UNITED STATES ENVIRONMENTAL PROTECTION AGENCY


WASHINGTON, D.C. 20460

OFFICE OF


AIR AND RADIATION 

The Honorable Heidi Heitkamp 

United States Senate 

Washington, D.C. 20510 

Dear Senator Heitkamp: 

Thank you for your letter of March 19, 2013, co-signed by three of your colleagues, expressing concerns 

with the U.S. Environmental Protection Agency's proposed "Tier 3" regulations for motor vehicle 

emissions and gasoline standards. 

The proposed Tier 3 standards, which were signed by Acting Administrator Bob Perciasepe on March 

29, 2013, would set new vehicle emission standards and lower the sulfur content of gasoline, in a 

manner that addresses the vehicle and its fuel as an integrated system. The Tier 3 proposed rulemaking 

package contains extensive, detailed analyses of the rule's anticipated health and air quality benefits as 

well as its potential impacts on the refining and automotive industries. 

Your letter urges the EPA to issue an advance notice of proposed rulemaking prior to initiating 

rulemaking. We appreciate your concern but note that the Administration has already provided 

significant advance notice to the public and opportunity for public input since the May 2010 Presidential 

Memorandum that requested the EPA's reevaluation of the motor vehicle and gasoline sulfur standards. 

For example, in the rulemaking that established light-duty vehicle greenhouse gas emissions standards 

for model year 2017 and later (finalized in October 2012), the EPA described its intention to propose 

Tier 3 vehicle and fuel standards and received public comment. The EPA has also already sought and 

received broad stakeholder input, which is reflected in the Tier 3 proposal, including from the 

automotive, oil and gas industries as well as environmental and public health organizations. It is 

important to emphasize that the Tier 3 proposal is subject to stakeholder and public input through the 

notice and comment process. The EPA will carefully consider and respond to all timely comments on 

the proposed rule before promulgating a final rule. 

The air quality benefits of the Tier 3 standards are important for the American public. Over 158 million 

Americans are currently experiencing unhealthy levels of air pollution that are linked to adverse health 

impacts such as hospital admissions, emergency room visits and premature mortality. Motor vehicles are 

a particularly important source of air pollution, especially in urban areas. Emission reductions from the 

Tier 3 program would lead to immediate air quality improvements that are critically important for states 

to attain and maintain the existing health-based National Ambient Air Quality Standards (NAAQS) and 

would yield substantial health benefits. By 2030, the EPA estimates the proposed Tier 3 standards would 

annually prevent up to 2,400 premature deaths, 23,000 cases of respiratory ailments in children, 3,200 

hospital admissions and asthma-related emergency room visits, and 1.8 million lost school days, work 

days and days when activities would be restricted due to air pollution. The benefits of the program 

Internet Address (URL) http//wwwepa gov


Recycled/Recyclable Printed with Vegetable Oil Based Inks on 1000 Postconsumer, Process Chlorine Free Recycled Paper
would continue to increase since Tier 3 would not be fully implemented until 2025, and fleet turnover to 

Tier 3 vehicles would continue beyond 2030. 

The EPA understands the importance of potential cost impacts on refineries and automakers, and we 

included extensive analyses of the costs associated with the proposed Tier 3 standards in the proposed 

rulemaking, including refinery-by-refinery analyses. We estimate the Tier 3 program would cost about a 

penny per gallon of gasoline and about $130 per vehicle, and yield health benefits between $8 and $23 

billion annually by 2030. Our evaluation of gasoline sulfur control costs has undergone independent 

peer review and is corroborated by two independent studies (by Mathpro Inc. and Navigant Economics). 

The Baker & O'Brien study cited in your letter estimates a slightly higher average cost increase of 2.1 

cents per gallon, but is based on a number of problematic assumptions that bias the study towards 

overstatement of costs. Simple adjustments to the Baker & O'Brien study to reflect plausible capital 

costs and accepted rates of return on investment bring the study's costs in line with those of the EPA. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may call 

Patricia Haman in the EPA's Office of Congressional and Intergovernmental Relations at (202) 564-

2806.

