5 minute read
2020 MEMA Advocacy Accomplishments
2020 ADVOCACY ACCOMPLISHMENTS
Policy Implementation in Action for Vehicle Suppliers
Advertisement
When the pandemic closed much of the U.S. economy, MEMA was instrumental in addressing key industry concerns including: • Designating vehicle parts employees as essential workers. • Advocating for states to make a similar designation. • Tracking state and local COVID-19 regulations. • Helping Congress pass more than $3.4 trillion in four broad relief packages, including the Paycheck Protection
Program (PPP) relief for small businesses and the Main
Street Lending Program (MSLP) for medium-sized businesses.
• Creating an open dialogue on the impact COVID-19 had in
Mexico and other trading partners.
Trade
USMCA
For much of 2020, the implementation of the USMCA was a critical focus for vehicle suppliers. During the process, MEMA actively engaged with the White House, the Office of the United States Trade Representative (USTR), and United States Customs and Border Protection (CBP). The Association:
• Was critical in attaining final Senate passage of USMCA.
MEMA’s strong efforts were recognized when senior
MEMA leaders were invited to the White House for the
USMCA signing ceremony. • Led industry efforts on identifying, drafting, and passing legislation to address the error in the agreement regarding the refundability of Merchandise Processing Fee (MPF). • Worked closely with the industry and the administration to address the new, complex USMCA Rule of Origin provisions.
Tariffs
• MEMA submitted comments on the Section 232 Exclusions
Process and Section 232 Electrical Steel Investigation. • MEMA opposed the reinstatement of the Sec 232 tariffs on
Canada.
• MEMA supported the extension of existing product exclusions for Section 301 tariffs.
Other Trade Policy Advocacy
• MEMA continued to lead policy discussions about the impact trade has on the vehicle supplier industry. For example, MEMA testified before the U.S. International
Trade Commission about the economic impact of trade agreements and submitted a letter to key congressional committees – Senate Finance and House Ways and
Means – regarding 2020 Trade Policy Agenda. • Export Controls • MEMA submitted comments to the Department of Commerce regarding its review of controls on certain foundational technologies. • MEMA supported efforts to seek clarifications “military end use” vis-à-vis trade controls.
Vehicle Safety
The regulatory agenda remained muted during most of 2020. There are a few legislative activities with regulatory and policy implications on vehicle safety. • MEMA strongly advocated for retaining the 5.9 GHz spectrum for vehicle communications and opposed the
Federal Communication Commission’s decision to split the spectrum and share bandwidth for other unlicensed devices and applications. • MEMA and Alliance of Automotive Innovation sent a joint letter to NHTSA urging them to issue a proposed rule to allow domestic manufacturers temporary exemptions for research, demonstrations and other purposes. In the last days of the Trump Administration, NHTSA issued a preview notice of an Interim Final Rule, but it was never officially published in the Federal Register.
• MEMA engaged with Capitol Hill and committee staff on legislative initiatives including: • MEMA provided comments and recommendations on the Five-Stars for Safe Cars Act, which would require the National Highway Traffic Safety Administration (NHTSA) to finalize updates to the U.S. New Car Assessment Program (NCAP). • MEMA had several meetings with Hill staff about legislation mandating specific vehicle safety technologies.
Light Vehicle GHG Emissions and Fuel Efficiency Standards
MEMA’s leadership and advocacy efforts resulted in tangible wins, greater access, and more recognition for the supplier industry. For example, the preamble of the federal Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule mentioned MEMA 43 times, indicating that its advocacy and information were extremely influential in shaping the final rule. • MEMA supported and achieved continued progress (1.5 percent year-over-year) in the CAFE and GHG emissions standards from a proposed flat standard. • MEMA advocated and maintained the air conditioning efficiency and off-cycle credit programs with improvements, despite agency proposals to eliminate them. • MEMA accomplished the long-term goal of EPA pledging to implement the off-cycle supplier process through a technical supplemental rulemaking. • The California Air Resources Board (CARB) OEM agreement included many of the elements MEMA advocated for with continued progress in the standards year-over-year (3.7 percent), continued the advanced technology multiplier credits after MY2021, continued and improved the A/C efficiency and off-cycle technology credit programs, and increased off-cycle menu cap to 15 g/mi. The agreement, which also allows for the off-cycle suppliers' process, will likely be the framework for federal action in 2021.
TSCA Chemical Regulation
• MEMA advocacy and member outreached helped to attain an exemption for the automotive industry use for two chemicals (DecaBDE and PIP). • EPA released a memo of "no action assurance" clarifying that importers of articles that contained high priority substances were not subject to risk evaluation fees.
EPA also released a proposed rulemaking permanently amending inclusion on article importers such as MEMA members. This was a direct result of MEMA advocacy, and will save our members millions of dollars. MEMA worked extensively with the State of Washington Department of Ecology on important clarifications needed regarding the State's exemptions for original equipment service contract brake pads. Ecology issued a policy statement in October. MEMA negotiated a three-month extension for the reporting requirement. • MEMA was able to get official guidance from Ecology on several issues including a re-testing clarification for "B" level brake pads deadline requirements.
Outreach to Members and the Industry
• For the fourth year running, MEMA and OESA held regular, bi-weekly Trade Working Group meetings. • MEMA held special webinars on USMCA implementation and Export Controls. • In December 2020, the respective Trade Working Groups of MEMA and the European Association of Automotive
Suppliers (CLEPA) held a joint meeting, which teed up an ongoing commitment to have joint dialogue throughout 2021 on U.S./EU trade policy and updates. • Planned and executed webinars on the CARES Act and
Paycheck Protection Program. • MEMA planned and executed summer virtual fly-in on
IP legislation including INFORM Consumers and SHOP
SAFE Legislation. • MEMA works with a variety of key stakeholders impacting the vehicle industry, such as the National Association of Manufacturers (NAM), U.S. Chamber of Commerce,
Alliance for Automotive Innovation, and others.
