Comment submitted by Ingevity Corporation
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Summary: Ingevity Corporation, a specialty chemicals and carbon materials manufacturer, supports the proposed two-model-year delay in the Tier 4 criteria pollutant standards. They argue that the delay is necessary because current BEV sales are insufficient to meet the proposed standards without unrealistic volumes, and they advocate for a longer three-year delay to provide manufacturers with adequate lead time.
Ingevity Corporation is pleased to submit the attached comments on the Revision of Tier 4 Criteria Pollutant Standards, Part 1: Amendments to Phase-In Schedule for Light-Duty and Medium-Duty Vehicles; EPA-HQ-OAR-2025-3297. We are submitting the attached comments via regulations.gov. See attached file.