Global Automakers submitted comments to the Environmental Protection Agency on its request for comments on "Alternative Method for Calculating Off-Cycle Credits Under Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From Fiat Chrysler Automobiles and Toyota Motor North America." Global Automakers requested that EPA approve the applications for off-cycle technology credits.

Global Automakers and our members have consistently supported the goals of long-term greenhouse gas (GHG) reductions and the development of advanced, innovative technologies. To this end, the off-cycle credit program is an important and critical part of the GHG and Corporate Average Fuel Economy (CAFE) regulations. It recognizes the benefits of proven GHG and fuel consumption reductions beyond those measured with standard test procedures. The off-cycle credit program helps support flexible and cost-effective strategies for reducing GHG-related emissions while supporting industry investment in innovative and forward-looking technologies that provide real-world environmental benefits. Thus, Global Automakers reiterated our ongoing request to EPA to improve upon the implementation of the off-cycle program.