Unpacking the EPA's new rule on cleaner trucks

The EPA has proposed a new rule for cleaner trucks, and the ICCT team is working hard to analyze the proposal and make suggestions for improvement before the rule is finalized later this year. This week, Ray Minjares testified about some of our findings.

The ICCT welcomes the EPA's proposal. The EPA must finalize this year so as not to miss the window on appropriate lead time for MY2027 standards. We are suggesting 3 major changes to the EPA's proposal.

First, the EPA should proceed with proposed Option 1 for its NOx standards but further strengthen it to fully align with California's Omnibus rule. For details on that rule, see our recent policy briefing.

Why not Option 2? By EPA's estimates, Option 2 would allow 1.25 million additional tons of NOx emissions and lead to up to $16 billion in cumulative health damages through 2045. Allowing these impacts to occur would be unacceptable since the EPA's Option 1 would protect public health to a greater extent, using technologies that are commercially available and justified based on benefits relative to costs.

Option 2 would allow 1.25 million additional tons of NOx emissions and lead to up to $16 billion in cumulative health damages through 2045.

Second, in the current proposal, revisions to GHG standards do not go nearly far enough to close the significant gap between current U.S. HDV policies and climate goals. To limit global temperature rise to within 2°C, at least 46% of new class 4-8 trucks and buses need to be zero-emission in 2030. Not all market segments are created equal. Some can transition more quickly because of the favorable total cost of ownership, product availability, and rapid infrastructure deployment.

Now, what does this mean for buses?

By 2030, 100% of new buses will need to be zero-emission.

How about urban delivery trucks?

In 2030, 50% of new class 4-8 rigid trucks will need to be zero-emission.

And semis?

In 2030, 30% of new tractor-trailers will need to be zero-emission.

For our take on a national ZEV roadmap for heavy-duty vehicles through MY2030, check out this recent blog.

We believe the best way for the EPA to achieve these outcomes is by including minimum ZEV production requirements in its greenhouse gas standard. Meeting a 1.5°C target would require even greater ambition and the EPA cannot afford to wait until 2030 to accelerate this transition.

The best way for the EPA to achieve these outcomes is by including minimum ZEV production requirements in its greenhouse gas standard.

Finally, we believe the EPA should also change its approach to ZEV crediting, which in its current form is projected to undermine the benefits of the proposed NOx and GHG standards. Our view is that the EPA has the authority to set minimum production requirements to ensure this ambition is met. Under the NOx standards, we recommend that the EPA eliminate ZEV credits.

Under the GHG standards, the EPA should eliminate advanced technology credit multipliers, not allow credits from states who have joined the Advanced Clean Trucks Program, and limit the lifetime of any credits that are generated.

Stay tuned for more details in our written public comments in the coming weeks.

We need cleaner trucks.