Auto Innovators submitted rebuttal comments on Minnesota’s proposed Clean Cars Rules to adopt California LEV and ZEV rules. These comments focus on why a one-time allotment of credits in the bank is appropriate, and why our recommended approach of capped proportional credits is preferred to the agency’s proposed single year worth of credits (Auto Innovators also continues to agree with the addition of early action credits). In addition, the comments provide clarification in response to other comments on statutory and legal requirements under the Clean Air Act and Minnesota’s Administrative Procedure Acts. The public comment period in Minnesota is now officially closed, and all parties will await a report from the Administrative Law Judge.
March 23, 2021 Agency Comments