Sunday, October 16, 2022
Clerks’ Office
California Air Resources Board
1001 I Street
Sacramento, California 95814
Subject: Strengthen the
Advanced Clean Fleets Rule -- Notice of Public Hearing to Consider
Proposed Advanced Clean Fleets Regulation
Dear
California Air Resources Board Chair Randolph and Members of the
Board:
Thank you for your work in developing the
Advanced Clean Fleets (“ACF”) thus far. I am writing to
urge you to accelerate your proposed 100% sales target from 2040 to
2036. The work that the California Air Resources Board (CARB) is
doing to eliminate pollution from California’s heavy and
medium-duty trucks is admirable, but the climate and air quality
crises demand more urgency from CARB than what is currently
planned.
Californians are feeling the impacts of the
climate crisis every day, from extreme heat to rising sea levels to
wildfires to droughts. Millions of Californians continue to live in
communities that are out of compliance with federal air quality
standards. The state must urgently move away from fossil fuels and
towards renewable energy and zero emission technologies to help
address these critical issues.
Diesel trucks are one of
the fastest growing sources of greenhouse gas emissions, the
largest source of California’s nitrogen oxide
(NOx) pollution, and the largest source of air pollution
disparity in the United States. Trucks make up a small portion of
vehicles on the road in California but are the largest producer of
our notorious smog problem and pose the most cancer risk connected
to pollution from our transportation sector. Burning diesel creates
one of the most toxic forms of air pollution for human health, and
is linked to premature death, chronic heart and lung disease,
asthma, and diminished lung function in children. Without immediate
action, the freight industry’s rapid growth means pollution
burdens will worsen, especially for low-income communities of
color. A delayed timeline for 100% electric trucks will only lead
to further health and climate impacts.
Delivery vehicles
have become part of our daily lives. All over the world, they clog
up our streets, take up space on our already congested roads and
pollute the air we breathe—and the situation is getting
worse. The Covid-19 pandemic normalized same-day and next-day
deliveries, and the inexorable rise of online shopping means the
delivery industry is only likely to grow—the United States is
currently the second biggest e-commerce market in the world, and is
expected to grow to a staggering US$1.3 trillion by 2025. This is
an environmental justice issue: communities of color and low-income
communities are the most likely to be nearby major freight routes
and therefore exposed to this pollution.
CARB’s
proposed Advanced Clean Fleets rule would deliver significant
emissions reductions, but the current proposal leaves too many of
California’s buses and trucks unaccounted for. CARB cannot
miss this opportunity to get polluting trucks off the road as soon
as possible. The ACF is critical to addressing California’s
climate and environmental justice crises associated with this boom
in e-commerce, and beyond. Strengthening the ACF rule is one of
CARB’s most critical opportunities to a pathway that meets
Governor Newsom’s Executive Order, the targets in the Mobile
Source Strategy, and our health and climate needs. The rule also
sets precedent for the rest of the country—an opportunity
that cannot be missed.
As CARB Staff’s analysis
confirms, adopting Alternative 2 is feasible and will lead to
critical emission reductions. Therefore, I ask that CARB change the
proposed Advance Clean Fleets regulation in line with Alternative 2
in the Initial Statement of Reasons (ISOR).
Specifically, CARB should:
1) require 100% zero
emission truck sales in California by 2036 (instead of 2040, as
proposed);
2) reduce the size of class 7 and 8 (big rig)
fleets covered by this rule from 50 to 10; and
3) begin
transitioning all trucks to zero emission starting in 2027 (instead
of 2030, as proposed).
California is far from attainment
in the most polluted air basins in the nation and from meeting the
2030 climate targets. Meanwhile, emissions from freight are rising
and new warehouses and logistics centers sprout almost weekly,
consuming the land and air around low-income communities of color.
Even more dramatic reductions are needed to fulfill CARB’s
obligations, but anything less than Alternative 2 imperils the
chances of doing so.
Alternative 2 delivers
substantially greater emission reduction benefits at little
additional cost. CARB staff’s assessment demonstrates that
advancing the 100% sales requirement to 2036 and lowering the fleet
threshold to 10 or more trucks would greatly speed the delivery of
ZE trucks. These components will add earlier and larger reductions
in NOx, fine particulates (PM2.5), and greenhouse gases
(GHGs), and avoid thousands of additional deaths and
hospitalizations. Benefits from Alternative 2 include:
*
Over 130,000 more ZE trucks in 2050;
* 43% to 60% greater
reduction tons of NOx and harmful fine particulate
emissions;
* 40% to 54% greater reduction of greenhouse gas
emissions;
* $25 to $34 billion in additional health benefits;
and
* 2,500 to 3,000 avoided premature deaths.
The
pace of progress in the zero emission truck sector is promising
with even more favorable research published as well as new
announcements for investment in battery and vehicle manufacturing,
charging infrastructure, and large purchase orders. Stronger
regulations will speed the maturation of a market that is already
growing.
Even with the changes we are calling for, the
ACF will not guarantee the level of ZE truck deployments necessary
to achieve our air and climate targets. But, the stronger
alternative will not only bridge the gap to our targets but build
the signals and momentum necessary to reach earlier tipping points
that unlock greater progress.
As you know, the Clean Air
Act waiver allows California to adopt stronger standards than those
of the federal government and set the precedent for the rest of the
country on how to mitigate vehicle emissions. California can
achieve and even exceed current commitments, and set the stage for
other states to follow suit. The fate of our air quality and the
planet depends on this outcome, which CARB has the unique ability
to influence. CARB cannot miss this opportunity to combat the
climate crisis and deliver clean air to overburdened, frontline
communities. Please do right by everyone in California and bring
100% electric trucks to California on the swiftest possible
timeline. Please update the rule to align with Alternative 2. I
urge you to use your power to ensure that our streets are for
people, not pollution.
Thank you for your consideration
of my comments. Please do NOT add my name to your mailing list. I
will learn about future developments on this issue from other
sources.
Sincerely,
Christopher Lish
San
Rafael, CA
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