COALITION FOR CLEAN AIR 

COMMUNITIES FOR A BETTER ENVIRONMENT 

ENDANGERED HABITATS LEAGUE 

ENVIRONMENTAL DEFENSE 

ENVIRONMENT NOW 

NATURAL RESOURCES DEFENSE COUNCIL 

 December 1, 2006 

Via Email and U.S.P.S. 

Mr. Joseph Cassmassi 

Planning and Rules Manager 

South Coast Air Quality Management District 

21865 Copley Dr. 

Diamond Bar, CA 91765 

jcassmassi@aqmd.gov 

Dear Mr. Cassmassi: 

On behalf of the undersigned groups, we provide initial comments on the South Coast Air 

Quality Management District (“AQMD” or “District”) Draft 2007 Air Quality Management Plan 

(“AQMP”). We appreciate the opportunity to comment on this draft early in the process. We 

look forward to further participation in developing the AQMP, and request that the suggestions 

in this letter be incorporated into subsequent versions of the document. Given the length and 

expansiveness of the draft AQMP, these comments solely serve as our initial comments on the 

draft plan. We will provide further comments later in the process. Further, while we focused our 

comments on select issues, we reserve the right to provide additional comments on measures and 

issues not touched on in this letter. 

Our comments are organized into seven main sections: Section I discusses the extent to which 

the District has relied on “black box” reductions and why use of the black box should be kept to 

a minimum. Section II discusses the ways the District’s new technology provisions do not meet 

Clean Air Act (“CAA”) criteria. In Section III, we comment on specific short and mid-term 

measures. Section IV highlights the specific problems that stationary sources, in particular, pose 

with respect to environmental justice considerations. In Section V, we comment on the District’s 

on-road mobile source reduction measures. Section VI concerns ways in which the District may 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 2 of 26 

compel action from other responsible agencies, and Section VII offers additional measures that 

the District should consider including in the AQMP. 

I. AQMD Should Minimize Its Reliance On “Black Box” Emissions Reductions. 

As it did in its 1994, 1997 and 2003 AQMPs, the District relies significantly on vague control 

measures that, presumably, will be based upon new technology and/or improvement of existing 

technology, “which cannot be specifically defined at this time.”1

 In our view, Section 182(e)(5) 

of the CAA (“Section 182(e)(5)”) offers the District and its residents an unfavorable trade-off. 

While use of these undefined “black box” reductions might make it easier for AQMD or the 

California Air Resources Board (“CARB”) to get a State Implementation Plan (“SIP”) revision 

approved in the short term, in reality, it constitutes little more than a deferral of AQMD/CARB 

responsibility to achieve the federal standards, during which time residents of the South Coast 

Air Basin (“SCAB” or “Basin”) will continue to breathe dangerously high levels of air 

pollutants. Moreover, as the AQMD is well aware, in exchange for the re-designation from 

“severe” to “extreme” nonattainment status that is necessary in order to use the black box 

provision, Section 182(e)(5) imposes stricter reasonable further progress requirements, a higher 

threshold for satisfaction of applicable offset requirements, and a more expansive definition of 

the “major stationary sources” that would require special permits.2 

In addition to strongly objecting to the use of black box reductions, we are concerned about the 

estimated size of the black box. Of the 186 tons per day (“tpd”) reduction of NOx needed to meet 

the 2021 deadline, 40 tpd, or 14%, has been attributed to black-box control measures. While this 

is significantly less than the District’s previous estimate in its 2003 AQMP (76% of NOx 

emissions allocated to black box), it still is too high. Similarly, out of an overall VOC reduction 

target of 300 tpd, a whopping 135 tpd have been tossed into the box, which translates to a 45% 

reliance on loosely-defined speculative measures. Although this too is less than the 

corresponding figure offered in the 2003 AQMP (71% of VOC reductions allocated to black 

box), it is still much too high, especially considering that the District’s black box estimates are 

merely best-case scenarios. That is, the AQMD’s estimates of 45% VOC black box emissions 

and 14% NOx black box emissions reflect the proportions “after implementation of the shortterm and mid-term control measures.”3

 Thus, AQMD’s black box allocation figures reflect 

emissions remaining after successful implementation not only of the District’s stationary and 

mobile source control measures, but also all 26 recommended state and federal control measures. 

As it is unlikely that CARB and the Environmental Protection Agency (“EPA”) will collectively 

adopt all of the recommended measures, the actual black box allocations of both VOCs and NOx 

will likely be higher than the provided estimates. The AQMP should reflect this fact. 

In short, while we recognize the enormous task the AQMD is faced with, it is best, for both the 

District and its residents, to work with CARB, the Southern California Association of 

Governments (“SCAG”), and EPA towards full attainment status in the present instead of 

 

1

 Draft 2007 AQMP, at 4-48. 

2

 42 U.S.C. § 7511a(e). 

3

 Draft 2007 AQMP, at 4-48. 
Mr. Joseph Cassmassi 

December 1, 2006 

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delaying reduction efforts until some later unspecified time. Thus, we urge AQMD to re-evaluate 

and strengthen its mid-term and short-term measures and ensure that CARB, SCAG, and EPA 

take measures to achieve the necessary reductions. The District’s discussion of “Recommended 

State and Federal Stationary and Mobile Source Control Measures” in Appendix IV-B is a good 

first step. If the District insists on using the black box, the numbers must be reduced to as small 

as possible instead of relying on unspecified reductions in the future. 

II. All Section 182(e)(5) Measures Must Meet CAA Criteria to Support the Attainment 

Demonstration. 

 

Approval of the attainment demonstration cannot occur unless the Section 182(e)(5) measures 

comply with the CAA, including requirements that the measures (1) contain sufficient definition; 

(2) contain schedules for development of the new technologies; (3) contain commitments for 

funding; (4) depend on development of new technologies; and (5) are accompanied by 

enforceable commitments to develop and adopt necessary contingency measures.4

 

A. The AQMP Fails to Sufficiently Define its Long-Term Control 

Measures. 

Most of the new technology measures in the current draft of the AQMP contain only vague 

descriptions of potential technologies, without any discussion of what steps will be taken for 

their financing and development. Even though, by their very nature, black box reductions are 

vague, there still needs to be a more concrete description of the potential technologies and the 

steps the District will take to reach attainment. 

B. The AQMP Fails to Include Schedules For Development of the “New 

Technology” Measures. 

A SIP must contain schedules outlining both “the steps leading to final development and 

adoption of the [new technology] measure(s)” and also “each phase in the development and 

adoption” of the new technology control measures.5

 The current draft of the AQMP fails, 

however, to include a discussion of these steps, instead offering little more than vague assurance 

that an annual technology assessment workshop will identify “the latest technology 

improvements and process changes.”6

 This does not constitute a sufficient timetable regarding 

the development of new technology. For example, the District’s stated plan to conduct studies 

“to evaluate the reactivity of VOC compounds” neglects to include a schedule or timetable 

regarding the development of such technology. Specifically, LTM-01, the long-term measure for 

which such reactivity studies would be the most useful, is itself likewise silent as to the steps 

taken that might lead to the development or applicability of these less reactive compounds. The 

AQMD’s discussion of this measure instead provides only that the use of such compounds 

should “be evaluated and considered in future rulemakings... in order to provide a viable 

 

4 See CAA § 182(e)(5), 42 U.S.C. § 7511a(e)(5); 62 Fed.Reg. 1150, 1179 (Jan. 8, 1997. 

5

 57 Fed. Reg. 13,524 (April 16, 1992); 62 Fed. Reg. 1179 (Jan. 8, 1997). 

6

 Draft 2007 AQMP, at 4-49, 4-50 
Mr. Joseph Cassmassi 

December 1, 2006 

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compliance option.” At most, LTM-01 only anticipates that it would require certain coatings to 

be formulated with acetone reactivity-equivalent materials “beginning in 2015.” This date sets 

forth only the time by which regulated parties are to comply with the rule; it offers nothing 

regarding the development of the new less reactive compounds. A single deadline date of “2015” 

cannot constitute a description of the steps “leading to final development” of the technology as 

required by federal regulation. 

C. The AQMP Does Not Commit to Funding the Development of the 

New Technologies. 

As EPA made clear in its approval of the 1994 SIP, the District must “define the long-term 

measures more precisely with respect to...evidence of adequate resources committed to the 

activities, and opportunities for the public to be informed and involved in the process.”7

Moreover, a plan for black box measures “must contain commitments from those agencies that 

would be involved in developing and implementing the schedule for the measure.”8

 

While the AQMP includes brief descriptions of various advanced technologies that may be 

explored in the future and recognizes that the plan for black box emission reductions will require 

aggressive development, the document fails to mention (1) whether the District in fact has 

readily-available resources to fund necessary research and development of new technologies; (2) 

a projection of how much funding can be allocated to advanced technologies, either individually 

or collectively; (3) the source of such funding; or (4) that AQMD is definitively committed to the 

funding and implementation of the measures. If the black box VOC and NOx emission 

reductions are to be realized, the AQMD and CARB must firmly and unambiguously commit to 

identify and allocate funding to assist in the necessary research and demonstration projects. 

D. The AQMP Fails to Demonstrate that the “New Technology 

Measures” Depend on the Development of New Technologies. 

Under the plain terms of Section 182(e)(5), a black box emissions reduction measure must 

“anticipate development of new control techniques or improvement of existing control 

technologies.” That is, the plan “must show that the long-term measures cannot be fully 

developed and adopted by the submittal date” because additional time is needed to develop a 

complex or conceptual technology.9

 However, many of the proposed long term measures do not 

meet this criterion. For example, as currently drafted, LTM-02 (Further Emission Reductions 

From NOx RECLAIM Facilities) does not meet this standard. Under “Phase I” of this measure, 

“RECLAIM allocations will be reduced to offset the potential emission increases due to the 

introduction of natural gas with a Wobbe Index greater than 1360.”10 Phase 1, which is targeted 

at reducing increased NOx emissions as soon as 2008 does not appear to require complex or 

conceptual technology. The rule thus offers little more than the possibility that the AQMD will 

 

7

 62 Fed. Reg. 1179 (Jan. 8, 1997). 

8

 57 Fed. Reg. 13,524 (April 16, 1992). 

9

 57 Fed. Reg. 13,524 (April 16, 1992). 

10 Draft 2007 AQMP, at IV-A-134. 
Mr. Joseph Cassmassi 

December 1, 2006 

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amend the current NOx RECLAIM program to offset anticipated NOx emission increases. The 

plan therefore constitutes neither a “new control technique” nor an “improvement of existing 

control technology,” as required under Section 182(e)(5). 

