Given the deadly risks of soot, especially to communities assaulted by polluting industries and vehicle exhaust from highways and heavy trucking, there’s nothing fine about the Environmental Protection Agency’s (EPA’s) recent proposal to clamp down on fine-particulate pollution.

You don’t have to be a scientist to understand why.

The soot particles in question are known as PM 2.5 for particulate matter that is 2.5 micrometers or smaller. This fine particulate often comprises a toxic brew of carbon, sulfur dioxide and nitrogen oxide created by several sources, including combustion in fossil fuel power plants, factories, and from car and truck emissions.

It is both fascinating and maddening to consider that a single particle of this soot is so tiny that 30 of them could fit inside the diameter of a single human hair. As New York’s State Department of Health noted, “several thousand of them could fit on the period at the end of this sentence.”

That microscopic size allows these particles to travel deeper into lungs and allows them to build up as time bombs in our lungs and blood streams. And the ambient air is filled with these particles. An international team of researchers said in Nature Communications last year that PM 2.5 is the “world’s leading environmental risk factor.”

Globally, fine particulate pollution kills at least 4.2 million people a year, according to the World Health Organization, and perhaps as many as 5.7 million a year, according to a study last year led by Canadian researchers. According to the Energy Policy Institute at the University of Chicago, PM 2.5 results in 2.2 years of life lost on average, more than from cigarette smoking, alcohol and drug use, or polluted water.

And the Lancet Commission on pollution and health last year warned that rising global deaths from ambient air pollution are offsetting public health progress made in lowering mortality from household air pollution and unsanitary water. “Since 2017, there has been strikingly little effort in most countries to act on these recommendations or to prioritize action against pollution,” the commission said.

That includes the United States. PM 2.5 prematurely kills between 100,000 and 200,000 people a year, according to several studies involving researchers from the University of Minnesota, the University of New Mexico, the University of Washington, the University of California Berkeley, the University of Illinois, the University of Texas, Carnegie Mellon, Stanford, and Brigham Young. Even the lower end of these estimates is equivalent to more than the deaths from guns and car crashes combined.

Chronic White House waffling on science

The US federal government has never sufficiently grappled with the gravity of this situation, largely because it has never fully embraced the counsel of its own scientists.

During the George W. Bush administration, the EPA’s Clean Air Scientific Advisory Committee (CASAC) recommended that polluters should emit no more PM 2.5 in their operations on an annual basis than 13 or 14 micrograms per cubic meter, “to provide increased public health protection.” Bush, beholden to industry, kept the standard at 15 micrograms, which had been established by the Clinton administration. In a highly unusual move, the CASAC even explicitly said it “did not endorse” keeping the standard at 15 micrograms.

The Obama administration lowered the standard to 12 micrograms per cubic meter, but only after being sued for dragging its feet by the American Lung Association, the National Parks Conservation Association and 11 states that Obama won both times, including California and New York. Even then, many public health experts said the federal standard was still insufficient.

The American Lung Association, in a joint report with the Clean Air Task Force and Earthjustice, said that the 12 microgram per cubic meter level might save 12,000 lives a year. But they also said tightening by just one more microgram to 11 micrograms would have avoided 35,700 premature deaths a year. It would have also avoided an annual 1.4 million cases of aggravated asthma, 2,350 heart attacks, and 2.7 million days of missed work or school.

The EPA of the Trump administration, run by coal and chemical industry hacks, clung to the 12- micrometer standard even though it admitted in its own analysis that such air quality would result in between 16,000 and 17,000 annual heart disease deaths from the narrowing of arteries. The Trump EPA also ignored a major study of people on Medicare that found that just a one microgram tightening of standards would save 12,000 lives. At that time, the government’s own scientists said a standard of 9 micrograms could save anywhere from 9,050 to 34,600 lives a year. 

The Biden administration came into office promising to restore science to its proper place in guiding environmental health policy and elevating environmental justice as a priority. Many studies show that communities of color and low-income neighborhoods disproportionately breathe in PM 2.5 pollution and thus suffer more than their fair share of sickness and death. The Medicare study, conducted by researchers at the Harvard School of Public Health, found that the risk of death to Black people from PM 2.5 is triple that of the general population. Indigenous, Latinx, and Asian American people also face elevated risks.

In a partial recognition of this, the Biden EPA announced early in January that it plans to lower the PM 2.5 standard down to between 9 and 10 micrograms per cubic meter. The agency said that would avoid up to 4,200 premature deaths a year. EPA Administrator Michael Regan said the proposal “is grounded in the best available science.”

While tightening the standard is surely welcome, the problem is that, in the decade since the Obama EPA set the standard at 12 micrograms, air pollution research continues to outstrip policy. The latest research points to the need for even lower limits and the ultimate elimination of such emissions.  A University of Wisconsin study last year estimated that if this nation eliminated the emissions of fine particulates, sulfur dioxide and nitrogen dioxide from the power sector, transportation, industry, and buildings, that would avoid 53,200 premature deaths a year and $608 billion in savings from illness and death.

That study directly connected the elimination of particulates to the fight against climate change. Given that “many of the same activities and processes that emit planet-warming greenhouse gases also release health-harming air pollutant emissions. . .Transitioning energy production away from fossil fuels and toward cleaner sources can produce health benefits from improved air quality in the near term while also providing climate benefits in the longer term.”

The 53,200 avoided deaths would more than fill Yankee Stadium. “These results offer a clear rationale for mitigating climate change on public health grounds,” the Wisconsin researchers said.

The Biden EPA has put out its proposal for public comment until March 28 and has set a public hearing for February 21 and 22. While signaling its intention for a standard of between 9 and 10 micrograms, the agency said it would hear arguments for as high as 11 micrograms and as low as 8.

Who will the EPA listen to?

In the current debate, it’s no surprise who is arguing to keep the standard at 12 micrograms. Invoking the worn-out rhetoric of job-killing regulations, US Chamber of Commerce executive Chad Whiteman said tighter standards would “stifle manufacturing and industrial investment.” Never mind that the corporate profits from unregulated industry surely comes at the cost of chronically ill workers and consumers who head to hospitals instead of shopping malls.

Conversely, many public health experts, overburdened community members, and environmental groups are making a case for 8 micrograms that should be impossible to ignore. A report published by the Environmental Defense Fund agrees with the Biden EPA that a standard of 10 micrograms might avoid 4,800 premature deaths. But it notes that a standard of 8 micrograms could save 19,600 lives–four times more.

Once again, the EPA’s Clean Air Scientific Advisory Committee has sent strong signals in favor of tighter standards. Most of the expert committee said an annual range of 8-to-10 micrograms would be “appropriate” to achieve “meaningful risk reductions,” given the “strengthened” science of “adverse health effects” at current levels. It is also strongly suggesting to the Biden administration that the EPA tighten regulations on daily emissions, as annual standards may not adequately account for the kind of concentrated bursts of pollution that smother fenceline communities living next to industrial facilities. Such communities that are disproportionately of color or low-income.

Perhaps to avoid getting industry too riled up about monitoring emissions around the clock, Regan proposes to leave the daily limits in place, although the EPA will take comments on tightening it. Despite Regan claiming that the EPA’s proposal will protect “the most vulnerable among us,” his own advisory committee said, “It is important to note that risk disparities across racial and ethnic groups remain substantial with the focus on an annual standard.” Environmental justice advocates are strongly displeased with the status quo on daily emissions. Beverly Wright of the Deep South Center for Environmental Justice flatly said the EPA’s proposal, as it stands, “does not address this racially disproportionate pollution burden.”

That means the burden once more is on the EPA to catch up to the anger in fenceline communities and to the analysis of its own expert advisors. Tens of thousands of lives have been lost over the years because regulations for PM 2.5 were one, two, three or four micrograms per cubic meters higher than they should be. The Biden administration has the chance to save lives with limits set exactly where the science says they should be.

California is rarely outshined as the leader when it comes to transportation electrification. However, the New York City Council is considering a bill that would codify a path toward a 100 percent zero-emission municipal fleet. This proposal would require the city’s entire on-road fleet, including heavy-duty trucks and specialty vehicles, to transition to zero-emission vehicles (ZEVs) by mid-2035.

The bill currently enjoys significant tailwinds with a supermajority of council members not only signaling support but co-sponsoring the bill (37 of 51 members to be exact). If enacted, Mayor Eric Adams and the City Council would not only surpass former Mayor De Blasio’s goal of an all-electric city fleet by 2040, but also make New York City the first major jurisdiction in the U.S. to adopt such a requirement.

As of February 2023, six states, including New York State, have passed California’s Advanced Clean Trucks rule, which requires manufacturers to sell an increasing percentage of zero-emission trucks and buses in those states. While this regulation is poised to accelerate the sales of zero-emission trucks after it begins in 2024, no regulation to date requires the transition of in-use trucks to ZEVs. California will consider adopting such a proposal, known as the Advanced Clean Fleets (ACF) rule, in late-April, but if New York City (NYC) adopts its bill before, it would make them the first to take this vital step.

Thus, the race for clean fleets is on, and not a moment too late.

An electric municipal fleet for a healthier New York City

Each year, fine particulate pollution from vehicles on NYC’s roads is responsible for an estimated 260 premature deaths and 720 emergency room visits. Around 65 percent of these lives lost can be attributed to fine particulate emissions from trucks and buses, despite those vehicles accounting for just six percent of annual vehicle miles traveled on city streets. Freight and port-adjacent communities bear the brunt of exposure and, according to New York City Department of Health research, people living in the city’s poorest neighborhoods experience over 8 times the number of emergency room visits from vehicle pollution compared to more affluent neighborhoods.

To be clear, the NYC bill would apply to its fleet of around 30,000 municipal vehicles, while California’s ACF would cover 139,000 municipal and state-owned medium- and heavy-duty vehicles in the state (as well as around 30,000 drayage trucks and 350,000 commercial trucks and buses). Even so, NYC’s proposal is meaningful: it has the nation’s largest municipal vehicle fleet and could transition its heavy-duty truck fleet to ZEVs at least four and one-half years faster than ACF’s municipal fleet requirements (assuming California municipal trucks’ useful life is similar to that of the legal minimum for commercial trucks).

The municipal electrification bill offers an opportunity for the city to establish itself as a leader in on-road electrification and influence other major American cities to follow suit, accelerating the adoption of zero-emission medium- and heavy-duty vehicles. New York City lags behind other major cities in both electric vehicle (EV) uptake and charging infrastructure deployment. In 2021, 3.4 percent of new car sales in NYC were battery-electric and plug-in hybrid vehicles. For comparison, the national average that year was 4.4 percent, and 22 percent in San Francisco. The disparity in public charging infrastructure suggests a lack of access to charging may be holding some would-be EV drivers from going electric because charging infrastructure typically needs to precede adoption. Currently, New York City has around 350 public charging stations – roughly 15 percent less than San Francisco despite having about 10 times the population. Transitioning its large municipal fleet to ZEVs will require significant EV charging infrastructure investments, which could be accompanied by supporting grid upgrades. This will better prepare the city to accelerate the installation of chargers for residential and commercial vehicles.

NYC’s opportunity to leapfrog and lead

Although NYC is by no means a car-centric city when compared to the rest of the United States, the story of the impacts is still the same: vehicles burning fossil fuels are a primary source of harmful pollution, and heavy-duty vehicles are disproportionately responsible. Many of the 26,000 vehicles city agencies operate daily are diesel-powered trucks and specialty vehicles, including fire trucks, street sweepers, trash collectors, and construction vehicles. The city has made some progress towards a cleaner fleet, but many of these vehicles are plug-in hybrids, which still produce harmful pollution. Furthermore, a recent study of light-duty plug-in hybrid vehicles suggested their emissions are much higher than previously estimated. This bill would require the city to deploy fully zero-emission vehicles in most cases.

There’s an international angle here too. At COP27, the White House announced the Zero-Emission Government Fleet Declaration, which sets a goal of 100 percent ZEV acquisitions for federal truck fleets by 2035. If the NYC bill passes, it provides the U.S. an opportunity to lead by example: our largest city not only exceeded the agreement’s acquisition goals, but committed to converting its entire fleet by mid-2035.

In NYC and beyond, the need and the path for municipal fleet electrification are apparent. Mayor Adams and the City Council should follow the footsteps of the fast-paced walkers on their sidewalks and seize the opportunity to up the tempo, and provide a meaningful example while doing so.

I love living in Maryland. We’re living in a historical moment, and I can’t help but do a lil’ happy dance around the possibilities of the new administration and the groundwork laid by the Climate Solutions Now Act which set some of the most ambitious climate targets in the country. Amid all this I’m grateful that part of my job is to spend my time advocating for how it can make these goals a reality—to transform the way we move people and goods towards a sustainable and equitable future.

