With over 250,000 vehicles in service, the United States Postal Service (USPS) has one the world’s largest truck fleets. Over the past several years, the USPS worked to plan the replacement of its aging delivery truck fleet with a mix of both electric and combustion vehicles. If electric delivery vehicle deployment is maximized, this transition could have significant positive impacts on both air quality and the larger adoption of commercial electric vehicles.

I’ve blogged in detail about this effort, focusing mainly on the severe analytical shortcomings in the Postal Service’s 2021 study of air quality, climate, economic, and technological aspects of the new fleet of vehicles, known as the Environmental Impact Statement (EIS). Quite a bit has happened since the EIS was published and, thanks in part to our strong advocacy on the issue, a handful of lawsuits, and significant funding through the Inflation Reduction Act, the Postal Service announced it would increase the share of zero-emission vehicles (ZEVs) in their new delivery fleet from 10 percent to 62 percent. A few weeks back, the Postal Service released an updated analysis supporting this increase, called the Draft Supplementary Environmental Impact Statement (SEIS), which examines the environmental and economic impacts of several potential fleet replacement strategies.

From a high level, the updated plan seems significantly improved: the percentage of ZEVs in the fleet has increased substantially, they’ve signaled that they plan to focus the deployment of ZEVs in communities experiencing environmental injustices, and they’ve committed to purchasing only ZEVs after 2026. This is all great news.

However, there are still several unaddressed flaws in their analysis that lead to undervalued benefits and overinflated costs of fleet electrification. If properly addressed, a more accurate analysis would likely show clear evidence for a plan that maximizes ZEV deployment within the fleet given the massive lifetime cost savings of ZEVs and the fact that, according to the USPS, 90 percent of routes could be served by electric delivery vehicles. A USPS fleet that maximizes electrification potential would not only help to reduce climate warming and air pollution but would help to make electric vehicles more commonplace in every community across the nation.

Still room for improving the analysis

I’ve tracked the Postal Service’s fleet replacement efforts for some time now and am consistently alarmed by the poor quality of their analysis and data inputs. One of the highlights of my year so far was reading a report published by the Postal Inspector General (somewhat akin to an independent auditor for the Postal Service) that stated they had serious concerns, “related to the evaluation of reasonable alternatives, total-cost of ownership cost inputs, and environmental emissions that the Postal Service should address as it prepares its SEIS.” How’s that for an affirmation?

It’s a hopeful sign to see a significant increase in the number of ZEVs the USPS plans to deploy, but there are still major flaws in the design, methods, and data inputs of their analysis in the SEIS. That said, I believe they could be easily addressed. Here are several key ways.

The need to include a maximum feasible electrification alternative

Environmental Impact Statements, including this draft SEIS, are built around analyzing different options, courses of action, or choices that governmental entities are considering to meet the purpose and need of proposed actions.

These options, referred to as “alternatives” in an EIS, should reflect the most likely, reasonable, and feasible potential courses of action. The objective of any EIS should be to provide an accurate and rigorous look at potential outcomes, but cherry-picking alternatives that fit or omitting feasible alternatives that do not fit an agency’s agenda can result in a biased analysis.

Unlike the original EIS, the SEIS did include at least one feasible alternative, but it still did not analyze an alternative including the maximum technically feasible ZEV deployment. The Postal Service noted in the SEIS that around 90 percent of all routes could be serviced by electric vehicles but did not analyze the costs and benefits of a 90 percent ZEV fleet. This major omission is disappointing as it potentially leaves additional fiscal and environmental benefits on the table, compared to their “preferred alternative” of a 62 percent ZEV fleet.

In the SEIS, the Postal Services suggests several reasons for not choosing a 100 percent electrification alternative that makes good sense, however, they do not make a reasonable case for not analyzing a 90 percent ZEV fleet and should include such an analysis in their final SEIS. While I do think it’s technically reasonable that, in the near term, some gasoline delivery vehicles may be needed for niche routes and situations, the Postal Service should be diligently pursuing electrification wherever feasible.

The importance of lifetime cost analysis

The angle at which the Postal Service chose to examine the potential economic costs and benefits of fleet electrification significantly limited their results. Where most economic studies of vehicle and fleet electrification look at costs over the life of the vehicle, the SEIS only looked at upfront costs. This cut out the meaningful lifetime fuel and maintenance savings that ZEVs provide, while inflating the total ZEV fleet cost estimate, given that electric vehicles tend to have higher sticker prices than their combustion counterparts.

Their original analysis did consider total costs but included ridiculous assumptions like, for example, that gasoline would cost around $2.50 per gallon in 2040. Instead of following the Inspector General’s suggestions to improve the cost inputs in the total-cost of ownership analysis and the U.S. Government Accountability Office’s suggestions to improve the credibility of its cost estimates, they cut it altogether. The Postal Service has often stated cost as a barrier to further electrification, but if they aren’t looking at the lifetime fleet costs and ignoring the significant cost and maintenance savings of battery-electric vehicles (BEVs), how can they make informed decisions related to cost?

The Postal Service claims that the electric delivery vehicles they are considering cost approximately 40 percent more than the combustion versions, however leaving it at this is simply unreasonable – they should be taking a long-term holistic look when considering updating a fleet that could be on the road for several decades. The overwhelming body of research is clear that electric delivery vans are approaching upfront price and total cost parity at rates much faster than other truck types. In fact, a January 2022 study by the International Council on Clean Transportation suggests that electric delivery vans with a 100-mile range have already reached total cost parity.

Appropriate infrastructure cost estimates

There are several other incorrect assumptions within the analysis that undervalue the benefits and overinflate the costs of BEVs. One that is particularly meaningful is the Postal Service’s assumption that each electric NDGV would need its own dedicated charger. In reality, it is highly unlikely that a ratio of 1-to-1 would be necessary. Each of the battery-electric models under consideration will have a minimum operational range of 70 miles, of which a Level 2 charger can provide a full charge to around 8 hours, and only two percent of postal routes exceed 70 miles (according to a 2022 report by the Inspector General). Why then are so many costly chargers necessary?

Sure, there will be select cases of longer routes and areas with range-impacting weather that could need a higher ratio of chargers, but the new fleet could reliably operate on both fewer chargers as well as a mix of charging options. The same Inspector General study I referenced above suggested that the Postal Service consider a mix of Level 2 and less costly Level 1 chargers. This would reduce the average cost of chargers in the fleet by around 40 percent.

Clearly, there are more options to consider when it comes to charging the fleet. Estimating that each vehicle will need a dedicated charger is an unrealistic assumption that falsely inflates the cost of BEVs, limiting the potential benefits from their increased deployment.

Each of these examples hearkens back to some of my biggest complaints with the original EIS – that they were using the study to support foregone conclusions, rather than doing real analysis to better understand their fleet replacement plan. Good, lasting, and meaningful public policy is based on – you guessed it – objective and transparent science. Decisions of policymakers and agency decision-makers must be driven by rigorous analysis.

A more realistic look at environmental justice

One notable improvement in the SEIS was the realization that this plan would, in fact, affect disproportionately impacted (DI) communities. In its original study, the Postal Service simply stated, “there would be no or negligible impacts on environmental justice.” However, the science is clear that certain neighborhoods, all too often majority communities of color, experience exposure to air pollution and resulting negative health outcomes at rates much greater than others. Given the Postal Service’s massive nationwide fleet, any plan to transition to more modern and cleaner delivery vehicles would most certainly impact these communities. Our goal here is to make sure that the most impacted communities see a fair share of the fleet electrification benefits, including air quality and infrastructure improvements.

Where the old EIS wrote off any potential impacts – good or bad – the updated SEIS includes an in-depth analysis of the locations best suited for ZEV deployment using several well-vetted tools including the Environmental Protection Agency’s EJSCREEN. The analysis examined several factors including historic economic and environmental issues, the amount of current pollution burden, and levels of economic, climate, and health risks. While environmental justice was not a factor in determining where BEVs would be deployed, it turns out that the locations best suited for electrification from an infrastructure and use case point of view are most often located in DI communities – around 85 percent in fact. This is because those sites were located in more urbanized and industrialized areas where charging infrastructure may be easier to develop.

CleanAirNow, a Kansas City-based environmental justice leader that organizes efforts around electrification, air quality, and equitable labor transitions to clean energy, has been quite instrumental in not only pushing for expanded USPS electrification but for the new electric delivery vehicles to be deployed first in communities most impacted by unhealthy air quality. In a recent conversation with Beto Martinez, the executive director of CleanAirNow, he reiterated the need to center environmental justice and the health of those most impacted. He noted that the areas the organization represents are, “high-risk zip codes where asthma, heart disease, and cancer are above the national average, which links back to environmental health hazards” from long-term exposure to breathing toxic emissions from transportation.

I would agree with Beto that, “we don’t want pollution to be delivered with our mail” and that the Postal Service should commit to an accelerated deployment of zero-emission delivery vehicles in areas of persistent air pollution and poverty.

Benefits and co-benefits of ZEV deployment

The potential to concentrate electric delivery vehicle deployment in DI communities is great news for several reasons. First and most obviously, replacing 30-plus-year-old delivery vehicles predominately with ZEVs will help to reduce air pollution in these areas. Second, and perhaps equally important in the long run, is that any significant fleet deployment of electric delivery vehicles in a concentrated area will help to jumpstart the grid and infrastructure work needed to usher in further ZEV deployment. That is to say that the Postal Service’s plan to transition to a zero-emission fleet can be a catalyst for the larger transition for delivery and commercial fleets. Furthermore, the energy grid and infrastructure upgrades ushered in by the Postal Service may create opportunities for co-benefits in DI communities, who are often among the last to see infrastructure modernizations.

As the Postal Service, or any other large fleet owner for that matter, transitions to ZEVs, working in close coordination with adjacent businesses and fleets could lead to efficiencies in permitting and usher in greater economies of scale for infrastructure construction. The current norm for electrifying fleets is to work one-on-one with power companies and grid owners when developing large-scale vehicle charging infrastructure, but imagine the potential to reduce developmental roadblocks if a more cooperative approach was taken.

The Postal Service states that the majority of facilities targeted for ZEV deployment will receive over 100 vehicles and that these facilities are often located in dense urban or industrialized areas. What if they could work together with neighboring fleets to ready their sites for a zero-emission freight future? To my knowledge, this has yet to be studied in detail, but I have a hunch that it could accelerate deployment through increased efficiencies and perhaps also allow co-benefits beyond air quality to the surrounding communities.

Lasting and Catalyzing Impacts

USPS trucks are one of the most visible and familiar vehicles in any community. Electrifying the USPS fleet will have immediate benefits across the country from reduced climate-warming emissions and air pollution, and that’s reason enough to make the switch. But transitioning the USPS’ substantial fleet to electric will have long-term benefits, too: it will make electric vehicles and the infrastructure that supports them more familiar and more embedded in the lives of everyone who gets mail delivered, spurring a bigger market, and helping speed ZEV adoption towards a more sustainable and equitable freight system. Just as the Postal Service was instrumental in expanding the commercialization of airplanes in the early 1900s, so too can it be a driver of freight electrification. What’s more, maximizing the potential co-benefits of this transition could serve as a catalyst for the larger transition to ZEVs. It’s feasible today, and it will help build the foundation for a cleaner transportation future.

We are at the height of Danger Season, the time of year when extreme weather events driven by climate change are most prevalent across North America. The power sector is the second highest source of climate pollution in the U.S. thus, it is crucial that we address carbon emissions from power plants.

The Environmental Protection Agency (EPA) recently published a proposed rule which would limit carbon pollution from fossil fuel burning power plants, a move which is critically important, statutorily required, and long overdue.

Dr. Marc Futernick, an emergency physician in Los Angeles and steering committee chairman at the Medical Society Consortium on Climate and Health, spoke with me about how the rule would impact public health and how as a medical professional he participates in the public process to help influence these standards.  

BRADY WATSON: How does the power sector impact public health?

DR. MARC FUTERNICK: It’s all connected to fossil fuels. Burning gas and coal leads to carbon dioxide emissions and air pollutants. Carbon dioxide is the main cause of global warming overall. Air pollutants contribute to all of the leading causes of death, such as heart disease, strokes, cancer, and respiratory illness. Now we have increasing evidence air pollution contributes to dementia as well. So, all the fossil fuel burning power plants on the grid have a direct public health impact as well.

BRADY WATSON: What do public health professionals have to do with power plants?

DR. MARC FUTERNICK: Because public health professionals care about the health of entire communities, anything is fair game. For example, something that was not directly medical but relevant to the greater community was mandatory seat belt laws. They were championed by public health officials decades ago. Similarly, air pollution is having enormous negative impacts on our health right now, and because a significant amount of that pollution comes from power plants, as a public health professional it is important to me to be aware of what is happening in the energy sector. Many public health and other medical agencies have clearly declared climate change as the number one health threat in humanity’s immediate future, and because power plants burning fossil fuels are one of the leading contributors to climate change in the U.S., I care greatly about this subject.

BRADY WATSON: Sometimes the EPA is thought of as focused on the environment, but protecting human health is actually a core part of its mission. Does the EPA listen to public health professionals? How do they incorporate consideration of public health impacts?

DR. MARC FUTERNICK: EPA listens to all input, including that from public health advocates, subject matter experts, and industry lobbyists—plus the general public. It is a difficult job finding the right balance among all these interests. Public health professionals like myself believe air pollution and greenhouse gas emissions regulations should be as strong as technically and economically feasible, and to that end there is still lots of room for improvement. Because of the significant public health impacts posed by the power sector, the EPA has specifically mentioned the public health sector as an interest group whose comments will be strongly considered as the rule is finalized.

BRADY WATSON: How could this proposed climate rule potentially impact public health in both the short and long term?

DR. MARC FUTERNICK: There are multiple studies that show current air pollution levels are causing between 7 and 10 million deaths worldwide, every year, plus all the non-lethal disease burden impacting people. This proposed climate rule would decrease toxic emissions from power plants, particularly in our densest cities, and that would have tremendous health benefits immediately. For instance, in California, a study of pregnant women in the vicinity of power plants demonstrated that closing those plants led to a significant decrease in pre-term birth in the local area. A rule like this impacts entire lives, starting at birth.

BRADY WATSON: There is a lot of discussion about the potential of hydrogen power and carbon capture and storage as alternatives to fossil fuels. From your perspective as a public health professional, what should we keep in mind?

DR. MARC FUTERNICK: This is a situation where the devil is in the details. CCS can theoretically be done so the energy used to perform CCS is renewable, the process achieves the carbon capture goal, and health-harming pollutants at the site and upstream are limited. The next question is whether that type of CCS can be done economically and at scale in the near future. If this can be achieved, CCS will be a valuable component of our battle to curb climate change. However, this ideal form of CCS has not emerged, so it’s important that we focus primarily on renewable energy that we know is affordable and effective, right now.

Hydrogen has many of the same question marks related to how it is produced and if it can be economically scaled. Once again, renewable energy, which is available at scale now, is the way to go.

BRADY WATSON: Because of the high stakes for public health that you’ve outlined, it’s clear public health professionals should care about this rule. How can public health experts like you, or community members who care about public health engage in this rulemaking process?

DR. MARC FUTERNICK: To be successful in this fight to curb carbon emissions and reduce the worst impacts of climate change, we need all hands on deck. Every resident and organization is able to provide public comments to the EPA on this and other regulations. Our elected and appointed officials need to know that the public wants to clean up our air and protect our future. We can show this by flooding the EPA with our comments, being more vocal in more settings, and setting a very clear path forward with specific recommendations.

For instance, my input to EPA on the power plant rule focused on including even more power plants because as the proposed rule is currently written, many are excluded. I also told the EPA in my comments they should add more interim goals that must be met over the years so that pollution and emissions decrease promptly.

You can take action

The public comment period for this particular rule is now closed. However, UCS supporters can follow future public comment opportunities at regulations.gov and follow our action page for more ways to get involved.

Extreme heat has hit hard lately from coast to coast and beyond, and it’s a major way Danger Season has shown up this year. Even as I write this, communities from the Northwest to the Southwest to the Southeast and Puerto Rico are under heat alerts.

The direct health impact of heat stress is bad enough, and dangerous. But extreme heat also hits our electricity system in ways that make it more expensive, more polluting, and less reliable. Here’s how.

Extreme heat means more expensive electricity

Extreme heat can sharply increase electricity consumption as people turn up their air conditioners for relief. For example, the Electric Reliability Council of Texas, the electricity grid serving much of the Lone Star State, has already set new records for power demand 11 times this sweltering summer.

As demand rises, grid operators turn for extra capacity to power plants that they don’t use frequently. They use—or “dispatch”—plants based on their operating costs, starting with the cheapest sources first, as this UCS video explains:

This approach means demand is met first by resources that don’t require fuel—particularly solar and wind—or have low fuel costs—nuclear. Combined-cycle gas plants typically come next. If even more capacity is needed, at the higher or later end of the curve are such supply options as coal plants, simple-cycle gas “peaker” plants, or even oil-fired ones (even though that fuel fell out of favor in the power sector decades ago). Using more of these more expensive sources means higher wholesale electricity costs, which translates to higher retail rates for customers.

Extreme heat means dirtier electricity

Going further up the dispatch curve drives up not only costs, but also pollution. One factor is the dirtiness of fossil fuels. Coal, oil, and gas are major sources of a variety of pollutants that threaten public health and the environment.  

Resources at the higher end of the cost-dispatch curve also tend to be less efficient. Even plants with the same fuel might use it differently. A combined-cycle gas plant might have an efficiency of 60 percent, while a gas peaker plant might be 20- to 35-percent efficient—that is, waste as much as 80 percent of the energy in its fuel. The average US coal plant is only about 33-percent efficient. For a given kilowatt-hour of electricity, lower efficiency means more fuel, which means more pollution.

So the extra power demand that often comes with extreme heat doesn’t just make electricity more expensive, it also makes it a lot dirtier.

Extreme heat means less reliable electricity

You might think that having extreme heat hit us in our pocketbooks and our lungs would be enough damage, but there’s more: Higher heat also can make our electricity less reliable.

One reason for that extra unreliability is that high power demand. When skyrocketing heat leads to skyrocketing demand, grid operators eventually run out of working power plants to turn to. And, while blackouts can have various causes, something has to give when demand outstrips available supply.

Extreme heat also exacts a toll on power plants directly, potentially exacerbating that supply shortage, and hits other parts of the grid. Many types of power plants become less efficient at higher temperatures. A gas turbine rated at 60 degrees F might be able to generate only 85 percent of that capacity when ambient temperatures reach 100 degrees F, for example. Many power plants that make steam to generate electricity, including nuclear and coal plants, most gas plants, and a small number of renewable energy plants, also take a hit when their cooling water temperatures climb. In addition, wildfires intensified by extreme heat can destroy transmission lines and other parts of the electricity grid.

That’s the supply part. But keeping our lights—and air-conditioners and cooling fans—running also requires delivering power from the plants to our homes and businesses, and high heat hits there too. Transmission lines’ ability to carry electricity drops as temperatures increase, and lines sag more at higher temperatures, potentially leading to short circuits. Transformers, meanwhile, can overheat and fail.

What we can do

Extra burdens from extreme heat that come via the power sector are serious, but there are serious responses we can bring to bear.

One important step is to recognize that the impact of extreme heat via the power sector doesn’t hit everyone equally, or equitably. Energy burdens are on average heavier for Black, Hispanic, and Native American households, for example. Peaker plants are located disproportionately in or near low-income communities and communities of color. And power outages hit some families much harder than others.

Given these inequities in the US power system, one important, near-term answer is making sure that we have and use systems that protect those most at risk. That means, for instance, having options not just for people who don’t have home access to air conditioning when it’s needed most, but also for those who can’t afford the extra electricity costs that the heat brings. Cooling centers and utility bill assistance, for example, can be lifesaving.

Grid operators have a range of tools they can use, in both the near and long term, to address extreme heat’s power sector impacts, and other energy sector decisionmakers can help make those tools more of a reality. Incentives and technologies can encourage and help customers shift demand to off-peak times, and investments in energy efficiency can help reduce demand overall, including during peaks. Energy storage, such as well-sited batteries—charged with clean electricity when demand is lower—can provide additional supply when demand escalates. Meanwhile, stronger transmission connections to other parts of the country, done right, can allow an area getting hit hard by extreme heat to draw on extra resources elsewhere in ways that reduce costs and pollution burdens.

Another key tool is renewable energy, at a range of scales, and recent experience has definitely shown the value of more wind, solar, and other renewables, as in Texas (repeatedly). Deploying more renewables—and having adequate transmission capacity for them—can shift the more expensive, dirtier power plant options farther to the right in dispatch curves and avoid or delay their use. Rooftop solar and other distributed renewables can reduce pressure on the electricity grid by supplying power where it’s needed. When paired with on-site energy storage, these resources can also help address transmission constraints, provide critical backup power in key locations in communities, and even do away with peaker plants. And using zero-carbon resources instead of fossil fuels can, over the long term, slow the climate change driving so much of the extreme heat.

Extreme heat can hit us hard through the power sector, hitting our finances, our health, and the reliability of that power, and it can hit some much harder than others. For the sake of everyone, we can hit back.

The UN’s Climate Change Conference is just about to kick off in Dubai, juxtaposing the powerful political power of the fossil fuel industry and the desperate need to reduce oil and gas usage as we face an ongoing climate crisis. With the petroleum-dominated transportation sector the leading source of heat-trapping emissions in the United States, it’s a great opportunity to look at the Biden administration’s progress on cleaning up passenger cars and trucks and what we should look for in the coming year.

This year, the Environmental Protection Agency (EPA) and National Highway Traffic Safety Administration (NHTSA) proposed new emissions and fuel economy standards (respectively) for model year 2027-2032 passenger cars and light trucks (sedans, utility vehicles, pickups, etc.). We expect those rules to be finalized early next year, and automakers have been pushing the agency to weaken its proposals.

The gap between industry’s asks and what is needed to address climate change is staggering:

Recent analysis shows that the additional emissions associated with finalizing a weaker proposal on passenger cars would be even greater than the entire reductions expected from EPA’s recent proposal to address power plant emissions.

Below I walk through who’s asking for what, and what’s at stake.

These rules must accelerate the ongoing transition towards electrification

As my colleague recently wrote, this year has seen a continued rise in sales of electric vehicles, on pace for over a million fully electric vehicles sold this year in the US, indicating the transition to electrify the passenger car market is well underway. Nowhere is this clearer than in the state of California, where EVs now make up one in four new vehicles sold, but California is not alone: Florida, Texas, New York, and other major markets are also accelerating

State policies have helped start the EV revolution, but we need the federal government involved to accelerate that transition nationwide and put us on track to meaningfully address climate change, which means electrifying all new light-duty vehicle sales by 2035. But it is precisely this pace of change that has the auto industry pushing back hard on EPA’s proposed rules.

