FINAL – ADOPTED

January 4, 2006

FINAL – ADOPTED

January 4, 2006

Volume II Volume II

Ozone Strategy

Bay Area 2005

Association

of Bay Area

Governments
 

BAY AREA 

2005 OZONE STRATEGY 

APPENDIX C - STATIONARY AND MOBILE 

SOURCE MEASURE DESCRIPTIONS 

FINAL ADOPTED 

JANUARY 4, 2006 

939 Ellis Street 

San Francisco, CA 94109 

(415) 771.6000 

www.baaqmd.gov
Bay Area 2005 Ozone Strategy C - 2 Final Adopted – January 4, 2006 

APPENDIX C - STATIONARY AND MOBILE SOURCE CONTROL 

MEASURE DESCRIPTIONS 

 

TABLE OF CONTENTS 

Stationary Source Control Measures 

Control Measure SS 1: AUTO REFINISHING............................................................ C - 3

Control Measure SS 2: GRAPHIC ARTS OPERATIONS .......................................... C - 6

Control Measure SS 3: HIGH EMITTING SPRAY BOOTHS ..................................... C - 9

Control Measure SS 4: POLYESTER RESIN OPERATIONS.................................... C-12

Control Measure SS 5: WOOD PRODUCTS COATING............................................ C-14

Control Measure SS 6: FLARES................................................................................ C-17

Control Measure SS 7: GASOLINE BULK TERMINALS AND PLANTS.................... C-20

Control Measure SS 8: MARINE LOADING OPERATIONS ...................................... C-23

Control Measure SS 9: ORGANIC LIQUID STORAGE TANKS ................................ C-26

Control Measure SS 10: PRESSURE RELIEF DEVICES AND BLOWDOWN 

SYSTEMS.......................................................................... C-29

Control Measure SS 11: WASTEWATER SYSTEMS................................................ C-33

Control Measure SS 12: INDUSTRIAL, INSTITUTIONAL AND COMMERCIAL 

BOILERS ........................................................................... C-37

Control Measure SS 13: LARGE WATER HEATERS AND SMALL BOILERS.......... C-41

Control Measure SS 14: STATIONARY GAS TURBINES......................................... C-45

Control Measure SS 15: PROMOTE ENERGY CONSERVATION............................ C-48

Mobile Source Control Measures 

Control Measure MS 1: DIESEL EQUIPMENT IDLING ORDINANCE ...................... C-51

Control Measure MS 2: GREEN CONTRACTING..................................................... C-54

Control Measure MS 3: LOW-EMISSION VEHICLE INCENTIVES ........................... C-56

Control Measure MS 4: VEHICLE BUY BACK PROGRAM....................................... C-59
Bay Area 2005 Ozone Strategy C - 3 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 1: AUTO REFINISHING 

Control Measure Description 

This control measure would reduce ROG emissions from automobile refinishing facilities 

through lower VOC limits for some categories of coatings based on the comparable 

South Coast Rule 1151. 

Background and Regulatory History 

The Air District regulates ROG emissions from auto refinish operations by setting volatile 

organic compound (VOC) limits on various types of paints and surface preparation 

solvents used in auto refinishing. In addition, the amount of some high-VOC coating is 

limited by a volume relationship with other coatings. This prevents “gaming” by using 

high-VOC coatings for general, rather than specialized purposes. Also, the rule requires 

the use of spray technology that is transfer efficient, to minimize the amount of paint that 

misses or bounces off the intended surface. 

Regulation 8, Rule 45: Motor Vehicle and Mobile Equipment Coating Operations, which 

includes auto refinishing and new and used mobile equipment coating, was adopted in 

1989. Auto refinish facilities were previously subject to the less stringent standards in 

Regulation 8, Rule 4: General Solvent and Surface Coating Operations, which limits 

facility emissions but not the VOC content of paints. The rule was also amended several 

times, most significantly in 1994. The emissions from auto refinishing operations (both 

coating and solvent) have been reduced from over 11 tons per day prior to the 

implementation of Rule 45 to approximately 3.3 tons per day today. 

Emissions Subject to Control 

The emissions from auto refinishing are included in the emission inventory as point 

sources. Any coating operation that uses 30 gallons of coating and solvent per year is 

required to have an Air District operating permit, and must submit usage information 

annually from which emissions are calculated. Auto refinish coating emissions are 

Category 274 in the emissions inventory. Category 275 is solvent used for surface 

preparation and clean up in auto refinishing and mobile coating operations. 

 Emissions Subject to Control 

(TPD, Summer) 

Year Cat. 274 Cat. 275 

2003 2.12 1.21 

2006 2.21 1.26 

Proposed Method of Control 

This proposal draws from two sources, South Coast Rule 1151: Motor Vehicle and 

Mobile Equipment Non-Assembly Line Coating Operations, and a draft suggested 

control measure currently being developed by CARB staff that recommends 1) 

combining separate categories for automobiles and mobile equipment, 2) elimination of 

the averaging provision for compliance with VOC limits for multistage topcoats, 3) 
Bay Area 2005 Ozone Strategy C - 4 Final Adopted – January 4, 2006 

combining other coating categories, 4) replacing the specialty coatings category with 

specific coatings with appropriate VOC limits, and 5) reducing VOC coating limits in a 

number of coating categories. In addition, the suggested control measure proposes a 25 

g/l VOC limit on solvent surface preparation and cleaning operations, based on the 

South Coast rule. 

Adoption of the South Coast limits was proposed for the 2000 Clean Air Plan and 

evaluated in the 2001 Ozone Plan for the One Hour Federal Standard RACM Analysis. 

At that time, an analysis of the lower South Coast limit for clear coatings showed a cost 

effectiveness of $35,000 per ton. However, as costs have come down since that 

analysis, the potential to reduce emissions at a reasonable cost should be re-examined. 

Automobiles (motor vehicles) and mobile equipment (public transit buses, trains, 

bulldozers, golf carts, street cleaners, etc.) are subject to different sets of VOC limits, the 

more stringent for mobile equipment. Based on the suggested control measure, these 

would be combined and given VOC limits that would, overall, be more stringent. For 

multistage topcoats, the individual coatings consist of base coat (or color coat), and clear 

coat. Although there are often a number of base coats of varying translucency, the base 

coat/clear coat application form a coating system. Currently, Bay Area Regulation 8, 

Rule 45: Motor Vehicle and Mobile Equipment Coating Operations, allows averaging of 

VOC contents of the coatings in the system based on specified formulae for the number 

of layers of coating used. The VOC limit would be replaced by VOC limits for each type 

(or layer) of coating. Other coating categories, specifically in the primer stage, would be 

eliminated. Rule 45 currently has separate VOC limits for pretreatment wash primer, 

primer, precoat, and primer-sealer. The category specialty coating is proposed to be 

eliminated. Specialty coating is a catch-all category for typically minor use coating that 

does not fit within the iterated categories. It would be eliminated and replaced with two 

categories of coating, antiglare (safety) coating, and uniform finish coating. Both of these 

categories would have VOC limits significantly lower than the existing limit for specialty 

coatings, 840 g/l, but the existing rule constrains use of these coatings on a volume 

basis whereas the draft suggested rule does not. Also, some coatings would have a 

lower VOC limit. These, primarily topcoat and clearcoat, would make of the bulk of the 

emissions reduction. Finally, Rule 45 currently has an VOC limit for surface preparation 

solvent of 72 g/l, except for plastic parts. The proposal would set a VOC limit for all 

surface preparation and clean-up of 25 g/l. 

Currently, staff of the Stationary Source Division of CARB have developed a draft 

suggested control measure in the form of a rule and have discussed it at public 

workshops on June 28, 2005 and June 30, 2005. CARB staff is waiting for more 

information from industry on a variety of topics related to the draft. CARB staff expects 

to present a proposal to their Board in Fall 2005. Because the auto refinish industry 

varies little between districts, coordination of statewide efforts is desirable. 

Emission Reductions Expected 

The emission reduction estimates consider only the implementation of a requirement to 

use high solids, low VOC clear topcoat. Additional reductions may be possible from the 

elimination of coating categories, however, they cannot be quantified at this time. 

Furthermore, a reduction in the emissions from associated solvent surface preparation 

and clean up should be considered. The emissions from implementation of a low-VOC 

clear coat standard would result in emissions reductions of 33%, or 0.7 tons per day. 
Bay Area 2005 Ozone Strategy C - 5 Final Adopted – January 4, 2006 

Costs of Control 

The control costs are based on the cost to the finisher of a high solids low-VOC clear 

coat, resulting in a reduction in the basecoat/clearcoat coating system or a reduction in 

the VOC attainable in individual coating categories. Currently, the Bay Area rule allows 

most coating companies to sell clear coat that has about 420 grams/liter VOC content 

(3.5 lbs/gal). There is also clear coat available at 250 – 265 g/l VOC content, used 

sometimes with higher VOC base coats to comply with the average VOC standard for 

basecoat/clearcoat systems. Due to increased production of low VOC clear coats 

because of South Coast Rule 1151 that mandates their use, the cost has come down 

since the 2000 investigation. High solids low-VOC clear coats are now available at 

lower cost than the conventional material used to meet Bay Area regulations, and the 

reducer or thinner used is also less expensive. Based on the clear coat alone, on which 

the emissions reductions are based, adoption of lower VOC standards could now save 

money. Some other elements of the rule could negate that cost savings, but the rule 

would still likely be cost effective. 

Other Impacts 

No significant adverse environmental impacts are expected as a result of the adoption of 

this control measure. The affected industry is already regulated and proposed changes 

in paint formulations will not be implemented in a way that will add to waste streams or 

impact other media. 

References 

South Coast Rule 1151: Motor Vehicle and Mobile Equipment Non-Assembly Line 

Coating Operations, and staff report dated 12/11/98 

2001 Ozone Plan for the One Hour Federal Standard RACM Analysis 

Bay Area Regulation 8, Rule 45: Motor Vehicle and Mobile Equipment Coating 

Operations 

CAPCOA Enforcement Managers' Automotive Coatings Model Rule, Final Draft, 7/19/02 

e-mail communication with Barb Fry, ARB Stationary Source Division, 5/20/03 

CARB workshop announcement, suggested control measure and summary, June, 2005 
Bay Area 2005 Ozone Strategy C - 6 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 2: GRAPHIC ARTS OPERATIONS 

Control Measure Description 

This control measure would reduce ROG emissions from printing operations by reducing 

the allowable VOC limit for flexographic ink used on porous substrates and by limiting 

the VOC content of clean up solvent used on flexographic presses. 

Background and Regulatory History 

The Air District regulates ROG emissions from graphic arts operations by setting volatile 

organic compound (VOC) limits on various types of inks and coating used in printing 

press operations. Also, fountain solutions used to wet image plates and solvents used 

to clean presses are limited by vapor pressure and/or VOC content. Regulation 8, Rule 

20: Graphic Arts Printing and Coating Operations was first adopted in 1980. The initial 

rule was based on an EPA Control Techniques Guideline for rotogravure and 

flexographic presses. Amendments in 1984 established standards for both letterpress 

and lithographic printing, and subsequent amendments made the limits applicable to 

smaller facilities, lowered allowable VOC limits and implemented the Bay Area 

Stratospheric Ozone Policy. Approximately 1600 graphic art establishments operate in 

the Bay Area, ranging from small local printing operations to large newspaper, 

magazine, and packaging operations. 

Emissions Subject to Control 

The emissions from printing operations are included in the emission inventory. Any 

printing operation that uses 30 gallons of coating or ink and solvent per year is required 

to have an Air District operating permit, unless the materials have less than 1% VOC by 

weight. This exemption has been a driving force in the development of soy based 

lithographic printing inks that have less than 1% VOC. The emissions inventory lists 

categories for gravure printing, flexographic printing, letterpress printing, lithograhic 

printing, silk screening and small in-house printing. The emissions that are the subject 

of this control measure are in category # 109 in the emissions inventory, which are all 

point sources. 

 Emissions Subject to Control 

(TPD, Summer) 

Year Cat. 109 ink Cat. 109 cleanup 

2003 0.36 0.06 

2005 0.36 0.06 

Proposed Method of Control 

The CAPCOA All Feasible Measures review found the Sacramento Metropolitan Air 

Quality Management District (AQMD) and South Coast AQMD graphic arts rules to be 

the most stringent rules considered feasible. In the South Coast, graphic arts (printing) 

operations are controlled by Rule 1130: Graphic Arts. In Sacramento, graphic arts 

operations are controlled by Rule 410: Graphic Arts Operations. Bay Area graphic arts 
Bay Area 2005 Ozone Strategy C - 7 Final Adopted – January 4, 2006 

operations are controlled by Regulation 8, Rule 20: Graphic Arts Printing and Coating 

Operations. 

South Coast Rule 1130: Graphic Arts has one ink VOC limit that is more stringent than 

the Bay Area limit. Flexographic ink used on porous substrates are subject to a VOC 

limit of 225 grams/liter. All flexographic inks used in the Bay Area are subject to a VOC 

limit of 300 grams/liter. 

Sacramento Rule 410: Graphic Arts, has no VOC limits for inks, coatings or adhesives 

that are more stringent than the VOC limits in Bay Area Rule 20. In fact, several ink 

VOC limits for screen printing are less stringent than Bay Area limits. However, the 

Sacramento rule does have a more stringent clean up limit for solvent used to clean 

flexographic presses. The clean up solvents limits in both rules are expressed in terms 

of VOC content or vapor pressure or both, depending on the type of printing press or 

press component being cleaned. The Sacramento limit for flexographic press clean up 

solvent is 100 grams VOC/liter and 3 mm Hg vapor pressure. The Bay Area limit is 810 

grams VOC/liter and 21 mm Hg vapor pressure. However, the South Coast has even 

more stringent VOC limits for graphic arts equipment clean up. The South Coast has 

adopted stringent VOC limits that become effective on 7/1/2005 and has no limits on the 

vapor pressure of solvents. The South Coast limits for clean up do not go into effect 

unless a technology review in 2004 finds them feasible. Among the South Coast VOC 

limits for clean up solvents, a 25 grams VOC/liter limit is in effect (SCAQMD Rule 1171) 

currently for clean up solvent used on flexographic presses, more stringent than the 

Sacramento limit. 

The CAPCOA All Feasible Measures review process does not consider future effective 

VOC limits that require a technology review to be feasible. The feasibility, however, 

changes as the limits become effective and technology becomes available. 

Consequently, this control measure only analyzes the potential emissions reductions 

from the 25 gram per liter VOC limit for flexographic clean up solvent and 225 gram per 

liter VOC limit for flexographic ink, although additional emission reduction opportunities 

from the source category may be discovered during the rule development process. 

Emission Reductions Expected 

The Bay Area inventory for flexographic printing shows 0.36 tons per day organic 

emissions from printing and 0.06 tons per day organic emissions from solvent clean-up 

operations. A reduction in the allowable VOC content of flexographic ink could yield a 

25% reduction [0.36 * (1 - 225/300) = 0.09 tons per day]. A reduction in the allowable 

VOC content of the flexographic clean up solvent would yield 0.058 tons per day [0.06 * 

(1-25/810)]. Combined emissions reductions are 0.15 tons per day. The emission 

reductions may be less, however, as the South Coast clean up solvent limit only affects 

flexographic printing on porous substrates. Under Rule 1130, non-porous substrates, 

such as food packaging film, are allowed to use ink of 300 grams VOC/liter, which is the 

same as the Bay Area standard. 

The potential emission reductions from this control measure appear to be greater than 

de minimis. In addition, the South Coast technical evaluation of lower VOC lithographic 

press clean up solvent, scheduled for 2004, may add to the potential emission 

reductions. The emissions from clean up solvent from litho presses in the Bay Area is 

currently 0.75 tons per day. 
Bay Area 2005 Ozone Strategy C - 8 Final Adopted – January 4, 2006 

Costs of Control 

Lower VOC flexographic ink is priced comparably with 300 g/l ink. Costs for lower VOC 

clean up solvent have yet to be determined. 

Other Impacts 

No significant adverse environmental impacts are expected as a result of the adoption of 

this control measure. The affected industry is already regulated and proposed changes 

in ink or cleaning solvent formulations will not be implemented in a way that will add to 

waste streams or impact other media. 

References 

Sacramento Metropolitan AQMD Rule 410: Graphic Arts 

South Coast AQMD Rule 1130: Graphic Arts Operations, and staff report dated Sept., 

1999 

South Coast AQMD Rule 1171: Solvent Cleaning Operations 

Telephone conversation, Gerald Boneto, California Printing Industries Council, 

2/25/2004 

Telephone conversation, Duke Nickoley, Flint Ink, 3/1/2004 
Bay Area 2005 Ozone Strategy C - 9 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 3: HIGH EMITTING SPRAY BOOTHS 

Control Measure Description 

This control measure would reduce ROG emissions from coating operations that emit in 

excess of 20 tons of emissions per year. It would require a reduction beyond the use of 

coatings that comply with existing Air District rules. Spray booths or enclosed coating 

operations could be abated to meet a standard based on a percent reduction 

requirement, or alternative lower emitting coating technology could be sought. 

Background and Regulatory History 

The Air District regulates industrial and commercial coating through industry or substrate 

specific rules. Due to the vast number of coating applications, fifteen of the fifty Air 

District organic compound rules affect these types of coating applications. Each rule 

sets specific volatile organic compound (VOC) content limits on various types of inks, 

coatings or adhesives, although the option exists in each rule to meet the VOC limits by 

the use of add on control technology. In addition, Regulation 2, Rule 2: New Source 

Review, requires the use of Best Available Control Technology (BACT) for new or 

modified sources that emit more than 10 pounds of organic compounds per day. For 

larger coating sources, BACT has required installation of abatement technology. 

Consequently, some of the sources that would be subject to this control measure would 

already meet the mandates for additional control. The South Coast has already 

implemented this control measure. Rule 1132: Further Control of VOC Emissions from 

High Emitting Spray Booth Facilities, is derived from the South Coast's 1999 AQMP, 

control measure CTS-09. Rule 1132 requires coating facilities that emit 20 tons of VOC 

per year from spray booths to reduce emissions by 65% from a 2001 baseline, primarily 

through the installation of abatement equipment, although alternative compliance options 

exist. 

Emissions Subject to Control 

There are 12 facilities in the Bay Area that do surface coating that emit 20 tons VOC per 

year. Of these, 47% of the total emissions are from 2 facilities, New United Motors 

Manufacturing in Fremont and Ball Metal Beverage Container in Richmond. Five of the 

facilities, including New United Motors and Ball Metal, are already abated, with 

emissions are controlled to at least the extent required by the South Coast rule. Of the 

remaining seven facilities, one is a mobile equipment manufacturer, one is a can 

manufacturer, one a wood furniture company, two are metal parts manufacturers, and 

two are foundries that have significant coating emissions. 

Because this rule is source specific rather than source category or industry specific, the 

emissions are found in several source categories in the emission inventory. It is more 

appropriate to look at specific facilities that would be subject to the rule. The following 

table shows emissions on a facility by facility basis. Emissions Subject to Control 

consists of the emissions from specific sources at Bay Area facilities that emit 20 tons or 

organic compounds per year in each of the source surface coating source categories 

from the emissions inventory. 
Bay Area 2005 Ozone Strategy C - 10 Final Adopted – January 4, 2006 

Facility Emissions Subject 

to Control 

Potential 

Reduction at 65% 

US Pipe and Foundry 297 lb/day 193 lb/day 

McGuire Furniture 128 lb/day 83 lb/day 

Gillig Corp. 198 lb/day 129 lb/day 

Enclosures Engineering 185 lb/day 120 lb/day 

Container Mgmt Serv. 140 lb/day 91 lb/day 

Rexam Beverage Can 170 lb/day 110 lb/day 

American Brass and 

Iron 

436 lb/day 283 lb/day 

The emissions total 0.78 tons per day and the reduction, assuming 65% control could be 

achieved on all operations, is approximately 0.5 tons/day. 

Proposed Method of Control 

The Bay Area, like the South Coast, has numerous rules that affect commercial and 

industrial coating operations. Some, such as Wood Products Coating and Automotive 

Refinish Coating, have already been identified for emission reductions (see Wood 

Products Coating and Auto Refinishing Control Measure Descriptions, respectively). 

Others, such as aerospace coating, have very small inventories or, such as can and coil 

coating, already have emissions largely controlled by abatement technology. For 

coating categories for which there is sufficient inventory and technical evidence that 

emissions can be further reduced, staff will continue to pursue emission reduction 

opportunities. However, this control measure is directed at various source categories at 

the highest emitting facilities. If emissions are sufficient, it is considered to be cost 

effective to abate emissions instead of reduce solvent content in coating materials. A 

65% reduction requirement would also allow alternative coating technology such as 

ultraviolet cured coatings or very low VOC water based technology. 

Several air pollution control devices are available to reduce VOC emissions from spray 

booths. They include commonly used control technologies such as carbon or zeolite 

adsorption, and thermal or catalytic oxidation, and newer technologies such as 

biofiltration, cryogenic condensation, ultraviolet oxidation, and hybrid 

concentrator/oxidation systems. A 65% reduction, as specified by the South Coast rule, 

could be achieved by any of these technologies. 

Emission Reductions Expected 

The South Coast rule only applies to emissions from spray booth operations, and 

exempts booths with air flows that have a low VOC concentration because control of 

these booths is much less cost effective. The South Coast staff report estimates that, 

due to this exemption, emission reductions are about 15% less than they would have 

been had all sources had to reduce emissions by 65%. Based on the seven currently 

unabated Bay Area facilities with coating emissions of 20 tons per year, and assuming a 

15% of the emissions would be exempted from the requirement due to cost or technical 

problems, an emissions reduction of approximately 0.43 tons per day could be achieved. 
Bay Area 2005 Ozone Strategy C - 11 Final Adopted – January 4, 2006 

Costs of Control 

The South Coast estimates that the cost effectiveness for control of spray coating 

operations subject to the rule is about $5484 per ton of emission reduction. The 20 ton 

per year threshold may be adjusted to improve rule effectiveness and cost-effectiveness. 

The emissions from two of the facilities included, Rexam Beverage Can and American 

Brass and Iron, are from coating operations, but not from spray booths as specified in 

the South Coast rule. The emissions from Rexam Beverage Can are from tab lube 

applicators and the emissions from American Brass and Iron are from a dip tank. An 

examination of each of these facilities must be conducted to determine whether control 

would be cost effective for these operations. 

Other Impacts 

No significant adverse environmental impacts are expected as a result of the adoption of 

this control measure. The affected coating operations are part of existing industrial 

operations, so that an addition of emissions control equipment will not cause additional 

impacts. The proposed control option, however, will add emissions of NOx to the 

atmosphere if incineration is the preferred technology to comply with the proposal. 

References 

CST-10: Miscellaneous Industrial Coatings and Solvent Operations, South Coast 2003 

Air Quality Management Plan, SCAQMD 

Rule 1132: Further Control of VOC Emissions from High Emitting Spray Booth Facilities, 

and staff report, SCAQMD, 1/2001 

 
Bay Area 2005 Ozone Strategy C - 12 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 4: POLYESTER RESIN OPERATIONS 

Control Measure Description 

This control measure would reduce ROG emissions from polyester resin operations 

(fiberglass product manufacturing) by lowering some limits in Regulation 8, Rule 50: 

Polyester Resin Operations. 

Background and Regulatory History 

The Air District regulates ROG emissions from polyester resin operations by setting 

volatile organic compound (VOC) limits and monomer content limits. Monomers are 

relatively low molecular weight compounds that combine chemically to become a cured 

resin. Approximately 5% of resin monomers do not react, and are emitted. A reduction 

in allowable monomer content reduces ROG emissions. Also, for polyester resin sprayup applications, the rule requires the use of certain spray technologies that are relatively 

transfer efficient to minimize the amount of resin that misses or bounces off the intended 

surface. Regulation 8, Rule 50: Polyester Resin Operations, was adopted in 1990. Only 

minor amendments to the rule have been adopted since 1990. 

Emissions Subject to Control 

The emissions from polyester resin operations are included in the emission inventory as 

point sources. The emissions from this source category include organic emissions from 

mixing, pouring, impregnating, injecting, forming, spraying and curing with polyester 

resins. Any polyester resin operation is required to have an Air District operating permit, 

and must submit usage information annually. Emissions are calculated from the 

submitted information. Polyester resin operations are found in Category 45: Fiberglass 

Products Manufacturing in the emissions inventory. Clean-up solvent used in polyester 

resin operations is almost all acetone, a negligibly photochemically reactive solvent. 

 Emissions Subject to Control 

(TPD, Summer) 

Year Category 45 

2003 0.66 

2006 0.69 

Proposed Method of Control 

South Coast Rule 1162: Polyester Resin Operations, amended in November 2001, sets 

monomer content standards for polyester resins used in a variety of applications. 

Currently, the Bay Area rule allows a monomer content of 35%, or 50% for materials 

used for corrosion-resistant or fire-retardant service. The South Coast rule allows from 

10% to 35% for specified types of general purpose resins, 48% for resins used for 

corrosion-resistant service, 38% for fire-retardant service, and 40% for high strength 

service. The South Coast rule also sets monomer content standards for gel coats and 

requires the use of non-atomizing spray application equipment, which is stated to reduce 

emissions by 40%. 
Bay Area 2005 Ozone Strategy C - 13 Final Adopted – January 4, 2006 

Emission Reductions Expected 

The Bay Area emissions inventory shows that polyester resin (fiberglass) products 

manufacturing operations emit 0.66 tons organic compounds per day. The South Coast 

rule development staff report states that the amendments adopted in November 2001 

reduce emissions by 68%. In the Bay Area, this would achieve a reduction of 

approximately 0.45 tons organic compounds per day, although the previous South Coast 

rule had some provisions slightly more permissive than the existing Bay Area rule. At 

this time, the South Coast has delayed the non-atomizing spray provisions for gel coats 

from July 2003 until July 2005. 

Costs of Control 

The staff report for the 2001 amendments to South Coast Rule 1162 estimates the cost 

effectiveness of this measure at approximately $800 per ton ROG emissions reduced. 

Typically, improvements in transfer efficiency can save operators money because less 

material is used. 

Other Impacts 

No significant adverse environmental impacts are expected as a result of the adoption of 

this control measure. Styrene, a toxic air contaminant, is the predominant organic 

compound emitted from polyester resin operations. A reduction in ROG emissions 

would also reduce exposure to styrene. 

References 

South Coast AQMD Rule 1162: Polyester Resin Operations, and staff report, SCAQMD, 

November, 2001 

ARB-CAPCOA Suggested Control Measure For Polyester Resin Operations, CAPCOA 

Technical Review Group and CARB, September, 1990. 

 
Bay Area 2005 Ozone Strategy C - 14 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 5: WOOD PRODUCTS COATING 

Control Measure Description 

This control measure would reduce ROG emissions from wood coating facilities by 

lowering some VOC limits in Regulation 8, Rule 32: Wood Products Coating. 

Background and Regulatory History 

The Air District regulates ROG emissions from wood coating facilities by setting volatile 

organic compound (VOC) limits on various types of coatings used on wood, clear and 

pigmented topcoats, sanding sealers, penetrating sealers (wash coats), fillers and 

stains. Also, the rule requires the use of spray technology that is transfer efficient to 

minimize that the amount of paint that misses or bounces off the intended surface. 

Rule 32 regulates coatings used in the manufacturing of furniture, kitchen cabinets, 

outdoor speakers, picture frames, bathroom vanities and other wood products. Rule 32 

was adopted in 1983 and amended several times. The most significant amendments 

were in 1991 and 1995. The rule exempts certain types of products and operations for 

which low VOC technology is not appropriate, such as musical instruments, antique 

refinishing and foundry patterns. Emissions from wood product coating have been 

reduced by 50% through the implementation of VOC limits in the rule. A reduction in the 

number of facilities operating in the Bay Area has also reduced emissions from this 

source category. 

Emissions Subject to Control 

The emissions from wood coating operations are included in the emission inventory as 

point sources. Any coating operation that uses 30 gallons of coating and solvent per 

year is required to have an Air District operating permit, and must submit usage 

information annually from which emissions are calculated. Wood product coating 

emissions are found in Category 256 in the emissions inventory. Category 257 is 

surface preparation and clean up solvents used in wood finishing operations. 

 Emissions Subject to Control 

(TPD, Summer) 

Year Cat. 256 Cat. 257 

2003 2.74 0.44 

2006 2.78 0.46 

Proposed Method of Control 

Several other California districts have adopted VOC limits that are more stringent than 

the Bay Area’s. Generally, the difference between rules is marginal currently, but the 

other rules become more stringent in July, 2005. The following table illustrates the major 

differences in the rules in four districts, expressed in allowable VOC content in 

grams/liter. 
Bay Area 2005 Ozone Strategy C - 15 Final Adopted – January 4, 2006 

Coating 

Bay Area 

current 

South Coast(2)

effective 7/05 

Sacramento(2)

effective 7/05 

San Joaquin(2)

effective 7/05 

Clear topcoat 275/550(1) 275 275/550(3) 275 

Sanding sealer 550 275 275 275 

Color topcoat 275/550(1) 275 275 275 

High solid stain 700 350 350 240 

Low solid stain 480 120 120 120 

Filler 500 275 275 275 

Wash coat 480 120 120 120 

Notes: 

(1) The lower limits are for general wood products, the higher are for furniture. 

(2) Other coating limits apply. 

(3) The higher limit is for conversion varnish, a type of clear or colored topcoat. 

The current Bay Area limits in Rule 32 are higher than the future limits in the other rules, 

550 g/l for clear and colored topcoats and sealers, except for the Sacramento limit for 

conversion varnish, 700 g/l for high solids stains, and 480 g/l for low solids stains and 

washcoats. Based on the other districts adopted future limits, the following VOC limits 

are suggested for consideration, at a minimum: 

High solids stain 350 g/l 

Sealers 275 g/l 

Filler 275 g/l 

Low solids stains 120 g/l 

Wash coats 120 g/l 

Emission Reductions Expected 

A 1998 study conducted by UC Davis under ARB contract 93-343 found that high solids 

stains were 15% of the volume of coatings used, sealers were 23%, fillers were 3% and 

low solids stains and washcoats were 6%. The following table illustrates potential 

emission reductions from the above suggested limits, assuming that the volume 

percentage coating used is equivalent to a percentage of emissions and that there was 

no reduction in volumes used due to a higher solids content of lower VOC materials. 

Coating Current 

VOC (g/l) 

Suggested

VOC (g/l) 

Calculation Reduction 

tons/day 

High solid stain 700 350 2.74*0.15* (700–350)/700 0.21 t/dy 

Sealers 550 275 2.74*0.23* (550–275)/550 0.31 t/dy 

Fillers 500 275 2.74*0.03* (500-275/500 0.04 t/dy 

Low solid stain 480 120 2.74*0.06* (480-120)/480 0.12 t/dy 

Wash coat 480 120 Included with low solid stains 

Together, the potential emission reduction is 0.68 tons per day. This does not include 

potential reductions from clear topcoats, which represent 48% of the volume of coating 
Bay Area 2005 Ozone Strategy C - 16 Final Adopted – January 4, 2006 

used. Because of the potential based on volume, and the lower limits in other rules, 

lower VOC limits should be investigated. 

Costs of Control 

In the staff report for the proposed amendments to South Coast Rule 1136, the cost 

effectiveness was estimated to range from $1900 to $2900 per ton for waterborne 

systems, and for acetone reformulated coatings to be slightly less, about $1600 per ton. 

At an inflation rate of 3%, this equates to a range of $2406 per ton to $3674 for 

waterborne coatings and $2026 per ton for acetone coatings. This is within the range of 

cost effectiveness of other surface coating control measures. 

Other Impacts 

During the course of rule development in 1990 and 1995 for Bay Area Regulation 8, 

Rule 32: Wood Products Coating, it was found that the Bay Area is home to a unique set 

of custom furniture and millwork manufacturers and antique refinishers, for which 

coatings designed for large factory environment applications would not be able to be 

employed. Consequently, coating technology that meets the requirements of wood 

product manufacturers in other districts may not be applicable to the Bay Area. 

When the South Coast rule requirements came into effect, they found an increase in the 

use of an ozone depleting compound, 1,1,1 trichloroethane, of about 1 ton per day. 

Since that time, however, the Montreal Protocol and 1990 Clean Air Act amendments 

have phased out the production of this compound. 

Many California districts have VOC limits on strippers. Most commercial furniture 

refinishers use methylene chloride for wood stripping. Methylene chloride is a toxic 

compound and has been declared negligibly photochemically reactive by EPA. It is 

exempt from controls as a VOC in those rules outside of the Bay Area that have stripper 

limits. In Bay Area Rule 32, methylene chloride is a VOC. Conseqently, a reduction in 

the allowable VOC content for strippers in the Bay Area may be technically infeasible. 

Methylene chloride emissions from stripping operations, however, may be limited either 

through the existing Bay Area risk reduction program or through the development of a 

statewide Air Toxic Control Measure. 

Other than the minor impacts discussed above, no potential adverse environmental 

impacts are expected as a result of the adoption of this control measure. 

References 

Industrial Surface Coatings-Wood Furniture & Fixtures Emission Inventory Development, 

Robert P. Anex, et al, U.C. Davis Civil Engineering Department, June 1998, Air 

Resources Board Contract 93-343 

Staff report, Proposed Amendments to Rule 1136 - Wood Products Coating, South 

Coast AQMD, May 10, 1996 
Bay Area 2005 Ozone Strategy C - 17 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 6: FLARES 

Control Measure Description 

This control measure will reduce ROG emissions from flares in petroleum refineries and 

chemical plants. Regulation 12, Rule 12: Flares at Petroleum Refineries, was adopted 

by the Board of Directors on July 20, 2005. 

Background and Regulatory History 

Flares in refineries provide for the safe disposal of liquid and gaseous hydrocarbons that 

are either automatically vented from process units through pressure safety valves, 

control valves or manually drawn from units. Blowdown systems gather hydrocarbon 

flow, separate liquid from gases, recover condensable oil and water, and discharge the 

gases to be combusted at the flare. 

The 2001 Ozone Attainment Plan contained two measures related to flaring operations 

at petroleum refineries. Control measure SS-15 included a commitment to adopt a 

regulation requiring monitoring of flows to flares and calculation of emissions from flares. 

On May 21, 2003, the Bay Area adopted new Regulation 12, Rule 11: Flare Monitoring 

at Petroleum Refineries. Further study measure FS-8 in the 2001 Ozone Plan called for 

an assessment of the viability of controlling flare emissions at petroleum refineries. In 

December, 2002 a draft technical assessment document (TAD) was completed that 

recommended that routine flaring could be minimized by equipment control strategies or 

by pollution prevention strategies. 

Following completion of the TAD, between August, 2003 and February, 2005 the District 

convened a technical working group that met ten times and conducted two public 

workshops to develop a regulatory approach to reduce flaring emissions. This rule 

development process led to the Regulation 12, Rule 12 adopted by the Board on July 

20, 2005. 

Emissions Subject to Control 

Emissions from flares at petroleum refineries are reported in Category 15 in the 

emissions inventory, Flares and Blowdown Systems. The emissions inventory for this 

category is derived from the calculated emissions based on data analyzed during the 

development of the 2001 Ozone Plan and incorporated into the emissions inventory. 

The base year for these data is 1999. 

 Emissions Subject to Control 

(TPD, Summer) 

Year Cat. 15 Flares and Blowdown Systems 

2003 7.78 

2006* 0.68 

Current data based on the monitoring requirements of Reg. 12-11 shows that the volume 

of flare gas sent to flares has been reduced by over 50% from 2001 and 2002. This 
Bay Area 2005 Ozone Strategy C - 18 Final Adopted – January 4, 2006 

reduction can be attributed to two factors: 1) the installation at one refinery of new 

compressors with sufficient capacity to provide recovery of gases to be used as fuel gas 

at that refinery, and 2) greater attention to operating practices at refineries that have 

minimized the need for flaring. Also, improvements in flow monitors and better gas 

composition information are helping to replace engineering assumptions made for the 

2001 Ozone Plan with refined data and better emission estimates. Data collected since 

the monitoring requirements in Reg. 12-11 became effective in December, 2003 indicate 

that emissions from refinery flares in this time period have averaged about 0.68 tons 

reactive organic gases/day on average. 

Method of Control 

Flaring in refineries can be roughly categorized as being one of three types, routine 

flaring as part of petroleum product manufacturing, flaring during startups and 

shutdowns of process units, and flaring during process upsets and emergencies. The 

reductions already achieved in flaring are primarily the result of reduced routine flaring. 

Flares exist as emissions controls and safety devices that function during upsets, 

unanticipated breakdowns of pressurized equipment, or unforeseen events such as 

power outages. Either by carefully controlling processes, including startup and 

shutdown, or by equipment modifications, some flaring may be able to be eliminated. 

Regulation 12, Rule 12 will reduce emissions from flares at petroleum refineries by 

minimizing the frequency and magnitude of flaring. The proposal includes a standard 

that prohibits the use of a refinery flare unless the use is consistent with an approved 

flare minimization plan (“FMP” or “Plan”). The rule is structured to capture reductions 

realized by the refineries, and to require refiners to identify and implement feasible 

prevention measures to further minimize flaring. In addition to the requirement to 

develop and implement plans, the rule will: 1) require annual updates to the FMPs; 2) 

require timely notification to the District when flaring occurs; 3) require refineries to 

conduct a causal analysis when flaring occurs; and require monitoring and recording of 

the pressure and water levels in the flare water seals. The flare minimization plans will 

be made available to the public for review and comment. A plan will only be approved if 

the APCO determines that all feasible flaring prevention measures have been identified, 

considered, incorporated and scheduled for expeditious implementation. Flaring will 

only be allowed in accordance with an approved FMP or for emergencies where 

necessary to prevent accident, hazard or release of flare vent gas into the atmosphere, 

based on a causal analysis. Regulation 12, Rule 12 will result in a continuous 

improvement process in refineries to reduce flaring. 

Emission Reductions Expected 

Emissions from flares fluctuate on a daily, monthly and yearly basis. The emission 

inventory estimates developed for the 2001 Ozone Plan are not expected to be 

consistent with present or future estimates. Overall, emissions are expected to continue 

their downward trend. 

Costs of Control 

Equipment control strategy costs can vary greatly depending on the specifics of each 

refinery. Flare gas compressors cost between one and eight million dollars depending 

on the size of the compressor. Also, additional gas storage capacity or equipment to 
Bay Area 2005 Ozone Strategy C - 19 Final Adopted – January 4, 2006 

process the gas may need to be installed. Costs for operational controls or process 

changes that could minimize flaring may have economic benefits. The rule is structured 

to allow refiners to investigate and choose cost effective options for control. 

Other Impacts 

Flares act to burn gases released from process units to avoid fires or explosions. As 

long as safety considerations are not compromised, significant adverse environmental 

impacts are not expected as a result of adding equipment to process flare gas or making 

changes to minimize flaring. Large flaring events are of particular concern to 

communities around refineries. Implementation of this measure may reduce public 

exposure to emissions from these events. The affected flare systems are part of existing 

refinery operations, so that additional equipment added to these systems will not cause 

additional impacts. However, to the extent that additional control equipment is required, 

there may be an increase in incineration technology used to abate emissions. 

Incineration and flares both generate NOx emissions. 

* Because flare emissions are variable and not predictable based on anticipated refinery 

production or material throughputs, 2004 average emission data from the flare 

monitoring has been used for the 2006 emissions estimate. 

References 

Staff Report, Proposed Regulation 12: Miscellaneous Standards of Performance, Rule 

12: Flares at Petroleum Refineries, BAAQMD, July 8, 2005 

Technical Assessment Document, Further Study Measure 8, Flares, BAAQMD, Dec. 

2002 
Bay Area 2005 Ozone Strategy C - 20 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 7: GASOLINE BULK TERMINALS AND PLANTS 

Control Measure Description 

This control measure would reduce ROG emissions from gasoline bulk terminals and 

bulk plants by requiring backpressure monitors and alarms or controls to shut down 

loading when backpressure exceeds a set standard, setting more stringent liquid and 

vapor leak standards, increasing enforceability, and setting a more stringent emission 

standard. 

Background and Regulatory History 

The Air District regulates ROG emissions from gasoline terminals and bulk plants under 

Regulation 8, Rule 33, and Rule 39, respectively. Both rules also set standards for 

gasoline delivery vehicles. Gasoline terminals receive gasoline products by pipeline or 

barge and load it into trucks for delivery to gasoline dispensing facilities. Gasoline bulk 

plants receive gasoline products by truck and also load it into trucks for shipment to 

gasoline dispensing facilities. The principal difference is that bulk plants have the ability 

to balance or return gasoline vapors to the point of origin via truck, whereas gasoline 

bulk terminals must process them on site. 

