Board Resolution, 3/20/2002

Resolution

Air Pollution Control Board of Jefferson County

March 20, 2002

Opposition to HB618

 

Whereas, Jefferson County, Kentucky, is part of the Louisville interstate area that was redesignated to attainment of the 1-hour ozone National Ambient Air Quality Standard (NAAQS) on November 23, 2001, by the U.S. Environmental Protection Agency (EPA) but whose air quality is not in attainment with the 8-hour ozone NAAQS;

Whereas, The federal Clean Air Act requires long-term adherence to the federally-approved maintenance plans for areas redesignated to attainment. Further, the federal Clean Air Act requires conformity with the federally-approved motor vehicle emissions budgets (MVEBs) for approval of transportation plans;

Whereas, The emission reductions resulting from the Jefferson County Vehicle Emissions Testing (VET) program are included in the maintenance plans for the 1-hour ozone NAAQS and the carbon monoxide (CO) NAAQS and the regional (including portions of Bullitt and Oldham Counties, Kentucky, and Clark and Floyd Counties, Indiana) MVEBs for transportation conformity purposes;

Whereas, If the VET program were to be totally eliminated, then adherence with the maintenance plans for neither the 1-hour ozone NAAQS nor the CO NAAQS would be maintained using the currently-applicable EPA-approved emissions estimating models. Likewise, transportation conformity would not be maintained. Therefore total elimination of the VET program is not approvable by the EPA without requiring additional emission reductions from Jefferson County industry, businesses, and/or citizens;

Whereas, Total elimination of the VET program would cause significant increases of volatile organic compound (VOC), oxides of nitrogen (NOx), and CO emissions because high-emitting vehicles may not be identified and repaired. This poses a threat to the public health and welfare of the citizens of Jefferson County and the Louisville metropolitan area.

Whereas, Enactment of HB618 would require the elimination of the VET program by November 1, 2003;

Whereas, The VOC, NOx, and CO emission reductions resulting from the VET program were among the most cost-effective reductions implemented in Jefferson County to achieve and maintain attainment of the 1-hour ozone NAAQS and the CO NAAQS;

Whereas, After exhaustive study, the State Implementation Plan Advisory Panel to the Air Pollution Control Board of Jefferson County (Board) concluded that there were no cost-effective VOC or NOx emission control measures that were, or are now, not already being implemented;

Whereas, On January 19, 2000, the Board passed a motion to revisit the issue of exemptions from the VET program when the area was redesignated as attainment with the primary air pollution standard for ozone; and

Whereas, Jefferson County Judge/Executive Rebecca Jackson has proposed a plan for improving the VET program that would focus on testing and repairing vehicles that are the most likely to be high-emitting vehicles. Implementation of this VET Improvement Program would neither require the implementation of less cost-effective control measures by Jefferson County industry, businesses, and/or citizens nor jeopardize the federally-approved maintenance plans or transportation conformity demonstrations; now, therefore, be it

Resolved, That the Air Pollution Control Board of Jefferson County recommends to the members of the Legislature of the Commonwealth of Kentucky that HB618 not be enacted.

Adopted March 20, 2002

 

 

_________/signed/____________
Joseph D. Vibbert
Chairman

 

_________/signed/____________
Jonathan L. Trout
 Secretary-Treasurer