Clean Air Board asks DEP to examine Regional Greenhouse Gas Initiative

At the invitation of the Pennsylvania Department of Environmental Protection, the Clean Air Board submitted comments on adopting state plans under the Clean Air Act to reduce carbon emissions.   On Dec. 9, 2013, the DEP held a listening session to hear from environmental organizations on how to implement Section 111(d) of the Clean Air Act, which would require state plans to curb carbon emissions once EPA adopts carbon emission limits for new power plants.

CAB’s comments urge DEP to look at the Regional Greenhouse Gas Initiative (RGGI) – undertaken by nine states (but not including Pennsylvania) – as a model for reducing carbon emissions.  According to RGGI: “The experience in the RGGI states shows the magnitude of emission reductions possible from the power sector: a projected 50% decline in tons of carbon dioxide (CO2) emissions and a fossil fuel-fired generation fleet that is projected to achieve emission rates on par with the recently proposed new source performance standard for new electric generating units.”

Click for  the full text of CAB comments to DEP

The Sentinel editorial, May 5, 2013

More than 40 people gathered around a large table in Carlisle Thursday night doing something very important: They talked.

They talked about the lasting, damaging effects of Cumberland County’s toxic air at a public forum hosted by the Clean Air Board of Central Pennsylvania, an event spurred by The Sentinel’s three-day special report about air quality. Their attendance — not to mention their great ideas — is a sign that many in this area are serious about the issue even if our politicians appear not to be.

Many of those in attendance expressed their frustration that elected officials took a pass on dealing with the issue.

Read more:

http://cumberlink.com/news/opinion/editorial/our-view-our-air-a-grassroots-effort-reborn/article_5184199e-b425-11e2-bc60-0019bb2963f4.html

The Job-Creating Mercury Rule

New York Times – Published: February 22, 2012

After 20 years of delay and litigation by polluters, the Obama administration approved in December one of the most important rules in the history of the Clean Air Act. It will require power plants to reduce emissions of mercury and other toxic pollutants by more than 90 percent in the next five years and is expected to prevent as many as 11,000 premature deaths annually from asthma, other respiratory diseases and heart attacks.  More …

http://www.nytimes.com/2012/02/23/opinion/the-job-creating-mercury-rule.html?_r=1&partner=rssnyt&emc=rss

The Diesel Powered Motor Vehicle Idling Act – General Restriction on Idling

Section 3.  Restrictions on idling.

(a) Restrictions.–No driver or owner of a diesel-powered motor vehicle with a gross vehicle weight of 10,001 pounds or more engaged in commerce shall cause and no owner or operator of the location where the vehicle loads, unloads or parks shall allow the engine of the vehicle to idle for more than five minutes in any continuous 60-minute period, except as provided under subsections (b) and (c).

(b) Exclusions.–The idling restrictions set forth in subsection (a) do not apply to motor homes, commercial implements of husbandry, implements of husbandry, farm equipment or farm vehicles.

(c) Exemptions.–A diesel-powered motor vehicle with a gross weight of 10,001 pounds or more may idle beyond the time allowed in subsection (a) for one or more of the following reasons:

(1) When a vehicle idles while forced to remain motionless because of on-highway traffic, an official traffic control device or signal or at the direction of a law enforcement official.

(2) When a vehicle must idle to operate defrosters, heaters, air conditioners or cargo refrigeration equipment, or to install equipment, in order to prevent a safety or health emergency and not for the purpose of a rest period, or as otherwise necessary to comply with manufacturers’ operating requirements, specifications and warranties in accordance with Federal or State motor carrier safety regulations or local requirements.

(3) When a police, fire, ambulance, public safety, military, utility service vehicle or other emergency or law enforcement vehicle or any vehicle being used in an emergency or public safety capacity shall idle while in an emergency or training mode and not for the convenience of the driver.

(4) When the primary propulsion engine idles for maintenance, particulate matter trap regeneration, servicing or repair of the vehicle or for vehicle diagnostic purposes, if idling is required for that activity.

(5) When a vehicle idles as part of a Federal or State inspection to verify that all equipment is in good working order, if idling is required as part of the inspection.

(6) When idling of a primary propulsion engine is necessary to power work-related mechanical, safety or electrical operations other than propulsion. This exemption shall not apply when idling is done for cabin comfort or to operate nonessential onboard equipment.

(7) When idling of a primary propulsion engine is necessary as part of a security inspection either entering or exiting a facility.

