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 Philly IPL Chapter’s April 12th Program!

Can PGW Accelerate Philadelphia’s Clean Energy Transition?

The city-owned Philadelphia Gas Works (PGW) acquires, stores, and distributes natural gas to churches, libraries, schools, industry, restaurants, other businesses, and residences in the city of Philadelphia. The gas is used for heating, hot water, cooking, and industrial processes. PGW employees install and repair the network of underground pipes that deliver gas to consumers. Methane, the primary component of natural gas, is a fossil fuel. When burned it produces CO2, the major greenhouse gas. When natural gas leaks along the way from well to consumer it contributes to global warming because methane itself is a significant greenhouse gas. Natural gas is a large part of Philadelphia’s carbon footprint.

In order to avoid ever worsening effects of climate change, the UN’s IPCC says we must cut in half our use of fossil fuels by 2030 and eliminate them entirely by 2050. What can and should be PGW’s response to this requirement? How do we wean Philadelphia from its natural gas addiction?

The discussion leader at our April PA IPL Philadelphia Chapter meeting is Mitch Chanin. Mitch is a long time Philadelphia climate activist. He was a leader in the opposition to SEPTA developing a gas-fired electric generating station in the Nicetown section of Philadelphia. Mitch is the co-chair of the Climate Justice Caucus at Reclaim Philadelphia and is also a member of Philly Thrive and Philly DSA. As a volunteer with POWER Interfaith, Mitch is a member of the PGW Just Transition campaign team and has presented testimony to the Philadelphia Gas Commission. We will be talking about the work that has gone on in this area and about the pros and cons of different options for reducing Philadelphia’s reliance on natural gas and encouraging the use of clean, renewable energy.

Sign up here if you would like to join the Philadelphia chapter of PA IPL!

Philadelphia PA IPL Local Chapter Meeting – April 2022

This month’s meeting will be held on April 12th:
Can PGW Accelerate Philadelphia’s Clean Energy Transition?
REGISTER HERE

The city-owned Philadelphia Gas Works (PGW) acquires, stores and distributes natural gas to churches, libraries, schools, industry, restaurants, other businesses, and residences in the city of Philadelphia. The gas is used for heating, hot water, cooking, and industrial processes. PGW employees install and repair the network of underground pipes that deliver gas to consumers. Methane, the primary component of natural gas, is a fossil fuel. When burned it produces CO2, the major greenhouse gas. When natural gas leaks along the way from well to consumer it contributes to global warming because methane itself is a significant greenhouse gas. Natural gas is a large part of Philadelphia’s carbon footprint.

In order to avoid ever worsening effects of climate change, the UN’s IPCC says we must cut in half our use of fossil fuels by 2030 and eliminate them entirely by 2050. What can and should be PGW’s response to this requirement? How do we wean Philadelphia from its natural gas addiction?

The discussion leader at our April PA IPL Philadelphia Chapter meeting will be Mitch Chanin. Mitch is a long time Philadelphia climate activist. He was a leader in the opposition to SEPTA developing a gas-fired electric generating station in the Nicetown section of Philadelphia. Mitch is the co-chair of the Climate Justice Caucus at Reclaim Philadelphia and is also a member of Philly Thrive and Philly DSA. As a volunteer with POWER Interfaith, Mitch is a member of the PGW Just Transition campaign team and has presented testimony to the Philadelphia Gas Commission. We will be talking about the work that has gone on in this area and about the pros and cons of different options for reducing Philadelphia’s reliance on natural gas and encouraging the use of clean, renewable energy. There will be plenty of time for questions and discussion.

We look forward to welcoming you on Tuesday, April 12th at 7:00pm via Zoom. If you can’t attend but are interested in the program, please register and we will send you the recording.

REGISTER HERE

Please note:
*  The Philly PA IPL’s normal monthly chapter meeting will take place from 7:00 – 7:30pm for chapter members only.
*  The program, which is open to all, begins at 7:30pm.


The Philadelphia chapter of PA IPL is very active. Chapter volunteers plan workshops, services, and work in coalition with many other groups bringing faith voices to climate justice and clean energy transition efforts, and they bring climate justice voices to faith work. Their monthly meetings are on the second Tuesday of the month at 7:00 PM, and are open to everyone. Particular meetings may focus either on planning or on a particular program.

