Testimony in Favor of NJDEP NOx Omnibus Diesel Pollution Rule

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Good morning, my name is Doug O’Malley, Director of Environment New Jersey, representing more than 80,000 citizen members and activists. We strongly support the Low NOx Omnibus rule and urge its adoption as quickly as possible.

It shouldn’t need to be said, but diesel exhaust is a major component of particulate matter air pollution, which has been linked to asthma, lung diseases and heart disease. It also has been studied as a cause of increased risk of death from heart attacks and stroke, premature birth and adverse pregnancy outcomes. Additionally, its toxic gases and vapors are linked to cancer and can affect cognition and learning.

That being said, it is critical to understand the impacts of diesel pollution upon our communities, the impacts of diesel truck traffic pollutants on community health and local air quality. I will cite two separate examples, one hyper local in the port city of Elizabeth and the other more global research on the number of air pollutants that infiltrate the passenger car cabin on the New Jersey Turnpike. Both example are deeply indebted to the research of Dr. Robert Laumbach from Rutgers EOHSI.

For decades, heavy diesel trucks taking cargo from container ships at the Port Newark–Elizabeth Marine Terminal used a residential street in Elizabeth to avoid the tolls between Exits 13 and 13A on the New Jersey Turnpike. The trucks also routinely idled on the street awaiting their next load.

Their route along the narrow, two-lane First Street took them past many homes, two schools, a childcare center and an athletic field, prompting concern that the community’s rising rates of asthma were connected to the diesel exhaust.

In 2014, Dr. Robert Laumbach, director of community outreach for Rutgers Center for Environmental Exposures and Disease (CEED) and the Environmental and Occupational Health Sciences Institute (EOHSI), enlisted residents as “citizen-researchers” to work with his team and count trucks and measure particulate matter air pollutants between 8 a.m. and 10 a.m. on a typical weekday morning when children walked to school. Their goal was to create a profile of the air pollution levels on First Street.

After Laumbach and community leaders presented the collected data to local officials, the City of Elizabeth’s council passed an ordinance in 2017 to restrict traffic on First Street to vehicles under four tons, essentially banning tractor-trailers.

Four years after the first truck count, Laumbach and his researchers partnered again with residents for a post-ordinance assessment on truck count and diesel emissions. They found an 86 percent reduction in truck traffic and an 80 percent reduction in black carbon and ultrafine particle counts.

That result obviously can’t be replicated across the state, as we can’t ban truck traffic from all local, state and interstate roads. But earlier research conducted by Dr. Laumbach illuminated that the very simple act of driving on the New Jersey Turnpike created real and immediate public health impacts with the air quality reductions in the cabin. Dr. Laumbach conducted research from 2007 to 2014 where study participants drove in a car with closed windows and open vents during morning rush hours on 190 days. Real-time measurements of air pollutants were captured, and were elevated that you would find on normal local roads.? Median in-cabin concentrations were 11 μg/m3 PM2.5, 40 000 particles/cm3, 0.3 ppm CO, 4 μg/m3 BC, and 20.6 ppb NO2. In-cabin concentrations on the NJ Turnpike were higher than in-cabin concentrations on local roads by a factor of 1.4 for PM2.5, 3.5 for PNC, 1.0 for CO, and 4 for BC. Median concentrations of NO2 for full rides were 2.4 times higher than ambient concentrations. So what’s different on the Turnpike? Certainly more cars, but clearly many more trucks.

Note, these examples are not isolated: the New Jersey medium and heavy duty fleet includes nearly 423,000 vehicles that annually travel more than 6.2 billion miles and consume 653 million gallons of petroleum-based fuels. In New Jersey, medium and heavy duty vehicles are currently responsible for an estimated 7.6 million metric tons (MMT) of greenhouse gas (GHG) emissions annually—approximately 20 percent of all GHGs from the on-road vehicle fleet.

In New Jersey, medium and heavy duty vehicles are also responsible for 44 percent of the nitrogen oxide (NOx) and 39 percent of the particulate matter (PM 2.5) emitted by on-road vehicles, both of which contribute to poor air quality and resulting negative health impacts in many urban areas, including low-income and disadvantaged communities that are often disproportionately affected by emissions from freight movement due to the proximity of transportation infrastructure to the communities.

This includes all on-road vehicles registered in New Jersey with greater than 8,501 pounds gross vehicle weight, encompassing vehicle weight classes from Class 2b though Class 8. This is a diverse set of mostly commercial vehicles that includes heavy-duty pickups; school and shuttle buses; sanitation, construction, and other types of work trucks; and freight trucks ranging from local delivery vans to tractor-trailers that weigh up to 80,000 pounds when loaded.

Greater emissions from diesel trucks and buses emit higher levels of air pollution, which can lead to even greater health concerns in populations more directly exposed to diesel emissions. Communities located adjacent to ports and related goods-movement infrastructure (i.e. warehouses, logistics centers, rail yards, etc.) experience higher levels of truck traffic, both from surrounding thruways and on local streets, which exacerbates health concerns. Since these emissions are local in their effects, policies to reduce transportation emissions from medium- and heavy-duty vehicles can improve the health and well-being of communities in urban areas or around transportation corridors, which are often home to people of color, low-income residents, or those who are otherwise vulnerable or disadvantaged.

To ensure reductions in those communities, program requirements on truck manufacturers, such as the Advanced Clean Truck and Heavy-Duty Omnibus Rules, would need to be accompanied by additional policies designed specifically with these communities in mind. The cumulative NOx reductions from the NOx Omnibus Rule are estimated at 94,000 Metric Tons over the next 30 years, and the monetized value of cumulative net public health benefits is close to $2.7 billion.

For all of these reasons, we encourage the NJDEP to adopt the Low NOx Omnibus rule as quickly as possible.