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Page 120 PREV PAGE TOP OF DOC Segment 2 Of 2 SUBMITTED STATEMENT OF AMERICAN TRUCKING ASSOCIATIONS, INC.
Mr. Chairman and Members of the Committee, the American Trucking Associations, Inc. (ATA) thanks you for the opportunity to submit our statement into the record for the May 8, 2002 hearing on Health Effects of Particulate Air Pollution: What Does the Science Say?
ATA is a united federation of motor carriers, state trucking associations, and national trucking conferences created to promote and protect the interests of the trucking industry. Its membership includes more than 2,000 trucking companies and industry suppliers of equipment and services. Directly and through its affiliated organizations, ATA encompasses over 34,000 companies and every type and class of motor carrier operation. As such, it effectively represents the interests of the trucking industry in the United States.
The trucking industry is committed to promoting a better environment for all Americans and is proud of its accomplishments in helping reduce particulate matter (PM) emissions. Between 1990 and 2000, our industry reduced PM emissions by 44 percent, going from 235 tons per year down to 131 tons per year.(see footnote 55) As the U.S. Environmental Protection Agency (EPA) implements its 2006/2007 Heavy-Duty Diesel Engine Rule regulating both diesel fuel and engines, further significant PM reductions will be recognized by the trucking industry. By 2010, overall PM emissions from trucks will be reduced to 54 tons and by 2020, the trucking industry will emit a mere 15 tons of PM, a 94 percent reduction over 1990 levels.(see footnote 56) The trucking industry's goal, however, does not stop there. EPA projects that the trucking industry will emit a mere 8 tons of particulate matter in the year 2030.(see footnote 57)
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The trucking industry has done its part, and will continue to do its part, in curbing PM emissions. However, it is imperative for regulators to begin focusing on the worst emitters of PM; namely locomotives, marine vessels, stationary sources, and nonroad sources (such as construction and agricultural equipment). EPA must address nonroad sources of PM emissions by proposing its Nonroad Rule later this year. From an equitable perspective, ATA challenges EPA to do the right thing and impose comparable fuel and emission standards on nonroad sources. A quick side-by-side comparison between on-road and nonroad PM emissions shows a wide disparity between what trucking is doing to reduce PM emissions and what non-road sources have yet to do (See Attachment A). For example, projected annual emissions of PM from heavy-duty nonroad sources in 2010, 2015, and 2020 are estimated to be 195, 175, and 170 tons respectively while heavy-duty on-road trucks will emit 54, 28, and 15 tons respectively.
Other sources of PM, such as marine diesel engines and their fuels, account for upwards of 3 percent of annual U.S. mobile source contributions of PM emissions yet they still remain unregulated at this time.(see footnote 58) Locomotives and stationary sources contribute substantial amounts of PM and should be regulated to maximize the drastic reductions already realized in national PM emission levels.
Air quality in the United States has improved significantly over the past decade, even though the economy has more than doubled in size during the same period. The trucking industry has played a significant role in achieving these environmental and economic accomplishments and is proud of its record. Our industry's commitment to clean air is not only longstanding, but also ongoing. However, more can be done to decrease sources of PM emissions from all sources. Federal regulators must begin to regulate more equitably across all industries. To do otherwise leads to gross economic inequities and a failure on behalf of EPA to regulate even-handedly.
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(Footnote 55 return)
U.S. Environmental Protection Agency, Regulatory Impact Analysis: Control of Emissions of Air Pollution from Highway Heavy-Duty Engines (July 2000); Draft Technical Support Document: Control of Emissions of Hazardous Air Pollutants from Motor Vehicles and Motor Vehicle Fuels (July 2000); Draft Regulatory Impact Analysis for the Proposed Heavy-Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements Rule (May 2000).
(Footnote 56 return)
(Footnote 57 return)
(Footnote 58 return)
Daily Report for Executives, Marine Diesel Engine Manufacturers to Cut Ox, Particulate Emissions Under Proposal (May 3, 2002), at A50.