appendix f evaluation of mobile source ......f-3 strategy description limitations on idling of...

APPENDIX F

EVALUATION OF MOBILE SOURCE CONTROL STRATEGIES FOR THE HOUSTON-GALVESTON-BRAZORIA

STATE IMPLEMENTATION PLAN (With Detailed Strategies)

Prepared for Houston-Galveston Area Council

Prepared by ENVIRON International Corporation

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Overview of Commitments Introduction Voluntary Mobile Source Emission Reduction Programs (VMEPs) can be granted emissions credit in State Implementation Plans (SIP). As part of the SIP, the VMEP as identified and described; contains projections of emission reductions attributable to the program, along with relevant technical support documentation; commits to monitor, evaluate, and report the resulting emissions effect of the voluntary measure; and commits to remedy in a timely manner any SIP credit shortfall if the VMEP program does not achieve projected emission reductions. The VMEP was intended to be a flexible approach regarding the SIP requirements. EPA expects that the SIP commitments include a remedying for shortfalls in a voluntary measure that include adjusting the voluntary measure, adopting a new voluntary measure, or revising the VMEP emission credits to reflect actual emission reductions, provided overall SIP commitments are met. For this VMEP commitment, H-GAC interprets this to mean that the individual components of the VMEP described here can be adjusted according to the funding, technology, or projects available, but that the overall goal presented for the VMEP will be met. H-GAC presents four strategies of the VMEP and expected emission reduction from each element, but is committed to the overall emission reduction goal. EPA has established a limit of three percent (3%) of the total projected future year emissions reductions required to attain the appropriate NAAQS. TCEQ has estimated that this 3% limit represents about 2.25 tpd NOx reduction for the 2018 attainment year. H-GAC estimated that 2.25 tpd could be attained for the VMEP program with the projected funding and organizational administration commitment. H-GAC has been administering VMEP programs for many years at least since 2003 and has instituted the inter-organization, public/private partnerships, and other arrangements to implement the VMEP projects. The funding for these emission reduction projects therefore will be derived from a wide variety of sources. H-GAC administers Congestion Mitigation and Air Quality (CMAQ), provides in kind funding to administer and implement alternative commuting options, and arranges the use of Supplemental Environmental Project (SEP) funding. In addition, H-GAC works with local municipalities and private firms who either implement emission reduction measures on their own or with co-funding from the funding sources that H-GAC administers. This report consists of an overview of the VMEP commitments to include in the State Implementation Plan (SIP) submittal for the Houston-Galveston-Brazoria non-attainment area. The VMEP on- and off-road measure commitments, which H-GAC and its partners will pursue as allowed by State law are outlined in Table 1. The emission reduction commitments identified at this time are the 2.25 tons per day from on-road and off-road control measures shown in Table 1. The on-road measures include a mix of infrastructure (signal timing, intersection improvements, and others), alternative commuting options,

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and truck replacement or retrofit projects. The off-road measures include marine, construction, or other off-road equipment projects including replacement or fleet managements approaches. Table 1. Mobile Emission Reduction Commitments

Strategy

NOx Reduction Estimate

(tons per day)

Alternative Commuting 0.20

Regional Traffic Flow Improvement 0.05

Off-road Measures 0.70

Vehicle Retrofit and Replacement 1.30

TOTAL 2.25 The mobile source emission reduction control measures detailed in this report were developed using methodology in accordance with currently known State and Federal regulations. It is impossible for H-GAC to fully predict what economic or regulatory changes will occur over the decade for which these control measures are slated to be placed into action; however any deviation from the current conditions will likely result in changes to the emission reductions resulting from the strategies detailed in this report. These changes could result in the reassessment of support for strategies. It must be noted that any reassessment would not change the commitment of H-GAC and its partners to meet the emission reduction goals that have been set for the region. It would, however, indicate that flexibility is needed to determine and implement the most effective emission reduction methods under changing conditions. Some situations which may require a reassessment of SIP control measures include but are not limited to: changes to State or Federal fuel standards, changes to State or Federal engine standards, significant economic growth or contraction, or the introduction of technology updates which result in significant changes to estimated emission reductions. Weight of evidence reduction measures as shown in Table 2 may be implemented to further reduce emissions beyond the voluntary commitments described in this report. Table 2. Weight of Evidence Emission Reduction Measures

Strategy Description Continue current passenger vehicle scrappage and buy-back program

Monetary compensation for old vehicle scrappage. Increase the range of vehicles and heavy-duty truck engines targeted for replacement credit or subsidy.

Pay-As-You-Drive Insurance

Insurance costs would be associated with mileage driving by a vehicle increasing the incremental cost per mile driven. The cost of insurance then becomes an incremental cost and could be combined with mileage based registration fees and fuel tax increases to add incentive to alternative transportation.

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Strategy Description

Limitations on idling of heavy-duty vehicles

May require city ordinance. Will require additional power sources for local major events. Large truck stops have constructed alternatives to idling partially funded by TERP.

Encourage/Mandate Livable Centers

Includes a host of ideas to reduce vehicle travel. Such ideas could be incorporated into ordinances promoting multi-use development.

Enhanced enforcement for smoking vehicles

Link to I/M test status: encourage local police to enforce existing smoking vehicle legislation- vehicle impounding for violators (like Dallas Emissions Enforcement Pilot Program)

Creation of regional government idling restriction MOU

Idling is usually a small portion of the emissions from vehicles.

Limitations on idling of heavy-duty construction equipment

Idle reduction either through the use of automatic shut-off devices or operator training

This document consists of a general description of the measures that will be taken to reach the commitment for the voluntary mobile source emissions reductions program. Please refer to the Environ document for a detail description of each control measure.

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VMEP Measures Description

Alternative Commuting There are various methods for reducing emissions through alternative commuting options several of which have been detailed in ENVIRON (2009).1 Those measures showing the most promise include the following.

• Bicycle and pedestrian • Compressed work week, telework, and other employer options • Internet ride sharing • Vanpool programs • Improved low emission transit options

All of these approaches are being implemented in the HGA nonattainment area and one or more of these options will be sufficient to provide reduced vehicle travel and emissions reductions meeting the level of commitment described in this report. There are additional approaches that could be implemented to provide emission reduction through pricing measures affecting fuel, parking, congestion, and vehicle miles traveled registration or insurance fees.

Regional Traffic Flow Improvement Traffic signalization improvements, reversible lanes and intersection improvements are an ongoing part of the H-GAC plan and Transportation Implementation Plan (TIP). According to practice in evaluating CMAQ projects, as well as straightforward logic, traffic flow improvements encouraged by improved intersections or traffic signals provide benefits for 2 – 5 years (3 years was used for this analysis) before latent demand and growth in traffic cause the facility to return to about the same flow level as prior to the signal or other improvements (although better able to handle higher traffic volume). The emissions benefits from these improvements are reduced idling and start/stop activity modes.

Vehicle Retrofit and Replacement Through the Clean Cities/Clean Vehicles program, H-GAC is aggressively pursuing participation from public and private fleet owners in introducing low-emission technology into their vehicle fleets (primarily heavy-duty trucks and buses) and their fueling infrastructure. Federal funds (Congestion Mitigation and Air Quality – CMAQ) are available for eligible projects using approved technology to reduce smog-forming

1 ENVIRON (2009), “Evaluation of Mobile Source Control Strategies for the Houston-Galveston-Brazoria State Implementation Plan (With Detailed Strategies),” Final Report Prepared for Houston-Galveston Area Council, May 11, 2009.

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emissions from on-road motor vehicles. This program has been highly successful in implementing emission controls from on-road mobile sources. H-GAC's Clean Vehicles program is a fuel/technology-neutral grant program that funds cost-effective engine retrofit, repower, replacement, conversion (to alternative fuels), or the establishment of publicly accessible alternative fuel infrastructure. Overhead and administrative costs are not eligible for funding. Eligible entities include any public or private fleets that primarily operate within the 8-county ozone non-attainment area (Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller counties). Both light- and heavy-duty vehicles are eligible; however, at this time, off-road vehicles are ineligible. Eligible vehicles must spend at least 75% of their operating hours within the 8-county ozone non-attainment area, and travel more than 12,000 miles/year. As a general rule, the replacement of the heaviest, oldest, and most used diesel engines will qualify for the most funding. H-GAC has been administering a Clean Vehicles program for several years now, and has initiated and completed many projects. Over the past 6 years, nearly $60 million has been committed to replacement and retrofit projects with engines meeting lower emission standards. Off-road Measures There are several approaches to reducing emissions from off-road engines centering on replacement or retrofit with engines meeting lower emission standards and reduced activity especially idling. Table 3 shows the various approaches that could be used to target various off-road sectors. Table 3. Off-Road Emission Reduction Measures Strategy Description Voluntary non-road replacement and retrofit programs

Funding for accelerated turnover of construction equipment and other non road equipment

Government construction incentives

May include funding, tax relief, or proposal preference to firms using clean equipment

Promote cleaner lawn and garden equipment

Retirement program for old and malfunctioning lawn and garden equipment

Reduced Idling Reduced activity through practice or installed devices. Development of Clean Air Action Plans for regional port and marine operations

Could include vessel speed reductions, at berth control, and engine improvements

Rail Efficiency measures Grade separation, track straightening, voluntary fleet turnover measures may be implemented.

Voluntary retrofit and replacement programs have been used across the US to reduce emissions using a variety of programs providing cofunding incentive to offset the costs incurred. One of the most important methods for emission reduction projects is to replace

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older vehicles and equipment with those meeting the lower emission standards. The retrofit projects often use technologies employed on new engines to meet the lower emission standards.

773 San Marin Drive, Suite 2115, Novato, CA 94998 415.899.0700

ENVIRON International Corporation

Final Report

EVALUATION OF MOBILE SOURCE CONTROL STRATEGIES FOR THE

HOUSTON-GALVESTON-BRAZORIA STATE IMPLEMENTATION PLAN

(With Detailed Strategies)

Prepared for

Houston-Galveston Area Council 3555 Timmons Lane, Suite 120

Houston, TX 77027

Prepared by

ENVIRON International Corporation 773 San Marin Drive

Suite 2115 Novato, CA. 94998

May 11, 2009

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TABLE OF CONTENTS

Page 1. BACKGROUND AND PURPOSE OF STUDY................................................................ 1-1

Background............................................................................................................................ 1-1 Purpose of Study .................................................................................................................... 1-2 Overview of Commitments.................................................................................................... 1-2 Organization of Report .......................................................................................................... 1-4

2. CONTROL MEASURE IDENTIFICATION .................................................................. 2-1

Refining Initial Master List.................................................................................................... 2-1 Evaluating Feasibility and Potential for Emission Reductions.............................................. 2-1

3. METHODOLOGY FOR ANALYSIS OF MOBILE CONTROL MEASURES ........... 3-1 Qualitative Review of Master List......................................................................................... 3-1 Qualitative Review of Emission Control Potential................................................................ 3-1 Qualitative Review of Feasibility .......................................................................................... 3-2

4. SUMMARY OF ALL MOBILE MEASURES CONSIDERED ...................................... 4-1 5. DETAILED EVALUATION OF QUALIFYING MOBILE MEASURES .................... 5-1 6. LOCAL SUPPORT OF FOR IMPLEMENTATION OF MOBILE MEASURES ....... 6-1

TABLES

Table 1-1. On-Road Emission Reduction Commitments...................................................... 1-3 Table 1-2. Non-Road Emission Reduction Measures ........................................................... 1-3 Table 1-3. Weight of Evidence Emission Reduction Measures............................................ 1-3 Table 4-1. On-road vehicle emission reduction measures .................................................... 4-2 Table 4-2. Non-road vehicle emission reduction measures ................................................ 4-22 Table 5-1. On-road measures detailed evaluations summary................................................ 5-1 Table 5-2. Non-road measures detailed evaluations summary.............................................. 5-4 Table 5-3 Weight of evidence measures summary .............................................................. 5-5

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APPENDICES Appendix A: Summaries of the Houston-Galveston Area Council of Governments Meetings with

the Texas Commission on Environmental Quality and Various Stakeholders concerning the Houston-Galveston-Brazoria Eight-Hour Ozone State Implementation Plan Master List Control Measures

Appendix B: Written Comments from Stakeholders and their Respective Responses Regarding

Master List Control Strategies Appendix C: Summaries of the Houston-Galveston Area Council of Governments Meetings with

the Texas Commission on Environmental Quality and Various Stakeholders concerning the Houston-Galveston-Brazoria Eight-Hour Ozone State Implementation Plan Short List Control Measures

Appendix D: Written Comments from Stakeholders and their Respective Responses Regarding

Short List Control Strategies Appendix E: Overview of the Transportation Control Measures to Be Included as Part of the

Houston-Galveston-Brazoria Eight-Hour Ozone State Implementation Plan Submittal

Appendix F: Detailed Evaluations for On-Road Control Strategies Appendix G: Detailed Evaluations for Non-Road Control Strategies Appendix H: Detail Evaluations for Weight of Evidence Control Strategies

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1. BACKGROUND AND PURPOSE OF STUDY This report documents a study performed by ENVIRON International Corporation on behalf of the Houston-Galveston Area Council (H-GAC). The study was conducted in support of development of an ozone attainment plan. ENVIRON International Corporation, in collaboration with subcontractors Earth Matters and Hazel Barbour, provided assistance in identifying, evaluating, and documenting mobile emission control measures in an attempt to determine a set of strategies to achieve emission reductions of volatile organic compounds and nitrogen oxides in the Houston-Galveston-Brazoria (HGB) nonattainment area. This initial work involved preparing and qualitatively evaluating a master list of mobile control strategies. H-GAC and its stakeholders began with the initial mobile master list from public comment and involvement culminating in 2006. The master list was winnowed to those deemed of most interest to H-GAC, its stakeholders, and additional measures were suggested. A summary of the stakeholder meetings is provided in Appendix A of this report along with a summary of written comments and responses supplied by the stakeholders, provided in Appendix B. ENVIRON and its subcontractors then reviewed the remaining master list strategies to estimate their applicability and potential for inclusion in a regional State Implementation Plan (SIP). Once this analysis was completed and a draft short list of quantified mobile control measures was assembled, further meetings were held to gauge additional stakeholder perspectives. A summary of this second round of stakeholder meetings is provided in Appendix C along with a summary of written comments received during this time and responses supplied by the stakeholders, provided in Appendix D. Background The study was initiated by a request and support from the Texas Commission on Environmental Quality (TCEQ) to H-GAC for assistance in developing approvable mobile control strategies for the Houston-Galveston-Brazoria area toward attaining the ozone standard by the year 2018. The study was initiated to assist TCEQ in the development of the State Implementation Plan (SIP), a document used to demonstrate attainment for the federal 1997 ozone standard. The federal standard is now based on an 8-hour averaging of the fourth annual maximum during a three year period. TCEQ requested that an evaluation of control strategies be conducted in order to understand the potential benefit of those strategies and if they could be implemented as rules or voluntary initiatives. The Houston-Galveston-Brazoria ozone nonattainment area includes the following counties, Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller. The mobile emission reduction measures detailed in this report were developed using current methodology in accordance with currently known State and Federal regulations. It is impossible for H-GAC to fully predict what economic or regulatory changes will occur over the next decade. Any deviation from the current situation will likely result in changes to the emission reductions for the mobile control measures detailed in this report and could result in the reassessment of support for those strategies based on these changes. It must be noted that this reassessment would not change the commitment to meet the emission reduction goals of the region. It would, however, reflect that flexibility is needed to determine and implement the most effective emission reduction methods under changing conditions.

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Anticipated situations which may require a reassessment of SIP control measures include but are not limited to: 1) Changes to State or Federal fuel standards, 2) Changes to State or Federal engine standards, 3) Significant economic growth or contraction, 4) Evaluation technology updates which result in significant changes to estimated emission

reductions. Purpose of Study This study is a part of an overall process to develop the revised Ozone SIP for the year 2018. The primary objective of the study was to identify and evaluate feasible mobile control measures to reduce NOx emissions. A secondary objective was to assist H-GAC in ensuring that area stakeholders were involved in the process of identifying the mobile measures and in commenting on their feasibility. These efforts were intended to “feed in” to the general SIP process, which will include emission inventory development and photochemical modeling by the TCEQ; ongoing and new processes initiated by H-GAC to identify potential new mobile control measures; and H-GAC efforts to, solicit stakeholder input into these potential measures, and maintain regional planners and government officials in the process. Key tasks of this ENVIRON study included: 1) Reviewing existing mobile emission inventory and previously evaluated mobile control

measures, 2) Assisting H-GAC in identifying potential new mobile measures, 3) Performing a qualitative analysis of the primary pollutants and applicability of the proposed

control strategies, 4) Quantifying the effects of measures (emissions, costs, feasibility), 5) Coordinating with H-GAC on the measured analyses for placement into the emission

projections, 6) Documenting control measure effects and presenting findings to technical, policy and

steering committees, 7) Developing control strategies and submitting documentation to H-GAC. Although H-GAC is the regional transportation planning agency, the study was not limited to transportation sources. Instead, the purpose was to explore all possible on-road and non-road mobile source measures, including sources such as lawnmowers or construction equipment. Overview of Commitments The bulk of this report consists of an overview of processes that H-GAC and ENVIRON used to determine mobile source emission reduction control measures to include in the State Implementation Plan (SIP) submittal for the Houston-Galveston-Brazoria non-attainment area. One result of this evaluation is a list of on- and non-road measure commitments, which H-GAC and its partners will pursue as allowed by State law. The emission reduction commitments identified at this time are the 2.5 tons per day from on-road control measures shown in Table 1-1,

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a commitment to pursue agreements on certain non-road shown in Table 1-2, and weight of evidence control measures shown in Table 1-3. Table 1-1. On-Road Emission Reduction Commitments.

Strategy

NOx Reduction Estimate

(tons per day)

Alternative Commuting 0.5

Regional Traffic Flow Improvement 0.5

Vehicle Retrofit and Replacement 1.5

TOTAL 2.5 Table 1-2. Non-Road Emission Reduction Measures. Strategy Description Voluntary non-road replacement and retrofit programs

Funding for accelerated turnover of construction equipment and other non road equipment

Government construction incentives May include funding, tax relief, or proposal preference to firms using clean equipment

Promote cleaner lawn and garden equipment

Retirement program for old and malfunctioning lawn and garden equipment

Development of Clean Air Action Plans for regional port and marine operations

Could Include Vessel Speed Reductions, At Berth Control, and engine improvements

Table 1-3. Weight of Evidence Emission Reduction Measures.

Strategy Description Continue current passenger vehicle scrappage and buy-back program


Pay-As-You-Drive Insurance












The mobile source emission reduction control measures detailed in this report were developed using methodology in accordance with currently known State and Federal regulations. It is

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impossible for H-GAC to fully predict what economic or regulatory changes will occur over the decade for which these control measures are slated to be placed into action; however any deviation from the current conditions will likely result in changes to the emission reductions resulting from the strategies detailed in this report. These changes could result in the reassessment of support for strategies. It must be noted that any reassessment would not change the commitment of H-GAC and its partners to meet the emission reduction goals that have been set for the region. It would, however, indicate that flexibility is needed to determine and implement the most effective emission reduction methods under changing conditions. Some situations which may require a reassessment of SIP control measures include but are not limited to: changes to State or Federal fuel standards, changes to State or Federal engine standards, significant economic growth or contraction, or the introduction of technology updates which result in significant changes to estimated emission reductions. Organization of Report The remainder of this report is organized as follows: Section 2, Mobile Control Measure Identification, documents the process used to select individual control measures for analysis. Section 3, Methodology for Analysis of Mobile Control Measures, briefly describes the data sources, assumptions and techniques used in the analysis. Section 4, Summary of All Mobile Measures Considered, presents an overview of the qualitative evaluation of all suggested measures displayed in tabular format. Section 5, Detailed Evaluation of Qualifying Mobile Measures includes summary results of quantitative evaluations of voluntary strategies for on-road and non-road mobile sources. Section 6, Local Support for Implementation of Mobile Measures details the steps taken to gain support for the quantitatively analyzed voluntary strategies. Appendix A, presents summaries of stakeholder meetings used to gather input and comments on the control strategy selection process for the Master List of Mobile Control Measures. Appendix B, presents stakeholder written comments and their respective responses provided by H-GAC for the Master List of Mobile Control Measures. Appendix C, presents summaries of stakeholder meetings used to gather input and comments on the control strategy selection process for the final Short List of Mobile Control Measures. Appendix D, presents stakeholder written comments and their respective responses provided by H-GAC for the final Short List of Mobile Control Measures. Appendix E, presents an overview of the Transportation Control Measures. Appendix F, presents the quantitative evaluation of each on-road control strategy.

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Appendix G, presents the quantitative evaluation of each non-road control strategy. Appendix H, presents the quantitative evaluation of each weight of evidence control strategy.

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2. CONTROL MEASURE IDENTIFICATION ENVIRON, in collaboration with H-GAC, used the master mobile source control measure list developed in 2006 as a starting point from which to identify measures for the HGB nonattainment area Ozone SIP strategies development. H-GAC solicited additional measures for the HGB area from local stakeholders including the Regional Air Quality Planning Committee (RAQPC) to ensure that all potential emission control measures could be identified. Refining Initial Master List Several hundred potential on-road mobile source measures and just fewer than one hundred non-road mobile source measures were suggested in the 2006 master list. Because the process was all encompassing, many measures were suggested more than once, although in different ways. In addition, many measures that would alone have minimal effect on emissions were easily recognized as being naturally a part of larger measures and others were not well described. Due to these issues, and with the help of stakeholder’s comments, we refined and cleaned up the master list to create the “final master list”. The final master list is a collection of measures that represented a refined version of all ideas proffered to date to be considered for more detailed evaluation. The general categories included such diverse groupings as the clean vehicle programs, pricing measures for on-road mobile sources, incentive programs, public fleet measures, in addition to locomotive and marine measures for non-road mobile sources. The complete master list of mobile measures is outlined in Section 4. Evaluating Feasibility and Potential for Emission Reductions The primary goal of the master list evaluation was to identify the potential emissions reduction of the control measures. As noted, the initial evaluation was qualitative, as it was not feasible to model each of the individual control measures. The qualitative review outlined those measures that met the minimum criteria for inclusion in the SIP along with information about the affected pollutants and implementation considerations related to each measure. The final master list, provided here, was then used to determine which measures would be included in a more detailed quantitative analysis.

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3. METHODOLOGY FOR ANALYSIS OF MOBILE CONTROL MEASURES

For the initial evaluation of the master list of mobile control measures, a qualitative approach was used to examine the measures. This section briefly summarizes the approaches and assumptions used in this analysis. Qualitative Review of Master List The primary qualifier for the SIP control measure used in this study was based upon the EPA criteria that the SIP control measures need to meet four criteria outlined for mobile source measures by EPA guidance documents (found online at http://www.epa.gov/otaq/stateresources/transconf/policy.htm). They must be: 1) permanent, 2) quantifiable, 3) surplus, and 4) enforceable (PSQE). A permanent measure is one that cannot be rescinded and will continue through the time period that the emission reduction is applicable so in effect this would include replacement or retrofitted equipment through the useful life of the mobile source affected, but may not include measures that the operator could disable or avoid using at any given time. In a quantifiable measure it must be possible to measure and estimate the quantity of emissions reduced as a result of this measure. A surplus measure must reduce emissions beyond that which are covered under any existing emission reduction programs or measures. Finally, an enforceable measure must be part of a program that meets Federal guidance and could be administered by EPA staff. Practically though enforceability means that the strategy must follow EPA criteria and include penalties for violations where appropriate. Following logically from the enforceability requirement, EPA also requires that the measures be adequately supported by funding sources and personnel dedicated to administering the program, for example, the TERP or Clean Cities programs have state or federal funding administered by TCEQ and H-GAC staff respectively who follow EPA guidance, maintaining proper oversight and documentation. The definitions of these criteria and the administrative oversight may not be obvious from the short description of each measure; however the ENVIRON team made a judgment as to whether a program could be defined to satisfy these criteria prior to analysis. EPA allows for a limited portion of the emission reductions in the SIP to be voluntary commitments that may not strictly meet all of the criteria listed above. However, for voluntary measures, the administrating agency must demonstrate real emission reductions by showing funding, oversight, and verification of progress toward the emission reduction goal. For instance, the H-GAC Clean Cities and Clean Vehicles Program can demonstrate funding for clean heavy-duty vehicles and verification of disposal of the replaced vehicles even though the measure may not be considered strictly as enforceable. Therefore voluntary programs may be considered for inclusion in a SIP if defined and funded properly. Qualitative Review of Emission Control Potential The qualitative review of the emission control potential for each measure relies on the basic understanding of the emission inventory. Control strategies for mobile sources rely on the basic understanding that diesel engines are a significant source of NOx emissions but produce a small fraction of the VOC emissions, and that gasoline vehicles and engines are primarily responsible for VOC emissions while on-road gasoline vehicles also contribute to the NOx emission inventory. Therefore, programs to reduce diesel engine and vehicle emissions primarily affect

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NOx emissions, non-road gasoline engines affect VOC emissions, and on-road gasoline vehicles affect both VOC and NOx emissions. Qualitative Review of Feasibility The feasibility of each measure was not ranked, but a description of the implementation considerations is provided for each master list measure.

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4. SUMMARY OF ALL MOBILE MEASURES CONSIDERED This section contains the Master List of Measures, which summarizes the qualitative results for all measures initially analyzed. Table 4-1 lists each on-road measure that was reviewed, and Table 4-2 lists each off-road measure analyzed. The measures are described qualitatively but not ranked in terms of potential benefit or cost effectiveness because inventories have not been finalized and often the program’s implementation has not be adequately defined. However, with stakeholder input, a list of measures deserving detailed evaluation could be selected from this list. The measures were not ranked by emission reduction potential for a number of reasons. The emission reduction potential depends on the level of implementation in most cases or the measure needs of greater detail in order to evaluate the potential. For non-road mobile sources, a 2018 forecasted emission inventory is not available at this time to provide a relative assessment to compare between non-road source emission categories or to compare with those measures for on-road sources. Lastly, there has yet to be an emission reduction target to meet attainment for the HGB area. Rather than dismiss a measure because it might seem unimportant based on emissions reductions expected, all viable measures were included in the master list. Even small reductions might be important if implementation is more aggressive than conceived, the source category is of larger importance than expected, or if the attainment goal does not require large reductions. Another consideration could be that the measure might result in small reductions but be very cost effective or easy to implement. Our initial list therefore marks those measures that qualify as emission reduction programs under a likely EPA (PSQE) review with "+" to denote which pollutant would be affected by the measure. Each measure is described in terms of what would be implemented and a further comment field discusses the implementation considerations and other unobvious factors affecting the measure.

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Table 4-1. On-road vehicle emission reduction measures.

ID Old ID Control Strategy Description Category

Year Added

EPA PQSE VOC NOx Comment

1 17 Bicycle and pedestrian action groups

Benefits from bicycle measures include new bicycle lanes as well as encouraging greater use of existing lanes instead of vehicle use. But it can be difficult to determine the benefits of such programs.

Bicycle and Pedestrian

2006 Y + + Reporting requirements could be difficult to meet to claim emission reduction benefits. For comparison, determine the emission reduction potential of 20% of employees with commutes of 5 miles or less bicycle to and from work two times per week.

2 51 Clean Cities Technical Coalition

An example program might be the NCTCOG program where entities participate in programs to purchase clean vehicles (light or heavy-duty) for their fleets.

Clean Vehicle Programs

2006 N The strategy, incentives, and benefits have yet to be defined.

3 54 Private sector clean fuel fleets

This measure is patterned after the H-GAC Clean Cities Program where clean engines (whether alternatively fueled or no) are purchased for fleets to reduce emissions.


2006 Y + CMAQ funding for clean vehicles has been a successful program for generating emission reductions. Similar to measure 22.

4 56 Close loopholes in the Texas Clean Fleet Program making fewer exemptions for fleets

The Texas Clean Fleet Program was repealed by TCEQ, and because the Tier 2 light-duty and 2007 heavy-duty vehicle emissions standards have superceded the original proposal.


2006 N A revision and implementation of such a program needs to be described in more detail to evaluate the benefits.

5 58 Fleet review, procurement and operations policies

ENVIRON expects that this could be a voluntary version of a Clean Fleet Program where purchases would be directed to cleaner engines.


2006 Y + See Measure 3

6 59 Public agency clean fleet program

Commitment by public agencies to purchase cleanest possible fleet vehicles could be an element in funding or a voluntary commitment.


2006 Y + See Measure 3

7 71 Electric Vehicles This measure is considered to include each of various options for the purchase and use of electric (zero emission) light-duty vehicles.


2006 Y + + This measure would affect light-duty vehicles only.

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Year Added


8 99 Area-wide "Steer It/Clear It" program

This program considers quick removal of vehicles from roadway in event of a stall or non-serious accident. The benefits of the program include better traffic flow reducing slow speed operations.

Freeway Incident / Roadway

Construction Management

2006 N The benefits of the program include better traffic flow reducing slow speed operations, but the measure may not be considered permanent. In addition the extent to which incident-related slow speed events are included in the emission inventory is unclear.

9 100 Additional freeway service patrol

Operation of additional lane miles of new roving tow truck patrols to clear incidents and reduce delay on freeways during peak periods. Reduces traffic congestion improving average vehicle speeds.



2006 N See measure 8

10 101 SAFEClear - Mandatory quick removal of disabled vehicles during peak periods

Similar to Measures 8 and 9. Freeway Incident / Roadway



11 115 Cleaner diesel fuel There are diesel fuels that have improved performance even beyond the TxLED. This could include cetane additives or gas-to-liquids diesel fuels.

Fuel Standards

2006 Y + EPA evaluation of fuel benefits. http://www.epa.gov/otaq/fuelsmodel.htm

12 127 Air quality information with driver training

Include information on vehicle emissions and air pollution with new-driver and defensive-driving education.

General Public Education and

Outreach

2006 N It would be difficult to demonstrate emission reduction benefits for this measure.

13 144 Divert trucks from nonattainment areas

Require through-traffic trucks to travel around rather than through nonattainment areas.

Goods Movement

2006 N While this measure would have large potential benefits, it would be difficult to implement and demonstrate emissions reductions.

14 146 Peak period truck bans on freeways and major arterials

Ban on heavy duty trucks entering or exiting freeways during peak periods.

Goods Movement

2006 N This measure would be infeasible to propose or implement. Note that the total truck travel would through the region not change by much if any, and what did would cause emission increases elsewhere. The day to day and hour to hour benefits for emissions would make it difficult to claim credit.

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Year Added


15 147 Permit HOV lane use by qualifying low emission vehicles (LEV)

Vehicles marked as low emitting would be allowed to use HOV lanes as an incentive for greater use.

High Occupancy

Vehicle (HOV) Lanes/Manag

ed Lanes

2006 N Check HOV lane use - if too full already this measure cannot help. Also it would be difficult to define and mark vehicles that qualify. It is unclear that the incentive would be sufficient to achieve greater use of low emitting vehicles.

16 150 Increase occupancy to three or more per vehicle

Based on a review of the effectiveness of this measure in other parts of Houston (see comment column) the measure could be extended to other freeways.

High Occupancy


ed Lanes

2006 N This is a measure already being implemented in some parts of Houston on Katy and NW freeways where HOV and toll incentives are used. If implemented on additional freeways, the freeways would need to be identified and discussed with H-GAC and TDOT and the daily single occupant and 2-car occupant volumes determined.

17 157 Single Occupant Vehicles (SOV) access to HOV and transit stations

Provide direct freeway access to adjoining HOV or transit park-and-ride facilities to encourage use and expedite access.

High Occupancy


ed Lanes

2006 N See measure 15. Also incremental nature of benefit such that it should be thought of as a qualitative supplement to HOV and transit modes.

18 161 Managed lanes to accommodate some single occupant vehicles in HOV lanes

In highly congested corridors where speeds are below 20 miles per hour on freeway lanes, permit limited use of HOV lanes by SOV using tolls or other limiting technique.

High Occupancy


ed Lanes

2006 N See measure 15.

19 163 Focus on finding and penalizing extreme high emitters

(a) Improved remote sensing program, or (b) enhanced enforcement of the I/M program could reduce numbers of likely high emitting vehicles escaping testing through purchase of fraudulent stickers or avoiding the program completely. Penalize fraud not high emitters

High-Emitting Vehicle

Detection and Programs

2006 N Questionable regarding excess modeled reductions (I/M modeled at 96% compliance) but could produce real reductions.

May 2009



Year Added


20 165 Rewards for reporting smoking or high emitting vehicles

Rewards could be dollars or discounted I/M tests and/or repairs for those reporting smoking vehicles.




21 172 Scrappage/buy-back plan




2006 Y + + Increased LIRAP funding (total $45 million this biennium) has hugely increased replacement/scrappage. LDGV's over 10 years now eligible for replacement (don't have to have failed the I/M test). TERP also requires scrappage of replaced vehicles/engines. 2010 bus 99% cleaner than 1998 bus for NOx.

22 181 Dedicated funding for school bus replacement

Clean Cities Clean Vehicle or TERP or EPA funding sources. This program specifically targets school bus fleets that trend toward older models.



2006 Y + Currently using Supplement Environmental Program (SEP) funds federal and state.

23 186 Non-profit organization assistance program

Investigate opportunities to partner with non-profit organizations to ensure high-emitting donation vehicles are not returned to the road and reused in an "as is" condition.



2006 N Will reduce value of donation to the non-profit.

24 188 Enforce smoking vehicle reports and require repairs

Link reports to vehicles' current I/M test status. Require vehicle to be retested.



2006 N May enhance I/M compliance. Repairing to reduce smoke may not mean vehicle will pass I/M test. Currently no requirement to I/M test diesels.

25 191 Low-interest financing for low income and/or old vehicle trade-ins

Financing made available to vehicle owners not eligible for LIRAP replacement option




26 193 Ban sale of high-emitting vehicles

Vehicles sold within I/M counties must have valid passing VIR



2006 N Provides additional I/M enforcement strategy

May 2009



Year Added


27 194 Ban high-emitting vehicles in CBD

Vehicles not allowed through check point if fail remote sensing scan, or if do not have a valid inspection sticker



2006 N Difficult to implement plus once the program is known about, vehicles may avoid CBD but be driven around in the wider HG area anyway. Additional RS expensive.

28 195 Deny registration to vehicles with repeated emission failures

This measure would require a legislative change.



2006 N Registration already denied if vehicle fails and doesn't subsequently pass I/M test. If not in LIRAP, could require repairs be done at Recognized Emissions Repair Facility.

29 201 Communicate by radio best routes through area to avoid congestion

Improvements of traffic flow would affect average speeds on roadways if there are alternate routes..

Intelligent Transportation Systems (ITS)

2006 N The benefits would be day to day and hour to hour making it difficult to claim emission credit. Alternate routes often increase VMT and associated emissions.

30 202 Information telephone hotline for traffic conditions

Improvements of traffic flow would affect average speeds on roadways.



31 207 Provide transportation conditions internet site

Provide hotlink to local transportation conditions website or provide internal web page with transit, traffic, other conditions, schedules and directions to encourage use of modes other than driving alone.



32 208 Encourage bicycle use by using ITS to increase safety in strategic bicycle/automobile conflict areas

Duplicate or supplemental measure.


2006 Y + + See measure 1.

33 209 Dynamic message signs for control of truck movements

Emissions benefits of truck movements are unclear.



34 210 Dynamic message signs for freeway traffic control

Emissions benefits of freeway movements are unclear. Houston area has numerous dynamic message signs in any case.



35 211 Real-time display of estimated time of arrivals at bus stops

Provide changeable message signing at bus stops noting ETA of the next buses arriving at the stop.


2006 N See measure 29. Measure could have unquantifiable but positive incremental effects on transit measures.

May 2009



Year Added


36 212 Increase system surveillance

The effect of this measure on traffic movements is not well defined.



37 214 Limit left turns on selected thoroughfares during ozone season

This measure may show capacity improvements on selected roads allowing for better average speeds.

Ozone Action Day / Ozone

Season

2006 N May increase average vehicle speeds for arterials The emissions evaluation would require developing a database of all left turns to be banned, and the additional miles traveled as a result, as well as changes in travel speeds due to increasing the volumes. Cost of installing the signs could be high.

38 218 Delay high emissions producing activities on ozone action days; delay activities for non-ozone action days

The program is ill defined, and any benefits experience in the nonattainment area may be offset by degradation downwind.

Ozone Action Day / Ozone

Season

2006 N Involved ozone modeling would be necessary to demonstrate any benefits to the proposed strategy.

39 227 Preferential parking for High Occupancy Vehicle (HOV) lane users and ride sharers; Free spaces, reserved spaces

Incentive for ride sharing and reduced commuting alternative. Alternative commuting options include incentives, penalties, and other encouragements for alternatives to single occupancy vehicle commuting. This measure is for preferential parking incentives and would be one part of the overall program.

Parking Management

2006 Y + + This measure should be evaluated as part of a Commute Solutions Program (ridesharing). If the measure is implemented consider adding it to the suite of programs for enhancing ridesharing incentives and opportunities.

40 228 Preferential parking for High Occupancy Vehicle (HOV) lane users and ride sharers; Rate reduction

Duplicate measure. Parking Management


41 229 Preferential parking for High Occupancy Vehicle (HOV) lane users and ride sharers; Metered spaces



May 2009



Year Added


42 231 Free parking at park-and-ride facilities for High Occupancy Vehicle (HOV) lane and transit users

Provide free parking at facilities served by transit; include costs elsewhere or subsidize. Include in weekly or monthly passes.

Parking Management

2006 N Insignificant emission reduction effects, overlap with ridesharing program, possible overflow at park and ride lots and unsure of current cost structure at these lots.

43 235 Increase parking at transit centers or stops

An incentive to use transit instead of personal vehicles, but not emission reduction measure itself.

Parking Management

2006 N Should provide at least a qualitative discussion due to overflow issues at current transit centers

44 236 Use direct ramps to connect park-and-ride lots with freeway system


Parking Management

2006 N Capital intensive and low emission reductions could be demonstrated.

45 237 Locate fringe parking and park-and-ride lots on approach routes and interchanges to central and other major business districts.


Parking Management

2006 N Capital intensive and low emission reductions could be demonstrated.

46 240 Provide parking at all major transit stations


Parking Management

2006 N Need to examine feasibility

47 241 Commuter parking pricing

No free parking. Price increase would be applied to employees adjusted for vehicle occupancy so that carpoolers would not be subject to increased parking prices.

Parking Management

2006 Y + + Utilize an analysis approach whereby the current price elasticity is applied to a 25% to a 50% increase in parking prices in applicable parking centers. See measure 39 that uses an incentive rather than a penalty.

48 243 Parking space tax or surcharge

Duplicate measure but perhaps a better name.

Parking Management

2006 N Same as measure 47.

49 246 Increase meter fees for on-street parking

Unclear if the current availability and cost would affect vehicle travel.

Parking Management

2006 N Baseline data of use, availability, and pricing not available.

May 2009



Year Added


50 248 Eliminate employee parking subsidies

Duplicate measure. As opposed to traditional parking cash-out, this program would operate on employer-owned parking.

Parking Management

2006 N Determine number of employer-owned parking spaces and cost to employers of providing them. Evaluate using average or area-specific average parking costs and a cash-out equivalent to the expected revenue from renting the spaces out to employees of other companies. Measure 51 has a better description of the approach.

51 249 Employee parking cash-out program

A monetary incentive to ride share or use alternative commuting options.

Parking Management

2006 Y + + Re-evaluate based on current subsidies, potential for removal, and price effect on commuters. Other areas have predicted large emission reductions for this measure. Evaluate with measure 47.

52 253 Smart Cards pay as you go parking

Unclear if this measure represents an incentive to reduce vehicle travel.

Parking Management

2006 N The incentive for reduced vehicle use has not been identified.

53 256 Reduce legal on-street parking spaces in high congestion areas

Effectively increasing road capacity to reduced stop and go progression improving arterial speeds.

Parking Management

2006 N Increase average vehicle speeds for arterials.

54 262 Limit peak period parking to vehicles with two or more occupants

Use flextime, but permit only vehicles with two or more occupants to enter workplace parking facilities during peak periods.

Parking Management

2006 N Unless this measure is better defined, only the peak traffic would be affected not reducing overall vehicle use. Enforcement would be difficult and the costs would outweigh emission likely emission benefits.

55 271 Remove fuel subsidies

Fuel prices and vehicle use have a direct correlation, but the specifics of this measure (price increase) need to be defined.

Pricing Measures

2006 Y + + The relationship of the fuel price and the vehicle use is required especially based on recent gasoline price increases and its resulting effects, and proposed legislation on fuel taxes and subsidies.

56 273 Accelerated depreciation allowance for employer provided vanpool and bicycle facilities

Incentive to provide alternative commuting options, but not an emission reduction measure by itself.

Pricing Measures

2006 N This measure could be examined further to determine cost savings and additional incentives for employers to provide vanpools or bike facilities. If this examination shows sufficient potential the measure should be quantified.

May 2009



Year Added


57 275 Congestion pricing for major activity centers

Charge vehicles to enter high-activity centers (retail/business districts, etc.) in cities, with higher prices charged during high-traffic hours.

Pricing Measures

2006 Y + + This measure was evaluated in 2006 and the conclusion was that reductions would be less than 0.01 tpd. This measure is applied in many other countries with success, but would raise a lot of implementation concerns.

58 277 Pay-As-You-Drive Insurance (per-mile)


Pricing Measures

2006 Y + + This measure was quantified as producing among the higher emission reductions in the 2006 analysis and should clearly be quantified for the 2008 analysis. The measure has also been implemented at least at a pilot level in other areas, and is attractive to insurers. The effect of recent gas price increases on driving needs to be evaluated with respect to the choice of the appropriate elasticity will need to be evaluated.

59 287 Local or regional fuel taxes

Fuel prices increases. Duplicate to measure 55.

Pricing Measures

2006 Y + + This is a more direct and clear approach than measure 55. The amount of tax would need to be defined but the effectiveness would be proportional to the tax.

60 291 Vehicle miles traveled - based taxes

Charge a tax or registration fee by vehicle miles traveled per year.

Pricing Measures

2006 Y + + Like measure 59, this is a more direct and measurable approach than measure 55. The amount of the tax would need to be estimated to determine the impact of the measure.

61 295 Increase tolls during peak traffic periods

The application higher costs only during peak hours are likely to have an insignificant impact on regional vehicle travel. The Houston area peak period is too long to permit more than small incremental travel changes outside the peak .

Pricing Measures

2006 N Based on the HOT lanes on some freeways in Houston region, this measure may have applicability now and in the future as freeways become more congested. But the effect is likely to be small because of the limited number of toll ways and penalty for driving would be applied only to peak hours.

62 298 No tolls for buses and vanpools


Pricing Measures

2006 N Possibility that removing tolls for vanpools would provide a significant incentive to employers to purchase vanpools.

63 300 Increased speeding fines

Increase amount of fines for exceeding existing speed limits over 45 miles per hour; use additional funds generated to fund vehicle replacement of other emission-reduction programs.

Speed 2006 N This measure may reduce emissions, but MOBILE model limitations would make it difficult to evaluate. An assumption regarding the effect; for example, the speeding above 65 mph would be reduced.

May 2009



Year Added


64 302 Aggressive driving enforcement

Speed 2006 N This would not likely be considered a permanent measure but as an element of Measure 65 or 66.

65 304 Lower speed limit in urban area to 55 miles per hour

The MOBILE model estimates lower emissions if freeway free flowing speeds of cars and especially heavy-duty trucks are reduced.

Speed 2006 Y + This measure may be difficult to implement because it requires State approval. The approach would apply only to limited access roads where high speeds occur. Increased enforcement personnel would be needed.

66 311 Reduce speed to 55 miles per hour for commercial trucks

Lower freeway speeds of trucks lower emissions more than lower speeds for light-duty vehicles.

Speed 2006 Y + Historically, Texas has not wished to have different speed limits for cars and trucks. Although it currently does have different ones for certain freeways.

67 316 Incentives for infill and redevelopment

Several measures to plan communities for lower vehicle travel. This would entail that the development be compact (to encourage walking and bicycling) and convenient to transit.

Sustainable and Transit-

Oriented Development

2006 Y + + Evaluate potential using methods and projections of infill and smart growth. Combine with measure 69 and 70 and especially 137, which is recommended as the "umbrella" measure

68 319 Local medical facilities

Increase the number of local “neighborhood” facilities for routine medical procedures



2006 N Evaluate VMT due to medical trips, which will be a percentage of Home-to-Other and Work-to-other. The percentage could be obtained from the travel modeling section or from most recent trip surveys. But is likely to be insignificant or one part of larger measure to reduce community travel. See measure 137.

69 321 Encourage or require complementary uses in close proximity in all developments or development areas

Apply Planned Use Development (PUD) concept by area, requiring a mix of complementary uses in each square mile or other development area in accordance to a sub-area, locally developed plan.




70 323 Comprehensive design guidelines for activity centers

Comprehensive design guidelines for layout of schools, neighborhoods and other activity centers to maximize walkability and minimize the need for short-distance automobile trips.




May 2009



Year Added


71 324 Locate personal business support centers at park-and-ride facilities (convenience businesses)

Business location selection results for numerous reasons.



2006 N The headway times at park and ride facilities too short to justify expense, who would use these facilities, and the probable cost of installation and maintenance would not justify additional incentive to park and ride.

72 326 Co-locate event centers and major transit centers and stations

Local event centers at sites of major transit centers to ensure high level of service.



2006 N This measure would be event oriented and very capital intensive. It would probably cause a percentage of event attendees to utilize transit to avoid parking problems at events so worth looking into when siting these facilities, but not a regional strategy.

73 327 Daycare and other services

Daycare, other convenience services at park-and-ride lots and transit stations.



2006 N Many employers already provide. Could develop a qualitative evaluation of commuting employees with children in off-site day-care and quantify extra VMT associated with driving children to day-care and then assume a percentage of those can be serviced by day-care provided at the work site.

74 328 Ban left turns Effectively increasing road capacity to reduced stop and go progression improving arterial speeds.

Traffic Flow Improvements

2006 N May increase average vehicle speeds for arterials. Evaluation would require developing a database of all left turns to be banned, and the additional miles traveled as a result, as well as changes in travel speeds due to increasing the volumes.. Cost of installing the signs would be high.

75 342 Reversible traffic lanes

Increased capacity in commuting direction.


2006 N

76 350 Local intersection signal improvements



2006 Y + + Increase average vehicle speeds for arterials.

77 351 Traffic signal equipment or software updating




May 2009



Year Added


78 352 Emphasis on major route traffic signalization; through route traffic platooning




79 354 Real-time traffic flow management

Traffic signals that change timing/cycles to accommodate real-time traffic conditions.



80 355 Adaptive traffic signals and signal timing




81 357 Light emitting diode (LED) traffic signal replacement

It is unclear how this measure could reduce emissions.


2006 N

82 358 Two-phase signals Traffic Flow Improvements

2006 N Increase average vehicle speeds for arterials.

83 360 Signal timing and coordination to promote traffic progression

Currently signal coordination tends to focus on reducing delay time for individual drivers; alter coordination to promote greatest movement for traffic as a whole.



84 366 Prohibit drive-thru service during ozone season

The measure might be difficult or onerous to implement.

Traffic Management

2006 Y + This measure reduces idling of vehicles, but that is historically a small benefit.

85 371 Reduce transit fares Incentive to use transit instead of vehicles.

Transit 2006 Y + + Evaluate changes in transit use occurring in a selected time period of gasoline price increases to determine potential. The lost revenue would need to be replaced for transit capacity to continue. Reduced fare usually results in a small increase in transit use.

86 374 Peak/off-peak transit fares

Duplicate measure. Transit 2006 N See measure 85.

87 376 Personalized rapid transit

Duplicate measure. Transit 2006 N See measure 90.

88 377 Transit schedule coordination

Transit 2006 N Effect too small to encourage significant additional transit use.

May 2009



Year Added


89 393 Guaranteed ride home

Incentive for transit use, not a reduction measure itself.

Transit 2006 N This measure is part of various measures that enhance ridesharing programs. It is not recommended that it be evaluated individually.

90 403 Subscription bus service

On demand personalized transit service similar to other commercial shuttle services but providing lower cost and less stressful methods of commuting or running errands in parts of town that are far from residences.

Transit 2006 Y + + A transit enhancement measure designed to attract transit users to specialized and customized transit services. This measure may be particularly attractive in years such as the attainment year. If the service was subsidized through transit funding or through the use of funds generated by other programs such as VMT taxes it could be highly effective in terms of both emissions and costs.

91 407 Business First enhanced buses

Provide buses with laptop/Internet links, telephone and other business amenities. Similar to measure 90.

Transit 2006 N An incentive for transit use, not a reduction measure by itself unless structured like measure 90.

92 414 Electrify bus routes Fixed routes with catenary electric delivery. This could be a significant change in current operations.

Transit 2006 Y + Direct emission reduction from electrified buses. This could be very difficult to evaluate because the routes, engineering considerations (e.g. clearances and power substations), and bus purchases or retrofits all need to be considered.

93 422 Monthly transit pass programs

Already implemented and difficult to predict the increase transit ridership as a result.

Transit 2006 N Already implemented for some time. Perhaps further reduce prices.

94 423 Eliminate trips - Free transit from remote sites

This measure is ill defined especially on how reduced vehicle mileage is attained.

Transit 2006 N This measure does not seem to provide any emission reduction.

95 424 Provide an off-peak unlimited-ride daily pass

May already be implemented in large measure through the monthly pass program.

Transit 2006 N Evaluate extent to which this is already offered in current transit program.

96 426 Uniticket programs This is an incentive not a vehicle travel reduction measure.

Transit 2006 N Largely including in the monthly pass program.

97 428 Simplified fare collection

Difficult to show that this is an incentive for greater transit usage.

Transit 2006 N Not quantifiable.

98 430 Public transportation - Special fares

The measure needs to be refined in terms of the incentives and participants in the program.

Transit 2006 N Not quantifiable without extensive survey data.

May 2009



Year Added


99 433 Accelerate rail expansion

Increase transit capacity. Rail evaluations would need to have specific proposals and market analysis.

Transit 2006 Y + + If specificity on expansion and ridership can be provided by appropriate agency this measure could be evaluated.

100 436 Commuter Rail Combine regional and light passenger rail measures.

Transit 2006 N See measure 99.

101 437 High-speed rail Specially designed regional passenger rail.

Transit 2006 N See measure 99.

102 438 Free circulator service to major generators

Free shuttle/transit service connecting remote areas with major activity generators. Increase transit capacity.

Transit 2006 Y + + If the description refers to shuttles in between major employment and retail centers this measure could have significant potential. Recommend agreeing upon additional specificity with appropriate H-GAC staff. Specificity refers to identifying major generators, number and capacity of shuttles, and their frequency of service.

103 441 Provide High Occupancy Vehicle (HOV) shuttle between company facilities

Effectiveness of the measure depends on the number of companies and shuttles operating.

Transit 2006 N Evaluate number of companies that have multiple locations within Houston region along with frequent travel back and forth by employees. The benefit is likely to be small.

104 446 Teleconferencing of meetings

The available benefit is unclear. Travel Demand

Management: Business

Operations

2006 N Evaluate potential from a qualitative standpoint. Most companies implementing already to extent possible for other reasons and due to advances in web-meeting technology.

105 453 Mandated peak spreading

Require business hours to be staggered to spread peak traffic over a wider time period and reduce congestion.

Travel Demand


Operations

2006 N The peak in Houston is longer than almost all other urban areas in the U.S. (view HOV lane times). Less opportunity for further peak spreading exists in Houston region.

106 459 Mandatory or voluntary compressed work week

The benefits of this program could be included with a variety of commute reduction options. This represents one alternative of the reduced commuting options.

Travel Demand


Operations

2006 Y + + This measure creates a 10 - 20% reduction in weekly trips by any participant. Recommend a mandatory and a voluntary evaluation with the latter based upon a review of current employer practices and ability to sustain a compressed work week.

May 2009



Year Added


107 460 Subscription buses or buspooling

Duplicate measure. Travel Demand


Operations


108 461 Internet ridematching services

Real-time ridematching offered via a Website, by an employer, or by a third party (sponsored by city or transportation authority).

Travel Demand


Operations

2006 Y + + Evaluate 2008 and expected future benefits of NuRide – the current internet-based program for H-GAC which began providing internet matching for ridesharing in 2006. Then evaluate the extent to which this program is expected to grow along with the use by Houstonians of other online ridesharing services such as GoLoco, Ridesearch, erideshare, etc. The effect of recent gas price increases needs to be considered.

109 462 Purchase vans for vanpools

Commute reduction along with the opportunity to buy cleaner vans.

Travel Demand


Operations

2006 Y + + With or supplemental to measure 118.

110 463 Mandate or encourage vanpooling and carpooling

One of many commute reduction measures already included in the list.

Travel Demand


Operations

2006 N Mandate not feasible. Encouragement already provided in Commute Solutions program.

111 465 Mandatory or voluntary flextime program (daily start and end time)

Temporal allocation of vehicle travel, but not a reduction measure itself.

Travel Demand


Operations

2006 N As normally constructed, flextime allows employees to commute during off-peak hours. Because of the long peak period length in Houston this measure would not have a quantifiable effect.

112 470 Pay or other financial incentive for not driving

Employer pays employees who do not drive a monthly stipend; employees who drive receive no corresponding benefit.

Travel Demand


Operations

2006 Y + + It may be more cost effective than other measures, particularly capital intensive ones. This type of measure ought to be evaluated in connection with comparing the relative cost effectiveness of various programs.

May 2009



Year Added


113 471 Employer tax credit or deduction

Institute a tax credit or deduction for employees that regularly use a non-single occupancy vehicle mode for commuting and/or for employers, based on number of employees that commute using non-SOV

Travel Demand


Operations

2006 N Recommend qualitative evaluation with respect to implicit tax credits due to high transportation costs. Also employers in some workplaces are already providing such incentives. But it is an incentive that would require survey work to determine an emission reduction.

114 475 Incentives for Best Workplaces for Commutes Designation

Already implementing in Houston Travel Demand


Operations

2006 N Review status of this program. Federal funding no longer available.

115 477 Trade equivalent jobs to be closer to work

For employees of the same company but at different worksites, identify opportunities to "trade jobs" or worksites to reduce commute distance.

Travel Demand


Operations

2006 N Employees who could do this already would in order to save time and money.

116 484 Personalized travel planning

Based on rider's origin and destination(s), personalized travel plan of transit routes and connections provided via website or telephone service.

Travel Demand


Operations

2006 N Difficult to reach a significant enough individuals, have them make a change and sustain that change in a way that reduces emissions. Provision of such services could enhance existing programs quantified under measures listed elsewhere in this list.

117 487 Telecommuting incentives or mandates

The measure is ill defined and is duplicative of other measures.

Travel Demand


Operations

2006 N Mandates not feasible. Suggest combining measures into separate individual measures from Commute Solutions.

118 496 Regional Vanpool programs

Could add more to current Houston vanpooling program, but a duplicate measure.

Travel Demand

Management: Regional

Applications


119 499 Share hybrid vehicles

Shared vehicles among a group of owners

Travel Demand


Applications

2006 N No evidence that shared vehicles lower emissions because the same number of mile could be driven.

May 2009



Year Added


120 500 Encourage pooled ownership of single occupant vehicles for local midday travel

Encourage pooled ownership of cars, trucks; e.g., one neighborhood collectively owns an SOV for periodic use.

Travel Demand


Applications


121 501 Car Sharing Programs (Flexcar)

Car-sharing programs. We give our members the key to new cars, trucks, and minivans located across a metropolitan region. You pay an hourly rate, and the company pays for the car, insurance, gas and a reserved parking spot!

Travel Demand


Applications


122 503 Rideshare matching, transit marketing and information programs

This measure could be included as part of a larger strategy to reduce commuting by single occupancy vehicles.

Travel Demand


Applications

2006 N Reporting requirements would likely make this measure be a voluntary measure.

123 504 Rewards for reducing total vehicle miles traveled in a city or region

It is unclear how this measure would reduce vehicle miles traveled or how it would be measured.

Travel Demand


Applications

2006 N

124 551 If the California Low Emitting Vehicle Program is adopted and only LEV certified, gasoline vehicles are for sale in Texas, then mandated fleets should have to purchase the ULEV alternative fuel version of the same vehicle rather than the gasoline version

The California LEV II program includes new fleet average emissions standards as well as CO2 reductions. A fleets mandate in addition to the Cal. LEV II standards would have a much lower impact.

Vehicle Emission Standards

2006 Y + + TCEQ and several state have concluded that the California LEV II program would reduce VOC and NOx emissions. http://www.cdphe.state.co.us/op/aqcc/meetingminutes/2007/092107-Final.pdf http://www.flchamber.com/docs/Coalitions/Energy/DEP_CA_MotorVehicleEmissions_082307.pdf This would be in addition to measure 125.

