UNITED STATES OF AMERICA
            ENVIRONMENTAL PROTECTION AGENCY
                        1717 Arch  Street,  50th Floor
                        Philadelphia,  Pennsylvania
                        Tuesday, November 2, 1999
                        10:00  a.m.
CONTROL  OF  EMISSIONS OF AIR
POLLUTION  FROM 2004 AND LATER
MODEL YEAR  HEAVY-DUTY HIGHWAY
ENGINES  AND VEHICLES;
REVISION OF LIGHT-DUTY TRUCK
DEFINITION
NO- A-93-32
PRESENT:       MARGO OGE
               CHET FRANCE
               JUDY KATZ
               MICHAEL HOROWITZ
               ROB FRENCH
REPORTED  BY:   BERNADETTE BLACK,  RMR,  Notary Public
               LISA C. BRADLEY,  RPR, Notary Public
           VINCENT VARALLO ASSOCIATES,  INC.
          Registered Professional  Reporters
                  Eleven  Penn  Center
             1835 Market  Street,  Suite 600
                Philadelphia,  PA 19103
                     (215) 561-2220
                   Vincent Varallo Associates, Inc.

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                           LAWYER'S NOTES
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INDEX
Opening Statements 	
Jed Mandel, Engine Manufacturers Association.
William Becker, STAPPA/ALAPCO 	
Walter Tsou, M.D. , Citizen 	
Joseph Otis Minott 	
Richard Kassel, Natural Resources Defense
Council 	
Richard Breeze Citizen 	
Beth Osteunski, Citizen 	
Blake Early, American Lung Association 	
Greg Dana, The Alliance of Automobile
Manufacturers 	
Sam Boykin Citizen 	
Maria Bechis, Bucks County Sierra Club 	
Meggy Bechis Citizen 	
Beth McConnell, PennPIRG 	
Kathleen Kerdei, Citizen 	
Kitty Campbell Citizen 	

Patrick Charbonneau, NAVISTAR Transportation
Corp 	
Rrnrp Bprtelsen, MECA 	
Mike Carter, California Air Resources Board..
Coralie Coooer, NESCAUM 	

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. 104
. 107
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. 124
133

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 2   INDEX (Cont'd)

 3   Julie Becker, Women's Health  and  Environmental
    Network	 147
 4
    Gina Porreco, Clean Air Network	 149
 5
    Angie Farleigh, U.S. PIRG	 156
 6
    Kevin Stewart, PA American  Lung Association... 160
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    Emily Bertram, Nat'l Environmental  Trust  DE... 167
 8
    John Duerr, Detroit Diesel  Corp	 172
 9
    Alan Schaeffer, American Trucking
10   Association	 179

11   Bob Jorgensen, Cummins Engines	 198

12   Jonathon Sinker, Nat'l Environmental  Trust
    Pennsylvania	 202
13
    Britta Ipri,  Clear the Air  Campaign	 206
14
    Nancy Brockman, Wyncote Audubon Society	 209
15
    Valerie Sowell, Citizen	 221
16
    Jeff Harden,  Citizen	 223
17
    Jason Rash, PA Clean Cities  Program	 225
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    Natasha Ernst, Low-income housing activist.... 227
19
    Ami Doshie, NJ PIRG	 230
20
    Ajahi Harris, Citizen	 234
21
    Dennis Winters, De Valley Transit Users
22   Group	 236

23   Abram Haupt,  Citizen	 238

24

25                          -  -


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 2                   PROCEEDINGS




 3               MS. OGE:  Good morning.  On behalf  of




    Environmental Protection Agency, I want to  thank  you




    for coming and welcome all of you to this hearing.




                Before  I give you some brief  remarks,  I




    would like to introduce Judy Katz, who is sitting  on




    my left.  She is with our office here in




    Philadelphia, and she will formally welcome  us  into




10   this area.




11               Judy.




12               MS. KATZ:  Good morning.  I would  like




13   to take this opportunity to welcome everybody  to




14   Philadelphia.  This  is an appropriate place  for a




15   public hearing on a  rule that will reduce emissions




16   from heavy-duty trucks and large sport - utility




17   vehicles and produce cleaner diesel fuel  because




18   this rule is going  to result in significant




19   reductions in emission of nitrogen oxide  and




20   particulates.




21               As you  probably know, nitrogen  oxide  is




22   an ozone precursor.  And ozone is a pollutant which




23   causes smog, which  creates respiratory problems,



24   asthma attacks in people.




25               Philadelphia has not yet attained  the






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                     Opening Statements




    one-hour ozone standard, which has been  in effect




    for many years and which has been attained in much




    of the rest of the country.  In fact, Philadelphia




    is currently classified as a severe non-attainment




    area for the one-hour ozone standard.




                The on-highway, heavy-duty category  of




 8  vehicles accounts for about 15 percent of the




 9  national nitrogen oxide emissions in this country.




10  Today's proposal will dramatically cut the amount of




11  pollution from this source.




12              As you also probably know, EPA issued a




13  new ozone standard, the eight-hour standard, in




14  1997.  That is now going through some court




15  challenges, but we have reason to believe that when




16  EPA resolves the legal  issues and moves  on to the




17  implementation of the eight-hour standard, which is




18  more protective of human health, the scope of the




19  non-attainment problem  in  the Philadelphia area  will




20  be even greater than it is now.




21              Particulate matter from heavy-duty




22  diesels are also a major human health concern.




23  Exposure to this kind of pollution causes cancer




24  risks and causes premature deaths.  And  particulates




25  are important matters of concern, particularly in






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                     Opening Statements




    cities like Philadelphia.



                So there is no doubt that we  in



    Philadelphia,  as in many places in this country,




    need this rule.




                The rule will be the first step  of  a




    two-step process to reduce emissions from on road,




    heavy-duty motor vehicles.




                The rule piggybacks on EPA's  recent Tier




10  2 strategy, which proposes tougher tailpipe  controls




11  for passenger cars and smaller trucks and sport-




12  utility vehicles to start in the year 2004.




13              Today's proposal serves to level the




14  playing field with respect to the largest trucks  and




15  super-large SUVs that are just now being  introduced




16  into the marketplace.  The rule will close the




17  loophole that excludes those largest vehicles from




18  the controls outlined in the Tier 2 proposal.




19              Today's proposal would require cutting




20  emissions from heavy-duty trucks and the  very




21  largest sport-utility vehicles, those over 8500




22  pounds, beginning in the Model Year 2004.




23              In the second phase of our strategy,  EPA




24  plans to propose later this year or early next  year




25  an even more stringent standard for heavy-duty






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    trucks,  which could take effect as early as 2007.




                The second phase will also include a




    proposal to reduce the sulfur content in diesel fuel




    to enable new emission control technologies on




    heavy-duty trucks.  These will mirror the proposed




    sulfur reduction in gasoline under the Tier 2




    proposal.




                So with this, I would like to thank you




10  for coming to offer testimony today on this




11  proposal.  And we are anxious to hear what you have




12  to say on the new rules.




13              MS. OGE:  Okay, Judy.  Thank you.




14              My name is Margo Oge.  I am director  of




15  the Office of Mobile Sources for EPA, and I will  be




16  serving as the presiding officer for today's




17  hearing.




18              I am glad to be back in Philadelphia.




19  We were here a few months ago to have our first




20  public hearing on the Tier 2 proposal.




21              Today we will hear testimony on the




22  proposal for cleaner heavy-duty vehicles, both




23  gasoline and diesel.  We believe that the proposal




24  that we are going to be hearing comments on today is




25  a very significant step towards helping us in






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                     Opening Statements




    obtaining cleaner air for this country.



                The proposal in today's hearing was




    signed by the administrator Kevin Browner and




    announced by the president October 6th.  EPA's




    intention to hold this hearing was filed in the




    "Federal Registrar" on Friday, October 22nd, and




    the proposal was published in the "Federal




    Registrar" on October 29th.




10              Heavy-duty vehicles, both gasoline and




11  diesel, with a gross vehicle rate greater than 8,500




12  is the subject of today's hearing.  This category is




13  very diverse and includes large commercial trucks,  a




14  large version of full-size pick-up trucks, passenger




15  vans and the largest sport-utility vehicles.




16              Vehicles weighing up to 8500 pounds will




17  be covered under the emission standards that EPA




18  propose in May.  And we had our first hearing here.




19  We call those standards Tier 2 standards, and the




20  Administration is planning to finalize those




21  standards by the end of the year.




22              Heavy-duty trucks contribute to the




23  annual NOx emission inventory by about 50 percent




24  across the country.  These vehicles contribute




25  significantly higher across the country, essentially






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                 Opening Statements




in the urban area.



            As Judy mentioned, we are proposing a




two-phased approach to the heavy-duty diesel  engine




standards.




            The first phase,  EPA is proposing new




engine standards beginning in 2004  for  all  trucks




and SUVs over 8500 pounds.   The new standards will




require gasoline trucks to be 78 percent  cleaner




than today's heavy-duty gasoline trucks,  and  diesel




trucks to be 40 percent cleaner than  today's  most




models [sic] .




            In the second phase of  this we  plan to




propose later this year or earlier  next year,  we're




planning to propose more stringent  standards  to,




again, significantly reduce  pollution,  both NOx,




nitrogen oxides and particulates, from  heavy-duty




trucks, both gasoline and diesel, and to  also




control at the same time sulfur in  diesel  fuel.




            That proposal, when it  is finalized,




would take effect not later  than 2007,  and  it would




reduce emissions by 75 percent and  90 percent from




NOx and particulates beyond  the proposal  that we're




making today that we're going to obtain in  2004 time




frame.
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                 Opening Statements




            Very briefly, let me outline  the  key




components of the proposal that we are discussing




here today:




            First, the proposal reaffirms  the




technological feasibility of the nitrogen  oxide




standards for heavy-duty diesel engines  that  was




finalized in 1997.  When EPA finalized those




standards in 1997, we committed to assess  the




technological feasibility of the standards, and we




have done that.  We believe those standards are




feasible to take place in 2004.  These are nitrogen




oxide and hydrocarbon standards.




            Second, we are proposing  NOx  standards




for gasoline-fueled engines that will be  78 percent




cleaner than today's gasoline heavy-duty  engines.




            These requirements will harmonize with




California when they become effective in  2004 time




frame .



            Third, we propose to devise  the advise




of regulatory finish of light-duty trucks  in  order




to form the subset of heavy-duty vehicles  that are




designed primarily for transportation.  We're




proposing to bring those vehicles under  our Tier  2




proposal.





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                 Opening Statements




            Fourth, we're proposing test




requirements for heavy-duty diesel engines.   These



requirements have their origin in the  consent




decrees entered into last November by  seven  of  the




largest heavy-duty diesel engine manufacturers.




            We are proposing to codify some  of  the




provisions of the consent decrees to provide




assurance that diesel engines will meet the




standards under a broad range of driving  conditions;




            Fifth, we're proposing to  require




onboard diagnostic requirements for diesel and




gasoline heavy-duty vehicles from 8,500 to 14,000




pounds.




            This element of the proposal  would  help




identify any possible failure of components  of  the




emission control systems, and it would harmonize




federal OBD, onboard diagnostic, requirements with




those already in place in California.




            And, finally, the proposal  discusses the




possibilities for the next phase of heavy-duty




emission standards for diesel and gasoline engines,




both for NOx, nitrogen oxides, and particulates,




including the fact we need that to address fuel




quantity, diesel fuel quantity.






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                 Opening Statements




            We are granting  specific  comments  on




diesel spenders and on all of  the  diesel-fuel



quality in meeting these Tier  2  standards  that will




go into affect much later  than 2007  time  frame.




            Now, here, we've already  introduced Judy




Katz here from Philadelphia.




            On my left is  Robert French.   He is with




our Engines and Compliance Division.   He  is  one of




the authors of this very important regulatory




problem.




            On my right, Chet  French;  he  is  also




with Office of Mobile Sources,  and he  is  in  charge




of all of the regulatory problems.   And next to him




is Mike Horowitz; he  is with the Office of General




Counsel.




            I am glad to see you here  today  here.




            His wife  is expecting  a  baby.  So  if you




see him walking out today, you know  what  is  going




on.




            We are conducting  this hearing in




accordance with Section 307-B5 of  the  Clean  Air Act,




which requires EPA to provide  interested  persons




with an opportunity for oral presentation of data  in




views related to the  proposal.






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                 Opening Statements




            The official record  for  this  hearing




will be kept open for 30 days; it  is  provided




according to the Act.  That means  that  written




comments will be accepted  through  Thursday,  December




2nd, 1999.




            The hearing will  be  conducted




informally, and formal rules  of  evidence  will not




apply.



            The presiding  officer,  however,  is




authorized to strike  from  the record statements



which are deemed irrelevant or needlessly




repetitious in order  to enforce  reasonable limits on




the duration of the statement of any witness.




            Now, Bill Charmling  (ph),  will you stand




up, please?




            He is an  important person;  he is going




to keep the time for  each  one of you,  to  officiate.




So to the people the  testify,  try  to keep your




comments not more than ten minutes,  because we do




have a number of individuals  that  have  expressed an




interest to testify.




            I would ask that  the witnesses be




requested to state their names and affiliation prior




to making their statements.   When  a  witness is






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                 Opening Statements




finished his or her presentation, members  of  the




panel may ask that person questions  concerning the




testimony.




            To the panel members  on  the  panel  today,




I will ask each witness to make a statement;  I would




ask the EPA panel to hold their questions,  and at




the end of everybody's presentations,  we may  have



questions from the panel.




            The witnesses are  reminded that any




false statements or false responses  to questions may



be a violation of law.




            If there are any members  of  the audience




that wish to testify and have  not already  signed up,




I would ask you to please submit  your  names at the




reception table, and we will make every  possible




effort to accommodate all of those who wish to




testify.




            We would like all  activists  to sign the



registrar whether or not they  testify.




            Finally, I would like to  ask the




witnesses to please speak up close to  the




microphone.  It would be great if you  can  give your




statement to the court reporter.  I  think  that will




facilitate her job.






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                                                      15
 1                     Jed Mandel - EMA




 2               And if you would like to have a




 3   transcript of the proceedings, you should make




 4   arrangements directly with the court reporter during




 5   one of the breaks.



 6               The transcript will be available  in  the




 7   docket on our web site within two weeks.




 8               This  concludes my statement.  And if  you




 9   don't have any questions, I would like  to start  with




10   our first panel of witnesses.




11               Any questions?




12               I would like to call Mr. Jack Mandel,




13   Mr. William Beckel, Mr. Richard Kassel,  Mr. Joe




14   Minott, and Dr. Walter Tsou.  Would you please  take




15   your seat?



16               You should have a piece of  paper  in




17   front of you.  I  would like you to please state  your




18   name.




19               We will ask Mr. Mandel to start.




20               MR. MANDEL:  Good morning.   My  name  is




21   Jed Mandel, and I am here today on behalf of  the




22   Engine Manufacturers Association.




23               EMA's membership includes major




24   manufacturers of  the engines used in heavy-duty,




25   on-highway vehicles, the subject of today's hearing.





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 l                     Jed Mandel   EMA




 2               The original rulemaking leading up  to




    the rules currently in place for 2004 was the




    product of a joint Statement of Principles signed  by




    EPA,  The Air Resources Board in California, and the




    leading engine manufacturers.




                That rule was a ground-breaking effort,




    designed to provide the people who build engines the




    certainty, stability and extra lead time necessary




10   to meet the very stringent engine standards that the




11   people who regulate emissions might not otherwise  be




12   able to justify or adopt.




13               That rule also included a commitment by




14   EPA to review the 2004 standards in 1999 to assess




15   the appropriateness of the standards under the  Clean




16   Air Act, including the need for and technical and




17   economical feasibility of the standards based on




18   information available in 1999.




19               While EPA reserved the right to either




20   tighten or relax the standards, the clear intent of




21   the SOP and the 2004 Final Rule was to provide




22   manufacturers certainty, stability and lead time.




23               Today's proposal takes away that




24   certainty, stability and lead time.




25               EPA is proposing multiple new emission





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                                                      17
                      Jed Mandel   EMA




    standards,  massive changes to the existing



    regulatory program, significant new test procedures,




    and the fundamental recharacterization of heavy-duty




    engines and vehicles.  Those proposed changes




    significantly increase the stringency of the 2004




    standards,  propose new standards not part of the




    2004 Final Rule, and erode the certainty, stability




    and lead time that were so fundamental in the




10  original adoption of the 2004 standards.




11              Just a few examples may be




12  illustrative:  EPA is proposing multiple new




13  supplemental test procedures and emission standards




14  that significantly increase the stringency of  the




15  2004 standards.  Yet neither EPA nor the regulated




16  industry have adequate data to determine the




17  feasibility and cost- effectiveness of these new test




18  procedures.  In fact, it is unclear how these




19  procedures are to be run,  or even if they can  be




20  run.




21              Further, EPA has proposed to make  the




22  engine manufacturer responsible for the emission




23  performance of its products at essentially any




24  possible combination of extreme operating




25  parameters.  The net result is that manufacturers






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                  Jed Mandel  -  EMA




must design their engines  to  meet emission  standards




at conditions that may  rarely,  if ever,  be  seen in



operation.




            But EPA has  not established  the




feasibility or cost- effectiveness of  requiring that



standards be met in such outlier  conditions.




            EPA also has proposed very  stringent new




emission  standards for  heavy-duty gasoline  engines




in vehicles without proper consideration of the




design margins necessary to ensure  compliance.  And




EPA has proposed to recategorize  a  whole segment of




the heavy-duty category,  flying in  the  face of 30




years of  Congressional  mandate  and  regulatory
policy.
            Not  only  has  EPA  proposed  so  many new,
complex changes,  but  EPA  has  proposed  those changes




at the very  end  of  the  intended  window of




opportunity  for  conducting  the 1999  review.   The




1999 review  was  contemplated  to  be undertaken and




finished well before  the  end  of  1999.




             Instead,  EPA  did  not  publish  its




intended action  until just  this  past Friday,  October




29, did not  hold a  hearing  until  today, the 2nd of




November, and has set December 2nd for the  close of
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                                                      19
                      Jed Mandel - EMA




    comment period.



                That leaves the interested parties  an




    unbelievably short period of time to review,  digest




    and comment on the proposed rule, and leaves  EPA and




    OMB with only a scant 29 days, including Christmas,




    if the rule is to be finalized before year  end.




                The critical need for a timely  1999




    review, acknowledged explicitly  in the SOP, was to




10  ensure that manufacturers were provided no  less than




11  four full model years of lead time, as is




12  statutorily required.




13              EPA's failure to conduct the 1999  review




14  in a timely fashion and EPA's subsequent decision to




15  propose at the last minute a host of new




16  requirements for finalization yet this year does not




17  provide the interested and affected parties adequate




18  opportunity to comment, does not provide EPA




19  adequate time to assess comments and prepare  a  final




20  rule,  and generally, shortchanges one of the




21  Agency's most important rules in such a profound way




22  that fundamental principles of due process  are  now




23  threatened.




24              Some of the issues being proposed  today




25  have not been discussed with the affected parties,
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                  Jed Mandel  -  EMA




nor have they been elucidated,  as they  should have




been, in public workshops  that  never  were  held.




            Some  of  the  issues  have been discussed




at some length with  a handful  of manufacturers but




hardly at all with others.




            In fact, EPA characterizes  some of the




issues as mere regulatory  adoption  of items




addressed in certain consent  decrees; however, the




consent decrees were separate  processes with




separated criteria for acceptance and separate




criteria for review.




            EPA must recognize  that in  a rulemaking,




it must meet the  requirements  of the  Clean Air Act.




In any event, the reality  is  that EPA's proposal




goes beyond any of the existing consent decrees.




            The heavy-duty engine industry has made




significant strides  in reducing emissions  from its




product, and the  industry  is  committed  to  doing even
more.
            As  EPA  is  aware,  engine  manufacturers
and others are  investing  multi  millions  of  dollars




in developing emission-reduction  technologies  that



have the potential  to  reduce  emissions  from the




conventional - fueled engines to  levels  so low as to
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                  Jed Mandel    EMA




have been unthinkable in  the years  past.




            But as  EPA  also knows,  those



technologies require the  removal  of sulfur from both




diesel and gasoline.  And while EPA has  proposed to




reduce sulfur  from  gasoline,  it has yet  to propose




any reduction  in  diesel fuel  sulfur.




            The standards and  regulatory program




being proposed today require  substantially reduced




fuel sulfur levels.




            Engine  manufacturers  are ready to do




their part.  But  the refining  industry must also do




theirs.  And EPA  must recognize that future




emissions reductions, can only  be  cost effectively




achieved through  a  systems approach requiring a




coordinated improvement in engine technologies and
 fuels.
             EPA  simply  should  not  proceed with rules
 requiring  changes  in  technology until it adopts




 rules requiring  changes  in  fuel quality.




             So where  do  we  go  from here?  We




 recommend  that EPA announce immediately that it is




 extending  the comment period an extra 60 days.   We




 recommend  that discussions  be  held between EPA and




 affected parties concerning the important issues
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                                                      22
                      Jed Mandel   EMA




    associated with the lead time and stability




    requirements of the Clean Air Act.



                Finally, we recommend that EPA publish




    now a proposal to reduce the level in sulfur  and




    diesel fuel so that commentors can assess all  of  the




    relevant factors impacting the feasibility and




    cost-effectiveness of EPA's proposal.




                EMA is reviewing EPA's proposal and




10  plans to prepare and submit written  comments  that




11  are as complete and detailed as possible given the




12  constraints of the late publication  of the rule and




13  the limited comment period.




14              In the meantime, and I understand  at  the




15  end of the panel's presentation, I would be glad  to




16  answer any questions you might have.




17              MS. OGE:  Thank you.




18              Mr. Becker, good morning.




19              MR. BECKER:  Good morning.




20              My name is Bill Becker,  and I am  the




21  executive director of STAPPA, the State and




22  Territorial Air Pollution Program Administrators,




23  and ALAPCO, the Association of Local Air Pollution




24  Control Officials,  which are the two national




25  associations of air quality officials in 55 states






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                                                      23
               William Becker -  STAPPA/ALAPCO




    and territories and more than 165 major metropolitan




    areas across the country.



                I am pleased to be here this morning  to




    provide our associations' testimony on EPA's recent




    proposal for controlling heavy-duty engines.




                The regulation of heavy-duty engines  on




    fuels is a critical issue for State and local air




    officials, and I commend EPA for issuing a proposal




10  that not only looks beyond the near-term, but also




11  takes a comprehensive systems approach to




12  controlling the on road segment of this very




13  significant source of air pollution.




14              While our forthcoming written comments




15  will provide our perspectives on your complete




16  proposal for on-road, heavy-duty engines, including




17  aspects related to the regulated heavy-duty gasoline




18  engines, today I would like to focus my comments  on




19  the few fundamental issues related to heavy-duty




20  diesels and fuel.




21              There is probably no more visible or




22  offensive kind of air pollution than the thick,




23  noxious, suffocating exhaust from big diesel trucks




24  and buses.  Moreover, the adverse health impacts  of




25  diesel pollution are dire, posing a serious threat






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                                                  24
           William Becker  - STAPPA/ALAPCO




to public health nationwide, and  especially in urban




areas.



            The hazardous  mixture that  comprises




diesel exhaust contains hundreds  of  different




chemical compounds.   From  a health perspective,




three of the most significant  pollutants  in diesel




exhaust are nitrogen  oxide, particulate matter and




toxic compounds.




            Mobile sources are responsible for




almost one half of all NOx emissions nationwide.




EPA7s own projections show that by 2010,  NOx from




mobile sources will near 8 million tons,  with  more




than half of this, over 4  million tons, coming from




diesel engines.



            Further,  one-third of the diesel




contribution of NOx is attributed to on-road,




heavy-duty diesel vehicles and two-third  to




off-road.



            These NOx emissions are  primary




precursors to  the formation of ground-level ozone.




And with close to 100 million  people nationwide




living in areas that  continue  to  violate  the



one-hour standard for ozone.   We  must taking




aggressive steps to address emissions from






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               William Becker - STAPPA/ALAPCO




    heavy-duty engines and their fuels.



                Mobile sources also generate primary




    emissions of particulate matter, accounting  for 20




    percent of direct PM emissions nationally.   This  is




    in addition to the secondarily formed particulate




    that occurs when NOx emitted into  the atmosphere  is




    transformed into dangerous fine particulate  matter.




                EPA projects that by 2010, direct  PM




10  emissions from mobile sources will exceed  600,000




11  tons, with diesel engines contributing to  nearly  70




12  percent.  Of this diesel contribution to PM  10,




13  on-road diesels account for 9 percent and  off  road




14  heavy-duty diesels for 60 percent.




15              And particulate emissions pose an  also




16  tremendous health problem.  The World Health




17  Organization has concluded that globally particulate




18  matter causes 460,000 premature deaths each  year.




19  The most hazardous particulate is  that which is very




20  small.




21              It is these especially fine particles




22  that are able to evade our respiratory defense




23  mechanisms, lodge deep within our  lungs, and cause




24  or contribute a variety of health  problems,




25  including asthma, chronic bronchitis, pneumonia.
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    heart disease and even premature death.  Up to 95




    percent of the fine particulate from diesels is




    smaller than 1 micron in diameter.




                And,  finally, there is a very serious




    health threat posed by the toxic emissions from




    diesels.   Diesel  exhaust contains over 40 chemicals




    that are  listed by EPA and California as toxic air




    contaminants known as human carcinogens, probable




10  human carcinogens, reproductive toxicants or




11  endocrine disrupters.




12              In 1998 California declared particulate




13  emission  from diesel- fueled engines a toxic air




14  contaminate based on data that supported links




15  between diesel exposure and human cancer.




16              There is an array of other significant,




17  adverse environmental impacts that I won't get into,




18  but these include, among others, regional haze, acid




19  rain, global warning.  So based on a substantial




20  contribution of heavy-duty diesels' emissions to air




21  pollution and the very serious public health and




22  environmental problems,  we believe we have no




23  alternative but to impose greater controls on




24  heavy-duty diesels and their fuels, and to do so in




25  a truly meaningful way.






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           William Becker  -  STAPPA/ALAPCO




            And,  further,  because many  of  these




vehicles constantly  travel back  and  forth  across the




country, their  emissions are ubiquitous.   And we




must not only regulate  these emissions,  we must do




so on a national  basis.




            STAPPA and  ALAPCO applaud  EPA  for its




proposal on the Tier 2  vehicle standards and low-




sulfur gasoline,  which  demonstrates  tremendous




leadership.  The  programs  proposed by  EPA  and




announced by President  Clinton himself  in  May, and




the time frames on which they're based,  are




absolutely critical  to  state and local  efforts to




achieve and sustain  clean, healthful air
nationwide.
            We  urge  EPA  to  exercise  similar
 leadership  in  comprehensively  addressing heavy-duty




 engines and  their  fuels.   The  regulatory program we




 envision is  a  comprehensive  one  that  takes  a systems




 approach that  includes  three fundamental prongs:




 stringent emission  standards,  tight  controls on




 sulfur in diesel fuel,  and rigorous  and  effective




 programs to  ensure  continued compliance  with




 standards when  the  vehicles  are  in use.




             STAPPA  and  ALAPCO  are extremely pleased
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that EPA is pursuing such  a three-prong  systems




approach.  Let me first address  emission standards.




            While we believe  that more stringent




emission standards for on  road,  heavy-duty  diesels




would have been appropriate for  2004, we understand




that EPA instead plans to  move forward with the




implementation of the standards  as  promulgated in




1997 with the intent of pursuing more stringent




standards in the next phase of regulations  that  take




effect in 2007.



            Notwithstanding our  disappointment in




the timing, we commend the direction  this  agency




appears to be moving, regarding  more  stringent




standards, and strongly urge  that at  least  three




fundamental principles underlie  EPA's efforts:




            First, 2007 must  be  a firm date;




substantially more stringent  emissions standards




must be in place for all on-road, heavy-duty




emissions standards nationwide by no  later  than




2007.



            Second, these  more stringent emissions




standards must be based on the most advanced



technology's possible.




            And, third, because  compliance  with  more
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    stringent future standards, based on advanced




    technologies is dependant on the availability of



    low-sulfur diesel fuel.  Such fuel must be provided




    nationally far enough in advance to ensure




    successful implementation of emissions standards,




    which brings me to the second-prong of the




    comprehensive strategy, control of diesel fuel




    quality.



10              Earlier this year STAPPA and ALAPCO




11  adopted recommendations for low-sulfur diesel fuel




12  to take effect early the next decade.  Our




13  associations have called upon EPA to cap sulfur and




14  diesel fuel at no higher than 30 parts per million




15  by 2004.




16              In addition, we have recommended that




17  based on additional studies, EPA further lower




18  national standards on sulfur in diesel fuel and set




19  appropriate standards for other characteristics




20  affecting diesel fuel quality and/or emissions, to




21  take effect in 2007.  We've attached a copy of the




22  resolution of sulfur and diesel fuel to my written




23  statement.




24              I would like the draw your attention to




25  the fact that STAPPA and ALAPCO's recommendations tc





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               William Becker   STAPPA/ALAPCO




    low sulfur in diesel fuel, apply not only to on  road




    diesel fuel,  but to off road diesel fuel as well,



    and further include a preliminary step to cap sulfur




    in off-road diesel fuel at 500 parts per million  as




    soon as possible but before 2004 so that this fuel




    is subject to the same sulfur standards as currently




    applied to on-road diesel fuel before sulfur levels




    for both on-road and off-road diesel are cut even




10  further.



11              We view the control of off-road diesels,




12  such as construction equipment and agricultural




13  equipment, to be as critical as the control of




14  on-road diesels.  Further, we believe that the




15  technological advances that occur in order to meet




16  future, more stringent, on-road, heavy-duty




17  standards will carry over to off-road equipment,  but




18  only if the low-sulfur diesel fuel is available  for




19  this sector as well.




20              We're extremely concerned, however,  that




21  EPA may not be proceeding as quickly or aggressively




22  as necessary to develop off-road diesel engine fuel




23  programs that are commiserate with the enormous




24  contribution off-road engines make to air pollution.




25              More must be done.






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            To this end we urge  EPA  to  intergrate




more closely the program development  strategies  for




on-road and off-road diesel engines  and fuels  so we




can more effectively reduce a  huge hair quality




proposed by these sources.



            I want to  turn quickly to the  third




prong of the strategy,  in-use  compliance.




            It is absolutely essential  that  we




ensure that heavy-duty engines operate  in  use  the




way they are expected  to operate.




            We remain  very concerned with  the  loss




of a significant level of  anticipated and  much-




needed NOx emissions reductions  that  resulted  from




the consent decrees settling complaints against




seven heavy-duty diesel engine manufacturers who




equipped their engines with defeat devices,




adversely affecting the NOx emission control systems




in use.




            Our concern is only  heightened by  the




fact that the Agency has chosen  to remove  in-use




testing and onboard diagnostics  provisions from  this




proposal and, instead,  based on  industry's




objections to the scope of the proposal in a short




time frame, merely include vague, noncommittal
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    language to defer action to a subsequent




    rulemaking.



                Both EPA and engine manufacturers have




    been aware for quite some time that significant




    in-use compliance problems exist, and these problems




    must be addressed in a timely matter.




 8              For engine manufacturers to argue that




 9  more time is now needed to address this issue is




10  somewhat disingenuous.  We strongly urge that at  a




11  minimum EPA explicitly commit in this rule not only




12  to the implementation of a strong and effective




13  in-use compliance program that will ensure against




14  future transgressions, such as those that




15  necessitated the recent consent decrees, but also a



16  firm starting date of no later than 2004.




17              Before I conclude, I would like to make




18  two points:  First, I would like to say a word about




19  EPA's proposal regarding light-duty trucks weighing




20  over 8500.  STAPPA and ALAPCO strongly support




21  subjecting especially large passenger vans and




22  sport-utility vehicles weighing over 8500 to the




23  Tier 2 motor vehicles standards proposed by the




24  Agency in May.




25              Given the continuing growing trend






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    toward use of heavier light-duty trucks for personal


    transportation,  it is entirely appropriate to


    subject these vehicles to the same standards as


    apply to other passenger vans and SUVs.


                In fact, in our associations' April  1998


    resolution on Tier 2, we urged EPA to  consider


    applying those standards to vehicles such as SUVs,


    full-size vans and pick-up trucks weighing over


10  8500 .


11              And, finally, I haven't addressed the


12  gasoline vehicle issue here.  We're going to address


13  that in our written comments, but I will take the


14  hook that was offered by Jed about the lead time


15  issue.


16              And I have to tell you that the States'


17  and local agencies are extremely concerned about any


18  delays, not only for heavy-duty engines but for


19  gasoline -- not only for diesel engines but for


20  gasoline engines.  And we believe it would be


21  absolutely unacceptable for the Agency to delay  this


22  role beyond the no-later-than 2004 date.


23              We expect the lead time issue not to be


24  an issue, that you meet that standard, and we think


25  that harmonizing with California is an excellent way
                       *


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                                                      34
                 Walter Tsou, M.D.   Citizen




    to proceed.



                So I want to make sure that the  Agency




    understands how critical this issue is to us.




                So in conclusion, let me thank you  for




    this opportunity to testify.  You've done a  nice  job




    with this proposal.  We  hope you will  include our




    suggestions for strengthening and improving  it  the




    comprehensive way we've  mentioned.




10              Thank you.



11              MS. OGE:  Thank you.




12              Dr. Tsou, good morning.




13              MR. TSOU:  Good morning.   I will be




14  extremely brief and speak for five minutes.




15              Good morning.  I am Dr. Walter Tsou,




16  medical director with the Montgomery County  Health




17  Department.




18              Today I would like to add  my voice  to




19  others for stricter standards for clean air  and




20  reduction  in particulate matter.




21              The dramatic effect of clean air




22  standards  can be seen here in Pennsylvania.  Most




23  dramatically, Pittsburgh is no longer  the soot  city



24  so well known half a century ago.




25              California has the toughest clean air






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                 Walter Tsou,  M.D. - Citizen




    standards of automobile emissions, and it works.




    Recently because of these tough automobile




    standards,  it was reported by Los Angeles it is no




    longer,  quote,  the smog city of the United States.




                But our lesson should be that the time




    to act is before asthma worsens and respiratory




    deaths occur in the Delaware Valley.  SUVs should be




    held to the same standards for air pollution as




10  other cars.  Failure to enforce these standards,




11  given the popularity of SUVs, would reverse decades




12  of air quality and result in hundreds of thousands




13  of cases of preventable respiratory illnesses and




14  death.




15              Based on the most recent 1998, '99




16  Philadelphia Health Management Survey of Health in




17  Southeastern Pennsylvania, there are 197,000, or 7




18  percent of the adults, and more significantly and




19  disproportionately, 79,000, or 9 percent of the




20  children, under the age of 18 with asthma.  This is




21  a combined total of 276,000 in the Delaware Valley,




22  in the Southeastern Pennsylvania, Five-County area.




23 '             Over 46,000 children under the age 18




24  are reported to have frequent upper respiratory




25  illnesses, and almost 185,000 children under age 18,





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                 Walter Tsou, M.D. - Citizen




    or 21 percent of the children, have allergies.




                Heart disease and allergies can  be




    exacerbated by air pollution.  Already 229,000




    adults say they have, quote, a heart condition,  and




    780,000 or 28 percent of the adults say they have




    allergies .




                In short, we already have hundreds  of




    thousands of residents in Southeastern Pennsylvania




10  across all ages who are already beginning  each  day




11  with significant and potentially life - threatening




12  illnesses.   For their families and those who love




13  them, delays in enforcing the air pollution




14  standards can only add to the misery of trying  to




15  live each day to the fullest or trying to  do the




16  simplest and most natural thing we do in life;




17  namely, breathing.




18              Others will speak more eloquently about




19  closing the SUV loophole, tightening the particulate




20  matter standards, cleaning up diesel fuel, and




21  strict enforcement of diagnostic testing of  cars and




22  diesel fuel trucks.




23              I will simply add my voice to  their



24  wishes and say Amen.




25              Thank you.






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                                                      37
 1               Joseph Otis Minott   Citizen




 2               MS.  OGE:   Thank you.




 3               Is it Mr.



 4               MR.  MINOTT:  Minott.



 5               MS.  OGE:   Minott.   Good morning.




 6               MR.  MINOTT:  Good morning.




 7               MS.  OGE:   If all of you could please



 8   state your name and organization that  you represent




 9   with the court reporter today.




10               MR.  MINOTT:  My name is Joe Minott,  and




11   I am here as a concerned parent.




12               First, I would like to thank the  EPA for




13   holding this hearing, and in a  gentle, parental  way




14   maybe, chide them for holding it on Election  Day.  A




15   lot of the people that I work with tend to  be




16   interested in politics and are  out working  the




17   polls, and we had a hard time bringing them in.




18               Nevertheless, my name, as  I said,  is  Joe




19   Minott.  I am an attorney, an environmentalist,  a




20   soccer coach and a community activist.  But by  far




21   my most important role is that  of father.




22               My son, Christopher, is an active 9-year




23   old.  He loves to play soccer and basketball.   He  is



24   also an asthmatic.




25               I do not know how many of  you in  this






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            Joseph Otis Minott  - Citizen




room have had to deal with a child when that  child




has to be rushed to the hospital because  he  cannot




breathe, or even a child  that needs  to skip  a soccer




game because the air pollution  is making  him




wheeze.  If you have an asthmatic member  of  your




family, you will understand  the passion of my



testimony.




            The Clean Air Act mandates that  the  EPA




set National Ambient Air  Quality Standards that  will




protect Christopher's health.   There is no doubt




that the air in this region  is  not protective of his




health.  It is certainly  not protective of the




health of all people with respiratory disease.




            Asthma rates  among  children are  up 75




percent since 1980 with 4.6  million  children




suffering from asthma nationwide.




            In 1998 Pennsylvania had 616  readings




where the eight-hour National Ambient Air Quality




Standard for ozone was exceeded.




            Most Pennsylvanians are  still regularly




exposed to unhealthful levels of ozone-   In




Montgomery County where Christopher  lives, the




eight-hour standard was exceeded 19  times in  1998.




In Philadelphia County, it is estimated that  50  to
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                Joseph Otis Minott - Citizen




    60  percent of the fine particle pollution can be




    attributed to diesel exhaust.  The major health




    impact of fine particle pollution has been well




    documented.




                Much of the environmental community is




    going to applaud the EPA's action today.  I would



    rather ask of EPA:  What took you so long?




                The environmental health community has




10  been urging EPA to act on diesel pollution for




11  years.  Automobile owners that are required to have




12  their emissions checked each year resent the free




13  ride of diesel trucks, yet only now is EPA proposing




14  to act.




15              Despite the fact that EPA designed its




16  proposals in close consultation with the engine




17  manufacturers and auto industries, and despite the




18  fact that EPA has been unduly generous in allowing




19  extra time for both industries to meet their




20  expected standards, you will hear today much and




21  during the comment period much complaining from the




22  engine manufacturers and oil producers.




23              These industries, in my opinion, refuse




24  to honestly look at the impact their products are




25  having on asthmatics and other respiratorily





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                Joseph Otis Minott   Citizen




    impaired Americans.



                My question to them is:  What about  the




    cost to asthmatics of not moving forward



    expeditiously with tightening the heavy-duty




    particulate standard and the lower sulfur in  fuel




 7  standards?



                We have already heard today from  these




    industries those industries how they will resort  to




10  time-honored and historically proven wrong  each  and




11  every time protestations about how unreasonable



12  these regulations are, how costly they will be  for




13  consumers, how it will ruin the engine manufacturing



14  industry, how it will put small refiners out  of




15  business, and finally, how the regulations  are  not




16  technologically feasible.




17              What you will not hear from the fuel




18  industry is how their fuel throughout America is  so




19  dirty it is ruining the pollution control systems of




20  America's trucks and buses.




21              My plea to this panel is that I hope  you




22  truly listen to the health experts and the  worried




23  parents such as myself, and conclude that these




24  regulations will go a long way to starting  to




25  address the financial and emotional costs associated





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                                                      41
                Richard  Kassel  -  NRDC




with the dramatic  rise  in  asthma  cases in America's




children.



             It  is  time  for the  federal government to




understand  this growing  epidemic  and deal with it.




What EPA is  proposing  today is  the belated first




step .



              Thank  you.




             MS. OGE:   Mr.  Minott,  thank you for




taking your  time  and coming to  share your




comments and also  on Election Day.  We did




realize  that, although too late.   And my




apologies.



             Mr. Kassel.  Good morning.




             MR. KASSEL:   Good morning.  My name




is Richard  Kassel.   I  am a senior attorney with




the  National Resources  Defense  Council.  NRDS is




a national  nonprofit environmental advocacy




organization with  over 400,000  members
 nationwide.
             At  NRDC,  I  run our Dump Dirty Diesels
Campaign.   Thank  you  for the  opportunity to




comment  and for holding  the  hearing today,  even



on Election Day.




             My remarks will  provide an outline to
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                Richard Kassel   NRDC




NRDC's comments on the proposed  rule.   Given the




time constraints, it may not be  possible  to



provide sufficient detail  on every  provision of




the rule.  We will be  supplementing our statement




today and our written  statement  today  with




further supplemental comments  before the  close  of




comment period.




            But at the outset, we are  one of




those organizations  that is applauding EPA  for




taking the step.  Yes, it  has  taken a  long  time




to get here, but  in  NRDC's view, this  proposal




begins to close some of the loopholes  that  have




historically stood between millions of Americans




and their right to clean,  healthy air.



            Further, we believe  that this




proposal sends a  strong message  and a  strong




signal to the nation's diesel  engine




manufacturers, gasoline engine manufacturers,




auto makers and others that it's time  to  dump




dirt diesels and  that  it is time to ensure  that




all of America's  sport-utility vehicles,  no




matter how big and heavy,  meet the  same stringent



standards as the  nation's  family cars.




            I hope that the industries that  are
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                Richard Kassel  - NRDC




interested in this proposal hear that  signal  and




hear that message and choose  to ride what  we



think is a public wave towards  cleaner vehicles,




diesel and gasoline, rather than fighting  it.




            EPA is taking  important  steps,  and




we'll be working hard to ensure that the  goals




are met.  And we have heard already  quite  a bit




about the health impacts of diesel  exhaust.  I




won't add very much  to it  because  time is
1imited.
            Very  simply,  our  reasons  for our
longstanding  concerns  are  quite  clear:   Diesel



vehicles emit  huge  quantities  of  particulate



matter, nitrogen  oxides, or  NOx,  and  toxic
 compounds.
            The  emissions  from  diesels,
particulates,  are  associated  with  increased




asthma attacks  and emergencies,  numerous




cardiopulmonary elements,  and premature death.




Nitrogen oxides contribute to ground-level ozone,




acid raid, but  also here  in Philadelphia  to




nutrient pollution in  the  Chesapeake  and  other




large water  bodies around  the nation.




             Diesel exhaust and the particulate
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                    Richard Kassel   NRDC




    exhaust has been termed a toxic air contaminate,




    a  probable carcinogen, a reasonably anticipated




    human carcinogen and other similar phrases by




    many bodies,  the National Institute for




    Occupation Safety and Health, The International




    Agency for Research and Cancer, the California




    Air Resources Board, and EPA's Draft Health Risk




    Assessment, who last year reached a similar




10  conclusion.




11              Diesel isn't just toxic, the




12  emissions aren't just plentiful; they add up.   In




13  the South Coast Air Basin in California, 38




14  percent of the NOx emissions come from diesels.




15  In the Northeast, NESCAUM estimates that roughly




16  one-third of the NOx comes from diesel.  In New




17  York City, over half of the particulates that




18  people breathe on Madison Avenue come from




19  diesels.



20              So let's move on to the major




21  components of the rule:  First, reaffirmation of




22  the existing 2004 NMHC plus NOx standards for




23  heavy-duty diesel engines.




24              We strongly support the reaffirmation




25'  of this standard.  EPA'S reaffirmation of this






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                    Richard Kassel   NRDC




    standard as a necessary predicate to cleaning up




    the  nation's dirty diesels and moving on to the




    equally, and perhaps more important, second step




    we will be talking about today.




                We agree with EPA that no changes in




    diesel fuel quality are necessary to meet the




    2004 diesel standard.




                The Manufacturers of Emission




10  Controls Association and others have eloquently




11  provided ample evidence that shows that currently




12  available control technologies already exist to




13  meet the 2004 standard without fuel changes.  I




14  believe they will be testifying later to that.




15              We also strongly support the




16  confrontation of certain critical consent decrees




17  requirements to ensure in-use compliance with




18  these standards.




19              Let's be clear.  The consent decrees




20  resulted from an unconscionable, nearly




21  industry-wide practice that flourished for




22  years.  One of the most significant aspects of




23  the consent decrees was the adoption of




24  supplemental standards and test cycles, including




25  without limitation the adoption of the EURO III






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test cycle and the not - to-exceed,  or NTE,  cycle.




We support the codification of  these provisions.




            We think  it is outrageous  that




companies that sign consent decrees that




committed to play under the rules  of the  consent




decrees from October  2002 to  October 2004  would




stand here today or put comments into  the  record




before the comment period closes to say  that  in




October 2004 the NTE  standard procedure  should go
away
            These  companies will  be  meeting  the
consent decree provisions  for  two  years  starting



in October 2002.  They  should  continue  to  meet



them in the future-



            On a  related matter, NRDC urges  EPA



to go further though  to ensure  in-use



compliance.  We need  a  strong  in-use testing



program for all heavy-duty vehicles and  engines,



and we need a program that requires onboard



diagnostics, OBD, for all  heavy-duty vehicles.



            I will move on to  the  Otto-cycle of



gasoline engine provisions.



            We support  the 1 gram  of combined



NMHC plus NOx standards for auto engines cycles
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                                                  47
                Richard Kassel  - NRDC




through 14,000 pounds.  Like on  the  diesel  side,




we think an in-use testing program  in  OBD makes  a




lot of sense as do to  the NTE and other  consent




decrees provisions.




            As with diesels, we  don't  think that




there is a lead time  issue here.  We urge EPA to




finish the rule promptly, and we don't think




there will be a four-year lead  time  issue,




particularly given the  fact  that what  EPA is




proposing to do has already  been done  in




California.




            Next, closing the SUV loophole.  I




will only take a moment.




            We strongly support  what the EPA is




proposing.  We strongly support  Tier 2.  It will




finally require auto  makers  to  produce many SUVs,




minivans and light trucks that  will  match the




emission performance  of the  nation's family car.




            Of course,  we have  been  concerned




about the loophole that exists  for  the heaviest




of the SUVs, so we are  glad  that EPA is  closing




the loophole.  We would urge you to  expedite the




timetable so that all  of the requirements kick in



no later than 2007.






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                                                      48
 1                   Richard Kassel   NRDC




 2               In the time I have left, I would  like




    to talk about the next steps, coming to the next




    phase of EPA's efforts to dump dirty diesels.




                As I noted at the outset, diesel




    pollution remains unconscionably high in many




    urban areas of the nation.  That's why we




    consider diesel exhaust to be the number one  air




    pollution threat in many cities.




10              Thus, we hope that the Agency will




11  follow-up with a strong proposal to  cut sulfur




12  levels to near-zero levels by 2007,  to reduce




13  particulate levels to  .01 grams-per-brake-




14  horsepower hour by 2007 and to reduce nitrogen




15  oxides to .2 grams -per-brake-horsepower hour  by




16  2007.



17              We urge the Agency though to take




18  interim steps to move  to a sulfur cap of 30 parts




19  per million in 2004; to move to a .05 gram




20  particulate standard in 2004.




21              We don't think that these are




22  standards that should  get caught up  in the lead




23  time debate over today's NMHC plus NOx proposal.




24  It is a separate set of provisions.  And we don't




25  think that there should be a lead-time problem,





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                                                  49
if the EPA acts fast enough.



            In any event, we hope  EPA  will




consider a phased approach, because millions  of




American's health are at  risk,  and Americans




shouldn't have to wait until 2007  for  lower




sulfur diesel and for lower particulate-emitting




buses and trucks.




            I know that  I am about to  be  told




that I am out of time, so I will  stop  talking.




            I have considerably more detail  about




each of these provisions  in my  written




statement.  Thank you.




            MS. OGE:  Thank you.




            Mr. Mandel,  I have  a  question for




you.




            Last year, seven of the largest




diesel engine manufacturers, Environmental




Protection Agency, the Justice  Department and the



California Air Resource  Board entered  into  what




we  call consent decrees,  agreements under which




this country will produce cleaner  diesel  engines




prior to 2004, as early  as 2002 actually.   And




also these companies have agreed  to produce  these




engines to be clean,  for  the most  part,  of  the
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                                                  50
driving conditions, which we  call  the




certification procedures, that  are  known  to




exceed technical  issues  that  you  raise.




            In your statement you  raise  the issue




of lead time.  Under  the law  as you suggested,




EPA has to give four  years  to companies,




heavy-duty companies,  to implement  new




standards.




            What  if EPA  doesn't finish this




standard, this rule,  by  end of  the  year?   Are you




suggesting that the companies that  entered under




this agreement, under the consent  decree,  that




they will not follow  this agreement after the




2004 time frame,  that they  will be  producing




engines that do not meet the  standards under




driving conditions?   Is  that  what  you  are




suggesting?  I would  just like  to  clarify the




record.   So please go ahead.




            MR. MANDEL:   I  am certainly not




suggesting that.  The consent decrees  state what




the consent decrees state.  The companies and the




agencies, both EPA and ARB, that  signed  on to




those, manufacturers  have every right  to  expect




manufacturers to  live up to what  those consent
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                                                  51
decrees say.



            And I am  certain  that  those




manufacturers will  live up  to  those  obligations,




several of whom I think you will hear  from on the




record today with respect  to  that.




            But let me make a  couple of  other




comments.  I think  will you also hear  from some




of the other companies that did sign consent




decrees an interest in seeing  a level  playing




field.  There are different perspectives on that




from engine manufacturers  who  signed consent




decrees and those who did  not.




            So one  of the  concerns  that  I hope




the Agency takes away from this is  there are




companies who produce product  effected by today's




proposal who are not  signatories to  these consent




decrees .




            I also  want to  point out that not all




signatories signed  the same consent  decree.  And




there are companies who signed consent decrees




who have provisions very different  from  others




who have signed and from today's proposal.




            And, lastly, I  think there is a




misimpression -- perhaps two  misimpressions:   one
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is that today's proposal simply takes  the  consent




decrees and puts them  in the regulatory




language.  And as I  indicated  in my  statement,  I




certainly will provide detailed comments on,  we




don't believe that is  the  case.  We  believe  that




the regulatory proposal is beyond  the  consent




decrees.




            The second misimpression is  that  the




consent decrees are  static and sort  of a done




deal.  In fact, my understanding is  that the




consent decrees are  yet a  dynamic  process  for




which there is dialog  between  the  signing




companies and the agencies as  to how those




decrees and the obligations under  them are to be




implemented.




            So I don't think we should give  the




impression that it is  sort of  a complete status



quo static situation.




            MS. OGE:   So just  to make  certain




that I understand what you are saying, assuming




that we don't complete this regulation by  the end




of the year, the consent decrees do  go away  over




2004 time frame.  What you are saying  here, what




you are stating here is that the consent decree






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                                                  53
companies will continue meeting the  requirements




of the consent decree regardless of  what  the




Agency is going to do as  far as completing  this




role.  So they are not going to go back and start




producing engines that they know meets standard




because the consent decree has gone  away  because




they don't have the four  years leeway?  Is  that




what you are saying.




            MR. MANDEL:   What I said is the




consent decree obligations don't meet  the consent




decrees.  I think we have to be careful to  make




sure that this hearing isn't about consent




decrees but is about the  regulatory  proposal,




which is differently obviously.




            We as engine  manufacturers are  quite




interested in seeing EPA  reaffirm the  1997-2004




standards.  The concerns  that we have  is  how  --




not whether, but how the  Agency implements




additional requirements and what those




requirements are.




            And I think that's the nub of it.




            And if that is done in a proper time




frame and with proper consideration  of all  of  the




effected interests, certainly not just those  of






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                                                  54
engine manufacturers, but  there  are  fuel

producers who will be affected by  this  and

obviously the public has great interest and great

concerns over what is done,  when all  of those

interests regress, I think our expectations is

that there will be rules in place  that  all can

live by that will more  than meet the  needs of the

Agency, the breathing public, to see  the  cleanest

diesel products, the gasoline products, the

cleanest alternative fuel  product  in  the

marketplace doing the work that  is necessary by

trucks.

            MS. OGE:  Does anybody have any

questions?  Anybody?

            MR. FRANCE:  Yes.

            MS. OGE:  I still have one  question.

            MR. FRANCE:  Just one  brief question,

Jed.  This gets at the  non-consent decree

companies.  I just want to get a little bit of a

clarification.


            Let's assume for a second that we can

address the concerns with  the supplemental

tests.  I don't want to get  into details,  but

assume we can.

              ~'-.i
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            Do you see in the context  of  your




lead time arguments, do you  see a  way   -  or  do




you see a way that those companies  can support




the supplemental test limitation by 2004?




            MR. MANDEL:  Companies  that do not




sign the consent decree?



            MR. FRANCE:  Right.




            MR. MANDEL:  What I have always  felt,




and I will tell you my personal view,  having




spent a long time working with both the Agency




and individual engine manufacturers,  is that if




there are reasonable programs in place that  can




cost-effectively get emissions reductions, engine




manufacturers will step to the plate to agree to




those kinds of programs.




            And, of course,  sometimes  in some




cases, they have actually gotten ahead of  others




in promoting those kinds of  programs as we did




with low-sulfur fuel in the  first  go-around.




            So I guess my answer is.  yes,  there




is a path to do that.  Obviously there are




significant details that I am not  sure you even




have in mind yet that would  need to be addressed.




            But I think from a conceptual





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perspective,  I've  never  seen  it  where  engine




manufacturers have been  willing  to  do  their part




and beyond  to get  emissions  reductions.




            MR.  FRANCE:   And  just  to  summarize




and make sure I  am not misinterpreting what I am




hearing, the  issue is not a  philosophical




disagreement  with  the supplemental  test and their




intent  of robust calibrations,  but  it  was in




technical details  of  their implementation.




            MR.  MANDEL:   I think that  is right.




As I've been  quoted on more  than once, the  devil




is in the details.   I don't  think  that the




manufacturers object  to  the  goal of having




procedures  that  reflect  real  world  operations.




            I think that's an applaudable goal




that we've  supported  from Day 1.  The  question




is:  What are those details;  how do they get




implemented;  how do they work;  can  they be




reasonably  implemented;  et cetera.   And those are




the issues  we need to be working on together to




solve that  issue.




            MR.  BECKER:   May  I  comment?




            MS.  OGE:  Yes,  I  am coming to you.




            I have a  question,  and  then probably
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                                                  57
you can make a statement  in  response  to  what  Mr.




Mandel is saying.




            Bill,  you  suggested  that  these




standards that we  are  proposing,  both phases,  the




first phase in 2004  and  the  second phase in 2007,




is critical for  the  State agencies across the




country, especially  areas that have ozone




problems and particulate  issues.




            Could  you  give us your views of how




the States are going to  proceed  in identifying




cost-effective control status to meet the




one-hour standard  and  the PM concerns that they




have  if the Agency is  being  successful in




implementing the standards by 2004 time  frame,




into  2007.




            MR.  BECKER:   It  is a fair question.




And it will obviously  vary from  state to state.




But as everyone  knows,  state implementation




planning is a  zero-sum game.




            And  to the extent that we don't




achieve the anticipated  emissions reductions  from




cleaner standards  and  cleaner fuels and  cleaner




in-use requirements,  then states and  localities




will  be required under law to make up for the
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                                                  58
difference elsewhere.



            And some will go  after  utilities  even




in a more stringent way  than  they have  in  the




past.  And some who have already tapped their




utilities to the maximum will have  to  address the




small businesses.  And some will probably




continue to exceed on the health base  standards.




            And this witness,  Chuck's  [sic]




Christopher, and others  will  continue  to be




affected by these excessive pollution  levels.




            And I want to get back  to  the  point




here.  I want  to make two points:




            First, we have examined the costs and




cost effectiveness of reducing emissions from




mobile sources and examined reducing diesel




exhaust.  And  compared to many of the  other




strategies that we are examining now,  these  are,




indeed, very cost-effective ways at reducing,




especially longer-term emission productions.




            And the piece of  this that  seems  to




be missing a lot is this in-use piece.   And  I




won't  -- I can't speak as passionately  as  some




other witnesses, but I will tell you that  there




is a tremendous amount of frustration,  of






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disappointment, of  feeling betrayed  at  the  defeat




device problem that occurred  over  the past  few




years.  And there are more emissions  -  and at




the Justice Department's  resolution  of  that,  of




the consent decree.  We've gone  on record




strongly criticizing the  consent decree.




            And one of  many reasons  is  that there




are more emissions  reductions that were left on




the table unaddressed than what  is being required




in the NOx SIP call that  is extraordinarily




controversial  in  the Eastern  part  of  the country.




            And with that as  sort  of  the




predicate, imagine  how  we feel about  discussions




that  - some,  I don't know if you  -   I  couldn't




understand your answer, not through  your fault,




through my fault  probably.




            I  still don't know whether  the  engine




manufacturers  are still looking  to meet these




requirements post 2004  after  the consent decree




is finished.   And whether you are  or  aren't,  it




is incumbent upon EPA to  strengthen  the in-use




requirements to ensure  that they are  expected to




meet  something even more  stringent than you




have .
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                                                  60
              Timothy Breeze  - Citizen




            So I hope that you work  this  out,




Chet.  But I hope you strengthen  it.  And we  are




going to be watching the Agency,  because  what




we've learned is that we need a very




comprehensive and a very extensive and  a  very




stringent in-use compliance program.



            MS. OGE:  Any more questions?




            Thank you.




            We have three members of the  public




that have expressed an  interest in testifying.   I




would like you to come  up.  Mr. Timothy Breeze,




Ms. Susan Osteunski --  I hope I pronounced that




right -- and Mr. Andrew Marks.




            Good morning.




            MR. BREEZE:  Good morning.  My name




is Tim Breeze.  I am living in New Brunswick,  New




Jersey right now.  And  I want to  thank  you for




giving me the time to speak.




            I am living in - - New Jersey  is one




of these -- I want to say it  has  the worst air




pollution of any place  in the entire United




States .




            Every day as I am going  to  work or at




work, you know, you see the millions  of -   you






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                                                  61
              Timothy Breeze  -  Citizen




know, tons and tons  of  cars on  the  roads.   And in




addition to that, when  going  on the  Turnpike,  you




just see these trucks.   And every day you're




stuck behind the  trucks and you can't stand the




smell, the pollution that  you are feeling.




            It is something that, you know,




affects us every  day.   Every  day you're stuck  in




traffic, and millions of people in  our  state have




to go through the same  thing.




            In this  country,  you know,  there is




150,000 people who have to go to the emergency




room every year because of asthma attacks  that




are  triggered by  this kind of air pollution.  And




New  Jersey is one of the big  places  where  this is




a huge problem.




            This  summer it was  like  one out of




every three days  was a  smog alert day.




            And in the  town that I  am  living in




now, which is New Brunswick,  we had the highest




of all of the eight  hour smog standards.   That




was  the highest level of any  day reported  over




the  course of the summer.




            You know, this is due to a  lot  of




things.  Obviously there is a lot of traffic
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                                                  62
              Timothy Breeze   Citizen




going through that town with the Turnpike  and  the




Parkway both being right nearby.   So  it's  not



just automobiles and sport - utility vehicles,




which a number of people have mentioned.




            You need to make sure  that  those




standards are met early, by 2007.  But  also a  lot




of these heavy-duty vehicles, these  trucks which




the pollution from them is just  causing some huge




problems.



            Yeah, so definitely  I  applaud  the




EPA, you know, for this program  that  you guys




have put forth to clean up heavy-duty vehicles




and reduce these standards, reduce emissions that




are coming, this particulate matter  especially.




            I know a lot of people that I  am




friends with who are asthmatic and who  just can't




even go outside and can't  do the things that they




are supposed to do for their job or  the things




that they need to do to live a --  just  a healthy




life.  They can't even be  outside  and do any of




these things especially in the summer.




            But I don't see why  we have to be



waiting ten years to be cleaning this up.




Especially with the sport-utility  vehicle





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                                                      63
                  Timothy Breeze - Citizen




    loophole,  you know,  giving until 2009 to auto




 3 I! makers to  be cleaning up the dirtiest SUVs,  it




    just doesn't make sense.



                We're seeing extreme health effects




    right now.   And auto makers have the technology




    to clean up their vehicles.  There is no reason




 8   that we can't have this by, you know, 2007  for




 9   the rest of the sport-utility vehicle.  I  would
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love it to be even earlier.



            Also, I want to make sure  that  we  can




tighten the standards on the heavy-duties,  to




make sure that is definitely is done by  2004.




You have heard a lot from these engine




manufacturers and others who want to have  - - they




may be thinking, you know, we can't do this  or




whatever.  And this doesn't -- it needs  to  be




done, and there has to be something done about
this.
            So you've got to adopt  these  strong
standards in cleaning up the diesel  fuel  and



cleaning up the emissions.



            And that's all I have.   But thanks



for letting me speak about this.



            MS. OGE:  Thank you.
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                                                  64
             Suzanne Osteunski  -  Citizen




            I can't even pronounce your name.




            MS. OSTEUNSKI:  Good  morning.




            My name is  Susan, and I  live  in New




Brunswick, New Jersey.  And I just wanted  to




state thank you for having the  conference  and




putting out this  issue  and bringing  up  the




proposal.




            But I definitely think we  should make




it a sooner issue, especially because  every day I




drive into new Brunswick on Route 1, and  I am



constantly sitting in traffic behind all  of these




trucks, all of this smog is blowing  in  my  face.




My friend can't outside to hang out  because she




has horrible asthma.



            I don't see why --  obviously  these




companies can do  something about  this.  Obviously




it is not going to take them ten  years.   I don't




understand why we have  to give  them  ten years.



            There is obviously  a  problem.   We




obviously should  do something of  it; we should  do




it now.  Time is  of the essence.   What  better




time than the present to do something  about




this?



            There are some high rates  of  cancer






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                                                  65
             Suzanne Osteunski  -  Citizen




right now, and obviously  this is  one  of  the




direct problems of  it  is  air pollution.   You can




see the air pollution  outside.   If  you  go outside




of the city on the  top of the hill, you  can  see




the smog and the  garbage  hanging over the city.




            It is obviously  a problem;  it is in



our face; we see  the statistics.   We  can do




something about it, and we should do  something




now before the problem is even  bigger.




            And basically I  would like  you to




take a stand on it  and make  it  a sooner issue.




            MS. OGE:   Thank  you.   Thanks to  both




of you taking the time to show  your




reasonableness.



            Thank you  very much.




            I ask the  next panel  to please come




up.  Mr. Blake Early,  Mr. Greg  Dana,  Mr. Sam




Boykin and Ms. Maria Bechis, and Beth McConnell.




            Can you please print  your names  on




the paper in front  of  you, and  then we  can start




with Mr. Blake Early.




            MRS.  BECHIS:   We were scheduled  for




11:15 here.




            MS. OGE:   What is your  name?
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                                                  66
             Suzanne Osteunski    Citizen




            MRS. BECHIS:  We are  with  the  Sierra




Club.



            MS. OGE:  We  do have  an  available




seat.  Please take  a seat.




