UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY 

2000 TRAVERWOOD DRIVE 

ANN ARBOR, MI 48105-2498 

 OFFICE OF 

 AIR AND RADIATION 

May 13, 2013 

MEMORANDUM 

SUBJECT: Meeting with National Association of Clean Air Agencies Members Regarding 

the Proposed Tier 3 Standards 

FROM: Catherine Yanca, Assessment and Standards Division 

Office of Transportation and Air Quality 

TO: EPA Docket # EPA-HQ-OAR-2011-0135 

This memo documents a meeting held on May 13, 2013 between the members of the National 

Association of Clean Air Agencies (NACAA) and the Environmental Protection Agency (EPA) 

to discuss EPA’s proposed Tier 3 standards for motor vehicle emissions and fuels. 

Representatives of the following NACAA member agencies and organizations attended the 

meeting via phone: 

Alaska 

Connecticut 

Dayton 

Delaware 

Georgia 

Illinois 

Kentucky 

Louisville 

Maine 

Maryland 

Massachusetts 

Mid-Atlantic Regional Air Management 

Association (MARAMA) 

Minnesota 

Mississippi 

NACAA 

New Hampshire 

New Jersey 

New York 

North Carolina 

Northeast States for Coordinated Air Use 

Management (NESCAUM) 

Oklahoma 

Oregon 

Pennsylvania 

Philadelphia 

Puget Sound 

Rhode Island 

South Carolina 

Virginia 

Wisconsin 
The following EPA representatives participated in the meeting: 

Megan Beardsley 

Rudy Kapichak 

Paul Machiele 

Michael Olechiw 

Kathryn Sargeant 

The meeting included an overview of the proposed Tier 3 standards presented by EPA, slides 

attached below, followed by a clarifying questions from NACAA members. 

Attachment: 
Tier 3 Vehicle and Fuel Standards:

Proposal Overview

May 13, 2013

1
Overview

• Background on Tier 3

• Vehicle Standards

• Fuel Standards

• Emissions and Air Quality Impacts

• Benefits and Costs

• Comment Period and Hearings

2
What is Tier 3?

3

• Systems approach to reducing motor vehicle 

pollution: more stringent vehicle standards enabled 

by gasoline sulfur control

• Creates a harmonized vehicle program

– Coordinated with California LEV III and Light-duty GHG 

standards finalized last year for model years (MY) 2017- 2025

– Enables auto industry to produce and sell one vehicle 

nationwide

• Part of comprehensive approach to create cleaner, 

more efficient vehicles

– Begins phasing in with model year 2017

– To allow coordinated compliance with LEV III and LD GHG
Why Tier 3: Air Quality and Public Health

• Tier 3 standards would have immediate health 

and air quality benefits

• Will help attain and maintain ozone and PM 

NAAQS

– Provides cost-effective national reductions that avoid 

more expensive local controls

• Reduces pollution near roads

– More than 50 million people live, work, or go to school 

near major roads 4
Why Tier 3: Harmonized Vehicle Program

• California finalized LEV III standards last year

– EPA issued a waiver under CAA in December 2012

• The auto industry supports Tier 3 because they 

want to produce and sell one vehicle nationwide

• Tier 3 is harmonized with LEV III

– Would begin in 2017 to allow coordinated compliance 

with GHG and LEV III

5
Tier 3 Vehicle Standards

• Phase in between 2017 and 2025

• Tighter VOC and NOx tailpipe standards

– 80% reduction from today’s fleet average

• Tighter PM tailpipe standard

– 70% reduction in per-vehicle standard

• Evaporative emissions standards

– Reduced fuel vapor emissions and improved system 

durability

6
Vehicle Standards

• Vehicles we propose to address

– Light-Duty Vehicles (LDVs –passenger cars and very 

small trucks)

– Light-Duty Trucks (LDTs – larger pickups and minivans)

– Medium-Duty Passenger Vehicles (MDPVs)

• Heavy duty vehicles between 8,500 and 10,000 lbs 

GVW, designed for passenger transport

– Heavy-duty (HD) pickups and vans

• “Class 2b and 3” vehicles -- 8,500 to 14,000 lbs 

GVW

7
Vehicle Tailpipe Standards: NMOG and NOx FTP

• FTP=Federal Test Procedure

– Standard test procedure designed to capture cold start 

and average drive cycle emissions.

