1 Brunner, Christine

From: Sargeant, Kathryn

Sent: Wednesday, February 26, 2014 12:15 PM

To: Tier 3 Rule Team

Cc: Grundler, Christopher; Charmley, William; Birgfeld, Erin; Mylan, Christopher; Hengst, Benjamin; Cook, Leila Subject: FYI: CleanAir Watch and API dueling emails

Importance: High

See below...

From: Frank O'Donnell [ mailto:cleanairfrank@cleanairwatch.org ]

Sent: Wednesday, February 26, 2014 11:19 AM

To: cleanairfrank@cleanairwatch.org Subject: Is Big Oil flying the white flag of surrender on " Tier 3" clean-gas, clean-car standards?
Importance: High

Dear friends,

Perhaps the oil industry is now resigned to its fat e. I am talking about new EPA smog- fighting “Tier 3” standards that will
require cleaner gasoline and cleaner new vehicles.

That’s the only way I can account for the email, be low, that API chief Jack Gerard sent out this morni ng. It looks as if
Gerard is flying the white flag of surrender and si mply asking for surrender terms.

As I and many others have noted repeatedly, this EP A plan is the best and most effective smog-fighting tool available. (If
you need more, please let me know!)

We are hoping that EPA issues a final rule as soon as possible – this week!

Gerard’s email does nothing more than repeat refute d studies about the cost of the clean-gas standards (less than a
penny a gallon), about its environmental impact (it will reduce soot and smog-forming nitrogen oxides –enough to
prevent 2,500 premature deaths a year! )-- while fl eet emission reductions will more than offset ghg e missions from
running pollution control equipment. (Big Oil’s co ncern for climate seems so lame and hypocritical!)

Here is email, in case you missed it:

**

From: Jack Gerard, API < Jack_Gerard_API@mail.vresp.com > Date: Wed, Feb 26, 2014 at 8:44 AM
Subject: EPA’s Unnecessary New Gas Regulation

Click to view this email in a browser

February 26, 2014 The Renewable Fuel

Standard 

## EPA’s Unnecessary New Gas2 

## Regulation In addition to Tier 3, the

Renewable Fuel Standard (RFS) is part of a regulatory wave with the potential to exert upward pressure on gasoline prices. Learn more about the evidence against the RFS

.

Follow our Blog to stay upto-date

To stay up-to-date on the latest energy-related news, there is no better place to check than the Energy Tomorrow Blog

. Dear xxx,

Fairly soon, the Environmental Protection Agency (E PA) is expected to finalize new restrictions on the sulfur content of fuel – restrictions that are both costly and unn ecessary. Although the nation’s refiners have already reduced average sulfur content by 90 percent – from 300 par ts per million (ppm) to 30 ppm -- EPA’s new Tier 3 rule wo uld mandate a further reduction from 30 to 10 ppm.

Simple cost-benefit analysis demonstrates the new T ier 3 rule is misguided:

• According to a study by ENVIRON , removing the last bits of sulfur from gasoline would provide negligible, if any, environmental benefits. Baker & O’Brien found the rule will actually increase CO2

emissions at U.S. refineries because of the

energy- intensive hydro treating equipment needed

to meet the new standard.

• If finalized, the rule could lead to $10 billion in new capital costs; the annual compliance cost is $2.4 billion, equating to a potential increase of betwee n 6 cents and 9 cents per gallon to the cost of making gasoline, according to a study by Baker &

O’Brien

.

• The EPA’s proposed under three-year timeframe leaves little opportunity for refiners to design, engineer, permit, construct, start up, and integrat e the new machinery required – forcing an accelerated implementation that adds costs and potentially limits the industry’s ability to supply gasoline to consumers.

• EPA has failed to provide the evidence that this new standard would appreciably improve air quality. In fact, EPA’s proposed 10 parts per million standard is completely arbitrary -- not at all supported by science.

The current Tier 2 standard is still providing sulf ur reductions, and tailpipe emissions from our nation’ s vehicle fleet will continue to drop under existing regulations as more new cars and trucks come into t he market that can take advantage of today’s advanced, cleaner burning fuel. We can all agree that protect ing the public’s health and the nation’s environment is imp ortant. However, EPA’s Tier 3 regulations for gasoline go t oo far,

too fast.

Sincerely,

Jack Gerard

President and CEO

API