May 2009



Year Added


125 553 Adopt California standards for vehicle emission rates

Public and Publicly contracted fleet rules or Statewide.

Vehicle Emission Standards

2006 Y + + Benefit small if limited to these fleets. Better PM and CO2 benefits from CAL LEV. Past attempts at statewide legislation to adopt LEV II failed. If requirement is through local ordinance or contract terms, vehicles would need to be purchased in California.

126 576 Limitations on idling of heavy-duty vehicles


Vehicle Idling 2006 Y + Idling reductions, while cost effective, typically have a small impact.

127 587 Heavy-Duty Vehicle Border Inspection Program for AB 1009 (Pavley 2004)

HD commercial vehicles engines must meet US HDDV standards in place at the time of manufacture and must display valid emission control label.

Vehicle Inspection and Maintenance

2006 Y + Smoke check relatively easy to do, NOx would require heavy-duty dyno or possibly remote sensing for diesels. High PM usually correlates with low NOx and higher VOC emissions from diesels.

128 589 More frequent emissions tests for taxi cabs

Require taxi fleets to be tested twice per year to get license to operate.


2006 N Allow taxis over 5 years old to be eligible for LIRAP (c.f. current 10 year requirement for all vehicles) to provide a better benefit.

129 592 Augment truck and bus highway inspections with community-based inspections (HDV8)

HD vehicles are inspected to detect mal-maintenance and tampering and to measure smoke emissions in mixed-use communities.


2006 Y + MY 93-98 reflash if not already done (NOx reductions already included in regional emissions modeling). Smoke check relatively easy to implement but high PM means low NOx reduction.

130 594 Addition of HDGV2B weight class vehicles to inspection and maintenance program

The inspection criteria would need to be defined more precisely for these vehicle types.


2006 N Pre MY 96 vehicles currently receive TSI test. Would need to "centralize" placement of HD dynos. OBDII phase in from MY 2004 -2008.

131 598 More frequent testing for vehicles that repeatedly fail inspection tests

EPA has not quantified the benefit of more frequent testing.


2006 N No modeled benefit. Better to encourage these vehicles to be replaced (LIRAP) or at least require repair at Recognized Emissions Repair Facility.

132 601 Extend or expand light-duty diesel engine inspection and maintenance program

The technology has yet to be defined for inspection of these vehicle types.


2006 N Impractical to ASM test pre MY 96 LDDVs (no cut points available)

May 2009



Year Added


133 604 If the largest city in a county takes part in a testing program, the entire county must opt-in.

Current I/M legislation for nonattainment areas is based on counties. EAC area requirement is for county along with the largest municipality.


2006 Y + + The benefits are restricted to the small counties not already in the program.

134 623 Mandated no drive days

An extreme measure to prohibit vehicle travel include only if needed.

Vehicle Operations

Management

2006 Y + + Important to evaluate for perspective and as a last resort measure.

135 628 Voluntary no drive day programs

Such a voluntary vehicle travel reduction program needs to be defined more precisely.

Vehicle Operations

Management

2006 N This would be evaluated as small percentage of individuals voluntarily participating and would require extensive reporting to claim a benefit.

136 629 License plates determine access to vehicle use (odd/even driving days)

Duplicate measure. Vehicle Operations

Management


137 630 Encourage/Mandate Livable Centers

Includes a host of ideas to reduce vehicle travel.



2008 Y + + Combine with other individual measures into one package of options for community planning. Evaluate, discuss, and then apply spreadsheet-based methodology developed by H-GAC for three selected livable center scenarios defined in close collaboration with H-GAC and city/land use planners. Two different spreadsheet-based approaches are currently available.

138 631 DPS-like emissions sensors in HCTRA toll booths - enhanced smoking vehicles program

Program is ill defined in terms of the technology and how it would interact with the current inspection program.


2008 N If we are looking for NOx, difficult to use remote sensing if multiple booths in operation. For smoke, high PM, low NOx.

139 632 Enhanced enforcement for Smoking Vehicles Program - vehicle impounding for violators (like Dallas Emissions Enforcement Pilot Program)

Link to I/M test status: encourage local police to enforce existing smoking vehicle legislation



2008 Y + May reduce number of vehicles avoiding I/M test. Real versus modeled reductions issue. NCTCOG estimates I/M compliance at around 80% not 96% as modeled.

May 2009



Year Added


140 633 Limit left turns on selected thoroughfares at all times

Duplicate measure. Traffic Flow Improvements

2008 N See measures 74 and 37.

141 634 Higher registration fees for high emissions vehicles

The measure needs to be refined to include emissions standards and emitter status.

Pricing Measures

2008 N The implementation issues need to be addressed carefully with regard to model year and inspection test results.

142 635 Prime parking for vanpools/carpools/hybrids



143 636 Hybrid cars parking meter fee exemption

Hybrid light-duty vehicles cannot demonstrate much emission reduction, and this measure merely provides an incentive for their use.

Parking Management

2008 N Hybrid vehicles meet the same emission standards as other light-duty vehicles.

144 637 Use of taller highway barriers to reduce “rubbernecking”

This measure would affect free flowing vehicle speeds.



2008 N The benefits of the program may be difficult to demonstrate.

145 638 Increased use of hybrid buses

Hybrid heavy-duty vehicles have been funded to date in current air quality programs.

Transit 2008 Y + Benefits of this technology can be verified, but is relatively costly for the purpose of emissions reductions only. Reduced fuel consumption is an added benefit to the operator.

146 639 Initiate a flexbike service to encourage bicycling

Duplicate measure. Bicycle and Pedestrian


147 640 Creation of regional government idling restriction MOU


Vehicle Idling 2008 Y + + Demonstration of the benefit may be difficult.

148 641 Industry idling restrictions


Vehicle Idling 2008 Y + + Demonstration of the benefit may be difficult. See measure 147.

149 642 More stringent I/M cut points

Cut points only relevant to MY 95 and older vehicles, number of which reduces considerably each year, making this less effective.


2008 Y + + Decreasing benefit in the MOBILE model with each calendar year. Higher failure rate may encourage more fraud.

May 2009



Year Added


150 643 Accelerate development and construction of mass transit projects

Capacity improvements to mass transit combined with other bus and rail measures.

Transit 2008 N Very capital intensive, need to discuss with agencies in terms of potential ridership increases.

Table 4-2. Non-road vehicle emission reduction measures.

ID Control Strategy Description Year

AddedEPA

PQSE VOC NOx Comment 1 Aircraft emission standards New emission standards for aircraft

engines fall under international and Federal rules.

2001 N These are covered by international standards and any local measure would not be considered permanent.

2 Ordering lowest emission engines

Fleet management of aircraft flying into HGB.

2001 N These are covered by international standards and any local measure would not be considered permanent.

3 Changes in general conformity to make provisions more realistic; Allow equipment turnover to count

General conformity is a criteria to meet by new projects and not included in SIPs

2001 N This is not an emissions reduction strategy, but credit should be taken for lower emitting aircraft.

4 Modify regulations so credits can be generated for general conformity

General conformity is a criteria to meet by new projects and not included in SIPs

2001 N This is not an emissions reduction strategy.

5a Enhanced Texas Emission Reduction Program (TERP)

The TERP program has been responsible for significant NOx reductions to date

2005 Y + The TERP program could be revised to account for the realities of emission controls on on-road, nonroad, and other mobile source categories with EPA emission standards that have been promulgated in recent years.

5b Extend TERP to 2018 Current TERP legislation provides funding for the program until 2012.

Y + Proactively extending this funding to 2018 would ensure that this funding would be available until the region is required to meet attainment.

6 Aftermarket Technology and Fuel Additive Research Program

EPA approval of aftermarket and fuel technologies would be necessary.

2001 N Fuel additives not credited in the TERP might creditable, if they pass EPA approval. One example may include cetane improvers. But the strategy would need to be better defined to provide emission reductions creditable for SIPs.

7 Improve inventory of construction equipment; Log hours of actual equipment operation

Activity reduction of nonroad equipment.

2001 N Equipment activity reductions are difficult to prove that a reduction occurred and any reduction would not be considered permanent.

May 2009



AddedEPA

PQSE VOC NOx Comment 8 Government construction

incentives This measure is considered to include money, tax relief, or proposal preference to firms using clean equipment.

2005 Y + Incentive for the use of clean construction equipment has been attempted including the TxDOT program. But the reporting requirements and conflicts with the TERP benefit lead to less use of the program and lower benefits than were expected.

9 Develop air quality best management practices (BMPs); Use BMPs to manage emissions from construction sites, construction vehicles & wind-blown dust

The BMP could include a clean equipment use clause.

2005 N The program needs to be better defined in terms of the use and types of equipment at each job site. The reporting burdens to justify an emission reduction would be onerous.

10 Limitations on idling of heavy-duty construction equipment

Idle reduction either through the use of automatic shut-off devices or operator training.

2005 Y + Many states have regulations to reduce equipment idling. The benefits of the rule may vary depending upon the implementation and enforcement of the programs, but generally idling emissions reductions are small but cost effective.

11 Water injection for diesel engines Engine and Fuel Technology 2001 Y See 5 TERP, measure 5. 12 Alternative-fueled equipment for

all equipment types Engine and Fuel Technology 2001 Y See 5 TERP, measure 5.

13 Alternative fuel heavy-duty equipment

Engine and Fuel Technology 2001 Y See 5 TERP, measure 5.

14 Lean NOx catalyst Engine and Fuel Technology 2001 Y See 5 TERP, measure 5. 15 Early introduction of low-NOX

engines Engine and Fuel Technology 2001 Y See 5 TERP, measure 5.

16 Selective catalytic reduction (SCR)

Engine and Fuel Technology 2001 Y See 5 TERP, measure 5.

17 Compression ignition standards for vehicles and equipment

Engine Standards 2001 N EPA has already implemented Tier 4 regulations for nonroad equipment.

18 Spark ignition standards for vehicles and equipment

Engine Standards 2001 N Small and large spark-ignition engines have been covered by EPA rulemakings.

19 Lower sulfur fuels Fuel Standards 2001 N No VOC or NOx benefit beyond Federal mandates for low sulfur gasoline by 2004, on-road diesel by 2006, and all off-road diesel by 2012.

20 Texas Low Emission Diesel (TxLED)

Fuel Standards 2001 N Implemented

21 Lawnmower exchange; Trade in old gas powered equipment for discounts on zero emission models

A retirement program for old and malfunctioning lawn and garden equipment.

2005 Y + The benefits of such a program could be established, but focus primary on VOC reductions. It should not be restricted to lawnmowers and also include other equipment such as smaller blowers, string trimmers, etc. The overall benefits would be expected to be small, but could be cost effective.

May 2009



AddedEPA

PQSE VOC NOx Comment 22 Lawnmower recycling programs

(rebate program); replace gas mowers with electric

Duplicate measure. 2005 Y See 21

23 Promote use of cleaner lawn and garden equipment such as lower-emission four-stroke and electric-powered equipment


24 “Buy a Clunker” concept for small gas equipment


25 Disincentives such as fines if caught mowing during Ozone Alerts

Operational restriction. 2001 N This is not a permanent measure and difficult to demonstrate compliance.

26 Ban equipment such as two-stroke engines

Operational restriction. 2001 N This would preempt Federal rules.

27 No-mowing days Operational restriction. 2005 N This is not a permanent measure and difficult to demonstrate compliance.

28 Grass cutting; Public works will delay cutting grass till 6 pm on ozone action days

Operational restriction. 2005 N This is not a permanent measure and difficult to demonstrate compliance.

29 Landscape ordinance for nonresidential areas

This measure would need to be included in permits, building zoning, or municipal rules.

2005 Y + This measure refers to lower maintenance landscaping that reduces the need for off-road equipment usage such as lawnmowers and could reduce water consumption as well. These types of programs are difficult to administer and verify.

30 Use of auxiliary power units (APUs) for locomotives operating; Controls for locomotives are pre-empted by Federal law, but voluntary controls might have some success

This measure is equivalent to an anti-idling measure either through the use of devices or operator training.

2005 N Automatic idle shut-off devices may be installed on equipment. This measure was largely applied by the larger railroads on a voluntary basis for previous SIP efforts.

31 Accelerated purchase of Tier 2, 3, and 4 locomotive engines or remanufactured existing locomotives

An accelerated fleet turnover measure would need to be implemented on a voluntary basis because of federal preemption.

2005 Y + This measure has been superceded by EPA rules for existing and future locomotives. The 2008 rule includes a remanufacturing provision for locomotives in operation today. The rule might be implemented more quickly with incentives for remanufacture or replacement of older engines under a voluntary program.

32 Electrification of rail Rail electrification is nearly exclusively a passenger rail option, such as the Houston light rail line.

2005 N This option may be available for expanded light-rail or other passenger rail options. But the emission reductions would be less use of on-road vehicles.

May 2009



AddedEPA

PQSE VOC NOx Comment 33 Efficiency improvements on In-

Use Class 1 Rail Equipment (R11)

This measure would improve rail connections, eliminate at grade road and rail crossings.

2005 Y + Rail improvements might be considered if it can be shown that locomotive idling or braking events can be reduced. Usually these improvements also have safety and congestion relief benefits.

34 Limitations on idling of locomotives

Duplicate measure. 2005 N Automatic idle shut-off devices may be installed on equipment and reductions justified through reporting. Similar to measure 30.

35 Portable engine fleet turnover This measure addresses nonroad engines assigned to a specific industrial facility.

2008 Y + Includes registration and accelerated turnover of equipment to more recent model years but affects a small portion of the nonroad emission source categories. http://www.arb.ca.gov/portable/portable.htm

36A Low Sulfur Fuel for Marine Vessel Main and Auxiliary Engine

Low sulfur fuels provide a modest NOx reduction with large particulate and SOx emissions reductions.

2008 Y + California is proposing this measure as a rule, and the Port of Los Angeles as an incentive. http://www.arb.ca.gov/ports/marinevess/marinevess.htm

36B Harbor Craft Fleet Management Harbor craft include tugs, ferries, supply, excursion, and other smaller commercial marine vessels. The measure would seek to accelerate the fleet turnover to remanufactured existing and Tier 3 and 4 engines.

2008 Y + The California rule if finalized in its June 2008 proposed format would include provisions for mandated turnover of harbor craft engines to those meeting lower emission standards. Could be implemented as a voluntary measure to replace engines. http://www.arb.ca.gov/ports/marinevess/harborcraft.htm

37 Cargo Handling Equipment Fleet Management

Cargo handling equipment includes nonroad equipment used at intermodal (ports and rail) facilities to move freight. The California rule includes retrofit or fleet management with the use of newer engines to comply.

2008 Y + Encourage accelerated turnover or retrofit of equipment used at ports and intermodal rail yards. http://www.arb.ca.gov/ports/cargo/cargo.htm

38 Clean Fuel Option: Expand TxLED Use.

The use of TxLED could occur in source categories not currently required to implement the fuel use including marine and other engines.

N The use of TxLED is already required for sale for marine and locomotive fuel sales in the 110 counties affected by the Texas regulation. http://www.tceq.state.tx.us/implementation/air/sip/cleandiesel.html#Draft

39 Provide full funding for the National Retrofit Program

EPA has set up the mechanism for providing grants to reduce emissions from off-road equipment under the National Clean Diesel Campaign, http://www.epa.gov/cleandiesel/

2008 Y + The funding varies by year ($47 million in 2008) and is competitive from all states. The funding level is relatively small when applied nationwide.

May 2009



AddedEPA

PQSE VOC NOx Comment 40 Allow private companies to apply

for NRP grants Clean equipment grants program. 2008 Y + Further investigation into the application process is

required to determine the applicant restrictions, which are determined by EPA.

41 Allow NRP grants to cover incremental costs for TERP or CMAQ retrofits

Supplemental funding for other existing funding programs.

2008 N The use of TERP funds to provide matching might be possible, but would make the Clean Diesel and TERP applications more complicated. The mix of national and state funding however does not lead to more emission reduction.

42 Establish emissions trading program for nonroad vehicles (DERC)

Emission trading for stationary sources applied to mobile sources.

2008 N Verification of emission reduction credits is likely to be difficult.

43 Allow use of TERP funds for administrative costs. Specifically, this can be used to help small companies without the time or resources to apply and track retrofits

TERP revisions. 2008 N The TCEQ would find this difficult to justify, and a legal review of the enabling legislation would be necessary to determine if TCEQ is allowed to provide administrative funding. This measure by itself would not reduce emissions.

44 Provide cooperative grant assistance to encourage small companies (<20 employees) who do not have the resources to manage grants alone to apply for TERP

TERP revisions. 2008 N This measure might be addressed through greater staffing at TCEQ or the TERP administrative entity. The emission reduction benefit would be associated with increase participation rather than with the program itself.

45 Development of a Port of Houston Clean Air Action Plan that seeks to minimize emissions from ships, cargo handling equipment, on-road drayage trucks, and port-related rail.

Clean Port initiative including on-road and nonroad source categories.

2008 Y + A port related approach could yield emission reductions, but the program would need to be better defined. The strategies available exist in other measures listed.

46 Adopt policies and programs to increase the number of clean construction machines used on public works projects.

Clean construction equipment. Duplicative measure.

2008 Y See Measures 8 and 9

May 2009

G:\HGAC\Reports\Final_051109\Sec5_Eval_051109.doc 5-1

5. DETAILED EVALUATION OF QUALIFYING MOBILE MEASURES This section provides the Short List of Mobile Control Measures, and summarizes the detailed results of the study for voluntary measures that qualify as emission reduction measures under EPA guidance by the 2015 – 2018 time frame. The master list of measures outlined in Section 4 was pared to just those measures that have emission reduction potential under the EPA guidance outlined in Section 3 and could be implemented locally without requiring state regulations. The measures that remained on this pared down list also excluded several measures implemented by state or federal agencies. The analysis for this section was more quantitative in nature. The remaining measures can be found in the following tables. A summary of the on-road measures is provided in Table 5-1 from which the specific Transportation Control Measures (TCM) outlined in Appendix E were derived, non-road measures in Table 5-2 and weight of evidence measures in Table 5-3. The detailed summaries with full descriptions of the measure, implementation issues, public reaction, and analysis of benefits and cost effectiveness are supplied in Appendix F for on-road measures, Appendix G for non-road measures and Appendix H for weight of evidence measures. Table 5-1. On-road measures detailed evaluations summary.

Emission Reduction

Potential (tpd) Cost Effectiveness

($/ton) ID Control Strategy Description

VOC NOx VOC NOx

1 Bicycle and pedestrian action

Benefits from bicycle measures includes new bicycle lanes as well as encouraging greater use of existing lanes instead of vehicle use. But it can be difficult to determine the benefits of such programs.

32

Encourage bicycle use by using ITS to increase safety in strategic bicycle/ automobile conflict areas

Duplicate or supplemental measure.

0.04 0.03 $681k $915k

11 Cleaner diesel fuel/Alternative Fuels

There are diesel fuels that have improved performance even beyond the TxLED. They could include cetane additives or gas-to-liquids diesel fuels. Alternative fuels include: natural gas, propane, hydrogen, electric, and other alternative fuels. These are included only as voluntary measures.

unknown 0.02-2.4 unknown $40,000-$600,000

90 Dedicated long route or subscription bus service

Long route or on demand personalized transit service similar to other commercial shuttle services but providing lower cost and less stressful methods of commuting or running errands in parts of town that

0.18 0.05 $583k $2,100k

May 2009


Emission Reduction



VOC NOx VOC NOx are far from residences.

92, 99,

Electrify bus routes/Accelerate rail expansion

Increase transit capacity. Rail evaluations would need to have specific proposals and market analyses.

Unknown 0.07 Unknown

39, 47, 51, 57, 85, 102,106,

Compressed work week, telework, or other commuting alternatives

The benefits of this program could be included with a variety of commute reduction options. This represents one alternative of the reduced commuting options.

0.93 0.69 $4k $5k

108 Internet ridematching services

Real-time ridematching offered via a website, by an employer, or by a third party (sponsored by city or transportation authority).

0.52 0.38 $2k $2k

109 Purchase vans for vanpools

Commute reduction along with the opportunity to buy cleaner vans.

0.10 0.07 $119k $175k

76 Local intersection signal improvements


77 Traffic signal equipment or software updating


78

Emphasis on major route traffic signalization; route traffic platooning


79 Real-time traffic flow management

Traffic signals that change timing/ cycles to accommodate real-time traffic conditions.

80 Adaptive traffic signals and signal timing


83

Signal timing and coordination to promote traffic progression

Currently signal coordination tends to focus on reducing delay time for individual drivers; alter coordination to promote greatest movement for traffic as a whole.

2.0 1.7 $220K $240K

3 Private sector clean fuel fleets

This measure is patterned after the H-GAC Clean Vehicles Program where clean engines (whether alternatively fueled or no) are purchased for fleets to reduce emissions.

N/A 1 – 2.5 N/A $18k

May 2009


Emission Reduction



VOC NOx VOC NOx

5,6 Public agency clean fleet program

Commitment by public agencies to purchase cleanest practicable fleet vehicles could be an element in funding such as through the H-GAC Clean Vehicles Program or a voluntary commitment.

See measure #3

22 Dedicated funding for school bus replacement

H-GAC Clean Cities/Clean Vehicle or state/federal funding sources. This program specifically targets school bus fleets that trend toward older models.

N/A 0.77 N/A $15k

7, 145

Electric vehicles/Increased use of hybrid buses

Hybrid or other lower emitting heavy-duty vehicles have been funded to date in current air quality programs.

N/A 0.23 N/A $350k

May 2009


Table 5-2. Non-road measures detailed evaluations summary. Emission Reduction

Potential (tpd) ID Control Strategy Description VOC NOx

NOx Cost Effectiveness

($/ton)

Voluntary replacement / retrofit program: construction and other off-road

Cofunding measure for off-road engines and equipment –construction and others

N/A 2.5 $5k – $15k

Voluntary replacement / retrofit program: marine

Cofunding measure for off-road engines and equipment – marine

N/A 2 – 4 $3k 5b

Voluntary replacement / retrofit program: locomotive

Cofunding measure for off-road engines and equipment – locomotive

N/A 2 – 3.5 $4k – $7k

8 Government construction incentives

This measure is considered to include money, tax relief, or proposal preference to firms using clean equipment.

N/A 1 $1k – $19k

21, 22, 23, 24, 29,

Promote use of cleaner lawn and garden equipment such as lower-emission four-stroke and electric-powered equipment

A retirement program, for old and malfunctioning lawn and garden equipment, and purchase of low emitting replacements.

0.04 0 $15k – VOC

45, 36,

Development of a Ports Clean Air Action Plan that seeks to minimize emissions port-related operations.

Clean Ports initiative including on-road and nonroad source categories. (Vessel Speed Reduction (VSR), At Berth Control, Low Sulfur Fuel for Marine Vessel Main and auxiliary engines, Engine Improvements) Other off-road measures would follow measures #5b

N/A: VSR

0.2: Berth

N/A: Engine

4: VSR

6.8: Berth

4: Engine

Unknown: VSR

$11k - $80k: Berth Controls

Unknown: Engine

Controls

May 2009


Table 5-3. Weight of evidence measures summary.

ID Control Strategy Description

OR* 21

Continue current passenger vehicle scrappage and buy-back program


OR* 58

Pay-As-You-Drive Insurance (per-mile)


OR* 126 and OR* 148



OR* 67

and OR* 137



OR* 139



OR* 147



NR** 10



i * OR indicates an on-road measure ** NR indicates a non-road measure

May 2009

G:\HGAC\Reports\Final_051109\Sec6_LocalSup_051109.doc 6-1

6. LOCAL SUPPORT FOR IMPLEMENTATION OF MOBILE MEASURES Throughout the development of the final control strategy short lists H-GAC worked with Houston-Galveston-Brazoria area government and business stakeholders not only to develop appropriate control strategies to meet the SIP requirements, but also to recruit stakeholders who would take legal responsibility for implementing these strategies through the establishment of memoranda of agreement (MOA). To this end, H-GAC scheduled and participated in the following meetings with stakeholders:

- October 8, 2008: Stakeholder Meeting with Airports and Airlines, - December 1, 2008: Stakeholder Meeting with Railroads, - December 3, 2008: Stakeholder Meeting with Tug Boat Operators, - December 8, 2008: Stakeholder Public Meeting, - December 15, 2008 Stakeholder Meeting with Construction, - December 15, 2008: Stakeholder Meeting with Ports and Marine, - December 16, 2008: Stakeholder Meeting with Industrial Mobile Source, - December 19, 2008: Conference Call with Airports and Airlines, - January 6, 2009: Stakeholder Meeting with Airports and Airlines, - January 8, 2009: Stakeholder Public Meeting #2, - January 21, 2009: Conference Call with Tug Boat Operators, - January 28, 2009: Conference Call with Tug Boat Operators, - January 28, 2009: Stakeholder Meeting with Harris County Fleet Managers, - January 27, 2009: Stakeholder Meeting with Local Governments, - January 28, 2009: Presentation to Local Military Stakeholders, - February 3, 2009: Conference Call with Airports and Airlines, - February 9, 2009: Presentation to Montgomery County Commissioners’ Court, - February 9, 2009: Conference Call with Airports and Airlines, - February 19, 2009: Presentation to City of Alvin.

Despite these efforts, H-GAC staff has, to date, been unable to secure any MOAs, which would result in further emission reductions from non-road sources. Communications with stakeholders have determined that the cause of this reticence is primarily a result of the current economic climate. Secondarily, many businesses that had voluntarily entered into Memoranda of Agreement in the 2000 SIP believed that they were penalized when the Texas Emission Reduction Program was developed because they had to meet their MOA commitment before they could apply for TERP funding, where others who had not committed initially were able to apply for TERP funding. H-GAC will continue to pursue these agreements to secure emission reductions.

APPENDIX A

Summaries of the Houston-Galveston Area Council of Governments Meetings with the Texas Commission on Environmental Quality and Various Stakeholders concerning the

Houston-Galveston-Brazoria Eight-Hour Ozone State Implementation Plan Master List Control Measures

G:\HGAC\Reports\Final_051009\Appendix A_051009.doc -1

Houston-Galveston Area Council of Governments Meetings with the Texas Commission on Environmental Quality and Various Stakeholders concerning

the Houston-Galveston-Brazoria Eight-Hour Ozone State Implementation Plan Master List Control Measures

MEETING SUMMARIES

Airports/ Airlines Stakeholder Meeting May 22, 2008; held at H-GAC office in central Houston Stakeholders present: Roy Conn (Continental Airlines), Marianne Csaky (Continental Airlines), Dave Walden (Continental Airlines), Jim Parise (HAS), John Hall (consultant) Staff members present: Lola Brown (TCEQ), Theresa Pella (TCEQ), Santos Olivarez (TCEQ), Shelley Whitworth (H-GAC), Graciela Lubertino (H-GAC), Andrew DeCandis (H-GAC), and Kelli Angelone (H-GAC). TCEQ presented information concerning emissions inventories for the airport industry for the years 2000, 2002, and 2005. H-GAC presented information on suggested airport mobile control strategies and also on third-party TERP grants. Comments and concerns included:

1) Questions regarding TCEQ’s methodology for industry growth rates: Federal Aviation Administration possesses 2007 data on the industry and perhaps TCEQ’s data is gleaned from another source. TCEQ promised to send that information out.

2) How could the airports/ airlines industry contribute to air quality improvement? The industry has already made large contributions, especially in the area of fuel conservation.

3) TCEQ asked if military flights at Houston’s major airports were an important issue because their data only covers commercial flights. The consensus was that military flights were mainly from smaller airports and were a minor part of major airport traffic.

4) Some efforts on the part of airports may be hard to quantify. H-GAC recommended sharing information with TCEQ because there may be methods for quantifying those efforts, or ways may be found to do so if the efforts are seen to merit an attempt.

5) Is TxLED already used in off-road emission inventories? It has been established that TxLED or ultra-low sulfur diesel is used by most off-road and on-road equipment because it is widely available.

6) Due to low turn-out on the part of stakeholders at the meeting, it was suggested that H-GAC present the same information at some regular meetings that airport-industry groups hold for themselves. As of 7/15/2008, those presentations have not been given despite efforts on the part of H-GAC and airport-industry groups to coordinate.

G:\HGAC\Reports\Final_051009\Appendix A_051009.doc A-2

Construction Industry Stakeholder Meeting June 3, 2008; held at H-GAC office in central Houston Stakeholders present: Charles Webb (JD Abrams), Jeff Nielsen (HCA), Terry Williamson (Texas Sterling Construction), Bob Lanham (Williams Brothers), Jeff Greene (Durwood Greene Construction), Dale Kornegay (BorTunCo), Peck Boswell (BRH Garver Const.), Herb Young (Smith & Company), AP Boyd (AGC of Texas), Greg Webb (Hi-Way Equipment), Mike Wenske (Hi-Way Equipment), Jim Slack (Slack & Co.), Phillip King (Century Asphalt), Kyle Walker (Valero), Michael DeVita (McCarthy), Jerry Mayer (McCarthy), Dana Blume (POH), Jay Adams (PBS&J), Armando Jaramillo (OldCastle PreCast), David Boehm (NBG Constructors) Staff members present: Santos Olivarez (TCEQ), Lola Brown (TCEQ), Anusuya Iyer (TCEQ), Charles Airiohuodion (TxDOT), Shelley Whitworth (H-GAC), Graciela Lubertino (H-GAC), Andrew DeCandis (H-GAC), and Kelli Angelone (H-GAC). TCEQ presented information concerning the emissions inventories for the construction industry for the years 2000, 2002, and 2005. H-GAC presented information on the suggested construction mobile control strategies and also on third-party TERP grants. Comments and concerns included:

1) Industry representatives asked if the entire Non-Road Draft Master Control Strategies list could work as a VMEP. TCEQ and H-GAC replied that there might be some concerns as to how CMAQ and TERP would be credited, but that it was possible.

2) Any research into technological improvements for the industry need to be short-term research that brought technologies to the general market.

3) The issue of logging hours of actual equipment usage was seen to be a violation of businesses’ privacy and unfavorable for industry; although government groups really need this data to develop more accurate inventories.

4) Selective catalytic reduction was seen as a viable long-term solution which should be investigated.

5) Concern was expressed that the wording of some control strategies implied mandated use of technologies, and it was advised that this might exacerbate the price of fuel-- something industry representatives agreed would be undesirable.

6) Construction representatives were certain that ultra-low sulfur fuels were being used in almost all equipment because that type of fuel is widely available.

Railroad Industry Stakeholder Meeting June 12, 2008; held at H-GAC office in central Houston. Stakeholders present: Mike Clift (BNSF), Nicholas Williams (representing Congressman Nick Lampson), Melissa Hagan (UP) Staff members present: Theo Vosub (TCEQ), Lola Brown (TCEQ), Koy Howard (TCEQ), Donna Huff (TCEQ), Charles Airiohoudion (TxDOT), Shelley Whitworth (H-GAC), Andrew DeCandis (H-GAC), and Kelli Angelone (H-GAC).


TCEQ presented information concerning the emissions inventories for the railroad industry for the years 2000, 2002, and 2005. H-GAC presented information on the suggested railroad mobile control strategies and also on third-party TERP grants. Comments and concerns included:

1) Will the funds from the third-party TERP grant, that H-GAC is going to be awarded, be available for other groups beside the ones that requested it? Parties not listed on third-party TERP grants are still eligible to apply for those funds.

2) Proposal of a control strategy to help railroads in the Houston-Galveston-Brazoria region obtain auxiliary power units would not be helpful because they are only effective for railroads in cold climates.

3) The larger railroads have idle-reduction technologies on almost all of their trains which reduces fuel consumption; so more idling reduction or automatic shut-off technologies would not significantly reduce emissions.

4) Industry representatives commented that TCEQ’s eligibility formulas made it more difficult for railroads to qualify for funding.

5) Most locomotives are retrofitted, and Tier II locomotives are the lowest tier currently available on the market.

First Marine/ Ports Stakeholder Meeting June 12, 2008; held at H-GAC office in central Houston Stakeholders present: Robert Anatra (Ports America), Chuck Graham (Ports America), Matt Chapman (Ports America), Kenneth Kidwell (SSC USA), John Pace (ExxonMobil), Kenneth Gathright (Port of Houston), Bradley Loomis (Port of Houston), Richard Myers (EarthCon), Brad Stoker (WGMA), Nathan Wesely (WGMA), Owen Parker (Dannenbaum), Charles Airiohoudin (TxDOT), Christine Harris (Kinder Morgan), Kevan McGregor (Shell), Jim Guidry (Kirby Corp), Lisa McMicheal (Port of Freeport), Stuart Mueller (Weston Solutions), Harless Benthur (attorney), Sylvia Medina (EECOC) Staff members present: Theo Vosub (TCEQ), Koy Howard (TCEQ), Lola Brown (TCEQ), Donna Huff(TCEQ), Charles Airiohoudin (TxDOT), Shelley Whitworth (H-GAC), Graciela Lubertino (H-GAC), Andrew DeCandis (H-GAC), and Kelli Angelone (H-GAC). TCEQ presented information concerning the emissions inventories for the ports industry for the years 2000, 2002, and 2005. H-GAC presented information on the suggested ports mobile control strategies and on third-party TERP grants. Comments and concerns included:

1) TxLED or ultra-low sulfur diesel may be the only type of fuel available to those in the ports industry, rendering that suggested control strategy obsolete unless it needs to be documented.

2) General concern was expressed regarding the clarity of the control strategies and industry’s ability to provide meaningful comment. H-GAC has since then ‘cleaned up’ and offered further guidance and description on the control strategies list.


Second Marine/ Ports Stakeholder Meeting June 19, 2008; held at H-GAC office in central Houston Stakeholders present: Mark Rodriguez (TxDOT Ferry), Addie Wiseman (AWO), Kenneth Gathright (Port of Houston), Bob Fry (MegaFleet), Shelby Startz (Jacinto Port), Blake Beall (Kirby Corp), Amy Husted (Kirby Corp), Tom Tray (Bay-Houston Towing) Staff members present: Theo Vosub (TCEQ), Donna Huff (TCEQ), Shelley Whitworth (H-GAC), Graciela Lubertino (H-GAC), Andrew DeCandis (H-GAC), and Kelli Angelone (H-GAC). TCEQ presented information concerning the emissions inventories for the ports industry for the years 2000, 2002, and 2005. H-GAC presented information on the suggested ports mobile control strategies and on third-party TERP grants. H-GAC mentioned that the marine sector had the largest projected growth in regional NOx emissions. Comments and concerns included:

1) Industry representatives asked TCEQ if aggregated ship data was available. They wanted to know if data was available broken down into inland vessels and ocean-going vessels. TCEQ said they would look into it.

2) There was concern that projected growth data from the ports would be skewed because most industry growth would be on the trucking side. H-GAC wondered if projected growth was still available because that data would be helpful for inclusion in the emissions inventories.

3) One example put forth by H-GAC as an emissions reduction technology was ship stack scrubbers. Industry representatives said that was a good example but scrubbers do not reduce NOx particulate matter.

4) Industry representatives mentioned the California law governing foreign ocean-going vessels and their emissions was overturned by the Supreme Court.

5) Two control strategies industry inquired about were the “California Marine Vessel Main and Auxiliary Engine Rule” and the “California Harbor Craft Rule”. H-GAC explained that these were included by TCEQ at a previous meeting. It was added that industry might want to enter into a Memorandum of Agreement or Memorandum of Understanding with H-GAC concerning one or both of these strategies, but that they were not being proposed to industry as strategies to implement as mandates.

Small Local Government Stakeholders Meeting July 22, 2008; held at H-GAC office in central Houston

Stakeholders present: Barry Brock (City of Humble), Don Brandon (Chambers County), Marie Herndon (City of Prairie View) Staff members present: Brian Christian (TCEQ:SBLGA), Theresa Pella (TCEQ), Dick Karp, (TCEQ), Lola Brown (TCEQ), Clarence (TCEQ:SBLGA), Shelley Whitworth (HGAC), Graciela Lubertino(HGAC), Andrew DeCandis(HGAC), Kelli Angelone (HGAC) TCEQ presented information on the components of the SIP, discussed the process by which ozone is formed, and outlined the method of photochemical modeling that is used in the HGB nonattainment region. TCEQ also gave a presentation about the purpose and services available


for local governments and small businesses through the Small Business/ Local Government Office (SBLGA) of TCEQ. H-GAC presented information on the role of H-GAC in the region and its responsibilities on the development of the SIP, the regional transportation plan, and the link between both of them. Comments and concerns included:

1) What does the 96 ppb design value mean? The 96 ppb is the average ozone concentration measurement over 3 years for the highest monitoring site in the Houston area (Bayland Park).

2) Is Waller County listed as nonattainment? Waller County is listed as nonattainment because it is in the HGB region and closely tied economically and geographically to the counties, such as Harris County, which contain the majority of the monitors in violation of the standard.

3) To be in attainment the region must be below the 85 ppb standard, so 84 ppb is attainment.

4) Has TCEQ taken into account noncompliance with government law in the SIP? Yes. The paperwork involved with the SIP would not change as people come into compliance, only the monitors would be affected.

Industrial Mobile Sources Stakeholders Meeting August 13, 2008; held at H-GAC office in central Houston

Stakeholders present: Perry Galloway (NRG Texas), Robert Anatra (Ports America), Matt Chapman (Ports America), Julie Woodard (Dow), Judy Bigon (ExxonMobil), Elena Craft (ED), Roy Conn (Continental), Catarina Cron (Harris County), Dana Blume (POH) Staff members present: Theresa Pella (TCEQ), Anusuya Iyer (TCEQ), Shelley Whitworth (HGAC), Graciela Lubertino(HGAC), Andrew DeCandis (HGAC), Ben Finley (HGAC), Kelli Angelone (HGAC) TCEQ presented an inventory update for industrial mobile non-road sources and the timeline for SIP submission. For the industrial equipment emission estimations, the inventories take into account EPA programs and regular fleet turnover; so accelerated turnover due to legislation and other programs are part of the estimates. The estimations for non-road fleets include several inputs, extrapolations, and TCEQ field work survey for the industry. The ‘Industrial Mobile’ portion of Non-Road emissions is 13.3%. Forklifts account for about 98% of the whole equipment for Industrial Mobile Non-road, and about 54% of them are electric and 45% are diesel. HGAC presented an overview of SIP control strategy development for on-road and non-road sources, a third party TERP update, and the timeline for the development of the mobile source control strategies for the SIP. HGAC cannot mandate reductions and must rely on voluntary emission reductions to meet the SIP requirements. One advantage during this SIP timeframe is that TERP is committed to being in place throughout the process. MOUs are voluntary and reflect only what a company thinks it can achieve, not what they are unwilling to commit to.


Comments and concerns included:

1) Industrial representatives asked about the information sources for the inventories generation, to which TCEQ answered that they got most of the information from the Industrial Truck Association and from phone surveys we conducted.

2) TCEQ does not know if “gators” and golf carts are counted (mostly gasoline engines), but they will find out.

3) TCEQ stated that the distribution industry is counted as part of this inventory 4) TCEQ will send out the study that was done on ‘Industrial Mobile’ since that would

contain a lot of answers, including how many 2- and 4-stroke engines there are. 5) What are the consequences for not meeting the MOU agreement?

With these MOUs, we hope to give businesses some recognition for what they are doing. If the MOU is entered and not met, it may reflect back on that company. Other than that, consequences are for us – we have to figure out how to make up those reductions with another of our programs.

6) Are there any other control strategies for ‘Industrial Mobil’ besides electric forklifts? There are control strategies that involve cleaner fuels or clean construction for those of you that may be developing new properties, but other than that, we are looking to you to tell us what you can do.

7) If voluntary reductions are only allowed to be 3% of the reductions. Where are the rest of the reductions coming from? The rest are coming from regular fleet turn over and new standards coming for vehicles, ships and equipment.

8) Has HGAC been involved with other grants like DERA? There is concern that with the new regions that will be drawn by EPA and TCEQ TERP will be spread too thin. HGAC employs other funding sources such as SEP and CMAQ, but we agree, it is important to have other sources of funding, but we missed the proposal deadline for DERA. It’s important to remember that agencies such as HGAC must also find places to supply administrative funding as well, which is a huge challenge in itself.

9) Can private industry make use of TERP? H-GAC is planning to help with TERP funding by using the third-party agreement.

10) What about the requirement in TERP about destroying vehicles? It is a lot of capital to lose and turn over in a short time (TERP requires you buy new vehicles and destroy the old vehicles within 90 days). If you are interested in committing to accelerated fleet turnover, we cannot help you fund it if you do not destroy the engines or vehicles, but if you commit to an MOU, you may be able to send the old vehicles (minus the engines) out-of-region or out-of-state and get funding through CMAQ.

APPENDIX B

Written Comments from Stakeholders and their Respective Responses Regarding Master List Control Strategies

G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-1

The comment periods for the Draft On Road Control Strategy List and the Draft Non Road Master Control Strategy List was Friday, May 23, 2008 to Tuesday, August 5, 2008. Written comments were received by: Mail: Transportation Department, Air Quality Section, Houston-Galveston Area Council

P.O. Box 22777 Houston, Texas 77227-2777

E-mail: [email protected] Fax: (713) 993-4508 H-GAC received a total of 17 written comments. H-GAC has separated the written comments into two sections: 1. Rail Issues, Marine and Port Issues, and Special Interest Groups

1. BNSF Railway Company 2. Earthcon Premier 3. Port of Houston Authority 4. Sierra Club

2. Association of General Contractors

1. Angel Brothers Enterprises, Ltd. 2. Balfour Beatty Infrastructure Inc. 3. Beyer Construction, LLP 4. Cravens Partners, Ltd. 5. E.P. Brady, Ltd. 6. Highway Pavement Specialties, Inc. 7. J.D. Abrams, L.P. 8. NBG Constructors 9. Pavers Supply Company 10. Prime Eco Group 11. Smith & Company 12. W.W. Webber, LLC 13. William Brothers Construction Company, Inc.

Each comment in the Rail Issues, Marine and Port Issues, and Special Interest Groups section is shown in its entirety. Each comment is followed by the response given. Each comment in the Association of General Contractors section included the same “Comments on Draft Off Road Strategies” table. This table has been removed from each comment, and is displayed in B.2.14. Because comments in this section address the same issues, the same response was given. This response is displayed in B.2.15.


B.1.1.1 Comment from BNSF Railway Company

Comments on Non-Road NOx Reduction Strategies 8 Hour Ozone Attainment SIP Revision

Houston-Galveston Area Council July 15, 2008

BNSF Railway Company 4200 Deen Road

Fort Worth, Texas, 76106

HGAC ID Number 30 – Use of APUs for locomotive operations to reduce idling Note that auxiliary power units (APUs) are best suited for use in colder climates. BNSF typically deploys the APU units on switch engines that operate in areas such as Chicago and Denver. For example, the EcoTrans K-9 APU is used to provide electrical power to immersion heaters for lube oil and the main engine water. The south Texas climate would minimize the use of the APU. In the colder, winter months, the APU would operate as designed. However, for most of the year, the locomotive lube oil, diesel fuel and cooling water would never get cold enough for the APU to run. BNSF has an aggressive program of adding idle reduction kits to the switch engines in the Houston-Galveston (HG) area. Currently, 15 switch engines have ZTR SmartStart units installed. The SmartStart unit monitors the “health” of critical locomotive systems such as battery charge and water coolant temperature. If the SmartStart unit determines that the locomotive is idling and can be restarted, the engine is shutdown. Unlike the APU, if the temperature drops and the lube oil and coolant water also cool below a set temperature, the main engine is restarted instead of using a smaller engine to provide auxiliary electrical power or heat. As information, all new line haul locomotives that BNSF is purchasing come with idle reduction technology installed at the factory. All of the switch engines purchased under the TERP are equipped with idle reduction technology. HGAC ID Number 31 – Accelerated Purchase of Tier II Locomotives Since these NOx control measures were developed by HGAC, the EPA has passed new locomotive emission rules. Starting in 2009, the phase-in of Tier 3 locomotives will begin. Tier 4 locomotives, employing catalytic after treatment technology for exhaust gases, will be phased-in beginning in 2014. BNSF has been aggressively purchasing new, more fuel efficient locomotives. As new locomotives enter the fleet, older units are removed from service. At the end of 2007, BNSF had 989 Tier II locomotives in its fleet. The annual purchase plan for new locomotives is approximately 300 per year. BNSF has spent billions of dollars modernizing its locomotive fleet over the last five years.


H-GAC ID Number 32 – Electrification of Rail Switching Yards The electrification of rail facilities is not practical for several reasons. First, the cost of undertaking such an effort would require massive expenditures of capital on construction and equipment acquisition. There are currently no Class I railroads in the United States that move freight using electricity off of the grid. Second, there is no large scale production of high horsepower locomotives that use external electrical power. Lastly, the implementation of this strategy would take many years to fully implement. HGAC ID Number 33 – Efficiency Improvements on In-Use Class 1 Rail Equipment BNSF requested further clarification from HGAC on this implementation strategy and never received a reply. HGAC ID Number 34 – Limitation on Idling of Locomotives Comments were provided by BNSF to the TCEQ on proposed locomotive idling regulations in 2005. See the attached document for specific comments on this NOx reduction strategy.


COMMENTS OF THE THE BURLINGTON NORTHERN AND SANTA FE RAILWAY

COMPANY on

TCEQ’s Proposed Rules 114.520, 114.522, 114.526 and 114.529

Rule Project Number 2005-006-114-AI Submitted to the

Texas Commission on Environmental Quality January 6, 2005

The Burlington Northern and Santa Fe Railway Company (BNSF) is pleased to submit these comments on the above-referenced proposed TCEQ rules and revised State Implementation Plan narrative. The proposed rules were issued by the TCEQ on November 17, 2004. BNSF has approximately 70 switch locomotives operating in the Dallas / Forth Worth (DFW) area which would be subject to the regulation. We applaud TCEQ, the Council of Governments, and the business community for all the efforts to reduce emissions and improve air quality. Our corporate headquarters is located in this region and thousands of our employees live in the DFW area. BNSF has several concerns regarding the effective implementation of the rules as they are currently drafted. The concerns include rail safety issues, employee productivity, preventing locomotive freezing, unnecessary requirements when we already are reducing emissions, and extreme recordkeeping requirements. The ramifications of a restriction for switch engines limiting idling to no more than 15 minutes are much greater than might be imagined to those unfamiliar with railroad operations. A locomotive is quite unique compared to trucks or construction equipment which also can idle considerably. Safety of BNSF Employees and the Public The Federal Railroad Administration (FRA) requires that the braking system on all trains be tested before they are cleared to leave a yard. The braking system on the railcars is operated by the presence of high pressure air. This high pressure air is supplied by a compressor that is powered by the locomotive engine. Depending on the length of train, it could take at least an hour of engine idle time to generate enough air pressure to fully charge the braking system. To comply with FRA requirements, and provide for the safety of BNSF employees and the public, it is critical that the switch engine idle more than fifteen minutes to allow the braking system to be properly tested. In addition, if the air pressure in the system were to bleed off when the locomotive is standing with a group of cars and shut down waiting for the track to clear, the brakes could release allowing the train to roll into the path of other trains, cars or locomotives. Every time that a switch engine is shutdown, BNSF policy requires that the locomotive be “tied-down.” This is done by setting the handbrake on the switch engine. If the switch engine is coupled to any railcars when it is shutdown, the handbrakes on several of the cars must also be engaged. This is a laborious process that involves spinning a large wheel that activates the brakes. When the switch engine is started again for movement, the process has to be reversed. The increased physical exertion on employees required to set brakes dozens of times during an eight hour shift could possibly lead to safety concerns.


During periods of cold weather, it is necessary to run the cab heater to provide warmth for employees. The cab heater operates off of power and heat provided by the main engine. Obviously, if the switch engine has to be turned off when occupied, the employees will not have a source of heat. This scenario presents unnecessary discomfort and danger during periods of abnormally cold weather. Reduced Rail Facility Productivity As was shown above, the act of shutting off a switch engine is not as simple as pressing a button and “walking-away.” Even the smallest engines exceed 1500 horsepower. These engines are difficult to start. An intricate set of procedures is in place to start and stop the engine so that the switch engine is safe when shut off and that it will restart when needed. The procedure that is in place at BNSF to turn off a locomotive has approximately five steps. Specific switches and circuit breakers must be turned off and isolated while others must be left on or closed. According to BNSF operating personnel, running through this shutdown procedure takes approximately 15 minutes per engine. Most switching is done with two locomotives, so each required shutdown would take approximately 30 minutes. The EPA standard duty-cycle for a switch engine assumes that approximately 50% of the engine working time is at idle. Most rail facilities typically never close and the switch engines operate 24 hours a day. If 12 hours of the typical working day is spent at idle, the crews manning the switch engines will be required to perform the shutdown procedure dozens of times per day, causing significant delays to the movement of freight. Trains that operate on our network have critical, highly sensitive time schedules that require strict adherence. This allows BNSF to maximize the utilization of its infrastructure and train crews. If a train can not leave a terminal due to congestion caused by slow railcar switching, a cascade of events occurs, which can cause a whole segment of track to become less efficient. For example, a locomotive on a train from Ft. Worth may be assigned to another train leaving Amarillo when it arrives. If the train from Ft. Worth is late leaving, it can also cause the train originating in Amarillo to be late. You can easily see how slowing efficiency at one yard begins to affect efficiency and time schedules across the system. Under the proposed rules, the rail facilities in the DFW area will likely become less efficient. As a result, more switch engines will likely have to be used to perform the same level of work before the implementation of the proposed rules. This will have the adverse effect of negatively impacting air quality in the DFW non-attainment area, and actually increasing locomotive emissions instead of decreasing them. Locomotive Freeze Protection Unlike most internal combustion engines, locomotive engines do not use antifreeze compounds in their engine cooling systems. This is due to the high heat load that must be efficiently transferred from the engine to the cooling water during use. Because of this, locomotive engines are typically left idling during cold weather. If the engine were to stop during cold weather, the engine block could freeze, causing significant damage. Because of this, locomotive engines are equipped with an automatic dump system for the radiator water when it nears the freezing point.


All new line-haul locomotives come equipped with automatic start and stop equipment that is designed to keep the engine and fluids warm while minimizing idle time. We have retrofitted more than 1700 high horsepower General Electric locomotives with automatic start-stop equipment. This will reduce the amount of time our road fleet will idle in yards and at locomotive servicing facilities. However, due to the age of the locomotives, most existing switch engines do not have this equipment. BNSF is addressing this issue by adding after market idle control technology to a number of switch engines. TERP Funded Idle Reduction Equipment BNSF applied in 2003 for funding under the Texas Emissions Reduction Program (TERP) for the installation of idle reduction technology on approximately 30 switch engines in the DFW area. The application was successful and $333,000 was granted. The switch engines are being equipped with the ZTR SmartStart system. With this technology, several critical locomotive operating parameters, such as air pressure and cooling water temperature, are continuously monitored by the ZTR system. If all of the parameters are within an acceptable range, the locomotive is automatically shutdown during idle. If during the shutdown mode, one of the operating parameters falls below an acceptable limit, the locomotive is automatically restarted. This system does not have any auxiliary heating system to add heat to the locomotive fluids or the cab and will not shut down locomotives during cold weather. If BNSF is forced to shutdown all switch engines after only 15 minutes of idle time, the effectiveness of the TERP funded ZTR systems is going to be negatively effected. The ZTR units that are currently being installed are programmed to conduct an auto stop of the switch engine at 20 minutes of idle time. While the switch engines are in the yard working, it is not anticipated that many auto stops will be initiated. This technology primarily addresses unnecessary locomotive idling that occurs. Increased Recordkeeping Requirements The recording of every shutdown event for every switch engine will be extremely burdensome. This additional recordkeeping reduces the productivity of our train crews. The proposed shutdowns will require the development of forms, either single event records or daily logs that will have to be managed, collected, reviewed and stored. There was no indication if anyone outside of the railroad would ever see these forms or logs. This brings into question the value of collecting this information. If this information really is necessary, a less intrusive and disruptive method must be found. Other Locomotive Emission Reductions BNSF is reducing emissions in other ways which should be counted in the SIP. For example, BNSF has retrofitted 952 older locomotives to Tier 0 levels. This reduces the nitrogen oxide emissions by 33 percent from the uncontrolled levels. BNSF has also purchased four Green Goat hybrid switch engines for use in the DFW area. These were purchased with TERP funding and BNSF has agreed to operate these units in the DFW area for nine years. We also purchase low torque bearings for our railcars. This reduces train resistance and thereby reduces emissions from the engine. Conclusions


BNSF is aggressively addressing emissions from switch engines in the DFW area. Approximately 30 switch engines are having ZTR SmartStart idle reduction units installed. This equipment is designed to identify unnecessary idling of the switch engine, check its operational status, and safely shut it down. BNSF has also invested in new road locomotives with automatic engine start/stop features. Some of these locomotives will be used in and through the DFW area. BNSF, with assistance through the TERP, will bring four hybrid switch engines into use in the DFW area, which will lead to eliminating four older traditional switch engines. With these technological improvements and additions, Appendix K could be unnecessary as it pertains to BNSF and most likely the rest of the rail industry in the DFW area. BNSF has a good working relationship with TCEQ and the USEPA. We are available to further discuss these comments with TCEQ and look forward to working with you on this issue.


B.1.1.2 Response to BNSF Railway Company August 29, 2008 Michael Clift Manager Environmental Operations BNSF Railway 4200 Deen Road Fort Worth, TX 76106 Dear Mr. Clift: Thank you again for your comments regarding the mobile source control measures for the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP). We have considered your comments and would like to take a moment to respond to your comments directly. Your letter expressed comments on the following control measures:

• Non-road Measure 30 – Use of APUs for locomotive operations to reduce idling: Thank you for bringing this to our attention. We will address this issue when creating a more refined version of this control strategy list in the latter part of this year.

• Non-road Measure 31 – Accelerated Purchase of Tier II Locomotives: H-GAC thanks you for your continuing work to replace older locomotives with models which include newer and cleaner engines.

• Non-road Measure 32 – Electrification of Rail Switching Yards: Thank you for bringing this to our attention. We will address this issue when creating a more refined version of this list in the latter part of this year.

• Non-road Measure 33 – Efficiency Improvements on In-Use Class 1 Rail Equipment: H-GAC has worked to clarify all of the control strategies by increasing the specificity of the control strategy descriptions and to add comments to provide additional information about each strategy.

Control Strategy Description Comment

Efficiency improvements on In-Use Class 1 Rail Equipment (R11)

This measure would improve rail connections, eliminate at grade road and rail crossings.

Rail improvements might be considered if it can be shown that locomotive idling or braking events can be reduced. Usually these improvements also have safety and congestion relief benefits.

• Non-road Measure 34 – Limitation on Idling of Locomotives: H-GAC analysis has determined that this measure is similar to Non-Road Measure 30. We need some further analysis to be able to determine if Measure 34 will already be counted on 2018 inventories. This analysis will be made during the latter part of this year.


Throughout the latter part of 2008, H-GAC will work to quantify and refine this Master List into a Short List of measures which the Houston-region will recommend to TCEQ for implementation in early 2009 as part of the SIP. You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx

Additionally, we encourage you to become more involved with the SIP process. We are actively recruiting regional businesses that are willing to make their own commitments to reduce air pollution within the Houston-region through voluntary commitments. I am happy to provide more information about the form and scope of these commitments by phone (713-499-6695) or email ([email protected]).

Sincerely, Shelley Whitworth Air Quality Program Manager


B.1.2.1 Comment from Earthcon Premier Good afternoon; Following the Emissions Reduction Strategies for the Marine Industry meeting held at H-GAC on June 12, 2008 we discussed briefly the criteria for emission reduction strategy viability according to EPA. We submit the Marine Exhaust Scrubber (exhaust gas cleaning system) for inclusion in the list of SIP control strategies. This technology was developed with assistance from a US Environmental Protection Agency (EPA)/West Coast Collaborative grant and a contribution from the Puget Sound Clean Air Agency. Major support also came from the Vancouver Port Authority, Environment Canada, British Columbia Ministry of the Environment, the B.C. Clean Air Research Fund, and the Port of Seattle. Use of this technology can reduce sulfur emissions by 99.9% and particulates by 85%. It is capable of reducing these pollutants to a greater degree than using low sulfur (0.10%) marine diesel oil. In April of this year, the International Maritime Organization (IMO) through its Marine Environment Protection Committee, adopted guidelines for exhaust gas cleaning systems. We submit that these guidelines should be considered by the State of Texas to be applicable to any Marine Exhaust Scrubber cleaning system included in the list of control strategies. Kindly call or write me with any questions or for additional information. Richard R. Myers, J.D. Senior Consultant EarthCon Premier 600 Kenrick, Suite C-32 Houston, Texas 77060 phone (281) 591-0611 fax (281) 591-0636 cell (713) 256-0461 [email protected]


B.1.2.2 Response to Earthcon Premier August 29, 2008 Mr. Richard Myers EarthCon Premier 600 Kenrick, Suite C-32 Houston, TX 77060 Dear Mr. Myers:

Thank you again for your comments regarding the mobile source control measures for the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP). We have considered your comments and would like to take a moment to respond to your comments directly.

