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"Your Liberty is Our Interest"
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Jefferson Review |
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"Your Liberty is Our Interest" |
January 21, 2001 | |
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1. Air Pollution Control District Writes to Set Record Straight on VET Program’s Air Pollution Credits and 2. Stop The Vet Responds:
#1. Air Pollution Control District:
Rebecca Stutsman Public Information Officer
Dear editor:
#2 Stop the VET Responds:
Dear Ms. Stutsman,
I have reviewed your email letter regarding the article on the JeffersonReview.com website and I do have the following questions:
1) In your attempt to "clear up any confusion regarding the terms "emission reduction credits" and "SIP credits" you state the following: "This important environmental program, however, does not include the creation, trading, or sale of "VET pollution credits" to private industry and businesses located in Jefferson County." Are there (3) different kinds of "pollution credits"? (1) "emission reduction credits" (2) "SIP credits" (3) "VET reduction credits"
You state the following: "the District has an emissions reduction credit (ERC) banking program established by District Regulation 2.12. This program allows a company to "bank" ERCs that represent its emission reductions beyond those required by the SIP, federal regulations, or District regulations."
In regard to your statement above please answer the following:
2) Do the ERCs that you refer to have a cash value and are they allowed to be traded, sold or used to offset any emissions from any source within or outside of Jefferson County?
3) What are the names of the companies under your jurisdiction that participate in the ERC banking program?
4) What are the amounts and value of ERCs currently in inventory? (Please list these by company, amount and value.)
5) Have any of the ERCs in the banking program ever been sold or traded from one company to another (either within or outside of Jefferson County)? Again, what are the names of the companies and the amount and value of the ERCs sold or traded?
6) Has there been an audit of the use of SIP credits and is that available for public view?
The National Academy of Sciences (NAS) recently issued a report on inspection and maintenance programs (I/M or VET) which states the computer models which are used to calculate the SIP credits are inaccurate. Specifically the report states: "Independent and state sponsored evaluations of ongoing I/M programs have estimated that the emissions reductions attributable to these programs are from zero to about one-half of the reductions predicted by the models." Executive Summary page 2.
The NAS report states: "Testing clean cars does not provide any benefit; only repairing or removing high-emitting vehicles reduces fleet-wide emissions." Compliance and Enforcement section page 165.
The NAS report also states: "Vehicle emissions I/M programs are a comparatively burdensome environmental mandate for the public. As one of the only mandates that requires individuals to demonstrate compliance, I/M has not proved to be a particularly popular policy with the public or politicians." "....the owners of vehicles most in need of repairs are sometimes those least able to afford them. This lack of public acceptance presents an ongoing challenge to the design and implementation of an effective I/M program." Public Acceptance and Political Feasibility section page 168.
Your email letter dated August 23, 2000 states: "While newer vehicles are less likely to fail a VET test, our program continues to test these vehicles because of concerns for equity, consumer protection and federal credits." and "In addition, we receive more credits from EPA for testing newer model years in addition to older vehicles."
Regarding the statements above please answer the following:
7) Does the VET program in Jefferson County use the computer models which are referred to in the NAS report?
8) Your statement regarding the testing of "newer vehicles" clearly indicates that the EPA issues "pollution credits" to Jefferson County for testing newer vehicles. Are these "pollution credits" based solely on the vehicles that failed the test or do they include any vehicles that passed the test?
9) If "federal credits" are claimed for any vehicle that passes the test can you explain how a pollution reduction claim can be made on behalf of the citizens when no actual reduction was made?
10) As you may know, when a vehicle is purchased, included in the cost of the vehicle is the cost for design, engineering, manufacture and installation of the emissions reduction equipment which is on the vehicle. These costs are significant. Also, it is presumed that "credits" are claimed due to vehicles which fail and are required to be repaired at the owner’s expense. In addition the vehicle owner pays for the cost of the test. If credits are being claimed for vehicles that pass the test or for vehicles that have been repaired due to a failed test, do you believe those credits should belong to the individual who is responsible for the pollution reduction or should these credits be applied to the overall air quality in Jefferson County in an effort to remain in good standing with the EPA?
According to the Vehicle Emissions Testing 2000 Annual Report the program tested 289,066 autos and 124,117 light duty trucks for a total of 404,414 tests. The report indicates 14,568 autos and 8,275 light duty trucks failed the initial emissions test for a total of 22,843 failed. This represents a pass rate of 94.4% or 381,571 autos and light duty trucks passed the emissions test.
Considering the information above please answer the following questions:
11) What is the estimated total number of vehicles (auto and light duty trucks) being used in Jefferson County which are not registered in the county and therefore not subjected to VET testing?
12) How many of the 28,000 tons of emissions credits that you claim are attributed to the 22,843 vehicles (auto and light duty trucks) which failed the test?
13) Do you believe the elderly citizens of Jefferson County and the citizens who are less fortunate to be able to afford the purchase of a newer vehicle or make the expensive repairs to their older vehicle should carry the burden of "clean air" in Jefferson County and be treated as if they are criminals and/or major polluters of the air at the same time the business community continues to install drive through lanes and other pollution sources which foul the air without sanction?
Your most recent email states the following: "For an urban area, like Jefferson County, EPA will not approve a SIP relaxation; any loss of emission reductions from a specific SIP strategy must be offset by equivalent or greater emission reductions from a different control strategy added to the SIP."
Based on your statement quoted above please answer the following:
14) Are the "emission reductions" from VET testing used to offset any emissions from any other sources? Has the APCD of Jefferson County identified any industrial or commercial sources which could be reduced and used to offset the benefits that are claimed due to VET testing regardless of the cost to that source?
According to the VET 2000 annual report auto and light duty trucks vehicle model year 1990 and newer a total of 303,694 vehicles were tested. Of those 5,507 failed the test which indicates a failure rate of only approximately 1.8%. Considering these numbers it appears that $3,340,634.00 was paid to test these vehicles @ $11.00 per vehicle or $607 of testing cost to catch each failed vehicle. (Note: This amount does not include the costs of the citizen's time, fuel or other expenses required to comply with testing.)
Based on the information above, please answer the following:
15) Does the APCD of Jefferson County believe that this is an efficient use of the citizen’s time and money?
16) Why does the debate regarding the end of VET testing center around the issue of harm to further economic development versus the issue of clean air? Is clean air the goal or is economic development the goal?
17) The EPA currently is conducting a pilot program called "e-commute" in which a corporation can be issued pollution credits for allowing their employees to work via the internet from home. The vast majority of employees who could qualify to "e-commute" are generally driving newer less polluting vehicles. The credits which are issued can be used to offset other sources of real pollution or sold for cash. Do you agree with and/or support this program?
18) Do you believe the EPA has the authority to issue pollution credits which can be converted to cash? If so should these transactions be subject to audit and available to the public view?
19) The VET 2000 annual report indicates that the APCD of Jefferson County receives CMAQ (Congestion Mitigation and Air Quality) federal grant funding which is administered by the Kentucky Transportation Cabinet. The report explains that the CMAQ funds were used for "an additional five lane test center at Bowman Field..." and "CMAQ funds were used to offset all construction and implementation cost, and operational costs to the District for increased staff and work loads." Were the CMAQ funds used properly? Were the CMAQ funds used for any "congestion mitigation"? Has the APCD of Jefferson County ever been denied CMAQ funding due to it's use or abuse of this funding? Is an audit of use of CMAQ funds available for public view?
20) When will the new VET 2001 annual report be available?
As you can see, I do have some questions regarding VET testing and the use and accounting of pollution credits and I may have more questions in the future. However, for now I will look forward to your reply.
Thank you in advance for your help and cooperation. My hope is for citizens to be fully informed regarding the quest for clean air in Jefferson County. If you need any additional information please email me @ JRiley8609@msn.com .
Sincerely,
John Riley Member of Stop the VET
Mr. Riley: Thanks for writing and submitting additional questions about the VET program. I will have a response to your open records request within three days. Sincerely,
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