# C a r bon M onoxi d e

S t at e I m pl em ent at i o n P l an

Las V e gas V a l l ey N o nat t a i n m e nt A r ea

C l a r k C o u n ty , N e v a d a

A u gust 20 00

# A cknowledgements

CLARK COUNTY Bruce Wo odb ury, Chai r BOARD OF COMMISSIONERS Erin Kenny, Vice-Ch a irm a n Yvonne Atkin s on G a tes D a r i o H e r r e r a M a r y K i n c a i d L a n c e M a l o n e Myrna Willi ams

OFFICE OF THE Dale W. Aske w, Cou n ty Manage r COUNTY MANAGE R Richard B. Holmes, Assi stant Cou n ty Manag er Mike Ala s tue y , Assistant County Manag er

DEP ARTM E NT OF J o hn Sc h l eg el, D i r e c t or COMPREHENSIV E P L ANNING P h il Ros enq u i st

, A ssi st ant Dire ct o r Chri stine Rob i nso n , Planni ng Mana ge r Ru ssell Ro be rts, Assi stant Planning M a n ager Clete Kus, Pri n cip a l Planne r Zheng Li, Se nior Plan ner Ru ssell S. Merle Jr., Intern Planne r

CLARK COUNTY Dr. Donald S. Kwalick

, Chief Health Offic e r HEAL TH DISTRICT AQD Micha e l Nay l or, Dir e cto r AQD

AIR QUALITY William Cates, Clark County PLANNING COMMITTEE Den n is Me wshaw, M c Ca rren Internatio n a l Airport David Jame s, Tran spo r tation Re se arch Cente r , UNL V C l e t e K u s , C l a r k C o u n t y Lesli e Long, City of North Las Veg a s Susan Gray, City of Hende rso n Micha e l Nay l or, Cla r k Cou n ty Health Di stri ct Jerry Du ke, Region al Tra n sportation Co mmission Steve Koon, City of BoulderCity Ru ss Wilde, Nevad a De pa rtment of Tra n sp ortation Lori Wohlet z, City of Las Vega s

CARBON MONOXIDE STATE I M PLEMENTATION PLANPREF ACE

On Septe m ber 21, 1999, the Clark County Bo ard of Commissioners adopted the Las Vegas Valley Non-attainment Area Carbon Mo noxide Air Quality I m ple m entation Plan

. Following th e plan’s ado ption and su bmittal, the U.S. Enviro nmental Protection Age n cy, Region IX

, expressed concerns a bout several problematic areas that resulted in the emissions budget being found as inadequate. EPA also raised issues that affected the approvability of the plan. This rev i sed plan h a s been pr epared in r e sponse to these concerns so that the U.S. EPA can find Clark County’ s Carbon Monoxide State Implementat ion Plan acceptable and approve it.

This docu m ent is similar to the Septemb e r 1999, Carbon Mon o xide Air Quality Implementat ion Plan wit h the exception that ad ditional clarification, do cumentation and technical an alyses have been in cor porated. In general, th e changes are focused on control measures, cont ingency mea s ures and f u tu re year modeling. More specifically, additional d i scussion an d changes have been made to the following control measures: Voluntary Transportation Demand Management/ Transportat i on Control Measure (page 4-4), the Cleaner Burning Gasoline program (page 4-2), th e Alternative Fuel Vehicle Program (p age 4-8), and Inspectio n /Maintenance Technician Training and Certification (page 4-7). With respect to contin gency meas ures, a new set of mea s ures has been identified w h ich in clud e: On-Board Diagnostic testing, lowering of emission te sting cutpoints an d on-road re mote sensin g of vehicle s to ident ify high emittin g vehicles ( page 7-3). The final change relates to conducting a dditional micro-scale ho t spot modeling for future years for the p u rpose of v a lidating the future year emission bu dgets (page 6-7 and Appendix E).

By addressing these co ncerns and incorporating these chan ges into a r e vised plan, it is now possible for the U.S. EPA to make an adequacy determination on the emission budget and ultimately approve this plan. Clar k County is committed to working wit h the EPA to gain approval of this plan and to attainment the ca rbon mono xide standar d as expeditiously as possible.

CARBON MONOXIDE STATE I M PLEMENTATION PLAN i

# T able of Contents

PREFACE

........................................................................................................................ .......... i

GLOS SAR Y OF AC RON Y MS

................................................................................................. iv

LIST OF TABLES

................................................................................................................. .... vi

LIST OF FI GURES

................................................................................................................ . v iii

CHA PTE R ONE: INTRODUCTI O N

1.1 Introduction 1-1 1.2 Problem Statement 1-2 1.3 Physical Description 1-3 1.4 Climatological Setting 1-3 1.5 Focus of this Plan 1-8

CHA PTE R TWO: MONITORING NETWOR K AND TRENDS IN AIR QUALITY

2.1 Introduction 2-1 2.2 Background 2-1 2.3 Monitoring Network 2-2 2.4 Trends in Carbon Monoxide Air Quality 2-5

CHAPTER THREE: EMISSIONS INVENTORY SUMMARY

3.1 Introduction 3-1 3.2 Emissions Summary 3-2 3.3 Total Annual Emissions 3-4

CHAPTER FOUR: CONTROL MEASURES

4.1 Introduction 4-1 4.2 Carbon Monoxide Control Measures 4-1 4.2.1 On-Road Mobile Sources 4-1 4.2.1. 1 Cleaner Burning Gasoline 4-2 4.2.1.2 Transportation Cont rol Measures / Travel Demand Management 4-4 4.2.1.3 Technician Training and Cert i f i c a t i o n 4

- 7 4

. 2.1

. 4 Alternative Fuels Program 4-8 4.3 Off-Road Mobile Sources 4-10 4.4 Stationary Poin t and Area Sources 4-11 4.5 Previous ly Adopted Control Measures 4-11 4.6 Summary of Primary Carbon Monoxid e Control Measures 4-12

CARBON MONOXIDE STATE I M PLEMENTATION PLAN iiCARBON MONOXIDE STATE IMPLEMENTATION PLAN iii 

# T able of Contents - Continued

CHAPTER FIVE: AIR QUALITY MODELING

5.1 Introduction 5-1 5.2 Base Case Scenario Modeling 5-2 5.3 Carbon Monoxide Episode Se lection and Design Value 5-2 5.4 Assessment of UAM Model Performance 5-5

CHAPTER SIX: DEMONSTRATION OF ATTAINMENT

6.1 Introduction 6-1 6.2 2000 Base Year (No Acti on Scenario) Projections 6-1 6.3 UAM Attainment Demonstration 6-4 6.4 CAL3QHC Roadway Intersection Modeling 6-5 6.5 Micro-Scale Analysis for Airports 6-7

CHAPTER SEVEN: ADDITIONAL RE QUIREMENTS OF THE 1990 CAAA

7.1 Introduction 7-1 7.2 VMT Tracking Programs 7-1 7.2.1 VMT Projections 7-1 7.2.2 Contingency Measures 7-3 7.2.3 Annual VMT Tracking 7-5 7.3 Other Contro l Measures 7-5

CHAPTER EIGHT: IMPLEMEN TATION AND MONITORING

8.1 Implementation 8-1 8.2 SIP Implementation, Monitoring and Reporting 8-2 8.3 Maintenance 8-2 8.4 Mobile Sources Emissions Budget 8-3 8.5 Additional Commitments to Insure Conformity 8-5

REFERENCES R-1

APPENDIX A: EMISSION INVENTORY

APPENDIX B: TRANSPORTATION DOCUMENTATION

APPENDIX C: MODELING DOCUMENTATION

APPENDIX D: REGULATIONS AND POLICIES

APPENDIX E: SUPPLEMENTAL TECHNICAL SUPPORT DOCUMENTATION

# G lossary of Acronyms

ADT Average Daily Trips

AQD Air Quality Divis ion

CAAA Clean Air Act Amendment

CAL3QHC Microscale Dispersion Model ( based on California Line Source Model)

CO Carbon Monoxide

DCP Department of Comprehensiv e Planning

DTIM Direct Travel Impact Model

EPA Environmental Protection Agency

FRM Federal Reference Method

I/M Inspection and Maintenance

LVACTS Las Vegas Area Co mputer Traffic System

NAAQS National Ambient Air Quality Standards

NAMS National Air Monitoring Station

PPM Parts Per Million

RTC Regional T r ansportation Commission

SLAMS State and Local Air Monitoring Station

TCM Transportation Control Measure

TDM Transportation Demand Management

TIP Transportation Im provement Program

RTP Regional T r ansportation Plan

UAM Urban Airs hed Model

________________________ __________________ ______________________ Carbon Monoxide Stat e Implementation Plan iv__________________________________________ ______________________ Carbon Monoxide State Implementation Plan v 

# G lossary of Acronyms - Continued

VMT V e h i c l e Mi l e s T r a v e l e d

TRANPLAN Network based travel Demand Model which Estimates Vehicle Miles Traveled

MOBILE5a/5b Revised EPA Vehi cle Emission Factor Model

# L ist of Tables

Table 2-1 Las Vegas Valley Monitoring Sites Descripti ons

................................................... 2-3

Table 3-1 Demographic Data Used in Dev e loping Em issions Inv entories and to Project Activity Levels for Non-attainm ent Area

................................................ 3-1

Table 3-2 1996 Carbon Monoxide Emi ssion Summary-Average Daily CO Seas on Emi ssion

.............................................................................................. .... 3-3

Table 4-1 Recommended Carbon Monoxid e Control Measures to Reduce On- Road Mobile Source Emi ssions

............................................................................ 4-2

Table 4-2 Acceptanc e Criteria for “CBG” as a Carbon Monoxide Emissions Contro l Measure

.............................................................................................. ..... 4-4

Table 4-3 Acceptanc e Criteria for TC M/TDM as a Carbon Monoxide Emissions Contro l Measure

.............................................................................................. ..... 4-6

Table 4-4 Acceptance Criteria for Te chnician Training and Certification as a Carbon Monox i de Control M easure

..................................................................... 4-8

Table 4-5 Acceptanc e Criteria for Alter native Fuels as a CO Emissions Control Measure

...................................................................................................... ........ 4-10

Table 4-6 Previously Adopted Enforceabl e Carbon Monoxide Cont rol Measur es

.............. 4-12

Table 4-7 Primary Control Measures, Benefits, and Cost E ffec t ivenes s

............................. 4-13

Table 5-1 List of Highest 10 CO Ep isodes Based on Peak 1- and 8-hour Average CO Concentrations. Values Reported for East Charleston (EC) and Sunris e Acres (SA)

................................................................................. 5- 3

Table 5-2 Model Performance Statis tics for December 8-9, 1996 Comparing Scaled UAM 8-hour A v erage CO C oncentrations with Measurements from all Sites Operate d During the Fiel d Study

..................................................... 5-5

Table 6-1 1996 & 2000 Base Years Car bon Monoxide Modeling Emissions for The Las Vegas Valley Nonattainment Area

.......................................................... 6-3

Table 6-2 Proposed Enforceabl e CO Control Measures

....................................................... 6-5

Table 6-3 UAM Maximum Predicted Ambi ent Concentrations for the Various Scenarios

.................................................................................................... .......... 6-5

________________________ __________________ ______________________ CARBON MONOXIDE STATE I M PLEMENTATION PLAN vi__________________________________________ ______________________ CARBON MONOXIDE STATE IMPLEMENTATION PLAN vii 

# L ist of Tables – Continued

Table 6-4 Maximum Predicted 8-Hour CO Concentrations for Hot Spot In tersections................................................................................................ .......... 6-7

Table 6-5 Maximum 8-hour Carbon M onoxide Concentrations (ppm) From County Operated Airports for Four Modeling Years (Base Case Estimates Assume no Additional Controls on Motor Vehicles)

................................... 6-9

Table 7-1 Average Daily VMT Estimates and Forecasts by Func tional Cate gory................. 7-2

Table 7-2 Contin gency Meas ures ......................................................................................... 7-3

Table 7-3 Insurance Control Meas ures ................................................................................ 7-5

Table 8-1 Control Measur e Implementatio n Status............................................................... 8-1

Table 8-2 VMT Estimates for Monitoring and Ma intenanc e .................................................. 8-3

Table 8-3 Las Vegas Valley Peak Season Emission Budgets by Source Categor y ..................................................................................................... .......... 8-4

# L ist of Figures

Fig. 1-1 Las Vegas Valley Car bon Monoxide Non-attainment Area. 1-5

Fig. 1-2 Three Dimensional Perspective of the Las Vegas Valley Modeling D o main as Viewed from the Southwest. 1-6

Fig. 1-3 Las Vegas Carbon Mono xide Wind Drainage Patterns. 1-7

Fig. 2-1 Las Vegas Valley Car bon Monoxide Monitoring Sites Locations. 2-4

Fig. 2-2 Carbon Monoxide Air Q uality Trends - Unhealthy Day s

. 2-6

Fig. 2-3 Carbon Monoxide Air Q uality Trends - Exc eedence Days. 2-7

Fig. 3-1 1996 Annual CO Emissions by Source Category. 3-4

Fig. 5-1 Analysis of Maximum 8-hour CO Concentration Measurements (ppm) in Central Las Vegas on December 8-9, 1996. 5-4

Fig. 5-2 Graphs Comparing Observed CO Concentrations and UAM Predicted Concentrations at a Corresponding Site. 5-6

Fig. 6-1 CAL3QHC Intersection Location Map. 6-6

________________________ __________________ ______________________ CARBON MONOXIDE STATE I M PLEMENTATION PLAN viii

# C hapter One - Plan Introduction

1.1 INTRODUCTION

1.2 PROBLEM STATEMENT

1.3 PHYSICAL DESCRIPTION

1.4 CLIMATOLOGICAL SETTING

1.5 FOCUS OF THIS PLAN1.1 INTRODUCTION

The 19 90 Clea n Air Act Amend ments (CAAA) redefin ed the n a tional air po llution abatement framework and established ambit i ous policies to carry out air qu ality planning and control activities. T he r equirements mandated by t he CAAA affect the Las Vegas Valley in many ways. Two National Ambient Air Quality Standards (NAAQS) have been established for carbon monoxide. The 1-hour standard has a maximum allowable concentrat ion of 35 parts per million (ppm). The 8-hour standard is a maximum average of 9 ppm over an 8-hour period. Areas that violate one or both of the am bient standards more than two times in a two-year period are classified as non-a ttainment areas for carbon monoxide.

Previous ly, portions of the Valley violat ed the NAAQS f o r ca rbon monoxide (CO) during the winter months. The number and se verity of the CO vi olations caused the U.S. E n vironmental Pr otection Agency (EPA) to des ign a te the Valley as a Moderate nonattaiment area on November 15, 1990. Moderate nonattainment areas were required to implement emission control measures as “expeditious ly as practicable” in order to attain t he CO N AAQS by December 31, 1995. The Clean Air Act requires that moder ate nonattainm ent areas implement the following c ontrols:

1. An oxygenated gas oline program during the winter months that require gasoline to contain no less than 2.7% oxygen by weight;

2. An enhanc ed vehicle inspection and maintenance program meeting the Clean Air Act’s criteria;

3. Forecasts of vehicle m iles traveled (VMT) in the region, procedures for annua l updates and reports attesting to the accu rac y of the forecasts, and estimates of actual VMT based on tra ffic counts on area roadways;

4. Contingenc y measures that must be implemented if actual VMT exc e e d s forecasted VMT or if the area fails to a ttain the standar d by the applicable date; and

5. Transportation control measures necessa ry to demonstrate attainment of the standard (section 187( b)(2)).

Clark County implemented the above lis ted controls and made great strides towards attaining the N AAQS for carbon m onoxide but, due to the phenomenal growth the valley experienced during this decade, it fell short of meeting the NAAQS by the applicable dat e of December 31, 1995.

Improved carbon monoxide levels, attr ibuted to the impleme n tation of the aforementioned control measures, resu lted in Clark Count y being granted a oneyear extension to demonstrate complianc e with the NAAQS. Ho wever, the Las

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 1- 1Vegas Valley was not successful in ac hieving compliance by December 31, 1996. T h e CAAA requires that the area be “bumped“ up, or be reclassified as a “serious” nonattainment for carbon monoxide.

The notice of violation reclassifyi ng the area was published in the Federal Register on November 3rd, 1997. A deadline of May 1999 (18 months from the notice publication dat e) is set by the CAAA for submission of a control strategy implement ation plan demonstrating atta inment of the NAAQS for C a rbon Monoxide by Decem ber 31, 2000. This document r epresents such a plan in fulfillment of sections 107 and 110 of the CAAA.

1.2 PROBLEM STATEMENT

The Las Vegas Valley has been reclassifi ed as a serious nonattainment ar ea for CO air pollution after failing to a ttain the standard by the ex tended CAAA deadline of December 31, 1996. Although t he Valley has never exceeded the 1- hour standard, the 8-hour st andard was being exceeded at least once per year
on a seas onal bas is. During the winter m onths local inversions stagnate air masses and trap pollutants. The over night buildup of pollutants causes exceedanc e violations of the CO 8-hour air quality standard in a limited area surrounding the Sunrise Acres monitoring station.

