Dear Director Brooks,
Environment Maine would like to thank the Baldacci Administration for moving toward full adoption of a strong clean cars program. Environment Maine strongly supports the Department of Environmental Protection (DEP) proposal to adopt the Zero Emissions Vehicle program, or Cleaner Cars program, as a key piece of Maine’s clean air strategy.
I would like to comment on the problem of air pollution in Maine and how the Cleaner Cars program will improve our air quality, and to rebut some auto industry arguments. Quite simply, Cleaner Cars means cleaner air.
As you know, air pollution in Maine is a severe problem. Earlier this year, the EPA designated 108 towns and cities in half of Maine’s counties as failing air quality standards for ozone. Although this wet and cool summer only registered about 2 bad air days, in 2002 our state was faced with 17 bad air days. Smog blocks views all along the coast from Kittery to Acadia National Park.
Although this air pollution comes from various sources, the largest single source of air pollution in Maine is tailpipe emissions, at 494,127 tons per year in 2002. According to the Department’s numbers for 2002, on-road mobile sources account for the greatest amount of CO, NOx, and the third highest volatile organic compound emissions. On-road vehicle emissions also make up approximately 30 percent of Hazardous Air Pollutants (HAPs), such as benzene and formaldehyde, according to Maine Air Toxics 2002 Inventory. This air pollution impacts our health and environment.
Tailpipe emissions threaten our health. Maine has the highest childhood asthma rate in New England and one of the highest adult asthma prevalence rates in the country. Nitrogen oxides and ozone that forms from tailpipe emissions, especially on warm summer days, sears our lungs. It triggers asthma attacks among sensitive populations and according to recent studies published in the Journal of the American Medical Association, it puts children at higher risk of developing respiratory illnesses. Also, toxic air pollutants in car exhaust, such as benzene and formaldehyde, are known or suspected carcinogens.
Auto emissions also threaten our environment. Automobiles are the largest single source of global warming pollution. Global warming has the potential to totally change the ecosystems of our state. We have already started to see its effects, with a severe drought two summers ago, an increase in the average temperature in Auburn, and slowly rising sea level. Maple sugar production has decreased in the region and will continue if the winters are warmer or drier, and the ski industry has to rely more on snowmaking to cover the slopes. To our south in Connecticut, Rhode Island and Massachusetts, recent research has uncovered the cause of the abrupt and precipitous decline in a once healthy lobster population - increased water temperatures. The 1800 tons of SO2 that cars emit each year also contribute to acid rain, which is altering lakes and streams all across the state and is weakening red spruce growth at high elevations.
Cleaner Cars are one big piece of reducing our air pollution problems. The technology is here to make cars cleaner- both through gas-electric hybrids, other advanced technologies and conventional gasoline cars with lower emissions. There are numerous hybrids and cleaner gasoline cars on the market today. Some of these advanced technology vehicles achieve 90 percent reductions in air emissions than today’s average cars. And many hybrid-electric vehicles such as the Toyota Prius and Ford Escape achieve these pollution reductions while, at the same time, delivering significant improvements in fuel economy.
Consumers are buying cleaner cars, and faster than they can be shipped to Maine. Auto dealers in Maine report that they have a waiting list for certain hybrids between 6 and 18 months long. Often, people looking to buy a hybrid settle for some other car because they cannot wait for a hybrid to become available. Other evidence of the demand for hybrids is the fact that consumers do not attempt bargaining on the price, they simply sign up to get it the hybrid at list price.
Auto manufacturers are producing even more hybrid models to choose from. In addition to the three hybrids previously available – the Toyota Prius and the Honda Insight and Civic, consumers will be able to purchase a number of different hybrid vehicles in model year 2005 and 2006. Some of those models include the Ford Escape, GMC Sierra, Honda Accord, Toyota Highlander, Toyota Sienna, Lexus RX300, Dodge Ram, Saturn VUE, Nissan Altima, and others. More hybrids are slated to be released in model year 2007.
While hybrids are being developed and sold quickly, conventional gasoline cars are being made with significantly less emissions. Model year 2004 saw 27 types of cleaner cars available; BMW, Ford, Volvo, Toyota, Honda, Subaru, Hyundai, Mitsubishi, Nissan and Volkswagen all have several partial zero-emission vehicle or “PZEV” models available to consumers. For example, the Ford Focus now available on most car lots has a redesigned, more efficient engine, it traps volatile emissions from the gas tank and fuel lines, and cleans more of the pollution out of its exhaust before it leaves the tailpipe. In the television advertisement for the Focus, the cleaner engine is one of the perks listed along with the moonroof and cd player. Clearly, this is a plus for car shoppers.
At the Board hearing the following question was posed: with the demand for cleaner cars and the auto manufacturers increasing types of models and production numbers, why does Maine need to adopt the Cleaner Cars program? The reason is straightforward: with the Cleaner Cars program in place, Maine dealers will be prioritized over other dealers in parts of the country that do not have the Cleaner Cars program. Even in 2009, we might expect some supply limitations to meet the nationwide demand for cleaner cars, so states that had the Cleaner Cars program would be prioritized to receive the hybrids and cleaner conventional gasoline cars. Maine dealers would receive larger numbers of cleaner cars, and larger numbers of the cleanest cars would get onto the road earlier than if we did not adopt the Cleaner Cars program.
By getting more of these cleaner cars onto the road, Maine will be able to tackle its air pollution problems and stave off global warming. Despite industry arguments to the contrary, the Zero Emissions Vehicle program reduces tailpipe emissions substantially. According to Northeast States for Coordinated Air Use Management (NESCAUM), the current Low Emissions II program in Vermont will be successful in reducing pollution, with one third of the pollution reduction coming from the Zero Emission Vehicle program. Also, the MA DEP wrote, “As Part of the Department’s 1999 rulemaking process, the Department assessed the air quality impacts of adopting the California LEV II standards, including the modifications to the ZEV mandate, as compared to the impacts of having federal standards in-place in Massachusetts. The results of this analysis showed that the adoption of the LEV II standards, including the ZEV mandate, in the aggregate would achieve greater emission reductions than the federal standards.” By setting a mandatory goal for the percentage of new Cleaner Cars sold in relation to total light-duty vehicle sales, we will cut our vehicle emissions, even as vehicle-miles traveled is projected to increase.
In the legal interest of adopting a program identical to CA’s ZEV program and because car manufacturers will have enough lead time to satisfy the program, we recommend proceeding to adoption of the Cleaner Cars program in 2009, without an additional alternative compliance path. If Maine’s program started in 2009 with the same levels of cleaner cars sales as CA, then Maine will get cleaner cars more quickly and the program will be easier to administer. As manufacturers pointed out in the October 7th public hearing, cleaner car production will be “ramping up” over the next four to five years, in line with complying with the ZEV program in Maine in 2009. Additionally, if DEP establishes a flexibility mechanism such as an early credit banking system to encourage car manufacturers to increase sales of cleaner cars in Maine prior to model year 2009, we urge a one to one early credit banking system. In essence, car manufacturers could bank credits earned from 2005-2009 for PZEVs and AT-PZEVs at the same rate that they could receive credits after program implementation in 2009. This system would reward the industry leaders and increase the number of cleaner cars on Maine’s roads earlier than the straight implementation in 2009.
We need to do our part. Moving ahead with a strong Cleaner Cars program will build momentum for the work being done across the Northeast on cleaner cars. By showing our commitment through these rules it is more likely that that upwind states such as NJ, NY, CT, RI, MA and VT will continue to move forward so that we have cleaner cars throughout New England and the Northeast.
Sincerely,
Matthew Davis
Advocate, Environment Maine