• Proposed Emission Standards

– Fleet average standards in the form of NMOG+NOx

• Provides flexibility to the manufacturers to certify to a lower fleet 

average with no compromise in environmental benefits

– Standards would decline from a fleet average today of 

160 mg/mi to 30 mg/mi by 2025

– Propose declining fleet average starting MY 2017 for 

<6000 lb GVW and 2018 for > 6000 lb GVW

8
NMOG+NOx Fleet Average Standards

• Phase-in and credits:

– Program will allow vehicle manufacturers to earn credits in 2015 and 2016 

9

Final Tier 3 Standard 

30 mg/mi
Vehicle Tailpipe Standards: 

NMOG and NOx SFTP

• SFTP=Supplemental Federal Test Procedure

– Introduced in late 1990’s to address operation not captured in 

historic test cycles

– Two SFTP specific test cycles

• US06 – Rapid accelerations and high speeds

• SC03 – Air conditioning usage at hot summer temperatures

– SFTP standards are composite of FTP, SC03, and US06

• Proposed Tailpipe Emission Standards

– Tier 3 composite SFTP standards for NMOG+NOx would focus 

on preventing excess fuel enrichment and lubricating oil 

consumption

• Declining from a fleet average of about 100 mg/mi to 50 mg/mi

• Fleet average decreases between 2017 to 2025 (consistent w/FTP)

10
Vehicle Tailpipe Standards: PM

• Existing Tier 2 PM standards

– Tier 2: FTP – 10 mg/mi, SFTP – 70 mg/mi (weighted)

• Proposed Tier 3 PM per-vehicle standards

– FTP standard of 3 mg/mi

– SFTP: US06-only standard of 10 mg/mi for 

LDVs~LDT2s and 20 mg/mi for LDT3s and LDT4s

– Cap standards: Intended to bring all vehicles to typical 

levels already being achieved

• To encourage optimization of fuel controls, oil consumption 

controls, and combustion chamber design

– Phase in from 10% to 100% of an OEM’s fleet from MY 

2017 to MY 2022 11
Standards for Heavy-Duty Pickups and Vans

• Proposing standards of comparable 

stringency to light-duty, but numerically 

higher to reflect more demanding duty cycles

• Phase in from 2018 to 2022

– For vehicles >6000 GVW, CAA requires 4 years of 

lead time and 3 years of regulatory stability

– Proposal includes optional phase-ins that allow for 

this 12
Vehicle Standards: Evaporative Emissions

• Key elements

– Lower the existing standards to bring nationwide the 

evap control technology used in California

– Incentivize improved in-use system durability through 

system design improvements, extended useful life

– Introduce a new leak emission standard

– Bring nationwide the Onboard Diagnostic 

requirements used in California (helping to also 

facilitate the new leak standard)

• Standards cover all gasoline powered highway 

vehicles 13
Certification Fuel Changes

• Updating vehicle certification test fuel specifications 

used for vehicle testing

• Key highlights

– 10 ppm sulfur

– 15 vol% ethanol

• Forward looking with respect to ethanol content

• Ensures new vehicles are designed for the fuels they may see in 

the future

– 87 octane

• Also proposing certification test fuel specifications 

for E85 to provide greater consistency and stability 

in FFV testing

• Provisions to allow for testing on other fuels for 

vehicles that require their use (e.g., premium)

14
Why Lower Sulfur Gasoline?

• Both Tier 3 and LEV III vehicle standards depend upon lower 

sulfur gasoline

– Sulfur at current levels degrades the performance of vehicle catalytic 

converters the primary emission control system on vehicles

• Tier 3 vehicle standards not achievable without lower sulfur

• Lower sulfur also provides immediate reductions in NOx and VOC 

emissions from the existing fleet

• California already has lower sulfur gasoline (as do Europe, 

Japan, S. Korea, and several other countries)