Sign up here if you would like to join the Philadelphia chapter of PA IPL!

Build Back Fossil Free, 2022 Letter to President Biden

Dear President Biden,

As organizations collectively representing millions of members and supporters, including Indigenous, Black, Brown, and frontline communities, we urge you to use your executive authority to speed the end of the fossil fuel era, protect our communities from the climate emergency, and address the severe harms caused by fossil fuels.

Your first year in office was marked by historic climate disasters, another alarming surge in domestic greenhouse gas emissions, and increasingly dire warnings from the leading scientists around the world. From hurricanes and floods, to wildfires and droughts, tens of millions of Americans are directly confronting the dangerous consequences of a warming world. Indigenous, Black, Brown, AAPI and working-class communities are disproportionately harmed not only by fossil-fueled extreme weather, but also targeted by oil, gas, and coal corporations and suffer the health impacts of toxic pollution and ongoing environmental injustices.

You have repeatedly identified the existential threat posed by climate change, calling it a “code red” for humanity, and stated in your first week in office, “In my view, we’ve already waited too long to deal with this climate crisis. We can’t wait any longer.”

You further promised “environmental justice will be at the center of all we do addressing the disproportionate health and environmental and economic impacts on communities of color — so-called ‘fenceline communities’.” And you elevated the respect of Indigenous sovereignty and ordered federal agencies to strengthen nation-to-nation relationships with Tribes.

These statements must be backed up by bolder action. You have the authority under existing law to wind down fossil fuel production and catalyze a just, renewable energy revolution to deliver healthier communities, a livable future, and millions of good-paying jobs. It’s critical that you use that authority as quickly and broadly as possible.

Together, we call on you to take these steps:
— Follow through on your promise to ban all new oil and gas leasing, drilling, and fracking on federal lands and waters.
— Direct federal agencies to stop approving fossil fuel projects, including pipelines, import and export terminals, storage facilities, refineries, and petrochemical plants. Direct the Department of Energy to halt gas exports to the full extent authorized by law.
— Declare a climate emergency under the National Emergencies Act , unlocking special powers to reinstate the crude oil export ban, redirect disaster relief funds toward distributed renewable energy construction in frontline communities and marshal companies to fast-track renewable transportation and clean power generation, creating millions of high-quality union jobs.

The U.S. must contribute its fair share to the global effort to limit temperature rise to 1.5 degrees Celsius in line with what science, justice, and equity demand. Your administration’s legislative and regulatory climate proposals have not addressed limiting the production and burning of fossil fuels, the main driver of climate change. As fossil fuel lobbyists and politicians continue to block real climate action in Congress, bold executive action is desperately needed.

President Biden, you are the chief executive with immense powers to address our communities’ concerns.

You showed what serious climate leadership could look like in your first week in office when you canceled the Keystone XL pipeline and paused oil and gas leasing on federal lands. The urgency of the moment requires you to return to that original ambition. Fully deliver on your climate and environmental justice promises by using your executive authority to keep fossil fuels in the ground and build a resilient and affordable renewable energy system.

Renewable Energy & The National Environmental Energy Standard with JEA

Part of PA IPL’s Ongoing Partnership with Jewish Earth Alliance

Speakers: Odette Mucha, Mid-Atlantic Regulatory Director and Federal Liaison Vote Solarand
An inspirational spiritual speaker.

Jewish Earth Alliance and PA Interfaith Power & Light are co-sponsoring this informational and motivational meeting on Wednesday, September 1 at 7:30pm.

The US still gets 60% of its electricity from fossil fuels. Electrical generation is a major source of carbon emissions, second only to transportation. To avert the worst effects of climate change we need to use 100% clean renewable energy such as from solar or wind. A federal Clean Energy Standards (CES) would mandate progress toward the use of renewables for the entire country, which would be a tremendous step toward eliminating the greenhouse gas emissions causing climate change.

Democrats are aiming to pass a budget under the rules of reconciliation, offering another opportunity to remediate the climate crisis. Their proposed $3.5 trillion budget includes CES, and other climate solutions such as electric car incentives and energy efficient buildings. Members of Congress need to hear our call for comprehensive CES that accelerates the transition to renewable energy, with justice for communities harmed by fossil fuel.

REGISTER HERE for Wednesday, September 1st.