## rn July2l,2011

The Honorable Lisa Jacksorf - C') 

### Administrator Environmental Protection 

# Aeiy 1200 Pennsylvania Avenue,N\/ Washington, DC 20004 The Honorable Ray Laflood Secretary Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590

Automotive Aftermarket Suppliers Association Heavy Duty Manufacturers Association Motor & Equipment Remanufacturers Association Original Equipment Suppliers Association 

# DAILY 

# iri-wii" rur, Motor & Equipment Manufacturers Association Your 

### First Ca/I for Global Intelligence on the Motor Vehicle Supplier Industry

1030 15th Street, NW, Suite 500 East • Washington, DC 20005 202-393-6362 • Fax: 202-737-3742 • www.mema.org



### Dear Secretary LaHood and Administrator Jackson: The Motor & Equipment Manufacturers Association (MEMA) represents more than 700 companies that manufacture motor vehicle parts for use in the light vehicle and heavy-duty original equipment and aftermarket industries. Motor vehicle parts suppliers are the nation's largest manufacturing sector, directly employing 685,892 U.S. workers and contributing to more than 3.2 million jobs across the country. This industry is a leader in developing technologies critical to making today's vehicles safer and more fuel efficient and is investing in product development to help meet future consumer demand. Suppliers also manufacture the aftermarket products necessary to repair and maintain over 247 million cars and trucks on the road today. Suppliers account for as much as 70 percent of the value-added in the manufacture of motor vehicles and over 30 percent of total automotive investment in research and development. The supplier industry continues to take on a greater role in the design, testing, and engineering of new vehicle parts and systems and on-going service requirements. The investment and manufacturing role of the supply base continues to grow as federal requirements and consumers demand cleaner, more fuel efficient, advanced vehicles. As suppliers, the economic vitality of our members is closely interwoven with the ability of the vehicle manufacturers to manufacture and sell affordable passenger cars and trucks. Over the last few years, the entire industry has undergone tremendous restructuring to improve its global competitiveness, and we caution the agencies to proceed in a way that will not hinder future economic growth and job creation. Furthermore, future standards must allow the manufacturers and suppliers to package new vehicles in a manner that is affordable for consumers to purchase and maintain. As you pursue the next round of standards, we also encourage you to continue building on the foundation created under the MY2012-2016 National Program standards, which consider our country's need for reducing fuel consumption by the motor vehicle sector while still preserving affordable choices for personal and commercial transportation needs. MEMA supports the preservation and continuation of a uniform National Program because it permits vehicle manufacturers and suppliers to allocate the required human and resources in the best manner to achieve the levels prescribed by the program. This, in turn, provides the best opportunity for the entire U.S. industry to continually innovate and to turn research activities into commercially viable manufacturing opportunities.MEMA Letter to Secretary LaHood and Administrator Jackson July 21, 2011, Page 2

In developing national standards for MY2017-2025, MEMA urges you to: Develop standards that adequately reflect product development cycles, minimize manufacturing capital investment requirements and recognize the capital stock of the current U.S. manufacturing base. Long-term planning is an especiafly important 

### factor in the motor vehicle industry as there are likely to be uncertainties in the product development cycle that could directly impact - positively or negatively - the commercial success of new products and the return on investment required to expand the U.S. manufacturing base.

• Provide for a mid-term review to evaluate the timelines and provisions of the standards.

• Consider all technology options available to achieve the overall objectives of reduced fuel consumption and emissions. Because there is a wide array of means by which attainable, discernible improvements can he made, it is important for any requirements to not only he attribute-based, but also technology-neutral. Since a true attribute-based system is not a 'one-size-fits-all" approach, it encourages more innovation in various vehicle types to improve fuel economy and emissions in all vehicle classes. Unfairly favoring one or two types of technology over others also inhihits industry innovation options and limits consumer choice. Over time, complex combinations of vehicle technologies will be required to improve fuel efficiency and emission levels.

• Consider appropriate changes to the fuel economy evaluation cycle to more accurately match real-world driving conditions and increase technology options.

• Maintain the proper use of credits in the standards, Credits are an important tool and can be positively applied and provide the industry necessary options to achieve future standards. However, credits can also inadvertently influence technology "winners and losers' and, as such, should he carefully evaluated during MY2O 17- 2025 standards development and the mid-term review. In addition, we would welcome an opportunity to discuss with you the important role of vehicle inspections and afterniarket technology in assuring continued efficiencies in fuel consumption and emissions for the fleet of automobiles and light trucks currently on the road. Thank you for your consideration of our views and we look forward to working with you on these issues.

Robert F. McKenna President and CEO