Here are the official comments submitted to EPA by the Sierra Club, Clean Air Watch and the Respiratory Health Association:
Environmental Protection Agency
Air and Radiation Docket and Information Center
Mail Code 2822T
1200 Pennsylvania Avenue NW
Washington, DC 20460
July 1, 2012
Comments submitted on behalf of
Sierra Club * Clean Air Watch * Respiratory Health Association
RE: Docket ID Nos. EPA-HQ-OAR-2011-0135
Control of Air Pollution From Motor Vehicles: Tier 3 Motor Vehicle Emission and Fuel Standards
On behalf of our millions of members and supporters nationwide, Sierra Club, Clean Air Watch and the Respiratory Health Association applaud the Environmental Protection Agency for proposing strong Tier 3 cleaner tailpipe standards that will significantly reduce health-threatening pollution from our cars and trucks.
Over the past decades we have made substantial progress in cleaning our air, in part by transitioning from dirty fossil fuels to clean renewable energy. Still, today more than four in ten Americans live where the air is sometimes unsafe to breathe.1 This may be an underestimation, as EPA must update its ozone standards to meet current science. Air pollution causes a host of serious life-threatening health problems, including asthma, heart disease, cancer, neurological problems, and more.
1American Lung Association. State of the Air 2013. Accessed June 2012. http://www.stateoftheair.org/2013/key-findings/
Much of this health-threatening pollution comes from our passenger cars and trucks, which remain the second largest source of smog-forming pollution. These vehicles emit more than half of all carbon monoxide pollution and contribute significantly to deadly particulate matter and other air pollution that causes asthma and other respiratory diseases.
The proposed Tier 3 standards will require refiners to reduce the sulfur content of gasoline to an average of 10 parts per million and automakers to apply advanced pollution control technology to new vehicles. These health-protecting standards will significantly reduce smog-forming pollution, saving lives, preventing asthma attacks and giving Americans cleaner air to breathe.
We urge the EPA to move forward with these standards as quickly as possible, finalizing them no later than December 31, 2013.
Tier 3 standards will provide substantial pollution reduction, health and economic benefits.
By requiring refiners to produce lower sulfur gasoline and by requiring automakers to use advanced pollution control technology, Tier 3 standards will produce substantial reductions in health-threatening pollution. Importantly, reducing the sulfur content of gasoline from 30 parts per million (ppm) to 10ppm will have immediate health benefits when new standards go into effect in 2017. Cleaner burning gasoline will reduce emissions of nitrogen oxides from existing cars by more than 260,000 tons – the equivalent of taking 33 million cars off the road.
According to a study by the National Association of Clean Air Agencies, cleaner tailpipe standards have the potential to cut emissions of nitrogen oxides, carbon monoxide, and volatile organic compounds from passenger vehicles by 29, 38 and 26 percent respectively by 2030.2
2 National Association of Clean Air Agencies. Cleaner Cars, Cleaner Fuel, Cleaner Air: The Need for and Benefits of Tier 3 Vehicle and Fuel Regulations. October, 2011. http://www.4cleanair.org/documents/NACAATier3VehandFuelReport-EMBARGOED-Oct2011.pdf
Health Benefits Everyone knows it is dangerous to stand in front of a moving car. Increasingly, we understand that it is quite dangerous standing behind them. People living near major roads and highways are disproportionately affected by tailpipe pollution, suffering from higher rates of premature death and life-threatening ailments. Moreover, recent studies have linked living near roadways to increased risk of asthma in children.
The proposed Tier 3 standards will provide very real health benefits. According to the proposal, by reducing tailpipe emissions, the proposed standards would prevent up to 2,400 premature deaths, 3,200 hospital visits and 22,000 asthma attacks annually by 2030. Further, the standards would prevent 1.8 million lost school and workdays.
The health benefits discussed above will lead to substantial economic benefits, as well. According to EPA, the annual monetized value of health benefits could be as large as $23 billion dollars.
Further, the new standards will bring more American jobs as parts suppliers develop and build new technology and refiners and automakers install it. According to a study by Navigant Economics, implementation of cleaner tailpipe standards would create nearly 5,300 permanent jobs in the operation and maintenance of new refining equipment, as well as more than 24,000 new jobs over a three-year period as refineries install new equipment.3
3 Navigant Economics. Economic Analysis of the Implications of Implementing EPA’s Tier 3 Rules. June 2012. http://www.ectausa.com/061212-Economic-Analysis-of-the-Implications-of-Tier-3-Sulfur-Reduction-Final_embargoed.pdf
Tier 3 Standards complement existing vehicle standards
Finalizing the proposed Tier 3 standards by December 31, 2013 is critical to ensuring that existing vehicle standards are fully implemented. Automakers are innovating and employing advanced vehicle technologies needed to meet the historic light-duty vehicle efficiency standards that will increase fleet efficiency to an average of 54.5 miles per gallon by 2025. In order to fully utilize advanced vehicle technologies, automakers need lower-sulfur gasoline.