Clearing the air on clean air

Every soul walking this earth deserves to breathe clean air, and folks in Maryland are no exception. Still though, counties across the state have air that hasn’t met the Environmental Protection Agency’s (EPA) standards for decades, causing a host of public health problems from asthma and cardiovascular issues to premature death. With COVID-19 still on our minds, I can’t stop paying attention to what it means to breathe freely.

Much of this air pollution comes from diesel trucks rumbling along the state’s many highway corridors, in particular I-95 which connects many major cities along the East Coast. This all makes Maryland one of the deadliest states for diesel particulate pollution. What’s worse, these air pollution impacts fall hardest on communities of color across the state, following decades of racist policies and practices that have brought them closer to traffic corridors.

Climate change in Maryland is no joke either

Sometimes when I’m frustrated about climate legislation that isn’t moving forward fast enough in Annapolis I think about how ironic it is that more and more frequently, floodwaters will be knocking on legislators’ doors. Maybe if session happened during hurricane season, then they would internalize the point more, but I digress…

Climate change is not some abstract existential global problem; it is already impacting Marylanders in clear ways. From more and more days of killer heat, to increased flooding and severe storms, to sea level rise, to ecosystem impacts in the Chesapeake Bay, Maryland has a huge stake in the climate. What we don’t avoid by reducing global warming emissions, we’ll have to make up for in climate resilience measures.

Transportation is the biggest source of global warming emissions in the state, and trucks and buses are some of the heaviest polluters. Though medium- and heavy-duty trucks and buses make up only nine percent of the state’s 4.2 million registered vehicles, they contribute 39 percent of nitrogen oxide (NOx) emissions, 48 percent of fine particulate matter (PM2.5), and 21 percent of climate-changing emissions from all on-road vehicles in the state.

Electric trucks are ready for work

We’ll need to tackle these issues from many fronts, and one promising avenue is electrifying our trucks and buses. By replacing the thunderous diesel combustion engine with a quiet electric powertrain, electric trucks can reduce smog, soot, and global warming emissions significantly, no matter where you are in the country.

There are currently over 100 models of electric trucks available or coming in the next two years in the US, made by over 40 manufacturers. These range from pickup trucks just bigger than a Ford F-150 to delivery vans, yard hostlers, day cabs, and even long-haul. You may have heard this before, but I’m telling you, driving them in real life can really change your perspective! I had the chance to drive an electrified cargo van and see many other electric models mentioned above at a conference last year.

Can the grid handle it? The short answer is yes. Electric cars, trucks, and buses can also help boost grid resilience and benefit all utility customers with lower rates. What about charging infrastructure? Most trucks will be able to charge at depots during off-times, and fleets can work with their utility to meet the needs of their routes and vehicles while public charging options continue to grow. It’s no question that building this infrastructure is feasible–what we need to do now is to start preparing for the transition.

The lane is open for clean truck policies

This legislative session, there are a suite of potential policies to jumpstart the clean truck transition in Maryland.  I want to highlight the Clean Trucks Act of 2023, which would require the state to join seven others in adopting the Advanced Clean Truck rule, which would require manufacturers to sell an increasing percentage of electric trucks every year.

This feasible and commonsense regulation would result in 46.45 million metric tons of reduced greenhouse gas emissions through to 2050. Based on my analysis of data from the International Council on Clean Transportation, the ACT and additional Low-NOx Omnibus rules would bring over $2.2 billion in public health benefits to Maryland from 2020-2050, by avoiding over 314 hospital admissions and emergency room visits, 370 premature deaths, and more than 150,000 cases of respiratory illnesses like asthma. The benefits of these rules are sure to touch many of our lives.

So, how can you get involved? The first step is to contact your legislator about your support for the Clean Trucks Act of 2023. If the bill passes, then there will be more voices needed throughout the regulatory process to ensure that the Department of the Environment does everything possible to create a strong rule.

Policies like the Advanced Clean Truck rule can help protect our planet, allow us to breathe freely, and make economic sense through investing in our future. We owe this to our community both in the present and for generations to come.

Rose Sims has lived in South Memphis, Tennessee, for 25 years. She loves the stability of her block, with many homes owned by retired neighbors. Sundays come with aromas of dinners made by grandmothers wafting down the street. Weekends have men out washing cars and cutting lawns. On a good air day, people wave at each other from porches. 

“I like where I am because I know everyone,” she says.

Yet, Sims, 58, a retired workforce manager at the Internal Revenue Service, agonizes that she needs to move; she literally fears that the air she breathes could kill her. Her South Memphis neighborhood is nestled in one of the nation’s most infamous industrial zones. Her neighborhood and adjoining zip codes are home to about 90 facilities listed on the Environmental Protection Agency’s (EPA) Toxic Release Inventory.

They include the nastiness of oil and coal tar refineries; hazardous waste storage and treatment facilities; and companies making or handling asphalt, concrete, fertilizers, paint, pharmaceuticals, plastics, solvents, appliances, furniture coatings, laminates, animal feed, and automotive parts. Several are owned by corporate titans such as Valero, Nucor, Sherwin-Williams, General Electric, Owens Corning, Exxon Mobil, and Land o’ Lakes. 

With such a high concentration of chemical plants, Sims said that, in her 25 years there, hardly a week has gone by without some kind of odor. “Somedays you can see the smog, some days, you can’t tell where the smells are coming from. It just ain’t right. We’ve been dumped on all our lives.”

In the past two years alone, South Memphis residents defeated a crude oil pipeline that would have slashed through the community to provide more profits for Fortune 500 companies Valero and Plains All American Pipeline. But that victory was quickly deflated by the roar of belching diesel trucks moving millions of tons of coal ash through the community from a defunct Tennessee Valley Authority power plant. The removal of the ash was out of fears of poisonous cadmium, arsenic and mercury seeping into Memphis’s drinking water.

But the 120 truckloads of ash a day are going to a landflll in South Memphis, continuing the nation’s history of disproportionately siting hazardous waste treatment, storage and disposal facilities in communities of color. While Tennessee is 73 percent White, a 2021 study by researchers from the University of California Berkeley and UC Davis found that 53 percent of the population living near hazardous facilities are of color.  

Justin Pearson, a community activist who helped lead the fight against the pipeline and was elected this year to the state legislature at the age of 28, called the onslaught of pollution a “slow lynching.”

Attention turns to ethylene oxide threat

Incredibly, though, all those polluting factories are not the most urgent reason driving Sims to the brink of moving. The pollutant bedeviling her and her neighbors is one they learned about just last year. It’s colorless and is emitted without the cacophonic clanging of heavy industry.

It is ethylene oxide, also known as EtO, a gas spewing out of a facility run by Sterilization Services of Tennessee, which uses it to sterilize medical equipment. The EPA considers ethylene oxide emissions to be cancer causing. In 2016, the agency concluded that the gas is 60 times more toxic than previously estimated, causing many communities that had never given facilities that use ethylene oxide facilities much thought—at least  compared to refineries, coal-fired power plants, and hazardous waste—to take fresh stock of the unusually high levels of disease they were seeing.

The most publicized example to date comes from the Chicago suburb of Willowbrook, Illinois. A 2018 federal analysis said the cancer risk from ethylene oxide emitted from a Sterigenics medical sterilization plant there constituted a “public health hazard.” And last year, a Cook County jury awarded a Willowbrook breast cancer survivor $363 million for her exposure to ethylene oxide from the now-shuttered facility. In January, Sotera Health, the parent company of Sterigenics, agreed to a $408 million settlement with as many as 870 other people who blame their cancers, miscarriages, and other serious health issues on ethylene oxide.

While Willowbrook, a predominately white suburb, was able to muster local and state support to shut down Sterigenics, there are still nearly 100 facilities around the nation using ethylene oxide to sterilize medical equipment and spices. According to a 2022 analysis, nearly a quarter of them are listed by the EPA as presenting an elevated cancer risk that could result in at least 100 additional cases per million people.

Millions of people, thousands of schools at risk

One of these higher risk facilities is the Sterilization Services of Tennessee plant near Rose Sims’s house. The level of emissions from this facility is so high that people who live closest to it face a cancer risk of 2,000 additional cases per one million people.   

The Memphis plant is among those highlighted by my colleagues at the Union of Concerned Scientists in a new report on ethylene oxide, Invisible Threat, Inequitable Impact. UCS did the analysis because the EPA last updated its ethylene oxide regulations 17 years ago and the agency is nearly a decade late in issuing new rules to slash emissions in line with much-better-known cancer and health risks. With the absence of adequate federal regulation over these years, the sterilization industry and its emissions have expanded in many densely populated areas.

UCS estimates that today some 14.2 million people live within five miles of two types of facilities that emit ethylene oxide, including sterilizers. More than 10,000 schools and childcare facilities are situated within these five-mile zones. Children are particularly sensitive to ethylene oxide exposure as it can damage their DNA, which divides more rapidly for them than for adults.   

Ethylene oxide emissions in the census tract where Sterilization Services is located in South Memphis are responsible for nearly 82 percent of the estimated cancer risk from toxic air pollutants, according to Darya Minovi, lead author of the UCS analysis (UCS is also a partner, along with several other environmental and grassroots groups, in a lawsuit pressuring the EPA to come up with new, stricter ethylene oxide standards for sterilizers).

More than 130,000 people live within five miles of the Sterilization Services facility near Rose Sims. Scores of schools and childcare facilities lie within the zone too. Typical of the skewed demographics of who lives within five miles of ethylene oxide facilities, the residents of South Memphis are disproportionately people of color (87 percent) and low income (57 percent).

The Sterilization Service plant has been around since 1976. It was hit with two EPA enforcement actions in 2021, resulting in $9,857 in fines—an amount that adds up to less than pennies in a $4.5 billion global medical sterilization services market.

But it was only last summer that the EPA brought the plant’s dangers fully to the attention of South Memphis residents. For Sims, many illnesses among her relatives and friends suddenly made sense. A major noncancerous effect of ethylene oxide exposure, according to the federal government, can be “compromised respiratory function.”

Many neighbors frequently complain of sinus issues and bronchitis. Asthma runs rampant among the people Sims knows, including her own two children and grandchild. She said her son was hospitalized repeatedly for respiratory problems. “I can’t even explain how many times I spent the wee hours in the emergency room,” Sims said. “Then we’d come home, and I was up every four hours making sure he was breathing. It was so tiring.”  

Then there is cancer. “I was talking to a lady a few days ago and she said she had cancer,” Sims said. “It seems like you can go up one street and there’s eight to 10 people with cancer. It can’t be hereditary.”

But actions to mitigate the problem in Memphis remain scant to an outrageous level, compared to the attention and action Willowbrook ultimately received. There is no excuse to ignore South Memphis residents when some plants throughout the nation (including a sister facility of Sterilization Services in Georgia) have bowed to harsh publicity, state government scrutiny, and lawsuits in more empowered and resourced communities to install filters and other controls to limit emissions.. The EPA’s website says the Sterilization Services of Tennessee plant has had “no recent installation of controls,” and has “no current plans for new controls at this time.”

Unconscionable inaction

A resolution from the Memphis City Council calling on the plant to reduce ethylene oxide emissions to thus far no effect. The county thus far has been passive.  On February 7, the Southern Environmental Law Center, writing on behalf of South Memphis residents, petitioned the Shelby County Health Department to exercise emergency powers to shut down the Sterilization Services facility or halt ethylene oxide pollution. The petition cited the UCS analysis and noted that the average life span of a person living in the census tract where the facility is located is 65.3 years, 11 years below the state average. Four adjoining census tracts have average life spans between 66.5 years and 69.4 years.

“The South Memphis community should not be forced to endure several more years of
unnecessary exposure to a cancer-causing chemical while EPA completes its rulemaking,” the petition said.

But, just two days later, the county rejected a shutdown, saying the plant meets “current” federal, state, and local rules for ethylene oxide emissions. While admitting that South Memphis residents “face inequitable health, social, and environmental conditions,” the county said all it would do is ask for more federal and state health risk data.   

The response came so fast and was so unresponsive to community pleas that Angela Johnson, outreach director for Memphis Community Against Pollution, asked out loud in a telephone interview, “Did they even read our petition?”

EPA action needed

Such acute local inaction makes federal action urgent. But, so far, South Memphis residents are not sure what to make of the EPA’s sincerity. For one, the current movement of coal ash through the community is essentially federally approved, given that the Tennessee Valley Authority utility was created by Congress.

For another, the EPA under the Trump administration delayed telling even Willowbrook residents about the potential danger posed by its Sterigenics plant. Thirdly, the EPA under the Biden administration has sent a muddled message to South Memphis about ethylene oxide. One slide of a community presentation by the EPA last fall said, “Reducing EtO coming out of the facility is the best way to reduce risk.” But an EPA regional air quality director enraged some people at the presentation by adding that residents should reduce their risk by “spending less time near the facility.”

