Health impacts - International Council on Clean Transportation https://theicct.org/technology/health-impacts/ Independent research to benefit public health and mitigate climate change Thu, 15 Feb 2024 00:01:23 +0000 en-US hourly 1 https://wordpress.org/?v=6.4.3 https://theicct.org/wp-content/uploads/2022/01/favicon-150x150.png Health impacts - International Council on Clean Transportation https://theicct.org/technology/health-impacts/ 32 32 National Workshop on Low-emission Zones in Cities https://theicct.org/event/national-workshop-on-low-emission-zones-in-cities-feb24/ Tue, 30 Jan 2024 20:58:03 +0000 https://theicct.org/?post_type=event&p=36558 The post National Workshop on Low-emission Zones in Cities appeared first on International Council on Clean Transportation.

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About this event

The ICCT in collaboration with NITI Aayog is organizing a one-day workshop on Low Emission Zones (LEZs) in Indian cities. LEZs, designated areas where certain vehicles, particularly those with high emissions, are restricted or prohibited, have proven effective in reducing air pollution worldwide. Additionally, LEZs play a crucial role in promoting the adoption of electric vehicles, aligning with NITI Aayog’s proactive advocacy in this area.

Our workshop, in association with the Raahgiri Foundation & SUM Network, is scheduled for February 19, 2024 in New Delhi, and aims to raise awareness about LEZ benefits, discuss best practices for LEZ implementation in Indian cities, and formulate a roadmap for future actions.

The workshop will include discussions on the following topics:

  1. The benefits of LEZs for air quality and public health
  2. Case studies of successful LEZs from around the world
  3. Experiences in implementing LEZs in Indian cities
  4. Legal pathways for developing LEZs in India
  5. The role of technology in supporting LEZ implementation

The workshop will, we believe, significantly contribute to ongoing efforts to improve air quality and enhance EV adoption in Indian cities.

February 19, 2024
9:30 AM – 4:00 PM IST

Location: Royal Ballroom, The Imperial, New Delhi

Event Partners

Event Contact

Anandi Mishra, India Communications Manager
Vaibhav Kush, Researcher
communications@theicct.org

Agenda

9:30 AM – 10:00 AM: Registration

10:00 AM – 10:05 AM: Welcome Address

10:05 AM – 10:10 AM: Context Setting

11:30 AM – 11:45 AM: Keynote Address

10:30 AM – 11:00 AM: Tea Break

11:00 AM – 12:00 PM: Low emission zones – Understanding the concept

12:00 PM – 13:00 PM: Implementing low emission zones in India

13:00 PM – 14:00 PM: Lunch

14:00 PM – 15:00 PM: Technology and date for low-emission zones

15:00 PM – 16:00 PM: Enabling low-emission zones in India

10:00 AM – 10:05 AM: Closing remarks & Vote of thanks

Speakers

Amit Bhatt

India Managing Director, ICCT

Amit Bhatt is the ICCT’s Managing Director for India. He is based in New Delhi and has over 20 years of experience in transportation, urban development, and management. Before joining ICCT, Amit was Executive Director for Integrated Transport at WRI India for 12 years. Prior to the World Resources Institute he worked with the Urban Mass Transit Company, India’s leading urban transport consultancy, and with Infrastructure Leasing & Financial Services. He has also served as an adjunct faculty member at the School of Planning and Architecture in New Delhi.

Amit has a bachelor’s degree in architecture and a master’s degree in transport planning from the School of Planning and Architecture, New Delhi. Amit also has a master’s degree in economics and a diploma in transport economics and management.

Vaibhav Kush

Researcher, ICCT

Vaibhav Kush is a Researcher with ICCT’s India team, leading the Low Emission Zones work there. He engages with sub-national administrations to accelerate adoption of Low- and Zero Emission Zones in India. He has been working in the Sustainable Mobility sector since 2016, with expertise in safe systems, policy formulation and stakeholder engagements. Before joining ICCT, Vaibhav was associated with WRI India’s Sustainable Cities program for over six years, leading projects under Botnar CRS Challenge. He was actively involved in Haryana Vision Zero, pedestrianisation of Delhi’s Chandni Chowk, development of IRC guidelines on urban transport, etc. Prior to WRI India, Vaibhav has worked as an Architect and was involved in the design of large scale green building projects like corporate parks, Inter-container Depots, universities, etc.

