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. From https://www.energy.ca.gov/zevstats CARB. “California Green House Gas Emissions for 2008 to 2018.” California Air Resources Board. https://ww3.arb.ca.gov/cc/inventory/pubs/reports/2000_2018/ghg_inventory_trends_00- 18.pdf Clean Cars Minnesota - Appendix 1: Technical Support Document. Minnesota Pollution Control Agency. Accessed February 12, 2021. https://www.pca.state.mn.us/sites/default/files/aq-rule4-10v.pdf Exhaust Emission Standards and Test Procedures – 2015 and Subsequent Model Passenger Cars, Light-Duty Trucks, and Medium-Duty Vehicles. 13 CCR § 1961.2. 2021. George Milev, Astley Hastings, Amin Al-Habaibeh, The environmental and financial implications of expanding the use of electric cars - A Case study of Scotland, Energy and Built Environment, Volume 2, Issue 2, 2021, Pages 204-213, ISSN 2666-1233, https://doi.org/10.1016/j.enbenv.2020.07.005. (https://www.sciencedirect.com/science/article/pii/S2666123320300799) Kraker, D. (2020, February 20). Rural lawmakers push back against 'clean cars' proposal. Retrieved February 12, 2021, from https://www.mprnews.org/story/2020/02/20/rural- lawmakers-push-back-against-clean-cars-proposal Krisher, T. (2019, February 07). AAA: Cold weather can cut electric car range over 40 percent. Retrieved February 12, 2021, from https://apnews.com/article/04029bd1e0a94cd59ff9540a398c12d1#:~:text=DETROIT%20( AP)%20%E2%80%94%20Cold%20temperatures,as%20much%20as%20the%20cold. Kurani, K., Caperello, N., & TyreeHageman, J. (2020, December 24). New car Buyers' valuation of Zero-emission Vehicles: California. Retrieved February 12, 2021, from https://escholarship.org/uc/item/28v320rq Lashof, D., & Saha, D. (2020, October 08). California shows how the U.S. can reduce transport emissions. Retrieved February 12, 2021, from https://www.wri.org/blog/2020/09/california-shows-how-us-can-reduce-transport- emissions Proposed Permanent Rules relating to Clean Cars. Minnesota Pollution Control Agency. MPCA. Chapter 7023 Section 0150 and 0300. 03/02/20. Accessed February 12, 2021. https://www.pca.state.mn.us/sites/default/files/aq-rule4-10n.pdf Statement of Need and Reasonableness Minnesota Pollution Control Agency. Revisor ID No. 04626. December 2020. Accessed February 12, 2021. https://www.pca.state.mn.us/sites/default/files/aq-rule4-10m.pdf United States Environmental Protection Agency. History of reducing air pollution from transportation in the United States. (2020, November 04). Retrieved February 12, 2021, from https://www.epa.gov/transportation-air-pollution-and-climate- change/accomplishments-and-success-air-pollution-transportation
Doug Seaton Attachment 1
February 22, 2021
Via E-filing
The Honorable Judge Jessica Palmer-Denig Office of Administrative Hearings 600 North Robert Street P.O. Box 64620 Saint Paul, MN 55164-0620
Re: In the Matter of Proposed Rules Adopting Vehicle Greenhouse Gas Emissions Standards- Clean Cars Minnesota, Minnesota Rules, chapter 7023; Revisor’s ID Number 04626 OAH Docket No. 71-9003-36416
Dear Judge Palmer-Denig:
I represent, along with my colleague Attorney James Dickey, also of the Upper Midwest Law Center (“UMLC”), the Center of the American Experiment (“CAE”), which wishes to offer comments on the proposed Clean Cars Minnesota rules at issue in this proceeding.
CAE’s additional comments on the economic impact and the environmental report, prepared by Isaac Orr of CAE, will be submitted under separate cover by UMLC, on CAE’s behalf, at a later date. Mr. Orr’s comments relate to the damage that the proposed rules will do to Minnesota and Minnesotans, and they also relate to the MPCA’s failure to properly weigh the impact of the proposed Clean Cars Minnesota rules on the establishment, maintenance, operation and expansion of business, commerce, trade, industry, and other economic factors which affect the proposed rule’s feasibility and practicability. See Minn. Stat. § 116.07, Subd. 6.
In addition, I offer as comment and testimony for your consideration in this proceeding the following analysis related to the legality of the proposed Clean Cars Minnesota rules. In short, and as detailed further below, the proposed rules are invalid under state and federal law, are thus both unreasonable and unlawful, and should not be approved. See Minn. Stat. §§ 14.05, Subd. 1; Minn. Stat. § 14.45; Minn. Stat. § 14.15, Subd. 4; Minn. Stat. § 14.50.
I. The Proposed Clean Car Rules Violate Federal Law.
The proposed Clean Cars Minnesota rules are preempted by federal law because they seek to “adopt or attempt to enforce” rules contrary to the federal Clean Air Act and Energy Policy and Conservation Act.
8421 Wayzata Boulevard Suite 105 Golden Valley, MN 55426 612-428-7000 Fax 763-710-7429 UMWLC.org Shockingly, the MPCA recently admitted in a legal brief to the federal District of Minnesota that the federal Clean Air Act will not allow the enforcement of this proposed rule upon its adoption, even if it is adopted. Exhibit 1, p. 11. (“With full knowledge that while SAFE Part I persists, California does not have a waiver, the MPCA’s proposed rule (which the ALJ is yet to consider and the agency is yet to adopt) provides that it will not be effective unless authority is restored.”); see also Proposed Rule pp. 1:17-1:22, available at https://www.pca.state.mn.us/sites/default/files/ aq-rule4-10n.pdf. MPCA thus admits that the rule is preempted under federal law.
At the same time, the text of the proposed rule and the SONAR contradict the MPCA’s admission because it attempts to start offering “early action credits” as an “enforcement mechanism” that kick in within 5 days after the proposed rule’s publication and which will pressure auto dealers to participate despite the illegality of the proposed rule. Proposed Rule, pp. 8:22-9:18; Statement of Need and Reasonableness (“SONAR”), Clean Cars Minnesota Rule, Dec. 14, 2020, p. 35 (“The proposed early action credit mechanism and one-time credit allotment are not emission standards, but rather enforcement mechanisms intended to ensure that the ZEV standard is effective in Minnesota.”). When apparently realizing that creating “enforcement mechanisms” as part of a proposed rule undoubtedly triggers the EPA’s preemption clause discussed below, the MPCA tried to misrepresent the early-action credit in federal court by stating, in direct contradiction of the SONAR, that “[the early action credit mechanism] is neither compulsory nor an enforcement mechanism.” Ex. 1, p. 13. The MPCA’s misrepresentation to the federal court notwithstanding, what MPCA said in the SONAR is true—the early action credit mechanism is an enforcement mechanism.
MPCA’s admissions alone are reason enough to reject the proposed rules—they are a legal nullity at best and unavoidably preempted by federal law.
Under the Supremacy Clause, federal law is supreme where Congress has jurisdiction. U.S. Const. art. VI; M'Culloch v. Maryland, 17 U.S. 316 (1819). In a similar context, the Minnesota Supreme Court has recognized that rules passed pursuant to the authority allegedly derived from Minn. Stat. § 116.07 are subject to preemption where the MPCA has sought to regulate noise pollution. State by Minnesota Pub. Lobby v. Metro. Airports Comm'n, 520 N.W.2d 388, 390 (Minn. 1994). In Metro Airports, the Supreme Court noted that, related to air travel and noise, “[f]ederal control is intensive and exclusive. Planes do not wander about in the sky like vagrant clouds. They move only by federal permission, subject to federal inspection, in the hands of federally certified personnel and under an intricate system of federal commands.” Id.
Likewise, the federal government’s regulation of motor vehicle emissions and sales is “intensive and exclusive.” The federal government heavily regulates what vehicles can emit and what cars may be sold in the United States. See, e.g., 42 U.S.C. § 7543(a); 49 U.S.C. § 32919; 84 Fed. Reg. 51313.
Under the federal Clean Air Act, “[n]o State or any political subdivision thereof shall adopt or attempt to enforce any standard relating to the control of emissions from new motor vehicles or new motor vehicles.” 42 U.S.C. § 7543(a) (emphasis added). Under the federal Energy Policy and Conservation Act, “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.” 49 U.S.C. § 32919 (emphasis added). Absent an exception, therefore, Minnesota cannot “adopt or attempt to enforce” any law or regulation contrary to the CAA or the EPCA.
8421 Wayzata Boulevard Suite 105 Golden Valley, MN 55426 612-428-7000 Fax 763-710-7429 UMWLC.org The only exception to the CAA’s preemption of state law in existence was the waiver that was granted to California under 42 U.S.C. § 7543(b)(1). If the California waiver is in place, then other states may adopt standards identical to California’s, assuming they follow their own state law requirements, as discussed below. 42 U.S.C. § 7507. However, in 2019, the federal government revoked California’s waiver. 84 Fed. Reg. 51310 (Sept. 27, 2019). Thus, the CAA preempts any state attempt to adopt ZEV or LEV mandates like those MPCA is attempting to adopt.
In addition, on the same day that the EPA revoked California’s waiver under the CAA, the National Highway Traffic Safety Administration issued a rule stating that attempts to reduce carbon dioxide emissions are related to fuel economy. 84 Fed. Reg. 51310, 51313. The NHTSA stated:
A State or local requirement limiting tailpipe carbon dioxide emissions from automobiles has the direct and substantial effect of regulating fuel consumption and, thus, is ‘‘related to’’ fuel economy standards. Likewise, since carbon dioxide emissions constitute the overwhelming majority of tailpipe carbon emissions, a State regulation of all tailpipe greenhouse gas emissions from automobiles or prohibiting all tailpipe emissions is also ‘‘related to’’ fuel economy standards and preempted by EPCA.
While the MPCA may consider air pollution a major problem that should be remedied, Your Honor should consider the restraint exercised by Justice Page in the Metro Airports case cited above:
We do not doubt the aircraft noise generated by MSP is a serious and unpleasant problem which interferes with the enjoyment of life and property for people living in areas affected by that noise. The problem, though, cannot be remedied with means Congress preempted.
Metro Airports, 520 N.W.2d at 393.
Here, the MPCA is clearly “attempting to adopt” a rule within the purview of the CAA and EPCA. Even worse, the rule has “enforcement mechanisms” that “enforce” the rule. Under the CAA and EPCA, as a matter of law, the MPCA’s rulemaking is federally preempted and therefore illegal. The ALJ should not allow the adoption of a regulation that violates federal law.
II. The Proposed Clean Car Rules Are Not Supported by a Sufficient Grant of State Statutory Authority.
“An agency has the power to issue binding administrative rules only if, and to the extent, the legislature has authorized it to do so.” Hirsch v. Bartley-Lindsay Co., 537 N.W.2d 480, 485 (Minn. 1995); Minn. Stat. § 14.05.
The MPCA relies only on Minnesota Statutes § 116.07 for its authority to force auto dealers to sell certain vehicles and otherwise regulate what cars auto dealers may sell in Minnesota. SONAR, Clean Cars Minnesota Rule, Dec. 14, 2020, pp. 12 (LEV and ZEV standards require new cars to produce increasingly lower emissions, and a certain number of electric vehicles must be sold in Minnesota), 34-36 (discussing Minn. Stat. § 116.07). Minn. Stat. § 116.07 allows MPCA to “adopt, amend and rescind rules and standards having the force of law relating to any purpose within the provisions of Laws 1967, chapter 882, for the prevention, abatement, or control of air pollution.” Minn. Stat. § 116.07, Subd. 4(a). More specifically, the statute allows MPCA to “adopt standards
8421 Wayzata Boulevard Suite 105 Golden Valley, MN 55426 612-428-7000 Fax 763-710-7429 UMWLC.org of air quality, including maximum allowable standards of emission of air contaminants from motor vehicles.” Id. Subd. 2(a).
Neither of these grants of authority allows, either expressly or by implication, the MPCA to regulate what new motor vehicles may be sold in Minnesota. The MPCA is engaging in full-scale bootstrapping—trying to manufacture specific legislative authority from a statute that does not grant it. Without an express grant of regulatory authority, the MPCA has no power to impose a rule or standard on car sales. See State, By Spannaus v. Lloyd A. Fry Roofing Co., 246 N.W.2d 696, 699-700 (Minn. 1976). And, legislative authority is strictly limited to the subject matter delegated by the Legislature. See Lee v. Delmont, 36 N.W.2d 530, 539 (Minn. 1949).
Lloyd A. Fry is important here. In that case, the Minnesota Supreme Court held that even though Section 116 related to air pollution allowed certain regulatory actions, it did not specifically allow MPCA to issue “orders” or “a regulation authorizing an order” requiring private companies to conduct emissions tests. 246 N.W.2d at 700. Chapter 116 did not allow the issuance of orders because that power was not in the “explicit language” of Section 116. Id. at 699. Consequently, the MPCA’s orders to the Lloyd A. Fry Roofing Co. were invalid.
This matter is similar to Lloyd A. Fry because here, the MPCA is not imposing “maximum allowable standards of emission of air contaminants from motor vehicles,” but rather is requiring car dealers to sell certain types of vehicles and certain amounts of those vehicles consistent with California’s now-federally-revoked standards. SONAR, Dec. 14, 2020, pp. 11-14. Regulating emissions and requiring the sale of certain vehicles are not the same thing, and “any implied discretion or power granted [a regulatory agency] is necessarily limited by the purpose and scope of the statute as a whole.” Minn. Op. Att’y Gen. 1030-A (1978).
The MPCA’s attempt to use vaguely related language from section 116.07 is starkly different from the specific grant of authority from Congress to the EPA. In 42 U.S.C. § 7521(a), Congress directed the EPA to “prescribe . . . in accordance with the provisions of this section, standards applicable to the emission of any air pollutant from any class or classes of new motor vehicles or new motor vehicle engines . . . .” Congress gave EPA a clear directive to regulate new motor vehicles, and the Minnesota Legislature did not give MPCA a similar grant of authority, nor could it have lawfully done so in defiance of the preemptive federal CAA and EPCA.
MPCA must be aware of the need for more specific legislative authority. The MPCA has, previously, regulated tailpipe emissions by requiring inspections from 1991-1999 to achieve proper ambient air quality consistent with EPA requirements, but only because of a much more detailed grant of statutory authority. Air Quality in Minnesota: Problems and Approaches, Appendix A Draft § 1.2, available at https://www.leg.mn.gov/docs/pre2003 /mandated/010077.pdf. In 1988, the Legislature passed, and the Governor signed, Minn. Stat. § 116.62, which provided specific authority for an inspection program. Laws 1988, Chapter 661, S.F. No. 1783. Notably, the MPCA did not attempt to rely on Minn. Stat. § 116.07 in creating that program—it only mentioned section 116.07 as related to the general considerations the agency must weigh in determining a proposed rule’s need and reasonableness. SONAR, In the matter of the Proposed Motor Vehicle Inspection/Maintenance Rules 7005.5010 to 7005.5105, Apr. 19, 1989, available at https://www.leg.mn.gov/archive/sonar/SONAR-01466.pdf. If Section 116.07 wasn’t enough to create an actual testing program directly related to air emissions from motor vehicles, it is even less sufficient now to regulate the sale of cars in Minnesota.
8421 Wayzata Boulevard Suite 105 Golden Valley, MN 55426 612-428-7000 Fax 763-710-7429 UMWLC.org “It is the nature of the power . . . which determines the validity of its delegation.” Lee, 36 N.W.2d at 539. Here, the nature of the power the MPCA seeks to exercise is not contained in Minn. Stat. §116.07. Consequently, there is no legislative grant of authority that would allow the MPCA to issue its proposed rules related to the sale of vehicles in the state.
The UMLC and CAE thus respectfully request that the ALJ find that the proposed rules are invalid under state and federal law, are thus unreasonable and unlawful, and should not be approved. See Minn. Stat. §§ 14.05, Subd. 1; Minn. Stat. § 14.45; Minn. Stat. § 14.15, Subd. 4; Minn. Stat. § 14.50.
III. The ALJ Must Consider Both the Environmental and Economic Impact of the Proposed Rule in Rendering a Decision.
Finally, if the ALJ still believes that this Court has the legal authority to allow the adoption of MPCA’s proposed rule, we respectfully submit that the ALJ should consider the forthcoming comments of CAE and Isaac Orr as part of its duty to “consider both the economic impact and the environmental impact in rendering decisions dealing with environmental matters.” Reserve Min. Co. v. Herbst, 256 N.W.2d 808, 841 (Minn. 1977) (citing Minn. Stat. § 116.07). Upon consideration of these comments, we respectfully submit that the ALJ should reject the proposed rule as economically detrimental and without significant environmental benefit to Minnesota, even if not deemed unlawful.
* * * *
In addition to the foregoing analysis and the forthcoming comments of Mr. Orr, UMLC reserves the right, on CAE’s behalf, to submit further comments and replies to the comments of other parties through the close of the hearing record and rebuttal period, and to proceed with any applicable appeals.
Respectfully,
Douglas Seaton, Esq., President of UMLC Attorney for Center of the American Experiment
cc: James V.F. Dickey, Esq. (UMLC) Isaac Orr (CAE)
8421 Wayzata Boulevard Suite 105 Golden Valley, MN 55426 612-428-7000 Fax 763-710-7429 UMWLC.org Doug Seaton Attachment 2
March 15, 2021
Via E-filing
The Honorable Judge Jessica Palmer-Denig Office of Administrative Hearings 600 North Robert Street P.O. Box 64620 Saint Paul, MN 55164-0620
Re: In the Matter of Proposed Rules Adopting Vehicle Greenhouse Gas Emissions Standards- Clean Cars Minnesota, Minnesota Rules, chapter 7023; Revisor’s ID Number 04626 OAH Docket No. 71-9003-36416
Dear Judge Palmer-Denig:
Center of the American Experiment (CAE) opposes the adoption of the proposed “Clean Cars Minnesota” rules because they are illegal and bad for Minnesotans. CAE, through its attorneys at the Upper Midwest Law Center, attaches here CAE’s full initial comments, along with an additional letter brief from the UMLC, which show that the proposed rules should be disapproved. CAE therefore urges the Administrative Law Judge to do exactly that.
Respectfully,
Douglas Seaton, Esq., President of UMLC Attorney for Center of the American Experiment
Attachments cc: James V.F. Dickey, Esq. (UMLC) John Hinderaker (CAE) Isaac Orr (CAE)
8421 Wayzata Boulevard Suite 105 Golden Valley, MN 55426 612-428-7000 Fax 763-710-7429 UMWLC.org Doug Seaton Attachment 3
March 15, 2021
Via E-filing
The Honorable Judge Jessica Palmer-Denig Office of Administrative Hearings 600 North Robert Street P.O. Box 64620 Saint Paul, MN 55164-0620
Re: In the Matter of Proposed Rules Adopting Vehicle Greenhouse Gas Emissions Standards- Clean Cars Minnesota, Minnesota Rules, chapter 7023; Revisor’s ID Number 04626 OAH Docket No. 71-9003-36416
Dear Judge Palmer-Denig:
I represent, along with my colleague Attorney James Dickey, also of the Upper Midwest Law Center (“UMLC”), the Center of the American Experiment (“CAE”), which wishes to offer additional comments in opposition to the proposed Clean Cars Minnesota rules at issue in this proceeding.
The enclosed comments on the substance of the rules are in addition to the prior comments on applicable law submitted to Your Honor through the OAH’s e-comments website under my username (“Doug Seaton”) on February 22, 2021, and also in addition to the comments and legal analysis I provided orally during the public hearing on February 22, 2021.
CAE’s additional comments attached here focus on the economic and environmental impact of MPCA’s proposed rules. They are authored by Isaac Orr of CAE. Mr. Orr’s comments demonstrate that the proposed rules are not needed nor reasonable, and are not rationally related to the MPCA’s objective. Minn. Stat. 14.15, Subd. 4; Minn. R. 1400.2240, Subp. 6; Minn. R. 1400.2100(B).
Mr. Orr’s comments show the damage that the proposed rules will do to Minnesota and Minnesotans. Given the damage the MPCA’s proposed rules will cause, the MPCA has failed to properly weigh the impact of the proposed rules on the establishment, maintenance, operation and expansion of business, commerce, trade, industry, and other economic factors which affect the proposed rule’s feasibility and practicability. Minn. Stat. § 116.07, Subd. 6.
In addition, the MPCA has admitted in its Statement of Need and Reasonableness that California’s regulatory agencies will have full control over the literal text of the rules in Minnesota:
8421 Wayzata Boulevard Suite 105 Golden Valley, MN 55426 612-428-7000 Fax 763-710-7429 UMWLC.org The MPCA is proposing to adopt the LEV and ZEV standards “as amended.” Incorporation “as amended” means that any future amendments to the incorporated California regulations automatically become part of Minnesota rules.
SONAR, p. 41.
Given this admission, the proposed rules should also be disapproved pursuant to Minn. R. 1400.2100(F), which provides that the ALJ should disapprove rules which “improperly delegate[] the agency's powers to another agency, person, or group.” Delegating the agency’s rulemaking to the regulatory agency of another state is an even more egregious violation of law than improper delegation to another Minnesota agency, and violates the cardinal principle of Minnesota’s statehood—the self-governance of Minnesota by Minnesotans. Minn. Const. art. I, § 1.
For the reasons set forth here, in Mr. Orr’s attached comments, and in my prior comments and oral testimony, I respectfully request that Your Honor disapprove the proposed rules pursuant to Minn. R. 1400.2100 and 1400.2240.
In addition to the foregoing analysis, the comments of Mr. Orr, and my prior comments, UMLC reserves the right, on CAE’s behalf, to submit further comments and replies to the comments of other parties through the close of the hearing record and rebuttal period, and to proceed with any applicable appeals.
Respectfully,
Douglas Seaton, Esq., President of UMLC Attorney for Center of the American Experiment cc: James V.F. Dickey, Esq. (UMLC) John Hinderaker (CAE) Isaac Orr (CAE)
8421 Wayzata Boulevard Suite 105 Golden Valley, MN 55426 612-428-7000 Fax 763-710-7429 UMWLC.org Doug Seaton Attachment 4
Center of the American Experiment 8421 Wayzata Boulevard, Suite 110 | Golden Valley, MN 55426 Phone: 612-338-3605 | Fax: 612-338-3621 | Email: [email protected]
OAH Legal Assistant Sheena Denny OAH PO Box 64620 St. Paul, MN 55164-0620 [email protected]
Organization of this Comment 1. About Center of the American Experiment. 2. Executive summary and policy recommendations. 3. LEV and ZEV regulations infringe on the property rights of Minnesota auto dealers and harm the viability of their businesses. 4. ZEV rule will force auto dealers to stock electric cars that are not profitable and have limited demand. 5. LEV and ZEV rules will not increase consumer choice. 6. LEV and ZEV mandates will increase costs for consumers. 7. Environmental impacts of the proposed LEV and ZEV standards. 8. Disparate impacts on minority and low-income communities. 9. There is no legal basis to implement LEV and ZEV rules under Minnesota law. 10. Conclusions.
1 Center of the American Experiment (American Experiment) submits the following comments to the Minnesota Office of Administrative Hearings (OAH) regarding the adoption of California's Low-Emission Vehicle and Zero-Emission Vehicle air pollution standards (Revisor's ID R- 4626).
1. About Center of the American Experiment Center of the American Experiment is Minnesota's leading public policy organization. The Center is more than a think tank. It not only researches and produces papers on Minnesota's economy, education, health care, energy, environment, employee freedom, and state and local governance, it also crafts and proposes creative solutions that emphasize free enterprise, limited government, personal responsibility, and government accountability. American Experiment's staff advances those solutions by drafting legislation, testifying before legislative committees, placing op-eds in newspapers and magazines across the State of Minnesota and nationally, appearing on radio and television news programs, holding town meetings, and lobbying. Further, American Experiment conducts grass roots advertising campaigns on radio and on the internet, which bring the key findings of the Center's research papers to millions of Minnesotans. And the Center carries out investigative reporting, uncovering waste, abuse of power and ineptitude in Minnesota's state and local governments, schools, and unions. For more than 25 years, Center of the American Experiment has been the most impactful and effective public policy organization in Minnesota. It leads the way in creating and advocating polices that make Minnesota a freer, more prosperous, and better-governed state.
2. Executive Summary and Policy Recommendations On Dec. 21, 2020, the Minnesota Pollution Control Agency (MPCA) published a Notice of Intent to Adopt Rules with a Hearing for the California Low Emission Vehicle (LEV) and Zero Emission Vehicle (ZEV) mandates in the State Register. The rules would enforce regulations promulgated by the California Air Resources Board (CARB) to reduce greenhouse gas (GHG) and other emissions from the transportation sector in Minnesota and force auto manufacturers to stock a minimum number of electric vehicles in the state. Center of the American Experiment recommends that the Administrative Law Judge (ALJ) find the rules to be neither needed nor reasonable and thus disapprove the rules. Furthermore, Center of the American Experiment recommends the following policies be adopted in pursuit of vetting LEV, ZEV, and any future greenhouse gas emissions regulations to be promulgated by MPCA:
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1. Any proposed greenhouse gas regulation should clearly state how much it would reduce future global temperatures in clear and understandable terms. 2. MPCA should be required to make all data used in its technical support documents publicly available in easily accessible Excel spreadsheets and provide justification for the data it uses. 3. MPCA air modeling should also attempt to quantify health impacts under more realistic exposure paradigms (See Air Modeling).
3. LEV and ZEV regulations infringe on the property rights of Minnesota auto dealers and harm the viability of their businesses. First and foremost, the proposed LEV and ZEV regulations are an infringement on the private property rights of auto dealers to operate their businesses in the way that best serves their own financial self-interest, the interests of their employees, and most importantly, their customers.
LEV Mandates The LEV mandates will require all new internal combustion engine vehicles sold in the state to meet California's standards for carbon dioxide emissions. MPCA and other stakeholders acknowledge that these vehicles will be more expensive than non-LEV vehicles and will increase the cost of driving in Minnesota.
ZEV Mandates Because auto manufacturers will be forced to "deliver for sale in Minnesota a certain number of vehicles with ultra-low or zero tailpipe emissions each year, including battery electric vehicles (EVs), plug-in hybrid electric vehicles (PHEVs), and hydrogen-fueled vehicles," under the proposed ZEV standards, the rules would require car dealers to offer money-losing cars on their lots. Carmakers will be forced to raise prices on ICEVs sold in the state to make up for losses on EVs, further contributing to rising prices for new vehicles sold in Minnesota.
Scope of the Rules MPCA has also been ambiguous about the scope of the ZEV standard moving forward. This is worrisome because California Gov. Gavin Newsom announced he would direct CARB to draft regulations banning the sale of gasoline or diesel-powered passenger vehicles in the state after 2035.1 MPCA has indicated in listening sessions that Minnesota would not be bound to California's LEV or ZEV standards if the state increases the stringency of the regulations, and that MPCA would need to engage in a new rulemaking to adopt California's most-recent standards. However, MPCA's Statement of Need and Reasonableness (SONAR) says:
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"The MPCA is proposing to adopt the LEV and ZEV standards "as amended." Incorporation "as amended" means that any future amendments to the incorporated California regulations automatically become part of Minnesota rules. Using "as amended" improves administrative efficiency by reducing the need for rulemakings to maintain consistency with the California rules. Historically, 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. The decision to incorporate these rule updates or revert back to the backstop federal standards would still need to be considered on a case- by-case basis through Minnesota state rulemaking." (p. 41). Past performance is no guarantee of future results. California has become more aggressive in limiting the types of vehicles that Californians will have access to in the future, and as more states adopt LEV and ZEV standards, "as amended," CARB may feel a growing pressure to update their rules without issuing new rule parts. Such a change in the way CARB updates its rules would bind Minnesota to ever-increasing standards irrespective of whether they serve the best interests of Minnesota families. These factors represent real challenges for operating a car dealership in Minnesota under the proposed regulatory regime, which is why we believe the ALJ should deem the proposed rules as not needed or reasonable and not rationally related to the agency's objective. We believe the rule also "improperly delegates the agency's powers to another agency, person, or group." Minn. R. 1400.2100(F). Protecting the private property rights of auto dealers to stock the cars that are most popular with their customers is the best way to maintain the health of the auto dealer industry in Minnesota, which supports more than 97,000 jobs.2 Electric cars represented just 0.74 percent of new vehicles sold in Minnesota in 2018, meaning Minnesota consumers are not yet convinced EVs can replace ICEVs for personal transit. Center of the American Experiment outlines several factors contributing to low EV adoption in subsequent sections. 4. ZEV rule will force auto dealers to stock electric cars that are not profitable and have limited demand. MPCA presentations indicate the ZEV rules will require that 14,000 EVs be offered for sale every year in Minnesota. According to Atlas EV Hub, this number exceeds the number of EVs that have been registered in Minnesota over the last 10 years. 3
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Figure 1 shows, as of February 2020, there were 7,322 battery electric vehicles (BEV) registered in Minnesota and 5,556 plug-in hybrid electric vehicles (PHEV), for a total of 12,878 EVs.
Figure 1. As of February 1, 2020, there were fewer EVs registered in Minnesota (12,878 BEVs and PHEVs) than would be required to be "offered for sale" every year in Minnesota under the ZEV mandates. Figure modified from AtlasEVHub. American Experiment does not see how mandating more electric vehicles be "offered for sale" each year than have been sold in the last 10 years can be considered reasonable by MPCA, especially when we consider that electric vehicles are not profitable.
Not Profitable According to the Los Angeles Times: "Partly because of their high costs, electric cars so far have proved unprofitable. Carmakers are selling them at a loss. Government subsidies on electric car purchases have proved necessary to keep consumers interested. Carmakers hope that production levels will reach the point where per-car costs fall, subsidies are no longer necessary and EVs can be sold at a profit. When that point will be reached, no one can say."4
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An analysis by McKinsey & Company states: "There is a problem: today, most OEMs do not make a profit from the sale of EVs. In fact, these vehicles often cost $12,000 more to produce than comparable vehicles powered by internal- combustion engines (ICEs) in the small- to midsize-car segment and the small-utility-vehicle segment (Exhibit 1). What is more, carmakers often struggle to recoup those costs through pricing alone. The result: apart from a few premium models, OEMs stand to lose money on almost every EV sold, which is clearly unsustainable. … Current thinking holds that the industry will continue to produce EVs—largely because it has little alternative in the face of stringent fuel-economy and emissions policies—and that the industry will, in the meantime, absorb the losses."5
By imposing California's ZEV mandate on Minnesota, the agency would force automakers to sustain losses by mandating cars that few Minnesotans want to buy. The cost of these losses would be recouped by raising prices on the ICEVs that people actually wish to purchase.