Sims was one of those who took the EPA comment as an implied recommendation that she and her neighbors should move, while the agency shirked its responsibility to address the pollution. “Come on now,” she said. “Where are these people going to move when the housing market is so ridiculously high? You got elderly people here and some people at jobs making barely more than $1,000 a month (Tennessee has no minimum wage law, putting many wage earners below the $7.25 an hour federal minimum). It’s the plant that needs to move. Take that plant and move it somewhere next to nobody.”

Johnson said it is critical for the EPA to act because the threat of ethylene oxide is so much more invisible than the black clouds belching from a coal plant or a crude oil or natural gas pipeline slashing a scar through communities. “This fight against ethylene oxide will look a little different,” Johnson said. “We can win if everybody comes together. But it will be harder.”

“With a pipeline, you could pull people together across the city when you can talk about a leak ruining the water source of Memphis and Shelby County. With EtO, we must connect more dots. How far does it travel? What does it cost the city for so many people to be sick? Even Willowbrook, with their resources, they still had a fight on their hands before the company backed away. I can’t fathom what we will have to go through.”

Sims says that for her part, she will try to see the fight through, meeting by meeting, hearing by hearing and asking people on the street if they know that they are living under a cloud of carcinogenic gas. Sims says she doesn’t want to be living in a place that’s so dangerous to her health and that of her family and neighbors, but she also doesn’t want to move.

Her conundrum could end if the EPA would finally follow its own 2016 risk assessment and require ethylene oxide sterilizers  to either cap their emissions (and ideally, transition to safer methods of sterilization),  or close their doors.   

Lately, I have been writing a lot about cumulative impacts from environmental hazards. Meanwhile, the Union of Concern Scientists just published an important report on the potential threat posed by emissions of ethylene oxide from facilities that use the cancer-causing gas to sterilize medical equipment and other products. The report includes case studies of hotspots for ethylene oxide emissions (including in Minnesota) and an interactive map. This analysis is strong and important work. And, as I’ll try to show, these two subjects have a lot in common.

What is the situation in Minnesota?

The state of Minnesota uses EPA’s ethylene oxide emissions standards, which haven’t been updated since 2006. These standards no longer adequately protect the public. EPA’s own scientists concluded in 2016 that the risk value of ethylene oxide is 60 times more toxic than previously understood. While the agency has failed to update the rule as required under the Clean Air Act, last year, EPA identified 23 “elevated cancer risk” commercial sterilizers and is currently working to inform communities and work with state regulators and the facilities to decrease emissions. But much more is needed.

So, what does this have to do with Minnesota? And what about cumulative impacts? Well, when the EPA reviewed the 23 facilities, they reviewed them one at a time and none of the facilities in Minnesota were on the highest emitter list. But, the EPA analysis neglected the fact that sterilizer facilities emitting ethylene oxide might be within close proximity to one another. Looking at the data this way, we see that there is a cluster of five facilities in the northwest suburbs of the Twin Cities all emitting the same carcinogenic gas. Looking at more than one facility at a time, even if you are only considering one chemical at a time, is a step towards addressing the cumulative impacts of pollution. And by considering multiple facilities at a time, this UCS report shows that Minnesota should act to reduce ethylene oxide emissions to protect public health.

In the EPA’s analysis, computer models were used to estimate air concentrations of ethylene oxide around facilities. These air concentrations were compared to “inhalation unit risk values”, to estimate a potential number of cases of cancer in a population of people. So-called “acceptable levels of risk” are informational tools used to either require or ask facilities to reduce emissions, depending on the regulatory authority that applies. The EPA used a cancer risk guideline of 100 additional cases of cancer in a population of one million as a prioritization tool to pick the first 23 facilities to work on. But the state of Minnesota uses a lower risk guideline—10 additional cases of cancer in a population of one million—to identify facilities to work with to reduce air toxics emissions. The Minnesota facilities each reported emitting ethylene oxide levels that translate to between 20 to 50 additional cases of cancer in a population of a million people. So, the facilities emissions exceed the levels that ought to be prioritized in Minnesota.

What is ethylene oxide and why should I be concerned?

Ethylene oxide is a colorless gas that is used to sterilize medical equipment, plastics, packaged spices, and to make ethylene glycol (also known as antifreeze), among other uses. It is released into the environment as a gas and can break down in air and water. About half of the amount released is broken down in the air within 2 to 5 months. You can compare this to ozone which has a half-life on the order of minutes, and some PFAS chemicals that have a half-life in air on the order of several years. Ethylene oxide is released into the air continuously or multiple times, from stacks and more spread out from inside sterilization operations. Ethylene oxide breaks down more quickly in water and can evaporate from water into the air. That’s why we’re particularly concerned about air emissions.

Exposure to ethylene oxide by breathing it in the air is associated with cancers of white blood cells, such as non-Hodgkin’s lymphoma, as well as breast cancers. The EPA, and other public health and environmental agencies, determine levels in the air that are considered safe for sensitive populations. In 2016, the EPA updated the air value for ethylene oxide (called an “inhalation unit risk factor”) using more recent and robust science. These risk values are published on an EPA website and used by the agency to inform new environmental rules. These values are also available for use by tribal, state, and local public health and environmental agencies.

What can be done?

There are two ways that government agencies can work to reduce toxic air emissions, through regulations or through voluntary pollution reduction measures. Government agencies have the power to engage in either or both activities. The public can push for stronger protections by writing comment letters during public comment periods and voicing their concern (letter writing, phone calls) to local, state, or federal governmental officials.

You can find out more

You can learn more about ethylene oxide, dig into the UCS report, and look up particular addresses where ethylene oxide is emitted in UCS’s interactive map. The report looks at two types of facilities that emit ethylene oxide, but there are actually even more facilities that emit this toxic gas. Minnesota offers a tool you can use to find other permitted sources of ethylene oxide emissions.

Comment on the federal rule, push MPCA to support a protective rule

Currently, the EPA is writing a proposed rule to update ethylene oxide emissions standards for commercial sterilizers. Any member of the public, including state and tribal agencies, can comment on draft EPA rules. If you live in Minnesota, you can help make sure the Minnesota Pollution Control Agency (MPCA) writes a comment letter supporting adequate protection in the EPA’s upcoming update to its rules covering emissions of ethylene oxide at commercial sterilizer facilities. You can also write your own letter and use UCS’s handy guide to help. We expect the draft rule to be published in the coming months, with a final rule expected in 2024.

Voice your concern to state regulators

So, what can be done until a more protective federal rule is passed? Minnesota governmental agencies could push facilities to reduce ethylene oxide emissions now, especially since tightened federal rules are likely to require them to do so soon. You can call or write letters to state regulators voicing your concern on this issue.

Support safer alternatives to ethylene oxide

One important way to reduce ethylene oxide emissions is to find and develop safer replacements. Luckily, there are national organizations and local Minnesota organizations that help businesses find safer alternatives. Minnesota has recent experience with a toxic chemical switch, since it was the first state in the country to ban trichloroethylene. Voluntary substitutions for toxic chemicals do happen, but without regulatory action (e.g. rules, permit conditions) the safer changes may be tenuous and sometimes companies switch back to harmful alternatives. In 2020, the MPCA worked on ethylene oxide through a voluntary pollution prevention program, by offering grants. Ask for information about the outcomes of these previous grant-funded voluntary activities. If a company promises to use a safer process that reduces or avoids ethylene oxide emissions, make sure they do and that they stick with it!

Voice concern about unregulated releases of ethylene oxide

This is one of those super technical details in the field of environmental regulation. But, if you want to dive deep, Minnesota state rules allow some emission units (these are stand-alone emission units, so there can be more than one within a particular facility) to be categorized as an insignificant activity. When an emission unit is deemed an insignificant activity, that emission amount is not included in the calculations to determine if an air permit is needed. The amount for an emission unit to be deemed an insignificant activity is 200 pounds of ethylene oxide in a year. So, if you choose to engage on this issue, ask how many so-called insignificant activities at the facilities you are inquiring about include ethylene oxide emissions.

Support cumulative impacts legislation in Minnesota

Ethylene oxide poses significant risks on its own, but there are also other air emissions associated with cancer and other serious health effects. It is important that government officials know that the science supports the need to consider the effects of more than one chemical at a time. At the very least, the science supports the need to consider the cumulative impact of multiple facilities near one another to reduce overall exposures in an area. Proposed legislation in Minnesota would require the state to take cumulative impacts of environmental hazards into consideration in its regulations. You can contact your legislator to support this important new law. Here’s how.

No more delay

There is a lot to do to keep the public safe from environmental pollution and rarely a respite between one challenge to protect human health and the next. Environmental and toxicological sciences get more robust every day. It is important to heed the scientific information the EPA used to develop its assessment of the threat posed by ethylene oxide back in 2016. By acting on this science, we can ensure that industry moves to quickly reduce and eventually eliminate this health hazard.

Late last month, the Environmental Protection Agency (EPA) asked the public to provide oral comments on a major rule that will determine how much soot pollution you are exposed to. Among the commenters was my colleague Sam Wilson, who passionately and effectively called on the EPA to follow the science and enact the strongest air pollution standards to protect people’s health.

But the oral comments also included several speakers representing the industries producing a substantial amount of this deadly air pollution. Their main arguments include two disturbing tactics that come straight out of the disinformation playbook: casting doubt on the science, and pressing the EPA to violate a law passed by Congress.

The terrifying part is that these disinformation strategies, first honed by the tobacco companies, have a long history of successfully swaying public officials away from science-based decisionmaking and towards industry-favored positions that gravely endanger public health. Therefore, it is useful to examine these tactics more closely to better guard against their detrimental effects.

The science is clear, soot pollution kills people

Soot pollution, known as particulate matter, is a mixture of solid particles and liquid droplets found in the air. One especially dangerous form of this pollutant–and the one that the EPA’s rule has major consequences for–is called fine particulate matter, also known as PM 2.5, that is, particulate matter that measures 2.5 microns or less in width.

PM 2.5 pollution is responsible for millions of deaths worldwide. It is especially linked to harm in the cardiovascular and respiratory systems, but it also has the ability to damage practically every organ in the body. One recent study found that 99 percent of world’s population is exposed to levels that the World Health Organization deems unsafe, with especially high concentrations found in countries in the Global South.

There is a growing body of evidence (see here, here, and here) showing that Black, Indigenous, and people of color (BIPOC) communities are disproportionately exposed to more PM 2.5 pollution than white communities. One study linked the higher PM 2.5 pollution in BIPOC communities with the redlining practices of the 1930s, which continue to disenfranchise communities of color today.

The largest contributors to this deadly type of pollution come from human-made emission sources that burn fossil fuels, such as coal-fired power plants and vehicular emissions of diesel and gasoline. This process is estimated to be responsible for 1 in 5 deaths worldwide. In the United States, of the 100,000 deaths every year associated with human-made sources of PM 2.5 pollution, half of the deaths are attributable to the burning of fossil fuels.

EPA’s PM 2.5 rule is a good step, but more is needed

The Clean Air Act requires the EPA to periodically review the science for six criteria air pollutants, including particulate matter, and to use this science to set a standard known as the National Ambient Air Quality Standards. These science-based standards form the basis of how the federal government protects communities across the United States from harmful PM 2.5 pollution.

My colleague Derrick Jackson has gone into greater detail about this, but the basic gist is that the EPA is currently proposing to tighten the primary annual PM 2.5 standard to between 9 and 10 micrograms per cubic meter and to keep in place the current 24-hour PM 2.5 standard of 35 micrograms per cubic meter. This is both an excellent and a terrible decision. It is excellent to see the EPA wanting to tighten the annual standard (the current standard is 12 micrograms per cubic meter) but it is also terrible that the EPA is not fully committing to the best available science by lowering the annual and 24-hour standard further.

The EPA’s Clean Air Scientific Advisory Committee (CASAC), an independent and highly respected group of scientific experts, weighed in extensively on the EPA’s scientific and policy documents and concluded that even low levels of PM 2.5 pollution can cause harm to human health, and therefore the standards need to be tightened. Specifically, the majority of CASAC members recommended lowering the annual PM 2.5 standard to between 8 and 10 micrograms. Additionally, a majority of CASAC favored lowering the 24-hour standard and “suggested that a range of 25 to 30 micrograms per cubic meter would be adequately protective.”

As I’ve written before, the EPA’s approach to reviewing the science on particulate matter is a robust one. But it also has some inherent weaknesses in how it incorporates the pollutant’s health effects for populations that are more sensitive, such as people with lung disorders, and for populations that are more disproportionately exposed, such as BIPOC communities. Therefore, the EPA would do well to choose the most protective standards possible in order to protect underserved communities.

Fossil fuel industry wants to undermine science-based protections

The EPA’s public hearing on its proposed PM 2.5 rule took place in late February over a three-day period. Of the 281 speakers who presented, 94 percent (263 speakers) urged the EPA to lower the annual PM 2.5 standard to 8 micrograms and lower the 24-hour standard to 25 micrograms.

