November 16, 2002

silhouette3.JPG From the desk of Jane Galt:

Low Hanging Fruit

Many people don't realize that much of the environmental "low hanging fruit" - the changes that make big differences in pollution with little differences in lifestyle -- have already been plucked. As population continues to grow, and people expect a rising standard of living, it's going to get harder and harder to keep reducing the footprint we leave on the earth. Fritz Schrank has one example: in Washington DC, vehicle pollution is presenting the politically impossible choices of intrusive mandated lifestyle change or no more transportation projects.

Posted by Jane Galt at November 16, 2002 3:55 PM | TrackBack | Technorati inbound links"); ?>
Comments

The effects of enforced environmentalism are going to be interesting. How adaptable, really, is the whole of the American population? We already see that in the Los Angeles area, environmental regulations are depressing the economy, although you have to admit that the enforcement bureaucracy is a large part of that problem. However, California is culturally a different world than the rest of the country. What would a businessman in say Denver do if merely to open a non-manufacturing retail establishment required 40 different environmental permits, as in LA? On the other side of the political spectrum, what would the reaction of the Hispanic Low Rider community be if their favored vehicles were made illegal due to pollution? Would they scream racism? You bet! For all, what would the reaction be if, as is quite plausible, the response is to ban ALL vehicular traffic from city centers? Talk about urban decay! Talk about ghettos! Being an environmental activist would become political suicide. Bring popcorn, this is going to be fun to watch! [tongue firmly and sarcastically in cheek]

Posted by: Roland Mar on November 16, 2002 4:34 PM

Politicians on the make have found it is quite easy to mandate a 90% reduction in pollutants, since they have no obligation to show how it can be done.

Posted by: Walter E. Wallis on November 16, 2002 5:06 PM

The obvious point which no politician or Green will ever address is 'A fossil fueled motor vehicle emmits Maximum "pollution" when running but at rest'. Aside from changing to electric, and relocating the emmissions to stationary sources, the best way I can determine to help the problem is to improve traffic flow. I will leave that exercise to your readers.

Dorf (that's ford spelled funny)

Posted by: dorf on November 16, 2002 6:07 PM

This runs counter to my intuition (bias?) that opportunities for substitution and technical change are increasing. I'll bet that with the right tax scheme (a tax on truck pollution? a high tax on gasoline?) you'd see a lot of gain in emissions control without really intense pain.

Posted by: Arnold Kling on November 16, 2002 8:51 PM

A Car & Driver columnist a few months ago made a point that (if I recall it correctly) a typical car in the mid-1960s parked in a garage emitted more hazardous pollution from paint decay than does a modern vehicle's tailpipe while idling in traffic.

Modern cars are extremely fuel efficient; the problem is not really efficiency but the fact that we have so many more of them. Hybrids may show some promise as the technology progresses, but all-electrics are still a pipe dream for the most part. The ones out there cannot meet the needs and preferences of the typical commuter, and there are externalities associated with producing the batteries.

Btw Arnold, any way you slice your proposal, enforcing it to a degree to make it effective would also come with a lot of economic pain. Although I would definitely be in favor of a proposal that can successfully convince more truck/SUV drivers who use their vehicle like a car to give stronger consideration to buying a car instead, remember which country we live in, and how its political processes work in such matters.

Posted by: anony-mouse on November 16, 2002 9:03 PM

I'll go out on a limb and make a prediction: suburban population growth will decline within 10 years as people move back to the city center. All you have to do is look at the difference between how suburban communities are managing their water resources versus how larger cities are doing it.

Take the Denver area for example. Both Golden and Castle Rock (two popular Denver suburbs) are already having severe water supply shortages while Denver owns pretty much the entire state's worth of water. Similar case in Southern California. LA owns all of the water.

In the end, the suburbs simply aren't going to have the buying power to compete with the larger cities. Same thing is true in air transportation. Look at what's happening to second tier airports.

Unfortunately I think the future of many cities in the US is very similar to what we're seeing already in places like Mexico City, Brazil and Southeast Asia. Although this might seem to be a dream come true for the Sierra Club, it'll mean devasting environmental disaster.

