Climate 411

Diesel pollution from a freight truck in 2008. Pruitt is proposing a loophole that would allow new trucks to evade modern clean air protections by using high-polluting old engines like this one. Photo: EPA

The U.S. Environmental Protection Agency (EPA), led by Administrator Scott Pruitt, is proposing to roll back important safeguards and allow certain heavy-duty freight trucks – commonly known as “glider trucks” – to evade modern pollution standards.

Rolling back these protections would have terrible impacts for human health, including as many as 4,100 premature deaths in 2025 alone. Glider trucks can emit harmful pollution at a rate up to 450 times that of other new freight trucks. So the broad chorus of opposition from the public – including from EDF – is no surprise.

But you might be surprised by who else is strongly opposing EPA’s proposal.

Every segment of the freight industry — truck manufacturers, fleet owners, freight shippers and other stakeholders — has spoken out to oppose this rollback.

These industry stakeholders recognize that Pruitt’s proposal would undo decades of progress in cleaning up pollution from heavy-duty freight trucks. Moreover, it would undermine their significant investments in pollution control innovation.

The proposed rule would create a loophole for the small segment of the freight truck industry that manufactures super-polluting glider trucks, which use old diesel engines that are not equipped with modern pollution controls — and the loophole would be at the expense of other truck manufacturers and dealers who play by the rules.

These freight truck industry words speak for themselves – EPA needs to reverse course on this deeply damaging proposal:

TRUCK DEALERS

The National Automobile Dealers Association, as well as numerous individual truck dealers, have expressed opposition to the proposal.

TriState Truck Center, based in Memphis, Tennessee and employing about 400 people:

“We have been a heavy duty dealer for 72 years. I have personally worked here since 1972. I remember the days years ago when our truck shop was so thick with the exhaust from the trucks that you could not see the other side of our shop. Today, our shops are clean and exhaust free due to the new EPA compliant engines. Do we really want to go back to those days? That’s what more glider kits will do with engines that are both obsolete and environmentally unfriendly.” — Public Comment of TriState Truck Center

MANUFACTURERS

Daimler Trucks North America, a leading manufacturer of heavy-duty vehicles in the United States, opposes the proposed rule despite being a major supplier of glider kits:

“[T]he EPA’s proposed revisions to the glider rules would undermine the investments that DTNA and Detroit Diesel Corporation — and all other U.S. manufacturers — made in advanced technologies and exhaust after treatment, while opening the vehicle and engine markets to manufacturers who find simple options to skirt EPA regulations altogether and market high emitting engines or vehicles.” – Public Comment of Daimler Trucks North America

The Volvo Group, one of the world’s leading manufacturers of heavy-duty trucks, and direct employer of more than 13,000 Americans:

“A repeal of the Phase 2 glider provisions will make a mockery of the massive investments we’ve made to develop clean diesel technology. Any relaxation of the production caps is unnecessary and would exacerbate the negative competitive and environmental impacts from the glider industry. It’s imperative that the Agency ensure that all actors are playing by the same set of rules.” — Public Comment of the Volvo Group

The Alliance of Automobile Manufacturers, whose members include major car companies including Ford, General Motors, and Toyota, opposes the proposal and says this rule could have implications far beyond glider vehicles, resulting in drastic increases in air pollution from other motor vehicles:

“One glaring (and perhaps unintended) result of the Proposed Repeal is that any auto or engine manufacturer (or its customer) could circumvent EPA’s GHG regulation of new motor vehicles and new motor vehicle engines merely by incorporating a few used components into their finished products …Vehicle manufacturers or builders of ‘kit vehicles’ could attempt to avoid compliance with emission standards in their entirety by incorporating used powertrain components into their vehicles. A circumvention of criteria pollutant standards in this way would adversely affect public health and run contrary to other EPA efforts to promote low on-road emissions.” — Public Comment of Auto Alliance

The Truck and Engine Manufacturers Association (EMA), representing leading global manufacturers of heavy-duty and medium-duty vehicles and engines including Honda, Caterpillar, Cummins, Ford, General Motors, Navistar, Volvo, and Yamaha:

