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## Chapter 12: **Initial Regulatory Flexibility Analysis**  This chapter discusses the agencies’ Initial Regulatory Flexibility

Anal ys is (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), generall y requires an agency to prepare a regulatory flexibility anal ys is of any

rule subject to notice and comment rulemaking requirements under the Administrative Procedure Act or an y 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 b y 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 S ection 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 d iscu s sion 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 di rects the Panel to report on the comments of small entity representatives and make findings on issues related to elements of an IRFA under S ection 603 of the RFA. Those elements of an IRFA are:
 A description of, and where feasible, an estimate of the numbe r 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 req

uirement and the ty

pe 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.***** E.O. 12866 Review**
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12 - 2 The RFA was amended by SBREFA to ensure that concerns regarding small entities are adequatel y 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 b y the Panel may serve to h e lp lessen these economic impacts on small entities when consistent with the Clean Air Act requirements. 

### 12.2 **Need for Rulem ak**  **ing and Rulemak**

**ing Objectives** Heav y - dut y 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 endan ger public health or welfare. In2009, EPA found that six greenhouse gases (GHGs) were anticipated to endanger public heal th 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 Securit y Independence Act of 2007 (EI SA) directs NHTSA to develop regulations to increase fuel efficiency f or commercial medium - duty and heavy - duty on - highway vehicles and work trucks . Fundamentall y, EISA seeks energy conservation. In 2010, total fuel consumption and GHG emissions from medium - and heav y - dut y vehicles accounted for 23 percent of total U.S. transportation - related GHG emissions. EPA and NHTSA’s Phase 1 Heav y - Dut y Engines and Vehicles Program, which was finalized in September 2011 ( 76 FR 57106 ) , marked the first greenhouse gas emissions and fuel efficiency standards for heav y - dut y vehicles and engines. The program addressed medium - and heav y - dut y GHG emissions and fuel efficiency through the adoption of performance - based standards that allow manufacturers to determine the optimal mix of technologies to ach ieve 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 post 2017. Th e 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 b y s emi - tractors. If such a rule is adopt ed, manufacturers of heav y - 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 Busin esses**  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***** E.O. 12866 Review**
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12 - 3 of “small businesses” using size standards based on the North American Industry Classification Sy stem (NAI CS) (13 CFR 121.201). The standards being considered b y 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. T he agencies expect that the same industries affected by the Phase 1 rulemaking will also be affected b y 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 th is 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 Aff ected by**  **the A gencies’**  **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 employ ment 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 manu facturers qualify as small entities with 500 employ ees 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 mak e 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 c onsidered 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.***** E.O. 12866 Review**
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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 heavy duty vehicles and to the proposed Phase 2 rule under consideration. NHTSA has safety requirements for medium - and heav y - dut y vehicles located at 49 CFR 571 . California adop ted its own greenhouse gas initiative, which places aerody namic 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 an y 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, report ing, 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 CO 2 emissions rate for certification of vocational chassis and trailers, aerody namic testing to obtain aerody namic inputs to GEM for some trailer manufacturers , and engine d yn amometer testing for alternative fuel engine converters to ensure their conversions meet the proposed CO 2 , CH 4 and N 2 O engine standards. Report ing 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 P anel 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. Itwas agreed that EPA should consider the issues raised b y 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 way s to mitigate adverse impact s, 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 recomm ended b y 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 Inaddition, all of the flexibilities***** E.O. 12866 Review**
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12 - 5 that are being proposed in the rulem aking for small businesses, as well as those for all entities that may be affected b y 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 b urden of small business engine converters who convert engines in previously - certified complete vehicles, the Panel recommend ed allowing engine compliance to be sufficient for certification. This would mean the converted vehicle would not need to be recert ified 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 CO 2 performance necessary

to properl y certify

a vehicle with GEM. In addition, the Panel recommend ed that small engine converters be able to submit an engineering anal ys is, in lieu of measurement, to show that their converted engines do not increase N 2 O em issions. Many of the small engine converters are converting SI - engines, and the cataly sts in these engines are not expected to substantially

impact N 2 O production. Small engine converters that convert CI engines could likely

certify by ensuring that thei r controls require changes to the SCR dosing strategies. Based on the comments received from SERs, the Panel recommend ed not having separate standards for small business natural gas engine manufacturers. The Panel believe d this would discourage entrance i nto this emerging market b y adding unnecessary costs to a technology

that has the potential to reduce CO 2 tailpipe emissions. In addition, the Panel stated that it believes additional leakage requirements beyond a sealed crankcase for small business natur al gas - fueled CIengines and requirements to follow industry standards for leakage could be waived for small businesses with minimal impact on overall GHG emissions. Finally , the Panel recommend ed 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’ Propose d Regulatory Flexibility Options The a gencies have cho s en 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 ye ar delay in implementation for each increase in stringency throughout the proposed rule. In addition, sm all businesses that convert comp l ete vehicles will be able to use an engine - only certification of their final vehicles. Finally , the a gencies are proposing to allow small business engine converters to use an engineering analy sis approach to show that their converted engines do not impact N 2 O production.***** E.O. 12866 Review**
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12 - 6 12.7.2 **Vocational Vehicle Chassis Manufacturer Flexibilities**  12.7.2.1 SBAR Panel Recommendations The Panel recommend ed proposing less stringent standards for emergency vehicle chassis manufactured b y small businesses. The Panel stated that it believes it is feasible for small manufacturers to install a Phase 2 - compliant engine, but recommend ed that the rulemaking request comment on whether the use of LLR tires will provide enough CO 2 benefits to justify requiring small business emergency chassis manufacturers to adopt them. In addition, the Panel recommend ed a simplified certification approach for small manufacturers who make chassis for e mergency

