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Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles (Phase II)

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Last modified
Apr 16, 2024
Comment window
closed 3126d ago
Environmental Protection Network (EPN) filings
2

Activity

Environmental Protection Network (EPN) filed 2 comments on this docket between Jan 5, 2018 and Jan 5, 2018. 132 other organizations filed here. The comment window closed 3126d ago.

What Environmental Protection Network (EPN) filed (2)

Jan 5, 2018· Comment submitted by Ruth Greenspan Bell, President of the Board, Environmental Protection Network· EPA-HQ-OAR-2014-0827-4734

updating previously filed comments with a PDF attachment (content is identical).

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Jan 5, 2018· Comment submitted by Ruth Greenspan Bell, President of the Board, Environmental Protection Network· EPA-HQ-OAR-2014-0827-4732

See attached file(s) The agency proposes to repeal the 2016 final rule requiring most glider vehicle engines to be certified to the year of the vehicle. It, thereby, would allow manufacture and sale of these high-polluting vehicles and engines essentially without constraint. The proposal literally ignores all public health and welfare ramifications. These ramifications are there is no other word horrendous. The proposal would allow unlimited deployment of what Congressman Raskin accurately called the oldest, dirtiest, and deadliest diesel engines engines lacking essentially any more than rudimentary control of PM or NOx emissions because they predate model year 2002. The proposal would create a tilted playing field, heavily favoring glider manufacturers, strongly pushing legitimate manufacturers and dealers to also build and sell glider vehicles with high-polluting engines. Under the proposal there is the possibility that all or a high percentage of tractor-trailers could be a glider with a filthy engine. This means the emissions and risk estimates from the 2016 Final Rule 700-1600 premature mortalities for every model year at current glider vehicle production rates could be significantly understated. Response to Comment Document (EPA-420-R-16-901 (August, 2016)) (RTC) pp. 1880, 1962. The implications of the proposal also have the potential to eliminate the effectiveness of all Title 2 vehicular emission standards. Under the interpretation announced in the Proposal, all a manufacturer would have to do is install one or more used parts or components on an otherwise new motor vehicle, and the vehicle would no longer be subject to Title 2 standards. The agency nowhere discussed this or any other programmatic impact of its proposed interpretation. The absurdity of this result and its horrific emissions impact highlight the flaws in the agencys proposal. The agencys proposal is blithely oblivious to these deleterious consequences. It rests entirely on a reinterpretation of a portion of EPAs conclusion on its authority under section 202(a)(1) to set standards for glider vehicles, kits, and engines, as set out in the 2016 Final Rule. It is no exaggeration to say that the statutory interpretation advanced in the proposal is devoid of any legal merit. Moreover, that reinterpretation of section 202(a)(1)s authority would not justify repeal even if it were valid. Finally, even though the agency offers its reinterpretation as an exercise of the agencys Chevron step 2 authority to change its approach, the proposal offers absolutely no factual, technical, or policy analysis in support of that change. These defects are fundamental and cannot be cured by a response in the agencys final action. If the agency wishes to proceed with this initiative, it must issue a new proposal addressing the defects set out below and invite public comment on it.

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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.

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Co-filers (132)

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Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles (Phase II) (EPA) — Environmental Protection Network (EPN) | OpenPolis