Rule 33 for bulk terminals was adopted in 1983 and Rule 39 for bulk plants was adopted 

in 1987. Rule 33 sets an emission standard of 9.6 grams per cubic meter gasoline 

loaded (0.08 lb/1000 gal loaded). Rule 39 sets an emission standard of 60 grams per 

cubic meter gasoline loaded (0.5 lb/1000 gal loaded). Both rules also require equipment 

maintenance, set liquid leak standards and set standards for gasoline delivery vehicles 

consistent with the requirements of the California Health and Safety Code. Section 

41962 requires the ARB to set standards for gasoline delivery vehicles and pre-empts 

districts’ authority to set standards or to certify vehicles. 

Emissions Subject to Control 

Gasoline bulk terminals and plants are considered point sources and emissions are 

calculated for each facility. Category 64 is for gasoline truck loading at gasoline bulk 

plants. Category 898 is for gasoline loading at bulk terminals. The evaporative 

emissions from trucks during transport and from storage tanks at bulk plants and 

terminals are not part of this source category and are not part of this control measure. 

 Emissions Subject to Control 

Category, tons/day 

Year Category 64 Category 898 

2003 0.28 0.97 

2006 0.28 0.97 

Proposed Method of Control 

This control measure, which targets gasoline bulk plants and terminals subject to Bay 

Area Regulation 8, Rule 33: Gasoline Bulk Terminals and Gasoline Delivery Vehicles, 
Bay Area 2005 Ozone Strategy C - 21 Final Adopted – January 4, 2006 

and Regulation 8, Rule 39: Gasoline Bulk Plant and Gasoline Delivery Vehicles, has six 

specific elements: 

1) A requirement to install backpressure monitors on loading racks during gasoline 

cargo tank loading at terminals and automatic shutoffs or alarms if backpressure 

exceeds 18" H20 to prevent emissions releases from cargo tanks. 

2) A requirement for new vapor recovery piping from loading racks to the VRU to 

maintain pressure shutoff below 12" H20. 

3) More stringent leak standards for liquid leaks than the current 3 drops/minute and 

disconnect leaks than the current 10 ml per disconnect, averaged over 3 

disconnects. More stringent standards for vapor leaks than the current 100% 

LEL measured one inch from the leak source. 

4) Incorporation of California Air Resources Board standards for bulk plant 

certification to clarify responsibility for compliance with the standards. 

5) A prohibition on loading unless the cargo tank and terminal are compatible. 

6) A reduction in the allowable emission standard for bulk terminals. 

A requirement for alarms or automatic shutoffs at 12” backpressure at the loading racks 

would affect only new equipment installation. California standards and an incompatibility 

loading prohibition incorporate existing law to make the rules clearer and enforcement 

easier. Leak standards and disconnect standards would require increased maintenance 

and operator monitoring but would involve no new equipment installation. 

Emission Reductions Expected 

Emission estimates are derived from a reduction in the allowable emission rate from 

0.08 lbs organic emissions per 1000 gallons loaded to 0.04 lbs/1000 gallons loaded. 

This is a 50% reduction, or 0.48 tons/day, although existing control equipment at some 

bulk terminals may already comply with this standard. Further reductions from 

backpressure monitors on vapor piping and automatic shutoffs, and more stringent leak 

standards are expected, but cannot be quantified at this time. 

Costs of Control 

Installation of a pressure monitoring and either alarms or an automatic shutoff system at 

the bulk terminal loading racks would eliminate excess emissions during loading from 

over-pressurizing cargo tanks. Estimated costs for a pressure monitoring and automatic 

shutoff system are between $20,000 and $35,000 initial costs, with ongoing 

maintenance costs after installation. An alarm system would cost less. The cost will 

vary depending on the number of lanes at the terminal. There are 14 bulk terminals 

currently operating in the Bay Area. The cost effectiveness of this proposal will be 

determined, along with an estimate of the potential emissions reductions from prevention 

of backpressure popping the cargo tank’s P/V valves. Vapor processing equipment that 

meets current BACT standards is expected to comply with a more stringent emission 

limitation without additional equipment installation. 
Bay Area 2005 Ozone Strategy C - 22 Final Adopted – January 4, 2006 

Other Impacts 

Any new equipment would be installed within existing gasoline bulk terminals. No 

adverse environmental impacts are expected. 

References 

Ken Kunaniec, personal conversations, 3/24/03, 5/1/03, 6/16/03 

Bay Area Regulation 8, Rule 33: Gasoline Bulk Terminals and Gasoline Delivery 

Vehicles 

Memo, Ken Kunaniec, BAAQMD, 10/06/03 

Discussion, WSPA and bulk terminal operators, October 27, 2005 

 
Bay Area 2005 Ozone Strategy C - 23 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 8: MARINE LOADING OPERATIONS 

Control Measure Description 

This control measure will further reduce ROG emissions from marine loading operations 

by controlling currently unregulated cargoes, requiring more stringent emission 

limitations, and/or controlling housekeeping operations such as tank washing, tank 

venting or gas freeing aboard marine vessels that result in ROG emissions. On 

December 7, 2005, the Board of Directors adopted amendments to Regulation 8, Rule 

44 and deleted Regulation 8, Rule 46 because the standards in Rule 46 are now 

incorporated into Rule 44. 

Background and Regulatory History 

Regulation 8, Rule 44: Marine Vessel Loading Terminals and Regulation 8, Rule 46: 

Marine Tank Vessel to Marine Tank Vessel Loading were both adopted in 1989. Reg 8-

44 limits precursor organic emissions (ROG) that are emitted from the loading of 

specified organic liquids at marine terminals or emitted from the loading of tank vessels 

that previously contained these organic liquids. Reg. 8-44 affects mostly petroleum 

refineries, chemical plants, bulk terminal distribution facilities, and shipping companies. 

Prior to the December 7, 2005 consolidation of Reg. 8-46 requirements into Reg. 8-44, 

Reg. 8-46 applied to marine vessel to marine vessel loading operations, termed 

lightering. Reg. 8-44 (and until December 7, 2005, Reg. 8-46) requires control of 

specified organic liquids: gasoline, gasoline blending stocks, aviation gas, JP-4 aviation 

fuel, and crude oil. The existing emission standard in these rules for loading operations 

is 2 pounds of precursor organic compound emissions per thousand barrels of organic 

liquid loaded, or a 95% reduction in emissions. 

In the 2001 Ozone Attainment Plan for the San Francisco Bay Area, Further Study 

Measure 11 called for an assessment of the viability of further controls on marine vessel 

loading and marine tank vessel activities. A draft technical assessment document (TAD) 

was completed in December, 2002. The document recommended several changes to 

Bay Area Reg. 8-44 and 46 and concluded that there are viable strategies to further 

control emissions from these operations. In addition, the TAD recommended changes to 

the emissions inventory to better account for emissions from unregulated cargo. 

Following completion of the TAD, between June, 2002 and June, 2004 the District 

convened a technical work group that met six times and held three public workshops to 

discuss potential amendments to Reg. 8-44 and 8-46 to further reduce emissions from 

marine loading operations. This rule development process led to the amendments to 

Reg. 8-44 and 8-46 adopted by the Board on December 7, 2005. 

Emissions Subject to Control 

Emissions from marine vessels are divided into several categories in the emissions 

inventory. Categories 86 and 87 are ship and barge lightering, respectively. Categories 

88, 89, and 90 are the emissions from vessel ballasting, the loading of water into a tank 

that contains organic vapors from crude oil, gasoline and other organic liquids, 

respectively. Category 91 is for cleaning and gas freeing of vessels. Categories 795 

through 798 are the emissions at marine terminals at the refineries from the loading and 

unloading of crude oil and gasoline (including other products) in tankers and barges. 
Bay Area 2005 Ozone Strategy C - 24 Final Adopted – January 4, 2006 

Categories 799 through 802 are the emissions from the loading and unloading of crude 

oil and gasoline in tankers and barges at locations other than the petroleum refineries. 

 ROG Emissions Subject to Control (TPD, Summer) 

Categories 

Year 86, 87 88, 89, 90 91 795, 796, 797, 798 799, 800, 801, 802 

2003 0.07 1.40 0.56 0.25 0.36 

2006 0.07 1.52 0.60 0.25 0.39 

The reactive organic (ROG) emissions from these activities total 2.64 tons per day in 

2003 and 2.83 tons per day in 2006. 

The technical assessment document prepared in December, 2002 includes the results of 

source tests conducted on unregulated cargo. The results of these tests are not yet 

incorporated into the inventory data shown above. 

Method of Control 

The amendments to Regulation 8, Rule 44 continue to require controls for the five liquid 

categories listed in the current rules (gasoline, gasoline blending stock, aviation gas, JP4 jet fuel, and crude oil) and add requirements to control other liquids with a flash point 

below 100  ̊F. This requirement applies to a group of volatile organic chemicals that are 

not listed in the current rule and are handled in relatively small quantities in the Bay 

Area. These cargoes produce relatively high emissions during loading or transfer. 

Emission reductions from controlling these cargoes would be cost effective because 

significant emission reductions can be achieved by controlling a relatively small volume 

of cargoes. 

The amendments also clarify application of more stringent leak standards for the 

equipment that controls emissions; clarify and extend requirements for various activities 

such as ballasting, tank washing, purging, and gas freeing that can vent tank emissions 

to the atmosphere; and consolidate requirements in Regulation 8, Rule 46, concerning 

marine vessel to marine vessel tank loading, into Rule 44. On December 7, 2005, the 

Board conducted a public hearing and adopted the proposed amendments. 

Emission Reductions Expected 

It is estimated that ROG reductions of about 0.44 tons per day will be achieved from 

control of additional cargo and/or control to a more stringent level. In addition, 

unregulated venting emissions are estimated to be able to be reduced by 0.5 tons per 

day or more. However, due to Coast Guard directives, regulated venting activities may 

now be occurring largely outside of Bay waters. To the extent that this is the case, some 

venting emissions have already been reduced. 

Costs of Control 

The staff report for the December 2005 amendments to Reg. 8-44 and 8-46 estimated 

costs of control for these additional emissions reductions. Estimates of the cost to 
Bay Area 2005 Ozone Strategy C - 25 Final Adopted – January 4, 2006 

control unregulated cargo are from $9000 to $15,000 per load. 8,500,000 barrels loaded 

yearly of currently unregulated cargo would cost about $448,000 yearly. Given the 

emission reduction estimates of 0.44 tons per year, the cost effectiveness for the control 

of currently unregulated cargo is approximately $2800 per ton of ROG reduced. 

Control of housekeeping emissions is expected to be cost effective, because tank 

cleaning done under vapor recovery may speed up the process, resulting in fewer 

demurrage fees for shipping operators. A demurrage fee is a charge for detaining a ship 

beyond that necessary for loading or unloading cargo. As previously mentioned, the 

emissions may have largely already been transferred outside the Bay, so clarification of 

the standards does not have associated costs. 

Other Impacts 

Marine loading operations are part of existing industrial complexes, both part of and 

apart from refinery operations. The addition of control equipment and associated piping 

and hardware is not expected to result in adverse environmental impacts. However, to 

the extent that additional control equipment is required, there may be an increase in 

incineration technology used to abate emissions. Incineration generates NOx 

emissions. 

References 

Final Staff Report, Proposed Amendments to Regulation 8, Rule 44: Marine Vessel 

Loading Operations, Proposed Amendments to Regulation 8, Rule 46: Marine Tank 

Vessel to Marine Tank Vessel Loading, and Proposed Amendments to the Manual of 

Procedures, Volume IV, ST-34: Bulk and Marine Loading Terminals, Vapor Recovery 

Units, BAAQMD, November, 2005 

Technical Assessment Document, Further Study Measure 11, Regulation 8, Rules 44 

and 46, Marine Loading Operations, BAAQMD, Dec. 2002 

Draft Staff Report, Proposed Revision and Consolidation of Regulation 8, Rule 44 and 

Rule 46: Marine Loading Operations, BAAQMD, Oct. 2003 
Bay Area 2005 Ozone Strategy C - 26 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 9: ORGANIC LIQUID STORAGE TANKS 

Control Measure Description 

This control measure would reduce ROG emissions from organic liquid storage tanks by 

supplementing existing requirements in Regulation 8, Rule 5: Storage of Organic 

Liquids. 

Background and Regulatory History 

Regulation 8, Rule 5: Storage of Organic Liquids, was adopted in 1978. The rule 

mandates equipment standards for large organic liquid storage tanks. The rule applies 

to tanks storing liquids with a vapor pressure of at least 0.5 psia. Larger tanks and tanks 

storing highly volatile liquids are required to meet more stringent standards. This control 

measure applies primarily to large, floating roof tanks that are typically found at 

petroleum refineries and chemical plants, and gasoline bulk plants and terminals. 

Amendments were made to strengthen Reg. 8-5 in 1985 and 1988. In 1993, 

amendments were made to the rule to satisfy EPA policy requirements. In 1999 and 

2002, amendments were made based on Clean Air Plan measures to further reduce 

emissions. 

The 2001 Ozone Attainment Plan included two commitments regarding organic liquid 

storage tanks. Control Measure SS-12 focused on inspection requirements and was 

implemented through an amendment to Regulation 8, Rule 5 in November 2002. 

Further Study Measure FS-10 focuses on enhanced control requirements for tanks. A 

draft technical assessment document (TAD) regarding FS-10 was released in January 

2004. The TAD investigated the feasibility of requiring controls on lower vapor pressure 

liquids than Reg. 8-5 currently requires, retrofitting external floating roof tanks with 

domes to reduce evaporation from air movement across the tank, imposing more 

stringent tank cleaning standards, requiring external floating roof tanks to be retrofitted 

with vapor recovery, a provision to allow minor maintenance and encourage more 

frequent self-inspections, and phasing out riveted tanks currently in service. 

Following the 2004 TAD, staff convened technical workgroup meetings in February, 

2004 and May, 2005 and conducted tank inspections to better understand issues 

associated with storage tanks in May, 2004 and again in April, 2005. 

Emissions Subject to Control 

Emissions from storage tanks are included in the emissions inventory in Petroleum 

Refinery Evaporation, Storage Tanks. Categories 55, 56, 57, and 58 address cone roof 

tanks, external floating roof tanks, internal floating roof tanks, and other tanks, 

respectively. Category 940 addresses tank cleaning in petroleum refineries. Fuels 

Distribution contains the emission inventory categories for gasoline tanks in bulk 

terminals and bulk plants (Categories 62 and 63). Other organic liquid storage tanks are 

found in Categories 84 and 85, which address cone roof tanks and other types of tanks, 

respectively, in both point and area sources. This control measure focuses on point 

(permitted) sources. 

Emissions are derived from AP-42 correlation equations. The technical assessment 

document recommends that several elements in the calculations change, because the 
Bay Area 2005 Ozone Strategy C - 27 Final Adopted – January 4, 2006 

equations currently in use do not account for evaporative losses through deck fittings 

and do not account for “zero-gap” seals that are required on many tanks. Potential 

changes to the calculations are the subject of ongoing discussions with refinery 

representatives. 

Emissions Subject to Control (TPD, Summer) 

Categories 

55 56 57 58 940 62 - 63 84 85 

2003 2.10 1.31 .08 .05 .05 .56 .78 .15 

2006 2.19 1.36 .08 .05 .05 .56 .82 .15 

The ROG emissions subject to control total 5.08 tons per day in 2003 and 5.26 tons per 

day in 2006. 

Proposed Method of Control 

The draft TAD has several recommendations to reduce emissions from organic liquid 

storage tanks: 1) a requirement for domes to reduce wind speed over floating roof tanks 

that store liquids with at least 3.0 psia vapor pressure, 2) improved standards for 

degassing and cleaning tanks and for storing and transporting removed sludges, and 3) 

implementation of an inspection and maintenance program that provides an incentive for 

more frequent tank inspections. Since the TAD was released, staff has received more 

information on tank seal criteria on external floating roof tanks in refineries. A more 

detailed review of the emissions and cost effectiveness of these tanks indicates that the 

proposal to require domes on external floating roof tanks does not appear to be cost 

effective. 

The TAD did not recommend that three items be pursued as controls: 1) lowering the 

applicability of the rule to lower vapor pressure material, 2) requiring external floating 

roof tanks to be retrofitted to internal floating roofs or fixed roofs with vapor recovery, 

and 3) phasing out of riveted tanks. 

Emission Reductions Expected 

The overall emission inventory for tank cleaning is very small, although as tanks are 

cleaned infrequently, the emissions may be significant on days when tank cleaning 

occurs. Further work will quantify potential emission reductions from sludge handling. 

Also, emissions reductions for an inspection and maintenance program have not been 

determined. 

Costs of Control 

Cost effectiveness for the proposed amendments will be determined. Costs are 

expected to be reasonable. Standards for controlling degassing of tanks and handling 

sludges are already in effect in other air districts. Implementing an inspection and 

maintenance program is expected to be a cost benefit because such a program will 

enable tank owners to avoid District enforcement action while reducing emissions. 
Bay Area 2005 Ozone Strategy C - 28 Final Adopted – January 4, 2006 

Other Impacts 

Refinery and non-refinery tanks exist in industrial areas. Additional requirements related 

to tank cleaning or maintenance programs are not expected to have any adverse 

environmental impacts. No significant adverse environmental impacts are expected as a 

result of the adoption of this control measure. 

References 

Proposed Rule 1178: Further Reductions of VOC Emissions From Storage Tanks At 

Petroleum Facilities, Staff Report, South Coast AQMD, December 11, 2001 

Technical Assessment Document, Further Study Measure 10, Organic Liquid Storage 

Tanks, BAAQMD, January, 2004 

Conversation, Julian Elliot, February 26, 2004 

e-mail and data submission, Ferry, Rob, The TGB Partnership, October 22, 2004 

Conference call, WSPA and Rob Ferry, The TGB Partnership, November 15, 2004 
Bay Area 2005 Ozone Strategy C - 29 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 10: PRESSURE RELIEF DEVICES AND BLOWDOWN 

SYSTEMS 

Control Measure Description 

This control measure will further reduce ROG emissions from pressure relief devices in 

petroleum refineries and chemical plants through improved inspection, monitoring and 

recordkeeping. On December 21, 2005, the Board of Directors adopted amendments to 

Regulation 8, Rule 28 regarding pressure relief devices, and adopted the staff 

recommendation not to proceed with further regulatory amendments to address 

atmospheric blowdown systems at this time. 

Background and Regulatory History 

Pressure relief valves (PRVs) or pressure relief devices (PRDs) are safety devices 

installed in refinery and chemical plant process units on pressure vessels and tanks. 

They function to release overpressures that could threaten the integrity of the process 

vessel or tank. These devices are typically vented either directly to atmosphere through 

a PRV or PRD, or to atmosphere through a blowdown system. Some blowdown 

systems at one Bay Area refinery vent to atmosphere with limited controls; most are 

vented to a flare. 

Episodic releases of ROG emissions from pressure relief devices are regulated in 

Regulation 8, Rule 28: Pressure Relief Devices at Petroleum Refineries and Chemical 

Plants. Reg. 8-28 was first adopted in 1980 and significantly amended on December 17, 

1997. The amendments require refineries to conduct PRD monitoring, reporting, and 

release prevention planning. Prevention planning is designed to prevent releases from 

occurring and may include such measures as: flow, temperature, level and pressure 

indicators with interlocks, deadman switches, monitors, or actuators; routine inspection 

and maintenance programs; design changes; or deluge systems. The rule also requires 

controls for new PRDs and for PRDs that have repeat releases. In the 2001 Ozone 

Attainment Plan for the San Francisco Bay Area, Further Study Measure 8 called for an 

assessment of the viability of further controls on PRDs and blowdown systems in. A 

draft technical assessment document was completed in December, 2002. The 

document recommends several changes to Bay Area Regulation 8, Rule 28 and 

identifies two strategies to further control emissions from these devices. 

Blowdown systems that vent to atmosphere are only found in one Bay Area refinery. 

These blowdown systems are not able to be easily or cost-effectively controlled directly, 

however, due to the variable flow to and from them. Many of the inputs are controlled by 

pressure relief valves; these are subject to the provisions of Reg. 8-28. Many of the 

other inputs are excess steam or water. The emissions from blowdown systems that are 

not episodic, those from other than pressure relief valves, are periodic. Periodic 

emissions occur from cleaning, maintenance, and start-up and shutdown activities. 

They occur from the blowdown systems because organic liquids and vapors flow into the 

blowdown systems through manually operated valves. These emissions are subject to 

various other District rules, such as Regulation 8 rules controlling miscellaneous 

operations, vessel depressurization or fugitive emissions. 

District staff convened technical workgroup meetings in May, 2005 and again in October, 

2005 to discuss issues related to PRDs. Staff also met separately with affected and 
Bay Area 2005 Ozone Strategy C - 30 Final Adopted – January 4, 2006 

interested parties in October and November, 2005. Blowdown systems were addressed 

at a separate workgroup meeting in October, 2005. In addition, staff conducted a public 

workshop to discuss proposed amendments to Reg. 8-28 on September 14, 2005 and a 

public workshop to discuss the staff report for blowdown systems on October 27, 2005. 

Emissions Subject to Control 

Emissions from pressure relief devices are reported in Category 19 in the emissions 

inventory, Pressure Relief Valves. Emissions from blowdown systems are reported in 

Category 14, Flares and Blowdown Systems. Emissions from the inventory for Category 

19 are shown here. The emissions inventory for these categories is derived from the 

annual updates submitted by the affected industries. The emission inventory for 

pressure relief devices since 1980 shows significant differences year to year, because of 

the episodic nature of the releases. For example, 2000 data shows ROG emissions of 

0.6 tons per day. 2002 data, the most recent year for which plant submissions are 

available, shows ROG emissions of 0.18 tons per day. 2003 and future year emissions 

are calculated from 2002 data. 

 

 Emissions Subject to Control 

(TPD, Summer) 

Year Cat. 19 Pressure Relief Valves 

2003 0.19 

2006 0.19 

Regulation 8, Rule 28 also requires that emissions be calculated for releases and be 

submitted to the Air District. The highest calculated emission release from a single 

event since the 1997 amendments was 40,000 pounds (20 tons) organic compounds. 

This occurred during one day. The lowest calculated emission from a release event in 

the study was 6 pounds and the median calculated emission was between 3600 and 

3700 pounds. The annual average emissions for the time period since the 1998 

amendments is about 20.5 tons/year. The annual average emissions for the last five 

years, since the prevention measures requirements in Rule 28 took effect, is about 12.4 

tons/year. 

Proposed Method of Control 

Based on the findings in the TAD, input from workgroup and workshop participants, and 

extensive staff analysis, staff proposed certain amendments to Reg. 8-28. The 

proposed amendments to Regulation 8, Rule 28 will: 

1. Require facilities to ensure that they have the capability to detect and quantify all 

release events, including small releases of 10 pounds (the reporting threshold), 

and require facilities to demonstrate this capability to the District; 

2. Require data recordings of emissions releases, inspections of pressure relief 

devices, and monitoring associated with pressure relief devices; and 

3. Require facilities to report to the District a description of petroleum refinery 

process units. 
Bay Area 2005 Ozone Strategy C - 31 Final Adopted – January 4, 2006 

Staff examined whether all PRDs should be required to be vented to control systems as 

a safety measure to reduce the chance of accidental releases of acutely hazardous 

materials. Although not justified as an ozone control measure, staff nevertheless 

investigated this option because of a strong concern for worker and community safety. 

A comprehensive overlapping web of industrial safety laws and regulations already 

exists, which requires operators to “design and maintain a safe facility taking such steps 

as are necessary to prevent releases,” in the language of the federal Clean Air Act. 

Additional District regulation in the area of process safety would be duplicative of 

existing regulations and would not be well directed towards reducing community and 

worker risks. This conclusion reaffirms the determination of the Board of Directors’ Ad 

Hoc Committee on Accidental Emissions in connection with the adoption of the 1997 

amendments, that additional District requirements aimed at process safety would not be 

appropriate in Regulation 8, Rule 28. 

Staff did not recommend additional regulatory control of atmospheric blowdown systems 

at this time because the existing District regulatory structure is sufficient to minimize 

emissions from these systems. On December 21, 2005, a public hearing was held on 

proposed amendments to Regulation 8, Rule 28 regarding pressure relief devices, and 

on the staff recommendation not to require further control on blowdown systems. At the 

hearing, the Board adopted amendments to Regulation 8, Rule 28 and adopted the staff 

recommendation not to proceed with rule-making on atmospheric blowdown systems at 

that time. 

Emission Reductions Expected 

Based on estimates by EPA and others, increased monitoring requirements can be 

expected to reduce emissions by about 20%. However, because Reg. 8-28 already 

requires monitoring and prevention measures, staff believes that emissions reductions 

would be only 5%. This would result in ROG emissions reductions of 0.62 tons per year 

(0.0017 tons per day). These potential emission reductions do not account for any 

emissions inventory adjustments based on data reported pursuant to the requirements of 

Reg. 8-28. The emissions reductions would be from preventing releases due to 

increased monitoring requirements. 

The emissions on an annualized basis (tons per day annualized) are not sufficient to 

suggest development of a control measure. However, this control measure is 

recommended for inclusion in the Ozone Strategy because of the potential to reduce a 

large amount of organic emissions during release events curtailed because of increased 

monitoring. Since July, 1998 (the effective date of the Reg. 8-28 requirements) there 

have been 18 releases of between 0.5 tons and 5 tons ROG, and 9 between 5 and 50 

tons ROG. 

Costs of Control 

The costs of implementing enhanced monitoring procedures are expected to be cost 

effective. It is estimated that the proposed amendments are expected to cost about 

$65,000 District-wide. These costs are considered to be reasonable. Costs of venting 

all PRD’s to vapor recovery or disposal systems is expected to cost from about $50,000 

to $1.5 million/ton annualized over 20 years depending on whether additional flares 

were required. 
Bay Area 2005 Ozone Strategy C - 32 Final Adopted – January 4, 2006 

Other Impacts 

The rule development effort regarding pressure relief devices recognized that the 

purpose of these devices is safety. PRVs and PRDs prevent over-pressurization of 

vessels to avoid fires or explosions. As long as safety considerations are not 

compromised, significant adverse environmental impacts are not expected as a result of 

either adding to the existing rule or requiring more control of emissions from these 

devices. When these devices release, there is the potential for a large amount of toxic 

compounds to be released in fairly close proximity to communities. Consequently, there 

may be a large reduction in potential acute exposure to those compounds from 

implementation of this control measure. To the extent that additional control equipment 

is required, there may be an increase in incineration technology used to abate 

emissions. Incineration generates NOx emissions. Except as noted above, no 

significant adverse environmental impacts are expected as a result of the adoption of 

this control measure. 

References 

Staff Report, Proposed Amendments to Regulation 8, Rule 28: Episodic Releases from 

Pressure Relief Devices at Petroleum Refineries and Chemical Plants, BAAQMD, 

November, 2005 

Technical Assessment Document, Further Study Measure 8, Pressure Relief Devices, 

BAAQMD, Dec. 2002 
Bay Area 2005 Ozone Strategy C - 33 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 11: WASTEWATER SYSTEMS 

Control Measure Description 

This control measure will reduce ROG emissions from refinery wastewater systems by 

requiring control, covers or water traps at various emission points such as open drains, 

sumps, junction boxes and manholes. Amendments to Regulation 8, Rule 8 to reduce 

emissions from wastewater collection systems were adopted by the BAAQMD Board of 

Directors on September 15, 2004. Further study of controls on refinery wastewater 

treatment systems was evaluated by staff and presented to the BAAQMD Board of 

Directors on November 14, 2005, upon which the Board concluded that no further 

amendments to Reg. 8-8 were warranted at that time. 

Background and Regulatory History 

The Air District regulates ROG emissions from refinery wastewater systems through 

Regulation 8, Rule 8 by setting equipment standards which require minimum gaps in 

seals around around oil-water separators, gauging and sampling wells, dissolved air 

flotation units, slop oil vessels, separator effluent channels and junction boxes. A 1000 

ppm concentration limit for large oil-water separators is a regulatory option. Sludge dewatering units are required to have vapor recovery with a 95% destruction efficiency 

standard. The rule also allows vapor recovery as an option for oil-water separators, slop 

oil vessels and dissolved air flotation units. Regulation 8, Rule 8 was first adopted in 

1979, significantly amended in 1989 and amended to address EPA policy issues in 1993 

and 1994. In addition, Regulation 8, Rule 8 was amended in September, 2004. The 

amendments, developed as a result of Further Study Measure FS-9 in the 2001 Ozone 

Attainment Plan, imposed controls on the wastewater collection portion of the system. 

Subsequent to the 2004 amendments, staff convened a technical workgroup to focus on 

wastewater treatment systems. The workgroup met in April, June, September and 

October of 2005 to develop testing and sampling methodology, review results of the 

emissions evaluation, and discuss potential controls for the refinery wastewater 

treatment sources. The resultant report was discussed at a public workshop on 

September 27, 2005. 

Emissions Subject to Control 

In December, 2002, the staff of the California Air Resources Board and Air District 

produced a technical assessment document (TAD) that characterized the emissions 

from refinery wastewater systems. Emissions as shown in the Air District’s emission 

inventory are reported as point sources. Categories exist for refinery oil-water 

separators (Category 11), which includes fugitive emissions from process drains, and 

refinery wastewater treatment (Category 12), which includes the biological and/or 

chemical treatment, settling and clarification that occurs after the oil-water separator to 

meet water discharge standards. The emissions inventory is shown below 
Bay Area 2005 Ozone Strategy C - 34 Final Adopted – January 4, 2006 

 Emissions Subject to Control 

(TPD, Summer) 

Year Cat. 11 separators Cat. 12 treatment 

2003 3.63 0.13 

2006 3.80 0.14 

Category 11 consists of oil-water separators and process drains, as well as some other 

sources such as dissolved air flotation units. Process drains constitute most of the 

emissions, 2.43 tons/day in 2003 and 2.55 tons in 2006. The TAD estimated emissions 

by a combination of wastewater sampling to determine organic content, and industry and 

EPA emissions models to calculate emissions from refinery wastewater drains, junction 

boxes and manholes. These models estimate emissions to be at least 3.31 tons/day 

from the combination of these emission points. 

In 2005, an assessment was made of emissions from the uncontrolled treatment units 

located at the five refineries. A total of 0.24 tons per day (tpd) of VOC emissions was 

estimated. Of that total, the dissolved air flotation unit vents and channel/weir at 

ConocoPhillips emit approximately 0.11 tpd. At the remaining four refineries, the 

biological treatment units cause most VOC emissions because of turbulent conditions in 

the units. 

Method of Control 

A variety of methods can provide controls for open process drains, junction boxes and 

manholes, such as installation of vapor recovery on emission points accompanied by a 

control device, seals or traps on drains and open points in junction boxes and manhole 

covers, and the installation of solid piping where openings to the atmosphere exist. The 

most cost effective option is to require the installation of water seals on these emission 

points and to promulgate an emission standard to verify their effectiveness along with a 

program to assure that the water seals are maintained. The 2004 amendments do this, 

or allow the option of upstream source control to reduce organic laden wastewater into 

the drains. This option requires periodic monitoring and controls if the source control 

fails to reduce emissions to the 500 ppm level, equivalent to a concentration limit from 

controlled drains. 

In 2005, staff examined the potential to control emissions from the wastewater treatment 

operations. The District selected for evaluation several control technologies known to 

reduce VOC emissions from refinery wastewater streams. Staff considered installation 

of steam strippers and liquid phase carbon adsorption units to reduce the VOC content 

in the wastewater stream prior to its entry to secondary treatment and installation of 

aluminum domes over biological treatment tanks to reduce the wastewater stream’s 

exposure to the atmosphere. District staff investigated the technical feasibility of 

installing these technologies at the specific refineries, the potential emission reductions 

to be achieved from these technologies, and the costs to install, operate and maintain 

them. 
Bay Area 2005 Ozone Strategy C - 35 Final Adopted – January 4, 2006 

Emission Reductions Expected 

Based on established emission reduction factors for water seals, emissions from drains, 

junction boxes and manholes could be reduced by 65%. The 2004 amendments to Reg. 

8-8 reduced emissions by 2.1 tons per day. 

Staff found that the control technologies available for wastewater treatment systems 

could also reduce emissions by about 65%. The technologies examined would reduce 

emissions by about 0.14 tons per day. 

Costs of Control 

Staff estimated costs for controls on collection system components for the 2004 

amendments. The cost effectiveness for the drains, junction boxes and manholes 

ranged from $1100 to $8800 per ton reduced, depending on the component. Overall, 

cost effectiveness ranged from $1900 to $4200 per ton emissions reduced. 

Costs are significantly greater for control of wastewater treatment systems. Assuming a 

VOC emissions reduction of 0.14 tons per day, cost-effectiveness based on the 

installation of either a steam stripper or liquid phase carbon adsorption unit was 

estimated from $1.42 million to $1.35 million per ton of VOCs removed, respectively. For 

the doming option, only ConocoPhillips and Valero refineries have their treatment 

systems in tanks that are suitable for doming. The other refineries have aeration lagoons 

and ponds that cannot accommodate a dome. The estimated cost-effectiveness to 

reduce emissions by doming the tanks is $25,000 per ton of VOCs reduced based on a 

total reduction of 0.025 tons per day, not including the costs of vapor control and 

construction of additional infrastructure to support the domes. Consequently, staff 

recommended that no further controls be required for the wastewater treatment systems. 

On November 16, 2005, the Board of Directors conducted a public hearing and 

approved the staff recommendation. 

Other Impacts 

No significant adverse environmental impacts are expected as a result of the adoption of 

this control measure. The affected wastewater systems are part of existing refinery 

operations, so that additional equipment added to these systems will not cause 

additional impacts. The proposed control option will not add to other atmospheric 

pollutants because additional incineration or adsorption of hydrocarbon vapors is not 

anticipated. In addition, the existing water treatment systems are designed to handle 

much greater influent than exists in normal flows. Consequently, additional 

hydrocarbons going into the treatment system will not result in exceedances of the 

refineries water discharge permits. 

References 

Staff Report, Proposed Amendments to Regulation 8, Rule 8: Wastewater (Oil – Water) 

Separators, BAAQMD, September, 2004 

Staff Report, Further Study Measure 9: Refinery Wastewater Treatment Systems, 

BAAQMD, November, 2005 
Bay Area 2005 Ozone Strategy C - 36 Final Adopted – January 4, 2006 

Draft Technical Assessment Document: Potential Control Strategies to Reduce Emisions 

from Refinery Wastewater Collection and Treatment Systems, CARB, and BAAQMD, 

Jan. 2003 

SJVUAPCD Rule 4625: Wastewater Separators 

South Coast AQMD Rule 1176: VOC Emissions from Wastewater Systems 
Bay Area 2005 Ozone Strategy C - 37 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 12: INDUSTRIAL, INSTITUTIONAL AND COMMERCIAL 

BOILERS 

Control Measure Description 

This control measure would reduce emissions of nitrogen oxides (NOx) from boilers by 

extending controls to boilers smaller than those currently regulated by Bay Area 

Regulation 9, Rule 7 and evaluating lower NOx limits consistent with those adopted by 

the San Joaquin Valley Unified APCD. 

Background and Regulatory History 

The Air District regulates NOx emissions from boilers under three separate rules, all of 

which were adopted pursuant to California Air Resources Board (CARB) pollution 

transport regulations (California Code of Regulations beginning at section 70600). Each 

BAAQMD boiler rule regulates a different category of boilers. BAAQMD Regulation 9, 

Rule 7 imposes a 30 ppm NOx limit on industrial, institutional, and commercial boilers 

with a rated heat input of 10 million BTU/hr or more. Regulation 9, Rule 10 imposes a 

slightly more stringent NOx limit equivalent to 28 ppm on refinery boilers with a rated 

heat input of 10 million BTU/hr or more. Regulation 9, Rule 11 applies to extremely 

large boilers used to generate electricity and imposes a NOx limit equivalent to 15 ppm 

on boilers with a rated heat input of 250 million BTU/hr or more. 

This control measure applies to boilers currently subject to Air District Reg 9-7: Nitrogen 

Oxides and Carbon Monoxide From Industrial, Institutional, and Commercial Boilers, 

Steam Generators, and Process Heaters and those exempt by rated heat input. 

Smaller boilers exempt from Reg 9-7, with a rated heat of 10 million BTU/hr or less, are 

generally sold as “package boilers” that are equipped and shipped complete with 

burners, automatic controls and accessories, and mechanical draft equipment. They are 

generally used in high-rise office buildings, large hotels, and some industrial facilities to 

supply heat, steam, or hot water. A small number of boiler manufacturers – Ajax, Bryan, 

Cleaver-Brooks, Kewanee, Teledyne Laars, Parker, Peerless, Rite, and Thermo Pak – 

manufactured most of the boilers of this size installed in San Francisco. 

Emissions Subject to Control 

Boiler emissions are included in the BAAQMD inventory in several different categories. 

Emissions from boilers at power plants are found in the category called fuels combustion 

– power plants. Emissions from boilers at refineries are found in the category called 

fuels combustion – oil refineries external combustion. 

The emissions from other boilers, including smaller boilers not already subject to the 

existing BAAQMD rules, are included in the emission inventory source category called 

fuels combustion – other external combustion. This category includes external 

combustion sources such as boilers, furnaces, space heaters, and ovens. Boilers 

subject to Regulation 9, Rule 7 (those fired on natural gas or LPG of at least 10 MM 

BTU/hr and those fired on other fuels of at least 1 MM BTU/hr) have air quality permits, 

and emissions from these boilers are included in the point source portion of this 

category. Most emissions from the smaller boilers are included in the area source 

portion of this inventory category (the exception would be small boilers located at 

facilities required to have a permit for other reasons). These area source emissions are 
Bay Area 2005 Ozone Strategy C - 38 Final Adopted – January 4, 2006 

estimated by subtracting fuel usage by the point sources from total fuel usage as 

obtained from fuel consumption data. Emissions from both area and point sources are 

estimated to be 9.05 tons of NOx per day for 2003. 

To determine more precisely the emissions within the other external combustion 

inventory category that are attributable to Bay Area boilers in the 5 to 10 million BTU/hr 

size range, data from a boiler database developed by the San Francisco Department of 

Building Inspection (DBI) was used. Although San Francisco's population represents 

about one-tenth of the Bay Area total population, it represents about one-fourth of the 

population in heavily urbanized areas. This is important because boilers are not 

generally found in suburban areas except at laundries, some light industrial locations, 

and some schools. The San Francisco boiler population was therefore multiplied by 5 

and rounded to arrive at boiler population estimates for the entire Bay Area. 

Based on the DBI database, there are an estimated 420 boilers with a capacity greater 

than 5 million BTU/hr and less than or equal to 10 million BTU/hr in the Bay Area. Total 

estimated NOx emissions from these boilers are set forth below. Future-year emissions 

in this small boiler sub-category have been derived using the same growth factors used 

in the broader fuels combustion – other external combustion inventory category. 

Emissions from boilers smaller than 5 million BTU/hr are calculated from the area source 

portion of the inventory minus the 1.9 tons/day (2003) for 5-10 million BTU/hr boilers. 

 Emissions Subject to Control, TPD, Summer

Year <5 MM BTU/hr 5–10 MM BTU/hr >10 MM BTU/hr

2003 3.07 1.90 4.08 

2006 3.22 1.99 4.08 

Note that these emission estimates are likely to change during rule development as 

better population and emissions information becomes available. For example, Bay Area 

boiler service companies have indicated that estimates based on the DBI database may 

significantly understate the numbers of boilers for this particular size range. 

Proposed Method of Control 

This measure would consider the limits adopted by the San Joaquin Valley Unified 

APCD in Rule 4306 to boilers already controlled by District Reg 9-7, extend these limits 

to smaller boilers in the 5 to 10 million BTU/hr range, and consider regulation of boilers 

in the 2 to 5 million BTU/hr range. Control would generally be achieved by installation of 

low-NOx burners. On smaller boilers, it may only be cost effective to implement controls 

on new boilers. Low-NOx burners are available on new boilers manufactured by most of 

the major boiler manufacturers. Low-NOx burners are available as retrofits for some 

models, and virtually all of these retrofits are claimed to achieve NOx levels of 30 ppm or 

less. For some models, however, low-NOx retrofits may be unavailable. 

