UNITED STATES OF AMERICA ENVIRONMENTAL PROTECTION AGENCY 1717 Arch Street, 50th Floor Philadelphia, Pennsylvania Tuesday, November 2, 1999 10:00 a.m. CONTROL OF EMISSIONS OF AIR POLLUTION FROM 2004 AND LATER MODEL YEAR HEAVY-DUTY HIGHWAY ENGINES AND VEHICLES; REVISION OF LIGHT-DUTY TRUCK DEFINITION NO- A-93-32 PRESENT: MARGO OGE CHET FRANCE JUDY KATZ MICHAEL HOROWITZ ROB FRENCH REPORTED BY: BERNADETTE BLACK, RMR, Notary Public LISA C. BRADLEY, RPR, Notary Public VINCENT VARALLO ASSOCIATES, INC. Registered Professional Reporters Eleven Penn Center 1835 Market Street, Suite 600 Philadelphia, PA 19103 (215) 561-2220 Vincent Varallo Associates, Inc. ------- LAWYER'S NOTES PAGE LIME ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX Opening Statements Jed Mandel, Engine Manufacturers Association. William Becker, STAPPA/ALAPCO Walter Tsou, M.D. , Citizen Joseph Otis Minott Richard Kassel, Natural Resources Defense Council Richard Breeze Citizen Beth Osteunski, Citizen Blake Early, American Lung Association Greg Dana, The Alliance of Automobile Manufacturers Sam Boykin Citizen Maria Bechis, Bucks County Sierra Club Meggy Bechis Citizen Beth McConnell, PennPIRG Kathleen Kerdei, Citizen Kitty Campbell Citizen Patrick Charbonneau, NAVISTAR Transportation Corp Rrnrp Bprtelsen, MECA Mike Carter, California Air Resources Board.. Coralie Coooer, NESCAUM PAGE 4 15 22 34 37 41 60 64 66 75 85 87 9 1 93 . 104 . 107 . 109 . 112 . 118 . 124 133 Vincent Varallo Associates, Inc. ------- 1 2 INDEX (Cont'd) 3 Julie Becker, Women's Health and Environmental Network 147 4 Gina Porreco, Clean Air Network 149 5 Angie Farleigh, U.S. PIRG 156 6 Kevin Stewart, PA American Lung Association... 160 7 Emily Bertram, Nat'l Environmental Trust DE... 167 8 John Duerr, Detroit Diesel Corp 172 9 Alan Schaeffer, American Trucking 10 Association 179 11 Bob Jorgensen, Cummins Engines 198 12 Jonathon Sinker, Nat'l Environmental Trust Pennsylvania 202 13 Britta Ipri, Clear the Air Campaign 206 14 Nancy Brockman, Wyncote Audubon Society 209 15 Valerie Sowell, Citizen 221 16 Jeff Harden, Citizen 223 17 Jason Rash, PA Clean Cities Program 225 18 Natasha Ernst, Low-income housing activist.... 227 19 Ami Doshie, NJ PIRG 230 20 Ajahi Harris, Citizen 234 21 Dennis Winters, De Valley Transit Users 22 Group 236 23 Abram Haupt, Citizen 238 24 25 - - Vincent Varallo Associates, Inc. ------- 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 Vincent Varallo Associates, Inc. ------- 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 Vincent Varallo Associates, Inc. ------- 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 Vincent Varallo Associates, Inc. ------- 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 Vincent Varallo Associates, Inc. ------- 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 Vincent Varallo Associates, Inc. ------- 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. Vincent Varallo Associates, Inc. ------- 10 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. Vincent Varallo Associates, Inc. ------- 11 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. Vincent Varallo Associates, Inc. ------- 12 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. Vincent Varallo Associates, Inc. ------- 13 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 Vincent Varallo Associates, Inc. ------- 14 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. Vincent Varallo Associates, Inc. ------- 15 1 Jed Mandel - EMA 2 And if you would like to have a 3 transcript of the proceedings, you should make 4 arrangements directly with the court reporter during 5 one of the breaks. 6 The transcript will be available in the 7 docket on our web site within two weeks. 8 This concludes my statement. And if you 9 don't have any questions, I would like to start with 10 our first panel of witnesses. 11 Any questions? 12 I would like to call Mr. Jack Mandel, 13 Mr. William Beckel, Mr. Richard Kassel, Mr. Joe 14 Minott, and Dr. Walter Tsou. Would you please take 15 your seat? 16 You should have a piece of paper in 17 front of you. I would like you to please state your 18 name. 19 We will ask Mr. Mandel to start. 20 MR. MANDEL: Good morning. My name is 21 Jed Mandel, and I am here today on behalf of the 22 Engine Manufacturers Association. 23 EMA's membership includes major 24 manufacturers of the engines used in heavy-duty, 25 on-highway vehicles, the subject of today's hearing. Vincent Varallo Associates, Inc. ------- 16 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 Vincent Varallo Associates, Inc. ------- 17 Jed Mandel EMA standards, massive changes to the existing regulatory program, significant new test procedures, and the fundamental recharacterization of heavy-duty engines and vehicles. Those proposed changes significantly increase the stringency of the 2004 standards, propose new standards not part of the 2004 Final Rule, and erode the certainty, stability and lead time that were so fundamental in the 10 original adoption of the 2004 standards. 11 Just a few examples may be 12 illustrative: EPA is proposing multiple new 13 supplemental test procedures and emission standards 14 that significantly increase the stringency of the 15 2004 standards. Yet neither EPA nor the regulated 16 industry have adequate data to determine the 17 feasibility and cost- effectiveness of these new test 18 procedures. In fact, it is unclear how these 19 procedures are to be run, or even if they can be 20 run. 21 Further, EPA has proposed to make the 22 engine manufacturer responsible for the emission 23 performance of its products at essentially any 24 possible combination of extreme operating 25 parameters. The net result is that manufacturers Vincent Varallo Associates, Inc. ------- 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 18 Jed Mandel - EMA must design their engines to meet emission standards at conditions that may rarely, if ever, be seen in operation. But EPA has not established the feasibility or cost- effectiveness of requiring that standards be met in such outlier conditions. EPA also has proposed very stringent new emission standards for heavy-duty gasoline engines in vehicles without proper consideration of the design margins necessary to ensure compliance. And EPA has proposed to recategorize a whole segment of the heavy-duty category, flying in the face of 30 years of Congressional mandate and regulatory policy. Not only has EPA proposed so many new, complex changes, but EPA has proposed those changes at the very end of the intended window of opportunity for conducting the 1999 review. The 1999 review was contemplated to be undertaken and finished well before the end of 1999. Instead, EPA did not publish its intended action until just this past Friday, October 29, did not hold a hearing until today, the 2nd of November, and has set December 2nd for the close of Vincent Varallo Associates, Inc. ------- 19 Jed Mandel - EMA comment period. That leaves the interested parties an unbelievably short period of time to review, digest and comment on the proposed rule, and leaves EPA and OMB with only a scant 29 days, including Christmas, if the rule is to be finalized before year end. The critical need for a timely 1999 review, acknowledged explicitly in the SOP, was to 10 ensure that manufacturers were provided no less than 11 four full model years of lead time, as is 12 statutorily required. 13 EPA's failure to conduct the 1999 review 14 in a timely fashion and EPA's subsequent decision to 15 propose at the last minute a host of new 16 requirements for finalization yet this year does not 17 provide the interested and affected parties adequate 18 opportunity to comment, does not provide EPA 19 adequate time to assess comments and prepare a final 20 rule, and generally, shortchanges one of the 21 Agency's most important rules in such a profound way 22 that fundamental principles of due process are now 23 threatened. 24 Some of the issues being proposed today 25 have not been discussed with the affected parties, Vincent Varallo Associates, Inc. ------- 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 20 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 Vincent Varallo Associates, Inc. ------- 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 21 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 Vincent Varallo Associates, Inc. ------- 22 Jed Mandel EMA associated with the lead time and stability requirements of the Clean Air Act. Finally, we recommend that EPA publish now a proposal to reduce the level in sulfur and diesel fuel so that commentors can assess all of the relevant factors impacting the feasibility and cost-effectiveness of EPA's proposal. EMA is reviewing EPA's proposal and 10 plans to prepare and submit written comments that 11 are as complete and detailed as possible given the 12 constraints of the late publication of the rule and 13 the limited comment period. 14 In the meantime, and I understand at the 15 end of the panel's presentation, I would be glad to 16 answer any questions you might have. 17 MS. OGE: Thank you. 18 Mr. Becker, good morning. 19 MR. BECKER: Good morning. 20 My name is Bill Becker, and I am the 21 executive director of STAPPA, the State and 22 Territorial Air Pollution Program Administrators, 23 and ALAPCO, the Association of Local Air Pollution 24 Control Officials, which are the two national 25 associations of air quality officials in 55 states Vincent Varallo Associates, Inc. ------- 23 William Becker - STAPPA/ALAPCO and territories and more than 165 major metropolitan areas across the country. I am pleased to be here this morning to provide our associations' testimony on EPA's recent proposal for controlling heavy-duty engines. The regulation of heavy-duty engines on fuels is a critical issue for State and local air officials, and I commend EPA for issuing a proposal 10 that not only looks beyond the near-term, but also 11 takes a comprehensive systems approach to 12 controlling the on road segment of this very 13 significant source of air pollution. 14 While our forthcoming written comments 15 will provide our perspectives on your complete 16 proposal for on-road, heavy-duty engines, including 17 aspects related to the regulated heavy-duty gasoline 18 engines, today I would like to focus my comments on 19 the few fundamental issues related to heavy-duty 20 diesels and fuel. 21 There is probably no more visible or 22 offensive kind of air pollution than the thick, 23 noxious, suffocating exhaust from big diesel trucks 24 and buses. Moreover, the adverse health impacts of 25 diesel pollution are dire, posing a serious threat Vincent Varallo Associates, Inc. ------- 24 William Becker - STAPPA/ALAPCO to public health nationwide, and especially in urban areas. The hazardous mixture that comprises diesel exhaust contains hundreds of different chemical compounds. From a health perspective, three of the most significant pollutants in diesel exhaust are nitrogen oxide, particulate matter and toxic compounds. Mobile sources are responsible for almost one half of all NOx emissions nationwide. EPA7s own projections show that by 2010, NOx from mobile sources will near 8 million tons, with more than half of this, over 4 million tons, coming from diesel engines. Further, one-third of the diesel contribution of NOx is attributed to on-road, heavy-duty diesel vehicles and two-third to off-road. These NOx emissions are primary precursors to the formation of ground-level ozone. And with close to 100 million people nationwide living in areas that continue to violate the one-hour standard for ozone. We must taking aggressive steps to address emissions from Vincent Varallo Associates, Inc. ------- 25 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. Vincent Varallo Associates, Inc. ------- 26 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. Vincent Varallo Associates, Inc. ------- 1 2 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 27 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 Vincent Varallo Associates, Inc. ------- 28 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 Vincent Varallo Associates, Inc. ------- 29 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 Vincent Varallo Associates, Inc. ------- 30 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. Vincent Varallo Associates, Inc. ------- 1 2 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 31 William Becker - STAPPA/ALAPCO 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 Vincent Varallo Associates, Inc. ------- 32 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 Vincent Varallo Associates, Inc. ------- 33 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 * Vincent Varallo Associates, Inc. ------- 34 Walter Tsou, M.D. Citizen to proceed. So I want to make sure that the Agency understands how critical this issue is to us. So in conclusion, let me thank you for this opportunity to testify. You've done a nice job with this proposal. We hope you will include our suggestions for strengthening and improving it the comprehensive way we've mentioned. 10 Thank you. 11 MS. OGE: Thank you. 12 Dr. Tsou, good morning. 13 MR. TSOU: Good morning. I will be 14 extremely brief and speak for five minutes. 15 Good morning. I am Dr. Walter Tsou, 16 medical director with the Montgomery County Health 17 Department. 18 Today I would like to add my voice to 19 others for stricter standards for clean air and 20 reduction in particulate matter. 21 The dramatic effect of clean air 22 standards can be seen here in Pennsylvania. Most 23 dramatically, Pittsburgh is no longer the soot city 24 so well known half a century ago. 25 California has the toughest clean air Vincent Varallo Associates, Inc. ------- 35 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, Vincent Varallo Associates, Inc. ------- 36 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. Vincent Varallo Associates, Inc. ------- 37 1 Joseph Otis Minott Citizen 2 MS. OGE: Thank you. 3 Is it Mr. 4 MR. MINOTT: Minott. 5 MS. OGE: Minott. Good morning. 6 MR. MINOTT: Good morning. 7 MS. OGE: If all of you could please 8 state your name and organization that you represent 9 with the court reporter today. 10 MR. MINOTT: My name is Joe Minott, and 11 I am here as a concerned parent. 12 First, I would like to thank the EPA for 13 holding this hearing, and in a gentle, parental way 14 maybe, chide them for holding it on Election Day. A 15 lot of the people that I work with tend to be 16 interested in politics and are out working the 17 polls, and we had a hard time bringing them in. 18 Nevertheless, my name, as I said, is Joe 19 Minott. I am an attorney, an environmentalist, a 20 soccer coach and a community activist. But by far 21 my most important role is that of father. 22 My son, Christopher, is an active 9-year 23 old. He loves to play soccer and basketball. He is 24 also an asthmatic. 25 I do not know how many of you in this Vincent Varallo Associates, Inc. ------- 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 38 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 Vincent Varailo Associates, Inc. ------- 39 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 Vincent Varallo Associates, Inc. ------- 40 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 Vincent Varallo Associates, Inc. ------- 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 41 Richard Kassel - NRDC with the dramatic rise in asthma cases in America's children. It is time for the federal government to understand this growing epidemic and deal with it. What EPA is proposing today is the belated first step . Thank you. MS. OGE: Mr. Minott, thank you for taking your time and coming to share your comments and also on Election Day. We did realize that, although too late. And my apologies. Mr. Kassel. Good morning. MR. KASSEL: Good morning. My name is Richard Kassel. I am a senior attorney with the National Resources Defense Council. NRDS is a national nonprofit environmental advocacy organization with over 400,000 members nationwide. At NRDC, I run our Dump Dirty Diesels Campaign. Thank you for the opportunity to comment and for holding the hearing today, even on Election Day. My remarks will provide an outline to Vincent Varallo Associates, Inc. ------- 42 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Richard Kassel NRDC NRDC's comments on the proposed rule. Given the time constraints, it may not be possible to provide sufficient detail on every provision of the rule. We will be supplementing our statement today and our written statement today with further supplemental comments before the close of comment period. But at the outset, we are one of those organizations that is applauding EPA for taking the step. Yes, it has taken a long time to get here, but in NRDC's view, this proposal begins to close some of the loopholes that have historically stood between millions of Americans and their right to clean, healthy air. Further, we believe that this proposal sends a strong message and a strong signal to the nation's diesel engine manufacturers, gasoline engine manufacturers, auto makers and others that it's time to dump dirt diesels and that it is time to ensure that all of America's sport-utility vehicles, no matter how big and heavy, meet the same stringent standards as the nation's family cars. I hope that the industries that are Vincent Varallo Associates, Inc. ------- 43 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Richard Kassel - NRDC interested in this proposal hear that signal and hear that message and choose to ride what we think is a public wave towards cleaner vehicles, diesel and gasoline, rather than fighting it. EPA is taking important steps, and we'll be working hard to ensure that the goals are met. And we have heard already quite a bit about the health impacts of diesel exhaust. I won't add very much to it because time is 1imited. Very simply, our reasons for our longstanding concerns are quite clear: Diesel vehicles emit huge quantities of particulate matter, nitrogen oxides, or NOx, and toxic compounds. The emissions from diesels, particulates, are associated with increased asthma attacks and emergencies, numerous cardiopulmonary elements, and premature death. Nitrogen oxides contribute to ground-level ozone, acid raid, but also here in Philadelphia to nutrient pollution in the Chesapeake and other large water bodies around the nation. Diesel exhaust and the particulate Vincent Varallo Associates, Inc. ------- 44 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 Vincent Varallo Associates, Inc. ------- 45 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 Vincent Varallo Associates, Inc. ------- 46 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Richard Kassel - NRDC 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 Vincent Varallo Associates, Inc. ------- 47 Richard Kassel - NRDC through 14,000 pounds. Like on the diesel side, we think an in-use testing program in OBD makes a lot of sense as do to the NTE and other consent decrees provisions. As with diesels, we don't think that there is a lead time issue here. We urge EPA to finish the rule promptly, and we don't think there will be a four-year lead time issue, particularly given the fact that what EPA is proposing to do has already been done in California. Next, closing the SUV loophole. I will only take a moment. We strongly support what the EPA is proposing. We strongly support Tier 2. It will finally require auto makers to produce many SUVs, minivans and light trucks that will match the emission performance of the nation's family car. Of course, we have been concerned about the loophole that exists for the heaviest of the SUVs, so we are glad that EPA is closing the loophole. We would urge you to expedite the timetable so that all of the requirements kick in no later than 2007. Vincent Varallo Associates, Inc. ------- 48 1 Richard Kassel NRDC 2 In the time I have left, I would like to talk about the next steps, coming to the next phase of EPA's efforts to dump dirty diesels. As I noted at the outset, diesel pollution remains unconscionably high in many urban areas of the nation. That's why we consider diesel exhaust to be the number one air pollution threat in many cities. 10 Thus, we hope that the Agency will 11 follow-up with a strong proposal to cut sulfur 12 levels to near-zero levels by 2007, to reduce 13 particulate levels to .01 grams-per-brake- 14 horsepower hour by 2007 and to reduce nitrogen 15 oxides to .2 grams -per-brake-horsepower hour by 16 2007. 17 We urge the Agency though to take 18 interim steps to move to a sulfur cap of 30 parts 19 per million in 2004; to move to a .05 gram 20 particulate standard in 2004. 21 We don't think that these are 22 standards that should get caught up in the lead 23 time debate over today's NMHC plus NOx proposal. 24 It is a separate set of provisions. And we don't 25 think that there should be a lead-time problem, Vincent Varallo Associates, Inc. ------- 49 if the EPA acts fast enough. In any event, we hope EPA will consider a phased approach, because millions of American's health are at risk, and Americans shouldn't have to wait until 2007 for lower sulfur diesel and for lower particulate-emitting buses and trucks. I know that I am about to be told that I am out of time, so I will stop talking. I have considerably more detail about each of these provisions in my written statement. Thank you. MS. OGE: Thank you. Mr. Mandel, I have a question for you. Last year, seven of the largest diesel engine manufacturers, Environmental Protection Agency, the Justice Department and the California Air Resource Board entered into what we call consent decrees, agreements under which this country will produce cleaner diesel engines prior to 2004, as early as 2002 actually. And also these companies have agreed to produce these engines to be clean, for the most part, of the Vincent Varallo Associates, Inc. ------- 50 driving conditions, which we call the certification procedures, that are known to exceed technical issues that you raise. In your statement you raise the issue of lead time. Under the law as you suggested, EPA has to give four years to companies, heavy-duty companies, to implement new standards. What if EPA doesn't finish this standard, this rule, by end of the year? Are you suggesting that the companies that entered under this agreement, under the consent decree, that they will not follow this agreement after the 2004 time frame, that they will be producing engines that do not meet the standards under driving conditions? Is that what you are suggesting? I would just like to clarify the record. So please go ahead. MR. MANDEL: I am certainly not suggesting that. The consent decrees state what the consent decrees state. The companies and the agencies, both EPA and ARB, that signed on to those, manufacturers have every right to expect manufacturers to live up to what those consent Vincent Varallo Associates, Inc. ------- 51 decrees say. And I am certain that those manufacturers will live up to those obligations, several of whom I think you will hear from on the record today with respect to that. But let me make a couple of other comments. I think will you also hear from some of the other companies that did sign consent decrees an interest in seeing a level playing field. There are different perspectives on that from engine manufacturers who signed consent decrees and those who did not. So one of the concerns that I hope the Agency takes away from this is there are companies who produce product effected by today's proposal who are not signatories to these consent decrees . I also want to point out that not all signatories signed the same consent decree. And there are companies who signed consent decrees who have provisions very different from others who have signed and from today's proposal. And, lastly, I think there is a misimpression -- perhaps two misimpressions: one Vincent Varallo Associates, Inc. ------- 52 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 Vincent Varallo Associates, Inc. ------- 53 companies will continue meeting the requirements of the consent decree regardless of what the Agency is going to do as far as completing this role. So they are not going to go back and start producing engines that they know meets standard because the consent decree has gone away because they don't have the four years leeway? Is that what you are saying. MR. MANDEL: What I said is the consent decree obligations don't meet the consent decrees. I think we have to be careful to make sure that this hearing isn't about consent decrees but is about the regulatory proposal, which is differently obviously. We as engine manufacturers are quite interested in seeing EPA reaffirm the 1997-2004 standards. The concerns that we have is how -- not whether, but how the Agency implements additional requirements and what those requirements are. And I think that's the nub of it. And if that is done in a proper time frame and with proper consideration of all of the effected interests, certainly not just those of Vincent Varallo Associates, Inc. ------- 54 engine manufacturers, but there are fuel producers who will be affected by this and obviously the public has great interest and great concerns over what is done, when all of those interests regress, I think our expectations is that there will be rules in place that all can live by that will more than meet the needs of the Agency, the breathing public, to see the cleanest diesel products, the gasoline products, the cleanest alternative fuel product in the marketplace doing the work that is necessary by trucks. MS. OGE: Does anybody have any questions? Anybody? MR. FRANCE: Yes. MS. OGE: I still have one question. MR. FRANCE: Just one brief question, Jed. This gets at the non-consent decree companies. I just want to get a little bit of a clarification. Let's assume for a second that we can address the concerns with the supplemental tests. I don't want to get into details, but assume we can. ~'-.i Vincent Varallo Associates, Inc. ------- 55 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 Vincent Varallo Associates, Inc. ------- 56 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 Vincent Varallo Associates, Inc. ------- 57 you can make a statement in response to what Mr. Mandel is saying. Bill, you suggested that these standards that we are proposing, both phases, the first phase in 2004 and the second phase in 2007, is critical for the State agencies across the country, especially areas that have ozone problems and particulate issues. Could you give us your views of how the States are going to proceed in identifying cost-effective control status to meet the one-hour standard and the PM concerns that they have if the Agency is being successful in implementing the standards by 2004 time frame, into 2007. MR. BECKER: It is a fair question. And it will obviously vary from state to state. But as everyone knows, state implementation planning is a zero-sum game. And to the extent that we don't achieve the anticipated emissions reductions from cleaner standards and cleaner fuels and cleaner in-use requirements, then states and localities will be required under law to make up for the Vincent Varallo Associates, Inc. ------- 58 difference elsewhere. And some will go after utilities even in a more stringent way than they have in the past. And some who have already tapped their utilities to the maximum will have to address the small businesses. And some will probably continue to exceed on the health base standards. And this witness, Chuck's [sic] Christopher, and others will continue to be affected by these excessive pollution levels. And I want to get back to the point here. I want to make two points: First, we have examined the costs and cost effectiveness of reducing emissions from mobile sources and examined reducing diesel exhaust. And compared to many of the other strategies that we are examining now, these are, indeed, very cost-effective ways at reducing, especially longer-term emission productions. And the piece of this that seems to be missing a lot is this in-use piece. And I won't -- I can't speak as passionately as some other witnesses, but I will tell you that there is a tremendous amount of frustration, of Vincent Varallo Associates, Inc. ------- 59 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 . Vincent Varallo Associates, Inc. ------- 60 Timothy Breeze - Citizen So I hope that you work this out, Chet. But I hope you strengthen it. And we are going to be watching the Agency, because what we've learned is that we need a very comprehensive and a very extensive and a very stringent in-use compliance program. MS. OGE: Any more questions? Thank you. We have three members of the public that have expressed an interest in testifying. I would like you to come up. Mr. Timothy Breeze, Ms. Susan Osteunski -- I hope I pronounced that right -- and Mr. Andrew Marks. Good morning. MR. BREEZE: Good morning. My name is Tim Breeze. I am living in New Brunswick, New Jersey right now. And I want to thank you for giving me the time to speak. I am living in - - New Jersey is one of these -- I want to say it has the worst air pollution of any place in the entire United States . Every day as I am going to work or at work, you know, you see the millions of - you Vincent Varallo Associates, Inc. ------- 61 Timothy Breeze - Citizen know, tons and tons of cars on the roads. And in addition to that, when going on the Turnpike, you just see these trucks. And every day you're stuck behind the trucks and you can't stand the smell, the pollution that you are feeling. It is something that, you know, affects us every day. Every day you're stuck in traffic, and millions of people in our state have to go through the same thing. In this country, you know, there is 150,000 people who have to go to the emergency room every year because of asthma attacks that are triggered by this kind of air pollution. And New Jersey is one of the big places where this is a huge problem. This summer it was like one out of every three days was a smog alert day. And in the town that I am living in now, which is New Brunswick, we had the highest of all of the eight hour smog standards. That was the highest level of any day reported over the course of the summer. You know, this is due to a lot of things. Obviously there is a lot of traffic Vincent Varallo Associates, Inc. ------- 62 Timothy Breeze Citizen going through that town with the Turnpike and the Parkway both being right nearby. So it's not just automobiles and sport - utility vehicles, which a number of people have mentioned. You need to make sure that those standards are met early, by 2007. But also a lot of these heavy-duty vehicles, these trucks which the pollution from them is just causing some huge problems. Yeah, so definitely I applaud the EPA, you know, for this program that you guys have put forth to clean up heavy-duty vehicles and reduce these standards, reduce emissions that are coming, this particulate matter especially. I know a lot of people that I am friends with who are asthmatic and who just can't even go outside and can't do the things that they are supposed to do for their job or the things that they need to do to live a -- just a healthy life. They can't even be outside and do any of these things especially in the summer. But I don't see why we have to be waiting ten years to be cleaning this up. Especially with the sport-utility vehicle Vincent Varallo Associates, Inc. ------- 63 Timothy Breeze - Citizen loophole, you know, giving until 2009 to auto 3 I! makers to be cleaning up the dirtiest SUVs, it just doesn't make sense. We're seeing extreme health effects right now. And auto makers have the technology to clean up their vehicles. There is no reason 8 that we can't have this by, you know, 2007 for 9 the rest of the sport-utility vehicle. I would 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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. Vincent Varallo Associates, Inc. ------- 64 Suzanne Osteunski - Citizen I can't even pronounce your name. MS. OSTEUNSKI: Good morning. My name is Susan, and I live in New Brunswick, New Jersey. And I just wanted to state thank you for having the conference and putting out this issue and bringing up the proposal. But I definitely think we should make it a sooner issue, especially because every day I drive into new Brunswick on Route 1, and I am constantly sitting in traffic behind all of these trucks, all of this smog is blowing in my face. My friend can't outside to hang out because she has horrible asthma. I don't see why -- obviously these companies can do something about this. Obviously it is not going to take them ten years. I don't understand why we have to give them ten years. There is obviously a problem. We obviously should do something of it; we should do it now. Time is of the essence. What better time than the present to do something about this? There are some high rates of cancer Vincent Varallo Associates, Inc. ------- 65 Suzanne Osteunski - Citizen right now, and obviously this is one of the direct problems of it is air pollution. You can see the air pollution outside. If you go outside of the city on the top of the hill, you can see the smog and the garbage hanging over the city. It is obviously a problem; it is in our face; we see the statistics. We can do something about it, and we should do something now before the problem is even bigger. And basically I would like you to take a stand on it and make it a sooner issue. MS. OGE: Thank you. Thanks to both of you taking the time to show your reasonableness. Thank you very much. I ask the next panel to please come up. Mr. Blake Early, Mr. Greg Dana, Mr. Sam Boykin and Ms. Maria Bechis, and Beth McConnell. Can you please print your names on the paper in front of you, and then we can start with Mr. Blake Early. MRS. BECHIS: We were scheduled for 11:15 here. MS. OGE: What is your name? Vincent Varallo Associates, Inc. ------- 66 Suzanne Osteunski Citizen MRS. BECHIS: We are with the Sierra Club. MS. OGE: We do have an available seat. Please take a seat. MR. EARLY: Good morning. I am Blake Early. I am an environmental consultant for The American Lung Association. The American Lung Association is the nation's oldest volunteer organization dedicated to lung health. The American Lung Association strongly supports the EPA's efforts to reduce emission from large diesel and gasoline trucks and buses and the application of uniform emissions standards to the full-size pick-up trucks, passenger vans and sport-utility vehicle. We also strongly support reducing sulfur in diesel fuel. Clearly with these emissions reductions from the initiatives proposed, more will be needed in the effort to provide healthy air across the nation. For this reason we urge EPA to revise its proposal to retain more reductions and obtain them sooner. The American public has long opposed Vincent Varallo Associates, Inc. ------- 67 Blake Early the unequal level of effort in emissions reduction that has been imposed upon passenger vehicles and their owners in comparison to trucks and buses. For too long trucks and truck owners have shared the road but not shared the cleanup effort to curtailing air pollution from mobile resources. It is a simple matter of equitable treatment. EPA's proposal is an important first step in equalizing the cleanup effort; however, even if EPA were to adopt the ALA recommendation, which I will outline in a moment, the Phase 2 heavy-duty diesel engines, the level of reduction would substantially lag that required for passenger vehicles. NOx and fine particle reductions are clearly needed across the nation, and reducing NOx from diesels will help reduce ozone. EPA estimates that nationwide NOx emissions will return to their current levels in 2020, assuming the standards proposed today are adopted and implement and the projected PM emissions from mobile sources will begin the Vincent VaraJlo Associates, Inc. ------- 68 Blake Early trend upward beginning next year, precisely at a time when we need to reduce PM, especially the fine particulate portion of PM. These estimates are likely to be low given the historical difficulty in estimating vehicle miles traveled, growth, and consumer vehicle choices as exemplified by the current rage of purchasing SUVs that is dominating vehicle sales today. NOx reductions are needed to lower unhealthy levels of smog and prevails in many areas prevailing over eight-hour periods. The fact, that the United States Court of Appeals has remanded EPA's eight-hour ozone NAAQS standard, does not mean that adverse health effects from exposure to low levels of ozone are not occurring. Indeed, for the past two summers, the number of areas that have been experiencing unhealthy levels of smog has been in record numbers. In 1998 over 5,000 exceedences of the eight-hour ozone NAAQS were monitored in over 40 states . For two summers in a row, Salt Lake Vincent Varallo Associates, Inc. ------- 69 10 11 12 13 14 15 18 19 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 70 Blake Early off-road sources contributes up to 26 percent of the total NOx emissions, this proposal is clearly moving in the right direction. Reducing diesel particulates will also lower toxic and nontoxic particulate threats to health. Particles from diesel exhaust may contribute more than 50 percent to Manhattan's particulate emissions, and is also a large contributor - or contributes a large percentage of the particulates in many urban areas. This situation may actually. Worsen if oil manufacturers introduce a new generation of diesel engines in passenger vehicles, which would add to the particulate emissions inventory. Studies suggest that these vehicles would generate less large particulate pollution but 30 to 60 times more fine particles, which are the most dangerous to human health. Many studies link airborne fine particles with increased hospitalizations in respiratory disease, chronic obstructive heart disease, lung disease and premature mortality. Again, while the U.S. Court of Vincent Varallo Associates, Inc. ------- 71 Blake Early Appeals remanded EPA's particle standard for further explanation, this does not mean that the health threat from fine particles is any less real. EPA must continue its effort to reduce both PM 10 and PM 2.5. Diesel particulate concerns: Not only does it contribute to additional forms of morbidity and mortality, but for many workers exposed to the diesel exhaust link, such an exposure has a 20- to 40-percent increase in lung cancer. A number of international, national and state agencies have identified diesel particulates as a probable carcinogen. While experts disagree as to whether diesel particulate is a carcinogen and if so how potent, the fact still remains that millions of Americans are exposed to this pollutant every day. Prudence dictates that EPA lower diesel particulate emissions as a practical means as a precautionary measure. But EPA should require more reduction sooner than it has in its proposal thus far. Given the importance of Vincent Varallo Associates, Inc. ------- 72 Blake Early obtaining the reductions in emissions that contribute to ambient ozone and particulate pollution, we make the following recommendations: A recent study by the Manufacturers of Emissions Control Association demonstrated that current technology of heavy-duty engines needs .05 grams-per-brake-horsepower hour of particulate standards even using conventional fuel with high levels of sulfur. EPA should tighten the HDPE particulate standard to .05 by the year 2004. With a four-year leave time, manufactures should be able to fully adopt this currently available technology to their needs. In the second phase, EPA should require another big reduction in particulates and a strict NOx standard. The same need to study demonstrated that for a current - technology engine to achieve a NOx emission rate below 2 grams per-brake- horsepower-hour while achieving a particulate emission at .01 grams per-brake-horsepower hour, using conventional high sulfur fuel in exchange Vincent Varallo Associates, Inc. ------- 73 Blake Early for sulfur-in-fuel reductions, which we advocate below, which EPA is considering, EPA should mandate emissions at least this low or lower for the second phase of its program. EPA should harmonize non-passenger, gasoline and diesel vehicles weighing 8500 to 15,000 pounds with California's LEV II program. If manufacturers can produce cleaner vehicles for California, they should do so for the benefit of breathers across the nation. EPA should also assure all heavy-duty vehicles are subject to an in-use test program to ensure the vehicle's performance in the real world is the same as they perform during certification testing. EPA should also set sulfur standards to foster new control technologies. Lower sulfur in diesel fuel is important for two reasons: It will facilitate the use of advanced emissions control on heavy-duty trucks and will enable the most effective use of currently available emission reduction technologies to retrofit heavy trucks on the road today. Vincent Varallo Associates, Inc. ------- 74 Blake Early EPA should immediately initiate the program of requiring a phased retrofit of existing heavy-duty diesel trucks. Unlike passenger vehicles, which have a useful life of approximately 100,000 miles, diesel trucks are driven vastly more miles, sometimes over a million miles in their lifetime, often undergoing multiple rebuilds. While the nation's automobile fleet will convert in approximately 12 years from old-technology vehicles to new-technology vehicles, trucks will be on today's trucks that are driven on the road today will last and not turn over for many, many more years. The only solution is to retrofit those vehicles at the time their engine is being built and the useful life is being extended. EPA has imposed new source performance standards for any heavy-duty truck that is rebuilt, just as the Clean Air Act required. New source performance standards apply to major rebuilds of power plants. There is little question that low-sulfur diesel fuel is a critical part of any Vincent Varallo Associates, Inc. ------- 75 Gregory Dana The Alliance effort to reduce emissions from existing and new technology heavy-duty diesel trucks. EPA should also require low-sulfur fuel for use in off-road diesel engines. Off-road engines contribute as much as 40 percent of total diesel particulate emissions. Low-sulfur fuel for these engines allows emissions to be reduced and also eliminates major problems associated with segregating high-sulfur and low-sulfur fuels and enforcing low-sulfur requirements. It is a very broad agenda but a very needed agenda. We urge the Agency to move as rapidly as it can. Thank you very. MS. OGE: Thank you. Mr. Dana, good morning. MR. DANA: Good morning. I see you have an overhead projector; I thought I would use it. My name is Gregory Dana. I am vice president of Environmental Affairs for The Alliance of Automobile Manufacturers. I am here today to speak on EPA's proposed 2004 heavy-duty Vincent Varallo Associates, Inc. ------- 76 Gregory Dana The Alliance emissions rule and modifications to the light duty truck definition. I do need to do my public service announcement first, however. The Alliance is a fairly new organization, less than a year old, and this is a list of all of the members of all Alliance representing about 90 percent of the sales of vehicles in the country. The Alliance member companies support the pursuit of cleaner air, and we are committed to developing new advanced technology to minimize any potential impact our vehicles may have on the environment. Our commitment is shown by the proposal we put forth in response to EPA's Tier 2 proposal; a proposal that achieves greater emissions reductions than proposed by EPA. Reducing the emissions from the heavy-duty vehicle population will help in achieving the nation's clean air goals, and we struggle to do our part. My comments today will focus of three key issues in the NPRM which concern Alliance members. These are: lead time, light-duty truck definition and fuel quality. Vincent Varallo Associates, Inc. ------- 77 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 Vincent Varallo Associates, Inc. ------- 78 Gregory Dana - The Alliance heavy-duty vehicles and engine manufacturers be given four years' notice of changes to standards as well as a separate three years of stability of these same standards. A three-year stability of the standard in the four-year lead time granted by the act effectively removes the 2004 model year from discussion at this time as manufactures are currently producing 2000 model-year products. Furthermore, as diesel heavy-duty standards are promulgated in 1997, which are effected in the 2004 model year, no relation to the diesel heavy-duty standard is permitted prior to the 2007 year. Manufacturers require this stability and lead time for all cost-effective emission control standards to ensure the new products meet the needs of the heavy-duty vehicle customer while simultaneously achieving air quality standards. There is sound, fundamental rationale for this lead time, and EPA cannot explicitly or implicitly attempt to rescind this position provided by the Act. Vincent Varallo Associates, Inc. ------- 79 Gregory Dana The Alliance For the second time in the 1999 calendar year, EPA is proposing to modify the definition of light-duty truck. Even before the Tier 2 rule is final, EPA is again proposing to modify the definition to include the new nebulous category of vehicles between 8500 pounds and 10,000 pounds gross vehicle weight that are designed for personal transportation and have a capacity up to 12 persons. The attempt to pull these vehicles into the Tier 2 rule via the heavy-duty notice is not consistent with the proper notice and opportunity for comment which is afforded in the regulatory process. Manufacturers have not had the opportunity to comment on the provisions, and EPA has offered no analysis of the benefits of this suggestion in context of the Tier 2 rules. The Alliance is proposing an extremely comprehensive and aggressive emissions reduction program in the Tier 2 rulemaking covering light-duty vehicles and light-duty trucks, and we have been working with EPA to resolve the issues. * Vincent Varallo Associates, Inc. ------- 80 Gregory Dana The Alliance A top priority issue identified in the Tier 2 rulemaking has been the engineering workload during the phase-in. This reclassification of the heavy-duty vehicles adds to an already uncontainable workload problem for manufacturers over and above that caused by the Tier 2 rule. The Alliance continues to stress that heavy and light trucks are unique from passenger cars. The utility of trucks comes with the additional design considerations, such as engine size and structural integrity that challenges the emissions performance when the full range of vehicle use is recognized. This vehicle segment has admittedly found success in the marketplace because of the expanded utility. This should not create a platform for EPA to restrict its choice by setting standards that exceed the emission feasibility of these vehicles. EPA has failed to consider that trucks are for peak use. Therefore, a sport-utility vehicle or a large van may be purchased to tow the boat or camper only a few Vincent Varallo Associates, Inc. ------- 81 Gregory Dana - The Alliance times a year, but the consumer values these attributes to the point of accepting the stiffer ride or accepting the other non-car-like characteristics to accomplish this goal. The proposed definition of a truck designed for personal transportation appears to leave much room for Agency subjective interpretation. For example, a common airport shuttle vehicle is a large passenger van that accommodates eight, 12 or 15 people, depending on whether there is luggage. Although this vehicle is obviously a truck in rigorous, commercial use, this vehicle would likely be subjected to the definition of light-duty truck requiring compliance with the very stringent Tier 2 gasoline and diesel standards. There are many implications related to the inclusion of heavier vehicles into the Tier 2 requirements. An impossible workload is now further compounded by their addition. Also, chassis test facilities for the heavier gasoline and diesel vehicles including the capability to measure emissions from the SFTP cycles are limited in the entire industry. This Vincent Varallo Associates, Inc. ------- 82 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 Vincent Varallo Associates, Inc. ------- 83 Gregory Dana The Alliance technology will require complex exhaust after treatment which will only be viable with very low-sulfur diesel fuel. Cleaner air requires cleaner fuel sooner rather than later. Delays in implementation of diesel fuel quality improvements represent lost emissions and fuel economy opportunities. I would be remiss if I also didn't mention the need for low-sulfur fuels for gasoline - fueled vehicles as well. While 30 ppm is the first right step, lower levels will be needed to allow the use of the advanced technology vehicles. Sulfur-free fuel has enormous air quality benefits and will ensure that emission control systems work to their fullest. We also hope that EPA will respond to our -petition on the distillation index. Controlling the distillation index will also help us in designing cleaner vehicles. In conclusion, The Alliance is focused on three main topics today: We believe that these heavier vehicles can meet more stringent standards given adequate lead time arid Vincent Varallo Associates, Inc. ------- 84 Gregory Dana The Alliance clarification of the definition of this class of vehicles; We believe the stability and lead time provision of the act will only allow the promulgation of gasoline emissions standards of 2005 model year heavy-duty vehicles and 2007 model year diesel vehicles at the earliest; The Alliance believes that attempts to modify the light-duty truck and personal transportation definition circumvent the regulatory process of notice, comment and review. The potential subjective interpretation of the new light-duty truck definition may be very troubling, and a systems approach to vehicles and fuels needs to be applied to the diesel technologies. A 5 ppm sulfur maximum is required to enable diesel after-treatment devices to improve air quality. The Alliance appreciates this opportunity to provide testimony and welcomes the opportunity to work with the EPA staff on this important issue. MS. OGE: Thank you. Mr. Sam Boykin. Good morning. Vincent Varallo Associates, Inc. ------- 85 1 Sam Boykin - Citizen 2 MR. BOYKIN: Good morning. It's 3 Boykin. 