From: bm@bike2work.Eng.Sun.COM
Newsgroups: ca.environment
Subject: 91 Clean Air Plan
Date: 10 Apr 92 06:18:24 GMT
Reply-To: bm@bike2work.Eng.Sun.COM ()
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Organization: Sun Microsystems, Inc.  Mt. View, Ca.
NNTP-Posting-Host: bike2work


						
						The following is a copy of the State Air Resources
						Board's review of the Bay Area Air Quality Management
						District's "Clean Air Plan".

						There will be a public hearing on the topic on April 30th. For those interested in attending the hearing,

						contact bill michel for carpool info (bm@eng.sun.com).

						Bill
                              State of California
                              AIR RESOURCES BOARD








 PUBLIC MEETING TO CONSIDER THE APPROVAL OF
THE BAY AREA AIR QUALITY MANAGEMENT DISTRICT'S
             1991 CLEAN AIR PLAN









Date of Release:   March 30, 1992
To be Considered:  April 30, 1992
Agenda Item No.:   92-5-1








     This report presents the Air Resources Board (ARB or Board)
     staff analysis of and recommendations on the Bay Area Air
Quality Management District's (AQMD or District) 1991 Clean Air
Plan (plan).

     The plan was adopted by the District on October  30,  1991
     and  submitted to the Board for review on November 13,
1991.  Under state law, ARB must determine the adequacy of each
plan within  12  months  of  receipt.  Findings to be made by
the Board include:  whether  applicable  control  measures  have
been incorporated, and whether expeditious progress will be made
toward attainment of the state standards.

     The Bay Area AQMD is nonattainment for four of the state's
     twelve ambient air quality standards:  ozone  (1-hour),
carbon  monoxide  (8-hour), and particulate matter (24-hour and
annual).  The  District  also  experiences visibility problems
but, like the rest of the state, is currently unclassified for
that standard.

     Consistent with state law, the District's plan  addresses
     only  ozone  and carbon monoxide. Planning for
particulate  matter  and  visibility  reducing particles
has      been deferred pending further direction from the State
Legislature.        However, the strategies contained in the
plan  are  expected  to reap  benefits      for all
nonattainment pollutants.

     The  plan predicts attainment of the state carbon
     monoxide  standard  by approximately 1995.  No forecast for
ozone attainment is provided due to data base  and modeling
deficiencies. The plan  does  express  the  expectation that the
federal ozone standard will be attained  by  1997,  however.
The  plan also indicates that population exposure to
unhealthful  ozone  levels  will  be halved by  1994.

     The plan includes 50 proposed measures for  stationary
     and  area  sources.  Of these, 21 are to be fully adopted
by the end  of  1994.  Initial  action  on six other multi-phase
measures will be accomplished  during  the  same  period.

     The plan also contains 23 transportation control measures.
     Each of these comprise several elements and will be
implemented  in  various  stages, by various agencies,
throughout the decade.  A key exception is the employer-based
trip reduction rule scheduled for  District  adoption  in
1992.

     The plan incorporates the Board's motor  vehicle,  fuels,
     and  consumer product regulations. Most of these are
reflected  in  the  baseline  emission inventory forecast;
future measures are discussed in the  text  of  the  plan.  The
ARB measures, along with vehicle turnover, account for
approximately  75'Kl of the ozone precursor reductions claimed
in  the  1987-1994  period.  State measures account for almost
all of the carbon  monoxide  emission  decreases  in that
timeframe.

     The plan satisfies most of the California Clean Air Act
     requirements.  The applicable control measures for serious
and severe nonattainment  areas have been incorporated (the
self-assigned classifications for carbon monoxide and ozone,
respectively).  Emission accounting and ranking of measures by
cost-effectiveness has been done.  Transport mitigation
requirements set forth in ARB regulations are met.

     The plan will not achieve five percent annual emission
     reductions  for either carbon monoxide, hydrocarbons, or
oxides of nitrogen.  This is not a legal deficiency, however, if
the Board finds that the plan contains all feasible measures and
that the District is implementing those measures expeditiously.
In staff's view the plan generally meets these  tests,  with the
reservation noted below.

     The transportation portion of the plan is a major step
     forward, yet not as fully developed in some areas as state
law requires.  Though all aspects of the Act have been
addressed, several individual measures lack  essential details,
implementation milestones, or commitments from responsible
agencies.  Therefore, the transportation strategies are only
partially approvable.

     Staff is recommending that the Board approve all elements
     of the  plan found to conform with the California Clean Air
Act. This will  enable  work to proceed on completed elements.
Staff is recommending that the remaining portions of the plan be
conditionally approved, until such time as the needed changes
have been submitted.  Schedules for completing plan
modifications will be proposed by staff at the public meeting,
after consultation with the District and other affected
agencies.

     The primary issue surrounding the plan is whether it in
     fact  includes all feasible measures.  As noted above, the
Bay Area must satisfy this test since its plan will not achieve
five percent annual emission reductions.  "Feasible" is not
defined in the Act and must therefore be interpreted by the
Board.  The interpretation recommended by staff is set forth in
the body of this report ("Evaluation of District Plan," Section
C.1).  A contrary view, advanced by several environmental
groups, is set forth in the  public comment section.  The Board
will have to embrace one interpretation of feasibility in order
to make the statutorily required findings on this  and other
district plans.

I.   BACKGROUND

     A.    Development of the District Plan

     The California Clean Air Act assigns lead responsibility
     for  plan preparation to each district. In the San
Francisco Bay  Area,  companion legislation directs the
Metropolitan Transportation Commission (MTC  or Commission) to
prepare transportation control measures for inclusion in  the
District's plan (AB 3791, Cortese; Chapter 1569, Statutes of
1988).  The Commission provided those measures to the District
in December of  1990.

     The Association of Bay Area Governments (ABAG) is not
     legally obligated to participate under state law.  However,
ABAG has extensive planning experience, was co-lead for federal
air quality planning between 1979  and 1987, and has signed a
memorandum of understanding with the District and MTC ensuring
continued coordination. ABAG's role in 1991  plan  preparation
included development of population growth projections and
production of  the draft plan.

     A draft plan was released by the District in April 1991.
     After  a lengthy public comment period and multiple
@orkshops, the plan was substantially amended and re-issued. The
final plan was adopted  by  the District Board, unanimously, on
October 30, 1991.

     B.    Incorporation of State Measures

     Although districts bear chief responsibility for writing
     air  quality plans, the contents reflect all actions being
taken to reduce air pollution.  Efforts of other agencies,
changes in the marketplace, changes in  societal behavior are
all accounted for -- to the extent that they affect  emissions.

     The Air Resources Board with its comprehensive motor
     vehicle,  fuels, mobile source, and consumer product
regulations is a major partner in  every plan.  The impact of
existing state regulations is represented in the baseline
emission inventory forecasts for each district.  Recently
adopted and pending controls are assessed individually and may
be discussed in  the text of district plans. Controls adopted
after District plan  adoption  but prior to ARB plan approval
will be identified in these staff reports  and, where
appropriate, in the Board's final resolution.

     In this instance, ARB regulations and the associated
     turnover of  the vehicle fleet account for most of the
claimed ozone precursor reductions before 1994 -- between
85-90%. By 1997, District measures will  shift  the balance to
60/40 for ozone precursors, with ARB providing the larger
share.  By the year 2000, the balance will shift back to the
state, with ARB measures accounting for 73% of the total
decreases in ozone  precursors.

     State measures account for virtually all of the carbon
     monoxide reductions between 1987 and 1995 (the projected
attainment year).

     C.    Mandates Governing Plan Review and Approval

     The Board has primary responsibility under the Act for
     overseeing the statewide planning effort.  The ARB must
review and approve all attainment plans, ensure adequate
coordination and consistency between districts' control
strategies, monitor implementation, and generally track and
enforce compliance with the Act's provisions.  The statutes
governing plan review contain both procedural and substantive
provisions.  These are described, in turn, below.  All legal
citations are for the California Health & Safety Code, unless
otherwise specified.

	  1.    Procedural

     District plans were to have been submitted to ARB for
     review by July I of last year (40912).  Whether on time or
delayed, the Board is given twelve months from receipt of each
plan to make its determinations (41503).  In this case, a final
decision must be rendered by November 13, 1992.

     All actions of the Board to approve or disapprove a
     district's plan must be taken at a noticed public hearing
(41503.4), preceded by 45-day written notice (41502).  The Board
must convene its hearing within the affected air basin, and must
conduct its review to include the plans of every district within
that basin (41503(b)).

     If the Board deems any portion of the plan inadequate, it
     must notify the district of those deficiencies in writing
(41503.2(a)).  This action follows the public hearing, since the
Board must make those findings absent a delegation to ARB's
Executive Officer.  The district is required to correct the plan
and submit the revision to ARB for approval.

     The district may invoke a conflict resolution process if it
     disagrees with ARB's findings of deficiency (41503.2(b)).
The Board is to invoke conflict resolution if the district's
plan revisions are still not adequate, in its judgment, to
remedy the identified deficiencies.  A uniform conflict
resolution procedure was developed in May 1990 to guide this
process (see Appendix A).

     Ultimately, ARB is required to amend deficient district
     plans as it finds and determines necessary to comply with
the Act (41503.2(c)).  Before taking this step, written 45-day
notice must be provided and a second hearing must be convened
within the affected air basin (ibid).

	  2.    Substantive Requirements

     The Board must ensure that district plans comply with the
     Act and with any applicable provision of the Health &
Safety Code (41503.5).  Most of the germane sections are in
Chapter 10 "District Plans to Attain State Ambient Air Quality
Standards," starting with section 40910.  However, others are
scattered throughout the code (e.g., transportation, indirect
sources and area source control measures in sections 40716 and
40717), and some requirements are embedded in the plan review
procedures (41503-41503.5).

     Some of the more important of the latter requirements are
     these:  the requirement that the combination of plans
within an air basin be adequate  to attain state standards
throughout (41503(b)); the mandate to impose  uniform controls
for the same emission sources within an air basin, unless the
district makes a particular demonstration (ibid); the link to
transport mitigation requirements established by the Board
(41503(b)); the  requirement for all feasible controls where a
district is unable to project  attainment or is unable to
achieve five percent annual emission reductions  (41503(d) and
41503.1); and the mandates to attain state standards by the
earliest practicable date (41503(a)) and to adopt controls
expeditiously  (41503.1).

II.   EVALUATION OF THE PLAN

     A.    Technical Foundation and Analyses

	   1.    Emission Inventory

     The Act requires that district plans include consideration
     of  emission inventory characteristics, growth patterns
affecting emissions, and  emission reductions occurring in, or
expected to occur in, the district  (40913).  ARB regulations
require that districts use a planning inventory provided  by the
Board (Title 17, California Code of Regulations [CCR] Sections
70700- 70704) for the 1987 emissions baseline and future year
forecasts.

     Staff believes that the Bay Area plan meets these
     requirements.  The plan describes the District's emission
inventory in detail and  projects trends based on growth in
population, employment, industrial and  commercial activity,
travel, and energy use. In addition, the  ARB-provided  emission
factors have been used for the 1987 baseline inventory and
future year forecasts.

	  RECOMMENDATION: Approve the emission inventory
	  elements  of  the Bay Area plan.

	  2.    Air Duality Analysis

     The Act requires districts to consider the present and
     projected maximum pollutant concentrations, and the
distribution and frequency  of state standard violations
(40913). These factors are discussed in  the  Bay Area plan.

     The Act requires that district plans evidence attainment by
     the earliest practicable date (40913, 41500(a), 41503(a)).
The.most  common methods for making this demonstration are
photochemical modeling for  ozone, and some sort of proportional
roll-back analysis for carbon  monoxide.  Both depend on
adequate data and confidence that the projections are
reliable.

     The District's plan projects attainment of the state
     carbon  monoxide standard by approximately 1995. The main
factors leading to this  result  are the introduction of
wintertime oxygenated fuels and fleet  turnover.  Staff believes
that this assessment is accurate.

     The Bay Area AQMD is unable to generate an attainment
     demonstration for ozone at the present time. The District
undertook a considerable  effort  to apply the Urban Airshed
Model using extensive 1989 field studies.  ARB staff and
computer resources were also dedicated to this  effort.
Unfortunately, the data base and modeling results were not
adequate to support an attainment demonstration. The District is
therefore deferring  the  ozone analysis until more data can be
collected.

     The law allows attainment demonstrations to be deferred,
     provided  that ARB concurs that projecting an attainment
date is impossible  (41503(d)).  When this occurs, the Board
must also determine whether the plan  contains every feasible
control strategy or measure to ensure progress toward attainment
(ibid). The latter requirement is addressed in  detail  below.

     Staff concurs that an attainment demonstration for ozone
     cannot be provided at the current time. The modeling
difficulties experienced  by  the District were genuine,
unavoidable, and cannot be overcome prior to ARB action on the
plan.  Staff is continuing to work with the District on modeling
improvements, to enable future compliance with the attainment
demonstration requirement.

	  RECOMMENDATION:  Approve the carbon monoxide
	  attainment projection. Defer action on the ozone
	  attainment  demonstration until sufficient data are
	  available to support a  photochemical modeling
	  analysis.

	  3.    Presumed Area Classification

     The projected attainment dates for carbon monoxide and
     ozone place  the Bay Area AQMD in the serious and severe
categories, respectively.  The  plan presumes the more stringent
of the two categories and keys the control strategy accordingly.
While reporting both classifications would  be  more technically
correct, staff has no objection to this approach.

	  RECOMMENDATION: Approve the severe area
	  classification  for  the Bay Area District.

     B.    Proposed Control Measures

	   1.    New Source Permitting

     The Act requires that severe nonattainment areas adopt a
     permitting program designed to achieve no net increase in
emissions.  The program, embodied in a permit rule, applies to
all new or modified stationary sources (40920(a)(1)). ARB
transport mitigation regulations  require  the adoption and
implementation of a "no net increase" rule by July 1, 1991,  in
identified upwind districts (see Other Mandated Elements
below).  The  Bay Area adopted amendments to its New Source
Review rule on July 17, 1991,  to comply with these
requirements.

	  RECOMMENDATION: Find the District in compliance with
	  the 'no  net increase' requirement for new and
	  modified permitted stationary sources.

	  2.   Stationary Source Retrofit Measures

     Severe nonattainment areas must consider the application of
     best available retrofit control technology (BARCT) on all
existing sources in the district (40920(a)(1)). BARCT is defined
as "an emission limitation  that is based on the maximum degree
of reduction achievable, taking into account environmental,
energy, and economic impacts by each class or category  of
source" (40406).  ARB's transport mitigation requirements have a
BARCT element as well (see Other Mandated Elements below).

