Heavy-duty vehicles emit a lot of air pollution. EPA can change that.

Last spring, the Environmental Protection Agency (EPA) proposed regulations under the Clean Air Act to limit greenhouse gas (GHG) emissions from heavy-duty vehicles (HDVs).  The proposed rule sets standards for model years 2027-2032 and covers GHG emissions from a variety of HDVs, including heavy-duty vocational vehicles (e.g., delivery trucks and school buses) and tractor-trailer trucks. EPA originally planned to publish its final Phase 3 rule at the end of last year, but it has since delayed publication.  

The heavy-duty vehicle market is already preparing to decarbonize, and a large swath of federal and state programs will support zero-emission trucking and infrastructure buildout.  It is critical that EPA keep the HDV sector on the right track and publish a strong final rule as soon as possible.   

Strong heavy-duty vehicle standards are necessary to improve public health and fight climate change

EPA must finalize strong HDV standards to address public health and help fulfill the Biden administration’s environmental justice commitments. Heavy-duty vehicles emit GHGs and other dangerous air pollutants, such as particulate matter, nitrogen oxides (NOx), and volatile organic compounds (the latter two being ozone precursors). And while medium-and heavy-duty vehicles make up only a small fraction of on-road vehicles in the U.S., they generate “59% of ozone- and particle-forming NOx emissions and 55% of the particle pollution.”  

CATF recently analyzed the health and economic consequences of diesel vehicle emissions. In CATF’s Deaths by Dirty Diesel mapping, we found these emissions led to over 8,800 deaths, 3,700 heart attacks, hundreds of thousands of respiratory illnesses, and approximately $100 billion in monetized health damages across the country in 2023. It is well-documented, including by EPA, that these emissions disproportionately harm people of color and low-income communities.  

Failing to finalize heavy-duty vehicle emission standards also threatens our ability to achieve net-zero GHG emissions by 2050.  The transportation sector is responsible for an increasing percentage of GHG emissions and plays an outsized role in intensifying climate change. In 2021, it surpassed the electric power sector to become the single largest U.S. source of GHG emissions, causing 28.5% of total emissions. Medium- and heavy-duty vehicles are the second-largest domestic contributor to emissions in the transportation sector, emitting approximately 417.1 million metric tons CO₂e per year in the U.S., and vehicle miles traveled are only expected to rise.  

Zero-emission heavy-duty vehicles are on the rise, and a strong final rule will drive further progress

The pace of manufacturers’ announcements demonstrates that the heavy-duty trucking industry is already moving toward zero-emission vehicles (ZEV). This progress lays the foundation for further improvements that can be driven by strong regulations. New announcements from manufacturers come out regularly. A few recent examples: 

• Mercedes announced a new battery-electric long-haul truck – the eActros 600 – that can travel 311 miles on a single charge while hauling up to 22 tons of cargo.  It was set to go on sale at the end of 2023, with series production beginning in late 2024.  
• Nikola released a new Class 8 fuel cell electric vehicle (FCEV) with a 500-mile range and 20 minute refueling time and is already delivering trucks to buyers. 

• Ford signed a letter of intent for Quantron AG to provide it with hydrogen fuel-cell stacks for Ford’s F-Max commercial truck lineup.  
• Orange EV launched a new Husk-e Series electric terminal truck for port operations, rail, and other heavy-duty applications and is actively taking orders. 
• General Motors will supply hydrogen fuel cells to Autocar Industries, which will begin producing HD trucks in 2026.   

New vehicles are also successfully being tested on long-haul routes. For example:  

• Tesla’s new Class 8 battery electric vehicle (BEV) semi-truck recently traveled over 1,000 miles in a day with only 3 stops to reload and charge. 
• Daimler’s Mercedes-Benz GenH2 cabover FCEV – an 88,000-pound truck-and-trailer – completed a 650-mile run on a single hydrogen fueling.  
• Crowley agreed to test Terraline’s battery electric class 8 long-haul truck this year. The agreement includes an option to order trucks for delivery in 2026.     

School districts across the country, from California to Texas to Illinois to New York, also continue to announce plans to decarbonize their bus fleets.  According to the Department of Energy, 49 states had electric school bus commitments as of mid-2023.  And EPA just announced nearly $1 billion in grants to fund clean school buses across the country. 

Importantly, the heavy-duty zero-emission vehicle industry provides several options for decarbonizing HDVs. Along with battery electric vehicles, fuel cell electric vehicles are an appealing zero-emission vehicle technology for specific trucking operations, particularly long-haul. Like diesel trucks, fuel cell electric vehicles can complete long-haul routes without many additional refueling stops and can be refueled in approximately the same amount of time. Fuel cell electric vehicles can also carry up to 98% of the cargo that diesel trucks can carry when fully loaded. This makes fuel cell electric vehicles an excellent diesel replacement on long-haul routes, thus increasing the percentage of a given truck fleet that can be decarbonized and improving operational flexibility. 

