Copyright 1999 Federal Document Clearing House, Inc.
Federal Document Clearing House Congressional Testimony
July 21, 1999
SECTION: CAPITOL HILL HEARING TESTIMONY
LENGTH: 3414 words
HEADLINE:
TESTIMONY July 21, 1999 S. WILLIAM BECKER HOUSE SCIENCE ENERGY
AND ENVIRONMENT SULPHER IN GASOLINE AND DIESEL FUEL
BODY:
Statement of S. William Becker Executive
Director of the State and Territorial Air Pollution Program Administrators and
the Association of Local Air Pollution Control Officials at the U.S. House of
Representatives Subcommittee on Energy and Environment of the Committee on
Science Hearing on Reducing Sulfur in Gasoline
and Diesel Fuel July 21, 1999 Introduction Good afternoon. My name is Bill
Becker and I am the Executive Director of STAPPA - the State and Territorial Air
Pollution Program Administrators - and ALAPCO - the Association of Local Air
Pollution Control Officials - the two national associations of air quality
agencies in the 55 states and territories and more than 165 major metropolitan
areas across the country. On behalf of STAPPA and ALAPCO, I commend you, Mr.
Chairman, for convening this hearing to explore the extremely important and
timely issue of controlling sulfur in gasoline
and diesel fuel. I am pleased to have this opportunity to provide our
associations views. As I mentioned, STAPPA and ALAPCO represent the air
pollution control agencies in the states and territories, as well as in major
metropolitan areas across the country. Our members hold primary responsibility
for achieving and maintaining clean, healthful air nationwide and, as such, have
a keen understanding of the need to aggressively pursue emission reductions from
all sectors that contribute to air quality problems. In spite of the many air
quality improvements that have been achieved to date, we continue to face a
variety of serious air pollution problems in this nation. Similarly, while we
have taken significant steps in developing cleaner cars and cleaner fuels, we
have not gone nearly far enough. Emissions from mobile sources continue to be
major contributors to our air quality problems. The issue of
sulfur in gasoline and diesel fuel is a
critical one for state and local air agencies. Our interest in and commitment to
this issue is evidenced by two resolutions adopted by STAPPA and ALAPCO, calling
upon EPA to dramatically cut fuel sulfur levels nationwide.
Copies of these resolutions - the STAPPA/ALAPCO Resolution on a National
Gasoline Sulfur Cap (adopted October 28, 1997, amended April 7,
1999) and the STAPPA/ALAPCO Resolution on Sulfur in Diesel Fuel
(adopted October 13, 1998, amended May 18, 1999) - are attached. Air Quality
Need According to the U.S. Environmental Protection Agency (EPA), mobile sources
account for almost one-half of the nitrogen oxides (NOx) inventory, more than 40
percent of the hydrocarbon inventory, 80 percent of the carbon monoxide (CO)
inventory and 20 percent of the direct PM10 inventory. Reducing
sulfur in gasoline will decrease emissions of
hydrocarbons and NOx, which, in turn, will lead to reduced levels of ambient
ozone. Lower gasoline sulfur levels will also decrease PM and
CO emissions, improve visibility, address acid rain problems and reduce
greenhouse gases. Further, important reductions in toxic air pollutants will
occur, reducing the high risks these pollutants cause in many areas of the
country. Similarly, lower diesel fuel sulfur levels will
directly decrease emissions of sulfur dioxide, PM10, PM2.5,
PM2.5 precursors and acid rain precursors and reduce regional haze. In addition,
reducing sulfur in diesel fuel can indirectly decrease
emissions of other pollutants, including NOx and toxics, as well as visible
emissions from diesel engines, by enabling application of advanced catalyst
technologies and reducing the poisoning effect on these catalyst technologies.
However, all of these air quality benefits will be achieved in a meaningful way
only if sulfur is cut sharply. To use the National Ambient Air
Quality Standards (NAAQS) as an example: At the end of 1998, over 113 million
people lived in areas where at least one of the health-based NAAQS (including
the one-hour ozone standard and the CO, PM10, sulfur dioxide
and lead standards) was violated. Moreover, EPA projects that, in 2007, 28 areas
will violate health-based ozone standards and another 80 areas will be
precariously close to nonattainment, affecting about 129 million people. The
agency also projects a significant number of violations of particulate matter
standards in the latter part of the next decade, affecting tens of millions of
people. Clearly, we continue to face widespread and persistent air quality
problems. Very low- sulfur gasoline and diesel fuel offer a
tremendous opportunity to achieve vitally important emission reductions that
will help us achieve and maintain our clean air goals. Sulfur
in Gasoline The low-sulfur gasoline program
supported by STAPPA and ALAPCO is based upon a national, year-round
gasoline sulfur cap of no higher than 80 parts per million
(ppm), with an average level in the range of 30 ppm, to take effect in 2004, and
the inclusion of flexibilities to minimize the cost to and compliance burden on
affected parties. Our associations believe that such a program will achieve
important reductions in a variety of polluting emissions and further the
objectives of pollution prevention. The result will be cleaner, clearer air in
every area of the country. We are especially pleased that the low-sulfur
gasoline program proposed by EPA earlier this year directly reflects
almost every key recommendation made by STAPPA and ALAPCO over the past two
years. Sulfur in gasoline is a catalyst
poison. Its impact undermines the performance of vehicle emission systems. As
vehicle technology advances, this poisoning impact becomes more profound. A
sharp reduction in gasoline sulfur is absolutely necessary if
we are to comply with the statutory requirements of the Clean Air Act. Moreover,
as an emissions control strategy, it is technologically feasible, it is cost
effective and it makes sense. Emissions Impact Last year, STAPPA and ALAPCO
conducted an analysis to assess the emissions impact of reducing
sulfur in gasoline. Our intent was to quantify
the level of reductions to be achieved by a strong national gasoline
sulfur program and to express these reductions in terms to which
everyone can relate. The results, which are attached, were astounding. The
bottom line is that a national gasoline sulfur program with an
average in the range of 30 ppm will achieve emission reductions that are
equivalent to taking almost 54 million Tier 1 vehicles off the road today.
Further, to illustrate some of the localized benefits of such a program, we
calculated vehicle removal equivalencies for 29 areas across the country. The
results of this analysis are attached. As you review these figures, I remind you
that as the composition of our vehicle fleet advances technologically, the
impact of sulfur on emission control systems becomes more
pronounced. Based on data from a study conducted by the Coordinating Research
Council, we have illustrated the difference in emission reductions to occur from
Low-Emission Vehicles (LEVs) if sulfur levels were reduced from
current average levels of 330 ppm to about 30 ppm, as EPA has proposed, and to
150 ppm and 300 ppm, as the petroleum industry associations have advocated. As
the bar chart attached to this statement shows, the difference in LEV emission
reductions is dramatic. Technological Feasibility Clearly, meeting
gasoline sulfur levels of 30 ppm and lower is technologically
feasible. California s current Phase 2 reformulated gasoline
program sets an annual average sulfur limit of 30 ppm - with no
individual gallon exceeding 80 ppm - or a per- gallon flat limit of 40 ppm. This
program, which is already three years old, has been a huge success in that
state. Countries around the world are also regulating or proposing to regulate
sulfur in fuel to these low levels. The European Parliament has
recently adopted fuel quality specifications that will lower the cap on
sulfur in gasoline to 30 ppm beginning in
2005. Japan s gasoline has an average sulfur
level of 27 ppm, with the average sulfur level of premium
gasoline around 7 ppm. And New South Wales, Australia has
proposed to reduce its gasoline sulfur levels to 40 ppm. Cost
and Cost Effectiveness of Reducing Sulfur in
Gasoline Achieving average sulfur levels of 30
ppm appears to be affordable. EPA has estimated that such a limit would come at
a cost of an additional one to two cents per gallon of
gasoline. In almost every opinion poll taken in recent years,
the public has reiterated its willingness to pay what is necessary for
environmental protection. The agency has cited at least one company - CDTECH -
that has announced its ability to achieve these low levels at a cost of one to
two cents per gallon, and has noted that other designers of new
sulfur removal technologies have made similar claims. Further,
it is critical to recognize that five years, which is the amount of time that
will elapse before this program is proposed to take effect, is a technological
eternity in pollution control advancement. An examination of the history of EPA
and industrial projections of anticipated costs (e.g., acid rain and fuel
volatility) and the actual costs once rules were adopted and implemented reveals
that in almost every instance actual costs were far less than the projected
costs calculated by industry and EPA. STAPPA and ALAPCO also believe a national
program for achieving a 30-ppm sulfur limit is extremely cost
effective. Taking into consideration just the NOx+VOC reductions to be achieved
from a uniform national low-sulfur gasoline program with a
30-ppm average and an 80-ppm cap, such as proposed by EPA, the cost-
effectiveness would be less than $2,500 per ton of pollution removed. This
compares very favorably with many motor vehicle strategies we are implementing
today, such as: Basic Motor Vehicle Inspection and Maintenance - $5,850/ton
Low-Enhanced Motor Vehicle Inspection and Maintenance - $4,650/ton Phase I
Federal Reformulated Gasoline - $6,450/ton Phase II Federal
Reformulated Gasoline - $4,850/ton Phase 2 California
Reformulated Gasoline - $9,550/ton Clean-Fuel Fleets -
$61,000/ton National Low-Emission Vehicle Program without I/M - $17,400/ton
National Low-Emission Vehicle Program with LEV-only I/M - $2,300/ton Cost
effectiveness figures based on Appendix B of Chapter 5 of the final report of
the Ozone Transport Assessment Group: "Mobile Sources Assessment: NOx and VOC
Reduction Technologies for Consideration by the Ozone Transport Assessment Group
- April 11, 1996 and Amendment to Mobile Sources Assessment - May 12, 1997."