     The 1987 baseline emission inventory for the Bay Area AQMD
     includes approximately 2,400 separate facilities, with a
total of 18,000 different emission sources (e.g., boilers,
combustion units, degreasing tanks, etc.).  Retrofitting all of
them at once is clearly impossible, hence the District has
prioritized its efforts. Emphasis has been placed on emission
reduction potential, technological feasibility, and relative
cost-effectiveness, with the greatest weight falling on the
first factor. This is consistent  with statutory direction that
priority be placed on expeditious progress towards healthful air
(40910).

     The plan commits to retrofitting 17 source categories over
     the  next decade.  In many cases, this involves revisions
to existing rules.  In some cases, it involves more than one
revision.  For example, the improved valve and flanges rule will
require leakless valves, improved inspection and maintenance,
and a more stringent definition of "leaks.' A total of 29
changes have been proposed for the 17 source categories.

     Staff has reviewed the proposed control measures and has
     found them to be generally acceptable.

     The most serious concerns staff had after reviewing the
     draft plan concerned the implementation schedules for
proposed rules.  Staff was particularly concerned by the
schedules for NOx controls on stationary gas turbines and
electric power generating boilers.  The District responded to
those concerns with an expedited schedule for NOx control in the
final plan.

	  RECOMMENDATION:  Approve the BARCT proposals.

	  3.    Area Source Controls

>>     The Act requires that all nonattainment areas include
>>     provisions  to develop area source control programs (40918
>>et seq). 'Area source"  is  a catch-all category for numerous
>>small sources of pollution; for  example, residential water
heaters or cans of spray paint.  It also includes stationary
sources that are too small to be identified individually,  and
large diffuse sources (like the application of pesticides or
cattle  feed lots) that have no single emission point.

responsibility is not exclusive but tends to work out  that
way,  due  to  the federal waiver provisions and the
desirability of statewide uniformity.  Statewide mobile source
controls are seen as more effective and more efficient in many
cases.

     Districts and associated agencies generally focus  on  the
     use  of  motor vehicles. In other words, these agencies
are  striving  to  reduce  the  number of trips taken and/or the
number of miles  driven  through  the  application  of
transportation control measures (TCMs).  The  Bay  Area's
proposed  TCMs  are discussed in the next section.

     Some districts are pursuing local mobile  source  controls
     in  addition  to TCMs. These mobile source controls  are
intended  to  complement  and  enhance the state's programs.

>>     The Bay Area plan contains two  such  mobile  source
>>     measures:  a  citizen complaint program for smoking
>>vehicles; and a  fleet  rule  which  would  require the use of
>>clean fuel vehicles. The  former,  scheduled  for  adoption
this year, is patterned after portions of the  South  Coast's
"Cut  Smog"  program.  The fleet rule is proposed for adoption
during the next planning cycle (1995-1997).

>>     Staff believes that both measures  have  merit.  However,
>>     care  needs  to be taken with local fleet rules so that
>>double-counting of emission reductions, conflicts with the
>>state's  program,  and  other  unintended  adverse effects are
>>avoided. Staff is currently working  with  an  ad  hoc
>>committee  of interested district representatives to  fashion
>>a  workable  approach.  The product of this effort should be
>>available in time  to  meet  the  Bay  Area's proposed
>>schedule.

>>	  RECOMMENDATION:  Approve  the  smoking  vehicle
>>	  complaint  program.  Direct ARB staff to continue
>>	  working with districts on fleet rules, with the
>>	  objective of resolving implementation issues prior to
>>	  the next planning cycle.

	  6.    Transportation Control Measures/System
	  Management

     Perhaps the most challenging provisions of  the
     California  Clean  Air  Act are those related to
transportation.  The  Act  provides  districts  with  much
greater authority and responsibility to mitigate  the  impact
of  vehicular source emissions through the use  of
transportation  control  measures  (TCMs).  To meet this charge,
districts have had to  expand  their  expertise,  break  new
t6chnical ground, and obtain an unprecedented  level  of
cooperation  from  the many local, regional and state agencies
that  are  directly  responsible  for transportation, including
city and county governments.

>>     The staff believes that the Bay Area  agencies  have
>>     performed  well  in this area. The plan represents
>>significant  progress  in  addressing  the  Act's transportation
>>requirements.  However, further improvements in several
>>individual measures are needed before staff can reconrnend
>>that  the  Board

find the plan meets all the requirements of the Act.  The
staff's analysis and recommendations are presented below.

     The nature of TCMs is constantly evolving and the mix of
     implementation responsibilities in the Bay Area, like other
urban areas, is incredibly complex.  Given this, staff
encountered many circumstances during plan review where issues
had to be addressed for the first time.  Staff recommendations
were reached only after extensive thought, dialogue, and
analysis.  Through these recorrfnendations a number of policy
precedents are being proposed for the Board's consideration.
Among them are the criteria used to gauge TCM approvability.

>>     Legal Requirements.  The Act requires long term
>>     nonattainment areas to meet three transportation
>>performance standards.  As part of the strategy to reduce
>>pollution from motor vehicles, the plan must indicate how the
>>area will:  1) substantially reduce the rate of increase in
>>passenger vehicle trips and vehicle miles traveled; 2) attain
>>1.5 passenger vehicle occupancy during weekday commute hours by
>>1999; and 3) achieve no net increase in vehicle emissions after
>>1997.  All nonattainment areas are required to include
>>reasonably available TCMs in their plans, and those unable to
>>achieve 5% annual emission reductions must include all feasible
>>TCMs (40918 et seq).

     Criteria for Approval.  Staff defined general criteria for
     the overall transportation plan and more specific criteria
for the proposed measures.  For the latter, staff assessed the
degree to which the TCMs satisfied both the explicit and
implicit requirements of the Act.  Stated in the form of
questions, the criteria are:

     0    Reasonably available TCMs -- has each one of the
     general control
	  strategies deemed to be reasonably available for
	  transportation sources been addressed in some way?
	  (See below for definition of "reasonably available
	  TCMs.")

     0    Reduced rate of growth in trips and trip length --
     does the plan
	  contain sufficient TCMs to satisfy this requirement?

     0    1.5 Average Vehicle Occupancy -- does the plan contain
     sufficient
	  TCMs to achieve an average vehicle occupancy of 1.5
	  during peak periods by the year 2000?

     0    Technical basis for each measure -- will it actually
     reduce
	  emissions (or slow emission increases) if
	  implemented?

     0    Extent of each measure -- is it substantive enough and
     broad
	  enough to support the finding that reasonably
	  available TCMs have been included in the plan?

     0    Definition of each measure -- is it well enough
     defined so that
	  its implementation can be tracked in the annual
	  progress reports required by the Act?

     0    Degree of comitment to each measure -- has the
     implementing
	  agency accepted responsibility for implementing the
	  measure, and does that agency -have adequate legal
	  authority and resources to carry it out?

     Staff's assessment of the Bay Area's compliance with
     transportation performance performance standards is
summarized below.  The evaluation of individual TCMs is
suffrnarized in Table 1 and presented in more detail in
Appendix  B.

     Reasonably Available TCMS.  In previous guidance approved
     by the Board, staff recommended that "reasonably available
TCMS" be interpreted to include six general strategies:  1) an
employer-based trip reduction rule; 2) trip reduction rules for
other sources (such as universities or entertainment venues); 3)
management of parking supply and parking prices; 4) a High
Occupancy Vehicle or HOV system plan; 5) a comprehensive transit
plan, which also addresses access; and 6) land use strategies to
minimize vehicle trips.

     Staff believe that these general strategies comprise the
     universe of "reasonably available" TCMS.  They are the most
effective TCMs available today and it will take the better part
of this decade to design and implement them.

     Staff finds that the Bay Area plan addresses all of the TCM
     categories identified as reasonably available.  Trip
reduction rules are addressed in TCMs #1, #2 and #16; parking
management is addressed in #22; the HOV system is addressed in
TCM #8; transit is addressed in TCMs #3-7; and, finally,
land-use is addressed in TCMs #18 and #19.

     Staff has significant reservations about the specificity of
     several measures.  Thus, while the scope of the TCMs is
adequate to satisfy the "all reasonable TCMS" test, more depth
is required to find the TCMs fully approvable under the Act (see
Table 1 and Appendix B).

     Reduced Rate of Growth in Trips and Trip Length.  The
     Metropolitan Transportation CorrFnission (MTC) is
predicting a significant decline in the regional growth of
vehicle miles traveled (VMT).  This is a baseline projection,
which is expected to occur even if no additional measures are
implemented.  Annual VMT growth in the 1990's is forecast at 1.4
percent for each 1 percent growth in population.  This compares
to an annual VMT growth rate of 2.4 percent in the 1980's.  MTC
estimates that full implementation of the plan will reduce the
VMT growth rate to 1.1 percent.  Most of this impact would stem
from the proposed pricing measures.

     Previous ARB guidance suggested that holding VMT growth
     rate to the rate of population growth was an appropriate
goal and could constitute "a substantial reduction" as required
by the Act.  In the Bay Area's case, both 1.4 and 1.1 percent
growth in VMT represent a substantial reduction over the current
growth rate.  Staff believes that full implementation of
reasonably available TCMs and the downward trend in the VMT
growth rate is adequate to

meet this requirement of the Act.  During its review of the
draft plan, staff suggested that MTC and the District develop a
monitoring plan to  track the actual growth rate in VMT.  That
plan has been submitted and is now under review by ARB staff.

     1.5     Average Vehicle Occupancy (AVO).  As noted above,
     the Act requires the Bay Area to achieve an AVO of 1.5
during weekday commute hours by 1999.  MTC estimates that the
plan will increase a.m. peak occupancy from a projected baseline
level of 1.43 in 2000 to an average of 1.54 by the same date.
Most of this impact is from pricing measures.  Without  such
measures, the Bay Area cannot demonstrate compliance with the
1.5 AVO  requirement.

>>     Staff concurs with MTC's assessment that the 1.5 AVO
>>     requirement  is very difficult to meet and that pricing
>>measures will probably be needed to achieve that ridership level
>>in the Bay Area. However, since  neither  the District nor MTC
>>possesses adequate legal authority to institute  pricing
>>strategies, the AVO demonstration in the plan is theoretical.
>>Staff recommends that the Board withhold full approval of the
>>AVO  demonstration until the means of implementation have been
>>identified and stronger commitments to the necessary measures
>>and actions have been made.

     No Net Increase in Vehicle Emissions.  The baseline
     emission projections for the Bay Area AQMD indicate a
steady decline in motor  vehicle emissions through the year
2000.  This is in large part due to the combination of ARB
vehicle and fuel controls reflected in the plan.  Staff believes
that this projection, plus the full implementation of
reasonably available TCMS, is more than adequate to comply with
this requirement.

	  RECOMMENDATIONS: Find that the plan addresses  all
	  reasonably available TCMS, but that further definition
	  is needed for  some measures. Approve those TCMs
	  identified in Table 1  that  fully comply with the
	  Act's requirements.  Conditionally approve those TCMs
	  where further actions are needed to comply with the
	  Act, upon receipt of a coninitment from the
	  responsible agency (primarily the District or MTC) to
	  adequately define the  measures on an expeditious
	  schedule.  It is envisioned that most of these
	  improvements will be commitments to near term actions
	  (in  the next 6-12 months).  However, a few may
	  require longer timelines.

Note: At the time this staff report was released, staff was
meeting  with District and MTC representatives to determine if
an acceptable schedule to upgrade the incomplete TCMs could be
devised by the hearing date.  If agreement is reached, the staff
will recommend the consensus schedule to  the Board as part of
its action on the Bay Area plan.

	  Find that the plan satisfies the requirement for a
	  substantial reduction in the growth rate for trips and
	  trip  length.  Also find that the plan satisfies the
	  requirement for no net vehicle emission increases
	  after 1997.

	  Find that the plan does not currently satisfy the 1.5
	  AVO requirement, and recognize that a significant
	  amount of time will be needed to either develop
	  additional TCMs or to obtain  the needed authority and
	  comitments for pricing measures  that  are essential
	  to achieving a 1.5 AVO by the year 2000.

     7.    Miscellaneous Control Measures

     The Bay Area plan contains two unique "intermittent control
     measures." The first of these would encourage citizens to
postpone discretionary activities, such as unnecessary trips and
noncritical maintenance (mowing or painting) during forecasted
ozone episodes. The second measure,  aimed  at industrial
sources, would require curtailment of non-production emission
generating work during episode conditions. Examples of  such
activities include: maintenance coating, repairs of external
floating roof seals, uncontrolled soil aeration, and check out
of stand-by engines.  Industry would also be asked to
voluntarily limit all other activity--including production--to
the extent they can during ozone episodes.

     The voluntary citizens action program was endorsed by the
     District Board and initiated last year. The voluntary
portion of  the  industrial curtailment program is scheduled for
District consideration this year, with the mandatory element
following in 1994.

     Staff cannot confirm the emission reduction estimates for
     these measures until some actual experience with the
programs is gained.  (Note:  the District agrees that the
effectiveness of these measures is difficult to verify and did
not include them in its calculation of average annual emissions
reductions.)

     Staff believes the intermittent control concept is worthy
     of investigation and is monitoring the Bay Area's efforts
with interest.

	  RECOMMENDATION:  Endorse the investigation of
	  intermittent control strategies in the Bay Area plan.
	  Withhold  approval  of specific emission reduction
	  claims pending receipt of an acceptable demonstration
	  of their effectiveness.

     C.    Other Mandated Elements

	   1.    Annual Emission Reductions

     The Act states that each plan shall be designed to reduce
     district-wide emissions by five percent (5%) per year,
unless an alternative measure  of progress is employed (40914).
The District is not proposing an alternative method in the 1991
plan.

     The 5% requirement applies to each nonattainment pollutant
     and to each pollutant precursor covered by the plan.  For
the Bay Area this includes reactive hydrocarbons, oxides of
nitrogen, and carbon monoxide.

     A district plan may show a lesser rate of reduction if the
     district is unable to reduce emissions by 5% per year.
However, three conditions must be satisfied before ARB can
approve a reduced rate:  the Board must concur that the 5% rate
is unachievable; the plan must contain all feasible measures;
and the District must be pursuing an expeditious adoption
schedule (40914(b), 41503.1).  The following sections provide a
lengthy discussion of these conditions.

     ARB regulations require each district to display its
     emission accounting in a clear and straightforward manner
(17 CCR, Sections 70700- 70704).  The regulations also define
the time periods for emission averaging as: 1987-1994,
1995-1997, and 1998-2000.  As discussed above, the regulations
further require that the state issued inventory be used in
district plans.

>>     The combination of state and local measures in the Bay Area
>>     plan falls short of mandated emission reductions.  Instead,
>>the plan indicates cumulative hydrocarbon reductions of 4%
>>annually through 1994, declining to 3.8% per year in the next
>>reporting period, then dropping to 3.1% between 1998 and 2000.
>>[Note: staff expects all district plans to show a downward trend
>>in annual emission reductions through 2000, as opportunities for
>>large reductions are exhausted and growth pressures outpace
>>vehicle turnover.] For NOx, the District is forecasting 2.6%
>>average annual reductions through 1994, 3.4% per year reductions
>>after 1995, dropping back to 2.8% annual decreases after 1997.
>>For carbon monoxide, the plan shows 4% annual decreases through
>>1994, 4.5% average annual reductions after 1995, then 3.7%
>>annually after 1997.  Forecasts beyond 2000 are not included in
>>the plan.

