Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine Standards, Docket No. EPA-HQ-OAR-2019-0055, 85 Fed. Reg. 3306 (Jan. 21, 2020) PDF Free Download
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Tesla, Inc.
3500 Deer Creek Road, Palo Alto, CA 94304
p +650 681 5100 f +650 681 5101
19 February 2020
Submitted electronically via regulations.gov
U.S. Environmental Protection Agency
Office of Transportation Air Quality
Assessment and Standards Division
2000 Traverwood Drive
Ann Arbor, MI 48105
Docket ID No. EPA-HQ-OAR-2019-0055
RE: Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine Standards, Docket
No. EPA-HQ-OAR-2019-0055, 85 Fed. Reg. 3306 (Jan. 21, 2020)
Pursuant to the Environmental Protection Agency’s (EPA) notice, “Control of Air Pollution
from New Motor Vehicles: Heavy-Duty Engine Standards,” Docket No. EPA-HQ-OAR-2019-0055, 85
Fed. Reg. 3306 (Jan. 21, 2020), Tesla, Inc. (Tesla) submits the following comments on EPA’s Cleaner
Trucks Initiative.
Introduction
Tesla’s mission is to accelerate the world’s transition to sustainable energy. Moreover, Tesla
agrees with the scientific consensus that the world will not be able to solve the climate change crisis
without directly reducing air pollutant emissions—including greenhouse gases, NOx, and other
criteria air pollutants —from the transportation and power sectors.
To accomplish its mission, Tesla designs, develops, manufactures, and sells high-performance,
fully electric vehicles (EVs), solar energy products, and advanced battery storage systems. Tesla
currently produces and sells four EVs: The Model S sedan, the Model X sport utility vehicle, the
Model 3 sedan and the Model Y crossover. All Tesla vehicles offer high-performance and
functionality, attractive styling, and zero emissions.
In the U.S., Tesla conducts vehicle manufacturing and assembly operations at its factory in
Fremont, CA, and produces electric drive trains and manufacturers advanced battery packs, as well as
Tesla’s energy storage products, at its Gigafactory Nevada in Sparks, NV. It also builds and services
highly automated, high-volume manufacturing machinery at its facility in Brooklyn Park, MN, and
operates a tool and die facility in Grand Rapids, MI. Tesla produces solar energy and vehicle charging
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products at its Gigafactory New York in Buffalo, NY. Tesla continues to expand this domestic footprint
having recently acquired two advanced technology companies Maxwell Technologies, Inc.1 and Hibar
Systems.2
More specifically addressing the agency’s request for comment on reducing heavy-duty sector
NOx emissions, Tesla intends to bring to market its all-electric, Class 8 heavy duty semi by late-2020.
Widespread adoption of this vehicle can help mitigate the serious public health and welfare impacts
associated with heavy-duty truck emissions. Consistent, stringent, and enforceable performance
standards are necessary to accrue these benefits, to support continued innovation in the heavy-duty
sector, to stimulate domestic manufacturing job growth, and to ensure that vehicle makers invest in
a cleaner transportation future for America. Tesla strongly encourages EPA to be ambitious in
developing a NOx standard as stringency of the rules will dictate the efficacy of the policy.
The Need for Ambitious Heavy Duty NOx Standards
As the EPA recognizes:
NOx exposures over short periods can aggravate respiratory diseases,
particularly asthma, leading to respiratory symptoms (such as coughing, wheezing or
difficulty breathing), hospital admissions and visits to emergency rooms. Longer
exposures to elevated concentrations of NO2 may contribute to the development of
asthma and potentially increase susceptibility to respiratory infections. People with
asthma, as well as children and the elderly are generally at greater risk for the health
effects of NO2.3
Additionally, NOx reacts with other chemicals to form both particulate matter and ozone. Both of
these are also harmful when inhaled due to effects on the respiratory system.
According to the World Bank, traffic related air pollution and small particulate matter can
penetrate and lodge deep inside the lungs or enter the blood system. Ozone, another by-product of
vehicle tailpipes, is a major factor in causing and exacerbating asthma.4 The increasing impacts from
climate change are also accelerating the impacts of criteria air pollution like ground-level ozone.5 In
1 Acquired on May 16, 2019, Maxwell Technologies, Inc. is an energy storage and power delivery products
company.
