ERM was commissioned by the Natural Resources Defense Council (NRDC) and the Union of Concerned Scientists (UCS) to evaluate the costs and benefits of state-level adoption of clean truck regulations. The focus of ERM’s assessments were to analyze increased sales of zero- and low-emission medium- and heavy-duty (M/HD) trucks and buses. These analyses included all on-road, Class 2b through 8 vehicles in each state or region.
M/HD vehicles are responsible for a disproportionate share of greenhouse gas (GHG), nitrogen oxides (NOx), and particulate matter (PM 2.5) emissions from on-road vehicles. Both NOx and PM2.5 emissions contribute to poor air quality and result in negative health impacts in many urban areas. Low-income and disadvantaged communities are often unduly affected M/HDV emissions due to their proximity to highways and major trucking routes.
For each of the reports, ERM modeled three Clean Truck Policy scenarios with increasing levels of ambition:
- California’s Advanced Clean Trucks (ACT) Rule,
- ACT Rule plus California’s Heavy-Duty Omnibus Rule (NOx Omnibus Rule), and
- A 100 x 40 + Clean Grid Scenario where M/HD ZEV sales reach 100 percent by 2040 and include significant reductions in electricity generation emissions.
The results of these three policy scenarios are compared with a baseline, “business-as-usual” scenario in which all new trucks sold continue to meet existing EPA NOx, PM, and GHG emission standards and ZEV sales increase only marginally.
Each report includes a description of the M/HDV fleet within the state or region, the projected fleet under each modeled policy scenario, and a summary of the environmental, public health, and economic impacts of the modeled fleet transitions. Environmental impacts include changes in tailpipe and upstream GHG, NOx, and PM emissions from reduced diesel and gasoline use and increased electricity use from higher ZEV adoption. Economic impacts include:
- the financial investments required for charging infrastructure,
- the costs and savings associated with owning and operating a ZEV,
- the additional revenue or costs to electric utilities to charge the M/HD ZEVs,
- the change to national jobs, wages, and gross domestic product (GDP), and
- the monetized climate benefits from reduced GHG emissions and public health benefits from reduced NOx and PM emissions.
In addition to the state-specific studies, ERM was commissioned by NRDC and UCS to conduct an analysis on the impacts of EPA’s newly proposed heavy-duty engine standards. The Federal Clean Trucks Program Report analyzes the impacts of low NOx vehicles and ZEVs on the environment, public health, and the economy at a national level.
This analysis differs from the state-level reports as it only included Class 4 to 8 vehicles and evaluated how EPA’s assumption of M/HD ZEV adoption across the U.S. changed the benefits from increased heavy-duty engine standards. The analysis includes EPA’s “baseline” ZEV adoption as well as an “enhanced baseline” with a more realistic assumption of ZEV adoption considering existing state regulation, fleet commitments, and projected decline in total cost of ownership of ZEVs. Both baseline trajectories were used as comparison to a scenario modeling EPA’s proposed NOx regulation (Option 1) and a U.S.-wide ACT plus NOx Omnibus policy scenario.
2023 Benefit Cost Analysis Refresh
The analysis framework was updated in 2023 to utilize newer and more robust cost and emission assumptions, including recent economic growth projections from EIA’s Annual Energy Outlook 2023 (2022$), as well as account for new vehicle emission standard changes (e.g., EPA’s latest NOx standard for heavy duty vehicles). Due to EPA’s introduction of increased NOx regulations for new trucks, state reports in 2023 and beyond do not include a scenario with California’s Heavy-Duty Omnibus Rule (NOx Omnibus Rule):
Documents
Pennsylvania Clean Trucks Reports
California Clean Fleets Report
New Jersey Clean Trucks Report