     Staff believes the forecasted emission reductions represent
     the maximum achievable rate of progress in the Bay Area,
given the specific facts and circumstances facing the District.
These are described in further detail in the following
sections.

	  RECOMMENDATIONS:  Approve the District's emission
	  accounting as consistent with state regulations.
	  Approve the lesser rates of annual emission reductions
	  portrayed in the District's plan as the maximum
	  reductions possible and, as discussed in the next two
	  sections, as reflecting the expeditious adoption of
	  all feasible measures for the Bay Area.

	  2.    All Feasible Measurer

     As a district unable to achieve 5% annual emission
     reductions, the Bay Area AQMD must demonstrate to ARB's
satisfaction that it has included every feasible measure in its
1991 air quality plan (40914(b)(2) and 41503.1).  The District
asserts that it has.

     The term "feasible" is not defined in the California Clean
     Air Act.  However, related environmental statutes offer
useful definitions and substantial precedent.  The most relevant
of these are the Guidelines issued

to implement the California Environmental Quality Act (CEQA),
which  define "feasible" as incapable of being accomplished in a
successful manner within  a reasonable period of time, taking
into account economic,  environmental, legal, social, and
technological factors" (14 CCR,  Section  15364).  Three aspects
of this definition bear emphasis: the results  orientation,
the  time parameter, and the consideration of social factors
(among  several  others).

     Staff have encouraged all districts to give close
     consideration  to demonstrably achievable measures:  the
bread and butter regulations that have been successfully adopted
and implemented in  California.  Last  March, staff provided a
list of stationary and area emission source  categories  for
which regulations were clearly available and effective. The
staff  list  of feasible controls is by no means absolute.
Rather, it  represents  a  starting point for each district's
analysis. Other measures may  exist  today  which are also
feasible. New measures will undoubtedly be added over  time  as
districts' regulatory programs move forward.

     The District's plan covers all the listed stationary and
     area  source categories which exist in the San Francisco
Bay Area.  Current  District regulations, plus the proposed
measures in the plan, ensure that all  of  the identified
categories will be controlled. The District  has  15  additional
measures for stationary and area sources in its plan, which it
considers  to be feasible and necessary for the Bay Area.

     Staff's guidance to districts on transportation
     strategie5.was  to  focus on reasonably available TCMS.  As
discussed above, these are the most effective measures currently
available and will take a number of  years  to successfully
implement. Six broad control  categories  were  identified.
Three of these were regulatory in nature:  employer-based trip
reduction rules; management of parking supply and prices; and
>>trip reduction  rules  for other sources. The other three
>>measures affect  the  overall  transportation system: plans for
>>high occupancy vehicle  lanes;  comprehensive  transit plans;
>>and land use policies.

     The Bay Area plan addresses all of the identified
     transportation control categories. Though staff have
concerns with a number  of  the  TCMs (as detailed above and in
Appendix B), staff believe the scope of  the  plan is sufficient
to satisfy the Act's feasibility requirements.  Where  TCMs  are
deficient, it is for lack of specificity or
enforceability--not  scope.

     The time horizon for gauging feasibility is a  decisive
     factor.  Since the Act calls for plan revisions every third
year after  approval  (40925), staff believes the most
appropriate horizon is the current  planning  cycle.  Thus, what
has and can be accomplished between 1987 and 1994 is the
operative question. The District's intentions for  future
planning  cycles are instructive and revealing, but should not
form the basis for an "all feasible measures" determination
since the plan will inevitably  be  revised.

     Staff interprets "accomplish" to mean adopt or  otherwise
     initiate emission controls. This is because the full
effectiveness  of  many  measures will not be realized
immediately. For  example:  industrial  source  retrofits

take between two and five years, on average, to  fully
implement;  new  car standards require a turn-over in the
vehicle fleet to achieve maximum reductions.

     The Bay Area AQMD is proposing to adopt 26  stationary
     and  area  source measures, one mobile source measure, and
4  transportation  control  measures by the end of 1994. Initial
and/or  supporting  action  on  23  other  multi-part measures
will be undertaken in the same period (funding and legislative
authority permitting, for some of the latter).

     As mentioned previously, districts unable  to  achieve  5%
     annual  emission reductions must satisfy two tests:  all
feasible measures and expeditious adoption.  If the current
planning cycle is viewed as controlling, the question becomes:
'what pace of  rulemaking  activity  is  "expeditious"  in this
timeframe?" Staff believes  the  determination  of  expeditious
progress is fact-driven and district-specific. Staff  further
believes  that  the  Bay Area plan satisfies the expeditious
adoption  test.  The  rationale  for  this viewpoint is
described below.

     The need to consider social factors  adds  weight  to
     local  circumstances.  Communities differ and may respond
differently to proposed measures.  The composition of a
particular industry's  workforce  can  produce  special  issues,
as the impacts of proposed controls  are  being  considered.
Being  different is not automatic grounds for rejecting measures
which are commonly, and successfully, applied elsewhere. It is
a  legitimate  factor  to  consider, however, in the context of
what is feasible and how quickly it can be achieved.

     Staff believes the District plan sets forth  an  honest
     appraisal  of  what can be accomplished in the near term
given the particular setting, history, infrastructure,
constituency groups, and popular concerns in the San Francisco
Bay Area.

	  RECOMMENDATION:  Find that the District plan includes
	  'all feasible control measures' within the meaning of
	  the Act, and in consideration of the factors
	  affecting  the  selection  of  control measures within
	  the Bay Area.

	  3.     Expeditious Progress/Expeditious Adoption

     The Act generally requires expeditious progress toward
     attainment (40910).  Where districts are unable to achieve
5% annual emission reductions, the Act also requires
"expeditious  adoption"  of  all  feasible measures (40914(b)
>>and 41503.1).  Staff has construed this to mean a steady pace of
>>rulemaking taking into consideration the difficulty, novelty,
>>and controversy associated with  each  regulation;  procedural
>>requirements  imposed by statute for the adoption of
regulations  (including  due  process  and  review of
environmental and socioeconomic impacts); competing mandates
(e.g., toxic air contaminant controls which must be  locally
adopted  within  6  months of ARB approval); and district
resources.

     What is expeditious varies by district, based on its
     particular circumstances. The Bay Area AQMD is proposing to
adopt 36  stationary  and area source measures between 1991 and
the end of 1994, about nine per year.  This represents a
doubling of regulatory activity over the last four years, when
four to five measures per year was standard. Twelve of these
measures are brand new rules, which typically involve more work
than revisions  to existing rules.  Two measures involve the
reduction or elimination of exemptions, which tends to fall
hardest on small businesses and provoke significant
controversy.

     In the same timeframe, the District is proposing to act as
     lead on four transportation strategies, to assume a primary
role for three  additional TCM's, and to offer support for six
of the remaining measures. All  of  the former represent
'cutting edge" work. Few models are available to  emulate, and
those that are available are going through shake-down processes
of their own.

>>     Many of the individual measures in the District's 1991 plan
>>     will require considerable resources to develop.
>>Transportation strategies, inclusive of indirect source review
>>and employer-based trip reduction,  are extremely controversial
>>in the Bay Area. Creating a program that  is  both effective and
>>minimally acceptable to the agencies, businesses and individuals
>>that must carry it out is a great challenge.  The  market-based
>>strategies require new statutory authority which will take
>>extensive lobbying, negotiations, and coordination to secure.
>>The proposed NOx controls for utility boilers present different
>>difficulties owing to  the complexity of powerplants, the need
>>to coordinate equipment replacement with Monterey Bay Unified
>>and San Luis Obispo County (who are also proposing  to regulate
>>PG&E), and the high cost of the retrofit technologies.
>>
     Though not unique to the Bay Area, procedural requirements
     are a critical part of the expeditious calculation. In
addition to  due  process requirements (40725-40728), new
legislation has imposed further time- consuming procedural
steps.  Beginning this year, districts with a population of
500,000 or more are required to perform a socioeconomic analysis
on each regulation prior to adoption (AB 2061, Polanco;  Chapter
794, Statutes of 1991). This clearly applies to the  Bay  Area.
Districts' responsibilities for environmental review has
gradually expanded over  the past ten years, as air quality
regulations have raised energy, water, hazardous waste disposal,
hazardous material transport, and land-use concerns.  It is no
longer uncommon to see a full environmental impact report on an
individual rule.  Staff expects the trend toward broader, more
time consuming review to continue.

>>     A significant political and practical issue facing all
>>     districts  this year is the depth and persistence of
>>California's economic downturn.  Though signs of recovery are
>>beginning to emerge, the worst effects are still with us and
>>many expect the pace of recovery to be slow. Districts have  to
>>be unusually sensitive during this period, and to consider
>>special  compliance schedules or other options to mitigate
>>economic impacts. Costs  that  were absorbable in the past
>>decade may be temporarily less so, in certain

industries or by certain firms.  Responding  to  these  issues
as  they  arise will take additional time and creativity.

	  RECOMENDATION:  Approve  the  Bay  Area's  proposed
	  schedule  for rulemaking and related  activities  as
	  oexpeditiouso  within  the meaning of the California
	  Clean Air Act and given the particular circumstances
	  facing the Bay Area District.

	  4.     Cost-Effectiveness Ranking and Determination

     The California Clean Air Act requires  districts  to
     assess  the  cost- effectiveness of proposed control
measures.  Each  plan  must  include  a  list that ranks
measures from the least  to  the  most  cost-effective
(40922).  In addition, each district board must certify that its
plan is a cost-effective strategy for attaining state air
quality standards, prior to adoption (40913(b)).

     The Bay Area AQMD has  complied  with  the
     cost-effectiveness  ranking mandate to the extent possible.
Sixty-seven  of  the  plan's  90  proposed controls are ranked
in Volume 1 (tables 7a and 7b, page 26).  For the remaining 23
measures, there is insufficient information to complete a cost-
effectiveness assessment. -

>>     Staff believes this partial ranking is  adequate  to
>>     satisfy  state  law.  Cost estimates at the planning stage
>>are  often  preliminary  and  incomplete.  Unless another
>>district has adopted an  identical  rule,  plan  preparers  must
>>rely on their experience with comparable  rules,  vendor
>>literature,  and various studies.  In some cases, cost data
>>simply does not exist.  In others, no method has been developed
>>for  quantifying  emission  impacts.

     It is important to emphasize this is merely the first
     step.  As individual rules are taken up for development,
detailed  data  are  gathered and more specific
cost-effectiveness analyses are performed.  This ensures a
continuing emphasis on regulatory efficiency, as intended by the
Act.

     The Bay Area has also made the required cost-effectiveness
determination. On October 30, 1991,  the  District  Board
certified  that  the plan is a cost-effective strategy for
attaining  state  standards  by  the earliest practicable date
in Resolution 2050.

	  RECOMMENDATION: Find the District  plan  in
	  compliance  with  the cost-effectiveness
	  requirements.

	  5.    ixansport Mitigation

     The Act requires district plans to  include  any
     transport  mitigation requirements established by the Board
(40912).  In December 1989, ARB identified the Bay Area AQMD as
the source of  transport  into  Monterey  Bay Unified air
district, the San Joaquin Valley,  and  the  Broader  Sacramento
Area.  In August 1990, the Board adopted mitigation regulations
which require certain permitting and retrofit actions  (17
CCR,  Section  70600).

     Specifically, the District was required to adopt and
     implement a no  net increase permitting rule by July 1,
1991. In addition,  the  District  must adopt rules representing
BARCT for stationary sources that comprise 75%  of the 1987
inventories for hydrocarbons and NOx. The BARCT  requirement
must be met by January 1, 1994.

     The plan demonstrates compliance with both requirements.
     As noted above, a no net increase permitting rule was
adopted and implemented on July 17, 1991. For BARCT, the
District may be halfway there  already.  Over  the past several
years, Bay Area regulations have been  focused  on  stationary
sources of hydrocarbons. Consequently, the District believes
that  most  of its existing hydrocarbon rules represent BARCT.
Sources  covered  by  these rules represent 85 percent of the
stationary source inventory. The  District intends to revisit
these rules prior to 1994 to ensure that they do in fact achieve
the degree of control that currently represents BARCT.

     For NOx emissions, the District has proposed new retrofit
     control measures to meet BARCT requirements. These rules
will cover such sources  as reciprocating engines, stationary
gas turbines, electric  power  generating boilers, large
boilers, steam generators, process heaters, and  residential
water heaters. These and other sources amount to 83  percent
of  the  1987 point source inventory. Therefore, adoption of the
new NOx control  measures will comply with the transport
mitigation regulation provided the  District adopts the level of
control representing BARCT at the time  of  rulemaking, which it
has committed to do.

	  RECOMMENDATION:  Find the District in compliance with
	  the transport mitigation requirements.

	  6.    Population Exposure

     Long term nonattainment areas for ozone must address
     population exposure in their plans.  Specifically, each
severe area must include sufficient measures to reduce overall
population exposure 25%, 40% and  50% by 1994, 1997 and 2000,
respectively (40920(a)(4)). The baseline  for  this analysis is
the average level of exposure  experienced  between  1986-1988.

     The District performed a preliminary modeling study to
     assess the change in exposure over time.  Using a
combination of conservative and simplifying assumptions, Bay
Area concluded that the plan would satisfy  or exceed the Act's
requirements. The predicted exposure  reduction  for  1994
ranged from 49-81%, and ranged from 64-94% for the 1997
milestone date.

     ARB staff believes that the method used by  the  District
     to  estimate population exposure is acceptable.  Staff is
also confident that the analysis is qualitatively correct.
However,  the  underlying  photochemical model is not as
reliable as it needs to be to draw firm, numerical conclusions.
Substituting actual data for some of the  assumptions  in  the
analysis would also be highly desirable.

     The District is working diligently to improve modeling
     performance prior to the next plan revision. The District
has also  committed  to revisiting its population exposure
analysis, and intends to incorporate daytime population
patterns, more modeling results and more refined indoor/outdoor
exposure patterns at that time.

	  RECOMMENDATION:  Approve the population exposure
	  analysis as the best information currently available.
	  Recommend  that  the District revisit this analysis in
	  the next update to the plan.

	  7.    Intrabasin Uniformity

     The Act requires that control measures for the same
     emission sources  be uniform throughout the affected air
basin to the maximum extent  feasible (41503(b)).  In the case
of the Bay Area AQMD, district boundaries are coterminous with
the entire air basin. Hence, uniformity is generally  not  a
problem for stationary and area source control measures.

