By: Molly Rauch, Public Health Policy Director, Moms Clean Air Force
Date: April 12, 2022
About: Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine and Vehicle Standards Proposed Rule, Docket ID No. EPA-HQ-OAR-2019-0055
To: Environmental Protection Agency
Thank you for the opportunity to testify today. My name is Molly Rauch, and I am public health policy director for Moms Clean Air Force. I live with my family in Washington, DC.
EPA’s proposal is a welcome step forward. But it doesn’t go far enough. Moms and dads across the country want to see a rapid transition to zero-emitting trucks. We need cleaner air for our children and our communities.
Today you will hear from dozens of Moms Clean Air Force volunteers, organizers, and staff from across the country who support stronger tailpipe emissions standards for trucks. For any child with asthma, any adult with COPD or lung cancer, anyone with cardiovascular disease, anyone with a weakened immune system, air pollution from heavy-duty vehicles can make your disease worse. If you are pregnant, if you are an infant or child, if you are an older adult, you are especially vulnerable to air pollution. And despite overall progress in cleaning up our nation’s air over the past several decades, 40% of Americans live in places where the air is unhealthy to breathe, according to the American Lung Association. Transportation pollution is a major contributor to that unhealthy air.
Here in DC where I live, we have a problem with high ozone days. DC has a failing grade for ozone. My teenage boys, whose lungs are still developing, are athletes who often spend their afternoons and weekends outside, breathing in high levels of a pollutant that makes their lungs more vulnerable to infection and interferes with normal lung development. Much of this pollution comes from the tailpipes of trucks.
The trucks proposal should be strengthened. On the NOx portion of the rule, proposed Option 1 is insufficient and should be significantly strengthened. Option 1 would result in higher emissions of smog and soot-causing NOx pollution than California’s Heavy Duty Omnibus rule, which should be the bare minimum baseline for smog and particle pollution reduction goals.
On the greenhouse gas portion of the rule, EPA’s proposal is weak and reflects neither the urgency of the climate crisis nor the rapid advancement in zero-emission truck technology. The proposed standards will not accelerate the deployment of zero-emission electric trucks. In fact, the market is moving faster than what these rules are predicting.
These standards must go farther in reducing deadly NOx pollution, and they must put our national bus and truck fleet on a clear path to 100% zero-emission all-electric vehicles as quickly as possible.
Please strengthen the final standards, to better protect children, people with asthma, older adults, and other vulnerable groups from the health harms of air pollution. Everyone has the right to breathe clean air.