While I appreciate the EPA's attempt to levy penalties against the manufacturers of diesel-engine trucks, I do not understand or see reason for some of the figures in this rule to be expressed in monetary amounts from another decade (e.g., "December 1991 dollars" or "December 1984 dollars"). This seems like the creation of a loophole within the act.
I also wish the authors included information regarding a cost-benefit analysis of whether it is more beneficial to pay the fines or produce diesel-engine trucks that conform to the EPA's standards. This would prove that the fines are set at an appropriate amount to encourage environmentally sound production, versus paying the penalty and simply putting more environmentally unsound diesel-engine trucks on the road.
Anonymous public comment
This is comment on Rule
Nonconformance Penalties for On-highway Heavy Heavy-Duty Diesel Engines; Interim final Rule
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