10/24/97

MEMORANDUM

SUBJECT: Guidance on Incorporating Voluntary Mobile Source Emission Reduction

Programs in State Implementation Plans (SIPs).

FROM: Richard D. Wilson,

Acting Assistant Administrator

 for Air and Radiation

TO: EPA Regional Administrators, 1 - 10

Introduction

This memorandum provides guidance and sets forth the Environmental Protection

Agency’s (EPA) policy and interpretation regarding the granting of explicit State

Implementation Plan (SIP) credit for Voluntary Mobile Source Emission Reduction Programs

(VMEPs) under section 110 of the Clean Air Act. Voluntary mobile source measures have the

potential to contribute, in a cost-effective manner, emission reductions needed for progress

toward attainment and maintenance of the National Ambient Air Quality Standards (NAAQS). 

EPA believes that SIP credit is appropriate for voluntary mobile source measures where we have

confidence that the measures can achieve emission reductions. This memorandum announces

EPA’s intent to grant emission reduction credits for VMEPs, the terms and conditions for

establishing and implementing VMEPs, and the requirements for approvable VMEP SIP

submittals. 

 The establishment of this policy pertains solely to voluntary mobile source programs 

and is not intended to establish precedent for other air emissions source categories. Guidance on

emission reduction credits for voluntary activities for other source categories may be established

through future guidance documents. This policy also does not change existing EPA policy on

credits for mobile source measures in the context of emissions trading programs or Economic

Incentives Programs.
Throughout this document, the term “State” refers to any state or local government body or agency with 1

the authority to submit SIPs to EPA for approval.

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Policy Summary

The Clean Air Act Amendments of 1990 increased the responsibility of States to 1

demonstrate progress toward attainment of the NAAQS. At the same time, air pollution control

programs in the U.S. have had difficulty regulating the emission reduction potential of smaller or

unconventional sources. EPA supports innovative methods in achieving air quality goals and

wishes to promote the creation of viable voluntary mobile source air quality programs. The

desire to recognize the emission reductions from these sources has led the Agency to develop

policies to support an increasing variety of innovative approaches. EPA recognizes that emission

reduction credit toward SIP air quality demonstrations can be a positive factor for gaining

political and institutional support for program development and implementation. The

demonstration of air quality benefits is also desirable for program assistance through EPA’s

section 105 grants and is a requirement for project eligibility under the Department of

Transportation’s Congestion Mitigation and Air Quality Improvement (CMAQ) program.

 This memorandum is intended to clarify the basic framework for ensuring that VMEPs

become eligible for SIP credit. Generally, a State would submit a SIP which 1) identifies and

describes a VMEP; 2) contains projections of emission reductions attributable to the program,

along with relevant technical support documentation; 3) commits to monitor, evaluate, and

report the resulting emissions effect of the voluntary measure; and 4) commits to remedy in a

timely manner any SIP credit shortfall if the VMEP program does not achieve projected emission

reductions. 

 EPA anticipates that this policy will generate additional interest and resources toward

VMEP development and data collection. EPA wishes to ensure that the potential benefits of

VMEPs are properly quantified and that these benefits are sustained as successful components of

the SIP. As experience and information regarding the effectiveness of VMEPs becomes

available, EPA intends to provide further technical guidance and assistance to the States. As

States and EPA gain more experience with VMEPs in quantifying emissions benefits, more

precise information will be available in determining the effectiveness of a range of programs. 

The type of information that EPA expects to gain from evaluating VMEPs includes emissions

benefits, public response and education, cost of implementation, secondary indicators\benefits,

quantification methodologies, and data collection. 
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EPA hopes that the effect of this policy will be to generate sufficient information and

programmatic experience to warrant a wider application of VMEPs for progress toward

attainment under the new NAAQS policy framework. EPA believes that States should benefit

from this policy by having a wider range of programmatic options to consider. This policy will

ultimately support the creation of new, cost-effective air quality programs and market-based

incentives.

