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Chapter 12: Initial Regulatory Flexibility Analysis

This chapter discusses the agencies’ Initial Regulatory Flexibility Analysis (IRFA) that 

evaluates the potential impacts of the proposed standards on small entities. The Regulatory

Flexibility Act, as amended by the Small Business Regulatory Enforcement Fairness Act of 1996 

(SBREFA), generally requires an agency to prepare a regulatory flexibility analysis of any rule 

subject to notice and comment rulemaking requirements under the Administrative Procedure Act 

or any other statute unless the agency certifies that the rule will not have a significant economic 

impact on a substantial number of small entities. Pursuant to this requirement, we have prepared 

an IRFA for the proposed rule. Throughout the process of developing the IRFA, EPA conducted 

outreach and held meetings with representatives from the various small entities that could be 

affected by the rulemaking to gain feedback, including recommendations, on how to reduce the 

impact of the rule on these entities. The small business recommendations stated here reflect the 

comments of the small entity representatives (SERs) and members of the Small Business 

Advocacy Review Panel (SBAR Panel, or ‘the Panel’). NHTSA maintains obligations to 

evaluate small business impacts under the Regulatory Flexibility Act, but is not required to 

convene a SBAR Panel. As a joint rulemaking, EPA and NHTSA have coordinated formulation 

of standards, including flexibilities for small businesses. 

12.1 Overview of the Regulatory Flexibility Act

In accordance with Section 609(b) of the Regulatory Flexibility Act (RFA), EPA 

convened an SBAR Panel before conducting the IRFA. A summary of the Panel’s 

recommendations is presented in the preamble of this proposed rulemaking. Further detailed 

discussion of the Panel’s outreach, advice and recommendations is found in the Final Panel 

Report contained in the docket for this proposed rulemaking.1

Section 609(b) of the RFA directs the Panel to report on the comments of small entity

representatives and make findings on issues related to elements of an IRFA under Section 603 of 

the RFA. Those elements of an IRFA are:

 A description of, and where feasible, an estimate of the number of small entities to which 

the proposed rule will apply;

 A description of projected reporting, record keeping, and other compliance requirements 

of the proposed rule, including an estimate of the classes of small entities which will be 

subject to the requirement and the type of professional skills necessary for preparation of 

the report or record;

 An identification, to the extent practicable, of all relevant Federal rules which may

duplicate, overlap, or conflict with the proposed rule;

 A description of any significant alternatives to the proposed rule which accomplish the 

stated objectives of applicable statutes and which minimize any significant economic 

impact of the proposed rule on small entities.
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The RFA was amended by SBREFA to ensure that concerns regarding small entities are 

adequately considered during the development of new regulations that affect those entities. 

Although EPA is not required by the Clean Air Act to provide special treatment to small 

businesses, the RFA requires EPA and NHTSA to carefully consider the economic impact that 

our rules will have on small entities. The recommendations made by the Panel may serve to help 

lessen these economic impacts on small entities when consistent with the Clean Air Act 

requirements.

12.2 Need for Rulemaking and Rulemaking Objectives

Heavy-duty vehicles are classified as those with gross vehicle weight ratings (GVWR) of 

greater than 8,500 lb. Section 202(a) of the Clean Air Act (CAA) requires EPA to promulgate 

emission standards for pollutant emissions from new motor vehicles and engines which 

emissions cause or contribute to air pollution which may reasonably be anticipated to endanger 

public health or welfare. In 2009, EPA found that six greenhouse gases (GHGs) were 

anticipated to endanger public health or welfare, and that new motor vehicles and new motor 

vehicle engines contribute to that pollution which endangers. As explained in preamble section 

I, the D.C. Circuit upheld this endangerment finding, and further held that EPA had a mandatory

duty to promulgate standards for emissions of the pollutant which contributes to the 

endangerment: GHGs from new motor vehicles and engines.

The Energy and Security Independence Act of 2007 (EISA) directs NHTSA to develop 

regulations to increase fuel efficiency for commercial medium-duty and heavy-duty on-highway

vehicles and work trucks. Fundamentally, EISA seeks energy conservation. In 2010, total fuel 

consumption and GHG emissions from medium- and heavy-duty vehicles accounted for 23 

percent of total U.S. transportation-related GHG emissions.

