While, MEMA, The Vehicle Suppliers Association, and its members strongly support the objectives of the Environmental Protection Agency (EPA) to improve national air quality through improvements to light- and medium-duty vehicles, in comments submitted to EPA on July 5, 2023, the association urged the agency to address a wide range of challenges to ensure success for all parties.
“The success of our industry is interwoven with the success of this proposal and the ability of the government to work with industry and other stakeholders to meet significant challenges,” commented Ann Wilson, senior vice president government affairs, MEMA, “We are firm in our support of EPAs efforts in improving national air quality through emissions regulations, and with the additional considerations submitted through MEMA’s comments, we hope the go forward plan will successfully meet the complex needs of a transforming U.S. vehicle fleet.”
MEMA urges EPA to address the following:
• The need for regulatory certainty. The final rule must contain an effective mix of feasible, demonstrated technology along with emerging technology, leaving options to improve emissions reductions in today’s advanced propulsion designs.
• The influence of other technologies. Including internal combustion engines fueled by hydrogen and other renewable carbon-neutral fuels – which can impact and make measurable environmental improvements at scale.
• Technology Neutrality and BEV Emissions. EPA should ensure that battery electric vehicles (BEV) are included in metrics for vehicle-to-vehicle comparison.
• Challenges in our nation’s infrastructure and power grid. Federal and state incentives are needed to further expand the EV charging and refueling infrastructure in areas that connect these major thoroughfares.
• Supply chain challenges. The proposed rule assumes that all materials for advanced vehicles, which are not available today in the quantities needed to support the massive growth in vehicle construction, will become available within sufficient time. This places a significant and unnecessary risk on manufacturers and suppliers.
• Workforce challenges. A significant increase in skilled workers will be needed to support the implementation of this rule and long-term success thereof.
• Extended warranty. The necessity to clearly define the applicability of the extended warranty and the need to provide repair access to service these new vehicles.
MEMA, The Vehicle Suppliers Association, is the leading trade association in North America for vehicle suppliers, parts manufacturers, and remanufacturers. It has been the voice of the vehicle supplier industry since 1904. Its more than 1,000 members are Strong by Association.
Companies join MEMA via two membership groups: MEMA Aftermarket Suppliers and MEMA Original Equipment Suppliers. Automotive and commercial vehicle suppliers are the largest manufacturing sector in the United States and lead the way in new vehicle innovations.
Members conceive, design, and manufacture the OE systems and technologies that make up two-thirds of the value of every vehicle and supply the aftermarket with the parts that keep millions of vehicles on the road, fueling international commerce and meeting society’s transportation needs. MEMA members are committed to safety and sustainability.
MEMA has offices in Southfield, Mich.; Research Triangle Park, N.C.; and Washington, D.C. Learn more at MEMA.org.
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