Emission Reductions Expected 

Most of the reduction (11 tons/day of a total of 12.7 tons/day) attributable to Rule 4306 

comes from large numbers of process heaters at crude oil production facilities and 

boilers at food processing facilities through retrofits with ultra low-NOx burners. This 
Bay Area 2005 Ozone Strategy C - 39 Final Adopted – January 4, 2006 

indicates that the reduction in point source emissions (those boilers already subject to 

Reg 9-7) may be modest. 

The estimated NOx emission reduction that could be achieved in the 5 to 10 million 

BTU/hr size range, assuming the population could be completely retrofitted, would be 

1.44 tons per day. Actual emission reductions are likely to be significantly lower 

because many of the boilers in this size range are used for space heating. Annual 

usage of boilers used for space heating is relatively low, and installation of controls is not 

likely to be cost effective. For this reason, most boiler rules, including BAAQMD 

Regulation 9, Rule 7, exempt boilers with low annual usage (less than 90,000 therms). 

Up to 80% of boilers in this size range may be exempt, based on data developed by the 

Sacramento Metropolitan AQMD. Emission reductions could be higher if the number of 

boilers is found to be higher than currently estimated or if the standards imposed by the 

San Joaquin Air District are able to be implemented for a wide range of units. Any 

emission reductions could probably be achieved in a cost-effective manner only over a 

period of at least 5 years, given the likelihood that low-NOx burner retrofits will be 

unavailable for many existing boilers. Most air districts have allowed boiler operators at 

least 5 years to achieve similar emission limits. 

Costs of Control 

Installation of low-NOx burners is expected to have a cost effectiveness of $5000 per ton 

or better based on cost data developed by the South Coast AQMD during development 

of its Rule 1146.1 and by the Ventura County APCD during development of it Rule 

74.15.1. For boilers with low annual usage, controls would be much less cost effective 

than $5000 per ton. 

Other Impacts 

Bay Area NOx reductions may reduce ambient levels of fine particulate pollution, 

because some fraction of the NOx emissions is ultimately converted to nitrate particles in 

the atmosphere. However, these reactions are not currently well understood and are 

difficult to quantify. 

Minor adverse environmental impacts may occur as a result of this control measure. 

Photochemical modeling from the 1980’s and 1990’s and recent ambient measurements 

indicate that Bay Area NOx reductions are likely to cause an increase in localized Bay 

Area ozone levels. In addition, ambient measurements suggest an emerging “ozone 

weekend effect” in the Sacramento area that may mean Bay Area NOx reductions are 

counterproductive in reducing downwind ozone. Further information on the benefits and 

disbenefits of Bay Area NOx reductions may come from photochemical modeling 

associated with the Central California Ozone Study. 

Some NOx technologies may adversely affect boiler turndown, capacity, CO levels, or 

efficiency. Rule provisions should be designed to avoid, for example, efficiency 

decreases and resulting increases in fuel use that might come from widespread use of 

boiler derating, water or steam injection, or burners modified to reduce flame 

temperatures. 

Other than the minor impacts discussed above, no potential adverse environmental 

impacts are expected as a result of the adoption of this control measure. BAAQMD air 
Bay Area 2005 Ozone Strategy C - 40 Final Adopted – January 4, 2006 

quality permits are not currently required for boilers with an input capacity smaller than 

10 million BTU/hr unless they also fire liquid fuels. To implement this control measure, 

amendments to BAAQMD Regulation 2, Rule 1 to require permits for small boilers would 

probably be necessary. If boilers in the 5 to 10 million BTU/hr range are as numerous as 

boiler service companies suggest, the administrative burden for the Air District could be 

significant. 

References 

Blanchard, C., Tanenbaum, S. "Characterization of CCOS Intensive Operating Periods: 

Task 4c. Supplemental Analyses: Corroborative Analysis" (paper prepared by Envair for 

the Central Coast Ozone Study/ARB, 2001) 

Marr, L.C., Harley, R.A. 2002. "Spectral analysis of weekday-weekend differences in 

ambient ozone, nitrogen oxide, and non-methane hydrocarbon time series in California." 

Atmospheric Environment 36, 2327-2335. 

San Francisco Department of Building Inspection. 2003. Personal communication from 

DBI forwarding boiler data extracted from DBI database into Excel spreadsheet. 

San Joaquin Unified APCD. 2003. "Final Draft Staff Report: Proposed Amendments to 

Rule 4305 (Boilers, Steam Generators, and Process Heaters - Phase 2) and Rule 4351 

(Boilers, Steam Generators, and Process Heaters - Phase 1); New Rule 4306 (Boilers, 

Steam Generators, and Process Heaters - Phase 3)" 

San Joaquin Unified APCD. Rules 4305, 4351, and 4306. 

South Coast AQMD. 2001. "Potential Backstop Rule for Regulation XX - Regional Clean 

Air Incentive Market (RECLAIM)." Report to SCAQMD Board, November 9, 2001. 

South Coast AQMD. 2000. "Staff Report: Proposed Amended Rule 1146 - Emissions of 

Oxides of Nitrogen from Industrial, Institutional, and Commercial Boilers, Steam 

Generators, and Process Heaters." 

South Coast AQMD. 1997. "Final Staff Report for: Proposed Amended Rule 1146.2 - 

Emissions of Oxides of Nitrogen from Large Water Heaters and Small Boilers." 

South Coast AQMD. Rules 1121, 1146, 1146.1,and 1146.2. 

Texas Council on Environmental Quality. 1999. Rule Log. No. 1999-055I-117-AI, 

available at www.tnrcc.state.tx.us/oprd/rul-lib/pa99055i.pdf. 

Texas Administrative Code, Title 30, Chapter 117 - Control of Pollution form Nitrogen 

Compounds. 

TIAX LLC. 2004. “Control Measure Number: D-16 Bay Area: Boilers, Steam 

Generators, and Process Heaters/Space Heaters” Control measure suggested for the 

Bay Area by Sacramento Metropolitan AQMD/TIAX based on control measure D-16 

developed by TIAX for the Sacramento region. 

U.S. EPA. 1994. "Alternative Control Techniques Document - NOx Emissions from 

Industrial, Commercial, Institutional (ICI) Boilers." EPA document no. EPA-453/R-94-

022. 

 
Bay Area 2005 Ozone Strategy C - 41 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 13: LARGE WATER HEATERS AND SMALL BOILERS 

Control Measure Description 

This control measure would reduce emissions of nitrogen oxides (NOx) from water 

heaters larger than those currently regulated by BAAQMD rules and boilers smaller than 

those currently regulated by BAAQMD rules. NOx limits would be imposed on units with 

a rated heat input capacity greater than 75,000 BTU/hr and less than or equal to 2 

million BTU/hr. 

Background and Regulatory History 

The Air District regulates NOx emissions from water heaters under Regulation 9, Rule 6, 

which imposes a NOx limit of 40 nanograms NOx per joule of heat output on water 

heaters with a rated heat input capacity of 75,000 BTU/hr or less. The regulated water 

heaters are conventional tank water heaters typically found in single-family residences. 

Boilers are regulated under three separate rules. Two rules apply to large industrial 

boilers at refineries and power plants (Regulation 9, Rules 10 and 11, respectively). The 

third rule, Regulation 9, Rule 7, imposes a 30 ppm NOx limit on industrial, institutional, 

and commercial boilers with a rated heat input of 10 million BTU/hr or more. Control 

measure SS-12 proposes to extend the Regulation 9, Rule 7 limits to smaller boilers with 

a capacity of less than 10 million BTU/hr. 

The water heaters to which this measure applies are tank type water heaters similar in 

appearance, design, and construction to the smaller water heaters subject to Regulation 

9, Rule 6. These large water heaters range in size between 75,000 and 400,000 BTU/hr 

and are used in small hotels, apartment buildings, office buildings, and industrial and 

commercial facilities to supply hot water. 

Units larger than 400,000 BTU/hr are typically small boilers and are different in 

appearance, design, and construction from water heaters. The small boilers to which 

this measure applies are generally sold as “package boilers” that are equipped and 

shipped complete with burners and controls. Boilers in this size range generally rely on 

natural draft rather than mechanical draft equipment. They are used in office buildings, 

hotels, schools, and industrial facilities to supply heat, steam, or hot water. 

Emissions Subject to Control 

Emissions from these units along with emissions from many other types of combustion 

equipment are included in the BAAQMD inventory in two different categories. Some 

emissions from water heaters are included in the emission inventory source category 

called fuels combustion – domestic. Combined emissions from all types of equipment in 

this category are estimated to be 8.33 tons of NOx per day for 2003. Emissions from 

non-residential water heaters and boilers are included in the source category called fuels 

combustion – other external combustion, which includes external combustion sources 

such as boilers, furnaces, space heaters, and ovens. Emissions in this category are 

estimated to be 15.78 tons of NOx per day for 2003. 

To determine more precisely the emissions attributable to Bay Area water heaters and 

boilers in the size range subject to this measure, data from a boiler database developed 
Bay Area 2005 Ozone Strategy C - 42 Final Adopted – January 4, 2006 

by the San Francisco Department of Building Inspection (DBI) was used. Although San 

Francisco's population represents about one-tenth of the Bay Area total population, it 

represents about one-fourth of the population in heavily urbanized areas. This is 

important because large water heaters and boilers are not generally found in suburban 

areas except at laundries, some light industrial locations, and some schools. The San 

Francisco boiler population was therefore multiplied by 5 and rounded to arrive at water 

heater and boiler population estimates for the entire Bay Area. 

Based on the DBI database, there are an estimated 12,300 water heaters with a 

capacity from 75,000 to 400,000 Btu/hr in the Bay Area. The number of boilers with a 

capacity over 400,000 BTU/hr and up to 2 million BTU/hr is estimated at 10,500. Total 

estimated NOx emissions from these water heaters and boilers are set forth below. 

Future-year emissions for these units have been derived using the same growth factors 

used in the fuels combustion – other external combustion inventory category. 

 Emissions Subject to 

Year Control (TPD, Summer)

2003 5.30 

2006 5.54 

Note that these emission estimates are likely to change during rule development as 

better population and emissions information becomes available. 

Proposed Method of Control 

This measure would impose a NOx limit of 40 nanograms per joule of heat output as 

found in Regulation 9, Rule 6 on large water heaters with a capacity greater than 75,000 

BTU/hr and less than or equal to 400,000 BTU/hr. For boilers larger than 400,000 

BTU/hr and less than or equal to 2 million BTU/hr, the measure would impose the NOx 

limit of 30 ppm found in Regulation 9, Rule 7. All limits would apply to new units only. 

These limits would be identical to limits for new units adopted by the Santa Barbara 

County APCD (SBCAPCD Rule 360). Water heaters and boilers with burners capable of 

meeting these NOx limits are widely available from numerous manufacturers. 

Rather than impose the limits only on new units, the South Coast AQMD adopted retrofit 

requirements (in Rule 1146.2) for units with a capacity between 400,000 BTU/hr and 2 

million BTU/hr. However, because operators of the units were given approximately 10 

years to comply, the requirements are similar in effect to those adopted by the Santa 

Barbara APCD. In addition, South Coast AQMD staff have reported a non-compliance 

rate of 80% with rule limits for units subject to RECLAIM. In addition, it appears that 

retrofits are unavailable for most of these smaller units. 

Emission Reductions Expected 

The total estimated NOx emission reduction that could be achieved, assuming a 10 year 

life expectancy for these units and replacement of all units with complying units by the 

end of the 10-year period, would be 3.9 tons NOx per day. This emission reduction 
Bay Area 2005 Ozone Strategy C - 43 Final Adopted – January 4, 2006 

would be achieved year-by-year over the 10-year period as new units replace existing 

units. 

Costs of Control 

Based on cost data developed by the South Coast AQMD during development of its 

Rule 1146.1, cost effectiveness is expected to range from a net cost savings (due to 

higher efficiency of low-NOx units) to approximately $3,000 per ton of NOx reduced. 

Other Impacts 

Bay Area NOx reductions may reduce ambient levels of fine particulate pollution, 

because some fraction of NOx emissions is ultimately converted to nitrate particles in the 

atmosphere. However, these reactions are not currently well understood and are difficult 

to quantify. 

Burners used to comply with the control measure may reduce energy usage. Low-NOx 

burners have higher thermal efficiencies than conventional units. Energy savings from 

use of low-NOx units may be as high as 20%. 

Minor adverse environmental impacts may occur as a result of this control measure. 

Photochemical modeling from the 1980’s and 1990’s and recent ambient measurements 

indicate that Bay Area NOx reductions are likely to cause a localized increase in Bay 

Area ozone levels. In addition, ambient measurements suggest an emerging “ozone 

weekend effect” in the Sacramento area that may mean Bay Area NOx reductions are 

counterproductive in reducing downwind ozone. Further information on the benefits and 

disbenefits of Bay Area NOx reductions may come from photochemical modeling 

associated with the Central California Ozone Study. 

Some NOx technologies may adversely affect boiler turndown, capacity, CO levels, or 

efficiency. Rule provisions should be designed to avoid, for example, efficiency 

decreases and resulting increases in fuel use that might come from widespread use of 

boiler derating, water or steam injection, or burners modified to reduce flame 

temperatures. 

Except as noted above, no significant adverse environmental impacts are expected as a 

result of the adoption of this control measure. BAAQMD air quality permits are not 

currently required for these water heaters and boilers and would not be required for 

implementation of this measure. NOx limits for these units would be enforced through a 

sales and installation prohibition. The Air District would enforce the sales ban at the 

distributor level, and local building departments would prohibit installation of heaters that 

do not comply with rule requirements. Implementation of the measure is not expected to 

impose a significant administrative burden for the Air District. 

References 

Blanchard, C., Tanenbaum, S. "Characterization of CCOS Intensive Operating Periods: 

Task 4c. Supplemental Analyses: Corroborative Analysis" (paper prepared by Envair for 

the Central Coast Ozone Study/ARB, 2001) 
Bay Area 2005 Ozone Strategy C - 44 Final Adopted – January 4, 2006 

Marr, L.C., Harley, R.A. 2002. "Spectral analysis of weekday-weekend differences in 

ambient ozone, nitrogen oxide, and non-methane hydrocarbon time series in California." 

Atmospheric Environment 36, 2327-2335. 

San Francisco Department of Building Inspection. 2003. Personal communication from 

DBI forwarding boiler data extracted from DBI database into Excel spreadsheet. 

Santa Barbara County APCD. Rule 360. 

South Coast AQMD. 2001. "Potential Backstop Rule for Regulation XX - Regional Clean 

Air Incentive Market (RECLAIM)." Report to SCAQMD Board, November 9, 2001. 

South Coast AQMD. 1997. "Final Staff Report for: Proposed Amended Rule 1146.2 - 

Emissions of Oxides of Nitrogen from Large Water Heaters and Small Boilers." 

South Coast AQMD. Rule 1146.2. 

 
Bay Area 2005 Ozone Strategy C - 45 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 14: STATIONARY GAS TURBINES 

Background 

This control measure would reduce emissions of nitrogen oxides (NOx) from stationary 

gas turbines through the revision of existing limits to reflect current best available retrofit 

control technology (BARCT). 

Regulatory History 

The Air District regulates NOx emissions from stationary gas turbines under Regulation 

9, Rule 9. The rule was adopted in 1993 pursuant to California Air Resources Board 

(CARB) pollution transport regulations (California Code of Regulations beginning at 

section 70600). The CARB regulations required the BAAQMD to adopt by 1994 best 

available retrofit control technology (BARCT) for source categories that collectively 

amounted to 75% of the 1987 nitrogen oxides emission inventory. The BAAQMD 

standards for existing turbines are 9 to 42 ppm depending upon turbine size, with small 

turbines subject to less stringent limits. 

The CARB transport regulations were amended in 2003 and now require adoption of “all 

feasible measures” to reduce ozone precursor emissions. 

In 2002, the San Joaquin Valley Unified APCD adopted amendments to its gas turbine 

rule (Rule 4703) that impose turbine NOx standards more stringent than the standards 

found in the rules of most other air districts. The most significant of the SJVUAPCD 

amendments require larger turbines (greater than 10 megawatts) to meet standards of 

either 3 or 5 ppm, depending upon the installation date of NOx controls. 

Emissions Subject to Control 

Turbine emissions are included in the BAAQMD inventory in the category called fuels 

combustion – turbines. Estimated emissions for the category are set forth below. 

 Emissions Subject to 

Year Control (TPD, Summer)

2003 1.77 

2006 1.83 

Staff investigating this proposal has determined that emissions from permitted stationary 

gas turbines from reported throughput data for 2004 is about 2.9 tons/day. The 

discrepancy may be due to increases in usage. 

Proposed Method of Control 

Most emission reductions would come from the installation of selective catalytic 

reduction (SCR) on large turbines (>10 MW) that do not currently use SCR to control 

NOx emissions. 
Bay Area 2005 Ozone Strategy C - 46 Final Adopted – January 4, 2006 

There are 43 stationary turbines operating in the BAAQMD. Eleven of the turbines 

already meet 5 ppm limits, and the measure would not reduce emissions for those 

turbines. Another 20 large turbines currently meet 5 - 10 ppm limits using SCR. 

Emission reductions from requiring these turbines to meet a 5 ppm limit are likely to be 

minor, and cost effectiveness for controls is likely to be poor unless the limit can be 

achieved through catalyst resizing. Twelve large turbines are currently subject to a 15 

ppm or higher limit, and adoption of the SJVUAPCD limits would require that they meet a 

5 ppm limit. These turbines are all larger than 10 MW and do not use SCR for NOx 

control. Installation of SCR may not be feasible for all 12 turbines because of sitespecific constraints. 

Some very minor emission reductions might come from the installation of dry low-NOx 

combustors (DLN) on small tubines (<10 MW) currently subject to 42 ppm limits. The 

San Joaquin limits are 35 ppm limit if DLN is not available and 25 ppm if DLN is 

available. DLN appears to be available for less than half of the 13 Bay Area turbines in 

this size range. Emission reductions would be minor. 

Emission Reductions Expected 

Requiring turbines larger than 10 MW to meet a 5 ppm standard would reduce emissions 

by approximately 1.2 tons per day, assuming SCR installation is feasible and cost 

effective for all turbines in this category. Additional minor emission reductions may be 

achievable for some smaller turbines through the installation of DLN. Greater precision 

in the emission reduction estimate cannot be achieved without detailed investigation for 

each turbine. 

Costs of Control 

The SJVUAPCD found that cost effectiveness for the installation of SCR on turbines 

larger than 10 MW ranged from approximately $5,000 per ton to approximately $10,000 

per ton. Cost effectiveness for the installation of DLN on smaller turbines was in this 

same range. The cost estimates used by SJVUAPCD for new SCR’s appear to be three 

times higher than similar estimates from the EPA. Assuming these costs are valid, cost 

effectiveness of new SCR’s for NOx reduction is at the high end of traditional cost 

effectiveness for District rules. Staff is working to refine cost estimates. 

Other Impacts 

Bay Area NOx reductions may reduce ambient levels of particulate pollution, because 

some fraction of the NOx emissions is ultimately converted to nitrate particles in the 

atmosphere. However, these reactions are not currently well understood and are difficult 

to quantify. 

Minor adverse environmental impacts may occur as a result of this control measure. 

Photochemical modeling from the 1980’s and 1990’s and recent ambient measurements 

indicate that Bay Area NOx reductions are likely to cause localized increases in Bay 

Area ozone levels. In addition, ambient measurements suggest an emerging “ozone 

weekend effect” in the Sacramento area that may mean Bay Area NOx reductions are 

counterproductive in reducing downwind ozone. Further information on the benefits and 

disbenefits of Bay Area NOx reductions may come from photochemical modeling 
Bay Area 2005 Ozone Strategy C - 47 Final Adopted – January 4, 2006 

associated with the Central California Ozone Study. The current assessment is that a 

reduction of 1.2 tons/day of NOx is below the sensitivity of the model. 

Additional use of SCR would increase ammonia emissions and the hazards associated 

with the transportation and use of ammonia, since the SCR system relies on ammonia 

injection to reduce NOx. 

Other than the minor impacts discussed above, no potential adverse environmental 

impacts are expected as a result of the adoption of this control measure. 

References 

Blanchard, C., Tanenbaum, S. "Characterization of CCOS Intensive Operating Periods: 

Task 4c. Supplemental Analyses: Corroborative Analysis" (paper prepared by Envair for 

the Central Coast Ozone Study/ARB, 2001) 

Gallenstein, C., California Air Resources Board. 2003. Personal communication. 

Marr, L.C., Harley, R.A. 2002. "Spectral analysis of weekday-weekend differences in 

ambient ozone, nitrogen oxide, and non-methane hydrocarbon time series in California." 

Atmospheric Environment 36, 2327-2335. 

San Joaquin Valley Unified APCD. 2002. "Final Staff Report: Amendments to Rule 4703 

(Stationary Gas Turbines)" and Appendices. 

U.S. Environmental Protection Agency. 2000. "Compilation of Emission Factors, AP-42 , 

5th Ed., Chapter 3.1: Stationary Gas Turbines, Supplement F" and supporting materials 

including Background Document and turbine database. 
Bay Area 2005 Ozone Strategy C - 48 Final Adopted – January 4, 2006 

CONTROL MEASURE SS 15: PROMOTE ENERGY CONSERVATION 

Control Measure Description 

The purpose of this measure is to educate public and private entities about the link 

between air quality, greenhouse gas emissions and energy conservation. This measure 

would encourage local governments, businesses and the public to make choices that 

have a positive effect on energy conservation and air quality. Reduced combustion of 

fossil fuels through increased energy efficiency will reduce emissions of ozone 

precursors and other criteria pollutants, as well as reduce emissions of carbon dioxide 

and other pollutants contributing to global warming. This control measure would reduce 

emissions of criteria pollutants and greenhouse gas emissions through the voluntary 

adoption and enforcement of a model ordinance by local government agencies to reduce 

energy consumption. This measure may also include development of new Air District 

programs to increase energy conservation and strengthen existing Air District programs 

and measures already achieving some measure of energy conservation. Air District 

energy conservation programs may include education campaigns targeting the general 

public, businesses and industry through outreach programs and workshops. The Air 

District may also partner with local government agencies and other public agencies to 

encourage energy conservation. 

Background and Regulatory History 

Energy produced from the combustion of fossil fuels, such as gasoline or natural gas, 

results in air emissions of criteria air pollutants, such as those that form ozone, and 

greenhouse gases. According to the California Energy Commission (CEC), fossil fuel 

combustion provides Californians with 86 percent of the energy consumed in the State 

and results in the emissions of nitrogen oxides, an ozone precursor, and carbon dioxide, 

a greenhouse gas. Potentially large potential emission reductions from energy 

conservation exist in all sectors of the economy. The CEC, created in 1974, is the 

State’s primary energy policy and planning agency, promoting energy efficiency through 

appliance and building standards, public education, and other programs. The CEC also 

is involved with developing energy technologies and supporting renewable energy 

programs. 

The Air Resources Board, in response to AB 1493 (Pavley), has drafted a regulation to 

reduce greenhouse gas emissions from light-duty motor vehicles that will primarily be 

accomplished through increased vehicle efficiency. The draft regulation would increase 

the light-duty fleet fuel efficiency by approximately 30 percent, would be inexpensive to 

implement, could be easily achieved with current technology, and would result in a cost 

savings to the consumer. TCMs and mobile source measures proposed in the Ozone 

Strategy also achieve some measure of energy efficiency by encouraging people to 

drive less, use alternative and more energy efficient means of transportation, or operate 

vehicles more efficiently. 

The Air District is currently funding a pilot project to inventory the greenhouse gas 

emissions in Sonoma County, make recommendations to reduce these emissions, and 

highlight the link between greenhouse gas emission reductions and Air District air quality 

programs. The pilot project will also provide valuable information on developing a model 

greenhouse gas emission reduction ordinance that links these emission reductions with 

Air District efforts to reduce emissions of other air pollutants. Many of the Air District’s 
Bay Area 2005 Ozone Strategy C - 49 Final Adopted – January 4, 2006 

efforts to reduce emissions of criteria air pollutants, such as ozone precursors, have the 

additional benefit of reducing carbon dioxide, the primary greenhouse gas that 

contributes to global warming. This measure will more strongly link energy conservation 

measures with carbon dioxide and ozone precursor reductions. 

Market Affected 

This measure would affect all sectors of the Bay Area economy including building energy 

and industrial/manufacturing processes, transportation and land use planning. Design 

and construction of residential, retail, office, commercial and industrial buildings would 

be affected. Building envelopes (i.e. exteriors) that reduce heating and cooling loads 

would be promoted, as well as more energy efficient building systems that consume less 

energy for heating, cooling, lighting and water heating. More energy efficient industrial 

and manufacturing processes would be encouraged. Land use planning that promotes 

alternatives to the automobile would be encouraged (see TCM 15). Transportation 

sectors affected would include private and public fleets and would promote more energy 

efficient and alternate means of transportation. 

Proposed Method of Control 

This measure would be implemented through a combination of efforts. The Air District 

will develop a model Energy Efficiency Ordinance and encourage voluntary adoption by 

local government agencies. Agencies may adopt the Air District’s model ordinance or 

modify the ordinance prior to adoption. The Air District will encourage agencies adopting 

the Energy Efficiency Ordinance to promote the ordinance throughout the agency’s 

jurisdiction. In addition, the Air District may conduct a public education program 

promoting energy efficiency that links energy efficiency with combating air pollution and 

global warming. The Air District may also explore potential incentives that could be 

provided to promote projects and programs that in addition to reducing air pollution are 

energy efficient and reduce global warming gases. The Air District may also promote 

measures to reduce temperatures in urban areas through tree planting and the use of 

building and paving materials with high reflectivity. These measures would reduce urban 

ambient temperatures, and thus reduce energy demand for building cooling as well as 

contribute to reduced photochemical production of ozone. 

Emissions Reductions Expected 

Quantification of emission reductions from this measure is very difficult and would 

depend on the breadth of implementation and the available funding for implementation. 

Based on the growing concern over global warming, adoption and implementation of 

Energy Efficiency Ordinances (or similar climate change or greenhouse gas ordinances) 

by local government agencies may accelerate and thereby increase the effectiveness of 

this measure. The emission reductions achieved through enhancing the effectiveness of 

TCMs and mobile source measures from activities such as mode shifts to less polluting 

forms of transportation and reduced equipment idling are addressed in those measures. 

Costs of Control 

The annual costs of this measure cannot be determined at this time. Air District costs 

would include staff time for developing and implementing a model Energy Efficiency 

Ordinance. Costs may also include staff time for developing a public education program, 
Bay Area 2005 Ozone Strategy C - 50 Final Adopted – January 4, 2006 

including the printing and distribution of materials and media and advertising costs, as 

well as providing incentives for the implementation of energy conservation measures. 

Many energy efficiency measures promoted through existing local, State and national 

programs incorporate cost effective measures that provide a financial benefit to the 

participant (i.e. there is a savings). For example, walking, bicycling or taking transit, 

instead of owning or driving a car, can save an individual $5,000 -$6,000 a year in the 

Bay Area. 

Other Impacts 

This measure would also reduce: 

• Peak energy demands at utilities thereby reducing the need for construction of 

power plants to meet peak demands, 

• Emissions of carbon dioxide, a global warming gas, and 

• Consumer utility bills and fuel costs, 

• Exploration, extraction, transportation and use of fossil fuels that damage water 

and land resources (e.g. oil spills that destroy plant and animal life and leave 

waterways and their surrounding shores uninhabitable). 
Bay Area 2005 Ozone Strategy C - 51 Final Adopted – January 4, 2006 

CONTROL MEASURE MS 1: DIESEL EQUIPMENT IDLING ORDINANCE 

Background 

This control measure would reduce emissions from the idling of diesel equipment 

through the voluntary adoption and enforcement of a model ordinance by local 

government agencies. Reducing diesel equipment idling will primarily reduce emissions 

of NOx, particulate matter and toxic air contaminants. The measure would limit the 

amount of time operators of diesel equipment, including heavy-duty trucks, buses and 

construction equipment, idle their engines. This measure would reduce emissions from 

heavy-duty trucks at warehouse/distribution centers, port terminals, truck stops and rest 

areas. This measure would also reduce emissions from idling diesel buses and heavyduty diesel construction equipment. Diesel equipment idling for extended periods of time 

can produce localized high concentrations of emissions that affect the health of the 

operators and the neighboring communities. 

Regulatory History 

Anti-idling legislation has been enacted in at least 18 states across the country with 

some legislation targeting specific urban areas and others with statewide restrictions. 

The majority of the restrictions limit idling to 5 minutes. In December 2002, the ARB 

adopted its first anti-idling, airborne toxic control measure (ATCM) that would limit school 

bus idling at or near schools. That ATCM requires a driver of a school bus, urban bus, 

or other commercial motor vehicle to manually turn off the bus or vehicle engine upon 

arriving at a school and to restart it no more than 30 seconds before departing. 

Sections 40720 and 40720.5 of the California Health and Safety Code require coastal 

port authorities to limit truck idling at certain marine terminals to no longer than 30 

minutes. The Air District has responsibility of enforcing this requirement at ports in the 

Bay Area. ARB has voluntary incentive and demonstration programs to reduce idling, 

such as the Carl Moyer Program, that promotes the introduction of auxiliary power units 

as an idle reduction device for heavy-duty vehicles. Placer County APCD has adopted 

regulations limiting idling to 5 minutes for diesel-powered trucks with a gross vehicle 

weight (GVW) of 26,000 lbs or greater and off-road diesel-powered equipment rated at 

75 horsepower or greater. In July 2004, the California Air Resources Board adopted a 

heavy-duty vehicle idling emission reduction requirement. 

Emissions Subject to Control 

This control measure would potentially apply to all diesel-fueled medium and heavy 

heavy-duty trucks, heavy-duty urban buses and construction equipment rated at 75 

horsepower or greater operating within the boundaries of the Air District. Preliminary 

estimates of the projected baseline ROG, NOx and PM emissions for vehicles and 

equipment subject to control are provided in the table below. 
Bay Area 2005 Ozone Strategy C - 52 Final Adopted – January 4, 2006 

Emissions Subject to Control (Tons/Day) - Preliminary1

ROG NOx PM 

 2005 2010 2005 2010 2005 2010

Medium Heavy Duty Diesel Trucks 0.04 0.04 1.36 1.03 0.04 0.04 

Heavy Heavy Duty Diesel Trucks 0.18 0.14 3.90 2.85 0.09 0.07 

Heavy Duty Diesel Urban Buses 0.04 0.04 0.79 0.81 0.02 0.02 

School Buses 0.01 0.01 0.13 0.15 0.00 0.01 

Off-Road Construction Equipment 0.40 0.28 3.61 2.78 0.25 0.20 

Total 0.67 0.51 9.79 7.62 0.40 0.32 

Proposed Method of Control 

The Air District would develop a model diesel equipment idling ordinance and would 

encourage cities and counties to adopt it locally. Local governments choosing to adopt 

the ordinance would be responsible for enforcement. This measure would allow the use 

of alternative idle reduction devices such as automatic stop-start systems. Operators of 

diesel equipment without idle reduction devices would need to manually turn off their 

equipment. Diesel engine operators would not be subject to idling limitations under 

specified conditions in which idling would be necessary to accomplish the work for which 

the vehicle/equipment is designed. Compliance with this measure generally would be 

carried out by peace officers. General idling would be limited to 5 minutes per location 

for all applicable diesel equipment. Trucks with sleeper berths would be allowed to idle 

for more than 5 minutes only if an alternative means of providing power and heating or 

cooling to the berth were not available and the sleeping berth is in use. Devices such as 

fuel-fired heaters, auxiliary power units, and power inverter/chargers for use with 

batteries and grid-supplied electricity could be used to provide heating and air 

conditioning at truck stops for truck cab comfort. Outreach efforts to inform truck and 

bus operators could be carried out with signage at commercial fueling stations, 

Department of Motor Vehicles offices, transit stations, depots, truck stops and gateways 

to the Air District. Compliance by construction contractors could be promoted through 

informational materials provided by local governments, license renewals and/or mailings. 

Emission Reductions Expected 

The use of alternative idle reduction devices/strategies, in lieu of operating the heavyduty diesel engine at idle, will result in significant NOx reductions. Reductions in ROG, 

PM, carbon monoxide and carbon dioxide are also expected, but to a lesser extent. The 

fleet average cost-effectiveness of this proposal is less than $500 per ton of NOx plus 

ROG reduced. Estimated emission reductions from this measure are presented in the 

following table. 

 

1

 Emissions are from ARB database and are an annual average of grown and controlled 

emissions. 
Bay Area 2005 Ozone Strategy C - 53 Final Adopted – January 4, 2006 

Emissions Reductions Expected (Tons/Day) - Preliminary2

ROG NOx PM 

 2005 2010 2005 2010 2005 2010

Medium Heavy Duty Diesel Trucks 0.01 0.01 0.27 0.21 0.01 0.01 

Heavy Heavy Duty Diesel Trucks 0.04 0.03 0.78 0.57 0.02 0.01 

Heavy Duty Diesel Urban Buses 0.01 0.01 0.16 0.16 0.00 0.00 

School Buses 0.00 0.00 0.03 0.03 0.00 0.00 

Off-Road Construction Equipment 0.08 0.06 0.72 0.56 0.05 0.04 

Total 0.13 0.10 1.96 1.52 0.08 0.06 

Cost of Controls 

This measure could save up to $1,600 in fuel costs and $2,000 in maintenance costs 

annually per heavy-duty truck. Idle shutdown systems are a standard feature on current 

electronically controlled on-road heavy-duty engines, but would need to be 

reprogrammed to shut the engine down after 5 minutes. Either engine manufacturers or 

vehicle owners would need to reset the idle shutdown time. The cost incurred to reset 

the idle shutdown time is not significant. There would be no cost to operators of vehicles 

or equipment that do not have idle shutdown systems and would therefore need to 

manually turn off their equipment. 

Other Impacts 

This measure would also reduce: 

• Emissions of diesel particulate matter, which the California Air Resources Board 

has identified as a toxic air contaminant; 

• Consumption of diesel fuel; 

• Emissions of carbon dioxide, a global warming gas; and 

• Noise and odor impacts to sensitive receptors near warehouses and distribution 

centers. 

No significant adverse environmental impacts are expected as a result of the 

implementation of this control measure. 

 

2

 Emission reductions are based on ARB’s Staff Report: Initial Statement of Reasons, Public 

Hearing to Consider Adoption of Heavy-Duty Vehicle Idling Emission Reduction Requirement, 

December 5, 2003, that estimates 5% of emissions are from idling. Emission reductions in this 

table assume 1% emission reductions due to the voluntary nature of this measure and 

enforceability. 
Bay Area 2005 Ozone Strategy C - 54 Final Adopted – January 4, 2006 

CONTROL MEASURE MS 2: GREEN CONTRACTING 

Background 

This measure would entail development and promotion of a model ordinance for local 

government agencies to use in amending local codes that govern public agency 

contracting. Public agencies can play an important role in improving air quality by 

encouraging contractors to operate low-emission vehicles, purchase clean fuels, 

promote ridesharing programs and curtail polluting activities on Spare the Air days. By 

adopting and implementing Green Contracting Ordinances, public agencies can 

encourage contractors to operate their businesses in ways that benefit air quality. 

Regulatory History 

The Air District does not have regulatory authority to require local government agencies 

to adopt Green Contracting Ordinances. Under this measure, adoption of Green 

Contracting Ordinances by public agencies in the Bay Area would be strictly voluntary. 

The Sacramento Metropolitan Air Quality Management District and the Yolo-Solano and 

Placer County Air Pollution Control Districts have developed a Model Green Contracting 

Ordinance for use by local agencies in their jurisdictions. 

Emissions Subject to Control 

This measure achieves emission reductions by encouraging contractors that do 

business with public agencies to increase the use of low-emission vehicles and 

equipment or implement other measures that reduce emissions, such as use of clean 

fuels or business practices supporting employee trip reduction. Emissions subject to 

control would include on road mobile sources and off road equipment operated by 

contractors that do business with public agencies, emissions from the employee 

commutes for these contractors, and emissions from activities discouraged on Spare the 

Air days, such as vehicle refueling, use of gasoline-powered lawn and garden 

equipment, and use of paints and solvents. 

Proposed Method of Control 

The Air District will develop a model Green Contracting Ordinance and encourage 

adoption by local government agencies. Agencies may adopt the Air District’s model 

ordinance or modify the ordinance prior to adoption. The Air District will encourage 

agencies adopting a Green Contracting Ordinance to promote the ordinance with 

businesses that may contract with the agency. In implementing the ordinance, the 

agency would give preferential consideration in awarding contracts to contractors that 

procure and operate low-emission vehicles, purchase clean fuels, and achieve lowemission fleet status for off-road equipment and heavy-duty on-road fleets. Participating 

government agencies will also provide preferential consideration in awarding contracts to 

contractors that promote ridesharing programs and participate in the Spare the Air 

program. An agency would include contract bid language implementing the following 

contracting program requirements on contracts within the Air District: 

• Contractor would submit to the local government agency a clean air plan for 

reducing air emissions. The plan may contain but would not be limited to 

emission reductions from on-going activities, such as low-emission fleet 
Bay Area 2005 Ozone Strategy C - 55 Final Adopted – January 4, 2006 

operations and ridesharing programs, and/or intermittent emission reductions, 

such as participation in the Spare the Air program. This plan would be submitted 

to and approved by the contracting agency prior to the final execution of the 

contract. This plan would detail the types of actions the contractor would take to 

reduce air quality impacts while working within the jurisdiction. 

• A contractor may submit their low-emission fleet status as a qualifying plan. 

Low-emission fleet status might be achieved by subcontracting to a registered 

low-emission fleet for the contracted work or using approved alternative fuels or 

devices on non-compliant equipment. 

• Bidders that provide ridesharing program components could include those 

elements in their submitted plan. These components may include membership in 

a transportation management association, having a designated employee 

transportation coordinator, or some other type of effective employee alternative 

commute program. 

• The contractor submits an acceptable plan to curtail emission-producing activities 

on Spare the Air days. 

• The contractor meets with local agency staff and discusses suitable emission 

reduction strategies and future plans. 

Emission Reductions Expected 

Emission reductions expected from this measure are very difficult to quantify. 

Reductions would be achieved by the ability of contractors that meet Green Contracting 

requirements to win contracts with local government agencies. The volume of work, 

emission characteristics of the low emission fleet, volume of clean fuel used, level of 

participation of employee commute programs and number of Spare the Air days would 

all be factors affecting the level of emission reductions achieved by this measure. 

Cost of Controls 

Contractors may incur costs by purchasing, maintaining and/or operating a low emission 

fleet, providing employees with alternative commute benefits, purchasing clean fuels or 

curtailing activities on Spare the Air days. However, if local agencies favor contractors 

with such programs, they could improve the competitiveness of contractors in winning 

contract awards. Local government agencies may have higher costs if they award 

contracts to contractors that have higher costs but are selected because they meet 

Green Contracting requirements. 

Other Impacts 

Increased use of fuel efficient vehicles and equipment, reduced vehicle trips, and other 

energy saving measures implemented based on green contracting provisions would 

reduce emissions of pollutants that contribute to global warming. No significant adverse 

environmental impacts are expected as a result of the implementation of this control 

measure. 

 
Bay Area 2005 Ozone Strategy C - 56 Final Adopted – January 4, 2006 

CONTROL MEASURE MS 3: LOW-EMISSION VEHICLE INCENTIVES 

Background 

The purpose of this measure is to encourage the purchase of new low-emission vehicles 

and to reduce emissions from existing vehicles. Low-emission vehicles can be defined 

as vehicles that emit significantly less pollution than the standards established for 

vehicles of similar make and model year. Low-emission vehicles typically have cleaner 

burning engines, fuels and/or exhaust treatment devices. The Air District currently funds 

low-emission vehicle projects through the Transportation Fund for Clean Air (TFCA), 

Carl Moyer Program and other funding sources. TFCA enabling legislation identifies 

“low-emission and zero-emission vehicle programs” as one of the project categories 

eligible for TFCA funding. The legislation further requires that to be eligible for funding, 

control measures such as low-emission vehicle programs must also be included in the 

plans for attainment of state or federal ambient air quality standards, such as this Ozone 

Strategy. This measure clarifies the types of low-emission vehicle projects that would be 

eligible for TFCA funds and other Air District grant programs. 

