Date: July 5, 2023
About: Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles, Docket ID No. EPA-HQ-OAR-2022-0829
To: Environmental Protection Agency
Dear Administrator Regan,
On behalf of the 32 undersigned advocacy groups, we thank the Environmental Protection Agency for its leadership in reducing harmful vehicle pollution. We urge the agency to protect public health and address the climate crisis by finalizing the strongest possible emissions standard for light and medium-duty vehicles before the end of 2023.
Under the U.S. Nationally Determined Contribution to the Paris Agreement, we committed to cut economy-wide greenhouse gas (GHG) emissions by 50 to 52 percent in 2030, compared to 2005 levels. Meeting that commitment is more important than ever. According to the Intergovernmental Panel on Climate Change’s recently released Sixth Assessment Report, we are on course to exceed a 1.5° Celsius increase in global average temperature above
pre-industrial levels within the coming decades. This level of warming would be catastrophic for our health, our welfare, and our planet.
The final emissions standard should put us on the path to ensuring that all new vehicles sold in 2035 are zero-emission vehicles (ZEVs). This transition is critical to reducing not only GHG emissions, but smog-forming pollution and particulate matter as well. Passenger vehicles produce more than one million tons of nitrogen oxide (NOx) emissions and 33,400 tons of particulate matter (PM) pollution every year.1 These emissions disproportionately harm people in low-income communities and communities of color.
The EPA should ensure that the final standard reflects the investments from the Infrastructure Investment and Jobs Act and Inflation Reduction Act. Together, these two laws are expected to reduce ZEV adoption costs by providing at least $245 billion in federal funds—through tax credits, loans, and grants—to support ZEV infrastructure, manufacturing, purchasing, and charging.2 Long-term regulatory certainty, through strong federal clean car standards, will encourage domestic manufacturers to take full advantage of federal investments and spur ZEV innovations that can reduce pollution and save families money.
A strong LDV rule is technologically feasible and achievable because we are seeing dramatic cost and performance improvements in zero emission electric vehicle technology. This is bolstered by the availability of significant federal financial incentives, and affirmed by existing automaker commitments to deploy ZEV technologies and the adoption of state clean car standards across the country. A strong emissions standard can position the United States as a leader in ZEV technology development and manufacturing and create high-quality jobs.
We appreciate the EPA’s proposal, which moves our vehicles in the right direction. However, the final emissions standard for light-duty vehicles should:
- Secure greater pollution reductions with a focus on strengthening the later model years of the program, reflecting the cost-effective availability of greater zero-emission vehicle adoption due to market growth expected from IRA and IIJA investments (which will surpass existing commitments outlined in Executive Order 14037) and state leadership;
- Put the nation on a trajectory to ensure 100 percent of all light- and medium-duty vehicles sold in 2035 are zero-emission vehicles including pathway milestones assuring continuous progress;
- Appropriately take advantage of available cost-effective improvements to new fossil-fuel vehicles;
- Leverage the growth in ZEV deployment associated with state clean car standards adopted under state authority granted by the Clean Air Act; and
- Establish protective zero-emission vehicle durability and warranty requirements
By implementing these recommendations, we believe that the standards will protect public health, help lower fuel costs for consumers, create good, green jobs, and reduce environmental burdens on frontline communities.
We thank you for your consideration as you work to finalize these life-saving rules this year.
Sincerely,
Alliance of Nurses for Healthy Environments
The Asthma and Allergy Foundation of America (AAFA)
C40 Cities
CALSTART
Coltura
Clean Energy Works
Ecology Center
Elders Climate Action
Environmental Advocates NY
Environmental Defense Fund
Environmental Law & Policy Center
EV Charging for All Coalition
Evergreen Action
GreenLatinos
GRID Alternatives-Greater Los Angeles
Illinois Environmental Council
Interfaith Power & Light
League of American Bicyclists
League of Conservation Voters (LCV)
Long Island Progressive Coalition
MI Air MI Health
Michigan Environmental Council
Moms Clean Air Force
Natural Resources Defense Council (NRDC)
New Yorkers for Clean Power
New York City Environmental Justice Alliance
Project Green Home
Public Citizen
Reno + Sparks Chamber of Commerce
Sierra Club
Southern Environmental Law Center
Union of Concerned Scientists
1 Zeroing in on Healthy Air, American Lung Association,
https://www.lung.org/getmedia/13248145-06f0-4e35-b79b-6dfacfd29a71/zeroing-in-on-healthy-air-report-2022.
2 Noah Gabriel, $210 Billion of Announced Investments in Electric Vehicle Manufacturing Headed for the U.S., EV Hub (Jan. 12, 2023),
https://www.atlasevhub.com/data_story/210-billion-of-announced-investments-in-electric-vehicle-manufacturing-he aded-for-the-u-s/.