Kentucky Resources Council, PO Box 1070, Frankfort, KY 40602 Phone [502] 875-2428

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PO Box 1070, Frankfort, KY 40602  Phone 502.875.2428, Fax 502.875.2845

Oppose SB48  Posted: February 23, 2001

Kentucky Resources Council, Inc.

Post Office Box 1070

Frankfort, Kentucky 40602

(502) 875-2428 phone (502) 875-2845 fax

February 22, 2001


Dear Representative:

I am writing to express grave concerns regarding Senate Bill 48, which passed the Senate yesterday. The amended version of the bill still poses significant adverse consequences to the health and economy of Jefferson County residents.

While reports have described the amended SB 48 as "watered down," it is not. The bill still mandates elimination of the vehicle testing program in any county attaining air quality standards "at the earliest possible date" and mandates that the outcome of the "study" will be elimination of the vehicle testing program. The Kentucky Resources Council opposes SB 48 for these reasons:

* Eliminating vehicle testing in Jefferson County will undermine the effort to improve Jefferson County's air quality by limiting the county's options for seeking credited reductions for ozone pollution. VET testing is a required component of the county's plan for demonstrating attainment of air quality standards, and is a desired component of the required plan to maintain attainment of healthy air quality once the standard is met. Jefferson County may be redesignated within a few months, and this bill would undercut the county's ability to remain in air pollution "attainment" and transportation "conformity."

* Ending VET testing will hurt industries and could cause lost road funds.

If the VET program is eliminated immediately when Jefferson County is redesignated as "attainment," as Section 2 directs, Jefferson County will have to amend the maintenance plan and propose other reductions to replace the lost VET credits. If even possible to get the reductions elsewhere, they will have to come from additional severe reductions in emissions from industries. If the reductions cannot be made, Jefferson County will be redesignated nonattainment and suffer sanctions in the form of lost road funds.

* SB 48 is an intrusion on the right of Jefferson County to determine its own strategy for combating air pollution under Chapter 77. The state legislature should not intrude on local decisions concerning how to equitably allocate needed pollution reductions among smokestack industries, small businesses and the motoring public. Yet Section 4 of the bill demands that the study result in another method to replace the VET program rather than investigating whether it is, among options, the most cost-effective and equitable way to reduce ozone pollution.

The vehicle emissions program is a minor inconvenience that provides cost-effective credited pollution reductions. Please oppose SB 48. Thank you.

Tom FitzGerald, Director

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