Of the 6 percent of commenters who urged the EPA to retain or weaken the proposed PM 2.5 standards, the vast majority had direct ties to industry. The speakers included representatives from the American Chemistry Council and American Petroleum Institute–industry trade groups infamous for casting doubt on public health and environmental science to benefit their clients’ profit margins. For years, we at UCS have written extensively of the dangerous disinformation practices of the American Chemistry Council and American Petroleum Institute and their ongoing efforts to dismantle public health protections.

As noted above, the speakers arguing for less protective PM 2.5 standards primarily utilized two tactics. Let’s look at them in more detail.

First, they claimed that the science is in doubt. This is frankly ridiculous. Particulate matter pollution is one of the most well-studied types of air pollutants; for decades the evidence in the scientific literature has overwhelmingly shown how deadly PM 2.5 pollution is, even at low levels of concentration. The EPA’s supplement to the integrated science assessment on particulate matter runs to more than 300 pages that painstakingly review the scientific literature and conclude that, even at low levels of exposure, the relationship between PM 2.5 concentrations and cardiovascular effects and mortality is “causal.” This is the highest level of scientific certainty possible for this process and shows that the weight of scientific evidence is simply undeniable.

Second, industry representatives argued that economic considerations should be taken into account when setting PM 2.5 standards. This argument is utter hogwash because it stands in direct violation of the Clean Air Act. Standards for outdoor particulate matter are governed by section 109 of the Clean Air Act which clearly states that the standard must be based on criteria that “are requisite to protect the public health.”

This part of the law, requiring the government to consider only science-based evidence that can protect public health, has been upheld for years. As a congressional research service report from 2017 put it: “For 45 years, EPA has interpreted Section 109 as prohibiting the [EPA] Administrator from considering costs in setting the standards. In 2001, this interpretation was affirmed in a unanimous Supreme Court decision, Whitman v. American Trucking Associations. The Court pointed to numerous other CAA [Clean Air Act] sections where Congress had explicitly allowed consideration of economic factors, concluding that if Congress had intended to allow such factors in the setting of a primary National Ambient Air Quality Standards, it would have been more forthright—particularly given the centrality of the NAAQS concept to the CAA’s regulatory scheme. The court concluded that Section 109(b)(1) ‘unambiguously bars cost considerations from the NAAQS-setting process.’”

The EPA needs to pass the most health-protective measure possible

During the public hearing, industry representatives asked the EPA to set less protective PM 2.5 standards. This position ignores the best available science and lets thousands of people die every year so that industries can continue their practices of burning fossil fuels and polluting the air.

Fossil fuel companies are well aware of how harmful the air pollution generated by their activities can be for human health. For instance, reporters from the Guardian examined documents showing that the oil industry knew for at least 50 years that the PM 2.5 pollution associated with the burning of fossil fuels could harm human health. Just as fossil fuel industries have cast doubt on the science of climate change for decades, they are now using similar disinformation tactics to undermine the policy process protecting people from dangerous PM 2.5 pollution.

According to the EPA’s own analysis, if we tighten the annual PM 2.5 standard to 8 micrograms per cubic meter, we will save the lives of between 6,600 and 12,000 people every year. If the EPA is serious about following the best available science and protecting the health and safety of communities across the country, this is what it must do: lower its annual PM 2.5 standard to 8 micrograms per cubic meter and its 24-hour standard to 25 micrograms per cubic meter.

With the clean energy transition already under way, the US electricity mix is set to continue changing this year. The general outlook includes some good news and some bad news. I’ll start off with the good. 

Solar power is expected to make up about half of all additions of US electric generating capacity in 2023, according to data from the US Energy Information Administration (EIA). The 25.5 gigawatts (GW) of planned solar projects expected to come online this year is almost double the previous 13.4 GW record from 2021. Further, this estimate doesn’t even include smaller-scale projects such as rooftop solar, additions of which are also expected to be significant. 

The addition of newer, cleaner resources like solar power to our electricity grid will happen in tandem with the planned retirement (or permanent closure) of older and dirtier resources such as coal- and gas-fired power plants, which make up 98 percent of the planned retirements in 2023.  

However, there’s uncertainty about how much of this additional capacity will come to fruition this year. Renewable projects can experience delays due to the country’s antiquated (and slow) system of connecting to the grid, as well as other reasons like permitting and transmission constraints. And fossil fuel power plants may not stick to their retirement schedules for a variety of reasons. A bit more on those reasons later. 

But if plant owners actually do follow through on their retirement plans, there will be real, tangible public health and environmental benefits. In 2021 alone, the plants slated for retirement emitted more than 28,000 tonnes of nitrogen oxides (NO_x), 32,000 tonnes of sulfur dioxide (SO₂), and 51 million tonnes of carbon dioxide (CO₂), according to EIA data.  

Here’s why that matters: In addition to environmental effects—like reduced visibility due to haze—NO_x and SO₂ emissions both contribute to extremely small particles called particulate matter (PM) pollution, which has been linked to a wide array of human health impacts including reduced lung function, heart attacks, and premature deaths of people with heart or lung disease. NO_x also contributes to the formation of ozone (or “smog”), another toxic pollutant. 

A recent study found that more than 99 percent of the global population is exposed to unsafe levels of PM_2.5 pollution, which are particles with diameters of 2.5 micrometers or less. In 2019, air pollution more broadly was responsible for about 6.7 million deaths globally. 

And CO₂ emissions are a primary driver of global climate change, which is exacerbating the type of extreme weather that killed 474 people and caused $165 billion in damages in the United States last year alone. So what might happen if all the plants that are scheduled to retire did in fact retire and never burned fuel again? 

Health and environmental damages avoided 

Using Environmental Protection Agency (EPA) estimates, the United States could avoid more than $18 billion in annual damages from CO₂, NO_x, and SO₂ if all the coal and gas plants scheduled for retirement in 2023 permanently shut down as planned.  

(Note: this is adjusted for inflation to 2022 dollars and is based on the amount those plants emitted in 2021, the EIA’s most recent year of finalized data. The EPA’s Social Cost of Carbon was adjusted to 2025 to align with the emissions year of the NO_x and SO₂ estimates.) 

Keep in mind that this calculation comes nowhere close to a full estimation of the costs that would be avoided by retiring these power plants, since it only focuses on three pollutants and doesn’t account for the effects taking place upstream of the plants, such as the health and environmental impacts of extracting gas and coal. Moreover, analysts generally consider EIA data to be relatively conservative, so the plant closures and associated benefits could potentially be even greater this year, especially now that 99 percent of existing US coal plants are more expensive to run than building new wind and solar generating capacity, according to a recent analysis. 

This transition away from coal can be done while also addressing the associated negative impacts, such as lost jobs and reduced tax bases for communities. The Union of Concerned Scientists (UCS) found in a 2021 report with the Utility Workers Union of America that supporting former US coal industry workers through the clean energy transition can be achieved affordably with adequate planning, funding, and stakeholder engagement. 

Overall, the planned closure of these fossil fuel power plants is good news for the global climate and the health of surrounding communities—which tend to be communities of color—that have had to endure decades of air and water pollution from those facilities.  

Unfortunately, the outlook isn’t a 100 percent good-news story for a few different reasons. First, there are even more gas plants planned to come online this year. Further, not all the health and environmental benefits from plant retirements are guaranteed. And finally, even if all the fossil plants retire as scheduled, the pace is still not quick enough to get the country on track to meet its clean energy goals.  

More gas plants, uncertain coal retirements

As you may have noticed in the first table toward the top of the page, about 7.4 GW of new gas capacity is planned to come online in 2023, outpacing not only the 4.8 GW of gas capacity set to retire, but also slightly outpacing the planned additions of wind power. 

These new gas plants, which are not clean, could also potentially generate roughly five times the amount of electricity that the retiring gas plants generated in 2021. This is because more than 80 percent of the new gas-fired capacity coming online will use so-called combined-cycle technology that, because of its comparatively greater efficiency, typically results in plants running more frequently compared with older steam turbines, which make up about 78 percent of the gas-fired capacity set to retire this year. 

And while gas plants emit little SO₂, the additional emissions from this new gas-fired capacity could undo about 24 percent of the CO₂ emissions reductions and nearly all—more than 98 percent—of the NO_x emissions reductions resulting from the planned coal and gas retirements. 

The bottom line: There’s still a long way to go, and the clean energy transition must move quicker than it has been—despite the fossil fuel industry’s self-serving claims to the contrary. 

Modeling has shown that if the United States is going to live up to its Paris Agreement targets aimed at limiting global warming to 1.5 degrees Celsius, coal power should be entirely phased out by 2030. 

Yet none of the country’s 10 most-polluting coal plants are set to retire this year, and many of them are currently scheduled to continue running well into the 2030s. US coal plants that are neither economic nor compliant with federal environmental regulations are being kept online well past their profitable lives due to both political reasons and assertions of about grid reliability concerns that, in reality, could be addressed with cleaner and cheaper technologies. 

What can be done?

With all that said, there are many ways policymakers at virtually every level of government can bring more certainty and speed to the retirement of fossil fuel power plants and the installation of clean energy capacity to replace them. In doing so, the country can start realizing more of the tremendous economic, health, and environmental benefits of a clean energy future, while not leaving communities behind in the transition. 

Federal policymakers should continue breaking down market barriers for clean energy resources, while also going beyond the existing policy efforts to facilitate the buildout of a modern transmission grid that can transport more renewable electricity. State regulators should thoroughly scrutinize any utility company plans that would invest in new fossil fuel power plants or keep existing ones online at ratepayers’ expense, particularly now that tax incentives under the Inflation Reduction Act (IRA) have made cleaner resources like wind, solar, and energy storage even more cost-effective than before. 

Alongside federal and state government entities, communities should also take advantage of the wide array of incentives for local governments provisioned by the IRA, which, among other things, earmarks billions of dollars in funding for clean energy projects in communities with closed coal mines or plants. 

The transition away from a fossil fuel power system to a clean electricity grid is achievable, but policymakers must use their existing tools more expeditiously and continue adding more tools, as UCS has been pushing—and will continue pushing—them to do. 

Transportation is the largest source of global warming emissions in the United States, making it a critical piece of the puzzle to addressing climate change. Every new vehicle sold today could be on the road for two or even three decades, which means that achieving a goal for 2050 requires immediate action. This is what makes yesterday’s action by the Biden administration so critical—EPA proposed new emissions targets for both passenger vehicles and heavy-duty trucks manufactured and sold through 2032 that will accelerate the transition to electrification already underway.

Electrifying transportation is a necessary component of addressing climate change. But it also represents a critical solution to addressing the longstanding harms to public health from our transportation system, the costs of which are disproportionately borne by communities of color. While yesterday’s proposals are a welcome step and will go a long way to addressing climate change, the administration’s actions to address the harmful soot and particulate pollution from heavy-duty trucks impacting local communities fall short.

Below, I’ve summarized the key points of the two proposals put forth today and what we hope to see moving forward. There is a monthslong process ahead to get these rules over the finish line: through robust engagement with frontline communities, the administration can finalize and implement strong passenger vehicle and heavy-duty truck standards centering the needs of those most impacted by the rules and targeting the complete elimination of tailpipe pollution.

An ambitious and achievable goal to electrify privately owned vehicles

While complementary action to reduce car usage is necessary to address climate change, to the extent the United States continues to be reliant upon privately owned passenger cars and trucks, those miles must be electric, powered by an increasingly clean grid. This proposal will help accelerate that necessary transition.

Recent survey results show there is more demand for electric cars and trucks than there are electric vehicles being manufactured at the moment. With folks generally purchasing vehicles only once a decade, and more often than not doing so on the used market, it is imperative that new vehicles electrify ASAP. Under this proposal, up to two-thirds of the new vehicle fleet could be electric by 2032. This exceeds the President’s stated goal, and it’s nearly on track to where we need to be, which is to fully electrify the new vehicle fleet by 2035.

Importantly, this proposal recognizes the tremendous amount of support for this transition, including the two pieces of climate-related legislation Congress passed last term. Incentives for manufacturing, infrastructure, and purchasing support the rapid growth in electric vehicles on the timescale necessary to meet climate targets.

One critical point that was perhaps missed in the initial coverage of the proposal is how much more efficient the remaining gasoline-powered vehicles are expected to be. Despite the growing share of electric vehicles projected by this rule, 40 percent of vehicles sold in 2030 even under this proposal will still be powered by gasoline. For those vehicles, we think there is further opportunity for improvement. While EPA has projected gasoline vehicles to improve by close to 20 percent between now and 2032 in order to meet its standards, largely the result of standards already on the books through 2026, this could and must be closer to 30-35 percent to be consistent with our urgent need to address climate change. And, to the extent possible, we need EPA to be driving efficiency improvements for electric vehicles as well.

