Bryan W. Shaw, Ph.D., Chairman 

Buddy Garcia, Commissioner 

Carlos Rubinstein, Commissioner 

- . : ~~·.-> .:.\ \ .: I· 

!d:~ fJLr.;·u:i: 

. !· 

Mark R. Vickery, P.G., Executive Director 10 APR -9 Pii 1:55 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

Protecting Texas bg Reducing and Preventing Pollution 

April6,2010 

Docket No. 2009-0802-SIP, Project No. 2009-017-SIP-NR ~ 

Docket No. 2009-0932-RUL, Rule Project No. 2009-006-101-EN · 

Docket No. 2009-0867-RUL, Rule Project No. 2009-019-101-EN 

A1 Armendariz, PhD, Regional Administrator 

U.S. Environmental Protection Agency- Region 6 

1445 Ross Avenue 

Dallas, Texas 75202-2733 . 

Dear Dr. Armendariz: 

On March 10, 2010, the Texas Commission on Environmental Quality (Commission) adopted revisions to the 

State Implementation Plan (SlP) for the control of ozone air pollution for the Houston-Galveston-Brazoria 

(HGB) area. 

The Commission adopted amendments to 30 Texas Administrative Code (TAC) Chapter 101, Subchapter A, 

General Rules, Section 101.1; and Subchapter H, Emissions Banking and Trading, Division 6, Highly Reactive 

Volatile Organic Compound Emissions Cap and Trade Program, Sections 101.390 - 101.394, 101.396, and 

101.399 - 101.401; 30 TAC Chapter 101, Subchapter H, Emissions Banking and Trading, Division 3, Mass 

Emissions C and Trade Pro Sections 101.350 101.351 and 101.353 and co · revisions to the 

SlP; and GB Attsinment Demonstration SlP Revision for the 1997 Ei t-Hour Ozone Standard. These rule 

changes and SIP revisions demonstrate that the HGB area will attain the 1997 eight-hour ozone National 

Ambient Air Quality Standard by June 15, 2019. 

Enclosed are the proposed revisions to the SlP, a public hearing certification, a complete record of the public 

hearings, and the accompanying orders.· I look forward to your expeditious approval of these SlP revisions. 

Sincerely, 

B ~,;ktw.--· B~haw,PhD. Chairman 

BWS/jmm 

Enclosures 

cc: The Honorable Rick Perry, Governor ofTexas 

Mr. Toby Baker, Office ofBudget, Planning and Policy, Office of the Governor 

Mr. Mark R Vickery, P.G., Executive Director, Texas Cor!unission on Environmental Quality 

P.O. Box 13087 Austin, Texas 78711-3087 512-239'1000 1ntemet address: www.tceq.state.tx.us 
Texas Commission on Environmental Quality 

Public Hearings 

Odober 28-29, 2009 

Houston-Galveston-Brazoria (HGB) 

Attainment Demonstration SIP Revision 

for the 1997 Eight-Hour Ozone Standard 

Projed Number 2009-017-SIP-NR 

Volume 2 of2 
REVISION TO THE STATE IMPLEMENTATION PLAN 

FOR THE CONTROL OF OZONE AIR POLLUTION 

HOUSTON-GALVESTON-BRAZORIA 1997 EIGHT-HOUR OZONE STANDARD 

NONATTAINMENT AREA 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

P.O. BOX 13087 

AUSTIN, TEXAS 78711-3087 

Houston-Galveston-Brazoria Attainment Demonstration 

State Implementation Plan Revision for the 1997 Eight-Hour Ozone Standard 

PROJECT NO. 2009-017-SIP-NR 

Adopted 

March 10, 2010 
xv

LIST OF APPENDICES 

Appendix Appendix Name

Appendix A Meteorological Modeling for the HGB Attainment Demonstration SIP 

Revision for the 1997 Eight-Hour Ozone Standard 

Appendix B Emissions Modeling for the HGB Attainment Demonstration SIP 

Revision for the 1997 Eight-Hour Ozone Standard 

Appendix C Photochemical Modeling for the HGB Attainment Demonstration SIP 

Revision for the 1997 Eight-Hour Ozone Standard 

Appendix D Reasonably Available Control Technology Analysis 

Appendix E Reasonably Available Control Measure Analysis 

Appendix F Evaluation of Mobile Source Control Strategies for the HoustonGalveston-Brazoria State Implementation Plan (With Detailed 

