Thank
you to the Environmental Quality Board for the opportunity to present
testimony to you today on the important issue of the implementation of
the Pennsylvania Clean Vehicles Program. PennEnvironment is a statewide
non-profit, non-partisan environmental advocacy organization with more
than 18,000 citizen members across the state. PennEnvironment has been
active on air pollution and vehicle emission standard issues at the
state and national level, and has worked to educate the public and
decision makers on these issues.
Summary:
Given the public health and environmental threat posed by air pollution
in Pennsylvania, the state should implement the strongest possible
programs to reduce air pollution in the Commonwealth. Cars and trucks
are a significant source of this air pollution, but thankfully there
are both technologies that will drastically reduce pollution from
automobiles, and an established set of vehicle emissions standards that
will bring these cleaner vehicles to Pennsylvania faster than weaker
federal standards. We urge the Environmental Quality Board to move
ahead in implementing these standards in Pennsylvania, as encompassed
in the Pennsylvania Clean Vehicles Program.
Background
& Need for Air Pollution Reductions: While air quality has improved
in Pennsylvania and across the country over the last three decades,
Pennsylvania still suffers from air pollution levels that pose
significant public health and environmental threats, and levels that
represent some of the worst air pollution in the country. One air
pollutant of primary concern is ground-level ozone or smog pollution.
Nitrogen oxides and volatile organic compounds (VOCs) react with heat
and sunlight to create the smog that prompts “Code Red” ozone alert
days advising citizens to limit their outdoor activities.
In 2003, Pennsylvania ranked 11th nationwide for the worst ozone smog
pollution nationally, as measured by the number of exceedances of the
Environmental Protection Agency’s (EPA) 8-hour health-based ozone
standard. Preliminary data from 2005 suggests that from May through
August there were at least 20 days on which monitors in Pennsylvania
recorded smog levels exceeding EPA’s health-based standard. In
addition, 37 Pennsylvania counties have been named by EPA as
‘non-attainment’ areas for exceeding the 8-hour health-based ozone
standard. In addition to creating smog pollution, nitrogen oxides also
react with other substances in the air to form acid rain, which damages
forests, lakes, rivers and streams.
In addition to ozone smog pollution, two other air pollutants of
particular concern in Pennsylvania are air toxics such as benzene, and
global warming pollutants such as carbon dioxide.
PUBLIC HEALTH IMPACTS OF AIR POLLUTION
Ozone smog pollution creates a host of public health problems, and
exposure to even very low levels of ozone contributes to a wide range
of adverse health effects. Much like a sunburn affects the skin, ozone
burns our lungs and airways, causing them to become inflamed, reddened,
and swollen. Children, senior citizens, and people with respiratory
diseases are particularly vulnerable to the health effects of ozone
smog pollution. In 1997, EPA tightened the National Ambient Air Quality
Standard for ozone, and concluded that, when inhaled even at very low
levels, ozone can cause chest pain, aggravate asthma, reduce lung
function, increase emergency room visits for respiratory problems, and
lead to irreversible lung damage. Here in Pennsylvania, it is estimated
that ozone pollution triggers 370,000 asthma attacks annually, and
there are 740,000 adult asthmatics in Pennsylvania, or nearly 8 percent
of the state’s adult population. Additionally, a new PennEnvironment
report to be released next week found that smog pollution is
responsible for 7,000 hospital admissions due to respiratory problems
each year in Pennsylvania, as well as 4,000 visits to emergency rooms
due to asthma.
Since 1997, more than 1,700 additional studies on the health and
environmental effects of ozone smog pollution have been published in
peer-reviewed journals. These studies point to additional, even more
serious health effects associated with exposure to ozone smog
pollution, including the development of asthma in individuals (vs. the
triggering of asthma attacks), the development of cardiovascular
diseases, increased risk of birth defects in the children of pregnant
women exposed to ozone smog pollution, and premature mortality.
Also, toxic or hazardous air pollutants, such as benzene, have
significant public health impacts as well. Many are known or suspected
to cause cancer, birth defects, neurological damage, and other serious
health effects. Benzene specifically is known to cause leukemia.
CARS’ AND LIGHT TRUCKS’ CONTRIBUTION TO AIR POLLUTION
In
Pennsylvania, highway vehicles—including cars and light trucks—are
responsible for a significant portion of the air pollution created.
