4	With the effort that this administration

  5	has dedicated to increasing access to clean air, any

  6	limitation to these waiver requests would be a

  7	missed opportunity to bring crucial emission

  8	reductions to our nation's residents.	According to

  9	research from the American Lung Association, six out

 10	of the ten most polluting cities in the entire

 11	country are in California.

 12	For decades these harmful pollutants,

 13	especially those from the transportation sector,

 14	have burdened communities along highly utilized

 15	travel corridors which are overwhelmingly low income

 16	communities and communities of color.	California

 17	consumers and residents see firsthand the impacts of

 18	a changing climate in their everyday lives and in

 19	their pocketbooks.	And they understand the urgent

 20	need to address air quality issues in our

  1	most.	California consumers have continuously

  2	expressed support for California laborers for the

  3	state to go above and beyond emission standards set

  4	by the federal government.

  5	California and their residents have yet

  6	again expressed a desire to enable air quality

  7	policies that will bring direct benefits to the

  8	residents of this state, and the EPA should act

  9	swiftly in granting these waivers and allowing the

 10	state to act with the urgency that is needed to

 11	mitigate the impacts of emissions from

 12	transportation.	Thank you.

 13	THE MODERATOR:	Thank you for your

 14	comment.	The next speaker is Ameen Khan.	Please

 15	state your name and affiliation for the record.

 16	MR. KHAN:	Good morning, my name is

 17	Ameen Khan, regulatory affairs advocate for

 18	California Environmental Voters, formerly the

 19	California League of Conservation Voters.	On behalf

 20	of California Environmental Voters I would like to

  1	implement and enforce recently adopted emission

  2	standards for heavy-duty trucks, including the

  3	Advanced Clean Trucks and Low NOx Heavy-Duty Omnibus

  4	regulations.

  5	California Environmental Voters proudly

  6	represent over 120,000 members with the mission to

  7	protect and enhance the environment and the health

  8	of all California communities by electing

  9	environmental champions, advancing critical

 10	priorities, holding policy makers accountable, using

 11	political power to transform our political system

 12	and achieve climate justice.

 13	The transportation sector accounts for

 14	about 50 percent of California's greenhouse gas

 15	emissions, nearly 80 percent of nitrogen oxide

 16	pollution and 95 percent of toxic diesel emissions.

 17	Despite making up around just 7 percent of all

 18	vehicles in the state, heavy-duty trucks are the

 19	single largest source of smog forming nitrogen

 20	oxides and emit close to 40 percent of the state's

  1	essential tool for the state to fulfill this

  2	important objective.	In California the communities

  3	that are the most exposed and adversely impacted by

  4	the exposure to truck pollution are

  5	disproportionately low income communities of color.

  6	From the warehouses in the Inland Empire

  7	region to the busy ports of Long Beach in Oakland

  8	and all the way up and down the bread basket of the

              9	United States, the San Joaquin Valley, millions of

 10	Californians of color are harmed by increased

 11	exposure to truck pollution.	Due to the higher

 12	rates of respiratory illnesses and elevated cancer

 13	risks, some have called these communities diesel

 14	death zones.

 15	These overburdened residents and their

 16	communities have been disproportionately impacted

 17	and have suffered from the adverse impacts of truck

 18	pollution for too long.	Waivers could significantly

 19	improved air quality and public health in these

 20	historically underserved communities.	The waiver

  1	California Environmental Voters ask that

  2	the EPA expeditiously and unconditionally approve

  3	CARB's request for waivers so that all Californians

  4	can sooner enjoy and prosper from the environmental

  5	and health benefits that cleaner heavy-duty trucks

  6	provide.	Thank you for your consideration of these

  7	comments.

  8	THE MODERATOR:	Thank you for your

  9	comment.	The next speaker is Katherine Garcia.

 10	Please state your name and affiliation for the

 11	record.

 12	MS. GARCIA:	Good morning.	My name is

 13	Katherine Garcia, and I am the director of Sierra

 14	Club's Clean Transportation For All campaign.	Thank

 15	you for the opportunity to testify today.

 16	For far too long medium and heavy-duty

 17	vehicle manufacturers as a whole have sold dangerous

 18	diesel trucks with blatant disregard for the severe

 19	air pollution that harm so many communities and

 20	exacerbates the climate crisis.	Our Sierra Club

  1	public health and climate goals and to underscore

  2	what is at stake as the climate crisis intensifies,

               3	cleaning up air pollutants will become even more

  4	challenging.

  5	I have personally engaged with each of

  6	the California rules being discussed today and have

                7	attended the CARB hearings.	Prior to my current

  8	role I was the Sierra Club's policy lead for

  9	California's transportation regulations.	And over

 10	the past year in my national role, I've supported

 11	advocates from across the country urging policy

 12	makers to adopt these vital rules.

 13	I can attest that for each regulatory

 14	process, which has spared years in every case, at

 15	the heart of every testimony and every comment is

 16	the plea to deliver cleaner air for communities.

 17	Too many kids have suffered from respiratory illness

 18	due to truck and bus pollution.	And as a mom of a

 19	two-year old I am proud to join parents and

 20	caretakers across the country demanding that

  1	today would authorize rules that are designed to

  2	curb toxic air pollution and protect the health of

  3	all Californians.	Zero emission trucks and busses

  4	are a public health necessity.	The Advanced Clean

  5	Trucks rule will ensure that manufacturers deliver a

  6	robust supply of zero emission medium and heavy-duty

  7	vehicles in California and beyond.

  8	The airport shuttle rule offers many

  9	benefits, including reducing pollution in areas

 10	around airports which are often overburdened

 11	communities, improving the health of shuttle bus

 12	drivers, long-term financial savings for airports

 13	and shuttle operators and offering a model for

 14	airports throughout the country to transition to

 15	zero emission vehicles.

 16	In addition to zero emission vehicles,

 17	manufacturers must also slash nitrogen oxide,

 18	otherwise known as NOx from fossil fuel heavy-duty

 19	trucks.	The Heavy-Duty Omnibus rule ensures that

 20	truck makers curb NOx emissions and extend

  1	approve the three waivers in full to grant

  2	California the authority to create these lifesaving

  3	rules.	We must reduce deadly NOx pollution and

  4	accelerate the transmission to zero emission trucks

  5	and busses across the country.	Thank you for the

  6	opportunity to testify today.

  7	THE MODERATOR:	Thank you for your

  8	comment.	As a reminder if you're speaking today you

  9	will receive a notification on your screen that you

 10	are being promoted to a panelist shortly prior to

 11	your speaking time.	You must click to accept the

 12	invitation to be able to unmute when you're called

 13	to testify.	This will also allow you to turn on

 14	your camera which we encourage you to do.

 15	Speakers connected by telephone should

 16	unmute their phones by pressing *6 when called to

 17	testify.	Also, please remember to speak slowly and

 18	clearly so the court reporter and the interpreters

 19	can accurately capture your testimony.

 20	The next speaker is Alejandra

  1	policy and advocacy for Chispa National Program with

  2	the League of Conservation Voters.	I'm also based

  3	in Los Angeles and personally invested in this

  4	issue.	Chispa's mission is to build the power of

  5	low income communities of color across the country

  6	to achieve racial and environmental justice.

  7	The Chispa network strongly urges you,

  8	the EPA, to grant California's request for a waiver

  9	to adopt stringent state emission standards through

 10	its updated regulations.	Collectively and

 11	individually these standards address critical issues

 12	for California and will also have significant

 13	impacts beyond its borders.

 14	California is a known environmental

 15	justice leader, known for its commitment to

 16	addressing climate change and air pollution through

 17	its stringent emission standards.	California's

 18	regulations are in compliance with Clean Air Act

 19	Section 209, as they are more stringent.	They

 20	address the compelling need and are technically and

  1	more than 90 percent of Californians live in areas

  2	impacted by unhealthy levels of air pollution, and

  3	the state is meeting this public health crisis

  4	through its updated regulations.

  5	These rules, including the Advanced Clean

  6	Trucks rules, are a necessary step forward on a path

  7	to zero emissions future and will save countless

  8	lives, especially communities of color facing

  9	disproportionately high pollution levels.	Combined,

 10	these regulations will significantly reduce or

 11	eliminate greenhouse gas emissions as well as

 12	conventional air pollutants like nitrogen oxides.

 13	California is leading the transition from

 14	reliance on fossil fuels to safe and 100% electric

 15	energy.	This will allow communities bearing the

 16	brunt of climate change to seek urgent relief and

 17	will help us accelerate meeting our climate goals.

 18	California has six of the ten most

 19	polluted U.S. cities.	And while our state

 20	government has made tremendous gains in cleaning our

  1	waiver so California can address this public health

  2	emergency.

  3	These emissions standards in the

              4	aggregate are more productive of public health and

  5	welfare than current federal standards which do not

  6	go beyond the bear minimum.	Additionally vehicle

  7	manufacturers have the technology already to meet

  8	strong standards, and many of these analyses show

  9	that fully zero emission trucks would be cheaper to

 10	purchase and operate than diesel trucks within the

 11	time frame of these standards.

                  12	As a California native and immigrant and

 13	a woman of color who has been forced to experience

             14	environmental and racial racism every single day of

 15	my life, this issue is personal to me.	I grew up in

 16	Panorama City in the San Fernando Valley of

 17	Los Angeles, in a low income community of color

             18	surrounded by traffic corridors and freeways, dirty

 19	air and wildfires.

  1	of color.	It has a 93 percentile pollution burden.

  2	We live two blocks from the Van Nuys airport.	The

  3	Amtrak is 300 feet behind us and we're enclosed by

  4	the 405, 101 and 118 freeways, constantly surrounded

  5	by pollution sources.

  6	When you also consider systemic racism

  7	and other factors that have led to our lack of

  8	status and access to health care, we end up with

  9	disastrous consequences for our health and overall

 10	outcomes.	My father recently had open heart

 11	surgery.	My cousin and uncle struggle to breathe

 12	because of their asthma, and many more family

 13	members have been impacted by health issues

 14	exacerbated by dirty air.	And we are not the

 15	exception.

 16	As this is what it means to be a person

 17	of color living in California and in the U.S.,

 18	bearing the brunt of climate change and

 19	environmental racism.	As such the EPA must approve

  1	stringent standards.	Denying California's waiver

  2	would have disastrous consequences across the

  3	country.	It would set back federal and state

  4	pollution reduction goals considerably.	We urge

  5	you, the EPA, to approve California's waiver and go

  6	beyond the bear minimum to achieve the

  7	transformational change our communities need.

  8	Lastly, the EPA must approve California's

  9	waiver to realize the Biden Harris Administration's

 10	justice for new equity goals.	Climate justice is

 11	racial justice and our communities of color need

 12	urgent relief.	California's stringent emission

 13	standards are a necessary component of meeting those

 14	goals.	Thank you for the opportunity to provide

 15	public comment.

 16	THE MODERATOR:	Thank you for your

 17	comment.	The next speaker is Andy Su.	Please state

 18	your name and affiliation for the record.

 19	MR. SU:	Hello.	My name is Andy Su.	I'm

 20	speaking on behalf of the Environmental Defense

  1	full, lasting and durable effect of these lifesaving

  2	standards.	I'd like to focus my comments on the

  3	importance of Omnibus and the ACT rules which

  4	achieve deep reductions in pollution from new diesel

  5	vehicles and accelerate the transition to zero

  6	emission heavy-duty vehicles.

  7	Near term emission reductions are vital

  8	to mitigating the effects of climate change and to

  9	public health, especially the health of low income

 10	communities and communities of color

 11	disproportionately impacted by transportation air

 12	pollution.

 13	150 million people live in counties with

 14	unhealthy levels of ozone or particulate pollution,

 15	and many of the hardest hit communities are in

 16	California.	The South Coast and San Joaquin Valley

 17	are the only two areas in the nation designated as

 18	extreme nonattainment for federal health based ozone

 19	standards.	And the San Joaquin Valley has the

 20	highest fine particulate matter levels in the

  1	American Lung Association, people of color are more

  2	than three and a half times more likely to breathe

  3	the most polluted air.	The subsequent health

  4	impacts of diesel trucks and busses is devastating

  5	and follow broader trends of unequal burden.

  6	Studies have shown that communities near

  7	truck routes often experience elevated levels of NO2

  8	and black carbon which are associated with higher

  9	levels of cardiovascular events, asthma emergency

 10	room visits and hospitalizations as well as adverse

 11	pregnancy outcomes.	These studies highlight the

 12	importance of near term emissions reductions that

 13	will result from the Omnibus and ACT rules.

 14	Omnibus, fully phased in by 2031, is

 15	expected to reduce harmful NOx emissions in

 16	California by more than 23 times per day, the

 17	equivalent of taking 16 million light duty cars off

 18	the road in 2031.	The resulting emissions

 19	reductions will lead to 3,900 avoided premature

 20	deaths and 3,150 avoided hospitalizations statewide

               1	billion dollars over the next 20 years and create

  2	thousands of good new jobs by 2035.	A low NOx rule

  3	that offers robust protection is necessary

               4	complement to the Advanced Clean Trucks rule, as

               5	these regulations can offer important cumulative

               6	benefits.	For example, an ICCT report found that

  7	New York state emissions from medium and heavy-duty

  8	vehicles are expected to grow significantly leading

  9	up to 2050.

 10	While the ACT and low NOx rules

 11	independently can help reduce these emissions, the

 12	combination of ACT and Heavy-Duty Omnibus standards

 13	will deliver the greatest NOx benefits equal to 46

 14	percent below 2020 levels in 2050.	Already we've

 15	seen a significant expansion of zero emission model

 16	availability, a 625 percent increase since 2019, and

 17	this is likely driven in no small part by strong

 18	emission standards that catalyze the market.

 19	The increasing economies of scale that

 20	come from an expanded market means that an already

  1	consistent standards are necessary to ensure market

  2	certainty.

  3	These standards will continue to

  4	incentivize investment in clean zero emission

  5	technologies and help lead to economies of scale

  6	that will continue to bring down costs.	It is

  7	important that manufacturers lead in this transition

  8	to a zero emitting future and not litigate in a

  9	manner that stalls progress and innovation.

