Comment Sample for the Proposed Rule by the Environmental Protection Agency: Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine and Vehicle Standards
The Environmental Protection Agency has proposed a new rule to limit greenhouse gas and Nitrogen Oxide emissions for new medium and heavy duty trucks beginning with Model Year 2027, but the rule is extremely weak. It would reduce GHG emissions by less than 1%, when ZEV technology is commercially available to do much more. ECA and its allies are calling on EPA to withdraw the rule and start over with new standards requiring that most of these vehicles achieve zero emissions as quickly as possible. Setting a zero emission standard for short-haul vehicles like transit and school buses, garbage trucks, airport shuttle vans, local cargo trucks, and USPS and other local delivery vans could avoid over 1 billion metric tons of GHG by 2050. If EPA adopts this weak rule, the law prohibits setting a stricter standard for 3 years, so these emissions will be locked in for the 20-year useful life of all the 2027-2029 vehicles sold. So this is urgent; we must not miss this chance to persuade the EPA to do better. Send a comment to the EPA by May 13, by copying the message below and pasting it here.Your message will be most effective if you add some personal details.
Feel free to cut and paste the message below here. We encourage you to customize your message. https://www.regulations.gov/commenton/EPA-HQ-OAR-2019-0055-0983
Subject: EPA-HQ-OAR-2019-0055 Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine and Vehicle Standards
This proposed rule is extremely weak, and I urge EPA to withdraw it and propose a zero emission standard for all HDVs for which zero emissions power trains are now commercially available, beginning with model year 2027.
The current proposal would reduce CO2 emissions by less than 1% as compared to the existing rule, allowing the 2027 HDVs to emit an estimated 28,088,000 metric tons of CO2 annually, and 1.78 billion metric tons over their 20-year useful life.
Many HD vehicle types are NOW available with zero emission technology. By setting a zero emission standard for the vehicles now available as ZEVs, EPA can reduce by about 2/3 the total GHG emissions from these vehicle types, avoiding about 1.25 billion metric tons between now and 2050. This is the equivalent of shutting down five large coal-fired power plants.
The most recent IPCC report has told us that the climate crisis is accelerating, and we are out of time to take action. We must not forego these easily-achievable reductions. We must have a zero emission standard now.