Here's one posted just yesterday that caught our eye. It was submitted by the emission control industry: http://1.usa.gov/15mLykP
In a very analytical manner, the Manufacturers of Emission Controls Association (MECA) rebuts the bogus arguments made by the oil industry about the value of lower-sulfur gasoline.
Here are some excerpts of the comments by the Manufacturers of Emission Controls Association:
"MECA is unaware of any cold-start emission control technology that is not impacted by fuel sulfur levels since ultimately the cold-start emission performance is tied to the precious metal-containing three-way catalyst performance. API's and AFPM's premise that cold-start emissions can be zeroed out by a sulfur insensitive technology has no basis in fact."
"As MECA and the auto industry have both pointed out in public comments, a 10 ppm sulfur average gasoline standard is an important enabler for allowing lean GDI engines to meet proposed Tier 3 emission limits and deliver cost effective CO2 reductions."
"MECA believes that a number of factors will allow projected Tier 3 compliance costs to be lower than EPA estimates contained in their Tier 3 Draft Regulatory Impact Analysis."
[In its Comments, MECA Also Makes a Strong Pitch for EPA to Set a Strong Standard to Reduce Fine Particle Soot]
"Finally, MECA would like to reiterate our strong support for EPA harmonizing with ARB's LEV III 1 mg/mile FTP PM standard. In July 2013 MECA released a new report on ultrafine particulate (UFP) emissions entitled, "Ultrafine Particulate Matter and the Benefits of Reducing Particle Numbers in the United States." The report summarizes the current understanding of the potential adverse health impacts of UFPs; outlines the various control strategies and technologies that can be used to meet current and upcoming U.S. EPA and California ARB emission standards (including LEV III and EPA's proposed Tier 3 standards); and documents the success story of using diesel particulate filters (DPFs) to meet and exceed U.S. and European emission standards. Notably, the report highlights a correlation between particle number (PN) and PM that can be used in conjunction with PM-based health data to estimate the health benefits of reducing particle number emissions, and indicates that a PN measurement may offer a more robust unit for determining compliance at very low PM mass levels. In addition, the report quantifies the health benefits of the additional emission reductions that are realized when DPFs or gasoline particulate filters (GPFs) are used compared to only engine-based strategies. With respect to light-duty vehicles, the report echoes many of the comments made by MECA with respect to the expected dominant use of GDI engines in the U.S. because of their improved fuel economy versus port injected gasoline engines, the higher particle mass and number emissions of GDI engines relative to port injected engines, and the recommendation that EPA follow California's lead in including a 1 mg/mile PM FTP limit in its final Tier 3 standards. Gasoline particulate filters are a cost effective emission control technology option for meeting a 1 mg/mile FTP PM standard, and GPFs are expected to be introduced in Europe in the near future on some GDI models to meet the Euro 6 GDI PN limit of 6 X 1011 particles/km."
"In summary, there are significant opportunities to reduce both criteria pollutant and greenhouse gas emissions from the transportation sector through the design of fuel-efficient powertrains that include advanced exhaust emission controls for meeting even the most stringent criteria pollutant standards that are included in EPA's proposed Tier 3 program. MECA believes that advanced emission control systems have a critically important role in future policies that aim to reduce mobile source criteria pollutant and greenhouse gas emissions. MECA strongly supports EPA's Tier 3 emissions and fuel standards proposal, believes that Tier 3 compliance costs will be lower than the EPA estimates contained in their Tier 3 proposal, asks EPA to harmonize with ARB's 1 mg/mile FTP PM standard, and urges EPA to finalize these proposals by the end of this year."