Attention EPA:
The proposed regulation to clean up off-road heavy diesel equipment is a positive - and long overdue - step toward creating a sound diesel standard in this country. Stronger standards for highway trucks and buses already exist, and it's common sense that off-road equipment be held to similar standards. I strongly support EPA's proposal, though I believe it should be made even stronger.
First and foremost, all types of off-road engines, including ships and trains, which are currently exempt from the rule, need to meet the same standards. As your own estimates reveal, pollution from heavy off-road diesel equipment such as construction and farm equipment, locomotives and marine vessels is responsible for increased illness and almost 10,000 premature deaths per year due to causes such as asthma, heart disease, and cancer. Let's make sure we are tackling the whole problem, and not ignoring significant sources of diesel emissions that can only be regulated by EPA.
In addition, the polluting sulfur content in off-road fuel could be reduced more quickly, and the emissions standards could easily be enacted in 2012 rather than 2014, still a full two years after the date that highway trucks and buses must be cleaner. Any further delay only causes more hospitalizations and premature deaths due to diesel exhaust. I also have serious concerns with using a “pollution trading” scheme between old and new engines to reduce total emissions as history has shown such strategies have the potential for serious abuse.
Finally, I urge you to hold true to Administrator Whitman's commitment to reject the cost-benefit analysis that discounts the lives of seniors when analyzing the impacts of this policy or other policies being considered by the EPA.
Old or young, on land, sea, or rail, urban or rural, every American in every part of the nation should benefit from this new standard, and as soon as possible.
Sincerely,
The Undersigned