DEKRA America Public Hearing Houston, February 2, 2 010

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## Public Hearings for Reconsideration of the 2008 Nat ional Ambient Air Quality Standards for Ozone

Houston: Tuesday, February 2, 2010. Hilton Houston Hobby Airport, Moody Ballroom (located on the ground floor), 8181 Airport Boulevard, Houston, Texas 77061. Telephone: 713–645–3000.



### Presenter: Nguvi Kahiha Business Development Manager DEKRA America, Inc. 3901 Roswell Road Suite 120 30062 Marietta, Georgia, USA Office: +1 (770) 971- 3788 ext. 224 nguvi.kahiha@emissioncheck.comDEKRA America Public Hearing Houston, February 2, 2 010

2 Good Morning Ladies and Gentlemen

, First of all, I would like to start by thanking The Environmental Protection Agency for giving us the opportunity to express our opinion and comments about the proposed revision of the National Ambient Air Quali ty Standards for Ground-level Ozone. As a member of the Inspection and Maintenanc e (I/M) Industry, and on behalf of CITA, the International Motor Vehicle Inspection Co mmittee, DEKRA America supports the new proposed revision of Air Quality Standards. We believe that these new regulations are necessary to help insure a cleaner and safer environment for our future

and the future of our children. DEKRA has been in t he inspection business for almost 100 years servicing people and the environment around t he world. We understand the effects and consequences that ground level ozone has on peo ple and the environment. Literature

and scientific research states that one of the main emitters of pollutant gas such as Nitrogen Oxides or NOx and Volatile Organic Compoun ds or VOC’s are vehicles. As a result, the commitment of the I/M Industry lies not solely in making cars safer, but also

cleaner. The I/M Industry has rolled out very effective and innovative programs to curve the output of vehicle emission. For example the I/M program in the Atlanta area tests on average 2.3 million cars a year. The projected emis sions reduction in 2009 for metro Atlanta alone was 316 tons of carbon monoxides, 19 tons of VOCs (volatile organic compounds) and 19 tons of NOx per day. 1 Georgia’s management contractor, Georgia’s Clean Air Force has identified and repaired more th an 1.5 million heavy polluting vehicles.” As you may imagine, similar success stor ies can be found in many other metropolitan regions where vehicle emissions is an ongoing health hazard to the citizens

of these areas. Besides, the conventional I/M programs that reduce emissions, there are abundant other initiatives to gear America into a cleaner fu ture. These initiatives include RideShare programs, Public Relations campaigns to infor m the public on air issues and educational programs on proper vehicle maintenance. Air Check Texas, the program administrator in Texas, introduced a program titled Drive a Clean Machine that provides assistance to remove 10 years or older vehicles wit h failed emission tests from Texas

1 Information provided by Pam Earl, Program Manager of the Mobile & Area Sources Program GA EPADEKRA America Public Hearing Houston, February 2, 2 010

3 roadways. 2 This self-funded program gives subsidies to eligib le low income vehicle

owners which enables them to move into newer and cl eaner vehicles. The moving public may argue that some of these prog rams are inconvenient due

to the cost and time associated with emission testi ng. Even this argument was taken into consideration by the I/M Industry: Technology innov ations, such as OBDII testing and other alternative programs help reduce motorist inc onvenience and helping to keep costs

down. No doubt, the revision of the National Ambient Air Quality Standards for Ground-level Ozone will create new challenges for p rogram administrators. One may ask how practical new or adjusted programs are to meet the new standards. As mentioned earlier, the I/M Industry has a proven track record on how to implement programs efficiently, cost effectively and quickly; therefor e it can be argued that the industry has the competence and experiences to successfully tack le these challenges. An example of meeting the new standards could be to expand existi ng emission test programs into suburban areas, where the moving public heavily com mutes into the regions with high pollution rates. Another, more essential example is the integration of diesel operated heavy trucks into already existing federal annual s afety inspection programs. Heavy trucks make up the majority long-distance hig hway user, driving more than 120 thousand miles a year. Trucks use about 14 bill ion gallons of gasoline and 23 billion gallons of diesel fuel annually. Heavy trucks alone , excluding smaller commercial vehicles, are responsible for about 3 million tons of NOx emissions annually. 3 The influx

of commercial vehicles in metro areas causes an inc rease of emission pollution. According to a study by Oak Ridge National Laborato ry, about 25 thousand trucks drive through Knoxville, TN daily and contribute 40% of N Ox emissions in that area. 4 There are new regulations for new trucks to meet certain emission standards and several states have implemented annual emission inspection program s to oversee and control emission output caused by commercial vehicles. Nevertheless, in order to meet the new National Ambient Air Quality Standards for Ground-level Ozon e, a nationwide test program

2 http://www.tceq.state.tx.us/implementation/air/mob ilesource/vim/driveclean.html 3 “Estimation of Fuel Use by Idling Commercial Truck s”, TRB 85 th Annual Meeting Washington, DC 01/26/2006 4 “Truck Emission”; ACF News Source; www.acfnewsourc e.org/science/truck_emissions.htmlDEKRA America Public Hearing Houston, February 2, 2 010

4 should be rolled out, maybe in combination with the FMCSA periodic safety inspection program section 396, 17 though 23. To summarize, the I/M Industry has proven to be the most effective way to reduce ground level ozone. Its programs are a vital source to identify and repair gross polluting vehicles. Technology innovations and inclusion of h eavy truck testing could be a logical way to help further reduce harmful pollutants being added to our atmosphere. In conclusion, there are significant points of the proposed revision that has direct impact on the economy. Firstly, in metro Atlanta al one, inspection providers employ more than 2500 certified inspectors and this number would increase if the program is expanded into new areas and/or with the addition of heavy diesel vehicle testing. Most of the programs service providers are small businesses that use this program to create employment opportunities, and economic growth. Duri ng the state of the Union address on January 27, 2010, President Barak Obama made cle ar how important small business success is to the U.S. economy: “We should start wh ere most new jobs do –- in small businesses; when an entrepreneur takes a chance on a dream, or a worker decides it's time she became her own boss. Through sheer grit and de termination, these companies have weathered the recession and they're ready to grow.” 5 The proposed revision would give many small businesses the opportunity to expand and grow. Secondly, tougher policies on air pollution force o ther industries to utilize cleaner energy. Increased investments into clean energy wou ld lead to more innovations, advancement in technology and a cleaner environment but also to economic strength. Referencing again President Obama, he stated the ef fect of clean energy on the economy

as follows: “because the nation that leads the clea n energy economy will be the nation that leads the global economy. And America must be that nation.” 6

On behalf of DEKRA America, CITA and the Inspection and Maintenance Industry, I would like to thank you for your time a nd the opportunities that lie ahead.

5 http://www.whitehouse.gov/the-press-office/remarks -president-state-union-address

6 http://www.whitehouse.gov/the-press-office/remarks -president-state-union-address