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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


The Honorable James M. Itthofe AIR AND RADIATION 

United States Senate 

Washington, DC. 20510 

Dear Senator Inhofe: 

Thank you for your letter of January 12, 2012, co-signed by five of your colleagues, concerning 

the U.S. Environmental Protection Agency's forthcoming proposal of the "Tiei- 3" light-duty 

vehicle emissions and gasoline standards. 

The EPA is developing the Tier 3 standards to respond to the critical need to improve air quality, 

and to enable a harmonized national vehicle emissions control program. This rule would reduce 

motor vehicle emissions and help state and local areas attain and maintain the existing healthbased air quality standards in a cost-effective and timely way. Lower sulfur gasoline is necessary 

to operate the pollution control equipment to achieve new Tier 3 vehicle standards, and will 

facilitate the development of lower cost technologies to improve fuel economy. Improvements 

in fuel economy reduce gasoline consumption and save consumers money. 

The Tier 3 standards would create a comprehensive regulatory approach that provides certainty 

for both the auto and oil industries. Under a single harmonized national vehicle program, the Tier 

3 standards would provide for coordinated implementation with the California vehicle program 

and the EPA and Department of Transportation's recently proposed light-duty vehicle standards 

to reduce carbon pollution and improve fuel economy for model years 2017 through 2025. The 

proposed standards are projected to save approximately 4 billion barrels of oil and 2 billion 

metric tons of carbon pollution over the lifetime of the vehicles. Vehicles meeting these 

standards are projected to provide average net savings to consumers of $3,000 to $4,000 per 

vehicle. Further, the coordinated timing of the Tier 3 and refinery sector rules provides the oil 

industry regulatory certainty and opportunities for cost-efficiency. 

We understand that even minimal increases in the cost of gasoline are of importance to the 

American public. That is why EPA conducted extensive refinery modeling to understand the cost 

impacts of a variety of fuel requirements. As a result, the only fuel requirement we are 

considering for Tier 3 is one that would lower the amount of sulfur in gasoline. As with lead, 

sulfur in fuel impairs the functioning of emission control equipment. By focusing only on sulfur 

requirements in Tier 3, we estimate the costs to be approximately one penny per gallon in 2017, 

an estimate that is supported by a recent study by Mathpro. 

Your letter expressed concern about the regulation's potential effects on the refining industry and 

gasoline supply. Let me assure you that as many as 17 refineries are already able to meet the 10 

ppm sulfur standards we are considering, and some are currently producing and exporting to 

Interrre Address (URL) • hltp I/wwwepa gov


RecycIedlRecycIabe Pnnted with Vegetable 01 Based Inks on 100% Postconsurrer. Process Chlorine Free Recycled Paper
European countries gasoline that meets this standard (which is also required in places like Japan, 

South Korea, and a number of other countries). The regulatory flexibility we intend to build into 

the Tier 3 standards, similar to the flexibility we provide in our current fuel programs, will 

ensure that the Tier 3 standards under consideration would not cause refinery closures or 

negatively impact gasoline supply. 

Your letter points to the need for thorough scientific, cost, and benefits analyses before 

proceeding. Let me assure you and your colleagues that we agree that this major rule requires 

robust and transparent analyses of air quality, technological feasibility, and costs, as well as 

potential benefits. As we continue to develop the proposed rule, which has not yet been 

published for comment, we are conducting and documenting a wide range of analyses in all of 

these areas. 

Your letter also asks that the public should be allowed to consider the results of the antibacksliding study required under the Energy Independence and Security Act. I want to 

emphasize that the Tier 3 rule is independent of the anti-backsliding study required by sections 

211(q) and 211(v) of the Clean Air Act. The Tier 3 rule is focused on vehicle emissions 

standards in response to our obligations and authority under section 202(a) and the fuel necessary 

to enable them in response to our obligations and authority under section 211(c). In contrast, the 

anti-backsliding study will examine the broader issues related to impacts of renewable fuels, and 

it is required as a prerequisite to regulations under section 211(v). The anti-backsliding study 

will not affect any decisions about gasoline sulfur, which are being informed by a thorough 

analysis of the impact of gasoline sulfur on vehicle emissions and the air quality benefits of 

reduced motor vehicle emissions. We are not promulgating standards under section 211(v) in the 

Tier 3 rulemaking. 

