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Oral Statement of the

Motor & Equipment Manufacturers Association (MEMA)

Before the  

U.S. Environmental Protection Agency & U.S. Department of Transportation’s National

Highway Traffic Safety Administration  

RE: Proposed Rules for Greenhouse Gas Emissions and Fuel Efficiency Standards  

for Medium‐ and Heavy‐Duty Engines and Vehicles – Phase 2

Docket No. EPA–HQ–OAR–2014–0827; NHTSA‐ 2014‐0132

August 18, 2015 – Long Beach, California

My	name	is	Leigh	Merino	and	I	am	the	senior	director	of	regulatory	affairs	for	the	Motor	&	Equipment	

Manufacturers	Association	(MEMA).i

	MEMA	is	pleased	to	be	here	today	for	the	opportunity	to	present	

our	statement	about	the	proposed	rule.		

MEMA	 and	 our	 heavy	 vehicle	 supplier	 member	 companies	 appreciate	 the	 outreach	 from	 and	

engagement	with	the	U.S.	EPA	and	NHTSA	and	commend	the	agencies	for	their	open	and	collaborative	

approach,	and	their	receptiveness	to	stakeholder	suggestions.	Collaboration	between	the	government	

and	a	wide	 variety	 of	 stakeholders	is	 key	 to	 the	 success	 of	 such	a	 significant	and	 complex	 technical	

regulation.		

Particularly	over	the	past	two	decades,	the	medium‐	and	heavy‐duty	sector	in	the	United	States	has	

made	 considerable	 strides	 in	 improving	 the	 safety	 and	 efficiency	 of	 engines	 and	 vehicles.	 Further	

improvements	 present	 a	 set	 of	 considerable	 challenges.	 These	 are	 challenges	 that	 suppliers	 are	

prepared	to	tackle.		

MEMA	would	like	to	present	the	following	preliminary	comments.	

 Comment Period	–	MEMA	recognizes	and	respects	how	important	it	is	for	the	agencies	to	meet	

the	Administration’s	deadlines	in	promulgating	this	rulemaking.	But	we	also	believe	it	is	critical	

to	ensure	 that	stakeholders	have	as	much	 time	as	possible	 to	digest	 this	complex	rule	and	 to	

provide	substantive,	useful	feedback	to	the	agencies.	Any	additional	time	the	agencies	can	afford	

to	add	to	the	comment	period	–	even	a	short	term	extension	of	one	or	two	weeks	–	would	be	

appreciated.	

 Regulatory Framework	–	With	the	promulgation	of	the	Phase	1	rule,	our	industry	invested	a	

great	 deal	 of	 resources	 to	 develop	 and	 supply	 the	 technologies	 that	 would	 assure	 that	 the	

standards	 were	 attainable	 and	 cost‐effective	 for	 our	 customers.	 Continuation	 of	 a	 uniform	

program	allows	 vehicle	manufacturers	 to	 continue	investing	in	 the	 technologies	 vehicles	will	
MEMA Oral Statement; USDOT‐NHTSA & USEPA Public Hearing

RE: EPA‐HQ‐OAR‐2014‐0827; NHTSA‐2014‐0132

August 18, 2015

2

need	 to	 reach	 and	 exceed	 Phase	 2	 targets.	 MEMA	 strongly	 supports	 sustaining	 a	 single,	

nationwide	 program.	 This	 approach	 provides	 regulatory	 clarity	 and	 is	 vital	 to	 its	 success.		

The	 federal	 and	 state	 agencies	 must	 avoid	 any	 potential	 inconsistencies	 in	 their	 respective	

regulations.	Also,	retaining	the	separate	vehicle	and	engine	requirements	provides	continuity	of	

the	 standards’	 regulatory	 structures	 and	 strikes	 a	 balance	 between	 compliance	 and	 market	

latitude.	Lastly,	the	longer	timeframe	for	Phase	2	provides	the	industry	the	foresight	and	clarity	

to	develop	the	technologies	needed	to	continue	to	meet	the	standards,	particularly	during	the	

middle	and	latter	stages	of	the	rule.	

 Engine Stringencies	–	Overall,	as	a	group	we	believe	that	the	technologies	available	in	the	near‐

term	and	in	the	pipeline	are	feasible	and	achievable.	Even	so,	MEMA	believes	there	may	be	some	

opportunities	 to	 boost	 the	 engine	 stringencies	 to	 further	 drive	 innovation	 and	 technology	

throughout	 the	 Phase	 2	 timeframe.	 MEMA	 and	 some	 of	 our	 individual	 members	 are	 still	

evaluating	 and	 working	 on	 developing	 specific	 suggestions	 to	 be	 provided	 in	 our	 written	

comments.		

