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**Federal Transit Administration**

**Environmental Management Systems**

**Training & Assistance**

**Final Report**

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**Federal Transit Administration Office of Planning & Environment
September 2003 -- January 2006**

**Foreword**

This report contains the results of a 29 month effort by the Federal
Transit Administration (FTA), ten local transit agencies and the Center
for Organizational and Technological Advancement (COTA) at Virginia
Polytechnic Institute and State University (Virginia Tech) to advance
international environmental management standards (ISO 14001) in public
transit agencies in the United States. The report summarizes FTA's
environmental management systems (EMS) training and assistance project.
The intent of this program was three-fold:

1.  To introduce a geographically and size diverse set of public transit
    entities throughout the US to EMS;

2.  To stimulate these agencies into adopting EMS and becoming EMS
    champions in the universe of public transit agencies; and

3.  To develop an EMS training program that would be, to a certain
    extent, transit specific.

Training and assistance participants included FTA grantees from New
England, the Middle Atlantic Region, the Mid West, the Rocky Mountains,
the Southwest and the West Coast. These agencies ranged from medium
sized traditional bus and para-transit operations to large organizations
operating busses, ferries and commuter rail. The testimonials of Senior
Management are a tribute to both the enthusiasm of the individual EMS
teams and the estimable qualities of ISO 14001 Standards. At this
writing two participating agencies have obtained ISO 14001 certification
and one other agency is seeking certification. FTA believes that COTA
has developed a transit related EMS training program that would greatly
assist all FTA grantees in pursuing environmentally harmonious and
sustainable operations.

**Acknowledgements**

This document was developed under Cooperative Agreement, Project Number
VA-26-1005 awarded by the Federal Transit Administration (FTA) to the
Center for Organizational and Technological Advancement (COTA) at
Virginia Tech.

FTA would like to thank Jim Horne of Environmental Protection Agency's
Office of Water for his kind assistance and advice in launching this
initiative. FTA, Virginia Tech and the participants would like to thank
Kevin Considine of TriMet in Portland, Oregon for acting as transit EMS
practitioner/advisor. He generously donated his time, expertise and
enthusiasm to the effort. Additionally, FTA and Virginia Tech would like
to thank Kristel Riddervold, Environmental Manager for the City of
Charlottesville, Virginia who generously donated her time to serve as a
visiting EMS instructor.

**[Federal Transit Administration]{.underline}**

Carl Bausch, Director, Office of Planning and Environment

Susan Borinsky, Regional Administrator, FTA Region 3

Jim Barr, Project Manager, Office of Planning and Environment

**[Virginia Polytechnic Institute & State University (Virginia
Tech)]{.underline}**

W. Robert Herbert, Principal Contractor, COTA Fellow

Rose Woodford, Program Administrator

Lee Faulkner, P.E., instructor

Scott Perkins, P.E., instructor

Michele Lawton, Lead EMS auditor and instructor

**[EMS Team Members]{.underline}**

**Bay Area Rapid Transit, (BART)**

Tian Feng, District Architect

James Dunn, Chief Engineer, Maintenance and Engineering

Tamar Allen, Chief Mechanical Officer, Rolling Stock and Shops

Gary Jensen, Principal Environmental Engineer

**Community Transit**

Mike Burress, Risk Manager

Bruce Bachtel, Manager of Facilities and Automotive Services

Dan Jerome, Capital Facilities Planner

Colleen Sather, Loss Control Coordinator

Tom Huden, Facilities Journeyman

**Hampton Roads Transit (HRT)**

Barbara Brumbaugh, environmental representative from the City of
Chesapeake, Virginia.

Perry McCoy, Manager of Operations Analyst,

Robert Baker, Development Program Project Manager

Bill Bryan, Risk Manager

**Massachusetts Bay Transportation Authority (MBTA)**

Gerri R. Scoll, Assistant General Manager for Environmental Affairs

Janice Kearney, Environmental Counsel

Al Capachietti, Superintendent, Fellsway Garage

Robert Doyle, Superintendent, Orange Line Maintenance.

William Hayes, Subway Maintenance-CMO

Michael Le, Section Chief Everett Shop and Non Revenue, Bus Operations
and Engineering

Brandon Savage, Facilities Compliance Officer

Rodney MacCormack, Manager of Environmental Compliance

**City of Phoenix, AZ**

Reed Caldwell, City of Phoenix Public Transit Department EMS Management
Representative

Rob Cox, ATC Phoenix Environmental Administrator

Amanda Luecker, City of Phoenix Public Transit Department EMS
Coordinator

Larry Kucera, ATC Phoenix Management Representative

Monica Rabb, City of Phoenix Office of Environmental Programs EMS
Auditor

**Sound Transit, WA**

Perry Weinberg, Environmental Compliance Manager

Terry Beals, Permits Administrator

Katie Lichtenstein, Project Coordinator

Mark Menard, Senior Environmental Analyst

Lauren Swift, Environmental Planner

Christopher Townsend, Senior Environmental Planner

Vicki Youngs, Program Manager

**Transit Authority of River City, KY (TARC)**

Geoffrey Hobin, Special Projects Manager

James Barrett, Assistant Director of Maintenance

Dan Franklin, Director of Transportation

Cathy Reasor, Safety Assistant

**Tucson Department of Transportation (Sun Tran)**

Kevin Faulkner, Maintenance Director-Sun Tran

Clare Conley, Staff Assistant-TDOT

Ivey Schmitz, Deputy Director-TDOT

George Caria, General Manager-Sun Tran

John Zukas, Transit Services Coordinator-TDOT

Utah Transit Authority, (UTA)

Jerry Benson, Chief Performance Office -- Senior Management
Representative

Grantley Martelly, Manager Safety & Environmental Protection -- EMS Team
Leader

George Bryant, Manager of Maintenance

Allen Petersen, Manager of Facility Maintenance

Rick Garcia, Maintenance Training

Ed Buchanan, Rail Safety Administrator

Tim Rhoades, Bus Safety Administrator

Jeffery Harris, Deputy Chief -- Asset Management & Business Development

**Washington Metropolitan Area Transit Authority**

Kevin Lyons, Director, Department of Safety and Risk Protection

Diana Wood, Environmental Protection Oversight Administrator

Joan LeLacheur, Manager of Environmental Services

Claire Fox, Versar, Inc., Environmental Services Consultant

Dave Hardt, Supervisor, Car Maintenance

Earl Harper, Supervisor, Car Maintenance

**Prepared by:**

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Center for Organizational and Technological Advancement

Virginia Polytechnic Institute and State University (Virginia Tech)

110 Shenandoah Avenue

Roanoke, Virginia 24016

**Table of Contents**

**Executive Summary 1**

**Federal Transit Administration Effort 5**

**Selection Methodology 5**

**Project Outline 6**

**What is an EMS? 8**

**Benefits of an EMS 11**

**Resource Commitments 12**

**Keys to Successful Implementation 13**

**Senior Management Comments 16**

**Appendix "A" -- Case Studies 19**

**Executive Summary**

In the summer of 2003, the Federal Transit Administrator issued a Dear
Colleague letter to the 100 transit agencies throughout the United
States with the highest ridership levels inviting them to apply for the
FTA sponsored training and assistance for implementing an ISO 14001
based EMS. FTA\'s initiative of EMS training for public transit agencies
supports President's Bush's Executive Order 13148 *Greening the
Government* initiative and Executive Order 13274 *Environmental
Stewardship and Transportation Infrastructure Project Reviews*, which
directs federal agencies to promote environmental stewardship in the
nation\'s transportation system while streamlining the environmental
review and development of proposed transportation projects.

An Environmental Management System (EMS) is a set of processes and
practices that enable an organization to reduce its environmental
impacts and increase its operating efficiency. Organizations with an EMS
report being able to more effectively manage their environmental
obligations. Additionally, organizations report enhanced ability to
analyze, control and reduce environmental impacts, and to operate with
greater efficiency and control.

FTA believes that EMS is a valuable tool and desired to introduce the
doctrine of environmental management systems to a pilot group within the
public transit sector. The ISO 14001 Standards served as the basis of
EMS training. FTA left the option of ISO certification to the discretion
of the individual agencies.

**How Were Teams Selected?**

In December 2003, after receiving applications and completing
interviews, FTA selected ten of the applicant agencies to participate in
the training. FTA used a number of criteria to select participants,
including:

-   Organizational commitment by transit agency leadership to EMS
    implementation;

-   Geographical diversity;

-   Previous environmental experiences; and

-   Environmental challenges from operations and/or pending capital
    projects.

FTA believed that organizational commitment to environmental protection
and sustainability were the most important elements of the program and
that senior management buy-in was crucial to successful implementation.

It was important to the FTA that participating agencies attempt to
demonstrate quantitative costs and benefits of the EMS implementation.
FTA required teams to track both internal and external costs such as
staff (managerial time and other employee time), costs of potential
consulting assistance and outside training of personnel, and to the
extent possible, the quantitative benefits of measuring individual
environmental objectives and targets.

**FTA Assistance**

FTA contracted with The Center for Organizational and Technological
Advancement (COTA) at Virginia Polytechnic Institute and State
University (Virginia Tech) to support training and assistance under a
cooperative agreement. COTA developed a Memorandum of Understanding
(MOU) with each participating transit agency that outlined the roles and
responsibilities of all the parties (FTA, Virginia Tech and the transit
agency). The MOU was signed by the parties as a condition of
participation, prior to any work being performed. COTA provided
assistance in the form of:

1.  Baseline Environmental Reviews at each site

2.  Four 3-day workshops

3.  Team Conference Calls between workshops

4.  Senior Management Conference Calls prior to Workshops 2, 3 and 4

5.  Two technical site visits

6.  One concluding EMS audit at each site

**Benefits of Adopting an EMS**

Benefits of implementing an EMS were reported by each participant
transit agency and are documented in individual case studies found in
***[Appendix "A"]{.underline}***. Reported benefits include:

-   Improved relationships with state and federal regulators;

-   Enhanced public image with system users and the general public;

-   Improved employee awareness of potential environmental impacts of
    work activities;

-   Improved communications and cooperation through training and
    outreach;

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-   Increased management awareness of environmental issues;

-   Reinforcement of environmental processes currently in place;

-   Proactive management systems for environmental issues;

-   Documentation of standard operating procedures;

-   Institutionalization of best practices in and permanent improvements
    of on-time performance;

-   Increased fuel economy;

-   Reduction of air emissions; and

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-   Reduction of amount of oil in waste water.

**Cost Savings**

Cost savings and cost avoidances are identified in each agency case
study. Examples of documented cost savings:

  --------------------- ---------------------------------- --------------
  **Agency**            **Efficiency**                     **Annual
                                                           Savings**

  **Hampton Roads       Bus Idling Shutdown Campaign       \$140,400
  Transit**                                                

  **MBTA**              Bus Idling Monitoring Campaign     \$116,553

  **City of Phoenix     Reduced energy use                 \$49,000
  Transit**                                                

                        Switched to solvent-based parts    
                        washer                             
  --------------------- ---------------------------------- --------------

+--------------------+----------------------------------+-------------+
| **Agency**         | **Efficiency**                   | **Annual    |
|                    |                                  | Savings**   |
+--------------------+----------------------------------+-------------+
| **Transit Agency   | Natural Gas reduction campaign   | \$15,000    |
| of River City**    | and                              |             |
|                    |                                  |             |
|                    | 270,000 reduction in kilowatt    |             |
|                    | hours                            |             |
+--------------------+----------------------------------+-------------+
|                    | Emissions Reductions             | CO2=906,802 |
|                    |                                  | lb/yr       |
|                    |                                  |             |
|                    |                                  | SO2=1,425   |
|                    |                                  | lb/yr       |
|                    |                                  |             |
|                    |                                  | NOx=945     |
|                    |                                  | lb/yr       |
+--------------------+----------------------------------+-------------+
| **Utah Transit     | Idling fuel savings policy       | \$675,000   |
| Authority**        |                                  |             |
+--------------------+----------------------------------+-------------+
|                    | Idling labor savings             | \$63,000    |
+--------------------+----------------------------------+-------------+
|                    | Emission Reductions              | PM=2,484    |
|                    |                                  | lb/yr       |
|                    |                                  |             |
|                    |                                  | NOx=91,125  |
|                    |                                  | lb/yr       |
|                    |                                  |             |
|                    |                                  | CO2=3,037,  |
|                    |                                  | 500 lbs/yr  |
+--------------------+----------------------------------+-------------+
|                    | Addressing print shop            | \$72,000    |
|                    | environmental issues             |             |
+--------------------+----------------------------------+-------------+
|                    | Industrial waste savings (one    | \$500,000   |
|                    | time)                            |             |
+--------------------+----------------------------------+-------------+
|                    | Recycle used oil                 | \$4,000     |
+--------------------+----------------------------------+-------------+
|                    | **Grand Total** calendar 2005    | \$1,300,000 |
+--------------------+----------------------------------+-------------+
|                    | Annualized savings each year in  | \$814,000   |
|                    | future                           |             |
+--------------------+----------------------------------+-------------+
| **Bay Area Rapid   | Reduced costs by puncturing and  | \$15,740    |
| Transit**          | disposing of aerosol cans        |             |
+--------------------+----------------------------------+-------------+
|                    | Reduced use of aerosol           |             |
|                    | insecticide product              |             |
+--------------------+----------------------------------+-------------+
|                    | Reduced cost of recycling vs.    |             |
|                    | landfilling of creosote crosstie |             |
+--------------------+----------------------------------+-------------+

**Senior Management Comments**

Senior Management's dedication to the development and implementation of
the EMS was noteworthy as demonstrated by the following excerpts from
the case studies in **[Appendix "A"]{.underline}:**

-   "...BART has always been environmentally aware, but EMS gives us the
    tools to set goals, monitor performance, and report results to the
    key decision makers at the agency."

> **John Mack, BART Executive Manager, Transit System Compliance**
>
> ****

-   "The EMS program fits well into Community Transit's core values
    because it establishes clear priorities and sets realistic goals to
    provide a safe and clean workplace; it also adds to the quality of
    life for citizens in our community."

> **Joyce Olson, CEO, Community Transit**
>
> ****

-   "The EMS is one of my key strategic initiatives because it provides
    us with a disciplined framework for meeting our environmental
    responsibilities and allows us to continually improve our
    organizational performance."

> **Daniel A. Grabauskas, GM, MBTA**
>
> ****

-   "The EMS provides us with a ready-made and internationally
    recognized program that can be tailored to our needs."

> **Vernon Stoner, Deputy CEO, Sound Transit**

-   "Strong environmental management makes 'green' sense but it also
    makes good business sense. TARC intends to treat this as seriously
    as we treat our other requirements, such as Affirmative Action and
    EEOC compliance. With funding tight and gas prices rising, it will
    be more essential than ever for TARC to cut costs and run
    efficiently. The EMS helps us move in that direction."

> **J. Barry Barker, TARC, Executive Director**
>
> ****

-   "The Environmental Management System (EMS) is a lifestyle change we
    are integrating into our everyday approach of doing business"

> **George Caria, GM, Sun Tran**
>
> ****

-   "UTA's Environmental Management System helps managers identify
    harmful environmental impacts of our projects, services and
    activities and finding ways to resolve and prevent these impacts.
    The implementation of an Environmental Management System is not just
    a requirement\--it's a good idea. It supports our credo to provide a
    good transportation value for a better quality of life."

> **John Inglish, GM, UTA**
>
> ****

-   "Environmental management is an individual, as well as collective
    responsibility. The EMS is an effective tool for employees to use
    together to establish new goals and implement new programs to
    protect the community and the environment for future generations."

> **Debbie Cotton, Public Transit Department Director, City of Phoenix**
>
> ****

-   "The EMS is an effective 'grass roots' method for implementing
    WMATA\'s environmental policy and programs. The FTA/Virginia Tech
    assistance gave us the vehicle to move our policy from paper to a
    functioning program at the Greenbelt Yard. \"

> **Fred Goodine AGM, WMATA**

**The Federal Transit Administration Effort**

In the summer of 2003, the FTA Administrator issued a *Dear Colleague*
letter to 100 transit agencies throughout the United States with the
highest ridership levels inviting them to apply for the FTA sponsored
training for implementing an EMS. FTA\'s initiative of EMS training for
public transit agencies supports President's Bush's Executive Order
13148 *Greening the Government* initiative. Additionally the FTA
initiative supports Executive Order 13274 *Environmental Stewardship and
Transportation Infrastructure Project Reviews*, which directs Federal
agencies to promote environmental stewardship in the nation\'s
transportation system while streamlining the environmental review and
development of proposed transportation projects.

FTA believes that EMS is a valuable tool and desired to introduce the
doctrine of environmental management system on a voluntary basis to a
pilot group within the public transit sector. ISO 14001 served as the
basis of EMS training. FTA left ISO 14001 certification by an outside
3^rd^ party auditor to the discretion of the individual agencies.

**Selection Methodology**

In December 2003, after receiving applications and completing
interviews, FTA selected ten of the applicant agencies to participate in
the training. FTA used a number of criteria to select participants,
including:

-   Organizational commitment by transit agency leadership to EMS
    implementation;

-   Geographical diversity;

-   Previous environmental experiences; and

-   Environmental challenges from operations and/or pending capital
    projects.

FTA believed that organizational commitment to environmental protection
and sustainability were the most important elements of the program and
that regular and meaningful senior management participation was crucial
to successful EMS implementation. With this in mind, FTA selected the
following agencies to participate in the training:

+---------------------------------+------------------------------------+
| **Public Transit Agency**       | **Fenceline**                      |
+---------------------------------+------------------------------------+
| **Massachusetts Bay             | **Wellington Carhouse Maintenance  |
| Transportation Authority**      | Facility (rail)**                  |
|                                 |                                    |
| **Boston, MA**                  | **Albany Bus Garage Facility**     |
+---------------------------------+------------------------------------+
| **Washington Metropolitan Area  | **Greenbelt Rail Yard**            |
| Transit Authority, DC**         |                                    |
+---------------------------------+------------------------------------+
| **Hampton Roads Transit,        | **HQ Maintenance and Operations    |
| Hampton, VA**                   | Facility**                         |
+---------------------------------+------------------------------------+
| **Transit Authority of River    | **Union Station Bus Maintenance**  |
| City, Louisville, KY**          |                                    |
+---------------------------------+------------------------------------+
| **Bay Area Rapid Transit,       | **Richmond Shop and Yard**         |
| Oakland, CA**                   |                                    |
+---------------------------------+------------------------------------+
| **Utah Transit Authority, Salt  | **Meadowbrook Maintenance          |
| Lake City, UT**                 | Division**                         |
+---------------------------------+------------------------------------+
| **Sound Transit, Seattle, WA**  | **Sound Transit Environmental      |
|                                 | Compliance Division**              |
+---------------------------------+------------------------------------+
| **Community Transit, Everett,   | **Kasch Park Operating Base**      |
| WA**                            |                                    |
+---------------------------------+------------------------------------+
| **City of Phoenix, AZ**         | **South Operating Facility**       |
+---------------------------------+------------------------------------+
| **City of Tucson, AZ**          | **Bus Maintenance Facility**       |
+---------------------------------+------------------------------------+

Selected agencies ranged from medium sized agencies with bus and
paratransit services to agencies with large, complex operations
including ferry services, heavy rail, commuter rail and bus rapid
transit. Participating transit organizations faced a variety of
environmental challenges including one local transit participant that
was operating under a consent decree from EPA to develop an agency wide
EMS.

Training teams from transit agencies were comprised of four to seven
staff members. Teams intentional included management, operational and
mechanical personnel in an attempt to create support for the EMS through
all organizational levels. A special effort was made to include trade
unionists in an attempt to harness shop-floor loyalties to development
and implementation of the EMS.

**Project Outline**

The Center for Organizational and Technological Advancement (COTA) at
Virginia Polytechnic Institute and State University was selected by FTA
to support efforts of training and assistance under a cooperative
agreement. On behalf of the FTA, COTA developed a Memorandum of
Understanding (MOU) with each of the transit agencies that outlined the
roles and responsibilities of all the parties. The MOU was signed by the
parties prior to the beginning of training. It was the expectation of
FTA that each of the transit agencies would utilize the training and
implement an ISO 14001 EMS at the facility of choice and that COTA would
audit the degree of implementation at the end of the 24 month
initiative. FTA required that ISO 14001 serve as the basis of the EMS
training, although it would be at the discretion of the individual
agencies to pursue ISO certification.

FTA modeled the initiative after a successful Environmental Protection
Agency (EPA) program called *EMS Initiative for Governmental Agencies.*
FTA and COTA structured the two year program to address specific
environmental requirements of transit agencies. Local transit agencies
paid for their travel, room and board and FTA funded all contractor
training and assistance including technical support site visits to the
participating agencies.

It was important to the FTA that participating agencies attempt to
demonstrate quantitative costs and benefits of the EMS implementation.
COTA required teams to track both internal and external costs such as
staff, managerial time and other employee time on a quarterly basis;
costs of potential consulting assistance and outside training of
personnel. COTA also asked teams to track benefits which could include
savings from improved environmental performance, enhanced environmental
compliance, cost reductions, pollution prevention and resource
conservation. Additional indirect benefits were expected to include
increased efficiencies, enhanced employee morale, an improved public
image and greater employee awareness of environmental issues and
responsibilities.

**FTA provided assistance in the form of**:

**[Baseline Environmental Reviews]{.underline}:** COTA, a Public Entity
EMS Local Resource (PEER) Center
([www.peercenter.net](http://www.peercenter.net/)) began its effort in
January 2004 with a one day visit to each participating agency to meet
with executive management and the core EMS team. The site visit included
a presentation of FTA expectations followed by the signing of the MOU,
briefing of workshop(s) curriculum and a one day environmental audit of
the agency's fenceline facility. Fencelines chosen by participants
typically included a bus or rail maintenance facility. One exception was
Sound Transit which had significant new facilities coming on line in its
Transit Plan. Sound Transit was interested in first developing an EMS
for its capital program.

During the baseline audit, COTA took note of a variety of physical
improvements as well as site storm water runoff, hazardous waste
disposition, water and energy usage, recycling efforts, waste
management, fuel storage and environmental permitting. A summary report
of the environmental findings was prepared by COTA for each agency and
provided as background material in advance of Workshop #1.

**[EMS Training Workshops]{.underline}**: Four 3-day workshops were held
over a 10 month period at Virginia Tech's Roanoke, Virginia training
facility.

1.  Workshop \# 1: March 2004

2.  Workshop \# 2: June 2004

3.  Workshop \# 3 : September 2004

4.  Workshop \# 4: December 2004

Ten teams came to Roanoke for each of the four workshops. Approximately
one fourth of the 17 basic elements of ISO 14001 were presented at each
workshop. The COTA concept was to introduce the ISO Standards, provide
transit specific case studies to practice implementation, and then send
the teams back to their locality for a 4 month implementation period.

The ISO 14001 implementation strategy included selecting individualized
environmental objectives and targets based upon agency need and rigorous
homework requirements. Each team received one copy of GreenWare
software. GreenWare software included a comprehensive set of worksheets,
procedures and operational controls for implementing an ISO 14001 EMS,
and step-by-step detailed workflow, calendaring and task management
features. Finally, the software included detailed sample EMS procedures
for every section of ISO 14001 which were easily modified to meet
specific user needs.

On site training was supported by regular conference calls with
individual participant team, COTA and the FTA project manager.
Conference calls helped identify problems teams might be having
implementing workshop homework. As a condition of participation, all
teams were required to hold regular agency EMS meetings, maintain good
meeting minutes and regularly brief senior management on the progress of
their EMS.

The FTA project manager held quarterly senior manager conference calls
with agency upper management in an effort to maintain a high level of
management support for the implementation efforts and to address
intra-agency roadblocks. As the project went forward, these calls were
the critical component in sustaining the momentum of the EMS core teams.

**[Post Workshop Activities]{.underline}**: Homework assignments were to
be completed by May 1, 2005. COTA scheduled a two-day site visit to each
agency to conduct an EMS pre-assessment. Two to four months later, COTA
returned to each agency to conduct a formal two day EMS-audit, utilizing
GreenWare\'s ISO 14001 Audit software. This software enabled a qualified
Virginia Tech ISO 14001 auditor to verify and document systematically
the degree to which each transit agency has an EMS in place in
conformance with the audit criteria set out in *ISO 14010, Guidelines
for Environmental Auditing - General Principles of Environmental
Auditing and ISO 14011, Guidelines for environmental auditing - Audit
procedures - Auditing of environmental management systems*. The tenth
and final EMS Audit was completed on October 24, 2005. Final scoring
from the COTA EMS Audit is provided for each agency at the end of each
case study found in Appendix "A".

The 10 transit agencies produced their initial EMS case studies
documenting the organizations efforts related to their obligations
outlined in the MOU. Case studies include:

-   Narrative outlining their participation in the program;

-   Costs and benefits of EMS implementation;

-   Documentation on hours spent implementing the EMS;

-   Statement of benefits of adopting an EMS;

-   Cost savings and cost avoidances;

-   Next steps for the EMS in the agency; and

-   Statement of management commitment to sustain the EMS.

**What is an EMS?**

An Environmental Management System (EMS) is a set of processes and
practices that enable an organization to reduce its environmental
impacts and increase its operating efficiency. Organizations with an EMS
report being able to more effectively manage their environmental
obligations. Additionally, organizations report enhanced ability to
analyze, control and reduce environmental impacts, and to operate with
greater efficiency and control.

Additional program benefits include cost savings over time, improved
bond ratings, reduced insurance premiums, and better community
relations. An EMS integrates the environmental ethic into business
operations, and environmental stewardship becomes part of the daily
organizational responsibility.

An EMS is appropriate for organizations of varying size in public and
private sectors. From start to finish, a two-year timeframe is suggested
for the EMS implementation process. However, the process can be
shortened or extended based upon the organizational culture and needs.

FTA transit participants utilized the 17 elements ISO 14001
International Standard Reference number ISO: 1996(E). Working
definitions of the 17 elements are as follows:

1.  **[Environmental Policy]{.underline}**: Statement by the
    organization of its intentions and principles in relation to its
    overall environmental performance. The Environmental Policy is the
    driver for implementing and improving the organizations
    environmental management system so that it can maintain and
    potentially improve it environmental performance.

2.  **[Environmental Aspects]{.underline}**: Elements of an
    organization's activities, products and services that can interact
    with the environment. Consideration should be given to normal and
    abnormal operations within the organization and to potential
    emergency conditions.

3.  **[Legal and Other Requirements]{.underline}**: Element is heavily
    focused on all regulatory obligations legislated by local, state and
    federal environmental enforcement agencies as well as other
    requirements that subscribe to industry codes of practice and
    agreements with public authorities.

4.  **[Objectives and Targets]{.underline}**: Element requires that once
    the agency's aspects have been deemed significant, to set objectives
    and targets that are measurable and in concert with the
    Environmental Policy.

5.  **[Environmental Management Programs]{.underline} (EMP)**: Element
    requires organization to establish a program to complete Objectives
    and Targets for each of its significant aspects as well as the means
    and time frame by which they are to be achieved.

6.  **[Structure and Responsibility]{.underline}**: Element requires
    organization to define, document and communicate roles,
    responsibility and authorities to implement the EMS. Roles refer to
    appointing specific management representative(s) who have
    responsibility for ensuring the ongoing implementation of the EMS as
    well as reporting the performance of the EMS to top management.

7.  **[Training, Awareness and Competence]{.underline}**: Element
    requires the identification of training needs and requires that all
    personnel whose work may impact the environment, in regards to their
    environmental duties and activities, receive specific and
    appropriate training.

8.  **[Communication]{.underline}**: Element requires organization to
    insure that procedures be established and maintained that assure
    good internal communication between the various levels and functions
    of the organization as well as receiving, documenting and responding
    to relevant communications from external interested parties.

9.  **[Documentation]{.underline}**: Element requires the agency to
    establish and maintain information in paper or electronic format to
    describe the management system.

10. **[Document Control]{.underline}**: Organization is required to
    establish and maintain procedures for controlling all documents and
    assure that documents can be located, periodically reviewed, revised
    and approved by authorized personnel.

11. **[Operational Control]{.underline}**: Element requires the
    establishment and maintenance of documented procedures to cover
    operations where the absence of procedures could lead to deviations
    from the environmental policy and the objectives and targets.

12. **[Emergency Preparedness and Response]{.underline}:** Element
    requires the establishment and maintenance of procedures to identify
    potential for and response to accidents and emergency situations and
    periodically test the procedures where practicable.

13. **[Monitoring and Measurement]{.underline}:** The organization
    establishes and maintains documented procedures to monitor and
    measure the key characteristics of its operations and activities
    that have a significant impact on the environment. The organization
    commits to monitor the calibration and maintenance of its equipment
    and ensures that procedures are in place that requires periodic
    evaluation of compliance with environmental legislation.

14. **[Nonconformance, Corrective and Preventive action]{.underline}:**
    The organization establishes and maintains procedures for defining
    responsibility and authority for handling and investigating
    nonconformance and taking action to mitigate any impacts caused.
    Additionally, the element requires a further review to identify
    preventive actions to eliminate nonconformances.

15. **[Records]{.underline}:** The organization is required to develop
    procedures that will establish and maintain the identification,
    maintenance and disposition of environmental records, training
    records, and the results of audits and reviews.

16. **[EMS Audits]{.underline}:** The internal EMS audit evaluates the
    adequacy of documents, procedures, programs, and records and reviews
    the implementation, integration, and consistency of procedures and
    programs at that moment.  It looks at the organization's planned
    activities for meeting its objectives and targets, its control of
    significant aspects, and pollution prevention accomplishments.  It
    looks for evidence of management's commitment to the environmental
    policy and the EMS, and awareness and competency among
    employees.  Finally the audit has a look at how the organization is
    fulfilling its commitment to continual improvement. Results of
    internal audits are ***part of,*** not a substitute for the
    management review process.

17. **[Management Review]{.underline}:** The EMS core team ensures that
    the management review addresses the possible need for changes to
    policies, objectives and other element of the EMS, in light of EMS
    audit results, changing circumstances and the commitment to
    continual improvement. Senior management must be informed on the
    progress of objectives and targets as well as results of internal
    EMS audits. Senior management will then review the recommendations
    from the EMS Team for suitability, adequacy and effectiveness. The
    frequency of Management Review is recommended
    [quarterly]{.underline} during the first two years of the EMS
    implementation to keep Senior Management informed and engaged with
    the process of setting and tracking progress on the Objectives,
    Targets and Programs and monitoring the results of Audits.

**Four Phases of EMS**

A four-phased implementation process (four workshop series) was utilized
and ultimately provided a successful model for manageable implementation
of the EMS elements/requirements. Most EMS are built on the \"Plan, Do,
Check, Act\" model. This model leads to continual improvement based
upon:

**PLAN[\
]{.underline}**Planning, including identifying environmental aspects and
establishing goals

**DO[\
]{.underline}**Implementing, including training and operational controls

Framework

**CHECK**

Checking, including monitoring and corrective action

**ACT**

Reviewing, including progress reviews and acting to make needed

changes to the EMS

**Benefits of EMS**

EMS can result in both business and environmental benefits. For example,
an EMS may help you:

-   Improve environmental performance;

-   Enhance compliance;

-   Prevent pollution and conserve resources;

-   Reduce/mitigate risks;

-   Increase efficiency;

-   Reduce costs;

-   Enhance employee morale and possibly enhance recruitment of new
    employees;

-   Enhance image with public, regulators, lenders, investors; and

-   Achieve/improve employee awareness of environmental issues and
    responsibilities.

***Appendix "A"*** contains 10 participant transit agency case studies.
The case studies delineate in detail the individual accrued benefits
documented by the participant transit agencies.

**Resource Commitments**

The Federal Transit Agency required COTA to track the financial and
human resources committed by each the 10 participating transit agencies.
Each agency submitted an individual case study (**Appendix B**).
Resources tracked throughout the project period included:

-   Number of direct labor hours committed to EMS implementation;

-   Dollar value of direct labor;

-   Travel related expenses; and

-   Consultant expenses.

