11 Details to Know About the So-Called “Overwhelming” Support for the CT Vehicle Bans

1. From July 26 to August 30, thousands of CT residents weighed in on two new regulations, using the Secretary of State’s or Dept. of Environmental Protection comment portals. The Advanced Clean Cars II (ACC) and Medium and Heavy-duty Emission Standards (MHD) regulations would make it progressively more difficult to purchase new gas vehicles at CT dealerships. Before a complete ban begins in 2035.  On October 4, DEEP commissioner emailed 14 legislators on the Legislative Regulatory Review Committee (LRRC), endorsing both proposals, for reasons outlined below.                                           
2. The LRRC will vote on both proposals on November 28. If the vote fails, the regulation will go before the full General Assembly in February. 
3. Of the 3897 unique individuals commenting in the ACC portal, 75.0% (2923) were opposed, while 25.0% (975) voiced support. 
4. Of the 2752 unique individuals commenting on the MHD portal for trucks, 70.9% (1952) were opposed, while 29.1% (800) voiced support. 
5. DEEP felt comfortable making strong statements about the comments without documentation (no summary list regarding how many commenters supported each regulation in its Hearing Officer Report, much less an easily sortable list regarding who exactly voiced support or opposition). Commenters were placed into 5 categories for the table provided below: “Opposes,” “Supports,” “No Stance,” “Stance Unclear,” and “Duplicate Comments.” To help provide the clarity that DEEP’s report is lacking, a more thorough review of every published comment, with all individual commenters identified, has been produced by Yankee Institute, but due to legal concerns over DEEP’s privacy policy that spreadsheet is unavailable here. 
6. Yankee Institute recommends that individuals wishing to independently verify these lopsided results view the PDF’s “Comments received 8.17.23 to 8.20.23,” “Comments received 8.23.23,” and “Public comments received through eregulations.ct.gov” each of which had had at least five times as many “Opposed” comments as “Support” comments.  
7. In DEEP Commissioner Dykes’ letter to the Legislative Regulation Review Committee (made up of 14 legislators who could decide the fate of the ACC and MHD), she says, “…more than 4,000 comments were submitted to the Department….” While DEEP did receive more than 4,000 comments, more than 900 had identical email usernames and/or domain names ([email protected], [email protected]). Therefore, it is a good bet that fewer than 4,000 people actually commented. About 1 in 5 comments in both portals came from the same commenter. DEEP has not made it clear how they dealt with duplicates. Because duplicates occurred at similar rates between support and oppose, this would not impact the results by more than a few percentage points. 
8. Dykes letter continues, “…despite some misinformation about the intent and effect of these proposed standards, comments submitted by the regulated community overwhelmingly favored adoption.” Given the three points above, it would be difficult to see how this statement could be made in good faith if a cursory analysis of the comments was done. 
9. 62 comments in the ACC portal did not indicate a stance in support or opposed. If an individual voiced conditional support (e.g. “if the Legislature funds more electric EV chargers, I will support the ACC”), we included them in this category. 
10. Most of the comment batches posted in the ACC and MHD portals were identical. The ACC portal had two hyperlinks “Comments received 8.24.23 to 8.29.23,” and “Proposed Regulation Concerning: Advanced Clean Cars II” which were not present in the MHD portal.  The MHD portal hyperlinked to one page absent from the ACC page, “Proposed Regulation Concerning: Adoptionof 22a-174-37 Medium and Heavy-duty Emission Standards.” 12 other hyperlinks, linking to hundreds of pages of PDF’s with thousands of comments, were present in both ACC and MHD portals. Commenters who submitted comments to both portals were counted under each regulation for Yankee Institute’s “Vehicle Ban Comments Table.” 
11. In the first 3 weeks of the comment period, from July 26 to August 13, commenters in support of the ACC to those against numbered 320 to 155, a more than 2-to-1 ratio of support to opposed. In the final 2 weeks, from August 14 to August 30, comments opposed outnumbered those in support 2,768 to 654, a more than 3-to-1 ratio. 

If you didn’t get the chance to comment, you can email your legislators here.