 FuelNeutrality	–	MEMA	maintains	that	instituting	performance‐based	standards	is	the	best	way	

to	ensure	that	there	are	no	unintended	market	shifts	resulting	from	the	standards	and	that	the	

overall	objectives	of	the	program	are	not	unintentionally	compromised.	

o With	 respect	 to	 heavy‐duty	 pickups	 and	 vans,	 MEMA	 proposes	 an	 alternative	 to	 the	

proposed	rule	that	would	simply	require	a	16%	fleet	average	CO2	emissions	reduction.	

Consequently,	the	industry	and	customers	pick	the	fuel	and	technology	combination	that	

offers	the	best	value	while	also	meeting	the	requirement.	Moreover,	this	would	make	the	

regulatory	approach	similar	to	the	CAFE	standards	already	in	place	for	light‐duty	vehicles	

and	provide	the	intended	CO2	reduction	in	the	most	cost‐effective,	customer‐friendly,	and	

technology‐neutral	way.		

o Additionally,	MEMA	is	concerned	with	 the	agencies’	proposal	 to	exclude	gasoline	engines	

from	the	vocational	portion	of	the	rule	and	about	the	potential	market	impact	(a	possibility	

the	 agencies	 acknowledged	 in	 the	 NPRM).	 We	 believe	 that	 regulations	 that	 continue	 to	

increase	the	technical	complexity	of	diesel	engines	relative	to	gasoline	engines	may	result	in	

a	 much	 larger	 market	 share	 for	 gasoline	 in	 this	 space.	 MEMA	 is	 evaluating	 possible	

approaches	to	recommend	to	the	agencies	and	will	address	this	in	our	written	comments.	

 Wide Array of Technologies Recognized	–	MEMA	reinforces	our	appreciation	to	the	agencies	

for	the	scope	and	scale	of	their	endeavors	to	conduct	a	significant	amount	of	research	and	data	

to	offer	a	proposal	that	is	more	representative	of	real‐world	applications.		

o MEMA	supports	the	proposed	enhanced,	distance‐based	duty	cycles	with	road	grade,	the	

additional	 transient	 test,	 the	 optional	 powertrain	 test,	and	 other	 program	 flexibilities.	

These	offer	visibility	 to	 the	benefits	of	 technologies	previously	unseen	in	Phase	1	and	

offer	more	real‐world	parameters	to	account	for	those	technologies	not	captured	under	

the	GEM	(greenhouse	gas	emissions	model).	

o Regarding	 the	 GEM,	 MEMA	 appreciates	 the	 agencies’	 strategy	 to	 address	 a	 host	 of		

non‐powertrain	technologies	in	the	proposed	rule	under	the	model	as	well	as	in	aspects	
MEMA Oral Statement; USDOT‐NHTSA & USEPA Public Hearing

RE: EPA‐HQ‐OAR‐2014‐0827; NHTSA‐2014‐0132

August 18, 2015

3

of	 the	 vehicle	 and	 trailer	 standards.	 The	 broader	 range	 of	 inputs	 more	 accurately	

exemplifies	 vehicle	 performance	 and	 provides	 compliance	 benefits	 to	 vehicle	

manufacturers	that	adopt	improved	features.	We	also	encourage	the	agencies	to	consider	

expanding	the	GEM	inputs	to	include	additional	technologies;	supporting	details	about	

this	are	forthcoming	in	written	comments	from	MEMA	and	individual	suppliers.	

o As	 for	 supplements	 to	 the	 GEM, MEMA	 is	 still	 evaluating	 the	 details	 of	 the	 agencies’	

proposals	to	address	and	account	for	innovative/off‐cycle	technologies	and	will	provide	

more	commentary.	Although,	one	point	about	the	process;	MEMA	believes	that	suppliers	

should	 be	 offered	 the	 same	 opportunity	 as	 OEMs	 to	 pursue	 the	 path	 to	 have	

innovative/off‐cycle	technologies	approved/recognized	by	developing	a	test	procedure	

with	quantifiable	benefits,	and	submitting	for	a	public	review	by	the	agency.	

MEMA	appreciates	your	time	today.	MEMA	and	our	members	continue	to	closely	evaluate	the	NPRM	

and	we	are	committed	to	provide	more	feedback	to	the	agencies	in	our	written	comments.		

Thank	you.	

# # #

i MEMA represents vehicle suppliers through the following four divisions:  Automotive Aftermarket Suppliers Association (AASA), Heavy

Duty Manufacturers Association (HDMA), Motor & Equipment Remanufacturers Association (MERA) and Original Equipment Suppliers

Association (OESA).