Date: May 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 your recently announced proposal to address pollution from medium and heavy-duty trucks. We, the undersigned Arizona community organizations, elected officials, and community members are joining together to ask for stronger heavy-duty engine and vehicle standards. We are concerned about the impacts of the climate crisis on our children and communities, and do not feel that the proposal goes far enough to address the urgency we are facing.
We are writing to you today to ask that you please consider strengthening the proposed standards before they are finalized. The transportation sector is the leading source of climate pollution in the US.
The climate crisis is harming our families and our communities today and medium and heavy-duty vehicles are a major contributor to this pollution. In fact, despite making up only 10% of the total number of vehicles on the road, medium- and heavy-duty trucks contribute a quarter of the total climate pollution from the transportation sector.
Trucks are also major sources of other deadly air pollution. Medium and heavy-duty trucks account for more than 60% percent of the deadly particle pollution that comes from vehicles. Particle pollution cuts short tens of thousands of US lives per year and contributes to the heavy burden of asthma on our nation’s children. Moreover, this type of pollution is inequitably distributed and disproportionately harms Blacks and Latinos compared to whites.
The residents of Arizona, especially those living in Maricopa County, have been plagued with the health impacts of both the climate crisis and Air Pollution. The American Lung Association has consistently graded the Maricopa County and Pinal County areas with failing grades on air quality. The latest report came out this month and again, the Phoenix area has received an F on the American Lung Association “State of the Air Report”. Out of over 220 metropolitan areas, the Phoenix area ranked 5th worst for high ozone days, 11th worst for 24-hour participle pollution and 8th worst for annual particle pollution. The air we breathe is harming all of us, but especially our children and elderly.
Heavy duty vehicles are major contributors to the valley's air pollution. Diesel engines emit deadly particle pollution. And NOx combines with heat and sunlight in the atmosphere to form ground level ozone, or smog, a lung irritant and asthma trigger. Health officials tell us that the following groups are most at risk:
- Babies and children, whose bodies are rapidly developing.
- Pregnant women, whose risk of premature birth and low weight birth increases when exposed to air-pollution.
- Children and adults with asthma – as air pollution can both trigger asthma attacks and cause the development of the disease.
- People with COPD.
- People with lung cancer.
- People with cardiovascular disease.
- People with COVID-related lung problems or long-COVID, or people with active cases of COVID or other respiratory infections.
- People with any chronic disease such as cancer
- Older adults (over age 65), whose risk of premature death increases with exposure to air pollution.
To protect our children's health and future as well as our large Senior citizen population, and to address environmental injustice, EPA needs to immediately take urgent and bolder action. The proposed rule for heavy duty vehicle pollution should be strengthened. On the NOx portion of the rule, Option 1 is a start but is insufficient. It would result in higher emissions of smog and soot-causing NOx pollution than California’s Heavy Duty Omnibus rule, which should be the baseline for smog and particulate matter reduction goals. On the greenhouse gas portion of the rule, the proposed adjustments to existing Phase 2 greenhouse gas standards are weak and reflect neither the urgency of the climate crisis nor the rapid advancement in zero-emission truck technology. EPA should put our nation's heavy duty vehicle fleet on a clear path to 100% zero-emissions sales by 2035.
Thank you for your dedication to protecting public health and to advancing justice and equity.
Arizona Climate Action Coalition
Arizona Faith Network
Arizona Interfaith Power and Light
Arizona Public Health Association
Chispa League of Conservation Voters
Citizens' Climate Lobby
Climate Reality - Greater Phoenix Chapter
Climate Reality - Chandler
Defend Our Future
Elders Climate Action - Arizona Chapter
Extinction Rebellion Phoenix
JustFaith Arizona Network
Mi Familia Vota
Moms Clean Air Force
Northern Arizona Climate Change Alliance
Physicians for Social Responsibility, Tucson Chapter
Physicians for Social Responsibility Arizona Chapter
St Francis Renewal Center
Tó Nizhóní Ání
Valley UU Congregation
Yuma Audubon Society