E. The AQMP Must Include Enforceable Commitments to Develop 

Contingency Measures. 

When a SIP takes credit for emissions reductions from anticipated future technologies, it must 

also include “enforceable commitments to develop and adopt contingency measures to be 

implemented . . . if the anticipated technologies do not achieve the planned reductions.”11 These 

measures “shall be adequate to produce emissions reductions sufficient, in conjunction with 

other plan provisions” to achieve the applicable reasonable further progress reductions.12 

While we are aware that the AQMD is planning to dedicate Chapter 9 of the Final 2007 AQMP 

to a discussion of contingency measures, we remind the AQMD that the contingency measure 

requirements set out in CAA Section172(c)(9) are generally applicable to all nonattainment 

plans. Those specified in Section 182(e)(5) are specifically applicable to areas designated as 

being in “extreme” nonattainment. Therefore, if AQMD pursues its plan to request a 

redesignation to extreme nonattainment status, not only will it have to provide contingency 

measures for Section 172(c)(9), but it will also have to submit an “enforceable commitment to 

develop and adopt” contingency measures under Section 182(e)(5).13 

III. Specific Comments on Various Proposed Short and Mid-Term Measures 

BCM 04—Additional PM Emissions Reductions from Rule 444 

We are pleased that the district is addressing open burning from agricultural sources and is 

considering banning such burning. However, the timeline the district proposes—phasing out 

burning by 2015—is unnecessarily long. Open burning by most agricultural sources will be 

banned in the San Joaquin Valley in 2010. Already, agriculturalists have proven they can quickly 

adapt to this ban and, as is normal within this industrial sector, farmers in other parts of the state 

have begun to adapt practices similar to those required in the San Joaquin Valley. It makes no 

sense for the South Coast district to proceed as though it is inventing a new rule that an industry 

has no experience understanding or meeting. The South Coast should phase out agricultural 

burning by 2012. 

 

11 42 U.S.C. § 7511a(e)(5)(B). 

12 Id.

13 57 Fed. Reg. 13,524 (April 16, 1992) (“plan must contain a commitment to develop and submit 

contingency measures (in addition to those otherwise required for the area)”). 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 6 of 26 

MCS 05—Emissions Reductions from Non-Dairy Livestock Waste 

This rule should not rely on a list of Rule 223’s “interim BARCT guidelines” (all of which will 

vary in their respective abilities to reduce emissions), but instead employ the most efficient 

control method that meets existing cost-effectiveness criteria wherever it is known to be feasible. 

Accordingly, the District should commit to develop clearly-defined BARCT not just for poultry 

facilities, but for swine facilities and those holding any other type of livestock for which no 

BARCT is yet defined. For example, with respect to swine facilities, filters could be fitted to 

ventilation systems in enclosed facilities, and open-sided facilities with natural ventilation could 

be required to flush or scrape manure frequently. Manure should be collected into enclosed and 

fully controlled vessels (such as lagoons, tanks, etc.). The District should also ensure that the 

BARCT will address all precursor pollutants, including VOCs, PM and NH3. 

In any case, and at a minimum, the AQMP should clarify that the rule, in its current form, would 

mandate all of the Rule 223 Class Two Mitigation Measures for larger facilities and all of the 

Class One Mitigation Measures for smaller facilities, rather than allowing covered parties to 

choose which measures to implement. 

Lastly, the AQMD must revise the emissions inventory to account for those operations with high 

emission factors from NH3, as discussed in the AQMP at page IV-A-87. 

EGM-01 – Emission Reductions from New or Redevelopment Projects 

The SCAB is an economically vigorous region that is projected to continue growing through new 

development and redevelopment. This growth, according to projections from SCAG and other 

transportation and planning agencies in the Basin, will be accompanied by greater traffic, vehicle 

miles traveled, construction, and goods delivery linked to these new and redevelopment projects. 

This will inevitably lead to a growth in air pollution that could diminish gains made in pollution 

control through previously adopted and currently proposed measures and technology 

improvements. 

The AQMP’s measure EGM-01 suggests the District will explore the potential for reducing 

indirect emissions by gathering a stakeholder group. The District leaves the emissions goal of 

EGM-01 rule effectively open ended, giving the impression that the indirect source measure will 

reduce whatever amount of pollution the stakeholder group can agree it should reduce. This is an 

unacceptable approach. 

We urge the District to establish in subsequent drafts of the AQMP a realistic minimum 

emissions reduction goal to be achieved through a robust indirect source rule. This minimum 

should reflect at the very least what is necessary to control future indirect source pollution to 

maintain gains made in air quality through previously adopted and currently proposed measures 

and technology improvements. Notably, the San Joaquin Valley rule is expected to reduce 

emissions by more than 10 tons per day in the year 2010. A larger district like the AQMD should 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 7 of 26 

be able to reduce even more emissions with an indirect source rule and the AQMP should reflect 

this.14

Further, seeking advice from a stakeholder group that includes community members, including 

air quality advocates, during development of the rule is wise. But the notion of forming a 

stakeholder group does not qualify as a reduction measure required by the SIP. Additionally, the 

future activities of a stakeholder group cannot be allowed to delay rule development, public 

discourse about a proposed rule through the workshop and hearing process, or adoption or 

implementation of a rule. The AQMP should outline a calendar for an indirect source rule 

development to ensure no unnecessary delays occur. 

Lastly, voluntary approaches for reducing emissions through CEQA-related activities should be 

encouraged. But they should be viewed as uncertain supplements to any reductions achieved 

through an indirect source rule. 

MOB-02—Extended Exchange Program 

We are pleased to see that the District is considering expanding their SORE program to include 

recreational outboard engines. We strongly encourage the District to do so and consider 

additional approaches to accelerate the turnover of recreational craft. 

 

State law allows local public agencies to regulate boating in certain categories. Three of these 

categories (speed zones, special-use areas, and sanitation and pollution control) are relevant to 

the regulation of personal water craft and/or two-stroke engines. It is our understanding that 

many waterways have banned personal water craft all together, but others have come up with 

more creative alternatives: 

- The Anderson and Calero Reservoirs in the Santa Clara Valley Water District have 

prohibited pleasure craft (“PC”) entirely but allow powerboats if they have a receipt 

issued within the past two days from any of five area stations selling non-MTBE gas. 

- Other lakes, such as Coyote Lake, have placed a cap on the number of PC allowed in 

the lake each day. 

- Lake Tahoe, Cascade, Fallen Leaf, and Echo Lake require that motorboats meet 2001 

ARB emissions standards and ban carbureted and non-direct injection engines. 

- The San Pablo Reservoir in the East Bay Municipal Utilities District only allows 

four-stroke or equivalent emissions level engines.15

We strongly encourage the District to explore these strategies and include them in the AQMP. 

Additionally, as we recommend in our comments on OFFRD-02, the District should employ day 

 

14 The Control Measure Summary chart on page IV-A-101 indicates a modest estimate of emissions 

reductions, and we are concerned that the District is only considering adopting a weak indirect source 

review rule for new redevelopment projects. 

15 California Department of Boating and Waterways, Local Restrictions on Personal Watercraft and/or 

Two Stroke Engines, available at http://www.dbw.ca.gov/MTBEList.htm (last visited Apr. 7, 2004). 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 8 of 26 

use fees at prominent recreational marine sites that can help generate incentive funds to augment 

the SORE program. 

MOB-03—Backstop Measure for Indirect Source of Emissions from Ports and PortRelated Facilities 

As the AQMD’s figures demonstrate, collective emissions from the Ports of Los Angeles and 

Long Beach (collectively, “Ports”) represent the single largest source of emissions in the 

SCAB.16 Since reducing Port emissions is essential for the Basin to have a chance to meet the 

ozone and PM2.5 deadlines, we are extremely pleased that the AQMP includes Measure MOB03, consisting of three “Backstop Measures.”17 Initially, however, we are concerned that the Port 

Standards, namely the AQMD’s planned reduction of year 2011 NOx, SOx and diesel PM may 

be less stringent than the goals set forth in CARB’s Emission Reduction Plan for Ports and 

Goods Movement (ERP).18 The ERP includes a goal to reduce 2010 emissions down to 2001 

levels,19 while the AQMP’s Port Standards call for a reduction of year 2011 NOx, SOx and 

diesel PM emissions to 2001 levels.20 While the AQMP goes on to state that “[i]n order to assure 

early progress and consistent [sic] with goals stated in CARB’s Emission Reduction Plan . . ., the 

milestones for the year 2011 will be below emissions in the year 2001,”21 it is nonetheless 

unclear whether the AQMP’s proposed Port Standards are equally aggressive as the goals set 

forth in the ERP. We ask AQMD to clarify this important standard in subsequent drafts of the 

AQMP and ensure consistency between the plans. Below, we provide comments on the specific 

backstop measures. 

A. Backstop Measure No. 1 

We support a plan to use milestones to assist with the achievement of the mass emissions targets. 

However, the AQMD’s plan to calculate milestones triennially provides too long of a timeframe, and could result in this measure kicking in too late. Port sources exceeding the target rate 

of emissions could conceivably continue emitting pollutants at an excessive rate for 2 or 3 years 

until the next triennial milestone testing period. In order to keep the District and the Ports on 

pace and better informed of their progress towards the Port Standards, Port source emissions 

should be evaluated against annual milestones, rather than at three-year intervals. Moreover, as 

the ERP concludes, goods movement activities cause 2400 premature deaths annually, with 50 

percent of those deaths occurring in the SCAB.22 Accordingly, each year that goes by without 

significant improvements in air quality presents real life consequences for individuals in this 

 

16 Draft 2007 AQMP, at ES-7. By 2020, Ports will account for 73% of SOx, 24% of NOx, and 10% of 

PM2.5 by 2020. 

17 The AQMD has estimated that Port-related sources will need to reduce NOx emissions by 59%, SOx 

emissions by 97%, and PM2.5 emissions by 57% to attain PM2.5 standards. 

18 CARB Emissions Reduction Plan, at 38; Goods Movement Action Plan: Phase 1 Foundations, at I-5. 

19 Id.

20 Draft 2007 AQMP, at IV-A-122. 

21 Id. at IV-A-123. 

22 CARB ERP, at 4. 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 9 of 26 

region. Thus, any administrative difficulties associated with the yearly monitoring of Port 

emissions must be resolved in favor of achieving attainment and improving public health.

In any case, regardless of whether the backstop measure is triggered by a triennial or an annual 

milestone, the actual rule requirements must be strengthened by including clear enforcement 

mechanisms. In its current form, the AQMP offers two possibilities for backstop rule operation – 

“Option 1,” under which the Ports would be given leeway to allocate emission reduction 

requirements among their facility operators, and “Option 2,” under which the Ports would be 

required to submit their own Emission Control Plans to the District. Irrespective of which option 

the AQMD decides to implement, the proposal, as currently drafted, does not have an 

enforcement mechanism identified. The backstop measure says nothing about any penalties or 

fees under Option 2 that might compel the Ports to submit adequate Emission Control Plans. 

There is likewise no discussion of penalties under Option 1. The AQMP says only that a Port 

operator’s or Port’s failure to submit an adequate plan under Options 1 or 2 would “result in a 

violation of this rule.”23 The AQMP should clearly specify what enforcement procedures will be 

in place if the Ports do not meet the milestones and what penalties are in place if the Ports or 

facility operators do not comply with the backstop rules once they have been triggered. 

Moreover, in order to effectively deter violations, any fines or penalties established for violations 

of the rule must exceed the cost of compliance. 

 

Lastly, we note that the range of truck emissions sources covered by this rule actually differs 

from the range of sources that are identified in the Ports’ own Clean Air Action Plan (CAAP). 

Specifically, under the CAAP, trucks traveling to and from the ports are considered “port 

sources” up until their first drop-off destination,24 while AQMD port emissions sources under the 

Backstop Rules include trucks traveling to and from port-owned property at any location within 

the SCAB. Given the fact that the District’s backstop measures are conceived to help create 

incentives for the Port’s implementation of the CAAP,25 the AQMD should encourage the Ports’ 

CAAP to mimic the scope of emissions in the AQMP.

B. Backstop Measure No. 2 

This measure will also be crucial in curbing Port pollution. However, we are concerned that 

Backstop Measure No. 2, as currently drafted, is too vague and lacks clarity. Under this measure, 

the AQMD will establish triennial diesel PM milestones that the Ports must meet. For the same 

reasons discussed above regarding Backstop No. 1, a series of more frequent milestones should 

be employed. Further, the risk milestones (whether they are established triennially or otherwise) 

need to be further defined; the measure should specify whether the “risk” at issue here is 

occupational, individual, residential, or something else.26 Further, this measure does not specify 

 

23 Draft 2007 AQMP, at IV-A-124. 

24 San Pedro Bay Ports Clean Air Action Plan , at 12. 

25 Draft 2007 AQMP, at IV-A-122. 

26 Notably, the recent Draft EIR/EIS for the China Shipping Terminal (Berths 97-109) exemplifies how 

different residential versus occupational cancer risk can be. For example, while residential cancer risk 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 10 of 26 

whether the rule requirements are triggered if one port exceeds the 85% standard (as 

demonstrated by failure to meet milestones) or if diesel emissions from both ports, cumulatively, 

are sufficient to trigger the measure. Finally, insofar as Measure No. 2 “will be implemented in a 

fashion similar” to one of the two options offered for Measure No. 1, the comments raised under 

Backstop Measure No. 2 about enforcement apply. 

C. Backstop Measure No. 3 

We are especially pleased to see that Backstop Measure No. 3 will effectively require all Port 

projects not only to comply with applicable CEQA and NEPA requirements but also meet the 

additional Project Standards. This backstop measure should prove to be particularly important 

considering that in the near future alone, there are more than 10 massive expansion projects at 

the Port of Los Angeles and Long Beach that will have significant effects on air quality in the 

SCAB.27 At the same time, we recommend that the measure not defer the discussion of whether 

emissions increases should be offset for projects that exceed the nonattainment pollutant limits. 

It is imperative that emissions increases be offset for the Basin to ensure attainment and create 

appropriate incentives for responsible growth at the Ports. This measure will hopefully ensure 

that the massive expansions at the Ports to not impede attainment of air quality standards. 

IV. Health Concerns and Environmental Justice Considerations Require Continued 

Emphasis on Stationary Sources. 

Health concerns and environmental justice considerations require continued emphasis on 

stationary sources, as these are often concentrated in low income communities of color. Due to 

the proximity of sources to homes and schools and the volume of air emissions from these 

sources, stationary sources often create disproportionate impacts than their size in the overall 

inventory indicates. Moreover, many of these sources also emit toxic air contaminates whose 

impacts are in the "near field"—that is those whose neighborhoods are adjacent to these sources. 

Therefore, the District, as the sole agency with regulatory control over stationary sources of air 

pollution, should focus its efforts on reducing the impacts from stationary sources in the most 

heavily impacted communities. Developing a strong cumulative impacts policy, ensuring 

compliance with Title V, enhancing inspection, and enforcement capacity are all keys both for 

meeting CAA goals and protecting community health. 

 

was reported as 9.9 in a million (under the significance threshold), occupational cancer risk was reported 

as 22 in a million (over double the significance threshold). DEIS/DEIR Berths 97-109, App. E, at 3. 

27 As an example, the Port of Los Angeles recently released the China Shipping EIR, which had 

considerable air quality impacts and exceeded SCAQMD’s NOx significance threshold by more than 50 

times. 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 11 of 26 

A. Compliance Flexibility Programs 

FLX-02—Petroleum Refinery Pilot Program 

Petroleum refineries are among the largest sources of criteria pollutants in the SCAB. In order 

for the District to meet CAA standards, those emissions must be reduced. The District should 

require further reductions from refineries, including requiring every emission source to be 

upgraded to the standard of the Lowest Achievable Emission Rate (LAER). In general, the 

LAER standard does not view cost as a limiting factor. Given that air quality improvements 

have stalled despite significant profit margins in the petroleum sector, the District should require 

refineries to reduce emissions to the maximum extent possible. This is a particularly appropriate 

time to require additional emissions reductions from these major pollution sources. 

In addition, we have concerns about the environmental justice impacts of a control measure that 

provides an alternative means of compliance to existing refineries by allowing them to achieve 

their emission reduction obligations by reducing emissions from off-site projects. We urge the 

District to increase reductions at the source itself. 

B. Rule Effectiveness of Stationary Source Control Measures, Rule 

Compliance Rate, Audit and Emission Inventories 

The District assumes that the “control measures proposed in [Appendix IV-A] with quantifiable 

emission reductions are based on a rule effectiveness of 100 percent.”28 However, “An 

Evaluation of The South Coast Air Quality Management District’s Air Pollution Control 

Program” prepared by CARB dated January 2000, (“Audit”), found a 65% compliance rate (i.e. 

35% noncompliance) for VOC emitting facilities inspected, which is below CARB’s target goal 

of 95% compliance. The categories that had failure rates in the Audit were VOC Sources (Metal 

Parts, Wood Products, All Other Sources), small boilers, cargo tanks, dry cleaners and gasoline 

stations. The District has adjusted petroleum marketing/gasoline stations’ base and future 

emissions by 75% for noncompliance, but no other category has been adjusted. The District 

should address this 35% noncompliance rate in the AQMP by adjusting the base and future 

emissions, or demonstrate how it has included measures to improve compliance. 

V. On-Road Mobile Source Emissions 

A. The Air Quality Challenge From On-Road Mobile Source Emissions 

Despite substantial progress in cleaning up Southern California’s air, the AQMP correctly 

recognizes that “the Basin still exceeds the federal 8-hour standard more frequently than any 

other location in the U.S.”29 Ambient levels of fine particulates—a particularly dangerous form 

of air pollution—are more than double the standard in some locations. 

 

28 Draft 2007 AQMP, at IV-A-6. 

29 Draft 2007 AQMP, at ES-3-4. 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 12 of 26 

Moreover, progress made so far may be evanescent. “Unless significant steps are taken to 

further control air pollution, growth will overwhelm much of the improvement expected from the 

existing control program.”30 And even the existing program is of questionable effectiveness: 

“Lack of significant progress in ozone air quality for the last several years has raised some 

concern regarding the present-day effectiveness of control programs.”31 

It is thus indisputable that to prevent backsliding—and to meet attainment goals for PM 2.5 and 

ozone—all sources of emissions, including those, such as light duty autos, where great progress 

has been made, must contribute substantial additional reductions. It simply will not be enough to 

go after the low-hanging fruit, such as dirty diesel trucks. 

It also is clear that emissions reductions must come not only from the tailpipe, but also from 

measures designed to reduce substantial projected growth in total travel. In 2002, cars and trucks 

traveled more than 349 million miles per day on the Basin’s roads. They are projected to travel 

about 407 million miles per day by the year 2020.32 These additional 58 million miles traveled 

per day will consume much of the gains from increased fuel efficiencies and more stringent 

tailpipe standards. 

Controlling growth in terms of vehicle-miles-traveled (“VMT”) is particularly critical to attain 

the PM 2.5 standard by 2015. Unlike other criteria pollutants, fine particulates from on-road 

mobile sources are heavily correlated with VMT, regardless of anticipated improvements in 

vehicle and fuel technology, fleet turnover rates, tailpipe standards, and other historically 

effective means of reducing vehicle emissions. This is because fine particulates are produced not 

only by combustion, but also by operation of the vehicle itself. Growth in PM 2.5 emissions 

from engine, tire and brake wear, as well as from re-entrainment of fine particulate deposition on 

roads, are roughly correlated with VMT growth. It is therefore not surprising that projected PM 

2.5 emissions from light duty autos are actually expected to increase in the future, even as cars 

supposedly get cleaner. Annual average emission of PM 2.5 from light duty autos climb from 

4.12 tons per day in 2005, to 4.449 tons per day by the year 2020.33 This increase is 

unacceptable, given the region’s obligation to essentially halve such emissions in the Basin by 

2015. 