Gina McCarthy 

Assistant Administrator
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY


WASHINGTON, D.C. 20460

OFFICE OF 

AIR AND RADIATION 

The Honorable Mary L. Landrieu 

United States Senate 

Washington, D.C. 20510 

Dear Senator Landrieu: 

Thank you for your letter of March 19, 2013, co-signed by three of your colleagues, expressing concerns 

with the U.S. Environmental Protection Agency's proposed "Tier 3" regulations for motor vehicle 

emissions and gasoline standards. 

The proposed Tier 3 standards, which were signed by Acting Administrator Bob Perciasepe on March 

29, 2013, would set new vehicle emission standards and lower the sulfur content of gasoline, in a 

maimer that addresses the vehicle and its fuel as an integrated system. The Tier 3 proposed rulemaking 

package contains extensive, detailed analyses of the rule's anticipated health and air quality benefits as 

well as its potential impacts on the refining and automotive industries. 

Your letter urges the EPA to issue an advance notice of proposed rulemaking prior to initiating 

rulemaking. We appreciate your concern but note that the Administration has already provided 

significant advance notice to the public and opportunity for public input since the May 2010 Presidential 

Memorandum that requested the EPA's reevaluation of the motor vehicle and gasoline sulfur standards. 

For example, in the rulemaking that established light-duty vehicle greenhouse gas emissions standards 

for model year 2017 and later (finalized in October 2012), the EPA described its intention to propose 

Tier 3 vehicle and fuel standards and received public comment. The EPA has also already sought and 

received broad stakeholder input, which is reflected in the Tier 3 proposal, including from the 

automotive, oil and gas industries as well as environmental and public health organizations. It is 

important to emphasize that the Tier 3 proposal is subject to stakeholder and public input through the 

notice and comment process. The EPA will carefully consider and respond to all timely comments on 

the proposed rule before promulgating a final rule. 

The air quality benefits of the Tier 3 standards are important for the American public. Over 158 million 

Americans are currently experiencing unhealthy levels of air pollution that are linked to adverse health 

impacts such as hospital admissions, emergency room visits and premature mortality. Motor vehicles are 

a particularly important source of air pollution, especially in urban areas. Emission reductions from the 

Tier 3 program would lead to immediate air quality improvements that are critically important for states 

to attain and maintain the existing health-based National Ambient Air Quality Standards (NAAQS) and 

would yield substantial health benefits. By 2030, the EPA estimates the proposed Tier 3 standards would 

annually prevent up to 2,400 premature deaths, 23,000 cases of respiratory ailments in children, 3,200 

hospital admissions and asthma-related emergency room visits, and 1.8 million lost school days, work 

Internet Address (URL) . http /Iwww epagov


Recycled/Recyclable . Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycled Paper
days and days when activities would be restricted due to air pollution. The benefits of the program 

would continue to increase since Tier 3 would not be fully implemented until 2025, and fleet turnover to 

Tier 3 vehicles would continue beyond 2030. 

The EPA understands the importance of potential cost impacts on refineries and automakers, and we 

included extensive analyses of the costs associated with the proposed Tier 3 standards in the proposed 

rulemaking, including refinery-by-refinery analyses. We estimate the Tier 3 program would cost about a 

penny per gallon of gasoline and about $130 per vehicle, and yield health benefits between $8 and $23 

billion annually by 2030. Our evaluation of gasoline sulfur control costs has undergone independent 

peer review and is corroborated by two independent studies (by Mathpro Inc. and Navigant Economics). 

The Baker & O'Brien study cited in your letter estimates a slightly higher average cost increase of 2.1 

cents per gallon, but is based on a number of problematic assumptions that bias the study towards 

overstatement of costs. Simple adjustments to the Baker & O'Brien study to reflect plausible capital 

costs and accepted rates of return on investment bring the study's costs in line with those of the EPA. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may call 

Patricia Haman in the EPA's Office of Congressional and Intergovernmental Relations at (202) 564-

2806.

