**UNITED STATES ENVIRONMENTAL PROTECTION AGENCY** NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2000 TRAVERWOOD DRIVE ANN ARBOR, MI 48105

- 2498

OFFICE OF AIR AND RADIATION February 10, 2014
MEMORANDUM
SUBJECT: NGOs Meeting with Janet McCabe regarding Tier 3 Rule
FROM: Robin Moran, Senior Policy Advisor TO: EPA Docket # EPA

- HQ

- OAR

- 2009

- 0472

This me mo documents a meeting held on December 5, 2013, between EPA and representatives of several non

- governmental organizations, labor unions, and emissions control manufacturing companies to discuss the Tier 3 vehicle and fuel standards. The meeting attendees included the following:
**Name Organization**  Rob McCulloch Blue Green Alliance Paul Bugala Calvert Investments Tim Regan Corning , Inc Patricia Bruckbauer Creation Justice Ministries Mark McLeod Environmental Defense Fund Mary Minette Evangelical Lutheran Church in America Dave Bushnell JMD Associates on behalf of BASF
Bill Becker National Association of Clean Air Agencies Luke Tonachel Natural Resources Defense Council Jesse Prentice

- Dunn Sierra Club Meghan Higgins Union of Concerned Scientists Roy Houseman United Steelworkers Jalonne White

- Newsome WE ACT for Environmental Justice EPA participants included: Janet McCabe , Acting Assistant Administrator for Air and Radiation Bill Charmley , Director, Assessment and Standards Division (ASD), Office of Transportation and Air Qualit y (OTAQ)Robin Moran, Senior Policy Advisor, ASD/OTAQ
Th e discussion topics included these organizations’ support for the Tier 3 program and its broad public health benefits. The groups also urged the Agency to finalize the Tier 3 rule as soon as possible, so that the air quality and health benefits could be achieved. The groups delivered the attach ed letters in support of the standards.

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---------- Forwarded message

---------- From: **David Butler** < dbutler@consumer.org > Date: Tu e, Nov 5, 2013 at 3:51 PM Subject: Consumers Union urges EPA to act quickly on Tier 3 rule To: Shannon Baker

- Branstetter < sbaker

- branstetter@consumer.org > **News Release Consumers Union**  **Policy and Advoca cy Division of Consumer Reports**  **Tuesday, November 5, 2013 Consumers Union urges EPA to act quickly on Tier 3 rule**  WASHI NGTON

-- Consumers Union, the policy and advocacy division of Consumer Reports, today wrote the Environmental Protection Agency (EPA) to urge quick action to finalize the "Tier 3" rule to lower sulfur in gasoline and reduce vehicle tailpipe emissions. A variet y of health, environmental, and consumer groups are pressing the agency to take action before the end

- of

- 2013 deadline to ensure the rules are implemented starting in 2017 as planned. Ina letter to EPA Administrator Gina McCarthy , CU policy counsel Shannon Baker

- Branstetter wrote, "Cleaner gasoline and vehicles are within reach, but every year they are delay ed, more Americans nee dlessl y 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. Li ving, working, or going to school ne ar major roadway s increases exposure to ozone and particle pollution that worsens lung and heart health and causes thousands of premature deaths every y ear." CU is urging the EPA to finalize the rule as soon as possible, not only to avoid delay

of the r ule’s health benefits, but also so that Tier 3 implementation begins in 2017, so 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 econom y st andards alread y in place. CU collected more than 31,000 signatures in support of the rule. See below for the full text of the letter: November 4, 2013 The Honorable Gina McCarthy Environmental Protection Agency1200 Pennsylvania Avenue, N.W.