+------------------------------------------+--------------+------------+
|    **Transit Agency**                    | **Direct     | **Payroll  |
|                                          | Labor        | Value**    |
|                                          | Hours**      |            |
+------------------------------------------+--------------+------------+
| **Massachusetts Bay Transportation       |              |            |
| Authority**                              |              |            |
+------------------------------------------+--------------+------------+
| Core Team Hours                          | 2610         | \$ 163,600 |
|                                          |              |            |
| Sub Team Hours                           | 2532         |            |
|                                          |              |            |
| Other Personnel Hours                    | 95           |            |
+------------------------------------------+--------------+------------+
| Consultant/Training Hours                | 695          | 52,194     |
+------------------------------------------+--------------+------------+
| Travel to EMS Training and supplies      |              | 50,617     |
+------------------------------------------+--------------+------------+
| **Washington Metropolitan Area Transit   |              |            |
| Authority**                              |              |            |
+------------------------------------------+--------------+------------+
| Core Team Hours                          | 1535         | 150,670    |
|                                          |              |            |
| Sub Team Hours                           | 223          |            |
|                                          |              |            |
| Employee Training Hours                  | 560          |            |
+------------------------------------------+--------------+------------+
| Consultant Hours                         | 670          | 48,127     |
+------------------------------------------+--------------+------------+
| **Hampton Roads Transit, VA**            |              |            |
+------------------------------------------+--------------+------------+
| Core Team Hours                          | \*789        | not        |
|                                          |              | available  |
+------------------------------------------+--------------+------------+
| **Transit Authority of River City, KY**  |              |            |
+------------------------------------------+--------------+------------+
| Core Team Hours                          | 615          | 19,875     |
+------------------------------------------+--------------+------------+
| **Bay Area Rapid Transit, CA**           |              |            |
+------------------------------------------+--------------+------------+
| Core Team Hours                          | 1127         | 145,655    |
|                                          |              |            |
| Staff Support Hours                      | 2040         |            |
+------------------------------------------+--------------+------------+
| **Utah Transit Authority, UT**           |              |            |
+------------------------------------------+--------------+------------+
| Core Team Hours                          | 1549         | 72,946     |
|                                          |              |            |
| Other Hours                              | 279          |            |
+------------------------------------------+--------------+------------+
| **Sound Transit, WA**                    |              |            |
+------------------------------------------+--------------+------------+
| Core Team Hours                          | 2715         | \* 233,447 |
|                                          |              |            |
| Sub Team Hours                           | 635          | includes   |
|                                          |              | travel     |
|                                          |              | costs/time |
+------------------------------------------+--------------+------------+
| **Community Transit, WA**                |              |            |
+------------------------------------------+--------------+------------+
| Core Team Hours                          | 1926         | 77,740     |
|                                          |              |            |
| Sub Team Hours                           | 114          |            |
+------------------------------------------+--------------+------------+
|                                          |              |            |
+------------------------------------------+--------------+------------+
| **City of Phoenix, AZ**                  |              |            |
+------------------------------------------+--------------+------------+
| Core Team and Sub Team Hours             | 2530         | 101,700    |
+------------------------------------------+--------------+------------+
| **City of Tucson, AZ**                   |              |            |
+------------------------------------------+--------------+------------+
| Internal Labor                           | 2631         | \$ 92,085  |
+------------------------------------------+--------------+------------+
| Travel                                   |              | 14,102     |
+------------------------------------------+--------------+------------+
| Other                                    |              | 1200       |
+------------------------------------------+--------------+------------+
| **Average Per Participant**              | **Average    | **Average  |
|                                          | Direct Labor | Payroll    |
|                                          | Hours 2,635  | Value      |
|                                          | hours**      | \          |
|                                          |              | $126,125** |
+------------------------------------------+--------------+------------+

Direct Labor hours listed above were tracked by each agency on a
quarterly basis. In each case, direct labor hours can be placed in two
categories.

-   **[Category I Direct Labor]{.underline}**: Staff hours for EMS Core
    Team dedicated to learning, practicing and implementing the 17
    elements of the ISO 14001 EMS Standards. Prior to entry in the FTA
    sponsored EMS initiative, most of the 10 transit organizations had
    little formal knowledge of the ISO 14001 Environmental Management
    System.

Transit agencies spent significant time learning, practicing and
implementing:

1.  The ISO 14001 Standard

2.  Conducting comprehensive Legal and Other research

3.  Ranking and selecting 4-6 Significant Aspects

4.  Creating policies and procedures for each of the 17 elements

5.  Creating Environmental Management Programs or work procedures to
    guide and measure their significant aspects, and implementing a
    formal system of documentation and document control

-   **[Category II Direct Labor]{.underline}**: Training directed at the
    line employee work force plays a significant role in the long term
    sustainability of the EMS. Transit agencies sponsored considerable
    training to familiarize both existing and new employees on the
    purpose and benefits of an EMS. Agencies tracked specific EMS
    training hours related to their "Objectives and Targets" and
    Environmental Management Programs. Transit agencies were already
    obligated by state and federal law to properly train their workforce
    on environment related legal obligations. Because this was training
    that already should be part of their annual training plan, the hours
    in this category may have inflated the overall EMS implementation
    direct labor hours.

**Keys to Successful Implementation**

**[EMS Core Team]{.underline}:** FTA required each team to be organized
around a minimum of 4 persons. A number of agencies created core teams
made of six to eight individuals. Having sufficient manpower to learn
the ISO elements, practice them on transit specific case studies and
then to return home to implement after each workshop was critical to the
success of the EMS.

Virginia Tech identified a skill set for an **ideal EMS team** and
guided the FTA teams to create their teams based on:

> **Top Management Representative:** This person should be top
> management's representative and have the authority and responsibility
> to ensure that the EMS is fully implemented through the Virginia Tech
> program. This team member would travel to and participate in all four
> of the Virginia Tech workshops with the three individuals recommended
> below.
>
> **Environmental Champion***:* This person should be:

-   An excellent communicator;

-   A respected leader;

-   Technically competent regarding EMS;

-   Experienced at delegation

-   Experienced at implementing change;

-   Knowledgeable at conducting systems audits; and

-   Capable of transferring information learned and developed at the
    workshops back to the facility/department.

 

> **Operations Manager, Superintendent or Supervisor**: This person
> should have the following characteristics:

-   Strong knowledge of all facility/department operations;

-   Respected by the organization;

-   Possess strong communication skills;

-   Effective at delegation;

-   Exhibit leadership characteristics; and

-   Possess the management authority to implement changes as necessary.

 

**Administrative Person**: This person should have the following
characteristics:

-   Excellent computer skills;

-   Aptitude to learn software;

-   Be organized and project oriented;

-   Be diligent;

-   Portray effective communication skills;

-   Aptitude for conducting audits; and

-   Have an environmental interest.

**[Senior Management Support]{.underline}**: The interest and support of
senior management proved critical to the success of EMS implementation.
FTA required a formal commitment by senior management to conduct a
quarterly management review of the team's homework prior to returning to
workshops 2-4. More importantly, FTA required the 10 transit agency
senior management representatives to participate in an FTA conference
call one week prior to workshops 2-4. Two categories of critical
questions were asked:

1.  Are you satisfied with the quality of instruction provided by
    Virginia Tech? Do you have any concerns or requests for change in
    the format of the program?

2.  Is your team completing their assigned homework? Are you discussing
    barriers to EMS implementation and are you coaching them how to
    overcome barriers or if necessary, intervening on their behalf?

**[Objectives and Targets]{.underline}**: FTA urged teams to select
measurable objectives and to chart their progress based on valid
baseline data. Relevant Objectives and Targets are critical to long term
success of the EMS. Senior Management discussed and approved this
element at an early stage, and they tracked the progress of the steps
necessary to achieve the objectives through quarterly management review
sessions.

**[EMS Audits]{.underline}:** Along with the above, auditing the
progress of the EMS was absolutely necessary in insuring ongoing
progress of the EMS. The results of the audit drive the continual
improvement effort that is the centerpiece of EMS.

**[Management Review:]{.underline}** Regular participation by Senior
Management in the development and progress of the EMS is extremely
important to its success. FTA required this effort as a condition of
participation. Both COTA staff and FTA believe that s**enior management
participation in management review was a crucial factor in the success
of the participating agencies.**

**Senior Management EMS Comments**

Excerpts from individual transit agency case studies:

*"The discipline required through the EMS process is critical to the
successful implementation of this program. BART has always been
environmentally aware, but EMS gives us the tools to set goals, monitor
performance, and report results to the key decision makers at the
agency."*

**John Mack, Executive Manager, Transit System Compliance, BART**



***"**The FTA/ Virginia Tech approach in routinely involving me in
performance reviews with the Team was an excellent motivator for me to
get involved with the process and provide support as needed. I strongly
recommend that future training sessions use this approach, and if
possible, FTA should consider reconvening the teams of the recent
session for a 'lessons learned' reunion in 12 to 18 months."*

**Paul Oversier, Assistant General Manager, Operations BART**



*"Community Transit is committed to protecting the environment. As
responsible stewards of the public's resources, we are also committed to
using cost effective management practices in our environmental
programs."*

*The EMS program fits well into Community Transit's core values because
it establishes clear priorities and sets realistic goals to provide a
safe and clean workplace; it also adds to the quality of life for
citizens in our community.*

*Our employees are proud to work here because of the outstanding service
we provide, and that pride is evident in the care they take while doing
their jobs. EMS is a strong tool to help our employees do their jobs
well and it encourages everyone to contribute to our environmental
stewardship obligation."*

**Joyce Olson, Chief Executive Officer, Community Transit**



"The EMS is one of my key strategic initiatives because it provides us
with a disciplined framework for meeting our environmental
responsibilities and allows us to continually improve our organizational
performance."

**Daniel A. Grabauskas, General Manager, Massachusetts Bay
Transportation Authority**



"Since Sound Transit was created in 1996, our staff has hit the ground
running to deliver projects that have both aggressive schedules and
expectations. Our agency has grown in a very short time from having no
dedicated environmental staff to a 6-person Environmental Compliance
Division that provides environmental expertise during all phases of
capital project development. It's been very challenging to take the time
to address the "pro-active" side of managing the division while
constantly reacting to the demand for environmental expertise and
services.  Although our agency has an excellent environmental record, we
had been looking for ways to take our environmental program to the next
level.  When FTA offered technical training to develop an EMS, it
provided the catalyst we needed to create some structure and
institutional longevity. The other appeal of the EMS for us is that we
didn't have to start developing something from scratch.  The EMS
provides us with a ready-made and internationally recognized program
that can be tailored to our needs. 

We took an innovative approach to EMS by applying it to our capital
program rather than an operating facility. We feel that this EMS is
vitally important to our agency, and CEO Joni Earl and I are absolutely
committed to its successful implementation."

Vernon Stoner, Deputy CEO, Sound Transit



*"Strong environmental management makes 'green' sense but it also makes
good business sense. TARC intends to treat this as seriously as we treat
our other requirements, such as Affirmative Action and EEOC compliance.
With funding tight and gas prices rising, it will be more essential than
ever for TARC to cut costs and run efficiently. The EMS helps us move in
that direction."*

**J. Barry Barker, Executive Director Transit Authority of River City**



*"The Environmental Management System (EMS) is a lifestyle change we are
integrating into our everyday approach of doing business. We are
dedicated to incorporating the principals of EMS, and to improve our
stewardship and reduce the impacts to our environments in all activities
and services we provide."*

**George Caria, General Manager, Sun Tran**



*"Utah Transit Authority is working to further develop its Environmental
Management System and to be one of the first public transit agencies in
the nation to become certified with the International Standards
Organization's ISO 14001 principles. This is a proven, effective
organizational tool that provides a framework for managing environmental
responsibilities so they become more efficient and more integrated into
our overall business operations. The EMS is a business management tool
for any organization."*

**John Inglish, General Manager, UTA**



"Environmental management is an individual, as well as collective
responsibility. The EMS is an effective tool for employees to use
together to establish new goals and implement new programs to protect
the community and the environment for future generations".

**Debbie Cotton, Public Transit Department Director, City of Phoenix**



*"The EMS is an effective 'grass roots' method for implementing WMATA\'s
environmental policy and programs. The FTA/Virginia Tech assistance gave
us the vehicle to move our policy from paper to a functioning program at
the Greenbelt Yard.\"*

**Fred Goodine, Assistant General Manager**

**Department of Safety and Risk Protection, WMATA**

**Appendix "A"**

**Case Studies**

**Bay Area Rapid Transit 20**

**Community Transit 29**

**Hampton Roads Transit 40**

**Massachusetts Bay Transportation Authority 48**

**City of Phoenix, Public Transit Department 58**

**Sound Transit 66**

**Transit Authority of River City 76**

**Department of Transportation -- Sun Tran, City of Tucson 84**

**Utah Transit Authority 94**

**Washington Metropolitan Area Transit Authority 104**

![](media/image4.png){width="0.9881944444444445in"
height="0.6069444444444444in"}San Francisco Bay Area Rapid Transit
District (BART)

# Oakland, CA

Profile

The San Francisco Bay Area Rapid Transit District (BART) is a high-speed
inter-city and metropolitan rail transit system. It consists of 43
stations and over 100 miles of trackway in four counties. It provides
transit service to patrons in the Bay Area region including more than a
hundred municipalities. BART is the backbone of the regional and local
transportation network.

![](media/image5.png){width="3.376388888888889in"
height="3.376388888888889in"}BART was born over 40 years ago when civic
leaders of the Bay Area had the foresight to recognize the importance of
preserving the environment of the Bay Area. In the 1957 final report of
the San Francisco Bay Area Rapid Transit Commission, this concern was
emphatically expressed by the following:

*["If the Bay Area is to be preserved as a fine place to live and work,
a regional transit system is essential to prevent total dependence to
automobiles and freeways."]{.underline}*

Today BART delivers over 300,000 daily riders. BART has become an
essential part of the region's economy and quality of life.

A nine member elected board governs BART. Each board member represents a
geographical area within the three original counties of San Francisco,
Alameda, and Contra Costa, which BART serves. A fourth county, San Mateo
is served by special agreement. The Board sets the policy and direction
for the agency. The General Manager, Chief Counsel,
Treasurer/Controller, and District Secretary are appointed by the Board
to carry out its direction and run the agency. BART employs
approximately 3500 people.

BART's operating Budget for FY 2005 is \$412 million. BART fare revenue
contributes about 60%, with the remainder coming from a dedicated
3-county sales tax and a small property tax increment.

Fenceline

BART currently runs regional passenger rail service over five routes
with a fleet size of 669 revenue vehicles. To support operations, the
District has four yard and shop facilities: Concord, Richmond, Daly
City, and Hayward. BART employs the "captive fleet" concept, in which
under normal circumstances, a given car is stored and maintained only by
the yard and shop facility to which it is assigned. The BART EMS Team
selected The Richmond Yard and Shop as the EMS Fenceline project site.
Richmond is the largest, and busiest, of the BART yards with a fleet
size of 220 vehicles and responsibility for 33% of the systems daily
dispatches.

![](media/image6.png)

While the primary function of the yard and shop is to receive and
dispatch revenue ready vehicles from and to the mainline, support
operations include, vehicle maintenance, vehicle cleaning, track
maintenance, train control maintenance, grounds keeping and
administrative support. More than 600 employees report to the Richmond
Yard.

Facilities supporting yard operations include:

A.  Transportation Building -- Headquarters for yard administrative
    functions.

B.  Yard Control Tower -- Center for management and control of train
    movement in the yard

C.  Car Wash Building -- Exterior Car washer.

D.  Traction Power Substation and Gap Breaker Station -- A fenced area
    containing electrical equipment supplying 1000 V dc power to the
    third rail system in the yard.

E.  Employee Parking -- lot sized for approximately 150 employees.

F.  Storm Drain System -- surrounding facility with discharge to San
    Francisco Bay.

G.  Shop Facilities -- Facilities for all maintenance activities related
    to the revenue vehicle fleet including; preventive maintenance,
    unscheduled repair, component or fleet modification, and accident
    repair. Support facilities include:

    -   Main Repair Bay -- pit and vehicle lift locations for repair
        activity.

-   Truck Repair Area --equipped for the repair of truck assemblies
    including suspension, braking, traction pickup, bearings, draft
    gear, and other components.

-   Body Repair Area --for the heavy repair of vehicle structural and
    body skin damages

-   Wheel Truing Facility --located as an annex to the main shop
    building.

