California Auto Enthusiasts
02-07-2002, 09:57 PM
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Burning Brakes
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California Auto Enthusiasts
URGENT REGULATORY ACTION ALERT
California Revisions to Scrappage Regulations Don’t Go Far Enough
California Air Resources Board (CARB) staff is recommending revisions to the
agency’s scrappage regulations that allow parts recovery only for
non-emission related and non-drive train parts (Option 2 in the ARB
proposal). SEMA is supporting a policy option which would allow for total
recycling and resale of all parts from vehicles destined for scrappage
(Option 3). The CARB staff’s recommendation is especially offensive because
California law specifically mandates that scrappage programs allow recycling
of all parts – a mandate the CARB flatly ignores. A full Board hearing is
scheduled for February 21, 2002 in Sacramento. We have always had the facts
and law on our side. Now, we have one last chance to let the bureaucrats
know how we feel.
We urge California automobile enthusiasts to fight for Option 3 - TOTAL
parts recycling - by attending the CARB hearing and letting your views be
heard!
DATE: February 21, 2002
TIME: 9:00 a.m.
PLACE: California Environmental Protection Agency
Air Resources Board
Coastal Valley Hearing Room, Second Floor
1001 “I” Street
Sacramento, CA 95814
POINTS TO MAKE AT THE HEARING
· California law is very specific in requiring vehicle retirement programs
to “maximize the salvage value of vehicles through recycling, sales and use
of parts…” to accommodate the interests of car collectors and low-income
citizens. Only “Option 3,” allowing the complete resale/reuse of program
vehicles and their parts, actually meets the intent of the authorizing
legislation.
· “Option 2” calls for the permanent destruction of many specific and unique
parts which can never be replaced or found on other vehicles and also
entails administrative requirements so burdensome it is unlikely any
dismantler would try to exercise it.
· The effect of “Option 2” will include higher costs, reduced availability
of specific parts and an actual increase in ambient pollution due to the
reduced maintenance of existing in-use vehicles.
· “Option 3” (recycling of all parts) helps to ensure that affordable
repairs will be available and that these repaired vehicles will emit less
for the remainder of their useful lives.
If you need additional information or if you have any questions, please
feel free to contact Steve McDonald (stevemac@sema.org) or Brian Caudill
(brianc@sema.org) at the SEMA Washington, D.C. office at 202/783-6007. Our
fax number is 202-783-6024.
WHY VEHICLE SCRAPPAGE PROGRAMS DON’T WORK
1.) Do current scrappage programs ensure a verifiable net emissions benefit?
No. Since they currently do not ensure that the replacement vehicle, if
any, is cleaner than the scrapped vehicle, no net emissions reduction is
assured. In many cases, scrapped vehicles were rarely used second or third
vehicles with annual mileage which will simply be transferred to another
vehicle (or other vehicles), with no way of knowing which vehicle was
actually the highest emitting of the group. In fact, there is no procedure
to determine what the owner does after scrapping a vehicle as the computer
model only speculates.
2.) Is there any assurance the scrapped vehicles were being driven?
No. Since there is no proof the scrapped vehicles were actually being
driven on a regular basis, there is no assurance they were contributing to
the pollution problem. This could be remedied by using historical Smog
Check odometer data and/or data from roadside audits, etc. A minimum
annualized mileage requirement (based on the date of the vehicle’s last Smog
Check) could be added as an eligibility screen so that only vehicles which
were driven more than the minimum number of miles would be accepted for
scrappage. Similarly, evidence of regular use could be provided by roadside
audit data.
3.) Is there any assurance the scrapped vehicles were high emitters?
No. The actual emission levels of individual vehicles are not evaluated.
Thus there is no verifiable way of knowing if the scrapped (or replacement)
vehicles are really emitting at the levels speculated by the CARB computer
model. This also could be remedied via the use of historical Smog Check
data and/or using the Bureau of Automotive Repair High Emitter Profile as
eligibility screens. Since these criteria are based on the emission levels
of the individual vehicle, there is a much greater assurance that vehicles
which may be scrapped are actually true high emitters which are being
regularly used.
4.) What are the emission benefits attributed to scrappage in the SIP?
Scrappage programs are allocated a certain assumed emissions benefit in the
State Implementation Plan or “SIP.” The Measure M-1 scrappage program alone
claims an unverified credit of up to 25 tons per day of emission reduction.
This compares to an allocation of 112 tons per day for the entire Smog Check
II program. The former is based on scrapping 75,000 vehicles per year while
the latter is based on testing (and successfully repairing) approximately 11
Million vehicles per year. The local Air Quality Management Districts
through their own programs may claim additional scrappage credits. Many of
these allow for the trading of emission “credits” which have been alleged to
prolong the existence of toxic emission “hot spots”.
