In Re: February 23 Hearing “Building Back Better: Investing in Transportation while Addressing Climate Change, Improving Equity, and Fostering Economic Growth and Innovation.”
Dear Chairman Carper and Ranking Member Capito:
Thank you for your leadership on these issues and holding this hearing.
As the nation’s leading advocate for diesel technology, we submit these comments in hopes of illuminating an approach that will enable the United States to attack the broad climate change challenge and build back better.
Last week’s severe weather in Texas and Oklahoma, and the response to the severe wildfires in California, share both the relationship to climate change, and the unique call and deployment of diesel power to aid in the response.
"FEMA has supplied generators to Texas and is preparing to move diesel on to the state to ensure the continued availability of backup power," February 18, 2021 Jen Psaki, White House Press Secretary.
The U.S. cannot rely on a one-size-fits-all approach to mitigating greenhouse gas (GHG) emissions or planning for a more climate resilient future. All energy sources have value, limitations and unique properties that are particularly suited for different tasks.
- Building back better - the nation’s energy systems and infrastructure - will require both transformative technologies as well as proven and available solutions that can be deployed immediately. As we look to the promise of zero-emissions solutions in the longer term, we must leverage the fuels and technologies like diesel technology and renewable low-carbon biofuels that are available today.
- A diverse approach that incorporates conventional and renewable sources has the greatest chance of success to make our communities more resilient to the effects of climate change while doing the most we can now to reduce greenhouse gas emissions.
Building Back Better Recognizes the Time Factor and Immediacy of Reducing Transportation Sources of Greenhouse Gas Emissions
Greenhouse gases emitted today will remain in the atmosphere for centuries, which is why we should not ignore near term and available solutions that are ready today to eliminate these emissions.
Here, the new generation of diesel technology can play an outsized role in immediately reducing emissions from key sectors of the economy -heavy-duty mobile source applications like trucks, construction and agriculture equipment, locomotives, and marine vessels. Commercial vehicles are responsible for about 24 percent of mobile source emissions, and 60 percent of these emissions are generated by the larger Class 8 trucks, according to the latest emissions inventory published by U.S. Environmental Protection Agency (EPA).
As zero-emissions options are planned for the future to meet the demanding duty-cycle of these over-the-road trucks, and as a nationwide network of charging infrastructure is still in development, new more efficient diesel trucks can do quite a lot to reduce emissions today and tomorrow. Consider the following:
- Replacing a single older Class 8 diesel trucks with a new more efficient diesel option can eliminate almost 10 tons of greenhouse gas emissions in a year.
- New more stringent fuel economy and GHG reduction regulations (Phase 2) kick-in this year for commercial vehicles powered by diesel engines and these are expected to reduce emissions by over 1 billion tons between 2021 and 2027.  As zero-emissions solutions are slowly introduced into the fleet, diesel is expected to continue to be the dominant powertrain and deliver the majority of these benefits.
Leverage the Opportunity for Low-Carbon Advanced Biofuels
Even greater immediate term GHG reduction benefits from the diesel platform are expected using advanced biofuels including biodiesel and renewable diesel fuel. These are very low carbon fuels capable of reducing GHG emissions by at least 50 percent, and in the case of renewable diesel fuel, nearly 80 percent.
In California, these low carbon fuels have eliminated the most greenhouse gas emissions of all transportation fuels and technologies beating the benefits generated by electrified of cars, trucks and buses by nearly 4:1, according to the California Air Resources Board. These are low-cost immediate term benefits provided by fuels derived from waste products and do not require the purchase of new trucks or engines or investments in a nationwide charging network.
Accelerating the uptake of more efficient diesel commercial vehicles that are much more fuel efficient, coupled with the use of advanced biofuels can deliver significant and immediate GHG reductions helping to meet the immediacy of the climate challenge.
Clean Air Benefits of New Diesel Technology
Replacing the relatively large population of older trucks and equipment with these widely available new near-zero emissions diesel solutions can go a long way to improve air quality for residents in communities that have been promised cleaner air. The latest diesel innovations reduce emissions of fine particles (PM) and oxides of nitrogen (NOx) to near zero levels providing significant public health benefits for environmental justice communities located near large freight facilities like ports and railyards. Relative to previous generations of older diesel technologies, new trucks, and bigger engines that power locomotives and marine vessels are over 90 percent cleaner.
As an example of the benefits of new diesel trucks, the Ports of Long Beach and Los Angeles require that all the estimated 16,000 trucks entering and exiting marine facilities each day and transiting through dense communities meet the latest near-zero tailpipe emissions standard for fine particles. Fine particle emissions from trucks fell 90 percent and trucks are now one of the smallest contributors to all emissions generated in the port, according to the most recent emissions inventory published by the Port of Long Beach. These are immediate term public health benefits delivered directly to near-port communities thanks largely to new diesel technology.
All Fuels and Technologies Have a Role in Designing a Climate Resilient Future
As the recent events of last summer’s high heat and wildfire season in California, and more recently, unseasonal severe weather in Texas and Oklahoma have demonstrated, we cannot rely on a one-size-fits-all approach to planning for a more climate resilient future. All energy sources have value, limitations and unique properties that make them better suited for different tasks. We need to rely on multiple technologies and fuel types to better plan for a more resilient future.
Consider first responders in Texas last week, called upon to perform mission critical services fighting fires and providing emergency electrical power. In this scenario, an all-electric world would have limitations in times of crisis when access to electricity is unavailable. These are instances where fuel diversification is of extreme value and must play a role to meet the practical needs of more resilient communities.
Today, there are more clean transportation fuel options that ever before and these should all be considered an integral component of climate resiliency planning to deliver mission critical services in the face of future extreme weather events.
Diesel is the most efficient internal combustion engine coupled with near zero emissions and ability to use renewable low carbon renewable biofuels, all which make it a desirable part of the climate solutions. Diesel-powered machines and equipment are vital to delivering the net zero carbon future we all envision.
- We see diesel-powered construction machines completing utility grade solar arrays, grid hardening infrastructure and onshore wind farms.
- We see diesel-powered marine vessels facilitating the construction of offshore windfarms.
- We see diesel emergency backup generators being staged to provide electric power generation or water pumping capabilities to build climate resilient infrastructure.
Diesel is part of the solution for tackling climate change, growing the economy and delivering cleaner air now.
We thank you for the opportunity to provide these comments. Please contact me with any questions.
Diesel Technology Forum
The Diesel Technology Forum is a Maryland based educational not for profit association that represents manufacturers of diesel engines, vehicles and equipment including mobile and stationary generators, along with component manufacturers and fuel and biofuel producers. The Forum collects and commissions research that attests to the environmental and economic importance of diesel technology and serves to advocate these benefits broadly.