Regarding the refinery sector rule, we agree that thorough analysis of available data is crucial in 

the generation of common sense emission control standards. We have worked diligently to 

evaluate and analyze data received through the Information Collection Request. We have taken 

and will continue to take into consideration the perspective and input of stakeholders as we strive 

to develop a reasonable rulemaking that will achieve meaningful and cost-effective pollution 

reductions in the refining industry. 

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

may call Josh Lewis in EPAs Office of Congressional and Intergovernmental Relations at (202) 

564-2095.

Gina MtCarthy 

Assistant Administrator
ST.q,

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, DC. 20460 

PRO.0

OFFICE OF


The Honorable John Barrasso AIR AND RADIATION 

United States Senate 

Washington, D.C. 20510 

Dear Senator Barrasso: 

Thank you for your letter of January 12, 2012, co-signed by five of your colleagues, concerning 

the U.S. Environmental Protection Agency's forthcoming proposal of the "Tier 3" light-duty 

vehicle emissions and gasoline standards. 

The EPA is developing the Tier 3 standards to respond to the critical need to improve air quality, 

and to enable a harmonized national vehicle emissions control program. This rule would reduce 

motor vehicle emissions and help state and local areas attain and maintain the existing healthbased air quality standards in a cost-effective and timely way. Lower sulfur gasoline is necessary 

to operate the pollution control equipment to achieve new Tier 3 vehicle standards, and will 

facilitate the development of lower cost technologies to improve fuel economy. Improvements 

in fuel economy reduce gasoline consumption and save consumers money. 

The Tier 3 standards would create a comprehensive regulatory approach that provides certainty 

for both the auto and oil industries. Under a single harmonized national vehicle program, the Tier 

3 standards would provide for coordinated implementation with the California vehicle program 

and the EPA and Department of Transportation's recently proposed light-duty vehicle standards 

to reduce carbon pollution and improve fuel economy for model years 20 1 7 through 2025. The 

proposed standards are projected to save approximately 4 billion barrels of oil and 2 billion 

metric tons of carbon pollution over the lifetime of the vehicles. Vehicles meeting these 

standards are projected to provide average net savings to consumers of $3,000 to $4,000 per 

vehicle. Further, the coordinated timing of the Tier 3 and refinery sector rules provides the oil 

industry regulatory certainty and opportunities for cost-efficiency. 

We understand that even minimal increases in the cost of gasoline are of importance to the 

American public. That is why EPA conducted extensive refinery modeling to understand the cost 

impacts of a variety of fuel requirements. As a result, the only fuel requirement we are 

considering for Tier 3 is one that would lower the amount of sulfur in gasoline. As with lead, 

sulfur in fuel impairs the functioning of emission control equipment. By focusing only on sulfur 

requirements in Tier 3, we estimate the costs to be approximately one penny per gallon in 2017, 

an estimate that is supported by a recent study by Mathpro. 

Your letter expressed concern about the regulation's potential effects on the refining industry and 

gasoline supply. Let me assure you that as many as 17 refineries are already able to meet the 10 

ppm sulfur standards we are considering, and some are currently producing and exporting to 

Internet Address URL) http //wwwepagov


Recycled/Recyclable . Prurrled wi/h Vegetable Oil Based inks on 100% Poetconsumer, Process Chlorine Free Recycled Paper
European countries gasoline that meets this standard (which is also required in places like Japan, 

South Korea, and a number of other countries). The regulatory flexibility we intend to build into 

the Tier 3 standards, similar to the flexibility werjvile in our current fuel programs, will 

ensure that the Tier 3 standards under consideration would not cause refinery closures or 

negatively impact gasoline supply. 

Your letter points to the need for thorough scientific, cost, and benefits analyses before 

proceeding. Let me assure you and your colleagues that we agree that this major rule requires 

robust and transparent analyses of air quality, technological feasibility, and costs, as well as 

potential benefits. As we continue to develop the proposed rule, which has not yet been 

published for comment, we are conducting and documenting a wide range of analyses in all of 

these areas. 

