Response to SCAQMD Staff Comments on Advanced Clean Fleets Regulatory Concepts

A coalition of environmental, health, and labor organizations urges the SCAQMD to reject natural gas trucks as a viable alternative to zero-emission vehicles (ZEVs) for heavy-duty fleets. The coalition argues that gas trucks do not provide sufficient air quality benefits, exacerbate climate change through methane leaks, and create stranded assets. They contend that battery electric trucks are already operationally suitable for most drayage and heavy-duty needs and offer a superior total cost of ownership (TCO) due to declining battery costs and lower maintenance requirements.

• The coalition asserts that natural gas trucks are not a necessary solution for meeting ozone attainment standards, as nitrogen oxide (NOx) reductions will primarily come from the retirement of pre-2010 diesel trucks under SB1 and new lower NOx standards for model year 2024 trucks.
• Natural gas vehicles may have negative climate impacts due to methane leakage from the gas delivery system, which can increase greenhouse gas emissions by 60% to 500% above official estimates.
• The coalition argues that battery electric trucks are operationally feasible for most drayage needs at the Ports of LA and Long Beach, noting that the majority of tours in a 2019 GPS study were less than 130 miles.
• Zero-emission heavy-duty trucks are becoming more economically competitive, with some analyses showing a 13% lower total cost of ownership (TCO) per mile for a Class 8 electric truck compared to diesel, resulting in a roughly 3-year payback.
• The document highlights a surge in manufacturer capacity for zero-emission trucks, noting that Volvo and Peterbilt began mass production of ZE tractors in 2021, and several European manufacturers have committed to phasing out diesel trucks by 2040.

APA

Earthjustice (2021). Response to SCAQMD Staff Comments on Advanced Clean Fleets Regulatory Concepts. https://earthjustice.org/wp-content/uploads/scaqmd_acf_technical_response_-_6-29-21.pdf

Chicago

Earthjustice. Response to SCAQMD Staff Comments on Advanced Clean Fleets Regulatory Concepts. 2021. https://earthjustice.org/wp-content/uploads/scaqmd_acf_technical_response_-_6-29-21.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=Response to SCAQMD Staff Comments on Advanced Clean Fleets Regulatory Concepts |date=29 June 2021 |url=https://earthjustice.org/wp-content/uploads/scaqmd_acf_technical_response_-_6-29-21.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2021response, author = {{Earthjustice}}, title = {{Response to SCAQMD Staff Comments on Advanced Clean Fleets Regulatory Concepts}}, publisher = {Earthjustice}, year = {2021}, month = jun, url = {https://earthjustice.org/wp-content/uploads/scaqmd_acf_technical_response_-_6-29-21.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }