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August 16, 2018

Dear Air Quality Control Commission,

As members and allies of E2 (Environmental Entrepreneurs) in Colorado, we strongly urge the Commission to ensure the Notice of Rulemaking will allow alternative proposals to the Low Emission Vehicle (LEV) standard, including adoption of the Zero Emission Vehicle (ZEV) portion of the Advanced Clean Cars program, which are within the scope of this proceeding underway at the Air Quality Control Commission. Furthermore, a broadly worded notice serves the public interest, will allow for a full and robust discussion, and will ultimately result in better policy decisions.
E2 is a national, nonpartisan group of business leaders, investors, and professionals from every sector of the economy who advocate for smart policies that are good for the economy and good for the environment. Nationally, E2 members have founded or funded more than 2,500 companies, created more than 600,000 jobs, and manage more than $100 billion in venture and private equity capital. The Rocky Mountains chapter is in its eleventh year.
Governor Hickenlooper’s 2017 Executive Order committed the Centennial State to reduce heat-trapping greenhouse gas emissions 26 percent by 2030 from 2005 levels.  And under the Electric Vehicle (EV) plan the governor unveiled in January, he set a goal of putting almost one million EVs on the road by 2025. 
In light of the rollback of the Federal Clean Cars standards, it is urgent Colorado charts its own path. LEV adoption will prevent the state from backsliding and ZEV adoption will move Colorado forward by ensuring availability of the increasing numbers of electric cars, SUVs and trucks that manufacturers are making and releasing in the coming years.  Electric cars are key to significant carbon emissions and other air pollution reductions and will ensure Colorado is at the forefront of the economic benefits of new technology investment and adoption.

If Colorado adopts the ZEV standards, consumers will always be able to buy the size and power of vehicle that best fits their needs. These standards would encourage the sale of more efficient cars and trucks so that whatever vehicle you own, it will cost less to fill-up at the pump. 
According to the recent Clean Jobs Colorado 2018 report, Colorado is home to more than 2,700 jobs in the advanced vehicle industry, including technological innovation in lightweight materials, engine design, aerodynamics, EVs and EV charging infrastructure.  Long-term standards and policy are essential to ongoing innovation and job growth, and to a further strengthen the manufacturing sector in Colorado and beyond. As a result, private investment in next-generation EV technology – both R&D and development and production – is flowing at higher rates to ZEV states, and at much lower levels to non-ZEV states. By adopting both LEV and ZEV, Coloradans can expect the jobs in this industry to continue to grow.
A recent study by Synapse Energy Economics for the years 2020 through 2035, shows pursuing the ZEV standard would result in a positive, long term economic benefit for the state — to the tune of an increase of about $72 million in consumer spending and 1,700 jobs, annually. The economic benefits would grow over time, from the cumulative effects of less fuel consumption, lower maintenance costs, and as the cost to purchase EVs continue to come down. The ever-increasing economic benefits would extend to nearly every facet of the Colorado economy. The good news is environmental and health benefits of reduced emissions through LEV and ZEV can be achieved alongside employment and GDP growth in Colorado.
Automakers have shown they can meet and exceed the ZEV standard, which requires them to get just over 9 percent of their sales from zero-emission vehicles and gives them to until 2025 to do so. EV sales are already increasing in Colorado and the state can take steps to assure compliance. In some states, BMW and GM have already achieved above 10% sales level eight years ahead of schedule.
Adopting Advanced Clean Cars standards is a smart, business-first policy that will drive innovation and jobs, save consumers money, promote consumer choice and help improve the quality of our precious Colorado air. As business leaders who are creating jobs and driving economic growth in Colorado, we urge you to allow the rulemaking to be broad enough to consider both LEV and ZEV standards for Colorado.