Your comment recommended that H-GAC consider adding marine exhaust cleaning systems such as scrubbers to the list of SIP control strategies. We have considered your request and have added this measure to the Final Master List which is being submitted to TCEQ.

Throughout the latter part of 2008, H-GAC will work to quantify and refine this Master

List into a Short List of measures which the Houston-region will recommend to TCEQ for implementation in early 2009 as part of the SIP. Please note that though this measure has been added to the Master List, there is no guarantee that it will remain as part of the Short List. You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx

Additionally, we encourage you to become more involved with the SIP process. We are

actively recruiting regional businesses that are willing to make their own commitments to reduce air pollution within the Houston-region through voluntary commitments. I am happy to provide more information about the form and scope of these commitments by phone (713-499-6695) or email ([email protected]).



B.1.3.1 Comment from Port of Houston Authority August 12, 2008 VIA EMAIL Houston-Galveston Area Council 3555 Timmons Lane, Suite 120 Houston, Texas 77027 Attn: Shelley Whitworth, [email protected] RE: Port of Houston Authority Comments on H-GAC Master List of Non-Road Control Strategies for 8-Hour Ozone Plan Dear Shelley: The Port of Houston Authority (Port Authority) appreciates the opportunity to provide comments to H-GAC on the Master List of Potential Non-Road Emission Control Strategies for the 8-hour Ozone Plan. The Port Authority understands the magnitude and importance of emission reductions from all sectors to ensure air quality improvements for our community, region and state. The Port Authority was an active participant in assessing and assisting with the creation of the 1-hour SIP and is dedicated to working with H-GAC and TCEQ on the development of the 8-hour SIP. General Overall Comments The Port Authority wants to emphasize that considerable time and resources are necessary to perform technical, feasibility and cost analysis, as well as engage appropriate stakeholders in meetings and perform studies to ensure that measures adopted are accurate and well suited for the region’s needs. Given that the timeframe for H-GAC is compressed and will require many meetings with appropriate stakeholders, the Port Authority wants to emphasize that it is more important to ensure control measures are well thought out and understood prior to selection. The Port Authority encourages emission reductions through voluntary measures and continues to be supportive of the TERP program. Specific Listed Control Measures Below are some specific comments on control measures identified by H-GAC in the short list. These comments are based on what the Port Authority gleaned from the description provided in the spreadsheet and through a limited amount of research conducted to further investigate these measures. The Port Authority supports many of the control measures H-GAC identified, especially as voluntary measures that would be eligible for TERP funding; however, some could have significant operational, technical, or legal impediments for successful implementation. Listed below is a brief summary of the Port Authority’s comments or concerns. #28/5 - Enhanced Texas Emission Reduction Program (TERP) The Port Authority is highly supportive of an enhanced TERP program. The Port Authority has participated in several TERP projects and will continue to participate in such projects in the future. The Port Authority believes this program is the most successful method at finding cost-effective emission reductions for non-attainment regions. The Maritime Industry has had


excellent participation in the grant program and continues to apply for and receive grants. The Port Authority would encourage further development of this program to create a more user-friendly application and reporting process for all interested parties. The Port Authority would encourage further enhancements of the TERP program to address the limitation of this program’s success. Those enhancements need to take into account statutory limits on emission thresholds for technology, the EPA technology certification process, and limitations in the manufacturing industry and funding process of the program. #31 – Accelerated Equipment Turnover; Tier 2 or Tier 3 Non-road Engines The Port Authority has been accelerating equipment turnover through its own initiatives through the purchase of Tier II equipment at the Barbours Cut and Bayport Container Terminals. The Port Authority supports the accelerated purchase measure as a voluntary program, which would be eligible for TERP. If this measure is adopted as a mandatory program, the measure could face numerous legal and practical hurdles. The cost of completely replacing older equipment could be significant to some port users and could impact competitiveness if this measure is only adopted in the Houston region. The Clean Air Act expressly prohibits state or local rules that impose emissions control standards on new non-road engines. The Act implicitly extends this preemption to all other non-road engines (new and old), and provides that only California may apply to EPA for authorization to adopt and enforce standards or controls (at least as protective as federal standards) governing such engines or equipment. A state with an approved non-attainment plan may thereafter adopt standards identical to California’s, after notice to EPA and a statutorily required two-year lead-time before the standards take effect. The accelerated purchase rule has already been held to violate the federal preemption clause. The TCEQ adopted the same control measure for the 1-hour SIP. The rule was challenged by the Engine Manufacturer’s Association in the U.S. District Court for the Western District of Texas (Engine Manufacturers Association v. Robert J. Huston,190 F. Supp. 2d 922(W.D. Tex. 2001)). The court struck down the accelerated purchase requirements (and the morning hour construction ban), holding that the CAA deprives the state of jurisdiction over such matters. At the same time, the rules were replaced legislatively with TERP. The case was voluntarily dismissed. If the accelerated purchase rule were adopted again, the rule would likely be challenged in the same court. One of the original plaintiffs could also file a Rule 60(b)(6) motion in District Court for reconsideration of the dismissal—premised on TCEQ’s return to the prohibited conduct that it voluntarily dismissed. In a later and significantly relevant court decision, the U.S. Supreme Court overturned local air rules that would have required certain private fleet operators in the greater Los Angeles area to purchase or lease low-emitting or alternative-fuel vehicles when adding or replacing fleet vehicles (Engine Manufacturers Association v. South Coast Air Quality Management District (SCAQMD), 541 U.S. 246 (2004)). The primary distinction in this case is that the fleet rules applied to newly acquired, on-road vehicles (there was not a requirement to accelerate the retirement and replacement of older, more polluting vehicles). The Supreme Court concluded that the rules were emissions standards and preempted under the Clean Air Act. The Court was not willing to draw a distinction between regulations that compel manufacturers to meet new emissions limits (e.g., mandate the sale or production of certain types of vehicles or engines) and those that affect only the purchase of vehicles. Indeed, the Court held that a “standard” under CAA Section 209 is any mandate governing the emissions characteristics of an automobile.


Engine and Fuel Technology Control Measures #45/11 – Water Injection for Diesel Engines #46/12 – Alternative-Fueled Equipment for All Equipment Types #47/13 – Alternative Fuel Heavy-Duty Equipment #48/14 – Lean NOx Catalyst #49/15 – Early Introduction of Low-NOx Engines #50/16 – Selective Catalytic Reduction (SCR) #55 – Reformulated Fuels for Off-road Vehicles

The Port Authority is supportive of engine and fuel technology control measures as a voluntary program. Many of the measures listed above would be eligible for TERP grants once the technology has been verified or certified by CARB or EPA, respectively. Further research and information is necessary to fully assess the extent of each of these proposed measures on port operations. The Port Authority uses alternative fuel in much of its small engine equipment; however, alternative fuel vehicles are not available for larger engine sizes. Below is a California Air Resources Board (CARB) list of CARB certified alternative fueled off-road engines.

Since alternative fueled engines are not available in larger engine sizes, the use of such engines is restricted to equipment such as forklifts and yard hustlers. Although alternative fueled engines for yard hustlers are available, the Port Authority understands that the technology does not make practical sense for this application. Using an alternative fueled yard hustler requires more frequent refueling, adds significant cost for the equipment and fuel, requires additional infrastructure, increases maintenance costs, and does not provide a significant emissions benefit compared to the emission reductions from new cleaner diesel equipment. According to a California Air Resources Board report, the cost of using LNG is 20% higher than diesel, the equipment costs approximately $40,000 more per unit, the extra maintenance cost is about $2,000 to $4,300 more, and a new LNG terminal dispensing about 16,000 gallons costs approximately $700,000. CARB provided the following conclusion in its assessment of an alternative fuel requirement: “The possible higher cost of the alternative fuel and alternative fuel infrastructure, along with cleaner diesel engines which are near to the emissions of alternative fuel engines, favors selection of alternative fuels on a case-by-case basis instead of a general mandate.” See http://www.arb.ca.gov/regact/cargo2005/appf.pdf. In addition to alternative fueled equipment, the Port Authority has conducted a demonstrative study on selective catalytic reduction (SCR) technology. The Port Authority would like to express its concern over this control strategy due to the following:

• There is currently no EPA verified SCR technology for large size engines and the technology has only been verified on one smaller engine


• Port Authority’s demonstration project with an SCR on a 535 horsepower rubber tire gantry (RTG) was terminated due to nonperformance of the SCR and exceptional costs of installation and operation;

• A significant legal impediment exists regarding the adoption of a NOx reduction systems; and

• The compatibility of NOx reduction systems with other control strategies such as diesel emulsions, fuel additives, etc. has not been evaluated.

It is the Port Authority’s understanding that only one SCR has been verified to date —and that verification only applies to one engine size. The SCR is manufactured by Extengine. It is unlikely that EPA would accept a control measure with a technology that has not been verified by EPA or CARB. In addition to the lack of verification, the Port Authority has significant reservations about the viability of SCR on equipment operating with transient loads. The Port Authority’s experience with an SCR was burdened with significant operational problems. On the piece of equipment that was tested, an RTG crane, the SCR did not inject urea during any idling of the engine or when the engine temperature changed during the loading cycle. Since the SCR is temperature dependant, an emission reduction was difficult to determine during the in-situ testing program. Other factors that contributed to the SCR technology being deemed infeasible were the costs of installation, stainless steel piping, replacement of injectors, and urea. In addition to technical problems, HGAC and TCEQ are likely to experience a legal impediment in mandating the use of NOx reduction systems. Section 209(e) of the Federal Clean Air Act preempts states (except California) from adopting engine standards for offroad vehicles as discussed above. See EMA v. SCAQMD, 541 U.S. 246 (2004); Engine Manufacturers Association v. E.P.A., 88 F.3d 1075 (D.C. Cir. 1996); Engine Manufacturers v. Huston, 190 F.Supp.2d 922 (W.D. Tex. 2001). Based on the case law on this issue, it is apparent that a control measure requiring an equipment operator to achieve a certain emissions level by using an SCR or other type of emission control device is likely preempted. Construction Contract Control Measures

#35 – Conditions of Approval for New Construction #37 – Control Clauses for Construction Contracts #38 - Contract Bidding #39/8 - Government Construction Incentives #41/9 – Develop Air Quality Best Management Practices

The Port Authority already includes extensive environmental conditions in its new construction contracts. The Port Authority has spent millions of dollars to minimize air quality construction impacts. Some of the best management practices have included clean engine technologies, cleaner fuels/additives, extensive dust suppression requirements, innovative construction techniques, monitoring, recordkeeping, reporting, and fueling requirements. In addition to using contractual requirements, the Port Authority assesses air quality impacts from contractors through the use of a NOx Calculator on the Port Authority’s federal permitted projects. Contractors assess air quality impacts and provide proposed mitigation measures on projects via the NOx calculator. The Port Authority procures contracts through competitive sealed proposals and air mitigation efforts are part of that process.


The Port Authority believes its own procurement program is successful in providing an incentive to reduce emissions from construction project activities. For this reason, the Port Authority would request the flexibility to retain its own program, instead of simply adopting the TxDOT program. #42/10 – Limitations on Idling of Heavy-Duty Construction Equipment The Port Authority supports and actively participates in an idling limitation in its large construction contracts, as well as its own voluntary idling program. Tenants and users are informed of the need to reduce idling through signs, tenant audits, and stakeholder meetings. The Port Authority is currently evaluating the development of its’ own idling policy which will include internal enforcement mechanisms. The Port Authority supports voluntary idling reduction efforts and would potentially support a mandatory rule enforced by TCEQ or another regulatory agency—so long as the scope would not unduly restrict operations. Further information and assessment is necessary on this measure to provide more meaningful comments. Control Measures adopted from California Rules #87/35 – ARB Portable Engine Registration and Rulemaking The California Air Resources Board’s (CARB) Portable Engine Registration program is a voluntary program. The Port Authority generally supports voluntary programs, however, the Port Authority is unsure of the environmental benefit of such a program compared to the cost. The Port Authority is also unsure of the willingness of companies to participate. Essentially the CARB Portable Engine Program operates like a permit—requiring portable engine owners to comply with certain emissions specifications, reporting, recordkeeping, and other requirements. Complying with these requirements allows the portable engine owner to operate in all of the air quality districts in the State of California without being subjected to individual air quality district rules. It is unlikely that a significant number of portable engine owners in Texas will voluntarily enter into this program considering the significant administrative requirements. Even if a significant number entered into the program, it does not appear that the State of Texas has the resources to administer such a paper intensive permitting requirement for small sources. The CARB program, for example, requires owners to notify the agency every time the equipment is being moved to a new area. Currently TCEQ allows portable engines to operate under a permit-by-rule if certain criteria are met. The permit-by-rule ensures that portable engine owners comply with air quality standards without subjecting the owners (and the agency) to unduly burdensome administrative exercises that do not provide significant environmental gains (since the sources are generally small). As with other sources that have small emissions and can move from place-to-place, the most efficient and effective means to reduce emissions is generally through better emission standards at the manufacturer level. In addition, the legal use of such a rule is subject to the Clean Air Act Section 209 (e) preempting Texas from adopting mandatory portable engine controls for non-road sources and preempts user-based standards. This control strategy would need to be adopted “as is” from California’s voluntary program.


#88/36 – California Auxiliary Engine Rule The Port Authority is aware that California is currently considering a rule requiring ocean going vessels to use cleaner fuel in auxiliary engines (or an equivalent method of control). While the Port Authority is supportive of the voluntary use of cleaner fuels across all sectors, the Port Authority has potential concerns about the viability of the rule as a mandatory and voluntary measure—especially if the rule is intended to meet Houston’s SIP deadline. The Port Authority believes there has not been enough due diligence nor will there be enough time to conduct the proper due diligence over the next several months to adequately study the environmental and safety effects this measure may have on the commercial marine sector. Two California Ports (Los Angeles and Long Beach) are currently implementing a pilot program to cover the incremental cost for vessels to voluntarily switch to cleaner fuels while in or near ports. This program is still in pilot demonstration phase and will cost each port millions of dollars. The Port Authority will continue to monitor this program for feasibility and transferability. Below are some of the Port Authority’s specific concerns. This control measure is being considered in California largely as a particulate matter and SO2 control, not a NOx control. Unlike Texas, portions of California are non-attainment for the fine particulate matter standard. The projected particulate matter reductions from this rule are 75%, but only 6% for NOx. Although particulate matter reductions are important to Houston, H-GAC’s and TCEQ’s efforts are focused on ozone (NOx and VOC). There is also a question of the availability of fuel, logistic matters and tankage restrictions for the vessels. For this reason, the auxiliary engine rule is considerably less helpful, viable, and cost-effective for the Houston 8-hour Ozone SIP. Statistics show that few ships frequently call on the Port of Houston. According to the Houston Port Bureau, only 17% of ships calling on the Port of Houston in 2000 called more than 5 times.1

Requiring a ship that only visits a few times a year to utilize a certain fuel may not be the most efficient means of control. Although the CARB rule would allow alternative means of control, the question becomes whether the rule for infrequent visitors is essentially a de facto rule to comport with some other control mechanism or fee structure. The resulting program may have significant practical and legal implications. As discussed above, no studies have been performed or stakeholders engaged to assess the viability and effectiveness of this strategy in Texas. CARB has yet to complete its own rule


development which started several years ago. CARB has spent considerable time and resources developing the rule. CARB’s assessment includes thousands of pages describing fuel availability estimates, cost information, technical considerations, legal evaluations, public comment, business comments, etc. It is doubtful that H-GAC, TCEQ, and stakeholders could review necessary considerations under the current timeframe. Moreover, it should be noted that the California Auxiliary Rule has yet to become final. An additional comment period will soon begin and the rule is not expected to be delivered to the Office of Administrative Law until September of this year. Questions regarding CARB Control Measure Many of the concerns identified by CARB should be evaluated in Texas. For example, CARB estimated that only about 10% of all vessels would require retrofits to use cleaner fuel. Has H-GAC or TCEQ considered or investigated this statistic? CARB also estimated the average cost per business at $20,000 per year for non-diesel electric vessels and $2,000,000 for diesel-electric vessels (cruise ships and some tankers). Is this cost estimate accurate for Texas? Many older vessels operate auxiliary engines on steam, there is no other fuel option for this vessel. These vessels are not that common in California, where the average vessel is 1-5 years old. The average vessel at the Port of Houston is second or third generation, which is about 15 or more years old. CARB mentioned in its report that operators who choose to replace all residual fuel used in their auxiliary engines with marine distillate may experience scheduling conflicts and logistics issues when loading large amounts from local suppliers. Will this occur in Texas? There are numerous unanswered questions that require before this control measure is selected for rule adoption in Texas. In addition, the Auxiliary Engine Rule is likely to face legal challenges since the rule would regulate foreign flagged ships extending 24 nautical miles from the coastline. Below is a list of some potential legal considerations:

• International treaties - Most ships calling on the Port of Houston are foreign flagged (only about 9% visiting the Port of Houston in 1997 were U.S. flagged).2

• U.S. Constitution (the Supremacy Clause, Foreign Affairs Clause, etc.) • Federal statutory provisions – Examples:

o Section 209(e) of the Clean Air Act (preempting states from adopting state or local engine standards)

o Section 110(a)(5) of the Clean Air Act (restricting indirect source review programs)

• Case law o U.S. v. Locke, U.S. Supreme Ct. (2000) – The U.S. Supreme Court held

that certain maritime safety regulations adopted by the State of Washington were preempted by the comprehensive federal regulatory scheme governing oil tankers. The Court upheld petitioner’s argument that Washington’s standards invaded areas long occupied by the Federal government and interrupted an area where national uniformity was required.

o Bluewater Network v. EPA, D.C. Cir. (2004) – The D.C. Circuit held that an environmental group challenge to EPA’s decision to regulate emissions from engines on foreign-flagged vessels was premature. In its rule, EPA stated that, “We [EPA] do not need to decide now whether we have the discretion to include foreign vessels under the non-road provisions of the


Clean Air Act. In the subsequent rulemaking [in 2007], we will be in a better position to resolve under what circumstances we may and should define new nonroad engine and vessel to include foreign engines and vessels.”

o Gibbons v. Ogden, U.S. Supreme Ct. (1824) – In a seminal Supremacy Clause case, the U.S. Supreme Court held that where Congress acted, state vessel requirements were preempted. The Court stated, “In every such case, the act of Congress or treaty is supreme; and the law of the State, though enacted in the exercise of powers not controverted, must yield to it.”

o Engine Manufacturers Assoc. v. SCAQMD, U.S. Supreme Ct. (2004) – In this case the Supreme Court overturned local air rules that required certain private fleet operators in Los Angeles to purchase low-emitting vehicles. The Supreme Court held that a “standard” under the Clean Air Act’s preemption language in Section 209 is any mandate governing the emissions characteristics of an automobile. Based on this precedent and related case law, the Supreme Court would likely hold that a state or local marine emissions cap is invalid since the requirement would govern the emissions characteristics of a ship (a preempted category of engines under Section 209(e)).

o Scurry v. Texas Air Control Board (Tex. Civ. App. 1981) – The Texas Court of Appeals in Austin held that marine vessels were not subject to permitting requirements under the Texas Clean Air Act. The Court stated that the “Texas Clean Air Act makes no clear or implied reference to indirect sources. Section 1.03 defines a 'new source' as a 'stationary source,' Section 1.03(8), and a 'source' as a 'point of origin of air contaminants,' Section 1.03(2). While these terms are not used in Section 3.27, which establishes the permit requirements, their definitions indicate that the Legislature intended to regulate only direct sources. Had the Legislature intended to give the Board authority to require permits for so broad a category as indirect sources, it would have done so [with] more explicit language and with more guidance."

o Engine Mfrs Ass'n v. Robert J. Huston, (W.D.Tex. 2001) – Although the opinion was later vacated based on mootness, the Federal District Court held that a state regulation banning the use of construction equipment during the morning hours and a regulation requiring the purchase of new equipment were “engine standards” and therefore preempted by Section 209(e) of the Federal Clean Air Act.

In addition, the Port Authority would be concerned if this rule was adopted only in the Houston region. If it became cheaper or less prohibitive for vessels to use other ports in the Gulf Coast (which might be facing their own air quality issues), that cargo could be displaced to neighboring ports. The displaced cargo will then likely travel to Houston by truck. In conclusion, the Port Authority has been extremely involved in the passing of MARPOL Annex VI by the United States. These measures will put more aggressive engine and fuel standards into place for ocean going vessels on an international basis. The IMO has already determined even more stringent standards are needed once MARPOL Annex VI is ratified and the Port Authority will continue to provide resources and make efforts to ensure these more stringent standards are approved. The Port Authority and the American Association of Port


Authorities are leading these efforts to ensure that ocean going vessels are addressed on an international level, rather than local efforts to ensure world-wide compliance and economic competitiveness. 1 Information obtained by Nicole Cass of the Port of Houston Authority from the Houston Port Bureau. 2 TCEQ December 2000 HGA SIP. #89/37 – California Cargo Handling Equipment Rule The Port Authority is engaged in numerous efforts to reduce emissions from cargo handling equipment. Approximately 18% of the cargo handling equipment is owned and operated by the Port of Houston. The remainder is owned and operated by tenants and users. The Port Authority has spent many years testing and evaluating new emission control strategies and purchasing new cleaner equipment for its own engines. The Port Authority has also encouraged its tenants to use cleaner engine technologies through TERP application assistance, education programs, and tenant meetings. The Port Authority already has a fleet turnover program for its’ equipment and that of tenants that heavily relies on TERP funding availability. While the Port Authority supports voluntary measures to reduce emissions from cargo handling equipment such as TERP, the Port Authority has potential concerns about the viability of a mandatory measure—especially if the rule is intended to meet Houston’s SIP deadline. As with the CARB Auxiliary Engine rule, the Port Authority believes there has not been enough due diligence, nor will there be enough time to conduct the proper due diligence over the several months. Below are some of the Port Authority’s concerns. This control measure could not be implemented within the required SIP time frame (even if it were otherwise appropriate and legal). The State of California has yet to adopt the rule into law. Based on the Port Authority’s conversations with CARB, the rule is still subject to change and will not be submitted to the Office of Administrative Law until September 2006. Until the State of California adopts the rule, receives a waiver under Section 209 of the Clean Air Act, and the required time period has passed, the State of Texas cannot adopt the rule. Based on this time frame and the Houston SIP time frame, this rule does not appear to be currently viable. The Port Authority has concerns regarding the fact that no feasibility analyses, cost analyses, or other assessments have been conducted for this region. CARB prepared numerous reports and engaged stakeholders over a significant period of time. Six public workshops were held, four public working group meetings were held, additional outreach meetings occurred, a cargo handling equipment survey was conducted, site visits happened. Based on H-GAC’s current schedule, the off-road short list is scheduled for one generalized stakeholder meeting. The Port Authority believes that significant resources and time are needed for H-GAC and TCEQ to perform due diligence before this measure is further pursued. The Port Authority is concerned with technical and practical considerations. The rule would essentially require cargo handling equipment to be re-powered or replaced with 2007 on-road engines, Tier 4 off-road engines (when they become available), or retrofitted with a verified control that meets the same level of reductions. Numerous questions need to be addressed including cost, feasibility, availability of new engines (especially since Tier 4 engines are not applicable until 2011), availability of verified NOx control strategies since very few presently exist, the amount of emission reductions expected in the required timeframe, the possibility that


this rule would result in relocation of older equipment to other ports. Significant due diligence is necessary to ensure proper consideration of all environmental, social, and business factors. In addition, the Port Authority would be concerned if this rule were adopted only for the Houston region. Port equipment can move from port-to-port and a competitiveness issue could arise if one port was subject to the requirement while another port was not. If it became less costly for a shipper to send goods to another port, those goods could be redirected to another port that also may be facing air quality issues. The goods then might travel back to Houston via truck. #45 – Development of Port of Houston Clean Air Action Plan The Port Authority will provide comments to this potential measure in a separate document. We hope you found the above comments helpful in your analysis. The Port Authority appreciates the opportunity to provide these initial comments on the short list of non-road control strategies. The Port Authority will continue to evaluate and investigate these measures, as well as, others to develop practical and feasible solutions in reducing air emissions in the region. We look forward to working with you further to find the best path forward for voluntary measures towards achieving cleaner air. Please let us know if we can be of further assistance. Sincerely, Aston Hinds, PhD Environmental Affairs Manager


B.1.3.2 Response to Port of Houston Authority August 27, 2008 Mr. Aston Hinds Port of Houston Authority P.O. Box 2562 Houston, Texas 77252-2562 Dear Mr. Hinds: Thank you for your comments regarding the mobile source control measures for the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP). We have considered your comments and would like to take a moment to respond to your comments directly. Your letter expressed comments on the following control measures:

• Non-road Measure 28/5 – Enhanced Texas Emission Reduction Program (TERP): The TERP program is operated under the jurisdiction of the Texas Commission on Environmental Quality (TCEQ). Because of this, TCEQ will offer a separate response to address this comment.

• Non-road Measure 31 – Accelerated Equipment Turnover; Tier 2 or Tier 3 Non-road Engines: H-GAC thanks you for continuing to participate in programs such as TERP to obtain accelerated emissions reductions. We appreciate your comments regarding the mandatory implementation of accelerated vehicle turnover. H-GAC will use this information to create a refined version of this list in the latter part of this year.

• Non-road Measures – 45/11 (Water Injection for Diesel Engines), 46/12 (Alternative-Fueled Equipment for All Equipment Types), 47/13 (Alternative Fuel Heavy-Duty Equipment), 48/14 (Lean NOx Catalyst), 49/15 (Early Introduction of Low-NOx Engines), 50/16 (Selective Catalytic Reduction (SCR)), and 55 (Reformulated Fuels for Off-road Vehicles): We appreciate your comments regarding the implementation of alternative engine and fuel technologies in port operations. H-GAC will use this information to create a refined version of this list in the latter part of this year.

• Non-road Measures – 35 (Conditions of Approval for New Construction), 37 (Control Clauses for Construction Contracts), 38 (Contract Bidding), 39/8 (Government Construction Incentives), 41/9 (Develop Air Quality Best Management Practices): H-GAC thanks you for voluntarily working to improve air quality through best management practices. We will use this information to create a refined version of this list in the latter part of this year.

• Non-road Measure 42/10 – Limitations on Idling of Heavy-Duty Construction Equipment: H-GAC thanks you for creating a voluntary idling reduction program.

• Non-road Measure 87/35 – ARB Portable Engine Registration and Rulemaking: H-GAC appreciates your comments will use this information to create a refined version of this list in the latter part of this year.

• Non-road Measure 88/36 – California Auxiliary Engine Rule: H-GAC thanks you for your continuing work to reduce emissions from ocean going vessels that are entering and


leaving the port. We appreciate your comments and will use them to as we work to create a refined version of this list in the latter part of this year.

• Non-road Measure 89/37 – California Cargo Handling Equipment Rule: H-GAC thanks you for your continuing work to reduce emissions from cargo handling equipment. We appreciate your comments and will use them to as we work to create a refined version of this list in the latter part of this year.





B.1.4.1 Comment from Sierra Club


B.1.4.2 Response to Sierra Club August 27, 2008 Mr. Brad Mannchen Lone Star Chapter of the Sierra Club Houston Regional Group P.O. Box 3021 Houston, TX 77253-3021 Dear Mr. Mannchen: Thank you for your comments regarding the 2006 and 2008 mobile source control measures for the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP). Throughout the latter part of 2008, H-GAC will work to quantify and refine this Master List into a Short List of measures which the Houston-region will recommend to TCEQ for implementation in early 2009 as part of the SIP. You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx

Additionally, we encourage you to become more involved with the SIP process. I am happy to provide more information about the form and scope of these control measures by phone (713-499-6695) or email ([email protected]).



B.2.1 Comment from Angel Brothers Enterprises, Ltd.


B.2.2 Comment from Balfour Beatty Infrastructure Inc.


B.2.3 Comment from Beyer Construction, LLP


B.2.4 Comment from Cravens Partners, Ltd.


B.2.5 Comment from E.P. Brady, Ltd.


B.2.6 Comment from Highway Pavement Specialties, Inc.


B.2.7 Comment from J.D. Abrams, L.P.


B.2.8 Comment from NBG Constructors


B.2.9 Comment from Pavers Supply Company


B.2.10 Comment from Prime Eco Group


B.2.11 Comment from Smith & Company


B2.12 Comment from W.W. Webber, LLC


B.2.13 Comment from William Brothers Construction Company, Inc.


B.2.14 Comments on Draft Off Road Strategies


B.2.15 Response to Associate of General Contractors August 29, 2008 {Commenter} {Company} {Address} Dear {Commenter} Thank you again for your comments regarding the mobile source control measures for the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP). We have considered your comments and would like to take a moment to respond to your comments directly. Your letter expressed comments on the following control measures:

• Non-road Measure 5 – Enhanced Texas Emission Reduction Program (TERP): The TERP program is operated under the jurisdiction of the Texas Commission on Environmental Quality (TCEQ). Because of this, TCEQ will offer a separate response to address this comment.

• Non-road Measure 6 – Aftermarket Technology and Fuel Additive Research Program: Thank you for your comment regarding this measure. We will take this into account when creating a more refined version of this list in the latter part of this year.

• Non-road Measure 8 – Government construction incentives: Thank you for your comment regarding this measure. We will take this into account when creating a more refined version of this list in the latter part of this year.

• Non-road Measure 9 – Develop air quality best management practices: Thank you for your comment regarding this measure. We will take this into account when creating a more refined version of this list in the latter part of this year.

• Non-road Measure 10 – Limitations on idling of heavy-duty construction equipment: Thank you for your comment regarding this measure. We will take this into account when creating a more refined version of this list in the latter part of this year.

• Non-road Measures 11 (Water injection for diesel engines), 12 (Alternative-fueled equipment for all equipment types), 13 (Alternative fuel heavy-duty equipment), 14 (Lean NOx catalyst), 15 (Early introduction of low-NOX engines), and 16 (Selective catalytic reduction (SCR)): These measures all require revisions to the TERP program which is operated under the jurisdiction of the Texas Commission on Environmental Quality (TCEQ). Because of this, TCEQ will offer a separate response to address these comments.

• Measures 19 (Lower sulfur fuels) and 20 (Texas Low Emission Diesel (TxLED)): Thank you for your comment regarding these measures. We will take this into account when creating a more refined version of this list in the latter part of this year.


• Old Non-road Measures 30, 31, 33, 34, 35, 37, 38, 40, 43, 44, 58, 59, 60, 61, 62, 85, and 87: All of these measures were included in draft versions of the nor-road control measures list, however, they were removed from the final version of the Master.

Additionally, your letter suggested the addition of several new measures to the current list of control measures:

• Use the Federal (USEPA) Retrofit Program for non-road vehicles: This suggestion has been added to the Master List as Non-Road Measures 39, 40, and 41.

• Expand use of the Congestion Mitigation and Air Quality fund: Thank you for your comment regarding this measure. We will take this into account when creating a more refined version of this list in the latter part of this year.

• Expand the Emissions Banking and Trading Program to include non-road sources: Thank you for your comment regarding this measure. We will take this into account when creating a more refined version of this list in the latter part of this year.




APPENDIX C

Summaries of the Houston-Galveston Area Council of Governments Meetings with the Texas Commission on Environmental Quality and Various Stakeholders concerning the

Houston-Galveston-Brazoria Eight-Hour Ozone State Implementation Plan Short List Control Measures

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Houston-Galveston Area Council of Governments Meetings with the Texas Commission on Environmental Quality and Various Stakeholders concerning

the Houston-Galveston-Brazoria Eight-Hour Ozone State Implementation Plan Short List Control Measures

MEETING SUMMARIES First Airports/Airlines Stakeholder Meeting October 1, 2008; held at H-GAC office in central Houston Persons Present: Mike Kenney (KB Environmental Consulting), James Parise (HAS), Darcy Zarubiak (Jacobs Consultancy), Alan Goldman (Jacobs Consultancy), Debayan Sen (Jacobs Consultancy), Neal Wolfe (Jacobs Consulting), Karl Pepple (COH), Roy Conn (Continental Airlines), Marianne Csaky (Continental Airlines), Elaine Karnes (SW Airlines) Staff Present: Santos Olivarez (TCEQ), Donna Huff (TCEQ), Peter Ogbeide (TCEQ), Shelley Whitworth (HGAC), Graciela Lubertino (HGAC), Kelli Angelone (HGAC), Ben Finley (HGAC), Connie Chao (HGAC), Mary Schuwerk (HGAC) TCEQ Presentation: Discussion of Inventories TCEQ presented three handouts regarding the emissions inventories for the airlines/airports industry. The “Ground Support Equipment” handout showed the commitments that were agreed upon by the airport industry representatives from the last SIP process. This handout generated a lot of discussion because the control strategies agreed upon were not the same as what the airport industry ended up using to reach the target reductions. The “Airports/Airlines Emissions Inventory” handout precipitated discussion regarding the emissions growth projections. PUBLIC COMMENTS:

1) Jacobs Consultancy pointed out that there was a difference between what was shown and agreed upon between TCEQ and the airport industry and what would be shown on the documents verifying that the airport industry had achieved the reductions.

a. TCEQ answered that since the submitted verification documents and participants had not been audited, nothing was officially verified. What is on the handout is what was agreed upon in the 1998-1999 SIP documents.

2) HGAC asked why there was such a low emissions amount shown at Hobby for Continental.

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a. Continental answered that they had stopped service at Hobby except for maintenance flights.

3) Jacobs Consultancy asked about the dramatic drop shown from 2000 to 2002 on the Inventory handout.

a. TCEQ answered that they had received their information from the TexAir database and so accept it as true.

4) Jacobs Consultancy commented that some of the inventory numbers were clearly erroneous because they show a projected increase in one area and decrease in the other, which means that the same growth factors were not used in the calculations.

a. TCEQ said they would double-check the numbers. 5) Jacobs Consultancy asked if the last SIP’s control strategies were already subtracted from

the inventory data shown. a. TCEQ answered yes, the control strategies were already included.

6) HGAC asked how TCEQ came up with the numbers for 2018? a. TCEQ said it was just growth. b. HGAC said that it could not be just growth because fleet turnover and all

regulations that will be applied between 2005 and 2019 must be included for a base line inventory.

c. TCEQ answered that they did not see that as a very big factor. 7) Jacobs Consultancy asked what the growth factors were because of the inconsistencies in

TCEQ’s handouts. 8) Southwest said the FAA does not take into account a lot of factors like the economy or

the effects of 9/11. They would like to see what 350EP number were used and to understand EGAS.

a. TCEQ answered that the reason the numbers are off is because TCEQ has not been able to communicate with the industry and so were forced to use the numbers they have. The numbers TCEQ will use is what can be agreed upon between TCEQ and industry.

9) FAA asked if they and the industry groups could provide TCEQ with different numbers with good reasoning behind them, could those numbers be used?

a. Yes, of course, assuming they are certified and show methodology. 10) Jacobs Consultancy said that the SIP really matters to the airports and airlines. He

explained that that the airport is different from the airline, so there is a difference in responsibilities and roles. The airport is responsible for facilities and general conformity.

They are planning a multi-billion dollar upgrade at Intercontinental Airport that would be affected by this, and all that the industry is asking for is accuracy because projects like this cannot occur without general conformity. Houston Airport System (HAS) is owned by COH. Jim Parise [for HAS] has received more federal grants than any other airport in the county. Of about 24 grants available in the nation, 9 have gone to HAS. In general conformity, HAS will be putting together air quality mitigation programs. As for the EDMS, a lot of the defaults are bogus. For example, preconditioned air as a control strategy is very effective but the EDMS defaults do not reflect the level that it is utilized. It allows airplanes to turn off APUs while boarding. If the SIP makes a rule for a mitigation strategy, then HAS cannot use it for general conformity. HAS will go forward with owning emission reductions from now on. We want to cooperate with TCEQ and HGAC on a voluntary basis, not through rule-making.


11) HGAC asked if they would still allow HGAC to document those projects mentioned for the SIP.

a. Jacobs Consultancy answered yes. They would like the SIP to hold an airports inventory appendix for the years 2002, 2008, 2011, 2014, 2017 and 2018 that listed all airplanes, GSE, shuttles, etc in one place so that it made conformity determination easier.

b. H-GAC answer that the inventories for all those years are not for the attainment SIP, they are for the RFP SIP.

12) TCEQ said that all the airport data would have to be backed up by more data. TCEQ has to agree on the methodology used for the airport inventory, and so TCEQ needs to see the inventory to begin dealing with that. The appendix is not something that is needed for the SIP, but it can be discussed among TCEQ managers.

13) Southwest said they would like to point out that Jacobs Consultancy was speaking for HAS, not for the airlines. It is not necessarily what the airlines want or will agree to.

a. Jacobs Consultancy said that it did not want to misrepresent what was being said as also representing what the airlines wanted.

14) Continental Airlines asked why calculations used to inventory airline/ airport data for NEPA, which is sent to the FAA, could not be forwarded to TCEQ for the SIP [to save time, money, paperwork].

a. FAA commented that the data just is not used that way. TCEQ Presentation: TCEQ SIP Timeline TCEQ presented a handout showing their deadlines in relation to the SIP. The shaded dates shown were unmovable. [See “TCEQ SIP Timeline” handout at H-GAC website.] PUBLIC COMMENTS: Jacobs Consultancy commented that the timeline shows inventory to be a completed task. TCEQ answered that they are open to working with stakeholders until the last minute on the inventories to be sure they are as accurate as possible. HGAC Presentation : SIP Process Timeline HGAC presented a handout showing their deadlines in relation to the SIP. PUBLIC COMMENT:

1) Jacobs Consultancy asked if they should comment on the Master List of Control Strategies.

2) HGAC answered: no, the Master List in not up for comments any more. H-GAC is currently working on quantifing the emission reductions for the control strategies that made the Short List, and when that process is over, the stakeholders will be welcome to submit comments.

3) Jacobs Consultancy asked for confirmation that the Short List was scheduled for adoption by January 30, 2009.

HGAC answered: no, that is when the Short List will be sent to TCEQ, and it is up to TCEQ to include these control measures into the SIP.

HGAC Presentation : HGAC Funding Available HGAC’s 3rd Party TERP program allows local government (such as the airports) to apply for TERP grants without having to compete with the whole state. CMAQ funding is for on-road


vehicles such as airport shuttles. SEP is currently only available for school bus funding, but HGAC is working to make that funding available to local governments. ACTION ITEM: TCEQ

1) TCEQ should retrieve the demonstration documents from the past MOU agreements for the airports industry with HAS and DFW so that HAS may learn from past SIP experiences. TCEQ should also send copies to HGAC so it can be posted to the website.

2) Find out if the airports industry can use an appendix from the RFP SIP for the same purpose as the attainment SIP for general conformity and reference.

ACTION ITEM: Industry

1) Airports representatives and TCEQ should get together on Mondays to teleconference at 9:30am to update each other on the inventory and SIP.

ACTION ITEM: H-GAC

1) H-GAC should send a copy of sign-in sheet with contact information to everyone that attended the meeting.

Railroad Industry Stakeholder Meeting December 1, 2008; held at H-GAC office in central Houston. Persons Present: Ken Gathright (PoHA), Kirk Higbie (PTRA), Marvin Wells (PTRA), Hugh L. McCulley (PTRA), Brittney Weathers (GCFRD), Lanny Schmid (UP), Peter Conlon (KCS), Steve McNealy (KCS), Carl Akins (KCS), Mike Clift (BNSF), Staff Present: Donna Huff (TCEQ), Koy Howard (TCEQ), Shelley Whitworth (H-GAC), Graciela Lubertino (H-GAC), Kelli Angelone (H-GAC), Connie Chao (H-GAC), Chris Lindhjem (Environ) Environ Presentation: Overview of SIP Process and Control Strategy Discussion Environ reviewed the process by which control strategies were gathered into a master list of every possible strategy, then narrowed into a short list of realistic, achievable strategies. Strategies that would be voluntary or have local support were those that were considered for the Houston-Galveston-Brazoria region’s State Implementation Plan (SIP). The off-road strategies include:

1) Voluntary retrofit/replacement programs 2) Increasing the efficiency of switching yards in the region 3) Replacing old switching engines 4) General efficiency improvements, ie, straightening routes, grade separation, upgrading

technology such as bearings and lubrications. PUBLIC COMMENTS:

1) Question put to railroads: is 50% a reasonable estimate of the number of your switching engines that have already been replaced?

a. BNSF answered that their percentage of switching engines already replaced was probably higher.


b. KCS answered that they probably had no switching engines in the Houston area, they have just through-service on UP lines. However, they are planning to install a switching engine in Rosenberg.

2) Question put to railroads: has there been any route straightening in your area?

a. KCS answered no. b. UP said that actually, with Tier 4 standards, there would be a decrease in fuel

efficiency, which would cancel out some efficiency gains. MOU/MOA Discussion: H-GAC wanted to discuss potential agreements that could be made for emission reductions with railroad stakeholders. Railroads/ locomotive emissions make up a large portion of the emissions inventory. PUBLIC COMMENTS:

1) KCS referred to a project involving Tower 55 in Fort Worth—a freight crossing with BNSF which was successful, costing a couple million dollars. They said that it was probably not realistic to expect a good amount of emissions reductions funding to be available for aggregated crossing or fluidity improvements.

2) PTRA offered up the extension of double-track from Deer Park to Pasadena. The project originally cost $5 million in public funds 8 to 9 years ago, but it was not completed then due to pipeline issues which are now resolved. However, now the project will cost over $10 million, with the difference being made up by the railroads.

a. H-GAC asked if this project could be made into a VMEP and the reductions quantified.

b. PTRA was concerned about further project delays, which H-GAC said that they did not want either, and that a VMEP agreement should not hold up a project in any way.

3) UP commented that many times projects for environmental benefits had been ‘forgotten’ by the public, and that sometimes, they could not receive further funding because of VMEP agreements.

a. H-GAC reminded them of a project that H-GAC had worked on where they had verified that UP would make their VMEP reductions and still accept TERP funds to get even further reductions.

4) There was concern that a lot of locomotives eligible for MOAs are leased. TERP has some limitations for leased vehicles that are not attractive to industry. Suggestions were given for whom to talk to about leased locomotives.

5) PTRA detailed their inventory—24 units never leave Houston, all but 8 have been overhauled, and those will be overhauled this year. They applied to TERP in 2006 at TCEQ’s request. These emission reductions could work as an MOA.

6) BNSF detailed their fleet—a large percentage of their switch engines have been replaced by TERP. They do not think they are interested in replacing any more vehicles in this region.

7) KCS said that the potential for emission reductions may lie with smaller entities. They also asked if there were incentives to help with these projects or if they were expected to do them on their own.

a. H-GAC answered that projects for MOAs cannot be accepting TERP funds or they will have to be counted under TERP. The same is true for CMAQ funding.


ACTION ITEM: H-GAC 1) H-GAC should send to the railroads sample MOAs from the last SIP.

ACTION ITEM: Industry Groups

1) Groups should consult among themselves to decide on Memoranda of Agreement or Understanding that they would be able to enter into with H-GAC and TCEQ.

First Public Meeting December 8, 2008; held at H-GAC office in central Houston Persons Present: Brandt Mannchen (HSC), Madonna Lorraine (TxDOT), Melanie Oldham (public health advocate), Dana Blume (PoHA), Marise Textor (Texas Petrochemical Society), Russell Lehrman, Nancie Anderson, Beth Whitehead (GHP), Donna Huff (TCEQ), Koy Howard (TCEQ), Helen Vollmer (Vollmer PR), Lori Martin (Vollmer PR), Chris Lindjhem (Environ) Staff Present: Shelley Whitworth, Graciela Lubertino, Kelli Angelone, Connie Chao, Mary Schuwerk, J. Ben Finley, Andrew DeCandis Environ Presentation: Overview of SIP Process and Control Strategy Discussion Environ reviewed the process by which control strategies were gathered into a master list of every possible strategy, then narrowed into a short list of realistic, achievable strategies. Strategies that would be voluntary or have local support were those that were considered for the Houston-Galveston-Brazoria region’s State Implementation Plan (SIP). H-GAC Discussion : Control Strategies – On-Road and Off-road H-GAC asked for comments on the draft short list and recommendations from the public. PUBLIC COMMENTS:

1) PoHA asked about the project life for a marine VMEP. a. Environ answered that it is not ideal but is feasible to complete a project within

the SIP time period. 2) HSC asked if there was any way to get a manufacturer to bring out a Tier 4 engine early.

a. Environ answered that it is not possible at this time because of the timing of Tier 2 and Tier 3. We will most likely see new SCR technology in 2010.

3) HSC asked if there was a mobile burner piece of equipment that could be use for SCR? a. PoHA answered that there really was not anything like that to use in place of

SCR. b. Environ added that the issue is mostly ownership because a lot of groups are

leasing their vehicles, vessels, and equipment. 4) Possibilities for marine VMEPs were discussed by PoHA and Environ. Vessel speed

reduction and the vessel APU/ hood were explained. 5) Melanie Oldham commented that voluntary measures are not making an appreciable

difference in Brazoria County. She thinks the standard should be 60 ppb. 6) Texas Petrochemical Society commented that vessel speed reduction would probably not

be effective in the Houston region because we do not have the same wind patterns as


California. Our wind patterns would not necessarily push ship emissions further ashore, whereas California east-west winds would do that.

7) Texas Petrochemical Society asked about pay-as-you-drive insurance. a. Environ explained that pay-as-you-drive insurance was insurance that gave lower

premiums to those that drove their vehicles fewer miles. b. PoHA asked how that was quantifiable.

i. Environ answered that insurance companies’ records would be used. 8) Melanie Oldham asked about behavior-based measures such as reduced vehicle speed

and restrictions on when people could run their lawnmowers. a. Environ and H-GAC answered that those kinds of measures did not have a lot

public acceptance, so much so that legislation was passed against reducing vehicle speeds for environmental reasons.

b. Melanie Oldham requested that H-GAC and TCEQ look into public education and outreach as a way to get more acceptance for behavior-based measures and for environmental and health concerns in general, which might help with the public’s behavior. She mentioned that she had made her concerns known to her state representative, Dennis Bonnen. Ms. Oldham expressed frustration with the situation in Brazoria County.

9) Russell Lehrman commented that his area of town had some of the same problems that Ms. Oldham mentioned. He said the area where he lived was considered an environmental ‘hot spot’ because he lived near a dairy plant that had a large number of heavy-duty trucks that ran very near his home all day and night.

10) HSC commented that for his organization to give respectable feedback on the draft Short List report, H-GAC would need to provide more time for review before holding a meeting, and H-GAC should consider more carefully their invitation list. H-GAC responded that the usual public notice procedures were followed, to include publicized notifications and e-mail invitations. Furthermore, another public meeting will be held closer to the end of the public comment period to allow the public to have ample time to read, study, and ask questions on the material.

11) HSC also commented that the frequently-used acronym, ‘PQSE’, should be defined in the report.

a. ‘PQSE’ is an acronym employed by the Environmental Protection Agency (EPA) to describe the qualifications that control measures should have. ‘P’ stands for Public acceptance, ‘Q’ stands for Quantifiable, ‘S’ stands for Surplus, and ‘E’ stands for Enforceable. This acronym has been explained in many of the presentations H-GAC has given.

12) HSC was unclear from the report who was responsible for enforcing the voluntary measures.

a. H-GAC is responsible for overseeing the execution of all the voluntary agreements for the Houston-Galveston-Brazoria region.

13) HSC commented that Mobile6 most likely underestimates the amount of minor traffic violations that have affects on air quality. For example, HSC estimated that the number of vehicles traveling above the speed limit at any given time on the freeway is probably much higher than the estimates provided in Mobile6. HSC recommended that instead of lowering the speed limit, enforce the one already in place.

14) HSC recommended that dedicated truck lanes, and a control measure that focuses on reducing fleet age (older than 1996) be added to the Short List.

a. H-GAC asked how that differed from its current programs.


15) HSC mentioned that the previous standards were based on the technology of 1996. If improvement is desired, the 1996 engine should not set the standard in the 2009 program.HSC recommended changing the applicability of some of the rules for HOV lane and HOTR lane use.

16) HSC recommended the following inclusions to the Control Strategy Report: “route-traffic platooning”, adaptive traffic signals, and a glossary for the report.

17) Nancie Andersonelaborated on her situation about the ill effects of the trucking emissions and noise within her neighborhood, and asked that H-GAC do whatever it can to help the situation.

18) Mr. Lehrman made further comments regarding his concerns about the dairy plant and asked for suggestions for amending the situation.

a. H-GAC assured Mr. Lehrman and Ms. Anderson that their concerns would be addressed, and their complaints inquired into.

b. It was suggested by members of the public that a nuisance claim could be filed. 19) Ms. Oldham recommended that measures to increase the number of electric cars and

electrified bus routes should be increased. Ms. Oldham commented that plans to increase business at the Port of Freeport in Brazoria County were excessive unless some actions were taken to mitigate the damage done by the many trucks traveling to and from the port.

ACTION ITEM: H-GAC

1) H-GAC will review the public outreach procedures regarding meeting notification and publishing of meeting materials.

ACTION ITEM: Public

1) Public should continue to review and comment on draft Short List documents. Construction Industry Stakeholder Meeting December 15, 2008; held at H-GAC office in central Houston Persons Present: Ken Gathright (PoHA), Bill Duguay (J.D. Abrams), Bob Lanham (Williams Bros. Construction), Staff Present: Donna Huff (TCEQ), Koy Howard (TCEQ), Lola Brown (TCEQ), Shelley Whitworth (H-GAC), Graciela Lubertino (H-GAC), Kelli Angelone (H-GAC), Connie Chao (H-GAC), Mary Schuwerk (H-GAC), J. Ben Finley (H-GAC), Chris Lindhjem (ENVIRON) Environ Presentation: Overview of SIP Process and Control Strategy Discussion. Environ reviewed the process by which control strategies were gathered into a master list, then narrowed into a short list of feasible strategies. The strategies that were considered for the Houston-Galveston-Brazoria region’s State Implementation Plan (SIP) are voluntary control measures that have stakeholder support. H-GAC Discussion: Control Strategies (See handouts, (“Control Measure: Construction Contracting Incentives, Measure 8” and “Control Measure: Construction and other off-road idle reduction, Measure 10”)


ENVIRON and H-GAC reviewed the two off-road construction strategies from the short list and asked for comments and recommendations from industry representatives. PUBLIC COMMENTS:

1) Williams Brothers said that the suggested measure, “Construction Contracting Incentives”, had implementation/feasibility problems because it would not work as a fixed requirement and industry would not support it. They said the basic problem is the cavalier attitude taken on when equipment or new technology would be available. The measure was much more viable under the other option as a voluntary or incentive approach. Conceptually, an inventive-based approach would be supported by industry, but we will be asking people to do things that contractors will tell you they cannot do.

2) The incentives listed in “Table 1, the TxDOT clean engine incentive and calculated benefit” are not worthy of being used. It is an unused incentive because it is not enough to pay the person to track the data.

3) Another issue is that there is very little publicly-funded construction, so benefits will be limited. The Regional Air Quality Planning Committee’s Policy Subcommittee had some recommendations for what the dollar amounts should be for the incentive.

a. Environ commented that yes, this was true: publicly-funded construction only accounted for about 10% of construction. It does not get the most of the activity.

4) Williams Brothers continued, saying that the reason people are willing to do engines [retrofits] is because there is only a $40,000 engine in a $500,000 piece of equipment. [It is more cost-effective to do a retrofit than purchase a new vehicle.]

5) Environ commented that just restricting the incentive to publicly-funded construction is not enough to make a significant reduction. We need to figure out how to use it for everything.

6) For the measure, “Construction and other off-road idle-reduction”, Environ commented that anti-idling was very cost-effective.

a. H-GAC asked how idling reductions would be estimated by industry groups. b. Environ said that reduced hours could be determined through tracking hour-

meters. c. Williams Brother commented that they had an idle-reduction policy, but that they

have no idea what the benefit of it is. Concerns regarding this measure are that conflicting information would come out of attempting to estimate this because what industry groups say their usage is would be compared to TCEQ’s model, and they would not match.

7) H-GAC asked if you could look at old projects where equipment was leased on a time-basis?

a. Williams Brothers replied that they rent equipment based on the standard 176 hour per month usage. Charges are increased if the equipment is run more, but the minimum 176 is charged if you run less [accuracy issue]. Some leased equipment could possibly be sampled.

8) H-GAC asked if there were any companies that lease equipment that could be asked. a. Williams Brothers said there might be.

9) Williams Brothers commented that fuel data is too erratic to use for estimation because of the construction market.

a. J.D Abrams said they do not look at fuel data in a way that would be helpful for H-GAC.

b. H-GAC asked if the percentage of fuel reductions before the fuel price increase, would that be acceptable for documentation?


c. TCEQ said that their model looks more at activity in hours of use for equipment, so it does not look at fuel use very much.

10) Williams Brothers asked if idling reduction estimations were done in the past. a. Environ answered, yes, based on total hours.

11) Williams Brothers asked what the assumed hours per day were for a piece of equipment. a. Environ answered that for an excavator it was 1092 hours/year and that a year was

about 260 days. That equals 4.2 hours per day that the engine would be running. b. Williams Brothers said that sounded right, but that if anything, equipment would

tend to be oversized, not undersized [part of Environ’s estimations]. c. Williams Brothers commented that it looked like H-GAC and Environ had a fairly

good handle on the activity estimation. H-GAC Discussion: MOUs/ MOAs PUBLIC COMMENTS:

1) H-GAC asked the construction industry about signing an MOU to do a research project documenting emission reduction.

a. Williams Brothers said that because their research is being done through a private company that is trying to get certified, they would have to talk to the manufacturer of some equipment they are testing out.

2) Williams Brothers recommended that emphasis be put in SCR and other emerging technologies.

3) Williams Brothers asked about an anti-idling device and how it would work. a. Environ answered that it was a timer that monitors engine temperature and other

things. The biggest consumer is the railroad industry. 4) H-GAC asked if someone volunteered to document anti-idling equipment, how it should

be done. a. TCEQ answered that they would have to get back to us on that because they were

not sure the off-road model could deal with that. b. Environ said that it would be difficult for the model because even though it would

reduce hours of activity, it would increase load factor. Some calculations can be done independent of the model, though. H-GAC and industry groups would have to be careful not to overestimate reductions.

c. TCEQ commented that if they get more cooperation from the industry regarding activity, they could incorporate reductions into the model.

d. Williams Brothers said that they would like to know how to do the calculations to estimate the reductions too. As a company, they have not tracked hours of activity every day, but once a week or once every two weeks. From a business standpoint, they are not interested in how a piece of equipment operates on a daily basis.

5) H-GAC asked if it would be possible to document equipment every 500 hours? a. Williams Brothers asked what the benefit of that would be. b. H-GAC could use the data for usage estimations. c. Williams Brothers said they could not use data-loggers because they have too

many strings attached—proprietary issues and they are cost-prohibitive. It would be good to be able to ‘dummy-proof’ their own readings, and definitely need to do more research.

6) H-GAC asked how much Tier 0 equipment industry groups still owned. a. Williams Brothers estimated 10%. b. H-GAC commented that if it was replaced, it would get more usage.


c. Williams Brothers said that was only true if it was needed. 7) H-GAC wondered if there was anything that could be done about projects that were

almost but not quite cost-effective enough for TERP, or voluntary projects that could be left open for technology that would come into play before 2018.

8) Williams Brothers asked if MOUs precluded using TERP. a. Yes.

9) Williams Brothers said they could probably get a particular group to agree on an idle-reduction MOU, but without consensus on how to document, where would it get us?

a. H-GAC asked about purchasing equipment with shut-off switches. b. Williams Brothers said they would need to know what equipment switches can be

put on and how much they are, but that sounded feasible. 10) J.D. Abrams said that it would be beneficial to understand what drives idling, like

keeping employees comfortable. Maybe there is some equipment like truck stop electrification that could be used.

a. H-GAC commented that there was equipment like that that could be employed. 11) Williams Brothers commented that what they need is more facts.

ACTION ITEM: H-GAC

1) H-GAC should send to the construction industry stakeholders some sample MOAs from the last SIP.

2) H-GAC should look into idle-reduction information, switch-off technologies, and other anti-idling technologies.

3) H-GAC should allow Environ and industry groups to coordinate on possible MOUs. ACTION ITEM: Industry Groups

1) Industry representatives should look into who among the industry would be willing to commit to an MOU and what ideas they are interested in.