– Other states prohibited from controlling gasoline sulfur on their own

• Enables some lower-cost technologies for complying with vehicle 

greenhouse gas standards 15
Tier 3 Fuel Standards

• Lower the average sulfur standard from 30 to 10 ppm 

starting January 1, 2017

– California is already 10 ppm sulfur on average, and Europe 

and Japan have a 10 ppm cap

• Proposing to either:

– Maintain the current per-gallon sulfur caps (80 ppm at 

refinery gate, 95 ppm at retail); or 

– Lower caps to 50 ppm at refinery gate, 65 ppm at retail

• Seeking comment on 20 ppm/25 ppm caps

• Lower caps would take effect on 1/1/2020

16
Fuel Flexibilities

• Proposing the superset of flexibilities that have proven successful in 

past EPA fuel programs

• Annual average standard with a sufficiently high per-gallon cap

• Early credit program to phase in the sulfur standard from January 1, 

2014 through December 31, 2019

• Relief for small refiners and refineries <75,000 barrels per day

– Delay of 3 years through December 31, 2019, consistent with the end of the 

early credit phase-in for large refiners

– Total of 35 refineries representing a total of 10% of gasoline production

• Economic and Technical Hardship provisions available to all 

refiners

– EPA has granted hardship relief to over a dozen refineries under past fuel 

regulations; many more for RFS

17
Refinery-by-Refinery Results

• Of the total 111 refineries regulated:

– 29 No capital changes (no or minimal cost),

– 66 Revamp existing unit (moderate costs), 

– 16 Add new grassroots posttreater (higher costs)

18

Revamp New - Grassroots
Tier 3 Emission Impacts

• Emission reductions will continue to grow beyond 2030 as more of the fleet 

continues to turn over to Tier 3 vehicles 19

National Onroad Inventory Reductions

2017 2030

Tons Percent Tons Percent

NOx 284,000 8 525,000 28

VOC 45,000 3 226,000 23

PM 2.5 NA NA 7,500 10

CO 747,000 4 5,765,000 30

Benzene 1,625 4 8,581 36

Total air toxics 15,000 3 90,000 23
Ozone Reductions in 2017

20
Ozone Reductions in 2030

21
PM2.5 Reductions in 2030

22
Benefits of Tier 3

23

 Total Ozone and PM-related Premature Mortality Avoided: 

 820-2,400 in 2030 (based on range of ozone and PM mortality studies)

 Other PM- and ozone-related health impacts avoided in 2030:

 Hospital admissions and asthma-related ER visits: 3,200

 Asthma exacerbations: 22,000

 Upper and lower respiratory symptoms in children: 23,000

 Lost school days, work days, and minor restricted activity days: 1.8 million

 Total Monetized Benefits in 2030 (2010$):

 $8 to $23 Billion
Summary of Costs and Benefits

• Fuel Sulfur Standard

– 0.89 cents per gallon

– $2.1 billion in capital costs over 6 year phase-in period

– Based on a detailed, peer-reviewed, refinery-by-refinery analysis

• Vehicle Standards in 2025

– $130 per vehicle

• Annual Cost in 2030

– Vehicle Program: $2.0 billion

– Fuel Program: $1.3 billion

– Total Program: $3.4 billion

• Total Monetized Benefits in 2030

– $8 to $23 Billion

24
RIA Table of Contents

• Executive Summary

• Chapter 1: Vehicle Program Technological Feasibility

• Chapter 2: Vehicle Program Cost and Effectiveness

• Chapter 3: Establishing New Emissions Test Fuel Parameters

• Chapter 4: Fuel Program Feasibility

• Chapter 5: Fuel Program Costs

• Chapter 6: Health and Environmental Effects Associated with 

Exposure to Criteria and Toxic Pollutants

• Chapter 7: Impacts of the Proposed Rule on Emissions and Air 

Quality

• Chapter 8: Comparison of Costs to Emission Reductions and Air 

Quality Benefits

• Chapter 9: Economic Impact Analysis

• Chapter 10: Initial Regulatory Flexibility Analysis

25
Public Participation

• Comment period closes June 13

• Hearings held April 24 and 29

– Philadelphia and Chicago

– Broad spectrum of stakeholders, including citizens

– All testifiers supported Tier 3 except oil industry

• American Petroleum Institute, American Fuel and 

Petrochemical Manufacturers, Marathon

26