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 division 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 the final rule implemented as quickly as 

possible. Cleaner gasoline and vehicles are within reach, but every year they are 

delayed, more Americans needlessly suffer 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 (more 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 traveling along roads every 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 every year. 

Time is also of the essence because addressing sulfur levels in gasoline and 

vehicles together as a “system” further improves the cost-effectiveness of reducing 

emissions, and it allows automakers 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 also 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 identified 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 and less than 1 cent per gallon to gasoline 
costs. According to EPA’s own impact analysis, average costs of hospital care due 

to pollution-related illness alone range from $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 complications 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 additional 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