5.) What are some of the issues associated with trading of emission credits?
The primary concern is the emission credits granted for scrappage overstate
the potential benefits generated, if any, even after being “discounted.”
This is primarily due to the use of assumptions based on “average” emissions
and mileage levels, rather than direct measurements of either. Another
significant concern is that the emissions from mobile sources (vehicles) and
stationary sources (smokestacks) differ considerably in their chemical
makeup, etc. The failure to reduce the latter causes toxic “hot spots” on
the local level which are a concern in terms of “environmental justice”
relative to citizens residing in industrial areas.
6.) Does emission credit trading reduce the number of emission “Hot Spots?”
No, in fact the opposite is true. Allowing stationary source polluters to
buy emission credits rather than forcing them to reduce their smokestack
emissions actually causes toxic emission “hot spots” to continue to be a
problem. These localized areas of excessive emission levels are not reduced
by the regional reductions in emissions (of a different type) which emission
credit trading promises. The only true reduction realized on a local level
is in the expense incurred by the stationary source polluter to be
“compliant.”
7.) Do scrappage programs affect some groups more than others?
Yes. Vehicle enthusiasts can lose a valuable source of specific rare parts
for vehicle restoration projects, etc. People on low or fixed incomes may
also lose a source of inexpensive repair parts which could result in their
inability to drive their vehicles. A reduction in emission parts
availability can also hinder state parts locator services, thus resulting in
excessive emission levels being allowed for up to one year if a vehicle is
issued an exemption or waiver rather than repaired. Hundreds of such
exemptions are granted annually. SEMA strongly opposes the mandatory
destruction of vehicles and parts via scrappage programs, and will consider
reintroducing legislation to prohibit it.
8.) Can scrappage programs cause unintended economic effects?
Yes. By introducing an unnatural incentive to scrap vehicles prematurely,
the value of such vehicles may be artificially increased. This can reduce
the number of legitimately operable vehicles which may be considered for
scrappage since they may potentially be sold for a higher price than the
scrappage payment offered. Similarly, the scrappage subsidy may no longer
be sufficient for the owner to purchase another vehicle once the prices of
the most likely replacement vehicles will also have been raised. Lastly,
the offering of a cash payment for a scrapped vehicle can be an incentive
for fraud by making inoperable or rarely driven vehicles which are not real
emission contributors worth more than otherwise would have been the case.
9.) Can current scrappage programs be improved to minimize the issues
stated?
Yes. Reforms can be introduced which would help ensure that only verified
high emitting vehicles being regularly driven may be eligible for scrappage.
Similarly, a voucher system could be used to ensure only known cleaner
replacement vehicles are purchased. Revisions must also be made to ensure
that all VAVR vehicles and their parts are made available for resale to both
enthusiasts and persons on low/fixed incomes. SEMA has recommended many
such reforms in the past. While each of these reforms has a cost associated
with it (some of which can be significant) SEMA believes these are necessary
to meet legislative intent even if they further reduce the
cost-effectiveness of VAVR programs relative to other, less controversial
options.
10.) If reformed, can current scrappage programs be relatively cost
effective?
Yes and no. Compared to electric vehicle programs and stationary source
retrofits, etc., scrappage can be a less expensive alternative. That is a
primary reason why it is supported by those who would otherwise have to
implement such measures. However, data has shown that voluntarily upgrading
older vehicles with newer technologies can be roughly twice as
cost-effective as scrapping vehicles while repairing the highest emitters
can be as high as ten times more cost-effective. These two approaches allow
vehicle owners to keep their vehicles and avoid inconvenience, etc. The
need to speculate about replacement vehicle use and emission levels is also
eliminated. The issues relative to undue harm to certain groups are
replaced with true, verified emission reductions being achieved for a known
(and lower) cost. SEMA believes a Smog Check program which effectively
ensures correct and prompt repair of high-emitting vehicles, which promotes
responsible maintenance by the vehicle owner, and which allows for
incentives and credit to be given for the voluntary upgrade of vehicles, is
a more cost-effective means of actually improving air quality without
burdening or discriminating against the public.
California Revisions to Scrappage Regulations Don’t Go Far Enough
California Air Resources Board (CARB) staff is recommending revisions to the
agency’s scrappage regulations that allow parts recovery only for
non-emission related and non-drive train parts (Option 2 in the ARB
proposal). SEMA is supporting a policy option which would allow for total
recycling and resale of all parts from vehicles destined for scrappage
(Option 3). The CARB staff’s recommendation is especially offensive because
California law specifically mandates that scrappage programs allow recycling
of all parts – a mandate the CARB flatly ignores. A full Board hearing is
scheduled for February 21, 2002 in Sacramento. We have always had the facts
and law on our side. Now, we have one last chance to let the bureaucrats
know how we feel.
