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

Reconciliation Package Must include Strong Manufacturing Measures

Great news! Pennsylvania Interfaith Power and Light has joined other organization across the state for a sign on regarding the passing of a bold reconciliation package that will help rebuild our manufacturing sector in ways that will deeply reduce emissions while building domestic supply chains and creating and protecting good union jobs for workers and disadvantaged communities.

Serious action is required to address climate change and strengthen the U.S. economy for all. The following provisions must be included in any negotiations around budget reconciliation as well as future climate infrastructure packages to ensure that the Appalachian region can create a thriving manufacturing renaissance in the region.  We deserve it.

Appalachia can and should be a leader in the global economic race to modernize domestic manufacturing.

Several provisions key to building this future include:

  • Key investments to reduce climate pollution in emissions-intensive industries—such as cement, steel, and aluminum. We can reduce these emissions at scale by funding industrial efficiency measures and emissions reduction technology as well as broader supply chain programs.
  • Spurring domestic clean technology manufacturing through measures such as $25 billion in funding for 48C together along with new supply chain production tax credits that expand clean energy and technology manufacturing and onshore key supply chains.
  • Strong funding to strengthen the domestic automotive supply chain, protect workers and communities, and build the electric vehicle (EV) fleet of the future in Appalachia. This includes new funding for the Advanced Technology Vehicles Manufacturing (ATVM) loan program and manufacturing conversion grants—together enabling over $20B in investments to retool automotive manufacturing to build the EV technology of the future in existing plants and communities.
  • Support Manufacturing Supply Chains and Manufacturing-Centered Economic Development. In addition to investments that support clean technology manufacturing expansion and retooling directly, it is also critical to ensure that we expand and fund the broader programs that provide the economic, technical, and workforce infrastructure and support to strengthen advanced manufacturing ecosystems and communities.
  • Ensure that clean energy deployment tax credits include labor and domestic content standards and support the retention and growth of domestic manufacturing and high-quality jobs.

These provisions would make a historic investment in the expansion and retooling of domestic clean energy, vehicle and component manufacturing, the transformation of our industrial sector to reduce emissions and enhance competitiveness, as well as the necessary efforts to build out robust supply chains for critical clean technologies—all while building family sustaining careers and investing in the communities that need it most.

Any reconciliation package should advance a sustainable economic vision for a 21st century Appalachia—one that is good for working people, communities, the environment and our health. Our communities have many assets, but a sustainable economic future can’t be achieved without significant public investment, strong policies, and responsible economic development approaches designed to maximize the benefit to the community as a whole.

You can read more and sign on here.


UPDATE ON JUNE 6, 2022:

You can see the final letter here.

Tell your Senators Climate Can’t Wait!

Please take a moment to write to your Senators. Below is the template email to your members of Congress. Feel free to edit the letter on the next page before you send it, personalized letters are more effective.

Dear Senator,
As a person of faith and conscience, I believe that leaving a safe and thriving world to the next generation is a moral imperative. Climate change threatens the very life support systems that the planet provides. The issue could not be more urgent and we must invest now to shift off of fossil fuels and move rapidly to a clean energy economy.
I urge you to support big, bold investments in renewable energy, clean vehicles, environmental justice, and climate resilience by passing climate and clean energy investments through reconciliation. These investments will go a long way toward protecting our climate and rebuilding our crumbling infrastructure to meet the demands of a 21st century economy. It will also invest in rebuilding communities that have borne the brunt of pollution for too long.
Congress has a historic opportunity to make a difference in the lives of Americans for generations to come. Please support the important climate elements of the budget reconciliation bill that will protect our world and secure a more just and prosperous future for all people.
Sincerely,
[Your Name]

Let’s raise our collective voices and ensure our elected leaders get the $550 billion in climate and clean energy investments across the finish line. Email your senators and urge them to #GetClimateDone.

Climate can’t wait. We need action now.