Posted by: Matt on November 17, 2002 12:38 AM

Matt,

It's true that many cities, even in the wetter areas, have a better assured water supply than the suburbs. But in the cities I'm familiar with, that's not a big factor. There's also the sharing issue; Baltimore already shares its water with Howard county and Columbia (and I think the Baltimore county suburbs), and I believe Westchester county is served by NYC's water system.

Water is an important quality of life issue, but it's not the only issue. Traffic, high taxes, crime, and poor schools are all factors keeping people out in the suburbs.

My impression is that the real water hogs are the farms, and they certainly can't compete in a bidding war with a city. I'd look for a shift to lower-water crops; alternately, the farmers can sell out to developers and we'll have even more sprawl...

Posted by: PJ/Maryland on November 17, 2002 1:23 AM

The main problem is our failure to obey the wishes of our betters. We won't ride their trolley? Cut one lane off the freeway. We still insist on driving to work? Take away free job parking. Still too many cars? Take away more of the road funds to build more trolleys to wherever.

Posted by: Gene 6-Pack on November 17, 2002 1:40 AM

Cutting pollution will be easy. Denver was neck and neck with LA a decade ago as the worst polluted city. Then the authorities imposed rather expensive penalties (not fees, but minimum repair expenses) on the 10% of cars that create 90% of the pollution, mostly from bad maintenance. Today Denver is a clean air city.

And there is a lot of room to be gained on diesel with new clean diesel technology just being introduced.

I would prefer to see land use regulations reformed, since most cities and suburbs mandate the most polluting and personal-car dependent form of sprawl as the only legal development option. But if pollution reduction and not free market capitalism or quality of life is the only goal then simple regulation will reduce pollution far below present levels.

Posted by: Brian on November 17, 2002 2:15 AM

Herbert Stein once said, "If something can't go on forever, it will stop." If our air threatens to become unbreathable, we will effect change. The low hanging fruit HAS been picked. California now restricts spray painting and lawnmower emissions and will do whatever is necessary to sustain life, as will DC. Of course, they do it in absolutely stupid manner. Rather than mandate zero-emissions they should tax fuel use MUCH more (and cut other taxes).

Posted by: Norman Rogers on November 17, 2002 8:22 AM

Herbert Stein once said, "If something can't go on forever, it will stop." If our air threatens to become unbreathable, we will effect change. The low hanging fruit HAS been picked. California now restricts spray painting and lawnmower emissions and will do whatever is necessary to sustain life, as will DC. Of course, they do it in absolutely stupid manner. Rather than mandate zero-emissions they should tax fuel use MUCH more (and cut other taxes).

Posted by: Norman Rogers on November 17, 2002 8:22 AM

Seems to me that this issue begs the question of telecommuting. How many more people can work from home for one or two days per week? What would be the impact of 20% to 40% less traffic on any given day in large cities? Aren't most of the jobs in large cities condusive to some amount of telecommuting? This may not be "low-hanging friut" to most mid-level and senior managers and politicians but it is probably a no-brainer for most entrepeneurs. Either find or train employees to be disciplined enough to work from home a day or two per week, assuming the type of business would allow for it. I think this solution offers many beneftis to many people.

Posted by: Richard Matthews on November 17, 2002 9:13 AM

If the low hanging enviro-fruit has ben picked, then people all around the world are looking for ways to build a ladder. I am surprised that this point would be lost on the charming and usually sensible Ms. McArdle.

Posted by: buck smith on November 17, 2002 10:10 AM

>> This runs counter to my intuition (bias?) that opportunities for substitution and technical change are increasing.

That's because engineers always go for the most expensive and least effective alternatives first....

WRT pollution, they've already reduced the amount by over 90%. It is impossible for them to accomplish more than they've already done. (Anything over 50% made it impossible.)

Posted by: Andy Freeman on November 17, 2002 1:49 PM

>> I'll go out on a limb and make a prediction: suburban population growth will decline within 10 years as people move back to the city center.

I'd take that bet, from the other side.

The suburbs are dominated by people who don't want to live in a city. The cities, on the other hand, have a significant minority who'd love to live in the burbs, or at least have the detached house and lower living costs. (Even folks who don't want the hassle usually want more space.) Both groups are important because While many folks will vote to make someone else's dream impossible, few will vote to make their own dream impossible.

The burbs are getting the population to take "underutilized" resources from cities and the factors that are pushing people out of cities will continue.

I predict that cities will stabilize at a lower population. San Francisco, for example, could be quite livable at about half its current population.

