1

Perez, Idalia

From: Steckel, Andrew

Sent: Thursday, March 24, 2016 3:32 PM

To: Vanderspek, Sylvia@ARB; Sutkus, Carol@ARB; Hicks, Austin@ARB

Cc: Jeanhee Hong; Perez, Idalia

Subject: Prop 1B Benefit calculator information

Attachments: 3-23-16 US EPA Memo to File.docx

Sylvia, Carol & Austin, 

Thanks for the helpful information in your March 9 email below. 

We now understand that the emission reductions from the Prop 1B projects identified in the ARB Emission 

Reduction Report were calculated using the GMOD calculator. For the seven Prop 1B projects identified in our 

10/23/15 e-mail, could you please describe and provide specific examples of: 

· the adjustments that ARB staff made to the GMOD calculation methodologies to account for 

compliance deadlines in the Truck & Bus Regulation; and 

· the adjustments that ARB staff made to the GMOD calculation methodologies to account for VMT 

specifically within the SJV trade corridor. 

Please also submit to us any additional information used in your calculations for these seven projects (as 

provided in the Emission Reduction Report) that ARB would provide to the public upon request. 

We have attached our calculations of emission reductions associated with the Carl Moyer projects identified in 

our 10/23/15 e-mail, which are consistent with ARB's calculations for these projects in the Emission Reduction 

Report. We would appreciate your assistance on similar calculations for the seven Prop 1B projects identified 

in that e-mail. 

Finally, please submit to us the following documents from ARB's project file for one of the Carl Moyer projects 

and one of the Prop 1B projects identified in our 10/23/15 e-mail: 

· project application 

· grant contract 

· documentation of destruction of old engine 

Thank you. 

Andy Steckel 

Rules Office Chief 

(415) 947-4115 

From: Vanderspek, Sylvia@ARB [mailto:Sylvia.Vanderspek@arb.ca.gov] 

Sent: Wednesday, March 09, 2016 8:00 AM 

To: Steckel, Andrew <Steckel.Andrew@epa.gov>; Hong, Jeanhee <Hong.Jeanhee@epa.gov>
2

Cc: Sutkus, Carol@ARB <carol.sutkus@arb.ca.gov>; Hicks, Austin@ARB <Austin.Hicks@arb.ca.gov>

Subject: Prop 1 B Benefit calculator information 

The Proposition 1B Goods Movement Emissions Reduction Program (Program) emission reductions identified 

in the Report on Reductions Achieved from Incentive-Based Emission Reduction Measures in the San Joaquin 

Valley dated September 22, 2014 were calculated using the Program’s Goods Movement Online Database 

(GMOD). The purpose of GMOD is to rank potential projects based on emission reductions and costeffectiveness, which results in a list of projects that may be eligible for Program funding. ARB staff made 

adjustments to the calculation methodologies contained in GMOD to take into consideration compliance 

deadlines in ARB’s Truck & Bus Regulation to determine which portion of the reductions meet U.S. EPA’s 

definition of surplus (referred to as “early” and “extra” under Program guidelines). GMOD requires applicants 

to include the percentage of vehicle miles traveled in each specific trade corridor for each project. It provides 

the total project emission reductions which are not apportioned based on the vehicle miles traveled for a 

specific trade corridor. Staff made additional adjustments to account for the emission reductions specific to the 

San Joaquin Valley trade corridor. This provided a methodology to calculate emission reductions from Program 

funded projects that meet U.S. EPA’s criteria for SIP credit. 

In addition to GMOD, the Program also has truck calculators posted on the Program website (“online truck 

calculators”). The Program’s online truck calculators were developed for use by the public to estimate 

emission reductions based on required inputs of mileage, gross vehicle weight rating, old engine model year, 

and new engine model year. As noted above, there are several considerations that are included in ARB staff’s 

methodology for determining SIP creditable emission reductions that are not reflected in these online 

tools. These differences are summarized below. However, both tools provide a publically accessible method 

to determine estimates of the expected emission reductions from individual projects. In addition, a member of 

the public can request and receive all of the necessary information that was used in the calculation submitted 

in ARB’s staff report. 

· Unlike GMOD, the online truck calculators for FY2007-08 and FY2008-09 do not take into 

consideration compliance deadlines in ARB’s Truck & Bus Regulation. The subsequent online truck 

calculators for FY2013-14 and FY2015-16 do take into consideration compliance deadlines to calculate 

reductions. 

· The online truck calculator for FY2008-09 assumes any project with a 2010 or newer engine that 

meets the 0.2 NOx standard is a 2010 model year engine and uses a model year 2010 engine to 

calculate emission reductions regardless of the actual engine model year of the replacement 

truck. GMOD includes further refinements using the actual engine model year of the new truck to 

provide more accurate emission reductions. 

· The online truck calculators do not take into consideration the emissions that occur in each specific 

trade corridor. Staff apportioned the emission reduction results submitted for credit based on the 

percent of vehicle miles traveled in the San Joaquin Valley trade corridor.

