AIR QUALITY NEEDS BEYOND 2000
New Jersey has worked at complying with the National Ambient
Air Quality Standards since the passage of the Clean Air Act
(CAA) in 1970. After decades of regulations on mobile and stationary
sources of air pollution, New Jersey has made great strides,
but is still out of compliance for ozone.
Ground level ozone is formed when volatile organic compounds
(VOCs) and nitrogen oxides (NOx) react in the presence of sunlight.
With respect to VOCs and NOx, New Jersey has already achieved
approximately 95% of the reductions which would be required
to meet the one-hour ambient air standard for ozone. However,
the remaining 5% may prove to be difficult to achieve because
mobile sources are the main problem and are difficult to control.
Achieving adequate reduction on high ozone days will likely
require greater attention to short-term emissions rates and
may require control strategies specific to these times.
Air toxics and fine particulates (PM 2.5) remain a public
health concern in New Jersey. Efforts to better understand the
nature and effects of these pollutants need to be continued.
This public hearing solicited advice from interested parties
on ways in which New Jersey can meet clean air goals.
Stationary and mobile sources of air pollution in New Jersey
have been the subject of legislation and regulation in order
to bring the State into compliance with the requirements of
the Clean Air Act Amendments (CAAA). The first Federal Clean
Air Act (1970) established the basis for achieving National
Ambient Air Quality Standards in the United States. Each state
was directed to write a State Implementation Plan (SIP) describing
its strategy for attaining and maintaining these federal standards.
When an area does not meet the Clean Air Act standards, it is
"not in attainment" and New Jersey is still not in attainment
for ground level ozone.
At the present time the clean generation of energy and advanced
auto emissions control seem to offer the most beneficial path
to reach clean air goals. Although cars are cleaner than in
the past (vehicles built before 1981 emit 10 to 15 times as
much pollution as a new vehicle) the number of cars in New Jersey
increases yearly and the number of vehicle miles traveled (VMT)
continues to increase. Yearly gains in pollution control have
been countered by these yearly increases. Also, there needs
to be greater focus on short-term emissions from the generation
of energy during peak ozone periods.
Other approaches, such as the LEV II (low emission vehicle),
use of alternative fuels, tax incentives for low emission vehicle
purchase and "smart growth" have been suggested at this hearing.
Although New Jersey has more miles of highway per square mile
than any other state, over 60% of the State's interstate system
is operating at or above capacity during peak periods of use.
The State Plan recommends the development of centers or "compact
forms of development" in order to reduce the need for additional
road and car dependence.
New Jersey has long been in the forefront of programs aimed
at clean air. It was the first state to implement an inspection
and maintenance program for motor vehicles in February of 1974.
Emissions of VOCs during gasoline transfer operations are now
under strict control at marine terminals, refineries, gasoline
storage facilities and tanker trucks all the way to the gasoline
stations and the motor vehicle. Innovative and long-range solutions
to air quality problems is a continuing tradition in the State.
1. Because New Jersey has not yet attained the federal one-hour
air quality standard for ozone, the State needs to further decrease
the emissions of ozone-forming pollutants. The Clean Air Council
recommends that the State adopt rules for the regulation of
volatile organic compounds (VOCs) as set forth in the Ozone
Transport Commission's (OTC) six Model Rules (see www.sso.org/otc)
governing consumer products, architectural and industrial coatings,
portable fuel containers, solvent cleaning, mobile equipment
repair and oxides of nitrogen (NOx) emissions from select fuel
The Council has several recommendations dealing with mobile
sources, specifically automobiles, because of their substantial
contribution to air pollution, and the recognition that the
new ozone standard will require further control of mobile sources
since they are the major contributor of air pollution in the
State. These recommendations include the following:
2. The Council continues to support full implementation of
the enhanced I/M (inspection and maintenance) program for automobiles.
3. The Council recommends that the NJDEP focus on the operating
efficiency of mobile sources. As a step in improving such operating
efficiency, the Council further recommends that the state provide
financial incentives for the purchase of Ultra Low, near zero,
Emission Vehicles (ULEV), hybrid vehicles and fuel-efficient
vehicles. The Council supports legislation that would provide
such financial incentives.
4. The Council recommends that New Jersey Transit continue
to increase its purchase and use of alternative fuels, advanced
technology buses, and fuel-efficient buses.
5. The Council recommends that the public policy of New Jersey
should be to increase the capacity of public transportation
to the maximum extent possible. This policy should encourage
more light rail projects as well as programs that better coordinate
and connect existing public transportation systems.
6. The Council recommends that the State motor pool continue
to replace the state vehicle fleet through the purchase and
use of alternative fuels, alternative fuel vehicles, ULEV, and
fuel-efficient vehicles as much as possible.
7. The Council recommends that the State continue to evaluate
and study the California Low Emission Vehicle 2 (LEV2) or similar
programs for their air quality benefits and consider such programs
or strategies for the State.
8. The Council recommends that the State actively pursue the
"smart growth" portion of the State Plan in order to reduce
the increasing VMT statewide, recognizing that significant improvements
in public transportation infrastructure will be required to
meet this goal.
9. The Council supports the continued use of onboard fueling
vapor recovery, which will lessen emissions while refueling.
10. The Council continues to support a statewide public awareness
and education program with emphasis on the impact of automobiles
on air quality in general and air toxics in particular. This
program should continue to stress the importance of reducing
vehicle miles traveled, the advantage of the use of public transportation,
the benefit of the purchase and use of LEVs, ULEVs and ZEVs
(respectively, low, ultra-low and zero-emission vehicles), as
well as the importance of good vehicle maintenance.
11. The Clean Air Council, in its own deliberations, recognizes
that reasonable measures to smooth the flow of motor vehicle
traffic and lessen street and highway congestion will decrease
air pollution from cars and trucks. The Council knows that over
the last two decades, New Jersey's municipalities, counties,
and the State Department of Transportation have taken many positive
steps to improve traffic flow. These steps include the following:
providing left- and right- turn lanes at many intersections;
reconstructing certain intersections to eliminate confusion,
jogs, and offsets which interfere with signal timing and traffic
flow; improving signal timing; converting "isolated" signal
installations from fixed timing to actuated operation; putting
signals on "flashing" mode at night where traffic flows permit;
synchronized, interconnected signals favoring inbound traffic
during the morning rush hour, and outbound traffic during the
evening rush hour; and synchronization where appropriate during
the day; other approaches, such as bike paths, bus shelters,
carpool / vanpool encouragement, etc.
12. To the extent that there remain additional opportunities
to implement any of these "reasonably available control measures",
the authority responsible for each area should be encouraged
to complete the measure. The Council understands the question
of the cost of each investment. The Council also understands
that, for comparison, New Jersey has committed $500 million
to the Enhanced Motor Vehicle Inspection / Maintenance System.
In addition to the above automobile-related recommendations,
the Council has additional recommendations as follows.
13. The Council supports efforts to improve recycling of all
potentially usable waste streams and to diminish reliance on
landfills for solid waste management. Existing operating as
well as closed landfills should be tapped to capture and re-use
landfill gases, which contribute to global warming.
14. The Council continues to recommend more validation and
verification of the air toxics data and fine particulate data
collected in the State.
15. The Council recommends that the NJDEP continue to be alert
to the development of new control technologies for air toxics,
so that such technologies can be incorporated into the Department's
state-of-the-art manuals for use where appropriate in New Jersey.
16. The Council recommends that the state bring smaller, yet
significant, industrial and electric generating stationary sources
into air pollution control programs to help achieve the State's
air quality goals. Emissions from distributed generation during
high ozone periods need to be addressed so that distributed
generation sources lower precursor emissions rather than adding
to the peak ozone problem.
17. The Council recommends that the State adopt financial
incentives for the use of alternative and renewable sources
of energy to replace or complement polluting fossil fuels.
18. The Council recognizes that indoor sources of air pollution
contribute significantly to health concerns and recommends that
the NJDEP provide technical assistance to those agencies in
the State which regulate and investigate indoor air quality.
Commissioner Robert C. Shinn, NJ Department of Environmental
Before addressing what future actions the NJDEP should take
to curb air pollution, I want to review past successes. The
strategic planning process that we initiated has been working
well. Our database contains more than 30 years of air quality
monitoring data. New Jersey air is now cleaner than it has ever
been since monitoring began. This is no small feat given the
density of people and vehicles. The fact that the Supreme Court
upheld that public health, not cost, is the primary consideration
for air quality standard is critical.
Therefore, going forward, we see the state's responsibilities
as maximizing emissions reduction cost effectiveness and using
of multi-site initiatives where feasible. The State intends
to use innovative strategies to encourage sustainability, improve
energy conservation and provide co-beneficial emission reduction
Beyond 2000 the most important aspect will be to encourage
multi-state coordination through the Ozone Transport Assessment
Group (OTAG). This involves 28 eastern states that are receivers
and senders of air pollution. An example of successful OTC action
is the NOx budget rule, which provides a flexible control program
for very large boilers and electric generating units mostly
in power plants. This rule sets the total NOx reduction and
caps NOx emissions for each state in the region. Each source
is given an initial NOx emission allowance for the ozone season
(the seven-month period from April through October) and is free
to trade or acquire allowances to the extent that the total
budget is not exceeded. We are now in phase 1, phase 2 starts
on May 1, 2002.
This NOx budget rule should be a model for the control of
other pollutants including mercury, sulfur dioxide and carbon
dioxide. A four-pollutant strategy for power plants could be
built from our past success.
The current State Implementation Plan is tied to the OTC's
Memorandum Of Understanding (MOU) which supports six additional
model rules drafted by the OTC with the help of many stakeholders.
The DEP will propose all of these rules to close the gap on
emission reductions needed to attain the one-hour ozone air
quality standard. We will use these rules along with suggestions
from this hearing to provide multiple emission improvement.
Grace Sinden, American Lung Association of New Jersey
It is evident that we have come far in improving air quality
in the past 30 years. However, the American Lung Association
is very concerned about the sharp rise in asthma in New Jersey.
We estimate that 430,000 people in New Jersey suffer from asthma
and 122,000 of those are children. Asthma deaths in New Jersey
doubled between 1980 and 1990 and we know that air pollution
is a dangerous trigger for asthma attacks. A recent Robert Wood
Johnson study found that hospital admissions for asthma rise
significantly on high ozone days.
While New Jersey has reduced pollution from stationary sources,
it has a growing problem with mobile sources. On-road vehicles
are responsible for 44% of NOx and 30% of VOCs; therefore, cleaner
cars, buses and trucks will be the critical challenge in achieving
clean air. New Jersey should be a leader in this area. The following
are ALA's recommendations for cleaning the air:
- Adopt the California Low Emission Vehicle (LEV II) program
to promote low and zero emission vehicles. This has already
been done in New York, Massachusetts, Vermont and Maine.
- Create tax rebates to clean, fuel efficient car buyers and
conversely place an extra tax on SUVs and vans to compensate
for their disproportionate air pollution.
- Promote New Jersey's strong environmental policy as a lure
for a highly trained work force.
- Enact taxes and other incentives for efficiency and use
of alternative sources of energy to replace or augment polluting
- Plan for the use of alternative non-polluting buses by New
- Eliminate diesel fuel vehicles.
- Oversee the efficiency of enhanced vapor recovery systems
at service stations.
- Encourage municipalities to conduct once a week garbage
collection and begin the regulation of two-stroke engines.
- Mandate zero emission school buses to protect our children.
- All of these goals should be conveyed to the public through
an active public information program through media as well
Paul Lioy, Environmental & Occupational Health Sciences
The adoption of the eight-hour ozone standard and its re-affirmation
by the US Supreme Court in 2001 are important first steps toward
improving respiratory health in New Jersey. We know from field
studies conducted on active children in summer camps that there
are changes in lung function on high ozone days. Additionally
an analysis of Emergency Room visits at seven New Jersey hospitals
indicated that asthma attacks in summer are related to high
ozone. There are many toxicology studies that prove stress on
the lungs is related to atmospheric ozone.
These studies point to the necessity of overall reduction
in atmospheric ozone not just the reduction of peak occurrences.
The appropriate modeling simulations coupled with NOx reductions
can direct the OTC to design ozone precursor reduction strategies
that focus on reducing the burden of ozone and not just eliminating
the peak readings.
In regard to other pollutants, especially PM 2.5, recent epidemiological
studies completed since 1997 support the need for this standard,
even though causative agents or mechanisms are still unknown.