            MR. EARLY:  Good morning.   I am Blake




Early.  I am an environmental  consultant for The




American Lung Association.  The American Lung




Association is the  nation's oldest volunteer




organization dedicated  to lung health.




            The American  Lung  Association




strongly supports the EPA's efforts  to  reduce




emission from large diesel and gasoline trucks




and buses and the application  of  uniform




emissions standards to  the full-size pick-up




trucks, passenger vans  and sport-utility




vehicle.  We also strongly support reducing




sulfur in diesel fuel.




            Clearly with  these emissions




reductions from the initiatives proposed,  more




will be needed in the effort to provide healthy




air across the nation.  For this  reason we urge




EPA to revise its proposal to  retain more




reductions and obtain them sooner.




            The American  public has  long opposed





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                                                  67
                     Blake Early




the unequal level of effort  in emissions




reduction that has been  imposed upon  passenger



vehicles and their owners  in comparison  to  trucks




and buses.



            For too  long trucks and  truck owners




have shared the road but not shared  the  cleanup



effort to curtailing air pollution  from  mobile




resources.  It is a  simple matter of  equitable




treatment.




            EPA's proposal is an  important  first




step in equalizing the  cleanup effort; however,




even if EPA were to  adopt  the ALA recommendation,




which I will outline in  a  moment, the Phase 2




heavy-duty diesel engines, the level  of  reduction




would substantially  lag  that required for




passenger vehicles.




            NOx and  fine particle reductions are




clearly needed across  the  nation, and reducing




NOx from diesels will  help reduce ozone.




            EPA estimates  that nationwide NOx




emissions will return  to their current levels  in




2020, assuming the standards proposed today are




adopted and implement  and  the projected  PM




emissions from mobile  sources will begin the
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                                                  68
                     Blake Early




trend upward beginning next year, precisely at a




time when we need to reduce PM, especially  the




fine particulate portion  of PM.



            These estimates are likely  to be low




given the historical difficulty in  estimating




vehicle miles traveled, growth, and consumer




vehicle choices as  exemplified by the  current




rage of purchasing  SUVs that  is dominating




vehicle sales today.



            NOx reductions are needed  to lower




unhealthy levels of  smog  and  prevails  in many




areas prevailing over  eight-hour periods.




            The fact,  that the United  States




Court of Appeals has remanded EPA's eight-hour




ozone NAAQS standard,  does not mean that adverse




health effects from exposure  to low levels  of




ozone are not occurring.




            Indeed,  for the past two summers, the




number of areas that have been experiencing




unhealthy levels of  smog  has  been in record




numbers.  In 1998 over 5,000  exceedences of the




eight-hour ozone NAAQS were monitored  in over 40




states .



            For two  summers in a row,  Salt  Lake
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                                                      69
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                     Blake Early




City, which has never had ozone exceedences,  has




experienced over a week's worth of  exceedences  of




the eight-hour standard.



            EPA has both  the  right  and  the




obligation to use the authorities not stayed  by




the Court of Appeals to protect people  from the



unhealthy levels of ozone.  The court itself  did




not take issue with EPA's scientific  analysis



supporting the need for an eight-hour ozone
standard.
            As  a  number  of  areas  experiencing the
eight-hour period  of  unhealthy  smog  grows,  so,




too, do the number of people  vulnerable  to  the




effects of smog.
16              Between 1982 and 1994, asthma




17  prevalence among adults grew 61 percent.  It rose
 72 percent among  children.




            While  we  do  not  know  why more people




 are becoming asthma sufferers,  we do know that




 many people with  asthma  are  more  vulnerable to




 the effects of  ozone,  experiencing asthma attacks




 and sometimes even needing hospitalization;  some




 people even die from  severe  asthma attacks.




            Since  diesel  exhaust  from on road and
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                                                  70
                     Blake Early




off-road sources contributes up to  26  percent  of




the total NOx emissions,  this proposal  is  clearly




moving in the right direction.



            Reducing diesel particulates  will




also lower toxic and nontoxic particulate  threats




to health.  Particles  from diesel  exhaust  may



contribute more than 50  percent to  Manhattan's




particulate emissions, and is also  a large




contributor -  or  contributes a large  percentage




of the particulates in many urban  areas.



            This situation may actually.




            Worsen if  oil manufacturers introduce




a  new generation of diesel engines  in  passenger




vehicles, which would  add to the particulate



emissions inventory.




            Studies suggest that these vehicles




would generate less large particulate  pollution




but 30 to 60 times more  fine particles,  which  are




the most dangerous to  human health.




            Many studies link airborne fine




particles with increased hospitalizations  in




respiratory disease, chronic obstructive  heart




disease, lung disease  and premature  mortality.



            Again,  while the U.S.  Court  of
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                                                  71
                     Blake  Early




Appeals remanded  EPA's  particle standard for




further explanation, this does not  mean that the




health threat  from  fine particles  is  any less




real.  EPA must continue its  effort to reduce




both PM 10 and PM 2.5.




            Diesel  particulate  concerns:  Not




only does it  contribute to  additional forms of




morbidity and  mortality,  but  for  many workers



exposed to the diesel  exhaust link, such an




exposure has  a 20-  to  40-percent  increase in lung




cancer.




            A  number of international, national




and  state agencies  have identified diesel




particulates  as a probable  carcinogen.



            While experts disagree as to whether




diesel particulate  is  a carcinogen and if so how




potent, the fact  still  remains  that millions of




Americans are  exposed  to this pollutant every




day.



            Prudence dictates that EPA lower




diesel particulate  emissions  as a  practical means




as a precautionary  measure.   But  EPA should




require more  reduction  sooner than it has in its




proposal thus  far.  Given the importance of
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                                                  72
                     Blake Early




obtaining the reductions in emissions  that




contribute to ambient ozone and particulate




pollution, we make  the  following




recommendations:




            A recent study by  the  Manufacturers



of Emissions Control Association demonstrated




that current technology  of heavy-duty  engines




needs .05 grams-per-brake-horsepower hour  of




particulate standards even using conventional




fuel with high  levels of sulfur.   EPA  should




tighten the HDPE particulate standard  to  .05 by




the year 2004.



            With a  four-year leave time,




manufactures should be  able to fully adopt  this



currently available technology to  their needs.




            In  the  second phase, EPA should




require another big reduction  in particulates  and




a  strict NOx standard.




            The same need to study demonstrated




that for a current - technology  engine to achieve  a




NOx emission rate below  2 grams per-brake-




horsepower-hour while achieving a  particulate




emission at .01 grams per-brake-horsepower  hour,



using conventional  high  sulfur fuel in exchange
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                                                  73
                     Blake Early




for sulfur-in-fuel reductions, which  we  advocate




below, which EPA  is  considering,  EPA  should




mandate emissions at least this  low or  lower for




the second phase  of  its  program.




            EPA should harmonize  non-passenger,




gasoline and diesel  vehicles  weighing 8500  to



15,000 pounds with California's  LEV II  program.




If manufacturers  can produce  cleaner  vehicles for




California, they  should  do so for the benefit of



breathers across  the nation.




            EPA should also assure all  heavy-duty




vehicles are subject to  an in-use test  program to




ensure the vehicle's performance  in the  real




world is the same as they perform during



certification testing.




            EPA should also set  sulfur  standards




to foster new control technologies.




            Lower sulfur in diesel fuel  is




important for two reasons:  It will facilitate




the use of advanced  emissions control on




heavy-duty trucks and will enable the most




effective use of  currently available  emission




reduction technologies to retrofit heavy trucks




on the road today.
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                                                  74
                     Blake Early




            EPA should  immediately  initiate the




program of requiring a  phased  retrofit  of




existing heavy-duty diesel trucks.   Unlike




passenger vehicles, which have a  useful  life of




approximately 100,000 miles,  diesel trucks are




driven vastly more miles, sometimes over a




million miles in  their  lifetime,  often  undergoing




multiple rebuilds.




            While the nation's automobile  fleet




will convert in approximately  12  years  from



old-technology vehicles to new-technology




vehicles, trucks  will be on     today's  trucks




that are driven on the  road  today will  last and




not turn over for many,  many more years.




            The only solution  is  to retrofit




those vehicles at the time their  engine  is being




built and the useful life is being  extended.




            EPA has imposed  new source




performance standards for any  heavy-duty truck




that is rebuilt,  just as the  Clean  Air  Act




required.  New source performance standards apply




to major rebuilds of power plants.




            There is little  question that




low-sulfur diesel fuel  is a  critical part  of any
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                                                  75
             Gregory Dana   The Alliance




effort to reduce emissions  from existing  and new




technology heavy-duty  diesel  trucks.



            EPA should also require  low-sulfur




fuel for use in off-road  diesel engines.




Off-road engines contribute as much  as  40 percent




of total diesel particulate emissions.



Low-sulfur fuel for  these  engines  allows




emissions to be reduced and also  eliminates major




problems associated  with  segregating high-sulfur




and low-sulfur fuels and  enforcing low-sulfur



requirements.




            It is  a  very  broad agenda but a very




needed agenda.  We urge the Agency to move as




rapidly as it can.



            Thank  you  very.




            MS. OGE:   Thank you.




            Mr. Dana,  good morning.




            MR. DANA:   Good morning.   I see you




have an overhead projector; I thought I would use




it.




            My name  is Gregory Dana.   I am vice




president of Environmental Affairs for  The




Alliance of Automobile Manufacturers.   I  am here




today to speak on  EPA's proposed  2004 heavy-duty
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                                                  76
             Gregory Dana   The Alliance




emissions rule and modifications  to  the  light




duty truck definition.



            I do need  to do my public  service




announcement first, however.  The Alliance  is  a



fairly new organization, less than a year  old,




and this is a list of  all  of the  members  of all




Alliance representing  about 90 percent of  the




sales of vehicles in the country.




            The Alliance member companies  support




the pursuit of cleaner air, and we are committed




to developing new advanced technology  to  minimize




any potential impact our vehicles may  have  on  the




environment.  Our commitment is shown  by  the




proposal we put forth  in response to EPA's  Tier 2




proposal; a proposal that  achieves greater




emissions reductions than  proposed by  EPA.




            Reducing the emissions from  the




heavy-duty vehicle population will help  in




achieving the nation's clean air  goals,  and we




struggle to do our part.




            My comments today will focus  of three




key issues in the NPRM which concern Alliance




members.  These are:   lead time,  light-duty truck



definition and fuel quality.






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             Gregory Dana   The Alliance




            EPA has described the heavy-duty




rulemaking schedule, which is unrealistic  and  so




compressed that the opportunity for detailed




commerce by affected parties and a complete




review and analysis of  such comments  by the




Agency prior to promulgating the final rule is



highly doubtful.




            Due to  the  hurried and unrealistic




time frame, the Agency's proposal would create




implementation and  administrative dilemmas.




There are many contradictions within  and between




the heavy-duty Tier 2 rulemakings, which must  be




addressed.




            We are  more than happy to do our part




to clean the air, but we require clear and




concise regulations.




            EPA should  extend the comment  period




and allow additional time in the review period




for this important  regulation so it will come  to




a complete debate that  can be held on all  of the




issues.




            Lead time and stability of emissions



standards are the key issues laid out by Congress




in the Clean Air Act.  The act requires






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                                                  78
             Gregory Dana  - The Alliance




heavy-duty vehicles and  engine manufacturers  be




given four years' notice of changes  to  standards




as well as a separate  three years  of  stability of




these same standards.




            A three-year stability of the




standard in the  four-year  lead time  granted by



the act effectively removes the 2004  model year




from discussion  at this  time  as manufactures  are




currently producing 2000 model-year  products.




            Furthermore, as diesel heavy-duty




standards are promulgated  in  1997,  which  are




effected in the  2004 model year, no  relation  to




the diesel heavy-duty  standard is  permitted prior




to the 2007 year.




            Manufacturers  require  this  stability




and lead time for all  cost-effective  emission




control standards to ensure the new  products  meet




the needs of the heavy-duty vehicle  customer




while simultaneously achieving air quality




standards.




            There is sound, fundamental rationale




for this lead time, and  EPA cannot  explicitly or




implicitly attempt to  rescind this position




provided by the Act.






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                                                  79
             Gregory Dana   The Alliance


            For the second time in  the  1999


calendar year, EPA is proposing to  modify  the


definition of light-duty truck.  Even before  the


Tier 2 rule is final, EPA  is again  proposing  to


modify the definition to include the new nebulous


category of vehicles between 8500 pounds and


10,000 pounds gross vehicle weight  that are


designed for personal transportation and have  a


capacity up to 12 persons.


            The attempt to pull these vehicles


into the Tier 2 rule via the heavy-duty notice is


not consistent with the proper notice and


opportunity for comment which is afforded  in  the


regulatory process.


            Manufacturers  have not  had  the


opportunity to comment on  the provisions,  and  EPA


has offered no analysis of the benefits of this


suggestion in context of the Tier 2 rules.


            The Alliance is proposing an


extremely comprehensive and aggressive  emissions


reduction program in the Tier 2 rulemaking


covering light-duty vehicles and light-duty


trucks, and we have been working with EPA  to


resolve the issues.
                   *


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                                                  80
             Gregory Dana   The Alliance




            A top priority  issue  identified in




the Tier 2 rulemaking has been the  engineering




workload during the phase-in.  This




reclassification of the  heavy-duty  vehicles adds




to an already uncontainable workload  problem for




manufacturers over and above  that caused  by the




Tier 2 rule.




            The Alliance continues  to stress that




heavy and light trucks are  unique from passenger




cars.  The utility of trucks  comes  with the




additional design considerations,  such as engine




size and structural integrity that  challenges the




emissions performance when  the full  range of




vehicle use is recognized.




            This vehicle segment  has  admittedly




found success in the marketplace  because  of the




expanded utility.  This  should not  create a




platform for EPA to restrict  its  choice by




setting standards that exceed the emission




feasibility of these vehicles.




            EPA has failed  to consider that




trucks are for peak use.  Therefore,  a




sport-utility vehicle or a  large  van  may  be




purchased to tow the boat or  camper  only  a few
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                                                  81
             Gregory Dana  - The Alliance




times a year, but the consumer values  these




attributes to the point of accepting the  stiffer




ride or accepting the other non-car-like




characteristics to accomplish  this  goal.




            The proposed definition of a  truck




designed for personal transportation appears  to




leave much room for Agency subjective




interpretation.  For example,  a common airport




shuttle vehicle is a large passenger van  that




accommodates eight, 12  or  15 people, depending on




whether there is luggage.  Although this  vehicle




is obviously a truck in rigorous,  commercial  use,




this vehicle would likely  be subjected to the




definition of light-duty truck requiring




compliance with the very stringent  Tier 2




gasoline and diesel standards.




            There are many implications related




to the inclusion of heavier vehicles into the




Tier 2 requirements.  An impossible workload  is




now further compounded  by  their addition.




            Also, chassis  test facilities for the




heavier gasoline and diesel vehicles including




the capability to measure  emissions from  the  SFTP




cycles are limited in the  entire  industry.  This






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             Gregory Dana   The Alliance




further demonstrates the necessity  of  granting




sufficient lead time for manufacturers.




            Another key issue  for The  Alliance  is




that necessary improvements to diesel  fuel




quality are lacking in the heavy-duty  proposal.




            EPA has stated that a change  in  fuel




quality is not necessary to achieve the proposed




heavy-duty emissions standards in 2004.   This




fails to consider the needs of the  light-duty




diesel vehicle regardless of definition.  A  5 ppm




maximum sulfur level in diesel fuel is required




for these vehicles to achieves the  significant




emissions reductions required  in Tier  2.  A  delay




in considering diesel fuel quality  is  a lost




opportunity for air quality and fleet  fuel




economy improvements.




            By failing to act, EPA  must recognize




the severity of the Tier 2 standards without




proper fuel, may preclude the  continued use  of




diesel engines in these vehicles resulting in a




loss in fuel economy in this market  segment.




            Reduced sulfur levels provide




benefits for emission hardware longevity and for




ultimate emissions performance.  Advanced diesel






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                                                  83
             Gregory Dana   The Alliance




technology will require complex exhaust after




treatment which will only be viable  with  very




low-sulfur diesel fuel.  Cleaner  air requires




cleaner fuel sooner rather  than later.



            Delays in  implementation of diesel




fuel quality improvements represent  lost



emissions and fuel economy  opportunities.




            I would be  remiss  if  I also didn't




mention the need  for low-sulfur fuels for




gasoline - fueled vehicles as well.  While  30  ppm




is the first right step, lower levels will  be




needed to allow the use of  the advanced




technology vehicles.




            Sulfur-free fuel has  enormous air




quality benefits  and will ensure  that emission




control systems work to their  fullest.  We  also




hope that EPA will respond  to  our -petition  on the




distillation index.  Controlling  the distillation




index will also help us in  designing cleaner




vehicles.




            In conclusion,  The Alliance is




focused on three  main  topics today:   We believe




that these heavier vehicles can meet more




stringent standards given adequate lead time arid
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                                                  84
             Gregory Dana    The  Alliance




clarification of  the definition  of  this  class of




vehicles;



            We believe  the  stability  and lead




time provision of  the act will  only allow the




promulgation of gasoline  emissions  standards of




2005 model year heavy-duty  vehicles and  2007




model year diesel  vehicles  at  the earliest;




            The Alliance  believes that attempts




to modify the light-duty  truck  and  personal




transportation definition circumvent  the




regulatory process of notice,  comment and review.




            The potential subjective




interpretation of  the new light-duty  truck




definition may be  very  troubling,  and a  systems




approach to vehicles and  fuels  needs  to  be




applied to the diesel technologies.   A 5 ppm




sulfur maximum is  required  to  enable  diesel




after-treatment devices to  improve  air quality.




            The Alliance  appreciates  this




opportunity to provide  testimony and  welcomes the




opportunity to work with  the EPA staff on this




important issue.




            MS. OGE:  Thank you.




            Mr. Sam Boykin.  Good morning.
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                                                     85
1                   Sam  Boykin  -  Citizen




2              MR.  BOYKIN:   Good morning.   It's




3  Boykin.



4              My  name  is  Sam  Boykin.   I  am a




   concerned  citizen  who  lives here in Philadelphia,




   Pennsylvania.   Although I have had the chance to




   live in many  different  cities across the East



   Coast, I notice the  same air pollution problems




   there  that we have right here in Philadelphia.




               I think  the first thing I  would like




   to  say is  I would  definitely just urge EPA to put




   the  concerns  of the  health  of the roughly 40,000




   Americans  that  die prematurely each year from




   pollution  ahead of the  concerns of the largest




   automobile corporations in  the world.




               Just myself, luckily,  I am a somewhat




   healthy person,  and  so  I don't need to worry




   about  running to the hospital every time there is




   a  bad  ozone day or some big diesel bus drives by




   me.  But even on those  days,  I am affected in




   terms  of being  able  to  go outside and  enjoy




   myself and do things that I normally like to do,




   whether it is ride my  bike  or go running.




               And so I would  definitely  applaud the




   EPA  for these forward-looking programs to clean





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                                                  86
                Sam Boykin   Citizen




up pollution from  some  of the nation's  largest




and dirtiest vehicles.



            I am extremely  concerned  that  the




proposal is phased in  over  a very  long  period of




time resulting  in  delayed health benefits  that




these standards could  bring.



            Specifically, I would  like  to  urge




the EPA to consider the following  changes  to




strengthen the  heavy-duty program:




            Number one  would be to  accelerate the




time line for choosing  the  SUV loophole.   There




seems to be no  technological reason to  give auto




makers an additional ten years to  clean up the




largest and dirtiest SUVs.  It seems  like  all



passenger vehicles should meet clean  car




standards by at least  the year 2007.




            Secondly,  I would like  to urge you to




tighten the heavy-duty  particulate  standards by




50  percent by 2004.  The technology is  already




available to cut particulate pollution  from




heavy-duty trucks  by half using existing




technologies and catalysts.




            Third, I urge you to adopt  strong




standards for 2007 pollution from  heavy-duty
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                                                  87
        Maria Bechis,  Bucks  Co.,  Sierra Club




vehicles.  That  is  an  urgent  problem that needs




to be addressed  as  soon  as possible.   The EPA




must forge ahead additionally for a  90-percent




reduction in particulate matter no later than




2007 .




            Fourth,  clean up the diesel fuel in




order to ensure  that diesel  pollution equipment




is effective.  All  diesel fuel sulfur levels in




both -- in both  on  road  and  off road diesel




vehicles pollution  should be capped  at 10 parts




per million sulfur  by  2006.




            And,  fifth,  ensure that  trucks stay




clean once they  are on the road.   In order to




ensure that clean trucks stay in,  in-use testing



and  onboard diagnostic equipment should be




required for all heavy-duty  trucks both for




gasoline and diesel .




            I would like to  thank you for letting




me speak today.   That's  all  I have to say.




            Ms.  Meggy  Bechis  will testify with




her mom, Maria Bechis.   Good morning.




            MRS.  BECHIS:   Good morning.  My name



is Maria Bechis,  and sitting next to me is my




daughter, Meggy  Bechis,  who  is an asthma






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                                                  88
        Maria Bechis, Bucks Co., Sierra  Club




sufferer.



            I am vice chair and volunteer




advocate at the Bucks County Group  of  the  Sierra




Club.  I am here not only  as an environmental




advocacy organization, but because  I have




witnessed firsthand  the  debilitating impacts of




asthma on children and adults.




            My 10-year-old daughter and  48-year-




old husband has asthma.  My daughter and husband




have difficulty breathing  and  wheeze painfully on




bad ozone days in the summer.  My daughter could




not undergo a necessary  surgery in  1997  because




of wheezing.




            In the summer, I am a timer  for




children's  swim meets.   I  have watched children




come out of the pool at  the end of  the swim meet




panicked because they cannot catch  their breath




and are in  desperate need  for  their inhalers.




            Exhaust  from heavy buses and trucks




of heavy-duty fuels  makes  it difficult for




children or anyone with  asthma to breathe.




Studies have also shown  that this exhaust  is



potentially carcinogenic.




            Death rates  from asthmatic children,
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                                                      89
            Maria Bechis,  Bucks Co., Sierra Club




    rising  6 percent a year, have doubled between




    1980  and 1993.   Nearly 5 million children, or one




    in  ten  children under Age 18, have asthma.




                The medical treatment for these




    children cost $6.2 billion a year.  These




    children suffer miserably.  They cannot play



 8 I outdoors in the summer and are dependant  on




    medications and inhalers.  To parents in  hospital




    emergency rooms, no cost is too high to protect
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    the health and lives of their children.




                The Sierra Club and I applaud  the




    EPA's proposal to close the loopholes  that  allow




    SUVs to emit up to five times more pollution than




    cars; set cleaner standards for trucks and  diesel




    fuels; and require strict tests to ensure




    compliance in standards.




                The EPA is doing the right thing in




    cleaning up these big polluters.  But  just  as




    with the big SUVs, they are giving them  too much




    time.  The technology exists today to  reduce




    particulate matter and to make a real  difference




    in the public's health.  Giving them until  2007



    to clean up is just too long.




                Bucks County, where my family
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                                                  90
        Maria Bechis, Bucks  Co.,  Sierra Club




resides, does not meet  air quality  standards on




many days.  We need  cleaner  air  to  breathe.   We




urge the EPA not to  heed  the diesel fuel and




truck manufacturers  to  extend the time  line  for




implementation of standards.




            I brought with me a  postcard that the




Sierra Club circulates  to the public,  and the




public then sends this  postcard  to  their




policy-makers and legislatures.   It is  a picture




of a real child.  This  little boy lives in




Texas.  And they have the worst  air in  the United




States.  It is the worst  air.




            Many of  their cities  exceed air




pollution levels that were once  found  in Los




Angeles.  This child goes out with  a gas mask,




and it has become a  standard code of dress for




these children in some  of the cities in Texas.




            This is  not what  I want for my child




or anyone's child.   And if we don't do  something




about bringing these pollution levels  down




quickly, I am afraid that we will be witnessing




something of this sort  in more cities  in the



United States.




            Now, Meggy  wanted to  say a  few words,
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                                                  91
               Meggy Bechis    Citizen




and she wrote something  that  she  would  like to




read here, if that's all  right.



            MS. OGE:   Yes.  Go ahead.




            MISS  BECHIS:   My  name is Meggy




Bechis.   I am 10  years old and I  have  asthma.




            We first found that out  when I was




about 8 years old.   I  have come here because I




want the  EPA to make large trucks and  buses stop




putting bad things  into  the air that makes me, my




dad and other kids  sick.




            It's  very  hard for me to breathe in




the summer because  it  is  very hot and  humid,




especially when the  air  is full of pollution.




Sometimes I can't go outside  when it is very




hot.




            Last  summer  I had to  swim  two laps of




the pool  for placement in swim team.   When I was




finished, I couldn't breathe.   My chest felt very



tight; I  was very scared.




            Other kids who swim at the  meet come




out of the pool coughing.   They sound  like




barking seals and need their  inhalers.




            In the beginning  I used  my  inhaler




two times a day.  Now  I  use it only  when I need
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                                                      92
 1                  Meggy Bechis  - Citizen




 2   it.



 3               Please help the  kids  who have  asthma




    by making the air cleaner, by making the  air




    cleaner.



                This picture  is  of  a  boy that  has




    asthma and is using an  inhaler.   The magazine is




 8   "Time for Kids."




 9               MRS. BECHIS:   It is  "Time  Magazine




10   for Kids," and they have  an  article  here  on what




11   a health menace  it is  for children,  asthma is.




12   Thank you.
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            MS. OGE:  Thank you, Meggy.




            Thank you for  - -




            (Interruption.)
            MS. OGE:  Meggy, this doesn't  happen
all the time.
            I do want to thank you  for  taking




time.  I would suspect if you are probably




missing class this morning
            MRS. BECHIS:  No.  No.   Election
Day.
            MS. OGE:  Election Day,  okay.




            But your testimony is going  to  be




entered into the public docket.  Your  comment  is
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                                                  93
              Beth McConnell  -  PennPIRG




very important  to us  as  we  deliberate  on this




very important  topic.




            Thank you.



            And Ms.  Beth McConnell,  good morning.




            MS.  McCONNELL:   Good morning.   It's a




little hard to  follow that.




            My  name  is  Beth McConnell.   I am a




clean-air advocate  for  PenPIRG,  the  Pennsylvania




Public Interest Research Group.   Thank you very




much for giving me  an opportunity to voice my




concerns about  the  need to  reduce air pollution




from trucks and SUVs.




            As  those of us  that  live here in




Philadelphia  are painfully  aware of,  air




pollution is  causing a  public health crisis not




only here but across the state and nation.




            According to recent  reports,




Philadelphia  has the fourth worst air quality in




the nation, contributing to the  premature death




of  an estimated 2,000 Philadelphians each year.




And in the  1999 summer  smog season,  the State




recorded more than  460  violations of the 8-hour



ozone standard.




            While this  problem notably affects
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                                                  94
              Beth McConnell    PennPIRG




urban centers,  such  as  Philadelphia  and



Pittsburgh,  it  also  does  reach  to  suburban and




rural areas.  For example,  air  pollution monitors




in rural counties in Pennsylvania,  such as




Franklin and Mercer,  has  reported  many unhealthy




days as monitors  in  the Philadelphia area.



              For more  than 650,00'0




Pennsylvanians  like  Meggy that  suffer respiratory




ailments like asthma,  this  pollution can become




more than  just  an inconvenience.   It also becomes




the reason  that kids miss school,  parents miss




work.  And,  in  fact,  it triggers an  estimated




370,000 asthma  attacks  each year.   1997 alone,




there was  more  than  370,000 in  Pennsylvania.




             Now big  trucks  and  buses including




diesel- and gasoline-powered vehicles over 8500




pounds are  among  the biggest causes  of our




pollution  problems.   And  manufacturers have done




very little to  curve their  pollution.




             These big vehicles  are a bigger




problem today than they were 30 years ago when




the Clean  Air Act was originally passed.




             In  fact,  in urban areas,  as much  as




50 percent  of the deadly  particulate pollution
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                                                      95
                  Beth McConnell - PennPIRG




    that we breathe comes from diesel vehicles.




    Making matters worse, this diesel pollution  has




    been found to contain hundreds of toxic




    substances, and more than 30 health studies  link




    diesel pollution to  lung cancer.




                It is high time for manufacturers  of




    diesel engines and big trucks to use widely




    available technologies to reduce their




10  pollution.  Yet we know from experience  that we




11  cannot count upon them to do this voluntarily,
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nor can we rely on the manufacturers to obey  the




rules without strict monitoring and enforcement.




            Just last year these same diesel




engine manufacturers were discovered to be




cheating on emissions tests resulting in an




increase of smog-forming pollution of over 1




million tons each year.




            PennPIRG applauds the EPA for




proposing a forward looking program to close  the




SUV loophole that allows SUVs to emit up to five




times more pollution than cars, also setting




tougher standards on trucks and the fuels that




power them, and for requiring strict tests that




ensure compliance with the standards.
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                                                  96
              Beth McConnell   PennPIRG




            However, we are extremely  concerned




that the proposal is phased in over an



unnecessarily long period  of  time  resulting  in




delayed health benefits for the  public and that




the proposal may not adequately  ensure that




heavy-duty trucks comply with the  standards



throughout the time  that they are  actually on  the




road.




            Specifically we would  urge the EPA  to




consider the following  changes to  strengthen the




heavy-duty program:




            Number one, we would really  like to




see the time line for closing the  SUV  loophole




accelerated.  Under  the Tier  2 auto pollution




program, all cars and the  smaller  SUVs will  be




required to meet clean  car standards by  2007.




There is no technological  reason to give auto




makers another two years to clean  up the largest




and dirtiest SUVs of all.  All passenger vehicles




should meet clean car standards  by 2007.




            We also  would  like to  see  the




heavy-duty particulate  standard  tightened by



2004 .




            According to the  manufacturers of  the





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                                                  97
              Beth McConnell    PennPIRG




Emissions Control Association,  the  technology is




already available to  cut particulate  pollution



from heavy-duty trucks by  half  using  existing




catalysts, yet the current  proposal would  have




the public wait until 2007  before  any reductions




in particulate pollution from heavy-duty  trucks




would occur.




            This delay will  contribute to  the




premature deaths of  thousands of Americans.




            Third, we would  like to see  strong




standards adopted in  2007.   Pollution from




heavy-duty vehicles  is an  urgent problem  that




must be addressed as  soon  as  possible.   The  EPA




must forge ahead with an additional 90 percent




reduction of particulate matter and nitrogen




oxide no  later than  2007.




            Fourth,  we would  like  to  see  diesel




fuel cleaned up.  Pollution  control systems  can




be  truly  effective only when  they  are coupled




only with low-sulfur  fuels.




            In fact,  the current sulfur  levels in




diesel fuels are so  high,  they  actually prevent




the use of the most  advanced  pollution control




technology.
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                                                  98
              Beth McConnell  -  PennPIRG




            So in order  to  ensure  that diesel




pollution equipment  is effective,  all  diesel  fuel



sulfur levels, both  on-  and off-road diesel  fuel,




should be capped at  10 parts  per million sulfur




fuel by 2006.




            Finally,  I would  like  to ensure  that




the trucks stay clean once  they are  actually  on




the road.




            Unfortunately  lab tests  quite often




do not reflect the  true  on-road emissions and



often faulty  pollution control  equipment goes




unnoticed by  the truck owner.   Moreover, in  the




past, engine  manufacturers  and  users have




seriously undermined emissions  standards by  using




cheating devices during  testing procedures.




            In order to  ensure  that  clean trucks




stay clean, in-use  testing  and  onboard diagnostic




equipment should be  required  for all heavy-duty




trucks, both  gasoline and  diesel.




            Once again,  I  want  to  thank  you  very




much for allowing me to  speak on this  issue.




            MS. OGE:  Thank you.   Any  questions



of the witness?




            MR. FRANCE:  Mr.  Dana, you made  some





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                                                      99
    strong statements on lead time.  But as a




    practical matter, I want to ask the question




    related to the 85 light-duty vehicle gasoline




 5 II category.




                And in that program -- we've had




    extensive discussions with the principal



    manufacturers.  And, in fact, the program




    proposed is harmonizing with a California  LEV  I




    program, which based on my recollection, 2001  is
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    already phased in in California.



                And in large part, what  our  program




    does is facilitate carrying over  California




    vehicles nationwide.  There are some  models  that




    aren't produced in California.



                As a practical matter I  am trying  to




    understand, if you could help  clarify, why 2004




    is not possible for that class of vehicles.




                MR. DANA:  What we were  saying was




    that the lead  time and stability  of  the  act




    allows the standards --  (unintelligible.)




                MR. FRANCE:  I understand that.  But




    as a practical matter, setting aside  the lead




    time points, what is presenting the  limitation?




                MR. DANA:  If you  look at some
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                                                 100
aspects of that  class  of  vehicles  that you're




trying to control,  the ones  you  named in the




proposal, at  least  some of  the manufacturers




build those vehicles with diesel engines.




            MR.  FRANCE:  I  said  gasoline.




            MR.  DANA:   Gasoline  only?




            MR.  FRANCE:  Yes.




            MR.  DANA:   It is a matter of catalyst




loading; it's  a  matter of working.   It should be




pointed out that under the  Tier  2  rule alone,




some manufacturers  have to  redesign almost 100




parts in one  year,  and then  do it  again three




years later.   It simply becomes  an  unworkable




problem in trying to get  everything redesigned




immediately when you add  in  the  additional layer




            MR.  FRANCE:  Maybe we're missing each




other.




            My only question was very simple:




For  those models that  are already  being produced




in California,  all  you have  to do  is carry them




over federally,  you know,  the rest  of the  49




states.



            MR.  DANA:   Right.




            MR.  FRANCE:   What is preventing you
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                                                 101
manufacturers  from  doing  that  in 2004?   That's my




question.



            MR.  DANA:   I  don't think there is a




feasibility from that  standpoint.




            MR.  FRANCE:   It is mainly legal.




            MR.  DANA:   It is not just necessarily




it is legal.   It's,  again,  a work issue as well.




Again, I understand what  you are saying.




            MR.  FRANCE:   And do you see any --




just  one follow-up  question on that:




            Do you  see any way around the legal




concerns that  would allow the  Agency to implement




that  program  in 2004 for  gasoline?




            MR.  DANA:   Ask the guy on your




right.   We  just put up there what the act says.




It seems fairly clear  in  its reading.  I don't




know  how to decide  how to deal with it.




            MR.  FRANCE:   Are manufacturers




willing  to  give the special circumstances to




waive the  four-year lead  time  for this  class of




vehicles?




            MR.  DANA:   I  am not sure I  can say




that  at  this  point.




            MS.  OGE:   Anymore  questions?
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            Mike?




            MR. HOROWITZ:  Do you  want  to go




first?




            MS. OGE:  Go  ahead.




            MR. HOROWITZ:  I  have  two questions




for Mr. Dana.  On  the issue of  the new definition




for light-duty trucks,  you made  some comments
 9  about the subjective nature  of  them.




10              The definition that  we  are  proposing




11  isn't  - is similar in  some  respects  to the
difference that we  now  have  between light-duty




vehicles and light-duty trucks.   And I think it




sounds like you are  saying there  is a subjective




nature to that, too.



            But we  haven't really heard anything




from manufacturers  that they don't like that




definition, that  distinction.




            Why is  the  distinction now a problem




in this proposal  when  it hasn't been for the last




several years?




            MR. DANA:   I think what we are trying




to point out when we look at the  class of




vehicles that are regulated,  8500 to 10,000




pounds, you have  some  SUVs,  you have pick-ups and
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                                                 103
other specialty vehicles.



            The definition  is  broad  enough as you




thought by the proposed  rule,  that,  in  fact,  it




covers pick-up trucks  as  well  as  SUVs and  any




other vehicle that  carries  up  to  12  people.




            An example I  pointed  out in my




testimony was something  that  is  called  a super




shuttle.  I am sure  those of  you  who travel  a lot




have seen them.   They  carry eight to 12 people.




They would fall under  the definition as we see it




as being covered  under the  Tier  2 rule.  That is




clearly a commercial vehicle.




            What  I  am  trying  to  point out  is




under the definition as  proposed,  you can  log in




a  lot more vehicles  than  just  the ones  you've




named by model name.   And that is just  a




difficult issue we  need  to  figure out between us




and  the agency, how to control what  we  want  to




control and not lump in  everything else.




            MR. HOROWITZ:  The second question




was, you have a statement about  fuel economy with




regard to diesels.   Is The  Alliance  in  favor of



increasing the corporate  average  fuel economy




standards so that we can  take  advantage of that?
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                                                 104
              Kathleen Kerdei    Citizen




            MR. DANA:  We haven't  taken  a




position on that.   But I would  point  out if,  in




fact, the Government  decides  to do anything with




regards to fuel economy, we  need to move either




the diesel engines  or lean-burn gasoline engines,




both of which require almost  virtually sulfur




fuel.




            So  if  that is the Government's



intention, then we're going  to  have to talk to




the agencies some  more about  further  sulfur to




allow diesel engines  to  use  devices and  allow




diesel engines  to  exist.



            MR. HOROWITZ:  Okay.




            MS. OGE:   Anymore questions?



            Thank  you very much.




            We  have three additional  individuals




that have expressed an interest in giving us




comments:  Kathleen Kerdei,  Kitty  Campbell,




Carmen Lopez.




            MS. KERDEI:  My  name is Kathleen




Kerdei, and I live in the city  in  Philadelphia.




And  I thank you for the  opportunity to come here




today and tell  you how the poor air quality




affects some of the older residents of this
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                                                     105
                  Kathleen Kerdei   Citizen




    city .



                30 years ago our family moved  from




    the Oak Lane neighborhood of Philadelphia  to




    Montgomery County where my husband's engineering




    firm had just built a new facility.  The choice




    was made in order to prevent the risk  and  waste




    of time of spending two to three hours a day  on




    the Expressway.




10              Four years ago, after  the  kids were




11  gone and on their own, the decision was made  to




12  move back to the city; sort of a payback after




13  decades of taking advantage of Philadelphia's
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many education, medical, cultural and employment




opportunities.



            We joined the ranks of several




friends and neighbors who had already begun




adding to the life and vitality of the  city  as




well as its tax base which sort of reverses  the



sprawl situations.




            For the most part, it has been a very




enjoyable experience except for the ever




declining air quality.




            The number of days one has  to cancel




plans to garden, or bicycle, take a walk to  the
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                                                 106
              Kathleen  Kerdei    Citizen




market, doctor's, movies,  increases  yearly as



does the degree  of  respiratory  distress expressed




by the residents.   Because of  this,  several




friends and neighbors  have already moved back to




the suburbs or planned to  move  before the coming



summer.




            And  it  isn't  just  the over-50 crowd.




A young woman in the  neighborhood explained to me




that she was leaving  her  studies at the




University of the Arts to  go home to New England




because in her first  semester  she spent more time




in Jefferson Hospital  Emergency Room than she had




in class.



            The  decreasing quality of life,




indeed, the risk to health and  life itself, will




continue to drive people  from  this city.  The




fortunate people, those who have come to become




mobile.




            The  result is  a major disappointment




for  the citizens who  wanted to  help the city live




and  grow and a real death  toll  for the city




itself, who is in desperate need of  Government



policy of common sense and mercy.




            Thank you.
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                                                     107
 1                 Kitty Campbell - Citizen




 2               MS. OGE:   Thank you.



 3               MS. CAMPBELL:  Good morning.  My  name




    is  Kitty Campbell.  I am a Philadelphia resident




    for about a year now, having lived out west for




    the last 20 years.  And I have to say, I am



    thinking of moving back out there.




                I don't have asthma and  I don't have




    respiratory problems, but I am losing my sense  of




10   smell and I do have some trouble going outside  on




11   the bad air days.  So I think we have to do




12   something about it.



13               And I can attest to the  fact that




14   tighter regulations regarding smog testing on




15   cars in California have made a huge  difference  in




16   smog levels out there.  I was out there for about




17   20 years, and it honestly made a huge, huge,




18   difference.  And we can do the same  thing here.




19               There is no reason we can't pick  up




20  those standards.  I have an older car, and it




21  only cost maybe $75 to improve it.   It is not




22  real, real expensive.  So I come here as a




23  private citizen who just wants to be able to




24   breathe better.




25               I urge that more stringent standards





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                                                 108
              Kitty Campbell  - Citizen




recommended by the EPA  for SUVs be  adopted not by




2009 but by not later than 2007,  the  same  for




cars .



            Given that,  as I  have read,  the




Japanese have already produced a  SUV  that  does




not pollute 3 to 5 times  more than cars,  why




can't we Americans get  on it  pronto?  And  if we




have to steal their technology or something,




let's do it.  Or let's  cooperate  with them.




            I also urge the tighter control in



both trucks and bus emissions be  enacted as




proposed besides by the EPA as quickly  as




possible for both diesel  and  gasoline fuel.  They




are working in California with alternative fuel



vehicles in  - regarding  the  bus.




            I believe it's gas-powered  buses or




something, and it is helping  somewhat.




            We all want to breath free,  and I




know I speak for millions when I  say  this.  So




please adopt EPA standards and even tighten them




up more, if you can.




            Thank you for letting me  speak.



            MS. OGE:  Thank you.




            Ms. Lopez,  good morning.






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                                                 109
               Carmen Lopez   Citizen




            MS. LOPEZ:  Good morning,  my  name  is




Carmen Lopez, and I live  in Alexandra,  Virginia.




First I just want to  thank you  for  giving me  an




opportunity to voice  my concerns  about the need




to reduce air pollution from trucks and SUVs.




            Nationwide, air pollution  sends more




than 150,000 Americans to the emergency rooms




each year and causes  more than  6  million  asthma




attacks, according to a recent  study.




            Even worse, particulate is



responsible for cutting short the lives of




thousands of Americans each year.   And I  would




also like to add that this problem




proportionately affects Latinos,  African




Americans, and those  of us who  live in the city.




            In Virginia,  air pollution is taking




an enormous toll on public health.   There were




124  smog violations during the  first half of  the




summer.  There were 23 days when  ozone standards




deemed the air unhealthy  for people who were




living, walking and working on  the  streets to




breathe.




            I just learned that there  were




220,000 people in Virginia and  27,000  in  Richmond





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               Carmen Lopez    Citizen




who had asthma attacks  due  to  air  pollution.



            This  is  extremely  disturbing to me.




My family and my  friends  and  I are avid rock




climbers, campers  and hikers.   And like many




people in the Washington,  D.C. area,  we like to




head out to the Shenandoah National Park to enjoy



outdoor recreational activities on the weekends.




            I've  recently learned  that Shenandoah




National Valley is one  of the  most polluted




national parks in the nation  and there are days




when it is as unsafe to breathe at this national




park as it is in  Washington D-C.   I think that is
 disgusting.
             Big  trucks  and buses,  most of which
16 I are diesel vehicles, are among the biggest




17 || sources of air pollution and problems,  and
 manufacturers  have  done very  little to curb this
 pollution.
             In  urban areas,  as  much as 50 percent
 of  the deadly  particulate  pollution that we



 breath comes  from diesel vehicles.



            Making matters worse,  this diesel



 pollution  has  been found to contain hundreds of



 toxic substances  and  has been  linked to lung
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                                                     Ill
                   Carmen Lopez -  Citizen




    cancer in more than 30 health studies.  It is




    time  for the manufacturers of diesel engines and




    big trucks to use widely available technologies




    to reduce their pollution.




                I thank the EPA for taking measures




    to clean up pollution from the nation's largest




    and dirtiest vehicles.  However, I am extremely




    concerned that the proposal has such a long




10  phase-in time, the result of which is delayed




11  health benefits for the public, and that  the




12  proposal may not adequately ensure that



13  heavy-duty trucks comply with standards
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throughout the time that they are on the roads.




            Specifically, I would urge EPA to




consider the following changes to strengthen the




heavy-duty program:  Accelerate the time line for




closing the SUV loophole and do that by 2007;




            Tighten the heavy-duty particulate




standards at least 50 percent by 2004;




            Adopt strong smog standards for 2007;




            Clean up diesel fuel;




            And ensure that the trucks stay clean




once they are on the road by using in-use testing




and onboard diagnostic equipment.
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           Patrick Charbonneau  -  NAVISTAR




            Thank you  for  letting me  speak on




this issue.



            MS. OGE:   Thank  you.




            Any questions?




            Thank you  very much.




            We will  take  an  hour  break for lunch,




and we will return at  1:15.   Thank you.




            (Luncheon  recess taken from 12:15
10p.m. to 1:20 p.m.)
            MS. OGE:   If  you  could take your




seat.  I would like  to call Mr.  Andrew Altman,




Mr. Patrick Charbonneau,  Mr.  Mike  Carter,  Mr.




Bruce Bertelsen,  and Coralie  Cooper.




            Pat,  we'll start  with  you.




            MR. CHARBONNEAU:   I  would like to




preference my comments by saying that NAVISTAR




demonstrated here in Philadelphia  the Tier 2




hearings this summer that over all,  for a




500-pound school  bus,  there was  a  90  percent
21  reduction in particulates, no measurable
hydrocarbons and  emissions  lower  than CNG engines



with ultra low-sulfur  fuel.   This can be done



with clean fuel.



            My  name  is  Patrick  Charbonneau.   I am
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                                                     113
               Patrick Charbonneau   NAVISTAR




    vice-president of Engineering for the Engine  and




    Foundry Division of NAVISTAR.  We are a major




    North American manufacturer of medium and




    heavy-duty trucks and buses marketed under  the




    international tradename.  NAVISTAR  is also  the




    world's largest manufacturer of mid-range diesel




    engines .




                To understand our views on EPA's




10  proposed 2004 model year standards, it is useful




11  to understand the commitments made  by EPA,  GARB
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and industry under the 1995 Statement  of




Principals for SOP.



            The signatories developed  the  SOP  to




achieve historic emissions reductions  from




heavy-duty diesel engines but in a manner  that  is




realistic to the industry.  And, in  fact,  the




focus was a 50 percent reduction in  NOx for  these
engines.
            For NAVISTAR, a key principle  of  the
SOP was that it would provide increased  certainty




and stability for our business planning.   As  the




SOP states, "Without such certainty and




stability, industry could not commit to  the




enormous investment that the standards will
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           Patrick Charbonneau    NAVISTAR




require.  And with such  certainty and  stability,




those investments might  never be  recouped.   EPA




and California recognize the huge investment that




will be required of  the  industry."




            The SOP  provides such stability by,




among other things,  confirming  the Model Year



2004 standards would be  premised  on current




federal test procedures,  and that EPA  thus  would




not alter such standards in  this  rulemaking.




            Moreover,  the SOP expressly applies




to all heavy-duty engines,  including heavy-duty
13  SUVs  and passenger vans weighing between 8500 and




14  10,000  pound gross vehicle weight.




15              NAVISTAR is committed to achieving
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 the principles  that  were  expressed in the SOP,




 and has committed  tens  of millions of dollars to




 meeting the  2004 emissions targets on all of our




 heavy-duty product lines.  We  were disappointed,




 however,  to  find that  the EPA's  complex proposal




 includes  features  which are inconsistent with the
 22  SOP and raise some serious questions regarding
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 overall  feasibility.




             For  instance,  EPA's  proposed




 not-to-exceed  limits  and  maximum achievable
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           Patrick Charbonneau  -  NAVISTAR




emissions limits testing  requirements  have the




effect of dramatically  increasing the  stringency




of the 2004 model year  standards  that  the EPA and




industry agreed upon  under  the  SOP-  We know of




no data suggesting that the Model Year 2004




heavy-duty standards  can  feasibly be met with the




NTE requirements in place.




            Moreover,  on  top of the  NTE and MAEL




proposals, EPA has proposed to  require testing




compliance over a wider and unprecedented range




of ambient conditions,  which further compromises
13  the feasibility of the 2004 standards.
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             Also  the  EPA's  proposal to expand the



 Tier 2 program  for  light-duty vehicles to include



 heavy-duty  SUVs and passenger vans is
17  inconsistent with the EPA's commitment under  the
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 SOP  to  establish technologically feasible



 standards  for  all heavy-duty vehicles.
 20              To our knowledge, there is no
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 technology  that  will enable heavy-duty SUVs in



 2004 to  meet  the EPA's proposed interim and full



 Tier 2  standards for light-duty vehicles.   If the



 EPA is  aware  of  contrary information,  we would



 like to  review that  so we can comment.
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           Patrick Charbonneau  -  NAVISTAR




            Finally, notwithstanding  the  many



complex issues that need  to  be  worked out,  EPA's




timetable calls  for the Agency  to complete  this




rulemaking by December  31st.  Not only does this




proposed timetable deprive  the  public of  adequate



time to assess and comment  on the rulemaking




package, it leaves the  EPA  with a challenge of




only 29 days to  finalize  the rule after the




December 2nd.




            This  timetable  is unworkable,




particularly given that the  EPA's proposal  would




number one, dramatically  change the term of the




SOP; number two,  increase the stringency of the




Model Year 2004  standards;  number three,  result
16  in new standards and test procedures that were



17  not part of the SOP; and four, effectively
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 preclude heavy-duty  SUVs  and  vans  from the



 marketplace .
 20              NAVISTAR respectfully submits  that



 21   the SOP provides the right blueprint for



 22   achieving dramatic yet feasible reductions  in
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 emissions  from  heavy-duty vehicles.   The SOP,




 along  with actual  EURO  III testing without EPA




 modifications ensures  tremendous  emissions
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           Patrick Charbonneau  -  NAVISTAR




reductions benefits.   The  EPA's  proposal,




however, departs  from  the  SOP  in ways  that fail




to appreciably advance environmental  objectives,




but which call into  question  the overall




feasibility of the proposal.




            Therefore,  we  recommend that  EPA and



industry move forward  with the  SOP for Model Year




2004 heavy-duty engines, work  to establish a




dialog on potential  new emissions testing




protocols for post 2004 model  years.   We  also




look forward to continuing discussions with EPA




on fuel issues .




            As we stated in our  comments  on the




Tier 2 rulemaking, clean diesel  fuel,  5 parts per




million maximum sulfur,  is absolutely  necessary




for emissions controls technologies we are




developing for the post-2004 period,  and,




therefore, must be addressed  in  connection with
20  any post 2004 heavy-duty emissions standards.
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             I  hope  the  NAVISTAR's  comments have



 been helpful to  the  Agency.   I  would be happy to



 answer any questions that  you may  have  regarding
    my testimony.
            MS.  OGE:   Thank  you.
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                                                     118
  II
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               Bruce Bertelsen    MECA

            Mr. Bertelsen, please.

            Good afternoon.

            MR. BERTELSEN:   Good  afternoon.

            Good afternoon.   For  the  record,  my

name is Bruce Bertelsen.   I  am  executive director

of the Manufacturers of  Emissions Controls

Association.  MECA  is pleased to  present

testimony in support of  EPA's proposal.

            For those not  familiar with  MECA,  we

are a non-profit association made up  of  the

world's leading manufacturers of  emission control

technology  for motor vehicles.

            EPA's proposed regulatory initiative,

we believe, marks an important  first  step in
16  moving towards the objective of substantially

17  reducing exhaust emissions from highway,
 heavy-duty engines  and  vehicles.
            The Agency's  proposal  constitutes a
20  carefully crafted and balanced program  that,  if
   II
21  finalized,  will result in substantial

22  cost-effective emissions reductions over  the  next
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    several decades.
            Completing  the  task  will  also require

 EPA  to implement  the appropriate limits  on the
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                   Bruce Bertelsen - MECA




   allowable  sulfur levels in both gasoline and




   diesel  fuel  and to move forward with



   consideration of tighter NOx and PM standards for




   heavy-duty engines and vehicles in the post-2004



   time  frame.




 7               Today I'll briefly summarize MECA's



 8  position on EPA's proposed initiative.  We do




   plan  to submit more detailed written comments.




10               MECA concurs with EPA's assessment




11  that  the heavy-duty diesel engine for 2004 and




12  later model year standards are technologically




13  feasible.   We also agree with EPA that engine




14  manufacturers are likely to meet these standards




15   for heavy-duty trucks without it using exhaust




16   control technologies such as diesel oxidation




17   catalysts  or diesel particulate filters.




18               We believe that the utilization of
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these  types  of  PM exhaust control technologies




would  enable engine manufacturers to meet a PM




standard  of  0.05  grams-per-brake-horsepower and




also achieve significant reductions in toxic




hydrocarbon  emissions.




            Consequently, we feel the EPA's




program for  the 2004 standard could be
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                   Bruce Bertelsen -  MECA


   strengthened  by tightening the PM standard when


 3 || it  finalizes  this proposal later this year.


               Turning to the post 2004 highway


   heavy-duty  diesel engine standards:


               In its proposal, EPA invites comments


   on  the  feasibility of imposing more stringent NOx


   and PM  standards in the 2007 time frame.


               We believe that by employing a


   systems approach, which combines advanced engine
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    designs,  advanced integrated exhaust emission


    controls  and very low diesel sulfur fuel,


    significant additional reductions in NOx, PM and

                             f
    toxic  emissions are possible beyond the  levels
15  that  will  be achieved in meeting the 2004


16  standards.


17              With such a systems approach, we


18  believe  levels in the range of .5 NOx  .01 PM and


19  over an  80  percent reduction in toxic  emissions
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    can be achievable.


                We commend EPA for initiating the


    consideration and the dialog on the next tier of


    heavy-duty diesel engine standards.  To achieve


    the very low-emission targets in the 2007 time


    frame, it is critical for EPA to establish as
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               Bruce Bertelsen    MECA




soon as is practical the  significant




emission-reduction  limits  that  will be  required



as well as the limits  on  the  allowable  levels of



sulfur and diesel fuel.




            Once the standards  and the  fuel




quality requirements are  known,  engine




manufactures, emission control  technology




manufactures and fuel  producers can all commit




the necessary financial and human resources to




meet those targets.



            To offer a few comments on  the




proposed new standards for Otto-cycle heavy-duty




engines, while EPA's proposal certainly presents
15  significant engineering challenges, again, we




16  concur with EPA's assessment that with the lead




17  time available and the regulatory flexibility




18  provided,  these standards should be achievable.




19              As EPA discussed in its feasibility




20  analysis,  the likely technology solution  will be
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 to combine  the  applications  of  the types of



 advanced engine and  catalyst technologies that



 are or will  be  employed  on gasoline-powered



 passenger cars  and light-duty trucks.



             With regard  to the  proposal to extend
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                   Bruce Bertelsen -  MECA


   the Tier  2  standards to vehicles  up to 10,000


   pounds  in response to EPA's proposed Tier 2


 4 II standards,  we  discussed in considerable detail


   our views on the technological approaches that


   likely  will be employed to meet those proposed


   limits,  and,  consequently,  I will not repeat that


   discussion here other than to say that we believe


   that  the  same  type of strategies that will be


   used  for  passenger cars and light trucks up to
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    8500  pounds can and will be applied to passenger


    transport vehicles up to 10,000 pounds to help


    them  meet the proposed Tier 2 standards.
14              Even though designing systems for


15  transport vehicles in the 85 to 10,000 pound


16  weight  class may pose additional engineering


17  challenges,  we're optimistic that these


18  challenges can be met.

   II
19              Again, we stress, however, that a


20  systems approach will be critical in meeting


21  these standards, including the availability of
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     low-sulfur gasoline and very low diesel   - very


     low-sulfur diesel fuel.


                With regard to the proposal as it


     relates to OBD systems, we support EPA's
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                   Bruce Bertelsen -  MECA




   proposal.   OBD systems in light-duty vehicle




   applications  have proved to be an effective



   method  for  maintaining effective emissions




 5 I! control  performance, and we expect that




   similar-type  benefits will be realized by




   extending  OBD requirements for all vehicles less
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than 14,000 pounds.



            With regard to the new  certification



test procedures, we support the  concept  that  EPA



has proposed of new certification test



procedures.  While implementation of  new
13  certification procedures and the associated




14  standards adds to the challenge of designing the




15  emission control systems, we also believe that




16  it's vitally important from an air quality




17  perspective that any certification test procedure




18  reflect real world operating conditions to the




19  maximum extent possible.




20              And we may have some specific
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 comments relating the  details  of  the  proposal



 which we would provide  in our  written comments.



            In closing, we  commend  EPA for  its



 continuing efforts to  reduce emissions from



 highway heavy-duty vehicles and  engines.  We are
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                                                     124
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                  Mike Carter  -  ARE




extremely optimistic  that  significant  further




progress can be made  to  reduce  emissions  from




this category of motor vehicles.




            As EPA moves forward to  address the




issue of highway, heavy - duty-vehicle and  engine




emissions and heavy-duty diesel  fuel quality, we




look forward to working  with  EPA,  the  engine and




vehicle manufacturers,  fuel producers  and other




interested parties to find effective solutions to




address this air quality challenge.



            Thank you very much.




            MS. OGE:   Thank you.




            Mr. Carter.   Good  afternoon.
15              MR. CARTER:  Good afternoon.




16              Good afternoon.  My name is Mike




17  Carter with the California Air Resources Board.




18              Let me apologize for my voice.  I




19  caught a cold two days ago, so I am battling with



20  that.




21              Having said that, it is still a




22  pleasure to be here and to provide comments on
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 behalf  of  CARB.



             First,  I  would  like  to begin by



 giving  a brief  overview  of  the  California Air
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                                                     125
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                  Mike  Carter    ARE




quality and recent activities.   Then I  will




provide comments  on  the specific elements of the




U.S. EPA proposal.   And finally,  I will summarize




the ARE's recommendations.




            I  should also  note  that  we  will also




be submitting  formal written  comments to the




docket that will  provide a more detailed




description of  our comments.




            California  is  a state that  enjoys




mild weather compared to the  rest of the nation.




However,  it is  also  plagued with some of the




worst air quality in the nation.  Virtually all
14  of  the  major metropolitan areas in California are



15  still  in non-compliance with national and state



16  air quality standards.  In fact, over 90 percent



17  of  Californians breathe unhealthy air.



18              Due to our clean air program,



19  significant strides have been made to improve the



20  air quality.  For example, on a state-wide basis,



21  peak ozone levels have decreased on average by 49
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 percent  from  1980  to 1997.
             This  decrease has occurred despite a



 39 percent  increase  in vehicle population and a



 70 percent  decrease  in vehicle miles traveled.
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                                                     126
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                  Mike  Carter    ARE




This significant  decline  in  ozone  levels




demonstrates the  overall  success of  our control



programs.




            Despite  these strides,  however,




exceedences of  air quality standards still




commonly occur.   For example in 1998,  60 days




were recorded to  give above  the one-hour federal




ozone air quality standard in  the  South Coast Air




Basin.  Additional emissions reductions are




needed in order to achieve attainment  in both




national and state air quality standards.




            Over  50  percent  of emissions emitted




from man-made sources are from mobile  sources.




            These pie charts illustrate the
16  projected percentage of mobile source emissions




17  to each category of sources in the South Cost Air




18  Basin by 2010.  As shown, the active organic




19  gasses and oxides of nitrogen emissions from




20  heavy-duty vehicles will be responsible for 6 and
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 43 percent,  respectively,  of  the total mobile



 resource  inventory.   In addition,  heavy-duty



 vehicles  will  contribute almost 70 percent of



 on-road particulate  matter emissions.



             It  is  clear that  in California,
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                                                     127
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                  Mike  Carter  -  ARE




heavy-duty emissions  are  a  major part of the




emissions inventory and additional  reductions are



needed.




            To  highlight  the additional need for




diesel emissions  reductions, this chart shows the




diesel particulate matter in comparison to all




other toxins  combined.   While  the risk in general




has decreased from both diesel and other toxics,




it is still significant with diesel accounting




for over  60 percent  of  the  total risk.




            These last  two  slides were also shown




at the Air Basin  Technology Symposium Conference




in early  October  of  last month.   And at that
15  conference it was made very clear that ARB's




16 I number one priorty right now is to reduce diesel




17  exhaust emissions.




18              This slide shows some of  the board's




19  recently adopted regulations of ongoing




20  activities to reduce emissions from mobile
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     sources.
             In several of these projects, ARE has
 worked closely with U.S.  EPA staff to develop and



 harmonize  the requirements.   To highlight some of



 the key activities currently underway, ARE is
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                                                     128
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                  Mike Carter  -  ARE




implementing the call aware program  to  reduce




diesel emissions and  for  developing  a proposal




for urban bus standards,  and  diesel  particulate




matter risk management, and lower  heavy-duty




diesel standards beyond the levels called for in




the statement's principles.




            I would  like  to limit  my comments




today on the NPRM to  four specific items:  the




heavy-duty Otto-cycle standards,  the heavy-duty




diesel standards test procedures,  the  inclusion




of investigations over  8500 pounds gross vehicle




weight into the Tier  2  program,  and  the
14  implementation issues associated with these




15  issues.



16              First, ARE supports the proposed



17  standard of l gram per-brake-horsepower hour  to



18  be implemented in 2004 for the heavy-duty Otto



19  cycle.   It should be known that ARE's



20  consideration of reducing these standards is  part



21  of a settlement agreement of a State



22  implementation plan lawsuit.
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             To  comply  with  the  proposed standard,



 the advanced emission  control  technology and



 light-  and medium-duty Otto-cycle vehicles could
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                                                     129
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                  Mike  Carter  -  ARB




be transferred  into  heavy-duty vehicles.   We



expect the reductions  from  this  transfer  of



technology should be significant,  since the




light-and medium-duty  standards  are more




stringent than  the proposed heavy-duty standards.




            As  noted earlier,  heavy-duty  diesel




vehicles contributed a substantial portion of




oxides of nitrogen or  particulate matter




emissions.  ARB staff  has  worked closely  with




U.S. EPA to develop  and promulgate the 2004




heavy-duty diesel  standards as well as the




off-cycle consent  decree.   Thus,  these heavy-duty




diesel requirements  for California are similar to




the federal ones.



            The NPRM proposes  to reaffirm the
17  heavy-release standard of 2-and-a half grams




18  per-brake-horsepower hour of hydrocarbons plus




19  oxides  of nitrogen for the 2004 model year.




20              This standard is feasible with  the
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 availability  of  emission control technologies




 that can  reduce  hydrocarbons and oxides of




 nitrogen  down to the compliance levels.  This is




 especially  evident  given the consent decree




 requirements  that this be implemented 15 months
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                                                     130
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                  Mike  Carter    ARE




earlier in October of 2002.




            Other elements  proposed  in the NPRM



also for heavy-duty  diesel  vehicles  include the




addition of supplemental  standards and test




procedures.  And in  addition,  three  elements are




are being considered for  SIP  for next  year.  And



my next two slides will comment  on  these items.




            First, the  additional standards and




test procedures will allow  better control of




emissions for  driving  in  the  real world resulting




in realization of expected  emissions reductions.




The current certification test has  limitations,
14  and that  does not fully represent the broad range




15  of driving emissions.



16              The addition of the state bureau free




17  test of certification would require control
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 emissions  over  a  broader  range  of  driving



 conditions.   Other  proposed  heavy-duty elements,



 including  the not - to-exceed  limits are important



 to ensure  durability  and  no  excess emissions.



             These additional  test  requirements



 proposed in  the NPRM  are  the  same  as  those in  the



 consent decree  in the  Agency  and accepted by the



 largest heavy-duty  vehicle manufactures.   Thus,
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                                                     131
                      Mike Carter -  ARE




    in  the  consent  decree requirements, these




 3 I!  additional  requirements should be feasible in the



 4   2004  time  frame.




