September 26, 2016 – NACAA submitted comments to EPA, NHTSA and CARB on the three agencies’ draft Technical Assessment Report (TAR) related to the Midterm Evaluation of the Model Year (MY) 2022-2025 light-duty vehicle GHG and CAFE standards adopted in 2012.  In the comments, NACAA highlights the similar key conclusions reached by EPA and NHTSA based on their independent technical analyses and concurs with those conclusions, observing, among other things, that “automakers are firmly on track to meet the MY 2022-2025 standards without issue.”  The association also identifies and comments on some differences between the analyses conducted by EPA and NHTSA – including different assumptions related to the penetration of rates of Zero Emission Vehicles and “Skyactiv” and Atkinson Cycle technology as well as the timing of full compliance – which result in higher cost estimates by NHTSA.  NACAA also focuses on next steps post 2025, noting that “the magnitude and pace of technological innovation and advancement since 2012, as well as the cost effectiveness of these technologies, set the stage for next steps to further reduce GHG emissions and fuel efficiency from the light-duty fleet post 2025.”