By: Elizabeth Brandt, National Field Manager, Moms Clean Air Force
Date: June 28, 2022
About: Waiver Requests for California's Advanced Clean Trucks (ACT), Zero Emission Airport Shuttle, and Zero-Emission Power Train Certification Regulations; Omnibus Low NOx Regulation; and HD Emission Warranty Regulation, Docket ID No. EPA-HQ-OAR-2022-0331
To: Environmental Protection Agency
Hello, and thank you for listening to my testimony today. My name is Elizabeth Brandt. I am a social worker and a National Field Manager for Moms Clean Air Force. Moms Clean Air Force is an organization of more than one million parents across America who are taking action against air pollution and climate change.
I thank this administration for acting swiftly on a national clean trucks plan, but I am concerned that EPA might not approve California’s waiver requests in full. It is important to allow California and other states to create the strongest possible limits on heavy duty vehicle pollution and rules to accelerate the transition to zero emissions vehicles. We need to clean the air as soon as possible, and California’s authority under the Clean Air Act to set more stringent emissions standards is crucial to cleaning the air throughout all section 177 states. I live in Maryland, and I’m proud that my state has chosen to protect us from pollution by setting stricter vehicle emission standards as allowed by section 177 of the Clean Air Act. In fact, Maryland is moving toward adopting one of the waivers on heavy duty vehicle pollution that is at issue in this rulemaking.
Last summer, I spent some time in central Los Angeles helping my friend Margaret with her foster baby. My friend’s apartment is across the street from Interstate 5. A busy city park, with soccer fields and a senior center, is just over the fence from the freeway. This is a picture of environmental injustice. Just think of what the soccer players on that field breathe in every day. Think of what the babies in the apartment building across the street are breathing.
This year Los Angeles ranked as the most polluted city in America for smog/ozone, a ranking it’s earned many times before. It’s also receiving an “F” for particle pollution from the American Lung Association. Los Angeles is an extreme case—but so are the other seven California cities that round out the American Lung Association’s top 10 list of smoggiest cities. I applaud California for taking decisive action to fix this situation. The State of California must protect its residents, and these waivers are just one way in which California is trying to do so. The EPA must not stand in the way.
While California represents a very difficult air quality scenario, cities across America face the same challenges. Much of our affordable housing stock is a stone’s throw from a major highway or truck route. In my former life as a social worker for Washington State, I saw this all the time. In Seattle, high schools, medical clinics, nursing homes and foster homes all hug major truck routes and I-5. I am glad my home state has chosen to adopt the Advanced Clean Trucks rule- Washingtonians demonstrably need more protection from truck pollution.
EPA must issue these waivers quickly and in full to deliver on President Biden’s climate and environmental justice commitments. Any delay in implementation of California’s clean truck rules will cause harm to the tens of millions of Americans who live near high-traffic corridors, including many environmental justice communities, and set back greenhouse gas emissions reductions from the transportation sector. The facts are clear: exposure to diesel soot pollution causes asthma, lung disease, and death. Giving states the option to adopt the earliest and strongest possible clean, electric truck standards is necessary to fight environmental racism and provide relief to freight corridor communities.
Vehicle manufacturers have the technology to meet the goals of California’s rules, and many recent analyses have shown that fully zero-emission trucks will be cheaper to purchase and operate than diesel-trucks within the timeframe of these standards. Truck companies are already investing in this technology. Pilot programs across the country have proven that electric trucks and cleaner diesels are ready for the marketplace. Fleets are already putting in orders. There is no reason to delay the implementation of lifesaving cleaner truck technologies.