Chapter 173-423 WAC, Clean Vehicles Program Rulemaking Informal Comment Period

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Comment From: Safe Roads Coalition

2/10/25 @ 1:00 AM

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Comment From: Natural Resources Defense Coun... (Guillermo Ortiz)

2/09/25 @ 9:31 PM

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Comment From: Rachel Roberts

2/09/25 @ 9:27 PM

I encourage Ecology to adopt the proposed amendments. Not only should we do everything we can to fight climate change, but I live in a neighborhood bordered by state highways on two sides and our air quality suffers as a result. Cleaner trucks would ...↓

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Comment From: Denise Nelson

2/08/25 @ 8:33 AM

I am a 60yo female who will be retiring in 6 months. I am planning to travel full time in new 2025 Roadtrek Campervan built on a 2024 Dodge RAM Promaster van (Stellantis). I have put a large down payment on this from a dealer in Florida. I am a pr...↓

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Comment From: Earthjustice & Duwamish River ... (Jaimini Parekh)

2/08/25 @ 8:22 AM

Please see attached.

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Comment From: City of Seattle (Anna Johnson)

2/07/25 @ 5:42 PM

February 7th, 2025

Re: City of Seattle Comments on Washington Clean Vehicles Program Rulemaking

Dear Washington State Department of Ecology,

The City of Seattle appreciates the opportunity to provide comments on the Washington Clean Vehicles...↓ Program rulemaking. The City strongly supports the program's goals to accelerate the transition to zero-emission vehicles (ZEVs), reduce greenhouse gas (GHG) emissions, and improve air quality, particularly for communities disproportionately impacted by pollution. This rule has important implications for the City's sustainability goals, fleet management, and equity priorities, and we offer the following recommendations to ensure effective implementation while addressing potential challenges:
Prohibit ZEV Purchase Bundles with ICE Vehicles - The City supports adding language to prohibit manufacturers and dealers from requiring the purchase of a ZEV as a condition to procure internal combustion engine (ICE) vehicles. Such practices would undermine equitable access to vehicles, increase costs and create unnecessary barriers for fleet operations.
Increase transparency around Credits - The limited number of credits being made available in Washington is driving up the cost of vehicles and those costs are then being passed along to the end purchaser in the form of a fee. There is currently no prohibition on this practice and there is no transparency to the fee structures.
Provide Exemptions for Critical and Vocational Vehicles - We recommend updating the definition of "Authorized Emergency Vehicle" to include utility trucks and other vocational vehicles essential for disaster response and critical operations. These vehicles often lack ZEV alternatives that meet operational and reliability requirements.
Address Infrastructure and Fiscal Challenges - While Seattle is committed to fleet electrification, the program's accelerated timelines could exacerbate existing infrastructure and budget constraints. The City urges Ecology to develop policies or funding mechanisms to support the deployment of charging infrastructure and renewable fuels for vehicles where ZEV alternatives are unavailable. Additionally, allowing flexibility in procurement timelines could prevent the unintended consequence of prolonging the use of older, higher-emission vehicles. Wherever possible, we encourage the state to establish procurement contracts that allow for local jurisdictions to piggy-back and realize volume pricing.
Support for WMBE Businesses - We encourage Ecology to provide targeted support for small businesses, including women- and minority-owned contractors, who may face financial barriers to transitioning their fleets to ZEVs. Tailored financial assistance, training, and outreach will help ensure equitable access to cleaner transportation technologies.

Thank you for considering City of Seattle's input. We look forward to continuing our partnership with Department of Ecology on this matter.

Sincerely,

Anna Johnson
State Legislative Affairs Director
City of Seattle

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Comment From: Washington Clean Vehicles Coal... (Ellen Bini)

2/07/25 @ 5:42 PM

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Comment From: City of Kennewick (John Noble)

2/07/25 @ 5:11 PM

Thank you for the opportunity to comment on the proposed Clean Vehicles Program Rulemaking, we have appreciated the public information sessions. While the sessions have been helpful for those who have participated, we are still experiencing confusio...↓

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Comment From: Washington Refuse & Recycling ... (India Brine)

2/07/25 @ 4:53 PM

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Comment From: AAA Washington (Mellani McAleenan)

2/07/25 @ 4:29 PM

Thank you for the opportunity to provide comments regarding the future implementation of Zero-Emission Vehicle (ZEV) requirements in Washington State.