Sylvia Vanderspek, Chief 

Air Quality Planning Branch 

Air Quality Planning and Science Division 

Air Resources Board 

(916) 324-7163 
1

Perez, Idalia

From: Hong, Jeanhee

Sent: Thursday, March 24, 2016 4:15 PM

To: Steckel, Andrew; sylvia.vanderspek@arb.ca.gov; carol.sutkus@arb.ca.gov;

austin.hicks@arb.ca.gov

Cc: Perez, Idalia

Subject: Re: Prop 1B Benefit calculator information -- corrected attachment

Attachments: 3-23-16 US EPA Memo to File.pdf

Sylvia, Carol, Austin -- Our prior e-mail had the wrong attachment, please see this attachment 

instead. Thanks. 

________________________________

Jeanhee Hong

Assistant Regional Counsel

U.S. EPA, Region IX

75 Hawthorne Street (ORC-2)

San Francisco, CA 94105

(415) 972-3921 (direct)
U.S. EPA Region 9, Memorandum to File, March 23, 2016 

Sample emission reduction calculations for selected Carl Moyer and Prop 1B projects 

Docket No. EPA-R09-OAR-2015-0489 

1 

Sample Carl Moyer Project Calculations

From Appendix H.1, which lists the Moyer projects included in the Emission Reduction 

Report, we selected the following projects: 

Project Number 

G-0014-A 

S-1301 

C-2570 

C-14205 

Of these projects, ARB provided information regarding G-0014-A, stating: 

We have included data for this item as requested. However, this project should not be 

included in the San Joaquin Valley Incentive-Based Emission Reduction Measures List. 

It is not a San Joaquin Valley project and San Joaquin Valley staff plan to fix the error. 

All San Joaquin Valley Carl Moyer Program Projects are denoted with a "C", "S", or "N" 

in the Project Number. San Joaquin Valley staff administer the Carl Moyer Program on 

behalf of Great Basin Unified Air Pollution Control District and identify these projects 

with a "G." This error was an isolated issue and no other projects requesting credit under 

the Carl Moyer Program begin with a "G." 1

We present below a sample calc S-1301 From 

page 5 of Appendix H.1, we obtained the following project information: 

Project

Number

Carl 

Moyer 

Guideline

Equipment

Identifier 

Source 

Category 

Technology

Post

Inspection 

Date 

Project

Life 

2014 

NOx 

(tpy) 

2014 

PM2.5 

(tpy) 

S-1301 2005 1 Off-Road 

Equipment -

Mobile 

Agricultural

Repower 10/16/2009 7 2.610 0.092 

Appendix C of the 2005 Carl Moyer Guidelines contains the formulas used to determine 

annual emissions and annual emission reductions based on usage information, including options 

for using hours of operation, fuel consumption and miles traveled to determine annual usage. 

Formula C-4 in Appendix C (see 2005 Carl Moyer Guidelines, Appendix C at p. C-3) is used to 

calculate annual emissions within the San Joaquin Valley based on hours of operation. Appendix 

B, Tables for Emission Reduction and Cost-Effectiveness Calculations, of the 2005 Carl Moyer 

Guidelines has tables containing the data needed to calculate the emission reductions of projects 

using formulas in Appendix C. 

Emission = EF * hp * LF* Activity * Fraction Operation in the SJV * (1 ton /907,200 g) 

 

1

12/3/2015. 
U.S. EPA Region 9, Memorandum to File, March 23, 2016 

Sample emission reduction calculations for selected Carl Moyer and Prop 1B projects 

Docket No. EPA-R09-OAR-2015-0489 

2 

Emission = tons per year calculated independently for both the existing and replacement 

engines 

EF = Emission Factor in grams per brake horsepower-hour, obtained from Table B-12 

(see Appendix B at pp. B-11) 

hp = horsepower of the engine 

LF = Load Factor, obtained from Table B-13 (Appendix B at p. B-12) 

Activity = hours per year 

Formula C-10 in Appendix C is used to calculate the emission reduction by pollutant: 

Emission Reductions = Emission baseline Emissionsreduced 

Where: Emission baseline is the Annual Emissions for the Baseline Technology 

 Emissionsreduced is the Annual Emissions for the Reduced Technology 

We use the following project project-specific information obtained from the ARB upon request2

, 

both as terms in the above equation and to look up the EFs and LFs in Appendix B. 

