Nels Paulsen Attachment March 12, 2021 RE: OAH Docket No. 71-9003-36416 Honorable Judge Jessica Palmer-Denig, Conservation Minnesota is a statewide conservation organization working to protect the Minnesota we all love for future generations. In our conversations with members from all parts of the state, we find that Minnesotans are looking for common-ground solutions to address our most pressing conservation issues including the impacts of a changing climate and protecting the quality of our air in all communities. We are commenting in support of the proposed clean car rules. Minnesota is defined by our four seasons and our great outdoors. It’s our job to ensure we’re protecting the quality of our air and water, while taking the necessary steps to reduce greenhouse gas emissions and stave off the worst impacts of climate change. Our changing climate is already having a noticeable impact on our seasons—Minnesota anglers enjoy fewer days out on frozen lakes, researchers believe Minnesota’s moose populations are dropping in part due to the impacts of warmer temperatures, and foresters question the longevity of our northern boreal forests. Minnesota’s transportation sector is now the number one source of climate pollution in our state and our greatest opportunity to reduce carbon emissions. In 2007, the bipartisan Next Generation Energy Act (NGEA) was signed into law by Republican Governor Tim Pawlenty. The NGEA had a goal to reduce 80 percent of our emissions by 2050. We missed our 2015 milestone goal and aren’t on track to meet future goals. MPCA reports show adopting the proposed clean cars rule would reduce greenhouse gas emissions by 1.4 million tons over the first 10 years.1 This reduction would provide an important piece in helping us reach future goals outlined by the NGEA. Furthermore, our national vehicle emissions have started to trend in the wrong direction and must be corrected. Recently, and for the first time in five years, emissions from new vehicles went up. It’s astonishing to see 2019 vehicles were less fuel efficient than the year before. We simply cannot continue to go in the wrong direction. We’re running out of time to correct our course. Fortunately, vehicle manufactures are begging to build the electric trucks and SUVs well suited for the Minnesota lifestyle. Automakers—including Ford and GM—have announced plans for 20 electric trucks, SUVs, and crossover vehicles in the next 5 years. If we don’t adopt clean car standards, many of these models won’t get to the Minnesota market. We know there is a competitive market for electric vehicles, especially electric trucks. As an example, reservations for the all-electric 2022 GMC Hummer EV were sold out in 10 minutes. 1 MPCA SONAR, page 77: https://www.pca.state.mn.us/sites/default/files/aq-rule4-10m.pdf pg 1 of 2 aq-rule4-10z9 1101 West River Parkway, Suite 250 / Minneapolis, MN 55415 / 612.767.2444 / conservationminnesota.org Clean car standards are also advantageous for our Minnesota businesses because they will cut transportation costs and complement economic development activities powering the state’s clean energy transformation. Coming out of the economic downturn caused by the COVID-19 crisis, the clean energy industry—including EV charging infrastructure—will play a key role in our recovery by creating new, well-paying jobs across the state. One assessment from Recharge Minnesota showed every EV in a community delivers, on average, over $1,000 per year in local economic development benefit. Electric vehicles have attracted the attention of some of Minnesota’s most prominent businesses and employers, including Target, 3M, and Best Buy, which are all looking to transition their fleets. If more vehicle choices are made possible by the proposed clean car standards, businesses will be able to reduce their carbon footprint, save money on transportation costs, and help power local economic development by creating construction and installation jobs over the short and long term. Ultimately, the transition to electric vehicles will help eliminate costly energy waste, and that why Minnesota companies are investing in an electric vehicle future. On behalf of Conservation Minnesota, I encourage you to approve the proposed clean car standards. Sincerely, Nels Paulsen Policy Director pg 2 of 2 1101 West River Parkway, Suite 250 / Minneapolis, MN 55415 / 612.767.2444 / conservationminnesota.org Nels Paulsen Attachment 2 March 12, 2021 RE: OAH Docket No. 71-9003-36416 Honorable Judge Jessica Palmer-Denig, Conservation Minnesota is a statewide conservation organization working to protect the Minnesota we all love for future generations. In our conversations with members from all parts of the state, we find that Minnesotans are looking for common-ground solutions to address our most pressing conservation issues including the impacts of a changing climate and protecting the quality of our air in all communities. We are commenting in support of the proposed