E2 Members and Allies

Emily Applegate
Senior Manager, Business Funding & Incentives, Business Investments, OEDIT
Jeff Bennett
Founder, Big Kid Science
Chris Bentley
Business Development, Independent Power Systems
Jan Borstein
Volunteer, Retired
Katrina Brink
Owner/Founder, The Empowered Kitchen
Vince Calvano
Attorney & Business Owner, Vincent P. Calvano, LLC.
DJ Cardi
VP of Client Relations, Solar Power Financial
Rachel Carillo
David Carollo
Sales Rep., EcoSystems
John Cleland
Managing Partner, RenewWest
Phil Combs
M&V Engineer, Trane
Bryan Conklin
CEO, Resurgent Energy
Rich Crawford
CEO, Midwest Wind Resources
Andrew Currie
Investor, Active Minds LLC
Rick Defino
Sales Rep, EcoSystems
Kris Deutschman
Founder/CEO, Deutschman Communications Group, Inc
Pete Dignan
Founder, Ever Better, PBC
Dannie Diionno
Business Development Specialist, ME Group
Rachel Emmer
Principal and Senior Consultant, DetritusGroup
Alanna Fishman
Former Director, Policy and Social Responsibili, HBW Resources
Maxwell Fleming
Programs & Efficiency Manager, EcoSystems
Suzanne Foster Porter
Principal, Kannah Consulting
Angie Fyfe
Executive Director, ICLEI Local Gov'ts for Sustainability
John Gavan
Board Member, Delta County Economic Development
Billy Giblin
Project Engineer, Nexant
Kate Gridley
Founder, Atolla Energy
Lauren Hafford
Mechanical Eng
Matthew Hamilton
Sustainability Director, Aspen Skiing Company
Meriwether Hardie
Chief of Staff, BioLogical Capital
Grady Harper
Energy Rater, EnergyWise Consultants
RJ Harrington
President, Sustainable Action Consulting, PBC
Scott Hatfield
Business Development Manager, Scott Hatfield
Greg Hopkins
Associate, Rocky Mountain Institute
Richard Hubler
Planning Intern, City of Pueblo
Jerome Kalur
Attorney at Law
Scott Koehler
VP Global Strategy, Schneider Electric
Sue Kunz
CEO, ThriveOn Group
Rose Lew
Environmental Scientist, Retired from US EPA
Theron Makley
Marketing Director, Panasonic
Ryan Martens
Founder, Rally Software Development
Don Martinez
Senior Corespondent, Lima Charlie News
Alex Marvin
RJ Mastic
Founder and CEO, Ecosystems
Kevin Morse
Vice President, Lever Energy Finance
Jeni Nagle
Ela Family Farms
Whitney Painter
Partner, Buglet Solar Electric Installation
John Powers
President, Alliance for Sustainable Colorado
Rochelle Rabeler
Attorney, Holland & Hart LLO
Megan Rast
Corporate Sustainability Professional
Dave Reed
Co-leader, Citizens' Climate Lobby - GJ chapter
Christopher Riti
Principal, Promontory Financial Group
Jamila Rockette
Michael Rucker
CEO, Scout Clean Energy
Frank Sandoval
Principal, Pajarito Technologies
Ankit Sanghvi
Project Manager, PCL Construction
Auden Schendler
Director of Environmental Affairs, Aspen Skiing Company
Brad Seaman
Director of Project Finance, Scout Clean Energy
Brenna Simmons-St. Onge
Executive Director, The Alliance Center
Ian Skor
Co-Founder, Sandbox Solar
David Smith
Director Facility Services, Kaiser Permanente
Michael Smith
Founder, RenewWest
Eric Stoutenburg
Chief Development Officer, Able Grid Energy
Karen Sweeney
Energy Analyst, The Energy Group
Stu Swineford
Founder, Relish Studio
Kristen Tetrick
Dir of Sustainability, Lucky's Market
Andrew Thomaides
Tanya Travis
OTR, Welbrook
Pierre Trolin
Partner, BELT Natural Resources Development
Brad Udall
Sr. Water and Climate Scientist, Colorado State University
Aaron van Boer
Head of Solar Bus Development, Current by GE
Marie Venner
President, Venner Consulting
Thomas Vessels
President, Vessels Carbon Solutions Inc.
Lou Villaire
Co-owner, Atlasta Solar Center
Robert Welch
President, Energy Crafters
Susan Williams
Logistics Manager , GE Johnson Construction
Daniel Winer

76 members


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