CAB Petition: Environmental Quality Board of the Commonwealth of Pennsylvania (PDF)
Also see: Appendix A (PDF)
October 18, 2006
Why is the petitioner requesting this action from the Board? (Describe problems encountered under current regulations and the changes being recommended to address the problems. State factual and legal contentions and include supporting documentation that establishes a clear justification for the requested action.)
Change being Recommended to Address Problem:
The Clean Air Board of Central Pennsylvania, Inc. is a faith-based citizen’s initiative, organized to promote strategies that significantly reduce the amount of air pollution produced by on-road motor vehicles with commercial diesel engines. In this Petition, we request that the Environmental Quality Board adopt a state-wide regulation restricting the idling of diesel powered vehicles. Idling of diesel powered motor vehicles, contributes significantly to Pennsylvania’s fine particulate matter pollution (PM 2.5) – an air pollutant which is of great concern to citizens of Commonwealth of Pennsylvania. This harmful and wasteful practice must be stopped. Our neighboring states of New York, New Jersey, Delaware and Maryland have anti-idling restrictions in place, along with eight other states, the District of Columbia, and the cities of Atlanta, and Denver. In Pennsylvania, Philadelphia and Allegheny County have established anti-idling restrictions. The Commonwealth needs to act on this petition to address a critical public health problem.
Problems Presented by Idling:
Fine particulate matter (PM 2.5) poses a serious health risk to Pennsylvanians because it can easily lodge deep in the lungs. When inhaled repeatedly, PM 2.5 is proven to aggravate heart and lung disease and cause other serious health problems including lung cancer, abnormal lung development in children and premature death.
Pennsylvania has serious public health and environmental problems presented by PM 2.5. The US EPA has designated 18 Pennsylvania counties (Allegheny, Beaver, Berks, Bucks, Butler, Cambria, Chester, Cumberland, Dauphin, Delaware, Lancaster, Lebanon, Mercer, Montgomery, Philadelphia, Washington, Westmoreland and York) and portions of 4 other counties, including Armstrong, Greene, Lawrence and Indiana) as “non-attainment” under the Clean Air Act for PM 2.5. By April 2008, Pennsylvania must submit its state implementation plan (SIP) to bring these non-attainment areas into compliance. By April 2010, Pennsylvania must demonstrate that these areas attain the National Ambient Air Quality Standard for PM 2.5.
The air we breathe is not clean. Due to the concentration of truck traffic, fine particulate pollution from diesel exhaust is much higher in Cumberland County than in most places, particularly in the Carlisle area. Preliminary PM 2.5 sampling indicates that significant levels are found in the areas east and west of Carlisle borough, the “Miracle Mile” and the Interstate-81 (Exit 44) warehouse district, respectively. The Clean Air Board has requested DEP to establish a PM 2.5 monitoring station to monitor the quality of the air that a large number of residents breathe. DEP has agreed to do so for one year. CAB has recommended a location for an ambient air quality monitor which would collect data representative of the air coming in to residential neighborhoods. The DEP monitoring stations around the state indicate a widespread problem in meeting the 24 hour limit for PM 2.5. Recent data from DEP ambient air quality stations across the state demonstrate that the recently revised 24 hour limit for PM 2.5 (35 micrograms per cubic meter) has been violated numerous times in 2006. (See Appendix B-1)
Public health authorities have long recognized that diesel exhaust emission can cause adverse impacts on the general population and on at-risk populations of the elderly, young children, and those who suffer from respiratory illnesses. EPA’s health assessment for diesel engine exhaust examined information regarding the possible health hazards associated with exposure to diesel engine exhaust. The assessment concluded that long-term (i.e., chronic) inhalation exposure is likely to pose a lung cancer hazard to humans, as well as damage the lung in other ways depending on exposure. Short-term (i.e., acute) exposures can cause irritation and inflammatory symptoms of a transient nature, these being highly variable across the population. The assessment also indicates that evidence for exacerbation of existing allergies and asthma symptoms is emerging. The assessment recognized that diesel emissions, as a mixture of many constituents, also contribute to ambient concentrations of several criteria air pollutants including nitrogen oxides and fine particles, as well as other air toxics. (EPA/600/8-90/057F, 2002) The EPA states that nationwide, particulate matter, especially the fine particles found in diesel exhaust, cause 15,000 premature deaths every year. (EPA420-F-02-048, September 2002)