Moreover, when the full range of benefits of EPA s proposed low- sulfur
gasoline program is considered - including reductions in NOx,
nonmethane hydrocarbons, carbon monoxide, toxics, sulfur oxides
and greenhouse gases, visibility improvement, protection of emission control
devices, enablement of future technology and increased energy efficiency - the
cost effectiveness of the program increases further, making it an even more
attractive air pollution control option. National Versus Regional Program STAPPA
and ALAPCO strongly support the establishment of national requirements for
low-sulfur gasoline. A national program offers many advantages
over a regional or local program. First, and perhaps foremost, is the issue of
irreversibility - the extent to which sulfur makes all or some
catalysts less efficient. Many studies of this phenomenon have been undertaken.
To date, not one has been able to dismiss this as an issue. Therefore, to
forestall the very real and detrimental impact of irreversible catalyst
poisoning in vehicles that travel out of their home area with low-sulfur
gasoline, into an area with higher-sulfur gasoline and
then back home again, consistently low levels of gasoline
sulfur are imperative. Without a uniform national standard, the
integrity of the program will be sorely compromised. The discussion of
reversibility also begs the basic question of pollution prevention. If our
nation is truly serious about pollution prevention, a national, not regional,
program is necessary, aimed at preventing pollution at the source - in this
case, removing sulfur from fuel - rather than allowing the
pollution to occur and then requiring much more costly and less cost-effective
measures to ameliorate it. Second, a uniform national program provides
substantial air quality benefits over a regional program. While much of the
debate surrounding low-sulfur gasoline seems to have gravitated
toward ozone, it is imperative that we not overlook the many other important air
quality benefits of such a program, to be realized by both nonattainment and
attainment areas, east and west. While this program will, indeed, decrease
emissions of hydrocarbons and NOx, which, in turn, will lead to reduced levels
of ambient ozone, it will also provide an array of other important benefits -
including decreased particulate and CO emissions and acid rain precursors,
improved visibility and reduced toxic air pollution and greenhouse gases, thus
benefiting every area of the country, whether or not it has an ozone problem. A
third important advantage of a national program is that it enables automobile
manufacturers to meet strict motor vehicle control standards with the use of
advanced technologies, such as direct-injection engines and fuel cells. It is
widely acknowledged that gasoline sulfur has a detrimental
impact on advanced engine technologies, including the gasoline
direct- injection engine. These engines, which are currently being sold in
Japan, and are expected to be offered in the U.S., offer substantial improvement
in fuel economy and reductions in ozone precursors and greenhouse gas emissions.
The fuel economy savings alone could likely offset the modest consumer costs of
a national low-sulfur gasoline program. STAPPA and ALAPCO
continue to urge EPA to establish Tier 2 motor vehicle standards based upon new
and emerging technologies. It would be totally inappropriate for the
introduction of these technologies to be precluded because of a shortsighted
decision on gasoline sulfur. Fourth, a national
sulfur program will not only align the fuels program more
closely with a national Tier 2 program, but could also reconcile differences in
motor vehicle emissions performance that currently exist as a result of the
discrepancy between certification fuel and in-use commercial fuel. Finally, a
national program could be the most effective and easiest to implement from an
enforcement perspective. This uniformity could reduce compliance costs for
industry and minimize new reporting requirements. Sulfur in
Diesel Fuel As you are aware, EPA recently issued an Advance Notice of Proposed
Rulemaking (ANPRM) announcing its consideration of improvements in diesel fuel
quality and seeking comments on the merits of such action. STAPPA and ALAPCO
wholeheartedly agree that reducing sulfur in diesel fuel is of
critical importance. EPA currently caps sulfur in onroad diesel
fuel at a very high 500 ppm; sulfur in nonroad diesel fuel
(e.g., that used in construction and farm equipment) is not limited by federal
regulation. Advanced technologies, such as lean-NOx catalysts and adsorbers and
particulate filters, will likely be needed on new diesel engines in order to
meet future NOx and particulate reduction requirements for heavy-duty vehicles
and fuel-neutral emission standards for Tier 2 light-duty vehicles.