Barriers to EV Adoption One reason EVs have failed to naturally gain a larger market share is that they are significantly more expensive than their gasoline or diesel-powered counterparts. For example, a Chevy Bolt has a manufacturer's suggested retail price (MSRP) of $36,620, while a Chevy Malibu has an MSRP of only $22,095, meaning the Bolt costs about 66 percent more than the Malibu. The premium price tag for EVs is a major barrier to entry that most Minnesota families simply can't afford, especially when the fact that traditional vehicles are more useful and versatile than electric vehicles is considered. Research from MIT indicates the electric vehicles will remain more expensive than internal combustion engine vehicles (ICEV) for the foreseeable future. EV advocacy groups frequently claim that electric vehicles will have lower lifetime ownership costs because of reductions in battery prices. However, MIT researchers concluded it is likely to take another decade just to eliminate the difference in the lifetime costs between the vehicle categories, which factor in higher fuel and maintenance expenses for ICEVs compared to EVs.
MIT Research on The Higher Costs of EV Ownership The MIT Energy Initiative warns that EVs may never reach the same sticker prices as ICEVs if they continue to rely on lithium-ion batteries. Lithium-ion is the energy storage technology that powers most consumer electronics, according to the MIT Technology Review.6 These findings stand in sharp contradiction to studies by other research groups which have concluded that EVs could potentially achieve price parity with ICEVs within the next five years. However, MIT explains that the steady decline in the cost of lithium-ion batteries, which power
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EVs and account for about a third of their total cost, is likely to slow in the next few years as they approach the limits set by the cost of the raw materials.7 "If you follow some of these other projections, you basically end up with the cost of batteries being less than the ingredients required to make it, says Randall Field, executive director of the Mobility of the Future group at MIT. "We see that as a flaw." The MIT report continues: "Current lithium-ion battery packs are estimated to cost from around $175 to $300 per kilowatt-hour [kWh]. (A typical midrange EV has a 60/kWh battery pack.) A number of commercial and academic researchers have projected that the costs of such batteries will reach $100/kWh by 2025 or before, which many proclaim is the "magic number" where EVs and gas-fueled vehicles reach retail price parity without subsidies. And they would continue to fall from there. But reaching the $100 threshold by 2030 would require material costs to remain flat for the next decade, during a period when global demand for lithium-ion batteries is expected to rise sharply, MIT's "Insights into Future Mobility" study notes. It projects that costs will likely fall only to $124 per kilowatt-hour by then. At this point, the "total cost of ownership" between the categories would be about the same, given the additional fuel and maintenance costs of gas-fueled vehicles. (Where these lines cross precisely depends heavily on local fuel costs and vehicle type, among other factors.) But the sticker price of an EV with 200 miles of range would still run thousands of dollars more than a comparable gas-fueled vehicle in many areas. While closing the gap on total cost of ownership would be a solid step for electric vehicles, the average consumer is very sensitive to upfront price tag—and what it equates to in monthly payments." MPCA will undoubtedly receive comments claiming that EVs and ICEVs have already achieved, or will soon achieve, cost parity. However, the agency should carefully examine the assumptions used to come to these conclusions. It is doubtful the studies used to support these claims will have more credibility than MIT. As stated earlier in these comments, EVs are currently unprofitable, and the assumed road to profitability appears to be paved with unrealistic assumptions of future cost declines. If MIT is correct, the need to pass on losses incurred from the sale of EVs onto purchasers of ICEVs means the proposed regulations would burden traditional car buyers beyond the additional costs incurred by imposing LEV standards. At the very least, MPCA should use MIT's cost projections for lithium-ion battery technology to inform at least one scenario for the potential reductions in battery costs and the economic impacts ZEV regulations would have on Minnesota.
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EVs are Less Dependable than ICEVs Even if EVs and ICEVs reach sticker-price cost parity, there are legitimate reasons to doubt Minnesota consumers will choose to purchase 14,000 EVs per year. Compared to traditional engines, EV's have more-limited range, and this range declines substantially during periods of cold weather. These factors are likely a key reason why many current EV owners also own an ICE vehicle, and they why Metro Transit has reserves course on its announcement to stop purchasing buses that run on diesel fuel by 2022 and purchase electric buses, instead.
Range Anxiety According to a study conducted by Volvo, 58 percent of drivers cited range anxiety, the fear that they will run out of power before being able to charge their vehicle, as their main reason for avoiding purchasing an electric car, while another 49 percent fear the low availability of charging stations.8 According to MYEV.com, there eight EVs models for MY 2019 that can run for more than 200 miles before needing to be recharged. According to the website, new, longer-range models this year include the Audi e-tron at 248 miles, the Nissan Leaf e+ variant at 226 miles, and the Hyundai Kona Electric that can run for an average 258 miles.9 The Tesla Model S has the longest range, with 370 miles, but it also retails for $86,200, according to Kelley Blue Book.10 Charging times for these models range from 9.5 hours to 11.5 hours for home charging, although "fast charging" stations can charge some batteries up to 80 percent of their charge in 20 to 30 minutes. Short ranges combined with long charging times result in EVs having less utility than traditional vehicles. This is particularly important to realize in a state as large as Minnesota. People rarely purchase vehicles based on their average daily use, they purchase them with other factors in mind, such as road-trips or family vacations. For example, someone who grew up in Moorhead but moved to Minneapolis would likely have to charge their EV at least once if they were to travel home to visit relatives. This would make a 3.5 hour drive closer to four hours, if not longer. The number of times this EV driver would have to stop and charge their car would increase by two or three times during the coldest winter months, potentially lengthening the trip to more than five hours because cold weather greatly reduces the range of EVs.
Reduced Range in Cold Weather According to AAA, EVs can lose more than 40 percent of their battery range when temperatures reach 20 degrees Fahrenheit and battery range fell by more than 50 percent during the Polar
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Vortex of January 2019 (See Figure 2).11,12,13 Cold temperatures also result in longer charging times, which can further reduce the utility of electric vehicles.
Figure 2. Electric vehicles experience reduced range during periods of cold weather and warm weather. At 20 degrees Fahrenheit, all models studied by AAA experienced a 30 percent reduction in range, and some cars experienced a 50 percent reduction in EV range when using their heating systems. Other studies have come to similar conclusions. According to the experience of a Chevy Bolt driver in Quebec: "Plus, if I had connected the Bolt with the provided 120V charging cord, it would have taken it 50 hours to charge. Fifty! I've also been told that the 120V charger is too weak for Canada's savage conditions. At -40 degrees, that tiny cord is barely strong enough to provide heat to the batteries. Luckily, my phone app told me there was a Level 2, 240V public charger just half a mile from my home at the cost of $1 an hour. It would take my Bolt nine hours to charge." Studies in Germany have also corroborated the fact that electric cars lose utility in winter. In Minnesota, this means that the expected environmental benefit of ZEV rules could be mitigated by the fact that commuters may choose to use an ICEV during cold periods rather than ZEVs.
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Fuel economy is also diminished during periods of cold weather. According to the AAA study, on average, HVAC use 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 Figure 3).
Figure 3. According to AAA, the cost of driving an electric car while using the heating systems during periods of 20-degree Fahrenheit weather increases from 38 percent to 85 percent, depending on the make and model of the electric vehicle. All vehicles experience reduced fuel economy during periods of cold temperatures, but the impact of cold weather is more pronounced with electric vehicles because their batteries must use stored energy to create heat, whereas ICEVs use heat that is generated by the combustion of fuel to heat the cabin. As a result, American Experiment does not believe it is needed or reasonable to mandate 14,000 EVs to be stocked in Minnesota when they will experience reduced range and reliability for much of the year.
Real-World Experiences Validate Range and Reliability Concerns Real-world experience shows that range and reliability concerns over EVs are warranted. In California, Governor Newsom instructed the Department of General Services, the state's business
10 manager that oversees vehicle purchases for California's fleet, to no longer purchase gas- powered sedans. The immediate ban on state purchases of cars powered only by gas will include exceptions for public safety vehicles.14 The exclusion of public safety vehicles is a nod to sanity in an otherwise unwise policy. It is telling that the governor acknowledges the essential nature of ICEVs for public safety (due to their superior performance attributes), and this exclusion demonstrates that EVs are not ready to be the primary mode of transit for private or public transportation services.
Minnesota Examples Municipalities in Minnesota who have sought to electrify public transit have already experienced problems in their limited time using EVs. Duluth has already experienced cold-weather headaches with its costly line of electric buses, as detailed in the Duluth News Tribune article "DTA Temporarily Pulls Electric Buses," over braking problems on icy hillside avenues and a lack of on-board heat.15 Furthermore, Duluth's experience highlights the problems with attempting to mandate ZEVs for mass transit, because DTA's buses have auxiliary heat powered by a diesel engine to ensure passengers can ride in comfort without greatly reducing the range of the bus battery during cold weather. Since the CAA requires states wishing to adopt California's standards to do so exactly, Minnesota has no flexibility within the rules to adopt Minnesota-specific changes. As a result, it is unclear whether DTA's electric buses could quality as "zero emission" vehicles. Another example occurred in Minneapolis with the Metro Transit fleet. In late 2018, Metro Transit boldly proclaimed the agency would add electric vehicles to its fleet and stop buying diesel-powered buses entirely by 2022. However, after experiencing numerous problems with its eight electric buses in a pilot program, the agency has smartly announced a $122 million plan to purchase 143 buses that run on "biodiesel."16 As the Department of Energy notes, "biodiesel" vehicles and conventional diesel vehicles are one and the same.17 In October, the Star Tribune wrote an article entitled "Metro Transit Temporarily Pulls Electric Buses from C Line Because of Problems with Chargers."18 According to the article, eight electric buses on the newly formed C Line would be taken out of service until defects with the charging mechanisms could be fixed. Diesel-powered buses were used to continue service on the line. Cost likely played a large factor in Metro Transit's decision to hit reverse on its electric vehicle ambitions. Electric buses cost approximately, $1.2 million per bus, whereas the diesel buses Metro Transit is considering will cost $748,000, a difference of $452,000 per bus, or 60 percent. Buying diesel buses instead of electric buses will save the agency $64.6 billion and provide better options for riders.
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According to the Star Tribune article:
"Metro Transit officials said the pilot program involving eight electric buses on the C line arterial bus route has proved challenging. The first electric buses were rolled out to great fanfare in 2019, but the system soon encountered issues with charging equipment. On Tuesday, the electric chargers overheated, resulting in all eight buses being sidelined.
Cold climates like Minnesota's can also sap electric vehicle charges. The plan adopted three years ago called for half of the area's new rapid transit buses to be electric. But Metro Transit officials now say electric buses are not a good fit because the new lines cover too much territory, making establishing a network of charging stations challenging.
Those routes include the Orange Line, a 17-mile bus rapid transit project connecting downtown Minneapolis to Burnsville, which will begin service later this year; the D line, arterial bus rapid transit connecting Brooklyn Center to the Mall of America, which is slated to begin service next year; and the B line, linking Uptown to downtown St. Paul, which will open in 2024.
"It's too long," said Brian Funk, Metro Transit's deputy chief operating officer-bus. "They just do not fit the profile, given the operating range."
Residents in Greater Minnesota have been making these same arguments to the MPCA for 18 months. Mandating automakers to stock 14,000 electric vehicles per year in the state when government institutions in Minnesota are scrapping their plans to purchase electric vehicles proves the regulations are not reasonable. Metro Transit's decision also shows that diesel buses, not electric buses, are needed to provide the reliable transit service that many Minnesotans depend upon.
New Mexico Duluth and Minneapolis are not alone. Problems associated with electric buses prompted the city of Albuquerque to return the electric buses they had purchased, according to an article in CityLab.19 According to the article:
"Albuquerque recently made headlines in the urban public-transit world when the municipal transit agency, ABQ RIDE, returned the BYD-made electric buses it had ordered, finding them deficient. The city had paid $1.2 million apiece for these buses, and after it returned them, it bought diesel buses from New Flyer for $870,000 each."
The Met Council realized that spending additional taxpayer resources on electric buses that do not have the same performance or reliability characteristics as diesel-powered buses is a bad policy. However, it would be worse for the Governor and MPCA to enshrine those policies in the Minnesota administrative code.
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Temperatures are frequently below 20 degrees F in Minnesota and mandating that auto dealers offer cars that have not demonstrated that they are capable of delivering the same performance as ICEVs at a comparable cost is bad public policy.
Conclusion Given the dependability challenges faced by EVs in Minnesota's cold climate, we do not believe it is reasonable to mandate auto manufacturers to stock 14,000 EVs in the state every year. 5. LEV and ZEV Mandates Will Not Increase Consumer Choice One argument the Gov. Tim Walz and his administration are using to justify the California car mandates is that these mandates will increase consumer choice. However, we believe the administration is doing so under false pretenses and that the ZEV mandates will require auto dealers to stock more electric vehicles that few Minnesotans want.
Concerns LEV Standards Will the Number of Reduce Light-Duty Vehicles "Offered for Sale" in Minnesota American Experiment is concerned that the fleetwide emissions standards for greenhouse gas emissions will reduce the number of light-duty vehicles offered for sale in Minnesota to help automakers reach their mandates. In their supporting documents, MPCA estimates new vehicle sales will consist of 75 percent light-duty trucks, and 25 percent passenger cars. This assumption for passenger vehicle sales is slightly higher than vehicle sales in Minnesota in 2018, which were 21 percent passenger vehicles and 79 percent light-duty trucks. 20 We believe these are small discrepancies, but research from Bloomberg indicates that SUVs are a quickly-growing segment of the vehicle market, whereas cars sales have plunged 30 percent in a four-year timeframe (See Figure 4).21
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Figure 4. SUV sales are growing segment of the U.S. auto fleet, whereas cars have fallen in market share since 2015. While MPCAs current projections are not far off current vehicle sales, the trend in Minnesota, and nationally, toward crossover SUVs suggests these vehicles may continue to grow in market share relative to smaller vehicles. Minnesota consumers already have the freedom to choose a vehicle that get higher fuel mileage, but more often than not, they hold other factors such as size or safety features, to be a higher priority.
ZEV Rules Mandate EV Models That Virtually No One Wants MPCA claims the rules are needed to ensure that Minnesotans have access to the electric vehicle models they desire but cannot currently access in Minnesota.
However, comparing current EV registrations from Atlas EVHub and survey data from CleanTechnica.com, a website dedicated to promoting renewables and electric vehicles, suggests there is virtually no demand for the models that are not currently offered in Minnesota, undermining this argument by the Walz administration.22
EV registration data from Atlas EVHub shows the market for electric vehicles in Minnesota is dominated by Tesla, and no other automaker is even close to the same volume (See Figure 5).23
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The graph below shows that Tesla accounts for 65 percent of BEV registrations, with Nissan accounting for approximately 20 percent of the BEV market.
Figure 5. Registration data from Atlas EVHub shows Tesla EVs are by far the most popular BEVs in Minnesota.
The data from Atlas EVHub also show the most popular EV models in Minnesota. Here we can see that the Tesla Model 3, the most affordable Tesla offered, has the highest market share, accounting for about 37 percent of BEV registrations in Minnesota (See Figure 6). Unsurprisingly, the Chevy Volt leads PHEVs, and the Nissan Leaf is the second most-owned BEV.
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Figure 6. The most popular EV models in Minnesota are the Tesla Model 3, Chevy Volt, Nissan Leaf, and other Tesla models.
Part of MPCA's justification for imposing these regulations on Minnesotans is a claim that the rules will increase consumer choice and give Minnesotans access to the EVs they want but currently cannot get because they are not offered for sale in Minnesota.
Registration data show that Minnesotans already have access to all of the top-selling EVs in the nation, meaning the Walz administration is not expanding consumer choice. It could be argued that these cars are the biggest sellers because they are more available than other EV's, and not because they are the first choice of would-be EV consumers, but CleanTechnica's surveys do not support this argument.
Survey Data Suggest Low Demand for EVs Not Currently Offered in Minnesota
The CleanTechnica survey asked current EV drivers which model EV they would be most likely to purchase next. As you can see, Tesla Model 3 and Model Y are the most popular choices, with a generic "other" making 13 percent (See Figure 7). The Bolt, LEAF, and Kona constitute another 21 percent of the would-be EV market, and all are available in Minnesota.
MPCA has attempted to demonstrate the need for these rules by saying there is a large demand for the Kia Nero EV, which is not currently offered for sale in Minnesota. The CleanTechnica survey data suggests the Agency's argument is based on anecdotes and is not representative of broader consumer demand. Of current EV drivers, only 5 percent want a Kia Nero EV for their next vehicle.
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Figure 7. The most sought-after EVs on the market include the Tesla Model 3, and Model Y, "Other," Chevy Bolt, Nissan Leaf, Hyundai Kona EV and Tesla Model S, all of which are offered for sale in Minnesota. Only 5 percent of respondents wanted a Kia Niro EV.
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While proponents of the ZEV mandates often claim the rules are needed due to a large, pent-up consumer demand for EVs not offered in Minnesota, this survey seriously undermines this argument.
In actuality, every single electric car in the top eight sellers nationally is available for sale in Minnesota, and could be purchased today if the consumer is so inclined.
Adopting California's car regulations an forcing auto manufacturers to stock 14,000 EVs in the state annually for the sake of the small number of Minnesotans who want a Kia Nero EV would be a gross infringement on the rights of auto dealers to conduct their business as they see fit to promote cars that few people want. It is difficult to see how MPCA can determine that the ZEV vehicles are needed or reasonable to expand consumer choice.
6. LEV and ZEV Mandates Increase Costs for Consumers and Will Not Pay for Themselves The Walz administration claims the proposed LEV and ZEV standards could result in a net cost of $23 million in total average annual net consumer costs or a net savings of $48 million in total average net consumer savings per model year over vehicles' lifetimes for the 10-year time frame spanning model year 2025 to 2034. Over ten years, MPCA claims these would translate to between an estimated $236 million net consumer costs to $476 million in net consumer benefits over vehicles' lifetimes for the first 10 model years of implementation of the proposed rule. However, we believe these projections are underestimating the increase in consumer costs for the LEV standards, and the cost analysis for the ZEV standard is based on the incorrect assumption that EVs are "generally cheaper to own and operate over the life of the vehicles due in large part to fuel and maintenance savings. 24 Research from the Colorado Auto Dealers Association estimates the rules will cost substantially more than MPCA's assumptions, and the MIT study disputes the notion that EVs have reached cost parity with ICEVs. Lastly, rising electricity prices will diminish fuel savings for EVs in the near future.
Increasing Costs from LEV Standards The MPCA SONAR document states: "Once the LEV standard has reached its maximum stringency in model year 2025, the average up-front purchase price of a new LEV-certified vehicle may be $900 to $1,200 more than a SAFE-certified vehicle, depending on the vehicle size and type. An average new LEV-certified vehicle in Minnesota is estimated to be approximately $1,139 more than a new SAFE-certified vehicle, since more light-duty trucks are sold in Minnesota than passenger cars."25
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Colorado was the most recent state to adopt California's LEV standards. According to the Colorado Automobile Dealers Association (CADA) the rules would increase the averages sticker cost for vehicles by $2,110 per car produced between model year (MY) 2021 and 2025, and increase the average sticker price by $2,098 for MY 2025 (See Table 1). CADA's cost increase estimates are nearly twice as large as those developed by MPCA. Even at this lower cost, MPCAs analysis did not show a clear savings from lower fuel costs. For example, MPCA's slides state: "If there is a potential price difference in the future, consumers who buy LEV- certified vehicles would essentially break-even due to fuel savings." Using CADA's cost increase estimates, consumers would likely lose about $959 per vehicle over the lifetime of a MY 2025 vehicle, assuming a perfect “break-even” ($2,098-$1,139). Assuming approximately 200,000 vehicles are sold each year, this translates into an annual loss of $191.8 million, or $1.9 billion over ten years. This rough estimate is in line with CADA's analysis, which found LEV regulations would impose a net cost of more than $2 billion on Colorado consumers.26
Table 1. An analysis by CADA determined it would take more than 14 years for a MY 2022 truck to provide a consumer benefit, and that it would take 11 years for a MY 2025 truck. CADA's analysis investigated the "payback time" for a truck for MY 2022 would be more than fourteen years, and payback would be 11 years for a MY 2025 truck (See Table 1). This is problematic because the average vehicle age in Minnesota is 11.8 years, meaning it would take 11 years for consumers to see any fuel benefits.27
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MPCA should also note that CADA found the total fuel savings of $812 million were outweighed by $2.86 billion in direct costs. According to the CADA report: "In a state where consumers demonstrate a preference for [more] trucks than for cars, EVA [Energy Ventures Analysis] estimates that consumers will see cost benefits of the regulation in the eleventh year of vehicle ownership for a truck purchased at the end of the regulation timeframe. A truck purchased near the beginning of the regulation timeframe will not offer consumers a cost-benefit of regulation over the reasonable life of the vehicle." Minnesota consumers have a larger preference for large vehicles than those in Colorado. According to Auto Alliance, 39 percent of vehicles sold in Colorado in 2018 were cars, 35 percent were crossovers or sport utility vehicles (SUVs), 21 percent were pickups, and 5 percent were minivans. In contrast, cars represented just 21 percent of new vehicles sold in Minnesota while crossover vehicles represented 44 percent, SUVs accounted for 8 percent, pickup trucks comprised 21 percent, and minivans accounted for 5.3 percent of new vehicle sales in 2018.28 Due to consumer preferences in Minnesota, the regulations are likely to have even larger costs with smaller benefits than they would in Colorado. Therefore, LEV regulations would be a net loss for Minnesota's economy and consumers.
Increasing Costs from ZEV Standards MPCA accepts the inaccurate premise that EVs have lower lifetime ownership costs than ICEVs, but the newly released, comprehensive three-year study by MIT, mentioned above, concluded that electric vehicles are more expensive to operate than ICEVs even after taking higher fuel and maintenance costs for ICEVs into consideration.29 In practice, ZEV mandates will increase the cost of ICEVs offered for sale in Minnesota as auto dealers attempt to recoup the costs they will incur when they are forced to purchase the EVs by the auto manufacturers. In this way, ICEV consumers are providing a cross-subsidy to EV drivers. There will also be several additional societal costs that will be borne by Minnesotans that were "outside the scope" of MPCA's analysis. Among these are the costs of building enough charging stations to accommodate the mandated EV sales from the ZEV rules, how much home charging stations would cost to install, and who would be responsible for paying them?
A model utility with two to three million customers would need to invest between $1,700 and $5,800 in grid upgrades per EV through 2030, according to Boston Consulting Group. 30 Assuming 14,000 new EVs would be mandated on the Minnesota market each year, it would
20 require an additional investment of $81.2 million per year, or $812 million over the first 10 years of the mandates.
Rising Electricity Prices and Their Impact on EV Viability
The Walz administration's assessment of costs or benefits also relies on the assumption that the price premium for electric vehicles will be only $3,800 by 2025, and that EV fuel cost savings will total $9,000 over the life of a vehicle. We believe this expected savings on fuel for electric cars will only be $907 over the course of EVs lifetime.
EVs currently enjoy a price advantage on fuel relative to gas-powered cars. A Chevy Bolt can travel 238 miles on a single charge with its 60-kilowatt hour (kWh) battery. Using these numbers, it would take 0.25 kWh to drive one mile. In the City of Minneapolis, residential electricity prices are 16.11 cents after taxes and fees. This means the cost per mile is approximately 4 cents.
A 2020 Chevy Malibu has a fuel efficiency of 29 miles per gallon in town and 36 miles per gallon on the highway. If we assume an average fuel economy of 33 miles per gallon and a gasoline cost of 2.50 per gallon, the cost per mile is approximately 7.5 cents, meaning electric cars cost approximately 46 percent less to drive than ICEVs at this time.
However, the price difference between electricity and gasoline could easily diminish over time as residential electricity rates in Minnesota continue to increase. For example, Xcel Energy recently announced its desire to increase residential electricity prices by 20 percent to help pay for $597 million dollars in capital expenditures and to make up for lost revenue due to lower electricity consumption due to energy efficiency (See Figure 8).31
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Figure 8. Minnesota electricity rates vary substantially by electricity provider. Residential rates for Xcel Energy customers will increase substantially if its proposed rate increases are enacted. OTP is Otter Tail Power Company, MNP is Minnesota Power, XCEL is Xcel Energy, and US is the average residential rate in the United States.
Xcel's proposed rate increase would raise residential electricity rates to 17.19 cents per kWh before taxes and fees, which grows to 18.98 cents per kWh after taxes and fees in Minneapolis. As a result, the cost per mile would grow to 4.75 cents for EVs and diminish the fuel cost advantage of electricity from 46 percent lower than gasoline to 36.6 percent lower.
As electricity becomes more expensive over time, the price advantage of electricity, relative to gasoline, diminishes, making these rules less reasonable.
Center of the American Experiment has evaluated Xcel Energy's proposed Integrated Resource Plan and estimated the plan will cost $57 billion through 2051, and increase residential electricity rates to 24 cents per kilowatt-hour before taxes and fees, and 27.3 cents per KWh after taxes and fees are assessed.
Costs are driven by Xcel's proposed resource mix, which would close the remainder of their coal plants by 2030, and build up to 4,000 megawatts (MW) of wind, 3,500 MW of utility solar, 574 MW of community solar, 3,450 MW of natural gas (combines cycle and combustion turbine), and repower 3,499 MW of wind.32
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Figure 9 shows residential electricity prices in Xcel Energy's service territory, assuming these costs are split among residential, commercial, and industrial ratepayers in accordance with historical trends. Electricity prices reach 27.3 cents per kilowatt-hour in 2034.
Figure 9. Electricity rates in Minnesota continue to climb, and the trend will continue through 2035. This will reduce the current price advantage of using electricity instead of gasoline.
When we consider the rising price of electricity in Xcel's service territory for fueling electric vehicles against the Annual Energy Outlooks 2019 reference case, which the MPCA used in its analysis, we see that the price advantage of electricity is quickly eroded for the years 2025 through 2034 (See Table 2).
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Table 2. Using EPAs MOVES assumptions, the Energy Information Administration's Annual Energy Outlook's 2019 Reference case for gasoline prices, and American Experiment's analysis of future electric rates, we conclude the likely lifetime EV fuel savings will be around $910.
Using our electricity price forecast, the average EV driver would save almost $910 over the course of the lifetime of the vehicle. We did not attempt to quantify savings from lower lifetime maintenance costs for EVs compared to ICEVs.
We have reason to believe our electricity price forecast is conservative. Xcel's proposed capacity additions may not be enough to meet rising electricity demand due to increasing numbers of electric vehicles, as the National Renewable Energy Laboratory estimates an installed electric generation capacity would need to be double by 2050, primarily to meet the demand for electricity if 66 percent of the vehicle fleet were operated on electricity. (See Figure 10).33
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Figure 10. Installed electric generating capacity would need to double by 2050 to accommodate a vehicle fleet that is 66 percent powered by EVs.
Utilities will also be investing billions of dollars to accommodate electric vehicles. According to AutoBlog: "Investments in both the grid and charging infrastructure that are recovered from ratepayers could add between $3 billion and $10 billion in cumulative cash flow to the average utility through 2030, according to Boston Consulting Group."34
These capital expenditures will put significant upward pressure on electricity rates, further diminishing any operating cost advantages electric vehicles may currently enjoy. They may even make electricity more expensive than gasoline.
Rising electricity prices call into question the reasonableness of mandating the sale of EVs in Minnesota. There is also, as an aside, real concern about the future reliability of the electric grid as Minnesota's reliable, baseload electricity generators are retired in the next decade.
Electric Grid Reliability Concerns
An increasing reliance on intermittent power sources like wind and solar power have resulted in rolling blackouts in California, Texas, and the 14 states of the Southwest Power Pool since August of 2020. NREL estimates the electricity generated to power increasing quantities of
25 electric vehicles will primarily come from wind, solar, and natural gas. The increasing reliance on these fuels puts Minnesota's energy system at risk.
The risk is growing because as Jesse Jenkins, a Dr. Jesse Jenkins, a professor at Princeton University and a rising star in the world of renewable energy, stated on Twitter, "Wind is reliably unreliable, and the system operators and everyone else knows that. So we plan around it. The real failure is to plan around the likelihood of simultaneous thermal plant outages. That's my point."35
Wind generation often plummets when severe cold weather fronts move through Minnesota. Data from the U.S. Energy Information Administration show the regional grid to which Minnesota belongs, the Midcontinent Independent Systems Operator (MISO), saw a dramatic drop off in wind generation during the Polar Vortex that occurred in mid-February (See Figure 11).36
Figure 11. During the polar vortex of 2021, wind generation fell precipitously. Coal served the majority of electricity load during this time, with natural gas and nuclear also supply significant quantities of power.
MISO was able to avert blackouts largely due to the performance of the coal fleet, which shouldered more than 50 percent of electricity load during the cold snap. Without the coal fleet,
26 falling generation from wind turbines would necessitate an enormous increase in generation from natural gas-fired power plants.
Figure 12 demonstrates what a hypothetical day would look like for Minnesota's electric grid during an extreme winter weather event with low wind speeds in 2035, after the state's final coal plants have been retired. Electricity generation responsibilities would fall on the state's nuclear and natural gas generators.
Figure 12. Minnesota currently has a diverse fuel supply, but the grid will become increasingly dependent upon natural gas when the wind isn't blowing or the sun isn't shining.
The overreliance on natural gas is problematic because 66 percent of Minnesotans heat their homes with natural gas, and these customers often have first priority for the fuel.
Electric generators would be competing for supplies with heating fuel, and we would be placing additional strain on the grid to charge electric vehicles and keep the lights on. This situation could easily result in the types of rolling blackouts experienced in Texas, where the state's reliance on wind and gas led to several days of electricity shortages.
Some groups will argue EVs could help prevent blackouts by feeding power back to the grid when it is needed, but we find these arguments to be unpersuasive. If there is competition for natural gas for home heating, normal electricity generation needs, and transportation during a week-long Polar Vortex, EV batterie will be unable to meet demand.
