On Friday, May 13, PMTA submitted comments to the Environmental Protection Agency (EPA) on its proposed regulation of emissions for heavy-duty trucks. For more information on the rulemaking, please see Transport Topics article.

Comments on the regulation are due on Monday, May 16, and all PMTA are encouraged to submit comments. 

To do so, go to https://www.regulations.gov; scroll down to “What’s Trending”, click on “Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine and Vehicle Standards”, click on the “Comment” button; then upload your comments and submit.  

Filed via Federal eRulemaking Portal:  https://www.regulations.gov

EPA Docket Center

WJC West Building, Room 3334

1301 Constitution Avenue NW

Washington, DC 20004

RE:  Comments on EPA “Control of Air Pollution From New Motor Vehicles: Heavy-Duty Engine and Vehicle Standards, Proposed Rule,” Docket EPA-HQ-OAR-2019-0055

To Whom It May Concern:

As EPA develops the final rule on tailpipe emissions from heavy-duty trucks as part of the "Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine and Vehicle Standards," we file these comments in support of a single national low-NOx rule that is technologically feasible, protects American jobs, and is not disruptive to the nation’s economy or supply chains. An approach such as Option 1 that cannot be achieved by all classes of trucks under widely-varied business models will cause significant uncertainty amongst fleets and will result in purchasing new trucks before new standards are implemented.  This pre-buy/low-buy/no-buy scenario would jeopardize thousands of good-paying jobs and slow environmental success.  To be effective, the final rule must result in new trucks that are: 

Affordable.  If trucking companies choose not to purchase new trucks due to cost or reliability concerns, older trucks will stay on the road longer and environment goals will not be achieved; 

Durable.  New, more expensive trucks are not purchased to sit in repair bays. Trucks are unproductive pieces of equipment unless they are moving freight; 

Safe.  Safety is a top priority in every trucking operation. Putting off the purchase of the newest equipment will delay the use of the latest safety technologies; and

Cleaner.  An unworkable rule will delay fleet turnover and impede environmental progress.

Fleets don’t make trucks – they are consumers that buy trucks. While this rule is directed at manufacturers, it is trucking companies buying new technologies that determine the success or failure in the implementation of every trucking emission regulation. Fleets remain extremely sensitive to the many difficulties involved in running a trucking company – a matter that is especially significant to the 97 percent of fleets classified as small businesses.

Finally, we believe it important to point out that 34 business days is a wholly inadequate public comment period for a highly technical, 475-page proposed regulation, especially for these small businesses who struggle every day to manage the challenges of a supply chain crisis, record high-diesel prices, and a workforce shortage to deliver freight for their customers and keep the American economy afloat. Understanding the impact of this regulation on their business is itself a challenge, much less putting it into words in time to meet the May 13 deadline. We would ask that EPA consider these limitations as it assesses the comments (or lack thereof) that are submitted within the timeframe given.

Thank you for considering our comments as we continue our work to improve the environment and keep the nation’s goods and economy moving ahead.

Sincerely,

Rebecca K. Oyler

President & CEO