June 16, 2023
The National Center for Health Research (NCHR) appreciates the opportunity to provide public comments on the Environmental Protection Agency’s (EPA) proposal to establish new greenhouse gas (GHG) standards for heavy-duty highway vehicles and to revise certain GHG standards that were established previously under EPA’s Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles.
We are a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, with a particular focus on which environmental exposures are most dangerous for consumers’ health. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest.
The EPA’s proposal for new standards for heavy-duty highway vehicles is on the right track toward addressing the climate issue of GHG emissions. However, the proposed standards only set the goal that 50% of new sales for heavy-duty vehicles should be zero-emission vehicles. We strongly urge the EPA to strengthen the proposed standards, by instead requiring 100% zero emission sales by 2035 in the final rule.
Transportation sources are responsible for much of the total air emissions in the U.S. Among all vehicles, medium and heavy-duty vehicles contribute about 23% of GHG emissions and emit over 60% of tailpipe nitrogen oxides and particulate matter pollution, despite only making up 10% of all vehicles on the road.[1],[2] Air pollution from transportation disproportionately affects communities of color and those with lower household incomes.[3] For example, in the U.S., low-income people of color are exposed to 28% more nitrogen dioxide compared to their wealthier white counterparts, which increases their risk for cardiovascular and respiratory diseases.[4]
We also recommend that EPA amend their rule to limit alternative technologies such as hydrogen combustion engines that would do nothing to alleviate the tailpipe pollution harming local communities. Zero-emission vehicles have no tailpipe GHG or pollutant emissions and are essential for decarbonizing the transportation sector. Heavy-duty vehicles are good candidates for electrification, as they often travel to predictable destinations with consistent mileage, stop frequently, and have a primary operating range of less than 100 miles. Additionally, the total cost of ownership is lower for battery electric vehicles, including expenses for fuel and maintenance, making it a more cost-efficient option.[5]
Strengthened standards for heavy-duty highway vehicles are critical in reducing transport emissions, mitigating climate change, and improving air quality. It is an integral strategy to ensure the health of all Americans, especially for the communities of color and low-income households that are disproportionately affected by tailpipe pollution. For those reasons, we strongly urge the EPA to pass the strongest possible pollution standard for medium and heavy-duty highway vehicles in order to protect public health and set the United States on a path to a zero-emissions future.
[1] Delgado, C. (2023). EPA updates emissions standards for heavy-duty vehicles for the first time in 20 years. Popular Science. https://www.popsci.com/environment/heavy-duty-vehicles-epa-emissions/#:~:text=Heavy%2Dduty%20vehicles%20contribute%20about%2023%20percent%20of%20GHG%20emissions,the%20updated%20clean%20air%20standards.
[2] Putting the pieces together to curb transportation pollution. Southern Environmental Law Center. (2022). https://www.southernenvironment.org/news/putting-the-pieces-together-to-curb-transportation-pollution/
[3] Vasquez, K. (2021). Diesel trucks are driving environmental injustice in parts of the US. Greenbiz. https://www.greenbiz.com/article/diesel-trucks-are-driving-environmental-injustice-parts-us
[4] Moving Forward Network. Demand Zero Emission Freight Now. https://www.movingforwardnetwork.com/zero-emissions/.
[5] O’dea, J. (2019). (rep.). Now is the Time for Heavy-Duty Electric Vehicles. Union of Concerned Scientists.