Sulfur in onroad diesel fuel at the 500-ppm level currently
allowed by EPA is an impediment to the introduction and effective operation of
these advanced technologies, which, in addition to reducing emissions, also
offer the opportunity to improve fuel economy. The World-Wide Fuel Charter of
vehicle and engine manufacturers currently recommends that advanced countries,
including the U.S., limit sulfur in diesel fuel to 30 ppm and
will soon recommend a further tightening of diesel sulfur
levels. In Sweden, sulfur in Class I diesel fuel - which
accounts for almost 100 percent of the market - is limited to 10 ppm. The
European Union has adopted a 50-ppm cap on the sulfur content
of both gasoline and onroad diesel fuel, to take effect in
2005, with incentives for early introduction and up to a two-year limited delay
in compliance. In our associations resolution on sulfur in
diesel fuel we recommend that: EPA adopt a national cap on
sulfur in nonroad diesel fuel (including that used in
locomotives and marine engines) of 500 ppm, to take effect as soon as possible
prior to 2004, so that nonroad diesel fuel is subject to the same
sulfur standards as currently apply to onroad diesel fuel; By
2004, EPA adopt a national cap on sulfur in both onroad and
nonroad diesel fuel of no higher than 30 ppm; Based on additional study, EPA
further lower national standards for sulfur in onroad and
nonroad diesel fuel and set appropriate standards for other characteristics
affecting diesel fuel quality and/or emissions, to take effect in 2007; In
reducing sulfur in diesel fuel, EPA ensure that there will be
no adverse impacts on emissions or drivability as a result of changes in other
fuel parameters and no increase in the sulfur content of other
petroleum fuels; and In setting sulfur caps, EPA consider
regulatory flexibilities, such as early reduction credits and other economic
incentives, to minimize the cost to and compliance burden on affected parties,
without significantly affecting the overall benefits of the program in any
particular area of the country. STAPPA and ALAPCO have evaluated the air quality
impacts of these recommendations and have concluded that by enabling the use of
advanced technologies, such as lean-NOx catalysts and adsorbers and particulate
filters, such limits on sulfur in diesel fuel will yield
enormous reductions in emissions. In fact, once EPA s forthcoming onroad
heavy-duty diesel standards are fully effective, those standards, coupled with
the cleaner diesel fuel, will achieve NOx and PM emission reductions of about 80
percent. This is equivalent to taking four out of five heavy-duty diesels off
the road. Last week, our associations submitted comprehensive comments to EPA on
the ANPRM (copy attached). In our comments, we urge EPA to move ahead with
proposal and promulgation of a low-sulfur diesel fuel program
consistent with our recommendations and in a timeframe that will allow a cap on
diesel sulfur of no higher than 30 ppm to take effect in 2004,
at the same time the national low-sulfur gasoline program is
implemented. We believe such a program is essential for several key reasons:
Substantial additional control of diesel vehicle emissions is necessary to
protect public health and the environment; Reducing sulfur in
diesel fuel will decrease emissions of SO2, PM10, PM2.5, PM2.5 precursors and
acid rain precursors from existing and future diesel vehicles and engines;
Substantially reducing the sulfur content of diesel fuel can
enable the use of currently available advance control technologies and newly
emerging advanced technologies, thus facilitating reductions in ozone precursors
and toxic air contaminants from new onroad and nonroad diesel vehicles and
engines and potentially achieving further reductions in SO2, PM10, PM2.5, PM2.5
precursors and acid rain precursors; Substantially reducing
sulfur in diesel fuel will facilitate significant opportunities
to clean up existing onroad and nonroad diesel vehicles and engines; and Clean
diesel fuel is spreading to different parts of the world, demonstrating both the
environmental benefits and technical feasibility. Conclusion In conclusion,
STAPPA and ALAPCO strongly support the timely establishment of national programs
effecting sharp reductions in levels of sulfur in
gasoline and diesel fuel, consistent with our recommendations
and timetables. We urge this because of the serious and continuing nature of the
air pollution problems facing this country and because such programs are both
technologically feasible and cost effective. While a number of sources
contribute to air pollution, motor vehicles are the dominant cause. Accordingly,
we also support stringent emission standards for passenger cars and light- and
heavy-duty trucks, both gasoline fueled and diesel fueled.
Moreover, we can not overstate the fact that the issues of vehicle emission
standards and fuel sulfur levels are inextricably linked. We
appreciate this Committee s interest in this most critical and timely issue and,
again, thank you for this opportunity to present our views.
LOAD-DATE: July 24, 1999 