clean car rules. Minnesota is defined by our four seasons and our great outdoors. It’s our job to ensure we’re protecting the quality of our air and water, while taking the necessary steps to reduce greenhouse gas emissions and stave off the worst impacts of climate change. Our changing climate is already having a noticeable impact on our seasons—Minnesota anglers enjoy fewer days out on frozen lakes, researchers believe Minnesota’s moose populations are dropping in part due to the impacts of warmer temperatures, and foresters question the longevity of our northern boreal forests. Minnesota’s transportation sector is now the number one source of climate pollution in our state and our greatest opportunity to reduce carbon emissions. In 2007, the bipartisan Next Generation Energy Act (NGEA) was signed into law by Republican Governor Tim Pawlenty. The NGEA had a goal to reduce 80 percent of our emissions by 2050. We missed our 2015 milestone goal and aren’t on track to meet future goals. MPCA reports show adopting the proposed clean cars rule would reduce greenhouse gas emissions by 1.4 million tons over the first 10 years.1 This reduction would provide an important piece in helping us reach future goals outlined by the NGEA. Furthermore, our national vehicle emissions have started to trend in the wrong direction and must be corrected. Recently, and for the first time in five years, emissions from new vehicles went up. It’s astonishing to see 2019 vehicles were less fuel efficient than the year before. We simply cannot continue to go in the wrong direction. We’re running out of time to correct our course. Fortunately, vehicle manufactures are begging to build the electric trucks and SUVs well suited for the Minnesota lifestyle. Automakers—including Ford and GM—have announced plans for 20 electric trucks, SUVs, and crossover vehicles in the next 5 years. If we don’t adopt clean car standards, many of these models won’t get to the Minnesota market. We know there is a competitive market for electric vehicles, especially electric trucks. As an example, reservations for the all-electric 2022 GMC Hummer EV were sold out in 10 minutes. 1 MPCA SONAR, page 77: https://www.pca.state.mn.us/sites/default/files/aq-rule4-10m.pdf pg 1 of 2 1101 West River Parkway, Suite 250 / Minneapolis, MN 55415 / 612.767.2444 / conservationminnesota.org Clean car standards are also advantageous for our Minnesota businesses because they will cut transportation costs and complement economic development activities powering the state’s clean energy transformation. Coming out of the economic downturn caused by the COVID-19 crisis, the clean energy industry—including EV charging infrastructure—will play a key role in our recovery by creating new, well-paying jobs across the state. One assessment from Recharge Minnesota showed every EV in a community delivers, on average, over $1,000 per year in local economic development benefit. Electric vehicles have attracted the attention of some of Minnesota’s most prominent businesses and employers, including Target, 3M, and Best Buy, which are all looking to transition their fleets. If more vehicle choices are made possible by the proposed clean car standards, businesses will be able to reduce their carbon footprint, save money on transportation costs, and help power local economic development by creating construction and installation jobs over the short and long term. Ultimately, the transition to electric vehicles will help eliminate costly energy waste, and that why Minnesota companies are investing in an electric vehicle future. On behalf of Conservation Minnesota, I encourage you to approve the proposed clean car standards. Sincerely, Nels Paulsen Policy Director pg 2 of 2 1101 West River Parkway, Suite 250 / Minneapolis, MN 55415 / 612.767.2444 / conservationminnesota.org March 15, 2021 NESCAUM Admin Attachment Submitted Via E-Comments Portal Honorable Jessica Palmer-Denig Administrative Law Judge Office of Administrative Hearings St. Paul, Minnesota E-comments portal: https://minnesotaoah.granicusideas.com/discussions Re: Clean Cars Minnesota Rulemaking, OAH Docket No. 71-9003-36416 Dear Judge Palmer-Denig: On behalf of the Northeast States for Coordinated Air Use Management (NESCAUM), I am writing to offer support as Minnesota considers adopting California’s Low-Emission Vehicle (LEV) and Zero Emission Vehicle (ZEV) standards pursuant to Section 177 of the Clean Air Act as part of the Clean Cars Minnesota rulemaking. NESCAUM is the nonprofit association of state air quality agencies in Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, and Vermont. Our organization has a long history of working directly with states on adopting and implementing California’s LEV and ZEV standards. This unique role started three decades ago when NESCAUM first began evaluating the benefits of using the authority under Section 177 of the Clean Air Act to adopt California’s motor vehicle emission standards in the Northeast.