Policy Engagement Overview
InfluenceMap's database covers roughly 500 companies and 250 industry associations globally, with the most engaged entities scanned on a weekly basis and all entities assessed at least every other quarter. The current state of corporate engagement on this regulation is summarized below. The "Evidence Profile" at right indicates InfluenceMap's capture of corporate positions on the regulation, ranging from strong opposition to strong support. Both this page and the graph were last updated September 11th, 2023.
The following bullets summarize corporate lobbying on the EPA’s most recently proposed “Phase 3” GHG emission standards, proposed in April 2023:
● The Truck and Engine Manufacturers Association (EMA) has advocated to weaken numerous key aspects of the EPA's proposed "Phase 3" GHG emissions standards. In June 2023 comments to the EPA, the association cautioned that without substantial revision, including less ambitious timelines, the phase 3 standards would be “arbitrary, capricious and wholly unreasonable.” It also advised the EPA to reopen and reduce the ambition of the phase 2 standards.
● Electric utility companies expressed clear support for the proposed rule. The Edison Electric Institute, ConEdison, and PG&E all supported the regulations in June 2023 comments to the EPA. Enel also offered strong support in a letter to the EPA in June 2023. Industry group Advanced Energy United generally supported the regulation, and the Zero Emission Transportation Association, a group with members representing major utility companies and electric vehicle manufacturers, strongly supported the regulation in a May 2023 EPA testimony.
● Truck makers advocated to reduce the stringency and ambition of the proposed GHG standards. In June 2023 comments, Daimler Truck and Volvo Group advocated for the delay of the "Phase 3" standards from 2028 to 2030. Alongside this, Daimler Truck, Volvo Group, and PACCAR opposed increasing the ambition of existing "Phase 2" emissions standards in June 2023 comments to the EPA. PACCAR, Daimler Truck, and Volvo Group also advocated to maintain or extend existing credit multipliers that would reduce the stringency of the proposed regulation. Navistar also supported maintaining credit multipliers that could reduce the stringency of the rule, though more positively, it supported a 2032 target for zero-emission vehicle penetration.
● Fossil fuel industry advocacy remains highly negative. The American Fuel and Petrochemical Manufacturers Association (AFPM) and the American Petroleum Institute (API) refuted the legality of the standard's focus on electrification, instead advocating for a "technology neutral" approach in June 2023 comments to the EPA. The associations both also advocated for modifications that would make the regulation less ambitious. Valero also refuted the legality of the regulations, while Chevron did not contest their legality but advocated for significant modifications to the structure of the policy that would promote ICE vehicles as opposed to electrification. The American Petroleum Institute also organized a July 2023 joint letter addressed to government officials with over a hundred industry associations, primarily representing oil and gas producers, expressing general concern with the regulation and advocating against its focus on electrification.
● Larger cross-sector industry groups have advocated to weaken the regulation. The US Chamber of Commerce appear to advocate for the EPA to include flexibilities that would make the proposed standards less stringent in June 2023 comments on the regulation. The National Federation of Independent Business also requested that the EPA completely withdraw the rule in a June 2023 comment.
The automotive industry was highly active on the earlier, separate proposal in the EPA’s Clean Trucks Plan. The following bullets summarize lobbying on the EPA’s first proposed regulatory action under the Clean Trucks Plan in March 2022:
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Major U.S. truck manufacturers, including Daimler Truck, Navistar (a Volkswagen subsidiary), PACCAR and Volvo opposed the EPA’s revision of the “GHG Phase 2” final rule that would set more stringent HDV GHG emission standards for 2027-2029, instead supporting less ambitious GHG standards that would begin in 2030.
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Ford Motor and General Motors did not state a clear position on the proposed regulation.
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The Truck and Engine Manufacturers Association (EMA), where all the above automakers (except Ford) are members, took a particularly negative position, strongly opposing the increased stringency for 2027+ GHG standards on multiple occasions.
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Industry associations including the US Chamber of Commerce, American Petroleum Institute (API), and American Fuel and Petrochemical Manufacturers submitted negative comments on the EPA’s initial HDV proposal, recommending a long-term role for ICE vehicles over an increase in regulatory stringency.
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The Edison Electric Institute, representing U.S. utilities, supported the proposal. At the same time, a number of utilities (Duke Energy, Ameren, and others) – along with Marathon Petroleum, Nucor, and steel associations the American Iron and Steel Institute and Steel Manufacturer’s Association – submitted a joint comment that supported the NOx-related provisions without commenting on the GHG emissions standards.
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Valero Energy appears to be the only non-automotive company that strongly opposed the standards.
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Siemens, General Mills, and McDonald’s signed a joint letter through the Ceres BICEP network urging the EPA to further strengthen the proposed rule, which the letter deemed too weak.
