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TSTC Testimony: Virtual Public Hearing for California’s Advanced Clean Fleets Waiver and Authorization Request

Thank you for the opportunity to testify. My name is Jaqi Cohen, and I am the Director of Climate and Equity Policy at the Tri-State Transportation Campaign, representing the interests of New York, New Jersey, and Connecticut. I am testifying to request EPA to grant CARB’s waiver request without delay, allowing states to begin implementation of the Advanced Clean Fleets (ACF) regulation.

We are deeply concerned about the adverse effects of diesel pollution on public health, especially in disproportionately impacted low-income communities and communities of color. Families living near ports, rail yards, and warehouses suffer daily from the harmful emissions of heavy-duty trucks. The ACF rule presents a critical opportunity to alleviate these burdens and significantly improve air quality in these vulnerable areas.

Granting California’s waiver request to enact will provide the necessary regulatory certainty for states to move forward with adopting and implementing the ACF rule. This certainty is crucial for planning and investment in zero-emission technologies, ensuring a smooth and effective
transition.

The need to reduce emissions from Medium- and Heavy-Duty vehicles (MHVs) across the states we represent is urgent. In New York, MHVs are responsible for 24% of all on-road greenhouse gas emissions, despite making up only 5% of the state’s registered vehicles. A similar story exists in New Jersey, where a fifth of all on-road tailpipe emissions stem from MHVs. In Connecticut, MHVs account for a quarter of the state’s transportation emissions. In all three states, the transportation sector is responsible for the largest share of each state’s overall greenhouse gas emissions. (1)

The ACF rule, in conjunction with the Advanced Clean Trucks (ACT) standards, ensures that more zero-emission heavy-duty vehicles will be available on the market, gradually phasing in the use of zero-emission vehicles by 2036. This transition is vital for states like New York, New Jersey, and Connecticut, which have not yet enacted the ACF rule but stand to benefit enormously from its implementation.

Implementing the ACF rule will significantly reduce diesel emissions, leading to improved health outcomes and fewer hospitalizations. Diesel emissions from heavy-duty trucks are a leading source of air pollution, contributing to respiratory and cardiovascular diseases, increased cancer risks, and premature mortality. In California alone, the ACF rule is expected to save around 2,500 lives by 2050 and deliver roughly $26.5 billion in health savings.

The ACF standard is a transformative regulation that will protect public health, improve air quality, and combat climate change. I urge the EPA to grant California’s waiver request without delay, allowing states like New York and New Jersey to adopt and implement these crucial standards. The time to act is now, and the benefits of doing so will be profound and far-reaching.

Thank you for your consideration and commitment to protecting our environment and public health.




(1) Connecticut Department of Energy and Environmental Protection. “CT Proposed Emissions Standards for Cars and Trucks.” Accessed August 7, 2024.
https://portal.ct.gov/deep/air/mobile-sources/ct-proposed-emissions-standards-for-cars-and-trucks#:~:text=Medium%20and%20heavy%2Dduty%20vehicles%20are%20responsible%20for%2025%25%20of,middle%20of%20the%20next%20decade

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