The imperative to reduce vehicle related fine particulate emissions is not just legal; it’s a health 

and environmental justice issue. As the draft 2007 AQMP recognizes, “motor vehicles are a 

major source of ultrafine particulates” in the urban environment.34 High counts of particulates 

are found near freeways; substantially higher numbers of particles are found near the roadway, 

while a sharp reduction in particle count has been shown to occur within 100-300 meters 

downwind of the roadway.35

 

30 Draft 2007 AQMP, at 1-5. 

31 Draft 2007 AQMP, at ES-4. 

32 Draft 2007 AQMP, at 4-28. 

33 Draft 2007 AQMP, at 2-17 (Figure 2-9). 

34 Draft 2007 AQMP, at 11-2. 

35 Draft 2007 AQMP, at 11-2. 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 13 of 26 

Given the indisputable need to further address transportation-related emissions beyond what can 

be accomplished through state-mandated tailpipe emissions measures, it is incumbent upon the 

District, SCAG and local government to adopt aggressive new Transportation Control Measures 

to mitigate the effects of continued rapid VMT growth. 

B. On-Road Mobile Source Future Baseline Inventory 

We commend the District and CARB for its work in updating the 2002 Emissions Factors. The 

2007 Emissions Factors (EMFAC 2007) represent a substantial improvement over existing 

assumptions, particularly as applied to heavy duty vehicles.36 

We also commend the District for acknowledging the inherent uncertainty in predicting future 

mobile source emissions: 

Relative to future growth, there are many challenges with making accurate projections. 

For example, where vehicle trips will occur, the distribution between various modes of 

transportation (such as vehicle trucks and trains), as well as estimates for population 

growth and changes to the number and type of jobs – although they are forecast with the 

best information available; nevertheless, they contribute to the overall uncertainty in 

emission projections.37 

The District has not taken the next step, however, of building a “margin of safety” (perhaps of 

5% to 10%) into the on-road mobile source emissions inventory to account for potential 

underestimates of emissions loadings, particularly of oxides of nitrogen. 

The historical record more than justifies such a margin of safety. Both the 1998 and 2002 

Emissions Factors models were designed to account for underestimates in the prior model, 

notably to adjust for non-linear increases in NOx emissions, particularly at speeds over 35 mph 

that had not been accounted for. Consistent with this pattern, EMFAC 2007 has been developed 

in large part to account for underestimates in emissions from heavy duty vehicles. There is every 

reason to believe that the next iteration of the emissions factors model will follow a similar 

pattern of underestimating emissions. 

There are also well-known inadequacies in the ability of the model to accurately predict 

emissions. For example, to our knowledge the driving cycle model in EMFAC 2007 does not 

take into account the emissions impact of the Basin’s topography. Fuel consumption and engine 

combustion efficiency are fundamentally and adversely affected by hill climbing. Given the 

rugged nature of much of the Basin, a significant percentage of VMT will occur in these 

conditions, resulting in emissions not captured in the inventory. 

 

36 At the same time, we are still reviewing the EMFAC 2007 model because of concerns about other areas 

where emissions may have been underestimated. 

37 Draft 2007 AQMP, at III-1-2. 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 14 of 26 

Similarly, it is our understanding that the EMFAC 2007 model considers vehicle speeds in 

increments of 5 mph. That is, the emissions profile of a vehicle traveling at 35.3 mph is assumed 

identical to a vehicle traveling at 39.8 mph. This artificial assumption can result in substantial 

underestimates, since NOx emissions in particular are highly sensitive to speeds variations of 

less than 5 mph. 

Finally, there remain huge uncertainties in the art and science of accurately predicting VMT over 

long time periods. While we commend SCAG’s efforts in updating its travel demand model for 

the 2007/2008 RTP conformity cycle, it is not certain whether these updates will be fully 

incorporated into the emissions inventory for the AQMP. The AQMP states: 

Additionally, SCAG has been working with modeling experts and 

practitioners to develop a new Transportation Demand Model that is expected to more 

accurately forecast highway traffic volumes, speeds, and other aspects of the 

transportation system. The new Transportation Demand Model will be used for the Final 

2007 AQMP if available within the development schedule of the AQMP.

38 

If the new travel demand model is not available, then the AQMP must address how any 

underestimates in VMT projections identified in the model update will be corrected for in the 

AQMP. 

Also, in evaluating the adequacy of the travel demand model used, care should be taken that it 

incorporates the latest methodology relating to the measurement of travel demand that is induced 

by adding additional capacity to the network. Specifically, it has been empirically shown that 

capacity enhancements that reduce travel times facilitate new trips and lengthen existing trips in 

the short and medium term, thus adding to VMT and altering driving cycles (speeds, etc.) Long 

term changes in travel demand and therefore in VMT resulting from land use and development 

patterns facilitated by adding capacity must also be addressed. Even if the impact of these 

changes cannot be precisely measured, some allowance, or “margin of safety” must be built into 

the inventory to prevent underestimation. Historic underestimates in VMT growth projections as 

compared to historic patterns provides more than adequate justification for this. 

In sum, in formulating further refinements to the inventories for PM 2.5 and 8-hour ozone from 

on-road mobile sources, we believe that a conservative approach that incorporates a margin of 

safety is an appropriate means to avoid the impact of historic underestimates in mobile source 

emissions. 

 

C. Transportation Control Measures Must Include All Reasonably 

Available Control Measures. 

The AQMP’s approach toward transportation control measures is disappointing. In essence, the 

District proposes to rely only on those TCMs already contained in existing Regional 

Transportation Plans and Regional Transportation Improvement Programs. The AQMP states: 

 

38 Draft 2007 AQMP, at IV-C-43 (emphasis added). 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 15 of 26 

The long-term transportation planning requirements for emission reductions from on-road 

mobile sources within the Basin are met by SCAG’s Regional Transportation Plan (RTP) 

which is developed every four years with a 20-year planning horizon. The short-term 

implementation requirements of the Transportation Conformity Rule are met by SCAG’s 

biennial Regional Transportation Improvement Program (RTIP), the first two years of 

which are fiscally constrained and demonstrate timely implementation of a special 

category of transportation projects called Transportation Control Measures (TCMs).39

This modest (to say the least) approach is not surprising, in light of the District staff’s belief that 

they really don’t work. For example, the AQMP states that: 

[I]t should be recognized at the outset that potential improvements in air quality deriving 

from TCM and RTP strategies applied to on-road mobile sources are minimal. This is 

due to the fact that motor vehicle emissions have been substantially reduced through 

technology, individual TCMs affect only a small portion of regional travel, and that 

TCMs generally do not produce large scale changes in travel behavior.40

We believe the above approach–relying solely on already adopted TCMs already incorporated 

into existing transportation plans and programs—and the defeatist attitude that TCMs don’t 

work, are both flawed. Reasonably available TCM approaches have huge potential to reduce 

VMT and associated emissions at less cost than other measures. Moreover, by addressing 

vehicle use, TCMs have the potential to address simultaneously multiple problems facing our 

state, such as greenhouse gas emissions, petroleum dependency, loss of habitat and agricultural 

land, and quality of life. 

Below we suggest some approaches that we believe are reasonably available. 

D. Growth Management Strategies 

Researcher Keith Bartholomew surveyed members of the National Association of Regional 

Councils (NARC) in 2003-04 for examples of scenario planning using land use, transit, and other 

policies to reduce travel.41 Land use policies typically included density increases, clustering 

development in transit corridors or around rail stations, and urban limit lines. Both travel models 

and geographic information system evaluation tools were used in the scenario evaluations. The 

median reduction in VMT in the 20-year scenarios for 31 exercises with adequate data was 2.3% 

but 11 scenarios resulted in reductions of 5% or more. 

 

 

39 Draft 2007 AQMP, at 4-24. 

40 Draft 2007 AQMP, at IV-C-45 (emphasis added). 

41 Keith Bartholomew, Integrating Land Use Issues into Transportation Planning, Summary Report, 

DOT Cooperative Agreement No. DTFH61-03-H-00134. 2005. Dept. of Architecture, University of Utah. 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 16 of 26 

Five scenarios resulted in reductions of 10% or more, including the SCAG Region. These 

studies generally evaluated modest growth management policies and did not employ the pricing 

of parking or fuels or roadways. So, these results may be viewed as lower bounds on what VMT 

reductions could occur in scenario exercises. 

Example data from the projects are: 

- Arizona, Maricopa Association of Governments: ~ 3% VMT reduction in 20 years: 

- S.F. Bay Area Alliance for Sustainable Development: 4.6% reduction in VMT by 

2020. Most of the growth in this scenario is located in the existing urban cores of the 

region: 

- Georgia Regional Transportation Authority: 7% VMT reduction: 

- Baltimore Regional Transportation Board: 8.2% VMT reduction. Redevelopment was 

emphasized, road capacity maintained at current levels, and transit capacity 

moderately expanded: 

- Portland Metro: ~8.8% VMT reduction in 20 years (17.6% VMT reduction in 40 

yrs). Growth contained within urban growth boundary, plus auto pricing, transit 

investment, and pedestrian improvements: 

- Southern California Association of Governments: ~10% VMT reduction in 25 years. 

Housing and jobs focused in existing centers and corridors: 

- Denver Regional Council of Governments: 12.5% VMT reduction in 25 years. Most 

growth would locate in infill development sites within the central city and existing 

suburbs: 

- Envision Central Texas: ~17% VMT reduction compared to current trend. New 

growth in existing developed areas, which would accommodate 1/3 of anticipated 

new households and 2/3 of new jobs: 

- Contra Costa County, CA: 17.3% reduction in VMT in 20 years. Growth placed in 

existing urbanized areas, and along rail transit routes: 

- EPA, Atlanta, GA. ~38% difference in VMT between worse and best scenarios. 

These examples underscore the huge potential of land use to affect VMT growth rates, and 

therefore emissions. 

Indeed, SCAG has developed the Compass 2% Strategy, which dramatically reduces projected 

VMT while affecting just 2% of the land area of SCAG’s territory. While this Strategy as 

currently constituted does not merit emissions reductions credit as an enforceable TCM, it has 

the potential to become a powerful source of emissions reductions if proper commitments to 

implement it are obtained from the local jurisdictions responsible for implementation. The 

AQMP states that: 

Reductions in emissions due to changes in the socio-economic profile of the region are an 

important way of taking account of changes in land use patterns. For example, changes in 

jobs housing balance induced by changes in urban form and transit-oriented development 

induce changes in VMT by more closely linking housing to jobs. Thus, socio-economic 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 17 of 26 

growth forecasts are a key component to guide the Basin toward attainment of the 

NAAQS.42 

Thus, 

Of the benefits attributed to the 2004 RTP in year 2030, it was estimated that the 

Compass Vision distribution contributed approximately 50% of the VMT reduction, 

approximately 20% of the vehicle hours traveled (VHT) reduction, approximately 10% 

increased transit boarding, and approximately 70% of the reactive organic gas (ROG) 

emission reductions.43 

 

Current efforts to implement the Compass Strategy, however, consist of mere exhortations and 

technical assistance from regional planning staff.44 While these efforts are laudatory and 

important, they are not sufficient. 