Your letter also asks that the public should be allowed to consider the results of the antibacksliding study required under the Energy Independence and Security Act. I want to 

emphasize that the Tier 3 rule is independent of the anti-backsliding study required by sections 

211(q) and 211(v) of the Clean Air Act, The Tier 3 rule is focused on vehicle emissions 

standards in response to our obligations and authority under section 202(a) and the fuel necessary 

to enable them in response to our obligations and authority under section 211(c). In contrast, the 

anti-backsliding study will examine the broader issues related to impacts of renewable fuels, and 

it is required as a prerequisite to regulations under section 211(v). The anti-backsliding study 

will not affect any decisions about gasoline sulfur, which are being informed by a thorough 

analysis of the impact of gasoline sulfur on vehicle emissions and the air quality benefits of 

reduced motor vehicle emissions. We are not promulgating standards under section 211(v) in the 

Tier 3 rulemaking. 

Regarding the refinery sector rule, we agree that thorough analysis of available data is crucial in 

the generation of common sense emission control standards. We have worked diligently to 

evaluate and analyze data received through the Information Collection Request. We have taken 

and will continue to take into consideration the perspective and input of stakeholders as we strive 

to develop a reasonable rulemaking that will achieve meaningful and cost-effective pollution 

reductions in the refining industry. 

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

may call Josh Lewis in EPA's Office of Congressional and Intergovernmental Relations at (202) 

564-2095.

Gina Mccarthy 

Assistant Administrator
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, DC. 20460

OFFICE OF


The Honorable Mark Begich AIR AND RADIATION 

United States Senate 

Washington, D.C. 20510 

Dear Senator Begich: 

Thank you for your letter of January 12, 2012, co-signed by five of your colleagues, concerning 

the U.S. Environmental Protection Agency's forthcoming proposal of the "Tier 3" light-duty 

vehicle emissions and gasoline standards. 

The EPA is developing the Tier 3 standards to respond to the critical need to improve air quality, 

and to enable a harmonized national vehicle emissions control program. This rule would reduce 

motor vehicle emissions and help state and local areas attain and maintain the existing healthbased air quality standards in a cost-effective and timely way. Lower sulfur gasoline is necessary 

to operate the pollution control equipment to achieve new Tier 3 vehicle standards, and will 

facilitate the development of lower cost technologies to improve fuel economy. improvements 

in fuel economy reduce gasoline consumption and save consumers money. 

The Tier 3 standards would create a comprehensive regulatory approach that provides certainty 

for both the auto and oil industries. Under a single harmonized national vehicle program, the Tier 

3 standards would provide for coordinated implementation with the California vehicle program 

and the EPA and Department of Transportation's recently proposed light-duty vehicle standards 

to reduce carbon pollution and improve fuel economy for model years 2017 through 2025. The 

proposed standards are projected to save approximately 4 billion barrels of oil and 2 billion 

metric tons of carbon pollution over the lifetime of the vehicles. Vehicles meeting these 

standards are projected to provide average net savings to consumers of $3,000 to $4,000 per 

vehicle. Further, the coordinated timing of the Tier 3 and refinery sector rules provides the oil 

industry regulatory certainty and opportunities for cost-efficiency. 

We understand that even minimal increases in the cost of gasoline are of importance to the 

American public. That is why EPA conducted extensive refinery modeling to understand the cost 

impacts of a variety of fuel requirements. As a result, the only fuel requirement we are 

considering for Tier 3 is one that would lower the amount of sulfur in gasoline. As with lead, 

sulfur in fuel impairs the functioning of emission control equipment. By focusing only on sulfur 

requirements in Tier 3, we estimate the costs to be approximately one penny per gallon in 2017, 

an estimate that is supported by a recent study by Mathpro. 

Your letter expressed concern about the regulation's potential effects on the refining industry and 

gasoline supply. Let me assure you that as many as 17 refineries are already able to meet the 10 

ppm sulfur standards we are considering, and some are currently producing and exporting to 

Internet Address (URL) . htlp I/wwwepa gov


Recycled/Recyclable Prnted with Vegetable Oil Based Inks on 100% Postconsumer Process Chlorine Free Recycled Paper
European countries gasoline that meets this standard (which is also required in places like Japan, 

South Korea, and a number of other countries). The regulatory flexibility we intend to build into 

the Tier 3 standards, similar to the flexibility we provide in our current fuel programs, will 

ensure that the Tier 3 standards under consideration would not cause refinery closures or 

negatively impact gasoline supply. 