EPA and NHTSA’s Phase 1 Heavy-Duty Engines and Vehicles Program, which was 

finalized in September 2011 (76 FR 57106), marked the first greenhouse gas emissions and fuel 

efficiency standards for heavy-duty vehicles and engines. The program addressed medium- and 

heavy-duty GHG emissions and fuel efficiency through the adoption of performance-based 

standards that allow manufacturers to determine the optimal mix of technologies to achieve the 

necessary reductions for their vehicle fleets and engines.

Building on the Phase 1 rule, this proposed Phase 2 rule would reduce GHG emissions 

and fuel consumption associated with the transportation of goods across the United States post2017. The proposed Phase 2 rulemaking considers changes to existing engine, GHG, and fuel 

efficiency standards, as well as regulatory standards and certification requirements for 

previously-unregulated new trailers pulled by semi-tractors. If such a rule is adopted, 

manufacturers of heavy-duty engines, chassis, vehicles and trailers could be required to 

incorporate GHG-reducing and fuel-saving technologies in order to comply with the agencies’ 

performance-based standards.

12.3 Definition and Description of Small Businesses

The RFA defines small entities as including “small businesses,” “small governments,” 

and “small organizations” (5 USC 601) and references the Small Business Act for the definition 
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of “small businesses” using size standards based on the North American Industry Classification 

System (NAICS) (13 CFR 121.201). The standards being considered by EPA for this 

rulemaking are expected to affect a variety of small businesses. A listing of the NAICS codes 

identified as relevant to the potential rulemaking, along with their respective SBA size 

thresholds, is located in Table 12-1, below.

The agencies expect that the same industries affected by the Phase 1 rulemaking will also 

be affected by the proposed Phase 2 rulemaking. In addition, small businesses and trailer 

manufacturers are also included in the proposed Phase 2 rule. EPA and NHTSA used the criteria 

for small entities developed by the Small Business Administration (SBA) as a guide to 

identifying Small Entity Representatives (SERs) for this proposed rulemaking. Table 12-1 lists 

industries potentially directly affected by the regulation. The NAICS Code and size threshold 

are shown as well.

Table 12-1 Industry Sectors Potentially Affected by the Agencies’ Planned Action

INDUSTRY EXPECTED IN

RULEMAKING

NAICS 

CODE

NAICS 

DESCRIPTION

SBA SIZE 

THRESHOLD

Alternative Fuel 

Engine Converters

333999 Misc. General Purpose Machinery 500 employees

811198 All Other Auto Repair & Maintenance $7.0M (annual receipts)

HD Pick-up Trucks & Vans 336111 Automobile Manufacturing 1,000 employees

Vocational Chassis, 

Class 7 & 8 Tractors

336120 Heavy-Duty Truck Manufacturing 1,000 employees

Trailers 336212 Truck Trailer Manufacturing 500 employees

333924 Ind. Truck, Trailer & Stacker Machinery 750 employees

HD Engines 336310 Motor Vehicle Gasoline Engine & Engine 

Parts

750 employees

12.4 Summary of Small Entities to which the Rulemaking will Apply

Using the information from Table 12-1, with the agencies’ certification data and 

employment information from the Hoover’s online business information database, EPA and 

NHTSA determined that only three of these affected industries contained small businesses: 

vocational chassis manufacturers, alternative fuel engine converters, and trailer manufacturers, as 

described below. The agencies believe there are about 115 trailer manufacturers and 100 of 

these manufacturers qualify as small entities with 500 employees or less. EPA and NHTSA

identified 21 alternative fuel engine converters from previous certification data and 18 of these 

converters are considered small entities. Currently, 20 manufacturers that make chassis for 

vocational vehicles certify with EPA under the Phase 1 program. Three vocational chassis 

manufacturers contacted EPA and NHTSA to request an exemption from Phase 1 based on their 

small entity status. Gliders are a subset of vehicles being considered for regulation under the 

proposed Phase 2 rulemaking (including for regulation of criteria pollution emissions). Glider 

manufacturers traditionally manufacture new vehicle bodies (vocational vehicles or Class 7 and 8 

tractors) for use with older powertrains. The agencies are aware of four glider manufacturers and 

three are small entities.
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12.5 Related Federal Rules

The Phase 1 rulemaking continues to be in effect in the absence of this proposed rule. 