Since 1904, AAA Washington has been the trusted partner for generations of members, enhancing the...↓

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Comment From: American Trucking Asociations (Michael Tunnell)

2/07/25 @ 12:50 PM

Please accept and consider the attached comments on behalf of the American Trucking Associations

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Comment From: Puget Sound Clean Air Agency (Christine Cooley)

2/07/25 @ 12:05 PM

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Comment From: Climate Solutions (Leah Missik)

2/07/25 @ 11:35 AM

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Comment From: Washington PUD Association

2/06/25 @ 3:26 PM

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Comment From: Angela Stenhouse

1/30/25 @ 11:04 AM

This program is another level of burden on business and industry in Washington State that will primarily result in higher costs to do business. These additional expenses will be passed onto consumers resulting in higher prices for all goods and servi...↓

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Comment From: Elders Climate Action (Bob Yuhnke)

1/17/25 @ 1:56 PM

Now that US EPA has failed to grant a waiver for CARB's Advanced Clean Truck and Advanced Clean Fleets rules, and CARB has withdrawn those rules from further consideration by EPA, WA DE is precluded from adoption of the pre-empted portions of those r...↓egulations. As an alternative, we urge WA DE to consider the adoption of transportation control measures that limit or restrict the operation of polluting vehicles authorized by the CAA and that are not federally pre-empted because they are NOT an emission standard applicable to the manufacture and sale of new motor vehicles.
CARB's drayage truck rule is an example of this kind of transportation control measure because it phases out the operation of diesel trucks for the transport of cargo to and from the ports. This kind of rule does not require an EPA waiver before it can be implemented because it "limits or restricts the operation" of polluting vehicles rather than setting emission standards for new vehicles.

The Clean Air Act pre-empts States from adopting emission standards that limit emissions from new motor vehicles. A separate section of the Act authorizes states to limit or restrict the operation of existing vehicles as a control strategy to reduce emissions from on-road vehicles. Restricting diesel vehicle access to the ports is such a transportation control measure because it restricts the operation of all polluting vehicles after they have been purchased and registered for operation, but does not set standards for new vehicles. CARB's drayage rule prohibits the operation of polluting vehicles when carrying cargo to the ports, but is not federally pre-empted because it does not prohibit the sale of such vehicles by manufacturers or purchase by fleet operators.

As we discuss in our comments to EPA explaining that no waiver is required for implementation of the drayage rule (see attached), transportation control measures such as CARB's drayage rule are expressly authorized by the Act when needed to reduce emissions from the transport sector. The Act does not require a waiver from EPA for a State to implement a transportation control measure.

The South Coast State Implementation Plan (SIP) submitted by CARB in 2023 is very clear that the ozone air quality standards cannot be attained without major reductions in NOx from trucks operating in South Coast AQMD. The modeling analysis submitted to EPA in support of the SIP shows that the emission reductions required by enforceable control measures fall far short of the NOx emission reductions needed to attain healthy ozone levels in the region. The drayage rule, and other similar control measures to reduce truck emissions, are needed for attainment. Other states can adopt similar control measures as long as they can be shown as contributing to emission reductions needed to either attain or maintain a NAAQS.

In the comment to EPA we provide an analysis of the CAA and its legislative history to show that the Act expressly authorizes States to adopt such control measures as part of a control strategy to attain or maintain a NAAQS, and that the Act mandates that transportation control measures be adopted by the State when emission reductions are needed from motor vehicles to attain the air quality standards to protect public health. Because CARB's ozone SIP shows that NOx reductions from trucks are necessary for attainment, it is not lawful for CARB to withdraw the drayage rule. Instead it should be implemented, and supplemented by similar measures designed to limit or restrict the operation of other diesel vehicles.

Programs similar to CARB's drayage rule are not an emission standard for new trucks, are a transportation control measure which may be implemented by any State without first being adopted by California and being granted a waiver by EPA, and must be implemented in nonattainment areas without approved control strategies that contain enough emission reductions from other sources to end violations of national air quality standards no later than the statutory deadlines for attainment.

Given that TCM programs such as CARB's drayage rule are not federally pre-empted, CARB's action to withdraw the drayage rule as part of California's application for a waiver is not an obstacle to adoption of similar programs by other states. The drayage rule was designed to serve multiple health-related purposes, including: 1) contribute to the NOx reductions needed for controlling regional ozone pollution, 2) protect the health of residents living in the communities near the ports and along the heavily trafficked truck corridors providing access to the ports by reducing exposure to diesel particle pollution that add to emissions from ships and port operations and cause the highest health risks in the region, and 3) contribute to the State plan for reducing GHG emissions to slow the warming and minimize the impacts of a changing climate. Despite California's action to withdraw the drayage rule, along with other regulations that do require an EPA waiver, other States retain authority under the CAA to adopt similar transportation control programs to attain and maintain NAAQS and protect against other adverse impacts on public health caused by exposure to diesel exhaust.

This comment and the attached comment to EPA is submitted by Robert Yuhnke who was EDF's senior CAA attorney in 1990, played a major role in working with Henry Waxman and his staff in drafting the 1990 CAA Amendments, and wrote the transportation control measure text that requires states to "limit or restrict the operation of vehicles" when needed to attain national air quality standards.

