On Monday November 15, from Noon to 1:00 pm, gas mask-clad members of Transportation Alternatives will protest the faulty clean air plan New York State will file with the U.S. Environmental Protection Agency. Activists will hand out "environmental infractions" to motorists at 42nd St. and Lexington Ave. Participants will carry signs reading "Cuomo: Clean Air Wimp" and "Jorling, Do Your Job!"

Monday is the next deadline mandated by the 1990 Federal Clean Air Act Amendments. New York must file its plan to reduce volatile organic compound (VOC) emissions by 15% over the next few years. VOC emissions produce ground-level ozone pollution, or smog. Motor vehicles are by far the greatest source of VOC emissions in the area around New York City.

Environmentalists reject the plan's treatment of motor vehicle pollution. Specifically:

• The plan blatantly double-counts emission-reductions by taking two years-worth of reduction credit for the first year of its planned "Enhanced Inspection and Maintenance Program" (for motor vehicles).
• The plan seeks to count reductions in Nitrogen Oxide (NOx) emissions toward the VOC reduction requirement, although the two types of emissions contribute to ozone pollution at different rates and don't occur in the same concentrations in many locations. The Clean Air Act does not permit this type of accounting. The state must produce a separate NOx reduction plan for a later Clean Air Act deadline.
• The plan unrealistically scales back estimates of future vehicle-miles-traveled (a measure of total driving) in the region, based on figures from the last few years. The plan thus banks on continued sluggish economic performance in the downstate region, and makes this prediction in the face of extensive highway improvements and expansion planned for New York City, Long Island and the Mid-Hudson area. The plan does not contain any measures to reduce driving and increase transit ridership in the NY metropolitan region.

"With this plan, the Cuomo Administration is trying to turn a law designed to protect public health and the environment into a hollow exercise whose only basis is computer model tricks," said Jon Orcutt, director of Transportation Alternatives. "If it wants to stay out of court and avoid federal sanctions, the state had better change its approach. The EPA would have to utterly betray its mission to approve this plan," Orcutt said.

The EPA has still not approved New York's carbon monoxide reduction plan, submitted in November, 1992.