Posted by: Andy Freeman on November 17, 2002 1:58 PM

There is one lifestyle change that would cut pollustion and many people would welcome: telecommuting. It's not always possible - burger flippers and factory workers have to be physically present, but the USA doesn't have that many factory workers anymore. Maybe diplomats need to be there in person, though it's hard to tell what they do that wouldn't go as well over a videophone, and maybe faster through e-mail... But for most office workers, all it really would take would be a high-bandwidth connection to a small room and about $2,000 in computer & video equipment - less than you spend on gas and car insurance getting to your job. The hold-up, as far as I can tell, is that too many managers aren't competent to see what you are doing from the work you turn in, so they feel the need to walk around the cubicles...

Concerning SUV's, this is an area where regulations are probably making things worse. First, I strongly suspect that the reason trucks sell so well is because the regulators made cars too small. They cannot similarly regulate trucks because many people actually need to haul lots of stuff or lots of people around... E.g, I've got a pickup truck because now and then I haul a load of firewood, furniture, or building materials. Also, the high ground clearance and 4wd come in handy when it snows. But most of the time, two tons of steel is just taking me to work. (Unfortunately, my engineering job includes lots of hands-on to the equipment time; I might be able to telecommute part of the day, but I'd still wind up driving in almost every day.) I also have an old Ford Escort that I'm getting rid of. It burns less gas going to work than the truck does warming up in the driveway, and it's comfortable enough for my 11 minute commute - but it costs over $600/year more for license and insurance to split the same amount of driving between two vehicles. Somehow our legislators have managed to mandate an insurance system that assumes cars cause accidents, not drivers...

Posted by: markm on November 17, 2002 5:49 PM

Brian: Denver has improved, but in terms of absolute quality, it has a ways to go yet. Except on moderately windy days, there is ALWAYS a fairly ugly brown cloud across the entire metro area.

Norm: As with some of the other posters, you're proposing something that will have a flat-tax effect. And I don't think you understand that such a proposal will also cause significant long-term economic pain. There are better ways, like those Gene proposed. Ideally, you don't want to unfairly penalize use of the car for 'legitimate' purposes (driving over the river and through the woods to grandmother's house, for example), but still encourage the weekday work communters traveling from the suburbs to the cities to carpool, or to use alternative transportation methods where available.

Andy: Uhh...engineers always seek the most expensive solution first? My experience is that they prefer the laziest solution. Sometimes that coincides with the most expensive solution.

Posted by: anony-mouse on November 17, 2002 10:51 PM

>> Andy: Uhh...engineers always seek the most expensive solution first? My experience is that they prefer the laziest solution.

Sarcasm....

Auto engineering is driven by cost. They're occasionally wrong, but that's the metric.

To assert that that most of the cheap solutions are still out there is absurd. (There may be a couple that end up being quite cheap, but it has taken billions+years to get us to the point where we realize that they exist.)

Combine that with "most of the reductions of pollution are still available", which is arithmetically impossible given the progress so far and ....

Posted by: Andy Freeman on November 18, 2002 12:25 AM

Regarding Denver and low-hanging fruit:

The transportation-related pollutant culprits have always been and still are the local trucking companies. Trucks were not initially (and are still not, as far as I'm aware) emissions-regulated at all, yet are responsible for most of the HC and particulate emissions. I don't have any figures or cites for this because the last I read about it was at the start of pollution control in Denver in the early '90s. Comments, Denver-ites?

Also, ever looked at what comes out of the tailpipes of your school and commuter buses? Given that these are usually run by the city, these could be easily (but not cheaply) controlled.

Posted by: David Perron on November 18, 2002 10:13 AM

There is SOME low-lying fruit left. In the world of clean air, diesel regs. are (relatively) low-cost for high value. Between new fuel standards and new technology, california will be pulling a lot of pollutants out of the air over the next 20 years.

If you want a REALLY hard problem to worry about, its the state of our oceans. Modern fishing and farming (through discharges from fields) is doing tremendous damage and the only solution is a truly international one. I'm not holding my breath waiting for the current administration to do anything about it.

Odd to think that eating beef is better for the environment than eating fish.

Posted by: FDL on November 18, 2002 2:03 PM

Even if the evidence that we currently have suggests that all the low-hanging fruit is gone, I'd be deeply wary of making that claim.