     The uniformity requirement may provoke issues when the
     District delegates responsibility for TCM implementation to
local agencies.  As this is done, the District may need to take
steps to ensure that local agencies are implementing the
measures consistently.

     The District proposes to create model ordinances for the
     proposed employer-based trip reduction and indirect source
review measures.  As currently conceived, delegees will need to
meet certain standards  of performance but will have discretion
in selecting the compliance  method.  Staff believes this
approach is consistent with the Act's  uniformity requirement.

	  RECOMMENDATION: Find the plan in conformance with
	  the  uniformity requirement. Direct the District to
	  monitor the  effectiveness  of delegated measures in
	  achieving a uniform degree of  emissions control.

	  8.    Public Education

     The Act requires that all district plans include provisions
     for public education programs to promote actions which
reduce emissions from transportation and area sources (40918).
As noted above, the Bay Area  has  a unique citizen advisory
program designed to curb discretionary, air polluting activities
during smog episodes.  Its inauguration in 1991 drew substantial
press coverage and a discernible, positive response from local
residents.

     The Bay Area also has a public relations campaign to teach
     people  about single occupancy vehicles' impacts, and to
direct them towards transportation alternatives.  The campaign
was started last year; the District is currently seeking funds
to continue it on a long term  basis.

	  RECOMMENDATION: Find that the District plan  includes
	  provisions for public education.

	  9.    Contingency Measures

     The Act requires that contingency measures be included in
     each district's plan (40915). These are to be implemented
upon a finding,  by  the ARB, that the district is failing to
achieve interim goals or to  maintain adequate progress toward
attainment (41503.3).

     As noted above, the Bay Area AQMD is proposing to adopt
     all  feasible measures on an expeditious schedule.
Contingency measures are very difficult to define in this
context since additional measures are, by definition, infeasible
during the current planning cycle.

     In lieu of a list of contingency measures, the District is
     proposing  a contingency procedure. To wit: when a plan
measure cannot  be  adopted  or implemented (for whatever
reason), the District will do everything  possible to accelerate
the adoption and implementation of subsequent rules.  The annual
progress reports will detail all efforts made in this regard.

     Staff believes a procedural approach is appropriate for
     districts facing the all feasible measures/expeditious
adoption test.  However,  the generality of the District's
proposal leaves much to be desired.  At a minimum, an early
warning system should be in place so the Bay ' Area will have a
genuine opportunity to accelerate the adoption of other
(measures.

     The District has also corrrnitted to an ongoing
     re-prioritization process. Should measures not in the plan
be identified as  feasible,  capable of achieving significant
reductions, and more cost-effective than measures already in the
plan, they will be added to the District's annual  rulemaking
calendar with a priority that reflects their superiority (or
inferiority)  to measures awaiting adoption.

     Staff strongly supports the ongoing assessment of
     priorities and  the addition of new, feasible measures to
district plans. The Board may  wish  to caution the Bay Area,
though, that revised schedules which delay or  suspend existing
commitments need to be handled as plan revisions and submitted
to ARB for approval.

	  RECOMMENDATION: Conceptually approve the procedural
	  approach  to contingency measures in the Bay Area
	  plan; seek further detail  as to how it will be
	  effectively implemented.  Clarify the conditions under
	  which plan revisions are necessary.

	  10.   Environmental Review

     The California Environmental Quality Act (CEQA) requires
     that each project be assessed for potential significant
effects on the  environment.  This mandate applies to air
quality plans. The Bay Area AQMD,  like  several

other urban districts, opted to prepare a full environmental
impact  report (EIR) on its 1991 plan.  (Some districts,
particularly rural districts with straightforward and limited
control plans, elected to issue  negative declarations or
mitigated negative declarations, instead.)  The final EIR was
certified by the District Board on October 30, 1991.  Further
environmental documentation will be prepared during the adoption
process for individual rules and regulations, as necessary.

	  RECOMMENDATION: Find that the District has met  its
	  obligations under CEQA.

III.      ENVIRONMENTAL IMPACTS

	  The ARB's role in evaluating the environmental impact
	  of air quality
plans is limited.  Under CEQA, districts act as the lead
agencies for preparation of environmental documents.  The ARB is
thus a responsible agency, and, in that capacity, reviews the
environmental documents prepared by the districts and makes
appropriate findings as required by the Public Resources Code
sections 21081 and 21081.6, where applicable.

     Staff have reviewed the EIR for the Bay Area 1991 Clean Air
     Plan and find that it accurately describes the potential
environmental impacts of the plan.  Staff concurs with the
District's findings.

IV.   PUBLIC COMMENTS

     A.    Directed to the District

>>     Public participation in District plan development,
>>     refinement and adoption was extensive.  Last Spring, the
>>District held eight public workshops which were attended by
>>approximately 300 persons.  A total of 53 people testified at
>>the first hearing on the draft plan in July 1991.  Prior to
>>final adoption, the District received and responded to 224
>>comment letters.

     At the final hearing on the plan, testimony was presented
     by 54 speakers.  The overwhelming majority of commentators
expressed support, though often wanting parts of the plan
strengthened. Several speakers  also expressed the hope that
>>there would be flexibility in how measures were implemented.
>>
>>     Many witnesses expressed concern about TCMS.  Caltrans
>>     objected to highways being deemed an indirect source,
>>indicating that current air quality assessment procedures make
>>this redundant.  The Building Industry Association argued that
>>residential projects should not be considered an indirect
>>source, either, since they respond to growth pressures rather
>>than create them. The Bay Area Industrial Park Association
>>requested  that indirect source measures be withdrawn from
>>consideration entirely.

     Several employers and employer groups were concerned about
     TCM 2, the employer-based trip reduction control measure.
The National Association  of

Industrial Office Parks sought  an  exemption  for  office
complexes.  Other representatives wanted maximum employer
flexibility  (e.g.,  the  Business  Air Quality Policy
Committee).

>>     Considerable support was expressed for market-based control
>>     measures by both environmental  and  business
>>organizations.  However,  the  organization 'People of Color for
>>the Environment" urged  that  the  plan  be  rejected because
>>the pricing measures were  financially  regressive,  and
>>because  the impact of other measures on minorities and
>>low-income  groups  had  not  been sufficiently analyzed.
>>
>>     The second major area of concern was  whether  the  plan
>>     satisfies  the Act's performance standards. The  Sierra
>>Club  Legal  Defense  Fund  urged rejection on the basis that
>>all  feasible  measures  were  not  included.  The American Lung
>>Association urged the Bay  Area  board  to  include  additional
>>strategies in order to achieve the five percent annual emissions
>>reduction target.

     B.    Directed to the Air Resources Board

>>     Prior to release of this report,  staff  received  oral
>>     and  written comments from several  environmental  groups
>>including:  the  Coalition  for Clean Air, Natural Resources
>>Defense Council, Citizens for a Better Environment (CBE), and
>>the Sierra Club's Legal Defense Fund and San Francisco Bay
>>Chapter.
>>
>>     These groups are uniformly concerned with  the  quality
>>     of  TCMs  in district plans, particularly those of the Bay
>>Area  and  South  Coast  AQMDS.  Noting that the motor  vehicle
>>inventory  is  substantially  underestimated, these groups argue
>>that transportation  measures  should  receive  the  greatest
>>attention and priority.  These groups find many of the proposed
>>TCMs to be overly general and potentially unenforceable,  and
>>believe  this  is  grounds for finding district plans deficient
>>under  the  "all  feasible  measures"  test of the Act.
>>
>>     The interpretation of feasibility advanced  by  these
>>     groups  is  an objective standard, applicable to  all
>>districts  in  all  circumstances.  They would start from a
>>larger list,  incorporating  any  air  quality  measure
>>proposed, adopted or implemented by anyone, anywhere in the
>>world.  All such measures would be presumptively feasible, and
>>districts would bear a heavy burden of proof for excluding them
>>from  their  plans.  As  stated  in  the preceding chapter,
>>staff's list of feasible measures is both preliminary and
>>open-ended so more controls can, and inevitably  will,  be
>>added  over  time.  There is a fundamental difference between a
>>universal presumption and a case-specific determination,
>>however.  Staff  recommends  that  the  Board endorse the
>>latter.

     These groups' interpretation of feasibility is  not  bound
     to  the  time horizon of the current planning  cycle.
These  groups  appreciate  that  not every measure can be
adopted before 1994  (though  they  have  a  different opinion
about where the dividing line  is).  However,  they  see  value
in

placing longer term measures in the plan--i.e., ntier 2" and
'tier 3"--so that districts are thinking ahead, and so that
debate over the next plan revision is appropriately shaped.
Staff's position is not directly in conflict with this goal.  It
is not necessary to fail the 1991 plans to get districts to
think past 1994.  Virtually all of the transportation strategies
are geared to the middle-to-long term.  Furthermore, ARB's
emission accounting regulations require at least a preliminary
analysis through the year 2000, so districts, industry,
environmental groups, and the public know what lies ahead.

Staff will report and respond to additional comments on the Bay
Area plan at the April 30, 1992, hearing.

V.   SUMKARY OF STAFF RECOMMENDATIONS

1.   Approve the emission inventory elements of the Bay Area
plan.

2.   Approve the carbon monoxide attairunent projection.  Defer
action on the
     ozone attainment demonstration until sufficient data area
     available to support a photochemical modeling analysis.

3.   Approve the severe area classification for the Bay Area
District.

4.   Find the District in compliance with the ano net increase'
requirement
     for new and modified permitted stationary sources.

5.   Approve the BARCT proposals.

6.   Find that the plan contains provisions to develop an area
source
     control program.

7.   Find that the District plan contains provisions to develop
an indirect
     source control program.

S.   Approve the smoking vehicle ccxnplaint program. Direct ARB
staff  to
     continue working with districts on fleet rules, with the
     objective of resolving implementation issues prior to the
     next planning cycle.

9.   Find that the plan addresses all reasonably available TCMS,
but  that
     further definition is needed for some measures. Approve
     those  TCMs identified in Table 1 that fully comply with
     the Act's  requirements.  Conditionally approve those TCMs
     where further actions are needed  to comply with the Act,
     upon receipt of a commitment from the responsible agency
     (primarily the District or MTC) to adequately define the
     measures on an expeditious schedule. It is envisioned that
     most  of these improvements will be commitments to near
     term actions (in  the next 6-12 months).  However, a few
     may esquire longer timelines.

Note: At the time this staff report was re7eased, staff  was
meeting  with District and MTC representatives to determine if
an acceptable schedule to upgrade the incomp7ete TCMs could be
devised by the hearing date.  If agreement is reached, the staff
will recommend the consensus schedule to the Board as part of
its action on the Bay Area p7an.

     Find that the plan satisfies the requirement for a
     substantial reduction in the growth rate for trips and trip
     length.  Also find that the plan satisfies the requirement
     for no net vehicle emission increases after 1997.

     Find that the plan does not currently satisfy the 1.5 AVO
     requirement, and recognize that a significant amount of
     time will be needed to either develop additional TCMs or to
     obtain the needed authority  and commitments for pricing
     measures that are essential to achieving a 1.5 AVO by the
     year 2000.

10.  Endorse the investigation of intermittent control
strategies in the Bay
     Area plan.  Withhold approval of specific emission
     reduction claims pending receipt of an acceptable
     demonstration of their effectiveness.

11.  Approve the District's emission accounting as consistent
with state
     regulations.  Approve the lesser rates of annual emission
     reductions portrayed in the District's plan as the maximum
     reductions possible, and as reflecting the expeditious
     adoption of all feasible measures for the Bay Area.

12.  Find that the District plan includes all feasible measures
within the
     meaning of the Act, and in consideration of the factors
     affecting the selection of control measures within the Bay
     Area.

13.  Approve the Bay Area's proposed schedule for rulernaking
and related
     activities as nexpeditiousa within the meaning of the
     California Clean Air Act and given the particular
     circumstances facing the Bay Area District.

14.  Find the District plan in compliance with the
cost-effectiveness
     requirements.

15.  Find the District in compliance with the transport
mitigation
     requirements.

16.  Approve the population exposure analysis as the best
information
     currently available.  Recommend that the District revisit
     this analysis in the next update to the plan.

17.  Find the plan in conformance with the uniformity
requirement  for
     regional pollutants.  Direct the District to monitor the
     effectiveness of delegated measures in achieving a uniform
     degree of  emissions control.

18.  Find that the District plan includes provisions for public
education.

20.  Conceptually approve the procedural approach to contingency
measures in
     the Bay Area plan; seek further detail as to how it will be
     effectively implemented.  Clarify the conditions under
     which plan revisions are necessary.

21.   Find that the District has met its obligations under
CEQA.

		 Appendix A



	    PLAN REVIEW PROTOCOL



Onoer Lhe California Clean Air Act, the Air Resources Board  is
responsible for reviewing and approving all district plans.  The
Act requires that the ARB and districts develop a  "uniform
conflict resolution procedure" before any district submits a
plan for attainment of state standards.  ARB is considering the
appropriateness of regulation to implement the procedure.
Applicable sections of the Act are attached for reference.

It is ARB's intention to address and resolve differences as
early in the planning process as possible. The Board will
strive  to provide clear guidance and communicate its
expectations prior  to local adoption of plans. The protocol
below  includes  several steps prior to formal conflict
resolution to achieve that o b j e c t i v e .


 Review of Draft Plans

1.   Draft plans prepared by districts will be submitted to  the
     ARB's Office of Air Quality Planning and Liais'o'h (OAQPL)
     as soon as available, but no less than 30 days before the
     local hearing date.

2.   OAQPL and Division staff will communicate comments to  the
     district by telephone, followed by written comments prior
     to local plan adoption.


 Review of Final Plans

     Districts will submit final plans to OAQPL as soon as
     possible after local adoption.

2.   ARB will evaluate the final plans for compliance with  all
     applicable requirements.

3.   ARB will prepare a notice indicating intent to approve  or
     disapprove the plan (or portions thereof). ARB  will
     provide its staff report and recommendations on each plan
     to the affected district(s), as soon as available but no
     less than 30 days before the Board hearing.


 Board Action

1.   All actions of the ARB to approve, revise and approve,  or
     disapprove district attainment plans will be taken at a
     noticed public hearing.

2.   The Board will approve a@cedtable plan portions by
     resolution.

3.   The Board will identify plan deficiencies by resolution
     and transmit those findings to the district.  Concurrently,
     the Board will notice its intent to amend the plan within
     90 days, if deficiencies are not corrected.

4.   The district shall correct the deficiencies identified by
the
     Board and submit its revised plan for approval.  The
     district may request initiation of Conflict-Resolution
     procedures in lieu of revising its plan, if it does not
     concur with the Board's findings.


 Conflict-Resolution

1.   Upon district request, the Board will designate a conflict-
     resolution committee.

2.' The committee shall consist of representatives of the
affected district and ARB, and may include other parties (e.g.,
COG'S, transportation agencies) upon mutual consent.

