Kennedy Expressway, Chicago


Susan Mudd

Testimony on Greenhouse Gas Emission Standards for Heavy-Duty Vehicles

Trucks and buses account for one-third of transportation climate pollution. The EPA risks further harming disadvantaged communities without strong limits on truck pollution.

The U.S. Environmental Protection Agency has proposed new standards on greenhouse gas emission from heavy duty vehicles such as trucks and buses. While it is good to regulate these dangerous vehicles that pollute our air, the proposed rule does not go far enough to protect the most vulnerable in our communities. Here is my testimony calling for stronger standards:

on US EPA Greenhouse Gas Emissions Standards for Heavy-Duty Vehicles – Phase 3 Proposed Rule

May 5, 2023 – WASHINGTON D.C.

Thank you for the opportunity to testify. My name is Susan Mudd. I live in Chicago, the mother of 2, and am a Senior Policy Advocate at the Environmental Law and Policy Center, the Midwest’s leading environmental advocacy organization, where my work focuses on reducing diesel pollution.

I thank this administration for acting on greenhouse gas standards for trucks AND urge EPA to finalize the strongest possible limits on heavy duty vehicle pollution this year.

Vehicle pollution affects everyone, but the burden of living with unhealthy air is not shared equally. The EPA risks further harming disadvantaged communities if the strongest possible limits on truck pollution aren’t created.

ELPC is specifically concerned about the threat climate change poses to the Midwest’s 61 million people. Midwest temperatures are rising due to climate change, impacting public health with worsening air quality.

EPA must do all it can to avert the worst impacts of the climate crisis and thus issue strong, technology-forcing standards for heavy duty trucks to slash U.S. climate pollution.

Trucks and buses account for one-third of transportation climate pollution.

The Midwest is criss-crossed by interstate highways carrying tens of thousands of trucks per day. Densely populated neighborhoods in Chicago, Cleveland, Indianapolis, Milwaukee, Detroit, Minneapolis, and Des Moines are each crossed daily by at least 50,000 or more trucks.

Residents of these Midwest cities are among the 72 million people nationally living closest to trucking routes, and therefore most affected by freight pollution, and are more likely to be lower income people of color, according to EPA; that’s true for Chicago, Cleveland, Detroit and Milwaukee.

Children attending school near major roads are disproportionately children of color and from low-income households. In Chicago alone some 30 k-12 schools are within 500’ of heavily truck trafficked interstates, exposing 15,000 students to these emissions daily.

The youngest and future attendees of these schools will benefit greatly from the cleaner trucks and buses resulting from the strongest possible rules.

This year’s American Lung’s State of the Air report documented 2 counties in Indiana and Michigan as among the 25 worst counties in the US for year-round particle pollution and 8 Midwest counties with failing grades for daily spikes in particle pollution.

Stronger GHG standards, while reducing CO2 emissions, will have the additional benefit of reducing PM emissions, thus easing the suffering of those with asthma and COPD.

Strong emission standards from EPA will support innovation and the vehicle manufacturing sector critical to Midwest states economies. Indeed the market is already transitioning to zero-emission vehicles.

Strong standards would deliver massive emission reductions and life-saving relief to frontline communities and help achieve the goals of the Justice 40 initiative. Our nation and particularly disadvantaged communities need the federal government to lead. A handful of states have set stronger standards for heavy duty vehicle emissions. But that’s not enough to make a difference for kids in the Midwest. Now is the time for the EPA to set the strongest possible standards on heavy duty vehicle pollution to protect ALL US residents. At a minimum, EPA should ensure a clear pathway to zero emissions by 2035.

Susan Mudd,

Senior Policy Advocate

Susan Mudd is an attorney and senior policy advocate for ELPC, where she directs ELPC’s Diesel Pollution Reduction Initiative to protect children’s and community health, ELPC's Electric School bus campaign and with ELPC’s Science Advisory Council.

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