 10	Deploying clean and zero emitting heavy-duty

 11	vehicles is critical to reach our health and climate

 12	goals.

 13	These standards will protect human health

 14	and the environment for all people in all

 15	communities by reducing harmful diesel pollution and

 16	ensuring greater deployment of ZEVs.	Actions that

 17	will save money for truckers and fleets and help to

 18	support and grow jobs.	Thank you.

 19	THE MODERATOR:	Thank you for your

 20	comment.	We are now at the end of our morning

  1	please raise your hand?	If you're on your phone you

  2	can do this by clicking *9.	Okay.	I'm not seeing

  3	any raised hands.	Well then, Karl, could you please

  4	confirm that we're ready to take a short lunch

  5	break?

  6	MR. KARL SIMON:	Thanks, Tuana, I think

  7	we are going to take our lunch break and we'll give

  8	the details here as you see on the slide and I want

  9	to say thanks to all the panelists on block 3 for

 10	your very helpful testimony and again we look

 11	forward to seeing your supplemental or supportive

 12	written comments as well.	So we will see everybody

 13	back here at 12:45.	We'll start with block 4.

 14	Thank you.

 15

 16

 17

 18

 19

  1 	CERTIFICATE OF NOTARY PUBLIC - COURT REPORTER

  2

  3 	I do certify that the attached

  4 	proceedings were taken before me in the

  5 	above-entitled matter; that the proceedings

  6 	contained herein was by me reduced to writing by

  7 	means of stenography, and afterwards transcribed

  8 	upon a computer. 	The attached pages are a true and

  9 	complete transcript of the proceedings.

 10 	I do further certify that I am not

 11 	connected by blood or marriage with any of the

 12 	parties, their attorneys or agents, and that I am

 13 	not an employee of either of them, nor interested,

 14 	directly or indirectly, in the matter of

 15 	controversy.

 16 	IN WITNESS WHEREOF, I have hereunto set

 17 	my hand and affixed my notarial seal at West

 18 	Bloomfield, Michigan, County of Oakland, this 12th

 19 	day of July 2022.

                                        1

  2	UNITED STATES ENVIRONMENT PROTECTION AGENCY

  3	PUBLIC HEARING

  4	WEDNESDAY JUNE 29, 2022

  5	(Volume 2)

  6	Commencing at 12:45 p.m.

                                        7

                                        8

  9	For Consideration of Three Separate Waiver

 10	Requests from the California Air Resources

 11	Board (CARB) Regarding its Heavy-Duty

 12	Vehicle and Engine Emission Regulations

 13

 14

 15

 16

 17

 18

 19

 20

 21

 22

 23

 24

  1	INDEX OF SPEAKERS

  2	***	***	***

                                 3	SPEAKERS	PAGE

                                4	ATENAS MENA	145

                                 5	BETA LUGO	145

                             6	JIMMY O'DEA	145

                                7	WAYNE NATRI	148

                            8	JOHN ROBERTO MADRID	151

                              9	JASON QUARANTO	153

                             10	WILLIAM BECKETT	155

                             11	LEVI KAMOLNICK	157

                               12	AVI MERSKY	160

                                13	SAM APPEL	164

                             14	HAZEL CHANDLER	165

                             15	SHELLEY FRANCIS	168

                               16	JENNY GAENG	171

                               17	ERIC FEELEY	173

                             18	DAVID PORTUGAL	176

                         19	JORGE MORALES GUERRERO	179

                               20	NICK TORRES	182

                              21	ANJULI RAMOS	186

                            22	STEPHANIE SEARLE	189

                               23	RAY PINGLE	194

                              24	DONNA ALBERT	197                                           1	INDEX OF SPEAKERS CONTINUED

  2	***	***	***

                                 3	SPEAKER	PAGE

                               4	ALANA LANGDON	203

                              5	JESSICA MOERMAN	207

                              6	AIDAN GERONIMUS	211

                               7	JUDITH BORCZ	213

                              8	OSCAR HAUPTMAN	216

                            9	ELIZABETH HAUPTMAN	218

                             10	ANDREW HAUPTMAN	222

                              11	MIKE THOMPSON	223

                              12	NICOLE MARCOT	226

                               13	KELLY BLYNN	229

                             14	MOLLY GREENBERG	232

                              15	AISHA BALOGUN	235

                              16	CLARE ALFORD	237

                             17	VICTORIA PAYKAR	240

                               18	TOM JORDAN	243

                             19	VEENA DHARMARAJ	247

                              20	JOAN SCHILLER	249

                              21	MARVEN NORMAN	254

                            22	LINDSDY MENDELSON	257

                            23	BRIAN URBASZEWSKI	261

                              24	MORGAN FOLGER	266                                           1	INDEX OF SPEAKERS CONTINUED

  2	***	***	***

  3	SPEAKER	PAGE

  4	BRITT CARMON	272

  5	JAIMINI PAREKH	276

  6	JACK SYMINGTON	280

  7	GABRIELA MENDEZ	281

  8	ANGELIQUE ESPINOZA	283

  9	CERTIFICATE OF REPORTER	289

 10

 11

 12

 13

 14

 15

 16

 17

 18

 19

 20

 21

 22

 23

 24

  1	Virtual Zoom Hearing

  2	Wednesday, June 29, 2022

  3	12:45 p.m. EST

  4	THE MODERATOR:	Okay.	This is Jessica Mroz.

  5	If you are speaking today, please turn off

  6	your microphone.	It is nothing personal, we just want

  7	to make sure everyone has an equal opportunity to

  8	speak today.	And we sure have a lot of speakers to

              9	get through.	We will display the list of registered

 10	speakers arranged by panel so you know when it is your

 11	turn.

 12	If you are speaking today, you will receive a

 13	notification on your screen that you are being

 14	promoted to the role of panelist shortly prior to your

 15	speaking time.	You must click to accept that

 16	invitation to be able to unmute when you are called to

 17	testify.	This will also allow you to turn on your

 18	camera, which we encourage you to do if you feel

 19	comfortable doing so.

 20	Speakers connected by telephone should unmute

 21	their phones by pressing Star-6 when called to

 22	testify.

 23	When called upon, please state your name and

 24	any affiliation, and then begin your testimony.

  1	on Zoom so it's easier for us to find you, you can do

  2	that by clicking the participant button on the Zoom

  3	toolbar at the bottom of your screen.	Hover the mouse

  4	over your name and click on more, and a window will

  5	open allowing you to edit or correct how your name is

  6	displayed.	When done, click OK.

  7	Lastly, if you are having technical

  8	difficulties or are not registered to speak but would

  9	like to do so, those speakers will be accommodated

 10	tomorrow.	Please send an email to

 11<EMAIL_ADDRESS>  12	So is the EPA panel ready to begin?

 13	MR. DICKINSON:	Jessie, this is David

 14	Dickinson, yes, we are ready to begin. I believe Karl

 15	has joined us here as well.

 16	THE MODERATOR:	Great, I will pass the

 17	moderator duties over to my colleague Kayla Steinberg

 18	to get us started for the afternoon.

 19	THE MODERATOR:	Our next speaker will be

 20	testifying in Spanish.	So I will allow a moment for

 21	our interpreter to switch channels to translate the

 22	testimony into English for the panel.

 23	The next speaker will be Atenas Mena.

 24	Please state your name and your affiliation

  1	(Speaker was in Spanish. English channel was not operating)

  2	THE MODERATOR:	I believe our next two

  3	speakers will also be speaking in Spanish.

  4	The next speaker Ana Ramos.	I do not see

  5	your name on the speaker's list.	If you are here, can

  6	you please raise your hand?	If you are joining by

  7	phone you can do so by pressing Star-9.

  8	Okay.	I don't see you there.	We can move on

  9	to the Beto Lugo.	Please state your name and

 10	affiliation for the record.

 11	(Speaker was in Spanish. English Channel was not operating)

 12	THE MODERATOR:	Thank you for your comment.

 13	Our next speaker will be Jimmy O'Dea.	Please

 14	state your name and affiliation for the record.

 15	MR. O'DEA:	Good afternoon, my name is Jimmy

 16	O'Dea.	And I'm the Deputy Director of the Clean

 17	Trucks Initiative at CALSTART.	We are an

 18	industry-based organization with more than 300 members

 19	dedicated to the growth of the clean transportation

 20	industry.	My comments are informed by members that do

 21	not represent consensus across our membership.

 22	CALSTART urges EPA to grant all the Waivers

 23	being considered today without delay.	The goal to be

  1	protect public health and welfare.

  2	The decision before EPA is far narrower than

              3	when EPA adopts its own regulations.	Section 209(b)

  4	of the Clean Air Act, to source of California's

              5	authority to adopt the regulations being considered

  6	today requires adoptive standards to be consistent

  7	with Section 202(a)(2) of the Clean Air Act, which

  8	they are.

  9	Some would argue that Section 202(a) requires

 10	four-year lead time for California's Regulations.	It

 11	does not.	The Clean Air Act provides no specific

 12	period of required lead time for Regulations adopted

 13	by California.	Instead, Section 202 (a) which EPA has

 14	consistently applied to Waivers for over 50 years

 15	states that a California regulation shall take effect

 16	after a period that the Administrator finds necessary

 17	to permit the development and application of the

 18	requisite technology considering the complaints.	Such

 19	findings are well documented in the record developed

 20	by the California Air Resources Board.

 21	The Advanced Clean Truck Standards, or ACT,

 22	builds on progress made in the zero-emission and

 23	technology over the last several decades and the

  1	Today there are roughly 100 models of

  2	Zero-Emission medium- and heavy-duty vehicles

  3	available for purchase yet only 2,000 Zero-Emission

  4	trucks have been deployed in the last five years.	The

  5	ACT is necessary to accelerate sales of these

  6	vehicles.	This policy will not only reduce emissions,

  7	it will also provide significant savings for fleets.

  8	An estimated 5.9 billion in California alone due to

  9	lower fuel and maintenance costs.

 10	In the six states that have adopted ACT to

 11	date, we project roughly one million Zero-Emission

 12	Class 2b through 8 vehicles sold through 2035.

 13	Beginning at about 6 percent of all truck sales in

 14	2024 and increasing to about 60 percent of sales in

 15	2035.	For reference, there are about 26 million class

 16	2B through 8 vehicles on the road in the United States

 17	today.

 18	Despite the ACT acceleration to Zero-Emission

 19	vehicles, significant numbers of combustion engines

 20	will be continue to be sold into the future making the

 21	Heavy-Duty Omnibus Rule critical to public health.

 22	The Omnibus Rule will result in more than two times

 23	the reductions in NOx emissions as ACT through 2050.

  1	ACT.

                 2	Permission of the adoption of these policies

             3	in California involve rigorous public engagement over

  4	several years by stakeholders of all positions in both

  5	the ACT, and Heavy-Duty Omnibus Policies, public

  6	workshops began in November 2016.	I was there.

  7	Adoption of these policies by the California Air

  8	Resources Board occurred in the summer of 2020 and

  9	implementation will begin in Model Year 2024.

 10	We thank the EPA staff for the opportunity to

 11	provide these comments.	And we urge the administrator

 12	to grant all of the requested Waivers being considered

 13	today so there's no delay in the health, environmental

 14	and economic benefits of adopting these policies in

 15	California and other states.	Thank you.

 16	THE MODERATOR:	Thank you for your comment.

 17	Our next speaker will be Wayne Nastri.

 18	Please state your name and affiliation for the record.

 19	MR. NASTRI:	Good morning or good afternoon.

 20	My name is Wayne Nastri.	I'm the Executive Officer of

 21	the South Coast Air Quality Management District in

 22	Southern California.	We're requesting EPA's

 23	expeditious approval of all of the Waiver Requests

  1	approaching federal deadlines to attain air quality

  2	standards.	On-road heavy duty vehicles remain our

  3	largest source of smog forming emission and

  4	contributes to poor air quality to millions of our

  5	residents.

  6	Over a third of all goods in the nation come

  7	through our twin ports of Los Angeles and Long Beach.

  8	And heavy duty vehicles that are used to move these

  9	goods to our rail yards and warehouses and ultimately

 10	for distribution to the rest of the nation.

 11	These same vehicles serve our nation's supply

 12	chain travel through our local neighborhoods.	And

 13	these frontline environmental justice communities

 14	experience real health outcomes from exposure to air

 15	pollution from heavy duty vehicles, including higher

 16	asthma rates, cardiovascular disease, cancer risk,

 17	premature death and more.

 18	These communities need urgent action from the

 19	Federal government including through full granting of

 20	all Waiver Requests for California that EPA is

 21	considering right now.	Anything less will only

 22	further perpetuate the burdens that these communities

 23	have historically faced.	EPA has ample evidence

  1	in each regulation.	Many of the technologies are

              2	already operating commercially on the roads or well

  3	along the path of commercialization in the timeframes

  4	laid out in these rules.

  5	I say this with confidence because our agency

              6	has provided over 150 million in grant funding for

  7	these cleaner technologies over the past several

               8	years.	Both for the development and demonstration

  9	projects and for commercial deployments.

 10	In conclusion, because our region continues

 11	to face significant public health challenges from air

 12	pollution that exceeds Federal air quality standards

 13	we need EPA to take rapid action on heavy duty

 14	vehicles, both for these Waivers and for the upcoming

 15	EPA heavy duty vehicle Low NOx Rule.	South Coast has

 16	compelling and extraordinary needs for EPA to do its

 17	part and approve these Waiver Requests expeditiously

 18	and in whole.	We urge EPA to act quickly and approve

 19	this request.

 20	And I would just add, if EPA doesn't approve

 21	these requests, then EPA should adopt the proposed

 22	standards so that all can benefit.	Thank you.

 23	THE MODERATOR:	Thank you for your comment.

  1	being promoted to the role of panelist shortly before

  2	your speaking time.	You must click to accept that

  3	invitation in order to able to unmute when you are

  4	called to testify.	This will also allow you to turn

  5	on your camera which we encourage you to do.

