Pennsylvania Solutions for Pollutions Launch Event

This September, the Climate Action Campaign (CAC) is joining with dozens of coalition partners to launch the Solutions for Pollution (S4P) campaign demanding that agencies across the federal government set the strongest possible standards to deliver solutions for pollution.

The “Solutions for Pollution” campaign (S4P) will call on the Biden administration to carry out its responsibilities under our nation’s bedrock environmental laws, such as the Clean Air Act, by advancing approximately 20 protections across federal agencies that could cut climate pollution in half by 2030, advance vital public health and environmental justice goals, accelerate the transition to clean energy, and create new economic opportunity.

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EPA Heavy-Duty Rule State Sign-On Letter to Senators

Sign on by FRIDAY, SEPTEMBER 16 by close of business.

September X, 2022

Dear Senator:

On behalf of our millions of supporters, we write in response to the letter submitted on July 11, 2022, addressing EPA’s proposed rule on “Control of Air Pollution From New Motor Vehicles: Heavy-Duty Engine and Vehicles Standards” (Docket ID No. EPA-HQ-QAR-2019-0055). The letter expressed reservations about EPA’s proposed Option 1. We wish to assuage those concerns and emphasize why EPA’s final rule should strengthen and exceed Option 1.

The Importance of a Strengthened Option 1

EPA must finalize the strongest possible rule to address climate and air pollution impacts caused by heavy-duty trucks. Heavy-duty vehicles make up 10 percent of U.S. on-road vehicles, but contribute 45 percent of the transportation sector’s nitrogen oxide (NOx) pollution, 57 percent of its fine particulate matter (PM) pollution, and 28 percent of the sector’s greenhouse gas (GHG) emissions. 40 percent of U.S. ports and other freight facilities are in areas failing to meet the National Ambient Air Quality Standards (NAAQS) for ozone and particulate matter. This is concerning, as 72 million people live within 200 meters of a truck freight route, and are disproportionately people of color and lower income. A stringent Option 1 would create significant public health and environmental impacts needed.

EPA’s proposed Option 1 builds on the success of the Low-NOx Heavy Duty Omnibus (HDO) rule, which has already been adopted by California, Oregon, and Massachusetts, and is under consideration in other states. This option would implement NOx standards in two steps, starting in 2027 and align with some state actions after an additional step up in stringency in 2031. Under Option 1, the expectation is that by 2031, NOx standards would be 90 percent lower than today’s standards. EPA estimates this would achieve a 60 percent reduction in harmful NOx emissions, compared to the weaker Option 2 only achieving 47 percent reduction. Finalizing an enhanced version of Option 1 that occurs on a condensed timeline is critical for freight-impacted communities, given the urgency of the issue.

Need to Take a Consensus-based Approach

Under the Clean Air Act, EPA is required to set “standards which reflect the greatest degree of emission reduction achievable through the application of technology which the Administrator determines will be available for the model year to which such standards apply.” It also requires the agency to give “appropriate consideration” to costs and other factors. Following three days of public hearings and a public comment period on this proposal, diverse stakeholders have demonstrated overwhelming support for EPA to at a minimum adopt Option 1, if not a more stringent final rule. These stakeholders included health advocates, community groups, scientists, the business community, emission control manufacturers, state and local elected officials, and even engine manufacturers.

Feasibility of the Standards

Option 1 does not require reinventing emission control systems for internal combustion engines according to extensive multi-year research, testing, and stakeholder engagement from California regulators which concluded meeting a 0.02 g/bhp-hr NOx standard by 2027 is feasible and cost-effective. In addition, Ford, a major truck manufacturer, publicly stated they can meet the standard. Manufacturers of Emission Controls Association (MECA) also publicly affirmed Option 1’s feasibility. Meanwhile, other manufacturers are acquiring emission control companies capable of meeting the stronger state standards. A strengthened Option 1 also includes compliance flexibilities to ensure manufacturers are able to meet the standard, incentivize ZEV deployment, and maximize emission reductions.

Unintended Consequences: Diversion of Investment and Labor Concerns

Meeting stringent combustion engine pollution standards and deploying ZEVs are not mutually exclusive, yet there are manufacturers fighting strong standards to “avoid a diversion of investment” from electrification efforts, while publicly announcing advances in zero-emissions technology and significant investments in truck charging networks. In addition, significant investments are available to support them from the recently passed Infrastructure Investments and Jobs Act (IIJA) and the Inflation Reduction Act (IRA). Manufacturers have cited concerns on costs, pointing to an unverifiable survey conducted with inflated projections and an industry-funded report lacking peer review. In contrast, the California Air Resources Board (CARB), the International Council on Clean Transportation (ICCT), MECA, and EPA, have published lab testing-backed cost projections that are significantly less than the industry survey.

Industry also argues that these standards come at a cost, causing fleet managers to stock up on older truck models before the new standard comes into effect (“pre-buy”), resulting in a decrease in sales after the standard begins (“no-buy” or “low-buy”). A small group of manufacturers claim these standards will result in job cuts like previous heavy-duty emission standards. However, EPA issued a report in 2021 concluding that larger economic forces–not emissions standards–have been primary drivers of past declines in heavy-duty truck sales, and showed how critics conflate correlation with causation. 

Conclusion

EPA must quickly and effectively address greenhouse gas and air pollution from heavy-duty trucks, and the best way to achieve this is by strengthening Option 1. We hope to have your support and we look forward to continuing discussions on the best pathways to reduce emissions in affected communities and growing manufacturing jobs in this sector.

Signed,
Your Name

Now Available: Video of Southwest PA Chapter’s January 26th Program!

Indoor & Outdoor Ambient Air Quality

On Wednesday, January 26th at 6:30pm the Southwest PA Chapter of PA IPL welcomed Linda Wigington, of Reducing Outdoor Contaminants in Indoor Spaces (ROCIS).

January’s meeting and program focused on Indoor & Outdoor Ambient Air Quality. It began with a Reflection, time was provided for attendees to tell personal stories, there were PA IPL updates and introductions, and then we learnt more about indoor & outdoor ambient air quality from Ms. Wigington.

Sign up here if you would like to join the Pittsburgh & SW PA IPL Chapter!

January 2022 Pittsburgh & SW PA IPL Chapter Meeting

Please join us for our first Pittsburgh & SW PA IPL Quarterly Chapter Meeting taking place on Wednesday, January 26th from 6:30pm – 8:00pm!

This month’s meeting and program will focus on Indoor & Outdoor Ambient Air Quality. We will begin with a Reflection, provide time for attendees to tell personal stories, include PA IPL updates and introductions, and learn more
about indoor & outdoor ambient air quality from Linda Wigington, of Reducing Outdoor Contaminants in Indoor Spaces (ROCIS).

Register here to attend the SW PA IPL Quarterly Meeting and learn how you can be part of the February Cohort and impact the ROCIS Mission:

Reduce the impact of exterior environmental pollution in southwestern Pennsylvania to improve healthy and energy efficient indoor environments where we live, work, and learn.

We will automatically send you a meeting link after you register.

There is no fee for this program, but a suggested $5 donation will help us keep doing this work.

We look forward to welcoming you on Wednesday, January 26th at 6:30pm via Zoom.