(Green House Gas Vehicle Emission Standards)”
by Jon Hinck, NRCM staff attorney
Chairman Scott and members of the Board of Environmental Protection, my name is Jon Hinck and I am testifying here on behalf of the Natural Resources Council of Maine. NRCM is an environmental advocacy group whose mission is to protect, preserve and restore the Maine environment now and for future generations.
It is precisely our concern for the future of the Maine environment and the health and well-being of our families that leads us to urge the Board to vote to adopt Maine’s version of California’s green house gas emission standards for new motor vehicles. This would be a meaningful step toward addressing global warming pollution and would also preserve the progress that Maine has made as one of seven clean car states.
Cars and trucks continue to be the State’s largest source of many air pollutants, generating smog, soot, an array of toxics and global warming pollution. But the air is already cleaner today than it would be if the State had not opted into the California Low Emission Vehicle Program (“Cal LEV”) over 10 years ago. Section 177 of the Clean Air Act (CAA) allows states to adopt motor vehicle emissions standards stronger than federal standards, but only standards that are: (1) identical to those in California; and (2) adopted at least two years before commencement of the model year to which they apply. Maine has met these conditions and kept pace with the Cal LEV standards to date. As a result we have been realizing the benefits of putting the cleanest vehicles available on our roads and highways.
To date the LEV standards have successfully helped to reduce key conventional air pollution-from light-duty cars and trucks. This includes reductions of ground-level ozone (or smog) and certain air toxics. Smog, which forms from emissions of nitrogen oxides and volatile organic compounds, can lead to asthma, bronchitis, increased susceptibility to bacterial infections, and other respiratory problems. Cancer causing toxic air pollutants such as benzene, formaldehyde, 1,3-butadiene and acetaldehyde also threaten the health of our state’s residents.
Effective as the earlier standards have been, they have not regulated greenhouse gas emissions. The 1.1 million vehicles on Maine’s roads cause nearly 40% of the global warming pollution generated in Maine. The proposed rules establish Greenhouse Gas (GHG) emission targets for passenger cars, light-duty trucks, and medium duty vehicles. The standards target emission of carbon dioxide (CO2), along with methane (CH4), and nitrous oxides (N2O), and hydrofluorocarbons (HFC).
The GHG vehicle standards apply to emissions from the following sources:
1. Carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O) emissions resulting directly from operation of the vehicle,
2. CO2 emissions resulting from operating the air conditioning system (indirect AC emissions),
3. Refrigerant emissions (HFC) from the air conditioning system due to either leakage, losses during recharging, sudden releases due to accidents, or release from vehicle scrapping at end of life (direct AC emissions), and
4. Upstream emissions associated from production of the fuel used by the vehicle.
Reduction of all such emissions will reduce global warming impacts including adverse effects on human health and the economy.
The new regulation would gradually phase in standards that can be met with available car technology at a no cost to Maine drivers when the cost of gasoline is factored in to the equation. Some examples of near-term technology that are expected to be in use prior to 2012 are:
• Cam phasing;
• Variable valve lift;
• Turbo and Super-charging;
• Cylinder deactivation
• Gasoline direct injection stoichiometric;
• Variable compression ratio;
• 6 speed transmissions;
• Continuously variable transmissions;
• Aggressive transmission shift logic; and
• Variable displacement air conditioning compressor
Some examples of mid-term technology expected to be available prior to 2016 are:
• Camless valve actuation;
• Gasoline direct injection lean burn;
• Gasoline homogeneous compression ignition;
• Electric water pump
• 42 volt integrated starter generator; and
• Diesel high speed direct injection
We can also anticipate moderate and advanced hybrid electric vehicles will be widely available after 2015 along with advanced multi-mode diesel vehicles.
Despite significant public support, we expect that the auto industry will oppose these regulations. The car makers reflexively oppose all mobile source clean air initiatives with generalized claims that pollution control will damage the economy, reduce employment and harm our way of life. In 1970, Lee Iacocca, then VP of the Ford Motor Company, famously predicted that the Clean Air Act could “prevent continued production of automobiles” and labeled it “a threat to the entire American economy and to every person in America.” (Statement by L.A. Iacocca, Executive Vice President, Ford Motor Company, Sept. 9, 1970.)
Of course, the car makers prospered under the Clean Air Act, that is, until Ford and the other American makers were hurt by their failure to make more efficient cars. Time and time again we see that new technologies developed in response to pollution control requirements quickly reduce compliance costs, generate savings for consumers and new profits for car manufacturers. This will be the case again because these rules provide for sound motor vehicle technology and reliable transportation, even as it reduces global warming pollution.
At this stage, Maine is presented with a choice of continuing progress toward cleaner cars or backsliding toward dirtier air and increased global warming pollution. This is an easy choice. People in Maine should continue to have access to the same clean car technology that is improving motor vehicle emissions in California and six Northeast states. Cleaner air, less global warming pollution, a net savings to Mainers and no impact on the full range of consumer choice. This should happen.
Thank you for the opportunity to testify today.