Strategies), Prepared for Houston-Galveston Area Council, Prepared by 

ENVIRON International Corporation 

Appendix G Transportation Control Measures for the HGB Attainment 

Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard 

(Excerpt from Evaluation of Mobile Source Control Strategies for the 

Houston-Galveston-Brazoria State Implementation Plan), Prepared for 

Houston-Galveston Area Council, Prepared by ENVIRON International 

Corporation 

Appendix H Voluntary Mobile Emission Reduction Program for the HGB Attainment 

Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard 

(Excerpt from Evaluation of Mobile Source Control Strategies for the 

Houston-Galveston-Brazoria State Implementation Plan), Prepared for 

Houston-Galveston Area Council, Prepared by ENVIRON International 

Corporation 

Appendix I Corroborative Analysis for the HGB Attainment Demonstration SIP 

Revision for the 1997 Eight-Hour Ozone Standard 

Appendix J Recommendations for Best Management Practices to Control and 

Reduce Inadvertent Cargo Vapor Emissions in the Tank Barge 

Community 
APPENDIX H 

VOLUNTARY MOBILE EMISSION REDUCTION PROGRAM

FOR THE HGB ATTAINMENT DEMONSTRATION SIP REVISION 

FOR THE 1997 EIGHT-HOUR OZONE STANDARD 

Excerpt from 

Evaluation of Mobile Source 

Control Strategies for the 

Houston-Galveston-Brazoria 

State Implementation Plan 

Prepared for Houston-Galveston Area Council 

Prepared by ENVIRON International Corporation 

This appendix supplements the discussion provided in Section 4.6.2.2, Voluntary Mobile Emission 

Reduction Program (VMEP), and details the voluntary commitments made in this state implementation 

plan (SIP) revision. The VMEP emission reduction was included in modeling sensitivity runs described 

in Chapter 3, Photochemical Modeling. The 2.25 tons per day tpd reduction of nitrogen oxides (NOX) 

emissions resulting from these voluntary commitments are referred to as the Houston-Galveston Area 

Council (H-GAC) reductions. 

Alternative Commuting

Bicycle and Pedestrian Actions 

Bicycle measures encouraged by bicycle and pedestrian action groups include new bicycle lanes, new 

bikeway plans, and encouraging greater use of existing lanes instead of vehicle use. Bicycle action 

groups and other bicycle measures included in the H-GAC Regional Bikeway Plan from the 2035 RTP are 

evaluated below. The Regional Bikeway Plan, described in Appendix G of the 2035 RTP is intended to 

serve as a guide for investment, interagency coordination, and best practices in developing facilities for 

bicyclists in the eight-county Houston-Galveston Transportation Management Area (TMA). The plan 

acknowledges that the current level of bicycle travel within the TMA is not precisely known, making it 

difficult to define a benchmark for increases in bicycle travel replacing vehicular travel. Unfortunately, 

the Houston-Galveston region also has one of the highest rates of crashes involving motorists and 

bicyclists in Texas. The plan may be reviewed at http://2035plan.org/docs/final/Appendix%20G-

%20Draft%20Ped%20Bike%20RTP%20Appendix.pdf. 

Notable examples of local bikeway networks include Alvin, Conroe, Houston, Lake Jackson, La Porte, 

Missouri City, Pasadena, Sugar Land, and The Woodlands. The H-GAC plans to continue to work with 

local entities to identify projects that further the development of local bikeway networks as part of the 

overall regional transportation system. 

