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Alliance of Automobile Manufacturers comments on proposed MY2017-2025 LDV CAFE/GHG regulations

The Alliance of Automobile Manufacturers has filed comments in response to the Notice of Intent (NOI) and Technical Assessment Report (TAR) for MY2017-2025 light-duty vehicle fuel economy/greenhouse gas regulations released last month by Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) (earlier post).

In the comments, the Alliance outlined four specific concerns with the NOI and the accompanying Technical Assessment Report:

  1. The agencies should consider the critical role of fuel prices in ensuring public acceptance of more costly high-fuel economy vehicles.
  2. The Administration should establish a process by which an independent panel of experts periodically considers whether assumptions made in the standard setting process are still valid. To make this workable, the Alliance recommends that the 2017-2025 time frame be broken into segments of three or four years, and that this independent review take place prior to the agencies issuing a final rulemaking for each increment.
  3. The agencies should review the cost and technology assumptions in the Technical Assessment Report that were used to set the targets in the NOI.
  4. Additional analysis and discussion should take place on the potential effects of significant mass reductions on vehicle safety performance. Failure to undertake and complete these mandatory safety studies may render any final rule legally vulnerable, the Alliance suggested.

Automakers remain committed to the goals of the national program: a single, coordinated standard that promotes clean innovative vehicles, lowers greenhouse gas emissions, reduces dependence on foreign oil, and creates jobs. While the NOI and TAR represent a good start, it is clear that much work remains before new standards are proposed. The NOI references numerous additional analyses that EPA and NHTSA are working with the California Air Resources Board (CARB) to complete. We look forward to reviewing those studies.

—Alliance President and CEO, Dave McCurdy



Watch out, The AAM is the lobbying and coordination group for most of the auto companies doing business in the U.S. and they have a history of fighting any attempts to impose mileage requirements on the auto companies. What appears to be agreement is not necessarily really an okay.

The agencies should consider the critical role of fuel prices in ensuring public acceptance of more costly high-fuel economy vehicles.
In other words, tax gasoline.

This should be a no-brainer, but our policies have been essentially brainless for 3+ decades and counting.


Why should a light high fuel economy vehicle cost more than a heavy gas guzzler? This is strictly an AAM dishonest assumption.

The 2011 Sonata is much more frugal on gas than previous years models and cost less. The same can be said about 100+ other models.

AAM should have said that future, lighter, higher-fuel economy, 4-cyls vehicles will cost less, not more than current heavier V-6 and V-8.

Why can't those people tell the truth for a change.


It would be interesting to see if this alliance could be convinced that the electrification of transport could be a huge boon. If mileage requirements and escalating gasoline prices drive more consumers to purchase hybrid and EV autos - where does the Alliance lose? They may well sell MORE PHEVs than ICE vehicles simply because of the economies of electric energy vs. fossil energy.

They do have a point about an independent panel. This should be implemented.

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