Comments on U.S. Environmental Protection Agency Proposed Rule, "Control of Air Pollution from Motor Vehicles: Tier 3 Motor Vehicle Emission and Fuel Standards," RIN 2060-AQ86

As EPA granted the waiver for California's program in December 2012, the costs and benefits for that program should be included in the baseline of the RIA analysis for Tier 3.  California's air pollutant standards have long been different than other parts of the country so it makes both analytic and policy sense to consider the incremental impacts, costs and benefits of the rule with and without the California program.  It is requested that EPA breakdown and present these incremental impacts for the scenarios laid out in the matrix below.   

A clarifying question would be whether the seven other states that adopted California's standard would also be included in the baseline for Tier 3.  Presumably they should be included in the baseline if they adopted California's program; however, would the seven other states be preempted by the federal program if Tier 3 goes into effect?   


                               Fuel Sulfur Only
                       Fuel Sulfur and Vehicle Controls
                           Tier 3 (not counting CA)
                                       A
                                       B
                            Tier 3 (entire country)
                                       C
                                       D

A  -  This breakout will incorporate the impacts of the California program in the Tier 3 baseline so it separates the costs and benefits of the California program from the Tier 3 program.  The costs and benefits of the Tier 3 program will be estimated for all states outside of California and just for the fuel sulfur portion of Tier 3, not the vehicle controls portion of Tier 3.  

B -  This breakout will incorporate the impacts of the California program in the Tier 3 baseline so it separates the costs and benefits of the California program from the Tier 3 program.  The costs and benefits of the Tier 3 program will be estimated for all states outside of California covering both the fuel sulfur and vehicle controls portions of Tier 3.  

C  -  This breakout will incorporate the impacts of the California program in the Tier 3 cost and benefit analysis, although would only apply to the fuel sulfur portion of Tier 3 and not the vehicle controls portion of the program.  

D - This breakout will incorporate the impacts of the California program in the Tier 3 cost and benefit analysis and is what the agency has provide to date.  
