Public Comments

Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2

The Environmental Protection Agency’s (EPA) proposed regulation Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2 results in no demonstrable or verifiable mitigation of future climate change—the primary justification for the regulation. The reported reductions in the rate of rise of atmospheric carbon dioxide concentrations, average global temperature and global average sea level are so small as to be statistically indistinguishable from the evolution of these measures absent this regulation. As such, it is scientifically improper for the EPA to claim this regulation results in a “meaningful” impact on future climate change. Further, the EPA did not investigate any impact beyond the grossest of global-scale measures.

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