Your letter points to the need for thorough scientific, cost, and benefits analyses before 

proceeding. Let me assure you and your colleagues that we agree that this major rule requires 

robust and transparent analyses of air quality, technological feasibility, and costs, as well as 

potential benefits. As we continue to develop the proposed rule, which has not yet been 

published for comment, we are conducting and documenting a wide range of analyses in all of 

these areas. 

Your letter also asks that the public should be allowed to consider the results of the antibacksliding study required under the Energy Independence and Security Act. I want to 

emphasize that the Tier 3 rule is independent of the anti-backsliding study required by sections 

211(q) and 211(v) of the Clean Air Act. The Tier 3 rule is focused on vehicle emissions 

standards in response to our obligations and authority under section 202(a) and the fuel necessary 

to enable them in response to our obligations and authority under section 211(c). In contrast, the 

anti-backsliding study will examine the broader issues related to impacts of renewable fuels, and 

it is required as a prerequisite to regulations under section 21 1(v). The anti-backsliding study 

will not affect any decisions about gasoline sulfur, which are being informed by a thorough 

analysis of the impact of gasoline sulftir on vehicle emissions and the air quality benefits of 

reduced motor vehicle emissions. We are not promulgating standards under section 211(v) in the 

Tier 3 rulemaking. 

Regarding the refinery sector rule, we agree that thorough analysis of available data is crucial in 

the generation of common sense emission control standards. We have worked diligently to 

evaluate and analyze data received through the Information Collection Request. We have taken 

and will continue to take into consideration the perspective and input of stakeholders as we strive 

to develop a reasonable rulemaking that will achieve meaningful and cost-effective pollution 

reductions in the refining industry. 

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

may call Josh Lewis in EPAs Office of Congressional and Intergovernmental Relations at (202) 

564-2095.

Gina Mccarthy 

Assistant Administrator
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


The Honorable David Vitter AIR AND RADIATION 

United States Senate 

Washington, D.C. 20510 

Dear Senator Vitter: 

Thank you for your letter of January 12, 2012, co-signed by five of your colleagues, concerning 

the U.S. Environmental Protection Agency's forthcoming proposal of the "Tier 3" light-duty 

vehicle emissions and gasoline standards. 

The EPA is developing the Tier 3 standards to respond to the critical need to improve air quality, 

and to enable a harmonized national vehicle emissions control program. This rule would reduce 

motor vehicle emissions and help state and local areas attain and maintain the existing healthbased air quality standards in a cost-effective and timely way. Lower sulfur gasoline is necessary 

to operate the pollution control equipment to achieve new Tier 3 vehicle standards, and will 

facilitate the development of lower cost technologies to improve fuel economy. Improvements 

in fuel economy reduce gasoline consumption and save consumers money. 

The Tier 3 standards would create a comprehensive regulatory approach that provides certainty 

for both the auto and oil industries. Under a single harmonized national vehicle program, the Tier 

3 standards would provide for coordinated implementation with the California vehicle program 

and the EPA and Department of Transportation's recently proposed light-duty vehicle standards 

to reduce carbon pollution and improve fuel economy for model years 2017 through 2025. The 

proposed standards are projected to save approximately 4 billion barrels of oil and 2 billion 

metric tons of carbon pollution over the lifetime of the vehicles. Vehicles meeting these 

standards are projected to provide average net savings to consumers of $3,000 to $4,000 per 

vehicle. Further, the coordinated timing of the Tier 3 and refinery sector niles provides the oil 

industry regulatory certainty and opportunities for cost-efficiency. 

We understand that even minimal increases in the cost of gasoline are of importance to the 

American public. That is why EPA conducted extensive refinery modeling to understand the cost 

impacts of a variety of fuel requirements. As a result, the only fuel requirement we are 

considering for Tier 3 is one that would lower the amount of sulfur in gasoline. As with lead, 

sulfur in fuel impairs the functioning of emission control equipment. By focusing only on sulfur 

requirements in Tier 3, we estimate the costs to be approximately one penny per gallon in 2017, 

an estimate that is supported by a recent study by Mathpro. 

