Comments on Changes to Proposed Advanced Clean Truck Regulation

A coalition led by Earthjustice urges the California Air Resources Board to increase zero-emission (ZE) truck sales targets, arguing that initial proposals are insufficient to meet the state's 2045 carbon neutrality goals. Citing analysis from Lawrence Berkeley National Laboratory, the authors claim that without stronger mandates, carbon emissions from trucking would only drop by 18% by 2045. The letter proposes specific higher sales percentages for Class 7-8 tractors to meet drayage fleet goals by 2035 and calls for a 'work backwards' approach from 2040 fleet goals to eliminate internal combustion engine (ICE) vehicle sales for urban delivery by 2033. The coalition asserts that technological advancements, falling battery costs, and corporate commitments from entities like Amazon and UPS make these higher targets feasible, shifting the primary barriers from technical or economic to logistical planning.

• Analysis by Lawrence Berkeley National Laboratory (LBNL) indicates that CARB's initial proposal would leave approximately 1.2 million internal combustion engine (ICE) trucks on the road by 2045, resulting in a carbon emission reduction of only 18% over 25 years.
• To meet California's carbon neutrality goals, LBNL estimates that 21% of trucks on the road (roughly 400,000) must be zero-emissions by 2030.
• The coalition argues that Class 7-8 tractor sales mandates must be increased to achieve a 100% zero-emission drayage fleet by 2035, suggesting a ramp-up from 12% sales in 2024 to 80% by 2035 to meet port and railyard needs.
• To align with 2040 fleet goals, the authors suggest that sales mandates should be high enough to ensure no new ICE urban delivery trucks are sold after 2033, assuming a first-owner vehicle life of 7 years.
• Technological and economic feasibility is supported by a Navigant Research report predicting plug-in electric vehicles will comprise 12% of global commercial fleets by 2030, as well as battery pack prices trending toward $100/kWh before 2023.
• The primary remaining barriers to freight electrification are identified as logistical and policy-related—specifically a lack of mass-produced vehicle options and dealer networks—rather than technical or economic.

APA

Earthjustice (2020). Comments on Changes to Proposed Advanced Clean Truck Regulation. https://earthjustice.org/wp-content/uploads/2020-3-16_act-coalition-follow-up-letter.pdf

Chicago

Earthjustice. Comments on Changes to Proposed Advanced Clean Truck Regulation. 2020. https://earthjustice.org/wp-content/uploads/2020-3-16_act-coalition-follow-up-letter.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=Comments on Changes to Proposed Advanced Clean Truck Regulation |date=16 March 2020 |url=https://earthjustice.org/wp-content/uploads/2020-3-16_act-coalition-follow-up-letter.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2020comments, author = {{Earthjustice}}, title = {{Comments on Changes to Proposed Advanced Clean Truck Regulation}}, publisher = {Earthjustice}, year = {2020}, month = mar, url = {https://earthjustice.org/wp-content/uploads/2020-3-16_act-coalition-follow-up-letter.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }