Comment submitted by International Council on Clean Transportation (ICCT) (Part 2 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 already have the technology and lead time to comply, and that the EPA's cost estimates for emission controls are significantly 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 second of four parts.
Best regards,
Peter Slowik on behalf of the International Council on Clean Transportation
Attachments
- Comment (PDF)
- 23a Passive soot regeneration observations on a GPF equipped vehicle for PM exhaust emission control (PDF)
- 23b - Evaluation of uncoated GPF performance for US EPA MY27 Particulate Mass Emissions Regulation (PDF)
- 23c - Catalyzed GPF performance from fresh to full useful life (PDF)
- 23d - Improved coated GPF for China 7 and US Tier 4 legislations (PDF)
- 23e - Next generations of GPF for catalyzed applications (PDF)
- 24 - PGM prices and trading Johnson Matthey
- 25a - Nationwide and regional PM2.5 related air quality health benefits from the removal of energy-related emissions in the United States (PDF)
- 25b and 27b - Comprehensive review of health impacts of the exposure to NOx CO and PM (PDF)
- 25c - Air pollution control strategies directly limiting national health damages in the US (PDF)
- 26a - Long term exposure to PM2.5 and ozone and hospital admissions of medicare participations in the SE US (PDF)
- 26b - Source sector and fuel contributions to ambient PM2.5 and attributable mortality across multiple spatial scales (PDF)
- 28 and 29 and 33 and 36 - PM emissions from US gasoline LDVs and trucks ICCT 2023 (PDF)
- 30 and 31 - Comparison of GDI and PFI vehicle emissions
- 32 - Ultrafine PM and the benefits of reducing PN in the US (PDF)
- 37 - ICCT comments on EPA Multi-Pollutant Standards for MY 2027 and later light- and medium-duty vehicles vF (PDF)
- 38 - Light Duty Electric Drive Vehicles Monthly Sales Updates ANL (PDF)
- 39 - One Big Beautiful Act - Congress texts (PDF)
- 40a - Revision of Tier 4 DRIA - USEPA (PDF)
- 40b and 109 - Battery Electric Vehicle Market Share Analysis - USEPA (PDF)