Bryan W. Shaw, Ph.D., 

### Chairman Buddy Garcia, 

### Commissioner
Carlos Rubinstein, Commissioner 

### - 

## .

:**~~·.->** .:.\ \ .: I·**!d:~** 

## fJLr.;·u:i: . !·

Mark R. Vickery, P.G., 

### Executive Director 

## 10 APR -9 Pii 

## 1:55

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

Protecting Texas bg Reducing and Preventing Pollution 

## April6,2010

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

### Docket No. 2009-0932-RUL, Rule Project No. 2009-006-101-EN · Docket No. 2009-0867-RUL, Rule Project No. 2009-019-101-EN

A1 Armendariz, PhD, Regional Administrator U.S. Environmental Protection Agency- Region 6 

### 1445 Ross Avenue Dallas, Texas 75202-2733

.

Dear Dr. Armendariz:

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

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

### area.

The Commission adopted amendments to 

### 30 Texas Administrative Code (TAC) Chapter 101, Subchapter A, General Rules, Section 101.1; and Subchapter H, Emissions Banking and Trading, Division 6, Highly Reactive Volatile Organic Compound Emissions Cap and 

### Trade Program, 

### Sections 101.390

- 101.394, 101.396, and 

### 101.399

- 101.401; 30 TAC Chapter 101, Subchapter H, 

### Emissions Banking and Trading, Division 3, Mass Emissions C and 

### Trade Pro 

### Sections 101.350 101.351 and 

### 101.353 and co · revisions to the SlP; and 

### GB Attsinment Demonstration SlP Revision for the 1997 Ei t-Hour Ozone Standard. These rule changes and SIP revisions demonstrate that the HGB area 

### will attain the 

### 1997 eight-hour ozone National Ambient Air 

### Quality Standard by June 15, 2019.

Enclosed are 

### the proposed revisions to the SlP, a public hearing certification, a 

### complete record of the public hearings, and the accompanying orders.· I 

### look forward to your expeditious approval of these SlP revisions.

Sincerely, 

# B**~,;ktw.--·**

# B~haw,PhD.

Chairman

BWS/jmm

Enclosures

cc: The Honorable Rick Perry, Governor ofTexas Mr. Toby Baker, Office ofBudget, Planning and Policy, Office of the Governor Mr. Mark 

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

P.O. Box 13087 Austin, Texas 78711-3087 512-239'1000 1ntemet address: www.tceq.state.tx.usTexas Commission on Environmental Quality Public Hearings Odober 28-29, 2009

Houston-Galveston-Brazoria (HGB) Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard Projed Number 2009-017-SIP-NR Volume 2 of2

### REVISION TO THE STATE IMPLEMENTATION PLAN FOR THE CONTROL OF OZONE AIR POLLUTION

HOUSTON-GALVESTON-BRAZORIA 1997 EI GHT-HOUR OZONE STANDARD NONATTAINMENT AREA

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY P.O. BOX 13087 AUSTIN, TEXAS 78711-3087

Houston-Galveston-Brazoria Attainment Demonstration State Implementation Plan Revision for the 1997 Eight-Hour Ozone Standard

PROJECT NO. 2009-017-SIP-NR

Adopted March 10, 2010

### xv LIST OF APPENDICES

Appendix Appendix Name

Appendix A Meteorological Modeling for the HGB Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard

Appendix B Emissions Modeling for th e HGB Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard

Appendix C Photochemical Modeling for the HGB Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard

Appendix D Reasonably Available Control Technology Analysis

Appendix E Reasonably Available Control Measure Analysis

Appendix F Evaluation of Mobile Sour ce Control Strategies for the HoustonGalveston-Brazoria State Implementation Plan (With Detailed Strategies), Prepared for Houston-Galveston Area Council, Prepared by ENVIRON International Corporation

Appendix G Transportation Control Measures for the HGB Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard (Excerpt from Evaluation of Mobile Source Control Strategies for the Houston-Galveston-Brazoria State Implementation Plan), Prepared for Houston-Galveston Area Council, Prepared by ENVIRON International Corporation

Appendix H Voluntary Mobile Emission Reduction Program for the HGB Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard (Excerpt from Evaluation of Mobile Source Control Strategies for the Houston-Galveston-Brazoria State Implementation Plan), Prepared for Houston-Galveston Area Council, Prepared by ENVIRON International Corporation

Appendix I Corroborative Analysis for th e HGB Attainment Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard

Appendix J Recommendations for Best Ma nagement Practices to Control and Reduce Inadvertent Cargo Vapor Emissions in the Tank Barge Community

### APPENDIX F

EVALUATION OF MOBILE SOURCE CONTROL STRATEGIES FOR THE HOUSTON-GALVESTON-BRAZORIA STATE IMPLEMENTATION PLAN (With Detailed Strategies)

Prepared for Houston-Galveston Area Council

Prepared by ENVIRON International Corporation

### F-1 

# Overview of Commitments

Introduction

Voluntary Mobile Source Emission Reduc tion Programs (VMEPs) can be granted emissions credit in State Implementation Plans (SIP). As part of the SIP, the VMEP as identified and described; cont ains projections of emission re ductions attributable to the program, along with relevant technical suppor t documentation; commits to monitor, evaluate, and report the resulting emissions effect of th e voluntary measure; and commits to remedy in a timely manner any SIP credit shortfall if the VMEP program does not achieve projected emission reductions.

The VMEP was intended to be a flexible approach regarding the SIP requirements. EPA expects that the SIP commitments include a remedying for shortfalls in a voluntary measure that include adjusting the voluntar y measure, adopting a new voluntary measure, or revising the VMEP emission credits to reflect actual emissi on reductions, provided overall SIP commitments are met. For this VMEP commitment, H-GAC interprets this to mean that the individual components of th e VMEP described here can be adjusted according to the funding, technology, or projec ts available, but that the overall goal presented for the VMEP will be met. H-GAC presents four strategies of the VMEP and expected emission reduction from each element, but is committed to the overall emission reduction goal.

EPA has established a limit of three percent (3%) of the total projected future year emissions reductions required to attain th e appropriate NAAQS. TCEQ has estimated that this 3% limit represents about 2.25 t pd NOx reduction for the 2018 attainment year. H-GAC estimated that 2.25 tpd could be at tained for the VMEP program with the projected funding and organizationa l administration commitment.

H-GAC has been administering VMEP progr ams for many years at least since 2003 and has instituted the inter-organi zation, public/private partners hips, and other arrangements to implement the VMEP projects. The f unding for these emission reduction projects therefore will be derived from a wide variet y of sources. H-GAC administers Congestion Mitigation and Air Quality (CMAQ), provi des in kind funding to administer and implement alternative commuting options, and arranges the use of Supplemental Environmental Project (SEP) funding. In addition, H-GAC works with local municipalities and private firms who either implement emission reduction measures on their own or with co-funding from the funding sources that H-GAC administers.

This report consists of an overview of the VMEP commitments to include in the State Implementation Plan (SIP) submittal for the Houston-Galveston-Brazoria non-attainment area. The VMEP on- and off-road measure commitments, which H-GAC and its partners will pursue as allowed by State law are out lined in Table 1. The emission reduction commitments identified at this time are th e 2.25 tons per day from on-road and off-road control measures shown in Table 1. The on-road measures include a mix of infrastructure (signal timing, intersection improvements, a nd others), alternativ e commuting options,

### F-2 

### and truck replacement or retrofit projects. The off-road measures include marine, construction, or other off-road equipment projects including replacement or fleet managements approaches.

Table 1. Mobile Emission Reduction Commitments

Strategy NOx Reduction Estimate (tons per day)

Alternative Commuting 0.20

Regional Traffic Flow Improvement 0.05

Off-road Measures 0.70

Vehicle Retrofit and Replacement 1.30

TOTAL 2.25



### The mobile source emission reduction control measures detailed in this report were developed using methodology in accordance w ith currently known State and Federal regulations. It is impossible for H-GAC to fully predict what economic or regulatory changes will occur over the decade for which these control measures are slated to be placed into action; however any deviation from the current conditions will likely result in changes to the emission reductions resulting from the strategies detailed in this report.

These changes could result in the reassessment of support for strategies. It must be noted that any reassessment would not change the commitment of H-GAC a nd its partners to meet the emission reduction goals that have been set for the region. It would, however, indicate that flexibility is needed to dete rmine and implement the most effective emission reduction methods under changing conditions. Some situations which may require a reassessment of SIP control measures include but are not limited to: changes to State or Federal fuel standards, changes to State or Federal engine standards, significant economic growth or contraction, or the introduction of technology updates which result in significant changes to estimated emission reductions.

Weight of evidence reduction measures as shown in Table 2 may be implemented to further reduce emissions beyond the voluntary co mmitments described in this report.

Table 2. Weight of Evidence Emission Reduction Measures

Strategy Description Continue current passengervehicle scrappage and buyback program Monetary compensation for old vehicle scrappage. Increase the range of vehicles and heavy-duty truck engines targeted for replacement credit or subsidy.

Pay-As-You-Drive Insurance Insurance costs would be associated with mileage driving by a vehicle increasing the incr emental cost per mile driven. The cost of insurance then becomes an incremental cost and could be combined with mileage based registration fees and fuel tax increases to add incentive to alternative transportation.

### F-3 Strategy Description

Limitations on idling of heavy-duty vehicles May require city ordinance. Will require additional power sources for local major events. Large truck stops have constructed alternatives to idling partially funded by TERP. Encourage/Mandate Livable Centers Includes a host of ideas to reduce vehicle travel. Such ideas could be incorporated into ordinances promoting multi-use development.

Enhanced enforcement for smoking vehicles Link to I/M test status: encourage local police to enforce existing smoking vehicle legislation- vehi cle impounding for violators (like Dallas Emissions Enforcement Pilot Program) Creation of regional government idling restriction MOU Idling is usually a small portion of the emissions from vehicles.

Limitations on idling of heavy-duty construction equipment Idle reduction either through the use of automatic shut-off devices or operator training



### This document consists of a ge neral description of the measur es that will be taken to reach the commitment for the voluntary mobile source emissions reductions program. Please refer to the Environ document for a de tail description of e ach control measure.

### F-4 

### VMEP Measures Description

Alternative Commuting

There are various methods for reducing emi ssions through alternative commuting options several of which have been detailed in ENVIRON (2009). 1 

### Those measures showing the most promise include the following.

• Bicycle and pedestrian

• Compressed work week, telewor k, and other employer options

• Internet ride sharing

• Vanpool programs

• Improved low emission transit options

All of these approaches ar e being implemented in the HGA nonattainment area and one or more of these options will be sufficien t to provide reduced vehicle travel and emissions reductions meeting the level of commitment described in this report.

There are additional approaches that could be implemented to provide emission reduction through pricing measures affecting fuel, park ing, congestion, and vehicle miles traveled registration or insurance fees.

Regional Traffic Flow Improvement

Traffic signalization improveme nts, reversible lanes and intersection improvements are an ongoing part of the H-GAC plan and Tr ansportation Implementation Plan (TIP). According to practice in eval uating CMAQ projects, as well as straightforward logic, traffic flow improvements encouraged by im proved intersections or traffic signals provide benefits for 2 – 5 years (3 years was used for this analysis) before latent demand and growth in traffic cause the facility to retu rn to about the same flow level as prior to the signal or other improvements (although bette r able to handle higher traffic volume).

The emissions benefits from these improvement s are reduced idling and start/stop activity modes.

Vehicle Retrofit and Replacement

Through the Clean Cities/Clean Vehicles program, H-GAC is aggressively pursuing participation from public and private fl eet owners in introducing low-emission technology into their vehicle fl eets (primarily heavy-duty trucks and buses) and their fueling infrastructure. Federal funds (Conge stion Mitigation and Air Quality – CMAQ) are available for eligible projects using approved technology to reduce smog-forming

1 ENVIRON (2009), “Evaluation of Mobile Source Contro l Strategies for the Hous ton-Galveston-Brazoria State Implementation Plan (With Detailed Strategies),” Final Report Prepared for Houston-Galveston Area Council, May 11, 2009.

### F-5 

### emissions from on-road motor vehicles. This program has been highly successful in implementing emission controls from on-road mobile sources.

H-GAC's Clean Vehicles program is a fuel/te chnology-neutral grant program that funds cost-effective engine retrofit, repower, replacement, conversi on (to alternative fuels), or the establishment of publicly accessible alternative fuel infrastructure. Overhead and administrative costs are not eligible for f unding. Eligible entities include any public or private fleets that primarily operate with in the 8-county ozon e non-attainment area (Brazoria, Chambers, Fort Bend, Galvest on, Harris, Liberty, Montgomery, and Waller counties). Both light- and heavy-duty vehicles ar e eligible; however, at this time, off-road vehicles are ineligible. Eligible vehicles mu st spend at least 75% of their operating hours within the 8-county ozone non-at tainment area, and travel more than 12,000 miles/year. As a general rule, the replacement of the heav iest, oldest, and most used diesel engines will qualify for the most funding.

H-GAC has been administering a Clean Vehicl es program for several years now, and has initiated and completed many projects. Over th e past 6 years, nearly $60 million has been committed to replacement and retrofit projects with engines meeting lower emission standards.

Off-road Measures

There are several approaches to reducing em issions from off-road engines centering on replacement or retrofit with engines mee ting lower emission standards and reduced activity especially idling. Ta ble 3 shows the various approaches that could be used to target various off-road sectors.

Table 3. Off-Road Emission Reduction Measures Strategy Description Voluntary non-road replacement and retrofit programs Funding for accelerated turnover of construction equipment and other non road equipment Government construction incentives May include funding, tax relief, or proposal preference to firms using clean equipment
Promote cleaner lawn and garden equipment Retirement program for old and malfunctioning lawn and garden equipment Reduced Idling Reduced activity through practice or installed devices. Development of Clean Air Action Plans for regional port and marine operations Could include vessel speed reductions, at berth control, and engine improvements

Rail Efficiency measures Grade separation, track straight ening, voluntary fleet turnover measures may be implemented.



### Voluntary retrofit and replacement programs ha ve been used across the US to reduce emissions using a variety of programs providi ng cofunding incentive to offset the costs incurred. One of the most important methods fo r emission reduction projects is to replace

### F-6 

### older vehicles and equipment with those meeting the lower emission standards. The retrofit projects often use technologies employed on new engines to meet the lower emission standards.773 San Marin Drive, Suite 2115, Novato, CA 94998 415.899.0700 ENVIRON International Corporation



### Final Report

EVALUATION OF MOBILE SOURCE

CONTROL STRATEGIES FOR THE HOUSTON-GALVESTON-BRAZORIA

STATE IMPLEMENTATION PLAN (With Detailed Strategies)

Prepared for

Houston-Galveston Area Council

3555 Timmons Lane, Suite 120 Houston, TX 77027

Prepared by

ENVIRON International Corporation 773 San Marin Drive Suite 2115 Novato, CA. 94998

May 11, 2009May 2009

G:\HGAC\Reports\Final_051109\TOC_051109.doc 

### i TABLE OF CONTENTS

Page

1. BACKGROUND AND PURPOSE OF STUDY................................................................ 1-1

Background..................................................................................................................... ....... 1-1 Purpose of Study............................................................................................................... ..... 1-2 Overview of Commitments.................................................................................................... 1-2 Organization of Report ......................................................................................................... . 1-4

2. CONTROL MEASURE IDENTIFICATION .................................................................. 2-1

Refining Initial Master List................................................................................................... . 2-1 Evaluating Feasibility and Potent ial for Emission Reductions.............................................. 2-1

3. METHODOLOGY FOR ANALYSIS OF MOBILE CONTROL MEASURES ........... 3-1

Qualitative Review of Master List......................................................................................... 3-1 Qualitative Review of Emissi on Control Potential................................................................ 3-1 Qualitative Review of Feasibility .......................................................................................... 3-2

4. SUMMARY OF ALL MOBILE ME ASURES CONSIDERED ...................................... 4-1

5. DETAILED EVALUATION OF QUALIFYING MOBILE MEASURES .................... 5-1

6. LOCAL SUPPORT OF FOR IMPLEMEN TATION OF MOBILE MEASURES ....... 6-1

TABLES

Table 1-1. On-Road Emission Reduction Commitments...................................................... 1-3 Table 1-2. Non-Road Emission Reduction Measures ........................................................... 1-3 Table 1-3. Weight of Eviden ce Emission Reduction Measures............................................ 1-3 Table 4-1. On-road vehicle emission reduction measures .................................................... 4-2 Table 4-2. Non-road vehicle emission reduction measures ................................................ 4-22 Table 5-1. On-road measures de tailed evaluations summary................................................ 5-1 Table 5-2. Non-road measures detailed evaluations summary.............................................. 5-4 Table 5-3 Weight of evidence measures summary .............................................................. 5-5May 2009

G:\HGAC\Reports\Final_051109\TOC_051109.doc 

### ii APPENDICES

Appendix A: Summaries of the Houston-Galvest on Area Council of Governments Meetings with the Texas Commission on Environmental Quality and Various Stakeholders concerning the Houston-Galveston- Brazoria Eight-Hour Ozone State Implementation Plan Master List Control Measures

Appendix B: Written Comments from Stakeholders and their Respective Responses Regarding Master List Control Strategies

Appendix C: Summaries of the Houston-Galvest on Area Council of Governments Meetings with the Texas Commission on Environmental Quality and Various Stakeholders concerning the Houston-Galveston- Brazoria Eight-Hour Ozone State Implementation Plan Short List Control Measures

Appendix D: Written Comments from Stakeholders and their Respective Responses Regarding Short List Control Strategies

Appendix E: Overview of the Transportation Contro l Measures to Be Included as Part of the Houston-Galveston-Brazoria Eight-H our Ozone State Implementation Plan Submittal

Appendix F: Detailed Evaluations for On-Road Control Strategies

Appendix G: Detailed Evaluations for Non-Road Control Strategies

Appendix H: Detail Eval uations for Weight of Evidence Control StrategiesMay 2009

G:\HGAC\Reports\Final_051 109\Sec1_Bkgrd_051109.doc 

### 1-1 1. BACKGROUND AND PURPOSE OF STUDY

This report documents a study performed by ENVIR ON International Corpor ation on behalf of the Houston-Galveston Area Council (H-GAC ). The study was conducted in support of development of an ozone attainment pla n. ENVIRON International Corporation, in collaboration with subcontracto rs Earth Matters and Hazel Barbour, provided assistance in identifying, evaluating, and documenting mobile em ission control measures in an attempt to determine a set of strategies to achieve emi ssion reductions of volatile organic compounds and nitrogen oxides in the Hous ton-Galveston-Brazoria (HGB ) nonattainment area.

This initial work involved preparing and qualitati vely evaluating a master list of mobile control strategies. H-GAC and its stakeh olders began with the initial m obile master list from public comment and involvement culminating in 2006. The master list was winnowed to those deemed of most interest to H-GAC, its stakeholders , and additional measures were suggested. A summary of the stakeholder mee tings is provided in Appendix A of this report along with a summary of written comments and responses su pplied by the stakeholders , provided in Appendix B. ENVIRON and its subcontractors then review ed the remaining master list strategies to estimate their applicability and potential for in clusion in a regional State Implementation Plan (SIP). Once this analysis was completed and a draft short list of qua ntified mobile control measures was assembled, further meetings we re held to gauge additional stakeholder perspectives. A summary of this second round of stakeholder meetings is provided in Appendix C along with a summary of written comments recei ved during this time and responses supplied by the stakeholders, provided in Appendix D.

Background

The study was initiated by a request and suppor t from the Texas Commission on Environmental Quality (TCEQ) to H-GAC for assistance in deve loping approvable mobile control strategies for the Houston-Galveston-Brazoria area toward at taining the ozone standard by the year 2018. The study was initiated to assist TCEQ in the development of the Stat e Implementation Plan (SIP), a document used to demonstrate attainment for the federal 1997 ozone standard. The federal standard is now based on an 8-hour averaging of the fourth annual maximum during a three year period. TCEQ requested that an evaluation of control strategies be conducted in order to understand the potential benefit of those strategies and if they could be implemented as rules or voluntary initiatives. The Hous ton-Galveston-Brazoria ozone nonattainment area includes the following counties, Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller.

The mobile emission reduction measures detailed in this report were developed using current methodology in accordance with currently known State and Federal regulations. It is impossible for H-GAC to fully predict what economic or regulatory changes will occur over the next decade. Any deviation from the current situatio n will likely result in changes to the emission reductions for the mobile control measures deta iled in this report and could result in the reassessment of support for those stra tegies based on these changes.

It must be noted that this reassessment would not change the commitment to meet the emission reduction goals of the region. It would, however, refl ect that flexibility is needed to determine and implement the most effective emission reduction methods under changing conditions.May 2009

G:\HGAC\Reports\Final_051 109\Sec1_Bkgrd_051109.doc 

### 1-2 Anticipated situations which may require a reasse ssment of SIP control m easures include but are not limited to:

1) Changes to State or Fe deral fuel standards, 2) Changes to State or Fede ral engine standards, 3) Significant economic growth or contraction, 4) Evaluation technology updates which result in significant changes to estimated emission reductions.

Purpose of Study

This study is a part of an overa ll process to develop the revised Ozone SIP for the year 2018. The primary objective of the study was to identify a nd evaluate feasible m obile control measures to reduce NOx emissions. A secondary objective was to assist H-GAC in ensuring that area stakeholders were involved in the process of id entifying the mobile measures and in commenting on their feasibility. These efforts were intended to “feed in” to the general SIP process, which will include emission inventory development and photochemical modeling by the TCEQ; ongoing and new processes initiated by H-GAC to identify potential new mobile control measures; and H-GAC efforts to, solicit stakehol der input into these potential measures, and maintain regional planners and govern ment officials in the process.

Key tasks of this ENVIRON study included:

1) Reviewing existing mobile emission inventory and previously evalua ted mobile control

measures, 2) Assisting H-GAC in identifying potential new mobile measures, 3) Performing a qualitative analysis of the primary pollutants and applicability of the proposed control strategies, 4) Quantifying the effects of measures (emissions, costs, feasibility), 5) Coordinating with H-GAC on the measured analyses for placement into the emission projections, 6) Documenting control measure effects and pr esenting findings to technical, policy and steering committees, 7) Developing control strategies a nd submitting documentation to H-GAC.

Although H-GAC is the regional transportation pl anning agency, the study was not limited to transportation sources. Instead, the purpose was to explore all possible on-road and non-road mobile source measures, including sources such as lawnmowers or construction equipment.

Overview of Commitments

The bulk of this report consists of an overview of processes that H-GAC and ENVIRON used to determine mobile source emission reduction co ntrol measures to include in the State Implementation Plan (SIP) submittal for the Hous ton-Galveston-Brazoria non-attainment area. One result of this evaluation is a list of on- and non-road measure commitments, which H-GAC and its partners will pursue as allowed by St ate law. The emission reduction commitments identified at this time are the 2.5 tons per day from on-road control measures shown in Table 1-1,May 2009

G:\HGAC\Reports\Final_051 109\Sec1_Bkgrd_051109.doc 

### 1-3 a commitment to pursue agreements on certain non-road shown in Table 1-2, and weight of evidence control measures shown in Table 1-3.

Table 1-1. On-Road Emission Reduction Commitments.

Strategy NOx Reduction Estimate (tons per day)

Alternative Commuting 0.5

Regional Traffic Flow Improvement 0.5

Vehicle Retrofit and Replacement 1.5

TOTAL 2.5



### Table 1-2. Non-Road Emission Reduction Measures. Strategy Description Voluntary non-road replacement and retrofit programs Funding for accelerated turnover of construction equipment and other non road equipment

Government construction incentives May include funding, tax relief, or proposal preference to firms using clean equipment Promote cleaner lawn and garden equipment Retirement program for old and malfunctioning lawn and garden equipment Development of Clean Air Action Plans for regional port and marine operations Could Include Vessel Speed Reductions, At Berth Control, and engine improvements



### Table 1-3. Weight of Evidence Emission Reduction Measures.

Strategy Description Continue current passengervehicle scrappage and buyback program Monetary compensation for old vehicl e scrappage. Increase the range of vehicles and heavy-duty truck engines ta rgeted for replacement credit or subsidy.

Pay-As-You-Drive Insurance Insurance costs would be associated with mileage driving by a vehicle increasing the incremental cost per mile driven. The cost of insurance then becomes an incremental cost and could be combined with mileage based registration fees and fuel ta x increases to add incentive to alternative transportation.
Limitations on idling of heavyduty vehicles May require city ordinance. Will require additional power sources for local major events. Large truck stops have co nstructed alternatives to idling partially funded by TERP. Encourage/Mandate Livable Centers Includes a host of ideas to reduce vehicle travel. Such ideas could be incorporated into ordinances promoting multi-use development.

Enhanced enforcement for smoking vehicles Link to I/M test status: encourage local police to enforce existing smoking vehicle legislation- vehicle impounding for violators (like Dallas Emissions Enforcement Pilot Program) Creation of regional government idling restriction MOU Idling is usually a small portion of the emissions from vehicles.

Limitations on idling of heavyduty construction equipment Idle reduction either through the use of automatic shut-off devices or operator training



### The mobile source emission reduction control meas ures detailed in this report were developed using methodology in accordance with currently known State and Federal regulations. It isMay 2009

G:\HGAC\Reports\Final_051 109\Sec1_Bkgrd_051109.doc 

### 1-4 impossible for H-GAC to fully predict what economic or regulatory changes will occur over the decade for which these control measures are slat ed to be placed into action; however any deviation from the current conditions will likely result in changes to the emission reductions resulting from the strategies detailed in this report.

These changes could result in the reassessment of support for strategies. It must be noted that any reassessment would not cha nge the commitment of H-GAC a nd its partners to meet the emission reduction goals that have been set fo r the region. It would, how ever, indicate that flexibility is needed to determine and implemen t the most effective emission reduction methods under changing conditions. Some situations whic h may require a reassess ment of SIP control measures include but are not limited to: changes to State or Federal fuel standards, changes to State or Federal engine standard s, significant economic growth or contraction, or the introduction of technology updates which result in significan t changes to estimated emission reductions.

Organization of Report

The remainder of this report is organized as follows:

Section 2, Mobile Control Measure Identificat ion, documents the process used to select individual control measures for analysis.

Section 3, Methodology for Analysis of Mobile Control Measures, briefly describes the data sources, assumptions and techni ques used in the analysis.

Section 4, Summary of All Mobile Measures Consid ered, presents an overview of the qualitative evaluation of all suggested measur es displayed in tabular format.

Section 5, Detailed Evaluation of Qualifying Mo bile Measures includes summary results of quantitative evaluations of vol untary strategies for on-road and non-road mobile sources.

Section 6, Local Support for Implementation of Mob ile Measures details the steps taken to gain support for the quantitatively an alyzed voluntary strategies.

Appendix A, presents summaries of stakeholder meetings used to gather input and comments on the control strategy selection process for the Master List of Mobile Control Measures.

Appendix B, presents stakeholder written comm ents and their respective responses provided by H-GAC for the Master List of Mobile Control Measures.

Appendix C, presents summaries of stakeholder meetings used to gather input and comments on the control strategy selection process for the fi nal Short List of Mobile Control Measures.

Appendix D, presents stakeholder written comme nts and their respective responses provided by H-GAC for the final Short List of Mobile Control Measures.

Appendix E, presents an overview of the Transportation Control Measures.

Appendix F, presents the quantitative ev aluation of each on-road control strategy.May 2009

G:\HGAC\Reports\Final_051 109\Sec1_Bkgrd_051109.doc 

### 1-5 Appendix G, presents the quantitative ev aluation of each non-ro ad control strategy.

Appendix H, presents the quantitative evaluati on of each weight of evidence control strategy.May 2009

G:\HGAC\Reports\Final_051 109\Sec2_CM_ID_051109.doc 

### 2-1 2. CONTROL MEASURE IDENTIFICATION

ENVIRON, in collaboration with H-GAC, used th e master mobile source control measure list developed in 2006 as a starti ng point from which to iden tify measures for the HGB nonattainment area Ozone SIP strategies developm ent. H-GAC solicited additional measures for the HGB area from local stakeholders includ ing the Regional Air Qu ality Planning Committee (RAQPC) to ensure that all potential emi ssion control measures could be identified.

Refining Initial Master List

Several hundred potential on-road mobile source measures and just fewer than one hundred nonroad mobile source measures were suggested in the 2006 master list. Because the process was all encompassing, many measures were suggested mo re than once, although in different ways. In addition, many measures that would alone ha ve minimal effect on emissions were easily recognized as being naturally a part of larger measures and others were not well described. Due to these issues, and with the he lp of stakeholder’s comments, we refined and cleaned up the master list to create the “final master list”.

The final master list is a collection of measures that represented a refine d version of all ideas proffered to date to be considered for more de tailed evaluation. The general categories included such diverse groupings as the clean vehicle pr ograms, pricing measures for on-road mobile sources, incentive programs, public fleet meas ures, in addition to locomotive and marine measures for non-road mobile sources. The complete master list of mobile measures is outlined in Section 4.

Evaluating Feasibility and Potential for Emission Reductions

The primary goal of the master list evaluation wa s to identify the potenti al emissions reduction of the control measures. As noted, the initial evaluation was qualitative, as it was not feasible to model each of the indivi dual control measures. The qualitative review outlined those measures that met the minimum criteria for inclusion in th e SIP along with information about the affected pollutants and implementation cons iderations related to each meas ure. The final master list, provided here, was then used to determine which measures would be included in a more detailed quantitative analysis.May 2009

G:\HGAC\Reports\Final_051109\ Sec3_MethClean_051109.doc 

### 3-1 3. METHODOLOGY FOR ANALYSIS OF MOBILE CONTROL MEASURES

For the initial evaluation of the master list of mobile control measures, a qualitative approach was used to examine the measures. This se ction briefly summarizes the approaches and assumptions used in this analysis.

Qualitative Review of Master List

The primary qualifier for the SIP control meas ure used in this study was based upon the EPA criteria that the SIP control measures need to meet four criteria outlined for mobile source measures by EPA guidance documents (found online at http://www.epa.gov/otaq/statere sources/transconf/policy.htm ). They must be: 1) permanent, 2) quantifiable, 3) surplus, and 4) enforceable ( PSQE). A permanent measure is one that cannot be rescinded and will continue through the time period that the emission reduction is applicable so in effect this would include replacement or re trofitted equipment through the useful life of the mobile source affected, but may not include meas ures that the operator could disable or avoid using at any given time. In a quantifiable measure it must be possible to measure and estimate the quantity of emissions reduced as a result of this measure. A surplus measure must reduce emissions beyond that which are covered under any existing emission reduction programs or measures. Finally, an enforceable measure must be part of a program that meets Federal guidance and could be administer ed by EPA staff. Practically though enforceability means that the strategy must follow EPA criteria and include penalties for violations where appropriate. Following logically from the enforceability requirem ent, EPA also requires that the measures be adequately supported by funding s ources and personnel dedicated to administering the program, for example, the TERP or Clean Cities programs have state or federal funding administered by TCEQ and H-GAC staff respectively who follow EPA guidance, maintaining proper oversight and documentation. The definitions of these criteri a and the administrative oversight may not be obvious from the short description of each me asure; however the ENVIRON team made a judgment as to whether a program could be defined to satisfy these criteria prior to analysis.

EPA allows for a limited portion of the emi ssion reductions in the SIP to be voluntary commitments that may not strictly meet all of the criteria listed above. However, for voluntary measures, the administrating agency must de monstrate real emission reductions by showing funding, oversight, and verification of progress toward the emissi on reduction goal. For instance, the H-GAC Clean Cities and Clean Vehicles Pr ogram can demonstrate funding for clean heavyduty vehicles and verification of disposal of the replaced vehicles even though the measure may not be considered strictly as enforceable. Th erefore voluntary programs may be considered for inclusion in a SIP if defi ned and funded properly.

Qualitative Review of Emission Control Potential

The qualitative review of the emission contro l potential for each meas ure relies on the basic understanding of the emission inve ntory. Control strategies for mobile sources rely on the basic understanding that diesel engine s are a significant s ource of NOx emissions but produce a small fraction of the VOC emissions, and that gasoline vehicles and engines are primarily responsible for VOC emissions while on-road gasoline vehi cles also contribute to the NOx emission inventory. Therefore, programs to reduce diesel engine and vehicle emissions primarily affectMay 2009

G:\HGAC\Reports\Final_051109\ Sec3_MethClean_051109.doc 

### 3-2 NOx emissions, non-road gasoline engines affect VOC emissions, and on-road gasoline vehicles affect both VOC and NOx emissions.

Qualitative Review of Feasibility

The feasibility of each measure was not ranke d, but a description of the implementation considerations is provided for each master list measure.May 2009

G:\HGAC\Reports\Final _051109\Sec4_Sum_051109.doc 

### 4-1 4. SUMMARY OF ALL MOBILE MEASURES CONSIDERED

This section contains the Master List of Measures, which summar izes the qualitative results for all measures initially analyzed. Table 4-1 lists each on-road measure that was reviewed, and Table 4-2 lists each off-road measure analyzed. Th e measures are described qualitatively but not ranked in terms of potential benefit or cost e ffectiveness because inventories have not been finalized and often the program’s implementation has not be ade quately defined. However, with stakeholder input, a list of measur es deserving detailed evaluati on could be selected from this list.

The measures were not ranked by emission reduc tion potential for a nu mber of reasons. The emission reduction potential depends on the leve l of implementation in most cases or the measure needs of greater detail in order to eval uate the potential. For non-road mobile sources, a 2018 forecasted emission inventory is not available at this time to provide a re lative assessment to compare between non-road source emission cate gories or to compare with those measures for on-road sources. Lastly, there has yet to be an em ission reduction target to meet attainment for the HGB area.

Rather than dismiss a measure because it might seem unimportant based on emissions reductions expected, all viable measures were included in the master list. Even sm all reductions might be important if implementation is more aggressive th an conceived, the source category is of larger importance than expected, or if the attainment goal does not re quire large reductions. Another consideration could be that the measure might result in small reductions but be very cost effective or easy to implement.

Our initial list therefore marks those measures that qualify as emission reduction programs under a likely EPA (PSQE) review with "+" to denot e which pollutant would be affected by the

measure.