Regulatory History 

The Air District provides financial incentives to increase the use of low-emission 

vehicles. The Air District currently provides incentives to reduce mobile source 

emissions through the TFCA and Carl Moyer Programs. Section 44220 of the California 

Health and Safety Code allows the Air District to collect funds through a motor vehicle 

registration surcharge to carry out “low-emission and zero-emission” projects that are 

also contained in a State ambient air quality attainment plan, such as this Ozone 

Strategy. Chapter 9 of the California Health and Safety Code contains the enabling 

legislation for the Carl Moyer Program. Under the Carl Moyer Program, the California 

Air Resources Board (CARB) provides funding to local air districts, which award grants 

to reduce emissions from on-road and off-road engines and equipment in public and 

private fleets. In fall 2004, legislation was enacted which 1) significantly increases 

funding for the Carl Moyer Program, and provides a stable funding source through the 

year 2014, and 2) authorizes local air districts to impose an additional $2 per vehicle 

surcharge on motor vehicle registrations, to be used for projects to reduce emissions 

from heavy-duty vehicles, scrappage or repair of existing in-use vehicles, and 

agricultural sources. The new legislation will greatly increase the available funding to 

implement low-emission vehicle projects, especially projects to reduce emissions of NOx 

and particulate matter from heavy-duty diesel engines. The Air District’s Low Emission 

School Bus Program provides funds for the conversion of school buses to clean fuels or 

the installation of particulate matter retrofit devices on school buses. 

Emissions Subject to Control 

This control measure would achieve emission reductions from low-emission vehicle 

programs that include all vehicle weights (i.e., light, medium and heavy-duty) and onroad and off-road sources. This control measure would allow TFCA funding of lowemission vehicles, engine repowers and retrofits, exhaust treatments, clean fuels or 

additives, and the infrastructure to supply alternative fuels. The projected ROG and NOx 

emissions subject to control are provided below. 
Bay Area 2005 Ozone Strategy C - 57 Final Adopted – January 4, 2006 

 Emissions Subject to Control 

Year ROG (TPD) NOx (TPD)

2003 163 305 

2006 137 263 

2009 115 223 

 

Proposed Method of Control 

This control measure is intended to increase the share of low-emission vehicles in onroad and off-road fleets. TFCA funds and other Air District grant programs would be 

used to provide an incentive to: 

• Purchase low- or zero-emission vehicles or engines; 

• Engine repowers, retrofits and replacements; 

• Exhaust treatments and add-on equipment; 

• Clean fuels or additives; and 

• Infrastructure to supply alternative fuels. 

Emission Reductions Expected 

Estimated emission reductions are shown in the table below. Emission reductions would 

be limited by available TFCA and other Air District grant program funds, availability of 

vehicles and infrastructure, and the ability of projects to compete for the funds. With the 

increase in funding due to the legislation enacted in fall 2004, it is expected that the Air 

District will be able to distribute at least $20 million per year for low-emission vehicle 

projects beginning in 2005. 

 Emission Reductions 

Year ROG (TPD, 

Summer)

NOx (TPD, Summer)

2003 0.03 0.6 

2006 0.03 1.6 

2009 0.03 4.6 

Cost of Controls 

For the incremental cost of light-duty and medium-duty low-emission vehicles, the 

District typically provides between $1,000 and $4,000 per vehicle. For the incremental 

cost of new heavy-duty vehicles, the District typically provides between $15,000 - 

$50,000 per vehicle. Grants for repowers and retrofits of existing heavy-duty diesel 

engines typically range from $5,000 to $20,000 per vehicle. Projects funded by the Air 

District via the Carl Moyer Program typically achieve a cost-effectiveness of less than 

$5,000 per ton of NOx reduced. The cost-effectiveness of low-emission vehicle projects 

funded through the TFCA program can range from $5,000 to $90,000 per ton, with an 

average cost-effectiveness in the range of $30,000 to $40,000 per ton. 
Bay Area 2005 Ozone Strategy C - 58 Final Adopted – January 4, 2006 

Other Impacts 

It would be necessary to minimize leaks and losses of natural gas during handling, as 

methane is 30 times more potent than CO2 as a greenhouse gas. Increased use of 

natural gas and electric vehicles would reduce U.S. dependency on imported petroleum. 

Other than the minor impacts discussed above, no potential adverse environmental 

impacts are expected as a result of the implementation of this control measure. 
Bay Area 2005 Ozone Strategy C - 59 Final Adopted – January 4, 2006 

CONTROL MEASURE MS 4: VEHICLE BUY BACK PROGRAM 

Background 

This control measure would accelerate the retirement of older, high emitting vehicles 

from the region's roadways by providing incentives to scrap them. The first vehicle 

scrapping program in the country was implemented in the South Coast Air Basin by 

UNOCAL in 1990. The BAAQMD has administered a voluntary vehicle scrapping 

program since 1996. Other California air districts that have conducted publicly funded 

buy back programs include the South Coast AQMD, Santa Barbara APCD, San Diego 

APCD, and San Joaquin Unified APCD. 

Regulatory History 

The federal 1990 Clean Air Act amendments required the EPA to issue guidance on a 

control measure that would “encourage the voluntary removal from use and the market 

place of pre-1980 model year light duty vehicles”. Following the UNOCAL pilot project, 

numerous air districts throughout the state implemented vehicle buy back programs. 

The South Coast Air Quality Management District (SCAQMD) was the first to implement 

a vehicle buy-back program with their adoption of Regulation 1610 in 1993. 

The Air District began its Vehicle Buy Back (VBB) Program in June 1996. The Air 

District’s VBB Program purchases and scraps older vehicles that lack modern emission 

control systems and therefore produce more air pollution than newer cars. Since its 

inception in June 1996 through April 2004, the VBB Program has purchased and 

scrapped nearly 20,000 vehicles. The Air District funds the VBB Program through its 

Transportation Fund for Clean Air (TFCA). Section 44220 of the California Health and 

Safety Code allows the Bay Area Air District to collect funds through a motor vehicle 

registration surcharge to carry out specified clean air projects, including a vehicle 

scrapping program. The section further requires “an automobile buy-back scrappage 

program operated by a governmental agency” also be contained in a State ambient air 

quality attainment plan in order to be funded with TFCA funds. The Air District’s VBB 

Program adheres to the California Air Resources Board’s Voluntary Accelerated Lightduty Vehicle Retirement (VAVR) regulation. 

Emissions Subject to Control 

This control measure reduces emissions of reactive hydrocarbons, oxides of nitrogen 

and particulates from older model year light-duty motor vehicles. Currently, vehicles 

eligible for the VBB Program are light duty vehicles model year 1985 or older. There are 

approximately 327,225 model year 1985 and older vehicles in the Bay Area.3

 

Proposed Method of Control 

The VBB Program is a voluntary program that provides a financial incentive to owners of 

eligible vehicles to scrap their vehicles. The Air District implements the VBB Program by 

contracting with vehicle dismantlers to screen, purchase, and destroy eligible vehicles. 

The purchase of vehicles to be scrapped adheres to the VAVR vehicle eligibility 

 

3

 Number of 1985 and older vehicles is from DMV database provided to District through VBB 

contractor as of July 2005 
Bay Area 2005 Ozone Strategy C - 60 Final Adopted – January 4, 2006 

requirements, which include the registration status of the vehicle, ability of the vehicle to 

pass a functional test, and an equipment inspection test. VAVR eligibility requirements 

are established to provide assurance that a vehicle would remain on the road and 

continue to produce emissions if it were not scrapped. Marketing of the program by the 

Air District and its contractors informs potentially eligible vehicle owners about the 

program through annual direct mailings, newspaper and radio advertisements, fliers and 

on-site advertisements at scrapping sites. The VBB Program was expanded in October 

2004, increasing the eligibility of model years from 1981 to 1985 and increasing the 

incentive from $500 to $650. The Air District will continue to monitor the VBB Program 

and consider further revisions to the program, as necessary, to maximize the emission 

reductions and cost effectiveness. 

Emission Reduction Expected 

The emission reductions from this program depend upon the amount of funding 

available, the vehicle purchase price, vehicle eligibility requirements, the effectiveness of 

the marketing program, and the actual buy back rate. Increasing the purchase price, 

reducing the stringency of the vehicle eligibility requirements, and/or more intensive 

marketing increases the rate at which vehicles are purchased. Prior to October 2004, 

the Air District VBB Program offered $500 to eligible vehicle owners. At this funding 

level, the program purchased approximately 280 vehicles per month, or 3,360 vehicles 

per year. Scrapping 3,360 vehicles annually resulted in ROG reductions of 0.30 

tons/day and NOx reductions of 0.15 tons/day, and a cost effectiveness of approximately 

$6,400/ton of ROG and NOx reduced. The expansion of the program in October 2004, 

to allow up through 1985 model years and increasing the incentive to $650, increased 

the rate at which vehicles are purchased and the emission reductions achieved by the 

program. Under the expanded VBB Program, approximately 600 vehicles per month are 

purchased. Emission reductions under the expanded program are approximately 0.48 

tons/day of ROG and 0.31 tons/day of NOx. 

Cost of Controls 

The average cost of scrapping a vehicle under the expanded program is $890, which 

includes the $650 paid to the vehicle donor and $240 in program overhead costs. 

Program overhead consists of the cost of contractors to market the program, purchase 

and scrap the vehicles and Air District staff time. In FY 2003/04, the Air District spent 

approximately $3.7 million to purchase and scrap 4,573 vehicles. In FY 2004/05, the Air 

District’s allocation remained unchanged. In FY 2005/06, the VBB Program budget was 

increased to $7.2 million to fund the expanded program. Cost effectiveness for the 

expanded program is approximately $8,600/ton. 

Other Impacts 

Scrapping older vehicles may potentially reduce the supply of affordable vehicles for the 

economically disadvantaged. This measure would also increase the amount of solid 

waste generated by scrapped vehicles, although some material from scrapped vehicles 

is recycled. Except as noted above, no significant adverse environmental impacts are 

expected as a result of the implementation of this control measure. 
 

BAY AREA 

2005 OZONE STRATEGY 

APPENDIX D - TRANSPORTATION CONTROL 

MEASURE DESCRIPTIONS 

FINAL ADOPTED 

JANUARY 4, 2006

939 Ellis Street 

San Francisco, CA 94109 

(415) 771.6000 

www.baaqmd.gov
Bay Area 2005 Ozone Strategy D - 2 Final Adopted – January 4, 2006 

APPENDIX D - TRANSPORTATION CONTROL MEASURE 

DESCRIPTIONS 

TABLE OF CONTENTS 

TCM 1: SUPPORT VOLUNTARY EMPLOYER-BASED TRIP REDUCTION 

PROGRAM................................................................................................... D - 3

TCM 2: EMPLOYER BASED TRIP REDUCTION...................................................... D - 7

TCM 3: IMPROVE LOCAL AND AREAWIDE BUS SERVICE ................................... D - 8

TCM 4: UPGRADE AND EXPAND LOCAL AND REGIONAL RAIL SERVICE......... D-12

TCM 5: IMPROVE ACCESS TO RAIL AND FERRIES.............................................. D-15

TCM 6: IMPROVE INTERREGIONAL RAIL SERVICE.............................................. D-19

TCM 7: IMPROVE FERRY SERVICE........................................................................ D-21

TCM 8: CONSTRUCT CARPOOL / EXPRESS BUS LANES ON FREEWAYS......... D-24

TCM 9: IMPROVE BICYCLE ACCESS AND FACILITIES......................................... D-27

TCM 10: YOUTH TRANSPORTATION...................................................................... D-31

TCM 11: INSTALL FREEWAY TRAFFIC MANAGEMENT SYSTEMS ...................... D-33

TCM 12: ARTERIAL MANAGEMENT MEASURES................................................... D-36

TCM 13: TRANSIT USE INCENTIVES ...................................................................... D-39

TCM 14: CARPOOL AND VANPOOL SERVICES AND INCENTIVES...................... D-42

TCM 15: LOCAL LAND USE PLANNING AND DEVELOPMENT STRATEGIES...... D-45

TCM 16: PUBLIC EDUCATION/INTERMITTENT CONTROL MEASURES .............. D-51

TCM 17: CONDUCT DEMONSTRATION PROJECTS.............................................. D-56

TCM 18: IMPLEMENT TRANSPORTATION PRICING REFORM............................. D-59

TCM 19: IMPROVE PEDESTRIAN ACCESS AND FACILITIES ............................... D-64

TCM 20: PROMOTE TRAFFIC CALMING MEASURES............................................ D-67

The transportation control measures (TCMs) in this appendix for the 2005 Ozone Strategy were 

designed to reduce emissions from motor vehicles by reducing vehicle trips and vehicle miles 

traveled. TCMs may also reduce vehicle use, vehicle idling or traffic congestion. These TCMs 

address State ozone planning requirements for the Bay Area. Some of the TCMs are included in 

local, regional and state transportation programs. We expect to see those measures 

implemented, and achieve the emissions reductions we have projected. Other measures have 

little or no funding, and may require legislative authorization and voter approval prior to 

implementation. One example is TCM 18, Implement Transportation Pricing Reform. While the 

Air District would also like to see the most effective TCMs implemented, we acknowledge that 

there are significant obstacles that first must be overcome. Public education efforts must be 

undertaken in order to gain acceptance of these often-controversial measures. 
Bay Area 2005 Ozone Strategy D - 3 Final Adopted – January 4, 2006 

TCM 1: SUPPORT VOLUNTARY EMPLOYER-BASED TRIP REDUCTION PROGRAM 

Purpose

TCM 1 will support and encourage voluntary efforts by Bay Area employers to promote 

the use of commute alternatives by their employees. 

Background

The political and economic climate for employer-based trip reduction has changed since 

the early 1990’s, when employer-based trip reduction programs received greater 

emphasis in Bay Area air quality plans. Major developments include 1) the enactment of 

SB 437, which prohibited mandatory employer trip reduction programs as of January 1, 

1996, and 2) the reduction in public sector funding for transportation demand 

management programs. 

Despite these developments, the need for trip reduction programs remains strong. 

Without continued trip reduction programs, increased traffic volumes in general could 

increase motor vehicle emissions, and congestion, in particular, increases auto 

emissions due to stop and go traffic and lower, congested average speeds. 

Employment growth in the Bay Area has been especially robust in suburban areas, 

which due to land use patterns and limited transit infrastructure, tend to have the highest 

drive alone rates. In the near term, carpool and vanpool programs are especially suited 

for many suburban locations. 

Commute trips, which comprise 25 percent of daily trips, are still logical targets for 

employer-based trip reduction efforts due to: a) their key role in contributing to peak 

period traffic congestion and ozone formation, b) the long average distance of commute 

trips compared to other trip types, c) the repetitive nature of commute trips that occur on 

the same route and schedule each day, d) the pool of potential candidates for 

ridesharing at larger work sites, and e) the ability of employers to influence employee 

commute mode choice by means of the facilities, services, and incentives that they 

provide. 

While the need for employer programs is undiminished, TCM 1 will focus on assessing 

employer needs and maintaining core support services to employers. Generally, most of 

this effort will be accomplished through the regional ridesharing program administered 

by MTC and through discussions between the Air District and employers involved in the 

Spare the Air program, the Bay Area Clean Air Partnership (BayCAP), and other 

outreach efforts. 

Description

TCM 1 includes the following: 

Phase 1 (2004-2006) 

Generally maintain current efforts: 
Bay Area 2005 Ozone Strategy D - 4 Final Adopted – January 4, 2006 

• Provide core support for employer programs, based on an assessment of 

employer needs and the level of employer interest. Potential support includes 

assistance in developing or enhancing employer programs, information and 

referrals, employer networks, and programs to recognize outstanding employer 

programs. 

• Support legislation to maintain and expand incentives for employer programs, 

such as tax deductions and/or tax credits for employer efforts to promote 

ridesharing, transit, and other commute alternatives. (MTC, Air District, 

Congestion Management Agencies.) 

• Implement employer elements of the Spare the Air program (see TCM 16). 

• Provide information and assistance to employers in organizing transportation fairs 

and other marketing events at Bay Area work sites. 

• Work with employers to implement regional promotions such as Rideshare Week, 

Bike to Work Day, etc. 

• Work with employers to implement provisions of the State parking cash-out law, 

where certain employers who lease parking and provide subsidized parking to 

employees must offer their employees the choice of the subsidized parking or the 

equivalent value of the parking space as a cash payment to use for commute 

alternatives such as carpooling, transit, bicycling and walking, or to retain as 

additional income (see TCM 15). 

• Promote Commuter Check transit subsidy program to employers (see TCM 13). 

• Implement sub-regional or local programs to promote employer-based trip 

reduction in those cities and counties that choose to allocate local resources to 

such efforts. (Congestion Management Agencies, county transportation 

authorities, cities and counties). 

• Work with cities, counties and other public agencies who are also employers to 

develop commute alternatives, including telecommuting, compressed work week 

schedules, guaranteed ride home programs, etc. (MTC and the Air District can 

make special efforts to work with governmental agencies to encourage their 

support for these types of programs and explore new funding opportunities). 

• Continue to work with employers to support and encourage shuttle programs 

including the Bay Area Clean Air Partnership (BayCAP) comprehensive shuttles 

campaign to inventory existing programs, provide coordination and assistance, 

and promote “best practices” among shuttle operators. Support other efforts to 

coordinate shuttles with transit operators, improve shuttle marketing and provide 

additional shuttle funding opportunities. 

Phase 2 (Beyond 2006) 

• Continue programs listed above. 
Bay Area 2005 Ozone Strategy D - 5 Final Adopted – January 4, 2006 

• Seek legislation to create incentives for stronger voluntary programs for all 

employers or to require certain minimum elements of a basic commute 

alternatives program for public employers. 

Travel Market Affected 

This TCM targets commute travel, which accounts for approximately 25 percent of trips 

and 33 percent of VMT on a typical weekday. 

Effectiveness 

Empirical results show that employer trip reduction programs can decrease vehicle trips 

to a typical worksite by as much as 5-10 percent. Results from a 1996 BayCAP survey 

showed that work sites with voluntary trip reduction programs reduced commute trips by 

about 8 percent compared to the average for large work sites in 1994-95 before 

implementation of mandatory employer-based trip reduction. 

Maintenance of current efforts (and enhancements where feasible) is critical to assuring 

that voluntary trip reduction programs continue to reduce drive alone commute trips and 

emissions. Continued implementation of these voluntary programs is assumed to 

reduce work trips by 1% and yield the following emissions reductions: 

 ROG NOx

 2006 0.53 tpd 0.57 tpd 

 2015 0.23 tpd 0.22 tpd 

Cost 

The costs of this TCM include the public sector costs to provide services to promote 

voluntary employer efforts as well as the costs to employers that choose to implement 

such programs. Much of the public sector costs are included in the cost of funding the 

regional rideshare program (see TCM 14). 

Employer costs depend upon the number of employers that implement voluntary 

programs and the specific services and incentives that they offer to their employees. 

Data from studies of mandatory trip reduction programs indicate that employer costs 

typically ranged from $25 to $100 per employee per year. It is expected that employer 

costs for voluntary programs are lower, perhaps a maximum of $40-$50 per employee 

per year on average. Employer costs are offset to some extent by indirect gains such as 

increased productivity of employees due to less stressful commutes and improved 

recruitment and employee retention. 

Impediments 

The primary impediment is the reduced employer interest in trip reduction efforts given 

the cost of implementing these types of programs in a weakened economy and the lack 

of authority for the Air District to require these programs. 
Bay Area 2005 Ozone Strategy D - 6 Final Adopted – January 4, 2006 

Other Impacts 

In addition to reducing emissions, this TCM reduces auto trips in congested corridors 

and reduces fuel consumption and greenhouse gas emissions (CO2). Employees will 

benefit from reduced commute costs, such as vehicle operating and maintenance costs. 

 
Bay Area 2005 Ozone Strategy D - 7 Final Adopted – January 4, 2006 

TCM 2: EMPLOYER BASED TRIP REDUCTION 

(A summary description of this deleted TCM is provided below for reference only.) 

The purpose of TCM 2 was to decrease motor vehicle emissions by reducing the use of 

single occupant vehicles for commuting to work sites and employment centers in the Bay 

Area. TCM 2 differs from TCM 1 in that it was a District-wide regulation through which 

employers were required to implement programs to reduce employee vehicle trips. TCM 

1 consists of entirely voluntary efforts by Bay Area employers to promote the use of 

commute alternatives by their employees 

During the mid-1980’s, the Air Resources Board determined that employer-based trip 

reduction rules were a reasonably available transportation control measure in 

accordance with the California Clean Air Act (CCAA). In response to this CCAA 

mandate, the Air District adopted Regulation 13, Rule 1, Trip Reduction Requirements 

for Large Employers in December 1992. 

Regulation 13, Rule 1 applied to all employers at work sites with 100 or more 

employees. The rule divided the region into four geographic zones and established 

annual performance objectives for each zone. A failure to achieve the performance 

objectives was not considered a violation of the rule; however, it did trigger the 

requirement to submit an Employer Trip Reduction Plan or an Alternative Emission 

Reduction Program. The conventional Plan included trip reduction measures to reduce 

the number of employees commuting to the work site in single occupant vehicles. An 

Alternative Emission Reduction Program achieved emission reductions through other 

means, such as a vehicle buy-back or scrappage program. 

In addition to directly administering the rule, TCM 2 was also implemented by the Air 

District through multiple efforts to reduce commute trips to smaller work sites and 

employment centers that were not subject to Regulation 13, Rule 1. The Air District 

pursued this through informational and outreach efforts directed toward smaller 

employers and employment centers (i.e. multi-tenant facilities). The Air District also 

allocated Transportation Fund for Clean Air grants, as appropriate, to projects and 

programs that benefited trip reduction efforts at smaller work sites. 

However, TCM 2 was suspended in 1995 by Senate Bill 437 (Lewis). SB 437 prohibited 

air districts from requiring mandatory employer-based trip reduction programs. 
Bay Area 2005 Ozone Strategy D - 8 Final Adopted – January 4, 2006 

TCM 3: IMPROVE LOCAL AND AREAWIDE BUS SERVICE 

Purpose 

This TCM will help to reduce motor vehicle trips, vehicle miles traveled, and mobile 

source emissions by maintaining and improving the Bay Area’s extensive bus system, 

and by funding replacement of diesel buses with clean fuel buses and retrofits of diesel 

buses with emission control devices. 

Background 

TCM 3 will increase the attractiveness of local and regional bus service by ensuring the 

system is well maintained, adding more service as revenues permit, and developing new 

service concepts (such as enhanced bus, Bus Rapid Transit and Regional Express 

buses) to better serve existing markets and fill in regional transit gaps. There are 26 

transit operators in the Bay Area that provide local and regional bus service. Each 

operator must tailor its service to local conditions. Cumulatively, these operators 

provided about 94 million revenue miles of bus service in FY 2002-2003. Fixed route 

bus service accounts for approximately 66 percent of all transit riders in the Bay Area. 

Certain elements of this TCM – e.g., express bus, enhanced bus, clean fuel buses – will 

reduce motor vehicle emissions; elements regarding maintenance of the current system 

seek to assure that existing emission benefits continue. 

MTC's long range Regional Transportation Plan (RTP) dedicates significant funding to 

maintaining existing bus facilities and vehicles, but capital and operating shortfalls will 

still remain to meet future needs. Also, transit operators will be hard pressed to expand 

service without new revenues. Recent financial conditions have caused many operators 

to curtail service and/or raise fares. Therefore, the RTP does not anticipate significant 

improvements to local bus routes at this time, other than some of the improvements 

discussed below. 

Two examples of recent service improvements which would be continued and expanded 

under this TCM are the enhanced bus/BRT concepts being developed by AC Transit, 

Muni, and Santa Clara VTA and the Regional Express Bus Program funded with State 

transportation dollars. 

Mobile source emissions are controlled through fuel and engine regulations. Recent 

amendments to the diesel fuel standards require that sulfur content of diesel fuel be 

reduced from the current 500 ppm to 15 ppm beginning in June 2006. In June 2004, 

ARB adopted modifications to the fleet rule for transit agencies to allow for the purchase 

of diesel hybrid electric buses by diesel-path transit agencies. Please refer to Section 2 

of the main Ozone Strategy document for more information on state and national mobile 

source programs that impact transit buses. 

The Air District funds replacement of diesel buses with clean fuel buses through the 

Transportation Fund for Clean Air. Clean fuel buses meet specified emission standards 

and do not use diesel as their primary fuel. The Air District also funds retrofits of diesel 

buses to reduce emissions from existing diesel bus engines. 
Bay Area 2005 Ozone Strategy D - 9 Final Adopted – January 4, 2006 

Description 

Improvements in local bus service are determined by the individual transit operator 

boards, based on revenues available. Decisions on expanding local service must 

address both the needs of commuters as well as low-income travelers who do not have 

access to a car. As part of the 2001 Regional Transportation Plan, MTC defined a 

Lifeline Transportation Network which addresses some of these needs. 

The Regional Express Bus program was funded with $40 million in State transportation 

funds which were used to purchase about 90 buses serving 12 new regional express 

bus routes. Participating transit operators included: AC Transit, CCCTA, Fairfield/Suisun, 

Golden Gate Transit, LAVTA, Samtrans, Tri-Delta, Vallejo, and West Cat. These buses 

serve generally longer distance routes that fill in key transit gaps, and use freeway HOV 

lanes where possible to improve travel times and service reliability. 

Several transit operators are considering or have implemented enhanced bus service on 

major arterials, most notably AC Transit’s Route 72 along San Pablo Avenue. Enhanced 

bus service is a concept that can include a variety of improvements, including more 

frequent service, relocated bus stops and signal priority treatment for better schedule 

adherence, real time bus arrival information, improved signage, proof-of-payment fare 

system, multiple-door boarding, limited stops and other passenger amenities. San 

Francisco Muni has also developed a long range Vision Plan that would provide similar 

types of services along certain Muni routes. Bus Rapid Transit (BRT) includes most of 

the features of enhanced bus, and involves even more ambitious enhancements to bus 

service and would typically include dedicated lanes for bus operations as well. 

Phase 1 (2004-2006) 

• Continue to fund the timely replacement of worn out buses in local transit operator 

bus fleets; while providing flexibility to some operators to use federal funds for 

preventive maintenance (operating expenses) on a case-by-case basis. 

• Sustain the existing Regional Express Bus Program (12 routes) and expand with 

Regional Measure 2 revenues 

• Assist transit operators with further planning work on enhanced bus and Bus 

Rapid Transit concepts 

• Continue to seek new funding for MTC’s Lifeline Transportation Network, to serve 

low income communities and assist persons transitioning from Welfare to Work 

(to date, MTC has funded 32 projects through the Low Income Flexible 

Transportation (LIFT) program using federal, state, and local funds). 

• Complete retrofitting of 1,700 public transit buses with particulate traps and NOx 

catalysts. Continue Air District programs to fund the replacement of diesel buses 

with clean fuel buses and retrofitting of existing diesel buses with emission control 

technology. 

• Sustain current bus services to the three Bay Area commercial airports for air 

passengers and employees. 

Phase 2 (Beyond 2006) 

• Restoration of some local routes that were eliminated or where service was 

curtailed 
Bay Area 2005 Ozone Strategy D - 10 Final Adopted – January 4, 2006 

• Additional lifeline service as new funds become available 

• Implementation of new Enhanced Bus and Bus Rapid Transit (BRT) services 

consistent with the financial assumptions in MTC’s long range Regional 

Transportation Plan 

• Expansion of Regional Express Bus Programs in North and South Bay as defined 

in Regional Measure 2 

Travel Market Affected 

This measure would affect all intraregional travel, including commute travel, shopping, 

personal business, social and recreational travel, passenger and commute trips to 

airports, and school trips. 

Effectiveness 

Emission reductions are based on the new Enhanced Bus, BRT, and Regional Express 

bus services expected to be operational in 2006 and 2015. The calculations reflect the 

number of new transit riders expected to use the services, mode of access, and 

proportion of riders who are transit dependent and do not own cars. Additionally, the 

2006 calculations include the reductions from MTC’s efforts to retrofit the regional bus 

fleet with devices to lower NOx and particulates: 

 

 ROG NOx

 2006 0.42 tpd 1.13 tpd 

 2015 0.15 tpd 0.13 tpd 

Cost 

The cost of restoring and expanding local bus service cannot be estimated at this time. 

Capital costs for the existing Regional Express Bus Program and various AC Transit, 

Muni and VTA enhanced bus and Bus Rapid Transit programs are shown below; 

operating costs cannot be estimated at this time: 

• Regional Express Buses North and South Improvements: $19.5 million (funded 

by Regional Measure 2) 

• AC Transit BRT and Enhanced Bus, Phase 1: Telegraph Avenue/International 

Boulevard Corridor: $167.0 million 

• AC Transit BRT and Enhanced Bus, Phase 2: Telegraph Avenue/International 

Boulevard Corridor: $164.4 million 

• Muni BRT/Transit Preferential Streets (TPS) Program (includes Geary Street 

Corridor BRT project, also may include BRT along Van Ness Avenue and Potrero 

Avenue corridors): $280 million 

• VTA BRT Corridor: El Camino Real (Line 22) Phases 1 and 2: $7.0 million 

• VTA BRT Corridor: Along Stevens Creek Boulevard, El Camino Phase IIIB and 

Monterey Highway: $46.0 million 

• MTC Lifeline Transportation Program: $216 million committed over the 25-year 

horizon of the Transportation 2030 Plan 
Bay Area 2005 Ozone Strategy D - 11 Final Adopted – January 4, 2006 

Impediments

According to MTC’s latest financial estimates from the Transportation 2030 Plan, Bay 

Area transit bus operators will have combined funding shortfalls of approximately $1.3 

billion in operating and $1.4 billion in capital replacement over the next 25 years (some 

of these transit operators operate both bus and rail service). Thus restoring service that 

has been cut and expanding service will require new funding. New revenues may be 

available in the future from higher gas taxes, bridge tolls, and voter approved sales tax 

revenues in individual counties. 

Other Impacts

An improved bus system will offer more mobility choices for Bay Area travelers, provide 

a better transit network for those without a car, and reduce vehicle use. The Lifeline 

Transportation Network improves mobility options for low-income households. 

Reductions in vehicle travel will have corollary benefits in terms of saving energy, 

reducing greenhouse gases, and improving water quality through reduced runoff of oil 

laden water from roads. 
Bay Area 2005 Ozone Strategy D - 12 Final Adopted – January 4, 2006 

TCM 4: UPGRADE AND EXPAND LOCAL AND REGIONAL RAIL SERVICE 

 

Purpose 

This TCM will reduce motor vehicle trips, vehicle miles traveled and mobile source 

emissions by upgrading and expanding existing rail systems (BART, MUNI, VTA and 

Caltrain) and developing new rail service in the North Bay. This TCM will be most 

effective if implemented in conjunction with transit-oriented development near new and 

existing rail stations that provides for high density and mixed use development (see TCM 

15) and with transit access improvements (see TCM 5). 

Background 

The Bay Area rail system has been continuously expanded over the past several 

decades. Rail systems provide about 72 million revenue vehicle miles of service and 

carry 32 percent of Bay Area transit riders in FY 2002-03. This TCM includes new 

service expansions and upgrades that have been studied and included in local and 

regional rail programs. MTC’s Resolution 3434 Regional Transit Expansion Program 

includes nine new rail extensions and significant rail service expansions and 

enhancements. If fully implemented, the Resolution 3434 program would create 160 new 

route miles of rail and other bus and ferry improvements at a cost of around $12 billion. 

(Note: Resolution 3434 was adopted as part of the 2001 Regional Transportation Plan, 

and then subsequently updated as part of the Transportation 2030 Plan.) Funding for 

Resolution 3434 is based on a combination of federal aid, state funding, local sales tax 

revenues, and other local sources. (For example, Regional Measure 2, approved by 

Bay Area voters in March 2004, provides funds from increased bridge tolls to several rail 

expansion projects.) The long-term capital replacement costs of sustaining the rail 

system are substantial and exceed those of the bus system due to the need to maintain 

the tracks and other fixed plant facilities. Addressing ongoing maintenance and 

operations costs presents significant challenges for Bay Area transit operators. 

Description 

Phase 1 (2004-2006) 

• Muni Metro Third Street Light-Rail Project: light-rail extension to Bayview Hunters 

Point (Phase 1, initial operating segment) 

• Caltrain Express/Rapid Rail Phase 1 (“Baby Bullet”) to San Francisco 

• Vasona Corridor light-rail extension from downtown San Jose to Winchester 

Boulevard in Campbell 

Phase 2 (Beyond 2006) 

• BART extension to Warm Springs 

• BART-Oakland International Airport Connector 

• Muni Metro Third Street Light-Rail Project: light-rail transit extension to Chinatown 

(Phase 2, Central Subway) 

• Caltrain Express Tracks Phase 2 

• Caltrain Downtown Extension/ Transbay Terminal Replacement 

• Caltrain Rapid Rail Phase 2/ Electrification from San Francisco to Gilroy 
Bay Area 2005 Ozone Strategy D - 13 Final Adopted – January 4, 2006 

• BART/East Contra Costa Rail Extension 

• BART extension into Santa Clara County 

• Downtown/East Valley: Santa Clara/Alum Rock corridor and Capitol Expressway 

light-rail extension to Nieman Boulevard 

• Sonoma Marin Area Rail Transit District (SMART) commuter rail project 

• Capitol Corridor Phase 1 Intercity Rail Service: track capacity/frequency 

improvements from Oakland to San Jose designed to allow 16 daily round trips 

between Oakland and Sacramento/San Jose 

• Capitol Corridor Phase 2 

• Dumbarton Rail Corridor Phase 1 (diesel locomotive service connecting BART 

and Caltrain over a rebuilt Dumbarton rail bridge) 

• ACE service expansion to eight trains 

MTC has adopted policies to encourage supportive local land use plans and policies for 

areas near rail transit extensions. As part of the Transportation 2030 Plan, MTC 

adopted transportation/land-use principles to encourage local development that makes 

these rail investments more cost effective. 

Travel Market Affected 

This measure would affect all types of intraregional travel, including commute travel, 

shopping, personal business, social and recreational trips, school trips, and travel to 

airports. 

Effectiveness 

Emission reductions are based on the new rail services expected to be operational in 

2006 and 2015. The calculations reflect the number of new transit riders expected to use 

the services, mode of access to the rail stations, and proportion of riders who are transit 

dependent and do not own cars. The effectiveness of TCM 4 in reducing vehicle travel 

and emissions will be enhanced by implementing transit-oriented development near 

stations and station access improvements. 

 ROG NOx

 

 2006 0.23 tpd 0.21 tpd 

 2015 0.15 tpd 0.12 tpd 

Cost 

The Phase 1 improvements are under construction and will be operational before 2006. 

The Phase 2 improvements are in various stages of implementation, and are mostly 

contained in MTC’s Resolution 3434 program. Aggregate capital costs for the Phase 1 

and Phase 2 programs are listed below as included in MTC’s Transportation 2030 Plan: 

 

Phase 1: $947.0 million 
Bay Area 2005 Ozone Strategy D - 14 Final Adopted – January 4, 2006 

Phase 2: $12.0 billion (approximately $10.0 billion of this is committed funding) 

Impediments 

Upgrade and expansion of region’s rail systems will require that operators first be able to 

continue to maintain and operate their existing systems. Therefore, given the transit 

capital and operating shortfalls projected in MTC’s Transportation 2030 Plan, most of the 

new rail expansions will be contingent on new sources of capital and operating funds, 

such as Regional Measure 2 (approved by voters in March 2004); new local sales tax 

measures approved by voters in Contra Costa, Marin, Sonoma, and San Mateo counties 

in November 2004; and federal earmarks from the SAFETEA bill that was signed into 

law on August 10, 2005. 

Other Impacts 

Construction of various rail projects will have environmental impacts which are analyzed 

in the individual project level EIRs (including short term emissions from construction 

activities). Construction of new rail systems will create jobs and provide an economic 

stimulus to the Bay Area. Co-location of higher density development near rail systems 

will prove a benefit to overall regional mobility. Rail systems will generally improve the 

reliability of commute and other trips because they operate on their own dedicated right 

of way. Passengers accessing new rail stations by car could create localized congestion 

around the stations, but this can be mitigated by measures that promote the use of 

feeder buses, employer shuttles, walking, and bicycling to transit stations (e.g., TCM 5). 
Bay Area 2005 Ozone Strategy D - 15 Final Adopted – January 4, 2006 

TCM 5: IMPROVE ACCESS TO RAIL AND FERRIES 

Purpose 

TCM 5 will reduce motor vehicle trips, vehicle miles traveled and mobile source 

emissions by reducing auto trips used to make short access trips to rail stations and 

ferry terminals and by increasing transit ridership by improving access to transit. This 

measure will expand feeder buses and shuttles, and improve bicycle and pedestrian 

access. By improving rail and ferry access options, these systems will become more 

convenient and there is a greater likelihood people will choose transit for their overall trip 

instead of a car. This measure will complement TCMs 3, 4, 6 and 7. 

Background 

The Bay Area’s extensive investment in rail will be maximized if there is convenient 

access to the stations and terminals. Often access is constrained because of limited 

parking and because transit service to stations may be infrequent or not serve nearby 

destinations. Walking and bike access may be unsafe or difficult due to local traffic 

conditions, inadequate bicycle parking, terrain or other obstacles. The same issues 

apply to existing and potential new ferry terminals that would be developed by the Water 

Transit Authority in the future. 

From the standpoint of air quality, short station access trips by autos present particular 

problems and opportunities. Motor vehicle emissions are much higher when a cold 

engine has just been started (“cold start emissions”). Therefore, much of the air quality 

benefit of transit is negated if riders drive to the station. On the other hand, since most 

users of transit generally live within a few miles of the transit service, there is 

considerable potential for alternative access options other than by car. Feeder bus and 

shuttles, walking, and biking are the principal options. Extensive feeder bus service 

already exists to many rail stations, so the opportunities for further improvement may be 

limited, and new service can be expensive. In the last ten years employers, cities, 

universities, hospitals, transit agencies and others have developed more than 150 

shuttles directly linking rail stations with key nearby destinations. Walking and biking 

improvements have been a recent focus of public attention, including the Safe Routes to 

Transit concept. Currently only about 2 percent of BART’s riders ride bikes to BART. 

Another new station access concept that is currently being explored is the use of “station 

cars” for short trips. Station cars could be reserved in advance by transit riders and used 

for the “last mile” of a passenger’s trips from the station to their destination, where bus 

service, walking, or other means of transportation would take too long or be too 

inconvenient. Ideally, the station cars themselves would be low emission vehicles to 

reduce air emissions. 

Improved rail/bus connectivity at key transit hubs is another aspect of improved access. 

MTC is currently evaluating improvements to regional transit connectivity in an ongoing 

study, and it is likely that there will be station specific recommendations for these hubs 

addressing signage, transit information, or specific physical modifications. 
Bay Area 2005 Ozone Strategy D - 16 Final Adopted – January 4, 2006 

Many of these station access concepts were recently evaluated by MTC as part of 2001 

Ozone Attainment Plan Further Study Measure 5 (FSM 5), and findings from the study 

are included in this TCM. 

Description 

Bike/Walk Access: Improvements would include bicycle routes and lanes near transit 

stations, with connections to local and regional bike route networks; increased secure 

bicycle storage at transit, with bike stations at certain hubs; sidewalks, crosswalks, and 

direct pedestrian connections to nearby neighborhoods and activity centers, and better 

signage of bike/pedestrian access routes. This range of improvements is sometimes 

referred to as “Safe Routes to Transit”. 

Feeder Buses: Improvements would primarily focus on the transfer arrangements 

between rail and ferries and the buses to make the transfer more convenient. New ferry 

routes and terminals and new rail stations will need to be developed in collaboration with 

local transit operators who will provide the feeder bus service. 

Station Cars: These are vehicles that could be located at rail stations for use by transit 

riders who need to travel to destinations near the stations, but which do not have good 

transit service or are too far or inconvenient for walking/biking. Station cars would be 

shared vehicles that could be checked out in advance. Transit riders would pay for the 

use of the vehicle depending on how far it is driven and how long it is checked out. 

Station cars would need to meet the most stringent vehicle emissions requirements for 

maximum air quality benefit. 

Shuttles: Bay Area shuttles are operated by a diverse group of businesses, cities, 

schools and transit operators. In order to sustain successful shuttles over the long term, 

stable funding sources, particularly operating subsidies, will be pursued. There are 

additional opportunities to establish new shuttle services, where the required 

partnerships can be developed. MTC analyzed new shuttle service in the 2001 Ozone 

Attainment Plan (Further Study Measure 5) and will review “last mile” shuttle potential in 

the 2005 Regional Transit Connectivity Plan required by Regional Measure 2. 