Background

Historically, mobile source control strategies have focused primarily on reducing

emissions per mile through vehicle and fuel technology improvements. Tremendous strides have

been made resulting in new light-duty vehicle emission rates which are 70 to 90 percent less 

than for the 1970 model year. However, transportation emissions continue to be a significant

cause of air pollution due to a doubling of vehicle miles traveled (VMT) from 1970 to 1990, and

tripling since 1960. In some quickly developing urban areas, the more recent VMT growth rate

is even more dramatic. In San Diego, California, VMT tripled between 1970 and 1990. VMT in

Las Vegas, Nevada, increased 160 percent from 1981 to 1991, and nearly doubled in Phoenix,

Arizona, during the same time period.

The increasing cost of technological improvements to produce incrementally smaller

reductions in grams per mile or grams per kilowatt hour emissions in the entire fleet of vehicles

and engines, along with the time it takes for technological improvements to penetrate the existing

fleets, suggests that supplemental or alternative approaches for reducing mobile source air

pollution are necessary. Mobile source strategies which attempt to complement existing

regulatory programs through voluntary, nonregulatory changes in local transportation sector

activity levels or changes in in-use vehicle and engine fleet composition are being explored and

developed. 

A number of such voluntary mobile source and transportation programs have already

been initiated at the State and local level in response to increasing interest by the public and

business sectors in creating alternatives to traditional emission reduction strategies. Some

examples include economic and market-based incentive programs, transportation control

measures, trip reduction programs, growth management strategies, ozone action programs, and

targeted public outreach. These programs attempt to gain additional emissions reductions

beyond mandatory Clean Air Act programs by engaging the public to make changes in activities

that will result in reducing mobile source emissions.
The requirements regarding emission reductions needed to achieve attainment of the NAAQS. 2

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Definitions

The following definitions apply to VMEPs as described in this memorandum.

Voluntary Measures: Emission reduction programs that rely on voluntary actions of

individuals or other parties for achieving emission reductions.

Seasonal Measures: Emission reduction programs that are in effect only during the

season in which the area experiences high pollutant concentrations.

Episodic Measures: Activity-based mobile source programs that are implemented 

during identified periods of high pollutant concentrations, varying by meteorological 

conditions. These measures may or may not be continuous in nature depending on 

program design. The statutory authority for approval of episodic measures in SIPs 

applies only to activity-based mobile source emission reduction measures as explained 

below.

Clean Air Act Authority

EPA plans to use its authority under the Clean Air Act to allow SIP credit for new

approaches to reducing mobile source emissions. This policy represents a flexible approach 

regarding the SIP requirements set forth in section 110 , and economic incentive provisions in 2

section 182 and 108 of the Act. This policy responds to State and local government interest in

gaining SIP credits and funding for VMEP programs which will count toward their State’s plan

to make progress toward attainment and maintenance of the NAAQS and builds on EPA’s

history of approving measures that rely to some degree on voluntary compliance, such as

provision of mass transit. Recognizing that only a limited amount of implementation experience

currently exists, and that information on VMEP effectiveness will be evaluated and reported as a

result of this policy, EPA plans to re-evaluate this policy in the future.

Authority to approve of voluntary measures in SIP

EPA believes that it has authority under CAA section 110 to approve voluntary measures

in a SIP for emission reduction credit. However, EPA believes that as part of its SIP submittal a

State must commit to monitor, evaluate, and report the resulting emissions effect of the voluntary

measure, whether the measure is implemented directly by the State or another party, and to

remedy in a timely manner any credit shortfall.