Protecting public health and the climate

One critical aspect of the light-duty vehicle proposal that has also not been covered is that these newly proposed emissions standards don’t just pertain to global warming emissions: EPA has proposed new fleetwide average standards for smog-forming emissions (nitrogen oxides [NO_X] and volatile organic compounds [VOCs]) as well as particulate matter (PM) for passenger cars and trucks.

Electrification can eliminate tailpipe emissions entirely, which means directly reducing harmful pollution affecting the air we breathe. This is particularly important for the disproportionately BIPOC populations along freeways and near hubs of freight activity like ports and warehouses. Setting a “multi-pollutant” standard as EPA has proposed for light-duty vehicles drives simultaneously emissions reductions from both the best available emissions-reducing technologies for all pollutants, whether for gasoline-powered vehicles (e.g., gasoline particulate filters for PM and hybridization to reduce CO₂) or reductions resulting from shifting marketshare towards vehicles with zero tailpipe emissions.

Unfortunately, while the Biden administration moved forward with directly addressing the harmful smog-forming and particulate pollution from passenger cars and trucks, it did not do so for the heavy-duty truck sector, which means its proposal is not necessarily going to drive the transition to zero emissions needed for public health.

UCS and our allies have called for the agency to adopt a multi-pollutant strategy for its heavy-duty rulemaking, and we will continue to advocate for it during the comment period.

The heavy-duty truck proposal needs more ambition, urgency

While recent headlines have called EPA’s light-duty vehicle emissions proposal “strict,” “dramatic,” and “ambitious,” virtually nothing has been said about the heavy-duty proposal also released today. Unfortunately, those words don’t really apply here.

On the plus side, EPA is finally putting forth new emissions standards that recognize the shift towards electrifying the heavy-duty vehicle sector. The downside, however, is that the agency’s proposal does not appear to ride that wave of momentum.

The agency just authorized enforcement of state standards that will ensure over 50 percent of new heavy-duty trucks sold in those states will be electric by 2032. Manufacturers claim they are targeting even more aggressive electric truck sales, with plans to electrify more than half new heavy-duty truck sales by 2030 according to the manufacturers themselves. And the new purchase incentives for commercial trucks are expected already to drive electrification beyond those targets (upwards of 50 percent by 2032), even in absence of EPA action.

EPA’s proposal falls short of these ongoing actions, with the preferred alternative driving no more than 40 percent electrification. The momentum is there for new heavy-duty vehicles to be entirely electric by 2035—for fleets, what matters is the total cost of ownership, and electrification can cut operating costs, as well as emissions. Even the most stringent scenario in the proposal fails to create a workable transition to zero emission by 2035. Were EPA to set a more ambitious standard, that would help ensure the level of investment needed in infrastructure and manufacturing to meet this goal.

The biggest flaw in the proposal is that by focusing exclusively on regulating global warming emissions, the proposal sacrifices certainty in its efforts—while every modeling exercise is speculative, this leaves open the possibility that instead of driving a transition to the zero-emissions solutions needed, EPA’s rule will promote false solutions like hydrogen combustion engines that would do nothing to alleviate the tailpipe pollution harming local communities.

The proposals are a step in the right direction, but more is needed

Targeting a complete transition to electrify new vehicles by 2035 would both address our climate crisis and recognize and address the unjust burden felt by communities today as a result of heavy-duty trucks. This is a critical window for action. The agency’s proposal may not guarantee such a transition for passenger cars and trucks, but it doesn’t even attempt to encourage one in the freight sector: that has to change.

Over the coming weeks, we will continue to dig into the proposed rules to build support for that transition. There will be public hearings so that the general public can weigh in verbally, as well as via written testimony. It’s important that the EPA hears what it is like on the ground, to understand the lived experiences of today as well as the opportunities for a cleaner and more sustainable transportation future for us all.

UCS will be focused on strengthening both proposals, pressing EPA to meet the moment and finalize light- and heavy-duty truck standards targeting a zero-emission future. And we will be asking our supporters and partners to do the same. The opportunity for a just transition to zero emissions is now—and we need the administration to seize it.

In late April, California air regulators are poised to pass one of the most meaningful regulations to reduce pollution from commercial trucks, vans, and buses.

The Advanced Clean Fleets (ACF) rule, which I’ve blogged about in detail before, will phase out fossil-fueled trucks over the next several decades. This rule expands the benefits of the landmark Advanced Clean Trucks (ACT) rule, which compelled manufacturers to sell an increasing number of zero-emission trucks, by requiring that nearly all new medium- and heavy-duty vehicles (MHDVs) sold in the state be free of tailpipe emissions by 2036. 

Together, these standards will accelerate California’s necessary transition to a cleaner and more efficient freight system, increasing the estimated number of electric trucks on our roads and highways by 70% in 2050. These clean trucks will deliver health-related and economic benefits and provide much-needed relief to communities living close to industrial corridors, ports, and railyards. Although not immune to imperfections and challenges, the rule represents a massive step in the right direction and away from the diesel pollution that fouls our air and chokes communities.

What’s in the proposal?

The current draft of the ACF rule was released in late March and made several changes to the version that the California Air Resources Board (CARB) heard back in October 2022. The four primary parts of the regulation remain: electrification requirements for large commercial and federal truck fleets, flexible electrification requirements for state and municipal truck fleets, 100% zero-emission drayage truck operations by 2035, and a 100% zero-emissions MHDV sales requirement. These parts have three high-level impacts:

• Increasing electric truck purchase requirements for large commercial, federal, state, and municipal fleets, beginning as early as 2024 and ramping up to a 100% zero-emission fleet requirement in 2042, based on vehicle category.
• A full transition to electric drayage truck operations in 2035. These trucks, which move shipping containers and goods from ports and railyards, are among the dirtiest on the road and are a primary source of air pollution in disproportionately impacted communities.
• After 2036, all new MHDVs sold in California will be electric.

There are more than 1.8 million commercial trucks on California roads, and although they make up just 7% of vehicles on the road, these trucks are responsible for more than one-quarter of greenhouse gas (GHG) emissions, more than 60% of smog-forming nitrogen oxides (NOx) and more than 55% of lung- and heart-harming fine particulate (PM2.5) pollution from vehicles.

The more significant changes: some good, others not so great

One of the most significant changes in the final proposal is the acceleration of the 100% zero-emission vehicle (ZEV) sales requirement from 2040 to 2036. This small change is massively impactful and is estimated to put an additional 130,000 electric trucks on the road by 2050, decreasing fuel and maintenance costs to truck fleets and resulting in an additional $300 million in net savings to fleets in 2050. According to our research, these additional electric trucks would increase the health benefits of the rule by about 10% with significantly fewer illnesses and premature deaths.

Unfortunately, not all the changes were so great—one notable revision would delay the electrification of thousands of natural gas-fueled waste trucks by several years. Although the change is meant to allow flexibility for waste fleets that run on biogas captured from landfills, compost, and wastewater treatment, its broad language would allow waste trucks that run on fossil natural gas to take advantage of the delay by purchasing out-of-state biogas credits for their trucks. This change is unfortunate, given that these trucks are among the most well-primed for near-term electrification. In fact, a recent report estimates that waste trucks will transition to ZEVs faster than most other truck types by the end of the decade due to competitive prices of electric models.

Most changes in this final draft were small tweaks to increase compliance flexibility for fleets through targeted exemptions. These include cases of delayed charging infrastructure construction, canceled or delayed vehicle deliveries, and the like. The hope is that these exemptions won’t need to be tapped regularly as the market for clean trucks expands, production catches up to the demand for electric trucks, and the work to install charging infrastructure accelerates and streamlines. The new language also allows additional flexibility for municipal and state fleets through an alternative “ZEV milestone pathway” in the commercial/federal high-priority fleet portion of the rule. This pathway would set ZEV requirements for the in-use fleet and mandate the retirement of polluting combustion trucks after 18 years or 800,000 miles, rather than only requiring newly added trucks to be zero-emissions. This change gives options to public fleets to meet their individual needs while still ensuring that their trucks transition to ZEVs on a feasible timeline.

A notable missed opportunity

One important change that I, along with other advocates and researchers, pushed strongly for was that the ACF regulate more of the dirtiest trucks on our roads. I’ve previously blogged about the need to focus on electrifying semi-trucks, but the threshold at which fleets would be regulated under ACF is set at 50, regardless of the likely emissions from a fleet. This means a fleet of 10 semi-trucks would not be covered under the rule, but a fleet of 50 delivery vans would, despite the former fleet polluting at significantly higher rates than the latter.

Not focusing on the disproportionately negative impact of big rigs will allow thousands of the most polluting trucks on the road to continue operating. Many smaller fleets of tractor trucks would be electrified under the drayage requirements of the rule, but communities close to inland warehouses and logistics facilities far from marine ports and railyards may see fewer pollution reductions.

This is a missed opportunity for the rule to guarantee emissions reductions from the most polluting trucks, but it does present an opportunity for future rules and programs to focus squarely on small fleets. A more targeted rule could address some of the perceived concerns around regulating small fleets by creating additional implementation flexibilities, incentives, and/or low- or no-interest loans.

ACF delivers meaningful benefits

The ACF will deliver significant health and economic benefits to the state. CARB’s most recent Environmental Analysis for the rule estimates that the ACF will reduce MHDV emissions of ozone-forming nitrogen oxides by more than 60% and lung-damaging fine particulates by around 35% in 2050. Similarly, the rule is estimated to reduce climate-warming GHG emissions from trucks by around 65% in 2050.

The benefits delivered by ACF will lead to significant decreases in negative health outcomes due to cleaner air and reduced climate-warming pollution. Statewide, ACF is estimated to result in 2,500 fewer premature cardiopulmonary deaths, nearly 900 avoided hospitalizations for cardiovascular and respiratory illnesses, and around 1,200 avoided emergency room visits through 2050. Over half of these health benefit estimates are concentrated in the pollution-plagued South Coast region of California, which is home to some the highest freight traffic in the country.

The rule is also estimated to result in nearly $48 billion in net savings to fleets through 2050. While zero-emissions trucks typically have a higher sticker price than their combustion counterparts today, this price is declining and many fleets will be able to take advantage of purchase incentives in the recently-passed Inflation Reduction Act. The primary factor in the economic benefits to fleets is reduced fuel and maintenance costs, which are estimated to be nearly $59 billion and $25 billion respectively through 2050.

Making electric trucks work for California fleets

Truck fleets have expressed both excitement and concerns about ACF during this time of needed accelerated change. However, the rule as proposed is both reasonable and feasible. Its multiple compliance pathways largely follow declining cost projections for electric trucks, and the rule includes generous exemptions designed to address concerns from fleets and help them comply if obstacles arise.

Flexible compliance pathways

The California Air Resources Board (CARB) has baked in flexibility throughout the ACF by providing multiple compliance pathways for fleets. At the highest level, the rule allows fleets to comply either by requiring only zero-emission truck additions to the fleet after a certain date or allowing fleets to phase in zero-emissions trucks over a longer period of time based on annual fleet milestones.

For example, a fleet comprised mostly of smaller home delivery vehicles may choose to only purchase ZEVs after 2024 to comply with ACF, given these vehicles already have total-cost of ownership upsides. However, a fleet with harder-to-electrify vehicles could choose to turn over their fleet to ZEVs according to the annual milestones over the course of many years. A long-haul trucking fleet, for example, would have until 2030 to prepare their transition and would not have to fully electrify their fleet until 2042, nearly two decades from now.

ACF is not like flipping a switch, but rather a gradual sunrise. This regulation ramps up over the course of nearly two decades and begins with requirements for the easiest-to-electrify trucks, like delivery vans, box trucks, yard tractors, and small charter buses. Here in the Bay Area where I live, it’s not rare to see these ZEVs on the road today. Harder-to-electrify vehicles like long-haul tractors and concrete mixers won’t have to comply at all until the beginning of the next decade, though they may begin to transition sooner given the economic upsides of electric vehicles.  

Electric trucks deliver savings to fleets

In nearly every case, electric trucks will have a preferred total cost of ownership before they are ever regulated under ACF (see figure below). The numbers, in fact, could convince fleets to transition even faster than what is required under the ACF. Some electric truck types like home delivery trucks, large box vans, and refuse trucks can already have a lower upfront purchase price, given the new commercial EV tax credit in the Inflation Reduction Act.

Even in cases where an electric truck’s sticker price is more expensive than a fossil-fueled model, the significant fuel and maintenance costs savings outweigh the additional upfront purchase costs. CARB estimates that fleets will save more than $84 billion in fuel and maintenance costs through 2050 under ACF. Yes, there will be costs for installing charging infrastructure and facility upgrades, but these are far outweighed by the fuel and maintenance savings.