Regulatory certainty from a strong, national HDV rule will encourage greater private investment in infrastructure by letting industry know what must be built over the next decade.  Indeed, buildout plans are already moving forward.  For example:  

• Air Liquide and Trillium signed an MOU to develop HDV hydrogen fueling infrastructure in the U.S. Their goal is to “initially support the development of 150 tons per day of hydrogen production and the refueling infrastructure capable of supplying more than 2,000 heavy-duty vehicles.”   
• Daimler announced a partnership with Electrada to build out infrastructure for its medium- and heavy-duty electric vehicles. 

A strong national HDV rule will complement federal and state programs targeting zero-emission trucking and infrastructure buildout

Federal and state dollars will help support the adoption of heavy-duty zero-emission vehicles and make it easier for manufacturers to meet a strong federal HDV rule.  A slew of federal programs help fund the adoption of heavy-duty zero-emission vehicles.  CATF compiled a resource guide of federal programs available to support state adoption of California’s Advanced Clean Truck rule; these programs will also help implement a national HDV rule.  Even programs billed as more general pollution reduction funds – such as the Climate Pollution Reduction Grant Program – can be used for HDV deployment and infrastructure.  Alongside federal funds, state programs like California’s Hybrid and Zero-Emission Truck and Bus Voucher Incentive Project grants provide up to an additional $240,000 per vehicle. 

Federal investment will also bolster infrastructure.  For example, under the Inflation Reduction Act:  

• The Alternative Fuel Refueling Property Credit provides credits for BEV charging stations and hydrogen refueling stations.  The Congressional Joint Committee on Taxation estimated that the credit would amount to nearly $2 billion over its lifetime.   
• The Advanced Energy Project Credit provides $10 billion for qualifying advanced energy projects, which include charging and refueling infrastructure for ZEVs as well as electric grid modernization equipment and components.   

Additionally, the Infrastructure Investment and Jobs Act (IIJA) allocates billions of dollars to HDV infrastructure buildout, including:  

• $7.5 billion for building out ZEV charging infrastructure, including the $5 billion National Electric Vehicle Infrastructure Formula Program and the $2.5 billion Charging and Fueling Infrastructure Program. 
• $2.5 billion through the National Alternative Fuel Corridors Program for infrastructure to deliver alternative energy carriers like electricity and hydrogen along major highway. 
• Roughly $2.5 billion each year through 2026 through the Congestion Mitigation and Air Quality Management program. 
• $50 million to reduce truck emissions at port facilities. 
• $2.25 billion through the Port Infrastructure Development Program for projects to reduce or eliminate port-related pollution. 

For fuel cell electric vehicles specifically, the IIJA appropriates $8 billion for regional clean hydrogen hubs, $1 billion for the Clean Hydrogen Electrolysis Program, and $500 million for the Clean Hydrogen Manufacturing Initiative.  DOE recently selected 7 regional clean hydrogen hubs that will receive funding, which span across the country.  Of the 7 hubs selected, 6 include plans to build hydrogen refueling infrastructure for HDVs.  The hubs will accelerate the necessary buildout of hydrogen infrastructure.  This will expedite fuel cell electric vehicle market growth, as hydrogen hubs will be looking for off-takers.  Heavy duty trucking will likely move between hubs, stopping in regions across the U.S. to refuel with clean hydrogen. 

Zero-emission heavy-duty vehicle corridors will bolster EPA’s rule

Heavy-duty zero-emission vehicle corridors are being planned along several key freight highways around the country.  For example, CALSTART, Cummins, GTI Energy, and National Grid have received $7.4 million from the DOE to work on projects to develop medium- and heavy-duty electric vehicle charging and hydrogen corridor infrastructure plans along I-95, I-80, I-10, and the I-710.  Additionally, the West Coast Clean Transit Corridor Initiative is an ongoing, collaborative effort among 16 utilities to support the development of battery electric vehicle charging facilities along I-5, from San Diego to British Columbia, for heavy- and medium-duty freight haulers and delivery trucks. CATF is creating an HDV corridors resource guide that will outline how IRA and IIJA funding can be used for cost-effective development of clean corridors, which will promote the growth of a zero-emission long-haul trucking industry. 

EPA must release a final HDV rule to support existing initiatives within the heavy-duty vehicle industry to decarbonize and curb harmful public health emissions

Taken together, these incentives and announcements form a sturdy basis for a strong final HDV rule. Fleets will have plentiful options for reducing and even eliminating their vehicles’ emissions, and infrastructure will meet the needs of the market by the time EPA’s rule takes effect.   

Importantly, infrastructure needs for heavy-duty zero-emission vehicles will be modest at first and grow gradually over time.  The International Council on Clean Transportation recently published analysis demonstrating that EPA’s HDV rule would require very limited infrastructure deployment by 2030. Coordinated state and federal funding will ensure that HDV infrastructure will be built to meet the needs of EPA’s rule. 

The HDV market is preparing; it is EPA’s responsibility to set strong standards that build on technological progress and reduce emission of dangerous pollutants that disproportionately impact the most vulnerable populations. Now is the time for bold action to protect people and the planet.