Originally published by the Union of Concerned Scientists, The Equation.
By Dave Cooke
It has been more than twenty years since the standards for smog generation and particulate pollution for heavy trucks were strengthened. In the absence of federal action, states have moved forward in reducing pollution from trucks. Unfortunately, just last week, truck manufacturers filed a lawsuit to prevent states from enforcing these protection standards. And while the EPA is moving forward with its own proposal to finally strengthen regulations on truck pollution, the industry has waged a general war against them as well.
This struggle of industry to delay, obstruct and otherwise thwart tighter regulation has devastating consequences. To encourage the EPA to introduce standards that are in line with its powers under the Clean Air Act and protect public health, the Union of Concerned Scientists has provided EPA with technical comments on its truck policy, as a member of the Moving Forward Network (MFN). a national network of organizations that focus on the core community, knowledge, expertise, and engagement with communities across the United States that bear the negative impacts of the global freight transportation system, including heavy trucks.
There are serious concerns we at UCS have about this rule, and nearly 1,000 health professionals, scientists and engineers in our science network have agreed that this is NOTX the rule needs to be strengthened to meet the agency’s explicit commitment to climate, clean air and environmental justice. In the following, I will discuss a little more about what is actually in the proposal and why it is so insufficient to tackle the widespread environmental damage faced by freight-affected communities.
Justice postponed is justice denied
Thinking about the EPA proposal, I think it’s crucial to focus on something that Angelo Logan, director of politics and campaign for the Moving Forward Network, constantly reminds me: “Delayed justice is denied justice.” This is not a modest slogan – it’s a reminder that any delay in action means another day when local communities are flooded with cargo pollution, an injustice stemming from racial bias that has led the core of commercial cargo through colored communities.
I went into some detail about the high-level options proposed by the agency on its previous blog, but the summary is that the EPA seemed to have proposed either eventual (2031) alignment with state standards, or alternatively a move to self-adoption proposed by industry standards.
None of these outcomes are enough to address the problems facing communities today, and as detailed below, the rule does absolutely nothing to encourage the implementation of solutions sought by those communities that completely eliminate exhaust pollution. But after digging deeper, as a rule, it’s even worse than I originally thought.
EPA’s backdoor proposal to give the industry what it wants
It turned out that the EPA had packed a proposal with gifts. I’ve already commented on this kind of nonsense in the passenger car market, where loopholes in EPA law have given 16 percent of the benefits the rules were supposed to bring. This truck proposal is just more than the same: when considering loans, Option 1 gives 12 percent of the first step of regulation (2027-2030), causing even further delayed action in an industry that has not seen a new exhaust pipe NOX regulations in more than 20 years.
The EPA pays tribute to a number of things that are already happening, credits that can then be used to make up for shortcomings in emissions performance to new, stronger standards, thanks to regulations on averaging, banking and heavy truck trading rule. EPA has not even bothered to consider the availability of these credits in setting standards, allowing manufacturers to earn credits for things they will already be doing, which they will then cash in to avoid meeting stronger emission requirements in the future.
Three major lending to the status quo particularly undermines current rules: under the new proposed Transition Credit program, they will be able to earn performance loans better than current, weak standards – something producers are already doing; engines sold according to state standards exceed the strongest standards proposed by the EPA in the period 2024-2030. and will earn loans both under the transition program and under the general banking and trade regulations; and all electric trucks sold starting in 2024, including those required under the Advanced Clean Truck Rules adopted by the six states, will receive credits.
The net impact of these unexpected loans granted to implement the status quo is insane. As shown below, if the EPA finalizes Option 1, manufacturers would not have to do anything better than the Option 2 goals in the first 3 years. And if the EPA finalized option 2, nearly 30 percent of the trucks sold 2027-2029. there could be nothing better than today’s best (but still dirty) diesel trucks! In addition to two decades of inaction, it is difficult to understand the EPA’s thought process here to further delay progress.
Act now – reduce emissions as soon as possible
The communities were clear: a zero-emission freight system is needed to achieve environmental justice. Truck traffic is on the rise, even during the COVID-19 pandemic, and that increase means even greater air pollution in communities that are already disproportionately affected by public health emergencies. The only fair solution to such impacts is to eliminate problems in these communities, and that means eliminating emissions from exhaust pipes as quickly as possible.
Instead of addressing the problem directly, the EPA proposal throws the bucket on the road. Contrary to what we and others have advocated, the EPA has not proposed setting sales targets for electric trucks. Major truck manufacturers such as Volvo / Mack and Navistar / International claim they already plan to have up to 50 percent of truck sales by 2030, but the EPA is not keeping its feet on fire and is demanding such dedicated action.
In fact, the EPA proposal does not require any action on electric trucks. Although the agency proposes to recognize such trucks, recognizing “the performance of these technologies without emissions from the exhaust pipe”, they have not set any goals based on these performances. The result is the erosion described above.
EPA’s decision to ignore the best available emission reduction technology is clearly against the Clean Air Act, which says truck standards must “reflect the highest degree of emission reduction that can be achieved by using technology that the administrator determines will be available for model year to which those standards apply. ”
Extensive testing by EPA and suppliers such as Eaton and Achates shows that diesels can achieve 20 mg NOX/ bhp-hr standard. Truck manufacturers say they are targeting 50 percent of electric truck sales by 2030. If the EPA wants to set it up average NOX standard in line with these simple facts to achieve maximum reduction in diesel emissions while maximizing emissions-free sales, elementary school math is to understand that you need to set a standard below 20 mg / bhp-hr!
In other words, if the EPA wants to bring zero-emission trucks to market, it must be much better than Option 1. And there is no time to lose.
Not waiting for the industry to come into its own
Pollution from the truck industry is too big a problem to just sit and wait for the EPA to decide – colored communities across the country are disproportionately exposed to severe pollution, and this disparity continues across the country as a result of racist housing policies and other factors. If the EPA is serious about dealing with environmental justice, cleaning the cargo sector must become a priority – this has not been the case so far.
While we referred our case to the agency through joint technical comments, we will continue to engage the agency and present them with the best available information, including refuting false industry claims we have already seen entering the file. It is clear that the truck industry aims to continue its practice of non-payment for its enormous social damage – communities across the country cannot continue to suffer such injustice. Thousands of UCS supporters have already risen to have their voices heard in this fight, and we will continue to channel that energy in putting pressure on the agency to do what science shows is clearly feasible to address these long-standing damages.
Related: Truck manufacturers are suing for continued pollution
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