In light of the increasing incremental cost associated with additional mobile source
For example, an ozone area classified as severe needing reductions of 200 tpd of volatile organic 3

compounds (VOC) and 100 tpd of oxides of nitrogen (NO ) from the projected year 2005 baseline inventory could x

rely on VMEPs for up to 3% of the required reductions from each pollutant, or 6 tpd of VOC and 3 tpd of No . The x

area could also use all or a portion of these same reductions for purposes of meeting interim rate-of-progress (ROP)

milestones, but again the 3% limit would apply. Thus, if the area needed 25 tpd of creditable VOC reductions to

meet the 1999 ROP target, no more than 0.75 tpd of the VOC reduction in the 1999 ROP plan could come from

VMEPs.

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emission reductions, the lead time required for new technologies to penetrate fleets, and the

increasing need to target mobile source use to realize reductions, where voluntary measures meet

the requirements of this policy, EPA believes that it is appropriate and consistent with the Act to

allow a limited percentage of the total emission reductions needed to satisfy any statutory

requirement, as described below, to come from voluntary measures. In the event the voluntary

measure does not achieve the projected emission reductions, the State, having previously

committed in its SIP to remedying such shortfalls, will pursue appropriate follow-up actions in a

timely fashion including, but not limited to: adjusting the voluntary measure, adopting a new

measure, or revising the VMEP emission credits to reflect actual emission reductions, provided

overall SIP commitments are met. EPA believes that voluntary mobile source measures, in

conjunction with the enforceable commitment to monitor emission reductions achieved and

rectify any shortfall, meet the SIP control measure requirements of the Act.

Establishment of a cap on SIP credits allowed for VMEPs

Under this policy, in light of the innovative nature of voluntary measures and EPA’s

inexperience with quantifying their emission reductions, EPA is setting a limit on the amount of

emission reductions allowed for VMEPs in a SIP. The limit is set at three percent (3%) of the

total projected future year emissions reductions required to attain the appropriate NAAQS. 

However, the total amount of emissions reductions from voluntary measures shall also not

exceed 3% of the statutory requirements of the CAA with respect to any SIP submittal to

demonstrate progress toward, attainment of, or, maintenance of the NAAQS . EPA has analyzed 3

a number of voluntary mobile source programs which could be incorporated into a SIP. The

emission reduction potential of these programs is generally a fraction of one ton per day. A

three percent limit on emission reductions from VMEPs will allow areas to implement and claim

SIP credit for a significant number of voluntary mobile source programs. This cap still provides

a sufficient incentive for developing and implementing VMEPs, while setting a limit on the

extent to which a SIP can rely on innovative programs with which we have had limited

experience.
In accordance with the Act language (section 182 (g)(4)(A)), the EIP applies to “incentives and 4

requirements to reduce vehicle emissions and vehicle miles traveled,” including TCM’s contained in section 108 of

the Act. In addition, the EIP defines mobile sources to mean on-road (highway) vehicles (e.g., automobiles, trucks

and motorcycles) and non-road vehicles (e.g., trains, airplanes, agricultural equipment, industrial equipment,

construction vehicles, off-road motorcycles, and marine vessels). In certain cases, States are required to adopt EIP

provisions into their State Implementation Plan (SIP). The EIP also serves as guidance for all other States that

choose to adopt EIP provisions into their SIP as non-mandatory EIPs. In 1994, the Agency issued EIP rules and

guidance (40 CFR part 51 subpart U), which outlined requirements for establishing these programs.

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Relationship to Economic Incentive Programs

 The 1990 Amendments statutorily required the Agency to develop Economic Incentive

Program (EIP) rules . The EIP provides general SIP guidance for the adoption of incentive and 4

other innovative programs. Some programs that depend on voluntary actions also require either

State or local government authorization to implement the program. In these cases, which include

certain transportation control measures such as congestion pricing programs, it may be more

appropriate to use the EIP authority to incorporate the measure into the SIP. Further, where

emissions reductions are expected to exceed the 3% limit, EPA would anticipate the State could

use the EIP to incorporate measures. If a State wishes to have a VMEP approved under the EIP

program rules, EPA is willing to work with the State to develop such a program.

