The Motor Equipment Manufacturers Association (MEMA) and its members welcome the Environmental Protection Agency’s final rule for Greenhouse Gas Emissions Standards for Heavy-Duty Vehicles Phase 3, released March 29, 2024.
MEMA and its members support the objectives of the EPA to improve national air quality through improvements to heavy-duty vehicles and applauds the agency for incorporating improvements to the rule as advocated by MEMA. The supplier industry directly designs and manufactures vehicle components and systems that enable the transformation of the mobility sector. Suppliers play an essential role in providing the technology inherent to advanced internal combustion engine vehicles, plug-in hybrid electric vehicles (PHEVs), battery electric vehicles (BEVs), as well as hydrogen fuel cell vehicles.
The EPA final rule includes an amended and more comprehensive analysis of compliance pathways for a variety of propulsion technologies, including plug-in hybrid (PHEV), BEVs, hydrogen fuel cell electric vehicles (FCEV), hydrogen combustion (H2ICE), and other renewable fuel vehicles. This should allow for more technologies to achieve compliance. Of note is the EPA’s decision to grant additional time for certain vocational vehicles to comply by allowing different classes varying amounts of compliance time and adjusting stringency accordingly. The EPA also relaxed stringency in the early years of the implementation timeline, while still achieving significant CO2 reductions.
Providing greater flexibility for hard-working trucks was a key issue for MEMA members, and EPA responded affirmatively. EPA will also allow trading and averaging of compliance within some classes, to further enable fleet compliance despite individual application and vehicle challenges. MEMA had raised points concerning credit multipliers, which the EPA has now stated will be phased out gradually over time, again enhancing flexibility for compliance. MEMA welcomes these notable changes and believes that they will contribute toward a more balanced and holistic standard.
EPA further recognized concerns surrounding requisite infrastructure and services and made a specific commitment to track and report on feasibility and status. MEMA looks forward to engaging with EPA to understand how this monitoring will be implemented and understanding how the agency will weigh and address real-world issues.