EPA considering a range of alternatives

EPA proposed standards that would aim to reduce greenhouse gas tailpipe emissions by about 70 percent compared to today’s vehicles (or about a 60 percent reduction from the 2026 standards currently on the books), to a lab certification level of emissions of 82 grams per mile (g/mi) by 2032. One key part of the rule is closing a loophole for off-cycle credits that has eroded the stringency of the current standards over time.

In addition to their proposal, the agency considered three alternatives: one which is 10 g/mi ­more stringent (Alt 1), one which is 10 g/mi less stringent (Alt 2), and one which arrives at the same end point (82 g/mi) but does so more slowly than proposed (Alt 3), increasing the emissions impact compared to the proposal.

The Union of Concerned Scientists, as well as a number of other non-governmental organizations (NGOs) including consumer, environmental, faith, and environmental justice/community-based organizations, asked EPA to move even more aggressively than Alt 1—while the proposal moves forward with action commensurate to address heat-trapping emissions through 2030, it eases up on the pace of improvement and falls short of the trajectory needed to electrify new vehicles sales by 2035. Therefore, we pushed EPA not to ease up after 2030 as it has, with what we’ve called Alt 1+.

Unsurprisingly, automakers advocated for weakening the proposed greenhouse gas standards—Ford asked for Alt 3, while other automakers pushed for a combination of the slower pace of Alt 3 and a weakened stringency like Alt 2. Across the board manufacturers advocated for additional loopholes that would further erode the benefits of any standard.

Automakers have also pushed for weakening the newly proposed tailpipe emissions standards for particulate matter (PM) included in EPA’s “multi-pollutant” rule. These proposed PM standards represent an important step to address public health by cleaning up gasoline-powered vehicles as we make the transition to EVs by requiring gasoline particulate filters, which are already ubiquitous in Europe and China. However, automakers are pushing to weaken the stringency and test requirements of the proposal sufficiently such that this common-sense emissions-reducing technology remains on the shelf in the U.S.

EPA’s proposal underestimates what is possible

A lot of the press coverage of EPA’s proposal presented the agency’s analysis as though it were a guarantee of the future, but one of the key reasons UCS is pushing for Alt 1+ is because EPA has underestimated what is achievable in this time frame. Most notably, EPA understated the gains that can be made from gasoline-powered vehicles. In fact, EPA’s analysis assumes that a large share of gasoline-powered vehicles emit more heat-trapping emissions over time.

If we simply make the reasonable assumption that automakers aren’t going to make cars worse over time, that alone is enough to justify the agency’s stronger Alt 1 standard. But automakers can do even better than that because EPA’s modeling shortchanged the combustion engine technologies available today, meaning that not only have they mischaracterized how the technologies will be deployed, but they’ve underestimated the emissions reductions deployment would bring.

These shortcomings mean that automakers could do much more with their gasoline-powered fleet than EPA supposes, so if EPA doesn’t strengthen its rule, we will see far fewer EVs on the road than the modeling accompanying their proposal suggests. Manufacturers are setting EV sales records and planning the investments needed for an electric future, but we’ve also seen them willing to continue to kick the can down the road for short-term profit—that must end now.

Climate action requires more than what industry would prefer

As EPA looks to finalize its next regulation, it’s important to understand what’s at stake. Aggressive action is needed to address climate change and transportation pollution, and every new batch of regulations results brings the same ol’ song and dance from opposing automakers. The impact of heeding their objections rather than moving forward with what is feasible and necessary would be a serious step back in climate action.

Analysis by consulting firm ERM shows that through 2040, the UCS/NGO alternative (Alt 1+) would cut heat-trapping emissions by an additional 31 percent compared to EPA’s proposal. On the other hand, Alt 3 would increase emissions by 11 percent compared to the proposal. Since Alt 3 is stronger than what automakers have asked for, which includes additional loopholes not part of Alt 3, this means the analysis actually underestimates the gap between the two positions. And that gap results in some significant impacts.

In total, the difference between Alt 1+ and Alt 3 amounts to 645 million metric tons of heat-trapping emissions through 2040. To put that in perspective, this is greater than ALL of the reductions from the recently proposed power plant rule through 2042 (617 million metric tons).

These rules are about more than just the climate

Because these rules also include new standards for smog-forming emissions (nitrogen oxides [NO_x] and volatile organic compounds [VOCs]) as well as the emissions of soot, or particulate matter (PM), EPA’s new rules are about more than just the climate. While EPA did not consider additional alternatives in its NO_x+VOC or PM standards, UCS and others pushed for stronger NO_x+VOC standards that would reflect what is feasible both from increasing electrification and cleaner gasoline-powered vehicles.

Thanks to increased stringency, modeling projects that by 2040 there would be an additional 18 million EVs on the road if Alt 1+ were finalized instead of Alt 3. Combined with the increase in stringency to the tailpipe emissions standards for NO_x+VOC, this would reduce premature mortality from passenger cars and trucks by an additional 26 percent over the 2026-2040 time period, saving hundreds more lives and reducing trips to the ER and missed days from work and school.

These EVs result in significant net savings for drivers as well. In 2040, even including relevant technology and charger costs, Alt 1+ would save drivers $86 billion—that’s $24 billion more than Alt 3. Combined with improved air quality and the climate, Alt 1+ stands to generate $887 billion in social benefits through 2040, a sizeable increase from both the proposal ($679 billion) and Alt 3 ($628 billion).

EPA must side with the public rather than industry

The auto industry doesn’t care about emissions or public health—they care about selling cars. Reining in the harms of our car-centric transportation system is the responsibility of policymakers, including the regulators at EPA now facing a choice as they look to finalize the next phase of emissions standards for passenger cars and trucks.

This choice is clear: to the extent that we continue to rely upon privately owned vehicles, we need to eliminate their tailpipe emissions as we simultaneously reduce emissions from the electric grid powering those vehicles. Automakers want to continue to slow that progress.

The cost of listening to the auto industry instead of doing what is both feasible and necessary to protect public health and the environment would equate to wiping out the entire benefit of a major rulemaking governing heat-trapping emissions from new power plants. We cannot afford such harm in the middle of a climate crisis.

EPA’s proposal was a good step, but the facts support going stronger. EPA must finalize a rule that meets the moment—now is the time for decisive action.

With the holidays fast approaching, I sat down the other night to finish the list of gift ideas for the folks who’ve made my nice list. As I worked my way through family and friends, attempting to strategically formulate gift ideas within my budget, my mind drifted from the task at hand (as it often does) to ways I could reduce the environmental impacts of my holiday shopping and shipping decisions.

The holidays are the peak shopping time for US consumers. According to the National Retail Federation, around 20 percent of shopping occurs during November and December. Holiday shopping has grown consistently over the past decade at around 3.5 percent annually on average – outpacing population growth in the US by nearly 5 times.

Production of the gift itself and packaging contribute to pollution, however, I wanted to better understand this “last-mile” delivery impact. Would the footprint of my choices be greater if I shopped online versus driving to a local store? How would that change if I hopped on the electric bus route at the end of my block?

The answers to these questions are quite nuanced and vary greatly depending on where we live, the mode of transportation that our items travel, and what we purchase. A 2021 meta-analysis of over 40 peer-reviewed studies on the subject concluded that “there is no particular type of shopping that has an absolute environmental advantage and it is in no way possible to shop ourselves out of the environmental crisis.”

While the latter part of this conclusion is obvious, the former part isn’t as much. For example, home deliveries in some areas may cut climate-warming emissions compared to driving in a personal vehicle to purchase items in person. But while greenhouse gas emissions may be reduced, a delivery fulfilled by a diesel-burning truck may lead to increases in emissions of smog-forming nitrogen oxides and lung-damaging particulate matter. That said, expedited deliveries are often shown to have the highest emissions among all package modes of transportation as delivery system efficiencies are diminished and packages may take a cross-country plane trip.

The share of online transactions among total US sales grew from just under six percent in 2013 to around 15 percent in 2021, according to the Census Bureau’s Annual Retail Trade Survey. While the rise in online shopping and shipping has led to the displacement of shopping trips in personal vehicles and increasingly efficient deliveries, the related increase in warehouses has created significant negative health impacts for adjacent communities. The situation would indeed be much better if our gifts were delivered by a team of flying reindeer fueled by magic and apples instead of trucks running on polluting diesel fuel.

Electric Trucks Deliver Climate and Health Benefits

One throughline that cuts through the nuance of the science on the subject is that electrifying both freight and last-mile delivery significantly decreases the climate and public health impacts of our holiday shopping. Upcoming research from my colleague Dave Cooke shows that electric delivery trucks can reduce climate-warming emissions from driving by up to 92 percent and reduce lifecycle public health impacts by up to 85 percent compared to today’s average fossil-fueled delivery trucks. Even when accounting for pollution from electricity generation, electric trucks can significantly reduce air pollution and get us on a better track to addressing climate change. (Feel free to share this and our analysis of passenger car pollution with your cranky in-laws at the dinner table who still think electric vehicles pollute more than fossil-fueled vehicles!)

While it’s true that today’s large batteries increase the amount of pollution created by building electric trucks and buses compared to traditional models, their cleaner operations mean that today’s electric trucks are far cleaner over their lifecycle than those that run on diesel or natural gas. However, battery production is projected to become cleaner, and as the electricity grid gets cleaner, so do electric vehicles (See Figure 4 of our Driving Cleaner report). A 2023 International Council on Clean Transportation study on cradle-to-grave pollution of trucks in Europe shows that, while today’s battery-electric trucks are responsible for around one-third of the climate-warming pollution of a diesel truck, by 2030 this will shrink to around one-fifth of the pollution. Some of the same researchers are currently working on a comparable study for the United States and their preliminary results are similar.

2023 Delivered Meaningful Progress Toward Electrification

Another piece of good news is that this year has seen several large leaps toward commercial truck electrification:

• Ten states, comprising over 20 percent of the national market for heavy-duty trucks, have now adopted regulations that require manufacturers to produce and sell an increasing percentage of zero-emission trucks and buses.
• The number of available electric truck models in the US and Canada has surpassed 180.
• Electric truck charging technologies have expanded and public heavy-duty charging stations are beginning to come online with many more planned for the near term.
• The Postal Service increased its commitment to zero-emission vehicles in the first round of new delivery vehicles from 10 to 62 percent and committed to only purchasing electric delivery vehicles after 2026.
• California became the first jurisdiction in the world to require the largest and most polluting businesses to begin transitioning their trucks to zero-emission vehicles in 2024.
• New York City passed a bill requiring their 30,000 city vehicles (the world’s largest municipal fleet) to fully switch to zero-emission by mid-2035.
• Companies like Pepsi have successfully deployed electric tractor trucks carrying payloads up to 82,000 lbs. on routes between 250 and 450 miles.

Despite these positive facts, there’s still much progress to be made and the federal government must do more to push towards nationwide truck electrification.

Even as progress towards cleaner freight continues to be made, we still cannot shop our way to a more stable climate and healthier air. The point here is not to be a climate Grinch coaxing everyone into foraging gifts at the local city park. Rather, I think it’s valuable during this time of reflection, celebration, friends, and family to better understand the impacts of our consumption choices so that we’re informed and empowered to push for positive change.

Happy Holidays everyone!

Last week, I interviewed a patient who was hospitalized for severe and persistent asthma attacks. Ms. S (a pseudonym to protect patient privacy) had been perfectly healthy until her respiratory symptoms commenced one year ago. She described her struggle to breathe on her worst days as feeling as though “an elephant was sitting on her chest.” I asked about smoking history and exposure to any potential indoor irritants such as dust or mold, all of which she denied. Perplexed, I then thought to ask her about environmental exposures. She noted that she moved to a new apartment around the time her symptoms began. Suspecting a connection, I inquired about the location of her apartment and traffic congestion in the area. Ms. S revealed that she did, in fact, live very close to a main highway, and, to keep active, she took daily walks in her neighborhood. Although it is impossible to conclude causation in her case, I was nevertheless struck by the potential relationship between tailpipe emissions and respiratory health.

In the exam room, all I can do is ensure she is receiving her proper medications. But as a future healthcare provider, I want to use my voice outside the exam room to prevent future cases of disease induced by toxic environmental exposures—which we have the power to change right now.

Vehicles emit 1.5 billion tons of greenhouse gases each year, resulting in the transportation sector being the largest contributor to greenhouse gas emissions across all sectors. Conventional cars, trucks and buses also emit fine particulate matter, volatile organic compounds, carbon monoxide, and sulfur dioxide, all of which are associated with respiratory irritation, infection, and chronic disease. There is plentiful evidence that these pollutants increase the risk of childhood asthma, non-asthma respiratory symptoms, impaired lung function, and cardiovascular morbidity and mortality. I see the direct impact that this cocktail of pollutants has on the increasing severity of respiratory conditions in patients, all while knowing that this same source of pollution is destroying the health of the planet.

But it doesn’t have to be this way. We can transform the way we get around, building a future that brings clean air and clear lungs with it.

Expanding access to public transportation has multiple benefits

One major, and sometimes overlooked, solution to reducing car pollution is already available to us: public transportation. Electrifying vehicles is still important. But choosing to ride a bus or train as opposed to a car yields substantial benefits for the individual, community, and environment. Research shows that riding just one mile by bus in this country, on average, contributes 30% less to climate change than riding alone in a gas car. What’s more, public transportation use leads to more daily physical activity, as commuters often walk or bike to transit stops. In this way, opting for public transportation has a co-benefit of decreasing risk of obesity, respiratory, and cardiovascular disease. Finally, increased access to public transportation has been shown to improve mental health outcomes in older adults, decreasing feelings of social isolation.

For my patients and community to fully realize these wide-ranging benefits, it is crucial that decisionmakers invest in public transit as a public good, opting to view it as a core climate solution and a form of preventative medicine for those who are at risk of respiratory illnesses sparked by pollutants from tailpipes. Transit service has been chronically underfunded—a vicious spiral that has partially led to the health and climate outcomes we see today.

The good news is that there are big opportunities right now to invest in transit systems. Billions of dollars in federal infrastructure funding are flowing down to states—which, with enough public input, can decide to invest in transportation options that work for our health and the climate’s health. What’s more, Congress is finally getting serious about the need to fund transit operations. In January 2024, Representative Hank Johnson introduced H.R. 7039, the Stronger Communities through Better Transit Act which, if passed, would authorize $20 billion to support transit operations every year for four years. The operations side of running a transit system is crucial, covering maintenance expenses, bus and train operators’ salaries, and funding increases in the frequency of service. In fact, over 70% of transit agency expenses are for operations, rather than capital investments (i.e. building a new train line). Analysis has shown that this bill could provide the investments necessary to bring nearly 100 million new hours of transit service across the country, across urban, suburban, and rural areas. One way to support this bill right now is to ask your representative to become a cosponsor.

Investing in reliable, accessible transit service is essential—not only to the 10 million US households who don’t own a vehicle, but also as the bedrock for thriving communities and a better quality of life for all. This service is essential in increasing access to health care, nutritious food, employment, and a social network. It is therefore crucial that local, state, and national decisionmakers invest in public transit infrastructure and operations. There is much room for improvement, and it is my hope, as a medical student and future physician, that a shift towards increased public transportation utilization starts now, in the name of human health and a healthier planet.

Last week, the US Environmental Protection Agency (EPA) finalized updated regulations for certain facilities that emit ethylene oxide (EtO), a colorless, cancer-causing gas. These long-awaited rules will require facilities using EtO to sterilize medical devices and some food products—known as commercial sterilizers—to significantly reduce their emissions of EtO, install additional control equipment, and improve monitoring.

Ethylene oxide is used in chemical manufacturing, as well as sterilization, due to its effectiveness at killing microbes. However, mounting evidence has shown its harms to both workers and community members. Short-term, elevated exposure by inhalation can cause respiratory irritation, nausea, blurred vision, and headaches, and long-term exposure increases people’s risk of developing certain types of cancer, including white blood cell cancers and breast cancer. Children are especially vulnerable to exposure because EtO is a mutagen, meaning it can damage a cell’s DNA, and children’s cells divide more rapidly than adults’ cells do. And its effects can be “invisible” to many, as these sterilization operations are often housed in nondescript warehouses near other businesses and residential areas where people are often unaware of what is being emitted in their community.

The new rule will offer a significant boon to public health. An analysis by the Union of Concerned Scientists (UCS) last year found that more than 13 million people live within five miles of commercial sterilization facilities, with 10,000 schools and childcare centers in these same areas. Our report revealed that sterilization facilities are disproportionately located near people of color and people who do not speak English as a first language. We also found that co-located sterilization facilities, facilities in communities with higher cancer risks, and facilities that have violated the Clean Air Act are disproportionately near people of color, illustrating the vast disparities of who this pollutant impacts most. You can find our report and interactive map here.

This rule stands to alleviate the burden of EtO exposure in these communities across the country. Let’s review what EPA did well and where the agency fell short in the final rule.

Sterilization facilities must reduce EtO emissions

The key victory in this rule is that EPA will now require a combination of control measures and emissions limits at sterilization facilities. For the first time, the government will regulate fugitive or “unintended” emissions and require permanent total enclosure of sterilization operations. According to EPA, these controls could reduce EtO emissions at sterilization facilities by 90 percent.

Notably, the EPA also updated its risk review to consider “allowable” rather than “actual” emissions—a change that the agency says it considered after comments made by UCS and our partners. This important development ensures that the risks are assessed based on the maximum amount a facility can emit, rather than what the facility self-reports. Since estimated cancer risks were greater when considering allowable emissions, EPA was able to finalize additional control measures from what was originally proposed to bring these risks down to an “acceptable” level. This is encouraging, as EPA was able to strengthen its risk review in the final rule, leading to even stronger standards.

Still,  EPA also notably weakened some provisions in the final rule compared to the draft, or elected not to adopt them, despite a push for them in many public comments, including the one submitted by UCS and our partners.

Compliance delayed

One notable area in which the final rule falls short is in its compliance deadlines. The proposal initially provided sterilization facilities 18 months to comply with the requirements in the final rule—which is already longer than the minimum time required under the Clean Air Act (CAA). Instead, in response to comments made by the sterilization industry, EPA significantly lengthened the compliance deadlines in the final rule. Depending on the size of the facility, sterilizers will now have two to three years, with possibility of a one-year extension for some.

This is extremely disappointing, as it means that communities may continue to be unnecessarily and unknowingly exposed to hazardous levels of EtO for even longer. It is also puzzling because EPA asserts that, “a number of the facilities covered by this final rule have already implemented one or more of the controls that will be needed for compliance,” therefore one might assume that achieving full compliance would not require so much additional time. Furthermore, the risks of EtO have been known for decades now and should not be a surprise to the industry. As I’ve previously reported, in 2005, when EPA last reviewed these standards, the agency considered banning the use of EtO for new sterilization facilities altogether, but ultimately did not adopt the proposal due to industry pushback.

Accountability measures weakened or not addressed in final rule

Grassroots advocates and residents of communities with sterilization facilities also asked for a number of provisions that EPA did not adopt. First, EPA acknowledged that many comments argued that these regulations should extend to off-site or stand-alone warehouses, where companies often store newly sterilized material that continues to “off-gas” or emit EtO. These concerns were related to warehouses such as one in Covington, Georgia that was found to be releasing such high levels of EtO, that it would have required an air quality permit. EPA ultimately decided not to extend coverage of these regulations to off-site warehouses, in large part because they, “do not have sufficient information to understand where these warehouses are located, who owns them, how they are operated, or what level of emissions potential they may have.” It is disconcerting whenever any federal agency states that a lack of data—particularly data they should require companies to submit—is a reason to shirk regulation. Furthermore, this loophole raises concerns of whether it could incentivize companies with on-site warehouses to simply move their storage off-site to evade regulatory oversight. EPA did state that it plans to gather information about off-site warehouses and potentially develop new regulations for these sites. We urge the agency to do so promptly to ensure that data on where these warehouses are located is made public and emissions are properly controlled.

Many commenters also called on EPA to require sterilization facilities to install fenceline air monitors near the facility property line to measure ambient air emissions to which adjacent communities might be exposed. EPA opted not to require fenceline monitoring in the final rule, which would have provided an additional layer of oversight to ensure that the controls were reducing community-level exposure. That being said, the agency did strengthen emissions monitoring and reporting requirements from control equipment, which should provide helpful data on compliance.

And finally, the EPA decided to scrap a proposal requiring certain sterilization facilities to obtain a Title V operating permit. Title V permits offer an additional level of accountability that also expands public participation in the permitting process. Overall, while the rule significantly strengthen emissions limits and control requirements, we are concerned that EPA also weakened or failed to adopt provisions that would ensure accountability and compliance with these regulations.

A long-awaited win, with more to go

These regulations represent a major win for public health and grassroots advocates across the country. But it is important to note that they are a decade overdue. Under the Clean Air Act, EPA is required to review and revise standards for “hazardous air pollutants” (including ethylene oxide), every eight years. Prior to last week, regulations for commercial sterilizers had not been reviewed in nearly two decades and had been due for review in 2014. This means that people were unnecessarily, unknowingly, and unlawfully exposed to ethylene oxide for years, with consequences that may not be known for years to come.

Still, we share our immense gratitude to community advocates at Rio Grande International Study Center, Memphis Community Against Pollution, Clean Power Lake County, and Stop Sterigenics, among many others, for tirelessly pushing EPA to do better. Our partners at Earthjustice also successfully brought a lawsuit that required EPA to strengthen these standards.

This is the second major rule EPA has finalized this month to reduce chemical exposure hazards in communities across the country. We encourage the agency to maintain this momentum to continue reviewing and updating rules for facilities that emit ethylene oxide, including hospital sterilizers, which have major implications for health care workers, and synthetic organic chemical manufacturing (HON) facilities, which are often concentrated in already overburdened communities.

All communities exposed to EtO and other hazardous air pollutants must be afforded protections from harmful emissions.

The Environmental Protection Agency (EPA) just finalized its Phase 3 greenhouse gas regulation as a part of the administration’s plan to decarbonize the transportation sector. The Phase 3 regulation will cut new greenhouse gas emissions from trucks in 2032 by 32 to 62 percent for vocational trucks (e.g., refuse, delivery vans, school and transit buses) and 9 to 40 percent for tractor-trailers, compared to the current 2024 standards. We could also see up to 623,000 electric trucks on the road in this time period, with zero-emission trucks making up over one third of all new truck sales by 2032, according to our analysis…but that number is highly dependent on manufacturer compliance strategy and complementary policies.