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This presents an obvious safety hazard, as people may be unable to leave their homes to seek warmth or shelter because the electricity in their car batteries has been used to prop up the grid. The ZEV mandates will increase stress on an electric grid that is increasingly fragile.
7. Environmental Impacts of the Proposed LEV and ZEV Standards Center of the American Experiment believes MPCA may be overestimating the greenhouse gas emissions reductions from the rules. Furthermore, American Experiment believes the agency should be required to give the public estimate of how much future global warming may be averted by promulgating these regulations. Our own estimates suggest that adopting these rules will have no measurable impact on future global temperatures. The estimated benefits these rules would deliver by reducing traditional air pollutants is also likely exaggerated because Minnesota already meets all federal air quality standards; backyard fires and home heating contribute a larger share of pollutants than transportation; and the Air Quality Index in Hennepin County during the COVID-19 shutdown in the spring of 2020 was worse than the previous five-year average despite a 40 percent reduction in traffic.
Overestimating Greenhouse Gas Emissions Reductions MPCA estimates these regulations will decrease greenhouse gas emissions from the transportation sector by 1.4 million tons through 2034. This estimate does not consider the emissions that occur from manufacturing battery electric vehicles or ICE vehicles. We believe the rulemaking would benefit by incorporating this information because studies suggest it can take two to three years of operation for an EV to pay back its "carbon debt," and this will take longer on grids where the marginal fuel for electricity generation is coal, as it is in the Midcontinent Independent System Operator (MISO). According to Carbon Brief, recent studies have shown wide variations in estimates for emissions for manufacturing lithium-ion batteries. These estimates can be as low as 40 kilograms of CO2 equivalent per kilowatt-hour (kg/KWh) of battery capacity to 334 kg/KWh.37 We believe MPCA should conduction an emission analysis using both low-end and high-end estimates for their emissions calculations. Center of the American Experiment believes that EVs reduce GHG emissions relative to ICE engines in the long run, but because greenhouse gas emissions have a global effect, any emissions involved with manufacturing these vehicles should be quantified by MPCA even if the batteries and EVs are not manufactured in the state. This ensures the agency is properly accounting for greenhouse gas "leakage."
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MPCA Should Publish Estimated Temperature Impacts of All Greenhouse Gas Regulations The Walz administration clearly indicated the primary reason for initiating the LEV and ZEV rulemaking was to reduce transportation-related carbon dioxide emissions, thus reducing the impact of the transportation sector on climate change.
However, MPCA has not clearly stated how much future global warming adopting these rules would avert.
American Experiment believes all future greenhouse gas regulations promulgated by MPCA should clearly and publicly describe the degree to which greenhouse gas emissions would be reduced (in tons) and the impact such regulations would have on global temperatures (in degrees C by 2100) before enacting new rules.
To conduct this analysis, American Experiment recommends MPCA use the Model for the Integration of Greenhouse Gas Induced Climate Change (MAGICC), which is the same model used by the Obama Administration when it modeled the impacts of the Clean Power Plan. We believe a variety of inputs for equilibrium climate sensitivity should be used, ranging from 1 to 4.5 degrees C for each doubling of CO2 in the atmosphere.
We also believe the agency should be required to account for the likely growth in greenhouse gas emissions in developing countries would be most appropriate for distinguishing the impact these regulations will have on global temperatures and isolating these impacts from other emissions sources.
California Car Regulations Will Have No Measurable Impact on Global Temperatures
MPCA has state these rules will avert 1.4 million tons of greenhouse gasses by 2034. Using the same logic used by the Obama administration in developing the Clean Power Plan, which was widely considered to be the previous administration's most sweeping climate change initiative, American Experiment has estimated the temperature impact of the LEV and ZEV mandates on future global temperatures.
Had it not been stayed by the Supreme Court, the Clean Power Plan would have averted 730 million tons of carbon dioxide emissions from the electric power sector annually, which would have averted 0.019 degrees C by 2100, according to the Obama administration's own climate models. This is an amount too small to accurately measure with even the most sophisticated scientific equipment.
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The regulations proposed by Governor Walz would avert 1.4 million tons of carbon dioxide annually or 1.27 million metric tons. This means the LEV and ZEV mandates would avert approximately 0.17 percent of the anticipated reductions from the Clean Power Plan.
We can then estimate the temperature impact of the regulation by multiplying 0.019 degrees C by 0.17 percent, which gives us a temperature reduction of 0.000033 degrees C by 2100, an amount far too small to measure.
When announcing the LEV and ZEV regulations, Governor Walz stated the regulations would help "make sure there was still ice on the lake in January," but the administration has offered no credible proof that these regulations would have any measurable impact on Minnesota's climate or ice cover on Minnesota lakes.
Questions MPCA should answer before issuing rules: MPCA claims "In monetary terms, the total GHG reductions achieved by the proposed rule would lead to about $500 million (in 2018 dollars) in avoided climate damages." What is the timescale the agency is assuming the for the avoided damages? By 2100? Which year, specifically? What impact will carbon dioxide emissions reductions have on global temperatures?
No Impact on Traditional Pollutants California car mandates are unlikely to produce any measurable environmental or health benefits because emissions of criteria pollutants from American cars have fallen dramatically in the last four decades.
According to the U.S. Environmental Protection Agency, new passenger vehicles are 98-99 percent cleaner for most tailpipe pollutants compared to the 1960s.38 Technologies have created more efficient engines, and catalytic converters have greatly reduced tailpipe emissions from cars. Furthermore, fuels are much cleaner—lead has been eliminated, and sulfur levels are more than 90 percent lower than they were prior to regulation.
Falling tailpipe emissions are one reason Minnesota has some of the cleanest air in the world. Our air quality easily meets all federal health-based National Ambient Air Quality standards. MPCA data show that neighborhood sources, such as backyard fires, home heating, and dry cleaners, contribute a larger portion of traditional pollutants than on-road vehicles.
MPCA's own analysis shows the California LEV and ZEV mandates will have virtually no impact on the levels of traditional pollutants in Minnesota. In fact, MPCA's addendum to the statement of need and reasonableness (SONAR) document show the agency originally overestimated the impact the rules would have on traditional air pollutants by a factor of ten.
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Furthermore, and U.S. Environmental Protection Agency (EPA) air quality data show the Air Quality Index (AQI) was worse during the shutdown of the economy to stem the spread of COVID-19 in March of 2020 than the previous five-year average even though traffic volumes were down 40 percent. Lastly, a growing body of research indicates that indoor air quality is worse than outdoor air quality.
Minnesota's Air Is Already Clean
We believe the marginal utility of these regulations will be low because, according to the MPCA graph below, our air already meets the most stringent state and federal standards for air quality.
The National Ambient Air Quality Standards are required by law to be set with an adequate margin of safety which is designed to protect even vulnerable populations like children and the elderly.39,40
Pollution from sulfur dioxide, carbon monoxide, and nitrogen dioxide are especially low compared to established benchmarks (See Figure 13).
Figure 13. MPCA data show pollutants are below the most stringent air quality standards established by state and federal agencies.
Annual air quality reports from MPCA corroborate this data. The 2019 edition of "The Air We Breathe" concluded that Minnesota's air quality meets all federal standards and pollution levels are decreasing statewide (See Figure 14).41
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Figure 14. MPCA data show air quality for Minnesota is below federal standards. Even areas with elevated concentrations of some pollutants are below these guidelines.
Particularly noteworthy was MPCA's finding that there were zero "bad air" days in 2017, and in 2018, seven of the nine "bad air" days were caused by smoke from distant wildfires that was transported into Minnesota.
Among emissions sources in Minnesota, MPCA data show neighborhood sources, such as dry cleaners, home heating, backyard fires, etc., are the largest contributors of criteria air pollutants in the state, whereas emissions from vehicles are much lower in comparison (See Figure 15).
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Figure 15. Minnesota's air quality is far below federal limits for most measured emissions. Of these emissions, on-road vehicles constitute 24 percent of the total, which is 31 percent less than those emitted by neighborhood sources.
Center of the American Experiment believes Minnesota has made tremendous progress on improving its outdoor air quality, and this progress should be widely celebrated. Furthermore, MPCAs own SONAR data show the regulations would have no impact on air quality in the state.
MPCA Data Shows Virtually No Change
MPCA's addendum to the SONAR show the original estimates for particulate matter reduction were an order of magnitude too high. The agency now states the rules will avert approximately 0.0125 micrograms per cubic meter (μg/m3) of particulate matter measuring 2.5 micrometers in diameter, referred to as PM2.5, on a statewide average, and 0.03 μg/m3 in BIPOC areas (See Figure 16).
Figure 16. Reductions in PM2.5 will be a small fraction of the health-based standards established by the US EPA to protect vulnerable populations.
These values represent 0.1 percent, and 0.25 percent of the federal health-based standard of 12 μg/m3, respectively. The difference between the air quality in several Minnesota counties before the regulations would be implemented and after their implementation are shown in Figure 17.
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Figure 17. EPA air monitoring data show all of the Minnesota counties listed above have air quality that is at least 4 μg/m3 lower than the health-based standard. This figure assumes all counties will see an improvement of 0.03 μg/m3, the largest reduction estimated by MPCA.
The ALJ should note that each of the Minnesota counties listed in the chart have PM2.5 concentrations that are at least 4 μg/m3 lower than EPA's health-based standards. This means the average statewide reductions in PM2.5 concentrations would be 320 times smaller than the current "buffer" between PM2.5 concentrations and the health-based standards.
Health Benefits of Reducing 0.01 μg/m3
Exhibit O, Table 48 of MPCA's SONAR Addendum asserts that the marginal value of these reductions is worth $161 million - $289 billion in health benefits over the first ten years of implementation (based on a 7 percent discount rate).
We believe MPCA has incorrectly written "billion" instead of "million" because the agency's new estimate for health benefits is 229 times larger than the previous estimate, which was based of PM2.5 concentrations being an order of magnitude larger than the updated SONAR values.
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Even if we assume the savings will range from $161 million to $289 million, the health savings estimated by MPCA are likely overstated because MPCA is incorrectly (non-scientifically) assuming a linear threshold impact from PM exposure.
Using this logic, could we reasonably assume the benefits of being 4 μg/m3 below the current health-based standard is worth $51 billion to $92.5 billion in health benefits? Could we assume that eliminating the remaining ~8 ug/m3 would generate (up to) an additional $185 billion in benefits to Minnesota, on top of the $92 billion they have already received, for a total of $277 billion?
We argue such a calculation would be absurd, especially when we consider the gross state product for Minnesota was $383 billion in 2019.42
The justification for these rules is further diminished by the fact that air quality data from the U.S. EPA shows the Air Quality Index in Minnesota was worse during the COVID-19 shutdowns of 2020, even though state data show there were far fewer vehicles were on our roads.
Worse Air Quality During the COVID-19 Shutdown Despite Less Traffic
In some heavily polluted parts of the world like China and India, the economic shutdowns that resulted from attempts to slow the spread of the COVID-19 virus resulted in cleaner air. However, in Minnesota, the air was actually less clean during Gov. Walz's shutdown than the previous five-year average.
According to data from the U.S. Environmental Protection Agency (EPA) and the Minnesota Department of Transportation (MNDOT) air quality was worse in Hennepin County during the COVID-19 shutdown even though traffic volumes were down around 40 percent.43,44
The first graph shows air quality data from EPA's Air Quality Index in Hennepin County from March 16, 2020 through June 10, 2020. The data show air quality was worse during Governor Walz's shutdown than it was during the previous five-year average. Despite the AQI being higher than the previous five-year average, air quality in Hennepin County was still far below levels that are considered hazardous (See Figure 18).45
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Figure 18. Air quality was slightly worse in April-June of 2020 even though far fewer vehicles were on Minnesota roads.
The AQI for 2020, as shown in the gray line, shows upticks in pollution even though traffic was down by about 40 percent during this time, as shown in Figure 19.
Figure 19. The AQI registered higher pollution levels even though traffic was down 40 percent.
The COVID shutdowns of 2020 provide an important natural experiment on the impact of human behavior on air quality and the limitations of further environmental regulations to improve it.
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If reducing traffic volumes in the Twin Cities area by an average of 40 percent cannot show clear evidence of improvements in air quality, then there is no credible way that MPCA can argue the LEV and ZEV regulations will produce any reductions in future criteria pollution levels, or credibly claim the regulations will prevent hospitalizations, premature death, or lost GDP due to air emissions.
We therefore ask the administrative law judge to disallow MPCA's calculated benefits from reduced NOx, Sox, and PM from their cost-benefit analysis.
MPCA Should Measure, Not Model, Impacts for Vulnerable Communities
MPCA's assertion that the California car mandates will improve air quality most in environmental justice areas where Black, Indigenous, People of Color (BIPOC) live is based on modeling, not measurements. We believe the agency's modeling should be supplemented by air sampling in BIPOC communities to ascertain whether the models are accurately reflecting reality.
Air quality models are wonderful tools that can help scientists see what might happen under a variety of different emissions scenarios and ask interesting questions about how public policy might affect pollution levels, but they are not a substitute for accumulating actual real-world data.
Before imposing expensive regulations on the entire state of Minnesota, MPCA should be required to conduct air quality sampling in accordance with EPA guidelines in vulnerable communities. Such air sampling will provide the agency with the crucial data needed to verify whether its modeling assumptions are correct.
It is important to note that MPCAs rules could unintentionally make air quality worse in BIPOC neighborhoods if its air sampling program does find that these areas to indeed suffer from worse air quality.
The oldest cars on the road emit the most pollutants. By increasing the price of new vehicles, MPCA could be dissuading drivers from purchasing new cars. This could restrict the supply of used vehicles or incentivize repairing, rather than replacing, the oldest models on the road, delaying improvements in air quality.
Indoor Air Quality is Worse than Outdoor Air Quality
The U.S. Environmental Protection Agency states that in the last several years, a growing body of scientific evidence has indicated that the air within homes and other buildings can be more seriously polluted than the outdoor air in even the largest and most industrialized cities.46
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According to EPA, levels of indoor air pollutants are often two to five times higher than outdoor levels, and in some cases, these levels can exceed 100 times that of outdoor levels of the same pollutants.47
Other research indicates that people spend approximately 90 percent of their time indoors. Thus, for many people, the risks to health may be greater due to exposure to air pollution indoors than outdoors.48
In addition, people who may be exposed to indoor air pollutants for the longest periods of time are often those most susceptible to the effects of indoor air pollution. Such groups include the young, the elderly, and the chronically ill, especially those suffering from respiratory or cardiovascular disease.49 Conversely, these groups are also the least likely to be affected by outdoor air quality conditions due to spending the majority of their time indoors.
Interestingly, EPA states "If too little outdoor air enters a home, pollutants can accumulate to levels that can pose health and comfort problems. Unless they are built with special mechanical means of ventilation, homes that are designed and constructed to minimize the amount of outdoor air that can "leak" into and out of the home may have higher pollutant levels than other homes."
Imposing additional LEV and ZEV regulations on the automotive industry will increase costs for consumers but will do little to address the most pressing air quality challenges facing demographics MPCA considers to be among the most vulnerable in the state.
Air Quality Modeling
The U.S. EPA has provided considerable evidence suggesting that indoor air quality is now worse than outdoor air quality. This new pollution paradigm requires that MPCA reconsider its MNRISKS air modeling practices and how it assesses the economic impacts of cumulative air pollution.
For example, the agency writes:
"Having good air quality means fewer missed work and school days and less money spent on air pollution-related illness. The MPCA estimates the overall economic impact of health effects related to air pollution in Minnesota exceeds $30 billion per year."
According to MPCA source documents, the MNRISK model uses risk assessment methods to examine hypothetical individuals that spend their whole life in one community, breathing only that air. Modeled emissions include all air pollution sources in the state of Minnesota, including vehicles, factories, construction equipment, building boilers, residential wood burning, etc.50
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MNRISKS may be suitable for assessing "worst case scenario" impacts, but because they assume people spend an entire lifetime breathing air in the same neighborhood, the assumptions used in the model do not reflect real-world exposure risks. Therefore, we believe MPCA should be required to conduct modeling that attempts to more closely reflect the actual exposure Minnesotans have to pollutants in order to better assess what the health impacts of proposed regulations may be. American Experiment also believes MPCA should improve its risk assessment by using non-linear biphasic dose-response models, including adaptive and dynamic non-linear models (beyond classic threshold models) to enhance the quality of regulatory decisions and the protection of ecological health that were supported by Agathokleous et. Al, in the journal Environmental Pollution.51 In summary, MPCA should make it clear that the premature death and hospitalization figures estimated by MNRISKS likely represent high-end risk scenarios and do not reflect actual values for hospitalizations, premature death, or lost GDP due to air emissions. Furthermore, future regulatory decisions can be improved by using non-linear biphasic dose-response models rather than linear no-threshold modeling. 8. Disparate Impacts on Minority and Low-Income Communities There is great merit in investigating the impact the proposed regulations will have on communities of color and low-income communities, including rural communities in Greater Minnesota.
As such, it is vitally important that MPCA understands that a group of nationally renowned civil rights activists are currently suing CARB because their regulations on greenhouse gas emissions are having disparate negative impacts on low-income and minority neighborhoods.52
The group, known as The Two Hundred, alleges CARB's greenhouse gas emissions regulations are "staggering, unlawful and racist," and contributing to "resegregation," according to an article in Forbes:53
"Top civil rights leaders are suing California for climate policies they say disproportionately harm its poorest residents, particularly Latinos and African Americans.
"California politicians are using anti-racist and environmentalist words to hide the regressive impact of their climate policies on the poor and people of color," said John Gamboa, the co-founder of The Two Hundred, a coalition of prominent civil rights leaders, which filed a lawsuit against the California Air Resources Board (CARB) in Superior Court.
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The suit claims CARB is in violation of the Fair Employment and Housing Act, the California Global Warming and Solutions Act, the California Clean Air Act, and other federal and state laws.
"California’s climate policies guarantee that housing, transportation and electricity prices will continue to rise,” the complaint notes, “while ‘gateway’ jobs to the middle class for those without college degrees, such as manufacturing and logistics, will continue to locate in other states.”
The concerns voiced by the Two Hundred regarding the negative impact of CARB’s policies on disadvantaged communities will likely occur in Minnesota because the Walz administration is adopting identical policies.
The proposed regulations affecting Minnesotans would be drafted by CARB, the agency being sued by The Two Hundred. Because the Clean Air Act (CAA) requires states wishing to adopt California’s standards to do so exactly, Minnesota has no flexibility within the rules to adopt Minnesota-specific changes that may help mitigate the negative impacts CARB’s policies are inflicting on Latino and African American communities in California.
Secondly, as stated in previous sections, auto-dealers in Colorado have estimated these regulations would increase the cost of vehicles by $2,00 to $2,500 per vehicle. Such price increases would disproportionately harm low-income families, as George Lefcoe, a professor of law at the University of Southern California stated in Forbes:
“Lefcoe, who is not involved in the case, said the lawsuit’s challenge to transportation policies is particularly powerful. “Automobiles are the survival mechanism for low- income people,” noted Lefcoe. “If you try to increase the cost of automobiles, you hurt low-income people.”
Regardless of intent, rising automobile prices will harm low-income people the most.
LEV and ZEV rules are problematic because the benefits of these new, lower-emitting vehicles would disproportionately accrue in affluent, majority-Caucasian neighborhoods.
Data from the federal Energy Information Administration show 67 percent of EVs purchased in the United States were bought by households earning more than $100,000 per year.54 Only three percent of households earning less than $25,000 owned an electric vehicle, and fewer than five percent of households earning between $25,000 and $50,000 owned an EV (See Figure 20).
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Figure 201. EV ownership is highest among demographics earning more than $100,000 per year.
Additionally, research conducted by professors at Morgan State University studying the socio- demographic attributes of EV owners concluded that 85 percent of EV owners are white, and that “EV owners are white males who are more educated, affluent, older, and more environmentally focused than are owners of internal combustion engine vehicles.55 EVs were most popular among Democrats and least among those not interested in politics.”
The proposed LEV and ZEV regulations will make ICEVs more expensive, and the long payback period for these more fuel-efficient cars could incentivize car buyers to keep their cars longer than they normally would if new cars were less expensive. This could have an unintended effect of shrinking the secondary car market and raising prices for low-income households who have fewer resources available to commit to purchasing a new-to-them vehicle.
It is difficult to see how these proposed regulations will have a positive impact on minority or low-income communities. Access to affordable private transportation is a crucial part of empowering these demographics to seize economic opportunities wherever they may arise. Artificially inflating the cost of getting to work or school will have demonstrable, negative impacts for these communities. The vast majority of environmental benefits would accrue in affluent, mostly-white areas.
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9. There is no legal basis to implement LEV and ZEV rules under Minnesota Law
Section 177 of the Federal Clean Air Act allows other states to adopt California’s more stringent auto emissions standards, but the Legislature has not granted statutory authority to MPCA to enact these rules, which are legally required. In fact, the Legislature specifically decided not to pass such legislation at least twice, in 2007 and 2008. Moreover, the Federal EPA has withdrawn the rule authorizing the adoption of the California standards, effective November 18, 2019.
Gov. Walz and MPCA have cited the Next Generation Energy Act (NGEA), Minnesota statute 216H.02, subd. 1, which establishes a statewide goal “to reduce statewide greenhouse gas emissions across all sectors producing those emissions to a level at least 15 percent below 2005 levels by 2015, to a level at least 30 percent below 2005 levels by 2025, and to a level at least 80 percent below 2005 levels by 2050,” as justification for the rules, but these are non-binding goals. They are not requirements and no rulemaking authority is granted in that Act.
For these reasons, and in the reasons provided in CAE’s other comments through counsel, it is likely that the proposed rules, if enacted, would not withstand a legal challenge.
10. Conclusions
Adopting LEV and ZEV regulations promulgated by CARB will have measurable, negative economic impacts for the state of Minnesota, and will make driving less accessible for many low-income Minnesotans and reduce passenger safety. While the negative economic and public health impacts are tangible, the environmental and public health benefits of this rule are immeasurably small.
Increasing the cost of vehicles has an outsized negative impact on minority and low-income communities because LEV and ZEV ownership will skew toward predominantly wealthy and white areas. This could lead to the gap in environmental quality growing between neighborhoods, even if overall air quality improves.
For all of the foregoing reasons, Center of the American Experiment respectfully requests that the ALJ find the LEV and ZEV regulations proposed by the Walz administration and MPCA be unneeded and unreasonable.
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Respectfully submitted,
John Hinderaker President Center of the American Experiment [email protected]
Isaac Orr Policy Fellow Center of the American Experiment [email protected]
1 Office of Governor Gavin Newsom, “Governor Newsom Announces California Will Phase Out Gasoline-Powered Cars & Drastically Reduce Demand for Fossil Fuel in California’s Fight Against Climate Change, September 23, 2020, https://www.gov.ca.gov/2020/09/23/governor-newsom-announces-california-will-phase-out-gasoline-powered- cars-drastically-reduce-demand-for-fossil-fuel-in-californias-fight-against-climate- change/#:~:text=SACRAMENTO%20%E2%80%93%20Governor%20Gavin%20Newsom%20today,passenger%20vehi cles%20to%20be%20zero%2D
2 Auto Alliance, “Autos Drive Minnesota Forward,” State Facts, Accessed December 2, 2019, https://autoalliance.org/in-your-state/MN/pdf/?export. 3 EV Hub, “State Registration Data, Minnesota,” February 1, 2020, https://www.atlasevhub.com/materials/state- ev-registration-data/. 4 Russ Mitchell, “Electric Vehicle Sales Are Up Sharply In California, Mostly Due to Teslsa,” The Los Angeles Times, September 11, 2019, https://www.latimes.com/business/story/2019-09-10/ev-electric-car-sales-california-tesla. 5 Yeon Baik Et Al., “Making Electric Vehicles Profitable,” McKinsey & Company,” Automotive and Assembly,” March 8, 2019, https://www.mckinsey.com/industries/automotive-and-assembly/our-insights/making-electric-vehicles- profitable#. 6 James Temple, “Why the Electric-Car Revolution May Take a Lot Longer Than Expected,” MIT Technology Review, November 19, 2019, https://www.technologyreview.com/s/614728/why-the-electric-car-revolution-may-take-a- lot-longer-than-expected/. 7 James Temple, “Why the Electric-Car Revolution May Take a Lot Longer Than Expected,” MIT Technology Review, November 19, 2019, https://www.technologyreview.com/s/614728/why-the-electric-car-revolution-may-take-a- lot-longer-than-expected/. 8 Rob Stumpf, “Americans Cite Range Anxiety, Cost as Largest Barriers for New EV Purchases: Study,” The Drive, February 26, 2019, https://www.thedrive.com/news/26637/americans-cite-range-anxiety-cost-as-largest-barriers- for-new-ev-purchases-study.
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9 Jim Gorzelany, “Eight Models Can Now Run for More Than 200 Miles on a Charge, With Many More on the Way,” MYEV.com, Accessed December 2, 2019, https://www.myev.com/research/comparisons/the-longest-range- electric-vehicles-for-2019.
10 Kelley Blue Book, “10 Longest-Range Electric Cars of 2019, accessed December 2, 2019, https://www.kbb.com/car-reviews-and-news/top-10/longest-range-electric-cars/2100006708/?slide=3. 11 Tom Krisher, “AAA: Cold Weather Can Cut Electric Car Range By 40 Percent,” Associated Press, February 7, 2019, http://www.startribune.com/aaa-cold-weather-can-cut-electric-car-range-by-40-percent/505489192/. 12 Paul A. Eisenstein, “Tesla, Jaguar and Nissan EVs Lose Range in Freezing Temps As Polar Vortex Leaves Electric Vehicles Out in the Cold,” CNBC, February 5, 2019, https://www.cnbc.com/2019/02/05/tesla-jaguar- and-nissan-evs-lose-power-in-freezing-temps-.html.
13 AAA, “AAA Electric Vehicle Range Testing,” American Automobile Association, February 2019, https://www.aaa.com/AAA/common/AAR/files/AAA-Electric-Vehicle-Range-Testing-Report.pdf. 14 Rachel Becker, “California Says it Won’t Buy Cars from GM, Toyota, Others Opposing Tough Tailpipe Standards,” Calmatters, November 15, 2019, https://calmatters.org/environment/2019/11/california-says-it-wont-buy-cars- from-gm-toyota-others-opposing-tough-fuel-standards/. 15 Brady Slater, “DTA Temporarily Pulls Electric Buses,” Duluth News Tribune, December 12, 2018, https://www.duluthnewstribune.com/news/4542279-dta-temporarily-pulls-electric-buses. 16 Janet Moore, “Biodiesel, Not Electric, Buses May Join Metro Transit Fleet,” Minneapolis Star-Tribune, March 3, 2021, https://www.startribune.com/biodiesel-not-electric-buses-may-join-metro-transit-fleet/600029359/. 17 U.S. Department of Energy, “Diesel Vehicles Using Biodiesel,” Alternative Fuels Data Center, Accessed March 8, 2021, https://afdc.energy.gov/vehicles/diesel.html. 18 Janet Moore, “Metro Transit Temporarily Pulls Electric Buses From C Line Because of Problems with Chagers,” The Minneapolis Star Tribune, October 3, 2019, http://www.startribune.com/metro-transit-pulls-electric-buses- from-c-line-temporarily-due-to-charging-issue/562114192/?refresh=true. 19 Alon Levy, “The Verdict’s Still Out on Battery-Electric Buses,” City Journal, January 17, 2019, https://www.citylab.com/transportation/2019/01/electric-bus-battery-recharge-new-flyer-byd-proterra- beb/577954/. 20 Auto Alliance, “Autos Drive Minnesota Forward,” State Facts, Accessed March 10, 2021, https://autoalliance.org/in-your-state/MN/pdf/?export. 21 Keith Naughton, “The Next American Car Recession Has Already Started,” Bloomberg, January 14, 2019, https://alabamanewscenter.com/2019/01/14/next-american-car-recession-already-started/. 22 Johnna Crider, “Top U.S. Electric Vehicles- 2019 Vs. 2018 Best Sellers,” Clean Technica, February 12, 2020, https://cleantechnica.com/2020/02/12/top-u-s-electric-vehicles-2019-vs-2018-best-sellers/. 23 EV Hub, “State Registration Data, Minnesota,” February 1, 2020, https://www.atlasevhub.com/materials/state- ev-registration-data/. 24 Office of Governor Tim Walz and Lt. Governor Peggy Flanagan, “Governor Tim Walz Announces Clean Car Standards in Minnesota,” State of Minnesota, September 25, 2019, https://mn.gov/governor/news/?id=1055- 403887 25 Minnesota Pollution Control Agency, “Statement of Reasonableness and Need,” December 21, 2020, Revisor ID No. 04626, Page 71, https://www.pca.state.mn.us/sites/default/files/aq-rule4-10m.pdf. 26 Energy Ventures Analysis, “A Review of the Final Economic Impact Analysis in Support of CLEAR,” October 24, 2018, https://www.eenews.net/assets/2019/03/14/document_gw_10.pdf.
27 Auto Alliance, “Autos Drive Minnesota Forward,” State Facts, Accessed December 2, 2019, https://autoalliance.org/in-your-state/MN/pdf/?export. 28 Auto Alliance, “Autos Drive Minnesota Forward,” State Facts, Accessed December 2, 2019, https://autoalliance.org/in-your-state/MN/pdf/?export.
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2929 James Temple, “Why the Electric-Car Revolution May Take a Lot Longer Than Expected,” MIT Technology Review, November 19, 2019, https://www.technologyreview.com/s/614728/why-the-electric-car-revolution-may- take-a-lot-longer-than-expected/. 30 Autoblog, “EV Rollout Will Require Huge Investments in Strained U.S. Power Grids,” March 7, 2021, https://www.autoblog.com/2021/03/07/ev-power-grid-us-investment-needed/?ncid=txtlnkusaolp00000618/
31 Mike Hughlett, “Xcel’s Minnesota Customers Will Pay More Next Year- The Question is How Much?” Minneapolis Star Tribune, November 2, 2020, https://www.startribune.com/xcel-s-minnesota-customers-will-pay-more-next- year-the-question-is-how- much/572949642/#:~:text=Xcel%20is%20asking%20for%20a,small%20business%20customers%20by%20%241.50.
