Client Success: Environmental Team
On behalf of Volvo and Mack, and in conjunction with counsel for other truck engine manufacturers, we sought EPA reconsideration of an Interim Final Rule that the Agency had issued on January 31, 2012, without notice and comment. This rule established nominal noncompliance penalties for engines, which amount failed to reflect the actual cost of developing and implementing engine technologies that achieve the stringent emissions limits applicable to heavy duty truck engines. Following EPA’s denial of our request for reconsideration, we challenged the rule. We not only secured an expedited briefing and oral argument, but the U. S. Court of Appeals for the D.C. Circuit (which has jurisdiction for reviewing final agency action under the Clean Air Act) unanimously vacated the rule on June 12, 2012.
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Potentially saved 756 lives by donating 252 pints of blood during the American Red Cross's 2010-2011 fiscal year.
