The Motor & Equipment Manufacturers Association (MEMA) filed comments with the National Highway Traffic Safety Administration (NHTSA) and the Environmental Protection Agency (EPA) responding to a joint proposed rulemaking issued by the agencies to establish light-duty vehicle greenhouse gas emission standards and corporate average fuel economy standards.

In a letter submitted with the comments, MEMA president and CEO Bob McKenna stated that suppliers are “encouraged by the collaborative efforts” of NHTSA and EPA to undertake their work under one National Program.  “Compatible and consistent standards allow vehicle manufacturers to focus their resources on investing in the best technologies, which, in turn, feeds the ability of the supplier base to advance development and transfer research technologies into commercially viable products,” McKenna says.

Specifically, MEMA’s comments asked NHTSA and EPA to consider the following points:

• Standards must be technology-neutral and not inadvertently favor or promote certain technologies.
• Test cycle calculations must be revised to reflect real-world driving conditions. A simple calculation change under this current rulemaking can help industry provide vehicle solutions that address present-day driving habits and give industry long-term planning confidence.
• Proposed revisions to mass reduction technologies should not be limited by percent or time constrained.
• Complete battery system cost should be more clearly defined; distinguish cell cost and pack cost.
• Diesel technologies must be applied to 4-cylinder engines in the Volpe Model and not just applied to engines of 6-cylinders or more.
• Air conditioning system credits must better represent the benefit of the technology. The single-vehicle test protocol must be revised and more reflective of real-world conditions.
• The impact of real-time traffic information on emissions and fuel consumption should be evaluated for potential CAFE credit.

MEMA represents motor vehicle parts suppliers, the nation’s largest manufacturing sector, employing nearly 686,000 people across the country.  Suppliers are also the largest manufacturing employer in eight states. These jobs contribute to 3.29 million private sector jobs across the country. Suppliers manufacture the parts and technology used in domestic production of new cars and trucks produced each year, and the aftermarket products necessary to repair and maintain more than 247 million vehicles on the road today.

MEMA supports its members through its three affiliate associations, Automotive Aftermarket Suppliers Association (AASA), Heavy Duty Manufacturers Association (HDMA), and Original Equipment Suppliers Association (OESA).  MEMA represents more than 650 member companies with global motor vehicle parts sales exceeding $600 billion and 65 percent of North American automotive supplier sales.