32 Isaac Orr and Mitch Rolling, “Center of the American Experiment Comments on Xcel Energy’s Proposed Integrated Resource Plan, Docket No. E-002/RP-19-368, February 10, 2021. 33 Mai, Trieu Et Al., “Electrification Futures Study,” National Renewable Energy Laboratory, June 2018, https://www.nrel.gov/docs/fy18osti/71500.pdf. 34 Autoblog, “EV Rollout Will Require Huge Investments in Strained U.S. Power Grids,” March 7, 2021, https://www.autoblog.com/2021/03/07/ev-power-grid-us-investment-needed/?ncid=txtlnkusaolp00000618/ 35 @JesseJenkins, “Wind is reliably unreliable, and the system operators and everyone else knows that. So we plan around it. The real failure is to plan around the likelihood of simultaneous thermal plant outages. That’s my point.” Twitter, February 16, 2021, https://twitter.com/JesseJenkins/status/1361764659288801287. 36 U.S. Energy Information Administration, “Midcontinent independent Systems Operator, Inc. Electricity Generation By Energy Source 2/5/2021-2/24/2021, Central Time, Hourly Market Monitor, Accessed March 10, 2021, https://www.eia.gov/beta/electricity/gridmonitor/expanded- view/electric_overview/balancing_authority/MISO/GenerationByEnergySource-14/edit. 37 Zeke Hausfather, “Factcheck: How Electric Vehicles Help to Tackle Climate Change,” Carbon Brief, May 13, 2019, https://www.carbonbrief.org/factcheck-how-electric-vehicles-help-to-tackle-climate- change#:~:text=The%20IVL%20researchers%20now%20estimate,comes%20from%20zero%2Dcarbon%20sources.. 38 U.S. Environmental Protection Agency, “History of Reducing Pollution from Transportation in the United States,” Accessed November 26, 2019, https://www.epa.gov/transportation-air-pollution-and-climate- change/accomplishments-and-success-air-pollution-transportation. 39 Minnesota Pollution Control Agency, “Criteria Pollutant Data Explorer,” Explore Interactive Air Monitoring Data, Accessed November 26, 2019, https://www.pca.state.mn.us/air/criteria-pollutant-data-explorer.
40 Cornell Law School, “42 U.S. Code § 7409 - National Primary and Secondary Ambient Air Quality Standards,” Accessed March 9, 2021, https://www.law.cornell.edu/uscode/text/42/7409.
41 Todd Biwen, “The Air We Breathe: The State of Minnesota’s Air Quality 2019,” Minnesota Pollution Control Agency, Accessed November 26, 2019, https://www.pca.state.mn.us/sites/default/files/lraq-1sy19.pdf. 42 Federal Reserve Bank of St. Louis, “Total Gross Domestic Product for Minnesota,” October 2, 2020, https://fred.stlouisfed.org/series/MNNGSP. 43 U.S. EPA, “Outdoor Air Quality Data, Hennepin County,” Accessed February 12, 2021, https://www.epa.gov/outdoor-air-quality-data/air-data-daily-air-quality-tracker. 44 Metropolitan Council, “COVID-19 (Coronavirus) Outbreak- Metro Area Travel,” Accessed February 12, 2021, https://metrocouncil.org/Transportation/Planning-2/Transit-Plans,-Studies-Reports/Highways-Roads/COVID- 19.aspx. 45 Isaac Orr, “Air Quality Was Worse During COVID Shutdown Despite Far Fewer Cars on the Road, Data Shows,” Center of the American Experiment, July 9, 2020, https://www.americanexperiment.org/2020/07/air-quality-was- worse-during-covid-shutdown-despite-far-fewer-cars-on-the-road-data-show/. 46 U.S. Environmental Protection Agency, “The Inside Story: A Guide to Indoor Air Quality,” Accessed November 27, 2019, https://www.epa.gov/indoor-air-quality-iaq/inside-story-guide-indoor-air-quality. 47 Medical Associates of Northwest Arkansas, “Indoor Air vs. Outdoor Air,” Accessed November 27, 2019, https://www.mana.md/indoor-air-vs-outdoor-air/. 45
48 U.S. Environmental Protection Agency, “The Inside Story: A Guide to Indoor Air Quality,” Accessed November 27, 2019, https://www.epa.gov/indoor-air-quality-iaq/inside-story-guide-indoor-air-quality. 49 U.S. Environmental Protection Agency, “The Inside Story: A Guide to Indoor Air Quality,” Accessed November 27, 2019, https://www.epa.gov/indoor-air-quality-iaq/inside-story-guide-indoor-air-quality. 50 Todd Biwen, “The Air We Breathe: The State of Minnesota’s Air Quality 2019,” Minnesota Pollution Control Agency, Accessed November 26, 2019, https://www.pca.state.mn.us/sites/default/files/lraq-1sy19.pdf. 51 Agathokleous et. Al, “Commentary: EPA’s Proposed Expansion of Dose-Response Analysis is a Positive Step Towards Improving its Ecological Risk Assessment,” Environmental Pollution, March 2019, https://www.sciencedirect.com/science/article/pii/S0269749118343811#!. 52 Attorneys for Plaintiffs/Petitioners the Two Hundred, et al., “The Two Hundred vs. The California Air Resources Board,” SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF FRESNO UNLIMITED CIVIL JURISDICTION, https://static1.squarespace.com/static/56a45d683b0be33df885def6/t/5b9a834bc2241b0df2116e0a/1536852818 109/200+Lawsuit+Petition+%28as+filed%29.pdf.
53 Michael Shellenberger, “Sweeping Civil Rights Lawsuit Alleges Racial Bias In Implementation Of California Climate Policies, Forbes, September 13, 2018, https://www.forbes.com/sites/michaelshellenberger/2018/09/13/sweeping- civil-rights-lawsuit-alleges-racial-bias-in-implementation-of-california-climate-policies/#38f87e983c07.
54 U.S. Energy Information Administration, “Electrified vehicles continue to see slow growth and less use than conventional vehicles,” Today in Energy, May 22, 2018, https://www.eia.gov/todayinenergy/detail.php?id=36312.
55 Farkas et. Al, “Environmental Attributes of Electric Vehicle Ownership and Commuting Behavior in Maryland: Public Policy and Equity Considerations,” Morgan State University, August 2018, https://www.morgan.edu/Documents/ACADEMICS/CENTERS/NTC/Environmental%20Attributes%20of%20Electric %20Vehicle%20Ownership%20and%20Commuting%20Behavior%20in%20Maryland%20- %20Public%20Policy%20and%20Equity%20Considera.pdf.
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Drew Lyon Attachment
The Minnesota Soybean Growers Association (MSGA) would like to share our severe reservations regarding the Minnesota Pollution Control Agency's proposed Clean Cars Minnesota rulemaking (OAH docket number 71-9003-36416). MSGA is opposed to the State of Minnesota implementing another state’s green-house gas reduction goals. MSGA is also opposed to the use of rulemaking to enact this rule without the robust discussions that occur during the robust legislative process. Simply put: There is not room in One Minnesota for California. Minnesota has been a leader in reducing greenhouse gas emissions (GHG) through our own rules and regulations and should remain a leader, not a follower in this arena. Tying Minnesota to the California system and Clean Air Act (CAA) waiver system will result in needless rulemaking in the future.
The MPCA argues that the rule will not impact biofuels, and therefore farm groups should not be concerned about the rule. MSGA disagrees with this assertion. We feel the rule sets Minnesota on a path where electric cars are considered the only answer to GHG reduction goals. California has already announced this intention with proclamations by their governor on goals to stop selling combustion engines. The SONAR cites new rules and standards adopted by the Trump administration as the reason that they need to act to maintain a reduction in GHG emissions. The SONAR ignores and does not address the election of Joe Biden as president and his announcement in January that he will act to reverse the very decisions that MPCA cites as the reason Minnesota must act. The SONAR’s own graphics show reductions in transportation and other sectors GHG emissions. The undoing of the Trump administration’s actions makes this rulemaking unnecessary.
Unlike California, which has four separate electric car company’s world headquarters in their state, Minnesota is not the home of a single electric car company. Minnesota is, however, home to nearly 28,000 soybean farmers and three biodiesel plants. California does not produce anywhere near the amounts of soybeans that Minnesota does. Minnesota has been sued for our efforts in mandating Biodiesel in our fuel supply because of the GHG benefits and preemption by the CAA. This lawsuit was defended by the Minnesota Attorney General who described the Biodiesel Mandate not as a GHG statute, but a rural economic development program with GHG benefits. Minnesota won that lawsuit, and our mandate was upheld. Now MPCA appears to be prepared to work towards efforts that will hurt these economic wins in our state and shift those wins to California car companies.
MSGA is frustrated to see an agency, MPCA, that has been a primary opponent of blends over 20% biodiesel now pass over a proven GHG reduction solution in favor of technologies less proven to help with long term environmental issues. This rule does not account for the problems of where these electric car batteries will end up when they are no longer in service. It does not account for the environmental damage done in the mining industry done for necessary elements of these batteries. MPCA clings to old data on biofuels and ignores huge advances in biofuels production that lowers their carbon footprint.
One of our biodiesel plants ran calculations based on proven methods to illustrate this emissions reduction from the use of biodiesel. Renewable Energy Group found, “Here’s how much higher GHG emissions are for other fuel choices, compared to REG B100 (100% biodiesel): 580% higher with petroleum diesel: 435% higher with compressed natural gas; 195% higher with an electric vehicle with natural gas-derived electricity.” Transesterification is the main chemical reaction used to create biodiesel from any vegetable oil or waist cooking oils. This reaction requires energy to drive the reaction. In a traditional transesterification reactor, the feedstock is heated from 70 deg F (on average) to 145 deg F. The amount of natural gas needed to perform this heating on 1M gallons of feedstock is approximately 263,000 cubic feet. This is the process used in the REG plant, which leads to the huge reductions in GHG over other fuel choices in their example.
In comparison, the Plasma Blue technology, created with research dollars from Minnesota’s soybean checkoff, greatly reduces the energy used to produce Biodiesel. Plasma Blue’s units can make the same 1mMillion gallons of biodiesel with using the same electricity needed to power two 60-watt light bulbs. This amount of power can be easily created from a solar cell the size of a standard dining room table. These gains in reduction of GHG with biodiesel will greatly increase the benefits seen from burning biodiesel in vehicles in Minnesota. MPCA, however, overlooks these potential GHG reduction gains in their SONAR and advances one solution.
This rule is not necessary. The SONAR looks at one solution and does not consider other options. The SONAR fails to address new directions the Biden administration is taken. It fails to look at the impact of more demand on a “dirty” grid will have that may exacerbate climate change. The MPCA has not shown that this rule is reasonable. The SONAR does not describe how the rule and switch to electric cars will have a direct impact on the climate change driven effects Minnesota is feeling. MPCA admits neighboring states are not moving in this direction. With Green House gases not recognizing state borders, there is no proof in the SONAR that Minnesota’s actions will help Minnesota other than by meeting arbitrary goals.
Rulemaking is not the forum for these type of changes in State Law. MSGA and the State have directly different opinions on key definitions involved in the California Air Resources Board and their rulemaking. MN fought efforts to attack our Biodiesel mandate and adopted a position that soybean oil is a waste oil and a drag on the soy crush industry in the state. California calls soybean oil a human food product in direct opposition to MN’s position. By using the rulemaking process, this rule is not being vetted as thoroughly as it should be and these differences are not being discussed.
MSGA has been advocating for the use of Biodiesel in the state’s fuel supply for decades. Biodiesel was the first fuel named an advanced biofuel by the U.S. Environmental Protection Agency based on its ability to GHG by more than 50% compared with petroleum. The agricultural community hasn’t rested on our laurels with this level of reduction. The SONAR does not address any of these new technologies as a way to meet our GHG emission goals. They did not consider any other option than to adopt a California electric vehicle mandate. As discussed above, biofuels technologies are advancing and making these fuels more and more beneficial in their GHG reduction. The Biden administration’s EPA will surely be on a different trajectory than the Trump administration. California has already announced an intention to change their rule. All of these are very compelling reasons to stop the processes of adopting a rule that will be obsolete in the near future. MSGA opposes the adoption of this rule.
Jamie Beyer
President, Minnesota Soybean Growers Association Elizabeth Van Holt Attachment
March 15, 2021 Subject: 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
The American Fuel & Petrochemical Manufacturers (AFPM)1 and the American Petroleum Institute (API)2 support Minnesota’s goal to reduce greenhouse gas (GHG) emissions from the transportation fleet. We are committed to delivering solutions that reduce emissions while meeting society's growing energy needs and we seek to work with policymakers, including the Minnesota Pollution Control Agency (MCPA), on outlining policy options and balanced approaches.3 Minnesota should not adopt California’s zero emission vehicle (ZEV) mandate because it’s expensive for the consumer and ZEV mandates are among the least effective, most costly GHG abatement measures available. When viewed on a lifecycle basis, it becomes clear that electric vehicles (EVs)4 are not zero emission vehicles because they are responsible for significant amounts of GHGs and other pollutants during their lifecycle, including large amounts of GHGs associated with battery production and electricity generation necessary for charging. On top of making cars more expensive, the ZEV mandate will require electricity grid and infrastructure upgrades ultimately paid for by all Minnesotans including those who never drive an EV. California’s car plan is not suited for Minnesota for another reason: BEVs experience significant range decreases in the cold weather common to Minnesota. Despite these high costs and operability challenges, the proposal will not make a meaningful impact in the global
1AFPM is a national trade association that represents American refining and petrochemical companies. These companies directly and indirectly provide jobs, contribute to economic and national security, and enable the production of products used by families and businesses in Minnesota and throughout the United States. 2The API represents all segments of America’s natural gas and oil industry, which supports more than ten million U.S. jobs and is backed by a growing grassroots movement of millions of Americans. Our 600 members produce, process, and distribute the majority of the nation’s energy, and participate in API Energy Excellence, which is accelerating environmental and safety progress by fostering new technologies and transparent reporting. API was formed in 1919 as a standards-setting organization and has developed more than 700 standards to enhance operational and environmental safety, efficiency, and sustainability. 3 To name just two tangible ideas, cost effective policies and direct regulation can achieve methane emission reductions from new and existing sources across the supply chain and a minimum 95-research octane number (RON) standard, coupled with other reforms, could provide an annual carbon emissions reduction benefit that is equivalent to doubling the number of EVs sold last year in the U.S. and help automakers meet fuel economy standards more economically while preserving consumer choice. 4 We use the term “EV” to include battery electric vehicle (BEV), one with no gasoline powertrain, and plug-in hybrid electric vehicle (PHEV) that includes both an electric and gasoline powertrain. Sometimes authors use the term differently in quoted material. concentrations of GHGs. MPCA should not follow California and instead look for more efficient, less costly, and more appropriately tailored approaches for Minnesota across all sectors and that, in transportation, allows all efficient vehicle technologies to compete on a level playing field. AFPM and API Want to Reduce Emissions, Serve Customer Needs, and Support the Economy Any emission reduction program should recognize that all forms of energy, including petroleum and biofuels, are needed today and in the foreseeable future. Affordable, reliable, and abundant energy is essential to sustaining human health and wellbeing while simultaneously building a more equitable economy and improving the standard of living for Minnesotans and the world. Given the view that natural gas and oil will likely continue to provide a significant portion of our nation's transportation and power generation needs over the next few decades,5 AFPM and API look forward to working with Minnesota to drive meaningful emission reductions. The natural gas, oil, and petrochemical industry supports more than 171,000 jobs, or more than 4.5 percent of Minnesota’s total employment.6 Importantly, in 2019, traditional energy sectors including fuels, generation, and transmission, distribution, and storage, added 65,000 new jobs, producing oil, natural gas, electricity from many sources, and the systems that distribute them.7 The industry, including AFPM and API members, provides more than $11.4 billion in labor income and contributes more than $23 billion to the state economy. Many of our members’ employees call Minnesota home. The U.S. has led the world in reducing carbon dioxide emissions to generational lows since 2000, thanks in large part to greater use of natural gas in electricity generation and advancements in technology and innovation, including in transportation. Pending approval by the Minnesota Public Utilities Commission, Xcel Energy plans to increase its generation mix from 13 percent natural gas in 2020 to 25 percent natural gas in 2034 and bring on a new natural gas fired plant on the site of a decommissioned coal burning plant.8 While BEVs represent an alternative to internal combustion engine vehicles (ICEVs) this technology does not satisfy the full range of vehicle performance and design attributes preferred by consumers, as confirmed by the sales data representing the mix of vehicles sold. The current status of the technology is not sufficiently developed for use in all applications, many of which are common in Minnesota, and as such should not be mandated. Fuels and Vehicles are Much More Efficient and Can Continue to Improve Our industry will continue to provide and enable improvements in transportation efficiency. We have an established track record in this regard, and we recognize that more work
5 See U.S. Energy Information Administration’s (EIA) 2021 Annual Energy Outlook. 6 See “Impacts of the Natural Gas, Oil and Petrochemical Industry on the US Economy in 2018,” prepared for American Petroleum Institute, May 2020, prepared by PwC, www.pwc.com/us/nes. 7 See “2020 U.S. Energy & Employment Report,” A Joint Project of NASEO & EFI, . 8 See “How does a utility turn a net-zero vision into reality? That’s what they’re arguing about in Minnesota,” Inside Climate News, https://insideclimatenews.org/news/17022021/xcel-energy-utility-minnesota-net-zero-natural-gas- renewables/.
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needs to be done to build on improvements that are continuing to occur as cleaner vehicles, enabled by low sulfur fuels, penetrate the fleet.9 New passenger vehicles are 99 percent cleaner for most tailpipe pollutants compared to 1970.10 Advancements in ICEV efficiency have helped to reduce carbon dioxide emissions11 from the transportation sector over the last few decades. Since 1975, efficiency has nearly doubled while horsepower has increased over 75 percent, indicating internal combustion engine innovation is robust and can deliver more power and more efficiency (and potentially even more efficiency if consumers desire less power).12
Just since 2004, the fuel economy of new cars, trucks, and SUVs has increased 29 percent, and their related carbon dioxide emissions have dropped 24 percent,13 due in large part to greater industry investment in lightweight vehicle technologies. Vehicles are lighter now relative to their size thanks to these technologies. Further, the refining industry has reduced the annual average sulfur content of gasoline from 30 parts per million (ppm) to10 ppm in accordance with the fuel property requirements in the U.S. Environmental Protection Agency’s (EPA) Tier 3 rulemaking which were implemented on January 1, 2017. The reduction in gasoline sulfur content has lowered emissions from the on-
9 U.S. Environmental Protection Agency, 2014, “Final Rule for Control of Air Pollution from Motor Vehicles: Tier 3 Motor Vehicle Emission and Fuel Standards,” see https://www.epa.gov/regulations-emissions-vehicles-and- engines/final-rule-control-air-pollution-motor-vehicles-tier-3. 10 https://www.epa.gov/transportation-air-pollution-and-climate-change/accomplishments-and-success-air-pollution- transportation. 11 https://www.epa.gov/ghgemissions/draft-inventory-us-greenhouse-gas-emissions-and-sinks-1990-2019 12 See EPA Automotive Trends Report, https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P1010U68.pdf 2020, https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P1010U68.pdf, accessed March 13, 2021. 13 See U.S. Environmental Protection Agency, The EPA Automotive Trends Reports, https://www.epa.gov/automotive-trends.
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road fleet in Minnesota and has provided automobile manufacturers the opportunity to develop new more efficient engine technologies. The U.S. Department of Transportation (DOT), National Highway Traffic Safety Administration (NHTSA) studies have concluded that plastics and composite materials – primarily manufactured using petroleum feedstocks – can considerably reduce vehicle weight while still meeting performance and safety requirements.14,15 Research anticipates the continuation of these gains and by 2025, ICEV efficiency will improve by an additional 30 percent16 and by up to 78 percent in 2050.17 Outline of Comments There are numerous additional and multifaceted aspects of the proposal that deserve comprehensive assessment and evaluation. For example, the proposal has not fully addressed and attempted to categorize, much less minimize the potential costs to Minnesotans. In the remainder of our comments, we respectfully request the state to consider the following: I) All vehicles must be compared on a lifecycle basis and holistically considered for their environmental and economic attributes; II) The California program is ill-suited to Minnesota; and III) The MPCA rule is pre-empted by federal law.
I. All Vehicles Should Be Compared on a Lifecycle and Holistic Basis Policymakers should compare the environmental, economic and performance attributes of current conventional vehicle technology versus alternatives such as BEVs when making policy for the transportation sector. It is critical to employ a holistic approach using life-cycle analysis (LCA) that accounts for the vehicle’s emissions over its lifetime, including emissions associated with its production, recharging/refueling, required infrastructure modifications, and end of life disposal options. Every mode of transportation uses energy and impacts the environment. AFPM and API believe that the best approach to achieving Minnesota’s goal to reduce transportation emissions - while ensuring continued access to easy, affordable, and efficient mobility services - is to adopt policies that permit all available fuel/vehicle technologies to compete in the marketplace for the consumer’s resources.
14 See U.S. Department of Commerce, National Technical Reports Library, “Investigation of Opportunities for Lightweight Vehicles Using Advanced Plastics and Composites,” https://ntrl.ntis.gov/NTRL/dashboard/searchResults/titleDetail/PB2013103220.xhtml. 15 See U.S. Department of Transportation, National Highway Traffic Safety Administration, “High-Performance Computing Studies,” https://www.nhtsa.gov/sites/nhtsa.dot.gov/files/documents/812404_computingstudiesreport_v2_0.pdf. 16 A. Elgowainy, et al, Argonne National Laboratory, 2016, “Cradle-to-Grave Lifecycle Analysis of U.S. Light-Duty Vehicle-Fuel Pathways: A Greenhouse Gas Emissions and Economic Assessment of Current (2015) and Future (2025-2030) Technologies.” See https://greet.es.anl.gov/publication-c2g-2016-report. 17 On The Road Toward 2050: Potential For Substantial Reductions in Light-Duty Vehicle Energy Use and Greenhouse Gas Emissions. Massachusetts Institute Of Technology Sloan Automotive Laboratory, Engineering Systems Division, 2021, http://web.mit.edu/sloan-auto-lab/research/beforeh2/otr2050/. Accessed 15 Mar 2021.
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A sole reliance on vehicle tailpipe GHG emissions measurements will result in an incomplete and insufficient evaluation of the environmental performance of different powertrain technologies. A. Environmental Considerations There is no such thing as a zero-emission vehicle.18 Significant GHGs are emitted during the lifecycle of a BEV. A lifecycle perspective is required to understand any potential mitigation achieved by BEVs, since emissions are not eliminated, but rather shifted upstream in the fuel cycle (to the power plant) and potentially increased in the vehicle production supply chain. Proponents of BEV mandating proposals sometimes disingenuously describe BEVs as “zero” emission vehicles that justify government mandates, subsidies, and credits. A close examination of the LCA carbon emissions on the basis of both ICE and BEV automobiles reveals this is not true. Failure to quantify these real world GHG emissions is an issue of central relevance to this rulemaking and such a quantification must be undertaken before advancing the rulemaking. Scientists confirm that the carbon intensity of battery manufacturing has a large contribution to the lifecycle carbon emissions of the vehicle.19 Furthermore, studies show that the carbon reductions realized over the lifetime of operating an electric vehicle vary depending on the carbon intensity of the electric grid where the vehicle is used.20, 21, 22, 23 As discussed in greater detail below, Minnesota currently generates about 25 percent of its electricity from high carbon intensity coal-fired power plants.24 As a result, the carbon profile of both the BEV and the ICE over the production, operation, and disposal of the vehicle may not be that different in Minnesota, and any carbon reduction benefits from forcing consumers to shift to BEVs potentially come at an unacceptably high cost, so MPCA must address the BEV lifecycle to make a fully informed decision. Part of that lifecycle analysis will need to be an estimate of how much EVs are driven.
The UC-Davis study also noted that there are multiple regions, including Minnesota, where EVs actually increase GHG emissions.25 It is important to note that MPCA should
18 See “Slow Down: The Case for Technology Neutral Transportation Policy,” ConservAmerica, https://static1.squarespace.com/static/5d0c9cc5b4fb470001e12e6d/t/5fd1580999fe644e8a504a54/1607555090612/C A+Tech+Neutral+Paper+-+12.20+%281%29.pdf. 19 One fifth to one third of vehicle lifecycle GHG emissions. 20 See Tamayao M-A M, Michalek J, Hendrickson C and Azevedo I M L 2015 Regional variability and uncertainty of electric vehicle life cycle CO2 emissions across the United States Environ. Sci. Technol. 49 8844–55, Macpherson N D, Keoleian G A and Kelly J C 2012 Fuel economy and greenhouse gas emissions labeling for plug- in hybrid vehicles from a life cycle perspective J. Ind. Ecol. 16 761–73. 21 Onat N C, Kucukvar M and Tatari O 2015 Conventional, hybrid, plug-in hybrid, or electric vehicles? State-based comparative carbon and energy footprint analysis in the United States Appl. Energy 150 36–49. 22 Michalek J, Chester M, Jaramillo P, Samaras C, Shiau C-S N and Lave L B 2011 Valuation of plug-in vehicle life-cycle air emissions and oil displacement benefits Proc. Natl Acad. Sci. USA 108 16554–8. 23 Macpherson N D, Keoleian G A and Kelly J C 2012 Fuel economy and greenhouse gas emissions labeling for plug-in hybrid vehicles from a life cycle perspective J. Ind. Ecol. 16 761–73. 24 See U.S. Energy Information Administration, “State Profile and Energy Estimates: Minnesota,” https://www.eia.gov/state/?sid=MN#tabs-4. 25 J. Archsmith, James et al. "From Cradle To Junkyard: Assessing The Life Cycle Greenhouse Gas Benefits Of Electric Vehicles". Research In Transportation Economics, vol 52, 2015, pp. 72-90. Elsevier BV, doi:10.1016/j.retrec.2015.10.007. Figure 9.
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consider any environmental benefit from purported savings per mile must also accurately project how (and how much) BEVs will be used. Will they be replacements for gasoline and diesel- powered vehicles or an “extra” car for the affluent?26 Any net emissions abatement benefits from BEVs depend primarily on two key factors: 1) the marginal source of electricity generation,27 which depends on the composition of the electricity grid; and 2) the effect of ambient temperatures on the efficiency of charging and discharging batteries. In both factors, Minnesota and California are disparate.28 The same UC- Davis study found that in areas with warm temperatures and a relatively clean electricity grid, like California, EVs provide GHG abatement gains relative to a comparable ICE. But in regions with cold temperatures and higher-emitting marginal electricity generation technology, like Minnesota, EVs could increase GHG emissions by 25-30 percent by 2030.29 A recently completed research review by ConservAmerica (ConservAmerica Review) examines five unique studies that assess the GHG emissions from a variety of powertrain technologies.30 Each study uses an LCA approach to analyze the vehicles emissions based upon “… vehicle size and performance, battery size and lifetime, the carbon intensity of electricity generation and fuel production, and the state of technology advancements.” Recognizing these differences, the review concludes that “a variety of automotive technologies and powertrains deliver comparable GHG emission reductions,”31 and that all vehicle technologies should be examined based on the entire lifecycle of the vehicle and their energy sources as all vehicles produce GHG emissions. There is a substantial body of research that suggests the adoption of policies to promote ZEVs will not likely yield significant reductions in transportation sector GHG emissions, especially in the near term.32,33,34
26 EIA’s data reveals that households that own BEVs and PHEVs tend to have more vehicles per household, owning 2.7 vehicles compared with the household average of 2.1 vehicles. BEVs and PHEVs also tend to be used about 12% less than other vehicles in terms of annual mileage per vehicle. Further, about one-third of all households have annual incomes higher than $100,000. However, about two-thirds of households with BEVs or PHEVs have incomes higher than $100,000. Taken together, this indicates there is very little evidence that, right now, EVs are viewed as widespread replacements of traditional cars and as such should not be mandated in Minnesota. See U.S. Energy Information Administration, Today in Energy, “Electrified vehicles continue to see slow growth and less use than conventional vehicles,” May 22, 2018. 27 The marginal source of electricity generation is that additional electricity that will come from the lowest cost plant that has spare capacity at that time. 28 Archsmith, James et al. “From Cradle To Junkyard…” 29 Id. Figure 12. 30 ConservAmerica, “Slow Down: The Case for Technology Neutral Transportation Policy,” December 2020. See https://www.conservamerica.org/latest-news/report-highlights-importance-of-policy-neutrality-in-decarbonizing- transportation-sector. 31 ConservAmerica, “Slow Down: The Case for Technology Neutral Transportation Policy,” December 2020. See www.conservamerica.org, pg. 1. 32 IPIECA, “GHG emissions and the cost of carbon abatement for light-duty road vehicles: A compare-and-contrast analysis of public studies.” See www.ipieca.org. 33 International Energy Agency, “World Energy Outlook 2017.” 34 Jonathan Lesser, “Short Circuit: The High Cost of Electric Vehicle Subsidies,” May 2018.
