Comment submitted by International Council on Clean Transportation (ICCT) (Part 3 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 third of four parts. Best regards, Peter Slowik on behalf of the International Council on Clean Transportation

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