While the East Charleston station recorded 10 exceedances during the 1991- 1992 winter season, the number of exc eed ances was reduced t o 1 in 1995, 3 in 1996, 1 in 1997, and 2 in 1998. This downt rend is the direct result of the implement ation of CO c ontrol measures. The Ea st Charleston (recently relocated and re-named Sunris e Acres) moni toring sit e is adjacent to converging major transportation corridors named t he “Five Points” where three state highways intersect. Additionally , the site is located in a topographic bowl where air pollution often collects. In the 1996 s e ason, the highest 8-hour average CO concentration also oc curred in the “Five Points” area and meas ured 10.2 parts per million.

As mentioned above, the Las Vegas Valley is required to attain the standard by December 31, 2000. The CAAA requires s e rious non-attainment areas to meet all the requirements for moderate areas listed p r eviously, in add ition to implementing the following meas ures:

1. Gasoline s o ld during winter months must contain a leve l of oxygen as necessary, in combination with other measur es, to provide for attainment of the standard. EPA may waive this requiremen t if the area demons trates that the revision is not necess a ry to provide fo r attainment of the CO standard by the applicable attainment date and maint enanc e of the standard thereafter.

2. Mandatory employer-based travel reduc tion program for employers of 100 or more people that r equires each empl oyer to inc r ease average vehic l e

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 1- 2occupancy for commute trips by at leas t 25% over the regional average. Howev e r, this requirement can be avoided if the area can s h ow that suc h a program is not needed to demonstrate at tainment of the st andard or that a comparable emission reduction is achieved by other measures.

3. An economic incentive program cont aining fees and marketable permits if emission reduction milestones are not met by December 31, 2000.

4. Beginning in 1997, regi onal transportation plans must specific ally describe the transportati on system for future horizon y ears. This requir es the Regional Transportation Commission Board to approv e specific projects and programs for 2000, 2010, 2020.

1.3 PHY S ICAL DESCRIP T ION

The Las Vegas Valley Nonattainment Area, which c o incides, with Hydrogr aphic Basin 212, is illustrated in Figure 1-1. This area inc l udes the City of Las Vegas, the City of North Las Vegas, and the Ci ty of Henderson. The remainder constitutes unincorpor ated areas of Clark County. The Las Ve gas Valley airshed extends in a northwes t -southeast directi on bounded by the Spring Mountains to the west; the Pintwat e r, Desert, Sheep, and Las Vegas Mountains to the north; and Frenc hman Mountain to the east. The McCullough Range and Big Spring Range close the airshed to the south. The airshed covers approximately 500 square miles. The Valley drains toward the south and then easterly through Las Vegas Wash to Lake Mead. The upper boundaries of the alluv i al apron occ u r at approximately 4500 feet and ar e marked by a noticeable change in slope. T he lower boundaries of the apron are les s well defined due to massive sedimentation on the valley floor, but occur at an aver age elevation of approximately 2500 f eet. The basin lo wland levels of the Las Vegas Valley range from 1800 to 2500 feet. Figure 1- 2 provides a three dimen s iona l topographical perspec tive of the Las Vegas Valley modeling domain.

1.4 CLIMATOLOGICAL SETTING

The Las Vegas Valley is situated on the edge of the Mojave Desert and experiences an arid c limate typical of t he southern Mojave Desert. Due to the "rain shadow" effect of the Sier ra Nev ada Range and Spring Mountains to the west, moisture associated with storms or i g inating in the Pacific Ocean rarely reaches the Valley. Dry ai r masses move over the valle y resu lting in c l e a r to partly cloudy skies with 85 percent sunshine for an average year.

Temperatures range from an average daily maximum in July of approximately 104 degrees to an average daily maxim u m in January of approximately 56 degrees. Average daily minim u ms range from 33 degrees in January t o 75 degrees in July. Winters are gener ally mild and summers are hot.

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 1- 3Surface meteorology in the Las Vegas Valley is generally characterized by prevailing s outhwesterly winds wit h mont hly average wind speeds ranging from 7 to 11 miles per hour. Lower wind speeds are prevalent during the winter months with a windy season throughout mu ch of the spring. Winds in excess of 40 miles per hour are infrequent. During these ev ents, periods of wind gusts, blowing sand and dust are prevalent. In additio n to prevailin g winds, a pattern of local winds, generated by local topography and tem perature, also affect the Valley

. During the day, as the air mass is heated, wind directions are generally ups l ope and in a westerly gradient. At night, the wind direction is reversed and cool air drawn from the higher elevat ions drains to t he lower Va lley. Figure 1-3 displays the evening wind drainage patterns of the Las Vegas Valley.

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 1- 4FIGURE 1-1

(...... .) The dotted line around the non -at t ainment area (Bas in 212) repres ents a 25-mile z o ne to

con s id er sou r ce s that may contri bute CO emission s.

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 1- 5FIGURE 1-2

THREE-DIMENSIONAL PERSPECTI VE OF THE LAS VEGAS VALLEY MODELING DOMAIN AS VIEW ED FROM THE SOUT HWEST

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 1- 6CARBON MONOXIDE STATE I M PLEMENTATION PLAN 1- 7CARBON MONOXIDE STATE IMPLEMENTATION PLAN 1-8 1.5 FOCUS OF THIS PLAN

The remainder of this document consists of seven chapters, each addressing a specific topic. These chapter s are briefly summarized below:

Chapter 2, "Carbon Monoxid e Monitoring Network and Tr ends in Air Quality," provides information on the monitoring network and CO air quality trends.

Chapter 3, "Emission Inventory Summa ry," presents the 1996 base year emissions inventory for stationary, area, and mobile sources (on- and off-road) as required under the 1990 CAAA.

Chapter 4, "Control Measures," introduces and describes the control strategies, which will result in reducing CO emi ssions and lead to attainment status.

Chapter 5, "Air Quality Modeling," descr ibes the modeling process for the 1996 base case utilizing the Urban Airshed Mode l including the preparation of inputs and the model’s performance.

Chapter 6, "Demonstration of Attainm ent," describes the modeling analysis demonstrating attainment of the NAAQS and summarizes the CO concentrations with recommended control measures.

Chapter 7, "Additional Requirements of the 1990 Clean Air Act Amendments," presents forecasts of vehicle miles traveled (VMT) and identifies the agencies responsible for preparing VMT tracking re ports. Contingency measures which will be enacted if actual VMT counts exc eed projected VMT ar e also discussed.

Chapter 8, “SIP Commitments / Implem entation”, discusses the implementation of control measures, monitoring progr ess, emissions budget, maintaining attainment once it is achieved and concludes with a brief discussion on areas/issues to receive additional study.

The Appendices are divided into four se ctions. Appendix A contains the “1996 base year Carbon Monoxide Emission In ventory for the Las Vegas Valley Nonattainment Area”. A ppendix B consists of the “Transportation Control Measure Analysis Report” and associat ed data. Appendix C accommodates modeling documentation incl uding the attainment demonstration, emission reduction calculations and associated cost s. Appendix D cont ains regulations and policies associated with the control m easures documenting the enforceability of these control measures. Appendix E co nsists of additional technical support documentation for the control measur es and supplemental modeling analyses that support the future year emission budgets.

# C hapter Two- Monitoring Network and Trends in Air Quality

2.1 INTRODUCTION

2.2 BACKGROUND

2.3 MONITORING NETWORK

2.4 TRENDS IN CARBON MONOXIDE AIR QUALITY2.1 INTRODUCTION

This chapt er provides some backgr ound about carbon monoxide (CO) air pollution and a brief summary of the Las Vegas Valley CO monitoring network as of July 1999. In addition, this chapter pr ovides a disc ussion of t he trends in air quality for CO over the past sev e ral year s. The CO samplin g program indicates that air quality is improvi ng. T he reasons for these positive developments in recent years are briefly discussed.

2.2 BACKGROUND

Carbon monoxide occurs in the atmos phere as the result of incomplete combustion of fuels. In Las Vegas, as in other urban areas, motor vehicles ar e the major source of CO emissions, comp rising approximately 88 percent of total daily emiss i ons and even more in the late afternoon and evening hours when exceedenc es of the standard ar e usually recorded. For more details on the sources of CO emiss i ons and a breakdown of contribution by c a tegory refer to Chapter 3 of this document.

Carbon m onoxide is a colorles s, odorle ss , and tasteless gas. CO enters the body through the lungs, where it is absorbed by the bloodstream and then combines with hemoglobin in the red bloo d cells. Hemoglobin is the compound in the red blood cells that normally picks up oxygen from the lungs and carries it to the tiss ues. When CO binds with hemoglobin, it forms a compound calle d carboxyhemoglobin (COHb). COHb dim i ni shes the blood’s c apacity to carry oxygen. Hemoglobin has mo re affinity for CO than oxygen. Furt hermore, once attached it does not dissociate from the hem oglobin as readily as oxygen does at the tissue level. As a result, with cont inue d exp o sure to CO, COHb levels will continue t o increase in the bloodstr eam and the amount of oxygen being distributed throughout the body is reduced.

At greatest risk from CO expos ure are individuals wit h cardiovascular dis e ase, chronic obstructive pulm onary disease, pr egnant wom en, and children. Even healthy individuals can experience adverse effects from CO exposure, such as reduced ab ility to conc entrate. CO exposur es in h i ghe r altitude a r eas present a greater risk because of the i nherently low-oxygen atmosphere.

Blood laden with CO can we aken heart contractions, lo wering the blood volume being distributed to the body. A life-threatening situati on exists in-patients with heart disease, which are unable to com pensate for the loss of oxygen. The millions of people in the U. S. th at have a conditio n k nown as a n gina pect o ris (characterized by brief, spasmo dic attacks of chest pain due to reduced blood flow to heart muscles) may also be mo re sensitive to exposure to CO.

CARBON MONOXIDE STATE I M PLEMENTATION PL AN 2-1CO also affects the central nervous system by depriving it of oxy g en. Studies of automobile drivers reveal that expos ure to CO can i m pair a driver’s judgement and ability to respond rapidly to emergency traffic situati ons.

In order to protect public health and the environment, the U. S. Environmental Protection Agency (EPA) established spec ific standards for CO in 1971. The most stringent standard of 9 parts-per-m illion (PPM) is a v eraged ov er a rolling 8- hour period, while the maximum allowabl e hourly conc entration is 35 PPM. EPA is mandated by the Clean Air Act to revi ew the standard every 5 years. EPA has periodic a lly reviewed the CO standards and has made no changes to the current standards.

2.3 MONITORING NETWORK

The U.S. EPA has e s tablishe d ambient air quality monitoring requirements and standards for State and Local Air Monitori ng Stations ( S LAMS) a nd for National Air Monitoring Stations (NAMS). Thes e requirements and standards provide for operating schedules, data qualit y assurance, and for the design and siting of CO samplers. Table 2-1 below provides some details about the monitoring sites. Each of the air qualit y monitoring stati ons utilizes a Dasib i Car bon Mono xide Analyzer ( M odel 3003) which em ploys the Gas Filter Corre lation technique. The monitoring schedule is continuous

. The Carbon Monoxide air-monitoring netwo rk in the Las Vegas Valley has evolved int o a system of 15 monitoring sites (see Table 2-1). There are 7 SLAMS s i tes, 4 NAM S sites, and 4 spec ial purpose monitoring sites. The Air Quality Division (AQD) of the Clark County Health Dist rict operates and administers the air-monitoring program. T he system is governed by a set of quality assurance and quality control procedures approved by the EPA and is subject to periodic performance audits by the EPA. Quarterly air quality monitoring reports are being p r epared and submitted to the EPA. Carbon monoxide s a mpling loc a tions are identified in Figure 2-1 below.

CARBON MONOXIDE STATE I M PLEMENTATION PL AN 2-2TABL E 2-1

LAS VEGAS VALLEY CARBON MONOXIDE MONI TORI NG SITE DESCRIPT IONS

_

___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ __

_

___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ____ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ _ S I TE N A M E A D D R E S S T Y P E * E L E V A

TI O N

B o u l de r C i t y 1005 I n du s t r i a l & U S 95 A P C D 2391'

C i t y C e n t e r 559 N

. 7t h S t r e e

t N A M S 2020'

C r a i g R o a d 4701 M i t c h e l l S t r e e

t S L A M S 1919'

C r e s

t w o o d 1300 P a u l i n e W a y N A M S 1958'

E a s

t F l a m i n g o 210 E

. F l a m i n g o S L A M S 2017'

E a s

t S a h a r a 4001 E

. S a h a r a A v

e

. S L A M S 1692'

He a l t h D i s t r i c t 625 S h a d o w L a n e S L A M S 1935'

G r e e n V a l l e y 248 A r r o y o G r a n de A P C D 2010'

S

. E a s

t V a l l e y 545 L a k e M e a

d D r

. S L A M S 1870'

W i n t e r w

o o d 5483 C l u b Ho u s e

D r

. S L A M S 1708'

P

a u l M e y

e r 4525 N e w

F o r e s

t D r

. A P C D 2309'

P i t t m a n 1137 B o u l de r Hi g h w a

y A P C D 1699'

S

.

L

. V

.

B l v d 3799 S o u t h L

. V

.

B l v d

. N A M S 2079'

S u n r i s e

A c r e s 2501 S

. S u n r i s e

A v

e

. N A M S 1889'

J

. D

. S m i t h 1301B E a s

t T o n o pa h S L A M S 1775'

_

___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ _ * Notes: AQD = Air Quality Div ision S pecial Purpose (monitoring) Location Source: Clark County Health District (July, 1998)

CARBON MONOXIDE STATE I M PLEMENTATION PL AN 2-3CARBON MONOXIDE STATE I M PLEMENTATION PL AN 2-42.4 TRENDS IN CARBON MONOXIDE AIR QUALITY

An exc eedence of the 1-hour CO nat ional standard (35-PP M) has never been recorded within the Las Vegas Valley. Exc eedence events are limited to the 8- hour national standard (9-PPM). During t he past several years, the Las Vegas Valley has experienc ed a s ubstantial impr ovement in CO air quality. On an annual basis, there has been a trend towards a reduc tion in the number of exceedenc e events and a reduction in t he intensit y of CO concentrations. Figures 2-2 & 2-3 below ill ustrate this improving CO picture graphic a lly.

Apart from a wint e r season with fe wer inversions, annual reductions in exceedenc e events and CO concentrations are attributed to the following:

1) Improved motor vehicle emission control technology and the continued displacement of older and poorly maintained vehicles;

2) The wintertime oxygenated gasoline program;

3) Reduced Reid Vapor Pressure (RVP) in gasoline;

4) Requirements for annual vehic l e smog tests for mo tor vehicles, including medium and heavy duty gasoline vehicles;

5) The computerized traffi c signal management program; and

6) The use of the east leg freeway and other roadway im provements.

During 1997 and 1998, the Las Vegas Valley experienc ed only f our unhe alt h ful days and three exceedence days. In 1999, there were no unhealthful or exceedenc e days rec o rded in the Valley. These unhealthful and excee d ence days were recorded at the Sunris e Acres (old East Charleston) st ation. None of the other monitoring stati ons reported any unhealthful epis odes or exce edences during thes e same per iods. A day is c l assified as “unh ealth ful” when monitoring data indic a te that carbon monoxide le v e ls are above 100 on the pollution standard index (PSI). The PSI, also kn own as the air quality index (AQI), was develo ped by the EPA in 1 976 to pr ovide acc u rate, timely, and easily understandable information about daily levels of air pollu tion. A PSI level of 100 was set to equal the national ambient air quality standard (NAAQS) for a given regulated pollutant. T he PSI scale is divi ded into the following ranges, whic h are in turn attributed to th e following health levels:

0 - 50 Good 51 - 100 Moderate 101 - 200 Unhealthful 201 - 300 Very unhealthful
≥ 300 Hazardous

CARBON MONOXIDE STATE I M PLEMENTATION PL AN 2-5In the case of the Las Vegas Valley’s air monitoring system, operated by the AQD, a PSI of 113 (9.5 PPM for an 8-hour average) or above would translat e into an exceedence of the NAAQS.

FIGURE 2-2

LAS VEGAS VALLEY CARBO N M O NOXI DE AIR QUA L IT Y TRENDS - UNHEALTHY DAYS

32 41

38

34 48

39

24 27 34

17

14

5 8 8 7

4

1 3

0 0 10 20 30 40 50 601981198219831984198519861987198819891990199119921993199419951996199719981999

Ye arNumber of Days

CARBON MONOXIDE STATE I M PLEMENTATION PL AN 2-6FIGURE 2-3

LAS VEGAS VALLEY CARBO N M O NOXI DE AIR QUA L IT Y TRENDS - E X CEEDENCE DAYS

27 32 33

24 41

32

18 22 27

13

6

2 3 4

1 3

1 2
0 0 5 10 15 20 25 30 35 40 451981198219831984198519861987198819891990199119921993199419951996199719981999

Y earNumber of Days

CARBON MONOXIDE STATE I M PLEMENTATION PL AN 2-7

# C hapter Three - Emissions Inventory Summary

3.1 INTRODUCTION

3.2 EMISSIONS SUMMARY

3.3 TOTAL ANNUAL EMISSIONS3.1 INTRODUCTION

The CAAA require that all nonattainment areas prepare a bas e year inventory that is com p rehensive, accurate, and current with respect to actual emiss i ons in the area [Section 182(a)(1)]. The peak season and modeli ng inventories are based on this invent ory. This sect ion s u mmarizes the 1996 base year CO inventory for the Las Vegas Valley Nonattainment Area. The inventory addresses CO emissions from the following four major type categories: stationary point sour ces, area sources, on-road mobile sources, and non-road mobile sources. The intent of this section is to provide a brief overview of the sourc e categories and the as sociated m e thodologie s employ ed to estimate emissions. More detailed information pertaining to the inventory can be found in the “Carbon Monoxide Emission I n ventory for the Las Vegas Valley Nonattainment Area,” contained in Appendix A.

