The Association of Global Automakers submitted comments on the California Air Resources Board's (CARB) Initial Statement of Reasons (ISOR) and proposed amendments to the Low-Emission Vehicle III (LEV III) greenhouse gas (GHG) emission regulation. Global Automakers believes that the proposed amendments are premature at this time in light of the ongoing discussions with the federal government on the Notice of Proposed Rulemaking (NPRM) for the potential changes to the federal light-duty GHG emissions and Corporate Average Fuel Economy (CAFE) programs and that these proposed amendments do not contribute to the spirit of continuing a "One National Program" (ONP).

Thus, Global Automakers has three requests related to CARB’s proposed actions, as detailed in our comments to CARB:

  1. Global Automakers would like the Board to direct staff to participate fully and in good faith in negotiations with the Administration on fuel economy and GHG emissions standards that would maintain “One National Program,” continuing the progress the auto  industry has made on improving fuel economy and GHG emissions performance; providing environmental benefits for the nation as a whole; and ensuring that automakers have the flexibility to produce a wide range of vehicles that meet the diverse needs of customers. 
  2. We would like the Board to defer action on today’s proposed amendments until such time as all parties are better informed as to whether a national solution can be crafted that meets the regulatory and environmental goals of California. 
  3. If CARB finds it necessary to move forward with the proposed amendments, additional regulatory amendments are needed to CARB’s program. Thus, the agency should work with stakeholders on amendments and compliance alternatives necessary for implementation of CARB’s regulations without the “deemed to comply” provision.