Filed on regulations.gov — full text not in the inline record.
Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles (Phase II)
Activity
Environmental Defense Fund filed 25 comments on this docket between Oct 8, 2015 and Feb 5, 2020. 132 other organizations filed here. The comment window closed 3126d ago.
What Environmental Defense Fund filed (25+)
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Environmental Defense Fund and the Environmental Law & Policy Center submit the attached documents in support of our public comment regarding EPA's proposed rule, "Repeal of Emission Requirements for Glider Vehicles, Glider Engines, and Glider Kits," in Docket No. EPA-HQ-OAR-2014-0827. In addition to the attached documents, commenters request that the following document -- which cannot be attached due to file size -- be included in the administrative record. EPA, Schools Near Roads Analysis for the Tier 3 NPRM docket, available at https://www.regulations.gov/document?D=EPA-HQ-OAR-2011-0135-0488
Environmental Defense Fund and the Environmental Law & Policy Center submit the attached documents in support of our public comment regarding EPA's proposed rule, "Repeal of Emission Requirements for Glider Vehicles, Glider Engines, and Glider Kits," in Docket No. EPA-HQ-OAR-2014-0827.
Environmental Defense Fund and the Environmental Law & Policy Center submit the attached documents in support of our public comment regarding EPA's proposed rule, "Repeal of Emission Requirements for Glider Vehicles, Glider Engines, and Glider Kits," in Docket No. EPA-HQ-OAR-2014-0827.
Environmental Defense Fund and the Environmental Law & Policy Center submit the attached documents in support of our public comment regarding EPA's proposed rule, "Repeal of Emission Requirements for Glider Vehicles, Glider Engines, and Glider Kits," in Docket No. EPA-HQ-OAR-2014-0827.
Environmental Defense Fund and the Environmental Law & Policy Center submit the attached documents in support of our public comment regarding EPA's proposed rule, "Repeal of Emission Requirements for Glider Vehicles, Glider Engines, and Glider Kits," in Docket No. EPA-HQ-OAR-2014-0827. In addition to the attached documents, commenters request that the following study -- which cannot be uploaded due to the large file size -- be admitted into the administrative record: NTP Toxicology and Carcinogenesis Studies of 1,3-Butadiene (CAS No. 106-99-0) in B6C3F1 Mice (Inhalation Studies), available at https://www.ncbi.nlm.nih.gov/pubmed/12616297
Environmental Defense Fund and the Environmental Law & Policy Center submit the attached documents in support of our public comment regarding EPA's proposed rule, "Repeal of Emission Requirements for Glider Vehicles, Glider Engines, and Glider Kits," in Docket No. EPA-HQ-OAR-2014-0827.
To Whom It May Concern: Attached are the signatures of 50,221 Environmental Defense Fund supporters from across the country who have submitted comments opposing EPA's proposal to repeal emission requirements for glider vehicles, glider engines, and glider kits. The comment they each submitted reads: "I'm writing today with great concern over EPA's proposal to reopen the 'glider truck' loophole. Doing so would give an unfair competitive advantage to these super-polluting trucks over trucks that achieve clean air standards. Freight truck leaders invested in and now sell cleaner freight trucks and engines. Reopening this loophole could put their prudent investments--and their employees' jobs--at risk, which is why numerous trucking industry leaders have publicly opposed the unfair competition and pollution that would be allowed by a glider kit loophole. But this policy wouldn't just unfairly pick winners and losers in the industry. It would put Americans' lives at risk. According to EPA estimates, if the glider truck loophole were left open until 2021, glider vehicles would result in as many as 6,400 premature deaths. These trucks emit as much as 40 times the pollution of modern engines, contributing to a host of respiratory problems that increase our national healthcare costs and put our lives at risk. Reopening this loophole takes America in the wrong direction. Please reconsider this dangerous decision." Please let me know if you have any questions or concerns about this submission. Thank you for your consideration, Heather Shelby Manager, Grassroots Activism & Engagement Environmental Defense Fund hshelby@edf.org (202) 572 3242
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Attached please find comments from Environmental Defense Fund, Environmental Law and Policy Center, and WE ACT for Environmental Justice. This comment includes four attachments: Appendices A, B, C, D, and E. We have separately submitted additional documents in support of these comments.
