1 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 A ssociation of Clean Air Agencies (NACAA) to urge you to propose the Tier 3 vehicle em issions and gasoline standards as soon as possible this winter and promulgate the fin al 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 are as. The air quality professionals in our member agencies have vast experience dedicated to i mproving air quality in the United States. These comments are based upon that experienc e. 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 Regulations 1 – elaborating on our June 27, 2011 letter to you 2 , in which we recommended Tier 3 vehicle standards m odeled after California’s Low-Emission Vehicle (LEV) III p rogram 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 ve hicles and cleaner gasoline are extremely modest while the related public health an d environmental benefits are substantial. In particular, we detail how reducing sulfur in gas oline would not only enable the use of improved emissions control technology on new cars a nd 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 (NO x ), which is equivalent to taking 33 million cars of f our nation’s roads in 2017 when the program begins. We know of no other single air pollution control strategy that can provide emissions reducti ons as significant and immediate as this.

1 See NACAA’s report, “Cleaner Cars, Cleaner Fuel, Clean er Air: The Need for and Benefits of Tier 3 Vehicle and Fuel Regulations” (October 31, 2011), available at http://www.4cleanair.org/documents/NACAATier3Vehand FuelReport-EMBARGOED-Oct2011.pdf

. 2 See NACAA letter to EPA Administrator Lisa P. Jackson ( June 27, 2011), available at http://www.4cleanair.org/Documents/Tier3NACAALetter toEPAFinal062711.pdf

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Further, the additional cost to consumers of the cle aner 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 a verage. By 2030, the Tier 3 program would result in reductio ns in onroad mobile source emissions of NO x , volatile organic compounds and carbon monoxide of about 29, 26 and 38 percent, respectively.

There would also be substantial health and welfare b enefits associated with the emissions reductions to be achieved from Tier 3 vehicles and g asoline. As an example, the expected NO x reductions would lead to reduced levels of ambient particulate matter (PM) that would translate into more than 40 0 avoided premature deaths and 52,000 avoided lost wo rkdays each year. The benefits of the ozone reductions to occur from Tier 3 vehicles and gasolin e would lead to additional health protection. Acco rding to a study by Navigant Economics 3 , the emissions reductions to be achieved from the Tier 3 program would

translate into health benefits with an annual estim ated value of $5 billion to $6 billion by 2020 and between $10 billion and $11 billion by 2030.

Although motor vehicle emissions have been dramatic ally reduced over the past 40 years, air pollution in the U.S., as well as the associated ad verse health impacts, remains a serious and widespr ead problem. More than 125 million people still live i n areas that exceed at least one of the health-base d National Ambient Air Quality Standards (NAAQS), wit h 120 million residing where ozone levels exceed th at

federal standard.

Reducing emissions that cause air pollution is a ze ro-sum game. Missed emissions reduction opportunities from one source category means reduct ions will need to come from another. If our nation foregoes, or dilutes, Tier 3 vehicle and fuel standa rds, states and localities will have no choice but to turn to other, more expensive, less cost-effective measures – for example, placing additional controls on stat ionary sources and small “mom and pop” businesses and inst ituting transportation control measures – to garner

the emissions reductions needed to attain and maint ain clean air goals. Further, achieving emissions reductions of the magnitude that will result from Ti er 3 could be extremely difficult in areas where th ere may not be sufficient sources to control or where state and local regulation of certain sources is politic ally unacceptable.

Further, the Tier 3 program would promote innovation in the automotive sector and create jobs in the refining industry. Navigant Economics has esti mated that implementation of the Tier 3 program woul d result in the creation of 5,300 permanent jobs rela ted to operating and maintaining new refining equip ment and over 24,000 new jobs over a three-year period r elated 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 contin ue to wrestle with ubiquitous toxic air pollution, an effective program to tackle emissions from cars and light trucks – which are key contributors to all o f these problems – is critical. NACAA, therefore, encourag es 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 progra m and an average annual gasoline sulfur concentrati on of 10 ppm or lower, to help states and localities m eet their clean air obligations.

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

available at http://www.naviganteconomics.com/docs/061212%20Econ omic%20Analysis%20of%20the%20Implications%20of%20Ti er%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 Committ ee Sources and Fuels Committee

cc: Robert Perciasepe, EPA Deputy Administrator Gina McCarthy, EPA Assistant Administrator, Office of for Air and Radiation