-   Other shop areas include parts storage, battery storage, and machine
    and welding shop.

```{=html}
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```
-   Blow Down Building -- structure for power wash of vehicle underside
    and components.

-   Car Cleaner's Facility -- A structure for dispatching cleaning crews
    and storage of cleaning supplies and equipment.

Core Team

The core team is made up of four members:

-   Tian Feng, District Architect,

-   James Dunn Chief Engineer, Maintenance and Engineering

-   Tamar Allen, Chief Mechanical Officer, Rolling Stock and Shops, and

-   Gary Jensen, Principal Environmental Engineer and lead for BART's
    EMS implementation.

#### 

#### Key Drivers for Adopting an EMS

The San Francisco Bay Area is a very environmentally conscious region.
Politicians, citizens, and our own employees hold high expectations that
BART will assume a leadership role in the preservation of the region's
environment. In 2002, BART established its Sustainability Policy to
guide the District in providing the Bay Area communities with resource
efficient, high quality and affordable transit service while furthering
the District's strong commitment to environmental preservation.

The Sustainability Policy establishes goals for sustainable practices in
all major areas of BART's business; planning, access, design,
construction, and operation and maintenance. As we began to explore
methods of fulfilling our operational sustainability commitment, we
found EMS to be a natural fit. EMS provided a formal management
structure for identifying and tracking environmental impacts,
opportunities for improvement, environmental performance, and
organizational as well as individual responsibility and accountability.

Beyond external political pressures, BART needed the EMS program to
harness employee environmental enthusiasm. Prior to adoption of an EMS
policy, we were keenly aware of our deficiencies and in need of a
mechanism for providing input and improvement. The EMS program has
provided this mechanism and employees are seizing the opportunity.

Here at BART we recognize that environmental performance is the key to
our legacy. Individually and collectively we want it to be a good
legacy. Therefore, we are willing to find better ways to do business in
an effort to make the world a better place for generations to come; to
create a world where our children are free to swim in the water, dig in
the dirt, breathe the air, and eat the fish.

## Significant Aspects & Impacts

![](media/image7.wmf)BART developed its aspects using teams representing
each functional area of our maintenance and shops departments. After
identifying aspects and impacts, the teams met with environmental staff
to refine the lists and begin grading.

Each aspect was evaluated using two matrices. The first, Environmental
Factors, evaluated the scale, severity, probability, and duration of the
impact. The second, Implementation Factors, evaluated legal exposure,
operational impacts, public image, degree of change, and human factors.
BART identified 80 aspects and selected 7 of them as significant
aspects.

+-------+---+-----------+--------------------------+-----------------+
| #     | * |           |                          | # **Poli        |
| **Asp | * |           |                          | cy Commitment** |
| ect** | U |           |                          |                 |
|       | n |           |                          |                 |
|       | d |           |                          |                 |
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|       | h |           |                          |                 |
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|       | r |           |                          |                 |
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|       | o |           |                          |                 |
|       | r |           |                          |                 |
|       | t |           |                          |                 |
|       | o |           |                          |                 |
|       | m |           |                          |                 |
|       | a |           |                          |                 |
|       | i |           |                          |                 |
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|       | t |           |                          |                 |
|       | e |           |                          |                 |
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|       | a |           |                          |                 |
|       | n |           |                          |                 |
|       | c |           |                          |                 |
|       | e |           |                          |                 |
|       | * |           |                          |                 |
|       | * |           |                          |                 |
+-------+---+-----------+--------------------------+-----------------+
| **Imp | H |           |                          | Pollution       |
| act** | e |           |                          | Prevention      |
|       | a |           |                          |                 |
|       | v |           |                          | Regulatory      |
|       | y |           |                          | Compliance      |
|       | m |           |                          |                 |
|       | e |           |                          |                 |
|       | t |           |                          |                 |
|       | a |           |                          |                 |
|       | l |           |                          |                 |
|       | c |           |                          |                 |
|       | o |           |                          |                 |
|       | n |           |                          |                 |
|       | t |           |                          |                 |
|       | a |           |                          |                 |
|       | m |           |                          |                 |
|       | i |           |                          |                 |
|       | n |           |                          |                 |
|       | a |           |                          |                 |
|       | t |           |                          |                 |
|       | i |           |                          |                 |
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|       | n |           |                          |                 |
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|       | u |           |                          |                 |
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|       | t |           |                          |                 |
|       | o |           |                          |                 |
|       | v |           |                          |                 |
|       | i |           |                          |                 |
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|       | l |           |                          |                 |
|       | a |           |                          |                 |
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|       | o |           |                          |                 |
|       | f |           |                          |                 |
|       | w |           |                          |                 |
|       | a |           |                          |                 |
|       | s |           |                          |                 |
|       | t |           |                          |                 |
|       | e |           |                          |                 |
|       | w |           |                          |                 |
|       | a |           |                          |                 |
|       | t |           |                          |                 |
|       | e |           |                          |                 |
|       | r |           |                          |                 |
|       | d |           |                          |                 |
|       | i |           |                          |                 |
|       | s |           |                          |                 |
|       | c |           |                          |                 |
|       | h |           |                          |                 |
|       | a |           |                          |                 |
|       | r |           |                          |                 |
|       | g |           |                          |                 |
|       | e |           |                          |                 |
|       | p |           |                          |                 |
|       | e |           |                          |                 |
|       | r |           |                          |                 |
|       | m |           |                          |                 |
|       | i |           |                          |                 |
|       | t |           |                          |                 |
|       | . |           |                          |                 |
+-------+---+-----------+--------------------------+-----------------+
| **    |   | Meet      |                          |                 |
| Objec |   | i         |                          |                 |
| tives |   | ndustrial |                          |                 |
| and   |   | waste     |                          |                 |
| Targ  |   | discharge |                          |                 |
| ets** |   | limits    |                          |                 |
|       |   | for       |                          |                 |
|       |   | metals in |                          |                 |
|       |   | 100% of   |                          |                 |
|       |   | tests.    |                          |                 |
|       |   | Meet      |                          |                 |
|       |   | bi        |                          |                 |
|       |   | ochemical |                          |                 |
|       |   | oxygen    |                          |                 |
|       |   | demand    |                          |                 |
|       |   | g         |                          |                 |
|       |   | uidelines |                          |                 |
|       |   | in 75% of |                          |                 |
|       |   | tests.    |                          |                 |
+-------+---+-----------+--------------------------+-----------------+
| **Env |   |           | # **Monit                |                 |
| ironm |   |           | oring and Measurement**  |                 |
| ental |   |           |                          |                 |
| Manag |   |           | ![](media/image8.png)    |                 |
| ement |   |           |                          |                 |
| Progr |   |           |                          |                 |
| ams** |   |           |                          |                 |
|       |   |           |                          |                 |
| S     |   |           |                          |                 |
| ource |   |           |                          |                 |
| iden  |   |           |                          |                 |
| tific |   |           |                          |                 |
| ation |   |           |                          |                 |
|       |   |           |                          |                 |
| R     |   |           |                          |                 |
| evise |   |           |                          |                 |
| cle   |   |           |                          |                 |
| aning |   |           |                          |                 |
| me    |   |           |                          |                 |
| thods |   |           |                          |                 |
|       |   |           |                          |                 |
| -     |   |           |                          |                 |
|    no |   |           |                          |                 |
|       |   |           |                          |                 |
|   che |   |           |                          |                 |
| mical |   |           |                          |                 |
|       |   |           |                          |                 |
|  comp |   |           |                          |                 |
| ounds |   |           |                          |                 |
|       |   |           |                          |                 |
| -     |   |           |                          |                 |
|    no |   |           |                          |                 |
|     m |   |           |                          |                 |
| otor- |   |           |                          |                 |
| brush |   |           |                          |                 |
|       |   |           |                          |                 |
|   cle |   |           |                          |                 |
| aning |   |           |                          |                 |
|       |   |           |                          |                 |
|    in |   |           |                          |                 |
|       |   |           |                          |                 |
|    bl |   |           |                          |                 |
| owpit |   |           |                          |                 |
|       |   |           |                          |                 |
| Incr  |   |           |                          |                 |
| eased |   |           |                          |                 |
| m     |   |           |                          |                 |
| ainte |   |           |                          |                 |
| nance |   |           |                          |                 |
+-------+---+-----------+--------------------------+-----------------+
| **O   |   |           |                          |                 |
| perat |   |           |                          |                 |
| ional |   |           |                          |                 |
| Contr |   |           |                          |                 |
| ols** |   |           |                          |                 |
|       |   |           |                          |                 |
| Blo   |   |           |                          |                 |
| wdown |   |           |                          |                 |
| Proc  |   |           |                          |                 |
| edure |   |           |                          |                 |
|       |   |           |                          |                 |
| Bl    |   |           |                          |                 |
| owpit |   |           |                          |                 |
| Cle   |   |           |                          |                 |
| anout |   |           |                          |                 |
| Proc  |   |           |                          |                 |
| edure |   |           |                          |                 |
+-------+---+-----------+--------------------------+-----------------+

+-------+---+-----------+--------------------------+-----------------+
| #     | * |           |                          | # **Poli        |
| **Asp | * |           |                          | cy Commitment** |
| ect** | G |           |                          |                 |
|       | r |           |                          |                 |
|       | a |           |                          |                 |
|       | f |           |                          |                 |
|       | f |           |                          |                 |
|       | i |           |                          |                 |
|       | t |           |                          |                 |
|       | i |           |                          |                 |
|       | R |           |                          |                 |
|       | e |           |                          |                 |
|       | m |           |                          |                 |
|       | o |           |                          |                 |
|       | v |           |                          |                 |
|       | a |           |                          |                 |
|       | l |           |                          |                 |
|       | u |           |                          |                 |
|       | s |           |                          |                 |
|       | i |           |                          |                 |
|       | n |           |                          |                 |
|       | g |           |                          |                 |
|       | A |           |                          |                 |
|       | e |           |                          |                 |
|       | r |           |                          |                 |
|       | o |           |                          |                 |
|       | s |           |                          |                 |
|       | o |           |                          |                 |
|       | l |           |                          |                 |
|       | C |           |                          |                 |
|       | l |           |                          |                 |
|       | e |           |                          |                 |
|       | a |           |                          |                 |
|       | n |           |                          |                 |
|       | e |           |                          |                 |
|       | r |           |                          |                 |
|       | s |           |                          |                 |
|       | * |           |                          |                 |
|       | * |           |                          |                 |
+-------+---+-----------+--------------------------+-----------------+
| **Imp | D |           |                          | Pollution       |
| act** | i |           |                          | Prevention      |
|       | s |           |                          |                 |
|       | c |           |                          |                 |
|       | h |           |                          |                 |
|       | a |           |                          |                 |
|       | r |           |                          |                 |
|       | g |           |                          |                 |
|       | e |           |                          |                 |
|       | o |           |                          |                 |
|       | f |           |                          |                 |
|       | v |           |                          |                 |
|       | o |           |                          |                 |
|       | l |           |                          |                 |
|       | a |           |                          |                 |
|       | t |           |                          |                 |
|       | i |           |                          |                 |
|       | l |           |                          |                 |
|       | e |           |                          |                 |
|       | o |           |                          |                 |
|       | r |           |                          |                 |
|       | g |           |                          |                 |
|       | a |           |                          |                 |
|       | n |           |                          |                 |
|       | i |           |                          |                 |
|       | c |           |                          |                 |
|       | c |           |                          |                 |
|       | o |           |                          |                 |
|       | m |           |                          |                 |
|       | p |           |                          |                 |
|       | o |           |                          |                 |
|       | u |           |                          |                 |
|       | n |           |                          |                 |
|       | d |           |                          |                 |
|       | s |           |                          |                 |
|       | t |           |                          |                 |
|       | o |           |                          |                 |
|       | t |           |                          |                 |
|       | h |           |                          |                 |
|       | e |           |                          |                 |
|       | a |           |                          |                 |
|       | i |           |                          |                 |
|       | r |           |                          |                 |
|       | . |           |                          |                 |
+-------+---+-----------+--------------------------+-----------------+
| **    |   | Reduce    |                          |                 |
| Objec |   | volatile  |                          |                 |
| tives |   | organic   |                          |                 |
| and   |   | compound  |                          |                 |
| Targ  |   | emissions |                          |                 |
| ets** |   | a         |                          |                 |
|       |   | ssociated |                          |                 |
|       |   | with      |                          |                 |
|       |   | graffiti  |                          |                 |
|       |   | removal   |                          |                 |
|       |   | by 25% by |                          |                 |
|       |   | 6/30/05.  |                          |                 |
+-------+---+-----------+--------------------------+-----------------+
| **Env |   |           | # **Moni                 |                 |
| ironm |   |           | toring and Measurement** |                 |
| ental |   |           |                          |                 |
| Manag |   |           | VOC content of alternate |                 |
| ement |   |           | cleaning compounds       |                 |
| Progr |   |           |                          |                 |
| ams** |   |           | ![](media/image9.png)    |                 |
|       |   |           |                          |                 |
| Esta  |   |           |                          |                 |
| blish |   |           |                          |                 |
| bas   |   |           |                          |                 |
| eline |   |           |                          |                 |
| usage |   |           |                          |                 |
|       |   |           |                          |                 |
| Ide   |   |           |                          |                 |
| ntify |   |           |                          |                 |
| Alte  |   |           |                          |                 |
| rnate |   |           |                          |                 |
| Pro   |   |           |                          |                 |
| ducts |   |           |                          |                 |
|       |   |           |                          |                 |
| Esta  |   |           |                          |                 |
| blish |   |           |                          |                 |
| proce |   |           |                          |                 |
| dures |   |           |                          |                 |
| and   |   |           |                          |                 |
| con   |   |           |                          |                 |
| trols |   |           |                          |                 |
|       |   |           |                          |                 |
| Track |   |           |                          |                 |
| usage |   |           |                          |                 |
+-------+---+-----------+--------------------------+-----------------+
| **O   |   |           |                          |                 |
| perat |   |           |                          |                 |
| ional |   |           |                          |                 |
| Contr |   |           |                          |                 |
| ols** |   |           |                          |                 |
|       |   |           |                          |                 |
| Rail  |   |           |                          |                 |
| Ve    |   |           |                          |                 |
| hicle |   |           |                          |                 |
| Int   |   |           |                          |                 |
| erior |   |           |                          |                 |
| Cle   |   |           |                          |                 |
| aning |   |           |                          |                 |
| Proc  |   |           |                          |                 |
| edure |   |           |                          |                 |
|       |   |           |                          |                 |
| Ae    |   |           |                          |                 |
| rosol |   |           |                          |                 |
| Can   |   |           |                          |                 |
| Pun   |   |           |                          |                 |
| cture |   |           |                          |                 |
| Proc  |   |           |                          |                 |
| edure |   |           |                          |                 |
+-------+---+-----------+--------------------------+-----------------+

+-------+---+--------+-----------------------------+-----------------+
| #     | * |        |                             | # **Poli        |
| **Asp | * |        |                             | cy Commitment** |
| ect** | A |        |                             |                 |
|       | e |        |                             |                 |
|       | r |        |                             |                 |
|       | o |        |                             |                 |
|       | s |        |                             |                 |
|       | o |        |                             |                 |
|       | l |        |                             |                 |
|       | I |        |                             |                 |
|       | n |        |                             |                 |
|       | s |        |                             |                 |
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|       | c |        |                             |                 |
|       | t |        |                             |                 |
|       | i |        |                             |                 |
|       | c |        |                             |                 |
|       | i |        |                             |                 |
|       | d |        |                             |                 |
|       | e |        |                             |                 |
|       | U |        |                             |                 |
|       | s |        |                             |                 |
|       | e |        |                             |                 |
|       | f |        |                             |                 |
|       | r |        |                             |                 |
|       | o |        |                             |                 |
|       | m |        |                             |                 |
|       | F |        |                             |                 |
|       | l |        |                             |                 |
|       | e |        |                             |                 |
|       | a |        |                             |                 |
|       | A |        |                             |                 |
|       | b |        |                             |                 |
|       | a |        |                             |                 |
|       | t |        |                             |                 |
|       | e |        |                             |                 |
|       | m |        |                             |                 |
|       | e |        |                             |                 |
|       | n |        |                             |                 |
|       | t |        |                             |                 |
|       | P |        |                             |                 |
|       | r |        |                             |                 |
|       | o |        |                             |                 |
|       | g |        |                             |                 |
|       | r |        |                             |                 |
|       | a |        |                             |                 |
|       | m |        |                             |                 |
|       | * |        |                             |                 |
|       | * |        |                             |                 |
+-------+---+--------+-----------------------------+-----------------+
| **Imp | D |        |                             | Pollution       |
| act** | i |        |                             | Prevention      |
|       | s |        |                             |                 |
|       | c |        |                             |                 |
|       | h |        |                             |                 |
|       | a |        |                             |                 |
|       | r |        |                             |                 |
|       | g |        |                             |                 |
|       | e |        |                             |                 |
|       | o |        |                             |                 |
|       | f |        |                             |                 |
|       | v |        |                             |                 |
|       | o |        |                             |                 |
|       | l |        |                             |                 |
|       | a |        |                             |                 |
|       | t |        |                             |                 |
|       | i |        |                             |                 |
|       | l |        |                             |                 |
|       | e |        |                             |                 |
|       | o |        |                             |                 |
|       | r |        |                             |                 |
|       | g |        |                             |                 |
|       | a |        |                             |                 |
|       | n |        |                             |                 |
|       | i |        |                             |                 |
|       | c |        |                             |                 |
|       | c |        |                             |                 |
|       | o |        |                             |                 |
|       | m |        |                             |                 |
|       | p |        |                             |                 |
|       | o |        |                             |                 |
|       | u |        |                             |                 |
|       | n |        |                             |                 |
|       | d |        |                             |                 |
|       | s |        |                             |                 |
|       | t |        |                             |                 |
|       | o |        |                             |                 |
|       | t |        |                             |                 |
|       | h |        |                             |                 |
|       | e |        |                             |                 |
|       | a |        |                             |                 |
|       | i |        |                             |                 |
|       | r |        |                             |                 |
|       | . |        |                             |                 |
+-------+---+--------+-----------------------------+-----------------+
| **    |   | Reduce |                             |                 |
| Objec |   | vo     |                             |                 |
| tives |   | latile |                             |                 |
| and   |   | o      |                             |                 |
| Targ  |   | rganic |                             |                 |
| ets** |   | co     |                             |                 |
|       |   | mpound |                             |                 |
|       |   | emi    |                             |                 |
|       |   | ssions |                             |                 |
|       |   | asso   |                             |                 |
|       |   | ciated |                             |                 |
|       |   | with   |                             |                 |
|       |   | r      |                             |                 |
|       |   | evenue |                             |                 |
|       |   | v      |                             |                 |
|       |   | ehicle |                             |                 |
|       |   | flea   |                             |                 |
|       |   | b      |                             |                 |
|       |   | ombing |                             |                 |
|       |   | by 33% |                             |                 |
|       |   | by     |                             |                 |
|       |   | 6/     |                             |                 |
|       |   | 30/05. |                             |                 |
+-------+---+--------+-----------------------------+-----------------+
| **Env |   |        | # **Mo                      |                 |
| ironm |   |        | nitoring and Measurement**  |                 |
| ental |   |        |                             |                 |
| Manag |   |        | VOC emissions from          |                 |
| ement |   |        | flea-abatement per year.    |                 |
| Progr |   |        |                             |                 |
| ams** |   |        | ![](media/image10.png)      |                 |
|       |   |        |                             |                 |
| Esta  |   |        |                             |                 |
| blish |   |        |                             |                 |
| bas   |   |        |                             |                 |
| eline |   |        |                             |                 |
| usage |   |        |                             |                 |
|       |   |        |                             |                 |
| Eva   |   |        |                             |                 |
| luate |   |        |                             |                 |
| alte  |   |        |                             |                 |
| rnate |   |        |                             |                 |
| de    |   |        |                             |                 |
| -flea |   |        |                             |                 |
| ap    |   |        |                             |                 |
| plica |   |        |                             |                 |
| tions |   |        |                             |                 |
|       |   |        |                             |                 |
| Esta  |   |        |                             |                 |
| blish |   |        |                             |                 |
| proce |   |        |                             |                 |
| dures |   |        |                             |                 |
| and   |   |        |                             |                 |
| con   |   |        |                             |                 |
| trols |   |        |                             |                 |
|       |   |        |                             |                 |
| Track |   |        |                             |                 |
| usage |   |        |                             |                 |
+-------+---+--------+-----------------------------+-----------------+
| **O   |   |        |                             |                 |
| perat |   |        |                             |                 |
| ional |   |        |                             |                 |
| Contr |   |        |                             |                 |
| ols** |   |        |                             |                 |
|       |   |        |                             |                 |
| Rail  |   |        |                             |                 |
| Ve    |   |        |                             |                 |
| hicle |   |        |                             |                 |
| Int   |   |        |                             |                 |
| erior |   |        |                             |                 |
| Clean |   |        |                             |                 |
| ing - |   |        |                             |                 |
| Flea  |   |        |                             |                 |
| Abat  |   |        |                             |                 |
| ement |   |        |                             |                 |
| Pr    |   |        |                             |                 |
| ogram |   |        |                             |                 |
+-------+---+--------+-----------------------------+-----------------+

+-------+---+--------+--------------------------+---------------------+
| #     | * |        |                          | # **                |
| **Asp | * |        |                          | Policy Commitment** |
| ect** | S |        |                          |                     |
|       | o |        |                          |                     |
|       | l |        |                          |                     |
|       | i |        |                          |                     |
|       | d |        |                          |                     |
|       | W |        |                          |                     |
|       | a |        |                          |                     |
|       | s |        |                          |                     |
|       | t |        |                          |                     |
|       | e |        |                          |                     |
|       | P |        |                          |                     |
|       | r |        |                          |                     |
|       | o |        |                          |                     |
|       | d |        |                          |                     |
|       | u |        |                          |                     |
|       | c |        |                          |                     |
|       | t |        |                          |                     |
|       | i |        |                          |                     |
|       | o |        |                          |                     |
|       | n |        |                          |                     |
|       | * |        |                          |                     |
|       | * |        |                          |                     |
+-------+---+--------+--------------------------+---------------------+
| **Imp | D |        |                          | Pollution           |
| act** | i |        |                          | Prevention          |
|       | s |        |                          |                     |
|       | c |        |                          | Environmental       |
|       | a |        |                          | Preservation        |
|       | r |        |                          |                     |
|       | d |        |                          | Sustainability      |
|       | e |        |                          |                     |
|       | d |        |                          |                     |
|       | m |        |                          |                     |
|       | a |        |                          |                     |
|       | t |        |                          |                     |
|       | e |        |                          |                     |
|       | r |        |                          |                     |
|       | i |        |                          |                     |
|       | a |        |                          |                     |
|       | l |        |                          |                     |
|       | s |        |                          |                     |
|       | t |        |                          |                     |
|       | a |        |                          |                     |
|       | k |        |                          |                     |
|       | e |        |                          |                     |
|       | u |        |                          |                     |
|       | p |        |                          |                     |
|       | v |        |                          |                     |
|       | a |        |                          |                     |
|       | l |        |                          |                     |
|       | u |        |                          |                     |
|       | a |        |                          |                     |
|       | b |        |                          |                     |
|       | l |        |                          |                     |
|       | e |        |                          |                     |
|       | l |        |                          |                     |
|       | a |        |                          |                     |
|       | n |        |                          |                     |
|       | d |        |                          |                     |
|       | f |        |                          |                     |
|       | i |        |                          |                     |
|       | l |        |                          |                     |
|       | l |        |                          |                     |
|       | s |        |                          |                     |
|       | p |        |                          |                     |
|       | a |        |                          |                     |
|       | c |        |                          |                     |
|       | e |        |                          |                     |
|       | a |        |                          |                     |
|       | n |        |                          |                     |
|       | d |        |                          |                     |
|       | p |        |                          |                     |
|       | o |        |                          |                     |
|       | l |        |                          |                     |
|       | l |        |                          |                     |
|       | u |        |                          |                     |
|       | t |        |                          |                     |
|       | e |        |                          |                     |
|       | s |        |                          |                     |
|       | o |        |                          |                     |
|       | i |        |                          |                     |
|       | l |        |                          |                     |
|       | , |        |                          |                     |
|       | a |        |                          |                     |
|       | i |        |                          |                     |
|       | r |        |                          |                     |
|       | , |        |                          |                     |
|       | a |        |                          |                     |
|       | n |        |                          |                     |
|       | d |        |                          |                     |
|       | w |        |                          |                     |
|       | a |        |                          |                     |
|       | t |        |                          |                     |
|       | e |        |                          |                     |
|       | r |        |                          |                     |
|       | . |        |                          |                     |
+-------+---+--------+--------------------------+---------------------+
| **    |   | Est    |                          |                     |
| Objec |   | ablish |                          |                     |
| tives |   | a      |                          |                     |
| and   |   | rec    |                          |                     |
| Targ  |   | ycling |                          |                     |
| ets** |   | p      |                          |                     |
|       |   | rogram |                          |                     |
|       |   | to     |                          |                     |
|       |   | reduce |                          |                     |
|       |   | solid  |                          |                     |
|       |   | waste  |                          |                     |
|       |   | di     |                          |                     |
|       |   | sposal |                          |                     |
|       |   | to     |                          |                     |
|       |   | la     |                          |                     |
|       |   | ndfill |                          |                     |
|       |   | by 50% |                          |                     |
|       |   | after  |                          |                     |
|       |   | the    |                          |                     |
|       |   | first  |                          |                     |
|       |   | year.  |                          |                     |
+-------+---+--------+--------------------------+---------------------+
| **Env |   |        | # **Monit                |                     |
| ironm |   |        | oring and Measurement**  |                     |
| ental |   |        |                          |                     |
| Manag |   |        | ![](media/image11.png)   |                     |
| ement |   |        |                          |                     |
| Progr |   |        |                          |                     |
| ams** |   |        |                          |                     |
|       |   |        |                          |                     |
| Eva   |   |        |                          |                     |
| luate |   |        |                          |                     |
| waste |   |        |                          |                     |
| st    |   |        |                          |                     |
| reams |   |        |                          |                     |
|       |   |        |                          |                     |
| Ide   |   |        |                          |                     |
| ntify |   |        |                          |                     |
| al    |   |        |                          |                     |
| terna |   |        |                          |                     |
| tives |   |        |                          |                     |
| to    |   |        |                          |                     |
| dis   |   |        |                          |                     |
| posal |   |        |                          |                     |
|       |   |        |                          |                     |
| Esta  |   |        |                          |                     |
| blish |   |        |                          |                     |
| proce |   |        |                          |                     |
| dures |   |        |                          |                     |
|       |   |        |                          |                     |
| Esta  |   |        |                          |                     |
| blish |   |        |                          |                     |
| colle |   |        |                          |                     |
| ction |   |        |                          |                     |
| areas |   |        |                          |                     |
|       |   |        |                          |                     |
| Track |   |        |                          |                     |
| Pro   |   |        |                          |                     |
| gress |   |        |                          |                     |
+-------+---+--------+--------------------------+---------------------+
| **O   |   |        |                          |                     |
| perat |   |        |                          |                     |
| ional |   |        |                          |                     |
| Contr |   |        |                          |                     |
| ols** |   |        |                          |                     |
|       |   |        |                          |                     |
| Colle |   |        |                          |                     |
| ction |   |        |                          |                     |
| of    |   |        |                          |                     |
| O     |   |        |                          |                     |
| ffice |   |        |                          |                     |
| and   |   |        |                          |                     |
| Shop  |   |        |                          |                     |
| R     |   |        |                          |                     |
| ecycl |   |        |                          |                     |
| ables |   |        |                          |                     |
+-------+---+--------+--------------------------+---------------------+

+-------+---+----------------------+------------+---------------------+
| #     | * |                      |            | # **                |
| **Asp | * |                      |            | Policy Commitment** |
| ect** | D |                      |            |                     |
|       | i |                      |            |                     |
|       | s |                      |            |                     |
|       | p |                      |            |                     |
|       | o |                      |            |                     |
|       | s |                      |            |                     |
|       | a |                      |            |                     |
