UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2000 TRAVERWOOD DRIVE

ANN ARBOR, MI  48105-2498

									     OFFICE OF

									AIR AND RADIATION

February 10, 2014

MEMORANDUM

SUBJECT:  	NGOs Meeting with Janet McCabe regarding Tier 3 Rule

FROM:	Robin Moran, Senior Policy Advisor

TO:  EPA Docket # EPA-HQ-OAR-2009-0472

This memo documents a meeting held on December 5, 2013, between EPA and
representatives of several non-governmental organizations, labor unions,
and emissions control manufacturing companies to discuss the Tier 3
vehicle and fuel standards.  The meeting attendees included the
following:

Name	Organization

Rob McCulloch	Blue Green Alliance

Paul Bugala	Calvert Investments

Tim Regan	Corning, Inc

Patricia Bruckbauer 	Creation Justice Ministries

Mark McLeod	Environmental Defense Fund

Mary Minette	Evangelical Lutheran Church in America

Dave Bushnell	JMD Associates on behalf of BASF

Bill Becker	National Association of Clean Air Agencies

Luke Tonachel	Natural Resources Defense Council

Jesse Prentice-Dunn	Sierra Club

Meghan Higgins	Union of Concerned Scientists

Roy Houseman	United Steelworkers

Jalonne White-Newsome	WE ACT for Environmental Justice



EPA participants included:

Janet McCabe, Acting Assistant Administrator for Air and Radiation

Bill Charmley, Director, Assessment and Standards Division (ASD), Office
of Transportation and Air Quality (OTAQ)

Robin Moran, Senior Policy Advisor, ASD/OTAQ

The discussion topics included these organizations’ support for the
Tier 3 program and its broad public health benefits. The groups also
urged the Agency to finalize the Tier 3 rule as soon as possible, so
that the air quality and health benefits could be achieved. The groups
delivered the attached letters in support of the standards.

************************************************************************
****

 

---------- Forwarded message ----------

From: David Butler <  HYPERLINK "mailto:dbutler@consumer.org" 
dbutler@consumer.org >

Date: Tue, Nov 5, 2013 at 3:51 PM

Subject: Consumers Union urges EPA to act quickly on Tier 3 rule

To: Shannon Baker-Branstetter <  HYPERLINK
"mailto:sbaker-branstetter@consumer.org" 
sbaker-branstetter@consumer.org >

News Release

Consumers Union

Policy and Advocacy Division of Consumer Reports

Tuesday, November 5, 2013

 

Consumers Union urges EPA to act quickly on Tier 3 rule

 WASHINGTON -- Consumers Union, the policy and advocacy division of
Consumer Reports, today wrote the Environmental Protection Agency (EPA)
to urge quick action to finalize the "Tier 3" rule to lower sulfur in
gasoline and reduce vehicle tailpipe emissions.  A variety of health,
environmental, and consumer groups are pressing the agency to take
action before the end-of-2013 deadline to ensure the rules are
implemented starting in 2017 as planned. 

 In a letter to EPA Administrator Gina McCarthy, CU policy counsel
Shannon Baker-Branstetter wrote, "Cleaner gasoline and vehicles are
within reach, but every year they are delayed, more Americans needlessly
suffer from preventable air pollution.  Exposure to air pollution from
vehicles is widespread, and reducing sulfur in gasoline and cutting
tailpipe emissions will provide tremendous benefits to public health. 
Living, working, or going to school near major roadways increases
exposure to ozone and particle pollution that worsens lung and heart
health and causes thousands of premature deaths every year."  

 CU is urging the EPA to finalize the rule as soon as possible, not
only to avoid delay of the rule’s health benefits, but also so that
Tier 3 implementation begins in 2017, so automakers can reduce
compliance costs by harmonizing technology selection and development for
the Tier 3 standards and Model Year 2017-2025 greenhouse gas and fuel
economy standards already in place.

 CU collected more than 31,000 signatures in support of the rule. See
below for the full text of the letter:

  

November 4, 2013

 

The Honorable Gina McCarthy

Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

Via:   HYPERLINK "mailto:mccarthy.gina@epa.gov" \t "_blank" 
mccarthy.gina@epa.gov 

 

Dear Administrator McCarthy:

 Consumers Union, the advocacy and policy division of Consumer Reports,
urges the Environmental Protection Agency to promptly finalize the
“Tier 3” rule to lower sulfur in gasoline and reduce vehicle
tailpipe emissions.  Consumers Union collected 31,068 signatures in
support of this rule (submitted as part of our comments to the proposed
rule), and we are eager to see the final rule implemented as quickly as
possible.  Cleaner gasoline and vehicles are within reach, but every
year they are delayed, more Americans needlessly suffer from preventable
air pollution.

