March 25, 2011 

The Honorable Lisa Jackson 

Administrator 

U.S. Environmental Protection Agency 

Ariel Rios Building 

1200 Pennsylvania Avenue NW 

Washington, DC 20460 

Re: Light-Duty Vehicle Emission Standards 

Dear Administrator Jackson: 

I am writing on behalf of the environmental agencies in the Northeast to express our strong support for 

EPA developing a robust federal Tier 3 Light-Duty Vehicle program as soon as possible. The Northeast 

States for Coordinated Air Use Management (NESCAUM) is an association of the air pollution control 

programs in Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, 

and Vermont. Despite significant progress in achieving cleaner air, many states throughout the US face

the continuing challenge of attaining and maintaining current and forthcoming national ambient air 

quality standards. 

NESCAUM and our member states are committed to cleaner air and low-emission vehicles, as evidenced 

by the adoption of the California Low-Emission Vehicle (LEV) program in seven of our member states. 

While a Tier 3 rule would not directly affect emissions from new vehicles sold in these states, it will 

improve air quality in the Northeast by reducing pollution transport from neighboring regions and 

ensuring that out-of-state vehicles operating within our region have comparably low emission 

characteristics. In addition, to the extent that new federal rules are harmonized with the California 

program, it will facilitate compliance by automobile manufacturers. 

Strong federal emission standards for light-duty vehicles remain among the most important strategies for 

protecting public health through the reduction of particulate matter (PM), nitrogen oxides (NOx) and nonmethane organic gases (NMOG). Moreover, motor vehicle standards have driven advancements in costeffective emission control technologies, to the benefit of industry and the public alike. While Tier 2

vehicles are significantly cleaner than their predecessors, there is much more potential to be realized in 

reducing the adverse effects of motor vehicle pollution on public health and the environment. In addition, 

projected increases in air emissions resulting from implementation of the federal Renewable Fuels 

Standard (RFS2) reinforce the need to strengthen emission requirements for light-duty vehicles. 

We believe that it is feasible and appropriate to set federal requirements for exhaust and evaporative

emissions that are comparably stringent to those proposed by the California Air Resources Board (CARB)

in their next low-emission vehicle regulation (LEV III). If changes to fuel specifications are needed to 

enable manufacturers to meet these more stringent standards, EPA should revise its fuel requirements 

accordingly. Specifically, we request that EPA address the following issues as part of a Tier 3 program: 

• Exhaust emissions: Fleet average requirements should be set at levels consistent with CARB’s 

LEV III requirements for NOx, PM, and NMOG. 

• Evaporative emissions: Vehicles should be required to achieve evaporative emissions levels 

consistent with the CARB zero-evaporative emissions standard. 
2

• Certification fuel: Given the prevalence of ethanol as a blended component of motor gasoline, 

and EPA’s recent decision to allow gasoline blends of up to 15 percent ethanol by volume, EPA 

should require the use of a gasoline-ethanol blend in place of indolene as a certification fuel to 

more accurately reflect emissions from in-use vehicles. 

• Fuel sulfur: EPA should require an average motor gasoline sulfur concentration of 10 parts per 

million (ppm). This will enable the use of the most advanced catalysts, thereby facilitating auto 

manufacturers’ efforts to achieve the exhaust emissions levels described above. It will also 

provide important near-term air quality benefits by improving catalyst performance in the existing 

vehicle fleet. 

• Fuel volatility: EPA should set fuel volatility requirements as needed to enable the use of zeroevaporative emissions technology. 

Not only will these measures provide critical benefits for ambient air quality and public health, they will 

also promote economic growth and create jobs throughout the U.S. According to the Manufacturers of 

Emission Controls Association, the emission control technology industry provides 65,000 domestic jobs 

and accounted for $12 billion in economic activity in the U.S. in 2010.1

 Moreover, emissions standards 

have been shown to be very cost effective in terms of public health outcomes. As you are well aware, a

recent EPA study2 found that the health benefits resulting from implementation of the 1990 Clean Air Act 

Amendments exceed costs by a factor of three to one under the most conservative assumptions; under 

assumptions considered most likely, benefits exceed costs by a factor of 30 to 1. 

In summary, we urge EPA to: (1) move expeditiously to set stringent new standards for exhaust and 

evaporative emissions from cars and light trucks; (2) revise motor gasoline requirements if needed to 

facilitate compliance with these new standards; and (3) require the use of a gasoline-ethanol blend in

place of indolene as a certification fuel. We believe that new federal standards consistent with the 

requirements of CARB’s LEV III program are achievable and appropriate in the 2022 timeframe. These 

standards can be met using commercially available technologies, and at a cost that will be recovered 

many times over through reductions in morbidity and mortality throughout the nation. 

We look forward to supporting your work to ensure that the new vehicle standards are strong, achievable, 

and cost-effective. If you have any questions, please contact me or Matt Solomon of my staff at 617-259-

2029 or msolomon@nescaum.org. 

Sincerely, 

Arthur N. Marin 

Executive Director 

Cc: Margo Oge, Director, US EPA Office of Transportation and Air Quality 

 NESCAUM Directors

 

1

 Manufacturers of Emission Controls Association. MECA Highlights Economic Benefits of Mobile Source Emission Control Industry. Press 

release, March 11, 2011. (http://www.meca.org) 

2

 U.S. EPA, 2011. Benefits and Costs of the Clean Air Act: Second Prospective Study – 1990 to 2020.