"Overall, our members support the administration's approach to bring together the medium- and heavy-duty vehicle fuel efficiency standards and GHG emissions standards into a joint Heavy-Duty National Program," said Bob McKenna, MEMA's president and CEO. "A uniform program will allow vehicle and engine manufacturers to invest in appropriate technologies to reach and exceed the targets and it will also help the supplier base advance development and commercialize new technologies."
"However, we urge the agencies to consider several issues moving forward in order to achieve maximum efficiency," McKenna continued.
MEMA's comments made the following recommendations:
* Advanced technologies listed for credit should be expanded;
* Advanced vehicle technologies credits are needed for the vocational vehicle category;
* Power pack testing should be expanded to other drivetrain, non-engine, and advanced/innovative technologies;
* Innovative technologies should have a defined review and approval process;
* Innovative technologies should not be restricted and should be available beyond MY2018;
* Duty cycle should define targets and classification for overlapping classes for Class 7 and 8 vehicles;
* Mass reduction proposals should be reevaluated;
* GEM input credits for idle reduction should be modified;
* Additional simulation drive cycles are needed to capture more vocational applications;
* The agencies should work toward performance-based standards.
"Parts suppliers are critical to producing the results the administration seeks," said Tim Kraus, president and COO of the Heavy Duty Manufacturers Association, an affiliate association of MEMA. "Without further reflection and action on the items mentioned in the comments, as well as an expansion of advanced technologies eligible for credit and a clear process for stakeholders to submit technologies for regulatory flexibility credits, it will be a great deal more difficult to meet our common goals."