Emissions Control Technology Association
325 7th Street NW, Suite 600 Washington, DC 20004
Tel: 202-661-4150 Fax: 202-661-4165Opposition to Tier 3 Rider in Draft House Interior Appropriations Bill
Section 451 of the draft House Interior Appropriations bill (see page 138 of draft1) prevents EPA from using any funds from the FY14 appropriation to finalize, implement, administer, or enforce the Tier 3 rule or any other successor rule that would require a reduction in the sulfur content of gasoline.
2 Schink, George R. and Hal Singer. 2012. Economic Analysis of the Implications of Implementing EPA’s Tier 3
Rules. Online at http://naviganteconomics.com/docs/061212%20Economic%20Analysis%20of%20the%20Implications%20of%20Tier%203%20Sulfur%20Reduction%20Final_embargoed%20copy.pdf
Reasons to Oppose
Tier 3 is supported by a large coalition from the auto industry, the parts industry, the unions, the states, the faith-based groups, the science-based NGOs, the environmental NGOs, the health groups, and the consumer groups. More than 300,000 comments in favor of EPA’s Tier 3 proposal have been filed. In addition to support, the comments urged EPA to adopt Tier 3 this year. Given this broad base of support, the amendment should be opposed for the following reasons: • Creates Jobs: Navigant study2 shows that Tier 3 will create of 24,500 jobs over three years to construct the new desulfurization facilities and another 5,300 permanent jobs to operate and maintain these facilities.
• Generates Economic Growth: Navigant study concludes that Tier 3 will generate $2.6 billion in economic value added for three years, $1.5 billion in increased employment compensation, and $0.6 billion in tax revenue for Federal, State, and local governments.
• Saves Lives: EPA estimates that by the year 2030, Tier 3 will annually prevent 820 to 2,400 premature deaths, 3,200 hospital admissions and asthma related emergency room visits, 22,000 asthma exacerbations, 23,000 respiratory symptoms in children, and 1.8 million lost school and days.
• Cleans the Air: Currently, 58 million American breathe unhealthy air due to pollution from motor vehicles. Tier 3 addresses this problem by reducing emissions of ozone precursors (e.g., NOx) from each vehicle by 80% and particulate matter by 70%.
• Benefits Far Exceed Costs: EPA estimates that Tier 3 will generate up to 6.5 times more benefit than cost. By 2030, the cost of Tier 3 will be $3.4 billion compared to annualized health benefits of $8 billion to $23 billion.
• Doesn’t Increase Gas Prices: Navigant study shows that historically there has been no connection between the price of gasoline and emission control regulations under Tier 2, the current tailpipe regulation that has been enforced since 2004.
• Conforms to Global Fuel Standards: Tier 3 requires a reduction in the sulfur content of gasoline from 30ppm to 10ppm, the fuel standard in Europe, Japan, Korea, and soon China.
• Reduces Compliance Costs for the States: States that are not in attainment with ozone standards must find ways to reduce NOx, an ozone precursor. Tier 3 is the most efficient means for achieving such reductions. The National Association of Clean Air Agencies3 found that the cost of reducing a ton of NOx under Tier 3 is $3,300 per ton versus $39,700 to $79,700 for power plants.
• Harmonizes Tailpipe Standards: Today, motor vehicles in California must conform to tighter emission standards than the rest of the country. This requires the auto industry to sell vehicles in California that have different emission systems, creating an inefficient production cycle for auto and auto parts industries. Tier 3 will eliminate this inefficiency by adopting a national standard comparable to LEV III.
• Minimizes Compliance Cost: EPA estimates that Tier 3 will increase the average cost of refining gasoline by 0.89 cents per gallon. Tier 3 reduces the cost of compliance by allowing refiners to average, bank, and trade emissions credits.
3 National Association of Clean Air Agencies, "Clean er Cars, Cleaner Fuel, Cleaner Air: The Need For and Benefits of Tier 3 Vehicles and Fuel Regulations," October 2011, 2, available at: http://www.4cleanair.org/Documents/NACAATier3VehandFuelReportFINALOct2011.pdf
President, Emissions Control Technology Association