Until such time as adequate implementation mechanisms are in place, the substantial reductions 

in projected VMT from the Compass Strategy cannot be assumed in the baseline emissions 

inventory for the current draft of the AQMP or for any conformity determination based on an 

emissions inventory where these reductions are assumed. Conversely, if such reductions are 

assumed in the inventory, then the Compass Strategy becomes a de facto TCM, the timely 

implementation of which must be shown as a precondition to the federal funding or approval of 

transportation plans, programs or projects. 

E. Fees And Pricing 

 

The use of fees and pricing to encourage sustainable transportation choices and to discourage 

unsustainable ones is a powerful way to obtain desired environmental benefits. By internalizing 

the social cost of these decisions through fees, the market provides a more rational outcome. 

 

42 Draft 2007 AQMP, at IV-C-6. 

43 Draft 2007 AQMP, at IV-C-8. 

44 “The following tasks critical to implementation have been underway since the adoption of the 2004 

RTP: (1) Initiating Compass demonstration projects in critical growth opportunity areas with member 

cities and Council of Governments and providing technical assistance for projects that exemplify one or 

more of the key principles of the Compass Vision; (2) Targeting local governments to align their plans 

with the Compass Vision and providing assistance and training support to communities developing or 

updating general, specific and redevelopment plans and pilot projects; (3) Providing local governments, 

subregions and transportation commissions with development screening, scenario planning and real estate 

analysis tools, e.g. LA LOTS (Land Use Opportunity Tracking System) and other inter-regional 

partnership program tools; (4) Conducting an extensive public education, training and outreach program 

that promotes incentive based initiatives supporting Compass goals, e.g., Pilot corridor programs and 

local success stories; (5) Establishing benchmarking, program assessment, evaluation and monitoring 

guidelines in collaboration with subregional councils of government, transportation commissions, local 

government partners, and other applicable stakeholders.” 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 18 of 26 

The AQMP appears to recognize this potential: 

Charging a vehicle miles traveled (VMT) or emission-based fee for higher mileage and 

higher emitting vehicles, respectively, is another example. A pilot project could be 

considered as a way of initiating and evaluating this type of strategy. A task force could 

be convened to further explore and evaluate demand-side strategies. To improve public 

acceptance, these programs can be designed to minimize the socioeconomic impacts on 

low-income residents of the Basin.45

We encourage the development of this and other fee based strategies, as they have been shown to 

be quite feasible and effective in many metropolitan areas of the world.46 

Adoption of growth management and pricing strategies, along with strategic investments in 

transit and other “hard” investments, will create critical synergies that can have a real and lasting 

impact on VMT and emissions. We will work actively with the District to explore ways in 

which the mechanisms can be feasibly applied in the Basin measures. 

VI. The Recommended State and Federal Control Measures Provide a Good Template 

for Other Agencies to Ensure They Reduce Their Fair Share of Pollutants. 

We are pleased that the AQMD has taken an initial attempt to outline measures that local, state 

and federal agencies should undertake to reduce emissions directly impacting the SCAB. 

Appendix IV-B is particularly helpful given that CARB will not release its State and federal 

strategy until January of 2007. Once CARB releases its proposed strategy, we encourage the 

District to extensively comment on CARB’s plan to make sure it reflects Appendix IV-B instead 

of a weaker pollution control roadmap. 

Below, we provide specific comments on the suggested control measures. In addition, we have a 

couple of overarching comments. First, we request that subsequent drafts of the AQMP provide 

greater specificity on the measures the District believes other agencies should adopt. For 

example, OFFRD-07 does not make clear exactly what the District is proposing. There are 

general comments about shore-side power, but the measure does not make clear what needs to 

happen to ensure use of this technology. It is critical that the District provide clear direction to 

CARB, EPA, and other agencies on the stringency of the measures needed to reach attainment. 

Second, AQMD should better articulate which agency should take the lead in implementing each 

measure. For example, in OFFRD-06, it is unclear which agency the District is calling upon to 

act—the marine ports, CARB, or EPA, or how the District recommends that these agencies 

coordinate to exert overlapping authority. Finally, we encourage collaboration with and 

strategies for agencies outside of the traditional air quality arena, such as SCAG, and local 

jurisdictions, such as the City of Los Angeles, to encourage land use planning decisions and 

 

45 Draft 2007 AQMP, at 4-64. 

46 See Robert A. Johnston, Professor, Dept. of Environmental Science & Policy, University of California 

Davis, Review of U.S. and European Regional Modeling Studies of Policies Intended to Reduce 

Motorized Travel, Fuel Use, and Emissions (August 2006) (attached hereto). 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 19 of 26 

demand management strategies that reduce vehicle miles traveled and zoning and citing of 

facilities to reduce health impacts to residents of surrounding communities. 

ONRD-12—Further Emissions Reductions from Heavy-Duty Trucks Providing 

Freight Drayage Services 

This control measure provides a good template for addressing drayage trucks at the Ports. 

However, as referenced above, the measure needs to be clearer about how implementation will 

work. It is unclear how the AQMD, the Ports, and CARB will work together to achieve the 

needed reductions in emissions. 

Further, we are pleased that the AQMP mentions advanced transportation systems.47 These 

technologies could prove to be a positive way to alleviate the pollution issues in the Basin from 

trucks and rail. In fact, given the explosive growth in goods movement, advanced transportation 

systems should not be viewed as a “parallel track,” but rather a suggested mode of action. The 

District should encourage cleaning up the existing truck fleet and promoting new technologies to 

dramatically reduce pollution, such as the Electric Cargo Conveyer or Freight Shuttle System. 

Alternative fuels should be strongly incentivized. For captive drayage trucks that predominantly 

operate in a given area, we support incentives for cleaner alternatives to diesel. LNG products 

can provide significant emission benefits over its diesel counterparts. It is our understanding that 

in 2007, the EPA Heavy-Duty Highway Engine Standards allow for NOx averaging (i.e., engine 

families only need to meet a NOx average of approximately 1.2 g/bhp-hr instead of the originally 

proposed standard of 0.2). To date, no engine manufacturer has certified a diesel engine that 

meets EPA’s 2007 emission standards for both NOx and PM, nor has any manufacturer 

committed to meet the 0.2 g NOx standard for diesel engines by 2007. Instead, engine 

manufacturers are targeting the interim 1.2 g NOx average for diesel products. Manufacturers of 

natural gas engines, however, have committed to meet the final 0.2 g NOx standard in 2007; 

nearly 3 years ahead of EPA requirements. Both Cummins Westport Innovations and John Deere 

Power Systems have made this public commitment to deliver 2010 technology to operators by 

planning to make the ISL G and 9.0L natural gas engines available, respectively, for the 2007 

model year. 

OFFRD-01—Construction/Industrial Equipment Fleet Modernization 

This measure assumes incentives will be available to provide the reductions promised. However 

the measure provides no evidence that incentives beyond the existing Carl Moyer Program 

moneys exist, and does not indicate that even these funds will be applied in this measure. Thus, 

the measure is based on a hope for incentives. This doesn’t provide enough certainty to include 

incentive-based reductions as creditable SIP reductions. 

Additionally, the measure suggests that regulation will be part of this measure’s toolbox, but 

there is no description of potential regulations. 

 

47 Draft 2007 AQMP, at IV-B-57. 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 20 of 26 

OFFRD-02—Accelerated Turnover and Catalyst Based Standards for Pleasure 

Craft 

PC play a critical role in the South Coast’s emissions inventory and are projected to rank as the 

fourth highest VOC emissions source in 2020.48 Only light duty passenger vehicles contribute 

more VOCs to the South Coast’s mobile source inventory.49 We agree that an expedited retrofit 

and replacement program at the state level is necessary and fully support standards that reach 

beyond 5g/kw-hr and fall in line with the new LSI standards. We do urge the District to push for 

a more aggressive implementation timeline in light of aggressive reductions necessary to meet 

the 8-hour ozone and PM2.5 standards. In addition to these recommendations, this measure 

should also include additional approaches that could be folded into a state program or pursued at 

the district level. We have described these below. 

Currently, to our knowledge, a statewide program does not exist to address the in-use fleet of PC 

in California. Additionally, there are no restrictions on the sale of pre-2001 model year engines. 

Further, retrofitting of pre-2001 model year engines is not required nor is the purchase of a new 

engine. 

At a minimum, the proposed statewide measure should also include a program targeting 

replacement of two-stroke recreational marine engines with cleaner four-stroke engines through 

an incentive program such as a buy-back program. Additionally, the program should include a 

mandatory retrofit of four-stroke recreational engines with catalytic converters. Funding for 

such a program could be generated through the collection of day use fees (on the order of $5 to 

$10) that are often used at certain boating locations. 

Further, although California’s emission standards are stricter than any other state, it is not 

difficult to acquire new PC in California that fail to comply with California emission standards. 

It is relatively easy to go across the California border to purchase a new PC or even through 

online purchasing. We recommend that CARB determine to what extent this may still be 

occurring and approaches to best curb this. 

OFFRD-03—Lower Exhaust Standards for Off-Road Recreational Vehicles 

Similar to our comments on OFFRD-02, we strongly encourage the District to include a more 

aggressive implementation timeline and the use of an incentive buy-back program. Mandatory 

retrofits should also be included as technology develops. 

 

48 Draft 2007 AQMP, at 3-20. 

49 Id. 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 21 of 26 

OFFRD-04—Evaporative Standards for Recreational Vehicles and Pleasure Craft 

This measure lacks specificity. The recommended measure needs a more specific phase-in 

schedule, and the District should explicitly recommend how retrofits, regulations, and incentives 

can play together to attain the goals of this recommended measure. 

OFFRD-05—Further Emission Reductions From Locomotives 

Given that the SCAB serves as a major gateway of freight transport to the rest of the country, 

locomotive pollution must be addressed to help cure many air quality problems in the Basin. 

Failure of leadership on the federal and state level has resulted in a system that is not effectively 

controlling locomotive pollution. As the AQMP discusses, without further pollution controls, 

NOx and PM will not be adequately controlled into the future.50 This measure offers a strong 

method of curbing pollution from locomotives. 