  6	Speakers connected by telephone should unmute

  7	their phones by pressing Star-6 when called to

  8	testify.

  9	Also as a reminder, please speak slowly and

 10	clearly so the court reporter and interpreters can

 11	accurately capture your testimony.

 12	Our next speaker will Juan Roberto Madrid.

 13	Please state your name and affiliation for the record.

 14	MR. MADRID:	Yes.	Thank you.	My name is

 15	John Roberto Madrid.	I'm the GreenLatinos Clean

 16	Transportation and Energy Policy advocate for the

 17	State of Colorado.	GreenLatinos is a national

 18	nonprofit comunidad of Latino environmental and

 19	conservation champions fighting against climate change

 20	and environmental degradation that intensifies

 21	systemic social, health and economic injustices in our

 22	communities.	We use our cultural connections, shared

 23	resources and collective power to advocate for Latino

  1	Public Health Association, the oldest and largest

             2	nonprofit public health association of public health

  3	professionals in the state of Colorado.

  4	I'm here today because I'm concerned about

             5	medium- and heavy-duty trucks that represent not only

  6	a climate issue, but they are also a major public

  7	health problem.	Environmental justice communities

  8	suffer a disproportionate burden of pollution from

  9	medium- and heavy-duty trucks that often travel in and

 10	out of disproportionately impacted communities.

 11	We know that diesel emissions are responsible

 12	for dangerous levels of nitrous -- nitrogen oxide and

 13	fine particulate matter.	Fine particulate matter that

 14	increases the risk of heart disease, diabetes, asthma

 15	and respiratory disease.	A recent Health Effects

 16	Institute report released on January 26 of 2022, which

 17	is the result of a 16-year study reports a 6 to

 18	8 percent increase in mortality for ten micrograms per

 19	cubic meter increase in pm 2.5 exposure and the

 20	increases were higher among minority groups.

 21	Here in Metro Denver, we have seen this issue

 22	amplified and, in fact, Metro Denver area air quality

 23	was recently downgraded by EPA from serious

             1	communities that suffer the greatest impact in these

  2	so-called diesel death zones.

  3	Colorado is poised to adopt the California

  4	Advanced Clean Trucks Low NOx Heavy Duty Omnibus Rule

  5	as a part of our State's goals in reducing greenhouse

  6	gas emissions.	And we urge the EPA to approve

  7	California's Waive as this will allow Colorado to

  8	adopt the rule and address major air pollution sources

  9	in our state.	This is an environmental injustice and

 10	a health issue.	It is past the time that we put the

 11	health of Americans above profits for industries that

 12	seek to block these Waivers.

 13	Thank you for the opportunity to testify

 14	today and I urge EPA to fully grant California's

 15	Waiver for the Advanced Clean Trucks zero-emission

 16	Airport Shuttle and zero-emission-Emission Powertrain

 17	Certification Regulation for the Omnibus Low NOx

 18	Regulation and the Heavy Duty Emissions Warranty

 19	Regulation.	Thank you.

 20	THE MODERATOR:	Thank you for your comment.

 21	Our next speaker will be Jason Quaranto.	Please state

 22	your name and your affiliation for the court reporter.

  1	commercial vehicles headquartered in Honeoye, New

  2	York.	I want to thank you the Environmental

  3	Protection Agency for the opportunity to testify in

  4	support of the Advanced Clean Truck Rule Waiver the

                5	State of California has submitted.	At Hyzon, we

  6	believe the Advanced Clean Truck Rule is an important

               7	tool for the State as it seeks to meet its State

  8	Implementation Plan under the Clean Air Act.

                    9	California estimates that approximately

 10	34 percent of NOx emissions generated in the state

 11	comes from vehicles that will be impacted by the

 12	Advanced Clean Truck Rule.	This means more than

 13	one-third of the NOx emissions comes from about

 14	3 percent of all registered vehicles in California.

 15	This significant number generated by comparatively

 16	small number of vehicles shows the need for the

 17	accelerated deployment of zero-emission-Emission

 18	vehicles in the medium- and heavy-duty commercial

 19	space.

 20	Currently, over 15 million people live in

 21	8-hour ozone nonattainment areas in California.	They

 22	need viable options to reduce NOx and Volatile Organic

  1	pollutants.	The Advanced Clean Truck Rule coupled

  2	with the subsidy programs for commercial vehicle

  3	owners who choose Zero-Emissions options in

  4	California, provide a clear path to meaningful

  5	improvements in air quality for millions of

  6	Californians.

  7	There will be some who will argue that now is

  8	not the time, that the technology isn't ready yet, or

  9	that it is unfair to impose this burden on businesses.

 10	However, with the average price of diesel approaching

 11	$6.90 a gallon in California, the Karl Moyer and HVIP

 12	Subsidy Programs for commercial vehicle owners in the

 13	State, and the advances in hydrogen fuel cell and

 14	battery electric powertrains, there is a clear path

 15	forward for companies that want to meet the Advanced

 16	Clean Truck Rule.

 17	Again, I want to think the Environmental

 18	Protection Agency for the opportunity to testify and

 19	urge the swift approval of this Waiver Request.

 20	THE MODERATOR:	Thank you for your comments.

 21	Our next speaker is William Beckett.	Please state

 22	your name and affiliation for the record.

  1	faculty of Harvard Medical School.

  2	I am here today to speak in favor of giving

  3	the State of California Waivers under the Clean Air

  4	Act to enforce critical truck emission standards.	I

  5	say this as a Board Certified lung doctor who has

  6	spent many years both treating patients with lung

  7	diseases including many with asthma.	And also doing

  8	research on the health effects of air pollution

  9	including the effect of NOx and particles.

 10	Simply put, California has successfully

 11	reduced air pollution health effects for its citizens.

 12	But, California has further to go in protecting

 13	health.	We know, for example, from excellent research

 14	conducted in California, that children with asthma who

 15	live near roads with heavy truck traffic have worse

 16	asthma, lose more time from school, and need more

 17	asthma medication than children living farther away

 18	from truck traffic who have asthma.	Much more needs

 19	to be done to protect these vulnerable children.

 20	California has world class scientists guiding

 21	its pollution prevention programs through the

 22	California Air Resources Board.	And California has

              1	have been so successful that many other states have

              2	followed their lead.	EPA, by granting these Waivers

             3	to California, will make a big step in achieving its

              4	mission of protecting the public health.	Thank you.

                  5	THE MODERATOR:	Thank you for your comment.

                  6	Our next speaker is Levi Kamolnick.	Please

  7	state your name and affiliation for the record.

                   8	MR. KAMOLNICK:	My name is Levi Kamolnick,

               9	speaking on behalf of Ceres.	Ceres is a nonprofit

            10	organization transforming the economy to build a just

             11	and sustainable future to people and the planet.	We

            12	work with the most influential capital market leaders

 13	to solve the world's greatest sustainability

 14	challenges.	Our Ceres policy network and Ceres

            15	company network bring together large consumer brands

            16	working to reduce their carbon footprints and engage

 17	with policymakers in the interest of doing so.

                 18	Ceres is also the organizational founder of

 19	Climate Action 100+, an investor initiative working

 20	with 615 investors and $55 trillion in assets under

 21	management to ensure the largest emitters taking

            22	necessary action on climate as well as the corporate                                           1	We strongly urge the Environmental Protection

  2	Agency to grant California Full Waivers under the

  3	Clean Air Act for its Heavy-Duty Engine and Omnibus

             4	Regulation, and its Advanced Clean Truck Regulation.

  5	We believe these rules are necessary to address

  6	significant climate and public health concerns

  7	associated with the truck sector.	And we also promote

  8	a globally competitive U.S. trucking industry.

  9	Contrary to industry claims, there is in fact

 10	ample precedence for California to implement these

 11	Regulations under shorter time frames than those

 12	provided by the Clean Air Act for Federal Standards.

 13	Medium- and heavy-duty vehicles are among the largest

 14	greenhouse gas emissions sources in the transportation

 15	sector.	And their emissions are projected to

 16	materially increase in the years to come.

 17	Medium- and heavy-duty vehicles are also the

 18	largest source of nitrogen oxide or NOx emissions in

 19	the transportation sector and harmful concentrations

 20	of particulate matter, ozone and other potent toxins.

 21	Failure to grant California's Waiver will

 22	have devastating consequences for California and for

  1	as well as improve air quality for disadvantaged

  2	communities that have long borne the brunt of truck

  3	pollution.

                   4	A recent Ceres analysis demonstrated that

              5	although many vehicle classes are increasing their

  6	price competitiveness with their gasoline-powered

  7	counterparts, preserving the Advanced Clean Truck Rule

  8	in California and other states will drive economies of

  9	scale that will reduce costs and accelerate the

 10	necessary transition to electrification.	Given that

 11	it does not appear that a federal

 12	zero-emission-Emission vehicle mandate will be adopted

 13	in the near future, preserving California's Truck

 14	Standards is more important than ever to ensure the

 15	rapid electrification of this sector which in turn

 16	will provide significant cost savings for businesses

 17	in addition to enabling the U.S. to meet climate and

 18	air quality goals.

 19	In sum, Ceres strongly urges the

 20	Environmental Protection Agency to grant California's

 21	Request for Waiver which will play a significant role

 22	in reducing the climate, public health, equity and

  1	As a reminder, if you are speaking today, you

  2	will receive a notification on your screen that you

  3	are being promoted to the role of panelist shortly

  4	prior to your speaking time.	You must click to accept

  5	that invitation to be able unmute when you are called

  6	to testify.	This will also allow you to turn on your

  7	camera, which we encourage you to do.

  8	Speakers connected by telephone should unmute

  9	their phones by pressing Star-6 when called to

 10	testify.

 11	Also, as a reminder, please speak slowly and

 12	clearly so the court reporter and interpreters can

 13	accurately capture your testimony.

 14	Our next speaker will be Avi Mersky.	Please

 15	state your name and affiliation for the record.

 16	MR. MERSKY:	Thank you.	I am Avi Mersky,

 17	speaking on behalf of the American Council for an

 18	Energy-Efficient Economy.	We welcome the opportunity

 19	to testify today on EPA's consideration of

 20	California's Waiver Request and for many other states

 21	heavy-duty vehicle emission regulations.	While, for

 22	time's sake, our testimony will focus on the ACT and

  1	Rules for which California is seeking waivers are at

  2	least as stringent as the Federal Rules, whether

  3	California needs these rules to meet compelling and

  4	extraordinary conditions under the proposals put forth

  5	and standards that are technologically feasible.

  6	With regards to stringency, California's

  7	Rules under consideration clearly go above and beyond

  8	the Federal NOx and GHG emission programs.

  9	Regarding the need for these Rules, half of

 10	California's total population lives in counties that

 11	are noncompliant with the National Ambient Air Quality

 12	Standards.	Twenty percent in extreme noncompliance

 13	for at least one pollutant.	Heavy-duty vehicles

 14	represent a major source of GHG and NOx as well as

 15	other criteria air pollutant emissions.

 16	California is the first stop for a growing

 17	number of goods imported into the country that will be

 18	hauled by a GHG vehicle at least once if not once at

 19	the port, if not for the whole trip, not allowing

 20	California to address the problems arising from its

 21	unique place in the U.S. trade market will result in

 22	its citizens living with severe health conditions

  1	this is evidenced by official statements from

  2	manufacturers who have announced schedules for

  3	heavy-duty electric vehicle production.	Volvo has

  4	announced a target for of 50-percent heavy-duty

  5	vehicle electrification by 2030.	As has Scania.

  6	Other manufacturers have pledged similarly ambitious

  7	timelines.	Academic analysis suggests that similar

  8	electrification schedules are likely with NREL

  9	predicting 42 percent of electrification of heavy-duty

 10	vehicles by 2030.	These numbers or in or beyond the

 11	30 to 50 percent by 2030 of penetration rate by 2030

 12	that ACT requires.

 13	The Rules feasibility is further supported by

 14	the stringent and standardized rate that California

 15	maintains, which is comparable to EPA's own.	CARB has

 16	run cost benefit, environmental impact, and technical

 17	feasibility and market time analyses for each of these

 18	Rules followed by an extensive period for public

 19	comments and full revisions.

 20	These Waivers do not matter only to

 21	California.	California's ability to balance public

 22	health, environments, technical feasibility and a net

             1	state agencies have carried out their own regulatory

  2	review of the rule and decided to adopt it.	And three

  3	additional states are in the process of doing so.

               4	One additional state has decided that CARB's

  5	own reviewing process is sufficient enough evidence to

              6	adopt the ACT.	These states are looking at the risk

             7	of polluting heavy-duty vehicles to their communities

  8	and are taking these actions because they are

  9	administrations accountable to their citizens know

 10	that these rules are the best options that their

 11	states have to protect their constituent's health.

 12	ACEEE would like to once again thank the EPA

 13	for the opportunity to speak today.	If EPA has any

 14	questions please do not hesitate to contact us.

 15	THE MODERATOR:	Thank you for your comment.

 16	Our next speak will be Valencia Bednar, but I

 17	can't find you in the list of attendees.	Can you

 18	please raise your hand if you joined under a different

 19	name.	If you joined by phone, you can select Star-9

 20	to raise your hand.	Thank you.	I think you might not

 21	be here.

 22	So then we can move on to Marjaneh Moini.	I

  1	If you join later or trying to join now, we

  2	can try and get you later.

  3	Our next speaker will be Sam Appel.	Please

  4	state your name and affiliation for the record.

  5	MR. APPEL:	Good morning or good afternoon,

  6	east coast time.	My name is Sam Appel.	I'm the

  7	California State Manager for the BlueGreen Alliance.

  8	Thank you for the opportunity to comment.	BlueGreen

  9	Alliance in an alliance of ten national unions of

 10	large environmental organizations, working at the

 11	intersection of economic and environmental issues with

 12	relevance to working people across this country.

 13	The BGA coalition works on both National and

 14	State-based transportation policies, and has supported

 15	California as a national leader in advancing our

 16	National Clean Vehicle Agenda.	California has put

 17	forward nation and world leading EPA emissions

 18	standards Rules when the Federal government had been

 19	deadlocked by partisanship on this issue.	That

 20	mission must continue.