|       | l |                      |            |                     |
|       | o |                      |            |                     |
|       | f |                      |            |                     |
|       | C |                      |            |                     |
|       | r |                      |            |                     |
|       | e |                      |            |                     |
|       | o |                      |            |                     |
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|       | o |                      |            |                     |
|       | t |                      |            |                     |
|       | e |                      |            |                     |
|       | T |                      |            |                     |
|       | r |                      |            |                     |
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|       | a |                      |            |                     |
|       | t |                      |            |                     |
|       | e |                      |            |                     |
|       | d |                      |            |                     |
|       | W |                      |            |                     |
|       | o |                      |            |                     |
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|       | d |                      |            |                     |
|       | T |                      |            |                     |
|       | i |                      |            |                     |
|       | e |                      |            |                     |
|       | s |                      |            |                     |
|       | * |                      |            |                     |
|       | * |                      |            |                     |
+-------+---+----------------------+------------+---------------------+
| **Imp | D |                      |            | Pollution           |
| act** | i |                      |            | Prevention          |
|       | s |                      |            |                     |
|       | c |                      |            | Environmental       |
|       | a |                      |            | Preservation        |
|       | r |                      |            |                     |
|       | d |                      |            | Sustainability      |
|       | e |                      |            |                     |
|       | d |                      |            |                     |
|       | t |                      |            |                     |
|       | i |                      |            |                     |
|       | e |                      |            |                     |
|       | s |                      |            |                     |
|       | m |                      |            |                     |
|       | a |                      |            |                     |
|       | y |                      |            |                     |
|       | b |                      |            |                     |
|       | e |                      |            |                     |
|       | u |                      |            |                     |
|       | s |                      |            |                     |
|       | e |                      |            |                     |
|       | d |                      |            |                     |
|       | i |                      |            |                     |
|       | m |                      |            |                     |
|       | p |                      |            |                     |
|       | r |                      |            |                     |
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|       | p |                      |            |                     |
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|       | l |                      |            |                     |
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|       | r |                      |            |                     |
|       | d |                      |            |                     |
|       | i |                      |            |                     |
|       | s |                      |            |                     |
|       | p |                      |            |                     |
|       | o |                      |            |                     |
|       | s |                      |            |                     |
|       | e |                      |            |                     |
|       | d |                      |            |                     |
|       | o |                      |            |                     |
|       | f |                      |            |                     |
|       | a |                      |            |                     |
|       | s |                      |            |                     |
|       | w |                      |            |                     |
|       | a |                      |            |                     |
|       | s |                      |            |                     |
|       | t |                      |            |                     |
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|       | h |                      |            |                     |
|       | a |                      |            |                     |
|       | t |                      |            |                     |
|       | t |                      |            |                     |
|       | a |                      |            |                     |
|       | k |                      |            |                     |
|       | e |                      |            |                     |
|       | s |                      |            |                     |
|       | u |                      |            |                     |
|       | p |                      |            |                     |
|       | v |                      |            |                     |
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|       | d |                      |            |                     |
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|       | i |                      |            |                     |
|       | l |                      |            |                     |
|       | l |                      |            |                     |
|       | s |                      |            |                     |
|       | p |                      |            |                     |
|       | a |                      |            |                     |
|       | c |                      |            |                     |
|       | e |                      |            |                     |
|       | a |                      |            |                     |
|       | n |                      |            |                     |
|       | d |                      |            |                     |
|       | p |                      |            |                     |
|       | o |                      |            |                     |
|       | l |                      |            |                     |
|       | l |                      |            |                     |
|       | u |                      |            |                     |
|       | t |                      |            |                     |
|       | e |                      |            |                     |
|       | s |                      |            |                     |
|       | s |                      |            |                     |
|       | o |                      |            |                     |
|       | i |                      |            |                     |
|       | l |                      |            |                     |
|       | , |                      |            |                     |
|       | a |                      |            |                     |
|       | i |                      |            |                     |
|       | r |                      |            |                     |
|       | , |                      |            |                     |
|       | a |                      |            |                     |
|       | n |                      |            |                     |
|       | d |                      |            |                     |
|       | w |                      |            |                     |
|       | a |                      |            |                     |
|       | t |                      |            |                     |
|       | e |                      |            |                     |
|       | r |                      |            |                     |
+-------+---+----------------------+------------+---------------------+
| **    |   | Eliminate reclaimed  |            |                     |
| Objec |   | creosote crossties   |            |                     |
| tives |   | from going to        |            |                     |
| and   |   | landfills by         |            |                     |
| Targ  |   | 12/31/05.            |            |                     |
| ets** |   |                      |            |                     |
+-------+---+----------------------+------------+---------------------+
| # **  |   |                      | #          |                     |
| Envir |   |                      | **Monitori |                     |
| onmen |   |                      | ng and Mea |                     |
| tal M |   |                      | surement** |                     |
| anage |   |                      |            |                     |
| ment  |   |                      | Wh         |                     |
| Progr |   |                      | eelabrator |                     |
| ams** |   |                      | Shasta     |                     |
|       |   |                      | Energy     |                     |
| Esta  |   |                      | Company    |                     |
| blish |   |                      | selected   |                     |
| tra   |   |                      | for        |                     |
| cking |   |                      | recycling  |                     |
| pr    |   |                      | ties for   |                     |
| ogram |   |                      | energy     |                     |
|       |   |                      | cog        |                     |
| De    |   |                      | eneration. |                     |
| velop |   |                      |            |                     |
| p     |   |                      | Tran       |                     |
| olicy |   |                      | sportation |                     |
| of    |   |                      | ar         |                     |
| recy  |   |                      | rangements |                     |
| cling |   |                      | being      |                     |
| ties  |   |                      | finalized. |                     |
|       |   |                      |            |                     |
| Esta  |   |                      | 100% of    |                     |
| blish |   |                      | ties will  |                     |
| proce |   |                      | be         |                     |
| dures |   |                      | recycled.  |                     |
| and   |   |                      |            |                     |
| con   |   |                      | Target on  |                     |
| trols |   |                      | Track      |                     |
|       |   |                      |            |                     |
| Track |   |                      |            |                     |
| and   |   |                      |            |                     |
| r     |   |                      |            |                     |
| eport |   |                      |            |                     |
| tie   |   |                      |            |                     |
| dis   |   |                      |            |                     |
| posal |   |                      |            |                     |
+-------+---+----------------------+------------+---------------------+
| #     |   |                      |            |                     |
|  **Op |   |                      |            |                     |
| erati |   |                      |            |                     |
| onal  |   |                      |            |                     |
| Contr |   |                      |            |                     |
| ols** |   |                      |            |                     |
|       |   |                      |            |                     |
| Cre   |   |                      |            |                     |
| osote |   |                      |            |                     |
| Cro   |   |                      |            |                     |
| sstie |   |                      |            |                     |
| Dis   |   |                      |            |                     |
| posal |   |                      |            |                     |
| Proc  |   |                      |            |                     |
| edure |   |                      |            |                     |
+-------+---+----------------------+------------+---------------------+

+-------+---+------------------+----------------+---------------------+
| #     | * |                  |                | # **                |
| **Asp | * |                  |                | Policy Commitment** |
| ect** | H |                  |                |                     |
|       | y |                  |                |                     |
|       | d |                  |                |                     |
|       | r |                  |                |                     |
|       | a |                  |                |                     |
|       | u |                  |                |                     |
|       | l |                  |                |                     |
|       | i |                  |                |                     |
|       | c |                  |                |                     |
|       | O |                  |                |                     |
|       | i |                  |                |                     |
|       | l |                  |                |                     |
|       | S |                  |                |                     |
|       | p |                  |                |                     |
|       | i |                  |                |                     |
|       | l |                  |                |                     |
|       | l |                  |                |                     |
|       | s |                  |                |                     |
|       | f |                  |                |                     |
|       | r |                  |                |                     |
|       | o |                  |                |                     |
|       | m |                  |                |                     |
|       | O |                  |                |                     |
|       | n |                  |                |                     |
|       | - |                  |                |                     |
|       | r |                  |                |                     |
|       | a |                  |                |                     |
|       | i |                  |                |                     |
|       | l |                  |                |                     |
|       | E |                  |                |                     |
|       | q |                  |                |                     |
|       | u |                  |                |                     |
|       | i |                  |                |                     |
|       | p |                  |                |                     |
|       | m |                  |                |                     |
|       | e |                  |                |                     |
|       | n |                  |                |                     |
|       | t |                  |                |                     |
|       | * |                  |                |                     |
|       | * |                  |                |                     |
+-------+---+------------------+----------------+---------------------+
| **Imp | O |                  |                | Pollution           |
| act** | i |                  |                | Prevention          |
|       | l |                  |                |                     |
|       | s |                  |                | Regulatory          |
|       | p |                  |                | Compliance          |
|       | i |                  |                |                     |
|       | l |                  |                |                     |
|       | l |                  |                |                     |
|       | s |                  |                |                     |
|       | f |                  |                |                     |
|       | r |                  |                |                     |
|       | o |                  |                |                     |
|       | m |                  |                |                     |
|       | o |                  |                |                     |
|       | n |                  |                |                     |
|       | - |                  |                |                     |
|       | r |                  |                |                     |
|       | a |                  |                |                     |
|       | i |                  |                |                     |
|       | l |                  |                |                     |
|       | e |                  |                |                     |
|       | q |                  |                |                     |
|       | u |                  |                |                     |
|       | i |                  |                |                     |
|       | p |                  |                |                     |
|       | m |                  |                |                     |
|       | e |                  |                |                     |
|       | n |                  |                |                     |
|       | t |                  |                |                     |
|       | c |                  |                |                     |
|       | a |                  |                |                     |
|       | n |                  |                |                     |
|       | r |                  |                |                     |
|       | e |                  |                |                     |
|       | s |                  |                |                     |
|       | u |                  |                |                     |
|       | l |                  |                |                     |
|       | t |                  |                |                     |
|       | i |                  |                |                     |
|       | n |                  |                |                     |
|       | p |                  |                |                     |
|       | o |                  |                |                     |
|       | l |                  |                |                     |
|       | l |                  |                |                     |
|       | u |                  |                |                     |
|       | t |                  |                |                     |
|       | i |                  |                |                     |
|       | o |                  |                |                     |
|       | n |                  |                |                     |
|       | o |                  |                |                     |
|       | f |                  |                |                     |
|       | s |                  |                |                     |
|       | o |                  |                |                     |
|       | i |                  |                |                     |
|       | l |                  |                |                     |
|       | a |                  |                |                     |
|       | n |                  |                |                     |
|       | d |                  |                |                     |
|       | w |                  |                |                     |
|       | a |                  |                |                     |
|       | t |                  |                |                     |
|       | e |                  |                |                     |
|       | r |                  |                |                     |
|       | . |                  |                |                     |
+-------+---+------------------+----------------+---------------------+
| **    |   | Procure          |                |                     |
| Objec |   | necessary spill  |                |                     |
| tives |   | response         |                |                     |
| and   |   | supplies.        |                |                     |
| Targ  |   |                  |                |                     |
| ets** |   | Train all        |                |                     |
|       |   | affected         |                |                     |
|       |   | employees in     |                |                     |
|       |   | spill procedures |                |                     |
|       |   | by 9/30/05.      |                |                     |
+-------+---+------------------+----------------+---------------------+
| # **  |   |                  | # **           |                     |
| Envir |   |                  | Monitoring and |                     |
| onmen |   |                  |  Measurement** |                     |
| tal M |   |                  |                |                     |
| anage |   |                  | Spill response |                     |
| ment  |   |                  | equipment has  |                     |
| Progr |   |                  | been procured  |                     |
| ams** |   |                  | and mounted on |                     |
|       |   |                  | each vehicle   |                     |
| Eva   |   |                  | with a         |                     |
| luate |   |                  | significant    |                     |
| spill |   |                  | spill          |                     |
| pote  |   |                  | potential.     |                     |
| ntial |   |                  |                |                     |
| for   |   |                  | Spill          |                     |
| each  |   |                  | procedures     |                     |
| ve    |   |                  | have been      |                     |
| hicle |   |                  | written.       |                     |
|       |   |                  |                |                     |
| De    |   |                  | Training video |                     |
| velop |   |                  | is done and    |                     |
| spill |   |                  | training is    |                     |
| res   |   |                  | underway.      |                     |
| ponse |   |                  |                |                     |
| proce |   |                  | Target on      |                     |
| dures |   |                  | track.         |                     |
|       |   |                  |                |                     |
| Pr    |   |                  |                |                     |
| ocure |   |                  |                |                     |
| spill |   |                  |                |                     |
| res   |   |                  |                |                     |
| ponse |   |                  |                |                     |
| equi  |   |                  |                |                     |
| pment |   |                  |                |                     |
|       |   |                  |                |                     |
| Co    |   |                  |                |                     |
| nduct |   |                  |                |                     |
| emp   |   |                  |                |                     |
| loyee |   |                  |                |                     |
| tra   |   |                  |                |                     |
| ining |   |                  |                |                     |
+-------+---+------------------+----------------+---------------------+
| #     |   |                  |                |                     |
|  **Op |   |                  |                |                     |
| erati |   |                  |                |                     |
| onal  |   |                  |                |                     |
| Contr |   |                  |                |                     |
| ols** |   |                  |                |                     |
|       |   |                  |                |                     |
| On    |   |                  |                |                     |
| -rail |   |                  |                |                     |
| Ve    |   |                  |                |                     |
| hicle |   |                  |                |                     |
| Spill |   |                  |                |                     |
| Res   |   |                  |                |                     |
| ponse |   |                  |                |                     |
| Proc  |   |                  |                |                     |
| edure |   |                  |                |                     |
+-------+---+------------------+----------------+---------------------+

+-------+---+-----------------------+-----------+---------------------+
| #     | * |                       |           | # **                |
| **Asp | * |                       |           | Policy Commitment** |
| ect** | F |                       |           |                     |
|       | l |                       |           |                     |
|       | o |                       |           |                     |
|       | r |                       |           |                     |
|       | e |                       |           |                     |
|       | s |                       |           |                     |
|       | c |                       |           |                     |
|       | e |                       |           |                     |
|       | n |                       |           |                     |
|       | t |                       |           |                     |
|       | L |                       |           |                     |
|       | a |                       |           |                     |
|       | m |                       |           |                     |
|       | p |                       |           |                     |
|       | s |                       |           |                     |
|       | a |                       |           |                     |
|       | n |                       |           |                     |
|       | d |                       |           |                     |
|       | E |                       |           |                     |
|       | l |                       |           |                     |
|       | e |                       |           |                     |
|       | c |                       |           |                     |
|       | t |                       |           |                     |
|       | r |                       |           |                     |
|       | o |                       |           |                     |
|       | n |                       |           |                     |
|       | i |                       |           |                     |
|       | c |                       |           |                     |
|       | W |                       |           |                     |
|       | a |                       |           |                     |
|       | s |                       |           |                     |
|       | t |                       |           |                     |
|       | e |                       |           |                     |
|       | * |                       |           |                     |
|       | * |                       |           |                     |
+-------+---+-----------------------+-----------+---------------------+
| **Imp | D |                       |           | Pollution           |
| act** | i |                       |           | Prevention          |
|       | s |                       |           |                     |
|       | p |                       |           | Regulatory          |
|       | o |                       |           | Compliance          |
|       | s |                       |           |                     |
|       | a |                       |           |                     |
|       | l |                       |           |                     |
|       | o |                       |           |                     |
|       | f |                       |           |                     |
|       | l |                       |           |                     |
|       | a |                       |           |                     |
|       | m |                       |           |                     |
|       | p |                       |           |                     |
|       | s |                       |           |                     |
|       | a |                       |           |                     |
|       | n |                       |           |                     |
|       | d |                       |           |                     |
|       | e |                       |           |                     |
|       | l |                       |           |                     |
|       | e |                       |           |                     |
|       | c |                       |           |                     |
|       | t |                       |           |                     |
|       | r |                       |           |                     |
|       | o |                       |           |                     |
|       | n |                       |           |                     |
|       | i |                       |           |                     |
|       | c |                       |           |                     |
|       | w |                       |           |                     |
|       | a |                       |           |                     |
|       | s |                       |           |                     |
|       | t |                       |           |                     |
|       | e |                       |           |                     |
|       | t |                       |           |                     |
|       | o |                       |           |                     |
|       | l |                       |           |                     |
|       | a |                       |           |                     |
|       | n |                       |           |                     |
|       | d |                       |           |                     |
|       | f |                       |           |                     |
|       | i |                       |           |                     |
|       | l |                       |           |                     |
|       | l |                       |           |                     |
|       | s |                       |           |                     |
|       | c |                       |           |                     |
|       | a |                       |           |                     |
|       | n |                       |           |                     |
|       | r |                       |           |                     |
|       | e |                       |           |                     |
|       | s |                       |           |                     |
|       | u |                       |           |                     |
|       | l |                       |           |                     |
|       | t |                       |           |                     |
|       | i |                       |           |                     |
|       | n |                       |           |                     |
|       | h |                       |           |                     |
|       | e |                       |           |                     |
|       | a |                       |           |                     |
|       | v |                       |           |                     |
|       | y |                       |           |                     |
|       | m |                       |           |                     |
|       | e |                       |           |                     |
|       | t |                       |           |                     |
|       | a |                       |           |                     |
|       | l |                       |           |                     |
|       | p |                       |           |                     |
|       | o |                       |           |                     |
|       | l |                       |           |                     |
|       | l |                       |           |                     |
|       | u |                       |           |                     |
|       | t |                       |           |                     |
|       | i |                       |           |                     |
|       | o |                       |           |                     |
|       | n |                       |           |                     |
|       | o |                       |           |                     |
|       | f |                       |           |                     |
|       | s |                       |           |                     |
|       | o |                       |           |                     |
|       | i |                       |           |                     |
|       | l |                       |           |                     |
|       | a |                       |           |                     |
|       | n |                       |           |                     |
|       | d |                       |           |                     |
|       | a |                       |           |                     |
|       | i |                       |           |                     |
|       | r |                       |           |                     |
|       | . |                       |           |                     |
+-------+---+-----------------------+-----------+---------------------+
| **    |   | Recycle all salvaged  |           |                     |
| Objec |   | materials from        |           |                     |
| tives |   | florescent and HID    |           |                     |
| and   |   | mercury vapor lamps   |           |                     |
| Targ  |   | and reduce electronic |           |                     |
| ets** |   | waste entering        |           |                     |
|       |   | landfills by 80% by   |           |                     |
|       |   | 12/1/05.              |           |                     |
+-------+---+-----------------------+-----------+---------------------+
| # **  |   |                       | # **M     |                     |
| Envir |   |                       | onitoring |                     |
| onmen |   |                       |  and Meas |                     |
| tal M |   |                       | urement** |                     |
| anage |   |                       |           |                     |
| ment  |   |                       | P         |                     |
| Progr |   |                       | rocedures |                     |
| ams** |   |                       | have been |                     |
|       |   |                       | est       |                     |
| De    |   |                       | ablished. |                     |
| velop |   |                       |           |                     |
| proc  |   |                       | Vendor    |                     |
| edure |   |                       | has been  |                     |
| for   |   |                       | selected  |                     |
| han   |   |                       | and       |                     |
| dling |   |                       | c         |                     |
| and   |   |                       | ollection |                     |
| dis   |   |                       | stations  |                     |
| posal |   |                       | have been |                     |
| of    |   |                       | est       |                     |
| lamps |   |                       | ablished. |                     |
| and   |   |                       |           |                     |
| elect |   |                       | D         |                     |
| ronic |   |                       | eveloping |                     |
| w     |   |                       | metrics   |                     |
| aste. |   |                       | to track  |                     |
|       |   |                       | per       |                     |
| S     |   |                       | formance. |                     |
| elect |   |                       |           |                     |
| ve    |   |                       | Target on |                     |
| ndors |   |                       | track.    |                     |
| to    |   |                       |           |                     |
| re    |   |                       |           |                     |
| cycle |   |                       |           |                     |
| elect |   |                       |           |                     |
| ronic |   |                       |           |                     |
| w     |   |                       |           |                     |
| aste. |   |                       |           |                     |
|       |   |                       |           |                     |
| Train |   |                       |           |                     |
| empl  |   |                       |           |                     |
| oyees |   |                       |           |                     |
| on    |   |                       |           |                     |
| e-    |   |                       |           |                     |
| waste |   |                       |           |                     |
| p     |   |                       |           |                     |
| roced |   |                       |           |                     |
| ures. |   |                       |           |                     |
|       |   |                       |           |                     |
| Track |   |                       |           |                     |
| pro   |   |                       |           |                     |
| gress |   |                       |           |                     |
+-------+---+-----------------------+-----------+---------------------+
| #     |   |                       |           |                     |
|  **Op |   |                       |           |                     |
| erati |   |                       |           |                     |
| onal  |   |                       |           |                     |
| Contr |   |                       |           |                     |
| ols** |   |                       |           |                     |
|       |   |                       |           |                     |
| Flore |   |                       |           |                     |
| scent |   |                       |           |                     |
| Tube  |   |                       |           |                     |
| and   |   |                       |           |                     |
| Ba    |   |                       |           |                     |
| llast |   |                       |           |                     |
| Dis   |   |                       |           |                     |
| posal |   |                       |           |                     |
| Proc  |   |                       |           |                     |
| edure |   |                       |           |                     |
+-------+---+-----------------------+-----------+---------------------+

# **Benefits of Adopting an EMS**

BART has realized a number benefits from EMS over the course of our
first year. They Include:

-   Providing a mechanism for expanding BART's robust Sustainability
    Policy and Program to include daily operations.

-   Communicating through our Board of Directors, to the public, BART's
    commitment to Environmental Sustainability

-   Providing a forum for a new level of inter-departmental
    communication and cooperation. This has not only positively impacted
    our environmental performance, but has enhanced our ability to
    conduct our core business.

-   Developing an excellent training mechanism, allowing for a single
    repeatable consistent message broadcast throughout the organization.

-   Creating a structure that encourages and enables employee
    participation in environmental and work place process improvements.

-   Elevating the priority of environmental performance and safety
    compliance at all levels of the organization. Problems tend to get
    immediate attention.

-   Dramatically reducing VOC emissions, solid waste disposal and
    hydraulic spill contamination potential.

Resources

The number of hours associated with the development and fenceline
implementation of BART's EMS programs is:

> EMS Core Team 1127 hours
>
> Staff Support 2040 hours
>
> Labor Cost Total \$145,655 (through May 31, 2005)

## Cost Savings and Avoidance

The management of several of our significant aspects has resulted in
greater efficiency and corresponding cost savings. We have already put
programs in place that will save the District over \$15,000 per year.
Additional initiatives that we have underway will result in cost savings
but we have not yet collected enough data to quantify the savings.

+-----------------------+--------------------------------+------------+
| **Aspect**            | ##### Efficiency               | **Annual** |
|                       |                                |            |
|                       |                                | *          |
|                       |                                | *Savings** |
+-----------------------+--------------------------------+------------+
| **Aerosol Graffiti    | Reduced disposal costs by      | \$4,770    |
| Removal**             | puncturing spent cans.         |            |
+-----------------------+--------------------------------+------------+
| **Aerosol Insecticide | Savings due to reduced product | \$2,700    |
| Use**                 | use.                           |            |
+-----------------------+--------------------------------+------------+
| **Creosote Crosstie   | Reduced cost for recycling     | \$8,000    |
| Disposal**            | compared to landfill.          |            |
+-----------------------+--------------------------------+------------+

Additional cost savings come from the intangible costs that are avoided
by having a high level of environmental compliance. Fines and penalties
are avoided. Citizen suits that could have been filed are avoided. Both
of these items have the potential to be a huge drain of District
resources.

#### Next Steps

The EMS team will continue to refine the EMS process within the Richmond
Shop and Yard with a focus on further expanding employee participation.
Additionally, the EMS team will work to involve more BART departments in
the EMS process. The team will specifically target

the Procurement Department in an effort to establish EMS criteria for
inclusion in purchase requisitions and service contracts. Finally, the
EMS team will look for opportunities to expand EMS concepts developed
within the fenceline to other parts of the organization, with the
long-term goal of extending the EMS program to all areas of the
District.

## Management Commitment

BART's executive management has been committed to the EMS project from
the beginning, providing the necessary resources to implement the
program. In addition to top management support, the support and
participation of key managers in the Maintenance and Engineering and
Rolling Stock and Shops departments has been critical to achieving and
maintaining the momentum we have enjoyed on this project.

**BART Audit Report**

This Environmental Management System (EMS) Audit was based on a request
by Virginia Tech (VT) and the Federal Transit Administration (FTA) as a
final follow-up to an eighteen month program for EMS development and was
conducted in accordance with the approved schedule.

Ms. Michele M. Lawton -- EMS Specialist with Virginia Tech conducted the
EMS Audit for Bay Area Rapid Transit (BART) -- San Francisco, CA on
August 8 and 9, 2005 to report on its conformance with the requirements
of the ISO 14001:1996 standard.

The EMS was evaluated against each of the requirements set out in the
ISO 14001:1996 standard titled "Environmental Management System --
Specification with guidance for use." The Audit included the examination
of documents, interviews of personnel and observations of activities and
conditions.

The site visit involved a review of the core EMS documents with the EMS
team. The BART EMS Team participated in the review and discussion
regarding the scoring.

The following scores are the result of the EMS Assessment:

1\. The overall score for the Assessment with respect to meeting the
requirements of an EMS as specified in the ISO 14001:1996 Standard is
**ninety-five percent (95%)**.

2\. **Ninety-one percent (91%)** of the requirements were **"met."**

3.  **Nine percent (9%)** of the requirements were **"partially met."**

**Detailed scoring on next page.**

**BART EMS Audit Results**

The following graph compares the total number of requirements met
*(shown in blue)* to the total number of requirements from the ISO
14001:1996 Standard *(shown in green)*.

  ------------ ------------------------------- --------- ----- ----------- ------ ----------------------
  The ISO                                      Overall   Met   Partially   Not    Ref.
  14001:1996                                                               Met    
  Standard                                                                        
  Elements of                                                                     
  an EMS                                                                          

                                               Score (%) (%)   Met (%)     (%)    

  4.2          Environmental Policy            95        90    10          \-     [4.2.10]{.underline}

  4.3.1        Environmental Aspects           100       100   \-          \-     [4.3.11]{.underline}

  4.3.2        Legal & Other Requirements      100       100   \-          \-     [4.3.21]{.underline}

  4.3.3        Objectives & Targets            100       100   \-          \-     [4.3.31]{.underline}

  4.3.4        Environmental Management        100       100   \-          \-     [4.3.41]{.underline}
               Program(s) (EMPs)                                                  

  4.4.1        Structure & Responsibility      100       100   \-          \-     [4.4.11]{.underline}

  4.4.2        Training, Awareness &           93        86    14          \-     [4.4.21]{.underline}
               Competence                                                         

  4.4.3        Communication                   100       100   \-          \-     [4.4.31]{.underline}

  4.4.4        EMS Documentation               100       100   \-          \-     [4.4.41]{.underline}

  4.4.5        Document Control                93        86    14          \-     [4.4.51]{.underline}

  4.4.6        Operational Control             88        75    25          \-     [4.4.61]{.underline}

  4.4.7        Emergency Preparedness &        100       100   \-          \-     [4.4.71]{.underline}
               Response                                                           

  4.5.1        Monitoring & Measurement        100       100   \-          \-     [4.5.11]{.underline}

  4.5.2        Nonconformance, Corrective &    100       100   \-          \-     [4.5.21]{.underline}
               Preventive Action                                                  

  4.5.3        Records                         100       100   \-          \-     [4.5.31]{.underline}

  4.5.4        EMS Audit                       63        25    75          \-     [4.5.41]{.underline}

  4.6          Management Review               90        80    20          \-     [4.6.10]{.underline}
  ------------ ------------------------------- --------- ----- ----------- ------ ----------------------

This section compares the percentage of requirements *met*, *partially
met*, and *not met* in each element of the EMS.

![](media/image12.jpeg){width="2.91875in" height="1.8847222222222222in"}

> Snohomish County, Washington

**Profile**

Community Transit is a full-service, public transportation provider,
operating local service throughout Snohomish County, Washington and
commuter service to Seattle and the University of Washington. Our
services include fixed route transit, paratransit, vanpool, ride
matching, and Sound Transit Express services to the Seattle metropolitan
market. In 2004, approximately 9.5 million passenger trips were made
throughout all services.

The Snohomish County Public Transportation Benefit Area (PTBA)
encompasses approximately 1,300 square miles in the northwest section of
Washington State and contains a diversity of land uses and
population/employment densities. Community Transit is both a rural and
urban transit service provider.

Currently, Community Transit operates 32 local bus routes, 31 commuter
routes and Dial-A-Ride Transportation (DART) services in Snohomish
County and south into neighboring King County. We also offer carpool
matching and our successful vanpool program ranks as one of the largest
in the nation.

In September 2001, voters approved an additional sales tax increase from
.6% to .9%, effective January 1, 2002. With the voter-approved funding,
Community Transit began growing again, restoring Sunday service in
February 2002 and expanding service by 18 percent during 2003.

**Fenceline**

![](media/image13.jpeg){width="2.3375in" height="1.7513888888888889in"}

The fenceline for EMS development at Community Transit is the Diesel
Fueling Operations at the Kasch Park Operating Base (KPOB), located at
2300 Kasch Park Road, Everett, Washington. Approximately 240 employees
work out of KPOB, of which 180 are contract employees supporting the
operation and maintenance of our commuter fixed route service. The other
60 employees work directly for Community Transit in Facilities
Maintenance, Marketing, Vanpool,
![](media/image14.jpeg){width="2.3375in" height="2.1375in"}Contracted
Services, and Automotive Maintenance who services approximately 275
vanpool vehicles, and 92 support vehicles. There are two unions at the
Kasch Park facility -- International Association of Machinists (IAM)
representing the mechanics, and the Amalgamated Transit Union (ATU)
representing Facilities Maintenance, coach operators, customer service,
and internal security. The facility operates 24/7/365 and just
celebrated its 20^th^ year of operation.

Diesel Fueling Operations include the following departments and areas:

1.  **Diesel Fueling Operations**. This occurs at the fueling island in
    the center of the facility where Community Transit's contractor
    fuels transit buses.

2.  **Diesel Fuel Delivery**. This constitutes outside fuel delivery
    contractors from the time they enter Community Transit property,
    fill the underground storage tanks with diesel fuel, clean-up as
    necessary, engage in preparations for emergency response, seek final
    delivery approval by Community Transit's contractor, and exit from
    the property.

3.  **Underground Storage Tanks (UST)**. There are eight USTs at our
    Kasch Park tank, one 10,000 gallon lube oil tank, one 6,000 gallon
    antifreeze tank, one 6,000 gallon automatic transmission fluid tank,
    and one 6,000 gallon waste oil tank. The fenceline includes all
    maintenance, operation, and emergency response associated with these
    tanks.

4.  **Bus Leaks in the Yard**. This incorporates all leaks -- fuel,
    coolants, oils, or any liquids that could potentially cause a spill
    of any amount on the KPOB bus yard. The bus yard runoff drains to
    our oil-water separators, then to our underground detention tank and
    finally through our wetlands property.

Our goal for the tasks falling within the fenceline is to ensure
compliance with our Environmental Policy Statement to minimize pollution
and comply with all applicable environmental regulations, as well as to
improve the quality of life for all of Community Transit's employees,
contractors and the general public who are affected by our
transportation services.

**Core Team**

Our current EMS Core Team consists of six members from throughout the
company. Our senior executive representative is Community Transit's
Director of Administration, Emmett Heath. The remainder of the EMS Core
Team is made up of:

-   Mike Burress, Risk Manager

-   Bruce Bachtel, Manager of Facilities and Automotive Services

-   Dan Jerome, Capital Facilities Planner

-   Colleen Sather, Loss Control Coordinator

-   Tom Huden, Facilities Journeyman

The make-up of the team has enabled us to create a program that
encompasses all factors of environmental issues, from planning and
permitting to operation, monitoring, and inspecting.

**Key Drivers for adopting an EMS**

We have identified the following key drivers for Community Transit's
development of an EMS program:

-   To be an environmental leader in the transit industry

-   To improve our environmental awareness

-   To elevate our current environmental processes and programs

-   To gain commitment from our employees and contractors on
    environmental issues

-   To show the community our support for environmental issues

-   To develop a fully documented environmental program for the benefit
    of the future of Community Transit

-   To capitalize on an FTA-sponsored framework for developing an EMS

**Significant Aspects and Impacts**

Community Transit's environmental impacts include storm water,
industrial wastewater, ground water, air, and noise. Environmental
aspects are defined as activities, products or services that can affect
one or more environmental impact. After a thorough survey of Community
Transit's KPOB facility, many environmental aspects were identified. A
numerical weighting system was used to determine how significant each
aspect was regarding its potential for negatively or positively
affecting each environmental impact.

For the initial development of Community Transit's EMS program, the four
most significant aspects based upon numerical priorities became our
fenceline.

-   Diesel fueling operations

-   Diesel product delivery

-   Diesel underground storage

-   Bus leaks in the yard

The remainder of our list of highest priority aspects to review,
evaluate and recommend steps for improvement is included later in this
report in the *Beyond Current Fenceline* section.

**Objective and Targets**

The objectives and targets for the significant aspects we are currently
managing are listed in the table below; along with the process we will
use to evaluate our success.

+---------------------+------------------------------------------------+
| **Significant       | **Diesel Fueling Operations**                  |
| Aspect**            |                                                |
+---------------------+------------------------------------------------+
| **Policy            | Pollution prevention                           |
| Commitment:**       |                                                |
|                     | Improve training and procedures to reduce      |
| **Objective:**      | potential for diesel spills                    |
|                     |                                                |
| **Target(s) and     | Zero reportable spills                         |
| Date(s):**          |                                                |
|                     | Reduce non-reportable diesel spills in 2005 by |
| **Performance       | 10% over 2003-2004 numbers                     |
| Indicator(s):**     |                                                |
|                     | Number of reported or observed spills          |
| **Evaluation        |                                                |
| Process:**          | Compare 2005 data with 2003--2004 data to      |
|                     | determine if the increased awareness due to    |
|                     | the training and procedures directly impacted  |
|                     | the difference, or if we encouraged more       |
|                     | accurate reporting of spills                   |
+---------------------+------------------------------------------------+

**STATUS:** Spill Prevention Procedure updated; 100% of fuelers trained
on the procedure; created and implemented a spill log for tracking
spills; baseline for spills in 2003-2004 established.

+---------------------+------------------------------------------------+
| **Significant       | **Diesel Product Delivery**                    |
| Aspect**            |                                                |
+---------------------+------------------------------------------------+
| **Policy            | Pollution Prevention, waste minimization       |
| Commitment:**       |                                                |
|                     | Reduce potential for product delivery errors   |
| **Objective:**      | and potential for product delivery spills      |
|                     |                                                |
| **Target(s) and     | Zero product delivery errors                   |
| Date(s):**          |                                                |
|                     | Zero storm water permit violations             |
| **Performance       |                                                |
| Indicator(s):**     | Implement QC procedures and Standard Operating |
|                     | Procedures (SOPs) for fuel delivery by 2006    |
| **Evaluation        | contract                                       |
| Process:**          |                                                |
|                     | Number of spills during delivery, number of    |
|                     | product delivery errors                        |
|                     |                                                |
|                     | Implement procedure to inspect area around     |
|                     | truck after delivery, track number of leaks or |
|                     | spills                                         |
+---------------------+------------------------------------------------+

**STATUS:** All tank delivery ports labeled; established agreement with
fuel delivery vendor to implement our Standard Operating Procedure for
spill prevention during delivery; vendor issued memo to all employees
requiring these new procedures.

+---------------------+------------------------------------------------+
| **Significant       | **Diesel Underground Storage**                 |
| Aspect**            |                                                |
+---------------------+------------------------------------------------+
| **Policy            | Pollution Prevention                           |
| Commitment:**       |                                                |
|                     | Eliminate potential for ground contamination   |
| **Objective:**      | from underground storage tanks                 |
|                     |                                                |
| **Target(s) and     | Increase understanding of operation of         |
| Date(s):**          | monitoring system by Jan. 31, 2006             |
|                     |                                                |
| **Performance       | Establish annual training on Veeder-Root       |
| Indicator(s):**     | monitoring system by Jan. 31, 2006             |
|                     |                                                |
| **Evaluation        | Establish and implement reporting procedures   |
| Process:**          | for underground storage tank monitoring system |
|                     | by Jan. 31, 2006                               |
|                     |                                                |
|                     | Timely reporting of alarms, corrective action  |
|                     |                                                |
|                     | Generation of monthly in-tank leak report,     |
|                     | timeliness in reporting and responding to      |
|                     | alarms, routine inspection to ensure alarms    |
|                     | are reported                                   |
+---------------------+------------------------------------------------+

**STATUS:** Received training from vendor on Veeder-Root monitoring
system; corrective action plan for deficiencies prepared and being
implemented; drafted procedure for inspection and response to alarms;
need to complete training for affected employees.

+---------------------+------------------------------------------------+
| **Significant       | **Bus Leaks in Yard**                          |
| Aspect**            |                                                |
+---------------------+------------------------------------------------+
| **Policy            | Pollution Prevention                           |
| Commitment:**       |                                                |
|                     | Reduce bus leaks in yard                       |
| **Objective:**      |                                                |
|                     | Develop daily inspection procedures by July    |
| **Target(s) and     | 31, 2004                                       |
| Date(s):**          |                                                |
|                     | Reduce number of bus leaks in yard by 10% in   |
| **Performance       | 7/1/05 -- 6/30/06 over 7/1/04 -- 6/30/05 data  |
| Indicator(s):**     |                                                |
|                     | Conduct training on proper clean-up of spills  |
| **Evaluation        | by Oct. 31, 2005                               |
| Process:**          |                                                |
|                     | Evidence of bus leaks and reportable spills    |
|                     |                                                |
|                     | Compare 7/1/05 -- 6/30/06 data with 7/1/04 --  |
|                     | 6/30/04 data                                   |
+---------------------+------------------------------------------------+

**STATUS**: Daily inspection procedure established June, 2004; baseline
established; training outline prepared; need to complete training.

**Benefits of Adopting an EMS**

Community Transit has seen the following benefits within the first year:

-   Increased awareness of environmental issues with sub-contractor
    through training and process improvements.

-   Involved other departments within Community Transit to assist and
    partner in the development of our EMS program.

-   Developed a documented process for managing our environmental
    issues.

-   The Board of Directors has adopted an EMS Policy which demonstrates
    to the general community our environmental commitment.

-   Learned from numerous other transit and public agencies how to
    improve our environmental quality.

-   Eliminated "phantom" oil spills in our storm water and industrial
    wastewater because everyone is more aware of the importance of
    working together to prevent spills, to maintain equipment better,
    and to report and properly clean-up spills immediately if they do
    occur.

**Resources**

Resources used for program development (Feb. 2004 to Aug. 2005) are as
follows:

  ---------------------- ---------------------- -------------------------
                         **Hours**              **Labor Costs**

  **Core Team**          2,351                  \$91,423

  **Sub-Teams**          154                    \$4,192
  ---------------------- ---------------------- -------------------------

In addition to program development, we have implemented specific
training and daily inspection procedures. The time and labor costs for
these activities are not included in the numbers above.

**Cost Savings or Avoidance**

Due to the implementation of our EMS, we anticipate cost avoidance
savings in three categories:

1\. Product delivery

> In years past, vendors have delivered the wrong product to the
> underground storage tanks within our fenceline, resulting in wasted
> fuel and product contamination, and cleanup costs of approximately
> \$18,000 for labor and disposal per instance. To prevent this from
> occurring, we have labeled the delivery ports for each tank and worked
> with the vendor to standardized and implement best practices for fuel
> delivery. Additionally, we inspect the delivery ports each month to
> ensure they remain correctly labeled.

2\. Spill Cleanup

> Historically, we have averaged 3 major diesel spills (over 1 gallon)
> within our fenceline from fueling operations per year. The past year,
> we had two major spills. Due to the implementation of our EMS
> including increased awareness and additional training, the spills were
> handled more expeditiously, resulting in proper cleanup prior to the
> spills reaching the wastewater system. The decreased number and
> severity of the spills has resulted in a savings of over \$2,000, as
> well as eliminating the potential for fines from the regulating agency
> of up to \$1,000 per instance.

3\. Groundwater and soil contamination

> Community Transit had a major remediation due to leaking lines of our
> underground storage tanks in 1990, which went unnoticed for a
> significant period of time, resulting in extensive soil contamination
> and significant cleanup costs in excess of 1.5 million dollars. The
> tanks and lines were replaced with double walled tanks and a
> monitoring system. Through the EMS, we have developed daily, weekly,
> and monthly inspections along with providing training and notification
> procedures of any inspection failure or alarms from the monitoring
> system. Due to the increased training and inspections, should we
> experience any problems with the tanks or lines, they will be detected
> and remedied immediately. We believe that savings of this nature
> cannot be quantified, but evaluated instead as a good business
> practice.

**Next Steps**

We have completed the development of our EMS; now we are focusing on
continual improvement. To ensure that our EMS continues to be up to date
and as effective as it can be, we are planning to perform self-audit
assessments annually. We will use these assessments to track progress,
incorporate changes, and expand the fenceline to other Community Transit
properties. We are working on a transition plan to complete our work
plan and expand the EMS to other activities that contribute to our
overall environmental footprint.

The EMS Core Team is working with sub-teams throughout the company to
further the development and implementation of our EMS. We are working
with the Purchasing Department to include an environmental supplement in
each RFP to ensure environmental impacts are addressed by
subcontractors. The Marketing Department is developing an EMS General
Awareness Video which will be shown during new employee orientation and
refresher training. We worked with Marketing to produce a poster
campaign to increase employee awareness about our EMS. We worked with
our Public Information Officer to produce other forms of communication
for employees and other community outreach projects. Our Information
Technology Department has included the EMS on both our internal and
external websites.

In addition to the on-going development and implementation, we have
identified the following aspects as high priority items to be evaluated
in the up-coming months and years.

**Future Work Plan: Highest Priority Items**

+-----------------+---------------------+------------------------------+
| **Aspect        | **Problem**         | **Solutions:**               |
| Issue**         |                     |                              |
|                 |                     | **Processes/Procedures**     |
+-----------------+---------------------+------------------------------+
| **Soaps and     | Potential storm     | Evaluate secondary           |
| detergents**    | water contamination | containment for drums        |
|                 | and harsh chemical  |                              |
|                 | usage               |                              |
+-----------------+---------------------+------------------------------+
|                 |                     | Evaluate "greener" soaps     |
+-----------------+---------------------+------------------------------+
| **Oil and waste | Potential           | Evaluate use of recycled oil |
| oil**           | groundwater         |                              |
|                 | contamination and   |                              |
|                 | opportunity for     |                              |
|                 | better use of       |                              |
|                 | natural resources   |                              |
+-----------------+---------------------+------------------------------+
|                 |                     | Evaluate containment and     |
|                 |                     | spill procedures             |
+-----------------+---------------------+------------------------------+
|                 |                     | Evaluate filtration for      |
|                 |                     | storm water                  |
+-----------------+---------------------+------------------------------+
| **Hydraulic     | Potential           | Develop inspection process   |
| fluid**         | groundwater         | for early detection and      |
|                 | contamination       | spill prevention             |
+-----------------+---------------------+------------------------------+
| **Tires**       | Zinc in the storm   | Evaluate covered storage for |
|                 | water               | surplus tires                |
+-----------------+---------------------+------------------------------+
| **Brake dust**  | Air quality (heavy  | Evaluate options             |
|                 | metals)             |                              |
+-----------------+---------------------+------------------------------+
| **Gasoline**    | Potential           | Evaluate conditions and      |
|                 | groundwater, storm  | prevention measures          |
|                 | water or air        |                              |
|                 | quality             |                              |
|                 | contamination       |                              |
+-----------------+---------------------+------------------------------+
| **Antifreeze    | Potential           | Evaluate conditions and      |
| and**           | groundwater         | prevention measures          |
|                 | contamination       |                              |
| **waste         |                     |                              |
| antifreeze**    |                     |                              |
+-----------------+---------------------+------------------------------+
| **EBS pump      | Potential storm     | Develop inspection and       |
| station**       | water contamination | prevention procedures for    |
|                 |                     | pump and sump                |
+-----------------+---------------------+------------------------------+
| **Steam         | Potential           | Evaluate alternatives and    |
| cleaning**      | wastewater          | procedures for chemical use  |
|                 | contamination (high |                              |
|                 | pH)                 |                              |
+-----------------+---------------------+------------------------------+
| **Bus wash**    | Potential           | Evaluate alternatives for    |
|                 | wastewater          | chemical use                 |
|                 | contamination (high |                              |
|                 | pH)                 |                              |
+-----------------+---------------------+------------------------------+
| **Misc.         | Potential air       | Evaluate vapor recovery      |
| chemicals/      | quality             | system                       |
| aerosols**      | contamination,      |                              |
|                 | worker safety       |                              |
+-----------------+---------------------+------------------------------+
|                 |                     | Evaluate alternatives and    |
|                 |                     | procedures for chemicals     |
|                 |                     | used                         |
+-----------------+---------------------+------------------------------+
| **Contractor    | Potential storm     | Evaluate chemicals used and  |
| cleaning        | water, wastewater   | procedures                   |
| chemicals for   | contamination       |                              |
| buses**         |                     |                              |
+-----------------+---------------------+------------------------------+
| **Shop floor    | Potential           | Evaluate chemicals used and  |
| cleaning**      | wastewater          | procedures                   |
|                 | contamination       |                              |
+-----------------+---------------------+------------------------------+
| **Paint booth** | Potential air       | Evaluate filtration and      |
|                 | quality             | inspection procedures        |
|                 | contamination       |                              |
+-----------------+---------------------+------------------------------+
| **Carbon        | Potential air       | Evaluate fuels, filtration   |
| monoxide**      | quality             | and preventative maintenance |
|                 | contamination       | procedures                   |
+-----------------+---------------------+------------------------------+
| *               | Potential air       | Evaluate procedures          |
| *Refrigerants** | quality             |                              |
|                 | contamination       |                              |
+-----------------+---------------------+------------------------------+
| **Acetylene/    | Potential air       | Evaluate inspection and      |
| oxygen tanks**  | quality             | operational procedures       |
|                 | contamination       |                              |
+-----------------+---------------------+------------------------------+
| **Propane**     | Potential air       | Evaluate inspection and      |
|                 | quality             | operational procedures       |
|                 | contamination       |                              |
+-----------------+---------------------+------------------------------+
| **Batteries**   | Potential air       | Evaluate inspection and      |
|                 | quality             | operational procedures       |
|                 | contamination,      |                              |
|                 | worker safety       |                              |
+-----------------+---------------------+------------------------------+

**Management Commitment**

A key factor to the success of our EMS has been the support and active
participation of our executive leadership. The Chair of the Board and
our Chief Executive Officer both signed our Environmental Policy
Statement, ensuring that our EMS makes business sense for the future, as
it adds to the quality of life for citizens in our community, and helps
quantify and document our improvements, cost savings and benefits to our
environment. Because of the support of our Executive Team, we have been
able to utilize the expertise of other departments, including Contracted
Services, Purchasing, Information Technology, Public Affairs and
Marketing, and Records Management in the development of procedures and
work products that support our EMS Policy.

**Community Transit Audit Report**

This Environmental Management System (EMS) Audit was based on a request
by Virginia Tech (VT) and the Federal Transit Administration (FTA) as a
final follow-up to an eighteen month program for EMS development and was
conducted in accordance with the approved schedule.

Ms. Michele M. Lawton -- EMS Specialist with Virginia Tech conducted the
EMS Audit for Community Transit on September 14 and 15, 2005 to report
on its conformance with the requirements of the ISO 14001:1996 standard.

The EMS was evaluated against each of the requirements set out in the
ISO 14001:1996 standard titled "Environmental management system --
Specification with guidance for use." The Audit included the examination
of documents, interviews of personnel and observations of activities and
conditions.

The site visit involved a review of the core EMS documents with the EMS
team. The Community Transit EMS Team participated in the review and
discussion regarding the scoring.

The following scores are the result of the EMS Assessment:

1\. The overall score for the Assessment with respect to meeting the
requirements of an EMS as specified in the ISO 14001:1996 Standard is
**ninety-five percent (95%)**.

2\. **Ninety-one percent (91%)** of the requirements were **"met."**

3\. **Nine percent (9%)** of the requirements were **"partially met."**

**Detailed scoring on next page.**

**Community Transit EMS Audit Results**

The following graph compares the total number of requirements met
*(shown in blue)* to the total number of requirements from the ISO
14001:1996 Standard *(shown in green)*.

  ------------ -------------------------------- --------- ----- ----------- ------- ----------------------
  The ISO                                       Overall   Met   Partially   Not Met Ref.
  14001:1996                                                                        
  Standard                                                                          
  Elements of                                                                       
  an EMS                                                                            

                                                Score (%) (%)   Met (%)     (%)     

  4.2          Environmental Policy             100       100   \-          \-      [4.2.10]{.underline}

  4.3.1        Environmental Aspects            100       100   \-          \-      [4.3.11]{.underline}

  4.3.2        Legal & Other Requirements       100       100   \-          \-      [4.3.21]{.underline}

  4.3.3        Objectives & Targets             100       100   \-          \-      [4.3.31]{.underline}

  4.3.4        Environmental Management         100       100   \-          \-      [4.3.41]{.underline}
               Program(s) (EMPs)                                                    

  4.4.1        Structure & Responsibility       100       100   \-          \-      [4.4.11]{.underline}

  4.4.2        Training, Awareness & Competence 93        86    14          \-      [4.4.21]{.underline}

  4.4.3        Communication                    100       100   \-          \-      [4.4.31]{.underline}

  4.4.4        EMS Documentation                100       100   \-          \-      [4.4.41]{.underline}

  4.4.5        Document Control                 93        86    14          \-      [4.4.51]{.underline}

  4.4.6        Operational Control              100       100   \-          \-      [4.4.61]{.underline}

  4.4.7        Emergency Preparedness &         100       100   \-          \-      [4.4.71]{.underline}
               Response                                                             

  4.5.1        Monitoring & Measurement         100       100   \-          \-      [4.5.11]{.underline}

  4.5.2        Nonconformance, Corrective &     90        80    20          \-      [4.5.21]{.underline}
               Preventive Action                                                    

  4.5.3        Records                          100       100   \-          \-      [4.5.31]{.underline}

  4.5.4        EMS Audit                        63        25    75          \-      [4.5.41]{.underline}

  4.6          Management Review                80        60    40          \-      [4.6.10]{.underline}
  ------------ -------------------------------- --------- ----- ----------- ------- ----------------------

This section compares the percentage of requirements *met*, *partially
met*, and *not met* in each element of the EMS.

> ![](media/image15.png) Hampton, Virginia

## 

## Profile

The Transportation District Commission of Hampton Roads (operating as
Hampton Roads Transit - HRT) is an independent political subdivision of
the Commonwealth of Virginia authorized by the Transportation District
Act of 1964, Code of Virginia. HRT is tasked to plan, develop, own,
improve, repair, maintain, operate, and manage a transit system in the
Hampton Roads regional area of southeastern Virginia. HRT operates in
the (7) seven cities of Hampton, Newport News, Virginia Beach,
Chesapeake, Norfolk, Portsmouth and Suffolk comprising a service area
population of 1.3 million, and over 369 square miles of urban service
area.

HRT provides all public transportation services in Hampton Roads in the
form of a fixed route bus fleet of 340 vehicles; 97 Para-transit (ADA)
vehicles; 3-river passenger ferries; 48 carpool/vanpool stands, and
other transportation services. The HRT-EMS will be incorporated into
these existing, plus all new services, including upcoming LRT and BRT as
they are developed.

**Initial EMS Project Fenceline**

The Initial EMS Fenceline for HRT is the HQ Maintenance and Operations
Facility, located at 3400 Victoria Blvd., Hampton, VA. Including the
following specific facility areas and equipment:

1.  *[Fueling Islands and Daily Service Buildings (DSB)]{.underline}*
    where HRT trained employees to fuel the bus fleet, service vehicles
    and non-revenue fleet.

2.  *[Bus Wash Facilities]{.underline}* where HRT employees operate the
    automatic bus wash equipment including waste wash water-recycling
    system.

3.  *[Diesel Fuel Delivery]{.underline}* and Storage where a local
    distributor delivers over 1.2 mil. gallons in diesel fuel and
    180,000 gallons of gasoline annually.

4.  *[Underground Storage Tanks (UST)]{.underline}* including 2 diesel
    tanks with a capacity of 24,000 gallons plus an 8,000 gal gasoline
    tank.

5.  *[Oil / Water Separators]{.underline}* for storm water runoff
    retention, processing 50 gallons per hour.

6.  *[Hydraulic Lifts]{.underline}* in the shop with 8 lift bays.

7.  *[Bus Leaks in the Yard]{.underline}* managed via active spill
    response team of trained and dedicated employees.

The goal of these Fenceline Tasks is for HRT to actively manage and
mitigate pollution and ultimately be good stewards of the environment
while setting the best example as a good corporate partner with local,
state, and federal agencies and environmental organizations.

**Core Team**

The HRT EMS Core Team is composed of four members from various
departments within the company plus an Environmental Manager from one of
the sponsoring / commission member cities. The team is led by our COO /
Vice-President of Operations, along with the Manager of Operations
Analyst, the Risk Manager, a Development Program Project Manager plus
the aforementioned environmental representative from the City of
Chesapeake, Virginia. With this Team, we are able to affect, control,
document, manage and incorporate all aspects of an EMS Program into
project planning, development, engineering, facility management,
equipment monitoring & inspection, and fleet service / operations.

**Key Drivers EMS Program: Partnerships and Ownership**

Key drivers for EMS success are the development of partnerships with
other environmental agencies as well as public entities that share our
ownership concerns for keeping our regional environment clean and
healthy. These partnerships and our memberships include:

-   HRT is a member and sponsor of the *[Elizabeth River
    Project]{.underline}*, whose mission is to preserve and protect the
    Elizabeth River running through the Hampton Roads region. HRT is
    vested in that our passenger ferry service travels many hundreds of
    trips weekly between Downtown Norfolk and Downtown Portsmouth using
    the Elizabeth River. Our Families recreate on this river, so we have
    an interest in her long-term viability and vitality.

-   Hampton Roads Transit is a partner agency with the Hampton Roads
    Sanitation District (HRSD) and has been the recipient of the *["Gold
    Pretreatment Excellence Award in 2004"]{.underline}*. Recipients of
    this award have demonstrated a significant regional commitment to
    environmental excellence in maintaining a healthy Chesapeake Bay
    estuary system.

-   HRT is in partnership with the *[Chesapeake Bay
    Foundation]{.underline}*, an organization committed to implementing
    regional pollution control and mitigation programs affecting the
    water quality of the entire Chesapeake Bay estuary system.

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-   *[HRT is an FTA Sponsored Participant]{.underline}* and member
    agency working towards the requirements of the Second EMS Initiative
    for Government Entities

-   HRT is a pledge signatory of the *[UITP Charter on Sustainable
    Development]{.underline}* with intent to reach full signatory status
    in the next few years.

Hampton Roads Transit is also committed to complete the following
specific steps toward sustainable development:

-   Establishing an EMS that complies with all applicable environmental
    legislation, regulations, internal requirements, and United States
    Federal Transit Administration standards.

-   The EMS system will allow our organization to set specific
    environmental goals for operations and measure performance in
    achieving such goals, and is based on the 14001 Standard of the
    International Organization for Standardization (ISO).

-   This EMS policy will be reviewed annually, documented and
    communicated to all Hampton Roads Transit employees and to the
    public.

-   Commitment towards identifying and implementing environmentally
    sound practices of pollution prevention, reuse, recycling and proper
    disposal methods, such as:

> \(a\) Maintain commitment to alternative fuel powered means of
> transportation (i.e. our electric buses and natural gas powered
> ferries),
>
> \(b\) Maintain our Transportation Demand Management program known as
> TRAFFIX which provides travel alternatives to the single occupant
> vehicle including, car and vanpooling, express HOV lane bus service,
> ride matching, Bike-to-Bus programs, and other programs geared to
> mitigate vehicle congestion and improve air quality, and
>
> \(c\) Implement a number of new commuter and express transit services
> including BRT and LRT Services to address the escalating traffic
> congestion and air quality problems in the region.

-   Dedicated to educating and training our employees to improve
    environmental performance and increase their awareness of
    environmental issues; educating our business partners on HRT's
    Environmental Management System; soliciting employee input for
    creating viable operational controls and for defining environmental
    roles and responsibilities for incorporation into existing work
    activities.

**Significant Aspects and Impacts**

Implementation of the *[initial phase]{.underline}* of the EMS Program
will be confined to the operations and maintenance areas of the HRT
Headquarters facility. The environmental significant aspects and impacts
to be controlled, monitored, managed and documented are:

> 1). Vehicle Parking Lot Storm-Water Runoff,
>
> 2). Vehicle Engine Air Emissions Control, and
>
> 3). Chemical Leaks and Spills Control and Abatement.

To the result of an immediate impact and mitigation of the 3 Significant
Aspects, HRT has initiated a Program to inspect and Repair the entire
114-vehicle tripper fleet within the initial Fenceline Area. Via the
process of Work Orders for Preventative Maintenance, the 1^st^ step is
to thoroughly steam-clean engines, transmissions and undercarriage while
capturing the waste water with a oil / water separator. The process
continues with a full detail and documentation of a close vehicle
inspection for leaks of oil, coolant refrigerant, hydraulic fluid, brake
fluid and other liquids. Once any leaks are identified and repaired, air
emissions are then measured and further repairs ordered as needed. The
Inspection process requires at minimum 2 hours per vehicle, even if no
shop repairs or general serviceability are needed. This Fenceline Fleet
Inspection and Repair Program will be completed by September 1, 2005.

The following List of Aspects/Issues is for future review and mitigation
by the EMS Core Team:

  ------------------------ ------------------------- -----------------------
  **Aspects Issue**        **Problem**               **Solutions
                                                     Processes/Procedure**

  **Increased computer     Mercury & silver          I.T. Awareness training
  disposal**               contamination             & proper disposal

  **Hazardous Waste        Ground water              Evaluate Training
  disposal**               contamination             

  **Mold fungi within      Sick building syndrome    Regular Inspections
  buildings**                                        

  **Leaks of CFC's in      Atmosphere Ozone          Regular Inspections
  heating, A/C systems     Depletion                 
  (HVAC)**                                           

  **Bio-hazards, body      HIV, hepatitis exposures, Evaluate and Update
  fluids, blood, etc.**    etc.                      Operator Training &
                                                     Awareness

  **Trash & dirt           Soil, surface, &          Regular Inspections
  accumulation**           groundwater contamination 

  **Oily rags & soiled     Soil, surface, &          Proper disposal
  uniforms**               groundwater contamination 

  **Paints, thinners,      Air, soil, surface and    Awareness training &
  fillers disposal**       ground water              proper disposal

  **Scrap metal & metal    Soil, surface & ground    Awareness training &
  debris**                 water pollution           proper disposal
                           associated w/land filling 
  ------------------------ ------------------------- -----------------------

![](media/image16.jpeg){width="2.7263888888888888in"
height="2.0381944444444446in"}

**Objectives and Targets**

  --------------------- ------------------------- ----------------------------
  **Objective**         **Target**                **Evaluation Process**

  **Prevent pollutants  Immediate cleanup of      Daily visual check of
  from entering the     leaks & spills; sweeping  parking lot; monthly visual
  storm drain system**  of parking lot; scrub     inspection of storm drain
                        parking lot               catch basin; monthly grab
                                                  sample and visual inspection
                                                  of runoff; favorable DEQ
                                                  audit

  **Minimize air        Purchase engines &        100 % of OEM & aftermarket
  pollution emissions   sub-components that are   components meet required
  from fleet engines**  compliant with regulatory emission regs; supervisory
                        requirements; inspections review of all PM work
                        & engine tune-ups during  orders; agency will
                        PMs; alternative fuels    participate in regional
                        usage                     environmental initiatives

  **Reduce              Maintenance supervisory   Maintenance supervisory
  occurrence/severity   review of all preventive  review of all preventive
  of fleet leaks and    maintenance work orders   maintenance work orders to
  spills**              as they are completed;    ensure inspections and parts
                        operators pre & post trip replacement are completed as
                        inspection of bus         needed; training for
                                                  operators on proper
                                                  completion of vehicle
                                                  condition reports
  --------------------- ------------------------- ----------------------------

**Benefits of Adopting and Applying an EMS**

There have been numerous important benefits to HRT from adopting an EMS.
First, bringing various departments together to address our significant
environmental aspects has created an overall enhanced awareness of
environmental issues and has fostered better communication between
departments, which will continue well past the EMS development process
into long-term benefit. Next, enlisting cooperation from all levels of
the organization within the Fenceline has allowed everyone to take
ownership of the EMS Program and everyone then strives to make it work
to the most benefit. Most importantly, the EMS Program has facilitated
HRT becoming a better steward of the natural environment. This benefits
the entire community and Eco-System.

The success of this EMS program will be measured in several ways:

-   Stakeholder feedback

-   Employee interest/feedback

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-   Visual improvements (i.e. bus emissions, storm water quality)

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```
-   Improved housekeeping

Additionally, the EMS Communications Program will have the following
measurable goals,

-   Expressions of interest from employees and external individuals in
    our program.

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```
-   The number of hits on the EMS page of the HRT website.

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```
-   Periodic surveys conducted among employees in general about HRT EMS
    communications.

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```
-   When a "Call to Action" is included in the information request, we
    will track and count the number of responses we receive to the call,
    and respond appropriately.

**Resources**

  -------------------- ------------------------ --------------------------
                       **Hours**                **Labor Costs**

  **Core Team**        789                      Not available
  -------------------- ------------------------ --------------------------

**Cost Savings**

Analyzed cost savings from decreased idling with our "*[Bus Shutdown
Campaign]{.underline}*" provides the following quantitative information:

Av. Idle "Rate of Burn" / Consumption per hr...      1.5 gph (2 hrs.) =
3 gals per 2 hrs. idle

Current Price per Gal. Diesel...                              \$2.00 per
gal. = \$3.00 per hr.

\# of hours of Idling eliminated, per bus...             x 2 hrs. daily
= 3 gals daily

\# Days per week...                                             5

\# Hrs. per week...                                               10

\# Of weeks...                                                     36

Per vehicle annual reduction in fuel use...            10 hrs per wk.
(36 wks.) = 360 hrs. Year  

Fenceline Fleet Size...                                     130 vehicles
(360 hrs. per yr.) = 46,800 hrs. per

> @ \$3.00 per hr. = \$140,400 @ 1.5 gph

                                                           

Total estimated annual cost savings (130 Tripper Vehicle Fleet) "Bus
Shutdown Campaign" is \$140,400.                                      

**Next Steps**

The HRT - EMS Core Team is working with sub-teams within the agency
Operations, Maintenance and Facilities Departments. HRT will also
continue to partner with, among other Agencies, the City of Chesapeake
and Southeastern Public Service Authority (SPSA), both currently engaged
with EMS programs of their own. With this and other ongoing Partnerships
and assistance, and the conducting and exchange of auditing and
monitoring results, we anticipate further positive input and
improvements to the program.

**HRT Audit Report**

This Environmental Management System (EMS) Audit was based on a request
by Virginia Tech (VT) and the Federal Transit Administration (FTA) as a
final follow-up to an eighteen month program for EMS development and was
conducted in accordance with the approved schedule.

Ms. Michele M. Lawton -- EMS Specialist with Virginia Tech conducted the
EMS Audit for HRT -- Hampton, VA on September 20 and 21, 2005 to report
on its conformance with the requirements of the ISO 14001:1996 standard.

The EMS was evaluated against each of the requirements set out in the
ISO 14001:1996 standard titled "Environmental management system --
Specification with guidance for use." The Audit included the examination
of documents, interviews of personnel and observations of activities and
conditions.

The site visit involved a review of the core EMS documents with the EMS
team. The HRT EMS Team participated in the review and discussion
regarding the scoring.

The following scores are the result of the EMS Assessment:

1\. The overall score for the Assessment with respect to meeting the
requirements of an EMS as specified in the ISO 14001:1996 Standard is
**seventy-two percent (72%)**.

2\. **Fifty-one percent (51%)** of the requirements were **"met."**

3\. **Forty-two percent (42%)** of the requirements were **"partially
met."**

4\. **Seven percent (7%)** of the requirements were **"not met."**

**Detailed scoring on next page.**

**HRT EMS Audit Results**

The following graph compares the total number of requirements met
*(shown in blue)* to the total number of requirements from the ISO
14001:1996 Standard *(shown in green)*.

This section compares the percentage of requirements *met*, *partially
met*, and *not met* in each element of the EMS.

  ------------ -------------------------------- --------- ----- ----------- ------- ----------------------
  The ISO                                       Overall   Met   Partially   Not Met Ref.
  14001:1996                                                                        
  Standard                                                                          
  Elements of                                                                       
  an EMS                                                                            

                                                Score (%) (%)   Met (%)     (%)     

  4.2          Environmental Policy             90        80    20          \-      [4.2.10]{.underline}

  4.3.1        Environmental Aspects            100       100   \-          \-      [4.3.11]{.underline}

  4.3.2        Legal & Other Requirements       100       100   \-          \-      [4.3.21]{.underline}

  4.3.3        Objectives & Targets             100       100   \-          \-      [4.3.31]{.underline}

  4.3.4        Environmental Management         63        25    75          \-      [4.3.41]{.underline}
               Program(s) (EMPs)                                                    

  4.4.1        Structure & Responsibility       80        60    40          \-      [4.4.11]{.underline}

  4.4.2        Training, Awareness & Competence 57        29    57          14      [4.4.21]{.underline}

  4.4.3        Communication                    83        67    33          \-      [4.4.31]{.underline}

  4.4.4        EMS Documentation                75        50    50          \-      [4.4.41]{.underline}

  4.4.5        Document Control                 71        43    57          \-      [4.4.51]{.underline}

  4.4.6        Operational Control              88        75    25          \-      [4.4.61]{.underline}

  4.4.7        Emergency Preparedness &         100       100   \-          \-      [4.4.71]{.underline}
               Response                                                             

  4.5.1        Monitoring & Measurement         50        \-    100         \-      [4.5.11]{.underline}

  4.5.2        Nonconformance, Corrective &     40        \-    80          20      [4.5.21]{.underline}
               Preventive Action                                                    

  4.5.3        Records                          57        14    86          \-      [4.5.31]{.underline}

  4.5.4        EMS Audit                        13        \-    25          75      [4.5.41]{.underline}

  4.6          Management Review                50        20    60          20      [4.6.10]{.underline}
  ------------ -------------------------------- --------- ----- ----------- ------- ----------------------

# **[Massachusetts Bay Transportation Authority (MBTA)]{.smallcaps}**

# **[Boston, Massachusetts]{.smallcaps}**

![](media/image17.jpeg){width="6.338888888888889in"
height="2.015972222222222in"}

**Profile**

# In 1897, America's first subway was constructed between Park Street and Boylston Street in Boston, Massachusetts. This half-mile section of subway is still operated today by the MBTA, making the MBTA the oldest continuously operating subway system in the country. In the 108 years since this service opened, Boston's public transportation system has remained a critical part of the city, and has grown dramatically in response to an ever-increasing demand for transportation services. The MBTA now serves 175 communities, providing transit alternatives to a population of 4.7 million over an area of 3,200 square miles. 

# 

# Currently, the MBTA is the fifth largest mass transit system in the United States as measured by ridership. The Authority serves a daily ridership of approximately 1.2 million passengers. To provide these services the Authority maintains 200 bus routes, 4 rapid transit lines of heavy and light rail, 1 bus rapid transit line, 4 trackless trolley lines, 11 commuter rail lines, several ferry lines and a paratransit service. Its large roster of equipment currently consists of 408 heavy rail vehicles, 204 light rail vehicles, 927 diesel buses, 61 compressed natural gas (CNG) buses, 2 prototype alternative fuel buses, 40 trackless trolleys, 80 commuter rail locomotives, 377 commuter rail coaches, 2 ferry boats, and 418 vehicles for the RIDE. Service is provided to 275 stations. The Authority maintains 885 miles of track, 478 bridges, and 20 miles of tunnels. System expansion efforts over the next five years include two new commuter rail lines and the new Silver Line. The MBTA operates 19 commuter rail, light/heavy rail and bus maintenance facilities, numerous right-of-way (ROW) maintenance facilities, and currently has 6,000+ employees. 

# 

# A nine member Board of Directors manages the affairs of the Authority. The Secretary of the Commonwealth's Executive Office of Transportation (EOT) chairs the Board. The Governor on a rotating schedule appoints the remaining members of the Board. The Board has the power to appoint and employ a General Manager and other officers and approves all capital investments over \$500,000. The MBTA has an Advisory Board, consisting of representatives from each of the cities and towns within the MBTA's service area that approves the annual operating budget and reviews the five-year Capital Investment Program. 

# 

# In 1999, the Governor of Massachusetts signed into law legislation reforming the finances of the MBTA. This new law, known as "Forward Funding" established a new funding mechanism as of July 1, 2000. MBTA funding is now limited to: fares and other own source revenues, 20% of the state-wide sales tax, and assessments from the 175 cities and towns in its service district.

## Fenceline

The MBTA selected two facilities, the Wellington Carhouse Maintenance
