September 12, 2022
California Air Resources Board
Byron Sher Auditorium
1001 I Street
Sacramento, California 95814
Coalition for Clean Air Comments on the
Proposed 2022 State Strategy for the State Implementation
Plan
California is home to the most polluted air in
the United States. Air pollution causes a wide range of health
impacts, including asthma attacks, heart attacks, strokes, lung
cancer and thousands of premature deaths annually in California.
Pollution threatens the health of all Californians, but especially
those in our most disadvantaged communities and communities near
ports, railyards, warehouses and other major trucking routes.
The 2022 State Strategy for the State
Implementation Plan (SSSIP) needs to provide a map toward
delivering healthy air to all Californians. We appreciate all the
hard work that went into the proposal and look forward to
collaborating with CARB on implementing many of the measures. At
the same time, we think it important to point out that the proposal
is unlikely to bring the South Coast and San Joaquin Valley regions
into attainment with national ambient air quality standards.
Achieving clean air will require concerted
action by CARB, the federal government and the air districts. We
strongly agree with the statement that “For California to
meet air quality standards, it is imperative that the federal
government act decisively to reduce emissions from
primarily-federally regulated sources of air pollution, including
interstate trucks, ships, locomotives, aircraft, and certain
categories of off-road equipment.” Unfortunately, we can not
say with confidence that the federal government will in fact
fulfill its duty to take those actions.
Zero Emissions Trucks
Measure
Heavy-duty trucks are responsible for over
half of smog- and particle forming emissions despite representing
only three percent of the vehicles on California roads. Diesel
exhaust is a toxic air contaminant containing dozens of carcinogens
and is often concentrated in low-income communities and communities
of color. Recent CARB estimates indicate that nearly 145,000 trucks
would be considered gross polluters under the planned Heavy-Duty
Inspection and Maintenance program as vehicles age and emission
controls deteriorate over time.
Requiring the retirement of old heavy-duty
diesel trucks is probably the single biggest step that CARB could
take to reduce air pollution and improve lung health in California.
Adopting such a measure would require no additional statutory
authority; only willingness by the Board to take this life-saving
step. Therefore, we appreciate the inclusion of the Zero Emissions
Trucks Measure in the SSSIP, in response to suggestions from the
public, and we recommend some improvements to maximize its
effectiveness.
How
Does State Law Define “Useful Life?”
Section 43021 of
the Health and Safety Code, enacted by SB 1 in 2017, intends
to provide “certainty about the useful life of engines.” The
provision prohibits CARB from requiring the retirement,
replacement, retrofit, or repower of heavy-duty trucks until they
have reached at least 13 years of age and then reach either 800,000
miles or 18 years, whichever comes first. This definition of useful
life was de facto
sponsored by the California Trucking Association. However, nothing
currently requires heavy-duty trucks to be removed from operation
at the end of their useful life.
What are the benefits of
retiring old trucks?
- Combustion engines and emission controls degrade as mileage
and time accumulate, so older fossil fuel trucks almost always emit
more per mile than younger ones;
- Before 2013, heavy duty trucks did not have on-board
diagnostics (OBD), which means their emission controls are not as
robust and excessively polluting trucks will not be identified as
well by CARB’s proposed Inspection and Maintenance rule,
which will rely heavily on OBD;
- All new trucks sold from 2024 onward will have to meet
stronger NOx standards from the Heavy-Duty Omnibus (HDO) rule.
Mandated retirement will shrink the overall pool of pre-2024 diesel
vehicles; and
- Mandating retirement will provide more
opportunities for the deployment of cleaner technologies and enable
better planning by providing more certainty on truck turnover. For
instance, the upcoming Advanced Clean Fleets rule would drive an
increasing number of purchases of zero emission (ZE) trucks. New
entrants to the Drayage Truck Registry would have to be ZE
from 2024
on.
The Timetable for the Zero Emissions
Trucks Measure Should be Accelerated
The measure in the proposal would
potentially come before the Board in 2028, go into effect in 2030,
and could follow one of two pathways. Given the urgency of our air
pollution crisis, the Board should take action sooner, because all
of the 2010 trucks will have reached the end of their useful lives
by 2028.
Therefore, we recommend that CARB
decide by the end of 2024 which option it will pursue, with the
Board acting no later than 2026 so that the rule can be implemented
by 2028. The statewide NOx reductions of 14.3
tons per day make this measure one of the most significant in the
SSSIP, and we cannot afford to delay or equivocate in implementing
the measure.
Respectfully Submitted,
Bill Magavern
Policy Director
Coalition for Clean Air
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