Specifically, in 2001, highway vehicles emitted over 300,000 tons of
smog-forming nitrogen oxides—or 37 percent of the state’s total
emissions—and over 180,000 tons of volatile organic compound emissions
(VOCs), or 30 percent of the VOC emissions in Pennsylvania. In 2001,
transportation sources accounted for 27% of Pennsylvania emissions of
the global warming gas carbon dioxide.
POLLUTION REDUCTION TECHNOLOGY
Thankfully, there is pollution control technology available today that
can make all cars cleaner cars. In addition to the advanced technology
hybrid vehicles that are more efficient and often pollute less than
conventional cars and trucks, there are also technologies that can be
used to make conventional cars and trucks pollute less.
Ozone smog and air toxics pollution reduction technologies that can be
applied to most conventional car and truck models include exhaust gas
recirculation; oxygen sensors that allow adjustments in the air/fuel
mix in a vehicle’s cylinders in order to maximize the efficiency of
combustion and ensure proper function of the catalytic converter;
faster-heating catalytic converters to reduce emissions that take place
while the car is heating up; improved computerized control of the
engine start-up sequence to reduce “cold-start” emissions; and
“smog-eating” coatings on radiators that convert ground-level ozone in
ambient air into oxygen.
Global warming pollution reduction
technologies include more efficient engines, more aerodynamic designs,
cylinder deactivation, improved lubricating oil, direct-injection
engines, advanced transmissions, integrated starter-generators, weight
reduction, and improved air conditioning systems.
The Pennsylvania Clean Vehicles Program: Given the availability of
these pollution reduction technologies, and the need to reduce air
pollution and its public health and environmental impacts, many states
across the country have adopted a set of standards that will bring
cleaner cars and their environmental benefits to the nation’s roads
sooner than under weaker federal standards. These more stringent
standards were developed by California, and have since been adopted by
10 states—including New York and New Jersey. Pennsylvania now has the
opportunity to join these states, by moving forward with the
Pennsylvania Clean Vehicles Program, which implements these standards.
HISTORY OF THE STANDARDS
The federal Clean Air Act is built upon the premise that every area
across the country should reduce air pollution to levels that are
protective of public health—as measured against the National Ambient
Air Quality Standards. These standards have been set for a number of
pollutants, including ozone and nitrogen oxides, and those areas that
meet the standards are said to be in “attainment” whereas the areas
with pollutant levels higher than the standards are said to be in
“non-attainment.” As was mentioned earlier in this testimony, 37
Pennsylvania counties are currently in non-attainment for ozone
pollution. The Clean Air Act requires states with non-attainment areas
to submit to EPA state-implementation plans (SIPs), which map out how
the state will reduce pollution to acceptable levels by no later than
2010.
Section 177 of the Clean Air Act allows states with approved SIPs to
adopt California’s stronger motor vehicle standards. In other words,
states with air pollution problems have two choices when deciding how
to regulate emissions from mobile sources: they can follow the federal
standards or the California standards. This choice allows states with
entrenched air pollution problems the option of adopting policies
proven to reduce pollution in other states, and in states with the most
polluted areas, federal standards may not be enough to achieve
attainment status under the Clean Air Act.
In 1998, Pennsylvania’s Department of Environmental Protection (DEP)
adopted the Pennsylvania Clean Vehicles Program as codified in 25 Pa.
Code 121 and 126, and in 1999 EPA incorporated the Pennsylvania Clean
Vehicles Program as part of Pennsylvania’s SIP. As outlined in 25 Pa.
Code 121 and 126, automobile manufactures were allowed to comply with
the National Low Emission Vehicle (NLEV) Program—a voluntary national
low emission vehicle program—“as a compliance alternative to the
Pennsylvania Clean Vehicles Program requirements” until model year
2006. In model year 2006, all new passenger cars and light trucks sold
in Pennsylvania were to meet the requirements of the Pennsylvania Clean
Vehicles Program.
REQUIREMENTS OF THE STANDARDS
The standards within the Pennsylvania Clean Vehicles Program require
automobile manufacturers selling cars in Pennsylvania to certify under
California’s Low Emission Vehicle (LEV) and LEV II requirements that
their vehicles meet a set of more stringent vehicle emission standards
than those required under federal ‘Tier II’ standards, as well as a
fleet-wide average for hydrocarbon emissions.
