6 NYCRR Part 218, 252, and 200 Assessment of Public Comments
Comments Received from August 1, 2012 through 5:00 P.M., September 27, 2012
1. Comment: The Manufacturers of Emission Controls Association (MECA) is pleased to provide comments in support of the New York Department of Environmental Compliance proposal to adopt 6 NYCRR Part 218 that includes California's LEV III emission standards, 2017-2025 GHG requirements, ZEV mandates and aftermarket converter requirements for light-duty vehicles. These amendments, when adopted, will reset the bar for state-of-the-art exhaust and evaporative emission controls for light-duty vehicles through 2028. MECA applauds NY-DEC for bringing forward a comprehensive and largely harmonized set of proposals covering lightduty vehicle greenhouse gas emissions and criteria emissions for future vehicles while also requiring the best technology for cleaning up the existing fleet of gasoline passenger vehicles in the state. Commenter 2.
2. Comment: The standards that New York, along with thirteen other states and the District of Columbia, adopted helped lay the foundation for stronger national fuel efficiency and greenhouse gas standards for passenger vehicles. Commenter 4.
3. Comment: I am writing on behalf of the Alliance of Automobile Manufacturers (Alliance), a trade association of 12 car and light-truck manufacturers representing about 75 percent of the new vehicle market in the U.S. The Alliance worked with the California Air Resources Board (ARB), the New York State Department of Environmental Conservation (DEC), and the other Section 177 States in the development of the criteria emissions regulations under the Low Emissions Vehicle III program (or LEV III). We support the changes adopted by California and changes to New York's regulations needed to harmonize with California. Commenter 7.
Response to Comments 1-3: The Department thanks you for your support and agrees that a set of comprehensive and harmonized standards is the optimal approach for reducing harmful criteria and greenhouse gas emissions.
4. Comment: Global Automakers supports a single, harmonized program for greenhouse gases and tailpipe emissions and has actively engaged in promoting harmonization between the U.S. Environmental Protection Agency (EPA), National Highway Traffic Safety Administration (NHTSA), and California Air Resources Board (ARB). ARB's GHG regulations for model years 2017-2025 and the environmental performance label are in line with such harmonization; the NY DEC should, however, be aware that the ARB has noted that minor amendments will be necessary once EPA and NHTSA finalize the federal programs for GHG and Corporate Average Fuel Economy (CAFE), respectively, and such minor amendments are likely to be necessary in New York as well. Commenter 3
Response to Comment 4: The Department is aware that CARB proposed a revision to its regulations on August 31, 2012. This proposal, also known as "deemed-to-comply", would allow automobile manufacturers to demonstrate compliance with the EPA National Program greenhouse gas requirements for model years 2017-2025 in lieu of demonstrating compliance with California's adopted greenhouse gas emissions requirements for those same model years. The Department will assess the impact of the proposed revisions on New York State and incorporate them into New York's regulations as appropriate. New York's rulemaking process would begin later this year or early next year. See also Response to Comments 1-3.
5. Comment: We also have high hopes that EPA will move forward in the coming year to propose and adopt Tier 3 emission standards to nationalize the benefits of LEV III standards and provide a basis for further harmonization. We believe such harmonization will maximize environmental benefits, while streamlining reporting and other compliance effots. Commenter 3.
Response to Comment 5: The Department agrees that harmonizing California and Federal standards is the optimal approach. However, California's standards are more protective of public health and the environment in the absence of comparable Federal Standards. As it has done in the past, the Department is willing to consider and implement "deemed-to-comply" provisions allowing manufacturers to demonstrate compliance with comparable Federal standards. This was done most recently with the 2012 through 2016 GHG standards. The Department is also willing to work with vehicle manufacturers to streamline compliance and reporting efforts. The Department has demonstrated this willingness by eliminating some reporting requirements, allowing pooling of vehicle sales to demonstrate compliance with applicable standards, and developing a Section 177 State ZEV optional compliance path among other examples.
6. Comment: It is important to note that this August, the EPA and Department of Transportation finalized new standards that will double the fuel efficiency of new cars and light trucks, as well as cut in half their greenhouse gas pollution by 2025. California's greenhouse gas standards will harmonize with these historic national standards, but it is important to also note that national standards to address criteria pollutants, Tier III, have been delayed. Therefore, it is critical that New York incorporates the recent changes to the California program that will increase protections from tailpipe pollution. Commenter 4.
