Environmental Impact Statement for New Medium and Heavy Duty Vehicle Fuel Efficiency Improvement Program Standard

Dear Administrator Friedman, On behalf of Environmental Defense Fund (EDF), a leading a non-profit, non-partisan, non-governmental environmental organization that combines law, policy, science, and economics to find solutions to todays most pressing environmental problems, I am pleased to submit the attached comments in response to the NHTSA notice of intent to prepare an environmental impact statement on the Phase 2 Medium- and Heavy-Duty Vehicle Fuel Efficiency Improvement Program Standards. I am also attaching recommendations EDF made along with NRDC, UCS and the Institute for Policy Integrity to OMB for its Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis under Executive Order No. 12,866. We refer to these recommendations in our specific comments about the phase 2 rule and hereby incorporate them into these comments. Phase 2 standards should reduce new truck fuel consumption on average by at least 40 percent for the entire fleet by 2025, compared to 2010 trucks. Such standards are technically feasible, economically beneficial and fundamentally required to alter the upwards path of medium- and heavy-duty GHG emissions and fuel consumption. Respectfully, Jason Mathers Senior Manager Environmental Defense Fund 18 Tremont St Boston, MA 02108 617 406 1806 edf.org/freight