Exemptions for tricky situations

Some fleet owners are keenly aware of the upsides to transitioning to electric vehicles, but have voiced concerns about market uncertainty, delays in installing infrastructure , and, for more rural fleets, whether their electricity grid can handle the additional energy demand. CARB has a fix for that—ACF includes targeted exemptions so fleets can stay in compliance and keep moving people and commodities.

Say you’re a fleet owner and you’ve been planning to transition to ZEVs under the rule. You’ve ordered the trucks you need, planned to install chargers at your facility, and worked with the local utility to ensure adequate electric capacity is available. If any of these processes to transition to zero-emission vehicles are delayed, CARB has included clear exemptions that allow your fleet to still comply with the rule. Although there are more than 160 models of electric MHDVs in nearly every class and configuration today (and more than 200 if you include transit and school buses), if an applicable vehicle isn’t available to meet a fleet’s specific needs, there’s an exemption. Even if you order a vehicle and its delivery is delayed or canceled, there’s an exemption. 

In short, fleets that do their due diligence will not be penalized under the rule. I doubt these exemptions will be tapped often, however, given the slow ramp of ACF requirements, the economic benefits of electric trucks, the quickly expanding market for electric trucks, record federal investments, and substantial incentives for infrastructure development, and growing planning efforts among utilities.    

An opportunity for California to continue leading

Although the federal government has shown some recent momentum towards truck electrification through its approval of the ACT waiver, the Environmental Protection Agency’s recent proposal on zero-emission trucks misses the moment. Together, the ACF and ACT will supercharge the market and adoption of clean trucks in California, but the current draft of the federal greenhouse gas standards for trucks falls short of zero-emission truck market expectations and electrification targets set by manufacturers themselves.

California is leading the way in cleaning up truck pollution and we know that well-designed policies drive innovation and markets. Thanks to the ACT, manufacturers are already rolling out an increasing number of pollution-free MHDVs. Now, CARB should adopt the ACF to speed the shift to all-electric trucks and put us on the road away from diesel pollution and toward a future of cleaner air and a more stable climate.

Fossil fuel power plant owners are facing increased accountability for their air and water pollution, including from a new round of environmental and public health protections that are being rolled out by the US Environmental Protection Agency (EPA). These new protections will include updates to power plant standards on carbon emissions, mercury pollution, and toxic coal ash pollution, just to name a few.

While these new rules will benefit the climate, the environment, and communities all around the country—particularly those near the power plants—fossil fuel companies, and intransigent power and utility companies, stand to lose by being less able to evade accountability for all of the damages caused by their operations. Their disinformation apparatus is therefore starting to spin up in response, pushing out false and misleading narratives that aim to water down the pollution measures as much as possible.

We’ve heard these lazily disingenuous narratives before. After the EPA proposed the Clean Power Plan in 2014, for example, fossil fuel interests and their backers tried to argue that the proposal’s 2030 emission-reduction targets were completely unrealistic, and that the country would see astronomically high costs and blackouts due to the rule. But in reality the proposed emission targets were achieved 11 years early in 2019—without the plan ever even taking effect.

With all that set as the backdrop, there are three basic facts about fossil fuel power plants that everybody should understand before the full barrage of disinformation begins in response to the EPA proposals.

1. Fossil-fueled power is expensive

Even if you put health and environmental costs aside—which you shouldn’t, and I’ll get to those in a second—fossil-fueled power just doesn’t make economic sense given more affordable energy sources.

For natural gas-fired power, the costs of maintaining outdated and inefficient infrastructure–let alone building new infrastructure–like power plants, production wells, and pipelines add up quickly and largely get passed along to consumers in the form of higher energy bills. Further, the going price of gas can be volatile and generally tracks very closely with US wholesale electricity prices, since the country grew so over-reliant on gas power plants throughout the 2010s. This means that when the price of gas spikes–as it did in 2022 amid Russia’s invasion of Ukraine and inevitably will again in the future–the price of electricity for consumers also eventually spikes in response.

These dynamics related to gas, along with sharp declines in the cost of renewable technologies, have rendered large-scale solar and onshore wind the most affordable electricity sources in the country, and that’s not even taking clean energy incentives from federal nor state governments into account, which weaken the economic case for gas-fired power even further.

For coal-fired power, the economic case has been bleak for a long time now, which has brought US coal-fired generation down to less than half of its 2010 level. Last year, for the first time ever, US renewable electricity generation surpassed coal-fired electricity generation. A recent analysis also showed that every single coal plant in the country–except for one newer facility in Wyoming–is more expensive just to continue running compared to building completely new large-scale solar or onshore wind.

And again, none of these data points take into account the insidious health and environmental costs associated with fossil-fueled power, which are astronomical.

Gas plants proposed as of the close of 2021 were estimated to result in up to $74 billion in health costs over their lifetime, and that’s just from the burning of gas at the power plant, ignoring all of the polluting upstream impacts from drilling and transporting gas. Research has shown that the country’s remaining coal plants are responsible for 3,800 premature deaths per year, based on 2019 data. It was even worse when there was more coal-fired generation in 2014, when the plants were responsible for an estimated 91 percent of the 16,000 premature deaths resulting from electricity generation.

The health costs of these pollution sources are also inequitably distributed, since power plants tend to be sited in communities that have lower incomes and education levels. Communities where  predominantly people of color and people who don’t speak English as a first language live also have a disproportionate amount of power plants sited near them. The 2014-focused study referenced above found that Black Americans were most affected by the toxic power plant emissions. Studies have also shown that even when emissions are reduced, the benefits have accrued disproportionately to white and non-environmental justice communities.

And to zoom out a bit, burning fossil fuels is the primary contributor to global climate change, which is driving and exacerbating the once-rare extreme weather events that are impacting people across every part of the country—and across the world. In 2022 alone, there were 18 US climate and weather-related disasters–many of them worsened by climate change–that cost more than a billion dollars each, killing at least 474 people and causing $165 billion in damages.

Just some things to keep in mind when you hear fossil fuel interests and their backers desperately trying to shift the “high costs” argument away from where it truly lies.

2. Fossil-fueled power is not as reliable as once thought

Fossil fuel-fired power plants are proving to be vulnerable during extreme weather events, which is precisely when we need reliable electricity the most. Though the same types of vulnerabilities we’re seeing today have been exposed for quite some time now, they have gotten worse, caused increasing levels of devastation, and are forcing grid operators and policymakers to reevaluate the capability of these plants to help keep the lights on and other critical infrastructure running during dire circumstances.

Gas plants, in particular, have failed miserably to perform during cold weather events due to vulnerabilities along the entire gas supply chain, from the production wells all the way to the power plants. And since the country has become so over-reliant on gas to produce electricity, the impacts of a widespread gas system failure can be particularly devastating, as was the case in February 2021 when Winter Storm Uri tragically led to the deaths of 246 people in Texas, most due to hypothermia. While the gas system was not the only factor at play, the event brought more than 1,000 generating units in the central United States offline or to reduced capacity, nearly 60 percent of which were gas-fired units.

The country’s aging coal power fleet has also failed to perform as expected during recent cold snaps. Just around Christmas time in 2022, coal-fired power was second only to gas-fired power in terms of plant failures during Winter Storm Elliott, according to preliminary data from two large grid operators covering the Midwest and the Mid-Atlantic.

In the case of the Mid-Atlantic grid operator, PJM Interconnection, coal and gas plants together accounted for 91 percent of the megawatt-hours (MWh) that failed to get delivered to the grid. For coal, the leading cause of the plant failures by far was issues with their boilers, which are critical to their ability to generate electricity. For gas, the leading cause of plant outages was fuel supply issues.

It’s not just cold weather either. Thermal power plants, which use steam in their electricity generation process, are also vulnerable during heat waves and droughts, both of which are expected to be exacerbated in a warming world.

Most US fossil fuel generating capacity utilizes steam to generate electricity, which requires water sources that can become less available during drought conditions. Even if there is water available, heat waves can cause the water sources to be too hot, which can reduce the plant’s efficiency or even cause unsafe operating conditions because the plant can’t be adequately cooled. If there isn’t enough water or the incoming water is too hot, plants can be put to reduced capacity or be forced completely offline, increasing the risk of blackouts.

So, the next time you hear fossil fuel interests talking about grid reliability, know that they’re trying to distract you from the host of vulnerabilities of fossil-fueled power and its shortcomings in reliably keeping the lights on.

3. Rapid, deep cuts to fossil fuel use are necessary to address the climate crisis

The power sector is second only to the transportation sector in terms of total US greenhouse gas emissions, making up about a quarter of overall emissions. This means if the country is going to meaningfully address the climate crisis, it needs to rapidly shift to clean resources for generating electricity.

Coal is the most destructive fossil fuel in terms of its climate impact. Modeling has shown that coal power should be phased out entirely by 2030 if the United States is going to live up to its Paris Agreement targets to limit global warming to 1.5 degrees Celsius. As I mentioned above, coal power is on the decline, but the decline isn’t currently fast enough, with too many plants slated to stay online. And remember, almost none of the country’s coal plants are economic anymore, and further, some of them aren’t even compliant with current air quality standards set by the EPA years ago.  

While burning gas at a power plant isn’t as carbon intensive as burning coal, the fuel’s main component is methane, which is more than 80 times as powerful as carbon dioxide at warming the planet over a 20-year time frame. Methane leaks are rampant along the entire gas supply chain, and research repeatedly shows that the problem is worse than previously thought. One recent study found methane from the US oil and gas industry to be 70 percent higher than EPA estimates. When those leaks are factored in, they undermine–and sometimes even outpace–the difference in smokestack emissions.

As long as the gas-fired power system is around, methane leaks upstream of the power plants are likely to remain a feature of that system. State and federal methane protections will drive some of the investments necessary for reducing leaks, but examples to date show challenges with enforcing these measures, and the oil and gas industry just wants to use its own measures of what it considers to be adequate methane controls. In any case, gas is still a dirty fossil fuel that is burned in the power-production process, warming the planet and polluting the air.

The UCS and NREL modeling referenced above show little to no need for new gas plants in the reliable, decarbonized grid of the future. The models also show those plants operating very infrequently in the future, and that further, alternatives to these gas plants exist and more alternatives may be coming. So, the further buildout of the gas-fired power fleet would not only be completely incompatible with addressing climate change, it would also be a huge waste of ratepayer and investor money because that fossil-fueled electricity would mostly have nowhere to go.

Strongest possible EPA standards are needed

After the EPA inevitably gets pushback from fossil fuel companies and backward-thinking power and utility companies on its proposals, the agency must thoroughly interrogate those claims and press forward with the best available science. It must not respond by watering the protections down based on industry disinformation.

EPA has already finalized a rule that aims to address interstate ozone pollution, dubbed the Good Neighbor Plan. Though the new measure is ultimately strong, the agency now expects the final rule to keep thousands of megawatts of polluting fossil fuel plants online for longer compared to its original proposal, after receiving industry pushback.

Industry players will paint a “sky-is-falling” picture about new environmental protections regardless of the substance within the rules, just like they did with the Clean Power Plan and virtually every other regulatory proposal that required them to protect public health at the expense of their shareholders.

But strong environmental protections from the EPA, and on fossil fuel power plants in particular, are essential for safeguarding public health and the climate, particularly for communities that have been burdened the most by both toxic air pollution and climate change and are seeking environmental justice.

The best available science on the environment and public health should inform these critical decisions that affect the health and well-being of people and the planet, not false claims and disinformation.

The next time you hear fossil fuel interests or their backers making dubious claims about protections from fossil fuel power plant pollution, keep in mind these key facts that stand in their way—and that they desperately want you to forget.

In the coming years, Californians will begin to see a massive switch away from highly polluting fossil-fueled trucks to zero-emission electric trucks.

Why? Because last week, the California Air Resources Board (CARB) made history by unanimously adopting what is perhaps the most transformative clean trucks regulation ever considered—the Advanced Clean Fleets (ACF) rule. This rule creates the first-ever, economy-wide, zero-emission standard for large truck fleets. The rule will apply to commercial, federal, state, municipal, and drayage fleets. Additionally, the rule phases out the sale of fossil-fueled trucks in 2036.

Why did the state create this truck rule?

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 a sizable amount of climate-warming greenhouse gas emissions as well. ACF is anticipated to accelerate the annual adoption of zero-emission trucks in California by around 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.

Accelerating the adoption of zero-emission trucks will also provide huge economic benefits to fleets in California because of the savings from electric vehicles’ fuel and maintenance compared to that of combustion vehicles. Statewide, CARB estimates that fleets will save around $48 billion through 2050, even when considering costs related to installing charging infrastructure and retraining drivers and mechanics.

As we celebrate ACF as an important step in addressing our state’s dual public health and climate crises, we must also recognize that more work is needed to accomplish this transition to clean trucks and support their operation.

