Clean Air Resolution: Cumberland County, PA

CLEAN AIR RESOLUTION

Resolution Regarding Air Quality in Cumberland County

Authored by the Clean Air Board of Central Pennsylvania

ADD YOUR NAME TO THE RESOLUTION

SEE CURRENT SIGNERS

Whereas,

pollution from diesel engine emissions has been proven to be harmful to our health. Diesel exhaust can contain 40 hazardous air pollutants, 15 of which are known human carcinogens. Fine particles from diesel emissions have been linked to heart attacks, asthma, stroke, stunted lung growth and premature death. Children and seniors are at the greatest risk from these emissions1; and

Whereas,

air quality has been shown to be especially degraded in Cumberland County and EPA has designated the County as being in non-attainment of fine particle (PM 2.5) and ozone standards. The average lifetime diesel soot cancer risk here is 393 times greater than the accepted EPA cancer level of one in one million2. Cumberland County is among the 2% most polluted counties in the nation for fine particle pollution3; and

Whereas,

in August 2005 more than 100 doctors in the region submitted a paid advertisement to local media citing statistics about air pollution and attributing the problem primarily to fine particle pollution from diesel exhaust and the heavy concentration of trucks in the area; and

Whereas,

“the earth is the Lord’s, and all that is in it,” as the Psalmist says, and human beings are called to be responsible stewards of God’s creation;

Therefore, the undersigned members of the Cumberland County faith community hereby ask that:

1. Planning and municipal authorities in Cumberland County take air quality factors into account in land use planning decisions, particularly with regard to diesel trucks and buses that contribute to air quality degradation.

2. Cumberland County enact ordinances to limit air pollution from the idling of diesel-powered vehicles.

3. Truck facilities in Cumberland County implement programs to reduce diesel emissions, including installation of electrification units to eliminate the need for extensive diesel-powered truck idling.

4. School districts in Cumberland County enact policies limiting school bus idling and aggressively pursue grant funding and programs to retrofit and upgrade school bus diesel engines with devices to help control harmful emissions.

CITATIONS

1. Clean Air Task Force, “Diesel and Health in America,” February 2005. Available online at http://www.catf.us/publications/view/83

2. Clean Air Task Force, Diesel Project. Available at http://www.catf.us/projects/diesel/

3. American Lung Association, “State of the Air 2005.” Available online at http://lungaction.org/reports/stateoftheair2005.html

4. The Sentinel: Carlisle, PA. August 23, 2005

SmartWay Transport Partnership: Low-Cost EPA Loans for Emissions Reduction

SmartWay Transport Partnership is an EPA program that offers low-cost loans for truckers to buy wide tires, aerodynamic farings, diesel oxidation catalysts, diesel particulate filters and A.P.U.’s.

SmartWay: US EPA

Basic Information

In 2004, EPA launched SmartWaySM — an innovative brand that represents environmentally cleaner, more fuel efficient transportation options.

In its simplest form, the SmartWay brand identifies products and services that reduce transportation-related emissions.  However, the impact of the brand is much greater as the SmartWay brand signifies a partnership among government, business and consumers to protect our environment, reduce fuel consumption, and improve our air quality for future generations.

All of EPA SmartWay transportation programs result in significant, measurable air quality and/or greenhouse gas improvements while maintaining or improving current levels of other emissions and/or pollutants.

EPA believes the quality of the environment is everyone’s responsibility; therefore, SmartWay is positioned as a personal choice that can make a difference for the environment.