Response to Comment 6: The Department agrees that harmonizing California and Federal standards is the optimal approach. However, California's standards are more protective of public health and the environment in the absence of comparable Federal Standards.
7. Comment: There are significant opportunities to reduce both criteria pollutant and greenhouse gas emissions from the transportation sector through the design of fuel efficient powertrains that include advanced exhaust emission controls for meeting even the most stringent criteria pollutant standards that are included in California's LEV III program. MECA believes that advanced emission control systems have a critically important role in future policies that aim to reduce mobile source criteria pollutant and greenhouse gas emissions. Emission control manufacturers are working with their auto manufacturer partners to further optimize these emission control technologies to be more effective at reducing criteria pollutants and play a role in reducing vehicle greenhouse gas emissions. Commenter 2.
8. Comment: Our industry is prepared to do its part to deliver the most advanced and cost-effective emission control technologies to the state of New York. Commenter 2.
Response to Comments 7-8: The mobile source sector is a significant contributor to air quality degradation in New York and vehicle emissions tend to increase with age as emissions control devices deteriorate. The Department acknowledges the significant investments that your members, and vehicle manufacturers as well, have made to develop and deploy more efficient and durable emissions control technologies. These technologies play a key role in enabling New York to achieve and maintain its air quality.
9. Comment: Sierra Club applauds New York for its continued leadership to put in place standards that will reduce dangerous pollution and drive innovation in the auto industry. Commenter 4.
10. Comment: The revised rules under consideration today build on decades of progress, most of which has been driven by the leadership of New York. Commenter 5.
11. Comment: We applaud New York's longstanding commitment to promoting the cleanest vehicle technologies and pursuing a healthy, low carbon future for all New Yorkers. We urge you to adopt the strongest possible standards today to continue that strong leadership. Commenter 6.
Response to Comments 9-11: The Department thanks you for your comments and support.
12. Comment: This important achievement never would have happened without the leverage of states like New York. As we look towards implementing these vehicle standards, it will be important for New York to remain involved and to push back against any efforts to derail or undermine this important program. Commenter 5.
Response to Comment 12: The Department thanks you for your comment. The Department has been, and will continue to be, an active participant in the development and adoption of the Low Emission Vehicle, Zero Emission Vehicle, and Greenhouse Gas standards. The Department is not aware of any "push back" or efforts to "derail" the proposed standards by the regulated community. The Department notes that original equipment manufacturers (OEMs) and manufacturers of emissions control components expressed support for the proposed regulations and worked with CARB to craft technologically and economically feasible emission standards.
LEV III Standards
13. Comment: These advanced exhaust and evaporative emission control technologies will allow all current and future high efficiency powertrain options to comply with LEV III criteria pollutant standards, thus enabling these powertrains to be viable options for complying with California and EPA greenhouse gas pollutant standards. Commenter 2.
Response to Comment 13: The Department agrees that a vast array of existing and future technologies will enable vehicle manufacturers to meet the new standards.
14. Comment: In nearly all cases, these fuel-efficient powertrain designs, combined with appropriate emission controls, can be optimized to either minimize fuel consumption impacts associated with the emission control technology, or, in some cases, improve overall fuel consumption of the vehicle. This optimization extends beyond carbon dioxide emissions to include other significant greenhouse gases such as methane and nitrous oxide. Commenter 2.
Response to Comment 14: The Department agrees with this comment. While carbon dioxide constitutes the largest volume of GHG emitted by vehicles, other GHG such as methane and nitrous oxide still have significant environmental impacts due to their higher global warming potentials.
15. Comment: As the technology pushing arm of the Advanced Clean Car Program, the Zero Emissions Vehicle program will help ensure greater numbers of battery electric vehicles and plug in hybrid vehicles on our roads. Commenter 4.
16. Comment: The second regulation under consideration today, the revised rules to the Zero Emission Vehicle program, is a critical policy that will ensure that thousands of New York families can choose a car powered by cleaner sources of energy, such as plug in vehicles or fuel cell vehicles. Commenter 5.
Response to Comments 15-16: The Department agrees with these comments.
17. Comment: California and other clean car states can expect nearly 4 million plug in hybrid and battery electric vehicles on the road by 2025. Commenter 4.
