NATSO, representing America’s travel centers and truck stops, SIGMA: America’s Leading Fuel Marketers, and the National Association of Convenience Stores (NACS) urged the Environmental Protection Agency (EPA) to revise its proposed greenhouse gas standards for heavy-duty trucks and adopt a market-oriented, technology-neutral approach to transportation decarbonization.
Rather than adopting a single approach to emissions reductions, the organizations urged EPA to harness the immediate decarbonization benefits of existing lower carbon options, including renewable diesel and biodiesel.
“The enormous practical and logistical challenges associated with electrifying trucks necessitate that the agency not rely entirely on a prodigious pace of heavy-duty electrification to decarbonize the trucking sector,” the organizations wrote in public comments submitted to EPA. “Instead of depending on one technology to act as a silver bullet, the agency should adopt an agnostic approach to low-carbon technologies that can deliver substantial emissions savings in the heavy-duty sector, without compromising the market’s ability to gravitate toward electrification as it becomes commercially viable and practical at scale.”
With the right alignment of policy incentives, transportation energy providers can facilitate a faster, more widespread, cost-effective transition to petroleum alternatives, including electricity, in the coming years.
Fuel retailers support the development of electric vehicle technologies and the associated refueling network but are concerned that the current state of heavy-duty electric vehicle charging technology renders the electrification timeline proposed under this rulemaking unachievable.
Renewable diesel and biodiesel represent the best opportunity for reducing carbon emissions from the commercial trucking sector for the foreseeable future. Establishing sensible tailpipe emissions in conjunction with strong incentives for renewable liquid fuels will encourage investments in currently scalable technologies that can reduce the carbon footprint of fuels that are in use today.
Policies that incorporate lifecycle GHG emissions which consider multiple technologies and ensure an accurate accounting of the lifecycle carbon intensity will facilitate continued investment in all decarbonization technologies, as opposed to only one.
Under EPA’s proposed rule, off-highway refueling locations will need dozens of fast chargers to support 25 percent of new long-haul trucks being electric by 2032. However, the charging capacity required at a single large truck stop would be equivalent to the electric load of a small town, according to a recent study from RMI. Fuel retailers remain unconvinced that electricity providers will be able to increase generation and transmission activity to service that load at scale within 10 years.
Fuel retailers have provided biofuels to reduce the carbon footprint of the nation’s ground transportation for more than a decade. Compared with petroleum-based diesel, biofuels reduce greenhouse gas emissions by up to 75 percent. Between 2011 and 2019, renewable diesel and biodiesel removed more than 18 million tons of carbon dioxide in California alone.
The fuel retailing sector has urged EPA to increase the blending mandate for biodiesel and renewable diesel under the Renewable Fuel Standard and encourage Congress to eliminate preferential treatment for sustainable aviation fuel, which uses the same feedstocks as renewable diesel but produces fewer emissions savings.
NATSO, SIGMA and NACS look forward to working with EPA to improve its GHG standards in a manner that is feasible and practicable.