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Current BEV technology presents challenges to the widespread use of BEVs that MPCA has not included in its analysis. Some of these challenges to EV expansion include: battery material sourcing, battery production, emissions generated during operation, disposal of the battery, energy security implications, and an explanation of why a ZEV mandate is not needed to meet NAAQS. All of these challenges may be overcome and when they are, these vehicles will compete on their own accord, but until that time a ZEV mandate could increase the cost of all vehicles and potentially slow environmental progress (section 7). 1. Battery Material Sourcing Lithium-ion batteries are made from critical minerals, including cobalt, graphite, and lithium. One study demonstrates that the steps for extracting and processing critical minerals are responsible for approximately 20 percent of the lifecycle GHG emissions from battery production.35 While GHG emissions from extraction and processing depend upon the fuel source (e.g., electricity, heat, or fossil fuel) for the energy consumed during these activities, mining of selected materials for BEVs typically takes place in countries where environmental, health, and safety precautions are generally less stringent than those in the United States. Mining is an energy- and environmentally-intensive activity. Activities associated with mining produce GHG emissions, as well as particulate matter emissions, nitrogen oxide emissions, and other air pollutant emissions from mining equipment, or generate heat or electricity for processing. 2. Battery Production Scientists confirm that the carbon intensity of battery manufacturing has a large contribution to the lifecycle carbon emissions of the vehicle.36 While production emissions are less than 10 percent of LCA GHG emissions for today’s gasoline vehicles, they account for about 40 percent for a BEV.37 MPCA must consider, like Metro Transit did when evaluating electric buses,38 the need to replace EV batteries over time and the new carbon deficit associated with that requirement. Ultimately, there is no mode of transportation that has “zero emissions” and each technology should be considered on a lifecycle basis to ensure that the best policies to reduce GHG emissions from transportation are developed and implemented. 3. EV Operation Emissions Studies, including those considered in the ConservAmerica Review, show that the carbon reductions realized over the lifetime of operating an electric vehicle vary depending on the carbon intensity of the electric grid where the vehicle is used.39 As for the in-use phase of the
35 H.C. Kim, et al., “Cradle-to-Gate Emissions from a Commercial Electric Vehicle Li-Ion Battery: A Comparative Analysis,” Environmental Science and Technology, vol. 50 (2016), pp. 7715-7722. 36 One fifth to one third of vehicle lifecycle GHG emissions. 37 Hanjiro Ambrose, Alissa Kendall, Mark Lozano, Sadanand Wachche, Lew Fulton, “Trends in life cycle greenhouse gas emissions of future light duty electric vehicles,” Transportation Research Part D: Transport and Environment, Volume 81, 2020, 102287, ISSN 1361-9209, https://doi.org/10.1016/j.trd.2020.102287. 38 See Metropolitan Council Meeting, March 10, 2021, Information Item: Electric Bus Update, Metro Transit (Wes Kooistra, 612-349-7510), https://metrocouncil.org/getdoc/1a2f7a70-cb54-4df1-98d3-17ceb8354f84/Agenda.aspx. 39 See Tamayao M-A M, Michalek J, Hendrickson C and Azevedo I M L 2015 “Regional variability and uncertainty of electric vehicle life cycle CO2 emissions across the United States” Environ. Sci. Technol. 49 8844–55; Onat N C, Kucukvar M and Tatari O 2015 “Conventional, hybrid, plug-in hybrid, or electric vehicles? State-based comparative carbon and energy footprint analysis in the United States” Appl. Energy 150 36–49; Michalek J, Chester M,
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BEV/ICEV lifecycle comparison, it is understood BEVs do not emit GHGs from their tailpipe during operation. Instead, the carbon emissions attributable to EV operation occur throughout the power generation, transmission, and distribution supply chain, including the portion at the powerplant as electricity is consumed during vehicle charging. EIA’s electric power monthly data indicates that about 32 percent of net electricity generation in California came from nonhydroelectric renewable sources and no electricity generated with coal, whereas Minnesota derived 26.8 percent of its electricity from nonhydroelectric renewables and 25 percent from coal. This means that the carbon emissions from operating an EV in Minnesota would be significantly higher than in California, reducing the carbon benefit from EVs in Minnesota.40 One study found all electric vehicles have higher emissions in Minnesota compared to California, due to the effects of regional climate and grid mix on emissions.41 Any analysis of generation should consider imports and exports to determine the mix of electricity actually used within Minnesota, not just that generated in Minnesota. A BEV plugged into a grid supplied primarily by coal will have higher GHG emissions than a grid supplied with less coal generation. Further, the GHG emissions attributable to the BEV will approach those from a hybrid electric vehicle (HEV) even when the BEV is operated in an electric grid supplied by a mix of fossil fuel and renewable sources (i.e., a “lower” emissions grid). The transportation sector accounts for 28 percent of economywide CO2e emissions and light-duty vehicles (passenger cars, SUVs, and light-duty trucks) contribute 59 percent of those emissions. Based on the range of values in the ConservAmerica Review, if BEVs are assumed to be 28 percent to 64 percent more efficient than light-duty ICEVs, then converting all light duty ICEVs to BEVs would (all else being equal) yield a maximum potential reduction in economy- wide GHG emissions that is between 4 percent and 11 percent. However, when a BEV is plugged into a coal fired grid, the emissions will be higher than the ICEV and thus the ZEV mandate will have the opposite effect of that intended and would actually increase GHG emissions. Using the ConservAmerica Review data and an analytical approach similar to the above but for a scenario where the entire Minnesota fleet is assumed to be HEVs, the maximum potential reduction in economy wide GHG emissions would be less than two percent. The agency should quantify exactly what reductions it expects to achieve from this regulation and consider other alternatives to reduce GHG emissions in transportation. MPCA’s existing analysis of carbon reductions from BEVs is deficient in that it does not take into account the
Jaramillo P, Samaras C, Shiau C-S N and Lave L B 2011 Valuation of plug-in vehicle life-cycle air emissions and oil displacement benefits Proc. Natl Acad. Sci. USA 108 16554–8; Macpherson N D, Keoleian G A and Kelly J C 2012 Fuel economy and greenhouse gas emissions labeling for plug-in hybrid vehicles from a life cycle perspective J. Ind. Ecol. 16 761–73. 40 See U.S. Energy Information Administration, “State Profile and Energy Estimates: Minnesota,” https://www.eia.gov/state/?sid=MN#tabs-4, and “State Profile and Energy Estimates: California,” https://www.eia.gov/state/?sid=CA#tabs-4. 41 Tugce Yuksel et al "Effect of regional grid mix, driving patterns andclimate on the comparative carbon footprint ofgasoline and plug-in electric vehicles in the United States,” 2016 Environ. Res. Lett. 11 044007.
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actual, historical, generation mix used to supply electricity in Minnesota under real world conditions and a realistic projection of future generation. 4. Disposal Recycling the battery and related electrical components of BEVs is in a state of infancy and poses unique materials handling and safety challenges.42 Until they are resolved, these disposal- related issues are likely to impact the environment:
• Battery packs could contribute 250,000 metric tons of waste to landfills for every 1 million retired BEVs.43
• Less than five percent of lithium-ion batteries, the most common batteries used in BEVs, are currently being recycled “due in part to the complex technology of the batteries and cost of such recycling.”44
• Recycling BEV batteries to recover high-value metals has not been proven at commercial scale.45 The environmental profiles of both BEVs and ICEVs should be considered in light of the production, operation, and disposal of the vehicle (its life). Any carbon reduction benefits from forcing consumers to shift to BEVs potentially come at an unacceptably high cost (as discussed in Section I.B.), so MPCA must consider all environmental factors and the entire vehicle lifecycles to make a fully informed decision. 5. Energy Security U.S. energy security would also undergo a dramatic paradigm shift if vehicle technologies shifted from ICEVs to BEVs. We would be in danger of moving from being North American liquid fuel secure, to being dependent largely upon foreign sources for the minerals needed to make BEV batteries. As the U.S. Geological Survey has pointed out, although the U.S. produces roughly half of the lithium supply it currently consumes, it has but a single lithium production operation in Nevada.46 97 percent of the lithium that the United States imports is sourced from Chile and Argentina.47 Domestic production of other minerals required for rechargeable battery production is insufficient. Of the foreign nations that produce cobalt, molybdenum, and other minerals needed to produce electric vehicles, China has disproportionate influence. For instance, the U.S. Geological Service (USGS) reported that domestic primary
42 Kelleher Environmental, “Research Study on Reuse and Recycling of Batteries Employed in Electric Vehicles: The Technical, Environmental, Economic, Energy and Cost Implications of Reusing and Recycling EV Batteries”, September 2019 (Kelleher Environmental Study). See https://www.api.org/oil-and-natural-gas/wells-to- consumer/fuels-and-refining/fuels/vehicle-technology-studies. 43 Gavin Harper, Roberto Sommerville, et al., “Recycling lithium-ion batteries from electric vehicles,” January 21, 2020. See https://www.nature.com/articles/s41586-019-1682-5. 44 Congressional Research Service, “Electric Vehicles: A Primer on Technology and Selected Policy Issues,” February 14, 2020. See https://blogs.fas.org/sgp/crs/misc/R46231.pdf. 45 See Kelleher Environmental Study. 46 U.S. Geological Survey, Mineral Commodity Summaries 2018 at 98, available at, https://minerals.usgs.gov/minerals/pubs/mcs/2018/mcs2018.pdf. 47 Id.
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aluminum production in 2017 (740,000 metric tons) was nearly a third of domestic production in 2013 (1,946,000 metric tons).48 China, however, possesses over half of the entire world’s aluminum smelting capacity.49 54 percent of the world’s supply of cobalt comes from the Democratic Republic of Congo where eight of the largest 14 mines are Chinese owned.50 Cobalt has seen U.S. domestic mining production decline (760,000 tons in 2015 compared to 650,000 tons in 2017).51 Secondary cobalt production has largely remained flat over the same span while imports have increased (11,400,000 tons to 12,100,000 tons).52 The United States imports all its graphite and manganese, having no domestic production of these minerals. China produces 67 percent of the world’s graphite,53 while Gabon, a less stable country, provides 73 percent of the United States’ manganese.54 For any one of these minerals, these mandates, taken to their logical end, put the United States into a situation resembling the oil embargoes of the 1970s, where foreign actors control majorities of the critical raw material supplies used in the manufacture of fuels, battery, and motor components designed to provide transportation mobility services for the U.S. consumer. Indeed, China has a dominant position in the global supply chain for battery production as detailed in a recent report by Securing America’s Future Energy (SAFE).55 Adopting California’s ZEV mandate will push BEVs into the market before these issues can be properly addressed. 6. ZEV Mandate is Not Needed for NAAQS MPCA has not demonstrated that Minnesota needs to adopt Clean Cars Minnesota to comply with the national ambient air quality standard (NAAQS), a predicate to opt-in to the California standards under Clean Air Act §177.56 Minnesota has excellent air quality. EPA data show that the average annual PM2.5 concentration of 5.9 ug/m3 across all Minnesota monitors is less than 50 percent of the current PM2.5 NAAQS of 12 ug/m3, a standard set to protect public health with an adequate margin of safety. Not all states are achieving these superior results; for example, California federal reference monitors average 10.3 ug/m3 from 2017-2019. In other words, while most of California’s monitors indicate compliance with the applicable NAAQS, their average levels are 75 percent higher than aggregate Minnesota concentrations. A similar comparison for all regulated air pollutants between the two states further highlight Minnesota’s outstanding results compared to California and allowable federal limits.57
48 Id. at 20. 49 Id. at 21. 50 See “China Has a Secret Weapon in the Race to Dominate Electric Cars,” Bloomberg, December 2, 2018, https://www.bloomberg.com/graphics/2018-china-cobalt/. 51 See Mineral Commodity Survey, at 50. 52 Id. 53 Id. at 72. 54 Id. at 6. 55 See Securing America’s Future Energy, The Commanding Heights of Global Transportation, https://secureenergy.org/wp-content/uploads/2020/09/The-Commanding-Heights-of-Global-Transportation.pdf. Accessed 13 Mar 2021. 56 See United States Environmental Protection Agency, Green Book, “Minnesota Nonattainment/Maintenance Status for Each County by Year for All Criteria Pollutants,” https://www3.epa.gov/airquality/greenbook/anayo_mn.html. 57 U.S. EPA, Air Quality Design Values, https://www.epa.gov/air-trends/air-quality-design-values#map.
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MPCA’s proposal as described in the Statement of Need and Reasonableness58 (SONAR) does not appear to adequately compare the reductions in criteria air pollutants under this proposal with what would be the anticipated reductions that will occur without the proposal (and in any event Minnesota is in attainment for all pollutants other than lead as explained elsewhere).Emission reductions of on-road passenger and light duty trucks are projected to continue as the fleet is turned over, and even lower emitting internal combustion engine vehicles are placed into service. The emission reductions of criteria air pollutants attributed to this proposal are much lower than presented in the SONAR once a realistic “no action” case is included. Further, the MPCA has revised and reduced its original estimate of tailpipe PM emissions in the first 10 years of ZEV program implementation by nearly an order of magnitude (i.e., from 3,032 tons down to 339 tons). It further concludes that, “This correction also reduces the estimated health and equity benefits of the proposed rule but does not impact the overall conclusions that the proposed rule would reduce negative health impacts of vehicle pollution and reduce, but not eliminate, disparities in air pollution exposure.”59 The last portion of the concluding sentence only tells a partial story. The report also says that: The proposed rule could prevent 149-348 28-65 early deaths from air pollution relative to the business-as-usual reference scenario. Additionally, many less severe health outcomes would also be avoided. These are estimated benefits throughout the U.S. resulting from the change in emissions in Minnesota, but given the local and regional qualities of these pollutants, the majority of these benefits would occur in Minnesota.60 This reduces the health benefit by 81 percent. It is not reasonable to continue to argue the case that the mandate will reduce environmental injustice and improve air quality, especially when one considers the adverse health outcomes associated with the traffic’s non-exhaust PM emissions. Additionally, MPCA’s revised results represent a range of derived health or environmental benefits. The projected health benefits from estimated PM2.5 reductions are not scientifically justified based on the assumptions in the exposure data used, as well as the uncertainties in the methods used to quantify PM2.5 reductions, especially at levels well below the NAAQS. 7. Making Cars More Expensive Will Slow Environmental Progress Because EVs are priced higher than ICEVs, even with generous taxpayer subsidies and buyer cross-subsidies, and because this regulation likely would make all vehicles cost more (by requiring car manufacturers and dealers to increase the price of conventional gasoline and diesel vehicles that consumers want in order to lower the prices of EVs and meet the sales mandate), this policy will reduce overall new light-duty vehicle sales and slow down the fleet turnover.
58 MPCA SONAR https://www.pca.state.mn.us/sites/default/files/aq-rule4-10m.pdf. 59 Exhibit O, Proposed Revisions to Minnesota Rules, chapter 7023, Adopting Vehicle Greenhouse Gas Emissions Standards (Clean Cars Minnesota) Addendum to Statement of Need and Reasonableness, February 2021, https://www.pca.state.mn.us/sites/default/files/aq-rule4-10ad.pdf. 60 Id, page 6 (strikethrough edits in the original). 11
The ZEV mandate will not improve air quality as much, or at all, if consumers choose to drive their older and less fuel-efficient cars longer, instead of purchasing new lower emitting vehicles. The MPCA should investigate and report on these issues in order to permit the public and interested parties to provide informed comment on the proposed rule. When consumers defer replacing older vehicles, the introduction of vehicles with technological innovations and lower global warming potential, such as more climate-friendly refrigerants, to the fleet is delayed. For example, vehicle manufacturers now utilize a more climate friendly refrigerant alternative, HFO-1234yf (hydrofluoroolefin) in about half of the new vehicles sold in 2018.61 The ZEV mandate’s impact on all new vehicle prices could slow fleet turnover and the ensuing penetration of modern refrigerants. Consequently, older cars will remain on Minnesotan roads longer, and ultimately have a detrimental impact on MPCA’s efforts to secure GHG reductions. MPCA appears to assume that EVs will make significant contributions to the environment; however, determining the potential GHG benefit, environmental impact, and national security implications of BEVs is not that simple: sourcing raw materials for EV manufacturing, generating electricity to power EVs, disposing of batteries, potentially exposing mobility supply chains, and considering whether more expensive new vehicles will slow fleet turnover impact this conclusion, and must be reconsidered before moving forward with this proposed rule. There are economic challenges that must also be taken into account. B. ECONOMIC Having seen that when BEVs used in Minnesota are subject to an LCA, their emissions benefits, if any, are relatively minor. GHGs are global in nature and this proposal is an expensive approach to reducing emissions that will have no practical impact on climate. Now let’s examine the costs associated with realizing these incremental benefits. 1. Improvements, if Any, Come at a High Cost Because there are many ways to reduce emission across many sectors of the economy, it is helpful to have some benchmarks on estimated damages to compare different policies. One such benchmark is the social cost of carbon (SCC). Resources for the Future defines SCC this way, ‘an estimate, in dollars, of the economic damages that would result from emitting one additional ton of greenhouse gases into the atmosphere.”62 At the end of February, the Biden Administration indicated that they would use the interim values for the SCC of $51 per ton developed by the Interagency Working Group (IWG).63 Proponents of using SCC as a policy tool explain that costs above this amount may not be warranted when weighing costs and benefits. Although it is unclear what process may follow, it is expected that the IWG will take
61 EPA, “Transitioning to Low-GWP Alternatives in Motor Vehicle Air Conditioning,” EPA 430-F-15-029 (Dec. 2016). 62 https://www.rff.org/publications/explainers/social-cost-carbon-101/. 63 See Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates under Executive Order 13990 Interagency Working Group on Social Cost of Greenhouse Gases, United States Government, February 2021, https://www.whitehouse.gov/wp- content/uploads/2021/02/TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf.
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comment on the science and economics for use in a more comprehensive update scheduled to be issued by January 2022. More generally, to compare policies, analysts often develop a “cost of abatement,” which is a calculation of the cost of the policy divided by the GHG reductions achieved by the policy. It is normally expressed in a dollars per ton figure. Although not all BEV-inducing policies have been examined and a cost of abatement has not been calculated for every policy, it is a way to compare policies. MPCA should develop and present to the public its estimate of the cost of abatement for Minnesota Clean Cars. If it is like most BEV-inducing policies, then the cost of abatement is likely to be high. That is because the technology is relatively expensive and the reductions relatively modest. According to the ConservAmerica paper, the calculated range of costs encompasses about $300 to $1,100 per 64 metric ton CO2e abated. These costs are from 4 to 23 times the IWG’s social cost of carbon. To be clear, the assessment does not consider dozens of additional federal, state, local and utility subsidy programs (for EV manufacturers, EV purchasers, EV charging stations, below-market utility rates, etc.) That further increase the cost of any emissions abatement. Minnesota’s proposed rule to adopt the California ZEV mandate will reduce the incentives for the automobile manufacturers to develop new internal combustion engine technology to reduce emissions further, will limit the ability to provide the consumer choice, and will not necessarily result in the emission reductions that the state is seeking to achieve. Most importantly, adopting California’s zero-emission vehicle standards will remove the opportunity for other powertrains to compete in the marketplace that can provide a significant contribution to the reduction of GHG and criteria pollution emissions. In a recent article published in Automotive News, Mr. Gill Pratt, CEO of Toyota Research Institute, said “research shows that [BEVs] may not be the best solution for all consumers, especially those with limited access to charging or who live in areas where power generation is still carbon-intensive… ‘Depending on your needs and your circumstances, there are different vehicles for different circumstances that best lower carbon emissions.’” 65
Drawing largely upon a 2019 assessment of electric vehicle costs performed by the International Council on Clean Transportation,66 the MPCA analysis shows that BEVs are more expensive than ICE vehicles beginning in 2025, which is directionally correct, and then assumes without adequate justification that they become less expensive to purchase than ICE vehicles beginning in 2028. By 2034, based on Minnesota market shares, the MPCA expects that an average BEV with 250 miles of range will be over $6,600 less expensive to purchase than an average ICEV.67 There is good reason to doubt this analysis and MPCA has failed to adequately defend its projection of five figure cost reductions in BEVs over just a few years.68 Nevertheless
64 ConservAmerica, “Slow Down: The Case for Technology Neutral Transportation Policy.” 65 Automotive News, https://www.autonews.com/manufacturing/toyota-na-plans-introduce-2-evs-1-plug-hybrid-year 66 Lutsey, N. & Nicholas, M., Update on Electric Vehicle Costs in the United States through 2030, The International Council on Clean Transportation (April 2, 2019). 67 MPCA, SONAR Technical Support Document…p.53. 68 Id. at 53-54. 13
if BEV costs do follow the MPCA’s projections, a ZEV mandate cannot be justified on a cost basis.
Time and again, the free market has demonstrated that competition will result in reducing the cost of technology while meeting policy goals. Policies that allow all technologies (e.g., battery electric vehicles, hybrids and efficient gasoline and diesel vehicles, natural gas, hydrogen, etc.) to compete in the marketplace can and should be developed to ensure that the most efficient and effective technologies are implemented to achieve the goal of reducing GHG emissions in transportation. With the knowledge that the cost to Minnesotans of any CO2e abatement in this proposal is likely many multiples of the IWG’s uncertain social cost of carbon (i.e., the estimated value to global society of avoided emissions), and the fact that emissions reduced are also very small, if not increased, it is appropriate to conclude that Minnesota should not pursue a ZEV mandate. Instead, Minnesota could accept the Biden Administration’s offer to participate in the federal government’s announced plans to review the fuel economy and GHG emission requirements for new motor vehicles instead of adopting the California rules which could change in the near term. MPCA proposes to justify adoption of California rules for a ZEV mandate on the basis of provisions under Section 177 of the Clean Air Act, which is entitled “New motor vehicle emission standards in nonattainment areas.” However, the aforementioned air quality data and state-wide attainment of the NAAQS in Minnesota raises the question whether MPCA has authority to adopt any California ZEV mandates and/or GHG emission limits, and, if so, why the state would direct limited resources to require Minnesotans to pay a steep price for marginal improvements to already world-class air quality. 2. Minnesota’s Grid Doesn’t Support the Amount of BEVs necessary The proposed rule fails to quantify the cost of infrastructure upgrades that will be required to implement the mandate. This is another issue of central relevance to the rulemaking that is not presented for public comment. For example, The Colorado Electric Vehicle and Infrastructure Readiness Plan, for example, estimated that for every 100 BEVs, there should be 100 residential charging ports, 10 private charging ports, and 20 public charging ports. This would result in 1.3 charging ports for every BEV, which aligns closely with the general industry recommendations of 1.5 charging ports for every BEV on the road.69 The Minnesota regulation will require that for model year 2025, there will be an additional 18,852 BEVs and PHEVs on the roads.70 This number of vehicles would likely necessitate more charging stations and the associated infrastructure to support them. The full cost of such a network is substantial and likely to be paid for, at least in part, by the rate payers. MPCA should provide reasonable estimates of these numbers.
69 Project FEVER, Colorado Electric Vehicle, and Infrastructure Readiness Plan (2012). 70 18,852 cite: https://www.pca.state.mn.us/air/minnesota-ev-dashboard and Minnesota Pollution Control Agency (MPCA), supplement to Statement of Need and Reasonableness (SONAR), Appendix 1: Technical Support Document, “Table 3, 5, Estimated Minnesota light-duty vehicle and EV sales under Clean Cars compliance scenario”.
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The addition of EV charging stations requires significant investment in additional transformers, distribution circuits, conductors, substations, transmission, more net dependable generating capacity, and other necessary grid upgrades. For example, a case study for the city of Sacramento identifies a need to replace 12,000 transformers at an average cost of $7,400 per transformer to accommodate 240,000 BEVs in the city, an investment of almost $90 million.71 These costs translate to a hidden utility ratepayer tax. In effect, this creates a burden for utility ratepayers, the overwhelming majority of whom do not utilize BEVs (and would not even if the ZEV were fully successful in achieving its target market share) and may not wish to utilize BEVs, to subsidize predominantly wealthy, high energy users, which is unfair and incompatible with proper ratemaking. Moreover, transformers and other required infrastructure upgrades to accommodate BEVs require the mining of large amounts of metals and production of large amounts of steel and copper to fabricate the equipment, with corresponding environmental impacts. The MPCA should consider the alternatives to spending millions of dollars on charging stations and associated infrastructure that may not be used as anticipated, given the potential likelihood that a significant fraction of these infrastructure costs could be borne by Minnesotans who receive none of the benefits because they neither own nor operate EVs. One estimate of costs to install charging infrastructure from the grid to chargers estimated that it would cost about $5,100 per BEV spread over 10 years.72 The study also found that, “[i]f these costs were borne solely by EV owners, each owner would have to pay more than $500 a year per EV or $9 every time they completely charge their 75-kWh battery vehicle.”73 The construction of the necessary infrastructure to charge BEVs presents complex issues that may adversely affect the Minnesota environment, and result in air and other emissions that have not been considered by MPCA.
In addition to those costs, utilities will be seeking to balance the power demands from different sectors while decarbonizing the grid. A Deloitte74 paper that examines the strategies needed to decarbonize the U.S. electric grid estimates that by 2040 the building blocks to decarbonize the grid will be in place. According to the paper, in this same timeframe residential and industrial utilization of natural gas and oil could be replaced by heat pumps and “advanced electro-thermal technologies [will] replace gas industrial processes.” By that time, Deloitte anticipates the transportation sector will be transitioning away from gasoline and diesel and that the grid will have its largest challenge due to the anticipated power demand growth from BEVs which alone could achieve a compound annual growth rate of 12.1 percent to 14.7 percent between 2019 and 2050.
71 See Smart Electric Power Alliance, Utilities and Electric Vehicles: The Case for Managed Charging, 13, available at http://emotorwerks.com/images/PR/Articles/sepa-managed-charging-ev-report.pdf. 72 Energy Marketers of America, “Utility Investments and Consumer Costs of Electric Vehicle Charging Infrastructure,” December 2020. 73 Id. at i. 74 Deloitte Insights, “Utility decarbonization strategies: Renew, reshape, and refuel to zero,” https://www2.deloitte.com/content/dam/insights/us/articles/6849_Utility-decarbonization-strategies/DI_Utility- decarbonization-strategies.pdf, 2020.
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A study on the grid in New England by the Energy Futures Initiative, a nonprofit clean energy think tank founded by former Energy Secretary Ernest Moniz,75 estimates that the electricity needed to power the complete electrification of transportation and other sectors will increase by 60 to 90 percent over the next three decades.76 This large increase in electricity demand occurs despite significant energy efficiency included in the study’s scenarios. Absent energy efficiency, demand growth would be even higher. This demand growth does not come without costs that should be considered by MPCA.
A new Princeton University study, “Net-Zero America,” anticipates that this shift will require “at least $2.5 trillion in additional capital investment into energy supply, industry, buildings, and vehicles over the next decade relative to business as usual.”77 An aggressive electrification scenario, the study predicts, will require $2.6 trillion of energy supply-side capital before 2030, and $10 trillion by 2050.78 All this capital will not solely come from investors, it will come from consumers too.
The current average retail price of electricity to the residential sector in Minnesota is about 13 cents per kWh. Minnesota’s electric rates have been rising faster than the national average, possibly due to mandates to retire fossil generation and to integrate more intermittent generation and associated transmission and distribution. These initiatives have not yet been paid for; they are financed over future decades, risking that rates will continue to climb for the foreseeable future. If this proposal is finalized, Minnesotans could see even higher electricity prices, but MPCA has not properly included such costs. If Minnesota follows California’s environmental vision and EVs were to be adopted widely, MPCA would need to examine the extraordinary investments cited in the Princeton study. At minimum, MPCA should undertake a study to estimate the cost to decarbonize the grid and its impact on consumers due to this and any other proposals.
3. Adopting a ZEV Mandate May Have Unintended and Disproportionate Socio-Economic Impacts The adoption of a ZEV mandate could result in Minnesota utilities raising the rates of all households to pay for the electric vehicle service equipment (EVSE) needed to service the mandated volumes of BEVs that would have to be sold. Even small utility rate hikes in good economic times can have a disproportionate impact on less wealthy households. Nearly 1 in 3 American households reported difficulty paying their energy bill, according to a 2018 Energy
75 “Net-Zero New England: Ensuring Electric Reliability in a Low-Carbon Future,” November 2020. https://static1.squarespace.com/static/58ec123cb3db2bd94e057628/t/5fb44a7fc7082162b99baf2c/1605651079 438/E3+EFI_Report+New+England+Reliability+Under+Deep+Decarbonization_Full+Report_11-17- 2020_Release.pdf. 76 Id. At page 2. 77 E. Larson, C. Greig, J. Jenkins, E. Mayfield, A. Pascale, C. Zhang, J. Drossman, R. Williams, S. Pacala, R. Socolow, EJ Baik, R. Birdsey, R. Duke, R. Jones, B. Haley, E. Leslie, K. Paustian, and A. Swan, Net-Zero America: Potential Pathways, Infrastructure, and Impacts, interim report, Princeton University, Princeton, NJ, December 15, 2020. 78 Id.
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Information Administration report.79 Minnesota has the 14th highest electricity energy rates of all the 50 states with the average consumers’ electric bill costing $114 per month.80 If Minnesota follows the vision of some in California to move from natural gas use to electrification, then higher demand on electricity for transportation and these other uses could make heating homes more expensive.81 According to 2017 figures, 6.8 percent of the Minnesota population was living in poverty82 while the elderly and fixed-income families made up 15.9 percent of the population.83 These Minnesotans will pay for BEV charging infrastructure through higher electricity bills. To that end, we point you to the concerns raised by the director for the New Jersey Division of the Rate Counsel (NJDRC), who noted during a June 3, 2020 Board of Public Utilities webinar84 that, “We can’t ask people, residential or business customers… to pay more for an essential service like electricity right now, unless it’s absolutely necessary.” In 2019, Colorado proposed and passed a law that granted utilities the authority to increase customer rates to cover the costs for EV charging infrastructure. In response to the proposed law, AARP85 stated that utility customers could have to pay an additional $50-$75 per year in utility bills for EV charging infrastructure that very few people use. Regardless of the exact increase, a ZEV mandate will drive the need to build out EV charging infrastructure and any utility rate increases that would likely result, would be borne by all residents, even those who are not going to utilize the service. Alternatively, without a ZEV mandate, private capital will be utilized to build out the infrastructure as has historically been done at a pace that matches an organic adoption rate of EVs. As EVs become more prominent, the demand for charging stations will increase and create more opportunity to invest in that infrastructure; accordingly, drawing more private capital to build out infrastructure. Allowing the market to function without a government mandate will result in the most robust development of the Electric Vehicle Service Equipment (EVSE) and ensure it is placed in the best locations and is timed to meet the natural growth rate for EV adoption. 4. Total Cost of Ownership The Statement of Need and Reasonableness (SONAR) states that “some of the most important benefits of BEVs, such as reduced maintenance and the potential to charge from home, are not readily apparent to the average car owner.” But even if maintenance costs prior to having to replace a battery pack or an engine may appear to be less expensive for BEVs than ICEVs,
79 https://www.eia.gov/todayinenergy/detail.php?id=37072. 80 https://www.chooseenergy.com/electricity-rates-by-state/. 81See Information Brief, Research Department Minnesota House of Representatives, Residential Space Heating Fuels in Minnesota, https://www.house.leg.state.mn.us/hrd/pubs/heatfuel.pdf. 82 https://www.thebalance.com/us-poverty-rate-by-state-4585001. 83 https://www.prb.org/which-us-states-are-the-oldest/. 84 https://register.gotowebinar.com/recording/1544180925673058822 (starting at approximately at time 1:12:30). 85 https://states.aarp.org/colorado/senate-bill-19-77-is-bad-for-colorado-consumers.
