WASHINGTON, D.C. – The Motor & Equipment Manufacturers Association (MEMA) has 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 continued.
 
Specifically, MEMA’s comments has 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.