October 25, 2013 

Air and Radiation Docket and Information Center 

Environmental Protection Agency 

Mailcode 2822T 

1200 Pennsylvania Avenue, NW. 

Washington, DC 20460 

Re: Docket ID No. EPA-HQ-OAR-2011-0135 

The U.S. Environmental Protection Agency’s Proposed Rule on Control of Air Pollution From Motor 

Vehicles: Tier 3 Motor Vehicle Emission and Fuel Standards 

Submitted via www.regulations.gov and by email to A-and-RDocket@epamail.epa.gov.

The American Petroleum Institute (API) is providing supplemental written comments to the public 

docket for the Environmental Protection Agency’s proposed Tier 3 light-duty vehicle emissions and fuel 

standards. As noted in our earlier written comments, maintaining a strong domestic refining industry is 

critical to our nation’s economic viability. The proposed Tier 3 rule would impose high costs with 

negligible environmental benefits. Combined with other regulations, such as the RFS2, this rule could 

impact domestic fuel supplies, result in increased consumer costs, and affect energy security. The US 

Environmental Protection Agency (EPA) has failed to provide an adequate scientific justification, 

demonstration of technical need, or evaluation of cost effectiveness for its proposed Tier 3 rulemaking. 

As such, this rule is unnecessary and we oppose promulgation of a final Tier 3 regulation.

API is a national trade association representing all segments of the U.S. oil and natural gas industry. Its 

more than 500 members – including large integrated companies, exploration and production, refining, 

marketing, pipeline, and marine businesses, and service and supply firms – provide most of the nation’s 

energy. Our members are dedicated to meeting environmental requirements, while economically 

developing and supplying energy resources for consumers. Since 2000, our industry invested over $2 

trillion in capital projects in the U.S. to advance all forms of energy, including alternatives.

In our earlier comments, API observed that the establishment of a 10 ppm average gasoline sulfur 

standard in order to facilitate the use of lean burn gasoline direction injection (GDI) engine technology 

lacked adequate technical justification. We noted that the penetration of this technology into the 

market place in areas such as Japan and Europe (where gasoline sulfur is capped by regulation at 10 

ppm) has been limited and is not expected to grow. We also provided a study performed by the Martec 

Group which concluded that, in the US, the potential share for lean-burn GDI engines will reach a 

maximum of ~3% between 2015 and 2020 and decline thereafter as observed in Japan and Europe.1 It is 

 

1

The Martec Group, Technology Cost and Adoption Analysis: Impact of Ultra-Low Sulfur Gasoline Standards, prepared for API, 

April 9, 2010. Note: this report also is available as the following Society of Automotive Engineers technical paper: McMahon,

Robert L. Greco, III

Group Director

Downstream & Industry Operations

1220 L Street, NW

Washington, DC 20005-4070

USA

Telephone 202-682-8167

Fax 202-682-8051

Email greco@api.org

www.api.org 
2

expected that the automakers will rely on other, more cost-effective technologies which will not require 

the highly sulfur sensitive and costly exhaust after-treatment devices needed with lean-burn engines. 

In these supplemental comments, API is submitting, for the record, a recently completed study by H-D 

Systems which re-affirms the findings of the earlier research by the Martec Group. The attached report, 

entitled Future US Trends in the Adoption of Light-Duty Automotive Technologies, provides a detailed 

assessment of the incremental costs, market penetration, GHG emissions reduction and/or fuel 

economy improvement potential associated with the technologies planned for use in all new light-duty 

motor vehicles to 2025.2 The study was based on a comprehensive review of the engineering technical 

literature as well as extensive contacts with the automobile manufacturers and automotive equipment 

suppliers. 

With respect to the lean-burn GDI engine, HD-S notes that while this technology offers significant fuel 

consumption benefits, the ancillary “...piezo fuel injector and the emission control system are expensive, 

and lean burn technology will be restricted to luxury cars to 2020.”

3

 HD-S further observes that two 

luxury European automakers have expressed interest in bringing this technology to the U.S. However, it 

is important to note that the combined total share of the US light-duty vehicle market by these two 

manufacturers does not exceed 3.7%.4 These findings further support the fact that a 10 ppm gasoline 

sulfur standard will not, in and of itself, enable the widespread use of fuel efficient technologies such a 

lean-burn GDI. Instead, as studies by Martec and HD-S show, it is likely that the automakers will focus 

on other, more cost-effective hardware for meeting more stringent future emissions and fuel economy 

standards.

If you have any questions concerning the attached report, please do not hesitate to contact us.

Sincerely, 

Robert L. Greco, III

Group Director

Downstream & Industry Operations

att./

 

K.B., Selecman, C., Botzem, F., and Stablein, B., “Lean GDI Technology Forecast: The Impact of Ultra-Low Sulfur Gasoline 

Standards,” Society of Automotive Engineers Technical Paper Series, Paper No. 2011-01-1226, 2011 

2

H-D Systems, Future US Trends in the Adoption of Light-Duty Automotive Technologies, Final Report, prepared for API, 

September 2013

3

Ibid, p. xii

4

The Wall Street Journal, Market Data Center, Auto Sales, (accessed on September 30, 2013)