The Clark County Department of Comprehensive Planni ng (DCP) is the agency responsible for preparing and submitting the Clark C ounty, Las Vegas Valley Nonattainm ent Area 1996 base y ear CO emi ssions inv entory. The DCP is also responsible for coordinating and supervis i ng the com p leti on of each part of the inventory. Several other local agencie s contributed information necessary for preparing emissions estimates. These agencies inc l ude the AQD, Clark County Regional Transportation Commission (RT C ), Clark County Department of Aviation, and the Clar k County Fire Depar tment. Additional information sources included the Nevada Departm ent of Transportation, U.S. Forest Service, and Southwest Gas Corporation.

The point source inv entor y was prepared primarily from a mail survey by the AQD. Survey results were supplem ented by information obt ained through personal c ontacts during compliance in sp ections. VMT data necessar y to calculate on-road mobile source emission s was prov ided by t he RTC. The DCP ran the MOBILE5b model to determine v ehicle emission factors from on-road mobile sources. Table 3-1 below contains demographic information for Clark County. Table 3-1

Demo graphi c Data Used in Developi ng Emissi on Inventorie s an d to Proje c t Activity Levels for No n-attainm ent Area*

Ja n u a r y P o pu l a t i o n E m pl o y m e n t V M T
1996 1, 037

, 844 493, 2 1 3 22, 46 9, 020
2000 1, 269

, 600 609, 4 0 0 24, 92 9, 48 5
2010 1, 790

, 700 859, 5 0 0 38, 022

, 3 3 0
2020 2, 406

, 500 1, 11 5, 10 0 57, 49 2, 3 3 3

* D a t a i s ba s e d o n R e g i o n a l T r a n s p o r t a t i o n C o m m i s s i o n 1997 E s t i m a t e s / P r o j e c t i o n s

_

___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ CARBON MONOXIDE STATE I M PLEMENTATION PLAN 3- 13.2 EMISSIONS SUMMARY

The results of the Las Vegas Valley 1996 base year CO emissions inventory for stationary point and area sources, on-road mobile sources, and non-road mobile sources categories are tabulated in this section. The biogenics cat e gory has been omitted, as it is not applicable to carbon monoxide emissions. Table 3-2 below contains a detailed listing of average daily, CO season emissions by source category. Large stationary source s at the periphery of the nonattainm ent area (State Hydrographic Basin No. 212) have also been included in the inventory.

_

___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ CARBON MONOXIDE STATE I M PLEMENTATION PLAN 3- 2TABL E 3-2

1996 CARBO N MO NOXIDE EMISSION SUMMARY -Averag e Dail y CO Season Emissio n

SOURCE CAT E GORIES E m i s s i ons Em i s s i on ( T o n s / Day ) ( P er c ent) ST AT IONARY POINT SOURCES

T i tanium Metals 2.92 0.61 Ker r Mc G ee- BMI 0.24 0.05 Chem ic al Lim e Co. Apex 0.82 0.17 Bonanz a Mater i als 0 .28 0 .06 J a m e s Har d ie G y ps um 0.55 0.11 Souther n Nevada Paving 0.55 0.11 Pabc o Cogener ation/NCA 2 0 .55 0 .11 G eor gia Pac i f i c @ Apex /NCA 1 0 .62 0 .13 Point Sourc e T o tal 6 .53 1 .36

AREA SOURCES

Sm all Stationar y 2 .7 0.56 Boiler Em is s i ons 0.38 0.08 F i r eplac es 2.12 0.44 Struc t ural Fires 0 .64 0 .13 V e h i cu l a r Fi re s 0 .0 5 0 .0 1 Br us h F i r e s 1 .26 0 .26 Res i dential Natur a l G a s 0 .31 0 .06 C o m m e r c ial N a tur a l G a s 0 .09 0 .02 Indus tr ial Natur a l G a s 0 .32 0 .07 Elec tr ic al Utility G ener ation 0 .56 0 .12 Cigarette Sm ok ing 0 .04 0 .01 Area Sourc e T o tal 8 .47 1 .8

NON-ROAD MO BILE SOURCES

County Air por ts 36.4 7 .6 N e llis Air F o r c e Bas e 2.86 0.6 Loc om otive Em is s i ons 0.23 0.05 Law n & G a r den Equipm ent 3.57 0.75 Cons tr uc tion Equipm ent 9.77 2.04 MC & Rec r eation Equipm ent 5.9 1 .23 Non- Road T o tal 58.73 12.3

O N -RO A D MO BILE SO URCE 405.4 84.61

G R AND T O T A L 479.13 100

_

___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ CARBON MONOXIDE STATE I M PLEMENTATION PLAN 3- 33.3 TOTAL ANNUAL EMI SSIONS

Total average annual CO emissions a ssociated with the Las Vegas Valley Nonattainm ent Area for the 1996 base year are 479.1 tons per day. Figure 3-1 depicts the relative magnitude of annual contribution by each source category and indicates that the percent contributions of emissions by source category are consistent on both a seasonal and annual basis.



### Fi gur e 3

- 1

199 6 A n n u a l CO E m i s s i o n s by So ur ce

Ar ea S o u r c e s 2% N on -R oa d S o u r c e s 12 % Sta t iona r y So u r c e s 1%

O n R o ad M obi l e So u r c e s

85 %

_

___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ ___ CARBON MONOXIDE STATE I M PLEMENTATION PLAN 3- 4

# C hapter Four – Control Measures

4.1 INTRODUCTION

4.2 CARBON MONOXIDE CONTROL MEASURES

4.2.1 On-Road Mobile Sources 4.2.1.1 Cleaner Burning Gasoline 4.2.1.2 Transportation Control Measures / Trip Demand Management (TCM/TDM) 4.2.1.3 Technician Training and Certification 4.2.1.4 Alternative Fuels Program

4.3 OFF-ROAD MOBILE SOURCES

4.4 STATIONARY POINT AND AREA SOURCES

4.5 PREVIOUSLY ADOPTE D CONTROL MEASURES

4.6 SUMMARY OF PRIMARY CARBON MONOXIDE CONTROL MEASURES4.1 INTRODUCTION

About 86 percent of the CO emissions in the Las Vegas Valley in 1996 were produced by on-road motor vehicles. Non -road mobile sources contributed about 11 percent . Stationar y, point, and area s o urces accounted for the remaining 3 percent of the total emissions. This c hapter presents the control measures being implement ed in order to attain the CO NA AQS. The identifi ed control measures are those which are considered to offe r the most potential for reducin g carbon monoxide emissions. Particul ar attention is given to control measures for onroad motor vehicles. The Lima & Asso ciates report (Appendi x B, Section 1) contains additional information and ca lc ulations on the costs and emission reductions of some of these control m easures. This chapter c oncludes with a discussion on off-road mobile s ources, area sources, and stationary sources control measures c ontained in t he 1995 Carbon Monoxide Air Q uality Implementation Plan for the Las Vegas Valley Nonattainment Area. These control measures have pr eviously been implemented.

4.2 CARBON MONOXIDE CONTROL MEASURE S

Regulations and resolutions in support of the control measur es necess a ry for attainment have already been adopted and bec ame effective at the end of 1999 (Appendix D). Control measures and progr ams from previous plans which are listed later in this c hapter, serve as the foundation upon which additional measures will be added to s h ow attain ment of the standar d. When fully implement ed by the end of the year 2000, the proposed c o ntrol measures discussed belo w , along with all the contro l measures implem ented to date, will reduce CO emissions from on-road motor v ehicles by over 22 percent from 1996 levels. The control measures outlined in this section are sufficient to ensur e attainment and maintenance of the CO NAAQS by t he des ign a ted attainment date, and target the largest contributing source categor y, mobile s o urces. Contingenc y measures, which will be implemented if VMT estimates are exceeded or if needed to attain and/or ma intain the federal standard, are addressed in Chapter 7 of this documen t. Table 4-1 below summarizes the three primary control measur es relied upon in demonstr ating attainment with the CO NAAQS. Each c ontrol measure is list ed along with its estimated reduction benefit; adoption dat e; and the agency res ponsible for its implement a tion, enforcement, and monitoring.

4.2.1 On-Road Mobile Sources

On-road motor vehicles include passenger cars, light-duty trucks, medium-duty vehicles, heavy-duty vehicles, and motorcycl es. Proposed strategies for reducing CO emissions from on-road moto r vehicles include Cleaner Burning Gasoline (CBG) for the winter season, some voluntary Traffic Control Measures / Trip Demand Management (TCM/TD M) programs, Vehicle Inspection Maintenance Program Technician Traini ng and Certification and an Alternative

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 4-1Fuels Program (AFP) for government fleets. Table 4-1 identifies these federally enforceable and voluntary mobile sour ce CO control measures and their anticipated emission reductions by the end of the year 2000. The remainder of this chapter summarizes these control measures, including their effectiveness and implementation. TABL E 4-1

RECO MMEN D ED CA RBO N MO NOXID E CONT RO L MEASURES TO REDUCE ON-ROA D MOBILE SOURCE EMISSIONS

Control Mea s ure Year 20 00 E m issi on Red u ctio n Adoption Date Re spo n si ble Agency

Clea n Burnin g Gasoline 9.8% 1999 Health Distri ct

Voluntary Tra n sp ortation Control Measures / T r an spo r tation Dema nd Ma n ageme n t 0.08% 1999/O ngoi n g RTC

Tech nici an Training a nd Certification 2.95% 1988 DMV&PS

Alternative Fuels Program for Govern ment Fleets 0.12% 1991/O ngoi n g NDEP/Govt. Entities

Combi ned Effect of Cont rol s 12.2%

4.2.1.1 C l eaner Bu rning Gasoline (CBG)

The Clark County Dis t rict Board of Health is the governing board r e sponsible for promulgating regulations fo r a Cleaner Burning Gasoli ne progra m and the Clark County Health District Air Quality Division (AQD) is the agency responsible for administering their implementati on. This authority is ve sted in the He alth District through Chapter 445B of the Nevada Rev i sed Statutes ( NRS 445B). The AQD is also responsible for administering the existing oxygen ated fuels program.

CBG is a low sulfur and low aromatic fuel. S u lfur and aromatics in fuel adhere to manifolds, piping, and catalytic converters reducing the efficiency of air pollution control dev ices. It has been shown that r educing sulfur and arom atic lev e ls in gasolines increases c a talytic converter ef fectivness, resulting in lower CO, as well as other air emissions. On April 22 , 1999, the Clark Count y District Board of Health adopted sectio n 54 of the Air Pollution Cont rol Regulations to implement the CBG program starting November 1, 1999 to Ma rch 31, 2000 and each such winter season thereafter. Under this program compliance can be achieved by one of two methods: a flat limit of 40 ppm by weight for sulfur and 25 percent for

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 4-2aromatics; or a maximum su lfur limit of 80 ppm by weight and 30 percent for aromatics with averages not exceeding 30 ppm and 22 percent respectively.

Adoption of the aforementi oned limits will lower CO emissions from gasoline powered m o tor vehicles in the Las Vegas Va lley by approximately 31.9 ton s per day, or by 9.8% above and beyond the benefits provided by existing control measures (RVP, 3.5% oxygenated fuel, etc.). The current State and local regulations for Reid Vapor Pressure of 9 psi and oxygen content of 3.5 % by weight will not chang e. It is estimated that cons umers would pay between 2 and 5 cents more per gallon for this improvement for a total annual c o st to the public of about 15 million d o llars. The cost effectiveness for this much needed CO emission r eduction will aver age about $1,225 per ton of CO reduced. CBG can satisfy all eight acc e ptance crit eria c onstit u ting a pplicable State and Federal requirements for the adoption of a fuel cont rol measur e. Thes e criteria inc l ude the following: practicality, reasonableness, reliability, its necessity for attainment, effectiveness, safety, cost effectiveness, and availability of technology. Table 4-2 summarizes how the acceptanc e criteria are met for CBG as a CO emission control measure.

The AQD is also responsible for monito ring and enforcing the Cleaner Burning Gasoline program. Nearly all gasoline delivered to the Valley is refined in Southern California. Compliance inspections on CBG primarily targets the refiners and shippers. The Health District has contracted with the California Air Resources Board (CARB) to sample and track the wintertime clean bur ning gasoline s h ipments at the refinery. CA RB has had this monitoring and tracking program in plac e for many years to insu re complianc e with their own state fuel requirements. Additionally, the Nevada Department of Agricu lt ure’s Bureau of Weights and Measures conduc ts random sampling at gasoline stations and informs the Health District when test ing indicates non-complianc e with the regulations . Annual r eports summarizi ng the winter seas on gas oline programs will be pro v ided to the EPA at the conclu sion of the applic able time period. Section 54 of the Air Pollution Control Regulations provides additional det ailed information on testing, record keeping an d enforcement of the Cleaner Bur n ing Gasoline program. A copy of this regulat ion can be fou nd in Appendix D, Se ction 1, along with a report on the 1999 –2000 Wintertime Cleaner Burning Gasoline Program.

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 4-3TABL E 4-2

ACCEPTAN CE CRITE RI A FOR “ C BG ” AS A CO CONT RO L MEASURE

ACCEPT ANCE CRITERION HOW CRITERION IS MET E f f e c t i v e n e s s EPA’s CO Complex Model es timates that emissions can be reduce by 9.8% or 31.9 tons per day. This makes CBG an effective control measure. S a f e t y The proc edure for safe handling, transporting and dis pensing convention a l gasoline will ap ply to this reformulate d gasoline. Cost Effectiveness $1,225 per t on of CO reduced is within the accept able range of other existing cost effective control measures. Availability of Technol o g y Presently, the fuel is refined in the State of California at a rate of 38 million gallons per day. Informal advice by California Energy offi cials indicates that additional local de mand here of 1.5 million g a llons per day will not jeopardize overall supply conditions. Practicality The common use of reformulated gasoline in severa l other states suggests that CBG is practical. R e a s o n a b l e n e s s T h e common use of reformulated gasoline in severa l other states suggests that CBG is reasonable. R e l i a b i l i t y S u b s t a n t i a l emi ssion t e sting by v ehicle manufacturers and petroleum marketers document reliab ility o f CBG as a CO control measure. Necessary for Attainment It is shown in Chapter 6 of this document that CBG is a nec e ssary control measure for demonstrating attainment.

4.2.1.2 Transportation Control Measures / Travel Demand Management (TCM/TDM)

The 1990 CAAA requires that consideratio n be given to the implementation of TCMs for the purposes of reducing motor vehicle emissions and offsetting growth in vehic l e miles traveled (VMT). As a serious CO nonattainment area, the Las Vegas Valley is required to evaluate and implement (if practical) those TCMs referenced in Section 187(b)(2) referenc ing Section 182(d)(1)(A) and (B) with the

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 4-4focus of reducing car bon monoxide emission s. Section 108(f) of the CAAA also requires that plans evaluat e and implement such measures as necessary to demonstrate attainment of the CO standard, in combi nation with other measures.

The CAAA sections referenced above allow the Las Vegas Valley and other serious CO nonattainment areas to be ex empt from the stated requirements if certain conditions are met. These secti ons contain language that is interpreted to mean that the SIP needs only to contai n those TCMs that are necessary to demonstrate attainment. This section of the document contains the rationale for the selected TCMs, benefits and cr iteria for their selection.

In developing this plan, a Carbon M onoxide Transportation Control Measure Analys is was conducted by Lima and Associates. A copy of this document is contained in Appendix B, Section 1. The in tent of this study was to identify those transportati on control measures that s howed the greatest potential in reducing carbon monoxide emissions in the Valley. Based on this study’s findings, the following measures are being im plement ed as voluntary control measures: employer based commuter incentive pr ograms, telecommuting and area wide ridesharing programs.

According to EPAs policy on Volu ntary Mobile Source Emission Re duction Programs (VMEPs), reflected in a me morandum dated October 24, 1997, from Richard D. Wilson, “ Voluntary mobile source measures have the potential to contribute, in a cost-effective m anner, emission reductions needed for progress toward attainment and maintenance of the N AAQS.” Furthermore this guidanc e states, “EPA believ e s that SIP credit is appropriate for voluntary mobile sou r ce measures where we have confidence t hat the measures can achieve emission reductions.” Under thi s policy, credit fo r VMEPs are limited to 3% of the total projected future year emissions reductions required to attain the NAAQS.

