2021-11-17_act_comments_final-59d11bb27e5813e9.pdf

The document argues that adopting the ACT rule is essential for New York to meet its climate goals under the Climate Leadership and Community Protection Act (CLCPA) and to address severe public health disparities caused by diesel emissions. It highlights that medium- and heavy-duty vehicles (MHDVs) are a primary source of greenhouse gases and toxic air pollutants, particularly in communities of color. The authors assert that zero-emission MHDVs are technically viable and cost-effective, projecting that the rule would add over 228,000 zero-emission vehicles by 2050 and generate $1.9 billion in net societal benefits. The statement recommends strengthening the rule by limiting early crediting to one year and lowering the fleet reporting threshold to five vehicles to better identify pollution hot spots and address labor misclassification.

• Medium- and heavy-duty vehicles (MHDVs) are a primary driver of emissions and health disparities in New York, with diesel emissions accounting for 21% of statewide greenhouse gas (GHG) emissions despite representing only 4% of registered vehicles.
• The adoption of the ACT rule is projected to significantly reduce air pollutants and improve public health, potentially avoiding 237 premature deaths and 231 hospitalizations by 2050.
• The ACT rule is deemed critical for New York to meet the binding emission limits of the Climate Leadership and Community Protection Act (CLCPA), as meeting 2050 targets requires an 86–97% reduction in transportation sector emissions.
• Zero-emission MHDVs are considered economically viable, with a projected net societal benefit of $1.9 billion by 2050 and estimated net fleet savings of $318 million over the same period.
• The document argues that the ACT rule will substantially increase the deployment of zero-emission vehicles, adding over 25,000 in 2030 and exceeding 228,000 by 2050.
• The authors recommend that the Department of Environmental Conservation (DEC) limit early crediting to Model Year 2024 and lower the fleet reporting threshold to five or more vehicles to improve data granularity and target environmental justice communities.

APA

Spector, R., & Disa, A. (n.d.). 2021-11-17_act_comments_final-59d11bb27e5813e9.pdf. Earthjustice. https://earthjustice.org/wp-content/uploads/2021-11-17_act_comments_final.pdf

Chicago

Spector, Rachel, and Alok Disa. 2021-11-17_act_comments_final-59d11bb27e5813e9.pdf. Earthjustice, n.d. https://earthjustice.org/wp-content/uploads/2021-11-17_act_comments_final.pdf.

Wikipedia

{{cite press release |last1=Spector |first1=Rachel |last2=Disa |first2=Alok |title=2021-11-17_act_comments_final-59d11bb27e5813e9.pdf |publisher=Earthjustice |url=https://earthjustice.org/wp-content/uploads/2021-11-17_act_comments_final.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{spectornd20211117actcommentsfinal59d11bb27e5813e9pdf, author = {Spector, Rachel and Disa, Alok}, title = {{2021-11-17\_act\_comments\_final-59d11bb27e5813e9.pdf}}, publisher = {Earthjustice}, url = {https://earthjustice.org/wp-content/uploads/2021-11-17_act_comments_final.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }