The E.P.A.’s Phase 3 Greenhouse Gas Emissions are essentially an “EV Mandate,” argues TTP President Daniel Gage.
The founding of the Natural Gas Vehicle Coalition in the late 1980’s coincided with the start of a new era for alternative fuels. Addressing energy security was a top priority, and Congress was preparing a major rewrite of the Clean Air Act.
In the three-plus decades since a lot has changed Our organization – now known as Transport Project — has actively partnered with U.S. Environmental Protection Agency (EPA) policymakers and other federal regulators. We have worked closely with these agencies to advance the switch to cleaner, domestic transportation fuels.
The result: Deployment of hundreds of thousands of clean natural gas cars, trucks, and buses on America’s roadways, clearing the air of harmful criteria pollutants and decarbonizing commercial fleets.
But today, we are sadly suing the EPA. How did we get here?
Discarding RNG
The simple answer is new EPA mandates as they relate to on-road transportation are unrealistic and unimplementable. Moreover, they work against complementary science-based policies and initiatives that EPA itself is advancing
And it gets worse. After years of championing affordable conventional and renewable natural gas (RNG) to achieve dramatic emission reductions, EPA has soured on any vehicle without an electrical cord. The EPA’s Greenhouse Gas Emissions Standards for Heavy-Duty Vehicles – Phase 3 released in March effectively discards RNG and other biofuels as viable alternatives.
First the facts. Trucks and buses powered by RNG are 90 percent cleaner than the current cleanest diesel, delivering a zero-emission equivalent in terms of harmful criteria pollutants. For decarbonization efforts important to climate, RNG trucks can achieve a carbon-negative outcome.
And RNG trucks are proven, affordable, scalable, and on our roads today, delivering heavy-duty workloads that will be impractical to electrify.
A De Facto EV Mandate
Phase 3 defenders say the rule is not a mandate. They argue that it is technology-neutral and performance-based. And this, they say, allows each manufacturer to choose what set of emissions control technologies is best suited to meet the standards and the needs of their customers.
But this rule effectively places the federal government’s finger on the scale for battery electric to the detriment of any other solution.
Truck and engine makers must weigh unwieldy compliance requirements against market demand and real-world economics. They are forced to sell an increasingly larger share of battery electric or hydrogen fuel cell vehicles to meet tailpipe-specific GHG emission targets. And these targets are increasingly unachievable by internal combustion engines.
Phase 3 is a de-facto EV mandate.
And herein lies the contradiction. Through its Renewable Fuel Standard and Methane to Markets programs, EPA has advanced the role biofuels like RNG and biodiesel play in decarbonizing our nation’s emissions. The agency has incentivized their development and expanding their production.
But in the Phase 3 tailpipe rule, EPA blindly limits their end use and thus their ability to play a broader role.
For years now EPA has stated in rulemakings and proposals that life cycle emissions matter. And it is worth noting that reliable tools exist for evaluating full life cycle.
Yet the Phase 3 rule inexplicably ignores upstream emissions to focus solely on an antiquated tailpipe standard. And doing so allows EPA to promote electric vehicles over other equally beneficial solutions like biofuels.
EPA policy must engage all realistic, cost-effective, and available solutions. It is myopic to think that only one technology will solve the global climate issue.
A central point in TTP’s argument is that RNG trucks are proven, affordable, scalable, and on our roads today, delivering heavy-duty workloads that will be impractical to electrify.
Moving freight – everything we eat, wear, and use – involves high volumes and low margins. Cost matters. The ease of incorporating in new technologies matters. Upending existing operations and business models will not yield success.
The Transportation Project is Born
This past April, our organization transformed into The Transport Project (TTP). Our organization is a broad collective of industry drivers from every corner of the commercial transportation field. Our members include fleets and end users, vehicle dealers, servicers and suppliers, fuelers and fuel producers, and OEMs and engine manufacturers.
TTP fleet members deploy every on-road technology available, carefully considering duty cycle and range needs for each application.
We endorse an “all-of-the-above” set of clean freight technologies.
Why doesn’t EPA?
Daniel Gage is president of the The Transport Project. TTP is a national coalition of roughly 200 fleets, vehicle and engine manufacturers and dealers, servicers and suppliers, and fuel producers and providers dedicated to the decarbonization of North America’s transportation sector.
Through the increased use of gaseous motor fuels including renewable natural gas and hydrogen, the United States and Canada can help achieve ambitious climate goals and greatly improve air quality safely, reliably, and effectively without delay and without compromising existing commercial business operations.
Find out more at: transportproject.org.
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