Marine/Ports Stakeholder Meeting December 15, 2008; held at H-GAC office in central Houston Persons Present: Dana Blume (PoHA), Ken Gathright (PoHA), Linda Henry (PoHA), Kenneth Kidwell (Shippers Stevedoring Company, (SSC) USA), Shareen Larmond (West Gulf Maritime Association (WGMA)), Chris Lindhjem (Environ), Lisa McMichae (Port of Freeport), Chuck Moss (Oxid, LP), Rebecca Rentz (Bracewell & Giuliani) Staff Present: Kelli Angelone (H-GAC), Connie Chao (H-GAC), Ben Finley (H-GAC), Graciela Lubertino (H-GAC), Mary Schuwerk (H-GAC), Shelley Whitworth (H-GAC), Lola Brown (TCEQ), Koy Howard (TCEQ), Donna Huff (TCEQ), Santos Olivarez (TCEQ) Environ Presentation: Chris Lindhjem gave a summary of voluntary non-road control measure #5 which affects the Marine/Port industry. This measure is based on retrofit and replacement of marine engines as the primary means to reduce emissions. By replacing older engines and equipment with those meeting lower emission standards, NOx and VOC emissions are drastically reduced. EPA has


announced new emission standards for marine engines such that older marine equipment will have to be replaced in the future. Current state funding (TERP) already assists in engine retrofits and replacements especially for projects that focus on harbor craft (tugboats, ferries, towboats, dredges). Other techniques that could be used to achieve emission reductions could be: shore power, clean fuel, after treatment controls, plug in operations, other idling reductions. PUBLIC COMMENTS:

1) H-GAC reached out to Marine stakeholders to consider consenting to a Memorandum of Understanding/Memorandum of Agreement to reduce emissions- The MOU/MOA did not have to contain any specific details about what type of technique will be used to achieve the emission reductions, but just a number of tons per day or year.

a. PoHA and others did not disagree, but will require more time than the January 2009 deadline allowed them to devise a MOU/MOA.

b. Bracewell & Giuliani asked a clarification question about whether marine stakeholders had to come up with a draft MOU by January 2009 or whether marine stakeholders can just come to an agreement to write an MOU by then.

1) H-GAC’s response: In the past, stakeholders just came up with a consensus for an MOU and then hashed out the details after that date to devise the MOU agreement document.

2) H-GAC conducted a discussion to solidify where each segment of the marine industry could reduce emissions.

a. Stevedoring: Can own or lease equipment. The highest emitting equipment: forklifts, cranes, and on-road trucks (which take cargo on the site and also onto highways).

b. Voluntary emission reductions could also come from harbor crafts. This can occur naturally through advances in technology, and by other strategies such as the use of a bonnet (device to place over exhaust to collect and treat emissions).

3) What is each marine stakeholder doing to reduce emissions? a. Port of Freeport: It is a landlord port. This port is working on its emissions

inventory and is coming up with control measures for the site. b. Port of Houston: It is a partially landlord port, but also owns equipment. The

cruise ships at the port are a big source of pollution, and PoHA offers shore power for them. The bulk carriers are also a big source of pollution since they can be at PoHA from 2 to 10 days. This port has done its emissions inventory but an MOU but will require a lengthy approval process with the Board of Directors and Transportation Commission. If an MOU is to be passed, this will require separate meetings for approval with each stakeholder before such an agreement can be decided.

c. City of Houston: COH had no comment. d. Port of Galveston: Was not represented but was anticipated that no emissions

inventory had been started. 4) H-GAC suggested that maybe PoHA could try an anti-idling policy again.

a. PoHA responded saying it was extremely hard to enforce except for when the price of gas was high and people would not idle out of financial constraint. At one time there was a desire to increase fuel efficiency because gas was so expensive so the no idling policy came into play. However, when gas is cheaper, it’s hard to get the support.

1) H-GAC confirmed by saying that the no idling policy was voluntary.


Announcements The next public meeting for the State Implementation Plan is scheduled for January 8, 2008. ACTION ITEMS: Marine/Port Stakeholders

1) Stakeholders should consult among themselves to decide on a Memorandum of Agreement or Understanding that they would be able to enter into with H-GAC or TCEQ.

Industrial Mobile Sources Stakeholders Meeting December 16, 2008; held at H-GAC office in central Houston Persons Present: Judy Bigon (ExxonMobil) Staff Present: Shelley Whitworth (H-GAC), Graciela Lubertino (H-GAC), Kelli Angelone (H-GAC), Connie Chao (H-GAC), Mary Schuwerk (H-GAC), Ben Finley (H-GAC) H-GAC Discussion : Emissions Inventory and Control Strategies H-GAC showed the ExxonMobil representative what part of the off-road NOx inventory was concerned with industrial mobile sources, then explained the relevant control strategies for off-road, marine, rail, and anti-idling. PUBLIC COMMENTS:

1) ExxonMobil said they have a switch engine, but don’t know if it has been replaced or retrofitted through TERP. Most of their transport operates under Union Pacific.

2) ExxonMobil said they have mostly harborcraft and tankers docking and operating around their pier.

a. They were advised by H-GAC that those should be considered for possible VMEPs.

3) ExxonMobil did not know for sure whether their forklifts are leased or owned, nor how old they are, or if they have participated using TERP and said they would find out.

4) ExxonMobil asked how much of the 5.87 tons per day shown from industrial mobile sources for 2018 we were hoping to get industry to reduce because they were concerned about cost-effectiveness of reducing emissions of mobile sources when the point source controls were probably more cost-effective.

a. H-GAC replied that the Deer Park monitor showed a necessary 100 tons per day reduction from the surrounding area to come into compliance according to TCEQ models, so H-GAC is trying to get reductions from any source they are able to.

5) H-GAC asked ExxonMobil to also look at their on-road fleets of tanker trucks for on-road reductions, and at their handful of construction equipment for anti-idling and possible retrofitting/replacement.

a. ExxonMobil replied that the tanker trucks were run by another division of the company and that another contact would have to be supplied for information regarding the trucks.


ACTION ITEM: H-GAC 1) HGAC should send to the industrial mobile stakeholders some sample MOAs from the

last SIP. 2) H-GAC should look into the forklift and switch engine cost-effectiveness for

stakeholders to see. 3) H-GAC should consult contacts at TXOGA to ensure better participation for this

stakeholder group at future meetings. ACTION ITEM: Industry Groups

1) Industry representatives should look into how many forklifts make up their fleet and if those forklifts had already participated in the TERP program.

2) ExxonMobil should find out what the cost-effectiveness is for point source controls. 3) Groups should consult among themselves to decide on Memoranda of Agreement or

Understanding that they would be able to enter into with HGAC or TCEQ. Second Airports/Airlines Stakeholder Meeting January 6, 2009; held at H-GAC office in central Houston Persons Present: Karl Pepple (COH), Elaine Karnes (SW), Marianne Csaky (Continental), Debayne Yen (Jacobs Consulting), Peter Ogbeide (TCEQ), Walker Williams (TCEQ), Lola Brown (TCEQ), Chris Kite (TCEQ), Jim McKay (TCEQ), Santos Olivarez (TCEQ) Staff Present: Graciela Lubertino, J. Ben Finley, Mary Schuwerk, Connie Chao, Kelli Angelone Discussion: Control Strategies and Memoranda of Understanding (MOUs) No airport- or airline-specific control strategies are listed in the State Implementation Plan (SIP) Short List because industry representatives were concerned about the accuracy of the inventory and because industry did not confirm any of the strategies as very feasible. In light of this, staff discussed those strategies previously set aside as possibilities for MOUs and as a starting point for generation of further possible strategies. QUESTIONS/ COMMENTS:

1) H-GAC asked industry groups which of the strategies provided might be feasible, and if none were feasible, were there any that industry representatives could suggest?

a. Industry groups expressed doubt in their ability to make significant reductions with electrified or alternative fuel ground support equipment (GSE). They said this was because they have made most of the reductions that can be made with electrified GSE by converting most of the GSE as part of the last SIP agreement. Airlines stated that they estimate that most of the equipment left is the equipment that must stay diesel-fueled because electric equipment does not have the same pulling power.

2) H-GAC asked to confirm that airports/airlines had reached their emissions reductions from the last MOUs to the Texas Commission on Environmental Quality’s (TCEQ’s) satisfaction. [There had been discussion of this at the last airports/airlines meeting.]

a. TCEQ and industry representatives confirmed that the airports and airlines had definitely made the reductions they had said they would do in the last MOU.


3) H-GAC asked industry about the feasibility reduced-idling policies for aircraft, airport shuttles, and/or ground support equipment.

a. Airlines representatives said that reduced-idling policies for aircraft is a federal matter and that they have no ability to affect that. They also said that airport shuttles would be something that the airport parking lots would be the people to contact for that. Airlines representatives would prefer to focus on the ground support equipment, whose operations they have the ability to affect.

4) Industry representatives said that the rest of the strategies H-GAC had listed were also beyond their control. They wanted to commit to making emissions reductions in order to help the region, but said it would be more helpful to see the revised inventory first, which TCEQ was still assembling.

a. TCEQ was not sure when the document would be available, but knew that they were supposed to receive the last of the airport data January 9th, then would be reviewing the data themselves for the next week or so. The data had to be reinserted into the model January 29th.

5) H-GAC expressed concern that this timeline did not allow staff enough time to view the inventories and work with industry groups on MOUs.

a. TCEQ replied that they were working as fast as they could but they had to be sure everything was in order.

6) Southwest asked what percentage of reductions the region would probably need. a. H-GAC replied that TCEQ had told them at least 25%. b. TCEQ staff present had not heard this statistic and could not confirm.

7) H-GAC asked industry groups about possible gate electrification. a. Industry groups said that was a possibility for MOU.

ACTION ITEMS:

1) Airports should get their inventory information together and get the last part to TCEQ for review.

2) TCEQ should distribute copies of the airports/airlines inventory as soon as possible. 3) Industry groups should be ready to consider the inventory and look into what strategies

they might be able to make. 4) Tentative next meeting date was set for February 2, 2009 at 10:30am.

Second Public Meeting January 8, 2009; held at H-GAC office in central Houston Persons Present: Brandt Mannchen (HSC), Chuck Moss (Oxid L.P.), Tricia Clark (Skaugen), Susan Sharp (Emisstar), Shareen Larmond (WGMA), James Patterson (Fort Bend County), Catarina Cron (Harris County Judge), Mary Shine (Brazoria County), Lanie Platt (DOW-Freeport), Ken Gathright (PoHA), Dana Blume (PoHA), Russell Lehrman, Marcie Anderson, Elvia Cardinal (TxDOT), Charles Airiohoudion (TxDOT), Madonna Lorraine (TxDOT), Charles Stillman (Texas Climate Emergency), Matthew Tejada (GHASP), Donna Huff (TCEQ), Theresa Pella (TCEQ), Lola Brown (TCEQ), Helen Vollmer (Vollmer PR), Lori Martin (Vollmer PR), Chris Lindjhem (Environ)


Staff Present: Shelley Whitworth, Graciela Lubertino, Kelli Angelone, Connie Chao, Mary Schuwerk, J. Ben Finley, Andrew DeCandis, Gina Mitteco, Veronica Baxter-Lamb, Jeff Taebel, Alan Clark, Steve Howard H-GAC Presentation: Overview of SIP Process and Control Strategy Discussion H-GAC reviewed the health effects and costs of air pollution, progress that had been made by H-GAC in cooperation with regional stakeholders, the 2005-2018 projections for emissions, possible local government measures, and the on-road and off-road control strategies. PUBLIC COMMENTS:

1) Brandt Mannchen, Houston-chapter Sierra Club (HSC) a. HSC appreciates that H-GAC recognized that small emission reductions when put

together can make for effective control measures. b. HSC would still like to see the EPA criteria ‘PQSE’ defined in the Short List

document. c. For control measure, “Public Agency Clean Fleet Programs”, HSC would like

companies to commit to the lowest-emission vehicles available in California. d. For control measures #63-66, HSC is disappointed that adequate law enforcement

is not emphasized because speed enforcement would be good for the environment and for safety.

e. HSC recommends that H-GAC monitor emissions as vehicles are going down the road [a study] because they may show very different results than Mobile6.

f. They also recommend studies to monitor emissions inside vehicles for health reasons. There may be higher doses of emissions inside vehicles than we know.

g. As for control measure #13, HSC does not favor this one and would like to see dedicated trucking lanes on highways as they have in many other states.

h. Regarding measures #19 and #139 which refer to smoking vehicles, HSC finds these contradictory and would like to see a program which increased compliance because even with an estimated 4% of vehicles out of compliance, that equals 100,000 smoking vehicles on the road.

i. HSC is disappointed that #39-62 do not include employer trip-reduction programs, which should be some kind of voluntary control measure.

j. HSC supports control measure #92, rail expansion, mass transit projects, #124, #5a, #5b, and #45.

k. HSC expressed concern about TERP information and would like to have more facts about the penetration of the program into industrial sectors so that the public would be better equipped to decide what should be done.

2) Russell Lehrman, resident of Houston, northeast of downtown

a. Mr. Lehrman was concerned that #60, travel-based taxes, would not apply to idling vehicles, which he thought it should. He thought it might be a good idea to have idling-based taxes because of the 65 vehicles at the dairy plant near his home which idle 24 hours a day.

b. Mr. Lehrman supports limits on idling heavy-duty vehicles. c. Mr. Lehrman mentioned that the dairy plant near his home does have one or two

APUs, but it is still expanding the ‘parking lot’, so it is not having enough of an effect.


d. Mr. Lehrman and his friend, Ms. Anderson, have met with city council and the city attorney, and many residents have fallen ill from the pollution. Doctors have told many people that they should not spend time immediately outside their homes due to the health risks.

ACTION ITEM: H-GAC

1) HGAC will continue to integrate comments into the short list. ACTION ITEM: Public

1) Public should continue to review and comment on draft Short List documents.

Local Government Stakeholders Meeting January 27, 2009; held at H-GAC office in central Houston Persons Present: Patrick Buzbee (Montgomery County), Bob Allen (Harris County), Cristina Gossett (City of Deer Park), Snehal Patel (Harris County Attorney’s Office), Nick Finan (City of Texas City), Charles Dean (Harris County), Perri D’Armond (Greater Fort Bend EDC), Don Brandon (Chambers County), DeWight Dopslauf (Harris County Purchasing), Ann Werlein (Fort Bend County), Ken Gathright (Port of Houston Authority), Stacie Henderson (City of Sugar Land), Luis Rodriguez (City of Sugar Land), Dolly Arons (City of Shoreacres), Kerry Collins-Leggett (City of Alvin), Gail Miller (Harris County Precinct 2 Commissioner Sylvia Garcia’s Office), Larry Buehler (City of Alvin), Jim Wigihton (Brazoria County District Attorney’s Office), Cindy Sumrall (Fort Bend County Transit), Catarina Cron (Harris County), Scott Tuma (City of League City), Shaun Light (City of Houston, Large-Position 3 Councilwoman Melissa Noriega’s Office) Staff Present: Steve Howard, Jeff Taebel, Shelley Whitworth, Graciela Lubertino, Kelli Angelone, Connie Chao, Mary Schuwerk, J. Ben Finley, Andrew DeCandis, Shaida Dezfuli, Ilyas Choudry, Veronica Baxter-Lamb, Gina Mitteco, Meredith Dang, Jerry Bobo, Ashley K. Wadick (TCEQ), Cynthia Williams (TCEQ), Lola Brown (TCEQ), Theo Kosub (TCEQ) Purpose of Meeting: Workshop to provide tools for local government on how to reduce NOx emissions H-GAC Presentation: Overview of SIP Process and Voluntary Control Strategies Shelley Whitworth, H-GAC Air Quality Program Manager, described the State Implementation Plan and gave an overview of the process. The purpose is to reduce emissions through state and local controls. Nitrogen oxide (NOx) and Volatile Organic Compounds (VOC) levels were estimated in a TCEQ modeling emissions inventory in 2005 and predicted for 2018. Currently, 8-hour ozone design values have a downward trend which means that the ozone level is slowly decreasing in the HGB region. However, more on-road and non-road reductions must happen to continue the downward ozone level trend. Government agencies are encouraged to take more voluntary measures to reduce emissions. Recommended on-road voluntary control measures are: Alternative commuting, regional traffic flow improvement, and vehicle retrofit and replacement. Recommended non-road voluntary control measures are: Engine replacement and retrofit


programs, government construction incentives, limits on construction idling, promoting cleaner garden and lawn equipment. Some local actions that government can take are to support on-road and non-road voluntary control measures, enact ordinances promoting livable centers and multi-use developments, support increased transit service, expand the use of natural gas in vehicle fleets, add bicycle and pedestrian control strategies, increase fleet turnover for newer vehicles, encourage practices which reduce emissions, and increase public education about air quality issues. H-GAC encourages the signing of Memoranda of Agreement (MOAs) to formalize emission reduction commitments to the SIP. Local SIP commitments must be submitted to TCEQ no later than February 20, 2009. Finalized MOA documents must be submitted to TCEQ by April 2009. H-GAC Open Session to Explore Different Voluntary Measures: Twenty minutes were taken to have local government staff visit stations around the room and ask questions about the different voluntary measures available to them. The stations were the following: Fleet Turnover, Support Commute Solutions, Airport Control Strategies, Non-Road Mobile Control Strategies, Traffic Signal Strategies, Idle Reduction Strategies, Livable Cities/Bicycle /Pedestrian Program, All On-Road Funding Available: Congestion Mitigation & Air Quality (CMAQ), TERP funds, Supplemental Environmental Project (SEP), Local Initiative Project (LIP), Surface Transportation Program Metro Mobility (STPMM), Surface Transportation Project Enhancements (STPE), and Local Funds. The group came back afterwards for a group discussion. PUBLIC COMMENT: A question was asked by Dolly Arons of the City of Shoreacres: Are there other funds besides the TERP program that may be available for local government use? Shelley Whitworth answered it saying that TERP was the main funding available for now although there were plans to expand the availability of SEP funds to include local government fleets. MEETING ADJOURNED: 3 pm ACTION ITEM: Local governments work to decide on voluntary control measures to commit to, and sign an MOA formalizing the commitment to reduce emissions in their respective areas.

APPENDIX D

Written Comments from Stakeholders and their Respective Responses Regarding Short List Control Strategies

G:\HGAC\Reports\Final_051009\Appendix D_051009.doc D-1

The comment periods for the Draft On-Road Control Strategy List and the Draft Non-Road Short List Control Strategy List was Monday, December 8, 2008 to Thursday, January 15, 2009. Written comments were received by: Mail: Transportation Department, Air Quality Section, Houston-Galveston Area Council

P.O. Box 22777 Houston, Texas 77227-2777

E-mail: [email protected] Fax: (713) 993-4508 H-GAC received a total of 10 written comments. H-GAC has separated the written comments into two sections:

1. Jim Blocher 2. Troy Miller 3. Leo Waltz 4. Peter Wang 5. Sierra Club 6. Charles Stillman 7. Carol Caul 8. Port of Houston Authority 9. Smith Electric Vehicles 10. Harris County Texas

Each comment received is shown in its entirety. Each comment is followed by the response given.


1.1 Comment from Jim Blocher From: Jim Blocher [[email protected]] Sent: Monday, December 08, 2008 8:57 PM To: Air Quality Study Subject: use the Pickens plan I agree with T. Boone Pickens idea that in the short run only Natural Gas will solve our energy and pollution problems. For the next ten years or so I suggest we revive the CNG fueled vehicles which all of the Big 3 used to manufacture. I live in Freeport, Texas and have purchased a Natural Gas Vehicle and Fuelmaker home appliance refueling compressor at some considerable expense. The City of Lake Jackson nearby has a fleet of NGV cars and trucks which it fuels from its own station. If they could receive a grant to install a retail CNG fueling pump I believe it would pay for itself eventually. During this last period of high gasoline prices I was still fueling my car for less that $1.50 per GGE, including the electricity needed to pump the Natural Gas. This is a long term investment for me as a commuter to Houston, but I believe others would consider NGV’s if there were more fueling stations available. At present, there are two Clean Energy CNG stations in Houston that I am aware of. Thanks for considering my suggestion, Jim Blocher


1.1 Response to Jim Blocher February 13, 2009 Dear Mr. Blocher:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP).

Your question concerned a grant for the installation of a retail Natural Gas

Vehicle fueling station in the City of Lake Jackson. We encourage interested citizens toseek private or public agencies in applying for a grant(s) under the Clean Vehicles program. The Houston-Galveston Area Council’s Clean Vehicles program is afuel/technology-neutral grant program that funds cost-effective engine retrofit, repower, replacement, conversion (to alternative fuels), or the establishment of publicly accessiblealternative fuel infrastructure. You may visit www.Houston-cleancities.org for additional information.

You can follow the progress and see a more detailed summary of the SIP process,the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx



2.1 Comment from Troy Miller

From: troy miller [mailto:[email protected]] Sent: Monday, December 08, 2008 4:43 PM To: Spain, Mary Subject: comment on upcoming meeting After reading the Brazosport Facts paper online I had to reply. Your office is requesting comments for insight. Here goes... I had worked in the brazosport area for afew years doing environmental monitoring at Dow, Testing process equipment for emissions, inspections on RCRA lines through out Dow Freeport, then after becoming a master tech for my firm, I became a manager of change. Then ended my tour doing projects at Dow. I have to ask, HOW CAN I SPEND TWO YEARS DOING WHAT I DID, SEEN WHAT I SEEN, AND NOONE ELS HAS. I remember one day in early spring 04, I was working aproject, and was looking for a tower that had been monitored the month before, come to find out the tower had been gone for 3+years! Now tell me how it was monitored the month before? EAI who does the monitoring at dow hushed me up. At the end of each year Dow has over 500.000 componets which must be monitored right! Not all were never found, and EAI swept it under the mat. You may have a 3"valve beside the buc-ees store on hwy 332, do you think it was monitored? WELL NOPE! If your office really wants to help, here is how you can start. During the last three weeks of monitoring for 4Q08 at Dow, Send ateam to follow all the 10 or so tech's while they monitor all the site DTM'S and ALL annuals. And when you do you will do Three things. One: you will wonder how in hell they ever got monitored in the first place thats if they are even found, Two; Lord we have LEAKS, And last you will see the people of brazosport are in danager. Thank You


2.2 Response to Troy Miller February 13, 2009 To: [email protected] Dear Mr. Miller:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP). Since your comments deal with the monitoring of point source emissions at industrial plants, a subject not directly related to the mobile source SIP process, your comments have been forwarded to the Texas Commission on Environmental Quality for their review and response.

You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx

Sincerely,

Shelley Whitworth Air Quality Program Manager


3.1 Comment from Leo Waltz

From: Leo Waltz [[email protected]] Sent: Thursday, December 11, 2008 12:36 PM To: Air Quality Study Subject: Industrial airborne dust After seeing the article in the Chronicle, I visited the web address provided, but the complexity of that web site in trying to find anything led me to write this email instead. Also I realize that the concerns are mostly about ozone, but one item often overlooked is dust that emanates from sand, gravel and concrete companies as well as other industries. A good example is near where I live. Sometimes the airborne dust is so heavy from the plant on State Hwy 3 in Webster (between NASA Parkway and Medical Center Blvd.) that it appears to be a heavy fog. Yet it is obvious where it is coming from. Airborne dust particles can cause breathing problems among some people. I would like to see some controls on airborne dust from industrial plants that are near residential areas. These are typical questions I would like addressed: If there are dust particle standards, are there any ordinances to uphold those standards? If there are ordinances, is there any enforcement of them? The plant I referenced also has high noise levels at many hours, but since no one controls noise pollution except an unenforced city ordinance in Webster, then that aspect of an industrial plant is uncontrolled except maybe for some OSHA hearing protection rules for the employees at the plant. Thanks for reading. Leo Waltz P.O. Box 580037 Houston, TX 77258-0037 281-316-2255


3.2 Response to Leo Waltz

February 13, 2009 Mr. Leo Waltz P.O. Box 580037 Houston, Texas 77258-0037 Dear Mr. Waltz:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP). Since your comments deal with airborne dust at industrial plants, a subject not directly related to the mobile source SIP process, your comments have been forwarded to the Texas Commission on Environmental Quality for their review and response.

You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx



4.1 Comment from Peter Wang

From: Peter Wang [[email protected]] Sent: Saturday, December 27, 2008 6:59 PM To: Air Quality Study; Mergo, Cheryl; BikeHouston Advisors Subject: Comment on bicycle-pedestrian portion of Mobile Source Control Strategies document I agree with the methodology employed on pages 116 - 119 of the Environ Corp. "Evaluation of Mobile Source Control Strategies Document" (by Ms. Barbara Joy) for evaluating the cost per ton of ozone reduction for bicycle-pedestrian modes, but I heartily disagree with the choice of data inputs, and therefore with the conclusions. Basically, I think the results are meaningless. The $390,000 per ton figure should be replaced by $12,200 per ton. The investigator takes $96 million in bike-ped projects as the numerator and divides that dollar amount by the estimated tonnage of ozone eliminated. The problem with this large numerator, however, is that the local bicycling community has had absolutely no input into this bicycle plan, and there has been zero buy-in to the alleged commuting utility of this plan which has been assumed by the investigator. If you take a look at the cited plan, you will see that the bulk of it is recreational in nature. The consultant is also caught in the mental trap that, like cars, all you need to do is build infrastructure and it will get used. That is not the situation with bikes, because of suppressive social and cultural factors which could be much less expensive to change than building new infrastructure. What am I referring to? I am referring to governments:

• actually actively encouraging people to ride bikes on the roads (which would be a 180 degree shift from the current Harris County stance)

• enforcing speed limits, and lowering speed limits generally • enforcing drunk driving and distracted driving laws • prosecuting road-rage and assaults against bicyclists • making use of the corps of dozens of low-cost (or in some cases free volunteer) League

of American Bicyclists Cycling Instructors in the Houston area • enforcing laws that cyclists break that endanger cyclists (running stops signs and lights,

and riding in the dark without lights, and riding against traffic) What is the cost of these types of actions? The "encouraging" actions are almost free. Strongly enforcing speed limits, DWI, and distracted driving should be done anyway, and those costs should not be borne by cyclists, but generally. The Vehicular Assault team at the Harris County DA's office could be beefed up. The education component could be quite low cost, since the instructors will work for little money mostly for the joy of teaching, but they need to be made part of an official adult bicycle educational program that governments widely promote to the public. Writing tickets for traffic violations by cyclists could be revenue neutral. I think we're not talking about $96 million, honestly I am guessing at a multi-year program cost of maybe $3 million, in my estimation, which would lead to ozone reduction costing $12,200 per ton.... not $390,000 per ton. I am writing this letter as an individual, but my affiliations are listed below.


Thank you. -- Sincerely, Peter Wang League of American Bicyclist Instructor Board Member, Citizens' Transportation Coalition Advisor to BikeHouston


4.1 Response to Peter Wang February 13, 2009 To: [email protected] Dear Mr. Wang:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP). Your comments about the cost effectiveness for bicycle-pedestrian projects are greatly appreciated. Our consultant’s figures were taken from data in the Regional Transportation Plan for our region, based on the project cost forbuilding additional bike and pedestrian projects We agree with you that additional education and encouragement as well as additional enforcement of safety rules already in place will promote increased bicycle and pedestrian activities and bring further emission reductions due to increased usage of already existing facilities. Unfortunately, themeasures that you mention in your letter do not meet all of the EPA criteria necessary to be included in the SIP (permanent, surplus, quantifiable and enforceable) and were not able to be added to the short list of control measures.

We do value your input and we encourage you and the whole bike community to

become involve in our Transportation Improvement Program (TIP) and Regional Transportation Plan (RTP) which will be updated this year. Please go to 2035plan.org for more information.

You can follow the progress and see a more detailed summary of the SIP process,the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/.

Sincerely,



5.1 Comment from Sierra Club


5.2 Response to Sierra Club

February 17, 2009 Mr. Brandt Mannchen Lone Star Chapter of the Sierra Club Houston Regional Group P.O. Box 3021 Houston, TX 77253-3021 Dear Mr. Mannchen: Thank you for your comments regarding the 2006 and 2008 mobile source Control Measures for the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP). The Texas Commission on Environmental Quality (TCEQ) and H-GAC continue to examine a wide range of voluntary control measures. Additionally, your letter commented specifically on sections of the report as well as specific control measures. Responses to each of these comments follow:

1) Page 1-1, in the first paragraph of “1. Background and Purpose of Study”: Both statements are correct. The primary objective is to reduce NOx. Strategies are identified in the study that will help the region achieve this primary objective. Many of the strategies reduce volatile organic compounds (VOCs) as well as nitrogen oxides (NOx).

2) Page 2-1, Refining Initial Master List: For those measures which have a minimal

effect on emissions and have been grouped with other measures, the individual emission reductions resulting from these is still available in Appendices F, G, and H of the final draft control measure report.

3) Page 2-1, Evaluating Feasibility and Potential for Emission Reductions: The word

“model” is used in this sentence as a reference for calculations done based on certain assumptions.

4) Page 3-1, Qualitative Review of Master List: four criteria were developed by the EPA to guide state and local governments in developing control strategies for the SIP, to improve local air quality, and comply with federal regulations. Satisfaction of these criteria is necessary to generate an emission reduction that is creditable in the SIP.

Emission reductions are “Permanent” if they can be ensured that no emission increase (compared emissions in the absence of the project) occur over the time the emission reductions are relied upon in the SIP. They are “Surplus” as long as they not otherwise relied on other Air quality-related programs in the SIP, SIP-related requirements, other State air quality programs adopted but not in the SIP, or federal rules that focus on reducing criteria pollutants or their precursors. They are “Quantifiable” if they can be reliably measured or determined, and if these determinations can be independently verified and replicated. Emission reductions are “Enforceable” if they employ a methodology to ensure that the promised emission reduction actually occurs. If a program cannot be created (or defined), then the Control Measure does not satisfy the enforceable requirement of the four criteria, and is not selected for the “Short List”.


Professional experience and judgment were factors critiqued during the consultant selection process. ENVIRON uses professional judgment based in professional experience, research, and identification of Control Measures being enforced in this and other regions. Many Control Measures that were not enforceable were excluded from this study. This practice was followed to focus discussion, time, energy, and resources upon Control Measures that could either satisfy all four criteria, or ENVIRON believed that the region should determine the feasibility or acceptability of the Control Measure.

5) Page 4-1, 4. Summary of Measures: We refer you to answers given to questions and comments made in item number 4 above. Regarding best professional judgment, this was used to establish the list of Control Measures within the study. Professional judgment encompasses many facets including professional experiences, knowledge of best practices, research of the ingenuity and improvement of technology, observing the success of similar Control Measures currently being used inside and outside the region, and studying the feasibility of near future possibilities.

6) Pages 4-2 through 4-22, Table 4-1, On-road vehicle emission reduction measures: H-GAC appreciates Sierra Club’s comments on this list of measures. H-GAC has attempted to take your comments into account for those measures which you have commented on For the questions or comments that Sierra Club made on On-Road Control Measures which did not progress to the “Short List’, no response is provided.

7) Pages 4-22 through 4-26, Table 4-1, Non-road vehicle emission reduction measures: H-GAC appreciates your comments on current measures and suggestions of measures to include. H-GAC will follow the public participation process in informing decision makers of your concerns.

Throughout the latter part of 2008, H-GAC worked to quantify and refine this Master List into a Short List of measures which the Houston-region will recommend to TCEQ for implementation in early 2009 as part of the SIP. You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road Control Measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx Additionally, we encourage you to continue to be involved with the SIP process. I am happy to provide more information about the form and scope of these Control Measures by phone (713-499-6695) or email ([email protected]).

Sincerely,



6.1 Comment from Charles Stillman


6.2 Response to Charles Stillman

February 13, 2009 To: [email protected] Dear Mr. Stillman:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP) Draft Short List. We have received your port and marine control strategy comments and will transfer them to the appropriate agencies.

Your comment expressed support for increasing marine engine control standards,

promoting the use of clean fuels for marine vessels, and the creation of clean air action plans for local ports. We will take this support into account when creating the Final Short List for submittal to the Texas Commission on Environmental Quality. You can follow the progress and see a detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx

Sincerely,



7.1 Comment from Carol Caul


7.2 Response to Carol Caul

February 13, 2009 Ms. Carol Caul President Energy Business Inc, 685 North Post Oak Lane Houston, TX 77024-4606 Dear Ms. Caul:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP) Control Measures Short List. The Texas Commission on Environmental Quality (TCEQ) and H-GAC continue to examine a wide range of voluntary control measures. Your letter commented specifically on sections of the report as well as specific control measures. Responses to each of these comments follow:

• Pay as you drive insurance vs. VMT tax: H-GAC appreciates your comments. VMT taxes

are implemented on a state or federal level rather than a local level. Since the control measures that H-GAC can place on the Final SIP Control Measures Short List must be implemented voluntarily by local governments, this measure will be removed from the final report. Alternatively, pay as you drive insurance can be implemented by insurance providers as a service to their customers. Because of this difference, the pay as you drive insurance measure will remain a part of the Final SIP Control Measures Short List.

• Bicycles-benefits are incorrectly analyzed and undercounted: Your comments about the cost effectiveness for bicycle-pedestrian projects are greatly appreciated. Our consultant’s figures were taken from data in the Regional Transportation Plan for our region, based on the project cost for building additional bike and pedestrian projects as well as forecasts for use of new and existing trails.

• On-road speed reduction: both heavy and light vehicles: H-GAC appreciates your comments. Because this control measure cannot be implemented locally, it is not included in the “short list”.

• Fuel reformulations & vehicle efficiency standards: H-GAC appreciates your comments.

Because these control measures cannot be implemented locally because they cannot be enforced, it was removed from the ”short list”.

• Voluntary measures requiring behavior modification & demand reduction, reporting &

verification systems / idling – mandatory and voluntary: H-GAC is currently working with government and business entities within the Houston-Galveston-Brazoria region to develop both the infrastructure (such as truck stop electrification or the installation of auxiliary power units), the regulatory structure, and the Memoranda of Agreement necessary to implement these control measures as part of the SIP.


• Electric vehicles: H-GAC recognizes the practical difficulty in the integration of budding technology into established systems and it may not be practicable at this time, however in future years it may be practicable.

• Stations and facilities for alternative & new fuels: H-GAC appreciates your comments.

• Compressed work schedules: H-GAC appreciates your comments and has already

lumped this control measure and teleworking with other commute solution control strategies.

• Heavy Duty Vehicle Border Inspection Program control measure should be withdrawn from H-GAC short list: H-GAC appreciates your comments. You are correct, and this control measure will be removed from the final report.

You can follow the progress and see a more detailed summary of the SIP process, the

timetable for the rest of the process and the on‐ and non‐road control measures at the H‐GAC SIP website: http://www.h‐gac.com/taq/airquality/sip/mobile/default.aspx



8.1 Comment from Port of Houston Authority


8.2 Response to Port of Houston Authority

February 13, 2009 Ms. Dana Blume Port of Houston Authority P.O. Box 2562 Houston, Texas 77252-2562 Dear Ms. Blume:

Thank you for your comments regarding the State Implementation Plan’s (SIP) short list of control strategies for on-road and non-road measures. The Texas Commission on Environmental Quality (TCEQ) and H-GAC continue to examine a wide range of voluntary control measures. Your letter commented specifically on several aspects of non-road control measure number 45. Responses to each of these points follow:

• Clean Port Initiative: Thank you for your comment. The Houston-Galveston Area

Council supports implementation of air quality improvements by all of the Houston-Galveston-Brazoria (HGB) region’s ports. To reflect this, the wording of this measure will be changed to encourage the development of clean air action plan at all ports within the HGB region.

• Vessel Speed Reduction and Reduction of At-Berth OGV Emissions: Port of Houston Authority as well as the other ports located within the HGB region will develop clean air action plans tailored towards each facility’s specific needs and abilities. Should vessel speed reduction and at-berth OGV be removed from consideration as part of a proposed clean air action plan, expected emission reductions for this measure would be reduced accordingly.

• OGV Auxiliary Engine & Main Engine Fuel Standards: Thank you for your comment. Since fuel standards can only be implemented as a state or federal level and since H-GAC can only place control measures that can be implemented voluntarily on a local level, this measure will be removed from the final report.

• OGV Main and Auxiliary Engine Emissions Improvements: Thank you for your comment. This will be applied only as a voluntary measure. You can follow the progress and see a more detailed summary of the SIP process, the

timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx

Sincerely,



9.1 Comment from Smith Electric Vehicles


9.2 Response to Smith Electric Vehicles

February 13, 2009 Mr. Bryan Hansel, CEO Smith Electric Vehicles US 141616 Carter Road Overland Park, KS 66221 Dear Mr. Hansel:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP). Your comment focused on Draft Short List Control Measure #7, regarding the replacement of internal combustion engine vehicles with electric vehicles. H-GAC agrees with your assessment that by adjusting the measure to focus on replacing all weight and duty vehicles with electric versions would provide greater emission reductions than simply focusing on light-duty vehicles. This control measure is part of our “short list” and would be applied only as a voluntary measure.

Thank you again for your feedback on this control measure. You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/mobile/default.aspx



10.1 Comment from Harris County, Texas


10.2 Response to Harris County, Texas

February 13, 2009 Mr. J. Marcus Hill First Assistant Harris County Attorney’s Office 1019 Congress, 15th Floor Houston, TX 77002-1700 Dear Mr. Hill:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP) Control Measures Short List. The Texas Commission on Environmental Quality (TCEQ) and H-GAC continue to examine a wide range of voluntary control measures. Additionally, your letter commented specifically on sections of the report as well as specific control measures. Responses to each of these comments follow:

• Qualitative Review of Master List, 1-3: Thank you for your comment. The final version

of the report will clarify and expand the description of PQSE and other SIP criteria.

• Quantified Evaluation of Measures, 5-1: The voluntary control measures which become part of the final SIP submittal to TCEQ can and will only be adopted by TCEQ in the event that an entity within the Houston-Galveston-Brazoria region is able to commit to create, implement, and enforce the control.

• Bicycle and Pedestrian Action, Id. 1: H-GAC understands that the conversion of roads to

bicycle lanes is not possible or practicable in all cases. Nonetheless, retrofitting existing roads to accommodate bicycle lanes is a common practice and is only one of the options explored in this measure which H-GAC feels should be available to local governments to enact where appropriate.

• Public Agency Clean Fleet Program, Id. 6: H-GAC appreciates your comment and will

edit the final report to account for your suggestion.

• Electric Vehicles, Id. 7: H-GAC recognizes the practical difficulty in the integration of budding technology into established systems and it may not be practicable at this time, however in future years it may be practicable.

Cleaner Diesel Fuel, Id. 11: H-GAC appreciates your comments. This control measure would be implemented only as a voluntary measure. This does not disqualify this measure from inclusion in the SIP

• Preferential Parking for HOV Lane Users, Ids. 39 and 47: Since this is a voluntary measure, it is not necessary that all entities within the region participate in each measure. In the case of this particular measure, all entities may not be able to implement due to issues such as those which you mentioned in your comment. This does not disqualify this measure from inclusion in the SIP


• Local or Regional Fuel Taxes/Vehicle Taxes, Ids. No. 59-60: H-GAC appreciates your comments. Because this control measure cannot be implemented locally, it will be removed from the final report.

• Traffic Signals and Flows, Ids. 76-83: H-GAC congratulates Harris County on their

visionary efforts in emission reductions, and encourages them to enter into an MOA so that their reduction efforts can be properly cataloged in the SIP.

• Mandatory or Voluntary Compressed Work Week, Id. 106: H-GAC congratulates Harris

County on their visionary efforts in emission reductions, and encourages them to enter into an MOA so that their reduction efforts can be properly cataloged in the SIP.

• Purchase Vans for Vanpools, Id. 109: H-GAC supports a successful program

encouraging this particular control measure. The participation level in this program supports the validity of offering this control measure to the entities of the region.

• Limitations on Idling of Heavy-Duty Vehicles, Id. 126: As noted in your comment, TCEQ

does promote this control measure in other metropolitan areas throughout Texas. H-GAC is monitoring these existing anti-idling programs outside of the region and has begun to promote this option within the Houston-Galveston-Brazoria region.

• Enhanced Enforcement for Smoking Vehicles Program, Id. 139: H-GAC recognizes the

important role of law enforcement in this control measure. H-GAC is currently working with jurisdictions within the Houston-Galveston-Brazoria region to develop funding and methodology for such a program.

• Voluntary Replacement/Retrofit Programs, Id. 5b: H-GAC appreciates your comments.

• Government Construction Incentives, Id. 8: H-GAC appreciates your comments on this control measure. The inclusion of any of these measures within the SIP is contingent upon the creation of voluntary commitments from local governments. If a local government does not specifically commit to this measure, it will not be legally bound to carry it out despite inclusion of the measure within the SIP.

• Landscape Ordinance, Id. 29: Since this is a voluntary measure, it is not necessary that all entities within the region participate in each measure. In the case of this particular measure, all entities may not be legally able to implement due to issues such as those which you mentioned in your comment. This does not disqualify this measure from inclusion in the SIP

• Readability for the Public: H-GAC appreciates your comments, and will work to

improve readability for the general public in the final report.

You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/mobile/default.aspx


APPENDIX E

Overview of the Transportation Control Measures to Be Included as Part of the Houston-Galveston-Brazoria Eight-Hour Ozone State Implementation Plan Submittal

G:\HGAC\Reports\Final_051009\Appendix E_051009.doc E-1

Transportations Control Measures (TCMs) were reviewed and chosen as part of the work of the TCM/VMEPs Working Group, which consisted of local government representatives. This committee worked to evaluate projects in the current Transportation Improvement Plan (TIP) for the Houston-Galveston-Brazoria for possible designation with TCM status in the SIP. Once projects were singled out for inclusion, project sponsors were notified and agreed to upgrading their project(s) to TCM status. The Technical Advisory Committee and H-GAC staff reviewed the responses to these notifications and narrowed the possible candidates to the attached list.

G:\HGAC\Reports\Final_051009\Appendix E_051009.doc E-2

RECOMMENDED TRANSPORTATION CONTROL MEASURE PROJECTS

CSJ # MPO ID # Sponsor Street Description

NOx Emission Reduction (tons/day)

Cost Effectiveness

($/ton)

0912-72-145 11972

Greater Southeast Management District Holman

Pedestrian Improvements 0.0001862 253,871

0912-72-146 11973

Greater Southeast Management District

Elgin, Ennis, Alabama

Pedestrian Improvements 0.0004562 172,066

0912-72-147 11006 Uptown Houston Association Westheimer

Pedestrian / Transit Improvement Program 0.0137628 85,027

0912-71-544 2930 City of Houston

Columbia Tap Rail to Trail Construct Bikeway 0.0002721 4,376,248

0912-71-801 10350 City of Houston

Columbia Tap Union Station Trail

12' Wide Concrete Shared Use Path with 5’ Bike Lane 0.0005840 692,274

0912-71-655 6085 City of Houston Terry Hershey Park

West Houston On-Street Bikeway Network (Phase 2) 0.0001653 3,420,128

Total 0.0154266

APPENDIX F

Detailed Evaluations for On-Road Control Strategies

G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure1-Bike-EM_051009.doc

Control Measure: #1 and #32, Bicycle and pedestrian actions Category: On-road Author: Barbara Joy, Earth Matters DESCRIPTION Bicycle measures encouraged by bicycle and pedestrian action groups include new bicycle lanes, new bikeway plans, and encouraging greater use of existing lanes instead of vehicle use. Bicycle action groups and other bicycle measures included in the Houston-Galveston Area Council’s (H-GAC) Regional Bikeway Plan from the 2035 RTP are evaluated below. The Regional Bikeway Plan, described in Appendix G of the 2035 RTP is intended to serve as a guide for investment, interagency coordination and best practices in developing facilities for bicyclists in the 8-county Houston-Galveston Transportation Management Area (TMA). The plan may be reviewed at http://2035plan.org/docs/final/Appendix%20G-%20Draft%20Ped%20Bike%20RTP%20Appendix.pdf. The plan acknowledges that the current level of bicycle travel within the Transportation Management Area (TMA) is not precisely known, making it difficult to define a benchmark for increases in bicycle travel replacing vehicular travel. Unfortunately, the Houston-Galveston region also has one of the highest rates of crashes involving motorists and bicyclists in Texas. Notable examples of local bikeway networks include Alvin, Conroe, Houston, Lake Jackson, La Porte, Missouri City, Pasadena, Sugar Land, and The Woodlands. H-GAC plans to continue to work with local entities to identify projects that further the development of local bikeway networks as part of the overall regional transportation system. There are two employment centers within the TMA that generate a significant level of bicyclist commuters: the Texas Medical Center in Houston and the University of Texas Medical Branch (UTMB) in Galveston. The Texas Medical Center (TMC) draws the greatest amount of commuter bicyclists of any employment center in the TMA. According to the 2000 census, there were 50,238 work trips, of which 36,973 drove alone, 7,927 carpooled, 4,018 took the bus, 430 walked, 379 biked, and 511 used other means (motorcycle, taxi, permanent telecommute). The 430 walking trips and the 379 biking trips represent 0.9% and 0.8% respectively of all trips. The Texas Medical Center has the highest concentration of bicyclist trips within a census tract in the region (even greater than Downtown Houston), and the third highest concentration of walking trips in the region (after downtown and the University of Texas Medical Branch in Galveston). Recent observations made by H-GAC and TMC staff indicate that over 1,000 bicyclists now commute to the Texas Medical Center on a daily basis. The 2000 Census indicated that UTMB had 10,470 daily work trips. Of these 89% were by private vehicle, 1.3% by bus, 2.2% by bicycle and 5.3% walking trips. These are much higher than the regional average of 0.3% by bicycling and 2.1% by walking.


ANALYSIS This analysis is based on the assumption that every major employment center in the Houston metropolitan area grows to the same level of bicycle use as the UTMB, due to the expansion of regional bikeway plans, the high cost of driving, and the efforts of bicycle and pedestrian action groups. According to modeling results for 2018 from the H-GAC transportation model the following shows employment by major employment center in Houston. Table 1. Employment at Major Employment Centers in Houston Area in 20181. Employment Center 2018 EmploymentBellaire/Pin Oaks 19,837 Brookhollow 49,843 CBD 146,600Clear Lake/NASA 42,444 Galleria 141,801Greenspoint 94,052Greenway Plaza 60,416Medical Center 135,749Northwest Crossing 53,225Sharpstown 38,512The Woodlands 30,379West Houston 105,335Westchase 80,799Total 998,992

On an average weekday it is assumed that 2.2 percent of these employees bike to work an average of 3.5 miles each way. This would mean 21,978 people per day are commuting by bicycle by 2018 and reducing 153,845 miles of travel per day, if they were previously driving, and a weekday/weekend adjustment is applied. The estimate also assumes that nearly zero individuals were biking in the baseline. This is consistent with the 0.3% figure cited in the description above. EMISSIONS ANALYSIS The emissions analysis utilized the basic process suggested by the MOSERs methodology, as follows: Variables: EFA: Speed-based composite emission factor after

implementation (NOx , VOC, or CO) grams/mile)

EFB: Speed-based running composite emission factor before implementation (NOx , VOC, or CO) (grams/mile)

1 Personal Communication Sharon Ju, H-GAC to Barbara Joy, Earth Matters. November 10, 2008.


NVA: Number of vehicles after implementation NVB: Number of vehicles before implementation TEFAUTO: Auto trip-end emission factor (NOx , VOC, or CO)

(grams/trip) TLA: Average auto trip length after implementation (miles) TLB: Average auto trip length before implementation (miles) VMTA: Vehicle trips after implementation VMTB: Change in VMT as a result of implementation

It was assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emission factors and the assumption that access to alternative modes is not through SOV use. Equation:

Daily Emission Reduction =

C = VMTB * EFA = 153,845 * 0.171 gram/mile NOx/454 = 57.9 lb/day, and 0.03 tpd NOx and 153,845 * 0.231 gram/mile VOC/454 = 78.3 lb/day, and 0.04 tpd VOC.

COST EFFECTIVENESS H-GAC’s current TIP contains over 41 pedestrian and bicyclist projects, representing an investment in nearly of $87 million. The 2025 RTP, with subsequent amendments, contains an additional 61 pedestrian and bicyclist projects with a projected cost in excess of $96 million. In addition, a number of local governments have made significant local funding commitments to bikeway development in their current Capital Improvements Programs. The cost effectiveness evaluation assumes that a $200 million investment is made to implement all pedestrian and bicycle projects in the TIP and RTP and local plans, and that this investment is made over a 20 year period. Using a simple linear assumption, this would equate to $10 million per year.


Total emission savings from NOx and VOC combined is 25.6 tons per year; cost effectiveness is therefore $390,625 per ton. COMMENTS This evaluation is based on assumptions consistent with current statistics and implementation of planned bike and pedestrian projects in the 2008 RTP and TIP. It may be considered for use in ozone plan after review of key assumptions. SUMMARY OF RESULTS

Expected Emission Reduction Measure

ID Name Description Affected Source

Affected Emissions

(tpd) % Tpd

Cost Effectiveness

($/ton) 1 Bicycle

and pedestrian action groups

Growth in biking to consistent with current UTMB levels

On-Road – Light-duty vehicles

40.7 VOC 30.3 NOx

0.1 0.1

0.04 0.03

$390,625

G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control Measure 3 Clean Cities_051009.doc

Control Measure: #3, Private Sector Clean Fueled Fleets Category: On-road Author: Chris Lindhjem, ENVIRON DESCRIPTION This measure seeks to reduce on-road vehicle emissions by rapid turnover to newer lower emitting engines, retrofit of existing engines with approved devices, or new lower emission technologies. These programs have been mandated or voluntarily implemented with federal incentives or state funding from programs like TERP. In Houston, H-GAC administers a program under The Clean Cities/Clean Vehicles Program (http://www.houston-cleancities.org/#) where Congestion Mitigation and Air Quality (CMAQ) funds are distributed to replace and retrofit lower emitting heavy-duty. In Texas, the popular TERP program has been successful in co-funding many emission reduction projects of many different types including on-road trucks, construction and off-road equipment, marine vessels, and locomotives. To date, about $300 million of projects have been approved in the HGB area from 2002 through 2008 with the most of the funding occurring in the 2004 through 2008 period. Because the most recent projects have just been approved, not all of the emission reductions have been realized and are still pending IMPLEMENTATION FEASIBILITY Programs of this type have been successfully established in Houston, Los Angeles, and Sacramento. The program implementation relies on a partnership between the transportation planning organization, H-GAC, and TxDOT and FHWA to properly distribute CMAQ dollars. H-GAC has dedicated staff time to administer the program addressing funding, preparing contracts, conducting verifications, reporting, and other functions of this program. PUBLIC ACCEPTANCE The program has been successful in Houston in the most recent years. The similar TERP program has also demonstrated high participation and has lowered the cost per emission reduction during the 2005 fiscal year from previous years. ANALYSIS The benefit of a voluntary retrofit or replacement program targeted at emission reductions in the 2015 - 2018 timeframe would center on the replacement of trucks with those


meeting the 2010 emission standards that call for a dramatic reduction in the NOx emission rates as shown in the Table 1 summary of emission standards. Table 1. Emission standards for heavy-duty truck engines (differences exist for buses and whole vehicles and a pull ahead of the implementation date for many truck engines in the 2003 model year by a consent decree).

Federal Heavy-Duty Truck Standards (G/bhp-hr)

MODELYEAR HC1 CO NOx PM HC+NOx Opacity 1974-78 --- 40.0 --- --- 16.0 No 1979-83 1.5 25.0 --- --- 10.0 No 1984-871 1.3 15.5 10.7 --- --- No 1988-89 1.3 15.5 10.7 0.60 --- Yes

1990 1.3 15.5 6.0 0.60 Yes 1991-93 1.3 15.5 5.0 0.25 --- Yes 1994-97 1.3 15.5 5.0 0.10 --- Yes 1998-03 1.3 15.5 4.0 0.10 --- Yes

2004-2006 0.52 15.5 2.03 0.10 2.52 Yes 2007 (50% of Fleet) <0.5 15.5 ~1.1 0.01 --- Yes

2010 0.142 15.5 0.2 0.01 --- Yes 1 – Test procedure change. 2 – HC standards shown are total hydrocarbons except for model year 2004-2006 when it is NMHC. 3 – Assumes 2.5 g/bhp-hr (NOx+NMHC) with a 0.5 g/bhp-hr NMHC cap effective October 2002. The analysis of the cost and effectiveness of these programs relies on the progress of the TERP and H-GAC Clean Cities programs. Other programs such as the California Carl Moyer program demonstrate similar costs and effectiveness, but rely on evaluations specific to California. Through 2008, the H-GAC Clean Cities/Clean Vehicles program had committed funding to many projects. The projects include alternative fueled vehicles, hybrid-electric drive trains, and clean diesel engines. These projects produced NOx, PM, and some VOC emission reductions. Individual truck replacement/retrofit projects funded by CMAQ in the Houston area in 2008 averaged approximately $20,000 to $40,000 per vehicle with typical clean engine costs running at about $60,000 to $80,000 focusing primarily on the larger engines. TERP funded projects have been running at an average of just over $40,000 per truck project. Table 6 indicates most recent information on the benefit and cost per project from the TERP program in the HGB area. The most typical project was to replace current equipment that would not necessarily be replaced otherwise. However, regardless of the inflation rate, the new engine costs are expected to increase because of the new emissions standards, so the current TERP figures may underestimate the cost of future projects. Also, some TERP projects combine two or more categories of project types, and the figures here can vary depending upon the size of the engine and other considerations. The figures in Table 6 are approximate and may change as the projects are implemented and reviewed.


Table 2. TERP implemented and pending projects in HGB

Project Type Total Cost Number ofProjects

Cost per Project

Total NOx Reduced

(tpd)

NOx Reductionper Project

(tpy) Locomotive $75,996,969 116 $655,146 7.29 22.95Marine $39,216,837 400 $98,042 5.99 5.46Non-road $81,284,069 1,995 $40,744 7.86 1.44On-road $103,974,922 1,867 $55,691 10.63 2.08 EMISSIONS AFFECTED This measure would affect about 21 tpd of NOx in 2018 on-road heavy-duty emissions in the eight-county HGB ozone nonattainment area. This measure would address heavy-duty diesel, heavy-duty gasoline, and buses as shown in Table 3. Table 3. On-road weekday emissions 8-County totals (tpd)

Pollutant Light-duty Heavy-Duty

Gasoline Heavy-Duty

Diesel Total VOC 40.69 0.80 3.15 44.64 CO 691 13 5 709 NOx 30.31 1.88 19.67 51.69 EMISSIONS BENEFIT Table 4 provides the average emissions factors, registration distribution, and mileage accumulation derived from the MOBILE input files used in the HGB emissions modeling. About 15% of the NOx emissions were projected to come from 2001 and early model year trucks in 2018, but 50% from the model years 2002 through 2009. Table 4. Class 8b Truck approximate emission rates Model Year Age VOC CO NOx

Mileage Accumulation

Registration Distribution

1994- 24 0.66 3.08 22.79 11,765 0.00991995 23 0.65 3.06 22.79 12,979 0.00311996 22 0.64 3.03 22.17 14,319 0.00351997 21 0.64 3.01 22.41 15,796 0.00411998 20 0.64 3.00 21.08 17,426 0.00431999 19 0.63 2.98 18.17 19,224 0.00572000 18 0.63 2.97 18.15 21,208 0.00742001 17 0.63 2.95 18.13 23,396 0.00802002 16 0.62 2.93 12.43 25,810 0.00902003 15 0.61 2.91 8.88 28,473 0.00582004 14 0.48 2.88 7.78 31,411 0.02162005 13 0.47 2.86 7.75 34,652 0.02822006 12 0.46 2.83 7.71 38,228 0.03662007 11 0.26 0.24 4.21 42,172 0.03452008 10 0.26 0.24 4.18 46,523 0.04192009 9 0.26 0.24 4.15 51,324 0.05862010 8 0.26 0.24 0.61 56,620 0.08952011 7 0.26 0.24 0.61 62,462 0.1050


Model Year Age VOC CO NOx

Mileage Accumulation

Registration Distribution

2012 6 0.26 0.24 0.61 68,907 0.06652013 5 0.26 0.24 0.61 76,017 0.02982014 4 0.26 0.24 0.61 83,861 0.05232015 3 0.26 0.24 0.61 92,514 0.04262016 2 0.26 0.24 0.61 102,060 0.09432017 1 0.26 0.24 0.61 112,590 0.11102018 0 0.26 0.24 0.61 124,208 0.1269

Replacing an older truck would produce emission reductions through the use of lower emission vehicles. A better case and a most expensive case were modeled to determine the range of benefits and cost effectiveness. A better case scenario is to replace a model year 2000 truck with one of 2010 or later model years. Using the mileage accumulation for a 2000 model year truck and the difference in the emission rates would result in 0.009 tpy VOC and 0.41 tpy NOx. A less beneficial case is to replace a 2008 model year truck with a 2010 and later truck resulting in 0 VOC and 0.183 tpy NOx. Replacing two thousand older vehicles expected to be in use in 2018 with those meeting 2010 or later emissions standards would result in about 1 to 2.5 tpd emission reduction. COST AND COST-EFFECTIVENESS The current cost of on-road heavy-duty projects in both the TERP and H-GAC Clean Cities program has been running $20,000 to $40,000 per project. The better case and lower benefit case of replacing a 2000 and 2008 truck respectively used a project (remaining useful) life of 5 years for the 2000 truck and 10 years for the 2008 truck replacement. Applying the cost range, the life, and the benefit of the replacement examples, the cost effectiveness is expected to range from $11,000 to $25,000 per ton of NOx removed. Some small VOC benefit would also be found but not accounted for in this analysis. This is somewhat higher than the TERP program has achieved to date, but that is primarily due to the lower emission benefits from the replacement of trucks meeting more stringent emission standards. SUMMARY OF RESULTS

Expected Emission Reduction

Measure # Name Description Affected Sources

Affected Emissions

(tpd) % Tpd

Est. Cost Effective-

ness ($/ton)

3 Clean Fleet Vehicle

Procurement Policy/Clean

Fleet Program

Maintain a fleet program that

addresses clean vehicle

acquisitions of public and

private fleets.

