The Ohio EPA (OEPA) has updated their website confirming that round three of the Diesel Mitigation Trust (DMT) will be released in a funding solicitation on June 1, 2020. Prior to the announcement, a coalition of interested fleets, local governments, and clean energy and air advocates, and industry stakeholders sent a letter to Governor Mike DeWine and Ohio EPA Director, Laurie Stevenson. The letter urged changes advocates said would more accurately measure emissions reductions from the program and achieve greater positive health impacts in Ohio communities.
According to advocates, the underlying issue is new diesel vehicles, such as school buses and garbage trucks, emit levels of pollution far over the federal standards. This is confirmed by research measuring “in-use” emissions – the amount of pollution emitted by vehicles when operating in the community. By comparison, compliance with federal new diesel standards is measured by laboratory, not in-use, emissions testing.
According to a white paper from the International Council on Clean Transportation (ICCT), in-use nitrogen oxide (NOx) emissions of new diesel vehicles during low speed (under 25 mph) operation average five times the federal NOx limit. Line haul trucks emit seven times more NOx than allowed at low speed urban conditions and three times as much in suburban driving. Only at high speed conditions do trucks meet the standard.
The federal NOx standard for on-road diesel is 0.2 g/bhp-hr. Actual in-use diesel truck emissions are 1.41 g/bhp-hr at urban driving conditions, 0.70 g/bhp-hr at suburban conditions and 0.2 g/bhp-hr at highway conditions. Source: Current State of NOx Emissions from In-Use Heavy-Duty Diesel Vehicles in the United States, International Council on Clean Transportation, November 2019
The Ohio EPA’s $75 million DMT program seeks to “achieve the maximum air quality benefits for the people of Ohio.” The agency uses a straightforward cost-effectiveness metric to judge funding applications – tons of NOx reduced per grant dollar requested. OEPA directs applicants to quantify emissions reduction benefits using the Diesel Emission Quantifier (DEQ), which was developed by U.S. EPA following passage of the Diesel Emission Reduction Act in 2005. The DEQ draws upon data assumptions from a larger U.S. EPA model called MOVES.
Currently, the DEQ and MOVES both rely upon laboratory results from new diesel engines and do not account for in-use data. Thus, emissions of new diesel vehicles funded under the DMT will be significantly higher than assumptions, and total program NOx reductions are less than projected.
The agency has awarded two rounds of funding thus far. Based on an analysis conducted by Clean Fuels Ohio, 83.41% of vehicles funded thus far have been new diesels and 16.59% all others, including electric, natural gas, and propane. 61.83% of funds have been awarded to diesel replacements and 38.17% for all other vehicle technologies.
In its letter, the coalition argues, “by using the DEQ, the state of Ohio is significantly over-estimating the emissions reductions and health impacts of replacing old diesels with new diesels.”
“A program that’s supposed to put clean vehicles into our communities is funding diesels that are still dirty,” said Susan Mudd from Environmental Law and Policy Center (ELPC). “These new diesels are still harming our health and Ohio isn’t getting the levels of emissions reduction and health benefits that the agency's numbers suggest.”
Fortunately, the Trustee guidance for the VW Settlement allows states to use other available tools to quantify emissions reductions from proposed projects if they are simple for applicants to use and render accurate results.
In January 2018, Argonne National Laboratory developed the Heavy-Duty Vehicle Emission Calculator (HDVEC). This tool was designed specifically for scoring in state-based VW program in response to concerns that the DEQ was significantly undercounting NOx emissions from new diesels. HDVEC was designed to perform like the DEQ and be easy for non-technical users. Most significantly, it includes factors that render results that equate much more closely to in-use emissions of diesel vehicles.
Several states, including Illinois, Minnesota, Louisiana, Colorado and Connecticut and others have been using HDVEC or a similar tool called AFLEET, rather than the DEQ in their VW diesel replacement funding programs. Other states, including Indiana, now require VW funding is spent on non-diesel replacements (electric, natural gas, and propane) with some exceptions.
According to Clean Fuels Ohio, author of the coalition letter, the Ohio EPA could address concerns raised by research and inaccuracies of current tools in three ways, individually or in combination:
1. Prioritize awards to “inherently cleaner” vehicle technologies (electric, natural gas, propane) over diesel-to-diesel replacements within fleet sectors, e.g. school buses, freight trucks and so forth. 2. Allow use of the DEQ for initial scoring but then manually adjust outputs based on the more accurate in-use data. (This result would produce outcomes and rankings similar to those utilizing the HDVEC.) 3. Switch to the HDVEC tool for applicant quantification and agency verification and scoring.
“Prioritizing inherently cleaner technologies would give all Ohioans assurance that the new vehicles funded by DMT are really clean and safe for our health,” said Sam Spofforth, Executive Director of Clean Fuels Ohio. “Also, based on years of experience working with fleets, we know that the most effective strategy of these funding programs is to drive fundamentally cleaner vehicles into the market. That’s how we can leverage greater medium to long-term health and air quality benefits for everyone.”
The coalition plans to continue to encourage Governor DeWine and Ohio EPA staff to make these changes to the program leading up to and following release of the June 1 DMT solicitation.