Chair Randolph and members of the board, my name is Sam
Wilson and I’m a Senior Vehicles Analyst with the Union of
Concerned Scientists, a national nonprofit that puts rigorous
science to work in our democracy. On behalf of our half-a million
supporters, thank you for the opportunity to comment on this highly
consequential regulation.
Thanks to CARB staff for their hard work and robust public
process. The ACF is a crucial step in the right direction to reduce
GHG emissions, help to relieve disproportionate health burdens on
freight-adjacent communities and accelerate the market and tech for
clean heavy-duty vehicles.
While we support this proposal, it does not adequately
address the outsized impacts of tractor trucks. Big rig trucks are
just around 10 percent of the state’s medium and heavy-duty
fleet but are responsible for about half of GHGs, NOx, and fine
particulate emissions from HD vehicles. However, the compliance
threshold under the rule is agnostic to the fact that different
types of trucks and fleets contribute vastly different amounts of
pollution. For example, a fleet of 50 tractor trucks emits around
14 times as much NOx, 4 times the fine particulates, and 4.5 times
the GHG emissions as a fleet of 50 class 2b delivery vans.
Our analysis shows that a compliance threshold of 10 for
tractors would best account for the significant pollution from
these trucks – it would bring nearly 90 percent of tractor
truck emissions under the rule, while only regulating around 10
percent of tractor fleets in the state AND leaving the most
vulnerable small businesses outside the regulation. A lower
threshold would also help to address the exclusion of certain
tractor trucks under the drayage portion of the rule, which would
allow combustion-powered auto transports and fuel delivery drayage
trucks to operate nearly 20 years past the Governor’s goal of
100 percent drayage operations by 2035.
Finally, other 177 states have signaled their intent to
adopt a dynamic threshold by establishing fleet reporting
thresholds of 5.
A dynamic compliance threshold that recognizes the outsized
impacts of the dirtiest trucks would supercharge the benefits ACF
is poised to deliver. Thank you.