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Comment 2 for LEVIII GHG and ZEV (leviiidtc12) - 45 Day.

First NameJoseph
Last NameKubsh
Email Addressjkubsh@meca.org
AffiliationMECA
SubjectMECA support for GHG compliance flexibilities
Comment
The Manufacturers of Emission Controls Association (MECA) is
pleased to indicate our industry's support of the California Air
Resources Board’s proposal to permit compliance with federal
greenhouse gas emission standards for light-duty vehicles to serve
as compliance with ARB's vehicle greenhouse gas emission standards.
 These amendments provide needed flexibility that ensure a single
national program to reduce climate change emissions and improve
vehicle fuel economy.  MECA applauds ARB and EPA for finalizing a
comprehensive and largely harmonized set of proposals covering
light-duty vehicle greenhouse gas emissions that will result in a
single national program for reducing the climate impacts of future
vehicles (through 2025).  

MECA is a non-profit association of the world’s leading
manufacturers of emission control technology for mobile sources. 
Our members have over 40 years of experience and a proven track
record in developing and manufacturing emission control technology
for a wide variety of on-road and off-road vehicles and equipment,
including extensive experience in developing exhaust and
evaporative emission controls for gasoline and diesel light-duty
vehicles in all world markets.  Our industry has played an
important role in the emissions success story associated with
light-duty vehicles in California, and has continually supported
efforts to develop innovative, technology-forcing, emissions
programs to deal with California’s unique air quality problems.

	The experience of our industry over the last 40 years vividly
demonstrates the connection between vehicle emission regulation and
economic development.  Prior to 1970, our industry did not exist. 
But, with the enactment of the Clean Air Act in 1970, our industry
has flourished, developing successive generations of technology to
meet ever tightening regulatory standards.  Since the introduction
of the catalytic converter in 1975, more than 500 million
light-duty vehicles have been sold in the United States equipped
with exhaust and evaporative emission control technologies
developed by our industry.  This generated an estimated $250-$300
billion in economic activity since 1975.  In 2010 alone, our
industry generated $12 billion of economic activity and accounted
for 65,000 U.S. jobs, mostly in manufacturing.  ARB’s LEV III
amendments and greenhouse gas emission standards on light-duty
vehicles will provide additional support for the continued
development of a thriving U.S. industry focused on a wide range of
technologies that can reduce vehicle criteria and greenhouse gas
emissions.

Dr. Joseph Kubsh
Executive Director, MECA

Attachment
Original File Name
Date and Time Comment Was Submitted 2012-11-13 08:14:13

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