SMALL VOLUME MANUFACTURER JOINT COMMENT ON ADVANCED CLEAN CAR CARB PROPOSAL LEVIII AND GHG January 18, 2012 This comment is submitted on behalf of Aston Martin Lagonda Limited, Lotus Cars Limited and McLaren Automotive Limited. Each of these companies is classified as a “small volume CARB regulations and is a manufacturer of a very limited number of high manufacturer” under performance sports cars. See ; ; THE CARB PROPOSAL : SMALL VOLUME MANUFACTURER (SVM) PASSENGER CAR REQUIREMENTS For LEV III, CARB is proposing to provide specific requirements for Small Volume Manufacturers (SVM) category. This approach was also followed by CARB in LEV II. Staff has explained that the proposed SVM requirements arose out of the need to recognize limited model lines that SVMs had available to comply with fleet average requirements as well as the limited investment and engineering resources needed to meet more stringent emission standards. We support both the staff proposal as well as the reasoning behind it. All three manufacturers also understand the need to control mobile source pollution and GHG, and support the regulatory efforts of CARB. The three companies further believe that small manufacturers must do their fair share to reduce vehicle pollution and GHG. BACKGROUND Independent vehicle manufacturers with a California three-year sales volume average of 4,500 units per year or less of new PCs, LDTs, MDVs and heavy-duty vehicles / engines are defined by CARB as SVMs. Manufacturers meeting this sales volume criterion (approximately a half dozen) are primarily those with very low volume sales (less than a thousand units per year) of high performance vehicles. In LEV II, compliance with the fleet average NMOG requirement for SVMs was deferred until 2007, the end of the phase-in period, Beginning in 2007, SVMs were required to meet a fleet average requirement approximately 53% less stringent than the fleet average requirement for larger manufacturers. In general, we support postponing SVM compliance until the end (or near the end) of any Doing so levels the playing field for SVMs vis a vis the specialty models of large volume manufacturers, since those large volume manufacturer models are permitted to comply with the new requirements only at the very end of the phase-in. The CARB proposal provides this necessary SVM lead-time flexibility.
SMALL VOLUME MANUFACTURER JOINT COMMENT ON ADVANCED CLEAN CAR CARB PROPOSAL LEVIII AND GHG January 18, 2012 This comment is submitted on behalf of Aston Martin Lagonda Limited, Lotus Cars Limited and McLaren Automotive Limited. Each of these companies is classified as a “small volume manufacturer” under CARB regulations and is a manufacturer of a very limited number of high performance sports cars. See ; ; THE CARB PROPOSAL : SMALL VOLUME MANUFACTURER (SVM) PASSENGER CAR REQUIREMENTS For LEV III, CARB is proposing to provide specific requirements for Small Volume Manufacturers (SVM) category. This approach was also followed by CARB in LEV II. Staff has explained that the proposed SVM requirements arose out of the need to recognize limited model lines that SVMs had available to comply with fleet average requirements as well as the limited investment and engineering resources needed to meet more stringent emission standards. We support both the staff proposal as well as the reasoning behind it. All three manufacturers also understand the need to control mobile source pollution and GHG, and support the regulatory efforts of CARB. The three companies further believe that small manufacturers must do their fair share to reduce vehicle pollution and GHG. BACKGROUND Independent vehicle manufacturers with a California three-year sales volume average of 4,500 units per year or less of new PCs, LDTs, MDVs and heavy-duty vehicles / engines are defined by CARB as SVMs. Manufacturers meeting this sales volume criterion (approximately a half dozen) are primarily those with very low volume sales (less than a thousand units per year) of high performance vehicles. In LEV II, compliance with the fleet average NMOG requirement for SVMs was deferred until 2007, the end of the phase-in period, Beginning in 2007, SVMs were required to meet a fleet average requirement approximately 53% less stringent than the fleet average requirement for larger manufacturers. In general, we support postponing SVM compliance until the end (or near the end) of any Doing so levels the playing field for SVMs vis a vis the specialty models of large volume manufacturers, since those large volume manufacturer models are permitted to comply with the new requirements only at the very end of the phase-in. The CARB proposal provides this necessary SVM lead-time flexibility.
5-carb_comment.docx