Comment submitted by International Council on Clean Transportation (ICCT) (Part 1 of 4)
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Summary: The International Council on Clean Transportation (ICCT) opposes the EPA's proposed delay of the Tier 4 Criteria Pollutant Standards for light-duty and medium-duty vehicles. They argue that automakers have sufficient lead time and technology to comply with the existing 2024 standards, and they contend that the EPA's cost estimates for emission controls are overstated.
Dear EPA staff,
Please find the International Council on Clean Transportation's comments on the EPA’s proposed Tier 4 Criteria Pollutant Standards, Part 1: Phase-in Schedule for Light-Duty and Medium-Duty Vehicles, attached. Our comments are uploaded with references and thus submitted in multiple parts. This is the first of four parts.
Best regards,
Peter Slowik on behalf of the International Council on Clean Transportation
Attachments
- Comment (PDF)
- 1 CARB New vehicle and engine certification EO LDVs (PDF)
- 1 CARB New vehicle and engine certification EO LDVs (XLSX)
- 2 - US EPA Information about Family Naming Conventions for Vehicles and Engines (PDF)
- 3 - Application of low mass corning FLORA substrates for cold start emissions 2020-01-0652 (PDF)
- 5 and 11 and 13 - MECA LDV Technologies Vehicle Manufacturer Status at the Transition to Tier 4 (PDF)
- 14b - JD Power-GlobalData Forecast June 2026 - JD Power
- 15a - Hyundai’s Hybrid Sales Surge
- 15b - Kia Hybrid Sales are up 179 Percent (PDF)
- Blank Pages. 15c - Honda doubles down on hybrids with 15 new models planned by 2030 (PDF)
- 15d - Ford Restructures EV Plans with Hybrid Expansion Extended Range Technology (PDF)
- 15e - All-New 2027 Nissan Rogue Hybrid e-POWER Coming Late 2026 (PDF)
- 15f - Electrification made easy - Volkswagen presents new full hybrid for Golf and T-Roc - Volkswagen Newsroom
- 16 -Estimated Cost of Emission Reduction Technologies for LDVs Part 1 gasoline
- 19a - Estimated Cost of GPFs ICCT 2011
- 19b - What EPAs New Multi-pollutant Emissions Proposal Means for PM Emissions and GPFs ICCT 2023
- 20a and 21 - Development of High Performance Coated GPF - Technical Paper (PDF)
- 20b -Improved Coated Gasoline Particulate Filters for China 7 and US Tier 4 Legislations - Technical Paper (PDF)
- 22 - Next Generations of Gasoline Particulate Filters for Catalyzed Applications - Technical Paper (PDF)