 21	The California Air Resources Board has

 22	engaged labor unions and working people to advanced

  1	California's leadership, the U.S. will inevitably fall

  2	even further behind on greenhouse gas emissions goals,

             3	pollution emissions and climate progress in the face

             4	of existential threats to our state, country and the

  5	world.	This is an outcome neither Californians,

  6	Americans nor anyone in the world can afford.

  7	We respectfully request that the

             8	Environmental Protection Agency grant California the

             9	Clean Air Waivers under consideration to continue to

 10	fulfill its critical mission to protect people and the

 11	planet.	Thank for your consideration.

 12	THE MODERATOR:	Thank you for your comment.

 13	Our next speaker is Jenny Gaeng.	However, I can not

 14	find you in the list of attendees so please raise your

 15	hand if you joined under a different name.	If you

 16	joined by phone, you can select Star-9 to raise your

 17	hand.

 18	Our next speaker will be Hazel Chandler.

 19	Please state your name and your affiliation for the

 20	record.

 21	MS. CHANDLER:	Hi.	I'm Hazel Chandler.	I am

 22	a field organizer for Moms Clear Air Force in Arizona.

  1	of air quality issues on my health and the health of

  2	the children in our state.	While I live in the

  3	neighboring state, the California regulations have

  4	significant impact on Arizona.	Many of the trucks on

  5	our roads are licensed in California.	Ozone pollution

  6	does not stop at the state lines.	I want to thank you

  7	this administration for acting swiftly on clean

  8	trucks, but I want to urge EPA to approve California's

  9	Waivers Request in full.

 10	We need clean air as soon as possible.	And

 11	California's authority under the Clean Air Act to set

 12	more stringent emission standards are crucial to

 13	cleaning the air throughout the Section 177 states and

 14	actually probably all of our country.

 15	Vehicle manufacturers have the technology to

 16	meet these goals.	And recent analysis showed that

 17	zero-emission-Emission trucks will be cleaner to

 18	purchase and operate than diesel trucks within the

 19	time frames of the standards.	The climate crisis is

 20	harming our families and our communities today.	And

 21	the medium- and heavy-duty vehicles are a major

 22	contributor to this pollution.	In fact, despite only

  1	the transportation sectors.

  2	Trucks are also a source of other major

  3	deadly air pollution -- excuse me -- uhm, this impacts

  4	our communities of color disproportionate

  5	disproportionately and many of our children, black and

  6	latino children, and low income communities are living

  7	in what's called the Diesel Death Zone.	I know that

  8	personally because I've done studies on asthma in our

  9	communities and we found those along with the

 10	corridors that have the most diesel truck emissions

 11	have much higher asthma rates, sometimes in the 20 and

 12	25 and 30 percent range than the rest of the city.

 13	The residents of Arizona, especially those

 14	living in Maricopa County have been plagued with

 15	health impacts, both climate change and air pollution.

 16	We consistently have been an F on the American Lung

 17	Association grades for air quality.	And we are the

 18	fifth worst on ozone and eleventh worth on particle

 19	pollution and eighth worst on annual particle

 20	pollution.

 21	The air we breathe is harming us.	But it is

 22	especially harming our children and our elderly.	Air

  1	tools to be -- to be used to fight back against

  2	dangerous air pollution and raising diesel prices and

  3	increase the cost of goods to continue inflation and

  4	wreck havoc on our family and business budgets.

  5	Please approve the Waiver Request without

  6	delay.	Thank you very much for the opportunity to

  7	testify.

  8	THE MODERATOR:	Thank you for your comment.

  9	Our next speaker is Shelley Francis.	Please state

 10	your name and affiliation for the record.

 11	MS. FRANCIS:	Good afternoon.	My name is

 12	Dr. Shelley Francis and I'm co-executive director of

 13	EVHybridNoire.	Thank you for the opportunity to

 14	testify this morning -- or this afternoon.

 15	As I said, I'm the co-founder and Executive

 16	Director of EVHybridNoire.	We're a membership-based

 17	national 501(c)(3) nonprofit with thousands of members

 18	across the United States as well as globally.	Our

 19	mission is to increase awareness of multi-motor

 20	electric vehicles and accelerate their adoption in a

 21	manner that all communities have access to this

 22	E-mobility.

  1	community.

  2	Today I'm here, first as a concerned citizen,

  3	and then second as a public health E-mobility expert.

  4	I want to thank the administration for making it a

              5	priority to create the strongest possible limits on

  6	heavy-duty vehicle pollution.	The standards, here in

              7	my state, and in the states and cities that we work

  8	in, will begin to provide much needed relief from the

  9	burden of diesel fumes and air pollution.

 10	Vehicle manufacturers have the technology to

 11	meet stronger standards but have failed or many have

 12	failed to act on their own without the guiding hand of

 13	the EPA.

 14	I am particularly concerned about

 15	transportation driven air pollution.	As a child, I

 16	was very active, loved to play outside with my

 17	friends, and play a variety of sports.	It was only a

 18	few years ago, however, that I began to use an inhaler

 19	and began experiencing respiratory issues.	I don't

 20	live next to transportation corridor.	I don't live

 21	next to a refinery.	I don't live next to a port.	But

 22	imagine if I did.	I have to now be careful when the

  1	is also quite personal for me.

  2	This Rule has set the standard for vehicles

  3	which will be on the road for decades to come.	And

  4	families in diesel death zones and environmental

  5	justice communities, whether they are in West Oakland,

  6	whether they are in West Harlem, cancer alley Houston,

  7	or even rural North Carolina, or they have suffered

  8	for far too long and, as a result, face increased risk

  9	for cardiovascular disease, lung disease, and lung

 10	cancer as well as other respiratory illnesses.

 11	Diesel emissions caused nearly 21,000 -- and

 12	I'll repeat that.	Diesel emissions cause nearly

 13	21,000 premature deaths each year and impact nearly

 14	135 million Americans, with the majority of these

 15	individuals belonging to what we refer to as BIPOC

 16	community or front line communities.	So echoing what

 17	many of my colleagues have said in their comments.	I

 18	like to refer to this as the public health crisis that

 19	not enough people are talking about.

 20	So in conclusion, once again, I want to

 21	strongly urge and encourage this administration to

 22	set -- to allow us to have the strongest standards

             1	need to reduce these deadly pollution by at least 95

              2	percent within the next five years and really fully

              3	realize positive health impacts of what 100 percent

  4	zero-emission-Emission vehicle fleets.

                  5	If the administration wants to make good on

  6	its bold climate goals, it will have to prioritize

              7	people and communities first; not industry demands.

  8	So thank you again for the opportunity to

  9	testify.

                 10	THE MODERATOR:	Thank you for your comment.

 11	Our next speaker Jenny Gaeng.	Can you state

 12	your name and affiliation for the record.	Remember to

 13	speak slowly and clearly so that the court reporter

 14	and interpreters can accurately capture your

 15	testimony.

 16	MS. GAENG:	Thank you very much.	My name is

 17	Jenny Gaeng, and I live in Denver, Colorado.	I'm the

 18	transportation manager for Conservation Colorado, a

 19	political advocacy group fighting for Colorado's land,

 20	air, water in communities.

 21	For the past year, I've working on our

 22	State's implementation of the Advanced Clean Trucks

  1	will allow us to adopt these Rules.

  2	This administration has made a commitment to

  3	environmental justice, and allowing the Clean Truck

              4	Rule is a simple way to follow-through.	Coloradoans

  5	do not just want these rules, we need them.	In our

  6	State, the urgency of the climate and air quality

  7	crises is felt through environment violence and utter

  8	devastation.	From unprecedented wildfires that

  9	destroy thousands of homes in the dead of winter to

 10	the daily lives of communities in freight corridors

 11	that live with elevated rates of asthma, respiratory

 12	illness, cardiovascular disease, cancer, premature

 13	death and increased likelihood of deaths from Covid

 14	19.

 15	In the Denver metro area, medium- and

 16	heavy-duty vehicles contribute 24.3 of on-road NOx

 17	emissions despite accounting for less than 2 percent

 18	of vehicle miles traveled.	These freight adjacent

 19	communities are overwhelmingly low income and

 20	populated by Latinx, Black, indigenous, and other

 21	people of color.	They are disproportionately impacted

 22	not only by transportation, but air pollution from the

                 1	Therefore, it comes as no surprise that this

  2	year the EPA downgraded the Denver area Ozone

             3	non-attainment status from serious to severe.	In the

             4	fight against air pollution, our lives are literally

             5	on the line.	Now, we ask you to allow us to take the

  6	steps required to protect ourselves and our

  7	communities.	Thank you.

                  8	THE MODERATOR:	Thank you for your comment.

                  9	Our next speaker is Eric Feeley.	State your

 10	name and affiliation for the record.

 11	MR. FEELEY:	Good afternoon.	My name is Eric

 12	Feeley.	I am testifying on behalf of the Oregon

 13	Department of Environmental Quality where I am an air

 14	quality planner.

 15	As you heard from other officials and others

 16	during testimony this morning, the suite of California

 17	heavy-duty standards that we're discussing, all of the

 18	Operable Clean Air Act Waiver criteria.	Therefore,

 19	EPA should approve these Waiver Requests without

 20	delay.

 21	After many years of effort on their Low NOx

 22	Omnibus Regulation, California has demonstrated its

  1	90 percent reduction in NOx emissions for Engine Model

  2	Year 2027.	In addition, California's Advanced Clean

  3	Truck Rule is also feasible and puts us on a path to a

  4	zero-emission future that's clearly needed.

  5	Now why is it important for Oregon that EPA

  6	grants California's Waiver Requests.	Well, the

  7	significant reduction in emissions that will be

  8	realized with these Rules is necessary for communities

  9	in Oregon that continue to face a disproportionate

 10	impact for diesel emissions within our state.

 11	On-the-road diesel engines have a significant impact

 12	on neighborhoods close to warehouses, ports, rail

 13	yards, construction activity and major roadways.

 14	These neighborhoods are often where larger percentages

 15	of blacks, indigenous, and people of color live due to

 16	economic, social and historical factors.

 17	EPA is aware of these disproportionate

 18	impacts and should recognize these communities need

 19	the strongest possible standards to reduce their

 20	outside pollution burden.

 21	Now, over the years, Oregon has had

 22	difficulty in reducing emissions from the medium- and

              1	vehicle emission standards possible.	In Oregon, we

              2	have seen the decade-long downward trend of ambient

             3	ozone concentrations stabilized despite our status as

  4	a Section 177 state and our adoption of several of

  5	California's Rules including those we're talking about

              6	today.	It remains likely that we will see increases

  7	in ozone concentrations due to ongoing climate warming

              8	and increased interstate transportation.	Here there

  9	is a strong likelihood we will see a reduction for the

 10	national ambient air quality standard for ozone in the

 11	short term and Oregon would be at a greater risk of

 12	losing its attainment status in several communities

 13	should EPA deny these Waivers.

 14	Oregon has been working hard to address these

 15	pollutions.	In 2019, Oregon adopted the second

 16	strongest diesel regulation in the nation and will

 17	begin phasing out older model medium- and heavy-duty

 18	vehicle powered trucks in the Portland metro region

 19	starting next year.

 20	However, the effort to address pollution from

 21	legacy diesel engines must be paired with strong, new

 22	vehicle standards to be most effective.	California

  1	Finally, last August President Biden directed

  2	EPA to coordinate with California and other states

  3	that are leading the way in reducing pollution from

  4	the heavy-duty on-road sector.	For all these reasons

  5	described, we urge EPA to grant these Waiver Requests

  6	and recognize the enormous amount of effort, research,

  7	and public outreach necessary to adopt these Rules as

  8	well as lasting benefits that they will have on many

  9	of our communities.	Thank you for your attention.

 10	THE MODERATOR:	Thank you for your comment.

 11	Our next speaker will be David Portugal.

 12	State your name and affiliation for the record.

 13	MR. PORTUGAL:	Good morning.	My name is

 14	David Portugal.	I'm a Community organizer for Chispa,

 15	Arizona.	And has been stated several times today, air

 16	pollution is the leading environmental cause of

 17	disease and death, especially people of color who are

 18	disproportionately more likely to breathe hazardous

 19	air and suffer from more health issues as a

 20	consequence.

 21	I was born and raised in South Central Los

 22	Angeles and can speak firsthand of the health

             1	symptoms but my ability to enjoy playing outside.	It

             2	affected my education and impacted my mental health.

  3	No child should have to experience the panic of not

  4	being able to breathe.

                  5	Because the government played a significant

  6	role in creating these conditions because of practices

  7	with redlining, it has a moral obligation to remedy

              8	these injustices.	I do not claim to have a complete

  9	understanding of the predicted economic impact of

 10	stricter regulation.	What I do know, economic growth

 11	in this country has, and specifically Los Angeles, has

 12	been subsidized by the health of black and brown

 13	families nor generations.

 14	With rising inflation, every dollar counts

 15	for working class families.	Transitioning to electric

 16	heavy-duty and medium trucks and buses would save us

 17	$485 billion in health and environmental costs.	It is

 18	not only in the best health interests of our

 19	communities, but also the economic interests for us to

 20	transition to electric vehicles.	California's request

 21	for Waiver to adopt its Advanced Clean Trucks meets

 22	the clean air requirements of the Clean Air Act.

  1	step towards the administration's justice for the

  2	initiative.

                  3	The climate crisis is just that:	A crisis,

  4	due to generations of inaction and doing the bare

             5	minimum.	I would like to be able to tell my children

  6	that we did more than the bare minimum in trying to

  7	combat the realties of a climate crisis.

                 8	The EPA has the power to approve this Waiver

  9	as it has done in the past and clean up our air saving

 10	thousands of lives.	I implore you to approve this

 11	Waiver.	And thank you for the opportunity to comment.

 12	THE MODERATOR:	Thank you for your comment.

 13	At this time we have no more scheduled speakers during

 14	this block.	If there is anyone scheduled on this

 15	block from an earlier panel that was unable to speak,

 16	raise your hand or dial 9, Star-9, if you have joined

 17	us by phone.

