Nevada could evaluate implementation of a Clean Truck Program that includes requirements for low- or zero-emissions commercial truck sales in the state and/or operating requirements within the state. A Clean Truck Program could accelerate a large-scale transition of medium- and heavy-duty vehicles (MHDVs) within Class 2b to Class 8 from fossil fuels to zero-emissions technology (e.g., electric and hydrogen fuel cell).
The U.S. Environmental Protection Agency (EPA) estimates that MHDVs are the second-largest source of transportation-related greenhouse gas (GHG) emissions nationwide, noting that in 2018 light-duty vehicles represented 58% of CO2 emissions from transportation fossil-fuel combustion and MHDVs represented 25%.”
Like low-emissions vehicle (LEV) and zero-emissions vehicle (ZEV) standards, a Clean Truck Program would need to be based on regulations adopted in California. This is simply because the 1970 Clean Air Act allows California to seek a waiver to set stricter emissions standards than those set by the federal government and provides the authority for other states to adopt the California standards.
California adopted an Advanced Clean Truck (ACT) regulation on June 25, 2020. The regulation aims to accelerate California’s transition to zero-emissions MHDVs (CARB, 2019; CARB, 2020). It has two parts:
- Zero-emissions truck sales: Manufacturers that certify certain truck chassis or complete vehicles with combustion engines would be required to sell zero-emissions trucks as an increasing percentage of their annual California sales from 2024 to 2035.
- One-time large company and fleet reporting: Large employers including retailers, manufacturers, brokers, and others would be required to report information about shipments and shuttle services. Fleet owners with 50 or more trucks would be required to report about their existing fleet operations. This information would help identify future strategies to ensure that fleets purchase available zero-emissions trucks and place them in service where suitable to meet their needs.
In addition to California, 14 other states have signed a memorandum of understanding (MOU) committing to collaborate on a multi-state action plan to support a sustainable zero-emissions MHDV market and widespread electrification of MHDVs. The MOU also includes agreement to reach 30% zero-emissions MDHV sales by 2030 and 100% by 2050, and to make progress toward electrification of state government and quasi-governmental agency MHDV fleets. The MOU contains several other elements, including consideration of the need for adoption of the California Advanced Clean Trucks Rule under Section 177 of the Clean Air Act.
With dedication of some additional personnel resources, Nevada could join these 15 states to participate in development of the action plan and associated efforts. An initial review of a Clean Truck Program and identification of issues for further evaluation is included below, and may be partially completed through Nevada’s participation in the MHDV MOU and associated action plan with other states.
Greenhouse Gas Implications
In order to adequately assess the potential GHG reduction, more information is needed, such as the market for MHDVs in Nevada as well as operating characteristics of the MHDV fleets in the state. MHDV charging infrastructure planning and investments would need to be evaluated in parallel with adoption of a Clean Truck Program to better predict GHG emissions-reduction impacts.
Operating characteristics of fleets, such as local delivery trucks that travel short distances within confined areas versus long-haul interstate trucking, would be necessary to understand both the opportunity as well as the effectiveness of this policy. Some of this information is available, but detailed analysis has not yet been done for Nevada. Approximately 70% of trucks operating within the state are coming from or going to California, so Nevada will likely benefit from regulations in California (Transearch Truck Data, 2018).