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
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LAWYER'S NOTES
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LIME
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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
. 109
. 112
. 118
. 124
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1
2 INDEX (Cont'd)
3 Julie Becker, Women's Health and Environmental
Network 147
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Gina Porreco, Clean Air Network 149
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Angie Farleigh, U.S. PIRG 156
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Kevin Stewart, PA American Lung Association... 160
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Emily Bertram, Nat'l Environmental Trust DE... 167
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John Duerr, Detroit Diesel Corp 172
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Alan Schaeffer, American Trucking
10 Association 179
11 Bob Jorgensen, Cummins Engines 198
12 Jonathon Sinker, Nat'l Environmental Trust
Pennsylvania 202
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Britta Ipri, Clear the Air Campaign 206
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Nancy Brockman, Wyncote Audubon Society 209
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Valerie Sowell, Citizen 221
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Jeff Harden, Citizen 223
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Jason Rash, PA Clean Cities Program 225
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Natasha Ernst, Low-income housing activist.... 227
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Ami Doshie, NJ PIRG 230
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Ajahi Harris, Citizen 234
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Dennis Winters, De Valley Transit Users
22 Group 236
23 Abram Haupt, Citizen 238
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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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Opening Statements
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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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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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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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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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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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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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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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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William Becker STAPPA/ALAPCO
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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William Becker - STAPPA/ALAPCO
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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William Becker STAPPA/ALAPCO
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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William Becker - STAPPA/ALAPCO
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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William Becker STAPPA/ALAPCO
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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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.
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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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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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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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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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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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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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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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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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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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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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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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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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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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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
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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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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
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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
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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.
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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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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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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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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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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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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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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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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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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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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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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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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
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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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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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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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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
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to reduce PM and NOx pollution from heavy-duty
engines.
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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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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
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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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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.
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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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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
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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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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
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standards, you make the standard more stringent.
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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
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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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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
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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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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.
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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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
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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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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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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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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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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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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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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.
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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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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.
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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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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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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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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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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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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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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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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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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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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.
-------
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
------- |