For Colorado’s clean truck ambition, it’s time for action, not delay

In March 2022, Colorado Gov. Jared Polis unveiled an ambitious and forward-thinking zero-emission medium- and heavy-duty truck strategy his administration said could reduce climate emissions from this sector at least 45% by 2050.

Gov. Polis is right: Colorado’s Clean Truck Strategy would build upon the state’s “national-leading climate and infrastructure goals.” But key pieces necessary to achieve that ambition have already stalled. Three state agencies (Colorado Energy Office, Department of Transportation, Air Pollution Control Division) want to push adoption of the Advanced Clean Trucks rule and the Heavy-Duty Omnibus (low NOx) rule — key policy drivers for this transition — to next year.

In response, EDF and a host of other environmental groups, environmental justice advocates and local governments filed a petition with the state’s Air Quality Control Commission to move forward with the ACT and low NOx rulemaking and adopt these regulations this year, rather than delay to 2023, and AQCC agreed to hear the petition on April 21.

In short, the AQCC should work with the Polis administration to move forward with adopting the ACT and low NOx rulemaking by the end of the year.

The ACT and low NOx rules are a crucial piece of a cleaner transportation world

In 2020, Gov. Polis joined what is now a coalition of 17 states, the Province of Quebec and Washington D.C., in committing to ensuring 30% of new truck and bus sales in Colorado will be zero-emission by 2030, and 100% would be zero-emission by 2050.

In total, six states have adopted their own version of the ACT, and several of these states have also adopted the low NOx rule.  These rules require manufacturers to sell increasing numbers of zero-emission trucks, and reduces NOx pollution of new diesel vehicles by 90% by 2027, respectively. In total, states that have already adopted or are considering the ACT and/or low NOx rules account for 20% of the national fleet of medium- and heavy-duty trucks.

But since his 2020 pledge, Polis has not done nearly enough to deliver on it. If Colorado is to achieve the critical goals set out in its Clean Truck Strategy, there’s no time to waste. Every minute that passes leaves the benefits of zero-emission trucks and buses on the table. And the benefits extend far beyond reducing climate emissions. Adopting the ACT and low NOx rules in Colorado would provide his ambition a much-needed jolt.

Climate, health and economic benefits await — and the electric vehicles are ready

The American Lung Association says a transition to zero-emission vehicles will result in $9.5 billion in public health benefits by 2050, 857 avoided deaths, 31,200 avoided asthma attacks and 151,000 avoided lost workdays nationally.  For Coloradoans who live near highways, warehouses and other high-truck-traffic areas — disproportionately low-income and BIPOC communities — reducing diesel truck exhaust can literally be a matter of life and death. And for mechanics and technicians who worry about the future of their trade, electric transportation is projected to be a significant driver of good-paying jobs. Put another way, if designed and executed correctly, this transition can be a powerful lever to ensure economic and health equity.

Additionally, a more rapid transition to zero-emission vehicles is eminently feasible. Various analyses have demonstrated that electric trucks are ready to roll. The number of zero-emission truck models available since 2019 has increased 625% — every major truck manufacturer offers or is developing electric models that can address the overwhelming majority of trucking needs. And the economics of electric trucks continue to improve.

Already, the fuel and maintenance savings put electric trucks ahead of diesel trucks when considering lifetime costs of each. By 2027, when sales targets start to ramp up more, experts anticipate the upfront cost of electric models will be favorable relative to diesel alternatives.

Moreover, EDF’s own analysis has shown that the transition to zero-emission vehicles, including of heavy-duty trucks, is one of the most cost-effective means of reducing climate pollution. Putting clear and concrete rules in place to transition this sector will provide additional market certainty and help bring down the upfront cost of these new vehicles.

Finally, delay will have significant and adverse impacts on the state’s ability to achieve critical climate goals. Putting off these rules not only jeopardizes the state’s ability to meet its near-term climate targets in 2025 and 2030. It will also lead to increases in cumulative greenhouse gas emissions — the total buildup of GHGs in the atmosphere — which is the single most important metric for curbing long-term climate damages.

Establishing rules now to reduce emissions from medium- and heavy-duty trucks can ensure Colorado keeps more climate pollution out of the atmosphere and is able to maintain a path of sustained reductions in years and decades to come.

Common delay arguments are red herrings

Many common arguments for delay fall apart under examination.

First, there is concern that Colorado will face challenges in building the charging infrastructure necessary to support zero-emission vehicles. It is true that broad vehicle electrification will require significant infrastructure investment. However, deploying the charging stations needed to meet demand from increased medium- and heavy-duty trucks in the early years of the ACT is a challenge the state is well-equipped to overcome given the significant funding allocated to deploying charging infrastructure across the state. And adopting the rule in 2022 with ACT implementation starting in model year 2026 provides ample time to plan.

Another common argument suggests current supply chain issues justify a delay in the timeline. First, as described above, implementation of the ACT and the low NOx rule would not begin until model year 2026.  Predicting supply chain issues many years in the future is next to impossible — for electric and diesel vehicles alike. And there is reason to be optimistic — as a case in point, electric truck maker Rivian fully expects to fulfill its manufacturing goals based on its Q1 2022 progress. It is also important to remember that flexibilities built into the ACT allow manufacturers to focus on the electric vehicles that are most market-ready in the early years of the rule’s implementation.

Finally, waiting for federal standards should not be a reason for delay. As currently proposed, pending EPA standards may not ensure ACT levels of deployment of zero-emission vehicles, may not be as protective as the low NOx rules and will not be implemented until model year 2027 at the earliest — though EDF will be urging the agency to strengthen standards in a way that incentivizes meaningful zero-emission vehicle deployment. Action by states now can unlock significant health and environmental benefits in advance of federal standards.

Time for action, not delay

The bottom line is simple: the electric revolution has arrived. Fleets, manufacturers and state governments increasingly recognize the transition to zero-emission vehicles is in their financial interest, necessary to protect the environment and the health of its citizens and will help bolster local economic growth. Colorado should join them. Now’s the time for action, not delay.

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