OFFRD-06—Clean Marine Fuel Requirements for Ocean-Going Marine Vessels

As the chart on page IV-B-75 indicates, this measure is one of the most effective means of 

reducing SOx in the Basin.51 Thus, this measure is vital to achieving attainment of federal and 

state air quality standards. Further, we are pleased that this measure recommends utilizing low 

sulfur fuels out to 40 nautical miles off of Point Fermin. 

At the same time, it should not be assumed that CARB will adopt the 0.1% sulfur standard by 

2010 under its Auxiliary Engine Rule due to its scheduled feasibility assessment in 2008. Thus, 

the AQMP should recommend early demonstration of 0.1% sulfur marine fuel (no later than 

2008) to help ensure that 0.1% sulfur fuel is available and fully demonstrated well ahead of the 

CARB feasibility study. Notably, the NNI auxiliary engine fuel measure required use of 0.1% 

sulfur fuel in 2008. 

Further, as referenced above, the District needs to delineate what actions are expected of each of 

the implementing agencies - EPA, CARB, and the Ports. 

OFFRD—07—Further Emission Reductions from Ocean-Going Marine Vessels and 

Harbor Craft While at Berth 

This measure proposes that by 2010, 20% of vessels calling at the Ports should use cold-ironing 

and another 20% will be required to use alternative equivalent technologies. We believe the 

measure also needs to include later benchmarks that are at least as stringent as CARB’s ERP—

e.g., 20% cold ironing by 2010; 60% by 2015; and 80% by 2020. However, we recommend that 

the 2010 percentage be increased to use more shore-side power. These benchmarks are 

necessary to guide CARB and the marine ports on how to proceed in reducing pollution from 

 

50 See Draft 2007 AQMP, at 3-18 -19. 

51 Draft 2007 AQMP, at IV-B-45 (noting a 45.6 tons per day of SOx from this measure by 2014). 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 22 of 26 

ships while at berth. Further, as referenced above, the measure needs to include a clearer picture 

of what each implementing agency should do to comply with this measure. 

However, we remain convinced that within the ocean-going vessel category, dockside power 

remains the most effective technology for reducing emissions from ocean-going vessels. For this 

reason, the AQMP should request that 70-80% of all ship visits after a new or renegotiated lease 

use shore-side power. This requirement should apply to all ocean-going vessel types (e.g. 

tankers, container vessels, etc.). Further, we recommend that all cruise liner ships cold iron 

regardless of frequency of calls at both Ports. 

OFFRD—08—Further Emission Reductions from Cargo Handling Equipment

This measure could be improved by requiring BACT and a preference for alternative fuel cargo 

handling equipment where commercially available. Indeed, it is important to acknowledge that 

CARB’s Cargo Handling Equipment regulation does not require BACT or dictate a preference 

for alternative fueled equipment. The final rule adopted allows several different “compliance 

options” that create a variety of possible levels of emission reductions. We recognize that not all 

types of cargo handling equipment are compatible with the same level of control technology. 

However, as we emphasized in detailed comments to CARB, it is imperative for each type of 

equipment to employ the cleanest option of control, which will obtain the greatest emission 

reductions (i.e. BACT), unless AQMD or CARB find it technically infeasible or unavailable.52 

We strongly encourage that AQMD identify the cleanest available technology for each type of 

cargo handling equipment and incorporate this approach into the recommendation. 

Further, as stated, OFFRD-08 should recommend requiring the use of alternative fuel models for 

available applications. For example, any new container handling equipment purchased on or 

after 2007 should (a) run on alternative fuels such as natural gas or (b) meet EPA Tier IV 

standards applicable to the year 2013, whichever has lower emissions. Vehicles using alternative 

fuels, such as natural gas, can emit half the NOx and an order of magnitude less of PM emissions 

as conventional diesel vehicles. In addition to lower emissions, alternative fuels provide other 

benefits to the state of California, including fuel diversity, petroleum replacement, and 

potentially lower greenhouse gas emissions. Thus, when alternative fuel models certify to 

comparable standards as conventional models, their use should be encouraged through 

incentives. Further, we are pleased that the AQMD has recommended that control measures on 

cargo-handling equipment not only be applied at the Ports, but also intermodal freight facilities 

and warehouse distribution centers. 

 

52 For example, under CARB’s rule, basic container handling equipment, bulk cargo handling equipment, 

and rubber-tired gantry cranes can use one of four options to comply with the CARB rule. The rule allows 

an owner to select an option that allows a Tier 1 engine to be retrofitted with a level 1 control, reducing 

PM 25%, until 2015 when further clean up would be required. Before 2015 however, this compliance 

option is several orders of magnitude more polluting than the cleanest option. The final regulation created 

a situation where owners have no incentive to choose the cleanest option. 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 23 of 26 

In addition, we encourage AQMD to promote acceleration of the implementation of cleaner 

cargo handling equipment by recommending that the Ports adopt port-wide rules to employ the 

above-referenced technologies. 

Finally, this measure should recommend incorporating idling limits, which would save fuel as 

well as cut pollution from these terminals, and reduce a significant source of worker exposure to 

diesel fumes. Idling limits for captive fleets would be much easier to manage and enforce than 

for other off-road equipment. 

OFFRD-09—Vessel Speed Reduction

Before recommending this measure, AQMD should consider and disclose whether speed 

reduction programs will result in any increases in PM or NOx emissions both within and outside 

of the vessel speed reduction (VSR) zone. Under a VSR program, PM and NOx may logically 

increase due to extended use of auxiliary engines.53 Additionally, there is concern that PM from 

main engines may increase at slower speeds. Although we are pleased this measure aims to 

extend the VSR boundary to 40 nm, before continuing or enhancing this program, AQMD must 

first ensure that pollutant increases will not occur. While the ports have assured us that the initial 

findings on this issue are positive, we have yet to see any study alleviating our concerns. 

Further, assuming VSR will provide emissions benefits, this measure should encompass a 

mandatory program rather than merely extend the current voluntary program. Additionally, if 

the measure entails a CARB regulation, AQMD should recommend that development of this 

regulation receive lower priority than other CARB regulations such as a cold-ironing regulation. 

Finally, in calculating the emissions reductions from this measure, AQMD must make sure not to 

assume that the 0.1% sulfur fuel requirement in 2010 will take effect. The current CARB 

regulation requires a feasibility study of the 0.1% sulfur fuel requirement in 2008, and the results 

of that study will dictate whether 0.1% sulfur fuel will ultimately be required. 

OFFRD-10—Further Emission Reductions from Ocean-Going Vessels

This measure proposes numerous proven technologies that must be included in the SIP. 

However, the measure includes two implementing agencies, and the measure needs to explicitly 

state the duties of each agency in making this measure come to fruition. Further, the measure 

solely gives the proposed penetration rate recommendation for slide valves. To be effective, the 

measure must include penetration rates for the other seven proposed technologies. 

In addition, the measure should include Humid Air Motor and Combustion Air Saturation 

Systems (CASS). 

 

53 San Pedro Bay Ports Clean Air Action Plan, Appendix A at 61. 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 24 of 26 

Finally, the District should outline goals that target the port shipping fleets as a whole. 

We recommend the following standards and timeline for vessels engines serving Ports: 

- 25% of OGVs must meet “Blue Sky Series” Category 3 ship engine standards (those 

are 80% below current IMO NOx standards) by 2010, either OEM or through SCR, or 

other add-on controls; 

- 50% of OGVs must meet “Blue Sky Series” Category 3 ship engine standards (those 

are 80% below current IMO NOx standards) by 2015 (OEM or add-on); 

- 100% of OGVs must meet “Blue Sky Series” standards by 2020 (OEM or add-on). 

VII. Suggestions for Additional Measures to be Included in the AQMP 

A. Proposed Measures for the District 

Idling Restrictions for Cargo-Handling Equipment

We recommend that the AQMP include a measure to address idling of cargo-handling 

equipment. This measure would save fuel as well as cut pollution in places where cargohandling equipment is used. In addition, an idling measure would protect workers from this 

significant source of diesel fumes. 

Indirect Source Rule for Construction Equipment 

We recommend the District include in the AQMP an indirect source rule measure for 

construction equipment for all those projects that are not already covered by the general 

operational indirect source rule anticipated in EGM-01. 

Operational Restrictions for Construction Equipment on High Pollution Days 

We recommend the District include a proposal for mandatory operational restrictions on pre-Tier 

3 equipment on days when the air quality index is over 100. 

Green Contracting Requirements

The District should work with the legislature to increase the District’s authority to require that 

public agencies operating within district boundaries adopt green contracting practices that 

motivate construction contractors to use less polluting construction equipment on publicly 

funded projects. 

Improve Emissions Reconciliation 

Pursuant to the suggestion of Dr. Robert Harley, University of California, Berkeley, in his 

comments at the District’s Ozone Air Quality Forum and Technical Roundtable Discussion on 

October 31, 2006, additional measurements of reactivity and solvent emissions (for example 

consumer products and semi volatile organic compounds in gas phase) should be taken to 

improve emissions reconciliation between current ambient air and current inventory.
Mr. Joseph Cassmassi 

December 1, 2006 

Page 25 of 26 

B. Proposed Measures for the District and ARB 

Improved Strategies for PM 2.5, Paved Road Dust and Vehicle Miles Traveled

We recommend that the AQMP include improved measures to address paved road dust. It is 

projected to be the top ranked source of directly emitted PM 2.5 emissions.54 The District and 

ARB should develop and evaluate new technology that collects pollutants emitted by vehicles 

and those already present on roads. The District and ARB should develop technology to reduce 

PM 2.5 and better collaborate with local jurisdictions on demand management and land use 

strategies to reduce VMT. 

Raise Awareness of Link Between Greenhouse Gases and Air Quality Criteria Pollutants 

The AQMD’s air quality framework should tie reductions in ground level ozone from the 

proposed short and mid-term measures to a global warming strategy. Combustion sources (e.g. 

cars, power plants, refineries, and auto manufacturing) should be given a high priority because 

these sources also emit VOC, PM, and toxic chemicals. As stationary combustion sources and 

freeways are disproportionately near communities of color, this also links to environmental 

justice. 

