Comment submitted by New York State Department of Environmental Conservation

Summary: The New York State Department of Environmental Conservation (DEC) opposes the EPA's proposal to delay the phase-in of Tier 4 emission standards for light- and medium-duty vehicles. The agency argues that the standards are attainable, that the EPA failed to account for the public health and environmental costs of the delay, and that the proposal unfairly prioritizes automotive industry savings over consumer and health benefits.