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Dear Neighbor,
It is time to raise your voice! The city of Portland and Multnomah county have issued a revised draft of the “Clean Air Construction Standard” for public comment. We need you to submit your comments by 4:00 p.m. Thursday, November 15.
Click here to read the city/county draft, dated November 5 and click here for the background paper. We apologize for taking so long to come to grips with this draft and to draft our comments as “Portland Neighbors for Diesel Action.” We needed time to thoroughly review in order to draft appropriate and detailed response, which you can read here.
We think this is a good concept that could be a small but important step toward reducing the dangerous levels of diesel emissions and encouraging further steps by the Oregon legislature. Unfortunately, the legislature has been unable to pass the statewide regulations that we need to reduce emissions from pre-2007 diesel trucks. Although the basic concept is good, we think the draft needs lots of improvement. Our most important points are:
- Annual benchmarks must be set, site inspections made, and program assessments conducted and publicized.
- The seven-year timeline (Phase-In Schedule) needs to be compressed. Rather than one year to set up the program and six years to get to full Tier 4 requirements, we’d like to see the Phase-In period compressed by 50% -- one set-up year and three Phase-In years to get to Tier 4 requirements.
- Funds must be provided to reduce the impacts of this standard on certified DMWESB contractors (Disadvantaged/ Minority/Women/Emerging Small Businesses)
- The program itself needs to be adequately funded and tightly, consistently, and fairly managed.
The time is now! Please submit your comments by 4:00 p.m. Thursday, November 15.Now, more than ever it is important for our elected officials to hear from citizens like you across Portland that care about the negative health impacts of diesel pollution.
There are several ways to submit comments:
- Fill out this Google Form.
- Email your name and comment to sustain...@multco.us (We have profiled the email message with suggested response to make it easy for you to personalize and submit your comments.)
- Send mail to the Office of Sustainability, 501 SE Hawthorne Blvd., Suite 600, Portland, OR 97214
Here are our suggested responses to the four questions (summarized below) asked by the comment form for public comments. Of course, you will make up your own mind and express your own views. You do not need to answer each question. Even if you oppose this concept, please submit your comment accordingly. Both yea and nay votes show that people care and are engaged.
- Do you support the proposed contracting standard? If not what would you like to see changed?
Yes, but with major changes: tighter exemptions, shorter phase-in period, financial incentives for early adoption of a higher standard of emission reduction.
- Would you change the phase-in schedule? If so, how?
Yes, cut the phase-in period from six years to three years.
- Oregon State Certified D/M/W/ESB firms will be allowed to use lower cost Diesel Oxidation Catalysts (20 - 30% diesel particulate matter reduction efficiency) to comply with the standard for the useful life of the equipment. Would you alter this requirement? If so how?
Yes. Provide grants or loans to meet a higher stander of emission control, or raise the minimum standard that the dirtiest engines must meet during the Phase-In. Oldest engines should be retired from public construction work at the end of Phase-In, unless they meet high standards.
- Should this contracting standard also apply to publicly funded, but not contracted construction projects, such as affordable housing, even if this increases construction costs for affordable housing?
Yes. It is important to protect the public health of all of us, including those living around construction projects.
After you have submitted your comments (by or before 4:00 p.m. on November 15), please sign up here to join us for a show of support on December 13 at 8:30a.m. in front of City Hall. That’s the date the City Commissioners have set for a public hearing and vote on this program and standard.
Thank you for your support!
Beven Byrnes
Volunteer Facilitator
Portland Neighbors for Diesel Action (PNDA)
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