution supply chains continue to grow and generate new jobs.

Reasonableness and Practicality of the Proposed Rule

The proposed rule follows clean cars standards previously adopted by numerous other states, where they have been successfully implemented and maintained. Minnesota is in a unique position now to benefit from the direct experience of these peer states, which include oil and gas producers (e.g. Colorado) and states with cold climates (e.g. Maine and Vermont).

As of this writing, 14 states and Washington D.C. have already adopted the LEV standard and 12 states have adopted the ZEV standard. It is notable that Virginia is on track to formal adoption of these rules, and Quebec has also adopted ZEV standard modeled off of the U.S. clean car standards. All this points to a reasonable set of rules that automakers are perfectly capable of adhering to, and in fact have already adhered to for eight years on a national level given that the proposed LEV standard historically matched the national tailpipe emissions standards from 2012 through 2020.

Misinformation About the Proposed Rule

We have been alarmed at the degree to which the scope and substance of the proposed rule has been factually misrepresented, including at the Legislature and as part of this record.

Let us be clear. The proposed rules do not affect any existing vehicle in Minnesota. They do not apply to farm equipment, off-road, or to heavy-duty vehicles. They do not impose restrictions on Minnesota consumers and do not prevent Minnesotans from buying the vehicle of their choice. They also will not raise the price of food crops, forbid the operation of diesel generators for rural electric co-ops, or even remotely ban the sale of gas-powered passenger vehicles.

We have heard as well from representatives of auto-dealers and the automotive industry that purchase incentives, dealer incentives and training resources, and charging infrastructure investments would help the industry in the coming years. Legislation is currently pending to pursue these worthy ideas, all of which can be done concurrently with or in advance of the adoption of Clean Cars Minnesota given the two-year window between adoption and implementation.

In summary, we recommend adoption of the Minnesota Pollution Control Agency’s Proposed Rules Adopting Vehicle Greenhouse Gas Emissions Standards—Clean Cars Minnesota, Minnesota Rules, chapter 7023. These rules are reasonable, practical, fully consistent with Minnesota statute and would be a prudent step toward reducing our contribution to global climate change while also lowering the air pollution that so often overburdens and harms the most vulnerable Minnesotans.

Rep. Jamie Long Rep. Frank Hornstein Rep. Rick Hansen Sen. Scott Dibble Sen. Nick Frentz Sen. Patricia Torres-Ray

Dem. Leader Susan Kent Sen. John Marty Sen. Ann Rest Sen. Greg Clausen Sen. Matt Klein Sen. Lindsey Port Sen. Mary Kunesh Sen. Steve Cwodzinski Sen. Melisa Franzen Sen. Ann Johnson Stewart Sen. Jennifer McEwen Sen. Jason Isaacson Sen. Chris Eaton Sen. Jim Carlson Sen. Melissa Wiklund Sen. Sandra Pappas Sen. Chuck Wiger Sen. Ron Latz Sen. Kari Dziedzic Sen. Omar Fateh Sen. Karla Bigham Sen. Foung Hawj Sen. Jerry Newton

Maj. Leader Ryan Winkler Rep. Kaela Berg Rep. Alice Hausman Rep. Mike Freiberg Rep. Dave Pinto Rep. Todd Lippert Rep. Cedrick Frazier Rep. Zack Stephenson Rep. Liz Reyer Rep. Michael Howard Rep. Patty Acomb Rep. Jay Xiong Rep. Laurie Pryor Rep. Fue Lee Rep. Steve Elkins Rep. Jamie Becker-Finn Rep. Jim Davnie Rep. Sandra Feist Rep. Steve Sandell Rep. Andrew Carlson Rep. Sydney Jordan Rep. Jennifer Schultz Rep. Kristin Bahner Rep. Liz Olson Rep. Liz Boldon Rep. Tina Liebling Rep. Athena Hollins Rep. Kaohly Her Rep. Leon Lillie Jo Olson Attachment

Comment Submission for Proposed Rules Adopting Greenhouse Gas Emissions Standards (36416)

The following comments are submitted by Fresh Energy on behalf of 743 Minnesotans Regarding Clean Cars Minnesota Rulemaking

March 15, 2021

To: Administrative Law Judge Jessica Palmer-Denig OAH Docket No. 71-9003-36416

408 Saint Peter Street, Suite 350, Saint Paul, MN 55102 www.fresh-energy.org Name: Ina Ziegler

Zip Code: 55406

Comment:

I support Clean Cars Minnesota. Cars and trucks on the roads are a major source of air pollution in Minneapolis. I live near Lake Street and worry about the soot and ozone released from every car, truck, and bus that passes my home. I understand that most people rely on a gas-powered vehicle of some kind to get around, but we have an opportunity in Minnesota to clean up our air with clean car standards. Clean Cars Minnesota would help reduce air pollution from transportation and make our state healthier. I support this plan!

OAH Docket No. 71-9003-36416 Name: Susan Williams

Zip Code: 55449

Comment:

I have owned a plug-in hybrid electric vehicle (a Chevrolet Volt) since 2012, and there are so many advantages, just starting with a tremendous reduction in gas usage! The regenerative braking is a boon for winter driving in slippery conditions--every car should have it (you can slow down without brakes)! And maintenance costs are also less. Most importantly though, more electric cars is one big way to address climate change. I wholeheartedly support clean air standards that promote electric vehicles!

OAH Docket No. 71-9003-36416 Name: Scott Burtness

Zip Code: 55105

Comment:

I support Clean Cars Minnesota. Buying a car or truck is a big decision with so many factors to consider. Minnesotans deserve to be able to access to all the vehicles available in the U.S. marketplace when they’re deciding to buy or lease. Right now, many electric vehicles don’t even make it to Minnesota dealerships because they go straight to states like Maryland and Oregon with clean car standards - that’s just not fair. Minnesotans should be able to buy whichever car they want.

OAH Docket No. 71-9003-36416 Name: Dana Slade

Zip Code: 55337

Comment:

OAH Docket No. 71-9003-36416 Name: Elizabeth Hatfield

Zip Code: 55413

Comment:

OAH Docket No. 71-9003-36416 Name: Patricia Keefe

Zip Code: 55901

Comment:

Cleaner cars are a must in out struggle for our earth.

OAH Docket No. 71-9003-36416 Name: Dana Slade

Zip Code: 55425

Comment:

OAH Docket No. 71-9003-36416 Name: Bob McKlveen

Zip Code: 55436

Comment:

I’m a doctor and I see the health effects of climate change already happening in my community

OAH Docket No. 71-9003-36416 Name: Rolf Jacobson

Zip Code: 55113

Comment:

I support Clean Cars Minnesota.

Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards.

Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Revee Needham

Zip Code: 55020

Comment:

I support Clean Cars Minnesota. Clean energy is here to stay. The clean energy jobs sector is growing at a rapid pace, at this point clean energy is almost always cheaper than fossil fuels, and we can harness wind and solar energy right here at home in Minnesota. The time to save our climate is now and we can only do it if we fully embrace a home-grown clean energy economy that doesn’t harm our communities, air, lakes and forest. Clean Cars Minnesota is one piece of the puzzle that help Minnesotans transition to a zero emission future at a faster pace.

OAH Docket No. 71-9003-36416 Name: Leslie Pilgrim

Zip Code: 55118

Comment:

We need to act now with smart ideas for decarbonizing with technology that exists. Electric vehicles are this existing technology. Except, it's not readily available to me at a price I can afford. The state of MN can make this technology more accessible, more affordable while providing less polluting emissions.

OAH Docket No. 71-9003-36416 Name: Michael Noble

Zip Code: 55105

Comment:

Buying a car is a big decision for most families. When we got our current car in December 2018, we knew we wanted a plug-in car, and we talked to a lot of EV drivers and plug-in hybrid drivers about their experiences.

It was so frustrating though when we went to car dealerships to see the cars we were interested in. First, we learned that many of the cars that we thought were interesting just would not be available for sale here at all! Like the all-EV models of the Hyundai Kona, the Kia Niro and the Fiat 500.

Then we settled on a plug-in hybrid, which was a “compromise” because we are a one- car family, so we needed a car that could do everything, including travel long distances across SD, ND, MT, WY, a summer road trip we had planned. Even then, when we knew exactly what we wanted and there were 3 plug-in hybrid wagons and hatchback options that WERE supposedly for sale in MN, the dealers were only getting 1-2 per quarter and we could not order what we wanted. We either had to take the color and features on the cars they had on the lot, or go without!

Finally, I thought I would be willing to buy a one-way plane ticket and buy a car within 500 or 600 miles and drive it home, so I narrowed my choices to one vehicle, and started shopping online for the make, model, color and trim that I wanted in Milwaukee, Chicago, DesMoines, Omaha, Sioux Falls and Fargo.

A friend of mine bought the car he wanted in San Diego and paid $1200 to ship it to Lakeville. My wife ruled that out!

She was getting weary and was ready to give up. She was starting to feel maybe this industry wasn’t ready and we should buy a gasoline car or just buy one of the plug in hybrids that were here, but not what we wanted.

OAH Docket No. 71-9003-36416 Finally, a car salesman in Normal IL said to me: “you’re gonna buy a car you don’t want?!?! Don’t do it! This is America! How about I deliver the car you want to your house no charge, this Tuesday!” Two Korean War veterans in their late seventies got paid $300 bucks each to drive up and back that day! “We like the work; it gets us out of the house,” they told me.

We now have finished two years on our three-year lease, loving our small SUV navy blue Kia Niro plug-in hybrid. Unless we are driving long distances, we buy gasoline every six or eight weeks, because 90% of our trips are all electric. After the rebate from IRS, the car cost $27K, about exactly the same as the Niro that is gasoline-only.

It has a 26 mile all-electric range, and gets 48 miles per gallon when it seemlessly switches from EV mode to hybrid mode. So most of our driving is low cost and carbon free: we have the Windsource program from Xcel, and just last week got the offer from Xcel to switch to a night time charging rate at 2.8¢ per kilowatt hour, about a 70% reduction in our already VERY cheap fuel costs.

I know that there are other Kia Niro plug in drivers here in MN, but they are very rare.

A “regular” person would never go through the six months of hassle that my wife and I did to get what we wanted.

After MN Clean Cars is approved, anyone will be able go to the car lot, and ask the salesperson to test drive all the plug-in hybrid choices and all-EV choices that that manufacturer produces! And drive their car home, pollution free.

OAH Docket No. 71-9003-36416 Name: Peter Bjorndal

Zip Code: 55912

Comment:

Let's do what we can, guys. Clean cars MN is a green light from this mid 20s dude. � �

OAH Docket No. 71-9003-36416 Name: Nancy Lukens

Zip Code: 55347

Comment:

Please support getting more EV in MN.

OAH Docket No. 71-9003-36416 Name: Mary Jo Nissen

Zip Code: 55414

Comment:

OAH Docket No. 71-9003-36416 Name: Straka

Zip Code: 55105-1210

Comment:

Please pursue a clean energy standard that is both bold and aggressive at all cost to the industry. It can take it and needs to pay the price of the costs of adverse health care costs they cause. The adverse health effects alone represents justification for pursuing clean energy, clean cars etc.. If not for health (unclean air contributes substantially to morbidity and mortality of all citizens) concerns, then do it for the future of our children- a cleaner air, environment, less carbon in the atmosphere will make the world a better place, reduce man-made climate change, and avoid, or at least curtail the negative health, economic and social injustice caused by solution from impacts of pollution and particulate matter in the air- disproportionally affecting those of a lower social economic class.

OAH Docket No. 71-9003-36416 Name: Laurie Sovell

Zip Code: 55107

Comment:

I support Clean Cars Minnesota. Minnesotans deserve access to all the vehicles available in the U.S. marketplace when deciding to buy or lease. Right now, many electric vehicles don’t even make it to Minnesota dealerships because they go to states like Maryland and Oregon with clean car standards - that’s not fair.

My husband and I bought a plug-in hybrid Mitsubishi EV this spring. It was NOT our first choice, but after discovering it was the ONLY EV that fit our needs & available in Minnesota to purchase, we settled for it. We, and all Minnesotans, should be able to buy whichever car they want.

I am also a retired, 23-year employee of the MPCA. I know the science - both social AND physical - behind this issue. There is no single issue more important than climate change and fuel independence! We must act now.

Thank you.

OAH Docket No. 71-9003-36416 Name: Scot Adams

Zip Code: 55346

Comment:

I own a Chevrolet Volt and had little difficulty buying it, because there are two dealerships in the Minneapolis area that stocked them at the time. For most other types of BEVs and plug-in hybrids, it is much more difficult, as many of my friends have told me, from painful experiences they've had. Clean Cars MN would change all that for the better. I hope to see both the ZEV and LEV standards adopted in Minnesota, but especially the ZEV standards.

OAH Docket No. 71-9003-36416 Name: Jerry Stoner

Zip Code: 55113

Comment:

I support Clean Cars Minnesota. Electric vehicles can save people like me money because they have lower maintenance, operating, and fuel costs than a traditional gasoline-powered vehicle. However, both new and used electric vehicles are hard to track down here in Minnesota because they often go straight to states like Maryland and Oregon with clean car standards – and that’s just not fair. Clean Cars Minnesota would bring more EVs to Minnesota's new and used car marketplace and drive down competition for specific makes and models in my price range.

My friend had to buy a car in Washington DC, fly there and drive it back because the market for new/used cars is so small here. We won't need to have these standards forever but they are necessary to jump start the EV market further and keep us from the tipping point of climate change.

OAH Docket No. 71-9003-36416 Name: Lance Reschke

Zip Code: 55305

Comment:

As a citizen concerned about the economic, sociial, and environmental costs of climate change, I demand the MPCA implement rules to hasten the availability, affordability, and usability of electric vehicles and transportation across the State of Minnesota.

OAH Docket No. 71-9003-36416 Name: Lynn Glesne

Zip Code: 56354

Comment:

I'm a senior and won't buy a new vehicle until it is an electric SUV! Fossil fuels are destroying our planet!

OAH Docket No. 71-9003-36416 Name: Diane Hilscher

Zip Code:

Comment:

I support Clean Cars Minnesota. We need to do everything we can to reduce Minnesota’s dependence on fossil fuels and transition to clean, local energy that doesn’t harm our lakes, forests, air, and people. With Clean Cars Minnesota more Minnesotans will transition to a zero emission or low emission vehicle when they buy or lease their next car or truck, and thus reduce our dependence upon fossil fuels.

OAH Docket No. 71-9003-36416 Name: Debbie Nelson

Zip Code: 55044

Comment:

Let’s be the future and embrace what a cleaner more vital world will look like.

OAH Docket No. 71-9003-36416 Name: Bruce Killam

Zip Code: 55445

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice, let’s make Minnesota a state that cares and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Joel Haskard

Zip Code: 55104

Comment:

I want more EV choices. I would LOVE the additional choices of EVs in Minnesota that the clean car standards would give us. I plan to make my next car purchase an EV, and I want there to be as many choices of models and manufactures available as possible.

OAH Docket No. 71-9003-36416 Name: Cindy Larson O'Neil

Zip Code: 55424

Comment:

I support Clean Cars Minnesota. I drive an EV. Communities of color and under- resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionally harm Minnesota’s most vulnerable and marginalized communities. I support finding a way for Communities of color and under-resourced communities to utilize use of EVs in their community.

OAH Docket No. 71-9003-36416 Name: Jeff Jeremiason

Zip Code: 56082

Comment:

Minnesota's natural heritage is critical to our state and its future. Natural heritage encompasses both people and place. MN native people are being forced to directly suffer under Line 3 construction. All of MN will continue to suffer as climate change continues to erode the boundaries of the three major biomes in MN. MPCA can't undo the scientific ignorance and malfeasance of approving Line 3, but can be part of ending the need for fossil fuels by writing rules that reflect the severe risks MN is facing in a changing climate.

OAH Docket No. 71-9003-36416 Name: Anna Harmon

Zip Code: 55422

Comment:

OAH Docket No. 71-9003-36416 Name: Kate Wolford

Zip Code: 55419

Comment:

I am worried about the health of Minnesotans and I know that fossil fuel emissions from vehicles are hurting us, especially communities of color, under resourced families, people with pre-existing conditions and children. I support Clean Cars Minnesota as a major step toward cleaning up our air. This an opportunity for Minnesota to join other states who are leading the way with some version of clean car standards. Good for consumers, our economy, and the planet!

OAH Docket No. 71-9003-36416 Name: Jessi Wyatt

Zip Code: 55104

Comment:

Minnesota needs to continue leadership on climate action by passing the Clean Cars rulemaking with both LEV and ZEV included. Creating access to EV sales and requiring that manufacturers are held to the same standard as prior to the Trump administration rollback is vital to protecting our state's natural resources, ensuring that future generations have clean air to breathe, and is the natural next step on the state's journey to combatting climate change. I look forward to seeing thee rulemaking pass, followed by continued, increasingly aggressive on climate change. As a Minnesota native, a young woman, and environmentalist, and a humanitarian, the Clean Cars rulemaking is an easy, attainable step in the right direction.

OAH Docket No. 71-9003-36416 Name: Mike Brooks

Zip Code: 55060

Comment:

We must eliminate GHG.

OAH Docket No. 71-9003-36416 Name: Julie Weisbecker

Zip Code: 55118

Comment:

We need to pass Clean Cars Minnesota now.

OAH Docket No. 71-9003-36416 Name: Caley Long

Zip Code: 55105

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards (I am hopeful for change in 2021 but we need to act on a state level!). Clean Cars Minnesota reduces pollution and gives customers more choice, let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Lori Olinger

Zip Code: 55127

Comment:

I bought a Bolt two years ago and love driving it. I am concerned about pollution and climate change and that was my primary reason for buying an electric car but it has been a great purchase for many reasons. I love being able to charge it in my garage and I'm saving money compared to what I would have spent on gas. I'm saving on maintenance expenses too. And it is very fun to drive. I support Clean Cars Minnesota for many reasons but the main reason is that it would give Minnesotans more choices when they shop for an EV. There were very few cars available when we purchased our car 2 years ago. The sales person said they don't get very many Bolts because almost all of the cars go to states with incentives or with emissions standards like California. The car salesperson who sold us our car wasn't very familiar with the Bolt because he didn't sell many. We checked with lots of other dealers and found the same situation - very few options. Many of the cars we researched weren't even sold in Minnesota. We need to change that and give Minnesotans more EV options.

OAH Docket No. 71-9003-36416 Name: Leslie Martin

Zip Code: 55120

Comment:

I drive my daughter's old 2004 Honda Accord. It's a great car but I'd rather be driving an electric. EVs are far too expensive for this senior citizen, though, and that's a darn shame.

That's one reason I support Clean Cars Minnesota. Clean car standards are not only a proven way to reduce air pollution, they also bring down the cost of EVs. Who's not for that?

Further, communities of color and other marginalized and vulnerable communities currently bear the brunt of negative health impacts from air pollution--especially pollution caused by transportation.

Fourteen other states and Washington, D.C. have already adopted clean car standards, a wise move considering that the federal government has been actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice when it comes to leasing or buying a car or truck.

Ultimately, we need to do everything we can to reduce Minnesota’s dependence on fossil fuels and make the transition to clean, local energy that doesn’t harm our lakes, forests, air and people. With Clean Cars Minnesota, more Minnesotans will transition to a zero emission or low emission vehicle when they buy or lease their next car or truck, and thus reduce our dependence on fossil fuels.

Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards, and let's not waste any more time!

OAH Docket No. 71-9003-36416 Name: Gary Schettl

Zip Code: 55352

Comment:

My family is proof that electric vehicles work well in Minnesota. We have already converted 2 of our 3 cars to electric, and the third will be replaced when our all-electric pick-up truck arrives. Having driven electric cars for 8 years, (250,000 miles) we have saved over $20,000 in fuel costs. We support the clean cars initiative. To top it off, in 2023 electric cars are expected to cost less than gas cars, up front, (and they already are if maintenance costs are factored in).

OAH Docket No. 71-9003-36416 Name: Judy and Jerry Hofgman

Zip Code: 55120

Comment:

A healthy environment means survival for humans.. Any and all solutions necessary now.

OAH Docket No. 71-9003-36416 Name: Chris Fenne

Zip Code: 55118

Comment:

OAH Docket No. 71-9003-36416 Name: Dick Ottman

Zip Code: 55110

Comment:

Clean Car Standards are badly needed as Climate Change is real, and is causing devastating effects on our weather and society. I own an all electric Chevrolet Bolt, and it runs great.

OAH Docket No. 71-9003-36416 Name: Michael Overend

Zip Code: 0

Comment:

Dear MPCA,

The Clean Cars Minnesota Standard proposal is a win for our health, our economy, our environment and for jobs to support the necessary transformation to electric vehicles. Please adopt these standards and continue working toward additional Climate Solutions in every area of our State.

Thanks very much.

OAH Docket No. 71-9003-36416 Name: Stuart Knappmiller

Zip Code: 0

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice, let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

Cleaner cars mean cleaner air for myself and my neighbors. I love to be outside in my neighborhood but worry about how the air pollution coming from the cars and trucks passing by are affecting our health. I know that pollution harms lungs and hearts, especially when breathed in regularly. I also know that communities of color and low- income communities bear the brunt of the negative health impacts from air pollution. Clean Cars Minnesota would dramatically reduce these emissions and help protect me and everyone in my neighborhood.

Minnesota imports tons of gallons of oil annually while at the same time producing lots of electricity from clean sources from wind and power that’s even cheaper than gasoline – why? Let’s harness the wind and the sun (as we have in our roof) to power our vehicles with Minnesota-grown energy that’s clean to boot! Clean Cars Minnesota is a win-win- win. It will put more EVs on the road, increase the demand for home-grown clean energy, and boost clean energy jobs.

I'm tired of asking for and not being shown an EV at our dealer.

OAH Docket No. 71-9003-36416 Name: Marilyn Jones

Zip Code: 55113

Comment:

Let's do this now - legislate electric cars and the necessary infrastructure to keep them charged.

OAH Docket No. 71-9003-36416 Name: Chris McCollom

Zip Code: 55418

Comment:

Passing the clean car legislation is the bare minimum of what should be expected from our elected officials to fight climate catastrophe. I give my full support to this and future legislation to get us on a track to true carbon neutral standards.

OAH Docket No. 71-9003-36416 Name: Laurel Bruno

Zip Code: 55112

Comment:

Please pass the Clean Car Standards. Minnesota must do more to eliminate CO2 from transportation.

OAH Docket No. 71-9003-36416 Name: Ah-li Monahan

Zip Code: 55421

Comment:

I am concerned about climate change and feel strongly that reducing or eliminating carbon from vehicle exhaust is critically important!

OAH Docket No. 71-9003-36416 Name: Michelle Horan

Zip Code: 55416

Comment:

OAH Docket No. 71-9003-36416 Name: Laurence Margolis

Zip Code: 55345

Comment:

Combatting climate change should be a top priority and transitioning to an EV is one way to help in that fight. I drive an EV and I believe the overall cost of the vehicle over its life is less than a gas powered vehicle.

OAH Docket No. 71-9003-36416 Name: Amy Dritz

Zip Code: 55432

Comment:

I support Clean Cars Minnesota for three major reasons: clean air, equity, and economics.

Air pollution is a concern for everyone in our state, and especially for communities of color and under-resourced communities who bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Clean Cars Minnesota is a major step toward cleaning up our air and dismantling policies and that disproportionally harm Minnesota’s most vulnerable and marginalized communities.

Additionally, electric vehicles can save people money because they have lower maintenance, operating, and fuel costs than a traditional gasoline-powered vehicle. However, both new and used electric vehicles are hard to track down here in Minnesota because they often go straight to other states with clean car standards. Clean Cars Minnesota would bring more EVs to Minnesota's new and used car marketplace and make EVs more widely accessible to all income brackets.

I have been an EV owner since 2013 and own a plug-in hybrid and an all-electric battery EV. It has been frustrating for me and others to not have access to a wider variety of electric vehicles that meet a wider range of needs (range, capacity, features, etc.). I've talked to many people about switching to electric vehicles and often the price, range of miles, and/or size of currently available models just doesn't fit their family needs. This is extremely frustrating when I know that other models exist but we don't have access here in Minnesota. Cars and trucks bought today will be on the road for the next 10 years – we can't afford to wait!

OAH Docket No. 71-9003-36416 Name: Lane Ayres

Zip Code: 55424

Comment:

I have serious asthma so clean air is important to me. I would buy an EV is there were more options in Minnesota and if there were more charging stations around the state.

OAH Docket No. 71-9003-36416 Name: Millie Webb

Zip Code:

Comment:

Minnesota imports tons of gallons of oil annually while at the same time producing lots of electricity from clean sources from wind and solar that’s even cheaper than gasoline – why? Let’s harness the wind and the sun to power our vehicles with Minnesota-grown energy that’s clean to boot! Clean Cars Minnesota is a win-win-win. It will put more EVs on the road, increase the demand for home-grown clean energy, and boost clean energy jobs. We recently bought our first plug-in hybrid EV (used, because new is so incredibly expensive), and we absolutely adore it. My sole "if only" about this car, is that I wish we could also afford to install solar panels and get credits to send excess energy from them back to the power grid. We are saving up for a remodel, and especially if the cost of solar continues to comedown, we hope to also install solar panels to run our stove, dryer, washer, hot water heater, and other appliances, as well as future EVs for our family.

OAH Docket No. 71-9003-36416 Name: Brad Benn

Zip Code: 55435

Comment:

I’m doing what I can. I’ve driven electric since 2013. I’ve been disappointed at how unaware dealers’ salespeople are. Need clean car to get this going.

OAH Docket No. 71-9003-36416 Name: Joseph Strommen

Zip Code: 55431

Comment:

OAH Docket No. 71-9003-36416 Name: B Pearlman

Zip Code: 55118

Comment:

I want to buy an electric vehicle but there are so few choices in MN - the dealers say our state just does not support them. I can't believe that! Minnesota MUST be in the forefront of giving our citizens choices for electric cars AND taking a stand against climate change. Please make clean cars a priority here RIGHT AWAY! THANKS

OAH Docket No. 71-9003-36416 Name: Emily Ziring

Zip Code: 55410

Comment:

I support Clean Cars Minnesota. Cleaner cars mean cleaner air for myself and my neighbors. I love to be outside in my neighborhood but worry about how the air pollution coming from the cars and trucks passing by are affecting my health. I know that pollution harms lungs and hearts, especially when breathed in regularly. I also know that communities of color and low-income communities bear the brunt of the negative health impacts from air pollution. Clean Cars Minnesota would dramatically reduce these emissions and help protect me and everyone in my neighborhood. Further, the time to save our climate is now and we can only do it if we fully embrace a home-grown clean energy economy that doesn’t harm our communities, air, lakes and forest. Clean Cars Minnesota is one piece of the puzzle that help Minnesotans transition to a zero emission future at a faster pace.

OAH Docket No. 71-9003-36416 Name: john grinager

Zip Code: 55118

Comment:

We need this bill to make sure our grandchildrens' granchildren can breath fresh air!

OAH Docket No. 71-9003-36416 Name: Nancy Hassett

Zip Code: 55309

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice, let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: JoAnn W Pasternack

Zip Code: 55118

Comment:

As a grandmother, a lover of Minnesota's great outdoors, and a social justice advocate, I support Clean Cars Minnesota. Cleaner cars mean cleaner air for my and other people's grandkids, as well as vulnerable people like the elderly and those with preexisting conditions.

Communities of color and under-resourced communities currently bear the brunt of negative health impacts from the air pollution caused by transportation. Policies like Clean Cars Minnesota represent a small, but significant step toward dismantling policies and other systemic barriers that disproportionately harm Minnesota’s most vulnerable and marginalized communities.

In my ventures outdoors, I have seen direct negative effects from CO2 and dirty vehicle emissions. For myself, my community, and my grandchildren, I strongly advocate for passage of Clean Cars Minnesota. Thank you.

OAH Docket No. 71-9003-36416 Name: alexis reid

Zip Code: 55902

Comment:

OAH Docket No. 71-9003-36416 Name: Adam Marquardt

Zip Code: 55104

Comment:

OAH Docket No. 71-9003-36416 Name: Linda Zespy

Zip Code: 55410

Comment:

I’m concerned about our health and having clean air for my kids. Clean Cars MN makes so much sense!

OAH Docket No. 71-9003-36416 Name: Tess Bakken-Ziring

Zip Code: 55410

Comment:

I am 12 years old, and I think that it is SO important to act now before it's too late. I think that making electric vehicles easier to own is a step in the right direction.

OAH Docket No. 71-9003-36416 Name: Benjamin Bakken

Zip Code: 55410

Comment:

We are one of the most beautiful states in the country and we must be at the front of protecting our natural environment. We need access, tools, advocates and opportunities to be the best we can me. I'm a progressive and I support Walz and his team and their efforts to improve Minnesota.

OAH Docket No. 71-9003-36416 Name: brian fortmeyer

Zip Code: 55424

Comment:

OAH Docket No. 71-9003-36416 Name: Joelyn Malone

Zip Code: 55416

Comment:

OAH Docket No. 71-9003-36416 Name: Dave Crawford

Zip Code: 55117

Comment:

Right now, many electric vehicles don’t even make it to Minnesota dealerships because they go straight to states like Maryland and Oregon with clean car standards - that’s just not fair. Minnesotans should be able to buy whichever car they want.

We need to do everything we can to reduce Minnesota’s dependence on fossil fuels and transition to clean, local energy that doesn’t harm our lakes, forests, air, and people.

Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Nikki Niermann

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Laura Bretheim

Zip Code: 55419

Comment:

OAH Docket No. 71-9003-36416 Name: Dennis Sweet

Zip Code: 55417

Comment:

I care about our environment and I support Clean Cars Minnesota. Climate change is threatening our forests, water, and air. Our winters are already warming faster than the national average, and our northern forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late. Furthermore, buying a car or truck is a big decision with so many factors to consider. Minnesotans deserve to be able to access to all the vehicles available in the U.S. marketplace when they’re deciding to buy or lease. Right now, many electric vehicles don’t even make it to Minnesota dealerships because they go straight to states like Maryland and Oregon with clean car standards - that’s just not fair. We Minnesotans should be able to buy whichever car they want.

OAH Docket No. 71-9003-36416 Name: Jean Ross

Zip Code: 55409

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice, let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Shannon Churchward

Zip Code: 55410

Comment:

We need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Sheryl Theuninck

Zip Code: 55330

Comment:

I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota's forests, water and air. Our winters are already warming faster than the national average and our northern boreal forests are at risk of disappearing. Cars and trucks on the road are our #1 source of climate change causing pollutants in our state and nationally. So we need to act to reduce greenhouse gas emissions before it's too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let's act before it's too late.

OAH Docket No. 71-9003-36416 Name: Benjamin Wong

Zip Code: 55902

Comment:

I support Clean Cars Minnesota. Air pollution is a serious global issue that affects everyone and MN is not immune to air pollution’s harmful effects. MN needs to do its part in contributing to a solution. Clean Cars Minnesota is a major step toward cleaning up our air. The federal government has been reversing the progress made on reducing air pollution in our country to help maximize profits for Big Oil. If Washington won’t or can’t lead, Minnesota will and Governor Walz has shown strong leadership in pushing for innovative solutions to the climate crisis. Clean Cars Minnesota would keep Minnesota on the right track for slowing climate change and reducing air pollution. We all need to work together to protect the health of future generations.

OAH Docket No. 71-9003-36416 Name: Pamela Moret

Zip Code: 55403

Comment:

I’m an outdoorsperson and I support Clean Cars Minnesota. Minnesota is a great place to be an outdoorsperson but climate change is threatening our way of life. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally, so we need to act NOW to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to slowing climate change and reducing greenhouse gas emissions from transportation. Let’s act now before all the changes we’re already seeing become permanent.

OAH Docket No. 71-9003-36416 Name: Heather Hunt

Zip Code: 55410

Comment:

I am a parent who loves to spend time with my son’s outdoors. We kayak, swim, bike, hike, ski, walk, explore and breathe in the fresh air. Please protect that which we need to enjoy the outdoors.

OAH Docket No. 71-9003-36416 Name: Pat Peschman

Zip Code: 55124

Comment:

I am a gardener and outdoors person. The effects of climate change over the past decade are clearly visible in our state. I am working hard to do what I can as an individual but passing Clean Cars Minnesota would move Minnesota forward much more quickly. I own a hybrid but my next car will be all electric. I want a supply of cars and the infrastructure to support them available to me. Implementing this standard will galvanize the changes we need in Minnesota

OAH Docket No. 71-9003-36416 Name: Neil Moses-Zirkes

Zip Code: 55118

Comment:

I support Clean Cars Minnesota. We are in a toxic relationship with Big Oil and it’s time to cut ties. We need to do everything we can to reduce Minnesota’s dependence on fossil fuels and transition to clean, local energy that doesn’t harm our lakes, forests, air, and people. With Clean Cars Minnesota more Minnesotans will transition to a zero emission or low emission vehicle when they buy or lease their next car or truck, and thus reduce our dependence upon fossil fuels. We need to do this for our children, their children and their children.

OAH Docket No. 71-9003-36416 Name: Nick Fortmeyer

Zip Code: 55432

Comment:

I am an outdoorsman and value clean water, air and the environment. I see the impact that our practices have had on the state of Minnesota. It has impacted recreation, tourism and environmental health. I support clean cars Minnesota. Let’s act now.

OAH Docket No. 71-9003-36416 Name: Eleanor Nervig

Zip Code: 55417

Comment:

OAH Docket No. 71-9003-36416 Name: WmC Mantis

Zip Code: 55101

Comment:

I currently drive a hybrid. I look forward to the day when I, and all of our neighbors, drive an EV.

OAH Docket No. 71-9003-36416 Name: Ralph Brindle

Zip Code: 55439

Comment:

The critical move to a sustainable renewable energy environment begins with access by consumers to all electric vehicles being manufactured. Unless market demand is felt by vehicle manufacturers, they will continue to drag their feet in moving to electric vehicles. I believe Minnesotans will lead the way to an electric car future if given the chance.

OAH Docket No. 71-9003-36416 Name: Amy M Lindquist

Zip Code: 55127

Comment:

As a parent I am deeply concerned for the health of the next generation. They need clean air and water.I am also an outdoor enthusiast and already see the negative effects of climate change on our natural treasures. Please support clean cars!

OAH Docket No. 71-9003-36416 Name: Ellie Haus

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Bradley Blackett

Zip Code: 55124

Comment:

I strongly support any and all efforts to move personal and light weight fleet vehicles as well as Public ground transportation including school buses to all electric vehicles the sooner the better!

Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions.

Plus I believe we should be conserving what oil there is for Air Transportation and a few construction vehicles or machinery whose only fuel source is oil. It is the only excuse for consuming this natural resource at this time, until alternatives are found. i.e. electric bullet trains for cross country travel.

Along with that I would like to see the reduction of oil derived plastics that contribute to wasteful packaging and micro fabrics. 1) to reduce overflowing landfills and incineration of garbage that have no recycle markets. 2) to eliminate plastics from our surface waters.

OAH Docket No. 71-9003-36416 Name: Christopher Cloutier

Zip Code: 55105

Comment:

I have owned 3 electric vehicles - currently own one - and intend to own one for the rest of the time I own cars. The challenge in buying one in MN is so many dealerships either don't stock them at all, or if they do stock them, the inventory is incredibly limited and none of the sales staff know anything about them. This has to change in order for EV's to go mainstream. This is not sufficient, but it is a necesary next-step.

OAH Docket No. 71-9003-36416 Name: Rao Konidena

Zip Code: 55113

Comment:

I’m a business owner and I support Clean Cars Minnesota. As a business owner, keeping abreast of market trends helps me to make sound financial decisions. Companies who have set carbon reduction goals, like Target, 3M, and Best Buy, could more easily meet these goals through fleet electrification with clean car standards. . Clean Cars Minnesota presents a major opportunity for companies to reduce their carbon emissions and build on our state’s history of innovation and leadership.

OAH Docket No. 71-9003-36416 Name: Tom Bothwell

Zip Code: 55616

Comment:

We support a government initiative for a fast shift to electric vehicles. We own one now and will never go back. The environment and economics dictate the need. Tax incentives should be an immediate tool.

OAH Docket No. 71-9003-36416 Name: Michael Huber

Zip Code: 55317

Comment:

I’m also an EV owner. Driving an electric vehicle in Minnesota is a freeing experience. You can go from point A to point B without worrying about harmful tailpipe emissions and since EVs don’t have internal combustion engine they warm up much faster in the winter and have considerably lower maintenance costs. Clean Cars Minnesota would give the 6 in 10 prospective car buyers in Minnesota who are interested in electric vehicles the opportunity to actually see and test drive a much wider variety of makes and models - many of which currently don’t even make it to our state because they go to states with clean cars standards. Buying a car or truck is a big choice and Minnesotans deserve the chance to weigh all options.

OAH Docket No. 71-9003-36416 Name: Nicholas Banovetz

Zip Code: 55118

Comment:

I’m an outdoorsman and I support Clean Cars Minnesota. MN is a great place to be an outdoorsperson, but climate change is threatening our way of life. Cars and trucks on the roads are a leading source of climate change-causing pollution in our state and nationally, so we need to act NOW to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to slowing climate change and reducing greenhouse gas emissions from transportation. Let’s act now before all the changes we’re already seeing become permanent.

OAH Docket No. 71-9003-36416 Name: Steve Mann

Zip Code: 55116

Comment:

OAH Docket No. 71-9003-36416 Name: Jeff Riegle

Zip Code: 55082

Comment:

OAH Docket No. 71-9003-36416 Name: Jason Astleford

Zip Code:

Comment:

I’m a progressive and believe the time to make bold changes to save our climate is now.

OAH Docket No. 71-9003-36416 Name: Carmine Profant

Zip Code: 55407

Comment:

I am for making electric vehicles in Minnesota as affordable and accessible as possible. I want Minnesota to join other states in adopting clean car standards and I want to be able to go to a car dealership and find a good selection of plug-in electric vehicles so I can find the one that fits my needs and budget. I'm excited to be part of a clean energy future. Please adopt Clean Cars Minnesota!

OAH Docket No. 71-9003-36416 Name: Paul Carlson

Zip Code: 55108

Comment:

I’m a Minnesota EV owner and I support Clean Cars Minnesota.

I have driven an electric car for over two years.

Electric cars are better vehicles and we should do everything we can to offer everyone in Minnesota an opportunity to choose an EV. Right now, the EV availability is poor at dealers and we need to change that.

I have personally had challenges in buying an EV in Minnesota. Fortunately, there is a pre-owned market out there, but it's simply not enough for consumers.

I support Clean Cars MN because of the following:

• EVs don’t produce tailpipe emissions. Increasing EV adoption improves the air quality, especially in areas where vehicle traffic produces a lot of pollution. • EVs also use much less energy than internal combustion engine (ICE) cars so the overall emissions are considerably lower, and they improve our trade balance since we don’t need to import so much oil. • Since EVs consume less energy, they are much cheaper to drive. EVs have considerably lower maintenance costs so they are also much cheaper to own. Used EVs are the most affordable cars available. • In 2019, the average EV sold in Minnesota had over 250 miles of range, and when we have more choices everyone can find one that works for them. EVs are quieter and provide better performance, leading to a better driving experience. • Safety is important to me and IIHS test results clearly show that EVs are very safe. • EVs are great winter cars! They have emission free preheating functions and fast heating systems. • Home charging is the most convenient and affordable way to power driving. Public charging is a valuable service, but I don’t use public charging very often, so

OAH Docket No. 71-9003-36416 the current public charging infrastructure works well for me. I also feel confident that we will have more public charging infrastructure available in the future. • EVs reduce our dependence on imported oil so we can keep our dollars in Minnesota and not inhale the emissions caused by refining oil and burning gas. • Electric utilities are moving away from coal and adding clean renewable electricity production. EVs gets cleaner every day. At our home (where we charge our EV), we only purchase renewable energy from Xcel Energy. • Auto manufacturers are bringing dozens of new EV models to the US market before 2024, and I want to make sure that Minnesotans have access to ALL these options. • Clean Cars Minnesota would give 6 in 10 prospective car buyers in Minnesota who are interested in electric vehicles the opportunity to actually see and test drive a much wider variety of makes and models—many of which currently don’t even make it to our state because they go to states with clean cars standards. • Used EVs are the most affordable cars to own and drive. Even though Clean Cars Minnesota rules apply only to new vehicle sales, this also has an impact on the number of more affordable used EVs, since we first have to get the new EVs to build a healthy used EV market. • Even if most Minnesota auto dealers don’t understand it yet, they need Clean Cars Minnesota to stay competitive in the future. We have seen in recent years that even those dealers that would like to get more active in selling EVs often have a hard time getting cars. Clean Cars Minnesota will send a clear signal to auto manufacturers that Minnesota wants these options for our consumers, and will help our local auto dealers to stay competitive in the future.

I’m also happy with this rule making process since I understand that oil interests would be against efforts to increase EV adoption no matter what the process would be.

Since I drive an EV I’m happy to talk more about all these topics.

Those who oppose EVs simply don’t have experience in driving EVs. Don't listen to their misguided rants. Listen to actual EV drivers.

OAH Docket No. 71-9003-36416 Name: Bryce Pier

Zip Code: 55408

Comment:

I support Clean Cars MN because:

EVs don’t produce tailpipe emissions, so increasing EV adoption improves the air quality, especially in areas where vehicle traffic produces a lot of pollution.

EVs also use much less energy than ICE cars so the overall emissions are considerably lower, and they improve our trade balance since we don’t need to import so much oil.

Since EVs consume less energy, they are much cheaper to drive, and EVs have considerably lower maintenance costs so they are also much cheaper to own. Used EVs are the most affordable cars available.

In 2019, the average EV sold in Minnesota had over 250 miles of range, and when we have more choices everyone can find one that works for them. EVs are quieter and provide better performance, leading to a better driving experience.

EVs are great winter cars. They have emission free preheating functions and fast heating systems.

Home charging is the most convenient and affordable way to power driving. Public charging is valuable service, but I don’t use public charging very often, so the current public charging infrastructure works well for me. I also feel that confident that we will have more public charging infrastructure available in the future.

EVs reduce our dependency on imported oil so we can keep our dollars in Minnesota and don’t need to inhale the emissions caused by refining oil and burning gas.

Electric utilities are moving away from coal and adding clean renewable electricity production. EVs gets cleaner every day.

OAH Docket No. 71-9003-36416 Auto manufacturers are bringing dozens of new EV models to the US market before 2024, and I want to make sure that Minnesotans have access to all these options.

OAH Docket No. 71-9003-36416 Name: Jason Willett

Zip Code: 55082

Comment:

I'm on my third EV and love them.

I will never buy an ICE again and so would love more EV choices.

That said, of course we should work to clean the air, and reduce road noise, especially for the disadvantaged neighborhoods (including minority residents and businesses) that live near roads. And of course we should accelerate our climate change mitigation for everyone, including my 10 grandchildren and theirs to come. And of course we should move to less utilization of fossil fuels which Minnesota must buy and as we can use Minnesota's solar electricity to power transportation and keep our money circulating here!

OAH Docket No. 71-9003-36416 Name: Eric Gossett

Zip Code: 55448

Comment:

I strongly support the Clean Cars Minnesota initiative. I have been an electric car owner since 2012 -- but have always needed to travel at least 30 minutes to buy or service my vehicles. Electric cars are better for the environment, and over the course of ownership, are less expensive than comparable gas vehicles (due to much more affordable maintenance costs).

OAH Docket No. 71-9003-36416 Name: Patrick Hansen

Zip Code: 55306

Comment:

OAH Docket No. 71-9003-36416 Name: Dorette R Kerian

Zip Code: 55437

Comment:

We need to clean our air and decarbonize our transportation for our individual health, the health of the planet and so that my grandchildren and yours may be able to enjoy the natural world as I was able to. Clean Car MN is needed so that I have access to EV auto information and choice as I seek my first EV this year and to enable ways to power that vehicle as I travel. I seek to purchase my vehicle in state--if there are dealers and auto supply --but will go where needed to get my EV.

OAH Docket No. 71-9003-36416 Name: Jessica Guillotel

Zip Code: 55347

Comment:

I support clean cars MN and EVs are great for Minnesota. When I purchased my EV I had to go searching on the East coast. It is extremely important for Minnesotans to have a wide variety of affordable EVs available for purchase within Minnesota.

OAH Docket No. 71-9003-36416 Name: Maureen Fries

Zip Code: 55406

Comment:

We bought a Chevy Bolt 2020, an electric car, in September 2020. It was difficult to find. The large dealerships push huge gasoline cars and trucks. We purchased from an independent business owner. As Minnesotans we were disappointed our state is so backward. Get with the program; fossil fuels are killing us. This is 50-year old information. Let’s roll Minnesota.

OAH Docket No. 71-9003-36416 Name: Patricia Ohmans

Zip Code: 55104

Comment:

As a 40 year resident of the Frogtown neighborhood and an environmentalist, I know that climate change is going to hit my neighbors harder than residents of other, better- resourced communities. Several major commuter arteries slice through our neighborhood, carrying cars and trucks to the highways that border it. These add to the emissions that have already put Frogtown in the EPA's 95th percentile for air pollution. Please support Clean Cars Minnesota, which will help reduce air pollution from transportation and make my neighborhood healthier.

OAH Docket No. 71-9003-36416 Name: Steven Baxa

Zip Code: 56082

Comment:

I’m not from the Twin Cities metro area and I support Clean Cars Minnesota. Clean cars save money on fuel costs, and as someone who drives longer distances that means more savings for me. But it’s hard to find the specific new or used car you want – especially if its electric – when you’re shopping outside of the Twin Cities. In rural Minnesota, we have the least access to the full range of makes and models available in Minnesota and the U.S. Clean Cars Minnesota would change that by bringing more types of cars and trucks here, giving us more options to choose from.

OAH Docket No. 71-9003-36416 Name: Susan Westacott

Zip Code: 55418

Comment:

I’m a Minnesota EV owner and I support Clean Cars Minnesota.

Electric cars are an amazing option for many reasons and we should do everything we can to offer everyone in Minnesota an opportunity to choose an EV that would work for them. Right now, the EV availability is challenging at dealers and thus also at the downstream used market.

I support Clean Cars MN because EVs are:

Good for the environment - great for improving air quality, reducing noise pollution, great for reducing carbon emissions and thus helping battle global climate change.

Good for consumers - super affordable to maintain & run, easy and fun to drive, safe, warm up fast in the winter.

Right now, the limited availability of electric vehicles (both in sheer numbers and in variety of vehicles) in Minnesota hampers the ability of interested consumers to research, test drive and choose a vehicle that would work for their needs and pocketbooks. This then slows adoption of EVs. Minnesotans should have access to all the options that are on the market and will soon be coming to market.

Even if most Minnesota auto dealers don’t understand it yet, they need Clean Cars Minnesota to stay competitive in the future. EVs are the future and I’d love to see Minnesota at the forefront rather than running to catch up!

I’m also happy with this rule making process since I understand that oil interests would be against efforts to increase EV adoption no matter what the process would be.

Thanks for the opportunity to share my perspective as a Minnesotan with a strong interest in a clean environment for all the coming generations AND a happy EV driver.

OAH Docket No. 71-9003-36416 Name: Karen Hulstrand

Zip Code: 55082

Comment:

I am a retired family physician and know the importance of clean air and the health concerns of climate change that will happen. I also drive a plug-in hybrid Chevrolet Volt and have been very happy with it. My experience shopping for an EV was difficult due to lack of cars to check out and the disappointing lack of knowledge of the car salespeople I talked with. I am in support of this rule and very much hope other people get to experience the benefits of electric cars as we do what we can to slow climate change and improve the risks to our health.

OAH Docket No. 71-9003-36416 Name: Timothy Davis

Zip Code: 55412

Comment:

We need cleaner automobile choices, and a state government that supports a cleaner environment.

OAH Docket No. 71-9003-36416 Name: Bud Ensley

Zip Code: 55303

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

I have driven electric cars(3 cars) for 8 years, starting with two(2) Nissan Leaf and now a Tesla Model 3. My wife has her own electric car a Chevy Bolt. We still remember how hard it was to find our cars because the dealers not wanting to sale electric. We do not put tons of wast into the air nor oil on the roads or garage floor, and ice at stop lights from tail pipe exhaust. We know our cars will not cause people with health problem trouble.

Since EVs consume less energy, they are much cheaper to drive, and EVs have considerably lower maintenance costs so they are also much cheaper to own. Used EVs are the most affordable cars available.

Electric utilities are moving away from coal and adding clean renewable electricity production. EVs gets cleaner every day.

OAH Docket No. 71-9003-36416 getting cars. Clean Cars Minnesota will send a clear signal to auto manufacturers that Minnesota wants these options for our consumers, and will help our local auto dealers to stay competitive in the future.

OAH Docket No. 71-9003-36416 Name: Abby Young

Zip Code: 55126

Comment:

I care about our environment. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change.

OAH Docket No. 71-9003-36416 Name: Cole Kracke

Zip Code: 55425

Comment:

I’m an EV owner and I support Clean Cars Minnesota. Driving an electric vehicle in Minnesota is a freeing experience. You can go from point A to point B without worrying about harmful tailpipe emissions and since EVs don’t have internal combustion engine they warm up much faster in the winter and have considerably lower maintenance costs. Clean Cars Minnesota would give the 6 in 10 prospective car buyers in Minnesota who are interested in electric vehicles the opportunity to actually see and test drive a much wider variety of makes and models - many of which currently don’t even make it to our state because they go to states with clean cars standards. Buying a car or truck is a big choice and Minnesotans deserve the chance to weigh all options.

OAH Docket No. 71-9003-36416 Name: Bryn Shank

Zip Code: 55105

Comment:

Electric vehicles are more eco friendly and they cost less to operate because electricity is cheaper than gas. When I was looking to lease a PHEV last year it was somewhat difficult since so few models are available in MN because we don’t have a clean cars standard. Passing this will give consumers more choice.

OAH Docket No. 71-9003-36416 Name: Natalie Bothwell

Zip Code: 55616

Comment:

We need to promote more use of EV and hybrid cars to protect the environment and people's health. We currently own a Prius Prime and are getting over 92 mpg with it. More should be available to purchase! Having a higher mpg standard and more charging stations around the state would promote more people investing in EV vehicles.

OAH Docket No. 71-9003-36416 Name: James Guenter

Zip Code: 55105

Comment:

I’m a Minnesota EV owner and I support Clean Cars Minnesota.

I have driven electric cars for 12 years and over 150,000 miles. I’ve driven almost 50,000 in my latest, all-electric vehicle.

Electric cars are better vehicles with significantly less maintenance, the electricity is less expensive than gas and the cars are must more efficient, and they are so much cleaner, especially as our electrical grid uses more renewable energy. We should do everything we can to offer everyone in Minnesota an opportunity to choose an EV. Right now, the EV availability is poor at dealers and we need to change that.

I have personally had challenges in buying an EV in Minnesota. After trips to both Chevy and Ford dealership I have found they they are not equipped or motivated to sell EVs. Their salespeople are not informed about the technology and do their best to sell you other cars in their fleet. I can only imagine this is because they know they will lose years of maintenance and service funds because EVs just don’t break down as often. Minnesotan’s deserve access to low maintenance, non-emitting cars.

I support Clean Cars Minnesota and the advancement of EVs because:

EVs don’t produce tailpipe emissions, so increasing EV adoption improves the air quality, especially in areas where vehicle traffic produces a lot of pollution. EVs also use much less energy than ICE cars so the overall emissions are considerably lower, and they improve our trade balance since we don’t need to import so much oil.

In 2019, the average all-electric EV sold in Minnesota had over 250 miles of range, and when we have more choices everyone can find one that works for them. EVs are quieter and provide better performance, leading to a better driving experience.

OAH Docket No. 71-9003-36416 Safety is important to me and IIHS test results clearly show that EVs are very safe. Their architecture simply allows more space for life saving crumple zones and other structures.

EVs are great winter cars. They have emission free preheating functions and fast heating systems. There is no risk of deadly fumes when you warm your EV in a closed garage.

Home charging is the most convenient and affordable way to power driving. Public charging is valuable service, but I don’t use public charging very often, in fact I only use it for road trips so the current public charging infrastructure works well for me. I also feel that confident that we will have more public charging infrastructure available in the future.

Electric utilities are moving away from coal and adding clean renewable electricity production. EVs gets cleaner every day.

Auto manufacturers are bringing dozens of new EV models to the US market before 2024, and I want to make sure that Minnesotans have access to all these options.

Clean Cars Minnesota would give the 6 in 10 prospective car buyers in Minnesota who are interested in electric vehicles the opportunity to actually see and test drive a much wider variety of makes and models—many of which currently don’t even make it to our state because they go to states with clean cars standards.

Used EVs are the most affordable cars to own and drive. Even though Clean Cars Minnesota rules apply only to new vehicle sales, this also has an impact on the number of more affordable used EVs, since we first have to get the new EVs to build a healthy used EV market.

Even if most Minnesota auto dealers don’t understand it yet, they need Clean Cars Minnesota to stay competitive in the future. We have seen in recent years that even those dealers that would like to get more active in selling EVs often have a hard time getting cars. Clean Cars Minnesota will send a clear signal to auto manufacturers that Minnesota wants these options for our consumers, and will help our local auto dealers to stay competitive in the future.

OAH Docket No. 71-9003-36416 I also believe that this type of rule will be short lived. EVs are such a better technology that they will soon be the car of choice for virtually everyone. We just need to get the dealerships out of the way of EV innovation.

I’m also happy with this rule making process since I understand that oil interests would be against efforts to increase EV adoption no matter what the process would be.

Since I drive an EV I’m happy to talk more about all these topics. Most people who oppose EVs are not informed and have not had experience with them. I would love to help.

OAH Docket No. 71-9003-36416 Name: Stacy Nordstrom

Zip Code: 55113

Comment:

I’m a parent and I support Clean Cars Minnesota. Cleaner cars mean cleaner air for my kids, along with other vulnerable folks like the elderly and those with preexisting conditions who are most affected by the harmful effects of vehicle emissions. Clean Cars Minnesota will dramatically reduce these emissions and help protect my kids (and everyone else too!) when they’re waiting at the bus stop, walking in the neighborhood, or even just playing in the yard. Human health is at stake and the longer we wait, the more kids whose current and future health and wellbeing will be harmed by dirty vehicle emissions.

OAH Docket No. 71-9003-36416 Name: Tom Hatlestad

Zip Code: 55446

Comment:

OAH Docket No. 71-9003-36416 Name: Garrett Prehatney

Zip Code: 55330

Comment:

I support Clean Cars MN and I believe EVs are good for all Minnesotans.

OAH Docket No. 71-9003-36416 Name: Meli Mendoza

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: James Jonza

Zip Code: 55042

Comment:

I am a 3M scientist and I know the serious path toward an increase of 4 Celcius we are on. It is very important that we reduce the carbon dioxide emissions from transportation now. I found it nearly impossible to get an EV this summer. We need access to the Hyundai's, VWs, etc, not just Tesla.

OAH Docket No. 71-9003-36416 Name: Roger Klisch

Zip Code: 55082

Comment:

Please approve the clean car standards for Minnesota. I own an electric and we need this standard to provide momentum so that we can reach clean energy standards set by utilities, states, the federal government, and the Paris climate accord.

OAH Docket No. 71-9003-36416 Name: Cindy Lindquist

Zip Code: 55417

Comment:

I am a grandmother and am very concerned for the health of my grandkids. Clean cars is a must for the health of our kids and for the health of the planet.

OAH Docket No. 71-9003-36416 Name: James bohl

Zip Code: 55417

Comment:

Its time to show that there really is a care for what world we give our children. I know that argument is often used buy the cost of doing nothing is now far past and overdue. We can make small steps that will get us to the proper running speed.

OAH Docket No. 71-9003-36416 Name: Katherine Rogers

Zip Code: 55345

Comment:

I bought my first plug-in hybrid, a Prius Prime, two years ago. I couldn’t get one in Minnesota and had to go to Northern Virginia and buy it there. I am now ready to buy a second full EV and will travel again out of state if I must. But that is not why I support the ZEV.

I am originally from California and this summer was Armageddon. The air, a weirdly orange hue, was so dangerous you couldn’t walk outside. Ash coated every surface. Growing up, 100 degrees was a hot day. It was 113 this year. There has been no rain and the ground is sinking as the aquafers disappear. My family’s well ran dry. The electricity is turned off on windy days. Neighbors can’t get homeowners insurance because the risk of fire is so great… This is not the dystopian future, this is now. Supporting ZEV is the least we can do.

OAH Docket No. 71-9003-36416 Name: Marc Ballbach

Zip Code: 55345

Comment:

I have chosen to no longer purchase internal combustion cars and own two EV's and am purchasing my third this winter. I would be prefer to have as many options as possible and for the state of MN to support these choices.

OAH Docket No. 71-9003-36416 Name: Robert Secor

Zip Code: 55082

Comment:

I support Clean Cars Minnesota and have driven an EV for 10 years. Clean energy is here to stay and fossil fuels need to stay in the ground. The clean energy jobs sector is growing at a rapid pace, at this point clean energy is almost always cheaper than fossil fuels, and we can harness wind and solar energy right here at home in Minnesota. The time to save our climate is now and we can only do it if we fully embrace a home-grown clean energy economy that doesn’t harm our communities, air, lakes and forest. Clean Cars Minnesota is one piece of the puzzle that help Minnesotans transition to a zero emission future at a faster pace.

OAH Docket No. 71-9003-36416 Name: Mark Thieroff

Zip Code: 55108

Comment:

I strongly support the proposed rule because I believe Minnesotans should have access to a much broader range of electric vehicles. Our one-car family decided to purchase an EV in 2018 and in doing our related research we discovered that many of the models we might have been interested in could not be purchased in Minnesota. We ended up deciding that a plug-in hybrid was the best option for us and purchasing a Chevrolet Volt. We would have gone with a model with a longer electric range if one had been available in Minnesota.

OAH Docket No. 71-9003-36416 Name: Garry George

Zip Code: 55118

Comment:

OAH Docket No. 71-9003-36416 Name: Max Winter

Zip Code: 55114

Comment:

I am a supporter of the Clean Car Minnesota standard. We are running out of time to combat irreversible damage to the environment from climate change. In Minnesota the leading contributor to greenhouse gases (GHGs) is car pollution. We need to make buying electric vehicles easier and cheaper for Minnesotans to start transitioning away from internal combustion engine vehicles.

OAH Docket No. 71-9003-36416 Name: Michael Shoop

Zip Code: 55416

Comment:

I own 2 electric cars and it was not easy to find or buy either one. It should be as easy to buy an EV as it is to buy an SUV in Minnesota!

OAH Docket No. 71-9003-36416 Name: Steven C Dondlinger

Zip Code: 55436

Comment:

There is little time left to slow climate change. MN should be one of the leaders in supporting alternative energy and new jobs related to it.

OAH Docket No. 71-9003-36416 Name: Paul Norton

Zip Code: 55428

Comment:

OAH Docket No. 71-9003-36416 Name: Brian Hayes

Zip Code: 55076

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Dan Prince

Zip Code: 55408

Comment:

This is literally the least we can do for our kids' generation. Climate change is a problem we need to solve, and this is a start.

OAH Docket No. 71-9003-36416 Name: Dale Lutz

Zip Code:

Comment:

We are already 20 years too late in reducing our CO2 greenhouse gas emissions, as we can from the effects of climate change stronger and more frequent wildfires, droughts, and storms. Increasing the percentage of renewable energy on the electrical grid, combined with grid scale energy storage and infrastructure for electric vehicles, will decrease CO2 emissions from the burning of fossil fuels in both power plants and internal combustion engines.

OAH Docket No. 71-9003-36416 Name: Katie Griffin

Zip Code: 55416

Comment:

I’m a Minnesota EV owner and I support Clean Cars Minnesota. I have driven an electric car for 6 years. At first I was skeptical - it was my husbands idea - but it didn’t take long to recognize all the benefits of an electric vehicle. Even my young children appreciate and understand why we take the EV rather than the ICE vehicle as much as possible.

I have personally had challenges in buying an EV in Minnesota. We looked for our second vehicle to be an EV as well but have been frustrated with the lack of options and ability to see/try EVs at dealerships.

I support Clean Cars MN because:

Auto manufacturers are bringing dozens of new EV models to the US market before 2024, and I want to make sure that Minnesotans have access to all these options.

OAH Docket No. 71-9003-36416 Name: Bryan Vacinek

Zip Code: 55426

Comment:

I am an EV owner and want other Minnesotans to experience the joy of driving an EV.

I support Clean Cars Minnesota, it will put more EVs on the road and increase the demand for home-grown clean energy while boosting clean energy jobs.

OAH Docket No. 71-9003-36416 Name: Gene Marault

Zip Code: 55104

Comment:

I support Clean Cars Minnesota. Compared with traditional, gasoline-powered vehicles, electric vehicles can save us money through lower maintenance, operating, and fuel costs. And they're cleaner, which cuts down on health-related problems. And it's long past time we moved away from fossil fuels and transition to clean, local, renewable energy that doesn’t harm our lakes, forests, air, animals, and humans.

OAH Docket No. 71-9003-36416 Name: Charles Stephens

Zip Code: 55102

Comment:

I am voicing strong support for the Clean Cars MN rule making.

American ingenuity helped to bring automotive technology to the world.

Environmental damage from burning petroleum as automotive fuel is undeniable and mounting.

New electric ingenuity is solving this problem through vehicles that run on little or no fossil fuels and offer increasing flexibility for all kinds of applications.

Even with limited government support over the last 10 years, electric propulsion for cars and (soon) trucks has begun to take off in our country. It is beginning to eclipse traditional fossil fuel vehicles in other parts of the world already this year.

Current practices favor petroleum companies and the vehicles that depend on them.

Auto buyers (and dealers) with little or no exposure to these new vehicles fear the change they may bring, but that will not stop them coming.

Given local exposure, people quickly discover the economic and practical benefits that electric and other clean vehicles offer. Increased use and purchases will follow.

This rule encourages skeptical dealers to step into new territory so that they are not left out in the cold completely when the market shifts around them in the near future.

Please give us all the opportunity and pass the Clean Cars MN rule so that citizens in all parts of our state can see and experience these vehicles close to home.

OAH Docket No. 71-9003-36416 Name: Aaron Klemm

Zip Code: 55102

Comment:

I am a perfect EV candidate but the nearest car I want to buy is hundreds of miles away. I would have bought it by now if I could practically shop locally!

OAH Docket No. 71-9003-36416 Name: Charlie Hautman

Zip Code: 55352

Comment:

It is imperitive that we switch to electric cars to address climate change. When I was shopping for an EV it was very difficult to find a dealer that offered any. And when I did, the sales people didn't know anything about them. We must improve this situation so Minnesotans have the option to buy the cars they want.