Phase 1 (2004-2006) 

• Develop demonstration program for station car and bike station concepts at 

selected regional transit centers 

• Determine long term funding needs for existing shuttles, encourage better 

coordination between shuttles and transit operators, and examine funding 

options for new and existing shuttles 

• Begin implementation of Safe Routes to Transit to improve bicycle and 

pedestrian access (RM 2 to provide about $20 million) 

• Complete Regional Transit Connectivity Plan (MTC is required to complete plan 

by May 2006 under RM2 (as revised pending legislative action)). 

Phase 2 (Beyond 2006) 

• Continue Safe Routes to Transit improvements 

• Continue and expand other successful concepts from Phase 1 
Bay Area 2005 Ozone Strategy D - 17 Final Adopted – January 4, 2006 

• Develop a master plan for implementation of bike stations or other innovative 

secure bicycle storage strategies at key transit hubs. 

• Implement most cost effective new shuttles where funding is available. 

The Air District’s Transportation Fund for Clean Air (TFCA) funds public agency 

improvements to bicycle and pedestrian access, and local feeder bus or shuttle service 

to rail and ferry systems. The TFCA program funds several shuttle projects currently 

operating in the Bay Area. The amount of TFCA funds allocated to these routes 

generally decreases over time, and there is no guarantee these routes will continue to 

receive TFCA funding in the future. Efforts should be made to capture and retain the 

transit market created by the shuttle routes. The Air District will work with transit 

operators to develop TFCA applications for new shuttle and feeder bus service to rail 

and ferry stations that reduce emissions. 

The Air District’s TFCA program and MTC’s Transportation for Livable Communities 

program fund bicycle and pedestrian improvements at transit facilities. 

Cost 

The cost of expanding fixed route feeder bus service is not known, and would depend on 

the operator and which routes would be expanded. Current operating costs vary 

between $76 and $114 per revenue service hour. 

The cost of providing shuttles varies as well. Recent estimates for leasing a shuttle 

vehicle run between $35 and $75 per hour of service. 

A very large station car program (1,000 cars) would cost approximately $25 million for 

the cars (assume hybrid/SULEV type vehicles) and about $5 million per year in 

administration costs. 

The cost of adding bicycle storage at transit stations depends on whether the storage is 

provided as an enclosed locker or through a more substantial Bike Station arrangement. 

Lockers are fairly inexpensive, costing about $1,500. Bike Station costs vary 

considerably depending on the services provided, ranging from under $100,000 for the 

Berkeley BART bike station to over $700,000 for the downtown S.F. Caltrain bike 

station. Assuring long term operating costs for bike stations also must be considered. 

A comprehensive program of Safe Routes to Transit to BART stations could cost over 

$45 million, as estimated by one bicycle advocacy group. 

Effectiveness 

Emission reductions associated with TCM 5 are based on the following programs and 

assumptions. 

1) An increase in feeder bus trips by riders who formally drove to rail/ferry 

2) Additional bicycle access trips based on provision of new storage and safe routes to 

transit. 

3) 24 new shuttle services to rail and ferries 

4) 1000 car station car program 
Bay Area 2005 Ozone Strategy D - 18 Final Adopted – January 4, 2006 

 ROG NOx

 

 2006 0.17 tpd 0.15 tpd 

 2015 0.06 tpd 0.05 tpd 

Impediments 

The ability of local transit operators to increase fixed route feeder bus service depends 

on availability of new operating funds, which are scarce. While employers could 

underwrite the cost of shuttles, most of the time the costs are prohibitively expensive 

unless the employee pays a large portion. Comprehensive efforts to improve bike and 

walk access to a number of rail stations, will require new funding sources. An initial 

demonstration program for station cars at 4-6 stations may be able to access existing 

fund sources (CMAQ, RM2) 

Travel Market Affected

TCM 5 will affect all types of trips, including commute travel, shopping, personal 

business, social and recreational travel, and school trips. 

Other Impacts

This measure will improve traveler safety for pedestrians and bicyclists. Additional 

feeder and shuttle services would produce emissions that could be mitigated by 

retrofitting vehicles with catalysts (if diesel powered), or by purchasing CNG or electric 

vehicles. The measure could reduce local auto traffic and congestion around stations 

and alleviate potential auto parking shortages. 
Bay Area 2005 Ozone Strategy D - 19 Final Adopted – January 4, 2006 

TCM 6: IMPROVE INTERREGIONAL RAIL SERVICE 

Purpose 

TCM 6 will reduce motor vehicle travel and emissions for longer distance interregional 

trips by upgrading and expanding rail service in the Capitol Corridor (SacramentoOakland-San Jose) and the Altamont Corridor (Altamont Commuter Express between 

Stockton/Tracy and San Jose). It also includes initiation of new services as funding 

becomes available (e.g., potential High Speed Rail service between Los Angeles and 

the Bay Area). 

Background 

Capitol Corridor service between Sacramento and the Bay Area was initiated by the 

State in 1991 and management of the service was turned over to the Capitol Corridor 

Joint Powers Board in 1996. Currently there are 12 roundtrips a day between 

Sacramento and Oakland, with four continuing to San Jose. In recent years ridership 

growth on the Capitol Corridor has been among the highest in California for similar 

services. 

The Altamont Commuter Express (ACE) from Stockton/Tracy, through 

Livermore/Pleasanton, to San Jose started operating in 1998. ACE provides three daily 

roundtrips a day, with the largest volume of passengers getting on and off at the Great 

America station serving Silicon Valley. 

Another intercity service, Amtrak’s San Joaquin trains, provides four daily roundtrips 

between Oakland and Bakersfield with two connecting feeder buses serving Stockton. 

Description 

MTC’s Resolution 3434 Regional Transit Expansion Program includes funding for 

expanding existing intercity rail services as shown below. In addition, studies continue 

on a California High Speed Rail system between Los Angeles and the Bay Area, with 

potential funding pending a future statewide ballot measure. No significant changes in 

service are anticipated between now and 2006. 

Phase 2 (Beyond 2006) 

• Increase Capitol Corridor service to 16 daily roundtrips 

• Increase Altamont Corridor Express service to 8 daily roundtrips. 

• Track enhancements for both Capitol Corridor and ACE for more reliable service. 

• Potential High Speed Rail Service between Los Angeles and the Bay Area 

Additional services that may be studied and considered in the future include service from 

San Benito County and Monterey to the San Jose area.

Travel Market Affected 

TCM 6 will affect mostly interregional trips, but will also serve intraregional travel over 

portions of the various corridors. 
Bay Area 2005 Ozone Strategy D - 20 Final Adopted – January 4, 2006 

Effectiveness 

Emission reductions are based on ridership estimates for the Phase 2 Capitol and ACE 

service improvements that would be implemented by 2015. NOx estimates take into 

account the offsetting emissions from the diesel locomotives that power the additional 

trains. 

 ROG NOx

 

 2015 0.03 tpd (0.30) tpd increase

Cost 

The capital costs of the Capitol Corridor improvements in MTC’s Resolution 3434 Transit 

Expansion Program are estimated to be $245 million (2004 dollars). The capital costs 

for ACE improvements are estimated to be $128 million (2004 dollars). Higher levels of 

service will be contingent on finding additional sources of operating revenues. The total 

cost of the statewide high-speed rail system is about $37 billion. The California High 

Speed Rail authority plans to seek voter approval of $9.9 billion in general obligation 

bonds to develop the initial Los Angeles, San Francisco, and Sacramento segment. 

Impediments 

As with other proposed transit improvements, there are funding shortfalls on the capital 

and operating side for intercity rail enhancements that are addressed in MTC’s 

Transportation 2030 Plan. Because the intercity services use privately owned railroad 

tracks, increasing service can lead to lengthy negotiations with the railroad owner over 

the costs of making necessary track improvements in order to provide more capacity and 

allow for more scheduling flexibility. 

Other Impacts 

TCM 6 will improve travel options between the Bay Area and neighboring counties, and 

reduce auto trips in two of the region’s most heavily congested corridors, I-80 and I-580. 

Diesel locomotive emissions can be reduced by conversion of the locomotives to clean 

diesel or alternative fuels, or possibly through the use of catalytic devices. 

(Electrification of intercity lines would not be cost effective at current ridership levels.) 

Reduced auto use will lower fuel consumption and decrease greenhouse gas emissions. 
Bay Area 2005 Ozone Strategy D - 21 Final Adopted – January 4, 2006 

TCM 7: IMPROVE FERRY SERVICE 

Purpose 

TCM 7 will reduce emissions from Transbay auto trips, which tend to be longer in length, 

and will also reduce auto traffic in highly congested bridge corridors. New high-speed 

ferry service will offer a transportation alternative for crossing the Bay that is reliable, 

comfortable and provides a pleasant and relaxing travel experience. New ferry 

technology will result in overall emissions that are lower than those attributable to current 

passenger ferry service. 

Background 

Freeways and bridges that serve Transbay travel are already heavily congested in the 

peak periods, and during portions of the weekend. The number of trips crossing the Bay 

is projected to grow at a higher rate than the regional average over the next 25 years. 

Existing ferry services have all been expanded with newer, high-speed vessels on the 

Larkspur, Vallejo and Alameda/Oakland routes to San Francisco. In 1999 state 

legislation created the new Bay Area Water Transit Authority (WTA) to plan and operate 

new ferry routes beyond those currently in service. Their work produced an 

Implementation and Operations Plan in 2003, which recommended an expansion of 

existing ferry service and an initial set of routes shown below: 

• Pittsburg/Antioch-Martinez-San Francisco 

• Hercules/Rodeo-San Francisco 

• Richmond-San Francisco 

• Berkeley-San Francisco-Mission Bay 

• Oyster Point (South San Francisco)-San Francisco 

• Redwood City-San Francisco 

• Treasure Island – San Francisco 

Description 

TCM 7 contains several elements. Phase 1 (2004-2006) primarily involves initial 

planning for new ferry service. A new low emission ferry is expected to start service 

between Vallejo and San Francisco during Phase 1. Phase 2 includes the start up of 

these services as well as further study into other possible new ferry service. 

Phase 2 (Beyond 2006) 

• Expansion of existing ferry service between Oakland/Alameda and San Francisco 

(two new vessels) 

• New intermodal transit hub at Vallejo Ferry Terminal 

• Expansion of service between Larkspur and San Francisco 

• New Berkeley/Albany service to San Francisco (two vessels) 

• New South San Francisco service to San Francisco (two vessels) 

• New Richmond service to San Francisco 

• Expand berthing capacity at the Ferry Building in San Francisco 

• Feeder bus service to provide access to ferries (see also TCM 5) 
Bay Area 2005 Ozone Strategy D - 22 Final Adopted – January 4, 2006 

• Expand carrying capacity for bicycles on ferries (see also TCM 9) 

• Hydrogen fuel-cell ferry demonstration project 

• Assist operators in converting vessels to lower emissions 

Phase 2 will also include the continuing study of other new services, including: 

• Potential new service between Martinez, Redwood City, Antioch/Pittsburgh, to 

San Francisco; 

• Further study of using the Port of Sonoma 

• Future study of ferry service expansion to Moffett Field 

• Potential new service for passengers and cargo between Oakland and San 

Francisco airports 

MTC has worked with ferry and other transit operators to develop transfer arrangements, 

including low cost transfers and joint passes (see TCM 13). 

Travel Market Affected 

Transbay trips across the Bay bridges are projected to increase by 40 percent over the 

next 25 years, higher than the Bay Area average. This measure will focus primarily on 

peak period commute travel, when congestion on bridges is greatest. It will also provide 

an additional transportation option for shopping, personal business, and social and 

recreational trips. Tourism is also expected to generate a number of new riders for 

many of the ferry services. 

Effectiveness 

TCM 7's emission reductions are based on MTC’s analysis of the seven new services 

above. Emissions from the ferry vessels would be lower than those attributable to 

current passenger ferry service, given the WTA’s commitment to the operate ferries that 

are 85 percent cleaner than the EPA’s 2007 Tier 2 standards for marine vessels. Phase 

2 improvements are expected to yield the following emission reductions: 

 ROG NOx 

 

 2015 0.06 tpd 0.06 tpd 

Cost 

New ferry service requires funding for vessels, terminals and parking, and feeder bus 

service. Funds for several new services (vessels and operating funds) were provided 

through voter approval of Regional Measure 2 in March 2004. In addition, the WTA 

received a $10.0 million federal earmark for capital investments from the SAFETEA bill 

that was signed into law on August 10, 2005. Local jurisdictions together with County 

Congestion Management Agencies will need to prioritize funding for terminals in their 

local funding process. Future expansion of existing ferry services is uncertain given 

current transit funding problems. 
Bay Area 2005 Ozone Strategy D - 23 Final Adopted – January 4, 2006 

The capital cost of the seven new ferry routes (as estimated by WTA) is $175 million 

(plus the cost for fuel cell project to Treasure Island), and the net annual operating cost 

is estimated to be $90 million. 

Impediments 

Passage of Regional Measure 2 provides partial funding for the 

Oakland/Alameda/Harbor Bay, Berkeley/Albany, and South San Francisco routes. 

Planning for new ferry terminals, including environmental review and obtaining the 

necessary permits, could be lengthy depending on the site. Funding for feeder bus 

service to the new terminals will also need to be identified (see TCM 5). 

Other Impacts 

System level environmental impacts of an expanded ferry system were recently 

analyzed by the WTA in a comprehensive EIR; impacts of individual terminals would be 

assessed in separate project level EIRs. New ferry service could impact existing transit 

operators by shifting some existing passengers to water transit, resulting in some 

revenue diversion. New ferry terminals may result in traffic impacts on neighborhoods 

near the terminals. There could also be an increase in cold start emissions from the 

increase in passenger vehicles parked at ferry terminals during the workday. 

An extensive system of ferries could add to the attraction of the Bay Area as a tourist 

destination and provide an economic stimulus. 

Another major advantage of an expanded ferry system would be the role ferries would 

play in the event of a future earthquake that damaged one or more Bay bridges or 

BART. If an earthquake were to strike the Bay Area (highly probable over the next 30 

years), ferries could play a vital role in post quake evacuation and in the immediate to 

longer term recovery period. 
Bay Area 2005 Ozone Strategy D - 24 Final Adopted – January 4, 2006 

TCM 8: CONSTRUCT CARPOOL / EXPRESS BUS LANES ON FREEWAYS 

Purpose 

The California Air Resources Board considers an HOV lane network to be a "reasonably 

available" transportation control measure. This TCM could help reduce mobile source 

emissions by continuing the development of an integrated Bay Area HOV lane system 

that will encourage use of carpools, vanpools and other high occupancy vehicles 

(HOVs), such as express buses. Well-managed HOV lanes will encourage commuters 

and other trip makers to use high occupancy modes by providing faster more reliable 

travel compared to travel in the adjacent mixed flow freeway lanes. HOV lanes act in 

combination with other factors that influence carpooling and transit, such as free 

passage on the Bay bridges and limited or high cost parking in some areas. 

Background 

The Bay Area currently has 300 lane miles of HOV lanes (in 2000), including freeways 

and expressways (in Santa Clara County). Another 100 lane miles are programmed in 

MTC’s current Transportation Improvement Program (2005 TIP). Monitoring of existing 

HOV lanes by Caltrans indicates that most all of these lanes carry considerably more 

people than the adjacent mixed flow lanes. Under state law, alternatively fueled vehicles 

identified with a sticker may also use the HOV lanes. 

MTC periodically reviews HOV lane performance and updates the Bay Area HOV Lane 

Master Plan. Recommended HOV lane improvements are then included in the Regional 

Transportation Plan and programmed in the TIP. The latest HOV Master Plan would 

expand the system to 534 lane-miles. The HOV Master Plan also addressed other 

related issues, such as HOV lane occupancy requirements, hours of operation, and 

enforcement. The latest update (February 2003) also included a comprehensive 

analysis of regional emissions from different HOV lane configurations, including 

conversion of existing lanes to HOV lanes, raising occupancy requirements to 3+ on all 

HOV lanes, and providing exclusive lanes for express buses. 

Description 

The measure primarily addresses the physical configuration of the HOV lane system and 

operational requirements. Express bus service is addressed under TCM 3. The Phase 

1 HOV lanes are those included in MTC’s current TIP, whereas the Phase 2 lanes are 

those in the long range Regional Transportation Plan. 

Phase 1 (2004-2006) 

• 100 new miles of HOV lanes programmed in 2005 TIP 

• New HOV to HOV lane connector at Rt 101/85 interchange in Mountain View 

• New park and ride lots at various locations 

Phase 2 (Beyond 2006) 

The financially constrained element of the Transportation 2030 Plan includes funding for 

an additional 200 lane miles beyond those in the TIP, plus other park and ride lot 

projects. Another 200 lane miles is proposed in the vision element of the Transportation 
Bay Area 2005 Ozone Strategy D - 25 Final Adopted – January 4, 2006 

2030 Plan as part of a proposed region-wide high-occupancy toll network. Special 

attention should be paid to express bus operations to maximize benefits for transit. 

Monitor and adjust occupancy requirements and hours of operation to maximize air 

quality and mobility benefits. 

Phase 2 will also include the further development of HOV lane support infrastructure and 

programs, including strategically located park and ride lots, HOV bypass lanes at 

freeway on ramps, direct access HOV ramps (“slip ramps”) for carpools and buses to 

major employment centers, HOV-to-HOV lane freeway connectors to better integrate the 

entire network, possible use of freeway shoulders by express buses to bypass 

bottlenecks, and active enforcement of occupancy and use restrictions. 

Increases in certain express bus services will be considered to maximize person 

carrying capacity of HOV lanes. TCM 3 discusses regional express bus service, which 

would be operated on HOV lanes in the Bay Area. 

Average vehicle occupancy of all HOV lanes should be carefully monitored. MTC’s HOV 

Lane Master Plan predicts that by 2010, seven corridors will have HOV lane volumes in 

excess of the practical capacity of 1,600 vehicles per hour, and by 2025 15 out of 18 

HOV corridors will exceed this volume. An increase in vehicle occupancy from 2+ to 3+ 

would normally be considered after other feasible corridor management strategies 

(Express Bus, expanded CHP enforcement, ramp metering, etc.) have been deployed. 

As congestion continues to increase in the Bay Area and the length of the peak period 

expands, the Bay Area should consider moving toward a consistent regionwide set of 

hours (this would correspond to the current maximum spread of 5:00 a.m. to 10:00 a.m. 

and 3:00 p.m. to 7:00 p.m.). Additionally, there may be selected corridors and travel 

directions where hours of operation could be extended to mid-day hours (10:00 a.m. to 

3:00 p.m.) based on travel conditions in the mixed flow lanes and the number of transit, 

carpools and vanpool users who could take advantage of these lanes. 

Travel Market Affected 

TCM 8 is aimed primarily at commute trips, which account for the majority of trips during 

the morning and evening peak periods. In the future, HOV lanes should help to increase 

average vehicle occupancy for other types of trips as hours of operation are expanded 

(e.g., shopping, personal business, school, recreational). 

Effectiveness 

The emission estimates below are based on the new HOV lane miles programmed in the 

TIP. 

 ROG NOx

 2015 0.37 tpd 0.39 tpd 

Cost 
Bay Area 2005 Ozone Strategy D - 26 Final Adopted – January 4, 2006 

The cost of the HOV lanes programmed in the 2005 TIP is $2.1 billion ($256.0 million is 

programmed in FY 2005-2007). The cost of additional lanes in the Transportation 2030 

Plan is about $1.6 billion for HOV projects in the financially constrained element and 

over $600 million for HOV projects in the vision element. (Note: Many HOV projects are 

part of larger widening projects; total project costs are cited.) New county sales tax 

measures, as passed by voters in November 2004, will provide funding for new HOV 

lanes in some counties (e.g., Sonoma Route 101). Furthermore, federal earmarks from 

the SAFETEA bill that was signed into law on August 10, 2005 will also help fund I-80 

HOV lanes in Solano County. 

Impediments 

A review of the history of HOV lane violation rates indicates that there has been a 

dramatic improvement in HOV lane compliance, with only one lane exceeding the 

national average. However, continuing monitoring is important to preserve public 

support, particularly in light of new legislation allowing hybrid vehicles to use HOV lanes. 

Evaluation of future HOV lane performance in the HOV Lane Master Plan indicates that 

some lanes could become overcrowded in the future, and it may be necessary to 

consider changing occupancy requirements to preserve travel time savings; however, 

public resistance to such changes may be difficult to overcome. 

Other Impacts 

Increasing the use of carpools, vanpool, and express buses will have significant payoffs 

in conserving fuel, reducing dependence on foreign oil, and lowering greenhouse gas 

emissions. TCM 8 may have a short term negative impact on air quality due to emissions 

generated during construction and increased localized congestion. 

HOV lanes outside the urban core may have some marginal impact on land use by 

making longer distance commuting more attractive. However, development decisions 

involve many other factors as well, and ABAG’s adoption of a Smart Growth land use 

scenario (see TCM 15) is intended to focus more population growth in the Central part of 

the Bay Area, where HOV lanes will provide an important augmentation to mobility. 

A well-developed HOV lane network could serve as the foundation for conversion of 

these lanes to a High Occupancy Toll Network as discussed in TCM 18. 
Bay Area 2005 Ozone Strategy D - 27 Final Adopted – January 4, 2006 

TCM 9: IMPROVE BICYCLE ACCESS AND FACILITIES 

Purpose 

Bicycles are a low cost, widely available (60 percent of Bay Area households have at 

least one bicycle) and pollution free mode of transportation. TCM 9 will reduce mobile 

source emissions by expanding bicycle facilities serving employment sites, 

educational and cultural facilities, residential areas, shopping districts, and other 

activity centers. Typical improvements would include bike lanes, routes, paths, and 

bicycle parking facilities. Accessibility of transit to bike riders is also part of this TCM. 

Background 

According to the 1995 Nationwide Personal Transportation Study, 40 percent of all trips 

are two miles or less, and two-thirds are five miles or less. One-third of Bay Area 

employees live within five miles of their worksite. These short and medium length trips 

are well suited to bicycle travel, especially in the Bay Area’s mild climate. 

While a number of factors influence people’s decisions about whether to use bicycles for 

their trip, key obstacles are the lack of safe and convenient bicycle routes and storage. 

Currently bicycles are widely used for recreational riding, but are less used as a 

commute mode, with only 1 percent of total daily trips being made by bike (compared to 

9 percent by walking), or for other trips such as shopping or school trips. Greater use 

could be expected with a variety of local and system-wide improvements. MTC’s 2001 

Regional Transportation Plan defined a regional bike network for the first time, and MTC 

has decided to set aside funding in the Transportation 2030 Plan to complete critical 

gaps in this network. 

Experience in cities such as Palo Alto, Davis, Seattle, and Portland, Oregon shows that 

bicycles can play an important role in local transportation. To obtain TDA funding from 

MTC local jurisdictions must have a Bicycle Advisory Committee to plan and prioritize 

funding for bike projects. These plans can also address related bicycle mobility and 

safety features such as signage, bike detectors at signals, safe lane widths, etc. Also, a 

number of Bay Area cities routinely incorporate bicycle improvements when maintaining 

or upgrading local streets. 

Bicyclists also use transit extensively for their longer trips, and most Bay Area transit 

systems currently accommodate bikes (though some have restrictions during peak 

commute times). Buses accommodate bikes either through front mounted racks or on 

board if they can be folded. BART and Caltrain accommodate bikes on their trains, but 

with some restrictions. The Regional Express buses accommodate bikes with front 

racks as well. 

A special issue for the bicycle community has been the provision of bike lanes on the 

Bay bridges. Bay bridges with bicycle lanes currently include the Golden Gate, new 

Carquinez Bridge, Antioch, and Dumbarton bridges. New bridges under construction 

that will include bicycle lanes are the new eastern span of the Bay Bridge (Oakland to 

Treasure Island) and new Benicia Bridge. A feasibility study has been completed of 

installing bike lanes on the western portion of the Bay Bridge (costs range from $160 
Bay Area 2005 Ozone Strategy D - 28 Final Adopted – January 4, 2006 

million to over $300 million), and a study is being conducted of bicycle access across the 

Richmond-San Rafael Bridge. 

Description 

TCM 9 would focus on improvements to the Regional Bike Network defined in MTC’s 

2001 Regional Transportation Plan. TCM 9 also supports local efforts to provide bicycle 

access and amenities and to better integrate bicycles into roadway improvement and 

Caltrans’ efforts to consider non motorized travel in all of their plans, programs, and 

projects. 

The TCM includes the following types of programs and activities: 

• MTC’s Regional Bike Plan consists of over 600 miles of bike routes. MTC’s 

Transportation 2030 Plan commits $200 million in funding to complete critical links 

and to leverage local funds to construct even more facilities. This funding is 

allocated to both bicycle and pedestrian needs. As part of MTC’s monitoring of 

the regional transportation system, MTC collects bike counts at a number of 

heavily traveled bike facilities. 

• MTC and Air District grant programs fund bicycle improvements. 

• Caltrans Deputy Director Order 64 requires Caltrans to incorporate non-motorized 

transportation options in design and construction of state highway facilities. 

• Many local jurisdictions have developed bike plans and incorporate bike facilities 

when they repair or improve local arterials (for example, in Santa Clara County). 

Improvements to bicycle access and facilities are also discussed in TCM 15, Local Land 

Use Planning and Development Strategies and TCM 20, Traffic Calming. 

Phase 1 (2004-2006) 

• Fund Regional Bike Plan improvements (specific projects TBD) 

• Develop on-line bicycle mapping tool as part of the regional 511 traveler 

information number (MTC) 

• Bike to work day promotion (MTC) 

• Funding for bike improvements included in MTC’s Transportation for Livable 

Communities (TLC) projects 

• The Air District’s TFCA program funds bicycle routes, storage and other facilities. 

• Funding for other local bicycle improvements through local sales tax measures 

and state TDA Article 3 funds 

• Fund Safe Routes to Transit improvements (see TCM 5). 

• Encourage local jurisdictions to continue to develop safe and convenient networks 

of bicycle lanes and routes. 

• Encourage local jurisdictions to provide bike racks or other secure storage in 

downtowns, shopping areas, and other activity centers. 

• Encourage local jurisdictions to require bicycle access and amenities (e.g., bike 

storage, showers and lockers, etc.) as conditions of approval of development 

proposals (see TCM 15). 

• Explore innovative bicycle programs, such as “station bike” programs or similar 

bicycle sharing programs at transit stations, town centers, other activity centers. 
Bay Area 2005 Ozone Strategy D - 29 Final Adopted – January 4, 2006 

Phase 2 (Beyond 2006) 

• Generally a continuation of the above activities, but with the potential for 

additional funding from passage of local sales tax measures for transportation in 

various counties. 

• Additional emphasis on bicycle training and safety related projects, including 

public education for both bicyclists and motorists 

Travel Market Affected 

TCM 9 will promote bicycle use (or bicycles combined with transit) for the entire range of 

local trips, including commuting, shopping, personal business, and social and 

recreational travel. The potential market for TCM 9 is significant, given that short 

distance trips of less than five miles account for the majority of all trips in the region. 

Effectiveness 

The emission reductions below represent are based on increasing the regional bike 

mode share by 3% in 2006 (i.e., from 1.0% to 1.03% of regional trips) and 10% in 2015, 

and assume a higher bicycle mode share for regional trips, assuming an aggressive 

bicycle education and development program. 

 ROG NOx

 

 2006 0.04 tpd 0.03 tpd 

 2015 0.06 tpd 0.04 tpd 

Cost 

The cost of completing MTC’s Regional Bike Plan is estimated to be $1.0 billion, and as 

mentioned above, the Transportation 2030 Plan will provide a $200 million dedicated 

source of funding to help complete this network (includes pedestrian facilities). In 

addition, Alameda, Contra Costa, and San Francisco counties have committed close to 

$240 million in transportation sales tax funds for bicycle and pedestrian needs. With the 

passage of their sales tax measures in November 2004, Marin, Sonoma, Contra Costa 

and San Mateo counties pledge another $160 million. An estimated amount of $245 

million in traditional funding sources is potentially available for nonmotorized needs over 

the next 25 years. These sources include the Transportation Development Act, the Air 

District’s Transportation Fund for Clean Air, and Caltrans’ Bicycle Transportation 

Account, and federal Transportation Enhancement funds. In addition, several bicycle 

and multi-use trail projects received federal earmarks from the SAFETEA bill that was 

signed into law on August 10, 2005, including $25.0 million for non-motorized 

transportation pilot program in Marin County. 

Impediments 
Bay Area 2005 Ozone Strategy D - 30 Final Adopted – January 4, 2006 

Widespread use of bicycles is limited by a number of factors, including the user’s 

physical ability, terrain, weather, need to carry cargo or packages, etc. Personal safety 

is another concern for riders who may not have extensive experience in riding in different 

traffic conditions, but can be addressed through training and by providing bike lanes and 

other safety improvements. Public education for motorists and cyclists to obey traffic 

laws and “share the road” would also improve safety. While most transit operators have 

formulated workable arrangements for accommodation of bikes, increased 

accommodation of bikes during peak passenger loads will still present operational 

issues for some operators. Dedicated bike lanes across some bridges may be 

extremely expensive or operationally infeasible. Bicycle accommodation at work sites 

may create additional costs for employers. 

Other Impacts 

Bicycles have low impact on the environment across all resource categories. Some 

major bike facilities may have localized environmental impacts that would be addressed 

in project specific EIRs. Since bicycles are an excellent means of physical exercise, 

TCM 9 will also promote public health. Increased bicycle use may reduce the need for 

auto parking at some employment or residential sites and transit stations. 
Bay Area 2005 Ozone Strategy D - 31 Final Adopted – January 4, 2006 

TCM 10: YOUTH TRANSPORTATION 

Purpose 

TCM 10 is designed to reduce motor vehicle travel and mobile source emissions related 

to the transportation of youths and students for school and other activities. 

Background 

Youth and students have special transportation needs. Because they have limited 

access to motor vehicles, they depend upon public transit, bicycles, walking, and being 

driven by adults. 

Due to funding constraints, a number of school districts in the Bay Area are no longer 

able to operate school bus services. MTC conducted a recent study of re-instituting 

school district bus service in Alameda County, and determined that costs would be high 

in relation to air quality benefits. In addition, no funding sources for re-instituting service 

could be identified, unless new local revenues were somehow generated in the future. 

MTC and AC Transit are participating in a program to reduce the cost of school bus 

passes for low income students within AC Transit’s service area. The goals of the 

program are to increase school attendance and access to after school activities. The 

initial year’s evaluation has been completed, but it does not appear that the air quality 

benefits are significant. (Future evaluations of a more mature program may yield 

different results.) 

Recent State legislation (Safe Routes to Schools) provides for about $20 million per year 

statewide for certain projects to provide safer pedestrian access for school children. 

This legislation is currently pending renewal to extend the program for another five 

years. 

The Air District’s Low Emission School Bus Program provides funding to school districts 

for purchasing alternative fuel school buses, replacing old diesel engines with cleaner 

engines, or installing particulate matter retrofits. 

Description 

TCM 10 will improve youth and student mobility through a variety of means: 

Phase 1 (2004-2006) - Primarily includes continuation of existing programs to: 

• Encourage walking and bicycling to school (Safe Routes to Schools program). 

• Encourage carpooling among high school students with cars (e.g., the Rides to 

School Program) (see TCM 14). 

• Establish special carpool formation services for parents, students and staff at Bay 

Area elementary and secondary schools (see TCM 14). 

• Encourage shuttle programs to provide service to schools. 

• Target Bay Area schools for greater participation in Spare the Air program. 

• Purchase new, cleaner or alternatively fueled school buses, replace old diesel 

school buses with cleaner engines or retrofit older school bus engines. 
Bay Area 2005 Ozone Strategy D - 32 Final Adopted – January 4, 2006 

Phase 2 (Beyond 2006) 

• Continue Phase 1 programs 

• Support transit ride discounts to youth and students (contingent on transit 

operators ability to financially participate in the program) 

Travel Market Affected 

According to MTC travel data, school trips account for two to three percent of total 

vehicle miles traveled in the Bay Area. TCM 10 would address this market, as well as 

youth travel outside of school hours. 

In addition to its direct impact on school trips, TCM 10 may also have an impact on 

commute trips. If additional school bus service is provided, parents who must now drop 

off their children at school while in route to work might be able to commute via 

ridesharing or transit. 

Effectiveness 

Emission reductions are largely based on reducing the number of regional auto trips 

made to schools by 2% in 2006 and 10% in 2015 due to the combined effects of the 

various programs above. 

 ROG NOx

 

 2006 0.11 tpd 0.09 tpd 

 2015 0.22 tpd 0.16 tpd 

Cost 

MTC has provided $2 million in funds to AC Transit to test a student bus pass program 

for low income students. One year of the program has been completed. In 2003, the Air 

District had approximately $3.4 million available to assist school districts in reducing 

emissions from school buses. The emission reductions shown above for clean fuel 

school buses assume maintenance of this level of funding. 

Impediments 

Full implementation of this measure depends upon additional funding to re-institute 

school district provided bus service. The Safe Routes to Schools program will need to 

be reauthorized by the Legislature for funding to continue. 

Other Impacts 

In addition to reducing emissions, TCM 10 will mitigate local traffic congestion near 

schools and provide additional safety for children walking and cycling to and from 

school. Other benefits include reduced fuel consumption and the ability of some family 

members to carpool or take transit if they do not have to take children to school. 
Bay Area 2005 Ozone Strategy D - 33 Final Adopted – January 4, 2006 

TCM 11: INSTALL FREEWAY TRAFFIC MANAGEMENT SYSTEMS 

Purpose 

TCM 11 will reduce emissions produced by stop and go congestion on Bay Area 

freeways by employing the latest traffic management technologies to improve the flow of 

vehicles throughout the day. TCM 11 is consistent with the State’s statutory definition of 

a transportation control measure as a strategy to reduce vehicle trips, vehicle use, 

vehicle miles traveled, vehicle idling or traffic congestion for purposes of reduction motor 

vehicle emissions (H&S sec 40233 (4)(d)). 

Background 

Over 60 percent of daily vehicle miles of travel (VMT) in the Bay Area occurs on 

freeways. Vehicles that are stuck in stop and go traffic conditions produce higher 

emissions than vehicles traveling at higher constant speeds. Stop and go conditions 

can result from either recurrent congestion (excess vehicle demand compared to 

roadway capacity) or accidents and other incidents (such as a disabled vehicle) that 

back up traffic for extended periods. Incidents during the peak period can be highly 

disruptive to traffic because of the greater traffic volumes at these times. Traffic flow 

conditions can be managed through measures to control the amount of traffic entering 

freeways as well as advanced incident detection and response systems. These traffic 

management strategies are critical since the projected growth in vehicle miles of travel 

will significantly exceed the expected growth in regional road capacity. 

Description 

Caltrans manages freeway operations through a comprehensive system of traffic 

advisory signs, traffic surveillance by closed circuit TV and metering of freeway on 

ramps. This traffic management system is gradually being expanded as funds are 

available. Full implementation of the Traffic Operations System (TOS) will cover 

approximately 450 miles of the Bay Area's freeways. The chief component of the 

system that will help with regular peak period congestion is ramp metering. With ramp 

metering, the flow of traffic onto the freeway can be controlled to predetermined rates to 

ensure that the vehicles entering the freeway do not overload the capacity of the freeway 

and create congested flow conditions downstream. Caltrans maintains a centralized 

Traffic Management Center (TMC), where the information is collected and processed. 

Incident detection and response is also coordinated through Caltrans TMC. Detection is 

performed by freeway cameras, loop detectors in the freeway pavement, motorist calls, 

and other sources. MTC, Caltrans, and the CHP partner to provide roving tow truck 

services, called the Freeway Service Patrol (FSP) system to remove incidents as quickly 

as possible and prevent long periods of stop and go or blocked traffic. This system 

currently covers 450 miles of freeway and is mostly deployed to address commute 

conditions. FSP services include towing, gas, and accident removal. The system is 

popular with freeway users. Future expansion would include the addition of off peak 

routes and weekend service for heavily traveled recreational routes. 

In addition, MTC has developed and maintains a traveler information phone number 

(511) to allow motorists to access current traffic information over their intended travel 
Bay Area 2005 Ozone Strategy D - 34 Final Adopted – January 4, 2006 

route. This information system has secondary benefits in that it can allow travelers to 

change routes, travel times, or mode to avoid poor traffic conditions and thus reduce 

congestion-related emissions. (511 also provides extensive information on Bay Area 

transit routes and schedules.) 

Phase 1 (2004-2006) 

• Integrate traffic management features into new freeway construction projects 

• Maintain current level of FSP service 

• Maintain and improve 511 information and customer convenience 

Phase 2 (Beyond 2006) 

• Extend ramp metering in other major freeway corridors 

• Obtain adequate funding for full deployment of Caltrans’ TOS/TMC project 

• Expand FSP to other routes and times of the day 

• Continue to require traffic management elements in Caltrans freeway projects 

Travel Market Affected 

TCM 11 addresses all categories of vehicle trips, including inter-regional and commercial 

travel, as well as commute trips, shopping, recreation, personal business, etc. 

Effectiveness 

TCM 11 emission effects are based on a modest improvement in average freeway 

speeds of 13.5% to 27.0% due to the combined effects of all the programs above. 

Effectiveness was estimated using the following assumptions: 

• FSP Service emission reductions updated from TCM D (from 2001 Ozone 

Attainment Plan) with adjustments from EMFAC2002, v2.2. 

• Partial implementation of the TOS covering approximately 690 miles of 1,400 

total centerline miles of Bay Area freeways (2.6% implemented in 2006 and 

21.9% implemented in 2015). 

• Assumed Bay Area peak period freeway speed is 37 MPH. 

 ROG NOx

 

 2006 0.04 tpd 0.11-0.12 tpd

 2015 0.04-0.05 tpd (0.04) increase - 0.01 tpd 

To maintain the effectiveness of ramp meters, the timing plans should be periodically 

updated. 
Bay Area 2005 Ozone Strategy D - 35 Final Adopted – January 4, 2006 

Cost 

The cost of Caltrans’ high priority system management improvements is over $300 

million. The cost of operating the current Freeway Service Patrol/callbox system is 

approximately $5 million per year). The cost of the 511 Traveler Information number is 

approximately $6 million per year. 

Impediments 

The cost of deploying the full Caltrans Traffic Operation System in the Bay Area is 

constrained by lack of funding at the state level to install the hardware and operate the 

system. Initiation of local ramp metering is often controversial, as local jurisdictions fear 

that ramp traffic will spill over onto local streets and disrupt their arterial operations 

(although these impacts are most often mitigated prior to the operation of the ramp 

meters through protocols for the ramp metering timing or local street improvements to 

accommodate the ramp queues). The main impediment to the expansion of the FSP 

program is the availability of funding. 

Other Impacts 

Emission reductions calculated for this TCM may be less than calculated due to the 

generation of offsetting emissions from vehicle idling at freeway on ramps and 

acceleration onto the freeway (although there is no specific methodology to perform 

these calculations). Ramp metering may benefit some communities by reducing the 

amount of cut through traffic that gets off the freeway to avoid congestion. Overall 

freeway safety will be improved with the FSP program. 
Bay Area 2005 Ozone Strategy D - 36 Final Adopted – January 4, 2006 

TCM 12: ARTERIAL MANAGEMENT MEASURES 

Purpose 

Arterial traffic controls include signals, stop signs, and yield signs. Coordination of 

signals on major arterial routes can reduce vehicle idling and acceleration by dedicating 

extra “green” time to the major traffic direction and thereby reducing vehicle emissions. 

Bus operations will also benefit from these strategies through faster and more reliable 

travel times. 

Background 

About 40 percent of daily regional vehicle miles of travel (VMT) occurs on arterials/local 

roads and expressways. By coordinating the operation of multiple signals, vehicles can 

travel at fairly constant speed over a long route, reducing stop and go emissions. Close 

to 60 percent of 7000 signals in the Bay Area are currently subject to some kind of 

coordination. Advanced technologies allow signal timing plans to be reset based on 

actual traffic conditions at an intersection or group of intersections. Signals may also be 

adjusted from a central traffic management facility that manages large signal systems. 

For all signal systems it is important from an efficiency standpoint to ensure that their 

signal timing plans are periodically updated to reflect changes in local and areawide 

traffic conditions over time. 

Additionally, most local bus routes use arterials, and their operations can be impeded 

due to local traffic congestion which slows buses and reduces schedule reliability. 

Improving the performance and reliability of buses on arterials can stimulate increased 

ridership. Slower bus travel times also results in more buses being required to provide 

the desired headways. Signals can be equipped with software to extend the green time 

or switch the signal to green earlier to move buses faster and help maintain the 

schedule. 