Each measure is described in terms of what wo uld be implemented and a further comment field discusses the implementation considerations and other unobvious factors a ffecting the measure.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-2Table 4-1.On-road vehicle emission reduction measures.IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment1 17 Bicycle andpedestrian actiongroupsBenefits from bicycle measuresinclude new bicycle lanes as wellas encouraging greater use ofexisting lanes instead of vehicleuse. But it can be difficult todetermine the benefits of suchprograms.Bicycle andPedestrian2006 Y + + Reporting requirements could be difficult tomeet to claim emission reduction benefits. Forcomparison, determine the emission reductionpotential of 20% of employees with commutesof 5 miles or less bicycle to and from work twotimes per week.2 51 Clean CitiesTechnical CoalitionAn example program might be theNCTCOG program where entitiesparticipate in programs topurchase clean vehicles (light orheavy-duty) for their fleets.Clean VehiclePrograms2006 N The strategy, incentives, and benefits haveyet to be defined.3 54 Private sector cleanfuel fleetsThis measure is patterned after theH-GAC Clean Cities Programwhere clean engines (whetheralternatively fueled or no) arepurchased for fleets to reduceemissions.Clean VehiclePrograms2006 Y + CMAQ funding for clean vehicles has been asuccessful program for generating emissionreductions. Similar to measure 22.4 56 Close loopholes inthe Texas CleanFleet Programmaking fewerexemptions for fleetsThe Texas Clean Fleet Programwas repealed by TCEQ, andbecause the Tier 2 light-duty and2007 heavy-duty vehicle emissionsstandards have superceded theoriginal proposal.Clean VehiclePrograms2006 N A revision and implementation of such aprogram needs to be described in more detailto evaluate the benefits.5 58 Fleet review,procurement andoperations policiesENVIRON expects that this couldbe a voluntary version of a CleanFleet Program where purchaseswould be directed to cleanerengines.Clean VehiclePrograms2006 Y + See Measure 36 59 Public agency cleanfleet programCommitment by public agencies topurchase cleanest possible fleetvehicles could be an element infunding or a voluntarycommitment.Clean VehiclePrograms2006 Y + See Measure 37 71 Electric Vehicles Thismeasure is considered toinclude each of various options forthe purchase and use of electric(zero emission) light-duty vehicles.Clean VehiclePrograms2006 Y + + This measure would affect light-duty vehiclesonly.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-3IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment8 99 Area-wide "SteerIt/Clear It" programThis program considers quickremoval of vehicles from roadwayin event of a stall or non-seriousaccident. The benefits of theprogram include better traffic flowreducing slow speed operations.FreewayIncident /RoadwayConstructionManagement2006 N The benefits of the program include bettertraffic flow reducing slow speed operations,but the measure may not be consideredpermanent. In addition the extent to whichincident-related slow speed events areincluded in the emission inventory is unclear.9 100 Additional freewayservice patrolOperation of additional lane milesof new roving tow truck patrols toclear incidents and reduce delayon freeways during peak periods.Reduces traffic congestionimproving average vehicle speeds.FreewayIncident /RoadwayConstructionManagement2006 N See measure 810 101 SAFEClear -Mandatory quickremoval of disabledvehicles during peakperiodsSimilar to Measures 8 and 9. FreewayIncident /RoadwayConstructionManagement2006 N See measure 811 115 Cleaner diesel fuel There are diesel fuels that haveimproved performance evenbeyond the TxLED. This couldinclude cetane additives or gas-toliquids diesel fuels.FuelStandards2006 Y + EPA evaluation of fuel benefits.http://www.epa.gov/otaq/fuelsmodel.htm12 127 Air qualityinformation withdriver trainingInclude information on vehicleemissions and air pollution withnew-driver and defensive-drivingeducation.General PublicEducation andOutreach2006 N It would be difficult to demonstrate emissionreduction benefits for this measure.13 144 Divert trucks fromnonattainment areasRequire through-traffic trucks totravel around rather than throughnonattainment areas.GoodsMovement2006 N While this measure would have large potentialbenefits, it would be difficult to implement anddemonstrate emissions reductions.14 146 Peak period truckbans on freewaysand major arterialsBan on heavy duty trucks enteringor exiting freeways during peakperiods.GoodsMovement2006 N This measure would be infeasible to proposeor implement. Note that the total truck travelwould through the region not change by muchif any, and what did would cause emissionincreases elsewhere. The day to day and hourto hour benefits for emissions would make itdifficult to claim credit.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-4IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment15 147 Permit HOV laneuse by qualifying lowemission vehicles(LEV)Vehicles marked as low emittingwould be allowed to use HOVlanes as an incentive for greateruse.HighOccupancyVehicle (HOV)Lanes/Managed Lanes2006 N Check HOV lane use - if too full already thismeasure cannot help. Also it would bedifficult to define and mark vehicles thatqualify. It is unclear that the incentive wouldbe sufficient to achieve greater use of lowemitting vehicles.16 150 Increase occupancyto three or more pervehicleBased on a review of theeffectiveness of this measure inother parts of Houston (seecomment column) the measurecould be extended to otherfreeways.HighOccupancyVehicle (HOV)Lanes/Managed Lanes2006 N This is a measure already being implementedin some parts of Houston on Katy and NWfreeways where HOV and toll incentives areused.If implemented on additional freeways, thefreeways would need to be identifiedanddiscussed with H-GAC and TDOTand thedaily single occupant and 2-car occupantvolumes determined.17 157 Single OccupantVehicles (SOV)access to HOV andtransit stationsProvide direct freeway access toadjoining HOV or transit park-andride facilities to encourage use andexpedite access.HighOccupancyVehicle (HOV)Lanes/Managed Lanes2006 N See measure 15. Also incremental nature ofbenefit such that it should be thought of as aqualitative supplement to HOV and transitmodes.18 161 Managed lanes toaccommodate somesingle occupantvehicles in HOVlanesIn highly congested corridorswhere speeds are below 20 milesper hour on freeway lanes, permitlimited use of HOV lanes by SOVusing tolls or other limitingtechnique.HighOccupancyVehicle (HOV)Lanes/Managed Lanes2006 N See measure 15.19 163 Focus on finding andpenalizing extremehigh emitters(a) Improved remote sensingprogram, or (b) enhancedenforcement of the I/M programcould reduce numbers of likelyhigh emitting vehicles escapingtesting through purchase offraudulent stickers or avoiding theprogram completely. Penalizefraud not high emittersHigh-EmittingVehicleDetection andPrograms2006 N Questionable regarding excess modeledreductions (I/M modeled at 96% compliance)but could produce real reductions.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-5IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment20 165 Rewards forreporting smoking orhigh emittingvehiclesRewards could be dollars ordiscounted I/M tests and/or repairsfor those reporting smokingvehicles.High-EmittingVehicleDetection andPrograms2006 N See measure 16321 172 Scrappage/buy-backplanMonetary compensation for oldvehicle scrappage. Increase therange of vehicles and heavy-dutytruck engines targeted forreplacement credit or subsidy.High-EmittingVehicleDetection andPrograms2006 Y + + Increased LIRAP funding (total $45 million thisbiennium) has hugely increasedreplacement/scrappage. LDGV's over 10years now eligible for replacement (don't haveto have failed the I/M test). TERP alsorequires scrappage of replacedvehicles/engines. 2010 bus 99% cleaner than1998 bus for NOx.22 181 Dedicated fundingfor school busreplacementClean Cities Clean Vehicle orTERP or EPA funding sources.This program specifically targetsschool bus fleets that trend towardolder models.High-EmittingVehicleDetection andPrograms2006 Y + Currently using Supplement EnvironmentalProgram (SEP) funds federal and state.23 186 Non-profitorganizationassistance programInvestigate opportunities to partnerwith non-profit organizations toensure high-emitting donationvehicles are not returned to theroad and reused in an "as is"condition.High-EmittingVehicleDetection andPrograms2006 N Will reduce value of donation to the non-profit.24 188 Enforce smokingvehicle reports andrequire repairsLink reports to vehicles' current I/Mtest status. Require vehicle to beretested.High-EmittingVehicleDetection andPrograms2006 N May enhance I/M compliance. Repairing toreduce smoke may not mean vehicle will passI/M test. Currently no requirement to I/M testdiesels.25 191 Low-interestfinancing for lowincome and/or oldvehicle trade-insFinancing made available tovehicle owners not eligible forLIRAP replacement optionHigh-EmittingVehicleDetection andPrograms2006 N See measure 172.26 193 Ban sale of highemitting vehiclesVehicles sold within I/M countiesmust have valid passing VIRHigh-EmittingVehicleDetection andPrograms2006 N Provides additional I/M enforcement strategyMay 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-6IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment27 194 Ban high-emittingvehicles in CBDVehicles not allowed throughcheck point if fail remote sensingscan, or if do not have a validinspection stickerHigh-EmittingVehicleDetection andPrograms2006 N Difficult to implement plus once the program isknown about, vehicles may avoid CBD but bedriven around in the wider HG area anyway.Additional RS expensive.28 195 Deny registration tovehicles withrepeated emissionfailuresThis measure would require alegislative change.High-EmittingVehicleDetection andPrograms2006 N Registration already denied if vehicle fails anddoesn't subsequently pass I/M test. If not inLIRAP, could require repairs be done atRecognized Emissions Repair Facility.29 201 Communicate byradio best routesthrough area toavoid congestionImprovements of traffic flow wouldaffect average speeds onroadways if there are alternateroutes..IntelligentTransportationSystems (ITS)2006 N The benefits would be day to day and hour tohour making it difficult to claim emissioncredit. Alternate routes often increase VMTand associated emissions.30 202 Informationtelephone hotline fortraffic conditionsImprovements of traffic flow wouldaffect average speeds onroadways.IntelligentTransportationSystems (ITS)2006 N See measure 201.31 207 Providetransportationconditions internetsiteProvide hotlink to localtransportation conditions websiteor provide internal web page withtransit, traffic, other conditions,schedules and directions toencourage use of modes otherthan driving alone.IntelligentTransportationSystems (ITS)2006 N See measure 201.32 208 Encourage bicycleuse by using ITS toincrease safety instrategicbicycle/automobileconflict areasDuplicate or supplementalmeasure.IntelligentTransportationSystems (ITS)2006 Y + + See measure 1.33 209 Dynamic messagesigns for control oftruck movementsEmissions benefits of truckmovements are unclear.IntelligentTransportationSystems (ITS)2006 N See measure 29.34 210 Dynamic messagesigns for freewaytraffic controlEmissions benefits of freewaymovements are unclear. Houstonarea has numerous dynamicmessage signs in any case.IntelligentTransportationSystems (ITS)2006 N See measure 29.35 211 Real-time display ofestimated time ofarrivals at bus stopsProvide changeable messagesigning at bus stops noting ETA ofthe next buses arriving at the stop.IntelligentTransportationSystems (ITS)2006 N See measure 29. Measure could haveunquantifiable but positive incremental effectson transit measures.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-7IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment36 212 Increase systemsurveillanceThe effect of this measure ontraffic movements is not welldefined.IntelligentTransportationSystems (ITS)2006 N See measure 29.37 214 Limit left turns onselectedthoroughfares duringozone seasonThis measure may show capacityimprovements on selected roadsallowing for better average speeds.Ozone ActionDay / OzoneSeason2006 N May increase average vehicle speeds forarterials The emissions evaluation wouldrequire developing a database of all left turnsto be banned, and the additional milestraveled as a result, as well as changes intravel speeds due to increasing the volumes.Cost of installing the signs could be high.38 218 Delay highemissions producingactivities on ozoneaction days; delayactivities for nonozone action daysThe program is ill defined, and anybenefits experience in thenonattainment area may be offsetby degradation downwind.Ozone ActionDay / OzoneSeason2006 N Involved ozone modeling would be necessaryto demonstrate any benefits to the proposedstrategy.39 227 Preferential parkingfor High OccupancyVehicle (HOV) laneusers and ridesharers; Freespaces, reservedspacesIncentive for ride sharing andreduced commuting alternative.Alternative commuting optionsinclude incentives, penalties, andother encouragements foralternatives to single occupancyvehicle commuting. This measureis for preferential parkingincentives and would be one partof the overall program.ParkingManagement2006 Y + + This measure should be evaluated as part ofa Commute Solutions Program (ridesharing).If the measure is implemented consideradding it to the suite of programs forenhancing ridesharing incentives andopportunities.40 228 Preferential parkingfor High OccupancyVehicle (HOV) laneusers and ridesharers; RatereductionDuplicate measure. ParkingManagement2006 N See measure 39.41 229 Preferential parkingfor High OccupancyVehicle (HOV) laneusers and ridesharers; MeteredspacesDuplicate measure. ParkingManagement2006 N See measure 39.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-8IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment42 231 Free parking at parkand-ride facilities forHigh OccupancyVehicle (HOV) laneand transit usersProvide free parking at facilitiesserved by transit; include costselsewhere or subsidize. Include inweekly or monthly passes.ParkingManagement2006 N Insignificant emission reduction effects,overlap with ridesharing program, possibleoverflow at park and ride lots and unsure ofcurrent cost structure at these lots.43 235 Increase parking attransit centers orstopsAn incentive to use transit insteadof personal vehicles, but notemission reduction measure itself.ParkingManagement2006 N Should provide at least a qualitativediscussion due to overflow issues at currenttransit centers44 236 Use direct ramps toconnect park-andride lots withfreeway systemAn incentive to use transit insteadof personal vehicles, but notemission reduction measure itself.ParkingManagement2006 N Capital intensive and low emission reductionscould be demonstrated.45 237 Locate fringeparking and parkand-ride lots onapproach routes andinterchanges tocentral and othermajor businessdistricts.An incentive to use transit insteadof personal vehicles, but notemission reduction measure itself.ParkingManagement2006 N Capital intensive and low emission reductionscould be demonstrated.46 240 Provide parking atall major transitstationsAn incentive to use transit insteadof personal vehicles, but notemission reduction measure itself.ParkingManagement2006 N Need to examine feasibility47 241 Commuter parkingpricingNo free parking. Price increasewould be applied to employeesadjusted for vehicle occupancy sothat carpoolers would not besubject to increased parkingprices.ParkingManagement2006 Y + + Utilize an analysis approach whereby thecurrent price elasticity is applied to a 25% to a50% increase in parking prices in applicableparking centers. See measure 39 that usesan incentive rather than a penalty.48 243 Parking space tax orsurchargeDuplicate measure but perhaps abetter name.ParkingManagement2006 N Same as measure 47.49 246 Increase meter feesfor on-street parkingUnclear if the current availabilityand cost would affect vehicletravel.ParkingManagement2006 N Baseline data of use, availability, and pricingnot available.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-9IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment50 248 Eliminate employeeparking subsidiesDuplicate measure. As opposed totraditional parking cash-out, thisprogram would operate onemployer-owned parking.ParkingManagement2006 N Determine number of employer-ownedparking spaces and cost to employers ofproviding them. Evaluate using average orarea-specific average parking costs and acash-out equivalent to the expected revenuefrom renting the spaces out to employees ofother companies. Measure 51 has a betterdescription of the approach.51 249 Employee parkingcash-out programA monetary incentive to ride shareor use alternative commutingoptions.ParkingManagement2006 Y + + Re-evaluate based on current subsidies,potential for removal, and price effect oncommuters. Other areas have predicted largeemission reductions for this measure.Evaluate with measure 47.52 253 Smart Cards pay asyou go parkingUnclear if this measure representsan incentive to reduce vehicletravel.ParkingManagement2006 N The incentive forreduced vehicle use has notbeen identified.53 256 Reduce legal onstreet parkingspaces in highcongestion areasEffectively increasing roadcapacity to reduced stop and goprogression improving arterialspeeds.ParkingManagement2006 N Increase average vehicle speeds for arterials.54 262 Limit peak periodparking to vehicleswith two or moreoccupantsUse flextime, but permit onlyvehicles with two or moreoccupants to enter workplaceparking facilities during peakperiods.ParkingManagement2006 N Unless this measure is better defined, only thepeak traffic would be affected not reducingoverall vehicle use. Enforcement would bedifficult and the costs would outweighemission likely emission benefits.55 271 Remove fuelsubsidiesFuel prices and vehicle use have adirect correlation, but the specificsof this measure (price increase)need to be defined.PricingMeasures2006 Y + + The relationship of the fuel price and thevehicle use is required especially based onrecent gasoline price increases and itsresulting effects, and proposed legislation onfuel taxes and subsidies.56 273 Accelerateddepreciationallowance foremployer providedvanpool and bicyclefacilitiesIncentive to provide alternativecommuting options, but not anemission reduction measure byitself.PricingMeasures2006 N This measure could be examined further todetermine cost savings and additionalincentives for employers to provide vanpoolsor bike facilities. If this examination showssufficient potential the measure should bequantified.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-10IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment57 275 Congestion pricingfor major activitycentersCharge vehicles to enter highactivity centers (retail/businessdistricts, etc.) in cities, with higherprices charged during high-traffichours.PricingMeasures2006 Y + + This measure was evaluated in 2006 and theconclusion was that reductions would be lessthan 0.01 tpd. This measure is applied inmany other countries with success, but wouldraise a lot of implementation concerns.58 277 Pay-As-You-DriveInsurance (per-mile)Insurance costs would beassociated with mileage driving bya vehicle increasing theincremental cost per mile driven.The cost of insurance thenbecomes an incremental cost andcould be combined with mileagebased registration fees and fuel taxincreases to add incentive toalternative transportation.PricingMeasures2006 Y + + This measure was quantified as producingamong the higher emission reductions in the2006 analysis and should clearly be quantifiedfor the 2008 analysis. The measure has alsobeen implemented at least at a pilot level inother areas, and is attractive to insurers. Theeffect of recent gas price increases on drivingneeds to be evaluated with respect to thechoice of the appropriate elasticity will need tobe evaluated.59 287 Local or regional fueltaxesFuel prices increases. Duplicate tomeasure 55.PricingMeasures2006 Y + + This is a more direct and clear approach thanmeasure 55. The amount of tax would need tobe defined but the effectiveness would beproportional to the tax.60 291 Vehicle milestraveled - basedtaxesCharge a tax or registration fee byvehicle miles traveled per year.PricingMeasures2006 Y + + Like measure 59, this is a more direct andmeasurable approach than measure 55. Theamount of the tax would need to be estimatedto determine the impact of the measure.61 295 Increase tolls duringpeak traffic periodsThe application higher costs onlyduring peak hours are likely to havean insignificant impact on regionalvehicle travel. The Houston areapeak period is too long to permitmore than small incremental travelchanges outside the peak .PricingMeasures2006 N Based on the HOT lanes on some freeways inHouston region, this measure may haveapplicability now and in the future as freewaysbecome more congested. But the effect islikely to be small because of the limitednumber of toll ways and penalty for drivingwould be applied only to peak hours.62 298 No tolls for busesand vanpoolsAn incentive to use transit insteadof personal vehicles, but notemission reduction measure itself.PricingMeasures2006 N Possibility that removing tolls for vanpoolswould provide a significant incentive toemployers to purchase vanpools.63 300 Increased speedingfinesIncrease amount of fines forexceeding existing speed limitsover 45 miles per hour; useadditional funds generated to fundvehicle replacement of otheremission-reduction programs.Speed 2006 N This measure may reduce emissions, butMOBILE model limitations would make itdifficult to evaluate. An assumption regardingthe effect; for example, the speeding above65 mph would be reduced.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-11IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment64 302 Aggressive drivingenforcementSpeed 2006 N This would not likely be considered apermanent measure but as an element ofMeasure 65 or 66.65 304 Lower speed limit inurban area to 55miles per hourThe MOBILE model estimateslower emissions if freeway freeflowing speeds of cars andespecially heavy-duty trucks arereduced.Speed 2006 Y + This measure may be difficult to implementbecause it requires State approval. Theapproach would apply only to limited accessroads where high speeds occur. Increasedenforcement personnel would be needed.66 311 Reduce speed to 55miles per hour forcommercial trucksLower freeway speeds of truckslower emissions more than lowerspeeds for light-duty vehicles.Speed 2006 Y + Historically, Texas has not wished to havedifferent speed limits for cars and trucks.Although it currently does have different onesfor certain freeways.67 316 Incentives for infilland redevelopmentSeveral measures to plancommunities for lower vehicletravel. This would entail that thedevelopment be compact (toencourage walking and bicycling)and convenient to transit.Sustainableand TransitOrientedDevelopment2006 Y + + Evaluate potential using methods andprojections of infill and smart growth.Combine with measure 69 and 70 andespecially 137, which is recommended as the"umbrella" measure68 319 Local medicalfacilitiesIncrease the number of local“neighborhood” facilities for routinemedical proceduresSustainableand TransitOrientedDevelopment2006 N Evaluate VMT due to medical trips, which willbe a percentage of Home-to-Other and Workto-other. The percentage could be obtainedfrom the travel modeling section or from mostrecent trip surveys. But is likely to beinsignificant or one part of larger measure toreduce community travel. See measure 137.69 321 Encourage orrequirecomplementary usesin close proximity inall developments ordevelopment areasApply Planned Use Development(PUD) concept by area, requiring amix of complementary uses ineach square mile or otherdevelopment area in accordanceto a sub-area, locally developedplan.Sustainableand TransitOrientedDevelopment2006 N See measure 137.70 323 Comprehensivedesign guidelines foractivity centersComprehensive design guidelinesfor layout of schools,neighborhoods and other activitycenters to maximize walkabilityand minimize the need for shortdistance automobile trips.Sustainableand TransitOrientedDevelopment2006 N See measure 137.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-12IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment71 324 Locate personalbusiness supportcenters at park-andride facilities(conveniencebusinesses)Business location selection resultsfor numerous reasons.Sustainableand TransitOrientedDevelopment2006 N The headway times at park and ride facilitiestoo short to justify expense, who would usethese facilities, and the probable cost ofinstallation and maintenance would not justifyadditional incentive to park and ride.72 326 Co-locate eventcenters and majortransit centers andstationsLocal event centers at sites ofmajor transit centers to ensurehigh level of service.Sustainableand TransitOrientedDevelopment2006 N This measure would be event oriented andvery capital intensive. It would probablycause a percentage of event attendees toutilize transit to avoid parking problems atevents so worth looking into when siting thesefacilities, but not a regional strategy.73 327 Daycare and otherservicesDaycare, other convenienceservices at park-and-ride lots andtransit stations.Sustainableand TransitOrientedDevelopment2006 N Many employers already provide. Coulddevelop a qualitative evaluation of commutingemployees with children in off-site day-careand quantify extra VMT associated withdriving children to day-care and then assumea percentage of those can be serviced by daycare provided at the work site.74 328 Ban left turns Effectively increasing roadcapacity to reduced stop and goprogression improving arterialspeeds.Traffic FlowImprovements2006 N May increase average vehicle speeds forarterials. Evaluation would require developinga database of all left turns to be banned, andthe additional miles traveled as a result, aswell as changes in travel speeds due toincreasing the volumes.. Cost of installing thesigns would be high.75 342 Reversible trafficlanesIncreased capacity in commutingdirection.Traffic FlowImprovements2006 N76 350 Local intersectionsignal improvementsEffectively increasing roadcapacity to reduced stop and goprogression improving arterialspeeds.Traffic FlowImprovements2006 Y + + Increase average vehicle speeds for arterials.77 351 Traffic signalequipment orsoftware updatingEffectively increasing roadcapacity to reduced stop and goprogression improving arterialspeeds.Traffic FlowImprovements2006 Y + + Increase average vehicle speeds for arterials.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-13IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment78 352 Emphasis on majorroute trafficsignalization;through route trafficplatooningEffectively increasing roadcapacity to reduced stop and goprogression improving arterialspeeds.Traffic FlowImprovements2006 Y + + Increase average vehicle speeds for arterials.79 354 Real-time traffic flowmanagementTraffic signals that changetiming/cycles to accommodatereal-time traffic conditions.Traffic FlowImprovements2006 Y + + Increase average vehicle speeds for arterials.80 355 Adaptive trafficsignals and signaltimingEffectively increasing roadcapacity to reduced stop and goprogression improving arterialspeeds.Traffic FlowImprovements2006 Y + + Increase average vehicle speeds for arterials.81 357 Light emitting diode(LED) traffic signalreplacementIt is unclear how this measurecould reduce emissions.Traffic FlowImprovements2006 N82 358 Two-phase signalsTraffic FlowImprovements2006 N Increase average vehicle speeds for arterials.83 360 Signal timing andcoordination topromote trafficprogressionCurrently signal coordination tendsto focus on reducing delay time forindividual drivers; altercoordination to promote greatestmovement for traffic as a whole.Traffic FlowImprovements2006 Y + + Increase average vehicle speeds for arterials.84 366 Prohibit drive-thruservice during ozoneseasonThe measure might be difficult oronerous to implement.TrafficManagement2006 Y + This measure reduces idling of vehicles, butthat is historically a small benefit.85 371 Reduce transit fares Incentive to use transit instead ofvehicles.Transit 2006 Y + + Evaluate changes in transit use occurring in aselected time period of gasoline priceincreases to determine potential. The lostrevenue would need to be replaced for transitcapacity to continue. Reduced fare usuallyresults in a small increase in transit use.86 374 Peak/off-peak transitfaresDuplicate measure. Transit 2006 N See measure 85.87 376 Personalized rapidtransitDuplicate measure. Transit 2006 N See measure 90.88 377 Transit schedulecoordinationTransit 2006 N Effect too small to encourage significantadditional transit use.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-14IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment89 393 Guaranteed ridehomeIncentive for transit use, not areduction measure itself.Transit 2006 N This measure is part of various measures thatenhance ridesharing programs. It is notrecommended that it be evaluatedindividually.90 403 Subscription busserviceOn demand personalized transitservice similar to other commercialshuttle services but providing lowercost and less stressful methods ofcommuting or running errands inparts of town that are far fromresidences.Transit 2006 Y + + A transit enhancement measure designed toattract transit users to specialized andcustomized transit services. This measuremay be particularly attractive in years such asthe attainment year. If the service wassubsidized through transit funding or throughthe use of funds generated by other programssuch as VMT taxes it could be highly effectivein terms of both emissions and costs.91 407 Business Firstenhanced busesProvide buses with laptop/Internetlinks, telephone and otherbusiness amenities. Similar tomeasure 90.Transit 2006 N An incentive for transit use, not a reductionmeasure by itselfunless structured likemeasure 90.92 414 Electrify bus routes Fixedroutes with catenary electricdelivery. This could be a significantchange in current operations.Transit 2006 Y + Direct emission reduction from electrifiedbuses. This could be very difficult to evaluatebecause the routes, engineeringconsiderations (e.g. clearances and powersubstations), and bus purchases or retrofits allneed to be considered.93 422 Monthly transit passprogramsAlready implemented and difficultto predict the increase transitridership as a result.Transit 2006 N Already implemented for some time. Perhapsfurther reduce prices.94 423 Eliminate trips - Freetransit from remotesitesThis measure is ill definedespecially on how reduced vehiclemileage is attained.Transit 2006 N This measure does not seem to provide anyemission reduction.95 424 Provide an off-peakunlimited-ride dailypassMay already be implemented inlarge measure through the monthlypass program.Transit 2006 N Evaluate extent to which this is alreadyoffered in current transit program.96 426 Uniticket programs Thisis an incentive not a vehicletravel reduction measure.Transit 2006 N Largely including in the monthly passprogram.97 428 Simplified farecollectionDifficult to show that this is anincentive for greater transit usage.Transit 2006 N Not quantifiable.98 430 Public transportation- Special faresThe measure needs to be refinedin terms of the incentives andparticipants in the program.Transit 2006 N Not quantifiable without extensive surveydata.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-15IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment99 433 Accelerate railexpansionIncrease transit capacity. Railevaluations would need to havespecific proposals and marketanalysis.Transit 2006 Y + + If specificity on expansion and ridership canbe provided by appropriate agency thismeasure could be evaluated.100 436 Commuter Rail Combine regional and lightpassenger rail measures.Transit 2006 N See measure 99.101 437 High-speed rail Specially designed regionalpassenger rail.Transit 2006 N See measure 99.102 438 Free circulatorservice to majorgeneratorsFree shuttle/transit serviceconnecting remote areas withmajor activity generators. Increasetransit capacity.Transit 2006 Y + + If the description refers to shuttles in betweenmajor employment and retail centers thismeasure could have significant potential.Recommend agreeing upon additionalspecificity with appropriate H-GAC staff.Specificity refers to identifying majorgenerators, number and capacity of shuttles,and their frequency of service.103 441 Provide HighOccupancy Vehicle(HOV) shuttlebetween companyfacilitiesEffectiveness of the measuredepends on the number ofcompanies and shuttles operating.Transit 2006 N Evaluate number of companies that havemultiple locations within Houston region alongwith frequent travel back and forth byemployees. The benefit is likely to be small.104 446 Teleconferencing ofmeetingsThe available benefit is unclear. TravelDemandManagement:BusinessOperations2006 N Evaluate potential from a qualitativestandpoint. Most companies implementingalready to extent possible for other reasonsand due to advances in web-meetingtechnology.105 453 Mandated peakspreadingRequire business hours to bestaggered to spread peak trafficover a wider time period andreduce congestion.TravelDemandManagement:BusinessOperations2006 N The peak in Houston is longer than almost allother urban areas in the U.S. (view HOV lanetimes). Less opportunity for further peakspreading exists in Houston region.106 459 Mandatory orvoluntarycompressed workweekThe benefits of this program couldbe included with a variety ofcommute reduction options. Thisrepresents one alternative of thereduced commuting options.TravelDemandManagement:BusinessOperations2006 Y + + This measure creates a 10 - 20% reduction inweekly trips by any participant. Recommenda mandatory and a voluntary evaluation withthe latter based upon a review of currentemployer practices and ability to sustain acompressed work week.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-16IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment107 460 Subscription busesor buspoolingDuplicate measure.TravelDemandManagement:BusinessOperations2006 N See measure 90.108 461 InternetridematchingservicesReal-time ridematching offered viaa Website, by an employer, or by athird party (sponsored by city ortransportation authority).TravelDemandManagement:BusinessOperations2006 Y + + Evaluate 2008 and expected future benefits ofNuRide – the current internet-based programfor H-GAC which began providing internetmatching for ridesharing in 2006. Thenevaluate the extent to which this program isexpected to grow along with the use byHoustonians of other online ridesharingservices such as GoLoco, Ridesearch,erideshare, etc. The effect of recent gas priceincreases needs to be considered.109 462 Purchase vans forvanpoolsCommute reduction along with theopportunity to buy cleaner vans.TravelDemandManagement:BusinessOperations2006 Y + + With or supplemental to measure 118.110 463 Mandate orencouragevanpooling andcarpoolingOne of many commute reductionmeasures already included in thelist.TravelDemandManagement:BusinessOperations2006 N Mandate not feasible. Encouragementalready provided in Commute Solutionsprogram.111 465 Mandatory orvoluntary flextimeprogram (daily startand end time)Temporal allocation of vehicletravel, but not a reduction measureitself.TravelDemandManagement:BusinessOperations2006 N As normally constructed, flextime allowsemployees to commute during off-peak hours.Because of the long peak period length inHouston this measure would not have aquantifiable effect.112 470 Pay or otherfinancial incentivefor not drivingEmployer pays employees who donot drive a monthly stipend;employees who drive receive nocorresponding benefit.TravelDemandManagement:BusinessOperations2006 Y + + It may be more cost effective than othermeasures, particularly capital intensive ones.This type of measure ought to be evaluated inconnection with comparing the relative costeffectiveness of various programs.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-17IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment113 471 Employer tax creditor deductionInstitute a tax credit or deductionfor employees that regularly use anon-single occupancy vehiclemode for commuting and/or foremployers, based on number ofemployees that commute usingnon-SOVTravelDemandManagement:BusinessOperations2006 N Recommend qualitative evaluation withrespect to implicit tax credits due to hightransportation costs. Also employers in someworkplaces are already providing suchincentives. But it is an incentive that wouldrequire survey work to determine an emissionreduction.114 475 Incentives for BestWorkplaces forCommutesDesignationAlready implementing in Houston TravelDemandManagement:BusinessOperations2006 N Review status of this program. Federalfunding no longer available.115 477 Trade equivalentjobs to be closer toworkFor employees of the samecompany but at different worksites,identify opportunities to "tradejobs" or worksites to reducecommute distance.TravelDemandManagement:BusinessOperations2006 N Employees who could do this already would inorder to save time and money.116 484 Personalized travelplanningBased on rider's origin anddestination(s), personalized travelplan of transit routes andconnections provided via websiteor telephone service.TravelDemandManagement:BusinessOperations2006 N Difficult to reach a significant enoughindividuals, have them make a change andsustain that change in a way that reducesemissions. Provision ofsuch services couldenhance existing programs quantified undermeasures listed elsewhere in this list.117 487 Telecommutingincentives ormandatesThe measure is ill defined and isduplicative of other measures.TravelDemandManagement:BusinessOperations2006 N Mandates not feasible. Suggest combiningmeasures into separate individual measuresfrom Commute Solutions.118 496 Regional VanpoolprogramsCould add more to currentHouston vanpooling program, buta duplicate measure.TravelDemandManagement:RegionalApplications2006 N See measure 109.119 499 Share hybridvehiclesShared vehicles among a group ofownersTravelDemandManagement:RegionalApplications2006 N No evidence that shared vehicles loweremissions because the same number of milecould be driven.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-18IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment120 500 Encourage pooledownership of singleoccupant vehiclesfor local middaytravelEncourage pooled ownership ofcars, trucks; e.g., oneneighborhood collectively owns anSOV for periodic use.TravelDemandManagement:RegionalApplications2006 N No evidence that shared vehicles loweremissions because the same number of milecould be driven.121 501 Car SharingPrograms (Flexcar)Car-sharing programs. We giveour members the key to new cars,trucks, and minivans locatedacross a metropolitan region. Youpay an hourly rate, and thecompany pays for the car,insurance, gas and a reservedparking spot!TravelDemandManagement:RegionalApplications2006 N No evidence that shared vehicles loweremissions because the same number of milecould be driven.122 503 Rideshare matching,transit marketingand informationprogramsThis measure could be included aspart of a larger strategy to reducecommuting by single occupancyvehicles.TravelDemandManagement:RegionalApplications2006 N Reporting requirements would likely make thismeasure be a voluntary measure.123 504 Rewards forreducing totalvehicle milestraveled in a city orregionIt is unclear how this measurewould reduce vehicle milestraveled or how it would bemeasured.TravelDemandManagement:RegionalApplications2006 N124 551 If the California LowEmitting VehicleProgram is adoptedand only LEVcertified, gasolinevehicles are for salein Texas, thenmandated fleetsshould have topurchase the ULEValternative fuelversion of the samevehicle rather thanthe gasoline versionThe California LEV II programincludes new fleet averageemissions standards as well asCO2 reductions. A fleets mandatein addition to the Cal. LEV IIstandards would have a muchlower impact.VehicleEmissionStandards2006 Y + + TCEQ and several state have concluded thatthe California LEV II program would reduceVOC and NOx emissions.http://www.cdphe.state.co.us/op/aqcc/meetingminutes/2007/092107-Final.pdfhttp://www.flchamber.com/docs/Coalitions/Energy/DEP_CA_MotorVehicleEmissions_082307.pdfThis would be in addition to measure125.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-19IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment125 553 Adopt Californiastandards for vehicleemission ratesPublic and Publicly contracted fleetrules or Statewide.VehicleEmissionStandards2006 Y + + Benefit small if limited to these fleets. BetterPM and CO2 benefits from CAL LEV. Pastattempts at statewide legislation to adopt LEVII failed. If requirement is through localordinance or contract terms, vehicles wouldneed to be purchased in California.126 576 Limitations on idlingof heavy-dutyvehiclesMay require city ordinance. Willrequire additional power sourcesfor local major events. Large truckstops have constructedalternatives to idling partiallyfunded by TERP.Vehicle Idling 2006 Y + Idling reductions, while cost effective, typicallyhave a small impact.127 587 Heavy-Duty VehicleBorder InspectionProgram for AB1009 (Pavley 2004)HD commercial vehicles enginesmust meet US HDDV standards inplace at the time of manufactureand must display valid emissioncontrol label.VehicleInspection andMaintenance2006 Y + Smoke check relatively easy to do, NOxwould require heavy-duty dyno or possiblyremote sensing for diesels. High PM usuallycorrelates with low NOx and higher VOCemissions from diesels.128 589 More frequentemissions tests fortaxi cabsRequire taxi fleets to be testedtwice per year to get license tooperate.VehicleInspection andMaintenance2006 N Allow taxis over 5 years old to be eligible forLIRAP (c.f. current 10 year requirement for allvehicles) to provide a better benefit.129 592 Augment truck andbus highwayinspections withcommunity-basedinspections (HDV8)HD vehicles are inspected todetect mal-maintenance andtampering and to measure smokeemissions in mixed-usecommunities.VehicleInspection andMaintenance2006 Y + MY 93-98 reflash if not already done (NOxreductions already included in regionalemissions modeling). Smoke check relativelyeasy to implement but high PM means lowNOx reduction.130 594Addition of HDGV2Bweight class vehiclesto inspection andmaintenance programThe inspection criteria would needto be defined more precisely forthese vehicle types.VehicleInspection andMaintenance2006 N Pre MY 96 vehicles currently receive TSI test.Would need to "centralize" placement of HDdynos. OBDII phase in from MY 2004 -2008.131 598 More frequenttesting for vehiclesthat repeatedly failinspection testsEPA has not quantified the benefitof more frequent testing.VehicleInspection andMaintenance2006 N No modeled benefit. Better to encouragethese vehicles to be replaced (LIRAP) or atleast require repair at Recognized EmissionsRepair Facility.132 601 Extend or expandlight-duty dieselengine inspectionand maintenanceprogramThe technology has yet to bedefined for inspection of thesevehicle types.VehicleInspection andMaintenance2006 N Impractical to ASM test pre MY 96 LDDVs (nocut points available)May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-20IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment133 604 If the largest city in acounty takes part ina testing program,the entire countymust opt-in.Current I/M legislation fornonattainment areas is based oncounties. EAC area requirement isfor county along with the largestmunicipality.VehicleInspection andMaintenance2006 Y + + The benefits are restricted to the smallcounties not already in the program.134 623 Mandated no drivedaysAn extreme measure to prohibitvehicle travel include only ifneeded.VehicleOperationsManagement2006 Y + + Important to evaluate for perspective and as alast resort measure.135 628 Voluntary no driveday programsSuch a voluntary vehicle travelreduction program needs to bedefined more precisely.VehicleOperationsManagement2006 N This would be evaluated as small percentageof individuals voluntarily participating andwould require extensive reporting to claim abenefit.136 629License platesdetermine access tovehicle use (odd/evendriving days)Duplicate measure.VehicleOperationsManagement2006 N See measure 134.137 630 Encourage/MandateLivable CentersIncludes a host of ideas to reducevehicle travel.Sustainableand TransitOrientedDevelopment2008 Y + + Combine with other individual measures intoone package of options for communityplanning. Evaluate, discuss, and then applyspreadsheet-based methodology developedby H-GAC for three selected livable centerscenarios defined in close collaboration withH-GAC and city/land use planners. Twodifferent spreadsheet-based approaches arecurrently available.138 631 DPS-like emissionssensors in HCTRAtoll booths -enhanced smokingvehicles programProgram is ill defined in terms ofthe technology and how it wouldinteract with the current inspectionprogram.VehicleInspection andMaintenance2008 N If we are looking for NOx, difficult to useremote sensing if multiple booths in operation.For smoke, high PM, low NOx.139 632Enhancedenforcement forSmoking VehiclesProgram - vehicleimpounding forviolators (like DallasEmissionsEnforcement PilotProgram)Link to I/M test status: encouragelocal police to enforce existingsmoking vehicle legislationHigh-EmittingVehicleDetection andPrograms2008 Y + May reduce number of vehicles avoiding I/Mtest. Real versus modeled reductions issue.NCTCOG estimates I/M compliance at around80% not 96% as modeled.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-21IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment140 633 Limit left turns onselectedthoroughfares at alltimesDuplicate measure.Traffic FlowImprovements2008 N See measures 74 and 37.141 634 Higher registrationfees for highemissions vehiclesThe measure needs to be refinedto include emissions standardsand emitter status.PricingMeasures2008 N The implementation issues need to beaddressed carefully with regard to model yearand inspection test results.142 635 Prime parking forvanpools/carpools/hybridsDuplicate measure.ParkingManagement2008 N See measure 39.143 636 Hybrid cars parkingmeter fee exemptionHybrid light-duty vehicles cannotdemonstrate much emissionreduction, and this measuremerely provides an incentive fortheir use.ParkingManagement2008 N Hybrid vehicles meet the same emissionstandards as other light-duty vehicles.144 637 Use of taller highwaybarriers to reduce“rubbernecking”This measure would affect freeflowing vehicle speeds.FreewayIncident /RoadwayConstructionManagement2008 N The benefits of the program may be difficult todemonstrate.145 638 Increased use ofhybrid busesHybrid heavy-duty vehicles havebeen funded to date in current airquality programs.Transit 2008 Y + Benefits of this technology can be verified, butis relatively costly for the purpose ofemissions reductions only. Reduced fuelconsumption is an added benefit to theoperator.146 639 Initiate a flexbikeservice to encouragebicyclingDuplicate measure.Bicycle andPedestrian2008 N See measure 1.147 640 Creation of regionalgovernment idlingrestriction MOUIdling is usually a small portion ofthe emissions from vehicles.Vehicle Idling 2008 Y + + Demonstration of the benefit may be difficult.148 641 Industry idlingrestrictionsIdling is usually a small portion ofthe emissions from vehicles.Vehicle Idling 2008 Y + + Demonstration of the benefit may be difficult.See measure 147.149 642 More stringent I/Mcut pointsCut points only relevant to MY 95and older vehicles, number ofwhich reduces considerably eachyear, making this less effective.VehicleInspection andMaintenance2008 Y + + Decreasing benefit in the MOBILE model witheach calendar year. Higher failure rate mayencourage more fraud.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-22IDOldIDControl StrategyDescriptionCategoryYearAddedEPAPQSEVOCNOxComment150 643 Acceleratedevelopment andconstruction of masstransit projectsCapacity improvements to masstransit combined with other busand rail measures.Transit 2008 N Very capital intensive, need to discuss withagencies in terms of potential ridershipincreases.Table 4-2.Non-road vehicle emission reduction measures.IDControl StrategyDescriptionYearAddedEPAPQSEVOCNOxComment1 Aircraft emission standards New emission standards for aircraftengines fall under international andFederal rules.2001 N These are covered by international standards and anylocal measure would not be considered permanent.2 Ordering lowest emissionenginesFleet management of aircraft flyinginto HGB.2001 N These are covered by international standards and anylocal measure would not be considered permanent.3 Changes in general conformity tomake provisions more realistic;Allow equipment turnover tocountGeneral conformity is a criteria tomeet by new projects and notincluded in SIPs2001 N This is not an emissions reduction strategy, but creditshould be taken for lower emitting aircraft.4 Modify regulations so credits canbe generated for generalconformityGeneral conformity is a criteria tomeet by new projects and notincluded in SIPs2001 N This is not an emissions reduction strategy.5a Enhanced Texas EmissionReduction Program (TERP)The TERP program has beenresponsible for significant NOxreductions to date2005 Y + The TERP program could be revised to account for therealities of emission controls on on-road, nonroad, andother mobile source categories with EPA emissionstandards that have been promulgated in recent years.5b Extend TERP to 2018Current TERP legislation providesfunding for the program until 2012.Y + Proactively extending this funding to 2018 wouldensure that this funding would be available until theregion is required to meet attainment.6Aftermarket Technology and FuelAdditive Research ProgramEPA approval of aftermarket and fueltechnologies would be necessary.2001 N Fuel additives not credited in the TERP mightcreditable, if they pass EPA approval. One examplemay include cetane improvers. But the strategy wouldneed to be better defined to provide emissionreductions creditable for SIPs.7 Improve inventory of constructionequipment; Log hours of actualequipment operationActivity reduction of nonroadequipment.2001 N Equipment activity reductions are difficult to prove thata reduction occurred and any reduction would not beconsidered permanent.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-23IDControl StrategyDescriptionYearAddedEPAPQSEVOCNOxComment8 Government constructionincentivesThis measure is considered to includemoney, tax relief, or proposalpreference to firms using cleanequipment.2005 Y + Incentive for the use of clean construction equipmenthas been attempted including the TxDOT program. Butthe reporting requirements andconflicts with the TERPbenefit lead to less use of the program and lowerbenefits than were expected.9Develop air quality bestmanagement practices (BMPs);Use BMPs to manage emissionsfrom construction sites,construction vehicles & wind-blowndustThe BMP could include a cleanequipment use clause.2005 N The program needs to be better defined in terms of theuse and types of equipment at each job site. Thereporting burdens to justify an emission reductionwould be onerous.10 Limitations on idling of heavyduty construction equipmentIdle reduction either through the useof automatic shut-off devices oroperator training.2005 Y + Many states have regulations to reduce equipmentidling. The benefits of the rule may vary dependingupon the implementation and enforcement of theprograms, but generally idling emissions reductions aresmall but cost effective.11 Water injection for diesel engines Engine and Fuel Technology 2001 Y See 5 TERP, measure 5.12 Alternative-fueled equipment forall equipment typesEngine and Fuel Technology 2001 Y See 5 TERP, measure 5.13 Alternative fuel heavy-dutyequipmentEngine and Fuel Technology 2001 Y See 5 TERP, measure 5.14 Lean NOx catalystEngine and Fuel Technology 2001 Y See 5 TERP, measure 5.15 Early introduction of low-NOXenginesEngine and Fuel Technology 2001 Y See 5 TERP, measure 5.16 Selective catalytic reduction(SCR)Engine and Fuel Technology 2001 Y See 5 TERP, measure 5.17 Compression ignition standardsfor vehicles and equipmentEngine Standards 2001 N EPA has already implemented Tier 4 regulations fornonroad equipment.18 Spark ignition standards forvehicles and equipmentEngine Standards 2001 NSmall and large spark-ignition engines have been coveredby EPA rulemakings.19 Lower sulfur fuelsFuel Standards2001 NNo VOC or NOx benefit beyond Federal mandates for lowsulfur gasoline by 2004, on-road diesel by 2006, and alloff-road diesel by 2012.20Texas Low Emission Diesel(TxLED)Fuel Standards2001 N Implemented21 Lawnmower exchange; Trade inold gas powered equipment fordiscounts on zero emissionmodelsA retirement program for old andmalfunctioning lawn and gardenequipment.2005 Y +The benefits of such a program could be established, butfocus primary on VOC reductions. It should not berestricted to lawnmowers and also include otherequipment such as smaller blowers, string trimmers, etc.The overall benefits would be expected to be small, butcould be cost effective.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-24IDControl StrategyDescriptionYearAddedEPAPQSEVOCNOxComment22 Lawnmower recycling programs(rebate program); replace gasmowers with electricDuplicate measure. 2005 Y See 2123 Promote use of cleaner lawn andgarden equipment such as loweremission four-stroke and electricpowered equipmentDuplicate measure.2001 Y See 2124 “Buy a Clunker” concept for smallgas equipmentDuplicate measure. 2001 Y See 2125 Disincentives such as fines ifcaught mowing during OzoneAlertsOperational restriction. 2001 N This isnot a permanent measure and difficult todemonstrate compliance.26 Ban equipment such as twostroke enginesOperational restriction. 2001 NThis would preempt Federal rules.27 No-mowing daysOperational restriction.2005 N This is not a permanent measure and difficult todemonstrate compliance.28 Grass cutting; Public works willdelay cutting grass till 6 pm onozone action daysOperational restriction. 2005 N This isnot a permanent measure and difficult todemonstrate compliance.29 Landscape ordinance fornonresidential areasThis measure would need to beincluded in permits, building zoning,or municipal rules.2005 Y + This measure refers to lower maintenance landscapingthat reduces the need for off-road equipment usagesuch as lawnmowers and could reduce waterconsumption as well. These types of programs aredifficult to administer and verify.30 Use of auxiliary power units(APUs) for locomotives operating;Controls for locomotives are preempted by Federal law, butvoluntary controls might havesome successThis measure is equivalent to an antiidling measure either through the useof devices or operator training.2005 N Automatic idle shut-off devices may be installed onequipment. This measure was largely applied by thelarger railroads on a voluntary basis for previous SIPefforts.31 Accelerated purchase of Tier 2,3, and 4 locomotive engines orremanufactured existinglocomotivesAn accelerated fleet turnovermeasure would need to beimplemented on a voluntary basisbecause of federal preemption.2005 Y + This measure has been superceded by EPA rules forexisting and future locomotives. The 2008 rule includesa remanufacturing provision for locomotives inoperation today. The rule might be implemented morequickly with incentives for remanufacture orreplacement of older engines under a voluntaryprogram.32 Electrification of railRail electrification is nearlyexclusively a passenger rail option,such as the Houston light rail line.2005 N This option may be available for expanded light-rail orother passenger rail options. But the emissionreductions would be less use of on-road vehicles.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-25IDControl StrategyDescriptionYearAddedEPAPQSEVOCNOxComment33 Efficiency improvements on InUse Class 1 Rail Equipment(R11)This measure would improve railconnections, eliminate at grade roadand rail crossings.2005 Y + Rail improvements might be considered if it can beshown that locomotive idling or braking events can bereduced. Usually these improvements also have safetyand congestion relief benefits.34 Limitations on idling oflocomotivesDuplicate measure. 2005 N Automatic idle shut-off devices may be installed onequipment and reductions justified through reporting.Similar to measure 30.35 Portable engine fleet turnover This measure addresses nonroadengines assigned to a specificindustrial facility.2008 Y + Includes registration and accelerated turnover ofequipment to more recent model years but affects asmall portion of the nonroad emission sourcecategories.http://www.arb.ca.gov/portable/portable.htm36A Low Sulfur Fuel for MarineVessel Main and Auxiliary EngineLow sulfur fuels provide a modestNOx reduction with large particulateand SOx emissions reductions.2008 Y + California is proposing this measure as a rule, and thePort of Los Angeles as an incentive.http://www.arb.ca.gov/ports/marinevess/marinevess.htm36B Harbor Craft Fleet Management Harbor craft include tugs, ferries,supply, excursion, and other smallercommercial marine vessels. Themeasure would seek to accelerate thefleet turnover to remanufacturedexisting and Tier 3 and 4 engines.2008 Y + The California rule if finalized in its June 2008proposed format would include provisions for mandatedturnover of harbor craft engines to those meeting loweremission standards. Could be implemented as avoluntary measure to replace engines.http://www.arb.ca.gov/ports/marinevess/harborcraft.htm37 Cargo Handling Equipment FleetManagementCargo handling equipment includesnonroad equipment used atintermodal (ports and rail) facilities tomove freight. The California ruleincludes retrofit or fleet managementwith the use of newer engines tocomply.2008 Y + Encourage accelerated turnover or retrofit of equipmentused at ports and intermodal rail yards.http://www.arb.ca.gov/ports/cargo/cargo.htm38 Clean Fuel Option: ExpandTxLED Use.The use of TxLED could occur insource categories not currentlyrequired to implement the fuel useincluding marine and other engines.N The use of TxLED is already required for sale formarine and locomotive fuel sales in the 110 countiesaffected by the Texas regulation.http://www.tceq.state.tx.us/implementation/air/sip/cleandiesel.html#Draft39 Provide full funding for theNational Retrofit ProgramEPA has set up the mechanism forproviding grants to reduce emissionsfrom off-road equipment under theNational Clean Diesel Campaign,http://www.epa.gov/cleandiesel/2008 Y + The funding varies by year ($47 million in 2008) and iscompetitive from all states. The funding level isrelatively small when applied nationwide.May 2009G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc4-26IDControl StrategyDescriptionYearAddedEPAPQSEVOCNOxComment40 Allow private companies to applyfor NRP grantsClean equipment grants program. 2008 Y + Further investigation into the application process isrequired to determine the applicant restrictions, whichare determined by EPA.41 Allow NRP grants to coverincremental costs for TERP orCMAQ retrofitsSupplemental funding for otherexisting funding programs.2008 N The use of TERP funds to provide matching might bepossible, but would make the Clean Diesel and TERPapplications more complicated. The mix of national andstate funding however does not lead to more emissionreduction.42 Establish emissions tradingprogram for nonroad vehicles(DERC)Emission trading for stationarysources applied to mobile sources.2008 N Verification of emission reduction credits is likely to bedifficult.43 Allow use of TERP funds foradministrative costs. Specifically,this can be used to help smallcompanies without the time orresources to apply and trackretrofitsTERP revisions. 2008 N The TCEQ wouldfind this difficult to justify, and a legalreview of the enabling legislation would be necessaryto determine if TCEQ is allowed to provideadministrative funding. This measure by itself wouldnot reduce emissions.44 Provide cooperative grantassistance to encourage smallcompanies (<20 employees) whodo not have the resources tomanage grants alone to apply forTERPTERP revisions. 2008 N This measure might be addressed through greaterstaffing at TCEQ or the TERP administrative entity.The emission reduction benefit would be associatedwith increase participation rather than with the programitself.45 Development of a Port ofHouston Clean Air Action Planthat seeks to minimize emissionsfrom ships, cargo handlingequipment, on-road drayagetrucks, and port-related rail.Clean Port initiative including on-roadand nonroad source categories.2008 Y + A port related approach could yield emissionreductions, but the program would need to be betterdefined. The strategies available exist in othermeasures listed.46 Adopt policies and programs toincrease the number of cleanconstruction machines used onpublic works projects.Clean construction equipment.Duplicative measure.2008 Y See Measures 8 and 9May 2009

G:\HGAC\Reports\Final_051 109\Sec5_Eval_051109.doc 

### 5-1 5. DETAILED EVALUATION OF QUALIFYING MOBILE MEASURES

This section provides the Short List of Mobile Control Measures, and summarizes the detailed results of the study for voluntary measures th at qualify as emission reduction measures under EPA guidance by the 2015 – 2018 time frame. The ma ster list of measures outlined in Section 4 was pared to just those measures that have emission reduction potential under the EPA guidance outlined in Section 3 and could be implemented locally without requiring state regulations. The measures that remained on this pared down list also excluded several m easures implemented by state or federal agencies. The analysis for this section was more quantitative in nature.

The remaining measures can be found in the following tables. A summary of the on-road measures is provided in Table 5-1 from whic h the specific Transportation Control Measures (TCM) outlined in Appendix E were derived, non-road measures in Table 5-2 and weight of evidence measures in Table 5-3. The detailed su mmaries with full descriptions of the measure, implementation issues, public reaction, and analys is of benefits and cost effectiveness are supplied in Appendix F for on-road measures, Appendix G for non-road measures and Appendix H for weight of evidence measures.

Table 5-1. On-road measures detailed evaluations summary.
Emission Reduction Potential (tpd) Cost Effectiveness ($/ton) ID Control Strategy Description

VOC NOx VOC NOx

1 Bicycle and pedestrian action Benefits from bicycle measures includes new bicycle lanes as well as encouraging greater use of existing lanes instead of vehicle use. But it can be difficult to determine the benefits of such programs.

32 Encourage bicycle use by using ITS to increase safety in strategic bicycle/ automobile conflict

areas Duplicate or supplemental measure. 0.04 0.03 $681k $915k

11 Cleaner diesel fuel/Alternative Fuels There are diesel fuels that have improved performance even beyond the TxLED. They could include cetane additives or gas-to-liquids diesel fuels.
Alternative fuels include: natural gas, propane, hydrogen, electric, and other alternative fuels. These are included only as voluntary measures. unknown 0.02-2.4 unknown $40,000- $600,000

90 Dedicated long route or subscription bus service Long route or on demand personalized transit service similar to other commercial shuttle services but providing lower cost and less stressful methods of commuting or running errands in parts of town that 0.18 0.05 $583k $2,100kMay 2009

G:\HGAC\Reports\Final_051 109\Sec5_Eval_051109.doc 

### 5-2 Emission Reduction Potential (tpd) Cost Effectiveness ($/ton) ID Control Strategy Description

VOC NOx VOC NOx are far from residences.

92, 99

, Electrify bus routes/Accelerate rail expansion Increase transit capacity. Rail evaluations would need to have specific proposals and market analyses. Unknown 0.07 Unknown

39, 47, 51, 57, 85, 102, 106

, Compressed work week, telework, or other commuting alternatives The benefits of this program could be included with a variety of commute reduction options. This represents one alternative of the reduced commuting options. 0.93 0.69 $4k $5k

108 Internet ridematching services Real-time ridematching offered via a website, by an employer, or by a third party (sponsored by city or transportation authority). 0.52 0.38 $2k $2k

109 Purchase vans for vanpools Commute reduction along with the opportunity to buy cleaner vans. 0.10 0.07 $119k $175k

76 Local intersection signal improvements Effectively increasing road capacity to reduced stop and go progression improving arterial speeds.

77 Traffic signal equipment or software updating Effectively increasing road capacity to reduced stop and go progression improving arterial speeds.

78 Emphasis on major route traffic signalization; route traffic platooning Effectively increasing road capacity to reduced stop and go progression improving arterial speeds.

79 Real-time traffic flow management Traffic signals that change timing/ cycles to accommodate real-time traffic conditions.

80 Adaptive traffic signals and signal timing Effectively increasing road capacity to reduced stop and go progression improving arterial speeds.