There are two employment centers within the TMA that generate a significant level of bicyclist 

commuters: the Texas Medical Center (TMC) in Houston and the University of Texas Medical Branch 

(UTMB) in Galveston. The TMC draws the greatest amount of commuter bicyclists of any employment 

center in the TMA. According to the 2000 census, there were 50,238 work trips, of which 36,973 drove 

alone, 7,927 carpooled, 4,018 took the bus, 430 walked, 379 biked, and 511 used other means 

(motorcycle, taxi, permanent telecommute). The 430 walking trips and the 379 biking trips represent 

0.9% and 0.8% respectively of all trips. The TMC has the highest concentration of bicycle trips within a 

census tract in the region (even greater than downtown Houston), and the third highest concentration of 

walking trips in the region (after downtown and the UTMB in Galveston). Recent observations made by 

H-GAC and TMC staff indicate that over 1,000 bicyclists now commute to the TMC on a daily basis. 

The 2000 Census indicated that UTMB had 10,470 daily work trips. Of these 89% were by private 

vehicle, 1.3% by bus, 2.2% by bicycle and 5.3% walking trips. These are much higher than the regional 

average of 0.3% by bicycling and 2.1% by walking. 

Cleaner Diesel Fuel/Alternative Fuels 

The cleaner diesel control measure would consist of a change in diesel fuel from Texas Low Emission 

Diesel fuel (TxLED) to either cetane additive enhanced (CAE) or Fischer-Tropsch (FT) diesel fuel. It is 

anticipated that, due to the nature of CAE and FT diesel technology, this program may not be a mandatory 

change to CAE or FT diesel, but may more likely be for a localized or demonstration project on specific 

Class 8b Heavy Duty Truck (HDT) fleets. 

TxLED fuel contains less than 10 percent by volume of aromatic hydrocarbons and has a cetane number 

of 48 or greater. CAE diesel would consist of diesel to which additives were supplemented, producing a 

cetane number increase of 5 points with no changes in other parameters from TxLED fuel. FT diesel fuel 

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would consist of typical FT fuel with a cetane number of 74 and an aromatic content of 0.1 percent (Clark 

et. al., 1999). 

Subscription Bus Service 

There are many types of subscription bus services offered in the Houston and other metropolitan areas. 

The analysis presented here focuses on a subscription bus service catering to those that are least likely to 

use transit – white collar workers whose work load would make a quiet stress-free ride to work with 

internet access offered very attractive. Among the major obstacles to transit use are limitations in service 

between residential and employment areas. If transit service were designed specifically for certain 

residential areas to highly used but somewhat underserved employment areas, transit use could increase 

substantially. An example of such a service would be between the Katy areas to downtown areas such as 

the TMC. 

There are a number of potential services that could assist in transit use between such areas, including 

personalized rapid transit, subscription bus service, business first buses, easier access between METRO 

and other services such as those provided by TREK (such as a universal card), and personalized transit 

planning. There is a likelihood of some latent demand for transit service that specifically serves 

individuals because of time spent in traffic, gas prices, maintenance and parking costs that can be 

significantly offset by using an alternative mode of transportation such as transit. For example, 

personalized transit planners, somewhat like personal shoppers, could assist individuals by showing them 

how to easily use transit from one point to another (such as home to work, work to lunch spots or meeting 

locations, and work to home). Such a service could even be provided online. In addition, some buses 

could be equipped with fold-down tables and wireless internet connections (for example, through cellphone companies) so that people could work while on the buses, and feeder shuttles could bring people 

from transit stops directly to work centers. 

This measure evaluates the benefits of a hypothetical and ambitious program that would provide these 

services. It is assumed that 100 new business buses (buses equipped with fold-down tray tables and 

wireless internet) seating 35 people each providing service directly from neighborhoods to specific work 

locations would operate four trips per morning and four per evening. Service would also be augmented 

by the addition of 100 shuttle buses to provide service between current METRO stops and (1) underserved residential area too far from transit centers or park and ride lots to utilize them; and (2) 

employment areas in downtown Houston which currently do not have sufficient transit access. The 

shuttle buses are assumed to seat 15 people each and operate six trips each morning and six each evening. 

For the purpose of simplicity it is assumed that currently planned expansions to METRO service would 

accommodate the extra ridership created by the shuttle services. If this measure results in emissions 

significant enough to merit further review, this assumption, along with the others would need to be 

refined. 

Public Transit Improvements 

There are two measures related to transit options in the list of measures that could produce measurable 

emissions reductions shown below: 

• Electrified buses, and 

• Light rail expansion. 

The electrified buses or light rail require infrastructure improvements (overhead catenary or rail 

construction), but would result in an elimination of the engine emissions on those routes served. 

Compressed work week 

Compressed work weeks are among the most effective transportation demand management measures. 

Many Houston area employers currently have compressed work week programs. Employees in most of 

these programs either have a 4/40 schedule or a 9/80 schedule. A 4/40 schedule means they work four ten 

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hour days per week and have one day off. A 9/80 schedule means the employees work 9 hours a day and 

take one day off every two weeks. Most programs operate on a 4/40 schedule. 

Currently the H-GAC alternative work schedules program, which operates under the umbrella of the 

Commute Solutions program, helps employers implement several measures including telecommuting, 

carpooling, vanpooling, alternative parking, and compressed work weeks. A mandatory program 

specifically aimed at increasing the amount of compressed work weeks is not currently in place but could 

be implemented as a part of the overall ozone attainment plan. 

Internet Ridematching Services 

An H-GAC ridesharing program began in August of 2005, which utilizes computer-based methods 

similar to other online travel programs such as Travelocity. The program is internet based and uses the 

consultant NuRide, Inc. (http://www.nuride.com), the nations first incentive-based rideshare network. 

NuRide’s innovative online program lets individuals use NuRide’s patent-pending technology to find the 

ideal partner with whom to share a single ride for work or pleasure. Subscribing to the philosophy that 

people sharing rides provide a valuable service to their community, NuRide offers its members rewards 

each time they use the ridesharing program. By accumulating "NuRide Miles", members earn enough 

points to acquire gift cards and gift certificates from a variety of corporate sponsors such as Old Navy, 

TGI Fridays, Macy’s, and many other familiar retailers and restaurants. 

The program’s incentives to ridesharers are significant enough to have made the program grow from a 

few hundred carpoolers to nearly 5,000 in August 2008. The incentives mentioned above earn points at 

dozens of participating retailers. Points are only earned when, for each ridesharing day, ridesharers match 

themselves with an online carpool and fill out a survey form (all ridesharers must fill out the survey or no 

credit will be given). 

It should be noted that in addition to NuRide, there are several other internet based carpooling websites. 

eRideshare.com is the leading carpool/ridesharing website, according to Yahoo and Google. It has been 

recognized as "Best of the Net" by About.com, and was featured in Al Gore's book, An Inconvenient 

Truth as a way to Take Action. GoLoco, Zimride (which uses a facebook application), Mycarpools.com, 

and CarpoolWorld.com are other examples of carpooling websites. These internet sites saw enormous 

growth during 2008 while gas prices were rising. Specific statistics on Houston for all ridesharing sites 

are not available. 

Vanpooling

The H-GAC administers a vanpooling program that consists of ongoing efforts to reduce congestion by 

providing alternative transportation through trip sharing with vanpools. The program began operation in 

1996 and is funded using Surface Transportation Program (STP) funds, METRO local funds and 

employer incentives, which provide reduced monthly costs to participating employees. As of August 

2008, the vanpool program had 755 vans and 7,846 riders with an average of 10.4 riders per van. The 

vanpools average 54.6 miles per day (round trip). 

