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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	regulat ory	affairs	for	the	Motor	&	Equipment Manufacturers	Association	(MEMA). i MEMA	is	pleased	to	be	here	today	for	the	opportunity	to	presen t 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.	C ollaboration	between	the	government and	a	wide	 variety	 of	 stakeholders	is	 key	 to	 the	 success	 of	 suc h	a	 significant	and	 complex	 technical regulation.

Particularly	over	the	past	two	decades,	the	medium‐	and	heavy‐d uty	sector	in	the	United	States	has made	 considerable	 strides	 in	 impr oving	 the	 safety	 and	 efficienc y	 of	 engines	 and	 vehicles.	 Further improvements	 present	 a	 set	 of	 considerable	 challenges.	 These	 ar e	 challenges	 that	 suppliers	 are prepared	to	tackle.

MEMA	would	like	to	present	the	f ollowing	preliminary	comments.

 Comment Period –	MEMA	recognizes	and	respects how	important	it	is	for	the	age ncies	to	meet
the	Administration’s	deadlines	i n	promulgating	this	rulemaking. But	we	also	believe	it	is	critical to	ensure	 that	stakeholders	have	as	much	 time	as	possible	 to	di gest	 this	complex	rule	and	 to provide	substantive,	useful	feedback	to	the	agencies.	Any	addit ional	time	the	agencies	can	afford to	add	to	the	comment	period	–	even	a	short	term	extension	of	o ne	or	two	weeks	–	would	be appreciated.

 Regulatory Framework –	With	the	promulgation	of	the	Phase	1	rule,	our	industry	inve sted	a great	 deal	 of	 resources	 to	 devel op	 and	 supply	 the	 technologies that	 would	 assure	 that	 the
standards	 were	 attainable	 and	 co st‐effective	 for	 our	 customers. Continuation	 of	 a	 uniform program	allows	 vehicle	manufacturers	 to	 continue	investing	in	 t he	 technologies	 vehicles	willMEMA 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	 support s	 sustaining	 a	 single, nationwide	 program.	 This	 approach	 provides	 regulatory	 clarity	 a nd	 is	 vital	 to	 its	 success. The	 federal	 and	 state	 agencies	 must	 avoid	 any	 potential	 inconsi stencies	 in	 their	 respective regulations.	Also,	retaining	the	separate	vehicle	and	engine	re quirements	provides	continuity	of the	 standards’	 regulatory	 structures	 and	 strikes	 a	 balance	 betw een	 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	stan dards,	particularly	during	the middle	and	latter	stages	of	the	rule.

 Engine Stringencies –	Overall,	as	a	group	we	believe	that	the	technologies	availab le	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	 individu al	 members	 are	 still evaluating	 and	 working	 on	 develo ping	 specific	 suggestions	 to	 be provided	 in	 our	 written

comments.

 Fuel Neutrality –	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	compr omised.

o With	 respect	 to	 heavy‐duty	 pickups	 and	 vans,	 MEMA	 proposes	 an	 a lternative	 to	 the proposed	rule	that	would	simply	require	a	16%	fleet	average	CO 2 emissions	reduction. Consequently,	the	industry	and	customers	pick	the	fuel	and	tech nology	combination	that offers	the	best	value	while	also	meeting	the	requirement.	Moreo ver,	this	would	make	the regulatory	approach	similar	to	the	CAFE	standards	already	in	pl ace	for	light‐duty	vehicles and	provide	the	intended	CO 2 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	 regulat ions	 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	ag encies	and	will	address	this	i n	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	signifi cant	amount	of	research	and	data to	offer	a	proposal	that	is	more representative	of	real‐world	a pplications.

o MEMA	supports	the	proposed	enhanced,	distance‐based	duty	cycles with	road	grade,	the additional	 transient	 test,	 the	 optional	 powertrain	 test,	and	 ot her	 program	 flexibilities. These	offer	visibility	 to	 the	be nefits	of	 technologies	previous ly	unseen	in	Phase	1	and offer	more	real‐world	parameters to	account	for	those	technolog ies	not	captured	under the	GEM	(greenhouse	gas	emissions	model).

o Regarding	 the	 GEM,	 MEMA	 appreciates	 the	 agencies’	 strategy	 to	 a ddress	 a	 host	 of non‐powertrain	technologies	in	the	proposed	rule	under	the	mode l	as	well	as	in	aspectsMEMA 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	 inpu ts	 more	 accurately exemplifies	 vehicle	 performance	 and	 provides	 compliance	 benefit s	 to	 vehicle manufacturers	that	adopt	improved	features.	We	also	encourage	t he	agencies	to	consider expanding	the	GEM	inputs	to	include	additional	technologies;	su pporting	details	about this	are	forthcoming	in	written comments	from	ME MA	and	individu al	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	techn ologies	and	will	provide more	commentary.	Although,	one	point	about	the	process;	MEMA	be lieves	that	suppliers should	 be	 offered	 the	 same	 opportunity	 as	 OEMs	 to	 pursue	 the	 pa th	 to	 have innovative/off‐cycle	technologies approved/recognized	by	develo ping	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	m ore	feedback	to	the	agencies	i n	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).