Dear EPA Administrator Regan,
Thank you for your recently announced proposal to reduce air pollution from medium- and heavy-duty trucks. As a person who cares about the impact of pollution on lung health, I am concerned that the proposed rule doesn't do enough to reduce dangerous air pollution or to protect environmental justice communities that are often disproportionally impacted by pollution from overwhelmingly diesel-fueled medium- and heavy-duty trucks.
The primary concerns I have are as follows:
- The proposed tighter tailpipe emission requirements don’t kick in until 2027. California and several other states are already requiring trucks sold within their borders to meet tighter pollution standards by 2024. EPA should do what states are already requiring by 2027. EPA should adopt the schedule and pollution limits in the California NOx Omnibus Rule.
- EPA’s rule allows for manufactures to make more dirtier diesel trucks if they offset their impact by making electric zero-emissions trucks. EPA should account for electric truck sales that are already being driven by state requirements in multiple states and provide for adjustments if more states adopt such requirements. Credit should only be given if manufacturers go above and beyond what they already must do.
- EPA needs to set a zero-emissions standard in this rule and a set a date by which it is the default requirement. In short, EPA should require increasing sales of electric trucks over time and require that all new trucks sold are zero-emission versions by 2035.
Additionally, because of the points above, I believe that the proposed rule fails Environmental Justice (EJ) communities. It ignores the disproportionate impact that diesel pollution has on community health, especially in communities already inundated with medium- and heavy-duty vehicle traffic and pollution. The proposed rule punts meaningful action on stricter requirements onto uncertain future decisions, which delays or possibly prevents cleaner air for those communities. Forgoing action now to reduce harmful diesel pollution exposure to the greatest extent possible will reinforce and entrench historic inequities.
The EPA should be proposing solutions aimed at phasing out our dependency on deadly diesel. I do not accept partial solutions that leave the air we all breathe and the climate we all depend on further burdened and damaged by pollution for decades to come, and urge the Agency to fix the rule to address the above faults.