January 25, 2012

Honorable Lisa P. Jackson

Administrator U.S. Environmental Protection Agency

Mail Code: 6102T 1200 Pennsylvania Avenue, NW Washington, DC 20460

Re: Tier 3 Motor Vehicle Standards / Low Sulfur Gasoline Rule

Dear Administrator Jackson:

We, the undersigned state environmental leaders, write to urge you to expeditiously propose the

Tier 3 motor vehicle and low sulf ur gasoline standards and to fina lize that rule in 2012. Despite a significant and sustained join t state and federal effort spa nning more than 40 years, air pollution remains a serious public health threat in our region and across the United States.

EPA first committed to proposing Tier 3 standards in 2008 to help states meet the National Ambient Air Quality Standard (NAAQS) for ozone and is late in delivering the much needed reductions from the light-duty vehicl e sector. This sector remain s a significant source of ozoneforming pollutants across the coun try. EPA’s own modeling analysis shows that the Cross-State Air Pollution Rule (if implemented) will not re sult in attaining the new ozone NAAQS in many of the most populous areas in our region. Clearly, Tier 3 and low sulfur gasoline is needed to better protect public health.

Emissions from cars and light and medium-duty truc ks also contribute to fine particle pollution and are key sources of hazardous air pollutants such as benzene, formaldehyde, acetaldehyde and 1,3-butadiene. These pollutants disproportionately affect people living and working in our urban communities, where vehicle congestion and populati on density are highest. Further, nitrogen oxides (NOx) and other vehicle- related pollutants contribute to a number of environmental problems such as acid rain, coas tal marine eutrophication, and regi onal haze that affect cherished and economically valuable resources in the Northeast and Mid-Atlantic region.

Light-duty vehicles are by far the largest s ource of NOx emissions in the Ozone Transport Region (OTR), emitting over 700,000 tons of NOx per year. Lowering the sulfur content of gasoline to 10 parts per million (ppm), as EPA is considering, would immediately reduce NOx from this sector by more than 25 percent. Ov er time, the vehicle standards will dramatically reduce harmful pollutants as the Tier 3 vehicles replace older cars and trucks in the fleet.2.

A recent analysis indicates that the Tier 3 /low sulfur gasoline program would reduce NOx emissions in the OTR by over 50,000 tons per year in 2017, which is more than three times the benefits projected for the Cross-State Air Pollution Rule in the region. 1 Further, as a national strategy, the Tier 3 low sulfur gasoline pr ovision alone would reduce NOx emissions by over 175,000 tons per year, or 500 tons per day, by 2017 across the eastern United States. These reductions will benefit air quality by loweri ng the “ozone reservoir” and accompanying NOx precursor pollution generated in th e eastern United States and tr ansported into the OTR under the prevailing summertime winds.

These reductions would translate to between $235 m illion and $1.2 billion in direct public health benefits annually in our region. The 10 ppm su lfur gasoline provision s would likely reduce NOx at a cost of less than $4,000 per ton, which is comp arable to or less than th e costs associated with federal Tier 2 and heavy-duty engi ne/low sulfur diesel rules and ma ny stationary source controls, including industrial, commercial, and institutio nal (ICI) boilers and combustion turbines.

Given the stringency of existing emission contro ls already in place in our states, federal constraints on state regulation of motor vehicle fuel s, and the fact that our states are significantly affected by pollution transport from sources outside the region, national emission control measures for light-duty vehicles are critical to achieving further improve ments in air quality. Without Tier 3 and other federal measures, more costly emission reductions will have to be accomplished by controlling local sources in our states beyond what otherwise would be needed, in order to compensate for the foregone national measures.

We respectfully request that EPA expeditious ly issue a notice of proposed rulemaking and

finalize the Tier 3/low sulfur gasoline rule in 2012.

Sincerely,

Daniel C. Esty, Commissioner Christophe A. G. Tulou, Director

CT Department of Energy & Environmental Pr otection DC Department of the Environment

Robert M. Summers, Secretary Kenneth L. Kimmell, Commissioner

MD Department of the Environment MA Department of Environmental Protection

1 Assessment of Clean Gasoline in the Northeast and Mid-Atlantic States, Northeast States for Coordinated Air Use Management, Boston, MA (November 2011).3.

Joseph J. Martens, Commissioner Janet Coit, Director NYS Department of Environmental Cons ervation RI Department of Environmental Management

David K. Mears, Commissioner VT Department of Environmental Conservation

c: Bob Perciasepe, Deput y Administrator, EPA Gina McCarthy, Assistant Administrator, OAR Margo Oge, Dir ector, OAR/OTAQ