Your letter expressed concern about the regulation's potential effects on the refining industry and 

gasoline supply. Let me assure you that as many as 17 refineries are already able to meet the 10 

ppm sulfur standards we are considering, and some are currently producing and exporting to 

Internet Address CURL) . hIIp 1/wwwepa gov


RecyctedlRecyclable Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycled Paper
European countries gasoline that meets this standard (which is also required in places like Japan, 

South Korea, and a number of other countries). The regulatory flexibility we intend to build into 

the Tier 3 standards, similar to the flexibility we provide in our current fuel programs, will 

ensure that the Tier 3 standards under consideration would not cause refinery closures or 

negatively impact gasoline supply. 

Your letter points to the need for thorough scientific, cost, and benefits analyses before 

proceeding. Let me assure you and your colleagues that we agree that this major rule requires 

robust and transparent analyses of air quality, technological feasibility, and costs, as well as 

potential benefits. As we continue to develop the proposed rule, which has not yet been 

published for comment, we are conducting and documenting a wide range of analyses in all of 

these areas. 

Your letter also asks that the public should be allowed to consider the results of the antibacksliding study required under the Energy Independence arid Security Act. I want to 

emphasize that the Tier 3 rule is independent of the anti-backsliding study required by sections 

211(q) and 211(v) of the Clean Air Act. The Tier 3 rule is focused on vehicle emissions 

standards in response to our obligations and authority under section 202(a) and the fuel necessary 

to enable them in response to our obligations and authority under section 211(c). In contrast, the 

anti-backsliding study will examine the broader issues related to impacts of renewable fuels, and 

it is required as a prerequisite to regulations under section 211(v). The anti-backsliding study 

will not affect any decisions about gasoline sulfur, which are being informed by a thorough 

analysis of the impact of gasoline sulfur on vehicle emissions and the air quality benefits of 

reduced motor vehicle emissions. We are not promulgating standards under section 211(v) in the 

Tier 3 rulemaking. 

Regarding the refinery sector rule, we agree that thorough analysis of available data is crucial in 

the generation of common sense emission control standards. We have worked diligently to 

evaluate and analyze data received through the Information Collection Request. We have taken 

and will continue to take into consideration the perspective and input of stakeholders as we strive 

to develop a reasonable rulemaking that will achieve meaningful and cost-effective pollution 

reductions in the refining industry. 

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

may call Josh Lewis in EPA's Office of Congressional and Intergovernmental Relations at (202) 

564-2095.

Gina M€Carthy 

Assistant Administrator
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, DC. 20460

OFFICE OF


The Honorable Mary L. Landrieu AIR AND RADIATION 

United States Senate 

Washington, D.C. 20510 

Dear Senator Landrieu: 

Thank you for your letter of January 12, 2012, co-signed by five of your colleagues, concerning 

the U.S. Environmental Protection Agency's forthcoming proposal of the "Tier 3” light-duty 

vehicle emissions and gasoline standards. 

The EPA is developing the Tier 3 standards to respond to the critical need to improve air quality, 

and to enable a harmonized national vehicle emissions control program. This rule would reduce 

motor vehicle emissions and help state and local areas attain and maintain the existing healthbased air quality standards in a cost-effective and timely way. Lower sulfur gasoline is necessary 

to operate the pollution control equipment to achieve new Tier 3 vehicle standards, and will 

facilitate the development of lower cost technologies to improve fuel economy. Improvements 

in fuel economy reduce gasoline consumption and save consumers money. 

The Tier 3 standards would create a comprehensive regulatory approach that provides certainty 

for both the auto and oil industries. Under a single harmonized national vehicle program, the Tier 

3 standards would provide for coordinated implementation with the California vehicle program 

and the EPA and Department of Transportation's recently proposed light-duty vehicle standards 

to reduce carbon pollution and improve fuel economy for model years 2017 through 2025. The 

proposed standards are projected to save approximately 4 billion barrels of oil and 2 billion 

metric tons of carbon pollution over the lifetime of the vehicles. Vehicles meeting these 

standards are projected to provide average net savings to consumers of $3,000 to $4,000 per 

vehicle. Further, the coordinated timing of the Tier 3 and refinery sector rules provides the oil 

industry regulatory certainty and opportunities for cost-efficiency. 