Response to Comment 17: The Department agrees that plug-in hybrid and battery electric vehicles will be available in increasing numbers by 2025. However, the Department cannot confirm the commenter's estimate at this time that 4 million vehicles will be registered in California and Section 177 states by 2025.
18. Comment: These standards will also help our State develop the infrastructure to support a 21st Century transportation system. Commenter 4.
19. Comment: Automakers are certain to focus their initial sales efforts on states that have adopted the ZEV program, so if we want to have these vehicles in New York, it's vital that we adopt these new rules now. Commenter 5.
Response to Comments 18-19: The combination of a strong ZEV mandate and widely available fueling infrastructure provides manufacturers with certainty that a viable market exists for their products. Therefore, installation of alternative fuel infrastructure, including electric vehicle charging stations and hydrogen refueling stations, will support widespread penetration of advanced technology vehicles in New York.
20. Comment: The newest generation of plug in vehicles, such as the Chevy Volt and the Nissan Leaf, are great, they are fun to drive, some of them have no tailpipe and they allow people to get around without worrying about the price of gas or all the problems of oil. Commenter 5.
Response to Comment 20: The Department agrees that vehicle manufacturers offer a wide range of vehicles that meet consumer demands for increased fuel economy while maintaining reasonable levels of performance and utility.
21. Comment: The ZEV program will ensure that more of these cars get built, which will help drive down the initial costs and make these high tech vehicles an option for more families. Commenter 5.
Response to Comment 21: The Department agrees that the initial cost of purchasing advanced technology vehicles such as battery electric or plug-in hybrid vehicles may be significantly higher than the cost of a comparable internal combustion powered vehicle. However, it is expected that this cost differential will decrease in later years due to advances in battery technology, economies of scale and more efficient production processes.
New Aftermarket Catalytic Converter Standards
22. Comment: We commend NY-DEC for recognizing the opportunity to significantly reduce emissions from the existing light-duty passenger car and truck fleet by applying the types of advanced catalyst technologies that are being used on all new vehicles sold since 2004 under CARB's LEV II light-duty vehicle programs to aftermarket converters. Our members have invested and continue to invest significant resources in developing, optimizing and commercializing advanced emission control technologies to enable new and in-use motor vehicles to meet the most stringent standards for emissions. Commenter 2.
Response to Comment 22: The Department thanks you for your support. See also Response to Comments 7-8.
23. Comment: The additional requirements outlined in this proposal would insure that aftermarket converters sold in New York are fully compliant with the diagnostic systems on 1996 and newer model year vehicles. Furthermore, the proposed amendments will extend these advanced catalysts to pre-1996, non-OBD II vehicles so that they may benefit from the same advanced catalyst technologies used on vehicles equipped with OBD II systems and significantly reduce emissions of hydrocarbons and NOx that contribute to ozone and secondary PM formation. Commenter 2.
Response to Comment 23: The Department agrees with this comment.
24. Comment: To meet the durability requirements for new aftermarket converter catalysts of 50,000 miles, catalyst manufacturers have developed technologies based on more thermally durable materials. To insure that catalysts are compatible with the OBD II system and do not cause the vehicle's MIL to illuminate when the catalyst is functioning properly, manufacturers have developed advanced catalyst coating practices and implemented tight quality control procedures in their processes. These advances result in catalysts that can survive high temperature exposure and deliver the required performance over a longer useful life. MECA member companies have certified and continue to obtain CARB approval for new technologies to broaden the availability of aftermarket converters that comply with the latest requirements. Commenter 2.
Response to Comment 24: The Department thanks you for your comment. Staff believes this comment helps to demonstrate that feasible technologies and processes exist which will enable manufacturers to meet the more stringent performance and durability standards for aftermarket catalytic converters.
25. Comment: The benefit of applying the most advanced aftermarket converters on non-OBD vehicles was demonstrated by ARB staff through vehicle tests and presented in their staff report. After approximately 8,000 miles of mileage accumulation, the advanced catalysts resulted in 50-75 percent lower emissions of all three criteria pollutants compared to the aftermarket catalyst technology sold previously in California and currently sold in New York. Furthermore the advanced catalysts demonstrated far better durability resulting in 60 percent less deterioration in HC emissions and 75 percent less deterioration in NOx emissions after mileage accumulation relative to today's aftermarket converters sold for pre-OBD vehicles in New York. Commenter 2.
