The Motor & Equipment Manufacturers Association (MEMA) wants the U.S. government agencies in charge of developing new light-duty vehicle greenhouse gas emission (GHG) and corporate average fuel economy (CAFE) regulations to establish and follow “compatible and consistent” standards to ease the financial burden on its members.
In comments submitted to the National Highway Traffic Safety Administration (NHTSA) and the Environmental Protection Agency (EPA) about the joint proposed rulemaking, MEMA president & CEO Bob McKenna said that vehicle manufacturers “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.”
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.
- Proposed revisions to mass reduction technologies should not be limited by percent or time constraints
- 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.
Under the joint notice of proposed rulemaking issued in September, EPA is proposing GHG standards under the Clean Air Act, while NHTSA is proposing the CAFE standards under the Energy Policy and Conservation Act.Both sets of standards will be “harmonized,” the agencies said, and will apply to light-duty trucks as well as passenger vehicles covering model years 2012 through 2016. In essence, auto makers would be able to build a single light-duty national fleet that satisfies all requirements under both programs while ensuring that consumers still have a full range of vehicle choices, both agencies said in t