1 February 6, 2014

Howard Shelanski

Administrator Office of Information and Regulatory Affairs Office of Management and Budget

725 17 th Street, NW Washington, DC 20503

Gina McCarthy

Administrator U.S. Environmental Protection Agency William Jefferson Clinton Building 1200 Pennsylvania Avenue, NW Washington, DC 20004

Dear Administrator Shelanski and Administrator McCa rthy:

On behalf of the National Association of Clean Ai r Agencies (NACAA), we urge you to complete your review and finalize the Tier 3 vehicle emissions and gasoline standards by no later than February 28, 2014 so that the program wil l take effect with the 2017 model year. It is critical that there be no delay in the public healt h, air quality and economic benefits of these standards. NACAA is the organization of air pollut ion control agencies in 43 states, the District of Columbia, four territories and 116 metropolitan areas. The air quality professionals in our member agencies have vast experience dedicated to i mproving air quality in the United States. These comments are based upon that experience. The v iews expressed in this document do not necessarily represent the positions of every st ate and local air pollution control agency in the country.

NACAA strongly supports the Tier 3 regulations prop osed by EPA on May 21, 2013, as we articulated in our June 28, 2013 written comm ents and our testimonies provided at the agency’s April 24 and April 29, 2013 public hearing s. The program includes tailpipe emission standards – applicable to passenger cars, light-dut y trucks, medium-duty passenger vehicles and some heavy-duty vehicles – to be phased in betw een model years 2017 and 2025, as well as an average gasoline sulfur standard of 10 parts per million (ppm) to take effect January 1, 2017. As we said then, and as we are equally certa in now, we know of no other strategy that can achieve such substantial, immediate and cost-ef fective reductions in air pollution as Tier 3. State and local air quality agencies are counting o n these emission reductions to achieve and sustain our clean air goals and we are counting on EPA to issue the final rule by the end of February to ensure that the provisions will be imple mented on schedule.

More than 158 million people across the country li ve in areas where the air they

breathe violates at least one of the health-based N ational Ambient Air Quality Standards (NAAQS). The passenger cars and light trucks to whi ch Tier 3 will apply are primary contributors to these violations, particularly thos e related to ozone and fine particulate matter,

both of which have serious and well-documented adve rse health and welfare impacts.2 The emission reductions that will result from Tier 3, as proposed by EPA, will benefit the citizens of e very state and locality across the nation. In a study o ur association published while EPA was preparing th e Tier 3 proposal NACAA estimated that the overnight reducti ons in emissions of nitrogen oxides (NO

x ) from the existing fleet, due to the use of Tier 3’s low-sulfur gasolin e and the associated improved effectiveness of NO

x controls on existing vehicles, will be nearly 300,000 tons. Thi s is equivalent to taking 33 million cars off our n ation’s roads in 2017 when the program will begin. By 2030 and beyo nd, the Tier 3 program will yield additional substan tial

reductions in onroad mobile source emissions of NO

x , volatile organic compounds, carbon monoxide, benz ene and other toxic air pollutants.

These huge benefits come at a modest cost – less th an a penny a gallon for the low-sulfur gasoline component of the program and less than $150 per veh icle in 2025 for the Tier 3 vehicle emission control technologies. Meanwhile, the cost-effectiveness of Tier 3 is high, at $4,500 per ton of hydrocarbon (N MOG)+NO

x removed in 2030, which is far more cost effective t han most other potential NO

x reduction measures being considered in various part of the country.

In addition, Tier 3 will provide new employment opp ortunities, including 1,000 front-end design and engineering jobs and 6,000 construction jobs at ref ineries. These 7,000 new refinery jobs represent a 10-percent increase in employment in the petroleum sector comp ared to the 65,000 workers employed in 2009.

Finally, the Tier 3 program is feasible today. The vehicle technologies are consistent with, or nearl y identical to, those on current California cars. In addition, California’s gasoline already meets a st andard of 10 ppm sulfur, on average, and gasoline in the European Un ion and Japan is subject to a 10-ppm sulfur cap, wh ile China has adopted requirements for 10 ppm sulfur to take effect in 2017.

EPA’s Tier 3 rule is critical to efforts across the country to attain and maintain health-based air qu ality standards as well as to make meaningful strides in addressing toxic air pollution, regional haze and t he eutrophication of water bodies. It is, therefore, imperative that OMB expedite its review of the Tier 3 rule and that EPA issue the final regulation by the end of Februa ry 2014 so that it can be implemented on schedule, beginning with the 2017 model year, and our nation will reap its many important benefits.

Sincerely,

Barry R. Wallerstein Nancy L. Seidman (South Coast Air Quality Management District) (Mas sachusetts)

Co-Chair Co-Chair

NACAA Mobile Sources and Fuels Committee NACAA Mob ile Sources and Fuels Committee

cc: Robert Perciasepe (EPA) Janet McCabe (EPA) Christopher Grundler (EPA) Dominic Mancini (OMB) Jim Laity (OMB)