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Larry Brown Testimony to end Vehicle Emission Testing in Northern Kentucky

  I am writing in support to end Vehicle Emission Testing in Boone, Kenton and Campbell counties that was ordered by the governor under 401 KAR 65:011E that will repeal 401 KAR 65:010.  Tailpipe testing is not needed and is a waste of consumer money, bad public policy and ineffective method of cleaning the air. It was borne from an EPA regulatory system that valued political science over real science. Like the EPA’s mandated gasoline additive MTBE, a cancer causing agent, it is time to end all forms of consumer vehicle emission testing.

    The following reasons are the basis of my opposition.

   First, the test is passed by over 98% of automobiles built after 1993 according to the Division of Air’s report. This represents over 84% of all vehicles tested.  Second, the EPA has concluded through studies that emission system deterioration rates for tested and non-tested areas are statistically very similar. Third, the National Academy of Sciences reported that the EPA computer models overstated air pollution reduction as much as 100%. There is no proof that testing removes any substantial amounts of pollution from the air. Fourth, the auto manufacturer is producing a durable, reliable, tamper resistant emission system that the consumer already is paying for to clean air. Fifth, the consumer currently is denied equal property rights that are afforded to corporation or stationary polluters in terms of emission credits. Most automobiles tested pass with substantial credits available, but are not given the same rights to hold, trade or sell them. Sixth, numerous studies have shown that future air quality improvements will be the result of technologies and fewer older cars on the roadways.   Seventh, the failure rates among low income and senior citizens’ vehicles puts a financial burden on these people without any assistance. Eight, the testing program does not remove or prevent the very small number of gross emitters from the roadways. Ninth, testing puts the burden on only a small percentage of vehicles that use the highways in this Metropolitan area. Ten, because of the numerous non-tested, non-reformulated gasoline area vehicles that transverse these 3 counties, much of the poor air quality may be caused by these vehicles. Until such time that actual proof can be supplied that Boone, Kenton and Campbell county vehicles are causing a substantial portion of these polluting elements, testing should not be reconsidered.  Eleven on August 26, 2004, President Bush issued an executive order specifically calling for agencies, including the EPA, that calls for “cooperative conservation” and to “take account” of the interest of local property owners and include them in the decision making “to the extent of the law”.  And Twelve, there are approximately 250 or fewer businesses affected by the new regulations versus over 186,000 auto consumers. Plus, the newer paint equipment is inexpensive and more profitable use of paint, resulting in the businesses recouping their expenditures. In addition, the consumer and local economy will regain both the loss of productivity, wages and the fee imposed by tailpipe testing.

   In summary, I am submitting the attached comments, research and corresponding articles supporting the above claims that was submitted to the Federal Register during the EPA public comment period on ending vehicle emission testing. Please accept both documents for consideration in support of ending vehicle emission testing in Boone, Kenton and Campbell counties.

    The citizens of Northern Kentucky have endured this worthless program for too long. By a substantial majority, citizens using simple common sense have known this program to be without merit, scientific foundation or substantial air quality improvements. Removing it will not lessen the public’s desire for clean air, but will acknowledge the fact that automobiles are clean and the consumer’s efforts have substantially improved our air. They see it every day; now they will know it.

Submitted

Larry Brown

Co Founder VETO the VET

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