In detailed comments submitted to the Trump administration today, the Motor & Equipment Manufacturers Association (MEMA) again asserted that freezing progress in the fuel efficiency and vehicle emissions standards will impact American jobs and strand significant U.S. investments in technology development. MEMA also emphasizes supplier’s need for a One National Program negotiated with California that provides long-term regulatory certainty.
The comments, sent to the National Highway Traffic Safety Administration (NHTSA) and the U.S. Environmental Protection Agency (EPA), were in response to the notice of proposed rulemaking of the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model years 2021-2026 for Passenger Cars and Light Trucks.
“MEMA supports continued year-over-year increases to the stringency of the CAFE and the GHG vehicle emissions standards for light vehicles starting in 2021 and extending until 2026,” the comments say. “If the agencies eliminate progress in the standards through 2026, suppliers are at the greatest risk of having stranded investments. Suppliers have made long-term planning decisions committing to developing the necessary technologies and materials for their customers to meet the targets set for MYs 2017 – 2021 and the augural standards for MYs 2022 – 2025.”
The progress of fuel efficiency and vehicle emissions standards is necessary to maintain the sustained job growth in manufacturing jobs that the industry has seen in the last five years and to help U.S. companies compete in a highly competitive global marketplace in a race to develop fuel-efficient technologies. MEMA urges the agencies to continue the credit programs, particularly the off-cycle, A/C efficiency and the alternative mobile A/C refrigerant credit programs through 2026 and beyond. MEMA argues these credit programs provide are “essential for supplier investments and jobs.”
“Eliminating progress in the standards through 2026 would have a detrimental economic impact on U.S. supplier manufacturing jobs – the largest sector of manufacturing jobs in the U.S. – employing over 871,000 workers in all 50 states with a total impact of 4.26 million jobs,” MEMA’s comments say. “Continued progress in the standards is necessary to continue strengthening technology development and supplier manufacturing sector jobs.” MEMA argues that if progress in the standards is eliminated, it will impact U.S. supplier jobs, these are jobs that the U.S. will lose to other markets, including China.
In these comments and in recent testimony before the two agencies, MEMA has repeatedly argued that eliminating progress in the fuel efficiency and vehicle emissions standards will result in the U.S. losing its lead in technological innovation.
“The U.S. has a strong history of being a global leader in innovation. Our nation is uniquely positioned to lead the world in advanced fuel efficiency and emissions-reducing technologies. Continued progress in the standards is necessary to preserve U.S. competitiveness,” the comments conclude.