Response to Comment 25: The Department agrees with this comment.
26. Comment: MECA members have recently completed their own test program that compared the emission reduction benefit of fully aged California and federal aftermarket converters. After only 25,000 miles of equivalent aging the CARB converters emitted 77 percent less NOx, 60 percent less HC and 63 percent less CO than the equivalently aged EPA converter. The emission benefits of the CARB aftermarket converters were even more dramatic after 50,000 miles of aging. The results of this study have been submitted to the Society of Automotive Engineers for publication in April of next year. Commenter 2.
Response to Comment 26: The Department thanks you for your comment. The information provided by the commenter appears to corroborate the conclusions reached by CARB with regard to the improved effectiveness and durability of aftermarket catalytic converters certified to the new California standards. A copy of this study was not submitted with the comment; as a result the Department has not had an opportunity to independently verify these results.
27. Comment: NY-DEC has estimated that the level of emission reductions provided by the advanced aftermarket converters represents 3.66 tons/day of HC and NOx in the state in 2012. These reductions will make a significant contribution towards the state meeting its ozone air quality commitments. Commenter 2.
Response to Comment 27: The Department agrees with this comment.
28. Comment: As demonstrated by emissions tests conducted by CARB, an essential component of meeting these estimated emission reductions is the phase-out of used or remanufactured aftermarket converters. Although the used converters must pass an initial emission screening test before they are sold, because the operating history of the used converter is not known, there is no way to tell how long the converter will last in service. Commenter 2.
29. Comment: It has been proposed to allow the OBD system on OBD equipped vehicles to notify the driver if a used converter has failed. This approach would not be applicable to pre-OBD vehicles. Furthermore, the emissions threshold for OBD systems is 1.75 times higher than the certification limit that new aftermarket converters must meet. And finally, the higher exhaust emissions caused by operating a vehicle with the engine light illuminated would continue until the operator takes action or the next emissions inspection period. The stringent guidelines being proposed under Part 218 of 6 NYCRR are important to insure that only aftermarket technologies capable of achieving the highest standards of quality and performance are sold in New York. These are the same converter technologies that have been sold in California for the past three years. Commenter 2.
Response to Comments 28-29: The Department agrees with these comments. There currently are no practical screening methods to evaluate used catalytic converter performance to ensure they are capable of meeting the new, more stringent emission and durability standards.
Emissions Warranty and Recall Standards
30. Comment: We do not oppose the warranty and recall provisions in Section 218-9.1 and Section 218-10.1 or reporting requirements associated with these when requested by DEC. However, generating and submitting these reports consumes manufacturer resources, which we have no issues with, provided DEC needs them. Adding the "upon request" to these sections ensures DEC has access to needed reports, but reduces the burden on manufacturers when the reports are not needed. Commenter 7.
Response to Comment 30: The Department does not believe the suggested language is necessary. Part 218 already contains language requiring vehicle manufacturers to provide information upon request from the Department. Further, the warranty and recall provisions have specific criteria which trigger the generation of warranty and recall actions and reporting. The Department is not creating or mandating reporting requirements which differ from those being incorporated by reference. If a manufacturer demonstrates that a warrantable condition or recall action does not apply to vehicles delivered to New York State, no additional reporting is required.
Public Health and Environmental Quality
31. Comment: It is critical that New York continue to be a leader in protecting the health of our children, communities and environment from the effects of smog and soot pollution. Commenter 4.
32. Comment: Cars and light trucks emit toxic smog, soot pollution and greenhouse gas pollutants that are harmful to our health, environment and economy. Commenter 4.
33. Comment: The proposed amendments to Section 218-3.1 to incorporate California's latest Low Emission Vehicle and Greenhouse gas standards will help ensure that cars sold in New York emit less dangerous pollution, including fine particles that can damage the lungs of our children. Commenter 4.
34. Comment: In addition, the new LEV III regulations will reduce the emissions of smog-forming air pollutants that cause serious health problems by 75 percent, saving hundreds of lives. Commenter 5.
35. Comment: The American Lung Association in New York is fully committed to this effort to clean up our vehicle fleet because it is critical to our mission to improve lung health and prevent lung disease. We believe this regulation is a giant step forward for air quality and public health in New York. Commenter 6.
