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For decades, the medium- and heavy-duty (“MD/HD”) commercial vehicle industry has focused on improving freight efficiency in order to lower customers' total operating costs. To optimize fuel efficiency, most manufacturers no longer focus on discreet components but instead look at the complete vehicle and operations. The path to future efficiency gains is not sufficiently clear when looking towards 2030; what is clear is that one solution will not work for all manufacturers or vehicle applications. Therefore, fuel efficiency regulations must be sufficiently adaptive to allow a variety of technical approaches to ensure the needs of the commercial truck market are met. This paper explores further the ideas presented in other papers that focus on regulation of engine-only emissions as an approach for HD vehicles.