Unfortunately, smaller semi-truck fleets in the state were left out of ACF’s electrification strategies, despite operating some of the most polluting vehicles on our roads and producing more pollution fleet-wide than fleets of other vehicle types. CARB has recognized the need to focus on smaller semi-truck fleets and plans to address trucks unregulated by ACF through an upcoming Clean Trucks Measure, but this action is several years out. In the meantime, the state should consider additional strategies to influence small semi-truck fleets’ transition to zero-emission models, including expanded incentives and affordable loan programs.

Setting up more charging infrastructure will be critical

The most vital part of planning and successfully executing the wide-scale deployment of clean trucks and buses in California is charging infrastructure. The California Energy Commission estimates that 157,000 chargers need to be installed by 2030 to support California’s heavy-duty vehicle electrification goals. UCS anticipates the vast majority of the chargers needed will be lower-powered chargers installed at truck depots for overnight charging. Both the state and federal governments have committed billions of dollars to spur this work.

Last November, the California Energy Commission approved $1.7 billion for medium- and heavy-duty truck charging as part of the $2.9 billion Clean Transportation Investment Plan Update, and as of December 2022, the Public Utilities Commission approved nearly $800 million dollars in utility programs for medium- and heavy-duty charging infrastructure. At the federal level, the Inflation Reduction Act allows for a tax credit of up to $100,000 per commercial charger.

However, there is much to be done to coordinate and scale up planning for and deployment of charging projects to meet the appropriately ambitious timeline for truck electrification. That is particularly true for public-facing fast chargers for long-haul trucks, similar to the fueling stations we see at truck stops today. Efforts are ongoing, and I and the UCS team are excited to continue pushing for more action on infrastructure as the ACF is implemented.

Now that we have a clean trucks sales standard, generous purchase incentives, and a clean fleets standard in ACF, we must focus on accelerating the deployment of charging infrastructure powered by renewable energy and programs tailored to the specific needs of small tractor fleets.

I am excited to continue working with organizations in California to achieve a future where zero-emissions trucks are the norm, a society where all people have equal access to clean air, and a stable climate that supports a healthy society and robust biodiversity in nature.

Earlier this month, the Environmental Protection Agency’s (EPA) Clean Air Scientific Advisory Committee (CASAC) released a draft set of recommendations calling on the EPA to tighten its current standard for ground-level ozone pollution to protect public health. Specifically, six out of seven CASAC members stated that the EPA needs to lower the primary standard for ozone pollution to somewhere between 55 to 60 parts per billion (ppb) from the current standard of 70 ppb.

But will the EPA follow CASAC’s recommendations? The agency has a checkered history on this issue and the Biden administration’s take on ozone standards is already foreshadowing a potentially problematic ruling.

Ground-level ozone pollution is a nasty air pollutant that can cause lung problems and asthma attacks. If you’ve ever been outside in an urban environment on a hot sunny day and wondered why the air just seemed worse in your lungs—think sore and scratchy throat or difficulty breathing while doing exercise—you have likely experienced some of the health effects associated with ozone pollution. Unlike other major air pollutants, ground-level ozone is not emitted directly into the air but is created by chemical reactions between nitrogen oxides and volatile organic compounds, meaning that ozone pollution is tied to sources that emit these precursor chemicals, such as heavy duty vehicles.

Studies have shown that people experiencing elevated days of ozone pollution can result in increases in missing school or work and visiting the hospital or emergency room for asthma exacerbations; ozone pollution even increases the risk of premature death. And, as the CASAC draft report discusses in depth, some groups of people face an elevated risk of health effects, including children, people with asthma, outdoor workers, and communities of color.

Sadly, the process of setting an outdoor ozone pollution standard has a long history of being undermined by political leaders under the Bush, Obama, and Trump administrations. This track record is even more troubling considering that the Clean Air Act requires that only science can be used when setting the standard for major ambient air pollutants, something I covered in depth in a previous blog post.

As the EPA works through the process of setting a new ozone pollution standard, it is unfortunately all too easy to imagine a future where history repeats itself and the EPA once again sidelines science and fails to fully protect people from this dangerous air pollutant.

Setting the ozone standard is supposed to be a fully science-based process…

CASAC is a group of highly respected independent experts tasked by the Clean Air Act to provide science-based advice on national ambient air quality standards, including on the recent processes to update the EPA’s particulate matter standard. And it is a big deal when CASAC weighs in on the EPA’s scientific and policy reports for a pollutant such as ground-level ozone.

Here’s how the process is supposed to work. For major ambient air pollutants, the EPA is charged with assessing the state of the science every five years or so, producing two important assessment reports. One EPA report examines the latest scientific evidence on the air pollutant and how it can lead to health and welfare effects; the second report uses this science as a basis to form a set of policy options, which the agency can then use during its rulemaking process.

CASAC reviews these reports to, in essence, give the agency a nuanced thumbs up or thumbs down about them and to provide a set of evidence-based recommendations detailing what the air pollution standards should be. While the EPA is not required by law to follow CASAC’s recommendations, it is a really bad look if the agency fails to do so; the EPA administrator is even required to explain the reasoning for deviating from CASAC recommendations. And honestly, there aren’t a lot of good reasons to ignore CASAC’s recommendations, at least if you believe that the best available science should drive the process.

…But history shows a different story

There is ample reason to be concerned about whether the EPA under the Biden administration will fully commit to this science-based process. If we look at the history of how the ozone standard has been set during the 21^st century, we see a road of broken dreams, in which the EPA has promised to follow the science only to scuttle off and set the standards far too high when push comes to shove.

UCS has been watchdogging the issue since 2007, when we called out the Bush administration for blatantly ignoring CASAC’s recommendations to set the ozone standard to between 60 to 70 ppb. For reasons that had nothing to do with science—President Bush intervened shortly before the finalized regulations were to be issued and pressured the EPA to do an “emergency rewrite”—the EPA administrator set the ozone standard to 75 ppb.

The Obama administration continued this ugly tradition. In 2011, President Obama interfered with the EPA and pressured the agency to withdraw their draft ozone rule, delaying the rulemaking process by two years. In 2014, when CASAC weighed in and suggested a standard between 60 to 70 ppb, the advisory committee was explicit in stating that setting a standard at 70 ppb would be a very bad idea. The science at the time was showing that this measure would likely not protect public health, especially in groups of people who are more vulnerable to health impacts from ozone pollution. In 2015, when the EPA set what is now our current ozone standard of 70 ppb, the agency chose to ignore CASAC’s concerns about setting the standard at such a high level.

And, perhaps unsurprisingly, the Trump administration took this sidelining of science to a whole new level. In 2017, EPA administrator Scott Pruitt tried to delay the implementation of the 2015 ozone standard based on what he termed “insufficient scientific evidence,” until a major lawsuit forced the EPA to implement it. In 2018, the Trump administration completely nixed the EPA’s ozone review panel – an advisory committee that specialized in the science of ozone pollution and helped inform CASAC’s science-based recommendations. In 2020, the EPA attempted to issue a new rule on the ozone standard using a flawed and expediated process and concluded that the status quo of 70 ppb standard was good enough.

The current EPA is no exception

The EPA under Biden administration has already shown some signs of continuing this problematic history. Last year, the EPA issued a draft policy assessment that concluded that the 70 ppb is just fine. The agency concluded this despite an increase of strong scientific evidence showing that levels of ozone pollution below 70 ppb can be dangerous to human health (see the American Lung Association’s recent public comment to the EPA for further information).

CASAC members were so disturbed by the EPA’s draft policy assessment that they took the rare and unprecedented step of pausing the review process. The advisory committee said that they can’t weigh in on the policy options and instead needed to go back a step to review the science.

In the recent draft report released this month, the advisory committee once again hammered home this point and chided the current EPA on their poor procedures in reviewing the science, citing in particular how the agency prioritized certain forms of scientific evidence over others in a way that would drown out the health effects experienced by more sensitive populations, especially children, outdoor workers, and people with asthma. CASAC’s conclusion: EPA needs to drastically lower the standard to 55 to 60 ppb in order to be protective of public health.

Seriously EPA, do better and follow the science

In the next few month, the EPA faces a major choice. Will it follow the recommendations of CASAC to the fullest extent possible and thereby provide the strongest science-based protections to protect the country from ground-level ozone pollution, including populations most at risk of developing health effects when exposed to ozone? Or will the agency choose a standard that deviates from the best available science—as it did under all three of the most recent presidential administrations—and thereby fail to protect the health and safety of people across the nation from this pollutant?

If the EPA truly believes in its science-based mission statement to “protect human health and the environment,” it will buck this temptation and follow CASAC’s recommendations to tighten the ozone standard and safeguard the health of millions of people.

California has a long history of poor air quality and much of the pollution fouling the air is from cars and trucks.

As early as 1966, the state began to take regulatory action to reduce pollution from passenger cars and trucks. As a result of continuing progress on regulations, the air-polluting emissions of new passenger vehicles currently for sale are thankfully much lower than those of older vehicles. However, the emissions from older vehicles still produce significant air pollution.

To learn more about who in the state is exposed to this harmful exhaust, UCS partnered with The Greenlining Institute to analyze the location of these vehicles and their emissions. In this new report, we found that the exposure to pollution from older gasoline and diesel vehicles is inequitable. The harms fall disproportionately on Latino and Black Californians, lower-income households, and communities the state designates as disadvantaged.

California already has programs that help low-income residents buy or lease cleaner vehicles, but the state can save lives by better targeting these programs to disadvantaged communities with high concentrations of older cars.

Older vehicles pollute more and are a fraction of those on the road

Beginning with model year 2004, California has implemented Low-Emission Vehicle (LEVII) tailpipe pollution standards for passenger vehicles. Older vehicles (pre-2004) make up 19% of the state’s passenger vehicles and only 12% of miles driven, yet they emit almost 3 times as much smog-forming, nitrogen-oxide pollution as all 2004 and later vehicles combined.

These older vehicles are responsible for 73% of all nitrogen oxide exhaust from passenger vehicles and 64% of reactive organic gases. These pollutants react in the atmosphere to form harmful particulate matter pollution known as PM_2.5.

Exposure to harmful air pollution from older vehicles is inequitably distributed

Using an air-quality model and data from the California Air Resources Board about the location of vehicles and their emissions, we estimated the formation and transport of PM_2.5 pollution from the use of older passenger vehicles (defined as model year 1976 through 2003) and newer ones (model year 2004 through 2021). Combining the PM_2.5 pollutant concentration with US Census data, we estimated the exposure of Californians to harmful air pollution from older cars.

Our analysis shows that PM_2.5 exposure from the use of pre-2004 vehicles is inequitably distributed across racial and demographic groups in California. The communities with the highest pollution burden due to PM_2.5 from older vehicles–more than twice the state average–have a higher percentage of low- and moderate-income households than areas unburdened by air pollution from these vehicles. In the parts of the state with the highest exposure to PM_2.5 pollution from older vehicles, more than half of households have an income of less than $60,000 a year. In areas with the least exposure, only 35% of households have an income of less than $60,000 a year.

We also found racial and ethnic disparities in the exposure to air pollution from older vehicles. White Californians are on average exposed to 20% lower concentrations of PM_2.5 than the state average. Latino Californians are exposed to 19% higher concentrations, and Black Californians are exposed to 12% higher concentrations.

Communities with the highest exposure to PM_2.5 from older vehicles–greater than twice the state average–are home to much higher proportions of Latino and Black people than the state as a whole. In these areas with the highest exposure, 67% of the population are Latino and 8% are Black; the state as a whole is 40% Latino and 5% Black. In contrast, those same areas of highest exposure are only 13% White; the state is 36% White.

Rural areas have a higher proportion of older vehicles

While Southern California’s urban areas have the most older vehicles (and highest exposure to the resulting pollution), rural areas have higher proportions of older vehicles. For example, in rural Modoc, Trinity, and Sierra counties, more than 40% of vehicles are model year 2003 or older. In contrast, Orange, San Francisco, and Riverside counties, all of which are much more urban, have the lowest percentages of older cars.

Pollution from older vehicles leads to premature deaths

To estimate the health impacts of PM_2.5 pollution exposure resulting from older vehicles, we examined two scenarios considering the emissions from engine starts, evaporative emissions, and driving. These scenarios provided a range for the estimated premature deaths in California.

One scenario only considered cold-start emissions and assumed those happen where the vehicle is registered. The second scenario assumed that all tailpipe emissions happen where the vehicle is registered. Air quality modeling allows us to estimate the exposure to the PM2.5 pollution that results from these emissions and the resultant premature deaths. We estimated that older-vehicle emissions led to between 97 and 421 premature deaths per year.

These four policies can reduce inequitable exposure to pollution

Based on the impacts of older cars on local air quality and public health, it is imperative that California’s incentive programs for retiring and replacing vehicles prioritize getting the oldest cars off the state’s roads.