36. Comment: We believe these standards are not an option but a necessary step to protect public health today and for future generations. These updated standards will reduce smog-forming emissions, place stringent limits on fine particles and other air pollutants, reduce greenhouse gases, and promote clean vehicle technologies. Commenter 6.
Response to Comments 31-36: The Department agrees that these standards will have significant beneficial impacts on public health and the environment.
37. Comment: This proposal, like previously adopted standards, recognizes that motor vehicle emissions play a key role in our state's ongoing air pollution challenge and reflects the need to develop the technologies needed to overcome this challenge. Commenter 6.
38. Comment: While progress has been made to improve the quality of our air, population growth and people driving greater distances has challenged the air quality gains we have made. Mobile emissions sources continue to present both immediate and long term threats to the health of everyone in New York, particularly our children, elderly, and those living with chronic lung diseases like asthma and COPD. Commenter 6.
Response to Comments 37-38: The Department agrees that motor vehicle emissions are a significant source of pollution in New York State and may adversely affect public health and environmental quality. The Department believes the increased stringency and technology forcing nature of California's standards will help New York achieve and maintain its long term air quality goals, which will mitigate the adverse health impacts experienced by State residents.
39. Comment: The Environmental Protection Agency estimates that one out of three people are at higher risk of suffering from smog related health problems. In New York, this year alone, we've already had 20 bad air days. Commenter 4.
40. Comment: Far too many New Yorkers continue to suffer from some of the most polluted air in the country and we need sustained state action now to bring relief. The Lung Association's 2012 State of the Air report found that over 3.2 million New Yorkers live in counties where unhealthy air endangers their life and health. Adopting the clean cars package and strengthening California's Zero Emission Vehicle (ZEV) Program is the right prescription for New York's dirty air. Commenter 6.
41. Comment: Implementing these new standards will serve as a strong tool New York needs to reduce air pollution levels, protect public health, and meet the state's greenhouse gas reduction goals. Strong clean car standards have provided significant emission reductions over the past 40 years, but we must continue to reduce all emissions as quickly as possible to bring New York's most polluted regions into attainment of federal air quality standards. Commenter 6.
Response to Comments 39-41: As stated in the Regulatory Impact Statement, New York has made significant progress in improving its air quality to meet National Ambient Air Quality Standards (NAAQS) for ozone and particulate matter. In spite of this progress, there are still areas in New York State which are categorized as non-attainment areas for ozone, which may adversely impact public health. As mentioned previously, the Department believes the increased stringency and technology forcing nature of the proposed standards will help New York achieve and maintain its long term air quality goals, which will mitigate the adverse health impacts experienced by State residents.
42. Comment: For the millions of people who are suffering from lung illness, the benefits of this regulation are clear. Every cleaner car on the road contributes to reducing the health burden of premature deaths, asthma attacks and chronic lung illness from vehicle pollution. This burden of pollution especially threatens the 1.3 million adults and over 415,000 children with asthma in New York. Commenter 6.
Response to Comment 42: The Department agrees with this comment.
43. Comment: MECA supported CARB's LEV III, 2017-2025 greenhouse gas emission standards for light-duty vehicles and revision to the ZEV requirements adopted by the Board on January 25th, 2012. MECA provided detailed comments in support of this proposal a copy of which can be found here:
(http://www.meca.org/galleries/defaultfile/MECA%20comments%20on%20ARB%20LEV%20III,%20post-2016%20GHG%20012512.pdf). Commenter 2.
44. Comment: MECA has supported ARB's aftermarket regulation developments for over 20 years dating back to the original regulations for replacement converter certification in California in August of 1988. MECA and our members actively participated in the regulatory process leading up to California's most recent revision of their aftermarket converter standards implemented in 2009 including providing staff with comments regarding the capabilities of advanced aftermarket converter technologies. MECA members have provided converter samples to CARB staff to facilitate their understanding of the performance and durability of aftermarket converter technologies in support of their regulation. Commenter 2.
Response to Comments 43-44: While technically not comments on the proposed rulemaking, the Department has included these statements in the record since they demonstrate support for California's aftermarket catalytic converter regulations which are being incorporated by reference in New York. It further demonstrates that members of the regulated community collaborated with CARB staff to develop effective and feasible standards.
45. Comment: This summer's heat waves and parching drought across much of the country are reminders of the effects of climate disruption. Commenter 4.
