CoPIRG supports action on Advanced Clean Truck rule in 2022

CoPIRG

On February 21st, CoPIRG submitted a public comment to Colorado’s Air Quality Control Commission in support of moving forward with the Advanced Clean Trucks rulemaking in 2022. This is the comment we submitted:

Dear Air Quality Control Commission, 

We are writing in support of moving forward with both the Advanced Clean Trucks and Heavy-Duty Omnibus Rule in Colorado in 2022.  Delaying this ruling would postpone a critical step towards reducing truck-related emissions that is desperately needed in our state. 

At CoPIRG, we stand up for a healthier and safer world, starting with the air we breathe here in our own state. The negative impacts of Colorado’s growing air pollution problem are being felt by all residents on a regular basis. This past summer, the Denver Metro Northern Front Range surpassed the record of 53 ozone alert days in a single season. During ozone alerts officials from the Colorado Department of Health and Environment (CDPHE) warn residents of unhealthy conditions and urge some people to remain indoors.  

Tailpipe emissions from internal combustion engines release particulate matter, nitrogen oxides, and volatile organic compounds that contribute to ozone pollution.  In Colorado, the transportation sector is the highest emitter of greenhouse gas (GHG) emissions in the state. While passenger vehicles are the largest source of air pollution within this sector, medium and heavy-duty vehicles (MDHVs) are a close second. 

Nationally, MDHVs account for almost a quarter of all greenhouse gas emissions in the US despite comprising only 5% of all vehicles on the road. In the Denver Metro area, MHDVs account for less than 2% of all vehicle miles traveled, but contribute 24% of on-road NOx emissions.

According to Environment America’s Trouble in the Air report, many counties in Colorado had elevated levels of pollution throughout 2020.  With Boulder County reporting a whopping 151 days of elevated ozone and/or particulate matter in 2020, Greeley reporting 147 days, and Denver-Aurora-Lakewood reporting 129 days, over 3.6 million Coloradans experience elevated levels of air pollution on more than 30% of days in 2020.    

Particulate matter and ozone pollution associated with transportation and MDHVs has negative health impacts for all residents, however it can have a disproportionate impact on people who live near trucking corridors, ports, bus depots, and distribution hubs because this kind of air pollution is localized. Therefore, we must focus clean air policies on cleaning up pollution from medium and heavy-duty vehicles that frequent these industrial areas. 

We must convert medium and heavy-duty vehicles (MHDVs), to 100% zero-emission vehicles including electric-powered. Eliminating fossil fuels and tailpipe emissions from the transportation sector will spur significant reductions in ozone and greenhouse gas emissions, leading to improvements in air quality.   

Electric-powered trucks have several health and environmental benefits to diesel and gas powered vehicles.  By using electricity rather than combusting fossil fuels, they significantly reduce the emission of nitrogen oxide (NOx) and particle pollution that fuel ozone pollution.  To help illustrate the impact of this change, the American Lung Association compared a “Business As Usual” fleet to an “Electric Vehicle Scenario,” and estimated the following impacts by the year 2050: 82% reduction in nitrous oxide (NOx) pollution, a 62% reduction in fine particle pollution, and a 90% reduction in greenhouse gas emissions.

The ACT rule will help Colorado achieve its long-term vision of electrifying the transportation sector, while the Heavy-Duty Omnibus (HDO) Rule will make immediate improvements to air quality while we transition to electric vehicles by imposing a new NOx standard. 

Delaying these rulings will provide a setback to Coloradan residents who are expecting action on the worsening air pollution problem in the state. With a 2-year delay already built into the ruling to allow manufacturers time to adapt, it’s critical we move forward with the adoption in 2022.