On-road Heavy-

duty Vehicles

21.6 5 – 12% 1 – 2.5 $11,000 - $25,000 NOx


REFERENCES H-GAC, “Clean Cities and Clean Vehicles,” http://www.houston-cleancities.org/

G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control Measure 7 Electric Vehicles_051009.doc

Control Measure: #7, Zero Emission (Electric) Vehicles Category: On-road Author: Chris Lindhjem, ENVIRON DESCRIPTION The electric vehicle control measure consists of the voluntary inclusion of a greater percentage of zero emission vehicles (ZEVs) or zero emitting travel through the use of plug-in hybrids or other vehicles. This could occur through new purchases or a replacement program for existing vehicles. IMPLEMENTATION FEASIBILITY A study completed by National Renewable Energy Laboratory compares the near- and far-term scenario of specifications and retail prices between conventional vehicles (CVs), hybrid electric vehicles (HEVs) and plug-in hybrid-electric vehicles (PHEVs), summarized in Table 1 and 2, respectively. Plug-in hybrid-electric vehicles are characterized by a “PHEVx” notation, where “x” typically denotes the vehicle’s all-electric range (AER) – defined as the distance in miles that a fully charged PHEV can drive before needing to operate its engine. By this definition, a PHEV20 can drive 20 mi (32 km) all-electrically on the test cycle before the first engine turns-on.1 In addition, there are two main ZEV types in development: electric-only vehicles and hydrogen fuel cell vehicles (FCVs). Electric vehicles have been developed, but are generally only applicable for limited range applications. Fuel cell vehicles are currently a developing technology considered to be a possible alternative to gasoline/diesel vehicles in the future. PUBLIC ACCEPTANCE Technology needed to adopt this measure may not be cost-effective and could potentially be burdensome to vehicle manufacturers and consumers for such specialty vehicles. The program could target specific niches to partially achieve emission reductions. Options include targeting public or private sector fleets as demonstration programs for the implementation of ZEV technology and providing the infrastructure. ANALYSIS This measure was analyzed by comparing the emissions and costs compared to conventional vehicles. ZEVs were assumed to produce no emissions, so for example 1 “Cost-Benefit Analysis of Plug-In Hybrid Electric Vehicle Technology” by A. Simpson, National Renewable Energy Laboratory.


emissions associated with fuel (hydrogen) and electricity production were not included in this analysis. EMISSIONS AFFECTED This measure could affect about 40 tpd of VOC and 30 tpd of NOx 2018 on-road light-duty emissions in the eight-county HGB ozone nonattainment area. However, the most likely vehicle types to be replaced by zero emitting activity are the smaller passenger cars shown in Table 1. Table 1. On-road weekday emissions 8-County totals (tpd)

Pollutant Light-duty Passenger

Cars Light-duty

All Heavy-Duty Gasoline All

Heavy-Duty Diesel All Total

VOC 24.8 40.69 0.80 3.15 44.64CO 424 691 13 5 709NOx 16.6 30.31 1.88 19.67 51.69 EMISSIONS BENEFIT The emissions benefit of replacing the conventional vehicles (CV) with zero emitting cars by 2018 can be estimated by comparing the emission estimates for late model vehicles. Table 2 provides the expected emissions for late model vehicles. Table 2. Passenger car emission rates

Model Year VOC CO NOx Annual Mileage

2009 0.186 4.410 0.122 9,4562010 0.164 4.099 0.110 9,9472011 0.144 3.777 0.098 10,4632012 0.126 3.433 0.086 11,0062013 0.111 3.069 0.074 11,5772014 0.096 2.687 0.063 12,1782015 0.083 2.284 0.051 12,8102016 0.072 1.861 0.040 13,4752017 0.061 1.484 0.030 14,1742018 0.053 1.133 0.024 14,910

10 year total (tons) 0.014 0.353 0.009 119,996Per Year Emissions 0.0014 0.0353 0.0009 12,000 COST AND COST-EFFECTIVENESS According to Table 3, PHEVs give the highest cost compared to CVs and HEVs. The retail prices range from $29,435 to $50,184 with engine horsepower of 105 hp to 129 hp. Besides, HEVs are more expensive than CVs with comparable specifications.


Furthermore, in the long-term scenario shown in Table 4, HEVs and PHEVs achieve lower cost-of-ownership over time whereas CVs maintain at the same retail price. Table 3. Near-Term Scenario PHEV Specifications – Optimum DOH Vehicles1

Vehicle Curb Mass (kg)

Engine Power (kW/hp)

Motor Power (kW/hp)

DOH Battery Energy (kWh)

P/E Ratio (1/h)

SOC Window

Retail Price (US$)

CV 1429 122 / 163 -- -- -- -- -- $23,392 HEV0 1451 78 / 105 38 / 51 33% 1.5 33.4 37% $28,773 PHEV2 1451 78 / 105 38 / 51 33% 1.5 33.4 37% $29,435 PHEV5 1505 80 / 107 42 / 56 35% 3.6 15.9 39% $31,447 PHEV10 1571 82 / 110 44 / 59 35 6.9 8.6 41% $34,180 PHEV20 1678 85 / 114 47 / 63 35% 12.7 4.9 47% $38,935 PHEV30 1759 89 / 119 49 / 66 36% 17.2 3.8 53% $42,618 PHEV40 1824 91 / 122 51 / 68 36% 20.8 3.3 59% $45,655 PHEV50 1880 94 /126 52 / 70 36% 23.9 2.9 66% $48,162 PHEV60 1923 96 / 129 53 / 71 36% 26.4 2.7 73% $50,184 Table 4. Long-Term Scenario PHEV Specifications – Optimum DOH Vehicles1

Vehicle Curb Mass (kg)

Engine Power

(kW/hp)

Motor Power

(kW/hp)

DOH Battery Energy (kWh)

P/E Ratio (1/h)

SOC Window

Retail Price (US$)

CV 1429 122 / 163 -- -- -- -- -- $23,392 HEV0 1412 77 / 103 36 / 48 32% 1.5 32.8 37% $26,658 PHEV2 1412 77 / 103 36 / 48 32% 1.5 32.8 37% $27,322 PHEV5 1445 78 / 105 41 / 55 34% 3.5 15.7 39% $28,365 PHEV10 1481 79 / 66 42 / 56 35% 6.6 8.5 41% $29,697 PHEV20 1531 81 / 109 43 / 58 35% 11.8 4.9 47% $31,828 PHEV30 1569 82 / 110 44 / 59 35% 15.9 3.7 53% $33,533 PHEV40 1598 83 / 111 45 / 60 35% 19.0 3.2 59% $34,839 PHEV50 1618 84 / 113 45 / 60 35% 21.6 2.8 66% $35,857 PHEV60 1636 84 / 113 46 / 62 35% 23.6 2.6 73% $36,681 CV: Conventional vehicles DOH: Degree-of-hybridization P/E Ratio: Power-to-energy ratio SOC: State-of-charge According to Toyota Senior Vice President Jim Wilson, an electric vehicle costs $20,000 more to build than a comparable gasoline-powered car despite years of research. CARB staff estimates a cost premium of between $8,000 and $20,000 for production of an electric zero emission vehicle (ZEV) with performance characteristics inferior to those of a conventional vehicle.2 Table 5 illustrates the specification comparison between zero emission light and heavy-duty vehicles. The retail costs for light-duty vehicles range from $12,000 to $53,000 with horsepower from 5 hp to 72 hp. Zero emission heavy-duty vehicles are still under development, so a cost comparison would not be worthwhile to make at this point. 2 http://www.rff.org/RFF/Documents/RFF-Resources-142-zeroemmis.pdf


Table 5. Comparison between light and heavy-duty vehicles.

Specification Manufacturer/Model Name Retail

Cost Component Power Maximum

Speed Light-duty Vehicles

Miles Electric Vehicles XS 500 (full electric highway speed sedan)

$35,0003 Lithium-ion batteries 5.6 hp 105 mph

Miles Electric Vehicles ZX40ST (Electric Truck)

$18,4002 72-volt electric motor and a 150-amp-hour battery pack. (50-60 miles per

charge)

5.6 hp 25 mph

ZX40S (Electric Truck) $19,4992 72-volt electric motor and a 150-amp-hour battery pack. (50-60 miles per

charge)

5.6 hp 25 mph

ZENN (Model: NEV\LSV, 2-seat battery electric vehicle)

$12,000–$16,0004

Lead-acid batteries (30–50 miles per charge)

5 hp 25 mph

General Motors EV1 (Battery electric vehicles)

$40,0005 Gen II 1999, NiMH (150 miles per charge)

72 hp 80 mph

Honda EV Plus $53,0004 12 V NiMH (80–110 miles per charge) 66 hp 80+ mph Toyota RAV4 EV $40,0004 95 amp-hour NiMH battery pack (80-

120 miles per charge) 67 hp 78 mph

Toyota Prius Hybrid $19,9956 274V NiMH battery pack 58 hp Heavy-duty Vehicles

Navistar International $85,000 340 Volt Lithium Ion Battery 225 hp Balcon Electric Truck7 $208,500 To provide a cost comparison, a figure of $20,000 was used as the cost differential and a 15-year life was used resulting in an average annual capital cost of $1675 per year. If lower operating costs occur with these vehicles, then the cost differential is overstated. The cost effectiveness for replacing late model vehicles with zero emitting vehicles however is expected to be quite high by dividing the $1675 by the annual emissions figures in Table 2. This results in a cost effectiveness of over $1 million per ton of emissions reduced for VOC and NOx separately. In order to bring the cost effectiveness down to that of other strategies, the relative cost of production should be no more than $2,000 more per vehicle than conventional vehicles to make the air quality benefit close to other mobile sources measures.

3 http://en.wikipedia.org/wiki/Zero_emission_vehicle 4 http://en.wikipedia.org/wiki/ZENN 5 http://en.wikipedia.org/wiki/List_of_production_battery_electric_vehicles_(table) 6 http://en.wikipedia.org/wiki/Toyota_Prius 7 http://www.ens-newswire.com/ens/may2008/2008-05-21-092.asp


SUMMARY OF RESULTS


Measure # Name Description Affected

Sources Affected

Emissions(tpd) % tpd

Est. Cost Effectiveness

($/ton)

7 Zero

emission vehicles

10,000 ZEV on the road

Onroad - LDGV

24 VOC, 16 NOx

0.15% VOC, 0.15% NOx

0.04 VOC, 0.02 NOx,

$0.7 million VOC + NOx

G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control Measure 11 Clean Diesel_051009.doc

Control Measure: #11, Cleaner Diesel Fuel Category: On-road Author: Chris Lindhjem, ENVIRON DESCRIPTION The cleaner diesel control measure would consist of a change in diesel fuel from Texas Low Emission Diesel fuel (TxLED) to either cetane additive enhanced (CAE) or Fischer-Tropsch (FT) diesel fuel. It is anticipated that, due to the nature of CAE and FT diesel technology, this program may not be a mandatory change to CAE or FT diesel, but may more likely be for a localized or demonstration project on specific Class 8b Heavy Duty Truck (HDT) fleets. TxLED fuel contains less than 10 percent by volume of aromatic hydrocarbons and has a cetane number of 48 or greater. CAE diesel would consist of diesel to which additives were supplemented, producing a cetane number increase of 5 points with no changes in other parameters from TxLED fuel. FT diesel fuel would consist of typical FT fuel with a cetane number of 74 and an aromatic content of 0.1 percent (Clark et. al., 1999). IMPLEMENTATION FEASIBILITY Large-scale production of Fischer-Tropsch fuels are currently being researched by several oil companies (EPA, 2002), however, production is currently scarce and costly. Cetane additives are available for implementation; however, distribution issues would make it difficult to make the use of cetane enhancers mandatory over the entire HGB. Therefore, this measure was evaluated as a targeted measure, consisting of replacing TxLED fuel in 10% of the heavy-duty truck fleet with either FT or CAE fuel. PUBLIC ACCEPTANCE This measure would require changes in diesel production associated with each technology. Increased costs associated with this production could potentially be burdensome for diesel manufactures that would need to change their operations to conform to new standards, as well as for diesel consumers due to increased diesel costs. It is expected that grant funding could ease this burden. ANALYSIS This measure was analyzed by comparing the emissions associated with current TxLED fuel for heavy-duty vehicles (including buses) with FT and CAE diesel fuel. Emission reductions of 12% (Clark et. al. 1999) and 1.3% (EPA, 2003) were estimated for FT, and CAE fuel, respectively. Based on the on-road emissions inventory for 8-counties in the


HGB nonattainment area (TCEQ 2008), heavy-duty diesel vehicles totaled about 19.7 tpd of NOx emissions, of which, 12.9 tpd was from Class 8 only. A reduction of 0.02 tpd and 0.15 tpd is estimated for the implementation of FT and CAE fuel in 10% of the Class 8 heavy-duty fleet, respectively. The average emissions rates for Class 8a (33,000 to 60,000 lbs gross vehicle weight rating) and Class 8b are shown in Table 1. Along with the average fuel economy derived from the MOBILE6 technical documentation, the emissions per gallon of fuel consumed was calculated. Table 1. Heavy heavy-duty truck NOx emissions

Class 8a Class 8b Transit BusEmission Rates g/mile g/mile g/mile NOx Emissions (g/mile) 2.773 1.422 4.739Fuel Economy (mpg) 6.59 6.30 3.79NOx Emissions (g/gallon) 18.271 8.960 17.962 EMISSIONS AFFECTED The emissions affected could include all diesel engines (about 19.7 tpd, prior to adjustments for ambient conditions and other emission reduction measures) or to the entire or portions (estimated here at 10%) of fleets of larger Class 8 heavy-duty trucks that represent 12.9 tpd of NOx. EMISSIONS BENEFIT Estimated emission reductions from this measure for the fleets representing 10% of Class 8, or if applied across all diesel vehicles operating in the area would range from 0.02 tpd NOx reduction with cetane additives on 10% of the fleet to 2.36 tpd for Fischer-Tropsch applied across all diesel vehicles. COST AND COST-EFFECTIVENESS Estimates from vendors indicate that cetane additives that increase cetane levels of 5 points would cost approximately $0.08 per gallon. The cost of Fischer-Tropsch fuels ranges from $0.10 (cost to produce) up to $0.25 per gallon (to deliver under current market conditions) more than California Diesel (CEC, 2003)1. The cost of these fuels however has been decreasing due to advances in the technology and economies of scale, and will continue to decrease if demand increases as it is beginning to in California. In California, FT fuels are increasingly sold as a neat fuel or a blend stock to produce California reformulated diesel fuel.


The best (lowest cost) cost-effectiveness scenario applies to the low end of the FT cost to the 12 % NOx emission reduction for Class 8a (delivery type or short drayage vehicles). Using 10 cents a gallon and the emission rates in Table 1, the NOx reduction would be $41,000 per ton of NOx reduced. The highest cost-effectiveness scenario applies the cetane enhancement cost and benefit to the larger Class 8b truck emissions resulting in a cost effectiveness of $623,000 per ton of NOx reduced. SUMMARY OF RESULTS


# Name Description Affected Sources

Affected Emissions

(tpd) % Tpd


($/ton)

11 Cleaner Diesel Fuel

Cetane Additive

Enhanced or Fischer Tropsch

Diesel Fuel

Onroad – Class 8B HDT or

all HDDV

1.3 to 19.7 NOx

1.3% - 12%

0.02 – 0.15 or 0.25 – 2.36

$41,000 - $623,000

REFERENCES CEC (2003), “Reducing California’s Petroleum Dependence”, A Joint Report of the

California Energy Commission and California Air Resources Control Board, P600-03-005F, August 2003.

Clark, et. al. (1999), Clark, Nigel, Mridul Gautam, Donald Lydons, Chris Atkinson,

Wenwei Xie, 1999, “On-Road Use of Fischer-Tropsch Diesel Blends”, SAE Technical Paper Series, 1999-01-2251, Washington D.C., April 1999.

EPA. 2002, “Fact sheet: Clean Alternative Fuels: Fischer-Tropsch”, EPA420-F-00-036,

http://www.epa.gov/otaq/consumer/fuels/altfuels/420f00036.pdf EPA (2003), “The Effect of Cetane Number Increase Due to Additives on NOx

Emissions from Heavy-Duty Highway Engines, Final Technical Report”, EPA420-R-03-002, February 2003.

G:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC Measure 22 school buses_051009.doc 1

Control Measure: #22, Dedicated Funding for School Bus Replacement Category: On-road Author: Hazel Barbour DESCRIPTION Acceleration of the replacement of older buses in school district fleets through a fund dedicated to helping meet the costs of purchasing new buses to replace the older buses. Buses that are replaced should be scrapped. IMPLEMENTATION FEASIBILITY Apart from TERP funds, there is very little funding available for school bus purchase, e.g. EPA school bus grants (made available in Texas through the Blue Skyways Collaborative) fund retrofits of diesel powered school buses, not new bus purchases; EPA’s Smartway Clean Diesel Initiative funds trucks (school buses are not included); and CMAQ funds which can be used for diesel retrofits or engine replacement are unlikely to be available to replace the complete vehicle. Dedicated funding from TERP could be made available to HGAC in a format similar to the TERP block grants which the General Land Office and the Rail Road Commission have received to help fund purchase of natural gas and propane vehicles, respectively, and these funds could be made available to school districts in all 8 counties in the HGB area. While it could be possible to consider utilizing Local Initiative Project funds (excess LIRAP funds) for this program, HGAC would be required to come up with 100% matching funds, and, if Chambers, Liberty and Waller counties do not implement the I/M program, LIRAP funds cannot be utilized in these three counties. Having one organization in the HGB area focused on providing funds for school bus purchases should make communication with the school districts easier and, in turn, make it less burdensome for districts to submit applications. However, for many school districts, as their student population grows resulting in the need for a larger school bus fleet, the desire is often to purchase new buses but not remove older buses for the fleet. Implementation of this measure may need to be delayed until 2011/2012. To gain the most emissions reduction benefit, the aim should be to expedite the purchase of buses which meet the 2010 NOx standard of 0.2 grams/bhp-hr. However, at the point of writing, none of the manufacturers of school bus engines has announced the availability of an engine meeting this standard – it appears that Caterpillar will discontinue production of school bus engines completely and International is unlikely to produce an engine to the 2010 standard until 2012. Even if a school district is considering using an alternative fuel such as LPG, it appears that General Motors, the only manufacturer of an LPG school bus engine, will discontinue production of this engine in 2010. Additionally, if a TERP block grant for school bus replacement requires HGAC to operate under the current TERP requirements (cost effectiveness of $15,000 or less per ton NOx), it will be difficult to be able to offer substantial sums toward the purchase of new buses which do not meet the 2010 NOx standard due to the relatively small number of miles driven by a school bus per year.


PUBLIC ACCEPTANCE This measure should be well received by the public. ANALYSIS School districts are eligible to apply for TERP grants under the Replacement of On-road Heavy Duty Vehicles category. Grant recipients are eligible for reimbursement of up to 80% of the eligible incremental costs for the purchase or lease of the replacement vehicles, not to exceed an incentive amount that results in a cost-effectiveness of $15,000 or less per ton of NOx reduced. The total incentive amount must not exceed 80% of the cost of the replacement vehicle minus the scrappage value received for the old vehicle (which TCEQ estimates at $1,000 per bus). Current estimate of the cost of a 75 passenger school bus meeting the 2010 NOx standard is around $90,000. TERP rules require that the replacement bus must be certified to emit at least 25% less NOx than the bus being replaced. Any bus meeting the federal 2010 NOx standard (0.2 gms/bhp-hr) will emit 90% less NOx than a bus meeting the earlier 2004 NOx standard (2.0 gms/bhp-hr) and greater than 90% less NOx than buses manufactured prior to 2004. Assuming that the cost effectiveness requirement of $15,000 or less per ton is retained in a program dedicated to school bus replacement and that such a program focuses on replacing a diesel powered bus with another diesel powered bus, an example scenario using the TERP calculation methodology could be as follows:

Purchase of one bus meeting the MY 2010 standards to replace one MY 1995 bus:

Original engine NOx emissions standard: 5.0 g/bhp-hr Replacement engine NOx emission standard: 0.2 g/bhp-hr Original engine conversion factor: 2.93 bhp-hr/mile Replacement engine conversion factor 2.99 bhp-hr/mile Annual miles traveled 20,0001 TXLed conversion factor 0.943 TXLed and Baseline NOx emission factor (g/mile) 5.0*0.943 = 4.715 4.715*2.93 = 13.81 g/mile Reduced NOx Emission factor (g/mile) 0.2*2.99 = 0.598 g/mile Grams/mile NOx reduction 13.212 Grams NOx reduced per year 264,240.0 gms NOx reduced per year 0.291 tons NOx reduction over activity life of 7 years 2.037 tons

1 20,000 is at the high end of school bus annual mileage.


To maintain the TERP requirement that cost effectiveness be $15,000 per ton or less of NOx, in this scenario the maximum amount per bus for which a school district could apply would be $30,450. The number of school buses at the end of the 2007 school year in the 70 school districts and charter schools in Harris, Brazoria, Fort Bend, Galveston, Montgomery, Chambers, Liberty and Waller counties was estimated by the Texas Education Agency to be 8,574, with 31% (2,658) being greater than 10 years old. Assuming normal turnover from 2010 onwards would remove almost all of the remainder of these buses by 2018 (each ISD replacing an average of 10.5 buses per year); a dedicated school bus fund could aim to accelerate the replacement of 25% of the fleet. EMISSIONS AFFECTED Emissions affected are on road heavy duty diesel engine emissions. EMISSIONS BENEFIT The NOx benefit is estimated from replacing 25% of the current number of buses greater than 10 years old with buses meeting the 2010 HDDV NOx standard and assumes the average model year of the replaced buses to be MY 1995. NOx reduction per year from 665 buses: 193.5 tons NOx reduction per day (using 250 day year): 0.774 tons per day Total NOx reduction over 7 years’ activity life for 665 buses: 1,354.6 tons COST AND COST-EFFECTIVENESS Maximum grant per bus to achieve cost effectiveness not exceeding $15,000 per ton is calculated at $30,450. Total cost of the program at this level would be $20,249,250, not including HGAC administration costs of block grant. SUMMARY OF RESULTS


Measure ID Name Description Affected

Sources Affected Emissions

(tpd) % tpd


($/ton)

22

Dedicated funding for school bus replacement

Grant funding for school districts to replace 665 older buses.

Onroad School Buses

2.25 NOx school bus emissions

34.4% 0.774 NOx

$15,000 (not including HGAC admin costs)


REFERENCES Texas Education Agency: school bus data as at end of school year 2006/2007 provided by Forecasting and Fiscal Analysis. TCEQ: Texas Emission Reduction Plan (TERP); http://www.tceq.state.tx.us/implementation/air/terp/erig.html (TCEQ Emissions Reduction Incentive Grants Program Technical Supplement No. 1) EPA Blue Skyways Collaborative, www.blueskyways.org EPA Smartway Initiative: http://www.epa.gov/otaq/smartway/transport/what-smartway/financing-clean-diesel-info.htm TX Health and Safety Code; 382.220: Use of Funding for Local Initiative Projects Personal contact with Jim Murinchak, Hays CISD and Kouros Hafizi, Austin ISD.

G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure47-ParkPrice-EM_051009.doc

Control Measure: #47, Commuter Parking Pricing Category: On-road Author: Barbara Joy, Earth Matters DESCRIPTION Parking is generally free and abundant for most commuters. Among commuters who drive to work, only 5% pay the full cost of parking and another 9% pay a subsidized rate. Parking is not priced at 98% of U.S. work locations. (Litman, 2006) In Houston, paid parking is only common in a very few locations, namely Central Houston and a few large employment centers, like the Texas Medical Center. Commuters are most likely to pay all or part of the cost of parking in the Houston CBD. According to parking inventories from 2005, there are almost 75,000 structured parking spaces in downtown Houston and another 27,000 spaces in surface lots. In 2003, the average daily price of parking in downtown Houston was $8.00, with monthly unreserved spaces averaging $165.00 and reserved spaces averaging $245.00 per month. There are also 2,300 metered spaces downtown, which may be replaced by 750 multiple-space metering machines which would allow for cell phone or pre-paid card payment and better tracking of utilization (according to a Houston Chronicle article dated 3/5/06). This new technology also allows for variable pricing by time of day and demand. Changing the price of parking can affect mode choice and reduce VMT by shifting commute and other trips to alternative modes. A 2001 parking management plan prepared for Central Houston, Inc, called for “a comprehensive city-sponsored and promoted program to promote alternative means of transportation to the central business district.” (Moore and Assoc. 2001) According to the online TDM encyclopedia, Vaca and Kuzmyak (2005) found that the price elasticity of vehicle travel with respect to parking pricing ranges from –0.1 to –0.3 (meaning that a 10% increase in parking price would typically be expected to reduce vehicle trips by 1% - 3%, depending on the location, availability of transit and HOV options, demographics, etc. A recent Congressional Budget Office (CBO)1, prepared in January 2008 and at the request of the Ranking Member of the Senate Budget Committee relates rising gasoline prices to changes in how fast people drive, the volume of highway traffic, and rail transit ridership. In January 2003 the average retail price for a gallon of gasoline in the United States was $1.50. It was last below $2 per gallon in February 2005, and for much of 2007, prices topped $3 per gallon, spiking to over $4 a gallon in summer of 2008.

1 Effects of Gasoline Prices on Driving Behavior and Vehicle Markets. Congressional Budget Office January 2008.


The CBO study showed that freeway motorists have adjusted to higher prices by making fewer trips and by driving more slowly. CBO analyzed data collected at a dozen metropolitan highway locations in California, along with data on gasoline prices in California, to identify changes in driving patterns. On weekdays in the study period, for every 50 cent increase in the price of gasoline, the number of freeway trips declined by about 0.7 percent in areas where rail transit is a nearby substitute for driving; transit ridership on the corresponding rail systems increased by a commensurate amount. Median speeds on uncongested freeways declined by about three-quarters of a mile per hour for every 50 cents the price of gasoline has increased since 2003. The CBO study implies a short-term elasticity of 0.2, which is consistent with many other studies of price elasticity. An elasticity of 0.2 will be applied to the Houston CBD given the income levels, location, and availability of HOV lanes and commuter transit services. ANALYSIS At this time, the best data on parking charges, employment, and parking availability is from Central Houston. Most employees working in downtown Houston pay for some or all of their parking. Parking fees are most feasible where an existing market and infrastructure exists, as in Central Houston. As such, parking pricing would take the form of a parking surcharge to existing fees. It is estimated that the average cost of parking in downtown Houston was $15.00 per day in 2005. At a 3% per year growth rate, this would translate to $22 per day. A surcharge of 25% would increase this average fee to $27.50 per day. Increases in parking fees are known to shift some numbers of commuters to alternative modes, including carpooling. As such, preferential parking for carpools and vanpools is also recommended because some commuters would seek to share parking costs by sharing a ride. For this analysis, the commuters that might be subject to a parking surcharge and offered preferential parking are assumed to be located in Central Houston, where employees are most likely to pay some or all of their parking costs. There is a total of 3,182,938 employees projected for the Houston-Galveston region in 2018. According to H-GAC2 there are expected to be 362,600 employees in the CBD, Greenway Plaza/Bellaire and Texas Medical Center in 2018. In order to convert employees to vehicles, with which to apply the price elasticity factor, it is assumed that each 100 employees generates 77 vehicle trips (based on an assumed CBD commute mode split of 70% SOV, 15% HOV, 10% transit, and 5%bike/walk/telework/CWW/other). Thus, 362,600 employees are assumed to generate 279,202 round trip vehicle trips. EMISSIONS ANALYSIS The emissions analysis utilized the basic process suggested by the MOSERs methodology, as follows: 2 Personal Communication Sharon Ju, H-GAC and Barbara Joy, Earth Matters Nov 10, 2008.


Variables: EFA: Speed-based composite emission factor after





It was assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emission factors and the assumption that access to alternative modes is not through SOV use. In this analysis VMTB is derived by multiplying the number of employee vehicle trips by the elasticity associated with a 25% increase in average daily parking rates (from $22 to $27.50 per day) resulting in a switch to alternative modes that would result in vehicle trip reduction. Total driving costs effective in the decision to respond to parking prices are the variable weekly costs of driving: gasoline and oil plus parking. Insurance costs are factored in a different way and are not assumed to affect the response to an increase in parking price for the purpose of this analysis. According to H-GAC3 2002 costs of driving were 11.8 cents per mile considering gasoline, oil and maintenance. At a compounded growth rate of 3 percent per year it is expected that driving costs will be 18.9 cents per mile. For a 40-mile round trip to and from work, parking costs in the baseline are 1.8 cents per mile ($22/40 mile round trip). Total variable driving costs are therefore 20.7 cents a mile before the parking price increase and 21.15 cents per mile after. The total percentage increase is 2 percent. By multiplying the estimated number of vehicle trips (279,202) by a price elasticity of –0.2 and a change of 2.2 percent, we derive a 0.44 percent trip reduction; the vehicle trip reduction is therefore estimated to be 1,228 daily round trips. The VMT reduction 3 Personal Communication Gao Shixin, H-GAC and Barbara Joy, Earth Matters Nov 11, 2008.


associated with this trip reduction is derived by multiplying the average round trip work length (40.0 miles) weekdays, yields 35,086 miles of reduction per day. Equation:

Daily Emission Reduction = C = VMTB * EFA = 35,086 * 0.171 gram/mile NOx/454 = 13.2 lb/day, and 0.007 tpd NOx and 35,086 * 0.231 gram/mile VOC/454 = 17.9 lb/day, and 0.009 tpd VOC.

COST EFFECTIVENESS No data on costs for Houston is available. However, the cost associated with a surcharge and preferential parking program will largely be program planning and enforcement. This annualized cost could be around $5,000 for planning and $25,000 for enforcement. However, the surcharge, or a portion of it, could be used to defray program costs, especially enforcement. Conservatively, however, it is assumed that $30,000 per year would be spent. Annual combined reductions of NOx and VOC would be 5.84 tons per year. Therefore cost effectiveness would be $5,137/ton. COMMENTS This evaluation is based on national elasticities and may be considered for use in ozone plan after review of key assumptions. SUMMARY OF RESULTS



Affected Emissions

(tpd) % Tpd

Cost Effectiveness

($/ton)

47

Parking surcharge

25% surcharge on parking in Central Houston

On-Road Light-duty vehicles

40.7 VOC 30.3 NOx

0.02 0.009 0.007

$5,137 VOC+NOx

REFERENCES


Litman, 2006, “Parking Pricing – Direct Charges for Using Parking Facilities” in the Online TDM Encyclopedia, http://www.vtpi.org/tdm/tdm26.htm, updated February 2006. Vaca and Kuzmyak, 2005. “Parking Pricing and Fees” Chapter 13, TCRP Report 95, Traveler Response to Transportation System Changes, Transit Cooperative Research Program, Transportation Research Board. Walter Moore and Associates, Inc., Downtown Parking Management Program Planning – Houston Texas, prepared for Central Houston, Inc., January 23. 2001.

G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure51ParkCashOut-EM_051009.doc

Control Measure: #51, Parking Cash-Out Category: On-Road Author: Barbara Joy, Earth Matters Inc DESCRIPTION Parking cash-out is a program where certain employers who provide subsidized parking for their employees can offer a cash allowance in lieu of a free or subsidized parking space. California enacted a parking cash-out law after studies showed cash allowances in lieu of parking encourage employees to find alternate means of commuting to work, such as public transit, carpooling, vanpooling, bicycling, or walking. Parking cash-out offers the opportunity to improve air quality and reduce traffic congestion by reducing vehicle trips and emissions. It can also reduce an employer’s parking demand and reduce parking costs, which are estimated to be $432 annually per suburban parking space and $1,598 per urban space provided. (Thornton, 2005) According to the online TDM encyclopedia (http://www.vtpi.org/tdm/tdm8.htm) Don Shoup (1997) found that total vehicle trips declined by 17% after Parking Cash Out was introduced at various urban and suburban worksites, as illustrated in Figure 1 (from the online encyclopedia). These automobile trip reductions tend to increase over time: one employer found that solo commuting continued to decline each year after Parking Cash Out was introduced, as more employees found opportunities to reduce their driving and take advantage of the benefit.

76%

14%6% 3%

63%

23%

9%4%

0%

20%

40%

60%

80%

Drive Alone Car Pool Ride Transit Bike/Walk

Com

mut

e M

ode

Shar

e Before Cash Out

After Cash Out

Figure 1. Cashing Out Impacts on Commute Mode (Shoup, 1997). Parking Cash Out results in reduced automobile commuting and increases in carpooling, transit and non-motorized travel. In a later report, (Shoup, 2001), Shoup notes that employer-paid parking is the most common tax-exempt fringe benefit offered to workers in the United States, and that 95 percent of American automobile commuters park free at work. He notes that case studies


and statistical models suggest that, compared with driver-paid parking, employer-paid parking increases the number of cars driven to work by about 33 percent. ANALYSIS At this time there is little data upon which to support an analysis for the Houston-Galveston area. The number of employees who have free or subsidized parking at their worksites is unknown. However, employees who pay all or some of the cost of parking are generally located in Central Houston and the Texas Medical Center. In addition, the precise number of employers who require employees to pay or offer subsidized parking could be eligible for this program is unknown. Parking cash-out tends to work best where employers lease parking for their employees (creating the incentive to participate). For this analysis, the commuters that might be offered parking cash-out are assumed to be located in Central Houston or the Texas Medical Center. This analysis uses a hypothetical example in which 25 percent of downtown and medical center employees are offered a cash payment in lieu of free or heavily subsidized parking. It is also assumed that the results in California are applicable to Houston, since there are no other case studies available. Therefore it is suggested that this analysis not be used as a formal control measure until there is some basis upon which to support a projected emission reduction. There are a total of 3,182,938 employees projected for the Houston-Galveston region in 2018. In 2004, there were 145,318 employees in Central Houston and 65,300 in the Texas Medical Center. With a growth rate of 3.0% (based on Central Houston, Inc. projections), this would equate to 318,579 employees in 2018. If 25%, or 79,645, of them are provided with parking cash out payments and there is a 17 percent reduction in each of their drive-alone travel to work, the following emission reductions could be achieved. EMISSIONS ANALYSIS The emissions analysis utilized the basic process suggested by the MOSERs methodology, as follows: Variables: EFA: Speed-based composite emission factor after




(grams/trip)


TLA: Average auto trip length after implementation (miles) TLB: Average auto trip length before implementation (miles) VMTA: Vehicle trips after implementation VMTB: Change in VMT as a result of implementation

It was assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emission factors and the assumption that access to alternative modes is not through SOV use. In this analysis, VMTB is derived by multiplying the number of employees offered parking cash-out (79,645) by their average round trip work length (40.0 miles) and applying a 17 percent reduction for an average of 4 out of 7 days per week (to account for weekends, holidays, vacations, and that few alternative mode users use alternative modes every day; this part of the calculation assures that the estimate is an average daily reduction over any day of the week. Equation:


C = VMTB * EFA = 309,478 * 0.171 gram/mile NOx/454 = 116 lb/day, and 0.058 tpd NOx and 309,478 * 0.231 gram/mile VOC/454 = 157 lb/day, and 0.079 tpd VOC.

COST EFFECTIVENESS No data on costs for Houston is available. However, given employer savings on reduced parking lease costs, the cost to employers could be neutral (i.e., cost of the cash out equal or even less than the parking lease cost savings. Depending on program structure, cost per ton could be as low as $0. COMMENTS This evaluation is based on hypothetical assumptions and data for this program and may be considered for use in ozone plan after review of key assumptions.


SUMMARY OF RESULTS



Affected Emissions

(tpd) % Tpd

Cost Effectiveness

($/ton) 51 Parking

Cash-Out Cash-Out for 25% of Central Houston and TMC employees

On-RoadLight-duty vehicles

40.7 VOC 30.3 NOx

0.2 0.2

0.08 0.06

Parking cash-out costs equal to or less than

employer parking lease

savings REFERENCES Shoup, 2001. “Parking Cash Out (Chapters 1 and 22-28 from the manuscript of) The High Cost of Free Parking”. Donald Shoup, Chair, Department of Urban Planning Director, Institute of Transportation Studies. Shoup, 1997. Donald Shoup, “Evaluating the Effects of California’s Parking Cash-out Law: Eight Case Studies,” Transport Policy, Vol. 4, No. 4, 1997, pp. 201-216. Thornton, 2005. “Beating the Parking Crunch: How to Reduce Traffic, Expand Parking Supply, Save Money and Improve Employer Commutes,” Facilities Management Journal, May/June 2005, pp. 38-39.

G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure55-FuelSubsidy-EM_051009.doc

Control Measure: #55, Remove Fuel Subsidies – Fuel Pricing Category: On-road Author: Barbara Joy, Earth Matters DESCRIPTION The cost of gasoline in the U.S. spiked so high throughout most of 2008 that consumers had to make dramatic changes in their driving behavior. Unprecedented numbers turned to transit, bicycling and other alternative modes to avoid the pump prices. In this context it is non-intuitive but a well-established fact that gasoline prices in the U.S. are implicitly subsidized to a large extent through not incorporating many of the costs of gasoline into the prices. For example, a 1998 report by the International Center for Technology Assessment1 found that gas prices would rise from the 1998 average $1.25/gallon to $5.60 to $15.14 if they included subsidies such as tax subsidization of the oil industry; government program subsidies; protection costs involved in oil shipment and motor vehicle services; environmental, health, and social costs of gasoline usage; and other externalities. The report notes: “The majority of people paying just over $1 for a gallon of gasoline at the pump has no idea that through increased taxes, excessive insurance premiums, and inflated prices in other retail sectors that that same gallon of fuel is actually costing them between $5.60 and $15.14. When the price of gasoline is so drastically underestimated in the minds of drivers, it becomes difficult if not impossible to convince them to change their driving habits, accept alternative fuel vehicles, or consider progressive residential and urban development strategies”. The German Technical Corporation (GTZ), an international cooperation enterprise for sustainable development with worldwide operations, has compiled detailed reports on international gasoline prices. From this compilation it can be seen that international fluctuations in fuel prices are enormous. Generally oil producing countries have significantly lower prices than seen elsewhere, while non-oil producing countries that attempt to include external costs of gasoline use have much higher prices when compared with U.S. pump prices. Their full report can be found at http://www.gtz.de/en/dokumente/en-international-fuelprices-part2-2007.pdf. The report finds that European, Chinese, Mexican and representative South American countries such as Brazil that attempt to incorporate the real cost of gasoline use into gasoline prices charge up to 2.5 times the amount charged in the U.S. for a gallon of gas. This analysis estimates the reduction in driving that would occur if subsidies were reduced to the extent they appear to be in the U.K. The U.K. charges more than twice the amount per gallon as is charged in the U.S., according to the GTZ study cited above. The Center for Technology Assessment estimate is that prices would quadruple, at a minimum if all subsidies were incorporated into gasoline prices.

1 The Real Price of Gasoline: An Analysis Of The Hidden External Costs Consumers Pay To Fuel Their Automobiles. Kimbrell et al, 1998.


ANALYSIS The H-GAC travel model estimates total daily VMT in the Houston metropolitan region at 176,669,720 miles per day, including all vehicle categories and travel from within as well as from without the region but traveling through it. This analysis assumes that the price of driving in terms of gasoline was increased by a factor to roughly represent the differences amongst other countries that incorporate more of the external costs into their gasoline prices. Table 1. International Fuel Prices in 2006, in U.S. Dollars of Several Countries (source: GTZ, 2007 – see above-referenced web site for full report).

Country Price per Gallon of Gas in 2006

U.S. $2.38 Canada $3.18 Brazil $4.77 Mexico $2.80 Russia $2.91 China $2.61 U.K. $6.17 Germany $5.87 France $5.60 Spain $4.35

There is no empirical basis upon which to determine whether any of these prices would fully or best represent U.S. non-subsidized prices. A simple average was determined to be a reasonable rough estimate of an example price upon which to base the following analysis. The simple (non-population and non-factor-weighted) average of the above prices is $4.06 per gallon, or 171 percent of U.S. prices. It should also be noted that oil-producing countries such as Venezuela, Kuwait, and Iran cited in the same report by GTZ found prices ranging from 11 – 83 cents per gallon. A 170 percent increase, using a price elasticity of -0.2, would result in a VMT reduction of 34 percent. It is as yet unknown whether the elasticity findings in the literature would apply across-the-board to so large an increase in prices. The price increase from September 2007 to September 2008 was about the same; however studies of the effect are not yet publicly available. Therefore a correction factor of 0.5 similar to that applied for ozone action day programs in the U.S. is applied to the results to add conservatism pending additional data on driving responses to very substantial price changes. With the correction factor it is estimated that a 17 percent decrease in VMT would result from a removal of fuel subsidies in the U.S. It is further assumed that this decrease would only be realized by passenger vehicles. Although vehicles such as line haul trucks would be expected to also make changes, available elasticity values in the literature have focused on passenger travel. For conservatism it is assumed that heavy-duty travel is not affected.


Using the above approach, it is estimated that removal of fuel subsidies would reduce VMT by 27,203,228 miles per day in the region. EMISSIONS ANALYSIS The emissions analysis utilized the basic process suggested by the MOSERs methodology, as follows: Variables: EFA: Speed-based composite emission factor after





It was assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emission factors and the assumption that access to alternative modes is not through SOV use. In this analysis VMTB was derived as described above by multiplying the percentage change in travel (17%) by daily light duty vehicle travel in the region. The resulting reduction is 27,203,228 miles per day. Equation:


C = VMTB * EFA =


27,203,228 * 0.171 gram/mile NOx/454 = 10,246 lb/day, and 5.1 tpd NOx and 27,203,228 * 0.231 gram/mile VOC/454 = 13,841 lb/day, and 6.9 tpd VOC.

COST EFFECTIVENESS The program shifts costs from external to internal so, if applied correctly should result in revenue positive results. COMMENTS This evaluation is based on national short-term elasticities and may be considered for use in ozone plan after review of key assumptions SUMMARY OF RESULTS



Affected Emissions % Tpd

Cost Effectiveness

($/ton) 55 Remove

fuel subsidies

Internalize implicit fuel subsidies into the price of gasoline


40.7 VOC 30.3 NOx

17 6.9 5.1

<$100/ton

G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure57-ConPrice-EM_051009.doc

Control Measure: #57, Congestion Pricing Category: On-road Author: Barbara Joy, Earth Matters DESCRIPTION

Congestion pricing or congestion charges is a system of surcharging users of a transportation network in periods of peak demand in order to reduce traffic congestion. By providing drivers a financial incentive to take mass transit or other alternative modes during congested times or to shift their time of travel, internationally congestion pricing is a popular way to manage the number of vehicles on the road. The application on urban roads is limited to a small number of cities, including London, Stockholm, Singapore and Milan, as well as a few smaller towns. Four general types of systems are in use; a cordon area around a city center, with charges for passing the cordon line; area wide congestion pricing, which charges for being inside an area; a city center toll ring, with toll collection surrounding the city; and corridor or single facility congestion pricing, where access to a lane or a facility is priced.

Implementation of congestion pricing has reduced congestion in urban areas, but has also sparked criticism and public discontent. Critics maintain that congestion pricing is not equitable, places an economic burden on neighboring communities, has a negative effect on retail businesses and on economic activity in general, and is just another tax.

August 2007, the United States Department of Transportation selected five metropolitan areas to initiate congestion pricing demonstration projects under the Urban Partnerships Congestion Initiative, for $1 billion of federal funding. The five current projects under this initiative are; Golden Gate Bridge in San Francisco, State Road 520 serving downtown Seattle and communities to its east, Interstate 95 between Miami and Fr. Lauderdale, Interstate 35 West serving downtown Minneapolis and a variable rate parking meter system in Chicago, which replaced New York City after it left the program in 2008 after nearly implementing a program they were calling the PlaNYC 2030 Sustainability Initiative.

H-GAC evaluated a congestion pricing program for a downtown area in 2006 and concluded that the program would result in very small emission reductions and for a very high price because of feasibility and mobility issues. However the area is in the process of converting HOV lanes to “HOT” lanes, a plan to expand current High Occupancy Toll (HOT) activities on Katy and Northwest Freeways and add tolling to the other four HOV lanes to develop an integrated network of HOT lanes. Plans are being developed to optimize the entire network of HOV lanes on Houston using value pricing, to provide the maximum benefits for Houston travelers through reduced congestion and delays.

Specifically, meetings were held in late August 2008 in all five affected corridors regarding the proposed redesignation of 83 miles of Houston's existing reversible High Occupancy Vehicle (HOV) lanes to automated High Occupancy Toll (HOT) lanes. HOT

G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure57-ConPrice-EM_051009.doc

lanes are HOV lanes that can be used by Single Occupant Vehicles (SOVS) for a fee or toll only at times when normal HOV traffic flow is light.

Under the plan METRO would redesignate five of its existing HOV corridors: IH 45 North, US 59 North, IH 45 South, US 59 South and US 290 to HOT Lanes. The project will entail the design, installation and operation of new electronic toll collection, optical monitoring equipment and observation booths. ANALYSIS This measure was evaluated by Texas A&M University and found very small emission benefits. IT is expected that using some sort of traffic simulation model would yield some results although this requires a detailed analysis of exactly what mode travelers would be using if there were no HOT lane. For example, what percentage got off the bus to go SOV on the HOT lane and are therefore caused added pollution. Because ridesharing benefits are accounted for in other analyses and it is unclear whether the net effect would be a reduction or an increase in emissions from the current case, it is suggested that this measure needs a separate study to determine how to account for air quality benefits.

G:\HGAC\Reports\Final_051009\Appdx_F_051009\ControlMeasure59-FuelTaxes-EM_051009.doc

Control Measure: #59, Local or regional fuel taxes Category: On-road Author: Barbara Joy, Earth Matters DESCRIPTION

Taxes on transportation fuels have been advocated as a way to reduce pollution, conserve energy, and for certain countries reduce dependence on imported oil for foreign policy reasons. Placing high taxes on fossil fuels makes alternative (and often less polluting) fuels such as natural gas, biodiesel, or electric batteries more attractive, and put price pressure on manufacturers and consumers to choose more fuel-efficient products and processes. In a November 16, 2008 Op-Ed in the New York Times, for example, Dr. Daniel Sperling of the University of California at Davis argues that a variable tax based on a price floor of $3.50 per gallon should be assessed and the proceeds used to help bail out the auto industry which, as a condition of receiving these funds, would have to agree to build more fuel efficient vehicles. Dr. Sperling notes that at current average prices of $2.50 a gallon the variable tax would raise $17 billion in one month – more than half the $25 billion bail-out under discussion. And within a year of sustained $2.50 a gallon gas, the revenue would reach $140 billion – enough to begin repairing our roads and implement other needed transportation measures.

Proponents advocate that automobiles should pay for the roads they use and argue that the user tax should not be applied to mass transit projects. Critics argue transportation fuel taxes are a regressive tax, because low-income people pay a higher proportion with respect to their income, and transportation (to work, school, etc.) is not always an avoidable expense.

The federal gas tax in the U.S. is 18.5 cents per gallon. Additional State taxes, according to http://www.taxadmin.org/fta/rate/motor_fl.html, based on January 2008 data, range from 8 cents/gal in Alaska to 36 cents a gallon in Washington State. In Texas gas taxes are 20 cents/gal. Taxes in Canada, Europe and other countries are much higher. As of 2007, according to Wikipeida, Canadian taxes are 61 cents a gallon in the Yukon to $1.15 a gallon in Vancouver. In Europe gas taxes range from $3.80 a gallon in Britain to over $5 a gallon in Germany, the Netherlands, and Norway. ANALYSIS The H-GAC travel model estimates total daily VMT in the Houston metropolitan region at 176,669,720 miles per day, including all vehicle categories and travel from within as well as from without the region but traveling through it. It is assumed that VMT from external trips is about 4.8 million miles per day, based on external percent of trips, which is 2.7 percent. The analysis assumes that the fuel taxes are being increased in the


Houston area alone so that external trips are not affected. In addition it is assumed that about 10% of the VMT would go to bordering counties to obtain gasoline at lower prices. Therefore VMT of 154,202,748 is potentially reducible from raising gasoline taxes. This analysis assumes that the tax on gasoline was increased to be equivalent to Vancouver, Canada. 2008 average U.S. prices of $3.85 per gallon in mid-2008 were representative and currently (November 2008) they were about $2.40 in the Gulf States at the end of October 2008. The fluctuations this past year make it more difficult than usual to predict what prices may be in 2018. For the purpose of analysis it is assumed that the average price this summer is the base from which a higher gasoline tax equivalent to the tax in Vancouver is assessed. Subtracting the current taxes of 18.5 cents federal and 20 cents a gallon in Texas from the Vancouver taxes of $1.15, the increase would amount to 76.5 cents per gallon, or a 21 percent increase in 2008. It is further assumed that this approach would result in the same percentage increase in 2018 since we cannot predict taxes or gasoline prices. Using a gasoline price elasticity of 0.2, a 21 percent increase in gasoline costs would reduce travel by 4 percent, or 6,168,110 miles per day. EMISSIONS ANALYSIS The emissions analysis utilized the basic process suggested by the MOSERs methodology, as follows: Variables: EFA: Speed-based composite emission factor after






It was assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emission factors and the assumption that access to alternative modes is not through SOV use. In this analysis VMTB was derived as described above by multiplying the percentage change in travel (4%) by daily light duty vehicle travel in the region. The resulting reduction is 6,168,110 miles per day. Equation:


C = VMTB * EFA = 6,168,110 * 0.171 gram/mile NOx/454 = 2,323 lb/day, and 1.2 tpd NOx and 6,168,110 * 0.231 gram/mile VOC/454 = 3,138 lb/day, and 1.6 tpd VOC.

COST EFFECTIVENESS The program would be revenue positive; therefore costs per ton are less than zero. COMMENTS This evaluation is based on national short-term elasticities and broad assumptions regarding the appropriate percentage increase in gas taxes. It may be considered for use in ozone plan after review of key assumptions. The feasibility of implementing this measure is low. SUMMARY OF RESULTS




Cost Effectiveness

($/ton) 59 Fuel

Taxes Increase fuel taxes to be equivalent to those in Vancouver Canada, resulting in a 21 percent increase in fuel price

On-Road – Light-duty vehicles

40.7 VOC 30.3 NOx

4 1.6 1.2

<$100/ton

G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure60-VMT-Tax-EM_051009.doc

Control Measure: #60, VMT Tax Category: On-Road Author: Barbara Joy, Earth Matters Inc DESCRIPTION A tax on miles traveled is a measure potentially useful for reducing miles traveled. Under this measure, a charge would be levied for each mile driven. In name and application the measure differs from gasoline taxes or removal of fuel subsidies but it works the same way. Most scenarios envision this charge being collected during the annual registration process based upon the difference between the previous year’s odometer reading and the current reading. This is a key difference between VMT taxes and changes to fuel subsidies or increases in gasoline taxes, which are levied every time a vehicle is refueled. While there are potential difficulties with collecting accurate odometer readings, such as odometer roll-over, odometer malfunction, and tampering, it is expected that most readings would be accurate enough to successfully implement this measure. Some states such as California and Oregon have been considering such a tax also because gasoline taxes are not enough to keep pace with needs for road maintenance and capacity improvements, especially given the trend toward more fuel efficient and hybrid vehicles. One major benefit of this and other pricing programs is that it affects all categories of travel. Most measures aimed at reducing travel and associated emissions focus on commute travel, which represents about 25 – 30 percent of total travel in a given region. This measure would affect both commute and non commute travel. It is assumed that it would only affect travel in passenger vehicles; travel by vehicles such as heavy duty trucks is not as readily affected by a change in price per mile. This analysis evaluates the potential effect of this program were a 5 cent per mile VMT tax imposed on area drivers, with the exception of emergency vehicles, delivery vehicles, and high occupancy vehicles such as vanpools or taxis. Based on current gasoline, oil, vehicle maintenance and insurance costs grown at 3 percent per year from 2008 to 2018, it is assumed that driving costs will be about 31 cents per mile in 2018. A 5 cent per mile VMT tax would represent a 16 percent increase in driving costs at a 31 cent per mile rate. BACKGROUND FOR EMISSION REDUCTION BENEFITS There have been a number of estimates of the potential effects of mileage charges and similar programs involving changes in the price of driving. Harvey and Deakin utilized a modified transportation model called the STEP model initially developed for the San Francisco Bay Area to evaluate a variety of pricing measures on driving behavior. The model was applied to four different areas in California, based on 1990 land use and price


data. Table B-21 of their appendix1 contains a list of cents per mile charges and associated percent travel reduction. For example these range from 2.3 to 19.7 percent changes in VMT for mileage fees ranging from one to ten cents for 1991 in Los Angeles. These values were updated by Todd Littman (see http://www.vtpi.org/tdm/tdm79.htm, Table 1) to account for inflation between 1991 and 2001, as follows: Table 1. Mileage Fees and Percent Travel Reduction.

Mileage Fee (cents)

Travel Reduction (percent)

1 1.8 2 3.5 3 5.1 4 6.7 5 8.2 6 9.7 7 11.2 8 12.5 9 13.8

10 15.2 While the values were originally developed for California using a transportation model, they may be applicable to other areas. The Appendix written by Deakin and Harvey does not contain details about assumptions regarding elasticities, the number of people subject to a given measure, base prices, base transportation network characteristics and other inputs necessary for replicating the analysis for another area such as Houston. The values are reportedly based on generalized elasticity coefficients that include combined values of travel time, vehicle costs, toll prices, fuel taxes, transit fares, and parking prices. Some researchers quoted by Littman in http://www.vtpi.org/tdm/tdm11.htm such as Lee (2000) estimated the elasticity of vehicle travel with respect to total price (including fuel, vehicle wear and mileage-related ownership costs, tolls, parking fees and travel time, which is equivalent to generalized costs) is –0.5 to –1.0 in the short run, and 1.0 to –2.0 over the long run. The Harvey Deakin estimates are equivalent to a price elasticity of 0.4, which is slightly below the lower range noted above by Lee (“Demand Elasticities for Highway Travel,” HERS Technical Documents, FHWA (www.fhwa.dot.gov), 2000). However it is in line with the average long term elasticity of demand with respect to gasoline price of 0.4.