Facility (Wellington) and the Albany Street Bus Garage Facility (Albany)
respectively, to represent Subway Operations and Bus Operations for its
fenceline.

**[Wellington]{.underline}** was constructed in 1975; the 135,500 square
foot maintenance facility is located along the northern bank of the
Mystic River. The facility services the 120 car Orange Line Fleet that
transports 164,000 weekday passengers and Maintenance of Way Equipment.
Wellington currently has 50 employees consisting of mechanics, trades
people, car cleaners, foremen, administrators, and managers. Wellington
operates 24 hours.

![](media/image18.jpeg){width="4.0256944444444445in"
height="1.7833333333333334in"}

**Wellington Orange Line**

![](media/image19.jpeg){width="4.0256944444444445in"
height="1.9673611111111111in"}**[Albany]{.underline}** was constructed
in 1937 originally designed to handle 37 buses, it currently houses 139
buses with a 24-hour operation Monday thru Friday. Albany has 44
employees consisting of

buses with a 24-hour operation Monday thru Friday. Albany has 44
employees consisting of mechanics, trades people, car cleaners, foreman,
administrators and mangers, along with 100 bus operators drawn from a
pool of 500 operators in conjunction with a nearby facility. The age of
this facility combined with the current number of buses it services
along with the large number of bus operators operating out of Albany
make this a challenging facility to develop and implement an EMS.

## Core Team

The MBTA formed a seven-member core team to travel to Roanoke, Virginia
for EMS training. The core team consisted of two representatives from
the Environmental Affairs Department, two representatives from Subway
Operations, two representatives from Bus Operations, and one
representative from Operation and Support:

Assistant General Manager for Environmental Affairs

Environmental Counsel

Chief Mechanical Officer, Subway Operations

Superintendent, Orange Line (Subway)

Deputy Chief Mechanical Officer Bus Operations

Superintendent Bus Operations

Environmental Coordinator, Operations and Support

Upon return to the Authority, the Core Team was expanded to include
additional members representing Subway Operations, Bus Operations,
Environmental Department, Safety Department, and Labor Relations. The
Core Team established a standing meeting every Thursday morning.
Additionally each fenceline facility established an Environmental
Sub-team. The Sub-teams consisted of employees at each facility
representing all operations and trades conducted at the facility.
Members of the Core Team meet with the Sub-teams on a regular basis as a
way of tracking progress at each facility.

## Key Drivers for Adopting an EMS

The MBTA began its efforts to develop an EMS in 2002 with the adoption
of our Environmental Policy. Our commitment to develop an EMS was
further solidified and formalized in a Settlement Agreement with the
Massachusetts Department of Environmental Protection (DEP) and in a
Consent Decree with the United States Department of Justice (DOJ) and
the United States Environmental Protection Agency Region 1 (EPA). The
settlement with DEP involved soil contamination at an old rail yard
acquired by the MBTA through the Penn Central Railroad Bankruptcy
Proceedings.

The Consent Decree with the DOJ and EPA stemmed from violations of the
Clean Water Act (CWA) and the Clean Air Act (CAA). The CWA violations
involved the un-permitted discharging of process water and storm water
associated with industrial activity, the failure to prepare Spill
Prevention Control and Countermeasure (SPCC) plans, and the failure to
prepare Storm Water Pollution Prevention Plans (SWPPP). The CAA
violation involved the excessive idling of 56 buses at four MBTA Bus
Yards. In Massachusetts, the operator of a motor vehicle is not
permitted to unnecessarily operate "the engine of a motor vehicle while
said vehicle is stopped for a foreseeable period of time in excess of
five minutes." (310 CMR 7.11)

The Agreement/Consent Decree contain specific requirements for the
content of our EMS as well as a definite schedule for development,
implementation and audit of our EMS. Under these agreements, the MBTA is
required to conduct initial assessments and develop a Pilot EMS Manual
at Wellington and Albany. The Pilot EMS Manual shall be submitted to EPA
and DEP for comment. Once the MBTA implements the Pilot EMS Manual at
Wellington and Albany, the MBTA will then roll out the EMS System-wide
in three phases (Phase I -- 5 additional facilities, Phase II -- 6
additional facilities, Phase III -- 5+ facilities).

## 

## Significant Aspects & Impacts 

Members of the Core Team met with Environmental Sub Teams at both
Wellington and Albany. After reviewing operations and processes within
both facilities, many environmental aspects and impacts were identified.
To determine the significance of each aspect the Sub Teams scored them
using a numerical weighting system on a matrix answering the following
questions:

1.  Is the aspect regulated?

2.  Does the aspect pose a potential environmental impact?

3.  Is the aspect associated with a legal obligation?

4.  Is there significant financial risk or an opportunity to control the
    aspect?

For the development of our EMS, the MBTA selected the four most
significant aspects identified at the fenceline facilities, and
established objectives and targets to improve our environmental
performance of each.

![](media/image20.wmf)

# 

# Objectives and Targets 

+-------------+-------------+----------------------+------------------+
| **Aspect**  | **O         | **Targets**          | **Results**      |
|             | bjectives** |                      |                  |
+=============+=============+======================+==================+
| **Hazardous | Improve the | -   Identify         | -   Conducted    |
| Materials   | management  |     personnel to be  |     Compliance   |
| Handling**  | of          |     trained          |     Training     |
|             | petroleum   |                      |                  |
|             | products    | -   Develop training | -   Conducted    |
|             | and         |     module           |     EMS          |
|             | hazardous   |                      |     Awareness    |
|             | materials   | -   Determine        |     Training     |
|             | (In         |     training         |                  |
|             | Mas         |     schedule         | -   Trained      |
|             | sachusetts, |                      |     employees on |
|             | waste oil   | -   Conduct Subway   |     Standard     |
|             | is          |     employee         |     Opera- ting  |
|             | considered  |     training         |     Procedures   |
|             | a hazardous |                      |     (SOPs)       |
|             | waste.)     | -   Conduct Bus      |                  |
|             |             |     employee         |                  |
|             |             |     training         |                  |
|             |             |                      |                  |
|             |             | -   Train 100% of    |                  |
|             |             |     affected         |                  |
|             |             |     employee         |                  |
+-------------+-------------+----------------------+------------------+
| **Washing   | Ensure      | -   Develop baseline | -   Improved     |
| Trains**    | compliance  |     and obtain last  |     knowledge of |
|             | with water  |     quarterly        |     our          |
| **and       | discharge   |     sampling results |                  |
| Buses**     | standards   |                      |    pre-treatment |
|             |             | -   Obtain           |     systems for  |
|             |             |     schematics of    |     our vehicle  |
|             |             |     treatment        |     washes       |
|             |             |     systems          |                  |
|             |             |                      | -   Trained      |
|             |             | -   Evaluate         |     employees on |
|             |             |     baseline data to |     SOPs         |
|             |             |     determine        |                  |
|             |             |     patterns of      | -   No           |
|             |             |     discharge        |     violations   |
|             |             |                      |     to date      |
|             |             | -   Establish        |                  |
|             |             |     standard         |                  |
|             |             |     operating        |                  |
|             |             |     procedure        |                  |
|             |             |                      |                  |
|             |             | -   Evaluate and     |                  |
|             |             |     audit vehicle    |                  |
|             |             |     washes after one |                  |
|             |             |     year             |                  |
+-------------+-------------+----------------------+------------------+
| **Start Up  | Reduce bus  | -   Develop training | -   Developed    |
| and         | idling      |     video for bus    |     training     |
| Operation   |             |     operators        |     video        |
| of Buses**  |             |                      |                  |
|             |             | -   Train bus        | -   Trained      |
|             |             |     operators        |     operators at |
|             |             |                      |     Pilot        |
|             |             | -   Develop standard |     Facilities   |
|             |             |     operating        |                  |
|             |             |     procedure for    | -   Trained      |
|             |             |     bus operators    |     additional   |
|             |             |                      |     operators,   |
|             |             | -   Monitor peak     |     outside of   |
|             |             |     pull out periods |     fenceline    |
+-------------+-------------+----------------------+------------------+
| **Water     | Create      | -   Confirm location | -   Trained      |
| D           | water       |     of all           |     employees on |
| ischarges** | discharge   |     industrial and   |     requirements |
|             | permit      |     storm water      |     of SWPPP,    |
|             | tracking    |     discharges       |     SPCC and     |
|             | database    |                      |     NPDES        |
|             |             | -   Confirm permit,  |     permits      |
|             |             |     Storm water      |                  |
|             |             |     Pollution        | -   Increased    |
|             |             |     Prevention Plan  |     know-ledge   |
|             |             |     (SWPPP) and      |     of           |
|             |             |     Spill Prevention |     permitting   |
|             |             |     Control and      |                  |
|             |             |     Countermeasure   |    requirements, |
|             |             |     Plan (SPCC) for  |     plans and    |
|             |             |     each facility    |     water        |
|             |             |                      |     discharges   |
|             |             | -   Insure facility  |                  |
|             |             |     training on      |                  |
|             |             |     SWPPP and SPCC   |                  |
|             |             |                      |                  |
|             |             | -   Track and        |                  |
|             |             |     evaluate all     |                  |
|             |             |     permits, SWPPP   |                  |
|             |             |     and SPCC Plans   |                  |
+-------------+-------------+----------------------+------------------+

### 

### Benefits of Adopting an EMS 

MBTA has realized a number of immediate benefits resulting from
instituting an EMS at the fenceline facilities. These benefits include:

-   The creation of the Core Team and the development of the EMS have
    improved communications across departments at the MBTA.

-   The increased and improved understanding of all operations at the
    MBTA, specifically by employees of different departments.

-   The development of Standard Operating Procedures has allowed the
    MBTA to better retain and document institutional knowledge.

-   The increased enthusiasm and pride in how employees do their job.

-   The improved control and inventory of documentation.

-   The improved knowledge by all employees of environmental aspects and
    impacts.

## 

## Resources 

To date, the MBTA expended the following level of effort (estimated in
hours) in the development of the EMS:

Core Team 2,610

Sub Teams 2,532

Other Personnel 95

Consultants 695

To date, the MBTA incurred the following estimated cost in the
development of the EMS:

MBTA Labor \$163,600.20

Travel/Supplies \$ 50,617.57

Consultant/Training \$ 52,194.00

**Cost Savings or Avoidance**

By developing our EMS internally, we believe we have not only learned
valuable management tools to apply throughout our organization, but
additionally we saved extensively on outside services.

The focus of our EMS is compliance, and as such, our major environmental
initiatives have focused on improved environmentally compliant
operations and performance, as well as improved relations with federal,
state and local regulators. Compliance-based objectives and targets are
difficult to quantify, one known cost savings is reduced fines and
penalties.

One clear improvement in our daily operations is the reduction in idling
times of our buses. Since focusing our efforts on training and standard
operating procedures to reduce and monitor the idling of our buses, we
have observed improvements at our bus yards and layover areas.

We believe we can conservatively state that we have on average reduced
the unnecessary idling of our buses by at least 15 minutes per bus per
day.

Assuming:

1.  The average fuel saving on consumption per bus for 15 minutes is
    0.20 gallons per day;

2.  The average cost for diesel (ultra low sulfur) is \$2.06/gal;

3.  The average cost for CNG is \$2.03 per gallon equivalent.

4.  No calculation is available for emission reduction

**Calculation**:

Cost saving for diesel bus per date: 0.2 gal x \$2.06= \$0.42

Cost saving for 549 diesel bus on weekday per year: 549 x \$0.42 x 261
(week

> days/year) = **\$59,035**

Cost saving for 289 diesel bus on weekend per year: 289 x \$0.42 x 104
(weekend

days/year) = **\$12,623**

**[Annual Cost Savings for Diesel Bus Fleet :]{.underline}**
[\$59,035]{.underline} **+** [\$12,623]{.underline} **=
[\$71,658]{.underline}**

Cost saving for CNG bus per date: 0.2 gal x \$2.03 = \$0.41

Cost saving for 300 CNG bus on weekday per year: 300 x \$0.41 x 261

(Weekdays/year) = **\$32.103**

Cost saving for 300 CNG bus on weekend per year: 300 x \$0.41 x 104

(Weekend days/year) = **\$12,792**

**[Annual Cost Savings for CNG Bus Fleet:]{.underline}**
[\$32,103]{.underline} + [\$12,792]{.underline} **=
[\$44,895]{.underline}**

**Annual Total Cost Savings for Entire Bus Fleet:
[\$116,553]{.underline}**

## Next Steps

It is anticipated that the EMS for the fenceline facilities will be
operational by the summer of 2006. The MBTA is committed to implementing
a system-wide EMS over the next five years. The EMS implemented at the
fenceline facilities will be evaluated annually by the MBTA Core Team
and fenceline facility superintendent.

The MBTA has developed a Pilot EMS Manual, as well as an Environmental
Management System page on our Portal. The MBTA Portal is an online
resource that provides information to employees via the web-browser, 24
hours a day, 7 days a week. The MBTA is currently working to incorporate
the SOPs, Environmental Procedures, and Programs developed during this
FTA EMS Implementation Course into our Pilot EMS Manual. We have found
both our EMS Manual and the Portal useful tools for EMS Training and
Documentation.

## Management Commitment 

*"The FTA/Virginia Tech training and assistance helped us to make our
EMS not only effective but [real]{.underline}. The management and
training skills we learned have greatly helped us to clearly measure and
improve our performance."*

**Robert Doyle**, Superintendent, Orange Line Maintenance

The Senior Management at the MBTA is committed to implementing a
successful EMS.

The Board of Directors recently hired Daniel Grabauskas as General
Manager to replace Michael Mulhern, who retired in May 2005. Mr.
Grabauskas previously served as the Secretary of EOT when the MBTA
adopted its Environmental Policy. The new General Manager has made
eliminating negative environmental impacts as one of the things that
will make the MTBA, a world class world ld-class public transportation
system.

![](media/image21.jpeg){width="0.39375in"
height="0.38680555555555557in"}

**MBTA Audit Report**

This Environmental Management System (EMS) Audit was based on a request
by Virginia Tech (VT) and the Federal Transit Administration (FTA) as a
final follow-up to an eighteen month program for EMS development and was
conducted in accordance with the approved schedule.

Ms. Michele M. Lawton -- EMS Specialist with Virginia Tech conducted the
EMS Audit for MBTA on October 24 and 25, 2005 to report on its
conformance with the requirements of the ISO 14001:1996 standard.

The EMS was evaluated against each of the requirements set out in the
ISO 14001:1996 standard titled "Environmental Management System --
Specification with guidance for use." The Audit included the examination
of documents, interviews of personnel and observations of activities and
conditions.

The site visit involved a review of the core EMS documents with the EMS
team. The MBTA EMS Team participated in the review and discussion
regarding the scoring. The following scores are the result of the EMS
Audit for the **Wellington** facility:

1\. The overall score with respect to meeting the requirements of an EMS
as specified in the ISO 14001:1996 Standard is **ninety-six percent
(96%)**.

2\. **Ninety-two percent (92%)** of the requirements were **"met."**

3\. **Eight percent (8%)** of the requirements were **"partially met."**

**Detailed scoring on next page.**

**MBTA EMS Audit Results**

The following graph compares the total number of requirements met
*(shown in blue)* to the total number of requirements from the ISO
14001:1996 Standard *(shown in green)*.

This section compares the percentage of requirements *met*, *partially
met*, and *not met* in each element of the EMS.

  ------------ ------------------------------- --------- ----- ----------- ------- ----------------------
  The ISO                                      Overall   Met   Partially   Not Met Ref.
  14001:1996                                                                       
  Standard                                                                         
  Elements of                                                                      
  an EMS                                                                           

                                               Score (%) (%)   Met (%)     (%)     

  4.2          Environmental Policy            100       100   \-          \-      [4.2.10]{.underline}

  4.3.1        Environmental Aspects           100       100   \-          \-      [4.3.11]{.underline}

  4.3.2        Legal & Other Requirements      100       100   \-          \-      [4.3.21]{.underline}

  4.3.3        Objectives & Targets            100       100   \-          \-      [4.3.31]{.underline}

  4.3.4        Environmental Management        100       100   \-          \-      [4.3.41]{.underline}
               Program(s) (EMPs)                                                   

  4.4.1        Structure & Responsibility      100       100   \-          \-      [4.4.11]{.underline}

  4.4.2        Training, Awareness &           100       100   \-          \-      [4.4.21]{.underline}
               Competence                                                          

  4.4.3        Communication                   100       100   \-          \-      [4.4.31]{.underline}

  4.4.4        EMS Documentation               75        50    50          \-      [4.4.41]{.underline}

  4.4.5        Document Control                93        86    14          \-      [4.4.51]{.underline}

  4.4.6        Operational Control             100       100   \-          \-      [4.4.61]{.underline}

  4.4.7        Emergency Preparedness &        100       100   \-          \-      [4.4.71]{.underline}
               Response                                                            

  4.5.1        Monitoring & Measurement        88        75    25          \-      [4.5.11]{.underline}

  4.5.2        Nonconformance, Corrective &    100       100   \-          \-      [4.5.21]{.underline}
               Preventive Action                                                   

  4.5.3        Records                         100       100   \-          \-      [4.5.31]{.underline}

  4.5.4        EMS Audit                       63        25    75          \-      [4.5.41]{.underline}

  4.6          Management Review               90        80    20          \-      [4.6.10]{.underline}
  ------------ ------------------------------- --------- ----- ----------- ------- ----------------------

![](media/image22.jpeg){width="1.3791666666666667in"
height="0.9423611111111111in"}

City of Phoenix Public Transit Department

Phoenix, AZ

**Profile**

The city of Phoenix, located in Maricopa County, encompasses 514 square
miles and has a population of 1.4 million, making it the fifth largest
city in the nation. The City of Phoenix Public Transit Department
operates and maintains the largest bus fleet in the metropolitan area
with two transit maintenance facilities, 464 buses and an average daily
ridership of 118,225. Phoenix Public Transit services include local bus
service, RAPID (commuter bus), DASH (downtown area shuttle), ALEX
(neighborhood circulator), and Dial-a-Ride. METRO, a light rail system,
is currently under construction and will serve Phoenix, Glendale, Tempe
and Mesa. ![](media/image23.jpeg){width="2.2395833333333335in"
height="1.65in"}

In recent elections, Phoenix and area voters approved measures that
provide for transit and roadway improvements needed to keep up with the
area's growing population. In March 2000, Phoenix voters approved
*Transit 2000,* a plan that provided 4/10 of a percent local sales tax
for public transit improvements. *Transit 2000* provided for additional
local and commuter buses and Dial-a-Ride vehicles, increased frequency
and hours of service, and other transit improvements including
[METRO](http://www.valleymetro.org/rail/), the regional light rail
system.

In November 2004, voters approved the Regional Transportation Plan, a
multi-modal plan that provides for buses, park-and-ride facilities,
METRO, as well as other transit and roadway improvements in Maricopa
County through the year 2026. Other exciting Phoenix Transit projects
include the construction of a West Operating facility to add maintenance
and operations capability to the existing two maintenance
facilities.![](media/image24.jpeg){width="5.097222222222222in"
height="1.8340277777777778in"}

#### Fenceline

Phoenix Public Transit selected the South Operating Facility (2225 W.
Lower Buckeye Rd, Phoenix, AZ) to serve as the EMS fenceline facility.
The South Operating Facility is the larger of two maintenance and
operating facilities that currently serve Phoenix Public Transit. The
facility is approximately 15-acres in size and is open 24 hours, 7 days
a week. ATC Phoenix, under contract with the City of Phoenix, provides
fenceline facility operations. The facility has 130 maintenance
employees and serves approximately 245 buses. Components of the
fenceline facility include service and cleaning for the facility and
vehicles, maintenance for buses and support equipment, body and paint
shop operations, administrative services, revenue collection, and parts
storage and distribution.

#### Core Team

####  

The Core Team consists of five people selected from Phoenix Public
Transit, ATC Phoenix and the City of Phoenix Office of Environmental
Programs. The EMS Management Representative is the designated Core Team
Leader. Core Team members for 2004/2005:

-   Rob Cox, ATC Phoenix Environmental Administrator

-   Reed Caldwell, City of Phoenix Public Transit Department EMS
    Management Representative

-   Monica Rabb, City of Phoenix Office of Environmental Programs EMS
    Auditor

-   Amanda Luecker, City of Phoenix Public Transit Department EMS
    Coordinator

-   Larry Kucera, ATC Phoenix Management Representative

The City of Phoenix created an Environmental Team consisting of a
collection of employees responsible for the daily implementation of the
EMS. Many of the Environmental Team members work at the fenceline
facility and make regular reports on EMS progress to the Core Team. The
Core Team and Environmental Team met weekly, or bi-weekly, as needed
during the first year of EMS implementation.

**Key Drivers for Adopting an EMS**

The Federal Transit Administration's invitation to participate in the
EMS program was the key external driver for adopting the EMS. Internal
drivers included:

-   Developing a Public Transit Department environmental policy.

-   Increasing awareness of employee environmental roles and
    responsibilities.

-   Improving internal communication of environmental issues.

-   Improving fenceline facility compliance with environmental
    regulations.

**Significant Aspects and Impacts**

The 2004-2005 EMS significant aspects are:

a.  Purchasing of Hazardous Materials

b.  Waste Stream Identification

c.  Energy Use

d.  Paper and Cardboard Recycling

e.  Parts Cleaning Solvent

The Core Team began the aspect identification process by introducing the
EMS program to fenceline employees and asking them to identify
environmental impacts from their daily activities. Fenceline supervisors
met with the Core Team and used their understanding of employee
identified impacts, combined with other considerations such as severity
of impact, cost and feasibility to narrow the original list of aspects
to the top thirteen for rating against EMS criteria. The Core Team rated
each of the thirteen aspects against criteria such as environmental,
business and legal impacts to reach agreement on the top five aspects
selected for action in the 2004-2005 EMS programs. The remaining eight
aspects will be carried over to 2005-2006 for consideration along with
any newly identified items.

**Benefits of Adopting an EMS**

The City of Phoenix Public Transit Department South Operating Facility
benefited from the adoption of an EMS. Some of these benefits are
tangible; however others involve changes to daily employee behaviors and
improved overall awareness of how transit operations impact the
environment. Some of the benefits of the EMS include:

-   Cost savings

-   Reduced risk

-   Increased operational efficiency

-   Positive external relations and public image

-   Improved communication

-   Greater employee stewardship

-   Shared environmental solutions

-   Improved public relations

**Resources**

The number of hours associated with the development and implementation
of the Phoenix EMS from March 1^st^, 2004 to June 1^st^, 2005 are listed
below.

  ----------------------------------- -----------------------------------
  **Core Team and Environmental Team  
  EMS Hours and Wages (March 2004 to  
  June 2005)**                        

  TOTAL hours                         **2530**

  TOTAL Internal Labor Cost           **\$101,700.00**
  ----------------------------------- -----------------------------------

Personnel working on the implementation of the EMS include Phoenix
Public Transit Department upper management and staff. An Environmental
Specialist from the City's Office of Environmental Programs participated
as a Core Team member. The EMS has received considerable support from
ATC Phoenix, including participation on the Core Team by the ATC Phoenix
General Manager and Risk Manager. As the EMS moved into its
implementation phase, staff began regular meetings with an Environmental
Team comprised of ATC supervisory personnel and other employees.

**Cost Savings or Avoidance**

Cost savings or avoidance could be calculated in some circumstances
after the first year of EMS implementation. Other EMS activities
resulted in baselines and recommendations for future improvements. First
year EMS cost savings, avoidance and recommendations included:

-   Staff implemented a paper and cardboard recycling program at no
    charge to the fenceline facility. The program began with 0 lbs.
    recycled in August 2004 to a total of 15,590 lbs. recycled through
    the end of December 2005.

-   Staff completed the waste stream identification aspect and developed
    a baseline for evaluating disposal activities. The aspect has future
    cost avoidance potential because it resulted in recommendations for
    more efficient and environmentally friendly disposal methods.

-   Employees at the fenceline facility noticed improved employee and
    contractor awareness of environmental impacts from transit
    operations and increased opportunities for environmentally
    preferable and/or cost saving work procedures. To date, 445
    employees received EMS General Awareness Training. Improved employee
    environmental awareness resulted in positive changes that benefit
    the environment but are difficult to assign a dollar value.

-   The fenceline facility Energy Management Team reduced energy use at
    the fenceline facility, which resulted in a cost savings of
    approximately \$34,000 fiscal year to date when compared to average
    energy use over the prior three years. The EMS Energy Management
    Team is currently exploring options for future energy use
    reductions.

-   The City of Phoenix Public Transit Department purchased five new
    aqueous-based parts washers in FY05-06 at a total cost of \$22,000.
    It is expected that replacement of solvent-based parts washers with
    the new machines will lower servicing fees by \$15,000 per year. In
    addition, the aqueous-based washers will reduce the amount of
    solvent used by over 3,000 gallons per year.

![](media/image25.wmf){width="6.2652777777777775in"
height="4.281944444444444in"}

**Next Steps**

Continuation of environmental stewardship is vital to the success of our
organization. As we extend our rehabilitated environmental interest
throughout the organization more innovative means and methods will allow
continual improvements. A simple aspect as recycling has given renewed
significance to protecting our environment.

Future facilities will open with an environmental plan in place. A
department-wide environmental management system will incorporate all
department facilities. Implementation of these goals is dependent upon
additional staff to create and ensure continual monitoring of the EMS.

**Management Commitment**

**City of Phoenix Public Transit Department Audit Report**

This Environmental Management System (EMS) Audit was based on a request
by Virginia Tech (VT) and the Federal Transit Administration (FTA) as a
final follow-up to an eighteen month program for EMS development and was
conducted in accordance with the approved schedule.

Ms. Michele M. Lawton -- EMS Specialist with Virginia Tech conducted the
EMS Audit for the City of Phoenix, Phoenix, AX on August 22 and 23, 2005
to report on its conformance with the requirements of the ISO 14001:1996
standard.

The EMS was evaluated against each of the requirements set out in the
ISO 14001:1996 standard titled "Environmental Management System --
Specification with guidance for use." The Audit included the examination
of documents, interviews of personnel and observations of activities and
conditions.

The site visit involved a review of the core EMS documents with the EMS
team. The Phoenix EMS Team participated in the review and discussion
regarding the scoring.

The following scores are the result of the EMS Assessment:

1\. The overall score for the Assessment with respect to meeting the
requirements of an EMS as specified in the ISO 14001:1996 Standard is
**one-hundred percent (100%)**.

2\. The City of Phoenix Public Transit facility has **met all** of the
requirements specified in the ISO 14001;1996 Standard and may wish to
consider seeking registration or making a self-declaration to the
standard.

**Detailed scoring on next page**.

**City of Phoenix Public Transit Department EMS Audit Report**

The following graph compares the total number of requirements met
*(shown in blue)* to the total number of requirements from the ISO
14001:1996 Standard *(shown in green)*.

This section compares the percentage of requirements *met*, *partially
met*, and *not met* in each element of the EMS.

  ------------ --------------------------------- --------- ----- ----------- ------ ----------------------
  The ISO                                        Overall   Met   Partially   Not    Ref.
  14001:1996                                                                 Met    
  Standard                                                                          
  Elements of                                                                       
  an EMS                                                                            

                                                 Score (%) (%)   Met (%)     (%)    

  4.2          Environmental Policy              100       100   \-          \-     [4.2.10]{.underline}

  4.3.1        Environmental Aspects             100       100   \-          \-     [4.3.11]{.underline}

  4.3.2        Legal & Other Requirements        100       100   \-          \-     [4.3.21]{.underline}

  4.3.3        Objectives & Targets              100       100   \-          \-     [4.3.31]{.underline}

  4.3.4        Environmental Management          100       100   \-          \-     [4.3.41]{.underline}
               Program(s) (EMPs)                                                    

  4.4.1        Structure & Responsibility        100       100   \-          \-     [4.4.11]{.underline}

  4.4.2        Training, Awareness & Competence  100       100   \-          \-     [4.4.21]{.underline}

  4.4.3        Communication                     100       100   \-          \-     [4.4.31]{.underline}

  4.4.4        EMS Documentation                 100       100   \-          \-     [4.4.41]{.underline}

  4.4.5        Document Control                  100       100   \-          \-     [4.4.51]{.underline}

  4.4.6        Operational Control               100       100   \-          \-     [4.4.61]{.underline}

  4.4.7        Emergency Preparedness & Response 100       100   \-          \-     [4.4.71]{.underline}

  4.5.1        Monitoring & Measurement          100       100   \-          \-     [4.5.11]{.underline}

  4.5.2        Nonconformance, Corrective &      100       100   \-          \-     [4.5.21]{.underline}
               Preventive Action                                                    

  4.5.3        Records                           100       100   \-          \-     [4.5.31]{.underline}

  4.5.4        EMS Audit                         100       100   \-          \-     [4.5.41]{.underline}

  4.6          Management Review                 100       100   \-          \-     [4.6.10]{.underline}
  ------------ --------------------------------- --------- ----- ----------- ------ ----------------------

![](media/image26.png){width="2.28125in"
height="0.3645833333333333in"}**Seattle, Washington**

# **Profile**

![](media/image27.jpeg){width="2.3375in"
height="1.4736111111111112in"}The Puget Sound region of western
Washington is characterized by natural beauty: cool ocean waters,
glistening lakes, and snow-capped mountains are the natural backdrop of
life in the Pacific Northwest. Navigating around this region involves
bridges, tunnels and ferries, and two main interstates on either side of
Lake Washington. In the midst of this natural beauty lie the three most
urbanized counties and the bulk of Washington State's population. This
region has experienced tremendous growth since the late 1980's, fueled
by the notoriety of being named one of the country's best places to
live.

The region's transportation infrastructure has not kept pace with
population growth, however, leading to significant and worsening traffic
congestion. In 1993, the Councils in King, Pierce and Snohomish counties
voted to participate to form a single transit authority -- Sound Transit
-- to implement high capacity transit alternatives in this fast-growing
region.

In November 1996, voters in King, Pierce and Snohomish Counties approved
a new local tax giving Sound Transit the authority to implement Sound
Move, a comprehensive regional transit plan encompassing almost 100
separate but interrelated transportation improvements. Some of the
highlights of this multi-modal plan include:

-   A new 14-mile "Link" light rail system from Seattle to Sea-Tac
    Airport and one-mile light rail line in the city of Tacoma;

-   An 81-mile "Sounder" commuter rail system using the existing freight
    railroad from Everett to Seattle to Tacoma to Lakewood; and

-   ST Regional express bus service connecting urban centers throughout
    the service area, including design and construction of
    high-occupancy vehicle (HOV) lanes for buses and carpools,
    park-and-ride lots, transit centers, and access improvements.

![](media/image28.jpeg){width="2.3305555555555557in"
height="1.6902777777777778in"}

The value of all of these improvements is approximately \$13 billion.
Nineteen ST Express bus routes and more than 80 miles of commuter rail
service currently are operating, with additional service increasing over
time. Light rail service is operating in Tacoma and will be operating in
Seattle in 2009. With the exception of the Tacoma light rail system,
Sound Transit does not directly operate the service but instead
contracts with transit partners and the Burlington Northern Santa Fe
Railway. System-wide ridership in the first quarter of 2005 was 2.6
million riders, or approximately 36,000 riders per day.

Since inception, Sound Transit has focused primarily on planning,
design, and construction. Construction activities have been underway in
the Sounder commuter rail program and the ST Express program, but the
primary responsibility has been handled by our project partners, the
Burlington Northern Santa Fe Railway Company and the Washington State
Department of Transportation. The construction of Tacoma Link was
handled in-house and was completed in

2003\. In 2004, significant construction activities were initiated for
the rest of the Link light rail project, and the construction will
continue until 2009. System operations are contracted to local transit
agencies that operate complementary transit services for the region.

Sound Transit is governed by an 18-member Board of Directors comprising
local elected officials and the Washington State Secretary of
Transportation. Board representation includes mayors, city council
members, county executives, and county council members from within the
Sound Transit service area. Sound Transit also strongly believes in
independent outside oversight: the agency is overseen by a Citizen
Oversight Panel that examines tough Sound Transit issues from an expert
outside perspective; The Citizens\' Accessibility Advisory Committee
that promotes mobility and transit accessibility for the disabled and
elderly in our communities; and the Performance Audit Committee that
provides an independent, third party review of management\'s
performance, including efficiency of operations, effectiveness in
achieving desired results, and compliance with relevant policies, laws
and regulations. Approximately 350 people are employed at Sound Transit.
More information on Sound Transit background, projects and recent news
is located at
[***www.soundtransit.org***](http://www.soundtransit.org/).

# **Fenceline**

Unlike other transit agencies that draw an EMS fenceline around
operations or maintenance facilities, Sound Transit has established its
fenceline around environmental compliance activities that occur mostly
during planning, design and construction rather than operations and
maintenance. These activities are those handled or supported by Sound
Transit's Environmental Compliance Division, and include a broad array
of environmental services and programs, such as environmental impact
assessment, environmental permitting, hazardous waste management,
natural resources mitigation, regulation of threatened and endangered
species, historic and cultural resource evaluation, conformity with
clean air requirements, storm water management and compliance, and
cleanup of contaminated properties.

# **Core Team**

#  

The Sound Transit EMS Core Team is referred to as the EMS Steering
Committee, and is comprised of personnel representing the various
departments within the Agency. It includes eight full-time members
including staff from the Environmental Compliance Division,
representatives from each of the capital project departments (commuter
rail, express bus, and light rail), systems operation and project
delivery support services. The Environmental Compliance Manager is the
chair of the EMS Steering Committee.

Adjunct to the EMS Steering Committee are subcommittees that focus on
developing and implementing operational controls for each significant
aspect. Each subcommittee, composed of between three to seven members,
is chaired by the member of the EMS Steering Committee whose daily work
pertains to the aspect. The subcommittees are responsible for
development of detailed work instructions. The work performed by
subcommittees is brought before the EMS Steering Committee for review
and approval.

Sound Transit chose to appoint an eight-member steering committee rather
than a typical four-person team because of a desire to encourage
involvement in EMS from capital development, project delivery, and
operations departments as well as from environmental staff.

# 

# **Key Drivers for Adopting an EMS**

Sound Transit recognizes that a healthy and sustainable environment is
important to our economy, our future, and the citizens of the Puget
Sound region. We have devoted our best efforts and attention to managing
environmental resources for the benefit and enjoyment of current and
future generations. Consistent with our environmental commitment, and to
improve and document our environmental performance, the Agency decided
to develop and implement the EMS. Also, as an agency approaching its
10-year anniversary, Sound Transit is very young in the evolution of
public agencies. Although the environmental program has worked very well
up to this point, it is time to formalize our business practices to
provide clear direction and to create institutional stability.

# **Significant Aspects & Impacts**

Within the fenceline, the Steering Committee established and identified
aspects by determining the Agency activities that impact the environment
in either a beneficial or an adverse manner. The Steering Committee
prioritized and identified significant aspects based on the following
criteria:

-   Scale and Severity of Impact;

-   Probability of Occurrence;

-   Cost of Addressing;

-   Potential Legal and Regulatory Exposure;

-   Ease of Impact Avoidance;

-   Effect on Public Image;

-   Ease of Implementing Process Change;

-   Concerns of Agency Stakeholders; and

-   Impact on Program and Project Cost and Schedule.

Significant EMS aspects, meaning those of the highest priority in
meeting the Agency's commitment to the environment, were then identified
by the Steering Committee as being the following:

-   Environmental Commitment Implementation Monitoring;

-   Endangered Species Act (ESA) Compliance;

-   Compliance with National Environmental Policy Act / State
    Environmental Policy Act (NEPA/SEPA); and

-   Hazardous Materials Risk Assessment, Management and Cleanup.

The Steering Committee intends to review Agency operations at least
annually to determine if additional EMS aspects should be considered.

# 

# **Objectives & Targets 2005**

+-----------------------+----------------------------------------------+
| **Objectives**        | **Targets**                                  |
+=======================+==============================================+
| Implement project     | **Target 1:** Perform gap analysis to        |
| commitments made in   | identify current business practices for      |
| environmental         | managing commitments for Link, Regional      |
| documents, permits,   | Express, and Sounder.                        |
| and other executed    |                                              |
| agreements by         | **Target 2:** Modify existing processes and  |
| ensuring a system     | define new processes, as applicable,         |
| exists to manage,     | resulting from the Target 1 gap analysis.    |
| monitor and track     |                                              |
| compliance throughout | Target 3: Create a tracking system for       |
| the project lifecycle | monitoring and reporting on commitments for  |
| in order to minimize  | Link, Regional Express, and Sounder.         |
| environmental         |                                              |
| impacts, prevent      |                                              |
| pollution, and        |                                              |
| protect and enhance   |                                              |
| the environment.      |                                              |
+-----------------------+----------------------------------------------+
| Assure agency         | **Target 1:** Adopt a procedure that will    |
| compliance with and   | govern Sound Transit's formal and informal   |
| consistent            | consultation process. This procedure should  |
| implementation of the | address the relationship between the ESA     |
| Endangered Species    | process and the NEPA process.                |
| Act process and       |                                              |
| requirements in order | **Target 2:** Adopt a procedure regarding    |
| to avoid              | the commencement of soil-disturbing work     |
| environmental         | (geotechnical drilling, utility potholing,   |
| degradation.          | etc.) prior to completion of the             |
|                       | consultation process.                        |
|                       |                                              |
|                       | **Target 3:** Adopt a procedure regarding    |
|                       | the need to reinitiate informal              |
|                       | consultations in light of project changes,   |
|                       | new information, or other changed            |
|                       | circumstances.                               |
|                       |                                              |
|                       | **Target 4:** Adopt a procedure for ensuring |
|                       | due consideration is given to the protection |
|                       | of endangered species when no federal        |
|                       | consultation requirement exists.             |
+-----------------------+----------------------------------------------+
| Assure Agency         | **Target 1:** Adopt a procedure for handling |
| compliance with, and  | project or plan changes that occur after the |
| consistent            | completion of initial environmental review.  |
| implementation of,    |                                              |
| NEPA/SEPA and related | **Target 2**: Adopt a procedure for          |
| environmental review  | integrating SEPA requirements into Sound     |
| processes and         | Transit decision-making, including the Sound |
| requirements          | Transit Board.                               |
| throughout the agency |                                              |
| in order to help      | **Target 3:** Develop, document and train    |
| prevent pollution and | staff in business practices for scoping and  |
| avoid environmental   | screening of alternatives.                   |
| degradation.          |                                              |
|                       | **Target 4:** Adopt a procedure for          |
|                       | distributing draft and final environmental   |
|                       | documents and determinations.                |
|                       |                                              |
|                       | **Target 5:** Develop a list and schedule    |
|                       | for addressing future topic by order of      |
|                       | priority.                                    |
+-----------------------+----------------------------------------------+
| Manage the handling   | **Target 1:** Adopt a procedure for          |
| and disposal of       | production and review of environmental due   |
| hazardous materials   | diligence investigations.                    |
| used, discovered, and |                                              |
| generated by Sound    | **Target 2:** Adopt a procedure for the      |
| Transit in order to   | tracking and reporting of hazardous waste    |
| help prevent          | "generated" by Sound Transit.                |
| pollution and avoid   |                                              |
| environmental         | **Target 3:** Adopt a procedure for          |
| degradation.          | hazardous materials emergency response.      |
|                       |                                              |
|                       | **Target 4:** Adopt a procedure for          |
|                       | construction spoils and wastewater sampling  |
|                       | during construction.                         |
|                       |                                              |
|                       | **Target 5:** Develop a list and schedule    |
|                       | for addressing future targets by order of    |
|                       | priority.                                    |
+-----------------------+----------------------------------------------+

# 

# **Benefits of Adopting an EMS**

Sound Transit recognizes benefits of developing an EMS. Some benefits
seen include:

-   Establishing an inter-departmental Steering Committee and
    subcommittees that allow key staff to address environmental
    questions from multiple perspectives;