 Exposure to air pollution from vehicles is widespread, and reducing
sulfur in gasoline and cutting tailpipe emissions will provide
tremendous benefits to public health.  Over 130 million Americans (more
than 40% of the country) breathe unhealthy air, and a major source of
this pollution is passenger and heavy-duty vehicles.   On average,
Americans spend over an hour traveling along roads every day.   Time
spent in the car (especially in congested traffic) increases pollutant
exposure, and cars provide little protection against gas-phase
pollutants (especially VOCs).   Living, working, or going to school
near major roadways increases exposure to ozone and particle pollution
that worsens lung and heart health and causes thousands of premature
deaths every year.  

 Time is also of the essence because addressing sulfur levels in
gasoline and vehicles together as a “system” further improves the
cost-effectiveness of reducing emissions, and it allows automakers to
maximize efficiencies in emission reduction technologies.  Consumers
Union urges the EPA to finalize this rule as soon as possible, not only
to avoid delay of the rule’s health benefits, but also so that Tier 3
implementation begins in 2017.  Thereby, automakers can reduce
compliance costs by harmonizing technology selection and development for
the Tier 3 standards and Model Year 2017-2025 greenhouse gas and fuel
economy standards. 

 Although the proposed rule has clearly identified costs, pollution has
costs of much greater magnitude.  According to analyses by the EPA and
by independent economists, when the standards are fully implemented by
2025, they will likely add less than $150 to the cost of a vehicle and
less than 1 cent per gallon to gasoline costs.  According to EPA’s
own impact analysis, average costs of hospital care due to
pollution-related illness alone range from $400 for an emergency room
visit to $12,000 for a hospital admission for asthma and from $11,000 to
$30,000 to treat other respiratory and heart conditions.  Such
admissions can be especially expensive or fraught with complications for
the elderly or those with other health problems.  By 2030, the annual
health benefits of Tier 3 would be between $8 and $23 billion (double to
seven times the costs).  All polluting sectors should contribute their
fair share to reducing pollution, and Tier 3 standards are one of the
more economical and cost-effective ways to get meaningful reductions to
help make air safe to breathe.  

 It would be “pennywise, tons foolish” to save a cent on gasoline,
only to have to pay even more with our health as a result of additional
tons of pollution.  To put the cost in perspective, over the last four
years, gasoline prices fluctuated over $2.25 dollars per gallon, with
weekly increases of 10 cents happening with regularity.  

 In summary, this common-sense rule can deliver enormous public health
benefits, and can be implemented at an affordable cost.  We urge the
EPA to finalize the rule before the end of this year, so it can apply to
2017 models and sync with 2017-2025 greenhouse gas and fuel economy
standards.  We thank you for your attention to this important consumer
and public health issue.

 Sincerely,

Shannon
Baker-Branstetter                           
     

Policy Counsel, Consumers Union

 

December 5, 2013

The Honorable Gina McCarthy

Administrator, U.S. Environmental Protection Agency

William Jefferson Clinton Building Mail Code 1101A

1200 Pennsylvania Ave., N.W.

Washington, DC  20460

Dear Administrator McCarthy:

As representatives of our nation’s diverse faith communities, we write
to express our gratitude to the Environmental Protection Agency (EPA)
for proposing strong “Tier 3” clean vehicle and fuel standards,
which will reduce smog-forming pollution, make our air healthier to
breathe, and save lives. We also write to strongly urge you to finalize
these critical standards expeditiously. The longer the standards are
delayed, the longer the health of God’s creation, as well as the
health of our most vulnerable citizens – those in low-income
communities, our elderly, and our children – must wait and suffer the
life-threatening consequences of air that is dangerous to breathe.

As people of faith, we are taught through our sacred texts to love our
neighbors and to serve the least among us. Our shared values as a
society demand that our air be safe to breathe for everyone. The EPA has
been charged with ensuring that all people are protected from
significant risks to human health and the environment where they live,
learn, and work. In order to fulfill that mission, these standards must
be finalized as soon as possible. 

It is also important to act quickly because of the increasing number of
high heat days due to climate change. As temperatures rise, limiting
ozone-forming pollution becomes even more urgent. President Obama has
highlighted the impacts that climate change is already having on
communities across the nation. We must seek out every available option
for limiting pollution that exacerbates the impact of climate change.

The health benefits associated with the Tier 3 proposal are clear. By
reducing the sulfur content of gasoline and tailpipe pollution, 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.

These benefits will only be achieved once the standard is finalized and
implemented. As representatives of diverse faith communities across the
U.S. concerned with the health of our citizens and our environment, we
urge you to finalize Tier 3 standards as soon as possible and prevent
any further delays of these critical safeguards.

Faithfully,

Carmelite NGO

Coalition on the Environment and Jewish Life

Columban Center for Advocacy and Outreach

Creation Justice Ministries

Evangelical Environmental Network

Evangelical Lutheran Church in America

Friends Committee on National Legislation

GreenFaith

Interfaith Power & Light

Jewish Council for Public Affairs

Maryknoll Office For Global Concerns

Presbyterian Church (U.S.A)

Religious Action Center of Reform Judaism

Sisters of Mercy of the Americas, Institute Justice Team

