CALSTART Statement to the California Air Resources Board on the Low NOx Heavy-Duty Omnibus Regulation

August 27, 2020

  • Chair Nichols, members of the Board, thank you for this opportunity to provide comments. Meredith Alexander on behalf of CALSTART.
  • CALSTART with more than 250 member companies and agencies, is dedicated to the growth of the clean transportation industry, clean air for all, and stopping climate change.
  • We are asking the board to support the Proposed Low NOx Heavy-Duty Omnibus Regulation today because of how critical this issue is for addressing the state’s air quality needs. The data is clear that California cannot meet federal timelines for attaining health-based air quality standards without major actions such as this one.
  • Knowing that two major air basins are in extreme non-attainment, combined with the fact that more than 60 percent of transportation NOx emissions are from MHDVs, speaks to the necessity of these regulations. This segment’s impact on air quality is growing with increases in e-commerce.
  • At the same time, not all of our member companies agree with the proposed regulation and we know this measure will create challenges for certain manufacturers. However, given CALSTART’s mission to reduce air pollution AND GHGs while creating jobs, we have made the determination to support this proposal.
  • It is also relevant that Zero emission trucks will not achieve scale fast enough to have the necessary immediate impact on air quality in the desired timeframe.
  • Studies and engine tests from a few of our members, some of which CALSTART has been directly involved, support Staff’s assertion that these engine standards are achievable by 2027.
  • We acknowledge the challenges and potential unknown costs facing the industry to meet length of warranty provisions and to meet the emissions requirements all real-world operating conditions.
  • Given our multi-decade failure to meet health-based standards for millions of Californians; and the disproportionate burden of air pollution borne by disadvantaged communities; as well as the opportunity for innovative California-based companies to provide solutions, we support CARB Staff’s proposed Low Nox Regulation.