Advocacy Groups to EPA: Approve Clean Fleets for California

Electric Trucks
Multi-State Org ACF Waiver Support Letter Logos
Multi-State Org ACF Waiver Support Letter Logos

June 17, 2024 

The Honorable Michael S. Regan
Administrator 
U.S. Environmental Protection Agency 
1200 Pennsylvania Ave., N.W. 
Washington, DC 20460 

RE: California State Motor Vehicle Pollution Control Standard; Advanced Clean Fleets; Requests for Waiver of Preemption


On behalf of the undersigned environmental, transportation, health, faith, business and non-profit groups and the concerned residents across the country that we represent, we urge the EPA to approve California’s Advanced Clean Fleets (ACF) waiver request in full and without delay, securing California's and other states' ability to implement more stringent heavy-duty vehicle standards that will protect public health, and help alleviate local air pollution in the most impacted and highly polluted communities. 

Currently, 39% of people in America are experiencing unhealthy levels of air pollution, and the transportation sector is largely to blame. Under the Clean Air Act, California holds a unique authority to establish more protective clean vehicle standards than the federal government and allows other states to opt-in to California’s more stringent standards. Among other things, California’s ACF rule allows states to require truck fleets to transition over time to zero emission trucks and requires manufacturers to sell 100% zero emission trucks by 2036. Granting the ACF waiver will ensure that states stay on the pathway to equitably transition from diesel fuels, protect public health, and mitigate the twin crises of air pollution and climate change. 

The ACF regulation is crucial in the fight against toxic diesel pollution and the climate crisis. Diesel emissions from trucks stand as one of the country’s foremost contributors to unhealthy air pollution and climate change. While trucks make up only 5 percent of total on-road vehicles in the U.S., they are responsible for 30 percent of GHG emissions, 42 percent of NOx emissions, and 51 percent of fine particulate matter (PM2.5) emissions. Communities located near major roads, highways, railyards, and ports suffer disproportionate burdens from traffic and transportation pollution. Exhaust from diesel trucks is a leading source of harmful air pollution that sends countless Americans to the hospital every year. Diesel pollutants have devastating consequences on surrounding communities, and these collectively increase premature mortalities, cause cardiovascular and respiratory diseases,increase the risk of cancer, and threaten the stability of the climate.

Granting the ACF waiver will not only substantially reduce carbon and diesel emissions from the transportation sector, but also deliver important, life-saving reductions in local air pollutants linked to ozone and smog, especially in low-income communities and communities of color. The benefits of the ACF rule in California alone are enormous as it will deliver $57 billion in health savings by 2050 and is expected to save 5,000 Californian lives between 2024 and 2050. The community-driven ACF regulation ensures that efforts to enhance air quality prioritize the communities bearing the brunt of toxic air pollution, aligning closely with the Biden Administration’s Justice40 goals. California and states throughout the country will be able to protect their residents with this lifesaving regulation, but only if the EPA grants a waiver for the rule.

Many states have recognized the importance of moving faster than the federal medium- and heavy-duty (MHD) clean vehicle standards require. Seventeen states, the District of Columbia and Quebec have signed on to a memorandum of understanding committing to achieve 100 percent MHD ZEV sales no later than 2050 and subsequently released a Multi-State MHD ZEV Action Plan which highlights the adoption of California’s Advanced Clean Trucks (ACT) and ACF rules as key actions to advance MHD vehicle electrification. Eleven states have already adopted the ACT regulation and several more are currently considering adopting the ACT regulation. The ACF regulation is the next key step for these states in accelerating the market for MHD ZEVs. 

EPA must follow its decades-long precedent and fully approve the waiver request for the ACF rule to deliver public health and economic benefits. We urge you to grant California’s ACF waiver request as soon as possible.

Thank you for your consideration.