4 My name is Sam Boykin. I am a concerned citizen who lives here in Philadelphia, Pennsylvania. Although I have had the chance to live in many different cities across the East Coast, I notice the same air pollution problems there that we have right here in Philadelphia. I think the first thing I would like to say is I would definitely just urge EPA to put the concerns of the health of the roughly 40,000 Americans that die prematurely each year from pollution ahead of the concerns of the largest automobile corporations in the world. Just myself, luckily, I am a somewhat healthy person, and so I don't need to worry about running to the hospital every time there is a bad ozone day or some big diesel bus drives by me. But even on those days, I am affected in terms of being able to go outside and enjoy myself and do things that I normally like to do, whether it is ride my bike or go running. And so I would definitely applaud the EPA for these forward-looking programs to clean Vincent Varallo Associates, Inc. ------- 86 Sam Boykin Citizen up pollution from some of the nation's largest and dirtiest vehicles. I am extremely concerned that the proposal is phased in over a very long period of time resulting in delayed health benefits that these standards could bring. Specifically, I would like to urge the EPA to consider the following changes to strengthen the heavy-duty program: Number one would be to accelerate the time line for choosing the SUV loophole. There seems to be no technological reason to give auto makers an additional ten years to clean up the largest and dirtiest SUVs. It seems like all passenger vehicles should meet clean car standards by at least the year 2007. Secondly, I would like to urge you to tighten the heavy-duty particulate standards by 50 percent by 2004. The technology is already available to cut particulate pollution from heavy-duty trucks by half using existing technologies and catalysts. Third, I urge you to adopt strong standards for 2007 pollution from heavy-duty Vincent Varallo Associates, Inc. ------- 87 Maria Bechis, Bucks Co., Sierra Club vehicles. That is an urgent problem that needs to be addressed as soon as possible. The EPA must forge ahead additionally for a 90-percent reduction in particulate matter no later than 2007 . Fourth, clean up the diesel fuel in order to ensure that diesel pollution equipment is effective. All diesel fuel sulfur levels in both -- in both on road and off road diesel vehicles pollution should be capped at 10 parts per million sulfur by 2006. And, fifth, ensure that trucks stay clean once they are on the road. In order to ensure that clean trucks stay in, in-use testing and onboard diagnostic equipment should be required for all heavy-duty trucks both for gasoline and diesel . I would like to thank you for letting me speak today. That's all I have to say. Ms. Meggy Bechis will testify with her mom, Maria Bechis. Good morning. MRS. BECHIS: Good morning. My name is Maria Bechis, and sitting next to me is my daughter, Meggy Bechis, who is an asthma Vincent Varallo Associates, Inc. ------- 88 Maria Bechis, Bucks Co., Sierra Club sufferer. I am vice chair and volunteer advocate at the Bucks County Group of the Sierra Club. I am here not only as an environmental advocacy organization, but because I have witnessed firsthand the debilitating impacts of asthma on children and adults. My 10-year-old daughter and 48-year- old husband has asthma. My daughter and husband have difficulty breathing and wheeze painfully on bad ozone days in the summer. My daughter could not undergo a necessary surgery in 1997 because of wheezing. In the summer, I am a timer for children's swim meets. I have watched children come out of the pool at the end of the swim meet panicked because they cannot catch their breath and are in desperate need for their inhalers. Exhaust from heavy buses and trucks of heavy-duty fuels makes it difficult for children or anyone with asthma to breathe. Studies have also shown that this exhaust is potentially carcinogenic. Death rates from asthmatic children, Vincent Varallo Associates, Inc. ------- 89 Maria Bechis, Bucks Co., Sierra Club rising 6 percent a year, have doubled between 1980 and 1993. Nearly 5 million children, or one in ten children under Age 18, have asthma. The medical treatment for these children cost $6.2 billion a year. These children suffer miserably. They cannot play 8 I outdoors in the summer and are dependant on medications and inhalers. To parents in hospital emergency rooms, no cost is too high to protect 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 90 Maria Bechis, Bucks Co., Sierra Club resides, does not meet air quality standards on many days. We need cleaner air to breathe. We urge the EPA not to heed the diesel fuel and truck manufacturers to extend the time line for implementation of standards. I brought with me a postcard that the Sierra Club circulates to the public, and the public then sends this postcard to their policy-makers and legislatures. It is a picture of a real child. This little boy lives in Texas. And they have the worst air in the United States. It is the worst air. Many of their cities exceed air pollution levels that were once found in Los Angeles. This child goes out with a gas mask, and it has become a standard code of dress for these children in some of the cities in Texas. This is not what I want for my child or anyone's child. And if we don't do something about bringing these pollution levels down quickly, I am afraid that we will be witnessing something of this sort in more cities in the United States. Now, Meggy wanted to say a few words, Vincent Varallo Associates, Inc. ------- 91 Meggy Bechis Citizen and she wrote something that she would like to read here, if that's all right. MS. OGE: Yes. Go ahead. MISS BECHIS: My name is Meggy Bechis. I am 10 years old and I have asthma. We first found that out when I was about 8 years old. I have come here because I want the EPA to make large trucks and buses stop putting bad things into the air that makes me, my dad and other kids sick. It's very hard for me to breathe in the summer because it is very hot and humid, especially when the air is full of pollution. Sometimes I can't go outside when it is very hot. Last summer I had to swim two laps of the pool for placement in swim team. When I was finished, I couldn't breathe. My chest felt very tight; I was very scared. Other kids who swim at the meet come out of the pool coughing. They sound like barking seals and need their inhalers. In the beginning I used my inhaler two times a day. Now I use it only when I need Vincent Varallo Associates, Inc. ------- 92 1 Meggy Bechis - Citizen 2 it. 3 Please help the kids who have asthma by making the air cleaner, by making the air cleaner. This picture is of a boy that has asthma and is using an inhaler. The magazine is 8 "Time for Kids." 9 MRS. BECHIS: It is "Time Magazine 10 for Kids," and they have an article here on what 11 a health menace it is for children, asthma is. 12 Thank you. 13 14 15 16 17 1-8 19 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 93 Beth McConnell - PennPIRG very important to us as we deliberate on this very important topic. Thank you. And Ms. Beth McConnell, good morning. MS. McCONNELL: Good morning. It's a little hard to follow that. My name is Beth McConnell. I am a clean-air advocate for PenPIRG, the Pennsylvania Public Interest Research Group. Thank you very much for giving me an opportunity to voice my concerns about the need to reduce air pollution from trucks and SUVs. As those of us that live here in Philadelphia are painfully aware of, air pollution is causing a public health crisis not only here but across the state and nation. According to recent reports, Philadelphia has the fourth worst air quality in the nation, contributing to the premature death of an estimated 2,000 Philadelphians each year. And in the 1999 summer smog season, the State recorded more than 460 violations of the 8-hour ozone standard. While this problem notably affects Vincent Varallo Associates, Inc. ------- 94 Beth McConnell PennPIRG urban centers, such as Philadelphia and Pittsburgh, it also does reach to suburban and rural areas. For example, air pollution monitors in rural counties in Pennsylvania, such as Franklin and Mercer, has reported many unhealthy days as monitors in the Philadelphia area. For more than 650,00'0 Pennsylvanians like Meggy that suffer respiratory ailments like asthma, this pollution can become more than just an inconvenience. It also becomes the reason that kids miss school, parents miss work. And, in fact, it triggers an estimated 370,000 asthma attacks each year. 1997 alone, there was more than 370,000 in Pennsylvania. Now big trucks and buses including diesel- and gasoline-powered vehicles over 8500 pounds are among the biggest causes of our pollution problems. And manufacturers have done very little to curve their pollution. These big vehicles are a bigger problem today than they were 30 years ago when the Clean Air Act was originally passed. In fact, in urban areas, as much as 50 percent of the deadly particulate pollution Vincent Varallo Associates, Inc. ------- 95 Beth McConnell - PennPIRG that we breathe comes from diesel vehicles. Making matters worse, this diesel pollution has been found to contain hundreds of toxic substances, and more than 30 health studies link diesel pollution to lung cancer. It is high time for manufacturers of diesel engines and big trucks to use widely available technologies to reduce their 10 pollution. Yet we know from experience that we 11 cannot count upon them to do this voluntarily, 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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. Vincent Varallo Associates, Inc. ------- 96 Beth McConnell PennPIRG However, we are extremely concerned that the proposal is phased in over an unnecessarily long period of time resulting in delayed health benefits for the public and that the proposal may not adequately ensure that heavy-duty trucks comply with the standards throughout the time that they are actually on the road. Specifically we would urge the EPA to consider the following changes to strengthen the heavy-duty program: Number one, we would really like to see the time line for closing the SUV loophole accelerated. Under the Tier 2 auto pollution program, all cars and the smaller SUVs will be required to meet clean car standards by 2007. There is no technological reason to give auto makers another two years to clean up the largest and dirtiest SUVs of all. All passenger vehicles should meet clean car standards by 2007. We also would like to see the heavy-duty particulate standard tightened by 2004 . According to the manufacturers of the Vincent Varallo Associates, Inc. ------- 97 Beth McConnell PennPIRG Emissions Control Association, the technology is already available to cut particulate pollution from heavy-duty trucks by half using existing catalysts, yet the current proposal would have the public wait until 2007 before any reductions in particulate pollution from heavy-duty trucks would occur. This delay will contribute to the premature deaths of thousands of Americans. Third, we would like to see strong standards adopted in 2007. Pollution from heavy-duty vehicles is an urgent problem that must be addressed as soon as possible. The EPA must forge ahead with an additional 90 percent reduction of particulate matter and nitrogen oxide no later than 2007. Fourth, we would like to see diesel fuel cleaned up. Pollution control systems can be truly effective only when they are coupled only with low-sulfur fuels. In fact, the current sulfur levels in diesel fuels are so high, they actually prevent the use of the most advanced pollution control technology. Vincent Varallo Associates, Inc. ------- 98 Beth McConnell - PennPIRG So in order to ensure that diesel pollution equipment is effective, all diesel fuel sulfur levels, both on- and off-road diesel fuel, should be capped at 10 parts per million sulfur fuel by 2006. Finally, I would like to ensure that the trucks stay clean once they are actually on the road. Unfortunately lab tests quite often do not reflect the true on-road emissions and often faulty pollution control equipment goes unnoticed by the truck owner. Moreover, in the past, engine manufacturers and users have seriously undermined emissions standards by using cheating devices during testing procedures. In order to ensure that clean trucks stay clean, in-use testing and onboard diagnostic equipment should be required for all heavy-duty trucks, both gasoline and diesel. Once again, I want to thank you very much for allowing me to speak on this issue. MS. OGE: Thank you. Any questions of the witness? MR. FRANCE: Mr. Dana, you made some Vincent Varallo Associates, Inc. ------- 99 strong statements on lead time. But as a practical matter, I want to ask the question related to the 85 light-duty vehicle gasoline 5 II category. And in that program -- we've had extensive discussions with the principal manufacturers. And, in fact, the program proposed is harmonizing with a California LEV I program, which based on my recollection, 2001 is 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 100 aspects of that class of vehicles that you're trying to control, the ones you named in the proposal, at least some of the manufacturers build those vehicles with diesel engines. MR. FRANCE: I said gasoline. MR. DANA: Gasoline only? MR. FRANCE: Yes. MR. DANA: It is a matter of catalyst loading; it's a matter of working. It should be pointed out that under the Tier 2 rule alone, some manufacturers have to redesign almost 100 parts in one year, and then do it again three years later. It simply becomes an unworkable problem in trying to get everything redesigned immediately when you add in the additional layer MR. FRANCE: Maybe we're missing each other. My only question was very simple: For those models that are already being produced in California, all you have to do is carry them over federally, you know, the rest of the 49 states. MR. DANA: Right. MR. FRANCE: What is preventing you Vincent Varallo Associates, Inc. ------- 101 manufacturers from doing that in 2004? That's my question. MR. DANA: I don't think there is a feasibility from that standpoint. MR. FRANCE: It is mainly legal. MR. DANA: It is not just necessarily it is legal. It's, again, a work issue as well. Again, I understand what you are saying. MR. FRANCE: And do you see any -- just one follow-up question on that: Do you see any way around the legal concerns that would allow the Agency to implement that program in 2004 for gasoline? MR. DANA: Ask the guy on your right. We just put up there what the act says. It seems fairly clear in its reading. I don't know how to decide how to deal with it. MR. FRANCE: Are manufacturers willing to give the special circumstances to waive the four-year lead time for this class of vehicles? MR. DANA: I am not sure I can say that at this point. MS. OGE: Anymore questions? Vincent Varallo Associates, Inc. ------- 102 2 3 4 5 6 8 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Mike? MR. HOROWITZ: Do you want to go first? MS. OGE: Go ahead. MR. HOROWITZ: I have two questions for Mr. Dana. On the issue of the new definition for light-duty trucks, you made some comments 9 about the subjective nature of them. 10 The definition that we are proposing 11 isn't - is similar in some respects to the difference that we now have between light-duty vehicles and light-duty trucks. And I think it sounds like you are saying there is a subjective nature to that, too. But we haven't really heard anything from manufacturers that they don't like that definition, that distinction. Why is the distinction now a problem in this proposal when it hasn't been for the last several years? MR. DANA: I think what we are trying to point out when we look at the class of vehicles that are regulated, 8500 to 10,000 pounds, you have some SUVs, you have pick-ups and Vincent Varallo Associates, Inc. ------- 103 other specialty vehicles. The definition is broad enough as you thought by the proposed rule, that, in fact, it covers pick-up trucks as well as SUVs and any other vehicle that carries up to 12 people. An example I pointed out in my testimony was something that is called a super shuttle. I am sure those of you who travel a lot have seen them. They carry eight to 12 people. They would fall under the definition as we see it as being covered under the Tier 2 rule. That is clearly a commercial vehicle. What I am trying to point out is under the definition as proposed, you can log in a lot more vehicles than just the ones you've named by model name. And that is just a difficult issue we need to figure out between us and the agency, how to control what we want to control and not lump in everything else. MR. HOROWITZ: The second question was, you have a statement about fuel economy with regard to diesels. Is The Alliance in favor of increasing the corporate average fuel economy standards so that we can take advantage of that? Vincent Varallo Associates, Inc. ------- 104 Kathleen Kerdei Citizen MR. DANA: We haven't taken a position on that. But I would point out if, in fact, the Government decides to do anything with regards to fuel economy, we need to move either the diesel engines or lean-burn gasoline engines, both of which require almost virtually sulfur fuel. So if that is the Government's intention, then we're going to have to talk to the agencies some more about further sulfur to allow diesel engines to use devices and allow diesel engines to exist. MR. HOROWITZ: Okay. MS. OGE: Anymore questions? Thank you very much. We have three additional individuals that have expressed an interest in giving us comments: Kathleen Kerdei, Kitty Campbell, Carmen Lopez. MS. KERDEI: My name is Kathleen Kerdei, and I live in the city in Philadelphia. And I thank you for the opportunity to come here today and tell you how the poor air quality affects some of the older residents of this Vincent Varallo Associates, Inc. ------- 105 Kathleen Kerdei Citizen city . 30 years ago our family moved from the Oak Lane neighborhood of Philadelphia to Montgomery County where my husband's engineering firm had just built a new facility. The choice was made in order to prevent the risk and waste of time of spending two to three hours a day on the Expressway. 10 Four years ago, after the kids were 11 gone and on their own, the decision was made to 12 move back to the city; sort of a payback after 13 decades of taking advantage of Philadelphia's 14 15 16 17 18 19 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 106 Kathleen Kerdei Citizen market, doctor's, movies, increases yearly as does the degree of respiratory distress expressed by the residents. Because of this, several friends and neighbors have already moved back to the suburbs or planned to move before the coming summer. And it isn't just the over-50 crowd. A young woman in the neighborhood explained to me that she was leaving her studies at the University of the Arts to go home to New England because in her first semester she spent more time in Jefferson Hospital Emergency Room than she had in class. The decreasing quality of life, indeed, the risk to health and life itself, will continue to drive people from this city. The fortunate people, those who have come to become mobile. The result is a major disappointment for the citizens who wanted to help the city live and grow and a real death toll for the city itself, who is in desperate need of Government policy of common sense and mercy. Thank you. Vincent Varallo Associates, Inc. ------- 107 1 Kitty Campbell - Citizen 2 MS. OGE: Thank you. 3 MS. CAMPBELL: Good morning. My name is Kitty Campbell. I am a Philadelphia resident for about a year now, having lived out west for the last 20 years. And I have to say, I am thinking of moving back out there. I don't have asthma and I don't have respiratory problems, but I am losing my sense of 10 smell and I do have some trouble going outside on 11 the bad air days. So I think we have to do 12 something about it. 13 And I can attest to the fact that 14 tighter regulations regarding smog testing on 15 cars in California have made a huge difference in 16 smog levels out there. I was out there for about 17 20 years, and it honestly made a huge, huge, 18 difference. And we can do the same thing here. 19 There is no reason we can't pick up 20 those standards. I have an older car, and it 21 only cost maybe $75 to improve it. It is not 22 real, real expensive. So I come here as a 23 private citizen who just wants to be able to 24 breathe better. 25 I urge that more stringent standards Vincent Varallo Associates, Inc. ------- 108 Kitty Campbell - Citizen recommended by the EPA for SUVs be adopted not by 2009 but by not later than 2007, the same for cars . Given that, as I have read, the Japanese have already produced a SUV that does not pollute 3 to 5 times more than cars, why can't we Americans get on it pronto? And if we have to steal their technology or something, let's do it. Or let's cooperate with them. I also urge the tighter control in both trucks and bus emissions be enacted as proposed besides by the EPA as quickly as possible for both diesel and gasoline fuel. They are working in California with alternative fuel vehicles in - regarding the bus. I believe it's gas-powered buses or something, and it is helping somewhat. We all want to breath free, and I know I speak for millions when I say this. So please adopt EPA standards and even tighten them up more, if you can. Thank you for letting me speak. MS. OGE: Thank you. Ms. Lopez, good morning. Vincent Varallo Associates, Inc. ------- 109 Carmen Lopez Citizen MS. LOPEZ: Good morning, my name is Carmen Lopez, and I live in Alexandra, Virginia. First I just want to thank you for giving me an opportunity to voice my concerns about the need to reduce air pollution from trucks and SUVs. Nationwide, air pollution sends more than 150,000 Americans to the emergency rooms each year and causes more than 6 million asthma attacks, according to a recent study. Even worse, particulate is responsible for cutting short the lives of thousands of Americans each year. And I would also like to add that this problem proportionately affects Latinos, African Americans, and those of us who live in the city. In Virginia, air pollution is taking an enormous toll on public health. There were 124 smog violations during the first half of the summer. There were 23 days when ozone standards deemed the air unhealthy for people who were living, walking and working on the streets to breathe. I just learned that there were 220,000 people in Virginia and 27,000 in Richmond Vincent Varallo Associates, Inc. ------- 110 10 11 12 13 14 15 18 19 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- Ill Carmen Lopez - Citizen cancer in more than 30 health studies. It is time for the manufacturers of diesel engines and big trucks to use widely available technologies to reduce their pollution. I thank the EPA for taking measures to clean up pollution from the nation's largest and dirtiest vehicles. However, I am extremely concerned that the proposal has such a long 10 phase-in time, the result of which is delayed 11 health benefits for the public, and that the 12 proposal may not adequately ensure that 13 heavy-duty trucks comply with standards 14 15 16 17 18 19 20 21 22 23 24 25 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. Vincent Varallo Associates, Inc. ------- 112 1 2 4 5 6 7 8 9 11 12 13 14 15 16 17 18 19 20 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 113 Patrick Charbonneau NAVISTAR vice-president of Engineering for the Engine and Foundry Division of NAVISTAR. We are a major North American manufacturer of medium and heavy-duty trucks and buses marketed under the international tradename. NAVISTAR is also the world's largest manufacturer of mid-range diesel engines . To understand our views on EPA's 10 proposed 2004 model year standards, it is useful 11 to understand the commitments made by EPA, GARB 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 114 10 11 12 Patrick Charbonneau NAVISTAR require. And with such certainty and stability, those investments might never be recouped. EPA and California recognize the huge investment that will be required of the industry." The SOP provides such stability by, among other things, confirming the Model Year 2004 standards would be premised on current federal test procedures, and that EPA thus would not alter such standards in this rulemaking. Moreover, the SOP expressly applies to all heavy-duty engines, including heavy-duty 13 SUVs and passenger vans weighing between 8500 and 14 10,000 pound gross vehicle weight. 