Comment submitted by National Automobile Dealers Association (NADA)

Summary: The National Automobile Dealers Association (NADA) supports the EPA's proposal to extend Tier 3 standards and delay the phase-in of stricter Tier 4 standards for light- and medium-duty vehicles. They argue that the EPA's previous assumptions regarding rapid electric vehicle (EV) adoption were unrealistic and that the delay is necessary to account for current market realities, lower consumer demand for EVs, and the resulting compliance burdens on internal combustion engine vehicles.