2 Hibar Systems is a leader in precision manufacturing of small cell batteries.
3 EPA, Nitrogen Dioxide (NO2) Pollution, available at,
https://www.epa.gov/no2-pollution/basic-information-about-no2#What%20is%20NO2.
4 World Health Organization, “How Air Pollution Is Destroying Our Health,” available at,
https://www.who.int/air-pollution/news-and-events/how-air-pollution-is-destroying-our-health
5 See e.g., U.S. Global Change Research Program (USGCRP), “Fourth National Climate Assessment, Chapter 13:
Air Quality,” (Nov. 23, 2018), available at, https://nca2018.globalchange.gov/chapter/13/ (“Unless offset by
additional reductions of ozone precursor emissions, there is high confidence that climate change will increase
ozone levels over most of the United States, particularly over already polluted areas thereby worsening the
detrimental health and environmental effects due to ozone.”).
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2016, 5.5 million premature deaths worldwide (1 in every 10 deaths) were reported as attributable to
air pollution and cost the global economy more than $5 trillion in 2016.6 Closer to home, between
2000 and 2010, 141,900 to 331,200 of asthma cases in the United States were found to be attributable
to traffic related air pollution.7
The negative effects of air pollution disproportionately harm the most vulnerable populations,
including children, the elderly, and residents in low-income and disadvantaged communities.8 Indeed,
two-thirds of Americans who live near high-volume roads are people of color and the median
household income in these places is roughly 20% below the national average.9 Emissions from heavy-
duty diesel trucks are roughly the equivalent to those of 20 to 55 light-duty vehicles on the road.
Electrifying the heavy-duty sector will provide significant improvements in air quality and benefits to
all Americans through reduced CO2, NOx, and particulate matter emissions.
Anticipated Rapid Electrification of the Heavy Duty Market
Consistent with the mandate of Clean Air Act section 202(a)(3)(A), the Administrator should
determine that through electrification of the medium and heavy duty sectors NOx emission reductions
can be achieved to the greatest degree possible while reducing overall costs and improving vehicle
safety.
EPA suggests that heavy-duty vehicles will reach cost-parity with diesel in the early 2020s and
request perspectives on the market trajectory of electric powertrain technology from 2020 -2045. See
85 Fed. Reg. at 3319. Tesla believes that the adoption of electrification will occur much faster than the
EPA predicts and will be significantly represented in the marketplace before the agency adopts new
heavy duty NOx standards for 2027. While there are dozens of examples of zero-emission MD and HD
vehicle models developed by different manufacturers, Tesla has developed its Class 8 fully-electric
Semi truck10 which will start showing up on the country’s roads in late-2020. Tesla plans to produce
6 World Bank, “The Cost of Air Pollution: strengthening the economic case for action,” (Sept. 2016), available
at, http://documents.worldbank.org/curated/en/781521473177013155/The-cost-of-air-pollution-
strengthening-the-economic-case-for-action.
7 Alotaibi, et al., “Traffic related air pollution and the burden of childhood asthma in the contiguous United
States in 2000 and 2010,” Environment International (June 2019), available at,
https://www.sciencedirect.com/science/article/pii/S0160412018325388?via%3Dihub.
8 UN Environmental Programme, “Young and old, air pollution affects the most vulnerable,” (Oct. 16, 2018),
available at, https://www.unenvironment.org/news-and-stories/blogpost/young-and-old-air-pollution-affects-
most-vulnerable.
9 Union of Concerned Scientists, “Delivering Opportunity: How Electric Buses and Trucks Can Create Jobs and
Improve Public Health in California,” (May 2017), at 10, available at,
http://www.ucsusa.org/sites/default/files/attach/2016/10/UCS-Electric-Buses-Report.pdf.