vehicles that reduces the number of inputs these manufacturers would need to obtain for GEM. The Panel recommend ed 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 recommend ed that EPA request comment on the benefits of LRR tires in this market segment. The Pane l also recommend ed 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 produce d by small business glider manufacturers is too small to have a substantial impact on the total heavy - dut y 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 recommend ed proposing an explicit allowance for existing small businesses to continue assembling glider vehicles without having to comply with the GHG requirements. The Panel also recommend ed 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 Propose d 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 a gencies are also requesting comment on an appropriate low volume threshold for custom chassis manufacturers that would allow them to opt into a standard th at has fewer technology requirements. The exemption that the a gencies 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 Flexibilit**  **ies** 12.7.3.1 SBAR Panel Recommendations Box Trailers Box trailer manufacturers have the benefit of relying on the aerody namic 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***** E.O. 12866 Review**
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12 - 7 aerod ynamic device manufacturers have the opportunity to test and register their devices with EPA as technologies that can be used b y trailer manufacturers in their trailer certific ation. 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 wa s unclear if this strategy would be available inde finitel y, or if it would be an interim flexibility to allow manufacturers to ease into a testing - onl y compliance program. The Panel recommended that, i n the event that this strategy is limited to the early

years of the trailer program for all manufacture r s, small manufacturers should continue to be given the option to use pre - approv ed devices in lieu of testing. The Panel stated its belief that, i n the event that small trailer manufacturers adopt pre approved aerodyn amic technologies and the appropriate ti re 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 trai lers include approved technologies. Non
-Box Trailers The Panel recommended that EPA not base a standard for non - box trailers on performance of aerody

namic devices. Some of the non - box trailer manufacturer SER s have seen prototy pe - level demonstrations of a erod yn amic 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 sy stems. However, the non - box trailer manufacturer SERs indicated that LRR tires are not currentl y available for some of their trailer types. The SERs noted that tire manufacturers are currentl y focused on box trailer applications and that there are onl y 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 streaml ined compliance process based on the availability of t echnologies. 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 maint aining an up - to date list of certified tec hnologies. 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 f or 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 ap plications. These trailers may not spend much time at highway speeds and aerod ynamic devices may interfere with the vehicle’s intended purpose. Additionally , tires with lower rolling resistance may not provide the ty

pe of traction needed in off - road appl ications.***** E.O. 12866 Review**
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12 - 8 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) strat egy . 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 man y small business trailer manufacturers, small businesses in particular may have little leverage in this situation and risk losing the ir 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 competitiven ess compared to the larger manufacturers, as well as the ABT recordkeep ing 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 L RR 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 stream lined 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 ty pes that will be included in th e proposal, the Panel recommended a 1 - ye ar 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 - ye ar delay for each subsequent increase in stringency . This additional lead time w ould allow these small businesses to research and market the technologies required b y the new standards. 12.7.3.2 The Agencies’ Propose d Regulatory Flexibility

Options The a gencies are proposing man y 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, man y of the smallest trailer manufacturers produce specialty trailers that are already candidates for exemptio n under the proposed off - highway or heav y - 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 trail er 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 a gencies are also proposing an option for pre -***** E.O. 12866 Review**
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12 - 9 approved aerodyn amic device data to be made available to trailer manufacturers for use in complying with aerody

namic requirements. These pre - approved devices would eliminate the requirement for trailer manufacturers to complete aerodynamic performance testing for certi fication. 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 a gencies 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 b ox trailer subcategory

that reproduces the CO 2 results of the vehicle model. The standards proposed for non - box trailer manufacturers would require the use of LRR tires and ATIs ys tems, and these manufacturers would not need to evaluate the performance th ose 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 - ye ar implementat ion 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 compl y with EPA standards when NHTSA’s fuel efficiency standards woul d 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 Ru lemaking**  Th is 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 a gencies 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 analy sis for the pr oposed requirements are based on the cost estimates developed in Chapter 7 of th is Draft RIA. B ased on our current analy sis, EPA and NHTSA believe that small business trailer sales range from 1 to 6 3 million dollars. As presented in Chapter 7 of this Draft RIA, costs for trailer manufacturer s 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 manufactur ers 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. W e believe that small b usinesses in the alternative fuel engine converter sector will be able to comply

with the a gencies’ proposed regulations with minimal incremental cost compared***** E.O. 12866 Review**
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12 - 10 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 vocatio nal vehicle chassis manufactur e rs that EPA and NHTSA are aware of at this time are eligible for exemptions outlined in Section V B. (4), and the a gencies 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 D raft Regulatory

Impact Anal ys is.***** E.O. 12866 Review**
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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

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– 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

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