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 memo 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 Quality (OTAQ)
Robin Moran, Senior Policy Advisor, ASD/OTAQ

The 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 

attached letters in support of the standards.

****************************************************************************

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

From: David Butler <dbutler@consumer.org>

Date: Tue, 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 Advocacy Division of Consumer Reports

Tuesday, November 5, 2013

Consumers Union urges EPA to act quickly on Tier 3 rule

WASHINGTON -- 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 variety 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. 

In a 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 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. 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."

CU is urging the EPA to finalize the 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, 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 economy standards already 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 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
December 5, 2013

The Honorable Gina McCarthy

Administrator, U.S. Environmental Protection 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-threatening 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 

EPA 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 

gasoline 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 will 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 Legislation
GreenFaith

Interfaith Power & Light

Jewish Council for Public Affairs

Maryknoll Office For Global Concerns

Presbyterian Church (U.S.A)

Religious Action Center of Reform Judaism

Sisters of Mercy of the Americas, Institute Justice Team