The VMEP control measures, consisting of employer based commuter incentive programs, telecommuting and an area wide ridesharing program, are being recommended for implementation by this plan. The Transportation Demand Management Division of the Clark Count y’s Regional T r ansportation Commission will be responsible for implementing, managing and monitoring this program. Through adoption of the TIP (FY 1 998-2000), the implementation of TDM strategy is prioritized. Funding in the amount of $911,000 for these programs have been derived from Congestion Mitigatio n Air Quality (CMAQ) funds. On June 10, 1999, the Regional Transpor tation Commission of Clark County adopted Resolution No. 177 whic h establis hed guidelines for admi n istering the CAT MATCH commute r services p r ogram including the commuter incentive program, C l ub Ride. A copy of this re solution can be found in Appendix D, Section 2. Portions of the CAT MAT CH prog ram, which in clude employer bas ed commuter i n centives and area wide rides har ing programs, became operational in July, 1999. The voluntary TCM/TDM pr ograms considered for impl ementation are estimated to achieve approximately 0. 3 tons per day of emission reductions

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 4-5by the year 2000 at an estimated cost of $42,500 per ton of CO reduced. The reduction attributed to this measure is 0. 08% of the amount necessary to attain the NAAQS. This value does not exceed the 3% maximum credit that is allowed to be claimed by EPA’s VMEP policy guidan ce . As participation in creases in the Cat Match program it i s estimated that the resulting emission benef i t in 2010 and 2020 will be 1.8 and 2.3 tons per day, res pectively. A commitment to remedy any emission reduction shortfall is backed by separate resolutions from the Clark County Board of Commissi ons and the Regional Trans portation Commission. A copy of the RTC resolution is co ntained in Appendix D, Section 9.

Table 4-3 below addresses the eight ac ceptance criteria dis c ussed for the voluntary TCM/TDM control m easures th at will be implemen ted. Additional supporting information related to this measure can be found in Appendix E, Section 2. TABLE 4-3 ACCEPTAN CE CRITE RI A FOR TCM/ TDM AS A CO CO NT ROL MEASURE

ACCEPT ANCE CRITERION HOW CRITERION IS MET Effectiveness An analys is conducted by Clark County and the RT C indicate that the voluntary TCM/TDM program c an reduce mobile source emissions by 0.08% or 0.3 tons per day. S a f e t y The selected TCM/TDM elements of the Cat Match Program are cons idered safe with no other fu rther implications or risks. Cost E f f e c t i v e n e s s The cost effectiveness of these measures are higher than other proposed measures but are lower than others previous ly considered and rejected. Availability of Technology Th is test is not applicable. Practicality T h e implementat ion of these measures in other areas suggests that they are practical. R e a s o n a b l e n e s s T h e s e meas ures are considered reasonable when considered against other TCMs. R e l i a b i l i t y P r o g r a m element s may be difficult to administer across all segments of the population in a service based economy. Necessary for Attainment It is shown in Chapter 6 of this document that TCM/ TDM programs are necessary for demonstrating attainment.

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 4-64.2.1.3 Technician Tr aining and Certifica t ion

The State’s Motor Vehicle Inspection/Main tenance (I/M) Program requires that inspectors be licens ed. The traini ng and certification procedures were established to comply with 40 CF R 51.367. The requirement s for a certified inspector in Nevada’s I/M program are verified training, including a course approved by the Department of Motor Vehi cles and Public Safety (DMV & PS), a written and practical testing program and a separate certification process. In general terms inspector training will co ver: purpose and goals of enhanced I/M, emission c ontrol devic es, configurati on and inspection, test procedures and rationale. The I/M program also consis ts of training and licens ing of class 2 inspectors that conforms to the require ment s set forth i n 40 CFR 51.369. Under this requirement, a license is required to be a certified repair technic i an in order to perform work or service on vehi cle emission components. Additional information about these requirements ar e delineated in NAC 445B.485 through 445B.5084 as well as t he State of Nevada’s State Im plementation Plan for an Enhanc ed Program for the Inspection and Main tenance of Motor Vehicles f o r Las Vegas Valley and Boulder City, Nevada (March 1996).

The DMV & PS is the agency responsible for implementing and monitoring the State’s Motor Vehicle I/M Program including the Inspector Training and Certification programs. As specified in NRS 445B.765 and 445B.810, it is also the responsibility of DMV to prepare annual reports on the program and to submit them to the U.S. EPA in July of each year to comply with the provisions of 40 CFR 51.366. Additional information on the Inspection Maintenance Program can be found in the Inspection Maintenance St ate Implementation Plan referenced above.

The carbon monoxide emissi on reduction benefit from th is control measure was derived from the Mobile5b model. This was accomplished by setting the I/M control flag record equal to 6 (IMFLAG = 6) and including a value of 2 in the third position of the corresponding input reco rd. Setting these parameters in this fashion, the model applies t he benefits of technician tr aining and c e rtification to the emission factors. A second model r un was made keeping the inputs identical with the exception of not including the benefit s of technician training. The resulting values from these two runs were then compa r ed to determine the resulting benefit. The result of this analys is indicates that technicia n training and certification will provid e a 2.95 % reducti on in carbon mono xid e emissions. Table 4-4 provides additional informa tion on the acceptance criteria for technician training and certification as a control measure.

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 4-7TABL E 4-4

ACCEPTAN CE CRITE RI A FOR TEC H N ICAIN T R AINING

AND CE RTIFICATION AS A CO CONTROL MEASURE

ACCEPT ANCE CRITERION HOW CRITERION IS MET Effectiveness An analys is conducted by Clark County utiliz ing th e MOBILE model showed this program can redu ce mobile source emissions by 2.95% or 10.4 tons per day. S a f e t y Training and certification is s a fe and can improve work place safety. Cost Effectiveness Training an d certification are estimated to have a cost effectiveness of $115 per ton of CO reduced and is the most cost effective measure. Availability of Technology Th is test is not applicable. Practicality T h e implementat ion of this measure in other areas suggests it is practical. R e a s o n a b l e n e s s Improving the effectiveness of emissions testing and repairs is a reasonable control measure. R e l i a b i l i t y Training and Certification is administer ed by DMV & PS. This program has a high degr ee of re liab i lity in reducing mobile source emissions. Necessary for Attainment It is show n in Chapter 6 that Technician Training and Certific ation is necessary for demonstrating attai n ment.

4.2.1.4 Alternative Fuels Program

The Energy Policy Ac t of 1992 (EPACT) contai ns a number of ti tles that deal with the use and acquisit ion of al te rnative fue l veh i cles. Rea liz ing that this Act is currently in the process of being amended, the final version should ser v e to further accelerate the acquisition and use of alternative fuel v ehicles along with increasing fleet applic ability. In the abs enc e of applic able federal requirements, the State of Nevada has adopt ed an even more aggressive approach towards acquis i tion / conversion of fleets. Ne vada’s program is more aggressiv e by having an earlier implementat ion date and by inc l uding munic i pal fleets early in the implementation of the program.

The Nev a da Department of Conservation and Natural Resources, Division of Environmental Protection, is the agenc y responsible for administering the

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 4-8alternative fuels program. NRS 486A requires all gover nmental fleets in Clark County to acquire and utilize clean alternat ive fuels v ehicles. Starting in 1995, 10 percent of government fleets new ve hicle purchases were required to be alternative fuels vehicles. This percentage increases to 90 percent in fisc al year 2001 and each year thereafter. Nearly all fleets have chosen to acquire nat ural gas vehic l es and presently there are ov er 1,400 alternative fuel vehicles operating in the Valley. As vehicles are replaced through attrition, this number will further increase along with the use of the cle aner fuel. Through the cooperativ e efforts of governmental agencies, eight natural gas fueling facilities have been strategically located in the Las Vegas area. Additional information pertaining t o this control measure c an be found in Appendix E, Sec t i o n 4

.

It is estimated that the alternative f uel program in Clark County, Nevada wil l benefit CO emission reduction in the year 2000 by about 0.12%, or 0.4 tons per day at an estimated cost of about $4,000 pe r ton. This cost effectiveness based on the Phoenix Ariz ona Program. Clark C ounty’s estimates are substantially higher av eraging $80,000 per ton of CO reduced. Table 4- 5 enumerates the acceptance criteria for alternative fuels and presents arguments for the alternative fuel program as a pri m ary control measure.

In order to realize the ma ximum benefits of the alternat ive fuel control measure, entities will need to gain t he support of private fleets through the Clean Cities initiativ e an d possibly changes to the Energy Policy Ac t (EPACT) by providin g more refuel ing facilities and unlim ited publ ic access to existing facilities. The most benefits of this control measure can be realized when dedic ated vehicles are utilized because they are designed to oper ate efficiently on alternative fuels resulting in less CO pollution even though they may lack the advantages of longer range and the option of regular fuel that the dual-fuel fleet would afford.

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 4-9TABL E 4-5

ACCEPTANCE CRITE RI A FOR THE ALTERNA TIVE FUELS PROGRAM AS A CO CO NTR O L MEA S URE

ACCEPT ANCE CRITERION HOW CRITERION IS MET Effectiveness An analys is conducted by Clark County indic a tes that the government fleets alternative fuels program can reduce mobile source emissions by 0.12% or 0.4 tons per day. Safety A lternative fuel programs have been proven to be safe throughout the country. Cost Effectiveness* At $4, 000 per ton of CO emission reduced, alternative fuels are considered as having an average cost effectiveness in comparison to other

measures. Availability of Technology Alternat ive fuel technol ogy has been in place for a while. Numerous vehicle manufacturers are providing a variety of “clean” alternative fuel vehic l es. Practicality The use of alte rnative fuel veh i cles in other areas suggest that it is pr actical. Additionally , most government fleets are currently attaining a 90% acquis i tion rate. R e a s o n a b l e n e s s T h i s m easure is cons idered reasonable

. R e l i a b i l i t y Alternative fuels burn cleaner than gasoline in combustion engines this reliably reducing air pollution. Necessary for A t t a i n m e n t It is shown in Ch apter 6 that the Alternative Fuel Program is nec essary for demonstrating attai n ment.

*Cost Effectiveness value based on Phoenix Arizon a’s program. Cla r k Count y estimates of the cost effectiveness is substantially high er averaging $ 8 0

, 000 per to n of C O red u ced. 4.3 Off-Road Mobile Sources

The only direct proactive controls affe cting the off-road sources, mobile and otherwise, are the Wi ntertime Cleaner Burning Gasoline and the Oxygenated Fuels programs. Sinc e this category contributes only about 11% of the total CO emissions for the valley, further contro llin g these emissions wou l d not be cost effective, nor practical. If in the futu re, control technology, c l eaner fuels, or effective inspection pr ograms became feasib le, they will be incorporated into the SIP.

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 4-104.4 Stationar y Point and Area Sour ces

It is estimated that these source categor ies contribute only about 3% of the total CO emissions for the valley. As st ationary sources are not a significant contributor to CO l e vels, contributi ng only 1.39% of total emissions, the provisions of Section 187 (c) are not applicable to the Las Vegas Valley Nonattainm ent Area. Other than current controls required by the new source performance standards (NSPS) and New Source Review (NSR) on major sources of pollution, no addition al controls are warranted.

4.5 Previousl y Adopted Control Measures

Previous ly adopted contro l measures from the 199 5 Moderate Area Carbon Monoxide Plan continue to assist in air qua lity improvement efforts. This section highlights those measures that were adopted and implem ented and which continue to provide for CO emission reductions.

Although fleet turn-over does not meet a ll required criteria of a federally enforceable control measure, its effects in the Las Vegas Valley are signif i cant. Nevada Department of Taxation records i ndicate that approximately 60,000 new vehicles are purchas ed annually. With to tal vehic l e registrations increasing a modest 5 percent a year, the Las Ve gas fleet has been experiencing a 14 percent inc r ease in new model year vehicl es over the past three years. Since new cars emit pollution at a lower rate , the portion of newer vehicles comprising the Las Vegas fleet c an lead to a significant reduction in mobile source car bon monoxide emissions.

Lower Reid Vapor Pressure (RVP) wa s adopted as a control in the 1995 Moderate Area Carbon Mono xide Implementation Plan and continues to reduce CO emissions from fuel combustion in m o tor vehicles. The Nevada State Department of Business and Industry, Depa rtment of Agricult ure was granted the authority to regulate the RV P by Chapter 5 90 of the Nevada Revised Stat utes and Chapt er 590 of the Nev ada Administr a ti ve Code (NAC). Adopted by the Department of Agriculture, these regulations (NAC 590.065) lowe red the RVP limit of gas oline from 11.0 psi to 9.0 psi with no waiv er for ethanol blended fuel. The Department of Agriculture is the responsible agency for enforcing NAC 590.065 which limits the vapo r pressure of gasoline. Inspectors conduct approximately 88 random ins pections per month. Analy s es on gas o line samples from gasoline stations are conduc ted by c hemists in the Department’s laboratory. Results of each test are recorded in a database and mont hly reports are prepared for the Division of Weights and Measures, the Bureau Chief, and Administrator of the Depar tment of Agriculture.

The 1995 Moderate Area Plan also contained 2.7% oxyg enated fuels as a c ontrol measure. Since adopting t hese regulations , the Clark County Dis trict Board of Health am ended its regulations on Septem ber 27, 19 97, to require that all fuel

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 4-11sold in Clark County during the winter season (October 1 to March 31) contain 3.5% oxygenate by weight. D ue to the higher oxy genate mandate, ethanol is being used in lieu of MTBE to meet this requirement

. The 3.5% oxygenate by weight control measure continues to pr ovide cost-effective emissions reduct i ons within the non-attainment ar ea. The AQD is responsible for monitoring and enforcing this control measure.

The State’s Motor Vehicle Inspect i on Ma intenance program, administered by the Department of Motor Vehic l es and Public Safety, is al so responsible for reducing carbon monoxide. T h rough the use of the M O BILE model, it has been estimated that this program is currently providin g a 16.8 percent reduction of CO emissions.

Table 4-5 below contains previ ous ly adopted and implemented controls (specified in the 1995 Carbon Monoxide AQIP) listed with their adoption date.

TABL E 4-6

PREVIOUSLY ADOPTED ENFORCEA B LE CARBO N M O NOXI DE C O NT RO L MEASURES

Control Measure Adoption Date

Oxygenate Fuels 1991/1995

Reduced RVP Gasoline 1995

Motor Vehicle Inspection/

Maintenance Program 1978

Fleet Turnover 1967

4.6 Summar y Of Primar y Carbon Monoxide Control Mea s ures

The primary CO control measures discuss ed in the previous s e ctions of this Chapter ar e summarized below in Table 4- 7 with their emission benefit estimates for the attainment and future years along with the cost effectiveness. Contingenc y measures are discussed in Chapter 7 of this document.

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 4-12CARBON MONOXIDE STATE IMPLEMENTATION PLAN 4-13 TABLE 4-7

PRIMARY CONTROL MEASURES, BEN EFITS AND COST EFFECTIVENESS

2000 2010 2020

Control Measure Cost Effectiveness ($/ton) CO Benefit (TPD) CO Benefit (percent) CO Benefit (TPD) CO Benefit (percent) CO Benefit (TPD) CO Benefit (percent) Technician Training $ 115 10.42 2.95% 15.71 3.9% 23.89 4.1% CBG $ 1,225 31.92 9.8% 53.96 13.95% 96.55 17.3% Alternative Fuels $ 4,000 0.415 0.12% 1.12 0.28% 1.37 0.24% Cat Match TDM/TCM $ 42,500 0. 295 0.08% 1.82 0. 45% 2.33 0.40%

TOTALS 43.1 12.2% 72.6 18.1% 124.1 21.3%

# C hapter 5 - Air Quality Modeling

5.1 INTRODUCTION

5.2 BASE CASE SCENARIO MODELING

5.3 CARBON MONOXIDE EPISO DE SELECTION AND DESIGN VALUE

5.4 ASSESSMENT OF UAM MODEL PERFORMANCE5.1 INTRODUCTION

This chapter summarizes the modeling perfo rmed to establish an estimate of the amount of emission reduction needed t o achieve attainmen t of the 8-hour average NAAQS for CO in t he Las Vegas serious nonattainment area. Detailed technical documentation of the m odeling can be found in Appendix C.

Serious CO non-attainment areas, such as the Las Vegas Valley Air Bas i n, are required b y the 1990 CAAA to utilize EPA approv ed models to demonstrate attainment. The Urban Air-shed M odel (UAM), an urban-scale, threedimensional, grid-type, numerical simulation model which incorporates a condensed photochemical kinetics mechanism for urban atmospheres and the CAL3QHC, a micro-scale roadway intersec tion model are the current models o f choice for attainment demonstration. Sin c e EPA h a s identifie d the UAM and CAL3QHC as effective tools for evaluati ng the effectiveness of emission control programs needed to attain and maintain t he CO national stand ard, these two models were selected for the attainment demonstration, in compliance with the CAAA requirements.

The overall modeling system - compri sed of transportation (TRANPLAN), emissions (MOBILE5b), and ai r quality models (UAM) - is initially used to replicate historic CO hi gh pollution episodes in orde r to establish base case simulations . Each base case simulation relies on a wide variet y of input data, including meteorological dat a and inventories of esti mated emissions from all signific ant sources of CO. Air qualit y modeling with the UAM is performed initially utilizing a set of inputs fo r a historic episode with elevated CO concentrations, and t he results are evalua ted to deter mine the performance of the modeling system. Once the model ing system has been evaluated and determined to perform within prescribed le v e ls, the same met eorological inputs and a projected emissions inve ntory are used to simulate the impact of future emission s c enarios.