15 NAVISTAR is committed to achieving 16 17 18 19 20 21 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 23 24 25 overall feasibility. For instance, EPA's proposed not-to-exceed limits and maximum achievable Vincent Varallo Associates, Inc. ------- 115 10 11 12 Patrick Charbonneau - NAVISTAR emissions limits testing requirements have the effect of dramatically increasing the stringency of the 2004 model year standards that the EPA and industry agreed upon under the SOP- We know of no data suggesting that the Model Year 2004 heavy-duty standards can feasibly be met with the NTE requirements in place. Moreover, on top of the NTE and MAEL proposals, EPA has proposed to require testing compliance over a wider and unprecedented range of ambient conditions, which further compromises 13 the feasibility of the 2004 standards. 14 15 16 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 18 19 SOP to establish technologically feasible standards for all heavy-duty vehicles. 20 To our knowledge, there is no 21 22 23 24 25 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. Vincent Varallo Associates, Inc. ------- 116 1 2 10 11 12 13 14 15 Patrick Charbonneau - NAVISTAR Finally, notwithstanding the many complex issues that need to be worked out, EPA's timetable calls for the Agency to complete this rulemaking by December 31st. Not only does this proposed timetable deprive the public of adequate time to assess and comment on the rulemaking package, it leaves the EPA with a challenge of only 29 days to finalize the rule after the December 2nd. This timetable is unworkable, particularly given that the EPA's proposal would number one, dramatically change the term of the SOP; number two, increase the stringency of the Model Year 2004 standards; number three, result 16 in new standards and test procedures that were 17 not part of the SOP; and four, effectively 18 19 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 23 24 25 emissions from heavy-duty vehicles. The SOP, along with actual EURO III testing without EPA modifications ensures tremendous emissions Vincent Varallo Associates, Inc. ------- 117 10 11 12 13 14 15 16 17 18 19 Patrick Charbonneau - NAVISTAR reductions benefits. The EPA's proposal, however, departs from the SOP in ways that fail to appreciably advance environmental objectives, but which call into question the overall feasibility of the proposal. Therefore, we recommend that EPA and industry move forward with the SOP for Model Year 2004 heavy-duty engines, work to establish a dialog on potential new emissions testing protocols for post 2004 model years. We also look forward to continuing discussions with EPA on fuel issues . As we stated in our comments on the Tier 2 rulemaking, clean diesel fuel, 5 parts per million maximum sulfur, is absolutely necessary for emissions controls technologies we are developing for the post-2004 period, and, therefore, must be addressed in connection with 20 any post 2004 heavy-duty emissions standards. 21 22 23 24 25 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. Vincent Varallo Associates, Inc. ------- 118 II 1 2 3 4 5 6 10 11 12 13 14 15 18 19 Bruce Bertelsen MECA Mr. Bertelsen, please. Good afternoon. MR. BERTELSEN: Good afternoon. Good afternoon. For the record, my name is Bruce Bertelsen. I am executive director of the Manufacturers of Emissions Controls Association. MECA is pleased to present testimony in support of EPA's proposal. For those not familiar with MECA, we are a non-profit association made up of the world's leading manufacturers of emission control technology for motor vehicles. EPA's proposed regulatory initiative, we believe, marks an important first step in 16 moving towards the objective of substantially 17 reducing exhaust emissions from highway, heavy-duty engines and vehicles. The Agency's proposal constitutes a 20 carefully crafted and balanced program that, if II 21 finalized, will result in substantial 22 cost-effective emissions reductions over the next 23 24 25 several decades. Completing the task will also require EPA to implement the appropriate limits on the Vincent Varallo Associates, Inc. ------- 119 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 19 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 120 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 10 11 12 13 14 designs, advanced integrated exhaust emission controls and very low diesel sulfur fuel, significant additional reductions in NOx, PM and f toxic emissions are possible beyond the levels 15 that will be achieved in meeting the 2004 16 standards. 17 With such a systems approach, we 18 believe levels in the range of .5 NOx .01 PM and 19 over an 80 percent reduction in toxic emissions 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 121 10 11 12 13 14 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 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 122 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 10 11 12 13 8500 pounds can and will be applied to passenger transport vehicles up to 10,000 pounds to help them meet the proposed Tier 2 standards. 14 Even though designing systems for 15 transport vehicles in the 85 to 10,000 pound 16 weight class may pose additional engineering 17 challenges, we're optimistic that these 18 challenges can be met. II 19 Again, we stress, however, that a 20 systems approach will be critical in meeting 21 these standards, including the availability of 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 123 Bruce Bertelsen - MECA proposal. OBD systems in light-duty vehicle applications have proved to be an effective method for maintaining effective emissions 5 I! control performance, and we expect that similar-type benefits will be realized by extending OBD requirements for all vehicles less 8 9 10 11 12 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 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 124 10 11 12 13 14 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 23 24 25 behalf of CARB. First, I would like to begin by giving a brief overview of the California Air Vincent Varallo Associates, Inc. ------- 125 10 11 12 13 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 22 23 24 25 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. Vincent Varallo Associates, Inc. ------- 126 10 11 12 13 14 15 Mike Carter ARE This significant decline in ozone levels demonstrates the overall success of our control programs. Despite these strides, however, exceedences of air quality standards still commonly occur. For example in 1998, 60 days were recorded to give above the one-hour federal ozone air quality standard in the South Coast Air Basin. Additional emissions reductions are needed in order to achieve attainment in both national and state air quality standards. Over 50 percent of emissions emitted from man-made sources are from mobile sources. These pie charts illustrate the 16 projected percentage of mobile source emissions 17 to each category of sources in the South Cost Air 18 Basin by 2010. As shown, the active organic 19 gasses and oxides of nitrogen emissions from 20 heavy-duty vehicles will be responsible for 6 and 21 22 23 24 25 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, Vincent Varallo Associates, Inc. ------- 127 8 9 10 11 12 13 14 Mike Carter - ARE heavy-duty emissions are a major part of the emissions inventory and additional reductions are needed. To highlight the additional need for diesel emissions reductions, this chart shows the diesel particulate matter in comparison to all other toxins combined. While the risk in general has decreased from both diesel and other toxics, it is still significant with diesel accounting for over 60 percent of the total risk. These last two slides were also shown at the Air Basin Technology Symposium Conference in early October of last month. And at that 15 conference it was made very clear that ARB's 16 I number one priorty right now is to reduce diesel 17 exhaust emissions. 18 This slide shows some of the board's 19 recently adopted regulations of ongoing 20 activities to reduce emissions from mobile 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 128 10 11 12 13 Mike Carter - ARE implementing the call aware program to reduce diesel emissions and for developing a proposal for urban bus standards, and diesel particulate matter risk management, and lower heavy-duty diesel standards beyond the levels called for in the statement's principles. I would like to limit my comments today on the NPRM to four specific items: the heavy-duty Otto-cycle standards, the heavy-duty diesel standards test procedures, the inclusion of investigations over 8500 pounds gross vehicle weight into the Tier 2 program, and the 14 implementation issues associated with these 15 issues. 16 First, ARE supports the proposed 17 standard of l gram per-brake-horsepower hour to 18 be implemented in 2004 for the heavy-duty Otto 19 cycle. It should be known that ARE's 20 consideration of reducing these standards is part 21 of a settlement agreement of a State 22 implementation plan lawsuit. 23 24 25 To comply with the proposed standard, the advanced emission control technology and light- and medium-duty Otto-cycle vehicles could Vincent Varallo Associates, Inc. ------- 129 10 11 12 13 14 15 16 Mike Carter - ARB be transferred into heavy-duty vehicles. We expect the reductions from this transfer of technology should be significant, since the light-and medium-duty standards are more stringent than the proposed heavy-duty standards. As noted earlier, heavy-duty diesel vehicles contributed a substantial portion of oxides of nitrogen or particulate matter emissions. ARB staff has worked closely with U.S. EPA to develop and promulgate the 2004 heavy-duty diesel standards as well as the off-cycle consent decree. Thus, these heavy-duty diesel requirements for California are similar to the federal ones. The NPRM proposes to reaffirm the 17 heavy-release standard of 2-and-a half grams 18 per-brake-horsepower hour of hydrocarbons plus 19 oxides of nitrogen for the 2004 model year. 20 This standard is feasible with the 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 130 10 11 12 13 Mike Carter ARE earlier in October of 2002. Other elements proposed in the NPRM also for heavy-duty diesel vehicles include the addition of supplemental standards and test procedures. And in addition, three elements are are being considered for SIP for next year. And my next two slides will comment on these items. First, the additional standards and test procedures will allow better control of emissions for driving in the real world resulting in realization of expected emissions reductions. The current certification test has limitations, 14 and that does not fully represent the broad range 15 of driving emissions. 16 The addition of the state bureau free 17 test of certification would require control 18 19 20 21 22 23 24 25 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, Vincent Varallo Associates, Inc. ------- 131 Mike Carter - ARE in the consent decree requirements, these 3 I! additional requirements should be feasible in the 4 2004 time frame. 5 I The NPRM also proposes additional heavy-duty diesel provisions in consideration of a separate rule, and these items include onboard diagnostics for vehicles over 14,000 pounds gross vehicle weight. A manufactured-based in-use test program and revised rates meeting that 10 11 12 13 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 22 23 24 25 weight that are used primarily for personal transportation be included in the Tier 2 program. This provision was considered in Vincent Varallo Associates, Inc. ------- 132 Mike Carter - ARE California's Low-Emission Vehicle II rulemaking but was not finalized. It would be appropriate for these heavy-duty vehicles to be included in 5 II the Tier 2 program because they are used primarily as a personal transportation vehicle and would discourage manufactures from redesigning a light-duty truck to a heavy-duty vehicle just so that it can be certified by a significantly higher heavy-duty vehicle emissions 10 11 12 13 14 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 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 133 7 8 9 10 11 12 13 Coralie Cooper NESCAUM to move forward and propose a 2004 implementation date . Again, more detailed comments of the proposed elements will be submitted to the docket at a later date. But in summary, ARE supports the heavy-duty Otto-cycle standards in the 2004 model year, the heavy-duty diesel elements, and the inclusion of the personal transportation vehicles over the 8500 pounds gross vehicle weight into the Tier 2 program. While these proposed elements would provide emissions reductions from heavy-duty 14 vehicles, additional strategies to reduce 15 heavy-duty diesel emissions should continue to be 16 considered. 17 1 In particular, we are currently 18 19 pursuing along with the U.S. EPA a lower emissions standards beyond the 2004 standard 20 levels from an engine/fuel perspective. 21 22 23 24 25 comment. Thank you for this opportunity to MS. OGE: Thank you. Ms. Coralie Cooper, good afternoon. MS. COOPER: Good afternoon. My name Vincent Varallo Associates, Inc. ------- 134 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 135 IT 1 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Coralie Cooper - NESCAUM as the region implements further controls on other sources of NOx emissions and as the regulatory community refines its use in heavy-duty emissions. In the United States and in Europe, development and active treatment of exhaust in the use of low-sulfur diesel fuel have been shown to enable emissions reductions by more than 90 percent in NOx PM and toxins in heavy-duty engines EPA's proposal for regulating heavy-duty engine vehicle emissions for the 2004 time frame is an important step to reduce a heavy-duty engine emissions. When combined with further standards in the 2007 time frame, end reductions in diesel fuel and sulfur, the proposal will substantially reduce heavy-duty vehicle emissions. Now, I would like to summarize the NESCAUM comments, and NESCAUM will also submit more detailed comments in writing later. In terms of reaffirming the technological feasibility of the 2004 or later 25 model year for heavy-duty diesel engines, again Vincent Varallo Associates, Inc. ------- 136 Coralie Cooper NESCAUM it's NOx and PM, NESCAUM states support the proposed NOx standard for heavy-duty diesel engines. 5 I! This standard is technically and 6 economically feasible in the 2004 time frame 7 using currently available technology. 8 I In terms of particulate emissions, NESCAUM states that heavy-duty diesel engines can either be illustrated by .5 gram-per-brake- 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 137 10 11 12 13 14 15 16 17 18 19 20 21 22 Coralie Cooper - NESCAUM reduction and the next proposed reduction in 2007 . While the NESCAUM states believe that more stringent PM standards are technologically and economically feasible for 2004, we expect the EPA proposal is leaving the .1 PM standard as is for 2004 given that significant reduction down to the .01 level are may be proposed in the 2007 range and will be implemented after 2007. This will require development of rulemaking on both diesel fuel sulfur and new engine standards within the next year, we hope. The NESCAUM states urge EPA to move forward aggressively with this rulemaking and NOx PM for the 2007 standards. Scientific experiments or direct exposure to diesel PM is met by deep public concern and frustration over which diesel buses, trucks and heavy equipment, as has been expressed, I think, today by a number of people. This coalescence of expert and public 23 opinion provides added impetus for timely efforts 24 25 to reduce PM and NOx pollution from heavy-duty engines. Vincent Varallo Associates, Inc. ------- 138 1 Coralie Cooper NESCAUM 2 In terms of the heavy-duty gasoline emissions standards, in it's proposal EPA invited comments on the feasibility of proposed heavy-duty gasoline engine standards. The NESCAUM states concur with EPA that proposed heavy-duty gasoline standards are appropriate for several reasons: First, technical advances and three-way catalysts now allow for durable and 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 139 Coralie Cooper NESCAUM and more heavy vehicles are sold each year as passenger vehicles. These vehicles must be held to proposed Tier 2 standards in order to keep pace with increased submissions from these heavy vehicles . While technical challenges do exist, the phase-in schedule that is allowed under the proposal, the advances in three-way catalyst that 10 have been made and the larger space available in 11 these heavier truck wills facilitate a control of 12 emissions in trucks up to 10,000 pounds up to the 13 14 15 16 17 18 19 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 140 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 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 141 10 11 12 13 14 15 16 17 18 19 20 21 standards. We strongly urge the Agency to move forward with these two initiatives in the time frame laid out in this proposal, and we look forward to working together with you in the development of these rules. MS. OGE: Thank you. Any questions for the panel? Chet? MR. FRANCE: Just a few questions for Mr. Charbonneau. Pat, is my recollection is that NAVISTAR did not have to comply with the supplemental test. MR. CHARBONNEAU: We provided to the Agency that we did not believe that the supplemental testing was possible under these standards and provided information, although they are not covered under that policy. MR. FRANCE: I will follow that 22 question in a second. 23 24 25 How do you see - what would you recommend to the Agency on how can we attain the not-to-exceed concept and implement it by 2004? Vincent Varallo Associates, Inc. ------- 142 How do you see past that? MR. CHARBONNEAU: To tell you the truth, Chet, I don't know what the proper path of 5 I! that would be unless I think if there's 1.25 was I not to-exceed, if it was something in the range of 1.5 that would probably be reasonable. But what I put in my comments, the EURO III testing, using really the EURO III procedures on top of the 2004 emissions standards 10 11 12 13 14 15 16 17 18 19 20 21 and using our transient tests provides a tremendous amount of coverage on ensuring that we are, in fact, truly going to have engines that around 2 grams of NOx as we move into 2004. MR. FRANCE: I understand. Let me ask the question: You are suggesting, and I don't want to put you on the spot here but I would be interested in your reaction. You are implying that those provisions are unfeasible. What does that say to the consent decree companies that are complying? 22 MR. CHARBONNEAU: Chet, all I can 23 tell you is we provided you input that says for 24 these types of standards, this was not feasible 25 to do. And provided the Agency information, I Vincent Varallo Associates, Inc. ------- 143 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 really can't speak to what other the engine manufacturers have or have not told you. But you had a consistent message on that, and we provided information for you. MR. FRANCE: Okay. Thanks. MS. OGE: Can I follow-up on this? To the extent that the consent decree companies will comply with the not - to-exceed requirements in the 2004 time frame, would then NAVISTAR, do you think, their position on the not to exceed as far as the technological - - MR. CHARBONNEAU: Just to be very MS. OGE: Because what would be happening at the point is that those companies that have agreed to meet the not - to-exceed, would produce very clean engines, cleaner than your statistics of the 2004 standards. My question is: Would then NAVISTAR consider the technical feasibility? MR. CHARBONNEAU: There is really -- there is two aspects to this: The aspect of the 23 2004 standard, my comments are that when you 24 25 apply the not-to-exceed limits to the 2004 standards, you make the standard more stringent. Vincent Varallo Associates, Inc. ------- 144 10 11 12 13 14 15 16 17 18 19 20 21 And that is the clear fact you are attending to. The things that are not clear are with not - to-exceed limits, especially at the 25 percent level, the impact on things like performance, the ability of the vehicle to do the work it needs to do in conjunction with other aspects of transient responses are questionable in light of the 2004 -- basically the 2 gram NOx standard. So just to be perfectly clear, one is the not-to-exceed does reduce the 2004 standard lower than we had agreed to before, and the not-to-exceed limits both have impact on the things that have to do with low transient response and economy, et cetera. MS. OGE: Again, my question is: I thought you talked about -- are talking about visibility. MR. CHARBONNEAU: Yes. MS. OGE: And you did provide 22 comments to the Agency on this issue. We do have 23 24 a number of companies resulting in - - that have agreed to proceed with those not-to-exceed 25 requirements. And they will be producing those Vincent Varallo Associates, Inc. ------- 145 10 11 12 13 14 15 16 17 18 19 20 21 engines in 2002 time frame. My question is: Would NAVISTAR at that point MR. CHARBONNEAU: Margo, yeah, my answer would be this MS. OGE: Consider the position, technical visibility, that's all I'm asking. MR. CHARBONNEAU: All of the technologies are being utilized exactly the same. It is technologically feasible to accomplish it, and obviously NAVISTAR would accomplish it using the same technologies. MS. OGE: Thank you. Chet, any other questions? MR. FRANCE: One other question. Pat, I am assuming -- this just dawned on me -- that the concept, maybe a way out of this is just making sure that we have have a robust NCP available for companies perhaps like NAVISTAR. If there are other companies that are 22 not going to meet those requirements, then that 23 24 25 is what NCP's are supposed to accomplish. I presume that would be another alternative? MR. CHARBONNEAU: That's possible. I Vincent Varallo Associates, Inc. ------- 146 will get back - once again, I'll get back to the responses. Based on what we have done through our testing, the standard is going to get much tougher, and we believe that for 2004, it would 7 now become a technical challenge. What I am not 8 saying is that post 2004 is not the right thing to do . MS. OGE: I have a question for Mr. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Carter. Is ARE considering to address diesel fuel? question. MR. CARTER: That's a loaded MS. OGE: Okay. MR. CARTER: Well, certainly for 2004 standards. We don't think that you need to do anything necessarily with the fuel, but certainly post 2004 we do. And certainly it would be advantageous to California if the fuel sulfur level was reduced on a national basis primarily because of the traffic, interstate traffic. But as far as whether we in California would do something alone, I am not prepared to respond to that right now. I'm not Vincent Varallo Associates, Inc. ------- 147 Julie Becker - Citizen sure, to tell you the truth. 3 MS. OGE: Thank you. 4 Anymore questions? 5 Thank you very much. 6 (Bernadette M. Black, RMR, was excused from this proceeding and was relieved by 8 Lisa C. Bradley, RPR, at 2:15 p.m.) 9 MS. OGE: I would ask two individuals 10 that I guess -- one has been scheduled to testify 11 at 3:15 and the other one just expressed an 12 interest to testify. We would ask if both of 13 them would please step forward, Ms. Julie Becker 14 and Ms. Gina Porreco. 15 16 17 18 19 20 21 22 23 24 25 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. Vincent Varallo Associates, Inc. ------- 148 l Julie Becker WHEN 2 I appreciate the opportunity to testify at this 3 hearing on behalf of our coalition members and 4 community groups. 5 I'd like to focus attention today upon 6 the relationship between smog and health issues, 7 specifically, asthma. The number of asthma 8 sufferers has more than doubled since 1980 to more 9 than 15 million individuals. Currently, almost 10 10 percent of America's children under the age of 18 is 11 sickened with this common and costly disease. It 12 takes a disproportionate toll upon African-Americans 13 and Hispanics, primarily in urban areas. It is 14 estimated that asthma accounts for more than half a 15 million hospitalizations per year, the cost of more 16 than $15 billion. Smog may account for nearly 6 17 billion asthma attacks per year that require 18 approximately 150,000 emergency room visits at a 19 cost of $4.5 billion. 20 One of the greatest contributors to smog 21 comes from cars and trucks, an increase in sales of 22 the largest SUVs, coupled with an increased 23 emissions from these vehicles which are 24 approximately three to five times more polluting 25 than a regular car suggests that these vehicles are Vincent Varallo Associates, Inc. ------- 149 1 Jina Porreco - Clean Air Network 2 contributing more than their fair share to the smog 3 problem. 4 In order to begin to mitigate the health 5 risks to women and their families, WHEN would like 6 to encourage EPA to adopt the following: Reduce car 7 emissions and particulate matters from diesel 8 engines by 90 percent by 2007, reduce the sulfur 9 levels in diesel fuels, and to require in-use and 10 on-board diagnostic equipment in all heavy-duty 11 trucks by 2004. 12 Potential costs for asthma-related 13 illnesses will only increase unless we begin to 14 adopt preventative measures. The most vulnerable of 15 our population are the children who continue to 16 confront the chronic disease head-on unless we put 17 into place stronger standards. 18 The most stringent standards are another 19 way to begin this process and must be adopted in 20 order to lessen the health effects of smog on 21 Americans. Thank you. 22 MS. OGE: Thank you. 23 Ms. Jina Porreco. Good afternoon. 24 MS. PORRECO: Good afternoon. My name 25 is Jina Porreco with the Clean Air Network. I'm Vincent Varallo Associates, Inc. ------- 150 1 Jina Porreco Clean Air Network 2 here on behalf of 51 citizens, environmental and 3 public health groups from across the country that 4 couldn't be here today. Thank you for providing us 5 an opportunity to voice our concerns about the need 6 to reduce air pollution from trucks, buses, and 7 support utility vehicles. 8 Air pollution is a major threat to 9 public health in the US. One in three Americans 10 live in areas that do not meet EPA's public health 11 standards for air quality. Millions more live in 12 areas that exceed acceptable toxic risks. Those 13 more sensitive to the harmful effects of air 14 pollution make up a large portion of the general 15 population, children, the elderly, people with heart 16 and lung disease and the poor. Nationwide, air 17 pollutions sends more than 150,000 Americans to 18 emergency rooms each year and causes more than 19 6 million asthma attacks. Even worse, particulate 20 air pollution is responsible for cutting short lives 21 of more than 40,000 Americans each year. In at 22 least a handful of cities, up to 60 percent of fine 23 particle pollution continue to be diesel exhaust. 24 in addition to causing respiratory harm, it is also 25 a significant source of air toxics that can cause Vincent Varallo Associates, Inc. ------- 151 1 Jina Porreco - Clean Air Network 2 cancer. EPA has found emission from cars trucks and 3 buses account for the bulk of cancer - causing 4 pollut ion. 5 Despite the widespread health threats 6 associated with chronic exposure to diesel 7 pollution, we still encounter diesel buses, 8 18-wheelers, and trucks belching thick black smoke. 9 The fact that such visible sources of air pollution 10 are still uncontrolled illustrates EPA's great 11 failures for the past three decades. In fact, our 12 current diesel truck standards are lower than car 13 standards of the mid-1970s. 14 As we enter the 21st century, we need a 15 infrastructure that is clean, efficient, and doesn't 16 pose a health threat. Technologies are available 17 today that can significantly curb diesel emissions 18 from trucks and buses. It is time that the 19 manufactures are required to improve the diesel 20 engines, much like car manufacturers had to do over 21 the past three decades. 22 And while shining up the new fleet of 23 diesel engines are clean, EPA must equally commit to ,24 cleaning up the existing fleet of diesel trucks and 25 buses. Vincent VaraUo Associates, Inc. ------- 152 1 Jina Porreco Clean Air Network 2 We are very pleased that EPA has finally 3 taken steps to reduce air pollution from trucks, 4 buses, and SUVs. We're particularly pleased with 5 EPA's decision to close the loophole in Tier 2 that 6 allows SUVs to emit up to five times more pollution 7 than a car. We are also encouraged with EPA's 8 proposal to set tough standards on trucks, buses, 9 and diesel fuel. 10 However, we're concerned the time we are 11 facing a stricter engine emissions standards and 12 clean diesel fuel is unnecessarily long, thereby 13 delaying any health benefits for nearly a decade. 14 Furthermore, we are concerned that EPA's 15 Phase 2 may not adequate ensure that trucks comply 16 with the standards over their lifetimes. 17 Specifically, we urge EPA to consider 18 the following five points to strengthen the 19 heavy-duty program: 20 Point 1, accelerate the time line for 21 posing gas and diesel fuel. Under the Tier 2 auto 22 pollution program, all cars and smaller SUVs will be 23 required to meet clean car a standards by 2007. 24 There's no technological need to give automakers 25 another two years to clean up the largest and Vincent Varallo Associates, Inc. ------- 153 1 Jina Porreco Clean Air Network 2 dirtiest SUVs. All passenger vehicles should meet 3 clean car standards 2007. 4 Number 2, tighten the heavy-duty 5 particulate standards by 2004. Emission catalysts 6 are available today that can reduce the particulate 7 pollution by 50 percent. Urban buses are already 8 required to meet the tougher particulate standard. 9 For these reason, in the interim, all buses and 10 trucks should be healthier standards of .5 grams per 11 brake horsepower hour by 2004. Current particulate 12 reduction should then be phased in by 2007. That 13 would result in an additional 90 percent reduction 14 by the 2004 standards. 15 Number 3, clean up diesel fuel for on- 16 and off road engines,-as we feel the Tier 2 proposal 17 significant added emission reduction benefits can be 18 achieved if gasoline cars are brought into 19 low-sulfur fuel. The same is true for the diesel 20 engine. Rather than waiting until 2007 to clean up 21 diesel fuel, EPA should favor lower sulfur diesel 22 fuel between 2004 and 2007 and cap diesel sulfur at 23 no more than 10 parts per million by 2007. 24 Low-sulfur diesel is the only strategy for curbing 25 diesel exhaust in existing trucks and buses. By not Vincent Varallo Associates, Inc. ------- 154 1 Jina Porreco - Clean Air Network 2 putting in low-sulfur diesel before 2007, the 3 existing fleet will remain largely uncontrolled for 4 nearly another decade. Low-sulfur diesel fuel 5 should be also be required for off road diesel 6 fleet. According to EPA's own estimates, off road 7 diesel vehicles, like construction equipment, 8 account for 23 percent of all NOx pollution and 15 9 percent of VOC pollution nationwide. The off-road 10 fleet is nearly 15 times more polluting than on-road 11 engines, which account for 10 percent of NOx 12 emissions and 1 percent of VOC emissions. We are 13 alarmed to learn that EPA tends to exclude engines 14 from the clean sulfur requirement. This would be a 15 serious and negligent shortcoming of the diesel 16 strategy. 17 Point number 4, adopt strong standards 18 for 2007. EPA should set two-thirds standard at 19 least as strict as .01 grams per brake horsepower 20 hour and NOx standard of .2 grams per brake 21 horsepower hour by 2007. These low emission levels 22 could be enough with low-sulfur diesel fuel. 23 And finally, point 5, ensure that trucks 24 stay clean once they are on the road. Diesel 25 engines travel hundreds of thousands of miles over Vincent Varallo Associates, Inc. ------- 155 1 Jina Porreco - Clean Air Network 2 their lifetimes. Tests performed on an engine 3 before it leaves the plant often do not reflect 4 on-road emissions caused by engines. For this 5 reason, a car owners in cities throughout the 6 country were required for over a decade to have 7 their emissions checked to ensure they are meeting 8 allowable pollution levels. And new cars are 9 equipped with on board diagnostic equipment. The 10 same safeguards should be in place for large trucks. 11 In order to ensure that clean trucks stay clean, 12 in-use testing and on- board diagnostic equipment 13 should be required for all heavy-duty trucks, both 14 gasoline and diesels. 15 Thank you again for providing us an 16 opportunity to voice our support and concerns about 17 your proposed heavy-duty engine program. While we 18 feel this is an important first step, we urge you to 19 consider our recommendations for improving the 20 effectiveness of your program. 21 Finally, we can't stress enough the 22 importance of your finalizing the heavy-duty program 23 before the end of 2000. Thank you. 24 MS. OGE: Thank you. Any questions? 25 (No response.) Vincent Varallo Associates, Inc. ------- 156 1 Angle Farleigh US PIRG 2 MS. OGE: Thank you very much. 3 I'd like to call the next panel. Ms. 4 Angle Farleigh, Ms. Emily Bertram, Mr. John Duerr, 5 Mr. Kevin Stewart, and Mr. Alan Schaeffer. Please 6 print your names on the cards in front of you. 7 Ms. Farleigh, we will start with you. 8 Good afternoon. 9 MS. FARLEIGH: Good afternoon. My name 10 is Angie Farleigh, and I'm a clean air activist for 11 the U.S. Public Interest Research Group. US PIRG is 12 the national lobby often for the state PIRGs, 13 consumer and environmental group representing 14 citizens in over 40 states across the country. 15 I greatly appreciate the opportunity to 16 talk about the need to reduce air pollution from 17 heavy-duty vehicles, especially the large passenger 18 SUVs. 19 Across the country, air pollution is 20 taking an enormous toll on public health. 21 Nationwide air pollution sends more than a 150,000 22 Americans to emergency rooms each year and causes 23 more than 6 million asthma attacks. During the 24 summer smog season air pollution causes an asthma 25 attack once every three seconds. Even worse, Vincent Varallo Associates, Inc. ------- 157 1 Angle Farleigh US PIRG 2 particulate air pollution is responsible for cutting 3 short the lives of more than 40,000 Americans each 4 year. Heavy-duty vehicles, including diesel and 5 gasoline powered vehicles over 8500 pounds, are the 6 biggest causes of air pollution problems. In urban 7 areas as much as 50 percent of the deadly 8 particulate pollution we breathe comes from diesel 9 vehicles. What's especially disturbing about diesel 10 pollution is that it contains hundreds of toxic 11 substances, and more than 30 health studies have 12 linked diesel pollution to lung cancer. 13 The manufacturers of diesel engines and 14 big trucks need to start using widely available 15 technologies to reduce their pollution. Yet, we 16 know that we cannot count upon them to do this 17 voluntarily, nor can we rely on the manufacturers to 18 obey the rules without strict monitoring and 19 enforcement. Several people have already mentioned 20 the landmark settlement last year when seven of the 21 largest diesel engine manufacturers were discovered 22 to be cheating on emission tests which resulted in 23 an increase of smog pollution of over l million tons 24 each year. 25 As some of you may know, PIRG campaigned Vincent Varallo Associates, Inc. ------- 158 1 Angle Farleigh US PIRG 2 last summer in support of tougher emission standards 3 for passenger vehicles and to close the SUV loophole 4 that allowed SUVs to emit three to five times more 5 pollution than a passenger car. We are, therefore, 6 pleased with EPA's proposal to hold the largest 7 passenger SUVs to the same tough Tier 2 standards as 8 other passenger vehicles. We also agree with your 9 goal to set tough standards on heavy-duty vehicles 10 and fuels that power them, as well as to require 11 strict tests to ensure compliance with the standard. 12 However, we are extremely concerned that 13 the proposal is phased in over an unnecessarily long 14 period of time resulting in delayed health benefits 15 and that the proposal may not adequately ensure that 16 the heavy-duty trucks comply with the standards 17 throughout their useful life. Specifically, I will 18 highlight five changes that should be made to 19 strengthen the heavy-duty program. 20 First, the heavy-duty particulate 21 standard must be tightened by 2004. And as Mr. 22 Bertelsen testified earlier, MECA has shown that the 23 technology is already available to cut particulate 24 pollution from heavy-duty trucks to .05 grams per 25 horsepower hour by using existing oxidation Vincent Varallo Associates, Inc. ------- 159 1 Angle Farleigh - US PIRG 2 catalysts. Yet the current proposal will have the 3 public wait until at least 2007 before any 4 reductions in PM from heavy-duty trucks would occur. This delay will contribute to the premature deaths 6 of thousands of Americans. 7 Secondly, the time line for closing the 8 SUV loophole must be accelerated. Under the Tier 2 9 program, all cars and small SUVs would be required 10 to fully meet new car standards by 2007. The 11 largest and dirtiest vehicles should not have an 12 extra two years before they must fully comply with 13 EPA standards. All passenger vehicles, regardless 14 of size, should meet clean car standards by 2007. 15 Third, EPA must adopt strong standards 16 by 2007. Pollution from heavy-duty vehicles is an 17 urgent problem and must be addressed as soon as 18 possible. There are several public studies that 19 show that by using various combinations of existing 20 technologies, manufacturers can reduction NOx 21 emissions to below the standards without an increase 22 in particulate matter. The EPA must forge ahead as 23 the agency announced in its second phase strategy 24 and adopt additional standards in 2007 that would 25 require a 90 percent reduction beyond the 2004 Vincent Varallo Associates, Inc. ------- 160 1 Kevin Stewart ALAPA 2 standards of both PM and nitrogen oxides. 3 Also, in order to achieve necessary 4 pollution reductions, the EPA must clean up diesel 5 fuel. Pollution control systems can be truly 6 effective only when they are coupled with low-sulfur 7 fuels. In fact, current sulfur levels in diesel are 8 so high, they actually prevent the use of most of 9 the advanced pollution control technologies we have. 10 In order to ensure that diesel pollution 11 equipment is effective, all diesel fuel sulfur 12 levels for both on- and off-road diesel fuels should 13 be capped at 10 parts per million sulfur by 2006 or 14 before the 2000 standards go into effect. 15 Finally, the EPA must ensure that the 16 trucks stay clean once they're on the road by 17 requiring in-use testing and on-board diagnostics 18 equipment from all heavy-duty trucks, both gasoline 19 and diesels. 20 Once again, I thank you for allowing me 21 to speak on this. 22 MS. OGE: Thank you. 23 Mr. Stewart, good afternoon. 24 MR. STEWART: Good afternoon. The 25 American Lung Association of Pennsylvania, ALAPA, Vincent Varallo Associates, Inc. ------- 161 1 Kevin Stewart - ALAPA 2 appreciates the opportunity to present comments to 3 the EPA concerning the proposed rule. My name is 4 Kevin Stewart. I hold a Bachelor of Science Degree 5 in chemical engineering from Princeton University, 6 and as part of my duties I serve ALAPA as 7 environmental specialist. 8 I'm here today not only to represent the 9 Lung Association, but the interest of everyone who 10 breathes outdoor air. In fact, I'm here primarily 11 to help represent the interest of more than 30 12 million Americans who struggle with chronic lung 13 disease, and of the one-and-a-third million or some 14 Pennsylvanians who do. These are people most at 15 risk for health problems precipitated by air 16 pollution. Indeed, many of them are people who 17 simply cannot depend on outdoor air quality without 18 risking an unplanned trip to the hospital because of 19 the effects of air pollution. 20 ALAPA was founded 107 years ago to 21 combat tuberculosis, and we are now dedicated to the 22 prevention of lung disease and the promotion of lung 23 health. ALAPA commends EPA for issuing a good 24 proposal; nonetheless, it can be strengthened in 25 several ways. Ozone smog continues to be frequently Vincent Varallo Associates, Inc. ------- 162 1 Kevin Stewart ALAPA 2 recorded at levels that are hazardous to health. 3 Not only are more stringent vehicle and fuel 4 standards a necessary part of the solution preventing thousands of cases of death and disease, 6 but cost effective technology soon will be 7 available, and in some cases, already is available, 8 to meet such standards. It is on this basis that 9 ALAPA calls for the adoption and expeditious 10 implementation of strong national standards for 11 emissions from heavy-duty vehicles and for the fuel 12 that is used to operate them. We also call on EPA 13 to make sure that these vehicles comply with those 14 emission standards for as long as the vehicles 15 remain in use. 16 While I've deferred today to other 17 representatives of American Lung Association who 18 have submitted to the docket more detailed comments 19 on the proposed rule, I will make several brief 20 comments on the rule itself. But before that, I 21 will strive to show you what the presence of these 22 pollutants in the air we breathe means to the people 23 of Pennsylvania. 24 Despite what progress we've made over 25 the last 30 years, air pollution continues to be a Vincent Varallo Associates, Inc. ------- 163 1 Kevin Stewart ALAPA 2 very real and very serious problem. Pennsylvania 3 experiences dozens of days every year during which 4 unhealthful ozone levels are record. My hometown 5 of Lancaster, for example, experienced 25 days of 6 unhealthful ozone this year and is now in violation 7 of even the rather weak one-hour standard. Motor 8 vehicles, along with the entire network that 9 supports their use, are significant sources of air 10 pollution ranging from ozone precursors to 11 particulate matter to air toxics. And lest we lose 12 sight of the fact, air pollution constitutes a real 13 problem. It causes real suffering and even death to 14 real people- Four groups are at special risk: 15 infants and pre- adolescence children, the elderly, 16 persons with asthma, and those with COPD, chronic 17 obstructive pulmonary disease, chronic bronchitis, 18 and emphysema. 19 In Pennsylvania, the populations of 20 those at risk from ozone and particulate air 21 pollution include two million children at or below 22 the age of 13 and 1.7 million people aged 65 or 23 above. Furthermore, ALAPA reiterates today that 24 about 11 percent, 1 in 9, of the Commonwealth's 25 citizens suffer from 1 or more major chronic lung Vincent Varallo Associates, Inc. ------- 164 1 Kevin Stewart - ALAPA 2 diseases and are particularly at risk from air pollution. Among them are the more than 700,000 4 individuals who suffer from COPD. And in addition, 5 recent estimates show that some 800,000 citizens of 6 this state has asthma. About 30 percent of these 7 people are under 18, for whom asthma is the 8 number-one for hospitalization due to chronic 9 illness. It is also the number-one cause of school 10 absences attributed to chronic conditions, leading 11 to an average of a week and a half of school missed 12 annually by each student who has asthma. Even more 13 alarming, deaths from asthma have been climbing 14 steeply, increasing by 117 percent nationwide, from 15 2,598 in 1979 to 5,637 in 1995, with the increase 16 focusing among children and the elderly. 17 In Pennsylvania alone, studies show, 18 ambient air pollution is responsible for hundreds of 19 thousands of days with acute respiratory symptoms 20 and/or restricted activity for tens of thousands of 21 asthma symptoms days, for thousands of emergency 22 j room visits for respiratory problems and thousands 23 of excess hospital admissions for respiratory 24 diagnoses such as asthma, pneumonia, and COPD. And 25 finally, air pollution from vehicles alone is also Vincent Varallo Associates, Inc. ------- 165 1 Kevin Stewart - ALAPA 2 responsible for hundreds of premature deaths in the 3 Commonwealth every year. 4 As for my comments on the proposed rule 5 itself, we at ALAPA have several concerns and think 6 that the proposals can be strengthened in the 7 following ways: 8 One, given the fact that the technology 9 necessary for the largest support utility vehicles 10 to meet the proposed standards is already available, 11 within EPA's estimated cost range, and with the 12 added benefit of significant reductions in emissions 13 of air toxics, it is ALAPA's opinion that there is 14 no reasons to delay implementation of the standards 15 relative to those already set out for lighter SUVs 16 in the Tier 2 proposal. Eight years, by 2007, is 17 more than enough time to implement the new 18 standards. 19 The heavy-duty fine particulate emission 20 standard should be tightened at least 50 percent by 21 2004 rather than having the public wait until at 22 least 2007 for any reductions with the concomitant 23 illness and mortality. 24 Number 3, furthermore, under its 25 proposed anticipated Phase 2 strategy, EPA should Vincent Varallo Associates, Inc. ------- 166 1 Kevin Stewart - ALAPA 2 set a nitrogen dioxide emission standard stricter 3 than 0.2 grams per brake horsepower hour and a 4 particulate matter emission stand stricter than 0.01 5 grams per brake horsepower hour, and should proceed 6 to adopt these standards under an accelerated 7 schedule, preferably by 2004, with the paired 8 requirements that the best available control 9 technology be used, and that low-sulfur diesel fuel, 10 removing at least 90 percent of sulfur, preferably 11 more, be put into place. 12 Number 4, there should be no sense to 13 continue to allow sulfur levels in fuel to be as 14 high as 500 parts per million when we know that such 15 fuel wastes much of the investment spent on the 16 cleaner burning technologies. We must work harder 17 to get the highest sulfur fuels out of the market 18 sooner. 19 Five, finally, EPA must take steps to 20 ensure that in-use emissions from all heavy-duty 21 vehicles, both gasoline and diesel, both highway and 22 non-highway, actually meet the standards. The past 23 behavior of some engine manufacturers 24 notwithstanding, this is not a game. In-use testing 25 and on-board diagnostics should also be required. Vincent Varallo Associates, Inc. ------- 167 1 Emily Bertram NET 2 In conclusion, we know that ozone and 3 particulate air pollution in Pennsylvania, much of 4 it from vehicle emissions, adversely affects the health of substantial numbers, indeed millions of 6 our citizens. And we know that those adverse health 7 effects are substantial, resulting in thousands of 8 hospital admissions, emergency room visits, and even 9 deaths, with further costs of hundreds of thousands 10 of disrupted lives and hundreds of millions, perhaps 11 billions, of dollars. It is now clearly our 12 national task to attain and maintain helpful air 13 quality. The only way we can begin to do that is to 14 recognize the full reality of air pollution problems 15 and to face them unflinchingly. 