Description 

This measure includes both the coordination of signals that have not yet been 

coordinated as well as the periodic retiming of signals that are coordinated to update 

their timing plans based on current traffic conditions. Of the approximately 2,500 signals 

in the Bay Area that have not been coordinated, it is estimated that roughly 50 percent 

are near enough to another coordinated signal to merit coordination. Also, for the 4,400 

signals that have already been coordinated, the basic feature of this TCM is the updating 

of their timing plans to ensure they are optimized for current traffic conditions. 

Arterial management projects should pay careful attention to the needs of transit. Cities 

and counties should assure that retiming plans include discussions with transit operators 

to determine whether it is feasible and desirable to implement bus priority treatment on 

an arterial. Arterial management strategies that can enhance transit operations include 

dedicated transit-only lanes, queue jumper lanes at intersections, signal priority, bus 

bulbs, increased enforcement of bus loading zones, and relocation of bus stops. 

Reports on the effectiveness of transit signal priority systems indicate that they could 

provide up to 15 percent improvement in travel time along a given route. 
Bay Area 2005 Ozone Strategy D - 37 Final Adopted – January 4, 2006 

MTC also provides technical assistance grants to local jurisdictions to update signal 

timing plans. Another intersection treatment that can be evaluated, if local conditions 

permit, is development of “roundabouts”, which allow intersecting traffic streams to move 

in a circle around an intersection, thus eliminating vehicle stops and idling associated 

with traditional signalized intersections. (Roundabouts are employed extensively in the 

United Kingdom and throughout Europe.) 

Phase 1 (2004-2006) 

• Maintain current technical assistance program (MTC) for local jurisdictions that 

seek to retime signals; the program will also encompass evaluation of bus 

priority treatments as part of retiming plans. 

• Continue Air District TFCA program to fund projects to improve arterial 

conditions where air quality benefits can be demonstrated. 

Phase 2 (Beyond 2006) 

• Coordinate additional 1,200 signals and continue updating timing plans 

• Working with bus operators, provide priority treatment along major bus routes 

Travel Market Affected 

TCM 12 will affect the entire range of trips made on arterials, including commute travel, 

school travel, shopping, personal business, recreation, and commercial travel. 

Effectiveness 

The emission reduction calculations include two components: 1) coordination of an 

additional 1,200 new signals by 2006 which will improve traffic flow on local arterials, 

and 2) implementation of a select set of Transit Priority Streets (TPS) for the region’s 

most heavily used bus routes by 2015. The TPS emission reductions assume that faster 

bus speeds and more reliable service would have a positive effect on bus ridership, 

increasing ridership by up to 5%. They also take into account mode of access to the bus 

route and the proportion of new riders who are transit dependent and do not own a car. 

 ROG NOx

 

 2006 0.06-0.12 tpd 0.06-0.11 tpd 

 2015 0.01 tpd 0.01 tpd 

Cost 

The cost of coordinating/retiming signals is about $1,200 per signal. Advanced signal 

software and development of centralized traffic management centers would add to this 

cost and would vary depending on the sophistication of the installation. 

Impediments 
Bay Area 2005 Ozone Strategy D - 38 Final Adopted – January 4, 2006 

The main impediment to maintaining a well-coordinated signal system is the interest and 

level of effort required from local governments who have had to reduce staff resources 

due to financial pressures. Where signal coordination on an arterial requires 

cooperation of multiple jurisdictions, the negotiations can take time to resolve both 

technical and policy issues. 

Other Impacts 

Optimized signal timing plans have been shown to be potent strategies for reducing 

automobile fuel consumption, and the attendant greenhouse gas emissions (early 

interest in signal timing sprang up during the fuel crisis of the early 70’s and 80’s). To the 

extent that bus priority treatments improve travel times and schedule reliability, ridership 

and transit revenues could increase. Also consistent travel time savings could allow 

operators to serve a high volume route with fewer buses, saving capital and operating 

costs. 

It is also critical that arterial management projects carefully consider pedestrian and 

bicyclist safety. Reducing idling and stop and go traffic can reduce emissions, but 

arterial improvements – particularly those that speed the flow of traffic – should also 

assure that pedestrian and bicycle safety is preserved and enhanced. Measures to 

enhance pedestrian and bicyclist safety include: prominent crosswalks and pedestrian 

signals; signage and striping; provision of or improvements to mid-block crossings; 

bicycle loop detectors for signals; and consideration of bicycle access in planning new 

arterial construction or modifications. Bike/ped safety on arterials is also discussed in 

TCM 20, Traffic Calming. 
Bay Area 2005 Ozone Strategy D - 39 Final Adopted – January 4, 2006 

TCM 13: TRANSIT USE INCENTIVES 

Purpose 

TCM 13 will focus on programs that could potentially increase transit use and lower 

vehicle emissions, such as monetary incentives, better transit information, deployment of 

a universal fare card for transferring between operators, and better signage at transit 

stops and transfer locations. 

Background 

With 26 different transit operators in the Bay Area, transit users need convenient ways to 

plan trips, transfer between operators, and pay fares. Through cooperative efforts 

between MTC and the Bay Area transit operators, new technologies and strategies are 

being developed to make transit trips more convenient and to take less time. 

Transit fare policies are determined by the policy boards of the individual operators, but 

MTC is developing a new universal fare card (Translink) to make fare collection easier 

and to make it easier for riders to transfer between systems. Under state law, MTC 

requires each transit agency in the region to maintain a fare/transfer revenue sharing 

agreement with every connecting agency. The ability of transit operators to stimulate 

ridership growth by providing discounted fares for different age groups or various trip 

purposes depends on the individual operator’s revenue base and the ability of the 

operator to pay for ongoing operating costs as well as longer term capital replacement 

needs. Increasing fares can decrease ridership, and has a particularly adverse impact 

on low income transit users. (MTC is currently conducting a study of overall 

transportation affordability.) 

Various operators have also designated key transit hubs or centers for improvement 

(e.g., AC Transit’s Comprehensive Service Plan which is developing 11 transit centers, 6 

at BART stations), and these improvements are being made as funding becomes 

available. 

Description 

TCM 13 includes the following: 

Phase 1 (2004-2006) 

• TransLink®. TransLink is a program that utilizes “smart card” technology for the 

collection of fares on all the region’s transit systems. It will significantly improve 

the convenience of fare payment and collection. The universal fare card is being 

deployed on transit systems throughout the region, making it easier for riders to 

use multiple transit systems and providing an improved revenue tracking 

mechanism for transit operators. The initial phase will include deployment of 

Translink with the major transit operators. 

• Improvements to the 511 transit information service. Information for trip planning 

can be obtained by calling 511, which connects people to the individual transit 

operator, or through web based information on the internet at 
Bay Area 2005 Ozone Strategy D - 40 Final Adopted – January 4, 2006 

http://transit.511.org/. Web based transit information is also available for planning 

trips. 

• Commuter Check/Ecopass. The Commuter Check program, which sells transit 

vouchers to employers who then give them to employees to purchase tickets and 

passes, continues to expand with over $12 million in annual sales. A similar type 

of program in Santa Clara County, called EcoPass, provides discounted tickets to 

employees through their employer. Residential EcoPass programs have also 

been implemented. MTC and the Air District will encourage employers, transit 

operators, local governments and others to promote and expand such programs. 

Encourage colleges and universities to include transit passes with student 

registration fees to encourage transit use by students. The Class Pass program 

at UC Berkeley provides an AC transit pass as a part of student registration fees. 

• Improved signage at transit transfer hubs, including the provision of transit 

schedules and route maps. MTC’s Transit Connectivity Report addresses the 

need for better signage and other information at transfer hubs, which would be a 

low cost improvement. The Report was completed in January 2005, and an 

expanded effort to address transit connectivity, utilizing Regional Measure 2 

funds, will continue through 2005. 

Phase 2 (Beyond 2006) 

In addition to the continuation of the efforts above, additional activities would include: 

• Deploy real time transit arrival information. Bay Area transit operators are in 

different stages of studying and deploying equipment to provide real time bus/train 

arrival information. (BART has electronic arrival information signs, Muni is 

planning on a systemwide application, and AC Transit has installed bus arrival 

information signs along the San Pablo Ave. enhanced bus route.) Real time 

information improves the transit experience by removing uncertainty in knowing 

the arrival time for the next vehicle, minimizing waiting time, and increasing a 

passenger’s sense of security for late night trips. 

• Increased amenities at transit hubs and stops. The purpose for providing new 

amenities at transit hubs would be to improve comfort and convenience for riders 

and create a sense of “place” by having food, retail activities, restrooms, improved 

shelters, lighting improvements, etc. These improvements enhance the transit 

experience for riders, particularly regarding the quality of service and ease in 

making transfers. 

• Complete transit centers as identified in AC Transit’s Comprehensive Service 

Plan in Alameda and Contra Costa Counties. 

Travel Market Affected 

TCM 13 will make transit a more attractive and convenient option for a wide range of 

trips. Measures to promote the sale and subsidy of transit passes through employers 

focus primarily on commute travel, whereas TCM 13 measures would improve 

convenience for all types of transit trips. 
Bay Area 2005 Ozone Strategy D - 41 Final Adopted – January 4, 2006 

Effectiveness 

Emission estimates are based on a 1% to 5% increase in transit ridership due to the 

combined effects of all of these programs. 

 ROG NOx

 

 2006 0.02-0.12 tpd 0.02-0.10 tpd 

 2015 0.01-0.05 tpd 0.01-0.04 tpd 

Cost 

Annual costs for various types of programs are provided below: 

TransLink® costs about $80 million over the next 5 years as program ramps up. 

511 costs about $6 million per year. 

The RTC Clearinghouse and Commuter Check program cost approximately $400,000 

per year. 

Real Time Transit Arrival Information - With the passage of Regional Measure 2 in 

March 2004, about $20 million in competitive grant funding is available to implement real 

time transit information systems (the cost of large scale deployment is unknown because 

of the different types of systems and applications which are being considered in the Bay 

Area by different transit operators). Priority will be given to projects identified in MTC’s 

Transit Connectivity Plan mentioned above. 

Impediments

Most of the key elements of this measure are already in a mature stage of deployment. 

Development of more ubiquitous transit arrival information will depend on resolution of 

technological issues among by different transit operators and new funding. Provision of 

enhanced transit amenities at hubs will require new funding. 

Other Impacts 

TCM 13 is likely to enhance the overall perception of the quality of transit service in the 

Bay Area, and would have indirect benefits for reduced auto fuel consumption and 

greenhouse gas emissions to the extent the combination of strategies above produce 

new transit riders. Deployment of real time transit information systems results in an 

unknown additional demand on transit operating funds. 
Bay Area 2005 Ozone Strategy D - 42 Final Adopted – January 4, 2006 

TCM 14: CARPOOL AND VANPOOL SERVICES AND INCENTIVES 

Purpose 

The purpose of TCM 14 is to reduce motor vehicle emissions by promoting carpooling 

and vanpooling as an alternative to the single occupant vehicle. 

Background 

Organized efforts to promote ridesharing in the Bay Area began in response to the oil 

crises of the 1970’s. These programs have grown steadily over the years due mainly to 

efforts by regional agencies, local governments and employers to reduce commute 

related congestion. The share of Bay Area commuters who carpool to work (about 13 

percent) remained about the same between 1990 and 2000; this share is in the upper 

range compared to other major metropolitan areas. MTC administers the regional 

ridesharing program through its contract with Parsons Brinkerhoff, Quade & Douglas, 

Inc. MTC also provides funding to the Solano Napa Commuter Information (Solano and 

Napa counties), Peninsula Traffic Congestion Relief Alliance (San Mateo County), and 

511 Contra Costa (Contra Costa County) to perform portions of the Regional Rideshare 

Program’s work in their respective counties. 

The Rideshare Program’s primary focus is on carpool and vanpool matching services, 

but the program also promotes transit, biking, and walking. The program also 

coordinates with various county ridesharing agencies to help support their services and 

with employers who maintain commute alternatives programs. (Employer based trip 

reduction programs are discussed in TCM 1.) 

MTC created a technical advisory committee (TAC) to provide strategic direction for the 

program. This TAC is made up of representatives of the nine county congestion 

management agencies (CMAs) and the Air District, since several CMAs also support 

local programs to promote carpooling and vanpooling. For example, Alameda County 

operates a guaranteed ride home program for employees who take transit or carpool to 

work and need to make emergency trips home during the day. Contra Costa, San 

Mateo, Solano and Napa counties also operate local TDM programs, including local 

incentive programs, local transit information and shuttle operations and community 

outreach. The Air District’s TFCA program also provides financial support for the 

regional rideshare program and for some of the county trip reduction programs. 

Description 

MTC administers the regional rideshare program which provides the following core 

services to the Bay Area public: ridematching information; vanpool formation and 

support; information on other commute alternatives (transit, bicycling and 

telecommuting); outreach and promotion to generate new ridematching applications (e.g. 

Rideshare Week, transportation fairs, other special events, etc.). In 2003 the program 

initiated on-line ridematching to provide added convenience for those wishing to explore 

carpool options. 
Bay Area 2005 Ozone Strategy D - 43 Final Adopted – January 4, 2006 

The rideshare program contractor is responsible for answering all telephone inquiries 

related to rideshare and bicycling, through the regional 511 Traveler Information system. 

The rideshare program also maintains the rideshare and bicycle pages of the 511.org 

website, where carpoolers can find maps showing carpool lanes and park and ride lot 

locations. Vanpool drivers can also post advertisements of available seats. 

Phase 1 (2004-2006) 

• Maintain current regional rideshare programs and services. Increase efficiency 

in delivering regional core by improving coordination with local programs. 

• Examine other innovative concepts to promote carpooling, such as real time 

ridematching (using the internet). 

• Explore possibility of providing a regional incentive to increase ridesharing by 

implementing a demonstration program offering a cash incentive for new 

vanpools. 

• Explore options for expanding medium distance vanpools (i.e., 15-30 miles oneway), particularly since vanpools are able to take advantage of the extensive 

carpool lane system. Real-time vanpool matching could also be used to facilitate 

shared-ride van services. Such service could be based on the airport shuttle 

concept, but designed to serve multiple origins and destinations, rather than a 

single destination such as an airport. 

Phase 2 (Beyond 2006) 

• Maintain Phase 1 programs and enhance where feasible. 

Travel Market Affected 

This TCM focuses on commute travel; however, the ridematching system has potential 

applications for other types of trips, such as trips to and from transit stations, home-toschool trips, as well as trips to airports and other major activity centers. 

Effectiveness 

Due to recent changes to the approach to the regional ridesharing program, the program 

is expected to become more effective in the future. Emission reductions are based on a 

2% increase in ridesharing by 2006 and a 10% increase by 2015. Since this measure 

does not substantially increase the current level of effort by local and regional agencies 

or the private sector, or involve new concepts that are untested, very minimal emissions 

reductions are assumed. However, without maintaining current efforts, commute carpool 

and vanpool trips would likely decrease. 

 ROG NOx

 

 2006 0.01 tpd 0.01 tpd 

 2015 0.01 tpd 0.01 tpd 
Bay Area 2005 Ozone Strategy D - 44 Final Adopted – January 4, 2006 

Cost 

The cost to implement the regional rideshare program is approximately $4 million per 

year. Air District TFCA funding for regional and county trip reduction programs in FY 

03/04 was approximately $4.4 million. 

Impediments 

Surveys and focus groups have found that many people want flexibility in their daily trips 

due to the need to have flexibility in their work hours, conduct errands, or pickup and 

drop off children at daycare. This lifestyle directly impacts the markets for carpooling 

and vanpooling which are dependent on fixed schedules among participants. Strategies 

such as guaranteed ride home programs and real-time ridematching can help address 

these concerns. A secondary impediment is the decline in employer/private sector 

interest due to other financial priorities. This has led to a decline in promotional activities 

such as on-site commute fairs and dissemination of on site trip reduction information. 

The potential market for the real time ridematching concept and/or shared-ride van 

concept is large, but difficult to quantify until the specific approach is better defined. 

MTC rideshare program staff will participate on a task force for an instant ridematching 

demonstration project, sponsored by the Alameda County CMA. 

Other Impacts 

Increased use of carpools and vanpools for commuting is a highly effective strategy for 

reducing fuel consumption and CO2 emissions, and lowering dependence on foreign oil. 

Commuters who carpool and vanpool save money by reducing their expenditures for 

maintaining and operating their vehicles. In heavily traveled corridors, carpools using 

HOV lanes significantly improve the person carrying capacity of a freeway. Ridesharing 

programs can provide critical services in emergencies. After the Loma Prieta 

earthquake, the rideshare program served as a source of information for large numbers 

of employees seeking help in finding commute options to get to work. 
Bay Area 2005 Ozone Strategy D - 45 Final Adopted – January 4, 2006 

TCM 15: LOCAL LAND USE PLANNING AND DEVELOPMENT STRATEGIES 

Purpose 

Land use patterns directly affect how we travel between homes, jobs, schools, shops 

and services, and other destinations. Motor vehicles are a major source of ground-level 

ozone precursors, fine particulates, toxic air contaminants, carbon monoxide, and other 

air pollutants. TCM 15 seeks to reduce motor vehicle use and emissions by promoting 

land use patterns and development projects that facilitate walking, bicycling and transit 

use for a higher percentage of personal trips. 

Background 

The Air District has encouraged local governments to address the air quality impacts of 

all local activities by incorporating air quality elements or sections into their general 

plans since 1986. The District, ABAG, MTC and the Bay Area Alliance for Sustainable 

Communities undertook the Smart Growth Strategy/Regional Livability Footprint Project 

in 1999. The goal of the Smart Growth Project is to develop and implement a preferred 

land use vision for the region to promote environmental quality, economic vitality and 

social equity. During an extensive public workshop process, workshop participants 

identified a vision for the region that favors compact, mixed use development near transit 

stations, transit corridors and town centers. The Smart Growth vision is reflected in 

ABAG’s Projections 2003, and informs the Regional Transportation Plan (Transportation 

2030), air quality strategies, and implementation programs of the regional agencies. 

The California Clean Air Act (CCAA) requires regional clean air plans to include indirect 

source control programs to encourage developments, as well as local and regional 

plans, that: 

• Minimize dependence on motor vehicles and, thereby, reduce air contaminant 

emissions; 

• Require mitigation of adverse air quality impacts of facilities that do attract a 

significant volume of motor vehicle traffic. 

TCM 15 responds to the indirect source requirements of the CCAA and the increasing 

understanding of the connection between land use, transportation and environmental 

quality as reflected in the Smart Growth Project and related programs. 

Description 

The location, mix, intensity and design of development influence travel choices. 

Communities can promote transit, walking and cycling by encouraging compact, infill 

development providing a mix of uses at moderate or high densities. 

Local governments can address the land use/transportation/air quality connection 

through planning and development policies and programs. Cities and counties can 

integrate air quality-beneficial policies and programs into general plans and related 

implementation programs such as subdivision regulations, zoning ordinances, capital 

improvement programs, parking benefit districts, parking requirements, and 

development design guidelines. Localities can produce separate air quality elements, or 
Bay Area 2005 Ozone Strategy D - 46 Final Adopted – January 4, 2006 

can incorporate air-quality beneficial policies into the land use, circulation/transportation, 

and other required elements of the general plan. 

Local governments and transit districts can prepare specific plans for downtowns, transit 

stations, and other activity centers. Development patterns can support transit, walking 

and cycling in various ways, including: 

• Focusing higher density development near transit stations and corridors 

• Encouraging compact development with a mix of uses that locates housing near 

jobs, shops and services, schools, and other community facilities 

• Encouraging infill development 

• Locating shops and services near employment centers 

• Designing streets, sidewalks and bike routes to ensure safe and convenient 

access for pedestrians and bicyclists 

• Designing development projects to provide safe, convenient pedestrian access to 

transit stops and nearby services 

• Reducing parking requirements and the land area occupied by parking 

Phase 1 (2004-2006) 

MTC will implement its 5-point transportation land use platform that was adopted as part 

of the Transportation 2030 plan process. Included in the platform are a 

transportation/land use policy and a new planning grant program to fund specific plans 

around transit stations and corridors, which was approved by MTC in July 2005. 

MTC’s Transportation for Livable Communities (TLC) planning grants fund local planning 

programs to promote community revitalization. 

MTC’s TLC capital grants fund local projects that promote transit, walking and cycling. 

MTC’s Housing Incentive Program (HIP) provides financial incentives to cities to provide 

high-density housing near transit stations and corridors. 

MTC’s “T-Plus” program will provide funding to each county congestion management 

agency to promote community revitalization projects. 

The Air District’s Transportation Fund for Clean Air (TFCA) funds bicycle projects, traffic 

calming, shuttles, low emission vehicles, trip reduction programs, and other clean air 

projects. Funding levels average approximately $20 million/year. 

ABAG will periodically update and monitor its Smart Growth demographic projections. 

MTC will develop incentives and conditions to promote supportive local land use policies 

around major new transit investments that generate sufficient transit ridership and make 

new transit investments economically viable. 

Starting in 2006, MTC, ABAG, and the Air District will be conducting a parking study to 

assess strategies to reform parking policies to support smart growth and to demonstrate 

the applicability of those strategies in a series of case studies. 
Bay Area 2005 Ozone Strategy D - 47 Final Adopted – January 4, 2006 

MTC, ABAG and the Air District could develop financial and other incentives to 

encourage innovative parking strategies to promote reduced amounts of parking, parking 

fees, and other parking programs. Cities and counties have authority over parking 

policies. Local governments could take various actions to promote innovative parking 

strategies, including: 

• Reduce or eliminate parking requirements. Reduce parking requirements, 

particularly at transit oriented and infill development, mixed use projects, senior 

and affordable housing, and other appropriate locations. Utilize market-based 

measures to determine the appropriate amount of off-street parking. 

• Parking maximums / caps. Limit the number of off-street spaces in areas with 

good transit service. Encourage using cost savings to enhance transit services. 

• Unbundled parking. Consider allowing developers and property owners to 

unbundle the price of parking spaces from the rent for tenants. 

• Shared parking. Promote shared parking at mixed use projects and other 

appropriate locations. 

• On-street parking. Price on-street parking in commercial districts according to 

market demand and with consideration to adjacent off-street parking facilities. 

Consider implementing parking benefit districts that use revenue generated from 

on-street parking fees to fund pedestrian-supporting infrastructure and programs 

in the area. 

• Parking fees. Charge market-value for off-street parking, and consider 

residential permit programs to alleviate spillover concerns. 

• Parking cash out. Promote parking cash out through outreach, financial 

assistance, and requirements through CEQA processes or conditions of 

approval. 

• Parking design. Adopt design guidelines and local ordinances that minimize land 

area dedicated to off-street parking. Locate parking underground or behind 

developments to reduce land area used for parking and/or increase pedestrian 

accessibility. Encourage parking structures with ground-floor uses to enhance 

pedestrian access. 

MTC, ABAG and the Air District will provide technical assistance to local agencies by 

maintaining examples of best practices for innovative parking strategies. Highlight and 

publicize through workshops, guidance documents, awards, and other methods. 

MTC, in cooperation with transit operators and local governments, will examine 

promising opportunities for transit oriented development. 

ABAG will promote multi-jurisdictional planning along selected transit corridors to 

encourage transit oriented development. 

MTC, ABAG and the Air District will pursue legislative changes to remove barriers and 

provide incentives for smart growth. 

MTC, ABAG and the Air District will engage in outreach and public involvement 

processes to build support for smart growth programs. 

The Air District, MTC and ABAG will explore ways to promote carsharing as a way to 

reduce parking requirements. The regional agencies and cities and counties could 
Bay Area 2005 Ozone Strategy D - 48 Final Adopted – January 4, 2006 

support carsharing through financial incentives, helping secure additional parking, 

assistance with marketing, and pilot programs. Emphasis should be placed on hybrid 

and SULEV vehicles to maximize air quality benefits. 

The Air District will monitor implementation of indirect source mitigation programs in 

other regions for potential feasibility in the Bay Area. 

The Air District, MTC and ABAG will consult with and provide technical assistance to 

local jurisdictions interested in pursuing smart growth strategies, including highlighting 

best practices from throughout the Bay Area and other parts of the country. 

The Air District, MTC, and ABAG will highlight and publicize noteworthy examples of 

local clean air plans, policies and programs, as well as noteworthy development 

projects. 

Cities and counties are encouraged to require the provision of bicycle access and 

facilities (e.g., bike lanes/routes, secure parking and showers/lockers, where 

appropriate) at developments such as employment centers, shopping centers, and 

residential complexes (see TCM 9). 

Cities and counties should assure that local plans, policies and programs encourage 

walking and promote a safe and convenient pedestrian environment (see TCM 19). 

Cities and counties, in cooperation with transit providers, should prepare transit station 

area plans for appropriate transit stations and transit centers, with the goal of promoting 

higher density, mixed use development, multimodal connections and convenient 

pedestrian access in order to increase transit use, walking and other alternative modes. 

Cities and counties are encouraged to require developer-based trip reduction programs. 

The Air District encourages cities and counties to develop strategies to reduce 

emissions from sources other than motor vehicles, such as lawn and garden equipment, 

woodstoves and fireplaces, and residential and commercial energy consumption. 

The Air District, ABAG and MTC will study opportunities to promote location efficient 

mortgages (LEMs) to encourage home purchases near transit. 

The Air District will continue to provide technical support to local jurisdictions and other 

lead agencies on air quality analyses and mitigations through the BAAQMD CEQA 

environmental review program in the following ways: 

• Review and comment on CEQA documents for major projects and plans. 

• Provide a guidance document on best practices for assessing and mitigating air 

quality impacts. 

• Answer questions via telephone and email from planners, consultants and the 

public about all aspects of air quality analysis of the environmental review 

process under CEQA. 

• Encourage the incorporation of air quality beneficial policies and programs as 

CEQA mitigation measures into local projects and plans through comment 

letters, phone calls and email. 
Bay Area 2005 Ozone Strategy D - 49 Final Adopted – January 4, 2006 

Phase 2 (Beyond 2006) 

Implementation of smart growth strategies will occur over many years. MTC, ABAG and 

the Air District will continue the programs listed above, and refine and augment them as 

appropriate, in future years. Budgetary and legislative constraints may influence longterm programs. 

Travel Market Affected 

Local planning and development to improve air quality and reduce motor vehicle travel 

will address all types of trips–commute, shopping, school, recreation, social, and 

personal business. 

Effectiveness 

TCM 15 emission reductions in 2006 are based upon expected growth in funding smart 

growth projects through the Air District’s TFCA program and MTC’s TLC/HIP programs. 

This TCM would reduce emissions over the long term by promoting better integration of 

land use and transportation at the local level and by supporting the implementation of 

the other TCMs in the Ozone Strategy. 

 ROG NOx

 

 2006 0.09 tpd 0.14 tpd 

 2015 N/A* N/A* 

* Note that for 2015, emission reductions associated with TCM 15 are not yet 

determined. The Ozone Strategy mobile source inventory is based upon ABAG’s 

Projections 2003, which is a smart growth policy-based regional population forecast. 

Therefore, the emissions benefits associated with many of the programs and policies in 

TCM 15 have already been accounted for in the emissions inventory baseline. 

Cost 

It is impossible to quantify costs associated with this measure. Costs would include 

preparation of general and specific plans, development review and environmental 

clearance, public capital investments, private investment in development projects, and 

other costs. Costs would be offset by rents and tax revenue from new development. 

Impediments 

Because Smart Growth land use patterns result in accommodating more people in the 

urban core with more infill development, there sometimes may be jurisdictional and 

neighborhood concerns with increased density, traffic, parking, localized air pollution and 

other impacts. Providing appropriate levels of transit service for this new development 

will require additional funding. A full range of incentives will need to be developed, which 

will take time and possible legislative action. Local governments may have limits to the 

staff resources available to making major changes in their plans and zoning to reflect 

Smart Growth principles. 
Bay Area 2005 Ozone Strategy D - 50 Final Adopted – January 4, 2006 

Other Impacts 

Local plans, policies and programs that effectively integrate land use, transportation and 

air quality considerations can help cities and counties achieve the following benefits: 

• Preserve open space, agriculture and other land resources 

• Improve housing supply and affordability 

• Reduce long distance commuting 

• Increase accessibility 

• Increase mobility 

• Conserve energy 

• Improve water quality 

• Use infrastructure and land more efficiently 

• Increase transit ridership 

• Improve economic competitiveness 

• Enhance community attractiveness and quality of life 

The Smart Growth Strategy/Regional Livability Footprint Project preferred land use 

vision will provide emission benefits in neighboring counties as more housing is provided 

in the Bay Area, cutting down on long distance commute trips. MTC analyzed effects in 

neighboring counties and estimated roughly a 2.8% decrease in VMT and ozone 

precursor emissions. 
Bay Area 2005 Ozone Strategy D - 51 Final Adopted – January 4, 2006 

TCM 16: PUBLIC EDUCATION/INTERMITTENT CONTROL MEASURES 

Purpose 

The purpose of this measure is to educate the public about air quality in the Bay Area 

and encourage residents, employers and local governments to make choices that have a 

positive effect on air quality, particularly regarding transportation and consumer 

activities. Special emphasis is placed on the need to curtail polluting activities on the 

relatively infrequent days when meteorological conditions could lead to poor air quality 

and possible exceedances of federal and state air quality standards. This latter element 

of the region’s air quality program is called Spare the Air (STA). 

Background 

Educating the public about the health effects of air pollution, the sources of air pollution, 

and ways to reduce air pollutant emissions is a critical component of efforts to improve 

air quality in the Bay Area. Increased awareness can lead to changes in personal 

behavior. The Air District administers a wide variety of public education campaigns. 

The Air District encourages voluntary actions that reduce air pollution throughout the 

year, but particular emphasis is focused on days when pollution levels are expected to 

be highest. 

Since motor vehicles are the leading source of ozone forming emissions in the Bay Area, 

efforts to reduce vehicle travel, particularly on Spare the Air Days, can help in avoiding 

exceedances of federal and state standards. The Air District also encourages the public 

to reduce other types of polluting activities including use of paints, solvents and 

consumer products, use of gasoline-powered lawn and garden equipment, and 

woodburning. The Air District attempts to inform the public of actions they can take 

through public announcements in the media, through employers and local governments, 

and through various promotional activities. Surveys indicate that the public is willing to 

alter behavior in response to air quality goals. Because the Spare the Air program is 

voluntary in nature, its effectiveness depends on the cooperation of the general public. 

Description 

Spare the Air is an intermittent, voluntary control program in which Bay Area residents, 

businesses and public agencies are asked to reduce or postpone polluting activity on 

days when weather conditions are conducive to high ozone levels. It focuses on the 5 to 

15 days per year when air quality is expected to be poor. Spare the Air days are 

declared when any part of the Bay Area is predicted to have 92 or greater (parts per 

million) on the Pollutant Standards Index (PSI) scale - approaching the new federal 8-

hour standard for ozone. Predictions are made the previous afternoon by Air District 

meteorologists. STA advisories are then sent to participating individuals, employers and 

agencies, as well as press and media outlets. 

On these days, the Air District issues Spare the Air advisories and asks Bay Area 

residents to curtail or postpone activities that pollute. This includes eliminating 

discretionary driving and substituting driving trips with biking, walking, telecommuting, 

taking public transit or carpooling instead. The strategy also includes linking motor 

vehicle trips together ("trip-linking") to avoid excessive engine cold start emissions. To 
Bay Area 2005 Ozone Strategy D - 52 Final Adopted – January 4, 2006 

inform the public of these days, the Air District sends e-mail notices, contacts television 

news bureaus, publishes announcements in newspapers and makes public service 

announcements on the radio. Caltrans posts messages on their variable message signs 

on Bay Area freeways letting motorists know of Spare the Air days. Residents are also 

asked to avoid activities that generate pollution such as use of hair sprays, pesticides, 

gasoline-powered lawn and maintenance equipment, use of oil-based paints and 

solvents, and the use of recreational boats. Together these activities generate over 200 

tons per day of organic gases in the Bay Area.

The Air District also works very closely with Bay Area employers to implement the Spare 

the Air program. Employers who participate in the program pledge to educate their 

employees on air quality and Spare the Air, and to notify employees of Spare the Air

days. The Air District provides numerous educational materials to the employers 

including brochures, a video, posters, signs, sample newsletter articles, and training 

sessions. Approximately 2,250 employers representing over a million employees now 

participate. 

Topics addressed in the public outreach effort of this TCM include: 

• Health effects of air pollution, 

• Connection between air pollution and motor vehicle usage, 

• Benefits of reducing single-occupant motor vehicle use, particularly on poor air 

quality days, 

• Benefits to the environment of carpooling, vanpooling, taking public transit, biking, 

walking, or telecommuting, 

• Air pollution effects of motor vehicles that are not properly tuned, 

• Benefits of trip-linking, 

• Air quality advantages of avoiding consumer products that pollute on high ozone 

days and using electric or hand-powered lawn mowers and leaf blowers instead of 

gasoline powered models. 

In addition to expanding outreach efforts and enrolling increasing numbers of 

participants, the STA program has added other elements over the years, including: 

• Bay Area Clean Air Partnership (BayCAP) – Partnering with business groups and 

employers to promote voluntary action to reduce air pollution. 

• Clean Air Cities and Counties – Engaging local governments to educate 

residents about the STA program and ways to reduce air pollution. 

• Clean Air Consortium – Partnering with cities, counties and other public agencies 

to minimize polluting activities on STA days, i.e., postponing activities such as 

lawn maintenance, building painting, vehicle refueling, etc. 

• A youth outreach campaign and educational materials. 

• Coordination with San Joaquin Valley Unified APCD and Sacramento 

Metropolitan AQMD Spare the Air programs. 

• Spare the Air Tonight – Expansion of the STA program to wintertime, to 

discourage woodburning when high levels of fine particulate are predicted. 

Several recent efforts to examine new Spare the Air strategies have included free fares 

on the Livermore Amador Valley Transit system during the 2003 and 2004 ozone 

seasons, free morning BART rides on the first two weekday STA days during the 2004 
Bay Area 2005 Ozone Strategy D - 53 Final Adopted – January 4, 2006 

ozone season, providing “Observe the Speed Limit” messages on Caltrans’ freeway 

signs to reduce emissions from vehicles traveling at high speeds, conducting surveys of 

older vehicle owners to determine the interest and ability of owners of these cars to not 

use them on Spare the Air Days, and conducting meetings with employers to examine 

telecommuting opportunities on these days. During the 2005 ozone season, morning 

commutes will be free on participating Bay Area transit during the first five non-holiday 

weekday Spare the Air Days. 

Phase 1 (2004-2006) 

• Continue Spare the Air notices to media, employers, public agencies and 

individuals. 

• During the 2005 ozone season starting June 14, 2005 and ending October 14, 

2005, free morning commutes are offered on participating Bay Area transit during 

the first five non-holiday weekday Spare the Air Days. 

• Place greater emphasis on discouraging use of pre-1985 cars in Spare the Air 

advisories, outreach to employers and public agencies, STA website, and other 

outreach efforts. 

• Expand Clean Air Consortium to include additional cities and counties, as well as 

other public agencies such as park districts, school districts, colleges and 

universities, etc. 

• Place greater emphasis on ROG reductions (e.g., consumer products, paints and 

solvents, vehicle refueling, barbecue lighter fluid) in Spare the Air advisories, 

outreach to employers and public agencies, STA website, and other outreach 

efforts. 

• Target major commercial airports and airport tenants for greater participation in 

the Spare the Air program. 

• Place greater emphasis on obeying freeway speed limits in electronic freeway 

signs, STA advisories, outreach to employers and public agencies, STA website, 

and other outreach efforts. Explore opportunities to increase enforcement of 

freeway speed limits on Spare the Air days. 

• Increase efforts to coordinate Bay Area Spare the Air program with Sacramento 

and San Joaquin Valley STA programs and provide additional outreach to 

Sacramento and Central Valley commuters to the Bay Area. 

• Discourage use of recreational watercraft on STA days. 

• Continue gasoline-powered lawnmower buyback incentive programs. 

• Continue to expand the STA employer network. 

• Target Bay Area schools for greater participation in Spare the Air program. 

• Educate the public about ways to maintain and operate motor vehicles to reduce 

air pollution, such as keeping vehicles properly tuned, using synthetic motor oil, 

observing speed limits, and avoiding aggressive acceleration and deceleration. 

• Continue the Bay Area Clean Air Partnership (BayCAP) shuttle project to 

inventory existing shuttle programs, provide coordination and assistance, and 

promote “best practices” among shuttle operators. 

Phase 2 (Beyond 2006) 
Bay Area 2005 Ozone Strategy D - 54 Final Adopted – January 4, 2006 

• Continue Phase 1 programs, and expand depending on effectiveness and 

resources available. 

• Study effectiveness and costs of free transit service on all Spare the Air days. 

• Possible legislative approaches to formalize and strengthen certain episodic 

approaches, as required. 

Travel Market Affected 

The Spare the Air program is aimed at the general public with special emphasis on 

employers and morning commuters, since reductions in early morning emissions are 

important to avoid exceedances that occur later in the day as ozone precursors “cook” in 

hot sunlight. However, all motorists should attempt to reduce discretionary vehicle trips 

or better link trips to avoid excess emissions throughout the day, particularly when an 

ozone episode may extend for several days at a time. 

Effectiveness 

Efforts have been made to quantify emission reductions on Spare the Air days through 

follow up surveys. The Air District’s current estimate is that the Spare the Air program 

reduces ROG by about 1.9 tons per day and NOx by about 2.0 tons per day.1

 The 

estimated emissions reductions for the 2005 ozone season free morning commute for 

the first five non-holiday weekday STA days is estimated to be 0.21 tpd of ROG and 0.20 

tpd of NOx. Likely emission reductions from all the proposed Spare the Air 

enhancements are unknown, but collectively they could contribute additional reductions 

on STA days. 

Cost 

The annual cost of the Spare the Air program is approximately $2 million, which includes 

staff and consultant time for the public and employer program, the printing and 

distribution of materials, media advertising, and other costs. MTC and the Air District 

has committed $4.0 million towards a Spare the Air/Free Morning Transit Commute 

Program for the 2005 ozone season. 

Impediments 

The Air District has worked with employers and the general public through a voluntary 

framework, which relies on cooperation of all parties. Some enhancements to the Spare 

the Air program would require additional resources to initiate and maintain the programs. 

Free transit service on all Spare the Air days would require additional funding in the 

future. 

Other Impacts 

 

1

 Because the STA program is an episodic program, these emission reductions are assumed to 

occur only on STA days. 
Bay Area 2005 Ozone Strategy D - 55 Final Adopted – January 4, 2006 

This measure raises the awareness of the public about the causes of and solutions to 

the air pollution problem. Although this TCM mainly addresses intermittent controls, it 

may have a broader impact. People who choose to change their travel or other 

behaviors in response to a voluntary request may continue to reduce vehicle use or 

change other polluting activity on a regular basis. 
Bay Area 2005 Ozone Strategy D - 56 Final Adopted – January 4, 2006 

TCM 17: CONDUCT DEMONSTRATION PROJECTS 

Purpose 

This measure will promote demonstration projects to develop innovative approaches to 

reduce mobile source emissions. 

Background 

Additional work is needed to test new approaches and monitor their effectiveness, 

quantify emission reductions and travel benefits, and evaluate the synergistic effects of 

complementary measures. It is important to encourage demonstration projects that can 

serve as models for trip reduction and travel demand efforts and clean fueled vehicles 

and infrastructure throughout the region. 

Description 

This measure would undertake various demonstration projects and studies to further 

develop strategies that will ultimately be needed to help achieve State air quality 

standards. While these demonstration projects are not all strictly TCMs, they do impact 

mobile source emissions. The Air District, MTC, ARB and Caltrans will cooperate in 

developing demonstration projects. Examples are as follows: 

• Additional demonstration projects will be developed to promote the use of low and 

zero emission vehicles by public and private sector fleets, as well as by 

individuals. (Current Air District programs to encourage low emission vehicles are 

discussed under MS-3, Low Emission Vehicle Incentives.) Forthcoming 

demonstration projects may include both on-road vehicles (e.g. battery electric 

and hybrid school buses) and off-road vehicles (e.g. retrofit devices for diesel 

marine engines and construction equipment) with a variety of uses and fuels (e.g. 

compressed natural gas, hybrid engines, biodiesel). 

• Hydrogen technology. Continue working with automobile manufacturers and 

other interested parties on the testing of hydrogen fuel cell vehicles for use in 

local public fleets. Work with local and statewide hydrogen fuel cell partnerships 

on ways to improve fuel cell technology and to develop demonstration projects 

that improve the state’s hydrogen fueling infrastructure, especially exploring 

possible renewable sources for hydrogen. 

