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Comments to EPA on Proposed Heavy-Duty Vehicle Emission Standards

In March 2022, EPA proposed standards to regulate emissions of nitrogen oxides and particulate matter from heavy-duty vehicles beginning with Model Year 2027. Policy Integrity submitted comments recommending that EPA strengthen these crucial standards in order to fulfill EPA's statutory duty to set standards "reflecting the greatest degree of emission reduction achievable." We also made a number of recommendations designed to ensure that EPA is properly comparing regulatory alternatives and accounting for the benefits of strong regulation. Specifically, we recommend that EPA:

  • Revise and expand its distributional analysis to better reflect the impacts of the Proposed Rule on vulnerable subpopulations;
  • Clarify its economic assumptions to better explain its choices in methodology;
  • Consider revising its estimation of sales impacts and fleet turnover;
  • Clarify that any employment impacts are likely small and short-lived; and
  • Quantify and monetize the benefits of reducing greenhouse gas emissions.