Vaibhav has a bachelor’s in Architecture and a Master’s in Urban Planning from the School of Planning and Architecture, Delhi. He is a member of several professional bodies including International Sociological Association, Institute of Town Planners India, Council of Architecture, Indian Roads Congress, Indian Institute of Architects, Indian Buildings Congress, among others.

Sudhendu J. Sinha

Adviser, NITI Aayog

An alumnus of St. Stephen’s College, Delhi did his Major in History. He has experience of over 29 years in operations, infrastructure planning, coordination and management at field and policy making levels in Indian Railways with considerable success and appreciation.

His performance has been recognised and awarded twice at the National level (National Award for e-Governance- 2019-20, for ‘Excellence in providing Citizen – Centric Delivery’ by Department of Administrative Reforms and Public Grievances, Govt. of India, ‘National Award for Outstanding Service’ Ministry of Railways Govt. of India -2006) and thrice at the Ministry (of Railways) level. He also served as Dean of the Indian Railway Institute of Transport Management (IRITM), Lucknow, and General Manager Web Applications at the Centre for Railway Information Systems (CRIS). He has training and enrichment from Japan (Railway Management), Malaysia (ICLIF – Advance Management), Singapore (INSEAD – Advance Management), Germany (UIC) and the US (Oracle).

He is the Adviser at the NITI Aayog (National Institution for Transformation of India), the apex ‘Think Tank’ of the Govt. of India.

 

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Ketan Gore https://theicct.org/team-member/ketan-gore/ Thu, 12 Oct 2023 14:34:12 +0000 https://theicct.org/?post_type=team-member&p=28812 Ketan Gore is ICCT marine research fellow based in New Delhi, India, where is assisting with marine decarbonization projects for the ICCT’s global marine team, while also helping to develop its Indian maritime strategy. He is currently finishing up a PhD in Operations and Logistics Management from Maynooth University in Ireland. His thesis is titled […]

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Ketan Gore is ICCT marine research fellow based in New Delhi, India, where is assisting with marine decarbonization projects for the ICCT’s global marine team, while also helping to develop its Indian maritime strategy. He is currently finishing up a PhD in Operations and Logistics Management from Maynooth University in Ireland. His thesis is titled “Facilitating green practices within the Irish maritime industry from use of low-to-zero emission technologies.” He is lead author of two recent peer-reviewed articles which have been published in highly-reputed journals: one in the Journal of Environmental Management on cost-benefit assessments of shore side electricity for ships in Ireland and another in Transportation Research Part D: Transport and Environment on assessing the costs of alternative marine fuels in Ireland. He also holds B. Eng. degree in Electronics from HCET College, India and M.Sc. degree in Business Management from Maynooth University, Ireland.

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Jonathan Benoit https://theicct.org/team-member/jonathan-benoit/ Tue, 10 Oct 2023 19:08:01 +0000 https://theicct.org/?post_type=team-member&p=28662 Jonny is a Model Fellow with the Modeling center. His current work involves upgrading ICCT’s on-road emissions and health impacts models as well as conducting applied research on the impacts of vehicles on human health. Jonny earned an Sc.B. in Geophysics from Brown University where he focused on geospatial analysis and climate modeling.

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Jonny is a Model Fellow with the Modeling center. His current work involves upgrading ICCT’s on-road emissions and health impacts models as well as conducting applied research on the impacts of vehicles on human health. Jonny earned an Sc.B. in Geophysics from Brown University where he focused on geospatial analysis and climate modeling.

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Proposed Euro 7 emission limits could prevent over 7,200 deaths in Europe by 2050 https://theicct.org/proposed-euro-7-emission-limits-could-prevent-over-7200-deaths-in-europe-by-2050/ Tue, 12 Sep 2023 08:33:36 +0000 https://theicct.org/?p=28031 The European Commission’s proposed Euro 7 emission limits for gasoline and diesel cars, vans, trucks, and buses aim to reduce air pollution and protect people’s health. A new study by the International Clean Transportation (ICCT) shows that the regulation could avoid 7,200 premature deaths linked to nitrogen oxide (NOx) emissions in Europe by 2050. Europe […]

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The European Commission’s proposed Euro 7 emission limits for gasoline and diesel cars, vans, trucks, and buses aim to reduce air pollution and protect people’s health. A new study by the International Clean Transportation (ICCT) shows that the regulation could avoid 7,200 premature deaths linked to nitrogen oxide (NOx) emissions in Europe by 2050.