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and there is an added convenience to recharge a BEV from home, and it is important to put these benefits in context with the other costs that are not as obvious. Studies performed by Argonne National Laboratory, A.D. Little, MIT, and IPIECA show that the cost of owning a battery electric vehicle representative of current technology is significantly more expensive than a conventional vehicle equipped with an ICE.86, 87, 88, 89 A study by Argonne National Laboratory indicates that the total cost of ownership of a battery electric vehicle with a 210-mile range could be more than three-times higher than the cost of a gasoline/E85 vehicle.90 The A.D. Little analysis indicates that the total cost of ownership of a battery electric vehicle compared to an ICEV is 44 percent higher for a compact BEV and 60 percent higher for a mid-size BEV compared to the same sized ICEV.91 The A.D. Little calculation of Total Cost of Ownership has two major cost categories: those incurred by the original equipment manufacturer (OEM) and those incurred by the final consumer. Those costs should all be calculated by MPCA and include: 1) Annual miles driven 2) Cost of gasoline 3) Electricity for total cost of ownership and installed home-charging station 4) Battery from BEV at end-of-life (use of battery after completed with use in vehicle) 5) Insurance 6) Financing 7) State fees 8) Maintenance and repairs 9) Battery replacement 10) Alternative transportation
The Argonne National Lab report assessed the levelized cost of driving (LCD) that is a “function of vehicle purchase cost, assumed vehicle residual value at the end of the analysis period, assumed discount rate, fuel costs, fuel efficiency, and assumed vehicle miles traveled (VMT).” These levelized costs were generated for two cases: a “Current Technology” scenario and a “Future Technology” scenario. In the Future Technology scenario, it was still 1.6 times more expensive to drive the BEV than the ICEV (about $0.35/mile compared to $0.55/mile). Twenty cents per mile is a lot of money to ask Minnesotans to pay for negligible, if any, environmental benefits.
86 A. Elgowainy, “Cradle-to-Grave …” 87 John W. Brennan and Timothy E. Barder, Ph.D, “Battery Electric Vehicles vs. Internal Combustion Engine. Vehicles,” Arthur D. Little, 2016. See, http://www.ehcar.net/library/rapport/rapport201.pdf. 88 IPIECA, “GHG …” 89 A. Ghandi and S. Paltsev, “Global CO2 impacts of light-duty electric vehicles”. https://www.sciencedirect.com/science/article/pii/S1361920920307112; https://doi.org/10.1016/j.trd.2020.102524. 90 A. Elgowainy, “Cradle-to-Grave …” (see Table 39). 91 John W. Brennan, “Battery Electric Vehicles …”
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The earlier referenced MIT study on global CO2 impacts of light-duty EVs finds that the total cost of BEV ownership is ~$96,000 compared to ~$80,000 for a comparable conventional vehicle.92 They find this premium will persist in the range of $4,000-9,000 in 2030 and that “ICE vehicles may still be the main mode of private transportation for many decades to come,” in part, due to gains in fuel economy. Even if it is a cheaper and more convenient to refuel a BEV while at home, (after installing necessary charging equipment) it may not be cheaper to do so using public direct current fast charge (DCFC) equipment. About one-third of the U.S. population lives in multi-unit housing93 and they may rely on recharging their vehicle at commercial DCFC stations. According to one article that explains the different costs of recharging BEVs, using a publicly available DCFC system is the most expensive way to recharge a BEV costing 60 percent more than refueling a similarly sized ICEV.94 Car and Driver put it this way, “So if you're buying an electric car to save on fuel costs, make sure you plug in at home.”95 Despite vehicle consumers’ revealed preference and need to refuel vehicles rapidly, MPCA has not considered any costs to Minnesotans from spending much more time to charge their BEVs compared to fueling conventional vehicles. Specifically, current BEV charging technology provides for: two to five miles of range per one hour of charging for AC Level 1 supply equipment; ten to twenty miles per one hour of charging for AC Level 2 supply equipment; and 60-80 miles per 20 minutes of charging for DCFC (which is cost-prohibitive for most Minnesotans at its fair market price).96 In just a few minutes you can fill up a tank and travel 400 to 500 miles with existing ICEV technology. It appears the proposal does not properly consider the value of Minnesotans’ time. Though BEVs will play a role in reducing GHG emissions, they should be chosen by the consumer among other technologies that can accomplish a similar result at a less expensive cost. MPCA’s proposal has failed to consider both the higher costs of DCFC systems and the significant increase in time required for EV drivers to fuel their vehicles. Both must be accounted for in the analysis. 5. ZEVs are Cost-Prohibitive a) ZEV mandate affects entire light-duty vehicle market The MPCA SONAR – which should be published in full along with the full Technical Support Document at the website97 – discusses potential savings from a ZEV mandate that result from avoided fuel and maintenance costs for BEVs, which are addressed above as being incomplete. However, it also fails to adequately address other economic impacts of Minnesota’s
92 Abbas Ghandi, Sergey Paltsev, “Global CO2 impacts of light-duty electric vehicles,” Transportation Research Part D: Transport and Environment, Volume 87, 2020, 102524, ISSN 1361-9209, https://doi.org/10.1016/j.trd.2020.102524. (https://www.sciencedirect.com/science/article/pii/S1361920920307112). 93 See https://www.census.gov/population/www/cen2000/censusatlas/pdf/14_Housing.pdf (accessed 2/17/20). 94 Jim Gorzelany, “What it Costs to Charge and Electric Vehicle,” https://www.myev.com/research/ev-101/what-it- costs-to-charge-an-electric-vehicle, accessed January 31, 2021. 95 See “Our Tesla Model 3 Proves EVs Are Cheaper When Charged at Home,” Car and Driver, January 11, 2021, https://www.caranddriver.com/news/a35152087/tesla-model-3-charging-costs-per-mile/. 96 See U.S. Department of Energy, Alternative Fuels Data Center, “Developing Infrastructure to Charge Plug-In Electric Vehicles,” https://afdc.energy.gov/furnitifuels/electricity_infrastructure.html. 97 https://www.pca.state.mn.us/air/clean-cars-mn-rulemaking.
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proposed ZEV mandate. The implementation of California’s ZEV regulations likely would result in increased prices for new gasoline and diesel-powered vehicles. If automakers are unable to sell a sufficient volume of EVs to meet the mandate requirements, they must either buy ZEV credits or pay fines. To date, EV makers have been highly dependent on the revenue from ZEV and other credit sales, while other automakers have likely increased the prices of new traditional vehicles to offset the increased cost of ZEV production, fines, and ZEV credits. Increased new car prices have often resulted in higher used car prices, and when car prices increase, Minnesota consumers are less likely to purchase newer vehicles to replace their older ones.
ZEV mandates also result in indirect subsidies through the cross-subsidization of vehicle models.98 As EPA and NHTSA found, the significant “technology cost burden” of electrified vehicles requires cross-subsidization, inflating the prices of pick-up trucks, SUVs, and other conventional vehicles to offset the losses from the sales of ZEVs.99 One former auto executive explained that the cost of SUVs has risen significantly because automobile manufacturers are “trying to recover what they're losing at the other end with what I call compliance vehicles, which are Chevy Volts, Bolts, plug-in Cadillacs and fuel cell vehicles ….”100 This means that even those who are completely unwilling to pay for these vehicles still pay for them in part by absorbing a markup on internal combustion vehicle costs.101 These cross-subsidies are effectively a tax imposed on all those choosing not to purchase electrified vehicles.102
McKinsey & Company found that EV manufacturers “do not make a profit from the sale of EVs. In fact, these vehicles often cost $12,000 more to produce than comparable vehicles powered by internal-combustion engines (ICEs) in the small- to midsize-car segment and the small-utility-vehicle segment. What is more, carmakers often struggle to recoup those costs through pricing alone. The result: apart from a few premium models, OEMs stand to lose money on almost every EV sold, which is clearly unsustainable.”103 The adoption of a ZEV mandate
98 83 Fed. Reg. at 43,224. 99 83 Fed. Reg. at 43,084-85. 100 Six Superstars Ponder the Future of an ‘Irrational’ Auto Industry, Automotive News (Aug. 3, 2015), available at, http://www.autonews.com/article/20150803/INDUSTRY_ON_TRIAL/308039971/six-superstars-ponder-the-future- of-an-irrational-auto-industry (“I don't know if anybody noticed, but full-size sport-utilities used to be — just a few years ago used to be $42,000, all in, fully equipped. You can't touch a Chevy Tahoe for under about $65 [thousand] now. Yukons are in the $70 [thousands]. The Escalade comfortably hits $100 [thousand]. Three or four years ago they were about $60,000. What this is, is companies trying to recover what they're losing at the other end with what I call compliance vehicles, which are Chevy Volts, Bolts, plug-in Cadillacs and fuel cell vehicles.”) (quoting Bob Lutz, former Vice Chairman of GM). 101 83 Fed. Reg. at 43,085. 102 California has completely failed to consider these costs. When asked this question, the California Air Resources Board (CARB) routinely responds that “we do not know how much a credit costs.” CARB included this response for many years in the online ZEV tutorial. (https://ww3.arb.ca.gov/msprog/zevprog/zevtutorial/zev_tutorial_webcast.pdf) which has now been archived. Should MPCA similarly adopt the ZEV mandate, MPCA also will be requiring every American gasoline and diesel car buyer to fund their mandate through hidden buyer premiums transferred to automakers in the form of ZEV credits. MPCA has not identified any cost for these credits nor any statutory authority that would allow them to impose such a hidden tax on all American car buyers. 103 McKinsey & Company. March 2019. https://www.mckinsey.com/industries/automotive-and-assembly/our- insights/making-electric-vehicles-profitable
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forces Minnesotans to bear these additional costs. These additional costs are real and must be considered. Consequently, older vehicles that are potentially less safe, less clean, and less fuel- efficient than newer ones will stay on the road longer. The negative effects of this phenomenon are far-reaching and disadvantages the Minnesota environment and economy. An increase in the price of new and used vehicles will likely slow vehicle replacement. MPCA has not assessed these impacts.
As vehicle replacement slows, the rate of introduction of new safety features, such as blind spot monitoring, lane departure warning, and electronic stability control declines. Two recent studies from the Insurance Institute for Highway Safety (IIHS) found significantly lower crash rates for vehicles equipped with blind spot monitoring or lane departure warning. It found that cars equipped with lane departure warning are 24 percent less likely to be involved in accidents with injuries and 86 percent less likely to be involved in fatal accidents.104 Cars with blind spot detection are 23 percent less likely to be involved in lane-change accidents with injuries.105 Increased new vehicle prices will reduce the rate at which Minnesotans will benefit from these new technologies.
b) BEV Subsidies are Claimed by the top 20 percent of Income Earners Even with the continuation of subsidies and rebates, incremental cost of the BEV battery technology contributes to a differential in vehicle purchase price between BEVs and ICEVs that should be noted. In January 2021, the average transaction price for an electric vehicle was reported to be $53,701, before application of any consumer incentives, while the “industry average” new light-duty vehicle transaction price was estimated at $40,420.106 Since the “industry average” includes electric vehicles, a comparison of the difference between the two aforementioned values is somewhat misleading. Nevertheless, the roughly $13,000 difference falls within the range found by other studies which indicate that the cost of a BEV is $10,000 to $15,000 more expensive than an ICEV.107 The federal tax credit ranges from $2,500 to $7,500 per vehicle (except for manufacturers that have already sold 200,000 units), depending on the vehicle’s battery capacity.108,109 In 2018, 97 percent of the claims for the federal BEV income tax credit were submitted by taxpayers earning $100,000 or more, according to data provided in an annual survey conducted by the Internal Revenue Service.110 A 2019 study prepared by Strategic Vision for DOT indicated that
104 Cicchino, J. “Effects of lane departure warning on police-reported crash rates”. Journal of Safety Research, September 2018 105 Cicchino, J. “Effects of blind spot monitoring systems on police-reported lane-change crashes” Insurance Institute for Highway Safety, August 2017 106 "Kelley Blue Book - New And Used Car Price Values, Expert Car Reviews". Kbb.Com, 2021, https://mediaroom.kbb.com/2021-02-15-Average-New-Vehicle-Prices-Continue-to-Surpass-40-000-Up-More-Than- 5-in-January-2021-According-to-Kelley-Blue-Book. 107 ConservAmerica, “Slow Down: The Case for Technology Neutral Transportation Policy” 108 Congressional Research Service, “The Plug-In Electric Vehicle Tax Credit,” May 14, 2019. 109 It can only be used to offset a taxpayer’s tax liability in the current tax year (i.e., there is no carryback or carry forward). The credit is nonrefundable, meaning the credit amount cannot exceed a taxpayer’s tax liability. 110 U.S. Internal Revenue Service, “Individual Income Tax Returns 2018,” Publication 1304, Table 3.3 (Rev. 09- 2020)
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the median income for a BEV purchaser was $166,000, while the median income for a new car purchaser was about half that amount.111
c) The ZEV mandate limits options for Minnesota customers in the light truck market In addition to the cold weather concerns discussed in Section II, the towing capability of a BEV also is likely to be of significant importance to many Minnesotans, particularly those who rely on trailers for work and/or recreational purposes. The author of a recent Road & Track article concluded that although a BEV may have very good tow capacity, its driving range was severely impacted when pulling a trailer due to the combined effects of increased payload, aerodynamic drag, rolling resistance, and gravity on battery charge depletion.112 According to the MPCA analysis, ZEVs will increase the cost of all vehicles in the state but the ZEV will be of little use to rural Minnesotans and farmers who use their trucks in their daily work.113
Minnesota is a “truck heavy state” and the lack of workable ZEV options for the millions of Minnesotans who use powerful vehicles to handle the more rural life poses a real challenge for the proposed ZEV mandate. There are very few options in the light truck category, and the current and upcoming models are tremendously costly, ranging from $69,000 to $82,000.114 With the median household income of $68,411, these prices are cost prohibitive for the majority of Minnesotans, especially rural residents. Consequently, a ZEV mandate creates a burden on the rural residents and increases the price of the vehicle that they choose to purchase.
II. Minnesota is Not California, Making Policy Inappropriate A. Minnesota is Colder and EVs have Cold Performance Issues Minnesota is different from California in many ways, and this proposed ZEV regulation offers no flexibility to adapt to the varied needs of Minnesotans. Stating the obvious, Minnesota has a colder climate than California. On average, Minnesota is 18.2 degrees colder than California.115 The difference between Minnesota and coastal California (where BEVs are more prevalent) is even more stark. The average temperatures range from 9 to 83 degrees in Minneapolis and 7 to 78 degrees in Duluth. Conversely, major coastal California cities see a much narrower range with average temperatures that vary from 43 degrees to 82 degrees in San Jose; 50 to 77 degrees in San Diego; and 48 to 85 degrees in Los Angeles.116 Battery
111 Strategic Vision, “BEVS: THE CUSTOMER STORY,” January 2019 Prepared for U.S. Department of Transportation. 112 Road and Track, “Why Electric Cars Aren't Yet Great for Towing: They can pull, but they can't do it for long,” By Chris Perkins, Dec 4, 2019, https://www.roadandtrack.com/new-cars/car-technology/a30121167/electric-car- towing-range/ 113 Mankato Free Press, “Electric vehicle mandates will hurt farmers,” by Wanda Patsche, Feb 13, 2021, https://www.mankatofreepress.com/opinion/electric-vehicle-mandates-will-hurt-farmers/article_233ad7ea-6d4e- 11eb-97c1-4b34fbe48293.html 114 For example, the MSRP of the currently available 2019 Tesla Model X hovers around $82,000. The upcoming Audi e-tron will start at $74,800. The Rivian R1T pickup truck will start at $69,000 and the Rivian R1S All-Electric SUV has a starting price of $72,500. 115 See “U.S. Average Temperature State Rank,” USA.com, http://www.usa.com/rank/us--average-temperature-- state-rank.htm. 116 See WeatherSpark.com, https://weatherspark.com/.
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performance is significantly impacted by temperature as it deviates from around 70 degrees. At cold temperatures, battery efficiency, discharge capability, and range decrease; this is far less of an issue in California than in Minnesota. In addition, battery internal resistance, or the opposition to flow of current within the battery increases, reducing the power that can be drawn from the battery.117 Weather conditions have a direct impact on battery efficiency. Ambient temperature also drives the use of cabin air conditioning or heating, which can decrease driving range by up to 40 percent.118 Car and Driver recently conducted a study at the Chrysler Proving Grounds to test energy consumption with various levels of heating, ventilation, air conditioning (HVAC) usage. With the seat warmers and heat on, conditions reminiscent of many cold Minnesota mornings, a Tesla Model 3 lost over 60 miles of range compared to an expected range of 234 miles recorded with no HVAC use.119 In another study performed by Car and Driver, they recorded a 19 percent drop in fuel economy in 36-degree weather versus 56-degree weather.120 Manufacturers have also realized the detrimental effects extreme Minnesota cold can have on their vehicles. A 2019 American Automobile Association (AAA) study of electric vehicle ranges found several owner’s manuals that cautioned severe harm or voided warranties if batteries were exposed to extremely low temperatures. One manufacturer notes in their manual that “[a] battery will be permanently damaged by freezing.”121 Moreover, the 2018 Nissan Leaf owner’s manual included warnings against storing the vehicle in cold weather, noting that “[i]f the outside temperature is −13°F (−25°C) or less, the Li-ion battery may freeze and it cannot be charged or provide power to run the vehicle. Move the vehicle to a warm location.”122 The AAA study concludes with summary recommendations including that “[o]wners of EVs should be aware of environmental conditions in their area and plan for reduced driving range during periods of hot or cold temperatures,” and “EV owners should understand that HVAC use during periods of cold weather may result in significantly increased energy costs.” Another recent study performed in Winnipeg, just 70 miles north of the Minnesota border, found that for a Nissan Leaf, range exceeds 150 km (about 93 miles) at 68 degrees Fahrenheit, while it reduces to about 85 km (about 53 miles) and 60 km (about 37 miles) at 32 degrees and 5 degrees Fahrenheit), respectively.123 Minnesota should not force EVs into the
117 T. Yuksel, J. Michalek, Effects of Regional Temperature on Electric Vehicle Efficiency, Range, and Emissions in the United States, Environ. Sci. Technol. 2015, 49, 3974−3980, DOI: 10.1021/es505621s. 118 Environ. Sci. Technol. 2015, 49, 6, 3974–3980 Publication Date: February 11, 2015, https://doi.org/10.1021/es505621s. 119 See “How Much Does Climate Control Affect EV Range?,” Car and Driver Magazine, March 19, 2020. https://www.caranddriver.com/news/a31739529/how-much-does-climate-control-affect-ev-range/. 120 See “Tested: How Cold Weather Affects EV Range,” Car and Driver Magazine, May 25, 2018. https://www.caranddriver.com/features/a20915996/tested-how-cold-weather-affects-ev-range-feature/. 121 See “AAA Electric Vehicle Range Testing,” February 2019. https://www.aaa.com/AAA/common/AAR/files/AAA-Electric-Vehicle-Range-Testing-Report.pdf 122 See 2018 Nissan Leaf Owner’s Manual, EV-3, https://owners.nissanusa.com/content/techpub/ManualsAndGuides/LEAF/2018/2018-LEAF-owner-manual.pdf. 123 P. Iora and L. Tribioli, “Effect of Ambient Temperature on Electric Vehicles’ Energy Consumption and Range: Model Definition and Sensitivity Analysis Based on Nissan Leaf Data,” World Electric Vehicle Journal 2019, 10, 2; doi:10.3390/wevj10010002.
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marketplace124 when they suffer severely degraded performance or left to pay out of pocket to replace batteries because of normal winter conditions. To underscore the significance of Minnesota’s weather and how failure to properly consider it before mandating electric vehicles, consider the example of the Metropolitan Council, whose priority is to provide financially sustainable transportation system for the Twin Cities metropolitan region. They have discovered that the purchase price of electric buses are 160 percent the cost of diesel buses (prior to adding charging equipment), that electric buses cannot travel normal bus routes due to range limitations (including poor cold weather battery performance), and that charging equipment malfunctions (overheating) have resulted in sidelining electric buses that have cost Minnesota and federal taxpayers (through federal grants) millions of dollars. In short, this experiment has been a costly failure to invest in cost-effective emission reductions. As a result, the Metropolitan Council and Metro Transit are in the process of abandoning their near-term transition to EV buses and will acquire new diesel/biodiesel buses instead of EVs due to cold-weather performance problems (range reliability, battery-loss, overheated chargers, etc.).125 B. Minnesota is More Rural, Making Range Considerations Even More Important The urban/rural divide between California and Minnesota is significant. According to the 2010 census, only 5.1 percent of Californians live in rural areas, whereas 26.7 percent of Minnesotans live in rural areas.126 As one might expect from such a substantial difference between the two states, trucks and SUVs are much more popular in Minnesota than in California. California’s top selling vehicle is a Honda Civic while Minnesotans prefer the Chevy Silverado.127 One study has shown this disparity. It showed the share of new vehicle registrations in 2018 that are plug-in electric (both fully electric and plug-in hybrid) across U.S. metropolitan areas, with San Jose area having the highest electric vehicle market share at 21 percent, followed by other California cities.128 This figure is considerably higher than for rural Minnesotan areas, or even Minnesota overall, which had a plug-in electric vehicle share of 1.13 percent for that year.129 In addition to the private purchasers who live in rural areas, the industries that operate
124 Technically, a ZEV mandate does not require consumers to purchase EVs, but that is their effect since auto manufacturers are required to offer some portion of their fleet to be EVs and cars do not stay on dealer lots forever. 125 (Sources: Metro Transit, which vowed to go all-electric, seeks $122M for biodiesel - StarTribune.com https://www.startribune.com/biodiesel-not-electric-buses-may-join-metro-transit-fleet/600029359/ ; Metro Transit temporarily pulls electric buses from C Line because of problems with chargers - StarTribune.com, https://www.startribune.com/metro-transit-pulls-electric-buses-from-c-line-temporarily-due-to-charging- issue/562114192/ ) [Confirm Metropolitan Council March 10, 2021 vote here: https://metrocouncil.org/getdoc/3a5cc196-bebf-451b-9577-d264ed2212e6/Agenda.aspx , and here: http://metrocouncil.granicus.com/ViewPublisher.php?view_id=2 and here: https://metrocouncil.org/Council- Meetings/Committees/Metropolitan-Council/2021/3-10-21/Electric-Bus-PPT.aspx (see pages 5-7] 126 See “States with the biggest rural populations,” Andrew Lisa, April 8, 2019, https://stacker.com/stories/2779/states-biggest-rural-populations. 127 See “Most popular cars in America,” Edmunds.com, https://www.edmunds.com/most-popular-cars/. 128 P. Slowik and N. Lutsey, “The surge of electric vehicles in United States cities,” The International Council on Clean Transportation Briefing, Published June 10, 2019. https://theicct.org/publications/surge-EVs-US-cities-2019. 129 See “New Data Shows Statewide Growth in Electric Vehicle Purchases in Minnesota,” Drive Electric Minnesota, https://www.driveelectricmn.org/new-data-shows-statewide-growth-in-electric-vehicle-purchases-in-minnesota/.
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there, including agriculture and mining companies, need reliable vehicles and fuels that can deal successfully with snow and ice and other rugged conditions. They should not have to pay more for those vehicles to cross-subsidize EVs. Minnesota’s disproportionate rural population, when compared to California, is reflected in transportation statistics showing that Minnesota’s annual average vehicle miles traveled (VMT) per capita of 10,601 miles, is the 18th highest of any state, and 24 percent higher than California’s annual average VMT of 8,516 miles, the 10th lowest of any state.130 Minnesota has a population density of 67 per square mile, compared to 239 for California.131 Minnesota’s lower population density and demand for greater vehicle miles traveled means that an electric vehicle mandate is even less sensible in Minnesota when compared to California. The current state of battery technology makes them much less energy dense than petroleum-based fuels. The Tesla Model X’s 100 kilowatt-hour (kWh) battery pack has the most energy storage of any production BEV. EPA certified the Model X Long Range as being able to go 328 miles between charges. Car and Driver found BEV ranges routinely overestimated. In fact, their recent article points out that none of the EVs they tested in their 75 mile per hour highway test has met, let alone exceeded, its range rating.132 The study notes that their range figures should also be considered the absolute maximum possible and difficult to achieve with any regularity. The author notes that in their test, the EV battery is charged to 100%, which is not the norm. Topping off the last 10 to 15 percent is when the rate of charging slows substantially and increases the rate of battery capacity degradation. Indeed, Tesla recommends limiting charging to 90 percent for daily use.133 Another recent study published in Road & Track Magazine found that when you add a trailer to the mix, that range goes way down. The study simulates a family taking their Model X on a 100-mile trip with a trailer and driving up a one percent grade for one hundred miles at 75 miles per hour and finds that 100.4 kWh is needed to make that trip. In other words, the Tesla would have to recharge to complete the trip, and that is not factoring use of any HVAC or other ancillary vehicle electric systems. For comparison, the study authors run the same trip simulation with a Ford F-150. In the F-150 scenario, the trip would require 170 kWh of energy, or about five gallons of gasoline.134 To attain these proposed standards will mean making more expensive the very trucks, minivans, crossovers, and SUVs the vast majority of Minnesotans choose, and need, to drive. C. Minnesota is not California – Electric Rates and Fuel Taxes While the 2019 average retail price of electricity in Minnesota was on par with the national average, the average retail price of electricity in California is approximately 160 percent
130 See U.S. Department of Transportation, https://www.transportation.gov/transportation-health-tool/indicators. 131 See U.S. Census Bureau, https://www.census.gov/quickfacts/fact/table/MN,CA,US/PST120219 132 See “EV Range: Everything You Need to Know,” Car and Driver Magazine, published May 22, 2020, https://www.caranddriver.com/shopping-advice/a32603216/ev-range-explained/. 133 Id. 134 See “Why Electric Cars Aren't Yet Great for Towing,” Road & Track Magazine, December 4, 2019, https://www.roadandtrack.com/new-cars/car-technology/a30121167/electric-car-towing-range/.
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of the national average.135 The rates for both states are trending higher at a more rapid rate than the rest of the country. MPCA must consider whether the cost of all of their policies, including a ZEV mandate, as well as those of the Minnesota PUC, will continue to push electricity rates even higher. Minnesota should consider EV adoption policies holistically to ensure that EV owners and drivers pay the fair market rate for electricity, including, where appropriate, demand charges. At the very least, such costs should be considered by MPCA as part of this rulemaking. As a CEO of one of the largest EV charging companies in America stated, “if you pass the demand charge onto the customer in a high-demand charge market” it can cost anywhere from $70 to $110 to charge a vehicle.”136 Liquid transportation fuels are also taxed, both at the federal and state level, to fund building, maintenance and repair of bridges, roads, highways, and other transportation initiatives, even including bicycle paths. The federal tax on liquid transportation fuels is 18.4 cents per gallon. California levies an additional 61.2 cents per gallon, the most in the nation, while Minnesota adds 28.6 cents per gallon. As a result, a typical driver, traveling 12,000 miles per year in a vintage 2010 conventional vehicle, averaging 25 mpg, will pay nearly $400 per year in fuel taxes in California and nearly $200 of fuel taxes in Minnesota. By contrast, an EV owner only pays a $75 annual registration fee. There is no federal tax on electricity and there are de minimis state taxes on electricity. Minnesota should equalize treatment of vehicle owners so everyone is paying their fair share for road and bridge maintenance. MPCA should factor in losses to highway funds from reduced gasoline and diesel tax revenues.
III. Minnesota’s Proposed Rule is Preempted Under Federal Law Federal law preempts states from enacting ZEV mandates, whether alone or by opting-in to California’s Advance Clean Car Program. The fact that the Proposed Rule would not take effect until EPA grants California a Clean Air Act waiver does not save it from preemption under the federal Energy Policy and Conservation Act (EPCA). EPCA preempts states from adopting or enforcing any regulation “related to” fuel economy standards. See 49 U.S.C. sec. 32919. This self-implementing EPCA provision is administered by the U.S. Department of Transportation and does not authorize DOT, EPA, or any other federal agency to waive preemption. For this reason, the Proposed Rule if enacted, even with a delayed effective date, would be void ab initio. MPCA concedes that EPA must first grant a waiver to California as a precondition to the enforcement of a ZEV mandate. The plain language of the relevant federal statutes precludes states from adopting or enforcing standards, making the MPCA’s proposed adoption unlawful regardless of its plans to defer enforcement unless and until a waiver is granted. Aside from the plain language prohibiting adoption, the unique circumstances of EPA’s current revocation of California’s waiver raises substantial legal and policy concerns that MPCA’s proposal fails to address. No proposed reinstatement of the waiver has even been outlined by EPA, leaving stakeholders guessing as to what model years (MY) might be affected in a proposed
135 See U.S. Energy Information Administration, https://www.eia.gov/electricity/state/. 136 See “Volkswagen's Electrify America buys Tesla devices for EV charging stations,” Reuters, February 4, 2019, https://www.reuters.com/article/volkswagen-electrifyamerica-tesla/vws-electrify-america-buys-tesla-devices-for-ev- charging-stations-idUSL1N1ZW1O5.
26 reinstatement. A final reinstatement of the waiver retroactively to past or current MYs under production would raise substantial due process and retroactivity concerns. Were those concerns heeded, a final reinstatement covering only partial model years would invalidate MPCA’s proposal and require it to begin anew another rulemaking process to align with the reinstated waiver. Besides these federal concerns, MPCA cites no authority under Minnesota administrative law for a “contingent” rulemaking that depends on a series of other agencies and actors taking steps. And, for good reason: such contingent rulemakings violate settled norms of fairness, due process and administrative law because they leave stakeholders guessing as to how a rule might affect the public in its final form. As a policy matter, it would be prudent to await the outcome of the waiver proceedings. Minnesota and its stakeholder are spending significant resources on a Minnesota rule that may not come to pass or may be finalized in a different form depending upon the federal waiver proceeding. In order to opt-in to California’s program under sec. 177 of the Clean Air Act, Minnesota must contain areas that are in non-attainment with the National Ambient Air Quality Standards (NAAQS). See 42 U.S.C. §§ 7501, 7507. Minnesota is in attainment for Ozone, as well as Particulate Matter, Carbon Monoxide, Nitrogen Dioxide and Sulfur Dioxide.
