January 11, 2012

BY EMAIL AND US MAIL TRANSMISSION

The Honorable Lisa Jackson

Administrator

USEPA Headquarters

Ariel Rios Building

Mail Code: 1101A

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

jackson.lisa@epa.gov

Dear Administrator Jackson:

We are writing to strongly urge you to take an important step to reduce pollution from the 

nation's cars, light trucks, and sport-utility vehicles. In particular, we respectfully ask you 

to immediately propose Tier 3 emissions and gasoline standards for passenger vehicles

and to finalize these protections by the summer of 2012. A rigorous Tier 3 program 

would have immediate and far-reaching health and environmental benefits: reducing a 

cascade of harmful airborne contaminants, ensuring longer and healthier lives, and 

helping states and communities across our country restore healthy air. These vital health 

protections will be achieved at an extremely modest cost – the additional cost to 

consumers of the cleaner gasoline would be less than a penny a gallon. And timely 

finalization of Tier 3 standards would allow manufacturers to efficiently align technology 

upgrades with pending fuel efficiency and greenhouse gas emissions standards. Now is 

the time to secure these human health protections for our nation. 

Millions of Americans breathe cleaner, healthier air as a result of the U.S. Environmental 

Protection Agency's leadership in carrying out our nation's clean air laws. But serious 

challenges remain. More than 1 in 3 Americans still live in areas where air pollutant 

levels exceed at least one of the health-based National Ambient Air Quality Standards. 

And passenger vehicles remain the second largest emitters of oxides of nitrogen and 

volatile organic compounds in the U.S. – the primary pollutants that form ozone. These 

vehicles also emit more than half of all carbon monoxide pollution and contribute 

significantly to lethal particulate matter emissions.

A protective Tier 3 program has the potential to cut gasoline vehicle emissions of 

nitrogen oxides by nearly sixty percent, carbon monoxide by about 38 percent, and 

volatile organic compounds by close to a third when these protections are carried out. 

The substantial emissions reductions from all vehicles will translate into more than 400 

avoided premature deaths and 52,000 avoided lost workdays each year.1

 1 NACAA, Cleaner Cars, Cleaner Fuel, Cleaner Air: The Need for and Benefits of Tier 3 

Vehicle and Fuel Regulations; October, 2011. 
Reducing sulfur in gasoline will also result in an immediate reduction in emissions from

the existing fleet – on the order of approximately 260,000 tons of nitrogen oxides in 2017 

when the program begins – equivalent to taking 33 million cars off our nation’s roads. 

A timely federal Tier 3 program is also imperative for states to meet the health-based 

National Ambient Air Quality Standards, including the ozone standard adopted in 2008,

which assumed final Tier 3 emissions and gasoline standards in its baseline. Emissions

reductions not achieved through a rigorous Tier 3 program would have to come from 

controls on local sources, which could be far less significant in magnitude and less costeffective.

A timely Tier 3 program is critical to protect human health from transportation sector 

pollution and one of the single most cost-effective solutions our nation can deploy to help 

states achieve and maintain healthy air in communities out of compliance with healthbased national air quality standards. We cannot afford to delay these vital clean air 

protections for millions of Americans.

In a May 2010 Rose Garden ceremony, President Obama announced his intention to 

finalize a Tier 3 program by 2012 that would reduce sulfur levels in gasoline and 

introduce cleaner cars, light trucks and sport-utility vehicles on the same schedule as his 

already-finalized greenhouse gas program. Proposing this program now will help ensure 

that the President’s commitment is kept. Thus, we strongly urge you to propose this 

program as soon as possible.

Sincerely,

Frances Beinecke

President

Natural Resources Defense Council

Michael Brune

Executive Director

Sierra Club

Kevin Knobloch

President

Union of Concerned Scientists

Fred Krupp

President

Environmental Defense Fund

cc: Bob Perciasepe, Deputy Administrator, EPA (perciasepe.bob@epa.gov) 

Gina McCarthy, Assistant Administrator, OAR (mccarthy.gina@epa.gov) 

Nancy Sutley, Chair, CEQ (Nancy_H._Sutley@ceq.eop.gov) 

Gary Guzy, Deputy Director, CEQ (Gary_S._Guzy@ceq.eop.gov)

Margo Oge, Director, OAR/OTAQ (oge.margo@epa.gov) 

Cass Sunstein, Administrator, OIRA (Cass_R._Sunstein@omb.eop.gov)

Heather Zichal, Deputy Assistant to the President for Energy and Climate Change, 

(Heather_R._Zichal@who.eop.gov)