We now know that we can reduce the particulate matter if we
reduce the ozone because much of PM 2.5 in New Jersey is in
the form of sulfates and VOCs. These particulates will be reduced
when we reduce the precursors of ozone.
Regarding air toxics, we need to develop better toxicology
to assess reasonable low exposure risk issues because the current
unit risk factor design values do not reflect actual potential
risk. We also need to minimize the introduction of new air toxics
to the environment by conducting a thorough analysis of single
or multiple media exposures. The toxicological studies need
to focus on the potentially exposed population.
Indoor sources need to be studied since 95% of a citizen's
time is spent indoors. The state needs to support the RIOPA
(Relationship between Indoor and Outdoor Personal Air) studies
that are showing greater concentrations of chemicals like benzene
and formaldehyde indoors.
Jim Sell, Counselor National Paint & Coating Association
NPCA is an industry association established in 1888 consisting
of over 400 companies, which manufacture consumer paint products
and industrial coatings.
The association's efforts to reduce solvent materials from
coating pre-date the federal clean air regulations. Waterborne
coatings now represent over 80% of the coatings applied today.
The problem with waterborne coatings is that they are not
as durable as coatings made with solvents. If a coating must
be applied more often or does not last as long, there will be
more repainting. Even with a lower VOC coating, the net result
may be an actual increase in VOC emissions because more of the
coating is being used. Sometimes the expectations of the regulations
on VOCs can exceed the realistic possibilities of coatings technology,
where too low a VOC limit can actually eliminate a viable low
VOC or waterborne coating.
There are, and will probably always be performance trade-offs
in the industry that will not permit the elimination of VOCs.
Many coatings can be used in lower temperatures in spring and
fall when there is no ozone formation. The absence of certain
solvents like glycol makes freeze/thaw stability highly problematic.
There are other problems, such as the fact that stains absorbed
into wood need solvents to do a better job.
We estimate that our suggested table of standards can minimize
trade-offs while securing additional VOC emission reductions
beyond those achieved by the national AIM rule. Our table of
standards would result in an additional 12% to 13% reduction
in VOC emissions. Our high VOC specialty coatings, such as roof
coatings, are used in low volume and would require multiple
applications if VOCs were not present.
Joe Yost, Senior Affairs Rep, Consumer Specialty Products
CSPA is the Consumer Specialty Products Association, formerly
the Chemical Specialties Manufacturers Association. Currently,
43 of our member companies have facilities in the State. We
represent such companies as Honeywell, Procter & Gamble
and E.I. duPont de nemours. Member companies manufacture and
sell products used in every American home.
Along with the Cosmetic, Toiletry and Fragrance Association
(CTFA) we support the adoption of uniform consumer products
regulations for the control of VOCs in the Northeast and Mid-Atlantic
states. Currently, there are two sets of regulations being considered.
One is the California regulations and the other is the OTC Model
Rule for Consumer Products. CSPA member companies manufacture
and market almost every product covered by the draft OTC model
regulation for consumer products. We therefore strongly urge
that if NJDEP decides to promulgate regulations for consumer
products, then CSPA urges the State to adopt the OTC Model.
Consistency in the manufacture and marketing of these products
is critical to our member's financial health.
During the last ten months, CSPA has worked with state officials
in the OTCV's consumer products workgroup. We commend their
efforts to establish uniform clean air regulations within the
ozone transport region. We also support the OTC's decision to
establish January 1, 2005 as the effective date for OTR states'
consumer products regulations.
Jeff Trask, American Petroleum Institute
New Jersey requires service stations to have vapor recovery
systems. This technology involves the collection of vehicle
refueling vapors and reduces VOCs in the environment as well
as reducing service station personnel exposure.
Changes to this system will enhance vapor recovery by requiring
onboard refueling vapor recovery. This vehicle-based system
will be installed on most new gasoline vehicles by model year
2006. The vapors will be captured and recycled through the fuel
system of the car.
Bruce Carhart, Executive Director, OTC
The Ozone Transport Commission was created in the Clean Air
Act Amendments of 1990 to coordinate and control ground level
ozone planning in the Northeast and Mid-Atlantic States. It
was created because of the regional air pollution problem. Although
only 12 states and the District of Columbia are in the OTC,
28 states are actually contributing to the regional ozone problem.