Europe ranks third globally in transportation-attributable air pollution deaths after China and India.[1] These premature deaths are primarily linked to NOx, a harmful pollutant emitted by internal combustion vehicles. The shift to electric vehicles will reduce this burden on public health, but around 61 million gasoline and diesel vehicles will still be sold in the EU until 2050. The Euro 7 standards will be the last regulation to set legal emission limits for these engines.

Euro 7 holds the promise of saving many lives without requiring a large technological transformation. The existing emission control systems on the market can significantly reduce air pollution from the last generations of gasoline and diesel cars and trucks. The majority of the benefits stem from trucks. The proposed emission limits for heavy-duty vehicles have strong ambition behind them and would significantly reduce ambient concentrations of NOx,” says Dr Eamonn Mulholland, ICCT’s researcher. 

The investigation by the non-profit research organization ICCT examines three scenarios to evaluate the impact of the proposed air pollution regulation on emission reductions and public health. The regulation is now under discussion in the European Parliament and the Council of the European Union, facing opposition from certain political groups and eight Member States in the Council of the European Union.

The first scenario considers the current proposal by the European Commission. If implemented, it could prevent around 1 million tonnes of NOx emissions, with 77% of the reductions coming from trucks and buses.

The second scenario explores a delayed implementation of Euro 7. The Rapporteur of the European Conservatives and Reformists in the Parliament’s Environment Committee proposed to enforce Euro 7 emission standards for cars and vans three years after the entry into force of the regulation and five years after for trucks and buses. Assuming Euro 7 standards are adopted in 2024, this proposal would see the standards taking effect in 2027 for LDVs and 2029 for HDVs. The study demonstrates that such a delay would lead to approximately 1,800 additional premature deaths compared to the European Commission’s proposal.

“The later Euro 7 is implemented, the fewer vehicles it will affect. With cars and vans having average lifetimes of 18 years, and trucks and buses lasting around 20 years, each year of delay adds substantial NOx emissions to the air we breathe, which becomes a serious penalty on people’s health,” remarks Jan Dornoff, a senior researcher at the ICCT.

The third, more stringent scenario models a previous Euro 7 recommendation from the Commission’s impact assessment. According to the results, this more stringent option could avoid up to 9,900 premature deaths by 2050.

All scenarios account for the effect of the eventual phase-down of diesel and gasoline vehicle registrations for cars, vans, trucks, and buses planned under the EU’s CO2 standards. If adopted as proposed, Euro 7 standards will be introduced in 2025 for light-duty vehicles, impacting around 58 million new cars sold through 2035. For heavy-duty vehicles, Euro 7 will start to take effect in 2027, affecting a projected 3 million new trucks and buses that will be sold through 2050.

[1] See The global burden of transportation tailpipe emissions on air pollution-related mortality in 2010 and 2015 https://iopscience.iop.org/article/10.1088/1748-9326/ab35fc.

Media contact
Susana Irles, susana.irles@theicct.org
+49 (0) 302 332 68412

Publication details
Title: Emission reductions and public health benefits from timely Euro 7 standards
Authors: Nicole Egerstrom, Eamonn Mulholland, Jan Dornoff, Josh Miller, Felipe Rodríguez

About the International Council on Clean Transportation

The International Council on Clean Transportation (ICCT) is an independent research organization providing first-rate, unbiased research and technical and scientific analysis to environmental regulators. Our mission is to improve the environmental performance and energy efficiency of road, marine, and air transportation, in order to benefit public health and mitigate climate change. Founded in 2001, we are a nonprofit organization working under grants and contracts from private foundations and public institutions.

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Emission reductions and public health benefits from timely Euro 7 standards https://theicct.org/publication/euro7-premature-deaths-sep23/ Mon, 11 Sep 2023 21:30:01 +0000 https://theicct.org/?post_type=publication&p=28009 Models emission reductions and associated health benefits from implementing the Euro 7 standards as proposed, with increased stringency, and under a delayed timeline

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In November 2022, the European Commission released its proposed Euro 7 regulation for light-and heavy-duty vehicles, which limits the level of pollutants detrimental to human health, such as nitrogen oxides (NOx) and particulate matter (PM). This study models the emission reductions and health benefits from implementing Euro 7 as proposed, with increased stringency, and under a delayed implementation schedule.

