Background:
In 2024, Governor Lujan Grisham signed a bill to establish a clean transportation fuels program to help protect New Mexico from climate change. The legislation requires a 20% reduction in New Mexico fuel carbon intensity by 2030 and a 30% reduction by 2040 compared to 2018. The rule holds the potential to generate hundreds of millions of dollars to support faster progress in cleaning up vehicle pollution and it is an important part of New Mexico’s climate strategy.
Talking points:
Introduce yourself and what you care about
Say thank you
- Thank the Environmental Improvement Board for carefully considering this proposed rule
- Thank the Environment Department for their hard work to develop and propose the rule; and
- Thank Governor Lujan Grisham for her leadership in initiating this process and working to protect New Mexico from Climate Change
Emphasize Overall Position / Your Leadership Matters
- Reducing pollution from transportation is critical for securing New Mexico’s future. I urge the Board to adopt the strongest possible rule.
- New Mexico has a real opportunity to lead here. As the second largest producer of oil and gas in the country, strong clean fuels standards may encourage other states to follow what we do.
- This Board’s action is particularly important given the federal government’s attempts to roll back regulation of greenhouse gas emissions. The Board has an opportunity to pass a program that truly cuts emissions, supports jobs here at home, and promotes healthier air for New Mexicans. The Board must meet this mandate by adopting a strong, effective rule that keeps the benefits in New Mexico.
Topics to Raise – Pick and Choose
1. Let’s Keep Benefits in New Mexico
The Board should eliminate “book-and-claim” accounting so that the rule supports clean transportation in New Mexico.
The best version of this rule should help clean up the air, reduce greenhouse gas emissions, and boost the economy here in our state. However, NMED’s proposal has a serious loophole called “book-and-claim” accounting. The “book-and-claim” provisions would let industry take credit for fuels used in other states. For instance, a fuel supplier could take credit for renewable diesel fuel that’s produced in Iowa and used in Arizona. A supplier would not need to bother selling any clean fuels in New Mexico, but could still earn credits here. This approach would help pay for clean fuel projects in other states, yet it would do little or nothing to benefit our communities.
2. Make sure the rule recognizes efficiency. Energy-efficient vehicles cost less to fuel. By promoting efficiency, this rule can help New Mexicans save money while we also cut pollution. The proposed rule appropriately recognizes that some technologies are more efficient than others through the inclusion of Energy Economy Ratios (EERs), or EERs. The Board should absolutely ensure that EERs remain part of the final rule.
3. Recognize the full benefits of electric vehicles (EVs). The fossil fuel industry is asking you to weaken the standard by adopting a rule that does not credit electric vehicles, or EVs, for their full climate benefits. This flies in the face of science and common sense. EVs cut emissions, first, because they’re far more efficient than gas or diesel-powered internal combustion vehicles. Second, EVs run on electricity, a cleaner source of power, especially if it is generated by wind or solar. Please reject these attempts to undermine New Mexico’s transition to clean energy and clean vehicles. [THIS IS A DIFFERENT WAY TO SAY THE SAME POINT ABOVE IN #2] 4. Recognize the benefits of public transit. Allow public transit agencies to earn credits for the work they do to reduce emissions by moving people efficiently. That will help give a wider group of New Mexicans an opportunity to directly benefit from the rule.
5. Focus on fuels with real benefits. The Board must not allow industry to take credit for supplying fuels it characterizes as “clean,” but that have far-reaching adverse environmental and economic consequences. In particular, use of crop-based fuels often leads to deforestation and increased fuel prices. The Board should limit – or reject – any credits that have severe adverse consequences, or that fail to ensure real reductions in emissions.
6. Don’t pay for more pollution. The current proposal includes special treatment for methane produced by factory farms. The methane from these farms will receive more credits than methane from other sources like landfills and wastewater treatment plants. The Board should reject this special treatment for a polluting industry.
7. Streamline enforcement. The rule would create a lengthy and complex process for enforcement. This is unnecessary, and it would hamper enforcement and delay compliance. The Board should simplify the enforcement measures.