The VMT reduction resulting from these vanpoolers will be about 54.6 miles per day, or about 100 

million miles per year, assuming a 260-day work year. As vanpools are driven about 11 million miles per 

year to offset the 111 million miles that would have been driven in passenger vehicles. 

Regional Traffic Flow Improvement

Local Intersection Signal Improvements 

Traffic signalization improvements, reversible lanes, and intersection improvements are an ongoing part 

of the H-GAC plan and Transportation Implementation Plan (TIP). According to evaluations of 

Congestion Mitigation and Air Quality (CMAQ) projects, as well as straightforward logic, traffic flow 

H-3 
improvements encouraged by improved intersections or traffic signals provide benefits for 2 to 5 years (3 

years was used for this analysis) before latent demand and growth in traffic cause the facility to return to 

approximately the same flow level as prior to the signal or other improvements (although better able to 

handle higher traffic volume). 

Vehicle Retrofit and Replacement

Public and Private Sector Clean Fuel Fleets 

This measure seeks to reduce on-road vehicle emissions by rapid turnover to newer lower emission 

engines, retrofit of existing engines with approved devices, or new lower emission technologies. These 

programs have been mandated or voluntarily implemented with federal incentives or state funding from 

programs such as the Texas Emissions Reduction Plan (TERP). 

In Houston, the H-GAC administers a program under The Clean Cities/Clean Vehicles Program 

(http://www.houston-cleancities.org/#) where CMAQ funds are distributed to replace and retrofit lower 

emitting heavy-duty vehicles. 

In Texas, the TERP program has been successful in co-funding many different types of emission 

reduction projects including on-road trucks, construction and off-road equipment, marine vessels, and 

locomotives. To date, about $300 million of projects have been approved in the HGB area from 2002 

through 2008 with most of the funding occurring in the 2004 through 2008 period. The most recent 

projects have just been approved, so not all of the emission reductions have been realized and are still 

pending. 

Dedicated Funding for School Bus Replacement 

A fund dedicated to helping meet the costs of purchasing new buses to replace older buses has accelerated 

the replacement of older buses in school district fleets. Buses that are replaced should be scrapped. 

Electric Vehicles/Increased Use of Hybrid Buses 

The electric vehicle control measure consists of the voluntary inclusion of a greater percentage of zero 

emission vehicles (ZEVs) or zero emitting travel through the use of plug-in hybrids or other vehicles. 

This could occur through new purchases or a replacement program for existing vehicles. 

The hybrid buses available have two main advantages. No new (other than the buses themselves) 

infrastructure is required and fuel consumption is reduced. The main disadvantage is that a fraction of 

emission reductions (about 25%) would be applied to already low emission new bus engines. Therefore, 

the emission reduction in tons per year would be lower than that for projects implemented through 2007. 

Off-road Measures

Voluntary Non-Road Replacement and Retrofit Programs 

Voluntary retrofit and replacement programs have been used across the US to reduce emissions using a 

variety of co-funding incentive programs to offset the costs incurred. 

In Texas, the popular TERP program has been successful in providing co-funding for many emission 

reduction projects of many different types of emission sources, including, on-road trucks, construction 

and off-road equipment, marine vessels, and locomotives. To date, about $300 million of projects have 

been approved in the HGB area from 2002 through 2008 with most of the funding occurring in the 2004 

through 2008 period. Because the most recent projects have just been approved, not all of the emission 

reductions have been realized and are still pending. 

In addition, there are other funding sources for control strategy projects including the EPA grant program 

run by a local collaborative (http://www.blueskyways.org/). The EPA funding program was relatively 

H-4 
limited at $5,000,000 in 2008 (http://www.blueskyways.org/pdf/clean-diesel-FY08.pdf) for the states of 

Arkansas, Louisiana, New Mexico, Oklahoma, Texas, Iowa, Kansas, Missouri, Nebraska, and Minnesota. 

Nationally this program was funded at $49.2 million in 2008, of which, $27.6 million was available for 

national Clean Diesel Funding Assistance Program. Half of the national Clean Diesel Funding Assistance 

Program is dedicated to public fleets. Other monies were distributed to the States, research, and revolving 

loan program. 