The analysis finds that implementing the European Commission proposal for Euro 7 would avoid approximately 1 million tonnes of NOX from light- and heavy-duty vehicles through 2050. These reductions would avoid 7,200 premature deaths until 2050, with 56% attributed to reductions in emissions from heavy-duty vehicles. The analysis also finds that each year of implementation delay would lead to approximately 900 additional premature deaths. A delay in line with the proposals from the Environment Committee in the European Parliament would lead to an additional 1,800 premature deaths.

Added stringency, in line with the upper ambition of the impact assessment that accompanied the original Euro 7 proposal, could avoid totals of 5,500 premature deaths from light-duty vehicle emissions and 4,400 premature deaths from heavy-duty vehicle emissions. The additional benefits from increased stringency for light-duty vehicles are larger since the current proposal is comparatively less stringent to the proposal for heavy-duty vehicles.

 

chart showing cumulative deaths avoided due to various euro 7 implementation scenarios

This paper was updated on 9 November 2023 to correct values in Appendix Table 1B, and to reflect that those values are from 2025 to 2050. The original can be found here.

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Moorthy Nair https://theicct.org/team-member/moorthy-nair/ Mon, 07 Aug 2023 17:42:29 +0000 https://theicct.org/?post_type=team-member&p=27322 Moorthy Nair works as an Associate Researcher at the ICCT in New Delhi, India. He is currently involved in the Low Emission Zone (LEZ) programme for Indian cities at ICCT. His research interests include air quality models and management, health risk assessment, and the economic costs of air pollution. Prior to joining ICCT, he was […]

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Moorthy Nair works as an Associate Researcher at the ICCT in New Delhi, India. He is currently involved in the Low Emission Zone (LEZ) programme for Indian cities at ICCT. His research interests include air quality models and management, health risk assessment, and the economic costs of air pollution. Prior to joining ICCT, he was part of Programme Management Unit to the Government of Bihar facilitating effective implementation of City Clean Air Action Plans under the National Clean Air Program (NCAP), GoI. He has also worked at CSIR-NEERI, GoI where he was part of several projects including air quality monitoring, analysis, and pollutant dispersion modelling. Moorthy has a Master’s degree in Environmental Engineering from Manipal University and a Bachelor’s in Mechanical Engineering from Visvesvaraya Technological University, Belgaum.

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Vaibhav Kush https://theicct.org/team-member/vaibhav-kush/ Mon, 07 Aug 2023 17:22:33 +0000 https://theicct.org/?post_type=team-member&p=27316 Vaibhav Kush is a Researcher with ICCT’s India team, leading the Low Emission Zones work there. He engages with sub-national administrations to accelerate adoption of Low- and Zero Emission Zones in India. He has been working in the Sustainable Mobility sector since 2016, with expertise in safe systems, policy formulation and stakeholder engagements. Before joining […]

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Vaibhav Kush is a Researcher with ICCT’s India team, leading the Low Emission Zones work there. He engages with sub-national administrations to accelerate adoption of Low- and Zero Emission Zones in India. He has been working in the Sustainable Mobility sector since 2016, with expertise in safe systems, policy formulation and stakeholder engagements. Before joining ICCT, Vaibhav was associated with WRI India’s Sustainable Cities program for over six years, leading projects under Botnar CRS Challenge. He was actively involved in Haryana Vision Zero, pedestrianisation of Delhi’s Chandni Chowk, development of IRC guidelines on urban transport, etc. Prior to WRI India, Vaibhav has worked as an Architect and was involved in the design of large scale green building projects like corporate parks, Inter-container Depots, universities, etc. Vaibhav has a bachelor’s in Architecture and a Master’s in Urban Planning from the School of Planning and Architecture, Delhi. He is a member of several professional bodies including International Sociological Association, Institute of Town Planners India, Council of Architecture, Indian Roads Congress, Indian Institute of Architects, Indian Buildings Congress, among others.

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Soot-free road transport in South Africa: A cost-benefit analysis of Euro VI heavy-duty vehicle standards https://theicct.org/publication/africa-me-hvs-soot-south-africa-dec22/ Tue, 20 Dec 2022 23:28:48 +0000 https://theicct.org/?post_type=publication&p=22180 Argues that South Africa would enjoy substantial benefits in adopting Euro VI standards for its diesel HDV fleet, and is in a strong position to do so.

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This study estimates the costs and benefits of adopting Euro VI standards in diesel HDVs in South Africa under different timelines of fuel quality and emission standard advancements. Based on the results, we also make policy recommendations that would reduce HDV emissions and improve air quality and public health in South Africa.

