EPA’s and NHTSA’s proposed rule represents a good first step in the difficult job of setting fuel efficiency and greenhouse gas emissions standards for medium‐ and heavy‐duty vehicles. ACEEE supports the adoption of the program starting in 2014, as proposed. We also believe, however, that the proposal can and should be strengthened to capture more of the available fuel savings, to ensure support for the program among regulated entities and the public, and to establish precedents that will facilitate future improvements in the program.