About 100 years ago someone suggested that the U.S. Patent Office would soon be obsolete since everything useful had already been invented.

Posted by: a different Matt on November 18, 2002 4:06 PM

"About 100 years ago someone suggested that the U.S. Patent Office would soon be obsolete since everything useful had already been invented."

When we all know that the U.S. Patent Office is obsolete, but for profoundly different reasons.

Posted by: Paul Snively on November 18, 2002 7:10 PM

The low hanging fruit are not gone. Vehicle emissions, while they have been cut so substantially that here in Vancouver the air is better than it was 15 years ago (and gasoline sales have not increased since 1980 despite a substantial growth in the number of cars) can still be reduced significantly. It can be done by doing something about the basically unregulated trucks and buses that are a substantial source of pollution, and reducing car emissions yet further, perhaps through cleaner diesels. The wave of new cars bought with zero per cent financing and the consequent disappearance of old smoke-belchers has been the greatest environmental boon around here since residential homes stopped burning coal in the 1950s. It's getting better all the ti-i-i-ime ...

Posted by: Chris on November 18, 2002 7:16 PM

Tighter regulation of trucks and busses is still a tradeoff, because you extract more torque per unit consumed from an engine burning diesel fuel than you do from gasoline. That's why these type of vehicles use diesel engines.

How much cleaner they can be made through regulation, I have no idea. But the solution is not to convert to gasoline, because you have to burn more of it to haul the same load. Sort of a catch-22.

Posted by: anony-mouse on November 18, 2002 8:58 PM

>> It can be done by doing something about the basically unregulated trucks and buses that are a substantial source of pollution

Umm, anyone who says "basically unregulated" is either demonstrating ignorance or contempt for the truth.

Moreover, the regulations are about to get a lot tougher and, IIRC, older engines will soon thereafter become illegal.

Posted by: Andy Freeman on November 18, 2002 10:09 PM

There's a reason trucks and busses are dirtier and emit more carbon, and that's because they require more power. Especially for trucks, it's not safe to ratchet down the amount of power the engine generates, because a truck or a bus sliding backwards downhill would be a very, very bad thing. There's not only an energy-per-liter, but also a tradeoff between carbon emissions and other pollutants, between diesel and gasoline.

Posted by: Jane Galt on November 19, 2002 12:08 PM

No, Jane. No, anony-mouse. The point I am attempting (but failing, evidently) to make here is that bus and truck engines, diesel or no, are basically unregulated in the Denver metro area. These engines could run cleaner if kept in a better state of tune. Sure, there's no question that a bus or truck will emit more pollution simply because the engines are larger and more powerful and are furthermore pulling much larger loads. I don't think anyone credible is suggesting that a truck should be held to the same total emissions requirements as a car.

Ever notice how some buses emit more particulates than others? It's not necessarily because the bus in question has a lot more ponies under the hood.

Posted by: David Perron on November 19, 2002 2:30 PM

Much of the lowest hanging fruit may have been picked, but improving technology brings higher fruit within reach. Search for 'clean diesel' and you'll find lots of stuff. For instance,

" The Control of Air Pollution From New Motor Vehicles: Heavy-Duty
Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control
Requirements; Final Rule (2007 HD Rule) was promulgated on Thursday,
January 18,2001, and its emissions requirements will begin to take
effect in model year 2007.5 This program is based on the use of
high-efficiency catalytic exhaust emission control devices, particulate
filters, and other advanced technologies.The standards also require
reducing sulfur in highway diesel fuel by 97 percent (from 500 parts
per million (ppm)to 15 ppm) by mid-2006.This 15 ppm sulfur highway
diesel fuel (15 ppm fuel), coupled with advanced control technologies
on vehicles, are projected to decrease PM and NOX emissions to levels
that are 90 percent and 95 percent below 2001 levels, respectively."
Clean Diesel Independent Review Panel


"The clean, quiet and powerful diesel cars that have captured a third
of the European market are not available in the United States. The
diesel Audi A2 delivers 87 miles per gallon on the highway, but is not
sold in America.1 The divergence in the American and European markets
can be explained by a number of factors. Europeans have found that
diesel cars achieve better fuel efficiency than gasoline cars without
sacrificing performance. Fuel efficiency is an important factor for
European car-buyers because of the increased cost of fuel in Europe.
The economic advantages of driving a diesel car in Europe are
heightened by governmental tax structures that favor diesel technology.
In addition to such market-based factors, however, the divergence in
diesel penetration is due in part to the different regulatory schemes
employed in Europe and the U.S. to limit automobile emissions."
Diesel Technology Forum

There are also articles in the WSJ and Technology Review that subscribers can get to on the web.

