Comments to the Allegheny County Board of Health Concerning Proposed Regulation: ‘Diesel Powered Motor Vehicle Idling’
February 14, 2005
My name is Rachel Filippini and I’m the Executive Director for the Group Against Smog and Pollution (GASP) a non-profit, environmental, citizens’ group located in Pittsburgh working for a healthy, sustainable environment in Southwestern Pennsylvania.
Thank you for the opportunity to speak today on this important proposed regulation. Thank you also to the Allegheny County Health Department, Board of Health and Allegheny County Council for your continued work on reducing the needless idling of diesel vehicles.
While in general I believe the ‘Diesel Powered Motor Vehicle Idling’ regulation is a giant step forward from the former voluntary program, I do think there are several areas where the regulation could be made even more protective of citizens’ health.
1. Under subsection c. Exemptions, #3 Queuing: In the initial draft of this regulation queuing was not to take place within 100 feet of any restricted area, this was subsequently removed in an effort to produce a less complex regulation. I however think it is critical for that to remain in the regulation. I also think the language in #3 Queuing could be more clear by saying, “When, OTHER LESS POLLUTING CONFIGURATIONS ARE IMPRACTICAL, AND A vehicle MUST BE situated in a queue of other vehicles, must intermittently move forward to perform work or a service, and when shutting the vehicle engine off would impede the progress of the queue and be impractical. If other waiting configurations are possible such as parking and moving to a loading dock when another truck leaves, then we should not take that option off the table.
2. Under subsection c. Exemptions, #5 Cold/Hot Weather, part D: The regulation should define what the “low” temperature is in which alternate plans may be submitted and approved by the Allegheny County Health Department. Any alternate limits that are approved by the health department should be listed on the health department’s website or notices placed in the paper so that citizens are made aware of additional exceptions to the regulation.
3. Under subsection c. Exemptions, #6 Sleeping: We understand the need for a driver to be kept warm or cool when using their cab or sleeper berth to sleep, however it is essential that they don’t engage in what could be 6-8 hours of continuous idling within 100 feet of a restricted area. Again this condition was included in the initial draft but for reasons of simplification was removed. It only simplifies the situation for the driver and for the enforcement agency and not for the people living and breathing near where this extending idling may be taking place. We would like to see this limit of not idling within 100 feet of a restricted area to be placed back in the regulation, specifically in the Queuing and Sleeping Exemption sections.
4. In order to add restricted areas back into the regulation, it should be included in the definitions section. We would like to see the definition of a restricted area include the following: any real property zoned for individual or multifamily housing units that has one or more of such units on it, apartment buildings, schools, day care centers, hospitals and playgrounds. This would help to protect our most vulnerable populations from the deleterious effects of diesel exhaust. If the driver should need to idle for an extended period of time, for instance for sleeping, they should be responsible for finding the most appropriate place, furthest from harming citizens.
Thank you once again for your work on this regulation and for the opportunity to make comments.
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