The Panel noted that it was aware that the proposed Phase 2 rule would be a joint action by EPA 

and Department of Transportation (DOT), through NHTSA, as was done in the Phase 1 

rulemaking. The Panel is also aware of several other state and Federal rules related to heavyduty vehicles and to the proposed Phase 2 rule under consideration. NHTSA has safety 

requirements for medium- and heavy-duty vehicles located at 49 CFR 571. California adopted 

its own greenhouse gas initiative, which places aerodynamic requirements on trailers used in 

long-haul applications. None of these existing regulations were found to conflict with the 

proposed rulemaking.

12.6 Projected Reporting, Recordkeeping, and Other Compliance 

Requirements

For any emission control program, EPA must have assurances that the regulated products 

will meet the standards. The program that EPA and NHTSA are considering for manufacturers 

subject to this proposal will include testing, reporting, and recordkeeping requirements. Testing 

requirements for these manufacturers could include use of EPA’s Greenhouse gas Emissions 

Model (GEM) vehicle simulation tool to obtain the overall CO2 emissions rate for certification of 

vocational chassis and trailers, aerodynamic testing to obtain aerodynamic inputs to GEM for 

some trailer manufacturers, and engine dynamometer testing for alternative fuel engine 

converters to ensure their conversions meet the proposed CO2, CH4 and N2O engine standards. 

Reporting requirements would likely include emissions test data or model inputs and results, 

technical data related to the vehicles, and end-of-year sales information. Manufacturers would 

have to keep records of this information.

12.7 Regulatory Flexibilities

The Panel developed a range of regulatory flexibilities intended to mitigate the impacts of 

the proposed rulemaking on small businesses, and recommended that EPA propose and seek 

comment on the flexibilities. The Panel’s findings and discussions are based on the information 

that was available during the term of the Panel and issues that were raised by the SERs during 

the outreach meetings and in their written comments. It was agreed that EPA should consider 

the issues raised by the SERs (and issues raised in the course of the Panel) and that EPA should 

consider the comments on flexibility alternatives that would help to mitigate any negative 

impacts on small businesses. 

Alternatives discussed throughout the Panel process include those offered in the 

development of the upcoming rule. Though some of the recommended flexibilities may be 

appropriate to apply to all entities affected by the rulemaking, the Panel’s discussions and 

recommendations are focused mainly on the impacts, and ways to mitigate adverse impacts, on 

small businesses. A summary of the Panel’s recommendations, along with those provisions that 

we are actually proposing in this action, are detailed below. A full discussion of the regulatory

alternatives and hardship provisions discussed and recommended by the Panel, all written 

comments received from SERs, and summaries of the two outreach meetings that were held with 

the SERs can be found in the SBREFA Final Panel Report.2 In addition, all of the flexibilities 
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that are being proposed in the rulemaking for small businesses, as well as those for all entities 

that may be affected by the rulemaking, are described in the preamble to the proposed rule.

12.7.1 Alternative Fuel Engine Converter Flexibilities

12.7.1.1 SBAR Panel Recommendations

To reduce the compliance burden of small business engine converters who convert 

engines in previously-certified complete vehicles, the Panel recommended allowing engine 

compliance to be sufficient for certification. This would mean the converted vehicle would not 

need to be recertified as a vehicle. This flexibility would eliminate the need for these small 

manufacturers to gather all of the additional component-level information (e.g., transmission 

data, aerodynamic performance, tire rolling resistance) in addition to the engine CO2

performance necessary to properly certify a vehicle with GEM. In addition, the Panel 

recommended that small engine converters be able to submit an engineering analysis, in lieu of 

measurement, to show that their converted engines do not increase N2O emissions. Many of the 

small engine converters are converting SI-engines, and the catalysts in these engines are not 

expected to substantially impact N2O production. Small engine converters that convert CIengines could likely certify by ensuring that their controls require changes to the SCR dosing 

strategies.

Based on the comments received from SERs, the Panel recommended not having separate 

standards for small business natural gas engine manufacturers. The Panel believed this would 

discourage entrance into this emerging market by adding unnecessary costs to a technology that 

has the potential to reduce CO2 tailpipe emissions. In addition, the Panel stated that it believes 

additional leakage requirements beyond a sealed crankcase for small business natural gas-fueled 

CI engines and requirements to follow industry standards for leakage could be waived for small 

businesses with minimal impact on overall GHG emissions.

