Global Automakers

Written Testimony of Global Automakers’ President and CEO Michael J, Stanton at EPA Public Hearing Regarding Proposed Tier 3 Standards

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April 24, 2013


PHILADELPHIA, PA, APRIL 24, 2013 – Michael J. Stanton, president and CEO of the Association of Global Automakers (Global Automakers) testified today at the Environmental Protection Agency’s public hearing to discuss the Proposed Tier 3 standards.

Below is Stanton’s written testimony that was submitted to the record.


April 24, 2013 – EPA Public Hearing, Philadelphia, PA

Testimony of Michael J. Stanton
President & CEO
Association of Global Automakers, Inc.
Regarding Proposed Tier 3 Standards

Good morning. My name is Mike Stanton, and I am President and CEO of the Association of Global Automakers.  We represent international motor vehicle manufacturers, original equipment suppliers, and other automotive-related trade associations.

It’s hard to believe that it’s been nearly a year-and-a-half since we were here in Philadelphia providing testimony on the proposed standards for greenhouse gas emissions and fuel economy.  In that testimony we emphasized the need for uniformity.  Automakers need to be able to manufacture and sell vehicles that are compliant in all 50 states.  The benefits of producing one fleet are numerous – reducing costs, streamlining compliance, focusing resources, etc., all while providing real and significant health and environmental benefits for the nation.  

Today, we have returned to consider another of the President’s goals, to reduce criteria pollutant emissions under the Tier 3 rule, securing additional public health and environmental benefits in the coming years.  Global Automakers and its members have supported the Administration’s efforts to develop the Tier 3 standards.

While challenging, the Tier 3 emission standards are feasible and provide the necessary flexibility and time to implement fleet improvements, while simultaneously improving vehicle fuel efficiency.  But these standards cannot be met with vehicle changes alone, and the Tier 3 proposal recognizes another critical component in reducing vehicle emissions – fuel quality, or more specifically the sulfur content in gasoline.  Global Automakers believes the proposed EPA fuel standards for a nationwide supply of clean, ultra-low sulfur gasoline is critical for automakers to meet the new and highly stringent vehicle emissions standards. We support the 10 ppm average, and a low cap, for sulfur in gasoline.

Ultra-low sulfur gasoline has been available in California for years, and the ability to comply with emission standards in California is premised on the use of such fuel, recognizing the need to treat the vehicle and the fuel as a system.

In addition to needing ultra-low sulfur fuel to achieve the Tier 3 emission standards, ultra-low sulfur fuel is also critical to automobile manufacturer efforts to meet the combined 54.5 MPG fuel economy and greenhouse gas emissions standard by 2025.  

Most importantly, the ultra-low sulfur fuel will provide immediate, substantial public health benefits from the existing legacy fleet of nearly 250 million vehicles.  According to the National Association of Clean Air Agencies, the impact on the legacy fleet is equivalent in emissions impact to taking over 30 million vehicles off the road.

Today, vehicles are lasting longer, and the average age of all vehicles on the road is 11 years.  While Tier 3 will be another great step in reducing the fleet’s emissions, it will take time for the fleet turn over to fully realize the benefits.  In the meantime, the ability to immediately and directly reduce emissions from the vehicles on the road today by reducing sulfur in gasoline cannot be matched.  

We are continuing to analyze the proposed regulations and will be submitting detailed written comments. We look forward to continuing to work with EPA to refine the proposed regulations and thank you for your efforts.

About Global Automakers
The Association of Global Automakers represents international motor vehicle manufacturers, original equipment suppliers, and other automotive-related trade associations. We work with industry leaders, legislators, and regulators to create the kind of public policy that improves vehicle safety, encourages technological innovation, and protects our planet. Our goal is to foster a competitive environment in which more vehicles are designed and built to enhance Americans’ quality of life. For more information, visit

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