Comment submitted by Prime Mover Institute (PMI)

Summary: The Prime Mover Institute supports the EPA's proposal to delay the implementation of Tier 4 criteria-pollutant standards for light- and medium-duty vehicles due to the collapse of previous electric vehicle market projections. However, the Institute argues that the proposed two-year delay is insufficient and urges the EPA to extend the Tier 3 bridge through model year 2029 to provide manufacturers with adequate lead time.