Finally, the Panel recommended that small engine converters receive a one-year delay in 

implementation for each increase in stringency throughout the proposed rule. This flexibility

would provide small converters additional lead time to obtain the necessary equipment and 

perform calibration testing if needed.

12.7.1.2 The Agencies’ Proposed Regulatory Flexibility Options

The agencies have chosen to propose the Panel’s recommended regulatory flexibility

provisions for alternative fuel engine converters. EPA and NHTSA are proposing to offer small 

business engine converters a one year delay in implementation for each increase in stringency

throughout the proposed rule. In addition, small businesses that convert complete vehicles will 

be able to use an engine-only certification of their final vehicles. Finally, the agencies are 

proposing to allow small business engine converters to use an engineering analysis approach to 

show that their converted engines do not impact N2O production.
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12.7.2 Vocational Vehicle Chassis Manufacturer Flexibilities

12.7.2.1 SBAR Panel Recommendations

The Panel recommended proposing less stringent standards for emergency vehicle chassis 

manufactured by small businesses. The Panel stated that it believes it is feasible for small 

manufacturers to install a Phase 2-compliant engine, but recommended that the rulemaking

request comment on whether the use of LLR tires will provide enough CO2 benefits to justify

requiring small business emergency chassis manufacturers to adopt them. In addition, the Panel 

recommended a simplified certification approach for small manufacturers who make chassis for 

emergency vehicles that reduces the number of inputs these manufacturers would need to obtain 

for GEM.

The Panel recommended proposing a low volume exemption for small business custom 

chassis manufacturers based on the volume of sales. Similar to the recommendation for 

emergency vehicle chassis manufacturers, the Panel stated it believes it is feasible to require 

installation of a Phase 2-compliant engine and recommended that EPA request comment on the 

benefits of LRR tires in this market segment. The Panel also recommended that the rulemaking 

request comment on how to design a small business exemption by means of a volume exemption 

and what sales volume would be an appropriate threshold.

The Panel stated that it believes that the number of vehicles produced by small business 

glider manufacturers is too small to have a substantial impact on the total heavy-duty inventory. 

The Panel also stated that there should be an allowance to produce some number of glider kits 

for legitimate purposes, such as for newer vehicles badly damaged in crashes. The Panel 

therefore recommended proposing an explicit allowance for existing small businesses to continue 

assembling glider vehicles without having to comply with the GHG requirements. The Panel 

also recommended that any regulations for glider production be flexible enough to allow sales 

levels as high as the peak levels in the 2010-2012 timeframe.

12.7.2.2 EPA and NHTSA’s Proposed Regulatory Flexibility Options

EPA and NHTSA are proposing a flexibility for all emergency vehicles that includes 

fewer technology requirements and a simplified certification approach. The agencies are also 

requesting comment on an appropriate low volume threshold for custom chassis manufacturers 

that would allow them to opt into a standard that has fewer technology requirements. The 

exemption that the agencies are proposing for glider manufacturers is expected to encompass 

small glider manufacturers. See Section XIV of the NPRM preamble for additional details.

12.7.3 Trailer Manufacturer Flexibilities

12.7.3.1 SBAR Panel Recommendations

Box Trailers

Box trailer manufacturers have the benefit of relying on the aerodynamic technology

development initiated through EPA’s voluntary SmartWay program. The Panel acknowledged 

EPA’s plan to propose a simplified compliance program for all manufacturers, in which 
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aerodynamic device manufacturers have the opportunity to test and register their devices with 

EPA as technologies that can be used by trailer manufacturers in their trailer certification. This 

pre-approved technology strategy is intended to provide all trailer manufactures a means of 

complying with the standards without testing. Upon the completion of the SBREFA Panel 

process, it was unclear if this strategy would be available indefinitely, or if it would be an interim 

flexibility to allow manufacturers to ease into a testing-only compliance program. The Panel 

recommended that, in the event that this strategy is limited to the early years of the trailer 

program for all manufacturers, small manufacturers should continue to be given the option to use 

pre-approved devices in lieu of testing.

The Panel stated its belief that, in the event that small trailer manufacturers adopt preapproved aerodynamic technologies and the appropriate tire technologies for compliance, it 

would not be necessary to require the use of a vehicle emissions model, such as GEM, for 

certification. Instead, the Panel stated that it could be possible for manufacturers to simply

report to EPA that all of their trailers include approved technologies.