Engine Project Number S-1301

Equipment Identifier 1 

Equipment Category Off-Road Ag. Repower 

Equipment Type Other 

Annual Hours of Operation 1800 

Percent Operated in SJV District 100% 

Baseline Fuel Type Diesel 

Engine Year 1981 

Horsepower 320 

Engine Certification Uncontrolled 

Reduced Fuel Type Diesel 

Engine Year 2009 

Horsepower 300 

Engine Certification Tier 3 Standard 

We use the equipment category, engine year, horsepower and engine certification shown above 

to obtain the following EFs and LFs, from Tables B-12 and B-13 respectively: 

LF 0.51 

Baseline NOx EF 10.23 

PM EF 0.382 

Reduced NOx EF 2.32 

PM EF 0.088 

NOx Emission baseline = 10.23 * 320 *0.51* 1800 * 1 * (1 ton /907,200 g) 

 = 3.31 tpy 

NOx Emissionsreduced = 0.704 tpy 

NOx Emission Reductions = 2.61 

 

2

See d 

12/3/2015. 
U.S. EPA Region 9, Memorandum to File, March 23, 2016 

Sample emission reduction calculations for selected Carl Moyer and Prop 1B projects 

Docket No. EPA-R09-OAR-2015-0489 

3 

This is consistent with the data in Appendix H.1. 

PM Emission baseline = 0.382 * 320 *0.51* 1800 * 1 * (1 ton /907,200 g) 

 = 0.124 tpy 

PM Emissionsreduced = 0.027 tpy 

PM Emission Reductions = 0.97 tpy 

ARB clarified that there is a conversion ratio for Moyer calculations of 0.92 PM2.5 to the PM10

totals of exhaust. 3, Using this conversion factor, 

PM2.5 Emission Reductions = 0.92 * PM Emission Reductions 

 = 0.92 * 0.097 tpy 

 = 0.089 tpy. 

This is consistent with the data in Appendix H.1 (0.092), taking rounding errors at the third 

decimal point into account. 

The Table below shows the emission reduction values (in tpy) reported in Appendix H.1 of the 

Emission Reduction Report and calculated by EPA for the projects randomly chosen.

4

Project Number Equipment 

Identifier 

Reported 

NOx

Reported 

PM2.5

NOx Calculated 

by EPA 

PM2.5 Calculated 

by EPA

S-1301 1 2.61 0.092 2.61 0.089

3 4.04 0.120 4.04 0.124

C-2570 1 7.07 0.129 7.07 0.132

2 9.88 0.331 9.88 0.328

C-14205 1 1.57 0.055 1.57 0.055

As is evident in the table, we have verified that all examples were consistent to the second 

decimal. 

Sample Prop 1B Project Calculations

From Appendix H.2, which lists the Prop 1B projects included in the Emission Reduction 

Report, we selected the following projects: 

Equipment Project ID 

G08GMCT1_03079 

G08GMCT1_00642 

G08GMCT1_02930 

G07GMCT3_01246 

G07GMCT3_00301 

G07GMCT3_00437 

G07GMCT3_00377 

 

3

See email from Austin Hicks (ARB) to Idalia Pérez (EPA R9), dated 12/10/2015 Responses to Followup Questions

4
U.S. EPA Region 9, Memorandum to File, March 23, 2016 

Sample emission reduction calculations for selected Carl Moyer and Prop 1B projects 

Docket No. EPA-R09-OAR-2015-0489 

4 

We used the publicly available Project Benefits Calculator 5and information provided by ARB6

to verify the emission reductions. Specifically, we obtained information about each project from 

ARB, 7 such as the VMT, model year and fuel type of the old engine and the gross vehicle weight 

rating (GVWR) for the old and new engines

the corresponding Project Benefits Calculator. Based on these inputs, we divided 

emission reductions calculated by the Project Benefits Calculator by the total lifetime of the 

projects to obtain the reductions for 2014.8 

The table below shows some discrepancies between our calculations of the emission reductions 

and those provided in Appendix H.2 of the Emission Reduction Report. 

Equipment Project ID Reported 

NOx

Reported 

PM 

NOx calculated 

by EPA 

PM calculated 

by EPA 

G08GMCT1_03079 10281.32 229.63 10076.13 241.45

G08GMCT1_00642 1725.00 164.04 1680.75 176.64

G08GMCT1_02930 0.00 0.00 3374.45 1.47

G07GMCT3_01246 8012.63 235.70 8012.63 256.20

G07GMCT3_00301 394.22 22.10 2699.61 161.15

G07GMCT3_00437 3756.23 110.50 3938.27 127.78

G07GMCT3_00377 2909.29 92.69 3873.68 136.50

Information provided by ARB9indicates that the differences are due to ARB using a different 

methodology (GMOD) to calculate the emission reductions, instead of using the Project Benefits 

Calculators available on the ARB website. Broadly, the differences are due to the inability of the 

Project Benefits Calculators to account for 

Regulation and the emissions that occur specifically within the SJV trade corridor, and its use of 

emission factors different than those used by GMOD. 

 

[Insert calculations/discussion for Prop 1B projects analogous to above calculations/discussion 

for Carl Moyer projects explaining how Prop 1B emission reductions can be verified] 

 

5

See email from Sylvia Vanderspek (ARB) to 

request to support final action online truck calculators

6

12/3/2015. 

7

12/3/2015. 

8 The Project B

by 0.0005 (1 ton per 2000 pounds) to obtain the equivalent tonnage. 

9

See email from Sylvia Vanderspek (ARB) to Andrew Steckel (EPA R9), dated 3/9/2016 Prop 1 B 

Benefit calculator information