Adopting clean car standards is a good step in the right direction.

OAH Docket No. 71-9003-36416 Name: Barb Patterson

Zip Code: 55424

Comment:

I am a Climate Justice advocate, and am delighted that Gov. Waltz is putting forward the Clean Cars Initiative. It is vital that the be more pathways for people to participate in reducing our carbon footprint. We should move away from our dependence on fossil fuels.

OAH Docket No. 71-9003-36416 Name: Lauren Lindelof

Zip Code: 55114

Comment:

I support Clean Cars Minnesota. I teach high school students and I believe their future is in our hands. We need to do everything we can right now to reduce carbon emissions and save our communities and environment. Clean Cars Minnesota is another step on Minnesota’s path to cutting climate change-causing greenhouse gas emissions and saving our state, country, and planet.

I teach inner city students and for the average household, They cannot afford electric vehicles. Electric vehicles can save people money because they have lower maintenance, operating, and fuel costs than a traditional gasoline-powered vehicle. However, both new and used electric vehicles are hard to track down here in Minnesota because they often go straight to states like Maryland and Oregon with clean car standards, leaving Minnesotans with few choices. Clean Cars Minnesota would bring more EVs to Minnesota's new and used car marketplace and drive down competition for specific makes and models in my price range and the families that I serve.

OAH Docket No. 71-9003-36416 Name: Mark Pellerite

Zip Code: 55144

Comment:

I care deeply about our environment, and I want to express my support for Clean Cars Minnesota. Climate change is the leading issue of our time, and it is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Transportation is the #1 source of climate change-causing pollution in our state and nationally, so we need to act now to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. The time to act is NOW.

Minnesota produces not a drop of oil, yet produces abundant electricity from clean wind and solar power that’s even cheaper than gasoline. Let’s harness the wind and the sun to power our vehicles with Minnesota-grown energy that’s clean to boot! Clean Cars Minnesota is a win for all. It will put more EVs on the road, increase the demand for home-grown clean energy, boost clean energy jobs, and help to eliminate our toxic dependence on petroleum.

Please help bring electric vehicles to Minnesota!!!

OAH Docket No. 71-9003-36416 Name: Kirk Payne

Zip Code: 55906

Comment:

I am a grandfather and want future generations to see that we did our best to respond to the climate crisis. I believe making our transportation system cleaner would be a major positive step in our overall response. The science and long term economics say this would be a smart thing to do.

OAH Docket No. 71-9003-36416 Name: Brad Snyder

Zip Code: 55369

Comment:

As a Science Teacher/Environmental Educator, Engineering/STEM Professional, and an Environmental/Renewable Energy/Human Health/Natural World Advocate, I wholeheartedly support Clean Cars Minnesota!!

They’re an established and credible way that states can work to clean up pollution from transportation! Fourteen other states and the District of Columbia have already adopted clean car standards!

Minnesota is in a toxic relationship with Big Oil and it’s time to cut ties!

We need to do everything we can to reduce Minnesota’s dependence on fossil fuels and transition to clean, local energy that doesn’t harm our lakes, forests, air, and people! With Clean Cars Minnesota more Minnesotans will transition to a zero emission or low emission vehicle when they buy or lease their next car or truck, and thus reduce our dependence upon fossil fuels!

Clean Cars Minnesota reduces pollution and gives customers more choice!! Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards!! Thanks!

OAH Docket No. 71-9003-36416 Name: Meggie LaValley

Zip Code: 55418

Comment:

I am tired of my baby breathing in dirty exhaust on our walks outside. Please help to make air cleaner by setting a clean cars standard. It is so important for our health and our future!

OAH Docket No. 71-9003-36416 Name: Gina Cooper

Zip Code: 56055

Comment:

I am an owner of 3 hybrids and they are great vehicles that need to be more readily accessible to all Minnesotans! This will help protect human health for generations! Let’s step up to the challenge of improving our carbon footprint for future generations.

OAH Docket No. 71-9003-36416 Name: Emily Kjesbo-Johnson

Zip Code: 55104

Comment:

I support Clean Cars Minnesota. Air pollution is a serious issue in our state and the health of Minnesotans hangs in the balance. Clean Cars Minnesota is a major step toward cleaning up our air. Communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionally harm Minnesota’s most vulnerable and marginalized communities.

OAH Docket No. 71-9003-36416 Name: Kate Crowley

Zip Code: 55795

Comment:

As someone who loves and appreciates Minnesota's quality of life and natural resources, I am worried about Climate Change and how it will impact all aspects of our life and health. We MUST reduce greenhouse emissions now before it's too late. I am glad that Governor Walz is on board for reducing emissions and moving us away from a fossil fuel future.

OAH Docket No. 71-9003-36416 Name: Thomas Thies

Zip Code: 55346

Comment:

I support "Clean Cars for Minnesota". I bought a used Chevy Volt six years ago. My six year average fuel economy is 155 MPG. The State of Minnesota should support better fuel economy standards for all cars and trucks. Yes, it's possible. Less oil means, less oil pipelines, less oil trains, less oil spills, less pollution, less foreign oil, and less stress on our military. I charge my car at night when the energy demand on the grid is low. I buy wind power from my utility. You can also subscribe to a solar garden or install solar panels on your property. My next car will be 100% electric. It would be great to have more EV choices in Minnesota. It's about time that we the people and our government step forward and take responsibility for the fuel and energy that we all use.

OAH Docket No. 71-9003-36416 Name: Nancy Cruise

Zip Code: 55121

Comment:

I had to have my EV shipped from California. There just weren't enough options available in Minnesota. More options for Minnesotans means the more likelihood that people will adopt cleaner options and protect our planet.

OAH Docket No. 71-9003-36416 Name: Giampaolo Malin

Zip Code: 55446

Comment:

I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s natural resources. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions.

I have recently purchased an electric vehicle and was surprised about how little choice I had. We need to do better and give Minnesotans more EV alternatives. Clean Cars Minnesota can help.

Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Minnesota needs to be the next state. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Stephen Roscoe

Zip Code:

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Jim Nehl

Zip Code: 55347

Comment:

OAH Docket No. 71-9003-36416 Name: Kevin Miller

Zip Code: 55417

Comment:

I’m a Scout Leader and I support Clean Cars Minnesota. Minnesota is a great place to be an Scout but climate change is threatening our way of life. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally, so we need to act NOW to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to slowing climate change and reducing greenhouse gas emissions from transportation. Let’s act now before all the changes we’re already seeing become permanent.

I have not yet had the opportunity to buy an electric vehicle due to my finances, but next time I buy a vehicle, I will buy electric. Because Minnesota does not have very impactful clean car standards, the models that are offered in Minnesota are very limited. My wife and I plan to have a family in the next few years and we will therefore need an affordable electric crossover SUV. By implementing these standards, you can enable us to follow our principles and buy an electric car that fits our life.

OAH Docket No. 71-9003-36416 Name: Jeffrey Kidder

Zip Code: 55103

Comment:

I support Clean Cars Minnesota. Cars and trucks on the roads are a major source of air pollution in our state. I live near a busy road and worry about the soot and ozone released from every car, truck, and bus that passes my home. This is especially harmful to the many children who live in our neighborhood and folks who have asthma and other health complications already. I understand that most people rely on a gas-powered vehicle of some kind to get around, but we have an opportunity in Minnesota to clean up our air with clean car standards. Clean Cars Minnesota would help reduce air pollution from transportation and make our state healthier.

OAH Docket No. 71-9003-36416 Name: John Suzukida

Zip Code: 55126

Comment:

MN needs to pass Clean Cars MN as soon as possible to combat global climate change right here at home. I'm an electric car, zero net energy practitioner and this kind of action is urgently crucial to securing our future. As the saying goes, "We don't inherit the world from our ancestors, we borrow it from our children"

OAH Docket No. 71-9003-36416 Name: Lily O'Hara-Brantner

Zip Code: 55417

Comment:

OAH Docket No. 71-9003-36416 Name: Kate Hanson

Zip Code: 55113

Comment:

In addition, Minnesota imports tons of gallons of oil annually while at the same time producing lots of electricity from clean sources from wind and power that’s even cheaper than gasoline – why? Let’s harness the wind and the sun to power our vehicles with Minnesota-grown energy that’s clean to boot! Clean Cars Minnesota is a win-win-win. It will put more EVs on the road, increase the demand for home-grown clean energy, and boost clean energy jobs.

OAH Docket No. 71-9003-36416 Name: Caroline O’Hara

Zip Code: 55057

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. We know that our transportation is a huge source of pollution and global warming. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota the first state in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Karl Forsberg

Zip Code: 55123

Comment:

Our State and Nation have no choice but to electrify the Transportation system in this county a one of the major steps needed to avoid the worst effects of climate change. These include but are not limited to irreversible global warming, food and water scarcity, poverty and death on a massive scale.

I own an electric car and find it the most trouble free and economical vehicle I have ever owned. I am concerned that many auto dealers are ignorant of the many EV models available and simply do not display them. The State needs to reverse this trend in the interest of our children's future.

OAH Docket No. 71-9003-36416 Name: Thomas Yung

Zip Code: 55904

Comment:

Electric vehicles (EVs) are good for the environment, and saves their owners money. I support any initiative to help make it easier for anyone to buy EVs in Minnesota (or anywhere for that matter).

OAH Docket No. 71-9003-36416 Name: Philip Nehl

Zip Code: 55014

Comment:

I support the mn clean car program. I would like more options for buying a ev.

OAH Docket No. 71-9003-36416 Name: Peggy Fisher Johaningsmeir

Zip Code: 55113

Comment:

We all deserve clean air. I want to do my part, and the state to do it with me.

OAH Docket No. 71-9003-36416 Name: Sonja Jasansky

Zip Code: 55345

Comment:

I’m a Minnesota EV owner and I support Clean Cars Minnesota. I have driven electric cars for 5 years, and would never switch back to a gas car.

I support Clean Cars MN because:

EVs don’t produce tailpipe emissions, so increasing EV adoption improves the air quality, especially in areas where vehicle traffic produces a lot of pollution.

EVs also use much less energy than ICE cars so the overall emissions are considerably lower, and they improve our trade balance since we don’t need to import so much oil.

Since EVs consume less energy, they are much cheaper to drive, and EVs have considerably lower maintenance costs so they are also much cheaper to own. Used EVs are the most affordable cars available.

Safety is important to me and IIHS test results clearly show that EVs are very safe.

EVs are great winter cars. They have emission free preheating functions and fast heating systems.

Home charging is the most convenient and affordable way to power driving. Public charging is valuable service, but I don’t use public charging very often, so the current

OAH Docket No. 71-9003-36416 public charging infrastructure works well for me. I also feel that confident that we will have more public charging infrastructure available in the future.

EVs reduce our dependency on imported oil so we can keep our dollars in Minnesota and don’t need to inhale the emissions caused by refining oil and burning gas.

Electric utilities are moving away from coal and adding clean renewable electricity production. EVs gets cleaner every day.

Auto manufacturers are bringing dozens of new EV models to the US market before 2024, and I want to make sure that Minnesotans have access to all these options.

I’m also happy with this rule making process since I understand that oil interests would be against efforts to increase EV adoption no matter what the process would be.

Since I drive an EV I’m happy to talk more about all these topics.

Those who oppose EVs don’t have experience in driving EVs.

OAH Docket No. 71-9003-36416 Name: Mary Woollen

Zip Code: 55410

Comment:

It is imperative that we move away from the outdated technology of combustion engines and QUICKLY change the means by which we drive. We need fully electric vehicles and carbon free energy to power them.

OAH Docket No. 71-9003-36416 Name: Gregory Pratt

Zip Code: 55406

Comment:

My life's work has been on air pollution. I know the damages it does to health and the environment. I am also keenly aware of the existential danger of climate change--it causes me great worry for my grandchildren's future. Our human species need to stop putting climate altering gases into the atmosphere ASAP. Clean cars are one important step towards addressing these issues. Please move forward!!!

OAH Docket No. 71-9003-36416 Name: Richard Pedtke

Zip Code:

Comment:

I’m a Minnesota EV owner and I support Clean Cars Minnesota. I have purchased 2 Tesla Model S since 2012 and this is the best car brand I have ever owned in my 72 years. I have driven these 2 electric cars for 8 years and over 100,000 miles. My daughter now has the first one I purchased and she has driven it about 50,000 miles. We, together, have a significant amount of experience to validate that this EV is very low cost to operate, reliable, safe and a joy to drive.

I support Clean Cars MN because:

EVs don’t produce tailpipe emissions, so increasing EV adoption improves the air quality, especially in areas where vehicle traffic produces a lot of pollution.

EVs also use much less energy than ICE cars so the overall emissions are considerably lower, and they improve our trade balance since we don’t need to import so much oil.

Since EVs consume less energy, they are much cheaper to drive, and EVs have considerably lower maintenance costs so they are also much cheaper to own. Used EVs are the most affordable cars available.

Safety is important to me and IIHS test results clearly show that EVs are very safe.

OAH Docket No. 71-9003-36416 EVs are great winter cars. They have emission free preheating functions and fast heating systems.

EVs reduce our dependency on imported oil so we can keep our dollars in Minnesota and don’t need to inhale the emissions caused by refining oil and burning gas.

Electric utilities are moving away from coal and adding clean renewable electricity production. EVs gets cleaner every day.

Auto manufacturers are bringing dozens of new EV models to the US market before 2024, and I want to make sure that Minnesotans have access to all these options.

I’m also happy with this rule making process since I understand that oil interests would be against efforts to increase EV adoption no matter what the process would be.

OAH Docket No. 71-9003-36416 Since I drive an EV I’m happy to talk more about all these topics.

Those who oppose EVs don’t have experience in driving EVs

OAH Docket No. 71-9003-36416 Name: Theresa Olsen

Zip Code: 55104

Comment:

As an architect I drive a plug-in car energized by my solar panels or back-up WindSource because I love Minnesota. I want to pass on Minnesota’s pristine natural beauty and changing seasons to future generations with clean energy and clean cars. The species with whom we share our planet depend on us getting off dirty fossil fuels. EVs work in MN. They are quiet and do not emit noxious tailpipe exhaust.

OAH Docket No. 71-9003-36416 Name: Linda Quammen

Zip Code: 55122

Comment:

As a Master Naturalist and volunteer for several county natural resources programs I care about our environment & support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, & air. Our winters are already warming faster than the national average & our northern boreal forests are disappearing. Cars & trucks on the roads are the lead source of pollution caused by climate change in Minnesota & nationally so Clean Cars Minnesota is a key piece of the puzzle to protect our environment. Reducing vehicle emissions will slow our climate change & reduce greenhouse gas emissions. We must act now before it’s too late.

OAH Docket No. 71-9003-36416 Name: Craig Laughlin

Zip Code: 56655

Comment:

I am 70 years old and live on a lake. The later ice over dates in recent years have resulted in much more frequent occasions of snow on the thinner ice pushing water up through the cracks in the ice and covering the lake with a layer of slush that lasts all winter. It just happened again with the recent snow, and it makes walking, snow shoeing, or cross country skiing on the lake unpleasant to impossible. I don't recall this ever happening in the 90s.

OAH Docket No. 71-9003-36416 Name: Diane Bublitz

Zip Code:

Comment:

OAH Docket No. 71-9003-36416 Name: Todd Reubold

Zip Code: 55105

Comment:

OAH Docket No. 71-9003-36416 Name: Emily Hansen

Zip Code: 55116

Comment:

I went shopping for an EV or hybrid about a year ago and was very disappointed in the options we have in Minnesota. I support this legislation to bring more choice to drivers in this state to allow us to reduce emissions for our health and the health of our environment.

OAH Docket No. 71-9003-36416 Name: Deborah Frishberg

Zip Code: 55116

Comment:

OAH Docket No. 71-9003-36416 Name: Robert Hoke

Zip Code: 55108

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Cody DeSmet

Zip Code: 55901

Comment:

OAH Docket No. 71-9003-36416 Name: Laurie Fenner

Zip Code: 55072

Comment:

OAH Docket No. 71-9003-36416 Name: Pat Pratt

Zip Code: 0

Comment:

I support Clean Cars Minnesota. Minnesota is in a toxic relationship with Big Oil and it’s time to cut ties. We need to do everything we can to reduce Minnesota’s dependence on fossil fuels and transition to clean, local energy that doesn’t harm our lakes, forests, air, and people. With Clean Cars Minnesota more Minnesotans will transition to a zero emission or low emission vehicle when they buy or lease their next car or truck, and thus reduce our dependence upon fossil fuels. There will be much opposition to this from our conservative members. Please carry on with trying to get our state off fossil fuels as much as possible. I support EV and any thing you can do to get there is much appreciated. thank you.

OAH Docket No. 71-9003-36416 Name: Joseph P. Cherra.

Zip Code: 55422

Comment:

I support Clean Cars Minnesota because of the damage to our environment from fossil fuels. This damage is coming to a head as MNDOT struggles to curb the increased use of road salt that is damaging our rivers, streams and lakes. Much is being said about the CO2 emitted by fossil fuels but the damage that the water they create and the need for salt to keep our roadways safe is being hushed. It's time to bring this fact to light, EACH GALLON OF FOSSIL FUEL GENERATES 1.03 GALLONS OF WATER WHICH REQURES 2.2 # OF ROAD SALT TO KEEP THE WATER FROM FREEZING AT 0 DEGREES F.

OAH Docket No. 71-9003-36416 Name: Jackie smolen

Zip Code: 55305

Comment:

We must act now to preserve the remaining resources we have. We must act now to enable more people to have access to vehicles that run off renewable energy. I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Gail Lewellan

Zip Code: 55118

Comment:

OAH Docket No. 71-9003-36416 Name: John Hanson

Zip Code: 55112

Comment:

I support Clean Cars Minnesota. Cars and trucks on the roads are a major source of air pollution in our state. I live near a busy road and worry about the soot and ozone released from every car, truck, and bus that passes my home. I understand that most people rely on a gas-powered vehicle of some kind to get around, but we have an opportunity in Minnesota to clean up our air with clean car standards. Clean Cars Minnesota would help reduce air pollution from transportation and make our state healthier.

OAH Docket No. 71-9003-36416 Name: Leo Klisch

Zip Code: 56374

Comment: lets just do it

OAH Docket No. 71-9003-36416 Name: Michael Arquin

Zip Code: 55105

Comment:

OAH Docket No. 71-9003-36416 Name: Drew Johnson

Zip Code: 55116

Comment:

OAH Docket No. 71-9003-36416 Name: David Peichel

Zip Code: 55409

Comment:

OAH Docket No. 71-9003-36416 Name: Dennis Lund

Zip Code: 55144

Comment:

I support Clean Cars Minnesota. For the average American household, transportation is the second largest expense after housing, but it doesn’t have to be that way! Electric vehicles can save people like me money because they have lower maintenance, operating, and fuel costs than a traditional gasoline-powered vehicle. However, both new and used electric vehicles are hard to track down here in Minnesota because they often go straight to states like Maryland and Oregon with clean car standards – and that’s just not fair. Clean Cars Minnesota would bring more EVs to Minnesota's new and used car marketplace and drive down competition for specific makes and models in my price range.

OAH Docket No. 71-9003-36416 Name: Elizabeth Johnson

Zip Code: 55120

Comment:

We need Clean Cars Minnesota to pass!!!

OAH Docket No. 71-9003-36416 Name: Jason Roys

Zip Code: 55407

Comment:

OAH Docket No. 71-9003-36416 Name: David Lates

Zip Code: 55109

Comment:

I’m a Minnesotan and outdoorsperson and I support Clean Cars Minnesota. Minnesota has an amazing parks system, rich natural resources, and a plethora ways to enjoy nature, but climate change is threatening all of this. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally, and we have a responsibility for the public good to take meaningful action to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to slowing climate change and reducing greenhouse gas emissions from transportation. Let’s act now before all the changes we’re already seeing become permanent.

OAH Docket No. 71-9003-36416 Name: Greg Johnson

Zip Code: 55047

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Patrick Byron

Zip Code: 55987

Comment:

I am an educator, tax payer, college instructor, grandparent, farm owner and supporter of the outdoors.

WE NEED clean air standards NOW..in the FUTURE and FOREVER to keep our economy moving, for the health of ALL of our citizens and to keep our planet a viable and LIVABLE entity.

This is LONG overdue and we MUST take action ASAP!!

OAH Docket No. 71-9003-36416 Name: Jean Buckley

Zip Code: 55406

Comment:

As a current EV owner I would like to encourage the state of MN to support the Clean Car standards to prioritize health, the environment and choice. Friends who have wanted to follow my lead struggle with the availability of purchasing EV’s in MN. I had to purchase my car from a dealer in WI. Minnesota should encourage dealers to provide options for consumers and assist in building the infrastructure to support charging. We should no longer be dependent on fossil fuels when car manufacturers are building cars that do not run on polluting resources. My grandchildren depend on us making policy changes that will allow for cleaner air to breathe. Thank you.

OAH Docket No. 71-9003-36416 Name: Kelsy Kuehn

Zip Code: 55105

Comment:

MN should be leading the way on divesting from fossil fuels. Solar panels, electric cars, and the iron range windmills are a start. We have a strong contingent of workers from every trade who could be makingvgg the long needed transition to renewable energy sources. Let’s lead the way. More renewable, more jobs.

OAH Docket No. 71-9003-36416 Name: Andrew Boucher

Zip Code: 55379

Comment:

I support Clean Cars MN because transportation is one of the largest sources of emissions and it's necessary for municipalities to lead the way in their communities by making the investment first.

OAH Docket No. 71-9003-36416 Name: Eric Enberg

Zip Code: 55810

Comment:

We started our business, Orion's Harvest Farm, earlier this year and purchased a used Nissan Leaf for deliveries because used EVs are very reasonably priced and have very low operating costs.

However, finding the vehicle was very inconvenient. No local car dealers offered them and so I took an airport van from Duluth to MSP airport, the light rail to downtown Minneapolis, and then two metro transit buses to get within walking distance of the only used EV dealer I could find in the state.

As our business is growing, we will need to buy another EV in the near future. I really don't want another, thoroughly inconvenient, shopping experience when I'm prepared to drop $40,000 on a vehicle. Our business needs this rule.

OAH Docket No. 71-9003-36416 Name: Barb Omarzu

Zip Code: 55626

Comment:

Clean air is just one of the reasons I am proud to be a citizen of Minnesota. Clean car standards are essential to keeping our air and water clean. We can set an example and do what is right for our world.

OAH Docket No. 71-9003-36416 Name: Noelle Eveland

Zip Code: 55350

Comment:

OAH Docket No. 71-9003-36416 Name: Patricia Ryan

Zip Code: 55122

Comment:

I believe in Clean Energy including driving EVs and PHEVs. However, they are generally not available in MN. I had to go to Iowa to buy my Honda Clarity. All the Honda dealers in MN said that Honda would not send them any!! Please pass laws that will increase the numbers of EVs and PHEVs available in MN.

OAH Docket No. 71-9003-36416 Name: Meghan Faricy

Zip Code: 55122

Comment:

We must do all we can to stop climate change, for our future and to stop the environmental injustices that climate change exacerbates.

OAH Docket No. 71-9003-36416 Name: pdon pinkham

Zip Code: 55033

Comment:

I’m a business owner and I support Clean Cars Minnesota.

Clean car standards are important to businesses like mine because they will serve as an economic and workforce engine for our state. Clean energy jobs will play a key role in our state’s post-COVID-19 economic recovery and my business depends upon a healthy and financially stable Minnesota workforce. Clean Cars Minnesota will keep our state on the right track to reduce our carbon footprint all while aligning with our business goals. also, Communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionally harm Minnesota’s most vulnerable and marginalized communities. also, Minnesota imports tons of gallons of oil annually while at the same time producing lots of electricity from clean sources from wind and power that’s even cheaper than gasoline – why? Let’s harness the wind and the sun to power our vehicles with Minnesota-grown energy that’s clean to boot! Clean Cars Minnesota is a win-win-win. It will put more EVs on the road, increase the demand for home-grown clean energy, and boost clean energy jobs.

OAH Docket No. 71-9003-36416 Name: Reid Haase

Zip Code: 55423

Comment:

I'd like to strongly support the Clean Cars Minnesota rule for several reasons. As we should 'follow the science', we know the current issues with climate change and the short time frame to make the differences we need to in order to course correct from our current reliance on fossil fuels that is negatively impacting us on many fronts. I personally have done much research and recently purchased a 2017 Chevy Bolt from a local dealership that was an 'off lease' CA vehicle. The availability and pricing of both new and used EVs will be positively impacted by requiring the incremental move to requiring increasing percentages of vehicle sales be zero-emission vehicles. By promoting sales of EVs, our market will develop to the point where purchasing and using an EV in the state of MN is the most sensible and affordable one along with the concurrent development of both public and private charging infrastructure. For both environmental and national security reasons, we need to cut our reliance on foreign sources of energy and moving this rule making forward will enable MN to assert these policy stances and combine our efforts with other states who have already done so, as well as taking a leadership position and demonstrate to states yet to consider these moves that MN desires to be at the forefront of positive environmental and economic changes.

OAH Docket No. 71-9003-36416 Name: Craig Rice

Zip Code: 55057

Comment:

I care about our environment and I support Clean Cars Minnesota. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally, so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Laine Crump

Zip Code: 55033

Comment:

OAH Docket No. 71-9003-36416 Name: Sam Schreiner

Zip Code: 55112

Comment:

I care about our environment and I support Clean Cars Minnesota. Climate change is threatening not only Minnesota’s forests, water, and air, but also many pillars of our economy in the decades to come. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Anissa Wenzel

Zip Code: 55110

Comment:

Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Kim Pollard

Zip Code: 55125

Comment:

OAH Docket No. 71-9003-36416 Name: Michael Kelbel

Zip Code: 55125

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which is a really wise decision considering the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Bjorn Gangeness

Zip Code: 55113

Comment:

I’m an EV owner and I support Clean Cars Minnesota. I have owned a battery-only electric vehicle since 2014 and have driven over 60,000 miles. Driving an electric vehicle in Minnesota is a freeing experience, and Clean Cars Minnesota will give more Minnesotans the opportunity to have the same great experience I have in owning electric vehicles!

OAH Docket No. 71-9003-36416 Name: Isabel Ricker

Zip Code: 55406

Comment:

I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

Secondly, clean cars Minnesota will have critically important benefits for public health and the economic stability of less wealthy families.

Air pollution is a serious issue in our state and the health of Minnesotans hangs in the balance. Clean Cars Minnesota is a major step toward cleaning up our air. Communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionally harm Minnesota’s most vulnerable and marginalized communities.

For the average American household, transportation is the second largest expense after housing, but it doesn’t have to be that way! Electric vehicles can save people like me money because they have lower maintenance, operating, and fuel costs than a traditional gasoline-powered vehicle. However, both new and used electric vehicles are hard to track down here in Minnesota because they often go straight to states like Maryland and Oregon with clean car standards – and that’s just not fair. Clean Cars Minnesota would bring more EVs to Minnesota's new and used car marketplace and drive down competition for specific makes and models in my price range.

OAH Docket No. 71-9003-36416 Name: Kevin Frankel

Zip Code: 55125

Comment:

OAH Docket No. 71-9003-36416 Name: Joan Frankel

Zip Code: 55125

Comment:

I am a parent, engineer, and outdoor enthusiast. I am extremely concerned about what is happening with climate change and believe it is the most important issue of our time. Automobiles account for 1/5 of emissions and we have the technology to change that! Recently, I had a Suburu dealer call me about purchasing another Suburu. I told him I love the all wheel drive in MN but the biggest problem was the gas mileage and I could not continue to purchase vehicles that were not addressing the problem of global climate change. I asked if an EV Suburu were available but he said only in certain markets like the east and west coast. Wow...this shocked me that they are not available in MN. When will MN start addressing this problem?

OAH Docket No. 71-9003-36416 Name: Natalie Bothwell

Zip Code: 55616

Comment:

We are concerned about the environment and car emissions. We purchased a Prius Prime and absolutely love it! We were averaging 92 mpg, but since we're no longer driving as far to work, we're averaging 118 mpg. It's amazing! Our state needs to promote higher fuel efficiency standards. The technology is there and we should all be using it so we can all breathe better and reduce our dependency on fossil fuels. Please advocate for higher standards to protect our environment, save citizens gas money, and create a cleaner Minnesota!

OAH Docket No. 71-9003-36416 Name: Elissa Frankel

Zip Code: 55125

Comment:

OAH Docket No. 71-9003-36416 Name: Sam Villella

Zip Code: 55449

Comment:

Minnesotans need more electric vehicle options- driving electric is superior- let’s get on with the transition before we torch the planet

OAH Docket No. 71-9003-36416 Name: Sophie Nikitas

Zip Code: 55405

Comment:

I was born and raised in New York City, but have made the Twin Cities my home for the last 10 years, and plan to stay for life. My main reason for choosing Minneapolis over New York is the access to more open, green space, and the better air quality that comes with it. Please help accelerate our future into a pollution-free one with making it easier for people to access and choose electric vehicles, as well as continuing to invest in pedestrian and bike infrastructure!

OAH Docket No. 71-9003-36416 Name: Priya Murria

Zip Code: 55102

Comment:

I am concerned about the effects of fossil fuels and emissions from automobiles on MN's environment and the health of Minnesotans.

OAH Docket No. 71-9003-36416 Name: Sean Sweetnam

Zip Code: 55407

Comment:

I support Clean Cars Minnesota. Clean energy is the future. At this point clean energy is almost always cheaper than fossil fuels. We can harness wind and solar energy right here at home in Minnesota. Large economies like California have already adopted these standards, and that will drive the market. We will need to adopt these initiatives sooner or later in order to participate in the national and international markets. By adopting them now, we will be better positioned in the future, and we can start making an impact on the environment sooner.

OAH Docket No. 71-9003-36416 Name: Richard K. Dahl

Zip Code: 55987

Comment:

I have been fortunate to have lived in Minnesota for over 37 years where I have appreciated its relatively clean air compared to Chicago where I grew up. I strongly support the Clean Cars Minnesota Statute that will help to reduce pollutants from car exhaust. I drive a hybrid and was happy to need only one gas fill-up after six months of driving it. A full EV would be even better.

OAH Docket No. 71-9003-36416 Name: Samantha Raney

Zip Code: 55413

Comment:

OAH Docket No. 71-9003-36416 Name: Marilynn Torkelson

Zip Code: 55347

Comment:

I support Clean Cars Minnesota. Cars and trucks on the roads are a major source of air pollution in our state. I live near a busy road and worry about the soot and ozone released from every car, truck, and bus that passes my home. I already suffer from asthma. I understand that most people rely on a gas-powered vehicle of some kind to get around, but we have an opportunity in Minnesota to clean up our air with clean car standards. Clean Cars Minnesota would help reduce air pollution from transportation and make our state healthier.

My husband and I wanted to buy an EV, but found the cars we were most interested in purchasing could only be found in California and a few other distant states. We decided to lease a vehicle (Chevy Volt) a plug-in hybrid, until we can purchase an EV.

Thank you in advance for helping to make this dream a reality.

OAH Docket No. 71-9003-36416 Name: Thomas Torkelson

Zip Code: 55347

Comment:

OAH Docket No. 71-9003-36416 Name: Patrick Collins

Zip Code: 55045

Comment:

I am a 60 year old man from rural Minnesota. I have grandchildren and children and worry about the world they will inherit from my generation. We need to reduce our carbon footprint and using electric cars is a great way to do that. We need more choices and more incentives and more options from car dealers. I went to look for a more efficient vehicle at a big dealership and asked about their electric cars and the salesman said "they had very little and those electric cars really aren't ready yet.... I would wait if I was you." I waited and then bought a used Prius.

We need clean cars, dealerships who want to sell them nd are educated and we need to do this now. Thanks for listening.

OAH Docket No. 71-9003-36416 Name: Thomas Valois

Zip Code: 55113

Comment:

I am a life-long Minnesotan who cares about our environment and I support Clean Cars Minnesota. Climate change is not just threatening Minnesota but our entire planet. MN winters are already warming faster than the national average, and our entire way of life is threatened. Cars and trucks on the roads are the #1 source CO2 in our state and nationally so we need to act to reduce these emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. I own two EV's. They are superior forms of transportation and yet there are so few choices in MN. Why not have enough models available so others can discover the joy of owning an EV. When I take urban walks and have to breath in the exhaust stream of a fossil fuel powered car, it's truly disgusting and SO avoidable. Reducing vehicle emissions will slow climate change and improve the quality of life in MN and everywhere!

OAH Docket No. 71-9003-36416 Name: Jane Popp Simpson

Zip Code: 55406

Comment:

OAH Docket No. 71-9003-36416 Name: Laura Hannah

Zip Code: 55407

Comment:

I support Clean Cars Minnesota! Communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are not only a step toward dismantling policies and other systemic barriers that disproportionately harm Minnesota’s most vulnerable and marginalized communities, but also an urgently needed step toward deep decarbonization of the transportation sector. The science is clear - act boldly!

OAH Docket No. 71-9003-36416 Name: Lynn Arnsdorf

Zip Code: 55330

Comment:

I want Minnesota to work for fossil-free fuels!!!

OAH Docket No. 71-9003-36416 Name: Christine Popowski

Zip Code: 55408

Comment:

Because transportation is the biggest polluter in this country we must transition to a clean car (EV) economy without mining the boundary waters.

OAH Docket No. 71-9003-36416 Name: Jim Hawkins

Zip Code: 55408

Comment:

I am an 83-year old grandfather. I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. I am working to increase the rate of carbon sequestration in our State Forests and to introduce natural forest approaches to achieve this. oAs you know, Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change- causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. We should be producing large biogas from animal and other wastes .The PUC must not forget hydrogen including hydrogen carriers like methanol as fuels for vehicles. Let’s act before it’s too late. Clean car rules should be inclusive of these fuels as well as electricity. Delivering these sources of fuel to the transportation sector must be prioritized as it is the best way to reduce carbon emissions at this time.

OAH Docket No. 71-9003-36416 Name: Bart Pedretti

Zip Code: 55947

Comment:

I've been an EV enthusiast for over a decade. I bought my first EV over 2 years ago and there is no looking back. I work in electric power generation as a mechanical/electrical engineering manager and see so much potential in EV adoption. The list is endless - less maintenance, cleaner air, reduced dependence on foreign oil, potential for energy storage to the bulk electric system.... Endless possibilities. The state of Minnesota should be taking a lead on making EV adoption easier for all residents. Some ways that this could be implemented would be for offer incentives to potential vehicle buyers, increasing charging options and availability, working with utilities to draft standards on home charging rates and equipment, working with multi-family dwellings, i.e. apartment complexes and landlords for EV charging, and advertising. We are at a point where the technology is there and the easier the state can make adoption, the smoother our transition will be away from our old ways of transportation and beyond.

OAH Docket No. 71-9003-36416 Name: Pat Schmieder

Zip Code: 55616

Comment:

I am a Minnesotan that cares about my health and that of all Minnesotans. Vehicle emissions negatively impact our health, and the reliance on cars that burn fossil fuels impact our health and the environment. I also understand how cleaning up our transportation sector is necessary to battle our climate crisis, especially as we move to more renewable energy in the electric sector. I am an EV owner and I know that they work great even in Northern Minnesota. I support Gov. Walz in the Clean Cars Initiative that is the right thing for all Minnesotans.

OAH Docket No. 71-9003-36416 Name: Christov Churchward

Zip Code: 55407

Comment:

OAH Docket No. 71-9003-36416 Name: Sally Dumm

Zip Code: 56426

Comment:

Climate change must be controlled, like in Finland, with Minnesotans ALL using Electric vehicles to protect our grandchildren from floods, fires and abnormal weather caused by climate change.

OAH Docket No. 71-9003-36416 Name: Greg Ruud

Zip Code: 55406

Comment: carbon clean cars should be manditory!!

OAH Docket No. 71-9003-36416 Name: Patric von Drashek

Zip Code: 55110

Comment:

We're late, but now we can actually do damage control. We only have one planet and Minnesota needs to contribute for our environment. I would like to live in a world with hope towards the future rather than dread.

OAH Docket No. 71-9003-36416 Name: DeeAnn Stenlund

Zip Code: 55113

Comment:

We need to do everything we can to reduce Minnesota’s dependence on fossil fuels and transition to clean, local energy that doesn’t harm our lakes, forests, air, and people. With Clean Cars Minnesota more Minnesotans will transition to a zero emission or low emission vehicle when they buy or lease their next car or truck, and thus reduce our dependence upon fossil fuels.

OAH Docket No. 71-9003-36416 Name: Kristine Amundson

Zip Code: 55407

Comment:

I’m a future EV owner and I support Clean Cars Minnesota. I currently drive my boyfriend’s EV all the time because Its both practical for getting around the city and good for the environment. I have fallen so in love with driving an EV, I’m saving up to buy my own and I want to ensure I have all the options available to me. Clean Cars Minnesota would give the 6 in 10 prospective car buyers in Minnesota who are interested in electric vehicles the opportunity to actually see and test drive a much wider variety of makes and models - many of which currently don’t even make it to our state because they go to states with clean cars standards.

OAH Docket No. 71-9003-36416 Name: Michael Walstrom

Zip Code: 55417

Comment:

Clean cars promotes wise resource use, safer cars, and renewable energy, in addition to being an economic benefit that removes a major use of petroleum products and production of CO2 in our state - jobs, prosperity and a healthier state result. We need to overcome the stasis of big oil and big auto, and drive big auto to see the economic benefit of clean cars.

OAH Docket No. 71-9003-36416 Name: Brian Shukla

Zip Code: 55119

Comment:

OAH Docket No. 71-9003-36416 Name: Scott Brownlee

Zip Code: 55105

Comment:

I support the new rule regarding the requirement for car dealerships to offer electric vehicles for sale. I recently had to go out of state to find a suitable EV to purchase. If we had even a few more choices (in addition to Tesla, the Leaf and Chevy Bolt) I can see this part of the market taking off quickly. Impact on the environment and the convenience of not having to go to the gas station were the two biggest factors for me. Never going back to an ICE! Thank you for your time.

OAH Docket No. 71-9003-36416 Name: Jeanette Torkelson

Zip Code: 55407

Comment:

OAH Docket No. 71-9003-36416 Name: Chris Simon

Zip Code: 55406

Comment:

I support Clean Cars Minnesota. Minnesota's long term use of fossil fuels as the main option for transportation is short sighted! The Minnesota leaders need to reduce Minnesota’s dependence on fossil fuels and transition to clean, local energy that doesn’t harm our lakes, forests, air, and people. With Clean Cars Minnesota more Minnesotans will transition to a zero emission or low emission vehicle when they buy or lease their next car or truck, and thus reduce our dependence upon fossil fuels. We ALL need to do what's within our power to make this happen.

OAH Docket No. 71-9003-36416 Name: Elaine Mayer

Zip Code: 55430

Comment:

The trend all over the nation is to make cars as carbon-free as possible. Minnesota needs to step up for the future of our fragile planet.

OAH Docket No. 71-9003-36416 Name: Eric Lundgren

Zip Code: 55438

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

Minnesota is in a toxic relationship with Big Oil and it’s time to cut ties. We need to do everything we can to reduce Minnesota’s dependence on fossil fuels and transition to clean, local energy that doesn’t harm our lakes, forests, air, and people. With Clean Cars Minnesota more Minnesotans will transition to a zero emission or low emission vehicle when they buy or lease their next car or truck, and thus reduce our dependence upon fossil fuels.

OAH Docket No. 71-9003-36416 Name: Leigh Onkka

Zip Code: 55407

Comment:

I’m a parent and owner of a 2016 zero-emission Nissan Leaf, and I support Clean Cars Minnesota. Cleaner cars mean cleaner air for my kids, along with other vulnerable folks like the elderly and those with preexisting conditions who are most affected by the harmful effects of vehicle emissions.

Clean Cars Minnesota will dramatically reduce these emissions and help protect my kids (and everyone else too!) when they’re waiting at the bus stop, walking in the neighborhood, or even just playing in the yard. Human health is at stake and the longer we wait, the more kids whose current and future health and wellbeing will be harmed by dirty vehicle emissions.

I also believe that all Minnesotans should have the option to choose a zero-emission vehicle when purchasing a new or used vehicle. Minnesotans deserve to be able to access to all the vehicles available in the U.S. marketplace when they’re deciding to buy or lease. Right now, many electric vehicles don’t even make it to Minnesota dealerships because they go straight to states like Maryland and Oregon with clean car standards - that’s just not fair. Minnesotans should be able to buy whichever car they want.

OAH Docket No. 71-9003-36416 Name: Wesley Sisson

Zip Code: 55803

Comment:

I urge the Minnesota pollution control agency to adopt the clean car rule in order to increase diversity in the Minnesota auto market.

It is important that Minnesota aligns itself with the clean car standards of the majority of the auto market. It is not only economically sufficient but it is beneficial for Minnesotans to have access to a larger market including electric vehicles. adopting these standards is crucial and combating climate change, addressing pollution concerns, and the carbon footprint of the transportation industry.

I would also recommend that manufacturers should be given more incentives than in the current rule to add more electric vehicles faster. The market was already poised to set these standards into place before the change in leader ship at the federal level. Manufacturers should not be given wiggle room to ease into these standards which should have been logically implemented years ago.

OAH Docket No. 71-9003-36416 Name: Al Onkka

Zip Code: 55407

Comment:

OAH Docket No. 71-9003-36416 Name: Dennis Bird

Zip Code: 55447

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards!

OAH Docket No. 71-9003-36416 Name: Daniel Wilson

Zip Code: 55419

Comment:

I'm proud that Minnesota has always been a leader in the Midwest on policies that improve our quality of life. From some of the first smoking restrictions to policies that are aimed at reducing our carbon emissions to zero. Becoming the next state to pass clean car standards just makes sense. Adoption of EVs will be so much faster if manufacturers are required to make them more available to Minnesotans. It will lead to cleaner air, better health and lower costs for consumers. I was reluctant to buy my first EV because of this lack of exposure to them. Now that I have one I'm so glad that I never have to stop at a gas station again, have my oil changed, or worry about someone stealing my catalytic convertor! Please pass the Clean Car Minnesota standards and keep Minnesota the leader in quality of life for the Midwest!

Best,

Daniel

OAH Docket No. 71-9003-36416 Name: Scott Firman

Zip Code: 55315

Comment:

OAH Docket No. 71-9003-36416 Name: Curt Firman

Zip Code: 55744

Comment:

OAH Docket No. 71-9003-36416 Name: Rebekah Morse

Zip Code: 55102

Comment:

OAH Docket No. 71-9003-36416 Name: Sherryl Livingston

Zip Code: 55108

Comment:

I care about protecting our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Jason Lindahl

Zip Code: 55129

Comment:

OAH Docket No. 71-9003-36416 Name: RJ Devick

Zip Code: 55311

Comment:

Electrifying the transportation system is crucial to mitigating climate change. I full support any efforts to increase the number of EV vehicles sold in MN.

OAH Docket No. 71-9003-36416 Name: Dan Pierpont

Zip Code: 55042

Comment:

I am a huge advocate for reducing fossil fuel dependency and creating change that will thwart climate change. We have put solar panels on our home and wish for MPCA to advance the Clean Cars Minnesota standards that will further help to move Minnesota in the right direction with other states like California.

OAH Docket No. 71-9003-36416 Name: Leah Robertson

Zip Code: 55407

Comment:

I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Clean Cars Minnesota will help protect our children (and everyone else). Additionally, for the average American household, transportation is the second largest expense after housing, but it doesn't have to be that way. Minnesotans deserve to be able to access to all the vehicles available in the U.S. marketplace. Now, many electric vehicles don’t even make it to Minnesota dealerships because they go straight to states like Maryland and Oregon with clean car standards. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment and health. Act now before it’s too late.

OAH Docket No. 71-9003-36416 Name: Rhona Wilson

Zip Code: 55108

Comment:

OAH Docket No. 71-9003-36416 Name: Kathleen Hauser

Zip Code: 55124

Comment:

OAH Docket No. 71-9003-36416 Name: Lydia McAnerney

Zip Code: 55414

Comment:

I’m a social justice advocate and see the critical intersections of health, the environment and climate change as they relate to the future of Minnesota’s many communities.

OAH Docket No. 71-9003-36416 Name: Cecilia Govrik

Zip Code: 55104

Comment:

Minnesota should be one of the leaders, not lagging behind - 14 other states and D.C. have adopted clean car standards. I support Clean Cars Minnesota because it will reduce pollution and give customers more choice. Make Minnesota the 15th state and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Charles Stephens

Zip Code: 55102

Comment:

We have owned hybrids since 2000 and EV's since 2017. What they say about once you drive an EV, you'll never go back (to gas or diesel) is really true for me. I strongly favor this Clean Cars Rule to allow more Minnesotans to have access to these cars at dealerships locally.

The Auto Dealers Assn arguments against this Rule sound so much like those voiced by the bar and restaurant associations before the smoking ban was put in place. And things seem to have worked out just fine for them, despite no smoking in bars.

The oil and gas industry likes to pit this as the government choosing favorites, which discounts the massive infusions of public money and policy favoritism given to that industry for decades. The EV revolution is coming along reasonably well in the US even without this Rule, but will be sped up significantly with the increased hands-on experience that people, especially outstate, will get by having vehicles available locally.

OAH Docket No. 71-9003-36416 Name: Jon Montgomery

Zip Code: 0

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new and I hope to be driving an electric powered vehicle here in the state soon. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Sara-Jane Wilson

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Robert Wilson

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Ethan Culver

Zip Code: 55414

Comment:

OAH Docket No. 71-9003-36416 Name: Doug Rohde

Zip Code: 55416

Comment:

Moving toward electric vehicles satisfies so many needs -- reducing pollution, reducing greenhouse gas emissions, economic stimulus, to name a few -- but this is a moonshot kind of project that needs all hands on deck including government funding and support. Car companies and dealers are simply not going to do this on their own. They need our help. Consumers, too, will need financial help making the transition. Let's be smarter as a society about who we help. We don't need to help the fossil fuel industry. They have benefited long enough from government subsidies and tax breaks (and inaction). It's time for them to give back, and it's time for the government to do whatever it takes to make it happen.

OAH Docket No. 71-9003-36416 Name: Joyce Jones Strait

Zip Code: 55126

Comment:

I already own a hybrid electric car and I enjoy driving it knowing that I am not polluting the environment and leaving our children having to clean up the pollution of the past. We need to normalize making better environmental decisions for the betterment of society and the planet. I look forward to a day when I have access to electric charging stations at work and I use zero gas while still working outside of my home.

Sincerely, Joyce Jones Strait

OAH Docket No. 71-9003-36416 Name: Andy Pomroy

Zip Code: 55406

Comment:

MN established greenhouse gas reduction goals over a decade ago, yet our state is not on track to achieve those reductions, largely due to state policy stagnating after 2007 and only seriously addressing the electric energy generation sector of our economy. Even if emissions dropped to zero in that sector, as some utilities are proposing, it is not enough to achieve the goals established by the legislature and the governor on a wide bipartisan basis. Action such as MPCA is proposing will spread the work across multiple sectors of our economy and spur industry to innovate, just as the energy sector has.

This policy is necessary to achieve previously passed state goals to reduce greenhouse gas emissions.

OAH Docket No. 71-9003-36416 Name: Amber Sausen

Zip Code: 55414

Comment:

Furthermore, buying a car or truck is a big decision with so many factors to consider. Minnesotans deserve to be able to access to all the vehicles available in the U.S. marketplace when they’re deciding to buy or lease. Right now, many electric vehicles don’t even make it to Minnesota dealerships because they go straight to states like Maryland and Oregon with clean car standards - that’s just not fair. Minnesotans should be able to buy whichever car they want.

OAH Docket No. 71-9003-36416 Name: Nissa Tupper

Zip Code: 55118

Comment:

I'm writing in support of Clean Cars Minnesota. This is an important opportunity for us to provide leadership and demonstrate the important connection between environmental health and human health.

I support this for many reasons, but above all, I’m a parent of two budding community leaders and I support Clean Cars Minnesota. Cleaner cars mean cleaner air for my kids, along with other vulnerable folks like the elderly and those with preexisting conditions who are most affected by the harmful effects of vehicle emissions. Clean Cars Minnesota will dramatically reduce these emissions and help protect my kids (and everyone else too!) when they’re waiting at the bus stop, walking in the neighborhood, or even just playing in the yard. Human health is at stake and the longer we wait, the more kids whose current and future health and wellbeing will be harmed by dirty vehicle emissions.

Thank you for leading by example and instituting Clean Cars MN.

OAH Docket No. 71-9003-36416 Name: Milo Oien-Rochat

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Matthew Floding

Zip Code: 27705

Comment:

I am retiring to my great state of Minnesota this coming summer. I support Clean Cars Minnesota. Clean energy is here to stay. The clean energy jobs sector is growing at a rapid pace, at this point clean energy is almost always cheaper than fossil fuels, and we can harness wind and solar energy right here at home in Minnesota. The time to save our climate is now and we can only do it if we fully embrace a home-grown clean energy economy that doesn’t harm our communities, air, lakes and forest. Clean Cars Minnesota helps Minnesotans transition to a zero emission futureat a faster pace.

OAH Docket No. 71-9003-36416 Name: Daniel Green

Zip Code: 55414

Comment:

OAH Docket No. 71-9003-36416 Name: Jeff Peterson

Zip Code: 55105

Comment:

Insupportable Clean Cars Minnesota. Scientific evidence strongly suggests human activity has accelerated climate change. Encouraging the use of electric vehicles is something we can act on to help reduce our damaging reliance on fossil fuels. Future generations will not forgive our inaction.

OAH Docket No. 71-9003-36416 Name: Milo Oien-Rochat

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Meleah Houseknecht

Zip Code: 55409

Comment:

In addition, I’m an EV owner and I support Clean Cars Minnesota. Driving an electric vehicle in Minnesota is a freeing experience. You can go from point A to point B without worrying about harmful tailpipe emissions and since EVs don’t have internal combustion engine they warm up much faster in the winter and have considerably lower maintenance costs. Clean Cars Minnesota would give the 6 in 10 prospective car buyers in Minnesota who are interested in electric vehicles the opportunity to actually see and test drive a much wider variety of makes and models - many of which currently don’t even make it to our state because they go to states with clean cars standards. Buying a car or truck is a big choice and Minnesotans deserve the chance to weigh all options.

OAH Docket No. 71-9003-36416 Name: Roxanne Richardson

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Christine Popowski

Zip Code:

Comment:

I am a progressive and believe now is the time to move ahead and make the big push for clean cars. Transportation is the biggest polluter of the environment and we must change that.

OAH Docket No. 71-9003-36416 Name: Pat Samples

Zip Code: 55429

Comment:

I want clear air for my grandchild, and also for each of us. It is the most basic of our needs. I know several people personally who suffer severe consequences from the pollutants already in our air now. I dread the thought of this becoming a widespread occurrence. Please be bold in keeping our air clear.

OAH Docket No. 71-9003-36416 Name: William Henke

Zip Code: 56501

Comment:

I most definitely support Clean Cars Minnesota. Buying a car or truck is a big decision with so many factors to consider. Minnesotans deserve to be able to access to all the vehicles available in the U.S. marketplace when they’re deciding to buy or lease. Right now, many electric vehicles don’t even make it to Minnesota dealerships because they go straight to states like Maryland and Oregon with clean car standards - that’s just not fair nor does it make sense.

Furthermore, not all Minnesotans want large gas guzzling SUV's or pick-up trucks. As we consider adopting the "Clean Car Standard" for our state, many of the large automotive manufacturers are busy introducing multiple lines of low and zero emission vehicles. For goodness sakes, even General Motors has made a commitment to produce thirty new global electric vehicles by 2025! Minnesotans should be able to buy whichever car they want. Otherwise, Minnesota is a risk of being left behind in not only vehicle purchase opportunity, but also the supportive infrastructure and jobs associated with making the conversion to these vehicles.

Lastly, with the fact that a large percentage of Minnesota's greenhouse gas emissions come from tailpipes, adopting the Clean Car Standards is the right thing to do. If I can help secure my children's future by being able to purchase a low emission or zero emission vehicle in the effort to fight climate change, I want to be on the right side of history. Thank you.

OAH Docket No. 71-9003-36416 Name: Barbara Crosby

Zip Code: 55415

Comment:

I strongly support the Clean Cars initiative because of the urgency to protect our natural environment. Mitigating climate change's harm is a priority to me as a grandparent and one who cherishes Minnesota's natural beauty.

OAH Docket No. 71-9003-36416 Name: Taylor Watts

Zip Code: 55379

Comment:

In order to find a used EV I had to spend money with Carvana instead of a local dealerships. There is little to no inventory here in Minnesota. We also need to step up our DC fast charge network. One DCFC every 100 miles outside of the metro is not enough.

OAH Docket No. 71-9003-36416 Name: Michael Mandsager

Zip Code: 55057

Comment:

We need to implement the Clean Car Rule, and do everything we can to fight climate change, so that we can have a livable world for ourselves and for future generations.

OAH Docket No. 71-9003-36416 Name: kirsten lincoln

Zip Code: 55902

Comment:

OAH Docket No. 71-9003-36416 Name: Marie Failinger

Zip Code: 55117

Comment:

How can we possibly ask our grandchildren to suffer the environmental damage that cars are wreaking on our planet, when we have the intelligence and financial ability to change that trajectory?

OAH Docket No. 71-9003-36416 Name: Bonnie Russ

Zip Code: 55113

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Rick King

Zip Code: 55108

Comment:

I’m worried about the health of Minnesotans and know that emissions from vehicles are hurting us, especially communities of color, under-resourced families, people with preexisting conditions, and children.

I support Clean Cars Minnesota. Air pollution is a serious issue in our state and the health of Minnesotans hangs in the balance. Clean Cars Minnesota is a major step toward cleaning up our air. Communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionately harm Minnesota’s most vulnerable and marginalized communities.

OAH Docket No. 71-9003-36416 Name: Mary-Fred Bausman-Watkins

Zip Code: 55105

Comment:

I am a happy owner of two electric cars. We chose this option to be emissions free and to make our impact for the climate. One of our cars is a hybrid - Chevrolet Volt because we don’t have enough state infrastructure to support EV’s for all of our car needs. I fully support a clean car rule as a Minnesotan. EV’s are affordable now and it is possible. It is a myth that we need to rely on fossil fuels. It is time to stand up for the climate.

OAH Docket No. 71-9003-36416 Name: Ken Behringer

Zip Code: 55337

Comment:

I find it troubling that most of the vehicle options I see when looking at a new vehicle are virtually unchanged from MPG and emissions numbers 20 years ago. This proposal will help forward systemic change and necessary improvements.

OAH Docket No. 71-9003-36416 Name: Deanna Thompson

Zip Code: 55116

Comment:

OAH Docket No. 71-9003-36416 Name: Gail Morrison

Zip Code: 55116

Comment:

OAH Docket No. 71-9003-36416 Name: Christina Spiker

Zip Code: 55021

Comment:

The federal government has been reversing the progress made on reducing air pollution in our country. If Washington won’t lead, Minnesota will and Governor Walz has shown strong leadership in pushing for innovative solutions to the climate crisis. Clean Cars Minnesota would keep Minnesota on the right track for slowing climate change and reducing air pollution.

OAH Docket No. 71-9003-36416 Name: Joy McDonald Coltvet

Zip Code: 55113

Comment:

OAH Docket No. 71-9003-36416 Name: Nancy Newman

Zip Code: 55105

Comment:

I am a physician and this is a social justice, health and moral issue.

OAH Docket No. 71-9003-36416 Name: Kristine Swartchick

Zip Code: 55428

Comment:

OAH Docket No. 71-9003-36416 Name: Patrick Gannon

Zip Code: 55906

Comment:

I am fully in support of clean cars! Hybrid or Electric---both types will cut emissions that are so damaging to our planet! We must pass legislation to require the shift to these low emission vehicles.

We can do this.

OAH Docket No. 71-9003-36416 Name: Connie Noterman

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Karilyn Alexander

Zip Code: 55406

Comment:

There’s no reason we can’t all drive Hybrids or electric vehicles.

OAH Docket No. 71-9003-36416 Name: Janell Draper

Zip Code: 55106

Comment:

I’m concerned that we don’t produce a drop of crude oil in our state, but we do produce clean electricity and it only makes sense to power more vehicles with Minnesota energy.

OAH Docket No. 71-9003-36416 Name: David Lick

Zip Code: 56081

Comment:

I am a clergyperson, a father, and a deeply concerned citizen. I support Clean Cars Minnesota because the kind of world my son will grow up in matters to me. It is also a pillar of the my religious faith that human beings are responsible for this world. Taking care of the world means guarding our natural resources and treating every bit of creation as a sacred space. Using clean cars will help us to live into our calling as human beings. We need to do what we can to protect this world. We are caretakers - not just takers. We must remember that and live it out.

OAH Docket No. 71-9003-36416 Name: Carol Shaffer

Zip Code: 55904

Comment:

OAH Docket No. 71-9003-36416 Name: janet Petri

Zip Code: 55057

Comment:

I support Clean Cars Minnesota. The Clean Cars policy will help protect our climate, which is changing fast. It will give us cleaner air; research tells us this will give us both tremendous health benefits, and impressive economic benefits from reduced ill health and reduced health care expenses. Communities of color and under- resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation.

It will also give us better cars! Electric vehicles need less maintenance, they last longer, and are cheaper to run. Now, almost all of the EVs go to the states that have already implemented the clean cars rule. We can’t get them in Minnesota!

I’m not from the Twin Cities metro area and I support Clean Cars Minnesota. Clean cars save money on fuel costs, and as someone who drives longer distances that means more savings for me. It’s hard to find the specific new or used car you want – especially if it's electric – when you’re shopping outside of the Twin Cities. In rural Minnesota, we have the least access to the full range of makes and models available in Minnesota and the U.S. Clean Cars Minnesota would change that by bringing more types of cars and trucks here, giving us more options to choose from.

With the Clean Cars rule, people who want to buy internal combustion vehicles would still be able to do so. And I, and the many people I know who are eager to get an EV, would be able to exercise our choice, too.

OAH Docket No. 71-9003-36416 Name: John Stoeckel

Zip Code: 55901

Comment:

I’m an outdoorsperson and I support Clean Cars Minnesota. Minnesota is a great place to be an outdoorsperson but climate change is threatening our way of life

OAH Docket No. 71-9003-36416 Name: Mary E Savina

Zip Code: 55057

Comment:

Climate change is threatening our way of life. I am an earth scientist and have seen the negative effects of human-induced climate change here in Minnesota: heavier rainfall, more floods and, ironically, more droughts. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally, so we need to act NOW to reduce greenhouse gas emissions before it’s too late. It is much easier to make the sources of electricity sustainable than it is to continue to burn oil, diesel and natural gas. Clean Cars Minnesota will move us in the direction of using more of these sustainable sources.

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards. States like Minnesota need to work separately and together to exert authority because the federal government has not been leading on these issues, and, in fact, has been actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

Over the last several years, business leaders, such as those lobbying against Clean Cars Minnesota, have been wildly off in their pessimistic estimates of the economic impact of clean energy technologies like wind and solar (now cheaper than most fossil fuels). Electric and hybrid cars are already making a difference all over the country; I think those economic pundits will be wrong again. Clean Cars Minnesota will keep Minnesota on the right track for slowing climate change and reducing air pollution. I

OAH Docket No. 71-9003-36416 Name: Heather Ferguson

Zip Code: 55419

Comment:

As a master's of social work student, I support the use of electric cars powered by locally- produced solar and wind electricity to create jobs in Minnesota and to protect our air and water.

OAH Docket No. 71-9003-36416 Name: Emily DeGrazia

Zip Code: 55902

Comment:

I have an EV and live outside the twin cities. The lack of infrastructure makes ownership of EVs very inconvenient. I made the investment in a used electric car. There are zero tax benefits to this, because it is not a new vehicle. If I want to come to the cities, there are very few high speed chargers and none on the highway 52 along the way. Often I find the high speed chargers in the downtown area are not maintained or functioning.leading to a bottleneck of people waiting at the one or two that work. I have ideals and principles, but they are so inconvenient that it is a huge barrier to market entry. Especially because in the winter(which we are trying to keep) cars lose charge at almost double the rate. I will keep driving my car- in my community. But I hope that part of the plans include infrastructure infrastructure to support this network of cars. Both used and new.

OAH Docket No. 71-9003-36416 Name: Chip Jenne

Zip Code: 55419

Comment:

We should be all-electric in our vehicles and machines ASAP. From lawn mowers to long haul trucks we’ve got to get off the crude oil standard. Minnesota should start by mandating all state fleet vehicles be electric . It should finish by legislating for the future with road tools that prepare for the electric autonomous vehicles of the future. Things like roundabouts - traffic circles - that AV tech navigates with ease and that keep traffic flowing best and safest. Things like reduced speed limits that will prepare for safe AV EV. Things like charging stations all over the state. Things like a tax on all of those small penis luxury pick-up trucks that men with soft hands drive. If your job isn’t working with your hands and breaking your back and knees for your family than you should pay a “soft hands tax” on your toy. Things like a gas tax whose revenue goes into subsidizing cheaper renewable fuels so that when we do have an all electric grid, that electricity should be cheap for the people. This bill isn’t about the Earth it’s about people. I couldn’t give a crap about this planet if there is no one left to appreciate it. What gives life meaning is humanity so if you make this bill clean make it clean for people.

OAH Docket No. 71-9003-36416 Name: Russell Mattson PE

Zip Code:

Comment:

Minnesota is one of 15 states which does not have a vehicle zero emission standard or initiative. Many states have been on board with vehicle zero emissions since 2013. The impact of not having a zero emission standard or goal is detrimental in many ways to Minnesota. Among them our our air quality, our health, CO2 emissions and but not least, the economy. With zero emission vehicles the source of the energy could be entirely within the state in lieu of supporting jobs and companies out of state.

The incentive in these other zero emissions states varies from tax rebates, credits and investments in infrastructure.

OAH Docket No. 71-9003-36416 Name: Christine Danielson

Zip Code: 55105

Comment:

OAH Docket No. 71-9003-36416 Name: Fred Morris

Zip Code: 55410

Comment:

I am an older Minnesotan who is an avid outdoors person and who cares very much about the world I will leave behind for my sons and their children. In my lifetime, most of the mistakes we have made have been from not being bold enough, not taking steps to meet what has obviously been the future. Clearly, the future for Minnesota and elsewhere must be centered on reducing green house gas emissions and turning back (if possible) the threat of global warming. Make no mistake, global warming is an existential threat, maybe moreso than anything else has been in my lifetime. I strongly support and encourage the adoption of Clean Cars Minnesota standards. We cannot kick the can down the road any longer.

