Environmental Protection Agency (EPA) Greenhouse Gas (GHG) Emissions Standards Business Letter

Dear Administrator Zeldin,

We write to you as a group of businesses, including manufacturers, fleet operators, and investors, representing nearly $200 million in annual revenue and overseeing nearly $1 billion in assets under management to express our strong opposition to the U.S. Environmental Protection Agency’s (EPA) recent proposal to withdraw greenhouse gas (GHG) emissions standards across vehicle classes.

We are deeply concerned that rolling back these standards, as proposed by EPA, will destabilize the market at a time when long-term regulatory certainty is essential for investment, innovation, and job growth. While transportation represents the largest source of GHG emissions in the U.S. and a major component of our organizations’ emissions footprints, electrification can reduce and eliminate these emissions. Fleet electrification also provides direct economic benefits, including reduced fuel and maintenance costs, protection from fossil fuel price volatility, and improved efficiency. Robust vehicle emissions standards are necessary to create an aligned benchmark for manufacturers technological innovation that delivers the clean vehicles we need to lower operating costs, achieve climate goals, and improve air quality in the communities where we live and work.

Eliminating these standards would stall momentum at a critical moment and place our companies and communities at greater risk for financial loss. Many of us have invested significantly in fleet electrification and emissions reduction strategies in response to regulatory signals and market expectations. These investments have positioned the U.S. to produce more home-grown products and as a leader in technology innovation. Vehicle GHG standards help maintain a stable, predictable market environment that fosters further investment and ensures that American companies can compete globally in the rapidly expanding clean-transportation sector.

EPA’s GHG emissions standards are also supporting market expansion and vehicle availability, reducing costs through economies of scale, and accelerating innovation and domestic manufacturing. Backtracking on these policies threatens the nation’s progress toward decarbonizing transportation, reducing harmful air pollution, and ensuring global competitiveness in clean technology.

Maintaining strong consistent policies is critical to regulatory certainty, support business and investment planning, and delivering on the nation’s climate and public health commitments. We urge EPA to reconsider its proposed rescission of this vital program.

Sincerely,

Fermata Energy

Grove Collaborative

Harbinger Motors Inc.

Orange EV

Xos, Inc.

Zevin Asset Management