We urge California automobile enthusiasts to fight for Option 3 - TOTAL
parts recycling - by attending the CARB hearing and letting your views be
heard!
DATE: February 21, 2002
TIME: 9:00 a.m.
PLACE: California Environmental Protection Agency
Air Resources Board
Coastal Valley Hearing Room, Second Floor
1001 “I” Street
Sacramento, CA 95814
POINTS TO MAKE AT THE HEARING
· California law is very specific in requiring vehicle retirement programs
to “maximize the salvage value of vehicles through recycling, sales and use
of parts…” to accommodate the interests of car collectors and low-income
citizens. Only “Option 3,” allowing the complete resale/reuse of program
vehicles and their parts, actually meets the intent of the authorizing
legislation.
· “Option 2” calls for the permanent destruction of many specific and unique
parts which can never be replaced or found on other vehicles and also
entails administrative requirements so burdensome it is unlikely any
dismantler would try to exercise it.
· The effect of “Option 2” will include higher costs, reduced availability
of specific parts and an actual increase in ambient pollution due to the
reduced maintenance of existing in-use vehicles.
· “Option 3” (recycling of all parts) helps to ensure that affordable
repairs will be available and that these repaired vehicles will emit less
for the remainder of their useful lives.
If you need additional information or if you have any questions, please
feel free to contact Steve McDonald (stevemac@sema.org) or Brian Caudill
(brianc@sema.org) at the SEMA Washington, D.C. office at 202/783-6007. Our
fax number is 202-783-6024.
WHY VEHICLE SCRAPPAGE PROGRAMS DON’T WORK
1.) Do current scrappage programs ensure a verifiable net emissions benefit?
No. Since they currently do not ensure that the replacement vehicle, if
any, is cleaner than the scrapped vehicle, no net emissions reduction is
assured. In many cases, scrapped vehicles were rarely used second or third
vehicles with annual mileage which will simply be transferred to another
vehicle (or other vehicles), with no way of knowing which vehicle was
actually the highest emitting of the group. In fact, there is no procedure
to determine what the owner does after scrapping a vehicle as the computer
model only speculates.
2.) Is there any assurance the scrapped vehicles were being driven?
No. Since there is no proof the scrapped vehicles were actually being
driven on a regular basis, there is no assurance they were contributing to
the pollution problem. This could be remedied by using historical Smog
Check odometer data and/or data from roadside audits, etc. A minimum
annualized mileage requirement (based on the date of the vehicle’s last Smog
Check) could be added as an eligibility screen so that only vehicles which
were driven more than the minimum number of miles would be accepted for
scrappage. Similarly, evidence of regular use could be provided by roadside
audit data.
3.) Is there any assurance the scrapped vehicles were high emitters?
No. The actual emission levels of individual vehicles are not evaluated.
Thus there is no verifiable way of knowing if the scrapped (or replacement)
vehicles are really emitting at the levels speculated by the CARB computer
model. This also could be remedied via the use of historical Smog Check
data and/or using the Bureau of Automotive Repair High Emitter Profile as
eligibility screens. Since these criteria are based on the emission levels
of the individual vehicle, there is a much greater assurance that vehicles
which may be scrapped are actually true high emitters which are being
regularly used.
4.) What are the emission benefits attributed to scrappage in the SIP?
Scrappage programs are allocated a certain assumed emissions benefit in the
State Implementation Plan or “SIP.” The Measure M-1 scrappage program alone
claims an unverified credit of up to 25 tons per day of emission reduction.
This compares to an allocation of 112 tons per day for the entire Smog Check
II program. The former is based on scrapping 75,000 vehicles per year while
the latter is based on testing (and successfully repairing) approximately 11
Million vehicles per year. The local Air Quality Management Districts
through their own programs may claim additional scrappage credits. Many of
these allow for the trading of emission “credits” which have been alleged to
prolong the existence of toxic emission “hot spots”.
5.) What are some of the issues associated with trading of emission credits?
The primary concern is the emission credits granted for scrappage overstate
the potential benefits generated, if any, even after being “discounted.”
This is primarily due to the use of assumptions based on “average” emissions
and mileage levels, rather than direct measurements of either. Another
significant concern is that the emissions from mobile sources (vehicles) and
stationary sources (smokestacks) differ considerably in their chemical
makeup, etc. The failure to reduce the latter causes toxic “hot spots” on
the local level which are a concern in terms of “environmental justice”
relative to citizens residing in industrial areas.
6.) Does emission credit trading reduce the number of emission “Hot Spots?”
No, in fact the opposite is true. Allowing stationary source polluters to
buy emission credits rather than forcing them to reduce their smokestack
emissions actually causes toxic emission “hot spots” to continue to be a
problem. These localized areas of excessive emission levels are not reduced
by the regional reductions in emissions (of a different type) which emission
credit trading promises. The only true reduction realized on a local level
is in the expense incurred by the stationary source polluter to be
“compliant.”
7.) Do scrappage programs affect some groups more than others?
Yes. Vehicle enthusiasts can lose a valuable source of specific rare parts
for vehicle restoration projects, etc. People on low or fixed incomes may
also lose a source of inexpensive repair parts which could result in their
inability to drive their vehicles. A reduction in emission parts
availability can also hinder state parts locator services, thus resulting in
excessive emission levels being allowed for up to one year if a vehicle is
issued an exemption or waiver rather than repaired. Hundreds of such
exemptions are granted annually. SEMA strongly opposes the mandatory
destruction of vehicles and parts via scrappage programs, and will consider
reintroducing legislation to prohibit it.
8.) Can scrappage programs cause unintended economic effects?
Yes. By introducing an unnatural incentive to scrap vehicles prematurely,
the value of such vehicles may be artificially increased. This can reduce
the number of legitimately operable vehicles which may be considered for
scrappage since they may potentially be sold for a higher price than the
scrappage payment offered. Similarly, the scrappage subsidy may no longer
be sufficient for the owner to purchase another vehicle once the prices of
the most likely replacement vehicles will also have been raised. Lastly,
the offering of a cash payment for a scrapped vehicle can be an incentive
for fraud by making inoperable or rarely driven vehicles which are not real
emission contributors worth more than otherwise would have been the case.
9.) Can current scrappage programs be improved to minimize the issues
stated?
Yes. Reforms can be introduced which would help ensure that only verified
high emitting vehicles being regularly driven may be eligible for scrappage.
Similarly, a voucher system could be used to ensure only known cleaner
replacement vehicles are purchased. Revisions must also be made to ensure
that all VAVR vehicles and their parts are made available for resale to both
enthusiasts and persons on low/fixed incomes. SEMA has recommended many
such reforms in the past. While each of these reforms has a cost associated
with it (some of which can be significant) SEMA believes these are necessary
to meet legislative intent even if they further reduce the
cost-effectiveness of VAVR programs relative to other, less controversial
options.
10.) If reformed, can current scrappage programs be relatively cost
effective?
Yes and no. Compared to electric vehicle programs and stationary source
retrofits, etc., scrappage can be a less expensive alternative. That is a
primary reason why it is supported by those who would otherwise have to
implement such measures. However, data has shown that voluntarily upgrading
older vehicles with newer technologies can be roughly twice as
cost-effective as scrapping vehicles while repairing the highest emitters
can be as high as ten times more cost-effective. These two approaches allow
vehicle owners to keep their vehicles and avoid inconvenience, etc. The
need to speculate about replacement vehicle use and emission levels is also
eliminated. The issues relative to undue harm to certain groups are
replaced with true, verified emission reductions being achieved for a known
(and lower) cost. SEMA believes a Smog Check program which effectively
ensures correct and prompt repair of high-emitting vehicles, which promotes
responsible maintenance by the vehicle owner, and which allows for
incentives and credit to be given for the voluntary upgrade of vehicles, is
a more cost-effective means of actually improving air quality without
burdening or discriminating against the public.
02-08-2002, 10:13 AM
#2
Drifting
Member Since: Feb 2001
Location: San Francisco, CA
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Re: California Auto Enthusiasts (Steve Grodin)
Thanks for taking the time to post this. Reading it I wonder what special interest lobby might be involved in pushing for this change. Auto manufacturers? Regardless, another example of fixing something that is not broken. Ridiculous.
02-08-2002, 11:15 AM
#3
Racer
Member Since: Jun 2000
Location: new mexico
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Re: California Auto Enthusiasts (R. Bruno)
If you can't fix your old one then you have to buy a shinnny New One!!
Hey some people are fortunate, they are finaly getting all the government they paid for.
There is another scrappage bill in the US Senate. Bill S.1766, problem is section 803. Go to Summit Racing home page for more details and address to your congressmen
Hey some people are fortunate, they are finaly getting all the government they paid for.
There is another scrappage bill in the US Senate. Bill S.1766, problem is section 803. Go to Summit Racing home page for more details and address to your congressmen