 5 I              The NPRM also proposes additional




    heavy-duty  diesel provisions in consideration of




    a separate  rule,  and these items include onboard




    diagnostics for vehicles over 14,000 pounds gross




    vehicle weight.  A manufactured-based in-use test




    program and revised rates meeting that
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    definition.
                We encourage that U.S. EPA to
    continue the discussions and the regulatory
14  development of these items so the final rule can



15  be promulgated by early 2001 and implemented in



16  the 2004  model year.  These additional



17  requirements would provide additional assurance



18  of end-user ability and reduce the emission of



19  heavy-duty vehicleings.



20              The NPRM also proposes that heavy-



21  duty vehicles above 8500 pound gross vehicle
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    weight that are used primarily for personal



    transportation be included in the Tier 2
    program.
                This provision was considered in
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                                                     132
                      Mike Carter -  ARE




   California's  Low-Emission Vehicle II rulemaking




   but was  not  finalized.  It would be appropriate




   for these  heavy-duty vehicles to be included in




 5 II the Tier 2  program because they are used




   primarily  as  a personal transportation vehicle




   and would  discourage manufactures from



   redesigning a light-duty truck to a heavy-duty




   vehicle  just  so that it can be certified by a




   significantly higher heavy-duty vehicle emissions
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    standard.
                Thus, ARE supports this provision and
    we pursue the adoption of the civil requirement



    after a U.S. EPA final ruling.
15              We believe that the 2004 model year



16 I for the implementation of the NPRM elements is a



17  technologically feasible date.  We anticipate



18  that after the final rule, a similar California



19  rulemaking would be inconsistent in referencing
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     the CFR wherever possible will occur.




                But I have to emphasize, however,




     that the ARE is not constrained by the four-year




     lead time to the promulgation and implementation




     of the rulemaking.  Thus, regardless of whether




     there is a delay in the EPA rule, ARE does  intend
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                                                     133
 7





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10





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13
              Coralie Cooper    NESCAUM




to move forward and propose a  2004  implementation



date .




            Again, more  detailed  comments of the




proposed elements will be  submitted to the docket




at a later date.  But in summary,  ARE supports




the heavy-duty Otto-cycle  standards in the 2004




model year, the heavy-duty diesel  elements,  and




the inclusion of  the personal  transportation




vehicles over the 8500 pounds  gross vehicle




weight into the Tier 2 program.




            While these  proposed  elements would




provide emissions reductions  from heavy-duty
14  vehicles,  additional strategies to reduce




15  heavy-duty diesel emissions should continue  to  be




16  considered.



17 1             In particular, we are currently
18
19
 pursuing along  with  the  U.S.  EPA a lower



 emissions standards  beyond  the  2004 standard
20  levels from an engine/fuel perspective.
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     comment.
             Thank  you for this  opportunity to
             MS.  OGE:   Thank  you.




             Ms.  Coralie  Cooper,  good afternoon.




             MS.  COOPER:   Good afternoon.   My name
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              Coralie  Cooper    NESCAUM




is Coralie Cooper,  and I  am a  mobile  source




candidate for the Northeast States  Coordinated




Air Use Management,  or NESCAUM.




            NESCAUM is a  multi-state  organization




with eight member states    six member states,




New York and New Jersey.   NESCAUM provides




technical advice and policy guidance  to it




members.




            NESCAUM appreciates the opportunity




to provide testimony on EPA's  proposal relating




to 2004 model year  vehicles and engines and




proposed provisions of the light-duty truck
definition.
             Reducing heavy-duty engine emissions
 is a primary  concern in Northeast states.   These



 engines are significant contributors to elevated



 levels of  ozone  and fine particulate matter.



 Together highway and on-road heavy-duty engines



 are  responsible  for roughly 33  percent of all



 nitrogen oxide  or NOx emissions,  and 75 percent



 of  motor-vehicle-related PM emissions in the



 Northeast  corridor.



            The  relative importance of a



 heavy-duty engine sector is expected to increase
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                                                     135
  IT
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              Coralie Cooper  -  NESCAUM




as the region implements  further  controls on




other sources of NOx  emissions  and  as  the




regulatory community  refines  its  use  in




heavy-duty emissions.




            In  the  United States  and  in Europe,




development and active  treatment  of exhaust in




the use of low-sulfur diesel  fuel have been shown




to enable emissions reductions  by more than 90




percent in NOx  PM and toxins  in heavy-duty
engines
             EPA's  proposal  for regulating
heavy-duty  engine  vehicle emissions for the 2004




time frame  is  an  important step to reduce a




heavy-duty  engine  emissions.   When combined with




further  standards  in the 2007  time frame, end




reductions  in  diesel fuel and  sulfur,  the




proposal  will  substantially reduce heavy-duty




vehicle  emissions.



             Now,  I would like  to summarize the




NESCAUM  comments,  and NESCAUM  will also submit




more detailed  comments in writing later.




             In terms of reaffirming the




 technological  feasibility of  the 2004  or later
 25  model year for heavy-duty diesel engines, again
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                                                     136
                  Coralie Cooper   NESCAUM




    it's  NOx  and PM,  NESCAUM states support the




    proposed  NOx standard for heavy-duty diesel



    engines.




 5 I!              This  standard is technically and



 6   economically feasible in the 2004 time frame




 7   using currently available technology.




 8 I              In terms of particulate emissions,




    NESCAUM  states that heavy-duty diesel engines can




    either be illustrated by .5 gram-per-brake-
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    horsepower hour standard than that proposed,



    which is the .1 gram-per-brake-horsepower hour
    standard.
                And we believe that the further
    reductions could be achieved in a cost effective



    manner.   I believe Bruce mentioned urban buses



    are currently held to 2.5 grams-per-brake-



    horsepower hour standard and others as well.



    This is  being met with the use of oxidation
    catalysts.
                Heavy-duty trucks and interstate
    buses can also meet the same .05 standard with



    the use of oxidation catalysts.  Heavy-duty truck



    PM standard has not changed since 1994, and over



    13 years will pass between the last PM emissions
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                                                     137
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              Coralie Cooper  -  NESCAUM




reduction and the next  proposed reduction in



2007 .




            While the NESCAUM states  believe that




more stringent  PM standards  are technologically




and economically feasible  for 2004,  we expect the




EPA proposal is leaving the  .1 PM standard as is




for 2004 given  that  significant reduction down to




the .01 level are may be proposed in the 2007




range and will  be implemented after  2007.




            This will require development of




rulemaking  on both  diesel  fuel sulfur and new




engine standards within the  next year, we hope.




            The NESCAUM states urge  EPA to move




forward aggressively with  this rulemaking and NOx




PM  for the  2007 standards.   Scientific




experiments or  direct exposure to diesel PM is




met by deep public  concern and frustration over




which diesel buses,  trucks and heavy equipment,




as  has been expressed,  I think, today by a number
 of  people.
             This  coalescence of expert and public
23  opinion provides added impetus for timely  efforts
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 to reduce  PM and NOx pollution from heavy-duty




 engines.
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                                                     138
 1                 Coralie Cooper   NESCAUM




 2               In terms of the heavy-duty gasoline




    emissions  standards, in it's proposal EPA invited



    comments  on the feasibility of proposed




    heavy-duty gasoline engine standards.  The




    NESCAUM states concur with EPA that proposed




    heavy-duty gasoline standards are appropriate for




    several reasons:   First, technical advances and




    three-way catalysts now allow for durable and
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effective emissions control at the high




temperatures which can occur when heavy-duty



gasoline engines are under full load.




            Second, heavy-duty gasoline  trucks




provide ample space for placement of catalysts,




thus reducing or eliminating installation  issues




which can be associated with the installation of




three-way catalyst in the light-duty sector.




            Third, the experienced gained  with




the installation of millions three-way catalyst




over 25 years in light-duty vehicles would




facilitate a transfer of this technology from




light-duty to heavy-duty vehicles.




            NESCAUM states strongly support EPA's




proposal to extend the proposed Tier 2 gasoline




standards to vehicles up to 10,000 pounds.  More
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                                                     139
                  Coralie Cooper   NESCAUM




   and more  heavy vehicles are sold each year as




   passenger vehicles.   These vehicles must be held



   to proposed Tier 2 standards in order to keep




   pace  with increased submissions from these heavy



   vehicles .




                While technical challenges do exist,




   the phase-in schedule that is allowed under the




   proposal,  the advances in three-way catalyst that




10  have  been made and the larger space available in




11  these heavier truck wills facilitate a control of




12  emissions in trucks up to 10,000 pounds up to the
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Tier 2 proposed standards.



            The NESCAUM states strongly support



other aspects of EPA's proposal on heavy-duty



gasoline vehicles including the establishment  of



heavy-duty chassis testing, onboard diagnostics



and new engine standards.  These are important



steps which EPA should be commended on.



            There are three specific elements  of



the heavy-duty engine vehicle proposal which



happens to have been approved, which I would like



to mention.  And these apply to both diesel and



gasoline vehicles.



            The first is that there was a
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                  Coralie Cooper   NESCAUM




   manufacture-based used in testing program which



   has  been  removed for the time being; and the




   second  is an onboard diagnostic's program for




   vehicles  over 14,000; the third is an in-use




   compliance for gasoline engines.




 7               The NESCAUM states it strongly urges




 8  EPA  to  develop rulemaking to address these issues




   so that they will be implemented in the 20004
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time frame as well as the new standards.



            The in-use testing program,  the




in-use compliance requirements and onboard




diagnostics will help ensure that emissions




reductions result in new engine and emissions




standards will be realized in use.




            In summary, NESCAUM states  support




EPA's proposal to reduce heavy-duty engine




vehicle emissions, which will span the  next




decades.  The current proposal provides  NOx




reductions after 2004 for heavy-duty  engines and




begins to lay the ground work for substantial  PM




and future NOx reduction after 2007.




            The completion of this effort will




depend on the establishment of lower  diesel




sulfur fuel and in the year 2007 engine
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                                                     141
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standards.




            We  strongly  urge  the  Agency to move




forward with  these  two  initiatives  in the time




frame laid out  in  this  proposal,  and we look




forward to working  together with  you in the




development of  these  rules.




            MS.  OGE:   Thank you.   Any questions




for the panel?




            Chet?




            MR.  FRANCE:   Just a few questions for




Mr. Charbonneau.




            Pat,  is my recollection is that




NAVISTAR  did  not have to comply with the




supplemental  test.



            MR.  CHARBONNEAU:   We  provided to the




Agency  that we  did not believe that the




supplemental  testing was possible under these




standards and provided information, although they




are not covered under that policy.




            MR.  FRANCE:   I will follow that
22  question in a second.
23
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 25
             How do you see  -  what would you




 recommend  to the Agency on how can we attain the




 not-to-exceed concept and implement it by 2004?
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                                                    142
   How do you see past  that?


               MR.  CHARBONNEAU:   To  tell  you the


   truth, Chet,  I don't know  what the proper path of


5 I! that would be unless I  think  if there's 1.25 was

  I
   not to-exceed, if  it was  something in  the range


   of 1.5 that would  probably be reasonable.


               But  what I  put in my  comments, the


   EURO III testing,  using really the EURO III


   procedures on top  of the  2004 emissions standards
10


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21
   and using  our  transient  tests provides a


   tremendous  amount  of  coverage on ensuring that we


   are, in  fact,  truly going to have engines that


   around 2 grams of  NOx as we move into 2004.


                MR.  FRANCE:   I understand.


                Let  me ask the question:   You are


   suggesting,  and  I  don't  want to put you on the


   spot here  but  I  would be interested in your


   reaction.   You are implying that those provisions


   are unfeasible.   What does that say to the


   consent  decree companies that are complying?
22               MR.  CHARBONNEAU:   Chet,  all I can


23   tell  you  is  we  provided you input that says for


24   these types  of  standards,  this was not feasible


25   to do.  And  provided the Agency information, I
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                                                     143
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really can't speak  to  what  other  the  engine




manufacturers have  or  have  not  told you.   But you




had a consistent  message  on that,  and we  provided



information for you.




            MR. FRANCE:   Okay.   Thanks.




            MS. OGE:   Can I follow-up on  this?




            To the  extent that  the consent decree




companies will comply  with  the  not - to-exceed




requirements in the 2004  time frame,  would then




NAVISTAR, do you  think,  their position on the not




to exceed as far  as the  technological - -




            MR. CHARBONNEAU:   Just to be  very




            MS. OGE:   Because what would  be




happening at the  point is that  those companies




that have agreed  to meet  the  not - to-exceed, would




produce very clean  engines,  cleaner than  your




statistics  of the 2004 standards.




            My question  is:   Would then NAVISTAR




consider the technical feasibility?




            MR. CHARBONNEAU:   There is really --




there is two aspects  to  this:  The aspect of the
23  2004 standard, my comments are that when you
24
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 apply  the  not-to-exceed limits to the 2004



 standards,  you  make the standard more stringent.
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                                                     144
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   And  that  is  the clear fact you are attending to.




                The things that are not clear are




   with not - to-exceed limits, especially at the 25




   percent  level,  the impact on things like




   performance,  the ability of the vehicle to do  the




   work it  needs to do in conjunction with other




   aspects  of  transient responses are questionable




   in  light  of  the 2004 -- basically the 2 gram NOx
standard.
            So just to be perfectly  clear,  one  is
the not-to-exceed does reduce the  2004  standard




lower than we had agreed to before,  and the




not-to-exceed limits both have impact on the




things that have to do with low transient




response and economy, et cetera.




            MS. OGE:  Again, my question is:   I




thought you talked about -- are talking about
visibility.
            MR. CHARBONNEAU:  Yes.
            MS. OGE:  And you did provide
22  comments to the Agency on this issue.  We do have
23



24
a number of companies resulting  in  - -  that  have



agreed to proceed with those not-to-exceed
 25  requirements.  And they will be producing those
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                                                     145
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engines in 2002  time  frame.




            My question  is:   Would NAVISTAR at




that point




            MR.  CHARBONNEAU:   Margo,  yeah,  my




answer would be  this




            MS.  OGE:   Consider the position,




technical visibility,  that's  all I'm asking.




            MR.  CHARBONNEAU:   All of the




technologies are being utilized exactly the




same.  It is technologically  feasible to




accomplish it, and obviously  NAVISTAR would




accomplish it  using  the  same  technologies.




            MS.  OGE:   Thank you.




            Chet,  any other questions?



            MR.  FRANCE:   One  other question.




Pat, I am assuming -- this just dawned on me  --




that the concept,  maybe  a way out of this is  just




making sure that we  have have a robust NCP




available for  companies  perhaps like NAVISTAR.




            If there are other companies that are
22  not going to meet those requirements,  then  that
23
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 is  what  NCP's are supposed to accomplish.  I




 presume  that would be another alternative?




             MR.  CHARBONNEAU:   That's possible.  I
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                                                    146
   will  get  back -   once again, I'll get back  to  the




   responses.




               Based on what we have done  through




   our  testing,  the standard is going  to get much




   tougher,  and we believe that for 2004,  it would




7  now  become a technical challenge.   What I am not




8  saying is that post 2004 is not the right thing




   to do .



               MS.  OGE:  I have a question for Mr.
10




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   Carter.   Is ARE considering to address  diesel
   fuel?
   question.
               MR. CARTER:  That's  a  loaded
               MS. OGE:  Okay.



               MR. CARTER:  Well,  certainly  for 2004



   standards.  We don't  think that  you  need  to do



   anything necessarily  with the  fuel,  but  certainly



   post 2004 we do.  And certainly  it would  be



   advantageous to California if  the  fuel  sulfur



   level was reduced on  a  national  basis primarily



   because of the traffic,  interstate traffic.



               But as  far  as whether  we in



   California would do something  alone,  I  am not



   prepared to respond to  that  right  now.   I'm not
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                                                     147
                   Julie Becker - Citizen




   sure,  to  tell  you the truth.




 3               MS.  OGE:  Thank you.




 4               Anymore questions?




 5               Thank you very much.




 6               (Bernadette M. Black, RMR, was




   excused from this proceeding and was relieved by




 8  Lisa  C.  Bradley, RPR, at 2:15 p.m.)




 9               MS.  OGE:  I would ask two  individuals




10  that  I guess --  one has been scheduled to  testify




11  at  3:15 and the other one just expressed an




12  interest  to testify.  We would ask if  both of




13  them  would please step forward, Ms. Julie  Becker




14  and Ms.  Gina Porreco.
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            MS. OGE:  Ms. Becker, good afternoon.




            MS. BECKER:  Good afternoon.




            MS. OGE:  Speak to the close  to  the




microphone,  please.




            MS. BECKER:  Good afternoon.  My name  is




Julie Becker.  I'm a public health professional  who




works with community groups throughout the Delaware




Valley.   We are a coalition of organizations




dedicated to increasing awareness and directing




action that reduce toxic risks to women and




children's health from environmental contaminants.
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                                                     148
 l                    Julie Becker   WHEN




 2    I appreciate the opportunity to testify at this




 3    hearing  on behalf of our coalition members and



 4    community groups.




 5                I'd like to focus attention today upon




 6    the  relationship between smog and health issues,




 7    specifically,  asthma.  The number of asthma




 8    sufferers has  more than doubled since 1980 to more




 9    than 15  million individuals.  Currently, almost  10




10    percent  of America's children under the age of  18 is




11    sickened with  this common and costly disease.   It




12    takes a  disproportionate toll upon African-Americans




13    and  Hispanics, primarily in urban areas.  It is




14    estimated that asthma accounts for more than half a




15    million  hospitalizations per year, the cost of  more




16    than $15 billion.  Smog may account for nearly  6




17    billion  asthma attacks per year that require




18    approximately 150,000 emergency room visits at  a




19    cost of  $4.5 billion.




20                One of the greatest contributors to  smog




21    comes from cars and trucks, an increase in sales of




22    the largest SUVs, coupled with an increased




23   emissions from these vehicles which are




 24   approximately three to five times more polluting




 25   than a regular car suggests that these vehicles  are
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                                                     149
 1              Jina Porreco -  Clean Air Network




 2   contributing  more than their fair share to the smog



 3   problem.




 4                In order to begin to mitigate the health




 5   risks  to  women and their families, WHEN would like




 6   to  encourage  EPA to adopt the following:  Reduce car




 7   emissions and particulate matters from diesel




 8   engines by 90 percent by 2007, reduce the sulfur




 9   levels in diesel fuels, and to require in-use and




10   on-board  diagnostic equipment in all heavy-duty




11   trucks by 2004.




12                Potential costs for asthma-related




13   illnesses will only increase unless we begin to




14   adopt  preventative measures.  The most vulnerable of




15   our population are the children who continue to




16    confront  the chronic disease head-on unless we put




17    into place stronger standards.




18                The most stringent standards are another




19    way to begin this process and must be adopted in




20    order to  lessen the health effects of smog on




21    Americans.  Thank you.




22                MS. OGE:  Thank you.




 23               Ms. Jina Porreco.  Good afternoon.




 24               MS. PORRECO:  Good afternoon.  My name




 25   is Jina Porreco with the Clean Air Network.  I'm
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                                                     150
 1              Jina Porreco   Clean Air Network




 2   here  on  behalf of 51 citizens, environmental and




 3   public health groups from across the country that



 4   couldn't be  here today.   Thank you for providing us




 5   an  opportunity to voice  our concerns about the need




 6   to  reduce air pollution  from trucks, buses, and




 7   support  utility vehicles.




 8                Air pollution is a major threat to




 9   public health in the US.  One in three Americans




10   live  in  areas that do not meet EPA's public health




11   standards for air quality.  Millions more live in




12   areas that exceed acceptable toxic risks.  Those




13   more  sensitive to the harmful effects of air




14   pollution make up a large portion of the general




15   population,  children, the elderly, people with heart




16   and lung disease and the poor.  Nationwide, air




17   pollutions sends more than 150,000 Americans to




18    emergency rooms each year and causes more than




19    6 million asthma attacks.  Even worse, particulate




20   air pollution is responsible for cutting short lives




21    of more  than 40,000 Americans each year.  In at




22    least a  handful of cities, up to 60 percent of fine




23    particle pollution continue to be diesel exhaust.




24   in addition to causing respiratory harm, it is also




 25   a significant source of  air toxics that can cause
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                                                     151
 1              Jina Porreco -  Clean Air Network




 2    cancer.   EPA has found emission from cars trucks  and




 3    buses  account for the bulk of cancer - causing



 4    pollut ion.




 5                Despite the widespread health threats




 6    associated with chronic exposure to diesel




 7    pollution,  we still encounter diesel buses,




 8    18-wheelers, and trucks belching thick black smoke.




 9    The fact that such visible sources of air pollution




10    are still uncontrolled illustrates EPA's great




11    failures for the past three decades.  In fact,  our




12    current  diesel truck standards are lower than car




13    standards of the mid-1970s.




14                As we enter the 21st century, we need a




15    infrastructure that is clean, efficient, and doesn't




16    pose a health threat.  Technologies are available




17    today that can significantly curb diesel emissions




18    from trucks and buses.  It is time that the




19    manufactures are required to improve the diesel




20    engines, much like car manufacturers had to do  over




21   the past three decades.




22               And while shining up the new fleet  of




23   diesel engines are clean, EPA must equally commit to




,24   cleaning up the existing fleet of diesel trucks and




 25   buses.
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                                                     152
1              Jina Porreco   Clean Air Network




2                We are very pleased that EPA has finally




3   taken  steps  to reduce air pollution from trucks,




4   buses,  and SUVs.   We're particularly pleased with




5   EPA's  decision to close the loophole in Tier 2  that




6   allows  SUVs  to emit up to five times more pollution




7   than a  car.   We are also encouraged with EPA's




8   proposal  to  set tough standards on trucks, buses,




9   and  diesel fuel.



10                However, we're concerned the time we are




11   facing  a  stricter engine emissions standards and




12   clean  diesel fuel is unnecessarily long, thereby




13   delaying  any health benefits for nearly a decade.




14                Furthermore, we are concerned that  EPA's




15    Phase  2 may not adequate ensure that trucks comply




16    with the  standards over their lifetimes.




17                Specifically, we urge EPA to consider




18    the  following five points to strengthen the




19    heavy-duty program:




20                Point 1, accelerate the time line for




21    posing gas and diesel fuel.  Under the Tier 2 auto




22    pollution program, all cars and smaller SUVs will be




23   required to meet clean car a standards by 2007.




24   There's no technological need to give automakers




25   another two years to clean up the largest and
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                                                     153
1              Jina  Porreco    Clean Air Network




2   dirtiest  SUVs.   All  passenger vehicles should meet




3   clean  car standards  2007.



4                Number 2,  tighten the heavy-duty




5   particulate  standards  by 2004.  Emission catalysts




6   are  available  today  that can reduce the particulate




7   pollution by 50 percent.  Urban buses are already




8   required  to  meet the tougher particulate standard.




9   For  these reason,  in the interim, all buses and




10   trucks should  be healthier standards of .5 grams per




11   brake  horsepower hour by 2004.  Current particulate




12   reduction should then be phased in by 2007.  That




13   would  result in an additional 90 percent reduction




14   by the 2004  standards.




15                Number 3,  clean up diesel fuel for on-




16    and off road engines,-as we feel the Tier 2 proposal




17    significant  added emission reduction benefits can be




18    achieved  if  gasoline cars are brought into




19    low-sulfur fuel.  The same is true for the diesel




20    engine.  Rather than waiting until 2007 to clean up




21    diesel fuel, EPA should favor lower sulfur diesel




22    fuel between 2004 and 2007 and cap diesel sulfur at




23   no more than 10 parts per million by 2007.




24   Low-sulfur diesel is the only strategy for curbing




25   diesel exhaust in existing trucks and buses.  By not
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                                                     154
1              Jina  Porreco -  Clean Air Network




2   putting  in low-sulfur diesel before 2007, the




3   existing  fleet  will remain largely uncontrolled for




4   nearly another  decade.  Low-sulfur diesel fuel




5   should be also  be required for off road diesel




6   fleet.   According to EPA's own estimates, off road




7   diesel vehicles,  like construction equipment,




8   account  for 23  percent of all NOx pollution and 15




9   percent  of VOC  pollution nationwide.  The off-road




10   fleet  is  nearly 15 times more polluting than on-road




11   engines,  which  account for 10 percent of NOx




12   emissions and 1 percent of VOC emissions.  We are




13   alarmed  to learn that EPA tends to exclude engines




14   from the  clean  sulfur requirement.  This would be a




15   serious  and negligent shortcoming of the diesel




16   strategy.



17                Point number 4,  adopt strong standards




18    for 2007.  EPA  should set two-thirds standard at




19    least  as  strict as .01 grams per brake horsepower




20   hour and NOx standard of .2  grams per brake




21   horsepower hour by 2007.  These low emission levels




22    could  be enough with low-sulfur diesel fuel.




23                And finally, point 5, ensure that trucks




24   stay clean once they are on the road.  Diesel




25   engines  travel  hundreds of thousands of miles over
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                                                     155
1              Jina  Porreco -  Clean Air Network




2   their  lifetimes.   Tests performed on an engine




3   before  it  leaves  the plant often do not reflect




4   on-road emissions caused by engines.  For this




5   reason,  a  car owners in cities throughout the




6   country were required for over a decade to have




7   their  emissions checked to ensure they are meeting




8   allowable  pollution levels.  And new cars are




9   equipped with on  board diagnostic equipment.  The




10   same  safeguards should be in place for large trucks.




11   In  order to ensure that clean trucks stay clean,




12   in-use testing and on- board diagnostic equipment




13   should be  required for all heavy-duty trucks, both




14   gasoline and diesels.




15                Thank you again for providing us an




16    opportunity to voice our support and concerns about




17    your  proposed heavy-duty engine program.  While we




18    feel  this  is an important first step, we urge you to




19    consider our recommendations for improving the




20    effectiveness of  your program.




21                Finally, we can't stress enough the




22    importance of your finalizing the heavy-duty program




23    before the end of 2000.  Thank you.




24               MS. OGE:  Thank you.  Any questions?




25                (No response.)
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                                                     156
1                  Angle Farleigh   US PIRG




2                MS.  OGE:   Thank you very much.




3                I'd  like to call the next panel.  Ms.




4   Angle  Farleigh,  Ms. Emily Bertram, Mr. John Duerr,




5   Mr.  Kevin  Stewart,  and Mr. Alan Schaeffer.  Please




6   print  your names on the cards in front of you.




7                Ms.  Farleigh, we will start with you.




8   Good afternoon.




9                MS.  FARLEIGH:  Good afternoon.  My name




10   is  Angie Farleigh,  and I'm a clean air activist  for




11   the U.S. Public  Interest Research Group.  US PIRG  is




12   the national lobby often for the state PIRGs,




13   consumer and environmental group representing




14   citizens in over 40 states across the country.




15                I greatly appreciate the opportunity to




16    talk about the need to reduce air pollution from




17   heavy-duty vehicles, especially the large passenger




18    SUVs.



19                Across the country, air pollution is




20    taking an enormous toll on public health.




21   Nationwide air pollution sends more than  a 150,000




22   Americans to emergency rooms each year and causes




23    more than 6 million asthma attacks.  During the




24   summer smog season air pollution causes an asthma




25   attack once every three seconds.  Even worse,
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                                                     157
 1                  Angle Farleigh   US PIRG




 2   particulate air pollution is responsible for cutting




 3   short  the  lives of more than 40,000 Americans each




 4   year.   Heavy-duty vehicles, including diesel and




 5   gasoline powered vehicles over 8500 pounds, are the




 6   biggest causes of air pollution problems.  In urban




 7   areas  as much as 50 percent of the deadly




 8   particulate pollution we breathe comes from diesel




 9   vehicles.   What's especially disturbing about diesel




10   pollution is that it contains hundreds of  toxic




11    substances, and more than 30 health studies have




12    linked diesel pollution to lung cancer.




13                The manufacturers of diesel engines and




14    big trucks need to start using widely available




15    technologies to reduce their pollution.  Yet, we




16    know that we cannot count upon them to do  this




17    voluntarily, nor can we rely on the manufacturers to




18    obey the rules without strict monitoring and




19    enforcement.  Several people have already  mentioned




20    the landmark settlement last year when seven of the




21    largest diesel engine manufacturers were discovered




22    to be cheating on emission tests which resulted in




23   an increase of smog pollution of over l million tons




 24   each year.




 25               As some of you may know, PIRG  campaigned
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                                                     158
 1                  Angle  Farleigh   US PIRG




 2   last  summer  in support of tougher emission standards




 3   for passenger vehicles and to close the SUV loophole



 4   that  allowed SUVs to emit three to five times more




 5   pollution  than a passenger car.  We are, therefore,




 6   pleased  with EPA's proposal to hold the largest




 7   passenger  SUVs to the same tough Tier 2 standards as




 8   other passenger vehicles.  We also agree with your




 9   goal  to  set  tough standards on heavy-duty vehicles




10   and  fuels  that power them, as well as to require




11   strict tests to ensure compliance with  the standard.




12                However, we are extremely concerned that




13   the  proposal is phased in over an unnecessarily long




14   period of  time resulting in delayed health benefits




15   and  that the proposal may not adequately ensure that




16    the  heavy-duty trucks comply with the standards




17    throughout their useful life.  Specifically, I will




18    highlight  five changes that should be made to




19    strengthen the heavy-duty program.




20                First, the heavy-duty particulate




21    standard must be tightened by 2004.  And as Mr.




22    Bertelsen  testified earlier, MECA has shown that the




23    technology is already available to cut  particulate




 24   pollution  from heavy-duty trucks to .05 grams per




 25   horsepower hour by using existing oxidation
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                                                     159
1                  Angle Farleigh -  US PIRG




2   catalysts.   Yet  the current proposal will have the




3   public  wait  until at least 2007 before any




4   reductions  in PM from heavy-duty trucks would occur.




    This  delay  will  contribute to the premature deaths




6   of  thousands of  Americans.




7                Secondly, the time line for closing the



8   SUV loophole must be accelerated.  Under the Tier 2




9   program,  all cars and small SUVs would be required




10   to  fully  meet new car standards by 2007.  The




11   largest and dirtiest vehicles should not have an




12   extra two years  before they must fully comply with




13   EPA standards.  All passenger vehicles, regardless




14   of  size,  should meet clean car standards by 2007.




15                Third, EPA must adopt strong standards




16   by  2007.   Pollution from heavy-duty vehicles is an




17    urgent problem and must be addressed as soon as




18    possible.  There are several public studies that




19    show that by using various combinations of existing




20    technologies, manufacturers can reduction NOx




21    emissions to below the standards without an increase




22    in particulate matter.  The EPA must forge ahead as




23   the agency announced in its second phase strategy




24   and adopt additional standards in 2007 that would




25   require a 90 percent reduction beyond the 2004
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                                                     160
 1                   Kevin Stewart   ALAPA




 2   standards  of  both PM and nitrogen oxides.




 3               Also, in order to achieve necessary




 4   pollution  reductions,  the EPA must clean up diesel




 5   fuel.   Pollution control systems can be truly




 6   effective  only when they are coupled with low-sulfur




 7   fuels.   In fact, current sulfur levels in diesel are




 8   so  high,  they actually prevent the use of most of




 9   the advanced  pollution control technologies we have.




10                In order to ensure that diesel pollution




11   equipment  is  effective, all diesel fuel sulfur




12   levels  for both on- and off-road diesel fuels should




13   be  capped  at  10 parts per million sulfur by 2006 or




14   before  the 2000 standards go into effect.




15                Finally, the EPA must ensure that the




16    trucks  stay clean once they're on the road by




17    requiring  in-use testing and on-board diagnostics




18    equipment  from all heavy-duty trucks, both gasoline




19    and diesels.



20                Once again, I thank you for allowing me




21    to speak on this.




22                MS. OGE:  Thank you.




 23               Mr. Stewart, good afternoon.




 24               MR. STEWART:  Good afternoon.  The




 25   American Lung Association of Pennsylvania, ALAPA,
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                                                     161
1                   Kevin Stewart -  ALAPA




2   appreciates  the opportunity to  present comments to




3   the  EPA  concerning the proposed rule.  My name is




4   Kevin  Stewart.   I hold a Bachelor of Science Degree




5   in chemical  engineering from Princeton University,




6   and  as part  of  my duties I serve ALAPA as




7   environmental specialist.



8                I'm here today not  only  to represent  the




9   Lung Association, but the interest of everyone who




10   breathes outdoor air.  In fact, I'm  here primarily




11   to help  represent the interest  of more than 30




12   million  Americans who struggle  with  chronic lung




13   disease, and of the one-and-a-third  million or some




14   Pennsylvanians  who do.  These are people most at




15   risk for health problems precipitated by air




16   pollution.   Indeed, many of them are people who




17    simply cannot depend on outdoor air  quality without




18    risking  an unplanned trip to the hospital because of




19    the  effects  of  air pollution.




20                ALAPA was founded 107 years ago to




21    combat tuberculosis, and we are now  dedicated to  the




22    prevention of lung disease and the promotion of lung




23   health.   ALAPA commends EPA for issuing a good




24   proposal; nonetheless, it can be strengthened in




25   several  ways.  Ozone smog continues  to be frequently
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 1                   Kevin Stewart   ALAPA




 2   recorded  at  levels that are hazardous to health.




 3   Not  only  are more stringent vehicle and fuel




 4   standards a  necessary part of the solution




    preventing thousands of cases of death and disease,




 6   but  cost  effective technology soon will be




 7   available, and in some cases, already is available,




 8   to meet  such standards.  It is on this basis that




 9   ALAPA calls  for the adoption and expeditious




10   implementation of strong national standards for




11   emissions from heavy-duty vehicles and for the fuel




12   that is  used to operate them.  We also call on EPA




13   to make  sure that these vehicles comply with those




14   emission standards for as long as the vehicles




15    remain in use.



16                While I've deferred today to other




17    representatives of American Lung Association who




18    have submitted to the docket more detailed comments




19    on  the proposed rule, I will make several brief




20    comments on the rule itself.  But before that, I




21    will strive to show you what the presence of these




22   pollutants in the air we breathe means to the people




 23   of  Pennsylvania.




 24               Despite what progress we've made over




 25   the  last 30 years, air pollution continues to be a
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1                   Kevin Stewart   ALAPA




2   very  real  and very serious problem.  Pennsylvania




3   experiences  dozens of days every year during which




4   unhealthful  ozone levels are record.   My hometown




5   of  Lancaster, for example, experienced 25 days of




6   unhealthful  ozone this year and is now in violation




7   of  even the  rather weak one-hour standard.  Motor




8   vehicles,  along with the entire network that




9   supports their use, are significant sources of air




10   pollution ranging from ozone precursors to




11   particulate  matter to air toxics.  And lest we lose



12   sight of the fact, air pollution constitutes a real




13   problem.  It causes real suffering and even death to




14    real  people-  Four groups are at special  risk:




15    infants and  pre- adolescence children, the elderly,




16    persons with asthma, and those with COPD, chronic




17    obstructive  pulmonary disease, chronic bronchitis,




18    and emphysema.




19                In Pennsylvania, the populations of




20    those at risk from ozone and particulate  air




21    pollution include two million children at or below




22    the age of 13 and 1.7 million people aged 65 or




23   above.  Furthermore, ALAPA reiterates today that




24   about 11 percent, 1 in 9, of the Commonwealth's




25   citizens suffer from 1 or more major chronic lung
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                                                     164
1                   Kevin Stewart -  ALAPA




2   diseases  and are particularly at risk from air




    pollution.   Among them are the more than 700,000




4   individuals  who suffer from COPD.  And in addition,




5   recent  estimates show that some 800,000 citizens of




6   this  state  has asthma.  About 30 percent of these




7   people  are  under 18, for whom asthma is the




8   number-one  for hospitalization due to chronic




9   illness.   It is also the number-one cause of school




10   absences  attributed to chronic conditions, leading




11   to an average of a week and a half of school missed




12   annually  by each student who has asthma.  Even more




13   alarming, deaths from asthma have been climbing




14    steeply,  increasing by 117 percent nationwide, from




15    2,598 in  1979 to 5,637 in 1995, with the increase




16    focusing  among children and the elderly.




17                In Pennsylvania alone, studies show,




18    ambient air pollution is responsible for hundreds of




19    thousands of days with acute respiratory symptoms




20    and/or restricted activity for tens of thousands of




21   asthma symptoms days, for thousands of emergency




22 j  room visits for respiratory problems and thousands




23   of excess hospital admissions for respiratory




24   diagnoses such as asthma, pneumonia, and COPD.  And




25   finally,  air pollution from vehicles alone is also
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1                   Kevin Stewart -  ALAPA




2   responsible  for hundreds of premature deaths in the




3   Commonwealth every year.




4                As  for my comments  on the proposed rule




5   itself,  we  at ALAPA have several concerns and think




6   that  the proposals can be strengthened in the




7   following ways:




8                One, given the fact that the technology




9   necessary for the largest support utility vehicles




10   to  meet  the  proposed standards  is already available,




11   within EPA's estimated cost range, and with the




12   added benefit of significant reductions in emissions




13   of  air toxics,  it is ALAPA's opinion that there is




14   no  reasons to delay implementation of the standards




15   relative to those already set out for lighter SUVs




16    in  the Tier 2 proposal.  Eight  years, by 2007, is




17   more  than enough time to implement the new




18    standards.



19                The heavy-duty fine particulate emission




20    standard should be tightened at least 50 percent by




21    2004  rather than having the public wait until at




22    least 2007 for any reductions with the concomitant




23    illness and mortality.



24               Number 3, furthermore, under its




25   proposed anticipated Phase 2 strategy, EPA should
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1                   Kevin Stewart -  ALAPA




2   set  a  nitrogen dioxide emission standard stricter




3   than 0.2  grams per brake horsepower hour and a




4   particulate  matter emission stand stricter than 0.01




5   grams  per brake horsepower hour, and should proceed




6   to  adopt  these standards under an accelerated




7   schedule,  preferably by 2004, with the paired




8   requirements that the best available control




9   technology be used, and that low-sulfur diesel fuel,




10   removing  at  least 90 percent of sulfur, preferably




11   more,  be  put into place.



12                Number 4, there should be no sense to




13   continue  to  allow sulfur levels in fuel to be as




14   high as 500  parts per million when we know that such




15    fuel wastes  much of the investment spent on the




16    cleaner burning technologies.  We must work harder




17    to get the highest sulfur fuels out of the market




18    sooner.



19                Five, finally, EPA must take steps to




20    ensure that  in-use emissions from all heavy-duty




21    vehicles, both gasoline and diesel, both highway and




22    non-highway, actually meet the standards.  The past




23    behavior of  some engine manufacturers




24   notwithstanding, this is not a game.  In-use testing




25   and on-board diagnostics should also be required.
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                                                     167
1                    Emily Bertram   NET




2                In conclusion,  we know that ozone and




3   particulate  air pollution in Pennsylvania, much of




4   it  from  vehicle emissions,  adversely affects the




    health of  substantial numbers, indeed millions of




6   our citizens.   And we know that those adverse health




7   effects  are  substantial, resulting in thousands of




8   hospital admissions, emergency room visits, and even




9   deaths,  with further costs of hundreds of thousands




10   of  disrupted lives and hundreds of millions, perhaps




11   billions,  of dollars.  It is now clearly  our




12   national task to attain and maintain helpful air




13   quality.  The only way we can begin to do that is to




14   recognize  the full reality of air pollution problems




15   and to  face  them unflinchingly.




16                There's one thought I'd like  to leave




17   you with,  one to remind of.  It's that air pollution




18    not simply am inconvenience.  Being unable to catch




19    your breath  is not an inconvenience.  Trips to the




20    emergency room, hospitalization, and deaths are not




21    inconveniences.  Remember,  it's a health  issue.




22                MS. OGE:  Thank you.




23                Ms. Emily Bertram, good afternoon.




24               MS. BERTRAM:  Good afternoon.  My name




25   is Emily Bertram,  and I am the Delaware field
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                                                     168
1                    Emily Bertram   NET




2   organizer  for National Environmental Trust.




3   National Environmental Trust is non-profit,




4   non-partisan organization dedicated to educating the




5   American public on contemporary environmental




6   issues.  Since it was founded in 1995, National




7   Environmental Trust has worked to promote strong




8   health,  safety, and environmental protections on




9   issues  including food, air, drinking water safety,




10   global  climate change, and public right to-know




11   policies.



12                As the Delaware field organizer, I spend




13   a great  deal of time interacting with different




14   communities throughout the state, particularly the




15   cities  of  Wilmington and Newark.  I have  particular




16   concern  for the well-being of Delawareans and the




17   preservation of the surrounding natural environment.




18    Thank you  for giving me the opportunity to voice my




19    concerns  about the need to reduce air pollution from




20    heavy-duty vehicles.




21                In the state of Delaware, air pollution




22    has taken  an enormous toll on human health.  In a




23    mid-season report released in August 1999, ozone




24   monitors in Delaware reported 54 exceedences of the




25   eight-hour ozone health standard and a total of 12
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1                    Emily Bertram   NET




2   days  of  unhealthy air.   For example,  the peak ozone




3   level  at Lums  Pond,  a recreational area in New




4   Castle County,  Delaware,  was 119 parts per billion,




5   a  full 33  percent higher than the health standard.




6   Peak  ozone levels in the beach communities this




7   summer were recorded at 104 parts per billion, while




8   ozone  levels in Wilmington, Delaware's largest city,




9   were  recorded  at 98 parts per billion.




10                Heavy-duty diesel trucks and buses, as




11   well  as  large  SUVs,  are among the biggest




12   contributors to smog in Delaware.  Delaware serves




13   as a  thruway for traffic traveling between the New




14   York-Philadelphia and Baltimore-Washington




15   metropolitan areas.  Unfortunately, pollution from




16    all the trucks, buses,  and large SUVs on such




17    highways as 1-95 tends to be transported through  the




18    atmosphere and accumulates over the State of




19    Delaware.   Beach traffic in the southern part of  the




20    state also contributes to an overall increase in




21    pollution levels in the summer months.




22                High pollution levels pose a serious




23    health threat  to Delawareans.  Children, the




24   elderly, and the asthmatics are particularly




25   vulnerable to  smog.  According to a recent study,
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                                                     170
1                    Emily Bertram   NET
2




3




4




5




6




7




8




9




10




11




12




13




14




15




16




17




18




19




20




21




22




23




24
smog sends 210 Delawareans to  the  hospital  and




causes 25,000 asthma attacks  in  Delaware  each



summer.  Nationwide, asthma  rates  among  children are




up 75 percent since 1980, with 4.6 million  children




suffering from asthma.   Smog  is  responsible for up




to 10 percent of all hospital  admissions  during the




summer months.




            The Delaware field office  of  National




Environmental Trust applauds  EPA for their  proposal




to clean up the nation's largest and dirtiest




vehicles.  However, we  would  encourage EPA  to




consider the  following  changes in  order  to




strengthen the heavy-duty program:




            First,  accelerate  the  time line for




closing the SUV loophole.  Under the Tier 2 auto




pollution program,  all  cars  and  smaller  SUVs will be




required to meet clean  car standards by  2007.




However, under the  heavy-duty  vehicle  proposal,




automakers would have until  2009 to clean up larger




SUVs.  All passenger vehicles,  no  matter  what their




size,  should  meet  clean car  standards  by  2007.




            Second, tighten  the  heavy-duty




particulate standard at least  50 percent  by 2004.
 25   The current proposal would have the public wait
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                                                     171
1                    Emily Bertram -  NET




2   until  at  least  2007 before any reductions in




3   particulate  pollution from heavy-duty trucks would




4   occur.   This delay will contribute to the premature




5   deaths  of thousands of Americans.




6                Third, adopt stronger standards for




7   2007.   Pollution from heavy-duty vehicles is an




8   urgent  problem that must be addressed as soon as




9   possible.  By 2007, smog-forming pollution and




10   particulate  pollution from heavy-duty vehicles




11   should be lowered by 90 percent beyond 2004




12   standards.



13                Fourth, clean up diesel fuel.  Pollution




14   control systems can be truly effective only when




15   they are coupled with low-sulfur fuels.  To ensure




16   that diesel  pollution equipment is effective, all




17    diesel fuel  sulfur levels in both on-road and




18    off-road diesel fuels should be capped at 10 parts




19    per million sulfur by 2008.




20                Finally, ensure that the trucks stay




21    clean once they are on the road.  Lab tests rarely




22    reflect the true on-road emissions.  To  ensure that




23    clean trucks stay clean, in-use testing  and on-board




24   diagnostic equipment should be required  for all




25   heavy-duty trucks, both gasoline and diesel.
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                                                     172
1                John Duerr -  Detroit Diesel




2                These measures are critical to the




3   protection  of  the public  health and the natural




4   environment.




5                Thank you.



6                MS.  OGE:   Thank you.




7                Mr.  John Duerr.  Good afternoon.




8                MR.  DUERR:  Good afternoon.  My name




9   John  Duerr, and I'm here  representing Detroit Diesel




10   Corporation.   Detroit Diesel is a major manufacturer




11   of  diesel  engines used in a wide variety of




12   on-highway  vehicles.   The rulemaking that is the




13   subject  of  today's hearing proposes several new




14   requirements for these engines.




15                We appreciate this opportunity to




16   provide  our views on this proposed rule.  Let me




17   begin by stating that Detroit Diesel fully endorses




18    the comments of the EMA.   Let me go on to state that




19    Detroit  Diesel generally supports EPA's affirmation




20    of the 2004 standards and many of the other




21    provisions  included in this proposed rulemaking.   I




22    had hoped that we would be in a position to provide




23    much more detailed comments at this hearing.




24   Unfortunately, this is not the case.




25               This rulemaking was first made available
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                                                     173
1                John Duerr -  Detroit Diesel




2   for public  review on October 7th when it was posted




3   on the  EPA  web site.  Since then,  we have been




4   trying  to review and digest nearly 600 pages of




    regulatory  documents.  This has not been an easy




6   task.   The  proposed rule contains a number of very




7   complex and interrelated provisions that greatly




8   modify  the  existing regulatory program for




9   heavy-duty  engines.  A number of the changes were




10   incorporated in the proposed rule at the last minute




11   and were not previously discussed with industry.




12   The impacts of these changes are potentially




13   far-reaching and difficult to evaluate.  Further




14   complicating our assessment of the proposed rule is




15   the fact that the rule contains drafting errors,




16    inconsistencies, and entire sections that lacks




17    clarity.




18                DDC has three primary concerns with the




19    current state of the rulemaking.  First of all, the




20    lack  of adequate time for review and the




21    inconsistencies in the rule leave us unclear about




22    several of  the provisions and the requirements we




23    will  need to meet under the proposed rule-




24               Secondly, certain requirements, as we




25   understand  them, may in fact lead to a greater level
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                                                     174
1                John Duerr -  Detroit Diesel




2   of stringency than we had previously understood.




3                Furthermore,  certain test requirements,




    while  not  necessarily adding stringency, add




5   substantial  cost with little or no emission benefit.




6                Finally,  EPA has not provided any data




7   or analysis  that addresses the question of whether




8   the  2004  standards are feasible with current levels




9   of fuel  sulfur while also meeting the extended




10   useful life  and supplemental test requirements.  The




11   lack of  information on this critical issue puts us




12   in an  environment of making important decisions




13   regarding  feasibility without adequate information.




14                To help in clarifying the point about




15   the  lack of  clarity in the proposed rule, let me




16   provide  a  couple of examples which may seem small




17    and  detailed, but are actually critical to our




18    understanding the requirements of this rule.




19                Consider the equation in Paragraph




20    (e)(5) of  Section 86.1360-2004 as shown here.  This




21    equation is  to be used to compute the weighted




22    average  emissions for each regulated gaseous




23    emissions  over the proposed supplemental



24   steady-state emission test.  Leaving aside the fact




25   that this  equation will always return a value of
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1                John Duerr -  Detroit Diesel




2   infinity,  and thus is obviously incorrect, we note




3   that  the  factor A(wm) used in this equation is




4   identified as weighted mass emission level as




5   defined  in existing Section 86.1342.  A(wm) as it is




6   defined  in 86.1342 is the weighted brake specific




7   mass  emissions from the cold/hot transient federal




8   test  cycle.   Clearly, this is not an appropriate




9   value for inclusion in computing emissions from the




10   steady-state test.  We also note that even though a




11   particulate standard is proposed for the




12   supplemental steady-state test, this section fails




13   to describe how the weighted particulate emissions




14   are to be computed.



15                A second example concerns Section




16    86.1008-90 which states that engines chosen for




17    Selective Enforcement Audit testing are to be tested




18    on the Federal Test Procedure described in Subpart




19    N.  The proposed rule adds several new supplementary




20   teat procedures to Subpart N.  It is not  clear if




21   EPA intends to require that these new supplementary




22   tests be run as part of any Selective Enforcement




23   Audit.  And if these supplementary tests are




24   required to be run, EPA has not specified  the




25   ambient conditions and other test protocols to be
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1                John Duerr -  Detroit Diesel




2   used when  these supplemental tests are run as part




3   of an  audit.   Further, there is no definition of how




4   compliance with the newly proposed not - to-exceed and




5   maximum  allowable emission limits will be determined




6   and how  overall audit pass/fail decisions will be




7   made.  Without a clear understanding of how




8   Selective  Enforcement Audits will be conducted and




9   judged,  DDC cannot provide constructive comments nor




10   can we as  a company determine the impact of our




11   products,  and the feasibility of meeting the




12   agency's expectations.




13                While these examples may seem to address




14    fine  technical points of the regulation, they are,




15    in fact, important issues that may have substantial




16    impact on  our products and the stringency,




17    feasibility,  and cost effectiveness of the rule.




18    Furthermore,  these examples are not isolated, but




19    are representative of a great many cases where the




20    proposed rules are incomplete or unclear.  Because




21   of the lack of clarity in the proposed regulations,




22   we are having difficulty in understanding the




23   agency's intent and thus are unable to comment




24   meaningfully and constructively on the proposal.




25   Indeed,  unless steps are taken to redraft the
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1                John Duerr   Detroit Diesel




2   proposal  so that the agency's intent is made




3   sufficiently clear to allow interested parties to




    understand the proposal and provide meaningful




    comments,  we believe the fundamental principles of




6   due  process will have been shortchanged.  We know




7   that EPA  and the industry share a common interest in




8   ensuring  that the regulations that are finally




9   promulgated are clear, correct, and unambiguous.  To




10   ensure that the public process is not shortchanged




11   and  that  the final rule is free of uncertainty and




12   inconsistency, we believe EPA must extend the




13   comment period by at least 60 days and work closely




14   with the  various stakeholders during this period.




15   These regulations will be in effect for several




16   years.  Surely, there is no reason not to take the




17    time to make certain this rule is the best we can




18    make.



19                While many of the details of the




20    proposed rule are unclear, it is clear that EPA




21   intends to impose several new testing requirements




22   and associated emission limits.  These include a




23   supplementary steady-state emission test, maximum




24   allowable emission limits, not - to-exceed emission




25   limits, and load response testing.  These additional
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                                                     178
1                John Duerr   Detroit Diesel




2   requirements will add considerably to the cost of




3   engine  development and certification and will extend



4   the  time  needed to bring new low emission technology




5   to market.   Collectively, they constitute a belt and




6   suspenders  example of regulatory overkill.  To




7   reduce  redundancy and improve the overall




8   cost - effectiveness of the proposed rule, we believe




9   that,  at  a  minimum, the maximum allowable emission




10   limit  and load response test requirements should be




11   eliminated  and that the not - to-exceed provisions




12   should  be greatly simplified.




13                In conclusion, DDC requests additional




14   time to provide constructive and complete input




15   based on  a  clear understanding of the proposed




16    requirements.  We request that the agency carefully




17    review  the  necessity of all the proposed additional




18    testing requirements in light of the marginal




19    emission  benefits of these provisions.




20                Finally, we believe additional data




21    gathering and information development is needed




22    before  it can be determined that the 2004 emission




23    standards remain feasible when combined with




24   extended useful life and supplemental test




25   requirements and without any improvements in diesel
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                                                     179
1      Alan  Schaeffer -  American Trucking Association




2   fuel  quality.



3                Detroit  Diesel is continuing to review




4   and  study the  proposal.  We anticipate providing




5   comments on as many  of the critical issues as




6   possible within the  allowed comment period.  If DDC




7   concludes that the proposed rule increases




8   stringency beyond the level that we have agreed to




9   meet  in  October 2002 as result of our agreement,




10   then  DDC will  object to this rule.




11                Thank you.



12                MS. OGE:  Thank you.




13                Mr. Alan Schaeffer.  Good afternoon.




14                MR. SCHAEFFER:  Thank you.  Good




15    afternoon.  My name is Alan Schaeffer and  I'm vice




16    president of highway environmental policies for the




17    American Trucking Association located in Alexander,




18    Virginia.  Thanks for the opportunity to appear here




19    today on the important issue of diesel engine




20   emission standards.   Just as a matter of record, ATA




21   is a national  trade association representing




22   America's trucking  industry.  We represent over




23   3,000 members  directly of all types and sizes of




24   trucking companies  throughout America.  Within our




25   federation of  state affiliates, collectively that
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                                                     180
1      Alan  Schaeffer -  American Trucking Association




2   numbers  jumps to 35,000 trucking companies



3   nationwide.




4                I'm here today on behalf of the users  of




5   heavy-duty  diesel trucks.  Most of our members




    operate  vehicles over 8500 pounds, and most of  those




    are  over 26,000 pounds in weight.



                 The trucking industry does the work  that




 9   all  of  us in the economy demand, and everything  you




10   see  here today and brought with you today, that  you




11   ate  today,  that you're wearing today, was brought  to




12   you  by  a truck.  And because of that, our industry




13   demands  the most cost effective, fuel efficient, and




14    lowest  polluting technology available, and we




15    believe  that the engine manufacturers are delivering




16    that technology.




17                Also, as matter of record, the trucking




18    industry has a long record of responsibility




19    supporting clean air standards.  Let me highlight  a




20    few of  those.  We supported the change to lower




21   sulfur  diesel fuel back in 1993.  We support limits




22   on discretionary items.  We support vehicle smoke




23   emissions inspection programs at the state level.




24   And we  are here today to offer our support for  the




25   2004 lower engine standards.  We have been involved
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1      Alan  Schaeffer -  American Trucking Association




2    in the  1996  standard proposal and joined EPA at the




3    press  conference in Chicago, along with the engine




4    manufacturers,  to endorse more stringent lower




5    emission standards in 2004, knowing full well that




6    may  increase the cost of the trucking industry.




7    However,  we  felt that that was the responsible thing




8    to do  for the environment to help reduce pollution.




9                Our commitment has been heightened in




10    the  last six months.  In June our executive




11    committee adopted more aggressive policy urging




12    states  to begin enforcement against smoke emissions,




13    and  just on  Sunday of this week we adopted a




14    resolution supporting a national diesel fuel




15    standard with details to follow.




16                And the commitment by the trucking




17    industry has paid off.  Today's new truck engines




18    emits  one-eighth of pollution of engines built just




19    10 years ago.  That's a significant record.




20               Highway diesel truck emissions have




21   played an important role in dramatically improving




22   air quality overall in recent years.  A lot of what




23   we have heard today is the negative, that is, how




24   bad things are; but consider the positive about air




25   quality.  In the period of  1970 to 1997, the first
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1      Alan  Schaeffer   American Trucking Association




2   domestic product of the United States grew by 114




3   percent  constant dollars.   Our population grew by 31




4   percent.   At  same time our total criteria for




5   pollutant emissions declined by 34 percent.




6   Significant improvements have been made in air




7   pollution,  and the trucking industry is proud to




8   contribute its fair share.




9                I'd like to address a couple aspects of




10   the  notice today.  First of all, on the concept of




11   feasibility,  it was our view initially having




12   assessed this proposed rule in the limited time




13   we've had to do it, that in fact this is technically




14    feasible milestone in 2004.  However, I must admit




15    to the agency that I'm becoming concerned that what




16    appears  to have been agreed on in 1997 in fact




17    become a final rule, that the landscape has been




18    dramatically altered since that time.  And that




19    landscape has been altered without public input from




20    users, environmental groups, and others in the form




21   of a decent decree process.  And I guess we are




22   concerned that the fact that we're hearing more and




23   more from manufacturers about the new limits that




24   the agency is imposing has, in fact, the effect of




25   lowering the standard that is in federal rules
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2   today.   That  gives us great cause for concern.  We




    don't  manufacture or certify engines, we're only the




4   ones  that  buy and use the engines.  We have to rely




5   on that  kind  of information.  So we're concerned




6   that  there may be, not only a more stringent




7   standard that will have impacts on fuel economy,



8   durability,  and et cetera, but we're also concerned




9   about  the  process by which that standard appears to




10   be altered.   Because if in fact the agency is




11   promoting  a rule that is a lower standard than the




12   standard that is published, as you know, the




13   American Trucking Association has great concern




14   about  some of the processes with how the clean air




15   standards  are, in fact, established.  And we share




16    those  concerns now on this specific rule.




17                We do agree with the agency's assessment




18    at  this  point that no changes in diesel fuel




19    specifications are required to meet 2004 standards.




20    We,  as I mentioned,  have taken a position about




21    future national fuel policy, we believe it should be




22    a national standard that affects all diesel users,




23    both on-road and off-road engines.  So we support




24    the  agency assessment in that area.




25                With regard to the durability
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2   requirements,  back in 1997,  users of heavy-duty




3   vehicles are very concerned about reliability,




    maintainability,  and durability of those engines.




5   And  it  has  been pointed out earlier today, the




6   engines  are lasting longer than ever before, they're




7   operating more efficiently,  and emitting less



8   pollution.




9                In going forward,  it is our




10   understanding that some new technologies will be




11   employed that we have not seen before, exhaust gas




12   recirculation being one of the primary ones of




13   those.   We  argued very successfully back in that




14   proposed and final rulemaking period to extend the




15   useful  life and durability requirements from 290,000




16    to 435,000  miles for the largest on highway diesel




17    engines.  That was important to users then and it is




18    important to users today that we retain that




19    durability  requirement.




20                As indicated in the notice, the agency




21    anticipates the use of EGR will play a primary role,




22    allowing manufactures to meet those 2004 standards.




23    We very much like the idea of 435,000 mile




24   requirement staying in place.to make sure that these




25   new and as-of-yet unproven systems are robust in
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2   their  design  and performance throughout the lifetime




3   operation  of  the engine.   We don't want to see any




4   backsliding  of  that  number.




5                However, I have to go back to the point




6   that  that  assessment was made under the circumstance




7   without  the  settlement and under the certification




8   and  test procedure that we understood would be in




9   place  in '96  to '97  when the rule was enacted.  And




10   to  the extent that it becomes more complicated as a




11   result of  the settlement, we don't believe that the




12   agency can properly adjust what they have in  federal




13   rules  right  now with regards to durability based on




14   something in the consent decree that, in fact, was




15   not  subject  to public input, comment, and due




16   process.



17                We're very concerned because the  EGR




18    systems, if  they are not robust in their performance




19    and durability, they have a potential to break down,




20    become a maintenance headache and to reduce fuel




21    economy, and that's a user issue.  We don't want to




22    be on the receiving end of that.




23                With regard to the agency's proposals




24   for on-board diagnostic sensors for heavy-duty




25   engines, we generally support that, providing the
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2   proper SA  standards  are utilize that are consistent




3   heavy-duty vehicle maintenance standards now-  I'll




4   give  you some specific comments on that.




5                With regard to economic impact




6   assessment,  as I mentioned at the outset, the




7   industry fully supported the 1997 final rule and




8   lower standards, knowing full well that the increase




9   of cost  to folks that bought new heavy-duty diesel




10   engines.  It appears as though that the EPA just




11   rerun the  numbers and the numbers are higher to the




12   tune  of  74 percent increase in the case of lifetime




13   operating  cost and also increase in terms of the




14   initial  purchase price on these engines.  So that




15   raises  some concern for us as well about how we got




16   to those new numbers because it appears that the




17    same  technologies, i.e., EGR and turbo charge




18    geometry were contemplated then and, in fact, are




19    contemplated today.   The only thing I can conclude




20    is  that  the higher cost have come from additional




21    certification testing requirements that were, in




22    fact, imposed by consent decrees, which again raises




23    the  question about whether or not the users and




24    other stakeholders had an opportunity to comment on




25    issues that affect economic impact of this rule in
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2   the  proper setting.




3                Finally, with regard to future diesel




4   engine  emission standards, we are exploring within




5   out  membership right now that very question.   In




6   fact, we're just having our convention right now in




7   Orlando  and it is the topic of hot debate.  We are




8   not  prepared at this point to render some kind of




9   view of  what the rate for any future standard  should




10   be.   One thing that resinates very loud and clear




11   with the nation's top trucking executives, and that




12    is  that  we have done our fair share of cleaning up




13    the  air.  We will do more, but we expect the agency




14    to  hold other sectors accountable.  When you look at




15    the  charts within the proposed rule regarding  the




16    contribution of NOx and VOC emissions for heavy-duty




17    diesel  vehicles, we're talking 11 percent, 10




18    percent of NOx, 1 percent of VOC in 2000; and




19    non-road engines, 23 percent NOx and 15 percent VOCs




20    in 2000.



21                I drove up here today in a 1999 Honda




22    Accord,  which is a ULEV card certified vehicle.  The




23    majority of the trucks that I passed on Interstate




24   95 were late model, 1994, later model year trucks,




25   best I   could tell.  And we have a hard time
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 2   wondering  about the  equity with doing more to clean




 3   up the air while the non-road sector is doing,




 4   apparently,  less and less.  The agency is also




 5   failing  to hold the  non road sect the same




 6   improvements in diesel fuel quality that they held




 7   the  trucking industry to, and we think the time for




 8   that has come to an  end, specifically, with railroad




 9   emissions.  The trucking industry has been regulated




10   since 1970 for emissions for new engines.  Only last




11   year,  a  full eight years after the enactment of the




12   1990 amendments, did EPA issue standards for




13   locomotive engines and unfortunately did not see it




14    fit  locomotives would have to use the same level of




15   diesel  fuel that we're using today.  So as I look




16    out  the  window here, I see the trains going by the




17    switching yard knowing that they're using diesel




18    fuel that has significantly higher levels of sulfur




19    and some of those are competing directly with




20    trucks.   We're not too happy about that.




21                So in conclusion, we appreciate the




22    opportunity to appear here today to talk about the




23    future diesel engine standards.  We urge the agency




.24   to retain the numbers as you have them today.  We'd




 25   like to  hear some more dialog and understand more
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2   about  the  impact  of the consent decree certification




3   testing  issues  on the effective levels of standard.




4   It appears to be  that the standard might be in




5   effect been lowered by the consent decree, and that




6   can  be a problem.  We also want the agency to retain




7   the  435,000 mile  durability requirement.  We don't




8   want to  see any negotiations with regards to useful




9   life and diesel fuel modifications, and we think




10   very much that  the agency should focus more




11   resources on controlling the bigger unregulated




12   pieces of the pie, which is the non-road sources.




13                And just a final comment to address a




14    large number of folks that testified this morning




15    with regards to in-use emissions.  EPA has been our




16    primary  motivator to get some help in this area, but




17    I think  it should be made clear that the issue about




18    in-use enforcement is not the agency's prerogative;




19    this is  a state issue.  And all I can say to that,




20    to Bill  Becker and the state folks is, where are




21   you?  The trucking industry is ready to work with




22   you to have state emissions control programs.




23   About 13 states have inspection maintenance programs




24   right now.  We think that criticism toward EPA




25   should be directed toward the state.  So if you want
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1      Alan  Schaeffer   American Trucking Association




2   to talk  about that,  our industry and ATA which




3   represents  responsible trucking companies, we agree



4   with  you,  but get the gross emitters off the road




5.  and let's  not indict the entire industry for the




6   emissions  of just a few.  Thank you very much.




