A few weeks ago back before the MGB-V8 debacle, I had asked for people
to provide any sort of information that they could regarding
automobile emissions testing as it may relate to british cars,
particularly in New Hampshire.
I received helpful information from a number of individuals, and found
quite a bit of information at some local libraries. Below is a letter
that I sent to Governor Stephen Merrill of New Hampshire. (Similar
letters went to many others, as well.)
Although it is long, I am providing it here to provide a sample letter
for somebody desiring to send a similar letter to their elected
officials. Even though much of the detailed information is particular
primarily to New Hampshire, much of it is relevant to any of us in the USA.
The letter also appears in my WWW pages at
"http://rassp.sanders.com/streeter/index.html";
If people need help finding the addresses of their elected officials,
let me know, and I can probably help.
--ken
Kenneth B. Streeter | EMAIL: streeter@sanders.com
Lockheed Sanders, PTP2-A001 | WWW: http://rassp.sanders.com/streeter/
65 River Road | Voice: (603) 885-9604
Hudson, NH 03051 | Fax: (603) 885-0631
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February 11, 1995
Stephen Merrill
Governor's Office
State House
Concord, NH 03301
SUBJECT: EMISSIONS TESTING RELATED TO 1990 CLEAN AIR ACT
AMENDMENTS
Dear Governor Merrill:
My name is Kenneth Streeter; I am a resident of Bedford, New
Hampshire, and a registered member of the Republican party. I
am also a member of the "New England Triumphs," an official
chapter of "The Vintage Triumph Register." I am writing to you
on a matter of great concern to myself and thousands of other
New Hampshire residents involved in the collector car hobby. My
concern is with the proposed establishment of automobile
emissions testing related to the implementation of the Clean Air
Act Amendments of 1990, particularly with respect to vehicles
made over 10 years ago.
I am sure that I need not bother you with a history lesson on
the Environmental Protection Agency's (EPA) Clean Air Act
legislation, or the implementation of the EPA's guidelines in
New Hampshire, culminating with HB 1189 in 1994. I know for a
fact, after speaking with Bert Cox of the NH Department of
Environmental Services, that you are well informed. So, I will
get right to my point. The planned implementation of the EPA's
chassis dynamometer test known as I/M 240 will destroy my hobby,
and the hobby of many of your constituents as well. I am
strongly opposed to any legislation which would reduce the
availability of collectible automobiles, or increase the costs
of maintaining such a vehicle. In specific, I am opposed to the
implementation of the I/M 240 test for all vehicles, the 2-speed
test on vehicles over 10 years old (RSA 268:5,II), and any
"scrapped motor vehicle" programs which offer incentives for
motorists to scrap older vehicles. I am in favor of legislation
such as HB 164-FN (1995), as it reduces the extent of the costly
planned emissions testing.
The federal EPA has been pushing for emissions standards on cars
made from 1967 to 1980 that those same cars would not have
passed when new. Even vehicles with all their original
pollution controls in a perfect state of tune may not be able to
pass the proposed 1995 standards. If that were not enough, the
EPA wants to raise the standards little by little during the
rest of the nineties. Experts I have talked with suggest that
all carbureted vehicles (such as Triumphs) will eventually fail.
Some people think that if these cars have "collector status"
they would be worth fixing even if they failed. Nothing could
be further from the truth! Triumphs were and remain sports cars
for the common people. They were inexpensive when new, and are
today still less expensive than modern sports cars. This is
especially true of the last three models (1974-1981), the
Spitfire, TR7, and TR8. These models may very well be nearly
wiped out by the planned tests, since they are still too new to
have obtained substantial interest from collectors, and thus
have correspondingly low market values. Their monetary value is
too low for a reasonable person to invest $450 per year in fines
on top of the normal costs involved in car ownership.
These problems are not confined to the Triumph community. All
of the other collectable car clubs and owners face this type of
hardship. Many car clubs are currently working with COVA, a
national organization of car collectors, to fight this costly
EPA program. Collectable cars are responsible for only 2% of
all miles driven every year. Dozens of small businesses
employing hundreds of workers work in this industry in New
Hampshire. Unfortunately, the 25-year antique registration (RSA
259:4) isn't the answer for many of these cars. Many are less
than 25 years old!
Car collectors are not alone in opposing the EPA testing
programs. The American Automobile Association (AAA) has
recently released a study, "Cleaning The Air," conducted by
Energy and Environmental Analysis, Inc. which conclusively shows
that automobiles and light trucks are no longer the primary, or
even secondary cause of urban smog. Curiously, "Cleaning the
Air" indicates that stationary sources of pollution, such as
manufacturing facilities and utility plants, are the primary
threat to clean air, accounting for 57% of the VOC and 63% of
the NOx emissions nationwide.
If automobiles are no longer the major offenders in the quest
for clean air, why is New Hampshire poised to begin an emissions
testing program guaranteed to cost motorists millions of dollars
and thousands of hours? In California alone, motorists have
spent an estimated $2.4 billion since 1984 on emissions tests,
using up more than 100 million hours of their time!
Air quality has also been improving because of existing
controls. According to K.H. Jones, an air pollution analyst,
"the turnover of the auto fleet alone will produce a 15% to 25%
reduction in smog levels during the next five years." (Consumers
Research, v77, May 1994, pg 10(4)) This gradual turnover of the
automobile fleet to cleaner burning, more modern cars, coupled
with the use of less volatile gasolines will continue to reduce
automobile air pollution significantly. This will continue into
the next decade, without imposing the more complex and costly
emissions inspection programs, or "scrapped motor vehicle
programs," according to Jones.
Finally, the proposed emissions testing programs have not
demonstrated their effectiveness. As University of California
at Irvine researchers found, "We have theoretical models of how
they [emissions testing programs] are supposed to work but
almost no measures of actual effects. What data we do have are
hardly reassuring." Similarly, studies conducted by Douglas
Lawson, a professor at the Desert Research Institute in Reno,
Nevada, have found that vehicles in states with emissions
inspections do not have lower pollution levels than vehicles in
states with no emissions tests.
The American people will hold accountable those in Concord and
Washington who are forcing this wasteful nightmare of automobile
emissions testing upon all car owners. Please reel in the EPA
to focus on the real threats to clean air before millions of
dollars are wasted on unnecessary testing, and thousands of
collectable cars are lost forever. Thank you.
Sincerely,
Kenneth B. Streeter
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