-   Receiving support from the Board of Directors in the form of a
    resolution to adopt the Sound Transit Environmental Policy early on
    in the EMS development process;

-   Putting crucial institutional knowledge into written form and
    establishing document control;

-   Providing a strong foundation to support the Agency in choosing
    sustainable and environmentally responsible practices.

Some quantifiable results have been found in the area of contractor
management and environmental commitment implementation. For example,
results of storm water inspections are presented below. The graph
indicates that, although contractor performance in the area of managing
storm water Best Management Practices (BMPs) was initially very poor, as
measured by the frequency of recurrence of the same reported BMP
deficiencies from week to week, overall contractor performance steadily
improved. In this case, improvement is attributed to increasing
awareness of the importance of compliance monitoring and enforcement by
Construction Management staff. In addition, we were able to draw
personnel from our agency-wide Quality Assurance Department into the
monitoring activities, thereby integrating a formal auditing and
Corrective Action sequence into any continued deficiencies exhibited by
the contractors. Through the authority of the guiding principles
established in Sound Transit's Environmental Policy, the proactive
implementation of the monitoring/corrective action sequence resulted in
a continual improvement process for the prevention of environmental
degradation.

![](media/image29.png){width="5.627777777777778in"
height="3.8986111111111112in"}

# ** Resources** 

Sound Transit estimates it has devoted the following staff time to
undergo the training (including travel cost/time) and develop the EMS
from the period between February 2004 and June 2005 as follows:

  ---------------------------------------------------- ------------------
  EMS Steering Committee:                              2,715 hours

  Subcommittees and Other Personnel                    635 hours

  **Estimated Cost**                                   **\$233,447.50**
  ---------------------------------------------------- ------------------

![](media/image30.jpeg){width="6.0in" height="2.0in"}Most of the effort
was expended on development of EMS procedures and work instructions.
Additional time has also been expended with EMS training and auditing
and communicating the status of the EMS.

# **Cost Savings or Avoidance**

Steering Committee, with the assistance of construction representatives,
developed a work instruction outlining the protocols for management of
construction spoils to ensure they are disposed of properly. Improper
disposal can result in hundreds of thousands if not millions of dollars
in cleanup costs. This work instruction can be applied to other
construction programs of the Agency. With the Sound Transit EMS in its
early stages of development and implementation, the Agency has not yet
been able to quantify cost savings from the EMS. Nonetheless, we are
beginning to recognize savings. For example, the Agency anticipates
avoiding fines related to environmental compliance with implementation
of EMS. Additionally, cost savings are attributed to the recent
implementation of the EMS process for management of construction spoils
associated with the construction of the initial segment of the Link
light rail project. The EMS

Sound Transit also values the benefits and efficiencies resulting from
improved lines of communication among staff, improved relationships with
regulatory agencies by having a clear environmental policy, development
of written procedures for implementing environmental obligations,
capture of institutional knowledge related to addressing transit system
environmental impacts, and promotion of proactive responses in
evaluating and addressing environmental issues.

We envision that these efficiencies will reduce the amount of time
required for development and approval of environmental documentation and
permit acquisition. In the future, where possible, we intend to track
project schedules closely to identify opportunities for savings and cost
efficiencies resulting from the implementation of the EMS.

# 

# **Next Steps**

Over the next 12 months, the EMS will be implemented and appropriate
revisions to the procedures and work instructions to address project
specific issues and incorporate system improvements will be developed.
EMS revisions also may be necessary with project transition from
planning, design and construction to operations.

In the initial planning cycle, four significant aspects were identified.
The Steering Committee will continually review these aspects to
determine that they are satisfactorily addressed in the EMS. Future
expansion of the EMS to include aspects such as reduction in solid waste
generation, sustainable design, office waste
prevention/recycling/purchasing and potential use of alternative fuel
and energy sources may be identified and evaluated.

# **Management Commitment**

As a steward of public funding and trust, Sound Transit is committed to
balancing the implementation of Sound Move with the protection and
preservation of the environment. To that end, the Board of Directors of
the Agency adopted an environmental policy that not only identifies our
commitment to be an environmental leader, but also requires the
development and implementation of the Environmental Management System.

In addition, the EMS program has benefited greatly from the strong and
unwavering support of senior management, including the Chief Executive
Officer, the Deputy CEO, and the department directors.

**Sound Transit Audit Report**

This Environmental Management System (EMS) Audit was based on a request
by Virginia Tech (VT) and the Federal Transit Administration (FTA) as a
final follow-up to an eighteen month program for EMS development and was
conducted in accordance with the approved schedule.

Ms. Michele M. Lawton -- EMS Specialist with Virginia Tech conducted the
EMS Audit for Sound Transit, Seattle WA, on September 12 and 13, 2005 to
report on its conformance with the requirements of the ISO 14001:1996
standard.

The EMS was evaluated against each of the requirements set out in the
ISO 14001:1996 standard titled "Environmental management system --
Specification with guidance for use." The Audit included the examination
of documents, interviews of personnel and observations of activities and
conditions.

The site visit involved a review of the core EMS documents with the EMS
team. The Sound Transit EMS Team participated in the review and
discussion regarding the scoring.

The following scores are the result of the EMS Assessment:

1\. The overall score for the Assessment with respect to meeting the
requirements of an EMS as specified in the ISO 14001:1996 Standard is
**ninety-eight percent (98%)**.

2\. **Ninety-five percent (95%)** of the requirements were **"met."**

3\. **Five percent (5%)** of the requirements were **"partially met."**

**Detailed scoring on next page.**

**Sound Transit EMS Audit Results**

The following graph compares the total number of requirements met
*(shown in blue)* to the total number of requirements from the ISO
14001:1996 Standard *(shown in green)*.

This section compares the percentage of requirements *met*, *partially
met*, and *not met* in each element of the EMS.

  ------------ --------------------------------- --------- ----- ----------- ------- ----------------------
  The ISO                                        Overall   Met   Partially   Not Met Ref.
  14001:1996                                                                         
  Standard                                                                           
  Elements of                                                                        
  an EMS                                                                             

                                                 Score (%) (%)   Met (%)     (%)     

  4.2          Environmental Policy              100       100   \-          \-      [4.2.10]{.underline}

  4.3.1        Environmental Aspects             100       100   \-          \-      [4.3.11]{.underline}

  4.3.2        Legal & Other Requirements        100       100   \-          \-      [4.3.21]{.underline}

  4.3.3        Objectives & Targets              100       100   \-          \-      [4.3.31]{.underline}

  4.3.4        Environmental Management          100       100   \-          \-      [4.3.41]{.underline}
               Program(s) (EMPs)                                                     

  4.4.1        Structure & Responsibility        90        80    20          \-      [4.4.11]{.underline}

  4.4.2        Training, Awareness & Competence  93        86    14          \-      [4.4.21]{.underline}

  4.4.3        Communication                     100       100   \-          \-      [4.4.31]{.underline}

  4.4.4        EMS Documentation                 100       100   \-          \-      [4.4.41]{.underline}

  4.4.5        Document Control                  100       100   \-          \-      [4.4.51]{.underline}

  4.4.6        Operational Control               100       100   \-          \-      [4.4.61]{.underline}

  4.4.7        Emergency Preparedness & Response 88        75    25          \-      [4.4.71]{.underline}

  4.5.1        Monitoring & Measurement          88        75    25          \-      [4.5.11]{.underline}

  4.5.2        Nonconformance, Corrective &      100       100   \-          \-      [4.5.21]{.underline}
               Preventive Action                                                     

  4.5.3        Records                           100       100   \-          \-      [4.5.31]{.underline}

  4.5.4        EMS Audit                         100       100   \-          \-      [4.5.41]{.underline}

  4.6          Management Review                 100       100   \-          \-      [4.6.10]{.underline}
  ------------ --------------------------------- --------- ----- ----------- ------- ----------------------

![](media/image31.jpeg){width="5.5472222222222225in"
height="1.823611111111111in"}

**Profile**

In service since 1974, the Transit Authority of River City (TARC)
provides 50,000 rides every day on 55 fixed routes in a five-county area
in Kentucky and Southern Indiana. Each year TARC serves over 14 million
passengers with nearly 7.725 million vehicle miles and 531,275 vehicle
hours.

TARC\'s mission is to explore and implement transportation opportunities
that enhance the social, economic and environmental well being of the
greater Louisville community. Louisville has a rich transportation
history, beginning with the steamboat industry that thrived on the Ohio
River in the 18th century. Once the 10th largest city in the United
States, Louisville was soon at the center of booming railroad expansion
and had a significant passenger rail system in operation by the early
1900s, a system that continued operation until the 1940s. With the
conversion from rail (interurban and streetcar) to diesel buses several
private bus companies began operating in the community. In 1974 the
largest of these, the Louisville Transit Co., was acquired by the City
of Louisville became the Transit Authority of River City.

TARC makes Louisville a better place to live by implementing innovative
services that respond to the changing transportation needs of the
Greater Louisville community. Some of the changes we've made to enhance
our community's environmental well being include installation of bike
racks on all of our fixed route buses, switching to ultra low sulfur
diesel fuel and introducing hybrid electric buses into service. TARC is
integral to the development of our community because it provides greater
mobility for passengers young and old, and access to opportunities for
all citizens, including those with disabilities and new Americans; all
while helping reduce congestion and air pollution.

With an industrial component to its economy and its location in the Ohio
River Valley, Louisville has struggled to maintain air quality
standards. It has been out of compliance with federal ozone standards
many of the last 15 years. TARC continues to play an active role in
keeping the community in compliance by reducing tailpipe emissions.

**Fenceline**

TARC chose to limit the initial implementation of its Environmental
Management System (EMS) to Maintenance Department functions at its Union
Station division. Here 103 mechanics and service employees (88 are
members of the Amalgamated Transit Union) work around the clock, seven
days a week taking care of TARC's active revenue fleet of 263 buses and
trolleys. ![](media/image32.jpeg){width="2.75in" height="2.25in"}The
five-acre site includes a bus storage building (the "barn") where the
fleet is serviced and washed daily, six general repair bays, three
preventive maintenance bays and five specialty bays. The organization
has recognized the "permeability" of that fenceline, however. Where it
makes good sense to expand an environmental management program to
include another department, we do so.

TARC intends ultimately for the scope of its EMS to include all
operations, departments\
and facilities.

**Core Team**

At startup, the EMS Core Team included:

-   Dan Franklin, Director of Transportation

-   Cathy Reasor, Safety Assistant

-   Dan Jim Barrett, Assistant Director of Maintenance

-   Geoff Hobin, Special Projects Manager

Later Chris Ward of our Purchasing Department and Steve Javins,
Maintenance Training Supervisor, joined the team. Most recently the team
was bolstered by the addition of Russ Rakestraw, TARC's new Director of
Safety.

**Key Drivers for Adopting an EMS**

TARC has maintained an excellent record of environmental compliance
throughout its existence. So, when the FTA presented the opportunity to
receive training about and guidance in developing an environmental
management system, TARC responded without hesitation. To begin with,
accepting the opportunity and the challenge was in keeping with our
stated goals of continuous improvement and becoming a learning
organization. In addition, while we were proud of our environmental
record, we knew that we had not adequately documented our practices. We
believed that the training provided would help us learn valuable
management skills that could be shared and extended beyond our EMS. We
also understood that successful implementation would likely improve our
standing with the local, State and Federal agencies that administer
environmental regulations.

**Significant Aspects and Impacts**

TARC's EMS Core Team identified over 120 aspects associated with our
revenue vehicle maintenance. While considering the relative significance
of each aspect, the team gave most weight to those aspects whose
negative impacts were most likely to occur and to those aspects that
could most easily be managed. A survey of maintenance employees at Union
Station was also considered before arriving at a final decision.

After much deliberation, three aspects were finally chosen that the Team
felt would most likely yield significant improvement through appropriate
management, and that could most readily be addressed. The three aspects
were:

1.  Utility use associated with heating and cooling the bus barn

2.  Consumption of virgin oil

3.  Consumption of virgin paper

**Objectives and Targets**

The objectives reflect commitments stated in TARC's environmental policy
to reduce consumption of natural resources and pollution.

![](media/image33.jpeg){width="5.895833333333333in" height="2.25in"}

**Benefits of adopting an EMS**

In addition to some looked-for benefits of cost and risk reduction, TARC
is realizing a number of less tangible benefits from developing its EMS.
Most of those have to do with learning new ways of managing and
documenting processes. We also see evidence of the kind of incremental
shift in organizational behavior that can be extremely difficult to
bring about.

**Sharing What Works**

-   The Maintenance and Training departments have applied the EMS
    template for operational controls to all of their Standard Operating
    Procedures.

-   Simply talking about purchasing recycled paper for the Maintenance
    Department has led the Planning Department to order office paper
    with 30% "post-consumer" content.

-   Our Transportation Department, the agency's largest consumer of
    paper, has begun to talk to the Core Team about ways to reduce that
    consumption.

**Audits and Becoming a Learning Organization**

As a result of our work on the EMS, awareness of the importance of
documentation is growing, both as a way of capturing knowledge, and as a
way of creating audit trails for regulatory compliance. We are also
growing a culture that believes in the maxim, "What is measured is
![](media/image34.jpeg){width="2.467361111111111in"
height="2.213888888888889in"}managed."

**Keep it Simple**

We've found that simple, inexpensive solutions, such as tracking oil
changes right on engine compartments (pictured at right), can have
meaningful, significant impacts.

**Resources**

For the period from March 1, 2004 through July 31, 2005, during which
TARC's EMS was developed and implemented, TARC staff and consultants
committed their time as follows:

  -------------------------------------------------------- --------------
  **Member**                                               **Hours**

  Environmental Management Representative                  202

  Core Team                                                413

  Other                                                    84

  Consultants                                              38

  **TOTAL Labor Hours**                                    **737**
  -------------------------------------------------------- --------------

The cost of labor associated with the development of TARC's EMS is:

  -------------------------------------------------------- --------------
  **Category**                                             **Cost**

  Total Labor expense                                      22,670

  Travel expenses                                          18,447

  Other Costs                                              450

  **TOTAL Cost**                                           **41,567**
  -------------------------------------------------------- --------------

**Cost Savings or Avoidance**

Since we began managing utility use in the bus barn (January 2005) we
have reduced our consumption of natural gas by over 31,000 cubic feet,
**saving almost \$15,000 against our baseline, despite rising gas
prices.**

> ![](media/image35.wmf)

**Emissions Reduction**

At the same time, we've used 270,000 fewer kilowatt-hours of
electricity, exceeding our target by more than 7%.

**Resulting Emission Reductions**

Best of all, we've begun to see significant pollution reduction.

+-----------------------------------------------------------------------+
| +----------+--------+--------+--------+--------+--------+--------+    |
| | ### Po   | **C    | **S    | *      | **CO** | *      | **P    |    |
| | llutants | O^2^** | O^2^** | *NOx** |        | *VOC** | M2.5** |    |
| +----------+--------+--------+--------+--------+--------+--------+    |
| | ^Lbs.    | **999  | **1    | **1    | *      | **17** | **24** |    |
| | /^~year~ | ,381** | ,853** | ,088** | *125** |        |        |    |
| +----------+--------+--------+--------+--------+--------+--------+    |
+-----------------------------------------------------------------------+

**Next Steps**

During the next few months the EMS Core Team will complete the initial
implementation or our EMS. Our contractors and suppliers will be
receiving communication about TARC's environmental policy. Construction
and service providers will be asked to fill out an environmental
checklist before receiving a contract. Our environmental consultants
will perform an internal audit of our EMS this year. We expect that
audit to be repeated annually as a way to provide feedback for
continuous improvement. EMS procedures will be incorporated into the
design and construction processes of the maintenance annex we hope to
begin building this year.

Development of TARC's EMS has led to involvement with Louisville Metro's
"Green Team" and with Metro's "Partnership for a Green City." We expect
those partnerships to broaden and deepen in the coming months and years.
TARC is committed to expanding its EMS throughout the agency and to
raising awareness among all our team members of the many ways we impact
our environment. Ultimately, we hope TARC's EMS will help to move the
greater Louisville community toward truly sustainable public
transportation.

**Management Commitment**

**TARC Audit Report**

This Environmental Management System (EMS) Audit was based on a request
by Virginia Tech (VT) and the Federal Transit Administration (FTA) as a
final follow-up to an eighteen month program for EMS development and was
conducted in accordance with the approved schedule.

Ms. Michele M. Lawton -- EMS Specialist with Virginia Tech conducted the
EMS Audit for TARC -- Louisville, KY on September 29 and 30, 2005 to
report on its conformance with the requirements of the ISO 14001:1996
standard.

The EMS was evaluated against each of the requirements set out in the
ISO 14001:1996 standard titled "Environmental management system --
Specification with guidance for use." The Audit included the examination
of documents, interviews of personnel and observations of activities and
conditions.

The site visit involved a review of the core EMS documents with the EMS
team. The TARC EMS Team participated in the review and discussion
regarding the scoring.

The following scores are the result of the EMS Assessment:

1\. The overall score for the Assessment with respect to meeting the
requirements of an EMS as specified in the ISO 14001:1996 Standard is
**ninety-three percent (93%)**.

2\. **Eighty-six percent (86%)** of the requirements were **"met."**

3\. **Fourteen percent (14%)** of the requirements were **"partially
met."**

**Detailed scoring on next page.**

**TARC EMS Audit Results**

The following graph compares the total number of requirements met
*(shown in blue)* to the total number of requirements from the ISO
14001:1996 Standard *(shown in green)*.

This section compares the percentage of requirements *met*, *partially
met*, and *not met* in each element of the EMS.

  ------------ -------------------------------- --------- ------ ----------- ------ ----------------------
  The ISO                                       Overall   Met    Partially   Not    Ref.
  14001:1996                                                                 Met    
  Standard                                                                          
  Elements of                                                                       
  an EMS                                                                            

                                                Score (%) (%)    Met (%)     (%)    

  4.2          Environmental Policy             100       100    \-          \-     [4.2.10]{.underline}

  4.3.1        Environmental Aspects            100       100    \-          \-     [4.3.11]{.underline}

  4.3.2        Legal & Other Requirements       100       100    \-          \-     [4.3.21]{.underline}

  4.3.3        Objectives & Targets             94        88     13          \-     [4.3.31]{.underline}

  4.3.4        Environmental Management         88        75     25          \-     [4.3.41]{.underline}
               Program(s) (EMPs)                                                    

  4.4.1        Structure & Responsibility       80        60     40          \-     [4.4.11]{.underline}

  4.4.2        Training, Awareness & Competence 86        71     29          \-     [4.4.21]{.underline}

  4.4.3        Communication                    100       100    \-          \-     [4.4.31]{.underline}

  4.4.4        EMS Documentation                100       100    \-          \-     [4.4.41]{.underline}

  4.4.5        Document Control                 100       100    \-          \-     [4.4.51]{.underline}

  4.4.6        Operational Control              75        50     50          \-     [4.4.61]{.underline}

  4.4.7        Emergency Preparedness &         100       100    \-          \-     [4.4.71]{.underline}
               Response                                                             

  4.5.1        Monitoring & Measurement         75        50     50          \-     [4.5.11]{.underline}

  4.5.2        Nonconformance, Corrective &     90        80     20          \-     [4.5.21]{.underline}
               Preventive Action                                                    

  4.5.3        Records                          100       100    \-          \-     [4.5.31]{.underline}

  4.5.4        EMS Audit                        88        75     25          \-     [4.5.41]{.underline}

  4.6          Management Review                100       100    \-          \-     [4.6.10]{.underline}
  ------------ -------------------------------- --------- ------ ----------- ------ ----------------------

> **Tucson, Arizona**

![](media/image36.jpeg){width="2.5625in"
height="1.4444444444444444in"}**Department of Transportation/Sun Tran**

> ![](media/image37.png){width="0.7402777777777778in"
> height="1.09375in"}

**Profile**

Located in sunny Tucson, Arizona, Sun Tran is the Tucson metro area's
mass transit provider. With the region's population hovering around a
million residents, Sun Tran facilitates approximately 15 million
passenger trips annually over its 27 regular and 10 express routes. This
translates to approximately 50,000 passenger trips per average work-day
and 17,000 average trips each weekend day. Three transit centers located
throughout the city facilitate route information and easy passenger
transfers. Service outside city limits is funded by inter-governmental
agreements (IGA's) between Tucson and three nearby municipalities
requesting service. Passenger fares account for approximately 22% of
annual revenue, and more than 50% is subsidized by the City of Tucson's
General Fund. Additional funding is garnered through the federal
government and the State of Arizona.

![](media/image38.jpeg){width="4.971527777777778in"
height="2.029166666666667in"}

Mass transit in Tucson had its humble beginnings in 1879 with a herdic
(horse and mule-drawn) line operated by William Morgan, which traveled
to and from Nine-Mile Water Hole to meet the Casa Grande Stage. Over the
next 17 years, companies such as the *Tucson Land & Herdic Coach
Company* and the *University Hack Line* (the first scheduled public
service within the town) were added. Horse and mule-drawn cars with rear
entrances and side facing seats served Tucson's retail district. In
1905, Sun Tran's forerunner, Tucson Rapid Transit (TRT), bought out the
horse-drawn streetcar system and introduced electric streetcars the
following year. On New Year's Day 1931, buses replaced the streetcars
and the modern era was born. In 1969, the City of Tucson purchased TRT.
Throughout all these changes, public transportation kept expanding into
the modern, regional mass transit system serving today's Tucsonans from
an 8 acre complex with 520 employees, and a fleet of 189 diesel, dual
diesel/CNG, and CNG buses. Under contract, Professional Transit
Management, Ltd. of Loveland, Ohio manages the system on a daily basis
for the City of Tucson. In 2004, Sun Tran was the recipient of the
Arizona Transit Association's "Excellence Award Outstanding Transit
Organization". In 2005, Sun Tran was given the American Public
Transportation Association's "Outstanding Public Transportation System
Achievement Award" in the category of 4 to 30 million annual passenger
trips.

In the spring of 2004, the City of Tucson Department of Transportation
(TDOT) and Sun Tran were selected by the Federal Transit Administration
(FTA) to receive technical assistance and training, with the goal of
developing and implementing an Environmental Management System (EMS). An
EMS is a set of procedures designed to allow an organization to assess
the environmental impacts of its activities and develop appropriate
mechanisms to manage them, thus allowing the organization to operate
with greater efficiency and control.

Different organizations have different reasons for wanting to implement
an EMS. Prior to TDOT/Sun Tran involvement in this FTA/Virginia Tech
Pilot Program, TDOT's environmental efforts mainly encompassed only a
storm water program, operational procedures, and emergency management.
The primary management impetus for TDOT/Sun Tran's pursuit of an EMS is
three-fold: 1) to help achieve and maintain regulatory compliance, 2) to
ensure waste stream minimization, and 3) to design and implement more
effective operational controls. However, TDOT and Sun Tran also want to
be at the forefront in environmental management. They are not merely
committed to [meeting]{.underline} environmental minimum standards; they
are committed to **[exceeding]{.underline}** them.

**Fenceline**

> The Sun Tran bus maintenance facility operates 24 hours 7 days a week,
> staffed by approximately 100 maintenance employees. The Fenceline
> includes services associated with repair and maintenance of the
> transit buses. Sun Tran's bus maintenance facility became the
> fenceline for the purposes of piloting the EMS approach. It was
> selected by TDOT because of the variety of potential environmental
> impacts in the facility and because of the enthusiastic support for
> EMS implementation from Sun Tran's management and staff.

**Core Team**

The Core team was developed to involve senior management as well as
employees who would provide direct input into the EMS development and
processes. The members include:

-   Kevin Faulkner, Maintenance Director-Sun Tran;

-   Clare Conley, Staff Assistant-TDOT;

-   Ivey Schmitz, Deputy Director-TDOT;

-   George Caria, General Manager-Sun Tran; and

-   John Zukas, Transit Services Coordinator-TDOT.

In addition to the Core Team, an Environmental Team and an Oversight and
Implementation Team were developed to create and manage the
Environmental Management System. Further, smaller sub-groups were formed
to address development, coordination, and implementation of specific
elements of the EMS

**Key Drivers for Adopting an EMS**

Environmental management has become part of Sun Tran's daily mindset,
leading to improved efficiency, waste minimization, and more
cost-effective operation. Furthermore, Sun Tran's public image is
directly tied to its attitude toward the environment. Being cognizant of
this, employees must assure the public that their activities and
services, especially those with the potential to cause pollution, are
effectively and efficiently managed. Sun Tran is strongly committed to
maintaining a safe and clean environment, preventing pollution, and
preserving the community's natural desert resources. The development of
our EMS program is also in response to a challenge issued by former City
Manager James Keene to the City of Tucson to "become one of America's
ten best cities".

The Sun Tran maintenance facility was the City of Tucson's pilot program
for its Storm Water Pollution Prevention Plan and continues to strive
for continual improvement in all areas of environmental issues.

Sun Tran strives to continuously improve environmental practices with
the goal of meeting or exceeding all environmental requirements
concerning the bus maintenance facility, and the services associated
with repair and maintenance of the transit buses. We also seek to
empower each individual employee through ongoing training and will
actively seek employee and public input in promoting environmental
stewardship.

In addition, Sun Tran identified several critical factors leading to the
decision to pursue creation of an EMS. These included a conviction that
insurers and bonding agencies could reward the adoption of an EMS;
acknowledging a safer work environment and reduced risks, the
recognition that the EMS could be a valuable marketing and public
relations tool that would clearly demonstrate the desire to hold Sun
Tran to a very high standard of environmental contact; and the ability
to partner environmental management with existing health and safety
programs.

**Significant Aspects & Impacts**

Sun Tran is committed to minimizing significant environmental impacts
identified in Sun Tran's environmental management system (EMS) by
setting environmental objectives and continually evaluating progress
toward meeting those objectives. Over 30 environmental aspects were
identified and evaluated. However, the four most critically important
aspects were selected for the first phase of the EMS.

These are **hazardous waste, coolant, storm water** and **waste water.**

![](media/image39.jpeg){width="2.5694444444444446in"
height="1.43125in"}![](media/image40.jpeg){width="2.5305555555555554in"
height="1.4256944444444444in"}

**Objectives and Targets**

Each significant Aspect was evaluated by the environmental committee in
order to set objectives and targets. The environmental committee looked
at the activities, products, services, and policy commitments, in order
to set the objectives, targets, target date, and performance
indicator(s):

**STATUS**: Coolant: 98% of employees have been trained in the Coolant
Curriculum. Reduction objective was not achieved. All coolant is being
properly handled and recycled where practical.

+---------------------+------------------------------------------------+
| **Significant       | **Hazardous Waste**                            |
| Aspect**            |                                                |
+---------------------+------------------------------------------------+
| **Management        | Disposal of Hazardous Waste off Site           |
| program:**          |                                                |
+---------------------+------------------------------------------------+
| **Activity          | Storage, disposal, and shipment of hazardous   |
| /product/service:** | wastes                                         |
+---------------------+------------------------------------------------+
| **Policy            | Reduce Waste                                   |
| commitment:**       |                                                |
+---------------------+------------------------------------------------+
| **Objective:**      | Reduce the amount of hazardous waste generated |
|                     | by the Sun Tran Maintenance Facility           |
+---------------------+------------------------------------------------+
| **Target:**         | Reduce hazardous waste shipped off site by 10% |
+---------------------+------------------------------------------------+
| **Target Date:**    | April 1, 2005                                  |
+---------------------+------------------------------------------------+
| **Performance       | Aggregate quantity of waste generated (in lbs) |
| Indicator(s):**     | as reflected on                                |
|                     |                                                |
|                     | Manifests                                      |
+---------------------+------------------------------------------------+

**STATUS:** Hazardous waste: On track to achieve a 65% reduction in
waste shipped in 2005 over 2002/2003 baseline levels. 99% of employees
have been trained.

+---------------------+-------------------------------------------------+
| **Significant       | **Storm Water**                                 |
| Aspect**            |                                                 |
+---------------------+-------------------------------------------------+
| **Management        | Reducing impacts to storm water                 |
| program:**          |                                                 |
+---------------------+-------------------------------------------------+
| **Activity          | Storage of equipment and resources              |
| /product/service:** |                                                 |
+---------------------+-------------------------------------------------+
| **Policy            | Prevent pollution, minimize significant         |
| commitment:**       | environmental impact, and                       |
|                     |                                                 |
|                     | improve system-wide environmental practices     |
+---------------------+-------------------------------------------------+
| **Objective:**      | Reduce storm water impacts by training and      |
|                     | properly storing all                            |
|                     |                                                 |
|                     | Materials                                       |
+---------------------+-------------------------------------------------+
| **Target:**         | Training of 95% of maintenance-related          |
|                     | employees in proper                             |
|                     |                                                 |
|                     | storage and housekeeping                        |
+---------------------+-------------------------------------------------+
| **Target Date:**    | 7/1/05                                          |
+---------------------+-------------------------------------------------+
| **Performance       | Annual audit at 4/22                            |
| Indicator(s):**     |                                                 |
+---------------------+-------------------------------------------------+

**STATUS:** Storm water: 100% of employees have been trained in the
Stormwater Curriculum. No adverse storm water impacts observed.

+---------------------+------------------------------------------------+
| **Significant       | **Waste Water**                                |
| Aspect**            |                                                |
+---------------------+------------------------------------------------+
| **Management        | Training of all maintenance-related employees  |
| program:**          |                                                |
+---------------------+------------------------------------------------+
| **Activity          | Steam cleaning, bus washing, discharge of      |
| /product/service:** | wastewater from                                |
|                     |                                                |
|                     | maintenance facility into the sewer system     |
+---------------------+------------------------------------------------+
| **Policy            | Prevent pollution, minimize significant        |
| commitment:**       | environmental impact, and                      |
|                     |                                                |
|                     | improve system-wide environmental practices    |
+---------------------+------------------------------------------------+
| **Objective:**      | Maintain non-significant user status           |
+---------------------+------------------------------------------------+
| **Target:**         | Training of 95% of maintenance-related         |
|                     | employees in proper                            |
|                     |                                                |
|                     | wastewater use.                                |
+---------------------+------------------------------------------------+
| **Target Date:**    | 7/1/05                                         |
+---------------------+------------------------------------------------+
| **Performance       | Annual audit at 4/22                           |
| Indicator(s):**     |                                                |
+---------------------+------------------------------------------------+

**STATUS:** Wastewater: 100% of employees have been trained in the
Wastewater Curriculum. Maintaining non-significant user status and
meeting wastewater discharge permit limits.

**Benefits of Adopting an EMS**

As a result of developing and adopting an EMS, Sun Tran has realized a
number of benefits:

-   The environmental committees continue to meet on a regular basis in
    an effort to meet the EMS objectives. These meetings have promoted
    non-traditional, inter-departmental collaboration, which
    fundamentally stems from promoting continual improvement and meeting
    goals and objectives.

-   Sun Tran has seen an increased level of environmental awareness
    among management, front-line employees, and vendors as a result of
    developing objectives & targets, environmental management programs,
    work procedures, and facilitating regularly scheduled meetings. At
    all levels, people are becoming stewards of the EMS. In addition,
    through these meetings with employees, Sun Tran receives feedback
    from employees for new ideas and improving existing ones. Sun Tran
    has sponsored an awareness day for employees where over 300 tee
    shirts and 400 information cards were given to employees and it has
    recently completed a vendor fair wherein over 60 vendors were
    provided information about their responsibilities and Sun Tran's
    regarding the EMS.

-   Operating procedures are standardizing the flow of work, assuring
    that Sun Tran activities are both efficient and as sensitive as
    possible to environmental concerns. Moreover, as data is collected
    over the next several years, Sun Tran anticipates a significant
    decrease in waste generation, greater attention to resource
    management, and eventual cost savings.

-   Due to the cooperation displayed during the creation of the EMS,
    departments that never before interacted are now providing resources
    and cooperation that were not previously available. This increased
    cooperation with departments not currently in the Fenceline raises
    the potential to eventually expand the Fenceline to the City's
    paratransit operations in the near future, and further a field as
    opportunities arises.

-   Sun Tran employees are better trained because of the specialized
    curricula developed to address the four aspects chosen to be
    addressed first because of their criticality. In addition, the
    process of developing the Elements of the EMS, such as
    communications, involved a broad cross-section of Sun Tran staff,
    which raised their environmental consciousness and knowledge. There
    have been a number of notable "ah ha!" moments such as when members
    of subcommittees finally "got" the distinction between storm water
    and wastewater, or learned the proper disposal method of aerosol
    cans.

> ![](media/image41.jpeg){width="1.7166666666666666in"
> height="2.566666666666667in"}
> ![](media/image42.jpeg){width="3.8722222222222222in"
> height="1.9347222222222222in"}

-   The 10% reduction in hazardous waste generated in the Sun Tran
    maintenance facility results in lowered disposal costs borne by the
    City of Tucson's Fire Department.

-   Monitoring and measuring have accomplished the goal of maintaining
    our non-significant water user status. This has resulted in a
    significant cost savings for the City, which would have been
    required to pay the fees for and meet the regulatory requirements
    for a significant water user.

The TDOT/Sun Tran EMS implementation continues to provide sound evidence
to employees, taxpayers, financial institutions, and other stakeholders
that the system controls are in place to achieve management goals and to
strive for improvement of the environmental impacts of its operations.
Successful implementation requires that TDOT/Sun Tran focus on
activities that have always been considered routine and identify ways to
do them in a more environmentally friendly manner.

**Resources**

The number of hours associated with the development and implementation
of the program from February 2004 -- May 2005 are listed below:

  --------------------------------------------------- -------------------
  **Members**                                         **Hours**

  Environmental Management Representatives            1,094

  Core, Steering and Administrative Teams             1,294

  Other                                               163

  Virginia Tech direct technical support              80

  **TOTAL Hours**                                     **2,631**
  --------------------------------------------------- -------------------

  --------------------------------------------------- -------------------
  **Category**                                        **Cost**

  Total Internal Labor expense                        92,085

  Travel expenses                                     14,102

  Other                                               1,200

  **TOTAL Cost**                                      **107,387**
  --------------------------------------------------- -------------------

**Cost Savings**

Sun Tran's initial objectives and targets were focused largely on
training and development of employee awareness of environmental issues.
After review of our progress in achieving these initial objectives and
targets, and after completion of our evaluation of compliance with
regulatory requirements, several new objectives and targets were
established. Setting these new objectives and demonstrating progress in
achieving them was critical to the certification of Sun Tran's EMS as
compliant with the ISO14001 standard in October 2005.

One of these new objectives was "Ensure proper management of all waste
streams". This required that we identify all waste streams and ensure we
had documentation to support how each waste stream was managed (as
hazardous or non-hazardous waste). Lack of documentation to support
waste stream hazard determinations was identified as a concern by our
compliance evaluation. This also required a physical inventory of all
hazardous materials on site and a review to ensure we had current
material safety data sheets (MSDS) for all items. While most MSDS were
on site, many were not readily available for employee review and several
hundred MSDS were found to be in the system for materials no longer in
use.

Another new objective was to convert the fleet of diesel buses to
bio-diesel fuel. 38% of Sun Tran's diesel only fleet has been replaced
as of October 2005 by new buses that run on diesel fuel with 20% bio
content (B20). This fuel reduces emissions of both carbon monoxide and
particulate matter, both pollutants of concern to local air quality, by
12% over conventional diesel fuel. Having 20% of the fuel derived from a
domestic, renewable source, also helps decrease US dependence on foreign
oil. We are currently evaluating the feasibility of converting the
remaining existing fleet of diesel buses to 5% Bio-diesel fuel. For
November and December of 2005 Bio-diesel has been averaging \$.17 per
gallon less than regular #2 diesel. A total of 76,964 Bio-diesel gallons
used has resulted in a total savings of **\$13,080** for this 2 month
period.

A new target for our objective of reducing storm water impacts is to
evaluate the use of oil absorbing line skimmers at our main storm water
outfall location. We have installed these skimmers and are anxiously
awaiting our desert's winter rains to evaluate their effectiveness in
eliminating the slight oil sheen that has been observed in runoff at
this outfall.

**Next Steps**

TDOT/Sun Tran has increased dedicated resources by including additional
staff and allowing existing staff to contribute time to the development
and implementation of the EMS. With this added involvement and
dedication to the program Sun Tran is committed was successful in
becoming certified to the 2004 ISO 14001 standard in October 2005. This
has been challenging but rewarding in that revisions to the 1996
standard had to be documented and the program implemented to meet the
changes. The benefits to this will be the consistent monitoring of the
program that will insure continual improvement.

**Management
Commitment**![](media/image43.wmf){width="0.9506944444444444in"
height="0.7861111111111111in"}

The EMS Team has made several presentations to the Director of
Transportation, who has demonstrated a continued commitment in the
program. The Tucson Department of Transportation's Management Team has
received presentations on the efforts to develop and implement an
environmental management system, and will receive further updates on a
regular basis.

In addition, the Tucson Finance Department's Central Safety Services
Manager and the Environmental Manager for the City of Tucson have
actively participated in program review. The current Tucson City Manager
has approved of Tucson's participation in the program, and also receives
periodic updates.

**Tucson Department of Transportation Audit Report**

This Environmental Management System (EMS) Audit was based on a request
by Virginia Tech (VT) and the Federal Transit Administration (FTA) as a
final follow-up to an eighteen month program for EMS development and was
conducted in accordance with the approved schedule.

Ms. Michele M. Lawton -- EMS Specialist with Virginia Tech conducted the
EMS Audit for Tucson Department of Transportation, Tucson, AZ on August
24 and 25, 2005 to report on its conformance with the requirements of
the ISO 14001:1996 standard.

The EMS was evaluated against each of the requirements set out in the
ISO 14001:1996 standard titled "Environmental management system --
Specification with guidance for use." The Audit included the examination
of documents, interviews of personnel and observations of activities and
conditions.

The site visit involved a review of the core EMS documents with the EMS
team. The Tucson EMS Team participated in the review and discussion
regarding the scoring.

The following scores are the result of the EMS Assessment:

1\. The overall score for the Assessment with respect to meeting the
requirements of an EMS as specified in the ISO 14001:1996 Standard is
**ninety-nine percent (99%)**.

2\. **Ninety-eight percent (98%)** of the requirements were **"met."**

3\. **Two percent (2%)** of the requirements were **"partially met."**

**Detailed scoring on next page.**

**Tucson Department of Transportation EMS Audit Results**

The following graph compares the total number of requirements met
*(shown in blue)* to the total number of requirements from the ISO
14001:1996 Standard *(shown in green)*.

This section compares the percentage of requirements *met*, *partially
met*, and *not met* in each element of the EMS.

  ------------ -------------------------------- --------- ----- ----------- ------- ----------------------
  The ISO                                       Overall   Met   Partially   Not Met Ref.
  14001:1996                                                                        
  Standard                                                                          
  Elements of                                                                       
  an EMS                                                                            

                                                Score (%) (%)   Met (%)     (%)     

  4.2          Environmental Policy             100       100   \-          \-      [4.2.10]{.underline}

  4.3.1        Environmental Aspects            100       100   \-          \-      [4.3.11]{.underline}

  4.3.2        Legal & Other Requirements       100       100   \-          \-      [4.3.21]{.underline}

  4.3.3        Objectives & Targets             100       100   \-          \-      [4.3.31]{.underline}

  4.3.4        Environmental Management         100       100   \-          \-      [4.3.41]{.underline}
               Program(s) (EMPs)                                                    

  4.4.1        Structure & Responsibility       100       100   \-          \-      [4.4.11]{.underline}

  4.4.2        Training, Awareness & Competence 93        86    14          \-      [4.4.21]{.underline}

  4.4.3        Communication                    100       100   \-          \-      [4.4.31]{.underline}

