ACEEE filed comments in response to an EPA notice of proposed rulemaking, “Greenhouse Gas Emissions Standards for Heavy-Duty Vehicles – Phase 3 ” ( 88 FR 25926). To stave off the worst impacts of climate change, the United States will need to make rapid progress toward eliminating pollution from heavier vehicles. ACEEE’s recommends that EPA set standards that reflect higher EV penetration rates in all vehicle categories, drive efficiency gains in internal combustion engine vehicles and zero emission vehicles, and include upstream accounting. An improved final rule is necessary to ensure that the heavy-duty sector is contributing adequately to meeting economy-wide GHG emissions targets.