EPA Issues Stringent Emissions Standards for Light- and Medium-Duty Vehicles

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On March 20, 2024, EPA announced new emissions standards for light-duty and medium-duty vehicles, starting with model year (“MY”) 2027 and phasing in through MY 2032. The new standards require reductions in emissions of greenhouse gases (“GHGs”), hydrocarbons, non-methane organic gases (“NMOG”), nitrogen oxides (“NOx”), and fine particulate matter (“PM2.5”) from new passenger cars, light trucks, larger pickups, and vans.

EPA’s emissions standards are based on advancements in emission control technologies that, according to the Agency, enable emissions reductions, including advanced gasoline vehicle technologies, hybrid electric vehicles, and battery-electric vehicles. The emissions standards are performance-based, allowing each automaker to select the mix of emissions control technologies that is best suited for its vehicle fleet to meet the standards. Automakers will be able to continue to produce gasoline- and diesel-fueled vehicles, along with electric vehicles, to meet EPA’s standards on a fleet-wide basis.

EPA has projected that the GHG standards for light-duty vehicles will result in an industry-wide average target of 85 grams/mile (“g/mile”) of carbon dioxide (“CO2”) in MY 2032, representing a nearly 50% reduction in projected fleet average emissions target levels relative to the existing MY 2026 standards. EPA has also projected that the medium-duty vehicle standards will result in an average target of 274 g/mile of CO2 by MY 2032, representing a 44% reduction in projected fleet average emissions target levels relative to the existing MY 2026 standards.

With respect to criteria pollutant emissions, EPA is finalizing Tier 4 criteria pollutant emissions standards for NMOG, NOx, PM, and other criteria pollutants and their precursors. The final rule sets a PM2.5 standard of 0.5 milligrams per mile (“mg/mi”) for both light- and medium-duty vehicles. EPA projects that automakers will widely use gasoline particulate filters on vehicles with internal combustion engines to meet the PM2.5 standard. For light-duty vehicles, the NMOG + NOx standard phases down to a fleet average level of 15 mg/mi by 2032, which represents a 50% reduction from the existing standard established in 2014 under EPA’s Tier 3 program. Medium-duty vehicles will have to meet a fleet average of 75 mg/mi for NMOG + NOx by 2033, representing a 58-70% reduction from Tier 3 standards.

 In addition to setting emissions standards, the rule also revises several aspects of the GHG program, including off-cycle and air conditioning credits, the treatment of upstream emissions associated with zero-emission vehicles and plug-in hybrid electric vehicles in compliance calculations, medium-duty vehicle incentive multipliers, and vehicle certification and compliance measures. The final rule also establishes new standards to control refueling emissions from incomplete medium-duty vehicles, and battery durability and warranty requirements for light- and medium-duty electric and plug-in hybrid electric vehicles.

The rule will become effective 60 days after it is published in the Federal Register. After it is published, the rule is likely to be challenged in court by a variety of plaintiffs, including states and fossil-fuel companies. Continue to follow our blog for more updates on this rule.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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