Sincerely,

Will Brieger
Chair, Legislation & Policy Team
350 Sacramento

Jan Dietrick
Policy Team Leader
350 Ventura County Climate Hub

Marc Carrel
President and CEO
Breathe Southern California

Kate Johnson
Interim Regional Director, North America
C40 Cities

John Shears
Consultant on Air Quality, Climate and Clean Transportation
The Center for Energy Efficiency and Renewable Technologies

Nina Idemudia
CEO
Center for Neighborhood Technology (CNT)

Kimberly McCoy
Climate and Environmental Policy Associate
Central California Asthma Collaborative

Dave Robba
Manager, State Policy, Transportation 
Ceres

Margarita Parra
Transportation Decarbonization Director
Clean Energy Works

Amy Goldsmith
NJ State Director
Clean Water Action

Janet Cox 
CEO
Climate Action California

Don and Alona Steinke
Climate Action of Southwest Washington

Dorothy BarnettExecutive Director
Climate + Energy Project

Thomas Coleman and Pamela Tate
Co-Chair and Chair of Campaigns
Climate Reality Chicago Metro

Rev. Brian Sauder
President and CEO
Faith in Place

Jeanette Shaw
Senior Director of PolicyForth 

Tracey E. McFadden
Vice President
Fox Valley Electric Auto Association

Andrea Marpillero-Colomina
Sustainable Communities Program Director
GreenLatinos

Maurissa Brown
Manager, Transportation Equity Program
Greenlining Institute

Megan Kemp
Director
Healthy Air and Water Colorado

Shelley Mann-Lev
Executive Director
Healthy Climate New Mexico

Jeremy Abrams
Business Manager
IBEW 569

Rev. Susan Hendershot
President
Interfaith Power & Light

Drew Tompkins
Coordinator
Jersey Renews

Guillermo Ortiz
Clean Vehicles Advocate
Natural Resources Defense Council 

Tobias A. Fox
Managing Director
Newark Science and Sustainability Inc

Debra Coyle
Executive Director
New Jersey Work Environment Council

Rev. Clara Sims
Assistant Executive Director 
New Mexico & El Paso Interfaith Power and Light 

Kevin Garcia
Senior Transportation Planner
New York City Environmental Justice Alliance

Anshul Gupta
Policy & Research Director
New Yorkers for Clean Power

Ingrid Malmgren
Senior Policy Director
Plug In America

Sarahia Benn
President/CEO
Policy Foundation of Maryland

Sven Thesen
Co-Founder
Project Green Home

Ruben Aronin
Director
California Business Alliance for a Clean Economy

Levi Kamolnick
Federal Policy Director
CALSTART

Maya Golden-Krasner
Deputy Climate Director
Center for Biological Diversity

Marven Norman
Policy Coordinator
Center for Community Action and Environmental Justice (CCAEJ)

Leah Missik and Brett Morgan
Acting Washington Director and Oregon Transportation Policy Director
Climate Solutions

Bill Magavern
Policy Director
Coalition for Clean Air

Matthew Brandon
President
Communities Organized to Win

Emily K. Green
Senior Attorney
Conservation Law Foundation

Michael Jensen
CEO
Conservation Voters New Mexico

Gail Parson
Deputy Director
E2 (Environmental Entrepreneurs)

Athena Motavvef
Legislative Representative
Earthjustice

Conor Bambrick
Director of Policy
Environmental Advocates NY

Laura Deehan
State Director
Environment California

Doug O'Malley
Director
Environment New Jersey

Bakari Height
Transit Equity Organizer
Labor Network for Sustainability

Jack Symington
Sr. Program Manager, Transportation
LACI

William Colon
President and CEO
Latino Institute, Inc.

Matthew Davis
Vice President of Federal Policy
League of Conservation Voters

Dave Shukla
Operations
Long Beach Alliance for Clean Energy

Monique Fitzgerald
Climate Justice Organizer
Long Island Progressive Coalition 

Kathleen Meil
Senior Director of Policy & Partnerships
Maine Conservation Voters

Transportation Team
Mobilizing Climate Action Together (MCAT)

Linda Hutchins-Knowles
Co-founder & Team Coordinator
Mothers Out Front Silicon Valley

Mark Rose
Program Manager
National Parks Conservation Association

Ona Porter, MA
Founder Emerita and Clean Energy Leader
Prosperity Works, New Mexico

Joel Ervice
Associate Director
Regional Asthma Management & Prevention

Joyce Lane and Elaine Maltz
Board President and Member Legislative Committee 
SanDiego350

Katherine Garcia
Clean Transportation for All Campaign Director 
Sierra Club

Jack Eidt
Co-Founder
SoCal 350 Climate Action

Trip Pollard
Land & Community Program Leader
Southern Environmental Law Center

Kim Gaddy
Executive Director
South Ward Environmental Alliance

Travis Madsen
Transportation Program Director
Southwest Energy Efficiency Project

Renae Reynolds
Executive Director 
Tri-State Transportation Campaign

Michele Canales
Western States Policy Advocate
Union of Concerned Scientist