Details regarding the protocol followed in the air quality modeling program for the Las Vegas Valley are provided in the r eport entitled “Modeling Protocol fo r the Las Vegas Valley Carbon Monoxide Urban Air-shed M odel Update Project” dated September 11, 1996 ( s ee Appen dix C, Sect ion 1). The modeling protocol report as well as technical support for t he modeling pr ogram was provided by ENVIRON International Cor poration (ENVI R ON). This chapter summarizes the results of air quality modeling for the 1996 base case scenario. A comprehensive report of the applicati on of the UAM to the 1996 base c a se scenario is provided in a memorandum from ENVIRON describing the base c a se design value selection and sc aling (October 27, 1998 - see Ap pendix C, Section 4). EPA’s approval was obtaine d on the episode selec t ion and scalin g appro a ch before the actual attainment demonstr ation modeling was performed. The employed scaling approach is defined and explaine d in details in the above referenced memorandum of Oc tober 27, 1998, Appendix C.

CARBON MONOXIDE STATE I M PLEMENTAT ION PLAN 5-15.2 BASE CASE SCEN ARIO MODELING

The key tasks accomplished in the air quality modeling progr am for the base case scenario were:

(a) Selection of the CO episode to be modeled; (b) Preparation of meteorologi cal, air quality and emissi on inventory data files; and (c) Application of the UAM and a ssessment of model performance.

The base c a se included the exis ting Inspection and Maintenanc e (I/M) program, the 3.5% oxygenated fuel program, low Reid Vapor Pr essure gasoline (9 psi), and other existing control meas ures that are in place or mandated by the Clean Air Act (CAA).

5.3 CARBON MONOXIDE EPISODE SELE C T ION AND DESIGN V A LUE

In selecting an appropriate epis ode for UAM modelin g of the Las Vegas Valley area, the ten highest ambient air quality meas urement s of 8-hour CO concentrations were selected bas ed on peak 1- and 8-hour average CO concentrations above 8 PPM and 5.5 PPM, respectively in accordance wit h current modeling guidelines. Meteorological conditions were not the sole basis for selecting these periods, nor were t he overall CO patterns throughout the Las Vegas Valley. These top ten elevated CO episodes are listed in Table 5-1 below, along with the magnit ude of peak hourly CO (evening and morning) and peak 8- hour CO at East Charleston (EC) and Sunr ise Acres (SA). Table 5-1 also list s the time span of the peak 8-hour average at SA.

Note that t he highest 8-hour CO concent ration occ u rs on Dece mber 8-9, 1996 and on December 19-20, 1996 bot h of which coincide with the highest morning hourly CO of all epis o des in the table. On December 8-9 and Dec e mber 19-20 of 1996, both evening and morning peaks ar e evident, with gener ally lower CO levels across midnight rangi ng between 5-7 PPM. On December 4-5, however, only a s hort-lived evening peak o ccur s , and on January 9-10, 1997 concentrations between the evening and morning peaks dip t o 2 PPM. This indic a tes that sharp hourly peaks are not necessarily conduc ive to high 8-hour CO, and that the maintenance of moderate to high CO levels o v ernight is more likely to lead to exceedences of the 8-hour standard. Considering th ese characteristics, the top two elevat ed CO episode s from the analysis are December 8-9 and 19-20, 1996. The third ranked epis ode is December 18-19 based solely on peak 8-hour CO at both EC and SA ov er 7 PPM.

The first two episodes (Dec 8-9 & Dec. 19- 20) were is olated for further study and analys is as the result of extensiv e m onitoring and meteorological data gathering efforts conducted as part of a detailed Car bon Monoxide study for the Las Vegas V a l l e y [ T h e L a s V e g a s V a l l e y C a r b o n Monoxide Urban Airshed Model Update

CARBON MONOXIDE STATE I M PLEMENTAT ION PLAN 5-2Project - P hase II: UAM Base Ca se and Sensitivity Applications , Emery e t al., July 1998 - (Appendix C, Section 3)].

As discuss ed in an October 27 memor andu m to EPA (Appen dix C), the selected episode was December 8-9, 1996. This selection along with the employment of a scaling factor that resulted in a maxi mum predicted concentration of 11.2 P P M were discu ssed with and approve d by EPA Region IX. Figure 5-1 displays the UAM carbon monoxide concentrations for t he selected episode of December 8-9, 1996.

Table 5-1

List of Highest 10 CO Episodes Ba sed on Peak 1- and 8-hour Average CO Concentrations. Values Reported are for East Charleston (EC) and Sunrise Acres (SA). Peak 8-hour Period is Given for SA.

________________________________________________________________________ Episode PM peak AM peak Peak Peak hourly hourl y 8-hour 8-hour P e r i o d EC SA EC SA EC SA

________________________ __________________ ______________________

________ 1996 Dec 2-3 7.1 6.9 6.3 8.4 5.6 5.8 1900-0200

Dec 3-4 8.7 9.0 7. 6 9.4 6.2 6.9 1800-0100

Dec 4-5 10.5 9.5 3. 5 2.5 6.7 6.7 1800-0100

Dec 8-9 8.2 8.8 10. 4 11.8 7.2 7.9 2000-0300

Dec 18-19 8.8 8.5 8. 2 9.1 7.2 7.4 1900-0200

Dec 19-20 8.3 8.3 10. 4 10.8 7.9 8.0 0100-0800

Dec 25-26 6.5 7.1 8. 1 9.2 5.8 6.2 0200-0900

1997 Jan 9-10 9.8 11.1 9.2 7.8 6.7 7.0 1800-0100

Jan 18-19 7.5 8.2 5. 9 5.9 5.8 6.6 2000-0300

Jan 19-20 6.9 7.3 7. 9 8.9 6.3 6.7 0100-0800

CARBON MONOXIDE STATE I M PLEMENTAT ION PLAN 5-3Figure 5-1

Analysis of M a ximum 8-h o u r CO Con c e n tration Me asurem ents (PP M ) In Central L a s Vega s on Decem b e r 8-9, 1996.660665670675680UTMEasting(km)3995400040054010

UTM No rthi ng (km )7.24.46.33.94.43.87.95.34.19.69.19.54.66.33.99.47.84.15.91.1

CARBON MONOXIDE STATE I M PLEMENTAT ION PLAN 5-45.4 ASS ESSM ENT OF UAM MODEL PERFORMANCE

Data inputs for the UAM were devel oped using available air quality

, meteorological, and emissions inventory dat a. Emissions inventory data for the selected carbon monoxide epis o de was derived from the “1996 Carbon Monoxide Emissions Inventory” discussed in Chapter 3 of this document. Both graphical and statistical measures of model performance were conducted. Statistical measures of model performanc e show numbers well within accept able performance ranges established by the EPA in “Guidelines for Regulatory Application of the Urban Ai rshed Model for Areawide Ca rbon Monoxide, Volu me I and II” dated March 1992. Table 5-2 below s u mmarizes the resulting model performance statistics.

Table 5-2

Model Performance Statisti cs for December 8-9, 1996 Comparing Scaled UAM 8-hour A v erage CO Concentrations with Measurements from all Sites Operated During the Field Study

.

P e ak 8- ho ur M e as u r e m e n t 9. 6 pp m a t M a r n e l l F i e l d

S t at i s t i ca l Me a s u r e R e vi s e d R u n ( P h a se I I b ) C O s c al e d b y

1. 1 4

U n pa i r e d P e

a k ( p p m ) 1 1. 2

Pa i r e d P e a k ( p p m ) 9

. 6

UP P A

(

% ) 17

P PA ( % ) 0

P PA T i m i n g Er r o r ( h r ) 0

Bi a s i n P e a k s ( % ) 3

Er r o r i n P e a k s ( % ) 14

Ti m i n g B i a s ( h r )

- 1

T i mi n g E r r o r ( h r) 3

O

v

er

al l B i a s ( % ) 1

Ov e r a l l E r r o r ( % ) 17

Graphical representation is illus trated in a sample time series plot in Figure 5-2. For the complete set of time seri es plots, the reader is referred to Appendix C, Section 3. These time series plots show t hat model results agree well in timing at all monitor ed site locations. Based on model performance statistics, the time series plots, and meteorologic a l c onditio n s, EPA Re gio n IX concurred that the December 8-9 modeling episode was repr esentative of high CO concentrations

CARBON MONOXIDE STATE I M PLEMENTAT ION PLAN 5-5in the Las Vegas Valley and theref ore should be used for attainment demonstration purpos es.

Figure 5-2

Grap hs Com parin g Ob se rved CO Con c entration s (l arge dots) and UAM Predi ct ed Co ncentra tions

(soli d line ) at a Corre s p ond ing Site. The Dashed Li ne s Re pre s e n t the Minimum and Maximu m Predi cted CO Con c entratio n s with the S u rroun ding Ni ne-cell s Arou nd Each Site.

CARBON MONOXIDE STATE I M PLEMENTAT ION PLAN 5-6

# C hapter Six – Demostration of Attainment

6.1 INTRODUCTION

6.2 2000 BASE YEAR (NO ACTION SCENARIO) PROJECTIONS

6.3 UAM ATTAINMENT DEMONSTRATION

6.4 CAL3QHC ROADWAY INTERSECTION MODELING

6.5 MICRO-SCALE ANALYSIS FOR AIRPORTS6.1 INTRODUCTION

Air quality modeling is an inte gral part of the air qua lity planning process to achieve attainment of the NAAQ S. Th is chapter summarizes the application o f the UAM and CAL3QHC models in the demonstration of attainment of the CO NAAQS by December 31, 2000. The pr imary purpose for conducting UAM ar eawide and CAL3QHC roadway intersecti on modeling is to demonstrate the effectiveness of control strategies in attaining the 8-hour average NAAQS for CO (EPA/SYSAPP-92/04 5a, pg 49). The attain ment demonstration should c onsist of the following four parts :

1. Development of the attain ment-year base case emission inventory; this inventory reflects the net effect of existing required controls and growth projections fo r all source categories; 2. Development of future -year emission strategies; 3. Performing attainment year mode l simulations to assess control strategies; and 4. Using res u lts from both t he UAM and CAL3QHC modeling to demonstrate attainment.

With respe c t to utilizin g the UAM area-wi de model to d e monstrate attainment, the estimated 8-hour average concentrations must be below the 9. 0-ppm standard. EPA als o r e commends that the CAL3QHC model be applied to intersections at potential hot-spot locations. The hot-s pot modeling analysis ent ails c o mbining concentrations from the UAM with thos e der ived from the CAL3QHC micro-scale model.

This chapter concludes with a discussi on about a micro-scale analys is, whic h was conducted on the airport facilities in the Las Vegas Valley. The purpose o f this analysis is two fold: 1) to inc o r porate updated emission estimates from the Clark County airports i n to the plan and the attainment demons tration, and 2) to establish f u ture years emission budgets for airport sources as a means to facilitate future conformity determinations.

6.2 2000 BASE YEAR (NO ACTION SCENARI O) PROJECTIONS

To initiate attainment demonstration mo deling, a future y ear CO emission inventory representative of the year 2000, without an y control measures, was prepared for future year application of the UAM. This projected i n ventory is the basis for evaluating the potential CO r eductions from a variety of proposed control measures. The development of th e base case (no action scenario) future year projected invento r y followed EPA gu id a n ce contained in the document titled “Procedures for Prepa ring Emiss i on Pr ojections” (EPA- 450/4-91-019). Per EPA guidance, these emiss i ons reflect current regulations, or any regulations that wil l be in effect prior to the year 2000, and t he anticipat ed effects of any controls mandated by the 1990 CAAA. Two approaches were us ed to develop the Las

____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ CARBON MONOXIDE STATE I M PLEMENTATION PLAN 6-1Vegas 1996 and 2000 base year inventorie s. The 1990 base inventory was used as the bas i s for projecting the 1996 a nd 2000 background inventories utilizing Bureau of Economic Analys is gr owth fact ors and local data fo r stationary, area, and non-road sourc e s. T he on-road mobile sour ce inventory was derived utiliz ing M O BILE5b containing inp u ts representative of 19 96 an d 2000 conditions. Additional information per taining to the projected future year emission inventory can be found in the modeling docu mentation contained in Appendix C, Section 4 and Appendix E, Sec t ion 5.

The mobile source emissions were co mbined with the emissions from other sources and run through the Urban Airshed Model for a selected episode. Table 6-1 depicts the 1996 base year emissi on inv entory, the 2000 base year (uncontrolled, no action scenario) emissi on inventories used in the modeling analys is along with the 2000 cont rolled emis sion inventory.

____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ CARBON MONOXIDE STATE I M PLEMENTATION PLAN 6-2Table 6-1

1996 & 2000 BASE YEAR S CARBON MONOXIDE MODELI NG EMISSIONS FOR THE LAS VEG AS NON-ATTAINMENT AREA

1 996 Base 2000 Uncontrolled 2000 Controlled

Emi ssions E m issions Em issions SOU RCE CATEGORIES ( Tons/Da y ) ( T o n s / D a y ) ( T o n s / D a y )

B

o nan z a

M

a

t e r i al s 0

. 2 8 0

. 2 8 0

. 2 8 J a m e s H a r d i e G

y

ps um 0. 55 0. 55 0

. 5 5 S

o ut her n N e vada P a

vi ng 0. 55 0. 55 0

. 5 5 P

a bc o C o

g ener a

t i o n 0

. 5 5 0

. 5 5 0

. 5 5 G

eor gi a P a c i f i c 0

. 62 0

. 6 2 0

. 6 2 T

o

t a l P o in t S o u r c

e

s 6. 53 6. 53 6

. 5 3

A

R

E

A

S O URCE S

S m a l l S t at i ona r y 2

. 7 3

. 0 8 3

. 0 8 B

o i l e r E m i s s i o n s 0 .3 8 0 .4 3 0

. 4 3 Fi r

e pl ac es 2

. 1 2 2

. 5 9 2. 59 S

t ru c t u r

a l F i re s 0 .6 4 0 .7 8 0

. 7 8 V

e h i c u l a r F i re s 0 .0 5 0 .0 6 0

. 0 6 B r u s h F i re s 1 .2 6 1 .5 4 1

. 5 4 R

e

s i de nt i a l N G C

o m b us t i on 0. 31 0. 34 0

. 3 4 C

o m m e r c i al N G C

o m bus t i o n 0. 09 0. 10 0

. 1 0 I n d u s t r i al N G C o m bus t i on 0. 32 0. 36 0

. 3 6 E l ec t r i c al U t i l i t y N G 0. 56 0. 63 0

. 6 3 C i ga r e

t t e S m ok i n g 0

. 0 4 0

. 0 5 0

. 0 5 T

o

t a l A r e a S o u r c

e

s 8

. 4 7 9

. 9 6 9 .9 6

NO N- R O

A

D

M O B I L E S O U RCE S

C

ount y A

i r por t s 36. 4 40. 4 4 0. 4 N e l lis A

F B 2 .8 6 2 .8 6 2

. 8 6 L o c

o m o t i ve E m i s s i ons 0. 23 0. 23 0

. 2 3 L a

w

n and G

a r

den E

q ui pm ent 3. 57 3. 52 3

. 5 2 M C & R

e c r eat i on E q u i p m e n t 5

. 9 5. 86 5

. 8 6 C

ons t r u c t i o n E

qui pm en t 9

. 7 7 7

. 6 1 7

. 6 1 T

o

t a l N o n - R o

a d S

o u r ce s 58. 73 60

. 4 8 60. 48

O N

- R O

A

D M O B I L E S O UR CE S * 4 0 5

. 4 35 3. 23 31 0. 1 8

GR A

N D T O

T

A

L 47 9. 1 3 43 0. 20 38 7. 1 5

____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ CARBON MONOXIDE STATE I M PLEMENTATION PLAN 6-36.3 UAM ATT A INMENT DEMONST RATION

The 1996 and 2000 base conditions reflect changes to the roadway network that either were completed, or will be be comp leted under the latest RTC Fisca l Ye a r 1998-2000 Transportation Improv ement Program (TIP). Thus, changes in VMT, speed and vehicle occupanc y rates are included in the base scenarios. Likewise, CO emission reductions associ ated with existing co ntrol measures (oxygenated fuel program, low R VP, and the smog check program) and regulatory measures for stat ionary, area, and non-road m obile source categories, as discuss ed in Chapt er 4, are also inco rporated in the base condit ion modeling.

To demonstrate attai n ment of the CO NAAQS, the results from the UAM modeling analyses m u st indicat e that maximum concentrations greater than 9.0 PPM will not occur. Demonstration of attainment by December 31, 2000 was accomplished by modeling t he mobile source control measures introduced in Chapter 4 and depicted in Ta ble 6-2 below. Mobile source emission factors and traffic volumes were then input into t he DTI M 2 (Direct Travel Impact Model) and then input into the EPS2 m odel to c a lculate total area-wide uncont rolled emissions. Next, the UAM was run to determine the effects of the control measures. Consequently, the UAM resu lts indic a ted that the proposed cont rol measures provide suf f icient reductions and that the maximum concentration on the attainment date would be 8.1 PPM.

Additionally , to validate t he UAM attainment demonstrat ion, the micro-scale hotspot analys is combines the results fr om the roadway intersection modeling and the area-wide modeling and should show no predicted 8-hour maximum concentrations greater than 9.0 P P M. Of the three-modeled inters ections, the East Charleston/Eastern intersec tion has the highest predicted CO concentrations (see Section 6.4 below). It i s shown later that this plan results in sufficient emission reductions such that the intersection falls below the 8-hour CO NAAQS of 9.0 PPM at 8.3 P P M. This value is below the attainment threshold of 9.0 PPM, theref ore, attainment is demonst ra ted. A more complete description of the UAM CO modeling per formed for the Las Vegas Valley is provided in following documents: The Las Ve gas Valley Carbon Monoxide Urban Airshed Model Update Project - Phase II: Modeling to Dem onstrate Attainm ent of the Carbon Monoxide Standard (contained in Appendix C, Section 4) and the Supplemental Urban Airshed M odeling Analy s is for the Las Vegas Valley Car bon Monoxide Attainm ent Dem o nstration (contained in Appendi x E, Section 5).

