Date: December 4, 2024
To:
Acting Secretary Jessica Shirley
Pennsylvania Department of Environmental Protection
400 Market Street
Harrisburg, PA 17101
Re: Adopting the Advanced Clean Trucks (ACT) Rule and moving forward with the rulemaking process early in 2025
Secretary Shirley,
The 18 signed environmental and human health organizations representing tens of thousands of members across the state urge you to adopt the Advanced Clean Trucks (ACT) Rule and to move forward with the rulemaking process early in 2025. Initiating the rulemaking process expeditiously next year with an Environmental Quality Board vote to adopt the proposed rule would provide Pennsylvania with a pathway for successful adoption on or before January 1, 2027. This timeline would allow for ACT compliance to begin with model year 2029 vehicles pursuant to Section 177 of the Clean Air Act.
Pennsylvania has taken initial steps toward reducing air pollution from its roads through the Pennsylvania Clean Vehicles Program, which targets emissions from light-duty vehicles, but the state must also address the harmful emissions from medium- and heavy-duty vehicles.
Adopting the ACT Rule will help achieve the goal of Executive Order 2019-01 for an 80% reduction of greenhouse gasses by 2050 from 2005 levels. This is also in line with the joint memorandum of understanding (MOU) and the resulting Multi-State Zero Emission Vehicle Task Force between Pennsylvania and 16 other states plus DC to adopt 30% zero emission medium- and heavy-duty vehicles by 2030 and 100% by 2050.
Furthermore, section 4.5.8 of Pennsylvania’s 2024 Priority Climate Action Plan (PCAP) goals include to “accelerate the adoption of zero-emission medium- and heavy-duty vehicles (MHDVs) including battery electric, hydrogen fuel cell, and plug-in hybrid vehicles.” ACT provides flexible compliance options for truck manufacturers to achieve certain sales targets and would ensure that buyers of zero-emission MHDVs in PA have a full range of purchase options. The ACT Rule will undoubtedly accelerate the adoption of zero-emission medium- and heavy-duty vehicles and increase our chances of meeting our emissions reduction goals. A recent study projected that ACT adoption in Pennsylvania would reduce carbon pollution by 50 million metric tons and achieve nearly $2 billion in monetized health benefits by 2050.
There are also many existing incentive programs to complement and ease the adoption of the ACT Rule. The Pennsylvania Department of Environmental Protection offers the Alternative Fuels Incentive Grants (AFIG) and the Driving PA Forward program. The Pennsylvania Department of Transportation (PennDOT) implements the National Electric Vehicle Infrastructure Program (NEVI) and the Charging and Fueling Infrastructure (CFI) Grant Program. And, this year the White House released the National Zero-Emission Freight Corridor Strategy, designed to guide truck charging infrastructure deployment. These programs provide incentives and a roadmap for clean vehicle purchases and charging infrastructure build-out.
Adoption of the ACT Rule is critical to addressing Pennsylvania’s long-standing air quality attainment challenges and putting the Commonwealth in a position to potentially redesignate the Philadelphia area to attainment if recent improvements in air quality persist. The Philadelphia-Wilmington-Atlantic City area is currently designated Nonattainment under the 2015 8-hour National Ambient Air Quality Standards (“NAAQS”) issued by the U.S. Environmental Protection Agency. Over eight million Pennsylvanians, comprising over sixty percent of Pennsylvania’s entire population, continue to live in areas that are designated as failing to meet this 2015 health-based NAAQS and its 2008 predecessor. High ozone levels have documented adverse health impacts, including higher levels of asthma and asthma mortality.
Pennsylvania’s historically high ozone levels exacerbate race- and income-based health disparities and have a major impact on our environmental justice communities. For example, EPA’s EJScreen Tool indicates that Philadelphia is in the 83rd percentile for the ozone EJ index, an index that combines ozone levels with demographic data (by averaging populations of low-income people and people of color). In other words, only 17% of the U.S. population has worse ozone pollution impacts than Philadelphia, considering the demographic factors of income and race. Reducing NOx emissions, precursors of ozone is therefore essential for mitigating the adverse and unjust health impacts affecting Pennsylvania residents.
According to the American Lung Association’s “Delivering Clean Air” report, the ACT Rule would result in $49.9 billion of public health savings, and avoid 4,581 premature deaths, 88,010 asthma attacks and 432,212 lost work days in Pennsylvania through 2050, if paired with a transition to all renewable electricity. Pennsylvania's Climate Action for Environmental Justice Communities outlines how transitioning to zero-emission for medium- and heavy-duty vehicle fleets will improve health outcomes.
As such, the undersigned groups urge DEP to quickly start the process of adopting ACT Rule – to help achieve Pennsylvania’s climate goals, to build on the success of other Pennsylvania initiatives to clean the air and protect the health of millions of Pennsylvanians statewide.
Signed,
Sierra Club, Pennsylvania
Jewish Earth Alliance PA
PennFuture
Generation180
Pennsylvania Interfaith Power and Light
Alliance of Nurses for Healthy Environments
Plug In America
GreenLatinos
The Sunrise Project
Audubon Mid-Atlantic
Vote Solar
Evergreen Action
Environmental Defense Fund (EDF)
CALSTART
Natural Resources Defense Council (NRDC)
Clean Air Council
Ceres
Moms Clean Air Force