Testimony of Will Barrett 

Senior Policy Analyst 

American Lung Association in California T

AMERICAN 

LUNG 

ASSOCIATIONf: 

Proposed Rulemaking: Phase 2 Greenhouse Gas Emissions Standards and Fuel Efficiency 

Standards for Medium- and Heavy-Duty Engines and Vehicles 

The American Lung Association supports the strongest possible greenhouse gas and smog 

controls on the nation's trucks, buses and other polluting sources. We support EPA's efforts to 

update all standards to match the scientific understanding of the harms we face from criteria 

air pollutants, taxies and climate change. We view the Phase 2 rule as an important step in 

this direction, but do feel that more is needed to address our urgent air quality problems. 

We at the Lung Association share the EPA's view that climate change first and foremost 

represents a public health crisis and a public health opportunity. Earlier this year, we launched 

our public awareness campaign: Doctors for Climate Health to bring this point home. 

This past April, the American Lung Association's annual State of the Air report once again 

found that the Los Angeles metropolitan area is among the most polluted in the nation for both 

ozone and particle pollution. Transportation pollution threatens the health of all residents of this 

region, but especially children, seniors, people living with asthma, COPD and other respiratory 

conditions. Pollution from the transportation sector is an added burden for those communities 

most disadvantaged by multiple pollution sources, including refineries, ports, rail yards and the 

freeways that carry the nation's goods through these communities first and most. 

It is appropriate and appreciated that the EPA would host a hearing on the Phase 2 rules in 

Southern California. The residents of this region and our Central Valley have perhaps the most 

to gain from a strong rule of any area in the nation. In the past months, we have seen record 

temperatures, raging wildfires, torrential flooding and a persistent drought that has grown over 

the past four years into a major threat to air quality, water supplies, and the way of life that 

makes California unique. 

The American Lung Association offers the following recommendations to strengthen the 

stringency and timing of the proposal to address several key elements of California's 

commitment to protecting public health and air quality. 
The rule should achieve 40 percent fuel savings and the implementation period should 

follow Alternative 4, bringing the rule online by 2024. The urgency of climate change and 

the air pollution challenges in California indicate that we need all emission reductions possible 

in the near-term. A stronger standard and timeframe will help to drive down emissions sooner 

and help move us further down the path to clean, healthy air by cutting significantly more 

climate pollution and reducing petroleum consumption more rapidly. There is no reason to 

delay, and action now will also help to spur further action to reduce criteria air pollutants from 

the truck sector. 

Second, we urge EPA to immediately begin a low NOx emission rulemaking on the 

national level. EPA should begin a concurrent low-NOx standard to ensure that all trucks 

working in California are held to the standards we need to protect our citizens from ozone 

pollution. California's clean air progress must be protected against ongoing inter-state truck 

traffic with higher emissions. With a stronger ozone standard on the horizon, a national lowNOx standard will help all regions with attainment, but especially Southern California. 

Advanced technology credits should be maintained in Phase 2, rather than phased out. 

Given the severe air quality conditions in the South Coast and San Joaquin Valley, 

California needs truly zero emission technologies to be moving our freight. Without a 

strong commitment to advanced technologies and electrification in this sector, the overall 

proposal is missing a critical tool that California needs. In particular, battery electric, fuel cell, 

hybrid and other advanced technologies are vital to achieving the major reductions needed 

here. Retaining the focus on advanced technologies will also allow for a stronger overall 

standard and greater health and fuel saving benefits to be achieved. 

Particle pollution from the increased use of Auxiliary Power Units must be reduced 

through filters. The projected increase in Auxiliary Power Units, and associated particle 

pollution increases, must be mitigated with the use of particle filter systems as are required 

inside of California. We simply cannot afford trade-offs in this rule that would allow for 

increased carcinogenic diesel exhaust or climate forcing black carbon emissions. 
In closing, the American Lung Association urges the EPA to continue on with the 

rulemaking by strengthening the proposal with: 

o more rapid implementation of a stronger standard 

o beginning a low-NOx standard process immediately 

o maintaining a greater focus on advanced technologies, and 

o preventing increased particle pollution 

We appreciate the opportunity to speak to you today and look forward to continuing to work 

together with you and the California Air Resources Board to protect the health of all 

Americans. 

Finally, as a parent to two elementary school children, I thank you for your leadership to 

protect their future. 

Will Barrett 1 Senior Policy Analyst 

American Lung Association in California 

1531 I Street, Suite 201, Sacramento, CA 95814 

Ph: 916-585-76631 Email: william.barrett@lung.org