Transportation was responsible for 7% of deaths caused by exposure to PM2.5 and ozone in 2015 in South Africa, and of these deaths, 48% are attributed to on-road diesel vehicles. Severely outdated vehicle emission standards have contributed to this deadly air pollution: the current HDV emission standards in South Africa are Euro II, first introduced in Europe more than 20 years ago and phased-out long ago there and in other major economies. South Africa has not updated its official emission standard regulations since adopting Euro II standards in 2006. Diesel engines that lack modern emission control devices produce PM2.5, soot, nitrogen oxides (NOx) and other pollutants in large quantities.

Our analysis finds that South Africa would enjoy substantial benefits in adopting Euro VI standards for its diesel HDV fleet. The announcement of a 10 ppm sulfur diesel requirement by 2023 provides a great window of opportunity for modern emission standards to sync with fuel quality improvements.

With a timeline of implementing Euro VI standards in 2024, the societal benefits associated with reduced HDV tailpipe emissions can outweigh the costs of technology advancements and operating expenses by a ratio of 8.2:1 (5% discounted) between 2021 and 2050. By contrast, delaying the implementation of 10 ppm sulfur diesel requirements or Euro VI standards will diminish the health benefits and lead to a net welfare loss for South Africa.

Future analyses could expand on this study and examine the potential air quality impacts and the costs and benefits of electrification in combination with an improved understanding of reduced non-fatal NOx emissions under Euro VII aftertreatment technologies, potential HDV fuel economy or CO2 regulations, and fleet renewal.

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Will EPA’s proposed clean truck emission standards deliver environmental justice in U.S. states? https://theicct.org/epa-truck-standards-environmental-justice-jun22/ Tue, 28 Jun 2022 20:32:55 +0000 https://theicct.org/?p=21359 Adopting the most stringent possible rule can address the disproportionate impacts of emissions from diesel trucks and alleviate health burdens.

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Years of research have shown the severe health impacts of diesel truck emissions and their disproportionate impact on people of color. Communities living near truck traffic are all too familiar with the respiratory, cardiovascular, and other health issues that result from breathing polluted air. Although pollutant emissions from trucks have declined since the introduction of the U.S. Environmental Protection Agency (EPA) 2010 standards, trucks remain a significant source of air pollution and inequitable health impacts.

The Biden administration has committed to addressing current and historic environmental injustices, and for the first time in 20 years, EPA is updating emission limits for heavy-duty engines. This rare opportunity to implement strong emission standards will impact air quality and health for decades to come. It is also a chance to advance environmental justice by adopting the most stringent possible rule to address the disproportionate impacts of diesel trucks and alleviate health burdens.

EPA released their proposed rule in March of this year, putting forward two options to limit emissions of nitrogen oxides (NOx), starting with trucks manufactured in 2027. We analyzed the health benefits and environmental justice implications of the more stringent option, Option 1, finding that as soon as 2035, the rule will result in over $4.8 billion in monetized health benefits annually.

Emission reductions from a strong HDV rule will especially benefit groups who are disadvantaged in terms of particulate matter (PM) exposure and traffic proximity, as defined by the Climate and Economic Justice Screening Tool. Under EPA’s Option 1, these groups will see some of the largest benefits, experiencing 26%–27% greater than average reductions in PM exposure. These communities account for a small fraction of the total U.S. population (<4%) but their racial makeups reflect the inequities in traffic-related environmental hazards: more than 80% of the residents of these communities are people of color. Adopting a less stringent option, such as EPA’s proposed Option 2, would reduce benefits to these communities and fail to adequately address the disparate impacts of diesel trucks.

While all states will benefit from more stringent emission standards, states in the Midwest and South are projected to benefit the most relative to their population size, as shown in Figure 1. These are primarily states with high-traffic interstates and large populations living in close proximity to diesel truck-related pollution.

Map showing state share of monetized health benefits under EPA heavy-duty emissions rule option 1

Figure 1. The ratio of each state’s share of monetized health benefits in 2035 under EPA’s Option 1 compared to each state’s share of national population.