The Ozone Transport Assessment Group developed six model rules
to control ozone. We hope these rules will help the eight-hour
ozone standard as well as the one-hour ozone standard. We looked
at cost and at the quantity of reductions. At first we focused
on 14 measures, we identified these in January 2000 with June
2000 as the deadline for setting priorities. We held hearings
and the six model rules involve the following:
- consumer products
- architectural and industrial coatings
- portable fuel containers
- permeability standard for cutting VOCs
- solvent cleaning
- select fuel combustion sources, focusing on NOx emissions
We are hopeful that these rules will result in overall emissions
reduction for the broader Ozone Transport Region (OTR). This
package addresses both short-term and long-term needs of our
states and addresses the emission reductions shortfalls that
EPA identified. Of the six model rules, five of them focus on
VOCs and one on NOx. Actual emissions state to state will vary.
Another problem that needs addressing is the distributed generation
of electric power, that is, power generated at the point of
use. These are relatively small units that may not be permitted.
These sources are growing rapidly. However, some use electric
power generators that are cleaner than others. For instance,
microturbines are cleaner than diesel engines. We are very encouraged
about the development that has gone into fuel cell technology.
These will be even cleaner than microturbines. The question
is, how can the use of these distributed generators be encouraged
to use cleaner technology, especially the companies that are
using diesel generators. One way would be by granting permitting
incentives for cleaner technology.
The new Memorandum Of Understanding (MOU) just signed by all
of the OTC states sets forth new regional control measures based
on the six model rules. This will hopefully result in regional
consistency and encourage regional markets for cleaner consumer
and commercial products so that a particular consumer product
could be manufactured to the same standard whether it is in
New Jersey or any state in the region. Another recently signed
MOU involves diesels and we support the new diesel engine and
fuel rule. However, there are consent decrees with engine manufacturers
for 2005 and 2006 and OTC states prefer this timeline. All of
the OTC's MOUs are compatible with the states' SIPs.
John Filippeli, Chief USEPA Region 2 SIP Section
We have made great progress in controlling air emissions over
the last thirty years. Although the US population has increased
by 33% and our vehicle miles traveled (VMT) have increased 140%,
air pollution nationwide for six principle air pollutants has
decreased by 31%.
The new regulations for ozone and particulates were recently
challenged in court by the American Trucking Association. On
May 19, 1999 the D.C. Circuit Court limited the manner in which
EPA could enforce those standards. The case went to the Supreme
Court who upheld that public health, not cost, is the primary
consideration for air quality standards. This reaffirms EPAs
role in controlling air quality.
Although much progress has been made throughout the US, there
are still six severe one-hour ozone areas and New Jersey is
among them. I would like to address the one-hour standard, the
eight-hour standard and strategies for bringing ozone into control.
Some of the strategies include a federal vehicle program.
The LEV is expected to provide a 70 percent emission reduction,
reformulated gasolines and more stringent standards for SUVs
and light trucks will help as well, especially since these are
becoming a larger percentage of the fleet. NOx control for heavy
duty vehicles and off-road vehicles will help ozone. There is
also energy conservation, less volatile products and solid waste
control. Cool cities is another option for controlling urban
heat effects. Painting light colors on surfaces has been shown
to reduce ozone-forming heat islands. In Houston, where the
ozone level is excessive, they are considering regulating lawn
mowers, landscaping operations and port operations and fleet
control. They are looking at "smart growth," which is land use
and development more friendly to air quality. Houston is relying
heavily on motor vehicle and off-road vehicle measures. New
Jersey's current rate of progress report will be submitted to
EPA and will show emission reductions through 2007.
Keith Ciampa, Vice President, World Energy Alternatives
I am here to talk about World Energy Alternatives, which is
a company that manufactures and distributes biodiesel fuel,
a renewable fuel that burns cleaner than traditional fossil
fuels. The diesel engine was actually designed to run on peanut
oil, so biodiesel is not new. It can be purchased at almost
any commercial pump in Europe because it is not taxed and thereby
saves money. In Medford Township, NJ a project there runs 20
of their school buses on biodiesel. Currently 35 states have
fleets running on biodiesel. Gulf Oil is backing the current
In the 1970s the Department of Energy planned to displace
by the year 2000 10% of on-road petroleum and 30% by the year
2010. However, they succeeded in displacing only .3%. In the
1998 Act the use of alternative fuels gives credit as if the
vehicle were light duty. In NJ this year 75% of the new light
duty vehicles purchased have to be alternative fuel, either
propane or natural gas. Biodiesel should be part of the mix.