 18	In the meantime, just a reminder that if you

 19	are speaking today, you will receive a notification on

 20	your screen that you are being promoted to the role of

 21	panelist shortly prior to your speaking time.	You

 22	must click to accept that invitation to unmute when

  1	their phones by pressing Star-6 when called to

  2	testify.	We also ask that you speak slowly and

  3	clearly so that the court reporter and interpreters

  4	can accurately capture your testimony.

  5	I don't see any hands raised.	So I am going

  6	to move on to the next speaker block and my colleague

  7	Jessie Mroz will moderate that.

  8	THE MODERATOR:	Our next speaker will be

  9	Jorge Morales Guerrero.	State your name and

 10	affiliation for the record.

 11	MR. GUERRERO:	Hello, everyone.	My name is

 12	Jorge Morales Guerrero.	I am here as a community

 13	member with Chispa Arizona to represent the Latinx

 14	community.

 15	As a member of the Latinx community, I am

 16	aware of the inequalities that we face as minorities

 17	living in the U.S.	For example, people of color are

 18	over 60 percent more likely to breathe in unhealthy

 19	air than white people.

 20	The government has played a significant role

 21	in creating this harmful conditions of racist

 22	practices like redlining as have been said before.

  1	for initiatives and policies that secure a better air

  2	quality for me and my loved ones.	The EPA has the

  3	power to set Zero-Emissions Clean Trucks Rule that

  4	would clean up our air.	By transitioning to electric

              5	trucks and buses, we could we move life-threatening

  6	pollution from our communities.

  7	In this hearing I would like to point out

              8	many things.	One, zero-emission-Emission trucks and

  9	buses are crucial to reducing harmful emissions

 10	stemming back to my community disproportionately.

 11	Two, EPA must adopt strick and aggressive standards to

 12	relieve communities of color who are facing harmful

 13	pollution levels.	And three, Zero-Emission trucks and

 14	buses will help working class families in our economy.

 15	To take full action on air means to protect our health

 16	and safety.

 17	Now, I will explain each of these points in

 18	detail.	First, Zero-Emission trucks and buses are the

 19	best way to reduce harmful emissions that impact our

 20	health and is disproportionately affecting communities

 21	of color.	This transportation sector is the largest

 22	contributor to pollution and large trucks and buses

  1	pollution in our communities.

  2	Transportation pollution not only worsens the

  3	effects of planet change -- of climate change leading

  4	to more intensive wildfires, droughts, hurricanes, et

  5	cetera.	But it also harms our health in quality of

  6	life.	This is important for the health of our

  7	community and future generations.

  8	Second, the EPA must adopt the strictest

  9	clean truck standards to provide relief for

 10	communities of color facing harmful pollution levels.

 11	Air pollution is the leading environmental cause of

 12	disease and death especially for people of color who

 13	are more disproportionately more likely to breathe

 14	outside air and suffer from health issues as a

 15	consequence.

 16	Low income and communities of color are most

 17	impacted by air pollution.	With every breath we take,

 18	children and families of color are getting sicker in

 19	these neighborhoods.	Transitioning to trucks and

 20	buses with zero-emissions will address centuries of

 21	environmental racism.	The EPA must go beyond the bare

 22	minimum to achieve the transformational change our

  1	parties and their quality of life and will endanger

  2	the futures of our children.

  3	Third, the zero-emission-Emission trucks and

  4	buses will help working class families and our

  5	economy.	Since everything right now is getting more

  6	expensive, every dollar counts for working class

  7	families.	Transitioning to zero-emission-Emission

  8	heavy-duty trucks and medium trucks and buses can save

  9	billions of dollars in health and environment costs.

 10	This is not only in the best health interest of our

 11	communities, but also it has an economic impact for us

 12	and -- for us all.	This is a call on the EPA to pass

 13	this Rule.	Thank you very much.

 14	THE MODERATOR:	Thank you for your comment.

 15	Our next speaker will be Nick Torres.	Please

 16	state your name and affiliation for the record.

 17	MR. TORRES:	Good afternoon.	I am Nick

 18	Torres, Advocacy Director for the American Lung

 19	Association in Colorado, Utah and Wyoming.	And I

 20	appreciate the opportunity to offer comments and

 21	strong support of the U.S. Environmental Protection

 22	Agency granting California's Cleaner Truck Waivers

  1	granted over five decades ago, California has adopted

  2	policies to protect its residents from harmful air

  3	pollution.	Cutting emissions from trucking and other

  4	heavy-duty vehicles is vital to improving public

  5	health, reducing health disparities and reducing

  6	climate pollutants from the trucking industry.	These

  7	steps have resonated beyond California, as you heard

  8	today from many other states, and these policies reach

  9	residents throughout the country including in my home

 10	state of Colorado, who are able to opt in to these

 11	programs.

 12	So I urge the EPA to grant these Waivers

 13	immediately so that California and other states can

 14	move forward with these life-saving Rules.	These

 15	policies carry far-reaching effects in terms of

 16	environmental justice, reducing pollution, and

 17	protecting the health of many vulnerable communities.

 18	The trucking sector is the major source of

 19	regional air pollution that threatens health despite

 20	trucks making up a small percentage of on-road vehicle

 21	population.	According to the American Lung

 22	Association State of the Air 2022 report, 137 million

  1	community impacted by unhealthy air.	So opting in to

  2	California's programs will help us to ensure that

  3	these communities are no longer disproportionately

  4	burdened with emissions from the trucking sector.

  5	The Lung Association's State of the Air

  6	Report further notes that a person of color in the

  7	United States is 61 percent more likely to live in a

  8	community with failing air pollution and over three

  9	times more likely to live in a community with the

 10	worst level of air quality.

 11	The EPA's own data outlined in the

 12	Transportation Pollution and Environmental Justice

 13	Fact Sheet shows that 72 million Americans live in --

 14	near major trucking routes and those people tend to be

 15	lower income and people of color.

 16	California's Waivers are crucial for our

 17	nationwide transition to zero-emission-Emission

 18	transportation and to realize the significant health

 19	benefits that could come from the extension of

 20	zero-emission-Emission technologies.

 21	We strongly support EPA approving these

 22	Waivers to ensure progress is made to achieving these

  1	enjoy the benefits of cleaner engines and

              2	zero-emission-Emission technologies.	Colorado faces

  3	significant ozone pollution burdens and needs to take

  4	more actions to achieve clean air for all of our

  5	residents.

  6	The Lung Association estimates that Colorado

  7	could experience $9.5 billion in health benefits

  8	through the shift to zero-emission-Emission

  9	technologies and we are committed to pushing Colorado

 10	to act on these Rules so all Coloradoans, especially

 11	our most vulnerable residents are breathing cleaner

 12	air.

 13	Now I would like to speak personally as a new

 14	father.	Having my son has giving me renewed purpose

 15	to make sure his generation and all those who follow

 16	can have healthy air to breathe.	As new parents, my

 17	wife and I sometimes abscess over our son's

 18	milestones.	Is his neck strong enough, why isn't he

 19	rolling over more, and sometimes we just have to check

 20	to make sure he's still breathing at night, you know.

 21	We're obsessive.

 22	I think about every breath that he inhales is

  1	respiratory immune systems.	I will never forget, of

  2	course when he was born, but he was born just days

  3	before the massive Marshall fire, a wildfire in

  4	Colorado that affected our community.	And we know

  5	that these extreme wildfires and climate events will

  6	continue to happen unless we take decisive action.

  7	The transition to zero-emission-Emission

  8	transportation is such a critical step in meeting

  9	Clean Air and Climate Standards for future

 10	generations.	Granting California these Waivers for

 11	cleaner trucks and heavy-duty vehicles will carry

 12	far-reaching public health benefits, particularly for

 13	the most vulnerable among us.

 14	And so I would urge EPA to grant these

 15	Waivers without delay.	Thank you.

 16	THE MODERATOR:	Thank you for your comment.

 17	Our next speak will be Anjuli Ramos.	State

 18	your name and affiliation.

 19	MS. RAMOS:	I am Anjuli Ramos.	I am the New

 20	Jersey State Director for the Sierra Club.	Thank you

 21	for the opportunity to testify today.	I am going to

 22	assume you can all hear me.

  1	and urge the EPA to approve California's Waiver

  2	Request in full allowing the state to create the

  3	strongest possible limits on heavy-duty vehicle

              4	pollution and Rules to accelerate the transition to

  5	zero-emission vehicles.

  6	We need to clean the air as soon as possible

  7	and California's authority under the Clean Air Act to

             8	set more stringent emission standards are crucial to

              9	cleaning the air throughout all Section 177 states.

 10	Vehicle manufacturers have the technology to meet the

 11	goals of California's Rules and many recent analyses

 12	have shown that fully zero-emission-Emission trucks

 13	will be cheaper to purchase and operate than diesel

 14	trucks within the timeframe of these standards.

 15	In New Jersey, we are one of the 177 states.

 16	We adopted this past December the Advanced Clean

 17	Trucks Rule.	And with the states that have adopted it

 18	already and the ones that are considering to adopt

 19	soon, it makes up more than 20 percent of the national

 20	fleet of medium- and heavy-duty trucks.	That is huge

 21	for our country's air quality.

 22	The EPA's potential denial of California's

             1	our air is a necessary step in addressing the effects

             2	of environmental racism and providing relief to front

  3	line communities in bright corridors.

  4	Giving states that option to adopt the

             5	earliest and strongest possible clean electric truck

  6	standards is necessary to fight environment racism and

  7	provide relief to these corridor communities as I

  8	mentioned earlier.	Truck companies are already

              9	investing in this technology.	Pilot programs across

 10	the country have proven that electric trucks and

 11	cleaner diesel are ready for the marketplace.	Fleets

 12	are already putting in orders.	There's no reason to

 13	delay the elimination of these life-saving cleaner

 14	truck technologies.

 15	States have a responsibility to protect their

 16	citizens.	Clean truck standards are a major tool used

 17	to fight back against dangerous air pollution and

 18	rising diesel prices that increase the cost of goods,

 19	contribute to inflation, and wreck family and business

 20	budgets.

 21	To finish my statement, I just want to say

 22	that for New Jersey, specifically, our biggest and

  1	corridor, that's the I-95 corridor which is where you

  2	get the most or the highest diesel emissions in our

  3	state.	And that's very obvious.

  4	So this is very important, obviously for New

  5	Jersey, not just for New Jersey, but the entire

  6	country.	So thank you for the time and the

  7	opportunity to testify.

                  8	THE MODERATOR:	Thank you for your comment.

                  9	Our next speaker is Amy Goldsmith, but I do

 10	not see you on the list of attendees.	If you can

 11	raise your right-hand via the hand raise function at

 12	the bottom of your screen.	If you joined via a

 13	different name, I don't see any callers on the line.

 14	But if you have called in and it is just not showing

 15	up on the phone, you just need to dial Star-6 to raise

 16	your hand.

 17	I am not seeing any hand raises.	We will

 18	move on to our next speaker, which will be Stephanie

 19	Searle.	Please state name and affiliation for the

 20	record.

 21	MS. SEARLE:	Thank you.	I'm Stephanie

 22	Searle, the U.S. Regional Directer at the

  1	clean transportation policies.	We appreciate the

  2	opportunity to provide input to EPA on the subject of

  3	California's Waiver Request.

  4	The ICCT strongly supports California's

  5	Waiver Request for the Advanced Clean Trucks and

  6	Omnibus Low NOx Regulations.	We believe that

  7	compliance with these regulations, including in the

  8	early years, is technologically feasible and cost

  9	effective.	The Stage 3 SWRI test programs sponsored

 10	by the California Air Resources Board and EPA

 11	demonstrate that the NOx Standards can be met with

 12	available technology using optimized SCR

 13	after-treatment and cylinder deactivation.	SWRI has

 14	also shown that closing the crank case and thus

 15	reducing NOx from that source presents an additional,

 16	inexpensive option for reducing NOx and thus

 17	increasing the compliance margin for manufacturers.

 18	Additionally, there's flexibility engine

 19	aging.	Because of the increased durability

 20	requirements, Class 8 heavy-duty diesel vehicles will

 21	have two standards starting in Model Year 2027.	One

 22	for 435,000 miles, the current useful life.	And the

  1	test technologies that can be used to simultaneously

  2	achieve lower NOx emissions and reduce CO2 and fuel

  3	consumptions.

  4	For example, the Eaton Corp. development of a

  5	48-volt electric heater to increase catalyst inlet

  6	temperature at low loads, or the opposed piston diesel

  7	engine being developed by Achates Power in San Diego.

  8	Thus, there are sufficient options available in the

  9	near term for manufacturers to meet California's

 10	Omnibus Low NOx Regulation.

 11	We find that the costs to manufacturers of

 12	complying with the Low NOx regulation is reasonable.

 13	ICCT has estimated costs as low as $2,200 for a 12- to

 14	13-liter engine.	While EPA estimated $3,200 to $3,900

 15	and CARB 6,000 of $6,700 compared to, for example, an

 16	MSRP of around $168,000 for a leading Model Year 2022,

 17	Class 8 tractor-trailer, the Freightliner Cascadia.

 18	We find that higher cost estimates for the Engine

 19	Manufacturers Association, EMA, and the National

 20	Renewable Energy Laboratory, are inaccurate due to

 21	their overestimation of indirect costs.

  1	medium-duty delivery, drayage, shuttle bus, school

  2	bus, transit bus, refuse truck, and medium-duty

             3	delivery truck categories, battery-electric vehicles

  4	have all reached a technological readiness level of 9

  5	out of 9.

  6	In 2020, Zero-Emission transit buses, school

  7	buses, and coach buses were available from

  8	manufacturers representing 90 to 100 percent of these

  9	markets in the U.S Battery Electric Class -- in the

 10	U.S.	Battery Electric Class 6-8 refuse trucks are

 11	available from PACCAR, Volvo Group through their MACK

 12	brand, BYD and Lion Electric.

 13	For Class 7-8 tractor trucks, three of the

 14	four major manufacturers have announced plans for

 15	Zero-Emission products.	A number of studies,

 16	including our own research, have found that heavy-duty

 17	vehicles are expected to reach total cost of ownership

 18	parity between 2025 for short-distance urban trucks;

 19	and 2030 nor all trucks without incentives.

 20	Based on the evidence, we believe that these

 21	regulations are unlikely to result in significant

  1	California has a clear need to accelerate the

  2	reduction of harmful emissions from heavy-duty

  3	vehicles given the importance of improving air quality

  4	in the state.	Diesel vehicles are the largest

  5	contributor to health impacts from transportation

  6	related air pollution nationally, responsible for more

  7	than 9,000 premature deaths in 2015.	And these

  8	impacts disproportionately affect disadvantaged

  9	communities.

 10	Previous ICCT research has shown that

 11	achieving a 90-percent NOx reduction for Model Year

 12	2027 and later diesel engines could avoid more than

 13	one trillion dollars nationally in air pollution

 14	related health damages cumulatively from 2027 to 2050.

 15	The benefit of California's Regulation will outweigh

 16	the costs.	For example, EPA estimated a

 17	benefit-to-cost ratio of 5.3 for option one in its

 18	current proposed NOx Rule, which is similar to

 19	California's with a 3-year lag.

 20	More detail on the specific findings I have

 21	covered can be found in ICCT's public comment to EPA's

  1	the court reporter and interpreters can accurately

  2	capture your testimony.	If you are not able to

             3	complete your written remarks speaking slowly within

             4	the five minutes that you are allowed for testimony,

  5	we're happy to accept additional comments in the three

  6	dockets that are listed on the screen, which apply to

  7	these Waiver Requests.

  8	All right.	Our next speaker will be Ray

  9	Pingle.	Please state your name and affiliation for

 10	the record.

 11	MR. PINGLE:	Good afternoon, my name is Ray

 12	Pingle and I'm with Sierra Club California.

 13	We strongly recommend that the EPA fully and

 14	immediately grant the Waiver Requests in the approval

 15	and especially the Advanced Clean Trucks,

 16	zero-emission-Emission Airport Shuttle and Omnibus Low

 17	NOx regulations.

 18	For the past fours year, I've been an active

 19	participant in a large coalition of dozens of

 20	environmental justice, labor, health, clean air and

 21	environmental NGOs advocating for strong and effective

  1	approval of these CARB regulations.	The shear volume,

  2	diversity, passion, and technical expertise that's

  3	coalition's NGO representatives and its thousands of

  4	members have shown in supporting these rules in the

  5	CARB rule-making processes has been extraordinary.

  6	This is evidenced by participants and contributions at

  7	CARB workshops, meetings with CARB staff and board

  8	members, submission of comments to staff and the CARB

  9	board and the public testimony at CARB board meetings.

 10	For example, nearly 50 percent of the

 11	individuals providing oral testimony at a CARB board

 12	meeting on the ACT rule were our coalition members and

 13	affiliates.	The point is, that there is broad and

 14	strong support for these Rules in the greater

 15	statewide California community.	With these Rules

 16	having been highly vetted over years in a rigorous and

 17	a very participative stakeholder process.

 18	These Rules help fulfill the promises of

 19	California regulators and senior officials have made

 20	over the years to especially burdened front line

 21	communities to begin greatly mitigating toxic

  1	with ensuring that states comply with federal

              2	regulations to clean the air.	How could it require

  3	California to achieve attainment on healthy fines for

              4	failure on one hand, and then potentially take away

  5	the means to achieve attainment were it to disapprove

  6	these Waivers on the other.	It would make no sense at

  7	all.

                  8	The health, economic and climate mitigation

  9	benefits of these Rules are enormous.	Yet many of

 10	these benefits outline the documents from CARB

 11	including the ISOR and SRIA documents.	Not the least

 12	of these benefits are to the fleet and truck owners

 13	and operators themselves.	These include savings that

 14	would realize the positive total cost of ownership,

 15	lower fuel and maintenance costs, more reliable

 16	vehicles and happier drivers.

 17	Our economy will also ultimately benefit from

 18	lower goods transportation costs.	But failure of the

 19	EPA to approve these Waivers could be catastrophic and

 20	a dereliction of duty.	This approval would create

 21	chaos for CARB, California rulemakers, stakeholders,

  1	currently-in-process ACF Rule then require fleets to

  2	acquire these vehicles over years.	And the HD Omnibus

  3	Rule regulates combustion vehicles in the interim.

  4	All of this thoughtful, comprehensive, integrated,

  5	massive, years-in-the-making effort will be tossed

  6	out.	It will delay progress by years.	Lives would be

  7	lost and countless children and others would get

  8	asthma and suffer other health harms that otherwise

  9	could have been avoided.	Promises to EJ communities

 10	would be broken.	And all of this caused by EPA

 11	actions.

 12	The solution, of course, is to avoid this

 13	potential nightmare and instead realize all the

 14	comprehensive benefits these Rules will provide is for

 15	you to fully and immediately grant these Waiver

 16	Requests.	Thank you very much.

 17	THE MODERATOR:	Thank you for your comment.

 18	Our next speaker is Donna Albert.	State your

 19	name and affiliation for the record.

 20	MS. ALBERT:	Hi, my name is Donna Albert.

 21	I'm a retired Professional Engineer.	I am speaking as

             1	suffering right now because we have been too slow to

  2	provide them with a safe environment.	Delay is

  3	causing -- is harming children and even causing death.

  4	Delay is unnecessary and morally wrong.	While

             5	industry corporations are compelled to only consider

              6	company profits, government regulations protect the

              7	health and welfare of people.	According to a recent

  8	ICCT report on 1.5 degrees versus 2 degrees of

             9	warming, CO2 emissions from energy must be cut about

 10	in half by 2030 and ultimately nearly eliminated.

 11	Some energy infrastructure is easier to

 12	transition off of fossil fuels and others.	Land

 13	transportation is one we know how to do.	It is

 14	necessary to begin the transition off of fossil fuel

 15	trucks immediately in order for the trucking industry

 16	to cut emissions in half by 2030, which is only eight

 17	years away.

 18	In spite of the fact we have technology to

 19	use clean energy, we're not transitioning fossil fuels

 20	fast enough to safely avoid the worst effect of the

 21	climate change.	Many suffer already and many of them

  1	The global consequences of continuing to emit

  2	CO2 and other air pollutants are unacceptable

  3	persisting for centuries and even millenniums.	It is

  4	morally wrong for a rich country like the United

  5	States to delay this transition even for one day.

  6	Please grant all three CARB requests for exemption in

  7	full and without delay.	Thank you.

  8	THE MODERATOR:	Thank you for your comment.

  9	We are actually going to circle back to a speaker that

 10	we missed earlier, Amy Goldsmith.	Amy, if you could

 11	accept, I'm sending you an invitation to join as a

 12	panelist.	If you accept that, you will be able to

 13	join us on camera here and audio.

 14	Go ahead.	Please state your name and

 15	affiliation for the record.

 16	MS. GOLDSMITH:	Thank you.	My name is Amy

 17	Goldsmith.	I'm the New Jersey State Director for

 18	Clean Water Action.	We have 150,000 members in New

 19	Jersey, a million nationwide.	I'm also on the

 20	Steering committee of the coalition for healthy

 21	courts.	I'm speaking on behalf of Clean Water Action

  1	I'm here today to speak in favor of the EPA

  2	Waivers for all of the California-related heavy-duty

  3	Diesel Rules, the Advanced Clean Truck, Heavy-Duty

  4	Omnibus, and the Heavy-Duty Emission Warranty Act.

  5	EPA must continue to utilize its decades long

  6	precedent of approving Waivers with regard to vehicle

  7	emissions.	With these Waivers, states like New Jersey

  8	can adopt stricter and more protective policies of

  9	regarding diesel emissions.	This is critical in a

 10	state and region where intra- and interstate truck

 11	volume is ever rising and overburdened port

 12	communities have no relief.

 13	Port Elizabeth and Port Newark alone are

 14	responsible for over 20 truck trips per day and

 15	rising.	Even without the pandemic, it rises about ten

 16	percent a year.	These are some of the oldest and

 17	dirtiest trucks in the heavy-duty inventory.	The Port

 18	Authority still allows pre-2000 trucks to enter the

 19	gate, 22-year-old trucks can still come through our

 20	gate.	These trucks don't even have the most current

  1	that trucks are responsible for the majority of black

  2	carbon, health harming co-pollutants and ozone

  3	precursors in urban areas.

  4	Amazon is now the larger employer in the New

  5	Jersey.	Warehouses are proliferating and so too are

  6	heavy-duty diesel trucks and their corresponding

  7	emissions.

  8	We need every tool available to drive us

  9	toward zero-emission-Emission heavy-duty vehicles as

 10	fast as possible.	The EPA Waiver is an essential

 11	element.	We need more mandates and incentives to

 12	require the switch to zero-emission-Emission trucks.

 13	Our health communities and climate-changing trajectory

 14	demand it.	Need to require shorter and more

 15	aggressive timelines for the Rule adoption

 16	implementation and updating of Model Year engines.

 17	Remember, these trucks stay on the road for 20 to 30

 18	years unlike cars that have a ten-year lifespan.	And

 19	these and other heavy-duty diesel policies have

 20	generational impact.

  1	Federal EPA is not.

  2	As mentioned in previous Advanced Clean Truck

  3	Rule testimony, we have not -- we shouldn't allow

  4	fleet averaging.	We should include heavy-duty

  5	emission warranty rule as part of the Waiver package

  6	to ensure less tampering and better maintenance and

  7	repairs of these trucks.	And while idling,

  8	anti-idling, slow speed, traffic flow protocols have

  9	value on paper.	They rarely have any value on the

 10	actual road without enforcement and concerns about

 11	road rage threats which are real.

 12	The value of this and other EPA Rule

 13	proposals have huge impacts, positive and negative, if

 14	you don't do it.	It is vitally important that people

 15	who are most impacted have a voice at the table in

 16	shaping policy and its implementation.

 17	I only heard about this hearing through a

 18	late night E-Mail two days before the deadline to sign

 19	up.	It is imperative that the Biden Administration

 20	and EPA live up to its commitment to maximize

  1	There are examples of where the EPA has done

  2	much better, and with the new speaking time slots

  3	system, like what you have today, it is very, very

  4	helpful.	My day job is being an environmental

  5	activist.	And I had to scramble to be here today.

  6	Other people are not so fortunate and will not be

  7	heard.

  8	So, in conclusion, EPA must approve the

  9	Heavy-Duty Diesel Suite of Waivers; faster, bolder and

 10	more inclusive in developing, implementing and

 11	enforcing heavy-duty reductions while accelerating the

 12	purchase, utilization and infrastructure for

 13	zero-emission-Emission transportation in this case

 14	trucks.	Thank you for this opportunity to speak

 15	today.

 16	THE MODERATOR:	Thank you for your comments.

 17	The next speaker is Peter Brown.	I don't see

 18	you in list of attendees.	So if you joined us under a

 19	different name, there's a hand raise button at the

 20	bottom of your screen.

  1	Government Affairs and Global Policies representing

  2	the Nikola Corporation.	On behalf of Nikola, we

  3	appreciate this opportunity to express our support for

  4	reducing pollution and the carbon emissions footprint

  5	from heavy-duty trucks.	This support includes EPA

  6	granting Waivers to allow California and other states

  7	to enforce clean vehicle policies in the timeline set

  8	forth in their adoption.

  9	Such policies, including Advanced Clean

 10	Trucks and Clean Fleets policies, are important to

 11	accelerate the transition to zero-emission-Emission

 12	vehicle technology and reduce carbon emissions and

 13	criteria pollutants in California.	Particularly in

 14	air basins not attaining national ambient air quality

 15	standards.

 16	Over time, the adoption of

 17	zero-emission-Emission trucks will not only help

 18	address environmental and community health concerns,

 19	but is also expected to reduce costs for fleets over

 20	time with less moving parts.	And in Nikola's case,

  1	Arizona.	We are a leading manufacturer of

  2	zero-emission heavy-duty commercial battery electric

  3	and hydrogen fuel cell electric vehicles as well as

  4	provide energy solutions to support them.

  5	Nikola's mission is to transform the

  6	transportation industry while improving our employees'

  7	lives and leaving the world a better place.	This

  8	includes doing our part to increase the health and

  9	well-being of communities impacted by heavy trucking.

 10	Our products and services are built to deliver on

 11	these core commitments by manufacturing BEV and fuel

 12	cell trucks plus working with strategic business

 13	partners with suppliers to build a complete

 14	infrastructure ecosystem that will support the

 15	transition to zero-emission-Emission trucking.

 16	Operating as both a zero-emission-Emission

 17	OEM and an energy company, Nikola is a game-changer in

 18	the marketplace transforming the future of heavy-duty

 19	transportation focusing on addressing entire value

 20	chain to deliver an economic total cost for our

  1	trucks to launch, our launch customer, and total

  2	transportation services in December of 2021.	And have

  3	started production on the Nikola Tre battery electric

  4	truck at our Coolidge facility a few months ago,

  5	March 21 of 2022.	We have began delivering the

  6	battery electric trucks to customers and to our dealer

  7	network across the country anticipating between 300 to

  8	500 Tre battery electric trucks to be completed this

  9	year.

 10	The battery electric truck has a 753-kw

 11	battery onboard with a 350-mile range.	Its battery

 12	pack is modular and can be reduced for shorter

 13	distances and to maximize payloads to customers'

 14	operational needs and use case.

 15	Our next vehicle to market will be the Nikola

 16	Tre fuel cell truck which has 70-kilogram hydrogen

 17	onboard and is being designed and engineered to be

 18	capable of ranges up to 500 miles.	The Nikola Tre

 19	fuel cell truck will enter into production in late

 20	2023.

  1	to advance cleaner transportation and energy

  2	technologies that will yield a healthier tomorrow, by

  3	also creating jobs that will contribute to our

  4	nation's economic prosperity for generations to come.

  5	Thank you.

                  6	THE MODERATOR:	Thank you for your comment.

  7	As a reminder, please speak slowly and clearly so the

  8	court reporter and interpreters can accurately capture

  9	testimony.	If you can not give your prepared remarks

 10	in the five minutes allowed by speaking more slowly,

 11	you are welcome to submit it to the docket listed on

 12	the screen and we'll consider them in the, in the

 13	decision making process.

 14	Our next speaker is Angelique Espinoza.	I do

 15	not see you in the list of attendees.	Please raise

 16	your hand if you joined under another name.	There's a

 17	hand raise button on the bottom of your screen to be

 18	able to do so.

 19	I also don't see the next speaker, Mollie

 20	Michel.	If you joined under another name, if you

  1	for Science at Evangelical Environmental Network.	I'm

              2	a climate scientist and pastor of a local church in

  3	the Washington, DC area.	Most importantly, I am the

  4	mother of two boys, the youngest of whom just

  5	celebrated his first birthday.

  6	I speak to you from my capacity and

  7	experience in all three of these roles and I thank

  8	you, the administration, for acting swiftly on clean

  9	trucks, but I urge the EPA to approve California's

 10	Waiver Request in full allowing the State to create

 11	the strongest possible limits on heavy-duty vehicle

 12	pollution and Rules to accelerate the transition to

 13	zero-emission-Emission vehicles.

 14	Traffic emissions from heavy-duty trucking

 15	exhaust including ozone forming nitrogen oxide and pm

 16	2.5 harms health at every life stage, from children to

 17	adults.	Medical research continually affirms the link

            18	between toxic traffic emissions and life-threatening

            19	health conditions like asthma, heart disease, angina

 20	and premature death.

  1	exposure to traffic pollution increases the likelihood

             2	of reproductive, developmental harm including reduced

  3	fertility, preterm birth, low birth weight and even

             4	still birth.	Being recently pregnant this realty hit

              5	me at a very personal level.	While pregnant with my

             6	oldest son, I was living in downtown midtown Atlanta,

  7	a quarter mile from 75/85 downtown connector.	It is a

             8	more than 10-lane highway that cuts through the city

  9	and is filled with tractor-trailers and other

          10	heavy-duty trucks day and night.	I didn't appreciate

            11	this at the time that I was exposes my unborn son day

 12	and night to harmful truck emissions.

                13	My son recently received a diagnosis of ADHD

 14	which has been impacting his ability to learn and

            15	focus at school.	Medical research shows that exposure

 16	TO diesel fumes emitted from heavy-duty vehicles

            17	contributes to ADHD.	And like every parent, I want my

            18	children to reach their full God-given potential.	But

 19	the truth is that heavy-duty vehicle pollution robs

 20	children of this.	Personally, I can't help but feel

  1	our children.

  2	As an Evangelical Pastor, I take seriously

  3	what the Bible says in Proverbs, Chapter 13 Verse 22,

  4	that it is our duty to leave a good inheritance to

  5	future generations.	Asthma and unsafe climate, this

  6	is no inheritance leave to your children.	We need

  7	clean air now.

  8	As a parent, I know there's no time to wait

  9	for clean air now because the health and life of every

 10	children depends on it.

 11	As a climate scientist, I know there's no

 12	time to wait for clean air now because a safe and

 13	livable climate depends on it.	Clean air now depends

 14	on granting California's authority under the Clean Air

 15	Act to set more stringent emissions and standards.

 16	While you hear from others today about why we must

 17	wait for clean air, the truth is that vehicle

 18	manufacturers, as we just heard from Nikola, they

 19	already have the technology at hand to meet the goals

 20	of California's Rules.

  1	implementation of these life-saving technologies.

  2	As a mother, I have a responsibility to

  3	protect my kids.	As a pastor, I have a responsibility

  4	to protect my flock.	In the same way states have a

  5	responsibility to protect their citizens.	For more

  6	than 50 years U.S. States have had the explicit right

  7	granted under the Clean Air Act to protect their

  8	residents' health by choosing clean truck standards

  9	that are safer than Federal standards.

 10	So in closing, the EPA has the responsibility

 11	and the authority to approve this Waiver in full and I

 12	urge you to do so.	Thank you.

 13	THE MODERATOR:	Thank you for your comment.

 14	The next speaker will be Aidan Geronimus.

 15	Please state your name and affiliation for the record.

 16	MR. GERONIMUS:	My name is Aidan Geronimus,

 17	here representing Jobs to Move America.	We're a

 18	nonprofit organization that brings together community

 19	groups, environmental organizations and major

  1	address air pollution, but it is also increasingly

  2	clear that investment in zero-emission-Emission

  3	vehicles can create good jobs and work force pipelines

  4	to careers that provide for working families.

  5	So the EPA should support these Waivers.

  6	Because continuing to recognize state authority to set

  7	more protective truck standards has been and will

  8	continue to be a key tool for protecting public health

  9	across the country.

 10	Climate change is a public health emergency.

 11	From degraded air quality to warmer temperatures; more

 12	extreme weather events like storms and flood change is

 13	harming the health of communities across the county

 14	every single day.	The EPA and states must use all

 15	available tools to address climate change.	These

 16	tools include cleaning up the freight transportation

 17	sector, the nations biggest contributor to air

 18	pollution.	And these policies are entry points to do

 19	so.

  1	MS. BORCZ:	Hello.	Good afternoon.	My name

  2	is Judy Borcz.	And I'm testifying in both my

  3	individual capacity and as a member of 350 Silicone

  4	Valley here in California with the membership of

  5	several thousand.	Within the 350 Silicon Valley

  6	Group, I lead the transportation sub group to advocate

  7	laws and policies in the State, with the legislature

  8	and with groups like CARB.

  9	Thank you for the opportunity to testify

 10	today to urge EPA to fully grant California's Waiver

 11	Requests for the Advanced Clean Trucks,

 12	zero-emission-Emission Airport Shuttle, Zero-Emission

 13	powertrain Certification Regulations, the Omnibus Low

 14	NOx Regulations and the Heavy-Duty Emission Warranty

 15	Regulations.

 16	As a community member and advocate, I am

 17	keenly aware of the dire need to reduce air pollution

 18	from trucks.	And EPA should fully approve

 19	California's Waiver Request to enable state standard

 20	that are key drivers in advancing the technologies

  1	nonattainment as regulated by the Federal Clean Air

  2	Act among various issues.	California needs these

  3	regulation to enable achievement of Federal Standards.

  4	I'm also here because I am concerned about

             5	the climate crisis and the air quality in our State.

  6	My daughter recently move to Long Beach for college

  7	and the air quality difference versus Northern

  8	California is quite noticeable.	Not only are medium-

  9	and heavy-duty trucks a climate issue, but they are a

 10	major health problem.	Diesel emissions, particularly

 11	near the ports such as Long Beach are responsible for

 12	dangerous levels of nitrogen oxide and fine

 13	particulate matter that increases the risk of severe

 14	respiratory illness and other health problems.	We

 15	have only seen this issue amplified as studies

 16	continue to link long-term exposure to fine

 17	particulate matter with an increased risk of death

 18	from the Covid 19 Pandemic.

 19	The communities near the port are in dire

 20	need of all the electric trucks for the drayage trucks

  1	ability to address their unique air pollution

              2	challenges by enforcing life-saving truck pollution

  3	standards.	Thank you.

                  4	THE MODERATOR:	Thank you for your comment.

  5	At this time we have no one else scheduled to

           6	speak during the current time block.	But if there's

             7	anyone online that was scheduled to speak on this or

  8	an earlier panel and were unable to do so, please

             9	raise your hand in Zoom or dial Star-9 if you joined

 10	by phone and we'll get your testimony at this time.

 11	Not seeing any hand raises at this time, the

 12	next panel is scheduled to start at 2:45 Eastern Time.

 13	Karl or anyone else on the panel, can you confirm that

 14	we're ready to take a short break until the next break

 15	starts?

 16	MR. SIMON:	Yeah, that makes sense.	Let's

 17	take a short break.	Thanks, Jessie.

 18	THE MODERATOR:	We'll reconvene at 2:45 p.m.

 19	(Recess)

 20	THE MODERATOR:	It is now 2:45 p.m.	We're

  1	Did you give up and I missed it?	This is

  2	Tuana Phillips.	As a reminder, if you are speaking

  3	today, you will receive a notification on your screen

  4	that you are being promoted to the role of panelist.

  5	Shortly prior to your speaking time, you must click to

  6	accept that invitation to be able to unmute when you

  7	are called to testify and this will allow you to turn

  8	on your camera and we encourage you to do.

  9	Speakers connected by telephone should unmute

 10	their phones by pressing Star-6 when called to

 11	testify.	Please speak slowly and clearly so that our

 12	court reporter and interpreters can accurately capture

 13	your testimony.

 14	The next speaker will be Oscar Hauptman.

 15	State your name and affiliation for the record.

 16	MR. HAUPTMAN:	Hello.	My name is Oscar

 17	Hauptman.	O-s-c-a-r H-a-u-p-t-m-a-n.	I am 11 years

 18	old.	I live in Brighton, Michigan with my family.

 19	Dirty diesel trucks spew carcinogenic pollution into

 20	the air.	When that pollution heats up on hot days,

  1	nebulizer.	I went to the emergency room twice because

  2	of a bad asthma attack.

                  3	I love to play sports but poor air quality

  4	makes it hard.	I just started swimming this year.	It

  5	has been really hard.	Michigan has been under a heat

               6	advisory.	The weather app says the air quality is

              7	unsafe a lot this summer.	The air is too dangerous

  8	for me to swim, play basketball or soccer with my

  9	friends.

                 10	I know the largest source of pollution and

             11	smog comes from trucks, buses and cars.	It makes me

 12	mad that we are near these freeways when we play

          13	soccer breathing dirty air while we're trying to be

             14	healthy and strong.	The dirty air is especially bad

             15	for kids.	Kids breathe more rapidly and our hearts

          16	and brains are still developing.	We're breathing in

 17	poisons from these trucks and buses that harm our

 18	bodies.	Lots of kids in Michigan have asthma like me

             19	too.	Over 130,000 and we have over 12 countries --

            20	counties with a falling air quality grade, according                                           1	can help do this.	EPA must issue these Waivers

  2	quickly.	And, in full, to deliver President Biden's

  3	commitment to the authority of States to protect their

  4	vulnerability populations to address the climate

  5	crisis without delay and implementation of

  6	California's Clean Truck Rules will cause harm to the

  7	tens of millions of Americans who live near high

  8	traffic corridors including many kids like me.

  9	There's no time to waste.	Please protect our lungs

 10	and our brains.	Thank you.

 11	MR. DICKINSON:	Hey, Oscar, are you still

 12	there?	Mr. Simon and I would both like to take you

 13	for taking the time out of your summer to so

 14	effectively argue your point of view.	I want to thank

 15	you and congratulate you.	Looks like you and several

 16	other family members are participating.	I want to

 17	recognize you.	So thank you.

 18	THE MODERATOR:	Thank you for your comment.

 19	Our next speak will be Andrew Hauptman.

 20	State your name and affiliation for the record.

  1	throughout Michigan asking the EPA to allow California

  2	to set stronger standards for pollution.

  3	Since the earliest days of his presidency,

  4	and throughout subsequent Executive Orders, President

  5	Biden and his administration promised bold action to

  6	set strong rules and standards to lower emission for

  7	the transportation sector.	Including from medium- and

  8	heavy-duty vehicles; including granting the authority

  9	of California to set more stringent emission standards

 10	as EPA has done many times before in other states to

 11	adopt those stronger standards.

 12	These rules must be strengthened this year to

 13	protect the health of our community.	The EPA must

 14	enact these standards to protect American truck and

 15	bus fleets on a clear pathway to a hundred percent

 16	zero-emission by 2035.	Pollution harms all of us but

 17	disproportionately impacts children like my son, who

 18	has asthma.	His disease is made worse by our

 19	pollution.	Children are more impacted by air

 20	pollution for many reasons.	They breathe more

  1	concentrations of pollution from these trucks and

  2	buses is coming directly at them.

                  3	Pollution can also increase asthma rates in

  4	kids, poorer air quality can exacerbate asthma causing

              5	more asthma attacks resulting in millions of missed

  6	school days for kids across the county and often miss

              7	work days for adults.	In the summertime we need to

  8	watch our weather map to see if it is safe to play

  9	outdoors.	As a mother who has seen her son's face as

 10	his chest tightens and he gasps to breathe, we must do

 11	more to protect him and the children who suffer from

 12	chronic illness.	Far too often we have had to rush

 13	home after soccer game on a hot summer day to use his

 14	nebulizer.

 15	Furthermore, children's asthma rates are

 16	significantly higher in children of color.	Latinos

 17	are twice as likely to die from asthma.	And black

 18	children are ten times more likely to die from asthma

 19	than white non-Hispanic kids.	The statistics make it

 20	abundantly clear that a strong clean air car standard

  1	from the transportation sector, including medium- and

  2	heavy-duty vehicles.	And granting California the

  3	ability to set more stringent emission standards.

  4	Strengthening bus and truck emission standards is the

  5	best tool that you have in your tool box to fight

  6	climate change.	The urgent crisis is not something

  7	that we will see the impacts someday in the distant

  8	future.	We're seeing these impacts now with extreme

  9	weather events like flood, storms and heat Waivers.

 10	Addressing the pollution from heavy bus and truck

 11	transportation sector to fight climate change cannot

 12	wait.	Eliminating the emissions from heavy-duty

 13	vehicles especially through a rapid transition to

 14	zero-emission-Emission vehicles is essential for

 15	making strides for the steps that we need for cleaner

 16	air for these communities and safer climates.

 17	Zero-emission-Emission electric trucks are

 18	the best available technology to both reduce harmful

 19	NOx and climate pollution.	EPA should use these

              1	strong standards to reduce air pollution to protect

  2	our health especially for communities of color who

  3	bear the brunt of these health impacts from truck and

  4	bus pollution.	Thank you for your time.

