June 18, 2021. NGVAmerica submitted written comments to the New Jersey Department of Environmental Protection (DEP) in response to its proposal to adopt the Advanced Clean Trucks (ACT) Program. The proposal, based on recently adopted rules in California, would require that an increasing percentage of new medium- and heavy-duty trucks sales in the state are zero emission vehicles. Under the program, truck manufacturers earn needed credits by selling zero emission and near-zero emission trucks or acquiring credits from other manufacturers who do so.

In its letter to regulators, NGVAmerica writes, “NGVAmerica members support the ultimate goal of the Advanced Clean Trucks Rule – to decarbonize the medium- and heavy-duty transportation sector as quickly as possible while greatly reducing harmful criteria emissions that contribute to poor air quality and federal ambient air standards non-attainment. However, we respectfully disagree with the proposed program’s approach to achieving these objectives: relying on a sales mandate for vehicles that are largely not commercially available, affordable, or proven.”

A better approach would be to accelerate the introduction and sale of a variety of commercially available technologies that have a track record of delivering steep emission reductions. NGVAmerica noted the current problem is not the number of new trucks and cars being sold today, but the high negative emissions emitted by older, non-compliant medium- and heavy-duty trucks that remain on the road that are not impacted by the proposed new vehicle sales rule.

Rules adopted by California and proposed by New Jersey unfortunately do not accelerate the use of commercially available, ultra-low emission vehicles but instead focus on yet-to-be produced, unproven vehicle technology. By focusing only on tailpipe emissions to address climate change emissions and opting to mandate the most expensive technology, i.e., full electrification, the proposed rule prevents new, ultra-low emission natural gas trucks from qualifying under the program and contributing to cleaner air and lower emissions right away.

Currently available ultra-low NOx medium- and heavy-duty natural gas-powered trucks and buses perform at levels that are 95 percent below federal NOx standard and 98 percent below the federal PM standard. New natural gas ultra-low NOx engines operating on renewable natural gas – available today – also offer important reductions in greenhouse gas emissions in most cases providing carbon neutral or carbon negative emissions.

Reported data from the California Low Carbon Fuel Standard (LCFS) program demonstrates just how clean and low-carbon natural gas trucks truly are – the average carbon intensity of bio-CNG sold in California in 2020 was -5.85 g/MJ and in the fourth quarter of 2020 the average was -26.11 g/MJ. Under California’s rules, the same rules New Jersey has proposed adopting, these trucks do not qualify as zero emission vehicles and cannot earn credits as near-zero trucks.

An immediate solution for states to improve the lives of its citizens impacted by poor air quality is to accelerate the retirement of older, higher emitting vehicles from the roads. Taking older trucks off the road, adopting policies that reduce congestion in neighborhoods with exceedingly high pollution, increasing access to affordable, lower-polluting public transit, and implementing other similar measures, will provide more immediate relief and longer-lasting public health benefits than trying to force businesses and fleets to slowly incorporate costly, and unproven technology.

NGVAmerica continues its advocacy to promote the timely adoption of zero emission equivalent, carbon negative transportation solutions including RNG-fueled commercial trucks and buses.