OAH Docket No. 71-9003-36416 Name: Elaine Mayer

Zip Code: 55340

Comment:

For our health and the health of Earth, we need to move to safe and renewable resources. I'm happy that Governor Walz is supporting this environmental effort.

OAH Docket No. 71-9003-36416 Name: Jan Bauer

Zip Code: 55422

Comment:

I support clean energy, clean cars, reduced carbon

OAH Docket No. 71-9003-36416 Name: Anne Reich

Zip Code: 0

Comment:

We own an EV and love it. It doesn’t pollute the air (we purchase renewable, Minnesota- made clean electricity) and it $ave$ us money. EVs are a lot cheaper than most gas vehicles in the long run, due to lower fuel and maintenance costs. We were frustrated that when we went car shopping, our choice of EVs was severely limited in Minnesota -- since we are not (yet) a Clean Car state, EV car makers don’t sell many of their more desirable models here. By becoming a Clean Car state, Minnesota won't be left behind. Please promote freedom of choice, affordability, and clean air by supporting Clean Cars Minnesota - this is a win-win-win for individual Minnesotans, our state and our country!

OAH Docket No. 71-9003-36416 Name: Michelle Van Engen

Zip Code: 55406

Comment:

I support Clean Cars Minnesota because the transportation sector is the largest source of greenhouse gasses in Minnesota. Communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionately harm Minnesota’s most vulnerable and marginalized communities, and building an economy and environment that works for us all.

OAH Docket No. 71-9003-36416 Name: Carissa Lick

Zip Code: 56081

Comment:

As a millennial, as a parent (and teacher), and as a resident of rural Minnesota, I am enthusiastically in favor of Clean Cars Minnesota. This rule change is good for the environment, good for Minnesota industries, and good for future generations.

Clean energy is better than ever and is here to stay. The clean energy jobs sector is growing at a rapid pace, at this point clean energy is almost always cheaper than fossil fuels, and we can harness wind and solar energy right here at home in Minnesota. The time to save our climate is now. There is no reason to keep putting it off and risking further damage to our planet. But we can only do make this shift if we fully embrace a home-grown clean energy economy that doesn’t harm our communities, air, lakes and forest. Clean Cars Minnesota is one piece of the puzzle that will help Minnesotans transition to a zero emission future at the urgent pace that is needed. This will also help our own state's energy production! Minnesota imports tons of gallons of oil annually while at the same time producing lots of electricity from clean sources from wind and power that’s even cheaper than gasoline – why? Let’s harness the wind and the sun to power our vehicles with Minnesota-grown energy that’s clean to boot! Clean Cars Minnesota is a win-win-win. It will put more EVs on the road, increase the demand for home-grown clean energy, and boost clean energy jobs.

Writing as a young person and the mother of a young child, I believe the future is in our hands. We need to do everything we can right now to reduce carbon emissions and save our communities and environment. We can't afford to wait. Our children and grandchildren need this now.

Clean energy is also an equity issue. Communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionately harm Minnesota’s most vulnerable and marginalized communities. Minnesota is a great state to live in if you are white, but we have some of the worst racial disparities in the nation in

OAH Docket No. 71-9003-36416 other measures. It is absolutely essential that we fight systemic racial injustices on every front.

Clean Cars Minnesota is clearly the right choice. I am writing in favor of this rule change for the good of our state both now and in the future. Thank you.

OAH Docket No. 71-9003-36416 Name: Katherine Payne

Zip Code: 55906

Comment:

I support Gov. Walz in the move toward cleaner cars and air. We recently bought a new car and wanted an E-vehicle but we were told by THREE different dealers, “Just go to California, we only get one a year and there’s countless people on the list ahead of you.” Had I followed their advice, would that not have been a loss for our Minnesota businesses? We got a hybrid but wish it had been easier to secure the even better electric car. Help us do the right thing. Go green, Minnesota.

OAH Docket No. 71-9003-36416 Name: Lauren Lindelof

Zip Code: 55391

Comment:

I am a high school educator in St. Paul. I teach science. I would like the state to mandate more electric cars available in MN so that we can begin to transition to cleaner cities. I would also like to see more solar gardens that residents can subscribe to.

OAH Docket No. 71-9003-36416 Name: KAREN KINGSLEY

Zip Code: 55407

Comment:

I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. i want to drive an electric vehicle but the choices are so limited in Minnesota. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: David Leppik

Zip Code: 55416

Comment:

I am a battery electric car owner and, like 90% of EV owners, I have absolutely no desire to fill my garage with noxious car exhaust ever again. At some point I will need to replace my Nissan Leaf. Unfortunately, electric cars are hard to find in Minnesota, especially if I'm not looking for a Tesla.

There are lots of electric cars and SUVs being manufactured for the European and Chinese markets, but the few that make it to the US end up in California and other states with regulations similar to Minnesota's proposed rules. It is extremely burdensome to have to travel 2,000 miles to find, for example, an electric Kia. Also, although Kia offers a cold weather package in theory, good luck finding one if no cold weather states sell them.

Because it is so hard to get an EV right now, especially one that's suited for Minnesota winters, this will be a game changer both for Minnesotans and dealers. We're not the only ones who need to travel thousands of miles to find the car we want: it's a problem across the midwest. If Minnesota becomes the closest place that Wisconsin and Chicago car buyers can find the car they want, then this is where they'll need to come.

Dealers may tell you that they're not seeing demand for electric cars. That's simply because they're not looking. In a recent survey, 30% of consumers said they wanted their next car to be electric. When I was a kid, Minnesota became the first state in the country to require no-smoking sections in restaurants. Restaurants said it would kill their industry. If anything, Wisconsinites came here for fresh air. The same is true with electric cars: Minnesota needs to be a leader. It's good for the environment, good for consumers, and good for the economy.

OAH Docket No. 71-9003-36416 Name: Carolyn Wolski

Zip Code: 55102

Comment:

Someone recently said, "the pandemic will be but waves lapping at our feet compared to the tsunami of climate change." We need to get moving on better standards and better ways of living to keep our planet habitable and productive. Let's be leaders.

OAH Docket No. 71-9003-36416 Name: Jason Astleford

Zip Code:

Comment:

OAH Docket No. 71-9003-36416 Name: Mary Finley

Zip Code: 55105

Comment:

I care about the planet and increasingly worrisome and devastating global environmental crisis we all face. Any step to lower emissions is a positive step! Thanks!

OAH Docket No. 71-9003-36416 Name: Amy Blumenshine

Zip Code: 55407

Comment:

We all deserve to breathe. My urban neighborhood is plagued by vehicle emissions and noise, promoting worse health. This especially hurts the many children here and adults living with impairments. The urban haze is visible from a distance and I can smell and hear it nearly all the time. We've got to start taking our public health seriously. Additionally, petroleum use sucks finances unnecessarily from our state economy. And how bad does it have to get before we act with urgency and seriousness related to climate change? There is no question that humans are causing climate change and that we can change our behavior. We need to shift away from the internal combustion engine with its inherent problems to the better technology. Future generations are likely to curse us if we fail to act.

OAH Docket No. 71-9003-36416 Name: Susan Logan

Zip Code: 55047

Comment:

I think climate change is the greatest threat to our economy and way of life. I own an EV, love it, and think they are the wave of the future; everyone should have he opportunity to participate in this clean energy solution!

OAH Docket No. 71-9003-36416 Name: Kathryn Lien

Zip Code: 55110

Comment:

As I look towards buying a new car (I now own a 2007 Honda Civic) I want to have as many options as possible to own an electric vehicle. I have friends who drive them and love them. I want the infrastructure to support EVs in the state to be plentiful, reliable, and user-friendly. EVs are our future. What are we waiting for? I want to eliminate fossil fuel use for my grandchildren's health and the health of our natural resources. Clean air is good for health, business, and recreation. Let's do it!

OAH Docket No. 71-9003-36416 Name: Polly Andersen

Zip Code: 55391

Comment:

I support Clean Cars Minnesota. I want my state government to protect our natural resources so that they are available for the next seven generations. I can see that the time to act is now. We need everyone doing everything they can to help our economy transition to carbon neutral energy ASAP. I see the threat of climate change to our natural resources: animals, fish, forests, lakes, rivers, clean water to drink and clean air to breathe. I know that cars and trucks put more pollution in the air than anything else. Clean Cars Minnesota is a big and important piece of the solution to protect clean air for all Minnesotans. Clean Cars Minnesota will help to reduce vehicle emissions, slow climate change and reduce greenhouse gas emissions. Please, Minnesota Policy Makers: let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Nathan Lind

Zip Code: 55407

Comment:

I am a father, a Christian, and I believe in science. We must all act boldly, now, to curb greenhouse gases as much and as soon as possible, moving towards zero or negative carbon output as a state. We need bold Clean Car Rules that strongly encourage electric vehicles and the systems that support them. Now!

OAH Docket No. 71-9003-36416 Name: Frank Vogl

Zip Code: 55410

Comment:

I’m a grandparent and I support Clean Cars Minnesota. Cleaner cars mean cleaner air for my grandkids, along with other vulnerable folks like the elderly and those with preexisting conditions who are most affected by the harmful effects of vehicle emissions. Clean Cars Minnesota will dramatically reduce these emissions and help protect my kids (and everyone else too!) when they’re waiting at the bus stop, walking in the neighborhood, or even just playing in the yard. Human health is at stake and the longer we wait, the more kids whose current and future health and wellbeing will be harmed by dirty vehicle emissions.

OAH Docket No. 71-9003-36416 Name: Federico Rossi

Zip Code: 55424

Comment:

I'm a practicing physician in Minnesota and am worried sick about the clear impact climate change is having on my patients in a number of ways. I am also the father of three children and worry about the escalating impact that climate change is having on future generations. Please take this threat seriously and start taking meaningful actions including support Clean Cars Minnesota Rulemaking.

OAH Docket No. 71-9003-36416 Name: Carolyn Belle

Zip Code: 55414

Comment:

OAH Docket No. 71-9003-36416 Name: Christine Popowski

Zip Code: 55408

Comment:

As a concerned citizen who cares about peoples health and climate change EVs make so much sense.

OAH Docket No. 71-9003-36416 Name: Holly Fischer

Zip Code: 55057

Comment:

I love the woods and lakes and prairies and I support Clean Cars Minnesota. Minnesota is a great place to be an outdoorsperson but climate change is threatening our way of life. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally, so we need to act NOW to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to slowing climate change and reducing greenhouse gas emissions from transportation. Let’s act now before all the changes we’re already seeing become permanent.

OAH Docket No. 71-9003-36416 Name: Sandra Urgo

Zip Code: 55082

Comment:

I want to see a cleaner environment for my grandchildren!

OAH Docket No. 71-9003-36416 Name: Cheryl Arcand

Zip Code: 55128

Comment: https://fresh-energy.org/clean-cars-comment/I am committed to Social Justice, Health and a Clean Environment for my Grandchildren in their future. We need to be moving forward with more emergency now!

OAH Docket No. 71-9003-36416 Name: Mary Lou Logsdon

Zip Code: 55107

Comment:

OAH Docket No. 71-9003-36416 Name: Leota Goodney

Zip Code: 55057

Comment:

I am in favor of increasing access to electric cars because we need to move away from fossil fuels and toward renewable energy. Renewable energy results in cleaner air and less reliance on energy sources outside our state. Minnesota has an opportunity and obligation to lead in encouraging and supporting this transition and the clean car rule is a good first step.

OAH Docket No. 71-9003-36416 Name: James Jonza

Zip Code: 55042

Comment:

It is imperative that we get the Clean Cars Act passed. I wanted to buy and EV this summer, and it is nearly impossible compared to CA, WA, NY, etc. Not only can we drive down carbon dioxide emissions, but PM2.5 and VOCs will also be reduced, relieving people of asthma. I have found that the electricity costs you only about 1/3 the $ of gas, and EVs are quiet and very sporty to drive.

OAH Docket No. 71-9003-36416 Name: Julian Sellers

Zip Code: 55105

Comment:

I fully support Clean Cars Minnesota. For the survival of human culture we must stop burning fossil fuels as soon as possible. Therefor we must transition to electric vehicles as soon as possible. Clean Cars Minnesota is a small step that will help facilitate that transition by making more electric vehicles available for purchase in Minnesota.

OAH Docket No. 71-9003-36416 Name: Myron Drellack

Zip Code: 55068

Comment:

Looks like GM is going All Electric!!

OAH Docket No. 71-9003-36416 Name: Linnea Swenson Tellekson

Zip Code: 55419

Comment:

I’m a life-time Minnesotan, love the winter, and support Clean Cars Minnesota. Minnesota is a great place to be an outdoorsperson, but climate change is threatening our way of life.

I'm heart-broken by the slow and steady loss of dependable winter, especially good snow for cross-country skiing. Throughout my life, the winters have decreased in length and increased in temperature. I miss good blizzards and sub-zero days to kill the insects we don't want here. Repeated melting and freezing cycles create treacherous sideways and streets and horrible cross-country ski trails.

OAH Docket No. 71-9003-36416 Name: Beth Rahberg

Zip Code: 55106

Comment:

I am currently shopping for an EV.

OAH Docket No. 71-9003-36416 Name: Nowell Bjerkaas

Zip Code: 55960

Comment:

Hello,

I live outside the Twin Cities metro area and I support Clean Cars Minnesota. Clean cars save money on fuel costs, and as someone who drives longer distances that means more savings for me. But it’s hard to find the specific new or used car you want – especially if its electric – when you’re shopping outside of the Twin Cities. In rural Minnesota, we have the least access to the full range of EVs available elsewhere, and far fewer charging stations. Clean Cars Minnesota would change that by bringing more types of cars and trucks here - as automakers send new EV vehicles to states where emissions standards create demand - giving us more options to choose from.

OAH Docket No. 71-9003-36416 Name: Joe Foss

Zip Code: 55432

Comment:

I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Neal Lesmeister

Zip Code: 56425

Comment:

I have tried to buy a plug-in hybrid car in MN for 3 years and I was finally forced to drive to Connecticut in December 2020 to get one. I could not order one or afford to have one delivered so I drove for 4 days to get my Plug-in. I have extra solar on my house to charge it for free. Now I have a zero carbon footprint. Please pass laws so all Minnesotans can do this here at home and maybe become the hub for them in the midwest.

OAH Docket No. 71-9003-36416 Name: Leonardo Rapallini

Zip Code: 55424

Comment:

I have owned an electric car for more than 5 years and I have had the chance to charge it using only solar and wind power through the Renewable Connect program offered by Xcel Energy.

In these 5 years I have learned that an electric car not only is great for the environment, but also for your pocket as the overall cost of ownership is actually lower than most cars as electricity costs less than gas and basically there is zero maintenance. Last but not least, driving an EV is just super fun.

I really hope Clean Car will increase the choice at the dealerships. I had mixed experiences in the past. Often time I had to do my own research as dealers are not used to sell them and most of the models that are available in other states are not sold in Minnesota. If every consumer were educated about the benefits of driving an EV (environment and cost) and they actually had a good choice of a few models, the adoption of EVs would skyrocket.

OAH Docket No. 71-9003-36416 Name: Henrie Friesen

Zip Code: 55104

Comment:

OAH Docket No. 71-9003-36416 Name: David Gagne

Zip Code: 55406

Comment:

I support the expansion of electric car production and sales here in MN. I have serious heart problems that are worsened by car and truck emissions and pollution. Cleaner cars mean cleaner health for me, and a longer life. Plus I love fly fishing and hate to see the degradation of our streams and lakes from rising temperatures caused by climate change. Emissions from cars help worsen this climate change trajectory. Please do everything you can to expand the use of electric vehicles, both privately owned vehicles as well as government and agency vehicles, and reduce the number of polluting emissions from cars and trucks.

OAH Docket No. 71-9003-36416 Name: Ellen Palmer

Zip Code: 55406

Comment:

OAH Docket No. 71-9003-36416 Name: Dan Evans

Zip Code: 55110

Comment:

I am completely in favor of any policy that can build incentives to foster incentives to expand demand for clean cars, clean car production, and infrastructure that supports an increasing clean car market share. It is our responsibility to our children and future generations.

OAH Docket No. 71-9003-36416 Name: Sheila Evans

Zip Code: 55110

Comment:

OAH Docket No. 71-9003-36416 Name: Matthew Davis

Zip Code:

Comment:

OAH Docket No. 71-9003-36416 Name: Paul Volkert

Zip Code: 55442

Comment:

I support Clean Cars Minnesota because we need to start moving away from fossil fuels to combat climate change and give Minnesotans more choices in electric vehicles which will lead to more sales of electric vehicles resulting in lower greenhouse gas emissions.

OAH Docket No. 71-9003-36416 Name: Jill Janssen

Zip Code: 55417

Comment:

I strongly support adopting both parts of the Clean Cars Minnesota proposal, the Low Emission Vehicle (LEV) rules as well as the Zero Emission Vehicle (ZEV) rules. Adopting the ZEV mandate will improve consumer choice by increasing the number of electric and plug-in hybrid vehicles available to consumers in Minnesota. I would suggest adopting more stringent ZEV requirements than the proposed rule, the early-action credits and one-time credit allotment combined with a significant number of new EV models becoming available over the next few years, including many long range trucks and SUVs, will make more ambitious goals achievable.

OAH Docket No. 71-9003-36416 Name: Drew Johnson

Zip Code: 55116

Comment:

I support the Clean Cars rule because our family has tried to find EV options in Minnesota, and so many dealers do not stock nearly enough EV models. We have had to look outside the state. It is needlessly difficult to find EV's in Minnesota and this rule is necessary to give Minnesotans the full range of options when they go to dealers looking for EV's.

OAH Docket No. 71-9003-36416 Name: Kelly Billig

Zip Code: 55118

Comment:

OAH Docket No. 71-9003-36416 Name: Katie Jones

Zip Code: 55405

Comment:

I support Clean Cars Minnesota. Minnesota imports tons of gallons of oil annually while at the same time producing lots of electricity from clean sources from wind and power that’s even cheaper than gasoline – why? Let’s harness the wind and the sun to power our vehicles with Minnesota-grown energy that’s clean to boot! Clean Cars Minnesota is a win-win-win. It will put more EVs on the road, increase the demand for home-grown clean energy, and boost clean energy jobs. I also care about our environment. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Mary Tholkes

Zip Code: 55421

Comment:

Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Brian Webb

Zip Code: 55901

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Morgan Nordby

Zip Code: 55103

Comment:

I’m a Minnesotan who cares about our natural resources, and I know that reducing greenhouse gas emissions from cars and trucks is one way to combat climate change. I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Michael Lien

Zip Code: 55110

Comment:

OAH Docket No. 71-9003-36416 Name: Janelle London

Zip Code: 94025

Comment:

EVs will bring MN cleaner air. They will bring big $$ savings for MN drivers on fuel and maintenance, and will keep fuel $$ in the state with local electricity. EVs will avoid the motor oil and gasoline spills and drips that make road slick and pollute the waterways. MN drivers deserve to have a wide selection of EVs to choose from, at great prices -- which they will only get if MN joins the Clean Cars program. The switch is happening. Don't let MN get left behind.

OAH Docket No. 71-9003-36416 Name: Ann Manning

Zip Code: 55416

Comment:

I’m a renewable energy advocate, and I support a Clean Cars standard. Minnesota will never be an oil-producing state. However, we can produce a lot of clean, renewable wind and solar power. Clean Cars will make it easier for Minnesotans to drive electric vehicles, and these EVs can be charged with Minnesota made power! As we continue to clean up our electricity mix, more and more of our power can come from local sources. We can pay our local businesses and neighbors to fuel our cars instead of paying other countries or large multinational corporations. This is a huge economic opportunity for Minnesota that we can’t pass up. Another benefit: Minnesotans can reduce our climate pollution at the same time. Clean Cars is a win-win-win for all Minnesotans.

OAH Docket No. 71-9003-36416 Name: Nancy Nikora

Zip Code: 55416

Comment:

I am a senior citizen who has found it essential to be outdoors every possible day during the pandemic. Clean air is important to me; I was thrilled when the roads around the Chain of Lakes were closed to vehicles and their belching exhaust I’m a renewable energy advocate, and I support a Clean Cars standard. Minnesota will never be an oil- producing state. However, we can produce a lot of clean, renewable wind and solar power. Clean Cars will make it easier for Minnesotans to drive electric vehicles, and these EVs can be charged with Minnesota made power! As we continue to clean up our electricity mix, more and more of our power can come from local sources. We can pay our local businesses and neighbors to fuel our cars instead of paying other countries or large multinational corporations. This is a huge economic opportunity for Minnesota that we can’t pass up. Another benefit: Minnesotans can reduce our climate pollution at the same time. Clean Cars is a win-win-win for all Minnesotans.

OAH Docket No. 71-9003-36416 Name: Barbara Arney

Zip Code: 55410

Comment:

I'm concerned about health and the environment. Now is the time to act.

OAH Docket No. 71-9003-36416 Name: Karen Hawley

Zip Code: 55443

Comment:

OAH Docket No. 71-9003-36416 Name: Lois Egan

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Charlaine Tolkien

Zip Code:

Comment:

I am very committed to addressing climate change by going with renewable energy in Minnesota. I want my grandchildren to enjoy our natural environment. I own a hybrid vehicle and my next car will be electric. Please move forward with this.

OAH Docket No. 71-9003-36416 Name: Madeleine Henry

Zip Code: 55416

Comment:

The future of the planet is in our hands. Humankind has made big changes before—cars, electricity, etc. we can do it again! Renewable energy is the way to go

OAH Docket No. 71-9003-36416 Name: Russell Palma

Zip Code: 55416

Comment:

OAH Docket No. 71-9003-36416 Name: Beverly Caruso

Zip Code: 55416

Comment:

Please work to make the environment safe for my grandchildren.

OAH Docket No. 71-9003-36416 Name: Gene Tierney

Zip Code:

Comment:

Moving away from polluting gas powered cars will reduce damage to the environment as well as assure our economy stays up to date with renewable jobs. Win Win!

OAH Docket No. 71-9003-36416 Name: Jeff Hall

Zip Code:

Comment:

OAH Docket No. 71-9003-36416 Name: Stuart Sexton

Zip Code: 55105

Comment:

I’ve lived in Minnesota all my life and care deeply about this wonderful State. I also care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Christine Bonovsky

Zip Code: 55430-3156

Comment:

Minnesota is the most beautiful state in all the country, and has always been a leader in protecting the environment. It's time our state show true leadership by moving away from our dependence on fossil fuels and empower its citizens to do the same. The Clean Cars Act is a great way to do this because it gives average, everyday people more ability to buy eco-friendly vehicles. It will also make the air in dense, urban areas (like where I live) cleaner and healthier. Thank you for doing this!

OAH Docket No. 71-9003-36416 Name: Travis Bonovsky

Zip Code: 55430

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Susan Barry

Zip Code: 55106

Comment:

I support the adoption of this rule. I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change- causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Carrie Bakken

Zip Code: 55412

Comment:

Minnesota needs to take deliberate action to reach our climate goals. Higher emissions standards and more EV choices are one more step in reaching our goals. 14 other states already have passed it, and Minnesota could be the first in the Midwest.

OAH Docket No. 71-9003-36416 Name: Jim Nikora

Zip Code: 55416

Comment:

It is time to lead the way into the future. Fossil fuels are destructive and non-sustainable. Electric cars are the most viable alternative at the present. If we wait, there may be no future.

OAH Docket No. 71-9003-36416 Name: Zoe Bakken-Heck

Zip Code: 55949

Comment:

Not only that, but communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionately harm Minnesota’s most vulnerable and marginalized communities.

Beyond the health effects and climate change, buying a car or truck is a big decision with so many factors to consider. Minnesotans deserve to be able to access to all the vehicles available in the U.S. marketplace when they’re deciding to buy or lease. Right now, many electric vehicles don’t even make it to Minnesota dealerships because they go straight to states like Maryland and Oregon with clean car standards - that’s just not fair. Minnesotans should be able to buy whichever car they want.

OAH Docket No. 71-9003-36416 Name: Jane Cerhan

Zip Code: 55902

Comment:

We need to address climate change now!

OAH Docket No. 71-9003-36416 Name: Liesl Hargens

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Don Arnosti

Zip Code: 55105

Comment:

I live near busy roads. The soot and ozone released from every car, truck, and bus that passes my home causes an environmentally triggered asthma I suffer from. I understand that most people rely on a gas-powered vehicle of some kind to get around, but we have an opportunity in Minnesota to clean up our air with clean car standards.

I have two electric vehicles, myself, one of which I had to drive to Missouri to buy, because it was not available in Minnesota. Clean Cars rules would make it possible for more Minnesotans to conveniently buy electric cars and to experience their advantages in terms of reduced pollution and reduced operating costs.

OAH Docket No. 71-9003-36416 Name: Bruce Killam

Zip Code: 55445

Comment:

I’m a Minnesota EV owner and I support Clean Cars Minnesota.

I have driven electric cars for 1.5 years and over 18,000 miles.

I have personally had challenges in buying an EV in Minnesota.

I support Clean Cars MN because:

EVs don’t produce tailpipe emissions, so increasing EV adoption improves the air quality, especially in areas where vehicle traffic produces a lot of pollution.

EVs also use much less energy than ICE cars so the overall emissions are considerably lower, and they improve our trade balance since we don’t need to import so much oil.

Since EVs consume less energy, they are much cheaper to drive, and EVs have considerably lower maintenance costs so they are also much cheaper to own. Used EVs are the most affordable cars available.

In 2020, the average EV sold in Minnesota had over 250 miles of range, and when we have more choices everyone can find one that works for them. EVs are quieter and provide better performance, leading to a better driving experience.

Safety is important to me and IIHS test results clearly show that EVs are very safe.

EVs are great winter cars. They have emission free preheating functions and fast heating systems.

OAH Docket No. 71-9003-36416 Home charging is the most convenient and affordable way to power driving. Public charging is valuable service, but I don’t use public charging very often, so the current public charging infrastructure works well for me. I also feel that confident that we will have more public charging infrastructure available in the future.

EVs reduce our dependency on imported oil so we can keep our dollars in Minnesota and don’t need to inhale the emissions caused by refining oil and burning gas.

Electric utilities are moving away from coal and adding clean renewable electricity production. EVs gets cleaner every day.

Auto manufacturers are bringing dozens of new EV models to the US market before 2024, and I want to make sure that Minnesotans have access to all these options.

I’m also happy with this rule making process since I understand that oil interests would be against efforts to increase EV adoption no matter what the process would be.

Since I drive an EV I’m happy to talk more about all these topics.

OAH Docket No. 71-9003-36416 Name: Dan Brandt

Zip Code: 55416

Comment:

OAH Docket No. 71-9003-36416 Name: Mike Brooks

Zip Code: 55060

Comment:

I have six grandchildren and am committed to provide their generation the best possible natural environment. I am very concerned about the proven consequences of Greenhouse Gases in the atmosphere and the resultant existing Climate Catastrophe. My wife and I have owned a plug-in hybrid electric vehicle (Chevy Volt) for almost seven years and a battery electric vehicle (Chevy Bolt) for two and a half years. We love our electric vehicles and will never buy anything else. I fully support Clean Cars Minnesota and implore approval of the Clean Cars Minnesota rule.

OAH Docket No. 71-9003-36416 Name: Greg Johnson

Zip Code: 55047

Comment:

OAH Docket No. 71-9003-36416 Name: Chad Nelson

Zip Code: 56232

Comment:

We are an agriculture state with many ethanol plants and we can have clean by using this. What do california air and Mn air quality have in common?

OAH Docket No. 71-9003-36416 Name: Jeff Jeremiason

Zip Code: 56082

Comment:

We must move quickly to preserve Minnesota's natural heritage. Electric vehicles are the future.

OAH Docket No. 71-9003-36416 Name: Samuel Liberman

Zip Code: 55949

Comment:

OAH Docket No. 71-9003-36416 Name: Joe Gavin-Ballanger

Zip Code: 55315

Comment:

OAH Docket No. 71-9003-36416 Name: Amy Bakken

Zip Code: 55412

Comment:

Hi family!

Hoping I can compel you to take 3 minutes and send comments to the MPCA in the next few weeks in support of clean cars rulemaking, aka Clean Cars Minnesota.

Go here, copy-paste, and you’re pretty much done: https://fresh-energy.org/clean-cars- comment/

Clean Cars rulemaking is hugely important for reaching our climate goals but also hugely controversial in Minnesota. The auto dealers association has sued the MPCA over it, and the commissioner of the MPCA might get fired over it, all because some people think it’s a good idea to have slightly stricter vehicle emissions standards and more choices in electric vehicles (yep, that’s all the rule does). 14 other states already have passed it, but Minnesota would be the first in the Midwest.

OAH Docket No. 71-9003-36416 Name: Tyana Loiselle

Zip Code: 55949

Comment:

OAH Docket No. 71-9003-36416 Name: Mason Keel

Zip Code: 55949

Comment:

OAH Docket No. 71-9003-36416 Name: Kira Church

Zip Code: 55949

Comment:

OAH Docket No. 71-9003-36416 Name: Jill Grime

Zip Code: 55949

Comment:

OAH Docket No. 71-9003-36416 Name: Jonathon Solt

Zip Code: 55949

Comment:

OAH Docket No. 71-9003-36416 Name: James Lundy

Zip Code: 55108

Comment:

I care about our environment and I support Clean Cars Minnesota. In my 35-year career as a state government scientist, I worked on projects to maintain and improve the quality of Minnesota's ground water and drinking water. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests--an iconic image in the mindset of many Minnesotans-- are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally, so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Kira Pollack

Zip Code: 55104

Comment:

I work in the natural resource field and I support Clean Cars Minnesota. Minnesota is a great place to be outdoors but climate change is threatening our the lives of people and planet. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally, so we need to act NOW to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to slowing climate change and reducing greenhouse gas emissions from transportation. Let’s act now before all the changes we’re already seeing become permanent.

OAH Docket No. 71-9003-36416 Name: Louisa Mullin

Zip Code: 55949

Comment:

This is urgent and so time sensitive!!! At this point we need to do everything we can to reverse the damage we have already done to our earth and minority communities in it!

OAH Docket No. 71-9003-36416 Name: Robert Scheierl

Zip Code: 55744

Comment:

We must keep pushing for cleaner air and lower fossil fuel use. Electric cars show much promise but must be encouraged their sale because dealer economic incentives favor higher maintenance of fossil fuel vehicles over all electric vehicles.

OAH Docket No. 71-9003-36416 Name: Susan Anderson

Zip Code: 55442

Comment:

OAH Docket No. 71-9003-36416 Name: Donald Vasatka II

Zip Code: 55122

Comment:

My morning commute gives me a beautiful vista of Mpls. and St. Paul. Too many days in the summer my view of the Cities is obscured by a brown haze. Much of this is from transportation. I know this pollution is slowly damaging my family's health even when I can't see it. I want to be part of the solution to this problem. Purchasing a car or truck is a big decision with so many factors to consider. One of which is the pollution it creates. There are very few clean electric vehicles available for sale in Minnesota. In fact, at many dealerships, sales staff look like "deer in the headlights" when you ask about purchasing an electric vehicle. They have no product to sell and no knowledge what is available from their manufacture. We deserve access to all the vehicles available in the U.S. marketplace when deciding to buy or lease. Right now, too many electric vehicles don’t make it to Minnesota dealerships because they go straight to states with clean car standards. I know of one sale auto dealers could make today if they were willing to sell all models their manufacture makes. Minnesotans should have choice. I support Clean Cars Minnesota.

OAH Docket No. 71-9003-36416 Name: Deborah James

Zip Code: 55305

Comment:

I am writing in support of the Minnesota Clean Cars Rule. I am a 63 year-old registered nurse and resident of Minnetonka who, until the pandemic hit, spent a lot of time driving Twin Cities freeways visiting low-income, elderly patients in their homes. I drove a Prius until a year ago when a Dodge RAM rear-ended on the way to see a patient, and I ended up without a vehicle. When I went looking for a new car – and by this time I was open to considering an electric vehicle – I found few EV options. Since then, I have learned that only 19 of the 43 available EV models are available in Minnesota. There were virtually no used EVs for sale a year ago. I was fortunate to find a 2017 Chevy Volt that is serving me well. Its range of about 50 miles on a charge allows me to do nearly all of my day to day driving without any tailpipe emissions.

The fact that Minnesota has fallen far short of its goal of a 15% reduction in emissions by 2015 should be alarming to us all. Transportation, particularly from passenger vehicles, is the number one source of greenhouse gases in our state. I am a native Minnesotan, and I am concerned about how climate change is affecting our state. Our winters are warming - fast. While we do not yet experience the prolonged periods of heat and drought in the summer that are affecting other parts of the country, it is expected that we will by mid-century. Small, cautious, incremental steps are no longer an option. Our changing climate is affecting everything from agriculture to tourism.

The fact that automobile dealerships will need to adjust their business models should not matter. They are on the wrong side of this debate. It is time for automobile dealers to embrace zero-emission vehicles and make more of them available to Minnesotans who are interested in making the switch. Training their workforce to talk about and promote ZEVs will help drive up interest and demand. Car buyers need to see ZEVs on showroom floors and begin to learn how investing in a ZEV can actually save money in fuel and maintenance over the life of the vehicle, despite the higher upfront cost. It’s the right thing to do for the environment, and it’s the right thing to do for Minnesota consumers.

OAH Docket No. 71-9003-36416 I also support the early action credit so the process can begin moving as soon as possible. Our climate cannot wait an extra year.

OAH Docket No. 71-9003-36416 Name: Dave Anderson

Zip Code: 55442

Comment:

If it isn't obvious already, our climate is on the brink of no return. Clean renewable energy and sustainable living is our only hope moving forward.

OAH Docket No. 71-9003-36416 Name: Carter Anderson

Zip Code: 55442

Comment:

OAH Docket No. 71-9003-36416 Name: Daniel Prince

Zip Code: 55408

Comment:

Clean Cars is a modest measure that will help us lower greenhouse gas emissions - please support it!

OAH Docket No. 71-9003-36416 Name: Richard Newmark

Zip Code: 55125

Comment:

The increased carbon in the atmosphere is destroying most of the ski and snowmobile seasons in MN. As the oceans rise, much of Florida and the Gulf coast will go unde water. We don't want millions of people migrating north impacting our quality of life in MN.

OAH Docket No. 71-9003-36416 Name: Mary Adair

Zip Code: 55416

Comment:

I support the clean car rule. We need to be done with reliance on fossil fuels. I want my children and grandchildren to have clean air to breathe. I also would like to get an EV! Thank you!

OAH Docket No. 71-9003-36416 Name: Elle Barrett

Zip Code: 55108

Comment:

OAH Docket No. 71-9003-36416 Name: Bill Dow

Zip Code: 55418

Comment:

I’m an outdoorsperson and I support Clean Cars Minnesota. I want my next car to an EV, and we need to have more EVs available in Minnesota.

OAH Docket No. 71-9003-36416 Name: Nancy Jacobson

Zip Code: 55112

Comment:

I've gone to the auto dealer and was told there are no EV car available here! How can this be? We need EV cars available now. Thank you

OAH Docket No. 71-9003-36416 Name: Kathleen Laughlin

Zip Code: 55454

Comment:

In addition, communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionately harm Minnesota’s most vulnerable and marginalized communities.

Further, we'll spend less, and stop using up fossil fuels in the ground. For the average American household, transportation is the second largest expense after housing, but it doesn’t have to be that way! Electric vehicles can save people like me money because they have lower maintenance, operating, and fuel costs than a traditional gasoline- powered vehicle. However, both new and used electric vehicles are hard to track down here in Minnesota because they often go straight to states like Maryland and Oregon with clean car standards – and that’s just not fair. Clean Cars Minnesota would bring more EVs to Minnesota's new and used car marketplace and drive down competition for specific makes and models in my price range.

I am so glad I can see some initiative in this most obvious direction! - Kathleen

OAH Docket No. 71-9003-36416 Name: Paul Gardner

Zip Code: 55126

Comment:

I support Clean Cars very strongly for the following reasons:

1. My wife drives a 2019 Chevy Bolt and we love it. I have an internal combustion engine (ICE) vehicle and when I buy a new vehicle it will be electric. I've driven the Bolt from Minnesota to Maryland and back without any trouble. Fast chargers are plentiful along the route. We have a level 2 home charger. A recent survey showed that 96% of electric vehicle owners will NEVER go back to an ICE vehicle. I am one of them.

2. The MPCA has used the VW settlement money to make grants to install fast chargers along major transportation routes in Greater Minnesota. By the time the Clean Cars rule goes into effect, we will have a comprehensive network of DC fast chargers all around the state.

3. The quality and variety of EV models improves every year. Before the rule takes effect, Ford will introduce the F-150 electric pickup. The F-150 is the best selling vehicle in the United States. More pickups are hitting the market this year! Even before the rule takes effect, Minnesotans will be clamoring for EVs of all types, including pickups in Greater Minnesota.

Thank you for your consideration.

Paul Gardner

Shoreview, Minnesota

OAH Docket No. 71-9003-36416 Name: Theresa Olsen

Zip Code: 55104

Comment:

As an architect, we have the technology. I drive my EV powered by my PV. Dinosaurs are an old fuel. Electric, especially solar, is more current.

OAH Docket No. 71-9003-36416 Name: Jeff Disch

Zip Code: 55117

Comment:

Minnesotans deserve to have a choice in picking a vehicle. EV cars and trucks can help us live in a cleaner world. I support CleanCarsMinnesota

OAH Docket No. 71-9003-36416 Name: Kurt Klussendorf

Zip Code: 55116

Comment:

We need to do more to make EVs available to Minnesotans. We need more models and more availability. Many models I'd like to see are not available in the state (Kia Niro EV, etc.). They are clean, efficient, economical and we need to start replacing our ICE "fleet" with transportation that can improve sustainability.

OAH Docket No. 71-9003-36416 Name: Jo Holub

Zip Code: 55425

Comment:

OAH Docket No. 71-9003-36416 Name: Curt Carlson

Zip Code:

Comment:

I am an EV owner. I drove a Prius plug-in (PHEV) for four years. I then stepped up to a Chevy Volt and got a much better range on battery. I have owned it for the last four years. I am making the switch this year to an all electric. My choices are very limited and Clean Cars Minnesota would have helped this year if it was out there. Many of my friends would like to pursue EVs but are limited by that lack of choice. I also am a Grandfather and know that my Grand kids future is important. Climate Change will damage their future and we all need to do what we can to protect that future.

OAH Docket No. 71-9003-36416 Name: Amelia Dewberry

Zip Code: 55347

Comment:

OAH Docket No. 71-9003-36416 Name: Rylee Brazil

Zip Code: 55347

Comment:

I am a high school student and watching the effects of global warming on animals, the environment, and the human race is incredibly scary. I don't feel like it's ethical having kids and bringing a future generation into the world because I wouldn't want them to grow up facing the traumas of climate change like I have.

OAH Docket No. 71-9003-36416 Name: Christina Spicher

Zip Code: 55347

Comment:

We need to take bold action against the current climate crisis.

OAH Docket No. 71-9003-36416 Name: Matt Christian

Zip Code: 55404

Comment:

OAH Docket No. 71-9003-36416 Name: Sharon Knuth

Zip Code: 55437

Comment:

I believe we need to do what we can to reduce the amount of carbon in the atmosphere. EV's are the future and Minnesotans should be able to have access to that market.

OAH Docket No. 71-9003-36416 Name: David Rudolph

Zip Code: 55104

Comment:

I am a brand new Electric Vehicle owner and would like to make the process of buying a new car easier for others. I believe the Clean Cars Minnesota initiative would give Minnesota residents more choice and make the buying process easier and more affordable for a larger number of people. I actually ended up buying my vehicle out of state because there was more choice and it was less expensive than buying from a Minnesota dealer. We are missing out on more opportunities like this to keep revenue in the state if we do not act.

And besides that, it's just the right thing to do. Climate change is threatening Minnesota’s beautiful outdoors. Our weather is becoming unpredictable and the climate is warming faster than the national average, and our northern boreal forests are at risk of disappearing. Vehicles are the #1 source of climate change-causing pollution in our state so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a critical step in helping to protect our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Please act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Scott Berger

Zip Code: 55104

Comment:

I support adopting the clean car rules in Minnesota. Tailpipe emissions are hazardous and unpleasant. Now they're also avoidable. EVs are not a mature technology that simply needs encouragement to thrive in Minnesota. I am an EV owner and driver, and while I believe bike/walk/transit are the real solution to our emissions problem, clean cars are a step in the right direction. Other states and countries have shown that this is not only possible but beneficial. I enjoy charging off-peak in order to avoid stress to grid and to drive for very little money. I hope Minnesota is able to adopt these standards and join the future!

OAH Docket No. 71-9003-36416 Name: Janeen McAllister

Zip Code: 55118

Comment:

I own a hybrid car because I want to do as much as I can to reduce greenhouse gas emissions in our state. My next car will be all-electric. I want Minnesota to pass legislation to encourage the purchase of clean cars, and reduce greenhouse gas emissions.

OAH Docket No. 71-9003-36416 Name: Michael Stoick

Zip Code: 55118

Comment:

I support Clean Cars Minnesota because I have been trying to find an all electric family car for over 2 years and even though there are some great options in other states and countries- none are available for sale in Minnesota. Cleaner cars mean cleaner air for myself and my neighbors. I love gardening, running, biking, and playing with my kids in outside in my neighborhood but worry about how the air pollution coming from all the cars and trucks diving on major highways a few blocks away are affecting my families health. Science clearly shows that car pollution harms our lungs and hearts, especially when breathed in regularly and that communities of color and low-income communities bear the brunt of the negative health impacts from air pollution. Clean Cars Minnesota would dramatically reduce these emissions and help protect me and everyone in my neighborhood.

I support Clean Cars Minnesota because air pollution from cars, trucks, and buses negatively affects teachers and students, poisons soil, and might even affect the food produced from my backyard gardens and other urban gardens in our community. I support Governor Walz and his strong leadership in pushing for innovative solutions to keep Minnesota on the right track for slowing climate change and reducing food, water, air pollution.

OAH Docket No. 71-9003-36416 Name: David Peacock

Zip Code: 55116

Comment:

Please support clean air initiatives. Our great grandchildren will thank us.

OAH Docket No. 71-9003-36416 Name: Dennis Sweet

Zip Code: 55417

Comment:

I support Clean Cars Minnesota. Due to the lack of selection in electric vehicles in Minnesota, there are even fewer choices in used electric vehicles. The advantages of driving electric is even more important for those with fewer resources. Used internal combustion powered cars have expensive maintenance costs since engines, transmissions, etc. are closer to end of life. Electric powered cars don't have those parts and also require less maintenance even after several years of use. Right now, many electric vehicles don’t even make it to Minnesota dealerships because they go straight to states like Maryland and Oregon with clean car standards - that’s just not fair. Minnesotans should be able to buy whichever car they want and purchasers of used electric vehicles deserve to have a wider selection.

OAH Docket No. 71-9003-36416 Name: Mary Jordan

Zip Code: 55410

Comment:

Communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionately harm Minnesota’s most vulnerable and marginalized communities.

OAH Docket No. 71-9003-36416 Name: Charlie Hautman

Zip Code: 55352

Comment:

I have been an EV owner for 5 years and I support Clean Cars Minnesota. I will never own another gas car because EVs are so much better in so many ways. I support this initiative for many reasons but my primary one is climate change. If we don't get off of fossil fuels soon we will be causing untold pain and misery for future generations. Fortunately we have other options but we need to make sure those options are available to Minnesota consumers.

OAH Docket No. 71-9003-36416 Name: Craige Farwick

Zip Code: 55313

Comment:

Electric cars are one of the most important things we can have to limit climate change. It is important this transition be done sooner rather than later to prevent a potentially irreversible situation as has been recently reported. I currently own a 2019 Nissan Leaf so I have put action where my mouth is. A problem was I had limited choice because of the few electric vehicles available in Minnesota. Resolution of the problem cannot wait for demand to increase. rather electric cars must be available to purchase to encourage demand. This is a chicken and egg problem and requires government leadership to get this important change rolling.

OAH Docket No. 71-9003-36416 Name: Dennis Wiesenborn

Zip Code: 56560

Comment:

I am a retiree in Moorhead, MN, and feel strongly that Minnesota needs more rigorous standards on car emissions. Climate change is already happening; scientists believe the impacts will continue to escalate if we fail to change. Future generations will pay for our failure to act. My wife and I are in the process of buying a Chevy Bolt EV and will have a Level 2 charger installed in our garage this spring.

OAH Docket No. 71-9003-36416 Name: James Tucker

Zip Code: 55439

Comment:

My name is James Tucker and I’m writing in support of Clean Cars Minnesota. Nearly three years ago my wife and I leased a plug-in hybrid and have enjoyed it so much that we are planning to buy a full electric vehicle this year.

In 2018 it was not easy: we could only find one of the kind of plug-in variety we wanted in the Twin Cities. In 2021 it doesn’t appear to be any easier: even though there are many new models coming online the model we want isn’t available for a test drive in Minnesota until the end of May. Other states that have laws that are favorable to electric cars will have theirs as early as March. Clean Cars Minnesota will put us on a more level playing field with those states.

I’m sure you’ve heard the reasons for supporting electric cars – cleaner air, reduced reliance on imported oil, they’re cheaper to run and maintain, they’re wonderfully quiet. Here’s another reason I didn’t think of until I saw the front page of the Star Tribune this morning (2/20/21): electric cars have no catalytic convertor to steal!

I want to leave the world a better place for my two daughters and helping to reduce the huge carbon output from the transportation sector of the economy is a good place to start. EVs are loved by the people who drive them but they need help to improve availability and awareness. Clean Cars Minnesota is that help.

OAH Docket No. 71-9003-36416 Name: Flannery Clark

Zip Code: 55407

Comment:

I support Clean Cars Minnesota. Cleaner cars mean cleaner air for myself and my neighbors. I love to be outside in my neighborhood but worry about how the air pollution coming from the cars and trucks passing by are affecting my health. I know that pollution harms lungs and hearts, especially when breathed in regularly. I also know that communities of color and low-income communities bear the brunt of the negative health impacts from air pollution. Clean Cars Minnesota would dramatically reduce these emissions and help protect me and everyone in my neighborhood. I want my kids and all my neighbors across Minnesota to have cleaner air.

As a consumer, I want choice in my car buying. We wanted to buy an EV when we purchased our current car, but the vehicle we wanted wasn’t offered in Mn.

OAH Docket No. 71-9003-36416 Name: Julia Kelly

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Rebecca Skoler

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Jim Guenter

Zip Code: 55105

Comment:

I’m an EV owner and I support Clean Cars Minnesota because driving an electric vehicle in Minnesota is a freeing experience. You can go from point A to point B without worrying about harmful tailpipe emissions and since EVs don’t have internal combustion engine they warm up much faster in the winter and have considerably lower maintenance costs. I can avoid the queue at the gas station by charging, inexpensively, at home. Clean Cars Minnesota would give the 6 in 10 prospective car buyers in Minnesota the opportunity to actually see and test drive a much wider variety of makes and models - many of which currently don’t even make it to our state because they go to states with clean cars standards. Buying a car or truck is a big choice and Minnesotans deserve the chance to weigh all options.

Clean air in Minnesota will save lives. I frequently drive the I94 corridor between St. Paul and Minneapolis and cringe at the tail pipe emissions impacting residence along the route. This impacts people of color and low income families the most. Clean Cars Minnesota is a social justice action we need to take.

Please take action to support Clean Cars Minnesota.

Jim Guenter

St. Paul, MN

OAH Docket No. 71-9003-36416 Name: Kelly Pier

Zip Code:

Comment:

Clean energy should be mandatory.

OAH Docket No. 71-9003-36416 Name: Cheryl Anderson

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Cameron Barton

Zip Code: 55414

Comment:

I am a young person, small business owner, and climate voter. Climate change is the biggest challenge our generation is facing, and clean cars are a necessary part of our approach to solving climate change. The time to save our climate is now and we can only do it if we fully embrace a home-grown clean energy economy that doesn’t harm our communities, air, lakes and forest. I hope to be an EV owner when I purchase my next car. I hope Minnesota makes the ethical choice to be a part of Clean Cars Minnesota, and through that choice gives me the best selection of cars when I am purchasing an EV in the near future.

OAH Docket No. 71-9003-36416 Name: Ryan Saunders

Zip Code: 55414

Comment:

OAH Docket No. 71-9003-36416 Name: John and Kay Buzza

Zip Code: 55106

Comment:

We leased an EV for three years and were glad to participate in helping clean the air and forward the use of sustainable energy. The EV options currently available are either too expensive or unable to pull our Minnesota produced SCAMP trailer. We would like more options for purchase, more charging stations statewide and we strongly support Clean Cars Minnesota standard!! Thank you MPCA!

OAH Docket No. 71-9003-36416 Name: Nicole Everling

Zip Code: 55122

Comment:

OAH Docket No. 71-9003-36416 Name: Annie Kuthart

Zip Code: 55130

Comment:

I support Clean Cars Minnesota.

Buying a car or truck is a big decision with so many factors to consider. I want the freedom to access to *all* the vehicles available in the U.S. marketplace. Right now, many electric vehicles don’t even make it to Minnesota dealerships because they go straight to states like Maryland and Oregon with clean car standards - that’s just not fair. I should be able to buy whichever car I want. And it would be nice to buy it here in MN instead of in OR.

OAH Docket No. 71-9003-36416 Name: Jacqueline Prince

Zip Code: 55435

Comment:

Curtailing auto emissions is one climate strategy we have the tools to do now, and it brings benefits to everyone.

OAH Docket No. 71-9003-36416 Name: Virginia Allen

Zip Code: 55108

Comment:

Please support Clean Cars Minnesota. Climate change is the most pressing issue facing our state and our planet.

OAH Docket No. 71-9003-36416 Name: Alan Carlson

Zip Code: 55108

Comment:

I support Clean Cars Minnesota. Cars and trucks on the roads are a major source of air pollution in our state. I live near a busy road and worry about the soot and ozone released from every car, truck, and bus that passes my home. I understand that most people rely on a gas-powered vehicle of some kind to get around, but we have an opportunity in Minnesota to clean up our air with clean car standards. Clean Cars Minnesota would help reduce air pollution from transportation and make our state healthier.

In addition, I support Clean Cars Minnesota because I’m an EV owner and driving an electric vehicle in Minnesota is a freeing experience. You can go from point A to point B without worrying about harmful tailpipe emissions and since EVs don’t have internal combustion engine they warm up much faster in the winter and have considerably lower maintenance costs. Clean Cars Minnesota would give the 6 in 10 prospective car buyers in Minnesota who are interested in electric vehicles the opportunity to actually see and test drive a much wider variety of makes and models - many of which currently don’t even make it to our state because they go to states with clean cars standards. Buying a car or truck is a big choice and Minnesotans deserve the chance to weigh all options.

But the main reason that I support Clean Cars Minnesota is that historically, communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionately harm Minnesota’s most vulnerable and marginalized communities.

OAH Docket No. 71-9003-36416 Name: Dick Ottman

Zip Code: 55110

Comment:

I own a 2020 Chevrolet Bolt (all electric). More of these cars should be available. It works great, and it is much cheaper to operate and maintain than a gasoline powered vehicle. Everyone in MN should have the opportunity to own an electric vehicle.

OAH Docket No. 71-9003-36416 Name: Becky Erdahl

Zip Code: 55419

Comment:

OAH Docket No. 71-9003-36416 Name: Ralph Brindle

Zip Code: 55439

Comment:

Greater availability and choice in offerings of EVs can only increase participation in this critically important adoption and migration process. I think dealers will be surprised by the interest in EVs as this technology matures over the next few years. We cannot afford to wait in supporting the adoption of EVs in addressing climate change.

OAH Docket No. 71-9003-36416 Name: Andrew McConnell

Zip Code: 55422

Comment:

OAH Docket No. 71-9003-36416 Name: Phillip Snartland

Zip Code: 56303

Comment:

If we don't start legislating an improvement in our efforts to reduce carbon build-up and climate change, we will never reach the goal of averting climate disaster. Mandating clean cars is a great first step.

OAH Docket No. 71-9003-36416 Name: Rebecca Taibl

Zip Code: 55127-7177

Comment:

I am an advocate for Minnesota moving away from fossil fuels, making it affordable to all, and bringing it to ALL Minnesotans! And stop ENBRIDGE immediately!

OAH Docket No. 71-9003-36416 Name: David Elvin

Zip Code: 55116

Comment:

I support Clean Cars Minnesota. Air pollution is a serious issue for everyone on Earth, and this is an opportunity to do something meaningful to about it. This is also an opportunity to create green jobs, which critical for the coming years as we recover from the COVID recession. Please advance Clean Cars Minnesota! Thank you!

OAH Docket No. 71-9003-36416 Name: John Schmitt

Zip Code: 55417

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Frederick Paul Kile

Zip Code: 55116

Comment:

I am concerned about both localized air pollution (e.g., AQI values) and global warming. Cleaner and more efficient transportation plays a critical part in reducing harm to the environment. To that end, I agree with Gov. Walz' proposal for MN to adopt California's automotive standards, recognizing this will help bring car models to the state that are currently hard to find. (Past visits to car dealerships have demonstrated to me that intriguing models are simply hard to find; I've repeatedly been redirected to other vehicles with comparatively weak pollution and climate limits.)

Please adopt the California automotive standards, as other states have done.

OAH Docket No. 71-9003-36416 Name: Matt Boys

Zip Code: 55416

Comment:

OAH Docket No. 71-9003-36416 Name: Diane Krueger

Zip Code: 55108

Comment:

I am fortunate enough to own a hybrid car and would love to move to an EV. I would also like to ensure that such vehicles are more affordable and available. Adopting this rule is a step in the right direction.

OAH Docket No. 71-9003-36416 Name: Carmen Barker Lemay

Zip Code: 55419

Comment:

I’m a business owner and I support Clean Cars Minnesota. Clean car standards are important to businesses like mine because they will serve as an economic and workforce engine for our state. Clean energy jobs will play a key role in our state’s post-COVID-19 economic recovery and my business depends upon a healthy and financially stable Minnesota workforce. Clean Cars Minnesota will keep our state on the right track to reduce our carbon footprint all while aligning with our business goals.

OAH Docket No. 71-9003-36416 Name: Wendy Adams

Zip Code: 55082

Comment:

Providing abundant clean energy car options is but one of many actions we must take to reduce our climate impacts NOW. We also need to build resilient infrastructure, including expanding renewables, battery storage, and an energy grid capable of transmitting renewable energy. We also need to promote energy efficient buildings, with codes for new buildings, and incentives for building retrofits. And more: America should lead the world in creating new technologies to get to carbon neutral BEFORE 2050; we will create a plethora of new jobs, and grow our economy in the process. Thank you.

OAH Docket No. 71-9003-36416 Name: Marjorie Dahlager

Zip Code: 55416

Comment:

I am a progressive Minnesotan who believes in clean air and water, less pollution and less consumption of polluting petroleum fuels.

OAH Docket No. 71-9003-36416 Name: Scott Burtness

Zip Code: 55105

Comment:

Clean Cars Minnesota reduces pollution and gives customers more choice.

OAH Docket No. 71-9003-36416 Name: Gregory Dana

Zip Code: 55108

Comment:

I am very concerned about the negative effects of Climate Change for Minnesota and for the whole planet. I am planning to buy an EV or a plug-in hybrid in the next few months. I have discovered that some of the cars I am interested in are not sold in Minnesota because we do not have a Clean Car Standard. I am not happy with the idea that I will possibly have to buy the car I want in another state rather than from a local dealer.

OAH Docket No. 71-9003-36416 Name: Daniel Barnes

Zip Code: 55410

Comment:

I'm a car and driving enthusiast, a "car guy," who wants a green way to enjoy the hobby. But the relatively few electric car models sold in Minnesota make it difficult. Please help increase the variety of vehicles sold and driven in Minnesota. Thank you.

OAH Docket No. 71-9003-36416 Name: claudia egelhoff

Zip Code: 55118

Comment:

Climate change is our biggest challenge.

OAH Docket No. 71-9003-36416 Name: Cheryl Persigehl

Zip Code: 55406

Comment:

I support Clean Cars Minnesota. Minnesota is in a toxic relationship with Big Oil and it’s time to cut ties. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing.We need to do everything we can to reduce Minnesota’s dependence on fossil fuels and transition to clean, local energy, because climate change is threatening our forests, water, air and people. With Clean Cars Minnesota more Minnesotans will transition to a zero emission or low emission vehicle when they buy or lease their next car or truck, and thus reduce our dependence on fossil fuels.

I care about our environment in Minnesota. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions.

We know air pollution is a serious issue in our state and the health of Minnesotans hangs in the balance. Clean Cars Minnesota is a major step toward cleaning up our air. Communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionally harm Minnesota’s most vulnerable and marginalized communities.

Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Carol M Arney

Zip Code: 55104

Comment:

OAH Docket No. 71-9003-36416 Name: Leslie Swiggum

Zip Code: 0

Comment:

OAH Docket No. 71-9003-36416 Name: Mike Edlund

Zip Code: 55112

Comment:

I support Clean Cars Minnesota for a variety of reasons. I am an EV owner who would like to see greater choice in both new and used cars in Minnesota. Having owned two EVs to-date and having driven over 30,000 miles, I have appreciated the chance to own a low maintenance, low cost to operate vehicle in Minnesota (one flat tire and tire rotations). The cars have handled well and were comfortable to drive in our Minnesota winters and also have had options that allow for preheating at home during the cold of winter.

Greater choices in what EVs would be available in Minnesota would provide consumers, 6 of 10 who are interested in the EV option, greater choices than are now available. Currently, there are just a handful of EV cars, especially the most affordable models, available in Minnesota. I am aware that there are many more models available in other states with clean cars standards. In addition, if Minnesota were to have greater options and choices in the EV models sold here, there would also be more choices for consumers wanting to purchase used models, which can be an even more affordable option.

OAH Docket No. 71-9003-36416 Name: William Lorimer

Zip Code: 55108

Comment:

It's time to get with the program. Clean cars are necessary if we are to have a future for our grandkids.

OAH Docket No. 71-9003-36416 Name: Tyson Bramer

Zip Code: 55446

Comment:

I’m also a parent and cleaner cars mean cleaner air for my kids, along with other vulnerable folks like the elderly and those with preexisting conditions who are most affected by the harmful effects of vehicle emissions. Clean Cars Minnesota will dramatically reduce these emissions and help protect my kids (and everyone else too!) when they’re waiting at the bus stop, walking in the neighborhood, or even just playing in the yard. Human health is at stake and the longer we wait, the more kids whose current and future health and wellbeing will be harmed by dirty vehicle emissions.

OAH Docket No. 71-9003-36416 Name: Nancy Conger

Zip Code: 55056

Comment:

I now own an EV and can't believe how energy-efficient and cost-effective it is. I am buying Minnesota wind power to fuel it -- a perfect win for all of us!

OAH Docket No. 71-9003-36416 Name: David Carlson

Zip Code: 56449

Comment:

More than ready for an EV. Need more charging stations. Availability of EV's in rural areas is non existent. Weather is going nuts, we need to change our ways now.

OAH Docket No. 71-9003-36416 Name: Paul T.Dennison

Zip Code: 55074

Comment:

We have an opportunity to CHOOSE to convert our transportation to use renewable energy. If we wait, as the finite quantity of fossil fuels becomes used up, we will be forced to change and make decisions in crisis mode rather than in a thoughtful calculating manor.

OAH Docket No. 71-9003-36416 Name: Jerry Cleveland

Zip Code: 55975

Comment:

We are seeing the results of climate change all over. Agriculture is having a tough time because of changing conditions that affect our ability to grow food. Our summers are hotter our winters are colder. Sometimes it feels like the seasons are changing places. We need to move to renewable energy.

OAH Docket No. 71-9003-36416 Name: Sue Astin

Zip Code: 55422

Comment:

OAH Docket No. 71-9003-36416 Name: Jeff Bartlett

Zip Code: 55126

Comment:

I am a Minnesotan who has stayed and worked all over the country. Each time I've lived elsewhere I always return to the state where I was born, because it is a place of whose values and progress I can be proud. I am now raising a small son here, having decided it is simply the best place to live.

I want Minnesota to strengthen its national leadership on clean energy, environmental health and resiliency. I want Minnesota to reduce its terrible gaps in equity and access. Mostly, I want Minnesota to become a better place for everyone, including my son. My voice is added to the many neighbors who support the Clean Cars MN rulemaking efforts.

OAH Docket No. 71-9003-36416 Name: Carol Bungert

Zip Code: 55416

Comment:

It is time for immediate radical action to stop global warming. We must reduce our carbon footprint and clean energy cars would have a huge impact toward that end.

OAH Docket No. 71-9003-36416 Name: Mary Harlow

Zip Code: 55416

Comment:

It’s time for Minnesota to step up and join the 14 other states and DC who already have clean car standards. Even General Motors has joined the good fight to preserve our beautiful environment from fossil fuel pollution! I drive a 2018 Chevy Volt and it is the best car I have ever had! Not one repair to date �

OAH Docket No. 71-9003-36416 Name: Ann Farrell

Zip Code: 55104

Comment:

OAH Docket No. 71-9003-36416 Name: Elena de Ana Skinner

Zip Code: 55105

Comment:

I’m a kid and I believe its important to make our cars not depend on fossil fuels. I support clean cars Minnesota and I'm worried about climate change. Please do everything you can to help us reach 100% clean energy.

OAH Docket No. 71-9003-36416 Name: Megan Gallagher

Zip Code: 55904

Comment:

OAH Docket No. 71-9003-36416 Name: Mari Ojeda

Zip Code: 55113

Comment:

Also, for the average American household, transportation is the second largest expense after housing, but it doesn’t have to be that way! Electric vehicles can save people like me money because they have lower maintenance, operating, and fuel costs than a traditional gasoline-powered vehicle. However, both new and used electric vehicles are hard to track down here in Minnesota because they often go straight to states like Maryland and Oregon with clean car standards – and that’s just not fair. Clean Cars Minnesota would bring more EVs to Minnesota's new and used car marketplace and drive down competition for specific makes and models in my price range. I'm also a renter that currently wouldn't have access to a charging station. If Clean Cars MN were passed, the pressure for multifamily property owners to install charging stations would increase and allow renters like me to have access once I purchase an EV.

OAH Docket No. 71-9003-36416 Name: Rachel Braaten

Zip Code: 55422

Comment:

I tried finding an electric vehicle, when I was looking for a new car, about a year and a half ago. I DID NOT find one. Now, luckily, a friend is moving and is selling his Nissan Leaf to me.

Minnesota doesn't produce it's own fossil fuels. But we do produce wind and solar energy. Let's power our fleet with local, Minnesota energy!

OAH Docket No. 71-9003-36416 Name: Robert Iverson

Zip Code: 56601

Comment:

My Wife and I Have a Tesla Model Y Purchased in September 2020 We Beleave in the The Shift to BEV's Minnesota Needs to get on Board with the rest of the world and shift to EV's

Thank You Robert Iverson

OAH Docket No. 71-9003-36416 Name: Sarah Gleason

Zip Code: 55102

Comment:

OAH Docket No. 71-9003-36416 Name: Allie Gaddis

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Mary Ludington

Zip Code: 55409

Comment:

OAH Docket No. 71-9003-36416 Name: Analiese Miller

Zip Code: 55118

Comment:

OAH Docket No. 71-9003-36416 Name: Mike Mondloch

Zip Code: 55025

Comment:

I strongly support the rules and the choice to buy an EV. EVs offer too many environmental and financial advantages to ignore. We cannot continue to avoid the impacts of greenhouse gases on our climate.

OAH Docket No. 71-9003-36416 Name: Steven Miller

Zip Code: 55901

Comment:

I am a Minnesotan who is concerned about greenhouse gas pollution from cars and trucks. This pollution imperils the health and economic well-being of the citizens of Minnesota. I advocate for Minnesota to meaningfully reduce vehicle use of fossil fuels as a way to reducing greenhouse gas emissions. Improving fuel efficiency of vehicles and increasing use of electric vehicles would help lower greenhouse gas emissions in our state.

OAH Docket No. 71-9003-36416 Name: Mary T'Kach

Zip Code: 55077

Comment:

People in my family have respiratory illnesses and clean air is essential to their on-going health. Having more choice in vehicles that are cleaner burning overall would be a boon to our family's health and the health of other families in Minnesota and our region. As a market gardener for over 25 years, we have experienced changes in weather events including more damaging winds, more frequent torrential downpours that have caused us to replant expensive seed or harvest various crops early due to damage from wind and/or rain. It's time the Minnesota Legislature reduced barriers to consumers who want and need a cleaner and more robust economy in Minnesota. It's time the MPCA rules and regulations protect Minnesotans and Minnesota's fragile and diverse ecology with robust rulemaking for a Clean Cars Standard.

Thank you.

OAH Docket No. 71-9003-36416 Name: Jennifer Jacquot-DeVries

Zip Code: 56401

Comment:

OAH Docket No. 71-9003-36416 Name: Sally Ruvelson

Zip Code: 55118

Comment:

I’m a parent and grandparent. I support Clean Cars Minnesota. Cleaner cars mean cleaner air for my kids and grandkids, along with other vulnerable folks like the elderly and those with preexisting conditions who are most affected by the harmful effects of vehicle emissions. Clean Cars Minnesota will dramatically reduce these emissions and help protect my kids (and everyone else too!) when they’re waiting at the bus stop, walking in the neighborhood, or even just playing in the yard. They will protect me, too, an elder, when. Choose to walk to the grocery store instead of using a personal vehicle. Human health is at stake and the longer we wait, the more kids whose current and future health and wellbeing will be harmed by dirty vehicle emissions.

OAH Docket No. 71-9003-36416 Name: Matt Karlgaard

Zip Code: 56401

Comment:

OAH Docket No. 71-9003-36416 Name: Julie Guth

Zip Code: 56444

Comment:

I am a rural Minnesotans, and I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change- causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. I do think, however, that some provision needs to be made to insure that low-income Minnesotans are not disproportionately affected by the costs associated with the legislation (for eg., for vehicle inspections).Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Carly Coulson

Zip Code: 55802

Comment:

OAH Docket No. 71-9003-36416 Name: Dan Rogers

Zip Code: 56461

Comment:

Our lives are short on this planet and it is vital that we leave this world a better place. We are all stewards of the planet and the other untold numbers of plants, animals and other species that can't speak need us to advocate for them as well. I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Marian Severt

Zip Code: 56401

Comment:

“Clean Cars Minnesota” will put us on the road to cleaner air, severing our dependence on fossil fuels and leaving an energy use legacy for our progeny that we can be proud of. I am proud of Gov. Waltz’s stand.

OAH Docket No. 71-9003-36416 Name: Jodi Evenson

Zip Code: 56474

Comment:

We need tp continue to make strides to improve our environment and by turning to electric cars as an option to reduce emissions is a great option. So much more needs to be done but this is a great start.

OAH Docket No. 71-9003-36416 Name: David Winkelman

Zip Code: 56401

Comment:

Hi...I am an outdoors person and am concerned about how pollution is harming natural ecosystems and humans health. Please make our cars and trucks electric so we can reduce pollution, thanks.

OAH Docket No. 71-9003-36416 Name: Mike Spry

Zip Code: 56467

Comment:

OAH Docket No. 71-9003-36416 Name: Katen Vann

Zip Code: 56303

Comment:

OAH Docket No. 71-9003-36416 Name: Molly Gray

Zip Code: 55401

Comment:

OAH Docket No. 71-9003-36416 Name: Maraika Lumholdt

Zip Code: 55415

Comment:

OAH Docket No. 71-9003-36416 Name: Jason Giltner

Zip Code: 55401

Comment:

OAH Docket No. 71-9003-36416 Name: Samantha Huntley

Zip Code: 55447

Comment:

OAH Docket No. 71-9003-36416 Name: Andrew Bullock

Zip Code: 55423

Comment:

I am very focused on pushing MN away from fossil fuels in cars but also in electricity generation. I am buying a plug in hybrid this spring but know it's expensive and there needs to be a strong push to get things more affordable for all soon so the long term negative impacts of climate change are minimized before it's too late.

OAH Docket No. 71-9003-36416 Name: Chuck Anderson-Weir

Zip Code: 55406

Comment:

I support Clean Cars Minnesota. Cars and trucks on the roads are major source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: DyAnn Andybur

Zip Code: 55804

Comment:

Five years ago, I bought an electric vehicle hybrid car to lessen tailpipe emissions and take a personal step to reduce my carbon footprint. Even with all that motivation I still had to get past my own resistance to change! Most people experience that resistance when it comes to making choices so they end up doing what they’ve always done, that is, until the change becomes mainstream. This is my strongest argument for supporting Clean Cars Minnesota. Give Minnesotians more EV options and opportunities to drive an electric vehicle. They will soon find out how much fun they are to drive, how much money they will save on maintenance, and for many, they may begin to like the thought that they are helping reduce carbon emissions and air pollution.

OAH Docket No. 71-9003-36416 Name: Heidi Auel

Zip Code: 56401

Comment:

There are so many reasons to switch to and promote clean energy. We have a chance to be change makers and we should take it. I educate our youth about climate change, it is important that we take steps in our state to mitigate it any way we can, to show others that it’s what should be done.

OAH Docket No. 71-9003-36416 Name: Anne Fisher, Transitional Pastor

Zip Code: 55431

Comment:

To the Minnesota Pollution Control Agency,

Oak Grove Presbyterian Church in Bloomington, Minnesota is a congregation of approximately 500 people. We have a strong commitment to fighting climate change as shown by our use of renewable energy to get over 200% of our electrical consumption from wind (WindSource) and solar (rooftop solar and community solar garden).

We have sponsored EV Expos at our church to teach our congregation and community about EVs, chargers, e-scooters, e-bikes, electric mowers and about different ways they can stop burning fossil fuels in their daily lives. At last count, 10 members of our congregation drive EVs or PHEVs. We have installed two level 2 chargers in our parking lot that are available to members and the general public.

Oak Grove Presbyterian strongly favors adoption of the Minnesota Clean Car Standards for five reasons, including:

- Taking action to curb climate change - Improving health outcomes through cleaner air - Making cleaner cars (LEVs) and EVs (ZEVs) more widely available - Promoting affordability - Fostering sustainable economic development and equity in Minnesota - Taking action to curb climate change

Minnesota is not meeting our climate goals. Fossil fuel burning cars are our state’s biggest carbon emitters producing approximately 1/3rd of all GHG emissions. In addition, our refining of oil to make gasoline is another major source of emissions. Switching to more fuel efficient cars and to EVs is the only way we can possibly get back on track to fight climate change in time to avert catastrophic, out-of-control effects.

OAH Docket No. 71-9003-36416 Adoption of the Minnesota Clean Car rules will make more high mileage cars and EVs available for people to test drive and buy. Coupled with the “greening” of Minnesota’s electrical grid and with green energy programs such as WindSource, these standards will enable millions of Minnesotans to immediately and dramatically cut our carbon footprints.

Improving health outcomes through cleaner air Harvard University recently published a study showing that 1 in 5 deaths worldwide are due to burning fossil fuels. We don’t have to look very far to see this happening in Minnesota. Just go out on I-35 or I-94 on a hot day during rush hour and breathe the fumes. The most congested routes of our interstates and other major highways go through marginalized, segregated low-income areas and communities of color, forcing people to breathe nitrogen oxide, particulate matter and carbon monoxide which have terrible health impacts---from slow development of infants, to increased learning problems of youngsters, to increased respiratory disease, heart disease, cancer and premature death. The human costs of this air pollution are shameful and appalling! Adoption of the Minnesota Clean Car rules will help cut this pollution and help our communities enjoy better health outcomes.

Making cleaner cars (LEVs) and EVs (ZEVs) more widely available The 14 states and the District of Columbia that have joined California in adopting the Clean Car Standards proposed by the MPCA currently have far more EVs and PHEVs available on dealer lots than we do. If Minnesota fails to adopt the proposed Clean Car Standards, this disparity will grow even worse. With the Federal Government’s commitment to change its entire vehicle fleet of 650,000 vehicles over to EVs and with the commitment of many auto manufacturers to offer more and more EV models, first preference will be given to those states that have adopted the Clean Car Standards. The same logic will also apply to building (or not building) high-speed EV charging networks that will be critical to the future of Minnesota’s tourist and hospitality industries.

Promoting affordability The best way of promoting affordability is through competition. Studies have shown that the total cost of ownership over 5 years for a Tesla Model 3 is less than the costs of a Toyota Camry. This cost gap will only widen as battery technology develops rapidly and EVs become cheaper and have longer and longer ranges. Tesla has committed to bringing the cost of its next generation Model 2 SUVs down to $25K with a range of approximately 400 miles by 2024, which is, incidentally, the first year that the Minnesota

OAH Docket No. 71-9003-36416 Clean Car rules would go into effect. General Motors and other manufacturers have made similar commitments for their EV programs.

80% of EV charging is done at home for costs of approximately 86 cents to $1.10 per gallon equivalent. (Some utilities in Minnesota such as Great River Energy offer customers free charging at night). This compares to $2 to $3 per gallon cost for gasoline. Maintenance costs are far less for EVs than for internal combustion engine cars. By adopting the Minnesota Clean Car standards these competitive advantages of EVs and other high mileage cars can be clearly shown on dealers’ lots for Minnesota consumers to judge for themselves.

Fostering sustainable economic development and equity in Minnesota Minnesota imports billions of dollars worth of fossil fuels every year from other states and countries…. Wyoming, Oklahoma, Texas, Louisiana, North Dakota, Alaska, Alberta, the Middle East. It is time to cut back on these because, increasingly, the cheapest sources of energy are the cleanest- wind, solar and battery storage electricity generated right here in Minnesota.

By adopting the Minnesota Clean Car standards we will give consumers choices that will transform Minnesota’s transportation and energy sectors from high carbon emissions, disease and water pollution to good-paying, locally-sourced clean energy jobs---installing charging networks throughout the state, developing software for autonomous vehicles, installing wind turbines and solar gardens, building distributed energy micro-grids with vehicle-to-grid capabilities (V2G), long duration battery storage technologies and green hydrogen.

Please adopt the proposed Minnesota Clean Car Standards to help move our state forward to a new, sustainable world for all.

Sincerely,

Session, Oak Grove Presbyterian Church 2200 W. Old Shakopee Rd Bloomington, MN 55431, 952-888-4621 c/o Anne Fisher, Interim Head Pastor

OAH Docket No. 71-9003-36416 Name: John Crampton, VP, Minnesota Division, Izaak Walton League

Zip Code: 55431

Comment:

To the Minnesota Pollution Control Agency

We are writing on behalf of the Minnesota Division of the Izaak Walton League, approximately 1,000 members in 15 chapters located throughout the state, from Winona to New Ulm, from Duluth to Detroit Lakes, with 4 chapters located in the Twin Cities area. Founded in the 1920s our mission is to act as strong “defenders of soil, air, woods, waters and wildlife,” in other words all the natural ecosystems of which we humans are a part.

The Minnesota Division of Izaak Walton strongly favors adoption of the Minnesota Clean Car Rules for 5 reasons:

- Taking action to curb climate change

- Improving health outcomes and curbing disease through cleaner air

- Protecting clean water and wildlife

- Providing consumers with many, affordable clean car choices

- Building a sustainable, equitable 21st century clean energy economy in

Minnesota

Taking action to curb climate change

Minnesota is not meeting our climate goals. We are quickly running out of time as extreme, out-of-control climate impacts are now taking place everywhere. Fossil fuel burning cars are Minnesota’s biggest carbon emitters producing approximately 25-30% of all greenhouse gas emissions. In addition, refining oil to make gasoline adds another

OAH Docket No. 71-9003-36416 7-10% of total emissions. To mitigate climate change, we need to increase the year-by- year fuel economy performance of all new car models. We also need to increase the availability of low emissions vehicles (LEVs) and zero emissions vehicles (ZEVs). We need to expand 100% clean electricity options such as WindSource and Wellspring. Taken together, they offer reliable, affordable choices for customers to dramatically cut their carbon footprints.

Improving health outcomes and curbing disease through cleaner air

Harvard University recently published a study showing that 1 in 5 deaths worldwide are due to the burning of fossil fuels. We don’t have to look far to see this happening here. Just go out and breathe the fumes from I-35 or I-94 on a hot summer day during rush hour. Our most congested highway routes go through marginalized, segregated low- income areas and communities of color, forcing people to breathe high levels of nitrogen oxide, particulate matter and carbon monoxide that result in slower development of infants, increased learning problems of youngsters, and increased rates of respiratory disease, heart disease, cancer and premature death. The human costs of our gasoline- powered air pollution are shameful and appalling! This concern over the health of all citizens is why Congress passed the Clean Air Act in 1970 upon which these rules are based. Adoption of the Minnesota Clean Car rules will give consumers more choices of LEVs and ZEVs that have much lower or zero emissions of CO2, nitrogen oxide, and particulate matter.

Protecting clean water and wildlife

From the Exxon Valdez oil spill in Prince William Sound, to BP’s Deepwater Horizon oil spill in the Gulf of Mexico, to Enbridge’s ruptured pipeline spewing bitumen to the bottom of the Kalamazoo River, Michigan, to Enbridge’s Line 3 being built across the pristine headwaters of the Mississippi River, the oil industry has been a major worldwide source of water pollution and mass killings of wildlife. Adoption of the Minnesota Clean Car rules will provide Minnesota consumers with the choice of vehicles that run on clean electricity generated here in Minnesota by solar and wind energy sources that pose no threats to our waters and only minimal (and solvable) threats to our wildlife.

Providing consumers with many, affordable clean car choices

OAH Docket No. 71-9003-36416 The 14 states and the District of Columbia that have joined California in adopting the same Clean Car Standards proposed by the MPCA have more EV and PHEV models available on dealer lots than we do here in Minnesota. While there are approximately 45 models of EVs and PHEVs available in the US, only 10 of those models are currently available in Minnesota, (and 4 of those models are Teslas which are not sold in dealerships).

If we fail to adopt the proposed Minnesota Clean Car Standards, this disparity will grow even worse. With the Federal Government’s commitment to switch its vehicle fleet of 650,000 vehicles over to EVs, and with the commitment of many auto manufacturers to offer more and more EV models, first preference will be given to those states that adopt the Clean Car Standards. Minnesota consumers will be left behind. The same logic will also apply to building (or not building) high-speed EV charging networks along major routes. These charging networks will be critical to the future of our transportation, tourist and hospitality industries.

The best way of promoting affordability is through competition. That is the American way! Studies have shown that the total cost of ownership over 5 years for a Tesla Model 3 is less than the costs of a Toyota Camry. This gap will only widen as battery technologies develop rapidly and EVs become cheaper and have longer and longer ranges. Tesla has committed to bringing the cost of its next generation Model 2 SUVs down to $25K with a range of approximately 400 miles by 2024. General Motors and other auto manufacturers have made similar commitments for their EV programs.

85% of all EV charging is done at home for costs of approximately 86 cents to $1.10 per gallon equivalent. (Some utilities such as Great River Energy offer customers free charging at night). This compares to $2 to $2.50 per gallon for gasoline. Maintenance costs are far less for EVs than for gas-powered cars. By adopting the Minnesota Clean Car standards these competitive advantages of EVs, PHEVs and high mileage cars will be clearly shown on dealers’ lots for Minnesota consumers to judge for themselves.

Building a sustainable, equitable 21st century clean energy economy in Minnesota

OAH Docket No. 71-9003-36416 Minnesota imports billions of dollars worth of fossil fuels every year from other states and countries…. Wyoming, Oklahoma, Texas, Louisiana, North Dakota, Alaska, Alberta, the Middle East. It is time to cut back on these dirty fuel imports because, increasingly, the cheapest sources of energy are the cleanest and easiest to transport. They are wind, solar and long-duration battery storage electricity generated right here in Minnesota.

By adopting the Minnesota Clean Car rules Minnesota can become a clean car “mecca” for people from the mid regions of the US who live in states that have don’t adopt clean car standards. By adopting these Clean Car rules we can give consumers choices that will transform Minnesota’s transportation and energy sectors from reliance on expensive imports of dirty fuels to a growing new economy here in our state with good-paying, locally-sourced jobs and industries.

Please adopt the proposed Minnesota Clean Car Standards to help move our state forward to a better, sustainable world for all.

Sincerely, Minnesota Division, Izaak Walton League of America c/o John Crampton, VP 612-396-6010 [email protected]

OAH Docket No. 71-9003-36416 Name: Casey Giltner

Zip Code: 55418

Comment:

OAH Docket No. 71-9003-36416 Name: Brittany Bybee

Zip Code: 55418

Comment:

OAH Docket No. 71-9003-36416 Name: Jodie Provost

Zip Code: 56431

Comment:

So grateful Gov. Walz is working on clean energy!

OAH Docket No. 71-9003-36416 Name: Joseph Shimota

Zip Code: 55338

Comment:

I am for incentivizing the purchase of 0 or low emission vehicles. Notice, I said incentivizing, not mandating.

OAH Docket No. 71-9003-36416 Name: Mary Shimota

Zip Code: 55338

Comment:

OAH Docket No. 71-9003-36416 Name: Adrian Daley

Zip Code: 55123

Comment:

After owning an EV for 7 years I've found the driving comfort, performance, and reliability to be exceptional.

OAH Docket No. 71-9003-36416 Name: Sarah Shimota

Zip Code: 55904

Comment:

Minnesota has no future if there isn’t healthy planet to live on!

OAH Docket No. 71-9003-36416 Name: Josh Yank

Zip Code: 55417

Comment:

I’m an outdoorsperson and I support Clean Cars Minnesota. The outdoor life is such an important part of our Minnesotan culture - in part, it defines what it means to be a Minnesotan. But cars and truck emissions are threatening our outdoor resources and way of life. Automobiles are the #1 source of climate change-causing pollution in our state. We should be doing what we can now to mitigate this threat. As a state, we are falling short on our climate goals in general - Clean Cars Minnesota represents an excellent opportunity to get back on track, slowing climate change, reducing greenhouse gas emissions from transportation, and protecting our precious outdoor resources. Let’s act now before it's too late.

OAH Docket No. 71-9003-36416 Name: Isaac Evans

Zip Code: 55104

Comment:

There are a multitude of health, economic, and environmental reasons to hasten our transition towards lower and zero emissions vehicles by implementing the Clean Cars standard.

First, accelerating the adoption these zero and low emissions vehicles will have immediate impacts on local air quality and the health of frontline communities located near our highly trafficked roads and highways. Due to past planning decisions these frontline, oftentimes low-income and BIPOC, communities are disproportionately impacted by vehicle emissions that lead to poorer health outcomes than communities located further from high traffic corridors.

Second, electric vehicles can save owners money over the lifetime of a vehicle by reducing many of the more expensive routine maintenance and fuel costs of owning a conventional internal combustion engine car. A recent study published by MIT examines the lifetime cost and greenhouse gas emissions of every new model vehicle showing that the cheapest to own and most environmentally friendly options are plug-in hybrid and fully electric vehicles (https://www.carboncounter.com/#!/explore).

Finally, zero emissions vehicles paired with a progressively cleaner grid can eliminate vehicle greenhouse gas emissions that are now the leading cause of climate change in the state. Climate change is already having a large measurable impact on Minnesotans and Minnesota is a long way off from meeting our climate change and carbon emissions goals. If we are to limit warming to 1.5 degrees Celsius it is imperative to reduce emissions as quickly as possible and put every effort possible towards discouraging or preventing the purchase and development of long-term fossil fuel infrastructure and vehicles.

I support the Clean Cars Minnesota because the decisions we make today will impact the wellbeing and futures of millions of Minnesotans like myself. It is time for Minnesota to take bold action to ensure the health of its people and environmental.

OAH Docket No. 71-9003-36416 Name: Lynn Camp

Zip Code: 55423

Comment:

OAH Docket No. 71-9003-36416 Name: Jon Kuskie

Zip Code: 56472

Comment:

I am concerned that the EV is not yet ready for prime time in cold MN and we are dependent on China for rare earth minerals necessary for battery storage. MN should not force EV cars on the public until nuclear energy adopted more widely as part of our grid. Otherwise, we would have serious challenges with the dependability of our transportation system.

OAH Docket No. 71-9003-36416 Name: Eric Buchanan

Zip Code: 56267

Comment:

There is no question that EV's are our future. This future is already being set by car companies, Europe, and coastal states. MN should be a leader in this effort by adopting the clean car rules so we can benefit from all the new technology - especially here in rural MN where our choices are often more limited. Anyone who has driven an EV knows it is just a better vehicle in every way so the sooner we can get more options to drive, the sooner we start being part of the climate solution.

OAH Docket No. 71-9003-36416 Name: Wendy Armitage

Zip Code: 55104

Comment:

OAH Docket No. 71-9003-36416 Name: Joel Ostmoe

Zip Code: 55303

Comment:

I care about our environment and I DO NOT support Clean Cars Minnesota. Climate change is exaggerated by these eco-terrorist groups. Cars and trucks on the roads are the NOT the source of pollution in our state and nationally so we need to DO NOT NEED act to reduce greenhouse gas emissions, because science is not settled on GW. Clean Cars Minnesota needs to go before the MN legislature for a vote. There is no verifiable proof reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s NOT ACT hastily and waste taxpayer's money.

OAH Docket No. 71-9003-36416 Name: Allen Gleckner

Zip Code: 55105

Comment:

OAH Docket No. 71-9003-36416 Name: Sarah Clark

Zip Code: 55105

Comment:

Clean Cars Minnesota is a big opportunity for our state to reduce pollution from transportation and offer more options for electric car buyers. In 2016 I traded in my old minivan for a used 2013 Leaf. I saved more than $1,000 in the first year alone due to reduced fuel and maintenance costs. My family and I are no longer breathing in our own exhaust and we are no longer contributing as much to the "bad air quality days" we seem to be having more and more in our state. I want more Minnesotans of all incomes to experience the benefits of driving electric. Clean Cars Minnesota will ensure we do not miss out on new electric cars here, and will help build the overall market making used EVs available for people like me. For the climate benefits, public health and air quality benefits, and economic reasons, I support Clean Cars Minnesota.

OAH Docket No. 71-9003-36416 Name: steve mesmer

Zip Code: 55123

Comment:

I’m a Minnesotan who cares about our natural resources, and know that reducing greenhouse gas emissions from cars and trucks is a way of combatting climate change.

OAH Docket No. 71-9003-36416 Name: Emily Hagen

Zip Code: 0

Comment:

I support Clean Cars Minnesota. We've shown ourselves to be a future-conscious state in so many ways, and clean air and water are of paramount importance. Let's be leaders in protecting them for future generations.

Clean car standards are an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Ken Williams

Zip Code: 55410

Comment:

OAH Docket No. 71-9003-36416 Name: Christina Herold

Zip Code: 55436

Comment:

I have been an early adopter of energy efficient cars having owned a 2004 Honda Civic Hybrid and now a 2012 Chevy Volt. The average person drives ~32 miles round trip to and from work so if all new cars were plug-in hybrids with a 50 mile range, most driving would be done on electric power while still having the flexibility of using the gas engine on long road trips. The plug-in hybrid technology could bridge the gap until there are a enough power stations that are fast enough for a quick power refill for all electric vehicles. Electric cars have so many benefits to the environment and are really fun to drive.

OAH Docket No. 71-9003-36416 Name: Diane Grier

Zip Code: 55124

Comment:

I am part of the Interfaith Creation Care group and also a consumer. I also have 7 grandchildren and I'm concerned about the pace of destruction of our planet.

I care about the environment and want more choice in making my next car purchase, which will be an electric car. I 'm glad that

Governor Walz and others are stepping up to fight for a better environment and our collective health.

OAH Docket No. 71-9003-36416 Name: John and Mary Crampton

Zip Code: 55431

Comment:

My wife and I are both 73 years old and retired living on a fixed income. We live in Bloomington about 3 blocks away from 35-W in the area of 106th St exit. We are very concerned about the impact of all the gasmobiles and diesel trucks on 35W in terms our health in terms of particulate matter and ground level ozone pollution, especially during hot humid days. We favor the MPCA Clean Car standards that will give people more choices in buying ZEVs and LEVs that produce lower or zero emissions of CO2, nitrogen oxide, particulate matter and other harmful pollutants.

We are concerned about climate change which is negatively impacting our environment here in MN. We see it everywhere in terms of extreme weather events, the huge rainfalls, the fact that winter nights are not as cold as they used to be. We see it in the extinction of wildlife species, especially bugs and pollinators. Also the proliferation of invasive species as our climate shifts the biomes and natural ecosystems faster than they can adapt. Climate change is threatening the future livability of our planet for all living creatures...our children and grandchildren and future generations.

Therefore, we drive an electric car for 70% of our travel and charge at home with a level 2 charger (approx. $500) and 100% WindSource (green energy) electricity. It costs us approx. 80cents-$1.10 per gallon equivalent to power our EV for approximately 15,000 miles per years. This electricity is all produced in Minnesota and is 100% carbon free. These lower fuel costs, coupled with very low maintenance costs, means that, over the life cycle of our EV, we will pay less money than if we operated an equivalent gasmobile. And we are not subsidizing Saudi Arabia, Russia, North Dakota, Oklahoma or the Alberta Tar Sands with our transportation choices.

We have responded to 3 manufacturers recalls for our EV….. Each time we have taken it into the Nissan dealer, they have tried to upsell us on things that we don’t need. Once the dealer offered us a free oil change! Rather than bitching about EVs, maybe the auto dealers should train their personnel about EVs and to quit trying to convert us by bad- mouthing EVs… We are never going to buy their stinking, smelly gasmobiles!

OAH Docket No. 71-9003-36416 If they defeat the MPCA Clean Car rule-making and prevent us from having a robust selection of EVs to choose from here in MN, we will make sure to buy our next car from Tesla or from dealers in other states that have signed onto the Clean Car Standards.

We look around at Norway, China and Europe and other developed countries of the world where there is a tremendous demand for EVs and wonder, “What’s wrong with these Minnesota Auto Dealers and Chamber of Commerce types?” Are they so stuck in their warrantied service contracts that they can’t see that the world has changed? For Minnesota to be competitive in the future, we need to join California and the other 14 states and DC to adapt the proposed Clean Car Standards. If we don’t, our state will be a corrupt little backwater….. Louisiana of the North…. A place blessed beyond belief by nature but too selfish to care about pollution, climate change, the future of our children, grandchildren and future generations.

John and Mary Crampton, 1401 W. 102nd St. Bloomington, MN 55431 612-396-6010 (John) 612-865-7890 (Mary)

OAH Docket No. 71-9003-36416 Name: LeRoy Barnhart

Zip Code: 55419

Comment:

Right now, the EV availability is poor at dealers and we need to change that.

- EVs don’t produce tailpipe emissions, so increasing EV adoption improves the air quality, especially in areas where vehicle traffic produces a lot of pollution.

- EVs also use much less energy than ICE cars so the overall emissions are considerably lower, and they improve our trade balance since we don’t need to import so much oil.

- Since EVs consume less energy, they are much cheaper to drive, and EVs have considerably lower maintenance costs so they are also much cheaper to own.

- Used EVs are the most affordable cars to own.

- In 2020, the average EV sold in Minnesota had over 250 miles of range, and when we have more choices everyone can find one that works for them. EVs are quieter and provide better performance, leading to a better driving experience.

- Safety is important to me and IIHS test results clearly show that EVs are very safe.

- EVs are great winter cars. They have emission free preheating functions and fast heating systems.

- Home charging is the most convenient and affordable way to power driving. Public charging is valuable service, but I don’t use public charging very often, so the current public charging infrastructure works well for me. I also feel that confident that we will have more public charging infrastructure available in the future.

- EVs reduce our dependency on imported oil so we can keep our dollars in Minnesota and don’t need to inhale the emissions caused by refining oil and burning gas.

OAH Docket No. 71-9003-36416 - Electric utilities are moving away from coal and adding clean renewable electricity production. EVs gets cleaner every day.

- Auto manufacturers are bringing dozens of new EV models to the US market before 2024, and I want to make sure that Minnesotans have access to all these options.

- Clean Cars Minnesota would give the 6 in 10 prospective car buyers in Minnesota who are interested in electric vehicles the opportunity to actually see and test drive a much wider variety of makes and models—many of which currently don’t even make it to our state because they go to states with clean cars standards.

OAH Docket No. 71-9003-36416 Name: Chris Simon

Zip Code: 55406

Comment:

I have driven an EV as my daily car in Minnesota since 2009. Those who say they are too expensive or have too short of range or take too long to charge are stating opinions without experience. I have enjoyed driving EVs for over a decade and will never go back to a gasoline powered car.

Gasoline as a source of transportation had it's place fro over 100 years, and one of the impacts is an increase in the rate of climate change. It doesn't make sense to continue this any longer when EVs are a great alternative. Minnesotans deserve better than continuation of the dominance of fossil fuels for our transportation needs..

OAH Docket No. 71-9003-36416 Name: Sophie Clark

Zip Code: 55105

Comment:

OAH Docket No. 71-9003-36416 Name: Junaed Sattar

Zip Code: 55126

Comment:

I write this in support of the Clean Car MN Act proposal. I have been driving an EV for about 2 years now in MN, and that car has become my daily driver and also a long-drive companion. I do not see myself wanting to buy another ICE vehicle again, given my experience. New zero maintenance, amazing driving performance, range, and hassle- free ownership all contribute to that decision. With local electricity providers giving options for solar and wind energy, my car runs on fully renewable electricity. The biggest draw, of course, is the environmental impact of EVs, with zero pollutants produced during daily driving, helping us protect the very air, the very environment that sustains us. However, that EV purchase took a full year of research and exploration in Minnesota, as options were severely limited. They still are. Most EVs that come out in the US are not available for purchase in MN. My choice came down to just two manufacturers. At one point, we had to seriously consider a gas-electric hybrid as that seemed to be the only viable option within our budget. Thankfully we did find a battery electric vehicle in the end, but it took a long time to find one. Availability needs to be so much better. This situation is what forces us to go for ICE vehicles. Most EVs are safe, reliable, lasts a long time, holds their value, and hassle free as far as maintenance goes. I'd be fully supportive of this act and I hope that future EV buyers are not faced with the same hardships with availability that past buyers faced. With 2021 bringing in so many EV options to the market, I sincerely hope MN does not fall behind this opportunity to bring groundbreaking change to our transportation options towards a cleaner, better Minnesota.

OAH Docket No. 71-9003-36416 Name: Nichole Goodwell

Zip Code: 55118

Comment:

OAH Docket No. 71-9003-36416 Name: Jean Kennedy

Zip Code: 55403

Comment:

OAH Docket No. 71-9003-36416 Name: Timothy Fremouw

Zip Code: 0

Comment:

I’m writing in support of the proposed Clean Cars standards for Minnesota.

I grew up in rural Minnesota. When I first moved to the Twin Cities in 1969 to attend college, I was dismayed to find the campus surrounded by the fumes and noise from transportation. I’ve long wanted an electric vehicle, but very few are available for sale and support through Minnesota dealers. 15 years ago, I became aware of the impact of the burning of fossil fuels on our future climate.

I’m approaching 70. Over the course of my life I’ve seen our winters warm and weather become more variable. As temperatures rise, so does the amount of moisture in the air, fueling more frequent and severe storms. On flip side, it dries the land, resulting in more drought. Many do not realize that what emit today can lock our planet into warming for many decades, and likely centuries (due in part to the thermal mass of our oceans).

It even impacts nature. Minnesota is unique in that 3 biomes converge in our state: prairie, temperate deciduous forest (maple and oak) and boreal forest (spruce, fir, pine, birch, and aspen in the NE). This makes our state interesting, but it also makes our forests very susceptible to the impacts of a changing climate. Unless we take decisive action, we are at risk of losing our boreal forests by the end of this century. Can you imagine losing the huge trees in Itasca state park?

For future generations, we need to aggressively reduce our use of fossil fuels, and encourage the electrification of transportation (powered by non-fossil fuel electricity).

OAH Docket No. 71-9003-36416 Name: Dianne Gordon

Zip Code: 55114

Comment:

I support clean car legislation because I think it is an easy, popular early step we need to take to avoid climate change calamity.

OAH Docket No. 71-9003-36416 Name: Liz Deziel

Zip Code: 55118

Comment:

OAH Docket No. 71-9003-36416 Name: Nancy Henke

Zip Code: 56501

Comment:

I wholeheartedly support the Clean Cars Minnesota initiative. Delaying the conversion to low emission and zero emission vehicles from fossil fuel based transportation is foolhardy. The legacy of a sustainable and safe planet that I wish to leave for my children and future generations, is very much in jeopardy. To be able to own and operate a "clean car" of my choice, gives me one more way of contributing to the effort of combating climate change and least trying to secure my children's future.

OAH Docket No. 71-9003-36416 Name: Mark Snyder

Zip Code: 55418

Comment:

Minnesota imports tons of gallons of oil annually while at the same time producing lots of electricity from clean sources from wind and power that’s even cheaper than gasoline – why? Let’s harness the wind and the sun to power our vehicles with Minnesota-grown energy that’s clean to boot! Clean Cars Minnesota is a win-win-win. It will put more EVs on the road, increase the demand for home-grown clean energy, and boost clean energy jobs.

OAH Docket No. 71-9003-36416 Name: Nikolai Andrei Langlois

Zip Code: 55427

Comment:

I support this rule 100%. As a human and Minnesotan I am extremely concerned about air quality and climate / environmental issues. A huge positive step we can take is to lower the amount of stuff we burn and therefore the amount of carbon we release into the atmosphere. This isn’t controversial stuff, really. I did buy an EV around 18 months ago, but ended up having to buy it from NYS (Rochester, specifically) and have it shipped here to where I live in Golden Valley because I couldn’t get it from local dealers. This was and expensive and frustrating experience, though we’ve been very happy with the car. I’m looking forward to spending a good deal more money on a second EV within probably the next five years and would like to spend those dollars here in Minnesota rather than elsewhere. This is a no-brainer.

OAH Docket No. 71-9003-36416 Name: Dawn Blomgren

Zip Code: 55419

Comment:

I think that climate change action is urgent. My car was totaled recently and I wanted to buy a environmentally friendly car to replace it. I preferred to get a plugin hybrid. I was shocked that I simply could not find a plug-in hybrid in Minnesota that fit my needs despite willing to pay a premium for it. I realized that this was because Minnesota did not have sufficient clean car standards and it makes me upset. These cars are all sold in places like California who have stricter standards. I did buy a hybrid but it is not anywhere near the benefits of a plug in hybrid. Ugh!!!

OAH Docket No. 71-9003-36416 Name: Charles Cambell

Zip Code: 55419

Comment:

OAH Docket No. 71-9003-36416 Name: Barbara Reid

Zip Code: 55401

Comment:

We need to do everything we can to make a difference NOW!

OAH Docket No. 71-9003-36416 Name: Yelva Lynfield

Zip Code: 55118

Comment:

Please stop auto exhaust from polluting our air!

OAH Docket No. 71-9003-36416 Name: Linda Seime

Zip Code: 55423

Comment:

We have to be bold in addressing what we can do NOW to reduce carbon in the air. This action alone will affect the health and quality of life for Minnesotans now and in the future. Please pass the Clean Cars Minnesota act!

OAH Docket No. 71-9003-36416 Name: jim giebel

Zip Code: 55337

Comment:

OAH Docket No. 71-9003-36416 Name: Hazel A. Lutz

Zip Code: 55374

Comment:

We've got to create a sustainable economy before it's too late and we all become asthmatic!

OAH Docket No. 71-9003-36416 Name: Majid Shafiei

Zip Code: 55104

Comment:

I support the Clean Cars MN rule proposal. MN economy grew just fine under the fuel economy standards before, and the more we lead on fuel efficiency and EVs, the more opportunity for economic growth in the future. Every dollar a MN driver saves on gas is another dollar that can be spent locally, creating tax revenue and opportunity. EVs have a higher average sale price than outdated ICE vehicles, which generates more sales tax revenue per unit to the general fund, and EV drivers still pay $200 per year toward road maintenance. This proposal has both the right economics and the right values, and if anything does not go far enough. Please, support this proposal.

OAH Docket No. 71-9003-36416 Name: Susan Moses-Zirkes

Zip Code: 55118

Comment:

I currently own a Prius and would like to move to a fully electric car for my next car purchase. I want to be able to have as many choices as possible for myself and other Minnesotans.

OAH Docket No. 71-9003-36416 Name: Laura Millberg

Zip Code: 55408

Comment:

Adoption of the Clean Cars rule is very important to me personally and as a resident of Minnesota. I have asthma, so removing small particulates from the air is important to my health. I want more choices of electric vehicles for the next car I purchase after the Prius I currently own. I think it is very important that the state of Minnesota and its residents do as much as possible to reduce carbon emissions and this rule will help with that goal. I will be more likely to purchase a car from a Minnesota dealer if the dealers make more styles of EVs available to purchase. Adoption of this rule has the opportunity to be a win- win for everyone in Minnesota. We will only get climate change under control if we take steps to reduce carbon pollution from vehicles.

OAH Docket No. 71-9003-36416 Name: Bernard Miller

Zip Code: 55120

Comment:

I have been a Prius owner since 2010 and believe in renewable energy. There is a growing understanding that Earth is at a tipping point regarding climate and that if we don't take bold action now, the results will be disastrous. Minnesota has always been a state which takes good care of its resources and I am encouraged that part of this stewardship would include Clean Cars Minnesota. It truly reflects Minnesota values and I fully support it. As a social justice advocate, I also believe that policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionately harm Minnesota’s most vulnerable and marginalized communities. I strongly urge passing the Clean Cars Minnesota standard.

OAH Docket No. 71-9003-36416 Name: Garry George

Zip Code:

Comment:

We need Clean Car Standards.

OAH Docket No. 71-9003-36416 Name: William Davini

Zip Code: 55417

Comment:

Climate change is the existential crisis of our time and requires immediate and bold action. For decades, fossil fuel companies have worked tirelessly to prevent the adoption of renewable resources. Transition to clean energy and non-polluting vehicles is an immediate imperative and the Clean Cars initiative will assist Minnesotans in getting the choices they need to make this speed this transition. General Motors’ recent commitment to phasing out internal combustion engine automobiles demonstrates that this change is real and is happening now. We need this legislation to position Minnesota favorably with respect to this new reality.

OAH Docket No. 71-9003-36416 Name: Kira Berglund

Zip Code: 55406

Comment:

I support Clean Cars Minnesota. The clean energy sector is growing at a rapid pace, providing many jobs to Minnesotans. At this point clean energy is almost always cheaper than fossil fuels, and we can harness wind and solar energy right here in our state. We need to act to mitigate climate change, and we can only do so if we fully embrace a home-grown clean energy economy that doesn’t harm our communities, air, lakes and forest. Clean Cars Minnesota will help Minnesotans transition to a zero emission future at a faster pace. The time to move away from fossil fuels is now.

OAH Docket No. 71-9003-36416 Name: Jack Hanson

Zip Code: 55417

Comment:

Urgent we cut CO2 emissions for sake of planet. Hybrid cars are most practical and should be subsidized along with EV electric cars. Hybrids can run electric only for most trips. Since hybrids charge battery on deceleration, no electric cost and brakes last a long time, 100,000 miles + My Prius battery is 18 yrs old and still servicable.

OAH Docket No. 71-9003-36416 Name: Mark Goethel

Zip Code: 55418

Comment:

OAH Docket No. 71-9003-36416 Name: Sam Ferguson

Zip Code: 55408

Comment:

I support Clean Cars Minnesota. Communities of color and under-resourced communities disproportionately bear the burden of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionately harm Minnesota’s most vulnerable and marginalized communities.

OAH Docket No. 71-9003-36416 Name: Kristine Sieger

Zip Code: 55406

Comment:

Hello!

Sincerely,

Kristine Sieger

OAH Docket No. 71-9003-36416 Name: Liz Walton

Zip Code: 55419

Comment:

I support Clean Cars Minnesota. It’s long past time we in Minnesota do everything we can to reduce Minnesota’s dependence on fossil fuels and shift to clean, local energy that doesn’t harm our environment and residents. Clean Cars Minnesota will allow more Minnesotans options to purchase a future zero emission or low emission vehicle, and thus reduce our dependence on fossil fuels.

Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally; we need to act immediately to reduce greenhouse gas emissions. Clean Cars Minnesota is a key opportunity to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. We must act now.

Simply put: we must create more consumer choice for Minnesotans; reduce carbon emissions to help meet state goals and improve public health; lower emissions from the transportation sector, which account for the state’s greatest share of greenhouse gases; and provide more electric options at dealerships, making it easier for the growing number of people interested in electric cars to find and buy one.

OAH Docket No. 71-9003-36416 Name: Mark Wright

Zip Code: 55419

Comment:

Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally; we need to act immediately to reduce greenhouse gas emissions. Clean Cars Minnesota is a key opportunity to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Ashwat Narayanan

Zip Code: 55404

Comment:

Transportation is bringing us to the precipice of climate disaster. This rule is one important tool to help mitigate this.

OAH Docket No. 71-9003-36416 Name: Eliza Stougaard

Zip Code: 55416

Comment:

OAH Docket No. 71-9003-36416 Name: Gregg May

Zip Code: 53703

Comment:

I want to buy an EV and might have to drive to Minnesota to do so, please consider the impact from out-of-state shoppers.

OAH Docket No. 71-9003-36416 Name: Ali Renk

Zip Code: 55413

Comment:

Hi there! I'm writing in support of the Clean Cars Minnesota standard. Air pollution is a serious issue in our state and the health of Minnesotans hangs in the balance. Harmful air pollution in my hometown likely contributed to my sister's asthma diagnosis, and I don't want this harm inflicted into the future. Clean Cars Minnesota is a major step toward cleaning up our air.

Communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionally harm Minnesota’s most vulnerable and marginalized communities. Please make this change happen!

OAH Docket No. 71-9003-36416 Name: Alex Vasatka

Zip Code: 55419

Comment:

I support Clean Cars Minnesota. I was recently in the market to purchase a vehicle abd was frustrated by the fact that many electric cars are not available in MN because they go to other states with standards. Minnesotans deserve to be able to access all the vehicles available in the U.S. marketplace when they’re deciding to buy or lease. Right now, many electric vehicles don’t even make it to Minnesota dealerships because they go straight to states like Maryland and Oregon with clean car standards - that’s just not fair. Minnesotans should be able to buy whichever car they want.

OAH Docket No. 71-9003-36416 Name: Ann Manning

Zip Code: 55416

Comment:

I support a Clean Cars standard because I want more vehicle choice. I want access to all kinds of cars and trucks, including a wider variety of EVs. Right now, many different types of EVs aren’t even sold in Minnesota. Instead, they go to one of the other states that have adopted a Clean Cars standard. In the next few years, companies like Ford, GM, Tesla, Rivian, and others have plans to release electric pickup trucks and SUVs. These vehicles are made for places like Minnesota, and we should have access to them just as much as Californians.

OAH Docket No. 71-9003-36416 Name: Anna Rockne

Zip Code: 55406

Comment:

I strongly support changing air pollution standards to require lower-emission vehicles in Minnesota. This benefits people, animals and plants and makes our future more sustainable.

OAH Docket No. 71-9003-36416 Name: Adam Jass

Zip Code: 55106

Comment:

OAH Docket No. 71-9003-36416 Name: Tally Venjohn

Zip Code: 55343

Comment:

I am in strong support of low-emission vehicle and zero-emission vehicle air pollution standards. For generations to come!

OAH Docket No. 71-9003-36416 Name: Douglas Bruce

Zip Code: 55438

Comment:

It is long past time for this. Make it happen now!

OAH Docket No. 71-9003-36416 Name: Emily Greene

Zip Code: 55104

Comment:

I want cleaner air for all Minnesotans, for our health and the health of our planet. I want to reduce our dependence on fossil fuels to help combat climate change.

OAH Docket No. 71-9003-36416 Name: Craig Johnson

Zip Code: 55102

Comment:

I grew up and have spent most my life in Minnesota. While I'm a Minneapolitan, I also have been active in the greater part of life in Minnesota's outdoors. I've spent years actively traveling rivers, lakes, climbing, skiing, canoeing, ice climbing, camping and fishing—so I've noticed the changes occurring not by an occasional week of warm, but the record river levels usually only a once in 100 or 500 year occurrence, now happening multiple times in a 5-10 yr period. Record temps and rains in March that should be in late April or May. Lake ice that goes out far too soon and winter that never really feels like it was here. It's moved ice climbing events that I volunteer or teach for, it's canceled trips, and hurt small towns who love winter travelers and have invested in winter activities. It's time we do more to collectively slow or reverse this trend.

The city kid in me thinks about the studies I've read about children who do worse in school if they live near large amounts of traffic pollution (income was ruled out as a factor). While very active, I grew up with sports induced asthma and sometimes can tell when we have high pollution days. Then there is the noise. Car noise along with so much else in the city only makes city living more stressful. I realize biking and mass transit isn't always a practical solution for many in greater Minnesota or in the winter, but if climate change is your major concern—or just are sick of noise and pollution impacting the health of our communities—why wouldn't we move to cleaner, better methods of transportation? This seems like a simple problem that can be solved by moving us all forward through incentives and legislation. We have the technology and we have ability, let's do this before we regret it. When we realize Minnesota isn't Minnesota anymore weather and climate wise we will be sorry. Winter is a part of us. It's shaped a strange culture of shovel wielding, snow blowing, plow pushing people who sometimes wear plaid. Let's keep Minnesota cool.

OAH Docket No. 71-9003-36416 Name: Kevin Evans

Zip Code: 56157

Comment:

I do not support mn clean cars, it will raise cost to all of us in rural MN and the benefits of this movement are much over rated.

OAH Docket No. 71-9003-36416 Name: Pat Vasatka

Zip Code:

Comment:

I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. We can tell that our winters are already warming faster and our northern forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. This is bad for our environment and our citizens. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Julian Ryba-White

Zip Code: 55407

Comment:

OAH Docket No. 71-9003-36416 Name: Jean Muller

Zip Code: 55102

Comment:

OAH Docket No. 71-9003-36416 Name: Steve Best

Zip Code: 56098

Comment:

OAH Docket No. 71-9003-36416 Name: Anne Fisher

Zip Code: 55108

Comment:

We want to buy a car that is not sold in MN because we do not have the emission standard that 14 other states and Washington DC already have. If you pass this then we will not have to go to another state to get our vehicle. It is an embarrassment that MN has not adopted the Clean Car standards

OAH Docket No. 71-9003-36416 Name: Paul Erdmann

Zip Code: 55438

Comment:

The time is now- let's get out of the industrial stone age! I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. I see it happening everywhere! Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. I want more choices when I go to the dealership looking for EVs. Let's be Minnesota and lead from the front!

OAH Docket No. 71-9003-36416 Name: Rebecca Cramer

Zip Code: 0

Comment:

I am a progressive voter and a Minneapolitan who once lived near the intersection of Snelling and Univ Ave in St. Paul. We need better air quality in the metro and cleaner cars and trucks are the way to go. Municipals should replace gas-powered vehicles with electric ones where that is feasible and people should be incentivized to choose public transportation. Climate change is here and is a crisis that we must not ignore for the sake of our health and for a liveable future. The twin cities should be a leader in the clean car and public transportation issues.Thanks.

OAH Docket No. 71-9003-36416 Name: Tony Cuneo

Zip Code: 55812

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: William Chadwick

Zip Code: 55345

Comment:

Please adopt the Clean Cars Minnesota standards. Emissions from combustion engine vehicles are devastating our health and the future of the planet. I am an EV owner (on my second Nissan Leaf) and they are wonderful cars and I feel I am doing my part to save the planet for my grandchildren. Government should do all in its power to reverse climate disruption. Thank you!

OAH Docket No. 71-9003-36416 Name: Dave Zentner

Zip Code: 0

Comment:

I fully support the necessary next steps as we transit to a sustainable environment. Auto are major carbon emitters. Government can help achieve a sustainable future by requiring the auto industry to provide more choices and also serve as public educator on this subject. More choice are a positive contributor to lower prices for electric autos and hybrid vehicles. Dave Zentner

OAH Docket No. 71-9003-36416 Name: Janiece Watts

Zip Code: 55117

Comment:

I support Clean Cars Minnesota. Communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionately harm Minnesota’s most vulnerable and marginalized communities. I’m an EV owner and I support Clean Cars Minnesota. Driving an electric vehicle in Minnesota is a freeing experience. You can go from point A to point B without worrying about harmful tailpipe emissions and since EVs don’t have internal combustion engine they warm up much faster in the winter and have considerably lower maintenance costs. Clean Cars Minnesota would give the 6 in 10 prospective car buyers in Minnesota who are interested in electric vehicles the opportunity to actually see and test drive a much wider variety of makes and models - many of which currently don’t even make it to our state because they go to states with clean cars standards. Buying a car or truck is a big choice and Minnesotans deserve the chance to weigh all options. I know how hard it can be to find an EV that I could afford, in a great condition while thinking through how my travel habits may be affected. Having more options that are more affordable is just one way that MN can take a big step in reducing air pollution and GHG emissions that are harming our planet and health. Pass the Clean Cars Rule and then do more to address environmental and climate injustice!

OAH Docket No. 71-9003-36416 Name: Sara Wolff

Zip Code: 55105

Comment:

OAH Docket No. 71-9003-36416 Name: Richard Wheeler

Zip Code: 55438

Comment:

I am the Board President of the Bush Lake chapter of the Izaak Walton League of America. I am writing in favor of the Minnesota Clean Car rules drafted by the MPCA, Minnesota Pollution Control Agency.

These rules will enable Minnesota to join California, District of Columbia and 14 other states (AZ, CT, ME, MD, MA, NJ,NM, NY, OR, PA, RI, VT and WA) in requiring auto manufacturers to bring more EVs. and hybrids and fuel efficient models to Minnesota auto dealerships, so that we have more choices of clean and zero emissions cars when making our buying decisions.

I feel that this is a very important issue because:

- Carbon emissions from gas-powered autos are the largest source of carbon emissions in our state. EVs and hybrids have much lower/zero carbon emissions. We need to have more choices to see and test-drive these models. - Gas powered autos are a major source of nitrogen oxide and particulate matter air pollution that cause disease and early death, especially in low income neighborhoods located near freeways. EVs and hybrids have much lower/zero pollution from these sources. - - Much of the gasoline that powers cars in MN comes from oil mined in the Canadian Tar Sands. It is the dirtiest fuel on earth! As citizens and consumers, we need a choice of clean cars that don't run on and/or support these extreme fuels and the leaky pipelines that threaten our clean water.

Thank you for your attention in this climate critical matter.

With Gratitude,

Richard Wheeler

OAH Docket No. 71-9003-36416 Name: Doug Heuer

Zip Code: 55337

Comment:

I love the outdoors and I support Clean Cars Minnesota. Minnesota is a great place to get outdoors but climate change is threatening our way of life. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally, so we need to act NOW to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to slowing climate change and reducing greenhouse gas emissions from transportation. We must act now before the changes we’re witnessing today accelerate beyond the tipping point.

My next vehicle will be an EV, and I'd like some choices, and the infrastructure to support it so I can get outdoors in our great north woods. Think of the green jobs for northern MN to build out that infrastructure; a just transition from a dirty fossil fuel economy to a sustainable future.

OAH Docket No. 71-9003-36416 Name: Colin Leuthold

Zip Code: 55414

Comment:

February 12, 2021

To Commissioner Laura Bishop

Minnesota Pollution Control Agency (MPCA)

520 Lafayette Road North

St. Paul, MN 55155

Regarding the notice of intent for the state of Minnesota to adopt Vehicle Greenhouse Gas Emissions Standards - Clean Cars Minnesota. “Clean Cars Minnesota Proposed Rule (aq-rule4-10n) & Clean Cars Minnesota Notice of Intent to Adopt Rule With a Hearing (aq- rule4-10o).”

From Colin Leuthold

Thank you for the opportunity to comment on the proposed rule above the state of Minnesota is considering adopting. My name is Colin Leuthold, and I am currently a senior at the University of Minnesota studying Ag. & Food Business Management with an emphasis in Financial Analysis and Business Management. As someone who was born and raised in the heart of Minnesota farm country I am both encouraged and concerned about the impact the adoption of this rule could have on different parts of the state.

After reviewing the proposed rules, aq-rule4-10n & aq-rule4-10o there are several aspects that I support. I am also encouraged that Minnesota is the first Midwestern state to join with fourteen other states in the adoption of the California Emissions Standards. However, there are key parts of the proposed rule that I am concerned with that may have unforeseen consequences, especially on farming communities that drive one of Minnesota’s main industries, agriculture.

OAH Docket No. 71-9003-36416 I strongly support the overall idea of reducing air pollution and establishing vehicle standards as aimed at in the proposed rule.

Since the passing of the Clean Air Act in 1970, the United States has set a precedent for valuing the importance of clean air for its citizens to breathe. However, it can be understood that since the 1970’s there has been an increase in the amount of vehicles on the roads as the population has increased and access to vehicles has become more widely available. The transportation sector has become the largest source of greenhouse gas emissions in the United States (Environment America Research & Policy Center). This proposed rule “Clean Cars Minnesota” is a necessary part of the solution in helping to reduce the output of dangerous greenhouse gas emissions that are damaging to the planet. Not only does the establishment of vehicle standards help to curb greenhouse gas emissions, it has an economic benefit to everyday Americans. If these standards, such as the one proposed, were to be implemented by 2025, it is estimated that it could save Americans $3,200 per car, and $4,800 per truck over the course of the lifetime of the vehicle (Environment America Research & Policy Center).

I support the Zero Emissions Vehicle (ZEV) standard requiring that a certain percentage of the cars sold in Minnesota be electric.

If there was any worry about local government overreach in adopting these new rules and subjecting all Minnesotans to a hasty transition associated with the proposed rules, let them be put to rest. The idea proposed by the ZEV standard would create an incentive for auto manufacturers and dealers to offer electric vehicle options to consumers. Furthermore, on the Minnesota Pollution Control Agency website it states that no one under the new rules would be required to purchase an electric vehicle. In fact if the new rules are adopted and implemented by the target year of 2025 only about 8% of new vehicle sales that year would be either electric or partly electric (Sierra Club).

I support the establishment of the Zero Emission Vehicle credit bank.

Under the proposed rule Minnesota would establish a system of credits that would provide automakers an incentive to not only sell electric vehicles, but provide more electric vehicle models for consumer purchase. However, I register concerns that such a system has the potential for a slowdown in the process of consumers purchasing more electric vehicles. In California there is a concern among progressive groups that if an

OAH Docket No. 71-9003-36416 automaker builds up more credit than is required in electric vehicle sales, auto dealers will use the extra credits to fulfill obligations in future years (Arlington). In other words the auto industry will potentially use any extra credits they have built up to offset required electric vehicle sales in future years and in turn sell fewer cleaner cars. There is a concern that this loophole will slow down the sales of electric cars and in turn allow for more greenhouse gases to be released that affects the wellbeing of the planet. However, this concern has yet to come to fruition. Contrary to this belief electric vehicle adoption has only grown in California, with 108,977 vehicles in 2014 up to 566,902 as of 2019 (CA Gov). While I understand these concerns, I agree that if Minnesota is to adopt the proposed rules it should be with the establishment of the ZEV credit bank. Being the first Midwestern state to undertake these new rules will be a challenge. If the tightening of the allowances provided under the ZEV credit bank to automakers could possibly jeopardize the sales and incentive to sell electric vehicles, I believe that allowing more leeway under the credit bank to be worth it.

I strongly support the exclusion of farm vehicles & equipment from the new proposed standards.

Minnesota is in the heart of the corn belt, or the midwestern states that produce a large portion of grain, corn, and soybeans for export. Agriculture is one of Minesotas biggest industries, and is at the heart of many communities throughout the state. I myself come from a farming background, with all but my parents and aunt who do not either own or operate their own farms. In 2019, the agriculture industry ranked third in largest emitter of greenhouse gas emissions behind transportation and electricity (Dunbar). Agriculture production in Minnesota produces roughly $6.1 billion dollars annually towards Minnesota’s GDP (MN DEED). I believe that subjecting farmers and their livelihoods to a deadline to have cleaner vehicles and equipment by 2025 to be unrealistic and fully support their exclusion from the new rules. However, John Deere, major producer of tractors and other farm equipment, has recently stated that they “believe in electric tractors. 100%.” The interview given in March of 2020 did state that while John Deere does believe in and is developing tractors and other equipment to be electric it would be about 10 years before market introduction along with market penetration of electric tractors and other electric farm equipment (Future Farming). Furthermore, there is cause for concern when examining how long an electric tractor battery will hold a charge. Typically a farmer can expect to not have to worry about filling up their tractor with fuel for about 10-12 hours while in use (Campbell). Compared to the electric tractors sold by

OAH Docket No. 71-9003-36416 Soletrac which says it’s tractor batteries can hold a charge up to 3-6 hours depending on the load (Campbell). This is not feasible for farmers especially during harvest time when farm equipment especially tractors are used for much of the day. This is why I applaud and support the MPCA’s exclusion of farming equipment from these proposed new rules. I believe time must be allowed for development of new technologies to provide the easiest transition possible for the state’s farming communities.

I support and encourage the continuous review of Clean Cars Minnesota.

I firmly believe in the proposed rules above for the reasons I have listed. However, I strongly believe that an annual review of these standards is necessary to analyze how the standards are affecting not only differing parts of the state, but Minnesota as a whole. Furthermore, I support the idea of incremental increases in the required number of sales of electric vehicles each year. However, I would be interested in the data that would show how the standards, if implemented, are affecting different parts of the state. The population of Minnesota is spread between urban and rural areas, with 55% of the state's population living in the seven county region that makes up the Twin-Cities metropolitan area (MN Compass). If the data suggested that the proposed standards are having a negative impact on sparsely populated parts of the state compared to the heavily populated metro, would the MPCA be prepared to create exemptions to the rule for rural farming communities? While this is a hypothetical, it supports the underlying argument that I stated in support of the continued review of Clean Cars Minnesota and the adjustment of regulations if deemed necessary.

Sincerely,

Colin Leuthold

Works Cited

Arlington: Inside Washington Publishers. “Activists Fear California ZEV-Credit Banking Plan May Slow Vehicle Sales.” Jan 8, 2010 (Vol. 21, no. 1) - Present. https://search - proquest-com .ezp1.lib.umn.edu/docview/1008895940?accountid=14586&pq-origsite =primo

OAH Docket No. 71-9003-36416 Bains, Anjali. “What's Up With ‘Clean Car Standards’ and Why Do They Matter for Minnesotans?” Sierra Club, 13 Aug. 2020, www.sierraclub.org/minnesota/blog/2020/07/ what-s-clean-car-standards-and-why-do-they-matter-for-minnesotans#:~:text=Clean Cars Minnesota will not stop you from buying a,in Minnesota would be electric.

California Energy Commission. “Zero Emission Vehicle and Infrastructure Statistics” https://www.energy.ca.gov/data-reports/energy-insights/zero-emission-vehicle-and- charger-statistics

Campbell, Lindsey. “Going Green: Can Electric Tractors Overtake Diesel?” Modern Farmer, 28 March 2020, https://modernfarmer.com/2020/03/going-green-can-electric- tractors- override-diesel/.

Dunbar, Elizabeth. “Transportation, Ag Hold Back Minn. on Emissions Goals.” MPR News, MPR News, 5 Jan. 2019, www.mprnews.org/story/2019/01/05/transportation-agriculture- edge-out-electricity-minnesota-largest-emissions-sources.

Environment America Research and Policy Center. “The Benefits of the Clean Car Standards.” 29 Mar. 2018, environmentamerica.org/reports/amc/benefits-clean -car- standards.

Koerhuis, René. “John Deere: 'We Believe in Electric Tractors. 100%'.” Future Farming, 12 Mar. 2020, www.futurefarming.com/Machinery/Articles/2020/3/John-Deere-We-believe - in-electric-tractors-100-552869E/.

MN Compass. “All Minnesotans.” Minnesota Compass, https://www.mncompass.org/topics /demographics#:~:text=About%2055%25%20of%20Minnesota%20residents,Twin%20Citi es%20seven%2Dcounty%20region.

MN DEED. “Economic Impact.” Minnesota Department of Employment and Economic Development, https://mn.gov/deed/ed/minnesota-industries/manufacturing/impact/.

OAH Docket No. 71-9003-36416 Name: Sandra Hastings

Zip Code: 55410

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Dean Borgeson

Zip Code: 56442

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Anne Rykken

Zip Code: 55108

Comment:

I’m a Minnesotan who cares about our natural resources, and know that reducing greenhouse gas emissions from cars and trucks is a way of combatting climate change.

OAH Docket No. 71-9003-36416 Name: David Pipho

Zip Code: 55811

Comment:

As an ED physician in outstate Minnesota I have to drive to multiple EDs to cover shifts. We need electric car options here in northern Minnesota to minimize the environmental and health impacts on our rural citizens. First do no harm applies to how we treat the environment and by not having access to vehicles that limit the effects on that around us we continue to harm future generations.

OAH Docket No. 71-9003-36416 Name: Susan Spannaus

Zip Code: 55426

Comment:

I believe in Clean Cars MN but I also believe we need to ensure that we are not passing laws that are going to adversely impact those that are on limited income to make changes to there vehicle or purchase vehicles that comply when there is no way they can do this based on income.

OAH Docket No. 71-9003-36416 Name: Gerry Fuller

Zip Code: 55105

Comment:

OAH Docket No. 71-9003-36416 Name: Jim Wolf

Zip Code:

Comment:

OAH Docket No. 71-9003-36416 Name: Bob Pollock

Zip Code: 55077

Comment:

I’m a farmer, Botanist and conservationist,,,

Climate Change is Real!! Act!!

OAH Docket No. 71-9003-36416 Name: Beverly Westerberg

Zip Code: 55347

Comment:

We are a critical place where we need to look to providing clean energy. We don’t have much time before the damage we are doing using fossil fuels is irreparable. We need to take action now so we have a clean and healthy world for our children.

OAH Docket No. 71-9003-36416 Name: Rick Gravrok

Zip Code: 55416

Comment:

I am a senior citizen who loves our planet and I want our children and our children’s children to have a livable future so please let’s go electric wherever we can and also make that electricity come from green sources! - not fossil fuels. Thank you very much.

OAH Docket No. 71-9003-36416 Name: Ross Sutter

Zip Code: 55401

Comment:

A couple of years ago I was shopping for a used car and the salesman said that in five years they will mostly be selling electric vehicles--they're cheaper to run and maintain.

OAH Docket No. 71-9003-36416 Name: Jennifer Munt

Zip Code: 55343

Comment:

We need clean cars. We can’t buy electric vehicles if Minnesota dealerships don’t sell them.

OAH Docket No. 71-9003-36416 Name: Mark Lokowich

Zip Code: 55436

Comment:

1st) Nothing inherently clean with electric! 2nd) Nothing inherently cheaper on the pocketbook with electric. 3rd) The specter of blackouts and brownouts from a "single" source of energy is not very smart. 4th) Let market forces continue to bring us what we demand , not a government mandate. 5th) You are creating a electric boondoggle! Quit while your ahead!

OAH Docket No. 71-9003-36416 Name: Mary Ludwigson

Zip Code: 55987

Comment:

I am with Governor Waltz in making sure our state is doing everything possible to insure our next generations (my kids and grandkids) have clean air and water. Our family has purchased hybrid vehicles from the get go knowing that we must all do our part to save our planet. We even put in roof top solar with the help from our state. When trying to find a plug in car here in Minnesota the choices were very limited for our family. We needed a hatch back and the only car we found was the Ford CMAx energy and they have stopped making those so we can’t even get another. We are retired senior citizens who could choose to move to a state that won’t tax us as suggested by our CPA but we believe in our state that is a leader in health, education and environmental policies. My husband and are ordinary citizens who are so very concerned about our planet. We support all efforts to lead the nation in environmental concerns. Do what is right!

OAH Docket No. 71-9003-36416 Name: Larry Bogolub

Zip Code: 55105

Comment:

OAH Docket No. 71-9003-36416 Name: Gregg Koch

Zip Code: 56036

Comment:

Please don’t add more burdensome regulations we already have plenty of regulations on clean air.

Allow people to make their own choices

OAH Docket No. 71-9003-36416 Name: Liam Fisher

Zip Code: 55057

Comment:

The fact that we've had the ability to make hybrid and electric cars for many years, and they haven't already overtaken gas guzzling cars is bonkers! The future of the planet is at stake and drastic change needs to happen NOW!

OAH Docket No. 71-9003-36416 Name: Barry Drazkowski, President Will Dilg Chapter IWLA

Zip Code: 54629

Comment:

1. We have all been warned of the dire effects of climate change for the past 30 years. We've talked about the economic impacts of emission control, of modifying our vehicles to reduce emissions, and we have done nothing except to talk about the impacts of action. Here we are, 30 years later, no clean emission standards, and carbon dioxide atmospheric concentrations at 409 ppm. Climate change is here, its with us, and we as a society are feeling its multi billion dollar effects every year. Its not going away and its getting worse. Action is the only responsible strategy. Government is responsible for regulatory change as reflected in this action. Voluntary action does not work, relying on corporations does not work, only aggressive regulatory action is going to begin to make a difference. So yes, I support this bill.

2. The impact that must also be discussed and addressed in this action is one of social justice. The impacts of mining the metals to create this technology, whether its the copper, palladium, or others, all bring with them the specter of social injustice. We have long been aware of child slavery, and other serious social justice issues with the mining of these required metals. Action to grow zero emission vehicle use and manufacture, should be accompanied with action to demand social justice in their manufacture. Every vehicle should be accompanied with a clear description of where its components and their source metals come from and what the companies are doing to create social equity in their extraction.

OAH Docket No. 71-9003-36416 Name: Erich Rutten

Zip Code: 55104

Comment:

I live on the Interstate frontage road (Saint Anthony Street) at Lexington in Saint Paul. I experience air quality very acutely. I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Jim Bambenek

Zip Code: 55987

Comment:

OAH Docket No. 71-9003-36416 Name: John Steinworth

Zip Code: 0

Comment:

OAH Docket No. 71-9003-36416 Name: Don Kern

Zip Code: 54011

Comment:

I am a hard core environmentalist but a common sense person. Let's let the market and public buying drive these decisions, not legislative mandates with terrible economic second d order effects. Much more important and beneficial would be getting India and China on board! Let's not kill Ameran strength with kneejerk mandates. A strong economy means a strong environment.

OAH Docket No. 71-9003-36416 Name: Faith Wicklund

Zip Code: 56082

Comment:

I am a grandparent who wants my grandchildren and their children to have the marvelous outdoor experiences on this beautiful planet that I've had throughout my life. This requires drastically reducing green house gases. Supporting electric cars will help.

OAH Docket No. 71-9003-36416 Name: Jim Tjepkema

Zip Code: 55417

Comment:

It is essential to move forward as quickly as possible with strong legislation to support converting to the use of electric cars. We are already very late doing this with the harmful effects of climate change already occurring and increasing. This includes increases in severe weather in our state which will continue to increase and become even more serious if we don't do every thing we can to reduce the use of fossil fuels.

OAH Docket No. 71-9003-36416 Name: Susan Imker

Zip Code: 55040

Comment:

Thank you for your time and consideration of my comments.

OAH Docket No. 71-9003-36416 Name: Timothy Johnson

Zip Code: 55444

Comment:

OAH Docket No. 71-9003-36416 Name: Stephen Dale

Zip Code: 55438

Comment:

I care about climate change and pollution. I have and EV and Solar panels because I believe that we must reduce vehicle carbon and other pollutants for everyone's benefit.

OAH Docket No. 71-9003-36416 Name: William Christ

Zip Code: 55113

Comment:

It is imperative that Minnesota mandates clean / no emissions from automobiles.

OAH Docket No. 71-9003-36416 Name: Arnold London

Zip Code: 55118

Comment:

OAH Docket No. 71-9003-36416 Name: Dwight Smith

Zip Code: 55033

Comment:

The reasons for adopting clean car rules for Minnesota are too numerous to list in a brief comment. Our state is in the process of a human-caused warming trend that, at this point, is irreversible. Our only hope is to mitigate the worst effects by taking reasonable action to reduce carbon emissions. The largest source of emissions is exhaust from transportation, and, logically, the only way to reduce greenhouse gas emissions is to adopt measures to mitigate these emissions. Initiatives are already underway to reduce emissions from electric generation, the second largest source. We can no longer ignore the responsibility of our government to take action in this regard. It simply cannot be left to individual initiative. This latter alternative has been demonstrated to be ineffective.

Simply put, the only reasonable course for the state's leadership is to begin the process of changing our entire transportation paradigm, from cleaner vehicles to more robust public transit options. It simply makes sense to begin the process now before it becomes a full-blown crisis. That crisis isn't far away. Action needs to be taken now.

OAH Docket No. 71-9003-36416 Name: Lani Jacobsen

Zip Code: 55439

Comment:

I am a Minnesotan who cares about our natural resources and preserving them for the next generations. I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late. I am ready to buy an EV - let's get everyone on board for clean air & water.

OAH Docket No. 71-9003-36416 Name: Aimee Haag

Zip Code:

Comment:

If we can make strides toward cleaner energy and increase our social/environmental respect we should. Period. Let’s lead. I refuse to accept the rhetoric that greater regulations and “progress” lead to profit loss and lack of consumer choice. We can and will find ways to benefit as a great state from better standards.

OAH Docket No. 71-9003-36416 Name: Janet berryhill

Zip Code: 55113

Comment:

I see all the terrible results of climate change: fires, extra hurricanes, weather weirding. It is time to go bold. I wanted to be able to buy a Clarity last year when I needed a new car, but they had none at the honda dealer to try! Give us more choice please! Thank you.

OAH Docket No. 71-9003-36416 Name: Emily Mashuga

Zip Code: 55120

Comment:

I’m a progressive and believe the time to make bold changes to save our climate is now.

OAH Docket No. 71-9003-36416 Name: Clifton Ware

Zip Code: 55421

Comment:

OAH Docket No. 71-9003-36416 Name: Michelle Lechner-Riehle

Zip Code: 55337

Comment:

Choking on diesel fumes from the waiting school busses & vehicle exhaust from I94, one winter morning, I walked into an elementary school in St. Paul to help promote kindergarten readiness for the local children. My trachea and lungs burned for days after that event- I can only imagine what harmful effects repeated exposure has on the children. Please make clean cars and busses a priority - if it's possible then we must do it. Respectfully, MLR

OAH Docket No. 71-9003-36416 Name: Deanne Roquet

Zip Code: 55803

Comment:

It is important to me that we continue to work towards keeping our Minnesota environment clean and high quality for myself, my family and future generations. I am very glad Gov. Walz is supporting the Minnesota environment and I add my voice in support of the Clean Car Standards.

OAH Docket No. 71-9003-36416 Name: Jennifer Meadows

Zip Code: 55949

Comment:

Have 56K electric mls on our car. Charging infrastructure desperately needs more stations, especially in rural MN. Nearly ran out of power before I could make it to nearest charger one day recently. 2 of 3 charging spots were occupied, so it could have ended badly if the last spot was taken or blocked.

OAH Docket No. 71-9003-36416 Name: Tom Brinkman

Zip Code: 55906

Comment:

THE CASE FOR SPACE SHIP EARTH:

Recently I realized that Planet Earth is, in effect, Space Ship Earth! Our Good Ship Earth is nature-made, not man-made. But all of these ships travel through space. All have systems for air, water, food, and require leadership and a competent crew. Man-made vehicles are powered by batteries and free solar. But Space Ship Earth has been powered primarily by petroleum and coal—only recently with nuclear and rapidly growing wind and solar power (Exception: plant photosynthesis is powered fully by solar).

Man-made space vehicles are loaded and replenished quickly, in the blink of an eye by Nature’s timeframe. But Space Ship Earth’s resources (supplies) were stocked over millions of years, and natural replenishment requires many thousands of years—Nature does not adapt in the blink of an eye. Good Ship Earth’s leadership and crew preparation has historically been more inwardly focused on “internal” operations, without much perspective on long term ecological survival issues during our space travel. And what about the passenger list? Man-made space vehicles will carry passengers within a decade. But Good Ship Earth’s passengers already number 7.5 billion, with supplies for only 2-3 billion at America’s current standard of living.

During the next 30 years “God speed John Glenn” will become “God speed” to American and world leaders,…but with an urgent need for good luck, wisdom, and enlightenment.

“…it doesn’t take many words to speak the truth.”---Chief Joseph, Nez Perce

“…all things are connected. Whatever befalls the earth befalls the children of the earth.”-- -Chief Seattle, Suquamish and Duwamish

“We are a part of nature, not apart from her.”---Native American belief

OAH Docket No. 71-9003-36416 Name: Andrew Montain

Zip Code: 55113

Comment:

Let’s lead for a better future!

OAH Docket No. 71-9003-36416 Name: Murray Smart

Zip Code: 56211

Comment:

Clean Cars and Clean Energy are the future. Dirty Cars and Dirty energy is the past. We can no longer afford to just accept and perpetuate the status quo. We are at a tipping point of what we are going to do about our future. The future of all life on our planet is at stake. Ecocide is a real danger if we continue on this path. We can change what we are doing and we can do it in a way that will benefit us all. Just like we now have computers in our hands (cell phones) we can and must develop motor vehicles that are environmentally friendly. If we can create cell phones we can do this. We can and must fix this. We have spent way too much time and money subsidizing Dirty Energy. Our focus now must be on developing and using Clean Cars and Clean Energy for the health of all life on our home - the earth.

OAH Docket No. 71-9003-36416 Name: Laurel Bangs

Zip Code: 55406

Comment:

OAH Docket No. 71-9003-36416 Name: Peg Challgren

Zip Code: 55124

Comment:

OAH Docket No. 71-9003-36416 Name: Ogren, Lorrie

Zip Code: 53405

Comment:

Its past time we take strong action on clean car standards- with ecosystems collapsing, we have no more time to waste! Step up clean car standards asap!

OAH Docket No. 71-9003-36416 Name: Joan Bindner

Zip Code: 55068

Comment:

I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.I support Clean Cars Minnesota. The federal government has been reversing the progress made on reducing air pollution in our country. If Washington won’t lead, Minnesota will and Governor Walz has shown strong leadership in pushing for innovative solutions to the climate crisis. Clean Cars Minnesota would keep Minnesota on the right track for slowing climate change and reducing air pollution. Minnesota is in a toxic relationship with Big Oil and it’s time to cut ties. We need to do everything we can to reduce Minnesota’s dependence on fossil fuels and transition to clean, local energy that doesn’t harm our lakes, forests, air, and people. With Clean Cars Minnesota more Minnesotans will transition to a zero emission or low emission vehicle when they buy or lease their next car or truck, and thus reduce our dependence upon fossil fuels.

OAH Docket No. 71-9003-36416 Name: Lee Swenson

Zip Code: 55431

Comment:

Autos, trucks etc. are the No.1 source of particulate and CO2 and nitrous oxide polution on our planet. Going to E.V.s and hybrids are REALLY needed for most every consumer of private and commercial vehicles as I see it.

Getting to much lower emisions from all future vehicle sales is really an existential effort. Are we going to clean up and sustain a healthy breathable atmosphere for all creatures including us humans or are we going to go the way of the do-do bird because or unsustainable and carbon heavy choices. Thanks for this opportunity.

Lee Swenson - Minnesota resident and global citizen

OAH Docket No. 71-9003-36416 Name: Catherine Fouchi

Zip Code: 56055

Comment:

I am a Minnesotan who cares about our natural resources and spends a lot of time outdoors. A key strategy for protecting the clean air and amazing resources we have is to reduce pollution by gas burning cars. We need clean car rules for MN. Please support this legislation. Additionally there will be many human health benefits if we move to cleaner cars. I am a business owner, also. The clean car initiative is in line with our business plan and goals.

OAH Docket No. 71-9003-36416 Name: Zach Johnson

Zip Code: 55113

Comment:

OAH Docket No. 71-9003-36416 Name: Hendrik Svien

Zip Code: 55406

Comment:

OAH Docket No. 71-9003-36416 Name: Jean Abbott

Zip Code: 55044

Comment:

I am interested in purchasing an EV for many reasons and I strongly support Clean Cars Minnesota. We Minnesotans deserve to be able to access to all the vehicles available in the U.S. marketplace Right now, many electric vehicles don’t even make it to Minnesota dealerships because they go straight to states like Maryland and Oregon with clean car standards. Minnesotans should be able to buy whichever car they want. Pass Clean Cars Minnesota and offer us a broader range of EV choices!

OAH Docket No. 71-9003-36416 Name: JL Charrier

Zip Code: 55391

Comment:

I'm grateful that Governor Walz has been moving MN to cleaner energy. We need to continue growing away from fossil fuels and toward clean energy.

OAH Docket No. 71-9003-36416 Name: Deb Ullrich

Zip Code: 56001

Comment:

It's time to move away from dependence on fossil fuel.

OAH Docket No. 71-9003-36416 Name: Jennette Turner

Zip Code: 55403

Comment:

WInter is so different now than it was when I was little, 40+ years ago... we are already seeing the effects of climate change, and it's only getting worse. Please help. Please pass Clean Cars MN!

OAH Docket No. 71-9003-36416 Name: Anita Anderson

Zip Code: 55803

Comment:

I support Clean Cars Minnesota for many reasons. I love to go to the Boundary Waters and I want generations after mine to continue to enjoy the boreal forest which is threatened by climate change. I want people to keep enjoying our winter way of life, with safe ice on the lakes. I want people who depend on wild rice for subsistence to be sure this valuable resource is protected. I have seen the damage and increase in insurance costs due to major storm events and know how climate change hurts our economy. I work in the public health sector and climate change impacts on health are a steadily increasing challenge to our work. I want to protect our water resources, our Minnesota heritage.

Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally, so we need to act NOW to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to slowing climate change and reducing greenhouse gas emissions from transportation. Let’s act now before all the changes we’re already seeing become permanent. I own an all electric vehicle, and know what a great option electric cars are for many drivers. They aren't the only piece, but are critical to moving forward. Let's support the EV infrastructure and make them available to more drivers.

Sincerely,

Anita Anderson

OAH Docket No. 71-9003-36416 Name: Brian Wicks

Zip Code: 55346

Comment:

I am ready, my family is ready, my community is ready, my city is ready, my state is ready, my country is ready, my world is ready. Ready to tackle climate change, ready to leave a lighter trace, ready to build a more sustainable future for our children.

I'm a car guy, I'm an engineer who has worked in the automotive industry. I've designed engine components used in millions of engines. Engines that powered our development as a nation and a world.

But as an engineer I can understand trends, and technologies, and trade-offs, and cost efficiencies. It is a technology slam dunk that electric motor driven transportation will be the future. There is valid debate about the form of that electric motor driven transportation, and there is likely a much longer time horizon than most people will recognize. Large scale change takes time.

But we need to start the change for those of us wanting to take those initial steps. My next vehicle will be electric powered, a PHEV for me as I am a single vehicle family. My chosen vehicle is not available for sale in MN. Why? Because the vehicles are being directed to states that follow the CA regulations. So for now I wait, because I'm not driving much these days anyway. But I'm a Minnesotan, I want to direct my business to a Minnesota business and not waste flying to and driving back a car purchased in another state.

Please pass the Clean Cars Minnesota legislation and give me the choice!

OAH Docket No. 71-9003-36416 Name: Loni Kemp

Zip Code: 55922

Comment:

OAH Docket No. 71-9003-36416 Name: Emily Helgerson

Zip Code: 55405

Comment:

I drove an electric car and it was the best choice! It's a relief to be stopped at a traffic light in the winter, seeing all of the fumes coming out of the tailpipes of the cars around me and knowing that my car isn't doing the same. Everyone should have the choice of purchasing an electric vehicle. Once barriers are out of the way, we can all take advantage of the many practical and financial benefits while helping the environment, too!

OAH Docket No. 71-9003-36416 Name: Zach Lindner

Zip Code: 55414

Comment:

OAH Docket No. 71-9003-36416 Name: Vincent Leoo-

Zip Code: 55419

Comment:

OAH Docket No. 71-9003-36416 Name: Lonni Skrentner

Zip Code: 55439

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: PAUL THoMPSoN

Zip Code: 55416

Comment:

Essential piece of climate restoration for MN, please pass the clean car standards and promote biking and walking....most covid affected people are obese

OAH Docket No. 71-9003-36416 Name: Irene Alderson

Zip Code: 55418

Comment:

OAH Docket No. 71-9003-36416 Name: johnbergstrom

Zip Code: 55803

Comment:

Lets get to a sustainable grid

OAH Docket No. 71-9003-36416 Name: Rebecca Shedd

Zip Code: 55419

Comment:

I am so proud to have done my small part when I purchased a plug-in hybrid. I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Allen Frechette

Zip Code: 55379

Comment:

I'm a retired environmental professional with decades working with the MPCA on rules that were written to protect and improve the environment. The clean car rule is such a rule that is consistent with purpose the MPCA was created. Minnesota and our nation have committed to address climate change. Industry hasn't demonstrated sufficient action in this commitment so rules like this are needed. We wouldn't need any of the regulations the MPCA enforces if people and industry would do what is necessary to protect the environment, rather than focus on profit regardless of the impact to the environment and public welfare.

OAH Docket No. 71-9003-36416 Name: Santiago Fernandez-Gimenez

Zip Code: 55107

Comment:

As a citizen and consumer in Minnesota I want to purchase a PHEV or an EV in MN, but I find that the supply and choices are incredibly limited. Dealers simply don’t stock those vehicles here in sufficient numbers to have a good choice. I heard repeatedly that I would have to go to California to get a preferred model. People in Minnesota want a better selection of clean cars!

OAH Docket No. 71-9003-36416 Name: Mark Nelson

Zip Code: 55302

Comment:

My Comment is that we need more electric cars which emit 0 harmful aspects to our society. It gives me pleasure to imagine a future where our air is cleaner than it currently is.

OAH Docket No. 71-9003-36416 Name: Edith Thorstensson

Zip Code: 56082

Comment:

I care deeply about the environment. Because fossil fuels are the #1 sources of air pollution and greenhouse gases, I support drastic reduction of their use. Clean cars and other vehicles are the best means to that end. I believe that we are responsible for the world that future generations will inherit and that we must do all we can to make good decisions. As the owner/driver of a hybrid automobile (Prius) for many years, I am convinced that not only are electric cars great investments, they are our hope for a better, safer future. My next car will be electric!

OAH Docket No. 71-9003-36416 Name: Jeff Stromgren

Zip Code: 55408

Comment:

Please pass Clean Cars Minnesota for our future.

OAH Docket No. 71-9003-36416 Name: Patrick OLeary

Zip Code: 55120

Comment:

OAH Docket No. 71-9003-36416 Name: Kitura main

Zip Code: 56601

Comment:

It is difficult to get an electric car in the state. The dealers are not that well informed. We need more electric cars and this bill will help.

OAH Docket No. 71-9003-36416 Name: Andrew Willette

Zip Code: 55426

Comment:

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Nancy Conger

Zip Code: 55056

Comment:

Let's jump ahead to where the world is going anyway -- it's way more powerful than getting dragged along behind. If we prioritize clean cars now, businesses can adapt and people can more confidently buy electric cars.

OAH Docket No. 71-9003-36416 Name: Connie Nunemaker

Zip Code: 56676

Comment:

I think pushing the use of Clean electric cars in Minnesota, as has been done in California, is a terrible idea. Electric cars may make sense in the Twin Cities area, or warm climates, where people don't need to drive out of the city for most things, but makes no sense in the northern, rural parts of the state. The range for use of electric cars is possibly 200 miles, unless it's below freezing. Very cold temperatures can drop range 40% or more. That would mean I might drive to Bemidji from my house in cold weather (sometimes at night) and not only would I not have anywhere to plug in to recharge while I was in town (only charging station is at the electric company on one side of town, with no public transportation except expensive taxi to get around), but I might not be able to get back home safely, especially if I needed to use defroster and heat, and possibly AC to keep windows clear. Many areas I drive through also have no cell phone coverage, which could result in people being stranded on roads not well-traveled. Trips to Fargo from here are a 2-hour drive, with no known way to recharge an electric car once you get where you're going. If I wanted to take a longer trip, like to Michigan or Colorado, I might not find places to recharge the car if I traveled anywhere other than a major highway, and would have to use up travel time to recharge. Batteries in electric cars last only about 100,000 miles before needing to be replaced, at a cost of around $15,000. With the initial cost of these vehicles, lack of infrastructure to keep cars charged, and the effect of cold on battery and car efficiency, it makes no sense to me for Minnesota to require car dealers to try to sell a certain percentage of these vehicles. The only thing I can see happening is that available cars for everyone will be much more expensive as dealers try to make up for unsold electric cars, and I can envision many EV customers going back and wanting to trade them in for gas cars, to have better travel range and use of their time.

OAH Docket No. 71-9003-36416 Name: Marilynn Torkelson

Zip Code: 55347

Comment:

OAH Docket No. 71-9003-36416 Name: David Smith

Zip Code: 55347

Comment:

OAH Docket No. 71-9003-36416 Name: Mary Heise

Zip Code: 55616

Comment:

Addressing climate change & prioritizing innovative clean options is the right thing to do.

OAH Docket No. 71-9003-36416 Name: Avis Jensen

Zip Code: 55417

Comment:

I support the cause - let’s get as many clean cars as possible.

OAH Docket No. 71-9003-36416 Name: cami wolker

Zip Code: 55110

Comment:

OAH Docket No. 71-9003-36416 Name: Jane Krentz

Zip Code: 55082

Comment:

I’m a parent and grandparent, and I support Clean Cars Minnesota. Cleaner cars mean cleaner air for my children and grandchildren, along with other vulnerable people like the elderly and those with preexisting conditions who are most affected by the harmful effects of vehicle emissions. Clean Cars Minnesota will dramatically reduce these emissions and help protect my family when they’re waiting at the bus stop, walking in the neighborhood, or playing in the yard. Human health is at stake, and the longer we wait, the more children whose current and future health and wellbeing will be harmed by dirty vehicle emissions.

I support Clean Cars Minnesota. Clean car standards aren’t new. They’re an established and credible way that states can work to clean up pollution from transportation. Fourteen other states and the District of Columbia have already adopted clean car standards which seems like a really wise call considering that the federal government is actively working to roll back emissions standards. Clean Cars Minnesota reduces pollution and gives customers more choice. Let’s make Minnesota state #15 and the first one in the Midwest to adopt clean car standards.

OAH Docket No. 71-9003-36416 Name: Laura Dillon

Zip Code: 55104

Comment:

I care about our environment--locally and globally-- and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Another plus--building infrastructure for EV charging stations creates jobs! Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Robert Gubrud

Zip Code: 55435

Comment:

OAH Docket No. 71-9003-36416 Name: Julie Cox

Zip Code: 55406

Comment:

OAH Docket No. 71-9003-36416 Name: Robert Gubrud

Zip Code: 55435

Comment:

I support clean car legislation

OAH Docket No. 71-9003-36416 Name: Christine Hoffman

Zip Code: 56308

Comment:

Electric cars will make the air cleaner for everyone. It's time to implement cleaner car standards. Air pollution and greenhouse gases are at a worldwide high and now is the time to act! Make Minnesota air cleaner.

OAH Docket No. 71-9003-36416 Name: Katy Wortel

Zip Code: 56001

Comment:

I support the Clean Car standards so that Minnesotans can do their part to fight climate change.

OAH Docket No. 71-9003-36416 Name: Paula Engelking

Zip Code: 55416

Comment:

I'm a suburban voter who cares about the environment. Our family is a thrift-shopping, Prius-driving, recycling/composting family who turns our thermostat down to 57 at night. We want to see more incentives for everyone to reduce their carbon footprints. I've heard of long waiting lines for electric cars. It shouldn't be that way. I'd like to see Clean Car legislation that ensures there will be plenty of electric vehicles to choose from at the car lots. What's more, I want to see Minnesota adopt standards that will keep fuel-wasting vehicles from being sold in our state. We owe it to our kids and our grandkids to pass Clean Car legislation. It's the right thing to do, and it makes sense financially, too.

OAH Docket No. 71-9003-36416 Name: Steve Steuber

Zip Code: 55306

Comment:

I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. I lived in Minnesota all meh life of 67 years. My observations have been that our winters are much more milder today than when I was young. As teenager I remember that winter started in November and we has snow on the ground until April. I remember that people would put orange balls on the antennas of their car since the snow was piled so high at intersections you could tell if another car was also approaching from the other direction.

Since cars and trucks on the roads are the biggest source of CO2 we need to act now before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Please consider passing this legislation. Thank you.

OAH Docket No. 71-9003-36416 Name: Melia Derrick

Zip Code: 55443

Comment:

I am an outdoors person and have seen impacts on the enivornment by emissions. Reducing greenhouse gas emissions is possible and important. 14 other states have a vesion of clean car standards. Let's join them.

OAH Docket No. 71-9003-36416 Name: Margaret merkow

Zip Code: 55356

Comment:

I can’t wait for an electric car that has exchangeable batteries so I can travel to my other home, which is far away, without polluting the atmosphere.

OAH Docket No. 71-9003-36416 Name: Sam kedem

Zip Code: 55033

Comment:

Support green energy initiative, including public & private transportation, reliable internet throughout the state, electric car infrastructure, financial incentives for businesses & homeowners, adopting European green energy initiatives, raising awareness through education in k-12, fast rail system throughout the state & to other metropolitans.

OAH Docket No. 71-9003-36416 Name: Betsey Porter

Zip Code: 55431

Comment:

OAH Docket No. 71-9003-36416 Name: Mary Morrison

Zip Code: 55356

Comment:

OAH Docket No. 71-9003-36416 Name: Meghan Phimister

Zip Code: 55416

Comment:

OAH Docket No. 71-9003-36416 Name: Ann Thies

Zip Code: 55356

Comment:

I support Clean Cars Minnesota. The federal government has been reversing the progress made on reducing air pollution in our country. If Washington won’t lead, Minnesota will and Governor Walz has shown strong leadership in pushing for innovative solutions to the climate crisis. Clean Cars Minnesota would keep Minnesota on the right track for slowing climate change and reducing air pollution. I care about our environment and I support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

OAH Docket No. 71-9003-36416 Name: David Schaenzer

Zip Code: 55405

Comment:

I am an outdoors Minnesota person. I have seen changes in the BWCA during my trips over the past 53 years. I want cleaner cars to reduce harmful climate change from carbon emission. I look forward to buying a totally electric car on my next purchase. My house electric power is 100% wind source so I want my next car to join.

OAH Docket No. 71-9003-36416 Name: Christine Lee

Zip Code: 55413

Comment:

This type of standard is critical for Minnesota. It’s long last time to address the climate crisis. Millennials are terrified for our future under climate change. It’s time to move past this ridiculous partisanship and take some meaningful steps to deal with climate change.

OAH Docket No. 71-9003-36416 Name: Megan Hoff

Zip Code: 97391

Comment:

OAH Docket No. 71-9003-36416 Name: jim stiles

Zip Code: 55912

Comment:

As a small business owner in southern minnesota for the past 40 years our family totally supports the clean car bill. We live in Mower County, my son-in-law works on the wind turbines around Dexter, our County hugely benefits from a tax on turbines as do land owners and workers. We need clean carbon free energy. My business saves money by investing in new bakery ovens, air conditioners and compressors. The most important issue for me now is leaving my grandkids a carbon free future. thankyou very much

OAH Docket No. 71-9003-36416 Name: Chris Johnson

Zip Code: 55408

Comment:

I was born and raised on a small dairy farm in south-central Minnesota, and have lived in Minnesota most of my 57 years. From my hard-working, quiet, faithful, farming parents I learned that we have only one Earth, and that we're all called to care for and love it. I care about our environment and I support Clean Cars Minnesota.

Climate change is threatening Minnesota’s -- and the whole planet's -- forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the #1 source of climate change-causing pollution in our state and nationally so we need to act to reduce greenhouse gas emissions before it’s too late. Clean Cars Minnesota is a key piece of the puzzle when it comes to protecting our environment. Reducing vehicle emissions will slow climate change and reduce greenhouse gas emissions. Let’s act before it’s too late.

I also learned from growing up on the farm the benefits of paying attention both to science and to the ancient Earth-wisdom of indigenous peoples, and of innovating solutions to challenging problems. My dad never went to college himself, but it seemed like he could always "invent" a new tool or improvise a way to fix things in the face of the constant pressures of weather and time. Clean-car technology is one of the soundly science-based, Earth-friendly, rapidly advancing innovations that represents the best of a Minnesota farmer's way of being, and one that I strongly support.

My Minnesota farm roots, and the communities of faith and learning that I've been part of all across my decades here, have also taught me to care especially for those whose voices are less likely to be heard. So I support Clean Cars Minnesota because communities of color and under-resourced communities currently bear the brunt of negative health impacts from air pollution - especially pollution caused by transportation. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionately harm Minnesota’s most vulnerable and marginalized communities.

OAH Docket No. 71-9003-36416 Finally, I am an EV owner and I love it! Driving an electric vehicle in Minnesota is a freeing experience. You can go from point A to point B without worrying about harmful tailpipe emissions and since EVs don’t have internal combustion engine they warm up much faster in the winter and have considerably lower maintenance costs. Clean Cars Minnesota would give the 6 in 10 prospective car buyers in Minnesota who are interested in electric vehicles the opportunity to actually see and test drive a much wider variety of makes and models - many of which currently don’t even make it to our state because they go to states with clean cars standards. Buying a car or truck is a big choice and Minnesotans deserve the chance to weigh all options.

Thank you for doing the right thing!

OAH Docket No. 71-9003-36416 Name: Amy Green

Zip Code: 55102

Comment:

I am a climate activist and know the incredible impact that switching to electric can have. It should be cheaper and easier for people to own electric cars than gas cars.

OAH Docket No. 71-9003-36416 Name: Michael Wojcik

Zip Code: 55903

Comment:

Please support action to progressive minimize the number of GHG emitting vehicles on the road as quickly as possible.

OAH Docket No. 71-9003-36416 Name: andy zelinskas

Zip Code: 55107

Comment:

Hi. I fully support MN clean car initiative. We have to start the process of decarbonization of our transportation to help mitigate the effects of climate change. We should lead now and not wait for a crisis. We have time to adjust and that time is now. Thanks for your time

OAH Docket No. 71-9003-36416 Name: Jason Fife

Zip Code: 56071

Comment:

OAH Docket No. 71-9003-36416 Name: Wendy Reid

Zip Code: 55406

Comment:

I’m an organic vegetable gardener and I like to be outside in my neighborhood and I’m sick of breathing in exhaust fumes when I’m outside.

I support Clean Cars Minnesota. Cleaner cars mean cleaner air for myself and my neighbors. I love to be outside in my neighborhood but worry about how the air pollution coming from the cars and trucks passing by are affecting my health. And I worry that it negatively affects the soil. I know that pollution harms lungs and hearts, especially when breathed in regularly. I also know that communities of color and low-income communities bear the brunt of the negative health impacts from air pollution. Clean Cars Minnesota would dramatically reduce these emissions and help protect me and everyone in my neighborhood.

OAH Docket No. 71-9003-36416 Name: Sarah Ramler-Olson

Zip Code: 55409

Comment:

OAH Docket No. 71-9003-36416 Name: Ellie Crosby

Zip Code: 55356

Comment:

We must reduce greenhiuse gas from cars and trucks to help combat climate change.

OAH Docket No. 71-9003-36416 Name: lisa bergerud

Zip Code: 55406

Comment:

OAH Docket No. 71-9003-36416 Name: Emily Onello

Zip Code: 55812

Comment:

I am a doctor and I believe that clean cars in Minnesota takes a bold step toward the short and long term physical, mental and financial health of Minnesotans and the nation. Please support Clean Cars Minnesota because we know that continued combustion of fossil fuels like gasoline and diesel fuel have very real and very significant negative human health effects.

OAH Docket No. 71-9003-36416 Name: Christopher Loch

Zip Code: 55405

Comment:

We need the Clean Car Plan! We need the Green New Deal.

OAH Docket No. 71-9003-36416 Name: Dennis Cuchna

Zip Code: 56308

Comment:

OAH Docket No. 71-9003-36416 Name: Joel Weisberg

Zip Code: 55057

Comment:

I am writing to express my support for our state to adopt both the Low Emission Vehicle (LEV) and Zero Emission Vehicle (ZEV) standards as part of the Clean Cars rule. Adoption of these rules would help to move us away from seriously polluting (both in terms of CO2 and also other harmful gases and particles) , fossil fuel powered autos and toward much cleaner electrically powered vehicles. It is established science that fossil fuel burning leads to carbon dioxide emissions into the atmosphere which lead to global warming, so we need to do all that we can to bring them down. This is especially true of vehicles, which currently represent the largest class of CO2 emitters in the state. The emissions of particles and other gases from fossil-fueled engines are also harmful to our health, and adoption of these rules is estimated to avoid the premature deaths of 2-4 thousand persons per year due to reduction of these emissions.

I have read that there are very few new electric vehicles for sale on Minnesota car lots. This situation is intolerable, given the importance of the adoption of these kinds of vehicles for our health and for the planet's safety. We ourselves plan to purchase an electric vehicle in the next several years, and we urge you to adopt the rule so as to make them more available. The handwriting is certainly on the wall, with GM just announcing that they are phasing out conventionally-powered cars; and Minnesota should be part of the transition.

OAH Docket No. 71-9003-36416 Name: Elly Verhagen

Zip Code: 55105

Comment:

I care deeply about our environment so I used public transportation for almost 20 years commuting to work, owned low-emission cars for my other transportation needs, and support Clean Cars Minnesota. Climate change is threatening Minnesota’s forests, water, and air. Our winters are already warming faster than the national average, and our northern boreal forests are at risk of disappearing. Cars and trucks on the roads are the number one source of climate change. We need to act to reduce greenhouse gas emissions before it’s too late. By reducing vehicle emissions and thereby reducing greenhouse gas emissions, Clean Cars Minnesota provides a key component to protecting our environment and slowing climate change. We need to act before it’s too late.

OAH Docket No. 71-9003-36416 Name: Jamie Johnson

Zip Code: 55414

Comment:

I support clean cars Minnesota. Minnesota needs to demonstrate leadership related to clean cars. Other states have already shown that electric vehicles and sustainable transportation options not only work, but work well. More importantly, communities of color in Minnesota bear the brunt of localized air pollution from sources such as vehicles. Policies like Clean Cars Minnesota are a step toward dismantling policies and other systemic barriers that disproportionately harm Minnesota’s most vulnerable and marginalized communities.

OAH Docket No. 71-9003-36416 Name: Annie Pottorff

Zip Code: 55418

Comment:

I support Clean Cars Minnesota, as it's a key step to create a more just and sustainable future for our state. I'm also a young person and know we can't afford to wait any longer. Clean Cars Minnesota confronts climate change and is important for our BIPOC communities, as well as children, the elderly, people with health conditions, and all others especially vulnerable air emissions.

OAH Docket No. 71-9003-36416 Name: Emily Neuharth

Zip Code: 55414

Comment:

This is important to me and I want electric cars to be more available and more affordable.

OAH Docket No. 71-9003-36416 Name: Karissa Kostka

Zip Code: 55104

Comment:

OAH Docket No. 71-9003-36416 Name: Mark Owens

Zip Code: 55912

Comment:

OAH Docket No. 71-9003-36416 Name: Kelsey Fox

Zip Code: 55104

Comment:

OAH Docket No. 71-9003-36416 Name: Ben Fribley

Zip Code: 55407

Comment:

While we're at it, tell MNDOT to just reduce VMT.

OAH Docket No. 71-9003-36416 Name: Mike Tobin

Zip Code: 55416

Comment:

OAH Docket No. 71-9003-36416 Name: Ben Passer

Zip Code: 55102

Comment:

I support Clean Cars MN because it is critical to the future of our state. Minnesotans deserve more consumer options, and improved health through reduced air pollution. Clean Cars MN helps ensure both.

OAH Docket No. 71-9003-36416 Name: Camille Nicholson

Zip Code: 55107

Comment:

OAH Docket No. 71-9003-36416 Name: David Orr

Zip Code: 55420

Comment:

I’m a life long Minnesotan and I support Clean Cars Minnesota. As a resident of Bloomington, MN, I have signed up for Windsource through Xcel, purchased an electric car for one of my two family vehicles in 2013 and used it for the last 8 years, purchased and installed solar to offset our electrical grid usage and ensure a clean source of energy and made numerous other decisions focused on preserving the local environment and resources of this planet for generations.

Today, there are still too few options for electric cars and too much confusion. Nissan's own car mechanics and staff, whose job it is to sell/service their vehicles have often made incorrect statements or been confused about the electric vehicles they sell or service (even 10 years after their first model was on the market). They misunderstand how they work, how reliable they can be, whether they are practical in a cold climate, how little maintenance they require and other details important to the consumer. Their business model is built upon selling high margin vehicles and having those cars come back for servicing options again and again. The truth is, were they required to actually offer EV and Hybrid options in equal opportunity with internal combustion engines, not only would they be providing better choice to their consumers, but they might actually learn about the benefits of these vehicles and see how it is a big win for their sales, for the environment and for a competitive marketplace.

Anyone who needs a vehicle for work or sport that uses internal combustion can get one (new or used) easily. But most Minnesotans actually don't need an ICE vehicle. Were they given the choices a free market should provide, they would be able to be better informed and see the direct benefits of using and owning an EV or Hybrid vehicle. We have the technology and the use cases that make these vehicles extremely practical to many consumers - let's now require that car dealerships come into the 21st century and honor the competitive nature they regard so critical to their economy.

OAH Docket No. 71-9003-36416 Clean Cars Minnesota presents a major opportunity for companies to reduce their carbon emissions and build on our state’s history of innovation and leadership. Please support this initiative moving forward.

OAH Docket No. 71-9003-36416 Name: Erica Johnson

Zip Code: 56001

Comment:

While noble in the pursuit for a cleaner environment, enacting the Clean Cars MN is the wrong way to push change. There is no stable electric grid for car charging, the battery creation process is dirty and has a HUGE human cost with mining, the consumer cost for charging electric cars will push utility bills through the roof, and there is no hard evidence that electric cars will be any better (in overall production, etc.) than combustible engines. There is not an argument that phasing out greenhouse gases is the right thing to do. There should be a much more thoughtful method of going about it. Clean Cars MN is NOT the way.

OAH Docket No. 71-9003-36416 Name: Justin Fay

Zip Code: 55407

Comment:

I support the proposed rule and believe it is a modest step that the state can take to address greenhouse gas emissions from transportation. We know from MPCA data that transportation is the largest source of GHG emissions in Minnesota, so this needs to be a priority for the state to address.

I would like to add a personal note that this rule has the potential to offer significant secondary comments for Minnesota consumers. In 2019 I was in the market for an EV and after researching selected the Hyundai Ioniq all-electric as the best option for our household. Unfortunately after contacting multiple Hyundai dealers it became obvious that car is simply not available for sale in Minnesota. Further research found quotes from Hyundai leadership making it clear that battery electric vehicles that company produces are explicitly prioritized for sale in ZEV states.

Fortunately I was able to purchase a different EV - a 2019 Nissan Leaf - and I love it. It works great, has plenty of range for my needs and has had no performance issues or repair costs beyond very minor scheduled maintenance. It's the cheapest car to own that I've ever had. There are a lot of misconceptions about electric vehicles - I won't address them all here, but will simply share that I've owned mine through two winters now and have no desire to ever go back to gasoline. All Minnesotans should have this option, and the plain truth is that right now they don't simply because the industry is not making the full suite of electric/ZEV options available for sale.

In summary, I believe the proposed rule addresses an urgent and clearly identified problem (GHG emissions from transportation), provides a number of secondary public benefits (consumer choice, public health) and should be adopted.

OAH Docket No. 71-9003-36416 Name: Linda Charpentier

Zip Code: 55106

Comment:

I am all for practical electric vehicles like the ones that Exxon buried the patent on in the 1980's that could drive for 1500 miles without a recharge. The is nothing like a road trip to be able to see the true wealth and beauty of this country. Clean cars should be able to accommodate that option.

OAH Docket No. 71-9003-36416 Name: Brenna Doheny

Zip Code: 55037

Comment:

As an environmental health scientist, I support the MPCA's proposed Clean Car Standards as a much-needed strategy for improving air quality and reducing carbon emissions. These standards will help mitigate climate change and reduce the negative health impacts associated with it.

As a resident of Greater MN, the increased availability of electric and low emission vehicles that will result from this rule will directly benefit me and other members of my rural community. I have to commute long distances for my work and have been interested in owning an electric vehicle, but have not been able to find any for sale here in MN that meet my needs and budget. I look forward to the opportunities that the Clean Car Standards will provide.

OAH Docket No. 71-9003-36416 Name: steve schultz

Zip Code: 55416

Comment:

OAH Docket No. 71-9003-36416 Name: Johannah Frisby

Zip Code: 55104

Comment:

As a Minnesotan deeply concerned about and committed to systemic changes that benefit both people and the environment, introducing Clean Cars MN is a way to address both. As the United States' transportation system is run on highways and individual modes of transportation, making it easier for people to drive with an energy efficient vehicle is critical. Reducing emissions and commiting to standards that support health and livelihood of all beings should be a top priority.

OAH Docket No. 71-9003-36416 Name: Kate Graham

Zip Code: 55407

Comment:

OAH Docket No. 71-9003-36416 Name: Joan Poritsky

Zip Code:

Comment:

OAH Docket No. 71-9003-36416 Name: Emma Thomley

Zip Code: 55408

Comment:

OAH Docket No. 71-9003-36416 Name: Dana Donatucci

Zip Code: 55113

Comment:

This is a step in the right direction. Let's not delay the transition to cleaner transportation any longer. This is long overdo. Everyone benefits now and into the future!

OAH Docket No. 71-9003-36416 Name: Deborah Capouch

Zip Code: 55431

Comment:

I am a Minnesota citizen that is very passionate about environment conservation and the impact that carbon emissions has on our air quality and the long term effect on climate change.

I feel that this is a very important issue because:

- Gas powered autos are a major source of nitrogen oxide and particulate matter air pollution that cause disease and early death, especially in low income neighborhoods located near freeways. EVs and hybrids have much lower/zero pollution from these sources.

- Much of the gasoline that powers cars in MN comes from oil mined in the Canadian Tar Sands. It is the dirtiest fuel on earth! As citizens and consumers, we need a choice of clean cars that don't run on and/or support these extreme fuels and the leaky pipelines that threaten our clean water.

- As a voter and citizen of this beautiful state that I want to preserve for generations to come, I support Clean Cars Minnesota to reduce emissions, not allowing leaks from pipelines to ruin our native lands, and support more EV and hybrids on our roads, and clean air for all to enjoy.

Thank you for your time and consideration.

Deborah Capouch

Bloomington, MN

OAH Docket No. 71-9003-36416 Name: Carol Stoddart

Zip Code: 55116

Comment:

OAH Docket No. 71-9003-36416 Name: Margaret Cherne-Hendrick

Zip Code: 55409

Comment:

OAH Docket No. 71-9003-36416 Name: Jane Gleason

Zip Code: 55126

Comment:

OAH Docket No. 71-9003-36416 Name: Irene Nosow

Zip Code: 55422

Comment:

I strongly encourage Minnesota to conform its low emission and zero emission standards to those adopted by California. Though the federal government will probably move towards eliminating emissions in transportation, it is essential that each state take immediate action to help reduce climate change rather than wait for federal action. Given the large percentage of emissions attributable to transportation, the combined efforts of individual states will encourage automobile manufacturers to move more quickly to transition to EV and hybrid vehicles.

As I have researched the availability of EV and EV/hybrid vehicles over the last couple of years, I have noticed that many models are not even available for purchase in Minnesota. If we adopt the California standards, I expect that more models will become available here, hopefully making them more affordable.

OAH Docket No. 71-9003-36416 Name: Anna Johnson

Zip Code: 55407

Comment:

I support Clean Cars because society at all levels - including the state and individuals - have an imperative to reduce greenhouse gas emissions as soon as possible in order to avoid the worst impacts of climate change. At the state level, Clean Cars will reduce emissions from our highest-emitting sector and provide co-benefits of reducing all tailpipe pollutants. I live on a busy street less than half a mile from 35W, and I am eager for the day I can exercise and live in my neighborhood without the anxiety I currently have about the long-term effects of exposure to NOx, SOx, and other harmful particulates, when the vast majority of transportation is electrified. Clean Cars will also provide individuals who want to realize the many benefits of electric vehicles--including reducing emissions and costs--more and better opportunities to do so.

OAH Docket No. 71-9003-36416 Name: John Dunlop

Zip Code: 55405

Comment:

We are in a climate crisis. We must curtail carbon emissions immediately. Transportation is the largest emitter of greenhouse gases. We drive an all-electric sedan. We would like a larger all-electric vehicle with twice the range and four-wheel drive. The Clean Car Rule will help ensure that the vehicle we would like to buy will be available in Minnesota. The presence of EVs on dealers' lots will build confidence in EV shoppers that EVs are becoming mainstream, accelerating the transition to clean transportation.

OAH Docket No. 71-9003-36416 Name: Bill Middlecamp

Zip Code: 55124

Comment:

Electric vehicle adoption is a win-win for both EV owners and non owners. First, EVs increase sales of electricity at night, which makes more efficient use of capital investment in electricity infrastructure and lowers the cost of electricity for everyone. Second, EVs lower the demand for oil, which lowers the price of gasoline. Third, fewer oil-powered vehicles means fewer particulates emitted, which reduces the premature deaths and serious illness caused by particulates. Fourth, there is a limit on the amount of CO2 (a budget for all time) produced by human activities to avoid the worst effects on our environment, which will last longer if we can ramp down the use of fossil fuels more quickly, and EVs are a crucial component of that (together with electricity generation getting cleaner). Please remember that cars last about 15 years, so every missed opportunity because of lack of choice (and support) has a 15-year impact! This would be moot if owners do not buy EVs, but my nine years as an owner tell me that they are great cars to own and operate.

OAH Docket No. 71-9003-36416 Name: Britta Augdahl

Zip Code: 55408

Comment:

I support Clean Cars Minnesota. I’m a young person and I believe the future is in our hands. We need to do everything we can right now to reduce carbon emissions and save our communities and environment. Clean Cars Minnesota is another step on Minnesota’s path to cutting climate change-causing greenhouse gas emissions and saving our state, country, and planet. Cleaner cars mean cleaner air for myself and my neighbors. I love to be outside in my neighborhood but worry about how the air pollution coming from the cars and trucks passing by are affecting my health. I know that pollution harms lungs and hearts, especially when breathed in regularly. I also know that communities of color and low-income communities bear the brunt of the negative health impacts from air pollution. Clean Cars Minnesota would dramatically reduce these emissions and help protect me and everyone in my neighborhood.

OAH Docket No. 71-9003-36416 Name: Holly Bruce

Zip Code: 55438

Comment:

I dont know why we need a legal rule to "force" car dealers to bring more fuel efficient cars to Minnesota. It seems like the right thing to do but I guess if the dealers don't seen the logic we have to make them see. Please MAKE THEM SEE!! Thanks

OAH Docket No. 71-9003-36416 Name: Edward Cohen

Zip Code: 55902

Comment:

OAH Docket No. 71-9003-36416 Name: Karen Cohen

Zip Code: 55902

Comment:

I am concerned about negative health affects from the fumes from gas cars and

OAH Docket No. 71-9003-36416 A RESOLUTION OF SUPPORT FOR CLEAN CARS MINNESOTA John Anderson Attachment

Submitted by the Minnesota Valley Chapter of the Izaak Walton League

WHEREAS, transportation is the largest emitter of greenhouse gases (GHGs), both nationally and in Minnesota, making the sector a significant contributor to climate change, which is already affecting Minnesotans.

WHEREAS, the Next Generation Energy Act of 2007, directed the state of Minnesota to reduce greenhouse gas emissions by 15% by 2015, 30% by 2025, and 80% by 2050 (from 2005 levels).

WHEREAS, Tailpipe pollution from vehicles is one of the primary sources of exposure to harmful air pollutants in many communities around Minnesota.

WHEREAS, In 2019, Governor Walz announced that Minnesota would be joining 14 other states and the District of Columbia in adopting “clean car standards,” which are regulations and incentives for the auto industry aimed at reducing pollution and giving customers more choices for low and zero emission vehicles.

WHEREAS, The Minnesota Pollution Control Agency (MPCA) has been given the authority by the state though statute 116.70 subd 2(a) to act on reducing emissions in order to protect Minnesota air, water and health. Therefore the MPCA has been directed to lead the rule making rprocess fo the clean car standard.

NOW THEREFORE BE IT RESOLVED that the Minnesota Valley Chapter of the Izaak Walton League formally approves the Resolution of Support for the MPCA Rule making to adopt the Clean Cars Standards John Beath Attachment

John Beath Environmental, LLC Striving to make something better every day

Comments on Proposed Regulation: Clean Cars Minnesota, Minnesota Rules, Chapter 7023; Revisor’s ID Number 04626, OAH Docket Number 71-9003-36416

Prepared for:

Hon. Jessica A. Palmer-Denig Administrative Law Judge Office of Administrative Hearings State of Minnesota 600 North Robert Street Saint Paul, MN 55101 Issued: 03.15.2020

INTRODUCTION

March 15, 2021

Dear Judge Palmer-Denig,

John Beath Environmental, LLC (JBE) appreciates the opportunity to submit comments on Minnesota’s proposed rule that seeks to govern the sale of electric and gasoline-fueled vehicles in the state.

JBE is an environmental and sustainability consulting company whose team members have many years of experience evaluating sustainability issues in the energy sector. Though we are a small business that is only six years old, our employees number twenty-eight full and part-time staff spread through fourteen states. Amongst our team are three life cycle assessment certified professionals, more than most any consulting or industry organization in the US currently, as well as three professional engineers, all with direct oil industry experience.

JBE’s experience related to sustainability spans many industry sectors, supporting small and large clients, as well as providing technical expertise to government laboratories including support for enhancements to the Argonne National Laboratory’s GREET fuel transportation model. Unique to our company’s perspective is that a number of our team members have worked for energy sector companies directly and have served in environmental, process engineering and sustainability-related roles. In addition, our team is very experienced in the performance of life cycle assessments for all types of products ranging from solar panels to toothpaste to vehicles. One of our staff was involved in vehicle light-weighting studies that compared steel to other products such as various plastics. Two of our team serve as life cycle assessment third-party reviewers for companies seeking to comply with the ISO standards that govern the life cycle assessment practice.

We work for all kinds of clients and seek in every case to deliver fact-based, sound, and transparent science in support of efforts to improve the global environment in practical ways. We are regularly called upon to review work by others, and to address issues raised by shortcoming in their technical efforts.

In the attached Appendix document, we present our work analyzing the potential effectiveness of an electric car sales requirement for Minnesota’s specific situation developed specifically to address issues raised in the SONAR Technical Support Document and the Statement of Need and Reasonableness.

Sincerely,

John M. Beath, P.E. (Texas), LCA-CP LLC Manager, Senior Technical Consultant, and Environmental Coach, JBE [email protected] +1 888.777.4310

Appendix A - JBE Comments to the Statement of Need and Reasonableness and SONAR Technical Support Document

I. Overall Approach

JBE has conducted a review of key aspects of the documents presented by Clean Car Minnesota. Our objective was to provide a perspective as to whether the net positive benefits attributed to the growth of electric car use in Minnesota have been properly determined.

Our company supports the reduction of greenhouse gas (GHG) impacts by practical means and has a clear understanding of the potential benefits provided by electric cars provided that the issues this conversion may create are considered in proper context.

As with many life cycle studies, it is exceptionally important to consider tradeoffs thoughtfully, e.g., where a GHG reduction may be offset by a criteria pollutant increase. Equally important is to make sure all aspects of the impacts produced in each life cycle stage are considered in the evaluation performed.

II. Conclusions

After conducting a review of the data presented by SONAR and performing an independent analysis to develop estimates of the lifecycle GHG impact for Electric Vehicles (EVs) and Internal Combustion Engine Vehicles (ICEVs), we do not see a clear-cut case that there is a GHG emissions reduction benefit of EV’s for Minnesota over the next ten years. The key factors that have been overlooked include the following:

1. Not considering power plant actual emissions (emission factors developed based on the 2019 MN state emissions inventory result in values higher than the national average);

2. Not considering grid impacts due to importing power (which includes some coal and natural gas-fired power plant producers);

3. Using grid data for the region, instead of data specific to the state of Minnesota;

4. Not considering the actual GHG impacts from imported hydroelectric power;

5. Not allowing for transmission and battery losses in determining how much charging power is required for EV’s;

6. Not considering the impacts to power requirements due to operating and charging in cold weather;

7. Not considering the effects from battery efficiency loss over the life of the battery;

8. Overlooking that EV power requirements have been rising and the value for power selected is now at the lowest end of the power range of today’s available EV models;

9. Overlooking that the mile per gallon for gasoline-powered passenger cars sold in the US has been rising each year and is above the value selected by SONAR (and will keep improving); and,

10. Assuming 75% of MN crude oil used to produce gasoline is sourced (and will be) from oil sands sources.

Therefore, we encourage Minnesota to think creatively about how to manage any rulemaking it considers to provide the most GHG benefit for the short term, as well as the long-term. In our view, there can and should be alternate pathways.

Until adequate improvements are made to the existing electric grid and to the required infrastructure to facilitate a large electric vehicle fleet, a practical hybrid solution should be considered. The stakeholders should understand clearly that a sales mandate alone may not inspire car owners to buy new cars. What if the new car buyers opt just to hang on to their aging gasoline-powered cars for a while?

Though outside the scope of these comments, improving the efficiency of gasoline-powered vehicles (and the fuels they use) is something that can potentially proceed much faster than the scale up of EV’s over the next two to five years.

The use of Plug-In Hybrid Electric Vehicles (PHEVs) as a gap bridge should be studied carefully because of the benefits they offer (less dependence on infrastructure while still potentially reducing urban emissions and also potentially power plant emissions over EV options).

III. Comments on GHG Emissions Per Vehicle Mile

Reference: Minnesota’s Statement of Need and Reasonableness: Clean Care Minnesota document (Figure 6, Page 21)

The explanation provided in this document and in related portions of the Technical Support Document do not contain sufficient detail to connect assumptions made to results obtained. The AFLEET workbook that was the basis for the reported results should be made available during the rebuttal period for review.

Perhaps more significantly, reference is made to data on the electric power generation fuel supply grid developed by Midcontinent Independent System Operator (MISO) North. In reviewing data presented in various documents by MISO, the grid mix data they present is aggregated from parts of Montana, North Dakota, South Dakota, Iowa, Missouri, Minnesota, Illinois, Indiana, Kentucky and Michigan1. This data represents the grid in 2018 as 46% Coal, and there is no readily available division of the grid by contributing states.

To base an analysis on a representation of the power grid for Minnesota from this data is inaccurate. In reality, EIA data suggests that coal was 29.6% of the Minnesota grid in 2019. To independently determine this value, we collected detailed plant-by-plant generation data for each plant in Minnesota. That analysis resulted in a determination of 30.3% (based on in-state generation). This much of a shift is bound to make the benefit of electric vehicles (EVs) seem much larger than it might be.

JBE has conducted its own analysis in order to make the calculation process more transparent, and to point out reasons why the GHG impacts from operation of electric vehicles used in Minnesota may be significantly higher than reported in these documents.

1 2018 State of the Market Report, Misoenergy, Section B (Table 1, Page 27) https://cdn.misoenergy.org/2018%20State%20of%20the%20Market%20Report364567.pdf

Results from that analysis are presented below and discussed in some detail in the paragraphs that follow. Refer to the attached calculations for detailed analysis. That analysis shows clearly that while an “out-of-the-box” assessment might conclude that the advantages of EV operation are quite favorable, it is possible to construct a set of reasonable assumptions that can completely offset the potential GHG reduction.

Figure 1 – GHG Life Cycle Comparative Assessment – ICEV Versus EV for Minnesota

The graph above illustrates the from-the-ground up approach that results for a life cycle assessment. For both the ICEV and EV situations, the stacked bar shows the relative contributions of the making of the vehicle, its operation, and the making of the fuel for the vehicle. In the case of the EV, the “operation” includes the emissions from the power plant that actually occur as the vehicle battery is being recharged, rather than as emissions from the vehicle itself while it is being operated.

The ICEV graph differentiates the contribution of crude source. The SONAR documents appear to estimate GHG impacts for ICEVs using the assumption 75% of the crude used to produce the vehicle’s gasoline originates from the Alberta Oil Sands. While this scenario is possible given the geographic region, pipeline infrastructure, and existence of in-state refineries, the SONAR fails to provide adequate market analysis demonstrating that Minnesota’s personal vehicle gasoline supply is sourced regionally (i.e., existing long-term contracts and/or commodity pricing may result in long distance transfer of finished gasoline products).

As a consequence, a best representation would be that the conventional crude oil and oil sand crude represent brackets of operational flexibility. Thus, whether the overall g CO2e/mile value for an ICEV is greater than or less than an EV is dependent on the percent of crude originating in the oil sands versus conventional sourcing. When vehicle gasoline is produced by conventional crude sourcing, the ICEV has a lower GHG life cycle impact than a Minnesota EV.

The SONAR evaluation ran an example case that used 50% coal and 50% natural gas in the grid. This case is worse than the case our evaluation essentially offset, so a comparison to a worse case seems unnecessary. But if it were to be considered, our preliminary assessment is that the impacts would be 61% higher for the EV than the case we have presented.

Crude data supply by state is not publicly available but subregional data is published by EIA PADD region. JBE has reviewed 2014 data developed by DOE laboratories suggesting that PADD2 (Midwest) that includes Minnesota can be 25% from West Texas Crude and 6% from Bakken oil shale (via various pipelines). Of course, crude supply varies widely over time as prices and contracts come and go.

The second graph above for EV’s contains quite a bit more detail. While it also covers fuel production, vehicle operation and the manufacture of the vehicle, it contains some adjustments that are unique to the nature of the electric vehicle. These adjustments are:

 Solar and Nuclear Lifecycle Data – While GHG emissions may not occur during plant operation, a full LCA analysis of these fuel sources must consider their full life cycle. For the solar panel, this includes sourcing of the materials to make the solar panel, the maintenance required, and the implications from waste disposal. For a nuclear power plant, there are GHG emissions from extracting the source material, transporting it to the plant, operating various systems (e.g., cooling, lighting, etc.) and managing the waste (recently a subject of some debate). The values reported as incremental here are for the full life cycle as reported in the literature.2

 Power Plant Efficiency – The reported actual value for the impacts from power plants are higher than the “out-of-the-box” case because they reflect the actual emissions data we compiled for this study from emissions inventory reports.

 Adjustment for Imported Power – This takes into account the net change in the “as generated” grid considering the imported hydroelectric, coal-fired and gas-fired electricity.

 Adjustment for EV Efficiency – The ability of the EV to move the vehicle is based on its available power efficiency. Industry data is reported as “kWh/100 miles”, and this data is compiled by EPA as part of the fuel economy testing that ultimately is printed on a vehicle window sticker. The value relates to the power required to charge directly (and therefore the power plant load to support charging). The SONAR data suggests that a value of 29 kWh/100 miles was used for analysis. The higher this number, the more power required, and the higher the corresponding GHG impact.

JBE reviewed ratings for all EV’s currently being sold in the US that have EPA ratings. Only four models listed have values at or lower than 29 kWh/100 miles, while twenty-five models have higher values, with the maximum at 44 kWh/100 miles3. The trend over time demonstrates a reduction in efficiency due to consumer preference for heavier cars with more cargo area and the capability of carrying more passengers (e.g., 6 or 7 versus 5).

 Adjustment for Transmission Loss – Though a power plant produces power, the loss of power due to traveling lines and the actual transfer of the power to the battery needs to be considered. The study

2 Dones, Heck and Hirschberg, “Greenhouse Gas Emissions From Energy Systems: Comparison and Overview”, OSTI.GOV US Department of Energy, Office of Science and Technical Information https://www.osti.gov/etdeweb/servlets/purl/20547252

3 https://www.fueleconomy.gov/feg/evtech.shtml

provides a reasonable adjustment for that.

 Adjustment for Cold Weather Operation and Charging of Batteries – The effects of cold weather on battery operation are well-documented but not consistent in the level of performance adjustment that may result. Some data about low and high temperature operations is provided by make and model by Geotab4.

More data has been published recently that suggests that operating a battery in temperatures below 20°F can result in as much as a 40% reduction in efficiency (seen as reduced cruise range for a charge). Given the average low (and high) temperature in Minneapolis in winter, it is likely that some below 20°F operation could occur for three months of the year.

There is also a recently documented fact that EV manufacturers are using resistance heating to heat up batteries for charging as well as fans to cool them during hot weather. Data on this has not been quantified but it warrants further study. Note that this power load is not captured typically in a charging power requirement analysis.

 Adjustment for Battery Age – As the battery moves toward its life expectancy (8 – 10 years), it has been well documented that its efficiency will decrease over time.

 Miles Per Gallon (MPG) of Gasoline Vehicle Pool – The assumed fuel efficiency of the gasoline-fuel vehicle is critical to this analysis, both to consider 2019 operations, but also to contemplate how this value may change over time, especially over the next ten years. For this analysis we averaged 2019 MPG for the top five passenger cars sold (by make and model) in the US – that number – 29 MPG - was much less than various studies. Based on published 2021 vehicles sales to date, that number is already 31 MPG, so the trend seems to be close to one MPG increase over each model year. The calculations presented do not include having that number increasing over time.

As a consequence of the analysis presented in this section, a set of assumptions can be developed that matches the emissions performance of a gasoline-power vehicle for an EV operated in Minnesota given today’s operational situation.

IV. Comments on Power Plant GHG Emissions Data for Minnesota

A. Use of Specific Power Plant Data

The data we obtained from EIA that characterized grid representation can be connected to US grid emissions factors for GHG or other criteria pollutants. However, JBE’s experience has been that some power plants have emissions rates that are lower than the national average for that type of power plant (e.g., for coal-fired plants). JBE performed a detailed analysis of actual power plant data for Colorado in developing comments on their proposed rulemaking. That difference in emissions can result from equipment problems, weather-related impacts (e.g., forced downs), differences in control equipment, etc.

4 https://www.geotab.com/fleet-management-solutions/ev-temperature-tool/

To address this difference, JBE collected emissions inventory data from the Minnesota Pollution Control Agency (MPCA) for each power plant large enough to be required to report its emissions inventory data. This data covered most if not all of the state’s nuclear, gas, and coal-fired power plants. We compiled this data to form a representation of the actual emissions factors for each plant, and therefore for each type of fuel source for power plants in Minnesota. That analysis resulted in approximately 10% higher emission factors for GHG.

B. Consideration of Data for Power Consumption Versus Generation

Further investigation by JBE resulted in the discovery that a full description of the power grid for Minnesota needs to account for the fact that the state consumes more power than it generates. A portion of this power is generated by hydroelectric power plants in Manitoba and imported, and the balance of the power is sourced from North Dakota and Wisconsin.

Given the make-up of the North Dakota power system in the eastern part of the state and the high voltage DC power distribution line from the coal-fired power plant in North Dakota to Minneapolis, it is safe to conclude that a significant portion of the imported power from North Dakota may be coal. The grid in western Wisconsin is more varied. For purposes of our analysis, we assumed that 60% of the domestically sourced imported power was coal and 40% was natural gas. Though there is some wind power in the region, transfer of that source of power across state lines is rare to date. Consequently, there is an overall impact to the grid percentages from these, but it is partially offset by the influx of hydroelectric power from Canada.

The Hydroelectric power contribution to the Minnesota grid is substantial – moving the composition due to it from 1.6% to 12.6% (based on 2019 actuals). The GHG impacts associated with hydroelectric power are discussed further below.

C. Implications for Hydroelectric Power

The calculation of GHGs emitted from electricity production provided by the State fail to properly include emissions from electricity generation by hydroelectric sources. Although reservoirs are often thought of as carbon-neutral sources of energy, a growing body of publications has documented their role as significant GHG sources.

Imported Electricity from Hydroelectric Sources

In 2019, Minnesota consumed more electricity than it was able to produce resulting in the importation of approximately 18% of its consumed electricity. Of this 18%, approximately 12% was imported from Canada and 6% from neighboring states. The portion imported from Canada is most likely sourced from hydroelectric power plants located in the Canadian Province of Manitoba5.

5 EIA data providing Canadian imported generation and inter-state generation was provided via email from Glenn McGrath, Leader, Electricity Statistics Uranium Statistics and Product Innovation Team, dated March 4, 2021. 9

While hydroelectric generation plants do not use fossil fuels to operate, GHGs are still emitted due to biomass decay within the dam’s reservoir as described below:

 Flooding of terrestrial organic matter causes anaerobic decomposition of plant and animal matter which is then released to the atmosphere as methane6;

 Reservoirs which experience great fluctuations in water level have drops in hydrostatic pressure during water level drawdowns which can accelerate methane emissions. This effect called “enhanced ebullition” may then decrease the fraction of methane that is oxidized to carbon dioxide, a less potent GHG, by methane oxidizing microbes 7,8 ; and,

 Formation of the reservoir displaces the existing ecosystem which further results in a reduction in carbon uptake compared to pre-flooding conditions.

GHG emissions from hydroelectric power generation are greatest in sources with a manmade reservoir (though effects from in-river configurations may have some off-gassing as well). The extent of GHG emission is notably variable from source to source, and is dependent upon many factors including geography, temperature, latitude, topography, and local ecosystem vegetation.

A 2016 study by Scherer and Pfister includes analysis of 1,469 hydroelectric dams.9 The carbon dioxide

equivalent (CO2e) for the dams studied range from almost negligible to greater than those from a natural gas power plant. The significant variability in the GHGs emitted, warrants careful selection criteria when choosing hydroelectric power sources for use in Minnesota. Included in the study are five Manitoba dams shown in Table 1 for reference.

6 Bridget R. Deemer, Greenhouse Gas Emissions from Reservoir Water Surfaces: A New Global Synthesis BioScience, Volume 66, Issue 11, 1 November 2016.

7 Maeck A Hofmann, H Lorke. 2014. Pumping methane out of aquatic sediments: Ebullition forcing mechanisms in an impounded river. Biogeosciences 11 2925 2938.

8 Kiene RP. 1991. Production and consumption of methane in aquatic systems Pages 111-146, Rogers JE Whitman Microbial Production and of Greenhouse Gases: Methane, Nitrogen Oxides, and Halomethanes. American Society for Microbiology

9 Hydropower’s Biogenic Carbon Footprint. Scherer, Pfister. 2016. https://doi.org/10.1371/journal.pone.0161947

Table 1 - CO2e Emissions for Hydroelectric Power Sources in Manitoba Province Canada, Excerpted from Scherer, Pfister 2016

Hydroelectric Source CO2e (ton/MWh) Limestone 0.113 Long Spruce 0.117 Kelsey 0.239 Kettle 0.271 McArthur 0.334 Canada (country average) 0.400

For 2019, 12.61% of the electricity consumed in Minnesota is from hydroelectric sources (provided the 12% of imported electricity was in fact generated in Manitoba). Negating emissions from hydroelectric power generation underestimates emissions by 10% (for a 2019 base year estimate). 10

Future Grid Projections for Renewable Sources

The percent of electricity sourced from renewables in Table 5 to Appendix 1: Technical Support Document, provide a range of renewable production of 31.7% - 35.1% from 2025 to 2034 where hydroelectric electricity generation is classified as a renewable. The emissions reduction cited for the future case fails to include the emissions of GHGs from hydroelectric electricity generation sources. As the range of emissions varies greatly source to source, Minnesota state legislators are urged to provide documentation on the following:

 Ensuring the sourcing of imported electricity from Canada is known down to the specific dam from which electricity is being purchased (not simply the provider);

 Requiring the dam from which electricity is purchased to have a detailed GHG emissions analysis and provide the annualized impact to the State; and,

 Facilitatating a preferential policy for purchasing electricity from Canada where the lowest GHG emitters are selected.

D. Power Plant Grid Changes Over Time

In reference to the power generation resource mix, both the SONAR (page 21 of 99) and Technical Appendix 1 (page 31 of 110) reference the use of the Midcontinent Independent System Operator (MISO) North mix as the source of generation mix.

Citing Page 21 of 99 of the SONAR, “EVs will continue to get cleaner over time as they rely increasingly on renewable energy and other cleaner and less carbon-intensive fuels.” However, the expanded Table 5 to Technical Appendix 1 (shown below) was developed to suggest that the displacement of coal for

10 Using the average CO2e emission factor for Canada – corrected values - from Scherer, Pfister 2016. 11 natural gas is not consistent with actual 2019 data – you can’t claim future progress when you have not properly characterized the starting point.

Table 5: Projected Minnesota electricity generation mix - with Additional Values Added by JBE in Blue Fill Model Year Residual Oil Natural Gas Coal Nuclear Biomass Others (Solar, Imported Wind, Hydro) Electricity 2025 0.30% 13.30% 31.30% 20.90% 2.50% 31.70% 2026 0.20% 13.80% 29.40% 21.30% 2.40% 32.90% 2027 0.20% 20.10% 24.00% 20.40% 2.20% 33.10% 2028 0.20% 19.00% 23.90% 20.70% 2.20% 34.00% 2029 0.20% 21.10% 22.80% 19.70% 1.70% 34.50% 2030 0.20% 20.80% 22.40% 19.70% 1.70% 35.10% 2031 0.20% 20.80% 22.40% 19.70% 1.70% 35.10% 2032 0.20% 20.80% 22.40% 19.70% 1.70% 35.10% 2033 0.20% 20.80% 22.40% 19.70% 1.70% 35.10% 2034 0.20% 20.80% 22.40% 19.70% 1.70% 35.10% 2019 Actuals Electricity 0.07% 17.48% 24.83% 19.89% 1.08% 18.54% 18.11% Generated In-State

Electricity - - - - - 11.26% 11.26% Imported from Canada Electricity - 2.74% 4.11% - - - 6.85% Imported from Inter-State Grid Based on 0.07% 20.22% 28.94% 19.89% 1.08% 29.81% Consumption

Based on Table 5, there would be no change in natural gas grid makeup from 2019 out to 2034 when accounting for actual electricity consumption data (despite Minnesota’s claim that it plans to build a new natural gas power plant). Similarly, the decrease shown for residual oil, nuclear, and biomass shows no change from 2019 actuals to the projected 2034 grid.

The only category that “moves” is the “other” category; a 5% increase in renewables does not seem to justify the GHG benefit relayed in Appendix 1. Furthermore, neither the SONAR nor the attachments provide information on what type of renewable (solar, wind, or hydro) will increase over time. Is this actually imported hydroelectric power, and have its impacts been properly evaluated? The data presented in the graphs SONAR has prepared shows a 100% renewables bar – under what scenario is that possible in the foreseeable future in Minnesota?

Further, neither the SONAR nor Technical Appendix 1 provides analysis for the additional electricity consumption Minnesota will require based on the ZEV rule (plus any other active legislative actions to electrify industry). Where will the power plant capacity to support this growth come from? In order to adequately convey this, Table 5 requires production capacity data for both in-state production plus the

additional electricity that will be required from import.

E. Power Plant PM2.5 Emissions Change

SONAR documents have provided extensive comments on the advantage of operating EVs that do not produce air emissions in the breathing zone of urban populations. In this discussion, no mention is made of the change that would result in power plant emissions. While there would be no vehicle operation PM emissions (beyond those from tire wear) for EV operation, actual emissions inventory data from power

plants confirms that substantially more PM2.5 emissions (45% more) will occur at the power plant than those avoided from a gas engine vehicle operation.

What are the implications of these additional emissions from the power plant? The 45% more emissions may be emitted from a facility that has already installed Best Available Control Technology (BACT). More robust control systems for particulates may not be possible, let alone cost effective or practical. If not, then the surrounding population would just see more emissions. Though emitted from tall stacks, there

are climatic situations that can force particulates downward towards receptors. Studies done on PM2.5 overseas have resulted in significant risk findings in some settings.11,12

This is another example of a trade-off effect that is a consequence of a life cycle assessment that must be considered carefully. This is not to say that urban emission reductions are not desirable; clearly they are. But if they come at a cost, that cost must also be considered carefully.

This may be a situation where a compromise might be the right solution. Consider the role of a Plug-in Hybrid Electric Vehicle (PHEV) which would provide electric operation for short distances in the city, but rely on gasoline for long distance travel. This would reduce urban particulate emissions while operating there, but also reduce the increase in particulate emissions at the power plant by using gasoline on longer distance travel. This solution also might serve as a convenient bridge to overcome the shortage of charging infrastructure near-term (or even reduce the need for it somewhat; or delay the need for it).

F. Limitations on Expanding Solar and Wind in Minnesota

In order to expand the use of wind as a power plant alternative, the combination of wind availability based on weather and topography (e.g., tree cover, downwash from buildings, etc.), proximity to users and economics must all be considered. The National Renewable Energy Laboratory (NREL) has performed a siting study for Minnesota (and two other states). 13 While a large number of sites were

11 Gao, Beig, Song, Zhang et al, “The impact of power generation emissions on ambient PM2.5 pollution and human health in China and India,” Environment International 121 (2018) pp 250-259. https://www.sciencedirect.com/science/article/pii/S0160412018313369

12 Chio, Lo, Tsuang, Hu et al “Health Impact Assessment of PM2.5 From a Planned Coal-Fired Power Plant in Taiwan”, Journal of Formosan Medical Association (2019) 118, pp 1494-1503. https://www.sciencedirect.com/science/article/pii/S0929664619301937

13 McCabe, Sigrin, Lantz, Mooney, “Assessment of the Economic Potential of Distributed Wind in Colorado, Minnesota and New York,” National Renewable Energy Laboratory (NREL), Technical Report NREL/TP-6A20-70547, January 2018. https://www.nrel.gov/docs/fy18osti/70547.pdf

identified, a fair number of those may have already been implemented. The study data was performed in 2018 and almost three years have now passed since then. Before counting on the ability to expand, this study should be reviewed with the context of mapping potential sites to those already developed so that the true future potential is properly determined both for the present and over the next ten years.

Limitations on solar power use in the state also result from the extremely important need to keep snow off the panels in winter. 14 When coupling this with the limited solar available hours for the state of Minnesota, expectations that solar can grow to a major portion of the grid over time seem unrealistic. An important aspect to keep in mind is that clearing land for a large solar array is unacceptable as it creates what is called “land use change,” which is a term describing the reduction in carbon sequestration capability when vegetation surface area is reduced.

The grid change forecasted currently by the SONAR documents does not show a large increase in wind and solar currently, but as changes in the plan evolve, these limitations need to be considered.

14 Institute for Energy Research (IER), “Solar Panels Perform Poorly in Minnesota During Winter Months,” (2020) https://www.instituteforenergyresearch.org/about/ier-site-manager/articles 14

Appendix B – Supporting Emission Calculations

GHG Impact Comparison for Internal Combustion Engine and Zero Emission Electric Vehicles Emissions Comparison for Baseline Year 2019 GHG Data ICEV EV EV Footnotes Conventional Conventional Minnesota Components (g/car) Parts 4,520,767 4,130,652 4,130,652 Footnote 1 Assembly, Disposal, Recycling 921,259 921,259 921,259 Footnote 1 Batteries 40,008 1,636,283 1,636,283 Footnote 1 Fluids 806,958 213,190 213,190 Footnote 1 Total 6,288,993 6,901,385 6,901,385

Vehicle Lifetime (miles) 173,151 121,206 121,206 Footnote 2

Vehicle GHG Data (g CO2e/mile) Parts 26 34 34 Footnote 3 Assembly, Disposal, Recycling 5 8 8 Footnote 3 Batteries 0 14 14 Footnote 3 Fluids 5 2 2 Footnote 3 Total Vehicle Cycle (Components) 36 57 57

Operation Data (g CO2e/mile) Fuel Production 77 17 17 Footnotes 4, 5 Power Plant Combustion - 149 309 Footnote 6 Vehicle Operation 267 - - Footnote 7 Total 344 166 326

Grand Total (g/mile) 380 223 383

Notes:

(1) Emissions in grams for vehicle production Components, ADR, Batteries, and Fluids are based on Argonne National Laboratory’s Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation Series Model 2 published in 2020 (GREET2). Within GREET2, tabs 'Vehi_Comp_Sum', 'Vehi_ADR', 'Battery_Sum', and 'Vehi_Fluids' are used.

(2) The total miles within the vehicle life is based on values provided by GREET 2. (3) To obtain emissions in grams of pollutant per vehicle mile, the total emissions in grams (obtained from GREET 2) are divided by the total expected average vehicle lifetime miles. (4) Emissions in grams of pollutant per vehicle mile for the fuel production portion for ICEVs is based on GREET2, tab 'TEC_Results', Section Gasoline Vehicle - WTP.

(5) Emissions in grams of pollutant per vehicle mile for the fuel production portion for EVs is based on the Fuel-Cycle Energy Use and Emissions of Electric Generation provided by GREET2, tab 'GREET1_Import_Export' and on the fuel fraction dependent on the Minnesota resource mix. Detailed calculations can be found in the fuel production worksheet.

(6) Emissions in g/mile for EVs due to power plant combustion are calculated using 2019 EIA data for the Minnesota grid. Detailed emission calculations are provided in Appendix B to this report. (7) Emissions in g/mile for ICEVs is based on the weighted average EPA mpg combined fuel efficiency rating of the 5 top selling 4-door passenger cars. (8) The 2019 power grid resource mix is used to determine the fuel fraction; the mix is based on 2019 EIA-Form 923 net electricity generation data.

Supporting Calculations to Comments on Proposed Regulation: Clean Cars Minnesota, Minnesota Rules, Ch. 7023, Revisor’s ID Number 04626, OAH Docket Number 71-9003-36416 Fuel Production Emissions Impact Review of Proposed Zero Emission Vehicle (ZEV) Rule AQ-RULE-4-10

Fuel Production Impact Summary by Pollutant

Pollutant Fuel Production Impact Power Production Phase (g/mile)

CO2e 16.791 VOC 0.014

NOX 0.035 CO 0.018 PM10 0.011 PM2.5 0.009 SO2 0.015

Fuel Production Sample Calculation:

Fuel Production Emissions Portion (g CO2e/mile =

∑ 퐹푢푒푙 퐶푦푐푙푒 퐸푛푒푟푔푦 푈푠푒 (푔 /푀푀퐵푡푢) 푋 3,412 (퐵푡푢/푘푊ℎ) 푋 1 (푀푀퐵푡푢/퐵푡푢) 푋 1,000 (푘푊ℎ/푀푊ℎ) 푋 0.001 (푀푊ℎ/푘푊ℎ) 푋 퐸푛푒푟푔푦 퐶표푛푠푢푚푝푡푖표푛 (푘푊ℎ/푚푖푙푒) 푋 퐹푢푒푙 퐹푟푎푐푡푖표푛

Estimated EV 0.4 kWh/mile Efficiency

CO2e Conversion (1) (2) Greet 1 Match to Minnesota Grid g CO2e/MMBtu g/kWh kWh/mile g CO2e/mile Fuel Fraction Sum Product Fuel Type Category Oil DFO 39,057 133.27 0.4 53.31 0.07% 0.036 Natural Gas NG; Imports NG 19,877 67.82 0.4 27.13 20.22% 5.485 Coal BIT; LIG; RC; SUB; Imports Coal 17,725 60.48 0.4 24.19 28.94% 7.001 Biomass AB; LFG; MSB; MSN; OBG; WDS; WH 10,101 34.47 0.4 13.79 1.08% 0.149 Nuclear NUC 2,225 45.36 0.4 18.14 19.89% 3.609 Solar SUN 72.57 0.4 29.03 1.76% 0.511 Other Renewable SUN, WAT, WIND - - 0.00 - 28.04% 0.000 Total: 16.791

VOC Conversion (2) Greet 1 Match to Minnesota Grid g VOC/MMBtu g/kWh kWh/mile g CO2e/mile Fuel Fraction Sum Product Fuel Type Category Oil DFO 18.56 0.06 0.4 0.03 0.07% 0.000 Natural Gas NG; Imports NG 17.99 0.06 0.4 0.02 20.22% 0.005 Coal BIT; LIG; RC; SUB; Imports Coal 21.86 0.07 0.4 0.03 28.94% 0.009 Biomass AB; LFG; MSB; MSN; OBG; WDS; WH 4.48 0.02 0.4 0.01 1.08% 0.000 Nuclear NUC 0.95 0.00 0.4 0.00 19.89% 0.000 Other Renewable SUN, WAT, WIND - - 0.00 - 29.81% 0.000 Total: 0.014

NOX Conversion (2) Greet 1 Match to Minnesota Grid g NOX/MMBtu g/kWh kWh/mile g CO2e/mile Fuel Fraction Sum Product Fuel Type Category Oil DFO 74.46 0.25 0.4 0.10 0.07% 0.000 Natural Gas NG; Imports NG 61.87 0.21 0.4 0.08 20.22% 0.017 Coal BIT; LIG; RC; SUB; Imports Coal 39.24 0.13 0.4 0.05 28.94% 0.015 Biomass AB; LFG; MSB; MSN; OBG; WDS; WH 39.49 0.13 0.4 0.05 1.08% 0.001 Nuclear NUC 5.09 0.02 0.4 0.01 19.89% 0.001 Other Renewable SUN, WAT, WIND - - 0.00 - 29.81% 0.000 Total: 0.035

CO Conversion (2) Greet 1 Match to Minnesota Grid g CO/MMBtu g/kWh kWh/mile g CO2e/mile Fuel Fraction Sum Product Fuel Type Category Oil DFO 33.68 0.11 0.4 0.05 0.07% 0.000 Natural Gas NG; Imports NG 48.45 0.17 0.4 0.07 20.22% 0.013 Coal BIT; LIG; RC; SUB; Imports Coal 8.42 0.03 0.4 0.01 28.94% 0.003 Biomass AB; LFG; MSB; MSN; OBG; WDS; WH 18.29 0.06 0.4 0.02 1.08% 0.000 Nuclear NUC 3.90 0.01 0.4 0.01 19.89% 0.001 Other Renewable SUN, WAT, WIND - - 0.00 - 29.81% 0.000 Total: 0.018

Supporting Calculations to Comments on Proposed Regulation: Clean Cars Minnesota, Minnesota Rules, Ch. 7023, Revisor’s ID Number 04626, OAH Docket Number 71-9003-36416 PM10 Conversion (2) Greet 1 Match to Minnesota Grid g PM10/MMBtu g/kWh kWh/mile g CO2e/mile Fuel Fraction Sum Product Fuel Type Category Oil DFO 4.88 0.02 0.4 0.01 0.07% 0.000 Natural Gas NG; Imports NG 0.95 0.00 0.4 0.00 20.22% 0.000 Coal BIT; LIG; RC; SUB; Imports Coal 25.63 0.09 0.4 0.03 28.94% 0.010 Biomass AB; LFG; MSB; MSN; OBG; WDS; WH 2.39 0.01 0.4 0.00 1.08% 0.000 Nuclear NUC 0.31 0.00 0.4 0.00 19.89% 0.000 Other Renewable SUN, WAT, WIND - - 0.00 - 29.81% 0.000 Total: 0.011

PM2.5 Conversion (2) Greet 1 Match to Minnesota Grid g PM2.5/MMBtu g/kWh kWh/mile g CO2e/mile Fuel Fraction Sum Product Fuel Type Category Oil DFO 35.38 0.12 0.4 0.05 0.07% 0.000 Natural Gas NG; Imports NG 3.24 0.01 0.4 0.00 20.22% 0.001 Coal BIT; LIG; RC; SUB; Imports Coal 13.20 0.05 0.4 0.02 28.94% 0.005 Biomass AB; LFG; MSB; MSN; OBG; WDS; WH 186.16 0.64 0.4 0.25 1.08% 0.003 Nuclear NUC - - 0.4 - 19.89% 0.000 Other Renewable SUN, WAT, WIND - - 0.00 - 29.81% 0.000 Total: 0.009

SO2 Conversion (2) Greet 1 Match to Minnesota Grid g SO2/MMBtu g/kWh kWh/mile g CO2e/mile Fuel Fraction Sum Product Fuel Type Category Oil DFO 26.68 0.09 0.4 0.04 0.07% 0.000 Natural Gas NG; Imports NG 23.68 0.08 0.4 0.03 20.22% 0.007 Coal BIT; LIG; RC; SUB; Imports Coal 19.90 0.07 0.4 0.03 28.94% 0.008 Biomass AB; LFG; MSB; MSN; OBG; WDS; WH 0.86 0.00 0.4 0.00 1.08% 0.000 Nuclear NUC 2.51 0.01 0.4 0.00 19.89% 0.001 Other Renewable SUN, WAT, WIND - - 0.00 - 29.81% 0.000 Total: 0.015

2019 Minnesota Consumption - Power Grid Resource Mix, Including In-State Generation and Imports

Fuel Type Code Fuel Type Description 2019 Net Electricity Percent of Total Grid Generation (3) (MWh) (%) AB Agricultural Crop Byproducts 42,690.1 0.06% BIT Bituminous Coal 0.0 0.00% DFO Distillate Fuel Oil 47,315.3 0.07% LFG Landfill Gas 73,695.8 0.10% LIG Lignite Coal 0.0 0.00% MSB MSW Other 195,673.4 0.28% MSN MSW Other 239,158.6 0.34% NG Natural Gas 12,393,565.1 17.48% NUC Nuclear 14,104,547.0 19.89% OBG Other Biomass Gas 15,241.0 0.02% RC Minimum Reflectance Bituminous Coal 4,718,307.1 6.65% SUB Subbituminous Coal 12,886,397.1 18.18% SUN Solar 1,248,467.0 1.76% WAT Hydroelectric/Hydrokinetic 959,489.5 1.35% WDS Wood/Wood Waste Solids 160,013.4 0.23% WH Waste Heat 38,286.0 0.05% WND Wind 10,940,308.6 15.43% Imports - WAT Canadian Imports Hydro from Manitoba 7,983,973.0 11.26% Imports - COL Inter-State Imports of Coal 2,912,431.8 4.11% Imports - NG Inter-State Imports of NG 1,941,621.2 2.74% Total 70,901,181.1 100.00%

Conversion Factors: BTU/kWH 3,412.14 MMBTU/BTU 1.00E-06 kWH/MWH 1,000.00 MWH/kWH 1.00E-03

Notes: (1) Emission factor in grams per MMBtu for criteria pollutants and GHGs is based on GREET 1 (2020), tab 'Electric', Section (9) Fuel-Cycle Energy Use, Water Consumption, and Emissions of Electric Generation: Btu or Gallons or Grams per MMBtu of Electricity Available at User Sites (wall outlets). The total for 'fuel' is used. (2) According to the EIA, in 2019, 18% of the electricity consumed in Minnesota was imported from Canada and inter-state transfers. The grid used in this calculation assumes 82% of the consumed electricity was generated in state (assuming all electricity generated in-state was consumed, and the remaining portion of that consumed was imported). The total electricity imported from Canada and the total imported from inter-state transfers was obtained from the EIA. The source of production was assumed as follows: 12% of the 18% imported came from Canada - hydro from Manitoba is assumed; the remaining 6% is estimated to be a 60/40 split of coal and NG from North Dakota and Wisconsin. Refer to Attachment B of this submittal for additional data on the 2019 power resource mix.

Supporting Calculations to Comments on Proposed Regulation: Clean Cars Minnesota, Minnesota Rules, Ch. 7023, Revisor’s ID Number 04626, OAH Docket Number 71-9003-36416 Calculation Adjustment to Vehicle Operation to Reflect State-Specific Vehicle Mile per Gallon Fleet

Data Inputs: Parameter Value Unit Low Heating Value of Gasoline 0.116 MMBtu/gallon MPG Basis for GREET2 Result (U.S. Nation-wide Basis) 26.08 miles/gallon MPG for existing Minnesota Fleet (1) 32.47 miles/gal

GREET 2 Vehicle Operation Emission Estimates with 26.08 MPG Fleet Basis: Pollutant Value Unit

CO2e

Vehicle Operation GREET2 Result 332.26 g CO2e/mile

Emission Factor, GREET2 Basis 74,701.01 g CO2e/MMBtu

NOX

Vehicle Operation GREET2 Result 0.12 g NOX/mile

Emission Factor, GREET2 Basis 26.99 g NOX/MMBtu VOC Vehicle Operation GREET2 Result 0.24 g VOC/mile Emission Factor, GREET2 Basis 53.71 g VOC/MMBtu CO Vehicle Operation GREET2 Result 2.70 g CO/mile Emission Factor, GREET2 Basis 607.82 g CO/MMBtu

PM10

Vehicle Operation GREET2 Result 0.02 g PM10/mile

Emission Factor, GREET2 Basis 5.26 g PM10/MMBtu

PM2.5

Vehicle Operation GREET2 Result 0.01 g PM2.5/mile

Emission Factor, GREET2 Basis 2.11 g PM2.5/MMBtu

SO2

Vehicle Operation GREET2 Result 0.002 g SO2/mile

Emission Factor, GREET2 Basis 0.44 g SO2/MMBtu

Minnesota Factor - Calculation of Emissions Contribution from Vehicle Operation for ICEVs: Calculated Impact Factor for Minnesota Value Unit

CO2e 266.87 g CO2e/mile

NOX 0.10 g NOX/mile VOC 0.19 g VOC/mile CO 2.17 g CO/mile

PM10 0.02 g PM10/mile

PM2.5 0.01 g PM2.5/mile

SO2 0.002 g SO2/mile

(1) MPG for existing Minnesota fleet is based on the arithmetic average EPA mpg combined fuel efficiency rating of the 5 top selling 4-door passenger cars.

Supporting Calculations to Comments on Proposed Regulation: Clean Cars Minnesota, Minnesota Rules, Ch. 7023, Revisor’s ID Number 04626, OAH Docket Number 71-9003-36416 Greenhouse Gas Emissions Review of Proposed Zero Emission Vehicle (ZEV) Rule AQ-RULE-4-10

In 2019, Minnesota consumed more electricity than it generated in-state. To meet demand, Minnesota imported approximately 18% of its total consumed electricity from Canada and neighboring states. Of the 18% imported, approximately 62% is from international imports via Canada. This analysis estimates the international imported electricity is sourced from hydroelectric dams in Manitoba, Canada. Interstate imports are estimated to be comprised of 60% coal and 40% natural gas from neighboring North Dakota an Wisconsin. This analysis assumes electricity generated in Minnesota is consumed in-state.

Electricity Generation Emission Factor Determination by Fuel Type: Factors Based on Facility Data Final Factors with Data Substitution

Fuel Type Code Fuel Type Description 2019 Net Electricity CO2e CO2e Basis Note Generation for Plants with (Biogenic and Non-Biogenic (Biogenic and Non-Biogenic Aggregated) GHG Emissions Data (1) Aggregated) (MWh) (U.S. ton/MWh) (U.S. ton/MWh) - AB Agricultural Crop Byproducts/Straw/Energy Crops 42,690.1 0.35 0.35 - BIT Bituminous Coal No Data No Data - Not in 2019 Grid DFO Distillate Fuel Oil 5,304.8 1.22 1.22 - LFG Landfill Gas 28,629.8 0.60 0.60 - LIG Lignite Coal No Data No Data - Not in 2019 Grid MSB MSW Other No Data No Data 2.11 Set equal to MSN - MSW Other MSN MSW Other 236,681.7 2.11 2.11 - NG Natural Gas 12,170,616.3 0.47 0.47 - NUC Nuclear 14,104,547.0 0.00 0.00 - OBG Other Biomass Gas 15,241.0 0.11 0.11 - RC Minimum Reflectance Bituminous Coal 4,718,307.1 1.19 1.19 - SUB Subbituminous Coal 12,973,213.5 1.18 1.18 - SUN Solar No Data No Data 0.00 Assumed Zero WAT Hydroelectric/Hydrokinetic 8,686.5 0.02 0.37 Scherer, Pfister 2016 (7) WDS Wood/Wood Waste Solids 146,111.4 1.11 1.11 - WH Waste Heat No Data No Data 0.00 Negated WND Wind 22,131.0 0.03 0.03 -

Electricity Generation Emission Factor Total Accounting for 2019 Minnesota Power Grid Resource Mix:

(2) Fuel Type Code Fuel Type Description 2019 Net Electricity Percent of Total Grid CO2e Generation (3) (MWh) (%) (U.S. ton/MWh) AB Agricultural Crop Byproducts/Straw/Energy Crops 42,690.1 0.07% 0.000 BIT Bituminous Coal 0.0 0.00% 0.000 DFO Distillate Fuel Oil 47,315.3 0.08% 0.001 LFG Landfill Gas 73,695.8 0.13% 0.001 LIG Lignite Coal 0.0 0.00% 0.000 MSB MSW Other 195,673.4 0.34% 0.007 MSN MSW Other 239,158.6 0.41% 0.009 NG Natural Gas 12,393,565.1 21.34% 0.101 NUC Nuclear 14,104,547.0 24.29% 0.000 OBG Other Biomass Gas 15,241.0 0.03% 0.000 RC Minimum Reflectance Bituminous Coal 4,718,307.1 8.13% 0.097 SUB Subbituminous Coal 12,886,397.1 22.19% 0.262 SUN Solar 1,248,467.0 2.15% 0.000 WAT Hydroelectric/Hydrokinetic 959,489.5 1.65% 0.006 WDS Wood/Wood Waste Solids 160,013.4 0.28% 0.003 Represents WH Waste Heat 38,286.0 0.07% 0.000 82% of WND Wind 10,940,308.6 18.84% 0.005 Consumed Total 58,063,155.1 100.00% 0.492 Electricity

Supporting GHG Emissions Calculation to Comments on Proposed Regulation: Clean Cars Minnesota, Minnesota Rules, Ch. 7023, Revisor’s ID Number 04626, OAH Docket Number 71-9003-36416 Greenhouse Gas Emissions Review of Proposed Zero Emission Vehicle (ZEV) Rule AQ-RULE-4-10

Imported Electricity Emission Factor Determination by Fuel Type:

Origin 2019 Net Electricity Generation (8) Percent of Purchases (MWh) (%) Imports from Canada 7,983,973 62% Net interstate imports 4,854,053 38% Total: 12,838,026 100%

Source Mix 2019 Net Electricity Generation Net interstate imports (MWh) (%) Coal 2,912,432 60% NG 1,941,621 40% Total: 4,854,053 100%

Surrogate EF (2) Fuel Type Code Fuel Type Description 2019 Net Electricity Percent of Imported Grid CO2e CO2e Generation (Biogenic and Non-Biogenic Aggregated)

(MWh) (%) (U.S. ton/MWh) (U.S. ton/MWh) COAL Coal (all types) 2,912,432 22.69% 1.18 0.269 Represents NG Natural Gas 1,941,621 15.12% 0.47 0.071 18% of WAT Hydroelectric/Hydrokinetic 7,983,973 62.19% 0.40 0.249 Consumed Total: 12,838,026 100.00% - 0.589 Electricity

Weighted Average Factor - Generated and Imported

(2) Source Percent of Consumption CO2e (%) (U.S. ton/MWh) Electricity Generated In-state 82% 0.492 Electricity Imported 18% 0.589 Total Weighted Factor: 0.509

Independently Calculated g/mile Emission Factor for Electric Cars Based on Minnesota-Specific Power Grid Resource Mix: EV (kWh/mile) (4) 0.4 (5) EV Net (g CO2e/mile) 204

Adjusted EV Emission Factor - Adjusting for Battery Loss, Transmission Line Losses, Temperature Effects on Battery Life, and Battery Degradation

EV (kWh/mile) (4) 0.4 Adjustment for 15% Battery Loss and 7% Transmission Line Loss 223 Adjustment of 20% for Cold Ops Net g/mile 279 Adjustment of 10% for Battery Age Net g/mile 309 Independent Minnesota-Specific Emission Factor for EV g/mile: 309 Argonne's GREET2 Emission Factors for Reference/Comparison (6): EV GREET2 (WTP) (g/mile) 149 ICEV GREET2 (g/mile) 332

Notes:

(1) For emission factor determination for greenhouse gases, the total net electricity generation shown in Column C only shows generation values for plants where emissions data was available from the 2019 State Annual Emissions Inventory and/or 40 CFR 98 Part 98 Reports. Facilities without electricity generation data from the 2019 EIA Form 923 or emissions data from the EI/e-GRRT are not included in determining the emission factor by fuel category. Additionally, if the 2019 EIA Form 923 showed no electricity generation for a specific facility, those facilities, too, are excluded from emission factor determination. A complete list of facilities included in the determination of emission factors is provided within this appendix.

(2) Greenhouse gas emissions for calendar year 2019 were obtained from the e-GGRT dataset (part of mandatory greenhouse gas reporting under 40 CFR Part 98). Note small facilities (less than 25,000 metric tons of CO 2e) are not required to report emissions under 40 CFR Part 98 and, thus, not included in emission factor determination unless a State Emissions Inventory for the facility was available, where upon the facility would be, then, included.

(3) The adjusted emission factor is calculated as follows:

(i) CO2e emissions (ton CO2e) / Net electricity generation aggregated for fuel subcategory (MWh) = equals Emission Factor (tons CO2e/MWh), (unadjusted for grid)

(ii) Power Grid Resource Mix n% (for fuel subcategory, corresponding to n) X unadjusted emission factor equals adjusted factor (tons CO2e /MWh).

(4) kWh per mile factor is based on the average energy consumption for 2019 4-door passenger vehicles, obtained from the EPA testing dataset published with the US DOE Office of Energy Efficiency and Renewable Energy.

(5) Emission factor (g CO2e/mile) = Emission factor for CO2e (metric ton/MWh) X kWh/mile X (1MW/ 1,000 kW) X (1,000,000 gram/ 1 metric ton)

(6) For comparison and reference only, emission factors for each criteria pollutant are shown as published in Argonne National Library's The Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation Mode (GREET2 2020). Note the GREET2 factors do not debit for transmission loss, battery charging or discharging losses, for decreased efficiency during useful life or due to low temperature use.

(7) GHG emission factors for hydroelectric dams are national averages for the U.S. developed by Laura Scherer, Stephan Pfister, Hydropower’s biogenic carbon footprint, Institute of Environmental Engineering, ETH Zurich, 8093 Zurich, Switzerland. References: Barros N, Cole JJ, Tranvik LJ, Prairie YT, Bastviken D, Huszar VLM, et al. Carbon emission from hydroelectric reservoirs linked to reservoir age and latitude. Nat Geosci. 2011; 4: 593–596. doi: 10.1038/ngeo1211. Published in 2016. (8) Imported electricity data was provided by the Electricity Statistics Uranium Statistics and Product Innovation Team U.S. Energy Information Administration.

Conversion Factors:

MW to kW 1,000

kg to U.S. ton 0.0011023

Supporting GHG Emissions Calculation to Comments on Proposed Regulation: Clean Cars Minnesota, Minnesota Rules, Ch. 7023, Revisor’s ID Number 04626, OAH Docket Number 71-9003-36416 Criteria Emissions Review of Proposed Zero Emission Vehicle (ZEV) Rule AQ-RULE-4-10

Electricity Generation Emission Factor Determination by Fuel Type: Factors Based on Facility Data (1) (1) (1) (1) Fuel Type Code Fuel Type Description 2019 Net Electricity CO NOX PM10 PM2.5 SO2 VOC Generation for Plants with (Filterable plus (Filterable plus (1) Criteria Emissions Data Condensable) (1) Condensable) (1) (MWh) (tons/MWh) (tons/MWh) (tons/MWh) (tons/MWh) (tons/MWh) (tons/MWh) AB Agricultural Crop Byproducts/Straw/Energy Crops 42,690.1 0.00659 0.00502 0.00069 0.00068 0.00097 0.00003 BIT Bituminous Coal No Data No Data No Data No Data No Data No Data No Data DFO Distillate Fuel Oil 5,304.8 0.00245 0.01685 0.00074 0.00073 0.00055 0.00080 LFG Landfill Gas 28,629.8 0.00160 0.00041 0.00004 0.00004 0.00002 0.00022 LIG Lignite Coal No Data No Data No Data No Data No Data No Data No Data MSB MSW Other No Data No Data No Data No Data No Data No Data No Data MSN MSW Other 236,681.7 0.00098 0.00776 0.00013 0.00011 0.00062 0.00000 NG Natural Gas 12,154,098.9 0.00008 0.00008 0.00001 0.00000 0.00000 0.00001 NUC Nuclear 14,104,547.0 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 OBG Other Biomass Gas 15,241.0 0.00024 0.00116 0.00013 0.00010 0.00036 0.00011 RC Minimum Reflectance Bituminous Coal 4,718,307.1 0.00050 0.00050 0.00009 0.00005 0.00012 0.00000 SUB Subbituminous Coal 12,973,213.5 0.00015 0.00082 0.00011 0.00007 0.00066 0.00002 SUN Solar No Data No Data No Data No Data No Data No Data No Data WAT Hydroelectric/Hydrokinetic 8,686.5 0.00003 0.00047 0.00002 0.00002 0.00003 0.00004 WDS Wood/Wood Waste Solids 35,522.3 0.01914 0.01698 0.00142 0.00115 0.00760 0.00076 WH Waste Heat No Data No Data No Data No Data No Data No Data No Data WND Wind 22,131.0 0.00005 0.00048 0.00001 0.00001 0.00001 0.00002

Electricity Generation Emission Factor Total Accounting for 2019 Minnesota Power Grid Resource Mix:

(2) (2) (2) (2) Fuel Type Code Fuel Type Description 2019 Net Electricity Percent of Total Grid CO NOX PM10 PM2.5 SO2 VOC Generation (3) (Filterable plus (Filterable plus Condensable) (2) Condensable) (2) (MWh) (%) (tons/MWh) (tons/MWh) (tons/MWh) (tons/MWh) (tons/MWh) (tons/MWh) AB Agricultural Crop Byproducts/Straw/Energy Crops 42,690.1 0.07% 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 BIT Bituminous Coal 0.0 0.00% 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 DFO Distillate Fuel Oil 47,315.3 0.08% 0.00000 0.00001 0.00000 0.00000 0.00000 0.00000 LFG Landfill Gas 73,695.8 0.13% 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 LIG Lignite Coal 0.0 0.00% 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 MSB MSW Other 195,673.4 0.34% 0.00000 0.00003 0.00000 0.00000 0.00000 0.00000 MSN MSW Other 239,158.6 0.41% 0.00000 0.00003 0.00000 0.00000 0.00000 0.00000 NG Natural Gas 12,393,565.1 21.34% 0.00002 0.00002 0.00000 0.00000 0.00000 0.00000 NUC Nuclear 14,104,547.0 24.29% 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 OBG Other Biomass Gas 15,241.0 0.03% 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 RC Minimum Reflectance Bituminous Coal 4,718,307.1 8.13% 0.00004 0.00004 0.00001 0.00000 0.00001 0.00000 SUB Subbituminous Coal 12,886,397.1 22.19% 0.00003 0.00018 0.00002 0.00002 0.00015 0.00000 SUN Solar 1,248,467.0 2.15% 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 WAT Hydroelectric/Hydrokinetic 959,489.5 1.65% 0.00000 0.00001 0.00000 0.00000 0.00000 0.00000 WDS Wood/Wood Waste Solids 160,013.4 0.28% 0.00005 0.00005 0.00000 0.00000 0.00002 0.00000 Represents WH Waste Heat 38,286.0 0.07% 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 82% of WND Wind 10,940,308.6 18.84% 0.00001 0.00009 0.00000 0.00000 0.00000 0.00000 Consumed Total 58,063,155.1 100.00% 0.00017 0.00046 0.00004 0.00003 0.00019 0.00001 Electricity

Supporting Criteria Pollutant Emissions Calculation to Comments on Proposed Regulation: Clean Cars Minnesota, Minnesota Rules, Ch. 7023, Revisor’s ID Number 04626, OAH Docket Number 71-9003-36416 Criteria Emissions Review of Proposed Zero Emission Vehicle (ZEV) Rule AQ-RULE-4-10

Imported Electricity Emission Factor Determination by Fuel Type:

Origin 2019 Net Electricity Generation (4) Percent of Purchases (MWh) (%) Imports from Canada 7,983,973 62% Net interstate imports 4,854,053 38% Total: 12,838,026 100%

Source Mix 2019 Net Electricity Generation Net interstate imports (MWh) (%) Coal 2,912,432 60% NG 1,941,621 40% Total: 4,854,053 100%

Surrogate EF

Fuel Type Code Fuel Type Description 2019 Net Electricity Percent of Imported CO NOX PM10 PM2.5 SO2 VOC Generation Grid (Filterable plus (Filterable plus Condensable) Condensable) (MWh) (%) (tons/MWh) (tons/MWh) (tons/MWh) (tons/MWh) (tons/MWh) (tons/MWh) COAL Coal (all types) 2,912,432 22.69% 0.00007 0.00015 0.00002 0.00001 0.00009 0.00000 Represents NG Natural Gas 1,941,621 15.12% 0.00001 0.00001 0.00000 0.00000 0.00000 0.00000 18% of WAT Hydroelectric/Hydrokinetic 7,983,973 62.19% 0.00002 0.00029 0.00001 0.00001 0.00002 0.00002 Consumed Total: 12,838,026 100.00% 0.00011 0.00046 0.00003 0.00002 0.00011 0.00003 Electricity

Weighted Average Factor - Generated and Imported

Source Percent of Consumption CO NOX PM10 PM2.5 SO2 VOC (Filterable plus (Filterable plus Condensable) Condensable) (%) (tons/MWh) (tons/MWh) (tons/MWh) (tons/MWh) (tons/MWh) (tons/MWh) Electricity Generated In-state 82% 0.00017 0.00046 0.00004 0.00003 0.00019 0.00001 Electricity Imported 18% 0.00011 0.00046 0.00003 0.00002 0.00011 0.00003 Total Weighted Factor: 0.00016 0.00046 0.00004 0.00003 0.00017 0.00002 Independently Calculated g/mile Emission Factor for Electric Cars Based on Minnesota-Specific Power Grid Resource Mix: EV (kWh/mile) (6) 0.4 0.4 0.4 0.4 0.4 0.4 EV Net (g /mile) (7) 0.058 0.167 0.014 0.010 0.063 0.006 Adjusted EV Emission Factor - Adjusting for Battery Loss, Transmission Line Losses, Temperature Effects on Battery Life, Adjustment for 15% Battery Loss and 7% Transmission Line Loss 0.063 0.183 0.016 0.011 0.069 0.006 Adjustment for 20% Cold Ops Net g/mile: 0.079 0.229 0.020 0.014 0.086 0.005 Adjustment of 10% for Battery Age Net g/mile 0.088 0.254 0.022 0.015 0.095 0.006 Independent Minnesota-Specific Emission Factor for EV g/mile: 0.088 0.254 0.022 0.015 0.095 0.006 Argonne's GREET2 Emission Factors for Reference/Comparison (8): EV GREET2 (WTP) (g/mile) 0.056 0.103 0.017 0.007 0.225 0.017 ICEV GREET2 (g/mile) 2.703 0.120 0.023 0.009 0.002 0.239

Notes:

(1) For emission factor determination, the total net electricity generation shown in Column C only shows generation values for plants where emissions data was available from the 2019 State Annual Emissions Inventory. Facilities without electricity generation data from the 2019 EIA Form 923 or emissions data from the EI are not included in determining the emission factor by fuel category. Additionally, if the 2019 EIA Form 923 showed no electricity generation for a specific facility, those facilities, too, are excluded from emission factor determination. A complete list of facilities included in the determination of emission factors is provided within this appendix.

(2) Factor for MSB category is based on MSN from facility level data obtained within the State's Annual Emissions Inventory.

(3) The adjusted emission factor is calculated as follows: (i) Emissions (ton) / Net electricity generation aggregated for fuel subcategory (MWh) = equals Emission Factor (tons/MWh), (unadjusted for grid) (ii) Power Grid Resource Mix n% (for fuel subcategory, corresponding to n) X unadjusted emission factor equals adjusted factor (tons /MWh).

(4) Imported electricity data was provided by the Electricity Statistics Uranium Statistics and Product Innovation Team U.S. Energy Information Administration.

(5) Emission factors for imported electricity are based on those determined from Minnesota data based on emission inventory and generation data.

(6) kWh per mile factor is based on the average energy consumption for 2019 4-door passenger vehicles, obtained from the EPA testing dataset published with the US DOE Office of Energy Efficiency and Renewable Energy.

(7) Emission factor (g/mile) = Emission factor for pollutant n X kWh/mile X 907,185 grams/ton X (1MW/ 1,000 kW)

(8) For comparison and reference only, emission factors for each criteria pollutant are shown as published in Argonne National Library's The Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation Mode (GREET2 2020). Note the GREET2 factors do not debit for transmission loss, battery charging or discharging losses, for decreased efficiency during useful life or due to low temperature use.

Conversion Factors:

MW to kW 1,000

kg to U.S. ton 0.0011023

grams in ton 907,185

Supporting Criteria Pollutant Emissions Calculation to Comments on Proposed Regulation: Clean Cars Minnesota, Minnesota Rules, Ch. 7023, Revisor’s ID Number 04626, OAH Docket Number 71-9003-36416 Power Plant Emission Factors Calculated Based on 2019 Actual Facility-Level Data Color Key: Typo Identified in Dataset Data Outlier Removed Value from EPA CAMD Report

Minnesota Power Generation Plants - NAICS Codes 221 EIA CO2e Part 98 2019 Annual Emissions Average e-GGRT Inventory for Minnesota

Reported Net CO2-equivalent CO2-equivalent CO2-equivalent Fuel Type Code Generation

Name as Listed in U.S. EPA Name as Listed in 2019 Annual Emissions Inventory Name as Listed on Form 923, EIA - MWh (tons) (tons) (tons) e-GGRT Reporting System for Minnesota Adrian Adrian Public Utilities DFO 91 67.68 No Data 67.68 Alexandria Alexandria Light & Power DFO 66 57.82 No Data 57.82 Allen S King Allen S King Xcel Energy - Allen S King Generating Plant SUB 1,736,143 2,009,572.13 2,008,168.52 2,010,975.75 Benson City of Benson Power Biomass Plant Benson Municipal Utilities DFO 106 74.35 74.35 Black Dog Black Dog Xcel Energy - Black Dog Generating Plant NG 1,780,228 883,741.22 883,712.01 883,770.43 Blooming Prairie Blooming Prairie Public Utilities DFO 115 67.85 No Data 67.85 Blue Earth Blue Earth Light & Water DFO 79 59.40 No Data 59.40 Blue Lake Blue Lake Generating Plant Xcel Energy - Blue Lake NG 63,960 47,688.90 47,753.17 47,624.64 Cambridge CT Hybrid Cambridge Station Great River Energy - Cambridge NG 533 31,663.18 31,660.55 31,665.81 Cannon Falls Energy Center Cannon Falls Energy Center Invenergy Cannon Falls LLC NG 100,454 72,148.01 72,148.39 72,147.62 Cascade Creek Cascade Creek Rochester Public Utilities Cascade Creek NG 19,787 13,962.74 13,962.74 Clay Boswell Boswell Energy Center Minnesota Power - Boswell Energy Center RC 4,718,307 5,604,730.55 5,603,780.28 5,605,680.82 Covanta Hennepin Energy HENNEPIN COUNTY ENERGY CENTER Hennepin Energy Recovery Center MSN 104,046 173,254.41 173,254.41 Detroit Lakes Detroit Lakes Gas Turbine DFO 36 58.39 No Data 58.39 Elk River City of Elk River Elk River Municipal Utilities LFG 24,556 17,300.76 17,300.76 Fairfax Fairfax city of Stand-by Power Plant DFO 12 15.46 No Data 15.46 Fairmont (MN) Fairmont Energy Station NG 11,753 6,693.49 No Data 6,693.49 Faribault Energy Park Faribault Energy Park Faribault Energy Park NG 751,266 328,301.73 331,187.94 325,415.52 Fergus Control Ctr DFO 20 No Data No Data No Data Glencoe Glencoe Light & Power Commission DFO 252 198.00 No Data 198.00 Grand Marais Grand Marais Public Utilities Commission DFO 225 170.14 No Data 170.14 Granite Falls Granite Falls Municipal Utilities WAT 2,930 10.76 No Data 10.76 Halstad Halstad Municipal Utilities DFO 10 14.65 No Data 14.65 Hibbing HIBBING PUBLIC UTILITIES COMMISSION Hibbing Public Utilities Commission SUB 8,120 66,469.43 66,781.25 66,157.61 High Bridge High Bridge Xcel Energy - High Bridge Generating Plant NG 3,497,026 1,543,715.99 1,543,722.32 1,543,709.66 Hometown Bio Energy LLC Hometown BioEnergy OBG 15,241 1,697.29 No Data 1,697.29 Hoot Lake Hoot Lake Otter Tail Power Co - General Office SUB 312,103 403,067.60 402,316.69 403,818.50 Hutchinson Plant #1 Hutchinson Utilities Commission - Plant 1 NG 7,372 3,805.43 No Data 3,805.43 Hutchinson Plant #2 Hutchinson - Plant 2 Hutchinson Utilities Commission -Plant 2 NG 15,568 8,814.17 8,814.17 IBM West RPU - IBM Peaking Diesel Generators DFO 46 49.05 No Data 49.05 Inver Hills Inver Hills Generating Plant Xcel Energy - Inver Hills Generating Plant NG 2,178 7,713.90 7,958.68 7,469.13 Janesville Janesville Municipal Utilities DFO 31 106.78 No Data 106.78 Kenyon Municipal Kenyon Municipal Utilities DFO 23 20.17 No Data 20.17 Koda Biomass Plant Koda Energy LLC AB 42,690 15,087.75 No Data 15,087.75 Lake Crystal Lake Crystal Utilities Commission DFO 49 39.83 No Data 39.83 Lakefield Junction Lakefield Junction Generating Great River Energy - Lakefield Junction Station NG 59,390 50,568.01 50,635.71 50,500.31 Lakefield Utilities Lakefield Public Utilities DFO 13 10.48 No Data 10.48 Lanesboro Lanesboro Public Utilities WAT 99 3.53 No Data 3.53 Litchfield Litchfield city of DFO 351 729.38 No Data 729.38 LSP-Cottage Grove LP Cottage Grove Cogeneration LSP Cottage Grove Cogeneration Facility NG 499,004 279,923.91 282,517.64 277,330.18 Luverne Luverne Municipal Power Plant DFO 18 23.18 No Data 23.18 Mankato Energy Center Mankato Energy Center Mankato Energy Center NG 2,052,663 925,045.94 930,056.43 920,035.45 Maple Lake Great River Energy - Maple Lake DFO 494 705.11 No Data 705.11 Marshall (MN) Marshall Municipal Utilities DFO 83 137.42 No Data 137.42

Supporting Calculation Data to Comments on Proposed Regulation: Clean Cars Minnesota, Minnesota Rules, Ch. 7023, Revisor’s ID Number 04626, OAH Docket Number 71-9003-36416 Power Plant Emission Factors Calculated Based on 2019 Actual Facility-Level Data Color Key: Typo Identified in Dataset Data Outlier Removed Value from EPA CAMD Report

Minnesota Power Generation Plants - NAICS Codes 221 EIA CO2e Part 98 2019 Annual Emissions Average e-GGRT Inventory for Minnesota

Reported Net CO2-equivalent CO2-equivalent CO2-equivalent Fuel Type Code Generation

Name as Listed in U.S. EPA Name as Listed in 2019 Annual Emissions Inventory Name as Listed on Form 923, EIA - MWh (tons) (tons) (tons) e-GGRT Reporting System for Minnesota Melrose Melrose Public Utilities DFO 62 59.09 No Data 59.09 Minnesota River Minnesota River Station MMPA - Minnesota River Station NG 201 150.76 150.76 Monticello Nuclear Facility Monticello Nuclear Generating Facility NUC 4,964,575 2,200.94 No Data 2,200.94 Moose Lake Moose Lake Water & Light Commission DFO 50 22.73 No Data 22.73 Mora Mora Municipal Utilities DFO 55 416.66 No Data 416.66 Mountain Lake Mountain Lake Municipal Utilities WND 2,779 85.44 No Data 85.44 New Ulm New Ulm Public Utilities - Municipal Power NG 4,517 29,824.02 No Data 29,824.02 North Branch (MN) North Branch Municipal Water & Light DFO 311 224.55 No Data 224.55 Hibbard Energy Center Minnesota Power - Hibbard Renewable Energy Ctr WDS 21,817 32,247.60 32,248.08 32,247.12 Pine Bend Energy LLC LFG No Data No Data No MWh Northshore Mining Co SUB 182,439 479,835.22 No Data 479,835.22 Silver Lake Rochester Public Utilities - Silver Lake Plant BIT No Data No MWh No MWh Owatonna Owatonna Public Utilities - West Owatonn NG 196 871.10 No Data 871.10 Owatonna Energy Station Owatonna Energy Station NG 28,370 14,915.92 No Data 14,915.92 Pleasant Valley (MN) Pleasant Valley Station Great River Energy - Pleasant Valley Station NG 36,868 29,647.32 29,658.75 29,635.89 Prairie Island Xcel Energy - Prairie Island Nuclear Plant NUC 9,139,972 574.66 No Data 574.66 Preston (MN) Preston Public Utilities NG 71 69.74 No Data 69.74 Princeton (MN) Princeton Public Utilities Commission DFO 529 614.53 No Data 614.53 Rapids Energy Center Rapids Energy Center NG 16,517 95,306.82 95,306.82 No Data Red Wing Red Wing Plant Xcel Energy - Red Wing Generating Plant MSN 74,806 184,677.63 109,742.68 259,612.58 Redwood Falls Redwood Falls Public Utilities - S Plant WAT 3,828 119.35 No Data 119.35 Riverside (MN) Riverside (1927) Xcel Energy - Riverside Generating Plant NG 3,085,556 1,296,491.07 1,296,538.12 1,296,444.01 Rock Lake CT Great River Energy - Rock Lake DFO 743 890.04 No Data 890.04 Shakopee Energy Park MMPA Shakopee Energy Park NG 21,066 9,452.13 No Data 9,452.13 Sherburne County Sherburne County Xcel Energy - Sherburne County Generating Plant SUB 10,734,409 12,370,764.62 12,357,886.08 12,383,643.15 Sleepy Eye Sleepy Eye Public Utility DFO 128 86.62 No Data 86.62 SMMPA Methane Energy Facility SMMPA Methane Energy Facility LFG 4,074 11.94 No Data 11.94 Solway CT Solway Plant Otter Tail Power Co - Solway Plant NG 52,970 32,309.52 32,308.71 32,310.32 Spring Valley Spring Valley Utilities DFO 336 416.70 No Data 416.70 Springfield (MN) Springfield Power Plant DFO No Data No Data No MWh St Bonifacius Great River Energy - Saint Bonifacius DFO 489 709.62 No Data 709.62 St James ST JAMES DIESEL GENERATING PLANT Saint James Diesel Generating Plant DFO 91 64.53 64.53 St Paul Cogeneration ST PAUL COGENERATION WDS 110,589 40,637.76 40,637.76 No Data St. Charles Power Plant St Charles Public Utilities DFO 49 43.04 No Data 43.04 Syl Laskin Laskin Energy Center Minnesota Power - Laskin Energy Center NG 19,455 16,254.53 16,405.68 16,103.39 Taconite Harbor Energy Center Taconite Harbor Energy Center Minnesota Power - Taconite Harbor Energy Center SUB No Data No MWh No MWh Thief River Falls Thief River Falls Power Plant WAT 1,830 18.52 No Data 18.52 Truman Truman Public Utilities DFO 53 128.78 No Data 128.78 Virginia VIRGINIA PUBLIC UTILITIES Virginia Department of Public Utilities WDS 13,705 89,191.09 89,209.95 89,172.24 Wells IC Wells Public Utilities DFO 199 102.58 No Data 102.58 Westbrook Westbrook Municipal Light & Power DFO 12 0.01 No Data 0.01 Westside Energy Station Rochester Public Utilities Westside Energy Station NG 43,647 21,753.41 No Data 21,753.41 Willmar WILLMAR MUNICIPAL UTILITIES Willmar Municipal Utilities WND 6,208 67.49 67.49 Willmar Municipal East Substation Willmar Municipal East Substation DFO 68 58.37 No Data 58.37 Wilmarth Key City/Wilmarth Plant Xcel Energy - Key City/Wilmarth MSN 57,830 142,214.26 86,956.83 197,471.69 Windom Windom city of DFO 30 29.31 No Data 29.31 Worthington Worthington Diesel Generating Plant WND 13,144 452.07 No Data 452.07

Minnesota Power Generation Plants - NAICS Codes 221 2019 Annual Emissions Inventory for Minnesota

Carbon Monoxide Nitrogen Oxides PM10 Primary PM2.5 Primary Sulfur Dioxide Volatile Organic (Filt + Cond) (Filt + Cond) Compounds