Approval of Voluntary Measures into the SIP - Key Criteria

This section sets forth minimum criteria for approval of VMEPs into SIPs. These criteria 

require that the VMEP not interfere with other requirements of the Clean Air Act, be consistent

with SIP attainment and Rate of Progress requirements, and that emission reductions be:

1. Quantifiable - VMEP emission reductions must be quantifiable. The level of uncertainty in

achieving emission reductions must be quantified, and this uncertainty must be reflected in the

projected emission reductions claimed by the VMEP. VMEPs must also contain procedures

designed to both evaluate program implementation and to report program results as described in

the section “Technical Support for VMEPs” of this guidance. 

2. Surplus - The VMEP emission reductions may not be substituted for mandatory, required

emission reductions. States may submit to EPA for approval any program that will result in

emission reductions in addition to those already credited in a relevant attainment or maintenance

plan, or used for purposes of SIP demonstrations such as conformity, rate of progress, or

emission credit trading programs.

3. Enforceable - A State’s obligations with respect to VMEPs must be enforceable at the State

and Federal levels. Under this policy, the State is not responsible, necessarily, for implementing

a program dependent on voluntary actions. However, the State is obligated to monitor, assess
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and report on the implementation of voluntary actions and the emission reductions achieved from

the voluntary actions and to remedy in a timely manner emission reduction shortfalls should the

voluntary measure not achieve projected emission reductions. As stated earlier, EPA anticipates

that the State will take the steps it determines to be necessary to assure that the voluntary

program is implemented and that emission reductions are achieved so that corrective SIP actions

are not required. For example, the State may want to sign a Memorandum Of Understanding

(MOU) with the VMEP sponsors. 

Any uncertainty in the emission reductions projected to be achieved by the VMEP must

be estimated and reflected in the emission reduction credits claimed in the SIP. As part of this

submission, the State must commit to conducting program evaluations within an appropriate

time-frame. The State must also report the resulting information to EPA within an appropriate

time-frame in order to document whether the program is being carried out, and emission

reductions are being achieved as described in the SIP submittal. Through the program evaluation

provisions contained in this policy EPA anticipates that States will discover any potential

emission reduction shortfall in a timely manner and appropriately account for such shortfall

either by changing the program to address the shortfall, adopting a new measure, or revising the

VMEP’s emission credits to reflect actual emission reductions achieved, provided overall SIP

commitments are met. 

4. Permanent - Emission reductions produced by the VMEP must continue at least for as long

as the time period in which they are used by applicable SIP demonstrations. The VMEP need

not continue forever to generate permanent emissions reductions, but must specify an appropriate

period of implementation in the SIP. Voluntary actions in such a program, and the resulting

emission reductions, can be discrete (temporary) or continuous, depending on the nature of the

program. For example, an ozone action day program which takes effect over an ozone season,

but calls for specific actions on days when exceedences of the ozone standard are likely (i.e.,

episodic measures) is considered a continuous program producing discrete (temporary)

reductions, and therefore the reductions are SIP creditable.

5. Adequately Supported - As with all SIP creditable programs, VMEPs must demonstrate

adequate personnel and program resources to implement the program.

Approval of Episodic Measures

EPA has concluded that episodic transportation control measures and other mobile source

related market response measures may be approved for SIP credit under the Act. Prior to the

1990 amendments to the Act, EPA believed that section 123 of the Act, which bars the use of

dispersion techniques in calculating emission limitations, might apply to all control measures,

including transportation and mobile source market controls. However, new language was added

to the Act in the 1990 amendments that EPA believes indicates a clear congressional intent to 

allow and even require the incorporation of episodic transportation and mobile source market 
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response programs in SIPs.

Several new requirements added to the Act in 1990 specifically require adoption of

transportation control measures as listed in section 108(f)(l) of the Act under certain

circumstances. See, for example, section 182(c)(5) - Transportation Controls and section

182(d)(1) - Vehicle Miles Traveled. Section 108(e) and (f) authorizes EPA to issue guidance on

various types of transportation control measures available for selection in the control programs

required under section 182. Section 108(f)(1)(B) identifies methods that contribute to reductions

in mobile source related pollutants during periods in which a primary NAAQS will be exceeded. 