3.   The committee will meet and confer within 30 days of the
     Board's finding of deficiencies and shall report its
     conclusions back to the Board within 60 days.

4.   The Board will give substantial consideration to consensus
     recommendations of the conflict resolution committee in
     determining whether a second opportunity to amend the plan
     locally should be provided and, if not, what modifications
     should be made by the Board.

		 Attachment

     APPLICABLE SECTIONS OF THE CALIFORNIA CLEAN AIR ACT



41503.2   (a) If the state board concludes that a district's
	       plan  does  not  meet  the  requirements  of
	       Section 41503, the state board shall notify the
	       dstr7cl' of all deficiencies in writing.  The
	       dis.,-Ict shall correct the
	       deficiencies.......                     and
	       shall submit its revised plan to the state board
	       for approval.

	  (b)  If the district does not concur....... or the
	       state board determines that the district's plan
	       revisions are inadequate....... the state board
	       and the district shall attempt to resolve the
	       differences  within  three  months  of   the
	       board's disapproval.  The state board and the
	       districts shall develop a uniform conflict
	       resolution procedure....... prior to any
	       district's submittal of its attainment plan to
	       the state board.

	  (c)  If  a  conflict  between  the  state  board
	  and   district
	       cannot  be  resolved,  the  state  board  shall
	       take   all of the following actions:

	       (1)                    conduct a public hearing
	       in the air basin (2).......
	       provide 45-day written notice.......  (3)  . . .
	       revise the district's plan as 7t finds
		    and determines necessary.


-'?1503.4   All actions of the state board to approve, revise
ana
	  approve, or disapprove a district's attainment plan or
	  plan revision shall be taken at a noticed public h e a
	  r i n g .


41503.5   The  state  board  shall  ensure  that  a  district's
plan   and
	  plan revisions meet the requirements -of th7s part and
	  of Part 3 (commencing with Section 40000), and that
	  every reasonable action is taken to achieve the state
	  ambient air quality standards....... by the earliest
	  practicable date.

	  Flow Chart for Plan Approval



	       local adoption


		     ir                acceptable Board hearinc

		  deflclent





d i s t r I c t                             district
concurs                                     does not concur




local plan revision           onflict-resolution

		    90 I days


		     -T
	   Board hearing to amend ti-ie Piat-i, as t)ecessary

		 APPENDIX B
  1991 BAY AREA AIR QUALITY ATTAINMENT PLAN ARB ANALYSIS OF
TRANSPORTATION CONTROL MEASURES
	 Volumes I & II (Appendix F)

INTRODUCTION

     The Bay Area '91 Clean Air Plan (CAP) includes 23
     transportation control measures (TCMs).  This set of
measures was developed by the Metropolitan Transportation
Commission (MTC) and adopted with some modifications by the Bay
Area Air Quality Management District.  The plan as revised has
not been adopted by MTC or the Association of Bay Area
Governments (ABAG).

     Two of the TCMs are scheduled for District adoption as new
     rules: TCM  2 (Employer-based Trip Reduction) and TCM 16
(Indirect Source  Review).  The other TCMs are to be implemented
by other agencies.

     Implementation of the adopted TCM program is divided into
     two phases.  In general, Phase 1 measures are described
with more specific detail,  and include milestones, completion
dates and funding commitments.  Some  measures lack information
on project scope, baseline data, key assumptions, analysis
methods and effects on travel.

     Phase II measures are less specific.  They generally
     describe the goals, target group, estimated costs and
emission reductions of  measures.  Potential implementing
actions by lead agencies are discussed, but there  are no
commitments for funding, timelines or milestones for
monitoring.  The project scope is incomplete, and the background
data is often limited.

     Pursuant to state law, district plans must evidence a
     substantial degree of specificity and commitment to
implementation for all  reasonably available measures.  In
essence:  AM is going to do @     by @.  For complex or
multiyear projects, intermediate milestones for the planning
cycle are also needed. Commitment is shown for TCMs 2 and 16
by  District adoption of this plan and District authority to
implement these two measures. Commitment to implement the
remaining measures is less  clear,  and varies by measure.

     In order to evaluate effectiveness of the plan as well as
     the individual TCMS, travel characteristics of the current
transportation  system as well as the individual TCMs should be
identified.  For transportation control measures, such
indicators include the quantity of trips, vehicle miles
traveled, location and duration of congestion, average vehicle
occupancy during commute hours and the transportation system
infrastructure.  Forecasts of changes expected in each factor
over time are needed to successfully track the implementation of
the measures.   Much of this information cannot be found in the
plan.

     Staff does not believe that the transportation control
     measures  portion of the plan, as described in Appendices B
and F, are adequate at this time to meet all of the requirements
of the California Clean Air Act, and cannot

be unconditionally approved by the Air ROsources Board.  Needed
additional information to be supplied for each measure, as well
aS the transportation system, is identified in the following
section.



TRANSPORTATION CONTROL MEASURES

     Descriptions of the transportation control measures in the
     Plan are included in Volume II (Appendix F).  Volume II
describes how the TCM plan was developed, linkages among the 23
measures, and information on each TCM regarding purpose,
background, scope, travel market, costs, impacts, implementation
and impediments to the plan.

     The projected reductions in the baseline 1997 on-road
     vehicle  emissions for ROG, NOx and CO for Phases 1 and 2
are stated as a percentage reductions for each TCM.  A technical
report, Transportation Control Measures for the San Francisco
Bay Area: Analyses of Effectiveness and Costs (October 1991),
provided background information on modeling method, assumptions
and findings for the Plan.  The report, prepared by Greg Harvey
and Betty Deakin for the BAAQMD, (Harvey-Deakin report) is cited
as a reference in the ARB analysis.

     Additional information is included in Volume I.  Table 4:
     REDUCTION IN EMISSIONS AND VEHICLE TRAVEL FOR TCMs
suntnarizes the projected changes in the percentage and tons/day
of the criteria pollutant (RHC, NOx, CO) and the travel
indicators (vehicle trip, VMT). The pro,jected 1997 on-road
inventory includes:  137 tons/day (RHC), 222 tons/day (NOx) and
1939 tons/day (CO).

     Most TCM implementation plans are conceptual, and they do
     not contain enough specific information to be monitored.
Exceptions to this general evaluation are the two District rules
that are to be developed and adopted:  TCM #2 and TCM #16.
Commitments from participating agencies, including a scope of
work, timelines, milestones and budgets to achieve the expected
results need to be provided for most of the other measures.

     A shortfall of $500-$600 million dollars per year to
     implement the Phase 2 programs is identified in the Revenue
Measures summary of the TCM plan (page F-3).  This is a
substantial amount to be met by TCM #21. The Plan assumptions
that the TCM program will be implemented are not supported by
the existing revenues that have been identified to date.

     Recent passage of the Federal Intermodal Surface
     Transportation Efficiency Act (ISTEA) has provided new
flexibility in the use of revenues from the federal gas tax.
The combination of new federal, state and local revenues need to
be reexamined as funding sources for a revision of TCM #21.
Local government sales tax measures and congestion management
programs may also implement TCM activities.

     Preparation of multimodal planning guidelines and lists of
     "Jump Start" projects for early transportation programing
are opportunities to explore which TCMs may be funded with new
state and federal revenues.  ARB staff recommends that high
priority be given these unfunded Phase 2 projects in

these decisions.  Funding commitments should be reflected in the
upcoming state and regional Transportation Improvements Programs
(TIPs).

     Additional ARB staff corrrnents regarding the individual
     TCMs have been grouped in the following categories:

     o    Employer Based Trip Reduction o    Mobility
     Improvements o    Traffic Operations System (TOS) o    User
     Incentives o    Indirect Source Review o    Implementation
     Support o    Revenue Measures o    Pricing Measures o
     Intermittent Measures

Specific coarnents on these measures are as follows:

TCM #2    Employer-Based Trip Reduction Rule

     TCM #2 is projected reduce emissions by 3.57% (RHC), 3.67%
     (NOx) and 3.76% (CO) by the adoption of a BAAQMD rule that
would affect 75% of the workforce and require employers to
develop programs equivalent to $3.00 daily parking charges with
subsidies for ridesharing, transit and other alternatives to
solo commuting.

     Governmental administrative costs of $5 million per year
     may be met by employer fees.  Cities and counties that
develop equivalent trip reduction ordinances may be designated
to administer the plan.  It is proposed that the rule
development be integrated with the trip reduction/demand
management element of local congestion management programs.

     Clearly, TCM #2 is an ambitious measure, and staff believes
     that it will be be effective in reducing emissions.
However, additional information on the assumptions and methods
used in calculating impacts should be included in the plan to
document the projected effectiveness.

     The actual measure will be designed in the district's
     rulemaking process.  The plan does provide a clear
commitment by the district to implement TCM #2, an action for
which it has adequate authority.  Future funding is assured
because the District can levy fees necessary to implement the
program.

     ARB staff recommends that TCM #2 be fully approved, while
     concurrently recommending that additional information on
the projected changes in actual numbers of vehicle trips,
vehicle miles traveled (VMT) and emission reductions be provided
to supplement the percentage changes reported in the
Harvey-Deakin study (A-3, B-3, C-1, D-1).

	   140BILITY IMPROVEMENTS
TCM #3     Improve Areawide Transit Service

     TCM #3 is divided into funded (Phase 1) and unfunded (Phase
     2) actions.  Phase 1 includes continuation of
post-earthquake  BART  service  (FTCM  17b), extending Caltrain
to Gilroy and expanding service  from  54  to  66  tra' ins per
day (FTCM 19) and encouraging transit operators to do market
analyses and to convert bus fleets to  clean  fuel  vehicles.
Projected  emission  reductions from Phase 1 are: 0.46% (RHC &
NOx) and 0.44% (CO).

     Unfunded Phase 2 activities  are  projected  to  yield
     additional  emission reductions: 1.00% (RHC) and 0.90%
(NOx  &  CO).  Estimated  annual  costs  of expansion of rail
service ($100 million) and  bus  service  ($140  million)  do
not have identified revenue sources for the expanded measure.

     The cost estimates for Phase 2  include  both  the
     capital  costs  for rails and bus equipment and operating
shortfalls.  An increase of 33 percent in funding and ridership
capacity is  projected  in  the  Harvey  Deakin report (pages
A-3,4; B-3,4,5; C-1, D-1).

     TCM #3 is an ambitious measure, and  ARB  staff  believes
     that  it  could provide significant emission reductions.
However, additional information is needed to establish the
degree of emission  reduction  and  related  impacts  on
regional mode split, vehicle trips, VMT  and  vehicle
occupancy  that  are projected. Program activities in Phase 1
need  to  specify  the  lead  agency, budget, timetable,
milestones and  expected  effects  on  transit  operations.

     Preliminary ARB staff review  of  the  1992-2000  Short
     Range  Transit Plans for transit operators indicates  that
current  expansion  plans  for the regionwide bus fleet, after
deducting  planned  bus  replacements,  is less than one
percent. Therefore,  further  review  of  this  objective  is
needed, in light of the additional flexibility for  use  of
state  and  federal transportation funds that has been provided
in recent legislation.  The multimodal guidelines being
developed  should  address  transit  spending priorities.

     The Metropolitan Transportation Commission (MTC) support of
     transit expansion as a high priority for the  Regional
Transportation  Plan  (RTP)  is encouraging. We recommend that
the  transit  projects  included  in  the  State Transportation
Improvement Program be  identified  for  Phase  1  projects.
The long range RTP plans for bus and rail service should be
cited as Phase 2 assumptions.

>>     The ARB staff recommends  that  this  measure  be
>>     conditionally  approved, provided that MTC, county
>>congestion  management  agencies,  Caltrans  and regional
>>transit providers commit to an  expeditious  schedule  to
>>provide  the following data regarding Phase 2:
>>
>>0    Documentation regarding calculation of emission reduction
>>impacts, 0    Clear commitment by  participating  agencies  to
>>implement  the  measure, 0    Additional data needed to clarify
>>when the measure will be implemented, 0    Additional details
>>that  define  the  target  performance  goals,  and
>>
>>0    A funding program that is adequate to implement the
>>measure.

TCM  #5    Improve Access to Rail and Ferries

     Existing funding sources are expected to provide an
     unstated amount of support to improve access to rail and
ferries  in  connection  with  other  TCM activities and
projects. This Phase 1 of TCM  #5  is  projected  to  reduce
emissions by 0.02% (RHC, NOx) and 0.03% (CO).

     Phase 2 activities would include  timed-transfer  access
     to  mass  transit at an estimated total cost of $50 million
per  year  with  a  projected  emission reduction of: 0.30%
(RHC, NOx)  and  0.25%  (CO).  (See  Harvey-Deakin  report,
pages A-5, A-6, B-6, C-1, C-2, D-3.)

     ARB staff believes that this measure could help  increase
     the  modal shifts and therefore reduce emission reductions
from motor vehicles.  There is, however, the potential for the
'double-counting" of the emission reductions from access
improvements funded as  part  of  other  TCM  activities or
programs.  Additional information needs to be provided on the
assumptions, calculation methods and projected  impacts  on
emissions  and related travel indicators (e.g., regional vehicle
trips, VMT) to fully evaluate the proposed measure.

     Work efforts by various transportation  agencies  that
     could  contribute to the Phase 1 implementation are
identified  (page  F-19).  The  plan  does  not contain enough
specific information on what actually will be done so that the
measure can be monitored.  Additional  information  needs
to't;e  provided regarding the lead agencies, resource
commitments, timelines, milestones, and projected ridership
changes for both Phases 1 and 2.

     The ARB staff recommends that this  measure  be
     conditionally  approved, provided that MTC and all
identified service providers commit to an expeditious schedule
to provide:

0    Documentation regarding calculation of  emission
reduction  impacts, 0    Clear commitment by participating
agencies to implement the measure, 0    Additional data needed
to clarify when the  measure  will  be  implemented, 0
Additional details that define the target performance goals, and
0    A funding program that is adequate to implement the
measure.

TCM #6      Improve Intercity Rail Service

     TCM #6 is projected to reduce  emissions  by  0.05%  (RHC
     &  NOx)  and  0.04% (CO) in Phase I due to the initial
intercity rail service of three daily roundtrips in  the
Auburn-Sacramento-San  Jose  Corridor  (Federal  TCM  18).  The
funding for rolling stock (over $107.4 million) and operations
($7 million) were available.  The  ridership  in  early  1992
has  exceeded  expected  numbers.

     Daily service is projected to  expand  to  10  roundtrips
     by  1999/2000  with an additional emission reduction of
0.04% (RHC & NOx) and 0.03% (CO).  in Phase 2.  This goal was
based on the ARC 132 (Hannigan) Rail Corridor Upgrade Study.
Institutional agreements and additional funding will be needed
to  reach  this  goal.  The  additional  costs  were  not
identified.  (See pages A-6, B-6, C-2, D-4 of Harvey-Deakin
report.)

