EPA’s Latest Heavy Duty Vehicle Rule Does Not Meet the Moment

In a sustained effort to clean up one of the nation’s most polluting sectors, the Environmental Protection Agency (EPA) released a new rule aimed at curbing climate emissions from heavy-duty vehicles (HDVs)—a category encompassing delivery trucks, garbage trucks, shuttles, school buses, freight trucks and more. But why the focus on HDVs? Despite HDVs making up just four percent of vehicles on the road, they generate more than 25 percent of the total climate pollution from the transportation sector. According to analysis by Clean Air Task Force, diesel pollution in 2023 was projected to cause up to:

•    8,822 premature deaths
•    3,728 heart attacks
•    173,067 cases of respiratory symptoms
•    2,063 asthma-induced visits to the ER
•    $98 billion public health costs to the economy
•    516,704 lost workdays

Understanding EPA’s Latest Heavy-Duty Vehicle Rules

The EPA’s new measures establish a stronger framework of performance-based, greenhouse gas standards for HDVs spanning model years (MY) 2027 through 2032. This rule is not a ZEV mandate for heavy-duty vehicles. Notably, the new standards do not require the use of specific technologies, so it is likely that compliance will be met with a mix of internal combustion engine improvements and zero-emission vehicles (ZEVs). This technology neutral approach will lead to diesel engine vehicles that produce less carbon emissions, but those vehicles will continue to spew dangerous nitrogen oxides (NOx), volatile organic compounds (VOCs) and particulate matter (PM) pollution that continue to harm people in the communities they operate in. Greater ZEV deployment is the only way to guarantee that emissions will not just be reduced but eliminated outright. Unfortunately, the rule falls short of setting a clear pathway to 100% zero-emissions for heavy-duty trucks and ensuring emissions reduction for frontline and fence line communities.

EPA analysis suggests that the rule will prevent approximately 1 billion metric tons of greenhouse gas emissions from 2027 through 2055, representing an effort to limit climate change impacts such as sea level rise, heat waves, drought, wildfires, and more. The rule is also expected to reduce pollutants that harm our air quality and health, including NOx and VOCs. Specifically, EPA estimates that the new standards will reduce emissions of NOx and VOCs by 53,051 tons and 7,272 tons respectively.

If these reductions are realized under the standards, EPA expects tangible air quality improvements will be achieved, potentially curbing respiratory illnesses like asthma and reducing hospital visits. EPA estimates that combined climate and health benefits could amount to $220 billion and $6.5 billion, respectively, offering a compelling case for action. However, there’s much more to do to eliminate the continued pollution harm.  

What are we fighting for?

While HDVs are the backbone of our economy—projections show nearly $15 trillion of all goods by value are carried on a truck in the U.S—they emit concentrated amounts of harmful pollutants affecting public health and the environment, while also being expensive to run and maintain.

Frontline and fenceline communities living adjacent to ports, highways, warehouses, and railyards are disproportionately burdened by the pollution caused by our freight system. That is why the Moving Forward Network (MFN), a national network of over 50 member organizations led by grassroots members, has consistently supported EPA’s authority to implement stringent and protective standards with a goal of 100% ZE across the freight transportation system. In June 2023, NRDC as part of MFN, submitted comments on EPA’s Phase 3 GHG Emissions Standards for HDVs. Our priorities for EPA’s updated standards included that:

1. EPA should account for the cumulative impacts affecting environmental justice communities. This includes the multiple sources of industrial pollution concentrated in these neighborhoods, the compounding socioeconomic stressors experienced by communities of color and low-income communities, and the devastating effects of climate change. EPA should also prioritize policies that consider the significance of a just transition with high-quality jobs.
2. Compliance should be achieved with truly zero-emissions vehicles. The EPA should provide certainty that truly clean, and zero emissions technologies like battery electric trucks will be used to comply with the standard, rather than incentivizing alternative combustion fuels (such as hydrogen combustion and natural gas).
3. A strong standard is feasible, economical, and provides cost savings. We don’t have to wait for some distant future to secure tangible air quality and public health benefits to communities. Current ZEV technology can be used to comply with these updated GHG standards. Additionally, the Inflation Reduction Act and Bipartisan Infrastructure Law are providing unprecedented public investment to support the development and market for ZEV technology and supporting infrastructure. According to the ICCT, installing public charging plazas along just a 1,000 miles of U.S. roads (across just three truck corridors in California and Texas) would be enough to support full compliance with the EPA proposed rule. Finally, major truck manufacturers have committed to meeting ZEV standards, signaling the trajectory of the market. We asked for EPA to set standards to match that momentum and provide a strong market signal to support those commitments.
4. Freight trucks must be prioritized. Freight truck pollution harms everyone, but especially those who live near highways, ports, freight hubs, and other high-traffic areas. Drayage trucks–generally diesel-fueled, heavy-duty tractors that move containers and bulk freight between ports, rail facilities, and distribution centers– are some of the oldest and most-polluting vehicles in frontline and fence-line communities. As such, these trucks need to be prioritized in HDV regulations to eliminate harmful pollution in already overburdened, largely BIPOC and low-income communities where goods movement is concentrated.

EPA’s Rule Does Not Meet the Moment, and More Work Is Needed to Deliver a Zero Emission Freight System

While EPA’s Phase 3 rule is one step closer to reaching our climate goals, it falls short addressing the full spectrum of challenges posed by HDV emissions. MFN’s recommended approach (where 100% of all new vehicle sales are zero-emissions by 2035) would have achieved a 50% reduction in climate pollution from the on-road fleet by 2040 compared to 2026, yielding greater climate and air quality benefits compared to EPA’s finalized rule. 

Going forward, a comprehensive, all-of-government approach is needed to address the daily toll inflicted on environmental justice communities. Until that message is heard clearly and acted upon, environmental justice communities will continue to bear the public health and environmental consequences of the global freight system. 

However, a vision for a zero-emission freight transportation system is emerging, as evidenced by recent collaborative efforts among government agencies. Earlier this month, the Joint Office of Energy and Transportation, Department of Energy, Department of Transportation, and the EPA released a national freight electrification strategy that sets us on a path to 100% zero- emission trucking by 2040 by phasing in a reliable and affordable charging and refueling network. The strategy is a living document that will be regularly updated with public input to reflect real-world data, new technological innovations, market development, and community interests and engagement. MFN responded to the  announcement of the national zero emissions freight corridor strategy and advocated for its development in a letter to the White House that sought a commitment to a 100% zero emission freight transportation system. Identifying additional, critical steps to realize a zero-emissions freight system needs to be a top priority for our federal government, communities across the country are watching how we will meet this moment.

The Need for A Vision for Zero Emissions Future

Though EPA’s latest heavy-duty vehicle rule may not fully meet the mark, it illustrates an important point. As we strive to realize a future where climate goals align with equity, economic progress, environmental justice, and public health imperatives, an all-of-government approach is essential. No single rule is going to deliver the economic, public health, and climate benefits that we need. We need a vision for what America can and should be. MFN and NRDC are ready to support a zero-emissions freight transportation future.