Episodic transportation and market response measures designed to operate during periods when

ambient pollution levels are anticipated to exceed the NAAQS clearly fall within the scope of

these types of programs that Congress has authorized areas to include in their section 182

transportation and vehicle miles traveled programs. 

EPA therefore concludes that any implication that section 123 may have applied to

transportation and mobile source market response programs under the Act as amended in 1977

has been clarified by the Act as more recently amended in 1990 by the addition of the specific

authorization for adoption of any program identified in section 108(f) under the transportation

control programs required under section 182.

Technical Support for VMEPs

A State may take credit in its SIP for VMEPs only if they are quantifiable. VMEPs which

are thought to be directionally sound, but for which quantification is not possible cannot be

granted credit. EPA believes that carefully designed and implemented VMEPs are quantifiable

to the extent necessary to grant SIP credit. 

All VMEP submittals must include documentation which clearly states how the sources

from which the reductions are occurring, are currently, or will be addressed in the emissions

inventory, ROP plan, and attainment or maintenance plan, as applicable. This documentation

should include a description of the assumptions used in estimating and tracking emissions and

emissions reductions from affected sources.

The following sections are intended to provide general guidance on the elements of

emission reduction calculation and evaluation procedures that must be addressed in a VMEP SIP

submittal.
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Emission Reduction Calculation

To receive SIP credit for a VMEP, the SIP submittal must contain a good faith estimate

of emission reductions, including technical support documentation for the conclusion that the

measure will produce the anticipated emission reductions. VMEP emission reduction

calculations must account for and be adjusted to reflect uncertainties in the program. The

calculations must be adjusted to account for two types of uncertainty:

compliance uncertainty - the extent to which the responsible party (a public or

private entity) will fully implement the VMEP program, and

programmatic uncertainty - the extent to which voluntary responses actually occur

and/or the inherent uncertainties of program design. 

The State must adjust the VMEP calculation for compliance and programmatic

uncertainty, based on program design elements, and on the predictive quality of the information,

data, and analytic methodology used by the State to develop the projected emission reductions. 

The State must justify the appropriateness of the adjustments in its VMEP SIP submittal, usually

as part of the technical support document.

The adjusted emission reduction estimate should be developed and justified by the State

by taking into account various elements of the VMEP program design. These elements could

include, but not be limited to: the voluntary mechanism upon which the program is based, such

as public outreach or reduced fares; the variability in emission rates from affected mobile

sources; the extent of uncertainty in the emissions quantification procedure; and the frequency

and type of program evaluation, monitoring, record keeping and reporting.

Evaluation Reporting Procedures

States which use VMEPs in their SIP must describe how they plan to evaluate program

implementation and report on program results in terms of actual emissions reductions. Program

evaluation provisions for VMEPs must be accompanied by procedures designed to compare

projected emission reductions with actual emissions reductions achieved. The timing of the

evaluations must be specified in the VMEP SIP submittal. The States and program sponsors will

benefit from accurate and complete evaluation reports. EPA expects that program evaluations

and experience gained over time will result in VMEP modifications to increase effectiveness. 

The State must provide timely post-evaluation reports to the EPA relevant to the SIP

time-frame in which the emission reductions are being used. These reports may be used by EPA

for the purpose of reviewing subsequent SIP submissions required by the CAA, including but not

limited to: periodic inventories, rate of progress (milestone compliance demonstrations),

attainment demonstrations, and maintenance demonstrations.
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EPA is working with State and local government representatives to develop

methodologies which would provide sufficient technical support for VMEP SIP submissions. As

results become available, EPA will provide technical guidance to assist in the development of

VMEP emission reduction estimates and program evaluation procedures. However, EPA’s

policy is to recognize the experience of State and local voluntary programs in quantifying

emission reductions and evaluating program results. Acceptable methodologies and procedures

will not be limited to those developed by EPA, and programs are encouraged to discuss

technically sound alternative methods with EPA Regional Office staff.

