EPA’s Tier 3 Proposal Based on Flawed Analysis, Will Raise Fuel Costs

June 28, 2013

WASHINGTON – The American Fuel & Petrochemical Manufacturers (AFPM) will submit comments on the Environmental Protection Agency’s (EPA) Proposed Rulemaking on Tier 3 Motor Vehicle Emission and Fuel Standards. AFPM is joined by the American Petroleum Institute (API) in opposing a discretionary rulemaking to reduce the sulfur content in gasoline, for which EPA has failed to provide adequate scientific justification, technical need, or cost effectiveness.


If finalized, it would decrease the gasoline sulfur average from 30 parts per million (ppm) to 10ppm, but have negligible environmental benefit with respect to vehicle emissions or improvements in air quality.


“Not only is EPA’s Tier 3 proposal not justified, it is illogical, as well. It will force refiners to invest in energy intensive sulfur reduction equipment that will actually increase greenhouse gas emissions,” said AFPM President Charles T. Drevna. “The new rule could threaten the existence of some refineries while imposing a high-cost, minimal benefit regulatory requirement on America’s existing heavily regulated fuel supply.”


Refiners have already dramatically reduced sulfur levels in gasoline by 90 percent since 2004. EPA's own data indicates fuel emissions will continue to decrease without Tier 3.  As written, the rule could lead to domestic fuel supply reductions and higher petroleum product imports while potentially increasing consumer costs and reducing U.S. energy security.


“We understand that the general public isn’t likely to be concerned about increased regulations and costs to refiners, but Tier 3 will ultimately be an additional economic burden to consumers at the pump,” Drevna said. 

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