Gina McCarthy 

Assistant Administrator
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY


WASHINGTON, D.C. 20460

OFFICE OF


AIR AND RADIATION 

The Honorable Mark Begich 

United States Senate 

Washington, D.C. 20510 

Dear Senator Begich: 

Thank you for your letter of March 19, 2013, co-signed by three of your colleagues, expressing concerns 

with the U.S. Environmental Protection Agency's proposed "Tier 3" regulations for motor vehicle 

emissions and gasoline standards. 

The proposed Tier 3 standards, which were signed by Acting Administrator Bob Perciasepe on March 

29, 2013, would set new vehicle emission standards and lower the sulfur content of gasoline, in a 

manner that addresses the vehicle and its fuel as an integrated system. The Tier 3 proposed rulemaking 

package contains extensive, detailed analyses of the rule's anticipated health and air quality benefits as 

well as its potential impacts on the refining and automotive industries. 

Your letter urges the EPA to issue an advance notice of proposed rulemaking prior to initiating 

rulemaking. We appreciate your concern but note that the Administration has already provided 

significant advance notice to the public and opportunity for public input since the May 2010 Presidential 

Memorandum that requested the EPA's reevaluation of the motor vehicle and gasoline sulfur standards. 

For example, in the rulemaking that established light-duty vehicle greenhouse gas emissions standards 

for model year 2017 and later (finalized in October 2012), the EPA described its intention to propose 

Tier 3 vehicle and fuel standards and received public comment. The EPA has also already sought and 

received broad stakeholder input, which is reflected in the Tier 3 proposal, including from the 

automotive, oil and gas industries as well as environmental and public health organizations. It is 

important to emphasize that the Tier 3 proposal is subject to stakeholder and public input through the 

notice and comment process. The EPA will carefully consider and respond to all timely comments on 

the proposed rule before promulgating a final rule. 

The air quality benefits of the Tier 3 standards are important for the American public. Over 158 million 

Americans are currently experiencing unhealthy levels of air pollution that are linked to adverse health 

impacts such as hospital admissions, emergency room visits and premature mortality. Motor vehicles are 

a particularly important source of air pollution, especially in urban areas. Emission reductions from the 

Tier 3 program would lead to immediate air quality improvements that are critically important for states 

to attain and maintain the existing health-based National Ambient Air Quality Standards (NAAQS) and 

would yield substantial health benefits. By 2030, the EPA estimates the proposed Tier 3 standards would 

annually prevent up to 2,400 premature deaths, 23,000 cases of respiratory ailments in children, 3,200 

hospital admissions and asthma-related emergency room visits, and 1.8 million lost school days, work 

Internet Address (URL) . http //wwwepa gov 


Recycled/Recyclable . Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
days and days when activities would be restricted due to air pollution. The benefits of the program 

would continue to increase since Tier 3 would not be fully implemented until 2025, and fleet turnover to 

Tier 3 vehicles would continue beyond 2030. 

The EPA understands the importance of potential cost impacts on refineries and automakers, and we 

included extensive analyses of the costs associated with the proposed Tier 3 standards in the proposed 

rulemaking, including refinery-by-refinery analyses. We estimate the Tier 3 program would cost about a 

penny per gallon of gasoline and about $130 per vehicle, and yield health benefits between $8 and $23 

billion annually by 2030. Our evaluation of gasoline sulfur control costs has undergone independent 

peer review and is corroborated by two independent studies (by Mathpro Inc. and Navigant Economics). 

The Baker & O'Brien study cited in your letter estimates a slightly higher average cost increase of 2.1 

cents per gallon, but is based on a number of problematic assumptions that bias the study towards 

overstatement of costs. Simple adjustments to the Baker & O'Brien study to reflect plausible capital 

costs and accepted rates of return on investment bring the study's costs in line with those of the EPA. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may call 

Patricia Haman in the EPA's Office of Congressional and Intergovernmental Relations at (202) 564-

2806.