It is important to mention that the a ttainment demonstration is considered as being cons ervative as it does not incl ude the benefits of On -Board Diagnostic s (OBD) programs and Tier II mo tor vehicle technology. At present, the benefit of reduce CO emissions are unquan tifiable, but are expect ed to yield signific ant reductions in future years.

____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ CARBON MONOXIDE STATE I M PLEMENTATION PLAN 6-4TABL E 6-2

PROPOSED ENFORCEA B LE CO CONTROL MEASURES

Control Mea s ure Year 20 00 E m issi on Red u ctio n Adoption Date Re spo n si ble Agency

Clea n Burnin g Gasoline 9.8% 1999 Health Distri ct

Voluntary Tra n sp ortation Control Measures / T r an spo r tation Dema nd Ma n ageme n t 0.08% 1999/O ngoi n g RTC

Tech nici an Training a nd Certification 2.95% 1988 DMV&PS

Alternative Fuels Program for Govern ment Fleets 0.12% 1991/O ngoi n g NDEP/Govt. Entities

Combi ned Effect of Cont rol s 12.2%

Combined effect s of controls are not cumulative Table 6-3 below depict s the maximum ambi ent concentrations resulting from the UAM modeling runs.

Table 6-3

MAXIMUM VALLEY WIDE PRED ICTE D UAM CO NC ENTRATIO N S

R u n C o n t r o l s 1 9 9 6 2 0 0 0 2 0 1 0 2 0 2 0

(ppm ) (ppm ) (ppm ) (ppm ) Base Case 11.2 9.1 8.7 10.5

Control

Case CBG, Techni cian Traini ng, Alternative F u e l s , TC M / TD M N/A 8.1 7.2 8.5

6.4 CAL3QHC ROADWAY INTERS ECTION MODELING

As previously indicat ed the EPA reco mmends that a micr o-scale “hot-spot” analys is also be conducted as part of the attainment demonstration. Ty pically, three intersections having high traffic volu m e s, poor levels of ser v ice, and being in close proximity to the monitoring station r e cording exceedences are the b a sic

____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ CARBON MONOXIDE STATE I M PLEMENTATION PLAN 6-5selection c r iteria for this ana lysis ( EPA 45 4/R92-005, pg. 3). As such, the intersections referred to as the “5 points” were selected to be modeled to meet the micro-scale and attainment dem onstration modelin g requirements.

The three intersections which comprise t he “5 points” include: East Charleston and Eastern, East Charleston and Fr emont, and Eastern and Fremont and are located approximately one half mile sout hwest of the Sunrise Acres monitoring station. A l o cation map depict ing the configuration of “5 points” is provided below in Figure 6-1.

Figure 6-1

CAL3Q H C INTERSE C TI ON LO CATI ON MAP

The modeling approach inv o lv ed esti mating 8-hour “running” average CO concentrations at the three intersections for the 2000-attainment year. The 8- hour running average was calculat ed by the following method:

(1) Modeling hourly concentrations over a 24-hour period usin g the CAL3QHC microscale model;

(2) Combining micro-scale c onc entrations with background or neighborhood CO concentration generated from the UA M; and

(3) Calculating a “running” average of concentrations over the highest continual eight hours.

In the CAL3QHC modeling, an array of re ceptors is pla c ed around each selec t ed intersection in accord ance with EPA g u idance. In the UAM modelin g, an average concentration is estimated for eac h one squ a re mile grid cell. The UAM

____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ CARBON MONOXIDE STATE I M PLEMENTATION PLAN 6-6“background” component for a given in tersection is obtained by computing a weighted average of the concent rations from the four near est UAM grid cells. To combine t he UAM and CAL3QHC modelin g results, hourly concentration estimates from each model are summed, and then 8-hour running averages are computed. Predicted CAL3Q HC and UAM combined maximum 8-hour CO concentrations for the three roadway inte rsections are provided in T able 6-4 below. For detailed information on the CA L3QHC ana lysis, the reader is referred to the document titled “Micro-scale Hot S pot Modeling with CAL3QHC for the Las Vegas Car bon Monoxide SIP, contai ned in Appendix E, Section 6.

The predicted and combined maximum CO c oncentrations at the three roadway intersections all were within the 8- hour national standar d of 9.0 PPM. The predicted values support the contention that the existing and proposed control measures will result in the Las Vegas Valley reaching attainment of the CO NAAQS by the prescribed date of December 31, 2000. Fo r additional details, the reader is referred to Append ix E, Sections 5 and 6, Supplemental UAM Modeling Documentation.

Table 6-4

MAXIMUM PREDIC TED 8

- H O U R CA R B ON MO NO XIDE CON C E NTRATIO N S FOR HOT SPOT INTERSE C TIO N S

2 0 0 0 2 0 1 0 2 0 2 0

Inters ec tions Maximum Max i m u m UAM UA M+CAL3Q (ppm) (ppm) Maximum Maximum UAM UAM+CAL3Q (ppm) (ppm) Maximum Maximum UAM UAM+CAL3Q (ppm) (ppm)

Charl e ston/Ea stern 5.9 8.3 5.2 7.3 5.7 7.6

Charl e ston/F r e m ont 5.9 6.7 5.2 5.9 5.7 6.4

Eastern/F r emo n t 5.9 7.6 5.2 6.6 5.7 7.4

6.5 MICRO-SCALE ANAL YSIS FOR AIRPORT S

Towards t he conc lus i on of the modelin g analys is in 1999, updated em ission estimates from civilian air ports and related support activi ties became available. These new emission estimates were hig her than values prev ious ly quantified and reported. It was also postu lated that contributions from airport sources could be better represented, both in magnitude and ti ming/location with models other than the UAM, leading to a more accurate repres entation of air qua lity in the vic i nit y of airports. To reduce all uncer tainti es related to higher, updated emission estimates and potential mode ling limitations of the U A M, a separate modeling analys is was conduct ed utilizing the Em issions and Dispersi on M odeling Sy stem (EDMS).

____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ CARBON MONOXIDE STATE I M PLEMENTATION PLAN 6-7The EDM S was developed s pecifically for airport emission analyses and is approved by the EPA. EDMS is a combined emissions and dispersion model for assessing air quality at civili an a nd military airfields. T he model was deve l o ped by the Federal Aviation Administrati on (FAA) in co operation with the United States Air Force (USAF). The primar y aspects of the model include the development of an inventory of emi ssions generated by sour ces within and around an airport, and the ca lculation of pollutant concentrations in the surrounding environment.

EDMS performs dispersion analyses by incorporating prev ious ly dev eloped dispersion models (PAL2 and CALINE3-both EPA valid ated for the various sources of emissions ). These earlie r models hav e many known assum p tions and limitations regarding thei r applic ation. Assumptions used in the dispersion analys is m odule inc l ude: a s i mple or relativ e ly flat terrain, cons ervation of m a ss (i.e., negligible chemical breakdown of original substance), and steady stat e atmospheric conditions over the averagi ng period of one hour . Additionally

, Gaussian dispersion algorithms used by ED MS are limited to transport distances of less than 50 kilom e ters and do not c onsider complex aerody namic effects such as downwash from buildings. Poll utants currently included in EDMS for dispersion analyses are carbon monoxide ( C O), oxides of nitrogen (NOx), oxides of sulfur (S Ox), and particulate matter less than 10 mi crons in diameter (PM-10).

As illustrated in a pro t ocol submitted to the EPA, Reg i on IX (see Append ix C), this section summarizes the results fr om modeling CO at three Clark County airports wit hin the Las Vegas Valley us ing EDMS. The resu lting c oncentrations from EDMS are added to UAM predicted “ background” concentrations to provide a total CO concentration field for each scenario modeled, much the same way micro-scale intersection modeling is pe rformed as described by EPA’s CO modelin g guidanc e (EPA, 1992).

The total 8-hour average CO concentrations at the indiv i dual re ceptors are then rank-ordered to show the highest resulting concentrations, at which point an attainment/maintenance eval uation can be made. A more complete and detailed description of the methodology used to model the atmospheric dispersion of airport-related CO emissions is provided in the report “ C a r b o n M o n o x i d e Em iss i ons Inventories and Dispersion Modeling, McCarran International, North Las Vegas, and Henderson Executive Airports” prepared by Ricondo & Associates , 1999 (see Appendix C, Section 8).

Table 6-5 below depict s the EDMS/UAM results. All predicted future year 8-hour CO levels are below the standard, ex cept for one McCarran receptor in 2020 (9.07 ppm). The EDMS concentration at that point is only 0.17 ppm and the UAM component is 8.90 ppm. The future y ear UAM control strategy reported by Emery at al . (1999) indicate that adopt ion of one primary control measure (such as Cleaner Burning Gasoline) would r educe overall peak UAM concentrations from 10.8 ppm to 9.1 ppm , about a 16% reduction. Applying this same 16%

____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ ____ ____ ___ CARBON MONOXIDE STATE I M PLEMENTATION PLAN 6-8_____________________________________________________________________________ CARBON MONOXIDE STATE IMPLEMENTATION PLAN 6-9 reduction to the UAM background concent ration at the EDMS receptor would reduce the 8.90 ppm value to 7.50 ppm (8.90 ppm X .84 = 7.50 ppm). Even assuming that this control measure has no effect on McCarran sources, the 9.07 ppm peak in Table 6-5 reduces to 7.67 as a result of the CBG control measure (7.50 ppm + 0.17 ppm = 7.67 ppm). Therefor e, this analysis shows attainment in 2000 and maintenance in 2010 and 2020 with the adoption of t he primary CO control measures.

Table 6-5

MAXIMUM 8-HOUR CARBON MONOXIDE CONCENTRATIONS (PPM) FROM COUNTY OPERATED AIRP ORTS FOR FOUR MODELING YEARS (BASE CASE ESTIMATES ASSUME NO ADDITIONAL CONTROLS ON MOTOR VEHICLES)

EDMS CO UAM CO Total CO Airport Scenario Receptor Airports Uncontrolled Uncontrolled

McCarren Airport 1996 Base 277 0.00 9.64 9.64 2000 Base 277 0.01 8.66 8.67 2010 Base 277 0.01 8.06 8.07 2020 Base 1599 0.17 8.90 9.07

North Las Vegas Airport 1996 Base 801 0.00 8.89 8.89 2000 Base 801 0.00 7.54 7.54 2010 Base 801 0.00 7.03 7.03 2020 Base 801 0.01 8.27 8.28

Henderson Airport 1996 Base 92 0.14 0.43 0.57 2000 Base 92 0.19 0.39 0.58 2010 Base 204 0.04 0.51 0.55 2020 Base 181 0.09 1.08 1.17

The results of this airport micro-scale analysis serve to ensure that projected increased emissions from this source category can be accommodated within the Valley’s Carbon Monoxide airshed wit hout jeopardizing attainment or maintenance of the CO NAAQS.

# C hapter Seven - Additional Requirements of the 1990 CAAA

7.1 INTRODUCTION

7.2 VMT TRACKING PROGRAMS

7.2.1 VMT Projections 7.2.2 Contingency Measures 7.2.3 Annual VMT Tracking

7.3 OTHER CONTROL MEASURES7.1 INTRODUCTION

This section addresses requi rements applic able to non-attainment areas set forth by the 1990 CAAA. The VMT Tracking Program is fi rst discussed and includes VMT projections and cont ingency measures that wil l be implemented should either actual VMT exceed pr ojected VMT or if attain ment of the federal CO standard is not reached. Also c ontained in this section is a brief discussion of annual VMT tracking and reporting.

Both sections 172(c) (9) and 18 7(a)(3) of the 199 0 CAAA re quir e conting e ncy measures to be implemented in the event t he area fails to reach attainment by the specified attainment date. Such measures shall be inc l uded in the SIP revision to take effect automatically without further action by t he State or EPA. The trigger for such measures is an official finding by EPA that the area failed to attain the CO standard by the applic able at tainment date. Section 187(a)(3) also requires the Las Vegas Valley to im plement contingency measures if any estimate of actual VMT or any updated VM T forecast for the area contained in an annual report for any year prior to atta inment exceeds the num ber predict e d in the most recent VMT forecast, withi n a specif ied margin of error.

7.2 VMT TRACKING PROGRAMS

7.2.1 VMT Projections

Section 18 7(a)(2)(A) of the 1990 CAAA r equires CO non-attainment areas to forecast VMT for each year prior to th e attainment year. The first set of projections contained in this plan serves to satisfy this requirement. In addition, the accuracy of the VMT forecasts will b e tracked through an nual reports that present estimates of actual VMT for t he preceding year and updates of the VMT forecasts for subsequent years. A deviati on from the forecasted VMT of a given percentage will ca use implement ation of contingency measur es to offset either

excess VM T or CO emissions due to the additional VMT. These percentages are 5 percent in 1999, 4 percent in 2000, and 3 percent in 2001 and subsequent years. The cumulative VMT growth cannot be greater than or equal to 5 perc ent above the VMT forecast used as the basis for attainment demonstration. A nnu al VMT tracking reports contai ning the estimated and act ual reported VMT for each year is due in September of each year and will be submitted by the RTC.

The RTC is responsible for preparing VMT forecasts. The Nevada Departmen t of Transportation has the responsibility of estimating actual VMT in conjunction with the Highway Perf ormance Monitoring System and reporting these values to the Federal Highway Administration. The DCP will work with the RT C to prepare the annual VMT tracking report s . The VMT projections for future years were derived us ing the Las Vegas Regional Transportation Model develope d and maintained by the RT C. Table 7-1 contai ns VMT forecasts for each year prior to the 2000 attainment year as well as for the horizon y ears beyon d 2000. Note

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 7-1that average daily VMT will decline after the year 2020 due to the assumption that highways will saturate with traffic and will exceed their capacities resulting in commuters selecting alternate modes of trav el like mas s transit, ride sharing, and other modes.

TABL E 7-1

AVERAGE DAILY VMT ESTIMATES AND F O RE CA STS BY FUNCTIO NAL CATEGO RY AND BY YEAR*

S e g m e n t 1 99 7 1 99 8 1 9 9 9 2 00 0 2 00 1 2 0 0 2 2 0 0 3 2 00 4 2 0 0 5 2 0 0 6 2 00 7

