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Rich Kassel’s Blog

EPA Tier 3 will cut emissions, improve human health, and put money in people's pockets

Rich Kassel

Posted January 17, 2012

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Last week, I wrote about the need to move Tier 3 forward, which followed up on a letter that the leaders of NRDC, the Environmental Defense Fund, the Sierra Club, and the Union of Concerned Scientists sent to EPA Administrator Lisa Jackson earlier in the week. 

Predictably, over the weekend, I read skeptical remarks in the trade press from the oil industry and their friends in the U.S. Senate.

So, today, I’m going to hit some of the major facts to set the record straight.

Fact No. 1:  Our nation’s air is still too polluted for too many people.

More than 125 million people still breathe air that is too polluted for their health, according to the Environmental Protection Agency.  They live in areas that don’t meet EPA’s health-based standards for either ozone, particulate matter, or both.

People who live in these areas face higher risk of increased asthma attacks, bronchitis, cancer, heart disease, and premature deaths.

Fact No. 2:  Cleaner cars are a cost-effective way to help states and communities get cleaner air.

Summertime smog (or ground-level ozone) is created when nitrogen oxides and volatile organic compounds (or hydrocarbons) combine in sunlight.  Cars and other light-duty vehicles are a major source of these gases. 

In fact, these vehicles contribute roughly half of the nitrogen oxides generated on our highways, and more than ten times as much of volatile organic compounds as all of our heavy-duty trucks and buses.

As Bill Becker, the long-time executive director of the National Association of Clean Air Agencies (NACAA), explains it, “There is no rule that will provide states and localities with as significant and as expeditious reductions in NOx as the Tier 3 regulations.”

His organization did a study a few months ago, which looked at the key question of cost-effectiveness.  In other words, they looked at all of the likely ways that states could get cleaner air and achieve the EPA health-based standards.  They looked at new strategies and solutions for power plants, small gas boilers, municipal waste incineration, and other strategies that are on the table.

Their key finding:  a national program to reduce nitrogen oxides from cars and other light-duty vehicles would deliver nitrogen oxides reductions at a cost of approximately $3,300 per ton.  Other strategies went all the way up to $300,000 per ton.

Fact No. 3:  Cleaner cars won’t significantly add to the costs of driving.

The average new car costs almost $30,000 today.  The estimated cost of the improved catalysts that will meet Tier 3?  Less than $150 per vehicle.  That’s ½ of one percent.

In other words, it is hard to imagine that anybody will skip buying a new car because it comes with a Tier 3 catalyst. 

Aahhh, but six U.S. Senators, all from oil states—Senators James M. Inhofe (R-Okla.), Lisa Murkowski (R-Alaska), David Vitter (R-La.), John Barrasso (R-Wyo.), Mary L. Landrieu (D-La.), and Mark Begich (D-Alaska)—say that Tier 3 will add to the cost of driving by driving up the cost of gasoline.  In a letter they sent to the White House last week, they pointed out that the average cost of gasoline is currently $3.38. 

They also cite a study bought by the oil industry, which estimates the potential price increase as 12 – 25 cents per gallon.  What don’t they cite?  Most of that estimated price increase is due to a change in something called the “Reid Vapor Pressure” of gasoline.

Guess what? 

According to every source I can find, EPA isn’t planning to change to the “Reid Vapor Pressure” in its Tier 3 proposal.  They are planning to reduce sulfur levels, but Reid Vapor Pressure changes are not anticipated.

What’s the cost estimate for reducing sulfur in gasoline to 10 ppm?  Less than a penny per gallon, according to the expert refinery consulting firm MathPro, which did a study that looked at the sulfur reduction costs specifically.

Listen, I’m sensitive to cost increases.  I’ve got two kids, a mortgage, and a very old car that doesn’t get replaced because I’m part of the 99% who delay car purchases when things seem a bit tight. 

But a penny a gallon?  If gas costs $3.38/gallon, that is an increase of 3/10ths of one percent of the current cost of gasoline.

I can take a ten minute drive past a half-dozen gas stations stretched along a single road, and see far bigger price differentials in the market right now. 

Plus, according to a very impressive study by CNT, the average cost of owning, fueling, and maintaining a car today is more than $7,000 per year. 

Adding ½ of one percent to the cost of buying a car and 3/10 of one percent to the cost of fuel is not going to significantly change that whopper of a hit to most family budgets.  And, I think that adding ½ of one percent to the cost of buying a car and 3/10 of one percent to the cost of fuel is a reasonable cost to pay for significantly cleaner cars, cleaner air, and the health benefits that go along with those cleaner cars.

The bottom line: 

If EPA implements a Tier 3 program that harmonizes its standards with the standards that soon exist in California and other states that follow California’s standards, we could see nitrogen oxides reduced by 29 percent, hydrocarbons by 26 percent, and carbon monoxide by 38 percent according to the NACAA study.  Plus, particulate matter would be reduced, which should ease the concerns of people who wonder whether their health concerns about old, dirty diesel school buses in their communities should extend to the new, fuel-efficient diesel cars that are entering the market.

In other words, the costs would be reasonable, and the benefits would be great.

Nobody—neither the EPA, nor the White House, nor consumers and drivers—should fall for the oil industry’s scare tactics.

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