As a diesel replacement fuel biodiesel burns cleaner and is
renewable because it is made from soybeans. The carbon dioxide
produced in use is then sequestered in growing the product.
It also produces less particulate matter. Although the BTU content
is a little lower than low sulfur diesel, it is important to
remember that gasoline uses almost as much energy to produce
as it provides when we burn it. Biodiesel works in existing
engines and it costs only about 15 cents more per gallon than
The air quality benefits far outweigh this price difference.
Disadvantages include its performance in cold weather and its
NOx emissions, although the lower VOCs counteract the higher
NOx. Also, there is no benzene or formaldehyde and no sulfur.
Daniel Dowiak, PSEG Energy Technologies - Mgr of Business
I represent PSE&G Energy Technologies, a company covering
Virginia Beach through Boston and my topic is distributed generation
(DG). We look at this as the generation of electricity and heat
recovery. Cogeneration at the site of consumption. We focus
on commercial and industrial sites. These on-site generation
facilities range from 50 kilowatts to 50 megawatts. Some are
microturbines, some are large gas turbines, some are diesel
turbines. We are the exclusive distributors for the Honeywell
75 microturbine in the northeast.
The most efficient turbine to deploy is a gas reciprocating
engine because it is easy to install, site, and permit. Some
of these turbines will use renewable technology like photovoltaic
and wind. Hopefully, future distributed generation will use
fuel cells although the only one available currently is United
Technologies CA 1200 kw system. There are others in development
like balers, plug power and wave power.
Some experimentation with distributed generation has been
done at supermarkets and fast food restaurants. In Chicago McDonalds
ran their restaurant on a single 75 kw microturbine that ran
well. Other ideal places for distributed generation could be
office buildings and data centers. The advantage of on-site
generation is its reliability and money saving potential. For
the most part on-site generation is also cleaner.
Some of the restrictions on distributed generation are that
the person who owns the generator must work through a load-serving
entity, like PSE&G. The economics will improve if we experience
a hot summer.
We are involved in a number of experimental uses of microturbines.
One is at a milking farm in New York where they collect the
manure, run it through a digester and the microturbines are
run on the waste methane gas. Another one in Philadelphia at
a naval shipyard operates off poultry and agricultural wastes.
The other byproducts are fertilizer and water. Distributed generation
is being designed into buildings today. We are installing microturbines
and fuel cells into a 50 story, 1.5 million square foot office
building in Philadelphia. As time goes on these units will become
more green and more economical to install. The incentives currently
being considered will begin to make renewable technologies very
attractive. Fuel cells might be as cheap as $3 a watt. This
is getting close to real economy.
Jim Sinclair, Vice President, NJ Business & Industry
There are over 16,600 companies in our association and all of
them are affected by air quality standards. The last twenty
years have seen dramatic reductions in air pollution in New
Jersey from industrial sources. Tons of reductions are evident
from even 12 years ago. Industry has done its part in reducing
emissions. Mobile sources and transport sources need to be targeted
to further clean New Jersey's air. National and regional models
for air pollution control are needed. New Jersey's current standards
are too stringent.
Currently, public transportation does not serve the working
public. The Governor should be at the forefront with incentives
and encouragement for public transport and alternative technologies
so that we see a dramatic reduction in air pollution from mobile
Eileen Moyer, Director of Regulatory Relations, Reckitt
The product line of Reckitt Benckiser includes Lysol, Wizard,
Spray n' Wash and Old English furniture polish. As Director
of Regulatory Relations for these products I recommend to the
council that the consumer products model rule be adopted as
set forth by the Ozone Transport Commission. This model rule
will reduce VOCs and thereby act as a control measure for ozone
For the last ten months I have been part of an industry task
force that has been working cooperatively with the OTC committee
to develop a model rule that will regulate the VOC content of
consumer products sold in the Northeast. The resulting products
model rule is one we urge New Jersey to adopt. Although the
industry is unsure of how compliance will be met, consistency
and uniformity are essential to industry's reasonable compliance.
