Text Box: Below the line is the revised document being edited for improvement and accuracy, and now directed to US EPA on this stated final day for comments applicable to the insane proposition to (instead of fixing a poorly configured, unpopular program) stop Vehicle Emission Testing.  According to KY EPA, the result is an increase of pollution — 13,000 Tons per summer day.
Here are some additional links:
 
John Schmidt’s comments submitted at the Hearing 2005 Jan 04
Comments by Tom Fitzgerald of Kentucky Resources Council  
Channel 9 News Report
 
_________________________________________________________________
2005 May 25
 
Michele Notarianni
Air Planning Branch
U.S. Environmental Protection Agency
61 Forsyth St SW
Atlanta, GA  30303-8960
 
John Lyons, Director
Kentucky Division for Air Quality 
803 Schenkel Lane
Frankfort, KY  40601
 
Re:  401 KAR 59:760 and Proposed SIP Revision for Northern Kentucky, eliminating Vehicle Emission Testing
 
Fellow Citizens, Honorable Representatives, and Ministers of Air:
 
Context 
Northern Kentucky is the Heart of our Nation.
 
1.  Geologically, the Cincinnati Arch, centered in Northern Kentucky, is the oldest, deepest exposed rock layer (Ordovician) in the United States.  It is the anchor of the main North American tectonic plate, around which newer, less stable layers subside.  Faults, in rock layers, the precondition for earthquakes, are no closer than 50 miles away from Northern Kentucky.
 
2.  With regard to commerce, NKy is a 3-county core part of the 15-county Cincinnati Metropolitan Area, named by the US Census Bureau:    Cincinnati-Middletown, OH_KY_IN Metropolitan Statistical Area, code 17140, one of 76 US Major MSAs.
 
3.  Nationally, the 50 states are readily divided into East and West across the central plains.  The 33 states comprising the Eastern portion of the populous US, bounding a nearly aggregated complex of MSAs (Major and Minor), comprise 75%, 218 million, of the US 2003 population.  NKy is at the center of this area.  A1000 mile radius area around Northern Kentucky includes every Eastern US Major MSA, and over half (7million) of the Canadian population.  No other North American MSA is centered in a more populous 1000 mile radius.
 
4.  Geographically and climatologically, NKy is the Top of the South.  It is the Northernmost extent of the Mason-Dixon line.  
 
5.  Logistically, NKy is the Gateway to the North and Gateway to the South, primarily over the Brent Spence Bridge.  Comparable, alternative North-South routes are:
· westward 70 miles to I-65
· eastward 130 miles to I-77.
Within the Eastern North America, Northern Kentucky is on the central artery supporting the flow of commerce over Interstates 71, 74, and 75.
 
While there are many benefits of this location in the nation's transportation network, there are downsides familiar to commuters who traverse the Brent Spence Bridge:  congestion, slowed movement, and pollution.
 
 
 
Air 
 
While i can live several days without food and water, i cannot live more than 5 minutes without oxygen.  Except for those of us connected to heavy, metal oxygen tanks, we all share and depend on the same source for our oxygen, that is our Air.
 
While i can make choices for my supplies of food, and even water, i do not have a choice, beyond heavy metal tanks, for my oxygen.  I must get my oxygen from our common pool of Air.  It is the most public resource.
 
Air is a mix of 3 primary ingredients:  21% oxygen,  78% nitrogen (relatively inert), and 1% Argon (even more inert).  A small fraction is carbon dioxide.  As we consume oxygen we expel carbon dioxide, which is fortunately consumed by vegetation while producing more oxygen to maintain the balance of life.
 
But life today also includes combustion, producing the energy we consume at work and home, and especially while motoring about.  Perfect combustion, like animals, consumes oxygen and produces carbon dioxide and water.  But combustion is never perfect and so other products are created, most of which are harmful to life and so poison the most valuable public resource upon which all life depends.
 
So while we have become increasingly inventive at harnessing the power of combustion we must also be inventive in minimizing the poisoning of our air.  One of these innovations is periodic testing of our combustion engines to assure optimum combustion and minimum poisoning of our Air.  Every sizable urban area in the United States has employed this testing of our most prevalent source of pollution. 
 
Not bound by state lines, US EPA defines regional air pollution areas, generally within MSAs, that here involve 3 states, Indiana, Ohio, and Kentucky, each of which is mandated to decrease air pollution below thresholds determined by US EPA to be unhealthy when surpassed.  The two primary sources for this pollution are electricity generation and motor vehicles.
 
The State Implementation Program (SIP) defines the methods by which to achieve the necessary reduction of pollution.  There are 4 primary pollutants produced by motor vehicles:  Particulate Matter, Hydrocarbons, Nitrogen Oxides, and Carbon Monoxide.
 
Today, we consider abandoning a method that has been effective at reducing pollution in Northern Kentucky.  Why?
Two arguments have been made:
1.  It is painful.
2.  It is not needed.
 
Simple responses to these arguments might be:
1.  It is less painful then refilling our gas tank, because it generally costs less, and we do not have to get out of the car.
2.  It is needed to eliminate 13 tons of poison from our roadway Air every summer day.
 
 
 
Save the VET !
 
While the proposed SIP revision proposes to eliminate 1 ton per summer day of Volatile Organic Compounds (VOCs) in exchange for adding 2 Tons of other pollutants from motor vehicles, we should consider these points:
 
A.  We are not satisfied with the purity of our air when there are any poisons in it, so all methods cheap and easy, accomplishing cleaner air should be maintained.  It is not satisfactory to live with over 25 Tons of pollutants per day.  Who would not prefer 2 Tons less, when all it costs is a 20 minute visit every 2 years?
 
B.  The values for pollution magnitude on which the Proposed SIP revision is based derive from models which depend on data measured at a location.  Currently, across the 3-county Northern Kentucky area, there is an average of only one location per pollutant measured.  It is therefore likely that we under-estimate current pollution magnitude.
 
C.  The Brent Spence Bridge is the most significant factor in motor vehicle pollution generation.  It is the most probable cause of traffic slow-down, decreasing miles per gallon while increasing pollution.  Traffic volume over the fixed-capacity Bridge continues to increase, prompting our endeavor to augment the Bridge.  But there is estimated no result of this endeavor before 2015.  Therefore, over the next  decade, pollution will worsen based on this primary cause.  This factor is compounded by rapid growth of population in the Cincinnati MSA, coupled with increased use of the Brent Spence Bridge both by users within and outside of this affected area.
 
D. As a community, we are being asked to comment on a ridiculous either/or proposition:  either  Keep the VET, or Stop the VET.  This is ridiculous, because a rational alternative is not offered:  Improve the VET. 
 
Perhaps Emission Testing, as currently performed,  is not as efficient and effective as it could be.  Rather than throw out the baby with the bath water, let us consider improving the VET, making it more efficient and effective, and therefore less costly and less painful.  At least two potential improvements are feasible:
 
  1.  Since it is true that the newer the vehicle, the more likely it passes Emission Testing, why don't we consider exempting new car testing for the first 3 years?  The first test would be required during the 4th year of operation, or when the vehicle has exceeded 30,000 miles.
 
  2.  Half of the current VET programs across the nation, including our neighbor Ohio, use On-Board Diagnostics (OBD).  Every vehicle, beginning model year 1996, is equipped with a standard computer interface providing accurate, comprehensive and specific analysis of fuel combustion efficiency and thus minimization of pollution.  Implementation of OBD would cost almost nothing.
 
While tail pipe testing may be the only option for vehicles prior to model year 1996, OBD represents a more effective test as the years unfold and older cars are retired.
 
E. The price of gas is going up, not down.  Driving an inefficient combustion engine not only poisons our Air but also wastes your money.  The current VET price of $20 is a small fee to periodically check your vehicle and your mechanic to assure optimum fuel economy and minimum pollution.
 
After a decade of experience with VET, most vehicle managers have learned to attend maintenance prior to, or even prompted by, the unavoidable date with the VET.  As this “pressure” subsides due to VET elimination, cost-conscious individuals will let slide the “luxury” of vehicle maintenance.  Thus, while the Brent Spence Bridge bottleneck increases with growth of use, the using vehicles will operate less optimally, further exacerbating pollution, especially on the toxic corridor around which most humans aggregate.
 
F.1.  The exercise seeking to eliminate the VET has nevertheless uncovered new possibilities for cleaner air.  However, implementation of the proposed revision imposes a costly stress on a few business people in a short period of time, likely costing jobs.  By improving and keeping the VET, the stress on these businesses may be stretched over a longer period of time, easing the consequential strain.  Due to the fixed constraint of the limited Brent Spence Bridge, these gradual reductions will be desirable offsets to the increased pollution as Bridge bottleneck increases.
 
F.2.  If the VET is eliminated, fewer vehicle managers will pursue maintenance.  This will result in decreased demand for maintenance providers, causing business loss and job loss within this sector.  It is already a challenge to find good mechanics.  Fewer will be motivated to seek this skill.
 
G.  The measure of Air Quality by US EPA for this region is in transition from a 1-hour Ozone definition to an 8-hour Ozone definition.  Northern Kentucky has not yet demonstrated attainment of the new 8-hour definition; until we do, we should not jeopardize our current, hard-fought, 1-hour Attainment status.  Consequences of 8-hour nonattainment include loss of Federal highway funds and jobs.
 
H.  Another transition regarding US EPA Air Quality assessment in Northern KY involves new measures of Particulate Matter.  Medical science increasingly warns of the consequences of rising values of fine (less than 2.5 micron) Particulate Matter, including lung and heart disease.  2.5 PM can be more harmful than the older 10 micron measure.
 
I.  The 2004 December publication of the Journal of the American Medical Association reports a study proving a direct link between small increases in pollution with corresponding increases in disease and death.
 
J.  There has been increasing interest expressed by Chambers and Leaders to attract new and new-age jobs to this area and this state.  In the 2004 November report of the U.S. Economic Freedom Index (www.pacificresearch.org) by the Cincinnati Enquirer, KY and OH ranked 39 and 42 out of 50 states all competing for these "21st century brains".  My guess is that the 21st century brain will consider Air Quality high on the list of attributes when choosing a location for healthy living.
 
K.  After a decade of pathetic performance with consequential decline in fan interest, the Cincinnati Bengals, under the 2-year leadership of Coach Marvin Lewis have established a new basis for hope.  His message is "We cannot accept mediocrity."  It is a message equally apt to the quality of our most public resource.  It is not enough to be in Attainment.  That is a record of 8-8.   We must strive for optimum performance until we are champions of clean urban Air -- way under the thresholds of Attainment.
 
L.  Better than ever before, we understand we pay a price for Freedom.  As precious is our Freedom, we understand our civic responsibility to be a part of the solution, and not contribute to the problem.   Perhaps the highest call for duty, beyond the obvious military call, is for jury duty, when we are asked to defer our self-directed mission in order to participate in our justice system for the common good.  It is both painful and costly.  But it is our civic duty, and the shared benefit is confidence in Justice for All.  Similarly, we are asked to make a feeble gesture of civic duty, once every 2 years, for about 20 minutes, to contribute to cleaner Air we all share.  If you are irritated while you endure this biennial pain, consider, while you may wait in line, the sacrifice concurrently made by our soldiers and jurors.  Thank you for doing your share for cleaner Air!