Posted by: Bill Woods on
November 19, 2002 3:43 PM

Aaahhhh, diesel!! Not only can you make diesel burn cleanly as another poster pointed out, but you can get it from non-fossil sources. Search on bio-diesel :-) Aside from being renewable (it's made from plant oils), but because of that, you aren't pumping carbon extracted from the ground out your tail pipe, you now have a closed carbon cycle (plant pulls carbon from air and ground, car burns biodiesel, which plants pull from air and ground.....) So you're then just circulating the same amount of carbon, and if using clean diesel tech too, you've got a net drop in airborne carbon.

Posted by: David Mercer on November 19, 2002 8:08 PM

Aaahhhh, diesel!! Not only can you make diesel burn cleanly as another poster pointed out, but you can get it from non-fossil sources. Search on bio-diesel :-) Aside from being renewable (it's made from plant oils), but because of that, you aren't pumping carbon extracted from the ground out your tail pipe, you now have a closed carbon cycle (plant pulls carbon from air and ground, car burns biodiesel, which plants pull from air and ground.....) So you're then just circulating the same amount of carbon, and if using clean diesel tech too, you've got a net drop in airborne carbon.

Posted by: David Mercer on November 19, 2002 8:08 PM

Aaahhhh, diesel!! Not only can you make diesel burn cleanly as another poster pointed out, but you can get it from non-fossil sources. Search on bio-diesel :-) Aside from being renewable (it's made from plant oils), but because of that, you aren't pumping carbon extracted from the ground out your tail pipe, you now have a closed carbon cycle (plant pulls carbon from air and ground, car burns biodiesel, which plants pull from air and ground.....) So you're then just circulating the same amount of carbon, and if using clean diesel tech too, you've got a net drop in airborne carbon.

Posted by: David Mercer on November 19, 2002 8:09 PM

Aaahhhh, diesel!! Not only can you make diesel burn cleanly as another poster pointed out, but you can get it from non-fossil sources. Search on bio-diesel :-) Aside from being renewable (it's made from plant oils), but because of that, you aren't pumping carbon extracted from the ground out your tail pipe, you now have a closed carbon cycle (plant pulls carbon from air and ground, car burns biodiesel, which plants pull from air and ground.....) So you're then just circulating the same amount of carbon, and if using clean diesel tech too, you've got a net drop in airborne carbon.

Posted by: David Mercer on November 19, 2002 8:09 PM

>> The point I am attempting (but failing, evidently) to make here is that bus and truck engines, diesel or no, are basically unregulated in the Denver metro area.

That may be the attempted point, but it is FALSE and repetition won't help.

Diesel engines in buses and trucks are NOT "basically unregulated" anywhere in the USA, and, yes, that includes the Denver metro area. (see http://www.epa.gov/otaq/cert/hd-cert/stds-eng.pdf ) Moreover, the ratchet is about to click again.[1]

BTW - As Den Beste showed, bio-diesel can't come close to being a significant fuel source.


[1] And, IIRC, engines that are on the road today that don't meet the new standard will be banned a couple of years later.

Posted by: Andy Freeman on November 19, 2002 11:13 PM

Andy:

EPA regulations and periodic testing and certification are two completely different things. I'm willing to be wrong about this, but the link you cited is EPA regulations that I believe are only enforced for new vehicles. State or local testing is always optional. Here in Florida, they don't test any vehicles, ever. So the EPA regulations only apply to new vehicles.

That said, there does appear to be yearly inspection of one sort or another in Colorado. There's a lot of good information here but you have to wade through a lot of crap to get to the bottom line. The bottom line is they propose different testing standards as well as incentive programs for eliminating older, higher emissions trucks and buses from the fleet.

Posted by: David Perron on November 20, 2002 11:00 AM

>> EPA regulations and periodic testing and certification are two completely different things.

Not for the purposes of evaluating the truth of "basically unregulated".

