NACS Urges the EPA to Adopt a Technology-Neutral Approach to Greenhouse Gas Standards

The Association wants better, more practical standards for heavy-duty trucks.

June 19, 2023

ALEXANDRIA, Va.—NACS, along with NATSO and SIGMA, is urging the Environmental Protection Agency (EPA) to revise its proposed greenhouse gas (GHG) standards for heavy-duty trucks and adopt a market-oriented, technology-neutral approach to transportation decarbonization.

Rather than adopting a single approach to emissions reductions, the organizations urged the EPA to harness the immediate decarbonization benefits of existing lower carbon options, including renewable diesel and biodiesel.

“The enormous practical and logistical challenges associated with electrifying trucks necessitate that the Agency not rely entirely on a prodigious pace of heavy-duty electrification to decarbonize the trucking sector,” the organizations wrote in public comments submitted to the EPA. “Instead of depending on one technology to act as a silver bullet, the Agency should adopt an agnostic approach to low-carbon technologies that can deliver substantial emissions savings in the heavy-duty sector without compromising the market’s ability to gravitate toward electrification as it becomes commercially viable and practical at scale.”

With the right alignment of policy incentives, transportation energy providers can facilitate a faster, more widespread and cost-effective transition to petroleum alternatives, including electricity, in the coming years.

Fuel retailers support the development of electric vehicle technologies and the associated refueling network but are concerned that the current state of heavy-duty electric vehicle charging technology renders the electrification timeline proposed under this rulemaking unachievable.

Renewable diesel and biodiesel represent the best opportunity for reducing carbon emissions from the commercial trucking sector for the foreseeable future. Establishing sensible tailpipe emissions, in conjunction with strong incentives for renewable liquid fuels, will encourage investments in currently scalable technologies that can reduce the carbon footprint of fuels that are in use today.

Policies that incorporate lifecycle GHG emissions which consider multiple technologies and ensure an accurate accounting of the lifecycle carbon intensity will facilitate continued investment in all decarbonization technologies, as opposed to only one. Under the EPA’s Proposed Rule, off-highway refueling locations will need dozens of fast chargers to support the requirement that 25% of new long-haul trucks must be electric by 2032. However, the charging capacity required at one large truck stop would be equivalent to the electric burden of a small town, according to a recent study from RMI. Fuel retailers remain unconvinced that electricity providers will be able to increase generation and transmission activity to service that load at scale within 10 years.

The Associations will continue to press EPA to revise its proposed rules to ensure they are feasible and practicable.

NACS offers helpful sustainability-related resources online under the Sustainability Playbook, which retailers can scour for information related to ESG, packaging, alternative fuels and energy saving opportunities.