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                              July 19, 2022

       Harrie Schippers
       Chief Financial Officer
       PACCAR Inc
       777 106th Ave. N.E
       Bellevue, WA 98004

                                                        Re: PACCAR Inc
                                                            Form 10-K for
Fiscal Year Ended December 31, 2021
                                                            Filed February 23,
2022
                                                            File No. 001-14817

       Dear Mr. Schippers:

              We have reviewed your filing and have the following comments. In
some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for Fiscal Year Ended December 31, 2021

       General

   1.                                                   We note that you
provided more expansive disclosure in your ESG Presentation and on
                                                        your website than you
provided in your SEC filings. Please advise us what consideration
                                                        you gave to providing
the same type of climate-related disclosure in your SEC filings as
                                                        you provided in your
ESG Presentation and on your website.
       Risk Factors, page 10

   2.                                                   Disclose the material
effects of transition risks related to climate change that may affect
                                                        your business,
financial condition, and results of operations, such as policy and regulatory
                                                        changes that could
impose operational and compliance burdens, market trends that may
                                                        alter business
opportunities, credit risks, or technological changes.
 Harrie Schippers
FirstName  LastNameHarrie Schippers
PACCAR Inc
Comapany
July       NamePACCAR Inc
     19, 2022
July 19,
Page  2 2022 Page 2
FirstName LastName
3.       Please disclose any material litigation risks related to climate
change and explain the
         potential impact to the company.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
16

4.       There have been significant developments in federal and state
legislation and regulation
         and international accords regarding climate change that you have not
discussed in your
         filing. Please revise your disclosure to identify material pending or
existing climate
         change-related legislation, regulations, and international accords and
describe any material
         effect on your business, financial condition, and results of
operations.
5.       It appears you have identified climate-related projects in your ESG
Presentation, such as
         projects related to a transition to zero emissions. Tell us how you
considered providing
         disclosure regarding past and future capital expenditures for
climate-related projects.
         Include quantitative information for the periods covered by your Form
10-K and for future
         periods as part of your response.
6.       To the extent material, discuss the indirect consequences of
climate-related regulation or
         business trends, such as the following:
             decreased demand for goods that produce significant greenhouse gas
emission or are
             related to carbon-based energy sources;
             increased demand for goods that result in lower emissions than
competing products;
             increased competition to develop to develop new products that
result in lower
             emissions;
             increased demand for generation and transmission of energy from
alternative energy
             sources; and
             any anticipated reputational risks resulting from operations or
products that produce
             material greenhouse gas emissions.
7.       Please discuss the physical effects of climate change on your
operations and results. This
         disclosure may include the following:
             severity of weather, such as floods, hurricanes, sea levels,
extreme fires, and water
              availability and quality;
             quantification of material weather-related damages to your
property or operations;
             potential for indirect weather-related impacts that have affected
or may affect your
              major customers or suppliers; and
             any weather-related impacts on the cost or availability of
insurance.
         Include quantitative information for each of the periods covered by
your Form 10-K and
         explain whether increased amounts are expected in future periods as
part of your response.
8.       We note your disclosure on page 12 regarding the costs to comply with
environmental
         laws and regulations. Tell us about and quantify any compliance costs
related to climate
         change for each of the last three fiscal years and explain whether
increased amounts are
         expected to be incurred in future periods.
 Harrie Schippers
PACCAR Inc
July 19, 2022
Page 3
9.       If material, provide disclosure about your purchase or sale of carbon
credits or offsets and
         any material effects on your business, financial condition, and
results of operations.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Please contact Erin Donahue at 202-551-6063 or Sergio Chinos at
202-551-7844 with
any questions.



FirstName LastNameHarrie Schippers                             Sincerely,
Comapany NamePACCAR Inc
                                                               Division of
Corporation Finance
July 19, 2022 Page 3                                           Office of
Manufacturing
FirstName LastName