16 There's one thought I'd like to leave 17 you with, one to remind of. It's that air pollution 18 not simply am inconvenience. Being unable to catch 19 your breath is not an inconvenience. Trips to the 20 emergency room, hospitalization, and deaths are not 21 inconveniences. Remember, it's a health issue. 22 MS. OGE: Thank you. 23 Ms. Emily Bertram, good afternoon. 24 MS. BERTRAM: Good afternoon. My name 25 is Emily Bertram, and I am the Delaware field Vincent Varallo Associates, Inc. ------- 168 1 Emily Bertram NET 2 organizer for National Environmental Trust. 3 National Environmental Trust is non-profit, 4 non-partisan organization dedicated to educating the 5 American public on contemporary environmental 6 issues. Since it was founded in 1995, National 7 Environmental Trust has worked to promote strong 8 health, safety, and environmental protections on 9 issues including food, air, drinking water safety, 10 global climate change, and public right to-know 11 policies. 12 As the Delaware field organizer, I spend 13 a great deal of time interacting with different 14 communities throughout the state, particularly the 15 cities of Wilmington and Newark. I have particular 16 concern for the well-being of Delawareans and the 17 preservation of the surrounding natural environment. 18 Thank you for giving me the opportunity to voice my 19 concerns about the need to reduce air pollution from 20 heavy-duty vehicles. 21 In the state of Delaware, air pollution 22 has taken an enormous toll on human health. In a 23 mid-season report released in August 1999, ozone 24 monitors in Delaware reported 54 exceedences of the 25 eight-hour ozone health standard and a total of 12 Vincent Varallo Associates, Inc. ------- 169 1 Emily Bertram NET 2 days of unhealthy air. For example, the peak ozone 3 level at Lums Pond, a recreational area in New 4 Castle County, Delaware, was 119 parts per billion, 5 a full 33 percent higher than the health standard. 6 Peak ozone levels in the beach communities this 7 summer were recorded at 104 parts per billion, while 8 ozone levels in Wilmington, Delaware's largest city, 9 were recorded at 98 parts per billion. 10 Heavy-duty diesel trucks and buses, as 11 well as large SUVs, are among the biggest 12 contributors to smog in Delaware. Delaware serves 13 as a thruway for traffic traveling between the New 14 York-Philadelphia and Baltimore-Washington 15 metropolitan areas. Unfortunately, pollution from 16 all the trucks, buses, and large SUVs on such 17 highways as 1-95 tends to be transported through the 18 atmosphere and accumulates over the State of 19 Delaware. Beach traffic in the southern part of the 20 state also contributes to an overall increase in 21 pollution levels in the summer months. 22 High pollution levels pose a serious 23 health threat to Delawareans. Children, the 24 elderly, and the asthmatics are particularly 25 vulnerable to smog. According to a recent study, Vincent Varallo Associates, Inc. ------- 170 1 Emily Bertram NET 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 smog sends 210 Delawareans to the hospital and causes 25,000 asthma attacks in Delaware each summer. Nationwide, asthma rates among children are up 75 percent since 1980, with 4.6 million children suffering from asthma. Smog is responsible for up to 10 percent of all hospital admissions during the summer months. The Delaware field office of National Environmental Trust applauds EPA for their proposal to clean up the nation's largest and dirtiest vehicles. However, we would encourage EPA to consider the following changes in order to strengthen the heavy-duty program: First, accelerate the time line for closing the SUV loophole. Under the Tier 2 auto pollution program, all cars and smaller SUVs will be required to meet clean car standards by 2007. However, under the heavy-duty vehicle proposal, automakers would have until 2009 to clean up larger SUVs. All passenger vehicles, no matter what their size, should meet clean car standards by 2007. Second, tighten the heavy-duty particulate standard at least 50 percent by 2004. 25 The current proposal would have the public wait Vincent Varallo Associates, Inc. ------- 171 1 Emily Bertram - NET 2 until at least 2007 before any reductions in 3 particulate pollution from heavy-duty trucks would 4 occur. This delay will contribute to the premature 5 deaths of thousands of Americans. 6 Third, adopt stronger standards for 7 2007. Pollution from heavy-duty vehicles is an 8 urgent problem that must be addressed as soon as 9 possible. By 2007, smog-forming pollution and 10 particulate pollution from heavy-duty vehicles 11 should be lowered by 90 percent beyond 2004 12 standards. 13 Fourth, clean up diesel fuel. Pollution 14 control systems can be truly effective only when 15 they are coupled with low-sulfur fuels. To ensure 16 that diesel pollution equipment is effective, all 17 diesel fuel sulfur levels in both on-road and 18 off-road diesel fuels should be capped at 10 parts 19 per million sulfur by 2008. 20 Finally, ensure that the trucks stay 21 clean once they are on the road. Lab tests rarely 22 reflect the true on-road emissions. To ensure that 23 clean trucks stay clean, in-use testing and on-board 24 diagnostic equipment should be required for all 25 heavy-duty trucks, both gasoline and diesel. Vincent Varallo Associates, Inc. ------- 172 1 John Duerr - Detroit Diesel 2 These measures are critical to the 3 protection of the public health and the natural 4 environment. 5 Thank you. 6 MS. OGE: Thank you. 7 Mr. John Duerr. Good afternoon. 8 MR. DUERR: Good afternoon. My name 9 John Duerr, and I'm here representing Detroit Diesel 10 Corporation. Detroit Diesel is a major manufacturer 11 of diesel engines used in a wide variety of 12 on-highway vehicles. The rulemaking that is the 13 subject of today's hearing proposes several new 14 requirements for these engines. 15 We appreciate this opportunity to 16 provide our views on this proposed rule. Let me 17 begin by stating that Detroit Diesel fully endorses 18 the comments of the EMA. Let me go on to state that 19 Detroit Diesel generally supports EPA's affirmation 20 of the 2004 standards and many of the other 21 provisions included in this proposed rulemaking. I 22 had hoped that we would be in a position to provide 23 much more detailed comments at this hearing. 24 Unfortunately, this is not the case. 25 This rulemaking was first made available Vincent Varallo Associates, Inc. ------- 173 1 John Duerr - Detroit Diesel 2 for public review on October 7th when it was posted 3 on the EPA web site. Since then, we have been 4 trying to review and digest nearly 600 pages of regulatory documents. This has not been an easy 6 task. The proposed rule contains a number of very 7 complex and interrelated provisions that greatly 8 modify the existing regulatory program for 9 heavy-duty engines. A number of the changes were 10 incorporated in the proposed rule at the last minute 11 and were not previously discussed with industry. 12 The impacts of these changes are potentially 13 far-reaching and difficult to evaluate. Further 14 complicating our assessment of the proposed rule is 15 the fact that the rule contains drafting errors, 16 inconsistencies, and entire sections that lacks 17 clarity. 18 DDC has three primary concerns with the 19 current state of the rulemaking. First of all, the 20 lack of adequate time for review and the 21 inconsistencies in the rule leave us unclear about 22 several of the provisions and the requirements we 23 will need to meet under the proposed rule- 24 Secondly, certain requirements, as we 25 understand them, may in fact lead to a greater level Vincent Varallo Associates, Inc. ------- 174 1 John Duerr - Detroit Diesel 2 of stringency than we had previously understood. 3 Furthermore, certain test requirements, while not necessarily adding stringency, add 5 substantial cost with little or no emission benefit. 6 Finally, EPA has not provided any data 7 or analysis that addresses the question of whether 8 the 2004 standards are feasible with current levels 9 of fuel sulfur while also meeting the extended 10 useful life and supplemental test requirements. The 11 lack of information on this critical issue puts us 12 in an environment of making important decisions 13 regarding feasibility without adequate information. 14 To help in clarifying the point about 15 the lack of clarity in the proposed rule, let me 16 provide a couple of examples which may seem small 17 and detailed, but are actually critical to our 18 understanding the requirements of this rule. 19 Consider the equation in Paragraph 20 (e)(5) of Section 86.1360-2004 as shown here. This 21 equation is to be used to compute the weighted 22 average emissions for each regulated gaseous 23 emissions over the proposed supplemental 24 steady-state emission test. Leaving aside the fact 25 that this equation will always return a value of Vincent Varallo Associates, Inc. ------- 175 1 John Duerr - Detroit Diesel 2 infinity, and thus is obviously incorrect, we note 3 that the factor A(wm) used in this equation is 4 identified as weighted mass emission level as 5 defined in existing Section 86.1342. A(wm) as it is 6 defined in 86.1342 is the weighted brake specific 7 mass emissions from the cold/hot transient federal 8 test cycle. Clearly, this is not an appropriate 9 value for inclusion in computing emissions from the 10 steady-state test. We also note that even though a 11 particulate standard is proposed for the 12 supplemental steady-state test, this section fails 13 to describe how the weighted particulate emissions 14 are to be computed. 15 A second example concerns Section 16 86.1008-90 which states that engines chosen for 17 Selective Enforcement Audit testing are to be tested 18 on the Federal Test Procedure described in Subpart 19 N. The proposed rule adds several new supplementary 20 teat procedures to Subpart N. It is not clear if 21 EPA intends to require that these new supplementary 22 tests be run as part of any Selective Enforcement 23 Audit. And if these supplementary tests are 24 required to be run, EPA has not specified the 25 ambient conditions and other test protocols to be Vincent Varallo Associates, Inc. ------- 176 1 John Duerr - Detroit Diesel 2 used when these supplemental tests are run as part 3 of an audit. Further, there is no definition of how 4 compliance with the newly proposed not - to-exceed and 5 maximum allowable emission limits will be determined 6 and how overall audit pass/fail decisions will be 7 made. Without a clear understanding of how 8 Selective Enforcement Audits will be conducted and 9 judged, DDC cannot provide constructive comments nor 10 can we as a company determine the impact of our 11 products, and the feasibility of meeting the 12 agency's expectations. 13 While these examples may seem to address 14 fine technical points of the regulation, they are, 15 in fact, important issues that may have substantial 16 impact on our products and the stringency, 17 feasibility, and cost effectiveness of the rule. 18 Furthermore, these examples are not isolated, but 19 are representative of a great many cases where the 20 proposed rules are incomplete or unclear. Because 21 of the lack of clarity in the proposed regulations, 22 we are having difficulty in understanding the 23 agency's intent and thus are unable to comment 24 meaningfully and constructively on the proposal. 25 Indeed, unless steps are taken to redraft the Vincent Varallo Associates, Inc. ------- 177 1 John Duerr Detroit Diesel 2 proposal so that the agency's intent is made 3 sufficiently clear to allow interested parties to understand the proposal and provide meaningful comments, we believe the fundamental principles of 6 due process will have been shortchanged. We know 7 that EPA and the industry share a common interest in 8 ensuring that the regulations that are finally 9 promulgated are clear, correct, and unambiguous. To 10 ensure that the public process is not shortchanged 11 and that the final rule is free of uncertainty and 12 inconsistency, we believe EPA must extend the 13 comment period by at least 60 days and work closely 14 with the various stakeholders during this period. 15 These regulations will be in effect for several 16 years. Surely, there is no reason not to take the 17 time to make certain this rule is the best we can 18 make. 19 While many of the details of the 20 proposed rule are unclear, it is clear that EPA 21 intends to impose several new testing requirements 22 and associated emission limits. These include a 23 supplementary steady-state emission test, maximum 24 allowable emission limits, not - to-exceed emission 25 limits, and load response testing. These additional Vincent Varallo Associates, Inc. ------- 178 1 John Duerr Detroit Diesel 2 requirements will add considerably to the cost of 3 engine development and certification and will extend 4 the time needed to bring new low emission technology 5 to market. Collectively, they constitute a belt and 6 suspenders example of regulatory overkill. To 7 reduce redundancy and improve the overall 8 cost - effectiveness of the proposed rule, we believe 9 that, at a minimum, the maximum allowable emission 10 limit and load response test requirements should be 11 eliminated and that the not - to-exceed provisions 12 should be greatly simplified. 13 In conclusion, DDC requests additional 14 time to provide constructive and complete input 15 based on a clear understanding of the proposed 16 requirements. We request that the agency carefully 17 review the necessity of all the proposed additional 18 testing requirements in light of the marginal 19 emission benefits of these provisions. 20 Finally, we believe additional data 21 gathering and information development is needed 22 before it can be determined that the 2004 emission 23 standards remain feasible when combined with 24 extended useful life and supplemental test 25 requirements and without any improvements in diesel Vincent Varallo Associates, Inc. ------- 179 1 Alan Schaeffer - American Trucking Association 2 fuel quality. 3 Detroit Diesel is continuing to review 4 and study the proposal. We anticipate providing 5 comments on as many of the critical issues as 6 possible within the allowed comment period. If DDC 7 concludes that the proposed rule increases 8 stringency beyond the level that we have agreed to 9 meet in October 2002 as result of our agreement, 10 then DDC will object to this rule. 11 Thank you. 12 MS. OGE: Thank you. 13 Mr. Alan Schaeffer. Good afternoon. 14 MR. SCHAEFFER: Thank you. Good 15 afternoon. My name is Alan Schaeffer and I'm vice 16 president of highway environmental policies for the 17 American Trucking Association located in Alexander, 18 Virginia. Thanks for the opportunity to appear here 19 today on the important issue of diesel engine 20 emission standards. Just as a matter of record, ATA 21 is a national trade association representing 22 America's trucking industry. We represent over 23 3,000 members directly of all types and sizes of 24 trucking companies throughout America. Within our 25 federation of state affiliates, collectively that Vincent Varallo Associates, Inc. ------- 180 1 Alan Schaeffer - American Trucking Association 2 numbers jumps to 35,000 trucking companies 3 nationwide. 4 I'm here today on behalf of the users of 5 heavy-duty diesel trucks. Most of our members operate vehicles over 8500 pounds, and most of those are over 26,000 pounds in weight. The trucking industry does the work that 9 all of us in the economy demand, and everything you 10 see here today and brought with you today, that you 11 ate today, that you're wearing today, was brought to 12 you by a truck. And because of that, our industry 13 demands the most cost effective, fuel efficient, and 14 lowest polluting technology available, and we 15 believe that the engine manufacturers are delivering 16 that technology. 17 Also, as matter of record, the trucking 18 industry has a long record of responsibility 19 supporting clean air standards. Let me highlight a 20 few of those. We supported the change to lower 21 sulfur diesel fuel back in 1993. We support limits 22 on discretionary items. We support vehicle smoke 23 emissions inspection programs at the state level. 24 And we are here today to offer our support for the 25 2004 lower engine standards. We have been involved Vincent Varallo Associates, Inc. ------- 181 1 Alan Schaeffer - American Trucking Association 2 in the 1996 standard proposal and joined EPA at the 3 press conference in Chicago, along with the engine 4 manufacturers, to endorse more stringent lower 5 emission standards in 2004, knowing full well that 6 may increase the cost of the trucking industry. 7 However, we felt that that was the responsible thing 8 to do for the environment to help reduce pollution. 9 Our commitment has been heightened in 10 the last six months. In June our executive 11 committee adopted more aggressive policy urging 12 states to begin enforcement against smoke emissions, 13 and just on Sunday of this week we adopted a 14 resolution supporting a national diesel fuel 15 standard with details to follow. 16 And the commitment by the trucking 17 industry has paid off. Today's new truck engines 18 emits one-eighth of pollution of engines built just 19 10 years ago. That's a significant record. 20 Highway diesel truck emissions have 21 played an important role in dramatically improving 22 air quality overall in recent years. A lot of what 23 we have heard today is the negative, that is, how 24 bad things are; but consider the positive about air 25 quality. In the period of 1970 to 1997, the first Vincent Varallo Associates, Inc. ------- 182 1 Alan Schaeffer American Trucking Association 2 domestic product of the United States grew by 114 3 percent constant dollars. Our population grew by 31 4 percent. At same time our total criteria for 5 pollutant emissions declined by 34 percent. 6 Significant improvements have been made in air 7 pollution, and the trucking industry is proud to 8 contribute its fair share. 9 I'd like to address a couple aspects of 10 the notice today. First of all, on the concept of 11 feasibility, it was our view initially having 12 assessed this proposed rule in the limited time 13 we've had to do it, that in fact this is technically 14 feasible milestone in 2004. However, I must admit 15 to the agency that I'm becoming concerned that what 16 appears to have been agreed on in 1997 in fact 17 become a final rule, that the landscape has been 18 dramatically altered since that time. And that 19 landscape has been altered without public input from 20 users, environmental groups, and others in the form 21 of a decent decree process. And I guess we are 22 concerned that the fact that we're hearing more and 23 more from manufacturers about the new limits that 24 the agency is imposing has, in fact, the effect of 25 lowering the standard that is in federal rules Vincent Varallo Associates, Inc. ------- 183 1 Alan Schaeffer - American Trucking Association 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 Vincent Varallo Associates, Inc. ------- 184 1 Alan Schaeffer - American Trucking Association 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 Vincent Varallo Associates, Inc. ------- 185 1 Alan Schaeffer - American Trucking Association 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 Vincent Varallo Associates, Inc. ------- 186 1 Alan Schaeffer - American Trucking Association 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 Vincent Varallo Associates, Inc. ------- 187 1 Alan Schaeffer American Trucking Association 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 Vincent Varallo Associates, Inc. ------- 188 1 Alan Schaeffer - American Trucking Association 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 Vincent Varallo Associates, Inc. ------- 189 1 Alan Schaeffer American Trucking Association 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 Vincent Varallo Associates, Inc. ------- 190 1 Alan Schaeffer American Trucking Association 2 to talk about that, our industry and ATA which 3 represents responsible trucking companies, we agree 4 with you, but get the gross emitters off the road 5. and let's not indict the entire industry for the 6 emissions of just a few. Thank you very much. 7 MS. OGE: Thank you. I will let Bill 8 Becker know. 9 Mr. Duerr, thanks for your statements. 10 I have a couple of questions for you. When did you 11 first see the proposal? When did you have access to 12 the proposal. 13 MR. DUERR: October 7th. 14 MS. OGE: October 7th, so you had almost 15 30 days? 16 MR. DUERR: Yes. 17 MS. OGE: How many times have your 18 company and our staff got together for this past 19 year to discuss this proposal, I mean, details, 20 exhaustive details? Do you remember? 21 MR. DUERR: I don't remember. 22 MS. OGE: I would say many times. 23 MR. DUERR: I don't believe our company 24 ever directly interacted, but we did participate in 25 the manufacturers meetings. Vincent Varallo Associates, Inc. ------- 191 1 Alan Schaeffer - American Trucking Association 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 Vincent Varallo Associates, Inc. ------- 1 2 3 4 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 192 Alan Schaeffer American Trucking Association was to capture the essence of the consent decree supplemental test requirements. So accept that as a premise. What is Detroit Diesel's prospective on lead time, specifically the limitation of the supplemental requirements. MR. DUERR: Obviously, today under the consent decree, we're meeting those requirements. MR. FRANCE: What will you do in 2004? MR. DUERR: In 2004, I don't think we fully know what the impact of all these requirements will be at two and a half gram NOx level. We're still studying that. MR. FRANCE: I understand. To the extent just accept the premise that the consent decree is consistent with the requirement bing 2004 under our rules, okay? What would you like to see the program look like in 2004 from a federal perspective? MR. DUERR: I think I noted I would like to see the maximal allowable emission limits be eliminated, the low response test be eliminated. MR. FRANCE: You're suggesting that we delete not to exceed? 25 MR. DUERR: No, we're suggesting Vincent Varallo Associates, Inc. ------- 193 1 Alan Schaeffer American Trucking Association 2 simplify not to exceed. 3 MR. FRANCE: To make it a minimal 4 requirement in 2004? 5 MR. DUERR: Yes. 6 MR. FRANCE: How do we reconcile that 7 with DMA's comments and others that we can't do 8 that? How do you suggest that we go? 9 MR. DUERR: I don't understand your 10 question. 11 MR. FRANCE: You're suggesting that we 12 do make it mandatory in 2004. 13 MR. DUERR: We're not opposed to that, 14 provided we can get clarity on the regulations. 15 MR. FRANCE: So from Detroit Diesel's 16 perspective, you want to hold the agency to its 17 former lead time concerns that were raised by EMA? 18 MR. DUERR: No. 19 MR. FRANCE: Thanks. 20 MS. OGE: Any other questions? 21 MR. HOROWITZ: Mr. Duerr, did you or 22 anyone from DDC ever see any drafts of the 23 regulations before October 9th, or that date you .24 mentioned? 25 MR. DUERR: I believe there was a Vincent Varallo Associates, Inc. ------- 194 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Alan Schaeffer - American Trucking Association 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. Vincent Varallo Associates, Inc. ------- 195 1 Alan Schaeffer American Trucking Association 2 Mr. Schaeffer: You mentioned about two 3 things that I would follow-up with you. Again, I 4 don't know how much you can disclose at this public 5 hearing, but I would like to know when we can get 6 more details. You mentioned a resolution ATA 7 passed, I believe, last week on diesel fuel quality 8 and I believe you also stated that there is going to 9 be an upcoming meeting in Orlando, Florida -- the 10 weather will be better there than it is here 11 today - where you're going to discuss, I believe, 12 future engine standards with respect to 2007 13 standards. Would you give us a little bit more 14 information if you can and also the timing when we 15 can get more details on the decisions that the ATA 16 is making on these two very important issues. 