Benefits to environmental justice communities also vary by state, as shown in Figure 2, with some of the largest benefits going to states currently with significant exposure disparities. These communities are defined by select EPA environmental justice criteria such as income, race, PM exposure, and air pollution-related disease. Several states ranking highest in terms of benefits to environmental justice communities from EPA’s Option 1 are states that have significant racial disparities in diesel-related PM exposure. Indiana, Missouri, Ohio, and Pennsylvania are all states where people of color are exposed to 24%–35% more PM from diesel trucks compared to the state averages.

Chart showing health benefits of EPA's heavy-duty standards option 1 to disadvantaged communities

Figure 2. Health benefits of EPA’s proposed Option 1 to populations meeting any environmental justice criteria in 2035 by state, in annual premature deaths avoided per 1,000,000 population.

The health equity implications of this ruling extend beyond just NOx emissions—ambitious climate mitigation efforts are also needed to limit increases in inequitable health burdens. Communities are already feeling the effects of climate-related weather disasters, and overall health impacts of climate change are also projected to increase. Under a 2°C global warming scenario, Black children are 34% more likely to live in areas with the highest projected increases in childhood asthma incidences due to changes in weather patterns. These areas are highly concentrated in Southern states, where diesel trucks already have disproportionate impacts on air pollution and health. Significant greenhouse gas reductions are needed to limit these additional climate-related health effects as much as possible. California and 5 other states have adopted zero-emission sales requirements through the Advanced Clean Trucks rule and an additional 11 states plus Washington DC have signed onto a Memorandum of Understanding, committing to accelerating the transition to zero-emission trucks. However, these state level policies alone aren’t enough to reach climate goals—a strong federal policy is also needed. The proposed rule includes updates to the current Phase 2 greenhouse gas emission standards, but more ambitious action is needed. EPA’s heavy-duty vehicle rule must also set zero-emission vehicle targets to have a chance at limiting warming to 2°C.

EPA’s rule, scheduled to be finalized later this year, will have a huge impact on air quality and health across the nation. Communities exposed to the highest levels of diesel truck-related air pollution will be most affected by this decision. Now is the time to take decisive action toward environmental justice and implement stringent heavy-duty NOx limits and zero-emission sales targets to protect public health.

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Proposed EPA emission standards will deliver cleaner trucks and buses, but more is needed https://theicct.org/epa-hdv-proposal-march2022-statement/ Tue, 08 Mar 2022 20:05:32 +0000 https://theicct.org/?p=19764 8 March 2022 (Washington DC) – Yesterday the U.S. Environmental Protection Agency’s (EPA) Office of Transportation and Air Quality issued a proposed rule to limit emissions of nitrogen oxides and greenhouse gases from new heavy-duty engines and vehicles. Existing pollution limits on diesel trucks were set more than twenty years ago. This Administration deserves tremendous […]

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8 March 2022 (Washington DC) – Yesterday the U.S. Environmental Protection Agency’s (EPA) Office of Transportation and Air Quality issued a proposed rule to limit emissions of nitrogen oxides and greenhouse gases from new heavy-duty engines and vehicles. Existing pollution limits on diesel trucks were set more than twenty years ago. This Administration deserves tremendous credit for proposing the next generation of clean truck standards.

The proposed standards have the potential to reduce a significant number of premature deaths, childhood asthma cases, and disparities in pollution exposure among the nearly 72 million people – disproportionately people of color and low-income households – living along diesel truck corridors. But to realize this opportunity, these new standards must reduce the real-world NOx emissions of diesel trucks and they must be finalized by the end of the year.

EPA puts forward as their first option a proposal that aligns with California model year 2027 NOx engine standards in model year 2031. This is a big step in the right direction. Certain elements of the proposal do not capture the full benefits available, and so in the coming weeks we will be recommending additional ways EPA can strengthen these. ICCT modeling shows that nationwide alignment with the California Omnibus rule could avoid $1.3 trillion in health damages associated with ambient PM2.5 and ozone pollution from 2027-2050.

With the realities of climate change upon us, new truck pollution standards should also be aimed at moving the markets towards ambitious, science-based goals that are balanced by feasibility. While the proposal includes updates to GHG emission limits on heavy-duty trucks, these changes simply meet the markets where they are without moving them forward. Our research shows that far more is possible and far more is needed.

We look forward to responding to the EPA request for comments on how its proposal could promote electrification of heavy-duty vehicles, such as transit and school buses and urban delivery trucks. We recently outlined how this could be done in this briefing. In the coming weeks we will be sharing with EPA the ways in which we think the proposal can require far more electrification of the truck and bus fleet.

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