Name as Listed in U.S. EPA Name as Listed in 2019 Annual Emissions Inventory Name as Listed on Form 923, EIA (tons) (tons) (tons) (tons) (tons) (tons) e-GGRT Reporting System for Minnesota Adrian Adrian Public Utilities 0.39 1.82 0.13 0.13 0.12 0.15 Alexandria Alexandria Light & Power 0.34 1.56 0.11 0.11 0.10 0.13 Allen S King Allen S King Xcel Energy - Allen S King Generating Plant 52.25 916.46 139.15 102.82 1,031.03 56.27 Benson City of Benson Power Biomass Plant Benson Municipal Utilities 0.12 1.45 0.03 0.03 0.00 0.04 Black Dog Black Dog Xcel Energy - Black Dog Generating Plant 375.54 132.31 17.28 10.77 4.46 7.95 Blooming Prairie Blooming Prairie Public Utilities 0.10 1.32 0.02 0.02 0.00 0.03 Blue Earth Blue Earth Light & Water 0.12 1.19 0.03 0.03 0.01 0.04 Blue Lake Blue Lake Generating Plant Xcel Energy - Blue Lake 9.27 38.26 0.26 0.21 0.91 1.32 Cambridge CT Hybrid Cambridge Station Great River Energy - Cambridge 7.89 20.26 0.16 0.12 0.11 0.54 Cannon Falls Energy Center Cannon Falls Energy Center Invenergy Cannon Falls LLC 7.03 48.95 7.57 7.57 1.44 1.24 Cascade Creek Cascade Creek Rochester Public Utilities Cascade Creek 35.06 39.37 0.08 0.07 0.09 0.24 Clay Boswell Boswell Energy Center Minnesota Power - Boswell Energy Center 2,360.07 2,353.75 420.58 229.29 576.92 9.37 Covanta Hennepin Energy HENNEPIN COUNTY ENERGY CENTER Hennepin Energy Recovery Center 25.95 403.90 23.29 20.95 12.06 0.98 Detroit Lakes Detroit Lakes Gas Turbine 0.00 0.32 0.00 0.00 0.08 0.00 Elk River City of Elk River Elk River Municipal Utilities 0.43 2.01 0.14 0.14 0.13 0.16 Fairfax Fairfax city of Stand-by Power Plant 0.09 0.42 0.03 0.03 0.03 0.03 Fairmont (MN) Fairmont Energy Station 11.70 9.40 1.32 1.32 0.04 2.21 Faribault Energy Park Faribault Energy Park Faribault Energy Park 43.35 41.08 1.93 0.58 1.67 3.70 Fergus Control Ctr No Data No Data No Data No Data No Data No Data Glencoe Glencoe Light & Power Commission 1.55 4.65 0.95 0.93 0.00 0.22 Grand Marais Grand Marais Public Utilities Commission 0.99 4.58 0.11 0.11 0.30 0.37 Granite Falls Granite Falls Municipal Utilities 0.06 0.29 0.02 0.02 0.02 0.02 Halstad Halstad Municipal Utilities 0.08 0.39 0.03 0.03 0.03 0.03 Hibbing HIBBING PUBLIC UTILITIES COMMISSION Hibbing Public Utilities Commission 63.05 140.65 4.26 3.08 41.59 3.03 High Bridge High Bridge Xcel Energy - High Bridge Generating Plant 137.67 172.70 6.19 4.53 7.79 7.51 Hometown Bio Energy LLC Hometown BioEnergy 3.66 17.62 2.06 1.52 5.45 1.64 Hoot Lake Hoot Lake Otter Tail Power Co - General Office 53.57 486.97 150.37 98.93 1,137.87 5.98 Hutchinson Plant #1 Hutchinson Utilities Commission - Plant 1 1.92 11.29 0.07 0.06 1.39 1.43 Hutchinson Plant #2 Hutchinson - Plant 2 Hutchinson Utilities Commission -Plant 2 4.27 7.74 0.04 0.03 0.09 0.16 IBM West RPU - IBM Peaking Diesel Generators 0.03 0.94 0.02 0.02 0.01 0.02 Inver Hills Inver Hills Generating Plant Xcel Energy - Inver Hills Generating Plant 2.03 27.49 0.16 0.16 14.94 0.09 Janesville Janesville Municipal Utilities 0.22 0.84 0.05 0.05 0.05 0.06 Kenyon Municipal Kenyon Municipal Utilities 0.12 0.54 0.04 0.04 0.04 0.04 Koda Biomass Plant Koda Energy LLC 281.21 214.47 29.40 29.06 41.42 1.14 Lake Crystal Lake Crystal Utilities Commission 0.23 1.07 0.08 0.08 0.07 0.09 Lakefield Junction Lakefield Junction Generating Great River Energy - Lakefield Junction Station 13.43 14.87 0.23 0.18 0.23 0.08 Lakefield Utilities Lakefield Public Utilities 0.06 0.28 0.02 0.02 0.02 0.02 Lanesboro Lanesboro Public Utilities 0.02 0.10 0.01 0.01 0.01 0.01 Litchfield Litchfield city of 0.72 5.16 0.12 0.12 0.01 0.14 LSP-Cottage Grove LP Cottage Grove Cogeneration LSP Cottage Grove Cogeneration Facility 32.32 33.56 4.68 2.91 1.46 5.81 Luverne Luverne Municipal Power Plant 0.13 0.62 0.05 0.05 0.04 0.05 Mankato Energy Center Mankato Energy Center Mankato Energy Center 87.08 64.31 12.86 6.07 4.75 5.22 Maple Lake Great River Energy - Maple Lake 0.01 3.81 0.02 0.02 0.01 0.00 Marshall (MN) Marshall Municipal Utilities 0.20 1.31 0.03 0.02 0.20 0.03

Minnesota Power Generation Plants - NAICS Codes 221 2019 Annual Emissions Inventory for Minnesota

Carbon Monoxide Nitrogen Oxides PM10 Primary PM2.5 Primary Sulfur Dioxide Volatile Organic (Filt + Cond) (Filt + Cond) Compounds

Name as Listed in U.S. EPA Name as Listed in 2019 Annual Emissions Inventory Name as Listed on Form 923, EIA (tons) (tons) (tons) (tons) (tons) (tons) e-GGRT Reporting System for Minnesota Melrose Melrose Public Utilities 0.34 1.59 0.11 0.11 0.10 0.13 Minnesota River Minnesota River Station MMPA - Minnesota River Station 0.10 0.17 0.01 0.00 0.00 0.00 Monticello Nuclear Facility Monticello Nuclear Generating Facility 1.41 5.38 0.27 0.20 0.70 0.12 Moose Lake Moose Lake Water & Light Commission 0.13 0.61 0.04 0.04 0.04 0.05 Mora Mora Municipal Utilities 2.24 10.95 0.67 0.67 0.61 0.83 Mountain Lake Mountain Lake Municipal Utilities 0.38 1.74 0.13 0.12 0.12 0.14 New Ulm New Ulm Public Utilities - Municipal Power 14.25 40.21 0.08 0.07 0.11 0.93 North Branch (MN) North Branch Municipal Water & Light 1.03 6.05 0.15 0.15 0.40 0.49 Hibbard Energy Center Minnesota Power - Hibbard Renewable Energy Ctr 509.66 442.25 40.45 30.86 111.30 21.45 Pine Bend Energy LLC No MWh No MWh No MWh No MWh No MWh No MWh Northshore Mining Co 169.27 1,441.81 455.68 320.88 842.92 12.13 Silver Lake Rochester Public Utilities - Silver Lake Plant No MWh No MWh No MWh No MWh No MWh No MWh Owatonna Owatonna Public Utilities - West Owatonn 0.59 2.31 0.00 0.00 0.03 0.02 Owatonna Energy Station Owatonna Energy Station 78.47 45.74 4.33 4.33 6.25 18.86 Pleasant Valley (MN) Pleasant Valley Station Great River Energy - Pleasant Valley Station 21.90 27.11 0.19 0.16 0.15 0.62 Prairie Island Xcel Energy - Prairie Island Nuclear Plant 2.95 9.14 0.24 0.23 0.41 0.34 Preston (MN) Preston Public Utilities 0.31 1.74 0.07 0.07 0.06 0.11 Princeton (MN) Princeton Public Utilities Commission 0.95 12.01 0.22 0.21 0.01 0.32 Rapids Energy Center Rapids Energy Center No Data No Data No Data No Data No Data No Data Red Wing Red Wing Plant Xcel Energy - Red Wing Generating Plant 102.10 745.00 4.07 3.38 96.20 0.05 Redwood Falls Redwood Falls Public Utilities - S Plant 0.09 3.22 0.08 0.08 0.21 0.26 Riverside (MN) Riverside (1927) Xcel Energy - Riverside Generating Plant 86.61 186.26 5.21 3.80 6.54 11.36 Rock Lake CT Great River Energy - Rock Lake 0.02 4.96 0.02 0.02 0.01 0.00 Shakopee Energy Park MMPA Shakopee Energy Park 4.52 8.67 1.76 1.76 0.05 4.04 Sherburne County Sherburne County Xcel Energy - Sherburne County Generating Plant 1,627.90 7,628.00 664.00 399.38 5,483.31 195.08 Sleepy Eye Sleepy Eye Public Utility 0.50 2.30 0.17 0.17 0.15 0.19 SMMPA Methane Energy Facility SMMPA Methane Energy Facility 45.28 9.63 0.86 0.86 0.31 6.26 Solway CT Solway Plant Otter Tail Power Co - Solway Plant 8.06 34.35 0.14 0.10 0.20 0.56 Spring Valley Spring Valley Utilities 0.68 6.42 0.16 0.16 0.00 0.17 Springfield (MN) Springfield Power Plant No MWh No MWh No MWh No MWh No MWh No MWh St Bonifacius Great River Energy - Saint Bonifacius 0.01 3.81 0.02 0.02 0.04 0.00 St James ST JAMES DIESEL GENERATING PLANT Saint James Diesel Generating Plant 0.10 1.26 0.02 0.02 0.02 0.03 St Paul Cogeneration ST PAUL COGENERATION No Data No Data No Data No Data No Data No Data St. Charles Power Plant St Charles Public Utilities 0.25 1.16 0.08 0.08 0.08 0.09 Syl Laskin Laskin Energy Center Minnesota Power - Laskin Energy Center 2.90 14.50 0.98 0.36 0.23 0.70 Taconite Harbor Energy Center Taconite Harbor Energy Center Minnesota Power - Taconite Harbor Energy Center No MWh No MWh No MWh No MWh No MWh No MWh Thief River Falls Thief River Falls Power Plant 0.11 0.50 0.04 0.04 0.03 0.04 Truman Truman Public Utilities 0.36 1.49 0.10 0.10 0.09 0.12 Virginia VIRGINIA PUBLIC UTILITIES Virginia Department of Public Utilities 170.20 160.99 9.95 9.92 158.64 5.62 Wells IC Wells Public Utilities 0.39 2.10 0.08 0.08 0.07 0.13 Westbrook Westbrook Municipal Light & Power 0.00 0.00 0.00 0.00 0.00 0.00 Westside Energy Station Rochester Public Utilities Westside Energy Station 6.42 5.80 0.09 0.07 0.11 5.46 Willmar WILLMAR MUNICIPAL UTILITIES Willmar Municipal Utilities 0.05 0.06 0.00 0.00 0.00 0.00 Willmar Municipal East Substation Willmar Municipal East Substation 0.34 1.57 0.11 0.11 0.10 0.13 Wilmarth Key City/Wilmarth Plant Xcel Energy - Key City/Wilmarth 104.20 687.00 2.29 1.94 37.60 0.11 Windom Windom city of 0.17 0.79 0.06 0.06 0.05 0.06 Worthington Worthington Diesel Generating Plant 0.70 8.83 0.16 0.15 0.14 0.23

Supporting Calculation Data to Comments on Proposed Regulation: Clean Cars Minnesota, Minnesota Rules, Ch. 7023, Revisor’s ID Number 04626, OAH Docket Number 71-9003-36416 John Harkness Attachment

Please adopt the new Clean Cars Minnesota rules. We are dangerously behind in meeting global warming reduction goals. It is time to adopt much stronger greenhouse gas emission standards in Minnesota now. Each state must do its part because what we do here affects the whole world. It does not matter which state was the first to create the standards. The future of our children and grandchildren and the survival of the planet is at stake. Clean low cost energy souces that that will replace fossil fuels are available right now. For example I quite easily signed up for Xcel Energy's Renewable Connect Program. All my electricity now comes from 100% renewable sources like wind and solar at no extra cost to me. I then purchased 2 new electric vehicles and now all our family's driving is done with 100% clean renewable energy. Electric cars are wonderful, fun to drive, lower in total cost of ownership, and much more reliable than gasoline cars, but the process to obtain them is often more difficult that in other states. Most car shoppers would not go through the trouble I had to to obtain the cars I wanted. My eGolf I could not purchase in Minnesota because Volkswagen does not allow their dealers to sell them new here. I had to purchase and ship mine from a California dealership. Mini Cooper dealers are allowed to sell new electric cars in Minnesota, but they have none in stock and do not even bother to stock a demonstrator model to test drive. I had to order and pay for mine sight unseen, and then wait months for it to arrive. If electric cars were available in more dealerships, more Minnesotans would purchase and drive them. By the way, car dealers' argument that they would be stuck with excess inventory is false. This is dependent upon how many cars they choose to order and stock. Requiring them to keep at least one electric vehicle on hand for test drive or for sale would not be a significant burden. At the end of each year dealers have excess inventory for most gasoline engine car models so this is nothing new for them. Transportation is now the #1 source of greenhouse gas emissions. Minnesota should join the rest of the world and the other states that believe in science by taking the actions necessary to slow global warming and protect our children's future. Please adopt the Clean Cars Minnesota rules. Thank you for reading my comment. John Hausladen Attachment

John Larkin Attachment

Date: February L8,20Zl

Submitted by:John and Beverly Larkin, Falcon Heights, MN,55113

Comments on the Minnesota Pollution Control Agency proposed rule - Proposed Permanent Rules Relating to Clean Cars, parts 7023.0150 to 7023.0300.

t. We do not believe there need to be any changes to the Scope (7023.0150, Subpart 1) and lncorporation by Reference Subparts (7023.0150, Subpart 2). Transportation represents a significant portion of the Greenhouse Gas emissions (GHG) in the State of Minnesota. Minnesota is currently not meeting its goal of reduced GHG emissions (SONAR report, Dec2O2O, page 15), and we believe this proposed rule will help the State of Minnesota meet those goals and reduce the harmful effects of GHG emissions on Minnesota's residents and its climate. Considering Colorado, Connecticut, Delaware, Maine, Maryland, Massachusetts, New Jersey, New Mexico (2011 model year and later), New York, Oregon, Pennsylvania, Rhode lsland, Vermont, Washington, and the District of Columbia have also adopted the California Code of Regulations for vehicle emission standards, it is reasonable for us to believe that the California Code is equally appropriate for the State of Minnesota. Adopting the California Code by reference is the best option because it does not create additional accounting burden on the auto manufacturers besides what they are already practicing and will probably reduce the regulatory burden on the State of Minnesota regarding enforcement of this proposed rule. 2. We are in support of the adoption of section 7023.0300 (Zero-Emission Vehicle Standards). On two occasions we have had discussions with automotive dealers where they confided to us that the auto manufacturer they represented were not allowing them to order EV cars for sale within the state of Minnesota and were at the mercy of dealerships in CARB states to sell them EV cars to be sold at their dealerships here in the State of Minnesota. (At present, one of those manufacturers is now allowing their dealerships to order EV's. However, the other one is still prohibited). ln both cases we were in the market for a new EV or PHEV vehicle and we were not able to have the same selection of vehicles to choose from as someone in a CARB state. We believe it is unreasonable for us to have to travel outside of Minnesota to be given additional options for the purchase of an EV vehicle. We are convinced that the Zero-Emission Vehicle Standards will remove these barriers in addition to aiding in reducing GHG. We are not recommending any changes to 7023.0300.

UI4,"-- CL.^y-v A

Administrative Law Judge Jessica Palmer-Denig OAH Docket No. 71-9003-36416 Jon Grinnell Attachment 25 January 2021

Dear Judge Palmer-Denig,

Climate change is one of the greatest threats to humanity that exist today, and deserves our concerted efforts to minimize its impacts. Since transportation is one of the largest inputs to the greenhouse gases behind climate change, allowing Minnesota to adopt the LEV and ZEV standards is a good first step to reducing the impacts of the transportation sector. Providing Minnesotans with access to a broader range of electric and hybrid vehicles, and making those vehicles more affordable to purchase, is another good step. I completely support the rule-making proposed by the MPCA to update our clean car fleet and provide options for a climate-friendly transportation sector.

Sincerely,

Jon E. Grinnell 904 S. 4th Street St. Peter, MN 56082 The Honorable Jessica A. Palmer-Denig Office of Administrative Hearings 600 N Robert St. Jon Hunter Attachment P.O. Box 64620 St. Paul, MN 55164-0620

March 15, 2021

RE: Proposed Rules Adopting Vehicle Greenhouse Gas Emissions Standards – Clean Cars Minnesota, Minnesota Rules, chapter 7023; Revisor’s ID number 04626, OAH docket number 71-9003-36416

Dear Judge Palmer-Denig,

As Minnesota public health, environmental health, patient advocacy, and medical organizations, we support the Minnesota Pollution Control Agency’s rulemaking to adopt low emission vehicle (LEV) and zero emission vehicle (ZEV) standards to ensure Minnesota residents benefit from the strongest possible public health protections against harmful transportation pollution.

We support the adoption of the stronger vehicle emission and zero emission technology standards because transportation pollution is a direct threat to local air quality, public health, and a sustainable climate. Research shows that traffic pollution triggers asthma attacks in children and may cause a wide range of other effects including: the onset of childhood asthma, impaired lung function, premature death and death from cardiovascular diseases, and cardiovascular morbidity.

Tailpipe pollution can affect all Minnesotans, but it harms certain members of our communities most severely. Air pollution continues to impact our children, the elderly, and hundreds of thousands of Minnesota children and adults living with asthma, heart and lung disease, and other chronic health conditions that are harmed by transportation pollution. Those most affected are disproportionately Black, Indigenous, and other people of color, as air pollution compounds other health disparities, as well as people living and working near busy roadways, who receive higher exposure to air pollutants.

We believe the ZEV and LEV standards are not an option, but a necessity to protecting public health today and for future generations. We must take direct steps to ensure all communities are protected against the impacts of unhealthy air and the growing threats of climate change. Transportation sources like our cars and trucks are the leading source of greenhouse gas emissions that drive climate change. Climate change amplifies existing threats to public health and increases the difficulty of maintaining strong progress in protecting our clean air.

In adopting rules to reduce the impacts of vehicle emissions on our health, the Minnesota Pollution Control Agency is carrying out their mission to “protect and improve the environment and human health.” The people of Minnesota need every tool available to protect them from transportation pollution and to fight climate change. We support the Clean Cars Minnesota to protect the health of our residents and patients now and in the future.

Respectfully, the undersigned organizations:

American Lung Association in Minnesota Health Students for a Healthy Climate Health Professionals for a Healthy Climate Minnesota Public Health Association Jonathan Berry Attachment COMMENTS

submitted on behalf of

CLEAN FUELS DEVELOPMENT COALITION

Concerning the Minnesota Pollution Control Agency’s

Clean Cars Minnesota;

OAH Docket No. 71-9003-36416

Before Administrative Law Judge Jessica Palmer-Denig

By Jonathan Berry BOYDEN GRAY & ASSOCIATES PLLC 801 17th Street NW, Suite 350 Washington, DC 20006 202-955-0620 [email protected]

March 15, 2021 CONTENTS

INTRODUCTION & EXECUTIVE SUMMARY ...... 1

BACKGROUND ...... 5

A. The U.S. Constitution’s Supremacy Clause ...... 5

B. The Corporate Average Fuel Economy Program ...... 7

1. Federal law establishes maximum feasible average fuel economy standards for automobile manufacturers...... 7

2. The federal fuel economy program broadly prohibits any state policies related to automobile fuel economy standards...... 8

3. CAFE provides special treatment for automobiles that run on alternative fuel...... 9

C. The Clean Air Act’s Carbon Dioxide Standards ...... 10

D. California’s “Clean Cars” Program ...... 11

1. The Clean Air Act provides a limited waiver of federal Clean Air Act preemption for California and it allows some states to adopt identical standards...... 11

2. California’s greenhouse gas and zero-emission standards currently lack a valid Clean Air Act waiver...... 13

ARGUMENT ...... 16

I. THE CONSTITUTION’S SUPREMACY CLAUSE BINDS STATE ADMINISTRATIVE LAW JUDGES...... 16

II. THE PROPOSED AUTOMOBILE CARBON DIOXIDE EMISSION STANDARDS ARE PREEMPTED BY FEDERAL LAW...... 16

A. The Proposed Automobile Carbon Dioxide Standards Are “Related to” Fuel Economy Standards...... 16

1. There is a direct functional relationship between automobile fuel economy and carbon dioxide emission rates...... 17

2. The proposed carbon dioxide standards are de facto fuel economy standards...... 20

3. Because of their relation to fuel economy standards, state carbon dioxide standards have no environmental policy justification...... 21

B. Attempts to impliedly exempt California’s standards from CAFE preemption fail...... 22

III. ELECTRIC AUTOMOBILE QUOTAS ARE PREEMPTED BY FEDERAL LAW...... 27

A. The Proposed Electric Automobile Quotas Are Related to Average Fuel Economy Standards...... 27

1. State electric automobile quotas restrict manufacturer compliance choices and undermine CAFE’s flexible fleet-average standards...... 27

2. Because of their relation to fuel economy standards, state electric automobile quotas have no environmental policy justification...... 28

3. Attempts to carve out state electric automobile quotas from preemption fail...... 30

B. The Proposed Electric Automobile Quotas Impliedly Conflict with the Statute...... 35

IV. THE MINNESOTA POLLUTION CONTROL AGENCY’S TECHNICAL ANALYSIS IS DEEPLY FLAWED...... 35

A. The Technical Analysis Arbitrarily Ignores Leakage...... 36

B. The Technical Analysis Arbitrarily Ignores the Rebound Effect...... 38

C. The Technical Analysis Arbitrarily Ignores Delayed Turnover Effects...... 39

D. The Technical Analysis Arbitrarily Ignores Cold Weather Effects...... 40

E. The Technical Analysis Arbitrarily Assumes All Criteria Pollution Reductions Will Be in Minnesota...... 42

F. The Technical Analysis Arbitrarily Ignores Particulate Matter Emissions from Wear and Tear...... 43

iii

G. The Technical Analysis Arbitrarily Ignores Sulfur Dioxide Pollution from Power Plants...... 44

V. THE PROPOSED STANDARDS DO NOT BENEFIT CONSUMERS...... 45

VI. THE PROPOSED STANDARDS WILL HURT LOW-INCOME MINNESOTANS...... 48

VII. THE PROPOSED STANDARDS VIOLATE MINNESOTA LAW...... 50

A. Minnesota’s Pollution Control Agency does not have authority to adopt the proposed carbon dioxide standards...... 50

B. Minnesota’s Pollution Control Agency does not have authority to delegate power to Sacramento...... 50

CONCLUSION ...... 53

GLOSSARY Automobile ...... Any 4-wheeled vehicle that is propelled by fuel, or by alternative fuel, manufactured primarily for use on public streets, roads, and highways and rated at less than 10,000 pounds gross vehicle weight, with the exceptions noted in 49 C.F.R. 523.3(a)

CAFE ...... The automobile manufacturer corporate average fuel economy program required by Chapter 329 of Title 49 of the U.S. Code

NHTSA ...... The National Highway Traffic and Safety Administration

SONAR ...... Statement of Need and Reasonableness

INTRODUCTION & EXECUTIVE SUMMARY Established in 1988, the Clean Fuels Development Coalition is a non-profit organization supporting policies and programs to advance clean-fuel policies that improve air quality, create domestic jobs, and increase energy independence. The Coalition works with a wide range of fuel producers, automobile manufacturers, and agricultural organizations. Clean Fuels Development Coalition appreciates the opportunity to comment on this proposed rule.

The Clean Fuels Development Coalition opposes Minnesota’s proposed adoption of California’s “zero-emissions vehicle” quota. The zero-emissions vehicle quota is not needed or reasonable for Minnesota. While the objective of addressing climate change is laudable, the mandate is prohibited by federal fuel economy law. It does not advance clean air. It does not reduce carbon emissions. It is costly. It hurts the poor. And it unconstitutionally vests huge discretion in unaccountable and distant California bureaucrats.

The Minnesota Pollution Control Agency’s assertions to the contrary misread federal and state law and are based on a technical analysis that contains unrealistic assumptions. The technical flaws and unrealistic assumptions in the Agency’s analysis requiring correction include the following:

1. Failure to account for “carbon leakage.” The Agency’s assertion of climate benefits from the carbon dioxide standards fails to account for the behavior of automobile manufacturers in other states. Automobile manufacturers must meet the same national fleet-average carbon dioxide standard, regardless of what Minnesota does. Because reducing carbon emissions is expensive, when one state adopts more stringent standards, automobile manufacturers compensate by shipping less fuel-efficient car fleets to other states. In other words, for every fuel-efficient car sold in Minnesota to comply with the standards, there will be an equal and opposite gas guzzler sold in another state.

This phenomenon, known as “carbon leakage,” has been shown in modeling studies to wipe out all or most in-state carbon reductions from the adoption of California’s carbon dioxide standards. In short, due to leakage, the proposed state carbon dioxide standards have no quantifiable climate benefits at all. They impose net costs on society 1

for no gain.

The Agency’s failure to account for carbon leakage is odd, because the Agency accounts for carbon leakage from the zero-emissions vehicle standard, discounting any tailpipe carbon benefits down to zero. The Agency should do the same for the carbon dioxide standards, or it should explain why, contrary to economic logic and all modeling studies, the proposed carbon dioxide standard will not be offset by automobile manufacturers in other states.

2. Failure to account for the rebound effect. When driving costs less, drivers drive more. And by the same logic, studies show that when a state mandates more fuel-efficient cars, drivers drive more. This effect, known as the rebound effect, has been well- documented in the empirical literature. It is important to the analysis because it undermines the asserted goal of reducing pollution. The more drivers drive, the more carbon and air pollution they cause. The rebound effect also decreases safety, as increases in vehicle-miles traveled lead to more traffic fatalities.

The Agency’s analysis unreasonably assumes no rebound effect. Instead, it assumes the same number of vehicle-miles traveled in both the reference and the proposed rule scenarios. In other words, contrary to economic logic and empirical studies, the Agency’s analysis assumes drivers will not drive more if it is cheaper. This unrealistic assumption should be corrected. Once appropriately considered, the rebound effect undermines the Agency’s case for the need and reasonableness of the proposed rule.

3. Failure to account for delayed fleet turnover. As with the rebound effect, it does not take an expert to know that if new cars cost more, drivers will buy them less often. This fleet-turnover effect has also been empirically demonstrated, but the Agency inexplicably assumes that buyers do not react to prices. By slowing down the pace at which older cars are replaced with newer cleaner cars, the proposed rule will cause drivers to drive more miles on older cars, increasing pollution. This effect undermines the need and reasonableness of the proposed rule.

3. Failure to account for cold weather. The Agency’s technical analysis assumes no cold winter weather—in Minnesota of all places. Instead, the analysis assumes that electric cars will be driven year-round in California-style 70-degree weather conditions. That unrealistic assumption biases the analysis. Electric car efficiency is significantly impaired

during cold weather. In Minnesota’s winter, electric car efficiency will drop by nearly half. This means electric cars will need much more energy to travel the same number of miles, increasing pollution and consumer costs.

4. Failure to account for non-exhaust particle emissions. The proposed rule’s technical analysis assumes that electric cars reduce direct particle emissions. But the rule considers only tailpipe particle emissions, ignoring non-exhaust emissions from wear and tear, which are greater for electric cars. Once these non-exhaust emissions are accounted for, electric cars do not provide any significant tailpipe particulate emission reductions.

5. Failure to account for sulfur dioxide emissions. The proposed rule’s technical analysis ignores upstream sulfur dioxide pollution. Because sulfur dioxide pollution is emitted by the power sector and not by cars, replacing gasoline cars with electric cars increases sulfur dioxide emissions, leading to harmful particulate air pollution that undermines the claimed health and equity benefits.

6. Failure to account for lower gasoline costs. The proposed rule relies on outdated and now demonstrably incorrect gasoline price projections. Updated gasoline price projections are much lower, undermining the claimed fuel saving gains to consumers.

7. Failure to account for battery replacement costs. The Agency’s analysis unreasonably assumes that electric cars sold will uniformly drive for 150,000 miles without ever needing a battery replacement. Most car batteries are warranted for much fewer miles. The need to replace batteries prematurely in some electric cars undermines the claimed consumer and environmental benefits of the rule.

8. Failure to account for foregone performance improvements. The Agency’s analysis assumes that fuel-efficiency gains have no trade-offs for consumers, but that assumption is simply false. When manufacturers are forced to increase fuel economy, they trade off gains in fuel efficiency for gains in other performance attributes that consumers value, like increased horsepower or towing capacity. Once these trade-offs are considered, consumers overall see little or no gain from mandated fuel-efficiency increases.

9. Failure to account for distributional effects of increased car prices. The Agency’s analysis focuses like a laser on the asserted “environmental justice” benefits of the proposed rule. But it entirely ignores economic justice. As a matter of economic justice, the zero-

emissions vehicle standard is a regressive failure, effectively taxing low- and middle- income Minnesotans to benefit the rich. The standard will force all gasoline car buyers to pay more for their cars so that the wealthiest Minnesotans can get greater choice and discounts when shopping for their luxury electric cars. It is Robin Hood in reverse.

* * *

The proposed standards are not needed or reasonable. National energy and pollution laws already encourage the development of clean and efficient cars through technology-neutral standards, supplemented by incentive programs to encourage—not mandate—the development of all alternative fuels. This longstanding approach is working effectively to promote efficiency, reduce pollution, and encourage a variety of alternative fuels at an affordable cost to consumers. Adopting Sacramento’s regressive and expensive experiment with electric car quotas will harm Minnesota.

BACKGROUND A. The U.S. Constitution’s Supremacy Clause As the Supreme Court has recognized, “an immediate reason for calling the Constitutional Convention [was] the . . . the tendencies toward economic Balkanization that had plagued relations among the Colonies and later among the States under the Articles of Confederation.”1 Under the Articles, a feeble Confederation Congress was powerless to prevent states from advancing their political agendas at national expense. These centrifugal forces threatened to split the United States “into an infinity of little jealous, clashing, tumultuous commonwealths, the wretched nurseries of unceasing discord and the miserable objects of universal pity or contempt.”2

To defuse these centrifugal forces, the Framers decisively strengthened the national government. The U.S. Constitution grants Congress a sweeping power to enact laws that “regulate Commerce.”3 It also includes a practical means of enforcing the supremacy of federal law—the Supremacy Clause.4

The Supremacy Clause provides:

This Constitution, and the laws of the United States which shall be made in pursuance thereof; and all treaties made, or which shall be made, under the authority of the United States, shall be the supreme law of the land; and the judges in every state shall be bound thereby, anything in the Constitution or laws of any State to the contrary notwithstanding. The Supremacy Clause “creates a rule of decision”: judges “must not give effect to state laws that conflict with federal laws.”5 This rule of decision ensures that under our federal system, “States have no power . . . to retard, impede, burden, or in any manner control the operations of the constitutional laws enacted by Congress.”6 Without the

1 Hughes v. Oklahoma, 441 U.S. 322, 325–26 (1979). 2 Federalist No. 9. 3 Art. I, § 8, cl. 3. 4 Art. VI, cl. 2. 5 Armstrong v. Exceptional Child Ctr., Inc., 575 U.S. 320, 324 (2015). 6 McCulloch v. Maryland, 4 Wheat. 316, 436 (1819).

Supremacy Clause, Madison warned, the world “would have seen the authority of the whole society everywhere subordinate to the authority of the parts; it would have seen a monster, in which the head was under the direction of the members.”7

The Supreme Court has recognized three kinds of conflicts under the Supremacy Clause, and these conflicts are commonly referred to as federal “preemption” doctrine. The three kinds of preemption are express preemption, field preemption, and implied preemption.

• Express preemption happens when Congress enacts statutory text that prohibits certain kinds of state laws or regulations. Express preemption calls for the use of ordinary tools of statutory interpretation. As the Supreme Court has recognized, where a federal “statute ‘contains an express pre-emption clause,’ we do not invoke any presumption against pre-emption but instead ‘focus on the plain wording of the clause, which necessarily contains the best evidence of Congress’ pre-emptive intent.’ ”8

• Field preemption is a rare form of preemption that prevents states from regulating in entire areas of policy. “[F]ield” preemption “may be inferred where the scheme of federal regulation is sufficiently comprehensive to make reasonable the inference that Congress ‘left no room’ for supplementary state regulation. Pre-emption of a whole field will also be inferred where the field is one in which ‘the federal interest is so dominant that the federal system will be assumed to preclude enforcement of state laws on the same subject.’ ”9

• Implied preemption is of two kinds. First, impossibility preemption, which applies only “where it is ‘impossible for a private party to comply with both state and federal requirements.’ ”10 Second, obstacle preemption, which applies when

7 Federalist No. 44. 8 Puerto Rico v. Franklin California Tax-Free Trust, 136 S. Ct. 1938, 1946 (2016) (quoting Chamber of Commerce v. Whiting, 563 U.S. 582, 594 (2011)). 9 Hillsborough Cty., Fla. v. Automated Med. Labs., Inc., 471 U.S. 707, 713 (1985) (citation omitted) (quoting Rice v. Santa Fe Elevator Corp., 331 U.S. 218, 230 (1947)). 10 Mut. Pharm. Co. v. Bartlett, 570 U.S. 472, 480 (2013) (quoting English v. General Elec. Co., 496 U.S. 72, 79 (1990)).

state law “creates an obstacle to the full purposes and objectives of Congress.”11 For example, a state common law duty that would require the use of an airbag posed an obstacle to NHTSA safety standard allowing automobile manufacturers flexibility to meet a safety standard with a “variety and mix of devices.”12

B. The Corporate Average Fuel Economy Program 1. Federal law establishes maximum feasible average fuel economy standards for automobile manufacturers. In 1975, Congress required the Secretary of Transportation to establish ambitious corporate average fuel economy (CAFE) standards applicable to manufacturers of new automobiles.13 Congress increased the stringency of CAFE standards in 2007, requiring a fuel economy standard of “at least 35 miles per gallon” by 2020 for the combined fleet of automobiles and the “maximum feasible average fuel economy standard” by 2030 or earlier.14

When setting “maximum feasible” CAFE standards for new automobiles, the Secretary of Transportation must consider several factors, including “technological feasibility, economic practicability, the effect of other motor vehicle standards of the Government on fuel economy, and the need of the United States to conserve energy.”15 CAFE standards thus involve a complicated balancing. Under the “economic practicability” factor, for example, the Secretary considers any “adverse economic consequences, such as a significant loss of jobs or the unreasonable elimination of

11 Arizona v. United States, 567 U.S. 387, 410 (2012). 12 Geier v. Am. Honda Motor Co., 529 U.S. 861, 881 (2000). 13 Energy Policy and Conservation Act of 1975, Pub. L. 94-163 § 502(a)(1), 89 Stat. 871, 902 (1975); Ctr. for Auto Safety v. NHTSA, 793 F.2d 1322, 1324 (D.C. Cir. 1986). The term “automobile” in CAFE overlaps almost entirely with the light- and medium-duty vehicles regulated under Minnesota’s proposed regulations. See 49 U.S.C. § 32901(a)(3); 40 C.F.R. §§ 523.3(a), 523.4, 523.5 (defining the terms automobile, passenger automobile, and light-truck); 13 Cal. Code Reg. § 1900(b)(11), (12), (13), (17) (defining the terms light-duty truck, medium-duty passenger vehicle, medium-duty vehicle, and passenger car). For simplicity, these comments will generally use the broader term automobile. 14 49 U.S.C. § 32902(b)(2), Energy Independence and Security Act of 2007, Pub. L. 110-140 § 102(b)(2) (2007). 15 49 U.S.C. § 32902(f).

consumer choice.”16 While the Secretary’s discretion to set fuel economy standards is broad, it has some specific limits. As relevant here, when setting fuel economy standards, the Secretary may not consider the fuel economy of automobiles operating on alternative fuels—including electricity.17

The Secretary of Transportation has delegated the promulgation and enforcement of CAFE standards to an expert agency, the National Highway Traffic Safety Administration (NHTSA).18 NHTSA has set automobile fuel economy standards up to model year 2026.19

2. The federal fuel economy program broadly prohibits any state policies related to automobile fuel economy standards. Congress sought to establish a “single standard” for fuel economy.20 It recognized that CAFE’s effectiveness would be frustrated if states adopted needlessly duplicative or overlapping automobile policies. To prevent states from second-guessing federal “maximum feasible” fuel economy standards, or NHTSA’s enforcement of those standards, CAFE provides:

When an average fuel economy standard prescribed under this chapter is in effect, a State or a political subdivision of a State may not adopt or enforce a law or regulation related to fuel economy standards or average fuel economy standards for automobiles covered by an average fuel economy standard under [chapter 329 of title 49 of the U.S. Code].21 The statute provides one limited exception—automobiles purchased for the sole use of state or local governments are not subject to preemption.22

16 67 Fed Reg. 77,015, 77,021 (Dec. 16, 2002). 17 49 U.S.C. § 32902(h). 18 40 C.F.R. § 501(e). 19 49 C.F.R. §§ 531.5(c) (passenger automobiles), 533.5 (light-trucks). NHTSA cannot set CAFE standards for more than five model years in a row. 49 U.S.C. § 32902(b)(3)(B). 20 S. Rep. No. 93-526, at 59 (1973). 21 49 U.S.C. § 32919(a). 22 49 U.S.C. § 32919(c).

Congress used the broad term “related to” to prevent artful evasions of the prohibition and to preserve the integrity of the national program. As Congress recognized, “State or local fuel economy standards would be preempted, regardless of whether they were in terms of miles per gallon or some other parameter such as horsepower or weight.”23 Consistent with that anti-circumvention principle, CAFE’s express preemption provision is extraordinarily broad. As the Supreme Court has explained in an analogous preemption context, the “ordinary meaning” of “related to” “is a broad one—‘to stand in some relation; to have bearing or concern; to pertain; refer; to bring into association with or connection with,’ . . .—and the words thus express a broad pre-emptive purpose.”24 The Court of Appeals for the Second Circuit, for example, has held that “related to fuel economy standards or average fuel economy standards” must be construed broadly, applying the statute to prohibit local taxi-fleet rules encouraging the adoption of hybrid taxis.25

3. CAFE provides special treatment for automobiles that run on alternative fuel. CAFE, as amended by the Alternative Motor Fuels Act of 1988 and later statutes, provides fuel economy incentives for automobiles that use liquid or gaseous alternative fuels like ethanol, methanol, biodiesel, and compressed natural gas. It does so by dividing their fuel economy by 0.15, equivalent to multiplying their fuel economy almost sevenfold.26

Electric automobiles are treated equally by regulation. In 1980, Congress enacted a program to explore “the value and implications” of allowing the use of electric vehicles in CAFE as a way to encourage the commercialization of these vehicles.27 “In the event that a manufacturer manufacture[d] electric vehicles,” its fuel economy would be based

23 S. Rep. No. 93-526 at 66. 24 Morales v. Trans World Airlines, Inc., 504 U.S. 374, 383 (1992) (quoting Black’s Law Dictionary 1158 (5th ed. 1979)). 25 See Metro. Taxicab Bd. of Trade v. City of New York, 615 F.3d 152, 157–58 (2nd Cir. 2010); see also Ophir v. City of Bos., 647 F. Supp. 2d 86, 94 (D. Mass. 2009) (same). 26 49 U.S.C. § 32919(a) (emphasis added). 27 Chrysler Corporation Loan Guarantee Act of 1979, Pub. L. 96-185, § 18(1).

on “equivalent based fuel economy values” determined by the Secretary of Energy.28 “The intent of this legislation [was] to provide an incentive for vehicle manufacturers to produce electric vehicles by including the expected high equivalent fuel economy of these vehicles in the CAFE calculation.”29 Under this statute, the Secretary of Energy multiplies the gasoline-equivalent fuel economy of electric automobiles by 1/0.15 to provide “similar treatment to manufacturers of all types of alternative fuels, including electric vehicles.”30

C. The Clean Air Act’s Carbon Dioxide Standards Under § 202(a)(1) of the Clean Air Act, EPA must regulate “any air pollutant from” new motor vehicles which in its judgment “cause[s], or contribute[s] to, air pollution which may reasonably be anticipated to endanger public health or welfare.”31 EPA traditionally exercised this authority to regulate automobile emissions that are detrimental to air quality.

In 1999, a group of environmental non-profits petitioned EPA to find that carbon dioxide and other greenhouse gas emissions from motor vehicles were endangering public health and welfare because they contribute to global climate change.32 EPA rebuffed this petition,33 but in Massachusetts v. EPA, the Supreme Court held that EPA had to decide whether motor vehicle greenhouse gas emissions were endangering public health or welfare by contributing to climate change.34

Because carbon dioxide emissions are inextricably related to fuel consumption, EPA warned the Court that regulation under the Clean Air Act “would either conflict with [fuel economy] standards or be superfluous.”35 The Court recognized the relationship

28 Id. § 18(3), codified at 49 U.S.C. § 32904(a)(2)(B). 29 46 Fed. Reg. at 22,747. 30 65 Fed. Reg. 36,986 (June 12, 2000). 31 42 U.S.C. § 7521(a)(1). 32 See EPA-HQ-OAR-20001-0002-0001; Massachusetts v. EPA, 549 U.S. 497, 505 (2007). 33 Control of Emissions From New Highway Vehicles and Engines, 65 Fed. Reg. 52,922, 52,933 (Sept. 8, 2003). 34 Id. at 532. 35 Massachusetts v. EPA, 549 U.S. 497, 513 (2007).

between carbon dioxide and mileage standards, but it rejected this justification against action in a brief passage:

“But that [NHTSA] sets mileage standards in no way licenses EPA to shirk its environmental responsibilities. EPA has been charged with protecting the public’s ‘health’ and ‘welfare,’ a statutory obligation wholly independent of [NHTSA’s] mandate to promote energy efficiency. The two obligations may overlap, but there is no reason to think the two agencies cannot both administer their obligations and yet avoid inconsistency.”36 On remand, EPA concluded that motor vehicle greenhouse gas emissions were endangering public health and welfare.37 EPA and NHTSA jointly promulgated standards to implement their (now) overlapping obligation to regulate corporate average fuel economy and carbon dioxide emissions for model year 2012 to 2025 automobiles.38 In April of 2020, NHTSA and EPA revised the standards up to 2026 as part of the Safer Affordable Fuel-Efficient (SAFE) Vehicles final rule.39 The rules are projected to require an average standard of 202 grams of carbon dioxide per mile by 2026, mathematically equivalent to a fuel economy standard of 40.4 miles per gallon.40

D. California’s “Clean Cars” Program 1. The Clean Air Act provides a limited waiver of federal Clean Air Act preemption for California and it allows some states to adopt identical standards. In general, § 209(a) of the Clean Air Act prohibits states from regulating new motor vehicle emissions.41 This federal preemption avoids “an anarchic patchwork of federal

36 Id. at 532. 37 Endangerment and Cause or Contribute Finding for Greenhouse Gases Under Section 202(a) of the Clean Air Act, 74 Fed. Reg. 66,496 (Dec. 15, 2009). 38 40 C.F.R. § 86.1818-12. Because NHTSA lacks authority to promulgate standards for more than five years in a row, the fuel economy standards for model years 2022 to 2025 were non-binding “augural” standards. 49 U.S.C. § 32902(b)(3)(B). 39 The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks, 85 Fed. Reg. 24,174 (Apr. 30, 2020) (SAFE Rule). 40 Id. at 24,199. 41 42 U.S.C. § 7543(a).

and state regulatory programs, a prospect which threatened to create nightmares for [vehicle] manufacturers.”42

Since 1967, § 209(b) has allowed California to apply for a limited waiver of this prohibition.43 Under the statute (as further amended in 1977), California may apply for a waiver of preemption of the Section 209(a) prohibition if California “determines that the State standards will be, in the aggregate, at least as protective of public health and welfare as applicable Federal standards.”44 EPA “shall” then grant a waiver—but “[n]o such waiver shall be granted” if EPA “finds that”

(A) California’s “determination . . . is arbitrary and capricious”; (B) California “does not need such . . . standards to meet compelling and extraordinary conditions”; or (C) California’s “standards and accompanying enforcement procedures are not consistent with section 7521(a) [202(a)] of this title, which requires sufficient lead time “to permit the development and application of the requisite technology, giving appropriate consideration to the cost of compliance within such period.”45 Congress justified this waiver exception based on California’s “unique” smog (ground-level ozone) problems, caused by California-specific conditions such as the “numerous thermal inversions that occur within that state because of its geography and prevailing wind patterns.”46 Indeed, in 1967, “the air in Los Angeles basin was so thick

42 Motor Equip. Mfrs. Assn., Inc. v. EPA, 627 F.2d 1095, 1109 (D.C. Cir. 1979); see also Motor Vehicle Mfrs. Ass’n v. N.Y. Dep’t Envtl. Conservation, 17 F.3d 521, 526 (2nd Cir. 1994) (“The cornerstone of Title II is Congress’ continued express preemption of state regulation of automobile emissions.”). 43 42 U.S.C. § 7543(b)(1); see also Air Quality Act of 1967, Pub. L. No. 90-148, § 208(b), 81 Stat. 485, 501 (1967). “California is the only state . . . eligible for a waiver under this provision.” Chamber of Commerce v. EPA, 642 F.3d 192 (D.C. Cir. 2011); see also 42 U.S.C. § 7507 (allowing other states to adopt “California standards” in certain circumstances). 44 42 U.S.C. § 7543(b)(1). 45 Id. § 7521(a)(2). 46 California State Motor Vehicle Pollution Control Standards: Waiver of Federal Preemption Notice of Decision, 49 Fed. Reg. 18887, 18890 (May 3, 1984) (citing 113 Cong. Reg. 30,948, (Nov. 2, 1967)) (hereinafter 1984 Waiver).

with smog that a mountain, or even a nearby mountain range, could simply disappear.”47 While smog in Los Angeles has fallen significantly, California still struggles to meet federal air quality standards for smog.48

But while only California has a special federal preemption exemption, other states can copy California. As a result of a compromise adopted in the Clean Air Amendments of 1977, any state which has an EPA-approved non-attainment or maintenance plan with one or more federal air quality standards may adopt standards identical to the exempted standards for California.49

2. California’s greenhouse gas and zero-emission standards currently lack a valid Clean Air Act waiver. California traditionally used its exemption authority to promulgate automobile standards for smog-forming and particle emissions. But in recent times, California has also pursued a regulatory paradigm of forced electrification and climate change regulation.

California’s attempt to force automobile electrification began in 1990, when California adopted the first “zero-emissions vehicle” standards, effectively a percentage-of-production quota for electric (and now also hydrogen) automobiles.50 But automobile manufacturers failed to produce the mandated electric automobiles. In 2002, automobile manufacturers sued California and obtained a preliminary injunction enjoining the quota as preempted by CAFE.51

In 2005, California requested, for the first time, a waiver to regulate greenhouse gas

47 Coal. for Responsible Regulation, Inc. v. EPA, 2012 WL 6621785, at *3 (D.C. Cir. 2012) (Brown, J., dissenting from denial of rehearing en banc). 48 See 40 C.F.R. § 81.305 (collecting non-attainment designations). 49 42 U.S.C. § 7507; see also Am. Auto. Mfrs. Ass’n v. Cahill, 152 F.3d 196, 201 (2d Cir. 1998) (“[T]he Section 177 exception is available to the 49 other states only when a standard identical to an existing California standard is adopted.”). 50 58 Fed. Reg. 4166 (Jan. 7, 1993) (waiving preemption under Clean Air Act § 209(a)). 51 Cent. Valley Chrysler-Plymouth v. California Air Res. Bd., No. CV-F-02-5017 REC/SMS, 2002 WL 34499459, at *7 (E.D. Cal. June 11, 2002). California settled the lawsuit before the appeal was decided. Agreement of Counsel Concerning the 2001 California ZEV Litigation, https://www.arb.ca.gov/msprog/zevprog/zevlitigation/zevlitigation.pdf.

emissions, including carbon dioxide.52 EPA first denied California’s waiver.53 But after President Obama’s inauguration, EPA reversed course and granted the waiver.54 Auto manufacturers did not challenge the 2009 waiver decision; they had agreed to forgo any such challenge as part of a negotiated settlement agreement that would “create a uniform federal system” for regulation starting in 2012.55 As a critical part of that agreement, California adopted an amendment to its state standards that would deem compliance with federal greenhouse gas standards compliance with the state’s standards.56

In 2013, EPA granted California a consolidated waiver for a suite of standards, known broadly as California’s clean cars program.57 This program includes three sets of standards:

First, the California low-emissions vehicle air pollution standards, which address California’s ozone and particulate pollution problems by requiring reductions in automobile organic gases, nitrogen oxides, and particulate matter.58

Second, the greenhouse gas standards for model year 2017 and later automobiles, which seek to address climate change primarily by controlling the rate of carbon dioxide emissions.59

Third, California’s zero-emissions vehicle standards for model year 2018 and later vehicles, which require manufacturers to generate or acquire an increasing percentage of regulatory “credits” representing new electric or fuel-cell automobiles produced and delivered for sale as a fraction of a manufacturer’s total automobiles produced and

52 Letter from Catherine Witherspoon, Executive Officer, CARB, to Stephen Johnson, Administrator, EPA (Dec. 21, 2005). 53 73 Fed. Reg. 12156, 12168 (Mar. 6, 2008). 54 74 Fed. Reg. 32744, 32745 (July 8, 2009). 55 See Jody Freeman, The Obama Administration’s National Auto Policy: Lessons from the “Car Deal,” 35 Harv. L. Rev. 342, 345–46 (2011). 56 Id. 57 78 Fed. Reg. 2112, 2114 (Jan. 9, 2013) (hereinafter 2013 Waiver). 58 Id. 59 Id. (codified at 13 Cal. Code Reg. § 1961.3).

delivered for sale in California or like-minded states.60 By 2025, the zero-emissions vehicle credit percentage requirement will rise to 22% of all automobiles produced and delivered for sale.61 This electric-vehicle quota is not primarily to reduce automobile emissions—it is rather an ambitious regulatory cross-subsidy program to promote the commercialization of electric automobiles and discourage the sale of internal combustion engines.62

In 2018, as NHTSA and EPA reconsidered the stringency of federal fuel economy and greenhouse gas standards, California amended its rules (without requesting another waiver) to eliminate its “deemed to comply” provision, threatening the automobile industry with balkanization unless federal agencies adopted California’s preferred policy determinations.63 In 2019, EPA revoked the preemption waiver for California’s greenhouse gas standards and zero-emission vehicle standards. NHTSA also concluded that California’s standards were expressly and impliedly preempted by CAFE.64

Minnesota’s Pollution Control Agency now proposes to adopt the California standards EPA waived in 2013, as amended by California.

60 13 Cal. Code Reg. § 1962.2(b). 61 Id. CARB estimates that from 2018 to 2025, the mandate will require the sale of 867,000 to 967,000 new electric vehicles in California, and 720,000 to 1.1 million new electric vehicles in section 177 states. See CARB, California’s Advanced Clean Cars Midterm Review A-24 (Jan. 2017). 62 2013 Waiver, 78 Fed. Reg. at 2130 (“As CARB notes . . . the goal of . . . the ZEV regulation was to . . . move advanced low GHG vehicles from demonstration phase to commercialization.”). 63 California’s “deemed to comply” provision was amended in September 2018 to provide that it “shall not be available” for model years 2021 and later if the final rules promulgated by the Obama Administration were “altered.” 13 Cal. Code Reg. § 1961.3(c); see also Statement by CARB Chair on Action to Preserve California Vehicle Standards (Sept. 28, 2018), https://ww2.arb.ca.gov/news/statement-carb-chair-action-preserve-california-vehicle-standards. With the promulgation of the final SAFE Rule in April of 2020, compliance with federal standards is no longer deemed compliance with California’s greenhouse standards, and under California law manufacturers are required to comply with the more stringent California standards for current 2021 model year vehicles. 64 84 Fed. Reg. 51,310 (Sept. 27, 2019).

ARGUMENT

I. THE CONSTITUTION’S SUPREMACY CLAUSE BINDS STATE ADMINISTRATIVE LAW JUDGES. State Administrative Law Judges must follow federal statutes that forbid Minnesota’s proposal. The Supremacy Clause provides that “the judges in every state shall be bound” by federal law, “anything in the Constitution or laws of any State to the contrary notwithstanding.”65 “There can be little doubt that the role of the modern federal hearing examiner or administrative law judge . . . is ‘functionally comparable’ to that of a judge.”66 And in any event, all state officers—legislative, executive, or judicial—are “bound by oath or affirmation” to support the U.S. Constitution, including the Supremacy Clause.67 The Constitution therefore requires State Administrative Law Judges to obey the constitutional laws enacted by Congress over any conflicting state laws.

II. THE PROPOSED AUTOMOBILE CARBON DIOXIDE EMISSION STANDARDS ARE PREEMPTED BY FEDERAL LAW. A. The Proposed Automobile Carbon Dioxide Standards Are “Related to” Fuel Economy Standards. The Minnesota Pollution Control Agency is proposing to adopt California’s fleet- average carbon dioxide standards for automobiles. That proposal conflicts with federal law. Under CAFE, no state may adopt or enforce any law or regulation related to fuel economy standards or average fuel economy standards for automobiles.68 California’s average carbon dioxide standards for light-duty vehicles are de facto automobile fuel economy standards, so they are preempted under any sensible reading of CAFE. The Agency’s preempted proposal is hence not needed or reasonable.

65 Art. VI, cl. 2. 66 Butz v. Economou, 438 U.S. 478, 513 (1978). 67 Art. VI, cl. 3. 68 49 U.S.C. § 32919(a).

1. There is a direct functional relationship between automobile fuel economy and carbon dioxide emission rates. There is an undeniable direct functional relationship between regulating carbon dioxide and fuel economy standards. Carbon dioxide is the natural byproduct of combusting the carbon-based liquid or gaseous fuels that power internal combustion engines.69 Automobile manufacturers improve automobile carbon dioxide emissions per mile by improving new automobile fuel consumption rates, i.e., fuel economy.70 California’s automobile carbon dioxide standards are thus not just “related to” automobile fuel economy; they are functionally identical to adopting automobile fuel economy standards, as NHTSA has concluded in a final rule.71

Automobile carbon dioxide emissions and fuel economy are so closely related that automobile manufacturers measure fuel economy by measuring carbon emissions as a proxy. Under the CAFE test procedures, automobile manufacturers measure automobile fuel economy using a “carbon-balance” method: by measuring carbon per gallon in the test fuel and dividing it by the rate at which carbon is emitted from the tailpipe, manufacturers reliably estimate how fast an automobile is consuming fuel based on how rapidly it is consuming the fuel’s carbon.72 This relationship works because combusting hydrocarbon or alcohol fuels (gasoline, diesel, methanol, natural

69 See 49 C.F.R. Part 531, App’x B(a)(1)(B) (“Carbon dioxide is the natural by-product of automobile fuel consumption”). 70 See id. Part 531, App’x B(a)(1)(D) (“Almost all technologically feasible reduction of tailpipe emissions of carbon dioxide is achievable through improving fuel economy, thereby reducing both the consumption of fuel and the creation and emission of carbon dioxide.”). 71 See id. Part 531, App’x B. 72 See 40 C.F.R. § 600.113-12(h) (gasoline), (i) (diesel), (j) (methanol), (k) (natural gas), (l) (ethanol), (m) (liquified petroleum gas); see also 40 C.F.R. Part 600, App’x II (sample calculations from prior gasoline formula). While other carbon-related emissions (like hydrocarbons or carbon monoxide) are included in the carbon-balance equations, these emissions are trivial and dependent on factors other than efficiency. Carbon dioxide emissions account for 99% of all measured mass-based emissions per mile and depend on efficiency. See EPA, Greenhouse Gas Emissions from a Typical Passenger Vehicle 1 (May 2014) (“The amount of CO2 created from burning one gallon of fuel depends on the amount of carbon in the fuel. Typically, more than 99% of the carbon in a fuel is emitted as CO2 when the fuel is burned. Very small amounts are emitted as hydrocarbons and carbon monoxide, which are converted to CO2 relatively quickly in the atmosphere.”); see 71 Fed. Reg. at 17,661 (“[C]ompliance with federal fuel economy standards is based primarily on CO2 emission rates of covered vehicles.”).

gas, ethanol, or liquified petroleum gas) in the presence of oxygen naturally yields carbon dioxide emissions (and water vapor).73

For less exacting purposes, automobile carbon dioxide emissions and fuel economy rates can be mathematically converted if the carbon content of the fuel is known, assuming constant fuel energy density. EPA, for example, estimates a typical gallon of gasoline contains 2,421 grams of carbon, which would equal 8,887 grams of carbon dioxide.74 Plugging this value into a simple equation: a gasoline-powered automobile that emits 404 grams of carbon dioxide per mile has a fuel economy of 22 miles per gallon, and vice versa.75 The same formula can be used for other hydrocarbon or alcohol fuels.76

The close functional relationship between carbon dioxide and fuel economy is no secret. It has been recognized by federal courts, federal agencies, and experts. Here are just a few examples:

• The Court of Appeals for the D.C. Circuit recognized in an opinion that “any rule that limits tailpipe CO2 emissions is effectively identical to a rule that limits fuel consumption.”77

• A district court found after expert testimony that “there is a mathematical relationship between fuel consumption and carbon dioxide emissions.”78

73 For empirical data, see e.g., EPA, Tier 3 Certification Fuel Impacts Test Program, EPA-420-R-18- 004 (Jan. 2018). 74 This conversion is based simply on the ratio of the molecular weight of carbon and carbon dioxide, 44/12. See EPA, Average Carbon Dioxide Emissions Resulting from Gasoline and Diesel Fuel 2–3 (Feb. 2005). 75 EPA, Greenhouse Gas Emissions from a Typical Passenger Vehicle 2 (May 2014) (8,887 / 404 = 22). 76 See id. (diesel). 77 Delta Const. Co. v. EPA., 783 F.3d 1291, 1294 (D.C. Cir. 2015) (quoting 76 Fed. Reg. 57,124–25). 78 Chrysler Plymouth Dodge Jeep v. Crombie, 508 F. Supp. 2d 295, 342 n.49 (D. Vt. 2007).

• NHTSA in a 2006 preamble found that “tailpipe CO2 emissions are always and directly linked to fuel consumption because CO2 is the ultimate end product of 79 burning gasoline. The more fuel a vehicle consumes, the more CO2 it emits.”

• EPA in a 2009 waiver for California acknowledged that California’s greenhouse gas standards “overlap significantly [with CAFE standards], in that the technology used to increase fuel efficiency will also lead to reductions in 80 emissions of . . . CO2.”

• Jody Freeman, the “architect” of the first joint national fuel economy and greenhouse gas standards, recognized that reducing automobile carbon dioxide “essentially requires improving fuel economy.”81

• More recently, NHTSA concluded after notice-and-comment proceedings that “as a practical matter, regulating fuel economy controls the amount of tailpipe emissions of carbon dioxide, and regulating the tailpipe emissions of carbon dioxide controls fuel economy.”82

• California and its supporters’ opening brief challenging NHTSA’s preemption rule admits that “[m]ost technologies automakers currently use to comply with greenhouse gas emission standards improve fuel economy and reduce tailpipe carbon-dioxide emissions.”83 These statements are correct. The relationship between fuel economy and greenhouse gas standards explains why NHTSA and EPA promulgate joint national standards. And it explains why the Minnesota Pollution Control Agency predicts that fuel savings will result in Minnesota from adoption of California’s carbon dioxide standards.84

79 71 Fed. Reg. at 17,654, 17,659. 80 2009 Waiver, 74 Fed. Reg. at 32,751. 81 Jody Freeman, The Obama Administration’s National Auto Policy: Lessons from the “Car Deal,” 35 Harv. Envtl. L. Rev. 343, 350 (2011). 82 49 C.F.R. Part 531, App’x B(a)(1)(B). 83 Opening Br. State and Local and Public Interest Petitioners 100, Union of Concerned Scientists v. NHTSA, No. 19-1230, Doc. #1849316. The brief claims that there are “exceptions,” id., but the exceptions only prove the rule. 84 SONAR at 9.

2. The proposed carbon dioxide standards are de facto fuel economy standards. Given the functional relationship between carbon dioxide and fuel economy, carbon dioxide standards are not just “related to fuel economy standards”: they are de facto average fuel economy standards.

Like CAFE, California’s carbon dioxide regulations set fleet-average model year standards for new automobiles. These standards are derived from “gram per mile CO2 target value[s]” for each automobile type (e.g., passenger car, light truck) produced based on size, as measured by its “footprint.”85 These targets are strikingly similar to NHTSA’s own footprint-based fuel economy targets.86

California, for example, assigns a passenger car “with a footprint of less than or 87 equal to 41 square feet” a “gram per mile CO2 target value” of 131 in model year 2025. For a gasoline-powered automobile, that is a fuel economy target of approximately 67.8 miles per gallon.88 In California, a manufacturer that produces only gasoline-powered passenger cars of this size would have to meet a fleet-average fuel economy standard of 67.8 miles per gallon in 2025, an extraordinarily burdensome standard that could only be met with internal combustion engines through economically impractical hybridization.

It does not matter that California has chosen to label its standards as carbon dioxide standards. Under CAFE, “[s]tate or local fuel economy standards would be preempted, regardless of whether they were in terms of miles per gallon or some other parameter such as horsepower or weight.”89 The choice of carbon dioxide as a label does not matter given the close functional relationship between carbon dioxide and fuel

85 The vehicle “footprint” is the area defined by the points where the tires contact the ground. Or defined more technically, it is “the product of average track width . . . and wheelbase . .. divided by 144 and then rounded to the nearest tenth of a square foot.” 40 C.F.R. § 86.1803-01. 86 Compare 13 Cal. Code Reg. § 1961.3(a) (California footprint-based carbon dioxide targets), with 49 C.F.R. § 531.5(c) (NHTSA footprint-based fuel economy targets); see also 49 C.F.R. Part 531, App’x (example of calculating compliance under § 531.5(c)). 87 13 Cal. Code Reg. § 1961.3(a)(1)(A). 88 8,887 grams of CO2 per gallon of gasoline / 131 grams of CO2 per mile = 67.8 miles per gallon. 89 S. Rep. No. 93-526, at 66.

economy standards. To quote Shakespeare, “[t]hat which we call a rose by any other name would smell as sweet.”90

Despite this relationship, California and its allies argue state carbon dioxide standards are not “related” to fuel economy because there is no direct “mathematical” relationship between efficiency and carbon emissions for hydrogen or electric powertrains.91 Hydrogen automobiles emit only water, and electric automobiles do not have tailpipe emissions, since their carbon pollution is shifted upstream to the utility sector.

The relationship between carbon emissions and fuel economy for these automobiles is more complex. But California’s regulations apply to all automobiles, including all liquid- and gaseous-fueled automobiles for which there is a direct functional relationship between fuel economy and carbon dioxide emissions. “Preemption cannot be avoided by intertwining preempted requirements with non-preempted requirements.”92 California’s argument that its carbon dioxide regulations are not always precisely identical to fuel economy standards for all technologies is therefore beside the point. Carbon dioxide standards and fuel economy need only be “related” for preemption to apply. The relationship is undeniable, as California’s weak defense amply illustrates.