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Comment From: Cory Henry

1/11/25 @ 1:45 AM

Hello,
I believe in clean air and a healthy environment. I also think that the cart is way ahead of the horse with ACT. Billions of dollars have already been spent by manufacturers to make massive improvements to the current diesel engines. By allowi...↓ng ACT to stay enacted, the trucking industry and consumer's will not be able to purchase these newer cleaner engines at the level needed. The ZEV's of today are costly and the current infrastructure cannot support them. Inslee stated, in a response to the WTA, about providing charging infrastructure up and down Interstate 5, but what about the other 2/3 of the state. This new law immensely limits new diesel sales and will cause buyers to keep their current diesel engines that are not as clean due to availability. With these limitations, the state could fall backwards in what the end goal is, a cleaner environment. I have read the belief that there is no limitations for consumer's to purchase diesel engines, but that is completely false. OEM's purchasing ZEV credits does not help clean air and grant money for purchasing ZEV trucks and tractors is not plentiful enough to fulfill the amount of new diesel sales that are needed. I am a new truck salesman in Yakima and have ZERO customer interest in ZEV's. I sell 100 diesel chassis' per year and with ACT being implemented, I will sell no new cleaner diesel units due to no ZEV sales. I do not think that our state has a clue about how many new emissions diesel sales are generated on an annual basis. Range on ZEV's in Eastern Washington will not work due to the mileage between point A and B. Currently, we have the cleanest diesel engines in history and have other alternatives, such as CNG, that are not recognized as clean enough for any sort of diesel sale credits. We have more availability and range with CNG and need to assess what is realistic at this time. I have customers that are in need of new equipment they cannot purchase due to lack of credits and I will go broke myself having no sales if ACT stays enacted. Tax revenue for the state always seems to be the second most important agenda alongside clean air, but your tax revenue will also suffer with lack of new sales. It took almost a century to place gas and diesel pumps on every corner and now Washington State, among others, expect plentiful charging stations in a timely manner. This is absurd! If Washington State wants to see unemployment increase and consumer's running old equipment, then by rights keep moving forward. My family's livelihood revolves around trucking. It is a real shame that putting food on the table for them may end up being a struggle from here on out. I hope someone in our legislation has a wake up call and thinks up a better plan on a slower rollout over time and actually has the horse pulling the cart.

Thanks for your time,

Cory Henry

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Comment From: Sara Millard

1/09/25 @ 5:58 PM

We are not California! This law is not logical in any way. We should be able to choose what we drive. The fact that people can't even buy a certain size motorhome or pickup anymore is unbelievable. What about the semis? How many times would they have...↓

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Comment From: Gordon Truck Centers (Patrick Gendreau)

12/24/24 @ 9:56 AM

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Comment From: Puget Sound Transfer (Eric Flodstrom)

12/13/24 @ 1:12 PM

Clean Vehicles comments. Puget Sound Transfer is a small trucking company in Port Angeles, WA. We have 14 four axle heavy tractors that run 5 days a week. I am on a schedule to purchase one or two new diesel tractors a year to take the place of my ol...↓

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Comment From: Carrie Parks

12/11/24 @ 11:42 PM

I support continuing to follow Chapter 173-423 WAC, the Clean Vehicles Program rule. Washington law (RCW 70A.30.010) that requires Ecology to adopt certain California regulations to maintain consistency with California's emissions standards for new m...↓

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Comment From: Don Steinke

12/10/24 @ 7:57 PM

Hello, my name is Don Steinke. I'm a retired high school science educator in Clark County. I'm also on the Clark County Citizens Advisory Committee tasked with recommending policies to reach the emissions reduction goals mandated by our legislature...↓

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Comment From: Lori Benton

12/10/24 @ 12:25 PM

I very much support ACT. For the sake of everyone's health, we should help truckers to electrify and move away from diesel fuel ASAP.

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Comment From: Jason Walsh

12/10/24 @ 8:11 AM

Dear Regulators-

Truck manufactures are building on Ecology to weaken, delay and/or roll back the ACT (Advanced Clean Truck rule) and HDO (Heavy Duty Omnibus rule). These
state truck engine emissions standards were originally put in place to protect...↓

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Comment From: Julia Buck

12/09/24 @ 11:04 PM

I support the proposed Advanced Clean Truck rule and the Heavy-duty omnibus rule. Trucks are not only a disproportionate source of carbon pollution for the miles traveled, but they are a source of harmful particulate matter that has led to health dis...↓

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Comment From: Angela Stenhouse

12/03/24 @ 8:55 AM

I hope the State has taken into consideration that this rule will result in higher prices for all goods as they will be transported by haulers based out of Washington State or instate hauler will have to pass the higher cost to do business onto custo...↓

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Comment From: Patricia Davis

12/02/24 @ 3:23 PM

RE: CLEAN VEHICLE PROGRAM

Research on the impact of Ports is well known, well done, replicated research. It is clear and obvious that Ports cause grave harm to the air, humans, animals and the general earth environment. That is a FACT. It is UN...↓

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