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 technica l 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 n atural 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 ded icated 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 alternat ives.

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 n oted 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 G roup 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 vehic les 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 tw o 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 findin gs 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 wil l 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 Sulfu r 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. x ii
4 The Wall Street Journal , Market Data Center, Auto Sales , (accessed on September 30, 2013)