1 Greig Harvey and Elizabeth Deakin, “The STEP Analysis Package: Description and Application Examples,” Appendix B, in Apogee Research, Guidance on the Use of Market Mechanisms to Reduce Transportation Emissions, USEPA (Washington DC; www.epa.gov/omswww/market.htm), April 1997


ANALYSIS AND RESULTS The methodology uses a short-term gasoline price elasticity of 0.2 in order to be consistent with the analyses for fuel taxes and removal of fuel subsidies (measures 55 and 59). It is assumed that a 5 cent per mile fee is assessed. This fee is hypothetical for the purpose of providing an estimate of potential emission reductions intended primarily to determine whether a VMT tax is an approach that would yield sufficient emission reductions to merit additional and more intensive evaluation. The amount of this fee is loosely based on the concept that 10 cents is the per-mile charge levied by most vehicle leasing companies for exceeding pre-set mileage limits and that this fee would be set at less. The H-GAC travel model estimates total daily VMT in the Houston metropolitan region at 176,669,720 miles per day, including all vehicle categories and travel from within as well as from without the region but traveling through it. It is assumed that VMT from external trips is about 4.8 million miles per day, based on external percent of trips, which is 2.7 percent. The analysis assumes that the VMT tax is being assessed in the Houston area alone so that external trips are not affected. In addition it is assumed that an additional 10% of the VMT is from vehicles registered outside the modeling area. Therefore VMT of 154,202,748 is potentially reducible from levying a VMT tax. Since a VMT tax of 5 cents per mile represents a 16 percent increase in the cost of driving and the price elasticity of driving with respect to price is 0.2 we estimate that a 3.2 percent in VMT will result from a VMT tax set at this value. This would be equivalent to 4,934,488 miles of travel reduced per day. EMISSIONS ANALYSIS The emissions analysis utilized the basic process suggested by the MOSERs methodology, as follows: Variables: EFA: Speed-based composite emission factor after




(grams/trip) TLA: Average auto trip length after implementation (miles)


TLB: Average auto trip length before implementation (miles) VMTA: Vehicle trips after implementation VMTB: Change in VMT as a result of implementation

It was assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emission factors and the assumption that access to alternative modes is not through SOV use. In this analysis VMTB was derived as described above by multiplying the percentage change in travel (3.2%) by daily light duty vehicle travel in the region. The resulting reduction is 4,934,488 miles per day. Equation:



COST EFFECTIVENESS The program would be revenue positive; therefore costs per ton are less than zero. COMMENTS This evaluation is based on national short-term elasticities and broad assumptions regarding the appropriate VMT tax and the resulting percentage increase in driving costs per mile. In addition it is assumed that a cost levied only once per year would have the same effect in percentage terms as a cost levied each time a motorist refueled. The validity of this assumption is unknown. The measure may be considered for use in ozone plan after review of key assumptions. The feasibility of implementing this measure is untried; limited attempts have been made in Oregon but none elsewhere in the U.S. though the measure has been considered by many other nonattainment areas.


SUMMARY OF RESULTS Expected Emission Reduction Measure



Cost Effectiveness

($/ton) 60 VMT Tax Levy a VMT

tax of 5 cents per mile

On-Road – Light-duty Vehicles

40.7 VOC 30.3 NOx

3 1.3 0.9

<$100/ton

G:\HGAC\Reports\Final_051009\Appdx_F_051009\Measure 75_83 Traffic_051009.doc

Control Measure: Traffic signalization improvements, intersection improvements, Reversible traffic lanes (Measures 75, 76, 77, 78, 79, 80, 81, 82, and 83) Category: On-Road Author: Chris Lindhjem, ENVIRON DESCRIPTION Traffic signalization improvements, reversible lanes and intersection improvements are an ongoing part of the H-GAC plan and Transportation Implementation Plan (TIP). According to practice in evaluating CMAQ projects, as well as straightforward logic, traffic flow improvements encouraged by improved intersections or traffic signals provide benefits for 2 – 5 years (3 years was used for this analysis) before latent demand and growth in traffic cause the facility to return to about the same flow level as prior to the signal or other improvements (although better able to handle higher traffic volume). Table 1 provides a list of proposed projects that are being considered under this strategy. Table 1. Initial list of proposed traffic improvement projects.

County Name Project Type Location Project Description

Harris Traffic Signal Improvements

Various Locations in Harris County Precinct 4

Arterial Traffic Management System Build Out (Fiber Connectivity And Communications)


Various Locations in Harris County Precinct 1

Improve Traffic Flow Along Various Precinct 1 High Demand And Congested Arterials Through Traffic Signal System Enhancements

Harris Incident Management Systems

Various Install Traffic Signal Communications (Fiber, Wireless, Hardware, Etc.)

Harris Traffic Signal Improvements Harris County Precinct 3

Improve Traffic Flow Along Various Precinct 3 High Demand And Congested Arterials Through Traffic Signal System Enhancements


Various Locations In Harris County Precinct 2

Arterial Traffic Management System Build Out (Fiber Connectivity And Communications)

Brazoria Traffic Signal Improvements

FM 524: Entrance To Phillips Refinery

For Work Consistent Of The Modernization Of Existing Traffic Signals

Galveston Traffic Signal Improvements

FM 2351: At Westwood Elementary Install Traffic Signal And Turn Lanes

Harris Traffic Signal Improvements Various

Install Advanced Traffic Control Devices At HATSS Intersections To Bring These Intersection Up To Coh Standards And Improve Traffic Mobility And Signal Progression At Critical Locations (See Attachment). Equipment Deployed May Include: Vids (Video Vehicle Detection System) Pedestrian Control Devices (ADA Ramps, Ped. Heads, Pushbuttons) Dynamic "No Left Turn" Signs

Harris Traffic Signal Improvements Various Install Traffic Management Operations

Equipment Phase 2

Harris Traffic Signal Improvements Various Install Traffic Management Operations

Equipment Phase 2



Harris Traffic Signal Improvements Various Houston Intelligent Corridors For Transportation

Efficiency (ICTE)

Fort Bend Traffic Signal Improvements

5th St. At Present St

New Stand-Along Traffic Signal Utilizing Video Imaging Vehicle Detection System (VIVDS) And 3M Opticom Priority Control System For Emergency Vehicles


Kirkwood Rd At Cash Rd Install Traffic Signal


Cash Rd At HCC Campus Install Traffic Signals At Intersection


SH 87: Harbor View EastOf 6th St Install Arterial Traffic Management System

Montgomery Freeway Management Systems

IH 45 N N. Of Creighton Rd FM 1488

Install Computerized Transportation Management System


Washburn Tunnel Traffic Management And Information System Work Order #14


SH 6 At FM 1092 / University Blvd

Reconfigure And Upgrade Traffic Signal System At Intersection (RCTSS)


SH 6 At Glenn Lakes Blvd.



N. Main / Alexander Texas Ave To Baker Rd Texas Ave To McKinney

Traffic Signal Synchronization


FM 1092 At Cartwright Rd



Broadway St. 6th St to 61st St Upgrade Traffic Signals & Synchronization


Various Locations In Harris Co. Precinct 2

Harris County Signal Interconnect Project, Phase 2, Precinct 2: Project 1

Harris Other FM 2920 FM 2978 and Kuykendahl

Install Ethernet Equipment To Interconnect Traffic Signal Video & Data Communications With Regional Traffic Center (Transtar)

Harris Freeway Management Systems

NASA 1 IH 45 between SH 146

Install Computerized Transportation Management System

Fort Bend Other SH 6 In Sugarland At Various Locations Computerized Lane Assignments


FM 2920 IH 45 Kuykendahl

Install Vivds, Pan Tilt Cameras And Dynamic Message Signs At Major Intersections


Various Locations In Missouri City

Intelligent Transportation System: Upgrade All Traffic Signals To Provide Regionalized Traffic Flow



Harris County Signal Interconnect Phase 2 Precinct 1-Project 1



Harris County Signal Interconnect Phase 2 Precinct 4-Project 1

Fort Bend Traffic Signal Improvements SH 6 Signal Improvements At Intersections



Harris Traffic Signal Improvements City Of Houston City Of Houston RCTSS Program: Improve

Traffic Control Devices



Harris County Signal Interconnect Project, Phase 2, Precinct 3: Project 1

Harris Traffic Signal Improvements City Of Pasadena City Of Pasadena Signal Program

Fort Bend Other 111 Gillingham Ln. Sugar Land Traffic Management Center


IH 10 W & US 59 SW Houston CBD SH 99 & SH 6

Traffic Incident Management (Phase I): Utilize Its Technology, Including Helicopters W/ Real Time Cameras/Microwave Transmitters/Motorcycle Police Units/Marked Vehicles/Dedicated Response Trucks

Harris Other Midtown/Downtown Houston CBD Communications System

Harris Traffic Signal Improvements Various Arterials Harris County RCTSS Program Phase 3


Various Locations In Harris County

ITS For High Demand Arterial Streets, Harris County Phase 4 RCTSS

METHODOLOGY AND EMISSIONS ANALYSIS Traffic improvement projects (under the general strategy called Intelligent Transportation Systems, ITS) are to improve traffic operations. These projects would primarily provide better flow of traffic, reducing stop and go and increased idling especially at intersections. Emissions Analysis The primary measure of the benefit of the project is improvements in the average speeds. Improvement in flow of traffic can be measured as average travel speed for freeways in miles per hour before and after the implementation of an ITS project and delay reductions in vehicle-hours (to estimate reduced idling) plus speed improvements for arterial roadways. The emission factors are determined in units of kilo-grams/mile for freeways before and after the project is implemented. If data is not available through a simulation of the traffic flow, standard estimations, or any other means, then the default estimate is to use the assumption that the average speed will improve from 30-MPH to 35-MPH on Freeways and 20-MPH to 25-MPH on Arterials. The idling benefits were determined using the idling emission factor in kilo-grams/hour (The idling emission factor is determined using the grams/mile for 2.50-MPH idling speed multiplied by 2.50-MPH.) and the delay reduction in vehicle-hours. For freeways, the difference in emission factors (grams/mile) multiplied by vehicles-miles of travel (VMT) will give emission benefits in kilo-grams/day.


Cost Effectiveness The cost of this measure based on the sample list of proposed projects was based on the estimated cost and benefit of those projects. The total cost of those proposed projects were $230,527,658. COMMENTS This evaluation is based on the cost and evaluation of the proposed projects outlined in this summary. The proposed projects are based on next three years of projects that will be let, but there could be significantly more projects let over a three-year period. For this summary, it was assumed that twice the money and benefit would be available during the period of 2015 – 2017. SUMMARY OF RESULTS


Measure ID

Name Description Affected Source

Affected Emissions

% TPD

Cost Effectiveness

($/ton)

75 – 83 Traffic Flow Improvements

Traffic signal timing

On-Road

44.6 tpd VOC

51.7 tpd NOx

4.6 VOC3.6

NOx

2.0 VOC 1.8

NOx

$220,065 VOC

$239,958 NOx

$114,791 VOC+NOx

G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure85-ReduceTransitFares-EM_051009.doc

Control Measure: #85, Reduced Transit Fares Category: On-Road Author: Barbara Joy, Earth Matters Inc DESCRIPTION Transit fare decreases can increase transit ridership and encourage some individuals who are currently solo drivers to use transit for some travel. This switch reduces vehicle miles of travel and air pollution emission associated with this travel. The transit system in the Houston area is run mostly by METRO; some service is provided by other agencies and often coordinated through the efforts of local Transportation Management Organizations (TMOs). METRO provides local bus, express bus, Commuter bus, trolley services in the Texas Medical Center, and rail services for the Houston area. On November 2, 2008, METRO raised transit fares in the Houston area for the first time since 1994. Bus and rail passengers now pay 25 cents to $1 more to ride, and this is only the first of three annual fare increases planned by the transit agency. Under the hikes, local bus and rail fares were increased by 25 cents to $1.25. Park and Ride fares rose according to how much riders travel. For example, Park and Ride users in Missouri City saw fares go from $1.50 to $2; Katy Park and Ride customers pay $4.50, up $1 from current fares. The increase comes after METRO did away with its complex system of discounts and passes last year in favor of a Quick Card, or Q Card, payment system. The following fares are now applicable, according to the METRO web site at http://www.ridemetro.org/FareInfo/Default.aspx. Table 1. Transit Fares in Houston Area Effective November 2, 2008.

Fare Zone Chart Routes Fare Discounted Fare

Students, Seniors, Disabled

Local / METRORail $1.25 $0.60 Park & Ride Zone 1 $2.00 $1.00 Park & Ride Zone 2 $3.25 $1.60 Park & Ride Zone 3 $3.75 $1.85 Park & Ride Zone 4 $4.50 $2.25


All fares are rounded to the nearest nickel, dime, or quarter. According to the H-GAC transportation modeling department1 379,606 person trips are made by transit in the region on an average day out of a total of 22,115,558 trips, representing 1.7% of daily trips. Assuming this percentage is roughly equivalent to miles traveled, we estimate that 3,003,385 miles per day are taken via transit. ANALYSIS AND EMISSION RESULTS Assessing the effect of reduced transit fares on travel can be accomplished using transit elasticity. Elasticities are an economic measure of the percentage change in use of a good or service given a percentage change in another variable such as price. Demand elasticity is expressed as the amount of demand for a good that will change given a percentage change in price. For example, a demand elasticity of 0.50 tells us that a 10% change in price would lead to a 5% change in demand. Transit use can increase for changes in variables such as transit service and transit fares. Transit use is most elastic with respect to transit service and then transit fare. However, transit use alone is not necessarily a measure of a corresponding decrease in vehicle travel. For example, according to (Litman, 2005), transit use has a low-end short-term elasticity of 0.20 for transit use with respect to fare, and a low-end short-term elasticity of 0.03 of auto use with respect to fare. What this means is that a 50 percent decrease in transit fares would be expected to increase transit use by 10 percent but only a 1.5 percent decrease in auto use. This difference is due to the fact that the decreased transit fares will attract many non-vehicle owners and drivers while also convincing a few vehicle drivers to switch from their car to transit at least some of the time. The emissions analysis uses the following key variables:

• The current transit use is 379,606 people per day. • The current fare averages $2.95 per trip2. • The commuter route fares are lowered to $2.00 (the average annual fare for a

person using service twice per day 260 days per year). Fares for other transit services such as METRORail are decreased by the same percent.

• The percentage change in fare is 32 percent. • The high range short-term elasticity of auto use with respect to transit fare is used.

It is 0.10. If the program operates for three years before emission benefits are estimated, then longer range elasticity should be used. The long range elasticity of auto use with respect to transit fares ranges from 0.15 to 0.30.

• The average trip distance is 15 miles (work trips are 20 miles and non-work trips are generally around 10 miles)

• For this analysis,

1 Personal Communication, Shixin Gao, H-GAC and Barbara Joy, Earth Matters November 10, 2008. 2 This is based on a simple average of standard commuter route fares for the 4 zones.


• Average light duty vehicle composite emission factor for NOx for same day is 0.171 grams per mile

• Average light duty vehicle composite emission factor for VOC for same day is 0.231 grams per mile

The following utilizes the basic process suggested by the MOSERs methodology, as follows: Variables: EFA: Speed-based composite emission factor after implementation (NOx , VOC, or CO) grams/mile)


VMTA: Average Daily Change in VMT as a result of decreased

transit fares = Current daily transit ridership * average trip distance * % change in fare * elasticity of auto use with respect to transit fare = 379,606 * 15 * .32 * .1 = 182,211.

It is assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emission factors. In this analysis VMTA was derived above. Equation:


C = VMTA * EFA = 182,211* 0.171 gram/mile NOx/453.6 = 68.6 lb/day, and 0.03 tpd NOx and 182,211 * 0.231 gram/mile VOC/453.6 = 2.7 lb/day, and 0.05 tpd VOC.

COST EFFECTIVENESS If current ridership is 379,606, revenues from fares are approximately (using the assumptions above) $1,119,838/day, or $409 million a year. With the new fares the ridership would increase by approximately 12,147 people per day, to a total daily ridership of 391,753. Fares at this ridership are $783,507 a day, or about $286 million per year. Planning for transit service increases and administration costs are not known at this time.


Total annual costs in transit fare decreases alone are $123 million and total annual emission reductions of NOx and VOC combines are 29 tons per year. Therefore a rough estimate of cost effectiveness is 4.2 million dollars per ton. COMMENTS This evaluation is based on hypothetical assumptions and data for this program and may be considered for use in ozone plan after review of key assumptions. SUMMARY OF RESULTS


Measure ID Name Description

Affected Source


Cost Effectiveness

($/ton) 85 Decreased

transit fares

32% decrease in transit fares

On-Road: Commute Vehicles

40.7 VOC 30.3 NOx

0.1 0.05 0.03

>$1 million

G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure90-SubBusService-EM_051009.doc

Control Measure: #90, Subscription Bus Service Category: On-Road Author: Barbara Joy, Earth Matters Inc DESCRIPTION There are many types of subscription bus services offered in the Houston and other metropolitan areas. The analysis presented here focuses on a subscription bus service catering to those that are least likely to use transit – white collar workers whose work load would make a quiet stress-free ride to work with internet access offered very attractive. Among the major obstacles to transit use are limitations in service between residential and employment areas. If transit service were designed specifically for certain residential areas to highly used but somewhat underserved employment areas, transit use could increase substantially. An example of such a service would be between the Katy areas to downtown areas such as the Texas Medical Center. There are a number of potential services that could assist in transit use between such areas, including personalized rapid transit, subscription bus service, business first buses, easier access between Metro and other services such as those provided by TREK (such as a universal card), and personalized transit planning. There is a likelihood of some pent-up or latent demand for transit service that specifically serves individuals because of time spent in traffic, gas prices, maintenance and parking costs that can be significantly offset by using an alternative mode of transportation such as transit. For example, personalized transit planners, somewhat like personal shoppers, could assist individuals by showing them how to easily use transit from one point to another (such as home to work, work to lunch spots or meeting locations, and work to home). Such a service could even be provided online. In addition, some buses could be equipped with fold-down tables and wireless internet connections (for example through cell-phone companies) so that people could work while on the buses, and feeder shuttles could bring people from transit stops directly to work centers. This measure evaluates the benefits of a hypothetical and ambitious program that would provide these services. It is assumed that 100 new business buses (buses equipped with fold-down tray tables and wireless internet) seating 35 people each providing service directly from neighborhoods to specific work locations would operate four trips per morning and four per evening. Service would also be augmented by the addition of 100 shuttle buses to provide service between current METRO stops and (1) under-served residential area too far from transit centers or park and ride lots to utilize them; and (2) employment areas in downtown Houston which currently do not have sufficient transit access. The shuttle buses are assumed to seat 15 people each and operate six trips each morning and six each evening. For the purpose of simplicity it is assumed that currently planned expansions to METRO service would accommodate the extra ridership created by the shuttle services. If this measure results in emissions significant enough to merit further review, this assumption, along with the others would need to be refined.


METHODOLOGY AND EMISSIONS ANALYSIS This analysis is based upon the hypothetical scenario described above and an assumption that after a year of marketing, the development of an easy-to-use internet personal planning site, and fine-tuning the routes that the vehicles will be 80% full on an average day. The emissions analysis uses the following key variables:

• There are 100 buses seating 35 people operating four round trips (per person) per day; at 80% capacity this is equivalent to 11,200 people per work day;

• There are 100 shuttle buses seating 15 people operating 6 round trips (per person) per day; at 80% capacity this is equivalent to 7,200 people per work day.

• It is assumed that 100% of shuttle use is due to new transit users who did not previously use transit because it did not provide a viable way to their place of employment or their home.

• The average work trip distance is 40 miles round trip • The business buses travel 40 miles for each round trip, or 160 miles each day per

bus; new emissions due to these buses is therefore based upon an average weekday mileage of 16,000 miles.

• The shuttle buses are assumed to travel 10 miles per round trip, or 60 miles per day per shuttle; new emissions due to the shuttles is therefore based upon an average weekday shuttle mileage of 6,000 miles.

• Average light duty vehicle composite emission factor for NOx in 2018 is 0.171 grams per mile

• Average light duty vehicle composite emission factor for VOC is 0.231 grams per mile.

• Average shuttle bus emissions are represented by the MOBILE6 category HDDV6 and are 1.0 grams per mile of NOx and 0.18 grams per mile of VOC in 2018.

• Average transit bus emissions are represented by the MOBILE6 HDDBS category and are 4.74 grams per mile NOx and 0.36 grams per mile VOC in 2018.

The following utilizes the basic process suggested by the MOSERs methodology, as follows:

Variables

EFA: Speed-based composite emission factor for passenger vehicles (NOx , VOC, or CO) grams/mile)

EFB: Speed-based running composite emission factor for transit

vehicles (NOx , VOC, or CO) (grams/mile)


VMTA: Average Daily Change in passenger VMT as a result of increased transit service

VMTB: Average Daily Change in transit vehicle VMT as a result of increased transit service

Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emission factors. In this analysis VMTA is 18,000 new transit users * 40 mile average round trip work distance = 736,000 miles per weekday. VMTB is SUM(VMT for business buses and VMT for shuttle buses) = 22,000 miles/day. Equation:

Daily Emission Reduction from passenger vehicles =

C = VMTA * EFA = 736,000 * 0.171 gram/mile NOx/453.6 = 277.2 lb/day, and 0.14 tpd NOx and 736,000 * 0.231 gram/mile VOC/453.6 = 374.5.4 lb/day, and 0.19 tpd VOC. Daily emission increase from increased transit vehicles

= 16,000 * 4.74 gram/mile NOx = 167 lb/day and 0.08 tpd NOx; 16,000 * 0.36 gram/mile VOC = 12.7 lb/day and 0.01 tpd VOC and 6,000 * 1.0 gram/mile NOx = 13 lb/day and 0.006 tpd NOx. Total NOx increase is 0.09 tpd NOx. = 6,000 * 0.36 gram/mile VOC = 4.8 lb/day and 0.002 tpd VOC. Total VOC increase is 0.01 tpd. The net emission decrease is 0.05 tpd NOx and 0.18 tpd VOC. COST EFFECTIVENESS Costs of the program are estimated based upon hourly fees paid to transit vehicle leasing companies used in Houston such as AFC. Based on a conversation with Trek, these costs are $54.85/hour to cover the driver, the vehicle and other costs such as fuel and insurance. Both the business buses and the shuttles would operate from 4:30am to about


8 pm to provide the number of round trips described, or about 16 hours per day. At 260 weekdays per year the gross cost will be $45,635,200/year before marketing and administration. Because of the convenience of the business buses, it is assumed that each rider would pay a round-trip fare of $5 and that shuttle riders would pay a round-trip fare of $2. Therefore fare revenue would be $18,304,000. It is possible that additional revenue could be generated by selling ad space on the interior walls of the buses and shuttle vehicles. This is not currently done in the Houston area but is in many other urban areas and can be a significant source of revenue. For this analysis it is assumed that no advertising revenue would occur and that marketing/internet costs are insignificant compared with the operation of the vehicles. Therefore net costs are $27.3 million dollars per year. Annual combined NOx and VOC benefits are 59.8 tons. Cost effectiveness is $456,500/ton. COMMENTS This evaluation is based on hypothetical assumptions and data for this program and may be considered for use in ozone plan after review of key assumptions. The use of 100 of each type of bus is intended to assist in scaling the emissions estimates should other possibilities for implementation be considered. Also key is that the emission factors used in the analysis are emission factors with currently programmed federal and other control measures such as Tier 2 tailpipe standards. Other measures are being evaluated for the H-GAC region, such as California LEV (low emission vehicles), cleaner fleets and wider application of the Inspection and Maintenance program. If these or other similar programs were implemented, the emission factors used to evaluate programs affecting the amount of travel (such as this one) would be smaller – each mile driven would be at a lower emission rate and therefore each mile not driven would not reduce emissions as much as it would have without the additional measures.


SUMMARY OF RESULTS Expected Emission Reduction Measure



Cost Effectiveness

($/ton) 90 Subscription

bus service Business buses, shuttle services, personalized transit

On-Road 40.7 VOC 30.3 NOx

0.4 0.2

0.18 0.05

$456,500

G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control Measure 92 Transit Options_051009.doc

Control Measure: #92, 99, 145, Public Transit Improvements Category: On-road Author: Chris Lindhjem, ENVIRON DESCRIPTION There are three measures related to transit options in the list of measures that could produce measurable emissions reductions shown below.

• Electrified buses • Light rail expansion • Hybrid buses

The electrified buses or light rail require infrastructure improvements (overhead catenary or rail construction), but would result in an elimination of the engine emissions on those routes served. The hybrid buses available have two main advantages in that no new (other than the buses themselves) infrastructure is required and reduced fuel consumption. The main disadvantage is that a fraction of emissions reductions (about 25%) would be applied to already low emissions new bus engine emissions. Therefore, the emission reduction in tons per year would be lower than that for projects implemented through 2007. IMPLEMENTATION FEASIBILITY Light rail has been built in Houston starting with the opening in 2004 of 7.5 miles of a system. The planned and potential expansion beyond the current network would require significant investment as well as identifying the best possible routes. The use of electrified buses with an overhead catenary system has not been employed in Houston. The cost would presumably be lower than the light rail option, but it is unknown how much this option would cost. The buses that can run in electric or diesel mode would not necessarily be fixed to the electrified system, but would be specialty purchases. Hybrid buses are an attractive option because they are in effect identical in operation to conventional buses. The emissions difference between a new conventional bus and a hybrid one will be small once the NOx standard is fully implemented in 2010. But the fuel savings may be sufficiently significant to offset the extra cost of the hybrid system.


PUBLIC ACCEPTANCE The light rail or other options to bus routes have been extensively vetted throughout the process of designing the system. But there have been discussions and lawsuits about the placement and design of the new system. Hybrid buses are a seamless transition from the conventional bus service. Often passengers would not know the difference. ANALYSIS The analysis uses the forecast transit bus emissions and emissions rates to compare with the alternatives to transit buses or the use of the hybrid technology buses. EMISSIONS AFFECTED The transit bus emissions forecasted for 2018 are expected to be 0.05 tpd VOC and 0.98 tpd NOx. Transit buses typically have a 12-year life, and the most stringent NOx emission standard will have full effect by 2010, so most buses in-use in 2018 will meet that low NOx standard. EMISSIONS BENEFIT The current rail system offsets 346 bus trips per day along the 7.5 mile route would be equivalent to 0.001 tpd VOC and 0.012 tpd of NOx emissions for the average fleet of buses in 2018. The planned and potential expansion of the network could be up to an order of magnitude increase by 2018, and could include commuter rail as well as light-rail. Hybrid buses usually recover enough energy during braking and allow the engine to operate at peak efficiency to effect a 25% reduction in fuel consumption and emissions. Using the average emission rate figures in Table 1, a 2018 model year bus traveling 50,000 miles a year would have 0.012 tpd VOC and 0.044 tpd NOx benefit. Table 1. Transit bus emission rates.

Model Year

VOC (g/mile)

CO (g/mile)

NOx (g/mile)

1994 0.21 2.79 21.821995 0.21 2.79 21.841996 0.21 2.79 21.861997 0.21 2.79 21.861998 0.21 2.79 17.471999 0.21 2.79 17.472000 0.21 2.79 17.47


Model Year

VOC (g/mile)

CO (g/mile)

NOx (g/mile)

2001 0.21 2.79 17.472002 0.21 2.79 16.612003 0.21 2.79 14.042004 0.22 2.79 9.902005 0.22 2.79 9.902006 0.22 2.79 9.902007 0.22 0.29 5.752008 0.22 0.29 5.722009 0.22 0.29 5.692010 0.22 0.29 0.812011 0.22 0.29 0.812012 0.22 0.29 0.812013 0.22 0.29 0.812014 0.22 0.29 0.812015 0.22 0.29 0.812016 0.22 0.29 0.812017 0.22 0.29 0.812018 0.22 0.29 0.81

COST AND COST-EFFECTIVENESS The cost of the current light-rail system was $324 million for the initial 7.5 mile system. With an expected life of 30 years, the annual cost was estimated at $16.5 million. This does not count the operating or maintenance cost of the light-rail or the cost benefit compared with buying and operating buses (previous operations estimated to involve about 16 buses) along the same route. The cost effectiveness for the system is quite high (about $3 million per ton of VOC and NOx reduced) if basing the light rail benefit solely on the air emissions reduced. This is due to the expected low emission rate from the future year buses, and not counting alternative benefits such as congestion relief, increase ridership, or lower maintenance costs. Not counted in the benefits is the potential for rail to encourage greater ridership than the alternative bus routes, but comparison data on rail and bus ridership has not yet been made available. Hybrid buses have historically cost $200,000 more than conventional buses and typically produce a 25% reduction in emissions and fuel consumption. Other sources (SF Metro, 2008) note $150,000 cost and 30% improvement. The fuel consumption benefit would however be significant, and depending upon the fuel cost could pay for the higher purchase price over the life of the vehicle. But using the $200,000 figure and a 12-year life, the annualized cost for the hybrid bus is about $20,000 per year resulting in a cost effectiveness of $350,000 per ton of VOC and NOx reduced. This high cost estimate assumes the highest cost, lowest benefit, and does not consider other improvements in fuel or operating costs. Model year 2009 trucks would be expected to have almost ten times the benefit.


SUMMARY OF RESULTS



Affected Emissions

(tpd) % Tpd


($/ton)

92, 99 Light rail or electrifying

routes

Increased electric grid

powered transit

Transit Buses

0.05 VOC 0.98 NOx

1 – 10%

0.012 – 0.12 NOx

<$3 million

145 Hybrid Buses

New energy saving

technology

Transit Buses

0.05 VOC 0.98 NOx 25% 0.23

NOx <$350,000

REFERENCES METRO. 2008, “The Facts: METRORail on Main Street,” http://www.metrosolutions.org/go/doc/1068/112217/ San Francisco Metro, hybrid bus fact sheet, http://www.sfmta.com/cms/mfleet/hybrids.htm

G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure102-FreeCircService-EM_051009.doc

Control Measure: #102, Free Circulator Service to Major Generators Category: On-Road Author: Barbara Joy, Earth Matters Inc DESCRIPTION This measure would provide free shuttle/transit services connecting remote areas with major activity generators. Among the major obstacles to transit use are limitations in service between residential and employment areas. If transit services were designed specifically for certain residential areas to highly used underserved employment areas, transit use could increase substantially. An example of such a service would be between the Katy area to downtown areas such as the Texas Medical Center, Bellaire, Greenway Plaza, or the central business district. This measure evaluates the benefits of a hypothetical and ambitious program that provides free services between residential areas and downtown employment centers. According to H-GAC1 there are 998,992 jobs at the following downtown employment centers in 2018. Table 1. Employment Centers and Employment in 2018

Employment Center 2018

Employment Bellaire/Pin Oaks 19,837Brookhollow 49,843CBD 146,600Clear Lake/NASA 42,444Galleria 141,801Greenspoint 94,052Greenway Plaza 60,416Medical Center 135,749Northwest Crossing 53,225Sharpstown 38,512The Woodlands 30,379West Houston 105,335Westchase 80,799

It is assumed that 1,500 new shuttles seating 15 people each would provide service directly from under served residential neighborhoods to the above employment centers. This hypothetical scenario would service slightly over ten percent of the employment at the centers listed above.

1 H-GAC 11/10/08. Personal communication Sharon Ju, H-GAC and Barbara Joy, Earth Matters.


ANALYSIS This analysis is based upon the hypothetical scenario described above and an assumption that after a year of marketing, the development of an easy-to-use internet personal planning site, and fine-tuning the routes that the vehicles will be 90% full on an average day. EMISSION ANALYSIS The emissions analysis uses the following key variables:

• There are 1,500 buses seating 15 people operating five round trips (per person) per day; at 90% capacity this is equivalent to 101,250 people per work day;

• It is assumed that 100% of shuttle use is due to new transit users who did not previously use transit because it did not provide a viable way to their place of employment or their home.

• The average work trip distance is 40 miles round trip • The shuttles travel 40 miles for each round trip, or 160 miles each day per shuttle;

new emissions due to these buses is therefore based upon an average weekday mileage of 240,000 new miles by shuttle buses.


• Average light duty vehicle composite emission factor for VOC is 0.231 grams per mile.

• Average shuttle bus emissions are represented by the MOBILE6 category HDDV6 and are 1.0 grams per mile of NOx and 0.18 grams per mile of VOC in 2018.

The following utilizes the basic process suggested by the MOSERs methodology, as follows:

Variables

EFA: Speed-based composite emission factor for passenger vehicles (NOx , VOC, or CO) grams/mile)

EFB: Speed-based running composite emission factor for transit

vehicles (NOx , VOC, or CO) (grams/mile)

VMTA: Average Daily Change in passenger VMT as a result of increased transit service

VMTB: Average Daily Change in transit vehicle VMT as a result of increased transit service


Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emission factors. In this analysis VMTA is 101,250 new transit users on an average work day * 40 mile average round trip work distance = 4,050,000 miles per weekday, or 2,892,857 miles per average day. VMTB is VMT for shuttle buses = 240,000 miles/day. Equation:

Daily Emission Reduction from passenger vehicles =

C = VMTA * EFA = 2,892,857 * 0.171 gram/mile NOx/453.6 = 1,090 lb/day, and 0.54 tpd NOx and 2,892,857 * 0.231 gram/mile VOC/453.6 = 190 lb/day, and 0.09 tpd VOC. Daily emission increase from new shuttle buses

= 240,000 * 4.74 gram/mile NOx = 2,505 lb/day and 1.25 tpd NOx; 240,000 * .36 gram/mile VOC = 12.7 lb/day and 0.006 tpd VOC The net emission effect is an increase in NOx of 0.71 tons per day and a decrease of 0.08 tpd VOC. COST EFFECTIVENESS This measure results in a net increase of NOx and is by that fact alone not considered cost effective and is not recommended for further consideration. COMMENTS This evaluation is based on hypothetical assumptions and data for this program. Other assumptions could result in different results.


SUMMARY OF RESULTS




Cost Effectiveness

($/ton) 102 Free shuttle

service to employment centers

Free shuttle service to employment centers


40.7 VOC 30.3 NOx

<0 0.08 VOC NOx

Increase of 0.71

Not cost effective

G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure106-CWW-EM_051009.doc

Control Measure: #106, Compressed Work Week Program Category: On-Road Author: Barbara Joy, Earth Matters Inc DESCRIPTION Compressed work weeks are among the most effective of transportation demand management measures. Many Houston area employers currently already have compressed work week programs. The way most programs work is that employees either have a 4/40 schedule or a 9/80 schedule. A 4/40 schedule means they work four ten hour days per week and have one day off. A 9/80 schedule means the employees work 9 hours a day and take one day off every two weeks. Most programs operate on a 4/40 schedule. Currently the H-GAC alternative work schedules program, which operates under the umbrella of the Commute Solutions program, helps employers implement several measures including telecommuting, carpooling, vanpooling, alternative parking and compressed work weeks. A program specifically aimed at increasing the amount of compressed work weeks through a mandatory program is not currently in place but could be implemented as a part of the overall ozone attainment plan. ANALYSIS The purpose of this analysis is based upon the need to determine what programs, if implemented in a highly ambitious manner, might yield sufficient emission reductions to be further considered for inclusion in the 8-hour ozone attainment plan. The analysis presented here explores the potential effects of a very ambitious compressed work week program targeting 20 percent of Houston area employees for a 4/40 program. EMISSIONS ANALYSIS There are a number of variables important for evaluating the emission benefits of this measure. These are as follows:

• Total employment projected by H-GAC for 2018 is 3,183,0001. The above-cited figure of 20% would be 636,600 employees.

• The average round trip work distance for Houston area employees is 40 miles; therefore daily VMT reduction on a compressed work week day is 25,464,000 and on an average day (1/7th of the miles) would be 3,637,714 miles per day.


1 http://www.h-gac.com/rds/forecasts/documents/Pop_employment_Counties_Region.pdf


• Average light duty vehicle composite emission factor for VOC in 2018 is 0.231 grams per mile

The emissions analysis utilized the basic process suggested by the MOSERs methodology, as follows: Variables: EFA: Speed-based composite emission factor after implementation (NOx , VOC, or CO) grams/mile)


VMTB: Change in vehicle miles traveled as a result of

implementation = number of compressed work week employees * round trip distance * 1/7 (one day every 7).

It was assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emission factors. Equation:


C = VMTB * * EFA = 3,637,714 * .171 gram/mile NOx/453.6 = 1,370 lb/day, and 0.69 tpd NOx and 3,637,714 * 0.231 gram/mile NOx/453.6 = 1,851 lb/day, and 0.93 tpd VOC.

COMMENTS This evaluation is based on hypothetical assumptions and data for this program and may be considered for use in ozone plan after review of key assumptions. The feasibility of achieving a 20% participation rate from all Houston area employees has not been studied. Cross effects of a 20% compressed work week share on alternative modes such as transit, vanpooling and ridesharing have not been evaluated. Therefore if all these programs were implemented, emission benefits could not simply be added up without some accounting for the relationships between the programs.


COST EFFECTIVENESS Costs for this hypothetical program are not known. Costs to employers should be minimal and benefits in the form of decreased turnover, reduced parking demand, and possibly fewer sick days would be expected to offset costs. Current outreach/advertising and marketing costs for the Commute Solutions program are $2.5 million annually. If we conservatively assume half would be spent on compressed work weeks alone, and evaluate annual combined NOx and VOC reductions of 584 tons per year then cost effectiveness would be Annual NOx emission benefits are daily benefits * 260 workdays per year, or 598 tons per year. This would result in an estimated cost effectiveness of $2,140 per ton. This evaluation is based on hypothetical assumptions and data for this program and may be considered for use in ozone plan after review of key assumptions. SUMMARY OF RESULTS



Affected Emissions

(tpd) % Tpd

Cost Effectiveness

($/ton) 106 Compressed

Work Week Mandate

20% of area employees on a 4/40 schedule


40.7 VOC 30.3 NOx

2.3 0.93 0.69

$2,140

G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure108-rideshare-em_051009.doc

Control Measure: #108, Internet ridematching services Category: On-Road Author: Barbara Joy, Earth Matters Inc DESCRIPTION An H-GAC ridesharing program was kicked off in August of 2005, which utilizes computer-based methods similar to other online travel programs such as Travelocity. The program is internet based and uses the consultant NuRide, Inc. (http://www.nuride.com), the nations first incentive-based rideshare network. NuRide’s innovative online program lets individuals use NuRide’s patent-pending technology to find the ideal partner with whom to share a single ride for work or pleasure. Subscribing to the philosophy that people sharing rides provide a valuable service to their community, NuRide offers its members rewards each time they use the ridesharing program. By accumulating "NuRide Miles," members earn enough points to acquire gift cards and gift certificates from a variety of corporate sponsors such as Old Navy, TGI Fridays, Macy’s and many other familiar retailers and restaurants. The program’s incentives to ridesharers are significant enough to have made the program grow from a few hundred carpoolers to nearly 5,000 in August 2008. The incentives mentioned above earn points at dozens of participating retailers. Points are only earned when, for each ridesharing day, ridesharers match themselves with an online carpool and fill out a survey form (all ridesharers must fill out the survey or none will receive credit). Other incentives are the ease and convenience, as well as a “cool factor”. It should be noted that in addition to NuRide, there are several other internet based carpooling websites. eRideshare.com is the leading carpool/ridesharing website, according to Yahoo and Google. It has been recognized as "Best of the Net" by About.com, and was featured in Al Gore's book An Inconvenient Truth as a way to Take Action. There are also GoLoco, Zimride (which uses a facebook application), Mycarpools.com and CarpoolWorld.com. These internet sites saw enormous growth during 2008 while gas prices were rising. Specific statistics on Houston for all ridesharing sites are not available. ANALYSIS Between September 2007 and August 2008 the NuRide program grew 55%. This analysis is based upon the assumption that the program, together with the other programs mentioned above, continues to grow at this rate through 2018. If it does, there will be 376,757 carpoolers in the Houston region. It is assumed carpools average 2.7 people per vehicle and those carpoolers rideshare an average of twice per week at an average trip distance of 15 miles.


EMISSIONS ANALYSIS The emissions analysis utilized the basic process suggested by the MOSERs methodology, as follows: Variables: EFA: Speed-based composite emission factor after implementation (NOx , VOC, or CO) grams/mile)


TEFAUTO: Auto trip-end emission factor (NOx , VOC, or CO)

(grams/trip) VTB: Number of new carpoolers. AVR: Average vehicle ridership in carpools TLB Trip Length

It was assumed that emission factors and trip length before and after implementation are the same. Emission changes from vehicle trips and associated start emissions are evaluated through the use of composite emission factors and the assumption that access to the carpool is not through SOV use. Note that if there are 2.7 people per carpool and one is a driver not reducing mileage, each carpool has, on average 1.7 people that are actually reducing their driving behavior. Therefore of the 376,757 carpoolers, 237,217 are actually reducing travel. Equation:


C = VTB* ((AVR-1)/AVR) * TLB * 2* Frequency * EFA = 237,217 * 15 * 2 * 2/7 * 0.171 gram/mile NOx/453.6 = 766 lb/day, and 0.38 tpd NOx and 237,217 * 15 * 2 * 2/7 * 0.231 gram/mile NOx/453.6 = 1,035 lb/day, and 0.52 tpd NOx


COST EFFECTIVENESS NuRide’s budget for 2005 – 2006 fiscal year was $400,000 but the program, as planned, is moving towards being self-sustaining. It is expected that well before 2018 the costs of the program will be limited to reporting costs. Conservatively we estimate the combined reporting and administrative costs to H-GAC to be $100,000 in 2018. Annual emission benefits are 98.55 tons and the cost effectiveness would therefore be $1,014 per ton. COMMENTS This evaluation is based on hypothetical assumptions and data for this program and may be considered for use in ozone plan after review of key assumptions. SUMMARY OF RESULTS




Cost Effectiveness

($/ton) 108 Internet

ridemat-ching

NuRides plus other internet ridematching services grow at same rate NuRides grew between 2007 and 2008.


40.7 VOC 30.3 NOx

1.3 0.52 0.38

$1,014

G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control Measure 109 Vanpoo_051009.doc

Control Measure: #109, Vanpooling Category: On-Road Author: Chris Lindhjem, ENVIRON DESCRIPTION H-GAC administers a vanpooling program that consists of ongoing efforts to reduce congestion by providing alternative transportation through trip sharing with vanpools. The program began operation in 1996 and is funded using Surface Transportation Program (STP) funds, METRO local funds and employer incentives, which provide reduced monthly costs to participating employees. As of August 2008 the vanpool program had 755 vans and 7,846 riders with an average of 10.4 riders per van. The vanpools average 54.6 miles per day (round trip). The VMT reduction resulting from these vanpoolers will be about 54.6 miles per day, or about 100 million miles per year, assuming a 260-day work year. As vanpools are driven about 11 million miles per year to offset the 111 million miles that would have been driven in passenger vehicles. IMPLEMENTATION FEASIBILITY The approach here is to use the current progress of the vanpooling program to determine the benefit of the program in 2018. PUBLIC ACCEPTANCE This program has been popular, but it has been heavily subsidized and marketed to date. The riders gain the benefit of reduced fuel costs and deterioration of their personal vehicles. ANALYSIS The analysis is straightforward in that the emissions of single occupancy vehicles (SOV) are subtracted by the emissions from vans. EMISSIONS AFFECTED The primary emission affected by this measure are the light-duty single occupancy vehicles shown in Table 1.


Table 1. On-road weekday emissions 8-County totals (tpd).

Pollutant Light-duty Heavy-Duty

Gasoline Heavy-Duty

Diesel Total On-road

Vehicles VOC 40.69 0.80 3.15 44.64 CO 691 13 5 709 NOx 30.31 1.88 19.67 51.69 EMISSIONS BENEFIT The emissions analysis used the basic emission calculation for the average light-duty (commute vehicle) and the van used in the primary commute, as follows: Variables: EFA: Composite emission factor for commute vehicle (NOx, VOC,

or CO) grams/mile for the average light-duty vehicle

EFB: Van (LDGT4) emission factor (NOx, VOC, or CO) (grams/mile)

Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emission factors shown in Table 2. Table 2. On-road emission factors 8-County totals (g/mile).

Personal Vehicles Average Light-Duty

Average Van

LDGT4 Average Pollutant G/mile G/mile VOC 0.23 0.20CO 3.92 3.83NOx 0.17 0.27 Example Calculation:

Daily Emission Reduction = VMTA * EFA – VMTB * EFB 82 grams per day NOx benefit per van = 10.4 passengers * 54.6 miles * 0.171 gram/mile NOx – 54.6 miles * 0.267 gram/mile

COST AND COST-EFFECTIVENESS The total subsidized cost of the program has been $3,113,427 for the 12 months ending June 2008. Based on a 260 day work year, annual benefits for all vans are forecast to be 26 tons VOC and 18 tons NOx in 2018. The cost effectiveness would be $120,000/ton for VOC and $175,000/ton for NOx and $71,000 per ton of VOC + NOx for the air quality benefits alone. Vanpool programs are also administered for congestion relief benefit and


the benefit of removing 7,100 vehicles from the commuting peaks has not been incorporated into the cost benefit. SUMMARY OF RESULTS



Affected Emissions VOC / NOx % tpd


($/ton) 109 Vanpooling Vanpool Light-duty

On-road 41 / 30 tpd 0.4 /

0.2 0.1 / 0.07

$71,000 for VOC + NOx

G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control Measure 126 Reduced Idling_051009.doc

Control Measure: #84, 126, 147, 148, Reduced Idling Category: On-road Author: Chris Lindhjem, ENVIRON DESCRIPTION Idling of vehicles is inherently an inefficient operation that can produce unwanted air pollutants. Idling however also occurs during normal driving and other operations such as when the engine powers necessary accessories including for example man-lifts or concrete tumblers. Therefore it is not possible to eliminate all idling. But idle reduction programs are interesting because the costs are typically low and may be a net savings to the owner/operator of the vehicle while also reducing air emissions. IMPLEMENTATION FEASIBILITY There are several methods that have been attempted to reduce idling of vehicles; primarily from heavy-duty trucks that often idle while the driver is off-duty or performing other duties nearby. There are two basic methods: a voluntary approach where alternatives to idling are provided, and a punitive (fines) method where no idle zones are posted and policed to eliminate idling. PUBLIC ACCEPTANCE A voluntary program can achieve enthusiastic support because infrastructure to reduce fuel costs can be paid for from public funding. A requirement to eliminate idling would be difficult to administer, but would have a larger impact on emissions. ANALYSIS In the strictest implementation, idling more than 5 minutes would be prohibited except for normal operations whether or not an alternative to idling exists. This could affect all heavy-duty vehicles whether delivery / retail vehicles or other vehicle functions. The EPA (2004) guidance estimates that up to 3.4% of Class 8 truck NOx emissions could be reduced through reduced long duration idling programs. This presumably sets up the maximum benefit for programs such as the IdleAire truck stop electrification project funded by TERP. For light-duty vehicles at drive-thru operations, it would be difficult to gauge how much that would be. For an extraordinary total, even if an astounding 10% of the HGB population of 5,628,101 idled 10 extra minutes in a single occupancy vehicle, the


resulting emissions increase would be 0.16 tpd VOC and 0.04 tpd NOx. This calculation used the emission rates in Table 1 for passenger cars and light-duty gasoline trucks. Table 1. Idle emission rates for light-duty gasoline vehicles in 2018.

Vehicle Type VOC (g/hr)

CO (g/hr)

NOx (g/hr)

LDGV (passenger cars) 1.56 10.55 0.38LDGT1 (Light-duty trucks) 1.70 11.01 0.36LDGT2 1.82 12.49 0.53LDGT3 1.16 9.58 0.37LDGT4 1.22 10.03 0.57 EMISSIONS AFFECTED The EPA guidance on reduced idling includes an upper end estimate of 3.4% of area NOx due to extended idling. For the all diesel and gasoline trucks the NOx emissions are 21.6 tons per day, and for the larger Class 8 trucks (the subject of the EPA guidance) the NOx emissions are 13.2 tons per day for a weekday in 2018. EMISSIONS BENEFIT If idle reduction programs can be expanded to all heavy-duty vehicles, then 0.73 tpd could be reduced. The long duration idling reduction for Class 8 maximum would be 0.45 tpd of which 0.33 tpd was credited to the IdleAire TERP project expected to last through 2020. COST AND COST-EFFECTIVENESS The TERP program to supply idle reduction technology in the HGB area was estimated to reduce NOx emissions at $1,200 per ton. This truck stop electrification project however targets the most readily available and likely largest source of idling trucks, and so reducing idling in other areas would produce less benefit for the investment. It is not possible to estimate the lost revenue and cost of prohibiting drive-thru operations during ozone episodes or for the summer season when ozone events would likely occur.


SUMMARY OF RESULTS


ID Name Description Affected Sources

Affected Emissions

(tpd) % Tpd


($/ton)

126, 147, 148

Idle limits for heavy-duty vehicles

Idle Reduction Programs

Heavy-duty

vehicles 13.2 – 21.6 3.4 0.45 –

0.73 $1,200

84

Prohibit drive-thru service during ozone season

Idle Reduction Program

Light-duty vehicles

40.7 VOC 30.3 NOx

0.4% VOC 0.1% NOx

0.16 VOC 0.04 NOx

Unknown

REFERENCES EPA. 2004. “Guidance for Quantifying and Using Long Duration Truck Idling Emission

Reductions in State Implementation Plans and Transportation Conformity,” Office of Transportation and Air Quality,” EPA420-B-04-001, January 2004, pg. 12 http://www.epa.gov/SmartwayLogistics/documents/420b04001.pdf.

G:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC Measure 127 Mex trucks_051009.doc

Control Measure: #127, Heavy Duty Vehicle Border Inspection Program Category: On-road Author: Hazel Barbour DESCRIPTION This measure would build on the safety inspection procedures now in place at Texas/Mexico border crossings using remote sensing to identify high emitting vehicles. IMPLEMENTATION FEASIBILITY DPS regulations require that HDDVs undergo safety inspections at border crossings (HDDV inspections are also carried out at weigh stations throughout the state). Current Texas legislation allows emissions testing of diesel vehicles if TCEQ determines that an inspection program would minimize emissions (HSC.382.2.2(i)). Of the more than four million trucks that crossed the border from Mexico into the United States in 2003, 68 percent enter through Texas Ports of Entry. However, most of these Mexican trucks are currently restricted to operating within the designated commercial zones located around the border cities. In these zones, which stretch 20 miles on both sides of the Mexican border, drayage trucks cross the border from Mexico to depots where their load is transferred to US trucks for onward transportation. The only current exceptions to this restriction are a very small number of Mexican carriers that were grandfathered in and those carriers taking part in a pilot program implemented by US DOT. This 12 month program began in September 2007 and allows up to 100 carriers from each country to operate beyond the designated commercial zones if their trucks have effective safety controls in place. However, at the point of writing, funding to continue the program has not been appropriated and the future of expanding the ability of Mexican trucks to operate outside of the 20 mile commercial zones is unclear. According to the Council on Hemispheric Affairs, at the halfway point of the program, “more than twice as many US truckers (680 trips) had exercised their extended privileges in comparison to their Mexican counterparts (325 trips)”. In order for implementation of emissions inspections at Texas border crossings to have any identifiable impact on emissions of pollutants in the Houston-Galveston-Brazoria area, the current restriction on allowing Mexican trucks to operate more widely in the US than in the designated commercial zones must be permanently lifted. Until then, the measure has little relevance for the HGB. Additionally, when the border is eventually fully open to Mexican trucks, it is still to be expected that the transition from the current drayage system will be very gradual (Border Transportation Studies Review, TTI Aug 2005). Heavy Duty Remote Sensing Devices (HDRSD) studies have demonstrated the potential for using remote sensing to measure total emissions of in-use NO (from which NOx can be deduced) and VOC, but more work still has to be done to establish reliable pass/fail remote sensing cutpoints.


PUBLIC ACCEPTANCE Reducing emissions from diesel trucks is a strategy which is generally well received by the public. The Teamsters, Public Citizen, and Sierra Club are opposed to opening the border to Mexican trucks. ANALYSIS Opening the Texas/Mexico border to through truck traffic may result in increased Mexican plated trucks passing through the HGB area. Results from the cross border truck study carried out at Nogales showed little difference between emissions from trucks based on where they are registered i.e. in Mexico or the US. However, it should be noted that the Nogales study was conducted in 2006, prior to the pilot program allowing the limited number of long haul trucks to cross the border. Thus, almost all of the cross border traffic in the study would be drayage traffic. In the study, using a cutpoint of 144 gms/gal NO (approx 10.7 gm/bhp-hr NO) equivalent to approximately 13.4 gms/bhp-hr NOx, about 10% of the trucks at the border were flagged as potential high emitters. 95% of the trucks scanned were class 8 HDDVs. While remote sensing at the border is implementable, until pass/fail NOx emissions cut points are agreed upon, it is difficult to adequately estimate potential emissions reductions achievable using this testing methodology. However, it is possible to identify whether or not MY 1993-98 HDDVs manufactured in the US and sold in Mexico have NOx defeat devices in place (see the Consent Decree between the truck manufacturers and EPA) by using remote sensing to identify NOx levels higher than would be expected in these model year trucks. EPA estimates that the emissions benefit from bringing a truck engine with a NOx defeat device back into compliance with the federal standard is approximately 2 grams/bhp-hr, equivalent to 6.06 grams/mile. As of September 2007, of the 1.1 million trucks in the affected US population, EPA estimated that 9.5% of the trucks had been reflashed with the low NOx kit. In the Nogales truck study approximately 300 MY 1993-98 vehicles were sensed (approximately 16% were Mexican plated trucks, 74% dual plated trucks, and 10% US plated trucks). For the purposes of analyzing this measure, it is assumed that 90.5% of these trucks have the NOx defeat device in place. As required by the Consent Decree, the cost of reflashing MY 1993-98 trucks is borne by the engine manufacturers. Environmental Systems Products Inc (ESP) estimates that a 6 month remote sensing pilot program would cost $789,458. For the purposes of analyzing this measure, the writer is not able to make an assessment of the number of long haul trucks which will travel through the HGB area in the eventuality of the Texas/Mexico border becoming fully open to cross border traffic. EMISSIONS AFFECTED NOx emissions from on-road heavy duty diesel emissions for the 8 county HGB area of 19.97 tpd.


EMISSIONS BENEFIT Emissions benefit was calculated from re-flashing 272 class 8b HDDVs using EPA’s estimate of 2 grams/bhp-hr NOx reduction per vehicle (6.06 grams/mile). The average Class 8b annual mileage of 75,343 was deduced from the vehicle registration distribution in Harris County and the MOBILE6 mileage accumulation.

NOx reduction per vehicle: 0.503 tons per year Total NOx reduction: 136.8 tons per year or 68.3 for 6 month pilot project Tons per day NOx reduction (assuming 250 day year): 0.547 tons per day

COST AND COST-EFFECTIVENESS The only cost readily available is ESP’s estimate of $789,458 for a 6 month remote sensing pilot program. The cost of the NOx reflash is not included as this should be borne by the engine manufacturers. It is assumed that approximately the same number of MY 93-98 HDDVs will be identified as in the Nogales truck study. Cost effectiveness is therefore calculated as $11,542 per ton of NOx reduced. SUMMARY OF RESULTS



Sources Affected

Emissions(tpd) % Tpd


($/ton)

127

Heavy duty border vehicle inspection program

Use of remote sensing at Texas border crossing(s) to identify high emitting vehicles – pilot program

On-road HDDV NOx emissions

19.67 tpd NOx 2.74%

0.547 tpd NOx from 272 MY 1993-98 vehicles

$11,542 per ton NOx

REFERENCES: Council on Hemispheric Affairs: www.coha.org. Texas Transportation Institute, Texas A&M University: Border Transportation Studies Review, Aug 2005. M J Bradley and Associates: Cross Border In-Use Emissions Study for Heavy Duty Vehicles, Nogales, AZ, September, 2006. Environmental Systems Products Inc (ESP): Remote Sensing proposal for Diesel Emission Control Evaluation, Nov 2008 US EPA: Anne Wick, Vehicles and Engines Team Leader; [email protected].

G:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC measure133 IM_051009.doc

Control Measure: #133, Expand the emissions testing program to 3 counties not currently included in the program

Category: On-road Author: Hazel Barbour DESCRIPTION This measure would extend implementation of the vehicle emissions inspection (I/M) program to Chambers, Liberty and Waller counties. While initial TCEQ regulations required that the ASM/OBD program be implemented in these counties in 2004, the county judge and commissioners’ court of each of the three counties petitioned TCEQ to remove the requirement. IMPLEMENTATION FEASIBILITY Current legislation (HSC 382.302(a)) allows for counties not required to implement an I/M program to opt-in as follows: (petition to TCEQ) must be made by a resolution adopted by the governing body of the participating county and the governing body of the most populous municipality in the county. Implementation of the Low Income Repair and Assistance Program (LIRAP) is not a requirement of I/M program implementation, thus counties wishing to implement LIRAP are also required to opt in to this program in a similar manner. If an I//M program is proposed for the three counties, the issue of whether to only test MY 1996 and newer vehicles (i.e. OBD test) or to also include the ASM test requirement for older vehicles will need to be addressed. Current estimates of ASM/OBD analyzer costs range from $32,000 - $40,000. OBD-only analyzer costs range from $7,000 to $9,000. It is unlikely that the program could be in place in the three counties until 2010/11 at the earliest. By that point, it is estimated that only 6% of subject vehicles will be MY 95 and older (data from ENVIRON, 2006) and that number will drop further every year. Given the increasingly smaller number of vehicles subject to tailpipe testing, it may be difficult to convince all of the 47 existing safety inspection stations in the three counties to pay the costs of purchasing ASM/OBD test equipment. An alternative to ASM testing would be the two speed idle test which does not require the use of a dynamometer and thus is cheaper to install and operate, but repairing failed vehicles to pass this test would only achieve VOC reductions from the MY 1995 and older vehicles. In a program area where both ASM and OBD testing is required, current rules (TAC Title 37, Part 1, Chapter 23, Subchapter G, 23.95) allow waivers to be granted to inspection stations to offer OBD only testing (known as a low volume waiver). An inspection station operating under such a waiver is limited to performing 1200 emission inspections per year (each month, the inspection station is allocated 100 emission tests). If the I/M proposal requires all 2-24 year old gasoline vehicles registered in the three counties to be tested, it could be possible to implement the program in the first years by granting low


volume waivers to all 47 inspections stations (thus allowing them to continue to offer safety inspections) and require that MY 95 and older vehicles be either tested at an ASM/OBD inspection station in one of the five existing I/M program counties or at a DPS referee station. Alternatively, a very small number of inspection stations within the three counties could be allowed to offer both ASM and OBD testing with the remainder being granted low volume waivers. In all the above scenarios, it is assumed the test fee for both the ASM and OBD tests would be the same as in the existing five HGB counties, i.e. $27.00 (plus $12.50 safety inspection fee). A program adopted in the three counties could feasibly only require MY 1996 and newer vehicles to be subject to emissions testing (using OBD). In this case, there may be an equity issue regarding the test fee in relation to the existing program in the original five counties where MY1995 and older vehicles must be tested. The $27.00 emissions test fee was originally based on the costs of ASM testing. However, current legislation in HSC 382.202 (h) does allow TCEQ to set different test fees for different counties. PUBLIC ACCEPTANCE Past history indicates there may be opposition to this measure at the county level. If the proposal is to only require MY 1996 and newer vehicles to be tested, concerns could be raised regarding allowing the oldest most highly polluting vehicles to avoid emissions testing. Adopting a fee lower than $27.00 in an OBD only program may increase general public acceptance but may cause a degree of unrest in the adjacent counties currently implementing ASM/OBD. ANALYSIS This measure was analyzed by comparing emissions in the three counties with and without an ASM/OBD I/M program using MOBILE6. The I/M program was modeled assuming ASM testing at phase-in cutpoints. It was assumed that the emissions test fee for all subject vehicles will be $27.00 and that this fee covers the inspection station costs and the LIRAP costs. The number of subject vehicles in the 3 counties was estimated out to 2018 by taking the total number of subject vehicles for Chambers, Liberty, and Waller in the 2003 SIP revision (89,251) and growing that number out by the 3% fleet turnover rate used in MOBILE6. In the 2006 five county I/M program, the ASM failure rate was 9.5% and OBD 5.4% (TCEQ). Given the higher failure rate for OBD vehicles expected as these vehicles age out to 2015-2018, an overall program failure rate of 8.5% has been used. Given that the emissions inspection fee for the new program will include an element to cover the LIRAP costs, additional costs have not been added to account for uptake of LIRAP funds for repair and replacement of vehicles in the proposed new 3 county program area (the average LIRAP repair and replacement costs over the years 2015-2018 are estimated to be $447,732).


EMISSIONS AFFECTED On road weekday emissions from light duty gasoline vehicles in Chambers, Liberty and Waller counties: NOx, 3.32 tpd; VOC 2.66 tpd. EMISSIONS BENEFIT Modeled emission reductions in 2018 from implementing the program in the three counties: NOx, 1.26 tpd; VOC, 0.85 tpd. A tool was developed by TCEQ to approximate the HGB area emissions using a single MOBILE6 model run. This tool was used with a MOBILE6 model run using the I/M program in adjoining counties applied to these three counties. COST AND COST-EFFECTIVENESS Cost effectiveness is calculated as the average total cost of the program for the years 2015-2018 divided by the annual emissions reductions in 2018 (tons per day multiplied by 250). The average annual program cost including LIRAP costs was estimated to be $3,938,914.

VOC: $16,912 per ton NOx: $11,028 per ton VOC plus NOx: $6,813 per ton

SUMMARY OF RESULTS



Sources Affected



($/ton)

133

Expansion of the I/M program to Chambers, Liberty and Waller Counties

Remaining three HGB nonattainment area counties (Chambers Liberty and Waller) opt in to I/M

Light and Heavy duty gasoline vehicles

VOC - 2.66 NOx - 3.32

VOC32% NOx 38%

VOC 0.85; NOx 1.26

VOC $16,912 NOx $11,028; NOx+VOC $6,813

REFERENCES Texas Health and Safety Code (HSC) Texas Administrative Code (TAC)


Personal contact with Carl Nord, Environmental Systems Products (ESP) Personal contact with Danny Knauth, Texas Department of Public Safety. ENVIRON 2006. “Low Income Repair and Assistance Program Evaluation and

Improvement, Prepared for the Houston Advanced Research Center, H72AB, September 2006.

Texas State Implementation Plan Revision, Oct 8, 2003; Rule Log No: 2003-034-114-A1 Graciela Lubertino, H-GAC, personal communication.

G:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC Measure 149 IM cutpoints latest_051009.doc

Control Measure: #149, More Stringent I/M Cut Points Category: On-road Author: Hazel Barbour DESCRIPTION This strategy would impact Model Year 1995 and older gasoline vehicles subject to Acceleration Simulation Mode (ASM) testing in the Houston-Galveston-Brazoria (HGB) area vehicle inspection and maintenance (I/M) program. Vehicles older than 24 years old are not subject to any I/M testing and vehicles above 8,500 lbs GVWR and 4-wheel drive vehicles that cannot be tested on a dynamometer are subject to two-speed idle testing (which does not capture NOx emissions). The cutpoints currently in use that determine whether a vehicle passes or fails the ASM test are the original EPA phase-in cutpoints. The emissions reductions included in the HGB SIP are modeled using this data. EPA expected programs to eventually transition to more stringent final cutpoints, which are included in the MOBILE6 model. Using the final cut-points could result in failure rates similar to those found in enhanced I/M programs such as centralized IM 240 testing and could include a high percentage of false failures. EPA issued a memo in August 2002 releasing revised final cutpoints for ASM testing based on real world experience, which more strongly target only true failures. These alternative final cutpoints receive the same level of credit in MOBILE6 as the previous EPA final ASM cut-points. In addition, it might be useful to reexamine the exemption for vehicles 24 years and older to capture all vehicles that would benefit from maintenance. IMPLEMENTATION FEASIBILITY Modifications to the current ASM analyzer software will be required to incorporate the new cutpoints. Once the analyzer manufacturers have the new software available, this can be downloaded to all the ASM analyzers within 2/3 weeks. The current number of inspection stations offering ASM testing in the 5 counties is 966. (Note: if the HGB area wishes to adopt the more stringent cutpoints, it is likely that the DFW area will also do this.) ESP, which has sold 598 ASM analyzers into the HGB program (a number of the stations have more than one ASM test lane) has estimated a cost of $75,000 for the software update and download to their analyzers for both the HGB and DFW areas. In 2006 the average ASM failure rate was 9.5% of the subject vehicles. Implementing revised final cutpoints is likely to result in a higher failure rate among MY 1995 and older vehicles than currently experienced with vehicles tested at phase-in cutpoints, which will in turn mean a higher percentage of older vehicles failing and requiring repair. While it is difficult to find a reliable estimate of the expected increase in the percentage of vehicles failing the ASM test, as the number of MY 1995 and older vehicles drops annually, the absolute number of failing vehicles is likely to fall accordingly. In 2008, it is estimated that 15% of the fleet is MY 1995 and older. By 2011, it is estimated that 6% of the fleet will be MY 95 and older (ENVIRON, 2006). If the age range subject to I/M testing remains as 2-24 year old vehicles, then by 2018 there will be a very small number of these age range vehicles which are MY 1995 and older and eligible for ASM testing. For inspection stations offering both ASM and OBD testing, it may become increasingly uneconomic to continue to have to pay up to $4,000 per year for a maintenance contract for the emissions


analyzer and dynamometer. Thus, the availability of ASM testing for these older vehicles may become very limited (note: current TCEQ/DPS rules allow inspection stations to be granted a waiver from offering ASM testing to be able to offer OBD testing only, if the stations agree to conduct less than 1200 OBD tests per year: TAC Title 37, Part 1, Chapter 23, Subchapter G, 23.95). PUBLIC ACCEPTANCE General acceptance of the revised cutpoints should not be a problem as the majority of subject vehicles are MY 1996 and newer. However, as the percentage of MY 1995 and older vehicles drops, the burden of the potentially higher failure rate will fall more heavily on lower income vehicle owners. Repairing the oldest vehicles to pass the ASM test at the more stringent cutpoints may prove problematic. The increased funding now available under LIRAP should, however, mitigate these repair costs to some extent and may encourage more vehicles to be scrapped if they can’t be repaired - thus further reducing the number of MY 1995 and older vehicles in the fleet. It should also be noted that the owner of a vehicle at least 10 years old may be eligible for financial help to replace a vehicle even if that vehicle has not failed the emissions test. ANALYSIS The emission reductions were calculated using MOBILE6 to model moving the program in the five counties from phase-in to revised final cutpoints and modeling the program with the waiver rate of 3%. To estimate the impact on the number of vehicles failing more stringent ASM cutpoints and the resulting potential number of additional vehicles, which could be replaced through LIRAP, an additional 1 percent of MY 1995 and older vehicles were assumed to fail the test (it is difficult to find accurate estimates of the increased failure rate). As by 2018 the only vehicles subject to ASM testing will be 22-24 years old, the emission reduction benefits from the vehicles estimated to be replaced at an additional 1% failure rate (average 201 per year from 2015-2018) are estimated to very small, i.e. 2.8 pounds per year NOx and 1.1 pounds per year VOC. EMISSIONS AFFECTED Emissions affected are onroad light and heavy-duty gasoline vehicle emissions in Harris, Brazoria, Galveston, Fort Bend and Montgomery counties. EMISSIONS BENEFIT Estimated emission reductions in the 5 county HGB area are as follows based on the use of a modeling tool supplied by TCEQ to allow changes in MOBILE6 runs and calculate approximate area-wide emissions totals. The benefit of the I/M program change would result in 2018: NOx 0.13 tpd and VOC 0.12 tpd.


COST AND COST-EFFECTIVENESS Based on the emission reductions modeled for 2018 and the average annual costs covering repair and replacement for an additional 1% of vehicles failing the ASM test (current failure rate is 9.5%), the estimated total annual cost of this measure is $1,128,199.6 and the cost effectiveness per ton of NOx is $20,268; per ton of VOC, $25,232; and per ton of VOC and NOx combined, $11,281. Additional assumptions applied in calculating cost effectiveness: the number of MY 1995 and older vehicles drops by 16% per year (from HARC/Environ LIRAP report); cost of software modifications to all the ASM analyzers for HGB area only, approximately $75,000 (does not include any costs to upgrade the VID); average LIRAP repair cost of $517 used as the repair cost for all failing vehicles; and 18.9% of failing vehicles are replaced (percentage taken from 2007 HGAC LIRAP data). SUMMARY OF RESULTS


Measure # Name Description Affected

Sources Affected



($/ton)

149

More stringent I/M cutpoints

Changing to EPA’s revised final cutpoints for ASM test for MY 1995 and older vehicles.

On-road light and heavy duty gasoline vehicles in 5 counties

VOC - 37.2NOx - 26.9

VOC 0.32 NOx 0.48

VOC 0.12 NOx 0.13;

VOC $25,757 NOx $23,776 VOC and NOx $12,363

REFERENCES EPA memorandum, August 16, 2002 from Gregory Green, Director Certification and

Compliance Division, to EPA Regional Air Division Directors, entitled “Revised Final cutpoints for ASM 5015 and 2525”.

Dave Sosnowski, State Measures and Conformity Group, EPA Office of Transportation and Air

Quality.

ENVIRON 2006. “Low Income Repair and Assistance Program Evaluation and Improvement, Prepared for the Houston Advanced Research Center, H72AB, September 2006.

Chad Lenz, TCEQ I/M team, 2006 correspondence. Carl Nord, Environmental Systems Products (ESP). Danny Knauth, Texas Department of Public Safety. Graciela Lubertino, HGAC personal communication.

APPENDIX G

Detailed Evaluations for Non-Road Control Strategies

G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 5b Locomotive_051009.doc

Control Measure: #5, Voluntary Retrofit/Replacement Program - Locomotive (and other replacement retrofit funding, Measures 39 and 40)

Category: Nonroad Author: Chris Lindhjem, ENVIRON DESCRIPTION Voluntary retrofit and replacement programs have been used across the US to reduce emissions using a variety of co-funding incentive programs to offset the costs incurred. In Texas, the popular TERP program has been successful in providing co-funding for many emission reduction projects of many different types of emission sources, including, on-road trucks, construction and off-road equipment, marine vessels, and locomotives. To date, about $300 million of projects have been approved in the HGB area from 2002 through 2008 with most of the funding occurring in the 2004 through 2008 period. Because the most recent projects have just been approved, not all of the emission reductions have been realized and are still pending. In addition, there are other funding sources for control strategy projects including the EPA grant program run by a local collaborative (http://www.blueskyways.org/). The EPA funding program was relatively limited at $5,000,000 in 2008 (http://www.blueskyways.org/pdf/clean-diesel-FY08.pdf) for the states of Arkansas, Louisiana, New Mexico, Oklahoma, Texas, Iowa, Kansas, Missouri, Nebraska, and Minnesota. Nationally this program was funded at $49.2 million in 2008, of which, $27.6 million was available for National Clean Diesel Funding Assistance Program. Half of the National Clean Diesel Funding Assistance Program is dedicated to public fleets. Other monies were distributed to the States, research, and a revolving loan program. There may be additional funding sources available through State and Federal actions and other programs. This measure describes the issues and potential for locomotive replacement projects. IMPLEMENTATION FEASIBILITY The TERP program has worked well by co-funding fleet improvements for on-road and off-road vehicles and equipment. TCEQ has developed the organization and principles to administer the program formalizing the application process and providing assistance to owner/operators in implementing the emission reduction projects. The industrial owners of equipment have been enthusiastic participants of the program, and provide a large portion of the program funds.


PUBLIC ACCEPTANCE The current funding mechanism has been acceptable to nearly all parties, but the cost effectiveness goals may need to be reconsidered to continue to have the program fully subscribed. The continued funding with the current mechanism will require legislative and executive support. ANALYSIS One of the most effective emission reduction projects is the replacement of older locomotive engines with those meeting the lower emission standards. So the basis of this analysis is to compare emission rates from the older engines to the new locomotive standard in order to estimate an emission reduction potential. EPA announced final emission standards for locomotive engines (EPA, 2008) which included an analysis of the expected benefit of normal fleet turnover and the additional benefit of the EPA rule. The emission standards include a retrofit of existing equipment as well as new engine emission standards. Existing Tier 0, 1, and 2 engines will be subject to retrofit at the time of remanufacture; so the existing engines will be rebuilt gradually throughout their remaining useful life regardless of incentives. The emissions standards and projected EPA emission factors are shown in Tables 1a and 1b, depending on the duty cycle chosen to certify the engines: either line-haul or switching engine duty cycles. The duty cycle for line-haul engines typically leads to lower emissions on a gram per horsepower-hour (hp-hr) basis because the switching engine duty cycle has a considerable idling time (no hp-hr generated) and lower power modes where the engine operates inefficiently. In some cases the uncontrolled emissions are much lower than some of the emission standards, so no emission reduction would be expected from some of the standards especially for HC and CO emissions. Table 1a. Locomotive – Emission standards (g/hp-hr) for line-haul (duty cycle) engines.

Emission Standard Applicable

Year HC

(g/hp-hr) CO

(g/hp-hr) NOx

(g/hp-hr) PM

(g/hp-hr) Uncontrolled Emissions Pre-1973 0.48 1.28 13.0 0.32 Tier 0 – original 1973 – 2001 1.00 5.0 9.5 0.60 Tier 0 – final1 2008 / 2010 1.00 5.0 8.0 0.22 Tier 1 – original 2002 – 2004 0.55 2.2 7.4 0.45 Tier 1 – final1 2008 / 2010 0.55 5.0 7.4 0.22 Tier 2 – original 2005 0.30 1.5 5.5 0.20 Tier 2 – final1 2013 0.30 1.5 5.5 0.10 Tier 3 2012 – 2014 0.30 1.5 5.5 0.10 Tier 4 2 2015 0.14 1.5 1.3 0.03

1. These are retrofit standards at the time of rebuild and phased in as retrofit kit availability allows. 2. The Tier 4 NOx standard can be a 1.4 NOx + HC standard. The NOx standard may be delayed until 2017.


Table 1b. Locomotive – Emission standards for switching (duty cycle) engines.


Year HC

(g/hp-hr) CO

(g/hp-hr) NOx

(g/hp-hr) PM

(g/hp-hr) Uncontrolled Emissions Pre-1973 1.01 1.83 17.4 0.44 Tier 0 – original 1973 – 2001 2.10 8.0 14.00 0.72 Tier 0 – final1 2008 / 2010 2.10 8.0 11.80 0.26 Tier 1 – original 2002 – 2004 1.20 2.5 11.00 0.54 Tier 1 – final1 2008 / 2010 1.20 2.5 11.00 0.26 Tier 2 – original 2005 0.60 2.4 8.10 0.24 Tier 2 – final1 2008 / 2013 0.60 2.4 8.10 0.13 Tier 3 2011 - 2015 0.60 2.4 5.00 0.10 Tier 4 2 2015 0.14 2.4 1.30 0.03

1. These are retrofit standards at the time of rebuild and phased in as retrofit kit availability allows. 2. The Tier 4 NOx standard can be a 1.4 NOx + HC standard. The NOx standard may be delayed until 2017. EMISSIONS AFFECTED Table 2 shows the approximate summary emissions for non-road equipment emissions for 2018. The actual emissions may vary from day to day (such as weekday and weekend day) and depend upon whether the implementation of control strategies, such as TERP and TxLED, have or should be included in the estimates. Table 2 should be considered as reasonable estimates rather than exact figures. Table 2. Approximate 2018 baseline nonroad mobile source missions inventory.

Summer Weekday Emissions (tons)Aggregate Equipment Category

EquipmentPopulation NOX VOC CO

Agricultural Equipment 5,972 1.85 0.22 2.46Airport Ground Support Equipment 975 0.39 0.05 0.53

Commercial Equipment 256,241 6.50 10.95 425.19Construction and Mining Equipment 97,192 19.07 4.34 64.34

Industrial Equipment 39,145 5.87 0.89 21.99Lawn and Garden Equipment 1,664,135 2.12 17.98 300.42

Logging Equipment 2,154 0.05 0.13 1.75Pleasure Craft 129,479 1.47 14.91 31.95

Railroad Equipment 126 0.05 0.01 0.04Recreational Equipment 79,794 0.27 4.55 40.26

Underground Mining Equipment 0 0.00 0.00 0.008-County HGB Total General Nonroad 2,275,213 37.64 54.02 888.92

8-County HGB Total Spark-Ignition Nonroad 2,150,612 9.35 50.79 874.808-County HGB Total Diesel Nonroad 124,601 26.591 3.23 14.12Locomotive – Line Haul N/A 15.77 0.84 2.49Locomotive – Switching N/A 22.43 1.51 3.38Harbor craft N/A 13.40 0.29 3.32OGV – transit N/A 18.36 0.54 1.88OGV – dwell N/A 13.69 0.35 2.42Aircraft N/A 8.85 2.55 29.72All nonroad mobile sources 128.43 60.1 932.131 – 6% lower diesel nonroad NOx emissions than TCEQ provided to approximate the TxLED emission reduction not included in the submittal.


EMISSIONS BENEFIT Table 3 indicates most recent information on the benefit and cost per project from the TERP program in the HGB area. The most typical project was to replace current equipment that would not necessarily be replaced otherwise. However, regardless of the inflation rate, the new engine costs are expected to increase because of the new emissions standards, so the current TERP figures may underestimate the cost of future projects. Also, some TERP projects combine two or more categories of project types. The figures here can vary depending upon the size of the engine and other considerations. The figures in Table 3 are approximate and may change as the projects are implemented and reviewed. Table 3. TERP implemented and pending projects in HGB.


Cost per Project

Total NOx Reduced

(tpd)


(tpy) Locomotive $75,996,969 116 $655,146 7.29 22.95Marine $39,216,837 400 $98,042 5.99 5.46Non-road $81,284,069 1,995 $40,744 7.86 1.44On-road $103,974,922 1,867 $55,691 10.63 2.08 The projects for locomotives have focused on switching engine replacement projects because the railroads may not be able to guarantee that the line-haul locomotives would be used a majority of the time within the area. Because the focus has been on switching engines and the program has been successful replacing more than 100 switching engines, it is difficult to know how many more switching engines can be replaced. The predominant locomotive project is the replacement of switching engines with a specially designed locomotive that already meets the Tier 3 NOx emissions levels or below. The next significant change in NOx emissions for new locomotives based on the Tier 4 emission standards is not slated to occur until 2017, and that standard is subject to a technology review, so Tier 4 engines may not be widely available until the 2018 timeframe for the state implementation plan. Given the review of locomotive emission in HGB (ERG, 2006, http://files.harc.edu/Projects/AirQuality/Projects/H018.2003/H18FinalReport.pdf), approximately 206 switch locomotives were said to exist in HGB. Forecasting to 2018, then about 250 switching engines would be operating in HGB in 2018. To the extent that Tier 3 compliant switching engines are available, then about half of the switching engines could be replaced with lower emitting engines. The benefit in emissions (shown in Table 1b) between replacing a Tier 0-final engine (with 1.2 and 11.8 g/hp-hr VOC and NOx emission rates) is half that of replacing a pre-controlled switching engine (at 1.0 and 17.0 g/hp-hr VOC and NOx) with a Tier 3 engine that would have 0.6 and 5.0 g/hp-hr emission rates. It is most likely that the pre-controlled engines were the


ones that were replaced in the TERP program, but by 2018 most locomotives will need to have been rebuilt to Tier 0 emission standards. One issue is how many more switching engines can be replaced with low emissions switch engines because the lower emitting switching engines available at the time of this writing at the end of 2008 have limited maximum power. Often switching engines are used for some line-haul duty and so must have sufficient power for that duty as well. Therefore, arbitrarily half of the remaining maximum penetration rate (roughly 58 locomotives) was chosen as a lower limit of what could be achieved. COST AND COST-EFFECTIVENESS Table 3 indicated the cost and cost effectiveness of the TERP projects to date and inform the forecast for future projects. The TERP locomotive cost effectiveness of projects to date has been less than $5,000 per ton of NOx reduced. Using the TERP cost and emission reduction per project and an average project life of 10 years, the average cost effectiveness would be estimated at about $3,500 per ton of NOx reduced. However, if the remaining switching locomotives meet the Tier 0 standards under the expected rebuild schedule, then the benefit for the replacement program would be half of that for the TERP program to date resulting in a lower cost effectiveness of about $7,000 per ton reduced. If Tier 4 compliant engines become available, then the cost effectiveness for the additional NOx and PM reduction equipment (from Tier 3 to Tier 4 EPA, 2008) is estimated to be about $50,000 to $80,000 more per engine for original engine manufacturers. Using the lower figure the cost effectiveness for the added equipment would be $13,000 per ton of VOC and $2,000 per ton of NOx for Tier 4 compared with the Tier 3 standard. Because about half of the switching engines have been replaced and the remaining ones would probably already meet the Tier 0 standards resulting in half the individual benefit, the potential emission reductions would be about half as large as has already been realized in the TERP program. Because not all switching engines might be available for replacement, a lower emission reduction potential was chosen. SUMMARY OF RESULTS



Affected Emissions

(tpd) % Tpd

Est. Cost Effective-ness

($/ton) 3 Switch

Locomotive Replacement

Engine Off-road 1.5 VOC

22.4 NOx 10 - 15%

2 - 3.5

$3,500 - $7,000


REFERENCES EPA. 2008. “Regulatory Impact Analysis: Control of Emissions of Air Pollution from Locomotive Engines and Marine Compression-Ignition Engines Less than 30 Liters per Cylinder,” EPA420-R-08-001, March 2008.

G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 5b Marine_051009.doc

Control Measure: #5, Voluntary Retrofit/Replacement Program – Marine (and other replacement retrofit funding, Measures 39 and 40)

Category: Nonroad Author: Chris Lindhjem, ENVIRON DESCRIPTION Voluntary retrofit and replacement programs have been used across the US to reduce emissions using a variety of programs providing cofunding incentive to offset the costs incurred. In Texas, the popular TERP program has been successful providing cofunding for many emission reduction projects of many different types including on-road trucks, construction and off-road equipment, marine vessels, and locomotives. To date, about $300 million of projects have been approved in the HGB area from 2002 through 2008 with the most of the funding occurring in the 2004 through 2008 period. Because the most recent projects have just been approved, not all of the emission reductions have been realized and are still pending In addition, there are other funding sources for control strategy projects including the EPA grant program run by a local collaborative (http://www.blueskyways.org/). The EPA funding program was relatively limited at $5,000,000 in 2008 (http://www.blueskyways.org/pdf/clean-diesel-FY08.pdf) for the states of Arkansas, Louisiana, New Mexico, Oklahoma, Texas, Iowa, Kansas, Missouri, Nebraska, and Minnesota. Nationally this program was funded at $49.2 million in 2008 of which $27.6 million was available for National Clean Diesel Funding Assistance Program. Half of the National Clean Diesel Funding Assistance Program is dedicated to public fleets. Other monies were distributed to the States, research, and a revolving loan program. There may be additional funding sources available through State and Federal actions and other programs. This measure describes the issues and potential for marine engine replacement projects. IMPLEMENTATION FEASIBILITY The TERP program has worked well by co-funding fleet improvements for on-road and off-road vehicles and equipment. TCEQ has developed the organization and principles to administer the program formalizing the application process and providing assistance to owner/operators in implementing the emission reduction projects. The industrial owners of equipment have been enthusiastic participants of the program, and provide a large portion of the program funds.


PUBLIC ACCEPTANCE The current funding mechanism has been acceptable to nearly all parties, but the cost effectiveness goals may need to be reconsidered to continue to have the program fully subscribed. The continued funding with the current mechanism will require legislative and executive support. ANALYSIS One of the most important methods for emission reduction projects is to replace older vehicles and equipment with those meeting the lower emission standards. The retrofit projects often use technologies employed on new engines to meet the lower emission standards. So the basis of this analysis is to compare emission rates from the older with the new vehicles and equipment in order to estimate an emission reduction potential. The TERP program focuses on diesel emissions from on-road and off-road vehicles and equipment. EPA recently announced proposed emission standards for marine engines (EPA, 2008) that include an analysis of the expected benefit of normal fleet turnover of the final rule. The emissions rates for baseline engines prior emission control, and current and proposed emission standards shown in Table 1a and 1b for two representative tug propulsion engines. The actual standards and emission factors are more complicated because they depend upon the engine size and whether it is used for propulsion or auxiliary power. Table 1a. Emission standards (g/kW-hr) for Category 1 diesel marine engines (Sample engine: Caterpillar 3500 series, 4 liter/cylinder, <35 kW/l, 600 to 1000 kW).


Year HC

(g/kW-hr) CO

(g/kW-hr) NOx

(g/kW-hr) PM

(g/kW-hr) Baseline1 (uncontrolled) <2000 0.27 1.5 10 0.30 Tier 1 2000 None None 10.5 None Tier 2 2007 5.0 7.2 0.20 Tier 3 2012

Included in NOx std. 5.0 5.8 0.11

Tier 4 2017 0.19 5.0 1.8

(HC+NOx) 0.04 1 Baseline are the precontrolled average emission rates determined by EPA, not official emission standards. Table 1b. Emission standards for Category 2 diesel marine engines (Sample engine: EMD-645, 10 liter/cylinder, <2000 kW).


Year HC

(g/kW-hr) CO

(g/kW-hr) NOx

(g/kW-hr) PM

(g/kW-hr) Baseline1 (uncontrolled) <2000 0.50 1.1 13.2 0.72 Tier 1 2000 None None 11.4 None Tier 2 2007 5.0 7.8 0.27 Tier 3 2013

Included in NOx std. 5.0 6.2 0.14

Tier 4 2016 0.19 5.0 1.8

(HC+NOx) 0.04 1 Baseline are the precontrolled average emission rates determined by EPA, not official emission standards.


EMISSIONS AFFECTED Table 2a shows the approximate summary emissions for nonroad equipment emissions for 2018 and Table 2b shows a more detailed summary of the harbor craft emissions. The actual emissions may vary from day to day (such as weekday and weekend day) and depend upon whether the implementation of control strategies, such as TERP and TxLED, have or should be included in the estimates. Tables 2a and 2b should be considered as reasonable estimates rather than exact figures. Table 2a. Approximate 2018 baseline nonroad mobile source missions inventory.









8-County HGB Total Spark-Ignition Nonroad 2,150,612 9.35 50.79 874.808-County HGB Total Diesel Nonroad 124,601 26.591 3.23 14.12Locomotive – Line Haul N/A 15.77 0.84 2.49Locomotive – Switching N/A 22.43 1.51 3.38Harbor craft N/A 13.40 0.29 3.32OGV – transit N/A 18.36 0.54 1.88OGV – dwell N/A 13.69 0.35 2.42Aircraft N/A 8.85 2.55 29.72All nonroad mobile sources 128.43 60.1 932.131 – 6% lower diesel nonroad NOx emissions than TCEQ provided to approximate the TxLED emission reduction not included in the submittal. Table 2b. Approximate 2018 baseline detailed harbor craft emissions inventory (tons per day). Vessel Type NOx VOC CO Assist Tugboats 2.24 0.03 0.6Ferries 1.17 0.03 0.3Towboats 8.66 0.19 2.1Dredges 0.43 0.01 0.1Dredges 0.93 0.03 0.2Total 13.40 0.29 3.3


EMISSIONS BENEFIT Table 3 indicates most recent information on the benefit and cost per project from the TERP program in the HGB area. The most typical project was to replace current equipment that would not necessarily be replaced otherwise. However regardless of the inflation rate, the new engine costs are expected to increase because of the new emissions standards, so the current TERP figures may underestimate the cost of future projects. Also, some TERP projects combine two or more categories of project types, and the figures here can vary depending upon the size of the engine and other considerations. The figures in Table 3 are approximate and may change as the projects are implemented and reviewed. Table 3. TERP implemented and pending projects in HGB.


Cost per Project

Total NOx Reduced

(tpd)


(tpy) Locomotive $75,996,969 116 $655,146 7.29 22.95Marine $39,216,837 400 $98,042 5.99 5.46Non-road $81,284,069 1,995 $40,744 7.86 1.44On-road $103,974,922 1,867 $55,691 10.63 2.08 The TERP project for marine vessels have focused on harbor craft, which include tugs, excursion, and supply vessels because these vessel are more likely to spend most of their time within the area. Nearly all of the projects involve repowering propulsion and/or auxiliary engines with those meeting lower emission standards. The Tier 3 engines are at the time of this writing just coming into production for Category 1 (lower engine displacement per cylinder) affording additional NOx reductions below the current program benefits. The implementation schedule for Tier 3 Category 2 and Tier 4 Category 1 and 2 engines would make it difficult to use these lower emission engines ahead of the 2018 time frame. Some tugs, the primary target of the TERP funding to date, use Category 1 and others use Category 2 engines for the primary propulsion power. So the benefits of the projects may be hampered by the availability of lower emission Category 2 engine designs. The marine TERP projects dramatically increased starting in 2005. The individual project (a replacement engine) resulted in about 5.5 tpy of NOx reduction. The next step in emission standard is the production of Tier 3 engines in 2013 to 2014 timeframe with the very low emission Tier 4 standards not occurring until 2016 – 2017. It is difficult to determine the remaining marine projects available for retrofit or replacement, but an estimate can be made using the EPA (2008) estimates of age distribution. Based on the median life for Category 1 of 17 years and 23 years for Category 2, the remaining engines of model year 2006 or earlier (Tier 1 or older) were estimated to be 36% of the Category 1 and 51% of the Category 2 engines. Based on approximate emission rates of Tier 1 compared to Tier 2 and later engines, the fraction of


NOx emissions from Tier 1 and older models would be about 60% of future 2018 emissions, and an engine replacement program therefore (using the 13.4 ton per day NOx from harbor craft) could address at most about 8 tpd of the harbor craft emissions. To the extent that the TERP program has already replaced upwards to 400 engines to date, it may not be clear how many more projects could be affected. Comparing the Tier 3 with the Tier 1 emission rates provides a potential 45% reduction is possible or 4 tons per day of NOx as an upper limit. Arbitrarily half of this maximum penetration rate was chosen as a lower limit of what could be achieved. COST AND COST-EFFECTIVENESS Table 3 indicated the cost and cost effectiveness of the TERP projects to date and inform the forecast for future projects. The TERP marine project cost effectiveness to date ranges from $1,000 to $9,000 per ton of NOx reduced. The average cost effectiveness of about $2,500 for TERP projects was calculated from the TERP summary table cost of $100,000 and 5.46 tpy NOx benefit per engine replacement and an average project life of 8 years. SUMMARY OF RESULTS


Measure # Name Description

Affected Sources

Affected Emissions

(tpd) % Tpd

Est. Cost Effective

-ness ($/ton)

3 Marine vessels

Replacement Engine

Off-road 0.3 VOC 13.4 NOx

15 - 30% 2 – 4 $2,500

REFERENCES EPA. 2008. “Regulatory Impact Analysis: Control of Emissions of Air Pollution from

Locomotive Engines and Marine Compression-Ignition Engines Less than 30 Liters per Cylinder,” EPA420-R-08-001, March 2008.

G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 5b Offroad_051009.doc

Control Measure: #5, Voluntary Retrofit/Replacement Program – Nonroad (and other replacement/retrofit funding, Measures 39 and 40)

Category: Nonroad or onroad (see on-road measure #3) Author: Chris Lindhjem, ENVIRON DESCRIPTION Voluntary retrofit and replacement programs have been used across the US to reduce emissions using a variety of programs providing cofunding incentive to offset the costs incurred. In Texas, the popular TERP program has been successful providing cofunding for many emission reduction projects of many different types including on-road trucks, construction and off-road equipment, marine vessels, and locomotives. To date, about $300 million of projects have been approved in the HGB area from 2002 through 2008 with the most of the funding occurring in the 2004 through 2008 period. Because the most recent projects have just been approved, not all of the emission reductions have been realized and are still pending In addition, there are other funding sources for control strategy projects including the EPA grant program run by a local collaborative (http://www.blueskyways.org/). The EPA funding program was relatively limited at $5,000,000 in 2008 (http://www.blueskyways.org/pdf/clean-diesel-FY08.pdf) for the states of Arkansas, Louisiana, New Mexico, Oklahoma, Texas, Iowa, Kansas, Missouri, Nebraska, and Minnesota. Nationally this program was funded at $49.2 million in 2008 of which $27.6 million was available for National Clean Diesel Funding Assistance Program. Half of the National Clean Diesel Funding Assistance Program is dedicated to public fleets. Other monies were distributed to the States, research, and a revolving loan program. There may be additional funding sources available through State and Federal actions and other programs. This measure describes the issues and potential for construction and offroad engine replacement projects. IMPLEMENTATION FEASIBILITY The TERP program has worked well by co-funding fleet improvements for on-road and off-road vehicles and equipment. TCEQ has developed the organization and principles to administer the program formalizing the application process and providing assistance to owner/operators in implementing the emission reduction projects. The industrial owners of equipment have been enthusiastic participants of the program, and provide a large portion of the program funds.


PUBLIC ACCEPTANCE The current funding mechanism has been acceptable to nearly all parties, but the cost effectiveness goals may need to be reconsidered to continue to have the program fully subscribed. The continued funding with the current mechanism will require legislative and executive support. ANALYSIS One of the most important methods for emission reduction projects is to replace older vehicles and equipment with those meeting the lower emission standards. The retrofit projects often use technologies employed on new engines to meet the lower emission standards. So the basis of this analysis is to compare emission rates from the older with the new vehicles and equipment in order to estimate an emission reduction potential. The TERP program focuses on diesel emissions from on-road and off-road vehicles and equipment. The EPA has been setting emission standards for diesel (compression-ignition) engine for some time with the first set of standards shown in Table 1a. In 2004, EPA (2004) set new emission standards for Tier 4 non-road engines to be phased in primarily from 2011 through 20151 as shown in Table 1b. Emission standards for NOx and PM will dramatically reduce emissions in future years as the fleet turns over to new equipment models. The reduction in particulate and NOx emissions will be more dramatic when the ‘Final’ standards shown in Table 1b occur effectively mandating particulate filters and aftertreatment for NOx that could either be selective catalytic reduction or other NOx reducing catalyst. Table 1a. Tier 1, 2, and 3 Emission standards for new diesel engines g/kW-hr (g/hp-hr).

Engine Power Tier Model Year

NMHC+ NOX CO PM

Tier 1 2000 10.5 (7.8) 8.0 (6.0) 1.0 (0.75) Tier 2 2005 7.5 (5.6) 8.0 (6.0) 0.80 (0.60) kW<8

(hp<11) Tier 3 2008 --- --- 0.40 (0.30) Tier 1 2000 9.5 (7.1) 6.6 (4.9) 0.80 (0.60) Tier 2 2005 7.5 (5.6) 6.6 (4.9) 0.80 (0.60) 8≤kW<19

(11≤hp<25) Tier 3 2008 --- --- 0.40 (0.30) Tier 1 1999 9.5 (7.1) 5.5 (4.1) 0.80 (0.60)

19≤kW<37 (25≤hp<50)

Tier 2 2004 7.5 (5.6) 5.5 (4.1) 0.60 (0.45)

Tier 1 1998 9.25 (6.9) NOX 1.3 (1.0) HC None

None (smoke)

Tier 2 2004 7.5 (5.6) 5.0 (3.7) 37≤kW<75

(50≤hp<100) Tier 3 2008 4.7 (3.5) 5.0 (3.7) 0.40 (0.30)

1 EPA Tier 4 Emission Standards for Non-road Diesel Engines: http://www.epa.gov/nonroad-diesel/2004fr.htm


Engine Power Tier Model Year

NMHC+ NOX CO PM

Tier 1 1997 9.25 (6.9) NOX 1.3 (1.0) HC None

None (smoke)

Tier 2 2003 6.6 (4.9) 5.0 (3.7) 75≤kW<130

(100≤hp<175) Tier 3 2007 4.0 (3.0) 5.0 (3.7) 0.30 (0.22)

Tier 1 1996 9.25 (6.9) NOX 1.3 (1.0) HC 8.5 0.54 (0.4)

Tier 2 2003 6.6 (4.9) 3.5 (2.6) 130≤kW<225 (175≤hp<300)

Tier 3 2006 4.0 (3.0)

3.5 (2.6) 0.20 (0.15)

Tier 1 1996 9.25 (6.9) NOX 1.3 (1.0) HC 8.5 0.54 (0.4)

Tier 2 2001 6.4 (4.8) 3.5 (2.6) 225≤kW<450 (300≤hp<600)

Tier 3 2006 4.0 (3.0) 3.5 (2.6) 0.20 (0.15)

Tier 1 1996 9.25 (6.9) NOX 1.3 (1.0) HC 8.5 0.54 (0.4)

Tier 2 2002 6.4 (4.8) 3.5 (2.6) 450≤kW≤560 (600≤hp≤750)

Tier 3 2006 4.0 (3.0) 3.5 (2.6) 0.20 (0.15)

Tier 1 2000 9.25 (6.9) NOX 1.3 (1.0) HC 8.5 0.54 (0.4) KW>560

(hp>750) Tier 2 2006 6.4 (4.8) 3.5 (2.6) 0.20 (0.15)

Table 1b. Federal Tier 4 new engine emission standards for diesel offroad engines.

1 Manufacturers have the option of complying with the Tier 4 standards over a two year period at 50% per year using banked Tier 2 credits or over a three year period at 25% per year without the use of Tier 2 credits. The three year phase-in period is shown. The 2014 model year cannot extend beyond December 30, 2014, when the 3 year phase-in option is used. 2 Manufacturers may comply with the standards during the transitional implementation years using either a phase-in / phase-out approach or by using the Alternate NOx approach. The three year 25% alternate NOx standard is shown in the table. The two year 50% phase-in NOx standard would be 2.3 g/kW-hr. 3 Engine families in this power category may alternately meet Tier 3 PM standards from 2008-2011 in exchange for introducing final PM standards in 2012.

Engine HP Tier 4 Standard

Model Year

PM (g/kW-hr)

NMHC+NOx(g/kW-hr)

NMHC (g/kw-hr)

NOx (g/kw-hr)

CO (g/kw-hr)

Interim 2008 0.30 7.5 25-503

Final 2013 0.03 4.7 5.5

Interim 2008 0.30 50-75 Final 2013 0.03 4.7 5.0

Phase-in 0.19 0.40 Phase-out 4.7 Or/ alt NOx

2012-20141

3.42 75-100

Final 2015

0.02 0.19 0.40

5.0


2012-20141

3.42 100-175

Final 2015

0.02 0.19 0.40

5.0


2011 2.0 175-750

Final 2014

0.02 0.19 0.40

3.5

Interim 2011 0.1 0.40 >750 Final 2015 0.04 0.19 3.5 3.5


EMISSIONS AFFECTED Table 2 shows the approximate summary emissions for nonroad equipment emissions for 2018. The actual emissions may vary from day to day (such as weekday and weekend day) and depend upon whether the implementation of control strategies, such as TERP and TxLED, have or should be included in the estimates. Table 2 should be considered as reasonable estimates rather than exact figures. Table 2. Approximate 2018 baseline nonroad mobile source missions inventory.









8-County HGB Total Spark-Ignition Nonroad 2,150,612 9.35 50.79 874.808-County HGB Total Diesel Nonroad 124,601 26.591 3.23 14.12Locomotive – Line Haul N/A 15.77 0.84 2.49Locomotive – Switching N/A 22.43 1.51 3.38Harbor craft N/A 13.40 0.29 3.32OGV – transit N/A 18.36 0.54 1.88OGV – dwell N/A 13.69 0.35 2.42Aircraft N/A 8.85 2.55 29.72All nonroad mobile sources 128.43 60.1 932.131 – 6% lower diesel nonroad NOx emissions than TCEQ provided to approximate the TxLED emission reduction not included in the submittal. EMISSIONS BENEFIT On-road benefits have been described in on-road control strategy measure number 3 that include TERP and congestion mitigation and air quality or other funding programs for on-road vehicles. Therefore this control strategy description focuses on the off-road measures. Table 3 indicates most recent information on the benefit and cost per project from the TERP program in the HGB area. The most typical project was to replace current equipment that would not necessarily be replaced otherwise. However regardless of the


inflation rate, the new engine costs are expected to increase because of the new emissions standards, so the current TERP figures may underestimate the cost of future projects. Also, some TERP projects combine two or more categories of project types, and the figures here can vary depending upon the size of the engine and other considerations. The figures in Table 3 are approximate and may change as the projects are implemented and reviewed. Table 3. TERP implemented and pending projects in HGB.


Cost per Project

Total NOx Reduced

(tpd)


(tpy) Locomotive $75,996,969 116 $655,146 7.29 22.95Marine $39,216,837 400 $98,042 5.99 5.46Non-road $81,284,069 1,995 $40,744 7.86 1.44On-road $103,974,922 1,867 $55,691 10.63 2.08 The TERP program has gained more emission reductions from construction and other smaller nonroad engine projects than marine or locomotive source categories. The projects include primarily construction equipment of various types, forklifts, and other types. The average project benefit has been about 1.5 tpy of NOx reduction per project mostly representing Tier 2 and 3 engine replacements of in-use equipment. The next set of emission standards for Tier 4 engines are to be fully implemented by 2015. Until then the current TERP program projects using Tier 3 engines, which likely represents the predominant project types for the foreseeable future until the Tier 4 engines are produced. As with other off-road measures, it is difficult to determine how many more projects can occur and how much emission reduction can be attained. By 2018, the precontrolled (typically 1995 and earlier model year) and Tier 0 (1996 to the Tier 1 implementation date) engines will largely have been retired from operation, leaving the replacement of Tier 1 engines as the primary target of a replacement program. This can reduce the per project benefit by to as little as one-third the benefit of replacing a precontrolled engine. COST AND COST-EFFECTIVENESS Table 3 indicated the cost and cost effectiveness of the TERP projects to date and inform the forecast for future projects. The TERP projects had a project life of 5 or 7 years with the $41,000 per project price and 1.44 tpy NOx reduction resulted in a cost effectiveness of about $5,000 per ton per project on average. However, if the benefits of each project were reduced to one third (replacing Tier 1 with Tier 3 instead of precontrolled with Tier 3 engines), then the cost effectiveness could be 3 times higher.


SUMMARY OF RESULTS


Measure # Name Description

Affected Sources

Affected Emissions

(tpd) % Tpd

Est. Cost Effective

-ness ($/ton)

3 Nonroad Equipment

Replacement or Retrofit Engine

Off-road 3.2 VOC 26.6 NOx

10% 2.5 $5,000 – $15,000

REFERENCES EPA. 2008. “Regulatory Impact Analysis: Control of Emissions of Air Pollution from

Locomotive Engines and Marine Compression-Ignition Engines Less than 30 Liters per Cylinder,” EPA420-R-08-001, March 2008.

EPA. 2004. “Clean Air Nonroad Diesel - Tier 4 Final Rule,” United States

Environmental Protection Agency, http://www.epa.gov/nonroad-diesel/2004fr.htm.

G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 8 Construction incentives_051009.doc

Control Measure: #8, Construction Contracting Incentives Category: Nonroad Author: Chris Lindhjem, ENVIRON DESCRIPTION An incentive program or a requirement for publicly-funded (including just captive state, county, and municipal fleets of off-road equipment) or all construction projects could effect emission reductions by encouraging fleet turnover to those meeting lower emission standards. A TxDOT plan provides an example of an incentive program. Alternatively, many other states and localities have suggested or implemented emission standard (by model year) requirements for construction contracts. (EPA, 2008, http://www.epa.gov/diesel/construction/contract-lang.htm) While some areas target NOx control and others PM control, the incentives or requirements for new equipment based would control both pollutants. IMPLEMENTATION FEASIBILITY Based on a review of the contracting clauses to date, there are two basic methods, a voluntary or incentive approach and a fixed requirement for clean equipment. The incentive approach raises the cost to the State or local government contracts by offering an incentive, and the requirement raises the cost on the construction firm to maintain a clean fleet that would likely be passed on to the cost of the project. PUBLIC ACCEPTANCE The general public is unlikely to be affected by this strategy. The cost of incentives would need to be considered carefully because the contracting costs could increase and greater than expected by restricting how many contractors could qualify. ANALYSIS TxDOT (2004) issued a contracting incentive to encourage the use of advanced emission controlled engines in equipment used for road construction projects. The incentive was described as shown in Table 1 with Table 2a describing the model year of equipment for each Tier. The incentive provided by TxDOT could be realized without a special purchase of new equipment or engines.


Table 1. TxDOT clean engine incentive and calculated benefit. Engine Tier

Monthly Incentive ($/hp)

Tier 1 0.50 Tier 2 0.75 Tier 3 1.0

Table 2a. Emission standards for new compression-ignition engines in g/kW-hr (g/hp-hr).

Engine Power Tier

Model Year

NMHC+ NOX CO PM

Tier 1 2000 10.5 (7.8) 8.0 (6.0) 1.0 (0.75) Tier 2 2005 7.5 (5.6) 8.0 (6.0) 0.80 (0.60)

KW<8 (hp<11)

Tier 3 2008 --- --- 0.40 (0.30) Tier 1 2000 9.5 (7.1) 6.6 (4.9) 0.80 (0.60) Tier 2 2005 7.5 (5.6) 6.6 (4.9) 0.80 (0.60)

8≤kW<19 (11≤hp<25)

Tier 3 2008 --- --- 0.40 (0.30) Tier 1 1999 9.5 (7.1) 5.5 (4.1) 0.80 (0.60) Tier 2 2004 7.5 (5.6) 5.5 (4.1) 0.60 (0.45)

19≤kW<37 (25≤hp<50)

Tier 3 2013 4.7 (3.5) --- 0.03 (0.02)

Tier 1 1998 9.25 (6.9) NOX1.3 (1.0) HC None None

(smoke) Tier 2 2004 7.5 (5.6) 5.0 (3.7)

37≤kW<75 (50≤hp<100)

Tier 3 2008 4.7 (3.5) 5.0 (3.7) 0.40 (0.30)

Tier 1 1997 9.25 (6.9) NOX1.3 (1.0) HC None none

(smoke) Tier 2 2003 6.6 (4.9) 5.0 (3.7)

75≤kW<130 (100≤hp<175)

Tier 3 2007 4.0 (3.0) 5.0 (3.7) 0.30 (0.22)

Tier 1 1996 9.25 (6.9) NOX1.3 (1.0) HC 8.5 0.54 (0.4)

Tier 2 2003 6.6 (4.9) 3.5 (2.6) 130≤kW<225 (175≤hp<300)

Tier 3 2006 4.0 (3.0) 3.5 (2.6) 0.20 (0.15)

Tier 1 1996 9.25 (6.9) NOX1.3 (1.0) HC 8.5 0.54 (0.4)

Tier 2 2001 6.4 (4.8) 3.5 (2.6) 225≤kW<450 (300≤hp<600)

Tier 3 2006 4.0 (3.0) 3.5 (2.6) 0.20 (0.15)

Tier 1 1996 9.25 (6.9) NOX1.3 (1.0) HC 8.5 0.54 (0.4)

Tier 2 2002 6.4 (4.8) 3.5 (2.6) 450≤kW≤560 (600≤hp≤750)

Tier 3 2006 4.0 (3.0) 3.5 (2.6) 0.20 (0.15)

Tier 1 2000 9.25 (6.9) NOX1.3 (1.0) HC 8.5 0.54 (0.4) kW>560

(hp>750) Tier 2 2006 6.4 (4.8) 3.5 (2.6) 0.20 (0.15)

The TxDOT measure becomes dated as the fleet turnover and the Tier 4 emission standards begin to take effect as shown in Table 2b. The incentive might not affect any emission reduction compared to normal turnover of equipment as it is replaced. The incentive of Tier 4 engines is required to demonstrate significant emission reduction compared to the average fleet age distribution in 2018. By 2018, half of the equipment in use could meet Tier 4 final standards under normal turnover.


Table 2b. Federal and State Tier 4 new engine emission standards for diesel offroad engines.

1 Manufacturers have the option of complying with the Tier 4 standards over a two year period at 50% per year using banked Tier 2 credits or over a three year period at 25% per year without the use of Tier 2 credits. The three year phase-in period is shown. The 2014 model year cannot extend beyond December 30, 2014, when the 3 year phase-in option is used. 2 Manufacturers may comply with the standards during the transitional implementation years using either a phase-in / phase-out approach or by using the Alternate NOx approach. The three year 25% alternate NOx standard is shown in the table. The two year 50% phase-in NOx standard would be 2.3 g/kW-hr. 3 Engine families in this power category may alternately meet Tier 3 PM standards from 2008-2011 in exchange for introducing final PM standards in 2012. The Northeast Clean Diesel Collaborative (NEDC) (EPA, 2008) suggested an alternative approach where in the most straightforward approach mandates that Tier 4 equipment be used. Replacing older equipment with Tier 4 equipment would reduce emissions significantly even though the older equipment may represent the minority of the equipment. EMISSIONS AFFECTED TCEQ estimated construction equipment emissions by construction category based on local survey data collected as shown in Table 3. This permits the investigation of what fraction of the construction activity that public funding can affect.

Engine HP Tier 4 Standard

Model Year

PM (g/kW-hr)

NMHC+NOx(g/kW-hr)

NMHC (g/kw-

hr)

NOx (g/kw-

hr)

CO (g/kw-

hr) Interim 2008 0.30 7.5 25-503

Final 2013 0.03 4.7 5.5

Interim 2008 0.30 50-75 Final 2013 0.03 4.7 5.0


2012-20141

3.42 75-100

Final 2015

0.02 0.19 0.40

5.0


2012-20141

3.42 100-175

Final 2015

0.02 0.19 0.40

5.0


2011 2.0 175-750

Final 2014

0.02 0.19 0.40

3.5

Interim 2011 0.1 0.40 >750 Final 2015 0.04 0.19 3.5 3.5


Table 3. Construction equipment emission estimates before TxLED NOx reduction of about 6% applied for 2018.

Non-Road Equipment Subsector Summer Weekday Emissions (tons)Diesel Construction Equipment (DCE)

& Non-DCE EquipmentPopulation VOC CO NOX

DCE - Agricultural Activities 817 0.01 0.05 0.14DCE - Boring & Drilling Equipment 20,431 0.22 1.02 2.42DCE - Brick & Stone Operations 91 0.01 0.03 0.05DCE - City & County Road Construction 311 0.01 0.04 0.10DCE - Commercial Construction 5,625 0.26 1.05 2.32DCE - Concrete Operations 1,318 0.04 0.23 0.35DCE - County-Owned Construction Equipment 2,301 0.13 0.49 1.18DCE - Cranes 101 0.00 0.02 0.03DCE - Heavy Highway Construction 191 0.00 0.02 0.04DCE - Landfill Operations 3,162 0.05 0.24 0.61DCE - Landscaping Activities 79 0.01 0.02 0.05DCE - Manufacturing Operations 5,381 0.14 0.63 1.20DCE - Municipal-Owned Construction Equipment 149 0.03 0.04 0.11DCE - Transportation/Sales/Services 1,375 0.05 0.26 0.33DCE - Residential Construction 2,320 0.16 0.64 1.15DCE - Rough Terrain Forklifts 744 0.04 0.17 0.29DCE - Scrap/Recycling Operations 6,387 0.16 0.87 2.20DCE - Skid Steer Loaders 346 0.01 0.05 0.17DCE - Special Trades Construction 75 0.01 0.02 0.05DCE – Trenchers 175 0.01 0.04 0.09DCE - TxDOT Construction Equipment 187 0.02 0.03 0.10DCE - Utility Construction 3,428 0.29 0.57 2.25DCE - Mining & Quarry Operation 4,024 0.13 0.79 1.18DCE – Off-Road Tractors, Miscellaneous Equipment, & All Equipment Under 25 Horsepower 12,869 0.45 2.59 2.34Diesel Subtotal 71,886 2.27 9.90 18.74Diesel Public and Publicly-Funded 3,139 0.20 0.63 1.52Gasoline and Spark-Ignition Construction Equipment 25,306 2.07 54.44 0.33Total Construction 97,192 4.34 64.34 19.07 EMISSIONS BENEFIT The emission benefit for public and publicly funded contracts is limited (assuming City & County, County-Owned, Heavy-Highway, Municipal-Owned, and TxDOT equipment are included) to 1.4 tpd (with TxLED benefit applied) of NOx emissions. A significantly larger emission reduction could be affected if more construction categories could be included.


The maximum benefit that could be attained is if, by 2018, all equipment used in construction meets Tier 4 standards. As an example, dozer emissions in 2018 using normal turnover were compared with the dozer emissions if all equipment rapidly turned over to Tier 4 equipment. This example resulted in an expected emission reduction of 17% for VOC and 66% for NOx despite the fact that pre-Tier 4 equipment is expected to represent less than 50% of equipment by 2018. COST-EFFECTIVENESS EPA (2004) estimated that the cost effectiveness of Tier 4 nonroad engines would be about $1,000 per ton of NOx and VOC combined. This approach assumes that fleet owners would plan their fleet purchases so that a forced replacement would not occur and the initiative would merely affect the relative purchase price of new equipment. This would be considered a low cost scenario. As an alternative high cost estimate, one could consider the cost of replacing a Tier 3 engine with a Tier 4 engine. For an example, based on the TERP results (outlined in Measure 5), the cost of replacement projects for nonroad engines has been averaging $40,744 with an average life of 7 years. The emission reduction of a Tier 4 dozer instead of a Tier 3 results in about 0.01 tpy VOC and 0.33 NOx resulting an average cost effectiveness of about $19,000 per ton benefit using the TERP 3% rate of return. SUMMARY OF RESULTS


Measure # Name Description Affected Sources

Affected Emissions

(tpd) % Tpd


($/ton) 8 Emission

Reduction Contract Incentives with or without Public Funding

Encourage lower emitting engines

Nonroad Construction – Public Funded Projects

1.4 – 18 0 – 60%

1 or more

$1,000 - $19,000


REFERENCES EPA (2008), Summaries of clean contracting incentives,

http://www.epa.gov/diesel/construction/contract-lang.htm EPA (2004), Final Regulatory Analysis: Control of Emissions from Nonroad Diesel

Engines,” Office of Transportation and Air Quality, EPA420-R-04-007, May 2004.

TxDOT (2004), Special Specification 5018, “Incentive for Using Non-Road Diesel

Equipment Powered by EPA Tier 1, 2 or 3 Diesel Engines in Nonattainment and Affected Counties,” December 7, 2004.