Response to Comment 45: The Department is adopting this regulation to mitigate the potentially harmful effects of global warming and to protect public health and the environment. Scientific consensus is that global warming is real, and human activities are partly responsible. The impact and costs of global warming will increase if we do not begin to address them with programs such as this regulation.
46. Comment: The global warming standards in the Low Emission Vehicle program, or LEV III, now overlap with the Federal vehicle standards that will raise fuel efficiency across the country to 54.5 miles per gallon. Commenter 5.
47. Comment: This regulation is the single largest step the country has ever taken to either reduce oil consumption or global warming pollution, and it will save consumers thousands of dollars over the life of their vehicles. Commenter 5.
48. Comment: Ultimately, we need to not only make our cars cleaner and more efficient, but also to move towards alternative technologies that will break our dependence on oil for good. Commenter 5.
Response to Comments 46-48: The proposed standards are emission standards, not fuel economy standards. However, the use of advanced technologies may also increase fuel efficiency resulting in decreased operating expenses for vehicle owners.
Beyond the Scope of This Regulation
49. Comment: Can you explain in lay terms what the provisions are, the proposed changes and the impact it will have on the general public? Commenter 1
Response to Comment 49: This is an information request rather than a comment. The requested information was discussed in detail in the supporting documents.
50. Comment: Residents have been complaining about the food trucks that run their engines and emit fumes. Also those who cook and emit smoke and gases. Will any of the provisions allow us to correct this issue? Commenter 1.
Response to Comment 50: This comment is outside the purview of the proposed revisions to Part 218. Vehicle anti-idling restrictions are enforced under 6 NYCRR Subpart 217-3, Idling Prohibition for Heavy Duty Vehicles.
51. Comment: Although not part of the proposed changes, we request DEC revise the reporting date for the zero emission vehicle (ZEV) sales volumes from March 31 to May 1, to align with the ARB annual reporting requirements. A similar change is proposed to Section 218-8.5(a) correcting the reporting date for GHG emissions. Commenter 7.
Response to Comment 51: The section referenced in the comment, Section 218-4.2, deals with the voluntary alternative compliance plan (ACP) which is no longer being offered and is being deleted from the regulation. The Department agrees that the ZEV reporting date should be aligned with California's reporting date of May 1 rather than March 31. The May 1 reporting date is incorporated by reference in Section 218-4.1.
52. Comment: Although Alliance members only offer new vehicles and this is an existing part of the regulations (i.e., not part of the subject changes), it is worthwhile to note the prohibition against the sale of used vehicles in Section 218-2.1 and Section 218-8.2, "It is unlawful for any person to sell or register&133;new or used motor vehicle&133;" (emphasis added). We recommend deleting the "or used" from these sections since it could prevent a legitimate owner of a non-California certified vehicle (e.g., inherited vehicle, new resident of New York) from selling or registering the vehicle in New York. Commenter 7.
Response to Comment 52: The Department agrees that this comment is beyond the scope of the proposed regulation. While it is true that Section 218-2.1 and Section 218-8.2 prohibit the sale, lease, registration, purchase, or delivery of new or used vehicles that do not meet California emissions certification requirements, there are several exemptions that apply to noncompliant vehicles which would allow them to be registered in New York.
Section 218-2.1(b) states that the prohibitions do not apply if a vehicle meets one of the following criteria: acquired by a State resident to replace their New York State registered vehicle damaged beyond repair or stolen out-of-state; transferred by inheritance; transferred by court decree; sold after the effective date of this Subpart if the vehicle was registered in New York before such effective date; originally registered in another state by a resident who subsequently established residence in New York; emergency or tactical vehicles; or exempted by California Health and Safety Code Section 43656.
List of Commenters
1. East 86th Street Association
2. Rasto Brezny, PhD; Deputy Director; Manufacturers of Emission Controls Association (MECA)
3. Julia Rege; Senior Manager, Environment & Energy; Association of Global Automakers, Inc.
4. Caitlin Pixley; Conservation Program Assistant; Sierra Club Atlantic Chapter
5. David VanLuven; Director; Environment New York
6. Michael Seilback; Vice President, Public Policy & Communications; American Lung Association of the Northeast
7. Steven P. Douglas; Senior Director, Environmental Affairs; Alliance of Automobile Manufacturers