A lack of harmony on these rules will create barriers to interstate
Travis Madsen, NJ Public Interest Research Group
As the Clean Air Associate with NJ PIRG, New Jersey's leading
consumer advocacy organization with 20,000 members, I intend
to address three issues; New Jersey's progress toward meeting
the one-hour ozone standard, the OTC model rules and the long-term
possibility of reducing ozone levels. Despite 30 years of progress
in cleaning New Jersey's air, attainment of the one-hour ozone
standard is not assured. In order to be in attainment New Jersey
needs to cut NOx and VOC emissions. We must not lose sight of
the fact that protecting public health is the ultimate goal
of clean air programs. We have an obligation to protect asthmatics
in the population and we know that ozone makes them more sensitive
to allergens. In Atlanta during the Olympics traffic was curtailed
with a resulting 41 percent decrease in asthma-related hospitalizations.
Passenger cars are the single largest source of ozone precursors,
68 percent of on-road NOx and 57% of on-road VOCs. Despite federal
programs to reduce mobile emissions, like the tier II emissions
standards, by 2005 cars and trucks will still contribute 27%
of all ozone precursors. New Jersey should make reducing emissions
from motor vehicles a priority. We need to implement California's
LEV II programs by 2008. This could reduce NOx emissions by
29 percent. It would reduce emissions on SUVs by 68 to 70 percent.
There would also be a zero emissions vehicle requirement, which
would require car manufacturers to provide ZEVs as a small fraction
of their new car fleets. LEV II is the single most significant
action New Jersey can take to protect public health from air
toxics and ozone.
Dave Foerter, Institute of Clean Air Companies
The Institute is a national association of companies that supply
air pollution control and monitoring technology for emission
of air pollutants, including emission of NOx, VOCs, HAP, particulate
matter and SO2, all of which contribute to the air pollution
that affects public health. ICAC businesses that compete with
each other offer the full spectrum of technologies available
and serve all stationary source emitters.
The ICAC applauds the effort to seek emission reductions from
mobile, area and stationary sources. Meaningful market-based
programs need the regulatory driver and certainty provided by
emission budgets designed to address air quality goals.
Although a lot has been accomplished to reduce ground-level
ozone in New Jersey, more can be done. The pool of available
and cost-effective control technologies have not been exhausted.
In fact, seeking additional NOx reductions from smaller industrial
and electric generating facilities is a logical step to achieving
state and regional air quality goals.
Reducing NOx as a precursor of ozone has the added benefit
of reducing acid rain and improving regional visibility. NOx
reduction also limits eutrophication due to nitrogen loading
of water bodies. The concept of multi-pollutant strategies that
provide multiple benefits should be an argument for a wider
range of control options and their cost-effectiveness.
The current recommendations of the OTC for a market-based
structure for NOx reduction does not stretch the resources available
for pollution control. They are not technology forcing. Control
requirements can be deeper and more pervasive.
Control technologies are in themselves more energy efficient.
Upgrades in oxidizer systems often result in both reduced energy
requirements and greater control efficiencies.
The new NESHAP/MACT rules offer a national framework for VOC
and HAP emission control. Frequently at the federal level, reduction
of HAP and VOC emissions are not required for already existing
sources. New Jersey should encourage many of the existing sources
to employ existing technologies that meet the requirements of
Matt Hooper - Electric Power Technologies, Inc.
It would be helpful to see charts with current NOx and VOC emissions
allocated by source. An explanation of the cost per ton of removed
emissions for each source type would be helpful for understanding
the proposed measures for emissions reduction.
I support legislation to financially penalize non-commercial
or passenger vehicles that achieve less than 25 miles per gallon
(a pollution tax) and the adoption of the California standards
for LEV and ZEV automobiles. Since mobile sources are the largest
contributor to air pollution in the state, they should not be
ignored when emissions are discussed.
B. Sashaw - Concerned Citizen, 15 Elm St., Florham Park
The Clean Air Council should oppose the use of lead shot by
hunters in New Jersey because it deteriorates in air/ground
and water. I also think that airplanes should have their emissions
tested. All modes of transportation should be responsible for
clean air, as well as factory smokestacks.
Editor: Eileen Hogan, M.A.
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