G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control measure 21 Lawn and Garden Exchange_051009.doc

Control Measure: #21, 22, 23, 24 Lawn & Garden Exchange and Rebate Program Category: Off-road Author: Chris Lindhjem , ENVIRON DESCRIPTION Nonroad measures 21 through 24 address programs designed to promote the use of clean lawn and garden equipment. The primary benefit of these programs will be to reduce VOC and CO emissions. There are at least two examples of a replacement/purchase program to replace gasoline equipment with electric versions including several in California (http://www.aqmd.gov/tao/lawnmower.html, http://airquality.org/mobile/mowdown/mowdowngeneral.shtml) and the Central Texas program (http://www.cleanairforce.org/2008MowingFlyer.pdf). These programs have worked out many of the issues related to transfer of ownership and determining appropriate incentives. IMPLEMENTATION FEASIBILITY In order to change behavior, it might be helpful to provide a rebate or incentive for choosing clean equipment. It is important to design the rebate program to maximize the use of the clean equipment and not merely lower costs to consumers who were already considering clean equipment or replacing engines that already exceed their useful life. But by subsidizing the cost of an electric version and scrapping a working gasoline version, it would discourage the owner from also purchasing another gasoline version. PUBLIC ACCEPTANCE The programs outlined here appear to be successful and fully subscribed based on this year’s results. ANALYSIS To understand the impact of clean engines with the best example being electric lawn and garden equipment, residential leaf blowers and lawn mowers gasoline were used as the example equipment replaced. In 2018, the fleet of leaf blowers and lawn mowers will produce emissions as shown in Tables 1 and 2 from a default NONROAD model run for HGB. Most leaf blowers are modeled such that they do not last longer than 5 years, and lawn mowers 6 years on average in residential use. Most lawn and garden programs focus on lawn mowers, but Table 1 shows that the lifetime emissions from leaf blowers is


about half that of lawnmowers in Table 2, and so with a proportional incentive be candidates for replacement programs. Table 1. Residential leaf blowers (1 – 3 hp) emissions (grams/year).

Model Year

Area Population VOC CO NOx

2009 0 1,148 1,251 172010 699 1,148 1,251 172011 2,134 1,148 1,251 172012 3,907 1,148 1,251 172013 6,767 1,148 1,251 172014 21,230 1,148 1,251 172015 25,524 1,135 1,234 172016 28,092 1,088 1,178 172017 30,100 1,040 1,121 172018 31,836 989 1,065 17

Avg. Lifetime 5,095 5,518 81 Table 2. Residential lawn mowers (3 – 6 hp) emissions (grams/year).

Model Year

Area Population VOC CO NOx

2007 2,101 2,008 1,646 102008 5,884 1,580 16,973 562009 10,340 1,580 16,973 562010 15,497 1,580 16,973 562011 23,093 1,580 16,973 562012 38,925 1,580 16,973 562013 88,492 1,580 16,973 562014 99,402 1,562 16,347 562015 107,595 1,536 15,495 562016 114,110 1,507 14,528 562017 120,234 1,473 13,381 562018 125,834 1,428 11,885 56

Avg. Lifetime 9,071 88,615 333 EMISSIONS AFFECTED Table 2 shows the approximate summary emissions for nonroad equipment for 2018. The actual emissions may vary from day to day (such as weekday and weekend day) and depend upon whether the implementation of control strategies, such as TERP and TxLED, have or should be included in the estimates because TERP projects to date may exceed their project life by 2018. Table 2 should be considered as reasonable estimates rather than exact figures.


Table 2. Approximate 2018 baseline nonroad mobile source missions inventory. Summer Weekday Emissions (tons)Aggregate Equipment

Category EquipmentPopulation NOX VOC CO







8-County HGB Total Spark-Ignition Nonroad 2,150,612 9.35 50.79 874.808-County HGB Total Diesel Nonroad 124,601 26.591 3.23 14.121 – 6% lower diesel nonroad NOx emissions than TCEQ provided to approximate the TxLED emission reduction not included in the submittal. EMISSIONS BENEFIT Table 1 and 2 provides the lifetime average emission rates for the example equipment due to be replaced by electric versions. Replacing 6000 lawnmowers with electric versions results in 0.037 tpd VOC benefit. COST AND COST-EFFECTIVENESS Most programs provide an incentive of $100 to $165 per lawn mower replaced. Using the 6-year average life and benefit, the annualized cost effectiveness for VOC and NOx (but most of the benefit is in terms of VOC), ranges from $11,000 to $18,000 per ton of emissions reduced. Replacing 6000 lawnmowers would cost about $600,000 ($100,000 a year starting in 2013) to $1 million.


SUMMARY OF RESULTS



Affected Emissions

(tpd) % Tpd


($/ton)

21 Off-road Idle Small Engine Replacement

Replacement or Clean Engine

Purchase

Off-road engines

Lawn and

Garden

18.0 VOC 2.1 NOx 0.2 0.04 $11,000 -

$18,000

G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 33 Locomotive Freight Efficiency_051009.doc

Control Measure: #33, Rail Efficiency Category: Nonroad Author: Chris Lindhjem, ENVIRON DESCRIPTION This strategy suggests projects that might improve rail efficiency requiring less activity from line-haul locomotives. Some measures to effect this improvement could be public/private partnerships while others might be implemented by the railroads. Railroads have been improving their efficiency through technology and operational measures. The technologies include wheel and rail lubrication, better bearings, more efficient engines, perhaps other technologies yet to be identified. The operation changes include idle reduction, improved aerodynamics, longer trains, and improved training and evaluation of engineers to reduce braking, idling, and other inefficient operations. IMPLEMENTATION FEASIBILITY Efficiency measures need to be defined in more detail in order to determine the improvement in emissions. The additional benefits (reduce fuel consumption, safety, or others) beyond air quality benefits would account for some of the cost of the measures, and the level of investment by public or private entities would need to be negotiated. PUBLIC ACCEPTANCE If public funds are used to improve the rail network, there may be competing interests that will require officials to prioritize projects. However, benefits of freight efficiency improvements can be widespread. ANALYSIS This measure was assumed to primarily affect the mainline rail operations and therefore the line-haul locomotives. EMISSIONS AFFECTED Improving the rail network or the technology or operation of moving freight will primarily affect the line-haul locomotive emissions. Voluntary retrofit/replacement programs as described in offroad measure #5 can address yard-switching engines. Line-haul locomotives therefore represent a unique source moving the bulk of the rail freight


on the main rail lines. TCEQ estimated emissions from these locomotives as 0.8 tpd VOC and 15.8 tpd NOx in the HGB in 2018. EMISSIONS BENEFIT The rail efficiency in terms of freight moved per gallon of fuel consumed is a measure of how improvements in operations can improve emissions. The major railroads operating in the Houston area have been improving their efficiency in the range of 1% to 2% per year over the past 5 years as shown in Figure 1. The reasons for these efficiencies probably lie in both technology and operational changes.

Figure 1. Rail efficiency historical trends The focus of this strategy is to see what sort of improvements need to be made to continue improve efficiencies. The changes could include rail network improvements to avoid congestion (such as double-tracking where locomotives would otherwise need to brake and idle while awaiting other trains), free flow operations to avoid closing local roadways (such as through grade separation projects), regrading or straightening routes (to reduce mileage and fuel consumption), or other projects. The types of projects that would improve rail efficiency would be specific to the route and current or forecast activity conditions. Also, some projects may have other benefits

300

320

340

360

380

400

420

440

460

480

500

2001 2002 2003 2004 2005 2006 2007 2008

Year

Line

-Hau

l Rev

enue

Fre

ight

Effi

cien

cy (

ton-

mile

/gal

lon)

BNSFKCSUP


than air quality including safety, such as for grade separation, and reduced road congestion by removing traffic that would otherwise be handled by trucks. COST AND COST-EFFECTIVENESS The cost and cost effectiveness of rail improvement projects will be unique to each project. The project proponents would include the rail operators (railroads), and local, state, and federal transportation planners each of whom may provide funding and see benefits beyond air quality. Therefore the level of cofunding will be negotiated on a project-by-project basis. Also, it will not be possible to segregate the air quality benefit from other benefits of each project. Therefore, it is not possible to estimate the cost and cost effectiveness of these measures. SUMMARY OF RESULTS



Affected Emissions

(tpd) % Tpd


($/ton)

33 Rail Efficiency

Improved rail network and

grade separation

Line-haul Locomoti

ves

0.8 VOC 15.8 NOx 5 – 10

0.8 – 1.6 tpd NOx

N/A

REFERENCE AAR (2008), “Analysis of Class I Railroads,”

http://pubs.aar.org/pubstores/displayitem.aspx?id=13

G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 45 Clean Port_051009.doc

Control Measure: #36, 45 Clean Port Initiative Category: Nonroad Author: Chris Lindhjem, ENVIRON DESCRIPTION This measure seeks to adopt a plan that effects emission reductions from HGB area ports and private terminals. The plan could cover several or all emissions sources associated with marine activity include water and shoreside activities as outlined by EPA’s Clean Ports USA (http://www.epa.gov/otaq/diesel/ports/index.htm). But the focus in this description is the larger ocean-going vessel strategies because smaller commercial marine and shoreside (nonroad, locomotive, and trucking) port initiatives are described in nonroad measure 5. A program might use California ports plans as a model of what might be accomplished. The most widely sample plan is that for the Ports of Long Beach and Los Angeles who have adopted the San Pedro Bay Ports Clean Air Action Plan (CAAP), a plan aimed at significantly reducing the health risks posed by air pollution from port-related ships, trains, trucks, terminal equipment and harbor craft. (http://www.cleanairactionplan.org/about/default.asp) The primary purpose of this California plan is the reduction particulate matter emissions where the primary purpose of the HGB plan might be VOC and NOx reduction for ozone attainment. The plan described here will focus on the larger ocean-going vessels (OGV) because initiatives for other port sources revolve around the voluntary retrofit/replacement programs described in this report under measure 5. IMPLEMENTATION FEASIBILITY There are several complexities in implementing measures related to OGV control techniques including that most OGV are foreign flagged creating potential legal obstacles, interport competition (higher fees may be a competitive disadvantage), and other concerns with operating a port under unique costs or operating restrictions. The administration of program would fall to the ports or the state, and the methods used to enforce the program still needs to be defined. PUBLIC ACCEPTANCE While the general public may encourage emissions improvement from ships, the costs incurred and effects to business may be less well known.


ANALYSIS There are several approaches suggested in the CAAP that include and are more aggressive than the California state regulations. One focus of the CAAP is the large ocean-going vessels with several measures outlined here.

• Large Ocean-Going Vessels (OGV) o OGV Vessel Speed Reduction (VSR) o Reduction of At-Berth OGV Emissions o OGV Auxiliary Engine & Main Engine Fuel Standards o OGV Main and Auxiliary Engine Emissions Improvements

The CAAP also addresses other emission sources that have been addressed in other measures, especially nonroad measure 5 evaluated in this report. The cargo handling equipment (CHE) would fall under the category of all nonroad engines though to date it mostly applies to forklifts, construction, and other similar equipment.

• Clean truck program • Performance Standards for cargo handling equipment (CHE) • Performance Standards for Harbor Craft • Locomotive Initiatives (low emitting locomotives, idle reduction)

At issue is the potential implementation of international emission standards and national initiatives associated with marine vessels affecting the larger deep-draft ocean-going vessels. The international standards described below include provisions for low sulfur fuel and engine emission controls worldwide with additional controls near regions defined by nations as sensitive to OGV pollution. The United States championed by EPA is applying to define the US as a sensitive region requiring such emissions controls. Based on proposals to ‘International Convention for the Prevention of Pollution from Ships (MARPOL) Annex VI’ this year, a progressive reduction in sulphur oxide (SOx) emissions from ships is proposed with the global sulphur cap reduced initially to 3.5% (from the current 4.5%) effective from 1 January 2012; then progressively to 0.5 %, effective from 1 January 2020, subject to a feasibility review to be completed no later than 2018. (http://www.imo.org/environment/mainframe.asp?topic_id=233#annexvi). In addition, the sulphur dioxide emission control area (SECA) sulfur levels would be lowered from 1.5% currently to levels comparable to the CARB regulations starting with 0.5% sulfur in 2010 and 0.1% in 2015, or a few years later than the CARB regulations. The initial MARPOL Annex VI engine standards resulted in a minimal NOx reduction compared to the baseline emission factors and had no effect on PM. However, the Marine Environment Protection Committee (MEPC) of the International Maritime Organization (IMO) has agreed to proposed amendments to the MARPOL Annex VI regulations to reduce NOx emissions from engines beginning in 2011 with a 14.4 g/kW-hr and 3.4 g/kW-hr in an Emission Control Area (ECA) in 2016 compared with 17 g/kW-hr starting with vessels built in 2000.


EMISSIONS AFFECTED The emissions inventory for marine vessels is shown in Table 1. Table 1. Approximate 2018 baseline marine vessel missions inventory

Summer Weekday Emissions (tons) Aggregate Equipment Category NOX VOC CO

Harbor craft 13.40 0.29 3.32 OGV – transit 18.36 0.54 1.88 OGV – dwell 13.69 0.35 2.42 EMISSIONS BENEFIT

Vessel Speed Reduction Vessel speed reduction effects emission reductions by slowing vessels down substantially lowering the engine load. Unless the engine is at very low loads, the emissions per mile is a function of the vessel speed squared, so slowing the vessel speeds by 30% will reduce emission by half. Vessel speed reduction may be more effective near Los Angeles where vessels pass close to shore for a significant portion of their travel in the area. As shown in Figure 1, most traffic to Galveston Bay (the darkening of the route indicates more traffic) proceeds directly in and out to the Gulf. Within the Galveston Bay, vessels speeds are already low, therefore the vessel speed reduction would affect emissions well out in the Gulf and may not affect local air quality as much as might be expected.

Figure 1. OGV emissions near the Texas coast.


The emission inventory for OGV supplied by TCEQ was insufficient to determine how much of the transit emissions could be affected by vessel speed reduction.

Reduction of At-Berth OGV Emissions Vessels use auxiliary engine primarily to provide electrical power while docked. These engines are largely uncontrolled diesel engines with high emission rates. Two approaches exist to reduce emissions at dock: shoreside (plug-in) grid power provided, and use of hood or bonnet that routes the exhaust to a scrubber system that is either barge mounted or shore-based. There may be limitations to how much berthing emissions may be affected by shoreside power. For vessels that do not often visit, it may not be possible or cost effective to retrofit the vessel to allow a plug-in device. Also, some vessels have significant boiler emissions due to steam requirements (that cannot be supplied by shore power) and include, for example, some tankers that use steam-driven pumps to load and unload liquid products. Shoreside power requires time (roughly an hour at each end of the vessel call) to bring shore grid power online to the vessel including time to physically connect the power lines and balancing the vessel power grid. So shoreside power could reduce the engine emissions at berth to about 2 hours per call.

OGV Auxiliary Engine & Main Engine Fuel Standards A fuel switch to lighter fuels has been suggested primarily to reduce sulfur and particulate matter emissions, but would have some benefit for NOx emissions as well. Shown in Table 1 are the relative emission rates showing that the use of distillate fuels result in about a 6% NOx reduction. Table 1. Emission factors for OGV engine emissions by engine and fuel type. (ICF, 2006).

Engine Type Fuel VOC

(g/kW-hr) CO

(g/kW-hr) NOx

(g/kW-hr) Slow speed 2-stroke Residual 0.6 1.4 18.1 Slow speed 2-stroke Distillate 0.6 1.4 17.0 Medium speed 4-stroke propulsion Residual 0.5 1.1 14.0 Medium speed 4-stroke propulsion Distillate 0.5 1.1 13.2 Medium speed 4-stroke auxiliary Residual 0.4 1.1 14.7 Medium speed 4-stroke auxiliary Distillate 0.4 1.1 13.9 The distillate fuel in Table 1 represents diesel fuel prior to any additional controls such as was implemented with TxLED fuel. So use TxLED could reduce NOx further by another 6%. Not all auxiliary engines use residual fuel, and ARB (2005) estimated that about 29% of merchant vessels use residual fuel in auxiliary engines and only 8% of passenger vessels.


OGV Main and Auxiliary Engine Emissions Improvements A large NOx emission reduction benefit could be effectuated by using engine controls either designed into the engine or as an aftertreatment device that could be used only near sensitive air quality areas. The proposed Tier II international standard of 14.4 g/kW NOx (or 15% control) for slow speed engines from 17.0 might result from retrofit of engines, while the Tier III standard of 3.4 g/kW-hr (or 80% control) would likely require an aftertreatment device. The Tier II standards would be on vessels build in 2011 - 2015, and Tier III would be for those built in 2016 and later. The age distribution then becomes an important consideration to estimate the emission reduction, and to provide an approximate example we used 30% of vessels of 2011 - 2015 and newer by 2018 while only 10% would be 2016 and newer by 2018 using an average life of 20 years. This would result in about a 12.5% emission reduction in 2018. COST AND COST-EFFECTIVENESS

Vessel Speed Reduction The costs with regard to vessel speed reduction are associated with the added time that the products are in transit instead of sold and vessel’s crew is on duty. This can be difficult to determine, but could still be significant. For instance, a one-hour delay of all foreign freight passing through the Port of Houston Authority (about $120 billion of marine-borne freight moved through POHA in 2007 according to the Comprehensive Annual Financial Report for 2007) at 3% per year rate of return would cost about $400,000 in lost revenue. However there would be a savings of fuel used by slowing the vessels. At this point, there is no clear method to estimate the cost of slowing the vessels during a portion of their transit.

Reduction of At-Berth OGV Emissions ARB (2007) conducted a detailed evaluation of their rule to reduce emissions from OGV at port. The costs effectiveness depends upon the number of calls that each vessel would make to justify the cost of vessel retrofit, and the auxiliary loads of that vessel while in port. California highly values the PM emission reduction, but ignoring the PM benefits the cost effectiveness for only the NOx reduction from shoreside power was estimated to range from $11,000 - $80,000 per ton of NOx reduced.

OGV Auxiliary Engine & Main Engine Fuel Standards ARB (2005) conducted a detailed evaluation of their rule to reduce emissions from OGV with fuel changes. California highly values the PM emission reduction, but ignoring the PM benefits the cost effectiveness for the NOx reduction from shoreside power was estimated to be about $80,000 per ton of NOx reduced.


OGV Main and Auxiliary Engine Emissions Improvements

A cost study for implementing the international standard for engine controls was not conducted. The costs will be incurred not just for the added research and equipment used on new engines, but also maintenance cost of control equipment and perhaps a fuel penalty with low NOx designs. The engine designs have not yet been finalized so the cost is not known at this time. SUMMARY OF RESULTS

Emission Reduction Potential Measure


Affected Emissions

(tpd) % Tpd

Est. Cost Effective-

ness ($/ton)

45 Clean Port Plan

Vessel Speed Reduction

(Transit only)

OGV – transit

Less than 0.54 VOC 18.36 NOx

25% est.

4 NOx Unknown (PM benefits not counted)

45 Clean Port Plan

Reduction of At-Berth OGV Emissions

OGV – dwell

0.35 VOC 13.69 NOx

50% 0.2 VOC 6.8

NOx

$11,000 - $80,000

(PM benefits not counted)

36 Clean Port Plan

OGV Auxiliary Engine & Main

Engine Fuel Standards

OGV – All

0.89 VOC 32.05 NOx

6 – 11%

1.9 – 3.5

NOx

$80,000 (PM benefits not counted)

45 Clean Port Plan

OGV Main and Auxiliary Engine

Emissions Improvements

OGV – All

0.89 VOC 32.05 NOx

12.5% 4 Unknown Engine

designs not yet available

REFERENCES ARB (2005), “Emission estimation methodology for ocean-going vessels, Appendix D,”

Regulatory Support Document for the Rulemaking To Consider The Adoption Of Proposed Regulations To Reduce Emissions From Auxiliary Diesel Engines And Diesel-Electric Engines Operated On Ocean-Going Vessels Within California Waters And 24 Nautical Miles Of The California Baseline, December 8, 2005

ARB (2007), Technical Support Document: Initial Statement Of Reasons For The

Proposed Rulemaking to Reduce Emissions from Diesel Auxiliary Engines on Ocean-Going Vessels while At-Berth at a California Port, October 2007.

ICF (2006), “Current Methodologies and Best Practices in Preparing Port Emission

Inventories,” Final Report, Prepared for EPA, April 4, 2006.

APPENDIX H

Detail Evaluations for Weight of Evidence Control Strategies

G:\HGAC\Reports\Final_051009\Appdx H_051009\Control measure 10 Construction idling_051009.doc

Control Measure: #10, Construction and other off-road idle reduction Category: Off-road Author: Chris Lindhjem , ENVIRON DESCRIPTION Idling is an inefficient use of equipment in general and generates unnecessary emissions. Idling however cannot be avoided in all cases, such as during normal work when work is performed intermittently, and the time to restart the engine would be considered an annoyingly significant delay. This measure would seek to limit excessive idling when equipment is not required immediately. Suggested periods for limiting idling could be as little as 15 minutes maximum. Many on-road trucks have factory-installed engine shut down devices that automatically shut down the engine after a set period, or devices could be added to existing equipment. To implement this measure, idle shut-off devices could be employed with idle timers set to a period that would not cause typical operational problems. But operator training could provide significant idle reduction perhaps beyond idle shut-off devices. IMPLEMENTATION FEASIBILITY Engine shut off devices could be part of a cofunded opportunity, but operator training could be another opportunity for reduced idling time. There may be other methods to incorporate idling or fuel consumption into the accounting of each contract involving offroad equipment activity. PUBLIC ACCEPTANCE The measure would be easiest to implement as a funded idle shut-off device to avoid lengthy operator training. The general public would not often realize when equipment is idling excessively. ANALYSIS Analysis of this measure is based on estimated time in idle and relative emissions rates while at idle. Base on the EPA test procedure for off-road engines, it is estimated that nonroad engines are at idle 15% of the time they are in operation. Using emission results for a Tier 1 engine (see EPA, NONROAD model documentation, 2005) as shown, for example, in Table 1, the idle emissions are responsible for 1.4% of all emissions. Not all engines operate with the same profile as the 8-mode testing cycle shown in Table 1 and so may idle more or less than that shown. On the other hand, it is not possible to


eliminate all engine idling as some of the idle time occurs in short duration intervals between non-idle modes that occur during normal operations. Table 1. Mode weightings and emissions by mode for a sample engine.

Mode Time

Weighting Speed Torque

NOx (Tier 1 Engine)

(g/hour) Emissions Fraction

1 0.15 Rated 100% 1,626 24.9%2 0.15 Rated 75 1,220 18.7%3 0.15 Rated 50 784 12.0%4 0.1 Rated 10 231 2.4%5 0.1 Intermediate 100 1,740 17.8%6 0.1 Intermediate 75 1,342 13.7%7 0.1 Intermediate 50 898 9.2%Idle 0.15 0 0 92 1.4%

Applying the idle emission reduction percentage, 1.4%, to all nonroad equipment, excluding locomotive and aircraft addressed under different measures, the expected emission reductions would total 1 tpd in emission reduction. Because not all idling can be addressed as noted above and not all engines may be cost effectively retrofitted with automatic engine shut-offs, a 50% effectiveness criteria was applied to determine a more reasonable, lower estimate of actual emission reduction. EMISSIONS AFFECTED Table 2 shows the approximate summary emissions for nonroad equipment for 2018. The actual emissions may vary from day to day (such as weekday and weekend day) and depend upon whether the implementation of control strategies, such as TERP and TxLED, have or should be included in the estimates because TERP projects to date may exceed their project life by 2018. Table 2 should be considered as reasonable estimates rather than exact figures. Table 2. Approximate 2018 baseline nonroad mobile source missions inventory.












8-County HGB Total Spark-Ignition Nonroad 2,150,612 9.35 50.79 874.808-County HGB Total Diesel Nonroad 124,601 26.591 3.23 14.121 – 6% lower diesel nonroad NOx emissions than TCEQ provided to approximate the TxLED emission reduction not included in the submittal. EMISSIONS BENEFIT Overall, the per-project benefit is estimated at 1.4% based on the estimate that equipment idles for 15% of the total time the engine is used. To the extent that the equipment idles more than that, the benefit of the project could be greater. However, we need to consider that some idling would occur during normal operations (when engine shut off would cause an unnecessary burden on the operators) and only a fraction of the fleet that could implement controls, resulting in half of the estimated benefits. The VOC benefits were not estimated because the predominant source of VOC emissions are small gasoline nonroad engines, and so would not be able to demonstrate idle reductions. COST AND COST-EFFECTIVENESS The benefit of idle reduction would almost always be positive in terms of monetary gain. Only in the case where the engine is not often used would the return on the capital cost of added equipment result in a net cost, and in that case operator training would be a better option. SUMMARY OF RESULTS



Affected Emissions

(tpd) % Tpd


($/ton)

10 Off-road

Idle Reduction

Engine shut down devices

or operator training

Off-road engines 36 NOx 0.7 0.25

NOx ~ $0

G:\HGAC\Reports\Final_051009\Appdx H_051009\HGAC Measure 21 Scrappage_051009.doc

Control Measure: #21, Scrappage buy-back plan Category: On-road Author: Hazel Barbour DESCRIPTION This measure would build on the existing Low Income Repair Assistance Program (LIRAP), implemented as part of the AirCheckTexas Vehicle Emissions Testing program (I/M) by increasing the number of on road light duty gasoline vehicles scrapped, and would also make separate funds available to help with purchase of new on road heavy duty diesel vehicles (HDDV) to replace old, highly polluting vehicles. IMPLEMENTATION FEASIBILITY LIRAP is implemented in Brazoria, Harris, Fort Bend, Galveston and Montgomery counties and not in Chambers, Liberty and Waller which do not currently have an I/M program in place. Funds appropriated to repair and replacement assistance under LIRAP cannot be used to fund replacement/scrappage of diesel vehicles as these vehicles are not required to be emissions tested in the I/M program. Thus, it will be necessary to establish or use other sources of funding to be able to provide compensation for replacing and scrapping heavy duty diesel vehicles. However, as funds for diesel scrappage would not come from an I/M related source, a diesel scrappage buy back program could be implemented in the 8 county HBG area. Given the increased funding made available for LIRAP in the 2007 Texas legislative session, there is already a considerable increase in the uptake of funds to scrap gasoline vehicles which fail the I/M test, or which may have passed the I/M test but are over 10 years old. In FY 2007 (Sept 1, 2006 – Aug 31, 2007), 4% of the redeemed LIRAP vouchers were used to replace vehicles. After the changes to the program took effect in December 2007, the percentage of vouchers redeemed to replace vehicles in FY 08 rose to 74%. However, it should be noted that of the total number of 13,044 vouchers issued in FY 08, 4,307 vouchers were voided as unused. On the assumption the same percentage of these vouchers could have been used for replacement as the percentage of redeemed vouchers, 3,188 additional vehicles could have been replaced. According to HGAC, one of the major problems in increasing the number of participants whose vehicles may be eligible for replacement/scrappage is that owners cannot qualify for financing to purchase a replacement vehicle based on their income or credit history. PUBLIC ACCEPTANCE Removing old, high emitting vehicles from the road is a strategy that has been generally well received by the public. ANALYSIS The increased LIRAP funding available for replacing a vehicle and the higher income eligibility levels have greatly increased the number of vehicles being replaced and scrapped in 2007/08. However, the majority of the users for replacement have had incomes between 200-300% of the


poverty levels (the new income eligibility level added in 2007). On the assumption that owners of the 3188 vouchers which were not redeemed need help in addition to receiving the vehicle replacement amounts offered in the program ($3,000 for a car, current model year or up to three model years old; $3,000 for a truck, current model year or up to two model year sold; $3,500 for hybrid vehicle, current or previous model year), one solution could be to seek legislative approval to use excess funds collected through the $6 LIRAP fee on every On-Board Diagnostic (OBD) test to set up a revolving loan fund to provide low interest loans. Total LIRAP funds collected will increase every year as the number of MY 1996 and newer vehicles subject to the OBD test increases. If Chambers, Liberty and Waller come into the I/M program, this would increase the numbers of vehicles that could be replaced through the program (See Measure 133). Funds are available to help with the purchase of new heavy duty diesel vehicles to replace and scrap older vehicles through the TERP program. Additional outreach on TERP to smaller trucking companies, which may have older vehicles, could be implemented through the Texas Motor Transportation Association and at truck stops, etc. In addition to TERP funding, US EPA’s Smartway Clean Diesel Finance Program could provide the ability to establish a low interest loan program for new truck purchase or the purchase of used, pre-2007 heavy-duty trucks retrofitted with an EPA verified emission control technology, with the requirement that the new purchase replace a truck that is scrapped. The EPA grant could be used to leverage additional funds by borrowing from another lending institution, such as the Houston Green Bank. In this way, because the EPA funds are at 0 percent interest, the blended fund can offer potential truck purchasers a loan at lower interest rates if they meet the program requirements. The purchase of older light duty and/or heavy duty vehicles for scrappage could also be offered as a Supplemental Environmental Project (SEP) to companies in violation of environmental regulations, with the resulting emission reductions being treated as State Implementation Plan (SIP) credit. In 2007, approximately 440 on-road HDDVs in the HGB area were replaced with a new or newer on-road vehicle using TERP funds (thus 440 HDDVs were scrapped). In 2018, it is estimated that 9,305 of the 30,656 Class 8(a) and 8(b) heavy duty vehicles in the 8 county HGB area will be over 10 years old. If it is assumed the program can encourage an additional 50% (220) per year to take advantage of the funding offered, then the number of these vehicles over 10 years old can be reduced by over half. Identification of highly polluting HDDVs which may be good candidates for scrappage and replacement could be carried out through the use of remote sensing devices at DPS weigh stations. Emissions reductions from scrapping an additional 3188 light duty gasoline vehicles were calculated using MOBILE6 emissions factors for light duty gasoline vehicle types 1 through 5. The NOx and HC factors and annual VMT for types 1 and 2 (passenger cars, SUVS) were averaged as were the factors and VMT for types 3, 4, and 5 (all light duty trucks). Remaining useful life for the replaced vehicles was estimated at 3 years. While this is not a requirement in the LIRAP program, this is the life of a mobile emission reduction credit (MERC). The ratio of passenger cars and SUVs to all light duty trucks in the HGB area in 2007 was 0.959. For the purposes of this calculation it was assumed that 50% of the scrapped vehicles would be passenger cars and SUVs, and 50% light duty trucks.


EMISSIONS AFFECTED Emissions affected are on road light duty gasoline emissions in the 5 county HGB area and on road heavy duty diesel emissions in the 8 county HGB area. EMISSIONS BENEFIT Increasing LDGV scrappage by a minimum of 3188 vehicles per year would achieve emissions reductions of 0.09 NOx tpd or 23.16 tons per year, and HC 0.186 tpd or 46.69 tons per year. By increasing scrappage of HDDVs by 220 per year, the average NOx emission reductions per vehicle (based on averaging the emissions reductions from 330 of the 440 vehicles replaced under using TERP funds in 2007)) is estimated to be 1.1 tpd or 275 tons per year. The total NOx reduction of 1,925 tons is based on a project life of 7 years as used in the TERP calculations. COST AND COST-EFFECTIVENESS The total costs of providing the LIRAP incentive ($3,000) to replace and scrap the estimated 3188 light duty gasoline vehicles is estimated to be $9,564,000. Assuming the average continuing useful life of the scrapped vehicles if they had not been scrapped to be 3 years, the cost effectiveness per ton of NOx is estimated to be $137,651 and per ton of HC, $68,280. The TERP grant funds awarded to the 440 Houston-Galveston area HDDVs in 2007 range from around $15,000 up to $110,000, with the average grant awarded per vehicle being $59,655. Total cost of replacing 220 HDDVs is estimated to be $13,124,100. Cost effectiveness is calculated to be $6,818 per ton. SUMMARY OF RESULTS



Sources Affected

Emissions(tpd) % tpd


($/ton)

21 Scrappage Buy Back Plan

Monetary compensation for scrappage

of old vehicles, including HDDVs.

On-road LDVs in 5 county HGB area and HDDVs in the 8 counties

LDGVs NOx 26.88 VOC: 37.22: HDDVs NOx 19.67 VOC 3.14

LDGVs NOx 0.33 VOC 0.49: HDDVsNOx 5.59

LDGVs NOx 0.09 VOC 0.186: HDDVs NOx 1.1

LDGVs NOx $137,651VOC $68,280: HDDVs: NOx $6,818


REFERENCES Graciela Lubertino, HGAC; LIRAP statistics for FY 07 and 08. Texas Motor Transportation Association (TMTA): www.tmta.com TCEQ Texas Emission Reduction Plan (TERP) data: www.tceq.state.tx.us US EPA Smartway program: www.epa.gov

G:\HGAC\Reports\Final_051009\Appdx H_051009\BControlMeasure58-PAYD-EM_051009.doc

Control Measure: #58, Pay As You Drive Insurance Programs Category: On-Road Author: Barbara Joy, Earth Matters Inc DESCRIPTION Pay-As-You-Drive (PAYD) Vehicle Insurance (also called Distance-Based Vehicle Insurance and Mileage-Based Insurance) is a program whereby a vehicle’s insurance premiums are based directly on how much it is driven during the policy term. The way car insurance is currently structured, high mileage drivers are, in essence, subsidized by lower mileage drivers since all are charged the same premiums after accounting for driving history related to accidents and traffic violations. If you drive 5,000 miles per year you are charged the same premium as someone driving 50,000 miles per year. In pay-as-you-drive programs. driving more causes higher charges and driving less causes lower charges. According to a September 21, 2008 article in the Baltimore Sun1, participating motorists can save an average of about 40% on their annual insurance premiums. More and more areas in the U.S. are offering this program; currently (11/08) it is offered in Alabama, Michigan, Minnesota, New Jersey, and Oregon. In Texas, pilot programs have or are operating in various metropolitan areas such as Dallas. In addition to reductions in VMT there are other benefits. According to a recent Brookings Institution Hamilton Project study2, Economist Aaron Edlin estimates benefits to insurance companies for reduced accidents to be roughly $33 per vehicle (and even that is only a temporary gain until other firms match its new policies), while the social benefits from reduced accidents and congestion alone would be roughly $118 per vehicle. As noted by (Litman, 2005), in these programs existing rating factors are incorporated so higher-risk motorists pay more per unit than lower-risk drivers. For example, a $375 annual premium becomes 3¢ per mile, and a $1,250 annual premium becomes 10¢ per mile. An average U.S. motorist would pay about 6¢ per mile. Studies based on individual’s response to changes in the price of auto use show that significant travel and associated emission reductions can be realized through these programs. One major benefit of this and other pricing programs is that it affects all categories of travel. Most measures aimed at reducing travel and associated emissions focus on commute travel, which represents about 25 – 30 percent of total travel in a given region. This measure would affect both commute and non-commute travel.

1 http://www.baltimoresun.com/news/traffic/bal-id.insurance21sep21,0,155432.story 2 Pay-As-You-Drive Car Insurance: Transportation, Climate Change, Regulation, U.S. Economy, Environment Jason E. Bordoff, Policy Director, The Hamilton Project. Democracy Journal, Issue #8, Spring 2008


In 2001 the Texas legislature passed House Bill 45 that allowed Texas insurance companies to offer mileage-based insurance. However this law had a sunset provision and expired in September 2005. Companies in Texas and in all other states can still voluntarily offer the cents-per-mile choice under existing insurance law. This analysis evaluates the potential effect of this program were it subscribed to by 50 percent of Houston area drivers. ANALYSIS There have been a number of estimates of the potential benefits of mileage programs and similar programs involving changes in the price of driving. These estimates range from 1.8 to about a 20 percent reduction in driving per individual in the program. The sources of these estimates include:

1. Todd Littman’s “Distance-Based Vehicle Insurance Feasibility Costs and Benefits”, 2001, Victoria Transport Policy Institute;

2. Harvey and Deakin’s 1997 Appendix to the report “Technical Methods for Analyzing Pricing Measures to Reduce Transportation Emissions” by EPA and FHWA;

3. Baker and Barrett’s “The feasibility of Pay by the Mile Auto Insurance”, 1999 Economic Policy Institute; and, most recently,

4. Brookings Institution Hamilton Project, July 2008 the Impact of Pay-As-You-Drive Auto Insurance in California by Jason E. Bordoff and Pascal J. Noel.

Harvey and Deakin utilized a modified transportation model called the STEP model initially developed for the San Francisco Bay Area to evaluate a variety of pricing measures on driving behavior. The model was applied to four different areas in California, based on 1990 land use and price data. Table B-21 of their appendix3 contains a list of cents per mile charges and associated percent travel reduction. For example these range from 2.3 to 19.7 percent changes in VMT for mileage fees ranging from one to ten cents for 1991 in Los Angeles. These values were updated by Todd Littman (see http://www.vtpi.org/tdm/tdm79.htm, Table 1) to account for inflation between 1991 and 2001, as follows:

3 Greig Harvey and Elizabeth Deakin, “The STEP Analysis Package: Description and Application Examples,” Appendix B, in Apogee Research, Guidance on the Use of Market Mechanisms to Reduce Transportation Emissions, USEPA (Washington DC; www.epa.gov/omswww/market.htm), April 1997


Table 1. Mileage Fees and Percent Travel Reduction. Mileage Fee

(cents) Travel Reduction

(percent) 1 1.8 2 3.5 3 5.1 4 6.7 5 8.2 6 9.7 7 11.2 8 12.5 9 13.8

10 15.2 The figures presented here are reasonably consistent with those presented in the Brookings study, which found an 8 percent reduction for participants.4 ANALYSIS AND RESULTS The methodology uses the cents per mile changes noted by Littman (2001) and quoted in Table 1 above. Assumptions include the following:

• Emission factors for MOBILE6 for 2018 are used; • Elasticity of driving demand with respect to a one percent change in price is -0.4,

using a medium term elasticity value. • Insurance prices in 2018 are 12 cents per mile; • Only light duty passenger vehicles are affected by the program – delivery

vehicles, line haul trucks and the like are not; • Daily light duty vehicle miles traveled in 2018 for the H-GAC nonattainment area

are 160,018,988. • NOx emission factor for light duty vehicles is 0.171 grams per mile; • VOC emission factor for light duty vehicles is 0.231 grams per mile; • VOC and NOx emissions include all categories of emissions, including start,

tailpipe, evaporative, running loss, etc. All results are expressed as tons per day reduction and percent of total on-road vehicle emissions reduced.

4 More specifically they found that there would be an 8 percent reduction nationwide if all motorists were on a pay-as-you-drive system.


It is assumed that 2018 insurance rates, if assessed in the manner they are now, would average 12 cents per mile. Given expected savings of 40% from moving to a pay-as-you-drive program, costs would be reduced from 12 cents to 7.2 cents per mile for each participant. According to H-GAC5, 2002 costs of driving were 11.8 cents per mile considering gasoline, oil and maintenance. At a compounded growth rate of 3 percent per year it is expected that driving costs will be 18.9 cents per mile in 2018. The combination of variable driving costs plus insurance costs would be 30.9 cents per mile in the absence of a pay-as-you-drive program and 26.1 cents per mile with one. Using an elasticity of -0.4 it is estimated that the program would result in an 7.4 percent reduction in travel per participant, which is consistent with the independently derived Brookings Institution study. Emissions Analysis The emissions analysis utilized the basic process suggested by the MOSERs methodology, as follows: Variables: EFA: Speed-based composite emission factor after




(grams/trip) TLA: Average auto trip length after implementation (miles) TLB: Average auto trip length before implementation (miles) VMTA: Vehicle trips after implementation

VMTB: Change in VMT as a result of implementation Total light duty travel in 2018 is estimated by the H-GAC transportation model to be 160,018,988. If 50 percent of this travel is by motorists participating in a pay-as-you-drive program then 11,841,405 miles of travel would be reduced by this program. 5 Personal Communication Gao Shixin, H-GAC and Barbara Joy, Earth Matters Nov 11, 2008.


Equation:



COST EFFECTIVENESS PAYD insurance programs may actually produce a net savings in money, meaning they are exceptionally cost effective. The Brookings study cited earlier estimates $50 to $60 billion dollars per year in savings from less driving, fewer accidents, and lower costs. Therefore it is assumed that the net cost of this program would be negative. In summary it is expected that cost effectiveness will be less than $4,000/ton which is the highest ranking for cost effectiveness. COMMENTS This evaluation is based on a combination of hypothetical assumptions and data for this program and may be considered for use in ozone plan after review of key assumptions, expected emission reductions and potential implementation approaches. If more refined analysis is conducted it may provide additional accuracy to evaluate the measure based on price elasticities and estimates of expected costs per mile for driving.


Also key is that the emission factors used in the analysis are emission factors with currently programmed federal and other control measures such as Tier 2 tailpipe standards. Other measures are being evaluated for the H-GAC region, such as California LEV (low emission vehicles), cleaner fleets and wider application of the Inspection and Maintenance program. If these or other similar programs were implemented, the emission factors used to evaluate programs affecting the amount of travel (such as this one) would be smaller – each mile driven would be at a lower emission rate and therefore each mile not driven would not reduce emissions as much as it would have without the additional measures. SUMMARY OF RESULTS:




Cost Effectiveness

($/ton) 58 Pay-As-

You-Drive (PAYD) Insurance

PAYD participation at 50 percent of LDV activity


40.7 VOC 30.3 NOx

7 3.0 2.2

<$4,000

G:\HGAC\Reports\Final_051009\Appdx H_051009\Control Measure 126 Reduced Idling_051009.doc

Control Measure: #84, 126, 147, 148, Reduced Idling Category: On-road Author: Chris Lindhjem, ENVIRON DESCRIPTION Idling of vehicles is inherently an inefficient operation that can produce unwanted air pollutants. Idling however also occurs during normal driving and other operations such as when the engine powers necessary accessories including for example man-lifts or concrete tumblers. Therefore it is not possible to eliminate all idling. But idle reduction programs are interesting because the costs are typically low and may be a net savings to the owner/operator of the vehicle while also reducing air emissions. IMPLEMENTATION FEASIBILITY There are several methods that have been attempted to reduce idling of vehicles; primarily from heavy-duty trucks that often idle while the driver is off-duty or performing other duties nearby. There are two basic methods: a voluntary approach where alternatives to idling are provided, and a punitive (fines) method where no idle zones are posted and policed to eliminate idling. PUBLIC ACCEPTANCE A voluntary program can achieve enthusiastic support because infrastructure to reduce fuel costs can be paid for from public funding. A requirement to eliminate idling would be difficult to administer, but would have a larger impact on emissions. ANALYSIS In the strictest implementation, idling more than 5 minutes would be prohibited except for normal operations whether or not an alternative to idling exists. This could affect all heavy-duty vehicles whether delivery / retail vehicles or other vehicle functions. The EPA (2004) guidance estimates that up to 3.4% of Class 8 truck NOx emissions could be reduced through reduced long duration idling programs. This presumably sets up the maximum benefit for programs such as the IdleAire truck stop electrification project funded by TERP. For light-duty vehicles at drive-thru operations, it would be difficult to gauge how much that would be. For an extraordinary total, even if an astounding 10% of the HGB population of 5,628,101 idled 10 extra minutes in a single occupancy vehicle, the


resulting emissions increase would be 0.16 tpd VOC and 0.04 tpd NOx. This calculation used the emission rates in Table 1 for passenger cars and light-duty gasoline trucks. Table 1. Idle emission rates for light-duty gasoline vehicles in 2018.

Vehicle Type VOC (g/hr)

CO (g/hr)

NOx (g/hr)

LDGV (passenger cars) 1.56 10.55 0.38LDGT1 (Light-duty trucks) 1.70 11.01 0.36LDGT2 1.82 12.49 0.53LDGT3 1.16 9.58 0.37LDGT4 1.22 10.03 0.57 EMISSIONS AFFECTED The EPA guidance on reduced idling includes an upper end estimate of 3.4% of area NOx due to extended idling. For the all diesel and gasoline trucks the NOx emissions are 21.6 tons per day, and for the larger Class 8 trucks (the subject of the EPA guidance) the NOx emissions are 13.2 tons per day for a weekday in 2018. EMISSIONS BENEFIT If idle reduction programs can be expanded to all heavy-duty vehicles, then 0.73 tpd could be reduced. The long duration idling reduction for Class 8 maximum would be 0.45 tpd of which 0.33 tpd was credited to the IdleAire TERP project expected to last through 2020. COST AND COST-EFFECTIVENESS The TERP program to supply idle reduction technology in the HGB area was estimated to reduce NOx emissions at $1,200 per ton. This truck stop electrification project however targets the most readily available and likely largest source of idling trucks, and so reducing idling in other areas would produce less benefit for the investment. It is not possible to estimate the lost revenue and cost of prohibiting drive-thru operations during ozone episodes or for the summer season when ozone events would likely occur. SUMMARY OF RESULTS




Affected Emissions

(tpd) % Tpd


($/ton)

126, 147, 148

Idle limits for heavy-duty vehicles

Idle Reduction Programs

Heavy-duty

vehicles 13.2 – 21.6 3.4 0.45 –

0.73 $1,200

84

Prohibit drive-thru service during ozone season

Idle Reduction Program

Light-duty vehicles

40.7 VOC 30.3 NOx

0.4% VOC 0.1% NOx

0.16 VOC 0.04 NOx

Unknown

REFERENCES EPA. 2004. “Guidance for Quantifying and Using Long Duration Truck Idling Emission

Reductions in State Implementation Plans and Transportation Conformity,” Office of Transportation and Air Quality,” EPA420-B-04-001, January 2004, pg. 12 http://www.epa.gov/SmartwayLogistics/documents/420b04001.pdf.

G:\HGAC\Reports\Final_051009\Appdx H_051009\BControlMeasure137LivableCenters-EMUpdate_051009.doc

Control Measure: #137, Encourage/Mandate Livable Centers Category: On-Road Author: Barbara Joy, Earth Matters Inc DESCRIPTION Communities across the country are developing creative strategies aimed at preserving natural lands and critical environmental areas, protecting water and air quality, and reusing already-developed land. They conserve resources by reinvesting in existing infrastructure and reclaiming historic buildings. By designing neighborhoods that have shops, offices, schools, churches, parks, and other amenities near homes, communities are giving their residents and visitors the option of walking, bicycling, taking public transportation, or driving as they go about their business. A range of different types of homes makes it possible for senior citizens to stay in their homes as they age, young people to afford their first home, and families at all stages in between to find safe, attractive and affordable homes. Through smart growth approaches that enhance neighborhoods and involve local residents in development decisions, these communities are creating vibrant places to live, work, and play. The high quality of life in these communities makes them economically competitive, creates business opportunities, and improves the local tax base. EPA developed the Smart Growth Implementation Assistance (SGIA) program in response to communities' requests for help in achieving their development goals. Through this program, EPA provides technical assistance from private-sector experts to helping communities find the best tools and resources for planning growth in ways that sustain environmental and economic progress and create a high quality of life. In October 2008 the program selected three cities: receive Smart Growth Implementation Assistance from a team of private-sector experts: Capitol Region Council of Governments, Connecticut; Miami-Dade County, Florida; and New York City, New York. While Houston is not participating in the SGIA program at this time (they did receive an SGIA grant in 2006), the area has expressed interest in evaluating the potential effects of these measures on travel activity and emissions. The Community and Environmental Planning section of H-GAC developed a spreadsheet to assist in the evaluation of these measures, focusing on four types of centers:

1. Neighborhood Centers 2. Town Centers 3. Regional Centers 4. City Centers

Considered for each center are the acreage, walking distance to the center, the density of residents and employees, the number of residents who both work and live in the center, job density, number of dwelling units; the share of auto in all non-work trips for residents


of a center when the non-work destination is in the same center; the share of transit in all non-work trips for residents of a center when the non-work destination is in the same center; the share of walking/biking in all non-work trips for residents of a center when the non-work destination is in the same center; the percent of commuter trips (for residents) accounted for by SOV; and average people in a carpool (for residents). Note that this description includes a representative list of examples in order to provide a flavor; a full description of inputs can be provided upon review of the spreadsheet which is available on request. Values used in the spreadsheet are derived from the 2006 American Community Survey for Harris County, the 2001 National Household Transportation Survey (http://nhts.ornl.gov/2001/pub/STT.pdf), and the 2000 census1, as well as from engineering judgement generally based on values observed in the Houston or similar areas or inferred where data sources did not exist. ANALYSIS This analysis is based upon a hypothetical scenario in which the Houston area successfully completes a large number of town, regional, and urban core centers as follows: Table 1. Base Case (actual current centers) and Modeled (2018) Number of Centers. Neighborhood

Center Town Center Regional Center Urban Core

2005 82 23 3 1 2018 87 28 4 1

The base case is the actual number of centers based upon an evaluation of aerial photographs overlayed by grids performed by the Community and Environmental Planning section of H-GAC. The 2018 values are hypothetical. More or fewer centers could be feasible and completed depending on a variety of factors. The following utilizes the basic process suggested by the MOSERs methodology, as follows: EMISSIONS ANALYSIS The emissions analysis utilized the basic process suggested by the MOSERs methodology, as follows: Variables: EFA: Speed-based composite emission factor after



1 Personal communication October 23, 2008. Meredith Dang, H-GAC and Barbara Joy Earth Matters.



(grams/trip) TLA: Average auto trip length after implementation (miles) TLB: Average auto trip length before implementation (miles) VMTA: Vehicle trips after implementation

VMTB: Change in VMT as a result of implementation The spreadsheet estimates that the above centers would result in a 1 percent reduction in area-wide trips. It is assumed that the same percentage applies to VMT. There are 160,018,988 daily miles of travel by light duty vehicles in the region in 2018. A 1 percent reduction would be equivalent to a reduction of 1,600,190 miles per day. Equation:


C = VMTB * EFA = 1,600,190 * 0.171 gram/mile NOx/454 = 603 lb/day, and 0.30 tpd NOx and 1,600,190 * 0.231 gram/mile VOC/454 = 814 lb/day, and 0. 41 tpd VOC.


COST EFFECTIVENESS The cost of this measure is unknown and unquantifiable without planning for specific projects. COMMENTS This evaluation is based on hypothetical assumptions and data for this program. Other assumptions could result in different results. SUMMARY OF RESULTS


Measure ID

Name Description Affected Source

Affected Emissions

% Tpd

Cost Effectiveness

($/ton)

137 Encourage/mandate livable centers

Mix of town, regional and urban core centers


40.7 VOC 30.3 NOx

1.0 0.41 0.30

Unknown

G:\HGAC\Reports\Final_051009\Appdx H_051009\HGAC Measure139 Smoking vehicles_051009.doc

Control Measure: #139, Enhanced enforcement for Smoking Vehicles Program Category: On-road Author: Hazel Barbour DESCRIPTION This measure would encourage local law enforcement officers to enforce existing smoking vehicle legislation and enable the emissions inspection status of smoking vehicles to be checked. Owners of smoking vehicles displaying a valid inspection sticker would be fined. Smoking vehicles not having a valid inspection sticker would be impounded if the sticker were found to be fraudulent. The measure would be modeled on the Dallas Emissions Enforcement Pilot Program put in place by North Central Texas Council of Governments (NCTCOG). This program was established to identify and remove high emitting vehicles with fictitious or counterfeit state inspection and/or registration stickers from the roadways and was not linked to reports of smoking vehicles. The pilot program attempted to establish the percentage of impounded vehicles that cannot be found in the vehicle registration or inspection and maintenance databases. For Measure 139 to be most effective, in addition to smoking vehicles, vehicles seen by law enforcement officers to have potentially fraudulent stickers should be pulled over. IMPLEMENTATION FEASIBILITY Texas Transportation Code (TTC) Section 547.605(d) states that “Except when travel conditions require the downshifting or use of lower gears to maintain reasonable momentum, a person commits an offense if the person operates, or as an owner knowingly permits another person to operate, a vehicle that emits: (1) visible smoke for 10 seconds or longer; or (2) visible smoke that remains suspended in the air for 10 seconds or longer before fully dissipating. An offense under this section is a misdemeanor punishable by a fine of up to $350 for each violation. Thus, law enforcement officers have the right to pull over a vehicle which is smoking, and under TTC Section 548.603, have the right to impound the vehicle if a stolen, fictitious or counterfeit state inspection sticker is displayed. For each county in which the program is implemented, collaboration will be necessary between the County Judge, County JP, County Constable, and Texas Department of Public Safety. It will also be necessary to provide participating law enforcement agencies access to the I/M Vehicle Identification Database (VID) so that the smoking vehicle’s I/M test status can be investigated at the point of pulling over the vehicle.


Although the owners of diesel vehicles can be fined for exhibiting visible smoke, they are not subject to I/M testing. Thus, there is no requirement to reduce VOC or NOx emissions and no easy way to quantify VOC or NOx benefits from repairing the vehicles to reduce smoke. PUBLIC ACCEPTANCE Dealing with smoking vehicles has general public approval. The measure may be more controversial with regard to impounding vehicles generally owned by low income families. ANALYSIS The emissions reductions for the program are achieved by having out of compliance vehicles come into compliance with the emissions standards in the I/M program. The Dallas Pilot Project was implemented in one precinct of Dallas County. Of the over 1000 vehicles pulled over during the 3 months of the Dallas pilot project, 541 vehicles were identified driving with stolen, fictitious or counterfeit state inspection certificates and impounded. Of the impounded vehicles, 360 or 66.5% received a passing inspection certificate usually within 60 days of being impounded,. However, later investigation discovered that of the 360 passing inspections, 172, or 47.8% appeared to have received an incorrect inspection consisting of clean scanning, clean piping, wrong test type being conducted, or inspectors not being truthful about insurance. Thus, the emissions benefit for the program was estimated for the 188 vehicles that were repaired and received a valid inspection. Based on an average obtained from a sample set of MY 1995 and older vehicles that were repaired through the program, NCTCOG estimated the following emissions reductions per vehicle from passing the I/M test:

• Average VOC reductions of 0.0060 tons per year per vehicle • Average NOx reductions of 0.0632 tons per year per vehicle.

Reductions directly contributed to the Dallas Pilot program i.e. to the 188 vehicles that were legitimately repaired and passed the emissions test:

VOC Reduction = 188 vehicles x 0.0060 = 1.128 tons per year NOx Reduction = 188 vehicles x 0.0632 = 11.88 tons per year

Tons per day reductions from 188 vehicles (weekday emissions): VOC Reduction = 0.004 tons per day NOx Reduction = 0.047 tons per day The measure is analyzed assuming implementation in the 8 Constable Precincts in Harris County.


EMISSIONS AFFECTED The emissions affected are the 3% on road light duty gasoline emissions from vehicles in the Harris County I/M program, which are assumed to be waived from testing. However, realistically this rate is under 1%. The difference between 3% waiver rate and 0% was modeled for Harris County only using the current inventory. EMISSIONS BENEFIT Assuming there may be considerable overlap between smoking gasoline vehicles and vehicles not in compliance with the emissions test, and that all other factors remain the same, extrapolating from the Dallas county pilot program numbers the tons per day emissions reductions in the 8 precincts in Harris county provide at a minimum the following tons per day reductions from repairing 1504 vehicles in a 3 month period to be in compliance with the I/M test standards: VOC Reduction = 0.031 tons per day, or 1.937 tons for the three months NOx reduction = 0.376 tons per day or 23.5 tons for the three months Estimating for a 12 month period based on the Dallas numbers, 6016 vehicles could be repaired to be in compliance with the emissions test. This number would be well within the number of vehicles accounted for in the 3% waiver rate. COST AND COST-EFFECTIVENESS Cost effectiveness is assessed from the costs of the Dallas 3 month pilot program. It is to be expected that full implementation would achieve more cost effective results. Of the total cost of $265,000 NCTCOG estimated for the 3 month pilot program in one precinct in one county, $250,000 was accounted for as in-kind administrative oversight support from NCTCOG and county staff and in-kind law enforcement contribution. The remaining $15,000 costs were covered by an EPA grant. Cost effectiveness per ton of pollutant reduced for the 3 month period:

VOC Reduction = $136,809 NOx Reduction = $ 11,276 VOC and NOx combined = $ 10,417

NOTE: the cost effectiveness and emissions reduction calculations do not account for the actions which would be taken from following up the 172 vehicles which were improperly emissions tested following impoundment.


SUMMARY OF RESULTS



Sources Affected



($/ton)

139

Enhanced Enforcement for Smoking Vehicles Program

Local law officer

enforcement of smoking

vehicle legislation

and check on vehicle

inspection status

Harris Co. Light- Duty Gasoline vehicles

VOC 0.30 NOx 0.42 Harris County only

VOC 10 NOx8.9

0.031 VOC 0.038 NOx

VOC $136,809 NOx 11,276 VOC+NOx $10,417

REFERENCES Jody Purvis, Air Quality Operations Coordinator, NCTCOG Dallas Emissions Enforcement Pilot Program (DEEP), Final Report, March 1, 2007, NCTCOG