83 Signal timing and coordination to promote traffic progression Currently signal coordination tends to focus on reducing delay time for individual drivers; alter coordination to promote greatest movement for traffic as a whole. 2.0 1.7 $220K $240K

3 Private sector clean fuel fleets This measure is patterned after the H-GAC Clean Vehicles Program where clean engines (whether alternatively fueled or no) are purchased for fleets to reduce emissions. N/A 1 – 2.5 N/A $18kMay 2009

G:\HGAC\Reports\Final_051 109\Sec5_Eval_051109.doc 

### 5-3 Emission Reduction Potential (tpd) Cost Effectiveness ($/ton) ID Control Strategy Description

VOC NOx VOC NOx

5,6 Public agency clean fleet program Commitment by public agencies to purchase cleanest practicable fleet vehicles could be an element in funding such as through the H-GAC Clean Vehicles Program or a voluntary commitment. See measure #3

22 Dedicated funding for school bus replacement H-GAC Clean Cities/Clean Vehicle or state/federal funding sources. This program specifically targets school bus fleets that trend toward older models. N/A 0.77 N/A $15k

7, 145 Electric vehicles/Increased use of hybrid buses Hybrid or other lower emitting heavy-duty vehicles have been funded to date in current air quality programs. N/A 0.23 N/A $350kMay 2009

G:\HGAC\Reports\Final_051 109\Sec5_Eval_051109.doc 

### 5-4 Table 5-2. Non-road measures detailed evaluations summary.
Emission Reduction Potential (tpd)
ID Control Strategy Description VOC NOx NOx Cost Effectiveness ($/ton)
Voluntary replacement / retrofit program: construction and other off-road Cofunding measure for off-road engines and equipment – construction and others N/A 2.5 $5k – $15k

Voluntary replacement / retrofit program: marine Cofunding measure for off-road engines and equipment – marine N/A 2 – 4 $3k 5b

Voluntary replacement / retrofit program: locomotive Cofunding measure for off-road engines and equipment – locomotive N/A 2 – 3.5 $4k – $7k

8 Government construction incentives This measure is considered to include money, tax relief, or proposal preference to firms using clean equipment. N/A 1 $1k – $19k

21, 22, 23, 24, 29

, Promote use of cleaner lawn and garden equipmentsuch as loweremission four-stroke and electric-powered equipment A retirement program, for old and malfunctioning lawn and garden equipment, and purchase of low emitting replacements. 0.04 0 $15k – VOC

45, 36

, Development of a Ports Clean Air Action Plan that seeks to minimizeemissions portrelated operations. Clean Ports initiative including onroad and nonroad source categories. (Vessel Speed Reduction (VSR), At Berth Control, Low Sulfur Fuel for Marine Vessel Main and auxiliary engines, Engine Improvements) Other off-road measures would follow measures #5b N/A: VSR

0.2: Berth

N/A: Engine 4: VSR

6.8: Berth

4: Engine Unknown: VSR

$11k - $80k: Berth Controls

Unknown: Engine ControlsMay 2009

G:\HGAC\Reports\Final_051 109\Sec5_Eval_051109.doc 

### 5-5 Table 5-3. Weight of evidence measures summary.

ID Control Strategy Description

OR* 21 Continue current passengervehicle scrappage and buyback program Monetary compensation for old vehi cle scrappage. Increase the range of vehicles and heavy-duty truck engines targeted for replacement credit or subsidy.

OR* 58 Pay-As-You-Drive Insurance (per-mile) Insurance costs would be associated with mileage driving by a vehicle increasing the incremental cost per mile driven. The cost of insurance then becomes an incremental cost and could be combined with mileage based registration fees and fuel tax increases to add incentive to alternative transportation.

OR* 126 and OR* 148 Limitations on idling of heavy-duty vehicles May require city ordinance. Will require additional power sources for local major events. Large truck stops have constructed alternatives to idling partially funded by TERP.

OR* 67 and OR* 137 Encourage/Mandate Livable Centers Includes a host of ideas to reduce vehicle travel. Such ideas could be incorporated into ordinances promoting multi-use development.

OR* 139 Enhanced enforcement for smoking vehicles Link to I/M test status: encourage local police to enforce existing smoking vehicle legislation- vehi cle impounding for violators (like Dallas Emissions Enforcement Pilot Program)

OR* 147 Creation of regional government idling restriction MOU Idling is usually a small portion of the emissions from vehicles.

NR**

10 Limitations on idling of heavy-duty construction equipment Idle reduction either through the use of automatic shut-off devices or operator training

i

* OR indicates an on-road measure ** NR indicates a non-road measureMay 2009

G:\HGAC\Reports\Final_051 109\Sec6_LocalSup_051109.doc 

### 6-1 6. LOCAL SUPPORT FOR IMPLEMEN TATION OF MOBILE MEASURES

Throughout the development of the final contro l strategy short lists H-GAC worked with Houston-Galveston-Brazoria area government a nd business stakeholders not only to develop appropriate control strategies to meet the SIP requirements, but al so to recruit st akeholders who would take legal responsibility for implementing these strategies through the establishment of memoranda of agreement (MOA).

To this end, H-GAC scheduled and participated in the following meetings with stakeholders:

- October 8, 2008: Stakeholder Meeting with Airports and Airlines,

- December 1, 2008: Stakeholder Meeting with Railroads,

- December 3, 2008: Stakeholder Meet ing with Tug Boat Operators,

- December 8, 2008: Stakeholder Public Meeting,

- December 15, 2008 Stakeholder Meeting with Construction,

- December 15, 2008: Stakeholder Me eting with Ports and Marine,

- December 16, 2008: Stakeholder Meeting with Industrial Mobile Source,

- December 19, 2008: Conference Call with Airports and Airlines,

- January 6, 2009: Stakeholder Meeti ng with Airports and Airlines,

- January 8, 2009: Stakehol der Public Meeting #2,

- January 21, 2009: Conference Call with Tug Boat Operators,

- January 28, 2009: Conference Call with Tug Boat Operators,

- January 28, 2009: Stakeholder Meeting w ith Harris County Fleet Managers,

- January 27, 2009: Stakeholder Meet ing with Local Governments,

- January 28, 2009: Presentation to Local Military Stakeholders,

- February 3, 2009: Conference Call with Airports and Airlines,

- February 9, 2009: Presentation to M ontgomery County Commissioners’ Court,

- February 9, 2009: Conference Call with Airports and Airlines,

- February 19, 2009: Presentation to City of Alvin.

Despite these efforts, H-GAC staff has, to date , been unable to secure any MOAs, which would result in further emission reductions from non-ro ad sources. Communicati ons with stakeholders have determined that the cause of this reticence is primarily a result of the current economic climate. Secondarily, many businesses that had voluntarily entered into Memoranda of Agreement in the 2000 SIP believed that they were penalized when the Texas Emission Reduction Program was developed because they had to meet their MOA commitment before they could apply for TERP funding, where others who had not committed initially were able to apply for TERP funding. H-GAC w ill continue to pursue thes e agreements to secure emission reductions.

### APPENDIX A

Summaries of the Houston-Galveston Area Council of Governments Meetings with the Texas Commission on Environmental Quality and Various Stakeholders concerning the Houston-Galveston-Brazoria Eight-Hour Ozone State Implementation Plan Master List Control MeasuresG:\HGAC\Reports\Final_051009\ Appendix A_051009.doc 

### -1 

## Houston-Galveston Area Council of G overnments Meetings with the Texas Commission on Environmental Quality and Various Stakeholders concerning

the Houston-Galveston-Brazoria Eight-Hour Ozone State Implementation Plan Master List Control Measures

MEETING SUMMARIES

Airports/ Airlines Stakeholder Meeting May 22, 2008; held at H-GAC office in central Houston

Stakeholders present: Roy Conn (Continental Airlines), Marianne Csaky (Continental Airlines), Dave Walden (Continental Airlines ), Jim Parise (HAS), John Hall (consultant) Staff members present: Lola Brown (TCEQ), Theresa Pella (TCEQ), Santos Olivarez (TCEQ), Shelley Whitworth (H-GAC), Graciela Lubertin o (H-GAC), Andrew DeCandis (H-GAC), and Kelli Angelone (H-GAC).

TCEQ presented information concerning emissions inventories for the airport industry for the years 2000, 2002, and 2005. H-GAC presented informa tion on suggested airport mobile control strategies and also on third-party TERP grants.

Comments and concerns included:

1) Questions regarding TCEQ’s methodology for industry growth rates: Federal Aviation Administration possesses 2007 data on the indus try and perhaps TCEQ’s data is gleaned from another source. TCEQ promised to send that information out. 2) How could the airports/ airlines industry contribute to air quality improvement? The industry has already made large contributions, especially in th e area of fuel conservation. 3) TCEQ asked if military flights at Houston’ s major airports were an important issue because their data only covers commercial flig hts. The consensus was that military flights were mainly from smaller airports and were a minor part of major airport traffic. 4) Some efforts on the part of airports ma y be hard to quantify. H-GAC recommended sharing information with TCEQ because th ere may be methods for quantifying those efforts, or ways may be found to do so if th e efforts are seen to merit an attempt. 5) Is TxLED already used in off-road emission inventories? It has been established that TxLED or ultra-low sulfur diesel is used by most off-road and on-road equipment because it is widely available. 6) Due to low turn-out on the part of stakehol ders at the meeting, it was suggested that HGAC present the same information at some regular meetings that airport-industry groups hold for themselves. As of 7/15/2008, those pr esentations have not been given despite efforts on the part of H-GAC and air port-industry groups to coordinate.G:\HGAC\Reports\Final_051009\ Appendix A_051009.doc 

### A-2 

## Construction Industry Stakeholder Meeting June 3, 2008; held at H-GAC office in central Houston

Stakeholders present: Charles Webb (JD Abrams), Jeff Nielsen (HCA), Terry Williamson (Texas Sterling Construction), Bob Lanham (Wi lliams Brothers), Jeff Greene (Durwood Greene Construction), Dale Kornegay (BorTunCo), Peck Boswell (BRH Garver Const.), Herb Young (Smith & Company), AP Boyd (AGC of Texa s), Greg Webb (Hi-Way Equipment), Mike Wenske (Hi-Way Equipment), Jim Slack (Slack & Co.), Phillip King (Century Asphalt), Kyle Walker (Valero), Michael DeVita (McCarthy) , Jerry Mayer (McCarthy), Dana Blume (POH), Jay Adams (PBS&J), Armando Jaramillo (OldCastle PreCast), David Boehm (NBG Constructors) Staff members present: Santos Olivarez (TCEQ), Lola Br own (TCEQ), Anusuya Iyer (TCEQ), Charles Airiohuodion (TxDOT), Shelley Whitworth (H-GAC), Graciela Lubertino (H-GAC), Andrew DeCandis (H-GAC), a nd Kelli Angelone (H-GAC).

TCEQ presented information concerning the emi ssions inventories for the construction industry for the years 2000, 2002, and 2005. H-GAC presented information on the suggested construction mobile control strategies and al so on third-party TERP grants.

Comments and concerns included:

1) Industry representatives asked if the entire N on-Road Draft Master Control Strategies list could work as a VMEP. TCEQ and H-GAC replie d that there might be some concerns as to how CMAQ and TERP would be credited, but that it was possible. 2) Any research into technological improvement s for the industry need to be short-term research that brought technologi es to the general market. 3) The issue of logging hours of actual equipment usage was seen to be a violation of businesses’ privacy and unfavorable for i ndustry; although government groups really need this data to develop more accurate inventories. 4) Selective catalytic reduction was seen as a viable long-term solution which should be investigated. 5) Concern was expressed that the wording of so me control strategies implied mandated use of technologies, and it was advised that this might exacerbate the price of fuel-- something industry representatives agreed would be undesirable. 6) Construction representatives were certain that ultra-low sulfur fuels were being used in almost all equipment because that type of fuel is widely available.



## Railroad Industry Stakeholder Meeting June 12, 2008; held at H-GAC office in central Houston.

Stakeholders present: Mike Clift (BNSF), Nicholas Willia ms (representing Congressman Nick Lampson), Melissa Hagan (UP) Staff members present: Theo Vosub (TCEQ), Lola Brown (TCEQ), Koy Howard (TCEQ), Donna Huff (TCEQ), Charles Airiohoudion (TxDOT), Shelley Whitworth (H-GAC), Andrew DeCandis (H-GAC), and Kelli Angelone (H-GAC).G:\HGAC\Reports\Final_051009\ Appendix A_051009.doc 

### A-2 TCEQ presented information concerning the emissi ons inventories for the railroad industry for the years 2000, 2002, and 2005. H-GAC presented information on the suggested railroad mobile control strategies and also on third-party TERP grants.

Comments and concerns included:

1) Will the funds from the third-party TERP gran t, that H-GAC is going to be awarded, be available for other groups beside the ones th at requested it? Part ies not listed on thirdparty TERP grants are still eligib le to apply for those funds. 2) Proposal of a control strategy to help railro ads in the Houston-Galveston-Brazoria region obtain auxiliary power units would not be he lpful because they are only effective for railroads in cold climates. 3) The larger railroads have idle-reduction techno logies on almost all of their trains which reduces fuel consumption; so more idling reduction or automatic shut-off technologies would not significantly reduce emissions. 4) Industry representatives commented that TC EQ’s eligibility form ulas made it more difficult for railroads to qualify for funding. 5) Most locomotives are retrofitted, and Tier II locomotives are the lowest tier currently available on the market.



## First Marine/ Ports Stakeholder Meeting June 12, 2008; held at H-GAC office in central Houston

Stakeholders present: Robert Anatra (Ports America), Chuck Graham (Ports America), Matt Chapman (Ports America), Kenneth Kidwell (SSC USA), John Pace (ExxonMobil), Kenneth Gathright (Port of Houston), Bradley Loomis (Port of Houston), Richard Myers (EarthCon), Brad Stoker (WGMA), Nathan Wesely (WGM A), Owen Parker (Dannenbaum), Charles Airiohoudin (TxDOT), Christine Ha rris (Kinder Morgan), Kevan Mc Gregor (Shell), Jim Guidry (Kirby Corp), Lisa McMicheal (P ort of Freeport), Stuart Muelle r (Weston Solutions), Harless Benthur (attorney), Sylvia Medina (EECOC) Staff members present: Theo Vosub (TCEQ), Koy Howard (TCEQ), Lola Brown (TCEQ), Donna Huff(TCEQ), Charles Airiohoudin (TxDOT), Shelley Whitworth (H-GAC), Graciela Lubertino (H-GAC), Andrew DeCandis (H- GAC), and Kelli Angelone (H-GAC).

TCEQ presented information concerning the emissi ons inventories for the ports industry for the years 2000, 2002, and 2005. H-GAC presented inform ation on the suggested ports mobile control strategies and on third-party TERP grants.

Comments and concerns included:

1) TxLED or ultra-low sulfur diesel may be the only type of fuel avai lable to those in the ports industry, rendering that suggested cont rol strategy obsolete unless it needs to be documented. 2) General concern was expresse d regarding the clarity of the control strategies and industry’s ability to provide meaningful co mment. H-GAC has since then ‘cleaned up’ and offered further guidance and descrip tion on the control strategies list.G:\HGAC\Reports\Final_051009\ Appendix A_051009.doc 

### A-2 

## Second Marine/ Ports Stakeholder Meeting June 19, 2008; held at H-GAC office in central Houston

Stakeholders present: Mark Rodriguez (TxDOT Ferry), Addie Wiseman (AWO), Kenneth Gathright (Port of Houston), Bob Fry (MegaFleet ), Shelby Startz (Jacinto Port), Blake Beall (Kirby Corp), Amy Husted (Kirby Corp), Tom Tray (Bay-Houston Towing) Staff members present: Theo Vosub (TCEQ), Donna Huff (TCEQ), Shelley Whitworth (HGAC), Graciela Lubertino (H-GAC), Andrew DeCandis (H-GAC), and Kelli Angelone (HGAC).

TCEQ presented information concerning the emissi ons inventories for the ports industry for the years 2000, 2002, and 2005. H-GAC presented inform ation on the suggested ports mobile control strategies and on third- party TERP grants. H-GAC mentione d that the marine sector had the largest projected growth in regional NOx emissions.

Comments and concerns included:

1) Industry representatives asked TC EQ if aggregated ship data was available. They wanted to know if data was available broken down into inland vessels and ocean-going vessels. TCEQ said they would look into it. 2) There was concern that projec ted growth data from the ports would be skewed because most industry growth would be on the tr ucking side. H-GAC wondered if projected growth was still available because that da ta would be helpful for inclusion in the emissions inventories. 3) One example put forth by H-GAC as an em issions reduction technology was ship stack scrubbers. Industry representatives said th at was a good example but scrubbers do not reduce NOx particulate matter. 4) Industry representatives mentioned the Ca lifornia law governing foreign ocean-going vessels and their emissions was ove rturned by the Supreme Court. 5) Two control strategies industry inquired about were the “California Marine Vessel Main and Auxiliary Engine Rule” and the “Califor nia Harbor Craft Rule”. H-GAC explained that these were included by TCEQ at a prev ious meeting. It wa s added that industry might want to enter into a Memora ndum of Agreement or Memorandum of Understanding with H-GAC concerning one or both of these strategies, but that they were not being proposed to industry as stra tegies to implement as mandates.



## Small Local Government Stakeholders Meeting July 22, 2008; 

### held at H-GAC office in central Houston

Stakeholders present: Barry Brock (City of Humble), D on Brandon (Chambers County), Marie Herndon (City of Prairie View) Staff members present: Brian Christian (TCEQ:SBLGA), Th eresa Pella (TCEQ), Dick Karp, (TCEQ), Lola Brown (TCEQ), Clarence (TCEQ:SBLGA), Shelley Whitworth (HGAC), Graciela Lubertino(HGAC), Andrew DeCandis(HGAC), Kelli Angelone (HGAC)

TCEQ presented information on the components of the SIP, discussed the process by which ozone is formed, and outlined the method of phot ochemical modeling that is used in the HGB nonattainment region. TCEQ also gave a presenta tion about the purpose and services availableG:\HGAC\Reports\Final_051009\ Appendix A_051009.doc 

### A-2 for local governments and small businesses th rough the Small Business/ Local Government Office (SBLGA) of TCEQ.

H-GAC presented information on the role of H-GAC in the region and its responsibilities on the development of the SIP, the regional transpor tation plan, and the link between both of them.

Comments and concerns included: 1) What does the 96 ppb design value mean? The 96 ppb is the average ozone concentrati on measurement over 3 years for the highest monitoring site in the Houston area (Bayland Park). 2) Is Waller County listed as nonattainment? Waller County is listed as nonattainment be cause it is in the HGB region and closely tied economically and geographically to the countie s, such as Harris County, which contain the majority of the monitors in violation of the standard. 3) To be in attainment the region must be below the 85 ppb standard, so 84 ppb is attainment. 4) Has TCEQ taken into account noncomplia nce with government law in the SIP? Yes. The paperwork involved with the SI P would not change as people come into compliance, only the monitors would be affected.



## Industrial Mobile Sources Stakeholders Meeting August 13, 2008; 

### held at H-GAC office in central Houston

Stakeholders present: Perry Galloway (NRG Texas), Robert Anatra (Ports America), Matt Chapman (Ports America), Julie Woodard (Dow ), Judy Bigon (ExxonMobil), Elena Craft (ED), Roy Conn (Continental), Catarina Cron (Harris County), Dana Blume (POH) Staff members present: Theresa Pella (TCEQ), Anusuya Iyer (TCEQ), Shelley Whitworth (HGAC), Graciela Lubertino(HGAC), Andrew DeCandis (HGAC), Ben Finley (HGAC), Kelli Angelone (HGAC)

TCEQ presented an inventory update for industria l mobile non-road sources and the timeline for SIP submission. For the industrial equipment em ission estimations, the inventories take into account EPA programs and regular fl eet turnover; so accelerated tu rnover due to legislation and other programs are part of the estimates. The estimations for non-road fleets include several inputs, extrapolations, and TCEQ field work survey for the industry. The ‘Industrial Mobile’ portion of Non-Road emissions is 13.3%. Fo rklifts account for about 98% of the whole equipment for Industrial Mobile Non-road, and about 54% of them are electric and 45% are diesel.

HGAC presented an overview of SIP control strategy development for on-road and non-road sources, a third party TERP update, and the time line for the development of the mobile source control strategies for the SIP. HGAC cannot mandate reductions and must rely on voluntary emission reduc tions to meet the SIP requirements. One advantage during this SIP timeframe is that TERP is committed to being in place throughout the process. MOUs are volunta ry and reflect only what a company thinks it can achieve, not what they are unwilling to commit to.G:\HGAC\Reports\Final_051009\ Appendix A_051009.doc 

### A-2 Comments and concerns included:

1) Industrial representatives as ked about the information so urces for the inventories generation, to which TCEQ answered that th ey got most of the information from the Industrial Truck Association and from phone surveys we conducted. 2) TCEQ does not know if “gators” and golf carts are counted (m ostly gasoline engines), but they will find out. 3) TCEQ stated that the distri bution industry is counted as part of this inventory 4) TCEQ will send out the study that was done on ‘Industrial Mobile’ since that would contain a lot of answers, including how many 2- and 4-stroke engines there are. 5) What are the consequences for not meeting the MOU agreement? With these MOUs, we hope to give businesse s some recognition for what they are doing. If the MOU is entered and not met, it may reflect back on that company. Other than that, consequences are for us – we have to figur e out how to make up those reductions with another of our programs. 6) Are there any other control strategies for ‘I ndustrial Mobil’ besides electric forklifts? There are control strategies that involve clean er fuels or clean construction for those of you that may be developing new properties, but other than that, we are looking to you to tell us what you can do. 7) If voluntary reductions are only a llowed to be 3% of the reductions. Where are the rest of the reductions coming from? The rest are coming from regular fleet turn over and new standards coming for vehicles, ships and equipment. 8) Has HGAC been involved with other grants li ke DERA? There is concern that with the new regions that will be drawn by EPA a nd TCEQ TERP will be spread too thin. HGAC employs other funding sources such as SEP and CMAQ, but we agree, it is important to have other sources of fundi ng, but we missed the proposal deadline for DERA. It’s important to remember that agen cies such as HGAC must also find places to supply administrative funding as well, wh ich is a huge challenge in itself. 9) Can private industry make use of TERP? H-GAC is planning to help with TERP f unding by using the third-party agreement. 10) What about the requirement in TERP about dest roying vehicles? It is a lot of capital to lose and turn over in a short time (TERP requires you buy new vehicl es and destroy the old vehicles within 90 days). If you are interested in committing to accelerat ed fleet turnover, we cannot help you fund it if you do not destroy the engines or vehi cles, but if you commit to an MOU, you may be able to send the old vehicles (minus the engines) out-of-region or out-of-state and get funding through CMAQ.

### APPENDIX B

Written Comments from Stakeholders and their Respective Responses Regarding Master List Control StrategiesG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-1 The comment periods for the Draft On Road Co ntrol Strategy List a nd the Draft Non Road Master Control Strategy List was Frida y, May 23, 2008 to Tuesday, August 5, 2008. Written comments were received by:

Mail: Transportation Department, Air Qual ity Section, Houston-Galveston Area Council P.O. Box 22777 Houston, Texas 77227-2777 E-mail: airquality@h-gac.com Fax: (713) 993-4508

H-GAC received a total of 17 written comments. H-GAC has separated the written comments into two sections:

1. Rail Issues, Marine and Port Issues, and Special Interest Groups 1. BNSF Railway Company 2. Earthcon Premier 3. Port of Houston Authority 4. Sierra Club

2. Association of General Contractors 1. Angel Brothers Enterprises, Ltd. 2. Balfour Beatty Infrastructure Inc. 3. Beyer Construction, LLP 4. Cravens Partners, Ltd. 5. E.P. Brady, Ltd. 6. Highway Pavement Specialties, Inc. 7. J.D. Abrams, L.P. 8. NBG Constructors 9. Pavers Supply Company 10. Prime Eco Group 11. Smith & Company 12. W.W. Webber, LLC 13. William Brothers Construction Company, Inc.

Each comment in the Rail Issues, Marine and Port Issu es, and Special Interest Groups section is shown in its entirety. Each comment is followed by the response given.

Each comment in the Association of General Contractors section included the same “Comments on Draft Off Road Strategies” tabl e. This table has been removed from each comment, and is displayed in B.2.14. Because comments in this section address the same issues, the same response was given. This response is displayed in B.2.15.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-2 B.1.1.1 Comment from BN SF Railway Company


# Comments on Non-Road NOx Reduction Strategies 8 Hour Ozone Attainment SIP Revision Houston-Galveston Area Council July 15, 2008 BNSF Railway Company 4200 Deen Road Fort Worth, Texas, 76106

HGAC ID Number 30 – Use of APUs for lo comotive operations to reduce idling Note that auxiliary power units (A PUs) are best suited for use in colder climates. BNSF typically deploys the APU units on switch en gines that operate in areas su ch as Chicago and Denver. For example, the EcoTrans K-9 APU is used to prov ide electrical power to immersion heaters for lube oil and the main engine water. The sout h Texas climate would minimize the use of the APU. In the colder, winter months, the APU woul d operate as designed. However, for most of the year, the locomotive lube oil, diesel fuel and cooling water would never get cold enough for the APU to run.

BNSF has an aggressive program of adding idle reduction kits to the switch engines in the Houston-Galveston (HG) area. Cu rrently, 15 switch engines have ZTR SmartStart units installed. The SmartStart unit monitors the “health” of cri tical locomotive systems such as battery charge and water coolant temperature. If the SmartStart unit determines that the locomotive is idling and can be restarted, the engine is shutdown. Unlike the APU, if the temperature drops and the lube oil and coolant water also cool below a set temper ature, the main engine is restarted instead of using a smaller engine to provide au xiliary electrical power or heat.

As information, all new line haul locomotives that BNSF is purchasing come with idle reduction technology installed at the fact ory. All of the switch engines purchased under the TERP are equipped with idle reduction technology.

HGAC ID Number 31 – Accelerated Purchase of Tier II Locomotives Since these NOx control measures were developed by HGAC, the EPA has passed new locomotive emission rules. Starting in 2009, the phase -in of Tier 3 locomotiv es will begin. Tier 4 locomotives, employing catalytic after treatment t echnology for exhaust gases, will be phased-in beginning in 2014.

BNSF has been aggressively purchasing new, more fuel efficient locomotives. As new locomotives enter the fleet, older units are rem oved from service. At the end of 2007, BNSF had 989 Tier II locomotives in its fleet. The annual purchase plan for new locomotives is approximately 300 per year. BNSF has spent billions of dollars modernizing its locomotive fleet over the last five years.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-3 H-GAC ID Number 32 – Electrification of Rail Switching Yards The electrification of rail facilities is not pr actical for several reasons . First, the cost of undertaking such an effort would require massi ve expenditures of cap ital on construction and equipment acquisition. There are currently no Class I railroads in the United States that move freight using electricity off of the grid. S econd, there is no large s cale production of high horsepower locomotives that use external electr ical power. Lastly, the implementation of this strategy would take many years to fully implement.

HGAC ID Number 33 – Efficiency Improvement s on In-Use Class 1 Rail Equipment BNSF requested further clarifi cation from HGAC on this impl ementation strategy and never received a reply.

HGAC ID Number 34 – Limitation on Idling of Locomotives Comments were provided by BNSF to the TCEQ on proposed locomotive idling regulations in 2005. See the attached document for specific comments on this NOx reduction strategy.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-4 

# COMMENTS OF THE THE BURLINGTON NORTHERN AND SANTA FE RAILWAY COMPANY

on TCEQ’s Proposed Rules 114.520, 114.522, 114.526 and 114.529 Rule Project Number 2005-006-114-AI Submitted to the Texas Commission on Environmental Quality January 6, 2005

The Burlington Northern and Santa Fe Railway Company (BNSF) is pleased to submit these comments on the above-referenced proposed TCEQ rules and revised State Implementation Plan narrative. The proposed rules were issued by the TCEQ on November 17, 2004. BNSF has approximately 70 switch locomotives operating in the Dallas / Forth Worth (DFW) area which would be subject to the regul ation. We applaud TCEQ, the C ouncil of Governments, and the business community for all the efforts to re duce emissions and improve air quality. Our corporate headquarters is located in this region and thousands of our employees live in the DFW

area.

BNSF has several concerns regarding the effect ive implementation of the rules as they are currently drafted. The concerns include rail safety issues, employee productivity, preventing locomotive freezing, unnecessary requirements wh en we already are reducing emissions, and extreme recordkeeping requirements. The ramifi cations of a restriction for switch engines limiting idling to no more than 15 minutes are much greater than might be imagined to those unfamiliar with railroad operations. A locomotive is quite unique compared to trucks or construction equipment which also can idle considerably.

Safety of BNSF Employees and the Public The Federal Railroad Administrati on (FRA) requires that the brak ing system on all trains be tested before they are cleared to leave a yard. The braking system on the railcars is operated by the presence of high pressure air. This high pr essure air is supplied by a compressor that is powered by the locomotive engine. Depending on the length of train, it co uld take at least an hour of engine idle time to generate enough air pr essure to fully charge the braking system. To comply with FRA requirements, and provide for the safety of BNSF employees and the public, it is critical that the switch engine idle more than fifteen minutes to allow the braking system to be properly tested. In addition, if the air pressure in the system were to bleed off when the locomotive is standing with a group of cars and shut down waiting for the track to clear, the brakes could release allowing the train to roll in to the path of other tr ains, cars or locomotives. Every time that a switch engine is shutdown, BN SF policy requires that the locomotive be “tieddown.” This is done by setting the handbrake on the switch engine. If the switch engine is coupled to any railcars when it is shutdown, the handbrakes on severa l of the cars must also be engaged. This is a laborious pr ocess that involves spinning a la rge wheel that activates the brakes. When the switch engine is started agai n for movement, the process has to be reversed. The increased physical exertion on employees requi red to set brakes dozens of times during an eight hour shift could possibly lead to safety concerns.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-5 During periods of cold weather, it is necessary to run the cab heater to provide warmth for employees. The cab heater operates off of pow er and heat provided by the main engine. Obviously, if the switch engine has to be turned off when occupied, the employees will not have a source of heat. This scenario presents unnece ssary discomfort and danger during periods of abnormally cold weather.

Reduced Rail Facility Productivity As was shown above, the act of shutting off a switc h engine is not as simple as pressing a button and “walking-away.” Even the smallest en gines exceed 1500 horsepower. These engines are difficult to start. An intricate set of procedures is in place to start and stop the engine so that the switch engine is safe when shut off and that it will restart when needed.

The procedure that is in place at BNSF to turn off a locomotive has approximately five steps. Specific switches and circuit breakers must be turn ed off and isolated while others must be left on or closed. According to BN SF operating personnel, running through this shutdown procedure takes approximately 15 minutes per engine. Most switching is done with two locomotives, so each required shutdown would ta ke approximately 30 minutes.

The EPA standard duty-cycle for a switch engine assumes that approximately 50% of the engine working time is at idle. Most rail facilities typically never close and the switch engines operate 24 hours a day. If 12 hours of the typical working day is spent at idle , the crews manning the switch engines will be required to perform th e shutdown procedure dozens of times per day, causing significant delays to the movement of freight.

Trains that operate on our netw ork have critical, highly sensi tive time schedules that require strict adherence. This allows BNSF to maximi ze the utilization of its infrastructure and train crews. If a train can not leave a terminal due to congestion ca used by slow railcar switching, a cascade of events occurs, which can cause a whole segment of track to become less efficient. For example, a locomotive on a train from Ft. Wort h may be assigned to another train leaving Amarillo when it arrives. If the train from Ft. Wo rth is late leaving, it can also cause the train originating in Amarillo to be late. You can easily see how slowing efficiency at one yard begins to affect efficiency and time schedules across the system.

Under the proposed rules, the rail facilities in the DFW area will likely become less efficient. As a result, more switch engines will likely have to be used to perform the same level of work before the implementation of the proposed rules. This will have the adverse effect of negatively impacting air quality in the DFW non-attainme nt area, and actually increasing locomotive emissions instead of decreasing them.

Locomotive Freeze Protection Unlike most internal combusti on engines, locomotive engines do not use antifreeze compounds in their engine cooling systems. This is due to the high heat load that must be efficiently transferred from the engine to the cooling wate r during use. Because of this, locomotive engines are typically left idling during cold weather. If the engine were to stop during cold weather, the engine block could freeze, causi ng significant damage. Because of this, locomotive engines are equipped with an automatic dump system for the ra diator water when it nears the freezing point.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-6 All new line-haul locomotives come equipped with automatic start and stop equipment that is designed to keep the engine and fluids warm while minimizing idle time. We have retrofitted more than 1700 high horsepower General Electric locomotives with automatic start-stop equipment. This will reduce the amount of time our road fleet will id le in yards and at locomotive servicing facilities. However, due to the age of the locomotives, most existing switch engines do not have this equipment. BNSF is a ddressing this issue by a dding after market idle control technology to a numb er of switch engines.

TERP Funded Idle Reduction Equipment BNSF applied in 2003 for funding under the Texa s Emissions Reduction Program (TERP) for the installation of idle reduc tion technology on approximately 30 switch engines in the DFW area. The application was su ccessful and $333,000 was granted.

The switch engines are being equipped with th e ZTR SmartStart system. With this technology, several critical locomotive operating parameters , such as air pressure and cooling water temperature, are continuously m onitored by the ZTR system. If all of the parameters are within an acceptable range, the locomotive is automa tically shutdown during idle. If during the shutdown mode, one of the operating parameters falls below an acceptable limit, the locomotive is automatically restarted. This system does not ha ve any auxiliary heating system to add heat to the locomotive fluids or the cab and will not shut down locomotives during cold weather.

If BNSF is forced to shutdown all switch engi nes after only 15 minutes of idle time, the effectiveness of the TERP funded ZTR systems is going to be negatively effected. The ZTR units that are currently being installe d are programmed to conduct an auto stop of the switch engine at 20 minutes of idle time. While the switch engines are in the yard working, it is not anticipated that many auto stops will be initiated. Th is technology primarily addresses unnecessary locomotive idling that occurs.

Increased Recordkeeping Requirements The recording of every shutdown event for ever y switch engine will be extremely burdensome. This additional recordkeeping reduces the productivity of our train crews. The proposed shutdowns will require the development of forms, either single event records or daily logs that will have to be managed, collected, reviewed and stored. There was no indication if anyone outside of the railroad would ever see these forms or logs. This brings into question the value of collecting this information. If th is information really is necess ary, a less intrusive and disruptive method must be found.

Other Locomotive Emission Reductions BNSF is reducing emissions in other ways which should be counted in the SIP. For example, BNSF has retrofitted 952 older lo comotives to Tier 0 levels. Th is reduces the nitrogen oxide emissions by 33 percent from the uncontrolled leve ls. BNSF has also purchased four Green Goat hybrid switch engines for use in the DFW area. These were purchased with TERP funding and BNSF has agreed to operate these units in the DFW area for nine years. We also purchase low torque bearings for our railcars. This reduces tr ain resistance and there by reduces emissions from the engine.

ConclusionsG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-7 BNSF is aggressively addressing emissions from switch engines in the DFW area. Approximately 30 switch engines are having ZTR Sm artStart idle reduction units installed. This equipment is designed to identify unnecessary id ling of the switch engine, check its operational status, and safely shut it down. BNSF has also invested in new road locomotives with automatic engine start/stop features. Some of these locomo tives will be used in and through the DFW area. BNSF, with assistance through the TERP, will bring four hybrid swit ch engines into use in the DFW area, which will lead to eliminating four older traditional switch engines.

With these technological improvements and addi tions, Appendix K could be unnecessary as it pertains to BNSF and most likely the rest of the rail industry in the DFW area.

BNSF has a good working relationship with TCEQ a nd the USEPA. We are available to further discuss these comments with TCEQ and look forward to working with you on this issue.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-8 B.1.1.2 Response to BNSF Railway Company

August 29, 2008

Michael Clift Manager Environmental Operations BNSF Railway 4200 Deen Road Fort Worth, TX 76106

Dear Mr. Clift:

Thank you again for your comments regarding th e mobile source control measures for the Houston-Galveston-Brazoria 8-Hour Ozone St ate Implementation Plan (SIP). We have considered your comments and would like to take a moment to respond to your comments directly.

Your letter expressed comments on the following control measures:

• Non-road Measure 30 – Use of APUs for locomotive operations to reduce idling: Thank you for bringing this to our attention. We w ill address this issue when creating a more refined version of this control strategy list in the latter part of this year.

• Non-road Measure 31 – Accelerated Purchase of Tier II Locomotives: H-GAC thanks you for your continuing work to replace olde r locomotives with models which include newer and cleaner engines.

• Non-road Measure 32 – Electrification of Rail Switching Yards: Thank you for bringing this to our attention. We will address this issue when creating a more refined version of this list in the latter part of this year.

• Non-road Measure 33 – Efficiency Improvements on In-Use Class 1 Rail Equipment: HGAC has worked to clarify all of the control strategies by increasing the specificity of the control strategy descriptions and to add comments to provide additional information about each strategy.

Control Strategy Description Comment
Efficiency improvements on In-Use Class 1 Rail Equipment (R11) This measure would improve rail connections, eliminate at grade road and rail crossings. Rail improvements might be considered if it can be shown that locomotive idling or braking events can be reduced. Usually these improvements also have safety and congestion relief benefits.

• Non-road Measure 34 – Limitation on Idling of Locomotives: H-GAC analysis has determined that this measure is similar to Non-Road Measure 30. We need some further analysis to be able to determine if Measure 34 wi ll already be counted on 2018 inventories. This analysis will be made during the latter part of this year.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-9 Throughout the latter part of 2008, H-GAC will work to quantify and re fine this Master List into a Short List of measures which the Ho uston-region will recommend to TCEQ for implementation in early 2009 as part of the SIP. You can follow the pr ogress and see a more detailed summary of the SIP process, the timeta ble for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.hgac.com/taq/airquality/sip/default.aspx

Additionally, we encourage you to become more i nvolved with the SIP process. We are actively recruiting regional businesses that are willing to make their own commitments to reduce air pollution within the Houston-region through vol untary commitments. I am happy to provide more information about the form and scope of these commitments by phone (713-499-6695) or email ( Shelley.Whitworth@h-gac.com ).

Sincerely,

Shelley Whitworth Air Quality Program ManagerG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-10 B.1.2.1 Comment from Earthcon Premier

Good afternoon;

Following the Emissions Reduction Strategies for the Marine Industry meeting held at H-GAC on June 12, 2008 we discussed briefly the criteria for emission reduction strategy viab ility according to EPA. We submit the Marine Exhaust Scrubber (e xhaust gas cleaning system) for inclusion in the list of SIP control strategies.

This technology was developed with assistance from a US Environmental Protection Agency (EPA)/West Coast Collaborative grant and a contribution from the Puget Sound Clean Air Agency. Major support also came from the Vancouver Port Authority, Environm ent Canada, British Columbia Ministry of the Environment, the B.C. Clean Air Research Fund, and the Port of Seattle.

Use of this technology can reduce sulfur emissions by 99.9% and particulates by 85%. It is capable of reducing these pollutants to a greater degree than using low sulfur (0.10%) marine diesel oil.

In April of this year, the International Maritime Organization (IMO) through its Marine Environment Protection Committee, adopted gui delines for exhaust gas cleaning systems. We submit that these guidelines should be considered by the State of Texas to be applicable to any Marine Exhaust Scrubber cleaning system included in the list of control strategies.

Kindly call or write me with any questi ons or for additional information.

Richard R. Myers, J.D. Senior Consultant EarthCon Premier 600 Kenrick, Suite C-32 Houston, Texas 77060

phone (281) 591-0611 fax (281) 591-0636 cell (713) 256-0461 rmyers@premiercorp-usa.comG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-11 B.1.2.2 Response to Earthcon Premier

August 29, 2008

Mr. Richard Myers EarthCon Premier 600 Kenrick, Suite C-32 Houston, TX 77060

Dear Mr. Myers:

Thank you again for your comments regarding th e mobile source control measures for the Houston-Galveston-Brazoria 8-Hour Ozone St ate Implementation Plan (SIP). We have considered your comments and would like to take a moment to respond to your comments directly.

Your comment recommended that H-GAC consider adding marine exhaust cleaning systems such as scrubbers to the list of SIP c ontrol strategies. We have considered your request and have added this measure to the Final Mast er List which is being submitted to TCEQ.

Throughout the latter part of 2008, H-GAC will work to qua ntify and refine this Master List into a Short List of measures which the Houston-region will recommend to TCEQ for implementation in early 2009 as part of the SIP. Please note that though this measure has been added to the Master List, there is no guarantee that it will remain as part of the Short List. You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx

Additionally, we encourage you to become more involved with the SIP process. We are actively recruiting regional businesses that are w illing to make their own commitments to reduce air pollution within th e Houston-region through voluntary commitments. I am happy to provide more information about the form and scope of these commitments by phone (713-499-6695) or email ( Shelley.Whitworth@h-gac.com ).

Sincerely,

Shelley Whitworth Air Quality Program ManagerG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-12 B.1.3.1 Comment from Port of Houston Authority

August 12, 2008 VIA EMAIL Houston-Galveston Area Council 3555 Timmons Lane, Suite 120 Houston, Texas 77027

Attn: Shelley Whitworth, sh elley.whitworth@h-gac.com

RE: Port of Houston Authority Comments on H-GAC Master List of Non-Road Control Strategies for 8-Hour Ozone Plan

Dear Shelley:

The Port of Houston Authority (Port Authority) appreciates the opportunity to provide comments to H-GAC on the Master List of Potential Non- Road Emission Control Strategies for the 8-hour Ozone Plan. The Port Authority understands the magnitude and importance of emission reductions from all sectors to ensure air quality improvement s for our community, region and state. The Port Authority was an active participan t in assessing and assisti ng with the creation of the 1-hour SIP and is dedicated to working with H-GAC and TCEQ on the development of the 8- hour SIP.

General Overall Comments The Port Authority wants to emphasize that considerable time and resources are necessary to perform technical, feasibility and cost analysis, as well as engage appropriate stakeholders in meetings and perform studies to ensure that m easures adopted are accurate and well suited for the region’s needs. Given that the timeframe for H-GAC is compressed and will require many meetings with appropriate stakeholders, the Port Authority wants to emphasize that it is more important to ensure control measures are well thought out and understood prior to selection. The Port Authority encourages emission reductions th rough voluntary measures and continues to be supportive of the TERP program.

Specific Listed Control Measures Below are some specific comments on control meas ures identified by H-GAC in the short list. These comments are based on what the Port Aut hority gleaned from the description provided in the spreadsheet and thro ugh a limited amount of research conduc ted to further investigate these measures. The Port Authority supports many of the control measures H-GAC identified, especially as voluntary measures that would be eligible for TE RP funding; however, some could have significant operational, te chnical, or legal impediments for successful implementation.

Listed below is a brief summary of the Port Authority’s comments or concerns.

#28/5 - Enhanced Texas Emission Reduction Program (TERP) The Port Authority is highly supportive of an enhanced TERP program. The Port Authority has participated in several TERP pr ojects and will continue to partic ipate in such projects in the future. The Port Authority believ es this program is the most su ccessful method at finding costeffective emission reductions for non-attainme nt regions. The Maritime Industry has hadG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-13 excellent participation in the grant program and continues to apply for and receive grants. The Port Authority would encourage further developm ent of this program to create a more userfriendly application and reporting process for all interested part ies. The Port Authority would encourage further enhancements of the TERP program to address the limitation of this program’s success. Those enhancements need to take into account statutory limits on emission thresholds for technology, the EPA technology certification process, and lim itations in the manufacturing industry and funding process of the program.

#31 – Accelerated Equipment Turnover; Ti er 2 or Tier 3 Non-road Engines The Port Authority has been accelerating equipm ent turnover through its own initiatives through the purchase of Tier II equipment at the Bar bours Cut and Bayport Container Terminals. The Port Authority supports the acce lerated purchase measure as a voluntary program , which would be eligible for TERP. If this measure is adopted as a mandatory program, the measure could face numerous legal and practical hurdles. The cost of completely replacing older equipment could be significant to some port users and could impact competitiveness if this measure is only adopted in the Houston region. The Clean Air Act expressl y prohibits state or lo cal rules that impose emissions control standards on new non-road en gines. The Act implicitly extends this preemption to all other non-road engines (new and old), and provides th at only California may apply to EPA for authorization to adopt and enfor ce standards or controls (at least as protective as federal standards) governing such engine s or equipment. A state with an approved nonattainment plan may thereafter a dopt standards identical to California’s, after notice to EPA and a statutorily required two-y ear lead-time before the standards take effect.

The accelerated purchase rule has already been held to violate the federal preemption clause. The TCEQ adopted the same control measure for th e 1-hour SIP. The rule was challenged by the Engine Manufacturer’s Associati on in the U.S. District Court fo r the Western District of Texas ( Engine Manufacturers Association v. Robe rt J. Huston,190 F. Supp. 2d 922(W.D. Tex. 2001) ). The court struck down the accelerated purchase requirements (and the morning hour construction ban), holding that the CAA depriv es the state of jurisdiction over such matters. At the same time, the rules were replaced legislatively with TER P. The case was voluntarily dismissed. If the accelerated purchase rule were adopted again, the rule would likely be challenged in the same court. One of the original plaintiffs could also file a Rule 60(b)(6) motion in District Court for reconsideration of the dismissal—premised on TCEQ ’s return to the prohibited conduct that it voluntarily dismissed.

In a later and significantl y relevant court decision, the U.S. Supreme Court overturned local air rules that would have required ce rtain private fleet operators in the greater Los Angeles area to purchase or lease low-emitting or alternative-fu el vehicles when adding or replacing fleet vehicles ( Engine Manufacturers Association v. Sout h Coast Air Quality Management District (SCAQMD), 541 U.S. 246 (2004) ). The primary distinction in this case is that the fleet rules applied to newly acquired, on-road vehicles (t here was not a requirement to accelerate the retirement and replacement of older, more po lluting vehicles). The S upreme Court concluded that the rules were emissions standards and pr eempted under the Clean Air Act. The Court was not willing to draw a distincti on between regulations that comp el manufacturers to meet new emissions limits (e.g., mandate the sale or producti on of certain types of ve hicles or engines) and those that affect only the purchase of vehicles. Indeed, the Court held that a “standard” under CAA Section 209 is any mandate governing the emi ssions characteristics of an automobile.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-14 Engine and Fuel Technology Control Measures #45/11 – Water Injection for Diesel Engines #46/12 – Alternative-Fueled Equipment for All Equipment Types #47/13 – Alternative Fuel Heavy-Duty Equipment #48/14 – Lean NOx Catalyst #49/15 – Early Introduction of Low-NOx Engines #50/16 – Selective Catalytic Reduction (SCR) #55 – Reformulated Fuels for Off-road Vehicles

The Port Authority is supportive of engine and fuel technology control measures as a voluntary

program . Many of the measures liste d above would be eligible for TERP grants once the technology has been verified or certified by CARB or EPA, respectively. Further research and information is necessary to fully assess the ex tent of each of these proposed measures on port operations.

The Port Authority uses alternative fuel in much of its small engine equipment; however, alternative fuel vehicles are not available for larger engine si zes. Below is a California Air Resources Board (CARB) list of CARB certified alternative fueled off-road engines.

Since alternative fueled engines ar e not available in larg er engine sizes, the use of such engines is restricted to equipment such as forklifts a nd yard hustlers. Although alternative fueled engines for yard hustlers are available, the Port Aut hority understands that th e technology does not make practical sense for this application. Using an alternative fueled yard hustler requires more frequent refueling, adds signi ficant cost for the equipment and fuel, requires additional infrastructure, increases maintenance costs, and does not provide a significant emissions benefit compared to the emission reductions from ne w cleaner diesel equipment. According to a California Air Resources Board report, the cost of using LNG is 20% higher than diesel, the equipment costs approximately $40,000 more per un it, the extra maintena nce cost is about $2,000 to $4,300 more, and a new LNG terminal dispensing about 16,000 gallons costs approximately $700,000. CARB provided the following conclusion in its assessment of an alternative fuel requirement: “The possible higher co st of the alternative fu el and alternative fuel infrastructure, along with cleaner diesel engines which are near to the emissions of alternative fuel engines, favors selection of alternative fuels on a case-by- case basis instead of a general mandate.” See http://www.arb.ca.gov/regact/cargo2005/appf.pdf



### .
In addition to alternative fueled equipment, the Port Authority has conducted a demonstrative study on selective cataly tic reduction (SCR) technology. The Port Authority would like to express its concern over this contro l strategy due to the following:

• There is currently no EPA verified SCR technology for large size engines and the technology has only been verified on one smaller engineG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-15 • Port Authority’s demonstration project with an SCR on a 535 horsepower rubber tire gantry (RTG) was terminated due to nonperformance of the SCR and exceptional costs of installation a nd operation;

• A significant legal impediment exists regard ing the adoption of a NOx reduction systems; and

• The compatibility of NOx reduction systems with other control strategi es such as diesel emulsions, fuel additives, etc. has not been evaluated.