7                MS.  OGE:  Thank you.  I will let Bill




8   Becker know.




9                Mr.  Duerr, thanks for your statements.




10   I  have a couple of questions for you.  When did you




11   first see  the proposal?  When did you have access  to




12   the proposal.



13                MR.  DUERR:  October 7th.




14                MS.  OGE:  October 7th, so you had almost




15    30 days?



16                MR.  DUERR:  Yes.




17                MS.  OGE:  How many times have your




18    company and our staff got together for this past




19    year  to discuss this proposal, I mean, details,




20    exhaustive details?  Do you remember?




21                MR.  DUERR:  I don't remember.




22                MS.  OGE:  I would say many times.




23                MR.  DUERR:  I don't believe our company




24   ever  directly interacted, but we did participate  in




25   the  manufacturers meetings.
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2                MS.  OGE:   Let me say this.  One of the




3   reasons  that we  are  late with this rule, Mr. Duerr,




4   is because  we have been meeting with your company




5   and  many other companies and we have many times for




6   the  past year to make sure that indeed the industry,




7   your industry, was comfortable with the technical




8   issues.   To the  extent that we had the package




9   completely  ready and we pulled out substantially




10   around this in-use testing because we agreed with




11   your industry that we need to spend a little bit




12   more time.   So I'm somewhat disappointed through




13    this public hearing when I hear that you didn't have




14    enough time to discuss issues, technical issues.




15    And  I would like speak about it outside of this




16    public hearing.   But for the record, one of the




17    reasons  that we are late is because of the




18    substantial efforts this office has made, put




19    forward, working with your industry.




20                Any questions?




21               MR.  FRANCE:  Mr. Duerr, in the context




22   of  concerns with lead time that's been expressed by




23   a variety of individuals today, including EMA, I'd




24   like a little bit of clarification from Diesel's




25   perspective.  Assume for a second that our intent
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   Alan Schaeffer   American  Trucking Association




was to capture  the  essence  of  the  consent decree




supplemental  test requirements.   So  accept that as a




premise.  What  is Detroit  Diesel's prospective on




lead time,  specifically  the limitation of the




supplemental  requirements.




            MR.  DUERR:   Obviously, today under the




consent decree,  we're  meeting those  requirements.




            MR.  FRANCE:   What will you do in 2004?




            MR.  DUERR:   In 2004,  I don't think we




fully know  what the impact of all  these requirements




will be at  two  and  a  half  gram NOx level.  We're




still studying  that.



            MR.  FRANCE:   I understand.  To the




extent    just  accept  the  premise  that the consent




decree  is consistent  with  the requirement bing 2004




under our rules,  okay?   What  would you like to see




the program look like  in 2004 from a federal




perspective?



            MR.  DUERR:   I  think I  noted I would like




 to see  the  maximal  allowable  emission limits be




 eliminated, the low response  test  be eliminated.




            MR.  FRANCE:   You're suggesting that we




 delete  not  to exceed?
 25               MR. DUERR:  No, we're suggesting
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1      Alan  Schaeffer   American Trucking Association




2   simplify not to exceed.




3                MR. FRANCE:  To make it a minimal



4   requirement in 2004?




5                MR. DUERR:  Yes.




6                MR. FRANCE:  How do we  reconcile  that




7   with  DMA's comments and others that we  can't  do




8   that?  How do you suggest that we go?




9                MR. DUERR:  I don't understand  your




10   question.



11                MR. FRANCE:  You're suggesting  that  we




12   do make it mandatory  in 2004.




13                MR. DUERR:  We're not opposed  to  that,




14   provided we can get clarity on the  regulations.




15                MR. FRANCE:  So from Detroit Diesel's




16     perspective, you want to hold the  agency  to  its




17    former lead time concerns that were raised  by EMA?




18                MR. DUERR:  No.




19                MR. FRANCE:  Thanks.




20               MS. OGE:   Any other questions?




21               MR. HOROWITZ:  Mr. Duerr,  did  you or




22   anyone from DDC ever  see any drafts of  the




23   regulations before  October 9th, or  that date  you




.24   mentioned?



25               MR. DUERR:  I believe there was a






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partial draft made  available.   I  don't recall the
time frame.
            MR.  HOROWITZ:   Did you look through the
draft at that  point  to  see  -  to look at these




issues at  that point?   The issues you brought up




today with the inconsistencies,  did you have a




chance at  any  prior  drafts to  look in detail at the




drafts that it had inconsistencies?




             MR.  DUERR:   We did review the draft we




had  received.   But again,  it was sort of out of




context  so we  didn't see the full scope of what was




being proposed.   And we didn't at that time look




through  it in  as much detail as  we obviously are




doing now.



             MR.  HOROWITZ:   Thank you.




             MS.  OGE:  Mr.  Duerr, I would strongly




recommend  that you get  in touch  with Chet France




sitting  next to me.   We will make ourselves




available  you  and your  staff to  clarify any issues




 that you have  raised today or  you have.




             MR.  DUERR:   We would like to do as soon




as we  can  finish our review.  We'll be happy to do




 that.
 25               MS. OGE:  Great.
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1      Alan  Schaeffer   American Trucking Association




2                Mr.  Schaeffer:   You mentioned about two




3   things that  I would follow-up with you.  Again, I



4   don't know how much you can disclose at this public




5   hearing,  but I would like to know when we can get




6   more details.  You mentioned a resolution ATA




7   passed,  I believe, last week on diesel fuel quality




8   and  I believe you also stated that there is going to




9   be an upcoming meeting in Orlando, Florida -- the




10   weather  will be better there than it is here




11   today   -  where you're going to discuss, I believe,




12   future  engine standards with respect to 2007




13   standards.  Would you give us a little bit more




14   information if you can and also the timing when we




15    can  get  more details on the decisions  that the ATA




16    is making on these two very important  issues.




17                MR. SCHAEFFER:   I just came from




18    Orlando,  and the weather was much nicer.  We are in




19    the  midst of our annual meeting with the nation's




20    top  trucking executives, and the environmental




21    policy  committee on Sunday passed a resolution,




22    basically a two-prong resolution.  First, endorsing




23    the concept of a national uniform diesel fuel




24   standard for all diesel users, period.  And the




25   second  aspect of that was that a task  force was
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       Alan  Schaeffer    American Trucking Association




    appointed  to  investigate all the underpinnings and




3   probably more the  issues that you're interested




4   which  is the  numbers,  what levels of sulfur, time




5   frames,  and other  issues.  But the committee felt




6   strongly that the  need to speak out now about our




7   general  support for a national standard and support




8   for  a  standard that applies for all diesel users.




9                With regards to further views on 2007,




10   we have  a  series of meetings next week.  We have oil




11   industry representatives and perhaps engine




12   manufacturer representatives with some of our




13   technical  committees to try and sort out some of the




14    issues there and try to understand more about the




15    future,  and I suspect that we will be ready by the




16    end  of the year to be much more specific about what




17    our  views  are on 2007.  But if you look at our past




18    record,  we have generally supported standards that




19    are  cost-effective that show improvements in fuel




20    economy and durability and reliability and




21   maintainability, and manufacturers have been able to




22   deliver on those accounts.  But it appears now that




23   things are getting much more complicated, the




24   standard is getting much lower, and the issues are




25   becoming a bit more tenacious.  There are lots
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       Alan  Schaeffer -  American Trucking Association




    obviously,  we  don't  have any influence on




 3   certification  testing procedure,  so we are trying to




 4   learn  and  understand what the impacts of those




 5   changes  might  have on the operators in terms of cost




 6   of new engines,  cost of operation, and most




 7   importantly,  the impact on fuel economy.  The




 8   trucking industry is a very marginal industry.  For




 9   every  one  dollar revenue we make,  our companies put




10   about  two  or three cents in their pocket.  So you




11   can  see  that an issue where an engine would cost a




12   lot  more or the fuel would cost a lot more could




13   have a broad impact on the industry, and that's why




14   we're  putting our stake in the ground now.  We think




15    the  agency should look more broadly to expand its




16    efforts  to control diesel emissions, not just




17    on-highway, but off-highway.  We believe that we're




18    producing economies of scale and reducing emissions,




19    diesel fuel standards perhaps of off road sectors.




20    But this industry is responsible.   We breathe the




21    same air that you do.  We have no interest in a




22    dirty environment.  And we will be more specific




 23    later this year.



 24               MS. OGE:  Thank you.  Thank you all for




 25   coming forward to testify this afternoon.
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1           Bob  Jorgensen -  Cummins Engine Company




2                I'd like to proceed with our next panel.




3   Mr. Bob Jorgensen,  Jonathan Singer, Britta Ipri,




4   Julie  Becker,  and Nancy Brockman.




5                Mr. Jorgensen, we'll start with you.




6                MR. JORGENSEN:  Good afternoon.  My  name




7   is  Bob Jorgensen.  I am the Director of Product




8   Environmental  Management for Cummins Engine Company.




9   Cummins produces heavy-duty engines that are used  in




10   stationary  and mobile off-highway  applications as




11   well  as in  on-highway vehicles.  Cummins considers




12   the delay in accomplishing the 1999 Technical Review




13   to  be  a breach of faith with the diesel engine




14   industry and a breach of the contract we entered




15    into  with the  EPA as a result of the 1995 Statement




16    of  Principles.



17                By way of background,  I'd like to state




18    that  Cummins takes great pride the emission




19    reductions  we've achieved in the products that we




20    are currently producing, 75 percent reduction in NOx




21    emissions,  about 90 percent reduction in particulate




22    emissions,  and a like amount of volatile organic




23    compounds.



24               This morning Mr. Castle from the




25   National Resource Defense Council  made note of his
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1           Bob  Jorgensen -  Cummins Engine Company




2   responsibility for the  NRDC campaign, dump dirty




3   diesels.   So we may take different steps to get




4 I  there,  I  can tell you that myself and the other




    engineers at Cummins Engine Company have a very




6   similar responsibility, and we don't take that




7   lightly.   I and other members of the Cummins




8   community maintain a strong commitment to make




9   further reductions of emissions of our product.  And




10   as  the  agency is aware, we are investing heavily in




11   the development of emissions reduction technologies




12   that have the potential to reduce pollutant




13   emissions substantially from the today's low levels.




14                Cummins was among the industry




15   participants that collaborated closely with both EPA




16   and CARS in 1995 to reach agreement on a joint




17    statement of principles.  The SOP was a novel




18    approach between the agency and the regulated




19    parties designed to obtain commitment to reduce




20    emissions very significantly from on-highway




21    heavy-duty engines, while providing manufacturers




22    the stability certainty, and lead time necessary to




23    meet these stringent standards.  The Statement of




24   Principles was memorialized in writing, signed by




25   EPA, the California Air Resources Board, and
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1           Bob  Jorgensen   Cummins Engine Company




2   industry  representatives in mid 1995 and included a




3   provision to  conduct a Technical Review.  In




4   addition  to the SOP, the obligation to conduct this




5   review  is also set forth in the 1997 rule final




6   establishing  the 2004 emissions standards.  The SOP




7   and  the Rule  called for the review of the stringent




8   2004  emissions standards to be completed by the end




9   of  1999.   This is, of course,  the origin of the




10   proposal  before us today.




11                As you know, in 1995 all parties agreed




12   that  the  stringency of the emissions standards




13   definitely represented a significant technical reach




14   for the companies.  Therefore, the parties agreed




15   that  the  purpose of the Technical Review was to




16   provide an opportunity to review the progress of




17   technology over the nine years between the setting




18    of  the  standards and their implementation.




19                Furthermore, EPA and CARB and the




20    industry  never intended that the 1999 Technical




21    Review  to be conducted only in 1999.  Rather, the




22    date 1999 was selected as a not later-than date for




23    promulgation of the results of the Review in order




24   to meat lead time requirements of the Clean Air Act.




25   On the  basis of where we find ourselves today, it is
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2   clear  the  EPA has failed to adequately plan for the




3   complexity  of the issues that needed to be reviewed.




4                Not only did EPA fail to provide




    adequate  time for the Review of the 2004 emissions




6   standards,  but it also exacerbated the time




7   constraint  problem by choosing to use the Technical




8   Review as  a vehicle for promulgating independent




9   issues.   EPA started late.  The first public or




10   private session that Cummins had with EPA was in




11   late 1998.   EPA also skipped steps in the Technical




12   Review process.  For instance, it failed to conduct




13   workshops  and other outreach typical of a rule this




14    complex.   Then faced with certain time constraints,




15    EPA chose  to add a series of unrelated and



16   unanticipated technical issues to the review, for




17    instance,  on-board diagnostics and re-definition of




18    the light-duty truck.




19                As an evidence of EPA's failure to




20    adequately plan for and manage the 1999 Technical




21    Review, EPA's notice for this session today was




22    formally published in the Federal Register just last




23    Friday, October 29, only two working days prior to




24    this meeting.



25                And also as evidence of EPA's time
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                    Jonathan Sinker - NET




2   management  problem,  by the time written comments  on




3   the  Technical Review are received on December 2,




4   1999,  there will be only 29 days for EPA and then




5   the  Office  of Management and Budget to review the




6   comments  received and to develop a final rule.




7                We are asking, what was EPA thinking




8   when it  failed to allow for the nominal 90-day




9   review period typically afforded to OMB prior to




10   promulgation of a final rule?




11                OMB did use nearly the full 90-day




12   review period to review the NPRM that was released




13   just last week.



14                In summary, and the repeat, Cummins  is




15   very concerned that EPA will not be able to finalize




16    this review by year-end even after the agency has




17    had  no less than three years to prepare itself,




18    given that  we signed the SOP in 1995.




19                Cummins appreciates the opportunity  to




20    offer these remarks, and we intend to provide




21    further comments prior to the close of the written




22    comment period.



23                MS. OGE:  Thank you.




24                Mr. Jonathan Sinker, good afternoon.




25                MR. SINKER:  Good afternoon.  My name is
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                                                     203
 1                   Jonathan Sinker   NET




 2    Jonathan Sinker.  I am the field organizer  for  the




 3    National Environmental Trust in Pennsylvania.   The




 4    National Environmental Trust is a non-profit,




 5    non-partisan organization dedicated to  educating  the




 6    American public on contemporary environmental




 7    issues.  Since  it was founded  in 1995 as  the



 8    Environmental Information Center, NET has worked  to




 9    promote strong  health, safety, and environmental




10    protections issues including global climate change,




11    public right to-know policies, and air  and  drinking




12    water safety.




13                The Clean Air Act  mandates  that EPA set




14    National Ambient Air Quality Standards  that will




15    protect public  health.  There  is no doubt that  the




16   air in Pennsylvania is not protective of  public




17   health.  According to a 1999 Clean Air  Task Force




18   report, there were 9600 respiratory related




19   emergency room  admissions and  370,000 asthma  attacks




20   that can be attributed to air  pollution in




21   Pennsylvania.




22               In  1998 Pennsylvania had  616  readings




23   where  the eight hour standard  was exceeded.   Most




.24   Pennsylvanians  are still regularly exposed  to




 25   unhealthful levels of ozone.   In the  Philadelphia
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                    Jonathan Sinker   NET




2   area,  if  you live in Montgomery County the




3   eight  hour  standard was exceed on 19 different




4   occasions;  14 times in Bucks County; 27 times in




    Philadelphia County; and 19 times in Delaware




6   County.   During the summer of 1998,  27 Pennsylvania




7   Counties  exceeded the eight-hour standard.




8                According the EPA, big diesel trucks




9   emit  about  10 percent of all NOx emissions




10   nationwide  and account for a high percentage of




11   particulate emissions in urban areas.  EPA's




12   pollution trends report shows that diesel trucks




13   collectively emit more NOx and particulates soot




14   today than  they did in 1970, when the Clean Air Act




15   was passed.  In addition, the State of California




16   has labeled diesel particulate as toxic, and EPA




17    researchers believe diesel exhaust is connected with




18    human cancer.



19                NET joins the rest of the environment




20    community in supporting EPA's proposed strategy to




21   reduce emissions from heavy-duty vehicles.




22               NET calls on EPA today to:




23               One, accelerate the time line to close




24   the SUV emissions loophole.  Currently SUVs pollute




25   three to five times more than passenger cars.
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1                   Jonathan Sinker   NET




2   Because  SUVs emit the lion's share of auto




    emissions,  NET is asking for these vehicles to meet



4   the  clean car standard by 2007 as proposed under




5   Tier 2,  not 2009 as allowed by EPA's current




6   proposal.




7                Number two, tighten heavy-duty




8   particulate standards by at least 50 percent by




9   2004.   Pennsylvanians should not have to wait until




10   2007 as  allowed by EPA's current proposal to reduce




11   particulate pollution.  Enforcing a tighter standard




12   earlier  may delay the amount of premature deaths




13   related  to air quality.




14                Number three, set national standards  for




15    low-sulfur diesel fuel.  Sulfur is poison to the




16    pollution control devices on cars.  To ensure the




17    diesel pollution equipment is effective, all diesel




18    fuel sulfur levels should be capped at 10 parts per




19    million  by 2006.



20                Number four, since seven of the major




21   diesel engine companies were caught putting cheating




22   devices  on their engines that enabled them to pass




23   pre-sale emission tests, but then pollute more on




24   the road, a tighter verification process must be




25   imposed.  In-use testing and on-board diagnostic
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1            Britta Ipri   Clear the Air Campaign




2   equipment  should be required for all heavy-duty




3   trucks,  both gasoline and diesel to ensure clean



4   trucks  stay clean.




5                Number five, adopt strong standards for




6   2007.   Pollution from heavy-duty vehicles is a




7   serious problem that must be addressed as soon as




8   possible.   By 2007, smog-forming and particulate




9   pollution  from heavy duty vehicles should be lowered




10   by 90  percent beyond the 2004 standards.




11                There can be no doubt about the public




12   health need for cleaner motor vehicles.




13                NET reserves the right to submit written




14    comments during the comment period.  Thank you.




15                MS. OGE:  Thank you.




16                Ms. Britta  Ipri, good afternoon.




17                MS. IPRI:   Good afternoon.  Thank you




18    for the opportunity to  speak today.  My name is




19    Britta Ipri and I serve as the regional coordinator




20    in the Mid-Atlantic for the Clear the Air Campaign.




21   Clear the  Air's primary focus is stationary sources




22    of air pollution such as old, dirty coal power




23    plants.  However, as an advocate for clean air, one




24   cannot deny that mobile sources of air pollution




25   must be cleaned up  if our region's air is to reach a
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1            Britta Ipri   Clear the Air Campaign




2   level  that  is healthy for everyone.




3                Each year in Pennsylvania, air pollution




4   causes the  premature death of more than 5,000 people




5   and  threatens the health of almost two million more




6   who  suffer  from asthma and other respiratory




7   illnesses.




8                When considering the mobile sources of




9   air  pollution, big trucks and busses, most of which




10   use  diesel  fuel, are among the worst  culprits.




11   Unfortunately, because there is so many more  trucks




12   on the road today, manufacturers have done enough to




13    curb pollution from these large diesel vehicles.  In




14    areas like  Philadelphia, as much as half the




15    particulate pollution that threatens  public health




16    comes from large diesel vehicles.  More than  30




17    health studies have also linked diesel pollution and




18    the hundreds  of toxics it contains, to lung cancer.




19                The good news is that  the technology to




20   clean up diesel engines is available.  We can afford




21   to wait no longer  before requiring manufacturers to




22   use these technologies.




23               While  I applaud the EPA for proposing




24   this  program  to clean up pollution from these big




25   and dirty vehicles, I would like to urge the  EPA to
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 1            Britta Ipri - Clear the Air Campaign




 2    make a few changes that would make this program  even



 3    stronger.




 4                First, I would urge the EPA to




 5    accelerate the time line for closing the  SUV




 6    loophole.  Under the Tier 2 auto pollution  program,




 7    all cars and smaller SUVs will be  required  to  meet




 8    clean car standards by 2007.  However, under the




 9    heavy-duty vehicle proposal, automakers have until




10    2009 to clean up larger SUVs.  All passenger




11    vehicles, no matter how big or small they are,




12    should meet clean car standards by 2007.




13                Second, the heavy-duty particulate




14    standards must be tightened by 50  percent by 2004.




15    The current proposal would not require any




16    reductions in particulate pollution until 2007.




17                Third, smog-forming pollution and




18    particulate pollution from heavy-duty vehicles




19    should be lowered by 90 percent beyond the  2004




20   standards.



21               Fourth, diesel fuel must be cleaned  up.




22   Pollution control systems can be truly effective




23   only when they are coupled with low-sulfur  fuels.




.24   All diesel fuel sulfur levels should be capped at  10




 25   parts per million sulfur by 2006.
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1          Nancy Brockman   Wyncote Audbon Society




2                Last, the EPA must ensure that  trucks




3    stay  clean once they are on the road.  This  should




4    be  done through in-use testing and use of on board




5    diagnostic equipment.  These should be required  for




6    all heavy-duty trucks, both diesel and gasoline.




7                This program is a crucial part  of




8    cleaning up our regions' air.  Only when our worst




9    dirty-air culprits like large dirty diesel  vehicles




10    ar  cleaned up can we begin achieve cleaner  and




11    healthier air.



12                Thank you once again  for the opportunity




13    to  speak today.



14                MS. OGE:  Thank you.




15                Ms. Nancy Brockman, good afternoon.




16                MS. BROCKMAN:  Good afternoon.   I'm  here




17    to  speak on behalf the 2,000 members of the  Wyncote




18    Audubon Society, one of the nation's oldest  bird




19    clubs and as an asthmatic and the parent of  an




20    asthmatic child.  I want to compliment the  EPA for




21    proposing to close the loophole for enormous,




22    excessively polluting sport utility vehicles and for




23    the move to cut nitrogen oxides emissions from big




24   diesel trucks in half by 2004.




25               The air we are breathing today  in
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1          Nancy Brockman -  Wyncote Audbon Society




2    Philadelphia is dangerous.  This is according to EPA




3    standards.   The Delaware Valley is a severe



4    non-attainment area.  Between 1982 and 1992, the




5    region lost over 25 percent of its total farmland.




6    In  that same period, there was a 33 percent  increase




7    in  auto commuters in the area.  The picture  of  the




8    Greater Philadelphia region is one of shrinking




9    green space and wildlife habitat, increased  regional




10    sprawl, and higher  than deemed safe air pollution.




11    A walk in Center City Philadelphia can choke the




12    asthmatic and make  a healthy person turn their  head




13    or cover their faces from the fumes pouring  out  from




14    buses and trucks.   Drive along any major regional




15    highway and you will see dead trees and shrubbery




16    lining the road, dead because of the toxic




17    concentrations of air pollutants.  Couple that  with




18    the trend toward increased auto dependency and  the




19    resulting increase  in auto emissions, and we have a




20    dangerous recipe for environmental and human health




21    disasters.



22                The National Audubon Society's mission




23    is to  conserve birds and their habitats.  Today,




24   Audubon Societies are committed to bringing  people




25   closer to birdlife  in order to build a deeper
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 1          Nancy Brockman -  Wyncote Audbon Society




 2   understanding of the powerful links between healthy




 3   bird  populations,  ecosystems, and ourselves.



 4                Birds have been used to monitor the




 5   environment throughout history.  Declines in bird




 6   population numbers and changes in species' ranges




 7   resulting from human induced causes provide




 8   information crucial to environmental decisions.




 9   Birds integrate and accumulate environmental




10   stresses over time because they are usually high in




11   the food chain and have relatively long  lifespans.




12   Since birds are sensitive to stresses in  predictable




13   ways, they are often used as a proxy measure of




14    environmental change-




15                We are now being warned, much as the




16    canary warned miners of old of lethal gasses in deep




17    shaft mines.  Environmental changes are  occurring  at




18    an alarming rate.  Healthy bird populations are




19    decreasing in the region.  Fewer numbers  of once




20    numerous species are found as wildlife habitats




21    disappear or become increasingly polluted.  Acid




22    rain changes the ecological balance in lakes and




23    streams and affects the surrounding habitats.  Air




24    pollution kills trees and reduces food supplies for




25    both indigenous and migratory bird populations.
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 1          Nancy Brockman   Wyncote Audbon Society




 2                That portion of air pollution caused by




 3    cars,  minivans, SUVs,  and especially diesel vehicles




 4    is  enormous and can be reduced.  Each day we pander




 5    to  large business interests, more species approach




 6    oblivion diminishing our world and our lives as they




 7    go.   Too often the right move is unclear, but  here




 8    we  have all the components to make a substantial




 9    difference.  We know what to do and how  to do  it.




10    The benefits to reducing air pollution from these




11    highly polluting vehicles well outweigh  losses  or




12    inconvenience  to businesses.




13                On a personal note, I wish to say  that




14    not only am I  an asthmatic, but I am the parent of




15    an asthmatic child.  We all know the symptoms  of




16    asthma and are aware that asthma is substantially




17    worsened by air pollution.  Even with a  decrease in




18    air pollution  over the last few years, medical




19    experts still  tell us that asthma, especially  in




20   children,  is on the rise in the USA.  I  fear the




21   possibility that future scientific studies will




22   prove that the damage to human health from that




23   combination of air pollutants found in vehicle




 24   emissions  is more pervasive than originally thought.



 25               At the Tier 2 hearings I told the  story
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1 I)        Nancy  Brockman   Wyncote Audbon Society




2 I  of how  my  son,  now aged 15,  was rushed to the




    hospital with chest pain,  faintness, and the




    inability  to breathe.   His father and I went to the




    hospital to  find him gasping for breath and scared.




6   No child should have to feel his mortality at that



7   age.  He hates having exceptions made for his




8   condition.   It makes him feel different from most




9   other kids his age.  I hate that the quality of his




10   life  is compromised and perhaps permanently damaged.



11                This country has the technology and the




12   power to make substantial changes for the better,




13   now.  We  should not have to wait until 2007 to see




14   noticeable results.  Business will  not make changes




15    for  the better without being forced to do so by the




16    EPA  because it is not cost efficient to do so.  It




17    is obvious that the cost of doing business has been




18    more important to decision-makers than the cost to




19    human health.  Our collective priorities must




20   change.



21               Personal responsibility should count for




22   more than  it does in today's society.  Each one of




23   us needs to accept personal responsibility for the




24   type of vehicles we drive, the kind and number of




25 I  'miles we put on them, and the  impacts of the
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1          Nancy Brockman   Wyncote Audbon Society




2   resulting  pollution.  I believe that all gasoline




    vehicles,  compact car through giant SUV, should be




4   held  to  the same, more stringent emissions




5   standards.   If the emissions control devices on my




6   car do not work correctly, I must have them fixed.




7   Yet,  most  diesel big trucks don't even use the




8   pollution  control devices they could and should.  If




9   they  did,  they could be between 50 and 90 percent




10   cleaner  than they are today.  I am astonished that




11   in Philadelphia, our public transportation system




12   can use  a  low-grade high polluting diesel fuel




13    instead of the available but more costly high-grade



14   lower polluting diesel fuel in the busses that serve




15    the public.  How is this possible?  For these




16    reasons  I  am heartened to see EPA taking the




17    responsibility to implement tougher emissions




18    standards  for highway vehicles and engines.




19                Just a  final note:  With asthma on the




20    increase in America, most notably in pre-school aged




21   children,  we run the risk of our future generations




22   by not acting now.  Much as I mourn the decline and




23   loss  of endangered bird species that continue to




24   fall  victim to human engineered environmental




25   factors, I fear the irreparable damage to humans
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                                                     215
1         Nancy  Brockman -  Wyncote Audbon Society



2   more.




3                MS.  OGE:  Thank you.



4                Any questions for the panel?




5                MR.  FRANCE:  Yes, just a couple.  This




6   is  for  Mr.  Jorgensen.  I think all of us wish that




7   we  were here in January 1999, but we're not.  Before




8   I ask a question, I do have to set the record




9   straight.   Mr.  Jorgensen, you used a fairly strong




10   language in terms of breach of faith, breach of




11   contract,  EPA has a time management problem.  I  like




12   to  remind you,  first of all, consent decrees were




13   not,  any circumstances regarding consent decrees are




14   not of  our making.  Those consent decrees were  filed




15   with the court late last year, were finalized I




16    think in June or July  this year.  We made good  faith




17    efforts to integrate those provisions in a logical




18    way,  at the same time  trying to interact with the




19    industry,  I think, in  an unprecedented way.  I  think




20    we met  more than 10 times with the industry.  We've




21   met individually with  Cummins.  We were on site  at




22   your facility about the details.  On top of it,  as




23   Margo said before, on  behalf industry's request,




24   part of the delay in getting the rule was the lead




25   provisions that you all asked us to streamline  the
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                                                     216
1          Nancy  Brockman   Wyncote Audbon Society
2   rule.   So  speaking from our perspective, a lot of
3   the  delay  have been response to circumstances that
4   were  out  of  our control, but also in response to
5   requests  from the industry.  So I'd like that
    entered on the record.
7                Let me ask the question.  You keep
8   citing the SOP, you suggested first the inference
9   there is  that we just reaffirmed the standard.   Is
10   that what
11                MR. JORGENSEN:  In the SOP, of course,
12   it  called for a revisiting or a re-analysis of the
13   feasibility of the standards, and obviously it was
14   possible  to make them more stringent, make them  as
15   they were, or make them more stringent.  But all
16    those were possibilities that were listed both in
17    the SOP and in 1997 final rule.
18                MR. FRANCE:  How would you  anticipate
19    EPA dealing with the consent decrees supplemental
20    test provisions, from Cummins' perspective.
21               MR. JORGENSEN:  As far as incorporating
22   them, we definitely expected that EPA would take
23   that into account in the process.  As a matter of
24   fact, in the nearly dozen meetings that we refer to,
25 I  the first was held, I believe, in December of 1998,
                       i
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           Nancy  Brockman -  Wyncote Audbon Society




    and at  that  meeting, you know, the discussion had




 3   those  elements in it.  And at that point in time,



 4   the agency representatives talked about how the MPRM




 5   would  normally be out in March and that we'd be




 6   having a  hearing in April and that written comments




 7   would  be  due in May.




 8                MR. FRANCE:  Let me ask, so you




 9   anticipated us including not to exceed provisions  as




10   part  of this rule?




11                MR. JORGENSEN:  I would say certainly




12   taking the consent decree into account.  Now,




13   whether or not it was the exact replica, that,  I




14   think  was open for discussion.




15                MR. FRANCE:  Absolutely.  It still




16    remains open for discussion in terms of the




17   provisions.   I'm asking in Cummins' perspective, the




18    same  line of discussion I had with Detroit Diesel.




19    What  is Cummins' perspective on the lead time issue




20    that  has been identified and also what is your




21    company's intent complying with 2004?




 22                MR. JORGENSEN:  Of course, as you see,




 23    by our comments, we wish it was a moot point.   We




 24   wish  that the rule would have been finalized by year




 25   end such that the question of lead time would not
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 1          Nancy Brockman   Wyncote Audbon Society




 2   have  been an issue.   But we recognize and we noted



 3   with  interest in the preamble to the rule how  EPA




 4   acknowledges that it might not be possible to




    conclude the rule by year end and has thought  about




 6   ways  that we could still have an effect date of




 7   2004,  either through a voluntary agreement or




 8   whatever.  And I think Cummins, I can say, is  open




 9   to  those kinds of discussions.  And we wouldn't  rule




10  • out that those discussions could lead to a




11   conclusion that maintains the 2004 date.  We




12   wouldn't rule that out.



13                MR. FRANCE:  What is Cummins going to do




14    if  we don't?



15                MR. JORGENSEN:  Well, I can tell you




16    that  it's a very difficult and complex issue as  to




17    what  happens if the December 31, 1999 deadline is




18    met.   And quite frankly, I don't really understand




19    perfectly what happens to competitors that have  not




20   signed a consent decree.  So it's very difficult for




21   us to really answer that question.  I'm very open to




 22   those kinds of discussions, though, but I think  it's




 23   a very complex issue as to what happens to others.




.24   And in that light, it's very difficult for me  to




 25   answer the question as to how Cummins will behave.
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1         Nancy  Brockman   Wyncote Audbon Society




2                MR.  FRANCE:   That's fair enough.




3                MS.  OGE:   I  think that's fair.  I would



4   encourage  you  and other  companies to give us




5   comments  on  all  these issues.  And I think  there are




6   legal issues of  lead time appropriateness for all  of




7   us  to address  and then there are issues of




8   feasibility  to do it.  We would like comments on




9   both  issues.  And how do we proceed forward with the




10   best  program in place in 2004 time frame to give us




11   the clean air all of us  are looking for.  Thank you.



12                MR.  JORGENSEN:  You're welcome.




13                MS.  OGE:  Any other questions?




14                MR.  HOROWITZ:  Just a follow-up to




15    Chet's  point.   Just to state for the record that you




16    used the  words breach of contract and breach of




17    faith.   And obviously, we, EPA, had no contract with




18    any of  the companies under the SOP.  We wouldn't




19    make contracts to put out rulemakings and finalize




20    final numbers for emission standards without going




21   through the notice and comment process.  So I'm




22   worried about the use of that term, but I understand




23   the rhetorical charge.  And also regarding  breach  of




24   faith and not understanding complexity, obviously,




25   the intervening events came out of consent  decrees
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                                                     220
1          Nancy Brockman -  Wyncote Audbon Society




2   have  unfortunately delayed them.  As Chet  said,  that




3   was not  something that we anticipated in  1995.



4                MS.  OGE:  Anymore questions?




5                (No response.)




6                MS.  OGE:  Thank you.  Thank you  very




7   much  for coming forward.




8                We are doing great on time; we are




9   early.   We had a gentleman by the name Dennis




10   Winters .



11                AUDIENCE MEMBER:  He's not here.




12                MR.  OGE:  I  would like to call the  panel




13    that  was scheduled to testify at 4:15 if  they are




14    here. Valerie Sowell, Geoff Harden, Kathleen Erdei,




15    Jason Rash, Ajayi Harris.



16                I'm told that Natasha Ernst is here.




17    She was  scheduled for the 5:15.  If you would like




18    to come  forward, please  do that.  I'm reminded  that




19    Mr. Andrew Altman was not here earlier.




20                MR.  RASH:  He will be submitting




21   comments in written form.  He will not be




22   testifying.



23               MS.  OGE:  Thank you.




24               We can start with Ms. Valerie  Sowell.




25   Good afternoon.
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                                                     221
1                  Valerie Sowell   Citizen




2                MS.  SOWELL:   Good afternoon.  My name is




3   Valerie  Sowell.   I'm a citizen of Philadelphia here.




4   And  I  just  want  to thank you briefly for giving me
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an opportunity to voice my  beliefs  that  we  should




reduce pollution in  light trucks  and  SUVs.   We've




heard today about the  devastating effects  of air



pollution in this community and  in  cities  and towns




across the nation.   It seems  clear  to me that




anything that triggers 40,000  deaths  a year




constitutes a dire public health  crisis,  and no




effort should be spared to  curb  that  crisis.




            Furthermore, this  particulate  health




threat is straightforward.   We know the  problem that




air pollution triggers attacks of asthma and other




respiratory ill effects.  We  also know the  cure -  we




have to cut down on  pollution.   So  I  applaud the EPA




for proposing the program that they have in an




effort isolating the cure.




            I do believe, though,  that we  have to go




even further if we want to  eradicate  the public




health crisis entirely.  So I  agree that first we




should accelerate the  time  line  for closing the SUV




loophole.  All passenger vehicles should meet clean




car standards by 2007.  Absolutely.   We  should
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                                                     222
                   Valerie Sowell   Citizen




    tighten  the  heavy-duty particulate standard 50




    percent  by 2004.   The EPA must call for an




    additional 90 percent reduction of particulate




    matter and nitrogen oxide pollution by no later




    2007.  We have to clean up diesel fuel to go hand  in




 7   hand  with this.   All diesel fuel sulfur levels




 8   should be capped at 10 parts per million by 2006.




 9   As  well,  we  should ensure that trucks are not




10   getting  out  of their obligations; they stay clean




11   once  they're on the road using in-use testing and




12   on-board diagnostic equipment.




13                So we've isolated the cause.  We've




14    isolated the cure.  The problem, of course, is not




15    in  doing that, but in following through.  We have  to




16   make  sure that the changes that we see are met.




17                And,  you know, people in large groups




18    tend  to  share inertia with this sort of thing.  It's




19    somebody else's responsibility or it's somebody



20    else's  fault, but really little as possible.  And  I




21    learned  something.  I spent a year in Northern




22    Ireland.  Before I went there, I was researching the




23    psychology of large groups and mob rule to guard



24   away  from the terrorists if I could.  And I learned




25   that  when you're in the middle of a large group and
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                                                     223
                  Geoffrey Harden   Citizen




 2 I!  someone  attacks you in a crowd, that you  can't wail




 3   and  say  "Somebody help me.  Oh, God, I'm  in  dire
 4
 5
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need of help.  Help me,  somebody."   You have to grab




someone's hand and make  eye  contact and say, You,  in
 6    the  blue  shirt,  call the police.  You help me.   You




 7    have to help me.   I see you."  And so you make  eye
contact.  Only when  a  person is being spoken to will



they listen.




            So as  the  representatives of the EPA




which will ultimately  be  responsible for this




decision, I call you on with the power that you have




to make these changes  and care for our health.   You




can do  it.  You  can  tighten the loophole and you can




look out  for the public.   You have the authority.



            So thank you  for giving me this




opportunity to tell  you that directly.



            MS.  OGE:   Thank you.  Thank you for the




lesson.   I'll remember that.



            Mr.  Geoff  Harden,  good afternoon.




            MR.  HARDEN:   Good afternoon to you.  My




name is Geoffrey Harden,  and I'm a citizen of




Philadelphia concerned about smog from trucks and




SUVs.   By the way,  I appreciate having this




opportunity to talk  to you and express my concern.
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                                                     224
1                 Geoffrey Harden   Citizen




2   I'm here  as  a citizen,  but I want to offer my




    perspective  on this issue as a urban bicyclist.




                 Practical concerns like economic




    necessity and consideration for the environment




 6   compel  citizens like myself to use bicycles as an




 7   alternative  transportation in cities across the US.




 8   We  cyclists  share the streets with these big trucks




 9   and SUVs.  So making our way to work or school or




10   home,  we  choke on the fumes from these dirty




11   vehicles' tailpipes.



12                I ride my bike to work through Center




13   City  Philadelphia every morning.  So I've gotten my




14   share of  exhaust pumped in my face by these big




15   vehicles.  Tailpipe fumes burn my eyes, my throat,



16   and my lungs.  It's nauseating.  But what's really




17   worse is  the long-term effects of this smog, the




18   untimely  deaths of 40,000 citizens each year.  Smog




19    reduction is literally a question of life or death




20    so the work must not been delayed.  So I'm urging




21    you to continue in the spirit of what you propose to




22    clean up  our air, forcing automakers to use readily




23    available technology to reduce their deadly



24    pollution, tightening the heavy-duty particulate




25    standards by 50 percent by 2004, and limiting diesel
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                                                     225
                      Jason Rash   GPCCP




    sulfur  levels  to 10 parts per million by 2006, and



    closing the  SUV loophole by 2007.




 4                Thank you again for your time.




 5                MS. OGE :   Thank you.




 6                Mr. Jason Rash.  Good afternoon.




 7                MR. RASH:  Good afternoon.  My name  is



 8   Jason  Rash,  and I am here representing the Board  of




 9   Directors of the Greater Philadelphia Clean Cities



10   Program.   Great Philadelphia City Program is a




11   public/private partnership dedicated to promoting




12   the  development and use of alternative fuels and




13   alternative  fuel vehicles in the Greater




14   Philadelphia region.




15                The Greater Philadelphia Clean Cities




16   program was  established in 1993 and is widely




17    recognized as one of the most successful United




18    States Department of Energy Clean Cities Programs in




19    the  nation.   Thanks  to the efforts of its members,




20    local  governments, companies, and consumers in the




21   Greater Philadelphia region are powering thier vans,




22   trucks, cars and buses on alternative fuels such  as




23   compressed natural gas, propane, ethanol, methanol,




 24   and  electricity.  The results being improved air




 25   quality and a  reduction in the  reliance on foreign
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                                                     226
1                     Jason Rash - GPCCP




2   oil.




3                While the Greater Philadelphia Clean



4   Cities  Program coalition enthusiastically supports




5   EPA's proposed strategies to reduce emissions  from




6   heavy-duty diesel vehicles, it also calls on EPA  to




7   increase  alternative fuels.




8                Transportation in America revolves




9   around  motor vehicles that run on gasoline and




10   diesel;  two fuels that despite advances made in




11   catalytic and fuel cleaning technologies, will




12   continue  to contribute to the country's ground level




13   ozone problem well into the next century.




14                Furthermore, the world's oil supply is




15   not limitless and is the source of great




16   geopolitical instability.  As a result, the United




17    States  is forced to spend billions of dollars  each




18   year importing over half of its oil, often from




19    politically unstable regions of the world.



20                The public health hazard posed by




21    ground-level ozone and the increasing reliance on




22    foreign oil are serious threats to our nation's




23    future.  That is why the Greater Philadelphia  Clean




24    Cities  Program is calling on EPA to increase its




25    presence in the alternative fuel arena.  Alternative
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                                                     227
        Natasha  Ernst -  Low Income Housing Activist




    fuel vehicles  can make considerably less pollution




    than conventional vehicles, some even have  zero




    emissions,  and alternative fuels such as compressed




    natural  gas,  electricity,  and ethanol are in great



 6   abundance  here in the United States.




 7                The shift to alternative fuels  will not



 8   take place over night, but it is imperative that  it




 9   occur  now.   There is a willingness throughout  the




10   country  to use alternative fuel vehicles, but  its




11   growth is  contingent on EPA working with other




12   governmental agencies and private industry  to




13   improve  both alternative fuel infrastructure and




14   vehicle  development.




15                Thank you.



16                MS. OGE:  Thank you.




17                Ms. Natasha Ernst.  Good afternoon.




18                MS. ERNST:  Good afternoon.  My name  is




19    Natasha  Ernst.  I live in Philadelphia, and I work




20    with low income housing tenants in Philadelphia.




21    Thank  you for this  opportunity to voice my  concerns




22    about  the need to reduce air pollution from trucks




23    and SUVs.



24                A large part of Philadelphia's




25    populations comprised low income households.   These
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                                                     228
1       Natasha  Ernst -  Low Income Housing Activist




2   neighborhoods  often  look like post industrial




3   wastelands  surrounded had by abandoned factories and



4   warehouses.   The schools there suffer from crumbling




    buildings  and  textbook shortages.  People live in




6 I!  substandard  housing.  But in addition to all of




7   these  problems,  growing numbers of especially




8   African-American and Hispanic children in




9   Philadelphia are also suffering from severe asthma.




10                A large  quantity of the people I see




11   every  day  have a child that has asthma or they




12   themselves are asthma or another respiratory




13   problem.   I  see these families striving to provide a




14   better life  for their children by finding a decent




15   home,  a good public  school, and escaping the crime



16    ridden neighborhood.  However, no matter how hard




17    these  families work, they can't escape from air




18    pollution.



19                The polycyclic organic material in




20    Philadelphia's poorest area is more than 200 times




21    the no-risk level,  this according to the EPA.  This




22    is created by the burning of gasoline.  SUVs burn




23    more gasoline and are less fuel efficient than any




24   other passenger vehicle.  This air pollution




25   directly impacts the health and well being of
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                                                     229
1       Natasha  Ernst    Low Income Housing Activist




2   Philadelphians,  Philadelphians that are often too




3   poor  to  ever be  able to afford the luxury SUVs that



4   are on  the market  today.




5                I'm  asking EPA to put people above




6   corporate  profit.   The increased profit of




7   corporation, such  as forward and GM, that exist  as a




8   result  of  the SUV  loophole will result in more money




9   being spent  in medical costs, missed time at work,




10   and decreased quality of live by low income working




11   people  and their children who suffer the real cost,




12   the health costs,  of air pollution.




13                In essence, by not strengthening the




14   heavy-duty program, the adults and children of




15    Philadelphia and the United States will be financing




16    corporate  profit.



17                The EPA now has the unique opportunity




18    to put the public interest ahead of corporate profit




19    by strengthening the heavy-duty program in areas




20    such as closing the SUV loophole so all passenger




21   vehicles meet the clean air standard by 2007,




22   tightening  the heavy-duty particulate standard by 50




23   percent by  2004, cleaning up diesel fuel, and



24   ensuring that trucks stay clean once they are on the




25   road.
                      Vincent Varallo Associates, Inc.

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                                                230
                Ami Doshi    NJ PIRG




            Clean air  is a  public  resource,  not a



corporate resource.  And I  applaud the EPA for




working to protect  it.  Thank you  for letting me



speak about this important  issue.




            MS. OGE:   Thank you.   Any questions?




             (No response.)




            MS. OGE:   Thank you very much.




            Good afternoon.




            MS. DOSHI:  Good afternoon.




            MS. OGE:   Please state your  name.




            MS. DOSHI:  My  name is Ami Doshi, and I




am with the New Jersey PIRG,  the New Jersey  Publish




Research Group.  Thank you  for giving me an




opportunity to voice my concerns for the need to




reduce air pollution from  trucks and SUVs.




            In New  Jersey  and across the Country air




pollution is  taking enormous toll  on public  health.




Nationwide air pollution sends more than 150,000




Americans to  emergency rooms each  year and causes




more  than 6 million asthma  attacks according to a




recent study  by Act Associates, a  reputable




consulting firm.   Even worse, particulate air




pollution is  responsible for cutting short the lives




of more than  40 thousand Americans each year.  Have
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                                                    231
                     Ami Doshi   NJ PIRG




    big  trucks  and buses,  including diesel and gasoline



 3 II  powered  vehicles over 8500 pounds, are among the




 4   biggest  causes of our pollution problems.  Ad




 5   manufacturers have done very little to curb their




 6   pollution.   These big vehicles are a bigger




 7   pollution problem today than they were 30 years ago




 8   when the Clean Air Act was passed.




 9                In urban areas as much as 50 percent of




10   the  deadly particulate pollution we have breathe




11   comes from diesel vehicles.  Making matters worse,



12   this diesel pollution has been found to contain




13   hundreds of toxic substances, and more than 30




14   health studies link diesel pollution to lung cancer.




15                It is high time for manufacturers of




16    diesel engines and big trucks to use widely




17    available technologies to reduce their pollution.




18    Yet, we know from experience we cannot count upon




19    them to do this voluntarily, nor can we rely on




20    manufacturers to obey the rules with out strict




21    monitoring and enforcement.  Just last year these




22    same diesel engine manufacturers were discovered to




23    be cheating on emissions tests resulting in an




24    increase of smog-forming pollution of over 1 million




25    tons each year.
                      Vincent Varallo Associates, Inc.

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                                                232
                Ami Doshi    NJ  PIRG




            New Jersey  PIRG  applauds  the EPA for



proposing a forward-looking  program to close the SUV




loophole that allows  SUVs  to emit  up  to five times




more pollution than a car,  to set  standards on




trucks and the fuels  that  power them,  and require




strict tests to ensure  compliance  with the




standards .




            However,  we are  extremely concerned that




the proposal is phased  in  over  an  unnecessarily long




period of time resulting in  delayed health benefits




for the public and  that the  proposal  may not




adequately ensure that  heavy-duty  trucks comply with




the standards throughout the time  they are on the




road.  Specifically,  we urge the EPA  to considering




the following changes to strengthen the heavy-duty




program:



            Number  1, accelerate the  time line for




closing the SUV loophole.   Under the  Tier 2 auto




pollution program,  all  cars  and smaller SUVs will be




required to meet  clean  car standards  by the year




2007.  There is no  technological reason to give




automakers another  two  years to clean up the largest




and dirtiest SUVs of  all.   All  passenger vehicles




should meet clean air standards by 2007.
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 1
 2
 3
 4
 6




 7




 8




 9




10




11




12




13




14




15




16




17




18




19




20




21




22




23




.24




25
                                                     233
                Ami Doshi  -  NJ  PIRG




            Number 2,  take  in the  heavy-duty




particulate standard  by  2004.   According to the




Manufacturers  of  Emissions  Control Association,



MECA, the technology  is  already available to cut




particulate pollution from heavy-duty trucks by




using existing catalysts.   Yet  the current proposal




would have the public wait  until 2007 before any




reductions in  particulate  pollution  from heavy-duty




trucks would occur.   This  delay will contribute to




the premature  deaths  of  thousands  of Americans.



            Number 3,  adopt strong standards for the




year 2007.  Pollution from heavy-duty vehicles is an




urgent problem that  must be addressed as soon as




possible.  The EPA must  forge ahead  with an




additional 90  percent reduction of particulate




matter and nitrogen  oxide  no later than 2007.




            Number 4, clean up  diesel fuel.




Pollution control systems  can be truly effective




only when they are coupled with low-sulfur fuels.




In  fact, current  sulfur  levels  in diesel fuel are so




high, they actually  prevent the use  of the most




advanced pollution control technology.  In order to




ensure that diesel pollution equipment is effective,




all  diesel  fuel sulfur levels  in both on-road and
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                                                234
               Ajayi  Harris  -  Citizen




off-road diesel  fuel  should  be capped 10  parts per



million sulfur by  2006.




            And  Number  5,  ensure  that the trucks



stay clean once  they  are  on  the road.  Lab tests




quite often do not reflect the true on-road




emissions.  Often  faulty  pollution control equipment




goes unnoticed by  the truck  owner.   Moreover,  in the




past, engine manufacturers and users have seriously




undermined emission standards  by  using cheating




devices during testing  procedures.   In order to




ensure that clean  trucks  stay  clean,  in-use testing




and on-board diagnostic equipment should  be required




for all heavy-duty trucks,  both gasoline  and




diesels .



            Once again, I  thank you for allowing me




to speak on this important issue.




            MS.  OGE:   Thank  you.




            Mr.  Harris, Mr.  Haupt,  and Dennis




Winters.



            Good afternoon.   Please state your name




and your association  for  the record.



            MR.  HARRIS:   My  name  is Ajayi Harris.




That's A-J-A-Y-I.   I  live  in West Philadelphia.




Actually, I moved  to  the  City  to  work with the PIRG
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                                                235
               Ajayi  Harris    Citizen




partly because a  really  big  problem is  Philadelphia




has the fourth air  quality  in  the  country.   Lots of



urbanization, a lot  of people  living in densely




populated area, so  really a  great  opportunity to




come and work in  this city  and address  clean air




issues.  Particularly also  on  a personal level, I




myself am an asthma  sufferer myself, so I can speak




from personal experience both  on not only having to




breathe as  a problem,  both  whether I'm  hanging out




with friends or sitting  behind a diesel truck that



is just emanating tons and  tons of smoke and




pollution out of  the back,  whether it's a bus or




diesel truck or take your pick, Mercedes Benz,




whatever.



            So  it was a  great  opportunity for me to




come and testify  today and  just to tell you all that




as speaking from  a  personal  experience  it's tough




being  an asthma sufferer.   And there are kids and




adults out  there  that every  day sulfur  from this




problem.  I encourage the EPA  to take action on this




and really  find the will and courage to really go




out and  implement these  tougher standards.   And I




believe  that's  it.   Thank you.



            MS. OGE:   Thank  you for coming forward.
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                                                     236
1                   Dennis Winters   DVTUG




2                I will call again on Mr. John  Langan,



3   Mr.  Dennis Winters.




4                 What we will do is we will  stay  here




5   until  time has been scheduled for these  individuals.




6   So  we  ask that the court reporter to please  stay




7   with us.   We can stand up and walk around.   What  I



8   would  suggest for us to do is to try to  see  if  we




9   can get together by 4:15 and see is if the




10   individuals sign in here at 4:15.  So let's  take  a




11   break  until 4:15.



12                 (Brief recess.)




13                MS. OGE:  We will ask Mr. Dennis  Winters




14    and Mr. Abram Haupt to come forward, please.   Please




15   print  your names on the cards and state  your  names




16    for the court reporter.



17                MR. WINTERS:  Did you want us  to  speak




18    in that order?



19                MS. OGE:  State your name and  spell it




20    for the court reporter.




21                MR. WINTERS:  My name Dennis Winters,




22    D-E-N-N-I-S, W-I N-T-E-R-S.



23                MS. OGE:  Mr. Winters, good  afternoon.




24    Please start.



25               MR. WINTERS:  Thank you.  I'm  an officer
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                                                     237
1                   Dennis Winters - DVTUG




2    of  the  Delaware Transit Users Group or DVTUG.




3                Delaware Valley Transit Users Group



4    would like to thank the EPA for the opportunity  to




5    comment on efforts to reduce the pollution from




6    heavy-duty diesel engines.  Far too many people  die




7    and suffer each year because of the particulates  and




8    other emissions from diesel engines.  The health  of




9    thousands of young and elderly in the Philadelphia




10    area is compromised by this continuing source of  air



11    pollution.  And what is not known about the




12    consequences of this fine particle pollution is  even




13    more frightening.  Who knows what carcinogens invade




14    the eyes, nose, throat, and lungs riding these




15    minute particles?



16                As a transit promoter, DVTUG is




17    concerned, in particular, with the diesel-powered




18    buses operating in the Philadelphia metropolitan




19    area.  Both over-the-road and local bus fleets are




20    almost exclusively diesel powered.  Because much  of




21    the pollution from diesels takes place as billowing




22    clouds of black soot,  it is one of the few remaining




23    obvious sources of visible air pollution.  Based  on




24    the number of complaints we receive,  the continuing




25   reliance  of SEPTA and  New Jersey Transit on
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                                                     238
                    Abram Haupt - Citizen




     diesel-powered buses is a real impediment to gaining




 3    new transit users or even greater tolerance from  the



 4    public  who does not take transit.




 5                The members of DVTUG hope  that




 6    promulgating these regulations will now offset  some




 7    of the  external costs associated with  the health



 8    costs and pollution and that the purchase price of




 9    new natural gas-powered buses will become more



10    competitive with diesel vehicles.  Perhaps then




11    public  transportation agencies,  like this area's




12    SEPTA and New Jersey Transit, will no  longer cling




13    to the  excuse of price difference when choosing




14    diesel-powered buses over much cleaner alternatives.




15                 MS. OGE:  Thank you.




16                Mr. Abram Haupt.




17                MR. HAUPT:  Do you want me to state my




18    name?



19                MS. OGE:  Please.



20                MR. HAUPT:  My name  is Abram Haupt,




21    A-B-R-A-M, H-A-U-P-T.  I'm a concerned citizen  and




22    I'm testified with  the Pennsylvania Public Interest




23    Research Group.  I'm going to tell you a brief




24    little story today.  I'm a college student and



25    concerned  citizen and I'm here to testify in support





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                                                     239
1                   Abram Haupt   Citizen




2    of  the  new proposed emission standards on cars and




3    SUVs,  but I am a SUV owner.  Basically, I am




4    particularly concerned about the fact that SUVs are




5    given  a lethal loophole in our current standard




6    system and are allowed to pollute substantially more




7    than the average vehicle.  I purchased my SUV in  the




8    fall of '96, and one thing I find remarkably




9    striking is the fact that through my entire




10    purchasing process, I was never informed of the




11    potentially polluting, or I should say the polluting




12    ramifications of this vehicle-  This was, of course,




13    before I became an environmentalist.




14                And the point of this story is that auto




15    companies have a responsibility to provide




16    environmental responsible vehicles and oil companies




17    have an obligation to sell low-sulfur fuel because




18    the average citizen is usually not aware of these




19    things when he or she purchases a vehicle.  When  the




20    typical American purchases a vehicle, they do not




21    know that 40,000 Americans died prematurely last




22    year due to air pollution.  Proof of this is the




23    huge rise in SUV sales over the last decade.



24                Concluding, corporate America has an




25    obligation  to create vehicles and fuel safe for all
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                                                 240
                Abram Haupt -  Citizen




Americans,  and  they have the  obligation to do  it




now.  If we  do  not  act immediately on this issue,




the respiratory functions of  hundreds of thousands




of Americans  within the next  few years may be  at



stake.




             MS.  OGE:   Thank you.  And this concludes



the public  hearing  today.  Thank you for coming



forward to  testify.




             (Pubic  hearing concluded at 4:20 p.m.)
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                                                      241
2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25
               CERTIFICATION



            I  HEREBY CERTIFY  that  the  foregoing

proceedings of the United States  Environmental

Protection  Agency Public Hearing  of  November 2,

1999, were  reported fully and  accurately by me, and

that  this  is  a correct transcript of  the same.
                             Bernadete M.  Black, RMR
                             and Notary Pubic
                                  C.  Bradley i/RPR
                             and Notary Public
                       Vincent Varallo Associates, Inc.

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WORD INDEX

-------
Environmental Protection Agency Hearing
                                                         Hearing
                                                                             November 2,1999
$15 billion 148:16
$4.5 billion 148:19
$6.2 billion89:6
$75 107:21
          o
0.01 166:4
0.05 119:21
0.2 166:3
01 48:13; 72:24; 120:18;
137:9; 154:19
0548:19:72:9,12;
136:22; 158:24
1 26:4; 46:24; 56:17;
64:11; 95:17; 128:17;
136:12; 137:7; 152:20;
154:12; 157:23; 163:24,
25; 187:18; 231:24;
232:18
1.25142:5
1.5142:7
1.7163:22
10 25:12; 71:6; 87:11;
91:6; 98:5; 148:9; 153:23;
154:11; 160:13; 170:7;
171:18; 181:19;il87:17;
204:9; 205:18; 208:24;
215:20; 222:8; 225:2;
234:2
10;000 79:8; 102:24;
114:14; 122:2,12,15;
138:25; 139:12
10-year-old 88:9
100 24:22; 100:12
100,00074:6
104169:7
107 161:20
11 163:24; 187:17
114182:2
117164:14
 119169:4
 11:1565:24
 12 74:11;79:10;81:11;
 103:6,10; 168:25
 124109:19
 12:15112:9
 13 136:25; 163:22; 189:23
 14204:4
 14,000 11:13; 47:2;
 123:8; 131:8; 140:5
 15 5:8;81:11; 129:25;
 148:9; 154:8,10; 187:19;
 213:2
 15,00073:8
 150,000 61:12; 109:8;
 148:18;  150:17; 156:21;
230:19
16523:2
1835:20,23,25;89:4;
148:10; 164:7
18-wheelers 151:8
185,00035:25
19 38:24; 204:3, 5
197,00035:17
1970181:25:188:10;
204:14
1979164:15
1980 38:16; 89:3; 125:22;
148:8; 170:5
1982 69:16; 210:4
1990188:12
1992210:4
199389:3:180:21;
225:16
199469:16;136:24;
187:24
1995 113:12; 164:15;
168:6; 198:15; 199:16;
200:11; 202:18; 203:7;
220:3
1996 181:2
1997 5:14; 10:8,9; 28:9;
78:12; 88:13; 94:14;
125:22; 181:25; 182:16;
184:2; 186:7; 200:5;
216:17
1997-200453:17
1998 26:12; 33:6; 35:15;
38:18, 24; 68:22; 126:7;
201:11; 203:22; 204:6;
216:25
1999 13:6; 16:14,18;
18:19,20,21;19:8,13;
79:2; 93:22; 168:23;
187:21; 198:12; 200:9,20,
21,22; 201:20; 202:4;
203:17; 215:7; 218:17
1:15112:8
1:20112:10
 2 6:10,18; 7:7,20; 8:19;
 10:24; 12:4; 27:8; 32:23;
 33:7; 47:16; 48:15; 67:14;
 72:22; 76:15; 77:13; 79:5,
 12,19, 22; 80:3,8; 81:16,
 20; 82:14,19:96:15;
 100:11; 103:12; 112:18;
 115:15,23; 117:15; 122:2,
 3,13; 128:13; 131:23;
 132:5; 133:11; 138:24;
 139:4,13; 142:14; 144:9;
 152:5,15, 21; 153:4,16;
 154:20; 158:7; 159:8;
 165:16, 25; 170:16; 202:3;
 205:5; 208:6; 212:25;
 232:19; 233:2
 2,000 93:21; 209:17
 2,598 164:15
 2-and-a-half 129:17
2.5 71:6; 136:17
20 25:4; 71:11; 107:6,17
200 228:20
2000 78:10; 155:23;
160:14; 187:18, 20
20004 140:9
2001 99:10; 131:15
2002 46:7,14; 49:23;
130:2; 145:2; 179:9
2004 6:12, 22; 9:7, 24;
10:12,18; 16:3,14,21;
17:6,8,10,15; 28:6;
29:15; 30:6; 32:16; 44:22;
45:8,13; 46:7,10; 48:19,
20; 49:23; 50:15; 52:24;
55:5; 57:6,15; 59:20;
63:13; 72:13; 75:25; 78:8,
13; 82:9; 86:20; 96:24;
99:17; 101:2,14; 111:20;
113:10; 114:8,18; 115:4,
6,13,22; 116:15; 117:9;
119:11,25;120:15;
128:18;129:11,19; 131:4,
16; 132:15;  133:2,7,19;
134:12; 135:13,24; 136:6;
137:6,8; 140:20; 141:25;
142:10,14;  143:10,18,23,
24; 144:9,12; 146:6,16,
19; 149:11;  153:5,11,14,
22; 158:21;  159:25;
165:21; 166:7; 170:24;
171:11; 172:20; 174:8;
178:22; 180:25; 181:5;
182:14; 183:19; 184:22;
192:9,10,16,18; 193:4,
12; 200:6,8; 201:5; 205:9;
206:10; 208:14,19;
209:24; 217:21; 218:7,11;
219:10; 222:3; 224:25;
229:23; 233:3
2005 84:7
2006 87:12; 98:6; 160:13;
205:19; 208:25; 222:8;
225:2; 234:3
2007 7:2; 9:21; 12:5;
28:11,17,21;29:21;
47:25; 48:12,14,16; 49:6;
57:6,16; 62:7; 63:8; 78:15;
84:7; 86:17,25; 87:6;
89:23; 96:17,21; 97:6,12,
17; 108:3; 111:18,21;
120:8,24; 135:16; 137:3,
9,10,16; 140:22,25;
149:8; 152:23; 153:3,12,
20,22,23; 154:2,18,21;
159:3,10,14,16,24;
165:16, 22; 170:18,22;
171:2,7,9; 195:12; 196:9,
17; 205:4,10; 206:6,8;
208:8,12,16; 213:13;
221:25; 222:6; 225:3;
229:21; 232:22, 25; 233:8,
13,17
2008 171:19
2009 63:2; 108:3; 170:20;
205:5; 208:10
201024:12; 25:9; 126:18
2020 67:23
21 36:2
210 170:2
21st 151:14
220,000 109:25
229,000 36:4
22nd 8:7
23 109:20; 154:8; 187:19
25 138:20; 144:4; 163:5;
210:5
25,000 170:3
26 70:2
26,000 180:7
27204:4,6
27,000 109:25
276,000 35:21
2836:6
29 18:24; 19:6; 116:9;
201:23; 202:4
290,000 184:15
29th 8:9
2:15 147:8
2nd 13:6; 18:24,25;
116:10
3 108:7; 153:15; 165:24;
233:12
3,000 179:23
30 13:3; 18:13; 29:14;
48:18; 70:19; 83:11;
94:22; 95:5; 105:3; 111:2;
157:11; 161:11; 162:25;
164:6; 190:15; 207:16;
231:7,13
307-B5 12:22
31 182:3; 218:17
31st 116:5
33 134:20; 169:5; 210:6
34 182:5
35,000 180:2
370,00094:14,15;
203:19
3844:13
39 125:24
3:15 147:11
4 24:14; 154:17; 166:12;
233:18
4.6 38:16; 170:5
40 9:11; 26:7; 68:23; 75:6;
156:14; 230:25
40,000 85:12; 150:21;
157:3; 221:10; 224:18;
239:21
40-percent 71:11
400,00041:19
43 126:21
435,000184:16,23;
189:7
46,000 35:23
460 93:23
460,000 25:18
48-year 88:9
49 100:22; 125:21
4:15 220:13; 236:9,10,11
4:20 240:10
5 82:11; 84:17; 89:3;
108:7; 117:15; 120:18;
136:10; 153:10; 154:23;
234:4
5,000 68:22; 207:4
5,637 164:15
50 8:23; 38:25; 70:8;
86:20; 94:25; 110:20;
111:20; 113:18; 126:13;
153:7; 157:7; 165:20;
170:24; 205:8; 208:14;
214:9; 222:2; 224:25;
229:22; 231:9
500 30:5; 166:14
500-pound 112:20
51 150:2
54 168:24
55 22:25
5:15220:17
6 89:2; 109:9; 126:20;
148:16; 150:19; 156:23;
230:21
60 21:23; 25:14; 39:2;
70:19; 126:7; 127:11;
150:22; 177:13
600 173:4
600,000 25:10
61 69:17
616 38:18; 203:22
65 163:22
650,000 94:8
6th 8:5
735:17
70 25:11; 125:25; 126:23
700,000 164:3
7269:18
74 186:12
75 9:22; 38:15; 134:21;
170:5; 198:20
78 9:9; 10:15
780,000 36:6
79,000 35:19
7th 173:2; 190:13,14
 Vincent Varallo Associates, Inc.
                             Min-U-Script®
                                                 (1)  $15 billion - 7th

-------
                                                          Hearing
 November 2, 1999
                                                Environmental Protection Agency Hearing
           8
 8 24:13; 91:8
 8,500 8:11; 11:13
 8-hour 93:23
 80 120:19
 800,000 164:5
 85 99:4; 122:15
 8500 6:21; 8:16; 9:8;
 32:20, 22; 33:10; 73:7;
 79:7; 94:17; 102:24;
 114:13; 122:11; 128:12;
 131:21; 133:10; 157:5;
 180:6; 231:3
 86.1008-90 175:16
 86.1342175:5,6
 86.1360-2004174:20
9 25:13; 35:19; 163:24
9-year 37:22
90 9:22; 76:8; 97:15;
112:20; 125:16; 135:9;
149:8; 153:13; 159:25;
166:10; 171:11; 198:21;
206:10; 208:19; 214:9;
222:4; 233:16
90-day 202:8,11
90-percent 87:4
95 26:2; 187:24
96 185:9; 239:8
9600 203:18
97 185:9
98 169:9
9935:15
9th 193:23
A(wm 175:3,5
A-B-R-A-M 238:21
A-J-A-Y-I 234:24
abandoned 228:3
ability 131:18; 144:6
able 16:12; 25:22; 72:15;
85:21; 107:23; 196:21;
202:15; 229:3
above 80:7; 126:8;
131:21; 163:23; 229:5
Abram 236:14; 238:1,16,
20; 239:1; 240:1
absences 164:10
absolutely 27:13; 31:9;
33:21; 117:16; 217:15;
221:25
abundance 227:6
accelerate 86:11;
111:17; 152:20; 170:15;
204:23; 208:5; 221:23;
232:18
accelerated 96:15;
159:8; 166:6
accept 192:3,15; 213:23
acceptable 150:12
acceptance 20:11
accepted 13:5; 130:24
accepting 81:3,4
access 190:11
accommodate 14:17
accommodates 81:11
accomplish 81:5;
145:12,13,23
accomplishing 198:12
Accord 187:22
accordance 12:22
according 13:4; 93:18;
96:25; 109:10; 154:6;
169:25; 203:17; 204:8;
210:2; 228:21; 230:21;
233:3
account 25:13; 148:16;
151:3; 154:8,11; 204:10;
216:23; 217:12
accountable 187:14
accounting 25:4; 127:10
accounts 5:8; 148:14;
196:22
accumulate 211:9
accumulates 169:18
achievable 114:25;
120:20; 121:18
achieve 27:14; 57:22;
72:21; 82:8; 113:15;
119:22; 120:23; 126:11;
160:3; 209:10
achieved 21:15; 120:15;
136:15; 153:18; 198:19
achieves 76:16; 82:13
achieving 72:23; 76:20;
78:20; 114:15; 116:22
acid 26:18; 43:22; 211:21
acknowledged 19:9
acknowledges 218:4
across 8:24,25; 23:3;
27:3; 36:10; 57:7; 66:22;
67:19; 73:11; 85:7; 93:17;
150:3; 156:14,19; 221:9;
224:7; 230:17
Act 12:22; 13:4; 16:16;
20:14; 22:3; 35:7; 38:9;
39:10,14; 74:21; 77:25,
25; 78:8, 25; 82:18; 84:5;
94:23; 99:20; 101:16;
200:24; 203:13; 204:14;
230:22; 231:8; 240:3
acting 214:22
action 18:23; 32:2; 39:7;
147:24; 235:21
active 37:22; 126:18;
135:7
activist 37:20; 156:10;
227:1; 228:1; 229:1
activists 14:19
activities 110:8; 125:2;
127:20,25
activity 164:20
acts 49:2
actual 116:24
actually 49:23; 55:18;
70:12; 96:8; 97:23; 98:8;
160:8; 166:22; 174:17;
233:22; 234:25
acute 164:19
Ad 231:4
add 34:18; 36:14,23;
43:10; 44:12; 70:15;
100:16; 109:14; 174:4;
178:2; 201:15
added 137:23; 153:17;
165:12
adding 105:18; 174:4
addition 25:6; 29:16;
61:3; 81:21; 126:22;
130:5,6,16; 150:24;
164:4; 200:4; 204:15;
228:6
additional 29:17; 53:20;
71:8; 77:19; 80:12; 86:14;
97:15; 100:16; 104:17;
120:13; 122:16; 126:10;
127:3, 5; 130:9, 22; 131:3,
5,16,17; 133:14; 153:13;
159:24; 177:25; 178:13,
17,20; 186:20; 222:4;
233:16
additionally 87:4
address 11:24; 24:25;
28:3; 32:9; 33:12; 40:25;
54:23; 58:6; 124:5,11;
140:8; 146:11; 176:13;
182:9; 189:13; 219:7;
235:6
addressed 20:9; 32:7;
33:11; 55:24; 77:14; 87:3;
97:14; 117:19; 159:17;
171:8; 206:7; 233:14
addresses 174:7
addressing 27:17
adds  80:5; 123:14;
175:19
adequate 17:16; 19:17,
19; 83:25; 116:6; 152:15;
173:20; 174:13; 201:5
adequately 96:6; 111:12;
158:15; 201:2,20; 232:13
adjust 185:12
Administration 8:20
administrative 77:11
administrator 8:4
Administrators 22:22
admissions 164:23;
167:8; 170:7; 203:19
admit 182.14
admittedly 80:16
adopt 16:12; 63:20;
67:13; 72:15; 86:24;
108:21; 111:21; 149:6,14;
154:17; 159:15,24; 166:6;
171:6; 206:5; 233:12
adopted 29:11; 67:24;
97:12; 108:2; 127:19;
149:19; 181:11,13
 adoption 17:10; 20:8;
 45:23,25; 132:13; 162:9
 adopts 21:19
 adults 35:18; 36:5,6;
 69:17; 88:8; 229:14;
 235:20
 advance 29:5; 117:4
 advanced 28:23; 29:2;
 73:21; 76:12; 82:25;
 83:13; 97:24; 120:10,11;
 121:22; 128:24; 160:9;
 233:23
 advances 30:15; 138:8;
 139:9; 226:10
 advantage 103:25;
 105:13
 advantageous 146:20
 adverse 23:24; 26:17;
 68:16; 167:6
 adversely 31:18; 167:4
 advice 134:8
 advise 10:20
 advocacy 41:18; 88:6
 advocate 73:2; 88:4;
 93:9; 206:23
 Affairs 75:23
 affect 12:5; 186:25
 affected  19:17,25; 21:25;
 54:3; 58:11; 77:5; 85:20
 affecting 29:20; 31:18
 affects 61:8; 93:25;
 104:25; 109:15; 167:4;
 183:22; 211:23
 affiliates 179:25
 affiliation 13:24
 affirmation 172:19
 afford 207:20; 229:3
 afforded 79:14; 202:9
 afraid 90:22
 African 109:15
 African-American 228:8
 African-Americans
 148:12
 after-treatment 84:19
 afternoon 118:3,4,5;
 124:14,15,16; 133:24, 25;
 147:15,16,19; 149:23,24;
 156:8,9; 160:23,24;
 167:23,24; 172:7,8;
 179:13,15; 197:25; 198:6;
 202:24,25; 206:16,17;
 209:15,16; 220:25; 221:2;
 223:20,21; 225:6,7;
 227:17,18; 230:9,10;
 234:21; 236:23
 again 9:16; 70:25; 79:5;
 98:21; 100:13; 101:8,9;
 121:15; 122:19; 133:4;
 135:25; 144:17; 146:2;
 155:15; 160:20; 186:22;
 194:11; 195:3; 209:12;
 225:4; 234:16; 236:2
against 31:15; 32:13;
 181:12
age 35:20, 23, 25; 89:4;
 148:10; 163:22; 213:7,9
 aged 163:22; 213:2-
 214:20
 agencies 33:17; 50:23'
 52:14; 57:7; 71:14;    '
 104:11; 227:12; 238:11
 Agency 4:4; 28:13;
 31:21; 32:24; 33:21; 34:3-
 44:7; 48:10,17; 49:19;
 51:15; 53:4,19; 54:9;
 55:11; 57:14; 60:4; 75:14;
 77:7; 81:8; 101:13;
 103:19; 116:4; 117:22-
 130:24; 141:3,17,24;
 142:25; 144:22; 159:23;
 178:16; 182:15,24;
 183:10,24; 184:20;
 185:12; 187:13; 188:4,23;
 189:6,10; 193:16; 197:15;
 199:10,18; 202:16; 217:4
 Agency's 19:21; 77:10;
 118:19; 176:12,23; 177:2;
 183:17; 185:23; 189:18
 agenda 75:13,14
 ages 36:10
 aggressive 24:25; 79:21;
 181:11
 aggressively 30:21;
 137:15
 ago 7:19; 34:24; 94:22;
 105:3,10; 124:19; 161:20;
 181:19; 231:7
 agree 45:6; 55:15;
 119:13; 158:8; 183:17;
 190:3; 221:22
agreed 49:24; 115:5;
 143:16; 144:13,24; 179:8;
 182:16; 191:10; 200:11,
 14
agreement 50:13,14;
 128:21; 179:9; 199:16;
218:7
agreements 49:21
agricultural 30:12
ahead 50:19; 55:18;
85:14; 87:4; 91:4; 97:15;
 102:5; 159:22; 229:18;
233:15
ailments 94:10
air 8:2; 12:22; 16:5,16;
20:14; 22:3,22,23,25;
23:8,13, 22; 26:8,13,20;
27:14; 30:24; 34:19,21,
25; 35:9,12; 36:4,13;
38:5,9,10,12,19; 42:15;
44:2,8,13; 48:8; 49:20;
60:21; 61:14; 65:3,4;
66:22; 67:8; 74:21; 76:11,
20; 77:16, 25; 78:20;
82:16; 83:4,15; 84:19;
85:8;90:2,3,12,13,14;
91:10,14; 92:4,4; 93:12,
 15,19; 94:4,23; 104:24;
 105:23; 107:11; 109:6,7,
 17,21; 110:2,17; 123:16;
 124:11,17,25; 125:13,16,
 17,18,20; 126:6,9,9,12,
 17; 127:13; 134:4; 149:25;
8-air  (2)
                            Min-U-Script®
                                                                                       Vincent Varallo Associates, Inc.

-------
Environmental Protection Agency Hearing
                                                        Hearing
                                                                            November 2,1999
150:6,8,11,13,16,20,
25; 151:9; 152:3; 156:10,
16,19,21, 24; 157:2,6;
161:10,15,17,19; 162:22,
25; 163:9,11,12,20;
164:2,18, 25; 165:13;
167:3,12,14,17; 168:9,
19,21; 169:2; 180:19;
181:22,24; 182:6; 183:14;
187:13; 188:3;  197:21;
199:25; 200:24; 203:11,
13,14,16,17, 20; 204:14;
205:13; 206:1,  20,22,23,
24,25; 207:1,3,9; 208:1;
209:8,11, 25; 210:10,17;
211:23; 212:2,10,17,18,
23; 219:11; 221:7,15;
224:22; 225:24; 227:22;
228:17, 24; 229:12, 21;
230:2,16,17,19,23;
231:8; 232:25;  235:3,6;
237:10, 23; 239:22
Air's 206:21
airborne 70:21
airport 81:9
Ajayi 220:15; 234:1,23;
235:1
ALA 67:13
Alan 156:5; 179:13,15
ALAPA 160:25; 161:6,
20,23; 162:9; 163:23;
165:5
ALAPA's 165:13
ALAPCO 22:23; 27:7,25;
29:10; 32:20
ALAPCO's 29:25
alarmed 154:13
alarming 164:13; 211:18
alert 61:18
Alexander 179:17
Alexandra 109:3
allergies 36:2,3,7
Alliance 75:24; 76:5,8,
10,23; 79:20; 80:9; 82:4;
83:22; 84:9, 20; 103:23
allow 77:19; 83:13; 84:5;
89:13; 101:13; 104:12,12;
130:10; 138:9; 166:13;
177:3; 202:8
allowable 119:2; 121:4;
155:8; 176:5; 177:24;
178:9; 192:21
allowed 139:8; 158:4;
179:6; 205:5,10; 239:6
allowing 39:18; 98:22;
160:20; 184:22; 234:16
allows 75:8; 95:21;
99:21; 152:6; 232:4
almost 24:11; 35:25;
100:12; 104:7; 126:23;
148:9; 190:14; 207:5;
237:20
alone 94:14;  100:11;
146:24; 164:17,25
along 116:24; 133:18;
163:8; 181:3;  210:14
alter 114:10
altered 182:18,19;
183:10
alternative 26:23; 54:11;
108:15; 145:24; 224:7;
225:12,13, 22; 226:7, 25,
25;227:4,7,10,13
alternatives 238:14
although 41:12; 81:12;
85:6; 141:19
Altman 112:12; 220:19
always 55:9; 174:25
Ambient 38:10,19; 72:3;
115:12; 164:18; 175:25;
203:14
Amen 36:24
amendments 188:12
America 40:18; 179:24;
214:20; 226:8; 239:24
America's 40:20; 41:2;
42:22; 148:10; 179:22
American 66:8,8,11,25;
113:4; 160:25; 162:17;
168:5; 179:17; 183:13;
203:6; 239:20
American's 49:5
Americans 40:2; 42:14;
49:5; 71:19; 85:13; 97:10;
108:8; 109:8,13,16;
149:21; 150:9,17,21;
156:22; 157:3; 159:6;
161:12; 171:5; 230:20,25;
233:11; 239:21; 240:2,5
Ami 230:1,12; 231:1;
232:1; 233:1
among 26:18; 38:15;
69:17,18; 94:18; 110:16;
114:7; 164:3,16; 169:11;
170:4; 199:14; 207:10;
231:3
amount 5:10; 58:25;
142:12; 198:22; 205:12
ample 45:11; 138:14
analysis 69:9; 77:6;
79:18; 121:20; 174:7
and/or 29:20; 164:20
Andrew 60:14; 112:12;
220:19
Angeles 35:4; 90:16
Angie 156:1,4,10; 157:1;
158:1; 159:1
announce 21:22
announced 8:5; 27:11;
159:23
announcement 76:5
annual 8:23; 195:19
annually 164:12
anticipate 132:17; 179:4;
216:18
anticipated 31:13; 44:3;
57:22; 165:25; 217:9;
220:3
anticipates 184:21
anxious 7:11
Anymore 101:25;
 104:15; 147:4; 220:4
apologies 41:13
apologize 124:18
apparently 188:4
Appeals 68:15; 69:7;
71:2
appear 179:18; 188:22
appears 28:14; 81:7;
182:16; 183:9; 186:10,16;
189:4; 196:22
applaud 27:7; 39:7;
62:11; 85:24; 89:12;
207:23; 221:17; 230:3
applaudable 56:16
applauding 42:10
applauds 95:19; 170:10;
232:2
application 66:14
applications 121:21;
123:3; 198:10
applied 30:8; 84:17;
122:11
applies 114:11; 196:8
apply 13:9; 30:2; 33:5;
74:22; 139:23; 143:24
applying 33:8
appointed  196:2
appreciably 117:4
appreciate 148:2;
156:15; 172:15; 188:21;
223:24
appreciates 84:20;
134:10; 161:2; 202:19
approach 9:4; 21:15;
23:11; 27:20; 28:3; 49:4;
84:16; 120:10,17; 122:20;
199:18; 212:5
approaches 122:5
appropriate 4:14; 28:6;
29:19; 33:3; 118:25;
132:3; 138:7; 175:8
appropriateness 16:15;
219:6
approved 139:22
approximately 74:6,11;
148:18,24
April 33:6; 217:6
ar 209:10
ARB 50:23; 127:22,25;
128:16; 129:10; 132:12,
22,25; 133:6; 146:11
ARB's 125:5; 127:15;
128:19
area 4:10; 5:6,19; 9:2;
35:22; 94:7; 110:6; 169:3;
183:24; 189:16; 204:2;
210:4,7; 228:20; 235:5;
237:10,19
area's 238:11
areas  23:3; 24:3,23;
48:7; 57:8; 68:13, 20;
69:12; 70:11; 94:4,24;
110:20; 125:14; 148:13;
150:10,12; 157:7; 169:15;
204:11; 207:14; 229:19;
231:9
arena 226:25
argue 32:8
argued 184:13
arguments 55:3
around 43:24; 101:12;
142:14; 191:10; 226:9;
236:7
arrangements  15:4
array 26:16
article 92:10
Arts 106:11
as-of-yet 184:25
aside 99:23; 174:24
aspect 143:22; 195:25
aspects  23:17; 45:22;
100:2; 139:15; 143:22;
144:8; 182:9
assess 10:9; 16:14;
19:19; 22:6; 116:7
assessed 182:12
Assessment 44:9;
119:10; 121:16; 173:14;
183:17,24; 185:6; 186:6
associated 22:2; 40:25;
43:18; 75:10; 123:13;
128:14; 138:16; 151:6;
177:22; 238:7
Associates 230:22
Association 15:22;
22:23; 45:10; 66:8,9,11;
72:7; 97:2; 118:8,11;
160:25; 161:9; 162:17;
179:17,21; 183:13; 233:4;
234:22
associations 22:25;
23:5; 29:13; 33:6
assume  54:22,25;
191:25
assuming 52:21; 67:23;
145:17
assurance 11:9; 131:17
assure 73:12
asthma 4:24; 25:25; 35:7,
20; 38:15,17; 41:2; 43:19;
61:13; 64:15; 69:16,20,
21,22,24; 87:25; 88:8,10,
22; 89:4; 91:6; 92:3,7,11;
94:10,14; 107:8; 109:9;
110:2; 148:7,7,14,17;
150:19;156:23,24;
163:16; 164:6,7,12,13,
21,24; 170:3,4,6; 203:19;
207:6; 212:16,16,19;
214:19; 221:15; 228:9,11,
12; 230:21; 235:8,19
asthma-related 149:12
asthmatic 37:24; 38:6;
62:17; 88:25; 209:19,20;
210:12;212:14,15
asthmatics 39:25; 40:4;
169:24
astonished 214:10
ATA 179:20; 190:2;  195:6,
15
ate 180:11
atmosphere 25:7;
169:18
attached 29:21
attack 156:25
attacks 4:24; 43:19;
6l:13;69:22,24;94:14;
109:10; 110:2; 148:17;
150:19; 156:23; 170:3;
203:19; 221:15; 223:2;
230:21
attain 141:24; 167:12
attained 4:25; 5:3
attainment 126:11
attempt 78:24; 79:11
attempts 84:9
attending 144:2
attention 29:24; 148:5
attest 107:13
attorney 37:19; 41:16
attributed 24:17; 39:3;
164:10; 203:20
attributes 81:3
audience 14:13; 220:11
Audit 175:17,23; 176:3,6
Audits 176:8
Audubon 209:18;
210:22,24
August 168:23
authorities 69:6
authority 223:15
authorized 13:11
authors 12:10
auto 39:17; 42:20; 46:25;
47:17; 63:2,6; 86:13;
96:15,18; 152:21; 170:16;
205:2; 208:6; 210:7,18,
19; 232:19; 239:14
automakers 152:24;
170:20; 208:9; 224:22;
232:23
automobile 35:2,3;
39:11; 74:10; 75:24; 85:15
automobiles 62:4
availability 29:3; 122:21;
129:21
available 15:6; 16:18;
30:18; 45:12; 66:4; 72:16;
73:23; 86:21; 95:9; 97:3;
111:4; 121:17; 136:7;
139:10; 145:20; 151:16;
153:6; 157:14; 158:23;
162:7,7; 165:10; 166:8;
172:25; 180:14; 194:2,20;
207:20; 214:13; 224:23;
231:17; 233:5
Avenue 44:18
average 103:24; 125:21;
164:11; 174:22; 239:7,18
avid 110:4
aware 20:21; 32:5; 93:15;
115:24; 128:2; 199:10;
212:16; 239:18
awareness 147:23
away 16:23; 46:11; 51:15;
52:23; 53:7; 222:24
 Vincent Varallo Associates, Inc.
                            Min-U-Script®
                                                      (3) Air's - away

-------
November 2,1999
                                                         Hearing
                                               Environmental Protection Agency Hearing
baby 12:18
Bachelor 161:4
back 7:18; 27:3; 53:5;
58:12; 105:12; 106:5;
107:7; 146:2, 2; 180:21;
184:2,13; 185:5; 235:13
background 198:17
backsliding 185:4
bad 85:19; 88:12; 91:10;
107:11; 181:24
balance 211:22
balanced 118:20
Baltimore-Washington
169:14
barking 91:23
base 58:8; 105:19
based 16:17; 26:14,19;
27:12; 28:23; 29:2,17;
31:23; 35:15; 99:10;
 146:4; 178:15; 185:13;
237:23
basically 65:11; 144:9;
 195:22; 239:3
 Basin 44:13; 126:10,18;
 127:13
basis 27:6; 125:20;
 146:21; 162:8; 200:25
basketball 37:23
battling 124:19
 beach 169:6,19
 became 239:13
 Bechis 65:19,23; 66:2;
87:1,21,22,23,24,25;
88:1; 89:1; 90:1; 91:1,5,6;
 92:1,9,21
 Beckel 15:13
 Becker 22:18,19,20;
 56:23; 57:17; 147:1,13,
 15,16,19,20; 148:1;
 189:20; 190:8; 198:4
 become 10:18; 90:17;
 94:10; 106:18; 146:7;
 182:17; 185:20; 211:21;
 238:9
 becomes 94:11; 100:14;
 185:10
 becoming 69:20; 182:15;
 196:25
 begin 67:25; 124:24;
 149:4,13,19; 167:13;
 172:17; 181:12; 209:10
 beginning 6:22; 9:7;
 36:10; 68:2; 91:24
 begins  42:13; 140:21
 begun 105:17
 behalf 4:3; 15:21; 124:23;
 148:3; 150:2; 180:4;
 209:17;215:23
 behave 218:25
 behavior 166:23
 behind  61:5; 64:12;
 235:11
belated 41:6
belching 151:8
beliefs 221:5
believes 84:9
below 72:22; 73:3;
159:21; 163:21
belt 178:5
benefit 73:10; 165:12;
174:5
benefits 79:18; 82:24;
83:16; 86:6;96:5; 111:11;
117:2; 123:6; 152:13;
153:17; 158:14; 178:19;
212:10; 232:11
Benz 235:14
Bernadette 147:6
Bertelsen 112:14; 118:2,
4,6; 158:22
Bertram 156:4; 167:23,
24,25
besides 108:13
best 166:8; 177:17;
187:25; 219:10
Beth 65:19; 93:5,8
betrayed 59:2
better 64:22; 107:24;
130:10; 195:10; 213:12,
15; 228:14
beyond 9:23; 20:16;
23:10; 33:22; 52:7; 56:4;
120:14; 128:6; 133:19;
159:25; 171:11; 179:8;
206:10; 208:19
bicycle 105:25
bicycles 224:6
bicyclist 224:3
big 23:23; 42:23; 61:15;
72:18; 85:19; 89:19,20;
94:16,21;95:8; 110:15;
111:4; 157:14; 204:8;
207:9,24; 208:11; 209:23;
214:7; 224:8,14; 231:2,6,
16; 235:2
bigger 65:10; 94:21;
189:11; 231:6
biggest 94:18; 110:16;
157:6; 169:11; 231:4
bike 85:23; 224:12
Bill 13:15; 22:20; 57:4;
189:20; 190:7
billion 148:17; 169:4,7,9
billions 167:11; 226:17
billowing 237:21
bing 192:16
bird 209:18; 211:3,5,18,
25; 214:23
birdlife 210:25
birds 210:23; 211:4,9,12
bit 43:8; 54:20; 191:11,
24; 195:13; 196:25
Black 147:6; 151:8;
237:22
Blake 65:18,22; 66:6
blowing 64:13
blue 223:6
blueprint 116:21
Board 16:5; 44:8; 49:20;
124:17; 155:12; 199:25;
225:8
board's 127:18
boat 80:25
Bob 198:1,3,7; 199:1;
200:1; 201:1
bodies 43:24; 44:5
both 7:22; 8:10; 9:16,18;
11:23; 21:4; 30:9; 32:4;
39:19; 50:23; 55:11; 57:5;
62:3; 65:13; 69:5; 71:6;
87:10,10,17; 98:4, 20;
104:7; 108:12,14; 119:2;
126:11; 127:9; 137:12;
139:23; 144:14; 147:12;
155:13; 160:2,12,18;
166:21,21; 171:17,25;
183:23; 199:15; 206:3;
209:6; 211:25; 216:16;
219:9; 227:13; 233:25;
234:14; 235:9,10; 237:19
bought 186:9
boy 90:11; 92:6
Boykin 65:19; 84:25;
85:1,2,3,4; 86:1
Bradley 147:8
brake 153:11; 154:19,20;
166:3,5; 175:6
breach 198:13,14;
215:10,10; 219:16,16,23
break 112:7; 185:19;
236:11
breaks 15:5
breath 88:18; 108:19;
110:22; 167:19; 213:5
breathe 38:4; 44:18;
88:22; 90:3; 91:12,19;
95:2; 107:24; 109:23;
110:12; 125:17; 157:8;
162:22; 197:20; 213:4;
231:10; 235:10
breathers 73:11
breathes 161:10
breathing 36:17; 54:9;
88:11;209:25
Breeze 60:1,12,16,17;
61:1; 62:1; 63:1
brief 4:6; 34:14; 54:18;
124:25; 162:19; 236:12;
238:23
briefly 10:2; 119:7; 221:4
bring  10:24; 86:7; 178:4
bringing 37:17; 64:7;
90:21; 210:24
brings 29:7
Britta 198:3; 206:1,16,
19; 207:1; 208:1
broad 11:10; 75:13;
103:3; 130:14; 197:13
broader 130:18
broadly 197:15
Brockman 198:4;
209:15,16
bronchitis 25:25; 163:17
brought 90:7; 153:18;
180:10,11; 194:6
Browner 8:4
Bruce 112:14; 118:6;
136:16
Brunswick 60:17; 61:20;
64:5,11
Bucks 87:1; 88:1,4; 89:1,
25; 90:1; 204:4
Budget 202:5
build 16:8; 100:5; 210:25
buildings 228:5
built 74:18; 105:6; 181:18
bulk 151:3
bureau 130:16
burn 224:15; 228:22
burning 166:16; 228:22
bus 85:19; 108:12,16;
112:20; 128:4; 235:13;
237:19
buses 23:24; 40:20; 49:8;
66:14; 67:5; 88:20; 91:9;
94:16; 108:17; 110:15;
113:5; 136:16,22; 137:19;
150:6; 151:3,7,18,25;
152:4,8; 153:7,9,25;
169:10,16; 210:14;
225:22; 231:2; 237:18;
238:2,9,14
business 40:15; 113:22;
212:5; 213:14,17
businesses 58:7; 212:12
busses 207:9; 214:14
buy 183:4
C 147:8
calendar 79:3
calibrations 56:9
California 10:18; 11:19;
16:5; 26:8,12; 33:25;
34:25; 44:7,13; 47:12;
49:20; 73:10; 99:9,11,13,
15; 100:21; 107:15;
108:15; 114:4; 124:17,25;
125:10,14; 126:25;
129:14; 132:18; 146:20,
24; 199:25; 204:15
California's 73:8; 132:2
Californians 125:17
call 8:19; 15:12; 49:21;
50:2; 59:11; 112:12;
117:5; 128:2; 156:3;
162:12; 220:12; 222:3;
223:6,12; 236:2
called 29:13; 103:8;
128:6; 200:7; 216:12
calling 226:24
calls 116:4; 162:9;
204:22; 226:6
came 195:17; 219:25
Campaign 41:22; 199:2;
206:1,20; 207:1;. 208:1
campaigned 157:25
Campbell 104:19; 107:1,
3,4; 108:1
camper 80:25
campers 110:5
can 14:23; 17:19; 21:14;
22:6; 31:5; 34:22; 36:3,14;
39:2; 54:7, 22, 25; 55:4,
13; 56:19; 57:2; 63:11;
64:17; 65:3, 5,8,20,21;
73:9; 75:15; 77:21; 83:24;
94:10; 95:12; 97:19;
101:23; 103:15,25;
107:13,18; 108:22;
112:23; 115:7,25; 120:20;
121:9; 122:11,18; 124:3;
129:22; 131:14; 132:9;
136:9, 22; 138:11,16;
141:24; 142:22; 143:7;
150:25; 151:17; 153:6,17;
157:17; 159:20; 160:5;
161:24; 165:6; 167:13;
171:14; 176:10; 177:17;
178:22; 185:12; 186:19;
189:6,19; 193:14; 194:23;
195:4,5,14,15; 197:11;
199:4; 203:20; 206:11;
207:20; 208:22; 209:10;
210:11; 212:4; 214:12;
218:8,15; 220:24; 223:14,
14,14; 227:2; 231:19;
233:19; 235:8; 236:7,9
canary 211:16
cancel 105:24
cancer 5:23; 26:15; 44:7;
64:25; 71:12; 95:6; 111:2;
151:2; 157:12; 204:18;
207:18; 231:14
cancer-causing 151:3
candidate  134:3
cap 29:13; 30:4; 48:18;
153:22
capability 81:24
capacity 79:10
capped 87:11; 98:5;
160:13; 171:18; 205:18;
208:24; 222:8; 234:2
capture  192:2
car 47:19; 86:16; 96:17,
21; 107:20; 148:25; 149:6;
151:12,20; 152:7,23;
153:3; 155:5; 158:5;
159:10,14; 170:18,22;
205:4; 208:8,12; 214:3,6;
221:25; 232:5, 21
CARS 113:11; 124:23;
199:16; 200:19
carcinogen 44:3,4;
71:15,17
carcinogenic 88:24
carcinogens 26:9,10;
237:13
card 187:22
cardiopulmonary 43:20
cards  156:6; 236:15
care 223:13
careful 53:12
carefully 118:20; 178:16
 baby - carefully  (4)
                            Min-U-Script®
                                    Vincent Varallo Associates, Inc.

-------
Environmental Protection Agency Hearing
                                                         Hearing
                                                                             November 2,1999
Carmen 104:20; 109:1,3;
110:1; 111:1
carries 103:6
carry 30:17; 100:21;
103:10
carrying 99; 13
cars 6:11; 35:10; 36:21;
42:24; 61:2; 80:11; 89:15;
95:22; 96:16; 107:15;
108:4,7; 121:24; 122:10;
148:21; 151:2; 152:22;
153:18; 155:8; 159:9;
170:17; 204:25; 205:16;
208:7; 212:3; 225:22;
232:20; 239:2
Carter 112:13; 124:14,
15,17; 146:11,13,16
case 52:6; 172:24;
186:12
cases 35:13; 41:2; 55:18;
162:5,7; 176:19
Castle 169:4; 198:24
catalyst 100:9; 121:22;
138:17,19; 139:9
catalysts 86:23; 97:5;
119:17; 136:20,23; 138:9,
14; 153:5;  159:2; 233:7
catalytic 226:11
catch 88:18; 167:18
category 5:7; 8:12;
18:13; 79:7; 99:5; 124:4;
126:17
caught 48:22; 124:19;
205:21
cause 25:23; 150:25;
164:9; 183:2; 222:13
caused 80:7; 155:4;
212:2
causes 4:23; 5:23,24;
25:18; 94:18; 109:9;
150:18; 156:22,24; 157:6;
163:13; 170:3; 207:4;
211:7; 230:20; 231:4
causing 62:9; 93:16;
150:24
Center 203:8; 210:11;
224:12
centers 94:2
cents 197:10
century 34:24; 151:14;
226:13
certain 20:9; 45:16; 51:3;
 52:20; 173:24; 174:3;
 177:17; 201:14
certainly 38:13; 50:20;
 52:5; 53:25; 121:14;
 146:16,18,19; 217:11
 certainty 16:9,22,24;
 17:8; 113:21, 23; 114:2;
 199:22
 certification 50:3; 73:16;
 123:9,11,13,17;  130:13,
 17; 178:3; 185:7; 186:21;
 189:2; 197:3
 certified 132:9; 187:22
 certify 183:3
cetera 56:20; 144:16;
183:8
CFR 132:20
chain 211:11
chair 88:3
challenge 116:8; 123:14;
124:11; 146:7
challenges 5:15; 80:13;
121:15; 122:17,18; 139:7
chance 85:6; 194:8
change 82:7; 116:13;
168:10; 180:20; 203:10;
211:14; 213:20
changed 136:24
changes 17:2,5; 18:17,
17; 21:19, 20; 45:6,13;
78:3; 86:9; 96:11; 111:16;
158:18; 170:13; 173:9,12;
183:18; 197:5; 208:2;
211:6,17,22; 213:12,14;
222:16; 223:13; 232:16
characteristics 29:19;
81:5
characterizes 20:7
Charbonneau 112:13,
16,25; 141:12,16; 142:3,
22; 143:13, 21; 144:20;
145:5,9,25
charge 12:13; 186:17;
219:23
Charmling 13:15
chart 127:6
charts 126:15; 187:15
chassis 81:22; 139:17
cheating 95:16; 98:16;
157:22; 205:21; 231:23;
234:10
checked 39:12; 155:7
chemical 24:6; 161:5
chemicals 26:7
Chesapeake 43:23
chest 91:19; 213:3
Chet 12:12; 60:3;  141:10;
142:4, 22; 145:15; 194:18;
220:2
Chefs 219:15
Chicago 181:3
chide 37:14
child 38:2,2,4; 90:11,16,
 19,20; 209:20; 212:15;
 213:6; 228:11
children 35:20,23,25;
 36:2; 38:15,16; 41:3;
69:18; 88:8,16,22,25;
89:3,4,6,7,11; 90:18;
 92:11; 148:10; 149:15;
 150:15; 163:15,21;
 164:16; 169:23; 170:4,5;
 212:20; 214:21; 228:8,14;
 229:11,14
 children's 88:16; 147:25
 choice 80:19; 105:6
 choices 68:8
 choke 210:11; 224:10
 choose 43:3
choosing 86:12; 201:7;
238:13
chose 201:15
chosen 31:21; 175:16
Christmas 19:6
Christopher 37:22;
38:23:58:10
Christopher's 38:11
chronic 25:25; 70:23;
149:16; 151:6; 161:12;
163:16,17,25; 164:8,10
Chuck's 58:9
circulates 90:8
circumstance 185:6
circumstances 101:20;
215:13; 216:3
circumvent 84:11
cities 6:2; 48:9; 85:7;
90:14,18,23; 150:22;
155:5; 168:15; 221:8;
224:7; 225:9,15,18;
226:4, 24
citing 216:8
Citizen 34:1; 35:1; 36:1;
37:1; 38:1; 39:1; 40:1;
60:1; 61:1; 62:1; 63:1;
64:1; 65:1; 66:1; 85:1,5;
86:1; 91:1; 92:1; 104:1;
105:1; 106:1; 107:1,23;
108:1; 109:1; 110:1;
111:1; 147:1; 221:1,3;
222:1; 223:1, 22; 224:1,2;
234:1; 235:1; 238:1,21,
25; 239:1,18; 240:1
citizens  106:21; 150:2;
156:14; 163:25; 164:5;
167:6; 224:6,18
city 34:23; 35:5; 44:17;
65:5,6; 69:2; 104:22;
105:2,12,18; 106:17,21,
22; 109:16; 169:8; 210:11;
224:13; 225:10; 234:25;
235:6
civil 132:13
clarification 54:21; 84:2;
191:24
clarify 50:18; 99:17;
194:20
clarifying 174:14
clarity 173:17; 174:15;
176:21; 193:14
class 84:2; 92:20; 99:18;
100:2; 101:21; 102:23;
106:14; 122:16
classified 5:5
Clean 12:22; 16:15;
20:14; 22:3; 27:14; 34:19,
21,25; 38:9; 42:15; 49:25;
62:13; 63:7; 74:21; 76:20;
77:16,25; 85:25; 86:14,
16; 87:7,14,15; 89:24;
94:23:96:17,19,21; 98:8,
17,18;111:7,22,23;
112:24; 117:15; 125:18;
143:17; 149:25; 151:15,
23; 152:12,23,25; 153:3,
15,20; 154:14,24; 155:11,
11; 156:10; 159:14; 160:4,
16; 170:11,18,20,22;
171:13,21,23,23:180:19;
183:14; 188:2; 200:24;
203:13,17; 204:14; 205:4;
206:3,4,23:207:20,24;
208:8,10,12; 209:3;
219:11; 221:24; 222:6,10;
224:22; 225:9,15,18;
226:3, 23; 229:21, 24;
230:2; 231:8; 232:21,23,
25; 233:18; 234:5,12,12;
235:6
clean-air 93:9
cleaned 97:19; 206:25;
208:21; 209:10
cleaner 4:17; 7:22;'8:2;
9:9,11; 10:16; 43:4; 49:22;
57:23,23,23; 73:9; 76:11;
83:4,5,20; 89:15; 90:3;
92:4,5; 143:17; 166:16;
206:12; 209:10; 214:10;
238:14
cleanest 54:9,11
cleaning 36:20; 45:2;
62:24; 63:3,21,22; 89:19;
151:24; 187:12; 209:8;
226:11; 229:23
cleanup 67:7,12
clear 16:20; 43:13; 45:19;
77:16; 101:17; 126:25;
127:15; 144:2,3,11;
175:20; 176:7; 177:3,9,
20; 178:15; 187:10;
189:17; 201:2; 206:1,20,
21; 207:1; 208:1; 221:9
Clearly 66:19; 67:19;
70:3; 103:13; 167:11;
175:8
climate 168:10; 203:10
climbers 110:5
climbing 164:13
cling 238:12
Clinton 27:11
close 6:16; 14:22; 18:25;
24:22; 39:16; 42:7,13;
89:13; 95:20; 147:17;
152:5; 158:3; 202:21;
204:23; 209:21; 232:3
closely 31:3; 127:23;
129:10; 177:13; 199:15
closer 210:25
closes 46:9
closing 36:19; 47:13,22;
96:14; 111:18; 123:23;
159:7; 170:16; 208:5;
221:23; 225:3; 229:20;
232:19
clouds 237:22
Club 66:3; 87:1; 88:1,5;
89:1,12; 90:1,8
clubs 209:19
CNG 112:22
Co 87:1; 88:1; 89:1; 90:1
coach 37:20
coal 206:22
coalescence 137:22
coalition 147:22; 148:3;
226:4
Coast 44:13; 85:8; 126:9
code 90:17
codification 46:3
codify 11:7
cold 124:19
cold/hot 175:7
collaborated 199:15
collective 213:19
Collectively 178:5;
179:25; 204:13
college 238:24
combat 161:21
combination 17:24;
212:23
combinations 159:19
combine 121:21
combined 35:21; 46:24;
127:8; 135:15; 178:23
combines 120:10
comfortable 191:7
coming 4:5; 7:10; 24:14;
41:10; 48:3; 56:24; 62:15;
106:6; 197:25; 220:7;
235:25;240:8
commend 23:9; 28:13;
120:21; 123:23
commended 139:19
commends 161:23
comment 19:2,5,18;
21:23; 22:13; 39:21;
41:23; 42:8; 46:9;  56:23;
77:18; 79:14,17; 84:12;
92:25; 115:25; 116:7;
130:8; 133:22; 176:23;
177:13; 179:6; 185:15;
186:24; 189:13; 202:22;
206:14; 219:21; 237:5
commentors 22:6
comments 7:24; 12:2;
13:5,20; 19:19; 22:10;
23:14,18; 33:13; 41:11;
42:2,7; 46:8; 51:8; 52:5;
76:22; 77:6; 102:8;
104:19; 112:17; 117:14,
21; 119:9; 120:6; 121:12;
123:21,22; 124:22; 125:3,
7,9; 128:8; 133:4; 135:21,
22; 138:4; 142:8; 143:23;
144:22; 161:2; 162:18,20;
165:4; 172:18,23; 176:9;
177:5; 179:5; 186:4;
193:7; 202:2,6,21;
206:14; 217:6,23; 219:5,
8; 220:21
commerce 77:5
commercial 8:13; 81:13;
103:13
commiserate 30:23
commit 32:11; 113:24;
121:9; 151:23
commitment 16:13;
76:14; 115:17; 181:9,16;
199:8,19
commitments 113:11
 Vincent Varallo Associates, Inc.
                             Min-U-Script®
                                        (5)  Carmen - commitments

-------
November 2, 1999
                                                        Hearing
                                              Environmental Protection Agency Hearing
committed 10:9; 20:19;
46:6; 76:11; 114:15,17;
210:24
committee 181:11;
195:21; 196:5
committees 196:13
common 81:9; 106:24;
148:11; 177:7
commonly 126:7
Commonwealth 165:3
Commonwealth's
163:24
communities 168:14;
169:6
community 37:20; 39:6,
9; 135:4; 147:21; 148:4;
199:8; 204:20; 221:8
commuters 210:7
compact 214:3
companies 46:5,12;
49:24; 50:7,8,12,22;
51:9,16,21; 52:14; 53:2;
54:20; 55:4,6; 64:17;
76:10; 142:21; 143:9,15;
144:23:145:20,21;
179:24; 180:2; 190:3;
191:5; 197:9; 200:14;
205:21; 219:4,18; 225:20;
239:15,16
company 176:10;
190:18,23; 191:4; 198:1,
8; 199:1,5; 200:1; 201:1
company's 217:21
compared 58:17; 125:11
comparison 67:4; 127:7
compel 224:6
competing 188:19
competitive 238:10
competitors 218:19
complaining 39:21
complaints 31:15;
237:24
complete 22:11; 23:15;
52:18,22; 77:5,21; 116:4;
 178:14
completed 200:8
completely 191:9
completing 53:4; 118:24
 completion 140:23
 complex 18:17; 83:2;
 114:20; 116:3; 173:7;
 201:14; 218:16,23
 complexity 201:3;
 219:24
 Compliance 12:9; 18:11;
 27:23; 28:25; 31:8; 32:6,
 13; 45:17; 46:18; 60:7;
 81:16; 89:17; 95:25;
 115:11; 129:23; 140:6,12;
 158:11; 176:4; 232:7
 complicated 185:10;
 196:23
 complicating 173:14
 compliment 209:20
 comply 96:7; 111:13;
128:23; 141:14; 143:9;
152:15; 158:16; 159:12;
162:13; 232:13
complying 142:21;
217:21
components 10:3;
11:16; 44:21; 212:8
compounded 81:21
compounds 24:6,9;
43:16; 198:23
comprehensive 23:11;
27:19; 29:8; 34:9; 60:6;
79:21
comprehensively 27:17
compressed 77:4;
225:23; 227:4
comprised 227:25
comprises 24:4
compromised 213:10;
237:10
compromises 115:12
compute 174:21
computed 175:14
computing 175:9
concentrations 210:17
concept 123:10; 141:25;
145:18; 182:10; 195:23
conceptual 55:25
concern 5:22,25; 31:20;
76:23; 134:16; 137:18;
168:16; 183:2,13; 186:15;
223:25
concerned 30:20; 31:12;
33:17; 37:11; 47:20; 85:5;
86:4; 96:2; 111:9; 152:10,
14; 158:12; 182:15, 22;
183:5,8; 184:3; 185:17;
202:15; 223:23; 232:9;
237:17; 238:21, 25; 239:4
concerning 14:3; 21:25;
161:3
concerns 43:13; 51:14;
53:18; 54:5,23; 57:13;
71:7; 85:12,14; 93:12;
101:13; 109:5; 150:5;
155:16; 165:5; 168:19;
173:18; 175:15; 183:16;
191:22; 193:17; 224:4;
227:21; 230:15
concise 77:17
conclude 32:17; 40:23;
186:19; 218:5
concluded 25:17; 240:10
concludes 15:8; 179:7;
240:7
Concluding 239:24
conclusion 34:5; 44:10;
83:22; 167:2; 178:13;
188:21; 218:11
concomitant 165:22
concur 121:16; 138:6
concurs 119:10
condition 36:5; 213:8
conditions 11:10; 18:3,
7; 50:2,17; 115:12;
123:18; 130:19; 164:10;
175:25
conduct 19:13; 200:3,4;
201:12
conducted 13:7; 176:8;
200:21
conducting 12:21; 18:19
conference 64:6;
127:13,15; 181:3
confirming 114:7
confront 149:16
confrontation 45:16
Congress 77:24
Congressional 18:14
conjunction 144:7
connected 204:17
connection 117:19
consent 11:4,8; 20:9,10,
16; 31:15; 32:15; 45:16,
19,23; 46:5,6,13; 47:4;
49:21; 50:13, 21, 22, 25;
51:9,12,17,20,21; 52:2,
7,10,12,23,25:53:3,7,
11,11,13:55:7:59:6,7,
20; 129:13, 24; 130:24;
131:2; 142:21; 143:8;
185:14; 186:22; 189:2, 5;
192:2,8,15;215:12,13,
14; 216:19; 217:12;
218:20;219:25
consequences 237:12
Consequently 119:24;
122:7
conserve 210:23
consider 33:7; 48:8;
49:4; 80:22; 82:10; 86:9;
96:11; 111:16; 143:20;
145:7; 152:17; 155:19;
170:13; 174:19; 181:24
considerable 122:4
considerably 49:11;
178:2; 227:2
consideration 18:10;
53:24; 119:4; 120:22;
128:20; 131:6; 224:5
considerations 80:12
considered 130:7;
131:25; 133:16
considering 73:3; 82:15;
146:11; 207:8; 232:15
considers 198:11
consistent 79:13; 143:4;
186:2; 192:16
constant 182:3
constantly 27:3; 64:12
constitute 178:5
constitutes 118:19;
163:12; 221:11
constrained 132:22
constraint 201:7
constraints 22:12; 42:3;
201:14
construction 30:12;
154:7
constructive 176:9;
178:14
constructively 176:24
consultant 66:7
consultation 39:16
consulting 230:23
consumer 68:7; 81:2;
156:13
consumers 40:13;
225:20
contact 223:5,8
contain 95:4; 110:24;
231:12
contains 24:5; 26:7;
157:10; 173:6,15; 207:18
contaminants 26:9;
147:25
contaminate 26:14; 44:2
contemplated 18:20;
186:18,19
contemporary 168:5;
203:6
content 7:4
context 55:2; 79:19;
191:21; 194:12
contingent 227:11
continue 24:23; 46:14;
53:2; 58:8,10; 71:5;
106:17; 131:13; 133:15;
149:15; 150:23; 166:13;
214:23; 224:21; 226:12
continued 27:23; 82:20
continues 80:9; 161:25;
162:25
continuing 32:25;
117:12; 123:24; 179:3;
237:10,24
contract 198:14; 215:11;
219:16,17
contracts 219:19
contradictions 77:12
contrary 115:24
contribute 8:22,24;
25:24; 43:21; 70:8; 71:8;
72:3; 75:6; 97:9; 126:23;
159:5; 171:4; 182:8;
226:12; 233:10
contributed 129:8
contributes 70:2,10;
169:20
contributing 25:11;
93:20; 149:2
contribution 24:17;
25:12; 26:20; 30:24;
187:16
contributor 70:10
contributors 134:17;
148:20; 169:12
control 7:5; 9:19; 11:17;
22:24; 29:8; 30:11,13;
31:18; 40:19; 45:12;
57:12; 72:7; 73:18,21;
78:18; 83:17; 97:2,19,24;
98:12; 100:3; 103:19, 20;
108:11; 118:12; 119:16,
19; 121:8; 123:5,15;
126:3; 128:24; 129:21;
130:10,17; 138:10;
139:11; 160:5,9; 166:8;
171:14; 189:22; 197:16;
205:16; 208:22; 214:5,8;
216:4; 233:4,19,23; 234:7
controlling 23:6,12;
83:19; 189:11
controls 6:10,18; 26:23;
27:21; 45:10; 117:17;
118:7; 120:12; 135:2
controversial 59:12
convention 187:6
conventional 72:10,25;
227:3
conventional-fueled
20:25
convert 74:11
Cooper 112:14; 133:24,
25; 134:2
cooperate 108:10
coordinated 21:16;
134:3
coordinator 206:19
COPD 163:16; 164:4,24
copy 29:21
Coralie 112:14; 133:24;
134:2
corporate 103:24; 229:6,
16,18; 230:3; 239:24
Corporation 172:10;
229:7
corporations 85:15
correctly 214:6
corridor 134:23
cost 40:4; 58:15; 89:6,10;
107:21; 126:17; 148:15,
19; 165:11; 174:5; 178:2;
180:13; 181:6; 186:9,13,
20; 197:5,6,11,12;
213:16,17,18; 229:11
cost-effective 57:12;
58:19; 78:17; 118:22;
136:15; 162:6; 196:19
cost-effectively 21:14;
55:14
cost-effectiveness
17:17; 18:6; 22:8; 176:17;
178:8
costly 40:12; 148:11;
214:13
costs 40:25; 58:14;
149:12; 167:9; 229:9,12;
238:7,8
coughing 91:22
Council 41:17; 198:25
Counsel 12:16
count 95:11; 157:16;
213:21; 231:18
counties 94:5; 204:7
country 5:4,9; 6:4; 8:2,
24,25; 23:3; 27:4; 49:22;
57:8; 59:12; 61:11; 76:9;
150:3; 155:6; 156:14,19;
213:11; 227:10; 230:17;
235:3
 committed - country  (6)
                           Min-U-Script®
                                   Vincent Varallo Associates, Inc.

-------
Environmental Protection Agency Hearing
                                                         Hearing
                                                                             November 2,1999
country's 226:12
County 34:16; 38:23,25;
88:4; 89:25; 105:5; 169:4;
204:2,4,5,6
couple 51:7; 174:16;
182:9; 190:10; 210:17;
215:5
coupled 97:20; 148:22;
160:6; 171:15; 208:23;
233:20
courage 235:22
course 47:20; 55:17;
61:23; 200:9; 216:11;
217:22; 222:14; 239:12
court 5:14; 14:24; 15:4;
37:9; 68:15; 69:7,8; 70:25;
215:15; 236:6,16,20
cover 210:13
coverage 142:12
covered 8:17; 103:12;
141:20
covering 79:23
covers 103:5
crafted 118:20
create 77:10; 80:18;
239:25
created 228:22
creates 4:23
crime 228:15
crisis 93:16; 221:11,12,
22
criteria 20:11,12; 182:4
critical 19:8; 23:8; 27:13;
30:13; 34:4; 45:16; 57:7;
74:25; 120:25; 122:20;
172:2; 174:11,17; 179:5
criticism 189:24
criticizing 59:7
crowd 106:8; 223:2
crucial 209:7; 211:8
crumbling 228:4
culprits 207:10; 209:9
cultural 105:14
Cummins 198:1,8,9,11,
 18; 199:1, 5,7,14; 200:1;
201:1,10; 202:14,19;
215:21; 216:20; 217:17,
 19; 218:8,13,25
curb 110:18; 151:17;
207:13; 221:12; 231:5
curbing 153:24
cure 221:16,19; 222:14
current 67:22; 68:8; 72:8;
97:5,22; 114:8; 130:13;
 140:19; 151:12; 153:11;
 159:2; 160:7; 170:25;
 173:19; 174:8; 205:5,10;
 208:15; 233:7,21; 239:5
 current-technology
 72:21
 currently 5:5; 16:3; 30:7;
 45:11;72:16; 73:23;
 78:10; 127:25; 133:17;
 136:7,17; 148:9; 198:20;
 204:24
curtailing 67:8
curve 94:20
customer 78:19
cut 5:10; 30:9; 48:11;
86:21; 97:3; 158:23;
209:23; 221:17; 233:5
cutting 6:19; 109:12;
150:20; 157:2; 230:24
cycle 46:2,2; 128:19;
175:8
cycles 45:24; 46:25;
81:25
cyclists 224:8
          D
D-E-N-N-I-S 236:22
D.C 110:6,13
dad 91:11
damage 212:22; 214:25
damaged 213:10
Dana 65:18; 75:18,19,
22; 98:25; 99:19,25;
100:7,9, 24; 101:4,7,15,
23; 102:7, 22; 104:2
dangerous 25:8; 70:20;
210:2, 20
data 12:24; 17:16; 26:14;
115:6; 174:6; 178:20
date 28:17; 32:16; 33:22;
132:17; 133:3,6; 193:23;
200:22,22; 218:6,11
daughter 87:25; 88:9,10,
12
dawned 145:17
day 36:10,15; 37:14;
41:11, 24; 56:17; 60:24;
61:4,8,8,18,22; 64:10;
71:20; 85:19; 91:25;
92:22,23; 105:8; 212:4;
228:11; 235:20
days 13:3; 19:6; 21:23;
61:18; 85:20; 88:12; 90:3;
94:7; 105:24; 107:11;
 109:20; 110:11; 116:9;
 124:19; 126:7; 163:3,5;
 164:19,21; 169:2; 177:13;
 190:15; 201:23; 202:4
 DDC 173:18; 176:9;
 178:13; 179:6,10; 193:22
 dead 210:15,16
 deadline 218:17
 deadly 94:25; 110:21;
 157:7; 224:23; 231:10
 deal 38:2; 41:5; 52:11;
 101:18; 168:13
 dealing 216:19
 death 26:2; 35:14; 43:20;
 88:25; 93:20; 106:22;
 162:5; 163:13; 207:4;
 224:19
 deaths 5:24; 25:18; 35:8;
 97:10; 159:5; 164:13;
 165:2; 167:9,20; 171:5;
 205:12; 221:10; 224:18;
233:11
debate 48:23; 77:21;
187:7
debilitating 88:7
decade 29:12; 152:13;
154:4; 155:6; 239:23
decades 35:11; 105:13;
118:23; 140:19; 151:11,
21
December 13:5; 18:25;
116:5,10; 202:3; 216:25;
218:17
decent 182:21; 228:14
decide 101:18
decides 104:4
decision 19:14; 105:11;
152:5; 223:12
decision-makers
213:18
decisions 174:12; 176:6;
195:15; 211:8
declared 26:12
decline 126:2; 214:22
declined 182:5
Declines 211:5
declining 105:23
decrease 125:23,25;
212:17
decreased 125:21;
127:9; 229:10
decreasing 106:15;
211:19
decree 46:13; 50:13;
51:20; 52:25; 53:3,7,11;
54:19; 55:7; 59:6,7,20;
129:13,24; 130:24; 131:2;
142:21; 143:8; 182:21;
185:14; 189:2,5; 192:2,8,
16; 217:12; 218:20
decrees 11:5,8; 20:9,10,
16; 31:15; 32:15; 45:16,
19,23; 46:5,7; 47:5;
49:21; 50:21, 22; 51:2,10,
13,18,21; 52:3,8,10,12,
15,23; 53:12,14; 186:22;
215:12,13,14; 216:19;
219:25
dedicated 66:10; 147:23;
161:21; 168:4; 203:5;
225:11
deemed 13:12; 109:21;
210:10
deep 25:23; 137:18;
211:16
deeper 210:25
defeat 31:17; 59:2
defense 25:22; 41:17;
198:25
defer 32:2
deferred 162:16
defined 175:5,6
definitely 62:11; 63:13;
64:9; 85:11,24; 200:13;
216:22
definition 76:3,25; 79:4,
6; 81:6,15; 82:11; 84:2,
11,15; 102:7,10,18;
103:3,11,15; 131:11;
134:14; 176:3
degree 106:3; 161:4
Delaware 35:8,21;
147:21; 167:25; 168:12,
21,24; 169:4,12,12,19;
170:3,9; 204:5; 210:3;
237:2,3
Delaware's 169:8
Delawareans 168:16;
169:23; 170:2
delay 33:21; 82:14; 97:9;
132:25; 159:5; 165:14;
171:4; 198:12; 205:12;
215:24; 216:3; 233:10
delayed 86:6; 96:5;
111:10; 158:14; 220:2;
224:20; 232:11
delaying 152:13
delays 33:18; 36:13; 83:6
delete 192:24
deliberate 93:2
deliver 196:22
delivering 180:15
demand 180:9
demands 180:13
demonstrated 72:7,20;
112:18
demonstrates 27:9;
82:2; 126:3
Dennis 220:9; 234:19;
236:1,3,13,21; 237:1
densely 235:4
deny 206:24
Department 34:17;
49:19; 225:18
Department's 59:5
departs 117:3
depend 140:24; 161:17
dependant 29:3; 89:8
dependency 210:18
depending 81:11
deprive 116:6
describe 175:13
described 77:2; 175:18
description 125:9
design 18:2,11; 80:12;
185:2
designed 10:23; 16:8;
39:15; 79:9; 81:7; 199:19
designing 83:20; 122:14;
123:14
designs 120:11
desperate 88:19; 106:23
Despite 39:15,17;
125:23; 126:5; 151:5;
162:24; 226:10
detail 42:4; 49:11; 122:4;
194:8,14
detailed 22:11; 52:5;
77:4; 119:9; 125:8; 133:4;
135:22; 162:18; 172:23;
 174:17
 details 54:24; 55:23;
 56:10,13,18; 123:21;
 177:19; 181:15; 190:19,
 20; 195:6,15; 215:22
 determine 17:16; 176:10
 determined 176:5;
 178:22
 Detroit 172:9,10,17,19;
 179:3; 192:4; 193:15;
 21-7:18
 devastating 221:7
 develop 30:22; 127:23;
 129:11; 140:8; 202:6
.developed 113:14
 developing 20:23; 76:12;
 117:18; 128:3
 development 31:3;
 131:14; 135:7; 137:11;
 141:7; 178:3,21; 199:11;
 225:12; 227:14
 device 59:3
 devices 31:17; 84:19;
 98:16; 104:12; 205:16,22;
 214:5,8; 234:11
 devil 56:12
 devise 10:20
 diagnoses 164:24
 diagnostic 11:12,18;
 36:21; 87:16; 98:18;
 111:25; 149:10; 155:9,12;
 171:24; 185:24; 205:25;
 209:5; 222:12; 234:13
 diagnostic's 140:4
 diagnostics 31:22;
 46:21; 131:8; 139:17;
 140:13; 160:17;  166:25;
 201:17
 dialog 52:13; 117:10;
 120:22; 188:25
 diameter 26:4
 dictates 71:21
 die 69:24; 85:13; 237:6
 died 239:21
 diesel 4:17; 7:4,23; 8:11;
 9:4,10,18,19; 10:7; 11:3,
 6,9,12,22,25; 12:3; 21:5,
 7; 22:6; 23:23,25; 24:5,7,
 15,16,18; 25:11,12; 26:7,
 15; 27:22; 29:4,8,11,14,
 18,20,22; 30:2,3,3,5,8,
 9,18,22; 31:4,16; 33:19;
 36:20,22; 39:3,10,13;
 42:18; 43:5,9,13,25;
 44:11,16,23:45:7,8;
 47:2; 48:5,8; 49:7,18,22;
 54:10; 58:16; 63:21;
 66:13,18; 67:15; 69:25;
 70:5,7,14; 71:7,10,14,
 17,22; 73:7,19; 74:4,6,
 25; 75:3,5,7; 78:11,14;
 81:17,23; 82:5,11,12,15,
 21,25; 83:4,6; 84:8,17,
 18; 85:19; 87:7,8,9,10,
 18; 89:15; 90:4; 94:17;
 95:2,3,6,8,14;  97:18, 23;
 98:2,3,4,20; 100:5;
 Vincent Varallo Associates, Inc.
                             Min-U-Script®
                                               (7)  country's - diesel

-------
November 2,1999
                                                         Hearing
                                               Environmental Protection Agency Hearing
104:6,12,13; 108:14;
110:16,22,23:111:3,22;
113:7,16; 117:15; 119:3,
11,16,17; 120:5,12,23;
121:5; 122:22,23; 124:7;
127:6,7,9,10,16; 128:3,
4,6,11; 129:7,12,14;
130:4; 131:6; 133:8,15;
135:8,17,25; 136:3,9;
137:12,17,19; 139:23;
140:24; 146:11;  149:7,9;
150:23; 151:6,7,12,17,
19, 23,24; 152:9,12, 21;
153:15,19,21,21,22,24,
25; 154:2,4,5,7,15, 22,
24; 157:4,8,9,12,13,21;
160:4,7,10,11,12; 166:9,
21; 169:10; 171:13,16,17,
18,25;172:9,10,11,17,
19; 178:25; 179:3,19;
180:5,21;181:14,20;
183:18,22; 184:16; 186:9;
187:3,17;188:6,15,17,
23; 189:9; 195:7,23,24;
196:8; 197:16,19; 198:13;
204:8,12,16,17; 205:15,
 17,17,21; 206:3; 207:10,
13,16,17,20; 208:21,24;
209:6,9,24; 212:3; 214:7,
12,14; 217:18; 222:6,7;
224:25; 226:6,10; 229:23;
231:2,11,12,14,16,22;
233:18,21,24,25;234:2;
235:11,14; 237:6,8,20;
238:10
Diesel's 191:24; 192:4;.
 193:15
diesel-fuel 12:3
diesel-fueled 26:13
diesel-powered 237:17;
238:2,14
diesels 5:22; 23:20;
25:13,14; 26:3,7,20, 24;
 28:5:30:11,14; 41:21;
42:21; 43:17; 44:14,19;
45:3; 47:6; 48:4; 67:20;
 103:23; 155:14; 160:19;
 199:3; 234:15; 237:21
 difference 58:2; 89:22;
 102:12;107:15,18; 212:9;
 238:13
 different 24:5; 51:11,22;
 85:7; 168:13; 199:3;
 204:3; 213:8
 differently 53:15
 difficult 88:21; 103:18;
 173:13;218:16,20,24
 difficulty 68:6; 88:11;
 176:22
 digest 19:4; 173:4
 dilemmas 77:11
 diminishing 212:6
 dioxide 166:2
 dire 23:25; 221:11; 223:3
 direct 25:5,9; 65:3;
 137:17
 directed 189:25
 directing 147:23
direction 28:13; 70:4
directly 15:4; 179:23;
188:19; 190:24; 223:17;
228:25
director 7:14; 22:21;
34:16; 118:6; 198:7
Directors 225:9
dirt 42:21
dirtiest 63:3; 86:3,15;
96:20; 111:8; 153:2;
159:11; 170:11; 232:24
dirty 40:19; 41:21; 45:3;
48:4; 197:22; 199:2;
206:22; 207:25; 209:9;
224:10
dirty-air 209:9
disagree 71:16
disagreement 56:8
disappear 211:21
disappointed 114:19;
191:12
disappointment 28:12;
59:2; 106:20
disasters 210:21
disclose 195:4
discourage 132:7
discovered 95:15;
157:21; 231:22
discretionary 180:22
discuss 190:19; 191:14;
195:11
discussed 19:25; 20:4;
121:19; 122:4; 173:11
discusses 11:20
discussing 10:3
discussion 78:9; 122:8;
217:2,14,16,18
discussions 21:24;
59:14; 99:7; 117:12;
131:13;218:9,10,22
disease 26:2; 36:3;
38:14; 70:23, 24,24;
148:11; 149:16; 150:16;
161:13,22; 162:5; 163:17
diseases 164:2
disgusting 110:14
disingenuous 32:10
disproportionate
148:12
disproportionately
35:19
disrupted 167:10
disrupters 26:11
distillation 83:19,19
distinction 102:18,19
distress 106:3
disturbing 110:3; 157:9
diverse 8:13
Division 12:9;113:3
DMA's 193:7
docket 15:7; 92:25;
125:8; 133:5; 162:18
doctor's 106:2
documented 39:5
documents 173:5
dollar 197:9
dollars 20:22; 114:17;
167:11; 182:3; 226:17
domestic 182:2
dominating 68:9
done 10:11; 30:25; 34:6;
47:11; 52:10; 53:23; 54:5;
63:13,18,18;94:19;
110:18; 112:23; 146:4;
187:12; 207:12; 209:4;
231:5
Doshi 230:1,10,12,12;
231:1; 232:1; 233:1
doubled 89:2; 148:8
doubt 6:3; 38:11; 203:15;
206:11
doubtful 77:8
down 90:21; 129:23;
137:8; 185:19; 221:17
dozen 216:24
dozens 163:3
Dr 15:14; 34:12,15
Draft 44:8; 194:2,5,10
drafting 173:15
drafts 193:22; 194:8,9
dramatic 34:21; 41:2;
116:22
dramatically 5:10; 34:23;
•115:3; 116:13; 181:21;
182:18
draw 29:24
dress 90:17
drinking 168:9; 203:11
drive 64:11; 106:17;
210:14; 213:24
driven 74:7,14
drives 85:19
driving 11:10; 50:2,17;
 130:11,15,18
drove 187:21
due 19:22; 61:24; 77:9;
 110:2; 125:18; 164:8;
 177:6; 185:15; 217:7;
 239:22
 Duerrl56:4;172:7,8,9;
 190:9,13,16,21,23;
 191:3,21; 192:7,10, 20,
 25:193:5,9,13,18,21,
 25; 194:10,17,22
 Dump 41:21; 42:20; 48:4;
 199:2
 durability 130:21; 183:8,
 25; 184:4,15,19; 185:13,
 19; 189:7; 196:20
durable 138:9
duration 13:14
 during 15:4; 39:21;
 73:15; 80:4; 98:16;
 109:19; 156:23; 163:3;
 170:7; 177:14; 204:6;
 206:14; 234:11
 duties 161:6
duty 76:3; 131:21; 206:9
 DVTUG 236:1; 237:1,2,
16; 238:5
dynamic 52:12
          E
e)(5 174:20
earlier 9:14; 29:10; 63:10;
129:7; 130:2; 158:22;
184:5; 205:12; 220:19
earliest 84:8
early 6:24; 7:2; 29:12;
49:23;62:7;65:18,22;
66:6,7; 127:14; 131:15;
220:9
East 85:7
Eastern 59:12
easy 173:5
ecological 211:22
economic 186:5,25;
224:4
economical 16:17
economically 136:6;
137:6
economies 197:18
economy 82:17,22;
83:8; 103:22,24; 104:5;
144:16; 180:9; 183:7;
185:21; 196:20; 197:7
ecosystems 211:3
educating 168:4; 203:5
education 105:14
effect 5:2; 7:2; 9:21;
28:11; 29:12,21; 34:21;
115:3; 160:14; 177:15;
182:24; 189:5; 218:6
effected 51:16; 53:25;
78:13
effective 10:18; 27:22;
32:12; 73:23; 87:9; 97:20;
98:3; 123:3,4; 124:10;
138:10; 160:6,11; 171:14,
16; 180:13; 189:3; 205:17;
208:22; 233:19,24
effectively 31:5; 78:8;
116:17
effectiveness 58:15;
155:20
effects 63:5; 68:17;
69:15, 22; 149:20; 150:13;
161:19; 167:7; 221:7,16;
224:17
efficient 151:15; 180:13;
213:16; 228:23
efficiently 184:7
effort 14:17; 16:7; 66:21;
67:2,8,12; 71:5; 75:2;
140:23; 221:12,19
efforts 27:13; 28:16;
48:4; 66:12; 123:24;
137:23; 191:18; 197:16;
215:17; 225:19; 237:5
EGR 184:21; 185:17;
186:17
eight 81:11; 103:10;
134:6; 165:16; 188:11
eight-hour 5:13,17;
38:19, 24; 61:21; 68:13,
15,23; 69:4,10,13;
168:25; 203:23; 204:3,7
either 16:19; 104:5;
136:10; 218:7
elderly 150:15; 163:15;
164:16; 169:24; 237:9
Election 37:14; 41:11,
24; 92:21,23
electricity 225:24; 227:5
element 11:15
elements 43:20; 125:3;
130:3,6,19; 132:16;
133:5,8,12; 139:20; 217:3
elevated 134:17
eliminated 178:11;
192:22,22
eliminates 75:9
eliminating 138:15
eloquently 36:18; 45:10
else 103:20
else's 222:19,20
elsewhere 58:2
elucidated 20:2
EMA 22:9; 172:18;
191:23; 193:17
EMA's 15:23
emanating 235:12
emergencies 43:19
emergency 61:12; 89:10;
106:13; 109:8; 148:18;
150:18; 156:22; 164:21;
167:8, 20; 203:19; 230:20
Emily 156:4; 167:23,25
emission 4:19; 7:5; 8:17,
23; 11:17, 22;  16:25;
17:13,22; 18:2,9; 26:13;
27:21; 28:3,5; 31:18; 45:9;
47:19; 58:20; 66:13;
72:22, 24; 73:23; 78:17;
80:20; 82:24; 83:16;
118:12; 120:11; 121:8;
123:15; 128:24; 129:21;
131:18; 151:2; 153:5,17;
154:21; 157:22; 158:2;
162:14; 165:19; 166:2,4;
174:5, 24; 175:4; 176:5;
177:22, 23, 24, 24; 178:4,
9,19, 22; 179:20; 181:5;
187:4; 192:21; 198:18;
205:23; 219:20; 234:10;
239:2
emission-reduction
20:23; 121:3
emissions 4:15; 5:9; 6:7,
20; 9:22; 16:11; 20:18,24;
21:14; 24:11,20,25; 25:4,
5,10,15; 26:6,20; 27:4,5;
28:18,20, 22; 29:6,20;
31:14; 35:2; 39:12; 43:17;
44:12,14; 55:14; 56:4;
57:22; 58:15; 59:4,9;
62:14; 63:22; 66:15,19;
67:2,22,25:70:3,9,16;
71:22; 72:2,7; 73:4,21;
75:2,7,9:76:2,17,18;
 Diesel's - emissions  (8)
                             Min-U-Script®
                                     Vincent Varallo Associates, Inc.

