November 5, 2013

The Honorable Gina McCarthy Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460

Via: mccarthy.gina@epa.gov

Dear Administrator McCarthy:

Consumers Union, the advocacy and policy di vision of Consumer Reports, urges the Environmental Protection Agency to promptly finalize the “Tier 3” rule to lower sulfur in gasoline and reduce vehicle tailpipe emissions. Consumers Union collected 31,068 signatures in support of this rule (submitted as part of our comments to the proposed rule), and we are eager to see t he final rule implemented as quickly as possible. Cleaner gasoline and vehicles are within reach, but every year they are delayed, more Americans needlessly suffe r from preventable air pollution.

Exposure to air pollution from vehicles is widespread, and reducing sulfur in gasoline and cutting tailpipe emissions will provide tremendous benefits to public health. Over 130 million Americans (m ore than 40% of the country ) breathe unhealthy air, and a major source of this pollution is passenger and heavy-duty vehicles. On average, Americans spend over an hour trave ling along roads ever y day. Time spent in the car (especially in congested traffic) increases pollutant exposure, and cars provide little protection against gas-phase pollutants (especially VOCs). Living, working, or going to school near major roadways increases exposure to ozone and particle pollution that worsens lung and heart health and causes thousands of premature deaths ev ery year.

Time is also of the essence because addressing sulfur levels in gasoline and vehicles together as a “syst em” further improves the co st-effectiveness of reducing

emissions, and it allows autom akers to maximize efficiencies in emission reduction technologies. Consumers Union urges the EPA to finalize this rule as soon as possible, not only to avoid delay of the rule ’s health benefits, but al so so that Tier 3 implementation begins in 2017. Thereby, automakers can reduce compliance costs by harmonizing technology selection and development for the Tier 3 standards and Model Year 2017-2025 greenhouse gas and fuel economy standards.

Although the proposed rule has clearly ident ified costs, pollution has costs of much greater magnitude. According to analyses by the EPA and by independent economists, when the standards are fully implemented by 2025, they will likely add less than $150 to the cost of a vehicle an d less than 1 cent per gallon to gasolinecosts. According to EPA’s own impact anal ysis, average costs of hospital care due to pollution-related illness alone range fr om $400 for an emergency room visit to $12,000 for a hospital admission for asthma and from $11,000 to $30,000 to treat other respiratory and heart conditions. Such admissions can be especially expensive or fraught with comp lications for the elderly or those with other health problems. By 2030, the annual health benefits of Tier 3 would be between $8 and $23 billion (double to seven times the costs) . All polluting sectors should contribute their fair share to reducing pollution, and Tier 3 standards are one of the more economical and cost-effective ways to get meaningful reductions to help make air

safe to breathe.

It would be “pennywise, tons foolish” to save a cent on gasoline, only to have to pay

even more with our health as a result of additi onal tons of pollution. To put the cost in perspective, over the last four years, gasoline prices fluctuated over $2.25 dollars per gallon, with weekly increases of 10 cents happening with regularity.

In summary, this common-sense rule can deliver enormous public health benefits, and can be implemented at an affordable cost. We urge the EPA to finalize the rule before the end of this year , so it can apply to 2017 models and sync with 2017-2025 greenhouse gas and fuel economy standards. We thank you for your attention to this important consumer and public health issue.

Sincerely,

Shannon Baker-Branstetter Policy Counsel, Consumers Union