I am writing to express Yankee Institute’s opposition for Advanced Clean Cars II proposed by the Department of Energy and Environmental Protection (DEEP). Electric vehicles (EVs) are not a practical choice for Connecticut workers who are not able to make large salaries from the comfort of home, and will limit employment opportunities for many deserving Connecticut residents.
California regulators adopted these regulations specifically for California, over 2000 miles away, and they did not have Connecticut residents in mind. There are many reasons to not simply adopt the same regulations here in Connecticut.
One glaring concern is the cost of electricity. According to the most recent data available from the Energy Information Administration the average Connecticut resident spent 31.32 cents/kilowatt hour of electricity. The 14 other states that that have adopted California’s standards all have a consistently lower price of residential electricity than Connecticut, led by Washington state which pays less than half of Connecticut’s rate. Residents of those states can count on the cost of charging an electric vehicle to be less than the cost of filling up at the gas pump. In Connecticut, residents have every reason to suspect that charging will be just as expensive, if not more so, for the foreseeable future.
Even if Connecticut residents are not able to purchase new combustion vehicles in 2035, gasoline vehicles will still dominate the road for many years to come. According to automotive journalist David Booth, combustion cars now last about 12 years, with drivers replacing only 17 million of 275 million vehicles in the US each year. In the unlikely event that battery power accounts for half the cars sold in the U.S. by 2030, EVs will still only represent between 50 and 60 per cent of all the cars on North American roads by 2050.
Connecticut currently offers some of the most generous incentives to purchase EVs in the United States. And yet, only 0.73% of cars on Connecticut’s roads are electric, and most people who own an EV also own a gas-powered vehicle. To all appearances, demand for electric vehicles, is quite unresponsive to even large subsidies. Many residents see little point in the doubtful proposition of “saving money” by buying an EV, if one is forced to plan their day around charging their means of transportation.
It also remains an open question if Connecticut will be able to maintain this level of financial support for EVs, as the federal money which buoyed state budgets in recent years dries up. Connecticut’s long term fiscal outlook remains precarious, ranking 49th of 50 states in Truth in Accounting’s 2022 Fiscal Health rankings, largely due to enormous unfunded retirement obligations.
Additionally, legislators and residents will likely prioritize making Connecticut’s infrastructure more climate resilient leading up to 2035. The cost/benefit of such action far exceeds whatever minuscule benefit can be
attained from reducing Connecticut’s 0.11% share of global emissions, especially in terms of avoided disaster relief expenses.
For these reasons, Connecticut may soon be tempted to remit such generous subsidies, forcing legislators, and by extension taxpayers, to make the tough decisions about which parts of public spending will need to be pared back to pay for obligations that Connecticut is legally on the hook for.
As such, Connecticut residents, especially those with limited and/or fixed incomes, could be left with the difficult choice of purchasing a new, pricey electric vehicle at the unsubsidized full price, a used combustion vehicle (of which there will be a dwindling supply and higher price with each passing year) or a used electric vehicle. Even with the continued massive state and federal production subsidies of EVs, Oliver Wyman’s analysis for the Financial Times predicts that EVs will be 9% more expensive than combustion vehicles by 2030.
Connecticut cannot count on used EVs to keep the price of new EVs in check. All signs point to used EVs losing value at a faster clip than combustion vehicles. Used EVs driven in cold climates like Connecticut retain less value than used EVs in warm climates like California. According to Michigan Technological University’s Advanced Power Systems Research Center, the life expectancy of an EV battery decreases by 20% when driven at 32 degrees and deteriorates even faster the colder it gets.
Used electric vehicles are also less likely to hold value due to the uncertainty surrounding accident history. According to Carfax Vehicle History reports, 40% of vehicles on the road today have sustained damage of some sort, though this total is certainly higher because many fender benders go unreported. Whereas minor damage is rarely enough to make a combustion vehicle undriveable, EVs are more vulnerable to fender benders that can cost as much to repair as the vehicle is worth, a cost that car insurance companies will often not fully cover.
It is the duty of Connecticut’s government to inform the public of the very real risks of electric vehicles. Forcing car owners to choose between more expensive options will only push the cost of car ownership for lower-income Connecticut residents skyward, which is already the highest in the US, according to Automoblog.
The ramifications of Advanced Clean Cars II extend beyond the Connecticut consumer. While particulate matter emissions from exhaust will decrease if EVs replace combustion vehicles, non-exhaust particulate matter emissions will increase due to the heavier nature of EVs. There is no scientific consensus on which of these factors will alter health outcomes to a greater extent.
If vehicle prices increase due to the passage of this rule, a large swath of Connecticut could become more vulnerable to mental health crises. Access to automobiles has a strong positive relationship to employment outcomes. If fewer Connecticut residents have access to vehicles due to increased prices of vehicles overall, unemployment (and underemployment) will follow. According to the National Library of Medicine, we can expect a 1% increase in unemployment to cause a 2-3% increase in the rate of suicides.
I urge DEEP to reconsider passing such onerous clean vehicle standards. Until electric vehicles are shown to be a viable alternative to combustion vehicles, consumers should have the option to choose what makes the most sense for them. Please do not adopt the Advanced Clean Cars II.
(See comments with hyperlinked sources in attached PDF)
David Flemming
Director of Policy and Research
