May 15, 2022
National Center for Health Research’s Comments on the Environmental Protection Agency’s Heavy-Duty Engine and Vehicle Standards
We are writing to express our views on the EPA truck pollution standards.
The National Center for Health Research (NCHR) is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, with particular focus on which prevention strategies and treatments are most effective for which patients and consumers. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest.
NCHR agrees with the Environmental Protection Agency (EPA) that the proposed truck pollution standards, which would reduce emissions of smog- and soot-forming nitrogen oxides, are a crucial step towards EPA’s commitment to climate, clean air and environmental justice. However, in light of the ongoing health and climate crisis, the proposed standards fall short of a zero-emission transportation future, and we urge EPA to further strengthen the proposed standards. This has also long been requested by environmental justice communities across the country, because while truck pollution has been devastating the health of communities across the country, it has a disproportionate impact on communities of color.1
We are particularly concerned that zero-emission trucks are not the number one priority of the proposed standards, even though electric trucks are already available today. Zero-emission trucks been shown to improve health outcomes, and new research demonstrates that by 2027 pollution-free trucks will be cost competitive with diesel over the lifetime of the vehicle.2 The rule should also require the maximum possible reduction of emissions from diesel trucks. Diesel trucks are proven to contribute to smog and pollution, causing thousands of premature deaths nationwide each year.3 Lastly, in addition to phasing out diesel engines, the rule should make clear that natural gas-powered engines are not the solution. Research has shown that trucks running on methane can be as polluting as diesel, and any future investments should ensure cleaner energy sources, rather than incentivize the extraction, transportation or use of fossil fuels.4
Strengthened truck standards are an integral aspect of ensuring the health of our nation, and research has shown that pollution-free truck standards are feasible. Pollution also has long had a disproportionate effect on communities of color, making the issue even more pressing. We thus urge EPA to ensure that the proposed truck pollution standards are further strengthened so that they can have the necessary impact in order to protect public health and to set the United States on a path to a zero-emissions transportation future.
References
1. Moving Forward Network. Demand Zero Emission Freight Now. https://www.movingforwardnetwork.com/zero-emissions/.
2. Environmental Defense Fund. New Study Finds Rapidly Declining Costs for Zero-Emitting Freight Trucks and Buses. https://www.edf.org/media/new-study-finds-rapidly-declining-costs-zero-emitting-freight-trucks-and-buses. February, 2022.
3. Union of Concerned Scientists. Electrifying Trucks and Buses. https://ucsusa.org/resources/electrify-trucks. February, 2022.
4. The International Council on Clean Transportation. A Comparison of Nitrogen Oxide (NOX) Emissions from Heavy-Duty Diesel, Natural Gas, and Electric Vehicles. https://theicct.org/publication/a-comparison-of-nitrogen-oxide-nox-emissions-from-heavy-duty-diesel-natural-gas-and-electric-vehicles/. September 2021.
The National Center for Health Research can be reached at info@center4research.org or at (202) 223-4000.