Public Citizen Testimony in Support of HB 4841 — TERP Improvements
Public Citizen Testimony in Support of HB 4841 -- TERP Improvements
To: Chairman Brooks Landgraf and the Members of the House Committee on Environmental Regulatio
CC: Vice-Chair Claudia Ordaz, Rep. Rafael Anchía, Rep. Keith Bell, Rep. Ben Bumgarner, Rep. Penny Morales Shaw, Rep. Tom Oliverson, Rep. Ron Reynolds, Rep. Steve Toth
Via hand delivery and by email.
From: Adrian Shelley (ashelley@citizen.org), Public Citizen, 512-477-1155
Re: HB 4841 TERP third-party scrappage – Public Citizen testimony in support
Dear Chairman Landgraf and Members of the Committee:
On behalf of 30,000 members and supporters in Texas, Public Citizen appreciates the opportunity to testify in support of HB 4841 relating to a program administered by the Texas Commission on Environmental Quality to connect clean vehicle program applicants with certain vehicle owners to facilitate the issuance of grants or other funding for the replacement of those vehicles.
Summary of our testimony:
- We support HB 4841 because it strengthens TERP by promoting the retirement of older polluting vehicles.
- TERP is popular because it reduces pollution from mobile sources, taking the pressure off stationary industrial sources.
- Diesel engines produced before 2009 are ten times dirtier than modern diesel engines.
- HB 4841 will provide a mechanism for “third party scrappage,” allowing TERP to continue to operate in a cost-effective manner by getting old polluting trucks off the road.
Why TERP?
The Texas Emissions Reduction Plan (TERP) was created in 2001 as an incentive-based program to reduce air pollution from aging combustion-engine vehicles. TERP’s continued success is due to a number of factors:
- The need to reach attainment of federal Clean Air Act standards, particularly the ozone National Ambient Air Quality Standard (NAAQS).
- The cost-effectiveness of TERP at reducing nitrogen oxide (NOx) emissions, which are the driver of ozone pollution and our nonattainment status under the Clean Air Act.
- The incentive-based approach to reducing emissions from mobile sources (cars and trucks).
- The lessened obligation on stationary sources—industrial facilities, primarily in the oil and gas industry—to reduce their air pollution.
- The dramatic benefit to public health of reducing air pollution.
Diesel engines became dramatically cleaner in 2009.
The U.S. Environmental Protection Agency introduced in 2004 the Tier 4 emissions standards , which reduced emissions of particulate matter (which is deadly) and NOx (which contributes to ozone) by 90 percent.1 These new standards were phased in during the period 2008-2015. This means that a pre-2009 diesel engine can have ten times the air pollution emissions of a newer engine. It makes sense that HB 4841 targets these pre-2009 engines, as they offer the most opportunity for air pollution emissions reductions.
“Third-party scrappage” will help TERP do its job.
This bill creates a mechanism for “third-party scrappage” within the Texas Emissions Reduction Plan (TERP). In order to reduce air pollution from mobile sources, TERP has to ensure that older vehicles are taken out of service forever. TERP accomplishes this by requiring the replaced vehicle to actually be destroyed.2
This requirement means that some people who would otherwise take advantage of TERP will not be able to because they do not own an older vehicle to destroy. HB 4841 creates a database of owners of qualifying vehicles.
HB 4841 would make possible the following hypothetical exchange: Alice owns a model year 2015 truck and wants to replace it with a brand-new model year 2025 truck. Alice can’t qualify for a TERP grant for the new truck because she doesn’t have a pre-2009 model year truck to decommission. But Alice can use the database created by HB 4841 to locate Bob, a truck driver who owns a model year 2008 truck.
Alice trades her 2015 truck with Bob’s 2008 truck (probably some money also changes hands to make the deal fair). Now Alice applies for a TERP grant to pay for part of the cost of her new 2025 truck. Then she destroys Bob’s 2008 truck by drilling a hole through it’s engine block.
Bob now owns a 2015 truck that is 90% cleaner than his old 2008 truck. Alice used TERP for an incentive grant toward the purchase of her 2025 truck. The 2008 truck is destroyed and no longer emits as much pollution as 100 modern cars.3