10 Tesla, Tesla Semi, available at, https://www.tesla.com/semi.
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both a 300 mile version and a 500 mile version of its Semi,11 which should be able to accommodate
the 80% of Class 8 truck trips in the U.S. which are less than 250 miles. Indeed, Tesla’s Semi customers
already include many of the largest trucking companies in the country in nearly every major U.S.
industry.12
Tesla believes that the Class 8 tractor market in particular will electrify quickly given that the low
variable cost of driving on electricity will easily outweigh a slightly higher upfront purchase price. The
high annual mileage of these vehicles, which typically do over 100,000 miles per year, means that the
variable costs of driving are notably more important than the upfront cost. Fully loaded at 80,000
pounds, the Tesla Semi will have an efficiency of less than 2 kilowatt-hours (kWh) per mile. Assuming
a relatively conservative electricity cost of $0.10/kWh, that comes to less than $0.20/mile in fuel cost.
Compared with the variable fuel cost of diesel trucks at roughly $0.36/mile, assuming $2.50/gallon of
diesel and an efficiency of 7 miles per gallon, electric Class 8 vehicles offer very compelling savings for
trucking companies. Out of a typical all-in cost of roughly $1.50/mile, a savings of $0.16/mile is about
10%, which is a huge number in the very thin margin trucking industry.
Given the low cost of driving on electricity and thus the strong business case for adopting all-
electric tractors like the Tesla Semi, we anticipate that the Class 7-8 tractor group penetration rate to
approach a fleet zero-emission vehicle (ZEV) adoption rate of 20% by 2030. Commercial buyers in the
MD/HD vehicle segment are very economically rationale and will quickly adopt electric vehicles as
soon as the superior total cost of ownership of electric trucks like the Tesla Semi is apparent.
Benefits of Electrification
Throughout the proposal, EPA solicits responses to the technical status and performance of a
number of emission control technologies that may reduce NOx emissions from diesel and gasoline
engines, such as thermal management of catalysts, durability of catalysts, closed crank case, fuel
quality. See 85 Fed. Reg. at 3312 -3318. All of these technologies are not relevant to electric
powertrain vehicles. Accordingly, at the outset, EPA should recognize that one inherent benefit to
heavy duty electrification is a significant reduction in the regulatory complexity and enforcement
burden compared to that required of EPA to police the NOx emissions performance from fossil-fuel
engine technology.13
11 Id.
12 Business Insider, “Companies that Ordered Tesla Semi,” (Dec. 2017), available at,
https://www.businessinsider.com/companies-that-ordered-tesla-semi-2017-12.
13 As described below, electrification of the heavy duty sector could be recognized as achieving the greatest
degree of NOx emission reduction through the application of a technology that is both cost-effective and
provides greater safety. See 42 U.S.C. § 7521(a)(3)(A)(i).
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1. Total Cost of Ownership
Electrifying the heavy duty sector will have additional benefits including reducing total cost of
ownership (TCO). TCO is a major factor in determining the market uptake of electric trucks.
Estimates are that the total cost of owning an electric truck will be less than that of a diesel truck
and place the difference at about $0.15-$0.25 per mile.14
The biggest immediate cost-advantage to electrification comes from savings in energy costs:
fully loaded, the Tesla Semi consumes less than two kilowatt-hours of energy per mile and is capable
of 500 miles of range at GVW and highway speed, accommodating a wide range of shipping
applications given that nearly 80% of freight in the U.S. is moved less than 250 miles.15 Coupled with
the low and stable nature of electricity prices – which average $0.12/kWh in the U.S. and can be
significantly less for commercial and industrial users, falling to almost nothing when combined with
local solar generation and storage – owners can expect to gain $200,000 or more in savings over a
million miles based on fuel costs alone.16
2. Improved Vehicle Safety
Electric trucks can offer substantial safety and performance improvements over conventional
trucks in a number of ways. First, the powertrain is substantially less complex, which reduces
breakdowns and misshifts that lead to traffic collisions – there is no engine, driveline, exhaust
aftertreatment, or transmission. Further, electric motors have substantially more precise torque
control leading to more speed control and electronic stability control by allowing multiple wheels to
control power independently of each other and helping the truck move in the direction the driver
intends, thus reducing potential for rollover and jackknifing. Finally, the regenerative breaking in
electric vehicles means that the vehicles rarely have to use their breaks, decreasing the risk of
“runaway trucks” on high-grade roads. Given their increased safety and performance, electric trucks
should be able to help trucking companies with their perennial problem of driver retention. The
14 See e.g., GTG Technology Group, “How the Total Cost of Ownership of Electric Trucks Influences Fleet
Decisions,” available at https://gtgtechnologygroup.com/how-the-total-cost-of-ownership-of-electric-trucks-
influences-fleet-decisions/; See also, CNBC, “Tesla Semi could save money over diesels within 2 years of
ownership,” (Jan. 11, 2018), available at, https://www.cnbc.com/2018/01/11/tesla-semi-could-save-money-
over-diesels-within-2-years-of-ownership.html (estimating electric trucks would recoup their extra costs over
diesels and begin saving money in about 2.1 years); See also, CleanTechnica, “Why Truck Fleet Buyers Are Keen
On The Tesla Semi (Calculations),” (Dec. 17, 2017), available at, https://cleantechnica.com/2017/12/17/truck-
fleet-buyers-keen-tesla-semi-calculations/ (estimating that the Tesla Semi will saving, conservatively, 18¢/mile
or $18,000/year in fuel costs compared to a diesel truck).