(8) When an armored vehicle must idle when a person remains inside the vehicle to guard contents or while the vehicle is being loaded or unloaded.

(9) When a vehicle must idle due to mechanical difficulties over which the driver has no control, if the vehicle owner submits the repair paperwork or product repair verifying that the mechanical problem has been fixed, by mail to the department within 30 days of the repair.

(10) When a bus, school bus or school vehicle must idle to provide heating or air conditioning when non-driver passengers are onboard. For the purposes of this exemption, the bus, school bus or school vehicle may idle for no more than a total of 15 minutes in a continuous 60-minute period, except when idling is necessary to maintain a safe temperature for students with special needs who are transported by a school bus or school vehicle.

(11) An occupied vehicle with a sleeper-berth compartment that idles for purposes of air conditioning or heating during a rest or sleep period and the outside temperature at the location of the vehicle is less than 40 degrees or greater than 75 degrees Fahrenheit at any time during the rest or sleep period. This applies to a motor vehicle subject to this act parked in any place that the vehicle is legally permitted to park, including but not limited to, a fleet trucking terminal, commercial truck stop or designated rest area. This exemption expires May 1, 2010. This exemption does not apply if the vehicle is parked at a location equipped with stationary idle reduction technology that is available for use at the start of the rest period.

(12) When idling is necessary for sampling, weighing, active loading or active unloading or for an attended motor vehicle waiting for sampling, weighing, loading or unloading. For the purposes of this exemption, the vehicle may idle for up to a total of 15 minutes in any continuous 60-minute period.

(13) When idling by a school bus or school vehicle off school property during queuing for the sequential discharge or pickup of students is necessary because the physical configuration of a school or the school’s surrounding streets does not allow for stopping.

(14) When idling is necessary for maintaining safe operating conditions while waiting for a police escort when transporting a load that requires the issuance of a permit in accordance with 75 Pa.C.S. Ch. 49 Subch. D (relating to special permits for excessive size and weight).

(15) When actively engaged in solid waste collection or the collection of source-separated recyclable materials. This exemption does not apply when a vehicle is not actively engaged in solid waste collection or the collection of source-separated recyclable materials.

(d) Exception.–The restriction on idling set forth in subsection (a) does not apply to a diesel-powered motor vehicle that exhibits a label issued by the California Air Resources Board under 13 CCR § 1956.8(a)(6)(C) (relating to exhaust emissions standards and test procedures – 1985 and subsequent model heavy- duty engines and vehicles) showing that the vehicle’s engine meets the optional NOx idling emission standard.

SEE CAB LIBRARY FOR FULL TEXT OF THE LAW

CAB: Testimony Before the Environmental Quality Board about Anti-Idling Regulations

CAB: Testimony Before the Environmental Quality Board about Anti-Idling Regulations(PDF)

February 12, 2008

Good Afternoon. My name is Thomas Au. I am here today on behalf of the Clean Air Board of Central Pennsylvania.

The Clean Air Board was formed in the fall of 2005 after over 100 Cumberland County physicians signed an open letter in the newspapers informing the community of the growing danger of ozone and particulate pollution. The medical professionals observed that many of the health problems they see were attributable to air pollution that we all breathe. The letter stated: “Breathing diesel emissions containing these fine particulates can result in exacerbation of lung disease, i.e., asthma and emphysema, and can precipitate heart attacks. The populations at particular risk include infants, children, and the elderly with pre-existing heart and lung disease.” The Clean Air Board now includes people from many walks of life – ministers, teachers, doctors, lawyers, businessmen, civic leaders, and ordinary citizens.

The Clean Air Board of Central Pennsylvania is a faith-based citizens’ initiative dedicated to achieving clean air to protect our health and quality of life. We accomplish our mission by: raising public awareness of air quality issues; advocating, promoting and coordinating policy and practices for clean air; and, monitoring air quality. CAB is an entirely volunteer organization. We have no paid staff.

One of the air pollution problems the Board has identified in central Pennsylvania is the concentration of diesel exhaust emissions at rest stops, truck stops, and along the sides of roads. Due to an extensive interstate road system and geography, Pennsylvania has become a transportation and distribution hub for the nation. Every truck that idles over a long period of time at rest stops and truck facilities adds pounds of ground level pollutants.

The Board examined strategies that can significantly reduce the amount of air pollution produced by commercial vehicles with diesel engines. Idling by large diesel powered vehicles contributes significantly to ground level fine particulate matter pollution (PM 2.5) and leads to the formation of ozone pollution. The Board has met with local governments, the trucking industry, and civic groups to better understand the problems that truck and bus operators face if a regulation or statute is adopted. The Board also discussed the problem of enforcement with municipalities which already have adopted limitations on idling.