     ARB staff believes that  expansion  of  intercity  rail
     service  to  the  Bay Area could be effective in reducing
emissions.  Additional information on the assumptions and
methods used in calculating impacts on emissions and travel
indicators  affected  by  greater  rail  use  (e.g.  regional
mode  splits, vehicle trips, VMT,  vehicle  occupancy).  Given
the  initial  popularity  of  the service, the rate of ridership
growth and emission reductions may prove to be underestimated.

As a minimum, it seems possible that the Phase 2 emission
reductions are low, because they are not proportional to the
increases in daily train trips.

The plan does  not  contain  enough  specific  information  on
implementation steps so that the  measure  can  be  monitored.
Additional  information  needs  to

   be provided regarding the lead agencies, resource
   commitments, timelines, milestones, and projected ridership
   changes for both Phases 1 and 2.

   The ARB staff recommends that Phase 1 be approved and that
   Phase 2 of this measure be conditionally approved, provided
   that MTC, Caltrans, rail transit providers, and  any
   affected  congestion  management  agencies  commit  to an
   expeditious schedule to provide:

0  Documentation regarding calculation of emission reduction
impacts, 0  Clear commitment by participating agencies to
implement the measure, 0  Additional data needed to  clarify
when  the  measure  will  be  implemented, 0  Additional details
that define the target performance goals, and 0  A funding
program that is adequate to implement the measure.

TCM #7     Improve Ferry Service

     TCM #7 is a measure with two phases.  Phase 1 includes the
     funded projects to continue post-earthquake ferry service
between Oakland/Alameda and San Francisco Ferry (Federal TCM 17)
with an operating subsidy of $750,000, and $10 million is
available in the 1994-97 period  for  Wallejo ferry
improvements. The projected reductions in emissions from  Phase
1  are 0.02% (RHC) and 0.01% (NOx & CO).

     Phase 2 is projected to reduce emissions by another 0.03%
     (RHC & NOx) and 0.02% (CO). At an additional cost of $10
million per  year,  new  ferry service would be provided between
San Francisco and Berkeley/Richmond, and between the Oakland and
San Francisco airports.  Feeder bus service to ferries would be
included.  (See TCM #5)  Privately-operated ferries servicing
Port Sonoma and Harbor Bay Isle are also being  considered.
(See Harvey-Deakin report, pages A-6, A-7, B-7,  C-2,

     The implementation section provides  useful arrangements in
Phase 1. An increase  in  annual million person-trips per year
by the  mid-1990s, improvements, is cited from a MTC study for
the Ferry Service Plan.

D-4.)

detail on costs  and  funding ridership from 2.7  to  4.0 given
ferry service
 SB 2169 (Kopp)  Long  Range


     ARB staff believes that expansion of  ferry services could
     be  effective in reducing emissions. The plan does not
provide enough  information  on  the assumptions and methods
used in calculating impacts on emissions and regional travel
indicators affected by greater ferry use  (e.g.,  regional mode
splits, vehicle trips, VMT, vehicle occupancy), so  more
information needs to be provided.

     The ARB staff reconynends that Phase 1 of this measure be
     approved,  and that Phase 2 be conditionally approved
provided that MTC,  ferry  operators and any affected congestion
management agencies commit to  an  expeditious schedule to
provide:

0    Docunentation regarding calculation of emission reduction
impacts, 0    Commitment by participating agencies to implement
Phase  2  projects, 0    Additional data needed to clarify when
the measure will be implemented, 0    Additional details that
define the target performance goals, and 0    A funding program
that is adequate to implement the measure.

TCM #9    Construct Carpool/Express Buslanes on Freeways

     TCM #8 is a two-phase expansion of the existing
     80-lane-mile HOV lane system in the Bay Area.  Construction
of 220 directional HOV lane-miles (Federal TCM 20) is to be
financed from the $500 million in  funding  for  HOV projects
included in the 1988 State Transportation Improvement Program
(STIP).  This expansion is projected to reduce emissions by
0.23% (RHC), 0.22% (NOx), and 0.20% (CO).

     Phase 2 is projected to reduce emissions by 0.41% (RHC),
     0.40% (NOx) and 0.38% (CO) with the construction of another
190 HOV  lane-miles  that  are proposed in the 2005 HOV Lane
Master Plan. MTC is to  work  with  Caltrans  in the design and
funding of HOV facilities, study HOV  support  facility  needs,
and seek funding for additional express bus service in HOV lane
corridors.  The total costs, funding sources and work plans to
implement these Phase 2 projects are not stated in the plan.
(See Harvey-Deakin report, pages A-7, A-8, B-7, C-2, D-4.)

     ARB staff believes that expansion of the HOV facilities
     could be effective in reducing emissions.  HOV lanes can
provide time savings incentives to users that would enhance the
effectiveness of the  TCM  plan  as a whole.  However, ARB staff
questions whether all routes where HOV lanes would be feasible
strategies to reduce congestion and emissions have been included
in the existing masterplan.  For example, over half of the HOV
system is to be located in Santa Clara County.

     The August 1990 report to MTC, 2005 HOV Program
     Prioritization, outlined an action program that could
result in completing the remaining 190 lane-miles in the master
plan by 2005. ARB staff believes  that  each  of  the 16
unfunded HOV projects should be reviewed as recommended with
special attention to the following projects:

0    CC-80 between Willow and the Carquinez Bridge in Contra
Costa County

0    SCL-Capitol Expressway between Almaden and I-680  in
Santa  Clara  County

0    SCL-237 between Route 85 and U.S. 101 in Santa Clara County

0    SCL-Almaden Expressway between Haney Road and Ironwood in
Santa Clara
     County

0    CC-4 between Route 242 and Hillcrest in Contra Costa County

0    SON-101 between Marin County line and Washington in Sonoma
County

0    CC-680 between Route 4 and the Benecia Bridge in Contra
Costa County

0    ALA-92 from Clearwater to 1-880 in Alameda County

0    SCL/ALA-680 from Montague to Route 238 in Alameda County

0    SCL-87 from I-280 to US-101 in Santa Clara County

     In addition, ARB staff recommends that all
     capacity-increasing construction projects be evaluated as
possible additions to the 2005 HOV Lane Master Plan to provide a
more comprehensive HOV system.  Funding opportunities to
identify and construct  new HOV lanes in the system may now be
available under the provisions of new State and Federal
legislation regarding uses of gas tax revenues.  Revisions in
the criteria used in selecting priority projects for the 1992
STIP should be considered to meet the TCM implementation
schedules.

     The plan does not contain enough specific information on
     implementation steps so that the measure can be fully
monitored.  Additional information needs to be provided
regarding the lead agencies, resource commitments, timelines,
milestones, and projected changes in HOV use due to funded and
unfunded projects completion.

     The plan also fails to provide enough information on the
     assumptions and methods used in calculating impacts on
emissions and regional travel indicators affected by the
expanded HOV system (e.g. regional mode splits, vehicle trips,
VMT, vehicle occupancy), so more information needs to be
provided.

     The ARB staff recommends that this measure be conditionally
     approved, provided that MTC, Caltrans, and county
congestion management agencies 0    Documentation regarding
calculation of emission reduction impacts, 0    Commitment by
participating agencies to implement the measure, 0    Additional
data needed to clarify when the measure will be implemented,
0    Additional details that define the target performance
goals, and 0    A funding program that is adequate to implement
the measure.

TCM #9     Improve Bicycle Access and Facilities

>>     TCM #9 includes programs to encourage bicycle use for
>>     short  trips  of various types.  A target was added by the
>>District to the MTC-adopted measure that set the goal of
>>increasing the bicycle mode share during comute hours from 1.3%
>>in 1980 to 3.0% by 1997.

     The projected emission reduction for Phase 1 is 0.01% (RHC,
     NOx, CO), based on continued expenditure of $3 million per
year for bikeway projects in the region.  New guidelines are to
be drafted by MTC for local applications for these funds for
Fiscal Year 1993-94.

     Unfunded bicycle projects in Phase 2 are projected to
     reduce emissions by 0.02% (RHC & NOx) and 0.03% (CO) at an
estimated cost of $5 million per year.  Proposed funding sources
included new State revenues and coordination of plans with
Caltrans and transit operators to include provisions for
bicycles.  (See Volume II, and Harvey-Deakin report pages A-9,
A-16, B-7, B- 8, C-2, D-5.)

     Information is lacking on how the 3% goal for bicycle use
     is projected to affect future predictions of emission
reduction, VMT and vehicle trips.  A schedule and budget for
implementation by responsible agencies is needed.  Other sources
of revenue should be discussed as possible funding sources.

>>     The conceptual target for 3% peak period bicycle trips is
>>     ambitious, and ARB staff believes that increases in bicycle
>>use could be effective in reducing emissions.  The plan does not
>>provide enough information on the assumptions and methods used
>>in calculating impacts on emissions and regional travel
>>indicators affected by more bicycle use (e.g., regional mode
>>splits, vehicle trips, VMT), so more information needs to be
>>provided.

     The plan does not contain enough specific information on
     implementation

   steps so that the measure can be monitored.  Additional
   information needs to be provided regarding the lead agencies,
   resource commitments, timelines, milestones, and projected
   ridership changes for both Phases 1 and 2.

   The ARB staff recommends that Phase 1 of this measure be
   approved  and Phase 2 be conditionally approved, provided
   that MTC, Caltrans, and county congestion management agencies
   commit to an expeditious schedule to provide:

0  Documentation regarding calculation of emission reduction
impacts, 0  Commitment by participating agencies to implement
the measure, 0  Additional data needed to clarify when the
measure will be implemented, 0  Additional details that define
the target performance goals, and 0  A funding program that is
adequate to implement the measure.

TCM #10   Improve Youth Transportation

     TCM #10 is designed to reduce travel and emissions related
     to the transportation of children and youth. School trips
account for  an  estimated 2%-3% of weekday vehicle miles
traveled in the Bay Area.  Transportation of children and youth,
outside of school hours, is also addressed.

     TCM #10 is projected to reduce emissions by:  0.14% (RHC &
     NOx) and 0.16% (CO) at a cost of $11 million dollars
annually.  Projects to attain these reductions were placed in
Phase 2 because no funding was  identified.  Projects include:
$5 million for discount transit tickets, $5  million  for school
bus service and $1 million to promote ridesharing among
students.

     Information is lacking on how the measure is projected to
     affect  future predictions of mode split, vehicle trips,
VMT and average vehicle  occupancy.  A schedule and budget for
implementation by responsible agencies is needed.

     This is a modest supporting measure that ARB staff believes
     would help decrease the emissions from vehicle trips by
parents or youthful drivers  for transportation to school and
after-school activities due to more  schoolbus and public
transit ridership. There is, however, a potential  problem  with
the "double-counting" of emission reductions if these service
improvements are being funded as part of another TCM program or
activity. (See TCM  #13)

     Additional information needs to be provided on the
     assumpti4ns, calculation methods and projected impacts on
emissions and related travel indicators (e.g. regional mode
splits, vehicle trips, VMT, vehicle occupancy) to fully evaluate
the proposed measure.

     The plan does not contain information on specific proposals
     with an action plan that can be monitored. No funding
sources are  identified  beyond what may provided by new State
legislation.  Recent passage of State and Federal gas tax
legislation that allows more local discretion may provide a
source of funding for this measure.  Additional information
needs to be provided regarding the lead agencies, resource
commitments, timelines, milestones, and projected outcomes of
this measure.

     The ARB staff recommends that this measure be
     conditionally  approved, provided that MTC, District, RIDES
and transit providers commit to an expeditious schedule to
provide:

0    Documentation regarding calculation of emission reduction
impacts, 0    Comrritment by participating agencies to implement
the measure, 0    Additional data needed to clarify when the
measure will be  implemented, 0    Additional details that
define the target performance goals, and 0    A funding program
that is adequate to implement the measure.

	 TRAFFIC OPERATIONS SYSTEMS
TCM #11     Install Freeway Travel Operations System (TOS)

     TCM #11 will  reduce  congestion-related  emissions  by
     improving  the  flow of  traffic  on  regional  freeways.
Many  traffic  operational  improvements  are to be included in
Caltrans Traffic Operations System (TOS).

     Phase 1 implementation of the TOS  Segment  I  on
     freeways  near  the  Bay Bridge are predicted  to  reduce
emission  by:  0.42%  (RHC),  0.35%  (NOx)  and 0.65% (CO). The
cost, schedule  and  funding  source  for  Phase  I  (FTCM  26)
are stated.

     Phase 2 of the Caltrans TOS is  predicted  to  reduce
     emissions  by  1.40% (RHC), 1.10% (NOx) and 1.80%  (CO).
The  plan  notes  that  small  increases  in vehicle trips
(0.10%) and  VMT  (0.15%)  are  expected  from  the  fully
completed 216-mile TOS system when it  is  in  full  operation.
(See  pages  A-11,  A-12,  B- 10, B-11, C-3, D-6, D-7 of the
Harvey-Deakin report.)

     This is an ambitious measure  to  improve  traffic  flow
     on  freeways  and arterials in the  Bay  Area.  ARB  staff
believe  that  reducing  congestion  by providing reducing hours
of delay due to incidents and excess demand can both have
emission benefits.  Recent ARB research has provided new
information  regarding  the  relationships  between  vehicle
accelerations   and emission rates. Further research  on  how
total  emissions  from  metered  ramps and mainline freeway
operations  is  underway,  so  it  is  possible  that  emission
reductions from this measure may need  revision  at  a  future
update  of  the  TCM plan.

     Additional information should be provided on the
     assumptions, calculation methods  and  projected  impacts
on  emissions  and  related  travel indicators (e.g. regional
mode splits, vehicle trips, VMT, vehicle occupancy) to fully
evaluate the effectiveness of the proposed measure.

     The plan does not contain  information  on  a  specific
     action  plan  that can be monitored.  Caltrans is
identified as the funding source, and MTC is to cooperate in
developing the TOS ramp metering component and seeking funding
to install electronic toll collection on the Bay Bridge (See TCM
#20). More complete information  needs  to  be  provided
regarding  the  funding sources,  resource  commitments,
timelines,  milestones,  and  completion  dates for TCM #11.

     The ARB staff recommends  that  this  measure  be
     conditionally  approved, provided that  MTC,  Caltrans
and  any  county  congestion  management  agencies that      are
affected commit to an expeditious schedule to provide:

0         Documentation regarding calculation of emission
reduction impacts, 0         Commitment by participating
agencies to implement the measure, 0         Additional data
needed to clarify  when  the  measure  will  be  implemented,
0         Additional details that define the target performance
goals, and 0         A funding program that is adequate to
implement the measure.