• Gas cap replacement program for older cars. Preliminary District analysis 

suggests that replacing gas caps in vehicles exempt from Smog Check may be a 

cost-effective emission reduction strategy. Currently, the enhanced Smog Check 

program in the Bay Area includes a test of a vehicle's evaporative control system 

through which missing or malfunctioning gas caps must be repaired. A gas cap 

replacement program could target pre-1976 model year vehicles that are not 

required to submit to Smog Check. The Air District is considering a pilot program 

to swap older leaking gas caps for new gas caps in pre-1976 vehicles. Further 

analysis from a short-term pilot program in one Bay Area County would help to 

determine emission reductions, implementation mechanisms, costs, and funding 

sources for a possible more comprehensive program. 
Bay Area 2005 Ozone Strategy D - 57 Final Adopted – January 4, 2006 

• Heavy duty diesel vehicle idling. Extended vehicle idling of diesel vehicles can be 

a source of significant NOx and fine particulate emissions. This measure would 

explore the use of electric hookups at locations with high numbers of heavy-duty 

trucks to reduce the use of the vehicle’s diesel engine to produce on board power, 

and other techniques for reducing diesel vehicle idling. This demonstration 

project could complement efforts to reduce diesel idling under MS-1, Diesel 

Equipment Idling Model Ordinance. 

• Refuse truck incentive program. A new ARB regulation, which took effect in July 

2004, requires all refuse vehicle fleets to equip their trucks with the best available 

control technology to reduce emissions of particulate matter. The Air District and 

MTC plan to make incentive funds available to encourage fleets subject to the 

ARB regulation to install control technology to reduce NOx emissions, in addition 

to particulate matter. 

• Carsharing. Membership in carsharing organizations is increasing. Preliminary 

data from surveys to date show reduced auto ownership and reduced emissions 

from participants. There may be greater potential over the long term as 

carsharing allows households to reduce auto ownership. The data is very limited, 

however, and further experience with carsharing will allow better analysis of the 

program’s air quality impact and suggest ways to increase its effectiveness. This 

demonstration project would explore carsharing projects that have greatest 

potential to be air quality beneficial and then promote these opportunities, 

particularly at BART stations. MTC and the Air District plan to partner with UC 

Berkeley’s Institute of Transportation Studies to fund a hybrid and hydrogen fuel 

cell carshare vehicle demonstration project at the Pleasant Hill BART station. 

Notably, the City and County of San Francisco received a $1.6 million federal 

earmark from the SAFETEA bill that was signed into law on August 10, 2005 to 

expand its carsharing pilot program to serve low- and moderate-income 

neighborhoods. 

Travel Market Affected 

Demonstration projects generally would directly affect a small percentage of travel in the 

region. However, the experience gained through these projects will be of great benefit in 

developing longer term policies and programs that affect all types of travel in the region, 

including commuting, shopping, recreation and personal business, and commercial 

travel. 

Effectiveness 

Demonstration projects are intended to test, sometimes at a limited scale, concepts that 

appear promising but whose cost effectiveness is uncertain. Because the success of 

future demonstration projects is unknown, no direct emission reductions have been 

identified. However, results from demonstration projects should contribute to reduced 

emissions by providing tested models to use in crafting effective future programs with 

possible broader implementation. 
Bay Area 2005 Ozone Strategy D - 58 Final Adopted – January 4, 2006 

Cost 

Specific elements of demonstration projects have not yet been fully developed, and thus 

estimating costs is not feasible at this time. 

Impediments 

Demonstration projects are generally supported by the public and funding agencies as a 

reasonable way to gain valuable information about the feasibility and cost of new 

approaches to problems without making large scale investments up front. Depending 

upon the demonstration project, new funding may be required from the Air District and 

MTC (federal CMAQ funds). 

Other Impacts 

If found to be effective, the demonstration projects in TCM 17 could have beneficial 

impacts in terms of reducing certain other air pollutants (such as particulates from diesel 

engines) and could have positive economic impacts if the projects are developed and 

implemented by companies in the Bay Area. 
Bay Area 2005 Ozone Strategy D - 59 Final Adopted – January 4, 2006 

TCM 18: IMPLEMENT TRANSPORTATION PRICING REFORM 

Purpose 

Strategies to price the use of the region’s transportation system could have long-term 

implications for improving air quality and addressing persistent congestion issues. 

Pricing of transportation facilities would not only affect travel behavior, but would 

generate new revenues for future transportation improvements and for TCMs in this 

plan. Sound economic principles require a link between the cost of providing 

transportation facilities and services and the cost of using them; however, recent 

transportation funding decisions have decreased the proportion of funding from user 

based charges (such as gas taxes and tolls) and increased reliance on non user 

charges (such as local county sales). A variety of pricing strategies have been 

suggested to restore and better link the price of transportation with user demand and 

with the indirect costs of transportation consumption related to air and water quality 

impacts. 

Background 

Gas taxes have been the historic means for paying for transportation improvements, and 

as prices increase motorists generally will curtail some of their travel. Federal and state 

taxes currently amount to about 36 cents per gallon, and have not increased in over a 

decade. Increases in fuel efficiency and increased use of alternative fuels also reduce 

revenues from gas taxes. The arguments for new transportation fees are based on the 

need to provide enhanced transportation choices as much as they are on providing near 

term emission reductions. In order to affect the number of trips and amount of travel 

made by autos, pricing strategies would need to significantly increase the cost of gas, 

tolls, parking, etc., to levels that probably are not currently acceptable to the public 

(particularly given the already high cost of living in the Bay Area). Public surveys of 

interest in increasing the gas tax, even at modest levels, show significant public 

opposition. Efforts to secure legislative interest in strategies such as congestion pricing 

on the Bay Bridge also have failed to garner enough support to advance this concept, 

even as a demonstration project. Thus, the theory and implementation of new strategies 

must be coupled together in a pragmatic approach, and include outreach to business 

and environmental organizations and the public at large to build support for these 

measures. 

Specific traffic management fees include congestion pricing (fees change by time of 

day), High Occupancy Toll (HOT) lanes (solo drivers pay to access freeway carpool 

lanes where they would otherwise be prohibited), and cordon pricing (such as the fee 

paid to drive in central London). 

Vehicle based fees that could encourage motorists to purchase low or zero emission 

cars include registration fees and fees based on the emission characteristics of the car 

and amount of mileage driven. 

Parking availability and the pricing of parking are also key determinants in how often 

people use their vehicles and are discussed under TCM 15. 
Bay Area 2005 Ozone Strategy D - 60 Final Adopted – January 4, 2006 

With all of the above pricing concepts, the new revenue could be applied to transit, 

carpooling, bicycle facilities, pedestrian improvements, and other programs to enhance 

alternatives to driving alone. Or they could be used for some system management 

programs that lead to more efficient vehicle operations, or approaches to reduce 

emissions from more polluting vehicles, such as diesel vehicles. 

Although pricing measures offer potential for reducing air pollution and congestion, 

certain aspects of these fees could have disproportionately large effects on low income 

households, and would have to be designed with remedies in mind. 

Description 

Pricing measures under this TCM would require close cooperation between the Air 

District, MTC, the business community and other stakeholders to develop legislative 

support. This TCM would consist of the following pricing options: 

Phase 1 (2004-2006) 

• Higher Bridge Tolls - Regional Measure 2 increased bridge tolls by $1 as of July 

1, 2004. Higher bridge tolls will have a modest impact on shifting Transbay trips to 

various modes of transit. Bridge tolls are still relatively inexpensive compared to 

similar tolls on other bridges around the country. 

• Congestion Pricing - MTC and the Air District will continue to test legislative 

support for congestion pricing on the Bay bridges. If authorized by the legislature, 

MTC and Caltrans will begin a demonstration of congestion pricing. If this 

demonstration is successful, congestion pricing may be expanded to other 

bridges in the region. 

• Gas Tax Increase - MTC has authority for placing a regional gas tax measure on 

the ballot for up to a $0.10 increase over 20 years. Through periodic polling, MTC 

will continue to investigate the viability of proposing a regional gas tax to Bay Area 

voters (which would currently require a 2/3 margin of approval). This measure 

would include building legislative and public support for higher federal and state 

gas taxes, either through a tax increase or indexing current taxes to keep up with 

inflation. 

• Parking Pricing - MTC and the Air District will continue to work with cities and 

counties and transit agencies to encourage local parking pricing strategies such 

as the implementation of market-based on-street and off-street parking fees, and 

parking cash-out programs. More detailed descriptions of parking strategies are 

included in TCM 15. 

Phase 2 (Beyond 2006) 

• Continuation of Phase 1 elements 

• High Occupancy Toll (HOT lanes) - The most likely lane to be developed for 

testing this concept would be in the I-680 corridor (Sunol Grade), and would allow 

single occupant vehicles to pay for using the carpool lane to avoid congestion in 
Bay Area 2005 Ozone Strategy D - 61 Final Adopted – January 4, 2006 

the adjacent mixed flow lanes. Notably, a $2.0 million federal earmark from the 

SAFETEA bill that was signed into law on August 10, 2005 was directed towards 

the construction of the I-680 HOT project. Additionally MTC will be investigating 

the concept of a much more extensive system of HOT lanes, using the existing 

HOV system as a foundation for this network. Surplus revenues (those available 

after paying for the direct operating costs) generated by a HOT lane could be 

used to pay for expanding the HOT network or for commute options in congested 

corridors. Real time pricing would also be considered, which would factor in the 

value of the travel time savings compared to slower travel in the more congested 

mixed flow lanes. A preliminary evaluation by MTC of the air quality benefits 

shows decreases in VOC and increases in NOx. Any HOT lanes pursued under 

this TCM should be those showing the greatest emission reduction benefit. 

• Gas Tax Increase/VMT Fees - This measure would consist of a significant 

increase in the cost per mile of driving, either imposed as higher gas taxes or 

direct taxes on the amount of driving (Vehicle Miles of Travel). This TCM assumes 

gas prices (in real terms) would approach current levels in Europe and Japan. 

People who own more fuel efficient cars would pay less annually than others. 

Alternatively, VMT fees would directly relate to wear and tear on the roads and 

the amount of running emissions generated by on-road travel (but not cold start 

emissions). VMT would be less susceptible to revenue loss due future increases 

in fuel efficiency of cars and would have some impact on moderating the amount 

of vehicle travel conducted. A portion of the fee could be based on the air 

pollution characteristics of the vehicle (i.e., cleaner vehicles would pay less). With 

either fee, revenues could be used for a broad array of transportation and air 

quality programs. (Also see Vehicle Registration Fees below.) 

• Taxes on Diesel Fuel - A higher diesel fuel tax would be used to reduce NOx and 

particulate matter emissions from older heavy duty diesel trucks, which can stay 

on the road for many years due to the durability of their engines. Funds could go 

to help offset the cost of purchasing new vehicles, repowering existing vehicles 

with cleaner engines, or retrofitting trucks with catalytic converters that 

significantly reduce NOx and particulate matter. 

• Emissions-based Vehicle Registration Fees - Vehicle registration fees would 

be used to influence the purchase choices of new vehicles. Annual fees would be 

based on vehicle emission characteristics and the amount of annual driving that is 

conducted (which would be assessed at the time the vehicle undergoes a Smog 

Check). The fees would be used in turn to pay for various air quality programs, 

such as vehicle buy back, fixing emission controls on mid-aged vehicles, 

incentives to tune up vehicles prior to the next smog season, financial assistance 

to low income families that would face hardships with costly tune-ups, and other 

programs. 

• Parking Fees – This measure would establish $3 daily parking fees for all workrelated parking sites, including public and privately provided spaces. The fees 

would be used in turn to pay for various employer-sponsored programs to expand 

transit, carpooling, bicycling, walking and telecommuting and to administer 

residential parking permit programs to reduce spillover effects. 
Bay Area 2005 Ozone Strategy D - 62 Final Adopted – January 4, 2006 

Travel Market Affected 

Market-based measures would affect all types of travel, including commuting, 

commercial trips, shopping, personal business, and social and recreational travel. 

Effectiveness 

Different pricing strategies will produce different emission reductions, which are shown 

separately for each strategy. Emission reductions for most pricing measures are based 

on demand elasticity factors from the MTC travel demand forecast model which indicate 

how changes in automobile travel costs would affect regional vehicle trips and miles of 

travel. Emission estimates for HOT lanes are based on changes in freeway speeds 

resulting from allowing single occupant vehicles in the mixed flow lanes to use the HOT 

lanes for a fee. The emission estimates do not include the effects of investing the new 

revenues in other programs that would lower automobile emissions. 

 

• Congestion Pricing on Bay Bridges 

 ROG NOx

 2015 0.01 tpd 0.01 tpd 

 * Emission reductions would vary, depending on whether program is revenue neutral. 

• Regional and State Gas Tax / VMT Fees 

 ROG NOx

 2015 0.45 tpd 0.34 tpd 

• High Occupancy Toll (HOT lanes) 

 ROG NOx

 

 2015 0.03 tpd (0.04) tpd increase

• Parking Fees 

 ROG NOx

 2015 0.03 tpd 0.02 tpd 

 

Cost 
Bay Area 2005 Ozone Strategy D - 63 Final Adopted – January 4, 2006 

Different fees would generate different amounts of revenue. Pricing measures would 

obviously entail out-of-pocket expenses for many drivers, in some cases substantial 

expenses, especially those who are either unable or unwilling to shift to alternatives to 

the single occupant vehicle. However, most of these expenses represent transfers 

within the region's economy that could be directed to enhanced transportation 

alternatives and vehicle emission reduction programs. Increased costs to households 

and businesses would be offset to a certain degree by reduced costs of vehicle 

ownership, operations and maintenance. 

Impediments 

Bay Area business associations, government agencies and environmental organizations 

have historically expressed support for consideration of new pricing measures. Their 

support will be needed to secure legislation authorizing pricing measures. New fees 

would, however, have significant impact on business related costs and household 

expenditures, and therefore would continue to be unpopular with the public and 

Legislature. To obtain approval of new pricing strategies directed at improving air quality, 

there will need to be compelling reasons for their implementation based on tangible and 

near term improvements in traffic and air quality. Programs involving substantial pricing 

increases will need to mitigate the impacts on low income households. 

Other Impacts 

Pricing strategies that reduce the number of vehicle trips by modest amounts in 

congested corridors could produce relatively large improvements in delay. Revenues 

from pricing strategies could also provide new transportation options that provide faster 

or more convenient travel and save users considerable amounts of time. Reduced travel 

demand could lead to considerable savings in fuel consumption, dependence on foreign 

oil, and greenhouse gas emissions. Reduced vehicle use could extend the useful life of 

vehicles, and may stimulate consumers into purchasing more fuel-efficient and lower 

polluting vehicles. 
Bay Area 2005 Ozone Strategy D - 64 Final Adopted – January 4, 2006 

TCM 19: IMPROVE PEDESTRIAN ACCESS AND FACILITIES 

Purpose 

Implementing measures to make pedestrian travel safer, more convenient and more 

attractive will promote walking, reduce the need to use autos, and therefore reduce 

mobile source emissions. 

Background 

Virtually all travel, regardless of mode, entails some walking at some point in the trip. 

Many trips are very short in length. Approximately 14 percent of all trips are one-half 

mile or less in length, and 28 percent of all trips are one mile or less. These trip lengths 

are a reasonable walking distance for most people and represent an enormous 

opportunity to reduce motor vehicle use and emissions. Eliminating short vehicle trips is 

especially beneficial to air quality because vehicle emissions are highest at the 

beginning of a trip. In many parts of the Bay Area the share of trips made by walking is 

very small, as many people rely on the car. Much of this low level of pedestrian travel 

can be attributed to low density, single-use land use patterns and development of streets 

and roads and development projects that lack adequate attention to the pedestrian 

environment. MTC has recently focused more attention on pedestrian safety issues by 

creating a Regional Pedestrian Committee in 2002 to address the gamut of pedestrian 

planning and education issues of interest to local communities. Pedestrian 

improvements proposed in this TCM complement measures in other TCMs, particularly 

TCM 15 and TCM 20. 

Description 

Numerous actions can be pursued in order to increase pedestrian travel, including the 

following: 

• Local general plans, specific plans and zoning ordinances should promote land 

use patterns that facilitate walking, such as increased densities, mixed land uses, 

focusing development around transit stops, strengthening downtowns and 

community centers, infill development and reuse/redevelopment of underutilized 

land. 

• The design and placement of buildings in new development should encourage 

walking, for example by providing sidewalks/paths, minimizing setbacks, locating 

entrances near sidewalks and transit stops, etc. 

• Locate and design parking so that pedestrians have direct, attractive access. 

• An integrated street network with direct routes for pedestrians and ensuring easy 

pedestrian access between neighboring developments, as well as downtowns, 

commercial areas and community centers, should be provided. 

• Pedestrian amenities such as sidewalks, benches, landscaping, etc. should be 

provided at new development. 

• Existing development and streets should be retrofitted to incorporate pedestrianfriendly improvements. 

• Street design standards should enhance pedestrian safety and comfort through 

measures such as reduced street width, reduced turning radii, crosswalks with 

activated signals, curb extensions/bulbs, buffers between sidewalks and traffic 
Bay Area 2005 Ozone Strategy D - 65 Final Adopted – January 4, 2006 

lanes, street trees, etc. Traffic calming strategies are discussed in greater detail 

in TCM 20. 

Cities and counties can undertake a variety of actions to promote pedestrian travel, 

including the following: 

• Review and revise general and specific plans to assure that land use policies 

promote development patterns that encourage walking and circulation policies 

that emphasize pedestrian travel. 

• Review and revise zoning ordinances, subdivision ordinances, parking 

requirements and other local programs to include pedestrian-friendly design 

standards/guidelines. 

• Review and revise street design standards to promote pedestrian access, safety 

and comfort. 

• Include pedestrian improvements (e.g. sidewalks, lighted crosswalks, traffic 

medians and better signage) in local capital improvement programs. 

• Designate a staff person to be pedestrian or non-motorized (pedestrian/bicycle) 

program manager. 

• Require developers to provide pedestrian amenities in new projects. 

• Identify and implement pedestrian-friendly improvements to existing streets and 

developments. 

• Emphasize pedestrian safety in enforcement of local traffic codes and public 

education campaigns. 

Phase 1 (2004-2006) 

• The Air District and MTC will comment on pedestrian improvements in related 

elements of city and county general plans, policies and programs, and in CEQA 

documents to encourage local actions to promote pedestrian travel. 

• MTC will continue to fund the Transportation for Livable Communities (TLC) 

program, which includes funding for projects in local communities that improve 

pedestrian mobility. 

• MTC will continue to support the Regional Pedestrian Committee, develop 

pedestrian safety programs, collect data on pedestrian safety issues, and report 

on safety trends in the annual State of the System Report. 

• The Air District’s TFCA program funds certain pedestrian improvements (those 

that support development projects that reduce motor vehicle emissions). 

• MTC will continue to support Safe Routes to Schools (see TCM 10). 

Phase 2 (Beyond 2006) 

• MTC and the Air District will continue to identify and fund planning projects to 

identify ways to enhance pedestrian movement in neighborhoods, downtown 

centers, and near transit stops. 

• Continue funding specific improvements through a variety of programs, including 

TLC, TDA Article 3, local sales tax measures, etc. 

• Continue to support Safe Routes to Schools (also see TCM 10) 
Bay Area 2005 Ozone Strategy D - 66 Final Adopted – January 4, 2006 

Travel Market Affected 

Pedestrian improvements will tend to have a greater impact on trips for shopping, 

school, recreation and personal business since these trip types generally are shorter in 

length than work trips. 

Effectiveness 

Emission reductions estimates for TCM 19 assume a 1% increase in regional walk trips 

by 2006 (i.e., an increase from 11% to 11.3% of all regional trips) and a 5% increase by 

2015 due to the various programs described above: 

 

 ROG NOx

 

 2006 0.04 tpd 0.02 tpd 

 2015 0.08 tpd 0.04 tpd 

Cost 

MTC’s current TIP provides $69 million for bike and pedestrian projects. Owing to the 

very localized nature of a large number of small projects, it is difficult to develop a 

comprehensive estimate of pedestrian funding needs. 

Impediments 

Pedestrian improvements tend to have a lower priority in communities than 

improvements for autos and bicycles; therefore there is a need to raise the general 

awareness of the importance of pedestrian issues in communities and the need to 

integrate pedestrian improvements into street upgrade and maintenance projects. 

Safety concerns related to crime as well as conflicts with motor vehicles sometimes 

dissuade people from walking. Pedestrian improvements and related programs, e.g., 

enforcement of traffic laws, should enhance pedestrians’ actual and perceived safety. 

Other Impacts 

In addition to reducing motor vehicle emissions, pedestrian improvements will decrease 

the chance of personal injury, benefit health and fitness, and generally foster a greater 

sense of community vitality. 
Bay Area 2005 Ozone Strategy D - 67 Final Adopted – January 4, 2006 

TCM 20: PROMOTE TRAFFIC CALMING MEASURES 

Purpose 

“Traffic calming” is the combination of mainly physical measures that slow vehicle traffic 

and improve conditions for pedestrians and bicyclists in residential and retail areas. 

These measures are often desired by communities that experience excessive cut 

through traffic or that want to slow vehicle speeds to protect pedestrians and cyclists. 

Children and older adults are often considered particularly vulnerable. Motor vehicle 

emissions are reduced to the extent that walking and cycling increase and overall 

vehicle travel in an area is reduced. 

Background 

Traffic calming modifies the streetscape to reduce the number and speed of motor 

vehicles, smooth speeds and increase the attractiveness of transit, bicycling and 

walking. Traffic calming has been most extensively implemented in Western Europe. 

Traffic calming has grown fastest in Germany, with one province reporting over 8,000 

traffic calming projects in 1989. Many of the traffic calming techniques used in Europe 

are implemented on an areawide basis, which is generally not the case in the US. 

Areawide traffic calming strategies are preferable because they improve pedestrian and 

cycling conditions throughout an entire neighborhood or district, rather than shifting 

traffic from one street to another. 

Many communities in the Bay Area are developing traffic calming plans and installing 

traffic calming devices. Berkeley is developing a residential traffic calming program, and 

has installed numerous traffic diverters, speed humps, and other devices. Palo Alto has 

a Neighborhood Traffic Calming Program and has implemented traffic calming 

improvements in many parts of the city. Cotati completed a traffic calming plan for the 

downtown area. Oakland constructed a traffic median on International Blvd. in the 

Fruitvale district. San Francisco’s traffic calming program is implementing a variety of 

site specific and areawide projects. 

Description 

There are many traffic calming strategies that cities and counties may consider. The 

most effective programs generally involve thorough consultations with residents and 

merchants, as well as public safety officials. 

MTC’s Transportation for Livable Communities program and the Air District’s 

Transportation Fund for Clean Air fund traffic calming projects. 

The following actions can be taken to implement traffic calming in the Bay Area: 

• Pedestrian Streets - Pedestrian streets exclusively reserve streets for use by 

pedestrians. Consider converting streets to pedestrian streets where: 

 Streets have significant pedestrian activity, and 

 Pedestrians are able to access the area via transit, bicycle or walking and 

the area is difficult to access by motor vehicle. 
Bay Area 2005 Ozone Strategy D - 68 Final Adopted – January 4, 2006 

• Residential and Neighborhood Traffic Calming - Implement traffic calming on 

residential and neighborhood streets through: 

 Road humps and speed tables which raise the surface of the road, 

 Traffic circles/mini-roundabouts that replace traffic signals and stop signs 

at intersections, 

 Narrowing of motor vehicle lanes, introduction of dedicated bike lanes and 

wider sidewalks, 

 Chicanes, which place physical obstacles or parking bays, staggered on 

alternate sides of the street so that motor vehicles must slow down to 

maneuver through the street, 

 Traffic throttles/pinch points that restrict a two-way road over a short 

distance to a single lane, 

 “No Entry” signage restricting through motor vehicle access, 

 Surface treatments including textured surfaces such as brickwork, paving 

and rumble strips designed to warn drivers of excessive speed or of an 

approaching hazard where speeds should be lowered, and 

 Merging the street/sidewalk to the same height and use of the same 

paving materials so that there is no distinction between the road and 

sidewalk. 

• Arterial and Major Route Traffic Calming - Arterial traffic calming generally limits 

motor vehicle speeds to 33 mph on arterials and major routes, with the recognition 

that bicycle and pedestrian activity can still be enhanced. Implement traffic calming 

on arterials and major routes by: 

 Installing sidewalk bulbouts and traffic medians. 

 Replacing traffic signals and stop signs with modern roundabouts, 

 Improving pedestrian amenities and safety through making wider and 

attractive sidewalks, adequately marking crosswalks and installing countdown pedestrian signals. Strategies to facilitate pedestrian travel are 

discussed in greater detail in TCM 19. 

 Reduced speed limits and/or increased enforcement of speed limits and 

other traffic laws. 

Travel Market Affected 

TCM 20 will affect the entire range of motor vehicle, transit, bicycle and pedestrian trips, 

including commute travel, school travel, shopping, personal business, recreation, and 

commercial travel. 

Effectiveness 

Traffic calming techniques are most effective when implemented on an area-wide basis. 

By improving safety for pedestrians and bicyclists, traffic calming encourages walking 

and cycling. Some of these reductions may be captured in TCMs 9 and 19. It is 

uncertain how much additional emission reductions can be attributed specifically to 

traffic calming. To be conservative, no additional reductions are claimed, but traffic 

calming is considered an important support program for other bike/ped programs. 
Bay Area 2005 Ozone Strategy D - 69 Final Adopted – January 4, 2006 

Cost 

The cost of traffic calming ranges from $9 per square yard to $18 per square yard of 

street/sidewalk. These costs are outweighed by the benefits of reduced traffic accidents 

and congestion. In 1990, traffic accidents alone cost the nation up to $137 billion a year 

in directs costs, lost time and productivity. Surveys of local jurisdiction by the Institute of 

Traffic Engineers indicate that traffic calming projects reduce injury accidents by 20 - 50 

percent, depending on the type of treatment. 

Impediments 

If traffic calming is not implemented area wide but only in select and isolated streets, 

there is the potential for an increase in traffic in the surrounding areas due to trip 

diversion. 

Police and fire protection agencies may have concerns with barriers and other devices 

that slow their response times. However, experience in many communities has shown 

that close coordination between transportation planners and public safety officials can 

resolve most of these potential conflicts. Also, some studies have shown that when 

traffic calming leads to fewer traffic accidents, there are fewer emergencies needing a 

response. 

Cities and counties can include area-wide traffic calming policies in general or specific 

plans, or develop traffic calming plans, to ensure effective traffic calming measures in 

the overall area and minimize potential adverse affects. 

Other Impacts 

Traffic calming results in fewer vehicle and pedestrian accidents and injuries in areas 

where it is implemented. Lower traffic volumes on residential streets results in lower 

community noise levels. Traffic reductions on some streets may lead to more traffic on 

other streets without any traffic calming measures as diverted vehicles use alternative 

routes. Traffic calming can contribute to more livable neighborhoods and vibrant 

shopping areas. 

 
 

BAY AREA 

2005 OZONE STRATEGY 

APPENDIX E - FURTHER STUDY MEASURE 

DESCRIPTIONS 

FINAL ADOPTED 

JANUARY 4, 2006 

939 Ellis Street 

San Francisco, CA 94109 

(415) 771.6000 

www.baaqmd.gov
Bay Area 2005 Ozone Strategy E - 2 Final Adopted – January 4, 2006 

APPENDIX E - FURTHER STUDY MEASURE DESCRIPTIONS 

 

TABLE OF CONTENTS 

Further Study Measure FS 1: ADHESIVES AND SEALANTS................................... E - 3

Further Study Measure FS 2: ARCHITECTURAL COATINGS.................................. E - 5

Further Study Measure FS 3: COMMERCIAL CHARBROILERS .............................. E - 6

Further Study Measure FS 4: COMPOSTING OPERATIONS................................... E - 7

Further Study Measure FS 5: FOOD PRODUCT MANUFACTURING AND 

PROCESSING .......................................................... E - 8

Further Study Measure FS 6: LIVESTOCK WASTE.................................................. E - 9

Further Study Measure FS 7: LIMITATIONS ON SOLVENTS BASED ON RELATIVE 

REACTIVITY............................................................. E-11

Further Study Measure FS 8: SOLVENT CLEANING AND DEGREASING .............. E-12

Further Study Measure FS 9: EMISSIONS FROM COOLING TOWERS.................. E-14

Further Study Measure FS 10: REFINERY WASTEWATER TREATMENT 

SYSTEMS................................................................. E-15

Further Study Measure FS 11: VACUUM TRUCKS .................................................. E-17

Further Study Measure FS 12: VALVES AND FLANGES ......................................... E-18

Further Study Measure FS 13: WASTEWATER FROM COKE CUTTING 

OPERATIONS........................................................... E-19

Further Study Measure FS 14: NOx REDUCTIONS FROM REFINERY BOILERS .. E-20

Further Study Measure FS 15: STATIONARY INTERNAL COMBUSTION 

ENGINES.................................................................. E-21

Further Study Measure FS 16: ENCOURAGE ALTERNATIVE DIESEL FUELS....... E-23

Further Study Measure FS 17: MITIGATION FEE PROGRAM FOR FEDERAL 

SOURCES ................................................................ E-24

Further Study Measure FS 18: INDIRECT SOURCE MITIGATION PROGRAM....... E-25

Further Study Measure FS 19: FREE TRANSIT ON SPARE THE AIR DAYS .......... E-26

Further Study Measure FS 20: EPISODIC MEASURES ........................................... E-27
Bay Area 2005 Ozone Strategy E - 3 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 1: ADHESIVES AND SEALANTS 

Further Study Measure Description 

In 2003 and early 2004, the ARB, San Joaquin, Sacramento and Bay Area districts 

jointly undertook a rule comparison project for a number of source categories, including 

adhesives and sealants. The South Coast AQMD rule for adhesives appears to be the 

most stringent, particularly for architectural adhesives. Architectural adhesives 

encompasses a wide variety of adhesives used in residential and commercial 

construction: carpet adhesives, flooring adhesives, subfloor adhesives, tile adhesives, 

drywall adhesives, and multipurpose construction adhesives. The South Coast VOC 

limits range from 50 to 150 grams per liter (g/l) for various categories of architectural 

adhesives. 

In 1998, the ARB and California districts developed Reasonably Available Control 

Technology/Best Available Retrofit Control Technology (RACT/BARCT) VOC limits for 

adhesives and sealants. RACT/BARCT VOC limits range from 100 to 250 g/l for various 

categories of architectural adhesives. The Bay Area rule, Regulation 8, Rule 51: 

Adhesive and Sealant Products, meets the BARCT limits in the ARB document. 

Generally, most adhesive and sealant products that meet the RACT/BARCT limits will 

also meet the SCAQMD limits. VOC content for these products is dictated by 

formulation technology. Solvent-based products generally have a VOC content of 300-

400 g/l, and water-based products generally have a VOC content of 0-50 g/l. Reducing 

the VOC limits in rules will have little effect because most currently available solventbased products do not comply with either set of limits, and most water-based products 

comply with both sets of limits, so reducing the allowable VOC limits would not produce 

any emission reductions. A small subset of architectural adhesives are solvent-based 

products that have VOC contents in the 100-150 g/l liter range. These products 

generally use a mixture of water and hydrocarbon solvents and were typically formulated 

to meet the California RACT/BARCT limits. 

The largest category of architectural adhesives is subfloor adhesives formulated with 

solvent to allow bonding to wet or frozen lumber. These products meet the BAAQMD 

and BARCT VOC limit of 200 g/l. However, they would not comply with the South Coast 

AQMD limit of 50 g/l. In California, most wood frame construction relies upon green 

(wet) lumber. The South Coast 2000 staff reports states that the lower limits are feasible 

because of the warm climate of the Los Angeles area. The report also notes that 

relatively low-VOC polyurethane adhesives can bond wet and frozen lumber but fails to 

discuss the role of isocyanates from polyurethanes in allergic sensitization and asthma. 

In areas outside the Los Angeles basin, lower temperatures and higher humidity will 

cause curing difficulties for products meeting the SCAQMD limits. Consequently, a 50 

g/l VOC limit for the Bay Area is not feasible. 

In the rule comparison discussions, significant differences in inventory between the 

districts emerged. Specifically, the San Joaquin District has almost no area source 

adhesive emissions, which includes the architectural adhesives, whereas the Bay Area 

inventory has over 9 tons organic emissions per day from area source adhesives. When 

Bay Area staff developed Regulation 8, Rule 51: Adhesives and Sealants, the area 

source inventory was derived from the Rauch Guide to the US Adhesives and Sealants 

Industry, by the Rauch Associates, Inc., originally the 1990 edition. The Rauch Guide 
Bay Area 2005 Ozone Strategy E - 4 Final Adopted – January 4, 2006 

breaks down adhesives and sealants into nine categories, which allows some categories 

to be eliminated because they are either consumer uses and likely subject to the ARB’s 

consumer products standards, or used in sources that require a permit and would be 

included in the point source inventory. From the US totals, the Bay Area population 

percentage and control factors based on the rule requirements are applied to produce an 

area source inventory. Because of the discrepancy between inventories, joint further 

study among districts is recommended to reconcile these differences. 

References 

California Air Resources Board. 1998. "Determination of Reasonably Available Control 

Technology and Best Available Retrofit Control Technology for Adhesives and Sealants." 

Koressel, T., Charles McMurray Co. 2003. Personal communication. 

South Coast AQMD. 2002. "Final Staff Report: Proposed Amended Rule 1168-

Adhesives and Sealants" 

South Coast AQMD. 2000. "Staff Report: Proposed Amended Rule 1168-Adhesives and 

Sealant Applications" 

TIAX. 2003. Sacramento Regional Clean Air Plan Update: Control Measure D3. 

Walnut, F., TACC International. 2003. Personal Communication. 

 
Bay Area 2005 Ozone Strategy E - 5 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 2: ARCHITECTURAL COATINGS 

Further Study Measure Description 

The District amended Regulation 8, Rule 3: Architectural Coatings in 2001 based on the 

CARB Suggested Control Measure (SCM) for Architectural Coatings (June, 2000). The 

SCM was the product of nationwide surveys of available coatings conducted by CARB 

and discussion among districts, architectural and industrial maintenance coatings 

manufacturers, infrastructure owners and painting contractors. The Sacramento district 

was the first district to adopt amendments in June 2001, and the Bay Area adopted 

amendments in November 2001. 

The development of the SCM on which the amendments were based was directed by 

the California Air Pollution Control Officers Association (CAPCOA). CAPCOA further 

directed that CARB and the districts evaluate South Coast's future (later than 2004) VOC 

limits and/or other limits to achieve the maximum possible reductions from the 

architectural coatings category. CARB is currently evaluating new survey data, and 

investigating feasible VOC standards both on a mass basis and also on a reactivity basis 

following the same CARB/districts workgroup format. Districts are awaiting the results of 

the CARB surveys and data analysis and will work together to develop future reductions 

in VOC emissions from architectural coatings. The CARB/districts efforts are expected 

to be completed in 2005. 

References 

CAPCOA Statement of Principles and Positions on Architectural Coatings Regulations 

(10/28/99) 

SCAQMD Rule 1113: Architectural Coatings 

 
Bay Area 2005 Ozone Strategy E - 6 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 3: COMMERCIAL CHARBROILERS 

Further Study Measure Description 

In 1997, the South Coast AQMD adopted Rule 1138: Control of Emissions from 

Restaurant Operations. Rule 1138 requires that chain driven charbroilers install catalytic 

oxidation equipment to control emissions. The catalytic oxidizers control particulate 

matter and volatile organic compounds that are emitted from the cooking process. The 

South Coast determined that chain driven charbroilers to be the only type of restaurant 

operation for which control is cost effective, although further research is being conducted 

on under-fire charbroilers. In 2002, the San Joaquin Valley adopted Rule 4692: 

Commercial Charbroiling. Both rules have the same exemption criteria: charbroilers that 

cook less than 875 lbs of meat per week or emit less than 1 lb of emissions per day are 

not subject to the rule. 

The South Coast originally projected a cost effectiveness for this control measure of 

$4650 per ton for a combination of VOC and particulate matter. More recently, the San 

Joaquin APCD estimated a cost effectiveness of $3070 per ton combined VOC and PM 

reduced. However, for VOC alone, the cost effectiveness rises to $13,070. The South 

Coast assumed a control effectiveness of 90% and the San Joaquin APCD used figures 

for control efficiency of 83% and 86% for PM and VOC, respectively. Some additional 

research indicates that the emission reductions may be closer to 62%, which would raise 

the cost of pollutants reduced per ton 38%. 

The current inventory for VOC emissions from all cooking operations in the Bay Area is 

1.29 tons/day. Of that, based on a population-weighted comparison between the Bay 

Area and the San Joaquin Districts, emissions estimates from chain driven charbroilers 

are 0.08 tons/day VOC and 0.26 tons/day PM. A comparable rule would reduce 

emissions by 0.066 tons/day VOC and 0.22 tons/day PM. This is a de minimis amount 

for VOC alone. 

This control measure may not be justified for VOC alone, however, considering the 

potential to control particulate matter, it may be justified. Also, the South Coast's efforts 

regarding under-fire charbroilers, scheduled to be completed this year, may increase the 

potential emission reductions. 

References 

South Coast Rule 1138: Control of Emissions from Restaurant Operations and staff 

report, 11/7/1997, SCAQMD 

San Joaquin Rule 4692: Commercial Charbroiling and staff report, 3/21/2002, SJVAPCD 

 
Bay Area 2005 Ozone Strategy E - 7 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 4: COMPOSTING OPERATIONS 

Further Study Measure Description 

In January, 2003 the South Coast AQMD adopted Rule 1133.2: Emission Reductions 

from Co-composting Operations, to limit emissions of both VOC and ammonia. Cocomposting is the mixing of biosolids or manure with bulking agents to produce compost. 

Rule 1133.2 requires new co-composting operations to be enclosed and emissions 

controlled by 80%, and existing co-composting operations be enclosed and emissions 

controlled by 70%. Existing operations are given compliance dates between 2007 and 

2009, depending on throughput capacity. The rule does not apply to agricultural 

composting, greenwaste (gardening, agriculture and landscaping) composting, 

woodwaste composting, co-composting operations of less than 1,000 tons throughput 

per year or 35,000 tons per year throughput if no more than 20% biosolids. The rule is 

expected to reduce the South Coast composting emissions by 17.6%. 

The Bay Area does not have a specific category in the emission inventory for 

composting or greenwaste. Emissions are included within the category of "waste 

management, landfills, point or area sources" or "waste management, other.” The Bay 

Area requires a permit of a composting facility that processes 500 tons/year, lower than 

the South Coast exemption level for Rule 1133.2. The source code assigned to these 

operations varies, making an emissions estimate based on permitted sources uncertain. 

Based on the South Coast control measure and rule development staff report, the Bay 

Area inventory for composting operations is about 3.4 tons/day VOC and 2.35 tons/day 

ammonia (South Coast inventory numbers * 0.5). Consequently, this measure applied to 

the Bay Area would be expected to reduce VOC emissions by 0.6 tons/day. 

The South Coast Rule 1133.2 staff report indicates that the cost effectiveness for this 

rule ranges from $8700 to $10,000 per ton of ammonia and VOC reduced and from 

$23,000 to $26,500 per ton of VOC reduced. This is not very cost effective compared to 

most Bay Area rules for VOC, but within the range of acceptable costs for VOC and 

ammonia combined. However, as the South Coast AQMD gains experience in 

implementation of this rule, cost effectiveness may be found to be less. Also, additional 

benefits of particulate control from the reductions in ammonia (which reacts to form 

secondary particles) may make the cost effectiveness more attractive as a particulate 

control measure. 

References 

SCAQMD Rule 1133.2: Emission Reductions from Co-composting Operations and staff 

report, Jan. 10, 2003 

 
Bay Area 2005 Ozone Strategy E - 8 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 5: FOOD PRODUCT MANUFACTURING AND 

PROCESSING 

Further Study Measure Description 

The South Coast AQMD adopted Rule 1131: Food Product Manufacturing and 

Processing Operations, in September, 2000. The rule addresses any facility that emits 

more than 440 pounds of organic compound emissions per month that produces, 

formulates or configures food or food products, including spices, extracts, flavorings and 

colorings. Bakeries, wineries and breweries are not subject to the rule. VOC emitting 

processes found in food product manufacturing include distillation, extraction, reaction, 

blending, drying, crystallization, separation, granulation, filtration and extrusion. The 

South Coast rule limits solvents used in food processing to 120 grams VOC/liter or 

requires capture and control of emissions. Solvent used for sterilization of food products 

is limited to 400 grams VOC/liter and, after 2005, 200 grams VOC/liter. 