It is the Port Authority’s unders tanding that only one SCR has b een verified to date —and that verification only applies to one engine size. The SCR is ma nufactured by Extengine. It is unlikely that EPA would accept a control measure with a technology that has not been verified by EPA or CARB.

In addition to the lack of verifi cation, the Port Authority has si gnificant reservations about the viability of SCR on equipment operating with tran sient loads. The Port Authority’s experience with an SCR was burdened with si gnificant operational pr oblems. On the piece of equipment that was tested, an RTG crane, the SCR did not inject urea during any idling of the engine or when the engine temperature changed during the lo ading cycle. Since the SCR is temperature dependant, an emission reduction was difficult to determine during the in-situ testing program. Other factors that contributed to the SCR technology being deemed infeasible were the costs of installation, stainless steel piping, re placement of injectors, and urea.

In addition to technical problems, HGAC and TC EQ are likely to experience a legal impediment in mandating the use of NOx reduction systems. Section 209(e) of the Federal Clean Air Act preempts states (except California) from adopti ng engine standards for offroad vehicles as discussed above. See EMA v. SCAQMD, 541 U.S. 246 (2004); Engine Manufacturers Association v. E.P.A ., 88 F.3d 1075 (D.C. Cir. 1996); Engine Manufacturers v. Huston , 190 F.Supp.2d 922 (W.D. Tex. 2001). Based on the case law on th is issue, it is apparent that a control measure requiring an equipment ope rator to achieve a certain emi ssions level by using an SCR or other type of emission contro l device is likely preempted.

Construction Contract Control Measures #35 – Conditions of Approval for New Construction #37 – Control Clauses for Construction Contracts #38 - Contract Bidding #39/8 - Government Construction Incentives #41/9 – Develop Air Quality Be st Management Practices

The Port Authority already incl udes extensive environmental condi tions in its new construction contracts. The Port Authority has spent millions of dollars to minimize air quality construction impacts. Some of the best management practi ces have included clean engine technologies, cleaner fuels/additives, extensive dust suppres sion requirements, innovative construction techniques, monitoring, reco rdkeeping, reporting, and fueling requirements.

In addition to using contractual requirements, the Port Authority assesses air quality impacts from contractors through the use of a NOx Calc ulator on the Port Authority’s federal permitted projects. Contractors assess air quality impact s and provide proposed mitigation measures on projects via the NOx calculator. The Port Authority proc ures contracts through competitive sealed proposals and air mitigation efforts are part of that process.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-16 The Port Authority believes its own procurement program is successful in providing an incentive to reduce emissions from construction project activities. For this reason, the Port Authority would request the flexibility to retain its own program, instea d of simply adopting the TxDOT

program.

#42/10 – Limitations on Idling of He avy-Duty Construction Equipment The Port Authority supports and actively partic ipates in an idling limitation in its large construction contracts, as we ll as its own voluntary idling pr ogram. Tenants and users are informed of the need to reduce idling through sign s, tenant audits, and stakeholder meetings. The Port Authority is currently evaluating the development of its’ own idling policy which will include internal enforcement mechanisms.

The Port Authority supports voluntary idling re duction efforts and woul d potentially support a mandatory rule enforced by TCEQ or another re gulatory agency—so long as the scope would not unduly restrict operations. Further information and assessment is necessary on this measure to provide more meaningful comments.

Control Measures adopted from California Rules

#87/35 – ARB Portable Engine Registration and Rulemaking The California Air Resources Board’s (CARB) Portable Engine Registration program is a voluntary program. The Port Authority generally supports voluntary programs , however, the Port Authority is unsure of the environmental be nefit of such a program compared to the cost. The Port Authority is also unsure of the willingne ss of companies to partic ipate. Essentially the CARB Portable Engine Program operates like a permit—requiring portable engine owners to comply with certain emissions specifications, reporting, recordkeeping, and other requirements. Complying with these requirements allows the portab le engine owner to operate in all of the air quality districts in the State of California without being subjected to individual air quality district rules.

It is unlikely that a significant number of portabl e engine owners in Texas will voluntarily enter into this program considering the significant ad ministrative requirements. Even if a significant number entered into the program, it does not appear that the State of Texas has the resources to administer such a paper intensive permitting requirement for small sources. The CARB program, for example, requires owners to notify the agency every time the equipment is being moved to a new area. Currently TCEQ allows portable engine s to operate under a permit-by-rule if certain criteria are met. The permit-by-ru le ensures that portable engine owners comply with air quality standards without subjecting the owners (and the agency) to u nduly burdensome administrative exercises that do not provide si gnificant environmental gains (since the sources are generally small). As with other sources that have small emissions and can move from place-to-place, the most efficient and effective means to reduce emissions is generally through better emission standards at the ma nufacturer level.

In addition, the legal use of such a rule is subject to the Clean Air Act Section 209 (e) preempting Texas from adopting mandatory portabl e engine controls for non-road sources and preempts user-based standards. This control strategy would need to be adopted “as is” from California’s voluntary program.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-17 #88/36 – California Auxiliary Engine Rule The Port Authority is aware that California is currently considering a rule requiring ocean going vessels to use cleaner fuel in auxiliary engines (or an equivalent method of control). While the Port Authority is supportive of the voluntary us e of cleaner fuels across all sectors, the Port Authority has potential concerns about the viabil ity of the rule as a mandatory and voluntary measure—especially if the rule is intended to meet Houston’s SIP deadline. The Port Authority believes there has not been enough due diligen ce nor will there be enough time to conduct the proper due diligence over the next several months to adequately study the environmental and safety effects this measure may have on the co mmercial marine sector. Two California Ports (Los Angeles and Long Beach) are currently implementing a pilot program to cover the incremental cost for vessels to vo luntarily switch to cleaner fuels while in or near ports. This program is still in pilot demonstration phase and will cost each port millions of dollars. The Port Authority will continue to monitor this pr ogram for feasibility and transferability.

Below are some of the Port Au thority’s specific concerns.

This control measure is being considered in Ca lifornia largely as a particulate matter and SO2 control, not a NOx control. Unlike Texas, portion s of California are non-attainment for the fine particulate matter standard. The projected partic ulate matter reductions fro m this rule are 75%, but only 6% for NOx. Although particulate matte r reductions are important to Houston, HGAC’s and TCEQ’s efforts are focused on ozone (NOx and VOC). There is also a question of the availability of fuel, logistic matters and ta nkage restrictions for the vessels. For this reason, the auxiliary engine rule is considerably less helpful, viab le, and cost-effective for the Houston 8-hour Ozone SIP.

Statistics show that few ships frequently call on the Port of H ouston. According to the Houston Port Bureau, only 17% of ships calling on the Port of Houston in 2000 called more than 5 times. 1



### Requiring a ship that only visits a few times a year to utilize a certain fuel may not be the most efficient means of control. Although the CARB ru le would allow alterna tive means of control, the question becomes whether the rule for infrequent visitors is essentially a de facto rule to comport with some other control mechanism or fee structure. The resu lting program may have significant practical and legal implications.

As discussed above, no studies have been perfor med or stakeholders engaged to assess the viability and effectiveness of this strategy in Texas. CARB has yet to complete its own ruleG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-18 development which started several years ago. CARB has spent considerable time and resources developing the rule. CARB’s assessment includes t housands of pages describing fuel availability estimates, cost information, technical consider ations, legal evaluations, public comment, business comments, etc. It is doubtful that H-GAC, TCEQ, and stakeh olders could review necessary considerations unde r the current timeframe.

Moreover, it should be noted that the California Auxiliary Rule has yet to become final. An additional comment period will soon begin and the rule is not expected to be delivered to the Office of Administrative Law until September of this year.

Questions regarding CARB Control Measure Many of the concerns identified by CARB should be evaluated in Texas. For example, CARB estimated that only about 10% of all vessels would require retrofits to use cleaner fuel. Has HGAC or TCEQ considered or investigated this statistic? CARB also estimated the average cost per business at $20,000 per year for non-diesel el ectric vessels and $2,000,000 for diesel-electric vessels (cruise ships and some tankers). Is this cost estimate accurate for Texas? Many older vessels operate auxiliary engines on steam, there is no other fuel option for this vessel. These vessels are not that common in California, where the average vessel is 1-5 years old. The average vessel at the Port of Houston is second or thir d generation, which is about 15 or more years old. CARB mentioned in its report that operators who choose to replace all residual fuel used in their auxiliary engines with marine di stillate may experience scheduling conflicts and logistics issues when loading large amounts from local suppliers. Will this occur in Texas? There are numerous unanswered questions that require before this control measure is selected for rule adoption in Texas.

In addition, the Auxiliary Engine Rule is likel y to face legal challenges since the rule would regulate foreign flagged ships extending 24 nautical miles from the coastline. Below is a list of some potential legal considerations:

• International treaties - Most ships calli ng on the Port of Houston are foreign flagged (only about 9% visi ting the Port of Houston in 1997 were U.S. flagged). 2



### • U.S. Constitution (the Supremacy Clause, Foreign Affairs Clause, etc.)

• Federal statutory provisions – Examples:

o Section 209(e) of the Clean Air Act (p reempting states from adopting state or local engine standards)

o Section 110(a)(5) of the Cl ean Air Act (restricting indirect source review programs)

• Case law

o U.S. v. Lo cke, U.S. Supreme Ct. (2000) – The U.S. Supreme Court held that certain maritime safety regulations adopted by the State of Washington were preempted by the comprehensive federal regulatory scheme governing oil tankers. The Cour t upheld petitioner’s argument that Washington’s standards invaded ar eas long occupied by the Federal government and interrupted an area where national uniformity was required.

o Bluewater Network v. EPA , D.C. Cir. (2004) – The D.C. Circuit held that an environmental group challenge to EPA’s decision to regulate emissions from engines on foreign-flagged vessel s was premature. In its rule, EPA stated that, “We [EPA] do not need to decide now whether we have the discretion to include fore ign vessels under the non-ro ad provisions of theG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-19 Clean Air Act. In the subsequent rulemaking [in 2007], we will be in a better position to resolve under what circumstances we may and should define new nonroad engine and vessel to include foreign engines and vessels.”

o Gibbons v. Ogden , U.S. Supreme Ct. (1824) – In a seminal Supremacy Clause case, the U.S. Supreme Court held that where Congress acted, state vessel requirements were preempted. The Court stated, “In every such case, the act of Congress or treaty is supreme; and the law of the State, though enacted in the exercise of power s not controverted, must yield to it.”

o Engine Manufacturers Assoc. v. SCAQMD , U.S. Supreme Ct. (2004) – In this case the Supreme Court overturned local air rules that required certain private fleet operators in Los Ange les to purchase low-emitting vehicles. The Supreme Court held that a “s tandard” under the Clean Air Act’s preemption language in Section 209 is any mandate governing the emissions characteristics of an au tomobile. Based on this precedent and related case law, the Supreme Court would likely hold that a state or local marine emissions cap is invalid si nce the requirement would govern the emissions characteristics of a ship (a preempted category of engines under Section 209(e)).

o Scurry v. Texas Air Control Board (Tex. Civ. App. 1981) – The Texas Court of Appeals in Austin held that marine vessels were not subject to permitting requirements under the Texas Clean Air Act. The Court stated that the “Texas Clean Air Act makes no clear or implied reference to indirect sources. Section 1.03 defines a 'new source' as a 'stationary source,' Section 1.03(8), and a 'source' as a 'point of origin of air contaminants,' Section 1.03(2). While th ese terms are not used in Section 3.27, which establishes the permit require ments, their definitions indicate that the Legislature intended to re gulate only direct sources. Had the Legislature intended to give the Board authority to require permits for so broad a category as indirect sources , it would have done so [with] more explicit language and with more guidance."

o Engine Mfrs Ass'n v. Robert J. Huston , (W.D.Tex. 2001) – Although the opinion was later vacated based on moot ness, the Federal District Court held that a state regulation banning the use of construction equipment during the morning hours and a regula tion requiring the purchase of new equipment were “engine standards” and therefore preempted by Section 209(e) of the Federa l Clean Air Act.

In addition, the Port Authority would be concerne d if this rule was adopt ed only in the Houston region. If it became cheaper or le ss prohibitive for vessels to use other ports in the Gulf Coast (which might be facing their own air quality issues), th at cargo could be displaced to neighboring ports. The displaced cargo will then li kely travel to Houston by truck.

In conclusion, the Port Authority has been extremely involved in the passing of MARPOL Annex VI by the United States. These measures will put more aggressive engine and fuel standards into place for ocean going vessels on an international basis. The IMO has already determined even more stringent standards are needed once MARPOL Annex VI is ratified and the Port Authority will continue to provide reso urces and make efforts to ensure these more stringent standards are approved. The Port Auth ority and the American Association of PortG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-20 Authorities are leading these efforts to ensure that ocean going vessels are addressed on an international level, rather than local efforts to ensure world-wide compliance and economic competitiveness.

1 Information obtained by Nicole Cass of the Port of Houston Authority from the Houston Port Bureau. 2 TCEQ December 2000 HGA SIP.



### #89/37 – California Cargo Handling Equipment Rule The Port Authority is engaged in numerous efforts to reduce emissi ons from cargo handling equipment. Approximately 18% of the cargo handling equipment is owned and operated by the Port of Houston. The remainder is owned and ope rated by tenants and users. The Port Authority has spent many years testing and evaluating new emission control strategies and purchasing new cleaner equipment for its own engines. The Port Au thority has also encouraged its tenants to use cleaner engine technologies through TERP application assist ance, education programs, and tenant meetings. The Port Authority already ha s a fleet turnover program for its’ equipment and that of tenants that heavily reli es on TERP funding availability.

While the Port Authority supports voluntary me asures to reduce emissions from cargo handling equipment such as TERP, the Port Authority ha s potential concerns about the viability of a mandatory measure—especially if the rule is in tended to meet Houston’s SIP deadline. As with the CARB Auxiliary Engine rule, the Port Authority believes there has not been enough due diligence, nor will there be enough time to c onduct the proper due diligence over the several months.

Below are some of the Port Authority’s concerns.

This control measure could not be implemented within the required SIP time frame (even if it were otherwise appropriate and lega l). The State of California has ye t to adopt the rule into law. Based on the Port Authority’s conversations with CARB, the rule is still subject to change and will not be submitted to the Office of Administ rative Law until September 2006. Until the State of California adopts the rule, rece ives a waiver under Section 209 of the Clean Air Act, and the required time period has passed, the State of Texas cannot adopt the rule. Based on this time frame and the Houston SIP time frame, this rule does not appear to be currently viable.

The Port Authority has concerns regarding the fact that no feasibility analyses, cost analyses, or other assessments have been conducted for this region. CARB prepared numerous reports and engaged stakeholders over a significant period of time. Six public workshops were held, four public working group meetings were held, a dditional outreach mee tings occurred, a cargo handling equipment survey was conducted, site visits happened. Base d on H-GAC’s current schedule, the off-road short list is scheduled for one generalized stakeholder meeting. The Port Authority believes that signifi cant resources and time are needed for H-GAC and TCEQ to perform due diligence before this measure is further pursued.

The Port Authority is concerned with technical and practical consider ations. The rule would essentially require cargo handling equipment to be re-powered or replaced with 2007 on-road engines, Tier 4 off-road engines (when they beco me available), or retrofitted with a verified control that meets the same level of reductions . Numerous questions need to be addressed including cost, feasibility, availa bility of new engines (especiall y since Tier 4 engines are not applicable until 2011), availability of verified NOx control strategies since very few presently exist, the amount of emission reductions expected in the required timeframe , the possibility thatG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-21 this rule would result in relocation of older equipment to other ports. Significant due diligence is necessary to ensure proper cons ideration of all environmental, social, and business factors.

In addition, the Port Authority would be concerned if this rule were adopted only for the Houston region. Port equipment can move from port-to-port and a competitiveness i ssue could arise if one port was subject to the requirement while anot her port was not. If it b ecame less costly for a shipper to send goods to another po rt, those goods could be redirect ed to another port that also may be facing air quality issues. The goods then might travel back to Houston via truck.

#45 – Development of Port of Ho uston Clean Air Action Plan The Port Authority will provide comments to this potential measure in a separate document.

We hope you found the above comments helpful in your analysis. The Port Authority appreciates the opportunity to provide these in itial comments on the short list of non-road control strategies. The Port Authority will c ontinue to evaluate and investigate th ese measures, as well as, others to develop practical and feasible solutions in reduc ing air emissions in the region. We look forward to working with you further to find the best path forward for voluntary measures towards achieving cleaner air. Please let us know if we can be of further assistance.

Sincerely,

Aston Hinds, PhD Environmental Affairs ManagerG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-22 B.1.3.2 Response to Port of Houston Authority

August 27, 2008

Mr. Aston Hinds Port of Houston Authority P.O. Box 2562 Houston, Texas 77252-2562

Dear Mr. Hinds:

Thank you for your comments regarding the mobile source control meas ures for the HoustonGalveston-Brazoria 8-Hour Ozone State Implementa tion Plan (SIP). We have considered your comments and would like to take a moment to respond to your comments directly.

Your letter expressed comments on the following control measures:

• Non-road Measure 28/5 – Enhanced Texa s Emission Reduction Program (TERP): The TERP program is operated under the juri sdiction of the Texas Commission on Environmental Quality (TCEQ). Because of th is, TCEQ will offer a separate response to address this comment.

• Non-road Measure 31 – Accele rated Equipment Turnover; Tier 2 or Tier 3 Non-road Engines: H-GAC thanks you for continuing to part icipate in programs such as TERP to obtain accelerated emissions reductions. We appreciate your comments regarding the mandatory implementation of accelerated vehicle turnover. H-GAC will use this information to create a refined version of th is list in the latter part of this year.

• Non-road Measures – 45/11 (Water Injection for Diesel Engines), 46/12 (AlternativeFueled Equipment for All Equipment Type s), 47/13 (Alternative Fuel Heavy-Duty Equipment), 48/14 (Lean NOx Catalyst), 49/15 (Early Introduction of Low-NOx Engines), 50/16 (Selective Catalytic Reductio n (SCR)), and 55 (Reformulated Fuels for Off-road Vehicles): We appreciate your comments re garding the implementation of alternative engine and fuel technologies in port operations. H-GAC will use this information to create a refined version of th is list in the latter part of this year.

• Non-road Measures – 35 (Conditions of Appr oval for New Construction), 37 (Control Clauses for Construction Contracts), 38 (Contract Bidding), 39/8 (Government Construction Incentives), 41/9 (Develop Ai r Quality Best Management Practices): HGAC thanks you for voluntarily working to im prove air quality through best management practices. We will use this information to create a refined version of this list in the latter part of this year.

• Non-road Measure 42/10 – Limitations on Idling of Heavy-Duty Construction Equipment: H-GAC thanks you for creating a vo luntary idling reduction program.

• Non-road Measure 87/35 – ARB Portable Engine Registration and Rulemaking: H-GAC appreciates your comments will use this informa tion to create a refine d version of this list in the latter part of this year.

• Non-road Measure 88/36 – Califo rnia Auxiliary Engine Rule: H-GAC thanks you for your continuing work to reduce emissions from ocean going vessels that are entering andG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-23 leaving the port. We appreciate your comments a nd will use them to as we work to create a refined version of this list in the latter part of this year.

• Non-road Measure 89/37 – California Cargo Handling Equipment Rule: H-GAC thanks you for your continuing work to reduce emi ssions from cargo handling equipment. We appreciate your comments and will use them to as we work to create a refined version of this list in the latter part of this year.

Throughout the latter part of 2008, H-GAC will work to quantify and re fine this Master List into a Short List of measures which the Ho uston-region will recommend to TCEQ for implementation in early 2009 as part of the SIP. You can follow the pr ogress and see a more detailed summary of the SIP process, the timeta ble for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.hgac.com/taq/airquality/sip/default.aspx

Additionally, we encourage you to become more i nvolved with the SIP process. We are actively recruiting regional businesses that are willing to make their own commitments to reduce air pollution within the Houston-region through vol untary commitments. I am happy to provide more information about the form and scope of these commitments by phone (713-499-6695) or email ( Shelley.Whitworth@h-gac.com ).

Sincerely,

Shelley Whitworth Air Quality Program ManagerG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-24 B.1.4.1 Comment from Sierra Club 

# SIERRA

CLUB

FOUNDED 1 892



### June 1 0, 2008

Mr. Alan Clark Transportation Department A i r Quality Sect i on Houston

- Galveston Area Council P

. O

. Box 22777 Houston

, Texas 77227

Dear A l an , 

## Houston R egional Group P. 0. B ox 3021 

### Houston, Texas 77253-3021 713-895-9309 http://tcxas.sierraclub.org/housto n /



# RfC'O ,JU N 

# 1 6 2008

E ndosed are the comments of the Houston Regional Group and Lone Star Chapter of the Sierr a Club (Sierra Club) regarding our initial inpu t for the OnRoad/Non-Road Mobile Source Control Strategies Cata l ogs (Control Measures ) for the Houston-Galveston

- Brazoria ( HGB ) Eight

- Hour Ozone St a te Implementat ion Plan (SIP).

The Sierra Club is disappointed that HGAC has once aga in not fully exp l a in ed what each control measure (C M ) i s

. There are some CMs with explanations but



### even these are i ncomp le te and cryptic at best. If HGAC wants the public to truly participate then it needs to take the time to fully explain what each CM is

, possible emiss i on reductions f rom each CM

, approximate cost of each CM

, and availability of each CM based on techno l ogical feasibility and statutory and regulatory requi reme nts

.

Without this k ind of specif ic information the public is just guessing as to what CMs would be best and that i t supports

. II has been two years since HGAC went through this process

. II is sad to see that the process appears to be no different than the one that failed two 

### years ago

. If the public is going to tru l y participate it must be educated about the options

. Thes e two catalogs inadequate ly educate the pub li c so that i t can review, comment on

. understand the proposal and prov i de reasonable feedback

.

S I P Planning Pro cess

T h e S ier r a Club has been very disappo int ed with t h e SIP p l ann i ng process over the p as t few years

. The SI P planning process has remov ed from consideration CMs that we r e v iab le and s h o u l d have been analyzed

. W e fee l th e S I P planning process was n ot operat ed with a good fa i t h effort. At a min i mum the SIP p l ann in g p r ocess s h ould adhere t o th e following princip l es :G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-25G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-26G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-27G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-28G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-29G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-30 1

. L ocate haz a rdous freeway areas for poss i ble im p r ovements

, sharp t u ms , dover leafs

, etc

.

4 ) T he S i e r ra C lub re comm e n ds t ha t the follo win g Fr ee w ay S y stem Inf ra s tru c t u r e C M s be st u d i ed i n a d et a iled qualitative and quantitative

a ssessment

, an a lys i s , and ev a lu a tion and rul e effediveness a n a lysis

.

1. Limit road a nd highway im p rovemen t s to those be n efit in g trans i t a n d h i gh

occ u pancy ve h icl e lanes

.

2

. Shi ft high w ay fun d s t o tra n sit.

3. N o new peripher a l highways or loops

. 5) T he Sie r ra Club recom m e n d s t hat th e foll ow i n g F u el S tand a rd s C Ms b e stud i ed in a de ta il ed quali t a tiv e and quan ti t a t i ve assessmen t

, analysis

, and

e

va lu at i on and rul e effectivene s s a nalysis

.

1

. Federal ultra lower sulfur diesel.

2. C a liforn i a d i esel f u el

.

3

. R e formula t e d fu e l s f or off-road veh ic les

6 ) 

### The Sierra Club recommends th a t the following Gen e ral Pu blic Educa t io n and Ou tr eac h C Ms be stud i ed in a detail ed q uali t a t ive and qua n ti t at ive

ass es sment

, anal ysis

. a n d eva l uat i on an d ru l e e ff ectiv eness an a l ysi s.

1

. Educate pub li c about fue l sav i ngs from property inflated tires

, regular tune-ups

, and driving speed.

2

. Celebrity voluntee r s f or ozo n e a l e rt announcem en t s

.

3 . A i r qua li ty In f or ma ti o n with drive r tr a i n ing

.

4

. Air quality public outreach

.
7) Th e Sierra Club recommends that the f ollo wing Go od s M o vement C M s be

s t udie d in a d e t ail ed qu a l itative and q ua nti t a tiv e a ssessmen t

, an a l ysis

, an d

e v alu at i o n and rule e ffec t iveness analysis

.

1

. Designated truck routes

.

2

. Dedicate truc k lanes.

3

. Re qu ir e s h o rt -haul truck s t o use a l te rnat i ve fuels

.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-31G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-32 10. Enf orce smoking veh ic l e r eports and require repairs.

11

. New ve hicf e discounts for old vehicle tr ad e-ins

.

12

. Low-int ere st f in an cing for l ow i n come and or o l d v e hicle tr a de

- ins

.

13

. Transit passes/c red it in exchange for 

### old vehicle scrappage

.

14

. Ban sale o f high-emi tt ing vehic l es

.

15

. De ny r egis tration t o v ehicles with repeated emission fa i l ures

.

16. Increase parking at transit centers or stops

.

17

. Prov i de parking at all majo r trans it s t atio ns

.

1 0) The S i e rr a C l ub r ecommen ds that the fo ll owing Part<ing Mana gement C M s be studied in a detailed qualitativ e a nd quantitative assessment

. ana lysis, and evalu a tion and l rule effectiveness analys is

.

1

. Preferen ti a l parking f or HOV lanes u sers and ride s h a r ers; r a te r e d uction.

11) T he Sierra Club r ecommends th at the following P r ici ng M easures CM:S b e stud i ed in a detailed qualitative and quantit a tive assessm en t

, analys is

, and evalu a tion and l rule effectiveness ana lys i s

.

1

. We are ag a in s t cheaper gasoline pr ic es durin g even ing hours

.

2

. We oppose encouraging having muhiple cars

.

3

. Stat e an d l ocal exem pti ons fo r pooling/tran si t subs i d i es

.

4

. N o to lls fo r buses and van poo l s.

12) The Sierra Club recommends that the following Speed C Ms be studie d i n a detailed qualitative and quantitative ass ess ment, ana l y sis

, an d eva l uat i o n an d

r ule e ffec t i ven ess ana l ys i s

.

1

. Aggressive driving enforcement.

2

. The S i erra Club supports leaving the s peed limits as they are but im p l eme nt i ng aggressiv e enf orcemen t to br in g down a v erage speeds. There a re far too many d ri v e r s who driv e at 10 -20 m ilesfh ou r over th e pos ted speed lim it.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-33 13) The S i er r a C l u b recommends that the following Sustainable and Transit

Oriented D eve lopm ent CMs be studied in a deta iled qualitative and quantitat ive
assessment

. analys is

, and eva lu at ion and rule effect i veness ana l ys is

.

1

. Manage location of new growth to l imit add i tional spra w l.



### 2

. I ncentives for infi ll and r edevelopment. However

. this needs to be implemented so that those who presently live in the area are not forced to leave due to higher taxes

. Don ' t make this CM benefit the well off and hurt those who

are not.

3. M i xe d use deve l opm en t or d inance and zones

.

4

. Encourage or require complementary uses i n close prox imit y in all developments or deve lopment areas.

14) The Sierra Club recommends that the fo l low i ng Traffic Flow Improv e ments CMs b e studied in a detai l ed qualitative an d quantitative assessment

, ana lysis, and eva l uation and rule effectiveness analys i s

.

1. We are against freeway bottleneck improvements that add l anes ins tead of focus on transit.

2

. P roh ibit truck use of right lanes for load i ng on bus and bike routes

.

3

. Pedestrian mall route diversion

.
15) HGAC needs an entire program dea l ing wi th traffic management and a su i te of a l ternatives that will be imp lemented to resolv e the problem

. 

### The Sierra Club recommends that the following Traffic Flow Im prov ements CMs be studied in a detailed qual ita tive and quantitative assessment

, analysis. and eva luation a nd

ru l e effectiveness ana l ys i s

.

1

. Require two or mo r e occupants per veh ic les to enter designated con gested activity centers during am a nd pm peak traffic periods

.

2

. Requ ir e two or more occupan ts pe r vehicle to enter des igna ted congeste d activity cente rs all day

.

3

. Subsi d ize trans i t service

.

4

. More trans it access near universitie s and airports

.

5

. Acce l era t e r ail exp ansion.

6

. Light Rail.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-34 7

. Commuter Ra il.

8

. High- s peed ra il.

9

. We support t h e spe cific

, localized, allowance of j itn eys. This is not menti o ned

as an alternative.

1 0

. We support putting M etro and other public buses on p ropane or oth.er lower polluting f u els

. 16) HG AC needs an en tire program dealing with traffic management a nd a suite of alternatives th.at will be 

### impl emented to resolve the problem

. The Sierra Club recommends that the following Trans i t C M s be studied in a de t ailed qualitative and quantitative assessment

, analysis

, and evaluation and rule effectiveness analysis.

1

. Subsidize t r ansit service

.

2

. I mplement seaml ess public t r ans i t

, connectivi ty

. 17) HGAC needs an ent ire program dealing with traffic man a gement and a suite of altern a tives th.at will be 

### implemented t o resolve the problem

. The Sierra Club recommends that t he following Tra vel Demand Ma nagement

- Bus iness O p e r ations C M s be s t udied in a deta i led q uali tat i ve and quantita ti v e assessment. analysis, and evaluatio n and ru l e effe c tiv e n ess anal ysis.

1

. We support a mandatory employer trip reduction program for all employers wh o em ploy 20 or mor e p eo pl e

. Thi s is not men t i o ned as an al terna t i ve

.

1 8 ) The Sierra C lub recommends that the f ollowin g Travel !Demand Ma nagement

- Schools and Co ll eges C M s be 

### studied in a deta i led qualitat i ve and quantitative assessment

, analysis

, and eval uation and rule e ffe ctiveness anal ys i s

.

1

. Restrict student drivers t o high schools

.

1 9) Th.e Sierra Clu b recommends that the 

### following Vehicle E ng i ne M odifications C M s be studied in a de t a iled qualitative and quant ita tive

as sessment

, ana l ysis, a nd eva l uation and rule effec tiv eness ana l ysis

.

1. Eng ine software upgrade ( DHV 4 ) or low 

### N O x software upgrade

. 20) The S ierra C lub recomm e n ds that t he fo llo win g Vehicle I dling CMs be stud i ed in a detail ed quali t at i ve and quantitative assessment

, analy sis

, and evaluation and rule effectiveness an a lysis

.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-35G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-36 2008 HGAC On

- Road Source Control Measures

The following a re the On

- R o ad Sour c e CMs fr o m the 2008 HGAC catalog t h a t the S ierra C l ub wan t s to be fu ll y qu a!ltitati v ely an d qu a li tat iv ely a n a lyz ed and
pre sen ted t o th e public an d decis ion

- ma k ers for review

, comment. and understanding of the SIP proposal.

1

. #5 4

, Privat e s ec t or clean fue l fleet s

.

2

. #56

, Close loophole sin the Texas Clean Fleet Program ma k in g f ewer exemptions for fleets

.

3

. #59, Public a gency c l ean fleet program

.

4

. #1 44

, Di v ert truc ks from non

- attai nme nt are a s. The Sierra Club recommends a new CM, Construct and des i gnate truck o nly lan es.

5

. 

### # 1 4 7

, Permit HOV lane use by qualifying low emission ve hi c l es (LEV)

. The Sierra Club does not support this CM becau s e it does not get people 

### to change the i r one p e rson/one car mod e of transportati on and w o rks aga i nst other form s of transporta ti on that carry more than one person.

6

. #15 7

, S i ng l e Occupan t V e hi c l es (SO V ) a ccess t o H OV an d t ra

. nsit s ta tions

. The S i erra Club doe s not support th i s CM becau s e i t does not get people 

### to change the i r one pers o n / one c ar mode o f transportation and works aga i nst other forrns o f transportation that carry more than one person.

7

. #161, Ma nag ed lanes to accommodate some single occupant veh icles i n HOV lanes

. Th e S i erra C l u b does not support this CM because it does not get people to c hange the i r one person/one car mode of transportation and works against other forms of transportation that carry more than one person.

8

. # 1 63, Focus on finding a nd p e n a lizin g extre m e hig h em itt ers.

9

. #165

, Rewards for reporting smoking or high em itting vehicles.

10

. # 1 72

, Scra ppag e/buy

- back pl a n

.

11

. # 181

, Dedicated fund in g for school bus repl a cement.

1 2

. #188, En f o r ce sm o k ing ve hic l e r eports and r e q ui re repairs

.

13

. #191

, Low i nterest financing for low i n come a nd or old veh i c l e tr a de

- ins.

1 4

. # 193

, Ban sa l e of h ig h em i tti ng vehic l es

.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-37G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-38 36

. #487

, Telecommuting in centives or mandates.

37

. #49 6, Reg i onal vanpool prog r ams.

38

. #551

, If the California Low Em itting Veh icle Program 

### is adopted and only LEV

ce rtifi ed, gasoline vehic l es ar e for sal e in Te x a s, then ma nda ted fleets sh oul d have t o purchase the ULEV alternative fue l version of the sam e v eh i c l e r ather than the gasoline version

.

39

. # 553, Adopt Ca li forn i a standards for veh icle em iss i on r ates

.

40

. #576

, Limitations on idl in g of hea\1)' duty vehicles

.

41

. #587

, Hea\1)' duty vehicle bo r der insp ection program fo r AB 1009

.

42

. #601

, Ext end o r e xp and li ght duty d i esel e ngin e i ns pecti on and main t enance program

.

4 3

. #632

, Enhanoed enforcement for smoking vehicles prog ra m

- vehicle impo un d in g f o r v iola t or s (like Da ll a s Emi ss io n s En fo rceme n t Pilot Progr am)

.

44

. #635

, Prime parking for vanpools

, carpools, hybrids. The Sierra Club

recommends that hybri ds be rem oved from this CM s ince they continue one person/one vehic l e Ira nsportation

.

45

. #638

, Incre a sed use of hybri d buses.

46

. #639

, I nitiate a flex -b i k e service to encourage bicy cling

.

4 7

. #642 . M ore stringent l iM cut poin ts

.

48

. #643

, Accelerate development and construction of mas s transit projects

.

2008 HG A C N on- Road Source Control Measur es

The following are the Non-R o ad Source C M a from the 2008 HGAC c atalog th a t the S ier ra Club wan ts t o be fully quant ita tively and qua l i t a t ive l y analy ze d a nd presente d to the public and decision-makers for review, comment

, and understanding of the SIP proposal.

1

. #1

, A i rc ra ft emission s ta ndards

.

2

. #2

, Orde r ing lowes t emission engines

.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-39 3. #9

, Develop air qual i ty best management practices (BMPs); use BMPs to manage emissions from construction sites

, construction vehides

, and wind-blown dust.

4

. #1 0, Limita t ions on idl ing of heavy duty construction equipment.

5

. #11, Water inj ection for diesel engines

.

6

. #14

, L ean NOx cata l yst.

7

. #15

, Early introduction of low NOx eng ines.

8

. #16

, Se lective catalytic re duction (SCR)

.

9

. #21

, Lawnmower exchange: trade in o l d gas powered equ ipm ent for discounts

on ze ro emission mod e l s.

10

. #22

, L awnmower recycling programs ( rebate program) : replace gas mowers with ele ctr i c.

11

. #23

, Promote use of c l eaner l awn and garden equipment such as lower

em i ssion four stroke and electric powered equipment.

12

. #24

, B uy a Clunker concept for sma ll gas

. equipment.

13. #26, Ban equipment such as two stroke eng i nes

.

14

. #30

, Use of aux ilia ry power uni t s (APUs) for lo como tive s ope rating ; con t rol s for locomotives are**r~mpted** 

### by federal 

### law

. bu1 voluntary control s m i ght have

some success

.

15

. #31

, Accelerated purchase of Tier II l ocomotive engines

.

16

. #32

, Ele ctrification of rail switching yards

.

17

. #34

, Limitation on idling of locomotives

.

18

. #36, Ca l i fornia Ma rine Vessel Auxi liary Engine Rule.

19

. #37

, California Cargo Handling Equipment Rule

.

20

. #38, Clean fue l opti on : expand TxLED use. The use of TxLED could occur in source categories not currently required 1o implement the fue l use inclu d ing marine and other engines

.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-40G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-41G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-42 B.1.4.2 Response to Sierra Club

August 27, 2008

Mr. Brad Mannchen Lone Star Chapter of the Sierra Club Houston Regional Group P.O. Box 3021 Houston, TX 77253-3021

Dear Mr. Mannchen:

Thank you for your comments regarding the 2006 and 2008 mobile source control measures for the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP).

Throughout the latter part of 2008, H-GAC will work to quantify and re fine this Master List into a Short List of measures which the Ho uston-region will recommend to TCEQ for implementation in early 2009 as part of the SIP. You can follow the pr ogress and see a more detailed summary of the SIP process, the timeta ble for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.hgac.com/taq/airquality/sip/default.aspx

Additionally, we encourage you to become more involved with the SIP process. I am happy to provide more information about the form and scope of these control measures by phone (713- 499-6695) or email ( Shelley.Whitworth@h-gac.com ).

Sincerely,

Shelley Whitworth Air Quality Program ManagerG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-43 B.2.1 Comment from Angel Br others Enterprises, Ltd.

Ange l Broth ers E n terprises, Lt d

.

5210 West Road P.O. Box 570 

### Baytown, Te x as 77522-0570 

### Pbone 281.421.5721 

### Fax 281.4 21. 5 7 96



### www .angel br others

. com



### July 2 5

, 2008



### Hou s ton Ga l ves t o n Area Co u nc U 3555 T i mmo ns Ln.

, Suite 120 Howrt o n , l){

. 77 027 Attn: Board of Director s Fax # : 832-681

- 2551 E

- mai l : Mary .Spain@h -g ac.com

Dear H -G AC Board Membe r: 

# Angel Brothers

Povtng and Utility Conlroorors

An Equ al.()ppottuni ty Employer



### My nam e i s Duane M. 

### Gatlin, Sr

. and I am Vice Pres i dent of Ange l Brothers Enterprises. Ltd

. , and we are a memb er in g oo d s tanding with the A ss ociation of General Contrac t ors ("AGC" ) 

### and the Houston Contractors Association ("HCA"). I am writing 

### t oday to express my fu ll support f or the positions li sted on the attached d ocumen t co n c e rning off road emission control strategies and urge you to support these positions as well.

AttachmentG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-44 B.2.2 Comment from Balfour Beatty Infrastructure Inc. 

# Balfour Beatty
I n frastruc t u r

e In c

.

J uly 28, 2008

Ho u ston Galves t on Area Council 3555 T i mmons Lane, Suite 120
Ho u ston, TX 77027 Attn : Board of Directors F ax# : 832-681-2551 Emai l : Mary

. Spain@h-gac.com

Dear H

- GAC Board Member : 

### Balfour Beatty Infrastructure
, Inc. Southwest Region

170 I Directors Bou l evard Suite 1 0 10 Austin, Texas 78744

Tel 512-707-0797 Fax 512

- 707

- 0798



### My name is William L

. Miller

, I am the S r. Vice Pr es i dent, of B alfour Beatty Infrastructure, Inc

. and we are a member in good standing with the Association of General Contrac to rs and/o r the H ouston Contractors Assoc i ation. I am writing t oda y t o express my full

s upp o rt for the pos i tions li ste d on the attached document concerning off road emiss i on co n trol strategies an d urg e you to s upport these positions as well.

William L

. Miller Sr

. V i ce Pres i dentG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-45 B.2.3 Comment from Beyer Construction, LLP 

## BEYER CONSTRUCTION, LLP

1 2200-B Du n can Road H ouston

, Texas n066 (2 8 t) 587-5900 Fax (28 1 ) 587

- 5948

July 29, 2008

Houston Galveston Area Council 3555 Timmons Ln.

, Suite 120 Houston, TX. 77027 Attn : Board of Directors Fax# : 832-681-255 1 E

- mail : Mary.Spain@h-gac.com

Dear H-GAC Board Member:

My name is Steve Jarvis. I am the Vice President and General Manager of Beyer Construction, LLP and I am a member in good standing with the Association of Genera l Contractors and the Houston Contractors Association. I am writing today to express my full support for the positions**list~d** on the attached docum concerning off road emiss i on control strategies and urge you to support these posit i ons as

Atta chmentG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-46 B.2.4 Comment from Cravens Partners, Ltd.

U, '

. * 21728 Fa irg r ounds Rood • Hempstead. TX 77445 • Tel. 713-JOQ-1530 • Fox : 713

- 30Q-153 1 t'-•



### July 28. 2008

Houston Galveston Area Council 3555 Timmons ln., Suite 120 Houston. TX. 77027 Attn: Board of Directors Fax#: 832-681 -2551 E-mail: Mary.Spain@h

- gac:com

Dear H

- GAC Board Member:

My name is Will Cravens I am the owner/proprietor of Cravens Partners. LTD.

. ..... ..



### Construction

. Company and I am a member in good standing with the Association of

. General Contrac t ors and/or the Houston Contrac t ors Associat ion. I am writing today to
express my full 

### support for the posit i ons listed on the attached document concerning off road emission con t rol strategies and u r ge you t o support these positions as well.

William H

. 

### Cravens President · Cravens Management. LLC General PartnerG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-47 B.2.5 Comment from E.P. Brady, Ltd.

TELEPHONE 71:H9HI923

July 

### 29, 2008 "



### Houston Galveston Area Council 

### 3555 

### Timmons Ln., Suite 120**Ho~n.Texas77027**



### Attn: Board of Directors

Dear H-GAC Board Memb et: FAX 713-691·5423



### My 

### name is Daniel Brady: I 

### am the owner/proprietor ofEP Brady LTD 

### Const111ction Company' and I am a member in good standing with 

### the Association of General Contractors and/or 

### Houston Contractors Association. I am writing today to express my 

### ful I 

### support for the positions listed on the attached 

### document coJ1cerni11g off road emission control strategies and urge you to support these pos iti ons as well

.

Sincerely

,

# ~adyG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-48 B.2.6 Comment from Highway P avement Specialties, Inc. 

### UI,.UiJIJJV 

## niUUWitl**PA~MENT** SPECIALTIES, INC.

August 4, 2008

Houston**~~lveston** 

### Area Council 3555 Timmons Ln. ; Suite 120 Hou ston, TX 77027 ·

Attn: Board of Directors · Fax#: 832-681-2551 E-mail : Ma,Y.Spain@h-gac

. com

Dear H-GAC Board Member :

My name is Jo Ann H

. McGehee :

. I am the owner/proprietor of Highway Pavement & 

### Specialties

. Inc

., and I am a member in good standing with the Association of General Contractors and/or the Houston Contractors Association

. I am writing today to express my full suppprt for 

## the pos itions listed on the attached document concerning off road emission control strategies and

. urge you to support these

. , positions as well

. . Sincerely,

.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-49 B.2.7 Comment from J.D. Abrams, L.P.

J

. D

. ABRAMS, LP

.

EXEC UT IVE OFFICES Ill CONGRESS AV E NU E, S UIT E 2400 A

USTIN, TEXAS 7870 1 PH. 5 1 2 ·322·4000 FAX 512·322·4018

H

ouston Ga l veston Area Counci l 3555 Timm on s L n., Sui t e 1 20 Ho uston
, TX. 770 2 7 Att n : Bo a rd ofDirec t c:ir s Fa x # : 832

- 68l

- 2551 E

- ma il: Mary.Spain@h

- gac

. com



### Dear H-GAC Boa r d Me m be r : HOU STON AREA
1 3020 DONEGA L WAY HO US TON, TEXAS 77 047 PH

. 7 13 ·7 34-6499 F AX 7 1 3·734·6722

My name i s Will ia m Dug l Ja y. I am the Hous t on Area Ma nage r for J .D

. Abrams, L. P. and I am a me mber in good standing wi th the Association of Genera l Contrac t ors . I am writing t oday t o express my full
suppor t f

o r the positions lis te d on the a tt

ached document concenring of f road em i ss i on contro l st r ateg i es

an d u r ge you to suppor t these po sition s as we ll

. ·

Cc : Jon Abrams Tracy Sch ie f fer

, Pre side n t T exas Ch a p ter AGCG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-50 B.2.8 Comment from NBG Constructors



## NBG CONSTR U C T ORS, INC. General C ontractor

9702 Synott Road Hou s ton , Texas 77083 (281) 495-0842 Fax (281) 495-0960

7 / 28 / 2008

Houston Galveston Area Council 3555 Timmons L n. , St 120 Houston, Texas 77027 Attn: Board of Director s Fax# 832-681

- 2551 E-mail : Mary.Spain@h

- gac.com

Dear H-GAC Board M ember:

My name is David E. B oehm I am an owner ofNBG Constructors, I nc

. and I am a member in good standing with the Association of General Contractors and the H ouston Contractors Association . I am writing today to express my full support for the po s itions listed on the attached document concerning o f f r oad emission strategies and urge you to support t hese posit i ons as well

.

D avid E

. Boehm, Vice Pres i dent
NB G Constructors

, Inc

.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-51 B.2.9 Comment from Pavers Supply Company 

# PAVERS SUPPLY COMPANY

"Quality Road Building Materials Since 1978"
P .O. B OX 26 7 1 

## C ON R OE, T E XA S 7730 5 PHO NE (936) 

## 756

- 6960

FAX (936) 756

- 6903

P

lant Locat i ons: Con r oe (936) 756

· 2722 Hunts v il le (936) 291**~169** M o ntgomery ( 936 ) 597

· 6669 Cleveland ( 261) 4>! 2 -2722



### Ju l y 28, 2008

Houston Galveston Area Co u ncil 3555 Timmons 

### Ln., Suite 120 Housron

, TX 77027 

### ATIN: Board of D irectors 

### Fax#: 832-681-2551 Email : M111y.Spa j n @ b-gac

. com



### Dear H

- GAC Board Member:



### My name is G ene Smith 

### I am the owner / p r oprietor of Pavers Supply Co

. A local Construct i on Company and I am a 

### mem b er in good standing with 

### the Assoc i ation of General Contracrors. I am writing roday to e x press my full support for the posit i ons listed on the attached document concerning off road emis s ion control strateg i c:$ and urge you to s u pport these positions as wellG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-52 B.2.10 Comment from Prime Eco Group



## PRIME ECO 

## GROUP
Ecology Thru Technology

...

