May 22, 2023

Ann Mesnikoff

Testimony on Clean Car Standards

Vehicles are a leading source of both climate pollution and dangerous air pollution that impacts communities across the Midwest Great Lakes states.

The U.S. Environmental Protection Agency has proposed new standards on greenhouse gas emission from light- & medium-duty vehicles vehicles such as passenger vehicles and medium duty trucks. Here is my testimony calling for stronger standards:

TESTIMONY OF ANN MESNIKOFF, FEDERAL LEGISLATIVE DIRECTOR, ENVIRONMENTAL LAW & POLICY CENTER.
on US EPA Multipollutant Standards for Light- & Medium-Duty Vehicles

May 10, 2023 – WASHINGTON D.C.

ELPC urges EPA to:

• Adopt standards stronger than Alternative 1 for GHG emissions and the strongest possible criteria pollution standards.
• Continue standards after 2032 to sustain reductions and the transition to an all-electric fleet and
• Issue stronger standards for gasoline powered vehicles for MY 2027 and beyond.

Vehicles are a leading source of both climate pollution and dangerous air pollution that impacts communities across the Midwest Great Lakes states where ELPC works.

Reducing greenhouse gas pollution from America’s cars and light trucks is critical to mitigating climate change and achieving President Biden’s goals and commitments including rejoining the Paris Climate agreement. Vehicles also contribute to smog forming and other pollution that directly compromises public .

Climate change is already bringing havoc globally and we are seeing impacts across the Midwest and the Great Lakes region. Climate change threatens the Great Lakes ecosystem, fresh water supplies, and the economies that depend on them.

In addition to the pollution that is literally driving the climate crisis, this proposal recognizes the harms from other vehicle pollutants linked with premature death and other serious health impacts. This air pollution affects communities across the Midwest and nationwide, with greater impacts on Black, Brown, and low income communities who live or work near transportation corridors.

EPA should finalize the strongest possible standards by the end of this year. And as EPA notes, stronger standards for criteria pollutant will bring critical health benefits and assist areas across the country comply with NAAQs standards for PM and Ozone.

EPA’s final rule must be at least Alternative 1 with additional stringencies. Weaker standards should be rejected.

Alternative 1 provides the fastest near term reductions and results in the lowest GHG fleet average as compared to the proposed standard or other alternatives. EPA should maintain the rate of improvement in the first years of Alternative 1 to the later years.

We appreciate EPA’s effort to close or limit various credit loopholes such as off-cycle credits, addressing the AC credits and closing the distance between the car and light truck curves. The final rule should end the AC credit and phase out the off-cycle credits before model year 2030.

Skipping to Medium Duty vehicles – EPA should ensure final rules that drive electrification and achieve the greatest cuts in criteria pollution. Final standards should deter manufacturers from evading safeguards by upsizing and upweighting pickups.

As I think about EPA’s Medium Duty standards I consider my son who graduates from college next Monday. He is already a working EMT in New York City spending long hours in an ambulance -driving and refueling; he plans on becoming a paramedic. Stronger standards for medium duty vehicles including ambulances will benefit those that drive these vehicles and the communities they serve.