PRESIDENT BIDEN, HIS CABINET, AND All MEMBERS OF CONGRESS:

Climate can’t wait. People across the country want bold climate action to protect our common home.

We need bold action that supports families in our communities and addresses core moral concerns. This includes the most significant climate and clean energy investments EVER – that will create jobs and protect clean air and clean water for all.

We have a moral responsibility as a nation, and a sacred task as people of faith, to care for our climate and to leave a safe and thriving world for future generations. That’s why we need to pass the $550 billion in investments that will deliver on climate, justice, jobs, and clean energy.

Add your name to this petition.

¡El clima no puede esperar! ¡Necesitamos que se tome acción ahora!

PRESIDENTE BIDEN, SU GABINETE, Y TODOS LOS MIEMBROS DEL CONGRESO:

El clima no puede esperar. La gente de todo el país quiere acciones significativas a favor del clima para proteger nuestro hogar en común.

Necesitamos acciones contundentes que apoyen a las familias en nuestras comunidades y enfrenten las preocupaciones morales fundamentales y que sean las inversiones más significativas a favor del clima y de la energía limpia EN LA HISTORIA que crearán empleos y protegerán un aire y un agua limpios para todos.

Tenemos una responsabilidad moral como nación, y una tarea sagrada como personas de fe, de cuidad de nuestro clima y dejar un mundo seguro y próspero para las futuras generaciones. Es por esto por lo que necesitamos que se aprueben los $550 mil millones en inversiones por el clima, la justicia, los empleos y la energía limpia que protegerán de nuestra salud y de nuestro medioambiente.

Añade tu nombre a esta petición.

Feeling pain at the pump? Here’s what you can do:

Energy Independence Requires Clean Energy

Gas prices have skyrocketed and American families are paying the price.

Despite raking in record profits in 2021, the oil and gas industry is exploiting the crisis in Ukraine by pushing out misinformation to line their pockets and gain a free pass to drill for more fossil fuels.

There’s something you can do. Sign this petition.

Most of the big oil and gas companies posted huge profits in 2021, the highest profits seen in years. Yet, they are driving up energy costs for families with higher prices for gasoline, home heating oil and other energy. Even with US oil and gas production nearing record levels, Americans haven’t been spared from volatile fossil fuel prices.

No one should be profiting from a war, but that’s exactly what the fossil fuel companies are trying to do. And while big oil and gas get richer, Americans get more hurricanes, floods, wildfires and heatwaves, made worse by intensifying climate change.

Clean energy, not more oil and gas, will protect Americans from the volatile and dangerous fossil fuel economy. Wind, solar, and other renewable sources, are homegrown and create good-paying jobs here in the US. We don’t need to import it and it is not subject to the wild fluctuations of the global fossil fuel markets and supply chain disruptions. The clean energy and climate provisions under consideration in Congress would reduce annual US. oil consumption by 180 million barrels per year by 2030–roughly twice current US imports of Russian oil.

You actually can make a difference in this debate by signing this petition to Sen. Majority Leader Chuck Schumer. Sign now.

If members of Congress and the Biden administration are serious about energy security and energy independence, they need to say no to more fossil fuels no matter where they come from.

We’ll be delivering thousands of petitions to Congress who can act to reduce prices on things our families need. Make sure your name is on the list. Sign here.

Climate Can’t Wait: Add your name to the petition to Biden

If you are not a faith leader you can add your name to our petition to President Biden calling on him to keep his promise to take meaningful action on climate, justice, and clean energy.

The Build Back Better Act includes the most significant climate and clean energy investments ever- and it will create jobs and protect clean air and clean water for all. We need to pass the most comprehensive version of the Build Back Better Act possible, including the $550 billion in investments that will deliver on climate, justice, jobs, and clean energy.

Our climate, our communities, and our faith compel us to call for bold and just action. We have a moral responsibility as a nation, and a sacred task as people of faith and conscience, to care for our climate and to leave a safe and thriving world for future generations.

Thank you for helping encourage bold climate action for our neighbors and our common home.