Environmental Defense Fund, the Environmental Law & Policy Center, and WE ACT for Environmental Justice submit the attached documents in support of our public comment regarding EPA's proposed rule, "Repeal of Emission Requirements for Glider Vehicles, Glider Engines, and Glider Kits," in Docket No. EPA-HQ-OAR-2014-0827.
Filed on regulations.gov — full text not in the inline record.
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Please find attached comments from Environmental Defense Fund.
Please consider the attached comments on the use of the Social Cost of Methane and the Social Cost of Carbon to value the benefits of the proposed standards, submitted jointly by EDF, NRDC, Union of Concerned Scientists, and the Institute for Policy Integrity. Our organizations have also independently and separately submitted additional comments on the substance of the proposed standards.
Please see attached comments submitted by Environmental Defense Fund.
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Abstract
EPA and NHTSA, on behalf of the Department of Transportation, are each proposing rules to establish a comprehensive Heavy-Duty National Program (Phase II) that will reduce greenhouse gas emissions and fuel consumption for onroad heavy-duty vehicles, responding to the President’s directive on March 31, 2014, to take coordinated steps to produce a new generation of clean vehicles. NHTSA’s proposed fuel consumption standards and EPA’s proposed carbon dioxide (CO2) emissions standards are tailored to each of three regulatory categories of heavy-duty vehicles: Combination Tractors; Heavyduty Pickup Trucks and Vans; and Vocational Vehicles. The rules include separate standards for the engines that power combination tractors and vocational vehicles. Certain rules are exclusive to the EPA program. These include EPA’s proposed hydrofluorocarbon standards to control leakage from air conditioning systems in combination tractors, and pickup trucks and vans. These also include EPA’s proposed nitrousoxide (N2O) and methane (CH4) emissions standards that apply to all heavy-duty engines, pickup trucks and vans.
View on regulations.gov →Co-filers (132)
See everyone who commented →- Environmental Defense FundTHIS ORG25 filings · confidence 97%
- American Lung Associationtrade assoc.6 filings · confidence 85%
- National Automobile Dealers Associationtrade assoc.5 filings · confidence 97%
- Manufacturers of Emission Controls Associationtrade assoc.4 filings · confidence 85%
- Truck Trailer Manufacturers Associationtrade assoc.4 filings · confidence 85%
- Alliance of Automobile Manufacturerstrade assoc.3 filings · confidence 97%
- American Council for an Energy-Efficient Economytrade assoc.3 filings · confidence 85%
- Clean Transportation Technologies & Solutionsunverified attribution3 filings · confidence 70%
- Controlled Power Technologies Inc.unverified attribution3 filings · confidence 70%
- International Council on Clean Transportationtrade assoc.3 filings · confidence 85%
- Natural Resources Defense Council (NRDC)trade assoc.3 filings · confidence 97%
- Rubber Manufacturers Associationtrade assoc.3 filings · confidence 97%
- the Motor & Equipment Manufacturers Associationtrade assoc.3 filings · confidence 85%
- Truck and Engine Manufacturers Associationtrade assoc.3 filings · confidence 85%
- American Automotive Policy Counciltrade assoc.2 filings · confidence 85%
- American Chemistry Counciltrade assoc.2 filings · confidence 97%
- Arnold & Porter Kaye Scholer LLP on behalf of Truck Trailer Manufacturers Associationtrade assoc.2 filings · confidence 85%
- Caterpillar Inc.unverified attribution2 filings · confidence 70%
- Center for Biological Diversity2 filings · confidence 97%
- Cummins Inc.unverified attribution2 filings · confidence 70%
- Daimler Trucks North America LLCunverified attribution2 filings · confidence 70%
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- Lubrizol Corporationunverified attribution2 filings · confidence 70%
- National Association of Clean Air Agenciestrade assoc.2 filings · confidence 85%
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- Alliance of Idle Mitigation Technologiestrade assoc.1 filing · confidence 85%
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- American Bus Associationtrade assoc.1 filing · confidence 97%
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- National Propane Gas Associationtrade assoc.1 filing · confidence 97%
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