3. Because of their relation to fuel economy standards, state carbon dioxide standards have no environmental policy justification. There is a good reason for preempting state carbon dioxide standards like the proposed standards: State carbon dioxide standards make no sense when sprinkled atop of a national fleet-average fuel economy standard. Since compliance with federal fuel economy (or carbon dioxide) standards is determined by averaging an automobile manufacturer’s fleet nationwide, “the increased fuel economy of [California] vehicles would likely be offset by less efficient vehicles produced for sale in the rest of the U.S.,

90 84 Fed. Reg. at 51,316 (quoting W. Shakespeare, Romeo & Juliet, II, ii (47–48)(1597)). 91 Opening Br. State and Local and Public Interest Petitioners 87–93, Union of Concerned Scientists v. NHTSA, No. 19-1230, Doc. #1849316. 92 Cent. Valley Chrysler-Plymouth v. CARB, 2002 WL 34499459, at *4 (E.D. Cal. June 11, 2002).

leading to little to no change in either fuel use or [greenhouse-gas] emissions at a national level.”93

The net effect of the ambitious standard on national carbon pollution may be zero. For each compliant car sold in Minnesota, a manufacturer will be able to sell automobiles emitting more grams of carbon per mile elsewhere in the United States and still meet the same fleet-average federal standard, entirely offsetting Minnesota’s standards. Because reducing carbon dioxide emissions is costly, automobile manufacturers have strong economic incentives to offset the effect of state standards in other states. As one would expect, peer-reviewed studies show that carbon leakage offset carbon-reduction benefits from state automobile carbon dioxide standards, imposing additional compliance costs on automobile manufacturers for little or no incremental benefit.94

B. Attempts to impliedly exempt California’s standards from CAFE preemption fail. A coalition of states led by California (including Minnesota), as well as utilities and environmental pressure groups, dispute CAFE preemption. California’s coalition principally argues that Congress impliedly exempted California state standards that receive a Clean Air Act waiver from preemption under CAFE.95 This contention cannot be squared with the text.

The Clean Air Act’s text is straightforward. A waiver under section 209(b) “waive[s]

93 84 Fed. Reg. at 51,354. 94 See A. Jenn, et al., Alternative Fuel Vehicle Adoption Increases Fleet Gasoline Consumption and Greenhouse Gas Emissions Under United States Corporate Average Fuel Economy Policy and Greenhouse Gas Emissions Standards, 50 Environ. Sci. Technol. 2165 (2016); L. H. Goulder et al., Unintended Consequences from Nested State and Federal Regulations: The Case of the Pavley Greenhouse-Gas-Per-Mile Limits, 63 J. of Environ. Econ. & Mgmt. 187 (2012) (concluding that state carbon dioxide rules “would lead to ‘emissions leakage’ of 100 percent at the margin: the reductions within [California and other] states would be completely offset by emissions increases outside of those states”) (emphasis added) . The Congressional Budget Office has also predicted the same effect for federal tax credits. CBO, Effects of Federal Tax Credits for the Purchase of Electric Vehicles 14 (2012) (“With CAFE standards in place, therefore, putting more electric (or other high-fuel-economy) vehicles on the road will produce little or no net reduction in total gasoline consumption and greenhouse gas emissions.”). 95 Opening Br. State and Local and Public Interest Petitioners 87–93, Union of Concerned Scientists v. NHTSA, No. 19-1230, Doc. #1849316.

the application of this section”—section 209 of the Clean Air Act only.96 A Clean Air Act 209(b) waiver does not waive application of CAFE or any other federal preemption statutes. The same is true for section 177, which is limited to a waiver from “section 209(a)” of the Clean Air Act.97

CAFE’s text is also clear. “[A] State may not adopt or enforce a law or regulation related to fuel economy standards for automobiles.”98 Congress made only a single exception from this prohibition—“[A] state may prescribe requirements for fuel economy for automobiles obtained for its own use.”99 California is a “State,” not a foreign sovereign, so it is subject to the ordinary operation of the Supremacy Clause and CAFE’s plain text. As the Clean Air Act’s limited California exception demonstrates, Congress knows how to carve out states from general preemption laws, and it chose not to do so in CAFE.100 It chose instead to make preemption fully applicable to any State, maintaining federal uniformity.

Through an esoteric reading of the statute, California and its allies argue that a California exemption must be inferred from other CAFE provisions that do not deal with preemption at all.

Explaining California’s convoluted argument requires a historical detour. The original CAFE statute, the “Motor Vehicle and Cost Savings Act,” as amended in 1975, required automobile manufacturers to meet stringent “passenger car” fuel economy standards increasing from 18 miles per gallon in 1978 to 27.5 miles per gallon in 1985.101 But CAFE allowed any individual manufacturer to request a variance from the

96 42 U.S.C. § 7543. 97 Id. § 7543. 98 49 U.S.C. § 32919(a). 99 Id. § 32919(c). 100 See Russello v. United States, 464 U.S. 16, 23 (1983) (“[W]here Congress includes particular language in one section of a statute but omits it in another section of the same Act, it is generally presumed that Congress acts intentionally and purposely in the disparate inclusion or exclusion.” (citation omitted)). 101 Motor Vehicle Information and Cost Savings Act § 502(a)(1), 89 Stat. 871, 902. Only standards for 1978, 1979, 1980, and 1985 are numerically specified. From 1981 to 1984, CAFE required NHTSA to set maximum feasible standards that adequately made progress toward the 1985 goal. Id. § 502(a)(3), 89 Stat. 903.

passenger car standards for initial model years 1978, 1979, and 1980.102 To get a variance for any of these years, a manufacturer had to show “a Federal standards fuel economy reduction is likely to exist for such manufacturer for the model year to which the application relates.”103 And, for purposes of “this subsection” only—the subsection dealing with variances for these three initial model years—the term “Federal standards” included “emissions standards applicable by reason of section 209(b)” of the Clean Air Act.104 This limited consideration was adopted because California’s existing emission standards for smog-forming pollutants could have made it slightly more difficult for automobile manufacturers to increase fuel economy standards.105 Given that this transitional variance provision had no effect after 1980, Congress omitted this provision when it recodified the CAFE statute in 1994.106

The CAFE statute today requires that NHTSA consider several factors when setting fuel economy standards, including “the effect of other motor vehicle standards of the Government on fuel economy.”107 The term “standards of the Government” is an undefined term, but, based on the definition of “Federal standards” in the now defunct variance provision, California argues that “standards of the Government” does not bear its ordinary singular meaning, but means instead both federal standards and California standards waived under § 209(b) of the Clean Air Act. California further argues that this means that California’s standards are entirely outside the scope of CAFE’s preemption provision. Both propositions are wrong.

Congress “does not alter the fundamental details of a regulatory scheme in vague terms or ancillary provisions—it does not, one might say, hide elephants in

102 Id. § 502(d)(1), 89 Stat. 904. 103 Id. § 502(d)(2)(A)(i), 89 Stat. 904. 104 Id. § 502(d)(2)(A)(i), 89 Stat. 904. 105 H.R. Rep. 94-340, at 1849 (“The 1975 California standards ... appear to result in a 5.7 percent fuel penalty relative to automobiles subject to the 49 state standards”); Cal. Admin. Code § 1955.1 (1975). 106 3 Fed. Reg. at 43,210/2-3 (citing H.R. Rep. No. 103-180, at 583–584, tbl. 2A). The recodification made no substantive changes to the statute. Pub. L. No. 103-272, 108 Stat. 745 (1994) (preamble). 107 Id.

mouseholes.”108 California relies on the tiniest mousehole—a definition applicable only to a time-limited variance—to fit a mastodon—a total rewrite of the CAFE preemption provision that guts the national fuel economy program, supplementing NHTSA’s national standards with a patchwork of de facto fuel economy standards dictated from Sacramento.

Consider what would need to be true for California’s reading to be right.

First, in 1975, although Congress appeared to preempt all state regulations related to fuel economy, Congress furtively intended the sui generis definition of “Federal standards”—which expressly applied only to a temporary variance provision—to license a separate California fuel economy program on top of Congress’ carefully designed national fuel economy program. This “monster, in which the head was under the direction of the members,” finds no support in the text, structure, or purpose of the statute.109 If Congress intended to grant California such an extraordinary exemption from CAFE preemption, Congress would have said so more clearly, as it did under the Clean Air Act.

Second, when Congress enacted the 1977 Clean Air Act Amendments and said that section 209(b) and 177 waive preemption only from section 209(a) of the Clean Air Act, it silently also meant to allow any section 177 state to copy California’s de facto fuel economy standards.

Congress does not act in such a secretive fashion when making decisions of such vast political and economic importance.

Nor does the variance definition of “Federal standards” reflect any congressional judgment that California standards would never be preempted by CAFE. More likely, it reflects the fact that California’s 1975 standards targeted smog-forming emissions— nitrogen oxides or hydrocarbons—that are not “related to fuel economy standards.” Nitrogen oxides and hydrocarbons are controlled through a variety of emission control technologies, including the installation of three-way catalysts, more sophisticated fuel

108 Whitman v. American Trucking Assns., Inc., 531 U.S. 457, 468 (2001). 109 Federalist No. 44.

injection software, or charcoal canisters to control hydrocarbon evaporation.110 None of these are efficiency technologies. By contrast, “[a]lmost all technologically feasible reduction of tailpipe emissions of carbon dioxide is achievable through improving fuel economy, thereby reducing both the consumption of fuel and the creation and emission of carbon dioxide.”111

Nothing in the variance provisions can be sensibly read as exempting de facto fuel economy standards adopted by California or any other copycat state. Congress plainly contemplated that any regulations functionally related to fuel economy standards—for example, regulating vehicle weight or horsepower—would be preempted. Carbon is even more functionally related to fuel economy than vehicle weight or horsepower, so it is preempted.

CAFE’s preemption provision is simple. Any state regulations substantially related to fuel economy standards or average fuel economy standards are preempted, regardless of how they are labeled. California gets no special treatment. Indeed, implying a special exemption for California would raise serious equal sovereignty constitutional concerns given the lack of any reasonable policy justification for such disparate treatment, so any ambiguity must be construed against California’s reading of the statute.112

* * *

State carbon dioxide standards like California’s effectively control the rate of automobile fuel economy improvements, second-guess NHTSA’s expert judgments, and replace one national fuel economy standard with a patchwork of overlapping state standards dictated from Sacramento. This does nothing to increase fuel economy or reduce carbon dioxide, but it does increase economic costs and conflicts with federal law. Strained attempts to infer an exemption for California standards do serious violence to unambiguous statutory text and the national design of the standards. The proposed rule is therefore not needed or reasonable.

110 For a description of technologies, see Control of Air Pollution from Motor Vehicles: Tier 3 Motor Vehicle Emission and Fuel Standards Final Rule, Regulatory Impact Analysis, Ch. 1 (2014). 111 See 40 C.F.R. Part 531, App’x B(a)(1)(D). 112 See Nw. Austin Mun. Util. Dist. No. One. v. Holder, 557 U.S. 193, 203 (2009).

III. ELECTRIC AUTOMOBILE QUOTAS ARE PREEMPTED BY FEDERAL LAW. CAFE’s broad preemption provision also prohibits the proposed quotas mandating electric- or hydrogen-fueled automobiles. And in any event, these quotas are impliedly preempted by CAFE. Because they are illegal, they are not needed or reasonable.

A. The Proposed Electric Automobile Quotas Are Related to Average Fuel Economy Standards. 1. State electric automobile quotas restrict manufacturer compliance choices and undermine CAFE’s flexible fleet- average standards. CAFE forbids any state from adopting or enforcing “a law or regulation related to fuel economy standards or average fuel economy standards for automobiles.” The Supreme Court has interpreted the term “related to” in preemption statutes on many occasions.113 The “ordinary meaning” of “related to” “is a broad one—‘to stand in some relation; to have bearing or concern; to pertain; refer; to bring into association with or connection with,’ . . .—and the words thus express a broad pre-emptive purpose.”114 An impermissible “connection” to “fuel economy standards” may be found in a broad variety of circumstances. For example, under ERISA’s analogous preemption provision, the Supreme Court has held that a state law has an impermissible connection with ERISA plans if the indirect economic effects of the state law “force an ERISA plan to adopt a certain scheme of substantive coverage or effectively restrict its choice of insurers.”115 A state law also has an impermissible connection to ERISA if intrudes upon “a central matter of plan administration” or “interferes with nationally uniform plan administration.”116 This broad interpretation of “related to” is equally applicable to CAFE.117

The zero-emissions vehicle standard is related to fleet-average fuel economy

113 Morales v. Trans World Airlines, 504 U.S. 374, 383–84 (1992) (citing cases). 114 Morales, 504 U.S. at 383 (quoting Black’s Law Dictionary 1158 (5th ed. 1979)). 115 New York State Conference of Blue Cross & Blue Shield Plans v. Travelers Ins. Co., 514 U. S. 645, 668 (1995). 116 Gobeille v. Liberty Mut. Ins. Co., 136 S. Ct. 936, 945 (2016). 117See Metro. Taxicab Bd. of Trade, 615 F.3d at 157–58 (applying ERISA caselaw to CAFE preemption).

standards because it in effect requires the production of a certain percentage of electric automobiles per conventional vehicle sold, or the production of an equivalent number of credits. The zero-emissions vehicle standard works by increasing the cost of producing less efficient gasoline or diesel automobiles (as each car comes with a zero- emissions vehicle percentage obligation), and cross-subsidizing more efficient alternative fuel powertrains—electric automobiles. The effect of this program is to force automobile manufacturers to meet fleet-average fuel economy standards with a costlier fuel-efficiency technology, restricting manufacturer compliance choices and undermining CAFE’s flexible performance standards.118 The Second Circuit has held that analogous rules encouraging the adoption of hybrid and plug-in taxis are preempted as “related to” fuel economy.119 The same logic applies here.

California’s zero-emissions vehicle standard is functionally related to average fuel economy standards in yet another way.120 The number of credits manufacturers get for producing electric automobiles depends on driving range, with greater driving ranges getting more credits (up to 4 credits total per electric automobile).121 That central feature of the program is related to average fuel economy standards. For a given battery’s capacity (kilowatt hours of chemical potential energy stored in the battery), electric automobile range can be increased only by increasing their equivalent fuel economy (the number of miles per kilowatt-hour of chemical potential energy stored in the battery). Any regulations meant to encourage greater electric-automobile battery range therefore invariably encourage greater electric-automobile fuel efficiency and “relate[] to” average fuel economy standards.

2. Because of their relation to fuel economy standards, state electric automobile quotas have no environmental policy justification. Layering electric automobile standards on top of CAFE standards has perverse effects. Modeling studies predict that adding a state electric-vehicle automobile for 30%

118 Cf. New York State Conference of Blue Cross & Blue Shield Plans, 514 U. S. at 668. 119 See Metro. Taxicab Bd. of Trade, 615 F.3d at 158–59. 120 Id. 121 SONAR at 13; 13 Cal. Code. Reg. § 1962.2(d)(5)(A) (“ZEV Credit = (0.01) * (UDDS range) + 0.50”).

of the market on top of CAFE increases new automobile costs by $400 in 2025, undermining the economic practicability of the standards.122 “The reason for this cost increase is because, on the marginal cost curve of fuel-saving technologies, electrification of vehicles is relatively expensive per unit of fuel saved. Electrification is certainly a less cost-effective method . . . than refinements to the internal combustion engine.”123 And while electric-vehicle quotas increase costs, they also reduce fleet-average fuel economy and increase carbon emissions, undermining CAFE’s goal of increasing efficiency.124

To see why state electric car quotas decrease fuel economy and increase emissions, consider a simple hypothetical example. In the absence of a state electric-vehicle mandate, an automobile manufacturer could produce ten gasoline cars with a fleet- average CAFE fuel economy of 40 miles per gallon each to meet a 40 mile-per-gallon fleet-average standard. But a state now mandates that one of the ten cars be a more expensive electric car. While the electric car has a superior fuel economy of 60 miles per gallon, its CAFE fuel economy is artificially inflated by an alternative fuel factor of 1/.15, to 400 miles per gallon.125 As a result, the automobile manufacturer can now meet the 40 mile per gallon fleet-average standard by producing one electric car, and nine gasoline automobiles with a fuel economy of less than 5 miles per gallon each. The manufacturer’s actual fleet-average fuel economy under this scenario—without the artificial alternative fuel factor—is in fact closer to 10 miles per gallon, a significant reduction in fleet-average fuel economy compared to a scenario without a mandate. Fleet-average fuel consumption increases due to the electric automobile mandate, increasing carbon emissions. In short, state electric automobile mandates, like the proposed standards, counterproductively increase average automobile costs and

122 A. Jenn et al., Cost Implications for Automaker Compliance of Zero Emissions Vehicle Requirements, 53 Environ. Sci. Technol. 564, 568–69 (2019). 123 Id. at 569. 124 Id. at 586 (“[W]hile policies that promote the market development of [electric automobiles] are effective at increasing production and adoption of the vehicles, the combination of state and national policies results in an emissions penalty−more emissions on a national basis than would occur if federal programs did not give compliance credit for the state-required vehicles. The more effective ZEV is at driving the market for electric vehicles, the greater the emissions penalty will be.”). 125 See infra pp. 9–10.

decrease average fuel economy at the same time, undermining both the goal of improved efficiency and the economic practicability of the standards.

The Minnesota Pollution Control Agency appropriately acknowledges this offsetting effect: “As a manufacturer produces more [electric automobiles], the fleet-average system effectively allows internal combustion engine vehicles produced by a manufacturer to emit a little more, on average, meaning more [electric automobiles] produced does not necessarily mean a greater tailpipe [carbon] benefit.”126 But the Agency fails to consider that, given the favorable treatment of electric automobiles under the federal standards, electric-automobile quotas likely increase net carbon pollution.

3. Attempts to carve out state electric automobile quotas from preemption fail. Supporters of electric quotas—including Minnesota—argue that zero-emissions vehicle standards are not “related to” fuel economy standards or average fuel economy standards.127 No.

Supporters of California’s quotas first argue that CAFE excludes the fuel economy of alternative fuels like electricity from preemption. As they point out, the term “fuel” is defined to mean “gasoline,” “diesel oil” or any “other liquid or gaseous fuel” that NHTSA says is fuel.128 Electricity and hydrogen, by contrast, are classified as “alternative fuel.”129 Fuel economy is in turn defined as “the average number of miles traveled by an automobile for each gallon of gasoline (or equivalent amount of other fuel) used, as determined by the Administrator under section 32904(c) of this title.”130 Because electricity and hydrogen are “alternative fuel,” and not “other fuel,” California asserts that electric automobiles do not have a “fuel economy” and hence cannot be

126 TSD at 18. 127 Opening Br. State and Local and Public Interest Petitioners 87–93, Union of Concerned Scientists v. NHTSA, No. 19-1230, Doc. #1849316. 128 49 U.S.C. § 32901(a)(10). 129 Id. § 32901(a)(1)(G), (J). 130 Id. § 32901(a)(11).

related to fuel economy standards.

This argument ignores half of the statutory prohibition. California’s standards are preempted if they are “related to” fuel economy standards or average fuel economy standards. Average fuel economy is defined as the “average fuel economy determined under section 32904 of this title.”131 A manufacturer’s average fuel economy under section 32904, essentially the fleet-performance compliance calculation, includes the fueleconomy equivalent of “an electric vehicle,” or any other alternative automobile.132 Because electric automobiles are considered for compliance with the average fuel economy standards under section 32904, they are “related to” average fuel economy standards.

California’s supporters further argue that the fact that NHTSA is not allowed to consider the efficiency of electric automobiles when setting fuel economy standards means that electric automobile quotas cannot be related to average fuel economy standards.133 But a statute that dictates what technologies manufacturers must use to comply with the average fuel economy standard is necessarily connected to the fuel economy standards under the broad meaning of “related.”134 California’s contrary argument would turn CAFE’s express limitation on setting standards upside down. Congress prohibited NHTSA’s consideration of electric automobile efficiency when setting fuel economy standards precisely because they are related to average fuel economy standards. It did this so that the standards could be met using only conventional fuel-efficiency technologies, instead of more expensive alternative fuel automobiles.135 Congress chose to incentivize, not mandate, alternative fuel

131 Id. § 32901(a)(5). The term “average fuel economy standards” is also defined by statute. It “means a performance standard specifying a minimum level of average fuel economy applicable to a manufacturer in a model year.” Id. § 32901(a)(6). 132 Id. § 32904(a)(2)(B). 133 The term “average fuel economy standards” is defined by statute. It “means a performance standard specifying a minimum level of average fuel economy applicable to a manufacturer in a model year.” Id. § 32901(a)(6). 134 Cf. Gobeille v. Liberty Mut. Ins. Co., 136 S. Ct. at 943 (“A state law also might have an impermissible connection with ERISA plans if acute, albeit indirect, economic effects of the state law force an ERISA plan to adopt a certain scheme of substantive coverage or effectively restrict its choice of insurers.”) (quotation marks omitted). 135 Id. § 32902(h).

technologies through fuel economy credits that reward the production of alternative fuel automobiles.136 State electric-automobile quotas undo this flexible and limited design that is central to CAFE standards, forcing the production of a particular kind of technology that Congress decided against mandating through average fuel economy standards.

California and its allies also argue that CAFE should not be read to preempt California’s zero-emissions vehicle standards because that would make text in the Clean Air Act Amendments of 1990 surplusage. That is wrong.

California’s surplusage argument relies on language in the “clean fuel vehicles” program established in the 1990 Clean Air Act Amendments.137 Under this program, EPA must establish emission standards for “clean-fuel vehicles.”138 States in “covered areas”—metropolitan areas with bad smog or carbon monoxide pollution—must modify their state implementation plans to require that “covered fleets”—largely government fleets—purchase new automobiles that meet the clean-fuel vehicle standards.139 Beginning in 1998, covered fleet operators had to buy an increasing percentage of new vehicles certified as clean-fuel vehicles under EPA’s regulations, and they had to use alternative fuels when operating these vehicles in the covered area.140 But “[t]he choice of clean-fuel vehicles and clean alternative fuels” had to “be made by the covered fleet operator.”141

The clean-fuel-vehicles program included a state compliance “credit” provision to

136 Id. § 32905. 137 42 U.S.C. Ch. 85, Subch. II, Part C. 138 Id. § 7582(a). That includes automobile “exhaust emission” standards for smog-forming emissions, carbon monoxide, nitrogen oxides, particulate matter, and formaldehyde. Id. § 7583(a), (b), (c). EPA must also establish standards for flexible-fuel vehicles that can operate on “clean- alternative fuel.” Id. § 7583(a), (b), (c). Clean-alternative fuel includes any “alternative fuel” under CAFE. Id. § 7581. EPA established the regulations in 1994. 59 Fed Reg. 50,042 (Sept. 30, 1994), codified at 40 C.F.R. Part 88. 139 Covered fleets” are those owned by a single entity with “10 or more motor vehicles,” excepting any vehicles “held for lease or rental” to the general public, non-road vehicles, and law-enforcement or other emergency vehicles. 42 U.S.C. § 7581(5); see also 40 C.F.R. § 88.302-94 (defining terms). 140 42 U.S.C. § 7581(b). 141 Id. § 7581(d).

reward fleet operators that exceeded expectations by purchasing more clean-fuel vehicles than required, or by purchasing vehicles “which meet more stringent standards established by” EPA.142 The even “more stringent” EPA standards had to “conform as closely as possible to standards which are established by the State of California” for certifying vehicles as “Ultra-Low Emissions Vehicles” and “Zero Emissions Vehicles.”143

California and its allies rely on the reference to California’s zero-emissions vehicle certification requirements to argue that Congress embraced electric-automobile production mandates, and argue that the reference would be surplusage if CAFE preempted California’s electric-automobile quotas. Not so.

The credit provision requires EPA to “certify vehicles,” not entire manufacturer fleets, as complying with “more stringent standards” for zero-emissions vehicles. In context, this refers to California’s numerical emission limits for certification of a particular vehicle as a zero-emissions vehicle, and not California’s separate production quotas for manufacturers. EPA’s sole task under this credit provision is to closely conform its certification requirements to California’s own requirements for what cars count as zero-emissions vehicles. This use of “standard” in the credit provision “to denote requirements such as numerical emission levels with which vehicles or engines must comply” “is consistent with the use of ‘standard’ throughout Title II of the Clean Air Act.”144

Consistent with the plain text, EPA has always interpreted the reference to “standards” as referring to California’s standards for defining zero-emissions vehicles, and not California’s electric-vehicle production quotas.145 EPA’s “Zero-Emissions Vehicle” standard for the clean-fuel-vehicle program simply requires that the vehicle have no exhaust, evaporative, or auxiliary system emissions of specific pollutants.146 As

142 42 U.S.C. § 7581(f)(1). 143 Id. § 7586(f)(4). 144 Engine Mfrs. Ass’n v. S. Coast Air Quality Mgmt. Dist., 541 U.S. 246, 253 (2004) (holding certain local fleet standards preempted by the Clean Air Act). 145 59 Fed. Reg. at 50,050 (“Consistent with the CARB, EPA is establishing ZEV standards which require zero emissions of the following pollutants: NMOG, NOx, CO, particulates, and HCHO.”). 146 Id. § 88.104-94(g).

long as a particular vehicle conforms to those California criteria, it is certified as a “more stringent standards” clean-fuel vehicle. Because this statute has nothing to do with electric-automobile quotas, EPA could continue conforming to California’s definition of zero-emissions vehicle. There is no surplusage at all in preempting electric- automobile quotas.

California’s argument that the reference to zero-emissions vehicles somehow requires EPA to conform to California’s production quotas makes no sense. The clean- fuels vehicle program has its own phase-in schedule for mandating the purchase of clean-fuel vehicles, and “the choice of clean-fuel vehicles and clean alternative fuels” has to always “be made by the covered fleet operator,” not by decree of EPA or the states.147

The only clean-vehicle program provision that references production quotas like California’s expressly prohibits them. EPA rules or state plans may provide additional incentives for clean-fuel vehicles through a separate voluntary program, but the rules or plans “shall not include any production or sales mandate for clean-fuel vehicles” or subject automobile manufacturers to “penalties or sanctions for failing to produce or sell clean-fuel vehicles or clean alternative fuels.”148 Thus, the only section of the program that addresses electric-automobile production quotas prohibits them. That would be quite a strange way for Congress to embrace California’s electric-automobile quotas.

The argument that the Clean Air Act Amendments of 1990 somehow embraced California’s mandate, or that CAFE preemption would make any provision of the Clean Air Act surplusage, does not stand up to scrutiny. The only court to ever address CAFE preemption for California’s first zero-emissions vehicle mandate held that the mandate was preempted by CAFE.149 California never raised this surplusage argument in that litigation because the argument is meritless. Nor did that ruling render the credit provision’s reference to zero-emissions vehicles surplusage. The same is true now.

147 42 U.S.C. § 7581(b), (d). 148 Id. § 7589. 149 Cent. Valley Chrysler-Plymouth, 2002 WL 34499459, at *7.

B. The Proposed Electric Automobile Quotas Impliedly Conflict with the Statute. The zero-emissions vehicle standards are also impliedly preempted by CAFE because they stand as an obstacle to the statute’s objectives.150 CAFE gives automobile manufacturers flexible choices. Automobile manufacturers may meet the standards using conventional fuel-efficiency technologies or using a variety of alternative fuel technologies.151 CAFE pursues an all-of-the-above strategy for alternative fuels, where all liquid and gaseous alternative fuels have the same fuel economy credit multiplier (1/0.15) (as does electricity under the Department of Energy’s regulations).152 This allows automobile manufacturers a choice between improving conventional automobile fuel economy or producing a investing in a variety of alternative fuel technologies, including automobiles capable of operating on alternative liquid and natural gas fuels, not just electricity.

California’s electric automobile quotas take away that statutory choice by mandating the production of electric automobiles, when Congress has decided to encourage a range of options. Thus, as in Geier v. American Honda Motor, California’s zero-emissions vehicle regulation is “an obstacle to the variety and mix of devices that the federal regulation sought.”153

IV. THE MINNESOTA POLLUTION CONTROL AGENCY’S TECHNICAL ANALYSIS IS DEEPLY FLAWED. Even setting aside the proposed rule’s illegally under federal law, the proposed rule’s technical analysis contains numerous unrealistic assumptions. The Agency fails to consider significant aspects of the problem. Once these failures are understood, it is manifest that the proposed electric automobile quota and carbon dioxide standards are

150 See Geier, 529 U.S. at 881. 151 Id. §§ 32902(h), 32905. 152 See supra pp. 9–10. 153 Cf. Geier, 529 U.S. at 881 (holding that any rule of state tort law imposing a duty to install airbags was preempted by the National Traffic and Motor Vehicle Safety Act of 1966 and NHTSA’s implementing regulations, because the tort law would present “an obstacle to the variety and mix of devices that the federal regulation sought”).

not needed or reasonable at all.

A. The Technical Analysis Arbitrarily Ignores Leakage. Minnesota’s Pollution Control Agency asserts that the state greenhouse gas standards will have climate benefits, mostly from reduced tailpipe carbon emissions.154 It monetizes the global climate benefits of the rule at $500 million over the first ten years of the program.155

This is false. The proposed greenhouse gas standards have little or no global greenhouse gas benefits. As explained in greater detail in Part II.A.3, empirical literature demonstrates that automobile manufacturers will likely offset all or most of Minnesota’s requirements in other states, selling less fuel-efficient automobiles in other states while still complying with the same national average fuel economy and greenhouse gas standards.156 Most or all of the climate benefits of any in-state greenhouse gas emissions reductions are offset by corresponding increases in out-of-state emissions, as manufacturers shift fleets around while complying with the same national fleet-average standards.157

This offset phenomenon is well-known in environmental economics as “leakage.” Carbon leakage is particularly important because as far as climate-change policy is concerned, it does not matter where carbon dioxide emissions come from. Carbon dioxide globally mixes in the upper atmosphere, leaving the same concentration over Minnesota as over the rest of the country and, indeed, the whole world. Consequently,

154 SONAR at 78. The agency estimates that the rule will reduce tailpipe carbon dioxide emissions by 7.1 million tons in its first ten years. TSD at 25. 155 Id. at 79. The Agency quantifies the rule’s climate benefit using the federal social cost of carbon. Id. at 78. But in doing so, the Agency arbitrarily ignores that the effects of climate change are not uniformly geographically distributed, and that Minnesota will likely experience a net economic benefit from increased global mean surface temperatures. S. Hsiang et al., Estimating the economic damage from climate change in the United States, 356 Science 1362, 1364, Figure 2(I) (2017). 156 See supra pp. 21. 157 See, e.g., L.J. Goulder et al., supra note 94, at 205; see also J. Linn & V. McConnell, Interactions between federal and state policies for reducing vehicle emissions, 126 Energy Policy 507, 515 (2019) (“If the [state and national] standards are binding for all manufacturers, a state policy that reduces the average GHG emissions rate of new passenger vehicles sold in that state will cause an increase in the average emissions rate of vehicles sold in other states.”).

Minnesota’s carbon emissions are “not more relevant to the pollution problem at issue (i.e., climate change) . . . than are the [carbon-dioxide] emissions from cars being driven in New York, London, Johannesburg, or Tokyo.”158 Policies that simply drive carbon emissions elsewhere do nothing to reduce the threat posed by climate change. In fact, because leaky climate policies use up economic resources that could have been more usefully devoted to effective policies, they are in fact counterproductive.

The Minnesota Pollution Control Agency’s failure to consider carbon leakage in other states when calculating global climate benefits is arbitrary and capricious. It makes no sense to consider Minnesota’s greenhouse gas reductions in isolation, while ignoring the resulting increased greenhouse gas emissions in other states, particularly given the high likelihood of carbon leakage under federal standards. The reality is that, once leakage is considered, the proposed greenhouse gas standards have at best speculative climate benefits. The $500 million in net climate benefits should therefore be discounted down to zero.

The Minnesota Pollution Control Agency’s failure to consider carbon leakage is indefensible given that the Agency appropriately considered leakage for the zero- emissions vehicle quota.159 As the Agency acknowledges, due to the interaction with both federal and state “fleet-average” standards, the zero-emissions vehicle standard has no “tailpipe” greenhouse gas benefits.160 For a similar reason, the criteria-pollutant emissions also have no tailpipe emission benefits.161 (In reality, the upstream pollution benefits are also speculative, as refiners can shift the sale of their fuel to other

158 84 Fed. Reg. at 51,354. 159 TSD at 18. 160 Id. (“Since the SAFE and LEV GHG standards are enforced as a fleet average requirement for vehicle manufacturers, tailpipe GHG emissions benefits from additional EVs required under the ZEV standard are not included in tailpipe emissions benefit estimates. This is because EVs are allowed to be included when calculating a manufacturer’s fleet-wide average. As a manufacturer produces more EVs, the fleet-average system effectively allows internal combustion engine vehicles produced by a manufacturer to emit a little more, on average, meaning more EVs produced does not necessarily mean a greater tailpipe GHG benefit.”). 161 Id. (“Since LEV and federal NMOG + NOX emissions standards are equivalent, NMOG + NOX emissions rates are equal for vehicles in both scenarios. Since these pollutants are emitted at the same rate in each scenario, all estimated emissions reductions of these pollutants are a result of reduced upstream emissions from fuel production.”).

neighboring states that have less fuel-efficient cars. Oil is a global commodity, gasoline is a regional commodity, and ozone is a regional problem.) Given the Agency’s consideration of leakage for the zero-emissions vehicle quota and the criteria pollution standards, the Agency’s failure to consider how the same exact kind of leakage applies to its greenhouse gas standards is difficult to explain as anything other than an intentional oversight.

B. The Technical Analysis Arbitrarily Ignores the Rebound Effect. Even if ignoring leakage were appropriate, and it is not, the Minnesota Pollution Control Agency’s analysis overestimates the proposed rule’s impact on emissions by unreasonably assuming a “rebound effect” of zero.162 When driving costs less, either because an automobile is more fuel-efficient or because it uses cheaper electricity, drivers tend to drive more. This well-established phenomenon is known as the rebound effect, and it can significantly alter the consequences of emissions regulations. Estimates of the rebound effect vary, with academic studies finding rebound effects ranging from 10% to 50% of each mile per gallon.163 This means that for each ten percent increase in fuel economy, drivers will drive roughly 1% to 5% additional miles. EPA and NHTSA have used rebound-effect values ranging from 10% to 20% in recent rulemakings.164

The additional vehicle miles traveled under the proposed rule due to the rebound effect will generate additional greenhouse gas, particle, and smog-forming pollution, offsetting the alleged pollution benefits. The Agency arbitrarily and capriciously disregards this critical, well-known, and economically predictable effect. The Agency also ignores other consequences that flow from the rebound effect, including increased

162 The agency uses the same vehicle miles traveled for each scenario. TSD at 17 (“We used the same VMT values in both the Reference and Clean Cars scenario.”). 163 J. Linn & V. McConnell, Interactions between federal and state policies for reducing vehicle emissions, 126 Energy Policy 507, 515 (2019) (“[R]ecent studies have yielded a range of estimates [for the rebound effect] . . . typically falling between 10% and 30%.”); SAFE Rule, 85 Fed. Reg. at 24,674 (collecting studies and observing, “[t]he newer studies suggest that a plausible range for the rebound effect is 10–50 percent”). 164 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy Standards, 77 Fed. Reg. 62,624, 62,924–25 (Oct. 15, 2012) (using a rebound effect of 10%); SAFE Rule, 85 Fed. Reg. at 24,677 (using a rebound effect of 20%).

traffic fatalities that would result from the greater number of vehicle miles traveled under its proposed rule. NHTSA, on the other hand, carefully considers all of these issues to reach an economically practicable balance when promulgating fuel economy standards.

C. The Technical Analysis Arbitrarily Ignores Delayed Turnover Effects. Apart from ignoring the rebound effect, the Minnesota Pollution Control Agency also ignores the effect of its proposed rule on the rate of new automobiles purchases. If new automobile prices are higher, consumers will tend to delay the purchase of new vehicles, keeping older, more polluting automobiles on the road for longer. The additional fuel consumed—and emissions generated—by these older, dirtier automobiles offsets potential benefits under the proposed rule. This delayed turnover effect can be significant, increasing fuel consumption and emissions by up to 13% to 16% by some estimates.165

The Agency admits that its proposed rule will increase automobile prices for Minnesota’s consumers, but fails to account for the corresponding delayed turnover effect. According to the Agency’s estimates, the proposed greenhouse gas standard will increase the cost of a new gasoline automobile by $1,139.166 The costs under the proposed electric-automobile quota are similarly high: over the first ten years, plug-in hybrids are expected to cost $4,468 to $6,083 more than gasoline automobiles, depending on model year.167 Battery-electric automobiles are expected to cost $3,136 more in 2025, reaching cost parity with gasoline automobiles by 2028.168 These are significant price increases, and the Agency arbitrarily omits from its analysis the increased fuel consumption and emissions that will invariably arise from the resulting delayed vehicle turnover.

The Agency’s failure to consider this significant aspect of the problem is arbitrary

165 X. Dou & J. Linn, How Do US Passenger Vehicle Fuel Economy Standards Affect New Vehicle Purchases? 102 J Envt’l Econ. & Mgmt. (2020); M.R. Jacobsen & A.A. Van Benthem, Vehicle Scrappage and Gasoline Policy, 105 Am. Econ. Rev. 1312, 1314 (2015). 166 TSD at 38. 167 Id. at 53. 168 Id.

and capricious. It must be corrected.

D. The Technical Analysis Arbitrarily Ignores Cold Weather Effects. The proposed rule’s technical analysis also fails to account for the reduced efficiency of electric automobiles in cold weather, a significant oversight considering the average January temperature in Minnesota is approximately 12°F.169 A study by consumer group AAA found that operating in 20°F weather reduces electric-automobile efficiency by approximately 40% when compared to operating in the more temperate California-style conditions used to determine electric-automobile efficiency during certification testing.170

Incorporating the lower cold weather electric automobile efficiencies into the Agency’s analysis will substantially increase the amount of electricity needed to power electric automobiles on the road, which will similarly increase the upstream pollution

169 Average statewide temperature in Minnesota in January from 2000 to 2021. NOAA, Climate at a Glance: Statewide Time Series (published Feb. 2021), https://www.ncdc.noaa.gov/cag/. 170 AAA, AAA Electric Vehicle Range Testing 3 (Feb. 2019). (When using HVAC, electric automobile operation “at 20°F resulted in a 41 percent decrease of combined driving range and a 39 percent decrease of combined equivalent fuel economy (when compared to testing conducted at 75°F).”); see also SAE Tech. Paper 2013-01-1462 (similar). Source for the chart is Dep’t of Energy, Fuel Economy in Cold Weather, Fact of the Week #1164 (Dec. 14, 2020).

from the power sector.171 Given that average temperatures in Minnesota are below 20°F for nearly a third of the year,172 the additional emissions from increased electricity use are likely substantial.173

Moreover, the lower cold weather electric automobile efficiencies will decrease the estimated fuel cost savings to drivers, as drivers will have to purchase more electricity over the course of the vehicle’s lifespan than estimated by the Agency.174 These cold weather effects could considerably change the Agency’s economic analysis. For example, for model year 2034 vehicles, the Agency estimates the zero-emissions vehicle mandate will generate a fuel savings gain of less than $5 million compared to the reference scenario (not discounting to net present value).175 If cold weather effects reduce electric automobile fuel savings by only 6.4%, the savings benefit of the zero- emissions vehicle quota, relative to the reference scenario, for model year 2034 would be entirely wiped out.176 And if the reduction in cost savings is greater than 6.4%, the reference scenario will provide greater fuel savings than the zero-emissions vehicle quota for that model year.

171 TSD at 26, 28–30. 172 Average statewide temperatures in Minnesota in December, January, and February are below 20°F (calculated from 2000 to 2021). NOAA, supra note 169. 173 As a rough estimate, assuming that electric automobile efficiency is 0.6 times the standard warm weather efficiency (a decrease of 40%), an electric automobile operating in cold weather will require (1/0.6) = 1.67 times as much electricity as it would in warm weather to go the very same distance. Assuming that an electric automobile travels the same number of miles each month, operating three months in cold weather and nine months in warm weather would require 1.17 times as much annual electricity as operating in warm weather during the entire year, a 17% increase ((9 + (3 x 1.67))/12 = 1.17). Pollution from increased electricity generation would similarly be expected to increase 17%. 174 See TSD at 55–58. 175 Id. at 56, Table 28. 176 Id. From Table 28, for model year 2034: a 6.4% decrease due to cold weather effects would reduce the MY 2034 lifetime fuel cost savings under the zero-emission vehicle quota by $4.92M, more than estimated $4.90M benefit relative to the refence scenario. An accurate accounting of cold weather effects should include not only the decrease in electric automobile efficiency at cold temperatures, but also the decrease in combined city-highway fuel economy of gasoline-engines at cold temperatures. Cold temperatures are estimated to decrease city fuel economy of gasoline-engine vehicles by approximately 15%. Dep’t of Energy, supra note 170. Cold temperatures are unlikely to significantly decrease the highway fuel economy of gasoline-engine vehicles.

The Agency’s failure to account for cold weather—in Minnesota of all places— ignores a significant aspect of the problem and is arbitrary and capricious.

E. The Technical Analysis Arbitrarily Assumes All Criteria Pollution Reductions Will Be in Minnesota. While including out-of-state carbon emissions is essential for determining the climate benefits (or lack thereof) of the proposed rule, concluding that all out-of-state criteria pollutant emissions—whose effects are regional—will also benefit Minnesota is not appropriate when determining the proposed rule’s impact on Minnesota’s air quality.177

The Minnesota Pollution Control Agency’s analysis improperly incorporates out-of- state criteria emissions in its analysis by improperly assuming all upstream particulate matter and smog emissions from gasoline production and electricity generation will benefit Minnesota.178 These upstream emissions are produced through “liquid fuel extraction, transportation, and production” and “the extraction, processing, and transportation” of fuels necessary to generate electricity, including many activities that occur outside the state.179 The Agency admits that “emissions from gasoline and electricity extraction and production may not necessarily occur in Minnesota.”180 But it makes no effort to estimate the portion of regional particulate and smog emissions that will affect Minnesota’s air quality. The Agency therefore overstates the proposed rule’s asserted pollution benefits by incorporating emissions effects that will not accrue in Minnesota.

And the overstatement could be substantial, particularly for smog-forming

177 Indeed, without a formal air-quality analysis, one cannot even assume that pollution reductions in Minnesota will benefit Minnesota’s air quality. EPA v. EME Homer City Generation, L.P., 572 U.S. 489, 496 (2014) (“Air pollution is transient, heedless of state boundaries. Pollutants generated by upwind sources are often transported by air currents, sometimes over hundreds of miles, to downwind States. As the pollution travels out of state, upwind States are relieved of the associated costs. Those costs are borne instead by the downwind States, whose ability to achieve and maintain satisfactory air quality is hampered by the steady stream of infiltrating pollution.”). 178 TSD at 27–30. 179 Id. at 25. 180 Id.

emissions, where the estimated benefit derives entirely from upstream contributions.181 Because the Agency arbitrarily assumed all of out-of-state pollution would accrue benefits in Minnesota, its estimate cannot accurately reflect the proposed rule’s impact on Minnesota air quality.

F. The Technical Analysis Arbitrarily Ignores Particulate Matter Emissions from Wear and Tear. The Minnesota Pollution Control Agency’s analysis also overstates reductions in fine particle emissions because it fails to account for the comparably higher wear and tear of electric automobiles.182

Automobile particulate emissions arise from two sources: exhaust emissions and non-exhaust emissions from tire and road wear and tear.183 While electric automobiles have no exhaust particle emissions, they have higher non-exhaust particle emissions that gasoline cars because they are heavier, and so generate more particle emissions from tire and road wear and tear.184 For passenger cars, the increase in non-exhaust particle emissions nearly fully offsets the decrease in tailpipe particle emissions, so that overall, electric automobiles do not provide substantial particulate benefits compared to gasoline-only automobiles.185

But the Agency’s analysis entirely ignores non-exhaust particle emissions, and so incorporates only the tailpipe emission benefits of electric automobiles while excluding their drawbacks. When both exhaust and non-exhaust sources are included in the

181 Id. at 22, 28 (“All estimated emissions benefits of [smog-forming] pollutants reported in this analysis are from reductions in upstream emissions.”). 182 See TSD at 27–29, Figure 10 & Table 8. The Agency’s particulate matter analysis includes contributions from (1) tailpipe emissions benefits from “old vehicles with higher emissions [being] replaced by either lower-emitting LEV-certified [internal combustion engine] vehicles, [battery- electric vehicles], or [plug-in hybrid electric vehicles];” (2) upstream emissions benefits from reduced gasoline production; (3) and upstream emissions costs from electricity generation for additional electric vehicles. Id. 183 See V.R.J.H. Timmers & P.A.K. Achten, Non-exhaust PM emissions from electric vehicles, 134 Atmospheric Env’t. 10, 10 (2016). 184 Id. at 15. 185 Id. at 14 (“EVs emit the same amount of PM10 as modern gasoline and diesel cars” and “bring about a negligible reduction in [PM2.5] emissions.”).

analysis, the Agency would find a smaller benefit for particulate emissions, and possibly no benefit at all.

G. The Technical Analysis Arbitrarily Ignores Sulfur Dioxide Pollution from Power Plants. The Minnesota Pollution Control Agency’s analysis also entirely ignores the significant increase in sulfur dioxide pollution that will occur because of the increased electricity generation brought about by its proposed rule. Sulfur dioxide is, itself, harmful to individuals and the environment, but more importantly, it leads to the formation of deadly particulate matter in the atmosphere as well as welfare-damaging acid rain.186

As the Agency’s own data shows, electric utilities are the primary source of sulfur dioxide emissions in Minnesota.187 Those emissions are significant: the Midwest- Reliability-Organization-West grid, which includes Minnesota, emits sulfur dioxide at twice the average national rate.188 The region’s average emission rate is 1.4 pounds of sulfur dioxide per megawatt-hour, compared to an average national emission rate of 0.7 pounds per megawatt-hour. The Agency’s proposed zero-emissions vehicle quota will further increase sulfur dioxide emissions by increasing electricity generation in the region.

And the increased sulfur dioxide emissions will work against the Agency’s equity goals, disproportionately affecting residents of environmental justice areas. Coal plants are the primary contributor to power plant sulfur dioxide emissions and direct particulates in Minnesota.189 As of 2015, seven of the twelve coal plants tracked by the

186 Minnesota Pollution Control Agency, Sulfur Dioxide, https://www.pca.state.mn.us/air/sulfur- dioxide (Mar. 4, 2021). 187 Id. 188 EPA, Power Profiler, https://www.epa.gov/egrid/power-profiler#/MROW (Mar. 4, 2021). 189 Minnesota Pollution Control Agency, Power Plants and Environmental Justice, https://www.pca.state.mn.us/air/power-plants-and-environmental-justice (see sulfur dioxide emissions data available on “What are the emissions?” webpage) (Mar. 4, 2021).

Agency were in environmental justice areas.190

The Agency’s decision to ignore sulfur dioxide pollutants is arbitrary and paints an incomplete picture of the air quality, health, and equity effects of its proposed rule.

V. THE PROPOSED STANDARDS DO NOT BENEFIT CONSUMERS. By using overly-optimistic economic projections, ignoring effects that increase owner costs, and omitting indirect consumer costs, the Agency’s analysis masks the true consumer costs of its proposed rule: the greenhouse gas and zero-emissions vehicle standards will cost Minnesota consumers more and leave them with fewer vehicle options they want, while doing little-to-nothing to benefit the climate or Minnesota’s air quality. The proposed rule is not in the best interest of Minnesota’s consumers. It is not needed or reasonable.

For any rule with future effects, reasonable analyses must use a “discount rate”—an estimate of “how much the future costs or savings are [presently] worth to the consumer.”191 Using the federally-preferred 7% discount rate, the Agency itself estimates that its proposed rule will cost Minnesota consumers $236 million over the first ten model years.192 In reality, the costs are likely much greater, once multiple failings are corrected.

First, much of the proposed rule’s purported economic benefits arise from fuel cost savings. But the Agency estimates those savings using future gasoline prices that are far higher than current realities and updated projections, overstating the true savings to Minnesota consumers.193 Even by 2020, the projections in the U.S. Energy Information Administration’s 2019 Annual Energy Outlook used by the Agency were out of date:

190 Id. (see “coal and other fuels” power plant tally on “How many power plants are there?” webpage). 191 SONAR at 72. 192 Id. at 70; OMB, Circular A-4 33 (Sept. 17, 2003) (“As a default position . . . a real discount rate of 7 percent should be used as a base-case for regulatory analysis.”). Estimated net benefits happen only when the Agency uses a significantly lower 3% discount rate. See TSD at 50, 70. 193 TSD at 44, 52.

the predicted gasoline price for 2020 is $3.00 per gallon,194 while the actual average 2020 price in Minnesota was only $2.01 per gallon, a third less.195 The 2019 prices are also far higher than more recent projections: while the 2019 projections predicted a 2023 gasoline price of $3.07 per gallon, the most recent projection predicts a 2023 price of only $2.46 per gallon.196

The more recent gasoline price projections are, at least in the near term, closer to the “Low Oil Price” scenario the Agency evaluated in its sensitivity analysis than to the projections it used in its baseline analysis.197 Under the Low Oil Price scenario, the Agency found that the total fuel cost savings due to the carbon-dioxide standard were nearly 30% less than under its baseline scenario.198 The use of inflated estimates for future gasoline prices considerably overstates the fuel saving gains to Minnesota’s consumers.

The Agency also disregards technological realities that increase costs to drivers. As with its flawed analysis of emissions effects, the Agency ignores that cold weather reduces the efficiency of electric automobiles by roughly 40%.199 This requires electric automobiles to use more electricity and reduces the purported savings of electric automobile ownership. And by assuming constant electricity prices,200 the Agency ignores that greater demand for electricity will increase recharging costs by putting

194 U.S. Energy Info. Admin., Annual Energy Outlook 2019, Table: Petroleum and Other Liquids Price, Reference Case (2019 AEO) (price projected in 2018 dollars). 195 U.S. Energy Info. Admin., Weekly Retail Gasoline and Diesel Prices (Minnesota annual average price for 2020 is $2.012 per gallon, including taxes). 196 Compare AEO 2019, supra note 194, with U.S. Energy Info. Admin., Annual Energy Outlook 2021, Table: Table 12. Petroleum and Other Liquids Price, Reference Case (price projected in 2020 dollars). 197 TSD at 90. 198 Id. at 91, Table 56. Using standard (“Reference Scenario”) 2019 projected gasoline prices, the estimated cumulative fuel savings under the LEV standard using a 7% discount rate was $3.06 billion; using the Low Oil Price scenario projected prices, the estimated fuel savings dropped to $2.17 billion. Id. The Agency did not present a sensitivity analysis for fuel savings under the zero- emissions vehicle standard using the Low Oil Price scenario. 199 See supra note 170. 200 TSD at 55.

upward pressure on electricity prices.

The Agency also fails to consider the cost of electric-battery replacement: the analysis assumes a vehicle lifetime of 150,000 miles.201 But most batteries are only warranted for 100,000 to 120,000 miles.202 Many electric automobiles will require at least one battery replacement over their lifetime. Replacement costs vary but are estimated to be in the thousands of dollars per vehicle.203 Including the cost electric- battery replacement would reduce—or eliminate—the average per-car savings the Agency projects.204

The Agency’s economic analysis also ignores the proposed rule’s indirect costs to Minnesotans. Much of the capital cost of new infrastructure needed to support a zero- emissions vehicle standard—including funding for charging stations and electric utility upgrades—will ultimately be borne by Minnesota ratepayers. And electric automobiles have intangible costs that, though harder to quantify, represent a real loss to drivers: reduced driving ranges and longer refueling times. A complete economic analysis would account for these losses.

Finally, the analysis ignores economic studies showing that automobile manufacturers trade fuel economy gains with forgone automobile performance improvements—like acceleration or towing capacity—harming consumers who prefer

201 Id. 202 Batteries for the 2021 Nissan Leaf and Chevrolet Bolt are warranted for 8 years or 100,000 miles. Tesla warrants its batteries for 8 years or 100,000 to 150,000 miles, depending on vehicle. https://usa.nissannews.com/en-US/releases/2021-nissan-leaf-press-kit; https://media.chevrolet.com/media/us/en/chevrolet/vehicles/bolt-ev/2021.tab1.html; https://www.tesla.com/support/vehicle-warranty. 203 See Jessica Miley, Tesla Puts Price on Model 3 Battery Module Replacement Around $5000–$7000, Interesting Engineering (Apr. 15, 2019); Stef Schrader, It Costs Nearly $16,000 to Replace a Tesla Model 3 Battery Pack, TheDrive.Com (Jan. 25, 2021); Gustavo Henrique Ruffo, EV Rides Can Extend the Range of Your Nissan LEAF With Battery Upgrades, InsideEVs.com (Jun. 12, 2020). 204 MPCA estimates a net cost savings of $2,318 to $12,406 per electric automobile depending on the model year and discount rate applied. See TSD at 68–69.

these features.205

And many consumers do value these automobile performance features.206 The average willingness to pay for a single percentage increase in horsepower has been estimated at $41.207 Mandating fuel-economy increases therefore has enormous opportunity costs to consumers. For example, from 2012 to 2016, CAFE required automobile manufacturers to reduce fuel consumption by 13%. To reach this goal, automobile manufacturers failed to increase automobile horsepower much at all, and horsepower would have been an estimated 30% higher in the absence of tighter fuel economy standards. The forgone improvement in horsepower cost consumers billions in private welfare losses and largely wiped out private welfare gains from fuel savings.208 The lesson should be obvious: performance trade-offs cannot be ignored when setting fuel economy or carbon dioxide standards.

By failing to incorporate the opportunity costs of these technology trade-offs, the Agency underestimates the true cost of its proposed rule to Minnesota’s consumers. Once these errors are considered, it becomes clear that the proposed rule is neither needed nor reasonable.

VI. THE PROPOSED STANDARDS WILL HURT LOW-INCOME MINNESOTANS. The proposed rule will disproportionately benefit high-income residents, while harming low-income earners, who are over-represented in communities of color and

205 See, e.g., T. Klier and J. Linn, The effect of vehicle fuel economy standards on technology adoption, 133 J. of Pub. Econ. 41, 53 (2016) (finding that more stringent fuel economy standards “affected the direction of technology adoption by reducing light truck torque in the United States and both vehicle weight and horsepower in Europe”); K.S. Whitefoot et al., Compliance by Design: Influence of Acceleration Trade- offs on CO2 Emissions and Costs of Fuel Economy and Greenhouse Gas Regulations, 51 Environ. Sci. & Technol. 10307, 10313 (2017) (“find[ing] that automakers have an incentive to [trade-off between fuel economy and acceleration performance] and that GHG emissions and compliance costs . . . are significantly lower when these trade-offs are accounted for.”). 206 Id. 207 B. Leard et al., Have US Fuel Economy and Greenhouse Gas Emissions Standards Improved Social Welfare? Resources for the Future Working Paper 20-06 (Mar. 2020). 208 Id.

under-resourced communities.209

A recent analysis of electric automobile purchases in California—the Nation’s most developed electric car market—shows that, on average, electric automobile buyers are wealthier, better educated, and far more likely to live in detached, single-family homes than the average state resident.210 Similarly, wealthy, well-educated, suburban Minnesotans will benefit most from any increase in electric car availability brought about by the proposed rule. But all consumers, including the poorer Minnesotans, pay for this regressive cross-subsidy, in the form of higher car prices for conventional automobiles.

And not only are high-earners more likely to purchase electric automobiles, they also tend to enjoy the lion’s share of environmental gains: assessing national air pollution impacts from electric car adoption, a 2016 National Bureau of Economic Research study concluded, “[c]ensus block groups with median income greater than about $65,000 receive positive environmental benefits from electric vehicle adoption whereas block groups with income less than this threshold receive negative environmental benefits.”211

The Agency’s own data suggests the national trends will hold true in Minnesota: electric automobiles generate pollution largely through increased electricity generation, and Minnesota’s dirtiest power plants are disproportionately located in environmental justice areas, not wealthy suburbs.212 These communities will have to pay more for cars and breathe additional pollution to subsidize the cars of wealthy Minnesotans. The Agency entirely fails to consider these distributional effects.

209 Minnesota House Select Committee on Racial Justice Report to the Legislature 13 (Dec. 22, 2020) (reporting that “[t]he state of Minnesota has the second largest income inequality gap between Blacks and Whites in the United States,” where “[t]he median Black family in the Twin Cities area earns $38,178 annually, which is less than half of the median White family income of $85,459 annually”). 210 K. Canepa et al., An early look at plug-in electric vehicle adoption in disadvantaged communities in California, 78 Transp. Pol’y 19, 24–26 (2019). 211 S.P. Holland et al, Distributional Effects of Air Pollution from Electric Vehicle Adoption 4 (National Bureau of Economic Research, Working Paper 22862, Nov. 2016). 212 See supra notes 189 & 190 and accompanying text.

VII. THE PROPOSED STANDARDS VIOLATE MINNESOTA LAW. A. Minnesota’s Pollution Control Agency does not have authority to adopt the proposed carbon dioxide standards. Even if the proposed carbon dioxide standards were permitted under federal law (which they are not) and were sound policy (which they are not), the Minnesota Pollution Control Agency still could not adopt them under its existing statutory authority.

Minnesota law empowers the Pollution Control Agency to “adopt standards of air quality” for the sole purpose of “improv[ing] air quality.”213 But the Agency’s proposed greenhouse gas standards do not improve air quality—in Minnesota or anywhere else. As described in greater detail above in Parts II.A.3 and IV.A, when layered onto existing national standards, state-level limits on automobile emissions simply shift greenhouse gas generation to automobiles outside the state; they do not reduce overall national— or global—emissions. Because of predictable carbon leakage from state standards, any argument that the proposed rule’s carbon dioxide standards will improve Minnesota’s air is entirely speculative. The proposed carbon dioxide standards will have no discernible effect on Minnesota’s air quality. The Agency has no power to adopt standards with entirely speculative or non-existent air quality benefits. The proposed carbon dioxide standards are not needed or reasonable because they produce no real air quality benefits for Minnesota.

B. Minnesota’s Pollution Control Agency does not have authority to delegate power to Sacramento. The proposed rule violates non-delegation principles and Minnesota law by delegating future rulemaking authority to Sacramento. Under the proposed rule “any future amendments to the incorporated California regulations automatically become part of Minnesota rules.”214 This delegates Minnesota’s lawmaking power to unaccountable bureaucrats in Sacramento without any adequate safeguards.

The Minnesota Pollution Control Agency may not delegate its powers absent

213 Minn. Stat. § 116.07, Subd. 2(a). 214 SONAR at 41.

“adequate legislative or administrative safeguards” “to protect against the injustice that results from uncontrolled discretionary power.”215 Indeed, the Minnesota Supreme Court has long held that the state “cannot delegate purely legislative power to any other body, person, board, or commission.”216 Such purely legislative power is “the authority to make a complete law,” but does not include delegations of “discretionary power to ascertain operative facts and apply the law,” which are permissible.217 A delegation is impermissible when it “gives a private party ‘the arbitrary right to exercise an option to make a law operative on its own terms.’”218

Minnesota courts have upheld delegations of executive power over ministerial contractual terms, and discretion to waive certain restrictions on reducing teacher benefits.219 Similarly, the Minnesota Supreme Court upheld a rule that adopted standards developed by the American Bar Association for accreditation of law schools for purposes of applications for admission to the Minnesota Bar.220 Under these cases, the line between permissible and impermissible delegation is “between the delegation of power to make the law, which necessarily involves a discretion as to what it shall be, and conferring an authority or discretion as to its execution, to be exercised under and in pursuance of the law. The first cannot be done; to the latter no valid objection can be made.”221

The proposed rule crosses this line. First, the power delegated is not to a Minnesota regulatory commission or even to private participants in a self-regulating industry, but to the California regulators in Sacramento. This is a stark breach of Minnesota’s sovereignty that leaves California regulators the option to make a complete law that replaces Minnesota law. Second, under the proposed rule, California could radically

215 Hubbard Broad., Inc. v. Metro. Sports Facilities Comm’n, 381 N.W.2d 842, 847 (Minn. 1986). 216 Lee v. Delmont, 36 N.W.2d 530, 538 (1949). 217 Matter of Griepentrog, 888 N.W.2d 478, 487 (Minn. Ct. App. 2016). 218 Id. at 488 (quoting Remington Arms Co. v. G.E.M. of St. Louis, Inc., 102 N.W.2d 528, 534 (Minn. 1960)). 219 Hubbard, 381 N.W.2d at 847–48 (contractual terms); West St. Paul Fed'n of Teachers v. Indep. Sch. Dist. No. 197, 713 N.W.2d 366, 376–77 (Minn. App. 2006) (benefits). 220 In re Hansen, 275 N.W.2d 790, 796-97 (Minn. 1978). 221 Remington, 102 N.W.2d at 534.

amend the referenced provisions of the regulatory code containing the current zero- emission vehicles standards, replacing them with, for example, “a requirement that that 100 percent of in-state sales of new passenger cars and trucks will be zero-emission by 2035.”222

The Agency argues that this likely will not happen. “Historically,” it argues, “California has made minor housekeeping updates to its rules every few years. However, when California has conducted a major update to the rules, such as making them more stringent for future model years, California has done so in new rule parts. Because California uses new rule parts, these major updates would not be adopted automatically into Minnesota’s rules.”223 In other words, the Agency merely hopes California will not make “major updates” to the regulations Minnesota proposes to incorporate as amended.

But past is not always prologue. Sweeping amendments may be incorporated into the current code provision, past codification practices notwithstanding. The Agency offers no good reason for why it can rely on California to not make “major” updates to the existing regulations. The proposed rule in any event gives California regulators unfettered authority to “exercise an option” to make a law that will operate on its own terms within Minnesota, precisely what the non-delegation cases prohibit.224 There is no need to prove that California will exercise that option. It is enough that the option to make law is being handed to them by the Agency. Moreover, Minnesota cannot delegate away its legislative authority even over so-called “housekeeping” matters if those housekeeping matters fall within the “purely legislative” authority of another state.225

The Agency’s proposed rule thus appears to delegate legislative rulemaking authority to California, in violation of Minnesota’s Constitution. Relatedly, the proposed “as amended” provision also violates Minnesota’s Administrative Procedure Act, as it

222 Executive Order N-79-20. 223 SONAR at 41. 224 Remington Arms, 102 N.W.2d at 534 (emphasis added). 225 Lee, 36 N.W.2d at 538.

allows the Agency to circumvent the regulatory process for amending rules.

The proposed rule, in short, requires Minnesotans who want their voice to be heard to participate in far-flung rulemaking proceedings in Sacramento, controlled by regulators and politicians who are not accountable for nor responsible to their needs. A more blatant and obnoxious abnegation of Minnesota’s sovereignty is hard to imagine. Such a transfer of sovereignty is neither needed nor reasonable.

CONCLUSION The proposed carbon dioxide standards and zero-emissions vehicle standards are not needed or reasonable.