On October 16, 2006, the Clean Air Board filed a petition with the Environmental Quality Board to adopt a state-wide regulation to limit idling of diesel powered vehicles. The Clean Air Board’s 2006 petition asked the Department of Environmental Protection and the EQB to adopt regulations to limit idling by commercial diesel vehicles.

In drafting a proposed regulation for the Environmental Quality Board and the Department of Environmental Protection to consider, the Clean Air Board recognized that certain operational needs of the transportation industry may require some amount of idling. We included exemptions that would accommodate these operational needs. However, we recognize that idling for the sole purpose of heating and cooling of cabs has been made unnecessary by appropriate modern technology. Air quality benefits can also be achieved by reducing the amount of unnecessary idling that occurs when vehicles are waiting to load and unload.

The residents of Cumberland County are keenly aware of this diesel exhaust pollution. DEP’s studies have concluded that Cumberland County experiences the highest number of long duration idling hours in the Commonwealth. Idling emissions are a growing problem with the increase of long-haul diesel trucks traveling the highways of the Commonwealth. Where diesel trucks and buses congregate — at truck stops, rest areas, and parking lots — the concentration of emissions is especially harmful to those who must breathe these emissions – workers, drivers, residents. Along with direct emission of fine particulate, diesel powered vehicles emit nitrogen oxide (NOx) and volatile organic compounds (VOCs), both of which contribute to ground-level ozone and particulate matter. Ozone and fine particulate matter are pollutants that can cause or exacerbate breathing problems, especially in people with pre-existing respiratory conditions such as asthma, bronchitis and emphysema. These air pollution concerns are not only evident in central Pennsylvania, but are also evident in communities along our major transportation arteries across the state.

Excessive idling unnecessarily wastes fuel. One gallon of diesel fuel is burned for every hour spent idling. DEP estimates that diesel trucks spend 22.3 million hours a year in Pennsylvania in long-duration idling (idling for more than 15 minutes) – approximately 95 percent of which is due to truck travel rest periods. If each of the 13,000 long-haul trucks that idle in Pennsylvania each day used alternative means to provide power during rest periods, diesel fuel use would be cut by more than 20 million gallons per year. We believe that many in the transportation industry recognize the economic value of reducing idling time.

The proposed idling regulation is consistent with the EPA model rule and the state rules in those states which have adopted idling regulations. Pennsylvania is only state in the northeast that does not have an idling rule. The current situation may encourage some operators to rest in Pennsylvania and idle their trucks in Pennsylvania, thereby aggravating our air pollution problems. Other communities in Pennsylvania, such as those along I-80 in Luzerne County and along I-78 in the Lehigh Valley, also receive a disproportional share of long-duration idling emissions.

Many trucking operators and companies have installed auxiliary power systems, battery operated systems, and other idling reduction systems on their diesel vehicles to avoid the need to run the main engines to heat or cool the cab during rest periods. Technology has been developing rapidly to ensure the comfort of drivers during mandated rest periods. Among other initiatives, the Commonwealth has supported the installation of the Idle-Aire heating and cooling systems at several truck stops in Pennsylvania. The May 1, 2010 expiration date for the temperature related exemption of idling during rest periods provides companies and drivers with sufficient time to install bunk heaters, battery systems, or auxiliary power units (APUs). The regulation also requires truck operators to use existing facility electrification systems, such as Idle-Aire, if they are installed and available for use. We believe this is a sensible requirement and we support this requirement.

We do not support any additional exemptions for idling, other than the ones listed in the proposed regulation. As stated earlier, the proposed regulation accommodates legitimate operational needs of the transportation industry, as stated in sections 126.612(a)(3), (a)(4), and (a)(5), and in other provisions of the proposed regulation. Turning engines on and off while waiting to load and unload, where the truck or bus is not on a public road, is not an undue burden.

We believe that we need to protect school children from unnecessary exposure to diesel emissions, while protecting their safety. We recognize that there may be certain limited situations, where school buses may need to idle on public streets in order not to tie up traffic while waiting to pick up children. This is covered in section 126.612(a)(11) of the proposed regulation. When school buses are on school property, there are no such traffic concerns and they should not idle. We suggest that the exemption for school bus idling be clarified to allow such idling to public streets and not allow such idling while on school property.