>> I'm willing to be wrong about this, but the link you cited is EPA regulations that I believe are only enforced for new vehicles.

"Grandfather clauses" have been the case for cars, but I think that trucks are about to be treated differently. If I read correctly, some trucks on the road today will have to be re-engined within a couple of years.

>> State or local testing is always optional.

This is a usage of the word "optional" that I've never seen before. In CA, "optional" happens to be required, by both state and federal authority.

The federal reqt is triggered by certain measurements. Some of the state reqts (in CA) have more than a whiff of regional animosity.

I wouldn't be surprised to hear of waivers in the testing programs, but ....

Posted by: Andy Freeman on November 20, 2002 1:15 PM

>> I'm willing to be wrong about this, but the link you cited is EPA regulations that I believe are only enforced for new vehicles.

That link was to a regulatory history, showing how the regs have changed over time. It doesn't go into much detail for the pre 1980 regs but notes the existence of same back to the 1960s. It mentions regs for non-mobile, off-road, and marine diesels, not just trucks and buses. (I didn't see any distinction between trucks and buses, but didn't look for one either.)

Posted by: Andy Freeman on November 20, 2002 1:20 PM

>> EPA regulations and periodic testing and certification are two completely different things.

Not for the purposes of evaluating the truth of "basically unregulated".

Maybe I was unclear. By "unregulated", I meant that enforced testing of pollution standards was not being done. EPA regulations are fairly irrelevant in that context, because EPA regulations are valid everywhere but there's no post-purchase enforcement in many states.

>> State or local testing is always optional.

This is a usage of the word "optional" that I've never seen before. In CA, "optional" happens to be required, by both state and federal authority.

Again, by "optional", I meant at the discretion of the states. Unless and until the EPA mandates countrywide testing and certification of vehicles' compliance to pollution control standards, this is a true statement. I don't know by what process CARB and the EPA hooked up, but I suspect there wouldn't be any federal mandate for California if CA hadn't elected for there to be said controls.

There have been and are still exclusions for all kinds of vehicles made prior to 1982. You seem to be more cognizant of what's going on in the pollution control world, but the things I have read point to extremely recent innovation in diesel emissions control (as compared with gasoline engine emissions controls that go back to the 1970s) coupled with outdated testing methodology.

I've already admitted that I was wrong to an extent in my earlier comments. But it also looks like this can still be regarded as another category of low-hanging fruit, if I can further abuse that cliche.

Another interesting question is whether interstate trucking has to comply with Colorado pollution control laws. Denver sits squarely astride the intersection of I-70, I-76 and I-25. There's no question that it gets a great deal of interstate traffic. It'd be interesting to see what fraction of the brown cloud could be due to interstate traffic.

Denver also just happens to be sitting in an ideal place for an inversion layer to trap pollutants, which is an added detriment (is that an oxymoron?).


Posted by: David Perron on November 20, 2002 4:33 PM

>> By "unregulated", I meant that enforced testing of pollution standards was not being done.

And by "green", I mean the typical color of the daytime sky.

I finally got around to checking. CO does have mandatory emissions testing on trucks. There also seem to be county-level programs, including in the Denver Metro area. ("interstate" trucks are actually registered in every state they go through so I wouldn't be surprised if the ones that go through CO were emission-tested as well.)

Of course, even if there wasn't post-sale testing, the NATIONWIDE pre-sales testing is an "enforced testing of pollution standards".

>> Again, by "optional", I meant at the discretion of the states.

That's nice, but also false. It's not at the discretion of the states. When the EPA finds that a region/state is out of compliance, a testing program is imposed.

"basically unregulated" was wrong. Even the best defense merely compounds the error....

It may be that there are some legit beefs with CO's program or with the US' diesel regulatory system. However....

Posted by: Andy Freeman on November 20, 2002 6:55 PM

>> By "unregulated", I meant that enforced testing of pollution standards was not being done.

And by "green", I mean the typical color of the daytime sky.

And by "was", I meant past tense, which is pretty standard English (or so I thought).

Of course, even if there wasn't post-sale testing, the NATIONWIDE pre-sales testing is an "enforced testing of pollution standards".

Let's go back and read what I actually said, shall we?

Maybe I was unclear. By "unregulated", I meant that enforced testing of pollution standards was not being done. EPA regulations are fairly irrelevant in that context, because EPA regulations are valid everywhere but there's no post-purchase enforcement in many states.

