Comments and Testimonies

November 7, 2001

Comments on the proposed rulemaking for a Heavy-duty diesel Emissions Control Program, submitted to the Environmental Quality Board,
Pennsylvania Department of Environmental Protection.
[25. PA CODE CHS. 121 AND 126]

On behalf of the Clean Air Council, I would like to express my support for the Environmental Quality Board and Pennsylvania Department of Environmental Protection's proposal to establish a new Heavy-Duty Diesel Emissions Control Program.

The implementation of this program will significantly reduce emissions of carbon monoxide (CO), nitrogen oxides (NOx), volatile organic compounds (VOCs), particulate matter (PM), and air toxics from new model year 2005 and subsequent model year heavy-duty diesel engines.

Heavy-duty diesel engines pose a serious health threat to the citizens of Pennsylvania. The U.S. Environmental Protection Agency (EPA) has identified over 40 toxic substances in diesel fuel and has labeled many of these toxics 'likely human carcinogens'. Vehicles powered by heavy-duty diesel engines only account for only around 1% of all motor vehicles; yet, these vehicles represent a large portion of air pollution from all sources. Heavy-duty diesel engines are responsible for over one quarter of all NOx emissions in the United States. NOx mixes with VOCs and sunlight to form ozone smog. Ozone smog triggered 370,000 asthma attacks in Pennsylvania in 1997 according to estimates made by the Clean Air Network. Heavy Duty Diesel engines also release over half of all dangerous soot particles that are emitted into the air. Soot further irritates respiratory problems and when inhaled can get lodged deep in the lungs causing infection.

The decision to implement enhanced emissions tests for Heavy-Duty Diesel Engines is welcomed by Clean Air Council as it will eliminate 12.5 tons of nitrogen oxide emissions per average summer day in the Commonwealth during 2006. During the summer months, ozone smog and hence respiratory problems are at their worst.

A recent ruling issued by the U.S. EPA ensures that enhanced emissions testing will be required Nationally in 2007 and the ensuing years. The majority of heavy-duty diesel engine manufacturers have agreed to make engines compliant with the new standards by 2004. Therefore, Clean Air Council urges Pennsylvania to follow the example of California and other states in guaranteeing that these enhanced test procedures are carried out in the intermittent years of 2005 and 2006.

The current U.S. EPA Federal Test Procedure (FTP) is not sufficient to cover the new engines during 2005 and 2006. The FTP does not include elevated high temperatures and highway cruise patterns, however, a major requirement of the new engines is to make certain that diesel emissions control devices are not turned off during highway driving. The proposed emissions tests will require two supplemental tests to the FTP, including testing under highway conditions. This is essential to ensure the best possible emissions control devices are fully enabled as soon as possible to protect the health and environment of the Commonwealth of Pennsylvania.

Clean Air Council is in full support of the proposed amendments to 25 PA. Code Chapters 121 and 126, regarding a Heavy-Duty Emissions Control Program in Pennsylvania.

Sincerely,

Judy Hawson
Policy Analyst, Clean Air Council

Clean Air Council works through a combination of public education, community advocacy, and oversight of government enforcement of environmental laws, to protect everyone's right to breath clean air. The Council's main program areas are Clean Air, Clean Energy, Indoor Air Quality, Sustainable Transportation, Waste and Recycling, and Global Climate Change. The Council operates offices in Philadelphia and Harrisburg, Pennsylvania, and Wilmington, Delaware.