December 23, 2020 The Honorable Chap Petersen, Chairman Senate Agriculture, Conservation and Natural Resources Committee [email protected] The Honorable Ken Plum, Chairman House Agriculture, Chesapeake, and Natural Resources Committee [email protected] RE: Support for Clean Car Standards and Transportation Electrification Dear Senator Petersen and Delegate Plum, We are writing to respond to a recent letter distributed to General Assembly members by the Virginia Automobile Dealers Association (VADA). While we are pleased that VADA indicates support for electric vehicle (EV) adoption, their summary recommendation is misinformed. More importantly, VADA’s position overlooks the urgent importance of passing pro-EV policies that tackle carbon emissions from the transportation sector this coming year. We recognize that electric vehicle technology represents change to some of VADA’s constituency, but it is change for the better of all Virginians. Transitioning to electric transportation is essential for Virginia’s economy and climate. Surveys show that the overwhelming majority of Virginians want to reduce the Commonwealth’s dependence on imported fossil fuels and support vehicle electrification. Smart and thoughtful state level policy can support auto dealers in this transition, but a lack thereof can be an impediment to realizing the economic, health, and climate benefits that transportation electrification represents. As VADA outlined in their letter, the Low-Emission Vehicle (LEV) Program includes criteria and greenhouse gas emissions standards and the Zero Emission Vehicle (ZEV) Program stipulates that manufacturers provide additional access to EV inventory to dealerships. Together, these programs make up the Advanced Clean Car Standards, a pro-EV policy that can empower new-car dealerships to embrace electric vehicle technology and increase access to EVs for all Virginians. Point No. 1: Timing of Clean Car Standards adoption VADA’s letter presents a flawed argument to delay this legislation. Delaying adoption hurts Virginia’s public health, economy, environment, and consumer choice, and puts us behind states who are innovating and moving quickly toward a profitable clean energy economy. • There is already a built-in delay to the Clean Car Standards legislation, which is why we must act now. The Clean Car Standards are structured to support new-car dealerships with a built-in delay period and wouldn’t go into effect until Model Year 2025. This provides ample time for any necessary dealership upgrades to take place and also provides auto manufacturers with enough time to ramp up manufacturing as needed. We already failed to act on this legislation during the 2020 session and cannot afford to delay further. • VADA claims that adopting the Clean Car Standards means adopting California’s 2035 ban on new-car internal combustion vehicle sales, but this is not accurate. Governor Newsom’s Executive Order is not the same as the LEV/ZEV program. Additionally, Virginia is a sovereign state and is free to ignore any future standard that does not meet Virginians’ needs by returning to the federal standard. But the Clean Cars Standard is the right choice for Virginians, as it represents the Commonwealth's single biggest opportunity yet to tackle climate change and support a clean energy economy. • In addition, it is not just California but 14 other states (Colorado, Connecticut, Maine, Maryland, Massachusetts, New Jersey, New York, Oregon, Rhode Island, Vermont, Nevada, Minnesota, New Mexico, and Washington) who have moved to adopt the ZEV standards and are leading the way toward a clean energy economy. Point No. 2: Investment and Incentives Required Virginia already has EV demand that is being outpaced by our supply, as evidenced by the numerous EV owners who travel to Maryland to purchase their vehicles. New research shows that over 50% of Virginians are considering an EV for their next car; the Clean Car Standards would help to keep these sales in the Commonwealth by guaranteeing meaningful and consistent EV inventory access for our dealerships. • Virginia’s consumers lose out without this legislation because the most popular EV models— such as SUVs and the new truck models coming out—will not be sent to Virginia, but to ZEV states, further curtailing consumer choice and sending Virginians to neighboring states or back to gas-powered vehicles. • Passing the Clean Car Standards now still gives the General Assembly ample time to consider and fund a state level financial incentive. Even though EVs are already expected to reach price parity with gas vehicles around the same time as the ZEV program would take effect, we agree with VADA that incentives will help spur faster EV adoption. We support an equitably designed point- of-sale state level EV rebate, as will be considered during the 2021 General Assembly session. • Virginians spend $25 million every single day on imported petroleum to support our transportation needs. Transitioning to EVs would keep this money in our local economy and create new jobs. In addition to the economic benefits, electrifying our transportation system will have a profound positive impact on air quality, protecting our climate and supporting Virginians’ public health as we begin to recover from the Covid-19 pandemic. • The built-in delay in the Clean Cars Standards also gives Virginia time to finish building out its robust charging network, which is already underway. While the majority of EV charging takes place at home, Virginia is already investing $14 million and has commissioned charging company EVgo to ensure that 95% of Virginians live within range of an EV charger. EVgo is the nation's largest public fast charging network for electric vehicles, and the first to be powered by 100% renewable energy. • We don’t need to wait for additional studies about financial incentives and charging infrastructure because Virginia has already done the research. It has informed our data-driven policies. The consequence of implementing duplicative studies and waiting another year to pass the Clean Car Standards would mean another year of 10,000 unnecessary lost workdays, 2,600 avoidable cases of exacerbated asthma, and 92 preventable deaths attributable to Virginia- specific transportation emissions. Virginia proved itself to be a clean energy and climate leader when it passed the Virginia Clean Economy Act and joined the Regional Greenhouse Gas Initiative. We didn’t wait for federal action to lead the way then and we shouldn’t wait now. Furthermore, passing the Clean Car Standards now positions Virginia well should support for transportation electrification come from the Biden administration. Efforts to delay this legislation are not in Virginia’s best interest. Now is the time to cement Virginia’s role as a leader in our country’s clean energy transition. We ask that you continue on this bold path and support the Clean Car Standards. Sincerely, Wendy Philleo Executive Director Generation180 cc: The Honorable Dick Saslaw The Honorable Louise Lucas The Honorable Tommy Norment The Honorable Steve Newman The Honorable Eileen Filler-Corn The Honorable Charniele Herring The Honorable Todd Gilbert Members, Senate Agriculture, Conservation and Natural Resources Committee Members, House Agriculture, Conservation and Natural Resources Committee .