TCM #12   Improve Arterial Traffic Management

     TCM #12 includes improvements to arterial travel flow due
     to signal timing programs, bus flow improvements and
Caltrans' "smart streets" programs. This measure continues an
ongoing program to  extend  retiming programs to new traffic
signals (FTCM #24) and to maintain them in  good operating
condition (FTCM #25). The use of arterials as reliever  routes,
or usmart streets" is related to the TOS operating system (see
TCM #12).

     This measure is projected to reduce emissions by 0.20%
     (RHC), 0.25% (NOx) and 0.30% (CO) in Phase 1. When funded,
Phase 2 actions  are  predicted to further reduce emissions by:
0.23% (RHC), 0.52% (NOx) and 0.33% (CO).  The completed measure
is also predicted to result in small increases  in vehicle trips
(0.03%) and VMT (0-02%). Annual costs are of this  ongoing  TCM
program are estimated at $6 million per year, and the plan is
unclear regarding when the costs and benefits are projected to
occur. (See  pages  A- 13, B-12, B-13, C-3, D-7 of the
Harvey-Deakin report.)

     ARB staff believe that improvements to arterial traffic
     flow can provide some emission reduction benefits with
little creation of new travel demand when the improvements are
made in areas where land development has already occurred.
Improvements that favor the flow of buses, such as bus/HOV
lanes, bus traffic signal preemption and relocation of bus
stops, would have the highest benefit.

     More detailed information needs to be provided on the
     physical facilities and the measure's emissions and related
travel indicators (e.g., regional vehicle trips, VMT, vehicle
speeds) to fully evaluate the effectiveness of the proposed
measure.

     The plan contains useful detail on the signal retiming
     program scope, funding source and schedule. More complete
information needs to  be  provided regarding the funding
sources, resource corrfnitments, timelines, milestones, and
completion dates for TCM #12.

     The ARB staff recommends that Phase 1 of this measure be
     approved and Phase 2 be conditionally approved, provided
that MTC, Caltrans and any county congestion management agencies
that are affected commit to an expeditious schedule to provide:

0    Documentation regarding calculation of emission reduction
impacts, 0    Commitment by participating agencies to implement
the measure, 0    Additional data needed to clarify when the
measure will be  implemented, 0    Additional details that
define the target performance goals, and 0    A funding program
that is adequate to implement the measure.

	       USER INCENTIVES
TCM #13    Transit Use Incentives

     TCM #13 consolidates and expands upon the transit use
     incentives included elsewhere in the TCM plan.  Proposed
projects include:  selective fare reductions, an expanded ticket
distributions system, improved coordination of fares among
transit operations (FTCM #21) and a regional toll-free transit
information number.

     Phase 1 actions appear to be funded as part of the MTC
     work  program.  The costs are not defined, but the emission
reductions predicted are: 0.11% (RHC & NOx) and 0.09% (CO).
When funded, Phase 2 activities are predicted to further reduce
emissions by:  0.21% (RHC & NOx) and 0.22% (CO).

     Costs for the full program are estimated at $18 million
     dollars per year. Projects would include: $10 million for
selective  fare  subsidies; $5 million for feeder bus service to
rail and ferries and $3 million for 'transit stores" based on
the Berkeley TRIP model. The plan states that such subsidies
would help address the "equity" concerns regarding revenue
generating (TCM #21) and pricing measures (TCM #22) included in
the TCM plan.  (See Volume II and Harvey-Deakin report, pages
A-14, B-14, B-15, C-3, C-4, D-7, D-8.)

     This measure would expand transit subsidies somewhat beyond
     those proposed elsewhere in the TCM plan.  The ARB staff
believes that financial incentives can provide motivation to
change travel modes, and thus help reduce vehicle emissions.
However, because of the overlap between TCM  #13 and other TCM
activities, care should be taken to avoid "double-counting" of
the benefits and costs of programs, such as: youth and
children's  transit fares subsidies (TCM #10), feeder buses to
rail and ferries (TCM #5),  and "transit stores"that are part of
an employer trip reduction plan (TCM  #1, TCM #2).

     Additional information needs to be provided on how the
     projected emission reductions have been calculated before
the effectiveness of  this measure can be fully evaluated.  This
would include:  the assumptions, calculation methods and
projected effects of Phases 1 and 2 on vehicle emissions and
related travel indicators (e.g. regional mode splits, vehicle
trips, VMT, vehicle occupancy and transit ridership on services
affected by the TCM #13 programs).

     The plan contains general descriptions of the activities to
     be included, and additional detail on the 1991 work
programs and budget items of agencies that are participating in
Phase 1 activities (MTC, RIDES, transit operators). The funding
included $80,000 in State transportation funds and transit
operator support.

     The proposed Phase 2 activities are not defined in a manner
     that can be monitored for performance, and they are
contingent on future funding  from revenue sources that were
unavailable when the measure was drafted (TCM #21).  New revenue
sources have been provided by State and Federal legislation, and
we recommend that they be evaluated as possible ways of

funding the transit use incentives in a timely fashion. More
complete information needs to be provided for Phase 2 actions
regarding the funding.  sources, resource corrrnitments,
timelines, milestones, and expected completion dates.

     The ARB staff recommends that this measure be conditionally
     approved, provided that MTC, Caltrans and any county
congestion management agencies that are affected commit to an
expeditious schedule to provide:

0    Documentation regarding calculation of emission reduction
impacts, 0    Commitment by participating agencies to implement
the measure, 0    Additional data needed to clarify when the
measure will be implemented, 0    Additional details that define
the target performance goals, and 0    A funding program that is
adequate to implement the measure.

TCM #14    Vanpool Liability Insurance

     TCM #14 would seek to increase the rates of vanpool
     formation and retention by offering a publicly-financed or
subsidized vanpool liability insurance program.  Vanpools
currently serve less than one percent of Bay Area Commuters, and
liability insurance costs of $2,500-$3,000 per year appear to be
a factor in the declining rate of growth for this transportation
mode.

     Phase I consists of a RIDES study to determine how this
     program can stimulate growth of vanpooling in the Bay
Area.  It is to be conducted in FY 1991-92 within their funded
work program.

     Implementation in Phase 2 is contingent on securing funding
     for the program.  Estimated costs are $2.1 million per year
for full public funding.  but the actual costs would depend on
the scope of the program and the level of subsidy that was
provided.  The emissions reductions predicted from establishing
a vanpool liability insurance program are:  0.02% (RHC & NOx)
and 0.01% (CO). (See Volume II and Harvey-Deakin report, pages
A-15, B-15, C-4, D-8.)

     TCM #14 lacks information on the assumptions, data and
     methods used to calculate costs and effectiveness of this
measure.  As with other support measures, it is important to
avoid "double-counting" of the vanpool emission reductions.
I,nformation is also lacking on projected effects on future mode
sPlit, vehicle trips, VMT and average vehicle occupancy.

     If the  Phase 1 study findings are positive, the funding
     opportunities though new and existing revenue sources
should be reexamined.  For example, transportation management
associations (TMAS) might be asked to participate in a joint
benefit program of this nature.  Local discretion has been
increased regarding uses of gas tax and vehicle registration
surcharge fees.

     This measure would remove or reduce an identified
     disincentive to vanpool use, and the ARB staff believes
that the cost reduction would add motivation for greater vanpool
use, and thus help reduce vehicle emissions.  However, because
of the overlap between TCM #14 and other TCMs that include
vanpool elements, care should be taken to avoid
"double-counting" of the benefits and costs of this program.
Examples include measures to reduce single-occupant vehicle
trips through employer trip reduction plans  (TCM #1, TCM #2).

     Additional information needs to be provided on how the
     projected emission reductions have been calculated before
the effectiveness of this measure can be fully evaluated.  This
would include:  the assumptions, calculation methods and
projected effects of Phase 2 implementation on vehicle emissions
and related travel indicators (e.g. regional mode splits,
vehicle trips, VMT, vehicle occupancy and future vanpool numbers
and ridership).

     The measure is not defined in a manner that can be
     monitored for performance, and more complete information
needs to be provided as the Phase 2 program is developed
regarding the funding sources, resource commitments,

timelines, milestones, and expected completion dates.  We
realize that funding has not yet been identified, and
implementation is contingent on securing funds from  revenue
sources that were unavailable when the measure was drafted (TCM
#21).  New revenues, provided by recent State and Federal
legislation, will now need to be evaluated as possible ways of
funding a lower cost insurance program.  Another funding source
might be a jointly financed program with participation by
transportation management organizations, as a benefit for
employer members.

The ARB staff recommends that this measure be fully
conditionally approved, provided that MTC, RIDES and the
District commit to an expeditious schedule to   provide:

0    Full documentation regarding calculation of emission
reduction impacts, 0    Clear coninitment by participating
agencies to implement the measure, 0    Additional data needed
to clarify when the measure will be implemented, 0    Additional
details that define the target performance goals, and 0    A
funding program that is adequate to implement the measure

TCM #15   Provide Carpool Incentives

     TCM #15 would support legislation to increase the Federal
     tax deductions for employees of transit and ridesharing
subsidies, and to change State and federal tax policies that
allow employers to deduct the costs  of providing free or
subsidized employee parking a business expense.  No costs or
emission reduction benefits are identified for these Phase 1
activities that are to be included in the funded MTC and
District work programs.

     Future Phase 2 projects of this measure include both
     private  employer incentive programs and a new regional
carpool subsidy program to be designed by MTC and RIDES.
Employers would pay cash incentives to employees  in  the
private plans (See TCM #1, TCM #2), while the mmobility package'
revenues expected from TCM #21 are proposed as the funding
source for the RIDES carpool subsidy program.  Costs are not
given because they would vary by the types of subsidy programs
what were developed. However, the Phase  2 emission reductions
are projected as 0.20% (RHC & CO) and 0.30% (NOx).  (See Volume
II and Harvey-Deakin report, pages A-15, B-15, C-4, D-8, D-9.)

     This support measure contains both public and private
     subsidy programs, and it is unclear if any separation has
been made in calculations of the future  emission reduction
effects.  The ARB staff believes that financial incentive
programs can encourage mode switching, and thus reduce vehicle
emissions.  Care must be taken to avoid "double-counting' of
emissions where TCM plan objectives overlap.  This type of
confusion may have occurred in this measure.

     Additional information needs to be provided regarding the
     assumptions, data and methods used to calculate costs and
effectiveness of this measure.  Information is also needed
regarding the projected effects on future mode split, vehicle
trips, VMT vehicle occupancy and projected changes in the number
of carpools and carpool person-trips.

     The plan does not define the Phase 2 measure in a way that
     can be monitored for measure implementation.  More
information needs to be provided on the Phase 2 program scope
and implementation plans for the two subsidy programs.  (e.g.,
activity schedule, lead agencies, timetable, milestones, costs
and revenue sources). Funding options for the regional carpool

   subsidies need to be reexamined in light of current State and
   Federal programs.  Local discretion has also been increased
   regarding uses of gas tax and vehicle registration surcharge
   fees.

   The ARB staff recommends that this measure be conditionally
   approved, provided that MTC, RIDES and the District commit to
   an expeditious schedule to provide:

0  Full documentation regarding calculation of emission
reduction impacts, 0  Clear commitment by participating agencies
to implement the measure, 0  Additional data needed to clarify
when the measure will be implemented, 0  Additional details that
define the target performance goals, and 0  A funding program
that is adequate to implement the measure.

	   INDIRECT SOURCE REVIEW
TCM #16   Indirect Source Control Program

     TCM #16 includes the adoption of District rules to
     regulate  new  and existing development.  Non-work trips
are the stated target for the measure.

     The initial rule that will affect only new and modified
     land development is projected to reduce emissions by 0.7%
by 1997.  Full implementation of TCM #16 will include a second
rule that affects existing land uses as well, and the long-term
projections of reduction in  vehicle miles traveled (VMT) are
stated to be as much as 10 percent by 2005 or  2010 with similar
projections made for emission reductions (RHC, NOx, CO). (See
Volume II and the Harvey-Deakin report, pages A-16, B-16, C-4
and D-9.)

     Clearly, TCM #16 is an ambitious measure, and ARB staff
     believes that it will be be effective in reducing
emissions.  However, additional information on the assumptions
and methods used in calculating impacts  must be provided for
review to document the projected effectiveness.

     The plan states that the TCM #16 emission reduction
     projections will not overlap with reductio'ns projected for
high densities near transit (TCM #18). Similarly,the focus on
non-work trips appears to be  taken  to avoid overlap with TCM
#2, the Employer Trip Reduction Rule. To  the  degree that
home-work trips are made by persons working for small firms that
are not not covered by TCM #2, some underestimation of trips
diverted from  this employee subgroup could occur in projecting
future emission reductions.

     The plan does not contain sufficient information to fully
     evaluate  the scope of the rule to be developed.  Given
that the actual measure will be designed in the district's
rulemaking process, it is not necessary to resolve this issue in
the plan itself.  The plan does provide a clear commitment by
the district to implement TCM #16 by the adoption of rules  to
reduce the vehicle emissions impacts from new and existing land
uses,  an action for which it has adequate authority.  Future
funding is assured because the District can levy fees necessary
to implement the program.

     ARB staff recommends that TCM #16 be approved.  The scope
     and projected emission reductions will be refined in the
rule adoption process.

	   IMPLEMENTATION SUPPORT

TCM #17    Conduct Public Education

     The purpose of this measure is to inform people regarding
     the current status of air quality in the Bay Area and
inform them on individual actions to better air quality.

     No additional emission reduction credit is claimed for this
     support program.  The BAAQMD Public Outreach Steering
Committee will help develop and implement an ongoing public
education program throughout this  plan.

     The initial costs of this campaign are $250,000, and this
     expense was funded by an EPA grant.  The BAAQMD is seeking
sources of funds to continue and expand the program.

     Information is lacking on the final scope of the
     continuing  public education program with milestones and
budget.

     ARB staff recommends that Phase 1 of this measure be
     approved and Phase 2 be conditionally approved, while
concurrently recommending  that additional information be
provided to fully document the future  program objectives,
schedule and budget for the District program to implement the
public education requirements of the Act.

TCM #18    Zoning for High Densities Near Transit Stations

     TCM #18 is designed to reduce vehicle trips and increase
     transit ridership by promoting high density, mixed-use
development in the area of transit stations. The targeted areas
are located around  the  rail  extensions included in TCM #4,
Expedite and Expand Regional Rail Agreement.

     Emission reductions are projected to be reduced by 0.05%
     (RHC,  NOx,  CO) in Phase 2, and annual costs of $500,000
are estimated to prepare  site  plans for transit station.

     Phase I activities would take place within existing
     budgets,  including:  the evaluation of transit-oriented
development patterns for the Bay  Area  for the Regional
Transportation Plan (MTC), seeking of funds for  preparation  of
specific area plans for transit stations (MTC, transit
agencies)  and  cities and counties will be encouraged to plan
for high density, mixed-use development near transit by the
District to implement TCM #18, as well as TCM #16 (indirect
source review) and TCM #19 (air quality elements).  (See Volume
II and Harvey-Deakin report, pages A-17, B-16, B-17, C-4, D-9.)