Policymakers also should ensure that programs benefit disadvantaged and low-income communities. Moreover, when developing new policies and programs, California should involve–and in meaningful ways–the communities most impacted by older-vehicle emissions. This will help the state identify approaches to reducing the inequitable distribution of this pollution from older passenger vehicles.

UCS and The Greenlining Institute recommend the following changes in state policies and programs:

• Prioritize incentives toward priority populations owning old cars. State agencies should integrate programmatic changes to existing incentive programs, such as Clean Cars 4 All and the Clean Vehicle Assistance Program, to prioritize investments in low-income and disadvantaged communities with high concentrations of older cars.

• Target outreach and education. State and local agencies should target their limited outreach and education funds to households in areas with high concentrations of old cars and limited uptake of zero-emission vehicles.

• Provide transportation solutions that go beyond private passenger vehicles. Even as California attempts to reduce vehicle miles traveled, it continues to invest in vehicle incentive programs that prioritize car ownership. Agencies should consider further funds for programs that promote alternative modes of transportation, such as public transportation walking, car sharing, and e-biking.

• Evaluate and adjust incentive programs based on changing conditions in the electric vehicle market. Despite declining prices for electric vehicles, the pandemic’s impact on the supply of electric vehicles has created barriers to the purchase of both new and used electric vehicles. California should continue to evaluate and adapt its incentive programs to best assist people based on their needs. While a complete switch to zero-emissions technology will happen in the longer term, the current limited supply of electric vehicles can make their purchases more difficult in the near term. Thus, the state should encourage drivers to switch to cleaner and cheaper-to-fuel vehicles, including both zero- and low-emissions vehicles.

A cleaner, safer transportation future for all Californians is possible. To realize it, the state must commit to retiring the dirtiest vehicles on the road. With sustained investment and targeted policies, California can protect its vulnerable communities from harmful air pollution, saving money and lives.

A few months ago, I was reviewing the findings of a study my organization, the Union of Concerned Scientists, just concluded on facilities that use ethylene oxide (EtO), a carcinogenic gas, to sterilize medical equipment, spices and dried food, as well as manufacture other chemicals.   

I came to a sudden halt when I came across the listing of two spice sterilizing facilities–of four plants located in Maryland–that are only two and a half miles from my house. Alarmed, I spent the following two weeks learning as much as a could about EtO and driving around the Jessup and Hanover plants to try to figure out how far EtO “fugitive emissions” leaking from the buildings could travel. Could my family be affected?

It’s likely our neighborhood was most exposed from the time the neighborhood was developed in 2007 until 2014, when the plants installed scrubbers in their smokestacks. Since then, my husband and I were, at the very least, exposed when we biked through the area around the Hanover plant that the Environmental Protection Agency (EPA) determined exceeded the federal cancer risk threshold.

It turns out that we are among the lucky ones. The plant workers and people living and working within a fifth of a mile of the facilities are most at risk, according to the EPA. Beyond that point, the agency says the emissions start to dissipate. EtO, which is generally at ground level in the air, breaks down by half (in other words, its half-life) in 69 to 149 days.

However, it’s not only the plants that emit EtO that you have to worry about. EtO-sterilized products stored in offsite warehouses can continue to off-gas, or emit, EtO, for a few days after they are sterilized. One of those warehouses is also about 2.5 miles from my neighborhood. Data collected by an air monitor outside a warehouse in Georgia revealed the warehouse released nine times more EtO than released by the plant that sterilized the product.

When my neighbors and I attended a community meeting the EPA held in Jessup earlier this month, my alarm only grew. Agency officials told us that EtO is one of the most dangerous chemicals the agency regulates. There is no safe level. Workers at some of the 96 commercial sterilizers around the country have a 1 in 10 cancer risk based on the EPA’s exposure model.

The agency determined the chemical’s potency back in 2016–finding that it was up to 60 times more toxic than previously understood–but it took a recent lawsuit by Earthjustice for the agency to act.

Nearly 40 people–mostly from predominantly Black and Brown neighborhoods near sterilizer plants–recently traveled to Washington, D.C., to meet with EPA officials about its proposed regulations, which the agency released in May. Their stories were devastating.

• A woman who lives near a plant in Laredo, Texas, which uses a whopping 1.5 million pounds of EtO a year, and her daughter who has leukemia attended the meetings. A Texas health department study found a statistically significant cancer cluster of the types EtO causes, including leukemia, in three census tracks around the plant. The local government and school district now are spending $250,000 to install air monitors in Laredo to collect data on the community’s exposure.
• A grandmother from Salinas, Puerto Rico, who has lived only a few blocks from a plant for 45 years said there have been more than 100 deaths from cancer in their neighborhood. While the plant has promised to install scrubbers to limit EtO emissions from its smokestack, it remains unclear when that will happen. I cannot emphasize enough how astonishing it is that the facility still has not installed these additional control measures.
• A woman from Memphis, Tennessee, who grew up across the street from a sterilizer said just about her entire family has cancer. Many of her husband’s relatives, who grew up in the same neighborhood, also have cancer.

To be sure, it is not easy to regulate EtO, which is exceedingly difficult to contain. Plants in California that have complied with state regulations requiring them to seal off the sterilizer–which the proposed EPA regulations also would require–still emitted harmful EtO levels inside and outside of the plants.

The Food and Drug Administration is trying to identify alternatives to EtO and, in the meantime, insists that medical device sterilization must not be interrupted. But that makes the neighborhoods surrounding these plants, especially the ones created by redlining, sacrifice zones.

In fact, not all medical equipment requires this carcinogenic gas to be adequately sterilized. Just last year, the International Organization for Standardization determined that hydrogen peroxide is a valid EtO substitute. Meanwhile, the European Union has outright banned EtO for sterilizing spices. The United States must follow suit.

The demands made by communities represented by Earthjustice are more than reasonable. They are calling for the new EPA regulations to cover off-site warehouses. Without that requirement, companies will have an incentive to move products from regulated facilities to unregulated sites. They also want the EPA to require fenceline air monitoring around commercial sterilizers, so they know what the plants are emitting. And finally, they want the agency to implement the new regulations more quickly than the proposed 18 months. Residents living near these plants have been subjected to this carcinogenic gas for decades. The sooner they are protected, the better.

The EPA comment period for EtO regulations closes today. Everyone should lend their voice to this fight. Check out UCS’s comment guide on this rule—your comment doesn’t have to be long and can be done in under 10 minutes!

Over the past year, we’ve seen significant momentum toward an era of zero-emission trucks and buses. Perhaps most notable were California’s adoption of the world’s first economy-wide zero emission truck and bus fleet standard and the first nationwide purchase incentives for zero-emission medium- and heavy-duty vehicles in the Inflation Reduction Act (IRA). While both actions will stimulate the market for zero-emission medium- and heavy-duty vehicles and lead to accelerated adoption, much more work needs to be done to get us on track to a more equitable zero-emission future.

The Environmental Protection Agency (EPA) is currently developing a regulation to reduce climate-warming greenhouse gas emissions (GHG) from trucks, known as the Phase 3 GHG standards, which would in theory result in increased adoption of electric trucks. While this represents a huge opportunity to accelerate the adoption of zero-emission trucks, as my colleague Dave Cooke pointed out, the proposed standards would fail to even keep pace with electric truck adoption projections—never mind accelerate it.

There are many reasons EPA should pursue a much stronger standard than what they’ve proposed—first and foremost being the outsized impact trucks have on air quality and climate change. Additionally, the economics, growth in availability, and future markets for electric trucks all point in the right direction.

Zero-emission trucks and buses are reaching upfront cost parity

Price is often seen as a primary barrier to the adoption of zero-emission vehicles, as electric models often have a higher sticker price than combustion models. Retail prices for electric trucks and buses are declining and this trend is projected to continue. Despite this, and the significantly lower fuel and maintenance expenses of electric trucks, upfront price can still be a barrier. Thankfully, the up-to-$40,000 purchase incentive for commercial clean vehicles in the IRA helps to bridge this gap and will stimulate the market, which will in turn accelerate price parity. Notably, draft guidance recently released by the Internal Revenue Service (IRS) confirms that tax-exempt entities, including cities, could be eligible for this and certain other IRA incentives.

Studies examining the current and future market for zero emission medium- and heavy-duty vehicles have been published since the IRA’s passage last year and are showing promising results. Research published by The International Council on Clean Transportation (ICCT) earlier this year suggests that electric trucks and buses in most weight classes will reach upfront price parity before the end of the decade. Another study by BloombergNEF looked at total-cost of ownership (including upfront and ongoing costs like fuel and maintenance) and found that even the more expensive electric tractor trucks would achieve total-cost parity by 2030.

Timeline of Anticipated Retail Price Parity Between Heavy Duty Battery Electric Vehicles and Internal Combustion Engine Vehicles

Estimates are based on tax credits for qualified commercial vehicles under the IRA. Adapted from Table A2 in ICCT’s January 2023 study mentioned above.

The availability of electric trucks and buses continues to grow

The number of electric trucks and buses on the market has increased substantially over the past few years. Today, there are zero-emission medium- and heavy-duty vehicles available in every weight class and for most uses—from tractor trucks to coach buses. In the U.S. and Canada, more than 180 models of these vehicles are available, according to CALSTART’s Zero-Emission Technology Inventory. If you throw transit buses into the mix, the number jumps to over 200.

While this growth is meaningful, about a 30% increase in availability in just 3 model years, the market here in North America significantly trails that of China, where more than 260 models are available. The good news on this front is that California’s Advanced Clean Trucks (ACT) rule, which requires manufacturers to produce and sell an increasing amount of zero emission medium- and heavy-duty vehicles, is fully set to kick in next year. This will help to accelerate the availability and deployment of electric trucks and buses. So far, eight states (Colorado, Massachusetts, New Jersey, New York, Oregon, Rhode Island, Vermont, and Washington) have joined California in adopting the ACT, representing about 20% of the national market. Several others, including Maryland, are anticipated to adopt the rule in the coming months.

In the absence of a strong federal standard, the continued expansion of ACT is foundational to growing the market for zero emission medium- and heavy-duty vehicles.

Current market projections outpace EPA’s proposal

Both the positive economics and state regulations like ACT are pushing the market for electric trucks forward. Although electric trucks and buses are a small fraction of the total medium- and heavy-duty vehicles sold today, recent studies suggest significant market growth through the end of the decade.

The ICCT study I mentioned above projects significant growth in battery-electric truck and bus sales across the board, even in a moderate adoption scenario. In a few select cases, like box trucks and trash collectors, battery-electric models are anticipated to outpace diesel models by the end of the decade. This is driven by positive economics, incentives, and regulations like ACT. Each of these also creates additional market certainty, which accelerates technology development and infrastructure deployment.

Projected National Market Share of Heavy Duty Zero-Emission Vehicles and Diesel Vehicles

Table adapted from Table A3 in ICCT’s January 2023 study mentioned above. Rounding may cause percentages to not add to 100%. Zero-emission vehicles include both battery-electric and hydrogen fuel cell vehicles.

However, ICCT projections for some of the most polluting trucks, particularly long-haul tractor trucks, show that much more work is needed. Electrifying tractor trucks is essential to affecting equitable access to clean air given that tractor trucks make up the largest share of air pollution from medium- and heavy-duty vehicles, especially in port and freight-adjacent neighborhoods. California’s recently passed Advanced Clean Fleets (ACF) standard, which requires the state’s largest truck fleets and all trucks carrying containers from ports to transition to zero-emission vehicles over time, is a huge step in the right direction, but nationwide action is necessary to affect a meaningful transition.

As I mentioned before, in nearly every case, market projections for zero emission medium- and heavy-duty vehicles sales far outpace EPA’s current proposal for the Phase 3 GHG standard. When it comes to protecting public health and the environment, we simply cannot afford to take regulatory approaches that don’t accelerate the market for zero-emission trucks. Yes, states like California are heading in the right direction, but we need strong national standards to bring the necessary scale and pace of progress.

Comparing Heavy-Duty Zero-Emission Vehicle National Market Share Estimates: EPA’s Phase 3 Standard vs ICCT Projections

In nearly every case, EPA’s estimates for zero-emission vehicle adoption from its Phase 3 rule trail market projections. Table adapted from Table II-24 in the Phase 3 proposal and Table A3 in ICCT’s January 2023 study mentioned above.

We need a national 100% zero-emission vehicle sales standard

Despite the positive outlook for zero emission medium- and heavy-duty vehicles uptake, we still have a long way to go, and more work is required to deliver a clean, equitable, and cost-effective freight future.

In its recent study of the state of electric vehicles, BloombergNEF reports that “strong additional measures [are] needed urgently” to get the worldwide medium- and heavy-duty vehicles market on track for 100% zero-emission vehicle sales by 2050. Here in the U.S., I believe–and the research shows–we can and should get to the 100 percent sales mark far sooner.

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.