From: Laureen Boles<EMAIL_ADDRESS>Sent: Wednesday, April 24, 2013 5:05 PM Date of the Public Hearing in Philadelphia
Testimony on Tier 3 Standards

> My name is Laureen Boles. I am a civil engineer and environmental city
> planner and a member of the Environmental Justice Leadership Forum on Climate Change. The Forum is a national coalition of 35 environmental justice organizations working together to inform state and federal policy, as well as political and legislative action, toward the development of just policies and the equitable reduction of carbon emissions in all communities. Thank you for the opportunity to testify on the Tier 3 standards for Clean Vehicles and Clean Fuels.
>
> The EJLFCC supports those provisions of the Tier 3 standards that are consistent with the organizations mission. I caution that the credit trading provision of the standards, which are designed to offer flexibility during the transition to more efficient vehicles and cleaner fuels, seems counterintuitive to uniform national standards - and thereby uniform benefits.
>
> I propose that the success of the Tier 2 standards is well-documented and all the transition we need. We casually speak of trading credits. But if we look at the transaction closely, on one-half of the transaction someone is holding a basket full of credits and on the other half a basket full of dis-benefits.
>
> I ask that you examine the impact that credit trading has had on the success of Tier 2 standards, because all communities deserve equal protection and their share of benefits:
> - GHG reductions
> - Fuel savings
> - Energy Security
> - Mitigation of disproportionate adverse health impacts
> - Economic growth
> - Job Creation
>
> I applaud the work that you have done, as well as the effort that it takes to balance the protection of people, preservation of the planet, and promotion of economic prosperity.
>
> Thank you again for this opportunity.