Comment submitted by National Association of Manufacturers (NAM)

Summary: The National Association of Manufacturers (NAM) supports the EPA's proposal to delay the Tier 4 criteria pollutant standards compliance deadline for light- and medium-duty vehicles by two years. They argue that the delay is necessary because previous EV adoption projections were over-optimistic and that the agency needs more time to ensure the standards are achievable and legally sound under the "major questions" doctrine.