We understand that even minimal increases in the cost of gasoline are of importance to the 

American public. That is why EPA conducted extensive refinery modeling to understand the cost 

impacts of a variety of fuel requirements. As a result, the only fuel requirement we are 

considering for Tier 3 is one that would lower the amount of sulfur in gasoline. As with lead, 

sulfur in fuel impairs the functioning of emission control equipment. By focusing only on sulfur 

requirements in Tier 3, we estimate the costs to be approximately one penny per gallon in 2017, 

an estimate that is supported by a recent study by Mathpro. 

Your letter expressed concern about the regulation's potential effects on the refining industry and 

gasoline supply. Let me assure you that as many as 17 refineries are already able to meet the 10 

ppm sulfur standards we are considering, and some are currently producing and exporting to 

Irternet Address CURL) . htIp.Ilwwwepa gov


RecycledlRecyclable . Pnnred with Vegetable Oil Based Inks on 1OO Poatconsumer. Process Chlorine Free Recycled Paper
European countries gasoline that meets this standard (which is also required in places like Japan, 

South Korea, and a number of other countries). The regulatory flexibility we intend to build into 

the Tier 3 standards, similar to the flexibility we provide in our current fuel programs, will 

ensure that the Tier 3 standards under consideration would not cause refinery closures or 

negatively impact gasoline supply. 

Your letter points to the need for thorough scientific, cost, and benefits analyses before 

proceeding. Let me assure you and your colleagues that we agree that this major rule requires 

robust and transparent analyses of air quality, technological feasibility, and costs, as well as 

potential benefits. As we continue to develop the proposed rule, which has not yet been 

published for comment, we are conducting and documenting a wide range of analyses in all of 

these areas. 

Your letter also asks that the public should be allowed to consider the results of the antibacksliding study required under the Energy Independence and Security Act. I want to 

emphasize that the Tier 3 rule is independent of the anti-backsliding study required by sections 

211(q) and 211(v) of the Clean Air Act. The Tier 3 rule is focused on vehicle emissions 

standards in response to our obligations and authority under section 202(a) and the fuel necessary 

to enable them in response to our obligations and authority under section 2 11(c). In contrast, the 

anti-backsliding study will examine the broader issues related to impacts of renewable fuels, and 

it is required as a prerequisite to regulations under section 211(v). The anti-backsliding study 

will not affect any decisions about gasoline sulfur, which are being informed by a thorough 

analysis of the impact of gasoline sulfur on vehicle emissions and the air quality benefits of 

reduced motor vehicle emissions. We are not promulgating standards under section 211(v) in the 

Tier 3 rulemaking. 

Regarding the refinery sector rule, we agree that thorough analysis of available data is crucial in 

the generation of common sense emission control standards. We have worked diligently to 

evaluate and analyze data received through the Information Collection Request. We have taken 

and will continue to take into consideration the perspective and input of stakeholders as we strive 

to develop a reasonable rulemaking that will achieve meaningful and cost-effective pollution 

reductions in the refining industry. 

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

may call Josh Lewis in EPA's Office of Congressional and Intergovernmental Relations at (202) 

564-2095.

ma McCrthy 

Assistant Administrator
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460

OFFICE OF


The Honorable Lisa Murkowski AIR AND RADIATION 

United States Senate 

Washington, D.C. 20510 

Dear Senator Murkowski: 

Thank you for your letter of January 12, 2012, co-signed by five of your colleagues, concerning 

the U.S. Environmental Protection Agency's forthcoming proposal of the "Tier 3" light-duty 

vehicle emissions and gasoline standards. 

The EPA is developing the Tier 3 standards to respond to the critical need to improve air quality, 

and to enable a harmonized national vehicle emissions control program. This rule wou]d reduce 

motor vehicle emissions and help state and local areas attain and maintain the existing healthbased air quality standards in a cost-effective and timely way. Lower sulfur gasoline is necessary 

to operate the pollution control equipment to achieve new Tier 3 vehicle standards, and will 

facilitate the development of lower cost technologies to improve fuel economy. Improvements 

in fuel economy reduce gasoline consumption and save consumers money. 