“[S]uch a loophole would be especially damaging to EMA’s members who have invested hundreds of millions of dollars in advanced technologies – technologies that make them the world’s leaders in the manufacture of new heavy-duty and medium-duty on-highway engines and vehicles. EPA’s loophole would open the door for other manufacturers (that have not made the same investment) to enter the U.S. marketplace, even with used engines that have no advanced emission-control systems whatsoever.” — Public Comment of EMA

PACCAR is a manufacturer of medium- and heavy-duty trucks and engines, including a major manufacturer of glider kits. Even PACCAR, which would be able to sell glider kits through the proposed loophole, acknowledges the harmful implications of EPA’s proposed rule:

“PACCAR supports the comments submitted by the Truck and Engine Manufacturers Association (EMA) regarding EPA’s interpretation of the CAA used in this NPRM.  In particular, PACCAR agrees with EMA that EPA’s interpretation of CAA Section 202(a)(1) will create a loophole that could  … lead to traditionally ‘new’ engines being built with one or more refurbished parts in order to avoid being regulated to the current CAA emissions requirements.” — Public Comment of PACCAR

The National Association of Manufacturers (NAM), the nation’s largest manufacturing association representing nearly 14,000 small, medium, and large manufacturers in every industrial sector and in all 50 states:

“The framework created by the existing [2016 HDP2] regulations strikes an appropriate balance without creating a competitive disadvantage for manufacturers that comply with GHG standards. . . . [T]he proposed repeal of the glider vehicle requirements from the Phase 2 rule could have unintended consequences that affect the market for new heavy-duty vehicles.” — Public Comment of NAM

FLEETS AND SHIPPERS

UPS, which owns the largest truck fleet in the U.S.:

“Allowing gliders to remain unchecked as to fuel economy and emissions means that the cleanest heavy truck fleets in the nation will keep paying the price for clean air, while gliders don’t. In short, before asking [for] more improvements in the best-of-the-best trucks, EPA should pursue cleaner emissions in trucks that are already the worst-of-the-worst in emissions.” — Public Comment of UPS

The American Trucking Associations, which represents more than 34,000 companies, convened a Fuel Efficiency Advisory Committee comprised of leading truck fleets from across the country, including UPS, Wal-Mart, PepsiCo, and Penske Truck Leasing. The committee voted unanimously “to oppose any attempts to repeal the glider provisions in the [2016] final Phase 2 rule.”

“Our members have worked together tirelessly in support of technologies and programs that have resulted in the production and adoption of the cleanest and most fuel-efficient diesel trucks ever. EPA’s decision to allow the unchecked growth of the glider market and encourage the continued sale of antiquated engine technologies grossly undermines the investment decisions of thousands of companies, organizations, and businesses.” — Public Comment of American Trucking Associations

The Ceres BICEP Network (Business for Innovative Climate & Energy Policy) is comprised of leading companies such as Adobe, eBay, IKEA, L’Oreal, Nike, The North Face, Patagonia, Sierra Nevada Brewing, and Unilever:

“It is important to us that the transportation of our goods does not result in negative public health impacts, and we believe that those trucking companies that have invested in clean technologies, and those companies that use them, should not be penalized. Given that this proposal will result in significant harm to public health, and undermine a level playing field for those who support clean technologies, we strongly oppose this proposal.” — Public Comment of BICEP

Public health experts, freight truck manufacturers and truck dealers sent a shared message to Environmental Protection Agency (EPA) Administrator Scott Pruitt at a recent public hearing – don’t reopen a loophole for super-polluting glider trucks.

Glider trucks are new freight trucks that have used engines installed in them. Those older engines emit harmful soot and smog-causing pollutants at rates dramatically higher than trucks that comply with current emission standards.

Glider trucks, with their older engines, emit high levels of pollutants like cancer-causing diesel particulate, as well as oxides of nitrogen and particulate matter – which have been linked to severe human health impacts, including increased asthma attacks and exacerbation of heart disease.

