MFN Stands Firm: EPA Must Eliminate Toxic Air Pollution from Trucks

If the Biden administration is going to deliver on its pledge to address climate change and environmental justice, EPA must finalize strong emissions standards.

A cloud of smoke being emitted from the exhaust pipe of a diesel-fueled truck.



This is a joint blog with Dyna Anderson, Program Manager at the New Jersey Environmental Justice Alliance and Molly Greenberg, Campaign Manager for the Moving Forward Network.

As a network, the Moving Forward Network (MFN) has publicly and consistently supported EPA’s authority and responsibility to pass the most stringent and protective standards that eliminate the daily toxic threats impacting our communities. 

In June, NRDC, MFN, and the dozens of frontline environmental justice groups and NGO organizations who are part of MFN submitted comments to the EPA’s for the Phase 3 Greenhouse Gas (GHG) Emissions Standards for Heavy-Duty Vehicles—their latest action to address air pollution from heavy-duty vehicles and locomotives. 

As it stands, the current options in EPA’s Phase 3 proposed rule fall short of the strong action that is necessary to curb greenhouse gas emissions from the freight transportation sector. Moreover, they fail to alleviate the daily burdens that heavy duty trucks have on people’s lungs. Accordingly, our comments called on the EPA to strengthen the proposed standards and reiterated that protective standards must ensure that emissions are reduced in environmental justice communities. 

“We are dying every day. Our demands are ignored, and people die. We are tired of the minor changes, which are mere charity. We need something significant; we need environmental justice.” 

Dyna Anderson, New Jersey Environmental Justice Alliance

Additionally, the proposed rule would also revise federal preemption regulations for state and local action that addresses pollution from locomotives. We collectively submitted an additional comment letter expressing our support for this EPA action and for the agency taking a step further in the right direction to address the deadly harm caused by this largely unregulated industry. 

This Administration's commitment to environmental justice cannot end with words, a meeting, a press event, or money. Policy and regulations are needed to ensure that frontline and fenceline communities are protected and that they are able to thrive. Additionally, this regulation must meet the moment on climate too.

EPA’s Previous Action on Heavy-Duty Trucks Missed the Mark

Last year, EPA had a prime opportunity to finalize strong standards to reduce the amount of health-harming and smog-forming pollutants emitted by heavy-duty gasoline and diesel engines – like large trucks and school and transit buses. Ultimately, the final rule fell short and dismissed the possibility of a clear pathway to zero-emissions, largely due to a well-orchestrated lobbying effort by truck manufacturers and other critics of heavy-duty vehicle emission standards. You can read more about that action in this blog.

Our Asks for EPA’s Phase 3 GHG Rule

EPA now has a second chance to address this heavily polluting industry. Our demands align with a long-term goal to eliminate emissions from freight transportation, prioritize environmental justice communities and address the cumulative impacts caused by the freight sector. Specifically, we urge EPA to finalize a rule that ensures a clear pathway to 100% of all new heavy-duty vehicle sales being zero emissions by 2035. 

In our comments we hit on several key points including:

  • 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. Additionally, we urge EPA to go beyond solely considering the effects of emissions standards on job growth and to prioritize policies that consider the significance of a just transition with high-quality jobs.
  • A far stronger standard is feasible, economical, and provides cost savings. First, EPA has the authority under Section 202(a) of the Clean Air Act to adopt strong standards for motor vehicle emissions. Second, the zero-emission vehicle (ZEV) technology that can be used to comply with these standards exists. Third, significant public and private sector investments are supporting this transition and reducing barriers to adopting ZEV technology.
  • We need compliance with truly zero-emissions vehicles. The agency should explore incorporating structural additions to the rule that will provide certainty that truly clean and zero emissions technologies will be used to comply with the standard, rather than incentivizing alternative combustion fuels that are not truly zero emissions (such as hydrogen combustion and natural gas).
  • Freight trucks must be prioritized. Class 7 and 8 (short-haul) drayage trucks are some of the oldest and most-polluting vehicles in frontline and fence-line communities and these trucks need to be prioritized in heavy-duty vehicle regulations. These regulations must also involve establishing scrapping programs that prevent the re-sale, migration and increased density of these incredibly polluting vehicles in already overburdened, largely BIPOC and low-income communities where goods movement is concentrated.
  • Stronger standards deliver greater benefits. Lastly, we show that the potential benefits the agency associates with the various policy scenarios are more likely to be realized under a policy scenario that reflects the MFN recommended approach (where 100% of all new vehicle sales are zero emissions by 2035). This analysis is explored further below. 

Independent Analysis Affirms that Stronger Standards Deliver Greater Benefits 

Stronger standards deliver benefits for everyone and analysis by the independent research firm Environmental Resources Management, Inc. (ERM) affirms this.

ERM analyzed EPA’s Main Proposal (and preferred approach) for the Phase 3 HDV standards and alternative proposals, as well as the MFN recommended alternative proposal that is consistent with achieving a 100% ZEV sales share by 2035. 