For lower-sulfur gasoline to reach the market in 2017, in time to synchronize with the 2017-2025 light-duty vehicle efficiency standards, the proposed Tier 3 standards must be finalized no later than December 31, 2013.
Recommended changes to proposed Tier 3 standards
Per-Gallon Sulfur Caps
It is important to note that EPA is proposing an average sulfur standard of 10 ppm. However, the actual sulfur content of fuel can vary substantially, based on variations in refinery operations and contamination from gasoline being transported through pipelines to its final destination. Automakers must then design vehicles to function with higher-sulfur gasoline. In order to give certainty to automakers designing vehicles and to ensure emissions reductions, setting caps on per-gallon sulfur content is critical.
Currently, sulfur is capped at 80 ppm per gallon at the refinery gate and 95 ppm per-gallon downstream. In this proposal, EPA is proposing two options: keep the per-gallon caps the same, or lower them to 50 ppm at the refinery gate and 65 ppm downstream in 2020, to allow small refinery provisions to take effect.
We urge EPA, as it lowers the average sulfur standard from 30 ppm to 10 ppm, to also lower the per-gallon sulfur caps to at least 50 ppm at the refinery gate and 65 ppm downstream. Lowering the per-gallon caps will allow automakers to employ additional advanced vehicle technologies that can increase vehicle efficiency and lower emissions, while still allowing compliance flexibility for refiners.
Fine particulate matter is recognized as extremely hazardous to health, causing lung disease and contributing to premature death. The proposed standards seek to reduce emissions of particulate matter by proposing a FTP PM certification standard of 3 mg/mi for all model years. The proposed SFTP PM certification standard is much higher, either 10 mg/mi or 20 mg/mi, depending on the vehicle.
It is important to note that as part of their Low Emission Vehicle III (LEV 3) standards, the California Air Resources Board is proposing lower certification standards and will be phasing in a 1 mg/mi FTP standard beginning in MY 2025.
We urge EPA to coordinate with CARB to determine how to measure ultra-fine particles and to consider harmonizing PM standards with those set by CARB in LEV 3.
As EPA notes in the proposed standards, in-use gasoline has changed significantly in previous decades. With the implementation of the Renewable Fuel Standard, most gasoline sold contains up to 10% ethanol by volume (E10). In the proposed rule, EPA proposes moving from Indolene to an E15 test fuel. Additionally, EPA is proposing to allow manufacturers to request approval for alternative certification fuel, such as E30.
However, ethanol blends higher than E10 are not widely available in the market today. Though EPA recently increased the "blend wall" to E15, that fuel has not been widely adopted yet, and significant concerns have been raised about the effect of higher ethanol blends on older vehicles and small engines. By proposing E15 as a test fuel and blends such as E30 as an alternative test fuel, EPA is moving ahead of what is happening in the marketplace.
Instead of proposing E15 as a certification fuel, EPA should instead adopt a certification fuel that is closer to real-world conditions, such as E10. It is critical that this test fuel requirement be harmonized with test fuel requirements for other vehicle standards, particularly light-duty greenhouse gas and fuel economy standards, as increased ethanol blends affect fuel economy. Though test fuel conditions may need to be updated in the future, EPA should strive to match real-world fuel conditions.
Everyone from automakers and auto workers to public health agencies and the American public recognize the connection between cleaner cars, jobs, public health and a stronger economy. The only ones opposed to these standards are oil companies that oppose anything that would require them to clean up their act.
While the American Petroleum Institute’s scare tactics claim that these standards would cause gas prices to skyrocket, independent studies have shown that these standards can be achievedfor less than a penny a gallon. This is a clear case where we can clean our air, protect our public health and create jobs by reducing pollution from our cars and trucks.
The proposed Tier 3 standards will provide very real benefits - reducing health-threatening pollution, saving lives, and creating jobs. Again, on behalf of our millions of members and supporters, we applaud the EPA for proposing strong Tier 3 cleaner tailpipe standards and strongly urge the EPA to finalize these standards before December 31, 2013.