Pruitt has proposed reopening a loophole in our national Clean Truck Standards that would allow glider trucks to pollute without restriction. This proposed rollback of common sense pollution limits is a slap in the face – not only to American families, who deserve clean air to breathe, but also to the heavy duty trucking industry, which has invested in cleaner technologies for years.

Freight truck leaders voice concerns about glider truck loophole

Volvo senior vice president Susan Alt testified at the public hearing that Pruitt’s proposal “makes a mockery” of their responsible investments in pollution control equipment and clean technologies.

Representatives from the American Trucking Associations, the Engine Manufacturers Association, and the Heavy Duty Fuel Efficiency Leadership Group echoed concerns that the proposed rollback would undermine their investment decisions for the past decade, upend the level playing field the industry needs for the well-being of their businesses, and jeopardize the regulatory certainty upon which they rely.

Freight truck dealers underscored that they hire and employ skilled technicians — in communities all across the country — to service and maintain modern, cleaner engines. Their businesses, and their employees, will be at risk if the loophole for glider trucks is reopened.

Pruitt issued his proposal based on flawed, incomplete information

EPA estimated in 2016 that glider truck emissions were as much as 40 times higher than modern engines.

The agency recently undertook more emission testing to refine its data. But Pruitt issued his proposal to repeal the glider provisions before EPA’s testing could be completed.

Instead, Pruitt’s proposal highlights poorly supported assertions from Tennessee Tech University, which conducted testing on glider trucks that found much lower emissions of oxides of nitrogen and particulate matter than EPA’s estimates.

Last week, EPA released its new, updated testing data, as well as a memo with further details about the Tennessee Tech findings that show flaws in the university’s analysis. This new information confirms the serious threat to human health posed by glider trucks.

EPA’s new test data suggests that the estimates it relied on before closing the glider truck in the first place may have been too conservative:

Under highway cruise conditions, [oxides of nitrogen] emissions from the glider vehicles were approximately 43 times as high, and [particulate matter] emissions were approximately 55 times as high as the conventionally manufactured tractors. (emphasis added)

EPA identified a number of deeply troubling flaws and biases in Tennessee Tech’s methodology, facilities, and equipment used to generate their data. Most notably, Tennessee Tech’s assertions that the tested glider trucks met EPA’s 2010 emission standard for particulate matter and performed equally as well as modern trucks were not based on any actual measurement of the pollutant – just visible inspection, a practice abandoned decades ago as wholly inadequate for measuring particulate matter from diesel engines.

Equally alarming, as the Washington Post has reported, the EPA memo acknowledges that Tennessee Tech has a financial relationship with a major glider manufacturer – Fitzgerald Glider Kits – that is pushing for EPA to roll back the pollution protections for its product. The testing facility used by Tennessee Tech is owned by Fitzgerald.

Pruitt puts clean air at risk

These documents reinforce what has been clear since Pruitt took office – the Administrator is ignoring his agency’s own science and expertise, and putting the health of American families at risk, with an onslaught of attacks against vital pollution protections – attacks that are endorsed by politically connected major polluters.

Diverse voices turned out in full force at the public hearing to rebuke the most recent example of this pattern of practice:

• Terry Dotson of heavy-duty truck dealer Worldwide Equipment Inc. testified that his company could build glider kits, but chose not to because “we choose to do the right thing.”
• Blanca Iris Verduzco, on behalf of East Yard Communities for Environmental Justice, spoke as a resident of South East Los Angeles, an industrialized community exposed to a lot of freight transportation pollution. She urged EPA to protect her community from health dangers, and not to roll back protections.
• John Calvin Doub with TMI Truck and Equipment expressed concern for his three grandchildren, and talked about the breathing difficulties caused by air pollution. He cautioned EPA that until you have witnessed a child having an asthma attack, you don’t understand the full impacts of pollution from trucks.

EDF was represented at the hearing by Martha Roberts, Erin Murphy, Surbhi Sarang, and John Bullock. Their full testimonies are available here:

• Martha Roberts
• Erin Murphy
• Surbhi Sarang
• John Bullock

EPA is still accepting public comments on the proposed rollback of safeguards against glider truck pollution. You can send your comments through January 5^th.