The Joint Office of Energy and Transportation recently released a strategy on infrastructure deployment to support a transition to zero-emission trucks, and a number of states are accelerating that transition with sales requirements that ensure increasing share of zero-emission trucks are sold in the state. However, EPA’s final rule fails to capitalize on this momentum, and the path to a zero-emission freight sector remains uncertain. And EPA still hasn’t provided a waiver to California for its Advanced Clean Fleets program, creating uncertainty even in the states that have stepped up in absence of federal action.

To get the transition to zero-emission freight back on track, the Biden administration should develop a comprehensive strategy towards a zero-emission freight sector, including but not limited to eliminating emissions from heavy-duty vehicles. Such a plan should be directly informed by those most harmed to ensure that these rules do not leave behind communities already facing the disproportionate burden of a fossil-fueled freight sector.

EPA’s rule got worse…and better…and worse…since last year’s proposal

Since EPA’s spring proposal last year, there have been a number of changes made. Unfortunately, it is a mix of impacts that are likely, on net, to result in increased diesel truck deployment (and the commensurate harm from their tailpipe emissions) relative to the original proposal.

Across all vehicle classes, EPA has reduced the pace of improvement in the early years of the program. While targets increased in 2032 for some vehicle classes, the vehicles sold under this program will emit more greenhouse gas emissions as a result.

For the heaviest classes of vehicles, the rule’s stringency has been greatly diminished. This will likely set back the electrification of tractor-trailers and create increased uncertainty around the investments needed to electrify our freight corridors.

Increased flexibilities are a critical problem with the rule. EPA extended multipliers for electric trucks by a year (e.g., one battery-electric truck sold counts towards the regulation as 4.5 battery-electric trucks), even though manufacturers are already required to sell those trucks in states that have adopted the Advanced Clean Trucks rule. Worse, EPA now allows for credit trading between vehicle classes, which means these windfall credits will be used to offset what little improvements are required in the earliest years of the program.

One critical piece of the final rule that did not change is the crediting of hydrogen combustion trucks. Hydrogen combustion trucks can be just as harmful as the diesel trucks for which they are promoted as a replacement, but they are treated irrationally as zero-emissions vehicles, which erodes the rule’s ability to drive truly zero-emissions trucks to market.

Overall, the rule’s structure still diminishes its ability to guarantee the deployment of zero-emission trucks.

EPA’s final rule is a performance standard, not an EV mandate

EPA has set a technology-neutral greenhouse gas emissions rule, which means manufacturers have a range of technologies to choose from to reduce those greenhouse gas emissions, the vast majority of which will not result in reductions of the smog-forming and soot pollution inundating communities today. Because EVs are a cost-effective technology for a range of heavy-duty applications, it is likely that manufacturers will deploy them as part of their compliance strategy, but it is the states who are laying that groundwork by providing definitive sales requirements on manufacturers.

Roughly 20 percent of the heavy-duty market (11 states) have adopted the Advanced Clean Truck rule (ACT), which requires an increasing number of zero-emission trucks be sold in those states. California has also adopted the Advanced Clean Fleets rule, which helps create a market for electrification and ensures the entire fleet (not just new vehicles) electrifies—though EPA has been slow to approve a waiver on this rule. Manufacturers get credit under EPA’s rule for electric trucks sold to meet these state standards, so it begs the question: are there going to be more electric trucks deployed in response to EPA’s rule? And if so, where?

Below, I walk through a UCS analysis that tries to dig into this critical question.

This rule is expected to result in additional electric trucks, but not as many as EPA thinks

Because manufacturers can comply with EPA’s rules with any technology that reduces greenhouse gas emissions at the tailpipe, this rule will bolster the deployment of technologies that make diesel vehicles more efficient. While this may be good for cutting greenhouse gas emissions, it doesn’t do anything to reduce the harm from the smog-forming and particulate pollution from those vehicles. And unfortunately, EPA has not factored in the full suite of efficiency technologies in their analysis, which means these heavy-duty rules have plenty of regulatory slack that will ease pressure on manufacturers to deploy the cleanest available technology (electric trucks).

In thinking through how manufacturers will respond to EPA’s final rule, we consider three scenarios: 1) no additional diesel technology deployed beyond what was likely to be deployed under the Phase 2 regulations already on the books; 2) a continually increasing adoption through 2032 of non-engine efficiency technologies that EPA had already identified would be deployed by 2027; and 3) an adoption of diesel vehicle technologies that would pay for themselves within a 2-year timeframe thanks to reduced fuel costs. None of these scenarios represent a significant deployment of the most effective technology to cut fuel use from a diesel vehicle, hybridization, so these scenarios could still underestimate the degree to which diesel-fueled vehicles are used to comply with this regulation.

Even under a best-case scenario, EPA’s rule falls short of the level of zero-emission deployment needed to simultaneously address climate change and the freight pollution overburdening communities around the country. At the same time, the rule is still likely to lead to additional electric truck deployment according to our analysis. But the results vary significantly by vehicle class.

For the light-heavy-duty (LHD) trucks (Class 3-5, which include F-350 work trucks, package delivery vehicles, etc.), EPA’s final rule could result in a similar level of adoption in the rest of the country, if manufacturers primarily use electric trucks to comply with the rule, with an additional 160,000 electric Class 3-5 trucks deployed from 2027-2032 thanks to the added pressure of EPA’s rule. Even if cost-effective diesel efficiency technologies are deployed, EPA’s stringency for LHD trucks is great enough that this would still yield an additional 130,000 electric Class 3-5 trucks. Including ACT, zero-emission trucks could represent around ¼ of Class 3-5 trucks sold in the timeframe of this rule.

Unfortunately, when it comes to the heaviest vehicles on the road, the numbers are not nearly as rosy, because EPA’s rules for Class 6-8 vehicles are far less stringent. This is especially problematic since the largest vehicles have a disproportionate impact on emissions: Class 7-8 vehicles are about half of new heavy-duty vehicle sales but are responsible for 70 percent of all heavy-duty truck fuel use and global warming emissions in the U.S. For reference, Class 6-7 (medium heavy-duty, MHD) vehicles include school buses and large box trucks, while Class 8 (heavy heavy-duty, HHD) include refuse trucks and tractor-trailers.

Weaker stringency translates directly into a weaker push for electrification. ACT is expected to yield over 200,000 zero-emission MHD and HHD trucks in the 2027-2032 timeframe, representing 36 percent of Class 6-8 trucks sold in those states. Optimistically, EPA’s rule could result in nearly 170,000 additional zero-emission MHD and HHD trucks—however, diesel efficiency improvements could cut this number by over 70 percent, to under 50,000. Assuming those trucks are deployed outside of ACT states, this would represent just 2 percent of Class 6-8 sales in non-ACT states over the timeframe of the rule. Worse still, because EPA continues to erroneously credit hydrogen combustion trucks as zero-emission vehicles, that total is likely to be even further eroded.

The weak stringency of EPA’s rule for the heaviest and most polluting vehicles on the road, combined with a technology-neutral approach that doesn’t factor in tailpipe smog-forming and particulate pollution, allows for a disparity in national deployment of zero-emission trucks. The rule risks having communities of haves (in ACT states) and have-nots (in the remainder of the country), precisely the sort of situation a federal rule is supposed to ward against.

Considering how vital electric trucks are to addressing harms from the freight sector, this is unacceptable, even if on net the rule is still likely to result in additional electric trucks beyond what is required under state policies.

Electric trucks offer the clearest path to limiting harm from the freight sector

Communities on the ground currently disproportionately burdened by the harms of our freight sector need government intervention to eliminate those harmful emissions, which is why they’ve called for a transition to zero emissions. That path to zero is inclusive not just of the direct tailpipe emissions, but also a just transition for workers and a transition to clean energy to ensure that the transition doesn’t just exchange the health burdens on one community for another.

The heavy-duty sector encompasses a wide range of truck types and operating conditions, but no matter the type of vehicle, electric trucks represent a tremendous opportunity to cut greenhouse gases, which is why they’re highlighted by EPA in its rule.

Of course, for the communities already overburdened by freight pollution, the motivation for zero-emission freight is remedying the more direct public harm caused by thousands of trucks driving past. This is why when EPA was considering changes to its smog-forming and particulate pollution standards for heavy-duty vehicles we pushed for EPA to use that opportunity to drive the sector to zero tailpipe emissions and why it’s a missed opportunity that this rule doesn’t reflect a multipollutant strategy to drive ALL emissions from new trucks to zero.

We need a cohesive, comprehensive, and coordinated zero-emission freight strategy built on EJ community input

While this final rule provides some additional push to drive the freight sector to zero emissions, this rule is not happening in a vacuum. Because the number of electric trucks deployed under EPA’s rule are entirely dependent upon manufacturer strategy, the best thing the administration can do now is to support the deployment of electric trucks through complementary policies to help ensure that the rule is complied with in a way that will maximize the public health benefits.

A commitment to a 100 percent zero-emission freight sector would not only improve environmental and public health but bolster economic growth by advancing green technologies and job creation. Importantly, this comprehensive strategy when put into action could not only ensure coordination around a national charging system for freight corridors that will target a zero-emission truck fleet, but it would also help move the conversation beyond trucks to other sources of emissions harming communities around ports, warehouses, and rail/multimodal facilities, including locomotives, freight equipment, and ships.

Today’s EPA rule is not the single visionary policy needed to achieve a just path to zero, but it could be a positive step toward meaningful action. In order to drive the change needed for communities burdened by the harms of our freight sector today, and to align with the administration’s stated vision that “environmental justice is a whole-of-government commitment that requires early, meaningful, and sustained partnership with communities and dedicated leadership in Federal agencies,” the Biden administration should work with communities to develop a clear and comprehensive path to zero-emission freight.

Air pollution from ports comes from many sources: ships, trains, tugboats, cargo equipment, and – quite importantly – the trucks that move cargo containers to and from ports. The vehicles, vessels, and equipment that move our freight create hot spots of some of the worst air quality in the country and contribute significantly to climate change. However, zero-emission options for these workhorses of the economy are growing rapidly and some ports are beginning to move towards cleaner operations.

To accelerate the much-needed transition to cleaner ports nationwide, the Environmental Protection Agency (EPA) announced the Clean Ports Program (CPP), which provides $3 billion for zero-emission equipment and climate and air quality planning at our country’s ports. This funding, provided by the Inflation Reduction Act, is available to a wide variety of entities, including port authorities, local and tribal governments, and regional air quality agencies as well as businesses and non-profits that partner or collaborate with these public entities.

The types of projects eligible under the CPP range widely, but notably the agency is focused on already proven zero-emission technologies, like electric tractor trucks, tugboats, and cargo handling equipment. Additionally, much-needed activities like localized air quality monitoring, enhanced port collaboration with communities, and planning for things like climate resiliency and future zero-emission projects are eligible for funding. The program is squarely focused on zero-emission equipment and projects – combustion technologies are explicitly ineligible.

In addition to focusing on currently available technology, CPP is focused on projects that can begin near-term. The funding process for awarded projects is on a quick timeline, set to be released in late 2024. The amount of funding for zero-emission equipment ranges by port size and type. The largest water ports (think Ports of LA/Long Beach, Port of Houston, and the like) are eligible for between $150 million and $500 million per grant with a minimum cost share of 20 percent. Smaller water ports and inland ports (think intermodal rail yards and similar facilities) are eligible for up to $150 million with a 10 percent cost share, and both dry and inland ports run by Tribal governments are eligible for up to $50 million per grant, 100 percent funded by the program.

Combined with the new incentives to electrify commercial vehicles in the Inflation Reduction Act, and the billions of dollars in climate and air quality funding available from other federal programs like the Climate Pollution Reduction Grant, the CPP represents a meaningful step towards reducing climate-warming and toxic air pollution from our freight system.

The flexibility of the program will likely mean that a diverse array of project types will be funded under the CPP.  I thought it would be helpful to highlight some potential projects that could be awarded under the program as food for thought. Here are a few examples (in no particular order).

Electrifying tugboats

Harbor craft are a significant source of air pollution at ports, responsible for sizable portions of air and climate pollutants at seaports. Zero-emission tugboats may not be in the spotlight as much as electric cars and trucks, but these cleaner, quieter, and capable powerhouses are beginning to hit the water. While their abilities have been well-proven, electric tugboats are still a novelty; CPP funding could help to raise the profile of these vessels and drive costs down as more are ordered, in addition to the obvious air quality benefits.

Accelerated transition to clean drayage trucks

Drayage trucks – tractor trucks that move shipping containers to and from ports – are among the dirtiest of the dirtiest vehicles on our roads and contribute significantly to air pollution in areas near ports. Because drayage trucks tend to be among the oldest tractor trucks on the road, they tend to pollute at greater rates than other tractors. Mile for mile, a typical drayage truck operating out of the Port of LA emits around 70 percent more ozone-forming nitrogen oxides and over 20 percent more lung-damaging fine particulate matter compared to the typical tractor truck in the rest of California, according to CARB.  

While drayage trucks and their charging stations are beginning to come online across California, progress has been much slower in the rest of the country. The CPP could support a variety of projects to electrify drayage operations, including the purchase of trucks, constructing charging stations to support funded trucks, and even onsite renewable energy generation and minor grid upgrades. Although drayage fleets themselves aren’t eligible for the funding, ports and municipalities could partner directly with local drayage fleets or use the funding to prop up a program to help independent drayage operators purchase zero-emission trucks. Coupled with the up-to-$40,000 per truck federal incentive, funding for drayage electrification from CPP could help boost the market for clean drayage trucks.

Electrifying off-road cargo handling equipment

In addition to the drayage trucks that move containers on roads and highways, ports are home to yard trucks and polluting cargo equipment that move and organize shipping containers around the facility. Zero-emission yard trucks have already been deployed at ports and freight facilities across the country with great success. Orange EV, an electric yard tractor manufacturer based in Kansas City, has deployed its battery-powered trucks across the country for nearly a decade. Other electric “off-road” cargo equipment like the massive cranes and forklifts that move and stack containers could be eligible for funding under the program.

Better quality community-level data

Community and non-profit organizations can also apply for funding under the CPP, so long as they partner with an eligible public entity. The CPP could fund various types of projects to gather data on air quality and pollution sources, such as hyperlocal air quality monitors or visual truck counting technologies. These projects could be conducted by a community group in partnership with a local government, air quality management district, or port authority. A local air quality monitoring project like this is planned this year in the port-adjacent neighborhood of West Oakland and an innovative truck counting project, called Chicago Truck Count Data Portal, recently published.

High-quality localized air quality monitoring combined with truck count data could help to provide a better understanding of how individual communities are impacted by air pollution from ports and other sources. Because national air quality standards are enforced using ambient air quality measurements over large areas and timescales (daily and annual averages), they may not always accurately account for shorter spikes in air pollution or high concentrations in specific areas. Neighborhoods adjacent to ports often have significant levels of drayage truck traffic, which can cause these localized pollution spikes. Higher quality data in these areas could help to empower communities and mobilize decisionmakers to address this issue of environmental equity.

Funding for ports to improve collaboration with impacted communities

In addition to the projects and planning activities CPP can support, it can also provide funding to ports to increase its engagement efforts with communities. This could cover a range of things from propping up new collaborative programs internally to supporting staff and administration costs for consulting with community leaders. Regular and meaningful engagement among port authorities and port-adjacent communities is an important step toward addressing the historical and disproportionate impacts of port pollution. Also notable is that EPA signaled that they will prioritize applicants who have previously and will continue engaging with disproportionately impacted communities over the long term.  

More work to be done…

These potential projects are but a few examples of the meaningful and urgent work needed to reduce pollution from ports across the country. While this program represents a significant and targeted investment by the federal government to address climate-warming and toxic air pollution from ports, it is but one of many state and federal actions needed to mitigate climate change and address air quality disparities.  

Last year, the Union of Concerned Scientists (UCS) made headlines across the country when we published a report demonstrating how worsening wildfires in the West are linked to the unrelenting, shameless emissions of the fossil fuel companies. While we hope that our science will bolster efforts to hold these companies accountable, the truth is that such accountability is necessary but insufficient.

Climate-change fueled disasters will continue to have impacts on human health. We must measure these impacts and mitigate them. Wildfires have the most obvious and devastating effects on the lives of the people living in the neighborhoods that they destroy, but the impact they have on our air and water can spread far beyond the burn scar.

Two bills being considered by the California legislature can help mitigate the public health impacts of wildfires. UCS supports the passage of both.

Wildfires and water quality

Most of California’s water comes from rain and snow that falls in the Sierra Nevada Mountains and flows down to the population centers throughout the state. Usually, vegetation and soil will help soak up the rain and slow the flow of rainwater, nutrients, and soil over the land.

When a wildfire burns away vegetation and scorches soil, the soil becomes less absorbent and precipitation flows more quickly into the rivers, eroding away soil and picking up nutrients in higher quantities than usual, along with ash and debris. Worse, if a wildfire burns through an area populated by humans, when the rain falls, toxic chemicals from burning cars, plastics, and all sorts of synthetic products can flow into waterways and drinking water systems.

For more on the impacts that wildfires have on water quantity and quality, read our 2022 factsheet, Fire and Water in the Western United States.

Wildfire and air quality

Anyone who has lived in California for the past few years knows that our summers are plagued with unhealthy air quality days. And as is too often the case, the Central Valley bears the brunt of this impact.

There is an enormous amount of data on the adverse health impacts associated with poor air quality: respiratory issues, cognitive issues, impacts on pregnant people and their babies, and more. Many California communities already have some of the highest rates of heart and lung disease in the country, and these problems are only made worse by wildfire smoke.

What can we do?

California must continue to aggressively and equitably phase out fossil fuels across all sectors to minimize growth in the size and severity of future wildfires. The state should also plan for and fund projects that make our forests and communities more resilient to wildfire.

However, even with these actions, wildfires are a part of our lives in the western United States, as they have been for generations given our climate and our ecosystems. We must understand and mitigate their impact on human health.

There are two bills currently moving through the California Legislature that the Union of Concerned Scientists supports as key steps towards this end:

• Senate Bill 945 (Alvarado-Gil)would require state agencies to create, operate, and maintain a statewide-integrated wildfire smoke and health data platform to facilitate action from state authorities and the medical community to confront this critical, public health issue. We can’t improve what we can’t measure, and the current status quo makes it difficult to get a comprehensive picture of how smoke is affecting the health of Californians throughout the state.
• Senate Bill 1176 (Niello) would require state agencies and research entities to form a work group to establish best practices and recommendations for wildfire-impacted communities and first responders to avoid exposure to heavy metals after a wildfire.

California should pass these bills, continue to look for opportunities to make data on wildfire impacts accessible, and make data-informed decisions on protecting people from wildfire-associated human health impacts.

I am into air quality.

Especially when it means I can breathe outside because there is no pesticide drift, wildfire smoke, vehicle exhaust, or pungent odors. However, the reasons why I am into air quality are a bit contradictory.

On the one hand, I am fascinated by air quality because I love working with sensors and monitoring equipment. I enjoy doing outreach and education about electronics with kids. I am also into open hardware and open data access. I have been collaborating for a few years with AirGradient and am part of a team of worldwide volunteer scientists who advocate for air quality justice.

And, importantly, I strongly believe in community-driven data collection to empower people with relevant information to advocate for a safe and healthy environment. It’s fun! You should try it! Check out the air quality data from my backyard in Merced, California, this past year:

The graph shows PM2.5 (particulate matter smaller than 2.5 micrometers). Spikes in PM2.5 make the air unhealthy. My best guess is that the fall spikes are dust from almond operations near my home, and the winter spikes come from a combination of sources, including burning fuel. The air in Merced is trapped by the classic temperature inversion of the San Joaquin Valley. In addition, Merced County applies more than 10 million pounds of pesticides per year that contribute to the area’s poor air quality.

On the other hand, I am scared about bad air quality. I live in the region with the worst air quality in the United States: the San Joaquin Valley in central California. But I consider myself lucky because I live in Merced, which has one of the best air qualities in the region, although best doesn’t mean it’s good.

Why do I choose to stay in a place with such bad air quality? I suppose I’m stubborn enough to believe that my presence here can make a difference. I moved to Merced in 2015 to study for my PhD, and I found a place I could call home. This is a diverse and wonderful community I now call my own. I became attached to the people and to the place. Maybe one day I will move out of the San Joaquin Valley, but not yet. I’m deeply committed to socioenvironmental justice and agricultural sustainability, and I want to help people who need it the most. Failure is not an option because I live here; I cannot just disconnect. This is more than just my job.

This is personal.

The 2024 State of the Air report

I work every day on topics related to air in my role as a Senior Climate Scientist at UCS, through my volunteer grassroots work, and because I want to be a well-informed resident in the San Joaquin Valley. So of course the American Lung Association’s yearly report, State of the Air (SOTA), published every year since 2000, is of professional and personal interest.

Since its inception, the report has effectively heightened the awareness of some hazardous air pollutants, and engaged the public, media, advocates, and policymakers in the ongoing fight against air pollution. The report aims to empower individuals like me to inform ourselves, our families, and our communities.

The air quality for this report was calculated using data reviewed by EPA from 2020, 2021, and 2022. That means it includes the extreme wildfires exacerbated by the fossil fuel industry that burned more than 4% of California in 2021 and 2022. You can find this year’s SOTA report, released last month, on the American Lung Association’s website, and you can compare it with 2023’s report, 2022’s, and all of the reports.

Bad news first: challenges with air quality persist

Unfortunately, there were no significant changes this year, and California and the southern San Joaquin Valley still have the worst air quality in the country by far. 

This is not new. For the last several years, Bakersfield in Kern County, Visalia in Tulare County, the metropolitan area of Fresno, Kings, and Madera Counties, and Los Angeles have had the worst air quality in the United States out of more than 200 metropolitan areas nationally.

In the US, approximately 40% of the population, about 130 million people, live in places with failing grades for unhealthy levels of air quality.

Disparities in air quality disproportionately impact communities of color, highlighting systemic inequalities rather than individual choices. Across the county, people of color are 2.3 times more likely than white people to live in a county with failing grades in air quality.

This is not a new finding either. As UCS has been reporting for years, cars, trucks, and buses are a significant source of air pollution in California that disproportionately exposes Black, Latino, and Asian communities to higher levels of harmful pollution compared to majority white communities.

It is important to note that some extremely toxic air pollutants you may have heard about, such as ethylene oxide (EtO), are not included in the report. EtO is extremely difficult to monitor, yet very dangerous. You can inform yourself more in this UCS report.

One very important piece of information missing from the State of the Air report is air quality data for farmworker communities and other rural areas in the United States or California. The American Lung Association focuses only on metropolitan areas, and they use only official EPA air quality monitors. These monitors are very expensive and largely absent from small rural communities. All data used in the report must be reviewed by EPA, which makes the process slower.

