... Please point to the specific sections restricting diesel emissions that are faulty, use sound science to explain why and then propose changes that would still achieve the same level of air quality... .
Hope I’m not stepping on Obert’s toes here, but as an air quality forecaster and someone who’s been involved in the air quality field in some aspect for nearly 25 years, I’m inclined to try to tackle this one.
In fact, there are some major faults with the latest on-road emission regs (in my opinion), the major one being their (EPA's) fixation with NOx emissions. Have you ever heard of the “weekend ozone effect”? This occurs when lower ozone precursors (ozone is the primary constituent of “smog”) on weekends result in HIGHER ambient levels of ozone. This has been observed for dozens of years, especially in California. It now appears that the main reason for this rise in ozone levels on weekends is the very large decrease in NOx emissions (relative to a smaller decrease in NMHC and CO emissions), mostly due to a large decrease in diesel truck traffic on weekends. Here are several links about the weekend ozone effect:
http://www1.eere.energy.gov/vehiclesandfuels/pdfs/deer_2002/session5/2002_deer_lawson.pdf
http://www.arb.ca.gov/aqd/weekendeffect/envair_wspa_com.pdf
http://www.raqc.org/ozone/Workshop/October 2, 2002/Doug Lawson.PDF
Biodiesel Magazine
http://www1.eere.energy.gov/vehiclesandfuels/pdfs/deer_2005/session2/2005_deer_lawson.pdf
AEI - Short Publications
http://www.alabamapolicy.org/PDFs/EnvIndicators.pdf
EPA Rule Is Making Ozone Smog Worse - by Joel Schwartz - The Heartland Institute
View News
http://www.greendieseltechnology.com/Stedman Presentation at DEER 2006.pdf
Interestingly, EPA has acknowledged this phenomenon in several of their technical support documents:
“…It should be noted, however, that the potential exists for a few localized areas to actually experience slight increases in ozone concentrations as a result of NOx emission reductions. …” (page 119)
EPA Final Regulatory Impact Analysis: Control of Emissions of Air Pollution from Highway Heavy-Duty Engines,
http://www.epa.gov/otaq/regs/hd-hwy/1997frm/hwy-ria.pdf (this supports the reg that is currently imposing such strict limits on our diesel pickup trucks)
“…When NOx levels are relatively high and VOC levels relatively low, NOx forms inorganic nitrates (i. e. , particles) but relatively little ozone. Such conditions are called “VOC-limited. ” Under these conditions, VOC reductions are effective in reducing ozone, but NOx reductions can actually increase local ozone under certain circumstances…. ” (page 33/231)
Federal Register / Vol. 72, No. 63 / Tuesday, April 3, 2007
“…Under these conditions [VOC-limited], VOC reductions are effective in reducing ozone, but NOx reductions can actually increase local ozone under certain circumstances. Even in VOC-limited urban areas, NOx reductions are not expected to increase ozone levels if the NOx reductions are sufficiently large. … “ (page 2-41[42/114])
http://www.epa.gov/otaq/regs/nonroad/420d07001chp2.pdf
“…In urban areas with a high population concentration, ozone is often VOC-limited….
…Due to the complex photochemistry of ozone production, NOx emissions lead to both the formation and destruction of ozone…The terms “NOx disbenefits” or “ozone disbenefits” refer to the ozone increases that can result from NOx emission reductions in these localized areas…. ”
http://www.epa.gov/ttn/ecas/regdata/RIAs/ozoneriachapter2.pdf (pp 2-1 - 2-2)
EPA justifies the “increases in ozone in localized area” by suggesting an overall decrease in ozone will occur in most locations. In the first place, this is dubious since BASED ON MY OWN STUDIES, there is no evidence of any decreases in weekend ozone levels despite the fact that I live in an area that’s supposed to be “NOx limited”. Secondly, even if that was true, making air quality WORSE for poor inner-city residents does not seem like an effective policy to me.
In my opinion, EPA should craft regulations to discourage GASOLINE vehicles and ENCOURAGE diesels if better air quality is truly the goal.
Firstly, GASOLINE appears to be a much larger component of ambient PM2. 5 than diesel in most locations (North Front Range Air Quality Study; Eugene Kim, Philip K. Hopke; “Source Apportionment of Fine Particles in Washington, DC, Utilizing Temperature-Resolved Carbon Fractions. ” Journal of the Air & Waste Management Association, Volume 54, July 2004, Pages 773-785; : Alan W. Gertler, “Diesel vs. gasoline emissions: Does PM from diesel or gasoline vehicles dominate in the US?” Atmospheric Environment, Volume 39, Issue 13, April 2005, Pages 2349-2355)
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http://www1.eere.energy.gov/vehiclesandfuels/pdfs/deer_2007/poster3/deer07_lawson.pdf slide #2 - note this is ambient diesel PM2. 5 from ALL diesel sources - on-road and off-road.
Secondly, gasoline vehicles are BY FAR the largest sources of ambient NMHC (50% to as much as 80% in urban areas! -
http://www1.eere.energy.gov/vehiclesandfuels/pdfs/deer_2002/session5/2002_deer_fujita.pdf, slide #16; Steven G. Brown, Anna Frankel and Hilary R. Hafner; “Source apportionment of VOCs in the Los Angeles area using positive matrix factorization”. Atmospheric Environment, Volume 41, Issue 2, January 2007, Pages 227-237; John G. Watson, Judith C. Chow and Eric M. Fujita; “Review of volatile organic compound source apportionment by chemical mass balance. ” Atmospheric Environment, Volume 35, Issue 9, March 2001, Pages 1567-1584).
CO from gasoline vehicles also makes up an overwhelming proportion of CO in urban areas (up to 95% per EPA -
http://www.epa.gov/air/airtrends/aqtrnd01/summary.pdf, EPA Hazard Assessment Document for Diesel Engine Exhaust (page 43)).
If these regs wind up driving everyone back to gasoline vehicles, air quality will suffer in my opinion.