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To: The Jefferson Review

From: Clay Smith

Date: 31 January, 2002

Subject: Comments on Air Quality and the VET

Several weeks ago I offered to provide comments that might help your stop the VET efforts. A few days ago I received your latest e-mail issue of Jefferson Review with several commentaries on the VET.

In addition, I explored the State of Kentucky's web site and Jefferson County's air

pollution control district's site www.apcd.org . In addition, the 1996 State of Kentucky's Environmental Series report "Air Quality - August 1996" was downloaded and reviewed. This was the latest report located. Although this is quite limited information here are my comments, and I hope they might be of some assistance.

1. There seem to be two specific air quality issues that are related to vehicle emissions: ozone and carbon monoxide. Since Jefferson county and Northern Kentucky appear to be well in compliance with the 9 ppm NAAQS standard (p 8 of 1996 report), I'm at some loss for words - but my comments on CO follow.

Ozone is another problem, though it also appears (p 4 of 1996 report) that Jefferson County and Northern Kentucky also complied with the 0.12 ppm NAAQS standard. Of course there is the political issue that programs that employ public employees, generate revenues and vested stake holders, tend to perpetuate beyond their initial justification. The information on your web site on the costs and the allowance of pollution credits is a frightening demonstration of this. In fact, that is why I'm taking time to comment.

2. Vehicle Emissions for Carbon Monoxide

I have attached two Acrobat pdf files that are part of a set that I am developing that make several points. The entire argument is a bit more complex, but the data support the following:

a. Modern, on-board, emissions control technology have largely eliminated the

contributions vehicles to the ambient air quality problems. Auto manufacturers - with some prodding - have solved the problem.

b. The remaining significant factors are local meteorology and driving patterns (holidays, weekends, versus work days).

Once emissions have been reduced to some appropriately low level to achieve

reasonable air quality objectives, then there may still a small probability for a "bad air" day. In Denver this now occurs only during severe, and prolonged inversion conditions.

It make no sense to have an expensive program to prevent such occasional excursions, and even the government can not control your local weather.

Explanation of the Charts

The data are for the Denver CAMP air quality monitoring station in the metro downtown area. The six month periods from Oct 1965 - Mar 1966, and Oct 1996 - Mar 1996 cover the [CO] season. The 8 hour average maximum value [CO] for each day were sorted in ascending order. The [CO] concentration (ppm) was then plotted against the rank order for each point. This is called the "cumulative distribution function" of the data set. An analytical expression is then developed to fit these data. Using four or five normal ("student") curves to fit these data does so very well with a standard error estimate of about 1.5%. The results are shown on the attached charts. Analyses of intermediate years show the trend of improvement. I am in the process of doing this for other periods and for totally other reasons than air quality.

If a few years of daily 8 hour average data for Jefferson County were available, we could see if similar statistical populations of [CO] levels existed for your area. The method needs the data for every day - not just the bad days.

3. Ozone

Ozone is a different problem with different causes. Ozone is formed by a series of photochemical reactions involving NOx, VOC's and sunlight. Modern vehicle emissions control technology basically controls NOx and VOC emissions from vehicles as well as the carbon monoxide [CO].

The ozone season is generally the opposite time of the year from the carbon monoxide season. Ironically, the oxy fuels programs for vehicle emissions were intended to reduce [CO], but actually increase the VOC's from motor fuel by increasing vaporization of the light hydrocarbons, unless the fuel is reformulated to avoid this.

I believe that the VET will be largely ineffective for ozone control because NOx and VOC's are produced by many other sources - but you should eliminate summer oxy fuels use to reduce ozone.

Good luck!

See also:  Is Big Brother Smelling You? http://www.foxnews.com/story/0,2933,44478,00.html

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