Non-Box Trailers

The Panel recommended that EPA not base a standard for non-box trailers on 

performance of aerodynamic devices. Some of the non-box trailer manufacturer SERs have seen 

prototype-level demonstrations of aerodynamic devices on non-box trailers. However, most 

non-box trailer SERs identified unique operations in which their trailers are used that preclude 

the use of those technologies.

Some non-box trailer manufacturers have experience with LRR tires and ATI systems. 

However, the non-box trailer manufacturer SERs indicated that LRR tires are not currently 

available for some of their trailer types. The SERs noted that tire manufacturers are currently 

focused on box trailer applications and that there are only a few LRR tire models that meet the 

needs of their customers. The Panel stated that it believes EPA should ensure appropriate 

availability of these tires in order for it to be deemed a feasible means of achieving these 

standards and recommends a streamlined compliance process based on the availability of 

technologies. The Panel suggested that the best compliance option from a small business 

perspective would be for the agencies to pre-approve tires once they are available in sufficient 

quantities on the market, similar to the approach being proposed for aerodynamic technologies, 

and to maintain a list that could be used to exempt small businesses when no suitable tires are 

available. However, the Panel stated that it recognizes the difficulties of maintaining an up-todate list of certified technologies. The Panel recommended that, if the rulemaking does not 

adopt the list-based approach, the agency consider a simplified letter-based compliance option 

that allows manufacturers to petition the agencies for an exemption if they are unable to identify

tires that meet the LRR performance requirements on a trailer family basis.

Trailers with Unique Use Patterns

The Panel recommended excluding all trailers that spend a significant amount of time in 

off-road applications. These trailers may not spend much time at highway speeds and 

aerodynamic devices may interfere with the vehicle’s intended purpose. Additionally, tires with 

lower rolling resistance may not provide the type of traction needed in off-road applications.
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General Flexibilities for All Small Trailer Manufacturers

The Panel stated that it recognizes that some manufacturers, who have diverse product 

lines and high sales volumes, may benefit from an emissions averaging, banking and trading 

(ABT) strategy. However, due to the custom-order nature of the trailer industry, SERs have 

expressed their concern that ABT may provide an opportunity for historically loyal customers or 

customers with large fractions of a manufacturer’s business to bargain for the portion of a 

manufacturer’s sales that have minimal requirements. Based on the low volume of sales and 

niche market of many small business trailer manufacturers, small businesses in particular may 

have little leverage in this situation and risk losing their customers to larger manufacturers who 

have credits to spare. In addition, the accounting and reporting burdens of ABT may preclude 

small businesses from participating in the flexibility.

Due to the potential for reducing a small business’s competitiveness compared to the 

larger manufacturers, as well as the ABT recordkeeping burden, the Panel recommended EPA 

consider small business flexibilities to allow small entities to opt out of ABT without placing 

themselves at a competitive disadvantage to larger firms that adopt ABT, such as a low volume 

exemption or requiring only LRR where appropriate. The Panel recommended that EPA should 

also consider flexibilities for small businesses that would ease and incentivize their participation 

in ABT, such as streamlined the tracking requirements for small businesses. In addition, the 

Panel recommended that the rulemaking request comment on the feasibility and consequences of 

ABT for the trailer program and additional flexibilities that would promote small business 

participation. 

In addition, for all trailer types that will be included in the proposal, the Panel 

recommended a 1-year delay in implementation for small trailer manufacturers at the start of the 

proposed rulemaking to allow them additional lead time to make the proper staffing adjustments 

and process changes and possibly add new infrastructure to meet these requirements. In the 

event that the agencies are unable to provide pre-approved technologies for manufacturers to 

choose for compliance, the Panel recommended that the standards provide small business trailer 

manufacturers an additional 1-year delay for each subsequent increase in stringency. This 

additional lead time would allow these small businesses to research and market the technologies 

required by the new standards.

12.7.3.2 The Agencies’ Proposed Regulatory Flexibility Options

The agencies are proposing many of the Panel’s recommendations for small business 

trailer manufacturers, including seeking comment on the possibility of a small volume 

exemption. While many of the smallest trailer manufactures sell significantly fewer trailers than 

the largest small manufacturers, many of the smallest trailer manufacturers produce specialty 

trailers that are already candidates for exemption under the proposed off-highway or heavy-haul 

provisions described in Section IV C. (5) of the preamble to this rulemaking. 

