Submission Number: 8865
Submission ID: 61966
Submission UUID: b48cc841-93d4-436b-aa69-d11d69c5a9e9

Created: Fri, 07/17/2026 - 10:09
Completed: Fri, 07/17/2026 - 10:10
Changed: Fri, 07/17/2026 - 13:34

Remote IP address: 18.68.30.23
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes
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Submitted Comment
Jennifer Lewis
MEMA, The Vehicle Suppliers Association
MEMA's Brake Manufacturers Council (BMC) Comments on CARB's Drive Forward Proposal Re: NEE and PM Emission Standards

MEMA, The Vehicle Suppliers Association (MEMA) and MEMA's Brake Manufacturers Council (BMC) appreciate the opportunity to provide the attached comments to the California Air Resources Board’s (CARB) Drive Forward proposal addressing non-exhaust emissions (NEE), including the proposed brake wear particulate matter (PM) emission standards for new vehicles.

MEMA supports CARB’s continued research and stakeholder engagement regarding brake wear emissions. However, MEMA has significant concerns with the proposal as currently presented because CARB has not yet fully addressed the scientific basis for the proposed numerical standards, the certification pathway, testing capacity, implementation timing, enforcement mechanisms, and the potential implications for original equipment (OE) manufacturers, suppliers, and the aftermarket brake sector.

MEMA looks forward to continued engagement with CARB and would be pleased to provide additional technical information or participate in targeted working sessions with CARB staff and BMC members.

N/A