-------
Environmental Protection Agency Hearing
                                                         Hearing
                                                                             November 2,1999
77:23; 79:21; 80:14;
81:24; 82:9,14,25; 83:8;
84:6; 95:16; 97:2; 98:11,
15; 108:12; 112:22;
113:15; 114:18; 115:2;
116:23, 25; 117:10,17,20;
118:7,17,22; 119:23;
120:14,19; 123:4,24;
124:3,7; 126:10,13,16,
19, 24; 127:2,3,6,17,20;
128:3; 129:10; 130:11,12,
15,18,21; 132:10; 133:13,
15,19; 134:15, 21,22;
135:3,5,9,13,15,19;
136:8, 25; 138:3,10;
139:12; 140:13,14,18;
142:10; 148:23; 149:7;
151:17; 152:11; 154:12,
12; 155:4,7; 159:21;
162:11; 165:12; 166:20;
167:4; 171:22; 174:22,23;
175:7,9,13; 180:23;
181:12, 20; 182:5; 187:16;
188:9,10; 189:15,22;
190:6; 197:16,18; 198:21,
22; 199:9,11,13, 20;
200:6,8,12; 201:5; 204:9,
11,21, 24; 205:3; 209:23;
210:19; 212:24; 214:4, 5,
17; 226:5; 227:4; 231:23;
233:4; 234:7; 237:8
emit 43:14; 89:14; 95:21;
152:6; 158:4; 204:9,13;
205:2; 232:4
emits 181:18
emitted 25:7; 126:13
emitters 190:4
emitting 184:7
emotional 40:25
emphasize 132:21
emphysema 163:18
employed 121:23; 122:6;
184:11
employing 120:9
employment 105:14
enable 7:5; 73:22; 84:18;
115:21; 119:20; 135:9
enabled 205:22
enacted 108:12; 185:9
enactment 188:11
encounter 151:7
encourage 131:12;
149:6; 170:12; 219:4;
235:21
encouraged 152:7
end 8:21; 14:8; 18:18,21;
 19:7; 22:15; 31:2; 50:11;
52:22; 88:17; 135:16;
 155:23; 185:22; 188:8;
 196:16; 200:8; 217:25;
218:5
end-user 131:18
 endangered 214:23
 endocrine 26:11
 endorse 181:4
 endorses 172:17
 endorsing 195:22
Energy 225:18
enforce 13:13; 35:10
enforcement 36:21;
95:13; 157:19; 175:17,22;
176:8; 181:12; 189:18;
231:21
enforcing 36:13; 75:11;
205:11
engine 9:4,7; 11:6;
15:22; 16:6,10; 17:22;
20:17, 21; 21:11,16;
30:22; 31:16; 32:4,8;
39:16, 22; 40:13; 42:18,
19; 46:23; 49:18; 51:12;
53:16; 54:2; 55:12,14;
56:2; 59:18; 63:14; 72:21;
74:17; 78:2; 80:12; 95:15;
98:14; 113:2; 119:11,13,
20; 120:5,10,23; 121:7,
22; 124:6,8; 134:15,25;
135:13,15; 137:13; 138:5;
139:18,21; 140:14,17,25;
143:2; 152:11;  153:20;
155:2,17; 157:21; 166:23;
178:3; 179:19;  180:15,25;
181:3; 185:3; 187:4;
188:23; 195:12; 196:11;
197:11; 198:1,8,13;
199:1, 5; 200:1; 201:1;
205:21; 231:22; 234:9
engine/fuel 133:20
engineered 214:24
engineering 80:3; 105:5;
113:2; 121:15;  122:16;
161:5
engineers 199:5
engines 10:7,15,16;
11:3,9,22; 12:9; 15:24;
16:8; 17:5; 18:2,9; 20:25;
23:6,7,16,18; 24:15;
25:2,11; 26:13; 27:18;
30:24; 31:4,10,17; 33:18,
19,20; 44:23; 46:19,25;
49:22, 25; 50:16; 53:6;
67:15; 70:14; 72:8; 75:5,6,
8; 82:21; 95:8;  100:5;
104:6,6,12,13; 111:3;
112:22; 113:8,16,19;
114:12; 117:9; 118:18;
119:5; 121:14; 123:25;
134:12,17,19:135:11,25;
136:4,9; 137:25; 138:12;
140:6,20; 142:13; 143:17;
145:2; 149:8; 151:20,23;
153:16; 154:11,13,25;
155:4; 157:13; 172:11,14;
173:9; 175:16; 181:17,18;
183:3,4,23; 184:4,6,17;
185:25; 186:10,14;
187:19; 188:10,13; 197:6;
198:9; 199:21; 205:22;
207:20; 214:18; 231:16;
237:6,8
England 106:11
enjoy 85:21; 110:7
enjoyable 105:22
enjoys 125:10
enormous 30:23; 83:15;
 109:18; 113:25; 156:20;
168:22; 209:21; 212:4;
230:18
enough 29:5; 49:2;
103:3; 154:22; 155:21;
165:17; 191:14; 207:12;
219:2
ensure 18:11; 19:10;
27:23; 29:5; 31:10; 32:13;
42:21; 43:7; 45:17; 46:17;
59:23; 73:14; 78:18;
83:16; 87:8,13,15; 89:16;
95:25; 96:6; 98:2,7,17;
111:12,23; 130:21;
140:13; 152:15; 154:23;
155:7,11; 158:11,15;
160:10,15; 166:20;
171:15,20,22; 177:10;
205:16; 206:3; 209:2;
222:9; 232:7,13; 233:24;
234:4,12
ensures 116:25
ensuring  142:12; 177:8;
229:24
enter 151:14
entered 11:5; 49:20;
50:12; 92:25; 198:14;
216:6
enthusiastically 226:4
entire 60:22; 81:25;
163:8; 173:16; 190:5;
239:9
entirely 33:3; 221:22
environment 76:14;
168:17; 172:4; 174:12;
181:8; 197:22; 204:19;
211:5; 224:5
Environmental 4:4;
26:17, 22; 39:6,9; 41:18;
49:18; 66:7; 75:23; 88:5;
117:4; 147:25; 150:2;
156:13; 161:7; 168:2,3,5,
7,8; 170:10; 179:16;
182:20; 195:20; 198:8;
203:3,4,6,8,9; 210:20;
211:8,9,14,17; 214:24;
239:16
environmentalist 37:19;
239:13
envision 27:19
EPA 5:12,16; 6:23; 7:15;
8:17; 9:6; 10:8; 12:23;
14:7; 16:5,14,19,25;
17:12,15,21; 18:5,8,12,
16,17,22; 19:5,18; 20:7,
13,21; 21:3, 5,13,18,22,
24; 22:4; 23:9; 25:9; 26:8;
27:7,10,16; 28:2,7;
29:13,17;  30:21; 31:2;
32:4,11; 33:7; 37:12; 38:9;
39:8,10,13,15,18; 41:6;
42:10; 43:6; 45:6; 46:16;
47:7,10,15,22; 49:2,3;
50:7,10,23; 53:17; 59:22;
62:12; 66:23; 67:13, 21;
69:5; 71:5,21,23; 72:11,
17; 73:3,3,6,12,17; 74:2,
19; 75:4; 76:17; 77:2,18;
78:23; 79:3,5,17,24;
80:19, 22; 82:7,18; 83:18;
84:22; 85:11,25; 86:9;
87:3; 89:18; 90:4; 91:9;
95:19; 96:10; 97:14;
108:2,13,21; 111:6,15;
113:11; 114:3,9; 115:4,
10,24; 116:8,24; 117:7,
12; 118:25; 119:13; 120:6,
21,25; 121:19; 123:10,23;
124:5,8; 125:4; 127:23;
129:11; 131:12; 132:14,
25; 133:18; 137:7,14;
138:3,6; 139:19; 140:8;
149:6; 151:2,23; 152:2,
17; 153:21; 154:13,18;
159:13,15,22; 160:4,15;
161:3,23; 162:12; 165:25;
166:19; 170:10,12; 173:3;
174:6; 175:21,24; 177:7,
12,20; 181:2; 186:10;
188:12; 189:15,24;
198:15; 199:15,25;
200:19; 201:2,4,9,10,11,
15; 202:4,7,15; 203:13;
204:8,16,22; 207:23,25;
208:4; 209:2,20; 210:2;
213:16; 214:16; 215:11;
216:19,22; 218:3; 219:17;
221:17; 222:3; 223:10;
226:6,24; 227:11; 228:21;
229:5,17; 230:3; 232:2,
15; 233:15; 235:21; 237:4
ERA'S 6:9; 8:5; 19:13,14;
20:15; 22:8,9; 23:5; 24:12;
28:16; 32:19; 39:7; 44:8,
25; 48:4; 66:12; 67:11;
68:15; 69:9; 71:2; 75:25;
76:15; 89:13; 113:9;
114:20, 24; 115:14,17,22;
116:3,12; 117:2; 118:9,
14; 119:8,10,24; 121:14,
16; 122:3,25; 134:11;
135:12; 138:23; 139:15;
140:17; 150:10; 151:10;
152:5,7,14; 154:6; 158:6;
165:11; 172:19; 201:19,
21, 25; 204:11,20; 205:5,
10; 226:5
epidemic 41:5
equalizing 67:12
equally 45:4,151:23
equation  174:19,21,25;
175:3
equipment 30:12,13,17;
87:8,16; 98:3,12,19;
111:25; 137:19; 149:10;
154:7; 155:9,12; 160:11,
18; 171:16,24; 205:17;
206:2; 209:5; 222:12;
233:24; 234:7,13
equipped 31:17; 155:9
equitable 67:9
equity 188:2
eradicate 221:21
Erdei 220:14
Ernst 220:16; 227:1,17,
18,19; 228:1; 229:1
erode 17:8
errors 173:15
escape 228:17
escaping 228:15
especially 24:2; 25:21;
32:21; 57:8; 58:20; 62:15,
22,25; 64:10; 68:3; 91:14;
129:24; 144:4; 156:17;
157:9; 212:3,19; 228:7
essence 64:22; 192:2;
229:13
essential 31:9
essentially 8:25; 17:23
establish 115:18; 117:9;
120:25
established 18:5;
183:15; 225:16
establishing 200:6
establishment 139:16;
140:24
estimated 38:25; 93:21;
94:13; 148:14; 165:11
estimates 44:15; 67:21;
68:5; 154:6; 164:5
estimating 68:6
et 56:20; 144:16; 183:8
ethanol 225:23; 227:5
EURO 45:25; 116:24;
142:9,9
Europe 135:6
evade 25:22
evaluate 173:13
even 5:20; 6:25; 17:19;
20:19; 26:2; 30:9; 38:4;
41:23; 55:23; 58:3; 59:24;
62:18,21; 63:10; 64:2;
65:10; 67:13; 69:23,24;
72:10; 79:4; 85:20;
108:21; 109:11; 122:14;
150:19; 156:25; 163:7,13;
164:12; 167:8; 175:10;
202:16; 208:2; 212:17;
214:7; 221:21; 227:3;
230:23; 237:12; 238:3
event 20:15; 49:3
events 219:25
everybody 4:13
everybody's 14:8
everyone 57:19; 161:9;
207:2
evidence 13:8; 45:11;
201:19,25
evident 129:24
exacerbated 36:4; 201:6
exact 217:13
exactly 145:10
examined 58:14,16
examining 58:18
example 81:9; 94:4;
103:7; 125:20; 126:7;
163:5; 169:2; 175:15;
178:6
examples 17:11; 174:16;
176:13,18
exceed 25:10; 50:4; 58:8;
80:20; 90:14; 143:12;
150:12; 192:24; 193:2;
204:3; 217:9
 Vincent Varallo Associates, Inc.
                             Min-U-Script®
                                                    (9) emit - exceed

-------
November 2, 1999

exceeded 38:20,24;
203:23; 204:7
exceedences 68:22;
69:2,3; 126:6; 168:24
excellent 33:25
except 105:22
exceptions 213:7
excess 130:21; 164:23
excessive 58:11
excessively 209:22
exchange 72:25
exclude 154:13
excludes 6:17
exclusively 237:20
excuse 238:13
excused 147:7
executive 22:21; 118:6;
181:10
executives 187:11;
195:20
exemplified 68:8
exercise 27:16
exhaust 23:23; 24:5,8;
26:7; 39:3; 43:9, 25; 44:2;
48:8; 58:17; 69:25; 70:7;
71:10; 83:2; 88:20, 23;
118:17; 119:15,19;
120:11; 127:17; 135:7;
150:23; 153:25; 184:11;
204:17; 224:14
exhaustive 190:20
exist 32:6; 45:12; 104:13;
139:7; 229:7
existing 17:2; 20:16;
44:22; 74:4; 75:2; 86:22;
97:4; 151:24; 153:25;
154:3; 158:25; 159:19;
173:8; 175:5; 233:7
exists 47:21; 89:21
expand 115:14; 197:15
expanded 80:18
expect 33:23; 50:24;
123:5; 129:3; 137:6;
187:13
expectations 54:6;
176:12
expected 31:11; 39:20;
59:23; 130:12; 134:25;
216:22
expecting 12:18
expedite 47:23
expeditious 162:9
expeditiously40:5
expensive 107:22
 experience 95:10;
 105:22; 231:18; 235:9,18
 experienced 69:3;
 138:18; 163:5
 experiences 163:3
 experiencing 68:20;
69:12,22
experiments 137:17
expert 137:22
experts 40:22; 71:16;
                                                           Hearing
212:19
explained 106:9
explanation 71:3
explicitly 19:9; 32:11;
78:23
exploring 187:4
exposed 38:22; 71:10,
19; 203:24
Exposure 5:23; 26:15;
68:17; 71:11; 137:17;
151:6
express 223:25
expressed  13:21; 60:11;
104:18; 106:3; 114:16;
137:20; 147:11; 191:22
expressly 114:11
Expressway 105:9
extend 77:18; 90:5;
121:25; 138:24; 177:12;
178:3; 184:14
extended 74:18; 174:9;
178:24
extending 21:23; 123:7
extensive 60:6; 99:7
extent 57:21; 123:19;
143:8; 185:10; 191:8;
192:15
external 238:7
extra 16:9; 21:23; 39:19;
159:12
extraordinarily 59:11
extreme 17:24; 63:5
extremely 27:25; 30:20;
33:17; 34:14; 79:21; 86:4;
96:2; 110:3;  111:8; 124:2;
158:12; 232:9
eye 223:5,7
eyes 224:15; 237:14
face 18:13; 64:13; 65:8;
167:15; 224:14
faced 201:14
faces 210:13
facilitate 14:25; 73:20;
99:13; 138:21; 139:11
facilities 81:22
facility 105:6; 215:22
facing 152:11
fact 5:4; 11:24; 17:18;
20:7; 29:25; 31:21; 33:6;
39:15,18; 47:10; 52:11;
68:14; 71:18; 94:13,24;
97:22; 99:8; 103:4; 104:4;
107:13; 113:17; 125:16;
142:13; 144:2; 151:9,11;
160:7; 161:10; 163:12;
165:8; 173:15,25; 174:24;
176:15; 182:13,16,22, 24;
183:10,15; 185:14;
186:18, 22; 187:6; 216:24;
233:21; 239:4,9
factor 175:3
factories 228:3
                                                Environmental Protection Agency Hearing
factors 22:7; 214:25
fail 117:3; 201:4
failed 80:22; 201:2,12;
202:8
failing 82:18; 188:5
fails 82:10; 175:12
failure 11:16; 19:13;
35:10; 201:19
failures 151:11
faintness 213:3
fair 57:17; 149:2; 182:8;
187:12; 219:2, 3
fairly 76:6; 101:17; 215:9
faith 198:13; 215:10;
219:17,24
fall 103:11; 214:24; 239:8
false 14:11,11
familiar 118:10
families 36:12; 149:5;
228:13,17
family 38:7; 42:24; 47:19;
89:25; 105:3; 110:4
far 29:5; 37:20; 53:4;
71:25; 143:12; 146:23;
216:21; 237:6
far-reaching 173:13
Farleigh 156:1,4,7,9,
10; 157:1; 158:1; 159:1
farmland 210:5
fashion 19:14
fast 49:2
father 37:21; 213:4
fault 59:16,17; 222:20
faulty 98:12; 234:7
favor 103:23; 153:21
fear 212:20; 214:25
feasibility  10:6,10;
16:17; 17:17; 18:6; 22:7;
80:21; 101:5; 114:23;
115:13; 117:6; 120:7;
121:19; 135:24; 138:4;
143:20; 174:13; 176:11,
17; 182:11; 216:13; 219:8
feasible 10:12; 40:16;
115:18; 116:22; 119:13;
129:20; 131:3; 132:17;
136:6; 137:6; 142:24;
145:11; 174:8; 178:23;
182:14
feasibly 115:7
features 114:21
Federal 8:7,8; 11:18;
41:4; 114:9; 126:8;
129:15; 175:7,18; 182:25;
185:12; 192:18; 201:22
federally 100:22
federation 179:25
feel 59:14; 119:24;
153:16; 155:18; 213:6,8
feeling 59:2; 61:6
felt 55:9; 91:19; 181:7;
196:5
few 7:19; 17:11; 23:19;
59:3; 80:25; 90:25;
121:12; 141:11; 180:20;
190:6; 208:2; 212:18;
237:22; 240:5
Fewer 211:19
field 6:14; 51:11; 167:25;
168:12; 170:9; 203:2
Fifth 11:11; 87:13
fighting 43:5
figure 103:18
filed 8:6; 215:14
filters  119:17
Final 16:21; 17:8; 19:19;
77:7; 79:5; 131:14;
132:14,18; 177:11;
182:17; 184:14; 186:7;
189:13; 200:5; 202:6,10;
214:19; 216:17; 219:20
finalization 19:16
finalize 8:20; 116:9;
202:15; 219:19
finalized 9:20; 10:8,8;
19:7; 118:21; 132:3;
215:15; 217:24
finalizes 120:3
finalizing  155:22
finally  11:20; 14:21; 22:4;
26:5; 33:11; 40:15; 47:17;
98:7; 116:2; 125:4; 152:2;
154:23; 155:21; 160:15;
164:25; 166:19; 171:20;
174:6; 177:8; 178:20;
187:3
financial 40:25; 121:10
financing 229:15
find 114:20; 124:10;
200:25; 213:5; 235:22;
239:8
finding 228:14
fine 25:8,21; 26:3; 39:2,
4; 67:18; 68:4; 70:19, 21;
71:4; 134:18; 150:22;
165:19; 176:14; 237:12
finish  10:21; 47:8; 50:10;
194:23
finished 14:2; 18:21;
59:21;91:19
firm 28:17; 32:16; 105:6;
230:23
first 6:6; 7:19; 8:18; 9:6;
10:5; 15:10; 28:3,17;
32:18;  37:12; 41:6; 44:21;
55:20;  57:6; 58:14; 67:11;
76:5; 83:12; 85:10; 91:7;
102:4;  106:12; 109:4,19;
118:15; 124:24; 128:16;
130:9;  138:8; 139:25;
155:18; 158:20; 170:15;
172:25; 173:19; 181:25;
182:10; 190:11; 195:22;
201:9;  208:4; 215:12;
216:8,25; 221:22
firsthand 88:7
fit 188:14
five 34:14; 89:14; 95:21;
148:24; 152:6,18; 158:4,
18; 166:19; 204:25;  206:5;
232:4
Five-County 35:22
fixed 214:6
fleet 74:10; 82:16;
151:22, 24; 154:3,6,10
fleets 237:19
flexibility 121:17
Florida 195:9
flourished 45:21
flying 18:13
focus 23:18; 76:22;
113:18; 148:5; 189:10;
206:21
focused 83:23
focusing 164:16
folks 186:9; 189:14,20
follow 50:14; 93:7;
141:21; 181:15
follow-up 48:11; 101:11;
143:7; 195:3; 219:14
following 72:4; 86:9;
96:11; 111:16; 149:6;
152:18; 165:7; 170:13;
222:15; 232:16
food 168:9; 211:11,24
force 195:25; 203:17
forced 213:15; 226:17
forcing 224:22
foreign 225:25; 226:22
forge 87:4; 97:15;
159:22; 233:15
form 10:22; 182:20;
220:21
formal 13:8; 125:7
formally 4:9; 201:22
formation 24:21
formed 25:6
former 193:17
forms 71:8
forth 27:3; 62:13; 76:15;
200:5
forthcoming 23:14
fortunate 106:18
forward 28:7; 40:4;
117:8,12; 119:3; 124:5,8;
133:2; 137:15; 141:4,6;
147:13; 184:9; 191:19;
197:25; 219:9; 220:7,18;
229:7; 235:25; 236:14;
240:9
forward-looking 85:25;
95:20; 232:3
foster 73:18
found 80:17; 90:15; 91:7;
95:4; 110:24; 151:2;
211:20; 212:23; 231:12
founded 161:20; 168:6;
203:7
Foundry 113:3
four 19:11; 50:7; 53:8;
78:3; 105:10; 116:17;
128:9; 163:14; 205:20
four-year 47:9; 72:14;
78:7; 101:21; 132:22
Fourth 11:2; 87:7; 93:19;
 exceeded   Fourth  (10)
                             Min-U-Script®
                                                                                        Vincent Varallo Associates, Inc.

-------
Environmental Protection Agency Hearing
                                                        Hearing
                                                                             November 2,1999
97:18; 171:13; 208:21;
235:3
frame 9:25; 10:19; 12:5;
31:25; 50:15; 52:24;
53:24; 57:15; 77:10;
119:6; 120:8,25; 131:4;
135:14,16; 136:6; 140:10;
141:5; 143:10; 145:2;
194:3; 219:10
frames 27:12; 196:5
FRANCE 54:16,18; 55:8;
56:5; 98:25; 99:22; 100:6,
8,17,25; 101:6,10,19;
141:11,21; 142:15; 143:6;
145:16; 191:21; 192:9,14,
23:193:3,6,11,15,19;
194:18; 215:5; 216:18;
217:8,15; 218:13; 219:2
Franklin 94:6
frankly 218:18
free 39:12; 108:19;
130:16; 177:11
French 12:8,12
frequent 35:24
frequently 161:25
Friday 8:7; 18:23; 201:23
friend 64:14
friends 62:17; 105:17;
106:5; 110:4; 235:11
frightening 237:13
front 15:17; 65:21; 156:6
frustration 58:25; 137:18
fuel 4:17; 7:4; 9:19; 11:24,
25; 21:7,10,20; 22:6;
23:20; 27:22; 29:4,4,8,
11,14,18,20,22;30:2,3,
3,5,6,8,18,22;36:20,22;
40:6,17,18; 45:7,13;
54:2,11; 55:20; 63:21;
66:18; 72:11, 25; 73:19;
74:25; 75:5,8; 76:25; 82:5,
7,12,15,16,20, 22; 83:4,
5,7,8,15; 87:7,9; 90:4;
97:19; 98:3,4,6; 103:22,
24; 104:5,8; 108:14,15;
111:22; 112:23,24;
117:13,15; 119:3; 120:12;
121:5,6,9; 122:23; 124:7,
9; 135:8,17; 137:12;
140:25; 146:12,18,20;
152:9,12,21;153:15,19,
21, 22; 154:4, 22; 160:5,
11; 162:3,11; 166:9,13,
15; 171:13,17; 174:9;
179:2; 180:13,21; 181:14;
183:7,18, 21; 185:20;
188:6,15,18; 189:9;
195:7,23; 196:19; 197:7,
12,19; 205:15,18; 207:10;
208:21,24; 214:12,14;
222:6,7; 225:13; 226:11,
25; 227:2,10,13; 228:23;
229:23; 233:18,21,25;
234:2; 239:17, 25
fuels 21:17; 23:8; 25:2;
 26:24; 27:18; 31:4; 57:23;
75:11; 83:10; 84:16;
88:21; 89:16; 95:23;
97:21,23; 149:9; 158:10;
160:7,12; 166:17; 171:15,
18; 208:23; 225:12,22;
226:7,10; 227:4,7; 232:6;
233:20
full 19:11; 80:14; 91:14;
115:22; 138:12; 167:14;
169:5; 181:5; 186:8;
188:11; 194:12; 202:11
full-size 8:14; 33:9; 66:15
fullest 36:15; 83:17
fully 72:15; 130:14;
159:10,12; 172:17; 186:7;
192:11
fumes 210:13; 224:10,15
functions 240:4
fundamental 17:4,9;
19:22; 23:19; 27:20;
28:16; 78:22; 177:5
Further 17:21; 24:16;
27:2; 29:17; 30:4,10,14;
42:7,16; 46:17; 71:3;
81:21; 82:2; 104:11;
115:12;  124:2; 135:2,16;
136:14;  167:9; 173:13;
176:3; 196:9; 199:9;
202:21;  221:21
Furthermore 78:11;
152:14;  163:23; 165:24;
174:3; 176:18; 200:19;
221:13;  226:14
future 21:13; 29:2; 30:16;
32:14; 46:15; 140:22;
183:21; 187:3,9; 188:23;
195:12; 196:15; 212:21;
214:21; 226:23
 gained 138:18
 gaining 238:2
 game 38:5; 57:20; 166:24
 garbage 65:6
 garden  105:25
 gas 90:16; 152:21;
 184:11; 225:23; 227:5
 gas-powered 108:17;
 238:9
 gaseous 174:22
 gasoline 7:7,23; 8:10;
 9:9,10,18; 10:16; 11:13,
 22; 18:9; 21:5,6; 23:17;
 27:9; 33:12,19,20; 42:19;
 43:5; 46:23; 54:10; 66:13;
 73:7; 81:17,23; 84:6;
 87:18; 98:20; 99:4; 100:6,
 7; 101:14; 104:6; 108:14;
 119:2; 122:22; 138:2, 5,7,
 12,13,24; 139:16, 24;
 140:6; 153:18; 155:14;
 157:5; 160:18; 166:21;
 171:25; 206:3; 209:6;
 214:2; 226:9; 228:22,23;
 231:2; 234:14
 gasoline-fueled 10:15;
 83:11
 gasoline-powered
94:17; 121:23
gasping 213:5
gasses 126:19; 211:16
gathering 178:21
General 12:15; 127:8;
150:14; 196:7
generally 19:20; 172:19;
185:25; 196:18
generate 25:3; 70:18
generation 70:14
generations 214:21
generous 39:18
gentle 37:13
gentleman 220:9
Geoff 220:14; 223:20
Geoffrey 223.1,22;
224:1
geometry 186:18
geopolitical 226:16
gets 54:19
giant 214:3
Gina 147:14
given 22:11; 32:25;
35:11; 42:2; 47:10; 68:6;
71:25; 78:3; 83:25; 108:5;
116:12; 129:24;  137:8;
165:8; 202:18; 239:5
gives 183:2
giving 60:19; 63:2; 89:20,
23; 93:11; 104:18; 109:4;
124:25; 168:18;  221:4;
223:16; 230:14
glad 7:18; 12:17; 22:15;
47:22
global 26:19; 168:10;
203:10
globally 25:17
GM 229:7
go-around  55:20
goal 56:14,16; 81:5;
158:9
goals 43:7; 76:20
God 223:3
goes 20:16; 90:16; 98:12;
234:8
Good 4:3,12; 15:20;
22:18,19; 34:12,13,15;
37:5,6; 41:14,15; 60:15,
16; 64:3; 66:6; 75:18,19;
84:25; 85:2; 87:22,23;
93:5,6; 107:3; 108:25;
109:2; 118:3,4,  5; 124:14,
15,16; 133:24,25; 147:15,
16,19; 149:23,24; 156:8,
9; 160:23,24; 161:23;
167:23,24; 172:7,8;
 179:13,14; 198:6; 202:24,
25; 206:16,17; 207:19;
209:15,16; 220:25; 221:2;
223:20, 21; 225:6,7;
 227:17,18; 228:15; 230:9,
 10; 234:21; 236:23
 good-faith  215:16
 government 41:4; 104:4;
 106:23
Government's 104:9
governmental 227:12
governments 225:20
GPCCP 225:1; 226:1
grab 223:4
gram 46:24; 48:19;
128:17; 144:9; 192:12
gram-per-brake 136:10
gram-per-brake-
horsepower 136:12
grams 72:22,24; 129:17;
142:14; 153:10; 154:19,
20; 158:24; 166:3, 5
grams-per-brake 48:13;
136:17   .
grams-per-brake-
horsepower 48:15; 72:9;
119:21
granted 78:7
granting 12:2; 82:2
great 14:23; 54:4,4;
151:10; 168:13; 176:19;
183:2,13; 194:25; 198:18;
220:8; 225:10; 226:15;
227:5:235:5,16
greater 5:20; 8:11; 26:23;
76:16; 173:25; 210:8;
225:9,13,15,21; 226:3,
23; 238:3
greatest 148:20
greatly 156:15; 173:7;
178:12
green 210:9
Greg 65:18
Gregory 75:22
grew 69:17; 182:2,3
gross 8:11; 79:8; 114:14;
128:12; 131:8,21; 133:10;
190:4
ground 140:21; 197:14
ground-breaking 16:7
ground-level  24:21;
43:21; 226:12,21
Group 88:4; 93:10;
156:11,13:222:25;
230:14; 237:2,3; 238:23
groups 147:21; 148:4;
150:3; 163:14;  182:20;
222:17,23
grow 106:22
growing 32:25; 41:5;
228:7
grows 69:13
growth 68:7; 227:11
guard 222:23
guess 55:21; 147:10;
182:21
guidance 134:8
guy 101:15
guys 62:12
          H
 H-A-U-P-T 238:21
habitat 210:9
habitats 210:23; 211:20,
23
hair 31:5
half 24:11,14;34:24;
44:17; 86:22; 97:4;
109:19; 148:14; 164:11;
192:12; 207:14; 209:24;
226:18
hand 222:6,7; 223:5
handful 20:5; 150:22
hang 64:14
hanging 65:6; 235:10
happen 92:16
happening 143:15
happens 139:22; 218:17,
19,23
happy 77:15; 117:22;
188:20; 194:23
hard 37:17; 43:7; 91:12;
93:7; 187:25; 228:16
Harden 220:14; 223:1,
20,21,22; 224:1
harder 166:16
hardly 20:6
hardware 82:24
harm 150:24
harmful 150:13
harmonize 10:17; 11:17;
73:6; 127:24
harmonizing 33:25; 99:9
Harris 220:15; 234:1,19,
23,23;235:1
hate 213:9
hates 213:7
Haupt234:19;236:14;
238:1,16,17,20,20;
239:1; 240:1
hazard 226:20
hazardous 24:4; 25:19;
162:2
haze 26:18
HOPE 72:12
head 110:7; 210:12
head-on 149:16
headache 185:20
health 5:18,22; 23:24;
24:2,6; 25:16,16,24;
26:6,21; 34:16; 35:16,16;
38:11,13,14;39:3,9;
40:22; 43:9; 44:6,8; 49:5;
58:8; 63:5; 66:10; 68:17;
70:7,20; 71:4; 85:12; 86:6;
89:11,23; 92:11; 93:16;
95:5; 96:5; 106:16;
109:18;111:2,11; 147:20,
25; 148:6; 149:4,20;
150:3,9,10; 151:5,16;
152:13; 156:20; 157:11;
158:14; 161:15,23; 162:2;
167:5,6,21; 168:8,22,25;
169:5,23; 172:3; 203:9,
15,17; 206:12; 207:5,15,
17; 210:20; 212:22;
213:19:221:11,13,22;
 Vincent Varallo Associates, Inc.
                             Min-U-Script®
                                                  (11) frame-health

-------
November 2,1999
                                                         Hearing
                                               Environmental Protection Agency Hearing
223:13; 226:20; 228:25;
229:12; 230:18; 231:14;
232:11; 237:8; 238:7
healthful 27:14
healthier 153:10; 209:11
healthy 42:15; 62:20;
66:21; 85:17; 207:2;
210:12; 211:2,18
hear 7:11,21; 39:20;
40:17; 43:2,3; 51:5,8;
188:25; 191:13
heard 40:8; 43:8; 63:14;
102:16; 181:23; 221:7
hearing 4:5,15; 7:17,20,
24; 8:3,6,12,18; 12:21;
13:2,7; 15:25; 18:24;
37:13; 41:23; 53:13; 56:7;
148:3; 172:13,23; 182:22;
191:13,16; 195:5; 217:6;
240:8,10
hearings 112:19; 212:25
heart 26:2; 36:3,5; 70:23;
150:15
heartened 214:16
heavier 33:2; 81:19,23;
83:24; 139:11
heaviest 47:21
heavily 199:10
heavy 42:23; 73:24;
80:10; 88:20; 131:20;
 137:19; 139:2,5; 206:9
heavy-duties 63:12
 heavy-duty 4:16; 5:7,21;
6:8, 20,25; 7:6,'22; 8:10,
 22; 9:4,10,17; 10:7,16,
 22; 11:3,6,13,21; 15:24;
 17:4; 18:9,13; 20:17; 23:6,
7,16,17,19; 24:18; 25:2,
 14; 26:20,24; 27:17; 28:5,
 19; 30:16; 31:10,16;
 33:18; 40:5; 44:23; 46:19,
 21; 50:8; 62:8,13; 67:15;
 72:8; 73:12, 22; 74:4,20;
 75:3,25; 76:19; 77:2,13;
 78:2,11,14,19; 79:12;
 80:5; 82:6,9; 84:7; 86:10,
 19,22,25; 87:17; 88:21;
 96:7,12,23; 97:4,7,13;
 98:19; 111:13,17,19;
 113:5,16; 114:12,12,19;
 115:7,16,19, 21; 116:18,
 23; 117:9,20; 118:18;
 119:5,11,15; 120:5,23;
 121:13; 123:25; 124:7;
 126:20,22; 127:2; 128:5,
 10,10,18; 129:2,6,7,12,
 13; 130:4,19,25;131:6,
 19; 132:4,8,10; 133:7,8,
 13,15;134:15,19,25;
 135:5,10,13,15,18,25;
 136:3,9,21,23:137:24;
 138:2,5,7,11,13,22;
 139:15,17,21;140:17,20;
 149:10; 152:19; 153:4;
 155:13,17,22; 156:17;
 157:4; 158:9,16,19,20,
 24; 159:4,16; 160:18;
 162:11; 165:19; 166:20;
 168:20; 169:10; 170:14,
19,23:171:3,7,10,25;
173:9; 180:5; 184:2;
185:24; 186:3,9; 187:16;
198:9; 199:21; 204:21;
205:7; 206:2,6; 208:9,13,
18; 209:6; 222:2; 224:24;
226:6; 229:14,19,22;
232:13,16; 233:2,6,9,13;
234:14;237:6
heavy-duty-vehicle
124:6
heavy-release 129:17
heed 90:4
heightened 31:20; 181:9
held 20:3; 21:24; 35:9;
77:21; 136:17; 139:3;
188:6; 214:4; 216:25
help 11:15; 67:20; 76:19;
83:20; 92:3; 99:17;
106:21; 122:12; 140:13;
161:11; 174:14; 181:8;
189:16; 223:3,4,4,6,7
helpful 117:22; 167:12
helping 7:25; 108:18
high 48:6; 64:25; 72:11,
25; 89:10; 95:7; 97:23;
138:10; 160:8; 166:14;
169:22; 204:10; 211:10;
214:12; 231:15; 233:22
high-grade 214:13
high-sulfur 75:10
higher 8:25; 29:14;
132:10; 169:5; 186:11,20;
188:18; 210:10
highest 61:20,22; 166:17
highlight 127:5,24;
158:18; 180:19
highly 77:8; 212:11
highway 118:17; 120:4;
123:25; 124:6; 134:19;
166:21; 179:16; 181:20;
210:15; 214:18
highways 169:17
hikers 110:5
hill 65:5
himself 27:11
Hispanic 228:8
Hispanics 148:13
historic 113:15
historical 68:6
 historically 40:10; 42:14
 history 211:5
 hold 8:6; 14:7; 18:24;
 158:6; 161:4; 187:14;
 188:5; 193:16
 holding 37:13,14; 41:23
 home 106:11; 224:10;
 228:15
 hometown 163:4
 Honda 187:21
 honestly 39:24; 107:17
 hook 33:14
 hope 34:7; 40:21; 42:25;
 48:10; 49:3; 51:14; 60:2,3,
 13; 83:18; 117:21; 137:13;
238:5
hoped 172:22
Horowitz 12:15; 102:3,6;
103:21; 104:14; 193:21;
194:4,16; 219:14
horrible 64:15
horsepower 48:14;
136:11,18; 153:11;
154:19,21; 158:25; 166:3,
5
horsepower-hour 72:23
hospital 38:3; 85:18;
89:9; 106:13; 161:18;
164:23; 167:8; 170:2,7;
213:3,5
hospitalization 69:23;
164:8; 167:20
hospitalizations 70:22;
148:15
host 19:15
hot 91:13,16; 187:7
hour 48:14,15; 72:9,24;
112:7; 128:17; 129:18;
136:11,12,18; 153:11;
154:20,21; 158:25; 166:3,
5
hours 105:8
households 227:25
Housing 227:1,20;
228:1,6; 229:1
huge 31:5; 43:14; 61:16;
62:9; 107:15,17,17;
114:4; 239:23
human 5:18,22; 26:9,10,
15; 44:4; 70:20; 121:10;
168:22; 204:18; 210:20;
212:22; 213:19; 214:24
human-induced 211:7
humans 214:25
humid 91:13
hundreds 24:5; 35:12;
36:8; 95:4; 110:24;
154:25; 157:10; 164:18;
165:2; 167:9,10; 207:18;
231:13; 240:4
hurried 77:9
husband 88:10,10
husband's 105:5
hydrocarbon 10:13;
119:23
hydrocarbons 112:22;
129:18,22
 1-95 169:17
 i.e 186:17
 idea 184:23
 identified 71:14; 80:2;
 175:4; 217:20
 identify 11:16
 identifying 57:11
 II 73:8; 132:2
 III 45:25; 116:24; 142:9,9
ill 221:16
illness 164:9; 165:23
illnesses 35:13,25;
36:12; 149:13; 207:7
illustrate 126:15
illustrated 136:10
illustrates 151:10
illustrative 17:12
imagine 59:14
immediately 21:22; 74:2;
100:16; 240:3
impact 39:4,24; 76:13;
144:5,14; 176:10,16;
186:5, 25; 189:2; 192:11;
197:7,13
impacting 22:7
impacts 23:24; 26:17;
43:9; 88:7; 173:12; 183:7; '
197:4; 213:25; 228:25
impaired 40:2
impediment 238:2
imperative 227:8
impetus 137:23
implement 50:8; 67:24;
101:13; 118:25; 141:25;
165:17; 214:17; 235:23
implementation 5:17;
28:8; 29:6; 32:12; 56:10;
57:19; 77:11; 83:6; 90:6;
123:12; 128:14,22;
132:16,23; 133:2; 162:10;
165:14; 200:18
implemented 52:16;
56:19,20; 128:18; 129:25;
131:15; 137:10; 140:9
implementing 57:15;
128:2
implements 53:19; 135:2
implications 81:18
implicitly 78:24
implying 142:19
importance 71:25;
134:24; 155:22
important 5:25; 12:10;
13:17; 19:21; 21:25;
37:21;43:6; 45:4; 67:11;
73:20; 77:20; 84:23; 93:2,
3; 118:15; 123:16; 130:20;
135:14; 139:18; 155:18;
174:12; 176:15; 179:19;
181:21; 184:17,18;
195:16; 213:18; 230:5;
234:17
importantly 197:7
importing 226:18
impose 26:23; 177:21
imposed 67:3; 74:19;
186:22; 205:25
imposing 120:7; 182:24
impossible 81:20
impression 52:18
improve 84:19; 107:21;
125:19; 151:19; 178:7;
227:13
improved 225:24	
improvement 21:16
improvements 82:5,17;
83:7; 178:25; 182:6;
188:6; 196:19
improving 34:8; 155:19;
181:21
in-testing 140:2
in-use31:8,21; 32:6,13;
45:17; 46:17,18; 47:3;
57:24; 58:22; 59:22; 60:7;
73:13; 87:15; 98:18;
111:24; 131:9; 140:5,11,
12; 149:9; 155:12; 160:17;
166:20, 24; 171:23;
189:15,18; 191:10;
205:25; 209:4; 222:11;
234:12
inability 213:4
include 7:3; 26:18; 30:4;
31:25; 34:7; 79:6; 115:15;
130:4; 131:7; 163:21;
177:22
included 16:13; 131:23;
132:4; 172:21; 200:2
includes 8:13; 15:23;
27:20; 114:21
including 11:24; 16:16;
19:6; 23:16; 25:25; 45:24;
81:23; 94:16; 114:12;
122:21; 130:20; 139:16;
157:4; 168:9; 191:23;
203:10; 217:9; 231:2
inclusion 81:19; 128:11;
133:9; 175:9
Income 227:1,20,25;
228:1; 229:1,10
incomplete 176:20
inconsistencies 173:16,
21; 194:7,9
inconsistency 177:12
inconsistent 114:21;
115:17; 132:19
inconvenience 94:11;
167:18,19; 212:12
inconveniences 167:21
incorporated 173:10
incorporating 216:21
incorrect 175:2
increase 17:6,14; 71:11;
95:17; 116:14; 125:24;
134:25; 148:21; 149:13;
157:23; 159:21; 164:15;
169:20; 181:6; 186:8,12,
13; 210:6,19; 214:20;
226:7,24;231:24
increased 43:18; 70:22;
113:21; 139:5; 148:22;
210:9,18; 229:6
increases 106:2; 179:7
increasing 103:24;
115:3; 147:23; 164:14;
226:21
increasingly 211:21
incumbent 59:22
indeed  58:19; 68:19;
106:16; 161:16; 167:5;
 healthful - indeed  (12)
                            Min-U-Script®
                                    Vincent Varallo Associates, Inc.

-------
Environmental Protection Agency Hearing
                                                         Hearing
                                                                             November 2,1999
176:25; 191:6
independent 201:8
index 83:19,20
indicated 52:4; 184:20
indict 190:5
indigenous 211:25
individual 55:12
individually 215:21
individuals 13:21;
104:17; 147:9; 148:9;
164:4; 191:23; 236:5,10
industries 39:17,19,23;
40:9,9; 42:25
industry 17:16; 20:17,
19; 21:12; 40:14,18;
81:25; 113:12,17,24;
114:5; 115:5; 117:8;
173:11; 177:7; 179:22;
180:8,12,18; 181:6,17;
182:7; 186:7; 188:7,9;
189:21; 190:2,5; 191:6,7,
11,19; 196:11; 197:8,8,
13,20; 198:14; 199:14;
200:2,20; 215:19,20;
216:5; 227:12
industry's 31:23; 215:23
industry-wide 45:21
inertia 222:18
infants 163:15
inference 216:8
infinity 175:2
influence 197:2
informally 13:8
information 16:18;
115:24; 141:19; 142:25;
143:5; 174:11,13; 178:21;
183:5; 195:14; 203:8;
211:8
informed 239:10
infrastructure 151:15;
227:13
inhaler 91:24; 92:7
inhalers 88:19; 89:9;
91:23
initial 186:14
initially 182:11
initiate 74:2
initiating 120:21
 initiative 118:14; 119:8
 initiatives 66:20; 141:4
 input 142:23; 178:14;
 182:19; 185:15
 inspection 180:23;
 189:23
 instability 226:16
 installation 138:15,16,
 19
 instance 114:24; 201:12,
 17
 Instead 18:22; 28:7;
 31:23; 214:13
 Institute 44:5
 integrate 211:9; 215:17
 integrated 120:11
integrity 80:13
intend 132:25; 202:20
intended 18:18,23;
200:20
intends 175:21; 177:21
intent 16:20; 28:9; 56:9;
176:23; 177:2; 191:25;
217:21
intention 8:6; 104:10
interact 215:18
interacted 190:24
interacting 168:13
interest 13:22; 51:10;
54:4; 60:11; 93:10;
104:18; 147:12; 156:11;
161:9,11; 177:7; 197:21;
218:3; 229:18; 238:22
interested 12:23; 19:3,
17; 37:16; 43:2; 53:17;
124:10; 142:18; 177:3;
196:3
interests 53:25; 54.6;
212:5
intergrate31:2
interim 48:18; 115:22;
153:9
International 44:6;
71:13; 113:6
interpretation 81:9;
84:14
interrelated 173:7
Interruption 92:15
interstate 136:21;
146:22; 187:23
intervening 219:25
into 4:9; 6:16; 11:5; 12:5;
25:7,8; 26:17; 46:8; 49:20;
54:24; 57:16; 64:11;
79:12; 81:19; 91:10;
92:25; 117:5; 128:13;
129:2; 133:11; 142:14;
149:17; 153:18; 160:14;
166:11; 198:15; 216:23;
217:12; 226:13
introduce 4:7; 70:13
introduced 6:15; 12:6
invade 237:13
inventory 8:23; 70:16;
 126:22; 127:3
investigate 196:2
 investigations 128:12
 investing 20:22; 199:10
 investment 113:25;
 114:4; 166:15
 investments 114:3
 invited 138:3
 invites, 120:6
 involved 180:25
 Ipri 198:3; 206:1,16,17,
 19; 207:1; 208:1
 Ireland 222:22
 irrelevant 13:12
 irreparable 214:25
 isolated 176:18; 222:13,
 14
isolating 221:19
issue 23:8; 32:9; 33:12,
15,23,24; 34:4; 47:7,9;
50:5; 56:7,22; 64:7,10;
65:12; 69:9; 80:2; 82:4;
84:23; 98:22; 101:8;
102:7; 103:18; 112:3;
124:6; 144:22; 167:21;
174:11; 179:19; 185:21;
188:12; 189:17,19;
197:11; 217:19; 218:2,16,
23; 224:3; 230:5; 234:17;
240:3
issued 5:12
issues 5:16; 19:24; 20:4,
8; 21:25; 23:19; 50:4;
56:21; 57:9; 76:23; 77:22,
24; 79:25; 116:3; 117:13;
128:14,15; 138:15; 140:8;
148:6; 168:6,9; 176:15;
179:5; 186:25; 189:3;
191:8,14,14; 194:6,6, 20;
195:16; 196:3,5,14,24;
201:3,9,16; 203:7,10;
219:5,6,^9; 235:7
issuing 23:9; 161:23
items 20:8; 128:9; 130:8;
131:7,14; 180:22
Jack 15:12
January 215:7
Japanese 108:6
Jason 220:15; 225:1,6,
8; 226:1
Jed 15:21; 33:14; 54:19
Jefferson 106:13
Jersey 60:18,20; 61:15;
64:5; 134:7; 230:13,13,
17; 232:2; 237:25; 238:12
Jina 149:23,25
job 14:25; 34:6; 62:19
Joe 15:13; 37:10,18
John 156:4; 172:7,9;
236:2
joined 105:16; 181:2
joins 204:19
joint 16:4; 199:16
Jonathan 198:3; 202:1,
24; 203:1,2; 204:1; 205:1
Jorgensen 198:1,3,5,6,
7; 199:1; 200:1; 201:1;
215:6,9:216:11,21;
217:11,22; 218:15;
219:12
Joseph 37:1; 38:1; 39:1;
40:1
judged 176:9
Judy 4:7,11; 7:13; 9:3;
 12:6
Julie 147:1,13,20; 148:1;
 198:4
July 215:16
jumps 180:2
June 181:10; 215:16
Justice 49:19; 59:5
justify 16:12
          K
Kassel 15:13; 41:14,15,
16
Kathleen 104:1,19,21;
105:1; 106:1; 220:14
Katz 4:7,12; 12:7
keep 13:18,19; 139:4;
216:7
kept 13:3
Kerdei 104:1,19,21,22;
105:1; 106:1
Kevin 8:4; 156:5; 161:4
key 10:2; 76:23; 77:24;
82:4; 113:20; 127:25
kick 47:24
kids 91:11,21; 92:3,8,
10; 94:12; 105:10; 213:9;
235:19
kills 211:24
kind 5:23; 23:22; 61:14;
183:5;  187:8; 213:24
kinds  55:16,19; 218:9,
22
Kitty 104:19:107:1,4;
108:1
knowing 181:5; 186:8;
188:17
knowledge 115:20
known 26:9; 34:24; 50:3;
121:7; 128:19; 237:11
knows 21:3; 57:19;
237:13
 lab 98:10; 171:21; 234:5
 labeled 204:16
 lack 173:20; 174:11,15;
 176:21
 lacking 82:6
 lacks 173:16
 lag 67:16
 laid 77:24; 141:5
 Lake 68:25
 lakes 211:22
 Lancaster 163:5
 landmark 157:20
 landscape 182:17,19
 Lane 105:4
 Langan 236:2
 language 32:2; 52:4;
 215:10
 laps 91:17
 large 4:16; 8:13,14;
 32:21; 43:24; 66:13; 70:9,
 10,18; 80:24; 81:10; 91:9;
 99:12; 150:14; 155:10;
 156:17; 169:11,16;
 189:14; 207:13,16; 209:9;
 212:5;222:17,23,25;
 227:24; 228:10
 largely 154:3
 larger 139:10; 170:20;
 208:10
 largest 6:14,17,21; 8:15;
 11:6; 49:17; 85:14; 86:2,
 15; 96:19; 111:7; 113:7;
 130:25; 148:22; 152:25;
 157:21; 158:6; 159:11;
 165:9; 169:8; 170:11;
 184:16; 232:23
 last 11:5; 19:15; 44:9;
 49:17; 74:14; 91:17;
 95:14; 102:20; 107:6;
 127:12,14; 136:25;
 157:20; 158:2; 162:25;
 173:10; 181:10; 188:10;
 195:7; 201:22; 202:13;
 209:2; 212:18; 215:15;
 231:21;239:21,23
 lasting 184:6
 lastly 51.24
 late  22:12; 41:12; 187:24;
 191:3,17;201:9,11;
 215:15
 later 6:24; 9:14,21; 12:5;
 28:20; 32:16; 45:14;
 47:25; 83:5; 87:5; 97:17;
 100:14; 108:3; 119:12;
 120:3; 133:6; 135:22,24;
 187:24; 197:23; 222:5;
 233:17
 Latinos 109:15
 law 14:12; 50:6; 57:25
 lawsuit 128:22
 lay 140:21
 layer 100:16
 lead 16:22,24; 17:9;
 19:11; 22:2; 33:14,23;
47:7,9; 48:22; 50:6; 55:3;
76:24; 77:23; 78:7,17,23;
82:3; 83:25; 84:4; 99:2,20,
 23; 101:21; 121:16;
 132:23; 173:25; 191:22;
 192:5; 193:17; 199:22;
 200:24; 215:24; 217:19,
 25; 218:10; 219:6
 lead-time 16:9; 48:25
 leadership 27:10,17
 leading 16:2,6; 118:12;
 164:10
 lean-burn 104:6
 learn 154:13; 197:4
 learned 60:5; 109:24;
 110:9:222:21,24
 least 28:15; 73:4; 86:17;
 100:4; 111:20; 150:22;
 154:19; 159:3; 165:20, 22;
 166:10; 170:24; 171:2;
 177:13;205:8
 leave 72:14; 81:8;
 167:16; 173:21
 leaves 19:3,5; 116:8;
 155:3
 leaving 106:10; 137:7;
 Vincent Varallo Associates, Inc.
                             Min-U-Script®
                                         (13)  independent - leaving

-------
November 2,1999
                                                         Hearing
                                               Environmental Protection Agency Hearing
174:24
leeway 53:8
left 4:8; 12:8; 48:2; 59:9
legal 5:16; 101:6,8,12;
219:6
legislatures 90:10
length 20:5
less 19:10; 70:18; 71:4;
76:6; 123:7; 184:7; 188:4,
4; 202:17; 227:2; 228:23
lessen 149:20
lesson 35:6; 223:19
lest 163:11
lethal 211:16; 239:5
letting 63:24; 87:19;
108:23; 112:2; 230:4
LEV 73:8; 99:9
level 6:13; 22:5; 31:13;
51:10; 61:22; 67:2,15;
82:12; 137:9; 144:5;
146:21; 169:3; 173:25;
175:4; 179:8; 180:23;
188:14; 192:12; 207:2;
228:21; 235:7
levels 20:25; 21:10; 30:8;
38:22; 48:12,12,13;
58:11; 67:22; 68:12,17,
21; 69:8; 72:11; 82:23;
83:12; 87:9; 90:15,21;
97:22; 98:4; 107:16;
 119:2; 120:14,18; 121:4;
 125:21; 126:2; 128:6;
 129:23; 133:20; 134:18;
 149:9; 154:21; 155:8;
 160:7,12; 162:2; 163:4;
 166:13; 169:6,8,21,22;
 171:17; 174:8; 188:18;
 189:3; 196:4; 199:13;
 203:25; 205:18; 208:24;
 222:7; 225:2; 233:21,25
 life 36:16; 62:21; 74:5,18;
 105:18; 106:15,16;
 158:17; 174:10; 178:24;
 184:15; 189:9; 213:10;
 224:19; 228:14
 life-threatening 36:11
 lifespans 211:11
 lifetime 74:8; 185:2;
 186:12
 lifetimes 152:16; 155:2
 light 47:18; 76:2; 80:10;
 122:10; 128:25; 144:9;
 178:18; 218:24; 221:6
 light-and 129:5
 light-duty 10:21; 32:19;
 33:2; 76:24; 79:4,23,23;
 81:15; 82:10; 84:10,14;
 99:4; 102:8,12,13;
 115:15,23; 121:24; 123:2;
 132:8; 134:13; 138:17, 20,
 22; 201:18
 lighter 165:15
 lightly 199:7
 likely 68:5; 81:14; 119:14
 121:20; 122:6
 limit 128:8; 178:10
limitation 45:25; 55:5;
99:24; 192:5
limitations 130:13
limited 22:13; 43:11;
81:25; 182:12
limiting 224:25
limitless 226:15
limits 13:13; 114:25;
115:2; 118:25; 121:3,4;
122:7; 130:20; 143:24;
144:4,14; 176:5; 177:22,
24,25; 180:21; 182:23;
192:21
line 86:12; 90:5; 96:14;
111:17; 152:20; 159:7;
170:15; 204:23; 208:5;
217:18; 221:23; 232:18
lines 114:19
lining 210:16
Iink70:21;71:10;95:5;
231:14
linked 110:25; 157:12;
207:17
links 26:14; 211:2
lion's 205:2
Lisa 147:8
list 76:7
listed 26:8; 216:16
listen 40:22; 223:9
literally 224:19
little 54:20; 74:24; 90:11;
93:7; 94:20; 110:18;
174:5; 191:11,24; 195:13;
222:20; 231:5; 238:24
live 36:15; 50:25; 51:4;
54:8; 62:20; 64:4; 85:7;
93:14; 104:22; 106:21;
109:3,16; 150:10,11;
204:2; 227:19; 228:5;
229:10; 234:24
lived 107:5
lives 38:2?; 85:5; 89:11;
90:11; 109:12; 150:20;
 157:3; 167:10; 212:6;
 230:24
 living 24:23; 60:17,20;
61:19; 109:22; 235:4
 load 138:12; 177:25;
 178:10
 loaded 146:13
 loading 100:10
 lobby 156:12
 Local 22:23; 23:8; 27:13;
 33:17; 225:20; 237:19
 localities 57:24
 located 179:17
 locomotive 188:13
 locomotives 188:14
 lodge 25:23
 log 103:15
 logical 215:17
 long 39:8; 40:24; 42:11;
 55:11; 66:25; 67:6; 86:5;
 89:24; 96:4; 111:9;
 152:12; 158:13; 162:14;
180:18; 211:11; 232:10
long-term 224:17
longer 34:23; 35:5;
184:6; 207:21; 238:12
longer-term 58:20
longevity 82:24
longstanding 43:13
look 39:24; 99:25;
102:23; 117:12; 124:8;
141:5; 187:14; 188:15;
192:18; 194:4, 5,8,13;
196:17; 197:15; 223:15;
228:2
looking 59:19; 219:11
looks 23:10
loophole 6:17; 36:19;
47:13,21,23; 63:2; 86:12;
95:21;96:14; 111:18;
152:5; 158:3; 159:8;
170:16; 204:24; 208:6;
209:21; 221:24; 223:14;
225:3; 229:8,20; 232:4,
19; 239:5
loopholes  42:13; 89:13
Lopez 104:20; 108:25;
109:1,2,3; 110:1; 111:1
Los 35:4; 90:15
lose 163:11
losing 107:9
loss 31:12; 82:22; 214:23
losses 212:11
lost 82:15; 83:7; 210:5
lot 37:15; 47:4; 58:22;
61:24,25; 62:7,16; 63:14;
103:9,16; 181:22; 197:12,
12; 216:2; 235:4
lots 196:25; 235:3
loud 187:10
love 36:12; 63:10
loves 37:23
low 20:25; 27:8; 30:2;
68:5,17; 73:4; 120:12;
122:22; 144:15; 154:21;
178:4; 192:22; 199:13;
227:1,20,25;228:1;
229:1,10
low-emission 120:24;
132:2
low-grade 214:12
low-sulfur 29:4,11;
30:18; 55:20; 74:25; 75:4,
8,11,11; 83:4,10; 97:21;
112:23; 122:22, 23; 135:8;
153:19,24; 154:2,4,22;
160:6; 166:9; 171:15;
205:15; 208:23; 233:20;
239:17
lower 29:17; 40:6; 49:6,
7; 68:11; 70:6; 71:21; 73:4,
19; 83:12; 112:22; 128:5;
133:18; 140:24; 144:13;
151:12; 153:21; 180:20,
25; 181:4; 183:11; 186:8;
196:24; 214:14
lowered 171:11; 189:5;
206:9; 208:19
lowering 182:25
lowest 180:14
luckily 85:16
luggage 81:12
lump 103:20
Lums 169:3
lunch 112:7
Luncheon 112:9
Lung 66:8,8,10,11;
70:24; 71:11;95:6;
110:25; 150:16; 157:12;
160:25; 161:9,12,22,22;
162:17; 163:25; 207:18;
231:14
lungs 25:23; 224:16;
237:14
luxury 229:3
         M
M 147:6
M.D 34:1; 35:1; 36:1
Madison 44:18
MAEL 115:9
magazine 92:7,9
main 83:23
mainly 101:6
maintain 167:12; 199:8
maintainability 184:4;
196:21
maintaining 123:4
maintains 218:11
maintenance 185:20;
186:3; 189:23
major 5:22; 15:23; 23:2;
39:3; 44:20; 74:23; 75:9;
106:20; 113:3; 125:14;
127:2; 150:8; 163:25;
172:10; 205:20; 210:14
majority 187:23
makers 42:20; 47:17;
63:3,6; 86:14; 96:19
makes 47:3; 88:21;
91:10; 213:8
making 9:24; 13:25; 38:5;
92:4,4; 95:3; 110:23;
145:19; 174:12; 195:16;
215:14; 224:9; 231:11
man-made 126:14
manage 201:20
Management 35:16;
128:5; 134:4; 198:8;
202:2,5;215:11
mandate 18:14; 73:4
mandates 38:9; 203:13
mandatory 193:12
Mandel 15:12,19,20,21;
49:15; 50:20; 53:10; 55:6,
9; 56:11; 57:3
Manhattan's 70:8
manner 113:16; 136:16
manufacture 183:3
man uf actu re-based
140:2
manufactured-based
131:9
manufacturer 17:22;
113:4,7; 172:10; 196:12
manufacturers 11:6;
15:22, 24; 16:6, 22; 17:25;
19:10; 20:5,21; 21:11;
31:16; 32:4,8; 39:17,22;
42:19,19; 45:9; 49:18;
50:24, 25; 51:4,12; 53:16;
54:2; 55:12,15; 56:3,14;
59:19; 63:15; 70:13; 72:6;
73:9; 75:24; 78:2,16;
79:16; 80:7; 82:3; 90:5;
94:19:95:7,12,15; 96:25;
98:14; 99:8; 100:4,12;
101:2,19; 102:17; 110:18;
111:3; 118:7,12; 119:14,
20; 124:9; 143:3; 151:20;
157:13,17,21; 159:20;
166:23; 180:15; 181:4;
182:23; 190:25; 196:21;
199:21; 207:12, 21; 231:5,
15,20, 22; 233:4; 234:9
manufactures 72:15;
78:9; 121:8,9; 130:25;
132:7; 151:19; 184:22
manufacturing 40:13
many 5:3; 6:4; 18:16;
27:2; 37:25; 44:5; 47:17;
48:6,9; 58:17; 59:8; 68:12;
69:21; 70:11,21; 71:9;
74:15,15; 77:12; 81:18;
85:7; 90:3,14; 94:6;
105:14; 110:5; 116:2;
161:16; 172:20; 176:19;
177:19; 179:5; 190:17,22;
191:5,5; 207:11; 237:6
March 217:5
marginal 178:18; 197:8
margins 18:11
Margo 7:14; 145:5;
215:23
Maria 65:19; 87:1,22,24;
88:1; 89:1; 90:1
market 82:22; 106:2;
166:17; 178:5; 229:4
marketed 113:5
marketplace 6:16; 54:12;
80:17; 116:19
Marks 60:14; 118:15
mask 90:16
mass 175:4,7
massive 17:2
match 47:18
material 228:19
matter 5:21; 24:8; 25:4,8,
18; 32:7; 34:20; 36:20;
42:23; 43:15; 46:16;
62:15; 67:9; 87:5; 89:22;
97:16; 99:3,16,23; 100:9,
10; 126:24; 127:7; 128:5;
129:9; 134:18; 159:22;
163:11; 166:4; 170:21;
179:20; 180:17; 208:11;
216:23; 222:5; 228:16;
 leeway - matter (14)
                             Min-U-Script®
                                    Vincent Varallo Associates, Inc.

