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 agencie s in the Northeast to express our strong support fo r EPA developing a robust federal Tier 3 Light-Duty V ehicle 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 achiev ing cleaner air, many states throughout the US face the continuing challenge of attaining and maintaini ng current and forthcoming national ambient air quality standards.

NESCAUM and our member states are committed to clea ner air and low-emission vehicles, as evidenced by the adoption of the California Low-Emission Vehi cle (LEV) program in seven of our member states. While a Tier 3 rule would not directly affect emiss ions from new vehicles sold in these states, it wil l improve air quality in the Northeast by reducing po llution transport from neighboring regions and ensuring that out-of-state vehicles operating withi n our region have comparably low emission characteristics. In addition, to the extent that ne w federal rules are harmonized with the California program, it will facilitate compliance by automobil e manufacturers.

Strong federal emission standards for light-duty ve hicles remain among the most important strategies f or protecting public health through the reduction of p articulate matter (PM), nitrogen oxides (NO

x ) and nonmethane organic gases (NMOG). Moreover, motor vehic le standards have driven advancements in costeffective emission control technologies, to the ben efit of industry and the public alike. While Tier 2 vehicles are significantly cleaner than their prede cessors, there is much more potential to be realize d in reducing the adverse effects of motor vehicle pollu tion on public health and the environment. In addit ion, projected increases in air emissions resulting from implementation of the federal Renewable Fuels Standard (RFS2) reinforce the need to strengthen em ission requirements for light-duty vehicles.

We believe that it is feasible and appropriate to s et federal requirements for exhaust and evaporative emissions that are comparably stringent to those pr oposed 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 s tandards, EPA should revise its fuel requirements accordingly. Specifically, we request that EPA addr ess the following issues as part of a Tier 3 progra m:

• Exhaust emissions: Fleet average requirements should be set at levels consistent with CARB’s LEV III requirements for NO

x , 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 compon ent 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 vehic les.

• Fuel sulfur: EPA should require an average motor gasoline sulfu r 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 emiss ions 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 nee ded to enable the use of zeroevaporative emissions technology.

Not only will these measures provide critical benef its for ambient air quality and public health, they will also promote economic growth and create jobs throug hout 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 study 2 found that the health benefits resulting from impl ementation 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 belie ve that new federal standards consistent with the requirements of CARB’s LEV III program are achievab le and appropriate in the 2022 timeframe. These standards can be met using commercially available t echnologies, 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 t hat the new vehicle standards are strong, achievabl e, and cost-effective. If you have any questions, plea se contact me or Matt Solomon of my staff at 617-25 9- 2029 or msolomon@nescaum.org.

Sincerely,

Arthur N. Marin

Executive Director

Cc: Margo Oge, Director, US EPA Office of Transpor tation 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 Pro spective Study – 1990 to 2020.