In the San Joaquin Valley where I live, most rural communities are farmworker communities. Farmworkers are exposed to poor air quality both as outdoor workers and as residents inside homes that often are not properly insulated nor equipped with air conditioning to endure the scorching summer. While I think the American Lung Association report is a very important tool for millions of people in the US, we cannot forget that millions more live far from air quality monitors and may be breathing and living with poor air without knowing it. That is why community science for air quality monitoring in rural areas is extremely important to have everyone informed.

What pollutants are in the San Joaquin Valley’s (and California’s) air?

The American Lung Association’s State of the Air report measures three of the major types of pollutants in the San Joaquin Valley: long-term particle matter, short-term particle matter, and ozone.

Particle matter pollutants consist of extremely small solid and liquid particles in the air, originating from various sources like oil refineries and fossil fuel burning, fracking, transportation, conventional agriculture, wildfires, construction, and biomass burning (like heating with fireplaces). These particles are categorized by size. Coarse particles (PM10, that is particulate matter that is 10 micrometers or less) include dust and pollen, fine particles (PM2.5) come from burning fossil fuels and pesticide use, and ultrafine particles (PM0.1) come from reactions of industrial pollutants (nitrogen oxides and sulfur oxides) with sunlight and unfinished fuel combustion. Ultrafine particles can make the air look hazy even though individual particles are invisible to the naked eye. While the nose and throat mostly filter coarse particles trying to get into our bodies, fine and ultrafine particles can penetrate deep into the lungs and even enter the bloodstream. The negative effects include negative effects on cardiovascular and respiratory health, increased risk to babies and pregnant people, and increased risk of premature death in older adults. Even brief exposure to elevated levels of fine particles can increase the risk of heart attacks, strokes, and other cardiovascular events.

Ozone, too, poses significant risks to respiratory health. Ozone plays a dual role in our atmosphere. High up, it forms a protective layer that shields the Earth from ultraviolet rays. However, at ground level, where it can be inhaled, ozone becomes a key component of smog, a harmful mix of air pollutants. Ozone is formed when nitrogen oxides (NOx) and volatile organic compounds (VOCs) react in sunlight, and it is exacerbated under higher temperatures that make ozone pollution worse in the summer. In California, VOCs can come from fossil fuel industry, refineries, methane (especially in Los Angeles and southern San Joaquin Valley), and pesticides (in the San Joaquin Valley). NOx can come from vehicle pollution (Los Angeles, San Joaquin Valley, and the rest of California) and agricultural fertilizers (San Joaquin Valley). Short-term ozone exposure worsens asthma and chronic obstructive pulmonary disease, increases pneumonia risk, and impairs lung function. Long-term exposure can lead to asthma development, chronic obstructive pulmonary disease, and systemic health issues, including premature death.

As a reminder, California has about one quarter of a million oil wells: some small communities in Kern County, at the southern end of the San Joaquin Valley, are surrounded by thousands of wells, and people in L.A., Bakersfield, and other cities are familiar with oil wells in their metropolitan areas. For example, there are 1,700 oil wells inside the small rural community of Derby Acres and 9,500 within one mile. Inside the relatively large city of Bakersfield (population 410,000), also in Kern County, there are around 2,000 wells, and within one mile of the city there are more than 9,000. The metropolitan area of Bakersfield is and has been for several years the most polluted metropolitan area in the United States by short-term and year-round particulate matter, and ranks in third position for ozone pollution.

There’s good news: we’re working on solutions

The air quality in the San Joaquin Valley is poor, and we don’t even know how bad it actually is in the valley’s rural areas. But the good news is there are plenty of people doing something about it because we live here and we care.

For example, several groups like Central California Asthma Collaborative, Central California Environmental Justice Network, and the SocioEnvironmental and Education Network are installing accurate and affordable air quality monitors in many rural communities to raise awareness of air quality injustice and conduct outreach about its health impacts.

Another example is that of researchers at UC Merced who are trying a new generation of AI models to better estimate air quality in rural areas. Data collected with low-cost air quality monitors by community members can be used to inform their communities and support local leaders to make real-time decisions in response to air quality changes. Data can also be used to improve the accuracy of air quality models, which in turn will give even better information to communities.

The news from the SOTA report may be dire, but what gives me hope (besides phasing out fossil fuels) is a solution that I and many colleagues here in the San Joaquin Valley are actively working on: cropland repurposing. It’s a powerful solution that I blog about often (here, here, and here).  

Cropland repurposing is a viable solution to address water scarcity and water quality; and, the good news is it is also a solution to improve air quality. Cropland repurposing alongside sustainable agriculture that prioritizes healthy soil, limited to no use of pesticides, and reduced application of toxic fertilizers can improve air quality in places like the San Joaquin Valley. Here we will need to repurpose probably more than one million acres of crops over the next decades.

If we do it right, cropland repurposing can dramatically improve the quality of life in disadvantaged communities and increase economic and agronomic resilience for farmers while achieving sustainable water use and fostering environmental health.

In rural areas, a one-mile revitalization zone around the smallest 123 agricultural disadvantaged communities of the San Joaquin Valley could decrease water usage by 1.45 million acre-feet, pesticide usage by 11 million pounds, nitrate leaching to aquifers by 193 million pounds, and CO2 emissions by 1.85 million metric tons. This was the conclusion of a peer-reviewed study I was involved in.

But reimagining sustainable agriculture in California can also help the metropolitan areas reported on by the American Lung Association’s State of the Air report.

As a reminder, the worst air quality in the United States is in Kern, Tulare, and Fresno counties, and by far these three are the counties with the highest pesticide application in California. I don’t know if better agricultural practices can give a passing grade to our San Joaquin Valley cities because fossil fuel-related pollution is still very bad in those areas. But ending our reliance on fossil fuels combined with better agricultural practices can dramatically increase air quality in California for all of us.

The way forward

California’s air quality issues stem from a combination of its geography, climate, and anthropogenic factors. California’s beautiful topography, with its valleys and mountains, can make the air stagnant and trap air pollutants, leading to the accumulation of pollution in certain areas like the San Joaquin Valley or Los Angeles. We cannot change the topography.

Climatically and meteorologically, California has temperature inversions, where a layer of warm air traps cooler air near the ground, preventing pollutants from dispersing into the atmosphere. Again, this is particularly common in the Central Valley and in Los Angeles. Additionally, wildfires, exacerbated by climate change and drought conditions, release large amounts of smoke and particulate matter into the air, further worsening air quality.

While we can do a better job managing our forests to prevent wildfires, we cannot modify California’s meteorological characteristics. But we can change the anthropogenic factors that lead California to having the worst air quality in the United States.

We need to do more to improve air quality in both urban and rural areas and to inform people about it. We need to care about how public policies shape Californians’ health. We need to demand better, cleaner alternatives for energy, transportation, and agriculture. We need to reverse climate change.

Of course, I know this is easy to say… but if we act together, it can also be feasible to do!

In California cities, to improve our air quality and our well-being, we must end the reliance on fossil fuels, promote clean transportation, and enhance greener urban planning.

In California rural and agricultural areas, in addition to the above, we need to learn from the past and become sustainable. Cropland repurposing is an opportunity to improve everyone’s quality of life, bring economic and environmental sustainability to farmers and rural communities, and improve our air quality by drastically reducing the reliance on pesticides and fertilizers and by stopping inadequate agronomic practices that release polluting dust.

We are at a critical moment in California with a once-in-a-generation funding opportunity to correct injustices and improve climate resilience in the United States thanks to funds from the Inflation Reduction Act and Infrastructure Investment and Jobs Act. If California is going to continue to lead in environmental protection, agriculture, and technology, and make its air cleaner, then our elected leaders must incentivize more than ever the cleanest energy and transportation, the most sustainable agricultural practices, and the most equitable and environmentally-friendly economic growth.

Our noses, throats, hearts, and lungs deserve it.

It’s been just over a year since the California Air Resources Board unanimously adopted the Advanced Clean Fleets (ACF) Rule, which requires the largest commercial and public fleets operating in the state to gradually transition to zero-emission trucks and buses over the next two decades. By accelerating the adoption of zero-emission trucks and buses by around 80 percent, the ACF will usher in massive reductions in pollution, as well as billions of dollars in savings to fleets – estimated at $48 billion through 2050 to be exact, even when considering costs related to higher upfront vehicle purchase prices, installing charging infrastructure, and retraining drivers and mechanics.

Such meaningful and transformative efforts are not free from hiccups, however. Because of this, regulators worked closely with impacted businesses, community advocates, and technical and policy experts (like UCS!) to include a wide array of flexibilities for fleets to maintain compliance under the rule.

Similarly, the transition to a cleaner and more equitable freight system will not be free from increased upfront costs for fleets, but today there are more funding opportunities from both state and federal programs than ever before. The current incentives for zero-emission vehicles (ZEV) purchases can lower the upfront cost of zero-emission trucks and buses for California businesses to a rate comparable to, and sometimes even lower than, the exponentially dirtier diesel models on our roads today.

Despite the generous funding opportunities and holistic flexibilities baked into ACF, confusion around and misinformation about the rule may undermine this much-needed shift away from fossil-fueled trucks and buses. To set the record straight, we have answered some of the most frequently asked questions about the ACF’s feasibility, flexibility, costs, and benefits.

Funding for Advanced Clean Fleets (ACF)

What state funding is available to help with ACF compliance?

California provides more state incentives to electrify commercial vehicles than any other state:

• The California Hybrid and Zero-Emission Truck and Bus Voucher Incentive Project (HVIP) program provides eligible fleets who purchase zero-emission trucks with a voucher roughly equal to the difference in upfront cost between comparable zero-emission vehicle (ZEV) and internal combustion engine (ICE) models. The HVIP program has invested over $1 billion in California as of the year 2023, with over 12,000 vouchers.
• Fleets that utilize electric and hydrogen vehicles are eligible to earn Low Carbon Fuel Standard (LCFS) credits, which can be sold to offset ZEV costs. Revenue generated by LCFS credits depends on credit prices, but estimates can be calculated using the LCFS Credit Price Calculator (click here to download the calculator from CARB).
• The Carl Moyer Grant Program also provides incentive funds (around $60 million/year) to private companies and public agencies to purchase cleaner-than-required engines, equipment, and emission-reduction technologies for heavy-duty equipment.
• Additionally, the California Public Utilities Commission has approved programs for four separate utilities, with $739 million for investments in zero-emission medium-and heavy-duty vehicles (MHDVs) and charging infrastructure.

What about federal funding?

There are several federal programs with funding available to target medium and heavy-duty ZEV transition, including:

• The Commercial Clean Vehicle Credit (45W) under the Inflation Reduction Act of 2022 (IRA) assists fleets by defraying upfront costs associated with purchasing a clean vehicle, a tax credit of up to $40,000 per vehicle. The IRA also provides up to $100,000 in assistance per commercial vehicle charger under Section 30C.
• The Clean Ports Program (CPP) funded by the IRA and provided through U.S. Environmental Protection Agency (EPA), has been allocated $3 billion to fund zero-emission port equipment and infrastructure as well as climate and air quality planning at U.S. ports. The funding under the CPP will likely usher hundreds, if not thousands, of new zero-emission drayage trucks onto our roads with many replacing aging diesel trucks.
• The Climate Pollution Reduction Grants (CPRG) program provides $5 billion in grants to states, local governments, tribes, and territories to develop and implement ambitious plans for reducing greenhouse gas emissions and other harmful air pollution. Also funded through the IRA, the program provides $250 million for non-competitive planning grants and around $4.6 billion for competitive implementation grants.

Flexibility in Advanced Clean Fleets

Are there compliance extensions or exemptions within the ACF?

The ACF includes both generous extensions and exemptions for fleets that act in good faith but are unable to meet the requirements of the rule due to lack of appropriate model availability, delay in vehicle delivery, delays in infrastructure construction, and in cases where necessary electricity to support depot charging is not available. Some examples of compliance extensions and exemptions under the ACF are:

• Backup Vehicles– if a backup vehicle is in operation for fewer than 1,000 miles per year, compliance exclusions may apply.
• Daily Usage– if a fleet owner cannot comply because the daily usage of the vehicle cannot be adequately met with ZEV technology, exemptions may apply.
• ZEV Infrastructure Construction– if a fleet owner initiates a project for ZEV charging or refueling infrastructure, a construction delay can grant rule extensions for up to 2 years.
• ZEV Infrastructure Site Electrification– if fleets are unable to obtain the amount of electricity necessary to support ZEV operations, they may be granted an extension of up to five years.
• Vehicle Delivery Delay and Cancelation– if a fleet owner purchased ZEVs but the delivery from the manufacturer is delayed/canceled, extensions can apply.
• ZEV Purchase Exemption– fleet owners may request a compliance exemption if a ZEV model is unavailable in the configuration needed. CARB will maintain a list of unavailable ZEVs in popular configurations.
• Declared Emergency Response– a vehicle operating under contract to support a declared emergency may be exempted from compliance.
• Mutual Aid Assistance– some exemptions apply for fleet owners that have mutual aid agreements to send their ICE vehicles out to others during emergencies.
• Rarely operated vehicles (Five-day pass)- a 5-day exemption can be available to vehicles entering California once a year for up to 5 consecutive days.
• Non-Repairable Vehicles– if an existing ICE vehicle is damaged beyond repair, an exemption may apply for the ICE replacement model.

Other Frequently Asked Questions…

What are the climate benefits from the ACF Regulation?

The ACF is estimated to significantly reduce pollution from the statewide commercial truck and bus fleet. By 2050, the climate benefits from compliance with ACF will translate to a reduction of 146,000 tons of nitrogen oxides, nearly 7,000 tons of fine particulate matter, and 327 million metric tons of carbon dioxide.

What if a fleet just purchased new diesel medium- or heavy-duty vehicles?

ACF offers several flexible compliance pathways and many exemptions and extensions to improve the ease of compliance for California’s diverse set of fleets. In some cases, fleets who purchased certain ICE model year 2024 trucks would be able to operate them through 2042.

When will enforcement begin?

Compliance began on January 1, 2024 for state and local fleet and drayage requirements, but different portions of the rule phase in gradually through 2042. Under the federal Clean Air Act, California must obtain a waiver from EPA for certain air quality regulations that go beyond federal standards.

While drayage and high-priority fleets reporting and registration requirements were subject to enforcement as of January 2024, CARB communicated in December of 2023 that it would not be exercising its enforcement authority concerning the drayage or high-priority fleet reporting requirements or registration prohibitions until the EPA grants a preemption waiver applicable to those regulatory provisions or determines a waiver is not necessary. CARB requested the preemption waiver from EPA in November of 2023.

What counts as a ZEV under ACF?

Trucks and buses that produce zero tailpipe emissions, including battery-electric and hydrogen fuel-cell vehicles, count as ZEV compliant. Plug-in hybrid trucks and buses with certain all-electric ranges count towards compliance through 2035.

How many and what types of medium and heavy-duty vehicles are available today?

There are over 150 medium and heavy-duty zero-emission vehicles currently available across multiple categories, including school buses, tractors, vans trailer trucks and refuse trucks. CalSTART’s Zero-Emission Technology Inventory tool and the California HVIP website are two resources that offer MHDV inventory availability by brand and type to help assist with current vehicle options, as well as new inventory expected.

What is the total cost of ownership for ZEVs compared to diesel trucks?

ZEV options for several common truck types have preferable total cost estimates today, and ZEV models for all truck types are estimated to have lower total cost by 2030 (I’ve blogged in detail about this previously). While initial purchase prices may be higher, savings from fuel costs generate the greatest offset, even in California with the state’s historically higher electric rates. If state and federal ZEV funding incentives are applied in cost comparisons, buying a zero-emission MHDV realizes even further savings.

Where can I get more information?

You can find more details on CARB’s website or by checking out our other blogs on the rule. My colleague Michele Canales’ blog post explains what the rule will do for California.

Trucks and buses on California’s roads and highways are responsible for the majority of lung-damaging fine particulate and ozone-forming nitrogen oxide emissions, and over 20% of the climate-warming greenhouse gas (GHG) emissions from vehicles. Diesel exhaust in particular is a well known carcinogen and has also been linked to adverse health conditions ranging from chronic heart disease to decreased lung-function in children. Given that a disproportionate amount of public health impacts from heavy-and medium-duty vehicle emissions are concentrated in lower income communities, mitigating, and eventually eliminating this significant source of pollution has been a priority in the state of California.

Passed last year, the Advanced Clean Fleets (ACF) rule is a first-of-its-kind emission standards regulation designed to ease the introduction of zero-emission vehicles (ZEVs) into California’s large truck and bus fleets and address the air pollution and carbon emissions from trucks and buses. The regulation came to be after a multi-year workshop process that had significant participation from environmental justice groups in an effort to achieve the goals set out by Governor Newsom’s 2020 Executive Order (N-79-20) related to transportation sector emissions. UCS also attended ACF workshops and contributed relevant research on estimated emission reductions based on proposed iterations of the rule, which helped to inform the true extent of climate benefits that could be reaped, prior to its final adoption.

UCS Senior Vehicle Analyst Sam Wilson has previously written how the ACF rule is desperately needed to ensure access to clean air and combat climate change. The California Air Resources Board (CARB) estimates ACF will reduce climate-warming emissions from the state’s truck fleet by more than 40% by 2050. For more specifics on estimated reductions the ACF will bring to emission levels, take a look at Sam Wilson’s breakdown of air quality benefits here.

Since the ACF rule was adopted by CARB in April of 2023, both policy makers and fleet operators have asked questions about the scope and structure of the regulation.

What does the ACF require of California’s fleet operators? 

The rule can be broken down into three main parts: 

1. The “electrification” portion of ACF requires California’s largest and most polluting fleets, as well as state and municipal fleets, to gradually transition to zero-emission medium- and heavy-duty vehicles (MHDV) by 2050. 
2. The “drayage” portion requires vehicles operated for drayage (transporting containers to and from seaports and railyards) to transition to zero-emission vehicles (ZEV) by 2035.  
3. Lastly, the rule builds on the Advanced Clean Trucks (ACT) rule passed by CARB in 2020 and implements the requirement that all medium- and heavy-duty vehicles sold in California must be zero-emission after 2036, with some exceptions for emergency vehicles.   

Who is affected by the Advanced Clean Fleets rule?

Simply put, the rule applies to three types of fleets: fleets with 50 or more trucks, city and state-owned fleets of any size, and all drayage trucks. 

The electrification portion of the rule applies to fleets with 50 or more of any type of MHDV over 8,500 pounds and those whose annual revenue exceeds $50 million. Notably, ACF only applies to companies that own a lot of trucks, so many smaller fleet operators with as many as 49 vehicles have no requirements at all under the regulation.  

Also included under the rule are all state and local agency fleets—this includes any city, county, special district, department or agency operating at least one medium- or heavy-duty vehicle. Electrification requirements additionally apply to federal fleets and light-duty mail and package delivery vehicles.

The drayage electrification requirements apply to all vehicles operating drayage in California.

How can fleet operators comply with ACF? 

There are multiple compliance pathways for both commercial fleets and publicly owned fleets. Commercial fleets covered under the rule can choose from two different compliance pathways: 

1. Model Year Schedule: Fleets can begin to electrify now by only purchasing ZEVs for any new additions to a fleet, while continuing to use their existing internal combustion engine (ICE) fleet through the end of the vehicle’s useful life of 18 years or 800,000 miles, per Senate Bill 1 (SB 1).
2. ZEV Milestone Option: Fleets can gradually turn over their internal combustion fleet to zero-emission vehicles based on the California Air Resource Board’s gradual “ZEV Milestone” timetable. The timetable spells out when certain vehicles must be turned over. For example, the easiest-to-electrify vehicles like delivery vans, must be turned over to ZEVs in 2025, work trucks, day cabs, and three axel buses in 2027, and for sleeper cab tractors and specialty vehicles in 2030.  

Fleet managers of large public agencies are required to purchase at least 50% ZEVs when replacing vehicles beginning in 2024, and 100% ZEV purchases after 2027. Smaller public agencies are not subject to the 2024 requirements but are subject to the 2027 requirement. The rule includes exceptions for certain public safety and emergency vehicles. Public agencies of any size may choose to follow the gradual “ZEV Milestones” pathway instead.    

The ZEV requirements for drayage operators applies to all vehicles included under California’s drayage registry for port entry. Currently operating combustion drayage vehicles may operate through their SB 1 useful lives timeline or 2035, whichever comes first. All new vehicles added to the registry must be ZEVs.

The 2036 100% ZEV sales requirement applies to all manufacturers but does not apply to certain emergency vehicles.    

What benefits are expected from the ACF rule?

ACF is anticipated to accelerate the annual adoption of zero-emission trucks in California by an estimated 80%, which will reduce exposure-related health complications from air pollution. Additionally, the rule will reduce greenhouse gas emissions from the state’s trucking fleet by nearly 330 million metric tons through 2050, roughly equivalent to taking 90 coal-fired power plants offline for an entire year. This reduction is anticipated to significantly reduce illness and mortalities from exposure to air pollution, with an estimated 2,500 fewer deaths and over 2,000 avoided hospitalizations through 2050. The total health benefits are quantified at over $26 billion through 2050.  

ACF is also unique among many other air quality and climate change regulations in that it is estimated to have greater net financial benefits to regulated fleets than quantified health benefits. CARB estimates that regulated fleets will save nearly $50 billion through 2050, even when considering capital upgrade costs like charging infrastructure.  

While portions of the ACF rule are now in effect, enforcement has not yet begun, as CARB requires a specific waiver from the U.S. Environmental Protection Agency (EPA) to employ certain air quality regulations. The benefits that will come from ACF are both substantial and highly needed, as indicated by our previous coverage of the issue, which is why UCS urges EPA to approve the waiver sooner rather than later, as ensuring compliance is a vital part of the rule’s success.

You can learn much more about ACF by visiting CARB’s website. To get into the weeds on ACF funding, flexibility, and other frequently asked questions, check out Sam Wilson’s recent blog post.

Let’s start this one with some good news: the transition toward clean freight is picking up speed. Over the past few years, we’ve started to see more and more zero-emission commercial trucks, delivery vans, and buses hit the road. The much-needed evolution of our on-road freight system to one that’s cleaner and more equitable is gaining momentum – and not a moment too soon.

Medium- and heavy-duty vehicles (MHDVs), like the big rigs on our highways and the vans that deliver our packages, make up just over 1 in 10 of the vehicles on our roads, but are responsible for over half of ozone-forming nitrogen oxide pollution and lung-damaging fine particulate pollution from on-road vehicles. They are also disproportionately responsible for climate-warming emissions, representing around 30 percent of greenhouse gas pollution from vehicles on our roads and highways. Zero-emission trucks and buses eliminate tailpipe emissions and significantly reduce life-cycle pollution.