-------
Environmental Protection Agency Hearing
                                                         Hearing
                                                                             November 2,1999
233:17
matters 5:25; 95:3;
110:23; 149:7; 231:11
maximal 192:21
maximum 58:6; 82:12;
84:18; 114:25; 117:16;
123:19; 176:5; 177:23;
178:9
May 8:18; 14:3,8,11;
17:11; 18:3; 27:11; 30:21;
32:24; 42:3; 56:23; 63:16;
70:7,12; 76:13; 80:24;
82:20; 84:15; 96:6;
111:12; 117:23; 122:16;
123:20; 137:9; 148:16;
152:15; 157:25; 158:15;
173:25; 174:16; 176:13,
15; 181:6; 183:6; 199:3;
205:12; 217:7; 232:12;
240:5
maybe 37:14; 100:17;
107:21; 145:18
McDonnell 65:19; 93:5,
6,8
mean 68:16; 71:3; 190:19
meaningful 26:25; 177:4
meaningfully 176:24
means 13:4; 71:22;
162:22
meantime 22:14
measurable 112:21
measure 71:23; 81:24;
211:13
measures 111:6; 149:14;
172:2
meat 200:24
MECA 118:8,10; 119:10;
158:22; 233:5
MECA's 119:7
mechanisms 25:23
medical 34:16; 89:5;
 105:14; 212:18; 229:9
medications 89:9
medium 113:4
 medium-duty 128:25;
 129:5
 meet 11:9; 16:10; 18:2;
 20:14; 30:15; 33:24;
 39:19; 42:23; 45:7,13;
 46:14; 50:16; 53:11; 54:8;
 57:12; 59:19, 24; 78:18;
 83:24; 86:16; 88:17; 90:2;
 91:21; 96:17,21; 115:22;
 119:14,20; 121:11; 122:6,
 13; 136:22; 143:16;
 145:22; 150:10; 152:23;
 153:2,8; 159:10,14;
 162:8; 165:10; 166:22;
 170:18,22; 173:23; 179:9;
 183:19; 184:22; 199:23;
 205:3:208:7,12; 221:24;
 229:21;232:21,25
 meeting 12:4; 46:12;
 53:2; 114:18; 120:15;
 122:20; 131:10; 155:7;
 174:9; 176:11; 191:4;
 192:8; 195:9,19; 201:24;
217:2
meetings 190:25;
196:10; 216:24
meets 53:6; 88:16
Meggy 87:21,25; 90:25;
91:1,5; 92:1,13,16; 94:9
member 38:6; 76:10;
134:6,6; 220:11
members 14:2,5,13;
41:19; 60:10; 76:7,24;
134:9; 148:3; 179:23;
180:5; 199:7; 209:17;
225:19; 238:5
membership 15:23;
187:5
memorialized 199:24
menace 92:11
mention 83:10; 139:23
mentioned 9:3; 34:9;
62:5; 136:16; 157:19;
183:20; 186:6; 193:24;
195:2,6
Mercedes 235:14
Mercer 94:6
mercy 106:24
mere 20:8
merely 31:25
message 42:17; 43:3;
143:4
met 18:7; 43:8; 62:7;
115:7; 122:18; 136:19;
137:18; 215:20, 21;
218:18; 222:16
methanol 225:23
method 123:4
metropolitan 23:2;
125:14; 169:15; 237:18
micron 26:4
microphone 14:23;
147:18
mid-1970s 151:13
mid-1995 200:2
Mid-Atlantic 206:20
mid-range 113:7
mid-season 168:23
middle 222:25
 midst 195:19
 might 16:11; 22:16;
 114:3; 189:4; 197:5; 218:4
 migratory 211:25
 Mike 12:15; 102:2;
 112:13; 124:16
 mild 125:11
 mile 184:23; 189:7
 miles 68:7; 74:6,7,8;
 125:25; 154:25; 184:16;
 213:25
 milestone 182:14
 million 24:13,14,22;
 29:14; 30:5; 38:16; 48:19;
 74:8; 87:12; 89:3; 95:18;
 98:5; 109:9; 117:16;
 148:9,15; 150:19; 153:23;
 156:23; 157:23; 160:13;
 161:12,13:163:21,22;
166:14; 170:5; 171:19;
205:19; 207:5; 208:25;
222:8; 225:2; 230:21;
231:24;234:3
millions 20:22; 42:14;
49:4; 60:25; 61:9; 71:18;
108:20; 114:17; 138:19;
150:11; 167:5,10
mind 55:24
miners 211:16
mines 211:17
minimal 193:3
minimize 76:12
minimum 32:11; 178:9
minivans 47:18; 212:3
Minottl5:l4;37:l,4,4,5,
6,10,10,19; 38:1; 39:1;
40:1; 41:9
minute  19:15; 173:10;
237:15
minutes 13:20; 34:14
mirror 7:6
miserably 89:7
misery 36:14
misimpression 51:25;
52:9
misimpressions 51:25
misinterpreting 56:6
MISS 91:5; 94:12,12
missed 164:11; 229:9
missing 58:22; 92:20;
100:17
mission 210:22
mitigate 149:4
mixture 24:4
mob 222:23
Mobile 7:15; 12:13;
24:10,13; 25:3,10; 58:16;
67:8,25; 106:19; 126:14,
16, 21; 127:20; 134:2;
198:10; 206:24; 207:8
Model 6:22; 19:11;78:8,
13; 84:7,8; 103:17;
113:10;  114:7; 115:4,6;
116:15;  117:8,11; 119:12;
129:19;  131:16; 132:15;
133:8; 134:12; 135:25;
187:24,24
model-year 78:10
models 9:12; 99:14;
100:20
modifications 76:2;
116:25; 189:9
modify 79:3,6; 84:10;
173:8
mom 87:22
moment 47:14; 67:14
money 229:8
monitor 211:4
monitored 68:23
monitoring 95:13;
 157:18; 231:21
 monitors 94:4,7; 168:24
 Montgomery 34:16;
38:23; 105:5; 204:2
month 127:14
months 7:19; 129:25;
169:21; 170:8; 181:10
moot 217:23
morbidity 71:9
mo re 5:18; 6:25; 9:15;
13:20; 20:20; 23:2,21;
24:13; 28:4,9,14,18,22,
25; 30:16,25; 31:3,5;
32:9; 35:18; 36:18; 45:4;
49:11; 54:8; 56:12; 58:4;
59:4,9,24; 60:8; 66:20,
23; 69:19,21; 70:8,19;
71:24; 74:7,15; 77:15;
83:24; 89:14; 90:23;
93:23; 94:8,11,15; 95:5,
22; 103:16; 104:11;
106:12; 107:25; 108:7,22;
109:7,9; 111:2; 119:9;
120:7; 125:8; 129:5;
133:4; 135:9,22; 137:5;
138:25; 139:2; 143:25;
148:8,8,14,15, 24; 149:2;
150:11,13,17,18,21;
152:6; 153:23; 154:10;
156:21,23; 157:3,11;
158:4; 161:11; 162:3,18;
163:25; 164:3,12; 165:17;
166:11; 172:23; 181:4,11;
182:22,23; 183:6; 184:7;
185:10; 187:13; 188:2,25,
25; 189:10; 191:12; 195:6,
13,15; 196:3,14,16,23,
25; 197:12,12,15,22;
204:13,25; 205:23; 207:4,
5,11,16; 212:5, 24;
213:18, 22; 214:4,13;
215:2,20; 216:14,15;
228:20,23; 229:8; 230:19,
21,25; 231:13; 232:5;
237:13; 238:9; 239:6
Moreover 23:24; 98:13;
114:11; 115:9; 234:8
morning 4:3,12; 15:20;
22:18,19; 23:4; 34:12,13,
15; 37:5,6; 41:14,15;
60:15,16; 64:3; 66:6;
75:18,19; 84:25; 85:2;
87:22,23; 92:20; 93:5,6;
107:3; 108:25; 109:2;
189:14; 198:24; 224:13
mortality 70:24; 71:9;
165:23; 213:6
most 9:11; 19:21; 24:7;
25:19; 28:23; 34:22;
35:15; 36:16; 37:21;
38:21; 45:22; 49:25;
70:20; 73:22; 97:24;
105:21; 110:10,15;
149:14,18; 160:8;  161:14;
180:5,6,13;  197:6;
203:23; 207:9; 213:8;
214:7, 20; 225:17;  233:22
motivator 189:16
motor 6:8; 32:23;  118:13;
124:4; 163:7; 206:12;
226:9
motor-vehicle-related
134:22
mourn 214:22
move 28:7; 44:20; 46:22;
48:18,19; 75:14; 104:5;
105:12; 106:6; 117:8;
119:3; 133:2; 137:14;
141:3; 142:14; 209:23;
212:7
moved 105:3; 106:5;
234:25
moves 5:16; 124:5
movies 106:2
moving 28:14; 40:4; 45:3;
70:4; 107:7; 118:16
MPRM 217:4
MRS 65:23; 66:2; 87:23;
92:9,21
much 5:3; 12:5; 31:13;
39:6,20, 21; 43:10; 65:16;
75:6; 81:8; 89:20; 93:11;
94:24; 98:22; 104:16;
110:20; 112:6; 124:12;
146:5; 147:5; 151:20;
156:2; 157:7; 166:15;
167:3; 172:23; 184:23;
189:10; 190:6; 194:14;
195:4,18; 196:16,23,24;
207:14; 211:15; 214:22;
220:7; 230:8; 231:9;
237:20; 238:14
multi 20:22
multi-state 134:5
multiple  16:25; 17:12;
74:9
must 18:2; 20:13,14;
21:12,13; 24:24; 27:5,5;
28:17,19,23; 29:4; 30:25;
32:7; 71:5; 77:13; 82:18;
87:4; 97:14,15; 117:19;
139:3; 149:19; 151:23;
158:21; 159:8,12,15,17,
22; 160:4,15; 166:16,19;
171:8; 177:12; 182:14;
205:24; 206:7,25; 208:14,
21; 209:2; 213:19; 214:6;
222:3; 224:20; 233:14,15
myself 40:23; 85:16,22;
199:4; 224:6; 235:8,8


         N

N 175:19,20
NAAQS68:16,23
name 7:14; 15:18,20;
22:20; 37:8,10,18; 41:15;
60:16; 64:2,4; 65:25;
75:22; 85:4; 87:23; 91:5;
93:8; 103:17; 104:21;
107:3; 109:2; 112:25;
118:6; 124:16; 133:25;
147:19; 149:24; 156:9;
161:3; 167:24; 172:8;
179:15; 198:6; 202:25;
206:18; 220:9; 221:2;
223:22; 225:7; 227:18;
230:11,12; 234:21,23;
236:19,21; 238:18,20
 Vincent Varallo Associates, Inc.
                             Min-U-Script®
                                                 (15)  matters - name

-------
November 2,1999
                                                         Hearing
                                               Environmental Protection Agency Hearing
named 100:3; 103:17
namely 36:17
names 13:24; 14:15;
65:20; 156:6; 236:15,15
Nancy 198:4; 209:15
Natasha 220:16; 227:1,
17,19; 228:1; 229:1
nation 43:24; 48:7; 66:22;
67:19; 73:11; 93:17,20;
110:11; 125:11,13; 221:9;
225:19
nation's 42:18,24; 45:3;
47:19; 66:9; 74:10; 76:20;
86:2; 111:7; 170:11;
187:11; 195:19; 209:18;
226:22
national 5:9; 22:24; 27:6;
29:18; 38:10,19; 41:17,
18; 44:5; 71:13; 110:7,10,
11,12; 125:15; 126:12;
146:21; 156:12; 162:10;
167:12; 168:2,3,6; 170:9;
179:21; 181:14; 183:21,
22; 195:23; 196:7; 198:25;
203:3,4,14; 205:14;
210:22
nationally 25:5; 29:5
nationwide 24:2,11,22;
27:15; 28:20; 38:17;
41:20; 67:21; 99:14;
109:7; 150:16; 154:9;
156:21; 164:14; 170:4;
180:3; 204:10; 230:19
natural 36:16; 168:17;
172:3; 225:23; 227:5;
238:9
nature 102:9,15
nauseating 224:16
NAVISTAR 112:17;
113:3,6,20;  114:15;
116:20; 141:14; 143:11,
19; 145:3,12,20
NAVISTAR's 117:21
NCR 145:19
NCR's 145:23
 near 24:13
 near-term 23:10
 near-zero 48:12
 nearby 62:3
 nearly 25:11; 45:20; 89:3;
 148:16; 152:13; 154:4,10;
 173:4; 202:11; 216:24
 nebulous 79:6
 necessarily 101:7;
 146:18; 174:4
 necessary 16:9; 18:11;
 30:22; 45:2,7; 54:12; 82:5,
 8; 88:13; 117:16; 121:10;
 160:3; 162:4; 165:9;
 199:22
 necessitated 32:15
 necessity 82:2; 178:17;
 224:5
 need 6:5; 11:24; 16:16;
 19:8; 46:18,20; 55:24;
 56:21; 60:5; 62:6,20; 68:3;
69:10; 72:20; 76:4; 83:10;
85:17; 88:19; 90:3; 91:23,
25; 93:12; 103:18; 104:5;
106:23; 109:5; 116:3;
127:5; 146:17; 150:5;
151:14; 152:24; 156:16;
157:14; 168:19; 173:23;
191:11; 196:6; 206:12;
223:4; 227:22; 230:15
needed 31:14; 32:9;
66:21; 67:19; 68:11;
75:14; 83:13; 126:11;
127:4; 178:4, 21; 201:3
needing 69:23
needlessly 13:12
needs 38:4; 54:8; 63:17;
72:9,16; 78:19; 82:10;
84:16; 87:2; 144:7; 213:23
negative 181:23
negligent 154:15
negotiations 189:8
neighborhood 105:4;
106:9; 228:16
neighborhoods 228:2
neighbors 105:17; 106:5
neither 17:15
NESCAUM 44:15; 134:4,
5,7,10; 135:21,21; 136:2,
9; 137:4,14; 138:6,23;
139:14; 140:7,16
net 17:25; 202:1; 203:1,8;
204:1,19,22; 205:1,3;
206:13
Network 149:25; 163:8
Nevertheless 37:18
new 5:13; 7:5,12; 9:6,8;
16:25; 17:3,7,12,17;
18:8,16; 19:15; 44:16;
50:8; 60:17,17,20; 61:15,
20; 64:4, 5,11; 70:14;
73:18; 74:19,22; 75:2;
76:6,12; 78:18; 79:6;
84:14; 102:7; 105:6;
106:11; 116:16; 117:10;
121:13:123:9,11,12;
134:7,7; 137:12; 139:18;
140:10,14; 151:22; 155:8;
 159:10; 165:17; 169:3,13;
172:13:175:19,21;
177:21; 178:4; 181:17;
 182:23; 184:10,25; 186:9,
 16; 188:10; 197:6; 230:13,
 13,17; 232:2; 237:25;
238:3,9,12; 239:2
 new-technology 74:12
 Newark 168:15
 newly 176:4
 news 207:19
 next 6:24; 9:14; 11:21;
 12:14; 28:10; 29:12;
47:13; 48:3,3; 65:17; 68:2;
 87:24; 118:22; 120:22;
 130:7,8; 137:2,13;
 140:18; 156:3; 194:19;
 196:10; 198:2; 226:13;
 240:5
 nice 34:6
nicer 195:18
night 227:8
nine 200:17
nitrogen 4:19,21; 5:9;
9:17; 10:6,12; 11:23; 24:8;
43:15, 21; 48:14; 97:16;
126:19:129:9,19,23;
134:21; 160:2; 166:2;
209:23; 222:5; 233:17
NJ 230:1; 231:1; 232:1;
233:1
NMHC 44:22; 46:25;
48:23
no-later-than-2004
33:22
no-risk 228:21
nominal 202:8
non-attainment 5:5,19;
210:4
non-car-like 81:4
non-compliance 125:15
non-consent 54:19
non-highway 166:22
non-partisan 168:4;
203:5
non-passenger 73:6
non-profit 118:11; 168:3;
203:4
non-road 187:19; 188:3,
5; 189:12
noncommittal 31:25
nonetheless 161:24
nonprofit 41:18
nontoxic 70:6
nor 17:15; 20:2; 95:12;
157:17; 176:9; 231:19
normally 85:22; 217:5
North 113:4
Northeast 44:15; 134:3,
16,23
Northern 222:21
nose 237:14
not-later-than 200:22
not-to-exceed 46:2;
114:25; 130:20; 141:25;
142:6; 143:9,16,24;
144:4,12,14,24; 176:4;
177:24; 178:11
notably 93:25; 214:20
note 125:6; 175:2,10;
198:25; 212:13; 214:19
noted 48:5; 129:7;
192:20; 218:2
notice 78:3; 79:12,13;
84:12; 85:8; 182:10;
184:20; 201:21; 219:21
noticeable 213:14
Notwithstanding 28:12;
116:2; 166:24
novel 199:17
November 11:5; 18:25
NOx 8:23; 9:16,23; 10:14;
11:23:24:11,12,17,20;
25:7; 31:14,18; 43:15;
44:14,16, 22; 46:25;
48:23; 59:11; 67:18,20,
21; 68:11; 70:3; 72:19, 22;
113:18; 119:4; 120:7,13,
18; 134:21; 135:3,10;
136:2,3:137:15,24;
140:19,22; 142:14; 144:9;
154:8,11,20; 159:20;
187:16,18,19;192:12;
198:20; 204:9,13
noxious 23:23
NPRM 76:23; 128:9;
129:16; 130:3,23; 131:5,
20; 132:16; 202:12
NRDC 41:21; 46:16;
199:2
NRDC's42:2,12
NRDS 41:17
NTE 46:2,10; 47:4; 115:8,
9
nub 53:22
number 13:21; 48:8;
62:5; 68:20; 69:12,14;
71:13; 86:11; 96:13;
105:24; 116:13,14,15;
127:16; 137:20; 144:23;
148:7; 153:4,15; 154:17;
165:24; 166:12; 173:6,9;
185:4; 189:14; 205:7,14,
20; 206:5; 213:24; 232:18;
233:2,12,18; 234:4;
237:24
number-one 164:8,9
numbers 68:22; 167:5;
180:2; 186:11,11,16;
188:24; 196:4; 211:6,19;
219:20; 228:7
numerous 43:19; 211:20
nutrient 43:23

          o

Oak 105:4
OBD 11:18; 46:21; 47:3;
122:25;123:2,7
obey 95:12; 157:18;
231:20
object 56:14; 179:10
objections 31:24
objective 118:16
objectives 117:4
obligation 69:6; 200:4;
239:17,25:240:2
obligations 51:4; 52:15;
53:11; 222:10
oblivion 212:6
obstructive 70:23;
163:17
obtain 9:24; 66:24;
199:19
obtaining 8:2; 72:2
obvious 213:17; 237:23
obviously 53:15;54:4;
55:22; 57:18; 61:25;
64:16,17,20,21;65:2,7;
81:13; 145:12; 175:2;
192:7; 194:14; 197:2;
216:13;219:17,24
occasions 204:4
Occupation 44:6
occur 30:15; 35:8; 97:8;
126:7; 132:20; 138:11;
159:4; 171:4; 227:9;
233:10
occurred 59:3; 125:23
occurring 68:18; 211:17
occurs 25:7
October 8:5,7,9; 18:23;
46:7,7,10,14; 127:14;
130:2; 173:2; 179:9;
190:13,14;193:23;
201:23
off 181:17; 190:4
off-cycle 129:13
off-highway 197:17;
198:10
off-road 24:19; 25:13;
30:3,5,9,11,17,22,24;
31:4; 70:2; 75:5,6; 87:10;
98:4; 153:16; 154:5,6,9;
160:12; 171:18; 183:23;
197:19:234:2
offensive 23:22
offer 7:10; 121:12;
180:24; 202:20; 224:2
offered 33:14; 79:18
office 4:8; 7:15; 12:13,
15; 170:9; 191:18; 202:5
officer 7:16; 13:10;
236:25
official 13:2
Officials 22:24,25; 23:9
officiate 13:18
offset 238:6
often 74:8; 98:10,12;
155:3; 156:12; 211:13;
212:7; 226:18; 228:2;
229:2; 234:6,7
OGE 4:3; 7:13,14; 22:17;
34:11; 37:2,5,7; 41:9;
49:14; 52:20; 54:14,17;
56:24; 60:8; 63:25; 65:13,
25; 66:4; 75:17; 84:24;
91:4; 92:13,16,23:98:23;
101:25; 102:5; 104:15;
107:2; 108:24; 112:4,11;
117:25; 124:13; 133:23;
141:8; 143:7,14; 144:17,
21; 145:7,14; 146:10,15;
147:3,9,15,17;149:22;
155:24; 156:2; 160:22;
167:22; 172:6; 179:12;
190:7,14,17,22;191:2;
193:20; 194:17,25;
197:24; 202:23; 206:15;
209:14; 215:3; 219:3,13;
220:4,6,12, 23; 223:18;
225:5; 227:16; 230:6,8,
11; 234:18; 235:25;
236:13,19,23;238:15,19;
240:7
oil 39:22; 70:13; 196:10;
 named - oil (16)
                            Min-U-Script®
                                    Vincent Varallo Associates, Inc.

-------
Environmental Protection Agency Hearing
                                                          Hearing
                                                                              November 2,1999
226:2,14,18, 22; 239:16
old 37:23; 76:6; 88:10;
91:6,8; 206:22; 211:16
old-technology 74:12
older 104:25; 107:20
oldest 66:9; 209:18
OMB 19:6; 202:9,11
on-board 149:10; 155:9;
160:17; 166:25; 171:23;
185:24; 201:17; 205:25;
209:4; 222:12; 234:13
on-highway 5:7; 15:25;
172:12; 184:16; 197:17;
198:11; 199:20
on-road 6:7; 23:12,16;
24:17; 25:13; 28:5,19;
30:2,8,9,14,16; 31:4;
69:25; 87:10; 98:11;
126:24; 134:19; 154:10;
155:4; 171:17, 22; 183:23;
233:25; 234:6
onboard 11:12,18;
31:22; 46:20; 87:16;
98:18; 111:25; 131:7;
139:17; 140:4,12
once 56:12; 87:14; 90:15;
98:8, 21; 111:24; 121:6;
146:2; 154:24; 156:25;
160:16,20; 171:21; 209:3,
12; 211:19; 222:11;
229:24; 234:5,16
one 12:9; 13:18; 15:5;
19:20; 24:11; 27:19; 42:9;
45:22; 48:8; 51:14,25;
54:17,18; 59:8; 60:20;
61:15,17; 65:2; 86:11;
89:3; 96:13; 100:13;
101:11; 105:24; 110:10;
116:13; 127:16; 144:11;
145:16; 147:10,11;
148:20; 150:9; 165:8;
167:16,17; 184:12;
187:10; 191:2,16; 197:9;
204:23; 206:23; 209:18;
210:8; 213:22; 225:17;
237:22; 239:8
one-and-a-third 161:13
one-eighth 181:18
one-hour 5:2,6; 24:24;
 57:13; 126:8; 163:7
one-third  24:16; 44:16
ones  100:3; 103:16;
 129:15; 183:4; 184:12
 ongoing 127:19
 only 18:16; 19:6; 21:14;
 23:10; 27:5; 30:2,18;
 31:20; 32:11; 33:18,19;
 36:14; 39:13; 47:14; 71:8;
 74:16; 80:25; 83:3; 84:5;
 88:5; 91:25; 93:17; 97:20,
 21; 100:7,19; 107:21;
 116:5,9; 149:13; 153:24;
 160:6; 161:8; 162:3;
 167:13; 171:14; 183:3,6;
 186:19; 188:10; 200:21;
 201:4, 23; 202:4; 208:23;
 209:8; 212:14; 223:8;
 233:20; 235:9
open 13:3; 217:14,16;
218:8,21
operate 31:10,11;
162:12; 180:6
operating 17:24; 123:18;
184:7; 186:13; 237:18
operation 18:4; 185:3;
197:6
operations 56:15
operators 197:5
opinion 39:23; 137:23;
165:13
opportunities 83:8;
105:15
opportunity 4:13; 12:24;
18:19; 19:18; 34:6; 41:22;
77:4; 79:14,17; 82:16;
84:21,22; 93:11; 104:23;
109:5; 133:21; 134:10;
148:2; 150:5; 155:16;
156:15; 161:2; 168:18;
172:15; 179:18; 186:24;
188:22; 200:16; 202:19;
206:18; 209:12; 221:5;
223:17,25; 227:21;
229:17; 230:15; 235:5,16;
237:4
opposed 66:25; 193:13
optimistic 122:17; 124:2
oral 12:24
order 10:21; 13:13;
30:15; 87:8,14; 98:2,17;
105:7; 126:11; 139:4;
149:4,20; 155:11; 160:3,
10; 170:13; 200:23;
210:25; 233:23; 234:11;
236:18
organic 126:18; 198:22;
228:19
Organization 25:17;
37:8; 41:19; 66:10; 76:6;
88:6; 134:5; 168:4; 203:5
organizations 42:10;
 147:22
organizer 168:2,12;
 203:2
 origin 11:4; 200:9
 original 16:2; 17:10
 originally 94:23; 212:24
 Orlando 187:7; 195:9,18
 Osteunski 60:13; 64:1,3;
 65:1; 66:1
 others 20:6,22; 26:18;
 34:19; 36:18; 42:20;
 45:10; 51:22; 55:18;
 58:10; 63:15; 136:18;
 182:20; 193:7; 218:23
 otherwise 16:11
 Otis 37:1; 38:1; 39:1; 40:1
 Otto 128:18
 Otto-cycle 46:22;
 121:13; 128:10,25; 133:7
 ourselves 194:19;
 200:25; 211:3
 out 12:19; 37:16; 40:14;
 49:10; 51:19; 60:2; 61:17;
64:7,14; 77:24; 88:17;
90:16; 91:7,22; 100:11;
102:23; 103:7,14,18;
104:3:107:5,7,16,16;
110:7; 116:3; 141:5;
145:18; 165:15; 166:17;
184:5; 187:5; 188:16;
191:9; 194:11; 196:6,13;
210:13; 216:4; 217:5;
218:10,12; 219:19,25;
222:10; 223:15; 231:20;
235:10,13,20,23
outdoor 110:8; 161:10,
17
outdoors 89:8
outlier 18:7
outline 10:2; 41:25; 67:14
outlined 6:18
outrageous 46:4
outreach 201:13
outset 42:9; 48:5; 186:6
outside 62:18,21; 64:14;
65:4,4; 85:21; 91:15;
107:10; 191:15
outweigh 212:11
over 6:21; 9:8; 24:14;
26:7; 30:17; 32:20, 22;
33:9; 35:23; 41:19; 44:17;
48:23;  52:23; 54:5; 59:3;
61:22; 65:6; 68:13,22,23;
69:3; 74:7,15; 80:7; 86:5;
94:17; 95:17; 96:3; 99:13;
100:22; 112:19; 115:11;
118:22; 120:19; 125:16;
126:13; 127:11; 128:12;
130:18; 131:8; 133:10;
136:24; 137:18; 138:20;
140:5;  151:20; 152:16;
154:25; 155:6; 156:14;
157:5,23; 158:13; 162:24;
169:18; 174:23; 179:22;
180:6,7; 200:17;  210:5;
211:10; 212:18; 226:18;
227:8;  231:3, 24;  232:10;
238:14; 239:23
over-50 106:8
over-the-road 237:19
overall 114:23; 117:5;
126:3; 169:20; 176:6;
178:7; 181:22
overhead 75:20
overkill 178:6
overview 124:25
own 24:12; 105:11; 154:6
owner 98:13; 234:8;
239:3
owners 39:11; 67:4,6;
155:5
oxidation 119:16;
136:19,23; 158:25
oxide 4:19,21; 5:9; 10:6,
13; 24:8; 97:17; 134:21;
222:5; 233:17
oxides 9:17; 11:23;
43:15,21; 48:15; 126:19;
 129:9,19,22; 160:2;
209:23
ozone 4:22,22; 5:2,6,13;
24:21,24; 38:20,22;
43:21; 57:8; 67:20; 68:16,
18,23; 69:2,8,10,22;
72:3; 85:19; 88:12; 93:24;
109:20; 125:21; 126:2,9;
134:18; 161:25; 163:4,6,
10,20; 167:2;  168:23,25;
169:2,6,8; 203:25;
226:13,21
p.m 112:10,10; 147:8;
240:10
pace 139:5
package 116:8; 191:8
pages 173:4
paid 181:17
pain 213:3
painfully 88:11; 93:15
paired 166.7
pander 212:4
panel 14:3,5,5,7,9;
15:10; 40:21; 65:17;
141:9; 156:3; 198:2;
215:4; 220:12
panel's 22:15
panicked 88:18
paper 15:16; 65:21
Paragraph 174:19 '
parameters 17:25
parent 37:11; 209:19;
212:14
parental 37:13
parents 40:23; 89:9;
94:12
Park 110:7,13
parks 110:11
Parkway 62:3
part 17:7; 21:12; 49:25;
56:3; 59:12; 74:25; 76:21;
77:15; 99:12; 105:21;
116:17; 127:2; 128:20;
161:6; 162:4; 169:19;
175:22; 176:2; 209:7;
215:24; 217:10; 227:24
partial 194:2
participants 199:15
participate 190:24
particle 39:2,4; 67:18;
71:2; 150:23; 237:12
particles 25:21; 70:7,19,
22; 71:4; 237:15
particular 133:17;
168:15; 237:17
particularly 5:25,47:10;
116:12; 152:4; 164:2;
168:14; 169:24; 235:7;
239:4
Particulate 5:21; 24:8;
25:4,6,8,15,17,19; 26:3,
12; 34:20; 36:19; 40:6;
43:14,25; 48:13,20; 57:9;
62:15; 68:4; 70:6,9,15,
18; 71:7,17, 22; 72:3,10,
12,23; 75:7; 86:19,21;
87:5; 89:22; 94:25; 96:23;
97:3,7,16; 109:11;
110:21; 111:19; 119:17;
126:24; 127:7; 128:4;
129:9; 134:18; 136:8;
149:7; 150:19; 153:5,6,8,
11; 157:2,8; 158:20,23;
159:22; 163:11,20;
165:19; 166:4; 167:3;
170:24; 171:3,10; 175:11,
13; 198:21; 204:11,16;
205:8,11; 206:8; 207:15;
208:13,16,18; 221:13;
222:2,4; 224:24; 229:22;
230:23; 231:10; 233:3,6,
9,16
particulate-emitting
49:7
particulates 4:20; 5:24;
9:17,23; 11:23; 43:18;
44:17; 70:5,11; 71:15;
72:18; 112:21; 204:13;
237:7
parties 19:3,17,25;
21:25; 77:5; 124:10;
177:3; 199:19; 200:11,14
partly 235:2
partnership 225:11
parts 29:14; 30:5; 48:18;
87:11; 98:5; 100:13;
117:15; 153:23; 160:13;
166:14; 169:4,7,9;
171:18; 205:18; 208:25;
222:8; 225:2; 234:2
pass  136:25; 205:22
pass/fail 176:6
passed 94:23; 187:23;
195:7,21; 204:15; 231:8
passenger 6:11; 8:14;
32:21; 33:5; 66:16; 67:3,
17; 70:14; 74:5; 80:10;
81:10; 86:16; 96:20;
114:13; 115:16; 121:24;
122:10,11; 139:3; 153:2;
156:17; 158:3, 5,7,8;
159:13; 170:21; 204:25;
208:10; 221:24; 228:24;
229:20; 232:24
passion 38:7
passionately 58:23
past 18:23; 21:2; 58:5;
59:3; 68:19; 98:14; 142:2;
151:11,21; 166:22;
190:18; 191:6; 196:17;
234:9
Pat 112:15; 141:13;
145:17
path 55:22; 142:4
Patrick 112:13,25
payback 105:12
peak 80:23; 125:21;
169:2,6
PennPIRG 95:19
Pennsylvania 34:22;
35:17,22; 36:9; 38:18;
85:6; 93:9; 94:5,15;
 Vincent Varallo Associates, Inc.
                             Min-U-Script®
                                             (17)  old - Pennsylvania

-------
November 2,1999
                                                          Hearing
160:25; 162:23; 163:2,19;
164:17; 167:3; 203:3,16,
21, 22; 204:6; 207:3;
238:22
Pennsylvanians 38:21;
94:9; 161:14; 203:24;
205:9
PenPIRG 93:9
people 4:24; 13:19; 16:8,
11; 24:22; 37:15; 38:14;
44:18; 61:9,12; 62:5,16;
69:7,14,19,21, 24; 81:11;
103:6,10; 106:17,18;
109:21, 25; 110:6; 137:21;
150:15; 157:19; 161:14,
16; 162:22; 163:14, 22;
164:7; 207:4; 210:24;
222:17; 228:5,10; 229:5,
11; 235:4; 237:6
per 29:14; 30:5; 48:19;
87:12; 98:5; 117:15;
148:15,17; 153:10, 23;
154:19,20; 158:24;
160:13; 166:3,5,14;
169:4,7,9; 171:19;
205:18; 208:25; 222:8;
225:2; 234:2
per-brake 72:22
per-b rake-horsepower
72:24; 128:17; 129:18
percent 5:8; 8:23; 9:9,11,
22, 22; 10:15; 25:5,12,13,
14; 26:3; 35:18,19; 36:2,
6; 38:16; 39:2; 44:14;
69:17,18; 70:2,8; 75:6;
76:8; 86:20; 89:2; 94:25;
97:15; 110:20; 111:20;
112:20; 113:18; 120:19;
125:16,22,24, 25; 126:13,
21,23; 127:11; 134:20, 21;
135:10; 144:5; 148:10;
149:8; 150:22; 153:7,13;
154:8,9,11,12; 157:7;
159:25; 163:24; 164:6,14;
165:20; 166:10; 169:5;
170:5,7, 24; 171:11;
182:3,4, 5; 186:12;
187:17,18,18,19,19;
198:20, 21; 204:9; 205:8;
206:10; 208:14,19; 210:5,
6; 214:9; 222:3,4; 224:25;
229:23; 231:9; 233:16
percentage 70:10;
126:16; 204:10
perfectly 144:11; 218:19
perform 73:15
performance 17:23;
47:19; 73:14; 74:20, 22;
80:14; 82:25; 123:5;
 144:6; 185:2,18
performed 155:2
perhaps 45:4; 51:25;
145:20; 167:10; 196:11;
197:19; 213:10; 238:10
period 19:2,4; 21:23;
22:13; 39:21; 42:8; 46:9;
69:13; 77:18,19; 86:5;
96:4; 117:18; 158:14;
177:13,14; 179:6; 181:25;
                                                Environmental Protection Agency Hearing
184:14; 195:24; 202:9,12,
22; 206:14; 210:6; 232:11
periods 68:13
permanently 213:10
permitted 78:14
person 13:17; 14:3;
85:17; 210:12; 223:8
personal 33:2; 55:10;
79:9; 81:7; 84:10; 131:22;
132:6; 133:9; 212:13;
213:21, 23; 235:7,9,18
persons 12:23; 79:10;
163:16
perspective 24:6; 56:2;
123:17; 133:20; 191:25;
192:19; 193:16; 216:2, 20;
217:17,19; 224:3
perspectives 23:15;
51:11
pervasive 212:24
petition 83:18
ph 13:15
phase 6:23; 7:3; 9:6,13;
11:21; 28:10; 48:4; 57:6,6;
67:14; 72:17; 73:5;
152:15; 159:23; 165:25
phase-in 80:4; 111:10;
139:8
phased 49:4; 74:3; 86:5;
96:3; 99:11; 153:12;
158:13; 232:10
phases 57:5
Philadelphia 4:9,14,25;
5:4,19; 6:2,4; 7:18; 12:7;
35:16; 38:25; 43:22; 85:5,
9; 93:15,19; 94:2,7;
104:22; 105:4; 107:4;
112:18; 203:25; 204:5;
207:14; 210:2,8,11;
214:11; 221:3; 223:23;
224:13; 225:9,10,14,15,
21; 226:3,23; 227:19, 20;
228:9; 229:15; 234:24;
235:2; 237:9,18
Philadelphia's 105:13;
227:24; 228:20
Philadelphians 93:21,
229:2,2
philosophical 56:7
phrases 44:4
pick 107:19; 235:14
pick-up 8:14; 33:9; 66:15;
103:5
pick-ups 102:25
picture 90:10; 92:6;
210:7
pie 126:15; 189:12
piece 15:16; 58:21,22
pieces 189:12
piggybacks 6:9
PIRG 156:1,11; 157:1,
25; 158:1; 159:1; 230:1,
13; 231:1; 232:1, 2; 233:1;
234:25
PIRGs 156:12
Pittsburgh 34:23; 94:3
place 4:14; 10:12; 11:19;
16:3; 28:19; 54:7; 55:13;
60:22; 115:8; 149:17;
155:10; 166:11; 184:24;
185:9; 219:10; 227:8;
237:21
placement 91:18; 138:14
places 6:4; 61:15
plagued 125:12
plan 9:13; 119:9; 128:22;
201:2,20
planned 106:6
planning 8:20; 9:15;
57:20; 113:22
plans 6:24; 22:10; 28:7;
105:25
plant 155:3
plants 74:23; 206:23
plate 55:15
platform 80:19
play 37:23; 46:6; 89:7;
184:21
played 181:21
playing 6:14; 51:10
plea 40:21
please 13:16; 14:15, 22;
15:14,17; 37:7; 50:19;
65:17,20; 66:5; 92:3;
108:21; 118:2; 147:13,18;
156:5; 220:18; 230:11;
234:21; 236:6,14,14,24;
238:19
pleased 23:4; 27:25;
118:8; 152:2,4; 158:6
pleasure 124:22
plentiful 44:12
plus 44:22; 46:25; 48:23;
129:18
PM 25:5,9,12; 57:13;
67:24; 68:3,4; 71:6,6;
119:4,19,20; 120:2,8,13,
18; 134:22; 135:10; 136:2,
24,25:137:5,7,16,17,
24; 140:21; 159:4; 160:2
pneumonia 25:25;
164:24
pocket 197:10
point 51:19; 58:12; 81:3;
101:24; 102:23; 103:14;
104:3; 143:15; 145:4;
152:20; 154:17,23;
174:14; 183:18; 185:5;
187:8; 194:5,6; 217:3, 23;
219:15; 239:14
pointed 100:11; 103:7;
184:5
points 32:18; 58:13;
99:24; 152:18; 176:14
poison 205:15
police 223:6
policies 168:11; 179:16;
203:11
policy 18:15; 106:24;
134:8; 141:20; 181:11;
183:21; 195:21
policy-makers 90:10
politically 226:19
politics 37:16
polls 37:17
pollutant 4:22; 71:19;
182:5; 199:12
pollutants 24:7; 162:22;
210:17; 212:23
pollute 108:7; 204:24;
205:23:239:6
polluted 110:10; 211:21
polluters 89:19
polluting 148:24; 154:10;
180:14; 209:22; 212:11;
214:12,14;239:11,11
pollution 5:11,23:9:16;
22:22,23; 23:13,22, 25;
26:21; 30:24; 35:9; 36:4,
13; 38:5; 39:2,4,10;
40:19; 43:23; 48:6,9;
58:11; 60:22; 61:6,14;
62:9; 65:3,4; 67:8; 70:18;
72:4; 85:8,14; 86:2, 21,
25; 87:8,11; 89:14; 90:15,
21; 91:14; 93:12,16; 94:4,
10,19,20, 25; 95:3,6,10,
17,22; 96:15; 97:3,7,12,
19,24; 98:3,12; 109:6,7,
17; 110:2,17,19,21,24;
111:5,7; 137:24; 150:6,8,
14, 20,23; 151:4,7,9;
152:3,6, 22; 153:7; 154:8,
9; 155:8; 156:16,19,21,
24; 157:2,6,8,10,12,15,
23; 158:5, 24; 159:16;
160:4,5,9,10; 161:16,19;
162:25; 163:10,12,21;
164:3,18,25; 167:3,14,
17; 168:19,21; 169:15,21,
22; 170:17; 171:3,7,9,10,
13,16; 181:8,18; 182:7;
184:8; 203:20; 204:12;
205:11,16,17; 206:6,9,
22,24; 207:3,9,13,15,
17,24; 208:6,16,17,18,
22; 210:10; 211:24; 212:2,
10,17,18; 214:2,8; 221:6,
8,15,17;  222:5; 224:24;
227:2, 22; 228:18, 24;
229:12; 230:16,18,19,24;
231:4,6,7,10,12,14,17,
24; 232:5,20; 233:6,9,13,
19,23,24; 234:7; 235:13;
237:5,11,12,21,23;
238:8; 239:22
pollutions 150:17
polycyclic 228:19
Pond 169:3
pOol88:17;91:18,22
poor 104:24; 150:16;
229:3
poorest 228:20
popularity 35:11
populated 235:5
population 76:19;
125:24; 149:15; 150:15;
182:3; 211:6
populations 163:19;
211:3,18, 25; 227:25
Porreco 147:14; 149'23
24, 25
portion 68:4; 129:8;
150:14; 212:2
pose 25:15; 122:16;
151:16; 169:22
posed 26:6; 226:20
posing 23:25; 152:21
position 78:24; 104:3'
119:8; 143:11; 145:7;
172:22; 183:20
positive 181:24
possibilities 11:21'
216:16
possibility 212:21
possible 11:16; 14:16;
17:24; 22:11; 28:24; 30:6;
42:3; 87:3; 97:14; 99:18;
108:14; 120:14; 123:19;
132:20; 141:18; 145:25;
159:18; 171:9; 179:6;
206:8; 214:15; 216:14;
218:4; 222:20; 233:15
post 59:20; 146:19
post-2004 117:11,18,
20; 119:5; 120:4; 146:8
post-industrial 228:2
postcard 90:7,9
posted 173:2
potent 71:18
potential 20:24; 76:13;
84:13; 117:10; 149:12;
185:19; 199:12
potentially 36:11; 88:24;
173:12; 239:11
pound 114:14; 122:15;
131:21
pounds 6:22; 8:16; 9:8;
11:14; 47:2; 73:8; 79:7,8;
94:18; 102:25; 122:3,11,
12; 123:8; 128:12; 131:8;
133:10; 138:25; 139:12;
157:5; 180:6,7; 231:3
pouring 210:13
power 74:23; 95:24;
158:10; 206:22; 213:12;
223:12; 232:6
powered 157:5; 231:3;
237:20
powerful 211:2
powering 225:21
ppm 82:11; 83:11; 84:17
practical 71:22; 99:3,16,
23; 121:2; 224:4
practice 45:21
pre-adolescence
163:15
pre-sale 205:23
pre-school 214:20
preamble 218:3
precautionary 71:23
precipitated 161:15
precisely 68:2
preclude 82:20; 116:18
precursor 4:22	
Pennsylvanians  precursor  (18)
                             Min-U-Script®
                                    Vincent Varallo Associates, Inc.

-------
Environmental Protection Agency Hearing
                                                         Hearing
                                                                             November 2,1999
precursors 24:21;
163:10
predicate 45:2; 59:14
predictable 211:12
preferably 166:7,10
preference 112:17
preliminary 30:4
premature 5:24; 25:18;
26:2; 43:20; 70:24; 93:20;
97:10; 159:5; 165:2;
171:4; 205:12; 207:4;
233:11
prematurely 85:13;
239:21
premise 192:4,15
premised 114:8
prepare 19:19; 22:10;
202:17
prepared 146:25; 187:8
prerogative 189:18
presence 162:21; 226:25
present 64:23; 118:8;
161:2
presentation  12:24;
14:2; 22:15
presentations 14:8
presenting 99:24
presents 121:14
preservation  168:17
president 8:5; 27:11;
75:23; 179:16
presiding 7:16; 13:10
press 181:3
presume 145:24
prevailing 68:13
prevails 68:12
prevalence 69:17
prevent 97:23; 105:7;
160:8; 233:22
preventable 35:13
preventative  149:14
preventing 100:25;
162:5
prevention 161:22
previously 173:11; 174:2
price 186:14;  238:8,13
pride 198:18
primarily 10:23; 131:22;
 132:6; 146:21; 148:13;
 161:10
primary 24:20; 25:3;
 134:16; 173:18; 184:12,
 21; 189:16; 206:21
 Princeton 161:5
 principal 99:7
 Principals 113:13
 principle 113:20
 Principles 16:4; 19:22;
 28:16; 114:16; 128:7;
 177:5; 198:16; 199:17, 24
 print 65;20; 156:6; 236:15
 prior 13:24; 49:23; 77:7;
 78:14; 194:8; 201:23;
202:9,21
priorities 213:19
priority 80:2
priorty 127:16
private 107:23; 201:10;
227:12
probable 26:9; 44:3;
71:15
probably 4:21; 5:12;
23:21; 56:25; 58:7; 59:17;
92:19; 142:7; 196:3
problem 5:19; 12:11;
25:16; 48:25; 59:3; 61:16;
64:20; 65:7,10; 80:6; 87:2;
93:25; 94:22; 97:13;
100:15; 102:19; 109:14;
149:3; 159:17; 163:2,13;
171:8; 189:6; 201:7;
202:2; 206:7; 215:11;
221:14; 222:14; 226:13;
228:13; 231:7; 233:14;
235:2,10,21
problems 4:23; 12:14;
25:24; 26:22; 32:6,6; 57:9;
62:10; 65:3; 75:10; 85:8;
94:19; 107:9; 110:17;
157:6; 161:15; 164:22;
167:14; 228:7; 231:4
procedure 46:10;
123:17; 175:18; 185:8;
197:3
procedures 17:3,13,18,
19; 50:3; 56:15; 98:16;
114:9; 116:16; 123:10,12,
13; 128:11; 130:6,10;
142:10; 175:20; 234:11
proceed 21:18; 34:2;
57:11; 144:24; 166:5;
198:2; 219:9
proceeding 30:21; 147:7
PROCEEDINGS 4:2;
15:3
process 6:7; 19:22;
52:12; 79:15; 84:12;
149:19; 177:6,10; 182:21;
183:9; 185:16; 201:12;
205:24; 216:23; 219:21;
239:10
processes 20:10; 183:14
produce 4:17; 47:17;
49:22,24; 51:16; 73:9;
 143:17
produced 99:15; 100:20;
 108:6
producers 39:22; 54:3;
 121:9; 124:9
produces 198:9
producing 50:15; 53:6;
78:10; 144:25; 197:18;
 198:20
product 16:4; 20:19;
 51:16; 54:11; 114:19;
 182:2; 198:7; 199:9
 productions 58:20
 products 17:23; 39:24;
 54:10,10; 78:10,18;
 176:11,16; 198:19
professional 147:20
profit 229:6,6,16,18
profound 19:21
program 17:3; 21:8;
22:22; 27:18; 31:3; 32:13;
46:19,20; 47:3; 60:7;
62:12; 73:5,8,13; 74:3;
79:22; 86:10; 95:20;
96:12,16; 99:6,8,10,12;
101:14; 111:17; 115:15;
118:20; 119:25; 125:18;
128:2,13:131:10,24;
132:5; 133:11; 140:2,4,
11; 152:19,22; 155:17,20,
22; 158:19; 159:9; 170:14,
17; 173:8; 192:18; 207:24;
208:2,6; 209:7; 219:10;
221:18; 225:10,10,16;
226:4,24; 229:14,19;
232:3,17,20
programs 27:10,23;
30:23; 55:13,16,19;
85:25; 126:4; 180:23;
189:22,23; 225:18
progress 124:3; 162:24;
200:16
projected 67:24; 126:16
projections 24:12
projector 75:20
projects 25:9; 127:22
promote 168:7; 203:9
promoter 237:16
promoting 55:19;
183:11; 225:11
promotion 161:22
promptly 47:8
promulgate 129:11
promulgated 28:8;
78:12; 131:15; 177:9
promulgating 77:7;
201:8; 238:6
promulgation 84:6;
132:23; 200:23; 202:10
prong 31:8
prongs 27:20
pronounce 64:2
pronounced 60:13
pronto 108:8
Proof 239:22
propane 225:23
proper 18:10; 53:23,24;
79:13; 82:20; 142:4;
186:2; 187:2
properly  185:12
proportionately 109:15
proposal 5:10; 6:13,18,
19; 7:4,8,11,20,22,23;
8:3,8; 9:20,23; 10:3, 5,
25; 11:15,20; 12:25;
16:23; 20:15; 22:5,8,9;
23:6,9,16; 27:8; 31:23,
24; 32:19; 34:7; 42:12,17;
43:2; 48:11,23; 51:17,23;
52:2,7; 53:14; 64:8; 66:23;
67:11; 70:3; 71:25; 76:15,
16,16; 77:10; 82:6; 86:5;
89:13; 96:3,6; 97:5; 100:4;
102:20; 111:9,12; 114:20;
115:14; 116:12; 117:2,6;
118:9,19; 120:3,6;
121:14,25; 122:24; 123:2,
21; 125:4; 128:3; 134:11;
135:12,18; 137:7; 138:3,
24; 139:9,15, 21; 140:17,
19; 141:5; 152:8; 153:16;
158:6,13,15; 159:2;
161:24; 165:16; 170:10,
19, 25; 176:24;. 177:2,4;
179:4; 181:2; 190:11,12,
19; 200:10; 205:6,10;
208:9,15; 232:10,12;
233:7
proposals 39:16;
115:10; 165:6; 185:23
propose 6:24; 8:18; 9:14,
15; 10:20; 17:7; 19:15;
21:6; 133:2; 224:21
proposed 7:6; 17:5,21;
18:8,12,16,17; 19:5,24;
21:5,9; 27:10; 31:6; 32:23;
42:2; 66:20; 67:23; 75:25;
76:17; 81:6; 82:8; 99:9;
103:4,15; 108:13; 113:10;
114:24; 115:10,22; 116:6;
118:14; 119:8; 121:13;
122:3,6,13; 123:11;
128:16,23; 129:6; 130:3,
19,23; 133:5,12; 134:13;
136:3,11; 137:2,9; 138:4,
6,24; 139:4,13; 155:17;
161:3; 162:19; 165:4,10,
25; 172:16,21; 173:6,10,
14,23:174:15,23:175:11,
19; 176:4,20,21; 177:20;
178:8,15,17;179:7;
182:12; 184:14; 187:15;
194:13; 204:20; 205:4;
226:5; 239:2
proposes 6:10; 129:16;
131:5,20; 172:13
proposing 9:3,6; 10:14,
24; 11:2,7,11; 16:25;
17:12; 39:13; 41:6; 47:11,
16; 57:5; 79:3,5,20;
95:20; 102:10; 207:23;
209:21; 221:18; 232:3
prospective 192:4
protect 38:11; 69:7;
89:10; 203:15; 230:4
Protection 4:4; 49:19;
172:3
protections 168:8;
203:10
protective 5:18; 38:12,
13; 203:16
protestations 40:11
protocols 117:11;
175:25
proud 182:7
prove 212:22
proved 123:3
proven 40:10
provide 11:8; 12:23;
16:8,21; 19:17,18; 23:5,
15; 41:25; 42:4; 52:5;
66:21; 82:23; 84:21;
113:21; 123:22; 124:22;
125:3,8; 131:17; 133:13;
134:11; 138:14; 144:21;
172:16,22; 174:16; 176:9;
177:4; 178:14; 200:16;
201:4; 202:20; 211:7;
228:13; 239:15
provided 13:3; 19:10;
29:4;45:11;78:25;
121:18; 141:16,19;
142:23,25; 143:4; 174:6;
193:14
provides 114:6; 116:21;
134:7; 137:23; 140:19;
142:11
providing 150:4; 155:15;
179:4; 185:25; 199:21
provision 42:4; 84:5;
131:25; 132:12; 200:3
provisions 11:8; 31:22;
46:3,13,23; 47:5; 48:24;
49:12; 51:22; 79:17;
131:6; 134:13; 142:19;
172:21; 173:7, 22; 178:11,
19; 215:17,25; 216:20;
217:9,17
proxy 211:13
Prudence 71:21
psychology 222:23
Pubic 240:10
public 4:15; 7:20; 20:3;
24:2; 26:21; 43:4; 54:4,9;
60:10; 66:25; 76:4; 90:8,9;
92:25; 93:10,16; 96:5;
97:6; 109:18; 111:11;
116:6; 137:18,22; 147:20;
150:3,9,10; 156:11, 20;
159:3,18; 165:21; 168:5,
10; 170:25; 172:3; 173:2;
177:10; 182:19; 185:15;
191:13,16; 195:4; 201:9;
203:6,11,15,16; 206:11;
207:15; 214:11,15;
221:11,21; 223:15;
226:20; 228:15; 229:18;
230:2,18; 232:12; 233:8;
238:4,11,22; 240:8
public's 89:23
public/private 225:11
publication 22:12
publish 18:22; 22:4;
230:13
published 8:8; 183:12;
201:22
pull 79:11
pulled 191:9
pulmonary 163:17
pumped 224:14
purchase 186:14; 238:8
purchased 80:25; 239:7
purchases 239:19,20
purchasing 68:9; 239:10
purpose 200:15
pursue 132:13
pursuing 28:2,9; 133:18
 Vincent Varallo Associates, Inc.
                            Min-U-Script®
                                         (19)  precursors - pursuing

-------
November 2,1999
                                                         Hearing
                                               Environmental Protection Agency Hearing
pursuit 76:11
put 40:14; 46:8; 62:13;
76:15; 85:11; 101:16;
142:8,17; 149:16; 166:11;
191:18; 197:9; 213:25;
219:19; 229:5,18
puts 52:3; 174:11
putting 64:7; 91:10;
154:2; 197:14; 205:21
quality 12:4; 21:20;
22:25; 29:9,20; 31:5;
35:12; 38:10,19; 45:7;
76:25; 78:20; 82:6,8,15,
16; 83:7,16; 84:19; 90:2;
93:19; 104:24; 105:23;
106:15; 121:7; 123:16;
124:7,11; 125:2,13,16,
20; 126:6,9,12; 150:11;
161:17; 167:13; 179:2;
181:22,25; 188:6; 195:7;
203:14; 205:13; 213:9;
225:25; 229:10; 235:3
quantities 43:14
quantity 11:25,25;
228:10
questionable 144:8
quickly 30:21; 31:7;
90:22; 108:13
quite 32:5; 43:8,13;
53:16; 98:10; 218:18;
234:6
quo 52:19
quote 35:5; 36:5
quoted 56:12

          R

 rage 68:9
 raid 43:22
 railroad 188:8
 rain 26:19; 211:22
 raise 50:4,5; 114:22
 raised  193:17;  194:21
 raises  186:15,22
 ramifications 239:12
 range 11:10; 80:14;
 115:11; 120:18; 130:14,
 18; 137:10; 142:6; 165:11
 ranges 211:6  .
 ranging 163:10
 ranks  105:16
 rapidly 75:15
 rarely  18:3; 171:21
 Rash 220:15,20; 225:1,
 6,7,8; 226:1
 rate 8:11; 72:22; 187:9;
 211:18
 rates 38:15; 64:25; 88:25;
 131:10; 170:4
 rather 39:8; 43:5; 83:5;
 153:20; 163:7; 165:21;
200:21
rationale 78:22
re-analysis 216:12
re-definition 201:17
reach 94:3; 199:16;
200:13; 206:25
reached 44:9
reaction 142:19
read 91:3; 108:5
readily 224:22
reading 101:17
readings 38:18; 203:22
ready 21:11; 189:21;
191:9; 196:15
reaffirm 53:17; 129:16
reaffirmation 44:21,24,
25
reaffirmed 216:9
reaffirming 135:23
reaffirms 10:5
real 56:15; 71:5; 73:14;
89:22; 90:11; 106:22;
107:22, 22; 123:18;
130:11; 163:2,12,13,14;
229:11; 238:2
realistic 113:17
reality 20:15; 167:14
realization 130:12
realize 41:12
realized 123:6; 140:15
really 96:13; 102:16;
142:9; 143:2,21; 218:18,
21; 222:20; 224:16; 235:2,
5, 22, 22
reason 5:15; 63:7; 66:22;
86:13; 94:12; 96:18;
107:19; 153:9; 155:5;
177:16; 232:22
reasonable 13:13; 55:13;
142:7
reasonableness 65:15
reasonably 44:3; 56:20
reasons 43:12; 59:8;
73:20; 138:8; 165:14;
191:3,17; 214:16
rebuilds 74:9,23
rebuilt 74:21
recall 194:2
recategorize 18:12
receive 237:24
received 194:11; 202:3,6
receiving 185:22
recent 6:9; 23:5; 32:15;
35:15; 72:6; 93:18;
109:10; 125:2; 164:5;
169:25; 181:22; 230:22
Recently 35:3; 110:9;
127:19
reception 14:16
recess 112:9; 236:12
recharacterization 17:4
recipe 210:20
recirculation 184:12
reclassification 80:5
recognize 20:13; 21:13;
82:18; 114:4; 167:14;
218:2
recognized 80:15;
225:17
recollection 99:10;
141:13
recommend 21:22,24;
22:4; 117:7; 141:24;
194:18
recommendation 67:13
recommendations
29:11,25; 72:5; 125:5;
155:19
recommended 29:16;
108:2
reconcile 193:6
record 13:2,11; 46:8;
50:19; 51:6; 59:6; 68:21;
118:5; 163:4; 179:20;
180:17,18; 181:19;
191:16; 196:18; 215:8;
216:6; 219:15; 234:22
recorded 93:23; 126:8;
162:2; 169:7,9
recouped 114:3
recreational 110:8;
169:3
redesign 100:12
redesigned 100:15
redesigning 132:8
redraft 176:25
reduce 4:15; 6:7; 7:4;
9:16,22; 20:24; 21:6; 22:5;
31:5; 48:12,14; 62:14,14;
66:12; 67:20; 68:3; 71:5;
75:2; 89:21; 93:12; 95:9;
109:6; 111:5; 123:24;
124:3; 127:16,20; 128:2;
129:22; 131:18; 133:14;
135:14,18; 137:24;
140:17; 144:12; 147:24;
149:6,8; 150:6; 152:3;
153:6; 156:16; 157:15;
168:19; 178:7; 181:8;
185:20; 199:12,19;
204:21; 205:10; 221:6;
224:23; 226:5; 227:22;
230:16; 231:17; 237:5
reduced 21:9; 75:9;
82:23; 146:21; 212:4
reduces 211:24
reducing 20:18; 58:15,
16,19; 66:17; 67:19; 70:5;
76:18; 118:17;  128:20;
134:15; 138:15; 197:18;
212:10
reduction 7:7; 21:7;
34:20; 67:3,15; 71:24;
72:18; 73:24; 79:22; 87:5;
97:16; 112:21;  113:18;
120:19:137:2,2,8;
140:22; 153:12,13,17;
159:20, 25; 198:20,21;
199:11; 222:4; 224:19;
225:25; 233:16
reductions 4:19; 21:14;
31:14; 55:14; 56:4; 57:22;
59:9; 66:20,24; 67:18;
68:11; 72:2; 73:2; 76:17;
82:14; 97:6; 113:15;
116:22; 117:2; 118:22;
119:22; 120:13; 126:10;
127:3,6; 129:3; 130:12;
133:13; 135:9,17; 136:15;
140:14, 20; 159:4; 160:4;
165:12,22; 171:2; 198:19;
199:9; 208:16; 233:9
redundancy 178:7
refer 216:24
referencing 132:19
refiners 40:14
refines 135:4
refining 21:12
reflect 56:15; 98:11;
123:18; 155:3; 171:22;
234:6
refuse 39:23
regard 103:23; 121:25;
122:24; 123:9; 183:25;
185:23; 186:5; 187:3
regarding 28:14; 32:19;
107:14; 108:16; 114:22;
117:23; 174:13; 187:15;
215:13; 219:23
regardless 53:3; 82:11;
132:24; 159:13
regards 104:5; 185:13;
189:8,15; 196:9
region 38:12; 135:2;
210:5,8; 211:19; 225:14,
21
region's 206:25
regional 26:18; 206:19;
210:9,14
regions 209:8; 226:19
Register 201:22
Registrar 8:7,9; 14:20
regress 54:6
regular 148:25
regularly 38:21; 203:24
regulate 16:11; 27:5
regulated 17:15; 23:17;
102:24; 174:22; 188:9;
199:18
regulating 135:12
regulation 23:7; 52:22;
77:20; 176:14
regulations 28:10;
40:12,15,24; 77:17;
107:14; 127:19; 176:21;
177:8,15;  193:14,23;
238:6
regulatory 10:21; 12:10,
14; 17:3; 18:14; 20:8; 21:8;
27:18; 52:3,7; 53:14;
79:15; 84:12; 118:14;
121:17; 131:13; 135:4;
173:5,8; 178:6
reiterates 163:23
related 12:25; 23:17,19;
46:16; 81:18; 99:4;
203:18; 205:13
relates 122:25
relating 123:21; 134:11
relation 78:13
relationship 148:6
relative 134:24; 165:15
relatively 211:11
relax 16:20
released 168:23; 202:12
relevant 22:7
reliability 184:3; 196:20
reliance 225:25; 226:21;
237:25
relieved 147:7
rely 95:12; 157:17; 183:4;
231:19
remain 31:12; 154:3;
162:15; 178:23
remaining 237:22
remains 48:6; 71:18;
217:16
remanded 68:15; 71:2
remarkably 239:8
remarks 4:6; 41:25;
202:20
Remember  167:21;
190:20, 21; 223:19
remind 167:17; 215:12
reminded 14:10; 220:18
remiss 83:9
removal 21:4
remove 31:21
removed 140:3
removes 78:8
removing 166:10
render 187:8
repeat 122:7; 202:14
repetitious  13:13
replica 217:13
report 168:23; 203:18;
204:12
reported 35:4,24; 61:22;
94:6; 168:24
reporter 14:24; 15:4;
37:9; 236:6,16,20
reports 93:18
represent 37:8; 83:7;
130:14; 161:8,11; 179:22
representative 176:19
representatives 162:17;
196:11,12; 200:2; 217:4;
223:10
represented 200:13
representing 76:8;
156:13; 172:9; 179:21;
225:8
represents  190:3
reproductive 26:10
reputable 230:22
request 178:16; 215:23
requested 13:24
requests 178:13; 216:5
require 6:19; 9:9; 11:11;
 pursuit - require  (20)
                            Min-U-Script®
                                    Vincent Varallo Associates, Inc.

