The Association of Global Automakers' (Global Automakers) comments on the Notice of Proposed Rulemaking for Light-duty Vehicle GHG Program Technical Amendments supported moving forward with these important technical amendments as soon as possible. In addition to supporting these amendments, however, Global Automakers has identified a few areas of concerns to address in finalizing the amendments.


  • Clarify the rounding method presented in the proposal’s advanced technology vehicle (ATV) multiplier calculation. Depending on total volume, CO2 level, and EV/PHEV penetration rate, the end credit value can nontrivially vary due to rounding effects.
  • Clarify the awarding of off-cycle credits (OCC) for all technologies; and
  • Clearly define the term “baseline technology (item and efficiency)” as it relates to OCC technologies.