Clean Air Watch
Statement in Support of Amendments to the California Small Off-road Emission Standards and Test Procedures
Docket number EPA-HQ-OAR-2005-0133
June 29, 2006
My name is Frank O’Donnell and I am president of Clean Air Watch, a non-profit, non-partisan clean air watchdog organization.
Thank you for the opportunity to speak today. I will be very brief.
Aside from the fact that it has met all the appropriate legal requirements, there are two very big but simple reasons why EPA should grant California a waiver to proceed with its small-engine pollution standards.
1) Small engines are big sources of pollution and they can harm peoples’ health.
2) This is a state’s rights issue. By law, California has the right to protect its citizens from dirty air and should be permitted to exercise that right.
On the first point, smog is a serious public health problem: technically known as ozone, smog can cause asthma attacks among children and adults, send people to hospital emergency rooms, and reduce a person’s lung capacity. It has even been linked to premature death.[i]
Small engines are an increasingly large part of the smog problem.
California officials have noted that, on a gallon-for-gallon basis, small engines pump out 93 times more smog-forming emissions than 2006 cars.[ii]
To make another type of comparison, Northeastern state officials have noted that small engines spew out fully a tenth of all smog-forming emissions of volatile organic compounds on a typical summer day.[iii]
And as cars get cleaner and cleaner, small engines are becoming a bigger part of the remaining pollution problem.
California has adopted new small-engine pollution standards that it says would produce the equivalent of taking 800,000 cars off the state’s roads.
I believe these standards are absolutely necessary for California to make needed progress towards meeting national health standards for ozone. These standards are needed to meet compelling and extraordinary conditions. These standards are needed to help children avoid asthma attacks and trips to hospital emergency rooms.
On my second point, the Clean Air Act has long permitted California to set better-than-federal emission standards for most moving sources of pollution, subject to an EPA waiver.
In the past, EPA has granted waivers to permit California to set better standards for motor vehicles, including cars, SUVs and trucks. And the same thing should happen here.
This is a fundamental right that California has under the Clean Air Act. EPA should grant a similar waiver for California to proceed with pollution controls on new small engines.
In the course of EPA’s review of issues related to small engines, questions have been raised about safety and pollution controls and EPA has been directed to give “appropriate consideration” to safety factors.
We have long believed this to be a total red herring – a phony argument concocted by a politically wired, special-interest polluter that apparently would rather spend money on lobbyists and lawyers than on pollution controls that would improve people’s health. Or perhaps that polluter is just afraid to compete with other engine companies such as Kohler and Honda that have noted they can meet the standards without compromising safety.
I recall that we heard a similar argument in the 1970s by those who claimed that putting catalytic converters on cars would set off conflagrations. Well, it didn’t happen then, and it won’t happen here.
We believe that EPA has given “appropriate consideration” to the issue and put that red-herring to rest in its March 2006 report on safety, which concluded that “compliance with the anticipated emissions standards could somewhat reduce the risk to consumers.” [iv] Cleaner air and safer devices: it’s win-win.
Let me conclude with a simple thought: please grant the waiver so California can do the responsible thing – set better pollution standards to protect its citizens from dirty air.
[i] EPA, “Air Quality Criteria for Ozone and Other Photochemical Oxidants,” February 2006.
[ii] As reported in The New York Times, “A Greener Way to Cut the Grass Runs Afoul of a Powerful Lobby,” Felicity Barringer, April 24, 2006
[iii] June 21, 2006 letter to EPA Administrator Steve Johnson from Arthur Marin, executive director of Northeast States for Coordinated Air Use Management.
[iv] EPA fact sheet, “EPA Technical Study on the Safety of Emission Controls for Nonroad Spark-Ignition Engines Below 50 Horsepower,” March 2006