To the best of my knowledge, VET is slated to begin in Canyon County July 1, 2010 under DEQ's new administrative Rule approved by the House and Senate a couple of weeks ago. DEQ, if not already, is about to sign a contract with the contractor to conduct the emissions testing program as per the administrative Rule.
Ada County's VET program will be changed accordingly to once every two years with the exception of new cars less than 5 years old and older than 1980 and at an annual cost of $20. If I am not correct in these specific items, I am close and it really doesn't make any difference because implementation of VET under this RULE is ILLEGAL!
Read the law: 39-1168. The LEGAL requirement that preceeds the LEGAL authority for DEQ to hold the meetings to develop the RULE and implement VET under the new rules in the Treasure Valley is that the "Director" (of the DEQ) "determines the following conditions (plural) are met:"
Condition (b) states, "The department (DEQ) determines air pollutants from motor vehicles constitute one (1) of the top two (2) emission sources contributing to the design value of eighty-five percent (85%)." The condition (a) outlines this last phrase and means "85% of a national ambient air quality standard, for three (3) consecutive years starting with the 2005 design value." In plain English, the ozone clean air standard is .075 ppm. 85% of .075 is .063 ppm. So if the rolling average of the fourth highest ozone monitor readings over a three years is at or above .063 ppm, which DEQ has stated for 2006, 2007 and 2009 is at .075, then this condition's requirement must be met before any further action can be taken by DEQ in regard to RULE making or VET implementation.
It is well known that vehicle emissions of NOx and VOC are precursor gases in the creation of ozone. Therefore, the critical issue is vehicle NOx and VOC emissions "ONE OF THE TWO TOP EMISSIONS SOURCES?"
The short answer is NO.
The 2002 Northern Ada County PM10 State Implementation Plan was gone over page-by-page and judged of "high quality" by DEQ, COMPASS, EPA and the Idaho Clean Air Force. In 2003, the EPA stated, "In this maintenance plan, procedures for estimating motor vehicle emissions are well documented." EPA then based its future reduced vehicle emissions budgets for Ada County's Transportation Improvement Programs and Regional Transportation Plans on the 2002 PM10 SIP plan data. TIPs and RTPs must be approved by both EPA and the Federal Highway Administration. The reductions call for NOx to reduce from 21.0 tons per day in 1999 down to 11.2 tons per day in 2010 and VOC to reduce from 10.4 tons per day in 1999 down to 6.1 tons per day in 2010. In December 2009,
In December 2009, COMPASS data submitted for the 2010 TIP showed vehicle NOx at 10.87 tons per day and VOC at 5.44 tons per day; reductions of roughly 50% NOx and 40% VOC, both confirming the 2002 PM10 SIP data and EPA required reductions.
DEQ also had the Desert Research Institute study the Treasure Valley air pollution based on 2005 data. While the official report was published in May 2008, the data for 2005 was known to DEQ. The report showed that vehicle NOx had reduced to 38.2% in 2005 from 49.7% in 1999.
Why is this important? Because during the House hearing on HB586, the law which is now 39-116B, the DEQ director used the 1999 data in her testimony in favor of this law and in 1999, vehicle emissions of NOx was the number 1 source and VOC, the number 2 source. DEQ KNEW AND HAD THE 2010 PM10 SIP DATA THAT SHOWED VEHICLE NOx WAS NUMBER 2 SOURCE AND VOC, NUMBER 4 SOURCE. DEQ KNEW THAT EPA HAD LOWERED THE VEHICLE NOx AND VOC EMISSION LEVELS FOR 2010. DEQ KNEW VEHICLE NOx WAS LOWER IN 2005 AND WOULD NOT BE NUMBER 1 BY 2010.
THIS IS NOT 1999. CONDITION (b) IS NOT MET. ALL 2009 MEETINGS ON THE RULE WERE ILLEGAL. IMPLEMENTATION OF VET IN CANYON COUNTY IS ILLEGAL. THE CONTRACT BETWEEN DEQ AND THE VET CONTRACTOR IS ILLEGAL.
The final insult is that DEQ stated specifically that VET in Canyon County would reduce vehicle NOx by 114 tons per year and VOC, 138 tons per year. Based on the acknowledged total Treasure Valley NOx and VOC, those amounts represent reductions of .41% and .37%, absolutely unmeasureable on any monitor and insignificantly miniscule amounts that would not have any effect on ozone creation. COST? $1.2 million out of the pockets of Canyon County citizens and a $2.4 to $3.6 million loss to Canyon County's economy. Please remind me: FOR WHAT BENEFIT to the Treasure Vallen air quality? NONE, NADA, ZERO!
Ada County: Your losses will be at least double these amounts.
Humor: COMPASS 2010 data shows Canyon County vehicles are responsible of only 7.43% of the vehicle miles traveled in Ada County. Even if 10% of Canyon County vehicles do not meet emissions standards, they drive less than 3/4 of one percent (0.74%) of the mileage in Ada County.
W. Allen Freeman