Because of our shared concerns about the quality of the air we are breathing and the need to take steps to reduce diesel engine idling emissions, we have circulated a petition among local residents and communities in support of the proposed regulations. The Clean Air Board is pleased to submit petitions signed by over 1,400 central Pennsylvania residents supporting the Environmental Quality Board’s action in proposing these regulations. The petitions include the resident’s name, address, municipality, and zip code. Signers include residents of Cumberland County, Dauphin County, Lancaster County, York County, Perry County, and other counties. Most of the signers of the petition are not members of the Clean Air Board. These citizens signed the petition because they are interested in improving our air quality and interested in this proposed regulation.

The Clean Air Board wants to publicly thank the members of the Environmental Quality Board and the staff of the Department of Environmental Protection for the work that you have put into this proposed regulation. You have listened to our concerns. You have tried to address our concerns. In the end, we believe you will adopt regulations that we can be proud of.

Testimony before the Environmental Quality Board by the Rev. Duane Fickeisen

February 13, 2008

Testimony before the Environmental Quality Board by the Rev. Duane Fickeisen (PDF)

Harrisburg, PA

Testimony before the Environmental Quality Board

Good afternoon. My name is Duane Fickeisen and I am one of the pastors of the Unitarian Universalists of the Cumberland Valley in Boiling Springs. I also serve on the board of the Clean Air Board of Central Pennsylvania. I speak as a religious leader in support of the proposed regulation of idling.

Thank you for the efforts you have made to craft an effective and reasonable proposed regulation. I feel it is an excellent example of citizens and government working together to improve the quality of life in our state.

I am concerned about the health impacts of PM2.5 in the air we breathe. Members of the congregation I serve reside throughout the Cumberland Valley. Several of them suffer from respiratory and cardiac ailments. Some of them have expressed to me the belief that high PM2.5 levels impact their breathing. They have noticed that they are especially affected on days when the Air Quality Index is high, primarily due to fine particulates. This continues to have serious effects on the quality of their lives.

While the Carlisle/Harrisburg area is among the worst in the nation for fine particulate air pollution, other parts of Pennsylvania — especially the Pittsburgh, Allentown, and Philadelphia areas — also experience unhealthy levels of PM2.5.

It is my understanding of the medical research on effects of exposure to fine particulates that no safe level has been established, that even relatively small reductions in exposure have been estimated to provide significant health benefits, and that even short-term exposure to high concentrations increases the risk of heart attack. Further, I understand that exposure to fine particulates causes abnormal lung development in children that is irreversible.

I am especially concerned about the people who are frequently exposed to high concentrations of PM2.5 for long periods, including those who spend much of their time near diesel exhaust sources — on highways, at or near warehouses and trucking facilities, in or near school busses, for example. Professional drivers, highway construction crews, police and other emergency responders, and school children seem particularly vulnerable as does anyone who lives or works within 1000 feet of a highway, truck route, or trucking facility.

My religion teaches that we have a compelling responsibility to care for every person in our community — to practice a radical hospitality that cares for all. We affirm the inherent worth and dignity of every person. We also teach, along with virtually all of the world’s religions, that

we are called to be effective stewards of the Earth. Unitarian Universalists are called to respect the interdependent web of all existence. Whether you arrive at the call to stewardship from an understanding that God created it, saw that it was good, and charged us to care for it; from the belief that we owe it to future generations to protect the planet; or from the standpoint that it just makes sense not to foul our own nest, I think most people would agree that we should take our stewardship seriously.

Not only that, but the Commonwealth’s Constitution includes a declaration of rights, which includes this language in Section 27, titled Natural Resources and the Public Estate:

“The people have a right to clean air, pure water, and to the preservation of the natural, scenic, historic and esthetic values of the environment. Pennsylvania’s public natural resources are the common property of all the people, including generations yet to come. As trustee of these resources, the Commonwealth shall conserve and maintain them for the benefit of all the people.”

That seems pretty clear to me. As an agency of the Commonwealth, as one of the trustees of these resources, the people have a right to expect that you’ll act to protect, conserve, and maintain clean air.

The proposed regulation is balanced. It grants what seems an appropriate time line for the installation of alternative ways for drivers to maintain comfort in truck cabs during rest periods. With the rising costs of fuel, installation of alternative systems is cost effective.

I don’t expect that this regulation alone will solve all the problems of fine particulates in our air. It may not even bring us into attainment with Federal air quality standards, but I do believe it will be helpful, that it has the potential to make a difference, and that it will not be unfair or burdensome to drivers.

