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