17 MR. SCHAEFFER: I just came from 18 Orlando, and the weather was much nicer. We are in 19 the midst of our annual meeting with the nation's 20 top trucking executives, and the environmental 21 policy committee on Sunday passed a resolution, 22 basically a two-prong resolution. First, endorsing 23 the concept of a national uniform diesel fuel 24 standard for all diesel users, period. And the 25 second aspect of that was that a task force was Vincent Varallo Associates, Inc. ------- 196 Alan Schaeffer American Trucking Association appointed to investigate all the underpinnings and 3 probably more the issues that you're interested 4 which is the numbers, what levels of sulfur, time 5 frames, and other issues. But the committee felt 6 strongly that the need to speak out now about our 7 general support for a national standard and support 8 for a standard that applies for all diesel users. 9 With regards to further views on 2007, 10 we have a series of meetings next week. We have oil 11 industry representatives and perhaps engine 12 manufacturer representatives with some of our 13 technical committees to try and sort out some of the 14 issues there and try to understand more about the 15 future, and I suspect that we will be ready by the 16 end of the year to be much more specific about what 17 our views are on 2007. But if you look at our past 18 record, we have generally supported standards that 19 are cost-effective that show improvements in fuel 20 economy and durability and reliability and 21 maintainability, and manufacturers have been able to 22 deliver on those accounts. But it appears now that 23 things are getting much more complicated, the 24 standard is getting much lower, and the issues are 25 becoming a bit more tenacious. There are lots Vincent Varallo Associates, Inc. ------- 197 Alan Schaeffer - American Trucking Association obviously, we don't have any influence on 3 certification testing procedure, so we are trying to 4 learn and understand what the impacts of those 5 changes might have on the operators in terms of cost 6 of new engines, cost of operation, and most 7 importantly, the impact on fuel economy. The 8 trucking industry is a very marginal industry. For 9 every one dollar revenue we make, our companies put 10 about two or three cents in their pocket. So you 11 can see that an issue where an engine would cost a 12 lot more or the fuel would cost a lot more could 13 have a broad impact on the industry, and that's why 14 we're putting our stake in the ground now. We think 15 the agency should look more broadly to expand its 16 efforts to control diesel emissions, not just 17 on-highway, but off-highway. We believe that we're 18 producing economies of scale and reducing emissions, 19 diesel fuel standards perhaps of off road sectors. 20 But this industry is responsible. We breathe the 21 same air that you do. We have no interest in a 22 dirty environment. And we will be more specific 23 later this year. 24 MS. OGE: Thank you. Thank you all for 25 coming forward to testify this afternoon. Vincent Varallo Associates, Inc. ------- 198 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 Vincent Varallo Associates, Inc. ------- 199 1 Bob Jorgensen - Cummins Engine Company 2 responsibility for the NRDC campaign, dump dirty 3 diesels. So we may take different steps to get 4 I there, I can tell you that myself and the other engineers at Cummins Engine Company have a very 6 similar responsibility, and we don't take that 7 lightly. I and other members of the Cummins 8 community maintain a strong commitment to make 9 further reductions of emissions of our product. And 10 as the agency is aware, we are investing heavily in 11 the development of emissions reduction technologies 12 that have the potential to reduce pollutant 13 emissions substantially from the today's low levels. 14 Cummins was among the industry 15 participants that collaborated closely with both EPA 16 and CARS in 1995 to reach agreement on a joint 17 statement of principles. The SOP was a novel 18 approach between the agency and the regulated 19 parties designed to obtain commitment to reduce 20 emissions very significantly from on-highway 21 heavy-duty engines, while providing manufacturers 22 the stability certainty, and lead time necessary to 23 meet these stringent standards. The Statement of 24 Principles was memorialized in writing, signed by 25 EPA, the California Air Resources Board, and Vincent Varallo Associates, Inc. ------- 200 1 Bob Jorgensen Cummins Engine Company 2 industry representatives in mid 1995 and included a 3 provision to conduct a Technical Review. In 4 addition to the SOP, the obligation to conduct this 5 review is also set forth in the 1997 rule final 6 establishing the 2004 emissions standards. The SOP 7 and the Rule called for the review of the stringent 8 2004 emissions standards to be completed by the end 9 of 1999. This is, of course, the origin of the 10 proposal before us today. 11 As you know, in 1995 all parties agreed 12 that the stringency of the emissions standards 13 definitely represented a significant technical reach 14 for the companies. Therefore, the parties agreed 15 that the purpose of the Technical Review was to 16 provide an opportunity to review the progress of 17 technology over the nine years between the setting 18 of the standards and their implementation. 19 Furthermore, EPA and CARB and the 20 industry never intended that the 1999 Technical 21 Review to be conducted only in 1999. Rather, the 22 date 1999 was selected as a not later-than date for 23 promulgation of the results of the Review in order 24 to meat lead time requirements of the Clean Air Act. 25 On the basis of where we find ourselves today, it is Vincent Varallo Associates, Inc. ------- 201 1 Bob Jorgensen - Cummins Engine Company 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 Vincent Varallo Associates, Inc. ------- 202 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 Vincent Varallo Associates, Inc. ------- 203 1 Jonathan Sinker NET 2 Jonathan Sinker. I am the field organizer for the 3 National Environmental Trust in Pennsylvania. The 4 National Environmental Trust is a non-profit, 5 non-partisan organization dedicated to educating the 6 American public on contemporary environmental 7 issues. Since it was founded in 1995 as the 8 Environmental Information Center, NET has worked to 9 promote strong health, safety, and environmental 10 protections issues including global climate change, 11 public right to-know policies, and air and drinking 12 water safety. 13 The Clean Air Act mandates that EPA set 14 National Ambient Air Quality Standards that will 15 protect public health. There is no doubt that the 16 air in Pennsylvania is not protective of public 17 health. According to a 1999 Clean Air Task Force 18 report, there were 9600 respiratory related 19 emergency room admissions and 370,000 asthma attacks 20 that can be attributed to air pollution in 21 Pennsylvania. 22 In 1998 Pennsylvania had 616 readings 23 where the eight hour standard was exceeded. Most .24 Pennsylvanians are still regularly exposed to 25 unhealthful levels of ozone. In the Philadelphia Vincent Varallo Associates, Inc. ------- 204 Jonathan Sinker NET 2 area, if you live in Montgomery County the 3 eight hour standard was exceed on 19 different 4 occasions; 14 times in Bucks County; 27 times in Philadelphia County; and 19 times in Delaware 6 County. During the summer of 1998, 27 Pennsylvania 7 Counties exceeded the eight-hour standard. 8 According the EPA, big diesel trucks 9 emit about 10 percent of all NOx emissions 10 nationwide and account for a high percentage of 11 particulate emissions in urban areas. EPA's 12 pollution trends report shows that diesel trucks 13 collectively emit more NOx and particulates soot 14 today than they did in 1970, when the Clean Air Act 15 was passed. In addition, the State of California 16 has labeled diesel particulate as toxic, and EPA 17 researchers believe diesel exhaust is connected with 18 human cancer. 19 NET joins the rest of the environment 20 community in supporting EPA's proposed strategy to 21 reduce emissions from heavy-duty vehicles. 22 NET calls on EPA today to: 23 One, accelerate the time line to close 24 the SUV emissions loophole. Currently SUVs pollute 25 three to five times more than passenger cars. Vincent Varallo Associates, Inc. ------- 205 1 Jonathan Sinker NET 2 Because SUVs emit the lion's share of auto emissions, NET is asking for these vehicles to meet 4 the clean car standard by 2007 as proposed under 5 Tier 2, not 2009 as allowed by EPA's current 6 proposal. 7 Number two, tighten heavy-duty 8 particulate standards by at least 50 percent by 9 2004. Pennsylvanians should not have to wait until 10 2007 as allowed by EPA's current proposal to reduce 11 particulate pollution. Enforcing a tighter standard 12 earlier may delay the amount of premature deaths 13 related to air quality. 14 Number three, set national standards for 15 low-sulfur diesel fuel. Sulfur is poison to the 16 pollution control devices on cars. To ensure the 17 diesel pollution equipment is effective, all diesel 18 fuel sulfur levels should be capped at 10 parts per 19 million by 2006. 20 Number four, since seven of the major 21 diesel engine companies were caught putting cheating 22 devices on their engines that enabled them to pass 23 pre-sale emission tests, but then pollute more on 24 the road, a tighter verification process must be 25 imposed. In-use testing and on-board diagnostic Vincent Varallo Associates, Inc. ------- 206 1 Britta Ipri Clear the Air Campaign 2 equipment should be required for all heavy-duty 3 trucks, both gasoline and diesel to ensure clean 4 trucks stay clean. 5 Number five, adopt strong standards for 6 2007. Pollution from heavy-duty vehicles is a 7 serious problem that must be addressed as soon as 8 possible. By 2007, smog-forming and particulate 9 pollution from heavy duty vehicles should be lowered 10 by 90 percent beyond the 2004 standards. 11 There can be no doubt about the public 12 health need for cleaner motor vehicles. 13 NET reserves the right to submit written 14 comments during the comment period. Thank you. 15 MS. OGE: Thank you. 16 Ms. Britta Ipri, good afternoon. 17 MS. IPRI: Good afternoon. Thank you 18 for the opportunity to speak today. My name is 19 Britta Ipri and I serve as the regional coordinator 20 in the Mid-Atlantic for the Clear the Air Campaign. 21 Clear the Air's primary focus is stationary sources 22 of air pollution such as old, dirty coal power 23 plants. However, as an advocate for clean air, one 24 cannot deny that mobile sources of air pollution 25 must be cleaned up if our region's air is to reach a Vincent Varallo Associates, Inc. ------- 207 1 Britta Ipri Clear the Air Campaign 2 level that is healthy for everyone. 3 Each year in Pennsylvania, air pollution 4 causes the premature death of more than 5,000 people 5 and threatens the health of almost two million more 6 who suffer from asthma and other respiratory 7 illnesses. 8 When considering the mobile sources of 9 air pollution, big trucks and busses, most of which 10 use diesel fuel, are among the worst culprits. 11 Unfortunately, because there is so many more trucks 12 on the road today, manufacturers have done enough to 13 curb pollution from these large diesel vehicles. In 14 areas like Philadelphia, as much as half the 15 particulate pollution that threatens public health 16 comes from large diesel vehicles. More than 30 17 health studies have also linked diesel pollution and 18 the hundreds of toxics it contains, to lung cancer. 19 The good news is that the technology to 20 clean up diesel engines is available. We can afford 21 to wait no longer before requiring manufacturers to 22 use these technologies. 23 While I applaud the EPA for proposing 24 this program to clean up pollution from these big 25 and dirty vehicles, I would like to urge the EPA to Vincent Varallo Associates, Inc. ------- 208 1 Britta Ipri - Clear the Air Campaign 2 make a few changes that would make this program even 3 stronger. 4 First, I would urge the EPA to 5 accelerate the time line for closing the SUV 6 loophole. Under the Tier 2 auto pollution program, 7 all cars and smaller SUVs will be required to meet 8 clean car standards by 2007. However, under the 9 heavy-duty vehicle proposal, automakers have until 10 2009 to clean up larger SUVs. All passenger 11 vehicles, no matter how big or small they are, 12 should meet clean car standards by 2007. 13 Second, the heavy-duty particulate 14 standards must be tightened by 50 percent by 2004. 15 The current proposal would not require any 16 reductions in particulate pollution until 2007. 17 Third, smog-forming pollution and 18 particulate pollution from heavy-duty vehicles 19 should be lowered by 90 percent beyond the 2004 20 standards. 21 Fourth, diesel fuel must be cleaned up. 22 Pollution control systems can be truly effective 23 only when they are coupled with low-sulfur fuels. .24 All diesel fuel sulfur levels should be capped at 10 25 parts per million sulfur by 2006. Vincent Varallo Associates, Inc. ------- 209 1 Nancy Brockman Wyncote Audbon Society 2 Last, the EPA must ensure that trucks 3 stay clean once they are on the road. This should 4 be done through in-use testing and use of on board 5 diagnostic equipment. These should be required for 6 all heavy-duty trucks, both diesel and gasoline. 7 This program is a crucial part of 8 cleaning up our regions' air. Only when our worst 9 dirty-air culprits like large dirty diesel vehicles 10 ar cleaned up can we begin achieve cleaner and 11 healthier air. 12 Thank you once again for the opportunity 13 to speak today. 14 MS. OGE: Thank you. 15 Ms. Nancy Brockman, good afternoon. 16 MS. BROCKMAN: Good afternoon. I'm here 17 to speak on behalf the 2,000 members of the Wyncote 18 Audubon Society, one of the nation's oldest bird 19 clubs and as an asthmatic and the parent of an 20 asthmatic child. I want to compliment the EPA for 21 proposing to close the loophole for enormous, 22 excessively polluting sport utility vehicles and for 23 the move to cut nitrogen oxides emissions from big 24 diesel trucks in half by 2004. 25 The air we are breathing today in Vincent Varallo Associates, Inc. ------- 210 1 Nancy Brockman - Wyncote Audbon Society 2 Philadelphia is dangerous. This is according to EPA 3 standards. The Delaware Valley is a severe 4 non-attainment area. Between 1982 and 1992, the 5 region lost over 25 percent of its total farmland. 6 In that same period, there was a 33 percent increase 7 in auto commuters in the area. The picture of the 8 Greater Philadelphia region is one of shrinking 9 green space and wildlife habitat, increased regional 10 sprawl, and higher than deemed safe air pollution. 11 A walk in Center City Philadelphia can choke the 12 asthmatic and make a healthy person turn their head 13 or cover their faces from the fumes pouring out from 14 buses and trucks. Drive along any major regional 15 highway and you will see dead trees and shrubbery 16 lining the road, dead because of the toxic 17 concentrations of air pollutants. Couple that with 18 the trend toward increased auto dependency and the 19 resulting increase in auto emissions, and we have a 20 dangerous recipe for environmental and human health 21 disasters. 22 The National Audubon Society's mission 23 is to conserve birds and their habitats. Today, 24 Audubon Societies are committed to bringing people 25 closer to birdlife in order to build a deeper Vincent Varallo Associates, Inc. ------- 211 1 Nancy Brockman - Wyncote Audbon Society 2 understanding of the powerful links between healthy 3 bird populations, ecosystems, and ourselves. 4 Birds have been used to monitor the 5 environment throughout history. Declines in bird 6 population numbers and changes in species' ranges 7 resulting from human induced causes provide 8 information crucial to environmental decisions. 9 Birds integrate and accumulate environmental 10 stresses over time because they are usually high in 11 the food chain and have relatively long lifespans. 12 Since birds are sensitive to stresses in predictable 13 ways, they are often used as a proxy measure of 14 environmental change- 15 We are now being warned, much as the 16 canary warned miners of old of lethal gasses in deep 17 shaft mines. Environmental changes are occurring at 18 an alarming rate. Healthy bird populations are 19 decreasing in the region. Fewer numbers of once 20 numerous species are found as wildlife habitats 21 disappear or become increasingly polluted. Acid 22 rain changes the ecological balance in lakes and 23 streams and affects the surrounding habitats. Air 24 pollution kills trees and reduces food supplies for 25 both indigenous and migratory bird populations. Vincent Varallo Associates, Inc. ------- 212 1 Nancy Brockman Wyncote Audbon Society 2 That portion of air pollution caused by 3 cars, minivans, SUVs, and especially diesel vehicles 4 is enormous and can be reduced. Each day we pander 5 to large business interests, more species approach 6 oblivion diminishing our world and our lives as they 7 go. Too often the right move is unclear, but here 8 we have all the components to make a substantial 9 difference. We know what to do and how to do it. 10 The benefits to reducing air pollution from these 11 highly polluting vehicles well outweigh losses or 12 inconvenience to businesses. 13 On a personal note, I wish to say that 14 not only am I an asthmatic, but I am the parent of 15 an asthmatic child. We all know the symptoms of 16 asthma and are aware that asthma is substantially 17 worsened by air pollution. Even with a decrease in 18 air pollution over the last few years, medical 19 experts still tell us that asthma, especially in 20 children, is on the rise in the USA. I fear the 21 possibility that future scientific studies will 22 prove that the damage to human health from that 23 combination of air pollutants found in vehicle 24 emissions is more pervasive than originally thought. 25 At the Tier 2 hearings I told the story Vincent Varallo Associates, Inc. ------- 213 1 I) Nancy Brockman Wyncote Audbon Society 2 I of how my son, now aged 15, was rushed to the hospital with chest pain, faintness, and the inability to breathe. His father and I went to the hospital to find him gasping for breath and scared. 6 No child should have to feel his mortality at that 7 age. He hates having exceptions made for his 8 condition. It makes him feel different from most 9 other kids his age. I hate that the quality of his 10 life is compromised and perhaps permanently damaged. 11 This country has the technology and the 12 power to make substantial changes for the better, 13 now. We should not have to wait until 2007 to see 14 noticeable results. Business will not make changes 15 for the better without being forced to do so by the 16 EPA because it is not cost efficient to do so. It 17 is obvious that the cost of doing business has been 18 more important to decision-makers than the cost to 19 human health. Our collective priorities must 20 change. 21 Personal responsibility should count for 22 more than it does in today's society. Each one of 23 us needs to accept personal responsibility for the 24 type of vehicles we drive, the kind and number of 25 I 'miles we put on them, and the impacts of the Vincent Varallo Associates, Inc. ------- 214 1 Nancy Brockman Wyncote Audbon Society 2 resulting pollution. I believe that all gasoline vehicles, compact car through giant SUV, should be 4 held to the same, more stringent emissions 5 standards. If the emissions control devices on my 6 car do not work correctly, I must have them fixed. 7 Yet, most diesel big trucks don't even use the 8 pollution control devices they could and should. If 9 they did, they could be between 50 and 90 percent 10 cleaner than they are today. I am astonished that 11 in Philadelphia, our public transportation system 12 can use a low-grade high polluting diesel fuel 13 instead of the available but more costly high-grade 14 lower polluting diesel fuel in the busses that serve 15 the public. How is this possible? For these 16 reasons I am heartened to see EPA taking the 17 responsibility to implement tougher emissions 18 standards for highway vehicles and engines. 19 Just a final note: With asthma on the 20 increase in America, most notably in pre-school aged 21 children, we run the risk of our future generations 22 by not acting now. Much as I mourn the decline and 23 loss of endangered bird species that continue to 24 fall victim to human engineered environmental 25 factors, I fear the irreparable damage to humans Vincent Varallo Associates, Inc. ------- 215 1 Nancy Brockman - Wyncote Audbon Society 2 more. 3 MS. OGE: Thank you. 4 Any questions for the panel? 5 MR. FRANCE: Yes, just a couple. This 6 is for Mr. Jorgensen. I think all of us wish that 7 we were here in January 1999, but we're not. Before 8 I ask a question, I do have to set the record 9 straight. Mr. Jorgensen, you used a fairly strong 10 language in terms of breach of faith, breach of 11 contract, EPA has a time management problem. I like 12 to remind you, first of all, consent decrees were 13 not, any circumstances regarding consent decrees are 14 not of our making. Those consent decrees were filed 15 with the court late last year, were finalized I 16 think in June or July this year. We made good faith 17 efforts to integrate those provisions in a logical 18 way, at the same time trying to interact with the 19 industry, I think, in an unprecedented way. I think 20 we met more than 10 times with the industry. We've 21 met individually with Cummins. We were on site at 22 your facility about the details. On top of it, as 23 Margo said before, on behalf industry's request, 24 part of the delay in getting the rule was the lead 25 provisions that you all asked us to streamline the Vincent Varallo Associates, Inc. ------- 216 1 Nancy Brockman Wyncote Audbon Society 2 rule. So speaking from our perspective, a lot of 3 the delay have been response to circumstances that 4 were out of our control, but also in response to 5 requests from the industry. So I'd like that entered on the record. 7 Let me ask the question. You keep 8 citing the SOP, you suggested first the inference 9 there is that we just reaffirmed the standard. Is 10 that what 11 MR. JORGENSEN: In the SOP, of course, 12 it called for a revisiting or a re-analysis of the 13 feasibility of the standards, and obviously it was 14 possible to make them more stringent, make them as 15 they were, or make them more stringent. But all 16 those were possibilities that were listed both in 17 the SOP and in 1997 final rule. 18 MR. FRANCE: How would you anticipate 19 EPA dealing with the consent decrees supplemental 20 test provisions, from Cummins' perspective. 21 MR. JORGENSEN: As far as incorporating 22 them, we definitely expected that EPA would take 23 that into account in the process. As a matter of 24 fact, in the nearly dozen meetings that we refer to, 25 I the first was held, I believe, in December of 1998, i Vincent Varallo Associates, Inc. ------- 217 Nancy Brockman - Wyncote Audbon Society and at that meeting, you know, the discussion had 3 those elements in it. And at that point in time, 4 the agency representatives talked about how the MPRM 5 would normally be out in March and that we'd be 6 having a hearing in April and that written comments 7 would be due in May. 8 MR. FRANCE: Let me ask, so you 9 anticipated us including not to exceed provisions as 10 part of this rule? 11 MR. JORGENSEN: I would say certainly 12 taking the consent decree into account. Now, 13 whether or not it was the exact replica, that, I 14 think was open for discussion. 15 MR. FRANCE: Absolutely. It still 16 remains open for discussion in terms of the 17 provisions. I'm asking in Cummins' perspective, the 18 same line of discussion I had with Detroit Diesel. 19 What is Cummins' perspective on the lead time issue 20 that has been identified and also what is your 21 company's intent complying with 2004? 