Testing requirements for small businesses are largely reduced by provisions outlined in 

the program for both large and small trailer manufacturers. Tire rolling resistance is measured 

by tire manufacturers and information needed for compliance would be presented to trailer 

manufacturers when they purchase their tires. The agencies are also proposing an option for pre-
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approved aerodynamic device data to be made available to trailer manufacturers for use in 

complying with aerodynamic requirements. These pre-approved devices would eliminate the 

requirement for trailer manufacturers to complete aerodynamic performance testing for 

certification. A majority of the small trailer manufacturers produce non-box trailers, the 

proposed standards for which are not predicated on use of aerodynamic controls, which reduces 

the number of technologies to investigate, market, and implement. EPA and NHTSA expect the 

six small business box trailer manufacturers the agencies have identified will take advantage of 

the pre-approved aerodynamic devices for most of their trailers. 

Additionally, the agencies are proposing a simplified compliance program with options to 

demonstrate trailer performance without requiring the trailer manufacturers to perform vehicle 

modeling using GEM. Instead, the agencies have developed a GEM-based equation for each box 

trailer subcategory that reproduces the CO2 results of the vehicle model. The standards proposed 

for non-box trailer manufacturers would require the use of LRR tires and ATI systems, and these 

manufacturers would not need to evaluate the performance those technologies using GEM. As a 

result, no trailer manufacturers would use GEM for compliance in this proposal. For the small 

business trailer manufacturers that produce trailers that are regulated in this program, EPA is

offering a one-year implementation delay at the beginning of the program what will allow small 

business trailer manufacturers to demonstrate compliance starting in model year 2019. This 

provision will allow small businesses additional lead time to make the proper staffing 

adjustments and process changes and possibly add new infrastructure to meet their requirements.

For the proposed standards, small business trailer manufacturers would already be 

required to comply with EPA standards when NHTSA’s fuel efficiency standards would begin. 

Therefore, NHTSA does not believe that an additional year of delay to comply with its fuel 

efficiency standards would provide beneficial flexibility. 

12.8 Projected Economic Effects of the Proposed Rulemaking

This section summarizes the economic impact on small businesses of the proposed Phase 

2 rulemaking. To gauge the impact of the proposed standards on small businesses, the agencies

employed a cost-to-sales ratio test to if small businesses would be impacted by less than one 

percent, between one and three percent, and above three percent of their sales. The costs used in 

this analysis for the proposed requirements are based on the cost estimates developed in Chapter 

7 of this Draft RIA.

Based on our current analysis, EPA and NHTSA believe that small business trailer sales 

range from 1 to 63 million dollars. As presented in Chapter 7 of this Draft RIA, costs for trailer 

manufacturers range between 95 and 340 thousand dollars, which is greater than a one percent 

impact for most of the small trailer manufacturers. However, these projected costs do not 

account for the small business flexibilities, which we believe will reduce costs for a majority of 

the small trailer manufacturers to less than three percent of their sales. Additionally, many of the 

smallest manufacturers who see revenues below two million dollars produce specialty trailers 

that meet the criteria for exemption from the proposed standards.

We believe that small businesses in the alternative fuel engine converter sector will be 

able to comply with the agencies’ proposed regulations with minimal incremental cost compared 
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to their current costs for compliance with EPA’s criteria pollutant programs. As such, at this 

time, we believe they will be impacted at less than one percent of their current annual sales. All 

of the vocational vehicle chassis manufacturers that EPA and NHTSA are aware of at this time 

are eligible for exemptions outlined in Section V B. (4), and the agencies believe they would be 

impacted at less than one percent of their sales.

For a complete discussion of the economic impacts of the proposed rulemaking, see Chapter 8 of 

this Draft Regulatory Impact Analysis.
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References

1

Final Report of the Small Business Advocacy Review Panel on EPA’s Planned Proposed Rule: Greenhouse Gas 

Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles: Phase 2. Signed on 

January 15, 2015. Available in docket at: EPA–HQ–OAR–2014–0827

2

Final Report of the Small Business Advocacy Review Panel on EPA’s Planned Proposed Rule: Greenhouse Gas 

Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles: Phase 2. Signed on 

January 15, 2015. Available in docket at: EPA–HQ–OAR–2014–0827