C. Proposed Measures for the EPA 

Idling Restrictions and Landing and Take-off Reform for Commercial Aircraft 

We recommend that the AQMP include a measure to address the idling of commercial aircraft 

while parked at airport terminals. This measure would save fuel as well as substantially cut 

pollution without any negative impact on safety or security. This measure would also protect 

airport workers and the immediate surrounding communities from harmful diesel fumes. In 

research described in a paper published in May 31, 2006 Environmental Science and Technology 

(DOI: 10.1021/es0512091), Scott Herndon, of Aerodyne Research, Inc., and colleagues used a 

mobile laboratory parked near the airport fence at Boston’s Logan Airport. As the plumes floated 

downwind across the lab’s instruments, they gathered data that resulted in “real world” 

hydrocarbon emissions from airplanes. These measurements show that such emissions may be 

much higher when planes are left idling on an airport tarmac than previously believed and 

recorded in the International Civil Aviation Organization (ICAO) databank by as much as 40% 

to 90%. 

We appreciate your consideration of these comments. 

Sincerely, 

Adrian Martinez 

Staff Attorney 

Natural Resources Defense Council 

Tom Plenys 

Research and Policy Manager 

Coalition for Clean Air 

 

54 Draft 2007 AQMP, at 3-27. 
Mr. Joseph Cassmassi 

December 1, 2006 

Page 26 of 26 

Adrienne Bloch 

Senior Attorney 

Communities for a Better Environment 

Michael Fitts 

Staff Attorney 

Endangered Habitats League 

 

Kathryn Phillips 

Manager, California Clean Air for 

Life Campaign 

Environmental Defense 

Diane Forte 

Director of Sustainability Programs 

Environment Now 

Cc (via email only): 

Linda Murchison (lmurchis@arb.ca.gov), CARB 

 Lucille Van Ommering (lvanomme@arb.ca.gov), CARB 

 Matt Haber (haber.matt@epa.gov), U.S. EPA 

 Rebecca Rosen (rosen.rebecca@epa.gov), U.S. EPA 

 Elaine Change, (echang@aqmd.gov), SCAQMD 

Attachments: 

Review of U.S. and European Regional Modeling Studies of Policies Intended to 

 Reduce Motorized Travel, Fuel Use, and Emissions
Review of U.S. and European Regional Modeling Studies of Policies Intended to Reduce 

Motorized Travel, Fuel Use, and Emissions

 

Robert A. Johnston, Professor 

Dept. of Environmental Science & Policy 

University of California, Davis 

August 2006 

 

Summary

With the enactment of a new federal transportation law in 2005, State and regional transportation 

plans and programs are for the first time required to achieve the objectives of the SAFETEA-LU 

planning process, which focus on enhancing mobility and supporting economic development 

while minimizing fuel use and emissions. 

 

This paper reviews the experience to date in dozens of metropolitan regions and advanced 

industrial economies as they have used scenario planning to evaluate an array of pragmatic and 

feasible policies and investment strategies that are available to help states and regions satisfy this 

new federal legal requirement. 

 

The results from 40 long-range scenario exercises performed in the U.S. and Europe demonstrate 

that substantial reductions in vehicle-miles of travel (VMT), fuel use, and emissions of both 

criteria pollutants and greenhouse gas emissions are possible using transportation pricing 

policies and investment priorities that have been demonstrated as acceptable and effective in a 

modest but growing number of metropolitan areas and regions around the world. 

 

VMT reductions in 20 years range from 10% to 20%, compared to the future trend scenario, are 

achievable with reductions in emissions and fuel use roughly proportionate to the decrease in 

VMT, while supporting the same level of future job and housing growth. In most studies, the 

highway levels-of-service are the same as, or better than, the trend scenario. 

 

The studies reviewed also suggest that these reduced-VMT scenarios generally produce higher 

transportation system productivity, positive net user economic benefits, greater equity in the 

distribution of transportation system benefits, reduced congestion delays, and a reduction in 

other adverse environmental impacts. 

 

The most-effective policy sets combine land use policies, such as compact growth, with strong 

transit provision and not expanding highway capacity. The addition of auto pricing policies, such 

as fuel taxes, work trip parking charges, or all-day tolls increases the effectiveness of the land 

use and transit policies. Peak-period tolls, by themselves, increase travel. Expanding road 

capacity, along with transit capacity, but without changing market incentives to encourage more 

efficient use of existing roads and parking, results in expensive transit systems with low 

ridership. 

 

The U.S. Studies

 

The following is excerpted from: 
2 

Bartholomew, Keith, Integrating Land Use Issues into Transportation Planning, Summary 

Report, DOT Cooperative Agreement No. DTFH61-03-H-00134. 2005. Dept. of Architecture, 

University of Utah . 

 

Bartholomew surveyed members of the National Association of Regional Councils (NARC) in 

2003-04 for examples of scenario planning using land use, transit, and other policies to reduce 

travel. Land use policies typically included density increases, clustering development in transit 

corridors or around rail stations, and urban limit lines. Both travel models and geographic 

information system (GIS) evaluation tools were used in the scenario evaluations. The median 

reduction in VMT in the 20-year scenarios for 31 exercises with adequate data was 2.3% but 11 

scenarios resulted in reductions of 5% or more. 

 

Five scenarios resulted in reductions of 10% or more. These studies generally evaluated modest 

growth management policies and did not employ the pricing of parking or fuels or roadways. So, 

these results may be viewed as lower bounds on what VMT reductions could occur in scenario 

exercises. 

Example data from the projects are: 

 1. Arizona, Maricopa Association of Governments. ~ 3% VMT reduction in 20 yrs. 

 2. S.F. Bay Area Alliance for Sustainable Development. 4.6% reduction in VMT by 2020. 

Most of the growth in this scenario is located in the existing urban cores of the region. 

 3. Georgia Regional Transportation Authority. 7% VMT reduction. 

 4. Baltimore Regional Transportation Board. 8.2% VMT reduction. Redevelopment was 

emphasized, road capacity maintained at current levels, and transit capacity moderately 

expanded. 

 5. Portland Metro. ~8.8% VMT reduction in 20 yrs (17.6% VMT reduction in 40 yrs). Growth 

contained within urban growth boundary, plus auto pricing, transit investment, and pedestrian 

improvements. 

 6. Southern California Association of Governments. ~10% VMT reduction in 25 yrs. Housing 

and jobs focused in existing centers and corridors. 

 7. Denver Regional Council of Governments. 12.5% VMT reduction in 25 yrs. Most growth 

would locate in infill development sites within the central city and existing suburbs. 

 8. Envision Central Texas . ~17% VMT reduction compared to current trend. New growth in 

existing developed areas, which would accommodate 1/3 of anticipated new households and 2/3 

of new jobs. 

 9. Contra Costa County, CA. 17.3% reduction in VMT in 20 yrs. Growth placed in existing 

urbanized areas, and along rail transit routes. 

 10. EPA, Atlanta , GA. ~38% difference in VMT between worse and best scenarios. 

The European Studies

For many years the European Commission has performed sophisticated studies of policies to 

reduce pollution, traffic accidents, noise, and greenhouse gas emissions. We review the three 

main reports here. In these studies, urban models were used, which are state-of-the-practice 

methods representing both travel and land development and use. These model sets are composed 
3 

primarily of discrete choice models based on microeconomics and so give elasticities of demand 

with respect to price. These statistics permit comparisons across regions and validation of most 

model components. 

 

Quite significant policies were evaluated, including higher taxation of fuels, larger auto purchase 

and registration fees, and tolling of roadways, both all-day and for peak periods, as well as urban 

limit lines, and density increases. So, we may view these projections as the upper bounds of 

what3 could be achieved in most regions in the U.S. As these are the most complete and best 

designed studies ever done, this review gives some detail about the policies and results. 

 

F.V. Webster, P.H. Bly, and N.J. Paulley, eds., Urban Land-use and Transport Interaction, 

Avebury ( Brookfield , MA ), 1988. 

Seven urban models were run on seven cities around the world on the same policy sets, intended 

to reduce VMT and emissions. Each region ran a 20-year Future Base Case, different for each 

region, but basically a trend scenario plus any major investments already programmed. All 

results are reported as differences from the future base case. 

 

The results were reasonably coherent and showed that only urban limit lines reduce residential 

sprawl. Such controls did not raise housing prices, however, due to increased density. 

 

Increasing land use density is effective in reducing VMT, especially if the walk and bike modes 

are well-provided for. Parking charges in the central business district (CBD) decentralize 

employment, whereas vehicle purchase and registration taxes (or fuel taxes) reduce auto 

ownership and VMT. The vehicle taxes are much more effective, if supported by good transit 

service, especially to the CBD and other employment centers. Land use and transit policies have 

little effect, unless supported by pricing. 

 

Faster radial travel by freeway or rail increases the decentralization of upper-income households, 

thereby increasing segregation by income. Increasing the cost of both auto travel and transit by 

50% decreases travel and energy use about 10%. Increasing auto costs by 400% reduces VMT 

and emissions about one third. (Note that making workers pay for parking or providing 

cash-in-lieu-of-parking incentives in the U.S. increases “felt” travel costs by around 400%, 

without actually increasing costs, as the parking costs are merely being unbundled from wages.) 

All pricing scenarios decreased travel delays. 

 

Travel models must include an auto ownership step and the walk and bike modes in order to 

represent these policies accurately. Also, the peak and non-peak periods must be modeled 

separately. 

 

SPARTACUS, Final Report. European Commission, Environment and Climate Research 

Programme. Sept., 1998. On internet at www.ltcon.fi/spartacus or from Kari.Lautso@LTcon.fi. 

 

This study used MEPLAN, one of the most-advanced urban models, on Helsinki , Bilbao , and 

Naples . A raster (grid) GIS program was added to MEPLAN to calculate impacts from noise 
4 

and emissions on households and to produce maps. A user interface was also added to simplify 

the input of policies and also the production of output tables, maps, and graphs. Policy impacts 

were net from the future base case, as above. 

 

Overall, only the travel pricing policies were found to reduce VMT substantially. For example, 

increasing auto costs by 50% decreased VMT by 16%. Land use policies were not very effective, 

except to back up the transit system. Pricing is required in order to gain large increases in transit 

use. 

 

The most effective pricing policies combined congestion pricing with mileage or travel pricing 

(fuel tax or all-day tolls). Increasing rail service increased all travel speeds in Bilbao and 

Helsinki , due to some auto travelers switching to rail, while in Naples the existing transit system 

was made more efficient. This shows the need to not add highway capacity in long-range 

investment plans that are intended to reduce VMT and emissions. 