One indicator of this progress is the growing share of zero-emission truck and bus registrations. This tells us which fleets are deploying electric vehicles, which types of these vehicles are being deployed, and where. Information like this is vital to understanding how the market is developing, but I think it’s equally important to investigate the why as well – this way, we can better understand what’s working and what’s not. After all, these trucks aren’t going to electrify themselves (although this does kind of sound like a superhero blockbuster plot). Such a paradigm shift within our nation’s $400 billion on-road freight industry demands both regulatory forces and economic upsides to be successful and lasting.

Smaller vehicles and big fleets are leading the charge

Where just a handful of zero-emission trucks and buses were deployed annually in the US just a few years ago (around 600 total in 2019), over 27,500 zero-emission MHDVs were deployed in 2023. While this represents a small fraction of the national MHDV sales (around 2.5 percent in 2023), the growth is impressive. What’s more, zero-emission vehicle (ZEV) uptake among certain sectors of the MHDV fleet has been nothing shy of meteoric in some states.

Cargo vans (the delivery vans that bring packages the last mile to your door) have seen the largest growth in ZEVs among all other MHDV types. In 2021, just a handful of zero-emission cargo vans were in operation nationally, however, today there are over 22,000 of these clean-operating vehicles making deliveries in our neighborhoods across the country. In 2023, electric cargo vans represented over seven percent of new registrations nationally for this vehicle type.

Large companies are leading this early growth. Around 12 percent of cargo vans registered by businesses operating over 500 vehicles were electric in 2023, compared to 2.58 percent by fleets with less than 50 vehicles and 2.35 percent by fleets with between 50 and 499 vehicles. This could be explained by larger companies having more access to capital to invest in zero-emission vehicles compared to smaller fleets, larger fuel bills that zero-emission trucks could help reduce, and more flexibility with larger numbers of vehicles. However, businesses of all sizes can benefit from the significant fuel and maintenance savings that electric vehicles deliver and the relative price parity between electric and combustion cargo and delivery vans makes these vehicles more approachable for businesses with less capital.

Some states are seeing more accelerated deployments than others. In 2023, nearly one in three cargo vans registered in Washington state were ZEVs. Georgia also stood out with over 22 percent ZEV registrations among cargo vans in 2023 – a good comeback mark for a state that was once a leader in electric passenger vehicle adoption. Interestingly, Florida registered the most electric cargo vans last year, around 3,400, representing just under 20 percent of all registrations for that vehicle type.

Several key reasons are behind this accelerated adoption.

Electrification makes clear sense in the last-mile delivery sector (the last leg of an item’s journey). According to recent data from a Census Bureau survey of Class 2b and larger vehicles, over 90 percent of Class 2b and 3 trucks and vans travel less than 100 miles per day. Given that the range of the most common electric cargo vans on the market falls around 150 miles, fleets could see this is a no-brainer. Furthermore, delivery vehicles most often operate on predictable or fixed routes and return to a depot after the workday where electric vehicles could easily charge overnight and be ready for work the next day.  

As mentioned earlier, another major factor is lower operating costs. Compared to a combustion model, electric cargo vans have significantly reduced operating costs in most cases. Using the current national average for electricity and gasoline prices, fuel costs for the electric version of Ford’s Transit cargo van are around $0.10/mile, while the gasoline-powered version costs around $0.19/mile. In many cases, electric cargo vans have reached upfront cost parity with analogous combustion models. Ford’s 2024 electric and combustion Transit cargo van models are virtually the same base price – just over $50,000. This price parity is in part thanks to the $7,500 federal tax credit offered under the Inflation Reduction Act, but it could be eligible for additional incentives, depending on the location. In California, for example, electric cargo vans are eligible for an additional $7,500 incentive from the state. Incentives aside, the upfront prices of electric trucks and buses are anticipated to decline.

A third reason we see such rapid adoption of electric delivery vans may lie in their depots. Costs related to building out charging infrastructure can represent a significant cost of fleet electrification. However, where larger trucks and buses often require high-power chargers, fleets of last-mile delivery vehicles can reliably charge overnight on the Level-2 chargers often seen in people’s garages. This significantly reduces costs associated with charging hardware and construction and reduces potential hurdles of local grid capacity and permitting.

While the national public health, environmental, and climate impacts from a delivery van pale in comparison to the larger, mostly diesel-powered trucks and buses, their impact is not insignificant – the Census Bureau reports that Class 2b and 3 vans in the U.S. travel over 33 billion miles annually (roughly the distance of 20 round trips from Earth to Saturn). The climate impact of these vehicles is similar to that of nearly 70 natural gas power plants operating for a year (26.02 million metric tons CO2e annually). Additionally, electric delivery and cargo vans will serve as an example of the potential for successful accelerated electrification among other sectors in our freight system. Fleets operating larger vehicle types running similar routes have a path paved by electric cargo vans.

There’s no way around it – this growth is impressive. What’s more, delivery vehicles are nearly ubiquitous in our neighborhoods across the country and could also help to generate greater interest in electric vehicles among the public.

In the coming months, UCS plans to follow up its landmark 2019 report, Ready for Work, publishing additional research and analysis on early truck and bus electrification successes, opportunities, and barriers – stay tuned!

Recently, the states of Oregon and Massachusetts have proposed delaying enforcement of state truck engine emissions standards originally put in place to protect the health and welfare of their residents, standards stronger than what is enforced by EPA at the national level, and we’re seeing truck manufacturers push for even more delays around the country. The rationale for this delay is largely based on industry disinformation, with manufacturers choosing to gin up anxiety among truck dealers to wage a war on the regulations by proxy. We heard this all in full effect at recent meetings of the California Air Resources Board (CARB) and Oregon Department of Environmental Quality, where some in industry advocated for delays all the way out to 2027.

This path taken by industry is a game of chicken with the regulators, a refusal to comply with the regulations as they stand and a dare to enforce them. Below, we walk through this cynical industry action and why it’s critical that regulators hold firm in the face of this market manipulation. Lives are on the line.

Industry is compliant with state regulations and agreed not to oppose them

There are two separate state regulatory actions that manufacturers are fighting at the moment, the Advanced Clean Truck (ACT) rule, which requires an increasing share of electric trucks to be sold, and the Heavy-duty Omnibus (“Omnibus”) rule, which requires new heavy-duty engines achieve a 75 percent reduction in health-harming NO_x emissions, on average, compared to the current federal standards that have been in effect since 2010.

California is the only state in which those standards are in effect in model year 2024, and manufacturers are overcomplying with both standards at this time, thanks in large part to electric truck sales that well exceed what is required by ACT and flexibilities in the Omnibus rule that were agreed to with the manufacturers.

Truck manufacturers, however, are now throwing a temper tantrum behind the scenes in order to try to renegotiate a rule they promised to follow. Because they’ve agreed not to oppose adoption of these standards, they are waging that war by proxy, pushing dealers to oppose the regulations through lies and market manipulation. The dealers themselves made clear they are feeling the pain of these actions and are struggling to fight back against the manufacturers, embodied best in a plea from one dealer to CARB at the recent hearing to get the manufacturers to “act in the spirit of the Clean Truck Partnership agreement and stop putting politics ahead of public services.”

Truck makers are manipulating the market with draconian rules

In order to gin up anxiety among dealers, manufacturers are wreaking havoc on state truck sales by putting the burden for compliance exclusively on the backs of dealers and ignoring the many flexibilities in the regulation aimed to reduce compliance burdens. Such tactics represent a new anti-regulatory approach to compliance that seem more like a political statement than sound business strategy.

This tactic only makes sense if the goal is not to comply with the regulation but to maximize the pain felt by dealers. And, because increasing a company’s compliance costs is bad for business, this strategy is dependent upon one’s competitors also pursuing this uneconomic strategy. Incredibly, that is exactly what appears to be happening, a fact highly suggestive of collusion among the truck manufacturers.

So what exactly are they doing? Rather than working with dealers as required by the Clean Truck Partnership and as one would expect from a good faith effort to comply with the law, manufacturers are instead enforcing quotas that have absolutely no grounding in either regulation. Manufacturers are requiring dealerships to purchase a specified number of electric trucks before receiving any allotment of diesel-powered vehicles, even in applications for which there is no electric vehicle availability. This behavior, known as ratio-ing, has resulted in massive decreases in in-state truck sales, including (according to the California New Car Dealer Association) an 80 percent year-over-year decrease in Class 8 vehicle sales, the heaviest and biggest on-road vehicles. This ratio-ing behavior is not required by ACT and is instead a choice by manufacturers to manufacture a crisis and build pressure on regulators to delay pollution rules.

Importantly, manufacturers are lying to their dealers about the origin of this artificial product shortage. According to interviews with dealers and manufacturers, sales representatives are telling dealerships that limited product availability is being driven by compliance with ACT regulation. However, representatives from the same manufacturers have explicitly told regulators (accurately) they are well-situated to comply with ACT.

ACT does not require a specific share of any given application be electric—rather, compliance is based on the average of a manufacturer’s entire portfolio. This allows manufacturers to prioritize electric truck sales in the vehicle markets that are most advantageously deployed.

The voluntary decision by manufacturers to withhold sales from its dealers via ratio-ing is simply part of a strict, non-regulatory, and nonsensical business plan.

Truck makers are pursuing high-cost compliance to burden dealerships

Ultimately, it is the manufacturer that determines product availability, and it is critical to re-emphasize that the shortage felt by dealers is a crisis manufactured by truckmakers. This was reiterated by CARB at a recent meeting, and the dealers themselves confirmed this as well through their own testimony about sales restrictions. The lack of available trucks is fully within manufacturers’ control and comes directly as the result of business malpractice.

Manufacturers comply with ACT and the Omnibus through credits. For ACT, there is a minimum number of zero-emission trucks a manufacturer is required to sell—if they sell more than is required, they can bank those credits to offset future obligations, and if they fall short they need to either draw upon any bank they may have built up or purchase vehicle credits from manufacturers that have exceeded their obligations. The Omnibus works in much the same way, but with credits tallied in tons of emissions. Under both rules, there is an excess of available credits, particularly from the growing number of all-electric truck manufacturers that naturally exceed the requirements of both rules.

As we heard repeatedly during the CARB hearing, manufacturers are refusing to engage in the credit market. As in the case of ratio-ing, this artificially increases their costs of compliance but also naturally increases the pain felt by dealerships. Manufacturers are price gouging on the electric trucks they do sell, with costs nearly $90,000 per truck higher in the US than a comparable EV goes for on the European market, and then in markets where such trucks aren’t available, manufacturers are unwilling to compensate by using the flexibilities available. As Trevor Gasper of Thor Industries, an RV manufacturer that looks to truck manufacturers to supply chassis on which to build RVs, “These manufacturers are not interested in purchasing credits to assist the RV industry.”

Exiting an entire market segment because of self-imposed restrictions is certainly a choice, but it’s not a very smart one. And it’s one that flies in the face of industry sustainability commitments.

Truck makers have manufactured a crisis despite product availability

Of course, credits are meant as a temporary fallback—in the long run, it’s more cost-effective to simply comply with the regulations yourself. And in fact, that’s exactly what we see. Manufacturers have used their credit bank to buy time to supply product. While they certainly could have made some of these products available more quickly and, in some cases, have such compliant products available overseas, there is no doubt that manufacturers are preparing right now to comply without credits.

PACCAR was the first to certify its 13L heavy-duty diesel engine to the CARB 2024 standards, but Volvo introduced its own compliant engine shortly thereafter. The reason why they were able to do so is that 2024 compliance doesn’t require massive investment or timelines, as Volvo themselves noted: “Really, the D13 is the same engine on the inside. (The CARB-complaint D13) is more about the turbo and then the enhanced aftertreatment system, and the 48-volt alternator.” Cummins, the largest engine manufacturer, noted in recent comments to CARB that while they have not yet certified a diesel engine to these standards without credits, “This summer we added another engine family to our 50 mg [CARB-compliant] lineup, and we are on track for additional medium- and heavy-duty 20-50 mg engine families in 2025, 2026, and 2027.”

The question of product availability isn’t whether or not manufacturers can meet the rules on the books—it’s how they approach meeting them. And right now they are choosing to ignore all the available flexibilities that lower costs in an effort to undermine the regs themselves, punishing dealers in the process.

Tallying up the harm

If state regulators grant delays in these regulations by capitulating to this manufactured crisis, they are granting truck manufacturers exactly what they have set out to do, and they are doing so on the backs of those who these regulations were meant to protect. Every delay, every carve-out, every weakening made by regulators at the behest of industry has a direct and permanent cost on the health of residents around the country.

The table below tallies up the harm from delaying these rules, as Oregon and Massachusetts have proposed, as we continue to see industry support for similar action in other locales. There are lives at stake, as evidenced by UCS modeling.

Regulators should ensure communities benefit as intended

Industry has engaged state regulators in a game of chicken, and for the health of communities around the country, it’s critical that regulators not blink. Afterall, trucking industry disinformation is nothing new: this is just the latest example. But, if any agencies choose to weaken these rules through delay or carve-outs, they must ensure those emissions reductions still happen.

There is already a mechanism in place to do this in the Omnibus rule—as part of the Clean Truck Partnership, California negotiated an extension of a “legacy” provision that allows the sale of non-compliant engines in exchange for commensurate emissions reductions through designated projects meant to benefit disadvantaged communities, such as replacing dirty diesel locomotives with cleaner alternatives or deploying electric charging infrastructure. This is a poor replacement for compliance, but it at least makes an attempt to mitigate the harm caused directly by manufacturers, and on their dime.

Manufacturers have broken the rules with artificial caps that undermine the regulations. Regulators should hold firm on these rules to force industry’s hand, but if they’re going to fold, they better make sure industry pays for the harms caused by such market manipulations and ensure the communities suffering from diesel pollution aren’t the ones paying with their health.

In the wake of the recent election, we have already seen predictions about how the change in administration will affect various economic sectors, including the trucking industry. But whatever the various forecasts may say about the trucking sector’s future, there will remain two clear facts: 1) heavy-duty trucks and buses today adversely impact the health and well-being of communities around the country; and 2) the most surefire way to simultaneously reduce global warming emissions and the health impacts of the freight sector is through heavy-duty battery-powered electric trucks powered by an increasingly decarbonized grid.

Do you care about the lasting impacts of decisions made by your local school board about the school buses driving your kids to school? Or how rules driving electric trucks can reduce harm from future trucks? Or maybe you simply want to understand the health costs or global warming emissions of the local delivery truck you see every day?

If these types of questions are running through your head, UCS has the answers with a new tool comparing different types of trucks. Below, I walk through details of this new UCS analysis and what it says about cleaning up the freight sector. First, I walk through all the different considerations at play when considering the truck and fueling infrastructure. Next, I explain how we went about actually modeling the climate and health impacts of those truck options. Finally, I walk through how battery-electric trucks emerged clearly as the cleanest choice across the range of scenarios, and how you can use the tool.

There are a range of options for heavy-duty trucking

We’ve known for years that electric cars are always the cleanest option around the country when it comes to reducing global warming emissions from personal vehicles, but heavy-duty trucks and buses operate under much more diverse conditions, complicating things. For one thing, trucks and buses come in a range of different sizes, ranging from a heavy-duty pickup truck all the way up to a tractor-trailer. For another, they also are used in different ways, with some vehicles like school buses or delivery vans spending most of their time at low speed and stopping often, while a small portion of the largest vehicles may travel as much as 1,000 miles in a day, mainly at highway speeds.

This range of characteristics mean that the cleanest choice for one type of truck may not be the best for another, and that these choices can evolve over time. For example, the comparative advantage in energy efficiency of a compressed ignition engine used in a diesel truck as compared to a spark-ignition engine fueled with gasoline or natural gas is much greater at high loading (like in tractor trailers) compared to lower loads like delivery vans. But these trade-offs may change over time due to additional factors like fuel economy and emissions regulations.

To examine the cleanest heavy-duty truck and bus choices and how those may evolve over time, our analysis explored a a range of different vehicle characteristics:

• 8 different types of trucks of varying size and behavior: delivery van, delivery truck, garbage (refuse) truck, school bus, transit bus, drayage tractor-trailer, regional tractor-trailer, and long-haul tractor-trailer;
• 3 different powertrain types: battery-electric, combustion engine, and fuel cell;
• 6 different energy sources: gasoline, diesel, propane, natural gas, hydrogen, and electricity;
• 4 different model years (i.e. year the vehicle is purchased): 2023, 2027, 2030, 2035.

In addition to the vehicle characteristics, we also considered different energy futures. First, we considered both an electric grid consistent with today’s policies (“business as usual”), using data from the Energy Information Administration. We then also considered a grid that eliminates net global warming emissions by 2035 based on research from the National Renewable Energy Lab, using a conservative assessment of carbon capture technologies (“decarbonized grid”).

For the sourcing of hydrogen, we consider using either electrolyzers utilizing grid electricity or sourcing that hydrogen from natural gas via steam-methane reformation, which is where virtually all hydrogen comes from today.

Importantly, our analysis reflects improvements to all forms of trucks anticipated in the coming years, as new heavy-duty engine standards go into effect in 2027 and recent global warming emissions standards for vehicles continuing to push efficiency improvements across all types of trucks.

How to calculate the impact of a truck?

Once we identified the range of considerations for future new trucks, we can begin to think about the impacts of these vehicles. We considered two main impacts: total global warming emissions and total health impacts related to driving these trucks over their entire lifetime.

To estimate health impacts, we consider the impacts from the pollution generated from the use of the truck over its lifetime. These impacts include not just those from the pollution directly emitted from the tailpipe or particulate emissions from brakes and tires, but also upstream emissions related to the energy source powering the vehicle. In considering the upstream effects, we consider both the pollution generated in refining and distributing the energy (such as from a refinery or from the electric grid) as well as any extraction processes needed to obtain that fuel (i.e. pollution from oil recovery, coal mining, etc.). This pollution results in adverse health impacts ranging from lost days of school or work from aggravated asthma, to increased hospitalization for heart and lung diseases, to premature death.

We utilize EPA’s COBRA model, which uses air quality modeling and county-based population data to calculate the incidence of health problems for the trucks in question and a corresponding valuation of those impacts based on the related economic impacts. The COBRA model is exclusive to the contiguous United States, so no health impacts were calculated for Alaska and Hawaii. Additionally, the COBRA model considers two different rates of incidence for mortality related to particulate matter, or soot, leading to “low” and “high” estimates for our analysis.

It’s important to recognize that the impacts from heavy-duty trucks are location-dependent—the number of families living near fossil fuel power plants versus highways varies across the country, and we want to be sure that we are not simply shifting the health burden of our freight system from one community to another. There will also inherently be regional differences related to the power sources comprising the local power grid and how those evolve over time within a given policy environment.

Electrification is the best option in virtually every region no matter the truck or policy environment

Across every single scenario considered, battery electrification has the lowest global warming emissions…every year, every vehicle type, and in every region, even if the grid doesn’t improve beyond current policies (aka our baseline scenario).

While the story is a little more nuanced when it comes to public health considerations, battery-electric trucks still generally show the best way forward, even after 2027 when combustion trucks are expected to get cleaner under new EPA rules. In a world where no more progress is made on cleaning up the electric grid beyond today’s policies, battery-electric trucks still have the lowest impact on public health in 65-73 percent of the combination of trucks, regions, and model years considered in this analysis. And in the small number of cases where they are not the best performing option, they are not far behind, averaging only 19-22 percent worse impact. With a cleaner grid, the choice is even more apparent, with battery-electric trucks representing the best choice in 86-89 percent of all considered options, and falling behind by just 16-19 percent in the rare cases where it is not expected to be the best choice. It’s worth emphasizing here that the limiting factor here is how we’ve modeled the decarbonized grid—a grid powered exclusively by renewable energy, for instance, would be hands down the cleanest choice in 100 percent of cases. These data are simply meant to be illustrative to help frame the choices faced in attempts to clean up the freight sector.

No other choice comes close to battery-electric trucks at offering the same level of emissions and public health benefits. In the few cases where battery-electric trucks don’t have the lowest health impact, hydrogen fuel cell trucks were found to be the top choice, but such trucks will emit, on average, more than 3 times the global warming emissions over their lifetime than a battery-electric truck. This number increases to up to 13 times more, on average, when comparing a battery-electric truck fueled by a decarbonizing grid to a hydrogen fuel cell truck whose hydrogen is derived from natural gas, as is the case for virtually all hydrogen used today.

Don’t just take my word for it

Of course, me summarizing the analysis is not nearly as fun or educational as looking at things for yourself. And that is the entire reason we developed this tool—with so many choices and a trucking industry that would rather spend money on an astroturf site for misinformation to delay action than actually solve the harm caused by the freight sector, it can be difficult to sift through the noise.

Here are some examples of how this tool could be used:

• Are you a parent wanting to know what the lasting climate impacts are of their public school district locking in fossil fuel emissions from new propane school buses?
• Do you live near a freight hub and want to quantify how your truck counts translate into public health harms?
• Do you live in a state that is considering the Advanced Clean Truck rule and need to convince folks of the climate benefits at stake?
• Are you a fleet manager trying to argue for how cleaner trucks will improve your company’s carbon footprint?

Now more than ever we need advocates prepared with the best available data to advocate for the cleanest solutions for their communities. We need to be making decisions that address sustainability and public health now and in the long-term.

Download the full methodology for the UCS Clean Truck Map Comparative tool.

Have questions about the UCS Clean Truck Map Comparative Tool or want to share how you’ve used it to advocate for cleaner transportation choices? Let us know!

Decades of government vehicle standards to improve vehicle efficiency and cut down on tailpipe pollution have saved car and truck drivers trillions of dollars at the pump, saved countless lives from reduced exposure to toxic air pollution, and avoided the extraction and burning of billions of barrels of oil. 

On its first day in office, the Trump administration has indicated it wants to send the latest versions of these effective standards to the trash heap, issuing a directive to regulatory agencies to suspend, revise or rescind regulations inconsistent with the new national policy of “ensuring a level regulatory playing field for consumer choice in vehicles.” In other words, if a regulation mentions “electric vehicles,” it’s probably on the target list. Agencies will have 30 days to compile a list of offending regulatory actions, which are sure to include federal rules that would reduce pollution from new cars and heavy-duty trucks sold through 2032 and to undermine California’s clean car standards which are effective through 2035.   

The executive order also attacks clean vehicle incentives and federal support for electric vehicle charging stations, important complementary policies helping families around the nation make the switch to cleaner vehicles.

What’s at stake? Our health, some of the largest climate actions in US history, and more

Transportation is the largest source of US climate emissions, so it’s not surprising that undermining recent Environmental Protection Agency (EPA) actions targeting climate emissions from cars and trucks will be a major setback in meeting climate targets. But that’s just the tip of the iceberg.