Gina McCarthy 

Assistant Administrator
OFOCE OF


AIR AND RADIATION 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY


WASHINGTON, D.C. 20460

The Honorable Joe Manchin 

United States Senate 

Washington, D.C. 20510 

Dear Senator Manchin: 

Thank you for your letter of March 19, 2013, co-signed by three of your colleagues, expressing concerns 

with the U.S. Environmental Protection Agency's proposed "Tier 3" regulations for motor vehicle 

emissions and gasoline standards. 

The proposed Tier 3 standards, which were signed by Acting Administrator Bob Perciasepe on March 

29, 2013, would set new vehicle emission standards and lower the sulfur content of gasoline, in a 

maimer that addresses the vehicle and its fuel as an integrated system. The Tier 3 proposed rulemaking 

package contains extensive, detailed analyses of the rule's anticipated health and air quality benefits as 

well as its potential impacts on the refining and automotive industries. 

Your letter urges the EPA to issue an advance notice of proposed rulemaking prior to initiating 

rulemaking. We appreciate your concern but note that the Administration has already provided 

significant advance notice to the public and opportunity for public input since the May 2010 Presidential 

Memorandum that requested the EPA's reevaluation of the motor vehicle and gasoline sulfur standards. 

For example, in the rulemaking that established light-duty vehicle greenhouse gas emissions standards 

for model year 2017 and later (finalized in October 2012), the EPA described its intention to propose 

Tier 3 vehicle and fuel standards and received public comment. The EPA has also already sought and 

received broad stakeholder input, which is reflected in the Tier 3 proposal, including from the 

automotive, oil and gas industries as well as environmental and public health organizations. It is 

important to emphasize that the Tier 3 proposal is subject to stakeholder and public input through the 

notice and comment process. The EPA will carefully consider and respond to all timely comments on 

the proposed rule before promulgating a final rule. 

The air quality benefits of the Tier 3 standards are important for the American public. Over 158 million 

Americans are currently experiencing unhealthy levels of air pollution that are linked to adverse health 

impacts such as hospital admissions, emergency room visits and premature mortality. Motor vehicles are 

a particularly important source of air pollution, especially in urban areas. Emission reductions from the 

Tier 3 program would lead to immediate air quality improvements that are critically important for states 

to attain and maintain the existing health-based National Ambient Air Quality Standards (NAAQS) and 

would yield substantial health benefits. By 2030, the EPA estimates the proposed Tier 3 standards would 

annually prevent up to 2,400 premature deaths, 23,000 cases of respiratory ailments in children, 3,200 

hospital admissions and asthma-related emergency room visits, and 1.8 million lost school days, work 

Internet Address (URL) http://www epagov


Recycled/Recyclable . Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
days and days when activities would be restricted due to air pollution. The benefits of the program 

would continue to increase since Tier 3 would not be fully implemented until 2025, and fleet turnover to 

Tier 3 vehicles would continue beyond 2030. 

The EPA understands the importance of potential cost impacts on refineries and automakers, and we 

included extensive analyses of the costs associated with the proposed Tier 3 standards in the proposed 

rulemaking, including refinery-by-refinery analyses. We estimate the Tier 3 program would cost about a 

penny per gallon of gasoline and about $130 per vehicle, and yield health benefits between $8 and $23 

billion annually by 2030. Our evaluation of gasoline sulfur control costs has undergone independent 

peer review and is corroborated by two independent studies (by Mathpro Inc. and Navigant Economics). 

The Baker & O'Brien study cited in your letter estimates a slightly higher average cost increase of 2.1 

cents per gallon, but is based on a number of problematic assumptions that bias the study towards 

overstatement of costs. Simple adjustments to the Baker & O'Brien study to reflect plausible capital 

costs and accepted rates of return on investment bring the study's costs in line with those of the EPA. 

Again, thank you for your letter. If you have further questions, please contact me or your staff may call 

Patricia Haman in the EPA's Office of Congressional and Intergovernmental Relations at (202) 564-

2806.

ma McCarthy 

Assistant Administrator