Regarding
the cost of these standards, DEP’s estimates that there is a negligible
cost increase for Pennsylvania Clean Vehicles Program vehicles are
consistent with what has been determined by the California Air
Resources Board (CARB). While this added cost per vehicle will likely
increase in 2009, the cars being sold then will likely recoup those
additional costs through savings in operating costs—primarily reduced
fuel consumption. Vehicles with increased fuel efficiency are in high
demand—a recent national survey found that nine out of ten Americans
say that U.S. consumers should have access to the more fuel-efficient
vehicle models being offered by some U.S. automakers in other countries
but not in the United States.
Also, regarding some of the cost estimates that have been put forward
in documents from the Alliance of Automobile Manufacturers, it is worth
noting that pre-regulatory estimates from both the automobile industry
and regulators are typically higher than what the costs end up being.
Specifically, in the 1970s, Chrysler estimated that adding catalytic
converters to cars and trucks would add $1,300 ($2,770 in today’s
dollars) to the cost of vehicles. Regulators estimated the cost to be
$755 ($1,600 in today’s dollars). The actual cost for adding catalytic
converters ended up being $875 to $1,350 in today’s dollars, meaning
Chrysler’s estimate was roughly two to three times too high, and
regulators also overestimated the cost. Then, in the 1990s, the
automobile industry estimated that California’s LEV standard would add
$788 to the cost of vehicles, while the California Air Resources Board
estimated the added cost would be $120. The actual added cost for the
LEV standard ended up being roughly $83, meaning that the automobile
industry estimate was almost ten times too high, and even the
California Air Resources Board estimate was nearly one and a half times
too high. Given this track record, to base any public policy decision
on the $3,000 added cost estimate that has been put forth by the
automobile manufacturers with regard the Pennsylvania Clean Vehicles
Program simply doesn’t make sense.
BENEFITS OF THE STANDARDS
The Pennsylvania Clean Vehicles Program will result in cleaner vehicles
being available in Pennsylvania that will create significantly greater
reductions in vehicle air pollution than if Pennsylvania were to opt
into the federal Tier II standards. Automobile manufactures are making
cars that meet these standards, and implementation of the Pennsylvania
Clean Vehicles Program will ensure that Pennsylvanians will be able to
choose from these cleaner vehicles when buying a new car. Rather than
limit consumer choice, Pennsylvanians’ choice of vehicles will be
expanded to include cleaner models of vehicles that might not otherwise
be available if the state opts instead into the weaker federal Tier II
standards.
With regard to air pollution reduction, DEP estimates that by 2025, the
Pennsylvania Clean Vehicles Program standards will result in a 6 to 12
percent decrease in annual volatile organic compound (VOC) emissions, a
9 percent decrease in annual nitrogen oxide emissions, and a 7 to 15
percent decrease in toxic benzene emissions as compared to reductions
achieved through the federal Tier II standards. These estimates are
consistent with estimates from state agencies in other states that are
implementing the California standards. Also, with regard to the 1-2%
air pollution reduction figure from EPA that opponents of the
Pennsylvania Clean Vehicles Program have repeatedly referenced, it
should be noted that EPA has not performed a state-specific analysis of
the benefits from the Pennsylvania Clean Vehicles Program. In fact, in
response to an inquiry from state Representative Richard Geist in
December, 2005 about whether or not EPA had quantified emissions
benefits from the program, EPA regional administrator Donald Welsh
responded, “At present, EPA has not performed such an analysis,
although PA DEP has done so.” DEP’s benefits analysis is the only
state-specific study that has been presented thus far, and therefore
provides the most accurate estimate of what pollution reductions will
be realized by the Clean Vehicles Program. These standards will also
see greater reductions in global warming emissions, and consumers would
likely save money at the pump due to the increased fuel efficiency of
the cars meeting the standards.
Conclusion:
Despite the progress that has been made in recent years, air pollution
is still a serious environmental and public health problem for
Pennsylvania. There are many policy handles that can be implemented to
help tackle this problem, and one key policy in the effort is the
Pennsylvania Clean Vehicles Program—a program whose emissions standards
will cut smog-forming pollutants by roughly 10 percent and help the
state meet its federal air quality attainment requirements. Rather than
limiting vehicle choice, this program will increase the clean vehicles
that Pennsylvanians can choose from when purchasing a car. And
thankfully, this set of standards has already been researched and
implemented by other states, including two of our border states. For
all of these reasons, PennEnvironment strongly encourages the
Environmental Quality Board to move forward in implementing the
Pennsylvania Clean Vehicles Program.
Thank you again for the opportunity to testify before you today.