Hous t on G a l veston A r ea C ou n c il 3555 T im mons Ln

, Su it e 1 20 Hous t on, T X. 77027

A ttn: Bo ard o f D ir ectors

Sent by e-mail Dea r H- GAC B oar d Membe r :

My n am e is Fe li pe J. Gu zma n I am t h e ge ne r al ma na ge r / p r op ri e tor of Prim e Eco G rou p, Inc, a

ma nu f ac t ure r of env ir onmenta l che m i ca l s f o r t he Co n s tr uc t i on i ndustry

, an d a me mb e r i n good stan d i n g

w i t h t he Assoc i a t i on o f Gene r al Co n t r acto r s an d / or t h e Houston Co n t r acto r s Assoc i a t i on. I am w rit i n g to day to exp r e ss my full su pport for t h e posit i ons li st e d on t he attached d ocument co n ce rn i n g o ff r oad

em i ss i o n con t r o l s trat eg i es an d u r ge you t o s u ppo rt t h ese p os it i ons as we l l

As a com pan y de di ca t e d t o conser v a t i on an d t he r esearc h I de v e l opment o f en vironmenta l a lt erna t iv es for conc r e te an d asphalt pa v i ng, we u n der stan d t he n ecess it y o f env ir onmenta l i n it i a t i ves a t t h e sta te l eve l f or Texas dri ve r s an d taxp ayers.

Very S i ncere l y,

Fe li p e J. Gu zman Genera l Manage rG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-53 B.2.11 Comment from Smith & Company 

# SMITH & COMPANY

ROA D S

- BR IDG ES-HIG H WAYS -A SPHALT PAVI NG 

### ''Building Quality Roads Since 1970"

July 28, 2008

Houston Galveston Area Council 3555 Timmons Ln.

, Suite 120 Houston

, TX 77027 ATTN: Board of Directors Fax#: 832-681-2551 Ema i l : Mary.Spain@h-gac.com

Dear H-GAC Board Member: P.O. BOX691 CON ROE, TEXAS 77305-0691 PHONE (936) 756-69UO

FAX (936) 756- 6903



### My name is Mike Smith I am the owner/proprietor of Smith & 

### Company

. A local Constn1ction Company and I am a member in good standing with the Association of General Contractors. I am writing today to 

### express my full support for the positions listed on the attached document concerning off road emission control strategies and urge you to support these positions as well.

Sincerely,

# ;10w~ Mike SmithG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-54 B2.12 Comment from W.W. Webber, LLC

Houston Galveston Area Council 3555 Timmons Ln., Suite 120 Houston, TX

. 77027 Attn: Board of Directors Fax#: 832-681-2551 E-mail: Mary.Spain@h-gac.com

Dear H-GAC Board Member:

My name is Charles Burnett, I am the President of WWWebber. LLC Cons t ruction Company and

we are a member in good standing with the Association of General Contractors and the Houston Contractors Association. I am writing today to express our full support for the positions listed on the attached document concerning off road emission control strategies and urge you to support these positions as well.

Sincerely,

Charles Burnett PresidentG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-55 B.2.13 Comment from William Broth ers Construction Company, Inc.



## Williams Brothers Construction Company, Inc.

P

. O. Box**66428~** H o ui

. ton. T e,1as 77266 Phnntt: 71 3

.. 622·9821 FIUC : 713

.. 520·5247

Ju l y 25, ZOGB

Houston Galveston Area Coundl 3555 Tlmmon !> Ln., Su i re 120 Housto n , TX 77027

AUn : Board of**~ectors**

Re: Comments on PJoposed Non-Road Air Qtr.illty St'tlltegles

Dear H·GAC Board Member (s ): Vla**E~mail~** Marv.Spafnl! h Mgac.oo m
8 

### pages

My name is 

### Robert 

## c

. (Bob) l.lln ha m , la m v i ce pres i dent of WIIJiarTLS B r <Jthers Constr u ctio n Company ( a Houston-base d nrm) and 

### the fil'!l1 i s membe r in gOQ(I s t amdi ng W i th \he As$0Ciated Gen""'l Qmt ract ors of Texas (AGC**of Te~as)**  and the Houston Contractors As

. sociotlon**(~ICA),**
1 have been per.;onally t nv o l ved wlth the dean a i r Issue 1 11 Houston and how 

### I t re l ate s 10 ou r I ndUstrY f o r
over 12 years. A few o f my credentia l s: I am 

### a current 1 nemb e r of HGAC's RAQPC

, I am a Past Pr

e.s lde n t of the H o u ston Constructio n fnd ustry Coalition and the AGC or Te><as. I have served a s tile Cha i rman of! 

### he Highway Division 

### of**t~e.** AGC o f America and 

### as**t~e** Chalnnan o f AGC of Texas 

### 81>1 AGC

o r America ' s Envi r onme n tal Comm i ttees. Former Speake r Pete Laney appo i nted me to the. TERI' Advisory Boa r d**~ere** I

, selVecJ t\Vo y eats as the vice chair. I h ave participated in the West Coast, Mid-At l antic. a nd Blue Skyways Collaboratives

. I have spoken at several E PA National Oean Diese l Cllmpalgn conferences

. WIDiams Brothers Construction Is an act i ve TERP grantee W i th oVer 300 TERP p rojects.

I am persona ill( d i stu r bed a 

### boot the pr
· ocess llme li ne. Modell no ha s not been accomplished. S

u bsequently, the region docs not know the amou n t of emission r ed u ctio n s nec e ssary to r each al:ta1 n ment

. Businesse s do no t make de d s l ons without a target o r projected outcome. The reg i on Js

u n dertaking a decisio n -maki n g pr oc ess wi01out a target. This Is unw i se. U n necessa 1 y regional**ecot~om c**  dampers may r esult from fo ll owing this type of process,

As a**~ey** pa r ticipant in the deve l opmen t of these positions, as a l ead e r I ll our I ndustry, and a s a slbject
matter expert

, 1 am w ri ting today to express r ny lull support for the l oouslly positions li s ted on the attached doC\Jrnent c o n c e r n i ng oi F road emi.ssion cont r ol s trateg i es. Some of tile responses are unfortu n ately vague due 

### to t h e 

### lad< oF In f ormati o n availab l e obout U1 e a<tual strate gy be ing**co dere** **,** J am a>nOd e nt In the veracity of t h e comments aoo position s

. 

### J**tt o~** **y** urge you to consi d er and

SUP!>Of t 

### U l enl

.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-56 B.2.14 Comments on Draft Off Road Strategies

COMMENTS ON DRAFT OPP ROAD STRATEG IE S :

# I ndustry Categ01y/Strategy # Conuuent s Position
5 Suppo rt C l e aner Equi p ment Industry supports T ERP bu t o ff ers the f ollm.v i ng co nu nentary as methods to i mprove t he progr am : Requiremen ts &

Incen t i ves Expectation from TERP i n i t s c urrent configuration are TOO H I GH b a s ed on a numbe r of fac t ors :

1 ) Statutory lim i t s on emi ssio n thresho ld s f or te chno l ogy 2 ) Shifting o f excess i v e funds to research
3 ) EPA control of tecl mo lo gy certification
4 ) CARB & others l a ck of concern re{( arding NOx a s a p ollutant o f concern when t e s ting new
t eclmologies
5 ) Limitations in the manufacturing ind u stry
6 ) F u nding

As a resul t, progr am change s are nee d ed to expand suc ce ss. St !gge s ted i mprovement to TERP:

I. l'v!aximiz e. small bu siness 12articij2ation in TERP

TI

1 e TERP grant program req u ire s s i gn ifi cant
, complex air em i ss

io

ns calculations

. Th oug h viewed as

neces sary for stringent a udi t an d verific ati

on proce dure s, these requiren 1 ent

s serve as a deterrent t o small bu si ness pa rtici pation.

a. Re d efine "s mall bu siness " to SBA s ta ndards i n lie u o f TCEQ s tandards for the purp ose o f
adm i n i s tering TERP so tha t more

. firms can be eligible for ass is tance directly f rom t he TCEQ

. b

. :Modify TERP m le s so t1 1 a t third partie s (pu blic

, priva te
, profit

, non

- profit ) can s e..tVe as a coopera ti ve

o r collective f or the pur pose of grant applica ti ons. Small firms can J O i n the co -o p and receive the
b enefits b y tl 1e co -o p sub m i tting TERP a pplic ations on b eh alf of a group

.
C. lvfodify TERP m l es s o t ha t cer t a i n r epair s hop s o r d ea l er maintenance facilitie s can be preq ualified by

a gr ant process to ins tall retrofits or repm.ver s on equi pment br ought i n for repairs

. A " coupon "

p roc ess could b e util ize d obligating the e q u i pmen t owner to all of the required reporting procedures

w itho ut an applic a tion

.

Re quir e all public entities wi th cap i tal i mprovemen t programs in a ffe c te

d coun t i es t o provide TERP
outreach as a part of the pro jec t adverti s emen t pro t oco l s regard l ess of the media outle t.

2. Lower the 30 °Lo t hre sho l d requirement in TERP f or r etrofi t pro j ect s.

The 3 0% thr esho l d ha s b een a b arr i er t o teclu 1 ology de velo pmen t R econu nend low ering to 1 0 %

. The tlue s ho l d co u l d be " gra d uate d" w i tl1 a lower thresho l d p erm i tted if the cos t effec t i veness i sG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-57 # I ndu s t ry C ateg ory/St r a t e g y # Cotnn 1 en ts
Po s it io n excellent.

3. LO\ver t he a v e ra gl; co s t e ffective n es s of TERP 11 rojec ts

Co s t and pr ice are f undamental conce p ts of economic s. Co s t i s a fimction o f effic i e n cy i n the

manu f acturing proce ss

_ E mi ssi

on t echno l ogies have high prod u c ti o n costs due to re s earch and developm e n t, manuf a cnu i ng i nefficiencies , and s l ow cert i fica t i on p r otoco ls

. Price is a func ti on of

su

p p ly and d emand. There i s a deman d for t hese te chnologies wi t h extr e m e l y lim it ed su p p ly. T o l ower the co s t effectivene s s of TE RP p rojects

, a bu s i ness climate s houl d be c reated th at p r omo t es b oth l owe r cos t a n d l o w e.r p r i ce fo r emiss i on r ed

u ction technology

.

T o r eme d y / mitigat e the a d ve r s e e cono mi c factors for th e deli very of emi s s i on t ec h nology t o the

ma

rket , we r e commend :

• ) De v elop a n d im plemen t c r i te ria f o r th e ex p ans i o n of enti ti es , pu b lic or p r i va t e , tha t c an

b ) '' e ri fy I ce rti fy the em i ss i o n st an d a r d of n e w t echnology i n a manner accep t a b l e to the US E P A Spee d u p / s tr eam l i ne t h e US E PA t echno l ogy v er i fi ca tion / ce rtifi ca

ti on p ro ces s

_ c) The USEPA m u st b e gi n to a ccep t sta t e a genc y or t hir d p a rty v e r i fica ti on

/ c e r tification o f e missions technology

. d) Thes e b ro ad based p rogram changes \ V ill!ow e r th e cost to p ro d u ce an d d e liv e r n e w techno l ogy to th

e mar k e t. It will i ncrease ccmpetitio n i n the mar k et t hu s increas i ng supp l y and lowering p r ic e

. TI 1

e net effec t \Vii i b e 10\ v e r co s t effec ti venes s thresho l d s f or f u nu e T E RP p ro j ec

ts_

4. Manufactu re r limi t a ti ons

- R egardless on t he a mount of mone y a vail abl e th:ro u g h TERP o r a n y sim

i lar p rogran 1 , th ere ar e phys i c a l con s tr ain t s \V i t h '\\ rhich we mus t con t end.

a ) TI 1 e m a n uf acnuing ind u stry capa ci ty

- It t ook decad e s t o pr od u ce the o f f

- mad fleet cll!r e n ti y b eing

op erated

_ If ti 1 e manufac t ure r s com p le t e l y s t o pp e d n e w work and p rod uc

e d new engin e s for ti1e existing fl ee t, i t woul d take d e ca de s to m ak e thi s happen_
b ) Engineering fe as i b ility

- E ngine s canno t b e ar b itr ar il y sw a p p ed o ut Su ppo rt sys t em s h ave to be

e v a

l u a

t e d a n d r ed

e s i

gn e d t o acconunodate the n ewe r type e ngine s_ Sometim e s t h e n ewer engines j us t won>t fi t

_ Su b s e qu e ntly , " repowe ri ng" equ i pment is not a "silv e r b ull et

n t o cu re a ll of our
p ro b l em s

_ 8 S u pp ort C l eaner E qui p men t Incentive b as e d a pp roa c hes ar e su p porte d by i ndustry

. Not eno u g h details exist on t hi s i t em to prov i de

Re quire m e n ts & an y sub s t an

t i ve com me n t. Incentives

6 S u pport C l eaner E qui p m e n t G ood i f f oc us i s short te rm d e 1ive r abl e s. Researcher s have n o t b ee n ade qu at e ly co ntr o lled t o d a t e Re qu ir e

m e n ts & Incentiv e s
8 S u ppo rt Con s tru ctio n E q u i p men t Govemmen t contract i ng i ncentives

- The T: x D O T in ce

n ti v e program was de v e l o p ed join t l y <vithG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-58 # I ndus t ry Categoty /S trategy # Con1n1eJ1ts
Po s i tion
& O perations ind u s try and wou l d be s u p po rt ed

. I ncrease s i

n the a moun t o f i ncentives t o b e earned shou ld be

cons ide

red

. 9 S u ppo rt Cons tru ctio n Eq u i

pment This activity is already un de rway b y US E P A. I h a ve been a part icip ant i n th e pro cess. It '.'il l yie l d low & O p erati ons cos t r e d uctions B U T there w ill b e oppos iti

on b y the N I MBY faction. BMP s has so me potential but

mo s t a ddre ss PM an d not N Ox.
10 Suppo rt Con s tru ction E q u i pment A pro hi bi ti on on extended idli ng of diese l engines is an effec t i ve emi ss.i on r eduction s tr a tegy dta t c a n be ( Q ualifi ed ) & O p erati ons su pported b y the i n d us tr y. Depending on the appli cation

, limi ts c a n b e e s tab li s hed on how l ong diesel

eng

ines shou ld be allowed t o i dl e

.

1) Th at t he T C EQ wo r k w i d 1 d t e indus u y t o de v elop recommended idling l imi ts fo r \'llrio t lS type s o f
dies el engine app l i cation s

. 2) Su b s equently, T CEQ t o adopt a no- id

li ng nil e b ase d upon t he agreed app l i cation -b ased lim i t s

.

I d ling restrictions ar e gene r ally s u p po rted by i n d us t ry so long a s t here i s no cost i ncrea ses su ch as t a.'<es

.

S H OULD APPLY T O ON & O FF R OA.D
1 1- Support Engine & Fu e l Engine te chno l ogies

- af t e r market d ev i ce s will be supp o rt e d onl y u n d e r a v o l untaty mo d e such a s 14 ( Qualified ) Techno l ogy T ERP ; Mandates w i ll be litiga t e d

1 5

- S upp ort Engine Stan d ar ds 

# . US E PA engine standard s are su ppo rt ed on t heir curre n t time line 1 6 ( Qualified )



# . No r m a l at tr i tion of the o ld er fleet mu s t be allowed to occur on the norma l busi ness i nve s tmen t cycl e ruil e ss s u p p l emente d

. b y a volun t ary p rog r am snell as T ERP

1 9

- Support F ue l S t an d ar d s F u el strategies are s uppo rte d so long as c e

. rtain c rit eria ar e met: 20 ( Qualified )



# . Adequ a te ad\'llnce t esting i s co nduc t ed t o i n s ure no adve rse a ffects on the dies el engine or any of i ts

con 1 ponen ts

.



# . Adequ ate t esting t o i n sur e no Jo ss of p ow er occ ur s in the engine outp u t Lo ss o f pow er will r e q u ir

e the utiliz atio n o f l arge r equi p men t to per f orm d 1 e same t ask t ht lS defeating t he purp ose o f o r

r educing t he e ff ectivene ss o f the s trategy

.



# . Adequ ate te sting t o i n sur e no los s of fue l e f

fici e ncy. Lo ss o f fue l effi ciency wil l cause mo r e f u e l t o be

consume d to prod uce d 1e sa me an l Olll l t of wo rk d l t lS de f eating the purpo se o f or re d ucing the ef

fe

ctiveness of the s trategy.



# .**Adequ~t e**  t e s ting t o i n sur e

. the r e

. are no toxi ci ty i ss ue

s

. As em ploy er

s, t he i n dustry i s concerned w i th emplo yee expo s ur

e and the c r eation o f ad di tional environmen t a l hazar d s

.



# . Research and pl an d>e in 1 pl ementation t o i nsure ad e qu a t e fuel s u pp l y

.



# . Research and p l an t he impl emen ta tion t o pro tec t contr a ctors i n fixed price contract s f

rom incr ea sed
fue

l p ri ce s.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-59 OTHER POTENTIAL S IP CREDIT

1. Fe d er

al ( US EPA ) Retr ofi t Program

- In the 2005 Ene r gy Bill 1

, Sena t or Vo i no vi ch i ntroduced a n d pa ssed an a mendment th at p rov id e s S I billi on for th e

re trofi t of die s e l eng i nes

.

c ) Push for full f u nding and a pp

rop riation by the Congress. d) The T CEQ a nd the St ate of Te1ms apply f or their fair sh are of this funding

.
e ) Ob t a i n a commi t m ent from the U SEPA for a m i nimum g u ar anteed ftmding l eve l for Te xas retrofi t p ro j ec ts. Tilis g u a

r anteed ftmding l evel c ou ld
i ncl uded i n the SIP i n the s ame manner a s TERP

. t) The ftm di ng wou l d either b e i nclude d i n the TERP p rogran 1 or man a ged s epar ately

.

2. Congestion i'v liti gation a nd Air Qua li ty F und ( Ci\ILA.Q Fun d)

- TI 1 e reauth ori z ation of the fede r al l lighwa y b ill

, SAFETEA -L U'

, in cl uded r e v ision s tha t p ern the use of the C J'.; IAQ F u n d for enli ssi on reduction pr o j ec

ts for non

- road equi pment. P r e v io u s l y, these ftmds ha d b een linlite d on on ly on

- ro a d emi ssi o n

r eduction pro j ec

ts.

a ) Wo rk w i th t he US D O T an d FHWA t o expedite gu ida nce and po licy fo r t he imp l ementation of t l li s ne w provis i on. b ) \\ l o rk w i th TxDOT t o expedi t e implementation of t he new p olic y.

c ) Ob t a i n a commi t men t from TxDO T on the amount of monies to be spent ann ually from Ci\ILA.Q on non

- roa d e nlissio n red uction p rojects

. d) Adverti s e and p romo t e the program t hrough l oca l Metro p olit an P l anning Orga t lization s

.
e ) In cl ude the com nlitted ftmding l evels from Cv1AQ on e .nlission red uctio n pro j ec ts in t he SIP in th e same manner a s TERP.

3. Emi ss ion s Banking and Tr adi n g P rogram

a ) Emi ssi ons tr adi ng progr an 1 should be modified t o facili tat

e the i ncl

us ion of non

- road sou r c e red uctions.
b ) The tr ading progr an 1 will wo rk similiu t o an i ncentive program w i th the company making a n i n v e s tment in clean ai r tecl u1olog y and i s le ft w i t h
credits that c an accrue v a l ue depending on the mar k e t

1 H.R. 6

, Su btitle G

, Sec ti o t " 791

- 797 2 H.R.3G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-60 The f ollowing t ab l e i s a. l i s t of proposed con t rol s trat egies t hat th at are oppo s ed by th e c i vil con s tmction i nclu s hy a nd have been
removed from the li s t by RAQP C. We would strongly oppose any reconsiderat i on of the se items a s po s sible con t rol s trategy altemati v e s

.

30 Ne u tr al CleaneL Equ i p men t No comment Requiremen ts &

Incen t i ve

s 31 Oppo s e C l eaner Equ i pme nt Acce l erated Fleet T u rno v e r

- Li ti ga

t ed and d efea t ed in th e 1 H r SI P

. On l y a cce

p t a

b l e t o the i ndu s t ry Requiremen ts & unde r a vo l unta.<y measure fun d e d by TERP

. Inc e
. ntives
33 O p po s e C l eaner Equ i p m e n t Operating restriction s

- will be oppo s ed ; Previously litigated and o v er t urne d Requiremen ts &

Incentive s 34 & O p po s e Con s tru c t i on E q u i pmen t Condi t i on s of approval for new constructi on 35 & Operations
B a ckdoo r a pp r o ache s to a chie 1r e #3 1 and # 3 3 ; \ V ill b e oppo s ed; Pernli ts for ne w construc t i on w i ll create

more govemme , nt

; Emission s limits on pro j ects

- no t t echnicall y fea s i bl e d ue t o lac k of ex p erti s e

Unaccepta bl

e fo r the foll o wing reasons : 1 ) Death on econonlic growth
2 ) L ack of c ompeten t techn i c al experti s e t o do thi s i ntelligen tly
3 ) \\'i'il l b e u s e d a s a v ehicle b y s ome f action s to stop gro\vth
4 ) \\'i'ill re quire a ne w bureaucra cy t o e st a blis h a per mi t ting proce ss. Permit s wou l d b e the onl y mechan is

m to n 1 ake thi s enfo r ceable

.

Con tra ct

- Ba sed c o ntrol s tr a t eg i e s \vill :



# . D is en fr anchi s e contra c tors



# . Red uce con1petition



# . Increase the co s t o f cons tru ction

Furthermore, th e re i s s i gnifican t l egal pr ecedent prohib i ting t he use o f s uch meas ur es:



### • For s tate s o t he r t h a

n C al i fornia and all p olitical s ubdi vis

i on

s, § 20 9( e ) o f the federal Clean Air
Ac t preen 1 pt

s an y en1is s i on - r

elated s t ate o r loc a l s tand rurd or o t her re q u ir en 1 en t o n ne w o r n o n new veh icl es , b u t allows {( op ting i n> ' t o Cali f ornia' s r egulation s
.

0 §209 Pr o t ec ts Ve hi cle Con su mer s

. As t he S u pr

e me Court h e ld in E i\l l" v

. SCAQ i';

ID

, 54 1 U.S. 2 46 ( 2 0 0 4 ), by limiting the st a t e and l ocal go v ernmen ts t o choo s e between
EPA 's nationa l s t an d ard s an d California ' s s tan d a

r d s, Congre ss i n t en de d §209 to
p rotect b o t h veh icle manu f acnuers and con s umers from v ehicle s tandar ds tha t fail toG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-61 mee t the s t a mtory cri t e£ i a ( e

.

g. , teclulical and econonlic feas i b ili ty, l eadtime )

.

o § 209 Preemp t s In

- U s e Control s

. §209 ( d ) express l y reserve s s t a t es ' author i ty over in

use mo t or

- vehicles ( s u ch as Ca£POol l ane s )

. B y contra st, as the U

. S

. D i s trict Court i n Austin held in EMA v

. Hus t on, 1 90 F

. Supp.2d 922, 927 & n.3 (\V D

. Tex. 200 1 )

, §20 9 ( e ) preemp t s all em i ssion

- rela t e d contro ls for nonro ad vehi cles

, '.'ith no sav ing s claus e f or i n - use non r oad ve hicle s
.

• Under s ome s tatutes , courts recogn i ze a "mar ket

- pa rticip ant'"' exce ption to otherwi s e - a pplicabl e federal preemption

. In Cardinal**To \\** **~ng** v. C ity of Bed f o r d

, 180 F

. 3 d 686

, 693 ( 5th Cir

. 1 999 )

, the Fi f th C i rc ui t adopted a two-p ar t t est t o de t ernline wh en a go vernment action f alls on the "pro prie t ary'' sid e of the regu l a t ory

- proprie tary di s tinction :

o Exception Refle cts Typical, Effi cien t Behamor

. Doe s the action e ssentially r eflec t a
p ri

vate par ty's typica l**eh"'~or** i n e f ficien t pro c uremen t?

o Exception Is Narro w

. Does the action' s na r ro w scope s uggest a goal t o a d dre ss a
sp ec i fi c prop rie t a

r y pro bl em , rather than to e nco urage a gener al polic y?

o J ·v! anda t oty contract

- ba sed measures f a il bo th ha l ves of the Cardinal To wing t es t: ( 1 ) t he ir grea t er expen s e make s t hem the very oppos i te of a priva te party' s in t erest i n

e f

ficient procurement of s ernce s; and ( 2) t he y are no t narrow l y tailored to project

sp ec i fi c cri t er ia b ut i nstead are ob vi ousl y i

n t ended to address a genera l p oli cy of
red uc ing stat ewide emi ssi ons , partictilar l y for regional pollut ants like ozone

p r

ecursors
.

• To qualify under Clean Air Act § 1 10
, manda t or y contract

- based co ntrols mu s t be f e d e r all y

en f

o r ceable by E PA, the s tate
, an d the public. Whethe r volu n t ary or mandatoty

, reductions

mu st also b e q uan ti fia b l e , surpl u s, pe r manent, an d ade q u a te

ly s upported. Contract provis i ons fa il i n a spect t o :

o F ede r ally Enfor cea

b l e. Like pr iv ate market partic i pan t s, government contrac ts c annot i mpo s e puniti ve li quidated

- damages cla us es in con tr ac t s

. Priebe & Sons v

. U.S.

, 33 2
U

. S

. 407,411 ( 1 94 7)

.

o No t Quantifiable

. To q ualify a s q u antifiable

, an e .nlission r eduction mus t be capable o f ({ r

eli

abl e a nd replicab l e " mea s uretnent , and i t canno t be impractical t o de t ermine compliance \Yith t he published limi t

o Re d uctions Are Not Pe r m

a nent

. To q u ali fy as pennanen t, an en lission re d uction mu s t
exis t thro ug hou t t he time that the Sta t e Imp l ementation Pl an relie s on i t) un l es s theG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-62 s t

ate r epl a ce s i t { e.g. , b y another emi s s i on reduc ti on or SI P re vi sion )

.

3 7 Oppose Cons tru ction Equi p men t Con tr act con tr o l cla us es - l\ifanda t es will be**oppose d~**  Vo l untat.y incentive s will b e supported
& Operations
38 Oppo s e Cons tru ction Equi p men t Bi d p refe r ences will:
& Operations
1 ) D i senfr a nchi s e con t rac t o r

s 2 ) Dr i ve up t he cos t of con s tn1ction e..xponentiall y 3 ) Vio l ate numero us procu r emen t s t atu t es 4 } \Voul d be litigated b y numero u s constn 1 ction assoc i ations
4 0 Oppo s e Cons tru ction Eqtti p men t Ha l f da y construction s ch e d u l e s

- NOI See Comments on #3 1 & Operations
4 3 Oppo s e Cons tru c t i on Eqtti p meJ1 t Share eqttipmen t**~** Conunents re s e nred w 1 til mo r e i nfo i s**available ~**  Sounds i mpractica l and s tupid. & Operations

44 Oppo s e Cons tru c t i on Eqtti p me.n t Tags on equipmen t

- no benefi t and high co s t; If intent is m b undle wi th #3 1 & #33

- w ill b e opposed
& O p erations
58- Oppo s e General Ope r a ti on s 

# . #58

- NO; s ee conunents on #33
62 Manag e men t 

# . #59

- NO; s ee conunents on #35



# . An y r e s triction s on the us e o f e q u i pmen t will b e opposed ; pre vi ou s ly litigated and ove r nune d

8 5 Oppo s e S t ationary Engine s 

# . See commen t s on #3 1

- 35

8 7 Oppo s e C l eaner Equipm e n t ARB porta b le engine s t a ndards
Re q uirem e n ts &

Incentives Adoption of CA en g ine s tan d ards was discusse d d uring the I Hr SIP d eve l opment. I t remove s a gre at d eal o f f ut ur e contro l away from Texas (HG B .-1.

) if the a doption o cctus

. Any funue CA change s wou l d
ha v e to be irnn 1ediately a d o p ted b y T e..'<as. R ecommen d aga i n s t.

IND UST R Y GU ID I N G PRI NC I P L E S

Li

ti gation w ill be supporte d on any s tra t egy ( on

- wad or off

- roa d ) t ha t contains an y o f t he f ollowing including an y hy b rid / v ariation of:

a ) Eqtti p ment use r estr

i ction s b ) Ear l y flee t t umover o r e xis ti ng fleet o b so l es c ence

c ) Mandated e q u i pment modification or rep l acement d) A1. 1 y s t andar d t hat under mi nes the fe de r al r o l e in dies el engine st andar d s

e ) Bi d p r eferences o r restriction sG:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-63 B.2.15 Response to Associate of General Contractors

August 29, 2008

{Commenter} {Company} {Address}

Dear {Commenter}

Thank you again for your comments regarding th e mobile source control measures for the Houston-Galveston-Brazoria 8-Hour Ozone St ate Implementation Plan (SIP). We have considered your comments and would like to take a moment to respond to your comments directly.

Your letter expressed comments on the following control measures:

• Non-road Measure 5 – Enhanced Texa s Emission Reduction Program (TERP): The TERP program is operated under the juri sdiction of the Texas Commission on Environmental Quality (TCEQ). Because of th is, TCEQ will offer a separate response to address this comment.

• Non-road Measure 6 – Aftermarket Technol ogy and Fuel Additive Research Program: Thank you for your comment regarding this m easure. We will take this into account when creating a more refined version of this list in the latter part of this year.

• Non-road Measure 8 – Governmen t construction incentives: Thank you for your comment regarding this measure. We will take this into account when creating a more refined version of this list in the latter part of this year.

• Non-road Measure 9 – Develop air quality best management practices: Thank you for your comment regarding this measure. We will take this into account when creating a more refined version of this list in the latter part of this year.

• Non-road Measure 10 – Limitations on idlin g of heavy-duty construction equipment: Thank you for your comment regarding this m easure. We will take this into account when creating a more refined version of this list in the latter part of this year.

• Non-road Measures 11 (Water injection fo r diesel engines), 12 (Alternative-fueled equipment for all equipment types), 13 (Altern ative fuel heavy-duty equipment), 14 (Lean NOx catalyst), 15 (Early introduction of low-NOX engines), and 16 (Selective catalytic reduction (SCR)): These measures all require revi sions to the TERP program which is operated under the jurisdiction of the Te xas Commission on Environmental Quality (TCEQ). Because of this, TCEQ will offe r a separate response to address these

comments.

• Measures 19 (Lower sulfur fuels) and 20 (Texas Low Emission Diesel (TxLED)): Thank you for your comment regarding these measures. We will take this into account when creating a more refined version of this list in the latter part of this year.G:\HGAC\Reports\Final_051 009\Appendix B_051009.doc 

### B-64 • Old Non-road Measures 30, 31, 33, 34, 35, 37, 38, 40, 43, 44, 58, 59, 60, 61, 62, 85, and 87: All of these measures were included in draft versions of the nor-road control measures list, however, they were remove d from the final version of the Master.

Additionally, your letter s uggested the addition of several new measures to the current list of control measures:

• Use the Federal (USEPA) Retro fit Program for non-road vehicles: This suggestion has been added to the Master List as Non-Road Measures 39, 40, and 41.

• Expand use of the Congestion Mi tigation and Air Quality fund: Thank you for your comment regarding this measure. We will take this into account when creating a more refined version of this list in the latter part of this year.

• Expand the Emissions Banking and Trading Program to include non-road sources: Thank you for your comment regarding this m easure. We will take this into account when creating a more refined version of this list in the latter part of this year.

Throughout the latter part of 2008, H-GAC will work to quantify and re fine this Master List into a Short List of measures which the Ho uston-region will recommend to TCEQ for implementation in early 2009 as part of the SIP. You can follow the pr ogress and see a more detailed summary of the SIP process, the timeta ble for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.hgac.com/taq/airquality/sip/default.aspx

Additionally, we encourage you to become more i nvolved with the SIP process. We are actively recruiting regional businesses that are willing to make their own commitments to reduce air pollution within the Houston-region through vol untary commitments. I am happy to provide more information about the form and scope of these commitments by phone (713-499-6695) or email ( Shelley.Whitworth@h-gac.com ).

Sincerely,

Shelley Whitworth Air Quality Program Manager

### APPENDIX C

Summaries of the Houston-Galveston Area Council of Governments Meetings with the Texas Commission on Environmental Quality and Various Stakeholders concerning the Houston-Galveston-Brazoria Eight-Hour Ozone State Implementation Plan Short List Control MeasuresG:\HGAC\Reports\Final_051009\Appe ndix C_051009.docG:\HGAC\Reports\F inal_051009\Appendix C_051009.doc 

### C-1 

## Houston-Galveston Area Council of G overnments Meetings with the Texas Commission on Environmental Quality and Various Stakeholders concerning

the Houston-Galveston-Brazoria Eight-Hour Ozone State Implementation Plan Short List Control Measures

MEETING SUMMARIES



# First Airports/Airlines Stakeholder Meeting October 1, 2008; held at H-GAC office in central Houston

Persons Present: Mike Kenney (KB Environmental Consulting), James Parise (HAS), Darcy Zarubiak (Jacobs Consultancy), Alan Goldman (Jacobs Consultanc y), Debayan Sen (Jacobs Consultancy), Neal Wolfe (Jacobs Consulting), Karl Pepple (COH) , Roy Conn (Continental Airlines), Marianne Csaky (Continental Airlines), Elaine Karnes (SW Airlines)

Staff Present: Santos Olivarez (TCEQ), Donna Huff (TCEQ), Peter Ogbeide (TCEQ), Shelley Whitworth (HGAC), Graciela Lubertino (HGAC), Kelli A ngelone (HGAC), Ben Finley (HGAC), Connie Chao (HGAC), Mary Schuwerk (HGAC)

TCEQ Presentation : Discussion of Inventories TCEQ presented three handouts re garding the emissions inventor ies for the airlines/airports industry. The “Ground Support Equipment” handout showed the commitments that were agreed upon by the airport industry representatives from the last SIP process. This handout generated a lot of discussion because the cont rol strategies agreed upon were not the same as what the airport industry ended up using to reac h the target reductions.

The “Airports/Airlines Emissions Inventory” handout precipitated discussion regarding the emissions growth projections.

PUBLIC COMMENTS: 1) Jacobs Consultancy pointed outthat there was a difference between what was shown and agreed upon between TCEQ and the airport industry and what would be shown on the documents verifying that the airport industry had achieved the reductions.

a. TCEQ answered that since the submitted verification documents and participants had not been audited, nothing was officia lly verified. What is on the handout is what was agreed upon in the 1998-1999 SIP documents.

2) HGAC asked why there was such a low emissions amount shown at Hobby for Continental.G:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-2 a. Continental answered that they ha d stopped service at Hobby except for maintenance flights. 3) Jacobs Consultancy asked about the dramatic drop shown from 2000 to 2002 on the Inventory handout.

a. TCEQ answered that they had received their information from the TexAir database and so accept it as true. 4) Jacobs Consultancy commented that some of the inventory numbers were clearly erroneous because they show a projected increa se in one area and decrease in the other, which means that the same growth factor s were not used in the calculations.

a. TCEQ said they would double-check the numbers. 5) Jacobs Consultancy asked if the last SIP’s control strategies were already subtracted from the inventory data shown.

a. TCEQ answered yes, the control st rategies were already included. 6) HGAC asked how TCEQ came up with the numbers for 2018?

a. TCEQ said it was just growth. b. HGAC said that it could not be just growth because fleet turnover and all regulations that will be applied betw een 2005 and 2019 must be included for a base line inventory.

c. TCEQ answered that they did not see that as a very big factor. 7) Jacobs Consultancy asked what the growth factors were because of the inconsistencies in TCEQ’s handouts. 8) Southwest said the FAA does not take into account a lot of fact ors like the economy or the effects of 9/11. They would like to s ee what 350EP number were used and to understand EGAS.

a. TCEQ answered that the reason the numbers are off is because TCEQ has not been able to communicate with the indus try and so were forced to use the numbers they have. The numbers TCEQ will use is what can be agreed upon between TCEQ and industry. 9) FAA asked if they and the industry groups could provide TCEQ with different numbers with good reasoning behind them, could those numbers be used?

a. Yes, of course, assuming they are certified and show methodology. 10) Jacobs Consultancy said that the SIP really matters to the airports and airlines. He explained that that the airport is different from the airline, so there is a difference in responsibilities and roles. The airport is responsible for facilities and general conformity. They are planning a multi-billion dollar upgr ade at Intercontinental Airport that would be affected by this, a nd all that the industry is as king for is accuracy because projects like this cannot occur without ge neral conformity. Houston Airport System (HAS) is owned by COH. Jim Parise [for HAS] has received more federal grants than any other airport in the county. Of about 24 gran ts available in the nation, 9 have gone to HAS. In general conform ity, HAS will be putting together air quality mitigation

programs. As for the EDMS, a lot of the defaults are bogus. For exampl e, preconditioned air as a control strategy is very effective but the EDMS defaults do not refl ect the level that it is utilized. It allows airplanes to turn off APUs while boarding. If the SIP makes a rule for a mitigation strategy, then HAS cannot use it for general conformity. HAS will go forward w ith owning emission reductions from now on. We want to cooperate with TCEQ and HGAC on a voluntary basi s, not through rulemaking.G:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-3 11) HGAC asked if they would still allow HGAC to document those projects mentioned for the SIP.

a. Jacobs Consultancy answered yes. They would like the SIP to hold an airports inventory appendix for the years 2002, 2008, 2011, 2014, 2017 and 2018 that listed all airplanes, GSE, shuttles, etc in one place so that it made conformity determination easier. b. H-GAC answer that the inventories for al l those years are not for the attainment SIP, they are for the RFP SIP. 12) TCEQ said that all the airpor t data would have to be backed up by more data. TCEQ has to agree on the methodology used for the airpor t inventory, and so TC EQ needs to see the inventory to begin dealing with that. The appendix is not some thing that is needed for the SIP, but it can be discussed among TCEQ managers. 13) Southwest said they would like to point out that Jacobs Consultancy was speaking for HAS, not for the airlines. It is not necessarily what the air lines want or will agree to.

a. Jacobs Consultancy said that it did not want to misrepre sent what was being said as also representing what the airlines wanted. 14) Continental Airlines asked why calculations us ed to inventory airline/ airport data for NEPA, which is sent to the FAA, could not be forwarded to TCEQ for the SIP [to save time, money, paperwork].

a. FAA commented that the data ju st is not used that way.

TCEQ Presentation: TCEQ SIP Timeline TCEQ presented a handout showi ng their deadlines in relation to the SIP. The shaded dates shown were unmovable. [See “TCEQ SIP Timeline” handout at H-GAC website.]

PUBLIC COMMENTS: Jacobs Consultancy commented that the timeline shows inventory to be a completed task. TCEQ answered that they are open to working with st akeholders until the last minute on the inventories to be sure they are as accurate as possible.

HGAC Presentation : SIP Process Timeline HGAC presented a handout showing their deadlines in relation to the SIP.

PUBLIC COMMENT: 1) Jacobs Consultancy asked if they should comment on the Master List of Control Strategies. 2) HGAC answered: no, the Master List in not up for comments any more. H-GAC is currently working on quantifing the emission reductions for th e control strategies that made the Short List, and when that process is over, the stakeholders will be welcome to submit comments. 3) Jacobs Consultancy asked for confirmation that the Short List was scheduled for adoption by January 30, 2009. HGAC answered: no, that is when the Short List w ill be sent to TCEQ, and it is up to TCEQ to include these control measures into the SIP.

HGAC Presentation : HGAC Funding Available HGAC’s 3 rd 

### Party TERP program allows local governme nt (such as the airports) to apply for TERP grants without having to compete with the whole state. CMAQ funding is for on-roadG:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-4 vehicles such as airport shuttles. SEP is cu rrently only available for school bus funding, but HGAC is working to make that fundi ng available to local governments.

ACTION ITEM: TCEQ 1) TCEQ should retrieve the demonstration docum ents from the past MOU agreements for the airports industry with HAS and DFW so that HAS may learn from past SIP experiences. TCEQ should also send copies to HGAC so it can be posted to the website. 2) Find out if the airports industry can use an appendix from the RFP SIP for the same purpose as the attainment SIP for ge neral conformity and reference.

ACTION ITEM: Industry 1) Airports representatives and TCEQ should get together on M ondays to teleconference at 9:30am to update each other on the inventory and SIP.

ACTION ITEM: H-GAC 1) H-GAC should send a copy of sign-in sheet wi th contact information to everyone that attended the meeting.



# Railroad Industry Stakeholder Meeting December 1, 2008; held at H-GAC office in central Houston.

Persons Present: Ken Gathright (PoHA), Kirk Higbie (PTRA), Marvin Wells (PTRA), Hugh L. McCulley (PTRA), Brittney Weathers (GCFRD), Lanny Sc hmid (UP), Peter Conlon (KCS), Steve McNealy (KCS), Carl Akins (K CS), Mike Clift (BNSF), Staff Present: Donna Huff (TCEQ), Koy Howard (TCEQ), She lley Whitworth (H-GAC), Graciela Lubertino (H-GAC), Kelli Angelone (H-GAC), Connie Chao (H-GAC), Chris Lindhjem (Environ) Environ Presentation : Overview of SIP Process a nd Control Strategy Discussion Environ reviewed the process by which control stra tegies were gathered into a master list of every possible strategy, then narrowed into a sh ort list of realistic, achievable strategies. Strategies that would be voluntary or have local support were those that were considered for the Houston-Galveston-Brazoria region ’s State Implementation Plan (SIP). The off-road strategies include:

1) Voluntary retrofit/replacement programs 2) Increasing the efficiency of switching yards in the region 3) Replacing old switching engines 4) General efficiency improvements, ie, stra ightening routes, grade separation, upgrading technology such as beari ngs and lubrications.

PUBLIC COMMENTS:

1) Question put to railroads: is 50% a reasonable estimate of the number of your switching engines that have already been replaced?

a. BNSF answered that their percentage of switching engines already replaced was probably higher.G:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-5 b. KCS answered that they probably had no switching engines in the Houston area, they have just through-servi ce on UP lines. However, they are planning to install a switching engine in Rosenberg.

2) Question put to railroads: has there been any route straightening in your area?

a. KCS answered no. b. UP said that actually, with Tier 4 standards, there woul d be a decrease in fuel efficiency, which would cancel ou t some efficiency gains.

MOU/MOA Discussion: H-GAC wanted to discuss potential agreements th at could be made for emission reductions with railroad stakeholders. Railroads/ locomotive emi ssions make up a large portion of the emissions inventory.

PUBLIC COMMENTS: 1) KCS referred to a project involving Tower 55 in Fort Worth—a freight crossing with BNSF which was successful, costing a couple million dollars. They said that it was probably not realistic to expect a good amount of emissions reductions funding to be available for aggregated crossi ng or fluidity improvements. 2) PTRA offered up the extension of double-track from Deer Park to Pasadena. The project originally cost $5 million in public funds 8 to 9 years ago, but it was not completed then due to pipeline issues which are now resolved. However, now the project will cost over $10 million, with the difference be ing made up by the railroads.

a. H-GAC asked if this project could be made into a VMEP and the reductions quantified. b. PTRA was concerned about further projec t delays, which H-GAC said that they did not want either, and that a VMEP ag reement should not hold up a project in

any way. 3) UP commented that many times projects for en vironmental benefits had been ‘forgotten’ by the public, and that sometimes, they coul d not receive further funding because of VMEP agreements.

a. H-GAC reminded them of a project that H-GAC had worked on where they had verified that UP would make their VM EP reductions and still accept TERP funds to get even further reductions. 4) There was concern that a lot of locomotives eligible for MOAs are leased. TERP has some limitations for leased vehicles that ar e not attractive to indus try. Suggestions were given for whom to talk to about leased locomotives. 5) PTRA detailed their inventory—24 units ne ver leave Houston, all but 8 have been overhauled, and those will be overhauled this year. They applied to TERP in 2006 at TCEQ’s request. These emission reduc tions could work as an MOA. 6) BNSF detailed their fleet—a large percentage of their switch engines have been replaced by TERP. They do not think they are interested in replacing any more vehicles in this region. 7) KCS said that the potential for emission reductions may lie with smaller entities. They also asked if there were incentives to help with these projects or if th ey were expected to do them on their own.

a. H-GAC answered that projects for M OAs cannot be accepting TERP funds or they will have to be counted under TERP. The same is true for CMAQ funding.G:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-6 ACTION ITEM: H-GAC 1) H-GAC should send to the railroads sample MOAs from the last SIP.

ACTION ITEM: Industry Groups 1) Groups should consult among themselves to decide on Memoranda of Agreement or Understanding that they would be able to enter into with H-GAC and TCEQ.



# First Public Meeting December 8, 2008; held at H-GAC office in central Houston

Persons Present: Brandt Mannchen (HSC), Madonna Lorraine (TxDOT), Melanie Oldham (public health advocate), Dana Blume (PoHA), Marise Textor (Texas Petrochemical Society), Russell Lehrman, Nancie Anderson, Beth Whitehead (GHP), Donna Huff (TCEQ), Koy Howard (TCEQ), Helen Vollmer (Vollmer PR), Lori Ma rtin (Vollmer PR), Chris Lindjhem (Environ)

Staff Present: Shelley Whitworth, Graciela Lubertino, Kelli An gelone, Connie Chao, Mary Schuwerk, J. Ben Finley, Andrew DeCandis

Environ Presentation : Overview of SIP Process a nd Control Strategy Discussion Environ reviewed the process by which control stra tegies were gathered into a master list of every possible strategy, then narrowed into a sh ort list of realistic, achievable strategies. Strategies that would be voluntary or have local support were those that were considered for the Houston-Galveston-Brazoria region’s State Implementation Plan (SIP).

H-GAC Discussion : Control Strategies – On-Road and Off-road H-GAC asked for comments on the draft short list and recommendations from the public.