 

Combining land use policies for intensification in transit corridors and urban limit lines with 

transit investments and the pricing of auto travel was found to be the most effective approach to 

reducing VMT. Greenhouse gases and fuel use are reduced between 13% and 24%, depending 

on pricing levels, with an increase in auto operating costs of about 100% being most effective. 

Delays were decreased significantly in all pricing scenarios. 

 

The raster system was effective for analysis and mapping. The user interface was also very 

useful in aggregating the outputs in various ways. Various weighting schemes with social, 

economic, and environmental indicators were tried. Also, sensitivity tests were conducted on the 

various equity measures and on indicator weighting ranges. They also found that such studies 

should include surrounding rural areas, as they often receive significant impacts. The authors 

also recommend that studies should also be for at least 20 years, to capture counterintuitive and 

changing effects over time. 

 

PROPOLIS: Planning and Research of Policies for Land Use and Transport for Increasing Urban 

Sustainability. Final Report. European Commission, Energy, Environment, and Sustainable 

Development Thematic Programme. February, 2004. Available from Kari.Lautso@LTcon.fi. 

 

This study carried on the SPARTACUS approach, modeling 7 urban regions using three 

advanced integrated urban models. The study was firmly embedded in the sustainable 

development policy analysis paradigm, using many indicators of Social, Economic, and 

Environmental effects. All models used a raster analysis and mapping capability and a user 

interface for policy inputs and for the analysis of model outputs. Policy results were net from the 

future base case, as in the two previous studies. 

 

The policy results were generally the same as in the SPARTACUS study, with more variation 

due to differences among the urban regions. The results were generally similar across all 7 

regions, though. Methodologically, the findings were also the same as in the previous study. In 

the future baseline (trend) scenarios, the large number of European Commission sustainability 
5 

indicators deteriorated in all regions. 

 

By applying pricing, land use, and transit investment policies, most of the indicators could be 

reversed. Increasing auto operating costs by 75%, adding parking charges, and decreasing transit 

fares by 50% was the most effective pricing policy component. It reduced greenhouse gas 

emissions and fuel use by 15-20% in all regions, over 20 years. Because the same policy set gave 

the same general results in the 7 regions, the study concluded that this policy set would likely 

work in most EC regions. Making workers pay for work trip parking would increase 

“experienced” auto costs by 100-500% in most regions, since drivers choose modes based on 

out-of-pocket costs (gas, tolls, parking charges, transit fares). In the U.S. , the true unbundled 

cost to employers of providing free parking is typically much larger than the employee’s 

out-of-pocket fuel costs to drive to work by auto. 

 

The effects of the various pricing policies were found to vary by region and often had negative 

effects on sprawl (increased sprawl) and so all must be studied individually and in combination 

with other policies. Increasing transit speeds increased sprawl unless accompanied by pricing 

and urban limit line policies. Increases in transit service often reduced road congestion and 

caused more sprawl. This finding shows that highways must be allowed to become congested, 

while improving transit. The VMT-reducing policy sets increased economic welfare by 

1,000-3,000 Euros per person (net present value over 20 years) and also reduced traffic 

accidents, congestion, and noise. 

Studies by Robert A. Johnston 

A dozen published papers simulating similar policies in the Sacramento , California region by 

this author have produced findings similar to those in the three EC studies. These studies, 

conducted over a 20-year period, used three versions of the official MPO travel model and three 

versions of an urban model, the last version being the official version adopted by the MPO. 

These were all 20-year studies, unless otherwise noted. All results are compared to the future 

trend scenario or to a no-build (do nothing beyond the funded 3-year Transportation 

Improvement Program (TIP) projects) scenario. Because SAFETEA-LU requires MPOs to 

include support for increased economic development as a factor in developing their adopted 

plans, economic welfare findings are also presented. These are similar to consumer surplus for 

travelers, calculated from the mode choice model logsums, a measure commonly used in this 

kind of analysis across the world. 

 

Synthesis of Findings: 

 1. Expanding road capacity increases auto travel and emissions, compared to doing nothing. 

New HOV lanes on radial freeways increase travel and emissions. They also increase sprawl. 

Congestion generally becomes worse, in spite of adding highway capacity. 

 2. Expanding transit only decreases emissions about 1%, compared to doing nothing. It 

decreases travel costs for lower-income households. It can increase sprawl somewhat, due to the 

outer rail stations. 

 3. Expanding transit only and supporting it with land use intensification around Light Rail 
6 

stations decreases emissions about 5%. It decreases travel costs for lower-income households. 

 4. Expanding transit only and supporting it with land use intensification around Light Rail 

stations and with urban growth boundaries decreases emissions about 10%. It decreases travel 

costs and travel delays for all households. 

 5. Expanding transit only and supporting it with higher fuel taxes and with workplace parking 

charges (refunded in higher wages as cash-in-lieu-of-parking incentives) and shopping parking 

charges (refunded through lower costs for goods and services) lowers emissions about 10%. It 

greatly increases economic benefits to all travelers, due to better transit and faster freeways. 

This scenario reduces congestion significantly. 

 6. Expanding transit only and supporting it with land use intensification and urban limit lines 

and with fuel taxes and parking charges, as above, lowers emissions about 15-30%. This 

scenario maximizes economic welfare for the region and reduces congestion the most. 

Results from the most recent study using the most advanced urban model: 

 

This analysis was performed by the author with the MEPLAN urban model, developed for the 

Sacramento MPO. It assumed more ambitious transit investment levels than in previous studies. 

 The model analysis was performed for a 50-year time horizon to enable comparison with the 

MPO’s recent 50-year visioning study results. 

 1. The transit-only scenario assumed many Bus Rapid Transit (BRT) lines, in exclusive lanes 

within the urban areas, and on highways to the outlying cities in the region. The analysis did not 

include use of the California emissions model, but emissions and fuel use correlate very strongly 

with total travel (VMT). This scenario reduced VMT by 8% in 2025 and 12% in 2050. 

 2. The MPO’s transportation plan assumed more freeways, more HOV lanes, more or wider 

ramps, and more Light Rail lines, was modeled with an urban growth boundary (UGB). This 

scenario reduced VMT 7% in 2025 and 8% in 2050 and so performed somewhat worse than the 

transit-only scenario. 

 3. The transit-only scenario was tested with a UGB. This reduced VMT by 15% in 2025 and 

20% in 2050. Congestion was also reduced. 

 4. The transit-only scenario was tested with an extra fuel tax of $1.00 per gallon and parking 

charges for work trips. This reduced VMT by 14% in 2025 and 18% in 2050. Congestion was 

reduced substantially. 

 5. The transit-only scenario was tested with the pricing policies and with a UGB. This reduced 

VMT 20% in 2025 and 25% in 2050. In this scenario, congestion was reduced the most. 

Such strong results stem from the inclusion of a comprehensive transit scenario with fast BRT in 

exclusive lanes. Also, the urban model allows new development to complement the 

transportation systems. 

 

All of the tested scenarios were found to be economically beneficial for low-income travelers. 

The three Urban Growth Boundary scenarios were strongly positive for all travelers together, 

with savings of about $0.5 million per day. The analysis method used includes only the morning 

peak period, so if the results are factored to get all daily travel, the savings become about $1.5 
7 

million per day ($500 million per year). 

 

These scenarios all included only moderate pricing policies and thus the results should be viewed 

as the middle range of what is achievable for most large regions, where such levels of 

transportation pricing incentives will likely become acceptable within a few years. 

 

Including transportation investment and policy scenarios together with pricing and Smart 

Growth policies has a significant positive impact on system performance (congestion) and on 

user satisfaction. This likely enhances the political feasibility of adopting such policies. 

The studies summarized above: 

 

Johnston, Robert A. And Raju Ceerla. 1995. Land Use and Transportation Alternatives. In D. 

Sperling and S. Shaheen, eds., Transportation and Energy. ICEEE. 

 

Rodier, Caroline J. and Robert A. Johnston. 1997. Incentives for Local Governments to 

Implement Travel Demand Management Measures. Transp. Res.:A 31:4, pp. 295-308. 

 

Rodier, Caroline A. and Robert A. Johnston. 1997. Travel, Emissions, and Welfare Effects of 

Travel Demand Management Measures. Transp. Res. Rec. 1598, pp. 18-24. 

 

Johnston, Robert A. and Caroline J. Rodier. 1998. Regional Simulations of Highway and Transit 

ITS: Travel, Emissions, and Economic Welfare Effects. Mathl. Comput. Modeling, 27:9-11, pp. 

143-161. 

 

Johnston, Robert A., Caroline J. Rodier, and Melanie Choy. 1998. Transportation, Land Use, and 

Air Quality Modeling, pp. 306-315 in Transportation, Land Use, and Air Quality: Making the 

Connection, ed. by Said Easa and Donald Samdahl. American Society of Civil Engineers. 

 

Rodier, C. J., Johnston, R. A., & Shabazian, D. R. 1998. Evaluation of advanced transit 

alternatives using consumer welfare. Transportation Research:C, 6:1-2, 141-156. 

 

Johnston, R. A., & Rodier, C. J. 1999. Synergisms among land use, transit, and travel pricing 

policies. Transportation Research Record, 1670, 3-7. 

 

Johnston, Robert A. and Tomas de la Barra. 2000. “Comprehensive Regional Modeling for 

Long-Range Planning: Integrated Urban Models and Geographic Information Systems.” Transp. 

Res.: A, pp. 125-136 

 

J.D. Hunt, R.A. Johnston, J.E. Abraham, C.J. Rodier, G. Garry, S.H. Putman, and T. de la Barra. 

2001. “Comparison from the Sacramento Model Testbed.” Transp. Res. Rec. , 1780. pp. 53-63. 

 

Johnston, Robert A., Caroline J. Rodier, John E. Abraham, and John Douglas Hunt. 2001. 

Applying An Integrated Model to the Evaluation of Travel Demand Management Policies in the 
8 

Sacramento Region: Year Two. Mineta Transportation Institute, San Jose State University , CA. 

MTI Rept. 01-08. 

 

Rodier, C. J., Johnston, R. A., & Abraham, J. E. 2002. Heuristic policy analysis of regional land 

use, transit, and travel pricing scenarios using two urban models. Transportation Research: D. 

Johnston, Robert A., Shengyi Gao, and Michael J. Clay. 2005. “Modeling Long-Range 

Transportation and Land Use Scenarios for the Sacramento Region, Using CitizenGenerated Policies.” Transp. Res. Rec., 1902, pg. 99-106. 

www.vtpi.org/johnston.pdf