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HAAN MINNesoTA ‘April 12, 2018 ‘The Honorable E, Scott Pr U.S. Environmental Protection Agency 1200 Pennsylvania Avenue NW Mail Code 11018 Washington, D.C, 20460 Re: Minnesota Opposition to Vehicle Emissions and Fuel Economy Rollbacks Dear Administrator Pruitt: ‘We write to document our strong, sincere opposition to your initiative to roll back environmental rules aimed at cutting pollution and greenhouse emissions from vehicle tailpipe emissions. As you know, these existing rules resulted from extensive negotiations between federal officials, automakers, and states, including California, as well highly rigorous technical evaluation and significant public review and comment. We believe this effort to weaken clean vehicle standards with no documentation, evidence or law to back up that decision, will worsen people's health with degraded air quality and undermine regulatory certainty for automakers For more than 50 years, policy makers in Washington have pushed American automakers to build better, safer, cleaner cars. We believe this latest set of environmental goals, put in place by the Obama ‘Administration, are the logical outcome and continuation of this decades-old practice, and are very achievable by the industry. The practice of raising the bar on CAFE standards for automakers has always transcended party politics and industry interests, and it has happened across decades resulting in public health and environmental benefits across the United States. The US. automobile industry has long been a global leader in advancing new technologies that make vehicles cleaner and more efficient. These advancements have improved air quality across the country and saved consumers significant money at the gas pump. Maintaining the Model Year 2022-2025 light duty GHG emission standards will boost our economy, reduce harmful air pollutants, and ensure the United States continues to lead the globally competitive automobile industry. A joint 2015 Minnesota Department of Health/Minnesota Pollution Control Agency report, (Life and Breath: How Air pollution Affects Public Health in the Twin Cities)? identified tailpipe pollution from on- road vehicles as a leading source of oxides of nitrogen, fine particulate matter and other air toxics that have been shown to contribute to more than 2000 premature deaths each year. In fact, on-road vehicle tailpipe emissions exceed power plant and factory emissions in overall air pollution in Minnesota, (The Air We Breathe: The state of Minnesota's Air Quality 2017)? Rolling back the emission standards will add to this existing respiratory disease risk and impair the health of vulnerable populations of Minnesotans. Less than ten years ago, American taxpayers spent $80 billion to save the troubled US. automakers. We believe that sort of public investment entitles the federal government to ask for similar investments from " https://wwwpca state.mn.us/sites/default/fles/aq1-61 pdt 2 ites/default/files/Iraq-1sy17,pdf Administrator Pruitt April 12, 2018 Page Two automakers to continue to drive innovation to protect clean air and maintain the leading edge of global technology. These regulations allow us to do both. If as you have said, states are the best laboratory of environmental and public health innovation, this, suggested rollback ignores advances made possible by states like California, If carried out, we understand that the EPA will ikely challenge the state of California in court, arguing that states “should not be able to dictate standards for the rest of the nation.” On the contrary, California and the 12 similarly regulated states, who make up a third of the automobile market, are looking to push innovation to help mitigate severe damages to public health and property from air pollution and climate impacts, It makes no sense to block a negotiated path forward that avoids putting more gas-guzzling vehicles on the road, increasing total gasoline consumption, and significantly increasing carbon dioxide emissions. Rolling back these rules will certainly result in all three of those outcomes. If the American auto industry suggests modifications to these MY 2022-2025 GHG standards, and to 2012 CCAFE standards in the future, their voices can and should be heard. Stil, such requests do not warrant completely discarding environmental protection goals that have been on the books for nearly a decade, especially standards that were the result of highly rigorous technical evaluation and significant public review and comment. State environmental, public health and economic leaders voices should also be heard in a transparent and deliberative consultation. We can see no justification, nor any documented need, to set these protections back at this time, We Urge you to reconsider, and retract this initiative, Sincerely, math Johan Line Stine, Commissioner Charles A. Zelle, Commissioner Minnesota Pollution Control Agency Minnesota Department of Transport 520 Lafayette Road 395 John Ireland Boulevard St Paul, Minnesota 55155, St.Paul, Minnesota 55155