IV. Conclusion MPCA has not accurately accounted for the total economic or environmental costs associated with its proposed mandate. Requirements to replace affordable, reliable gasoline and diesel vehicles with higher cost, less reliable alternatives, will be expensive for taxpayers and ratepayers in addition to those who want to buy a gasoline or diesel-powered vehicle. If the MPCA ultimately chooses to adopt California’s ZEV mandate, the rules should be drafted in such a manner as to require the state to make an intentional decision to adopt any future California updates to the rule. Without taking this approach, Minnesota is in danger of blindly following California’s governor’s goal of banning the sale of all new ICE vehicles in 2035. AFPM and API members are applying their abilities to solve the complex challenges of GHG emission reductions in transportation in a manner that will provide affordable and reliable products that allow Minnesotans, and all consumers, the ability to choose the transportation mode that meets their needs while meeting the policy objectives of reducing transportation emissions. To that end, AFPM and API welcome discussion on viable solutions to the dual challenge of ensuring reliable and affordable energy supplies to support economic growth and human prosperity, while advancing environmental progress. For more information or if you have any questions, please contact: Don Thoren, Vice President, State & Local Outreach, American Fuel & Petrochemical Manufacturers | [email protected] | 202-844-5526 Elizabeth Van Holt, Midwest Region Director, State Government Relations, American Petroleum Institute | [email protected] | 630-607-4160
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Ellen Biales Attachment
Ellen Wald Attachment
February 24, 2021
Administrative Law Judge Jessica Palmer-Denig 600 North Robert Street St. Paul, MN 55101
Re: Proposed Rules Adopting Vehicle Greenhouse Gas Emissions Standards—Clean Cars Minnesota, Minnesota Rules, chapter 7023; Revisor’s ID Number 04626
Dear Judge Palmer-Denig:
I write in response to a request for comments related to the Proposed Rules Adopting Vehicle Greenhouse Gas Emissions Standards—Clean Cars. This letter addresses the reasonableness of the proposed regulation, specifically the section related to Zero Emission Vehicles.
My name is Ellen R. Wald. I am a senior non-resident fellow at the Global Energy Center at the Atlantic Council, the founder and president of Transversal Consulting, and an adjunct professor at Jacksonville University. Past appointments include visiting assistant professor at the University of Georgia, Majewski Fellow in Economic Geology at the American Heritage Center at the University of Wyoming, Visiting Scholar at the University of Cambridge, and lecturer at Boston University. I am a columnist on the energy industry and investing at investing.com. I earned my doctorate in history, with a focus on the energy industry, at Boston University, and my A.B. magna cum laude from Princeton University. The views I share in this letter are mine and do not represent those of any institution with which I am affiliated.
The proposed rule is not in the best interest of the state of Minnesota or Minnesotans. Adopting the California zero emission vehicle (ZEV) mandate would be a mistake for Minnesota. It would adopt California’s ZEV standards without consideration for the differences between consumer needs in Minnesota and in California. California may have taken the Lakers, but Los Angeles is a hot desert, and Sacramento does not understand or consider the needs of the people of the Land of 10,000 Lakes.
The proposed mandate in question would require car manufacturers to send the same percentage of electric vehicles to Minnesota as they send to car dealerships in California. However, consumer car purchases in Minnesota look very different from those in California, because the needs of Minnesotans are very different from those of Californians. Moreover, the current selection of electric vehicles available are not compatible with the needs of Minnesota’s consumers.
Electric vehicles currently make up only 1.5% of total vehicle purchases in Minnesota, and only 5% of Minnesota residents believe they are very likely to consider buying an electric vehicle.1 Work vehicles such as pickup trucks are not yet available as ZEVs, and though some
1 Minnesota Automobile Dealers Association, “Survey Results,” https://www.mada.org/userfiles/fck/file/Media%20Fact%20Sheet%20on%20Poll%20Results_FINALV2.pdf, accessed on February 22, 2021.
are expected in the next year or so, the price tags will be quite high. Weather is particularly important when judging the usefulness of ZEVs.
Californians do not generally require the same range for driving as many Minnesotans. A new ZEV may have a range of 200 to 350 miles per charge and then require a charge than can take well over half an hour. In California, urban lifestyles lend themselves more to ZEV usage, but Minnesotans are more likely to live outside of big cities. According to the 2010 census, 95% of Californians lived in urban areas while only 73% of Minnesotans did.2 Moreover, Minnesota lacks the advanced charging infrastructure to make it easy to recharge ZEVs mid-trip. For instance, there are still no DC fast charging stations in the southwestern part of Minnesota. In the winter, ZEV range is even further decreased in cold climates, like Minnesota’s. ZEV batteries are drained trying to heat the vehicle, because there is no natural heat from the engine to protect the passengers. Of course, this is a problem that most of California does not worry about. And, of course, extreme cold has been known to kill batteries in parked vehicles.
Electric Vehicles are still significantly more expensive than traditional internal combustion engine vehicles. According to a study examining the numbers, in 2019 the average cost of a consumer electric vehicle was $55,600, while the average retail price for all consumer vehicles (including electric) was only $36,600.3 Perhaps there are enough families willing to spend that kind of money in California, but it does not mean the same is true in Minnesota. In California, 7.7% of households (more than 1 million households) have over $1 million in investible assets,4 but in Minnesota that number is only 6.76%.5
This proposed mandate would further raise the cost of all vehicles in Minnesota. It would mean more expensive new internal combustion engine vehicles, and it would mean more expensive used vehicles. Minnesota car dealerships would likely end up with over 18,000 electric vehicles sent to their lots annually.6 By forcing dealerships to devote a predetermined percent of their inventories to ZEVs, this regulation would raise the cost of all vehicle purchases in the state.
There would be fewer new internal combustion vehicles (the preferred choice of Minnesotans) available. As supply decreases, prices rise. Moreover, since dealers would be forced to hold ZEVs on their lot instead of moving inventory, the dealers would seek to raise the cost of any vehicles that were selling—such as internal combustion vehicles—so that they could meet expenses and maintain profits. Furthermore, higher prices for new cars means higher demand for used cars as more people are priced out of the new cars they desire. That raises
2 Iowa State University Iowa Community Indicators Program, “Urban Percentage of the Population for States, Historical,” https://www.icip.iastate.edu/tables/population/urban-pct-states, accessed February 22. 2021. 3 Michael J. Coran, “The median electric car in the US is getting cheaper,” Quartz, August 27, 2019, https://qz.com/1695602/the-average-electric-vehicle-is-getting-cheaper-in-the-us/, accessed February 22, 2021. 4 Paige Austin, “CA Millionaires: Where We Rank With The Rest Of The US,” Patch, February 1, 2019, https://patch.com/california/hollywood/california-millionaires-where-we-rank-rest-us, accessed February 22, 2021. 5 Ibid. 6 “Car dealers ask Walz to pause standards,” The Journal, February 5, 2021, https://www.nujournal.com/news/agribusiness/2021/02/05/car-dealers-ask-walz-to-pause-standards/, accessed February 22, 2021.
demand on used cars and increases the price of used cars. Thus, this regulation would make vehicle purchases in the state more expensive, harming Minnesota families and consumers.
Perhaps the only cars that may see lower prices are the ZEVs themselves, only because at their price and with their characteristics they will not be desired by enough Minnesotans. If that is the case, Minnesota dealers could be a retail point for out-of-state ZEV consumers looking to get a deal. It is quite likely that this regulation would actually lead to discounts of ZEVs for wealthy consumers inside and outside of Minnesota and price hikes on vehicles for the vast majority of Minnesota families who cannot consider ZEVs because of their driving/work needs, the climate in Minnesota, and/or the still prohibitive ZEV cost.
Finally, Minnesota’s power supply negates much of the perceived benefit of ZEV adoption. The supposed environmental benefits of ZEV use purportedly come from using battery power instead of gasoline. However, batteries must be charged, and in Minnesota the electric grid is not always as clean as we believe.7 Take one recent day for example: February 21, 2021. According to the United State Department of Energy’s Energy Information Administration, on that day 50% of all electricity needs were met by burning coal.8 Instead of gasoline, a Minnesota resident may be powering her electric vehicle largely on coal, a much dirtier fuel, which is more harmful for the environment over its lifespan. Some advocates of the ZEV mandate seem to support it for the alleged benefits for air quality, but increased use of battery powered cars in Minnesota means and increased need for electricity, which means more air pollution. This undercuts the arguments by proponents of the proposed mandate who allege the increased use of battery-powered electric vehicles would have a significant positive effect on improving Minnesota’s air quality.
This proposed regulation would be a negative choice for Minnesota and its residents. California is a different state with different priorities and needs and characteristics. For the most part, ZEVs available today are not what Minnesotans want or need. This regulation would create a terrible financial strain on Minnesota families. And electric cars are not the clean energy panacea they are sold as. For these reasons, the regulation should not be adopted.
Sincerely,
Ellen R. Wald Ph.D. [email protected]
7 Elizabeth Dunbar, “Minnesota’s departure from coal will mean more natural gas and nuclear,” MPRNews, May 28, 2019, https://www.mprnews.org/story/2019/05/28/minnesota-energy-pie-transition, accessed February 24, 2021. 8 United States Energy Information Administration, Hourly Electric Grid Monitor, accessed February 22, 2021.
Emily Ziring Attachment
February 10, 2021
Honorable Jessica A. Palmer-Denig Administrative Law Judge Office of Administrative Hearings P.O. Box 64620 St. Paul, Minnesota 55164-0620
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:
The City of St. Louis Park appreciates the opportunity to comment on the proposed rule amendments known as Clean Cars Minnesota.
We support the adoption of Clean Cars Minnesota to achieve both local and state climate goals. The City of St. Louis Park’s Climate Action Plan aims to achieve carbon neutrality by 2040, and an interim goal includes reducing vehicle emissions by 25% by 2030. Without greater consumer choice in electric vehicles (EVs) and stricter tailpipe emissions standards, reaching this goal will be much more difficult. Transportation is the largest source of greenhouse gas (GHG) emissions in the state, but if adopted, by 2030 these rule amendments could reduce emissions annually by one million metric tons, helping the state make significant progress towards the GHG reduction goals of the 2007 Next Generation Energy Act—and that’s before including the effect of powering EVs with carbon-free electricity, which is a larger and larger source of Minnesota’s energy every year.
Many Black, Indigenous and People of Color, low-income residents, children, elderly residents, and those with cardiorespiratory conditions are particularly vulnerable to air pollution. Clean Cars Minnesota is a key step towards improving health outcomes for communities disproportionately impacted by tailpipe emissions. EVs can save drivers money over the lifetime of the vehicle; EV maintenance and operating costs are almost always less than gas-powered vehicles’ costs. Finally, clean energy job creation (such as EV charging station installers) will be important to our post-pandemic economic recovery. Clean Cars Minnesota is a win for our most vulnerable residents, our economy and our environment.
We encourage Minnesota to continue to serve as a sustainability leader and join the fourteen states and District of Columbia that have already adopted Clean Car Standards. Minnesota is experiencing the effects of climate change in every corner of the state and it is past time to mitigate the transportation-related causes of this crisis. Clean Cars Minnesota plays a crucial role in meeting climate action goals while benefitting our economy and the health of everyone across the state.
Sincerely,
Jake Spano Mayor City of St. Louis Park
CC: City of St. Louis Park Environment and Sustainability Commission members
St. Louis Park City Hall • 5005 Minnetonka Blvd., St. Louis Park, MN 55416 www.stlouispark.org • Phone: 952.924.2500 • TTY: 952.924.2518 February 10th, 2021 Erik Lundstrom Attachment
To: ALJ Jessica A. Palmer-Denig Minnesota Pollution Control Agency OAH, 600 N. Robert St., P.O. Box 64620 St. Paul, MN 55164-0620
Regarding Minnesota Pollution Control Agency’s 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 Jessica A. Palmer-Denig
Thank you for taking time to read my comment. My name is Erik Lundstrom. I am a student currently studying marketing and minoring in sustainability at the University of Minnesota Duluth. I am very interested in new policies and rules being enacted to help protect our natural resources, water, air quality and our citizens. With the change of administration at the White House this year. I am excited to see a push to create a brighter future for all by creating more effective policies to protect the citizens of our wonderful state and nation.
After reading through Clean Cars Minnesota, chapter 7023, I feel the proposed adoption would provide great benefits to the citizens of Minnesota. Minnesota has always taken pride in being a leader in protecting the environment and nature that brings us joy each and every day. We take pride in our natural spaces and waters. This is why it is so important for us to put rules and regulations in place that can help preserve our state’s beauty and our citizens' health. There are many health benefits that can be found in improving the emission standards and regulations within our state. “Air pollution increases the likelihood of citizens developing respiratory issues, such as asthma and bronchitis, along with cancer and other serious ailments” (Union of Concerned Scientists, 2014). It is staggering to see that “particulate matter, created by pollution, is responsible for around 30,000 premature deaths each year” (Union of Concerned Scientists, 2014). We need to work towards reducing the number of people affected by these ailments. This one area alone could save hundreds of lives if sufficient actions are taken to reduce the amount of pollution and particulate matter being spread into our atmosphere. https://www.ucsusa.org/resources/vehicles-air-pollution-human-health
I strongly support the adoption of California’s stricter greenhouse gas emission standards on “light-duty and medium-duty vehicles” There have been many improvements in vehicle efficiency and cleanliness over the years, “as many as 30% of new vehicles sport fuel efficiency of 30 miles per gallon” (Office of Energy Efficiency & Renewable Energy, 2020). Increasing the standards will push our auto makers to improve their products and create innovations that will improve our transportation and the health of Minnesotans. We will not be the first state to enact these stricter standards. I think it is valuable to look at how California has seen success with creating stricter laws surrounding motor vehicles. California set these stricter laws in “2012, on medium sized vehicles and trucks, to limit greenhouse emissions and reduce the amount of smog being created” (California Air Resources Board, 2019). With their changes in place, “from 2014 through 2019 California saw a 75% reduction of smog-forming pollution” (California Air Resources Board, 2019). When comparing the amount of greenhouse gas emissions, “there were 40% less greenhouse gasses emitted in 2019 than in 2016” (California Air Resources Board, 2019). https://www.energy.gov/eere/articles/wheels-keep-turning-innovations-more-efficient-an d-clean-vehicles-0 https://ww2.arb.ca.gov/sites/default/files/2019-09/California_Waiver_General-Backgroun d-091719.pdf
I strongly support the requirement for auto makers to “deliver automobiles for sale in Minnesota that meet the more stringent pollution standards, and a percentage of zero emission vehicles” In order for this rule to be successful there needs to be vehicles for sale that meet or exceed the standards that are being enforced. With a greater amount of zero emission vehicles sold, there will be a larger percentage found on the roads. These vehicles will be the future. Adopting a greater number of electric vehicles will only put Minnesota ahead on the road to sustainability. Minnesota should lead the way in reducing pollution and carbon placed into the atmosphere by humans.
There are many benefits to switching to electric vehicles for our state. A problem that will become more severe due to climate change is the concentration of ozone (smog) in our air. As “temperatures increase due to global warming, the chemical reactions that create ozone will be accelerated” (Union of Concerned Scientists, 2020). With the increasing pressures of climate change the push for electric vehicles should be at the forefront of our states efforts. Electric cars create around “15% greater emissions than conventional cars during the manufacturing process but once on the road its emissions are equivalent to getting 88 miles per gallon” (David Reichmuth, 2020). This mileage is double of almost every petrol powered car on the road today. With this significant improvement in emissions, our air, water and health can benefit greatly. https://www.nrcm.org/wp-content/uploads/2013/09/UCS_factsheet_Ozone_ME.pdf https://blog.ucsusa.org/dave-reichmuth/are-electric-vehicles-really-better-for-the-climate -yes-heres-why
In conclusion, this clean car rule will be the first of many upcoming changes to our state’s rules and regulations that will need to be made as we progress toward a more sustainable future. I think it is very important for Minnesota to lead the way in making these changes. With our amazing citizens, natural wonders, pristine waters and progressive attitude, we can create a brighter future for all.
Sincerely,
Erik Lundstrom Eyal Li Attachment From: Janessa Palmer M.A./M.S.
Subject: Clean Cars Minnesota for My Future
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. Data from the 14 other states that have implemented these type of clean car programs shows that a low and zero-emission vehicle program will help curb global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. The zero-emission vehicle program in particular will help increase the availability of electric vehicles across the state, enabling more potential buyers to test drive and purchase these vehicles. It's time for Minnesota to get serious about curbing heat-trapping emissions and transportation pollution.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jenna Yeakle M.P.H. candidate
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
As a public health professional, I am writing to express my support for the Clean Cars Minnesota rule. It is a common-sense standard that is way past due for our state. Data from the 14 other states that have implemented these type of clean car programs shows that a low and zero-emission vehicle program will help curb global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. The zero-emission vehicle program in particular will help increase the availability of electric vehicles across the state, enabling more potential buyers to test drive and purchase these vehicles. It's time for Minnesota to get serious about curbing heat-trapping emissions and transportation pollution.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: David Moseman J.D.
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
As a physician who had to watch many persons die slowly of lung diseases and similar illnesses I know that the Clean Cars rules will not only save lives but also reduce the suffering of many. I am writing to express my support for the Clean Cars Minnesota rule. Data from the 14 other states that have implemented these type of clean car programs shows that a low and zero-emission vehicle program will help curb global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. The zero-emission vehicle program in particular will help increase the availability of electric vehicles across the state, enabling more potential buyers to test drive and purchase these vehicles. It's time for Minnesota to get serious about curbing heat-trapping emissions and transportation pollution.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Craig Christenson B.A./B.S.
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. Data from the 14 other states that have implemented these type of clean car programs shows that a low and zero-emission vehicle program will help curb global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. The zero-emission vehicle program in particular will help increase the availability of electric vehicles across the state, enabling more potential buyers to test drive and purchase these vehicles. It's time for Minnesota to get serious about curbing heat-trapping emissions and transportation pollution.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Ann Miller B.A./B.S.
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. Data from the 14 other states that have implemented these type of clean car programs shows that a low and zero-emission vehicle program will help curb global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. The zero-emission vehicle program in particular will help increase the availability of electric vehicles across the state, enabling more potential buyers to test drive and purchase these vehicles. It's time for Minnesota to get serious about curbing heat-trapping emissions and transportation pollution.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jerry Dawson M.D.
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. Data from the 14 other states that have implemented these type of clean car programs shows that a low and zero-emission vehicle program will help curb global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. The zero-emission vehicle program in particular will help increase the availability of electric vehicles across the state, enabling more potential buyers to test drive and purchase these vehicles. It's time for Minnesota to get serious about curbing heat-trapping emissions and transportation pollution.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Terrence Nayes M.B.A.
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. Data from the 14 other states that have implemented these type of clean car programs shows that a low and zero-emission vehicle program will help curb global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. The zero-emission vehicle program in particular will help increase the availability of electric vehicles across the state, enabling more potential buyers to test drive and purchase these vehicles. It's time for Minnesota to get serious about curbing heat-trapping emissions and transportation pollution.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Brent Bateman
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my strong support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Paul Chmelik
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. I believe that supporting this rule is a tangible way to improve the health of Minnesotans and to contribute to the healing of our environment. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Ed Arenz
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. This initiative so so very important and should be a priority!
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Kate Crowley
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
As a grandparent who is concerned about the future of my grandchildren, I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Eleanor Wagner
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am very concerned about climate change and believe we need to take dramatic action to reverse global warming. I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Bob Bartlett
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
The world is being fuel efficient vehicles. Climate wise and economically wise to produce more fuel efficient vehicles. We could be the world leaders with our technology. I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Karin McAdams
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. Changing the vehicles we drive is one of the best ways for ordinary citizens like myself to help keep Minnesota air clean. I moved here recently, and I'm pleased by the policies that I'm hearing about in this fine state. This low and zero- emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: GAIL FRANCIS
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule, together with support for transit. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota, together with investment in transit, is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Marian Severt
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I support for the Clean Cars Minnesota rule. Global warming emissions from Minnesota's passenger vehicle fleet can and must be reduced. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The science is clear. Now is past the time for action. Thank you for your attention to this very serious matter.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Julie Guth
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. The time has come for us to contribute to solving the problem of pollution, and this is one positive step toward fulfilling our responsibility as a state. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Maynard Johnson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. My four granddaughters deserve a clean and safe future. We, as parents, grandparents -- i.e., 'the adults in the room' -- must act decisively to try to avert the worst effects of climate change before it's too late.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Bruce O'Brien
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. As a retired RN, with forty years of hospital experience, I have expanded my advocacy beyond my patients to include vulnerable people everywhere. As an empathic person, I am deeply concerned about, and can no longer ignore, the growing and tragic evidence that human lifestyle is destroying our Climate. A climate that does not function is already causing loss of life around the globe and will continue to do so. Minnesota is already seeing effects of accelerating climate destruction. If there are ways we can make changes in our lives to save lives, why would we not do them? The low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Sue Halligan
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global-warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Janet Ciegler
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. Car manufacturers are making all-electric cars. Minnesota needs to have incentives for buying these, and needs to phase out purchase of polluting cars. If California can do it, so can we!
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Neil Libson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. As an owner of an all electric vehicle I can testify to the many benefits as described above. I feel good knowing I am doing my small part in helping the environment, protecting my grandchildren and saving money along the way. Most major car manufacturers are transitioning to electric vehicles because they know the internal combustion engine is going the way of the horse drawn carriage. As caring Minnesota citizens we need to encourage and embrace this new reality! The benefits of doing so far outweigh the concerns. Thanks for your support. Neil Libson Chanhassen, MN
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: John AND Jean Fleming
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. Regards, John AND Jean Fleming
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Keith Thompson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. The technology for lower emissions is there, but not being utilized because of the profit margins the industry has maintained. Should health costs be factored in we could see enormous savings both in the day to day costs of transportation and the longterm healthcare benefits.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Karen Larson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am in support of the Clean Cars Minnesota rule. It is a logical and manageable next step in addressing carbon pollution and climate change. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. Thank you for hearing my comment.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Stewart Herman
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
AS the owner of a plug-in hybrid that I charge from my rooftop solar collectors, I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Melissae Bletsian
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. And there needs to be a program to help low income Minnesotans meet these standards as well. We can't just pass another bill that ignores low income people and thus, once again, criminalizes poverty. So this is a great ideal, and I support it, so long as you are lifting up ALL Minnesotans, not just the ones with free flowing cash.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Debbie Schlinger
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. I lived in San Jose, California for many years. During that time, they cleaned up their act. The air was noticeably cleaner. Before, my eyes watered and burned daily.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Nathan Zerbe
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I support the proposed Clean Cars Minnesota rule as an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Arlene Renshaw
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. For the future of every Minnesotan we must take the threat of air pollution more seriously than at present. The Clean Cars rule will give us an excellent start.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Kelsey Cramer
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
Dear Judge Palmer-Denig, I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Gary Schettl
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
My wife and I have already driven over 250,000 miles in all-electric cars here in Minnesota. I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Patrick Smith
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. This seems like a no- brainer, especially regarding the issue of climate change and lowering Minnesota's overall carbon footprint. We should strive to be the model that other states follow in regards to how we work to mitigate this issue. Thank you for your consideration.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jeffrey Nelson
Subject: Please adopt the Clean Cars Minnesota rule for the sake of all of us
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. I have been a family physician working in Cottage Grove, Minnesota from 1982 until I retired last August. I have been following the issue of protecting the environment for all of us and global warming since the 1970s. For the sake of our children and grandchildren, but even for ourselves, we must make much faster progress towards the goal of being carbon neutral in our society. We actually must work toward reducing the CO2 level because even if we stop raising it today, the level is high enough to cause continued global warming for centuries. As a family physician I always advocated for the health of my patients. In my retirement, I want to continue to do so. The Clean Cars Minnesota rule helps us to head in that direction. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Tim Bardell
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. For over 20 years my wife and I have lived one block east of Highway 100 and less than 1 mile south of I-394 - well within the area affected by vehicle pollution. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Dave Crawford
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. I support greater availability of low and zero-emission vehicles for drivers in Minnesota. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Ben Gorman
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program is an obvious and long-overdue step that will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Lois Swanson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. Global warming was pretty apparent in the weather report today in California, Alabama and Florida.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Elizabeth Songalia
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. I live in St. Paul, have solar panels on my property, and own a hybrid vehicle. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Clare Larkin
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Brian Thielke
Subject: We should adopt the Clean Cars rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I support the Clean Cars Minnesota rule for two key reasons: 1). Air pollution from vehicles is an asthma trigger for me and it can make it difficult to breath when exposed to these emissions. We need to do more to improve our air quality and this rule will help. 2). Global warming is now a climate crisis and it is only getting worse. This will leave the next generation (our children and grandchildren) with countless negative circumstances (floods, extreme heat, species loss, etc.). Minnesota set a goal in 2007 to reduce its total greenhouse gas emissions 80 percent by 2050, but is not on track to reach the goal. The Clean Car rule will help us meet this goal. The externalities of air pollution must be accounted for to protect public health and the environment.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: George Bentley
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. We need to take firm and attainable steps to aim at achieving zero carbon emissions. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Judith Weir
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. Getting electric loading stations out on the road is also much needed. Please speed this up.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Michael Shoop
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. I am sick and tired of being told by local car dealers, 'We do not sell or service that car in Minnesota' I should be able to buy the same electric cars that people can buy in CA!
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Clifford Patrick
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule, for 3 reasons. Efficiency, consumer cost benefits & carbon reduction. I drive a hybrid enjoying 60MPG on summer trips while my son enjoys 77 miles on $ .77 cents via off peak charging his EV. (Summer driving). Winter driving the hybrid, 37-50 MPG, 50 miles on the EV. EV is to transportation what the auto car was to the horse carriage. Same purpose, different world in efficiency, support net work, speed & cost. GRE, Great River Energy predicts a 13% decrease in costs via 93% green energy in 3-5 years. Progress. Thank You. Clifford Patrick Villard, Minnesota 320-232-9057
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Fred Graszer
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. I also know we can raise the gas tax to help pay for this decision and am in favor of that. Anyone who can't afford an extra hundred or two hundred dollars per year on gas should get a more efficient car and/or drive less.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: JOHN GABBERT
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. Indeed, we need to begin now.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Cynthia Reuss
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. I assume that curbing air pollution would also help other animal life that have to breath the air we humans have polluted.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Joan Felling
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. Polluted air makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. Please adopt the Clean Cars Minnesota rule to start cleaning up our air pollution. Thank you! Sincerely, Joan Felling
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Julie Pierson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. Our cities air quality is getting worse everyday and this is just the beginning. Better mass transit opportunities needed.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Leslie McDonald
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. The Metro Bus service committed to replacing their fleet with all electric, but is now trying to back out of that promise. We can't stop kicking the problem down the road - we made the problem! It's here! It's time to actively turn the situation around, and that means spend the money to make the needed changes and protect our air and climate. NOW.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Peggy Roeske
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. Since I no longer have my car, a friend of mine has taken me to a number of church and related activities. She has a Toyota Prius hybrid, and I was always surprised at how quiet and pollution free it ran when it started up. I would like to see more people drive hybrid and totally electric cars. The state's low- and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state because of climate change. They shouldn't spew pollutants that make it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Alan Fiene
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. Clean air is absolutely essential to healthy people.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Julie Smalley
Subject: I support the Minnesota Clean Cars rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I support for the Clean Cars Minnesota rule in order to address the climate change crisis and decrease air pollution.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Roland Rauenhorst
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. Electric vehicles are viable and have been since Tesla introduced the Model S in 2012 and they have become affordable since Tesla introduced the model 3 and model Y in the last few years. Almost all major auto manufacturers are now playing catch up. We should do all we can to promote fast charging infrastructure to allow recharging electric vehicles as convenient and common as gas stations. As I see it electric powered vehicles, large battery storage installations, wind and solar produced energy are what we need to invest in for a sustainable future. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Katha Ricciardi
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
Protect the environment and the air we breathe. Clean Cars for Minnesota! Yes! I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Lenore Healey Schultz
Subject: The Clean Cars Minnesota rule - a rule that should be adopted!
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. Future generations will thank us. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Susan Kallman
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. 13 other states have adopted similar programs. I'd love to see Minnesota join these forward- thinking states.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Bridgette Jessen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. Thank you sincerely for your time and attention to this important issue.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Grant Tiefenbruck
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. Minnesota needs more electric vehicles to reduce carbon dioxide emissions and noise, especially in the metropolitan areas. These electric vehicles should be incentivized.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Ann Burns
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
As the owner of both a gas-powered vehicle and an zero-emission electric vehicle, I enthusiastically support the MPCA’s adoption of both low-emission and zero-emission vehicle emission standards (the Clean Cars Rule) because doing so will: (1) help clean our air and improve Minnesotans’ health; (2) give consumers more choices, save Minnesotans’ money, and boost our economy; and (3) help move Minnesota forward in addressing our worsening climate crisis. First, the Clean Cars Rule would reduce tailpipe emissions from new cars and light-duty trucks, thereby reducing the harm that these emissions cause Minnesotans. Poor air quality contributes to between 2,000 and 4,000 premature deaths, 500 hospitalizations, and 800 emergency room visits each year. Second, when I bought my electric vehicle (a Chevy Bolt) in 2019, as a resident of rural Minnesota I had limited choices about where to shop and what to buy. While automakers have announced plans for dozens of new electric vehicles in the next 5 years (crossover vehicles, SUVs, and pick-up trucks), in Minnesota we can currently find only about half of the electric vehicles on the market. Minnesota car buyers have limited electric vehicle options because automakers have prioritized states with advanced Clean Car standards. A recent study found that 6 in 10 prospective car buyers in Minnesota are interested in electric vehicles – heck, my husband says that our ZEV is the best car he has ever driven in his 50-years of driving. Our consumers deserve more choices, and the Clean Cars Rule will help get us there. Further, I can personally attest to the fact that electricity as a fuel source is less expensive, and the pricing is more stable, than gasoline. Electric vehicles are 3 to 4 times more efficient than internal combustion engine vehicles; my fuel costs reflect this efficiency. I have saved between $200 and $300 per month since purchasing an EV – and again, I live in a rural area. My maintenance and repair costs are more than 60% lower due to simpler mechanics. Adopting Clean Car standards would save the average Minnesota family nearly $3,000 by 2030. The economic downturn caused by the pandemic provides Minnesota an opportunity to rethink the way we rebuild a more sustainable, equitable, and carbon free economy. Clean Car standards and the charging infrastructure needed to support EVs will help build back our economy. A study by the Union of Concerned Scientists found that the money Minnesota families would save and pump back into the economy would get people back to work and create nearly 13,000 new jobs. Third, our transportation sector is the largest source of carbon pollution in our state; it is imperative that we seize this tremendous opportunity to take action to shift Minnesota away from fossil-fueled travel. These rules are critical to making progress to achieve climate targets. Unless we commit to take action to meet them, we will condemn our children and grandchildren to a dangerous future. Minnesota should join the14 states and the District of Columbia that have adopted these standards. Already the Clean Car Rules have a successful track record of reducing carbon emissions, cleaning up the air, and saving consumers money.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Robert Andrews
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality. There are some cleaner cars that are not available to Minnesotans, because we are not part of the clean cars rules. We need to adopt Clean Cars Minnesota rule to make them available.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Sharon Stork
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. My husband and I recently moved here from Ohio with our hybrid Honda sedan, so we are already doing our part! Please do yours by adopting this rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Angela Anderson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Mary Alice Richardson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Charles Fitze
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Erin Enger
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Paul Norton
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Karrie Vrabel
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Elizabeth Therkilsen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Erik Roth
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Mari Hirabayashi
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Matt Ringquist
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Stefanie Weisgram
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Ruth Heller
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Bob Cutshall
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Dick Ottman
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Ordell Vee
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Madeline Troyer
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: JL Charrier
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Vicki Drake
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Judi Poulson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Gustavo Gomez
Subject: Please adopt the Clean Cars Minnesota rule.This is a critical issue for making Minnesota green.
