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Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles

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Edison Electric Institute filings
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Edison Electric Institute filed 1 comment on this docket between Jul 11, 2023 and Jul 11, 2023. 112 other organizations filed here. The comment window closed 1119d ago.

What Edison Electric Institute filed (1)

Jul 11, 2023· Comment submitted by Edison Electric Institute (EEI)· EPA-HQ-OAR-2022-0829-0708

The Edison Electric Institute (EEI) appreciates the opportunity to provide the enclosed responses to the U.S. Environmental Protection Agency's (EPA's) proposed rule, Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles. 88 Fed. Reg. 29,184 (May 5, 2023)(Proposed Rule). EPA proposes new, more stringent emissions standards for both criteria pollutants and Greenhouse Gas (GHG) emissions for light- and medium-duty vehicles that would phase in over model years 2027 through 2032 under Title II of the Clean Air Act (CAA). EPA's Proposed Rule is of critical importance to EEI members as they continue to lead this clean energy transformation. A light- and medium-duty vehicle rule that supports the continued electrification of the transportation sector and leverages the existing investment in the electric system and the electric sector's ongoing clean energy transformation will provide both environmental benefits and send appropriate signals to support the continued buildout of infrastructure to support increased electrification. EEI is the association that represents all U.S. investor-owned electric companies. Our members provide electricity for about 235 million Americans and operate in all 50 states and the District of Columbia. As a whole, the electric power industry supports more than seven million jobs in communities across the United States. EEI's member companies are proud to provide customers resilient clean energy and to be leading the clean energy transformation. EPA also recently proposed a related rulemaking addressing heavy-duty vehicles, Greenhouse Gas Emissions Standards for Heavy-Duty Vehicles: Phase 3. 88 Fed. Reg. 25,926 (Apr. 27, 2023). EPA noted in that rulemaking and in this proposal that several stakeholders have raised concerns that "slow" growth in charging and refueling infrastructure can slow the growth of electric vehicle (EV) adoption, and that this may present "challenges" for vehicle manufacturers ability to comply with future EPA GHG standards. EEI's comments on the heavy-duty rulemaking addresses these concerns in depth, noting that these concerns can be addressed through deliberate effort and collaboration among electric companies, fleet operators, and stakeholders, including planning for increased demand, customer engagement, and fleet electrification. Electric companies can accommodate localized power needs at the pace of customer demand, provided appropriate customer engagement and enabling policies are in place. Those comments are attached here as Appendix A to ensure that feedback is also available to EPA in the docket for this Proposed Rule, since the development of electric vehicle charging infrastructure is relevant to both proposals. Electric companies over the last decade have sought regulatory approval from their state regulatory commissions to accelerate transportation electrification by reducing customer barriers to adoption. As of March 2023, electric transportation filings from 62 electric companies in 35 states and Washington, D.C. have totaled more than $4.2 billion. These investments broadly support the deployment of EV charging infrastructure at customer locations across a variety of use-cases, including single-family homes, multi-family dwellings, workplaces, and other businesses and public destinations. These programs can help reduce the cost that the customer would otherwise pay for the installation of EV charging infrastructure, which is a commonly cited barrier to EV charging infrastructure deployment. EEI and its members also are engaged with the federal government and states to help ensure federal dollars intended to accelerate electric transportation are efficiently and effectively deployed. The continued work of EEI member companies will help support the increased adoption of EVs projected by EPA in the Proposed Rule, and in the years beyond. Further, EEI has spearheaded the creation of the National Electric Highway Co…

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Abstract

Per EPA's authority under the Clean Air Act section 202(a), EPA will propose a comprehensive set of emissions standards for greenhouse gases and criteria pollutants for the light-duty vehicle sector as well as medium-duty vehicles (i.e., Class 2B and 3 vehicles). The standards will begin with model year 2027 light-duty vehicles, with stringency levels set at least through model year 2030. This action is also supported by the President's Executive Order 14037, titled Strengthening American Leadership in Clean Cars and Trucks.”

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Co-filers (112)

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