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August 04, 2016 | Diesel Technology Forum
Washington, D.C. – As currently configured, the Volkswagen Partial Consent Decree and Settlement will fail to effectively mitigate the lifetime total emissions of nitrogen oxides (NOx) prescribed by the court due to a funding scheme that favors less effective and available technologies and approaches when compared to proven and documented benefits of advanced clean diesel technology, said Allen Schaeffer, the Executive Director of the Diesel Technology Forum.
The Forum today filed its official comments with the U.S. Department of Justice (DOJ) on the matter of the Proposed Partial Consent Decree: Volkswagen (VW) “Clean Diesel” Marketing, Sales Practices, and Products Liability Litigation, Environmental Mitigation Trust (EMT) between VW and the U.S. Environmental Protection Agency (EPA) and the State of California. (VW was not involved in the drafting of these comments and VW does not support these comments.)
“The only thing we can trust is that as currently fashioned this settlement will not ensure timely and proven mitigation of the lifetime total NOx emissions reductions. There’s a good chance that it will go down in history as a huge missed opportunity for making immediate clean air improvements. We urge the DOJ and parties to the settlement to modify the structure and allocation scheme in the EMT to be technology neutral and more open to private fleets to achieve the NOx mitigation goals articulated by the Court,” Schaeffer said.
“We are hopeful that the Court reconsiders this plan and recognizes the importance of near term benefits from proven technologies to mitigate NOx emissions. Otherwise, years from now, communities around the country may be wondering why so many dollars yielded so little progress to achieve clean air compliance, when immediate gains from accelerating the adoption of new, available clean diesel technology would have delivered proven benefits today.
The partial consent decree released on June 28th outlines the details of the $14.7 billion settlements that includes a $2.7 billion Environmental Mitigation Trust to “fully mitigate the total, lifetime excess NOx emissions” from the vehicles at issue. The Trust is established to mitigate these emissions generated by the 550,000 light-duty VW diesel vehicles found to have been outfitted with the means to skirt emissions standards established by the EPA and the California Air Resources Board (CARB).
“Upgrading to new clean diesel technology is the most cost effective technology to reduce NOx emissions, according to a recent analysis conducted by the U.S. Department of Transportation using the EPA’s emissions model. Investments in new diesel technologies can reduce a ton of NOx for under $20,000 while other approaches cost over $1 million. This makes investments in clean diesel truck replacements 50 times more cost-effective than other approaches,” Schaeffer said.
“Even as some are now calling for further reducing NOx emissions from new heavy-duty diesel engines, government negotiators appear to have ignored their own studies and data in fashioning the terms of this settlement. They know that upgrading to clean diesel is the best option when it comes to getting the biggest bang for the buck for reducing NOx emissions,” said Schaeffer.
The Forum’s comments to the Department of Justice, called for a more technology-neutral approach for allocating funds, urged equal treatment of government and private fleets and outlined the additional air quality benefits that several states – Pennsylvania, New York and New Jersey – could achieve if they were to accelerate the replacement of older diesel trucks with newer clean diesel models. New York could realize 34,000 to 95,000 tons of NOx eliminated while New Jersey could realize 22,000 to 63,000 tons of NOx eliminated.
The Forum praised the approach of the EMT making it eligible to paying down the federal matching funds for Diesel Emissions Reduction Act projects, but suggested additional options for leveraging the DERA program and its well-documented effectiveness.
“While clean diesel technology is widely available today and ready to deliver immediate-term air quality benefits for communities around the country, the $2.7 billion Trust incentivizes heavy-duty technologies that are unproven at best, and unavailable for most applications today and may not be on the market many years from now, if ever. For example, the EMT would allocate almost double the funding to all-electric freight locomotives relative to clean diesel options, yet all-electric freight locomotives are not currently available in the U.S.
“The California Air Resources Board estimates that between 2012 and 2035 average annual daily emissions of NOx from diesel powered vehicles and equipment will fall by 643 tons as more clean diesel engines enter into service. Getting the latest clean diesel technology into the population of trucks and equipment in the largest numbers in the shortest amount of time offers the greatest opportunity to achieve clean air goals,” Schaeffer said.
“Not that upgrading government fleet vehicles is not important, but the EMT in its current form is even more problematic in its treatment of government over private fleets, offering greater access to more dollars for government fleets over private fleets, and offering higher funding levels for investments in boutique fuels and technologies rather than mitigating NOx emissions. Since government vehicles typically travel far fewer miles than private fleets, this in turn means that even fewer clean air benefits will be generated than from private fleets using newer technology,” Schaeffer said.
“Diesel engines developed to meet the most recent emissions standards generate substantial air quality benefits. A 2016 clean diesel engine that powers a Class 8 tractor-trailer truck will reduce NOx emissions by over 1 ton each year relative to a truck manufactured in 2007. While the population is growing, today only one-in-four trucks on the road is powered by the newest generation clean diesel engine that meets a near-zero NOx standard. Replacing older commercial vehicles and equipment will generate enormous and immediate term air quality benefits,” said Schaeffer.
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ABOUT THE DIESEL TECHNOLOGY FORUM
The Diesel Technology Forum is a non-profit organization dedicated to raising awareness about the importance of diesel engines, fuel and technology. Forum members are leaders in clean diesel technology and represent the three key elements of the modern clean-diesel system: advanced engines, vehicles and equipment, cleaner diesel fuel and emissions-control systems. For more information visit www.dieselforum.org.
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