MFN’s Approach Could Result in 2.1 Million EVs on the Road

Additionally, MFN’s recommended approach could result in 2.1 million EVs on the road by 2032, which is approximately 640,000 more EVs than would be possible under the Industry Commitments Alternative Proposal, and over 1.05 million more EVs than is projected to occur under EPA’s Main Proposal within the same timeframe. This is seen in the figure below which depicts the number of EVs in use broken down by vehicle type.

Figure 1. In-Use EVs by Vehicle Type 

MFN's Approach Results in Greater Climate Benefits

Our recommended approach would be expected to achieve over a 50% reduction in emissions of CO2 by 2040 compared to 2026 and result in nearly $115 billion in climate benefits by 2040, which is approximately $81 billion more than would be possible from EPA’s Main Proposal during the same timeframe. In comparison, EPA’s Main Proposal could only result in approximately a 20% reduction in emissions of CO2 by 2040 compared to 2026. Accordingly, if EPA fails to finalize a rule that aligns with our recommended approach, the agency would be unnecessarily leaving significant climate benefits on the table, as seen in the figure below.

Figure 2. Comparison of Possible Climate Benefits

MFN’s Approach Results in Greater Public Health Benefits 

Additionally, as a result of the increased amount of EVs that would be deployed under MFN’s recommend approach, we could expect to see over $63 billion in monetized benefits from reducing NOx and particulate matter (PM) emissions, as seen in the table below.

Table 1: Comparison of Possible Health Benefits 

MFN’s Recommended Approach Results in Greater Consumer Benefits

Utility Costs

Electrifying heavy-duty trucks could lead to up to $2.2 billion in net utility revenue under the MFN recommended approach. Since public utility commissions are required to return (to all utility customers) additional revenues in excess of authorized revenue requirements, this increase in net revenue from charging electric heavy-duty trucks would result in a slight reduction of the electricity bills of residential and commercial customers below what the bills would otherwise be without truck electrification. The average U.S. household could see modest reductions of approximately up to $12 per year and the average commercial customers could see reductions up to $86 per year. This dynamic is pictured in the figure below.

Figure 3: Incremental Utility Net Revenue and Peak Load from M/HDV ZEV Charging

Fleet Costs

ERM analysis shows that purchasing an average model year 2032 EV would save its owner nearly $86,000 over the life of the vehicle. The analysis depicted in the figure below incorporates several different cost categories (including purchasing chargers, charger maintenance, incremental purchase price between combustion vehicles and EVs, vehicle maintenance savings associated with EVs, and the difference in fuel costs between purchasing gasoline and diesel fuel versus electricity). 

Figure 4: Possible Net Lifecycle Costs

Possible net lifecycle costs of a battery electric truck (EV) versus the comparable diesel or gasoline alternative.

MFN’s Approach Can Double the Overall Societal Benefits Possible 

Lastly, the ERM’s analysis shows that on a net societal basis, MFN’s recommended approach would achieve two-and-a-half times the benefits of EPA’s Main Proposal by 2040. This is inclusive of the benefits and costs to fleets, air quality benefits, climate benefits, and the net utility revenues that would be returned to all utility customers in the form of lower electricity bills. This is depicted in the figure below.

Figure 5: Possible Annual Net Societal Benefits for Various Scenarios

MFN Strongly Supports EPA’s Proposed Rail Preemption Regulations Revision

Lastly, our comments responded to EPA’s proposed revisions to its rail preemption regulations – an important part of this rulemaking. Locomotive operations are responsible for a significant amount of health harming pollution in communities across the country and there is no way to protect community health or for states to achieve federal air quality sources without regulating pollution from these vehicles. 

Unfortunately, the industry has resisted modernizing. Railroads continue to utilize antiquated locomotives, including some that are 50 to 60 years old. In fact, according to 2021 data, 45% of Class I locomotives are classified as Tier 0, meaning that they emit many times more pollution than Tier 4 locomotives, which have been available on the market for years. To put this in perspective, EPA estimates that Tier 4 locomotives have 90% lower particulate matter emissions, and 80% lower nitrogen oxides emissions, than a Tier 2 locomotive. These old, dirty trains often operate in low-income communities and communities of color, who are simultaneously facing the cumulative impacts of pollution from industrial sites, and socioeconomic stressors. 

For decades, the rail industry has poisoned families, workers, and communities with a barrage of pollution from outdated locomotives. We support EPA in taking this critical action to clarify that states and local authorities are not preempted from adopting life-saving emission control measures for non-new locomotives. States and local governments have the duty to meet the federal air quality standards and to reduce pollution for their communities. At the same time, EPA has the duty and the responsibility to further reduce emissions from the railroad industry. 

It Is Time for EPA to Meet the Moment for Climate and Environmental Justice

Environmental justice communities continue to bear the public health and environmental consequences of the global freight system. It is time that frontline and fenceline communities are no longer forced to live in a system that opposes their basic needs of health and safety. We must transition the transportation sector to zero-emissions to guarantee necessary and lifesaving emissions reductions for these disproportionately impacted communities. 

EPA must act now and finalize a heavy-duty vehicle strong regulation that addresses cumulative impacts caused by the freight transportation sector and that ensures a just transition. 

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