Tier 4 Criteria Pollutant Standards, Part 1: Phase-In Schedule for Light-Duty and Medium-Duty Vehicles

A climate advocate is opposing the proposed postponement of Tier 4 emission standards for light and medium-duty vehicles. The commenter argues that delaying these standards will harm public health and increase air pollution in communities.

Morgan Clark opposes the proposed delay of the Tier 4 Criteria Pollutant Standards for light-duty and medium-duty vehicles. He argues that the delay lacks scientific modeling and will lead to significant public health risks, including premature deaths and increased healthcare costs, particularly in underserved communities.

The Illinois Environmental Protection Agency opposes the EPA's proposal to delay the phase-in schedule for Tier 4 emission standards for light-duty and medium-duty vehicles. The agency argues that the EPA's rationale regarding a declining electric vehicle market is unsupported by data in Illinois, which shows continued growth in EV adoption and infrastructure.

Ford Motor Company supports the EPA's proposed revisions to the Tier 4 criteria pollutant standards, specifically endorsing the addition of NMOG+NOx bins and the continued use of a Tier 3 Averaging, Banking, and Trading fleet. The company also advocates for regulatory flexibility regarding California OBD requirements and highlights technical challenges related to gasoline particulate filter back pressure.

Mary Ann and Frank Graffagnino, private citizens from Tucson, Arizona, strongly oppose the EPA's proposal to delay the implementation of Tier 4 air pollution standards for light- and medium-duty vehicles. They argue that delaying these standards will harm public health, particularly for children and vulnerable communities, and lead to increased healthcare costs and preventable deaths.

Dr. Wendy J. Bernstein, a community psychiatrist, opposes the proposed delay in implementing Tier 4 Criteria Pollutant Standards. She argues that delaying these standards will result in millions of vehicles continuing to emit harmful pollutants that damage human health, particularly for marginalized communities and children.

Barbara Allaire, a private citizen, supports the implementation of Tier 4 emissions standards for 2027 vehicle models without delay. She argues that delaying the standards will leave people with respiratory issues, such as herself, vulnerable to harmful particulate matter pollutants.

Atid Kimelman of the Natural Resources Defense Council (NRDC) is submitting an additional attachment in support of comments from environmental and public health organizations. The submission provides an emissions and health impacts analysis regarding the proposed revision of Tier 4 criteria pollutant standards for light-duty and medium-duty vehicles.

General Motors supports the EPA's proposed amendments to the Tier 4 Criteria Pollutant Standards for light- and medium-duty vehicles. The company argues that the proposal appropriately reflects market realities regarding EV sales and provides necessary flexibilities for emissions standards and certification procedures.

MEMA, a trade association representing vehicle suppliers, supports the EPA's proposal to delay certain Tier 4 NMOG+NOx requirements by one to two years to provide compliance flexibility for customers. However, they emphasize that such delays impact supplier investments and strongly advocate for maintaining the existing Tier 4 particulate matter standards.