     The plan bases the emission reduction on obtaining extra
     funding  needed to prepare site plans for transit station
development.  A decrease in vehicle trips is expected to occur
that is beyond the scope of  related  TCMs in the plan. ARB
staff agrees with the conclusion that some  increase  in  TCM
plan effectiveness is reasonable, due to this  measure.
However,  additional information 'is needed for full review of
the emission reductions and  overall TCM plan impacts.

     The ARB staff recommends that this measure be conditionally
     approved, provided that the MTC, District and transit
agencies corrfnit to an expeditious schedule to provide:

0    Documentation regarding calculation of emission reduction
impacts, 0    Commitment by participating agencies to implement
the measure, 0    Additional data needed to clarify when the
measure will  be  implemented, 0    Additional details that
define the target performance goals, and 0    A funding program
that is adequate to implement the measure.

TCM #19   Air Quality Elownt for General Plans

     TCM #19 encourages all cities and counties to include an
     Air Quality Element in their General Plan to ensure that
air quality issues are integrated into lower planning and
decision-making.

     This support measure would expand the District efforts to
     have local governments in the Bay Area adopt these elements
which began in 1986.  District efforts include revision of
existing guidelines, the support of state legislation to mandate
Air Quality Elements in general plans and expanded assistance to
cities and counties in preparing the elements.  The adoption of
an element will be a condition of delegation for administration
of the future indirect source rules (TCM #16).  (See Volume II.)

     ARB staff commends that District for the leadership that it
     has  shown in providing leadership in developing this form
of local support by cities and counties.  The plan points out
the beneficial effects of having an adopted air quality element
in General Plans in the promotion of sound planning and policies
at the local level, and by supporting the implementation of
other TCMs in the Clean Air Plan. ARB staff agrees  with this
assessment.  The District experience in promoting this approach
will produce information of value to other districts, and it is
recommended that progress reports be made on this measure.

     ARB staff recommends that TCM #19 be accepted as an
     uncredited measure in support of the Act.

TCM #20    Conduct Downstration Programs

     TCM #20 will provide demonstration programs and studies to
     encourage innovative approaches to reducing vehicle travel
and emissions.  Topics listed as examples include:
telecommuting,  congestion  pricing/electronic license plate
evaluation and electric or natural gas carpools.

     The scope of these activities will depend on available
     funding.  The estimated costs are $500,000 per year.  No
additional emission reduction credit is claimed for these
small-scale projects.

     Additional detail on how these activities will be included
     in the work programs of participating agencies would be
desirable.  Timelines, budgets and work products for adopted
studies and demonstrations should be provided.

     ARB staff recommends that TCM #20 be accepted as an
     uncredited measure in support of the Act, while
concurrently recommending that additional information be
provided to fully document the assumptions and experience in
implementing the demonstration projects that are included in
the  measure.

		REVENUE @URES
TCM #21     Implownt Revenue Measures

     TCM # 21 is designed to secure the additional revenue
     needed to fully fund the mobility improvement measures in
the TCM plan.  Added revenues of $500-$600 million per year are
needed to meet this funding shortfall.  (See Volume II; Volume
I, page 19; and the Harvey-Deakin report, pages A-19, B- 17,
B-18, C-4, D-10.)

     Three of the five revenue measures have been approved.
     These Phase 1 elements include:

	  1)   an increase of $.09 per gallon in the State
	  gasoline tax, 2)   an increase to $1.00 for all bridge
	  tolls, and 3)   passage of AB 434 authorizing vehicle
	  registration fee
	       increases of up to $4 per vehicle

     Action has not been taken on legislation to increase bridge
     tolls to $2.00.  Legislation to further increase gasoline
prices by $.14 per gallon in the region seems unlikely to be
approved.

     TCM #21 is a critical measure in determining the success of
     the TCM program as a whole.  The implementation of many
other measures is contingent on new revenues.  The $.14 regional
gas tax, or some alternative source is projected to raise $420
million per year to meet the TCM funding shortfall.

     We recommend that this measure be revised to reflect the
     amount of new revenues now available for Bay Area projects
due to passage of the first three funding proposals.  New
Federal funding is also available.  The recent passage of the
Intermodal Surface Transportation Efficiency Act (ISTEA) has
provided new flexibility in use of future Federal gas tax
revenues, and this revenue source should also be included in
reviewing this measure.  Given these laws, TCM #21 could
logically be recast as a commitment to apply new state and
federal monies to help implement unfunded measures.

     A second concern is the potential for the "double-counting"
     of the emissions reductions.  More information on the
assumptions, data and methods used in the calculation of the
emission reductions need to be provided for full review of the
emission reductions claimed for these revenue measures.

     The ARB staff recommends that this measure not be approved,
     until it has been revised to reflect recent changes in
state and federal law.

	      PRICING 14EASURES
TCM 022     Implement Narket-Based Pricing Measures

     TCM #22 is  a  package  of  pricing  measures  that  are
     intended  to  reduce motor vehicle emissions and traffic
congestion by increasing the cost of driving significantly.  An
estimated $3.3 billion dollars per year would be raised if all
assumed pricing proposals were to be adopted.  These user costs
could be used to fund improvements in transit and other TCMs to
meet concerns  over  the  negative  impacts  on  low  income
travelers  ("equity   issue") or could be rebated to Bay area
residents to mitigate adverse economic impacts of pricing.

     This is the  most  ambitious  measure  in  the  TCM  plan,
     and  it  is  projected to have  large  impacts  on
vehicle  use  and  emissions  when  implemented.  TCM  #22 is
projected to  achieve  a  14.6%  reduction  in  motor  vehicle
trips  and  a  13.7% decrease  in  vehicle  miles  travelled
(VMT),  as  compared  to  baseline  levels projected by traffic
models for the year 2000.  The projected emission reductions
are: 20.6% (RHC), 15.5% (NOx), and 22.5% (CO).

     The  emission  reductions  assumptions  in  the  plan  are
     based  on  the  impact of  the  increased  costs  alone.
Additional  benefits  that  would  be  realized   if the new
revenues  supported  other  parts  of  the  TCM  plan  are  not
counted.  The plan  estimates  the  following  revenue  would
be  generated  from  the  measure:

     21a.      Smog-Based Vehicle Registration Fees ... Would
     raise $500 million
	       per year based on an average $125 fee per vehicle

     21b.      Regionwide  Freeway  and  Arterial  Congestion
     Pricing  ...  Would  raise
	       $354 million per year at $.10 per mile ($90 per
	       vehicle)

     21c.      Regionwide Non-Work Parking Charge of $0.60 per
     Hour ... Would
	       raise $690  million  year  with  $3.00  daily
	       cap  in  low  density  areas

     21d.      Gas Tax Increase of $2  per  Gallon  ...  Would
     raise  $1.8  billion  per
	       year ($450 per vehicle)

     21e.      Regionwide Worksite Parking Charges of $3.00 per
     Day ... This
	       charge is part  of  TCM  #2,  so  no  added
	       revenue  or  emissions  occur

     Financial disincentives are powerful motivation to consider
     mode changes, if reasonable alternatives are available.
The ARB staff believes that the degree of change in travel
habits due to pricing  appears reasonable, but that the
likelihood of passing the full range of pricing programs grouped
in this measure is low.

     The  description  of  the  MTC  and  District  activities
     during  Phase  1  does not  contain  specific  schedules,
budgets  or  milestones  that  can  be   monitored for
performance.  Additional  information  needs  to  be  provided
on  any   work programs to develop legislation, seek public
support and design project applications of the five pricing
strategies.

     The plan lacks a detailed plan for developing support for
     legislation and for the implementation of these measures,
including funding  commitments, milestones, and phased
implementation.   Although there is a great deal of support from
Bay Area business associations and environmental organizations
for these pricing measures, opposition is expected to any action
that would substantially increase the cost of owning and
operating an  automobile, especially from low income groups. ARB
staff notes that this  issue  is addressed in the USER
INCENTIVES measures to some degree (TCM #13, TCM  #15).

     The plan states that the new fees would be implemented in
     stages, such as TCM #21 as an initial objective.
Therefore, there appears to be some overlap in the emission
reduction estimates that needs to be  addressed.  The funding
shortfall that TCM #21 addresses could be met in this manner,
because TCM #22 would use the revenues to fund TCMs with the
greatest air quality benefits, and to provide a fund or programs
to reduce impacts on  low income households (e.g. subsidized
transit passes (TCM #13), improved transit service (TCM #3, TCM
#5), and income tax credits).

>>     Given the need for additional legal authority for most of
>>     these measures, the ARB staff can not recommend that the
>>emission  reductions associated with this measure, or its effect
>>on vehicular occupancy,  be approved for inclusion if the plan.
>>Staff concurs that pursuit of this measure is very worthwhile,
>>and recommends that MTC and the district  develop a work plan to
>>pursue the needed legal authority, and include a commitments in
>>the plan to execute this work plan.

	   INTERMITTENT 14EASURES
TCM #23    Ozone Excess aNo Drive Days' (Voluntary)

     TCM #23 is a voluntary, intermittent program to  encourage
     drivers  to eliminate unnecessary trips, use alternative
modes or chain  trips  on  high ozone days.  It is related to CM
#Gl, Citizen Postponement of Discretionary Activities and TCM
#17, Enhance Public Education.

     The initial experience with this program in  September
     1991  suggested that it could have high potential on high
ozone days.  If  a  5%  compliance rate could be achieved,
emission reductions are projected of 7 tons/day RHC and 11
tons/day NOx.    No enforcement or monitoring methods  are
available and no emission reduction credit is claimed in the TCM
plan.

     ARB staff recommends that TCM #23 be accepted as an
     uncredited measure in support of the Act, while
concurrently recommending that additional information be
provided to fully document the District assumptions and
experience in implementing this intermittent, voluntary
program.



                          Bay Area 1991 Clean  Air  Plan


             TCM Strategies              Reasonably  Adequately  Resources  ARB     Sta
                                         Available   Defined     Commited   Recommen

1-  Expand Employer Assistance Programs  OK          OK          OK         A

2-  Employer-Based Trip Reduction Rule   OK          OK          OK         A

3-    Improve Areawide Transit Service

Phase   1  OK  OK  OK  A
Phase   2  OK  OK  I   CA

4-    Expedite and Expand Regional Rail Service


Phase   1  OK  OK  OK  A
Phase   2  OK  OK  I   CA

5-    Improve Access to Rail and Ferries

Phase   1  OK  I  I  CA
Phase   2  OK  I  I  CA

6-    Improve Intercity Rail Service

Phase   1  OK  OK  OK  A
Phase   2  OK  OK  I   CA

7-    Improve Ferry Service

Phase   1  OK  OK  OK  A
Phase   2  OK  OK  I   CA

8-    Construct Carpool/Bus Lanes on Freeway

Phase   1  OK  OK  OK  A
Phase   2  OK  OK  I   CA


Legend:  'OK'   Adequate    'A'    Approve               '(a)'=  Need   data
         " I '  Incomplete  "CA"=  Conditional Approval  '(b)'=  Need   data

          "N/A'=  Not Applicable                    "AC'= Accept Commitment "(c)'= Possible  "d

Table 1 - Evaluation of Transportation Control Measures  in  t
                    Bay Area 1991 Clean  Air  Plan


TCM Strategies  Reasonably  Adequately  Resources  ARB     S
                Available   Defined     Commited   Recommen

9-    Improve Bicycle Access and Facilities

Phase   1  OK  OK  OK  A
Phase   2  OK  I   I   CA

10-   Improve Youth Transportation
          Phase   2                                           OK         OK CA

11-   lnstallFreewayTravelOperationsSystem

Phase   1  OK  OK  OK  A
Phase   2  OK  OK  I   CA

12-   lmproveArterialTrafficManagement

Phase   1  OK  OK  OK  A
Phase   2  OK  OK  I   CA

13-   Transit Use Incentives

Phase   1  OK  OK  OK  A
Phase   2  OK  I   I   CA

14-   Vanpool Liability Insurance

Phase   1  OK  OK  OK  A
Phase   2  OK  I   I   CA

15-   Provide Carpool Incentives

Phase   1  OK  OK  OK  A
Phase   2  OK  I   I   CA




Legend:  'OK'   Adequate    "A"    Approve               "(a)'=  Need   data
         " I '  Incomplete  'CA"=  Conditional Approval  "(b)'=  Need   data

          "N/A"=  Not Applicable                    'AC'= Accept Commitment "(c)'= Possible  "d

Table 1 - Evaluation of Transportation Control Measures in  t
                         Bay Area 1991 Clean  Air  Plan


              TCM Strategies          Reasonably  Adequately  Resources  ARB     St
                                      Available   Defined     Commited   Recommen

16-  Indirect Source Control Program  OK          OK          OK         A

17-   Conduct Public Education

Phase   1  OK  OK  OK  A
Phase   2  OK  OK      CA

18-  High Density Near Transit
          Phase   2                                           OK         OK CA

19-   Air Quality Elements for General Plans
          Phase   1                                           OK         OK OK A

20-   Conduct Demonstration Projects

Phase   1  OK  OK  OK  A
Phase   2  OK  OK  I   AC

21-   Implement Revenue Measures

Phase   1  OK  OK  I  AC
Phase   2  1   1   1  AC

22-   Market-Based Measures

          Phase   1                            N/A  I   i   AC
          Phase   2                            N/A  I   I   AC

23-  Ozone Excess 'No Drive Days' (voluntary)  OK   OK  OK  A





Legend: 'OK'    Adequate    "A"    Approve               '(a)'=  Need   data
                " I "       Incomplete"CA"=              Conditional Approval"(b)"=  Need   data

'N/A"=  Not Applicable                    "AC"= Accept Commitment "(c)'=  Possible  "

          Table 1 - Evaluation of Transportation Control Measures in t
                               Bay Area 1991 Clean Air Plan


DESCRIPTION OF CODES USED IN STAFF RECOMMENDATIONS
  REGARDING TRANSPORTATION CONTROL MEASURES


"A" = Full approval based on:

y         Air District has full authority to adopt rule and levy fees to fund implementation of control mea

o         Other agency has made funding or other  commitments  for  full  implementation  of  control  meas

o         Control measure is a continuation of existing support activities with identified funding source

"CA"      =  Conditional approval based on:

o         Air District has an adopted control measure that can  onlyt  be  implemented  by  another  agency
          o Credit for future emission reductions is conditional, based on commitment  of  resources  by  oth

"AC" =  Acceptance of commitment based on:

     y     Legal authority to implement control measure does not currently exist

     y     Air District and other responsible agencies need to continue development of measure

          o Emission reductions credit is deferred  until  resource  commitments  are  made  to  implement  m

--
Bill Michel			
bm@eng.sun.com		These views are my own, not Sun's.