The health problems presented by PM 2.5 are well documented (See Appendix B-2). In local newspaper advertisements, Cumberland County physicians have expressed their concern with the health effects of PM 2.5 exposure — the exacerbation of lung disease, i.e. asthma and emphysema, and the triggering of heart attacks (See Appendix B-3) Other states have developed strategies to reduce diesel pollution that Pennsylvania can emulate. These diverse strategies have been documented by EPA. See: http://www.epa.gov/ne/eco/diesel
Running a vehicle’s diesel engine while the vehicle is not moving (known as idling) creates unnecessary emissions of PM 2.5 and wastes fuel. Exhaust from diesel engines includes PM 2.5 and smog-forming pollutants. A typical idling truck burns nearly a gallon of fuel per hour. Seven thousand trucks, about the size of the fleet for a large national retail firm, idling for one hour a day would burn 2.1 million gallons of diesel fuel each year, and create 415 tons of smog-forming pollutants and 10 tons of particulate matter. (EPA Press Release, November 1, 2005; Release # dd051101)
Emissions from commercial diesel vehicles can cause significant local concentrations of PM 2.5. On August 9, 2006, DEP Secretary Kathleen McGinty participated in a press conference at the opening of the IdleAire facility in Carlisle. According to her remarks that day and the DEP press release, 13,000 diesel trucks idle in Pennsylvania everyday — most for up to 10 hours. (See Appendix B-4) Most operators allow their engines to idle in order to use heaters, air conditioning and electronics during their mandated rest period. This practice releases dangerous PM 2.5 and other pollutants into the air, wastes fuel, and decreases engine life.
Diesel exhaust is a major concern in central Pennsylvania. On Earth Day 2006, State Senator, Patricia Vance, noted that “Cumberland County has more truck traffic than any other county in the Commonwealth,”
Recognizing the need to eliminate unnecessary diesel engine idling, 15 representatives of the transportation industry in Cumberland County (shippers, truckers, warehouse managers, and diesel equipment manufacturers) have signed a resolution agreeing to minimize idling in their businesses. (See Appendix C-1)
The anti-idling regulation is a reasonably available control measure to reduce PM2.5. Pennsylvania should implement state-wide measures to limit idling and to reduce the air pollution. A uniform state-wide anti-idling measure will reduce local hot spots of PM 2.5, protect the health of Pennsylvanians — especially those who suffer from asthma and other respiratory conditions, assist the state in meeting its obligations to achieve the Clean Air Act’s national ambient air quality standard for PM 2.5, and ensure the citizens’ right to clean air as protected under the State Constitution. This requested anti-idling rule should be included in the State Implementation Plan for PM 2.5.
Additional Idle Reduction Benefits
Reducing the idling time of heavy-duty trucks reduces petroleum consumption, fuel costs, engine wear and maintenance costs, and noise, as well as diesel particulate and sulfur emissions,. Based on the approximately 460,000 long-haul trucks currently operating in the United States, Argonne National Laboratories estimates that idle reduction technologies could reduce diesel fuel use by 838 million gallons per year. That wasted diesel fuel translates to $1.4 billion that could be saved by drivers using idle reduction technologies.
By reducing the amount of time that trucks idle, estimated at about 6 hours per day, drivers can significantly reduce engine wear and the associated maintenance costs. Routine maintenance can be performed less often and trucks can travel farther before needing an engine overhaul.
In addition, Argonne National Laboratories estimates that idle reduction technologies used by the approximately 460,000 heavy-duty trucks operating on diesel fuel can reduce emissions of NOx by 140,000 tons, CO by 2,400 tons, and CO2 by 140,000 tons per year.(U.S. Department of Energy – Energy Efficiency and Renewable Energy http://www.eere.energy.gov/cleancities/idle/idle_benefits.html)
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