VMEP Emission Reduction Use

As explained above, under Title I of the Clean Air Act, EPA is permitting a limited

amount of voluntary mobile source measures to be included in SIPs and FIPs and to be adopted

for any criteria pollutant in both nonattainment and attainment areas. VMEP emission reductions

shall be limited in use as determined by existing applicable SIP policy including offsets, Rate of

Progress, attainment demonstrations, baseline determinations, redesignation and maintenance

demonstrations. 

Future Guidance and Regional Coordination

It is incumbent upon EPA Regional Offices and Headquarters to coordinate the

implementation of this policy through consultation and exchange of information. It will be

necessary to determine the appropriateness of individual VMEPs, applicability of emission

reductions, development of methodologies to estimate emission reductions (including the

appropriateness of uncertainty adjustments), peer review, and standardization of policy. To the

extent that issues cannot be resolved through ongoing coordination efforts between Regional and

Headquarter offices, issues may be ultimately raised through the SIP consistency process. EPA

encourages early consultation between project sponsors, planners, and EPA’s Regional offices

during the development of VMEPs.

For further information on EPA’s policy on VMEPs or the guidance set forth in this

memorandum, contact Michael Ball of the Office of Mobile Sources, at 313-741-7897.

Attachments
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Attachment 1

Examples of Voluntary Mobile Source

Emission Reduction Programs

The following are some examples which are representative of voluntary mobile source emission

reduction programs (VMEPs) that could be implemented and credited with emission reductions

for SIP related purposes. These programs can and have been designed to be implemented on an

episodic, seasonal, or a continual basis. More program examples and ideas may be found on the

following websites:

EPA Office of Mobile Source Smart Travel Resources Center web site

(www.epa.gov/omswww/strc.htm)

Market Incentive Resource Center (www.epa.gov/omswww/market.htm)

Episodic Measures Database (www.epa.gov/omswww/reports/episodic/study/htm)

Employer Based Transportation Management Programs

Various programs implemented by employers to manage the commute and travel

behavior of employees, such as: van pooling, car pooling, subscription buses, walking,

shuttle services, guaranteed rides home, alternative work schedules, financial

incentives(transit passes and subsidies) and on-site TDM support.

Work Schedule Changes

Changes in work schedules to provide flexibility to employees to commute

outside of peak travel periods, such as: telecommuting, flextime, compressed work

weeks, staggered work hours.

Area-wide Rideshare Incentives

Promotional assistance aimed at encouraging commuters to use alternatives to

single occupant vehicles, such as: marketing of ridesharing services, transit station

shuttles, computerized carpool matching, vanpool matching, program implementation

assistance.

Parking Management

Management of parking supply and demand, such as: preferential parking

locations for carpools and vanpools, preferential parking prices for carpools and

vanpools, fee structures that discourage commuter parking, reduced parking for new

developments.
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Special Event Travel Demand Management

Special plans to manage travel demand in effect during special events, defined as

destinations for a large number of vehicle trips which occur on a one-time, infrequent, or

scheduled basis(such as athletic events, festivals, and major entertainment performances). 

These measures could include parking management, remote parking connecting with

transit or shuttle services, efficient traffic routing efforts, public information and

communications systems. 

Vehicle Use Limitations/Restrictions

Techniques to limit vehicle activity in a given geographic area or specified time

period, such as: auto restricted zones, pedestrian malls, traffic calming, no-drive days,

commercial truck restrictions on parking and idling.

Reduced Vehicle Idling

Measures to reduce the amount of time which vehicles spend in idle modes as part

of their overall operation, such as: reduced operations of drive-thru facilities such as

banks and fast-food restaurants, reduced construction of drive-thru facilities, programs

that facilitate reducing idling at truck stops, transfer facilities and loading docks at

commercial developments.