In the US, automakers are subject to vehicle standards set by both the federal government and California.  California is allowed to set standards stronger than the federal government under the 1970 Clean Air Act provisions in recognition that California, and many other states which have adopted CA standards, serve an important role as laboratories of innovation controlling air pollution in novel ways. President Trump is targeting both federal and California vehicle standards in his recent executive order—standards that not only reduce climate emissions but also slash air pollutants like nitrogen oxides and particulate matter. Undermining these rules will have major negative environmental, health, energy, and consumer impacts. A number of standards covering different types of vehicles and emissions have been updated and finalized during the Biden Administration’s term. If rolled backed, the enormous health, climate, and consumer benefits of these rules would be reduced or completely eliminated.

Vehicle standards likely to be targeted include:

NHTSAs Corporate Average Fuel Economy (CAFE) standards—In addition to EPA’s passenger vehicle standards, complementary but separate fuel economy standards targeting improvement in miles per gallon efficiency were also updated and finalized by the National Highway Traffic Safety Administration (NHTSA) in June of 2024. These standards are also under threat by the Trump administration, which has falsely labeled them as an “EV mandate.” In reality, NHTSA is prohibited by law from considering or requiring the adoption of alternative fueled vehicles, like EVs, in setting CAFE standards. Rolling back these commonsense standards would increase fuel costs by $23 billion, increase gasoline consumption by 70 billion gallons through 2050, while adding more than 700 million metric tons (CO2e) of climate pollution, according to NHTSA.

Federal Heavy-Duty Truck Standards—Heavy-duty commercial trucks are the second largest source of transportation climate emissions behind passenger vehicles. In March of last year, EPA finalized the “Phase 3″ Greenhouse Gas Emissions Standards for heavy-duty vehicles that would reduce pollution from new trucks between model year 2027 through 2032.

These rules are expected to result in more than $13 billion in net societal benefits coming from a combination of avoided hospitalizations and illness like asthma attacks, and climate impacts. The Phase 3 standards alone are expected to result in annualized net savings to truck owners and operators of more than $2 billion as a result of lower operating costs from lower emission diesel and gasoline trucks as well as electric trucks. 

These new standards are more than feasible and, as UCS pointed out during the rulemaking process, don’t take full advantage of the fuel saving and zero emission technology available to reduce truck pollution. But they are an important step forward and rolling them back will result in more pollution, more illness and hospitalizations, and higher costs for industry and consumers.  

California’s clean cars leadership at risk

In addition to targeting federal rules, the Trump Administration is also targeting California’s leadership on clean cars and trucks. California is allowed under federal law to set standards for cars and trucks that are equal to or stronger than federal standards and has exercised this right for more than 50 years. Other states have the ability to adopt these more health protective standards and more than a dozen have.  

The last Trump administration attempted to withdraw a previously approved waiver for California to implement its standards for light-duty vehicles and it appears positioned to do so again with waivers approved by the Biden Administration’s EPA on the chopping block. The two most significant rules under threat are the Advanced Clean Cars II (ACCII) regulation—and the Advanced Clean Trucks (ACT) rule. The ACCII rule gradually ramps up new vehicle sales requirements to 100% by 2035. This rule is often mischaracterized as a gasoline vehicle ban, when in actuality, 20% of sales could be plug-in hybrid vehicles which have a gasoline combustion engine, but can travel some distance on electric power. ACT on the other hand requires manufacturers of heavy-duty trucks to sell an increasing share of zero-emission trucks with annual targets that vary based on the different sizes and types of trucks and is the driving force for clean truck manufacturing and deployment across the country.

California’s requirements for passenger cars and heavy-duty trucks have been more aggressive in pushing deployment of zero-emission vehicle technology and instrumental in expanding the electric vehicle options currently available today to car buyers and trucking fleet owners all around the country. Evidence of California’s leadership is widespread: more than 25% of new passenger vehicle sales in the state are electric, gasoline consumption is declining, and electric truck sales are on the rise. California is demonstrating that slashing climate and air pollution from cars and trucks is possible, and it’s unique authority under the Clean Air Act provides other states to follow it’s lead if they choose to.

Attacking CA’s ability to implement its standards will have lasting consequences—not just for the golden state, but for all the states looking to protect their residents from vehicle pollution and ultimately the nation as consumers across the country have fewer clean vehicles to choose from.

These rules work! Vehicle efficiency is at an all-time high—thanks to common-sense vehicle standards

It’s hard to overstate the importance of standards in making progress in making real world impacts on reducing air pollution, cutting climate emissions, and reducing petroleum use. Sure, auto industry innovation is rarely standing still, but history has demonstrated that safety, efficiency and pollution innovations don’t deliver without standards in place

A quick glance at average fuel economy of new vehicles over the last 50 years illustrates this clearly. Fuel economy standards were first established in the 1970s and average new vehicle miles per gallon (mpg) increased significantly. For the next two decades standards barely budged – fuel economy got worse but auto industry kept on innovating away. Finally, with new standards in place in the late 2000s auto companies were compelled to make improvements across the board, with average new vehicle fuel economy now approaching 30 mpg.

Vehicle standards have given consumers more choices, while saving them money at the pump

When Americans head to their local dealership to seek out a new or used vehicle, standards and regulations that automakers have to meet are very likely not top of mind. But the impact of these rules are clearly evident on the lot.

Consumers now have the option to choose pick-up trucks with 20-plus miles per gallon ratings, hybrid vehicles with 50 mile per gallon stickers, and plug-in electric vehicles. These options have all been spurred by standards and that ensure all automakers are moving toward a cleaner, healthier future, the nation is less vulnerable to global oil price shocks, and consumers pay less at the pump. The Trump Administration’s actions will take us backwards on all of these fronts.  

A gift to oil companies sure, but also to US automakers’ international competition

The only beneficiaries from this proposed action to rollback standards are the oil industry and America’s auto industry competitors who will continue to gain global market share as US automakers fall behind. It comes as no surprise that President Trump is happy to hand out a present to the oil industry—he allegedly promised he would in exchange for campaign contributions in May of last year. And President Trump’s allies appear to be thanking him with an advertising campaign.

More worrying for the US auto industry is the decline in US automaker global competitiveness. Being at the forefront of technology innovation helped US automakers be competitive abroad. But global competition is heating up and US automakers are already behind. The combination of standards, consumer incentives, and investments in manufacturing, domestic supply chains, and EV charging infrastructure contained in the Inflation Reduction Act and Bipartisan Infrastructure Law are a historic investment in the future of the U.S. auto industry. Yet all of this is now at risk – and somehow eliminating all of these investments and standards is characterized as good for the auto industry. You might think automakers understand this and would resist changes to rules that provide the benefit of regulatory certainty over the next several years. But their long history of resisting regulation (well documented in our Time for a U-Turn report) suggests the temptation of weaker rules is just too great.   

Is this time any different than the last time President Trump did this?   

These new attempts to rollback standards might all sound more than vaguely familiar. In 2017, the Trump administration took similar actions, with EPA revisiting a previous determination that passenger vehicle standards through 2025 were appropriate. In an about face, EPA under Scott Pruitt determined that they should be made less stringent, ignoring ample evidence that the standards were not only feasible, but positive for consumers as well as jobs and the environment. (My colleague Dave Cooke wrote about this in his blog, “EPA Rolls back fuel efficiency standards at the request of automakers”)

Ultimately, EPA proposed new standards despite their regulatory analysis clearly showing that the weaker rules would cost consumers more and lead to increases in premature deaths from increased air pollution. Though it took nearly President Trump’s entire first term, the rule rollbacks were ultimately finalized in 2020. Even many automakers were frustrated and ended up making separate agreements with California to comply with more ambitious targets. Over 175 members of Congress spoke out against these rollbacks. And the early part of the Biden administration was spent clawing back some of the benefits lost through President Trump’s rollbacks.

This time around, there is more at risk. Climate change is accelerating and the impacts on our daily lives is becoming all too clear as climate-fueled disasters occur on a regular basis. The longer we take to reduce emissions, the higher the cost. The administration may also try to move more quickly this time. 

What happens next?  

While the Administration would likely prefer to make these rollbacks effectively immediately, legally they can’t and the recent announcement is only the beginning of a process. EPA and NHTSA will need to justify any actions to modify their rules, including an opportunity for public input. And the incoming administration doesn’t have the legal authority to rescind or revoke the waivers already granted to states to protect their residents. 

Just as we were last time President Trump targeted common sense climate, public health, and transportation policies, UCS will be there every step of the way. UCS provided evidence supporting the benefits of retaining strong standards, highlighted the ways in which the administration’s rollbacks would harm the public and supported successful state efforts to blunt the impact of federal rollbacks. We are again ready to track, debunk, and fight this attack on bedrock health and climate protections and will make it hard for the administration to ignore the facts.

And we need your help. Join the more than 50,000 people who have already signed our open letter to Congress to protect independent science and support science-based decision making. By signing the petition, you will also get notified about future actions and opportunities to protect important clean transportation policies in the coming months.

At certain times of year (the holidays, back-to-school week, Amazon “Prime Day”), my neighborhood can feel like package central, with trucks from UPS, FedEx, and the post office making multiple trips a day. But there’s no comparison to neighborhoods closer to major nodes in the freight system. Take the intersection of South Ashland Avenue and West 35th Street, in the McKinley Park neighborhood of Chicago, where homes sit across the street from an Amazon warehouse, and where people walking to nearby parks, schools, and churches contend with traffic from several freight facilities. On one day in June 2023, 4,084 trucks and buses rolled through the intersection, according to data collected by the Little Village Environmental Justice Organization and the Center for Neighborhood Technology—with one passing through every 10 seconds during the busiest parts of the day.

Our freight system is a complex web of logistics. A typical online purchase (like the new bathtub stopper I bought online this month) might follow a journey like this:

1. Long before I ordered it, the item traveled on an international container ship which docked at a US seaport.
2. Its container was taken off the ship, probably onto a drayage truck (a truck which makes short trips between the port and facilities where cargo is moved onto other vehicles). At some ports, trains fill this role as well.
3. From there, the container moved onto a trailer truck or freight train for a trip of a few hundred miles to a local distribution center (if it was on a train, it probably moved to a truck for the last leg of this trip).
4. At the distribution center, workers opened the container, sorted its contents, repackaged my bathtub stopper, then put it on a delivery van to be dropped off on my front porch.

This network can feel almost miraculous at times—but it comes with a harmful side. Freight has an outsized impact on human health and the climate. Medium- and heavy-duty vehicles (which include the heaviest pickup trucks and vans as well as commercial trucks and buses) make up just over one of every ten vehicles on the road, but are responsible for over half of smog-forming and fine particulate pollution and nearly one-third of climate warming pollution from on-road vehicles.

The pollution from these vehicles is responsible for over 4,400 premature deaths every year, as well as thousands of emergency room visits and millions of lost school days. It is concentrated in neighborhoods like McKinley Park, which sits near e-commerce warehouses, highways, and railyards.

For decades, community groups—especially those in the environmental justice movement—have fought for a cleaner freight system. Andrea Vidaurre, a co-founder of the People’s Collective for Environmental Justice (in California’s Inland Empire), has put it this way: “What ends up in your stores and online shopping carts has to come through neighborhoods like mine first, and before it comes to my community it passes through many others worldwide completely powered by fossil fuels.”

UCS has also worked for many years to clean up trucking pollution, and our work now encompasses other parts of the freight system. There are tools, technologies, and policies that can reduce impact at almost every step in the process—from the moment a shipment arrives at port to the day a package is ultimately delivered to your porch or package room. Here’s what governments can do.

Cleaning up the ports

Nearly 80% of cargo entering the U.S. does so through seaports, the largest of which are massive operations. In a typical day at the Port of Los Angeles, for example, over 12,000 containers of freight are unloaded from cargo vessels (a similar number are also loaded onto ships for export). These containers are offloaded onto “drayage” trucks which make repeated trips between the port and nearby distribution centers or storage yards, where the cargo is loaded onto trucks or trains to continue its journey.

All of this activity makes ports surrounded by dangerous levels of air pollution. Since at least the early 2000s, community leaders and healthcare professionals have referred to the area around the Ports of Los Angeles and Long Beach as a “diesel death zone.” The port is a major contributor to poor regional air quality, which the South Coast Air Quality Management District has said leads to over 1,600 premature deaths per year.

Similar issues arise around “inland ports” where rail lines and trucking routes intertwine to form massive interchange areas. Children attending school near the San Bernadino Railyard, a major facility where cargo moves from trains to trucks, were more likely to use inhalers and suffer from chronic cough and impaired lung function, compared to students at a school seven miles west. As one community member told researchers, “When the weather is the hottest, that is when we have the most kids that are sick, with little kids getting sick with a horrendous cough, like a smoker’s cough.”

The concentrated pollution around ports demands concentrated solutions, such as:

Targeted grants: The Inflation Reduction Act, passed by Congress in 2022, included $3 billion for a Clean Ports Program run by the Environmental Protection Agency. Last December, that funding was announced—a surge of support for projects like electric cargo handling equipment and vessel shore power (electrical connections so that docked ships don’t run diesel engines to power their lights, climate control, and other systems).

In the Bay Area, UCS has worked closely with the West Oakland Environmental Indicators Project and other partners to identify the need for improved air quality. We were ecstatic to see these efforts pay off in a big way through the Clean Ports Program. Among the grants, the Port of Oakland, WOEIP, and other groups were awarded over $320 million to deploy nearly 500 zero-emission drayage trucks, build out charging infrastructure for trucks and cargo equipment, expand local air quality monitoring, and support enhanced community engagement.

Though the Clean Ports Program awards were a one-time infusion of funds, other federal programs can keep up the momentum. The U.S. Department of Transportation administers a Charging and Fueling Infrastructure program, for example, that has supported zero-emission drayage truck charging in Washington State, California, and Nevada.

Zero-emission drayage: Drayage trucks, which make repeated short trips between the port and nearby cargo facilities, are ripe for electrification. Ports and governments can facilitate the change through incentive programs, charging a per-container fee on polluting drayage trucks, and taking advantage of federal and state grants. The Port of Houston (to name one example) is using Federal Highway Administration funding to purchase clean trucks.

A cleaner regional and long-haul trip

The next step in the cargo journey generally involves being hauled close to its final destination. Whether this is a regional journey (most cargo travels less than 250 miles) or a cross-country long haul, it is most likely to be in a truck.

This makes battery-electric trucks one of the most important technologies we have to clean up the freight system. As my colleague Dave Cooke explained last month, battery-electric trucks beat out the alternatives when it comes to climate emissions. In nearly every state, replacing diesel trucks with battery-electric would sharply reduce health-harming pollution—with the benefits improving as electric power moves to cleaner sources.

Companies are increasingly putting battery-electric tractor trucks to work. Pepsi, for example, deploys dozens of electric tractor-trailers in Northern California, some of which take beverages up to 450 miles from a facility in Sacramento.

Pollutant and zero-emission truck rules: Two sets of rules require truck engine manufacturers to sell an increasing number of cleaner vehicles. The EPA requires new trucks to emit fewer greenhouse gases and health-harming pollutants than existing models. California has passed rules that target the same pollutants, but go beyond federal requirements.

Regional and national truck charging networks: For long-haul truck electrification to take off, the U.S. needs a robust network of charging sites where truckers could refuel their vehicles (probably at the same time that they take legally required rest breaks,).

Most of these sites are likely to be privately funded, but governments can do a lot to speed up the creation of this network. Federal scientists have driven progress toward high-speed-charging technologies that can refuel large battery-electric trucks in 30 minutes. Where the need for heavy-duty vehicle chargers can be reasonably foreseen, utilities can proactively build out their grids. The federal government has proposed a national “freight corridor strategy” outlining where it believes zero-emission truck infrastructure is needed first. Federal grants have also served as a down payment toward this system, funding (for example) battery-electric truck charging hubs in Illinois and along the I-95 corridor in Connecticut, New Jersey, Delaware, and Maryland.

Cleaner locomotives: Nearly seven percent of cargo moves via freight rail, and while rail is generally more climate-friendly than trucking, it contributes significantly to public health problems in communities near railyards.

The freight rail industry has stymied attempts to clean up locomotives, abusing loopholes in federal regulations. New locomotives must be built to “Tier 4” standards which make them less polluting than older trains, but rail companies have systematically evaded the rule by “remanufacturing” old, high-polluting locomotives instead of buying newer, cleaner models. The majority of trains in service use technology—and adhere to pollution standards—that are decades behind the times.

Environmental justice leaders (under the banner of the Moving Forward Network) had called on the Biden administration to not just close the loophole but to go beyond, given that even the Tier 4 standard is over a decade old and technology has continued to advance. California had also sought to go beyond weak federal regulations, passing an “in-use locomotive” rule that would require trains to operate in zero-emissions configurations within the state. The EPA did not take action on either request, not granting the waiver needed for California to enforce its rule and not issuing new locomotive standards (the chances of either happening under a Trump administration are slim), but the needs remain.

With enforcement of California’s locomotive rule uncertain for now, Congress can still take action. Last month, UCS stood with Senator Ed Markey of Massachusetts to support the “All Aboard Act,” which would improve both passenger and freight rail in the country, including funding to electrify freight railyards.

Cutting pollution from warehouses and delivery routes

The second-to-last stop in a package’s journey is often the distribution center, where goods are sorted and packed for delivery. These warehouses have grown significantly with the rise of e-commerce, becoming major concentrations of pollution. Warehouse construction has accelerated since 2010, and new ones tend to be larger “mega-warehouses” with more loading docks and parking spaces. They also are more likely to be clustered together, with some neighborhoods impacted by multiple new warehouses.

“All that carbon, diesel, black smoke, it’s everywhere in our community and we can’t escape it … We want to make sure every resident and ward in the city of Newark has a right to breathe clean air.” Kim Gaddy, the director of the South Ward Environmental Alliance in Newark, New Jersey, told a reporter in 2022. A quarter of children in Newark have asthma, and this asthma is a leading cause of absenteeism in schools, according to a report from Advocates for Children in New Jersey.

A NASA-supported study helps show the national impact. Using data from satellites, a team of scientists found that levels of nitrogen dioxide (which causes respiratory illness) were, on average, 20% higher near warehouses—and that warehouses are located in neighborhoods which tend to have more residents who are Black, Latine, Asian, or who identify with at least two races.

Potential solutions include:

“Indirect source” rules that require warehouse owners to reduce the impact of their facilities: One of the most promising ways to address the issue is by requiring warehouse owners to take responsibility for their impact.

In Southern California, large warehouse operators are now required to adopt plans to cut or mitigate pollution from their facilities—through measures like acquiring zero-emission trucks, installing on-site electric-truck charging infrastructure, and installing air filters at nearby schools, daycares, and hospitals. UCS and local advocates are looking to win a similar rule in New York, the Clean Deliveries Act.

(These rules are sometimes called “indirect source rules,” and are legally defined as such in the federal Clean Air Act. This is because trucks are the direct source of most pollution near warehouses, but the warehouse is the reason so many trucks are concentrated in one area—and thus, the warehouse is the “indirect source” of pollution.)

Clean delivery vehicles: The federal and state vehicle regulations I mentioned earlier all apply to delivery trucks and vans as well. UCS analysis of these rules suggests that, together, they could result in as many as 250,000 zero-emission “light heavy duty” vehicles like delivery vans on the road. Delivery vehicles are currently leading the way on electrification, in part because their business case is so clear. Daily routes are typically under 100 miles (well within the range of current vehicles), and charging can take place at centralized distribution centers, sometimes while the trucks are being loaded.

Curb management and land use: Finally, it’s worth noting that in cities, carefully considered curb and freight regulations can further reduce the impact of deliveries. New York City, for example, is incentivizing night deliveries (which reduce traffic and idling) and even building infrastructure to support the use of electric cargo bikes for “last mile” delivery.

Fighting for a freight system that works for everyone

You may notice that several of the programs and rules I describe above were only passed in the past few years. That speaks to a historical lack of urgency from government in addressing the harms of the freight system.

As Paulina Vaca of Center for Neighborhood Technology (one of the groups counting trucks in Chicago) told media last year, grassroots truck counts “weren’t taken seriously by the [Chicago] Department of Planning,” prompting advocates to contract with a professional traffic analysis firm which used cameras and computer analysis to produce “more systematic” research.

UCS has been proud to be part of Moving Forward Network and work with many of the local groups noted here to bring additional analysis into the conversation, increase the pressure, and ultimately win the rules, laws, grants, and commitments that can make the freight system cleaner and safer.

Several of these are already under attack by the Trump administration. The White House is attempting to roll back federal vehicle regulations and states’ ability to limit pollution from cars and trucks, it has ordered an illegal pause in federal funding that could delay or upend some of the programs described above. These come on top of direct attacks on immigrants and environmental justice programs, impacting many of the communities that bear the brunt of our freight system.

With our partners, we are defending against these attacks. And when it comes to transportation, we’ll be pointing out that states, local governments, and port districts retain a lot of power to clean up the ports, warehouses, and trucks that bring cargo from around the country and world to our homes and businesses. When led by experts within impacted communities, lawmakers and public agencies can take real action to address the harms of an expanding freight transportation system.

If you’ve read any of my blogs so far, you’ve probably caught the gist of why accelerating the switch to cleaner on-road freight is critical to both improving air quality in areas struggling with the impacts of truck pollution and reducing climate-warming pollution from our transportation system. Yes, zero-emission trucks (ZETs) are ready for work and are being deployed in greater numbers each year, but this growth couldn’t have happened without parallel growth in the availability of these vehicles.

Not even a decade ago, ZETs – trucks that emit no tailpipe pollution – were largely concept vehicles deployed in limited circumstances and locations. However, these cleaner, more efficient, cost-effective workhorses are on the road in every state across the nation today. In fact, it’s likely that you’ve seen a ZET on the road, if not had a package delivered to your house by one.

This growth has been impressive, but it didn’t happen in a vacuum.

Regulations like California’s Advanced Clean Trucks rule (ACT) have been key to driving increased ZET model availability and deployment in the early years of on-road freight electrification and will be crucial to accelerating this in the coming years. ACT sets clear market signals for manufacturers building ZETs, utilities and businesses developing charging infrastructure, and the supply chain industry creating the components that enable this work.

ACT requires manufacturers to gradually increase share of clean trucks sold

After several years of working with a wide range of stakeholders from organizations like UCS to truck and bus manufacturers, the California Air Resources Board (CARB) adopted ACT in 2021. To date, 10 other states have also adopted the rule. ACT’s timeline began in California last year and has come online in five additional states as of this year. The remaining five states will implement the rule over the next two years.

The rule itself is pretty straightforward – it requires manufacturers who sell medium- and heavy-duty vehicles (MHDV) in these states to gradually increase the share of zero-emission truck and bus models sold through 2035. The rule does not place any requirements on consumers to purchase ZETs, does not prohibit anyone from operating combustion-powered trucks, and does not apply to truck dealerships, despite some misleading information from bad actors meant to undermine the rule.

