CCM Notice Comments 3

March 7th, 2021 Derek Kelley Attachment Jessica A. Palmer-Denig Administrative Law Judge Minnesota Pollution Control Agency PO Box 64620 St. Paul MN, 55164-0620 Regarding Minnesota Pollution Control Agency’s Proposed Rules Adopting Vehicle Greenhouse Gas Emissions Standards - Clean Cars Minnesota. Proposed Revisions of Minnesota Rule Chapter 7023, Clean Cars Minnesota, Revisor ID No. 04626 From Derek Kelley, Thank you so much for the opportunity to publicly comment and express my feelings of satisfaction and concern on this rule. My name is Derek Kelley, and I am an undergrad student at the University of Minnesota, studying applied economics. Although I am young, I believe I bring an interesting perspective to the proposed revisions to Chapter 7023. The proposed changes to Chapter 7023 excite me because I believe they put Minnesota in a more progressive position when it comes to lowering our emissions. Minnesota would be taking a step to helping lower our emissions as a state. Currently transportation makes up the largest portion of our net greenhouse gas emissions (GHG), and this policy would help us to shrink that portion. After reading the proposed rule as well as portions of the Technical Support Document and Statement of Need and Reasonableness: Clean Car Minnesota, I have come to the conclusion that the proposed changes would improve Minnesota generally. Although I like the modifications, I also have some concerns over some of the changes to Chapter 7023 and how they would affect residents of Minnesota. I am strongly in favor of the proposed plan to increase the required number of low emission vehicles (LEV) and zero emission vehicles (ZEV) cars sold in Minnesota. It’s clear that the demand for cars has not changed drastically through recent history. Data on the California Energy Commission website shows that the number of cars in California has increased from 22,285,362 in 2010 to 28,462,885 in 2019. Through that increase of vehicles, the number of electric vehicles (EV) has gone up from 768 vehicles to 566,902 vehicles. This dramatic growth in EV’s has caused the percent of gas vehicles to drop by a little more than six percent. Adopting California’s regulations could help us to see a similar change, the number of cars will continue to go up, but giving consumers more electric vehicles and LEV’s as options will help Minnesota cut back on emissions. aq-rule4-10z3 I strongly support the proposed plan to increase the restrictions on vehicle emissions. As it stands, by your own data on the Statement of Need and Reasonableness, nearly a quarter of Minnesota’s emissions are from the transportation sector. If you break that category down even more, over half (52%) of the GHG emissions from surface transportation are from light duty automobiles and light duty trucks. California's gradual plan to decrease the amount of GHG emissions on a yearly basis is good for manufacturers. As stated in title 13 Section 1961.2 of the California Code of Regulations, car manufacturers are given around eight years to completely phase out some of their technology. California has also had their net carbon emissions from transportation drop by nearly 15 million tons since the early 2000’s. The California Air and Resource board has shown that 2002 levels were around 185 million tons of CO2, but by 2018 their levels of emissions from transportation were down to 170 million tons. This change has a relatively low cost on producers and consumers, because many companies are already designing cars to fit the bill for California, New York and other section 177 states. Cars are already being designed for those high population states, the supply of cars to Minnesota won’t change drastically. Many cars we are already purchasing are designed to fit California standards, therefore following California’s policies would not randomly cause those car’s prices to jump. In joining the section 177 states, Minnesota would be getting earlier access to these cars, and would be getting some cars we currently do have access to. Many who oppose the changes in Rule 7023 cite increased cost as the main reason why they are against the change. A recent study by the EPA found that every $1 spent on reducing emissions from “mobile sources” results in $9 of benefits towards “public health, the environment, productivity and consumer savings.” Despite the fact that the purchase price of new vehicles is projected to increase, other economic benefits for society as a whole that are harder to put a price on will also be increasing. One such benefit could be the prolonged life expectancy of humans, as pollution goes down. Another example of a benefit that is hard to put a price on is the impact that the reduction of greenhouse emissions would have on reducing and reversing the impacts of climate change. One concern I have after reading the proposed rule changes to chapter 7023, is how automobile demand and supply will interact with each other. If consumer demand for electric vehicles or zero emission vehicles stays the same through this next period under the rule change, the impact of the rule change will be underwhelming. A key part to making an impactful change in our emissions is having more electric cars on the road. Although LEVs do lower our output of emissions, they aren’t as impactful as electric vehicles. One thing I believe is missing from the proposed rule, is how you plan to increase the sales of electric vehicles. A study from University of California Davis, found that several key concepts needed to be met for most consumers to consider purchasing an electric vehicle as their next car. Overall, consumers that were more likely to purchase electric vehicles displayed a knowledge of how electric cars work, as well as an understanding of the difference gasoline has on human and environmental health compared to electric vehicles. “Prior knowledge of the availability of incentives” (UC Davis pg. 127), another big selling point is the knowledge of incentives that are offered to electric vehicle owners. I am aware that the government offers up to $7,500 on a tax credit for EV’s, but I am not sure if the rest of the population is aware of this. Too many people shopping for cars would purchase a car today only looking at the ticket price and be unaware of the tax credit. There needs to be a change to the public's perception on that. One of my big concerns given the above information, is how do you as the MPCA plan to raise awareness? The UC Davis study showed the importance that consumer awareness had in buying electric vehicles. If we are to adopt the California regulations, we need to make sure the increased supply of electric vehicles is met by an increased understanding of those vehicles and an increased demand. Another concern I have with the adoption of California’s emission reduction rules is that Minnesota is not California. As obvious as that statement is, I believe it holds some weight when adopting a policy designed by California's Pollution Control Agency. Minnesotans may have different vehicle requirements when it comes to the tasks we want to get done. I think it is risky to impose a strict following of California’s rules when we are bound to what they do. We lose control of how as a state we can react to the policy. I believe that we will need to re-evaluate after each update to California's plan. After every couple years when California assesses their emissions plan and decides to reduce emissions by more or less, I think Minnesota will need to check to make sure that California’s plan still works for us and is fitting with the states vision. Despite seeing the MPCA’s reassuring message in the Statement of Need and Reasonableness discussing other cold weather states, and their success with the increased electric vehicles, I still have some concern over whether Minnesota is ready. A 2019 study conducted by AAA on electric vehicles in a controlled environment found some interesting data on how those cars react to different temperatures. AAA found that when a Tesla ran at an ideal temperature of 75 degrees Fahrenheit, the range was 239 miles, but when the temperature was decreased to 20 degrees, the cars range was dropped by 91 miles. Driving over 100 miles a day might not be a common occurrence for everyone, but I believe the state needs to be prepared for such events. I believe that more strategic planning and design needs to go into deciding where these chargers go, and more investment in public charging stations. My final statements on the proposed rule changes to Chapter 7023 are as follows. After reading the MPCA’s analysis of the situation, I am in favor of adopting California’s regulations on car emissions. California’s policy has proven to help cut back on emissions and create cleaner cars that still meet consumers demands. I believe that there are still some question marks left in the proposal though. I think it is important that before the state mandates EV sales there is research into if Minnesotans have a high demand for these vehicles. The department of transportation also needs to make it a priority to inform the public of tax write offs or rebates to those who purchase electric cars. Sincerely, Derek Kelley Works Cited California Energy Commission (2021). California Energy Commission Zero Emission Vehicle and infrastructure Statistics. Date last updated August 28, 2020. Date accessed February 10, 2020.

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