Washingt on, DC 20460 Via: mccarth y. gina@epa.gov Dear Administrator McCarthy : Consumers Union, the advocacy and policy

division of Consumer Reports, urges the Environmental Protection Agency to promptly

fi nalize 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 rul e implemented as quickl y 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 su lfur 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 heav y - dut y vehicles. On average, Americans spend over an hour traveling along roads every day

. Time spent in the car (especiall y in congested traffic) increases pollutant exposure, and cars provide little protection against gas

- phase pollutants (especiall y VOCs). Li ving, working, or going to school near major roadway s 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 g asoline and vehicles together as a “s ys tem” 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. Thereb y, automakers can reduce compliance costs b y harmonizing technology selection and development for the Tier 3 standards and Model Year 2017

- 2025 greenhouse gas and fuel econom y standards. Although the proposed rule has clearl y identified costs, pollution has costs of much greater magnitude. According to anal ys es b y the EPA and by independent economists, when the standards are ful ly

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 anal ys is, average costs of hospital care due to pollution

- related illness alone range fro m $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 tho se 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 o ne of the more economical and cost

- effective way s to get meaningful reductions to help make air safe to breathe. Itwould be “penn ywise, tons foolish” to save a cent on gasoline, only to have to pay

even more with our health as a result of additional to ns of pollution. To put the cost in perspective, over the last four years, gasoline prices fluctuated over $2.25 dollars per gallon, with weekl y increases of 10 cents happening with regularit y. Insummary , this common

- sense rule can deliver enormous pu blic health benefits, and can be implemented at an affordable cost. We urge the EPA to finalize the rule before the end of thisye ar, so it can appl y to 2017 models and sync with 2017

- 2025 greenhouse gas and fuel econom y

standards. We thank you for your attention to this important consumer and public health issue. Sincerel y, Shannon Baker

- Branstetter Policy Counsel, Consumers UnionDecember 5, 2013

The Honorable Gina McCarthy Administrator, U.S. Environmental Protecti on Agency William Jefferson Clinton Building Mail Code 1101A 1200 Pennsylvania Ave., N.W. Washington, DC 20460 Dear Administrator McCarthy: As representatives of our nation’s diverse faith communities, we write to express our gratitude to the Environmental Protection Agency (EPA) for proposing strong “Tier 3” clean vehicle and fuel standards, which will reduce smog

- forming pollution, make our air healthier to breathe, and save lives. We also write to strongly urge you to finalize these critical standards expeditiously. **The longer the standards are delayed, the longer the health of God’s creation, as well as the health of our**  **most vulnerable citizens**

**– those in low** 
**- income communities, our elderly, and our children** 

**– must wait and suffer the life** 
**- threatenin**  **g consequences of air that is dangerous to breathe.** As people of faith, we are taught through our sacred texts to love our neighbors and to serve the least among us. Our shared values as a society demand that our air be safe to breathe for everyone. The EP A has been charged with ensuring that **all** people are protected from significant risks to human health and the environment where they live, learn, and work. In order to fulfill that mission, these standards must be finalized as soon as possible. It is also important to act quickly because of the increasing number of high heat days due to climate change. As temperatures rise, limiting ozone

- forming pollution becomes even more urgent. President Obama has highlighted the impacts that climate change is already having on communities across the nation. We must seek out every available option for limiting pollution that exacerbates the impact of climate change. The health benefits associated with the Tier 3 proposal are clear. By reducing the sulfur content of gaso line and tailpipe pollution, the proposed standards would prevent up to 2,400 premature deaths, 3,200 hospital visits, and 22,000 asthma attacks annually by 2030. Further, the standards would prevent 1.8 million lost school and workdays. These benefits wil l only

be achieved once the standard is finalized and implemented. As representatives of diverse faith communities across the U.S. concerned with the health of our citizens and our environment, we urge you to finalize Tier 3 standards as soon as possible and prevent any further delays of these critical safeguards. Faithfully , Carmelite NGO Coalition on the Environment and Jewish Life Columban Center for Advocacy and Outreach Creation Justice Ministries Evangelical Environmental Network Evangelical Lutheran Church in America Friends Committee on National LegislationGreenFaith

Interfaith Power & Light Jewish Council for Public Affairs Mary knoll Office For Global Concerns Presby terian Church (U.S.A) Religious Action Center of Reform Judaism Sisters of Mercy of the Americas, Institute Justice Team