PUBLIC COMMENTS: 1) PoHA asked about the project life for a marine VMEP.

a. Environ answered that it is not ideal but is feasible to complete a project within the SIP time period. 2) HSC asked if there was any way to get a manufac turer to bring out a Ti er 4 engine early.

a. Environ answered that it is not possible at this time because of the timing of Tier 2 and Tier 3. We will most likely see new SCR technology in 2010. 3) HSC asked if there was a mobile burner piece of equipment that could be use for SCR?

a. PoHA answered that there really was not anything like that to use in place of SCR. b. Environ added that the issue is mostly ownership because a lot of groups are leasing their vehicles, ve ssels, and equipment. 4) Possibilities for marine VMEPs were discussed by Po HA and Environ. Vessel speed reduction and the vessel APU/ hood were explained. 5) Melanie Oldham commented that voluntary measures are not making an appreciable difference in Brazoria County. She thi nks the standard should be 60 ppb. 6) Texas Petrochemical Society commented that vessel speed reduction would probably not be effective in the Houston region because we do not have the same wind patterns asG:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-7 California. Our wind patterns would not necessa rily push ship emissions further ashore, whereas California east-west winds would do that. 7) Texas Petrochemical Society asked a bout pay-as-you-drive insurance.

a. Environ explained that pay-as -you-drive insurance was insurance that gave lower premiums to those that drove their vehicles fewer miles. b. PoHA asked how that was quantifiable. i. Environ answered that insurance co mpanies’ records would be used. 8) Melanie Oldham asked about behavior-based measures such as re duced vehicle speed and restrictions on when people could run their lawnmowers.

a. Environ and H-GAC answered that those kinds of measures did not have a lot public acceptance, so much so that legislation was passed against reducing vehicle speeds for environmental reasons. b. Melanie Oldham requested that H-GAC a nd TCEQ look into public education and outreach as a way to get more acceptance for behavior-based measures and for environmental and health concerns in gene ral, which might help with the public’s behavior. She mentioned that she had ma de her concerns known to her state representative, Dennis Bonnen. Ms. Oldha m expressed frustration with the situation in Brazoria County. 9) Russell Lehrman commented that his area of to wn had some of the same problems that Ms. Oldham mentioned. He said the area where he lived was considered an environmental ‘hot spot’ because he lived near a dairy plant that had a large number of heavy-duty trucks that ran very ne ar his home all day and night. 10) HSC commented that for his or ganization to give respectabl e feedback on the draft Short List report, H-GAC wo uld need to provide more tim e for review before holding a meeting, and H-GAC should consider more car efully their invita tion list. H-GAC responded that the usual public notice proced ures were followed, to include publicized notifications and e-mail invitations. Furthermore, another public meeting will be held closer to the end of the public comment period to allow the public to have ample time to read, study, and ask questions on the material. 11) HSC also commented that the frequently-use d acronym, ‘PQSE’, should be defined in the report.

a. ‘PQSE’ is an acronym employed by the Environmental Protection Agency (EPA) to describe the qualifications that cont rol measures should have. ‘P’ stands for Public acceptance, ‘Q’ stands for Quantif iable, ‘S’ stands for Surplus, and ‘E’ stands for Enforceable. This acronym has been explained in many of the presentations H-GAC has given. 12) HSC was unclear from the report who was responsible for enforcing the voluntary

measures.

a. H-GAC is responsible for overseeing the execution of all the voluntary agreements for the Houston-Galveston-Brazoria region. 13) HSC commented that Mobile6 most likely unde restimates the amount of minor traffic violations that have affects on air quality. For example, HSC estimated that the number of vehicles traveling above the speed limit at any given time on the freeway is probably much higher than the estim ates provided in Mobile6. HSC recommended that instead of lowering the speed limit, enfor ce the one already in place. 14) HSC recommended that dedicated truck lane s, and a control measure that focuses on reducing fleet age (older than 1996) be added to the Short List.

a. H-GAC asked how that differed from its current programs.G:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-8 15) HSC mentioned that the previous standard s were based on the technology of 1996. If improvement is desired, the 1996 engine should not set the standard in the 2009 program.HSC recommended changing the applicability of some of the rules for HOV lane and HOTR lane use. 16) HSC recommended the following in clusions to the Control St rategy Report: “route-traffic platooning”, adaptive traffic signals, and a glossary for the report. 17) Nancie Andersonelaborated on her situation a bout the ill effects of the trucking emissions and noise within her neighborhood, and asked thatH-GAC do whatever it can to help the situation. 18) Mr. Lehrman made further comments regardi ng his concerns about the dairy plant and asked for suggestions for amending the situation.

a. H-GAC assured Mr. Lehrman and Ms. Ande rson that their concerns would be addressed, and their compla ints inquired into. b. It was suggested by members of the public that a nuisance claim could be filed. 19) Ms. Oldham recommended that measures to increase the number of electric cars and electrified bus routes should be increased. Ms. Oldham commented that plans to increase business at the Port of Freeport in Brazoria County were excessive unless some actions were taken to mitigate the damage done by the many trucks traveling to and from the port.

ACTION ITEM: H-GAC 1) H-GAC will review the public outreach procedures regard ing meeting notification and publishing of meeting materials.

ACTION ITEM: Public 1) Public should continue to review and comment on draft Short List documents.



# Construction Industry Stakeholder Meeting December 15, 2008; held at H-GAC office in central Houston

Persons Present: Ken Gathright (PoHA), Bill Duguay (J.D. Abrams ), Bob Lanham (Williams Bros. Construction),

Staff Present: Donna Huff (TCEQ), Koy Howard (TCEQ), Lola Brown (TCEQ), Shelley Whitworth (H-GAC), Graciela Lubertino (H-GAC), Kelli Angelone (H-GAC), Connie Chao (H-GAC), Mary Schuwerk (H-GAC), J. Ben Finley (H-GAC), Chris Lindhjem (ENVIRON)

Environ Presentation : Overview of SIP Process a nd Control Strategy Discussion. Environ reviewed the process by which control strate gies were gathered into a master list, then narrowed into a short list of feas ible strategies. The strategies that were considered for the Houston-Galveston-Brazoria re gion’s State Implementation Pl an (SIP) are voluntary control measures that have stakeholder support.

H-GAC Discussion : Control Strategies (See handouts, (“Control Measure: Construction Contracting Incentives, Measure 8” and “Contr ol Measure: Construction and other offroad idle reduction, Measure 10”)G:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-9 ENVIRON and H-GAC reviewed the two off-road construction strate gies from the short list and asked for comments and recommendations from industry representatives.

PUBLIC COMMENTS: 1) Williams Brothers said that the sugges ted measure, “Construction Contracting Incentives”, had implementation/feasibility problems because it would not work as a fixed requirement and industry would not support it. They said the basic problem is the cavalier attitude taken on when equipment or new technology would be available. The measure was much more viable under the other option as a voluntary or incentive approach. Conceptually, an inventive-base d approach would be supported by industry, but we will be asking people to do things th at contractors will tell you they cannot do. 2) The incentives listed in “Table 1, the TxDOT clean engine incentive and calculated benefit” are not worthy of being used. It is an unused incentive because it is not enough to pay the person to track the data. 3) Another issue is that there is very little publicly-funded construction, so be nefits will be limited. The Regional Air Quality Planning Co mmittee’s Policy Subcommittee had some recommendations for what the dollar amounts should be for the incentive.

a. Environ commented that yes, this wa s true: publicly-funde d construction only accounted for about 10% of construction. It does not get the most of the activity. 4) Williams Brothers continued, saying that the reason people are willing to do engines [retrofits] is because there is only a $40,000 engine in a $500,000 piece of equipment. [It is more cost-effective to do a retr ofit than purchase a new vehicle.] 5) Environ commented that just restricting the incentive to publicly -funded construction is not enough to make a significant reduction. We need to figure out how to use it for everything. 6) For the measure, “Construction and other o ff-road idle-reduction”, Environ commented that anti-idling was very cost-effective.

a. H-GAC asked how idling reductions woul d be estimated by industry groups. b. Environ said that reduced hours coul d be determined through tracking hourmeters.

c. Williams Brother commented that they had an idle-reduction policy, but that they have no idea what the benefit of it is. C oncerns regarding this measure are that conflicting information would come out of attempting to estimate this because what industry groups say their usage is w ould be compared to TCEQ’s model, and they would not match. 7) H-GAC asked if you could look at old proj ects where equipment was leased on a timebasis?

a. Williams Brothers replied that they re nt equipment based on the standard 176 hour per month usage. Charges are increased if the equipment is run more, but the minimum 176 is charged if you run less [accuracy issue]. Some leased equipment could possibly be sampled. 8) H-GAC asked if there were any com panies th at lease equipment that could be asked.

a. Williams Brothers said there might be. 9) Williams Brothers commented that fuel data is too erratic to use for estimation because of the construction market.

a. J.D Abrams said they do not look at fuel data in a way that would be helpful for H-GAC. b. H-GAC asked if the percentage of fuel re ductions before the fuel price increase, would that be acceptable for documentation?G:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-10 c. TCEQ said that their model looks more at activity in hours of use for equipment, so it does not look at fuel use very much. 10) Williams Brothers asked if idling reduc tion estimations were done in the past.

a. Environ answered, yes, based on total hours. 11) Williams Brothers asked what the assumed hours per day were for a piece of equipment.

a. Environ answered that for an excavator it was 1092 hours/year and that a year was about 260 days. That equals 4.2 hours per day that the engine would be running. b. Williams Brothers said that sounded right, but that if anything, equipment would tend to be oversized, not undersized [part of Environ’s estimations].

c. Williams Brothers commented that it look ed like H-GAC and Environ had a fairly good handle on the activity estimation.

H-GAC Discussion : MOUs/ MOAs

PUBLIC COMMENTS: 1) H-GAC asked the construction industry about signing an MOU to do a research project documenting emission reduction.

a. Williams Brothers said that because their research is being done through a private company that is trying to get certifie d, they would have to talk to the manufacturer of some equipment they are testing out. 2) Williams Brothers recommended that empha sis be put in SCR and other emerging technologies. 3) Williams Brothers asked about an anti-idling device and how it would work.

a. Environ answered that it was a timer that monitors engine temperature and other things. The biggest consumer is the railroad industry. 4) H-GAC asked if someone volunteered to document anti-idling equipment, how it should be done.

a. TCEQ answered that they would have to get back to us on that because they were not sure the off-road mode l could deal with that. b. Environ said that it would be difficult for the model because even though it would reduce hours of activity, it would increase load factor. Some calculations can be done independent of the model, though. H-GAC and industry groups would have to be careful not to overestimate reductions.

c. TCEQ commented that if they get more cooperation from the industry regarding activity, they could incorporate reductions into the model. d. Williams Brothers said that they would lik e to know how to do the calculations to estimate the reductions too. As a company, they have not tracked hours of activity every day, but once a week or once every two weeks. From a business standpoint, they are not interested in how a piece of equipment operates on a daily basis. 5) H-GAC asked if it would be possible to document equipment every 500 hours?

a. Williams Brothers asked what the benefit of that would be. b. H-GAC could use the data for usage estimations.

c. Williams Brothers said they could not use data-loggers because they have too many strings attached—proprietary issues and they are cost-pr ohibitive. It would be good to be able to ‘dummy-proof’ their own readings, and definitely need to do more research. 6) H-GAC asked how much Tier 0 equi pment industry groups still owned.

a. Williams Brothers estimated 10%. b. H-GAC commented that if it was re placed, it would get more usage.G:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-11 c. Williams Brothers said that was only true if it was needed. 7) H-GAC wondered if there was anything that could be done about projects that were almost but not quite cost-effective enough for TERP, or voluntary proj ects that could be left open for technology that woul d come into play before 2018. 8) Williams Brothers asked if MOUs precluded using TERP.

a. Yes. 9) Williams Brothers said they could probably get a particular group to agree on an idlereduction MOU, but without consensus on how to document, where would it get us?

a. H-GAC asked about purchasing equipment with shut-off switches. b. Williams Brothers said they would need to know what equipment switches can be put on and how much they are, but that sounded feasible. 10) J.D. Abrams said that it would be benefi cial to understand what drives idling, like keeping employees comfortable. Maybe there is some equipment like truck stop electrification that could be used.

a. H-GAC commented that there was equipment like that that could be employed. 11) Williams Brothers commented that what they need is more facts.

ACTION ITEM: H-GAC 1) H-GAC should send to the construction industr y stakeholders some sample MOAs from the last SIP. 2) H-GAC should look into idle-reduction information, switch-off technologies, and other anti-idling technologies. 3) H-GAC should allow Environ and industry gr oups to coordinate on possible MOUs.

ACTION ITEM: Industry Groups 1) Industry representatives should look into w ho among the industry would be willing to commit to an MOU and what ideas they are interested in.



## Marine/Ports Stakeholder Meeting December 15, 2008; held at H-GAC office in central Houston

Persons Present: Dana Blume (PoHA), Ken Gathright (PoHA), Li nda Henry (PoHA), Kenneth Kidwell (Shippers Stevedoring Company, (SSC) USA), Shareen Larmond (West Gulf Maritime Association (WGMA)), Chris Lindhjem (Environ), Lisa Mc Michae (Port of Freeport), Chuck Moss (Oxid, LP), Rebecca Rentz (B racewell & Giuliani)

Staff Present: Kelli Angelone (H-GAC), Connie Chao (H-GAC), Ben Finley (H-GAC), Graciela Lubertino (HGAC), Mary Schuwerk (H-GAC), Shelley Whitw orth (H-GAC), Lola Brown (TCEQ), Koy Howard (TCEQ), Donna Huff (TCE Q), Santos Olivarez (TCEQ)

Environ Presentation : Chris Lindhjem gave a summary of voluntary non-road control measure #5 which affects the Marine/Port industry. This measure is based on re trofit and replacement of marine engines as the primary means to reduce emissions. By replac ing older engines and equipment with those meeting lower emission standards, NOx and VO C emissions are drasti cally reduced. EPA hasG:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-12 announced new emission standards for marine e ngines such that older marine equipment will have to be replaced in the future. Current state funding (TERP) already assists in engine retrofits and replacements especially for projects that focu s on harbor craft (tugboat s, ferries, towboats, dredges). Other techniques that could be used to achieve emission reductions could be: shore power, clean fuel, after treatment controls, plug in operations, othe r idling reductions.

PUBLIC COMMENTS: 1) H-GAC reached out to Marine stakeholders to consider consenting to a Memorandum of Understanding/Memorandum of Agreement to reduce emissions- The MOU/MOA did not have to contain any specifi c details about what type of technique will be used to achieve the emission reductions, but just a number of tons per day or year.

a. PoHA and others did not disagree, but w ill require more time than the January 2009 deadline allowed them to devise a MOU/MOA. b. Bracewell & Giuliani asked a clarific ation question about whether marine stakeholders had to come up with a draft MOU by January 2009 or whether marine stakeholders can just come to an agreement to write an MOU by then. 1) H-GAC’s response: In the past, st akeholders just came up with a consensus for an MOU and then hashed out the details after that date to devise the MOU agreement document. 2) H-GAC conducted a discussion to solidify wh ere each segment of the marine industry could reduce emissions.

a. Stevedoring: Can own or lease equipment. The highest emitting equipment: forklifts, cranes, and on-road trucks (whi ch take cargo on the site and also onto highways). b. Voluntary emission reductions could also come from harbor crafts. This can occur naturally through advances in technology, and by other strategies such as the use of a bonnet (device to place over exhaus t to collect and treat emissions). 3) What is each marine stakeholde r doing to reduce emissions?

a. Port of Freeport: It is a landlord port. This port is working on its emissions inventory and is coming up with c ontrol measures for the site. b. Port of Houston: It is a partially land lord port, but also owns equipment. The cruise ships at the port are a big source of pollution, and PoHA offers shore power for them. The bulk carriers ar e also a big source of pollu tion since they can be at PoHA from 2 to 10 days. This port has done its emissions inventory but an MOU but will require a lengthy approval pro cess with the Board of Directors and Transportation Commission. If an MOU is to be passed, this will require separate meetings for approval with each stakeholder before such an agreement can be decided.

c. City of Houston: COH had no comment. d. Port of Galveston: Was not represente d but was anticipated that no emissions inventory had been started. 4) H-GAC suggested that maybe PoHA coul d try an anti-id ling policy again.

a. PoHA responded saying it was extremely hard to enforce except for when the price of gas was high and people would not id le out of financial constraint. At one tim e there was a desire to increase fuel efficiency because gas was so expensive so the no idling policy came into play. However, when gas is cheaper, it’s hard to get the support. 1) H-GAC confirmed by saying that the no idling policy was voluntary.G:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-13 Announcements The next public meeting for the State Implementation Plan is scheduled for January 8, 2008.

ACTION ITEMS: Marine/Port Stakeholders 1) 

### Stakeholders should consult among themse lves to decide on a Memorandum of Agreement or Understanding that they would be able to enter into with H-GAC or TCEQ.



# Industrial Mobile Sources Stakeholders Meeting

December 16, 2008; 

### held at H-GAC office in central Houston

Persons Present: Judy Bigon (ExxonMobil)

Staff Present: Shelley Whitworth (H-GAC), Graciela Lubertin o (H-GAC), Kelli Angelone (H-GAC), Connie Chao (H-GAC), Mary Schuwerk (H-GAC), Ben Finley (H-GAC)

H-GAC Discussion : Emissions Inventory and Control Strategies H-GAC showed the ExxonMobil representative what part of the off-road NOx inventory was concerned with industrial mobile sources, then ex plained the relevant control strategies for offroad, marine, rail, and anti-idling.

PUBLIC COMMENTS: 1) ExxonMobil said they have a switch engine, but don’t know if it has been replaced or retrofitted through TERP. Most of their transport operate s under Union Pacific. 2) ExxonMobil said they have mostly harborcraf t and tankers docking and operating around their pier.

a. They were advised by H-GAC that thos e should be considered for possible VMEPs. 3) ExxonMobil did not know for sure whether thei r forklifts are leased or owned, nor how old they are, or if they have participated using TERP and said they would find out. 4) ExxonMobil asked how much of the 5.87 tons per day shown from industrial mobile sources for 2018 we were hoping to get industr y to reduce because th ey were concerned about cost-effectiveness of reducing emissions of mobile sources when the point source controls were probably more cost-effective.

a. H-GAC replied that the Deer Park mon itor showed a necessary 100 tons per day reduction from the surrounding area to come into compliance according to TCEQ models, so H-GAC is trying to get reductions from any source they are able to. 5) H-GAC asked ExxonMobil to also look at their on-road fleets of tanker trucks for onroad reductions, and at thei r handful of construction e quipment for anti-idling and possible retrofitting/replacement.

a. ExxonMobil replied that the tanker trucks were run by another division of the company and that another contact would have to be supplied for information regarding the trucks.G:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-14 ACTION ITEM: H-GAC 1) HGAC should send to the industrial mobile st akeholders some sample MOAs from the last SIP. 2) H-GAC should look into th e forklift and switch engine cost-effectiveness for stakeholders to see. 3) H-GAC should consult contacts at TXOGA to ensure better participation for this stakeholder group at future meetings.

ACTION ITEM: Industry Groups 1) Industry representatives should look into how many forklifts make up their fleet and if those forklifts had already participated in the TERP program. 2) ExxonMobil should find out what the cost-effec tiveness is for point source controls. 3) Groups should consult among themselves to decide on Memoranda of Agreement or Understanding that they would be able to enter into with HGAC or TCEQ.



# Second Airports/Airlines Stakeholder Meeting January 6, 2009; held at H-GAC office in central Houston

Persons Present: Karl Pepple (COH), Elaine Karn es (SW), Marianne Csaky (Continental), Debayne Yen (Jacobs Consulting), Peter Ogbeide (TCEQ), Walker Williams (TCEQ), Lola Brown (TCEQ), Chris Kite (TCEQ), Jim McKay (TCEQ), Santos Olivarez (TCEQ)

Staff Present: Graciela Lubertino, J. Ben Finley, Mary Schuwerk, Connie Chao, Kelli Angelone

Discussion : Control Strategies and Memoran da of Understanding (MOUs) No airport- or airline-specific control strategies are listed in the State Implementation Plan (SIP) Short List because industry representatives were concerned about the accuracy of the inventory and because industry did not confirm any of the strategies as very feasible. In light of this, staff discussed those strategies previ ously set aside as possibilities fo r MOUs and as a starting point for generation of further possible strategies.

QUESTIONS/ COMMENTS: 1) H-GAC asked industry groups which of the strate gies provided might be feasible, and if none were feasible, were there any that industry representati ves could suggest?

a. Industry groups expressed doubt in their ability to make si gnificant reductions with electrified or alternative fuel ground support equipment (GSE). They said this was because they have made most of the reductions that can be made with electrified GSE by converting most of the GS E as part of the last SIP agreement. Airlines stated that they es timate that most of the equipment left is the equipment that must stay diesel-fueled because el ectric equipment does not have the same pulling power. 2) H-GAC asked to confirm that airports/airlines had reached their emissions reductions from the last MOUs to the Texas Commission on Environmental Quality’s (TCEQ’s) satisfaction. [There had been discussion of this at the la st airports/airlines meeting.]

a. TCEQ and industry representatives confirme d that the airports and airlines had definitely made the reductions they ha d said they would do in the last MOU.G:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-15 3) H-GAC asked industry about the feasibility re duced-idling policies fo r aircraft, airport shuttles, and/or ground support equipment.

a. Airlines representatives said that reduced-idling policies for aircraft is a federal matter and that they have no ability to a ffect that. They also said that airport shuttles would be something that the air port parking lots would be the people to contact for that. Airlines representatives would pref er to focus on the ground support equipment, whose operations th ey have the ability to affect. 4) Industry representatives said th at the rest of the strategies H-GAC had listed were also beyond their control. They wanted to commit to making emissions reductions in order to help the region, but said it would be more help ful to see the revised inventory first, which TCEQ was still assembling.

a. TCEQ was not sure when the document w ould be available, but knew that they were supposed to receive the last of the airport data January 9 th 

### , then would be reviewing the data themselves for the ne xt week or so. The data had to be reinserted into the model January 29 th



### . 5) H-GAC expressed concern that this timeline did not allow staff enough time to view the inventories and work with industry groups on MOUs.

a. TCEQ replied that they were working as fast as they could but they had to be sure everything was in order. 6) Southwest asked what percentage of reductions the region would probably need.

a. H-GAC replied that TCEQ had told them at least 25%. b. TCEQ staff present had not heard this statistic and could not confirm. 7) H-GAC asked industry groups abou t possible gate electrification.

a. Industry groups said that was a possibility for MOU.

ACTION ITEMS: 1) Airports should get their invent ory information together and get the last part to TCEQ for review. 2) TCEQ should distribute copies of the airports /airlines inventory as soon as possible. 3) Industry groups should be ready to consider the inventory an d look into what strategies they might be able to make. 4) Tentative next meeting date was set for February 2, 2009 at 10:30am.



# Second Public Meeting January 8, 2009; held at H-GAC office in central Houston

Persons Present: Brandt Mannchen (HSC), Chuck Moss (Oxid L. P.), Tricia Clark (Skaugen), Susan Sharp (Emisstar), Shareen Larmond (WGMA), James Patterson (Fort Bend County), Catarina Cron (Harris County Judge), Mary Shine (Brazori a County), Lanie Platt (DOW-Freeport), Ken Gathright (PoHA), Dana Blume (PoHA), Russell Lehrman, Marcie Anderson, Elvia Cardinal (TxDOT), Charles Airiohoudion (TxDOT), Ma donna Lorraine (TxDOT), Charles Stillman (Texas Climate Emergency), Matthew Tejada (GHASP), Donna Huff (TCEQ), Theresa Pella (TCEQ), Lola Brown (TCEQ), Helen Vollmer (Vollm er PR), Lori Martin (Vollmer PR), Chris Lindjhem (Environ)G:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-16 Staff Present: Shelley Whitworth, Graciela Lubertino, Kelli An gelone, Connie Chao, Mary Schuwerk, J. Ben Finley, Andrew DeCandis, Gina Mitteco, Veronica Baxter-Lamb, Jeff Taebel, Alan Clark, Steve Howard

H-GAC Presentation : Overview of SIP Process a nd Control Strategy Discussion H-GAC reviewed the health effects and costs of air pollution, progress th at had been made by HGAC in cooperation with regional stakeholders, the 2005-2018 projections for emissions, possible local government measures, and the on -road and off-road control strategies.

PUBLIC COMMENTS: 1) Brandt Mannchen, Houston- chapter Sierra Club (HSC)

a. HSC appreciates that H-GAC recognized th at small emission reductions when put together can make for effective control measures. b. HSC would still like to see the EPA crit eria ‘PQSE’ defined in the Short List document.

c. For control measure, “Public Agency Clean Fleet Programs”, HSC would like companies to commit to the lowest-emission vehicles available in California. d. For control measures #63-66, HSC is disappoi nted that adequate law enforcement is not emphasized because speed enfor cement would be good for the environment and for safety.

e. HSC recommends that H-GAC monitor emi ssions as vehicles are going down the road [a study] because they may show very different results than Mobile6. f. They also recommend studies to monitor emissions inside vehicles for health reasons. There may be higher doses of emi ssions inside vehicles than we know.

g. As for control measure #13, HSC does not favor this one and would like to see dedicated trucking lanes on highways as they have in many other states. h. Regarding measures #19 and #139 which re fer to smoking vehicles, HSC finds these contradictory and would like to s ee a program which increased compliance because even with an estimated 4% of vehicles out of compliance, that equals 100,000 smoking vehicles on the road. i. HSC is disappointed that #39-62 do not include employer trip-reduction programs, which should be some ki nd of voluntary control measure. j. HSC supports control measure #92, rail expansion, mass transit projects, #124, #5a, #5b, and #45. k. HSC expressed concern about TERP inform ation and would like to have more facts about the penetration of the program into industrial sectors so that the public would be better equipped to d ecide what should be done.

2) Russell Lehrman, resident of Houston, northeast of downtown

a. Mr. Lehrman was concerned that #60, trav el-based taxes, would not apply to idling vehicles, which he thought it shoul d. He thought it might be a good idea to have idling-based taxes because of the 65 ve hicles at the dairy plant near his home which idle 24 hours a day. b. Mr. Lehrman supports limits on idling heavy-duty vehicles.

c. Mr. Lehrman mentioned that the dairy plan t near his home does have one or two APUs, but it is still expandi ng the ‘parking lot’, so it is not having enough of an effect.G:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-17 d. Mr. Lehrman and his friend, Ms. Anderson, have met with city council and the city attorney, and many residents have fallen ill from the pollution. Doctors have told many people that they should not spend time immediately outside their homes due to the health risks.

ACTION ITEM: H-GAC 1) HGAC will continue to integrate comments into the short list.

ACTION ITEM: Public 1) Public should continue to review and comment on draft Short List documents.



# Local Government Stakeholders Meeting
January 27, 2009; 

### held at H-GAC office in central Houston

Persons Present: Patrick Buzbee (Montgomery County), Bob Allen (Harris County), Cristina Gossett (City of Deer Park), Snehal Patel (Harri s County Attorney’s Office), Nick Finan (City of Texas City), Charles Dean (Harris County), Perri D’Ar mond (Greater Fort Bend EDC), Don Brandon (Chambers County), DeWight Dopslauf (Harri s County Purchasing), Ann Werlein (Fort Bend County), Ken Gathright (Port of Houston Author ity), Stacie Henderson (City of Sugar Land), Luis Rodriguez (City of Sugar Land), Dolly Arons (City of S horeacres), Kerry Collins-Leggett (City of Alvin), Gail Miller (H arris County Precinct 2 Commissi oner Sylvia Garcia’s Office), Larry Buehler (City of Alvin), Jim Wigihton (Brazo ria County District Attorney’s Office), Cindy Sumrall (Fort Bend County Transit) , Catarina Cron (Harris County), Scott Tuma (City of League City), Shaun Light (City of Houston, Large-Po sition 3 Councilwoman Melissa Noriega’s Office)

Staff Present: Steve Howard, Jeff Taebel, Shelley Whitworth , Graciela Lubertino, Kelli Angelone, Connie Chao, Mary Schuwerk, J. Ben Finley, Andrew DeCandis, Shaida Dezfuli, Ilyas Choudry, Veronica Baxter-Lamb, Gina Mitteco, Meredith Dang, Jerry Bobo, Ashley K. Wadick (TCEQ), Cynthia Williams (TCEQ), Lola Brown (TCEQ), Theo Kosub (TCEQ)

Purpose of Meeting : Workshop to provide tools for local government on how to reduce NOx emissions

H-GAC Presentation : Overview of SIP Process a nd Voluntary Control Strategies Shelley Whitworth, H-GAC Air Quality Program Manager, described the State Implementation Plan and gave an overview of the process. Th e purpose is to reduce emi ssions through state and local controls. Nitrogen oxide (NOx) and Volatile Organic Compounds (VOC) levels were estimated in a TCEQ modeling emissions inve ntory in 2005 and predicted for 2018. Currently, 8-hour ozone design values have a downward tre nd which means that the ozone level is slowly decreasing in the HGB region. However, more on-road and non-road reductions must happen to
continue the downward ozone level trend. Govern ment agencies are encouraged to take more voluntary measures to reduce emissions. Recomm ended on-road voluntary control measures are: Alternative commuting, regional traffic flow impr ovement, and vehicle retrofit and replacement. Recommended non-road voluntary control measur es are: Engine replacement and retrofitG:\HGAC\Reports\Final_051 009\Appendix C_051009.doc 

### C-18 programs, government construction incentives, lim its on construction idling, promoting cleaner garden and lawn equipment. Some local actions that government can take are to support on-roadand non-road voluntary control measures, enact ordinances promoting livable centers and multiuse developments, support increased transit servi ce, expand the use of natural gas in vehicle fleets, add bicycle and pedestrian control strate gies, increase fleet tur nover for newer vehicles, encourage practices which reduce emissions, and increase public education about air quality issues. H-GAC encourages the signing of Memoranda of Agreement (MOAs) to formalize
emission reduction commitments to the SIP. Local SIP commitments must be submitted to TCEQ no later than February 20, 2009. Finalized MOA documents must be submitted to TCEQ by April 2009.

H-GAC Open Session to Explore Different Voluntary Measures: Twenty minutes were taken to have local government staff visit stations around the room and ask questions about the different voluntary measures available to them. Th e stations were the foll owing: Fleet Turnover, Support Commute Solutions, Airport Control Strate gies, Non-Road Mobile Control Strategies, Traffic Signal Strategies, Idle Reduction Strategies, Livable Cities/Bicycle /Pedestrian Program, All On-Road Funding Available: Congestion Mitigation & Air Quality (CMAQ), TERP funds, Supplemental Environmental Project (SEP), Local Initiative Project (LIP), Surface Transportation Program Metro Mobility (STPMM), Surface Transportation Project Enhancements (STPE), and Local Funds. Th e group came back afterwards for a group
discussion.

PUBLIC COMMENT: A question was asked by Dolly Arons of the City of Shoreacres: Are there other funds besides the TERP program that may be available for local government use? Shelley Whitworth answered it saying that TERP was the main funding available for now although there were plans to expand the availabili ty of SEP funds to include local government
fleets.

MEETING ADJOURNED: 3 pm

ACTION ITEM: Local governments work to decide on voluntary control measures to commit to, and sign an MOA formalizing the commitment to reduce emissions in their respective areas.

### APPENDIX D

Written Comments from Stakeholders and their Respective Responses Regarding Short List Control StrategiesG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-1 The comment periods for the Draft On-Road Contro l Strategy List and th e Draft Non-Road Short List Control Strategy List was Monday, December 8, 2008 to Thursday, January 15, 2009. Written comments were received by:

Mail: Transportation Department, Air Qual ity Section, Houston-Galveston Area Council P.O. Box 22777 Houston, Texas 77227-2777 E-mail: airquality@h-gac.com Fax: (713) 993-4508

H-GAC received a total of 10 written comments. H-GAC has separated the written comments into two sections:

1. Jim Blocher 2. Troy Miller 3. Leo Waltz 4. Peter Wang 5. Sierra Club 6. Charles Stillman 7. Carol Caul 8. Port of Houston Authority 9. Smith Electric Vehicles 10. Harris County Texas

Each comment received is shown in its entiret y. Each comment is followed by the response given.G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-2 1.1 Comment from Jim Blocher

From: Jim Blocher [jimblocher@earthlink.net] Sent: Monday, December 08, 2008 8:57 PM To: Air Quality Study Subject: use the Pickens plan

I agree with T. Boone Pickens id ea that in the short run only Natural Gas will solve our energy and pollution problems. For the next ten years or so I s uggest we revive the CNG fueled vehicles which all of the Big 3 used to manufacture. I live in Freeport, Texas and have purchased a Natural Gas Vehicle and Fuelmaker home applian ce refueling compressor at some considerable expense. The City of Lake Jack son nearby has a fleet of NGV cars and trucks which it fuels from its own station. If they could receive a grant to install a retail CNG fue ling pump I believe it would pay for itself eventually. During this last pe riod of high gasoline pri ces I was still fueling my car for less that $1.50 per GGE, including the el ectricity needed to pump the Natural Gas. This is a long term investment for me as a commuter to Houston, but I believe others would consider NGV’s if there were more fueling statio ns available. At present, there are two Clean Energy CNG stations in Houston that I am aware of.

Thanks for considering my suggestion, Jim BlocherG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-3 1.1 Response to Jim Blocher



### February 13, 2009

Dear Mr. Blocher:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP).

Your question concerned a grant for the installation of a retail Natural Gas Vehicle fueling station in the City of Lake Jackson. We encourage interested citizens to seek private or public agencies in applyi ng for a grant(s) under the Clean Vehicles
p rogram. The Houston-Galveston Area Council’s Clean Vehicles program is a fuel/technology-neutral grant program that funds cost-effective engine retrofit, repower, replacement, conversion (to al ternative fuels), or the establ ishment of publicly accessible alternative fuel infrastructure. You may visit www.Houston-cleancities.org for additional information.

You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx

Sincerely,

Shelley Whitworth Air Quality Program ManagerG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-4 2.1 Comment from Troy Miller

From: troy miller [mailto:billyt04@yahoo.com] Sent: Monday, December 08, 2008 4:43 PM To: Spain, Mary Subject: comment on upcoming meeting

After reading the Brazosport Facts paper online I had to reply. Your office is requesting comments for insight. Here goes... I had worked in the brazosport area for afew years doing environmental monitoring at Dow, Testing process equipment for emissions, inspections on RCRA lines through out Dow Freeport, then after becoming a master tech for my firm, I became a manager of change. Then ended my tour doing projects at Dow. I have to ask, HOW CAN I SPEND TWO YEARS DOING WHAT I DID, S EEN WHAT I SEEN, AND NOONE ELS HAS. I remember one day in early spring 04, I was working aproject, and was looking for a tower that had been monitored the month before, come to find out the tower had been gone for 3+years! Now tell me how it was monitored the month before? EAI who does the monitoring at dow hushed me up. At the end of each year Do w has over 500.000 componets which must be monitored right! Not all were never found, and EAI swept it under the mat. You may have a 3"valve beside the buc-ees store on hwy 332, do you think it was monitored? WELL NOPE! If your office really wants to help, here is how you can start. During the last three weeks of monitoring for 4Q08 at Dow, Send ateam to follow all the 10 or so tech's wh ile they monitor all the site DTM'S and ALL annuals. And when you do you will do Three things. One: you will wonder how in hell they ever got monitored in the first place thats if they are even found, Two; Lord we have LEAKS, And last you will see the people of brazosport are in danager.

Thank YouG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-5 2.2 Response to Troy Miller



### February 13, 2009

To: billyt04@yahoo.com

Dear Mr. Miller:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP). Si nce your comments deal with the monitoring of point source emissions at indu strial plants, a subject not directly related to the mobile source SIP process, your comments have be en forwarded to the Texas Commission on Environmental Quality for thei r review and response.

You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx

Sincerely,

Shelley Whitworth Air Quality Program ManagerG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-6 3.1 Comment from Leo Waltz

From: Leo Waltz [Leo.Waltz@prodigy.net] Sent: Thursday, December 11, 2008 12:36 PM To: Air Quality Study Subject: Industrial airborne dust

After seeing the article in the Chronicle, I visited the web address provided, but the complexity of that web site in trying to find anyt hing led me to write this email instead.

Also I realize that the concerns are mostly about ozone, but one item often overlooked is dust that emanates from sand, gravel and concrete companies as well as other industries. A good example is near where I live. Sometimes the airb orne dust is so heavy fr om the plant on State Hwy 3 in Webster (between NASA Parkway and Me dical Center Blvd.) that it appears to be a heavy fog. Yet it is obvious where it is co ming from. Airborne dust particles can cause breathing problems among some people.

I would like to see some controls on airborne dust from industrial pl ants that are near residential areas. These are typical questions I would like addressed: If there are dust particle standards, are there any ordinances to uphold thos e standards? If there are ordi nances, is there any enforcement of them?

The plant I referenced also has high noise levels at many hours, but sin ce no one controls noise pollution except an unenforced city ordinance in Webs ter, then that aspect of an industrial plant is uncontrolled except maybe for some OSHA hear ing protection rules for the employees at the plant.

Thanks for reading.

Leo Waltz P.O. Box 580037 Houston, TX 77258-0037 281-316-2255G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-7 3.2 Response to Leo Waltz



### February 13, 2009

Mr. Leo Waltz P.O. Box 580037 Houston, Texas 77258-0037

Dear Mr. Waltz:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP). Sin ce your comments deal w ith airborne dust at industrial plants, a subject not directly relate d to the mobile source SIP process, your comments have been forwarded to the Texa s Commission on Environmental Quality for their review and response.

You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/ai rquality/sip/default.aspx

Sincerely,

Shelley Whitworth Air Quality Program ManagerG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-8 4.1 Comment from Peter Wang

From: Peter Wang [pwang01@gmail.com] Sent: Saturday, December 27, 2008 6:59 PM To: Air Quality Study; Mergo, Ch eryl; BikeHouston Advisors Subject: Comment on bicycle-pedestrian portion of Mobile Source Control Strategies document

I agree with the methodology employed on pages 116 - 119 of the Environ Corp. "Evaluation of Mobile Source Control Strategies Document" (by Ms. Barbara Joy) for evaluating the cost per ton of ozone reduction for bicycle-pedestrian mode s, but I heartily disa gree with the choice of data inputs, and therefore with the conclusions. Basically, I thi nk the results are meaningless. The $390,000 per ton figure should be replaced by $12,200 per ton.

The investigator takes $96 million in bike-ped pr ojects as the numerator and divides that dollar amount by the estimated tonnage of ozone eliminated. The problem with this large numerator, however, is that the local bicyc ling community has had absolutely no input into this bicycle plan, and there has been zero buy-in to the alleged commuting utility of this plan which has been assumed by the investigator. If you take a look at th e cited plan, you will see that the bulk of it is recreational in nature.

The consultant is also caught in the mental trap that, like ca rs, all you need to do is build infrastructure and it will get used. That is not the situ ation with bikes, because of suppressive social and cultural factors which could be much less expensive to change than building new infrastructure. What am I referring to? I am referring to governments:

• actually actively encouraging people to ride bikes on the roads (which would be a 180 degree shift from the curr ent Harris County stance)

• enforcing speed limits, and lowe ring speed limits generally

• enforcing drunk driving and distracted driving laws

• prosecuting road-rage and assaults against bicyclists

• making use of the corps of dozens of low-cost (or in some cases free volunteer) League of American Bicyclists Cycling Instructors in the Houston area

• enforcing laws that cyclists break that enda nger cyclists (running stops signs and lights, and riding in the dark without lig hts, and riding ag ainst traffic)

What is the cost of these types of actions? Th e "encouraging" actions ar e almost free. Strongly enforcing speed limits, DWI, and distracted dr iving should be done anyway, and those costs should not be borne by cyclists, but generally. Th e Vehicular Assault team at the Harris County DA's office could be beefed up. The education component could be quite low cost, since the instructors will work for little money mostly for the joy of teaching, but they need to be made part of an official adult bicy cle educational program that governments widely promote to the public. Writing tickets for traffic vi olations by cyclists could be re venue neutral. I think we're not talking about $96 million, honestly I am guessing at a multi-year program cost of maybe $3 million, in my estimation, which would lead to ozone reduction costing $12,200 per ton.... not $390,000 per ton.

I am writing this letter as an individual, but my affiliations are listed below.G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-9 Thank you.

--

Sincerely,

Peter Wang

League of American Bicyclist Instructor Board Member, Citizens' Transportation Coalition Advisor to BikeHoustonG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-10 4.1 Response to Peter Wang



### February 13, 2009

To: pwang01@gmail.com

Dear Mr. Wang:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP). Y our comments about the cost effectiveness fo r bicycle-pedestrian projects are greatly appreci ated. Our consultant’s figures were taken from data in the Regional Transportation Plan for our region, based on the project cost for building additional bike and pedestrian projec ts We agree with you that additional education and encouragement as well as additio nal enforcement of safety rules already in

p lace will promote increased bicycle and pedestrian activities and b ring further emissio n reductions due to increased usage of alr eady existing facilities. Unfortunately, the measures that you mention in your letter do not meet all of the EPA criteria necessary to be included in the SIP (permanent, surplus, quantifiable and enforc eable) and were not able to be added to the short list of control measures.

We do value your input a nd we encourage you and the whole bike community to become involve in our Tr ansportation Improvement Pr ogram (TIP) and Regional Transportation Plan (RTP) which will be updated this year. Please go to 2035plan.org for more information.

You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/

.

Sincerely,

Shelley Whitworth Air Quality Program ManagerG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-11 5.1 Comment from Sierra Club



# SIERRA

CLUB

FOUNDED 1892

January 8, 2009

Mr. Alan Clark Transportation Department Air Quality Section Houston-Galveston Area Council P.O. Box 22777 Houston. Texas 77227

Dear Alan, 

### Houston Regional Group
P. 0. Box 3021 Houston, Texas 77253-3021 713-895-9309 http:/ /texas.sierraclub.org/houston/

Enclosed are the comments of the Houston Regional Group and Lone Star Chapter of the Sierra Club (Sierra Club) regarding input for the draft Evaluation of Mobile Source Control Strategies for the Houston-Galveston-Brazoria (HGB) State Implementation Plan (SIP), With Detailed Strategies by prepared by Environ for the Houston-Galveston Area Council (HGAC), December 5, 2008.

1) Page 1-1, in the first paragraph of "1. Background and Purpose of Study", the document states"

... in an attempt to determine a set of strategies to achieve emission reductions of volatile organic compounds and nitrogen oxides in the HGB non-attainment area" but in the first paragraph of "Purpose of Study" the document states "The primary objective of the study was to identify and evaluate feasible control measures to reduce NOx (nitrogen oxide) emissions". Which
statement is correct? The document should be modified to ensure that it clearly
states to the public what its purpose is.

2) Page 2-1, Refining Initial Master List, the document states "... many

measures that would alone have minimal effect on emissions were easily recognized as being naturally a part of larger measures". The Sierra Club appreciates this recognition. The Sierra Club requests that HGAC clearly show for any control measure (CM) that it recommends for adoption where specifically the CM has "minimal effects on emissions" but is "naturally a part of larger measures" is incorporated into other larger CMs so that the public can review,
comment on, and understand the full implications and complexity of CMs that are recommended by HGAC for adoption.

3) Page 2-1, Evaluating Feasibility and Potential for Emission Reductions, the document says"

... it was not feasible to model each of the individual control measures". Why would modeling be used in the first place? It would seem that the most likely need is to know the approximate population of a certain type of on-road or off-road vehicle or equipment and then the control efficiency of a CM

"When we tty to pick out anything by itself, we fmd it hitched to eve !}'thing else in the universe." jolm 

## A["ir

Printed on 100% Kenai tree free paperG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-12 (percent reduction) so that a calculation can be made to see how many tons/day

or year are gained by a CM. Then estimate the cost per ton of air pollution reduced and list, by cost and or emissions reduced, the different CMs. Modeling has already been done by HGAC to determine what the on-road and off-road budgets are for volatile organic compounds (VOC) and NOx for the SIP.

4) Page 3-1, Qualitative Review of Master List, the document lists four criteria which were used as the primary qualifiers for the SIP CM. These include permanent, quantifiable, surplus, and enforceable. However, these criteria are not defined so the public and decision-makers can review, comment on, and understand the proposal. These criteria should be defined.

In addition, the document states that "ENVIRON team made a judgment as to whether a program could be defined to satisfy these criteria". This is confusing. ENVIRON talks about a CM in one sentence and then a program in another sentence. A program is not necessarily a CM or vice versa. Also ENVIRON does not state what process was used to make a judgment. The public and decision-makers need to know this information so they can review, comment on, and understand the proposal. The process used to "make a judgment" should be stated clearly in this document.

Finally, the document states that voluntary commitments "may not strictly meet all of the criteria listed above" and may be considered for inclusion in a SIP "if defined and funded properly". What are these exceptions, how were they judged, which CMs had to use this exception, and why? The public and decision-makers need to know this information so they can review, comment on, and understand the proposal.

5) Page 4-1, 4. Summary of Measures, the document states "Our initial list therefore marks those measures that qualify as emission reduction programs under a likely EPA review with "+"to denote which pollutant would be affected by the measure". As stated in 4) above, the actual process with definitions is not provided so the public and decision-makers can review, comment on, and understand the proposal. Was "best professional judgment" used and if so how

was this type of evaluation used and what criteria were used for its implementation?

6) Pages 4-2 through 4-22, Table 4-1, On-road vehicle emission reduction
measures, the following CMs are ones the Sierra Club prefers or has questions about:

1. #1 Bicycle and pedestrian action groups. The Sierra Club supports this CM.

2. #2 Clean Technical Coalition. The Sierra Club supports this CM.

2G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-13 3. #3 Private sector clean fuel fleets. There needs to be adequate recordkeeping and on-site monitoring to ensure that commitments are kept. This is one problem with voluntary programs. Somehow the Texas Commission on Environmental Quality (TCEQ) has to make sure that the commitments are kept

over the long-term and not discarded or undone. Presently HGAC has a person who is monitoring onsite but if we are to get sufficient participation from all voluntary CMs then a greater monitoring effort will be required.

4. #6 Public agency clean fleet program. The Sierra Club prefers that public agencies/private companies commit to buy the lowest emission vehicles that are available in California (internal combustion or other technologies) so that a significant emission reduction over usual vehicle attrition occurs.

The Sierra Club expresses its disappointment that more law enforcement is not adequately stressed in the CMs (#63-66). Existing, against-traffic or close to free-flow conditions on Houston freeways or other roads, result in actual operating speeds that are 10-20 mph faster than posted speeds. For instance,

on Interstate 610 South Loop, going against traffic, cars frequently travel 70-80 mph versus the 60 mph speed limit.

