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January 22, 2013 

Lisa P. Jackson 

Administrator 

U.S. Environmental Protection Agency 

Ariel Rios Building 

1200 Pennsylvania Avenue, NW 

Washington, DC 20004 

Dear Administrator Jackson:

 We write to you today on behalf of the National Association of Clean Air Agencies 

(NACAA) to urge you to propose the Tier 3 vehicle emissions and gasoline standards as 

soon as possible this winter and promulgate the final rule no later than December 31, 2013. 

NACAA is the organization of air pollution control agencies in 43 states, the District of 

Columbia, four territories and 116 metropolitan areas. The air quality professionals in our 

member agencies have vast experience dedicated to improving air quality in the United 

States. These comments are based upon that experience. The views expressed in this 

document do not necessarily represent the positions of every state and local air pollution 

control agency in the country. 

 In October 2011, NACAA released a report – Cleaner Cars, Cleaner Fuel, Cleaner 

Air: The Need for and Benefits of Tier 3 Vehicle and Fuel Regulations1

 – elaborating on our 

June 27, 2011 letter to you2, in which we recommended Tier 3 vehicle standards modeled 

after California’s Low-Emission Vehicle (LEV) III program and an average annual gasoline 

sulfur concentration of 10 parts per million (ppm) or lower. 

In our report, we show that the costs of cleaner vehicles and cleaner gasoline are 

extremely modest while the related public health and environmental benefits are substantial. 

In particular, we detail how reducing sulfur in gasoline would not only enable the use of 

improved emissions control technology on new cars and light trucks, but also result in an 

overnight reduction in emissions from the existing fleet on the order of approximately 

260,000 tons of nitrogen oxides (NOx), which is equivalent to taking 33 million cars off our 

nation’s roads in 2017 when the program begins. We know of no other single air pollution 

control strategy that can provide emissions reductions as significant and immediate as this. 

 

1 See NACAA’s report, “Cleaner Cars, Cleaner Fuel, Cleaner Air: The Need for and Benefits of Tier 3 Vehicle

and Fuel Regulations” (October 31, 2011), available at 

http://www.4cleanair.org/documents/NACAATier3VehandFuelReport-EMBARGOED-Oct2011.pdf. 

2 See NACAA letter to EPA Administrator Lisa P. Jackson (June 27, 2011), available at 

http://www.4cleanair.org/Documents/Tier3NACAALettertoEPAFinal062711.pdf. 
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Further, the additional cost to consumers of the cleaner gasoline would be less than a penny a 

gallon, and the additional cost of a cleaner Tier 3 vehicle would be similarly low, at about $150, on average. 

By 2030, the Tier 3 program would result in reductions in onroad mobile source emissions of NOx, volatile 

organic compounds and carbon monoxide of about 29, 26 and 38 percent, respectively. 

There would also be substantial health and welfare benefits associated with the emissions 

reductions to be achieved from Tier 3 vehicles and gasoline. As an example, the expected NOx reductions 

would lead to reduced levels of ambient particulate matter (PM) that would translate into more than 400 

avoided premature deaths and 52,000 avoided lost workdays each year. The benefits of the ozone 

reductions to occur from Tier 3 vehicles and gasoline would lead to additional health protection. According 

to a study by Navigant Economics3, the emissions reductions to be achieved from the Tier 3 program would 

translate into health benefits with an annual estimated value of $5 billion to $6 billion by 2020 and between 

$10 billion and $11 billion by 2030. 

Although motor vehicle emissions have been dramatically reduced over the past 40 years, air 

pollution in the U.S., as well as the associated adverse health impacts, remains a serious and widespread 

problem. More than 125 million people still live in areas that exceed at least one of the health-based 

National Ambient Air Quality Standards (NAAQS), with 120 million residing where ozone levels exceed that 

federal standard. 

Reducing emissions that cause air pollution is a zero-sum game. Missed emissions reduction 

opportunities from one source category means reductions will need to come from another. If our nation

foregoes, or dilutes, Tier 3 vehicle and fuel standards, states and localities will have no choice but to turn to 

other, more expensive, less cost-effective measures – for example, placing additional controls on stationary 

sources and small “mom and pop” businesses and instituting transportation control measures – to garner

the emissions reductions needed to attain and maintain clean air goals. Further, achieving emissions 

reductions of the magnitude that will result from Tier 3 could be extremely difficult in areas where there may 

not be sufficient sources to control or where state and local regulation of certain sources is politically 

unacceptable. 

Further, the Tier 3 program would promote innovation in the automotive sector and create jobs in 

the refining industry. Navigant Economics has estimated that implementation of the Tier 3 program would 

result in the creation of 5,300 permanent jobs related to operating and maintaining new refining equipment 

and over 24,000 new jobs over a three-year period related to installing equipment at refineries. 

As state and local air agencies face the challenge of attaining the health-based NAAQS for ozone, 

PM, nitrogen dioxide and sulfur dioxide, and continue to wrestle with ubiquitous toxic air pollution, an 

effective program to tackle emissions from cars and light trucks – which are key contributors to all of these 

problems – is critical. NACAA, therefore, encourages EPA take full advantage of the opportunity to 

establish a meaningful and effective Tier 3 program to take effect in 2017, including vehicle emissions

standards modeled after California’s LEV III program and an average annual gasoline sulfur concentration 

of 10 ppm or lower, to help states and localities meet their clean air obligations. 

 

3 See Navigant Economics study, “Economic Analysis of the Implications of Implementing EPA’s Tier 3 Rules” (June 14, 2012), 

available at 

http://www.naviganteconomics.com/docs/061212%20Economic%20Analysis%20of%20the%20Implications%20of%20Tier%203

%20Sulfur%20Reduction%20Final_embargoed%20copy.pdf. 
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Toward this end, we request that you now release for public comment the proposed Tier 3 

rulemaking to allow all interested stakeholders to weigh in with their perspectives, and issue a final

rulemaking by no later than December 31, 2013. 

Sincerely, 

 

Barry R. Wallerstein Nancy L. Seidman 

 NACAA Co-President and Co-Chair, NACAA Mobile 

 Co-Chair, NACAA Mobile Sources and Fuels Committee 

 Sources and Fuels Committee 

cc: Robert Perciasepe, EPA Deputy Administrator 

 Gina McCarthy, EPA Assistant Administrator, Office of for Air and Radiation