Find out what you can do to save fuel, money, and the environment with SmartWay:

SmartWay Vehicles

Fuel Options

SmartWay Transport Partnership

SmartWay Tractors and Trailers

SmartWay Financing Options

Comments On DEP’s Proposed “Diesel Vehicle Idling; and Auxiliary Power Systems” Rule: Clean Air Council

Comments On DEP’s Proposed “Diesel Vehicle Idling; and Auxiliary Power Systems” Rule

Clean Air Council

January 12, 2008

38 Pa.B. 229

My name is Eric Cheung and I am the Senior Attorney for the Clean Air Council, a non-profit environmental group whose mission is to protect everyone’s right to breathe clean, healthful air. In order to fulfill this mission the Council works on a core set of diverse programs: air pollution, sustainable transportation, renewable energy, waste and recycling, indoor air quality and children’s environmental health. The Council represents the interests of over 7,000 members across Pennsylvania and Delaware, who provide financial support.

Clean Air Council supports PADEP’s proposed statewide anti-idling rule for diesel engines. When evaluating strategies to provide energy cleanly – whether for transportation or electric power – the Council places conservation at the top of its list. The cleanest unit of energy is the one that is not consumed. On the transportation side shutting off truck or bus engines when the vehicle has stopped should be as commonplace a practice as turning off the light switch when leaving a room. Stopping unnecessary idling reduces air pollution, saves individuals money, minimizes global warming gas emissions, and improves energy security.

Clean Air Council has long been aware of the impact of heavy duty vehicle diesel emissions on the health of Pennsylvania residents and has participated in initiatives to reduce them. From organizing clean diesel conferences, to advocating for the increased use of alternative fuels to diesel, to lobbying Philadelphia’s regional transit authority to replace its buses with hybrid electric models. Recently, the Council completed an Air Quality Assessment Report for the Carlisle Area, with a special emphasis on the impact of diesel emissions from truck traffic and recommendations for addressing this problem. It also spearheaded a campaign to encourage Pennsylvania school districts to voluntarily limit their school bus idling. Since 2003 the Council has been the co-administrator of the Philadelphia Diesel Difference Working Group, which has worked with local truck and bus fleets to retrofit their diesel engines with pollution control technologies. As an expert on the impact of diesel emissions and long-standing advocate for their reduction, the Council is excited to see PADEP announce this rule.

Petroleum-based diesel fuel is a significant source of both ozone-forming NOx compounds and harmful fine particulates. Among all highway vehicles, diesel-powered trucks and buses contribute 44% of the NOx and 75% of the fine particulates. Both of these pollutants cause harmful respiratory symptoms, trigger asthma attacks and can lead to premature deaths. Both are of particular concern to the 1.5 million school children in Pennsylvania who are transported to schools every day primarily by diesel-powered buses. Ozone and fine particulates have a disproportionately greater impact on children, because their lungs are still developing and they can breathe up to 50 percent more air per body weight than adults. Diesel exhaust is also known to contain toxic air contaminants – over 40 have been identified. Anti-idling will reduce the combustion of the diesel fuel that results in these harmful emissions.

Seven counties in PA are not in attainment of the current federal ozone health standards and 21 counties do not meet the standards for fine particulate. With stronger standards for both pollutants coming, Pennsylvania can expect to see more of its counties to be in non-attainment. While the 2006 ultra low sulfur requirement certainly has had an impact on fine particulate emissions, more significant reductions can only occur with changes to the engines themselves. Moreover, desulfurized fuel does nothing for NOx compounds that form ozone. Given that the federal health standards are becoming more and more stringent, Pennsylvania will need to use every regulatory tool it can devise to ensure the State achieves compliance. Failure to do so could lead to sanctions under the Clean Air Act such as loss of highway funding. Anti-idling is a relatively uncomplicated tool that will help the state reach compliance of the federal health standards.

With the rising costs of fuel, the Council believes there is an economic incentive to reduce unnecessary idling that will make acceptance of this rule easier. Quite frankly, many drivers and fleet owners are less concerned with the impact their vehicles are having on the environment than they are with the impact transportation costs are having on their bottom line. Much of the unneeded idling is a result of driver habit, apathy and misinformation. Moreover, new technologies like electrified truck stops and auxiliary portable units resolve the cabin comfort reasons for idling. A statewide anti-idling rule may be just the catalyst needed to get heavy duty vehicle operators to do what is in their best interest anyway. The Council recommends a strong education effort coinciding with the roll-out of this rule to ensure maximum support.