There may be additional funding sources available through State and Federal actions and other programs. 

 

Government Construction Incentives 

An incentive program or a requirement for publicly-funded (including just captive state, county, and 

municipal fleets of off-road equipment) or all construction projects could effect emission reductions by 

encouraging fleet turnover to those meeting lower emission standards. A TxDOT plan provides an 

example of an incentive program. Alternatively, many other states and localities have suggested or 

implemented emission standard (by model year) requirements for construction contracts. (EPA, 2008, 

http://www.epa.gov/diesel/construction/contract-lang.htm) While some areas target NOx control and 

others PM control, the incentives or requirements for new equipment based would control both pollutants. 

Promote Cleaner Lawn and Garden Equipment 

A program designed to promote the use of clean lawn and garden equipment. The primary benefit of 

these programs will be to reduce VOC and CO emissions. 

There are at least two examples of a replacement/purchase program to replace gasoline equipment with 

electric versions including several in California (http://www.aqmd.gov/tao/lawnmower.html, 

http://airquality.org/mobile/mowdown/mowdowngeneral.shtml) and the Central Texas program 

(http://www.cleanairforce.org/2008MowingFlyer.pdf). These programs have worked out many of the 

issues related to transfer of ownership and determining appropriate incentives. 

Reduced Idling 

Idling is an inefficient use of equipment in general and generates unnecessary emissions. Idling however 

cannot be avoided in all cases, such as during normal work when work is performed intermittently, and 

the time to restart the engine would be considered an annoyingly significant delay. This measure would 

seek to limit excessive idling when equipment is not required immediately. Suggested periods for 

limiting idling could be s little as 15 minutes maximum. Many on-road trucks have factory-installed 

engine shut down devices that automatically shut down the engine after a set period, or devices could be 

added to existing equipment. 

To implement this measure, idle shut-off devices could be employed with idle timers set to a period that 

would not cause typical operational problems. But operator training could provide significant idle 

reduction perhaps beyond idle shut-off devices. 

Development of Clean Air Action Plans for Regional Port and Marine Operations 

This measure seeks to adopt a plan that effects emission reductions from HGB area ports and private 

terminals. The plan could cover several or all emissions sources associated with marine activity include 

water and shoreside activities as outlined by EPA's Clean Ports USA 

(http://www.epa.gov/otaq/diesel/ports/index.htm). 

A program might use California ports plans as a model of what might be accomplished. The most widely 

sample plan is that for the Ports of Long Beach and Los Angeles who have adopted the San Pedro Bay 

Ports Clean Air Action Plan (CAAP), a plan aimed at significantly reducing the health risks posed by air 

H-5 
H-6 

pollution from port-related ships, trains, trucks, terminal equipment and harbor craft. 

(http://www.cleanairactionplan.org/about/default.asp) the primary purpose of this California plan is the 

reduction of particulate matter emissions where the primary purpose of the HGB plan might be VOC and 

NOx reduction for ozone attainment. 

Rail Efficiency Measures 

This strategy suggests projects that might improve rail efficiency requiring less activity from line-haul 

locomotives. Some measures to effect this improvement could be public/private partnerships while others 

might be implemented by the railroads. 

Railroads have been improving their efficiency through technology and operational measures. The 

technologies include wheel and rail lubrication, better bearings, more efficient engines, perhaps other 

technologies yet to be identified. The operation changes include idle reduction, improved aerodynamics, 

longer trains, and improved training and evaluation of engineers to reduce braking, idling, and other 

inefficient operations. 

Program Type NOX Reduction Estimate (tons per day) 

Alternative Commuting 0.20 tpd

Regional Traffic Flow Improvement 0.05 tpd

Vehicle Retrofit and Replacement 1.30 tpd

Off-road Measures 0.70 tpd

Total 2.25 tpd