I don't think I need to add anything there. But I will, because you don't seem to be absorbing this well. The EPA doesn't generally mandate emissions testing of automobiles after the sale. Until you can show that they can and do directly enforce such testing (which would be news to my 10-year-old Nissan), I stand by what I said.

>> Again, by "optional", I meant at the discretion of the states.

That's nice, but also false. It's not at the discretion of the states. When the EPA finds that a region/state is out of compliance, a testing program is imposed.

Interesting that you say that without evidence. I can guarantee you that there are tens, maybe hundreds of thousands of vehicles tooling about Florida, Alabama and various other corners of the country that are in violation of the EPA standards set for new automobiles. The EPA doesn't have any enforcement powers when it comes to emissions controls of the automobiles of individuals. They can attempt to crowbar individual states into enforcing compliance, but it's hard to imagine what damage they can really do aside from arranging the suspension of Federal funds.

BTW I can't find any substantiation to your comment to the effect that interstate trucking is "probably" emissions-controlled. Given that passing an emissions test doesn't seem to be an overt part of obtaining a Colorado permit, I'd say the level of probability is rather low.

We've come pretty far afield from the low-hanging fruit/Denver discussion. Do you now want to make a case that current testing of truck and bus engines in the Denver metro area is reasonable and appropriate; in short that there's no substantial, cheap gains to be made in that area? Or do you just want to offer a few more quibbles?


Posted by: David Perron on November 21, 2002 12:49 PM

>> By "unregulated", I meant that enforced testing of pollution standards was not being done.

And, that's still wrong. There is pre-sales testing. And, there is need-based post-sales testing. Both are enforced.

A reasonable person might well find fault with the regulatory system as it exists, but said person will not deny that a system exists.

>> The EPA doesn't generally mandate emissions testing of automobiles after the sale.

Except that it does through a need-based system, one which seems to apply to the supposed counter-example, the Denver Metro area.

>> Until you can show that they can and do directly enforce such testing (which would be news to my 10-year-old Nissan), I stand by what I said.

Take said Nissan to CA. The testing program is mandated by both EPA and the CA version. (My 15 year-old Nissan is due for yet another check next year.) Heck - said Nissan would also get the tail-pipe probe in the "basically unregulated" Denver metro area.

>> I can guarantee you that there are tens, maybe hundreds of thousands of vehicles tooling about Florida, Alabama and various other corners of the country that are in violation of the EPA standards set for new automobiles.

So what? I can find cars in CA that are in violation. (Folks murder too.) The fact that some cars are out of compliance does not imply "basically unregulated" either.

>> I can't find any substantiation to your comment to the effect that interstate trucking is "probably" emissions-controlled.

Interestingly enough, I didn't use the word "probably". I pointed out that states and the EPA had the relevant authority and mechanism and wrote "I wouldn't be surprised if" it was used by in certain areas. (I'd hope that the decision is driven by the relevant arithmetic for that area, regardless of how that calculation turns out.)

Whether or not a specific program is known to someone who is still trying to defend "basically unregulated" doesn't seem all that convincing to me.

FWIW - I'm not particularly interested in arguing a bunch of non-sequitors.

Posted by: Andy Freeman on November 21, 2002 1:20 PM

Me, either. Let me know when you've observed that I'm not speaking of pre-sales testing, and then (maybe) we can discuss what I've actually been talking about, which is testing of vehicles already on the road, and how intelligent redesign of that testing might yield some environmental benefit.

Posted by: David Perron on November 21, 2002 2:46 PM

>> Let me know when you've observed that I'm not speaking of pre-sales testing

I'm still waiting for "basically unregulated" to be retracted. Yes, it can be part of an appealing argument, but some of us think that accuracy is important.

I note that the proposed solution for the Denver Metro area (post-sales testing) has actually been LAW for several years.

That combination of errors isn't encouraging....

Posted by: Andy Freeman on November 21, 2002 8:17 PM

I actually did retract that statement. But if you need me to repeat it with more clarity:

I was wrong about that.

I thought this statement was sufficient:

That said, there does appear to be yearly inspection of one sort or another in Colorado.

Posted by: David Perron on November 23, 2002 1:46 PM

Comments are Closed.