22 MR. JORGENSEN: Of course, as you see, 23 by our comments, we wish it was a moot point. We 24 wish that the rule would have been finalized by year 25 end such that the question of lead time would not Vincent Varallo Associates, Inc. ------- 218 1 Nancy Brockman Wyncote Audbon Society 2 have been an issue. But we recognize and we noted 3 with interest in the preamble to the rule how EPA 4 acknowledges that it might not be possible to conclude the rule by year end and has thought about 6 ways that we could still have an effect date of 7 2004, either through a voluntary agreement or 8 whatever. And I think Cummins, I can say, is open 9 to those kinds of discussions. And we wouldn't rule 10 • out that those discussions could lead to a 11 conclusion that maintains the 2004 date. We 12 wouldn't rule that out. 13 MR. FRANCE: What is Cummins going to do 14 if we don't? 15 MR. JORGENSEN: Well, I can tell you 16 that it's a very difficult and complex issue as to 17 what happens if the December 31, 1999 deadline is 18 met. And quite frankly, I don't really understand 19 perfectly what happens to competitors that have not 20 signed a consent decree. So it's very difficult for 21 us to really answer that question. I'm very open to 22 those kinds of discussions, though, but I think it's 23 a very complex issue as to what happens to others. .24 And in that light, it's very difficult for me to 25 answer the question as to how Cummins will behave. Vincent Varallo Associates, Inc. ------- 219 1 Nancy Brockman Wyncote Audbon Society 2 MR. FRANCE: That's fair enough. 3 MS. OGE: I think that's fair. I would 4 encourage you and other companies to give us 5 comments on all these issues. And I think there are 6 legal issues of lead time appropriateness for all of 7 us to address and then there are issues of 8 feasibility to do it. We would like comments on 9 both issues. And how do we proceed forward with the 10 best program in place in 2004 time frame to give us 11 the clean air all of us are looking for. Thank you. 12 MR. JORGENSEN: You're welcome. 13 MS. OGE: Any other questions? 14 MR. HOROWITZ: Just a follow-up to 15 Chet's point. Just to state for the record that you 16 used the words breach of contract and breach of 17 faith. And obviously, we, EPA, had no contract with 18 any of the companies under the SOP. We wouldn't 19 make contracts to put out rulemakings and finalize 20 final numbers for emission standards without going 21 through the notice and comment process. So I'm 22 worried about the use of that term, but I understand 23 the rhetorical charge. And also regarding breach of 24 faith and not understanding complexity, obviously, 25 the intervening events came out of consent decrees Vincent Varallo Associates, Inc. ------- 220 1 Nancy Brockman - Wyncote Audbon Society 2 have unfortunately delayed them. As Chet said, that 3 was not something that we anticipated in 1995. 4 MS. OGE: Anymore questions? 5 (No response.) 6 MS. OGE: Thank you. Thank you very 7 much for coming forward. 8 We are doing great on time; we are 9 early. We had a gentleman by the name Dennis 10 Winters . 11 AUDIENCE MEMBER: He's not here. 12 MR. OGE: I would like to call the panel 13 that was scheduled to testify at 4:15 if they are 14 here. Valerie Sowell, Geoff Harden, Kathleen Erdei, 15 Jason Rash, Ajayi Harris. 16 I'm told that Natasha Ernst is here. 17 She was scheduled for the 5:15. If you would like 18 to come forward, please do that. I'm reminded that 19 Mr. Andrew Altman was not here earlier. 20 MR. RASH: He will be submitting 21 comments in written form. He will not be 22 testifying. 23 MS. OGE: Thank you. 24 We can start with Ms. Valerie Sowell. 25 Good afternoon. Vincent Varallo Associates, Inc. ------- 221 1 Valerie Sowell Citizen 2 MS. SOWELL: Good afternoon. My name is 3 Valerie Sowell. I'm a citizen of Philadelphia here. 4 And I just want to thank you briefly for giving me 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 Vincent Varallo Associates, Inc. ------- 222 Valerie Sowell Citizen tighten the heavy-duty particulate standard 50 percent by 2004. The EPA must call for an additional 90 percent reduction of particulate matter and nitrogen oxide pollution by no later 2007. We have to clean up diesel fuel to go hand in 7 hand with this. All diesel fuel sulfur levels 8 should be capped at 10 parts per million by 2006. 9 As well, we should ensure that trucks are not 10 getting out of their obligations; they stay clean 11 once they're on the road using in-use testing and 12 on-board diagnostic equipment. 13 So we've isolated the cause. We've 14 isolated the cure. The problem, of course, is not 15 in doing that, but in following through. We have to 16 make sure that the changes that we see are met. 17 And, you know, people in large groups 18 tend to share inertia with this sort of thing. It's 19 somebody else's responsibility or it's somebody 20 else's fault, but really little as possible. And I 21 learned something. I spent a year in Northern 22 Ireland. Before I went there, I was researching the 23 psychology of large groups and mob rule to guard 24 away from the terrorists if I could. And I learned 25 that when you're in the middle of a large group and Vincent Varallo Associates, Inc. ------- 223 Geoffrey Harden Citizen 2 I! someone attacks you in a crowd, that you can't wail 3 and say "Somebody help me. Oh, God, I'm in dire 4 5 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 .24 25 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. Vincent Varallo Associates, Inc. ------- 224 1 Geoffrey Harden Citizen 2 I'm here as a citizen, but I want to offer my perspective on this issue as a urban bicyclist. Practical concerns like economic necessity and consideration for the environment 6 compel citizens like myself to use bicycles as an 7 alternative transportation in cities across the US. 8 We cyclists share the streets with these big trucks 9 and SUVs. So making our way to work or school or 10 home, we choke on the fumes from these dirty 11 vehicles' tailpipes. 12 I ride my bike to work through Center 13 City Philadelphia every morning. So I've gotten my 14 share of exhaust pumped in my face by these big 15 vehicles. Tailpipe fumes burn my eyes, my throat, 16 and my lungs. It's nauseating. But what's really 17 worse is the long-term effects of this smog, the 18 untimely deaths of 40,000 citizens each year. Smog 19 reduction is literally a question of life or death 20 so the work must not been delayed. So I'm urging 21 you to continue in the spirit of what you propose to 22 clean up our air, forcing automakers to use readily 23 available technology to reduce their deadly 24 pollution, tightening the heavy-duty particulate 25 standards by 50 percent by 2004, and limiting diesel Vincent Varallo Associates, Inc. ------- 225 Jason Rash GPCCP sulfur levels to 10 parts per million by 2006, and closing the SUV loophole by 2007. 4 Thank you again for your time. 5 MS. OGE : Thank you. 6 Mr. Jason Rash. Good afternoon. 7 MR. RASH: Good afternoon. My name is 8 Jason Rash, and I am here representing the Board of 9 Directors of the Greater Philadelphia Clean Cities 10 Program. Great Philadelphia City Program is a 11 public/private partnership dedicated to promoting 12 the development and use of alternative fuels and 13 alternative fuel vehicles in the Greater 14 Philadelphia region. 15 The Greater Philadelphia Clean Cities 16 program was established in 1993 and is widely 17 recognized as one of the most successful United 18 States Department of Energy Clean Cities Programs in 19 the nation. Thanks to the efforts of its members, 20 local governments, companies, and consumers in the 21 Greater Philadelphia region are powering thier vans, 22 trucks, cars and buses on alternative fuels such as 23 compressed natural gas, propane, ethanol, methanol, 24 and electricity. The results being improved air 25 quality and a reduction in the reliance on foreign Vincent Varallo Associates, Inc. ------- 226 1 Jason Rash - GPCCP 2 oil. 3 While the Greater Philadelphia Clean 4 Cities Program coalition enthusiastically supports 5 EPA's proposed strategies to reduce emissions from 6 heavy-duty diesel vehicles, it also calls on EPA to 7 increase alternative fuels. 8 Transportation in America revolves 9 around motor vehicles that run on gasoline and 10 diesel; two fuels that despite advances made in 11 catalytic and fuel cleaning technologies, will 12 continue to contribute to the country's ground level 13 ozone problem well into the next century. 14 Furthermore, the world's oil supply is 15 not limitless and is the source of great 16 geopolitical instability. As a result, the United 17 States is forced to spend billions of dollars each 18 year importing over half of its oil, often from 19 politically unstable regions of the world. 20 The public health hazard posed by 21 ground-level ozone and the increasing reliance on 22 foreign oil are serious threats to our nation's 23 future. That is why the Greater Philadelphia Clean 24 Cities Program is calling on EPA to increase its 25 presence in the alternative fuel arena. Alternative Vincent Varallo Associates, Inc. ------- 227 Natasha Ernst - Low Income Housing Activist fuel vehicles can make considerably less pollution than conventional vehicles, some even have zero emissions, and alternative fuels such as compressed natural gas, electricity, and ethanol are in great 6 abundance here in the United States. 7 The shift to alternative fuels will not 8 take place over night, but it is imperative that it 9 occur now. There is a willingness throughout the 10 country to use alternative fuel vehicles, but its 11 growth is contingent on EPA working with other 12 governmental agencies and private industry to 13 improve both alternative fuel infrastructure and 14 vehicle development. 15 Thank you. 16 MS. OGE: Thank you. 17 Ms. Natasha Ernst. Good afternoon. 18 MS. ERNST: Good afternoon. My name is 19 Natasha Ernst. I live in Philadelphia, and I work 20 with low income housing tenants in Philadelphia. 21 Thank you for this opportunity to voice my concerns 22 about the need to reduce air pollution from trucks 23 and SUVs. 24 A large part of Philadelphia's 25 populations comprised low income households. These Vincent Varallo Associates, Inc. ------- 228 1 Natasha Ernst - Low Income Housing Activist 2 neighborhoods often look like post industrial 3 wastelands surrounded had by abandoned factories and 4 warehouses. The schools there suffer from crumbling buildings and textbook shortages. People live in 6 I! substandard housing. But in addition to all of 7 these problems, growing numbers of especially 8 African-American and Hispanic children in 9 Philadelphia are also suffering from severe asthma. 10 A large quantity of the people I see 11 every day have a child that has asthma or they 12 themselves are asthma or another respiratory 13 problem. I see these families striving to provide a 14 better life for their children by finding a decent 15 home, a good public school, and escaping the crime 16 ridden neighborhood. However, no matter how hard 17 these families work, they can't escape from air 18 pollution. 19 The polycyclic organic material in 20 Philadelphia's poorest area is more than 200 times 21 the no-risk level, this according to the EPA. This 22 is created by the burning of gasoline. SUVs burn 23 more gasoline and are less fuel efficient than any 24 other passenger vehicle. This air pollution 25 directly impacts the health and well being of Vincent Varallo Associates, Inc. ------- 229 1 Natasha Ernst Low Income Housing Activist 2 Philadelphians, Philadelphians that are often too 3 poor to ever be able to afford the luxury SUVs that 4 are on the market today. 5 I'm asking EPA to put people above 6 corporate profit. The increased profit of 7 corporation, such as forward and GM, that exist as a 8 result of the SUV loophole will result in more money 9 being spent in medical costs, missed time at work, 10 and decreased quality of live by low income working 11 people and their children who suffer the real cost, 12 the health costs, of air pollution. 13 In essence, by not strengthening the 14 heavy-duty program, the adults and children of 15 Philadelphia and the United States will be financing 16 corporate profit. 17 The EPA now has the unique opportunity 18 to put the public interest ahead of corporate profit 19 by strengthening the heavy-duty program in areas 20 such as closing the SUV loophole so all passenger 21 vehicles meet the clean air standard by 2007, 22 tightening the heavy-duty particulate standard by 50 23 percent by 2004, cleaning up diesel fuel, and 24 ensuring that trucks stay clean once they are on the 25 road. Vincent Varallo Associates, Inc. ------- 230 Ami Doshi NJ PIRG Clean air is a public resource, not a corporate resource. And I applaud the EPA for working to protect it. Thank you for letting me speak about this important issue. MS. OGE: Thank you. Any questions? (No response.) MS. OGE: Thank you very much. Good afternoon. MS. DOSHI: Good afternoon. MS. OGE: Please state your name. MS. DOSHI: My name is Ami Doshi, and I am with the New Jersey PIRG, the New Jersey Publish Research Group. Thank you for giving me an opportunity to voice my concerns for the need to reduce air pollution from trucks and SUVs. In New Jersey and across the Country air pollution is taking enormous toll on public health. Nationwide air pollution sends more than 150,000 Americans to emergency rooms each year and causes more than 6 million asthma attacks according to a recent study by Act Associates, a reputable consulting firm. Even worse, particulate air pollution is responsible for cutting short the lives of more than 40 thousand Americans each year. Have Vincent Varallo Associates, Inc. ------- 231 Ami Doshi NJ PIRG big trucks and buses, including diesel and gasoline 3 II powered vehicles over 8500 pounds, are among the 4 biggest causes of our pollution problems. Ad 5 manufacturers have done very little to curb their 6 pollution. These big vehicles are a bigger 7 pollution problem today than they were 30 years ago 8 when the Clean Air Act was passed. 9 In urban areas as much as 50 percent of 10 the deadly particulate pollution we have breathe 11 comes from diesel vehicles. Making matters worse, 12 this diesel pollution has been found to contain 13 hundreds of toxic substances, and more than 30 14 health studies link diesel pollution to lung cancer. 15 It is high time for manufacturers of 16 diesel engines and big trucks to use widely 17 available technologies to reduce their pollution. 18 Yet, we know from experience we cannot count upon 19 them to do this voluntarily, nor can we rely on 20 manufacturers to obey the rules with out strict 21 monitoring and enforcement. Just last year these 22 same diesel engine manufacturers were discovered to 23 be cheating on emissions tests resulting in an 24 increase of smog-forming pollution of over 1 million 25 tons each year. Vincent Varallo Associates, Inc. ------- 232 Ami Doshi NJ PIRG New Jersey PIRG applauds the EPA for proposing a forward-looking program to close the SUV loophole that allows SUVs to emit up to five times more pollution than a car, to set standards on trucks and the fuels that power them, and require strict tests to ensure compliance with the standards . However, we are extremely concerned that the proposal is phased in over an unnecessarily long period of time resulting in delayed health benefits for the public and that the proposal may not adequately ensure that heavy-duty trucks comply with the standards throughout the time they are on the road. Specifically, we urge the EPA to considering the following changes to strengthen the heavy-duty program: Number 1, accelerate the time line for closing the SUV loophole. Under the Tier 2 auto pollution program, all cars and smaller SUVs will be required to meet clean car standards by the year 2007. There is no technological reason to give automakers another two years to clean up the largest and dirtiest SUVs of all. All passenger vehicles should meet clean air standards by 2007. Vincent Varallo Associates, Inc. ------- 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 .24 25 233 Ami Doshi - NJ PIRG Number 2, take in the heavy-duty particulate standard by 2004. According to the Manufacturers of Emissions Control Association, MECA, the technology is already available to cut particulate pollution from heavy-duty trucks by using existing catalysts. Yet the current proposal would have the public wait until 2007 before any reductions in particulate pollution from heavy-duty trucks would occur. This delay will contribute to the premature deaths of thousands of Americans. Number 3, adopt strong standards for the year 2007. Pollution from heavy-duty vehicles is an urgent problem that must be addressed as soon as possible. The EPA must forge ahead with an additional 90 percent reduction of particulate matter and nitrogen oxide no later than 2007. Number 4, clean up diesel fuel. Pollution control systems can be truly effective only when they are coupled with low-sulfur fuels. In fact, current sulfur levels in diesel fuel are so high, they actually prevent the use of the most advanced pollution control technology. In order to ensure that diesel pollution equipment is effective, all diesel fuel sulfur levels in both on-road and Vincent Varallo Associates, Inc. ------- 234 Ajayi Harris - Citizen off-road diesel fuel should be capped 10 parts per million sulfur by 2006. And Number 5, ensure that the trucks stay clean once they are on the road. Lab tests quite often do not reflect the true on-road emissions. Often faulty pollution control equipment goes unnoticed by the truck owner. Moreover, in the past, engine manufacturers and users have seriously undermined emission standards by using cheating devices during testing procedures. In order to ensure that clean trucks stay clean, in-use testing and on-board diagnostic equipment should be required for all heavy-duty trucks, both gasoline and diesels . Once again, I thank you for allowing me to speak on this important issue. MS. OGE: Thank you. Mr. Harris, Mr. Haupt, and Dennis Winters. Good afternoon. Please state your name and your association for the record. MR. HARRIS: My name is Ajayi Harris. That's A-J-A-Y-I. I live in West Philadelphia. Actually, I moved to the City to work with the PIRG Vincent Varallo Associates, Inc. ------- 235 Ajayi Harris Citizen partly because a really big problem is Philadelphia has the fourth air quality in the country. Lots of urbanization, a lot of people living in densely populated area, so really a great opportunity to come and work in this city and address clean air issues. Particularly also on a personal level, I myself am an asthma sufferer myself, so I can speak from personal experience both on not only having to breathe as a problem, both whether I'm hanging out with friends or sitting behind a diesel truck that is just emanating tons and tons of smoke and pollution out of the back, whether it's a bus or diesel truck or take your pick, Mercedes Benz, whatever. So it was a great opportunity for me to come and testify today and just to tell you all that as speaking from a personal experience it's tough being an asthma sufferer. And there are kids and adults out there that every day sulfur from this problem. I encourage the EPA to take action on this and really find the will and courage to really go out and implement these tougher standards. And I believe that's it. Thank you. MS. OGE: Thank you for coming forward. Vincent Varallo Associates, Inc. ------- 236 1 Dennis Winters DVTUG 2 I will call again on Mr. John Langan, 3 Mr. Dennis Winters. 4 What we will do is we will stay here 5 until time has been scheduled for these individuals. 6 So we ask that the court reporter to please stay 7 with us. We can stand up and walk around. What I 8 would suggest for us to do is to try to see if we 9 can get together by 4:15 and see is if the 10 individuals sign in here at 4:15. So let's take a 11 break until 4:15. 12 (Brief recess.) 13 MS. OGE: We will ask Mr. Dennis Winters 14 and Mr. Abram Haupt to come forward, please. Please 15 print your names on the cards and state your names 16 for the court reporter. 17 MR. WINTERS: Did you want us to speak 18 in that order? 19 MS. OGE: State your name and spell it 20 for the court reporter. 21 MR. WINTERS: My name Dennis Winters, 22 D-E-N-N-I-S, W-I N-T-E-R-S. 23 MS. OGE: Mr. Winters, good afternoon. 24 Please start. 25 MR. WINTERS: Thank you. I'm an officer Vincent Varallo Associates, Inc. ------- 237 1 Dennis Winters - DVTUG 2 of the Delaware Transit Users Group or DVTUG. 3 Delaware Valley Transit Users Group 4 would like to thank the EPA for the opportunity to 5 comment on efforts to reduce the pollution from 6 heavy-duty diesel engines. Far too many people die 7 and suffer each year because of the particulates and 8 other emissions from diesel engines. The health of 9 thousands of young and elderly in the Philadelphia 10 area is compromised by this continuing source of air 11 pollution. And what is not known about the 12 consequences of this fine particle pollution is even 13 more frightening. Who knows what carcinogens invade 14 the eyes, nose, throat, and lungs riding these 15 minute particles? 16 As a transit promoter, DVTUG is 17 concerned, in particular, with the diesel-powered 18 buses operating in the Philadelphia metropolitan 19 area. Both over-the-road and local bus fleets are 20 almost exclusively diesel powered. Because much of 21 the pollution from diesels takes place as billowing 22 clouds of black soot, it is one of the few remaining 23 obvious sources of visible air pollution. Based on 24 the number of complaints we receive, the continuing 25 reliance of SEPTA and New Jersey Transit on Vincent Varallo Associates, Inc. ------- 238 Abram Haupt - Citizen diesel-powered buses is a real impediment to gaining 3 new transit users or even greater tolerance from the 4 public who does not take transit. 5 The members of DVTUG hope that 6 promulgating these regulations will now offset some 7 of the external costs associated with the health 8 costs and pollution and that the purchase price of 9 new natural gas-powered buses will become more 10 competitive with diesel vehicles. Perhaps then 11 public transportation agencies, like this area's 12 SEPTA and New Jersey Transit, will no longer cling 13 to the excuse of price difference when choosing 14 diesel-powered buses over much cleaner alternatives. 15 MS. OGE: Thank you. 16 Mr. Abram Haupt. 17 MR. HAUPT: Do you want me to state my 18 name? 19 MS. OGE: Please. 20 MR. HAUPT: My name is Abram Haupt, 21 A-B-R-A-M, H-A-U-P-T. I'm a concerned citizen and 22 I'm testified with the Pennsylvania Public Interest 23 Research Group. I'm going to tell you a brief 24 little story today. I'm a college student and 25 concerned citizen and I'm here to testify in support Vincent Varallo Associates, Inc. ------- 239 1 Abram Haupt Citizen 2 of the new proposed emission standards on cars and 3 SUVs, but I am a SUV owner. Basically, I am 4 particularly concerned about the fact that SUVs are 5 given a lethal loophole in our current standard 6 system and are allowed to pollute substantially more 7 than the average vehicle. I purchased my SUV in the 8 fall of '96, and one thing I find remarkably 9 striking is the fact that through my entire 10 purchasing process, I was never informed of the 11 potentially polluting, or I should say the polluting 12 ramifications of this vehicle- This was, of course, 13 before I became an environmentalist. 14 And the point of this story is that auto 15 companies have a responsibility to provide 16 environmental responsible vehicles and oil companies 17 have an obligation to sell low-sulfur fuel because 18 the average citizen is usually not aware of these 19 things when he or she purchases a vehicle. When the 20 typical American purchases a vehicle, they do not 21 know that 40,000 Americans died prematurely last 22 year due to air pollution. Proof of this is the 23 huge rise in SUV sales over the last decade. 24 Concluding, corporate America has an 25 obligation to create vehicles and fuel safe for all Vincent Varallo Associates, Inc. ------- 240 Abram Haupt - Citizen Americans, and they have the obligation to do it now. If we do not act immediately on this issue, the respiratory functions of hundreds of thousands of Americans within the next few years may be at stake. MS. OGE: Thank you. And this concludes the public hearing today. Thank you for coming forward to testify. (Pubic hearing concluded at 4:20 p.m.) Vincent Varallo Associates, Inc. ------- 241 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CERTIFICATION I HEREBY CERTIFY that the foregoing proceedings of the United States Environmental Protection Agency Public Hearing of November 2, 1999, were reported fully and accurately by me, and that this is a correct transcript of the same. Bernadete M. Black, RMR and Notary Pubic C. Bradley i/RPR and Notary Public Vincent Varallo Associates, Inc. ------- 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 ------- |