ACT Zero-Emission Truck Sales Percentage Schedule

Some have expressed fear that the Trump administration may try to dismantle the rule by attempting to revoke the waiver EPA granted to California to begin enforcing the rule. While this may be a reasonable conjecture based on this administration’s previous actions and his recent executive order targeting California’s authority to reduce pollution from automobiles, truck manufacturers entered into an agreement with California in 2023 committing to comply with ACT regardless of any legal outcomes at the state or federal level. Additionally, the manufacturers also agreed to only sell zero-emission models in California after 2036.

ACT provides flexible and feasible compliance pathways for manufacturers

Like other clean vehicle standards, compliance under the ACT is determined by a credit system.

Here’s the gist: Manufacturers are required to sell a certain percentage of ZETs among their total vehicle sales for each year, guided by ACT’s ZET Sales Percentage Schedule (see table above). ZET sales generate a certain number of credits for a manufacturer based on the number and types of new vehicles they sell each year. Manufacturers who sell more ZETs than their annual requirement generate surplus credits that can be traded or sold to manufacturers who did not meet their annual requirement.

However, there’s a key flexibility in the way compliance under the rule is measured.  Manufacturers are allowed to meet their obligations over three consecutive years – this gives manufacturers additional time to prepare as the rule is first implemented in different states and make adjustments as the market for ZETs matures. This flexibility in timing is in addition to the four years manufacturers have had to prepare between the rule’s adoption and implementation in each state.  

The rule also allows manufacturers to bank credits generated from ZET sales that occurred before the rule goes into effect. In California, for example, by 2023, manufacturers had already sold enough ZETs in the state to meet their 2024 requirements. Other states are likely to have met their requirements early as well. In Washington, ZETs represented about 10 percent of 2023 registrations of new MHDVs.  

ACT is accelerating the availability of clean trucks at a critical time

By increasing the share of ZETs truck manufacturers are required to sell, ACT helps to expand the market for ZETs and drives down the upfront cost of these vehicles. This, in turn, will accelerate the deployment of ZET, allowing fleets to access the significant fuel and maintenance savings they deliver – estimated at around one-third of the per-mile cost of comparable diesel trucks. Fleets across states that have adopted ACT are expected to see billions of dollars in net savings over the next 25 years (see estimates for different states here).

The market is already moving toward ZETs, but ACT is set to significantly accelerate this transition, as well as the charging infrastructure to support these vehicles. In New Jersey, for example, ACT is estimated to increase the share of ZETs on the road in the state to around 16 percent in 2035, compared to less than one percent in the absence of the rule.

Upcoming UCS analysis shows that ZETs are being deployed in states that have adopted ACT at rates significantly greater than states that have not, suggesting that the rule has had meaningful positive impacts even before going into effect in most states. Again, ACT is all about creating clear market signals – and it appears to be working quite well.

This accelerated transition to cleaner on-road freight is vital to reduce harmful air pollution generated from trucks, given that they’re the largest source of ozone-forming nitrogen oxides (NOx) pollution in the nation and the largest source of lung-damaging fine particulates from vehicles on the road. Neighborhoods close to high volumes of truck traffic from ports, warehouses, and the like, bear the brunt of these negative health impacts.

Medium- and heavy-duty vehicles are the largest source of NOx pollution in the United States. These vehicles continue to be significant drivers of sickness from exposure to transportation pollution, particularly in areas adjacent to ports, warehouses, and freight corridors. EPA 2024

Additionally, emissions of climate-warming greenhouse gases from trucks are on the rise, up nearly 80 percent in the past 3 decades compared to a less than 10 percent increase among light-duty passenger vehicles. This is largely because efficiency improvements among light-duty vehicles have far outpaced that of MHDVs and the amount of goods transported by our on-road freight system has increased significantly in the age of e-commerce. Electrifying on-road freight is crucial to achieving not only healthy air for us today, but also a vital part of the work toward a healthy and habitable planet in the future.

ACT is a foundational part of a more sustainable future not only for people and the planet, but for the fleets that move our goods each day. Regulations like this create a clear and feasible path for manufacturers to sell cleaner, more efficient, cost-effective vehicles that keep our economy moving while reducing harmful pollution.

California’s Advanced Clean Car II (ACCII) regulations are set to go into effect starting with model year 2026 vehicles. These rules include requirements that automakers provide Zero Emission Vehicles (ZEVs) for sale in California in increasing volume through 2035.

In the last few weeks, there has been a flurry of misleading information about how these rules work and the ability of industry to meet them. Some in the auto industry are acting as if these rules are a surprise. This is disappointing, as these ACCII rules were under discussion since 2020 and are the natural extension of ZEV rules that were first adopted in 1990. Automakers have had extensive notice of the rules and some of the traditional automakers had ZEVs make up over 30 percent of their California sales.

However, there is also a long history of the auto industry resisting change by claiming that regulations are an existential threat to their business. In 1970, Lee Iacocca, then Ford’s executive vice president, said that the Clean Air Act’s limits on tailpipe pollution “could prevent continued production of automobiles” and “do irreparable damage to the American economy.” Now 55 years later, the same type of arguments are being recycled to attack California’s ACCII standards.

The truth is that standards can be met, and with fewer sales than the opponents of ACCII claim. Auto companies that are actually offering consumers attractive EV options are well positioned to comply with the regulation, and Tesla’s slowing sales are masking the growing EV sales from other manufacturers. California’s clean car rules will save drivers money at the pump, slow the damage from climate change, and reduce exposure to harmful air pollution for everyone in the state. We can’t let the laggards in the auto industry prevent the state from moving forward with better transportation options than burning gasoline and diesel.

What is the actual ZEV sales requirement?

The automakers’ true ZEV sales requirement for model year 2026 is between 9 and 30% of their sales, and some of that requirement can be satisfied with plug-in hybrids that have gasoline engines. The range in the requirement is because the ZEV regulation has significant flexibility built into the sales requirements: automakers can use past credits for compliance, participate in early action and pooling provisions, and use plug-in hybrids to reduce the number of fully electric vehicles required. The exact requirement will depend on how a manufacturer decides to use these flexibility provisions.

Using only the past credits and 2026 plug-in hybrid sales would allow an automaker to meet the 2026 sales requirements with as little as 2 percent fully electric ZEV sales. Most automakers have a significant excess of ZEV credits in the current program and would be able to offset a portion of the 2026 requirement. Not all automakers will likely use all the past credits in the first year (2026), but even spreading out the credits over the first 5 years would reduce the total 2026 requirement to less than 30 percent ZEVs and only 23% would need to be battery electric (BEV) or fuel cell electric vehicles (FCEV). And any automaker that doesn’t have sufficient existing credits are allowed to buy credits from other carmakers. With the vast oversupply of old credits, there are a number of potential sellers for any automaker that is currently not meeting the ZEV requirement.

Supply and demand

One common complaint from those lagging behind in ZEV sales is that demand for EVs is low. But buyers can’t purchase EVs that aren’t for sale. The fact that only 5 percent of Honda sales in California were ZEVs in 2024 is much less an indicator of demand as it is of supply of ZEV models by Honda. Last year, Honda offered an array of models of gasoline cars and SUVs for sale, plus a pickup truck and minivan but only one BEV model. And that one BEV was actually manufactured by General Motors. In 2022 and 2023, Honda effectively offered no EVs at all in California. Buyers showing up at Honda dealerships are seeing an automaker that has little to offer in EV options or distinctive technology and no track record of EV manufacturing. Why would we blame the shoppers for the lack of Honda EV sales?

Contrast Honda’s lack of effort with that of Hyundai. Over 30 percent of Hyundai sales in 2024 in California were fully electric EVs and plug-in hybrids. Shoppers at Hyundai brand dealerships in 2024 had 3 battery electric options, 2 plug-in hybrids, and 1 fuel cell EV to pick from. And buyers likely have more confidence in an automaker that has been selling EVs in increasing numbers for several years and has more models coming soon.

Automakers like Honda and Toyota that offer paltry EV options will have trouble meeting the ZEV requirements if they continue down the road they are on. But automakers and dealers shouldn’t blame consumers for not buying EVs that they haven’t made and aren’t offering to shoppers.

Tesla’s downward trend is masking increasing EV sales from other carmakers

Overall, EV sales in California in 2024 were essentially unchanged from 2023 (441,000 in 2023 and 443,000 in 2024). However, the overall sales figures mask a significant change happening in the market. Sales leader Tesla’s sales are down 11 percent year-over-year, while EV sales for the rest of the industry are up 13 percent over the same span. Tesla’s decline is likely due to factors unrelated to interest in EVs in general. Tesla CEO Elon Musk’s high-profile support for Donald Trump and his likely illegal activities in the new administration are almost certainly causing many in Democratic-leaning California to avoid Tesla, especially now that there are many other options available. Having people put bumper stickers on their Tesla EVs saying that they regret their purchases is a bad sign for the company and not the kind of publicity any manufacturer would want.

But even beyond the actions of Musk, Tesla has a small number of models and has been slow to update their lineup. Their most recent debut, the Cybertruck, is polarizing and doesn’t appear to be selling in high volumes. And one of the company’s key advantages over other EV makers, its charging network, has been opening up to drivers of other EV models. Two years ago, the only way to get access to the top-rated Tesla charging network was to buy a Tesla, but now many different brands are offering that same access.

The ACCII and ZEV regulations are important to keep us on track to reduce emissions, air pollution

While there are some companies that see the long-term gains for moving from gasoline to electricity and are leading the transition, the ZEV regulations are critical to ensure that the entire industry moves in the right direction. Companies like Honda and Toyota shouldn’t be rewarded for dragging their feet and ignoring regulations like ZEV rules that have been developed over the course of decades.

The ACCII regulations, which include the ZEV rules, have economic benefits for drivers and reduce air pollution for everyone in the state. That’s why it’s important that we continue to make this transition now.

The boom in e-commerce over the past few decades has profoundly changed the way we shop, consume, and go about our daily lives. For many of us, long gone are the days when we wait days or weeks for a product to arrive in the mail or at a local store. Today, it may seem odd for a product to take more than 48 hours to reach our stoop or mailroom.

While the shifts in freight systems in response to the boom in e-commerce have led to many efficiencies, they have also influenced a significant rise in the number of new mega-warehouses—crucial hubs in this new system of freight and commerce, but magnets for highly polluting heavy-duty trucks and freight equipment. In our current fossil-fueled freight system, the cost for convenience spans far beyond membership fees for expedited deliveries. Exposure to pollution from heavy-duty vehicles results in thousands of premature deaths and nearly $100 billion in monetized negative health impacts each year, according to UCS modeling.

As our freight system has evolved to meet the demands of consumers, it must also evolve to address its impacts on public health and the planet. One strategy, called Indirect Source Rules or “ISRs,” is a promising solution to reduce pollution around freight hubs and resulting negative health impacts to nearby communities and the planet.

Today’s mega-warehouses facilitate and attract increased freight pollution

To facilitate this boom, more and more sprawling warehouses have popped up around the nation. These facilities are largely concentrated around areas with existing logistics infrastructure—ports, railyards, and the like. Between 2010 and 2021, not only did the frequency of new warehouse construction rise, but the size of these new warehouses increased by nearly 150 percent compared to the norm. Where the size of new warehouses typically hovered around 35,000 square feet since the 1980s, the warehouses of today are often nearly three times the square footage. These larger new warehouses facilitate significant increases in on-road freight activity and have upwards of four times the number of loading docks than those constructed before the e-commerce boom.

The increase in loading docks is of particular importance when looking at the air and climate pollution impacts from warehouses. Although warehouses themselves are often not significant sources of air pollution, they attract high concentrations of heavy-duty trucks, which are the nation’s largest source of nitrogen oxides, a key contributor to ground-level ozone pollution. Additionally, heavy-duty trucks are responsible for over half of fine particulate pollution emitted from on-road vehicles as well as a growing share of climate-warming emissions.

ISRs, however, can create opportunities to reimagine the pollution catalysts of e-commerce into solutions for air pollution and climate change—the ever-increasing number of loading docks can now be fast-charging stations for electric trucks and the ballooning footprint of warehouses present opportunities for solar energy generation and battery storage.

Addressing pollution from warehouse operations

The clearest way to reduce harmful pollution from our freight system is by electrifying trucks. Even when considering their fuel production, zero-emission trucks (ZETs) produce a fraction of the pollution that combustion trucks emit. Over the past several years, the availability of ZETs has expanded, and their deployments have increased significantly each year. Even as federal leadership on freight electrification has down throttled, ISRs adopted by state and local governments can help maintain the momentum the momentum toward electric truck deployments.

Currently, several states are pursuing ISR policies that could help freight facilities like warehouses, ports, and railyards influence the adoption of cleaner trucks and reduce air pollution in communities most impacted by on-road freight. In a nutshell, ISRs require covered freight facilities to reduce pollution associated with the activities that they facilitate or attract—such as truck trips, ship and locomotive visits, container handling equipment or other associated sources of pollution. Covered facilities can choose from a menu of flexible actions and strategies to meet their requirements under the ISR. Unlike state regulations that set clean air standards for vehicles and engines more stringent than federal standards, ISRs do not require approval from the Environmental Protection Agency.

Today, ISRs implemented in Southern and Central California and have shown promising results at reducing emissions from freight operations. Since its initial implementation in 2022, the South Coast Warehouse ISR has influenced meaningful increases in zero-emission truck trips, electric cargo handling equipment usage, electric truck charging, and warehouse solar power generation. In fact, between 2021 and 2023, warehouses covered under the program saw electric truck visits nearly triple and electric truck charger usage increased by over 20-fold. To support these activities, solar power usage at warehouses increased from just under three gigawatt hours to over 85 gigawatt hours during this time.

While these improvements are a relative drop in the bucket when considering the actions needed to address the historic pollution issues in the region—residents in San Bernardino County experience unhealthy concentrations of ground-level ozone over 360 days annually—they are a strong starting point to create additional avenues to electrify our freight system. Arguments against ISRs have asserted that they may stifle productivity, but the continued development of warehouses in the region suggests otherwise. Additionally, several studies have shown that fluctuations in fossil fuel prices have meaningful impacts to food prices; given the relative stability of electricity prices compared to fossil fuels prices and the significantly lower operating costs of electric trucks, this suggests that a zero-emission freight system has the potential to help stabilize and lower certain costs for consumers, although more research is needed to directly address this question.

Legislation in multiple states to expand ISRs

Both California and New York are currently considering legislation to expand the adoption of ISRs. Although legislative authorization is typically not necessary for local or regional ISRs to be adopted, these bills both affirm the authorization and require that statewide action be taken to reduce pollution from freight operations. UCS is working with both local and national partner organizations to promote the passage of these important pieces of legislation.

In California, Assembly Bill 914 would direct the California Air Resource Board to adopt a statewide ISR that quantifies, controls, and reduces emissions from indirect sources. If adopted, the bill could provide new pathways to incentivize freight electrification statewide through expanding access to electric truck charging at warehouses and ports, accelerating deployment of electric trucks and cargo equipment, and increasing on-site renewable energy generation to support these efforts.

New York’s Clean Deliveries Act (S1180A/A3575) would, among other things, direct the state’s Department of Environmental Conservation to develop a statewide ISR to address pollution from warehouses. Where e-commerce warehouses in the state are not currently subject to oversight with respect to the pollution they facilitate and attract, the bill would initiate a facility-by-facility review for both new and existing warehouses larger than 50,000 square feet and require warehouses to begin reducing their indirect pollution through flexible mitigation tactics. Importantly, the bill would require enhanced pollution reductions at warehouses near sensitive receptors, such as schools and communities overburdened by freight pollution.

According to Environmental Defense Fund research, over five million New Yorkers live within half a mile of a warehouse. These warehouses generate over 250,000 truck trips each day statewide and are disproportionately located in low-income and disadvantaged communities. The Clean Deliveries Act would help to relieve pollution burdens in freight-adjacent communities by increasing the deployment of ZETs and electric cargo equipment and increasing the quality of information available to public health officials and communities to better understand and address the historic and persistent problem of inequitable access to clean air among lower-income communities.

ISRs give states another tool to lead toward a cleaner freight system

Unfortunately, progress toward a cleaner, more efficient, and modern freight system is jeopardized under the current Trump administration. The White House and Congress have sought to roll back over half a century of legal precedent that allows California to adopt more protective vehicle emission standards (and for other states to choose to follow these standards), stalled federal leadership toward a national electric truck charging network, and are attempting to claw back federal investments that would both modernize and clean our domestic freight system.

Although our federal political climate renders many economically and technologically feasible actions to accelerate zero-emission freight politically infeasible, ISRs present an opportunity for states to take the baton and lead toward a cleaner, modern, energy efficient freight system. At this moment, policies like ISRs are an important and strategic tool for continuing the meaningful progress made over the past several years.

Congress is currently debating a budget megabill—also known as the “reconciliation” bill, after the budget reconciliation procedures it will use to try to pass it—that would keep low tax rates for the highest-income households and pay for it by cutting a wide swath of public programs.

The bill is big—increasing the federal budget deficit by at least $2.4 trillion over the next decade—and when it comes to transportation, would take the country seriously backwards.

The House passed its version of the bill on May 22, and the Senate is currently writing its own version of the legislation. Here are three things to know about it:

1. Lower taxes for wealthy households, new fees and higher taxes for families that drive electric

If your family owns a Chevrolet Bolt, Nissan Leaf, or Tesla, prepare to pay up. The same is true if you own a hybrid version of popular cars like the Toyota RAV4 and Camry or Honda CR-V and Accord. That’s because the bill would institute a new $250/year annual fee on electric vehicle owners and a $100/year fee for owners of hybrid cars.

These fees are supposedly meant to make up for the fact that EV drivers don’t pay gas taxes (which help fund transportation projects), but as my colleague Dave Cooke points out that’s a fallacy—EV drivers pay state and local taxes, which make up more than 80% of road funding, and into the federal general fund, which has been used to bail out the Highway Trust fund since 2008. What’s clear is that the fees would add up to much more than the average driver of a gasoline car pays in fuel taxes—nearly triple the cost, in fact.

The bill essentially kills tax credits for buying new and used electric vehicles.

As EV technology has continued to improve, automakers have brought more affordable models to market and used-vehicle inventory has grown. To pick two examples: A used 2023 Chevrolet Bolt EUV can be had in many parts of the country for under $20,000; current law allows many families a tax credit of up to $4,000 for buying a used EV. A new 2025 Chevrolet Equinox, meanwhile, has a suggested retail price just under $35,000—and is eligible for a $7,500 new-EV tax credit. The used clean vehicle tax credit would be eliminated entirely, making it harder for lower income families to switch to electric. And the new clean vehicle tax credit would be functionally killed, as my colleague Dave Reichmuth points out.

The House budget bill would also end an incentive in rural or disadvantaged areas to install an EV charger (a tax credit of 30% of the cost, up to $1,000).

2. Limited business access to clean trucks and a setback to the US transportation industry

Last month, I joined executives from companies that build and lease electric trucks and their charging infrastructure to warn against provisions in the House bill that would hurt the transition to a clean freight system.

Battery-electric trucks are one of the most cost-effective and consequential technologies we have to reduce pollution from vehicles. Take the diesel “drayage” trucks that operate near ports and transfer cargo to distribution centers. These trucks tend to be older models without modern pollution controls. Replacing a typical diesel drayage truck with an electric one is associated with hundreds of thousands of dollars in health improvements (i.e. fewer days spent in the hospital and fewer days missing work and school). And, as UCS analysis has shown, they are beginning to hit the streets in significant numbers.

But the House bill would make it harder for drivers and companies to make the switch by ending a commercial vehicle credit for clean trucks. It would also take back congressionally approved funds for the Clean Heavy Duty Program and Clean Ports Program, money that state and local governments are counting on to buy zero-emission heavy-duty vehicles, such as school buses and garbage trucks, and make improvements like shore power (which allows ships to run lighting and HVAC systems on electricity while docked, instead of idling their engines and polluting surrounding communities).

As one trucking executive put it at the press conference, “this is a Sputnik moment” for the US transportation industry. “We need some ‘Apollo 11’ energy here—not failure to launch.” And as my colleague Dr. Jessica Dunn recently wrote, other industries are closely tied to electric vehicle innovation; the future of US battery manufacturing is also at stake.

3. More money for oil companies, higher costs for drivers, and deadlier roads

The House’s version of the bill would roll back the most recent federal rules regulating vehicle fuel economy and global-warming pollution from trucks and passenger vehicles. A draft of the Senate’s version would strike the greenhouse gas rules; it would keep fuel economy standards on the books but render them useless by eliminating penalties for manufacturers who don’t comply.

Not only would this lead to billions more metric tons of heat-trapping emissions in the air, it would cost consumers more. Eliminating the global warming pollution rules would increase fuel and maintenance costs for new vehicles by $6,000 over the life of the vehicles. And if the fuel economy standards are functionally rolled back because it would be cheaper for automakers to simply not comply, drivers would see increased fuel costs by $23 billion through 2050.

Finally, the bill would rescind already-awarded “neighborhood access and equity” grants designed to make create safer transportation connections, especially in areas that are divided by dangerous highways or rail lines. Transportation for America recently listed the projects at risk. To pick one example, Portland, Maine could lose $22 million for safety improvements on local streets near Interstate 295. Across the country, over $2.4 billion could be rescinded.

Stop this backwards march on transportation

Transportation contributes more to US climate-warming emissions than any other sector of the economy. Transforming our transportation system is critical to thwarting the worst effects of climate change and protecting our health. In a megabill full of attacks on science and sound policy, the backwards march on transportation is one more reason to tell Congress no.

While most people think about AI in terms of the apps on their phones or the chatbots they interact with, the real environmental story happens behind the scenes—in massive facilities called data centers. These are the physical buildings filled with thousands of computers that process every AI request. Data centers come in many shapes and sizes, from small server rooms in office buildings to warehouse-sized facilities operated by tech giants like Google, Microsoft, and Amazon.  

But the newest generation of data centers, specifically built to handle AI workloads, are fundamentally different from their predecessors. They require far more powerful processors called GPUs (Graphics Processing Units), consume dramatically more electricity, and need significantly more water for cooling. A single AI-focused data center can use as much electricity as a small city and as much water as a large neighborhood. 

Generative Artificial Intelligence (GenAI) refers to tools and systems capable of generating text, images, and video. While its use perplexes many people, others react unimpressed by its day-to-day applications or fear its capacity to displace jobs. A recent Pew Research Center report reflects the public and experts’ mixed sentiments, showing that only 17% of people in the United States think AI will have a positive impact within the next 20 years, compared to 56% of experts. In addition, 51% say they are more concerned than excited compared to 17% of experts. One area where both groups agree on is the need for more control and regulation of AI.     