Exposure to high levels of PM2.5 impacts the quality of life of people who suffer from respiratory ailments and reduces their life expectancy. Children who are exposed to it may never develop normal lung capacity, with permanent impacts on their lives.

Our Constitution asserts that clean air is a right of the people and promises us that the Commonwealth will protect it. From a religious and ethical perspective, we have a responsibility to be good stewards of the Earth’s resources, including the very air be breathe.

The proposed regulation would be a step toward fulfilling the role of trustee for public natural resources. I urge your adoption of it.

Thank you.

Good afternoon. My name is Duane Fickeisen and I am one of the pastors of the Unitarian Universalists of the Cumberland Valley in Boiling Springs. I also serve on the board of the Clean Air Board of Central Pennsylvania. I speak as a religious leader in support of the proposed regulation of idling.
Thank you for the efforts you have made to craft an effective and reasonable proposed regulation. I feel it is an excellent example of citizens and government working together to improve the quality of life in our state.
I am concerned about the health impacts of PM2.5 in the air we breathe. Members of the congregation I serve reside throughout the Cumberland Valley. Several of them suffer from respiratory and cardiac ailments. Some of them have expressed to me the belief that high PM2.5 levels impact their breathing. They have noticed that they are especially affected on days when the Air Quality Index is high, primarily due to fine particulates. This continues to have serious effects on the quality of their lives.
While the Carlisle/Harrisburg area is among the worst in the nation for fine particulate air pollution, other parts of Pennsylvania — especially the Pittsburgh, Allentown, and Philadelphia areas — also experience unhealthy levels of PM2.5.
It is my understanding of the medical research on effects of exposure to fine particulates that no safe level has been established, that even relatively small reductions in exposure have been estimated to provide significant health benefits, and that even short-term exposure to high concentrations increases the risk of heart attack. Further, I understand that exposure to fine particulates causes abnormal lung development in children that is irreversible.
I am especially concerned about the people who are frequently exposed to high concentrations of PM2.5 for long periods, including those who spend much of their time near diesel exhaust sources — on highways, at or near warehouses and trucking facilities, in or near school busses, for example. Professional drivers, highway construction crews, police and other emergency responders, and school children seem particularly vulnerable as does anyone who lives or works within 1000 feet of a highway, truck route, or trucking facility.
My religion teaches that we have a compelling responsibility to care for every person in our community — to practice a radical hospitality that cares for all. We affirm the inherent worth and dignity of every person. We also teach, along with virtually all of the world’s religions, that
we are called to be effective stewards of the Earth. Unitarian Universalists are called to respect the interdependent web of all existence. Whether you arrive at the call to stewardship from an understanding that God created it, saw that it was good, and charged us to care for it; from the belief that we owe it to future generations to protect the planet; or from the standpoint that it just makes sense not to foul our own nest, I think most people would agree that we should take our stewardship seriously.
Not only that, but the Commonwealth’s Constitution includes a declaration of rights, which includes this language in Section 27, titled Natural Resources and the Public Estate:
“The people have a right to clean air, pure water, and to the preservation of the natural, scenic, historic and esthetic values of the environment. Pennsylvania’s public natural resources are the common property of all the people, including generations yet to come. As trustee of these resources, the Commonwealth shall conserve and maintain them for the benefit of all the people.”
That seems pretty clear to me. As an agency of the Commonwealth, as one of the trustees of these resources, the people have a right to expect that you’ll act to protect, conserve, and maintain clean air.
The proposed regulation is balanced. It grants what seems an appropriate time line for the installation of alternative ways for drivers to maintain comfort in truck cabs during rest periods. With the rising costs of fuel, installation of alternative systems is cost effective.
I don’t expect that this regulation alone will solve all the problems of fine particulates in our air. It may not even bring us into attainment with Federal air quality standards, but I do believe it will be helpful, that it has the potential to make a difference, and that it will not be unfair or burdensome to drivers.
Exposure to high levels of PM2.5 impacts the quality of life of people who suffer from respiratory ailments and reduces their life expectancy. Children who are exposed to it may never develop normal lung capacity, with permanent impacts on their lives.
Our Constitution asserts that clean air is a right of the people and promises us that the Commonwealth will protect it. From a religious and ethical perspective, we have a responsibility to be good stewards of the Earth’s resources, including the very air be breathe.
The proposed regulation would be a step toward fulfilling the role of trustee for public natural resources. I urge your adoption of it.
Thank you.
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