Washington, D.C. – The Alliance of Automobile Manufacturers has outlined concerns regarding the U.S. government’s proposed stringent fuel economy and greenhouse gas standards, warning that factors such as cost and consumer acceptance must be taken into consideration.

The Alliance is an association of twelve vehicle manufacturers including BMW Group, Chrysler, Ford, General Motors, Jaguar Land Rover, Mazda, Mercedes-Benz USA, Mitsubishi, Porsche, Toyota, Volkswagen and Volvo Cars North America.

In its report, the Alliance said that it “continues to support a single, national program that minimizes the disruptions of multiple programs on vehicle choice and availability. The Administration fundamentally accomplished this objective with its rulemaking governing greenhouse gas (GHG) emissions and fuel economy for the model year 2012-2016 timeframe.”

The Alliance said that in its comments on the original rule, it encouraged the U.S. Environmental Protection Agency (EPA) and the National Highway Transportation Safety Administration (NHTSA) to continue the single national program beyond 2016. “However, given the greater level of uncertainty for the model year 2017-2025 timeframe, a numeric commitment was not possible,” the Alliance said in its statement. “Those uncertainties remain, and it is essential that the federal government develop an integrated process that takes into account factors critical to the success of higher fuel economy standards, such as infrastructure, fuels and fuel quality, and consumer acceptance.”

The Alliance offered the following suggestions:

– That the agencies should consider the critical role of fuel prices in ensuring public acceptance of more costly high-fuel-economy vehicles.

– The Alliance has identified certain fundamental assumptions underlying the proposed standards that “highlight areas of uncertainty the agencies will need to revisit going forward. Many of these uncertainties go well beyond identification of technologies, costs, fuel economy improvements and GHG reductions.” The Alliance is asking the government to establish a process by which an independent panel of experts periodically considers whether assumptions made in the face of these uncertainties were valid. “Such a process would help to assure that all elements of a low-carbon transportation future – advances in fuel efficient technologies, consumer demand, low-carbon fuels and the infrastructure to deliver these fuels – arrive together.” The Alliance recommends that the 2017-2025 timeframe be broken into segments of three or four years, with an independent review taking place prior to a final rulemaking for each increment.

– The Alliance wants the EPA and NHTSA to revisit several assumptions as they work to prepare revised documents and to draft a proposed rule, including the rates and cost methodology used in various studies.

– Additional analysis and discussion are needed on the potential effects of significant mass reductions, required for fuel economy, on vehicle safety performance.

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