Testimony of Rebecca D. Stanfield
Clean Air Advocate
U. S. Public Interest Research Group
On the Environmental Protection Agency's Proposed Sulfur Standard for Gasoline
May 18, 1999

Good morning. My name is Rebecca Stanfield, and I am the Clean Air Advocate for U.S. Public Interest Research Group (U.S. PIRG). U.S. PIRG is the national lobby office for the state PIRGs, which are consumer and environmental watchdog organizations active across the nation. I greatly appreciate the opportunity to speak to the Subcommittee today on this important and timely issue.

Air Pollution is Causing a Public Health Crisis

Air pollution impacts the health of over 117 million Americans who live in areas where the air quality is often unhealthful. Each year tens of thousands of Americans are rushed to hospital emergency rooms due to asthma attacks brought on by smog pollution. Millions more miss work, miss school, are forced to stay indoors instead of playing outside or experience loss of lung function due to air pollution. More than 40,000 people this year will die prematurely as a result of air pollution.

An anecdote may serve to more clearly illustrate the magnitude of this problem. In one New Jersey Episcopal congregation more than half of the children carry inhalers to Sunday School, and the risks of an attack are so high that the minister keeps a nurse on call during on smoggy summer days when children are at the church for activities. Stories like this one are becoming more and more common, as the number of Americans with asthma rises even above its current number of 15 million victims, including over 5 million children.

Moreover, air pollution is not just a Northeastern or a California problem, as it was once believed to be. Today, air pollution is known to be a national problem. During the 1998 smog season, over 5200 violations of EPA's smog standard occurred in 41 states across the nation, including the home states of every member of this Subcommittee.

The Proposed Gasoline Sulfur Standards Would Save Lives

The U.S. EPA has proposed regulations that will save lives by reducing air pollution from one of its largest sources, the automobile. Despite improvements in automobile pollution control technology, motor vehicles are still responsible for one-third of the smog-forming, air pollution emitted in the United States. This is because people are driving more than ever: two and a half trillion miles a year in the 1990s, compared to just one trillion miles per year in 1970.

Reducing the extremely high levels of sulfur in gasoline sold throughout the U.S. will vastly improve the performance of the pollution control equipment in current and future models of automobiles, cutting smog and soot pollution, as well as hydrocarbons, carbon monoxide sulfur dioxide, and air tonics. Even in existing cars clean gasoline can cut pollution levels by up to 20 percent. In new, low-emission vehicles which will soon be available across the nation, pollution levels are more than double when using high sulfur gasoline, as compared to clean gasoline. Studies by the State and Territorial Air Pollution Program Administrators, and the Association of Local Air Pollution Control Officials show that EPA's sulfur proposal would have the same air quality benefits as removing -4 million cars Tom the roads entirely.

The Proposed Gasoline Sulfur Standards are Cost-Effective

EPA's proposal is a cost-effective pollution reduction measure which has already been implemented in Japan, Finland, Thailand, Canada, Hong Kong, Taiwan, the European Union and California. EPA estimates that the program will cost just one to two cents per gallon of gasoline. For the typical driver, that adds up to about $12 per year. This added cost is well within the cost that the American public is willing to pay for cleaner air. Earlier this year the American Lung Association commissioned a poll showing that 90 percent of Americans would pay three cents per gallon more for clean gasoline, while 70 percent would pay five cents more per gallon.

A Uniform, National Program Must Be Adopted

We agree with EPA that it is critical to adopt a uniform national standard, rather than the regional standards advocated by the petroleum industry for several important reasons. First, as I said before, air pollution is a national problem, with violations of the smog standards occurring in four out of five states last summer. Reducing smog and soot forming pollution from automobiles can benefit people everywhere, not just in the worst ozone non-attainment areas of Southern California and the Northeast.

Second, high sulfur gasoline sold in one state is very likely to have pollution impacts in many states. The reason is that Americans drive from state to state, and from region to region, fueling their vehicles along the way with whatever type of gasoline is sold in that state. A traveler filling up his gas tank with dirty Mel while passing through a slate with less stringent standards will damage the pollution control equipment in the car, part of which damage is irreversible. Thus the car will continue to be more polluting even after returning to its home state. Such an approach to gasoline sulfur standards would seriously undermine the effectiveness of the entire clean car program.

The Proposed Standards Provide Ample Flexibility for Industry

EPA's proposal strikes a balance between achieving necessary pollution reductions, and allowing the industry ample time and flexibility to meet the new standards. First, EPA allows the industry to use an averaging system to meet an average standard of 30 parts per million sulfur content. Second, EPA allows the oil refineries to meet these standards through the use of credits, generated as early as the year 2000 by refiners who make early sulfur reductions from current levels. Third, EPA is allowing less stringent caps to be met in the years 20()4 and 2005, with the final cap of 80 parts per million sulfur to be met in 2006, more than six years after adoption of the rules. Finally, EPA allows small refiners, defined as a small business under the Small Business Regulatory Enforcement Fairness Act of 1996, to meet less stringent standards through the year 2007.

The Proposed Standards Should be Phased In Earlier

We believe that EPA's proposed gasoline sulfur standards allows too much time to pass before the significant air pollution benefits can be expected. In 2001 automakers will begin nationwide marketing of low emission vehicles under the voluntary National Low Emission Vehicle program. The effectiveness of the emission control technology used in these vehicles will be compromised by the sulfur that will remain at high levels until 2004 - 2006, when clean gasoline would be phased in under the proposed standards. Moreover, under EPA's proposal, gasoline containing sulfur at levels up to 300 parts per million will continue to be sold in 2004, the year that EPA is requiring 25 percent of new cars to be significantly cleaner. Again, the technological advances made in these vehicles will be undermined by the use of high-sulfur fuel in 2004 and 2005. A better approach would be to begin phasing-in clean gasoline earlier, so that most, if not all gasoline sold in 2004 is clean gasoline.

Thank you again for the opportunity to address the Subcommittee. I hope that you will agree that the timely phase-in of a nationwide clean gasoline program is an important public health protection that should be adopted immediately.