Small Engine and Recreational Vehicle Programs

Measures targeted at reducing the frequency and duration of small engine and

recreational vehicle use. Other programs aim to shift the time period in which emissions

producing activities, such as lawn and landscape maintenance, take place so that the

negative impact on air quality is reduced. These measures are usually associated with

episodic or seasonal control programs with a significant component of public education

and outreach to encourage the voluntary change in activities.
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Attachment 2

Example of a Voluntary Program

Program scenario: A State air quality agency is approached by a public utility to begin a

lawn mower buy back program. The State would like to take credit for the emissions reductions

from this private sector activity in it’s 15% plan. 

Up-front credit: The State would like to take credit predicting the effect of the program

in reducing emissions associated with replacing uncontrolled lawnmower emissions with electric

-- non polluting lawnmowers.

SIP Submittal

General Process

C State notifies EPA of it’s intent to take credit for voluntary lawnmower program. 

Includes program information and technical support documentation and commitment to

remedy any emission reduction shortfall in a timely manner.

C Regional Office reviews and approves up-front credit after comments.

C Activity is conducted by the public utility.

C State verifies that the program achieved the predicted benefits and generates 

information for EPA review.

C Regional Office reviews the State SIP submission and determines that the credits have 

been achieved as predicted. Also approved under milestone compliance.

Program Identification: State submits to EPA its intent to conduct or take credit for the

voluntary lawn mower buy back program in the SIP. The State will describe how the program or

activity will work in practice. In the submission, the State will describe the following program

elements.

Program participants

How the program works

Activity effects

Emission effects

State commitment for evaluation, reporting, remedying emission credit shortfall

Technical support documentation

Program Participants The State will identify the sponsors of the program. In this case the

public utility. 

How the Program Works As part of the submittal the State will include a description of the
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basic program, predicted effect of the program on a given NAAQS criteria pollutant and a

commitment to evaluate the program over the desired period of implementation and remedy any

emission reduction shortfall in a timely manner. 

In the submittal, the State describes the basic program including how the utility intends to

facilitate the activity-- buy back of lawn mowers. On three consecutive Saturdays, the utility

customers and employees are able to bring in their gasoline powered lawnmowers and receive a

voucher toward the purchase of any new electric lawnmower.

Activity Effects The State will submit predicted and observed activity effects. Data will be

generated and analyzed which examines the predicted and actual effect of the program.

In this case, using information provided by the utility, the State estimates that 2000 lawnmowers

would be replaced by non-polluting electric mowers. 

Emission Effects Activity effects ultimately are translated into emissions benefit calculations

(usually in tons per day\per year).

The State would be given up-front credit for emission reductions in terms of HC, CO and other

NAAQS criteria pollutants for 2000 mowers being replaced by electric mowers.

State Commitment for Evaluation, Reporting, and Addressing Credit Shortfall The State

will be responsible for ensuring that data will be collected regarding participation and the

effectiveness of the program. In addition, the State must commit to remedy any SIP credit

shortfall in a timely manner if the voluntary measure does not achieve projected emission

reductions. 

The State, as part of the evaluation and reporting commitment, submits to EPA a comparison of

the predicted effect of the program with the actual observed levels. In this example the utility

finds that 2000 mowers were replaced. Thus, the predicted reductions were achieved.

Technical Support Documentation The State will submit Technical Support Documents

describing the program and the methodology for predicting emissions benefits. Where possible

the State should identify data collection methodologies and information necessary for describing

implementation, compliance, effectiveness and other relevant information. This information

should account for the following:

 

Programmatic Uncertainty- Because the program will be voluntary in nature, the State

will be responsible for submitting to EPA the predicted and, eventually, the actual participation

levels. 
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Analytic Methodology- The State will describe how they estimated participation levels

and the effect of the activity on emissions