                  5	THE MODERATOR:	Thank you for your comment.

                  6	The next speaker is Andrew Hauptman.	State

  7	your name and affiliation for the record.

                  8	MR. HAUPTMAN:	Andrew Hauptman, A-N-D-R-E-W

              9	H-A-U-P-T-M-A-N.	My affiliation is private citizen

             10	living in Britton, Michigan.	I am also an architect

 11	and a LEED certified green architect in Michigan.	And

            12	also I am the lucky father of Foster, the grandfather

 13	of Oscar and lucky husband to Elizabeth.	They have

 14	said very well what, uhm, what I think needs to be

 15	said.	And in my wife's work for Moms Clean Air Force,

            16	these -- I think they have put it very well which is

 17	that the EPA must enact standards that put the

 18	American trucking bus fleet on a clear roadway to a

            19	hundred percent zero-emission-Emission sales by 2035.                                           1	The next speaker is Mike Thompson.	State your name

  2	and affiliation for the record.

  3	MR. THOMPSON:	Good afternoon.	My name is

  4	Mike Thompson.	Today I am speaking on behalf Arrival.

  5	Before I get into my testimony, I also wanted to thank

  6	Oscar Hauptman for joining us today and speaking

  7	directly for the many kids, my own daughter included,

  8	who stand to benefit from these proposed Rules.

  9	Speaking today on behalf of Arrival, I am

 10	grateful for this opportunity to testify in support of

 11	California's Waiver Requests.	Arrival is a new

 12	manufacturer of exclusively battery electric

 13	commercial vehicles including Class 2B delivery vans

 14	and buses.	We manufacture our U.S. products at our

 15	Charlotte, North Carolina, Microfactory, and plan to

 16	scale with additional Microfactories close to customer

 17	demand across the country.

 18	Arrival's mission is to reduce emissions of

 19	greenhouse gases and pollutants to mitigate the

  1	medium- and heavy-duty vehicles.	These vehicles make

  2	up only about 5 percent of the vehicles on the road,

  3	but account for 30 percent of the greenhouse gas

  4	emissions from on-road transportation.

  5	Emissions from medium- and heavy-duty

  6	vehicles disproportionately harm disadvantaged

  7	communities including those that are in close

  8	proximity to industrial zones, ports and airports.

  9	The California programs being considered

 10	today will provide significant benefits to those

 11	communities, not only in California, but also in

 12	Section 177 states which choose to adopt these

 13	programs, as several have already done.	Several more

 14	states have announced their intentions to follow suit

 15	but would, of course, be prevented from doing so if

 16	EPA declines to grant these Waivers.

 17	In addition to the emissions benefits, these

 18	Rules will also drive American innovation and

 19	competitiveness.	These new Rules will drive

 20	investment by all companies selling vehicles to

  1	sector, which will continue to grow, and eventually

  2	dominate the automotive market.

  3	Indeed, such EV mandates would send a clear

  4	message to companies like Arrival, and others, that

  5	the United States is a welcoming and competitive

  6	market for EVs and would encourage further investment

  7	in domestic manufacturing and workforce development.

  8	It's also worthwhile to consider these

  9	regulations in the broader scheme of other

 10	EV-supporting policy instruments.	Grants, incentives

 11	and mandates work best when applied in coordination

 12	with one another, as has already been demonstrated in

 13	the light-duty ZEV market.	Grants enable the early

 14	development and proof of concept of novel

 15	technologies.	Incentives encourage adoption to the

 16	point that it becomes financially viable.	And

 17	mandates provide further uptake until the adoption

 18	goal is met.

 19	We're now at a stage where grants and

  1	Incentives like state-level vehicle purchase

  2	vouchers and the National Electric Vehicle

  3	Infrastructure Program will continue to support the

  4	ability of operators to meet these mandates.	Failing

  5	to adopt these mandates now would leave the job

  6	half-done resulting in avoidable climate change and

  7	deadly health outcomes and damage to America's

  8	automotive leadership.

  9	Thank you again for this opportunity to

 10	provide input.	We recommend EPA grant California's

 11	Waiver Requests without delay and we stand ready to

 12	assist in meeting this historic challenge.

 13	THE MODERATOR:	Thank you for your comment.

 14	Our next speaker is Stuart Liebowitz but I

 15	can't find you in the list attendees.	If you joined

 16	under a different name, can you please raise your hand

 17	using the raise-your-hand function at the bottom of

 18	your screen.	If you joined by phone, you can do that

 19	by selecting Star-9.

  1	for the opportunity to testify.

  2	I am grateful to this administration for

  3	acting swiftly on clean trucks, but I'm asking EPA to

  4	approve California's Waiver Request in full allowing

  5	the State create the strongest possible limits on

  6	heavy-duty vehicle pollution.	And Rules to accelerate

  7	the transition to zero-emission-Emission vehicles.

  8	We cannot delay any measures to ensure

  9	cleaner air as soon as possible.	California's

 10	authority to set more stringent emission standards

 11	under the Clean Air Act is crucial to cleaning the air

 12	throughout all Section 177 States.	Vehicle

 13	manufacturers are able to meet the goals of

 14	California's Rules, and recent research has shown that

 15	the Zero-Emission trucks will be cheaper to purchase

 16	and operate than diesel trucks within the timeframe of

 17	these standards.

 18	Very simply put, I'm here because I'm

 19	concerned about the future of children across America.

 20	As the mother of three young daughters, and a resident

  1	One in five people here in Detroit suffers

              2	from asthma.	And heart disease is the leading cause

  3	of death in our state with rates much higher among the

  4	lower income communities such as the one I live in.

             5	Delaying implementing clean truck and electric truck

             6	standards would prolong the suffering experienced by

  7	communities like mine.	Living daily with the impacts

  8	of environmental racism, redlining and generations of

  9	marginalization that make them vulnerable to pollution

 10	from trucks.	The disproportionate impacts of air

 11	pollution is the clearest example of environmental

 12	racism in our country.

 13	Giving States the option to adopt the

 14	earliest and strongest possible clean electric truck

 15	standards is necessary to fight environmental racism

 16	and provide relief to our communities.

 17	In conclusion, I urge the administration to

 18	approve the Waivers in full to grant California the

 19	authority to create life-saving Rules to reduce deadly

 20	pollution and to accelerate the transition to

  1	accurately capture your testimony.	And I want to

  2	remind everyone, if you are speaking today, you have

  3	received a notification on your screen that you are

  4	being promoted to the role of panelist shortly prior

  5	to your speaking time.	You must click to accept the

  6	invitation to be able to unmute when you are called to

  7	testify.	This will allow you turn on the camera and

  8	we encourage you to do so.

  9	Speakers connected by telephone should unmute

 10	their phones by pressing Star-6 when called to

 11	testify.

 12	The next speaker is Kelly Blynn.	State your

 13	name and affiliation for the record.

 14	MS. BLYNN:	Thank you.	My name is Kelly

 15	Blynn.	I'm a transportation climate change specialist

 16	for the Colorado Energy office.

 17	I'm testifying today on behalf of my agency

 18	and our partner agencies, the Colorado Department of

 19	Transportation and Colorado Department of Public

 20	Health Environment on the Notice of Waivers for

  1	NOx Rule.	Colorado is headed to approving rule making

  2	at our State Air Quality Control Commission later this

  3	year to consider adoption both the Clean Truck Rule

  4	and the Low NOx Omnibus Rule to help address our state

  5	air quality challenges and our climate change and

  6	environment justice goals.

  7	Greenhouse gas emissions from vehicles are

  8	the top source of emissions in Colorado.	A

  9	significant portion of our population lives in an area

 10	of the state that's soon to be classified as a severe

 11	ozone nonattainment area by EPA.	Transportation is

 12	one of the two largest sources of ozone precursors

 13	along with oil and gas production largely due to NOx

 14	emission from medium- and heavy-duty vehicles.

 15	Reducing transportation emissions is a critical

 16	strategy to meet our Air Quality Standards.

 17	Of note, cleaner trucks on the road are

 18	especially important for our residents who live in

 19	close proximity to freight routes and their

 20	disproportionate impact from truck emissions.	These

  1	Medium- and Heavy-Duty Zero-Emission Vehicle

  2	Memorandum of Understanding in 2020; hosting a robust

  3	stakeholder process to develop our clean truck

  4	strategy and implementing clean air transportation

  5	electrification enterprises that are forecast to

  6	invest over 700 million in transportation

  7	electrification over the next decade.

  8	Like I said, we are committed to a notice of

  9	rule making on Advanced Clean Trucks and the Low NOx

 10	Rule later this year, which we see as critical

 11	complimentary strategies for the suite of incentives

 12	charging investments, and other action in our clean

 13	truck strategy to reach our State Air Quality Climate

 14	and Environmental Justice Goals.

 15	We urge EPA to approve California's Waiver

 16	Requests without delay.	Thank for the opportunity to

 17	testify.

 18	THE MODERATOR:	Thank for your comment.

 19	Our next speaker will be Katherine Goff.	I

 20	can't find you on the list attendees.	Can you raise

  1	Greenberg.	Please state your name and affiliation for

  2	the record.

  3	MS. GREENBERG:	Good afternoon.	My name is

  4	Molly Greenberg, I'm a campaign manager with Moving

  5	Forward Network.	MFN is a national network of over 50

  6	member organizations that centers grassroots,

  7	frontline-community knowledge, expertise and

  8	engagement from communities across the U.S. that bear

  9	the negative impacts from freight transportation

 10	system.

 11	The freight system relies on a myriad of

 12	ships, trucks, trains, and cargo-handling equipment

 13	for the huge volumes of goods from place-to-place

 14	every day.	And for some communities, like those near

 15	the ports of LA and Long Beach, this is now a 24/7

 16	operation.	These communities are primarily BIPOC and

 17	low income communities, environmental justice

 18	communities across the country are living in the

 19	shadow of dirty freight operations and are caught in

 20	dangerous intersections of toxic pollution, racism,

  1	heavy-duty vehicles.	This should come from the State

  2	and from the Federal rule making.	And yet we're here

  3	today advocating that they do just that.

  4	A few weeks ago MFN members from across the

  5	country headed to the Summit of the Americas where

  6	President Biden spoke on climate action at the Port of

  7	Long Beach in California with a clear message directed

  8	at the Biden administration's Zero Emissions Now

  9	(unintelligible).	The Biden administration has spoken

 10	time and time again about the importance and

 11	prioritization of environmental justice communities

 12	and zero-emissions.

 13	And yet, industry is able to move and

 14	influence enough to call into question that for

 15	decades the U.S. EPA has granted California the

 16	Waivers for its clean air and climate programs.	Our

 17	members and our communities are not mincing words.	We

 18	need action.	We demand action.

 19	The final point I would like to make to share

 20	today is our concern is the public notification and

  1	public notification of hearing and comment process and

  2	actual registration and submission deadlines as well

  3	as additional opportunities to testify.	EPA still has

  4	the opportunity to do this since the public comment

  5	period remains open.

                 6	Along with stronger public notification, the

             7	EPA needs to provide at a minimum a stronger language

  8	process to their rule making.	For example,

  9	translating documents, making it clear that the

 10	hearings will be provided and have translation.	Over

 11	40 percent of the U.S. speak another language other

 12	than English and EPA should know that and support

 13	public participation within the rule making for

 14	everyone.	They did it recently within the heavy-duty

 15	truck rule and make sure to translate the announcement

 16	and it was not translated for this particular hearing.

 17	EPA's decision on this matter will impact

 18	communities outside of California who have been

 19	suffering from the deadly impact of the growing

 20	(unintelligible).	These Waivers for heavy-duty truck

  1	and Waivers in full.	Any delay, any reduction in

  2	regulation will result in generational health impacts

  3	and premature deaths for communities across the

  4	country.	Our communities lives are at stake.

  5	I thank you for your time and the opportunity

  6	to speak.	And we will be providing more technical

  7	comment for the written portion.

  8	THE MODERATOR:	Thank you for your comment.

  9	Our next speaker is Aisha Balogun.	Please

 10	state your name and affiliation for the record.

 11	MS. BALOGUN:	Hello everyone.	My name is

 12	Aisha Balogun.	I am an Environmental Justice Fellow

 13	with the Moving Forward Network, a position made

 14	possible by the Postdoctoral Fellowship Program at

 15	Yale University.	I'm also a Masters student studying

 16	urban planning at New York University Wagner Graduate

 17	School for Public Service.

 18	I'm speaking in support of EPA's full and

 19	prompt passage of California's Waivers for the

 20	Heavy-Duty Truck Regulations.	Even though I live in

  1	than Federal standards.	Many states, including my

  2	current home of New York, have chosen to adopt

  3	standards similar to California's on their own accord.

  4	These Waivers are of national importance.

  5	Across the country, urban highways frequently

  6	border and bisect low income communities and

  7	communities of color.	This is an unjust legacy of

  8	urban renewal and Federal transportation policy.	The

  9	proximity of low income communities and communities of

 10	color to heavy traffic means that these populations

 11	suffer the most from harmful emissions.	Communities

 12	and states should have access to every policy tool it

 13	takes to address the present harms of this injustice

 14	and that includes stringent emissions reduction

 15	projects.

 16	The negative health impact of emissions that

 17	disproportionately affect daily life in low income

 18	communities and communities of color have not ceased.

 19	So why would we reject new environmental regulations

 20	and endanger those that have been in place for

  1	emissions control and Zero-Emission trucks are

  2	necessary to ensure the health of environmental

  3	justice communities.

  4	We risk reversing years of progress by

  5	denying or partially denying the Waivers set forth

  6	today.	The EPA must fully grant California's new

  7	Heavy-Duty Truck Waivers.	Thank you for your time and

  8	consideration.

  9	THE MODERATOR:	Thank you for your comment.

 10	The next speaker will be Clare Alford.	State your

 11	name and affiliation for the record.

 12	MS. ALFORD:	My name is Clare Alford, and I'm

 13	on the Market Development Team of Highland Electric

 14	Fleets.	Highland is electrification service provider

 15	supporting municipal and government fleets across the

 16	country.	The focus today is on school bus

 17	electrification.	We're active in 27 states and are