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 ofthe 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 wi ll help to drive down emissions sooner and help move us further down the path to clean , healthy air by cuttin g sign ifi ca ntly 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 crite ria air pollutants from the truck sector
. Second, we urge EPA to immediately begin a low NOx emission rulemaking on the national level. EPA shou ld 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 . Cal ifornia' s clean air progress must be p rotected against ongoing inte r-state truck traffic with higher emissions. With a stronger ozone standa rd 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 technologi es are vital to achieving the major reductions needed here
. Retaining the focus on advanced technologies will a lso allow for a stronger overall standard and greater health and fuel savi ng benefits to be achieved.
Particle pollution from the increased use of Auxiliary Power Units must be reduced through filters. Th e 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 s imply cannot afford t rade-offs in this ru le that wou ld a llow 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 ma intaining 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 cont inui ng 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
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Will Barrett 1Senior Policy Analyst Ameri can Lung Association in California 1531 I Street, Suite 201, Sacramento, CA 95814 Ph: 916-585-76631 Email: william
.barrett@lung.org