One growing conversation in the use or non-use of GenAI is the environmental implications of the technology in every step of its life cycle. Recently, Sam Altman, CEO of OpenAI, suggested that AI’s benefits outweigh its costs. These statements overlook who bears these health and environmental costs, and who gets to decide what trade-offs are acceptable. The communities breathing polluted air near data centers or those experiencing increased energy costs are the ones at the frontline of the technology’s impacts and often last its benefits.  

Sam Altman ends by saying, “Intelligence too cheap to meter is well within grasp.” Implying that AI will become incredibly cheap to produce, so cheap that the cost becomes negligible. ‘Too cheap to meter’ is a quote from 1954 during the early development of nuclear energy, when similar promises were made about electricity costs that ultimately didn’t materialize, but many of its impacts did. Also, didn’t ChatGPT start free, then move to $20 per month for advanced features, with enterprise plans costing hundreds or thousands of dollars? So when Altman talks about intelligence becoming ‘too cheap to meter,’ we have to ask: cheap for whom? 

To understand the multiple environmental implications, let’s journey backward through the processes from when a user inputs a prompt into a GenAI tool to when they receive a response in the form of text, an image, or a video. Through this post, I’ll guide you to what I have learned about this topic, from the more well-known implications of artificial intelligence in terms of Energy to other less well-known impacts regarding water use and air pollution. 

The energy cost of a ChatGPT request  

A user is on their computer and writes a prompt into ChatGPT and clicks send. That request goes to OpenAI servers (the company that created ChatGPT). Servers are located in Data Centers; there are multiple companies that provide data center services, and some of the bigger tech companies like Meta, Google, Amazon, have their own data centers. Data centers are physical buildings with racks of processing units or computers. These units only process the data you input from your device (e.g. personal computer or phone). So, for practical purposes, imagine computers stacked on each other that don’t require a monitor, keyboard, or mouse. 

 The processing of the prompt happens in Graphics Processing Units (GPUs) and/or Central Processing Units (CPUs). The difference is that GPUs have higher processing power and are more energy-intensive. Most of GenAI requests happen on GPUs regardless of whether your prompt is asking for a text, image, or video response. They acquired their name because they were originally developed to process graphics for video games and other 3D graphics applications. Today they are used for parallel processing, which allows to perform multiple calculations simultaneously. The more “work” a GPU is doing, the more energy it requires. In general, it will take more energy to produce an image, or many images (videos), than text.  

To put this in perspective, calculations by O’Donnell and Crownhart in a MIT Technology Review report show that a single query to a small AI text model uses about 114 joules, roughly equivalent to running a microwave for one-tenth of a second. However, larger, more powerful models can use 6,706 joules per response, enough energy to run that same microwave for eight seconds or carry a person 400 feet on an e-bike, according to the report. 

The same report estimates that generating a standard-quality image requires about 2,282 joules, while creating a high-quality five-second video can consume over 3.4 million joules—more than 700 times the energy of generating a high-quality image, equivalent to riding 38 miles on an e-bike or running a microwave for over an hour.  

Of course, looking at an individual prompt may not seem like much without the context of how many prompts servers get in a day. Estimates are that ChatGPT receives over a billion requests per day for generating text and tens of millions for generating images. According to the same article published in MIT Technology Review, the electricity to process those prompts in one day is equivalent to the power used by over 3,000 homes for a year.  

These calculations do not include the energy to generate video and do not include the prompts that other large companies receive through their own AI models, like Microsoft Copilot, Google Gemini, X’s Grok, and other companies developing other AI tools and models.  

While many of these calculations have limitations and assumptions that bring uncertainty, what is certain is the observed increase in the electricity that data centers are already using. In 2018, data centers were using 1.9% (76 TWh) of total United States electricity consumed. In 2023, it increased to 4.4% (176 TWh) of the total U.S. electricity consumption and projections to 2028 fall within 6.7% to 12% (300+ TWh to 500+ TWh). All these estimates come from the 2024 United States Data Center Energy Usage Report. 

As GPUs are not perfectly efficient, a substantial portion of the energy is turned into heat. That’s where part of the water consumption comes in, to keep those servers cool.  

Water use in data centers 

Similarly to your phone or computer, the servers processing AI tool requests get hot and release heat into the room. Hot environments can damage electronic components or reduce their efficiency. To cool the servers and data center facilities, there are multiple methods. Air conditioning systems require massive amounts of electricity but use little water, while water-based cooling methods are often preferred because they are cheaper. The cooling happens through machines known as Computer Room Air Handlers (CRAH). In short, these machines take the hot air that rises inside the room, cool it, and return it to the bottom of the room.  

How does this work?  

Inside the machines there are coils with chilled water. The hot air transfers heat to the water, cooling the air in the process. The outcome is hotter water that needs to be chilled again. The hot water goes to cooling towers where part of the water is evaporated–that’s where the high water use happens. When water evaporates, it absorbs energy in the form of heat, decreasing the temperature of the remaining water, that becomes cooler. Freshwater needs to replace the water that was evaporated. According to a recent report by Lawrence Berkeley National Laboratory, U.S. data centers consumed 66 billion liters of water directly at their facilities (also known as direct water) in 2023.  

While 66 billion liters sounds significant–and it is–whether this represents a large amount depends on what we compare it to. If you compare it with water use for agriculture, for example, then it would arguably not be too much water. 66 billion liters convert to 53,507 acre-feet, a measure of water use in agriculture and you can think of each acre-foot as the area of one football field filled with one foot of water. I live in California’s Central Valley, where I can compare this to the water use of almond trees (5 acre-feet per acre of almonds per year in the southern part of the Valley). That would mean that with the water used by all data centers in the United States you could irrigate 11,101 acres of almonds. In California there are about 1.56 million acres of almonds. If we compare it to residential water use, then 66 billion liters is equivalent to the water use of over half a million people in one year.  

As a water expert with a PhD in hydrology and having worked on water and climate change for over 10 years, there are other concerns I have. One is that this is showing a dramatically growing trend. According to the same report from Lawrence Berkeley National Laboratory, the direct water used by data centers in 2014 was 21.2 billion liters. So, in the course of 10 years, the water use tripled and data centers are growing in number and size.  

The other big concern is that those numbers only reflect direct water use by data centers. It does not include other water uses in the life cycle of artificial intelligence, such as water use for the extraction and manufacture of resources for both the building itself and the hardware and microchips that form the processing units. And it also doesn’t account for indirect water use by the power plants that produce the electricity for data centers, estimated to be 800 billion liters in 2023, over 10 times the direct water use.  

Further, these comparisons don’t tell the whole story, because half of the data centers are located in regions where water is already scarce. Data centers strategically position themselves near population centers and in areas with lower electricity costs, but this also means they frequently compete with local communities and agriculture for limited water resources, particularly in drought-prone regions such as California, Arizona, and parts of Texas. California, Arizona, and parts of Texas. 

Data centers also contribute to air pollution and degradation of health 

The energy consumed by data centers doesn’t just contribute to carbon emissions—it also generates air pollution that directly harms human health. Throughout AI’s lifecycle, from chip manufacturing to data center operation, significant amounts of criteria air pollutants are released into the atmosphere, including fine particulate matter (PM2.5), nitrogen dioxide (NO2), and sulfur dioxide (SO2).  

A recent paper by Han et al. at UC Riverside and Caltech titled The Unpaid Toll: Quantifying the Public Health Impact of AI quantifies the public health impacts through the lifecycle of AI. They estimate the public health burden of U.S. data centers in 2030 to be valued at more than $20 billion per year, comparable to emissions by on-road vehicles in California. The cost comes from the increases of the asthma cases and other cardio-pulmonary diseases caused by poor air quality.   

These pollutants come from three main sources. First, data centers rely on diesel backup generators for emergency power, which emit substantial amounts of air pollutants during operation, testing and maintenance. Second, the electricity powering data centers often comes from fossil fuel power plants that release air pollutants when burning coal and natural gas. Third, the manufacturing of AI hardware (requiring highly refined materials) and materials to build data center buildings (iron for steel and resources for cement) generates significant air pollution. 

As with other cases of environmental justice, these health impacts are not distributed equally. The air pollutants can travel hundreds of miles from their sources, but the communities most affected are often low-income areas that receive little economic benefit from data centers. 

Take action: Learn more 

Understanding AI’s environmental implications is crucial for being more mindful about its use and for asking representatives to design and implement appropriate policies and regulations. We need policies that require community engagement from the planning stages, mandate environmental protections, encourage transparent and accessible information from technology developers, and ensure that the benefits of technological advancement are shared equitably. 

I had the pleasure of collaborating with a group of outstandingly smart, mindful, and talented students from the Computer Science and Mathematics majors at Harvey Mudd College and Scripps College. Our collaboration culminated in an educational website about Artificial Intelligence and its implications for energy and water. I invite you to explore the interactive elements, and share it with others who might be interested in learning more about the hidden environmental costs of artificial intelligence.   

La mayoría de las personas piensan en la Inteligencia Artificial (IA) como parte de las aplicaciones en sus teléfonos o los chatbots, pero la verdadera historia de implicaciones ambientales ocurre detrás de escena, en instalaciones masivas llamadas “centros de datos”. Estos son los edificios llenos de decenas, cientos o hasta miles de computadoras que procesan cada solicitud de IA. Los centros de datos vienen en muchas formas y tamaños, desde pequeñas salas de servidores en edificios de oficinas hasta instalaciones del tamaño de un almacén operadas por grandes corporaciones de tecnología como Google, Microsoft y Amazon.  

Pero la nueva generación de centros de datos, construidos específicamente para manejar servicios de IA, son fundamentalmente diferentes de sus predecesores. Requieren procesadores mucho más potentes llamados GPU (unidades de procesamiento de gráficos) que consumen mucha más electricidad y necesitan significativamente más refrigeración. Un solo centro de datos centrado en la IA puede usar tanta electricidad como una ciudad pequeña y tanta agua como un vecindario grande. 

La Inteligencia Artificial Generativa (IA Generativa) se refiere a herramientas y sistemas capaces de generar texto, imágenes y/o vídeo. Si bien su uso deja perpleja a muchas personas, otras reaccionan sin impresionarse por sus aplicaciones reales en el día a día o temen su potencial para desplazar puestos de trabajo.  

Un informe reciente del Pew Research Center refleja sentimientos encontrados del público y personas expertas, mostrando que solo un 17% de las personas en Estados Unidos piensan que la IA tendrá un impacto positivo en los próximos 20 años, en comparación con un 56% de las personas expertas en esta tecnología. Además, el 51% dice estar más preocupado que emocionado en comparación con el 17% de los expertos. Un área en la que ambos grupos están de acuerdo es la necesidad de un mayor control y regulación de la IA.     

Una preocupación cada vez mayor sobre el uso de IA Generativa son las implicaciones ambientales de la tecnología en cada paso de su ciclo de vida. Recientemente, Sam Altman, CEO de OpenAI, sugirió que los beneficios de la IA superan sus costos. Estas declaraciones no consideran quiénes soportan estos costos a la salud y al medio ambiente. Tampoco consideran quién puede decidir qué compromisos son aceptables. Las comunidades que respiran aire contaminado cerca de los centros de datos o aquellas que experimentan aumentos en los costos de energía son las que están en primera línea de los impactos de la tecnología y lejos de sus beneficios. 

Sam Altman termina diciendo: “La inteligencia demasiado barata para medirla está a nuestro alcance.” Refiriéndose a que la IA se volverá increíblemente barata de producir, tan barata que el costo se vuelva insignificante. ‘Demasiado barata para medirla’ es una frase de 1954 durante las primeras etapas del desarrollo de la energía nuclear, cuando se hicieron promesas similares sobre los costos de electricidad que finalmente no se cumplieron, pero muchos de sus impactos sí lo hicieron. 

Para comprender las múltiples implicaciones ambientales, viajemos hacia atrás a través de los procesos desde que un usuario ingresa un mensaje en una herramienta GenAI hasta que recibe una respuesta en forma de texto, imagen o video. A través de este post, describo lo que he aprendido sobre este tema, desde las implicaciones más conocidas de la inteligencia artificial en términos de energía hasta otros impactos menos conocidos con respecto al uso del agua y la contaminación del aire. 

El costo energético de pedirle algo a ChatGPT  

Un usuario está en su computadora y escribe un mensaje en ChatGPT y hace clic en enviar. Esa solicitud va a los servidores de OpenAI (la empresa que creó ChatGPT). Los servidores están ubicados en los centros de datos; hay varias empresas que brindan servicios de centros de datos, y algunas de las empresas tecnológicas más grandes como Meta, Google, Amazon, tienen sus propios centros de datos. Los centros de datos son edificios con racks de unidades de procesamiento o computadoras. Estas unidades solo procesan los datos que ingresa desde su dispositivo (como su laptop o teléfono). Para fines prácticos, imagine computadoras apiladas unas sobre otras que no requieren un monitor, teclado o ratón. 

El procesamiento de la solicitud se realiza en unidades de procesamiento de gráficos (GPU) y/o unidades centrales de procesamiento (CPU). La diferencia es que las GPU tienen un poder mayor de procesamiento y consumen más energía. La mayoría de las solicitudes de GenAI se realizan en GPU, independientemente de si el mensaje solicita una respuesta de texto, imagen o vídeo. Adquirieron su nombre porque originalmente se desarrollaron para procesar gráficos para videojuegos y otras aplicaciones de gráficos 3D. Ahora se utilizan para el procesamiento en paralelo, lo que permite realizar múltiples cálculos simultáneamente. Cuanto más “trabajo” hace una GPU, más energía requiere. En general, se necesitará más energía para producir una imagen, o muchas imágenes (videos), que texto.  

Para poner esto en perspectiva, los cálculos de O’Donnell y Crownhart en un informe de MIT Technology Review muestran que una sola consulta a un pequeño modelo de texto de IA utiliza alrededor de 114 julios, aproximadamente el equivalente a hacer funcionar un microondas durante una décima de segundo. Sin embargo, los modelos más grandes y potentes pueden usar 6706 julios por respuesta, suficiente energía para hacer funcionar ese mismo microondas durante ocho segundos o llevar a una persona a 120 metros en una bicicleta eléctrica, según el informe. 

El mismo informe estima que la generación de una imagen de calidad estándar requiere alrededor de 2282 julios, mientras que la creación de un video de cinco segundos de alta calidad puede consumir más de 3,4 millones de julios, más de 700 veces la energía de generar una imagen de alta calidad, lo que equivale a recorrer 61 kilómetros en una bicicleta eléctrica o hacer funcionar un microondas durante más de una hora.  

Considerar mensajes individuales puede no parecer mucho sin el contexto de cuántas peticiones reciben los servidores en un día. Se estima que ChatGPT recibe más de mil millones de solicitudes al día para generar texto y decenas de millones para generar imágenes. Según el mismo artículo publicado en MIT Technology Review, la electricidad para procesar esos avisos equivale a la energía utilizada por más de 3000 hogares durante un año.  

Estos cálculos no incluyen la energía para generar video y no incluyen las solicitudes que otras grandes empresas reciben a través de sus propios modelos de IA, como Microsoft Copilot, Google Gemini, Grok de X y otras empresas que desarrollan otras herramientas y modelos de IA.  

Si bien muchos de estos cálculos tienen limitaciones y suposiciones que reducen su precisión, algo innegable es el aumento que ya se ha observado en la electricidad que los centros de datos utilizan. En 2018, los centros de datos utilizaban el 1,9% (76 TWh) del total de electricidad consumida en Estados Unidos. En 2023, aumentó al 4,4% (176 TWh) del consumo total de electricidad de EE. UU. y las proyecciones hasta 2028 se sitúan entre el 6,7% y el 12% (300+ TWh a 500+ TWh). Todas estas estimaciones provienen del Informe de uso de energía de centros de datos de Estados Unidos de 2024. 

Como las GPU no son perfectamente eficientes, una parte sustancial de la energía se convierte en calor. Ahí es donde entra parte del consumo de agua, para prevenir que los servidores se sobrecalienten.  

Uso del agua en los centros de datos

De manera similar a su teléfono o computadora, los servidores que procesan las solicitudes de IA se calientan y liberan calor en la habitación. Los entornos calurosos pueden dañar los componentes electrónicos o reducir su eficiencia. Existen varias formas para enfriar los servidores y las instalaciones del centro de datos como sistemas de aire acondicionado que requieren grandes cantidades de electricidad pero usan poca agua, o enfriamiento a base de agua que a menudo se prefieren porque son más baratos. El enfriamiento se realiza a través de máquinas conocidas como Computer Room Air Handlers (CRAH). En resumen, estas máquinas toman el aire caliente que sube dentro de la habitación, lo enfrían y lo devuelven al fondo de la habitación.  

¿Cómo funciona esto?

En el interior de las máquinas hay serpentines con agua fría. El aire caliente transfiere calor al agua, enfriando el aire en el proceso. El resultado es agua más caliente que necesita ser enfriada de nuevo. El agua caliente va a las torres de enfriamiento donde parte del agua se evapora, ahí es donde ocurre el alto uso de agua. Cuando el agua se evapora, absorbe energía en forma de calor, disminuyendo la temperatura del agua restante, que se enfría. Se necesita reemplazar el agua que se evaporó. Según un informe reciente del Laboratorio Nacional Lawrence Berkeley, los centros de datos de EE. UU. consumieron 66 millones de metros cúbicos de agua directamente en sus instalaciones (también conocida como agua directa) en 2023.  

Si 66 millones de metros cúbicos es una cantidad significativa depende de con qué la comparemos. Si la comparamos con la cantidad de agua que se usa para la agricultura, por ejemplo, entonces podría decirse que no sería demasiada agua. 66 millones de metros cúbicos se convierten en 53 mil acres-pies, una medida del uso del agua en la agricultura de Estados Unidos y se puede pensar en cada acre-pie como el área de un campo de fútbol llena de un pie (30cm) de agua. Yo vivo en el Valle Central de California, donde puedo comparar esto con el uso de agua de árboles de almendras (5 acres-pies por acre de almendras por año en la parte sur del Valle). Eso significaría que con el agua utilizada por todos los centros de datos de Estados Unidos se podrían regar 11 mil acres (4492 ha) de almendras. En California hay alrededor de 1,56 millones de acres de almendras. Si lo comparamos con el uso de agua residencial, entonces 66 millones de metros cúbicos equivalen al uso de agua de más de medio millón de personas en un año en Estados Unidos.  

Como experto en agua con un doctorado en hidrología y habiendo trabajado en agua y cambio climático durante más de 10 años, hay otras preocupaciones que tengo. Una de ellas es que está mostrando una tendencia de crecimiento exponencial. Según el mismo informe del Laboratorio Nacional Lawrence Berkeley, el agua directa utilizada por los centros de datos en 2014 fue de 21 millones de metros cúbicos. Lo que significa que en el transcurso de 10 años, el uso de agua se triplicó y los centros de datos están creciendo en número y tamaño.  

La otra gran preocupación es que esos números solo reflejan el uso directo de agua por parte de los centros de datos. No incluye otros usos del agua en el ciclo de vida de la inteligencia artificial, como el uso del agua para la extracción de recursos y fabricación tanto para el propio edificio como para el hardware y los microchips que forman las unidades de procesamiento. Y tampoco tiene en cuenta el uso indirecto de agua por parte de las centrales eléctricas que producen la electricidad para los centros de datos, estimado en 800 millones de metros cúbicos en 2023, más de 10 veces el uso directo de agua.  

Además, estas comparaciones no cuentan toda la historia, porque la mitad de los centros de datos están ubicados en regiones donde el agua ya es escasa. Los centros de datos se posicionan estratégicamente cerca de los centros de población y en áreas con costos de electricidad más bajos, pero esto también significa que con frecuencia compiten con las comunidades locales y la agricultura por recursos hídricos limitados, particularmente en regiones propensas a la sequía como California, Arizona y partes de Texas. 

Los centros de datos también contribuyen a la contaminación del aire y a la degradación de la salud

La energía consumida por los centros de datos no solo contribuye a las emisiones de carbono, sino que también genera contaminación del aire que daña directamente la salud humana. A lo largo del ciclo de vida de la IA, desde la fabricación de chips hasta el funcionamiento del centro de datos, se liberan a la atmósfera cantidades significativas de contaminantes atmosféricos criterio, como partículas finas (PM2,5), dióxido de nitrógeno (NO2) y dióxido de azufre (SO2).  

Un artículo reciente de Han et al. en UC Riverside y Caltech titulado The Unpaid Toll: Quantifying the Public Health Impact of AI cuantifica los impactos en la salud pública a lo largo del ciclo de vida de la IA. Estiman que la carga para la salud pública de los centros de datos de EE. UU. en 2030 estará valorada en más de $20 mil millones de dólares por año, comparable a las emisiones de los vehículos de carretera en California. El costo proviene del aumento de los casos de asma y otras enfermedades cardiopulmonares causadas por la mala calidad del aire.   

Estos contaminantes provienen de tres fuentes principales. En primer lugar, los centros de datos dependen de generadores de respaldo que utilizan diésel y que emiten cantidades sustanciales de contaminantes atmosféricos durante el funcionamiento, las pruebas y el mantenimiento. En segundo lugar, la electricidad que alimenta los centros de datos a menudo proviene de plantas de energía de combustibles fósiles que liberan contaminantes atmosféricos al quemar carbón y gas natural. En tercer lugar, la fabricación de hardware de IA (que requiere materiales muy refinados) y materiales para construir edificios de centros de datos (hierro para el acero y recursos para el cemento) genera emisiones contaminantes. 

Al igual que en otros casos de justicia ambiental, estos impactos ambientales no se distribuyen de manera equitativa. Los contaminantes del aire pueden viajar cientos de kilómetros desde sus fuentes, pero las comunidades más afectadas suelen ser zonas de bajos ingresos que reciben pocos beneficios económicos de los centros de datos. 

Cómo aprende más?

Comprender las implicaciones ambientales de la IA es crucial para ser más conscientes de su uso y para pedir a los representantes que diseñen e implementen políticas y regulaciones adecuadas. Necesitamos políticas que requieran la participación de la comunidad desde las etapas de planificación, que exijan la protección del medio ambiente, que fomenten la información transparente y accesible de los desarrolladores de tecnología y que garanticen que los beneficios del avance tecnológico se compartan de manera equitativa. 

Tuve el placer de colaborar con un grupo de estudiantes extraordinariamente inteligentes, atentos y talentosos de las carreras de Ciencias de la Computación y Matemáticas en Harvey Mudd College y Scripps College. Nuestra colaboración culminó en un sitio web educativo sobre Inteligencia Artificial y sus implicaciones para la energía y el agua. Puedes explorar los elementos interactivos y compartirlos con otras personas que puedan estar interesadas en aprender más sobre los costos ambientales de la inteligencia artificial.