Traveling at these speeds increases NOx emissions significantly. The TCEQ has indicated that NOx reductions are more sought after than VOC reductions. This increase in NOx emissions is not modeled by MOBILE because the model
cannot model NOx emissions at higher speeds. More police on existing freeways and roads (including feeder streets) or more time allocated for existing police to enforce speed laws makes a lot of sense and will result in less property damage, injury, and death.

The Sierra Club is disappointed that this document does not discuss the need to monitor air emissions inside vehicles during travel and the need to monitor tailpipe emissions when vehicles are actually being driven. While the Sierra Club realizes these techniques may more appropriately come under the heading of research or emissions inventory they are key for educating the public why air emissions from vehicles need to be reduced since they indicate much greater air emission generation and greater potential for health effects due to greater exposure. The Sierra Club urges HGAC and TCEQ to support and seek funding for research in these two key areas.

5. #7 Electric Vehicles. The Sierra Club prefers that public agencies/private companies commit to buy electric vehicles that are available in California so that

a significant emission reduction over usual vehicle attrition occurs.

6. #11 Cleaner diesel fuel. The concern the Sierra Club has with this proposal is how to get many fueling stations to sell cleaner diesel fuel which will cost more.

3G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-14 7. #12 Air quality information with driver training. This CM should be implemented as a matter of course so people will get the connections between air pollution health costs and their personal use of motor vehicles.

8. #13 Divert trucks from non-attainment areas. The Sierra Club does not favor this CM. We are concerned that the CM of dedicated truck lanes is not included or discussed. By congregating trucks together the flow of traffic for other vehicles should be improved and therefore a reduction in fuel use and air pollution gained.

9. #15 Permit HOV lane use by qualifying low emission vehicles (LEV); #17 Single Occupant Vehicles (SOV) access to HOV and transit stations; #18 Managed lanes to accommodate some single occupant vehicles in HOV lanes; #39 Preferential parking for HOV lane users and ride sharers; Fee
spaces, reserved spaces; #40 Preferential parking for HOV lane users and ride sharers; Rate reduction; #41 Preferential parking for HOV lane users and ride sharers; Metered spaces; #42 Free parking at park-and-ride facilities for HOV lane and transit users. The Sierra Club does not support these CMs. These CMs dilute the impacts that High Occupant Vehicle (HOV) lanes have, both in terms of emissions and in terms of public acceptance of using

a travel mode other than one person/one vehicle travel.

Metro has already proposed turning most HOV lanes into High Occupant Toll (HOT) lanes during certain hours of the day. The Sierra Club believes this is an erosion of the purpose of HOV lanes which is to have other than one person/one vehicle travel mode accommodated. If lanes remain HOV then CMs 39-42 would be appropriate but Metro appears certain to turn HOV lanes into HOT lanes which rewards SOVs in HOV lanes and does not make public policy sense.

10. #19 Focus on finding and penalizing extreme high emitters and #139, Enhanced enforcement for Smoking Vehicles Program

- vehicle impounding for violators (like Dallas Emissions enforcement Pilot Program). These two CMs appear to contradict each other. #19 states "Questionable regarding excess modeled reductions (1/M modeled at 96% compliance) but could produce real reductions".

#139 states "May reduce number of vehicles avoiding 1/M test. Real versus modeled reductions issue. NCTCOG estimates 1/M compliance at around 80% not 96% as modeled". This gives credence to implementing CM #19. In addition, even with a 4% non-compliance rate this is a lot of vehicles. For instance, if we assume conservatively that the HGAC area has 5 million people, and has one vehicle/two people, or 2.5 million vehicles, then 4% of 2.5 million is 100,000 vehicles. Twenty percent of 2.5 million vehicles is 500,000 vehicles. These two figures are very large and document that better 1/M enforcement is
necessary and should be a CM that is proposed and implemented.

4G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-15 11. #20 Rewards for reporting smoking or high emitting vehicles. This CM
states "see measure 163" but there is no CM 163. There is an old CM 163 but there is no new CM 163. The Sierra Club supports this CM

12. #21 Scrappage/buy-back plan. The Sierra Club supports increasing the number of people that can use this CM.

13. #22 Dedicate funding for school bus replacement. The Sierra Club supports this CM since it reduces children's air pollution exposure.

14. #23 Non-profit organization assistance program. The Sierra Club is confused about this program. The "Description" states "to ensure high-emitting donation vehicles are not returned to the road and reused in an "as is" condition". The Sierra Club was under the impression that vehicles that are in such programs are not returned to the road and reused in an "as is" condition. Any
program that allows high emitting vehicles to be resold in "as is" condition should be changed or shutdown. Programs with this type of loophole do not contribute to air emission reductions.

15. #24 Enforce smoking vehicle reports and require repairs. The Sierra Club supports this CM.

16. #26 Ban sale of high-emitting vehicles. The Sierra Club supports this CM.

17. #39-62 the Sierra Club urges HGAC to list employer trip reduction programs (ETRPs) for large employers, both public and private, as a CM. The Clean Air Act at one time mandated implementation of ETRPs but unfortunately poor public and private leadership led to the removal of this requirement. Now, instead of having a reduced level of traffic congestion and air emissions and increased understanding by the public, we have greater problems. TCEQ, HGAC, and political bodies in the Houston area need to get a commitment from public and private sectors to implement a voluntary ETRP so we can get better acceptance of other than the one person/one vehicle travel mode.

18. #46 Provide parking at all major transit stations. The Sierra Club is concerned about the level of parking fees currently charge by Metro for its rail. In the past year parking costs have gone from $1.00 to $2.50. At some point this increase in parking, without an increase in benefits, will result in less use of rail. This would cause an increase in air pollution.

The problem of increased parking fees or fees for rider-ship should be included in
any analysis regarding CMs that are dependent on parking for their implementation. This may be what happens when privatization of parking occurs for public transit facilities.

5G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-16 19. #73 Daycare and other services. This CM states "Many employers already provide". This statement appears to serve an effort to discourage the consideration of this CM. Most employers do not provide daycare. What does
many mean? Define it in percentage. The Sierra Club believes the percentage is low.

20. #78 Emphasis on major route traffic signalization; through route traffic platooning. What does "through route traffic platooning" mean? The public and decision-makers need this information so they can review, comment on, and understand the proposal.

21. #80 Adaptive traffic signals and signal timing. What does this mean? The public and decision-makers need this information so they can review,
comment on, and understand the proposal.

22. #89 Guaranteed ride home. The Sierra Club supports this CM.

23. #92 Electrify bus routes. The Sierra Club supports this CM.

24. #99 Accelerate rail expansion. The Sierra Club supports this CM. People need viable alternatives to the one person/one vehicle travel mode.

25. #100 Commuter Rail. The Sierra Club supports this CM. People need viable alternatives to the one person/one vehicle travel mode.

26. #101 High-speed Rail. The Sierra Club supports this CM. People need viable alternatives to the one person/one vehicle travel mode.

27. #102 Free Circulator service to major generators. The Sierra Club supports this CM. People need viable alternatives to the one person/one vehicle travel mode.

28. #106 Mandatory or voluntary compressed work week. The Sierra Club supports this CM.

29. #109 Purchase vans for vanpools. The Sierra Club supports this CM. People need viable alternatives to the one person/one vehicle travel mode.

30. #110 Mandate or encourage vanpooling and carpooling. The Sierra Club supports this CM. People need viable alternatives to the one person/one vehicle travel mode.

31. #121 Car Sharing Programs (Fiexcar). Rice University has a car sharing
program that HGAC should look at as a possible model for Houston.

6G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-17 

# ..

32. #124 If the California Low Emitting Vehicle Program is adopted and only LEV certified, gasoline vehicles are for sale in Texas, then mandated fleets should have to purchase the ULEV alternative fuel version of the same vehicle rather than the gasoline version. The Sierra Club supports this CM.

33. #125 Adopt California standards for vehicle emission rates. The Sierra Club supports this CM.

34. #126 Limitation on idling of heavy-duty vehicles. The Sierra Club supports this CM.

35. #130 Addition of HDGV28 weight class vehicles to inspection and maintenance program. The Sierra Club supports this CM.

36. #137 Encourage/Mandate Livable Centers. The Sierra Club supports this CM.

37. #139 Enhanced enforcement for Smoking Vehicles Program -vehicle impounding for violators (like Dallas Emissions Enforcement Pilot Program. The Sierra Club supports this CM.

38. #145 Increased use of hybrid buses

. . The Sierra Club supports this CM. People need viable alternatives to the one person/one vehicle travel mode.

39. #150 Accelerate development and construction of mass transit projects. The Sierra Club supports this CM. People need viable alternatives to the one person/one vehicle travel mode.

7) Pages 4-22 through 4-26, Table 4-1, Non-road vehicle emission reduction
measures, the following CMs are ones the Sierra Club prefers or has questions about:

1. #Sa Enhanced Texas Emission Reduction Program (TERP) and #5b Extend TERP to 2018. The Sierra Club supports this CM. The Sierra Club continues to be concerned because we do not understand, and neither does the public, about the penetration that each Texas Emissions Reduction Program (TERP) CM or CMs that HGAC might be responsible for, has had for the total population of any particular on-road or non-road vehicle or equipment and the commensurate NOx and or VOC air pollution reductions that have been made.

This information is simple and basic but we have never seen it presented to the public at a mobile source CM public meeting or hearing. Without knowing what has already occurred and how much is left to be controlled it is difficult to know what one supports. The public and decision-makers need this information so they can review, comment on, and understand the proposal.

7G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-18 2. #10 Limitations on idling of heavy-duty construction equipment. The Sierra Club supports this CM.

3. #11 Water injection for diesel engines; #12 Alternative-fueled equipment for all equipment types; #13 Alternative fuel heavy-duty equipment; #14 Lean NOx catalyst; #15 Early introduction of low-NOx engines; and Selective catalytic reduction (SCR). The Sierra Club supports these CMs.

4. #21 Lawnmower exchange; Trade in old gas powered equipment for discounts on zero emission models. The Sierra Club supports this CM.

5. #31 Accelerated purchase of Tier 2, 3, and 4 locomotive engines or remanufactured existing locomotives. The Sierra Club supports this CM.

6. #33 Efficiency improvements on In-Use Class i Rail Equipment (Ri i ). The Sierra Club supports this CM.

7. #35 Portable engine fleet turnover. The Sierra Club supports this CM.

8. #36A Low Sulfur Fuel for Marine Vessel Main and Auxiliary engine. The Sierra Club supports this CM.

9. #368 Harbor Craft Fleet Management. The Sierra Club supports this CM.

10. #37 Cargo Handling Equipment Fleet Management. The Sierra Club supports this CM.

11. #39 Provide full funding for the National Retrofit Program. The Sierra Club supports this CM.

12. #44 Provide cooperative grant assistance to encourage small companies (less than 20 employees) who do not have the resources to manage grants alone to apply for TERP. The Sierra Club supports this CM.

13. #45 Development of a Port of Houston Clean Air Action Plan that seeks
to minimize emissions from ships, cargo handling equipment, on-road drayage trucks, and port-related rail. The Sierra Club supports this CM.

8) 5. Quantified Evaluation of Measures, Tables 5-1 and 5-2, the Sierra Club is disappointed that all CMs were not quantified. By not quantifying all CMs HGAC withholds important information from the public and decision-makers. Without emission reduction potential and cost effectiveness information the public and decision-makers cannot review, comment on, and understand the proposal.

8G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-19 

# - 

# . '

The Sierra Club is disappointed that more CMs did not make it onto Tables 5-1 and 5-2. In particular, the Sierra Club does not understand how #124 If the California Low Emitting Vehicle Program is adopted and only LEV certified, gasoline vehicles are for sale in Texas, then mandated fleets should have to purchase the ULEV alternative fuel version of the same vehicle rather than the gasoline version was not included. This CM would reduce air emissions tremendously from vehicles more quickly than almost any other CM. The comments in this Sierra Club letter list additional CMs that should be on these tables and their emission reduction potential and cost effectiveness should be calculated and provided for public review, comment, and understanding.

9) 5. Quantified Evaluation of Measures, Table 5-1, #39 Preferential parking for HOV lane users and ride sharers; Free spaces, reserved spaces, Metro has proposed turning all HOV lanes to HOT lanes. This program could reward those who pay a toll and still drive their SOV. This would defeat the purpose of the CM. The Sierra Club does not favor this CM.

1 0) 5. Quantified Evaluation of Measures, Table 5-1, #57 Congestion pricing for major activity centers, #58 Pay-As-You-Drive Insurance (per-mile), #59 Local or regional fuel taxes, and #60 Vehicle miles traveled

- based taxes, the Sierra Club has several questions about these CMs. How will those who are in lower socioeconomic areas afford to pay? Will miles driven outside the nonattainment area count? Will it matter if most of the driving occurs on the weekend? The Sierra Club is concerned that these CMs are not the best to implement.

The Sierra Club appreciates this opportunity to comment. Thank you.

Sincerely, 

# {l J1!1 / j

Brandt Mannchen 

# V**-~-/** f

# ~ Air Quality Issue Chair Lone Star Chapter of the Sierra Club Chair, Air Quality Committee Houston Regional Group of the Sierra Club 5431 Carew Houston, Texas 77096 713-664-5962 brandtshnfbt@juno.com

9G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-20 5.2 Response to Sierra Club

February 17, 2009

Mr. Brandt Mannchen Lone Star Chapter of the Sierra Club Houston Regional Group P.O. Box 3021 Houston, TX 77253-3021

Dear Mr. Mannchen:

Thank you for your comments regarding the 2006 and 2008 mobile source Control Measures for the Houston-Galveston-Brazoria 8-Hour Ozone St ate Implementation Plan (SIP). The Texas Commission on Environmental Quality (TCEQ) a nd H-GAC continue to examine a wide range of voluntary control measures. Additionally, your letter commented specifically on sections of the report as well as specific control measures. Responses to each of these comments follow:

1) Page 1-1, in the first paragraph of “1. Background and Purpose of Study”: Both statements are correct. The primary objectiv e is to reduce NOx. Strategies are identified in the study that will help the region achieve this primary objective. Many of the strategies reduce volatile or ganic compounds (VOCs) as well as nitrogen oxides (NOx).

2) Page 2-1, Refining Initial Master List: For those measures which have a minimal effect on emissions and have been grouped with other measures, the individual emission reductions resulting from these is still availa ble in Appendices F, G, and H of the final draft control measure report.

3) Page 2-1, Evaluating Feasibility and Potential for Emission Reductions: The word “model” is used in this sentence as a re ference for calculations done based on certain assumptions.

4) Page 3-1, Qualitative Review of Master List: four criteria were developed by the EPA to guide state and local governments in deve loping control strategies for the SIP, to improve local air quality, and comply with fe deral regulations. Satisfaction of these criteria is necessary to generate an emission re duction that is creditable in the SIP.

Emission reductions are “Permanent” if they can be ensured that no emission increase (compa re d emissions in the absence of the project) occur over the time the emission reductions are relied upon in the SIP. They ar e “Surplus” as long as they not otherwise relied on other Air quality-related programs in the SIP, SIP-related requirements, other State air quality programs adopted but not in the SIP, or federal rules that focus on reducing criteria pollutants or th eir precursors. They are “Qua ntifiable” if they can be reliably measured or determined, and if these determinations can be independently verified and replicated. Emission reducti ons are “Enforceable” if they employ a methodology to ensure that the promised emission reduction actually occurs. If a program cannot be created (or defined), then the Control Measure does not satisfy the enforceable requirement of the four criteria, and is not selected for the “Short List”.G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-21 Professional experience and judgment were factors critiqued during the consultant selection process. ENVIRON uses prof essional judgment based in professional experience, research, and identification of C ontrol Measures being enforced in this and other regions. Many Control Measures that were not enforceable were excluded from this study. This practice was followed to focus discussion, time, energy, and resources upon Control Measures that could either sati sfy all four criteria, or ENVIRON believed that the region should determine the feasibility or acceptability of the Control Measure.

5) Page 4-1, 4. Summary of Measures: We refer you to answers given to questions and comments made in item number 4 above. Regarding best professional judgment, this was used to establish the list of Control Measures within the study. Professional judgment encompasses many facets including profe ssional experiences, knowledge of best practices, research of the ingenuity a nd improvement of technology, observing the success of similar Control Measures currently being used inside and outside the region, and studying the feasibility of near future possibilities.

6) Pages 4-2 through 4-22, Table 4-1, On-road vehicle emission reduction measures: HGAC appreciates Sierra Club’s comments on this list of measures. H-GAC has attempted to take your comments into acc ount for those measures which you have commented on For the questions or commen ts that Sierra Club made on On-Road Control Measures which did not progress to the “Short List’, no response is provided.

7) Pages 4-22 through 4-26, Table 4-1, Non-road vehicle emission reduction measures: H-GAC appreciates your comments on current m easures and suggestions of measures to include. H-GAC will follow the public part icipation process in informing decision makers of your concerns.

Throughout the latter part of 2008, H-GAC worked to quantify and refine this Master List into a Short List of measures which the Houston-region will recommend to TCEQ for implementation in early 2009 as part of the SIP. You can fo llow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road Control Measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx

Additionally, we encourage you to co ntinue to be involved with the SIP process. I am happy to provide more information about the form and scope of these Control Measures by phone (713- 499-6695) or email ( Shelley.Whitworth@h-gac.com ).

Sincerely,

Shelley Whitworth Air Quality Program ManagerG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-22 6.1 Comment from Charles Stillman



## Port and Marine Control Strategy Short List Comment Card January 8, 2009

Thank you for participating in the public input process that is vital to the success of our region. 

### Your name and contact information is optional, but required if you would like to be added to the H-GAC Transportation Department's Mailing List. To view a Control Strategy Short List in its entirety, visit www.h-gac.com/taq/airquality/sip/mobile.

The comment period ends at 5 p.m. Thursday, Januarv 15, 2009. Written

comments can be made online at airquality@h-gac.com; by fax at 713-993- 4508; 

### or by mail at Houston-Galveston Area Council, Attn: Shelley Whitworth, Air Quality Program Manager, 3555 

### Timmons Lane, Houston,
TX 77027. 

# D Please add me to the Mailing List



### Name:

# ()~S,**SnLUMA~** Email Address: 

# Lh-or\e c;

## ~~S~V"v.l-~d M

## ')~i \.

## ~ Address:



## ------------------------------------------**Phone:~(** 

### _ _,_)

____ _ 

# i n rol Strategies
Li e Dislike 

# D Construct Clean Air Action Plans for ports 

# D D Develop shoreside power Plu into enerator or rid· Hood and bonnet method



# D D Promote use of clean fuels


# D Increase engine control standards

I have made additional comments, questions, and

concerns on the back of this form.G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-23 6.2 Response to Charles Stillman



### February 13, 2009

To: charlestexasclimate@gmail.com

Dear Mr. Stillman:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP) Draft Sh ort List. We have received your port an d marine control strategy comments and will tr ansfer them to the appropriate agencies.

Your comment expressed support for incr easing marine engine control standards,

p romoting the use of clean fuels for marine ve ssels, and the creation of clean air action

p lans for local ports. We will take this support into account wh en creating the Final Short List for submittal to the Texas Commis sion on Environmental Quality. You can follow the progress and see a detailed summary of the SIP process, the timeta b le for the rest of the process and the on- and non-road control measures at th e H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx

Sincerely,

Shelley Whitworth Air Quality Program ManagerG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-24 7.1 Comment from Carol Caul

685 N Po st Oak Ln Hou sto n TX 77024-4606 Phon e : 713

- 680-2500 Email : carolcau l @e nergybusiness .c om

January 14, 2008

Transportation Department

, Air Quality Section H ouston

- Galveston Area Council
P

. O

. Bo x 22777 Houston, Texas 77227

- 2777 Email: airquality @ h-gac.com ; fax: (713 ) 993

- 4508.

D ea r Air Qu ali ty Section:

Following are my comments on a few of the voluntary and mandatory items in HGAC 's quantified Short List Cont r ol Measures f o r inclusion in our SIP

.

COMMENTS ON HGAC SHORT LIST CONTROL MEASURES FOR INCLUSION IN TEXAS SIP

HGA C s h o uld b e certain to review pr o posed l egis l ation from the last Congressional session which is likely to be reintroduced, current legislation awaiting regulations, and US Supreme Court rulings to help it quantifY the short list measures. For example, The Energy Improvement and Extension Act of 2008 (Sep 2008, passed in House and Senate; latest version engrossed Senate version), provide a mechanism for quantifYing, and funding new
measures, in part, many of which are on the voluntary Short List Control Measures.'

The meshing of funding initiatives with the analyzed control measures is necessary to determine the level of and the extent to which the markets and affected governments will be willing to adopt these measures. That is, the money cannot be decoupled from the measures, particularly the voluntary

measures.

1 An example of these measures not specifically tied to a short list item is provision for Qualified Energy Conservation Bonds. The Energy Improvement bill c reates a new

ca teg ory of tax credit bonds to finance State a nd local gov ern ment initiativ e s d e signed to reduc e greenhouse emissions. There is a national limitation of $800 million, allocated to States, municipalities and tribal governments. The estimated cost of this proposal is $276 million over 10 years.G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-25 MANDATORY MEASURES REQUIRING LEGISLATION, REGULATION, OR ORDINANCES

PAY AS YOU DRIVE INSURANCE

This was the highest rated ofthe Environ Inc mechanisms, and I have

a number of problems with the structure and implementation this mechanism. I am certain that many others have expressed these and similar problems with this provision.

Among the more notable concerns with pay as you drive insurance are (1) pricing ofthis "insurance" component-you can label it "insurance", but it is not insurance: it is a tax; and, consequently, must have regulated rates, presumably a floor and a cap, whether it has a market veneer, or insurable risk veneer, or not; (2) responsibility for reporting ofthe miles; (3) uninsured motorists and the vehicles subject to the insurance mandate: many light vehicles in HGAC cruise around without insurance, a problem likely to get

worse; light vehicles register in other states or even areas outside HGAC,

some of which are in attainment areas; there will be more and more interregional and interstate heavy vehicle travel.

(1) This pay as you drive insurance is a tax. The VMT is a better
tax measure.

This "insurance" is a tax, no matter how it is labeled and should be mutually exclusive of a pure VMT. The VMT tax seems much simpler, easier

to administer nationwide, although it also has the same problems with rate design, reporting, enforcement, credits and exemptions, and demand elasticity that the insurance provision does.

(2) Vehicles subject to the insurance mandate; large number of uninsured free riders; and exemptions; 3-part rates

Contrary to the assertion in the Master List that short mile drivers subsidize long mile drivers, insurance statistics consistently appear to indicate that most accidents within a few miles ofthe home.

Right now, insurance companies in the HGAC and Texas markets can compete on price, subject to a cap. With this new measure, the type(s) of vehicle insurance a driver would have to carry would have three parts: (1) a

new mandatory component for miles traveled; (2) the current a flat rate for mandatory uninsured motorist insurance; and (3) whatever voluntary pieces the driver chose to purchase.

The guys driving around without insurance, the free riders, is presumably the easiest problem to overcome with this initiative: either theG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-26 SIP reduction claimed has to be reduced, so as not to include the miles ofthe uninsured, or the paying drivers have to pay for the uninsured (neither of which alternative is legally appealing to me). HGAC could make an assumption about their numbers, and deduct this amount from any savings that would otherwise be claimed through universal coverage or impose the miles driven rate the uninsured avoid on those paying for insurance. The

ozone reduction benefits could not be passed on through the uninsured provisions for liability, because the insured drivers would still be driving; if they do not have to pay, the demand elasticity for them is zero.

Light-vehicle guys registered out of state or even outside HGAC, particularly in "attainment" areas, create legal problems and enforcement problems. Are these guys subject to this tax? Similar issues exist for crossborder truck traffic given the recent US Supreme Court ruling, and for trucks registered in other states, particularly in attainment states.

I strongly support electric vehicles and other alternative energy and fuel efficiency mandates for vehicles. To induce persons to drive such vehicles, there could be a partial exemption from this "insurance;" such an electric vehicle exemption creates the need for an additional term to the model calculations to avoid double counting.

In contrast, with the VMT tax, a more valuable tax credit can be offered to induce demand reduction for NOx and VOCs producing vehicles and administered on a nationwide basis.

(3) Pricing of miles traveled "insurance" component, price elasticity, and effect on demand

Efforts need to be made to get traffic offthe roads during rush hour to help manage the number of exceedances of the 8 hour standard.

As to elasticity, TxDOT has statistics indicating how many people are driving to work. In the short run, it is not clear how many ofthese persons have an alternative mechanism for getting to work.

TxDOT generally says that 25% ofthe persons on the road during rush hours are making discretionary trips. If we want to get these folks to modifY their driving habits (organize trips and drive during non-rush hour), a timeof-use mandate would work better than a flat miles traveled.

How high would the miles driven rate component be set to see an effect

on demand? Would the VMT be in lieu ofthe fuels tax or in addition to? If in addition to current fuels tax, would the miles driven component be set higher that the liability component for a person's insurance? That would make sense if one accepts the insurance companies' data that most accidents occur closeG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-27 to home. Could it be higher than a monthly car payment? Would there be block, or declining block, rates like for electricity?

A rate design with only a flat tax pay as you drive component does not incorporate the congestion pricing mechanisms authorized in SAFETEA-LU. TxDOT and TTl have long stated that 1/4'h of rush hour drivers are not commuting to and from work. Commuter traffic and intervals must be meshed into the eight-hour ozone standard. Flat rate insurance on miles traveled would not seem to have any effect on discretionary driving during HGAC region rush hours.

VMTTAX

A VMT is a good idea, either alone or in conjunction with a motors fuels tax, to raise money for transportation projects. The effect on demand would presumably be the same as the effect on demand caused by vehicle miles traveled "insurance".

As above, an assumption has to be made as to elasticity of demand (how much of a reduction in miles traveled). A simple VMT, without dynamic pricing, may not maximize the ozone reduction but would be simpler to collect and administer.

As to enforcement, the free rider problem could be controlled better than with the "insurance", but there would remain the verification issue as to how many miles were actually driven. Presumably this number could be verified as a part of the annual state emissions test for light vehicles and periodically verified for heavy trucks.

The VMT will be hard to impose and apportion on trucks that engage in a lot of interstate travel without some form of verified report. Since it is estimated that heavy vehicles cause 50% ofthe NOx, there would be issues as
to apportioning both the VMT revenue, and more importantly for the SIP, the VMT credits for NOx reduction.

BICYCLES-BENEFITS ARE INCORRECTLY ANALYZED AND UNDERCOUNTED

The bicycle cost effective analysis is not supportable and should be reanalyzed and the benefits recounted. The short list quantification does not
count or even refer to benefits from increased use of existing facilities. Further the short list analysis only counts benefits from new capital construction, it implicitly assumes there would not be increased use of existing facilities. Moreover, the new construction analysis only counts bike

use of facilities for work commutes and not for errands or other discretionary trips.G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-28 Many persons who might drive a short distance non-work errand could be induced to use a bike for such errands, particularly ifthey work far away from their home and would have a commute long enough to render bike use infeasible.

Many measures should be aggregated or bundled to avoid double counting or to increase the benefits from the measure, and thus get it higher

up the short list. Some measures, however, need to be disaggregated to examine them correctly and fairly. Bicycles and other non-motorized vehicles need to be disaggregated into two components (1) voluntary increased use of existing facilities needing little funding except for education and public

awareness; and (2) the projects analyzed in the short list which require construction.

1) The Short List describes only increased use of bicycles if more facilities are constructed.

The current analysis, see p 8 ofthe short list analysis, wholly ignores the increased use of bicycles using existing facilities (i.e. the marginal cost of using an existing bike path is zero or nearly zero). Not a single additional

user is predicted from increased use of existing facilities due to voluntary

measures and public awareness efforts.

2) Further, and equally important, the analysis only forecasts use by cyclists for commutes or work trips while the rest of the control measures focus on metrics such as VMT, examining both work and non-work related trips.

Besides being flawed, this analysis puts the bicycle analysis at a disadvantage relative to other measures. Bicycle users may be willing to ride

a bike for discretionary travel, which it may be impractical to ride a bike to work. Work may be further away than the 3.5 mile metric used in the study, but the bank and drug store may well be within pedaling distance and not raise grooming, all day storage, and other issues that confront many commuting bike riders.

While these two types of projects (existing and new facilities use) probably induce demand interdependently, I do not quibble with the methodology employed in the capital outlay analysis for the second type of project (new construction) except that it ignores the use of bikes for

noncommute trips. The Short List analysis represents only those who would

not ride a bike, but for the additional expenditure; i.e. I ain't getting on a bike unless you make these capital improvements, and then only those going to and from work. (I ain't getting on this bike to go to the post office or gym.)G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-29 The analysis mentioned difficulties in counting bike riders. First, most ofthe short list metrics are modeled (predicted, not counted); but second,

counter cords could be placed randomly much like local traffic counters are used to get measurements from which to model.

Not only does SAFETEA-LU, in its current formulation, provide for grants for bicycles and walking, the The Energy Improvement and Extension Act of 2008, provides for Bicycle Commuters. The bill allows employers to provide employees who commute to work by bicycle limited fringe benefits to offset the costs of such commuting (e.g., storage). The estimated cost ofthis proposal is $10 million over 10 years. This provision is limited to commuters, but the SIP need not be.

ON ROAD SPEED REDUCTION: BOTH HEAVY AND LIGHT VEHICLES

The short list addresses reduced truck speed, but neither the master

nor short lists address fuel savings of reducing speed for light vehicles. In addition to supporting mandates for speed reduction for heavy vehicles-not just trucks, I support the reduction ofthe speed limit to 55mph in urban

areas and 60 mph in rural areas in HGAC for light vehicles. Many new fuel efficiency standards, such as the California standards and CAFE standards

are not tied to persons speeding. The HGAC TPC could hold meetings on why people think they need to drive faster than 60 mph given the drop in fuel efficiency. I am not addressing attainment areas for this speed limit.

FUEL REFORMULATIONS & VEHICLE EFFICIENCY STANDARDS

I support all federal fuel reformulations and California efficiency standards described in the master list. See my comments above regarding speed limits to be used in conjunction with these standards.

VOLUNTARY MEASURES REQUIRING BEHAVIOR MODIFICATION & DEMAND REDUCTION, REPORTING & VERIFICATION SYSTEMS

IDLING- MANDATORY AND VOLUNTARY

Mandatory and voluntary restrictions on idling are my favorite form of fuel savings without reducing vehicular miles traveled.

Intuitively, it will be harder to get large vehicles to constrain idling and measures for heavy vehicles-trucks, rail, waterborne vehicles--will need

to be mandatory or financial incentives will need to be provided.G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-30 Heavy: trucks, buses, truck stop electrification, off road construction equipment, federally regulated ships and rail; advanced insulation

Appropriate regulations and ordinances, whether state, federal, or local, should mandate a limit on truck and other heavy vehicle idling, except for safety and emergency vehicles, school buses at stops, and jet engines.

Several truck stop electrification facilities are either in operation or

near date of commencement of commercial operations. This is a good way to

save fuel, and to provide truckers a higher quality stop. The California Climate Registry is adopting protocols for Truck Stop Electrification to assist in the financing ofthese facilities that Texas could adopt particularly if we

are going to have all this trade traffic coming through HGAC.

Federal regulations should be adopted to control fuel used for idling or during demurrage of container ships and passenger ships.

Local Metro bus drivers absolutely do not have to idle their engines while they are on break. Some metric has to be adopted as to how long they idle before turning off the fuel.

The Energy Improvement and Extension Act of 2008 "Incentives for Idling Reduction Units and Advanced Insulation for Heavy Trucks," provides

an exemption from the heavy vehicle excise tax for the cost of idling reduction units, such as auxiliary power units (APUs), which are designed to eliminate the need for truck engine idling (e.g., to provide heating, air conditioning, or electricity) at vehicle rest stops or other temporary parking locations.

The bill also exempts the installation of advanced insulation, which

can reduce the need for energy consumption by transportation vehicles carrying refrigerated cargo. Such advanced insulation has the co-benefit of reduction of GHG due to the lower need for refrigerants.

Light Vehicles: idling at schools, airports, banks, and other public areas with waiting facilities

Idling by light vehicles in recurring circumstances such as at schools is the stupidest form of fuel waste, and education programs could be adopted to
encourage an end to this practice and the damage it does to the air, their kids' lungs, and to our dependence on foreign oil. These education programs could be instituted at schools at little cost and through public

announcements.

In some areas, restrictions on idling by light vehicles could be mandatory or enforceable by law, such as at airports and other areas whereG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-31 already on-duty law enforcement could induce people to move or go to the parking areas. Ticketing practices could be adopted to enforce the prohibition.

Situations at unpredictably long waits, such as at drive through banks,

can best be altered by education, direct deposits, electronic banking, or parking the car, turning offthe ignition, and going inside.

ELECTRIC VEHICLES

GM and others are rolling out electric vehicles in significant numbers in 2010, and I urge HGAC to reexamine the cost effectiveness ofthese vehicles. Of course, the electricity has to come from somewhere initially, and in ERCOT that somewhere may be a fossil burning generator.

In the near future, little electric cars will be able to plug into the grid

at a retail outlet or other, and sell electricity back to the grid. However, for right now, persons can be induced to buy these cars with a tax credit; in Texas, this would need to be a federal tax credit.

The Energy Improvement and Extension Act of 2008, establishes a

new credit for plug-in electric drive vehicles. Additionally, while not a mobile

measure, the Energy Improvements Bill also provides for accelerated depreciation for Smart Grid and Smart Meter initiatives. This right to take accelerated depreciation would probably be sought in ratemaking by wires utilities and wires merchants, but these features would improve the availability of a repowering station, making it more convenient for electric vehicle owners to repower while away from home base.

STATIONS AND FACILITIES FOR ALTERNATIVE & NEW FUELS

To encourage people in the HGAC area to use non-carbon or carbonbased renewable fuels, there must be stations or access to the fuels. The Extension Act recognizes this and provides for new or reformulated stations. Regrettably Exxon left the retail service station market, but other providers such as Shell, Chevron, BP, and Valero should be encouraged to participate in these ventures.

Specifically, the aforementioned improvements bill provides for an Extension and Expansion ofthe Alternative Refueling Stations Credit. The bill extends the 30% credit for alternative refueling property, such as natural
gas or E85 pumps, through 2010. The bill also adds electric vehicle recharging property to the types of property eligible for the credit. The credit for hydrogen refueling property is unchanged.G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-32 I do not favor the use of ethanol even switchgrass and other celulosic fiber. Corn is for people and animals to eat. Ethanol does not have the BTU value of conventional hydrocarbons blended into gasoline, so it is inefficient, and it is still carbon-based.

COMPRESSED WORK SCHEDULES

Compressed work schedules and telecommuting should be aggregated

or bundled: these could be adopted by ordinance or statute for government employees; but they would be voluntary for private employers. To reduce uncertainty from the voluntary component and to meet the enforceability criterion, a simple local reporting system needs to be adopted for major companies' local offices to report whether such plan will be and is used.

CERTAIN CONTROL MEASURES SHOULD BE WITHDRAWN FROM HGAC SIP SHORT LIST

This is an example of a CM that at this stage should be dropped from the short list, possibly to be reinstated later.

Control Measure: #127, Heavy Duty Vehicle Border Inspection Program explains that the number of cross-border vehicles that currently travel beyond a 20 mile zone is small. We assume that given NAFTA and the newly branded, fragmented, Trans Texas Corridor, the number of cross border trucks that could come into HGAC could increase.

Given recent US Supreme Court rulings regarding Safety, NAFTA, and NEPA, it would be difficult to implement this CM without federal legislation and implementing regulations. The numerical assumptions for this initiative are too difficult without a better regulatory metric that has withstood NAFTA challenges in court.

I submit these comments individually, but I am also a member ofthe Board of Directors ofthe Citizens' Transportation Coalition and an experienced instructor in electric power regulations, the CAA, NOx, Sox, and GHG regulations, state and federal initiatives, litigation, and evolving cap and trade programs. I am not a chemical engineer.

I greatly appreciate the very complicated undertaking ofHGAC staff and consultants and would be happy to assist with your efforts.

Best regards,

Carol Caul President, Energy Business Inc. Member, Southern Dist of Texas,G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-33 5'h Circuit Court of Appeals, and
US Supreme Court Bars Ph: 713-680-2500G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-34 7.2 Response to Carol Caul

February 13, 2009

Ms. Carol Caul President Energy Business Inc, 685 North Post Oak Lane Houston, TX 77024-4606

Dear Ms. Caul:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP) Control Meas ures Short List. Th e Texas Commission on Environmental Quality (TCEQ) and H-GAC continue to examin e a wide range of voluntary control measures. Your letter commented speci fically on sections of the report as well as specific control measures. Responses to each of these comments follow:

• Pay as you drive insurance vs. VMT tax: H-GAC appreciates your comments. VMT taxes are implemented on a state or federal level rath er than a local level. Since the control measures that H-GAC can place on the Final SIP Control Measures Short List must be implemented voluntarily by local governments, this measure will be removed from the final report. Alterna tively, pay as you driv e insurance can be implemented by insurance providers as a service to their customers. B ecause of this difference, the pay as you drive insurance measure will remain a part of the Final SIP C ontrol Measures Short List.

• Bicycles-benefits are incorrectly analyzed and undercounted: Your comments about the cost effectiveness for bicycle-pedestrian projects are greatly appreciated. Our consultant’s figures were ta ken from data in the Regiona l Transportation Plan for our region, based on the project cost for building additional bike and pedestrian projects as well as forecasts for use of new and existing trails.

• On-road speed reduction: both heavy and light vehicles: H-GAC appreciates your comments. Because this control measure ca nnot be implemented locally, it is not included in the “short list”.

• Fuel reformulations & ve hicle efficiency standards: H-GAC appreciates your comments. Because these control measures cannot be implemented locally because they cannot be enforced, it was removed from the ”short list”.

• Voluntary measures requiring behavior modification & demand reduction, reporting & verification system s / idling – mandatory and voluntary: H-GAC is currently working with government and business en tities within the Houston-Galveston-Brazoria region to develop both the infrastructure (such as truc k stop electrification or the installation of auxiliary power units), the regulatory stru cture, and the Memoranda of Agreement necessary to implement these contro l measures as part of the SIP.G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-35 • Electric vehicles: H-GAC recognizes the practical diffi culty in the integration of budding technology into established systems and it may no t be practicable at this time, however in future years it may be practicable.

• Stations and facilities fo r alternative & new fuels: H-GAC appreciates your comments.

• Compressed work schedules: H-GAC appreciates your c omments and has already lumped this control measure and teleworking with other commute solution control strategies.

• Heavy Duty Vehicle Border Inspection Progr am control measure should be withdrawn from H-GAC short list: H-GAC appreciates your comments. You are correct, and this control measure will be removed from the final report.

You can follow the progress and see a more detailed summary of the SIP process, the
timetable for the rest of the process and the on ‐ and non

‐ road control measures at the H

‐ GAC
SIP website: http://www.h

‐ gac.com/taq/airquality/sip/mobile/default.a spx

Sincerely,

Shelley Whitworth
Air Quality Program ManagerG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-36 8.1 Comment from Port of Houston Authority



## IF COHRl. 'lr 

## COl IF llli COl 1IJ § 

## 'II' 

## COl N A 1IJ 

## 'lr 

## llli COl Illl. 

## IT 'lr 

## lY

EXECUTNE OFFICES: 111 EAST LOOP NORTH • HOUSTON, TEXAS 77029-4327

MAILING ADDRESS: P.O. BOX 2562 • HOUSTON, TEXAS 77252-2562

TELEPHONE: (713) 670-2400 • FAX: (713) 670-2564

January 15, 2009

VIA E-MAIL
Houston-Galveston Area Council
3555 Timmons lane, Suite 120 Houston, Texas 77027

Attn: Shelley Whitworth, Shelley.whitworth@h-gac.com

RE: Port of Houston Authority Comments on H-GAC Final Short List Control Strategies for On-road and
Off-road for 8-Hour Ozone Plan

Dear Shelley:

The Port of Houston Authority (PHA) appreciates the opportunity to provide additional comments to H·

GAC on the Evaluation of Mobile Source Control Strategies for the Houston-Galveston-Brazoria State
Implementation Plan prepared by ENVIRON International Corporation dated December 5, 2008. The

comments provided in this document are in addition to the comments provided to H-GAC in August

2008 on the Master List of Non-road Control Strategies for 8-Hour Ozone Plan. The PHA has been an
active participant H-GAC's stakeholder meetings for the marine, ports, on-road and off-road mobile

sources regarding these control strategies. With our past involvement in the stakeholder groups and

our past comments, the PHA will focus this document on commenting on the measures presented as

_ _

#45 Development of_ a Port of Houston Clean_ air Action Ph;m th_at_s(!eks tomjnirrl_i?_e em[ssions from ships,

cargo handling equipment, on-road drayage trucks and port-related rail.

It is our understanding from H-GAC and ENVIRON that these control strategies are being considered and

comments requested on them for development into voluntary emission measures.

An important point that PHA would like to emphasize is that measures developed to work in other ports

around the world, such as California or European ports, may not specifically transfer over and be

successful in the Houston area for various reasons such as legal constraints, jurisdictional authority,

market share, coastal geography, etc. However, this will not preclude the PHA from coming up with a
similar plan or measure that will work for this area. Although all ports move cargo from ships to other

modes or to other ships, not all ports operate the same. Ports in the USA are operated by local
governments, state governments, and any mixture in between. Simply stated, a plan or a control
strategy in one port simply may not work in another port.G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-37 With this in mind, PHA has embarked on the development of the Clean Air Strategy Plan (CASP)
Approach document. This Approach document for the CASP will be the framework for the development,
implementation, and analysis of control measures that will reduce PH A's impact to the air quality of the

Houston region. The CASP Approach Document is expected to be publically released in January 2009

and the formation of stakeholder groups to contribute ideas to the CASP will begin in the First Quarter

of 2009. In addition to the CASP Approach document, the PHA will be releasing the final draft ofthe

Goods Movement Emission Inventory (GMEI} in January 2008 for stakeholder comments. The GME! will

be utilized as a baseline tool for the CASP programs.

With this in mind, we offer the following comments on Control Strategy #45:

Clean Port Initiative

PHA appreciates that H-GAC has recognized that comprehensive plans are important to this region's air
quality improvements; however, the PHA was disappointed that only a "Port of Houston" plan was
included as a control strategy with no regard to the other ports in the non-attainment region or governmental entities. Although, the Port of Houston has a greater overall market share in the area,

any implementation of port related control measure will be most effective when all ports are involved.

In addition, if governmental entities have a comprehensive plan for things they can control as a larger

unit rather than individually bigger reductions may be achieved in a more effective manner. An example

of this would be a regional idling policy.

Vessel Speed Reduction

As mentioned in the ENVIRON report and analysis, a Vessel Speed Reduction (VSR) program in the

Houston Ship Channel (HSC) would not be as effective as it is in the Port of Los Angeles/Port of Long

Beach areas because vessels in the Houston Ship Channel are already going slow speeds. Going any
slower will make maneuverability of the vessel limited and would affect safety in the channel per the US

Coast Guard and the Houston Pilots. The PHA has evaluated this measure in detail and provided this

iriformation in the past to**H~GAC;** however, it is likely that the PHA'S CASP Will evaluate VSR further out

in Galveston Bay and the Gulf of Mexico. While these speeds are higher, double that in the HSC, it is

believed that slowing vessels down will have little to no effect on regional air quality due to the distance

and the constant sea breeze. If more information is needed in addition to data previously submitted, it

will be provided upon request.

Reduction of At-Berth OGV Emissions

Reducing emissions at berth from cold ironing can be effective for some ships. Cold ironing works best

when ships operate in liner type services that have the same vessels calling in a frequent rotation over a
number of years to the same terminals. Additionally, another key factor is the amount of energy the
ships use while at berth. Currently at the Port of Houston Authority there are some high frequency
ships that are calling on the Barbours Cut Terminal. However, due to the small size of the ships (at berth

loads will be below one megawatt) plus the fact that the terminal would have to be retrofitted, the cost

per ton is expected be very high (ranging from $60,000 to $100,000 per ton NOx). Other older PHAG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-38 terminals will also have to be retrofitted if cold ironing is implemented. However, the Bayport Container

Terminal was constructed with the future possibility of providing shore power, so the retrofit for this

terminal will not be as costly. At this time though, Bayport is a newer terminal, so there has not been a long history of vessel calls to establish frequency and feasibility of cold ironing.

As mentioned in the ENVIRON report and analysis there are other technologies available to reduce

emissions while at berth such as the "bonnet" technology, which is a scrubber device that is placed over
the vessel's exhaust stack capturing a!! emissions. Technologies like this one are attractive in that

retrofit to terminal and ships are nonexistent or minimal; however, this technology is relatively new with only two known demonstrations. Additionally, the purchase cost for the device is around $10 million

dollars and operation/maintenance cost exceeds $2 million dollars annually. The "bonnet" technology

and other similar control measures will be reviewed in the PHA CASP program for feasibility of
implementation.

OGV Auxiliarv Engine & Main Engine Fuel Standards

As the ENVIRON report and analysis has established, the fuel standards for the fuel used in ocean going

vessels is regulated internationally through the IMO framework. Currently, the world fuel sulfur content

is 2.7%. However, the global cap on sulfur will be 0.5% in 2020 which will reduce SOx by 80% and PM by

75%. Additionally, the US EPA is planning to submit an application to the IMD for the US West, East,

and Gulf coast (plus Canada) to be designated as an Emission Control Area. This designation will allow

sulfur to be lowered to 1.0% in 2012 followed by a 0.1% cap in 2015. Additionally, any ship that
operates in the designated ECA area will have to comply with IMO NOx standards. Clearly, any
additional local controls on fuels will be superfluous as international regulation is the most effective way

to implement this kind of measure.

The PHA has been actively involved in supporting these measures at the IMO level as a US delegate for

AAPA. On a national level, the PHA has been active participant in an EPA Office of International Affairs
fu_el switching feasibility study between the PHA and a western hemisphere port operations. This study

and demonstration is currently in the initial study phase and will provide valuable insight for Gulf of

Mexico regional goods movement operations in comparison to those activities on the West and East

coasts. This study will become part of the CA5P once fully developed by PHA and EPA.