Another benefit to Pennsylvania’s anti-idling law will be the synergistic ones it produces. Neighboring states like Maryland, New Jersey and New York have their own anti-idling requirements. The two largest metropolitan areas in Pennsylvania, Allegheny County and Philadelphia, also have anti-idling rules. Once Pennsylvania’s law goes into effect, it can only reinforce the ones already in place. Conversely, having drivers already familiar with similar laws in neighboring areas, makes it easier for compliance in Pennsylvania. As each jurisdictional authority acts to cut back on unwanted idling, more and more drivers will get the message and will simply practice idling reduction as a matter of course, regardless of where they are.

Other benefits of the anti-idling rule include a reduction in greenhouse gases and foreign oil dependency. Each gallon of diesel that is burned produces 22 pounds of carbon dioxide, which contribute to global warming. Each gallon of petroleum diesel is most likely to have come from foreign oil sources like the Persian Gulf. Both the global environment and America’s energy security benefit as less diesel is burned as a result of this rule.

On a final note, the Council hopes that PADEP takes all the necessary steps to ensure enforcement of this rule. Philadelphia’s anti-idling ordinance has been in place for over 20 years and yet its effectiveness has been hampered due to a lack of enforcement resources. In order for this new rule to have an impact, it is essential that local enforcement agencies are educated about the rule and are willing to take on enforcement responsibilities. Furthermore, citizens should also be made aware of this rule and a number they can call to complain about idling should be established. The Council’s experience has been that governmental action can only be enhanced by community buy-in and support.

A rule that is better for the air and for people’s wallets seems like a no-brainer, so it is surprising that implementation of this rule would put Pennsylvania among a minority of states to pass such a requirement. It is not often that Pennsylvania is in a position to take a leading role among the states on an environmental initiative. This appears to be just such an opportunity and the Council hopes the State follows through.

Lastly, Clean Air Council would like to acknowledge and express gratitude for the Clean Air Board of Central Pennsylvania’s efforts in pushing for this rule. In a short time this burgeoning organization has established itself as one of the State’s more influential air quality advocates.

Eric Cheung, Esq.

Citizens Petition DEP and PennDOT for Diesel Anti-Idling Regulations: CAB Press Release

Citizens Petition DEP and PennDOT for Diesel Anti-Idling Regulations (PDF)

Harrisburg, PA (October 18, 2006) – To jump-start the regulatory process and to accelerate the arrival of cleaner, healthier air for all Pennsylvanians, a group of doctors, clergy, educators, concerned citizens, and municipal officials today asked the Rendell Administration to enact anti-idling regulations on commercial diesel vehicles. Reducing the time a truck or bus spends idling will cut the level of dangerous fine dust (particulate) emitted into the air across the state.

The Clean Air Board of Central Pennsylvania, Inc. (CAB) presented petitions to DEP and PennDOT Wednesday containing language to limit idling by commercial diesel vehicles. Due to an extensive interstate road system and favorable geography, Pennsylvania has become a transportation and distribution hub for the nation. Every truck that uses Pennsylvania roads, rest stops and truck facilities, and idles over a long period of time, adds pounds of pollutant dust to the state’s air.

Rev. Jennifer McKenna, President of CAB, noted the importance of fast action on these petitions, saying: “There’s no reason young children, older residents and people suffering from respiratory ailments should be forced to breathe diesel exhaust when it can be controlled.” She reminded us that; “The earth is God’s creation; and we are here to care for it and all the people on it.”

CAB Petition: We request that the Environmental Quality Board adopt a state-wide regulation restricting the idling of diesel powered vehicles.

CAB Petition: Environmental Quality Board of the Commonwealth of Pennsylvania (PDF)

Also see: Appendix A (PDF)

October 18, 2006

Excerpt:

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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