November 11, 2004

 
Clerk of the Board
Air Resources Board
P.O. Box 2815
Sacramento, CA 95812
Fax: (916) 322-3928

 
Re: SCAQMD Request for Within the Scope Waiver for Fleet Rules

 
Dear Air Resources Board:

I am writing on behalf of California Interfaith Power and Light (CIPL) and its members to urge you to submit the Fleet Rules adopted by the South Coast Air Quality Management District to U.S. EPA for a determination that the rules are "within the scope" of prior waivers that EPA has granted. Our members are very concerned about the quality of the air in the Los Angeles region and with the effect toxic and polluted air is having on their health. Members of all faiths recognize their moral and social responsibility to care for creation and bequeath a better quality of life to our children and children's children.

We need these rules to reduce pollution from diesel trucks and buses purchases by public fleets and to move technology toward cleaner fuels. Your Board has found that diesel exhaust alone causes over 70% of the cancer risk from the air we breathe. According to the SCAQMD, every year these rules reduce pollution on the South Coast Air Basin by over 1,000 tons. Alternative fuels like natural gas must play an important part in our efforts to reduce pollution in the region. Not only do the rules reduce toxic emissions in the is region with the worst air quality in the country, they also promote fuel diversity and decrease our dependence on petroleum products. While the diesel industry is now producing cleaner engines than ten years ago, they still have not caught up with natural gas and other alternative fuel engines.

California Interfaith Power and Light strongly supports submitting these rules for a waiver to help move the region toward cleaner air. Further, we believe that ARB is required to submit the rules to U.S. EPA because the rules were adopted pursuant to a law that delegated state authority to reduce pollution from public fleets to the SCAQMD, and that law specifically directed the SCAQMD to adopt this type of purchase requirement. CARB needs to submit the rules for a waiver to insure that this legislative mandate is carried out.

Finally, submittal of the rules to EPA is consistent with this agency's promotion of cleaner fuels, including the establishment of separate requirements for diesel and alternative fuel transit buses and allocation of a greater amount of funds under the low-emission school bus program to alternative fuel school buses as compared to diesel school buses.

Please act to protect our community and future generations by submitting the Fleet Rules to EPA for the grant of a within the scope waiver.

 
Sincerely,

Thomas A. Bourne
Executive Director