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                              September 16, 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
                                                            Response Dated
August 30, 2022
                                                            File No. 001-14817

       Dear Mr. Schippers:

              We have reviewed your August 30, 2022 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       July 19, 2022 letter.

       Response Dated August 30, 2022

       Risk Factors, page 10

   1.                                                   Your response to prior
comment two states that your primary transition risks related to
                                                        climate change are
meeting changing customer demand and achieving your science-based
                                                        targets. However, it
does not appear that disclosure in your Form 10-K addresses these
                                                        risks in the context of
climate change. Please revise to provide disclosure that specifically
                                                        addresses the
transition risks you have identified related to climate change and their
                                                        impact to your
business, operations, and financial condition.
 Harrie Schippers
FirstName  LastNameHarrie Schippers
PACCAR Inc
Comapany 16,
September  NamePACCAR
               2022        Inc
September
Page 2     16, 2022 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
16

2.       In response to prior comment four, you detail various statutory and
regulatory
         requirements governing emissions relevant to your business and
operations. You also
         state that you have set emissions targets to meet the goals of the
Paris Agreement.
         Consistent with our prior comment, please revise your disclosure to
identify legislation,
         regulations, and international accords related to climate change.
3.       Your responses to prior comments five and eight appear to suggest that
you are incurring
         material amounts of capital expenditures and compliance costs related
to reducing
         environmental impacts and emissions compliance with increases expected
in future
         periods. Please further explain to us how you considered providing
quantitative disclosure
         regarding past and future capital expenditures for climate-related
projects and compliance
         costs related to climate change. In addition, as your response states
that you do not
         categorize amounts incurred as    climate-related    and    not
climate-related," please
         describe your consideration of the disclosure requirement per Item
101(c)(2)(i) of
         Regulation S-K.
4.       We note your response to prior comment six does not provide all of the
requested
         information. Please more fully describe the indirect consequences of
climate-related
         regulation or business trends, including the specific items noted in
our comment, and tell
         us how you concluded whether they were material.
5.       We note your response to prior comment seven and reissue in part.
Please include the
         quantification requested by our comment on an aggregate basis, rather
than as a
         quantitative example, for each of the periods covered by your Form
10-K and those
         subsequent to year-end.

         In addition, your response states that you recognize the potential of
physical risks to your
         production facilities and supply chains from severe weather. Please
provide us with
         additional detail explaining how you considered providing disclosure
regarding the
         potential for the physical effects of climate change to affect your
operations and results
         and possible indirect financial and operational impacts to you from
disruptions to the
         operations of your customers from severe weather.
6.       We note your response to prior comment nine. Beyond your purchase of
European Union
         Allowances in 2021, please also provide us with quantitative
information related to your
         purchase of carbon credits or offsets for the other periods for which
financial statements
         are presented in your Form 10-K, and for the sale of carbon credits or
offsets, if
         applicable. Please also tell us about any planned future period
transactions.
 Harrie Schippers
FirstName  LastNameHarrie Schippers
PACCAR Inc
Comapany 16,
September  NamePACCAR
               2022        Inc
September
Page 3     16, 2022 Page 3
FirstName LastName
       Please contact Erin Donahue at 202-551-6063 or Sergio Chinos at
202-551-7844 with
any questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Manufacturing