15 See Tesla, Tesla Press Information, Semi, available at, http://www.tesla.com/presskit
16 Id.
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industry has a driver retention rate of less than a year, meaning truck drivers typically switch
companies more than once a year, so anything that can keep good drivers happy is of interest to
trucking companies. In fact, some of Tesla’s Semi customers have told Tesla that they have a waiting
list amongst their best drivers for who will drive the first Tesla Semis that their company
The Tesla Semi’s all-electric architecture is designed to have a higher safety standard than any
other heavy-duty truck on the market, with a reinforced battery that shields the Semi from impact
and gives it an exceptionally low center of gravity. Its windshield is made of impact resistant glass.
Jackknifing is prevented due to the Semi's onboard sensors that detect instability and react with
positive or negative torque to each wheel while independently actuating all brakes. The surround
cameras aid object detection and minimize blind spots, automatically alerting the driver to safety
hazards and obstacles. With Enhanced Autopilot, the Tesla Semi features Automatic Emergency
Braking, Automatic Lane Keeping, Lane Departure Warning and event recording. Additionally,
Enhanced Autopilot helps avoid collisions, a centered driver position provides maximum visibility
and control, and a low center of gravity offers rollover protection.
The Role of Incentives
EPA also seeks comments on the role of incentives in driving early deployment of advanced
powertrains. See 85 Fed. Reg. at 3329. Given that the purchasing decisions related to heavy-duty
vehicles are almost entirely cost-based, any incentives that lower the cost of deploying EV heavy-
duty vehicles will help to drive adoption. As Tesla has heard from some of its Semi customers, the
cost of a EV not only has to match the cost of a traditional vehicle but it has to be better than the
cost of a traditional vehicle in order for trucking companies to justify taking any risk by trying a new
technology, even if that technology has been proven for other segments, such as light-duty vehicles.
Establishing performance based NOx standards that reward manufacturers of zero emission heavy
duty vehicles help drive this equation.
Tesla encourages EPA to adopt early action crediting for the CTI program for the four years
proceeding implementation and application of a new NOx standard that starts in MY 2027. Early
action crediting incentivizes and rewards actual EV heavy duty deployment and sales, thus furthering
the EPA’s goal of increasing and accelerating the penetration levels of NOx emission-reducing
technologies.
Similarly, the ability to earn, bank, and trade early action NOx emission credits (credits earned
for delivering vehicles prior to the initial compliance year) provides heavy duty manufacturers an
incentive to pull forward deployment of electric powertrains before the initial compliance year. It
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allows each manufacturer to have planning assurance that compliance with a stringent NOx emission
standard may be achieved in the initial compliance year. Additionally, the early deployment also
pulls forward the investment in charging and other infrastructure deployment that will support
electrification of the heavy duty sector.
Conclusion
As provided above, Tesla supports the EPA developing an additional heavy duty NOx
performance standard that both effectively controls and reduces NOx emissions that endanger the
public health and welfare and incentivizes the rapid deployment of the best heavy duty pollution
control technologies.
Respectfully submitted,
Joseph Mendelson III
Senior Counsel
