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Larry Brown Comments on Ozone Maintenance Plan For Northern Kentucky

  This is a written submission regarding the Ozone Maintenance Plan SIP Revision for Boone, Kenton and Campbell counties in the Cincinnati-Hamilton Ozone Maintenance area and the new regulations being put forth by the Department for Environmental Protection. 

   My name is Larry Brown, 8202 Adella Florence Ky 41042 and Co founder of VETO the V.E.T.  I am pleased that we are attempting to end vehicle emission testing.  The marketplace has responded to the 1990 Clean Air Act by producing durable emission systems that allow 99% of cars built since 1994 to pass the current test. The marketplace, not cookie cutter EPA approaches, is the future of continued improvements in air quality.

  The Air Division has identified less than 100 potential users of High Volume, Low Pressure (HVLP) sprayers in the three counties of Boone, Kenton and Campbell.  The estimated cost of these sprayers is from a low of $50.00 to less than $ 500.00.  Furthermore, it is believed these sprayers use substantially less paint and waste than the sprayers being replaced. This means that users will quickly recoup their expense from reduced paint cost.

  It is our understanding that references to “properly trained” contained in the regulations will mean that the user has read and agrees to use the HVLP sprayer according to manufacturer’s suggested instructions.  Documentation verifying compliance is a simple letter from the owner/user that all persons have read and are using the equipment in accordance with instructions provided by the manufacturer.

    I believe the regulations to be fair and substantially less harmful to the local economy.  The average Northern Kentucky citizen earns $ 30,000 per year or $ 14.40 per hour. The average testing time from work or other economic activities is 2 hours.  That initially works out to $ 48.80 lost in the local economy ($ 20 + $ 28.80). Using a simple one and half trickle down effect, you can safely add to that lost economic cost , it cost Northern Kentucky over $ 6,500,000 per year ($ 48.80x 1.50% x 90,000 testers = $ 6,588,000).

    What is the possible economic cost to HVLP sprayer users? The initial cost, estimated at $270 per operator and coupled with the same economic effects of 150%, we can calculate the cost at $ 30,375. (75 x $ 270 x 1.50% = $ 30,375). This is not a reoccurring expense and will be recouped in lower paint expenditures.

     Our choices appear obvious.  Cleaning up VOC s using HVLP sprayers that affect 75 businesses verses VET that affects 90,000 automobile owners annually, one that cost the local economy $ 6,500,000 per year verse a $30,375 one time, and we can knowingly achieve better air quality.  The VET program, based on computer modeling and discredited by the National Academy of Sciences report, will not remove any additional emissions from our air, the use of HVLP sprayers will.

    As an additional concern, one of the regulations requires of cloth, paper or absorbent applicators moistened with certain VOC solvents be kept in nonabsorbent, non-leaking containers and kept closed.  The city of Florence recently has a large structure fire in which it is believed that solvent soaked rags, in a plastic (nonabsorbent, non-leaking) bags became over heated or self combusted into flames from a heat source close by.  If the HVLP sprayer user is using a self-contained and air filtered enclosure for spraying and drying, would it not be possible that these items would be safely allowed to dry with the car, or item that was just painted or coated?  It would appear no additional VOC would be escaping in the air.  To follow the regulation, the cloth or paper would or could maintain the VOC moisture indefinitively or require a special deposing method that may put the HVLP user at risk for fire. 

    Thank you,

Larry Brown

Submitted 12/22/04   

John Riley’s comments:

Larry Brown has presented an excellent point of view on the VET program issue in Northern Kentucky.  (Refer to Larry Brown VETSIP12-22-04response.doc which as been presented.) This is a very well researched and well thought out plan to end VET testing in Northern Kentucky.  One could only hope, and we all can insist, that the State of Kentucky and the EPA do the same.  "Cookie cutter" approaches to problems can never replace genuine thought and honest research.  With people like Larry Brown we can go a long way to doing just that.  My hat is off to him for the many, many hours, days, months and now years that he has been on top of this important issue.

The people in Northern Kentucky and beyond owe Larry Brown, and the many people who have supported him in these efforts, much gratitude and respect for his perseverance and the unselfish use of his time to care as much as he does about his fellow citizens and for clean air in Northern Kentucky!   It is my sincere hope that the people in both the State and Federal government positions take seriously the issues regarding VET testing and do everything possible to abandon this inefficient, burdensome and unproductive program so that Northern Kentucky can move in a positive direction in the quest for clean air.

There is also abundant research on the use of reformulated fuels that warrants a serious look possibly ending its use in the Commonwealth of Kentucky.  It appears there is strong evidence that the use of reformulated fuel is hindering the clean air goals as well and at a cost to the citizens that is high and unnecessary.  Several other states, and most notable is the State of California, have researched this issue and have requested waivers on the use of oxygenated fuels because of the high cost and most importantly the negative effect it has on air quality.

Citizen involvement works and Larry Brown is just another very good example of that.  The heavy hand of government with ill conceived ideas and programs based on flimsy research doesn't work. The VET program and the use of reformulated fuels are programs that need to end.  These programs unreasonably burden the citizens and accomplish little, and may in fact aggravate the problem of solving air quality issues.

Thank you to Larry Brown for all he has done and will do in the future on this issue.

Furthermore, I request this letter to be entered into the record on the question of air quality and possible SIP revision in Northern Kentucky.  If you need any additional information please let me know if there is anything I can do to help you in this important decision.

Sincerely,

John Riley

Concerned Citizen,

Co-Founder and Member of Stop the VET

Louisville/Jefferson County KY

955 Chatman Lane

Taylorsville, KY 40071

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