E x

t

. Con n ec t o r 6 4 0

, 6 0 5 68 2

, 3 1 5 7 2 4

, 0 24 76 5

, 7 3 4 8 0 0

, 8 57 8 3 5

, 9 8 1 8 7 1

, 1 05 90 6

, 2 2 9 9 4 1

, 3 53 97 6

, 4 7 7 1

, 0 1 1

, 6 00

F w

y R

a m p s 6 9

, 2 4 7 7 9

, 8 0 3 9 0

, 3 5 9 1 0 0

, 9 1 6 10 4

, 9 1 5 1 0 8

, 9 14 11 2

, 9 1 3 1 1 6

, 9 12 12 0

, 9 1 2 1 2 4

, 9 11 12 8

, 9 1 0

M i n o r A r t e r i a l 7

, 46 9

, 9 4 5 7

, 6 2 7

, 1 73 7

, 78 4

, 4 0 0 7

, 9 4 1

, 6 28 8

, 31 3

, 4 9 4 8

, 6 8 5

, 3 60 9

, 05 7

, 2 2 7 9

, 4 2 9

, 0 9 3 9

, 80 0

, 9 5 9 1 0

, 17 2

, 8 2 5 1 0

, 54 4

, 6 9 1

M a

j o r A r t e r i al 3

, 65 5

, 8 8 5 3

, 7 0 6

, 9 98 3

, 75 8

, 1 1 1 3

, 8 0 9

, 2 24 3

, 92 3

, 0 2 8 4

, 0 3 6

, 8 31 4

, 15 0

, 6 3 5 4

, 2 6 4

, 4 3 8 4

, 37 8

, 2 4 2 4

, 4 9 2

, 0 45 4

, 60 5

, 8 4 9

R

a m p s 2 6 7

, 7 2 4 27 7

, 2 0 3 2 8 6

, 6 83 29 6

, 1 6 2 3 1 1

, 9 04 3 2 7

, 6 4 6 3 4 3

, 3 88 35 9

, 1 3 0 3 7 4

, 8 72 39 0

, 6 1 4 4 0 6

, 3 56

I n t e r s

t a

t e 3

, 82 5

, 7 1 1 3

, 9 1 0

, 4 46 3

, 99 5

, 1 8 0 4

, 0 7 9

, 9 15 4

, 24 9

, 1 6 8 4

, 4 1 8

, 4 22 4

, 58 7

, 6 7 5 4

, 7 5 6

, 9 2 9 4

, 92 6

, 1 8 2 5

, 0 9 5

, 4 35 5

, 26 4

, 6 8 9

F r eew a y 1

, 20 2

, 2 5 3 1

, 3 6 1

, 4 97 1

, 52 0

, 7 4 1 1

, 6 7 9

, 9 85 1

, 84 9

, 2 0 8 2

, 0 1 8

, 4 32 2

, 18 7

, 6 5 5 2

, 3 5 6

, 8 7 8 2

, 52 6

, 1 0 2 2

, 6 9 5

, 3 25 2

, 86 4

, 5 4 8

E x p r e s s w

a y 21 4

, 0 9 7 2 4 0

, 6 31 26 7

, 1 6 4 2 9 3

, 6 9 8 29 9

, 4 2 2 3 0 5

, 1 47 31 0

, 8 7 1 3 1 6

, 5 95 32 2

, 3 1 9 3 2 8

, 0 43 33 3

, 7 6 7
C

o l l e c t o r 2

, 7 7 6

, 7 75 2

, 98 1

, 1 6 4 3

, 1 8 5

, 5 53 3

, 38 9

, 9 4 2 3

, 6 9 3

, 1 3 4 3

, 99 6

, 3 2 7 4

, 2 9 9

, 5 19 4

, 60 2

, 7 1 1 4

, 9 0 5

, 9 04 5

, 20 9

, 0 9 6 5

, 5 1 2

, 2 88

L o

c a l 2

, 1 8 5

, 6 95 2

, 25 5

, 4 5 5 2

, 3 2 5

, 2 16 2

, 39 4

, 9 7 6 2

, 4 9 8

, 8 4 9 2

, 60 2

, 7 2 1 2

, 7 0 6

, 5 94 2

, 81 0

, 4 6 6 2

, 9 1 4

, 3 39 3

, 01 8

, 2 1 1 3

, 1 2 2

, 0 84

I n t r az o n al T r i p s 1 0 0

, 0 2 8 10 3

, 4 8 7 1 0 6

, 9 47 11 0

, 4 0 6 1 1 4

, 9 10 1 1 9

, 4 1 4 1 2 3

, 9 18 12 8

, 4 2 2 1 3 2

, 9 27 13 7

, 4 3 1 1 4 1

, 9 35

P u bl i c T r an s i t 6 1

, 0 5 4 6 3

, 0 0 3 6 4

, 9 5 1 6 6

, 9 0 0 7 9

, 8 8 0 9 2

, 8 6 0 1 0 5

, 8 40 11 8

, 8 2 0 1 3 1

, 8 00 14 4

, 7 8 0 1 5 7

, 7 60

V M T To t a l s 22, 4 6 9

, 0 2 0 2 3

, 2 8 9

, 1 7 5 2 4, 1 0 9

, 3 3 0 24, 9 2 9

, 4 8 5 2 6

, 2 3 8

, 7 7 0 2 7, 5 4 8

, 0 5 4 28, 8 5 7

, 3 3 9 3 0

, 1 6 6

, 6 2 3 3 1, 4 7 5

, 9 0 8 32, 7 8 5

, 1 9 2 3 4

, 0 9 4

, 4 7 7

S e g m e n t 2 01 0 2 01 1 2 0 1 3 2 01 5 2 02 0 2 0 2 1 2 0 2 2 2 02 3 2 0 2 4 2 0 2 5 2 03 0

E x

t

. Con n ec t o r 1

, 1 1 6

, 9 72 1

, 15 2

, 4 8 0 1

, 2 2 3

, 4 95 1

, 29 4

, 5 1 1 1

, 4 7 2

, 0 4 9 1

, 47 7

, 2 6 1 1

, 4 8 2

, 4 72 1

, 48 7

, 6 8 4 1

, 4 9 2

, 8 96 1

, 49 8

, 1 0 7 1

, 5 2 4

, 1 66

F w

y R

a m p s 1 4 0

, 9 0 8 14 5

, 3 0 6 1 5 4

, 1 04 16 2

, 9 0 1 1 8 4

, 8 95 1 8 3

, 5 5 7 1 8 2

, 2 19 18 0

, 8 8 0 1 7 9

, 5 42 17 8

, 2 0 3 1 7 1

, 5 11

M i no r A r t e r i a l 11, 6 6 0

, 2 9 0 1 2

, 1 1 2

, 2 4 5 1 3, 0 1 6

, 1 5 5 13, 9 2 0

, 0 6 5 1 6

, 1 7 9

, 8 4 0 1 6, 1 2 2

, 1 5 5 16, 0 6 4

, 4 7 0 1 6

, 0 0 6

, 7 8 4 1 5, 9 4 9

, 0 9 9 15, 8 9 1

, 4 1 4 1 5

, 6 0 2

, 9 8 8

M a

j o r A r t e r i al 4

, 94 7

, 2 5 9 5

, 1 4 8

, 2 38 5

, 55 0

, 1 9 6 5

, 9 5 2

, 1 54 6

, 95 7

, 0 4 8 6

, 9 1 1

, 2 19 6

, 86 5

, 3 9 0 6

, 8 1 9

, 5 6 1 6

, 77 3

, 7 3 1 6

, 7 2 7

, 9 02 6

, 49 8

, 7 5 7

R

a m p s 4 5 3

, 5 8 3 47 3

, 3 2 2 5 1 2

, 8 00 55 2

, 2 7 8 6 5 0

, 9 73 6 4 6

, 5 3 9 6 4 2

, 1 04 63 7

, 6 7 0 6 3 3

, 2 35 62 8

, 8 0 1 6 0 6

, 6 28

I n t e r s

t a

t e 5

, 77 2

, 4 4 9 5

, 9 5 2

, 7 93 6

, 31 3

, 4 8 1 6

, 6 7 4

, 1 70 7

, 57 5

, 8 9 0 7

, 5 4 3

, 7 49 7

, 51 1

, 6 0 8 7

, 4 7 9

, 4 6 7 7

, 44 7

, 3 2 6 7

, 4 1 5

, 1 85 7

, 25 4

, 4 8 0

F r eew a y 3

, 37 2

, 2 1 8 3

, 6 1 3

, 6 78 4

, 09 6

, 5 9 7 4

, 5 7 9

, 5 17 5

, 78 6

, 8 1 6 5

, 7 3 1

, 0 12 5

, 67 5

, 2 0 8 5

, 6 1 9

, 4 0 4 5

, 56 3

, 6 0 1 5

, 5 0 7

, 7 97 5

, 22 8

, 7 7 8

E x p r e s s w

a y 35 0

, 9 3 9 3 5 9

, 3 50 37 6

, 1 7 2 3 9 2

, 9 9 5 43 5

, 0 5 0 4 3 5

, 4 95 43 5

, 9 3 9 4 3 6

, 3 84 43 6

, 8 2 9 4 3 7

, 2 74 43 9

, 4 9 8

C

o l l e c t o r 6

, 4 2 1

, 8 65 7

, 01 8

, 4 9 9 8

, 2 1 1

, 7 66 9

, 40 5

, 0 3 3 1 2

, 38 8

, 2 0 0 1 2

, 4 1 7

, 2 7 4 1 2

, 44 6

, 3 4 7 1 2

, 47 5

, 4 2 1 1 2

, 50 4

, 4 9 5 1 2

, 53 3

, 5 6 9 1 2

, 67 8

, 9 3 7

L o

c a l 3

, 4 3 3

, 7 01 3

, 62 7

, 7 8 4 4

, 0 1 5

, 9 49 4

, 40 4

, 1 1 4 5

, 3 7 4

, 5 2 7 5

, 35 9

, 1 3 2 5

, 3 4 3

, 7 37 5

, 32 8

, 3 4 2 5

, 3 1 2

, 9 47 5

, 29 7

, 5 5 2 5

, 2 2 0

, 5 77

I n t r az o n al T r i p s 1 5 5

, 4 4 7 16 8

, 8 6 7 1 9 5

, 7 06 22 2

, 5 4 6 2 8 9

, 6 45 2 8 8

, 8 1 5 2 8 7

, 9 86 28 7

, 1 5 6 2 8 6

, 3 26 28 5

, 4 9 7 2 8 1

, 3 48

P u bl i c T r an s i t 1 9 6

, 7 0 0 19 6

, 7 7 0 1 9 6

, 9 10 19 7

, 0 5 0 1 9 7

, 4 00 1 9 7

, 4 7 0 1 9 7

, 5 40 19 7

, 6 1 0 1 9 7

, 6 80 19 7

, 7 5 0 1 9 8

, 1 00

V M T To t a l s 38, 0 2 2

, 3 3 0 3 9

, 9 6 9

, 3 3 1 4 3, 8 6 3

, 3 3 1 47, 7 5 7

, 3 3 2 5 7

, 4 9 2

, 3 3 3 5 7, 3 1 3

, 6 7 7 57, 1 3 5

, 0 2 0 5 6

, 9 5 6

, 3 6 3 5 6, 7 7 7

, 7 0 7 56, 5 9 9

, 0 5 0 5 5

, 7 0 5

, 7 6 7

* E s t i m a t e s f o r 19 9 7

, 20 0 0

, 2 0 1 0

, 2 0 20, a n d 203 0 a r e b a s e d o n R T C ' s T R A N P L A N r u n s Other values h a ve be en i n ter pol ated.

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 7-27.2.2 Contingency Measu r es

Section 187(a)(3) of the 1990 CAAA requ ires that contingenc y measures be included in the attainment plan. These measures are required to be implement ed if a non-attainment area fails to attain the federal s t andard by the designated attainment date. Additionally, a deviation from t he projected VMT of more than 3% will als o tri gger im plementation of conti ngency measures to offset excess VM T and associated mobile source CO emissions (U.S. EP A, 1992).

If sufficient emission reduc tions needed to attain t he federal CO air quality standard are not achieved as anticipated, or if actual VMT ex ceed projected VMT by 3%, the contingenc y measures listed in Table 7-2 be low will be implemented according to the severity of ambient exceeda nce or VMT increase. EPA guidance does not mandate a specific r eduction level that contingency measures must achieve. However, EPA consider s measures that offset one year VMT growth to be an appropriate guideline. For the Clark County nonattainment area, annualized VMT growth from 2000 to 2005 is 5 percent. At a minimum, contingenc y measures should provide CO emission reductions to counteract the effect of one year’s growth in VMT, or at least to offset the emissions caused by the incremental increase in VMT forecasted in Table 7-1 above.

TABL E 7-2

CONTINGENCY MEASURES

MEASURE AGENCY RESPONSIBLE FOR IMPLEMENTATION IMPLEMENTATION TRIGGER

On Board Di agnostics II (OBDII) T e sting Department of Motor Vehicles & Public Safet y 9.5 ppm – 11 ppm exce edance 3% - 5% VMT increase

Lower I/M Program Cutpoints Department of Motor Vehicles & Public Safet y 11 ppm – 15 ppm excee dance 5% - 10% VMT increase

On Road Re mote Sensing Department of Motor Vehicles & Public Safet y 11 ppm – 15 ppm excee dance 5% - 10% VMT increase

The contingency measures selected do have the potential to significantly reduce CO emissions. Due to the limitations of exis ting models to quantify the emission reductions from these progr ams, accurately quantifying the actual reduction is problematic. With respect to On Board Dia g nostics II (OBDII) testing, the EPA’s MOBILE6 model would be the appropriate tool to use in determining the effectiveness of this measure. Unfortunatel y, this model is still in the process of

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 7-3development. Based on EPA’s draft document titled, Determinatio n of CO Basic Em iss i on Rates, OBD and I/M E f fects for Tier I and Later LDVs and LDTs (EPA420-P-99-017), OBDII testing has si gnif i cant potential to reduce CO emissions. Until the official releas e of MO BILE6, it is not possible to quantify the benefits from this conti ngency measure. EPA has indic a ted that Clark County could use the Cold CO model to quantify th is benefit. Howev e r, this model uses assumptions that are not consistent wit h the MOBILE5 model used in the SIP.

Lowering the cutpoints associated wit h the State’s Vehicle Inspection/ Maintenan ce Program will also result in reduced emis sions as vehicles will have to meet more stringent test ing standards. The MOBILE model is the appropriate tool to utilize for estimating the benefits a ttri buted to lowering the cutpoints. The limitations prohibiting the use of this model at this time is the fact that only one data set of cutpoints, for a two-speed I/M test, is available. Based on conversations with EPA’s OTAQ Divis ion, it may be possible for additional data sets to be develo ped. Once new data se ts are develo ped, it will then be pos sible to run the MOBILE model to estimate the effects of lower I/M program cutpoints. Clark County is commi tted to working with EPA, Region IX and OTAQ on this issue and will incorporate this anal ysis in a future SIP revision.

On-road Remote Sensing of high emitti ng vehicles is another contingency measure that has the potential to r educe CO emissions. EPA has develo ped draft guidance (EPA4 20-P-98-00 7) and a utilit y program that works in conjunction with the MOBILE model to estimate the effe cts of remote sensing. Although the focus of this guidance is predominately on clean screening, it also looks at the application of remote sens ing to identify high emitting vehicles. Clark County attempted to seek authorization from OT AQ on the use of this draft guidance and utility program to estimate the emission re d u ction ben efit. Becau s e of the draft status of the guidanc e and the inability to obtain authorization to use the draft utility program, it is not possible to pr ovide a defensib le emission re duction for this contingency measure. It is import ant to mention that Clark County’s analysis using the RSD utility program indicates that a 1.3% redu ction in mobile source emissions.

As indicated above, it is not possibl e to quantify the emi ssion reduc tions and effectiveness of the conti ngency measures at this time. From a qualitative perspective however, these contin gency m easures will b e effective at reducing emissions upon their implementation and should provide ample reduction to offset emissions associated with a 5 percent growth in VMT. Related to all th e contingenc y measures specified above, Clar k County will prepare and submit a SIP revision that quantifies the actual benefits of these c ontingency measures, within one year of the rel ease dat e of MOBILE6 (or it s successor), guidance and applicable models. This commitment will be contained in the Clark County Bo ard of Commissioners resolution adopting this plan. Should the contingency measure analys is indicate that the proposed cont ingency measures do not provide ample reductions, the SIP revision will incl ude additional contingency measures.

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 7-4CARBON MONOXIDE STATE IMPLEMENTATION PLAN 7-5 EPA expects that actions needed for fu ll implementation of contingency measures occur within 60 days after EPA notifie s the area of its fa ilure to attain. EPA has also concluded that, to be benefic ial, contingency measures must be fully implemented within 12 months afte r EPA’s findings (Technical Support Document to Aid States with the Deve lopment of Carbon Monoxide SIPs, EPA - July 1992). Legislation and regulations currently exist in NRS 445B and NAC 445B, respectively, that allow for changes to the cutpoints in the I/M program and to allow for on-road remote sensing to be conducted. The Nevada Department of Environmental Protection is proceeding with regulation changes that will require OBDII testing be incorporated into the existi ng I/M program. It is anticipated that the State Environmental Commission will adopt these regulation changes by July, 2000. With the adoption of these regulations, these c ontingency measures will be able to be implemented in a ti mely manner, without further action. Appendix E, Section 8, also contains a discussion on other potential contingency measures and the reasons why each was not selected.

7.2.3 Annual VMT Tracking

Annual reports updating VMT forecasts and presenting VMT estimates for the previous year are required under Section 187(a)(2). As previously stated, the DCP will work with the RT C to prepare annual VMT tra cking reports. These annual reports will contain estimates of actual VMT in the previous year, forecasts of VMT in future years, and ve rification that supplemental (contingency) control measures are being implemented if actual VMT estimates for previous years exceed earlier forecasts. Annual VM T tracking reports will be submitted to the EPA in September of each year beginning in the year 2000 and following EPA reporting guidelines. A resolution adopted on July 13, 1995 by the Regional Transportation Commission committing to preparing and submi tting an annual VMT tracking report is contained in Appendix D, Section 8.

7.3 OTHER CONTROL MEASURES

Future monitoring data will indicate t he amount of progress being made towards attainment. Should this data reveal that additional steps are necessary to reach attainment by December 31, 2000, st eps will be taken to further program activities of the insurance measures contained in Table 7-3 below.

TABLE 7-3

OTHER CONTROL MEASURES

MEASURE RESPONSIBLE AGENCY

Voluntary Vehicl e Repair Program Clark County, DMV & PS

Smoking Vehicle Telephone Hotline DMV & PS

# C hapter Eight

– 

# Implementation/SIP Commitments

8.1 IMPLEMENTATION

8.2 SIP IMPLEMENTATION, MO NITORING AND REPORTING

8.3 MAINTENANCE

8.4 MOBILE SOURCES EMISSIONS BUDGET

8.5 ADDITIONAL COMMITMENTS TO INSURE CONFORMITY8.1 IMPLEMENTATION

Implementation of the contro l measures specified in Chapter 6 is necess a ry for the Valley to attain the CO NAAQS. The responsibility for implementing these control measures lies with the following gov ernmental entities: the Clark County Health Dis t rict, Air Pollution Contro l Division; the Nevada Department of Conservation and Natural Resources, Divis ion of Environmental Protection; and the Clark County Regional Tr ansportation Commission. Each of these entities has adequate personnel, funding and aut hority to implement their respective measure of the proposed prim ary control measures.

On April 22, 1999, the Clark County District Board of H ealth adopted Section 54, Cleaner Burning Gasoline, to the Air Pollution Control Regulations. The Reg i onal Transportation Commission, at their June 10, 1999, meeting, adop ted Resolution No. 177. T he adoption of th is resolution establis hes T D M program guidelines t o mitigate traffic congestion and dir e cts the RTC’s TDM Divis ion to implement and monitor this program. Chapter 486A, of the Nevada Revised Statutes mandates alternative fuel vehicle acquis ition, fuel usage and r eporting requirements applicable to all gov ernmental vehicles based in nonattainment areas. The Nevada Department of Cons ervation a nd Natura l Resourc e s, Division of Environmental Protection, via this legi s l ation, is the agency responsible for administering this program.