The South Coast rule projects an emission reduction of about 2 tons from an inventory of 

2.47 tons/day. In the Bay Area, the emissions from food preparation are contained in 

the emission inventory categories, "Other Food and Agricultural Processing," which 

includes coffee roasting, grain milling, sugar refining and pet food processing. The 

emission inventory lists organic emissions from this category at 0.3 tons/day. However, 

some operations subject to the South Coast rule, such as sterilization, reaction or 

distillation, may have source codes that put them into other categories in the Bay Area. 

The South Coast staff report notes that food processing operations were exempt from 

the South Coast permit system. In the Bay Area, some food processing operations are 

exempt, including non-restaurant cooking operations of less than 1000 tons per year 

throughput, dry food milling, grinding, handling and packaging equipment, and small 

coffee, cocoa and nut roasters. Because other food processing equipment is subject to 

permit requirements, it may already be controlled, reducing the potential emissions 

reductions. 

Based on the difference between the South Coast emission inventory and the Bay Area 

emission inventory, the differences in permitting regulations and the possibility that some 

sources in the Bay Area are already controlled, this measure is recommended for further 

study. 

References 

South Coast AQMD Rule 1131: Food Product Manufacturing and Processing 

Operations, and staff report, September, 2000. 

 
Bay Area 2005 Ozone Strategy E - 9 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 6: LIVESTOCK WASTE 

Further Study Measure Description 

The South Coast AQMD has proposed Rule 1127: Emission Reductions from Livestock 

Waste, based on control measure WST-01 in their 2003 Air Quality Management Plan. 

The proposed rule would control emissions from livestock waste (primarily dairies) by 

requiring wastes to be transported out of the district, controlled in an approved 

composting operation, processed in a controlled anaerobic digestor, or spread on 

agricultural land approved for the spreading of manure. In 1997, the SCAQMD adopted 

Rule 1186 that requires livestock operations to take certain measures to reduce 

particulate matter, but the rule does not address livestock waste. South Coast proposed 

Rule 1127 is designed to reduce emissions of particulate, ammonia (which forms aerosol 

particulate matter) and VOC. The measure estimates that a reduction in ammonia of 

50% is possible at a cost effectiveness of from $2000 to $5000 per ton ammonia. The 

ammonia concentration is approximately three times the VOC concentration, so as a 

VOC only control measure, cost effectiveness would range from $6000 to $15,000 per 

ton. 

The Bay Area emission inventory for livestock waste is 29.81 tons/day total organic 

compounds. Most of that is methane. Reactive organic emissions are 8% of that total, 

2.38 tons/day. Of that inventory of emissions from total livestock waste, approximately 

13% (0.31 tons/day) is from dairy cattle, the basis of the South Coast measure. The 

ARB has raised questions about the emissions estimates, so ROG (VOC) emissions 

may be lower. Accordingly, the capital costs associated with control of VOC emissions 

would make the measure less cost effective. 

The focus of the South Coast measure is to control particulate and ammonia. The 

measure has more utility for control of particulate and ammonia, a fine particulate 

precursor, than for VOC, and particularly so in the South Coast where dairy farms are 

concentrated in an area that is upwind from monitoring stations that record high PM10 

levels. The South Coast control measure notes that a decrease in ammonia and VOC 

emissions of 2 to 3% per year is likely due to the increased urbanization of the region 

(which will decrease the number of dairies) and water quality control regulations that 

require manure to be removed from dairies bi-annually, or incorporated into soil at 

agrometric rates as quickly as possible. In the Bay Area, many farms may already 

comply with the proposal by segregating waste and incorporating manure into soil at 

agronomic rates. In addition, incentives already exist to sell electricity generated by a 

methane digester into the power grid. Any study should investigate these incentives as 

a cost effective means of control. Due to uncertainty in the VOC inventory for this 

category, and the cost effectiveness of a command and control measure, this measure is 

not recommended as a control measure at this time. However, because of the potential 

particulate matter benefits, it is recommended for further study. 
Bay Area 2005 Ozone Strategy E - 10 Final Adopted – January 4, 2006 

References 

“PG&E vs Cow Power Dairy Farmers Say the Utility Opposes Energy from Methane 

Gas” Martin, Glen, SF Chronicle, June 27, 2004 

SCAQMD Final 2003 Air Quality Management Plan, Control Measure #2003 WST-01, 

SCAQMD, August, 2003 

Air Emissions Action Plan For California Dairies, ad hoc Dairy subcommittee of the 

SJVUAPCD, May, 2003 
Bay Area 2005 Ozone Strategy E - 11 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 7: LIMITATIONS ON SOLVENTS BASED ON 

RELATIVE REACTIVITY 

Further Study Measure Description 

Further Study Measure F8 in the 2000 Clean Air Plan suggested the potential to make 

regulations more effective by replacing VOC limits, measured in mass VOC per volume 

of product, with limits based on the relative contribution to ozone formation of each of the 

organic species that make up the VOC of a product, or the "relative reactivity." This 

further study measure would examine whether a relative reactivity approach would be 

either more cost effective than mass reductions in VOC content or allow reductions 

where further reductions in mass might not be technically feasible. 

The differences in ozone produced by different species of organic compounds have 

been recognized for many years, however, the ability to quantify the relative 

contributions to ozone formation of the vast number of organic species has only recently 

been developed. The California Air Resources Board, working with scientists and 

representatives of industry and air agencies, have developed a scale of incremental 

reactivities that is used in their aerosol paint regulation (Regulation for Reducing the 

Ozone Formed from Aerosol Coating Product Emissions). Currently, CARB staff have 

requested speciation data for architectural and automotive refinish coatings to consider 

whether a relative reactivity approach might be advantageous for these two source 

categories. US EPA staff is involved in CARB's processes to consider relative reactivity 

based regulations, but they have yet to approve CARB's consumer product rules into the 

SIP, including the aerosol paint rule. District staff participate in discussions of reactivity 

as it relates to potential regulatory activity. At this time, however, because the potential 

for emission reductions (or ozone formation reductions) cannot be assessed for any 

source category, this control measure is recommended for further study. 

References 

17 California Code of Regulations, Section 94520, 94700, Regulation for Reducing the 

Ozone Formed from Aerosol Coating Product Emissions, and Table of Maximum 

Incremental Reactivity 

Further Study Measure 8, 2000 Bay Area Clean Air Plan, BAAQMD, December, 2000 

 
Bay Area 2005 Ozone Strategy E - 12 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 8: SOLVENT CLEANING AND DEGREASING 

Further Study Measure Description 

In 2003 and early 2004, the ARB, San Joaquin, Sacramento and Bay Area districts 

jointly undertook a rule comparison project for a number of source categories, including 

solvent cleaning and degreasing. The discussion included vapor degreasing, cold 

cleaning and wipe cleaning. The joint conclusion was that vapor degreasing, done 

largely with negligibly photochemically reactive solvents, was not a source category that 

was likely to produce any significant emissions reductions. Cold cleaning and wipe 

cleaning are discussed below. 

Cold Cleaning

Cold cleaning describes the use of cleaning solution in a tank or container into which a 

part to be cleaned is immersed, or a remote reservoir cleaner that pumps some cleaning 

solution over a part to be cleaned that then drains back into the reservoir. All districts 

except the South Coast have adopted a 50 gram/liter VOC standard for cleaning 

solutions, and the South Coast has adopted a 25 g/l VOC standard. The South Coast, in 

adoption of a 50 g/l VOC standard in 1997, used an EPA emission factor of 1.45 pounds 

VOC/day/cold cleaner. In 2002, the South Coast staff report assumed a 50% reduction 

in the remaining emissions because of the adoption of a 25 g/l VOC standard. 

Bay Area staff believe that the EPA emission factor used by South Coast for rule 

adoption, and subsequently by other districts for control measures, is too high because it 

did not account for the low volatility of the mineral spirits blends used in most mineral 

spirits cold cleaners and remote reservoir cleaners at the time the rule was adopted. In 

1998, the Bay Area adopted a 50 g/l VOC standard except for one cold cleaner in each 

facility. At that time, Bay Area staff estimated emissions from these cleaners based on 

information provided by the Safety Kleen Corporation, the dominant cold cleaner solvent 

provider. Emissions were estimated by a mass balance approach, considering 1) the 

percent market share that Safety Kleen had in 1998; 2) the number of mineral spirit cold 

cleaners Safety Kleen leased and serviced in the Bay Area; 3) the amount of solvent 

they supplied and recycled; and; 4) an estimation of the sludge and foreign substance in 

their return solvent. From that data, we developed an emission factor of 0.6 pounds 

VOC/day/cold cleaner, significantly less than the 1.45 lb/day factor used by the South 

Coast and other districts. In 2002, the Bay Area District amended the standards so that 

all cold cleaners, with some exceptions for specific substrates consistent with other 

districts, would have to meet the 50 g/l VOC limit. 

Using the methodology in the 2002 Bay Area staff report to calculate emissons 

reductions for a 25 g/l VOC standard, the additional emissions reductions to be gained 

from a rule amendment would be 0.0743 tons per day, less than de minimis. In addition, 

the South Coast, in their staff report, estimated that 70% of cleaning solutions available 

to comply with their 50 g/l VOC standard would also meet their 25 g/l VOC standard. 

Consequently, the potential emissions reductions would be only 30% of the above total, 

or 0.022 tons/day. However, because of the discrepancy in how emissions are 

calculated between districts, joint further study is needed to examine emissions 

calculations for cold cleaners within California. 
Bay Area 2005 Ozone Strategy E - 13 Final Adopted – January 4, 2006 

Wipe Cleaning

Wipe cleaning involves wetting a rag, cloth or paper with a cleaning solution and wiping 

grease or soils from a part by hand. The South Coast AQMD adopted a 25 g/l VOC 

standard for wipe cleaning concurrent with their adoption of a 25 g/l VOC standard for 

cold cleaning. 

In 2002, the Bay Area District amended 5 rules to incorporate a 50 gram/liter VOC 

standard for wipe cleaning operations. These rules regulate the surface preparation and 

coating of metal parts, metal furniture and large appliances, plastic parts, marine vessels 

and general solvent and surface coating. 

In calculation of the emissions attributable to wipe cleaning in Bay Area facilities, staff 

recalculated the emission inventory for area sources because it was developed from 

1993 data and did not account for the subsequent impact of the Montreal Protocol on 

Ozone Depleting Substances and EPA’s finding that acetone was a negligibly 

photochemically reactive. These two factors have led to a surge in the development of 

water-based cleaning applications, and a shift to the use of solvents such as MEK or 

alcohol to acetone, significantly reducing reactive organic emissions. 

The adoption of a 25 g/l VOC standard for wipe cleaning has been calculated to reduce 

emissions by 0.0756 tons per day, not including any cleaning solutions that would 

already meet the 25 g/l standard. If, as South Coast staff estimated for cold cleaners, 

70% of the solutions in use already meet a 25 g/l VOC standard, the emissions 

reductions could be only 0.023 tons per day. This is less than de minimis, however, 

further study is needed on a statewide basis to update the study on which the area 

source inventory was derived. 

References 

BAAQMD Analysis of SMAQMD Suggested Changes to BAAQMD Rules, attachment to 

letter, B. Norton to N. Covell, Nov. 12, 2002 

South Coast AQMD Proposed Amended Rule 1122 Staff Report, South Coast AQMD, 

July, 2001 

Staff report, Proposed Amendments to Regulation 8, Rules 4, 14, 19, 31, 43, BAAQMD, 

Oct. 2002 

Staff Report, Proposed Amendments to Reg. 8, Rule 16: Solvent Cleaning Operations, 

BAAQMD, Sept. 2002 

Staff Report, Proposed Amendments to Reg. 8, Rule 16: Solvent Cleaning Operations, 

BAAMQD, Sept. 1998 

 
Bay Area 2005 Ozone Strategy E - 14 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 9: EMISSIONS FROM COOLING TOWERS 

Further Study Measure Description 

The emission inventory for refinery cooling towers shows 0.45 tons/day organic 

emissions, based on cooling water throughput from cooling towers with District permits. 

AP-42 emission factors of 6 lbs organic emissions per million gallons water throughput 

were used in this calculation. This assumes organic compound leaks into the cooling 

water system are not minimized. However, if leaks are minimized, the AP-42 emission 

factor is 0.7 lb organic emissions per million gallons water. Further study is needed to 

determine whether leaks from cooling towers are currently minimized and whether there 

is any potential for emission reductions from regulations. 

References 

Compilation of Air Pollution Emission Factors (AP-42), US EPA, 1995 

 
Bay Area 2005 Ozone Strategy E - 15 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 10: REFINERY WASTEWATER TREATMENT 

SYSTEMS 

Further Study Measure Description 

Emissions from refinery wastewater systems were being studied through further study 

measure FS-9 from the 2001 Ozone Attainment Plan. Refinery wastewater systems 

basically consist of collection systems to collect and transport hydrocarbon-containing 

process water, physical separation systems to separate oil and water by mechanical 

means, and finally, biological and chemical processes to treat effluent. District staff 

studied emissions from the wastewater collection systems. The physical separation 

systems, including oil-water separators and dissolved air floatation units, are already 

controlled by Regulation 8, Rule 8. An amendment to Regulation 8, Rule 8: Wastewater 

(Oil-Water) Separators was adopted in September 2004 resulting in an estimated 

reduction in ROG emissions by 2.1 tons/day from this portion of the wastewater system. 

This further study measure focused on the effluent treatment systems, including 

wastewater ponds. 

Water entering the treatment systems after physical separation tends to have low 

organic content, but most of these organic compounds must be removed by biological 

degradation. Some of these compounds are volatilized and emitted to the atmosphere. 

Reg. 8-8 does not require control of biological or chemical treatment portions of 

wastewater systems. Water is treated until it meets the San Francisco Bay Regional 

Water Quality Control Board discharge requirements. 

Emissions for one refinery’s large treatment pond with a flow rate of 10 million gallons 

per day have been estimated, using EPA’s WATER8 model, to be approximately 150 

pounds per day. Total refinery wastewater treatment system emissions for the Bay Area 

refineries were estimated to be 0.24 tons per day, including emissions from dissolved air 

or nitrogen flotation units, biological treatment units, clarifiers, and equalization ponds. 

The emissions estimates were made by a combination of water sampling, flux chamber 

testing and calibrated models. A emissions study was initiated through a cooperative 

workgroup process that includes refinery personnel, ARB, District and SF Bay Regional 

Water Quality Control Board staff, environmental groups and consultants with expertise 

in developing emissions models for wastewater systems. The workgroup met in April, 

June, September, and October 2005. 

In addition to developing emissions estimates, staff estimated potential emissions 

reductions and costs of available controls. Staff estimated that emissions could be 

reduced by about 65%, or 0.14 tons per day. Available control technologies reviewed 

were steam strippers, liquid phase carbon adsorption units, and doming treatment tanks. 

Steam strippers and carbon adsorption would remove hydrocarbons from the 

wastewater, but would require emissions to be vented into new or existing control 

equipment. Doming tanks is applicable to only two facilities. Doming would capture 

emissions above the treatment tanks, but would also require use of new or existing 

emissions control equipment. It was found that the costs would be over $1 million per 

ton VOC reduced for the steam stripper or carbon adsorption. Doming would be less 

expensive, at $25,000 per ton of emissions, not considering costs of controls, but, 

because of limited applicability, would only reduce emissions by 0.025 tons per day. 
Bay Area 2005 Ozone Strategy E - 16 Final Adopted – January 4, 2006 

Based on the limited emissions reductions and high costs, staff did not recommend 

further regulatory controls for refinery wastewater systems at this time. A public 

workshop to discuss the report was held on October 27, 2005 and a public hearing 

before the District’s Board of Directors was held on November 16, 2005. The Board 

adopted the staff recommendation. 

References 

Staff Report, Further Study Measure 9: Refinery Wastewater Treatment Systems, 

BAAQMD, Nov. 2005 

Draft Technical Assessment Document: Potential Control Strategies to Reduce 

Emissions from Refinery Wastewater Collection and Treatment Systems, CARB and 

BAAQMD, Jan., 2003 
Bay Area 2005 Ozone Strategy E - 17 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 11: VACUUM TRUCKS 

Further Study Measure Description 

This measure was analyzed in the 1994 Clean Air Plan as Control Measure B6: Control 

of Emissions from Cleaning Up Organic Liquids. The analysis concluded that the 

measure would not be cost effective. However, in addition to cleaning up spills, vacuum 

trucks have been observed in frequent use as part of some refinery operations, such as 

removing water from tank surfaces, cleaning of oil-water separators, and transport of 

sludges, slop oils and tank bottoms. At one refinery, it was estimated that over 

1,000,000 gallons of hydrocarbon containing liquids were put in vacuum trucks per 

month, which is the equivalent of approximately 145,000 gallons of hydrocarbons per 

month. On a volume basis, at least 1.5 gallons of air is emitted for every gallon of 

vacuum tank capacity. 

In some cases, emissions from the tanks are controlled by the use of a carbon canister 

that adsorbs organic vapors as they are emitted from the truck tank, primarily to control 

odors. Further study can determine the emissions from these activities and whether 

control of emissions is more cost effective than the 1994 analysis found. 

References 

1994 Clean Air Plan Control Measure B6: Control of Emissions from Cleaning Up 

Organic Liquids 

 
Bay Area 2005 Ozone Strategy E - 18 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 12: VALVES AND FLANGES 

Further Study Measure Description 

In 2003 and early 2004, the ARB, San Joaquin, Sacramento and Bay Area districts 

jointly undertook a rule comparison project for a number of source categories, including 

valves and flanges. Valves and flanges are typically found at refineries and chemical 

plants, but also found in other petroleum and gas production facilities. The review found 

that the Bay Area’s existing Regulation 8, Rule 18: Equipment Leaks, is the most 

stringent regulation in the state. Reg. 8, Rule 18 was amended on January 21, 2004 to 

fulfill the provisions of control measure SS-16 from the 2001 Ozone Attainment Plan. 

During the rule development, staff identified a number of different areas for potential 

future study to further reduce emissions from valves and flanges. These areas include: 

1) setting a maximum leak limit for components; 2) targeting minimization and repair 

periods; 3) accelerating equipment replacement for equipment found leaking frequently; 

4) requiring inaccessible equipment to be replaced by superior technologies; 5) 

quantifying mass emissions and imposing emissions caps; 6) increasing inspection 

frequencies; and 7) incorporating remote sensing technologies to identify the largest 

leaking components. 

References 

Staff Report, Proposed Amendments to Regulation 8, Rule 18: Equipment Leaks, 

January, 2004, BAAQMD 

 
Bay Area 2005 Ozone Strategy E - 19 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 13: WASTEWATER FROM COKE CUTTING 

OPERATIONS 

Further Study Measure Description 

Refineries operate high pressure water pumps to remove or “cut” coke from coking 

drums. During the investigation of Further Study Measure FS 9: Refinery Wastewater 

Systems in the 2001 Ozone Plan, it was noted that coke cutting operations at some 

facilities generated significant quantities of wastewater. This wastewater, at elevated 

temperatures, is often recycled. The wastewater from coke cutting is not part of the 

refinery wastewater collection and treatment system. One possible method of control 

would be to include coke cutting wastewater in the existing collection and treatment 

system. Additional research needs to be conducted to determine whether coke cutting 

wastewater contains significant quantities of VOC and whether there is any potential for 

emissions reductions from these operations. Because of these unknowns, it is 

recommended that coke cutting operations be studied. 

References 

Draft Technical Assessment Document: Potential Control Strategies to Reduce 

Emissions from Refinery Wastewater Collection and Treatment Systems, CARB and 

BAAQMD, Jan., 2003 
Bay Area 2005 Ozone Strategy E - 20 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 14: NOX REDUCTIONS FROM REFINERY 

BOILERS 

Further Study Measure Description 

The measure is based on the San Joaquin Valley Unified APCD’s Rule 4306 – Boilers, 

Steam Generators, and Process Heaters – Phase 3: a five-ppm NOx limit corrected to 

3% O2, or 0.0062 lb/MMBtu standard for large refinery boilers and process heaters 

(larger than 110 MMBtu). This limit is much lower than that allowed in Bay Area 

Regulation 9, Rule 10: Nitrogen Oxides and Carbon Monoxide from Boilers, Steam 

Generators and Process Heaters in Petroleum Refineries. The Bay Area limit of 0.033 

lb/MM BTU (approximately 30 ppm) was adopted in 1994. The San Joaquin limit in Rule 

4306 was adopted in 2003 and represents the most stringent rule in California. 

The Bay Area Rule 9-10 applies only to refinery boiler units. When the rule was 

adopted, averaging among units was considered the only cost effective way to achieve 

the regulatory standards. Many of the units are old, low-NOx burner technology did not 

exist for some, and some are in locations where there is not enough space to add 

selective catalytic reduction (SCR) units. Newer units, however, are subject to lower 

BACT limits for NOx and are not part of the average. To properly determine the 

feasibility and appropriateness of implementing a lower NOx limit on refinery boilers in 

the Bay Area, at a minimum, several factors need to be evaluated: 

• A precise inventory of refinery boilers; 

• A determination of the type, age, retrofit ability of; and the nature of the 

emissions from these boilers; 

• The cost effectiveness of retrofits and replacement technologies; 

• The contribution to emissions of the boilers that are currently exempt from Rule 

9-10; and 

• The inventory of non-refinery boilers of similar size in use in the District. 

References 

San Joaquin Valley Unified APCD Rule 4306 – Boilers, Steam Generators, and Process 

Heaters – Phase 3. 

Staff Report, Regulation 9, Rule 10: Nitrogen Oxides and Carbon Monoxide from 

Boilers, Steam Generators and Process Heaters in Petroleum Refineries. 
Bay Area 2005 Ozone Strategy E - 21 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 15: STATIONARY INTERNAL COMBUSTION 

ENGINES 

Further Study Measure Description 

Gaseous Fuel Fired Engines

The District regulates NOx emissions from internal combustion engines under 

Regulation 9, Rule 8, which imposes NOx limits on engines fired with gaseous fuels. 

Reg 9-8 was adopted in 1993 pursuant to CARB pollution transport regulations 

(California Code of Regulations beginning at section 70600). Those regulations required 

the BAAQMD to adopt by 1994 BARCT for source categories that collectively amounted 

to 75% of the 1987 nitrogen oxides emission inventory. Because the majority of IC 

engine emissions came from approximately 60 large engines fired with gaseous fuels 

located at wastewater treatment facilities, landfills, and refineries, Reg 9-8 imposed 

controls only on gaseous-fueled engines. Collectively, these engines were estimated to 

emit 9 tons per day of NOx, and the rule was estimated to reduce emissions by 8.1 tons 

per day. 

Under Reg 9-8, engines fired with fossil-derived fuels must meet a NOx limit of 56 ppm if 

rich burn and 140 ppm if lean burn. (Current BARCT limits would be, respectively, 25 

ppm, or alternatively 96% reduction, and 65 ppm, or alternatively 90% reduction.) 

Engines fired with waste-derived fuel must meet a 140 ppm limit if lean burn and 210 

ppm if rich burn. Current BARCT limits would be 65 ppm and 50 ppm respectively, or 

alternatively, 90% reduction for either. The inventory currently shows that NOx 

emissions from stationary IC engines fired with gaseous fuels are 2.37 tons per day, 

including engines subject to Reg 9-8 as well as smaller engines not subject to the rule. 

District BACT for engines requires gaseous fuel except where impractical. 

Emission reductions from engines fired with gaseous fuels cannot be easily estimated. 

The CARB BARCT limits include alternative percentage reduction limits that allow 

compliance through a demonstration that, though an engine may not meet a specified 

exhaust concentration limit, emissions have been reduced by a specified percentage. 

Many of the engines are likely to comply with the BARCT alternative percentage 

reduction requirements so that the BARCT limits would produce no emission reduction. 

For other engines, emission reductions cannot be easily estimated: engine-by-engine 

calculations would be required, and emission reductions may be minor. 

Liquid Fuel Fired Engines

NOx emissions from stationary liquid-fueled IC engines in the Bay Area are shown in the 

most recent BAAQMD inventory to be 4.6 tons per day. Virtually all stationary liquidfueled engines in the BAAQMD are compression-ignited engines, almost all of which are 

fueled with diesel oil. The BAAQMD inventory for these engines is based on the 

inventory developed by CARB for the stationary diesel ATCM. The CARB/BAAQMD 

inventory shows approximately 4100 diesel engines rated 25 hp or higher in the 

BAAQMD, of which approximately 3800 are used to drive backup generators or backup 

pumps. These are emergency standby engines which are exempt from the 

requirements of Reg 9, Rule 8. These 3800 engines account for about one-fourth of all 

NOx emissions from stationary sources under the District’s jurisdiction. Many of the 

backup engines in the BAAQMD have been installed since 2000, when permits became 

mandatory for existing and new backup engines of at least 50 hp. New engines have 

been required to meet BACT NOx limits set at CARB's Tier 1 limit of 6.9 g/bhp-hr. 
Bay Area 2005 Ozone Strategy E - 22 Final Adopted – January 4, 2006 

Based on BAAQMD permit data, the CARB inventory appears to be fairly reliable in its 

population estimates for backup engines. 

According to the CARB inventory, approximately 300 diesel engines are used to drive 

prime generators, prime pumps, or for other purposes. These engines account for 

approximately three-fourths of all NOx emissions (3.3 tons per day) from liquid-fueled 

engines and would be the primary target for controls. We believe this number greatly 

overstates the number of such engines in the Bay Area. This discrepancy arises 

because CARB, in determining how many engines should be classified as prime 

engines, relied on data from four air districts, including two (San Joaquin and South 

Coast) that have large numbers of these engines in operation in petroleum production, 

an activity of no significance in the Bay Area. 

BAAQMD permit data shows that there are 495 engines flagged as non-standby 

engines. However, an examination of the data shows that some are, in fact, standby 

engines and a much larger number are used only intermittently. The permit data show 

that cities and counties have a large number of diesel generators that may run 

temporary lights for street repair, etc. Of the 495 non-standby engines, 70 of them have 

emissions of at least 1 pound of NOx per day, and only 47 of them have emissions of 10 

pounds of NOx per day. These are the prime engines that are of concern. The 

collective emissions estimate for those engines of greater than one pound NOx per day 

is 1294 lbs per day, 0.65 tons/day, confirmation that the CARB inventory overstates the 

number of diesel-fired prime engines. 

The California Air Resources Board adopted the stationary diesel ATCM on January 20, 

2004. District imposed NOx controls on liquid-fueled engines may not produce emission 

reductions beyond those that are likely to be achieved through the implementation of the 

ATCM. The ATCM will result in the replacement of virtually all existing prime engines by 

2011. All new engines will have to meet BACT both for particulate matter and for ozone 

precursors (VOC and NOx). If modifications to existing District Regulation 9, Rule 8 is 

recommended and will not cause regulatory conflict with the ATCM, it will be included for 

further study. 

References 

California Air Resources Board. 2001. "Determination of Reasonably Available Control 

Technology and Best Available Retrofit Control Technology for Stationary Spark-Ignited 

Internal Combustion Engines." 

California Air Resources Board. 2003. "Staff Report: Initial Statement of Reasons for 

Proposed Rulemaking, Adoption of the Proposed Airborne Toxic Control Measure for 

Stationary Compression-Ignition Engines." 

Marr, L.C., Harley, R.A. 2002. "Spectral analysis of weekday-weekend differences in 

ambient ozone, nitrogen oxide, and non-methane hydrocarbon time series in California." 

Atmospheric Environment 36, 2327-2335. 

Sacramento Metropolitan AQMD. Rule 412. 

San Joaquin Unified APCD. 2003. "Final Draft Staff Report: Proposed Amendments to 

Rule 4701 (Internal Combustion Engines - Phase 1) and Rule 4702 (Internal Combustion 

Engines - Phase 2)" 

San Joaquin Unified APCD. Rules 4701 and 4702. 

South Coast AQMD. Rule 1110.2. 

Ventura County APCD. Rule 74.9. 
Bay Area 2005 Ozone Strategy E - 23 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 16: ENCOURAGE ALTERNATIVE DIESEL FUELS 

Further Study Measure Description 

Biodiesel

The District is currently conducting a feasibility study and pilot project to explore the 

potential air quality benefits of using biodiesel fuel in place of conventional petroleum 

diesel. The study will quantify the recoverable biodiesel feedstock from Bay Area 

sources, assess the environmental benefits (including air emission benefits) from these 

sources, identify production technology and costs, prepare a marketing plan, and identify 

obstacles and corresponding solutions to increasing biodiesel use in the Bay Area. The 

pilot project would demonstrate conversion of local feedstocks to biodiesel, use of the 

biodiesel in local fleets, and compare air pollutant emissions resulting from the use of the 

pilot project biodiesel to emissions from use of petroleum diesel in local fleets. While 

biodiesel has been shown to reduce emissions of particulates, reactive organic gases 

and toxic air contaminants, it can increase emissions of oxides of nitrogen. One 

important element of the District’s feasibility study and pilot project is to explore ways to 

achieve emission reductions for oxides of nitrogen. The District will evaluate results of 

the study and project before determining whether and how to promote biodiesel use in 

the Bay Area. 

Water/Diesel Emulsion 

The ARB verified the emission reductions of Lubrizol’s PuriNOx water/diesel emulsion in 

January 2001. In March 2004, the ARB released a report assessing the emission 

characteristics of PuriNOx. On average, emissions of NOx and PM were reduced 14% 

and 58 %, respectively, while hydrocarbon emissions increased by 87%. A significant 

contribution to air quality from PuriNOx is in the reduction of diesel PM. ARB identified 

diesel PM as a toxic air contaminant that accounts for 70% of the toxic risk from all 

identified toxic air contaminants. While PuriNOx was shown to increase emissions of 

some toxic air contaminants, such as formaldehyde, acetaldehyde, BTEX, 1,3-

butadiene, and some polycyclic hydrocarbons, the benefits from reducing diesel PM 

were significantly greater than the risks posed by the increase in other toxic air 

contaminants. The District will consider appropriate methods to promote the use of 

water/diesel emulsified fuels in the Bay Area. 
Bay Area 2005 Ozone Strategy E - 24 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 17: MITIGATION FEE PROGRAM FOR FEDERAL 

SOURCES 

Further Study Measure Description 

The regulation of emissions from ships, aircraft, trains, and off-road farm and 

construction equipment less than 175 hp is under exclusive federal jurisdiction and 

therefore pre-empted from State and local air district authority. Existing and projected 

Federal regulations for these pre-empted sources are not expected to achieve significant 

emission reductions in the near term. The ARB’s emission inventory for ships, aircraft 

and trains in the Bay Area is estimated to be approximately 51.9 tpd of NOx and 9.0 tpd 

of ROG in 2005. 

The Mitigation Fee Program, adopted into the South Coast AQMD’s 2003 AQMP, but not 

yet implemented, would charge an air quality impact fee to sources pre-empted from 

State and local air district authority under the federal Clean Air Act. The proposed 

method of control would first require the EPA or other federal agencies to appropriate 

funds or enable collection of fees by the SCAQMD in lieu of controlling these sources 

through more stringent federal regulations. The SCAQMD has the authority to collect 

fees based on emissions under the Lewis Presley Air Quality Management Act; 

however, implementation of this control measure by the SCAQMD may require 

additional legislation. The SCAQMD would use the impact fees to fund and/or 

implement cost-effective emission reduction projects from both federal and non-federal 

sources. The District will monitor SCAQMD’s progress in implementing this program, 

and will evaluate the feasibility of implementing such a program in the Bay Area. The 

cost effectiveness of this measure in the Bay Area has not been determined. 

A second opportunity for mitigation of federal sources may occur through the 

implementation of the State of California’s Goods Movement Action Plan currently being 

developed by the Business, Transportation and Housing Agency and the California 

Environmental Protection Agency. The Action Plan will identify statewide priorities for 

infrastructure improvements and environmental mitigations that will simultaneously and 

continually improve freight movement and reduce impacts on local communities. A main 

goal of this effort is to ensure adequate funding to reduce emissions from ships, trains, 

trucks and other sources is part of major infrastructure projects. The Air District and 

MTC are active participants in the development of the Action Plan. The initial plan will 

be available by the end of 2005, with additional development work taking place during 

the first half of 2006. 
Bay Area 2005 Ozone Strategy E - 25 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 18: INDIRECT SOURCE MITIGATION PROGRAM 

Further Study Measure Description 

Indirect sources are development projects that generate vehicle trips and thus indirectly 

cause air pollutant emissions. Health & Safety Code Section 40716 states that air 

districts may "...adopt and implement regulations to...reduce or mitigate emissions from 

indirect and areawide sources of air pollution," but also states, "Nothing in this section 

constitutes an infringement on the existing authority of counties and cities to plan or 

control land use, and nothing in this section provides or transfers new authority over 

such land use to a district.” 

Some small, single-county California air districts have implemented limited indirect 

source control (ISC) requirements. Most California air districts currently limit their 

indirect source control activities to review of CEQA documents and, occasionally, 

technical guidance. No multi-county, regional air districts currently have ISC programs 

beyond CEQA commenting and limited technical assistance. 

San Joaquin Valley Unified APCD staff has evaluated the option of adopting indirect 

source rules to reduce emissions of PM10 and ozone precursors. Rule 9510 establishes 

provisions for review of development projects and require implementation of mitigation 

measures and/or payment of fees. Rule 3180 establishes the fee schedule. 

SJVUAPCD Board of Directors adopted Rules 9510 and 3180 at a hearing on December 

15, 2005. Implementation of the rules is pending likely litigation. 

In October 2005, Sacramento Metro AQMD adopted a new CEQA policy to implement 

an EIR mitigation fee program. Lead agencies whose projects exceed SMAQMD’s 

adopted significance threshold for construction emissions and who cannot mitigate these 

impacts to a less-than-significant level on-site are required to pay a mitigation fee that 

funds off-site mitigation projects, such as construction equipment engine retrofits, engine 

repowers, and the purchase of alternatively-fueled construction equipment. 

The Air District currently implements various programs to reduce emissions from indirect 

sources, including: review and comment on CEQA documents; promotion of air quality 

elements in local plans; Transportation Fund for Clean Air grants for bicycle facilities, 

traffic calming, shuttles and other projects; cooperation with other regional agencies and 

stakeholder groups in the Smart Growth Strategy/Regional Livability Footprint project. 

The Air District will evaluate ways to enhance these programs and study other options to 

further reduce emissions from new and existing land uses. The primary goal of the 

program would be to encourage land use development projects located and designed in 

such a way as to reduce vehicle use. Examples include infill development, mixed uses, 

increased densities near transit facilities, street design to encourage walking and cycling, 

etc. A secondary goal could potentially include providing funds (e.g., from air quality 

mitigation fees) for air quality mitigation measures such as transit improvements, 

shuttles, bicycle and pedestrian facilities, retrofitting or repowering heavy-duty diesel 

vehicles, etc. Potential program options that could be evaluated include Air District 

rules, enhanced outreach to local government, expanded CEQA review, or other 

programs. The Air District will monitor the progress of SJVUAPCD and SMAQMD with 

developing indirect source rules and fees in order to determine the viability of such a 

program in the Bay Area. 
Bay Area 2005 Ozone Strategy E - 26 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 19: FREE TRANSIT ON SPARE THE AIR DAYS 

Further Study Measure Description 

Various transit districts around the United States have implemented free or reduced 

transit fares on ozone alert days. In the Bay Area, the Air District and MTC have 

implemented several pilot programs involving free transit service on Spare the Air (STA) 

days: a 1996 program with Santa Clara VTA, a 2003 and 2004 program with LAVTA, a 

2004 program with BART, and a 2005 program with many additional Bay Area transit 

providers. 

The 1996 VTA program involved distribution of VTA transit vouchers at participating 

worksites on STA days. The program was moderately successful, and also identified a 

number of enhancements to improve effectiveness, particularly the need for better 

marketing and more simplified implementation. Under the 2003 LAVTA program, all 

rides on all of LAVTA's Wheels routes were free on STA days. Survey data showed 

increases in ridership on STA days. The program continued in 2004. 

Under the BART program, BART agreed to provide free rides during the morning 

commute for up to the first five weekday Spare the Air days in 2004. $2 million in CMAQ 

and TFCA funding were committed to the project in 2004, which provided roughly 

$312,000 per day for BART’s costs and approximately $450,000 for marketing and 

program evaluation. During the 2005 ozone season, the Air District and MTC have 

committed $4 million to provide free morning transit service on 19 transit operators in the 

region, including all major operators, on the first five, non-holiday, weekday Spare the Air 

Days. 

In 2002, Air District staff calculated rough estimates of the costs and potential emission 

reductions of providing free rides on all Bay Area transit systems (excluding ferries) on 

STA days. Approximate costs were estimated to be $1.1 million - $1.3 million per day. 

Approximate emission reductions, assuming 5% and 15% increases in ridership, were 

as follows: ROG, 1.2 - 3.5 tpd; NOx, 1.5 - 4.6 tpd. MTC also evaluated such a program 

in 2002 and estimated costs to be $1.5 million per day and emission reductions (15% 

ridership increase) to be: ROG, 0.7 tpd; NOx, 1 tpd. Thus, emission reductions from free 

transit on STA days could be significant (particularly for a TCM), but costs would be very 

high. 

The Air District and MTC will study the feasibility of providing free transit service on STA 

days, focusing particularly on: 1) identifying the most cost-effective routes, and 2) 

identifying federal, State, regional, local and/or private funds that could potentially pay 

for the program. Since the cost of region-wide implementation is so high, pilot programs 

on selected transit systems may be warranted as alternatives to region-wide 

implementation. Further study would be needed to identify the most cost-effective transit 

systems for pilot programs. Other, more limited options that may be studied include 

reduced fares (rather than free fares) and free transfers between systems. Effective 

marketing programs for free transit on STA days will also need to be studied. The 

current limited-day STA free transit program will provide valuable information to evaluate 

this concept. 
Bay Area 2005 Ozone Strategy E - 27 Final Adopted – January 4, 2006 

FURTHER STUDY MEASURE FS 20: EPISODIC MEASURES 

Further Study Measure Description 

Episodic measures are measures that are not implemented year-round, but instead are 

implemented only at times when pollution levels are expected to be highest. The Air 

District’s Spare the Air program (STA), described in TCM 16, is a long-standing episodic 

measure aimed at discouraging polluting behavior by businesses, government agencies, 

and members of the public on days when weather conditions are conducive to high 

ozone levels. 

The Air District and MTC have previously examined enhancements to episodic 

measures. The STA program has expanded significantly over the years. TCM 16 

proposes further enhancements to the STA program. Further study measure 20 

proposes to examine opportunities for and benefits of providing free transit service on 

STA days, possibly leading to expansion of several pilot programs the Air District and 

MTC have implemented in previous years. 

The Air District and MTC will study additional potential episodic measures. Key 

considerations will include emission reduction potential, costs, technical and 

administrative viability, and public acceptability. Potential episodic measures that could 

be examined include, but are not limited to, the following: 

Reduce high-speed travel on freeways. Cars and trucks produce higher emissions when 

traveling at high freeway speeds (e.g., above posted speed limits). TCM 16 proposes to 

emphasize (voluntary) compliance with freeway speed limits on STA days through STA 

advisories and outreach. MTC and the Air District could examine additional measures, 

such as expanded California Highway Patrol enforcement of freeway speed limits on 

STA days. 

Limit use of pre-1981 vehicles. Older vehicles produce much more pollution than newer 

vehicles because they lack current emission control devices. The Air District’s Vehicle 

Buy Back program offers owners of pre-1981 cars a cash incentive to voluntarily retire 

their vehicle, which is subsequently scrapped. TCM 16 proposes to place greater 

emphasis on discouraging use of pre-1981 vehicles in STA advisories and outreach. 

MTC and the Air District could examine additional measures to discourage use of pre1981 vehicles on STA days, such as targeted outreach to owners of pre-1981 vehicles 

or providing incentives. 

Reschedule processes at stationary sources. Some Air District rules limit polluting 

activity – such as repair and maintenance, cleaning, and other shutdowns of production 

equipment – at industrial facilities on STA days. Examples include prohibiting tank 

cleaning or process vessel depressurization at refineries on STA days. As Air District 

rules are adopted or amended, the District will continue to investigate such STA 

limitations to polluting activity that is infrequent and thus could be easily rescheduled.