  4.4.4        EMS Documentation                100       100   \-          \-      [4.4.41]{.underline}

  4.4.5        Document Control                 100       100   \-          \-      [4.4.51]{.underline}

  4.4.6        Operational Control              100       100   \-          \-      [4.4.61]{.underline}

  4.4.7        Emergency Preparedness &         100       100   \-          \-      [4.4.71]{.underline}
               Response                                                             

  4.5.1        Monitoring & Measurement         100       100   \-          \-      [4.5.11]{.underline}

  4.5.2        Nonconformance, Corrective &     100       100   \-          \-      [4.5.21]{.underline}
               Preventive Action                                                    

  4.5.3        Records                          100       100   \-          \-      [4.5.31]{.underline}

  4.5.4        EMS Audit                        100       100   \-          \-      [4.5.41]{.underline}

  4.6          Management Review                90        80    20          \-      [4.6.10]{.underline}
  ------------ -------------------------------- --------- ----- ----------- ------- ----------------------

![](media/image44.jpeg){width="3.8965277777777776in"
height="1.0645833333333334in"} **Utah Transit Authority**

**Profile**

The Utah Transit Authority (UTA) operates along a region known as the
Wasatch Front. The service area is 116 miles long, 50 miles at its
widest point, 2 miles at its narrowest and encompasses over 1,633 square
miles. UTA serves more than 60 municipalities with a population of over
1.7 million people which is about 80% of Utah's total population.

The Authority was incorporated on March 3, 1970, and began operation on
August 10, 1970. UTA operates under state enabling legislation, Title
17A of the Utah State Code, and is classified as a special district. UTA
is governed by a board of 15 trustees appointed by the local government
entities within the service area. Management of UTA is overseen by a
general manager, John M. Inglish, who directly reports of the Board of
Trustees. UTA's current operating budget is approximately \$130 million.
The majority of UTA's funding comes from city and county local option
sales tax. UTA operates 129 bus routes and over 20 miles of light rail
service with approximately 1750 employees. In 2004, UTA provided over 34
million passenger trips.

In 2003, UTA had a major reorganization and now operates under a
business unit concept. There are three bus operating business units, one
rail services business unit, a support services business unit, a Capital
Development Office, an Office of General Counsel, an Office of
Operations Performance and an Office of the General Manager. In addition
to traditional operations and maintenance functions, each operating
business unit is responsible for the planning, marketing and
implementation of its respective transit service. Coordination between
the operating business units and administrative functions takes place
through a Policy Forum. The Policy Forum includes all Corporate Officers
as well as all Business Units Managers.

In 2000, the public in three counties voted to increase the local option
sales tax dedicated to transit in order to fund the expansion of rail
transit along the Wasatch Front. The advent of TRAX revolutionized UTA's
concept and the public's perception of public transit. Over the next ten
years, UTA plans to develop an additional 25 miles of light rail
service, 100 miles of commuter rail service, implement a bus rapid
transit system and revamp the Salt Lake area bus service.

UTA has a long tradition of environmental stewardship and the
organization views the implementation of ISO 14001 as a way to reinforce
the current practices as it embarks on a major expansion of transit
along the Wasatch Front.

**Fenceline**

As a fenceline for its EMS, UTA chose the Meadowbrook maintenance
division. The Meadowbrook facility is located in Salt Lake County and
serves as both UTA's administrative headquarters and the largest of
UTA's operating and maintenance divisions. The Meadowbrook operating
division is one of two operating divisions in the Salt Lake Business
Unit. The Salt Lake Business Unit operates approximately 370 buses, 250
of which operate out of the Meadowbrook division, seen below. There are
1,090 employees in the Salt Lake Business Unit, 789 are bus operators,
233 are mechanics and 68 are administrative employees. The operation and
maintenance staff are, for the most part represented by the Amalgamated
Transit Union.

![](media/image45.jpeg){width="5.84375in" height="3.31875in"}

UTA\'s Meadowbrook facility

**Core Team**

The core team is made up of eight members representing various functions
within UTA, the Salt Lake Business Unit, the Support Services Business
Unit, the Operations Performance Office and the Capital Development
Office. The name and title of the team members are:

-   Jerry Benson, Chief Performance Office -- Senior Management
    Representative

-   Grantley Martelly, Manager Safety & Environmental Protection -- EMS
    Team Leader

-   George Bryant, Manager of Maintenance

-   Allen Petersen, Manager of Facility Maintenance

-   Rick Garcia, Maintenance Training

-   Ed Buchanan, Rail Safety Administrator

-   Tim Rhoades, Bus Safety Administrator

-   Jeffery Harris, Deputy Chief -- Asset Management & Business
    Development

UTA chose such a large, diverse team in anticipation of expanding the
EMS into other areas of the organization and because these
representatives brought to the table a unique set of skills and
knowledge that would benefit the implementation of the EMS. In addition
to the core team, the ISO process involved a significant proportion of
the fence line's maintenance, operation, and administrative staff. For
example, as part of the process to identify environmental aspects the
core team surveyed all the personnel within the fence line. This effort
not only provided valuable information to the teams deliberations, it
created a sense of ownership and participation that facilitated the
implementation of the ISO 14001 program.

**Key Drivers**

UTA is goal oriented with a basic tenant of that orientation centering
on the concept of continual improvement. Largely, UTA's efforts
surrounding the continual improvement concept are a result of its
governance structure. UTA is governed by an appointed, 15 member Board
of Trustees. The Board's role is to set the overall strategic direction
of the organization. It sets the strategic direction by establishing
ends and means policies and by establishing yearly performance goals for
the management team. Management's role is to implement the policy
direction of the Board and strive to achieve the goals and objectives
set by the Board. ISO 9001 and 14001 tenants are a natural complement to
the organization's basic business philosophy and are seen as another set
of tools that help the management team achieve its goals. In addition to
the philosophical reason for adopting ISO standards, UTA choose to
embark on its quality improvement program by adopting the ISO 14001
standard and implement an EMS because of several issues surrounding the
organization's environmental compliance obligations.

On several occasions over the two years preceding its decision to adopt
the EMS, UTA exceed the permitted amount of emulsified oil allowed in
its waste water discharge. As a result of these violations, UTA began an
internal review of related management practices and initiated an
engineering assessment of associated mechanical systems. The results of
this evaluation revealed that the discharge violations were not
necessarily caused by a mechanical failure in the existing oil water
separator (OWS). While staff did discover that the OWS was incapable of
processing certain oil/water emulsions and ultimately recommended and
implemented the installation of an improved OWS system, the primary
cause of the violations was human in nature. Staff determined that
existing management practices were either not being followed by UTA
employees and contractors, or they inadequately addressed circumstances
and practices that could lead to excessive discharges.

UTA recognized the processes outlined in the ISO 14001 standard would
provide an improved framework for identifying and correcting troubled
areas before they became problems. UTA also saw that the EMS structure
would improve its ability to train and communicate the goals and
expectations to all employees. As a result of this effort, UTA
identified several key drivers for adopting an EMS which included the
following:

-   Paradigm shift from "reactive" to "proactive" management approach

-   Development of better day-to-day management systems

-   Creation of a more efficient operational system

-   Avoidance of environmental disasters

-   Enhanced awareness of employee impact on environment

**Significant Aspects and Impacts**

The establishment of these key drivers guided the core team's
identification and evaluation of significant aspects and impacts. The
core team analyzed the organization's activities and evaluated the
potential for adverse environmental impacts, the extent of those
potential impacts, environmental controls already in place and the
ability of UTA to manage and/or influence those impacts.

The core team initiated an extensive, internal outreach program designed
to inform personnel about the EMS program and solicit input and help in
identifying potential environmental aspects and their associated
impacts. The primary tools used for the outreach program were open
houses and presentations to UTA management and staff both within and
outside the EMS fence line. The core team also conducted surveys of all
operations and maintenance personnel as its primary tool for collecting
information on potential environmental aspects and their associated
impacts.

Members of the core team then rated each aspect based on newly
established criteria. Each aspect was given a score between one and
five. The scores were then averaged and the aspects with the highest
scores became the focus of the EMS. The team came up with a list of over
20 aspects and rated 13 of them. The list of aspects, with the six
significant aspects included (I) in the EMS are listed below:

-   Print shop (I)

-   Industrial waste water treatment (I)

-   Fuel consumption and excessive idling (I)

-   Used oil management (I)

-   Used oil/fuel/antifreeze filters (I)

-   Paint related waste -- aerosol cans and other pain products (I)

-   Electricity usage

-   Petroleum spills

-   Electronic waste

-   Paper recycling

-   Recycling used tires

-   Damaged batteries

-   Breakdown leaks

**Objectives and Targets**

From the larger aspect list of 13 aspects, the team, through the rating
process, identified six significant aspects to be covered in the initial
EMS. The team then established a series of objectives and targets for
those six aspects. The following table outlines the objectives and
targets of some of the main aspects:

+-----------+----------+----------------------------+-----------------+
| *         | **Obj    | > **Targets**              | **Results**     |
| *Aspect** | ective** |                            |                 |
+-----------+----------+----------------------------+-----------------+
| **Print   | Reduce   | -   Establish process      | -   Print shop  |
| Shop:     | the      |     controls               |     odors       |
| Employee  | number   |                            |     reduced by  |
| Exposure  | of       | -   Reduce print shop      |     more than   |
| in Shop;  | employee |     odors into employee    |     50%.        |
| Exposure  | co       |     areas outside of print |                 |
| adjacent  | mplaints |     shop by 04/01/05       | -   Chemicals   |
| to shop;  | by 50%   |                            |                 |
| Disposal  |          | -   Inventory chemicals    |    Inventoried. |
| of        |          |     used in print shop by  |                 |
| ch        |          |     07/31/04               | -   Work        |
| emicals** |          |                            |     Procedures  |
|           |          | -   Document work          |     documented. |
|           |          |     procedures by 08/15/04 |                 |
|           |          |                            | -   Training    |
|           |          | -   Train employees in     |     completed   |
|           |          |     Hazard Communication   |     on          |
|           |          |     and work procedures    |     Procedures. |
|           |          |                            |                 |
|           |          | > **Target Date:           |                 |
|           |          | > 12/29/04**               |                 |
+-----------+----------+----------------------------+-----------------+
| **I       | No       | -   Document baseline for  | -   Baseline    |
| ndustrial | vi       |     Meadowbrook Industrial |     document    |
| Waste     | olations |     Wastewater Discharge   |     completed.  |
| Water     | of       |     System                 |                 |
| Tr        | p        |                            | -   Basis       |
| eatment** | ermitted | -   Establish baseline of  |     document    |
|           | d        |     current situation as   |     completed.  |
|           | ischarge |     documented in the      |                 |
|           | limits   |     Notices of Violation   | -   Engineering |
|           |          |     reports and the        |     evaluation  |
|           |          |     Engineering Basis      |     and design  |
|           |          |     Document by 8/31/04    |                 |
|           |          |                            |   modifications |
|           |          | -   Complete engineering   |     documented  |
|           |          |     evaluation and design  |     and design  |
|           |          |     for modification to    |     completed.  |
|           |          |     current system to      |                 |
|           |          |     reflect current permit | -   New         |
|           |          |     requirements and       |     modified    |
|           |          |     operational needs      |     oil water   |
|           |          |                            |     separator   |
|           |          | -   Install new equipment  |     installed.  |
|           |          |     by 10/31/04            |                 |
|           |          |                            | -   Employees   |
|           |          | -   Document and implement |     trained on  |
|           |          |     operational controls   |     operation   |
|           |          |                            |     and         |
|           |          | -   Monitor operational    |     maintenance |
|           |          |     controls               |     of the      |
|           |          |                            |     system.     |
|           |          | -   Document BMPs          |                 |
|           |          |                            |                 |
|           |          | -   Train employees        |                 |
|           |          |                            |                 |
|           |          | > **Target Date:           |                 |
|           |          | > 07/31/05**               |                 |
+-----------+----------+----------------------------+-----------------+
| **Fuel    | Increase | -   Restructure Sing-Out   | -   Signout     |
| Co        | fuel     |     procedures to better   |     procedures  |
| nsumption | economy  |     utilize fleet          |                 |
| and       | within   |     equipment              |    restructured |
| Excessive | the      |     characteristics in the |     to optimize |
| Idling**  | di       |     areas of fuel economy  |     fleet       |
|           | vision's |     and feasibility.       |     assignments |
|           | bus      |                            |     and fuel    |
|           | fleet    | -   Restructure the        |     economy.    |
|           |          |     vehicle starting       |                 |
|           |          |     process for the        | -   Vehicle     |
|           |          |     November 2004 Change   |     starting    |
|           |          |     Day period (Nov. 2004  |     process     |
|           |          |     -- April 2005).        |     revised to  |
|           |          |                            |     limit       |
|           |          | -   Document and evaluate  |     idling down |
|           |          |     the effectiveness of   |     to one hour |
|           |          |     the changes to the     |     or less.    |
|           |          |     system by April 29,    |                 |
|           |          |     2005.                  | -   Vehicle     |
|           |          |                            |     idling      |
|           |          | -   Develop and implement  |     policy      |
|           |          |     vehicle idling         |     developed   |
|           |          |     procedures for         |     and         |
|           |          |     maintenance and        |     approved    |
|           |          |     operations employees   |     for Bus     |
|           |          |     by 11/31/2004          |     Operations  |
|           |          |                            |     and         |
|           |          | -   Document and refine    |                 |
|           |          |     fuel delivery          |    Maintenance. |
|           |          |     procedures and         |                 |
|           |          |     overfill reporting     | -   Fuel        |
|           |          |     requirements by        |     delivery    |
|           |          |     09/30/2004.            |     procedure   |
|           |          |                            |     documented  |
|           |          | -   Investigate fuel       |     and         |
|           |          |     economy improvement    |     trained.    |
|           |          |     opportunities by       |                 |
|           |          |     10/31/2004             | -   Fleet       |
|           |          |                            |     Engineering |
|           |          | -   Have Fleet Engineering |     study       |
|           |          |     study areas within the |     completed.  |
|           |          |     system and make        |                 |
|           |          |     recommendations for    | -   Fuel        |
|           |          |     areas of improvement   |     economy has |
|           |          |     by 9/30/ 2004          |     improved in |
|           |          |                            |     the         |
|           |          | > **Target Date:           |     fenceline   |
|           |          | > 05/31/05**               |     facilities  |
|           |          |                            |     as idling   |
|           |          |                            |     has been    |
|           |          |                            |     reduced by  |
|           |          |                            |     about 70%.  |
+-----------+----------+----------------------------+-----------------+
| **Used    | To       | -   Develop standard       | -   SOP         |
| Oil       | document |     operating procedures   |     adopted,    |
| Man       | the      |     for used oil           |     approved    |
| agement** | handling |     management by 11/30/04 |     and         |
|           | and      |                            |     training    |
|           | r        | -   Train maintenance      |     completed.  |
|           | ecycling |     fenceline employees by |                 |
|           | of used  |     02/28/05               |                 |
|           | oil      |                            |                 |
+-----------+----------+----------------------------+-----------------+
| **Used    | To       | -   Develop standard       | -   SOP         |
| Oil /     | document |     operating procedures   |     adopted,    |
| Fuel /    | the      |     for handling used oil  |     approved    |
| A         | handling |     / fuel / antifreeze    |     and         |
| ntifreeze | of used  |     filters by 11/30/04    |     training    |
| Filters** | filters  |                            |     completed.  |
|           |          | -   Train maintenance      |                 |
|           |          |     fenceline employees by |                 |
|           |          |     02/28/05               |                 |
+-----------+----------+----------------------------+-----------------+
| **Aerosol | To       | -   Develop standard       | -   SOP         |
| / Paint   | document |     operating procedures   |     adopted,    |
| Can       | the      |     for handling and       |     approved    |
| D         | proper   |     disposal of aerosol    |     and         |
| isposal** | disposal |     and paint cans by      |     training    |
|           | of       |     11/30/04               |     completed.  |
|           | aerosol  |                            |                 |
|           | and      | -   Train maintenance      |                 |
|           | paint    |     fenceline employees by |                 |
|           | cans     |     02/28/05               |                 |
+-----------+----------+----------------------------+-----------------+

**Benefits of Adopting an EMS**

The core team regards the process of establishing an EMS program as very
productive. The adoption of the EMS program has improved its ability to
anticipate and evaluate potential environmental aspect and associated
impacts. With the adoption of its EMS, UTA has realized the following
benefits:

-   Increased employee awareness of environmental issues

-   Increased management awareness

-   Reinforcement of environmental processes currently in place

-   Employee involvement with EMS implementation

-   Proactive management systems

-   Documentation of standard operating procedures

-   Institutionalization of best practices in and permanent improvements
    of on-time performance

-   Increased fuel economy of 3% due to reduction of bus idling time

-   Reduction of air emissions

-   Reduction of amount of oil in waste water by a factor of 10

-   Reduction in adverse employee effects from print shop

-   Training matrix for maintenance and operations

-   Database for tracking employee training

-   Increased employee initiative

-   Increased accountability throughout organization

-   Built-in controls

-   Increased ability to identify exposure and smaller aspects

-   Framework for sustainable growth

**Resources**

The resources needed to implement the EMS at UTA are represented below:

  --------------------------------------------------- -------------------
  **Members**                                         **Hours**

  Environmental Management Representative             14

  Core Team                                           1,534

  Other                                               1,200

  Consulting                                          0

  **TOTAL Hours**                                     **1,827**
  --------------------------------------------------- -------------------

**Total Internal Labor Cost \$ 72,964**

**Cost Savings**

UTA documented the following cost savings during the initial EMS
implementation:

+-----------------------------------------------+----------------------+
| **Efficiency**                                | **Annual Savings**   |
+-----------------------------------------------+----------------------+
| Idling fuel savings policy                    | \$675,000            |
+-----------------------------------------------+----------------------+
| Idling labor savings                          | \$63,000             |
+-----------------------------------------------+----------------------+
| Emission Reductions                           | PM=2,484 lb/yr       |
|                                               |                      |
|                                               | NOx=91,125 lb/yr     |
|                                               |                      |
|                                               | **CO2=3,037, 500     |
|                                               | lbs/y**r             |
+-----------------------------------------------+----------------------+
| Addressing print shop environmental issues    | \$72,000             |
+-----------------------------------------------+----------------------+
| Industrial waste savings (one time)           | \$500,000            |
+-----------------------------------------------+----------------------+
| Recycle used oil                              | \$4,000              |
+-----------------------------------------------+----------------------+
| **Grand Total** calendar **2005**             | \$1,300,000          |
+-----------------------------------------------+----------------------+
| Annualized savings each year in future        | \$814,000            |
+-----------------------------------------------+----------------------+

**Next Steps**

Based on the success UTA has experienced in implementing an EMS at its
Meadowbrook division, the organization is seeking to further expand the
ISO 14001 standard to each of the six remaining bus and rail operating
divisions. The current plan is to complete the process by the end of
2005. While the EMS will not be formally implemented in the Capital
Development Office, the office is reevaluating the existing quality
assurance and quality control programs and will likely adopt a frame
work similar to that of ISO quality improvement programs.

**Management Commitment**

The management of UTA is highly committed to the continued success of
ISO 14001 and the EMS within the organization. The high levels of
commitment from top management have contributed greatly to UTA's overall
success with the program. This, coupled with FTA support, has produced a
positive and growing experience for the core team as well as all UTA
employees. The ultimate result will not only be satisfaction from UTA,
but a sustainable system that will continue to serve the public and
environment of Utah.

+-----------------------------------------------------------------------+
| ![](media/image44.jpeg){width="1.8833333333333333in"                  |
| height="0.5125in"}                                                    |
|                                                                       |
| > *".......I'm proud of our employees who come to work each day,      |
| > doing their part to bring a better quality of life to residents,    |
| > businesses and all those who live and work along the Wasatch Front. |
| > This attitude reflects our agency's commitment to the environment   |
| > and our desire to protect and manage the resources around us.*      |
| >                                                                     |
| > *Many of you have heard the phrase, 'think globally, and act        |
| > locally,' which means that actions to protect our rich natural      |
| > heritage begin at home. That is why the Utah Transit Authority is   |
| > working to further develop its Environmental Management System and  |
| > to be one of the first public transit agencies in the nation to     |
| > become certified with the International Standards Organization's    |
| > ISO 14001 principles. ........The EMS is a business management tool |
| > for any organization.*                                              |
| >                                                                     |
| > *UTA's Environmental Management System helps managers identify      |
| > harmful environmental impacts of our projects, services and         |
| > activities and finds ways to resolve and prevent these impacts. And |
| > it allows every employee to take part in preventing problems and    |
| > promoting environmental sustainability at work and even at home.    |
| > ...The implementation of an Environmental Management System is not  |
| > just a requirement\--it's a good idea........"*                     |
|                                                                       |
| **John Inglish, General Manager, UTA**                                |
+-----------------------------------------------------------------------+

**UTA Audit Report**

This Environmental Management System (EMS) Audit was based on a request
by Virginia Tech (VT) and the Federal Transit Administration (FTA) as a
final follow-up to an eighteen month program for EMS development and was
conducted in accordance with the approved schedule.

Ms. Michele M. Lawton -- EMS Specialist with Virginia Tech conducted the
EMS Audit for Utah Transit Authority (UTA) -- Salt Lake City, UT on
August 11 and 12, 2005 to report on its conformance with the
requirements of the ISO 14001:1996 standard.

The EMS was evaluated against each of the requirements set out in the
ISO 14001:1996 standard titled "Environmental management system --
Specification with guidance for use." The Audit included the examination
of documents, interviews of personnel and observations of activities and
conditions.

The site visit involved a review of the core EMS documents with the EMS
team. The UTA EMS Team participated in the review and discussion
regarding the scoring.

The following scores are the result of the EMS Assessment:

1\. The overall score for the Assessment with respect to meeting the
requirements of an EMS as specified in the ISO 14001:1996 Standard is
**ninety-nine percent (99%)**.

2\. **Ninety-nine percent (99%)** of the requirements were **"met."**

3\. **One percent (1%)** of the requirements was **"partially met."**

**Detailed scoring on next page**.

**UTA EMS Audit Results**

The following graph compares the total number of requirements met
*(shown in blue)* to the total number of requirements from the ISO
14001:1996 Standard *(shown in green)*.

This section compares the percentage of requirements *met*, *partially
met*, and *not met* in each element of the EMS.

  ------------ -------------------------------- --------- ----- ----------- ------- ----------------------
  The ISO                                       Overall   Met   Partially   Not Met Ref.
  14001:1996                                                                        
  Standard                                                                          
  Elements of                                                                       
  an EMS                                                                            

                                                Score (%) (%)   Met (%)     (%)     

  4.2          Environmental Policy             100       100   \-          \-      [4.2.10]{.underline}

  4.3.1        Environmental Aspects            100       100   \-          \-      [4.3.11]{.underline}

  4.3.2        Legal & Other Requirements       100       100   \-          \-      [4.3.21]{.underline}

  4.3.3        Objectives & Targets             100       100   \-          \-      [4.3.31]{.underline}

  4.3.4        Environmental Management         88        75    25          \-      [4.3.41]{.underline}
               Program(s) (EMPs)                                                    

  4.4.1        Structure & Responsibility       100       100   \-          \-      [4.4.11]{.underline}

  4.4.2        Training, Awareness & Competence 100       100   \-          \-      [4.4.21]{.underline}

  4.4.3        Communication                    100       100   \-          \-      [4.4.31]{.underline}

  4.4.4        EMS Documentation                100       100   \-          \-      [4.4.41]{.underline}

  4.4.5        Document Control                 100       100   \-          \-      [4.4.51]{.underline}

  4.4.6        Operational Control              100       100   \-          \-      [4.4.61]{.underline}

  4.4.7        Emergency Preparedness &         100       100   \-          \-      [4.4.71]{.underline}
               Response                                                             

  4.5.1        Monitoring & Measurement         100       100   \-          \-      [4.5.11]{.underline}

  4.5.2        Nonconformance, Corrective &     100       100   \-          \-      [4.5.21]{.underline}
               Preventive Action                                                    

  4.5.3        Records                          100       100   \-          \-      [4.5.31]{.underline}

  4.5.4        EMS Audit                        100       100   \-          \-      [4.5.41]{.underline}

  4.6          Management Review                100       100   \-          \-      [4.6.10]{.underline}
  ------------ -------------------------------- --------- ----- ----------- ------- ----------------------

**The Washington Metropolitan**

![](media/image46.jpeg){width="2.601574803149606in"
height="1.522047244094488in"}![](media/image47.wmf){width="0.5in"
height="0.3826771653543307in"} **Area Transit Authority**

**Profile**

Based on annual passenger miles, the Washington Metropolitan Area
Transit Authority (WMATA) operates the second largest rail transit
system and the fifth largest bus network in the United States. Safe,
clean and reliable, "America's Transit System" transports more than a
third of the federal government to work and millions of tourists to the
landmarks in the Nation's Capital. Thirty-five Metrorail stations serve
federal facilities and 47 percent of Metro's peak period commuters are
federal employees.

![](media/image48.jpeg){width="2.08125in" height="2.571527777777778in"}

WMATA was created in 1967 by an Interstate Compact to plan, develop,
build, finance and operate a balanced regional transportation system in
the National Capital area, including the District of Columbia, and
portions of Virginia and Maryland. Construction of the Metrorail system
began in 1969. Subsequently, WMATA acquired four area bus systems in
1973. The first phase of the Metrorail began operation in 1976 and the
final leg of the planned 103-mile system was completed in 2001. In 2004,
the first in-fill station opened along with two extension stations.
There are now 86 Metrorail Stations serving a 106-mile system. The bus
system services 12,435 bus stops. Additional expansions of Metrorail are
in the planning stages.

Metrorail and Metrobus serve a population of 3.5 million within a 1,500
square mile area. Overall, 42 percent of those working in the center
core -- Washington and parts of Arlington County -- use mass transit.
Over a million riders per day are served by a fleet of 950 rail cars and
over 1400 buses (including 160 fueled by CNG) with more cars and buses
to arrive in the next few years.

WMATA is governed by a Board of Directors that is comprised of six
appointed voting members and two appointed alternates from the District
of Columbia, Virginia and Maryland. The General Manager/Chief Executive
Officer serves at the Board's pleasure and operates WMATA, which employs
over 10,000 people.

Since WMATA's inception, the federal government has contributed 65
percent of the capital costs for construction. Fares and other revenue
fund 56 percent of the daily operations while state and local
governments fund the remaining 44 percent. There is no dedicated source
of funding for WMATA. The FY2006 operating budget is about \$1 billion
and the capital budget is \$500 million.

**Fenceline**

With support from the Chief Operating Officer for Metrorail, WMATA
safety and environmental management chose the Greenbelt Rail Yard to be
the fenceline for the pilot program to implement the ISO 14001 standard
Environmental Management System (EMS). The facility is a 90-acre site
located in Beltsville, Maryland. There are several organizations from
the Department of Operations that work at or report to Greenbelt Rail
Yard 24 hours/day, seven days/week, including Car Maintenance, Plant
Maintenance, Systems Maintenance, Track and Structures and Rail
Transportation, with a total of 155 union and 10 nonunion. The following
operations occur at the Greenbelt Yard:

**Car Maintenance
(CMNT)**![](media/image49.jpeg){width="2.3652777777777776in"
height="1.7833333333333334in"}

The majority of the CMNT employees work at the Service and Inspection
Shop (7 tracks), which is a maintenance facility and a
service/inspection area. Maintenance activities include complete and
routine inspections, routine servicing, preventive maintenance, minor
body repairs and interior and exterior cleaning. To manage the expanding
fleet, additional heavy repair and overhaul are now located at this
facility.

There is a paint booth and body shop where each rail car is prepared and
painted. The Maryland Department of the Environment (MDE) has issued a
permit for this operation.

In another building, a group is dedicated to the maintenance of track
equipment used to maintain the system.

**Plant Maintenance (PLNT)**

PLNT is responsible for maintaining stationary equipment and providing
custodial and grounds maintenance services. Many of the employees report
to the Greenbelt Yard but work throughout the system and include HVAC
maintenance and landscaping crews. Small engine repairs and custodial
serves are provided on-site.

**Systems Maintenance (SMNT)**

SMNT is responsible for communications, power, and automatic fare card
systems. The employees that report to the Greenbelt Yard perform battery
maintenance and some communication repairs.

**Track and Structures
(TRST)**![](media/image2.jpeg){width="2.540277777777778in"
height="1.6840277777777777in"}

These employees mostly report to the Greenbelt Yard and pick up
equipment prior to making repairs at other locations. Equipment and
materials are stored in the Yard. Diesel and gasoline fueling is
available for track equipment as well as non-revenue vehicles and other
equipment.

**Rail Transportation (RTRA)**

The rail operators report to this location prior to being dispatched to
passenger rail cars. Around 40 operators report to this facility.

WMATA was fortunate in that there was an established environmental
program with a policy manual based on ISO EMS and there were procedures
established to address regulatory requirements. However, a recent
internal audit of the program indicated that there were communication
and cooperation concerns between the groups sharing Rail Yards. It was
concluded that Greenbelt, the only Yard with a painting operation in
addition to the multiple groups, would be an excellent prototype.

**Core Team**

Our EMS core team consisted of six members:

-   Kevin Lyons, Director, Department of Safety and Risk Protection

-   Joan LeLacheur, Manager of Environmental Services

-   Diana Wood, Environmental Protection Oversight Administrator

-   Earl Harper, Supervisor in Car Maintenance

-   David Hardt, Supervisor in Car Maintenance

-   Claire Fox of Versar, Inc., Environmental Services Consultant

**Key Drivers for Adopting an EMS**

Because WMATA had an ISO 14001 based environmental program, management
determined that it should be fully implemented. The FTA-sponsored
program offered an opportunity for WMATA to learn from others how to
most successfully achieve this goal.

WMATA was also aware of the potential benefits for adopting an EMS and
was receiving encouragement from regulatory agencies throughout the
region to adopt the formal system. WMATA management has identified
communication as a key challenge throughout the organization. The EMS,
with a substantial communication component, could result in
improvements.

**Significant Aspects and Impacts**

The Core Team reviewed rating criteria with environmental staff and
decided to adopt a matrix that first rated negative impacts such as
scale of impact, potential regulatory exposure, probability of
occurrence, and concerns of interested parties to determine the negative
score which represents a lack of controls. The team then rated the
positive impacts such as design, operating procedures; regulatory
compliance history, training and competence to develop a positive
average score for the presence of management controls.

The Team then proceeded to meet with supervisors and other employees
from all of the work groups who report to Greenbelt to review their work
activities and identify and rank the environmental aspects. Over 50
environmental aspects were identified; the most significant were:

-   Rail Car Wash

-   Battery Management

-   Track Lubricators

-   Storm Water Permit

-   Wheel Lathe & Bore

-   Blow Pit

-   Diesel/Gas Storage

In retrospect, the list of aspects was long and detailed. For next year,
the Team intends to generalize this list to better fit our management
program and list aspects such as hazardous waste, storm water
management, wastewater management, and also modify the aspect rating to
include compliance audit results. This would better focus attention,
facilitate training and communications, and provide for continuous
environmental performance improvement.

**Objectives and Targets**

For each significant aspect, the Core Team, with appropriate
supervisors, developed Objectives and Targets to address the significant
environmental aspects.

**Benefits of Adopting an EMS**

There are many benefits identified for adopting an EMS; specific areas
that were significant to WMATA include:

-   Improved employee awareness of potential environmental impacts of
    work activities

-   Improved communications and cooperation through training and
    outreach (over 280 employees)

-   Improved awareness through banners, flyers, environmental posters
    and cup cozies![](media/image284.jpeg){width="1.75in"
    height="1.8069444444444445in"}

-   Improved knowledge of work activities

-   Improved relations with regulatory agencies

-   Modified environmental procedures and improved work procedures

-   Gap analysis for ISO 14001 EMS certification

-   Adoption of an environmental policy for the Greenbelt Yard

-   Improved environmental performance in all the significant aspects
    and other aspects and reduced environmental liabilities

**Resources**

Since we first met with Virginia Tech and FTA, through June 1, 2005, the
following labor hours were expended:

[Hours]{.underline}

> EMS Core Team 1535

Other WMATA Employees 223

Consultant 670

Employee Training [560]{.underline}

**TOTAL 2988**

The total costs (using estimated hourly costs) were:

WMATA labor \$ 150,670

Consultant 48,127

Travel 10,200

Materials [2,600]{.underline}

**TOTAL \$211,597\***

\*These expenses were reallocated within the existing environmental
management budget.

We found that resources can be an issue given competing priorities at
WMATA and the demands of the existing environmental program. The Core
Team envisions that this commitment of resources will be reduced as the
EMS is expanded using the Greenbelt environmental procedures and
components of the existing program.

**Cost Savings and Avoidance**

The Authority has had an environmental management program in place for
over ten years so that many of the typical cost reductions obtained
through waste minimization and pollution prevention have already been
realized. For example, solvent parts washers were previously replaced by
aqueous parts washers which significantly reduced waste and exempted the
bus divisions as hazardous waste generators.

Through the EMS implementation at Greenbelt, some direct savings were
obtained. The inline lathe/wheel bore environmental aspect involved the
refusal by the metal recycle contractor to pick up the oily metal chips
generated. If the chips can not be recycled, WMATA must dispose of them
as oily waste at a cost of \$135/drum or about \$3500/year. Instead, the
team found a way to absorb the oil prior to recycling so that the
Authority would be **[paid]{.underline}** about \$3300/year by the
recycle contractor (price varies with the market). Therefore, we have a
net gain of \$6800/year at the fence line. When the program is expanded
to the other rail yards that generate the oily chips, there is a net
gain of over \$34,000/year.

We also believe there are cost savings obtained in improving the
management of diesel and gas cans and lead acid batteries by reducing
the potential for spills. Further, training in storm water management
and EMA awareness and should reduce the likelihood of spills.

We see greater intangible benefits and reduced environmental
liabilities. There have been improvements in communication and
cooperation within the fence line and a new appreciation for
environmental requirements by the employees. The EMS team gained a
better understanding of work activities and their impacts. We anticipate
more cost savings and reduced liabilities as the EMS is implemented at
additional facilities.

**Next Steps**

The EMS Core Team sees the EMS components divided into three basic
areas:

Administrative: Document Control, Structure/Organization, Legal
Requirements,

Audits, Management Reviews, Records, Monitoring & Measuring

Communications: Environmental Policy, Training and Outreach

Actions: Aspects, Objectives and Targets, Environmental Management

> Plans, Operational Controls, Contractor Management, Emergency
>
> Response, Corrective/Preventive Actions

Although there are interactions between these three areas, it is a
framework for the participants. The Administrative components are mostly
addressed by safety and environmental management. The actual operating
work groups at the facility are the keys to the Actions components. All
employees are involved with communications, with safety and
environmental management taking the lead.

Given the success of this model, WMATA will continue to maintain the EMS
at Greenbelt Yard and will determine how best to expand it. Future steps
include:

-   Based on our pre-assessment, fill in gaps in preparation for the
    Virginia Tech EMS Audit (8/31/05) and continue quarterly internal
    EMS audits

-   Reevaluate environmental aspects based on the compliance audit and
    lessons learned

-   Develop a plan for expansion to other facilities

-   Identify alternative training method for training in Spring 2006

-   Transfer the Intranet-based WMATA EMS site to an Internet-based site

-   Expand participation in the Greenbelt EMS

**Management Commitment**

The most senior management of WMATA was committed to the intent of the
FTA-sponsored implementation of the EMS at the fence line. However, as
the program progressed, it was difficult to get consistent participation
and support due to competing priorities and reorganizations. The EMS
Core Team realigned the management presentation to show how the EMS
goals supported WMATA's priorities. Improved work procedures and
environmental performance strengthen WMATA's primary service and
reliability goals. This helped WMATA's senior management to better value
the benefits of an EMS and understand management's role.

The Team also refocused its efforts to concentrate on the senior
management at Greenbelt. The senior management from each WMATA operating
work group were invited to the fourth quarter presentation. This
presentation was then repeated for the Greenbelt Environmental
Compliance Officer and Deputy Compliance Officers for each working group
in addition to some supervisors.

The Greenbelt Environmental Compliance Officer and Deputies from each
work group comprise the senior management for the Greenbelt Yard. They
have approved and adopted the environmental policy for the Yard. This
senior management team will continue to support and maintain the EMS at
Greenbelt.

**WMATA Audit Report**

This Environmental Management System (EMS) Audit was based on a request
by Virginia Tech (VT) and the Federal Transit Administration (FTA) as a
final follow-up to an eighteen month program for EMS development and was
conducted in accordance with the approved schedule.

Ms. Michele M. Lawton -- EMS Specialist with Virginia Tech conducted the
EMS Audit for WMATA -- Washington D.C. on August 31 and September 1,
2005 to report on its conformance with the requirements of the ISO
14001:1996 standard.

The EMS was evaluated against each of the requirements set out in the
ISO 14001:1996 standard titled "Environmental Management System --
Specification with guidance for use." The Audit included the examination
of documents, interviews of personnel and observations of activities and
conditions.

The site visit involved a review of the core EMS documents with the EMS
team. The WMATA EMS Team participated in the review and discussion
regarding the scoring.

The following scores are the result of the EMS Assessment:

1\. The overall score for the Assessment with respect to meeting the
requirements of an EMS as specified in the ISO 14001:1996 Standard is
**ninety-seven percent (97%)**.

2\. **Ninety-four percent (94%)** of the requirements were **"met."**

3**. Six percent (6%)** of the requirements were **"partially met."**

**Detailed scoring on next page**.

**WMATA EMS Audit Results**

The following graph compares the total number of requirements met
*(shown in blue)* to the total number of requirements from the ISO
14001:1996 Standard *(shown in green)*.

This section compares the percentage of requirements *met*, *partially
met*, and *not met* in each element of the EMS.

  ------------ -------------------------------- --------- ----- ----------- ------- ----------------------
  The ISO                                       Overall   Met   Partially   Not Met Ref.
  14001:1996                                                                        
  Standard                                                                          
  Elements of                                                                       
  an EMS                                                                            

                                                Score (%) (%)   Met (%)     (%)     

  4.2          Environmental Policy             100       100   \-          \-      [4.2.10]{.underline}

  4.3.1        Environmental Aspects            100       100   \-          \-      [4.3.11]{.underline}

  4.3.2        Legal & Other Requirements       100       100   \-          \-      [4.3.21]{.underline}

  4.3.3        Objectives & Targets             100       100   \-          \-      [4.3.31]{.underline}

  4.3.4        Environmental Management         100       100   \-          \-      [4.3.41]{.underline}
               Program(s) (EMPs)                                                    

  4.4.1        Structure & Responsibility       80        60    40          \-      [4.4.11]{.underline}

  4.4.2        Training, Awareness & Competence 100       100   \-          \-      [4.4.21]{.underline}

  4.4.3        Communication                    100       100   \-          \-      [4.4.31]{.underline}

  4.4.4        EMS Documentation                100       100   \-          \-      [4.4.41]{.underline}

  4.4.5        Document Control                 100       100   \-          \-      [4.4.51]{.underline}

  4.4.6        Operational Control              88        75    25          \-      [4.4.61]{.underline}

  4.4.7        Emergency Preparedness &         100       100   \-          \-      [4.4.71]{.underline}
               Response                                                             

  4.5.1        Monitoring & Measurement         88        75    25          \-      [4.5.11]{.underline}

  4.5.2        Nonconformance, Corrective &     100       100   \-          \-      [4.5.21]{.underline}
               Preventive Action                                                    

  4.5.3        Records                          100       100   \-          \-      [4.5.31]{.underline}

  4.5.4        EMS Audit                        88        75    25          \-      [4.5.41]{.underline}

  4.6          Management Review                100       100   \-          \-      [4.6.10]{.underline}
  ------------ -------------------------------- --------- ----- ----------- ------- ----------------------