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Marcia Peck
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Fred Green
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Glenn Kuschke
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Neal Skorpen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Rick Priebe
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Susan Roverud
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Allen Gibas
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Carol Miller
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Colleen Joe - UCS O'Meara
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Elizabeth Eide
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Dorothy Brown
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Norm Herron
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jennifer Schally
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Paul and Margaret Heffron
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jay Roth
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Michael Favero
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Catherine Iliff
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Thomas Bretl
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Debra Swanson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Patrick Doss-Smith
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Gaius Poehler
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Richard Bjorum
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Frances Bell
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: John and Virginia an Kunz
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Andrew Willman
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Gerald Nolte
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Nell Ubbelohde
Subject: Please adopt the Clean Cars Minnesota rule Help save our Home!
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Patricia Keefe
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Benjamin Hart
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Donna Seabloom
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Laura Brubaker
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Joe Culver
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Ryan Baka
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Judith MacKenzie
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Laura Landstad
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Elizabeth Paulson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Mark L. Nelson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Don Quest
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Kenneth Kaseforth
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Sandra Kuschel
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Gerald Wambach
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Kay Schoenwetter
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Shawn Kakuk
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Harvey Bartz
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: WILLIAM STAUFFER
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Tracy Anderson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Pat Lang
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Margaret Sines
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jerry Fitzgerald
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Edna Mullen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jack Enblom
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Diane Glorvigen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Julie Morris
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: John Kolstoe
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Geoffrey Saign
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jane Truhlar
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Denise Fogel
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Alan Fiene
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Frank Bures
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Dudley Parkinson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Lisa Leonard
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Rachel Imholte
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Barb Powell
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: James Bartsias
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Patricia Nelson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Joan Hughes
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Sara-Jane Wilson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Juli Bratvold
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: AMY GRACE
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Susan Macpherson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Melissa Hochstetler
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jim O'Toole
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Juliann Rule
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Richard Holcomb
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Marion Potyondy
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Edward Matheson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Charles Favorite
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Linda Weber
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Murray Smart
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Heather Hundt
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Diane Tessari
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jennifer Rials
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Vernon Hill
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Richard Cardinal
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Garrett Butler
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Charles Favorite
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jim Marsden
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Gretchen Corkrean
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Cole Jegen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Eric Benson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Douglas Harkins
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Carol Bechtel
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Ann White
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Robin Nicholson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: lucy elliott
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Charley Hopkins
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Mike Mooney
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Betsey Porter
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: patrick zalusky
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Brian Krysinski
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Mickey Garza
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Kenneth Stewart
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Kari Stringer
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Lawrence Landherr
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Philip Rampi
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Nancy Hansen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Laurence Margolis
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Peppi Enos
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Mark Floyd
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Angela Hansen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: George Muellner
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Bryan McCullough
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Alva Crom
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Frank Jewell
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jackie Holmbeck
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Kim Tostenson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Karen Hildebrandt
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: William Gotz
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Carol Ashley Ashley
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Kevin Nguyen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Arthur Rosenberg
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jim Bungarden
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Trina Joyce
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Barbara Dennis
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Irene Bussjaeger
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Peter Melka
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Janine Morgan
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Pat Whebbe
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Michael Chutich
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Elaine Thandet
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Aaron Mlynek
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jack Carrick
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Elizabeth Merryman
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Janet Neihart
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Carol Anderson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Susan O'Donnell
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Mary Faulkner
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Candace Marx
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Natalie Stephens
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Pamela Endean
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jennifer Krinke
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Lynn C. Lang
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Sheila Tran
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Federico Rossi
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Laura Regan
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Steve Vizecky
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Nancy Engelhardt
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Joshua Lies
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Anna Darland
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Janet Roemer
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: saraphine metis
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Florence Steichen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: jason husby
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Nicholas Henke
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Deborah L Steinmetz
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: James Schoettler
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Robert Chase
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Elizabeth Ishmael
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jeanne Nordland
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Rebecca Klotz
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Karen Rex
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Marvin Bunnell
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Heyward Nash
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Heyward Nash
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: theresa del rosario
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Michael Mc Cormick
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Norma Jean Falink
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Bree M
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Gretchen Bratvold
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Nancy Johnson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Scot Westphal
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Matthew Saxe
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Nancy Hauer
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Melissa Cathcart
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jean Ross
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Cara Gubrud
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Mary Creighton
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Michael Erickson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Kimberly Swenson-Zakula
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Bob Hoffman
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: kimberly nieman
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Terrance Hyk
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Shirley Espeland
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Joel Clasemann
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: LaVonne Rathsack
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Ramona Kopnick
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: India Kelley
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Edward Cohen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: April Narcisse
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Linda Kollman
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Anthony James
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Brian Thorbjornsen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Doug Stevens
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Pat Ament
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Rebecca Shedd
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Sue Morem
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Sue Morem
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jeffrey Horejsi
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Barbara Border
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Ann Marie
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Tim Wallace
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Harriet McCleary
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Barbara Thomborson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Roberto Gutiérrez
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Sandra Schilling
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Betsy Olson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Steve Steele
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Joseph Wenzel
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Mary Madeco-Smith
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Denise Bobst
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Justin Smith
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Theresa Beckhusen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Sarah Schulz
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Stacie Spaeth
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Brandon Allen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Colleen Joe - Menend O'Meara
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Kathy Moraski
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Susan O'Donnell
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Ricco Venterea
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Julie Viken
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Paul Norton
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: james may
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Robert Kriesel
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Judy Rockne
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Amanda Busch
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Laura Dalin
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Steve George
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Elizabeth Paulson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Duane Reichert
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jon Hayman
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Craig Blacklock Blacklock
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Lynda Pauling
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Liz Tempel
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Carol Taylor
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Richard Bjorum
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Franz Kitzberger Kitzberger
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Daniel Vogel
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Laura Kramer
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Gretchen Corkrean
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Ronald Johnson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: John McKenzie
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Daniel Herman
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Starr Jarvis
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Barbara Brockway
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Peggy Endres
Subject: We need Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Christy Spear
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Charles Favorite
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Linda Mitchell
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Joan O'Connor
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Martha Baxter
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Roxanne Friedenfels
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Judy Peterson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Tracy Templin
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Mina Blyly-Strauss
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Dawn Baker
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Steve Vizecky
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Debra Johnson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Patrick Cruit
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Benjamin Hart
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Kelley Raisanen
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Sue and
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Ralph Pamperin
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: LouAnn Lanning
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Paul Densmore
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jennifer Schmidt
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Ann Tucker
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Shelly Kepler
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Kathy Dunn
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Jane Galbraith
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Patricia Thielman
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Lucy Grina
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: CHRISTOPHER WRIGHT
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: September Steinolfson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Mark Carlson
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Rebecca Pelton
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: David Walsh
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Tim Whitley
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Kathleen Hutchins
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Mary Miller
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Cheri Haram
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Gary LaMaster
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Terrence Nayes
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Rodney Hemmila
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Elaine Thander
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: theresa del rosario
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: John Hartjes
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system. From: Cynthia Miller
Subject: Please adopt the Clean Cars Minnesota rule
Dear Administrative Law Judge Jessica Palmer-Denig:
I am writing to express my support for the Clean Cars Minnesota rule. This low and zero-emission vehicle program will help draw down global warming emissions from Minnesota's passenger vehicle fleet, while improving air quality and providing substantial savings for drivers. Clean Cars Minnesota is an effective policy to address the dual crisis of climate change and the harmful health impacts of air pollution. The cars and trucks Minnesotans drive to work, school, and other activities should not contribute to the floods and extreme heat faced by communities across the state. They shouldn't spew pollutants that makes it hard for many Minnesotans to breathe, especially children, the elderly, and those with respiratory conditions who are more susceptible to poor air quality.
Please adopt the Clean Cars Minnesota rule to start cleaning up our transportation system.
Gary Caruso Attachment OHA Docket Number: 71-9003-36416
RE: Proposed Revisions to Minnesota Rules, Chapter 7023 Adopting Vehicle Greenhouse Gas Emissions Standards (Clean Cars Minnesota)
Dear Administrative Law Judge Palmer-Denig:
The risks of climate change are certainly real and the need to take bold and pragmatic action is clearly pressing. Like many people in Minnesota, including Governor Tim Walz, I am an advocate of responsible environmental stewardship and effective climate action. I am a senior advisor in the Energy Security and Climate Change Program at the Center for Strategic and International Studies, a Washington-based think tank. Prior to that, I was Administrator of the U.S. Energy Information Administration from 2002 to 2008. In 2018, I served as president of the U.S. Association for Energy Economics, a non-profit forum.
I write in regard to a proposed rule in Minnesota that would tie the state’s policy on electric vehicles to California’s Zero Emission Vehicle program. The rule, first recommended by the Minnesota Department of Transportation in August 2019, was this past December officially proposed by the Minnesota Pollution Control Agency. If implemented, the rule would require vehicle retailers in Minnesota to stock a certain number of electric vehicles, all for the purpose of mitigating the risks of climate change and improving public health through pollution reduction.
As someone who has devoted my career to prioritizing the reliance on credible and accurate data for informing sensible policymaking, particularly on climate-related issues, I was most very concerned to learn about the Minnesota Pollution Control Agency’s miscalculation of data related to a government mandate on dictating the sale of electric vehicles in the state. A series of miscalculations, all of which are now publicly available, was used by the agency to advance this mandate, which resulted in gross overstatements of environmental and health benefits and which distorted for the public and policy makers the value of the mandate itself.
First, the agency’s miscalculation grossly overstated the costs of particulate matter (PM) emissions, which are a mixture of solid particles and liquid droplets found in the air and a term used as a general proxy for air pollution. As the agency has now admitted by publication of its addendum to Statement of Need and Reasonableness, its calculations were off by any entire decimal point on their calculations of the PM tailpipe emissions rates. While the agency has attempted to minimize this error by stating that it “does not impact the overall need for and reasonableness of the rule,” the result is a significant distortion of the proposed rule’s effect on PM emissions.
For example, the agency initially projected that the electric vehicle mandate would reduce net cumulative well-to-wheel PM emissions by 3,245 tons over 10 years. After admitting its error, that number is just 552 tons. A page later on its addendum, on Page 4, the agency altered its table assessing “PM emissions costs and benefits from the proposed rules over time (with average electricity generation mix) in tons.” The result was that tailpipe emissions benefits were downgraded by a factor of about 10, and in many cases, far more. For 2025, the first year the rule would go fully into effect, the benefits were revised from 20.6 tons of PM emissions avoided to 2.1 tons. Looking at projections for 2034, the most distant year in the projections, the mandate’s projected benefits fell from 597.7 tons of PM emissions avoided to just 66.5 tons. This is a staggering difference. Second, the miscalculation had a similar effect on projections related to avoided health outcomes. On page 6 of the addendum, a table shows “Estimated health benefits of the proposed rule over first 10 years of implementation.” After the agency discovered and fixed its error, premature deaths avoided fell from as many as 348 lives saved to somewhere between 28 and 65. Another figure, respiratory emergency room visits, fell from 82 to just 15, while projections for work loss days fell from 18,453 to just 3,555. Regarding avoided asthma exacerbation, that figure was downgraded from 4,405 incidents to 857.
While every life in Minnesota is worth saving and every day of work lost hurts the economy, the differences in these projections are remarkable and the value for the state’s citizens much less attractive. Moreover, such basic errors and their extrapolations into specific data, e.g. lives saved, should lead officials to call into question the methodology used to determine this data. At the end of the day, the agency’s carelessness with data led to a remarkable overstatement of the mandate’s benefits, any of which were designed to emotionally appeal to citizens and policy makers alike.
Third, in addition to the overstatements of fact the agency has now admitted and revised, the agency has improperly and unprofessionally used data from Cars.com to make its case about the unavailability of electric vehicles for sale in Minnesota. As Amber Backus with the Minnesota Auto Dealers Association has explained, the agency’s reliance on Cars.com as a data source is inappropriate, as such data offers an inaccurate picture of electric vehicle unavailability.
“The MPCA vastly undercounts the EV supply by pulling data from cars.com. Cars.com is not an aggregator of vehicle supply,” Backus states. “It's a third party advertising platform dealers pay to use if they want to list their vehicles for sale.”
The use of this data distorts the reality in Minnesota when it comes to electric vehicles. The Minnesota Auto Dealers Association’s own analysis of electric vehicles pulled from manufacturer websites shows at least twice as many electric vehicles on Minnesota car lots as those listed on Cars.com. Furthermore, Backus explains that while the agency claims car lots in Duluth, Bemidji and Marshall had no electric vehicles available for sale on July 9, 2020, dealers themselves have affirmed that they did, in fact, have such cars on their lots for sale. But since those dealers don’t advertise on Cars.com, the agency overlooked those vehicles and, as a consequence, presented a false picture of reality.
Finally, it cannot be overlooked that the California model, on which Minnesota’s electric vehicle has been modeled, has itself overstated its own value. A February 23rd report from the California State Auditor has found that the California Air Resources Board (CARB) “has overstated the GHG emissions reductions its [low- and zero-emission vehicle] incentive programs have achieved.”
“One effect of this overstatement is to obscure the programs’ cost-effectiveness in reducing GHG emissions,” the report states. Even without making the basic errors the Minnesota Pollution Control Agency made in its calculations, California itself, ground zero for electric vehicle mandates, has overstated the benefits of its own mandate.
I believe that electric vehicles can be part of the climate change solution, but the miscalculations made by the Minnesota Pollution Control Agency are appalling and call into question the very basis of the rulemaking. If the agency made errors of such a basic nature in calculating benefits, what other basic misuse or miscalculations lie waiting to be discovered? At a minimum, this rule should be examined by the state legislature in a manner in which accurately depicts the costs and benefits so that all elected lawmakers can weigh in with a legislative approach rather than rush through with administrative rulemaking. In this case, such additional scrutiny and diligence seems warranted and necessary.
Sincerely,
Guy Caruso Former EIA Administrator (2002-08)
Jack Sewpersaud Attachment March 12, 2021
To Commissioner Laura Bishop The Minnesota Pollution Control Agency (MPCA) 520 Lafayette Rd St Paul, MN 55155
Regarding the Minnesota Pollution Control Agency “Proposed Permanent Rules Relating to Clean Cars, RD4626.”
From Jack Sewpersaud
Thank you for the opportunity to comment on the Minnesota clean cars initiative. My name is Jack Sewpersaud, and I am a second-year University of Minnesota undergraduate student studying political science and economics. As a citizen who likes to be environmentally conscious of my decisions as a person and consumer, I would like to express support for the proposed “Clean Cars” rule.
I believe that this rule has the potential to put Minnesota at the forefront of the electric vehicle and Zero-Emission Vehicle (ZEV) industry for the next few decades, while also aiding the state in accomplishing its climate goals set by Former Governor Tim
Pawlenty in 2005, to lower CO2 emissions by 30% by 2025 (Minnesota PCA, 2021). Currently, we are not on track to reach this initiative, and we already missed 2015’s target. If this rule is passed, not only would it help us to attain the goals set out in the Next Generation Energy Act, but it would be the first of its kind in the Midwest (Erwin, 2020), meaning we could become a leader in zero-emission vehicle regulations and sales in our region.
I support rule 7023.0300, the Zero-Emission Vehicle (ZEV) standards. I believe that not only will this help Minnesota reach its emission reduction goals, but will significantly help Minnesota consumers, both in the long and short-term. First, we examine the price in the long-term, as many consumers are potentially dissuaded from purchasing electric cars due to supposedly large price tags in the short-term. To examine the relationship between cost and time for gas versus electric vehicles, I derive the following equations:
Average Cost of running a gas-powered vehicle (GPV) vs a zero-emission vehicle (ZEV) over time (t, in years) in thousands of dollars can be found from the equations: (1) C(GPV) = 1.72(t)
1 These costs are derived from a 2020 NRDC Study (Palmer, 2020). (2) C(ZEV) = 0.78(t) While the cost equations above only account for the refueling and maintenance costs, or not taking into account the purchase price, even when factoring the purchase price in, zero-emission vehicles cost less every month compared to gas-powered vehicles. In a 2021 New York Times article, a study revealed that zero-emissions vehicles cost within the range of $275 per month to $590 per month, including purchase cost. On the other hand, gas-powered vehicles have a much larger range, from $275 to $790 per month (Penney, 2021). Overall, zero-emissions vehicles are much less expensive over time compared to gas-powered alternatives. However, there is a significant shortage in the market for electric vehicles considering these financial benefits, which means despite the savings, consumers who want to save money are not able to purchase as many zero-emission vehicles as they might like. That being said, in the short-term, immediately after implementing this rule, the price of these vehicles may increase, absent financial incentives to producers, or consumers.
If producers are asked to produce and supply electric or zero-emission vehicles at a quantity above the status quo equilibrium, then in the short term, we may see price increases for consumers as shown in the figure below:
Because the technology of these car producers will not improve immediately following implementation of the rule, short-term incentives must be provided to ensure the price is
2 These costs are derived from the same source as from the first equation. not cost-prohibitive for consumers to justify purchasing a zero-emission vehicle over a gas-powered vehicle. For consumers, this could include maintaining the current electric vehicle rebate. The current tax rebate from the federal government totals up to $7,500 for certain electric vehicles and plug-in hybrid electric vehicles produced between 2012 and 2021 (Environmental Protection Agency, 2021). This helps ensure consumers aren’t overwhelmed by the potentially higher prices as a higher quantity is required to be supplied, and incentivizes consumers to purchase electric vehicles. However, this potential increase in the price charged by suppliers might also be combated by another system already in place -- the ZEV credit system.
The ZEV credit banking system is already in place and has been implemented with other ZEV rules. This would allow car producers to earn credits for selling ZEVs to consumers in a given state. They are required to sell a certain amount of low-emission and zero-emission vehicles within a given year to comply with regulations. In 2019, this meant that approximately 3% of all major car companies’ sales in a given state had to be zero-emission vehicles. This 3% is broken into two categories. The first category, plug-in hybrid vehicles have to make up 43% or less of that 3% of sales, or approximately 1.3% of total yearly sales. The other 57% must be battery or hydrogen fuel cell electric vehicles (Union of Concerned Scientists, 2019). By 2025, projections from UCS state that this will likely rise to 8% of total sales, for an average increase of 1% of sales per year.
However, these producers are not restricted to these numbers and can produce more zero-emission vehicles to accumulate a surplus of credits. Those credits can then be sold to producers who were unable to produce the required level of zero-emission vehicles. This provides an important incentive for producers, to ensure that the price gap we may experience initially after adopting this rule does not become a long-term reality. By creating a market for these ZEV credits, we provide an incentive for auto manufacturers to innovate and improve electric vehicle technology in a shorter time period than usual to capitalize on a market that has reportedly “brought in $428 million in revenue” for Tesla in 2018 (Erwin, 2020). While these credits may not be valuable for long as more manufacturers enter the market and no longer need credits, the technology improvements they incentivize should help improve efficiency in producing cheaper zero-emission vehicles for consumers.
In the long-term, when the supply of current electric vehicles increases, we see that the price significantly decreases. In addition, increased technological advancements mean that the price to produce zero-emissions vehicles will also decrease since an increase in technological advancements means an increase in supply. Eventually, we see the market equilibrium looks something like the following graphic:
As the price decreases, we know that the quantity demanded by consumers increases, meaning we will see more ZEVs purchased, at more affordable prices. At the same time, we might expect the opposite to occur for gas-powered vehicles. If the ZEV rule is enacted, manufacturers will have to sell a certain percentage of zero-emission vehicles, meaning that as the relative percentage of ZEVs sold increases, the relative percentage of gas-powered vehicles being supplied and sold should decrease, thus increasing the price by some amount “p” and decreasing the quantity demanded. This means that the value equations change by some constant (represented in this equation by “Δp”) represented by the change in price. The new equations are as follows:
C(GPV) = Δp + 1.72(t) C(ZEV) = 0.78(t) - Δp
While we cannot put a determinate value on when these two equations may be equal in value, we know that the indeterminate constant Δp means that the cost of maintaining a zero-emission vehicle will improve over time compared to the cost of a gas-powered vehicle in the future. However, this price change will also apply to the upfront cost of buying an electric vehicle, meaning that even the initial upfront cost of electric vehicles will become less cost-prohibitive as time goes on. As the consumer’s preferences change over time, reorienting towards a preference for zero-emissions vehicles, we can expect to see fewer carbon emissions from transportation.
According to the US Department of Energy’s Alternative Fuels Data Center, in Minnesota, using a Gasoline-Powered Vehicle produces 11,435 pounds of CO 2 emissions per year, whereas using a fully electric vehicle only produces 3,920 pounds of CO2 equivalents (US Department of Energy, No Date). In terms of pure emissions reductions, the individual choice to drive an electric vehicle instead of a gasoline-powered vehicle cuts car emissions by 65.7%, which would help us get significantly closer to our emissions-cutting goals.
However, in terms of monetary values, we can use the newly updated “social cost of carbon” to quantify the societal savings. The current social cost of carbon is $51 per ton of CO2, meaning each ton of CO2 incurs $51 worth of damage to society (McNamara, 2021). Over the course of a year, a single person changing from a gas-powered vehicle to a zero-emissions vehicle reduces emissions by 3.76 tons, which means in terms of the social cost of carbon, means that individual choice avoids nearly $192 of societal damage every year, per person. This means that the monetary value of avoided environmental damages per year per person (D) can be represented by the function:
D = 192(n) where “n” is the total number of people who own zero-emissions vehicles. This shows that, as increasing numbers of people own ZEVs, which according to earlier models displayed, the numbers of people owning these types of vehicles should increase, the environmental damages avoided increase. Therefore, the benefits are not only felt by the consumers of zero-emission vehicles but shared by the rest of society through added environmental protections and benefits. This provides yet another large benefit to adopting the zero-emissions vehicle rule.
If this rule is implemented sooner rather than later, we could see our state get even closer to reaching the proposed emission reduction goal by 2025, and see hundreds of thousands of dollars worth of potential environmental damages avoided in the long-term. While the benefits may not be immediate, in the long-run, they have immense implications for our ability to reduce the disastrous effects of climate change.
Sources Cited Erwin, Blane (2020). What is a ZEV Credit and How does Tesla make money with them? Current Automotive. https://www.currentautomotive.com/what-is-a-zev-credit- and-how-does-tesla-make-money-with-them/. (Accessed 1-28-21)
McNamara, Audrey (2021). Biden raises social cost of carbon, restoring key climate policy tool slashed by Trump. CBS News. https://www.cbsnews.com/news/carbon- social-cost-raised-by-biden/
Minnesota PCA (2021). State and Regional Initiatives. https://www.pca.state.mn.us/air/state-and-regional-initiatives. (Accessed 2-2-21).
Palmer, Brian (2020). Electric vs Gas: Is It Cheaper to Drive and EV? Natural Resources Defense Council. https://www.nrdc.org/stories/electric-vs-gas- it-cheaper-drive-ev. (Accessed 2-2-21).
Penney, Veronica (2021). Electric Cars Are Better for the Planet - And Often Your Budget, Too. The New York Times. https://www.nytimes.com/interactive/2021/01/15/ climate/electric-car-cost.html. (Accessed 3-1-21).
Union of Concerned Scientists (2019). What is ZEV? https://www.ucsusa.org/resources/what-zev#:~:text=The%20Zero%20Emission%20Veh icle%20. (Accessed 2-8-21)
US Department of Energy (No Date). Emissions from Hybrid and Electric Plug-In Vehicles. Alternative Fuels Data Center. https://afdc.energy.gov/vehicles/electric_ emissions.html. (Accessed 2-8-21).
US Environmental Protection Agency (2021). Federal Tax Credits for New All-Electric and Plug-in Hybrid Vehicles. https://www.fueleconomy.gov/feg/taxevb.shtml. (Accessed 2-9-21) James Kelly Attachment
March 11, 2021
Via E-Filing
The Honorable Judge Jessica Palmer-Denig Office of Administrative Hearings 600 North Robert Street P.O. Box 64620 Saint Paul, MN 55164-0620
Re: In the Matter of Proposed Rules Adopting Vehicle Greenhouse Gas Emissions Standards Clean Cars Minnesota, Minnesota Rules, chapter 7023; Revisor’s ID Number 04626 OAH Docket No. 71-9003-36416
Dear Judge Palmer-Denig:
The Minnesota Department of Health (MDH) supports the adoption of the proposed Clean Cars Minnesota rule because of its potential to reduce air pollution and greenhouse gas emissions to the benefit of public health. The mission of MDH is to protect, maintain, and improve the health of all Minnesotans. Rules such as this support this mission and are an important step in contributing to health in all policies. This letter addresses air pollution, climate change, and health equity considerations in support of the proposed Rule.
Air Pollution and Health
Low-emission vehicle standards and access to zero-emission vehicles can reduce ambient air pollution.
The 2019 Life and Breath Report from the Minnesota Pollution Control Agency and MDH should guide decisions and actions to reduce air pollution across the state and address health inequities that affect quality of life for all Minnesotans. This report estimates the health impacts from air pollution, using the most current outdoor air quality data available (from 2013), matched with available hospital and emergency department admission data, and addresses how broad reductions in air pollution could improve health.
Air quality in Minnesota currently meets federal standards, but even low and moderate levels of air pollution can contribute to serious illnesses and early death.
Overall, MDH estimated that in 2013 across Minnesota:
▪ Between 5 and 10 percent of all residents who died, and 1 to 5 percent of all residents who visited the hospital or emergency room for heart and lung problems, did so partly because of fine particles in the air or ground-level ozone.
An equal opportunity employer. ▪ This is roughly 2,000 to 4,000 deaths, 500 additional hospital stays, and 800 emergency room visits.
In addition, MDH estimated how many health impacts could be avoided from a ten percent decrease in ambient air pollution.
▪ A reduction in 10% in 2013 fine particle pollution levels could prevent up to 500 deaths, 50 hospitalizations, and 60 emergency room visits while fulfilling Clean Air MN goals, resulting in a significant public health impact across Minnesota. ▪ A reduction in 10% in 2013 ozone pollution levels could prevent up to 20 cardiopulmonary deaths, 20 hospitalizations, and 100 emergency room visits.
Climate Change and Health
Low-emission vehicle standards and access to zero-emission vehicles can reduce greenhouse gas (GHG) emissions.
MDH recognizes changes occurring in Minnesota’s climate are affecting our health and wellbeing and will have even greater impacts in the future. The Minnesota Climate & Health Program is focused on improving our ability to protect public health and prevent future harms from climate change. MDH supports and participates in statewide goals related to climate change.
In 2007, the state passed the bi-partisan Next Generation Energy Act that established goals for the state to reduce GHG emissions by 15% below 2005 levels by 2015, 30% by 2025, and 80% by 2050. However, the state did not meet its 2015 goal, and it is not on track to meet its future goals. Transportation is now the largest emitter of GHGs in the state. To achieve Minnesota’s GHG reduction goals, state-level action is needed, and there are many opportunities for immediate action in the transportation sector (Minnesota Department of Transportation 2019 Pathways Report Summary), including this Rule.
Health Equity
Minnesota has some of the worst health disparities in the country, because it has significant inequalities in healthcare as well as in areas such as income, education and home ownership. Minnesota needs to address health disparities as part of multi-faceted public investments in areas such as transportation.
All Minnesotans can be affected by air quality, but vulnerable populations are impacted more than others. At-risk populations include the elderly, children, people living in poverty, and people with little access to quality health care. While the 2019 Life and Breath Report does not provide direct evidence that communities with higher proportions of Black, Indigenous and People of Color (BIPOC) have the highest rates of death and hospitalizations due to air pollution, there is a large body of literature (including the 2015 Life and Breath report for the
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Twin Cities metro area) that show BIPOC communities tend to suffer disproportionate health impacts from air pollution.
GHGs emitted by cars help drive climate change. While climate change impacts everyone, certain populations are more vulnerable to the health impacts of climate change. Learn more in our Minnesota Climate Change Vulnerability Assessment Summary, where MDH identified specific vulnerable populations for several climate hazards, including flooding and flash flooding, tick- and mosquito-borne diseases, extreme heat, drought, and air pollution.
The proposed rule would bring public health benefits to all our communities, and especially our most vulnerable populations. Health starts where we live, learn, work, and play. To create and maintain healthy Minnesota communities, we must think in terms of health and equity in all policies. Thank you again for the opportunity to provide comments on the Clean Cars Minnesota rule.
Sincerely,
Daniel Huff, MPA REHS Assistant Commissioner | Health Protection PO Box 64975 St. Paul, MN 55164-0975 651-201-5000 [email protected] www.health.state.mn.us
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