-------
Environmental Protection Agency Hearing
                                                         Hearing
                                                                             November 2,1999
21:4,9; 47:17; 71:24;
72:18; 75:4; 77:16; 78:16;
83:2; 89:16; 104:7; 114:2;
115:10; 118:24; 130:17;
137:11; 148:17; 149:9;
158:10; 159:25; 175:21;
208:15; 232:6
required 19:12; 39:11;
57:25; 59:10; 67:16;
74:22; 82:12,14; 84:18;
87:17; 96:17; 98:19;
114:5; 121:3; 151:19;
152:23; 153:8; 154:5;
155:6,13; 159:9; 166:25;
170:18; 171:24; 175:24;
183:19; 206:2; 208:7;
209:5; 232:21; 234:13
requirement 132:13;
154:14; 184:19,24; 189:7;
192:16; 193:4
requirements 10:17;
11:3,4,12,18; 19:16;
20:14; 22:3; 45:17; 47:24;
53:2,20,21; 57:24; 59:20,
23; 75:12; 81:20; 115:2,8;
121:7; 123:7; 127:24;
129:14,25; 130:22; 131:2,
3,17; 140:12; 143:10;
144:25; 145:22; 166:8;
172:14; 173:22, 24; 174:3,
10,18; 177:21; 178:2,10,
16,18,25:184:2,15;
186:21; 192:3,6,8,11;
200:24
requires 12:23; 46:20;
77:25; 83:4
requiring 18:6; 21:15,19,
20; 74:3; 81:15; 95:24;
160:17; 207:21
rerun 186:11
rescind 78:24
Research 44:7; 93:10;
156:11; 230:14; 238:23
researchers 204:17
researching 222:22
resent 39:12
reserved 16:19
reserves 206:13
resident 107:4
residents 36:9; 104:25;
106:4
resides 90:2
resinates 187:10
resolution 29:22; 33:7;
59:5; 181:14; 195:6,21,22
resolve 79:25
 resolves 5:16
 resort 40:9
 Resource 49:20; 126:22;
 198:25; 230:2,3
 Resources 16:5; 41:17;
 44:8; 67:9; 121:10;
 124:17; 189:11; 199:25
 respect 6:14; 51:6;
 195:12
 respectfully 116:20
 respectively 126:21
respects 102:11
respiratorily 39:25
respiratory 4:23; 25:22;
35:7,13,24; 38:14; 70:23;
94:9; 106:3; 107:9;
150:24; 164:19,22,23;
203:18; 207:6; 221:16;
228:12; 240:4
respond 83:18; 146:25
response 57:2; 76:15;
122:3; 144:16; 155:25;
177:25; 178:10; 192:22;
216:3,4; 220:5; 230:7
responses 14:11; 144:8;
146:3
responsibility 180:18;
199:2,6; 213:21,23;
214:17; 222:19; 239:15
responsible 17:22;
24:10; 109:12; 126:20;
134:20; 150:20; 157:2;
164:18; 165:2; 170:6;
181:7; 190:3; 197:20;
223:11; 230:24; 239:16
rest 5:4; 63:9; 100:22;
125:11; 204:19
restrict 80:19
restricted 164:20
result 4:18; 17:25; 35:12;
106:20; 111:10; 116:15;
118:21; 140:14; 153:13;
179:9; 185:11; 198:15;
226:16; 229:8,8
resulted 31:14; 45:20;
157:22
resulting 82:21; 86:6;
95:16; 96:4; 130:11;
144:23; 158:14; 167:7;
210:19; 211:7; 214:2;
231:23; 232:11
results 200:23; 213:14;
225:24
retain 66:23; 184:18;
188:24; 189:6
retrofit 73:24; 74:3,16
return 67:22; 112:8;
174:25
revenue 197:9
reverse 35:11
reverses 105:19
review 16:14; 18:19,20;
19:4,9,13; 20:12; 77:6,
19; 84:12; 115:25; 173:2,
4,20; 178:17; 179:3;
194:10,23; 198:12; 200:3,
5,7,15,16, 21,23; 201:5,
8,12,16, 21; 202:3, 5,9,
12,12,16
reviewed 201:3
reviewing 22:9
revise 66:23
revised 131:10
revisiting 216:12
revolves 226:8
rhetorical 219:23
Richard 15:13; 41:16
Richmond 109:25
ridden 228:16
ride 39:13; 43:3; 81:4;
85:23; 224:12
riding 237:14
right 12:12; 16:19; 42:15;
50:24; 55:8; 56:11; 60:14,
18; 62:3; 63:6; 65:2; 69:5;
70:4; 83:12; 85:9; 89:18;
91:3; 100:24; 101:16;
116:21; 127:16; 146:8, 25;
185:13; 187:5,6; 189:24;
206:13; 212:7
right-to-know 168:10;
203:11
rigorous 27:22; 81:13
rise 41:2; 212:20; 239:23
rising 89:2
Risk 44:8; 49:5; 105:7;
106:16; 127:8,11; 128:5;
161:15; 163:14,20; 164:2;
214:21
risking 161:18
risks 5:24; 147:24; 149:5;
150:12
RMR 147:6
road 67:7; 73:25; 74:14;
87:14; 96:9; 98:9; 111:24;
154:24; 160:16; 171:21;
190:4; 205:24; 207:12;
209:3; 210:16; 222:11;
229:25; 232:15; 234:5
roads 61:2; 111:14
Robert 12:8
robust 56:9; 145:19;
184:25; 185:18
rock 110:4
role 33:22; 37:21; 53:5;
181:21; 184:21
room 38:2; 61:13; 81:8;
106:13; 148:18; 164:22;
167:8,20; 203:19
rooms 89:10; 109:8;
150:18; 156:22; 230:20
rose 69:17
roughly 44:15; 85:12;
134:20
Route 64:11
row 68:25
RPR 147:8
ruin 40:13
ruining 40:19
rule 4:15,18; 6:5,6,9,16;
16:7,13, 21; 17:8; 19:5,7,
20; 22:12; 32:11; 42:2, 5;
44:21; 47:8; 50:11; 76:2;
77:7; 79:5,12; 80:8;
100:11; 103:4,12; 116:9;
131:7,14; 132:18,25;
161:3; 162:19,20; 165:4;
172:16; 173:6,10,14,15,
21,23; 174:15,18; 175:19;
176:17; 177:11,17,20;
178:8; 179:7,10; 182:12,
17; 183:11,16; 185:9;
186:7,25; 187:15; 191:3;
200:5,7; 201:13; 202:6,
10; 215:24; 216:2,17;
217:10,24; 218:3, 5,9,12;
222:23
rulemaking 16:2; 20:13;
32:3; 77:3; 79:22; 80:3;
114:10; 116:5,7; 117:15;
132:2,19,24; 137:12,15;
140:8; 172:12, 21, 25;
173:19; 184:14
rulemakings 77:13;
219:19
rules 7:12; 13:8; 16:3;
19:21; 21:18, 20; 46:6;
54:7; 79:19; 95:13; 141:7;
157:18; 176:20; 182:25;
185:13; 192:17; 231:20
ruling  132:14
run 17:19,20; 41:21;
175:22, 24; 176:2; 214:21;
226:9
running 85:18,23
rural 94:4,5
rushed 38:3; 213:2
SA 186:2
safe 210:10; 239:25
safeguards 155:10
Safety 44:6; 168:8,9;
203:9,12
sales 68:10; 76:9;
148:21; 239:23
Salt 68:25
Sam 65:18; 84:25; 85:1,
4; 86:1
same 9:19; 30:7; 33:4;
35:9; 42:23; 51:20; 61:10;
72:20; 73:15; 78:5; 85:8;
95:14; 107:18; 108:3;
122:9; 130:23; 136:22;
145:11,13; 153:19;
155:10; 158:7; 182:4;
186:17; 188:5,14; 197:21;
210:6; 214:4; 215:18;
217:18; 231:22
saying 52:21,24; 53:9;
57:3; 99:19; 101:9;
102:14; 112:17; 146:8
scale 197:18
scant 19:6
scared 91:20; 213:5
Schaeffer 156:5; 179:13,
14,15; 195:2,17
schedule 77:3; 139:8;
166:7
scheduled 65:23;
147:10; 220:13,17; 236:5
school 94:12; 112:20;
164:9,11; 224:9; 228:15
schools 228:4
Science 161:4
scientific 69:9; 137:16;
212:21
scope 5:18; 31:24;
194:12
seals 91:23
season 93:22; 156:24
seat 15:15; 66:5,5;
112:12
second 6:23; 7:3; 9:13;
10:14; 28:22; 45:4; 52:9;
54:22; 57:6; 72:17; 73:5;
79:2; 103:21; 138:13;
140:4; 141:22; 159:23;
170:23; 175:15; 191:25;
195:25; 208:13
second-prong 29:7
secondarily 25:6
Secondly 86:18; 159:7;
173:24
seconds 156:25
sect 188:5
Section  12:22; 174:20;
175:5,12,15
sections 173:16
sector 30:19; 134:25;
138:17; 188:3
sectors 187:14; 197:19
seeing 51:10; 53:17; 63:5
seem 174:16; 176:13
seems 58:21; 86:13,15;
101:17; 221:9
segment 18:12; 23:12;
80:16; 82:22
segregating 75:10
selected 200:22
Selective 175:17,22;
176:8
sell 239:17
semester 106:12
sends 42:17; 90:9; 109:7;
150:17; 156:21; 170:2;
230:19
senior 41:16
sense 47:4; 63:4; 106:24;
107:9; 166:12
sensitive 150:13; 211:12
sensors 185:24
separate 20:10, ll;
48:24; 78:4; 131:7
separated 20:11
SEPTA 237:25; 238:12
series 196:10; 201:15
serious 23:25; 26:5,21;
114:22; 154:15; 163:2;
169:22; 206:7; 226:22
seriously 98:15; 234:9
serve 161:6; 206:19;
214:14
serves 6:13; 169:12
service 76:4
serving 7:16
session  201:10,21
set 18:25; 29:18; 38:10;
48:24; 73:17; 89:15;
152:8; 154:18; 158:9;
165:15; 166:2; 200:5;
 Vincent Varallo Associates, Inc.
                            Min-U-Script®
                                                   (21)  required-set

-------
November 2,1999
                                                         Hearing
                                               Environmental Protection Agency Hearing
203:13; 205:14; 215:8;
232:5
setting 80:20; 95:22;
99:23; 187:2; 200:17
settlement 128:21;
157:20; 185:7,11
settling 31:15
seven 11:5; 31:16; 49:17;
157:20; 205:20
several 51:5; 102:21;
105:16; 106:4; 118:23;
127:22; 138:8; 157:19;
159:18; 161:25; 162:19;
165:5; 172:13; 173:22;
175:19; 177:15,21
severe 5:5; 69:24; 210:3;
228:9
severity 82:19
SFTP 81:24
shaft 211:17
share 41:10; 149:2;
177:7; 182:8; 183:15;
187:12; 205:2; 222:18;
224:8,14
shared 67:7,7
Shenandoah 110:7,9
shift 227:7
shining 151:22
shirt 223:6
short 19:4; 31:24; 36:8;
109:12; 150:20; 157:3;
230:24
shortages 228:5
shortchanged 177:6,10
shortchanges 19:20
shortcoming 154:15
show 24:12; 65:14;
 159:19; 162:21; 164:5,17;
 196:19
shown 76:14; 88:23;
 126:18; 127:12; 135:8;
 158:22; 174:20
 shows 45:11; 127:6,18;
 204:12
 shrinking 210:8
 shrubbery 210:15
 shuttle 81:10; 103:9
 sic 9:12; 58:9
 sick91:ll
 sickened 148:11
 side 47:2
 Sierra 66:2; 87:1; 88:1,4;
 89:1,12; 90:1,8
 sight 163:12
 sign 14:19; 46:5; 51:9;
 55:7; 236:10
 signal 42:18; 43:2
 signatories 51:17,20;
 113:14
 signed 8:4; 14:14; 16:4;
 50:23; 51:12,20,21,23;
 199:24; 202:18; 218:20
 significant 4:18; 7:25;
 17:3; 20:18; 23:13; 24:7;
 26:16; 31:13; 32:5; 36:11;
45:22; 55:23; 82:13;
119:22; 120:13; 121:2,15;
124:2; 125:19; 126:2;
127:10; 129:4; 134:17;
137:8; 150:25; 153:17;
163:9; 165:12; 181:19;
182:6; 200:13
significantly 8:25; 9:16;
17:6,14; 35:18; 132:10;
151:17; 188:18; 199:20
signing 52:13
similar 27:16; 44:4,9;
102:11; 129:14; 132:18;
199:6
similar-type 123:6
simple 67:9; 100:19
simplest 36:16
simplified 178:12
simplify 193:2
simply 21:18; 36:23;
43:12; 52:2; 100:14;
161:17; 167:18
simultaneously 78:20
Singer 198:3
Sinker 202:1,24,25;
203:1,2; 204:1; 205:1
SIP 59:11; 130:7
site 15:7; 173:3; 215:21
sitting 4:7; 64:12; 87:24;
194:19; 235:11
situation 52:19; 70:12
situations 105:20
six 134:6; 181:10
size 80:13; 159:14;
170:22
sizes 179:23
skip 38:4
skipped 201:11
slide 127:18
slides 127:12; 130:8
small 25:20; 40:14; 58:7;
159:9; 174:16; 208:11
smaller 6:11; 26:4; 96:16;
 152:22; 170:17; 208:7;
232:20
smell 61:6; 107:10
smog 4:23; 35:5; 61:18,
21; 64:13; 65:6; 68:12, 21;
69:13,15; 93:22; 107:14,
 16; 109:19; 111:21; 148:6,
 16,20; 149:2,20; 156:24;
 157:23; 161:25; 169:12,
 25; 170:2,6; 223:23;
 224:17,18
 smog-forming 95:17;
 171:9; 206:8; 208:17;
 231:24
 smoke 151:8; 180:22;
 181:12; 235:12
 soccer 37:20,23; 38:4
 Societies 210:24
 Society 209:18; 213:22
 Society's 210:22
 sold 139:2
 solution 74:16; 121:20;
162:4
solutions 124:10
solve 56:22
somebody 222:19,19;
223:3,4
someone 223:2
someone's 223:5
sometimes 55:17; 69:23;
74:7;91:15
somewhat 32:10; 85:16;
108:18; 191:12
son 37:22; 213:2
soon 30:6; 87:3; 97:14;
121:2; 159:17; 162:6;
171:8; 194:22; 206:7;
233:14
sooner 64:10; 65:12;
66:24; 71:24; 83:5; 166:18
soot 34:23; 204:13;
237:22
SOP 16:21; 19:9; 113:13,
14,21,23:114:6,11,16,
22; 115:5,18; 116:14,17,
21,23; 117:3,8; 199:17;
200:4,6; 202:18; 216:8,
11,17; 219:18
sort 52:10,18; 59:13;
90:23; 105:12,19; 194:11;
196:13; 222:18
sound 78:22; 91:22
sounds 102:14
source 5:11; 23:13;
74:19,22; 126:16; 134:2;
150:25; 226:15; 237:10
Sources 7:15; 12:13;
24:10,13; 25:3,10; 31:6;
58:16; 67:25; 70:2;
110:17; 126:14,14,17;
127:21; 135:3; 151:9;
163:9; 189:12; 206:21,24;
207:8; 237:23
South 44:13; 126:9,17
Southeastern 35:17,22;
36:9
southern 169:19
Sowell 220:14,24; 221:1,
2,3; 222:1
space 138:14; 139:10;
210:9
span 140:18
spared 221:12
speak 14:22; 34:14;
36:18; 58:23; 60:19;
63:24; 75:25; 87:20;
98:22; 108:20,23; 112:2;
143:2; 147:17; 160:21;
191:15; 196:6; 206:18;
209:13,17; 230:5; 234:17;
235:8; 236:17
speaking 216:2; 235:18
special 101:20; 163:14
specialist 161:7
specialty 103:2
species 211:6,20; 212:5;
214:23
specific 12:2; 123:20;
125:3; 128:9; 139:20;
175:6; 183:16; 186:4;
196:16; 197:22
Specifically 86:8; 96:10;
111:15; 148:7; 152:17;
158:17; 188:8; 192:5;
232:15
specifications 183:19
specified 175:24
spell 236:19
spend 168:12; 191:11;
226:17
spenders 12:3
spending 105:8
spent 55:11; 106:12;
166:15; 222:21; 229:9
spirit 224:21
spoken 223:8
sport 6:11; 209:22
sport-utility 4:16; 6:21;
8:15; 32:22; 42:22; 62:4,
25; 63:9; 66:16; 80:24
spot 142:18
sprawl 105:20; 210:10
stability 16:9,22,24;
17:8; 22:2; 77:23; 78:4,6,
16; 84:4; 99:20; 113:22,
24; 114:2,6; 199:22
staff 84:22; 127:23;
129:10; 190:18; 194:20
stake 197:14; 240:6
stakeholders 177:14;
186:24
stand 13:15; 46:8; 61:5;
65:12; 166:4; 236:7
standard 5:2,6,13,13,
17; 6:25; 24:24; 33:24;
38:20, 24; 40:6; 44:25;
45:2,8,13; 46:10; 48:20;
50:11; 53:6; 57:13; 68:16;
69:4,11; 71:2; 72:12,19;
78:7,14; 90:17; 93:24;
96:23; 119:21,25; 120:2;
126:9; 128:17,23; 129:17,
20; 132:11; 133:19; 136:3,
5,11,13,18,22,24;
137:7; 143:23,25; 144:10,
12; 146:5; 153:8; 154:18,
20; 158:11,21; 163:7;
165:20; 166:2; 168:25;
169:5; 170:24; 175:11;
181:2,15; 182:25; 183:7,
9,11,12,22; 187:9; 189:3,
4; 195:24; 196:7,8,24;
203:23; 204:3,7; 205:4,
11; 216:9; 222:2; 229:21,
22; 233:3; 239:5
standards 8:17,19,19,
21; 9:5,7,8,15; 10:7,9,
10,11,13,14; 11:10, 22;
12:4; 16:10,14,15,17,20;
17:2,7,7,10,13,15; 18:2,
7,9; 21:8; 27:8,21,24;
28:3,5,8,10,15,18,20,
23; 29:2,6,18,19; 30:7,
17; 32:23; 33:4,8; 34:19,
22; 35:2,4,9,10; 36:14,
20; 38:10; 39:20; 40:7;
42:24; 44:22; 45:18,24;
46:25; 48:22; 50:9,16;
53:18; 57:5,15,23; 58:8;
61:21; 62:7,14; 63:12,21;
66:15; 67:23; 72:10;
73:17; 74:20,22; 77:24;
78:3, 5,12,18,21; 80:20;
81:17; 82:9,19; 83:25;
84:6; 86:7,17,19,25;
89:15,17; 90:2,6; 95:23,
25; 96:7,17, 21; 97:12;
98:15; 99:21; 103:25;
107:20,25; 108:21;
109:20; 111:13,20, 21;
113:10, 25; 114:8,10;
115:4,7,13,19,23;
116:15,16; 117:20; 119:4,
12,14; 120:5,8,16,23;
121:6,13,18; 122:2,4,13,
21; 123:14; 125:16; 126:6,
12; 128:4,6,10,11,20;
129:5,6,12; 130:5,9;
133:7,19; 135:16; 137:5,
13,16; 138:3, 5,7,25;
139:4,13,18; 140:10,15;
141:2,19; 142:10,24;
143:18,25; 146:17;
149:17,18; 150:11;
151:12,13; 152:8,11,16,
23; 153:3,5,10,14;
154:17; 158:2,7,9,16;
159:10,13,14,15,21,24;
160:2,14; 162:4,8,10,14;
165:10,14,18; 166:6,  22;
170:18, 22; 171:6,12;
172:20; 174:8; 178:23;
179:20; 180:19,25; 181:5;
183:15,19; 184:22; 186:2,
3,8; 187:4; 188:12,23;
195:12,13; 196:18;
197:19; 199:23; 200:6,8,
12,18; 201:6; 203:14;
205:8,14; 206:5,10;
208:8,12,14,20; 210:3;
214:5,18; 216:13; 219:20;
221:25; 224:25; 232:5,8,
14,21, 25; 233:12; 234:10;
235:23:239:2
standpoint 101:5
STAPPA 22:21; 27:7,25;
29:10,25:32:20
start 6:12; 15:9,19; 53:5;
65:21; 112:15; 156:7;
157:14; 198:5; 220:24;
236:24
started 201:9
starting 32:16; 40:24;
46:13
state 13:24; 15:17; 22:21;
23:8; 27:13; 37:8; 50:21,
22; 57:7,18,18,19; 61:9;
64:6; 71:14; 93:17, 22;
125:10,15;126:12;
128:21; 130:16; 156:12;
164:6; 168:14, 21; 169:18,
20; 172:18; 173:19;
179:25; 180:23; 189:19,
20,22,25; 198:17; 204:15;
219:15; 230:11; 234:21;
 setting - state  (22)
                             Min-U-Script®
                                    Vincent Varallo Associates, Inc.

-------
Environmental Protection Agency Hearing
                                                         Hearing
                                                                             November 2,1999
236:15,19; 238:17
state-wide 125:20
stated 82:7; 117:14;
195:8
statement 13:14; 14:6,
24; 15:8; 16:4; 29:23; 42:5,
6; 49:13; 50:5; 52:4; 57:2;
103:22; 113:12; 198:15;
199:17,23
statement's 128:7
statements 13:11,25;
14:11; 99:2; 190:9
states 22:25; 33:16; 35:5;
57:11, 24; 60:23; 68:14,
24; 90:13,24;  100:23;
113:23; 134:3,6,6,16;
135:6; 136:2,9; 137:4,14;
138:6,23; 139:14; 140:7,
16; 156:14; 175:16;
181:12; 182:2; 189:23;
225:18; 226:17; 227:6;
229:15
static 52:10,19
stating 52:25; 172:17
stationary 198:10;
206:21
statistics 65:8; 143:18
status 52:18; 57:12
statutorily 19:12
stay 87:13,15; 98:8,18;
 111:23; 154:24; 155:11;
 160:16; 171:20,23; 206:4;
 209:3; 222:10; 229:24;
 234:5,12; 236:4,6
 stayed 69:6
 staying 184:24
 steady-state 174:24;
 175:10,12; 177:23
 steal 108:9
 steeply 164:14
 Step 6:6; 7:25; 30:4; 41:7;
 42:11; 45:4; 55:15; 67:12;
 83:12; 118:15; 135:14;
 147:13; 155:18
 steps 24:25; 43:6; 48:3,
 18; 139:19; 152:3; 166:19;
 176:25; 199:3; 201:11
 Stewart 156:5; 160:23,
 24; 161:4
 stiffer81:3
 still 38:21; 54:17; 59:18,
 19; 71:18; 124:21; 125:15;
 126:6; 127:10; 151:7,10;
 192:13; 203:24; 212:19;
 217:15; 218:6
 stood 42:14
 stop 49:10; 91:9
 story 212:25; 238:24;
 239:14
 straight 215:9
 straightforward 221:14
 strategies 31:3; 58:18;
  122:9; 133:14; 226:5
  strategy 6:10,23; 29:8;
  31:8; 153:24; 154:16;
  159:23; 165:25; 204:20
streamline 215:25
streams 211:23
streets 109:22; 224:8
strengthen 59:22; 60:3;
86:10; 96:11; 111:16;
152:18; 158:19; 170:14;
232:16
strengthened 120:2;
161:24; 165:6
strengthening 34:8;
229:13,19
stress 80:9; 122:19;
155:21
stresses 211:10,12
strict 36:21; 72:19; 89:16;
95:13, 24; 154:19; 157:18;
158:11; 231:20; 232:7
stricter 34:19; 152:11;
166:2,4
strides 20:18; 125:19;
126:5
strike 13:11
striking 239:9
stringency 17:6,14;
115:3; 116:14; 174:2,4;
176:16; 179:8; 200:12
stringent 6:25; 9:15;
16:10; 18:8; 27:21; 28:4,9,
14,18, 22; 29:2; 30:16;
42:23; 58:4; 59:24; 60:7;
81:16; 83:25; 107:25;
120:7; 129:6; 137:5;
143:25; 149:18; 162:3;
181:4; 183:6; 199:23;
200:7; 214:4; 216:14,15
strive 162:21
striving 228:13
strong 32:12; 42:17,17;
46:18; 48:11; 63:20;
86:24; 97:11; 99:2;
 111:21; 154:17; 159:15;
 162:10; 168:7; 199:8;
 203:9; 206:5; 215:9;
 233:12
 stronger 149:17; 171:6;
 208:3
 strongly 28:15; 32:10,
 20; 44:24; 45:15; 47:15,
 16; 59:7; 66:12,17;
 138:23; 139:14; 140:7;
 141:3; 194:17; 196:6
 structural 80:13
 struggle 76:21; 161:12
 stuck 61:5,8
 student 164:12; 238:24
 studies 29:17; 70:17,21;
 88:23; 95:5; 106:10;
 111:2; 157:11; 159:18;
 164:17; 207:17; 212:21;
 231:14
 study 72:6,20; 109:10;
 169:25; 179:4; 230:22
 studying  192:13
 subject 8:12; 15:25; 30:7;
 33:4; 73:13; 172:13;
 185:15
subjected 81:14
subjecting 32:21
subjective 81:8; 84:13;
102:9,14
submissions 139:5
submit 14:15; 22:10;
119:9; 135:21; 206:13
submits 116:20
submitted  133:5; 162:18
submitting 125:7;
220:20
Subpart 175:18,20
subsequent 19:14; 32:2
subset 10:22
substances 95:5;
110:25; 157:11; 231:13
substandard 228:6
substantial 26:19;
118:21; 129:8; 140:21;
167:5,7; 174:5; 176:15;
191:18; 212:8; 213:12
substantially 21:9;
28:18; 67:16; 118:16;
135:18; 191:9; 199:13;
212:16; 239:6
suburban 94:3
suburbs 106:6
success 80:17; 126:3
successful 29:6; 57:14;
225:17
successfully 184:13
suffer 89:7; 94:9; 163:25;
164:4; 207:6; 228:4;
229:11; 237:7
sufferer 88:2; 235:8,19
sufferers 69:20; 148:8
suffering 38:17; 163:13;
170:6; 228:9
sufficient 42:4; 82:3
sufficiently 177:3
suffocating 23:23
suggest 70:17; 193:8;
236:8
suggested 50:6; 57:4;
216:8
suggesting 50:12,18,
21; 115:6; 142:17; 192:23,
25; 193:11
suggestion 79:19
suggestions 34:8
suggests  148:25
sulfur 7:4,7; 9:19; 21:4,
6,7,10; 22:5; 27:9,22;
 29:13,18,22; 30:2,4,7,8;
40:6; 48:11,18; 49:7;
66:18; 72:11,25; 73:17,
 19; 82:12,23; 84:18; 87:9,
 12; 97:22; 98:4, 5; 104:7,
 11; 117:16; 119:2; 120:12;
 121:5; 135:17; 137:12;
 140:25; 146:20; 149:8;
 153:21,22; 154:14; 160:7,
 11,13; 166:10,13,17;
 171:17,19; 174:9; 180:21;
 188:18; 196:4; 205:15,18;
208:24,25; 222:7; 225:2;
233:21,25; 234:3; 235:20
Sulfur-free 83:15
sulfur-in-fuel73:2
summarize 56:5; 119:7;
125:4; 135:20
summary 133:6; 140:16;
202:14
summer 61:17,23;
62:22; 88:12,15; 89:8;
91:13,17; 93:22; 106:7;
109:20; 112:19; 156:24;
158:2; 169:7, 21; 170:4,8;
204:6
summers 68:19,25
Sunday 181:13; 195:21
super 103:8
super-large 6:15
supplemental 17:13;
42:7; 45:24; 54:23; 55:5;
56:8; 130:5; 141:15,18;
174:10, 23; 175:12; 176:2;
178:24; 192:3,6; 216:19
supplementary 175:19,
21,23; 177:23
supplementing 42:5
supplies 211:24
supply 226:14
support 32:20; 44:24;
45:15; 46:3,24; 47:15,16;
55:4; 66:17;76:10; 118:9;
122:25; 123:10; 136:2;
138:23; 139:14; 140:16;
150:7; 155:16; 158:2;
165:9; 180:21,22,24;
183:23; 185:25; 196:7,7;
238:25
supported 26:14; 56:17;
180:20; 186:7; 196:18
supporting 69:10;
180:19; 181:14; 204:20
supports 66:12; 128:16;
132:12; 133:6; 163:9;
172:19; 226:4
supposed 62:19; 145:23
sure 34:3; 53:13; 55:23;
56:6; 62:6; 63:11,13;
101:23; 103:9; 145:19;
147:2; 162:13; 184:24;
191:6; 222:16
Surely 177:16
surgery 88:13
surrounded 228:3
surrounding 168:17;
211:23
Survey 35:16
Susan 60:13; 64:4
suspect 92:19; 196:15
suspenders 178:6
sustain  27:14
SUV 36:19; 47:13; 86:12;
95:21; 96:14; 108:6;
 111:18; 158:3; 159:8;
 170:16; 204:24; 208:5;
214:3; 221:23; 225:3;
229:8, 20; 232:3,19;
239:3,7,23
SUVs 6:15; 9:8; 33:5,8;
35:8,11; 47:17,22; 63:3;
68:9; 86:15; 89:14,20;
93:13; 95:21; 96:16,20;
102:25; 103:5; 108:2;
109:6; 114:13; 115:16,21;
116:18; 148:22; 152:4,6,
22; 153:2; 156:18; 158:4,
7; 159:9; 165:15; 169:11,
16; 170:17,21; 204:24;
205:2; 208:7,10; 212:3;
221:6; 223:24; 224:9;
227:23; 228:22; 229:3;
230:16; 232:4, 20,24;
239:3,4
Suzanne 64:1; 65:1; 66:1
swim 88:16,17; 91:17,
18,21
switching 188:17
Symposium 127:13
symptoms 164:19,21;
212:15
system 214:11; 239:6
systems 11:17; 21:15;
23:11; 27:19; 28:2; 31:18;
40:19; 83:17; 84:15;
97:19; 120:10,17; 122:14,
20,25;  123:2,15; 160:5;
171:14; 184:25; 185:18;
208:22; 233:19
table 14:16; 59:10
tailpipe 6:10; 224:15
tailpipes 224:11
talk 48:3; 104:10; 156:16;
188:22; 190:2; 223:25
talked 144:18; 217:4
talking 45:5; 49:10;
144:18; 187:17
tapped 58:5
targets  114:18; 120:24;
121:11
task 118:24; 167:12;
173:6; 195:25; 203:17
tax 105:19
team 91:18
technical I6:l6;50:4;
56:10; 134:8; 138:8;
139:7; 143:20; 145:8;
146:7; 176:14; 191:7,14;
196:13; 198:12; 200:3,13,
15, 20; 201:7,11,16,20;
202:3
technically 136:5;
182:13
technological 10:6,10;
30:15; 86:13; 96:18;
122:5; 135:24; 143:12;
152:24; 232:22
technologically 40:16;
115:18; 119:12; 132:17;
137:5; 145:11
technologies 7:5; 20:23;
 Vincent Varallo Associates, Inc.
                             Min-U-Script®
                                     (23)  state-wide - technologies

-------
November 2,1999
                                                         Hearing
                                                Environmental Protection Agency Hearing
21:4,16; 293; 45:12;
73:18,24; 84:17; 86:23;
95:9; 111:4; 117:17;
119:16,19; 121:22;
129:21; 145:10,13;
151:16; 157:15; 159:20;
160:9; 166:16; 184:10;
186:17; 199:11; 207:22;
226:11;231:17
technology 21:19; 63:6;
72:8,16; 75:3; 76:12; 83:2,
14; 86:20; 89:21; 97:2,25;
108:9; 115:21; 118:13;
121:8,20; 127:13; 128:24;
129:4; 136:7; 138:21;
158:23; 162:6; 165:8;
166:9; 178:4; 180:14,16;
200:17; 207:19; 213:11;
224:23; 233:5,23
technology's 28:24
temperatures 138:11
ten 13:20; 62:24; 64:18,
19; 86:14; 89:4
tenacious 196:25
tenants 227:20
tend 37:15; 222:18
tends 154:13; 169:17
tens 114:17; 164:20
term 116:13; 219:22
termed 44:2
terms 85:21; 135:23;
 136:8; 138:2; 186:13;
 197:5; 215:10; 217:16
Territorial 22:22
territories 23:2
terrorists 222:24
testll:2;.17:3,13,17;
45:24; 46:2; 55:5;  56:8;
73:13; 81:22; 114:9;
 116:16; 123:10,11,17;
 128:11; 130:5,10,13,17,
 22; 131:9; 141:15; 174:3,
 10,24; 175:8,10,12,18,
 20,25; 177:23; 178:10,24;
 185:8; 192:3,22; 216:20
 tested 175:17
 testified 158:22; 189:14;
 238:22
 testify 13:19,22; 14:14,
 18,20; 34:6; 87:21; .-
 147:10,12; 148:2; 197:25;
 220:13; 235:17; 238:25;
 240:9
 testifying 45:14; 60:11;
 220:22
 testimony 7:10,21; 14:4;
 23:5; 38:8; 84:21; 92:24;
 103:8; 117:24; 118:9;
 134:11
 testing 31:22; 36:21;
 46:18; 47:3; 73:16; 87:15;
 98:16,18; 107:14; 111:24;
 115:2,10; 116:24; 117:10;
 139:17; 140:11; 141:18;
 142:9; 146:5; 155:12;
 160:17; 166:24; 171:23;
 175:17; 177:21,25;
178:18; 186:21; 189:3;
191:10; 197:3; 205:25;
209:4; 222:11; 234:11,12
tests 54:24; 89:16; 95:16,
24; 98:10; 142:11; 155:2;
157:22; 158:11; 171:21;
175:22, 23; 176:2; 205:23;
231:23; 232:7; 234:5
Texas 90:12,18
textbook 228:5
thanks 63:23; 65:13;
143:6; 179:18; 190:9;
193:19; 225:19
theirs 21:13
thereby 152:12
Therefore 80:23; 117:7,
19; 158:5; 200:14
thick 23:22; 151:8
thier 225:21
thinking 63:16; 107:7;
202:7
Third 10:20; 28:25; 31:7;
86:24; 97:11; 138:18;
140:5; 159:15; 171:6;
208:17
though 46:17; 48:17;
122:14; 175:10; 186:10;
218:22; 221:20
thought 75:20; 103:4;
144:18; 167:16; 212:24;
218:5
thousand 230:25
thousands 35:12; 36:9;
97:10; 109:13; 154:25;
159:6; 162:5; 164:19,20,
21,22; 167:7,9; 171:5;
233:11; 237:9; 240:4
threat 23:25; 26:6; 48:9;
71:4; 150:8; 151:16;
169:23; 221:14
threatened 19:23
threatens 207:5,15
threats 70:6; 151:5;
226:22
three 24:7; 27:20; 28:15;
60:10; 61:18; 76:22; 78:4;
83:23; 100:13; 104:17;
105:8; 116:15; 130:6;
 139:20; 148:24; 150:9;
 151:11,21; 156:25; 158:4;
 173:18; 197:10; 202:17;
204:25; 205:14
three-prong 28:2
three-way 138:9,17,19;
 139:9
three-year 78:6
throat 224:15; 237:14
throughout 40:18; 96:8;
 111:14; 147:21; 155:5;
 158:17; 168:14; 179:24;
 185:2; 211:5; 227:9;
 232:14
thruway 169:13
 Thursday 13:5
 Thus 48:10; 71:25;  114:9;
 129:13; 130:25; 132:12,
24; 138:15; 175:2; 176:23
Tier 6:9,18; 7:7,20; 8:19;
10:24; 12:4; 27:8; 32:23;
33:7; 47:16; 76:15; 77:13;
79:5,12,19, 22; 80:3,8;
81:16,20; 82:14,19;
96:15; 100:11; 103:12;
112:18; 115:15,23;
117:15; 120:22; 122:2,3,
13; 128:13; 131:23; 132:5;
133:11; 138:24; 139:4,13;
152:5,21; 153:16; 158:7;
159:8; 165:16; 170:16;
205:5; 208:6; 212:25;
232:19
tight 27:21; 91:20
tighten 16:20; 63:12;
72:12; 86:19; 108:21;
111:19; 153:4; 170:23;
205:7; 222:2; 223:14
tightened 96:23; 158:21;
165:20; 208:14
tightening 36:19; 40:5;
120:2; 224:24; 229:22
tighter 107:14; 108:11;
119:4; 205:11, 24
Tim 60:17
time-honored 40:10
timely 19:8,14; 32:7;
137:23
timer 88:15
times 38:24; 70:19; 81:2;
89:14; 91:25; 95:22;
108:7; 148:24; 152:6;
154:10; 158:4; 190:17,22;
191:5; 204:4,4, 5, 25;
215:20; 228:20; 232:4
timetable 47:24; 116:4,6,
11
timing 28:13; 195:14
Timothy 60:1,12; 61:1;
62:1; 63:1
today 7:10,21,24; 9:24;
10:4; 12:17,19; 14:5;
15:21; 18:24; 19:24; 21:9;
23:18; 34:18; 37:9; 39:7,
20; 40:8;  41:6,23; 42:6,6;
45:5; 46:8; 51:6; 67:23;
68:10; 73:25; 74:14;
75:25; 76:22; 83:23;
87:20; 89:21; 94:22;
104:24; 119:7; 128:9;
137:20; 148:5; 150:4;
151:17; 153:6; 161:8;
162:16; 163:23; 179:19;
180:4,10,10,11,11,24;
181:23; 182:10; 183:2;
184:5,18; 186:19; 187:21;
188:15,22,24; 191:23;
192:7; 194:7,21; 195:11;
200:10,25; 201:21;
204:14,22; 206:18;
207:12; 209:13,25;
210:23; 214:10; 221:7;
229:4; 231:7; 235:17;
238:24; 240:8
Today's 5:10; 6:13,19;
7:16; 8:3,12; 9:10,11;
10:16; 15:25; 16:23;
48:23; 51:16,23; 52:2;
74:13; 172:13; 181:17;
199:13; 213:22
together 56:21; 134:19;
141:6; 190:18; 236:9
told 49:9; 143:3; 212:25;
220:16
tolerance 238:3
toll 106:22; 109:18;
148:12; 156:20; 168:22;  .
230:18
tons 24:13,14; 25:11;
61:2,2; 95:18; 157:23;
231:25; 235:12,12
took 39:8
top 65:5; 80:2; 115:9;
142:10; 187:11; 195:20;
215:22
topic 93:3; 187:7
topics 83:23
total 35:21; 70:3; 75:7;
126:21; 127:11; 168:25;
182:4; 210:5
touch  194:18
tough  35:3; 152:8; 158:7,
9; 235:18
tougher 6:10; 95:23;
146:6; 153:8; 158:2;
214:17; 235:23
toughest 34:25
tow 80:25
toward 33:2; 189:24,25;
210:18
towards 7:25; 43:4;
118:16
town 61:19; 62:2
towns 221:8
toxic 24:9; 26:6,8,13;
43:15; 44:2,11; 70:6; 95:4;
110:25; 119:22; 120:14,
19; 147:24; 150:12;
157:10; 204:16; 210:16;
231:13
toxicants 26:10
toxics 127:9; 150:25;
163:11; 165:13; 207:18
toxins 127:8; 135:10
trade 179:21
tradename 113:6
traffic 61:9,25; 64:12;
146:22,22; 169:13,19
trains 188:16
transcript 15:3,6
transfer 129:3; 138:21
transferred 129:2
transformed 25:8
transgressions 32:14
transient 142:11; 144:8,
15; 175:7
Transit 237:2,3,16,25;
238:3,4,12
transport 122:12,15
transportation 10:23;
33:3; 79:9; 81:7; 84:11;
131:23; 132:6; 133:9;
214:11; 224:7; 226:8;
238:11
transported 169:17
travel 27:3; 103:9; 154:25
traveled 68:7; 125:25
traveling 169:13
treatment 67:10; 83:3;
89:5; 135:7
trees 210:15; 211:24
tremendous 25:16; 27:9;
58:25; 116:25; 142:12
trend 32:25; 68:2; 210:18
trends 204:12
triggered 61:14
triggers 94:13; 221:10,
15
trip 161:18
Trips 167:19
trouble 107:10
troubling 84:15
truck 67:6; 74:20; 76:3,
24; 79:4; 81:6,13,15;
84:10,14; 90:5; 98:13;
132:8; 134:13; 136:23;
139:11; 151:12; 180:12;
181:17,20; 201:18; 234:8;
235:11,14
Trucking 179:17,22,24;
180:2,8,17; 181:6,16;
182:7; 183:13; 187:11;
188:7,9; 189:21; 190:3;
195:20; 197:8
trucks 4:16; 6:11,14,20;
7:2,6; 8:13,14,22; 9:7,9,
10,11,18; 10:21; 23:23;
32:19; 33:2,9; 36:22;
39:13; 40:20; 47:18; 49:8;
54:13; 61:4, 5; 62:8; 64:13;
66:13,16; 67:4,6; 73:22,
24; 74:4,6,13,13; 75:3;
79:24; 80:10,11,23;
86:22; 87:13,15,17;
88:20; 89:15; 91:9; 93:13;
94:16; 95:8, 23; 96:7; 97:4,
7; 98:8,17,20; 102:8,13;
103:5; 108:12; 109:6;
110:15; 111:4,13, 23;
113:5; 119:15; 121:24;
122:10; 136:21; 137:19;
138:13; 139:12; 148:21;
149:11; 150:6; 151:2,8,
18, 24; 152:3,8,15;
153:10,25; 154:23;
155:10,11,13; 157:14;
158:16,24; 159:4; 160:16,
18; 169:10,16; 171:3,20,
23, 25; 180:5; 187:23,24;
188:20; 204:8,12; 206:3,
4; 207:9,11; 209:2,6,24;
210:14; 214:7; 221:6;
222:9; 223:23; 224:8;
225:22; 227:22; 229:24;
230:16; 231:2,16; 232:6,
13; 233:6,10; 234:4,12,
14
true 98:11; 153:19;
171:22; 234:6
 technology - true  (24)
                             Min-U'Script®
                                     Vincent Varallo Associates, Inc.

-------
                                                             Hearing
Environmental Protection Agency Hearing
                                                                             November 2,1999
truly 26:25; 40:22; 97:20;
142:13; 160:5; 171:14;
208:22; 233:19
Trust 168:2,3,7; 170:10;
203:3,4
truth 142:4; 147:2
try 13:19; 196:13,14;
236:8
trying 36:14,15; 99:16;
100:3,15; 102:22; 103:14;
173:4; 197:3; 215:18
Tsou 15:14; 34:1,12,13,
15; 35:1; 36:1
tuberculosis 161:21
tune 186:12
turbo 186:17
turn 31:7; 74:15; 210:12
Turning  120:4
Turnpike 61:3; 62:2
two 15:7; 22:24; 32:18;
46:13; 51:25; 58:13;
68:19, 25; 73:20; 91:17,
25; 96:19; 102:6;  105:8;
116:14; 124:19; 127:12;
130:8;  141:4; 143:22;
147:9; 152:25; 159:12;
163:21; 192:12; 195:2,16;
197:10; 201:23; 205:7;
207:5; 226:10; 232:23
two-phased 9:4
two-prong 195:22
two-step 6:7
two-third 24:18
two-thirds 154:18
type 122:9; 213:24
types 119:19; 121:21;
142:24; 179:23
typical 201:13; 239:20
typically 202:9
           u
 U.S 70:25; 125:4; 127:23;
 129:11; 131:12; 132:14;
 133:18; 156:11
 ubiquitous 27:4
 ULEV 187:22
 ultimate 82:25
 ultimately 223:11
 ultra 112:23
 unable 167:18; 176:23
 unacceptable 33:21
 unaddressed 59:10
 unambiguous 177:9
 unanticipated 201:16
 unbelievably 19:4
 uncertainty 177:11
 unclear 17:18; 173:21;
 176:20; 177:20; 212:7
 unconscionable 45:20
 unconscionably 48:6
 uncontainable 80:6
 uncontrolled 151:10;
154:3
under 7:7; 8:17; 10:24;
11:10; 16:15; 35:20, 23,
25; 46:6; 49:21; 50:6,12,
13,16; 52:15; 57:25; 89:4;
96:15; 100:11; 103:11,12,
15; 113:5,12; 115:5,17;
138:12; 139:8; 141:18, 20;
148:10; 152:21; 159:8;
164:7; 165:24; 166:6;
170:16,19; 173:23; 185:6,
7; 192:7,17; 205:4; 208:6,
8; 219:18; 232:19
undergo 88:13
undergoing 74:8
underlie 28:16
undermined 98:15;
234:10
underpinnings 196:2
understands 34:4
understood 174:2; 185:8
undertaken 18:20
underway 127:25
unduly 39:18
unequal 67:2
unfeasible 142:20
unflinchingly 167:15
Unfortunately 98:10;
169:15; 172:24; 188:13;
207:11; 220:2
unhealthful 38:22;
163:4,6; 203:25
unhealthy 68:12,21;
69:8,13; 94:6; 109:21;
125:17; 169:2
uniform 66:14; 195:23
unintelligible 99:21
unique 80:10; 229:17
United 35:5; 60:22;
68:14; 90:12,24; 135:6;
182:2; 225:17; 226:16;
227:6; 229:15
University 106:11; 161:5
unless 142:5; 149:13,16;
176:25
Unlike 74:4
unnecessarily 96:4;
152:12; 158:13; 232:10
unnoticed 98:13; 234:8
unplanned 161:18
unprecedented 115:11;
215:19
unproven 184:25
unrealistic 77:3,9
unreasonable 40:11
unregulated 189:11
unrelated 201:15
unsafe 110:12
unstable 226:19
unthinkable 21:2
untimely 224:18
unworkable 100:14;
 116:11
up 8:16; 13:16; 14:14,22;
16:2; 26:2; 36:20; 38:15;
44:12; 45:2; 48:22; 50:25;
51:4; 57:25; 60:12; 62:13,
24; 63:3,7,21,22; 64:7;
65:18; 70:2; 79:10; 86:2,
14; 87:7; 89:14,19, 24;
95:21; 96:19; 97:19;
101:16; 103:6; 107:19;
108:22; 111:7,22; 118:11;
122:2,10,12; 138:25;
139:12,12; 150:14,22;
151:22, 24; 152:6,25;
153:15,20; 160:4; 170:5,
6,11,20; 171:13; 187:12,
21; 188:3; 194:6; 206:25;
207:20, 24; 208:10,21;
209:8,10; 222:6; 224:22;
229:23; 232:4,23; 233:18;
236:7
upcoming 195:9
upon 29:13; 59:22; 67:3;
95:11; 115:5; 148:5,12;
157:16; 231:18
upper 35:24
upward 68:2
urban 9:2; 24:2; 48:7;
70:11; 94:2, 24; 110:20;
128:4; 136:16; 148:13;
153:7; 157:6; 204:11;
224:3; 231:9
urbanization 235:4
urge 27:16; 28:15; 31:2;
32:10; 47:7,23; 48:17;
66:22; 75:14; 85:11; 86:8,
18,24; 90:4; 96:10;
107:25; 108:11; 111:15;
137:14; 141:3; 152:17;
155:18; 188:23; 207:25;
208:4; 232:15
urged 33:7
urgent 87:2; 97:13;
159:17; 171:8; 233:14
urges 46:16; 140:7
urging 39:10; 181:11;
224:20
USA 212:20
use 27:24; 31:10,19;
33:2; 69:6; 73:21,23; 75:5,
20; 80:15,  23; 81:13;
82:20; 83:13; 91:25; 95:8;
97:24; 104:12; 111:4;
134:4; 135:4,8; 136:19,
23; 140:15; 160:8; 162:15;
163:9; 183:4; 184:21;
188:14; 201:7; 202:11;
207:10, 22; 209:4; 214:7,
12; 219:22; 224:6,22;
225:12; 227:10; 231:16;
233:22
used 15:24; 91:24;
122:10; 131:22; 132:5;
140:2; 162:12; 166:9;
172:11; 174:21; 175:3;
176:2; 198:9; 211:4,13;
215:9; 219:16
useful 74:5,18; 113:10;
158:17; 174:10; 178:24;
184:15; 189:8
user 185:21
users 98:14; 180:4;
182:20; 183:22; 184:2,17,
18; 186:23; 195:24; 196:8;
234:9; 237:2,3; 238:3
using 72:10,25; 86:22;
92:7; 97:4; 98:15; 111:24;
119:15; 136:7; 142:9,11;
145:13; 157:14; 158:25;
159:19; 188:15,17;
222:11; 233:7; 234:10
usually 211:10; 239:18
utilities 58:3,6
utility 6:12; 80:11,18;
150:7; 165:9; 209:22
utilization 119:18
utilize 186:2
utilized 145:10
vague 31:25
Valerie 220:14,24; 221:1,
3; 222:1
Valley 35:8,21; 110:10;
147:22; 210:3; 237:3
value 174:25;"175:9
values 81:2
van 80:24; 81:10
vans 8:15; 32:21; 33:5,9;
66:16; 114:13; 115:16;
116:18; 225:21
variety 25:24; 172:11;
191:23
various 159:19; 177:14
vary 57:18
vastly 74:7
vehicle 8:11; 27:8; 33:12;
62:25; 63:9; 66:17; 68:7,8,
10; 76:19; 78:19; 79:8;
80:15,16, 24; 81:10,12,
14; 82:11; 99:4; 103:6,13;
114:14; 123:2; 124:9;
125:24,25; 128:12;
130:25; 131:9,21; 132:2,
6,9,10; 133:10; 135:13,
19; 139:21; 140:18; 144:6;
162:3; 167:4; 170:19;
180:22; 186:3; 187:22;
201:8; 208:9; 212:23;
227:14; 228:24; 239:7,12,
19,20
vehicle's 73:14
vehicleings 131:19
vehicles 4:17; 5:8; 6:8,
12,17, 21; 7:22; 8:10,15,
16,24; 10:22,24; 11:13;
15:25; 17:5; 18:10; 24:18;
27:3,24; 32:22,23; 33:4,
8; 42:22; 43:4,14; 46:19,
21; 62:4,8,13; 63:7; 67:4,
17; 70:15,17; 73:7,9,13;
74:5,12,13,17; 76:9,13;
78:2; 79:7,11, 23; 80:5,
21; 81:19, 23; 82:13,21;
83:11,14,21,24; 84:3,7,
8,16; 86:3,16; 87:2,11;
94:17, 21; 95:2; 96:20;
97:13; 99:14,18; 100:2,5;
101:22; 102:13, 24; 103:2,
16; 108:16; 110:16,22;
111:8; 115:15,19,23;
116:23; 118:13,18; 119:5;
122:2,12,15; 123:7,25;
124:4; 126:20,23; 128:25;
129:2,8; 130:4; 131:8,21;
132:4; 133:10,14; 134:12;
138:20,22,25; 139:2,3,3,
6,16,24; 140:5; 148:23,
25; 150:7; 153:2; 154:7;
156:17; 157:4,5,9; 158:3,
8,9; 159:11,13,16;
162:11,13,14; 163:8;
164:25; 165:9; 166:21;
168:20; 170:12,21; 171:7,
10; 172:12; 180:6; 184:3;
187:17; 198:11; 204:21;
205:3; 206:6,9,12;
207:13,16,25; 208:11,18;
209:9,22; 212:3,11;
213:24; 214:3,18; 221:24;
224:11,15; 225:13; 226:6,
9; 227:2,3,10; 229:21;
231:3,6,11; 232:24;
233:13; 238:10; 239:16,
25
verification 205:24
version 8:14
via 79:12
viable 83:3
vice 75:22; 88:3; 179:15
vice-president 113:2
victim 214:24
view 30:11; 42:12; 55:10;
182:11; 187:9
views 12:25; 57:10;
113:9; 122:5; 172:16;
196:9,17
violate 24:23
violation 14:12; 163:6
violations 93:23; 109:19
Virginia 109:3,17,25;
179:18
virtually 104:7; 125:13
visibility 144:19; 145:8
visible 23:21; 151:9;
237:23
visits 148:18; 164:22;
167:8
vitality 105:18
vitally 123:16
VOC 154:9,12; 187:16,
18
VOCs 187:19
voice 34:18; 36:23;
93:11; 109:5; 124:18;
150:5; 155:16; 168:18;
221:5; 227:21; 230:15'
volatile 198:22
voluntarily 95:11;
157:17; 231:19
voluntary 218:7
volunteer 66:9; 88:3
 Vincent Varallo Associates, Inc.
                             Min-U-Script®
                                               (25)  truly - volunteer

-------
November 2,1999
                                                        Hearing
                                               Environmental Protection Agency Hearing
vulnerable 69:14,21;
149:14; 169:25

         w

W-I-N-T-E-R-S 236:22
wail 223:2
wait 49:6; 97:6; 159:3;
165:21; 170:25; 205:9;
207:21; 213:13; 233:8
waiting 62:24; 153:20
waive 101:21
walk 105:25; 210:11;
236:7
walking 12:19; 109:22
Walter 15:14; 34:1,15;
35:1; 36:1
wants 107:23
warehouses 228:4
warned 211:15,16
warning 26:19
Washington 110:6,13
waste 105:7
wastelands 228:3
wastes 166:15
watched 88:16
watching 60:4
water 43:24; 168:9;
203:12
wave 43:4
way 19:21; 26:25; 31:11;
33:25; 34:9; 37:13; 40:24;
55:3,4; 58:4; 101:12;
145:18; 149:19; 167:13;
198:17; 215:18,19;
223:24; 224:9
ways 58:19; 117:3;
161:25; 165:7; 211:13;
218:6
weak 163:7
wearing 180:11
weather 125:11; 195:10,
 18
web 15:7; 173:3
week 164:11; 181:13;
 195:7; 196:10; 202:13
week's 69:3
weekends 110:8
weeks 15:7
 weighing 8:16; 32:19,22;
 33:9; 73:7; 114:13
 weight 79:8; 114:14;
 122:16; 128:13; 131:9,22;
 133:11; 180:7
 weighted 174:21; 175:4,
 6,13
 welcome 4:5,9,13;
 219:12
 welcomes 84:21
 well-being 168:16;
 228:25
 west 107:5; 234:24
 What's 157:9; 224:16
wheeze 38:6; 88:11
wheezing 88:14
wherever 132:20
whole 18:12
wide 172:11
widely 95:8; 111:4;
157:14; 225:16; 231:16
wider 115:11
widespread 151:5
wife 12:18
wildlife 210:9; 211:20
William 15:13
willing 56:3; 101:20
willingness 227:9
wills 139:11
Wilmington 168:15;
169:8
window 18:18; 188:16
Winters 220:10; 234:20;
236:1,3,13,17,21,21,
23,25; 237:1
wish 14:14,17; 212:13;
215:6; 217:23,24
wishes 36:24
Within 15:7; 25:23; 77:12;
137:13; 165:11; 179:6,24;
187:4,15;240:5
without 18:10; 45:13,25;
82:19; 95:13; 113:23;
116:24; 119:15; 157:18;
159:21; 161:17; 174:13;
176:7; 178:25; 182:19;
185:7; 213:15; 219:20
witness 13:14,25; 14:6;
58:9; 98:24
witnessed 88:7
witnesses 13:23; 14:10,
22; 15:10; 58:24
witnessing 90:22
woman 106:9
women 147:24; 149:5
wondering 188:2
word 32:18
words 90:25; 219:16
work 37:15; 54:12; 56:19;
60:2, 24, 25; 83:17; 84:22;
94:13; 101:8; 117:9;
140:21; 144:7; 166:16;
177:13; 180:8; 189:21;
214:6; 224:9,12,20;
227:19; 228:17; 229:9;
234:25; 235:6
worked 116:3; 127:23;
129:10; 168:7; 203:8
workers 71:9
working 37:16; 43:7;
55:11; 56:21; 79:24;
100:10; 108:15; 109:22;
124:8; 141:6; 191:19;
201:23; 227:11; 229:10;
230:4
workload 80:4,6; 81:20
works 35:2; 147:21
workshops 20:3; 201:13
World 25:16; 56:15;
73:15; 85:15; 123:18;
130:11; 212:6; 226:19
world's 113:7; 118:12;
226:14
worried 40:22; 219:22
worry 85:17
worse 95:3; 109:11;
110:23; 150:19; 156:25;
224:17; 230:23; 231:11
Worsen 70:13
worsened 212:17
worsens 35:7
worst 60:21; 90:12,13;
93:19; 125:13; 207:10;
209:8
worth 69:3
writing 135:22; 199:24
written 13:4; 22:10;
23:14; 29:22; 33:13; 42:6;
49:12; 119:9; 123:22;
125:7; 202:2,21; 206:13;
217:6; 220:21
wrong 40:10
wrote 91:2
Wyncote209:17
yard 188:17
year 6:12,22,24,24;
8:21; 9:14,14; 19:7,16;
25:18; 29:10; 39:12; 44:9;
49:17; 50:11; 52:23;
61:13; 68:2; 72:13; 76:6;
78:8,13,15; 79:3; 81:2;
84:7,8; 85:13; 86:17; 89:2,
6; 93:21; 94:14; 95:14,18;
100:13; 107:5; 109:9,13;
113:10; 114:7; 115:4,6;
116:15; 117:8; 119:12;
120:3; 129:19; 130:7;
131:16; 132:15; 133:8;
134:12; 135:25; 137:13;
139:2; 140:25; 148:15,17;
150:18, 21; 156:22; 157:4,
20,24; 163:3,6; 165:3;
187:24; 188:11; 190:19;
191:6; 196:16; 197:23;
207:3; 215:15,16; 217:24;
218:5; 221:10; 222:21;
224:18; 226:18; 230:20,
25; 231:21,25; 232:21;
233:13; 237:7; 239:22
year-end 202:16
yearly 106:2
years 5:3; 18:14; 19:11;
21:2; 39:11; 45:22; 46:13;
50:7; 53:8; 59:4; 62:24;
64:18,19; 74:11,15; 78:3,
4; 86:14; 91:6,8; 94:22;
96:19; 100:14; 102:21;
105:3,10; 107:6,17;
117:11; 136:25; 138:20;
152:25; 159:12; 161:20;
162:25; 165:16; 177:16;
181:19, 22; 188:11;
200:17; 202:17; 212:18;
231:7; 232:23; 240:5
York 44:17; 134:7
York-Philadelphia
1.69:14
young 106:9; 237:9
zero 227:3
zero-sum 57:20
 vulnerable - zero-sum  (26)
                            Min-U-Script®
                                    Vincent Varallo Associates, Inc.

-------
Lawyer's Notes

-------