The Tier 3 standards would create a comprehensive regulatory approach that provides certainty 

for both the auto and oil industries. Under a single harmonized national vehicle program, the Tier 

3 standards would provide for coordinated implementation with the California vehicle program 

and the EPA and Department of Transportation's recently proposed light-duty vehicle standards 

to reduce carbon pollution and improve fuel economy for model years 2017 through 2025. The 

proposed standards are projected to save approximately 4 billion barrels of oil and 2 billion 

metric tons of carbon pollution over the lifetime of the vehicles. Vehicles meeting these 

standards are projected to provide average net savings to consumers of $3,000 to $4,000 per 

vehicle, Further, the coordinated timing of the Tier 3 and refinery sector rules provides the oil 

industry regulatory certainty and opportunities for cost-efficiency. 

We understand that even minimal increases in the cost of gasoline are of importance to the 

American public. That is why EPA conducted extensive refinery modeling to understand the cost 

impacts of a variety of fuel requirements. As a result, the only fuel requirement we are 

considering for Tier 3 is one that would lower the amount of sulfur in gasoline. As with lead, 

sulfur in fuel impairs the functioning of emission control equipment. By focusing only on sulfur 

requirements in Tier 3, we estimate the costs to be approximately one penny per gallon in 2017, 

an estimate that is supported by a recent study by Mathpro. 

Your letter expressed concern about the regulation's potential effects on the refining industry and 

gasoline supply. Let me assure you that as many as 17 refineries are already able to meet the 10 

ppm sulfur standards we are considering, and some are currently producing and exporting to 

Internet Address (L)RL) http.11wwwepa gov


RecycledlRecyclable Printed wirn Vegetable Oil Based Inks on 100% PoStconsurner. Process Chlorine Free Recycled Paper
European countries gasoline that meets this standard (which is also required in places like Japan, 

South Korea, and a number of other countries). The regulatory flexibility we intend to build into 

the Tier 3 standards, similar to the flexibility we provide in our current fuel programs, will 

ensure that the Tier 3 standards under consideration would not cause refinery closures or 

negatively impact gasoline supply. 

Your letter points to the need for thorough scientific, cost, and benefits analyses before 

proceeding. Let me assure you and your colleagues that we agree that this major rule requires 

robust and transparent analyses of air quality, technological feasibility, and costs, as well as 

potential benefits. As we continue to develop the proposed rule, which has not yet been 

published for comment, we are conducting and documenting a wide range of analyses in all of 

these areas. 

Your letter also asks that the public should be allowed to consider the results of the antibacksliding study required under the Energy Independence and Security Act. I want to 

emphasize that the Tier 3 rule is independent of the anti-backsliding study required by sections 

211(q) and 211(v) of the Clean Air Act, The Tier 3 rule is focused on vehicle emissions 

standards in response to our obligations and authority under section 202(a) and the fuel necessary 

to enable them in response to our obligations and authority under section 211(c). In contrast, the 

anti-backsliding study will examine the broader issues related to impacts of renewable fuels, and 

it is required as a prerequisite to regulations under section 211(v). The anti-backsliding study 

will not affect any decisions about gasoline sulfur, which are being informed by a thorough 

analysis of the impact of gasoline sulfur on vehicle emissions and the air quality benefits of 

reduced motor vehicle emissions. We are not promulgating standards under section 211(v) in the 

Tier 3 rulemaking. 

Regarding the refinery sector rule, we agree that thorough analysis of available data is crucial in 

the generation of common sense emission control standards. We have worked diligently to 

evaluate and analyze data received through the Information Collection Request. We have taken 

and will continue to take into consideration the perspective and input of stakeholders as we strive 

to develop a reasonable rulemaking that will achieve meaningful and cost-effective pollution 

reductions in the refining industry. 

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

may callJosh Lewis in EPA's Office of Congressional and Intergovernmental Relations at (202) 

564-2095.

ma Mc'arthy 

Assistant Administrator