Additionally , the Nevada State Environm ental Commis s ion adopted a resolution on April 9, 1999, committing to adopti ng appropriate emission reduc t ion

measures as necess a ry to insure that ambient air quality standards c an be achieved and maint a ined in the Las Vegas Valley. This action by the Commission serves to further insure that attainment will occur by December 31, 2000. Copies of regulations and resolu tions mentioned abov e c an be found in Appendix D.

Table 8-1 s u mmarizes the implementation st atus of the primary c ontrol measures along with information on the agency respon sible for im plementing the respec tiv e control measure. TABL E 8-1

CONTROL MEASURE IMPLEMENTATION STATUS

Control Mea s ure Implementati on Date Re spo n si ble Agency

Clea n Burnin g Gasoline 1999 Health Distri ct Voluntary TCM/TDM Pro g ram 1999/O ngoi n g RTC Technici an Training/ Ce r t i f i c a t i o n 1 9 8 8 D M V & P S Alternative Fuels Program for Govern ment Fleets 1991/O ngoi n g NDEP/Govt. Entities

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 8-18.2 SIP IMPLEMENTATI ON, MONITORING AND RE PORTING

This plan provides direction for attaini ng the national CO stand ard. To insure that attainment is reached, the progr ess associated with im plementation of controls and the resulting emission reduction s must be monitored. In doing so, monitoring will indic a te if implementation is on sche dule or if implementation needs to be accelerated. This r e spons ibility will be s hared by t h e Clark County Health District AQD

, the State of Nev ada Department of Environm ental Protection, the Clark C ounty Regional Transportati on Commission and the Clark County Department of Compreh ensive Planning. Monitori ng will also assis t in determining the effectiveness of contro l measures. VMT will be monitored through an annual VMT tracki ng report. This annual r eport will serve as the vehicle by which monitoring / tracking of controls are repor ted to the EPA. Ambient air quality data will co ntinue to be monitored through the monitoring network described in C hapter 2 of this doc ument. Th is network will continue to be operated in accordance with t he federal requirements of 40 CF R Part 58 and quarterly reports will continue to be pr epar ed and su bmitted to the EPA b y the AQD. The Las V ega s Valley Air Qua lity P l ann ing Co mmittee will co ntinue to insure int e rgovernmental coordination, consensus building, and monitoring functions.

8.3 MAINTENANCE

The EPA r equires that implementation plans also prov ide for the maintenance of the standard after it has been attained. Si nce the primary source of CO is the on-road mobile sour ces category, VMT projections for five years past the demonstration date have been forecasted (T able 8-2). These VMT projecti ons will be utilized in conjunction with the M obile-UAM Modeling sy stem as part of monitoring the effectiveness of contro l measures past the year 2000. It is anticipated that additional modeling will be a requirement of maintenanc e plan submittals for areas se eking redesignation.

VMT contingency measures wi ll be trigger ed after the year 2000 in the event actual VMT s exc eed f o recasts. The Las Vegas Valley Air Quality Implementation Plan will remain in effect following t he attainment date unt il superseded by approval of a CO Maintenance Plan.

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 8-2TABL E 8-2

VMT ESTIMATES FOR MONITO RIN G AND MAINT E NAN C E

R

o a

d S e gm en t 2 0 0 0 2 0 01 2 0 02 2 0 03 2 0 04 2 0 0 5

E

x

t e r n al C onne c t or 765, 73 4 800, 85 7 835, 98 1 871, 10 5 906, 22 9 941, 35 3

F r e e w a y S y s t e m R a m p s 100, 91 6 104, 91 5 108, 91 4 112, 91 3 116, 91 2 120, 91 2

M i nor A r t e r i a l 7, 941, 62 8 8

, 313, 49 4 8

, 685, 36 0 9

, 057, 22 7 9

, 4 2 9

, 0 9 3 9, 800, 95 9

M a

jor

A r t e r i a l 3, 809, 22 4 3

, 923, 02 8 4

, 036, 83 1 4

, 150, 63 5 4

, 2 6 4

, 4 3 8 4, 378, 24 2

R

a m p 296, 16 2 311, 90 4 327, 64 6 343, 38 8 359, 13 0 374, 87 2

I n

t e r s t a

t e 4, 079, 91 5 4

, 249, 16 8 4

, 418, 42 2 4

, 587, 67 5 4

, 7 5 6

, 9 2 9 4, 926, 18 2

F r e

e w

a y 1

, 679, 98 5 1

, 849, 20 8 2

, 018, 43 2 2

, 187, 65 5 2

, 3 5 6

, 8 7 8 2, 526, 10 2

E

x p r es s w

a y 293, 69 8 299, 42 2 305, 14 7 310, 87 1 316, 59 5 322, 31 9

C

o l l e c t o r 3

, 389, 94 2 3

, 693, 13 4 3

, 996, 32 7 4

, 299, 51 9 4

, 6 0 2

, 7 1 1 4, 905, 90 4

Loc a l 2, 394, 97 6 2

, 498, 84 9 2

, 602, 72 1 2

, 706, 59 4 2

, 8 1 0

, 4 6 6 2, 914, 33 9

I n t

r a

z o n a l T r i p s 110, 40 6 114, 91 0 119, 41 4 123, 91 8 128, 42 2 132, 92 7

P

ubl i c T r a n s i t 66, 9 0 0 79, 88 0 92, 86 0 105, 84 0 118, 82 0 131, 80 0

D a i l y Av er a g e T o t a l 2 4

, 9 2 9

, 48 6 26, 2 3 8

, 770 2 7

, 5 4 8

, 0 54 28

, 8 57

, 3 3 9 3 0

, 1 66

, 6 23 31

, 4 7 5

, 9 0 8

8.4 MOBILE SOURCE S EMISSIONS BUDGE T

Under the conformity provisions of the Clean Air Act, Section 176(c)(2)(A) requires regional transportation plans an d programs to show that “emissions expected f r om implementat ion of plans and progr am s are consistent with estimates from motor vehicles and neces s a ry emission reduct ions contained in the applic able imp l e m entation plan.” On Novemb er 24, 1993 EPA iss u e d regulations defining h o w the provisions of 176(c) will work, including defin in g mobile v ehicle emiss i on budgets in applicab le SIPs. EPA conformity rule defines motor vehicle emissions budgets as:

“.... the explic it or implicit ide n ti fication of the moto r vehicle-related portions of the projected emission inventory used to demonstrate reasonable further progress m i lestones, attainment, or m a intenance for a particular year specified in the SIP.”

The motor vehic l e emissions budget t herefore establishes a cap on m o tor vehicle-related emissions whic h cannot be exceeded by predicted transportation system emissions in t he future. The em issions budget applies as a ceiling on emissions in the year for which it is defined and for all subsequent years until another year for which a different budget is defined or until a SIP rev i sion modifies the budget.

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 8-3Without a clearly indicat ed intent otherwise express ed in the SIP, the SIP’s estimate of future tra n sportation netwo rk emissions used in the milestone or attainment demonstration is the motor v ehicle emiss i ons budget. The SIP may also specif y emissions budgets for subar eas of the region, provided the SIP includes a demonstration that the s ubregional emissions budget, when com b ined with all oth e r portions of the emissions inve ntory, will r e sult in att a inment an d/or maintenance of the standard.

The emiss i ons analys is for conf ormity determinations must inc l ude emiss i ons from the entire transportation network withi n the nonatt a inment ar ea. Likewise, if the transportation and air quality m odeling domains extend beyond the nonattainm ent area, the budget applies for the portion only within the nonattainm ent area boundary. In the case of Las Vegas , the nonattainment area encompass e s both the air qua lity modelin g d o main (UA M) and the transportation planning domain.

EPA’s conf ormity rule requires that ai r quality implem entati on plans contain an emissions budget. The emissions budget re flects the portion of emissions , by source cat egory and year, whic h can be accommodated in the airshed wit hout exceeding the NAAQ S. The emissions budgets als o reflect the effects that control measures will have in future years.

Table 8-3 below provides a breakdown of the Las Vegas Valley Nonattainm ent Area’s attainment and future horizon year’s emission budgets.

TABL E 8-3

LAS VEGAS VALLEY PEA K SEASON E M ISSION BUDGETS by Source Category

S our ce C a t e gor y 199 6 200 0 201 0 202 0 (T o n s/ D a y ) (T o n s/ D a y ) (T o n s/ D a y ) (T o n s/ D a y )

O n

- r oad M o t o r V ehi cl e s * 405

. 4 310

. 2 329

. 5 45 7. 4

A r ea S our ce s 8. 5 9

. 9 15. 3 19. 4

Po i n t So u r c e s 6. 5 6

. 5 6. 5 6. 5

N on- r oad Sour ces ex cl

. C ount y A i r por t s 22. 3 20. 1 18. 2 19. 3

C ount y A i r por t s 36. 4 40. 4 55. 6 77. 1

T o t a l B udg et 47 9. 1 3 8 7

. 2 42 5. 2 57 9. 7

M a x i mu m P r e d i c t e d C O C o n c e n t r a t i o n ( p p m ) 11. 2 8

. 1 7. 2 8. 5

* O n

- R o a d M o bi l e So ur c e s Bud g et s ar e ad j us t e d f o r t h e M o nt h of D e c e m b er ( a d j u s t m e n t f a c t o r = 1. 0 21)

CARBON MONOXIDE STATE I M PLEMENTATION PLAN 8-4CARBON MONOXIDE STATE IMPLEMENTATION PLAN 8-5 8.5 ADDITIONAL COMMITMENTS TO INSURE CONFORMITY

The ability for Transportation Im provement Programs and Regional Transportation Plans to demonstrate confo rmity with this Air Quality Plan in future years is of utmost importance to State and local gover nmental agencies. To insure that a positive conformi ty determination can be made on the aforementioned transportation documents, this section constitutes an implementation plan commitmen t to promulgate regulations as provided for in the U.S. Environmental Protec tion Agency’s Transportation Conformity Rule (40 CFR 51.452).

Contained in the 1995 Ca rbon Monoxide Air Quality Implementation Plan, the commitment to remote sensing of 90% of all vehicles in the Las Vegas Valley by 2011 was made by the Nevada D epartment of Motor Vehicl es and Public Safety (DMV&PS). This commitment is carried fo rward with this plan so that an additional 5% emission reduction will take place.

The additional commitment constitutes a control measure that will insure a positive conformity determination. Addi tionally, the Nevada State Environmental Commission adopted a Resolution at their meeting on April 9, 1999, committing to “adopting appropriate emission reduction measures as necessary to ensure that ambient air quality standards can be achieved and maintained in the Las Vegas Valley, and conformity between t he Transportation Improvement Program and the State Implementation Plan can be demonstrated”. This commitment by the State Environmental Co mmission will provide additi onal emission reductions. A copy of the resolution and the commi tment letter from Nevada DMV&PS is located in Appendi x D, Section 7.

# R eferences

1. Bohning, S. 1998. Letter to Cl ete Kus, Clark County Department of Comprehensive Planning, from the U.S. Environmental Protection Agenc y, Region IX, San Francisco, CA (October 27, 1998).

2. Bowen, J.L. and R.T. E gami. 1994. “Clark Count y Car b on Monoxide Hotspot Study”, Final report prepared for the Clark County Health District, DRI Document NO. 6460-684-4010.1F1, Nov. 10, 1994.

3. BRW and SAI. 1992. “Las Vegas Ai r Quality Implement ation Plan Update, Phase II: Carbon Monoxi de Modeling and Attainment Demonstration.” Prepared for the Clark County Department of Comprehensiv e Planning, by BRW, Inc., San Diego, CA and Sy stems Applications, Inc., San Rafael, CA.

4. CCDCP. 2000. Supplem ental Urban Airshed Modelin g Analys is for the Las Vegas Valley Carbon Monoxide Attainment Demonstration.

5. CCDCP. 2000. Microscale Hot S pot Modeling with the CAL3HC for the Las Vegas CO SIP.

6. DRI, STI, and ENVIRON. 1996. “Modelin g Protocol for the Las V egas Valley Carbon Monox i de Urban Airshed Modelin g Project – Phase II: Field Dat a Collection.” Prepared for the Clark County Department of Comprehensiv e Planning, by the Desert Research In stitute, Reno, NV ., Sonoma T e chnology, Inc., Santa Rosa, CA, and ENVIRON Intern ational Corp.

, Novato, C a lifornia.

7. Egami, D., J. Bowen, P. Roberts, S. Reyes, T. Dye, C. Emery, D. Souten. 1998. “The Las Vegas Valley Carbon Monoxide Urban Airs hed Model Updat e Project – Phase II: Field Data Collection.” Prepar ed for the Clark County Department of Comprehensiv e Planning, by the Desert Research Institute, Reno, NV, Sonoma Technology, Inc. , Santa Rosa, CA, and ENVIRO N International Corporation, Novato, CA.

8. Emery, C., J. Heiken, D. Souten. 1996. “Phase I Draft Final Report. ” Technical memorandum prepared for t he Clark County Department of Comprehensive Planning, by ENVIRON International Cor p ., Novato, California.

________________________ __________________ ______________________ CARBON MONOXIDE STATE I M PLEMENTATION PLAN R-1

# R eferences - Continued

9. Emery, C., D. Souten , N. Kumar, F. Lurmann, and P. Roberts. 1998. “The Las Vegas Valley Carbon Monoxide Ur ban Airshed Model Update Project – Phase II: UAM Base Case and Sensitivit y Applications.” Prep ared for th e Clark County Department of Comp rehensive Planning, by ENVIRO N International Corporat ion, Novat o , CA , and Sonoma T e chnology, Inc., Santa Rosa, CA.

10. Emery, C., D. Souten. 1998. “Results of Revise d Phase II Base Case CO Modeling, and Recommendati on of Epis ode Selec t ion for Future Year Assessments.” Technical memorandum prepared for Scott Bohning of the U.S. Envir onmental Protection Agency, Region IX, San Francisco, CA, by ENVIRON Internationa l Corp., Novato, CA.

11

. ENVIRON. 1996. “Modelin g Protocol for the Las Vegas Valley Carbon Monoxide Urban Airs hed Model Update Pr oject.” Prepared for the Clark County Department of Comp rehensive Planning, by ENVIRON International Corp., Novato, California.

12. EPA 1992. Guidelines fo r Regulatory Applic ation of the Urban Airshed Model for Areawide CO Applicat ions. EPA-450/4- 92-011a&b, Res e arch Triangle Park, NC.

13. U.S. EPA. Janu ary 1992. Section 1 87 VMT F o recasting and Trac kin g Guidance.

14. EPA. 1 9 9 7 . “Guidance on Inc o rporati ng Volu ntary Mobile Sou r ce Emission Reduction Programs in State Implementat ion Plans ( S IPs).” Memorandum to EPA Reg i onal Administrators, from Ric hard D. Wilson, Actin g Assistan t Administrator for Air and R adiation (Oct ober 24, 1997).

15. EPA. 199 1. Emission Inventory Require ments for carbon Monoxide Sta t e Implementation Plans . U.S. EPA. Re search Triangle Park, NC ( EPA-450/4

- 91-011).

16. EPA. 1991. Final Draft, Secti on 187 VMT Forecasting and Tracking Guidance.

17. EPA. 1988. Guidan ce for the Preparatio n of Qua lity Assurance Plans for O3/CO SIP Emission Inv entory. EPA-450/4

- 88-023.

________________________ __________________ ______________________ CARBON MONOXIDE STATE I M PLEMENTATION PLAN R-2__________________________________________ ______________________ CARBON MONOXIDE STATE IMPLEMENTATION PLAN R-3 

# R eferences

– 

# Continued

18. EPA. 1991. Procedures for the Pr eparation of Emission Inventories for Carbon Monoxide and Precursors of Oz one, Volume I: General Guidance for Stationary Sources. EPA- 450/4-91-016, Research Triangle Park, NC.

19. EPA. 1991. Procedures for the Pr eparation of Emission Inventories for Carbon Monoxide and Precursors of Ozone, Volume II: Emission Inventory Requirements for Photochemical Air Quality Simulation Models. EPA-450/4- 91-014, Research Triangle Park, NC.

20. EPA. 1991. Quality Review Guidelines for 1990 Base Year Emission Inventory. EPA-450/ 4-91-022, Research Triangle Park, NC.

21. EPA. 1991. User’s Guide to MOBI LE5. U.S. EPA, Ann Arbor, Michigan.

22.Lima and Associates. 1998. “C arbon Monoxide Transp ortation Control Measures Analysis.” Prepared for the Clark County Department of Comprehensive Planning, by Lima & Associates.

23. Environ, July 1999. “Dispersion M odeling of Carbon Monoxide Emissions from Three Clark County Airports in Suppor t of the Revised CO SIP”. Prepared for the Clark County Department of Aviation, by ENVIRON International Corp., Novato, California.

24. Ricondo & Associates, 1999. “Carbon Monoxide Emissions Inventories and Dispersion Modelin g from McCarran Internati onal, North Las Vegas, and Henderson Executive Airports ” Prepared for Clark County, Department of Aviation.