OGV Main and Auxiliarv Engine Emissions Improvements

Again, the international control through IMO is the most effective way to promote this measure. The

Tier 2 international NOx standards will be phased in from 2011 to 2016 and will provide modest NOx

reductions for ships built during this time. The more significant reductions will start in 2016 when the

Tier 3 standard is implemented. Again, it would not be beneficial in implementing additional local

measures because engines on vessels engaged in international trade are best regulated at the

international level and local controls for only one port in the Gulf of Mexico would result in a significant

economic disadvantage for the Houston-Galveston region and not necessarily lower overall emissions

with the shift of cargo and additional transportation modes introduced to relocate the shifted cargo
back to this area.G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-39 As detailed in these comments, the PHA believes international regulations are the most effective way to

control emissions in the ocean going vessel sector. However, this does not mean the PHA would not still
try to implement any voluntary project that would help benefit the Houston region. As mentioned

before the CASP will be the framework used to implement any PHA related control strategy, and not just

for ocean going vessels, but in all port related sectors (rail, harbor vessels, on road drayage trucks, and

cargo handling equipment). A vital portion of the CASP will seek TERP grant funding as well as other

outside funding mechanisms that have not been identified at this time. With the overall CASP not fully developed or implemented, it is premature to develop voluntary control measures at this time.

The PHA anticipates these comments will be utilized to further develop and analyze voluntary control

measures for the HGB SIP. The PHA appreciates the opportunity to provide these additional comments

and will continue to work with H-GAC and TCEQ as an active stakeholder in the development of our
CASP and evaluation of practical and feasible measures and solutions in reducing air emissions in the region. We look forward to working with H-GAC. Please let me know if the PHA can be of further

assistance.

Sincerely,

# ~ Dana Blume, P.G.
Environmental Program Coordinator- Air Quality & SedimentG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-40 8.2 Response to Port of Houston Authority

February 13, 2009 Ms. Dana Blume Port of Houston Authority P.O. Box 2562 Houston, Texas 77252-2562

Dear Ms. Blume:

Thank you for your comments regarding the St ate Implementation Plan’s (SIP) short list of control strategies for on-road and non-road measures. The Texas Commission on Environmental Quality (TCEQ) and H-GAC continue to examin e a wide range of voluntary control measures. Your letter commented spec ifically on several aspe cts of non-road control measure number 45. Responses to each of these points follow:

• Clean Port Initiative: Thank you for your comment. Th e Houston-Galveston Area Council supports implementation of air qua lity improvements by all of the HoustonGalveston-Brazoria (HGB) region’s ports. To reflect this, the wording of this measure will be changed to encourage the development of clean air action plan at all ports within the HGB region.

• Vessel Speed Reduction and Reduction of At-Berth OGV Emissions: Port of Houston Authority as well as the other ports located within the HGB region will develop clean air action plans tailored towards each facility’s specific needs and abilities. Should vessel speed reduction and at-berth OGV be removed from consideration as part of a proposed clean air action plan, expected emission reduc tions for this measure would be reduced accordingly.

• OGV Auxiliary Engine & Ma in Engine Fuel Standards: Thank you for your comment. Since fuel standards can only be implemented as a state or federal level and since H-GAC can only place control measures that can be implemented voluntarily on a local level, this measure will be removed from the final report.

• OGV Main and Auxiliary Engine Emissions Improvements: Thank you for your comment. This will be applied only as a voluntary measure.

You can follow the progress and see a more detailed su mmary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/default.aspx

Sincerely,

Shelley Whitworth Air Quality Program ManagerG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-41 9.1 Comment from Smith Electric Vehicles

Jan 15 09 04:03p Vanessa Saltmarsh

14616 Carter Road

Overland Park, KS 66221

FalC 913.685.4637**,-~~----** 

# 'facsimile transmittal

L------

To: Trans Depart, Air Quality

From: Bryan Hansel

Re: Public Comments

Cc:

D Urgent D For review D Please comment

Notes: Following are our comments**J~aoo~ss!-SB40** p. I



# smiTH

-· ,_ 

## - _.,

---·---- ---- ----- 

# ------,

-- ----·-----------· -- J

Fax: (713)**993~4508**
Date: 1/15/2009

Pages: 3

o Please reply 0 Please recycleG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-42 Jan 15 09 04:03p Vanessa Saltmarsh 1-800-691-9840 p.2

Comment on On-road vehicle emission reduction measure ID #7. Electric Vehicles:

Given that the Houston-Galveston-Brazoria region is working toward an attainment date of 2019 or sooner and that extensive zero-emission vehicle technologies exist. while new ones are being developed, Smith Electric Vehicles proposes that on-road control strategy ID #7 be amended to also include medium-duty and heavy-duty zero emission vehicles.

Heavy-duty vehicles are already recognized as high emitters**ar~d** medium-duty vehicles, because of their large populatiorJ numbers typically operating short-haul routes in urban**enviror~ments,** are also**significar~t cor~tributors**  to emissions of**r~itrogen** oxides.

However, current volt.mtary irJcentive programs such as the Texas Emissions Reduction Plan and Congestion Mitigation and Air Quality funded programs tend to be structured to focus on reducing emissiorJs from heavyMduty, highmileage vehicles, leaving emissions from medlumMduty and lower mileage urban heavyMduty vehicles largely unaddressed.

Use of medium- and heavy-duty electric trucks proves arJ ideal strategy for emissions reduction in populated urban
areas, given that they emit no nitrogen oxides, particulate matter, or greenhouse gases and operate far more quietly than their diesel counterparts. In addition, use of electric vehides reduces dependence on foreign oil. Because zeroemission vehicles ranging from 5,000 pounds to 26,000**pour~ds** Gross Vehicle Weight Rate (Class 7) are currently available, Smith Electric Vehicles is proposing that medium- and heavy-duty vehicles be included as part of the Electric Vehicle control strategy, in order for public and private fleets in the Houston-Galveston-Brazoria regiorJ to be

aware of and have access to all available and potential zero-emission vehicle technologies now and in the future.

About Smith Electric Vehicles:

Smith Electric Vehicles is the world's largest manufacturer of zero-emission vans and trucks. Smith produces a range of commercial electric vehicles with Gross Vehicle Weight Rates up to 26,000 lbs. The vehicles all have impressive acceleration, top speeds of up to 70 mph and a range on one battery charge in excess of 100 miles.

The vehicles are zero emission at the point of use, meaning no exhaust air pollutants such as**r~itrogen** oxides or particulate matter and also no greenhouse gas emissions, such as carbon dioxide.

The product range is designed for urban applications such as deliveries, food and beverage distribution, 3PL logistics, construction, utilities, airports and public sector operations.

141616 Carter Road Overland Park, KS 66221 913.940.8353 www.smithelectricvehicles.comG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-43 Jan 15 09 04:03p Vanessa Saltmarsh 1-800-691-9840

Smith has a partnership agreement with Ford to develop and produce commercial electric vehicles, utilizing the Ford chassis. Founded in 1920, Smith has a unique heritage and unparalleled expertise in the manufacture and service of commercial electric vehicles.

Smith Electric Vehicles is a trading division of The lanfreld Group Pic, which is a profitable, high growth company listed on the Alternative Investment Market (AIM) of the London Stock Exchange.

www.smlthelectricvehic!es_com

www.tanfieldqroup.com

lhank you for your time and attention in reviewing these comments.

Sincerely,**~**

# \~ Bryan Hansel CEO 

# v

Smith Electric Vehicles US p.3G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-44 9.2 Response to Smith Electric Vehicles



### February 13, 2009

Mr. Bryan Hansel, CEO Smith Electric Vehicles US 141616 Carter Road Overland Park, KS 66221

Dear Mr. Hansel:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP). Your comment focused on Draft Short List Control Measure #7, regarding the replacemen t of internal combustion engine vehicles with electric vehicles. H-GAC agrees with y our assessment that by adjusting the measure to focus on replacing all weig ht and duty vehicles with el ectric versions would provide greater emission reductions than simply focusing on light-duty vehicles. This control measure is part of our “short list” and would be applied only as a voluntary measure.

Thank you again for your feedback on this control measure. You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road cont rol measures at the H-GAC SIP website: http://www.h-gac.com/taq/airqua lity/sip/mobile/default.aspx

Sincerely,

Shelley Whitworth Air Quality Program ManagerG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-45 10.1 Comment from Harris County, Texas

Mr. Alan Clark Transportation Department Air Quality Section Houston-Galveston Area Council P. 0. Box. 22777 Houston, Texas 77227 January 20, 2009 

### Vince Ryan Harris County Attorney

RE: Comments on Draft Report: Evaluation of Mobile Source Control Strategies for the Houston-Galveston-Brazoria State Implementation Plan (SIP)

Dear Mr. Clark:

Harris County Attorney Vince Ryan's Office submits comments regarding the draft mobile source strategies prepared by Environ for the Houston-Galveston Area Council (HGAC) on December 5, 2008. We appreciate the extension of the deadline that

you provided. In the April 30, 2008 comments on the draft control strategy concept list submitted by Harris County Public Health & Environmental Services (HCPHES), it was recommended that the proposed list should be exhaustive to include as many strategies as possible, and that as the planning process moves forward, the exhaustive list would be reduced to include all reasonable strategies. We are pleased that this list includes a broad

range of control strategies; and we continue to recommend that a thorough review of a broad range of control strategies be conducted by the Texas Commission on Environmental Quality (TCEQ). Additionally, we believe that a multi-pollutant reduction approach should be utilized to maximize improvements in air quality. Moreover, as control strategies are identified to be included as part of the SIP, they should be implemented as soon as possible to maximize improvements in air quality without waiting for final SIP submittal before beginning implementation. Within the context of the report presented and the compressed timeline, we have focused our attention on the short list in Section 5; however, we encourage HGAC not to disregard the strategies on the master list if found to be viable. We believe that the control strategies listed in Section 5 have merit; however, the implementation of these strategies require further scrutiny and review given the complexity and diversity of Harris County with its population of approximately four million residents.
We provide the following comments which we hope will encourage and stimulate further meaningful discussion as this important process takes shape.

1019 Congress, 15 1 h Floor • Houston, TX 77002-1700 • Phone: 713-755-5101 • Fax: 713-755-8924G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-46 Qualitative Review of Master List, 1-3. The report states that the primary qualifier for the SIP control measure used in the study was based upon the U.S. Environmental Protection Agency (EPA) criteria which consider that the SIP control measures need to be: 1) permanent, 2) surplus, 3) quantifiable, and 4) enforceable (PSQE). These terms are not defined and it is unclear how they were used for decision making. The report goes on to say that Environ made a judgment as to whether a program could be defined to satisfy these criteria. However, the method and rationale on how this "judgment" was made is

not provided and needs to be included.

Quantified Evaluation of Measures, 5-l. The report states that these are "voluntary measures" but this contradicts the EPA criteria used by Environ which requires these

measures to be enforceable. It is unclear which measures would be voluntary (i.e. not enforceable or mandatory). The report also states that "the master list of measures was pared to just those measures that have emission reduction potential and could be implemented locally rather than requiring state regulations except in the cases affecting inspection and maintenance programs." Harris County disagrees that all of these could be implemented locally without state regulations. A key legal concept applying to counties is that "counties may do only those things that they are authorized to do, either expressly or by necessary implication." Tex. Att'y Gen. Op. No. JM-1215 at 2 citing Canales v. Laughlin, 214 S.W.2d 451 (Tex. 1948); Anderson v. Wood, 152 S.W.2d 1084 (Tex. 1941); Childress County v. State, 92 S.W.2d 1011 (Tex. 1936). Unlike cities, counties do not have ordinance-making authority and its authority comes from the Texas Constitution or statutes. Under the Texas Clean Air Act, municipalities have the authority

to enact ordinance to abate air pollution in a way that is not inconsistent with state
statutes and agency rules but there is no such similar provision for counties. See Tex. Health & Safety Code§ 382.113. A number of the proposed control strategies if required

to be implemented by counties would require legislative mandate. The report needs to make this clear and include a thorough discussion of legal feasibility of these measures and where legislative action or rulemaking will be required.

Bicycle and Pedestrian Action, Id. I. Encouraging the conversion of existing road lanes for bicycle use may not be practicable in all cases because the county roads were not originally designed to handle such traffic. Such action may require new design and construction. In addition, Environ should quantify the benefits of such program.

Public Agency Clean Fleet Program, Id. 6. Given the wide range of functions that vehicles are used for in county government, we recommend revising "cleanest possible"

to "cleanest practicable" fleet vehicles to give county government flexibility in the purchase of clean vehicles.

Electric Vehicles, ld. 7. The current generation of electric vehicles is in its infancy and
may not be practicable to all county operations. Environ's own analysis shows that it is

not a cost-effective control strategy.

Cleaner Diesel Fuel, Id. II. We encourage further review of this strategy.G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-47 Preferential Parking for HOV Lane Users, Ids. 39 and 47. These control strategies deserve further scrutiny as they continue to be refined. For instance, if public parking

garages are subject to revenue bonds, then there may be legal restrictions on free parking.

Local or Regional Fuel TaxesNehicle Taxes, Ids. No. 59-60. Again, we believe that these control strategies would require legislative changes.

Traffic Signals and Flows, Ids. 76-83. Harris County under the Congestion Mitigation Air Quality (CMAQ) program already is implementing these types of measures in its road projects. For example, for major arterials, we upgrade the signal control hardware and vehicle detection devices that allow us to be more responsive to changing traffic volumes. Outside of CMAQ, over the past several years, we have also upgraded all of Harris County's 700 plus traffic signals to use state-of-the-art traffic control hardware.

Mandatory or Voluntary Compressed Work Week, Id. 106. Subject to individual department approval, various county departments implement this policy already.

Purchase Vans for Vanpools, Id. 109. Because of cost-per-ton associated with this strategy, a funding mechanism would need to be in place.

Limitations on Idling of Heavy-Duty Vehicles, Id. 126. The TCEQ has implemented idling rules that are applicable only within the jurisdiction of a local government that has signed a memorandum of agreement (MOA) with TCEQ to delegate enforcement of the idling rules to that local government. See Tex. Health & Safety Code§ 382.115; 30 Tex. Admin. Code §§ 114.510-114-512 and 114.517. Such agreements currently exist in central and north Texas and require further scrutiny here.

Enhanced Enforcement for Smoking Vehicles Program, Id. 139. Aside from the TCEQ, HCPHES already enforces this smoking vehicles program. However, as currently written, the program is not easy to enforce and verifying compliance is a problem. Assistance from law enforcement would make this program more effective.

Voluntary Replacement/Retrofit Programs, Id. 5b. This has worked well under the Texas Emission Reduction Program (TERP) and Low Income Vehicle Repair Assistance, Retrofit, and Accelerated Vehicle Retirement Program (LIRAP) and should be encouraged through those programs.

Government Construction Incentives, Id. 8. Tax relief for firms using cleaner equipment would require specific statutory authority similar to the Pollution Control Property Tax Exemption program. Unless specifically authorized, requiring proposal preferences to firms using clean equipment requires more legal review. There are Texas

cases and attorney general opinions regarding situations where competitive bidding laws

were contravened for some other stated purpose and were found to be invalid unless such requirements were specifically authorized by statute. (e.g. See Sterrett v. Bell, 240 S.W.2d 516, 520 (Tex. Civ. App-Dallas, 1951, no writ; Op. Tex. Att'y Gen. MW-139G:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-48 ( 1 980) (County prohibition again s t th e pur c h ase of for e ign automobiles where the
pur c has e was subject to competitive biddin g r e quir e m e nt s was found to b e in va lid )

. Give n thi s, specific l eg i s lativ e r ev i s ion s in th e pur c ha s in g requ ir eme nt s may be n eeded ( e.g. T ex. Loc. Gov' t Code C h a pt e r 262).

Wh e re a co nstru c tion proje c t i s f e derall y funded (or p otential l y fede r a ll y fund e d) and i s l oca t e d in the n o n-attainm e nt a r ea, Harri s Cou nt y Fl ood Control District a lready requires

con tr ac t ors to upgrad e a ll pr e- Tier2 cons tru ction equipmen t drive train s a nd engi n es a t a

r ate of at least 20% of th e fleet p e r yea r a nd t o use l ow nitrogen ox ide s (NO,) e mi ss i o n s
t ec hnolo gy

. The c ont ract o r and s ubcontra cto r s are also r e quir e d to app l y fo r fun d s thr ough th e Te xas Emi ss ion R e du c ti on Plan (TERP) I ncenti ve Gr ants Pr og ram to m o dify

or purchase die sel equipment wi th l ow NO

, di esel emission s technology.

Landscap e Ordinance , ld. 29. Unde r plattin g r e quir e ment s, Ha rr is Co unty has adop t ed l andscaping r equireme nt s for r es i dentia l and com m e r c ial developmen t for unincorporat e d

areas. Th e r eg ulation s pro v ide s tand ards for plantin g tr ees and shmbs and in s tall i n g landscaping bu ffers. The se r e gulation s a re a d o pt e d und e r a uth o rit y provided in Tex. Gov ' t Code § 232 .101

. H ar ri s Cou nty r eg ulati ons furt h e r pro t ec t Harri s County gree n e r y b y o ff er i n g in ce nti ves t o p rope rt y ow n ers w ho p r eserve and take ca r e o f ex i s tin g trees on pri va te properti es

. (S

ee hltp: // www

. eng. h c t x

. n e t / perm i ts / pdl i' landscape r C!.!S i nfo packa!.!e.pd l).

Readability for the Public. For reader s n o t familiar wi th th e t e c h n i ca l aspects of th e S IP (and w h o may be tryin g to ge t a gras p o f w hat

, w h y, a n d h ow th e eva luations ca me t o the

conc lu sions in cluded in th e var io us su mmari es and how the cost-effect i ve nes s of

pr

opose d c ontrol m eas ures co mp a r es to w hat i s c urr e ntl y be in g do n e or not b e in g done), th e r e port need s to pro v id e mor e inf ormat i on on th es e aspect s

. Pr ovid i ng a li s t of

ac r o n y m s used in th e docum e nt and th e ir definitions wou ld a l so be h e lpful. A key p a rt of the r e p ort i s Se c tion 5 w hi ch w ill be m ost ref e r enced an d s h ou ld b e easy to under s t and

. Th e description col umn se e ms t o offer for eac h control s trat egy e ith e r an ob j ec ti ve, d e finition

, o r ta c tic

, but it i s n o t consistent.

We l ook forw a rd t o act i ve l y p a rti ci p a ting in de ve lopin g a n e ffecti ve SIP and brin gi ng the HGB region i nto attainment wi th th e 8- hour o z on e Nationa l Ambie n t A ir Qualit y Standard (NAAQS) as ex p e d i tiou s l y as pra c ti ca ble. We a ppr ec iat e yo ur considerat i on of our co mm e nts. If you h ave any qu es ti o n s , or if we can pro vi d e any additional infonn at i o n , p l ease co nt ac t
, S n eha l R. Pa t el, Senio r Ass ist an t Coun t y Attomey

, a t 713-755- 828 4.

# ~lJ;tj

# ~ J

.

# M"~"' H;ll

, F ; n;t 

### A;, ; " '"'
/ S"' h "l R

. P "ol, Soo;oc 

## A;,;"'" '

Harr i s Co unt y Attorney 's OfficeG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-49 c: Harris County Judge Ed Emmett Harris County Commissioner Ei Franco Lee

- Precinct i Harris County Commissioner Sylvia R. Garcia- Precinct 2 Harris County Commissioner Steve Radack

- Precinct 3 Harris County Commissioner Jerry Eversole- Precinct 4 Herminia Palacio, M.D., M.P.H., HCPHES Executive Director Bud Karachiwala, Division Director, HCPHES Environmental Public Health Division Art Storey, HCPID Executive Director Pat Garrett, Deputy Director, HCPID ArchitecturaVEngineering Division Catherine Elliott, Assistant Manager, HCFCD Environmental Services Department Ron Krafka, Director, HCTRA Construction Programs Division Andy Mao, Deputy Director, Traffic Engineering, HCPID Traffic and Transportation Division Keith Branner, Division Manager, Harris County Management Services Fleet Services Division Dwight Dopslauf, Assistant Purchasing Agent, Harris County Purchasing Agent's Office Donna Phillips, Regional Director, TCEQ Region 12 David Schanbacher, Chief Engineer, TCEQ Arturo Blanco, Chief, City of Houston Bureau of Air Quality ControlG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-50 10.2 Response to Harris County, Texas

February 13, 2009

Mr. J. Marcus Hill First Assistant Harris County Attorney’s Office 1019 Congress, 15 th 

### Floor Houston, TX 77002-1700

Dear Mr. Hill:

Thank you for your comments regarding the Houston-Galveston-Brazoria 8-Hour Ozone State Implementation Plan (SIP) Control Meas ures Short List. Th e Texas Commission on Environmental Quality (TCEQ) and H-GAC continue to examin e a wide range of voluntary control measures. Additionally, yo ur letter commented specifically on sections of the report as well as specific control measures. Responses to each of these comments follow:

• Qualitative Review of Master List, 1-3: Thank you for your comment. The final version of the report will clarify and expand the description of PQSE and other SIP criteria.

• Quantified Evaluation of Measures, 5-1: The voluntary control measures which become part of the final SIP submittal to TCEQ can and will only be adopted by TCEQ in the event that an entity within the Houston-Galveston-Brazoria region is able to commit to create, implement, and enforce the control.

• Bicycle and Pedestrian Action, Id. 1: H-GAC understands that the conversion of roads to bicycle lanes is not possible or practicable in all cases. Nonetheless, retrofitting existing roads to accommodate bicycle lanes is a co mmon practice and is only one of the options explored in this measure which H-GAC feels should be available to local governments to enact where appropriate.

• Public Agency Clean Fleet Program, Id. 6: H-GAC appreciates your comment and will edit the final report to ac count for your suggestion.

• Electric Vehicles, Id. 7: H-GAC recognizes the pr actical difficulty in the integration of budding technology into established systems and it may not be practicable at this time, however in future years it may be practicable.

Cleaner Diesel Fuel, Id. 11: H-GAC appreciates your comments. This control measure would be implemented only as a voluntary measure. This does not disqualify this measure from inclusion in the SIP

• Preferential Parking for HOV La ne Users, Ids. 39 and 47: Since this is a voluntary measure, it is not necessary that all entities wi thin the region participate in each measure. In the case of this particular measure, all entities may not be able to implement due to issues such as those which you mentioned in your comment. This doe s not disqualify this measure from inclusion in the SIPG:\HGAC\Reports\Final_051009\ Appendix D_051009.doc 

### D-51 • Local or Regional Fuel Taxes/Vehicle Taxes, Ids. No. 59-60: H-GAC appreciates your comments. Because this control measure cannot be implemented locally, it will be removed from the final report.

• Traffic Signals and Flows, Ids. 76-83: H-GAC congratulates Harris County on their visionary efforts in emission reductions, and en courages them to enter into an MOA so that their reduction efforts can be properly cataloged in the SIP.

• Mandatory or Voluntary Comp ressed Work Week, Id. 106: H-GAC congratulates Harris County on their visionary efforts in emission reductions, and encourages them to enter into an MOA so that their reduction effort s can be properly cataloged in the SIP.

• Purchase Vans for Vanpools, Id. 109: H-GAC supports a successful program encouraging this particular control measure. The participation level in this program supports the validity of offeri ng this control measure to th e entities of the region.

• Limitations on Idling of He avy-Duty Vehicles, Id. 126: As noted in your comment, TCEQ does promote this control measure in other metropolitan areas thr oughout Texas. H-GAC is monitoring these existing anti-idling programs outside of the region and has begun to promote this option within the Houston-Galveston-Brazoria region.

• Enhanced Enforcement for Smoking Vehicles Program, Id. 139: H-GAC recognizes the important role of law enforcement in this co ntrol measure. H-GAC is currently working with jurisdictions within the Houston-Galveston-Brazo ria region to develop funding and methodology for such a program.

• Voluntary Replacement/Retrofit Programs, Id. 5b: H-GAC appreciates your comments.

• Government Construction Incentives, Id. 8: H-GAC appreciates your comments on this control measure. The inclusion of any of th ese measures within the SIP is contingent upon the creation of voluntary commitments from local governments. If a local government does not specifically commit to this measure, it will not be legally bound to carry it out despite inclusion of the measure within the SIP.

• Landscape Ordinance, Id. 29: Since this is a voluntary measure, it is not necessary that all entities within the region pa rticipate in each measure. In the case of this particular measure, all entities may not be legally able to implement due to issues such as those which you mentioned in your comment. This does not disqualify this measure from inclusion in the SIP

• Readability for the Public: H-GAC appreciates your comments, and will work to improve readability for the general public in the final report.

You can follow the progress and see a more detailed summary of the SIP process, the timetable for the rest of the process and the on- and non-road control measures at the H-GAC SIP website: http://www.h-gac.com/taq/airquality/sip/mobile/default.aspx

Sincerely, Shelley W hitworth Air Quality Program Manager

### APPENDIX E

Overview of the Transportation Control Measures to Be Included as Part of the HoustonGalveston-Brazoria Eight-Hour Ozone State Implementation Plan SubmittalG:\HGAC\Reports\Final_051 009\Appendix E_051009.doc 

### E-1 Transportations Control Measures (TCMs) were revi ewed and chosen as part of the work of the TCM/VMEPs Working Group, which consisted of local government representatives. This committee worked to evaluate projects in the cu rrent Transportation Improvement Plan (TIP) for the Houston-Galveston-Brazoria for possible desi gnation with TCM status in the SIP. Once projects were singled out for in clusion, project sponsor s were notified and agreed to upgrading their project(s) to TCM status. The Technical Advisory Comm ittee and H-GAC staff reviewed the responses to these notificati ons and narrowed the possible candidates to the attached list.G:\HGAC\Reports\Final_051009\Appendix E_051009.docE-2RECOMMENDED TRANSPORTATIONCONTROL MEASURE PROJECTSCSJ #MPO ID #SponsorStreetDescriptionNOxEmissionReduction(tons/day)CostEffectiveness($/ton)0912-72-145 11972GreaterSoutheastManagementDistrict HolmanPedestrianImprovements 0.0001862 253,8710912-72-146 11973GreaterSoutheastManagementDistrictElgin, Ennis,AlabamaPedestrianImprovements 0.0004562 172,0660912-72-147 11006Uptown HoustonAssociation WestheimerPedestrian / TransitImprovementProgram 0.0137628 85,0270912-71-544 2930City of HoustonColumbiaTap Rail toTrail Construct Bikeway 0.0002721 4,376,2480912-71-801 10350City of HoustonColumbiaTap UnionStation Trail12' Wide ConcreteShared Use Pathwith 5’ Bike Lane 0.0005840 692,2740912-71-655 6085City of HoustonTerryHershey ParkWest Houston OnStreet BikewayNetwork (Phase 2) 0.0001653 3,420,128Total0.0154266

### APPENDIX F

Detailed Evaluations for On-Road Control StrategiesG:\HGAC\Reports\Final_051009\Appdx_F_05100 9\BControlMeasure1-Bike-EM_051009.doc 

### Control Measure: #1 and #32, Bicycle and pedestrian actions Category: On-road Author: Barbara Joy, Earth Matters

DESCRIPTION

Bicycle measures encouraged by bicycle and pedestrian action groups include new bicycle lanes, new bikeway plans, and encour aging greater use of existing lanes instead of vehicle use. Bicycle action groups and other bicycle measures included in the Houston-Galveston Area Council’s (H-GAC) Regional Bikeway Plan from the 2035 RTP are evaluated below. The Regional Bikeway Plan, described in Appendix G of the 2035 RTP is intended to serve as a guide for i nvestment, interagency coordination and best practices in developing facili ties for bicyclists in the 8-county Houston-Galveston Transportation Management Area (TMA). The plan may be reviewed at http://2035plan.org/docs/final/Appendix%20G- %20Draft%20Ped%20Bike%20RTP%20Appendix.pdf . The plan acknowledges that the current level of bicycle travel within the Transportation Management Area (TMA) is not precisely known, making it difficult to define a benchmark for increases in bicycle travel replacing vehicular travel. Unfortunately, th e Houston-Galveston region also has one of the highest rates of crashes involving motorists and bicyclists in Texas.

Notable examples of local bikeway networ ks include Alvin, Conroe, Houston, Lake Jackson, La Porte, Missouri City, Pasade na, Sugar Land, and The Woodlands. H-GAC plans to continue to work with local entit ies to identify projects that further the development of local bikeway networks as part of the overall regional transportation system.

There are two employment centers within the TMA that generate a significant level of bicyclist commuters: the Texas Medical Center in Houston and the University of Texas Medical Branch (UTMB) in Galveston. Th e Texas Medical Center (TMC) draws the greatest amount of commuter bicyclists of any employment center in the TMA. According to the 2000 census, there were 50,238 work trips, of which 36,973 drove alone, 7,927 carpooled, 4,018 took the bus, 430 walked, 379 biked, and 511 used other means (motorcycle, taxi, permanent teleco mmute). The 430 walking trips and the 379 biking trips represent 0.9% and 0.8% respectively of all trip s. The Texas Medical Center has the highest concentration of bicyclist trips within a census tract in the region (even greater than Downtown Houston) , and the third highest concen tration of walking trips in the region (after downtown and the University of Texas Medical Branch in Galveston). Recent observations made by H-GAC and TMC st aff indicate that over 1,000 bicyclists now commute to the Texas Medi cal Center on a daily basis.

The 2000 Census indicated that UTMB had 10,470 daily work trips. Of these 89% were by private vehicle, 1.3% by bus, 2.2% by bicycl e and 5.3% walking trips. These are much higher than the regional av erage of 0.3% by bicycling and 2.1% by walking.G:\HGAC\Reports\Final_051009\Appdx_F_05100 9\BControlMeasure1-Bike-EM_051009.doc 

### ANALYSIS



### This analysis is based on the assumption that every major employment center in the Houston metropolitan area grows to the same level of bicycle use as the UTMB, due to the expansion of regional bikeway plans, th e high cost of drivi ng, and the efforts of bicycle and pedestrian action groups. Accordi ng to modeling results for 2018 from the HGAC transportation model the following shows employment by major employment center in Houston.

Table 1. Employment at Major Employment Centers in Houston Area in 2018 1



### .

Employment Center 2018 Employment Bellaire/Pin Oaks 19,837 Brookhollow 49,843 CBD 146,600 Clear Lake/NASA 42,444 Galleria 141,801 Greenspoint 94,052 Greenway Plaza 60,416 Medical Center 135,749 Northwest Crossing 53,225 Sharpstown 38,512 The Woodlands 30,379 West Houston 105,335 Westchase 80,799 Total 998,992



### On an average weekday it is assumed that 2.2 pe rcent of these employees bike to work an average of 3.5 miles each way. This woul d mean 21,978 people per day are commuting by bicycle by 2018 and reducing 153,845 miles of tr avel per day, if they were previously driving, and a weekday/weekend adjustment is applied. The estimate also assumes that nearly zero individuals were biking in the baseline. This is consistent with the 0.3% figure cited in the description above.

EMISSIONS ANALYSIS

The emissions analysis utilized the ba sic process suggested by the MOSERs methodology, as follows:

Variables: EF A 

### : Speed-based composite emission factor after implementation (NO x 

### , VOC, or CO) grams/mile)

EF B 

### : Speed-based running composite emission factor before implementation (NO x 

### , VOC, or CO) (grams/mile)

1 Personal Communication Sharon Ju, H-GAC to Barbara Joy, Earth Matters. November 10, 2008.G:\HGAC\Reports\Final_051009\Appdx_F_05100 9\BControlMeasure1-Bike-EM_051009.doc 

### N VA 

### : Number of vehicles after implementation

N VB 

### : Number of vehicles before implementation

TEF AUTO 

### : Auto trip-end emission factor (NO x 

### , VOC, or CO) (grams/trip)

TL A 

### : Average auto trip length after implementation (miles)

TL B 

### : Average auto trip length before implementation (miles)

VMT A 

### : Vehicle trips after implementation

VMT B 

### : Change in VMT as a result of implementation

It was assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emi ssion factors and the a ssumption that access to alternative modes is not through SOV use.

Equation:

Daily Emission Reduction =

C = VMT B 

### * EF A =



### 153,845 * 0.171 gram/mile NOx/454 = 57.9 lb/day, and 0.03 tpd NOx

and

153,845 * 0.231 gram/mile VOC/454 = 78.3 lb/day, and 0.04 tpd VOC.

COST EFFECTIVENESS

H-GAC’s current TIP contains ov er 41 pedestrian and bicyclis t projects, representing an investment in nearly of $87 million. The 2025 RTP, with subsequent amendments, contains an additional 61 pedest rian and bicyclist projects wi th a projected cost in excess of $96 million. In addition, a number of local governments have made significant local funding commitments to bikeway developmen t in their current Capital Improvements Programs. The cost effectiveness evaluati on assumes that a $200 million investment is made to implement all pedestrian and bicy cle projects in the TIP and RTP and local plans, and that this invest ment is made over a 20 year period. Using a simple linear assumption, this would equate to $10 million per year.G:\HGAC\Reports\Final_051009\Appdx_F_05100 9\BControlMeasure1-Bike-EM_051009.doc 

### Total emission savings from NOx and VOC combined is 25.6 tons per year; cost effectiveness is therefore $390,625 per ton.

COMMENTS

This evaluation is based on assumptions consistent with current statistics and implementation of planned bike and pedestrian projects in the 2008 RTP and TIP. It may be considered for use in ozone plan after review of key assumptions.

SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions (tpd) 

### % Tpd Cost Effectiveness ($/ton) 1 Bicycle and pedestria n action groups Growth in biking to consistent with current UTMB levels On-Road – Light-duty vehicles 40.7 VOC 30.3 NOx 0.1 0.1 0.04 0.03 $390,625G:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 3 Clean Cities_051009.doc 

### Control Measure: #3, Private Sector Clean Fueled Fleets Category: On-road Author: Chris Lindhjem, ENVIRON

DESCRIPTION

This measure seeks to reduce on-road vehicle emissions by rapid tur nover to newer lower emitting engines, retrofit of existing engines with approved devices, or new lower emission technologies. These programs have been mandated or voluntarily implemented with federal incentives or state funding from programs like TERP.

In Houston, H-GAC administers a program under The Clean Cities/Clean Vehicles Program ( http://www.houston-cleancities.org/# ) where Congestion Mitigation and Air Quality (CMAQ) funds are distributed to re place and retrofit lower emitting heavy-duty.

In Texas, the popular TERP program has been successful in co-funding many emission reduction projects of many different types incl uding on-road trucks, construction and offroad equipment, marine vessels, and locomo tives. To date, about $300 million of projects have been approved in the HGB area from 2002 through 2008 with the most of the funding occurring in the 2004 through 2008 period. Because the most recent projects have just been approved, not all of the em ission reductions have b een realized and are still pending

IMPLEMENTATION FEASIBILITY

Programs of this type have been successfu lly established in Hous ton, Los Angeles, and Sacramento. The program implementati on relies on a partnership between the transportation planning or ganization, H-GAC, and TxDOT and FHWA to properly distribute CMAQ dollars. H-GAC has dedicate d staff time to administer the program addressing funding, preparing contracts, c onducting verifications, reporting, and other functions of this program.

PUBLIC ACCEPTANCE

The program has been successful in Houston in the most recent years. The similar TERP program has also demonstrated high participa tion and has lowered the cost per emission reduction during the 2005 fiscal year from previous years.

ANALYSIS

The benefit of a voluntary retrof it or replacement program targ eted at emission reductions in the 2015 - 2018 timeframe would center on th e replacement of trucks with thoseG:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 3 Clean Cities_051009.doc 

### meeting the 2010 emission standards that ca ll for a dramatic reduction in the NOx emission rates as shown in the Table 1 summary of emission standards.

Table 1. Emission standards for heavy-duty truck engines (differences exist for buses and whole vehicles and a pull ahead of the implementation date for many truck engines in the 2003 model year by a consent decree)



### . Federal Heavy-Duty Truck Standards (G/bhp-hr)

MODELYEAR HC 1 CO NOx PM HC+NOx Opacity 1974-78 --- 40.0 --- --- 16.0 No 1979-83 1.5 25.0 --- --- 10.0 No 1984-87 1 1.3 15.5 10.7 --- --- No
1988-89 1.3 15.5 10.7 0.60 --- Yes

1990 1.3 15.5 6.0 0.60 Yes 1991-93 1.3 15.5 5.0 0.25 --- Yes 1994-97 1.3 15.5 5.0 0.10 --- Yes 1998-03 1.3 15.5 4.0 0.10 --- Yes 2004-2006 0.5 2 15.5 2.0 3 0.10 2.5 2 Yes 2007 (50% of Fleet) <0.5 15.5 ~1.1 0.01 --- Yes 2010 0.14 2 15.5 0.2 0.01 --- Yes 1 – Test procedure change. 2 – HC standards shown are total hydrocarbons except for model year 2004-2006 when it is NMHC. 3 – Assumes 2.5 g/bhp-hr (NOx+NMHC) with a 0.5 g/bhp-hr NMHC cap effective October 2002.



### The analysis of the cost and effectiveness of these programs relies on the progress of the TERP and H-GAC Clean Cities programs. Other programs such as the California Carl Moyer program demonstrate similar costs a nd effectiveness, but rely on evaluations specific to California.

Through 2008, the H-GAC Clean Cities/Clean Vehicles program had committed funding to many projects. The projects include altern ative fueled vehicles, hybrid-electric drive trains, and clean diesel engines. Thes e projects produced NOx, PM, and some VOC emission reductions. Indivi dual truck replacement/retrofit projects funded by CMAQ in the Houston area in 2008 av eraged approximately $20,000 to $40,000 per vehicle with typical clean engine costs running at a bout $60,000 to $80,000 focusing primarily on the larger engines. TERP funded projects have been running at an average of just over $40,000 per truck project.

Table 6 indicates most recent information on the benefit and cost per project from the TERP program in the HGB area. The most typical project was to replace current equipment that would not necessarily be replaced otherwise. However, regardless of the inflation rate, the new engine costs are expect ed to increase because of the new emissions standards, so the current TERP figures may underestimate the cost of future projects. Also, some TERP projects combine two or mo re categories of project types, and the figures here can vary depending upon the size of the engine and other considerations. The figures in Table 6 are approximate and may change as the projects are implemented and reviewed.G:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 3 Clean Cities_051009.doc 

### Table 2. TERP implemented and pending projects in HGB

Project Type Total Cost Number of Projects Cost per Project Total NOx Reduced (tpd) NOx Reduction per Project (tpy) Locomotive $75,996,969 116 $655,146 7.29 22.95 Marine $39,216,837 400 $98,042 5.99 5.46 Non-road $81,284,069 1,995 $40,744 7.86 1.44 On-road $103,974,922 1,867 $55,691 10.63 2.08



### EMISSIONS AFFECTED

This measure would affect about 21 tpd of NOx in 2018 on-road heavy-duty emissions in the eight-county HGB ozone nonattainment ar ea. This measure would address heavyduty diesel, heavy-duty gasoline, and buses as shown in Table 3.

Table 3. On-road weekday emissions 8-County totals (tpd)

Pollutant Light-duty Heavy-Duty Gasoline Heavy-Duty Diesel Total VOC 40.69 0.80 3.15 44.64 CO 691 13 5 709 NOx 30.31 1.88 19.67 51.69



### EMISSIONS BENEFIT

Table 4 provides the average emissions fact ors, registration dist ribution, and mileage accumulation derived from the MOBILE input files used in the HGB emissions modeling. About 15% of the NOx emissions were projected to come from 2001 and early model year trucks in 2018, but 50% from the model years 2002 through 2009.

Table 4. Class 8b Truck approximate emission rates
Model Year Age VOC CO NOx Mileage Accumulation Registration Distribution
1994- 24 0.66 3.08 22.79 11,765 0.0099 1995 23 0.65 3.06 22. 79 12,979 0.0031 1996 22 0.64 3.03 22. 17 14,319 0.0035 1997 21 0.64 3.01 22. 41 15,796 0.0041 1998 20 0.64 3.00 21. 08 17,426 0.0043 1999 19 0.63 2.98 18. 17 19,224 0.0057 2000 18 0.63 2.97 18. 15 21,208 0.0074 2001 17 0.63 2.95 18. 13 23,396 0.0080 2002 16 0.62 2.93 12. 43 25,810 0.0090 2003 15 0.61 2.91 8. 88 28,473 0.0058 2004 14 0.48 2.88 7. 78 31,411 0.0216 2005 13 0.47 2.86 7. 75 34,652 0.0282 2006 12 0.46 2.83 7. 71 38,228 0.0366 2007 11 0.26 0.24 4. 21 42,172 0.0345 2008 10 0.26 0.24 4. 18 46,523 0.0419 2009 9 0.26 0.24 4.15 51,324 0.0586 2010 8 0.26 0.24 0.61 56,620 0.0895 2011 7 0.26 0.24 0.61 62,462 0.1050G:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 3 Clean Cities_051009.doc Model Year Age VOC CO NOx Mileage Accumulation Registration Distribution
2012 6 0.26 0.24 0.61 68,907 0.0665 2013 5 0.26 0.24 0.61 76,017 0.0298 2014 4 0.26 0.24 0.61 83,861 0.0523 2015 3 0.26 0.24 0.61 92,514 0.0426 2016 2 0.26 0.24 0.61 102,060 0.0943 2017 1 0.26 0.24 0.61 112,590 0.1110 2018 0 0.26 0.24 0.61 124,208 0.1269



### Replacing an older truck would produce emi ssion reductions through the use of lower emission vehicles. A better case and a most expensive case were modeled to determine the range of benefits and cost effectiveness. A better case scenario is to replace a model year 2000 truck with one of 2010 or later model years. Using the mileage accumulation for a 2000 model year truck and the difference in the emission rates would result in 0.009 tpy VOC and 0.41 tpy NOx. A less beneficial ca se is to replace a 2008 model year truck with a 2010 and later truck resulting in 0 VOC and 0.183 tpy NOx. Replacing two thousand older vehicles expected to be in use in 2018 with those meeting 2010 or later emissions standards would result in a bout 1 to 2.5 tpd emission reduction.

COST AND COST-EFFECTIVENESS

The current cost of on-road heavy-duty projects in both the TERP and H-GAC Clean Cities program has been running $20,000 to $40,000 per project. The better case and lower benefit case of replacing a 2000 a nd 2008 truck respectivel y used a project (remaining useful) life of 5 years for th e 2000 truck and 10 years for the 2008 truck replacement. Applying the cost range, the life, and the benefit of the replacement examples, the cost effectiveness is expect ed to range from $11,000 to $25,000 per ton of NOx removed. Some small VOC benefit woul d also be found but not accounted for in this analysis. This is somewhat higher than the TERP program has achieved to date, but that is primarily due to the lower emissi on benefits from the replacement of trucks meeting more stringent emission standards.

SUMMARY OF RESULTS

Expected Emission Reduction Measure # Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. CostEffectiveness ($/ton)
3 Clean Fleet Vehicle Procurement Policy/Clean Fleet Program Maintain a fleet program that addresses clean vehicle acquisitions of

public and private fleets. On-roadHeavyduty Vehicles 21.6 5 – 12% 1 – 2.5 $11,000 - $25,000 NOxG:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 3 Clean Cities_051009.doc 

### REFERENCES

H-GAC, “Clean Cities and Clean Vehicles,” http://www.houston-cleancities.org/G:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 7 Electri c Vehicles_051009.doc 

### Control Measure: #7, Zero Em ission (Electric) Vehicles Category: On-road Author: Chris Lindhjem, ENVIRON

DESCRIPTION

The electric vehicle control measure consis ts of the voluntary inclusion of a greater percentage of zero emission vehicles (ZEVs) or zero emitting travel through the use of plug-in hybrids or other vehicles. This could occur through new purchases or a replacement program for existing vehicles.

IMPLEMENTATION FEASIBILITY

A study completed by National Renewable Ener gy Laboratory compares the near- and far-term scenario of specifications and retail prices between conventi onal vehicles (CVs), hybrid electric vehicles (HEVs) and plug- in hybrid-electric vehicles (PHEVs), summarized in Table 1 and 2, respectively. Plug-in hybrid-electric vehicles are characterized by a “PHEVx” notation, where “x” typically denotes the vehicle’s allelectric range (AER) – defined as the distan ce in miles that a fu lly charged PHEV can drive before needing to operate its engine. By this definition, a PHEV20 can drive 20 mi (32 km) all-electrically on the test cy cle before the first engine turns-on. 1



### In addition, there are two main ZEV types in development: electric-only vehicles and hydrogen fuel cell vehicles (FCVs). Electri c vehicles have been developed, but are generally only applicable for limited range appl ications. Fuel cell vehicles are currently a developing technology considered to be a possible alternative to gasoline/diesel vehicles in the future.

PUBLIC ACCEPTANCE

Technology needed to adopt this measure may not be cost-effective and could potentially be burdensome to vehicle manufacturers and co nsumers for such specialty vehicles. The program could target specific niches to partially achieve emission reductions. Options include targeting public or pr ivate sector fleets as demonstration programs for the implementation of ZEV technology and providing the infrastructure.

ANALYSIS

This measure was analyzed by comparing the emissions and costs compared to conventional vehicles. ZEVs were assumed to produce no emissions, so for example

1 “Cost-Benefit Analysis of Plug-In Hybrid Electric Vehicle Technology” by A. Simpson, National Renewable Energy Laboratory.G:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 7 Electri c Vehicles_051009.doc 

### emissions associated with fuel (hydrogen) and electricity production were not included in this analysis.

EMISSIONS AFFECTED

This measure could affect about 40 tpd ofVOC and 30 tpd of NOx 2018 on-road lightduty emissions in the eight-county HGB oz one nonattainment area. However, the most likely vehicle types to be replaced by zero emitting activity are the smaller passenger cars shown in Table 1.

Table 1. On-road weekday emissions 8-County totals (tpd)

Pollutant Light-duty Passenger Cars Light-duty All Heavy-Duty Gasoline All Heavy-Duty Diesel All Total VOC 24.8 40.69 0.80 3.15 44.64 CO 424 691 13 5 709 NOx 16.6 30.31 1.88 19.67 51.69



### EMISSIONS BENEFIT

The emissions benefit of replacing the convent ional vehicles (CV) with zero emitting cars by 2018 can be estimated by comparing the emission estimates for late model vehicles. Table 2 provides the expected em issions for late model vehicles.

Table 2. Passenger car emission rates

Model Year VOC CO NOx Annual Mileage 2009 0.186 4.410 0.122 9,456 2010 0.164 4.099 0.110 9,947 2011 0.144 3.777 0.098 10,463 2012 0.126 3.433 0.086 11,006 2013 0.111 3.069 0.074 11,577 2014 0.096 2.687 0.063 12,178 2015 0.083 2.284 0.051 12,810 2016 0.072 1.861 0.040 13,475 2017 0.061 1.484 0.030 14,174 2018 0.053 1.133 0.024 14,910 10 year total (tons) 0.014 0.353 0.009 119,996 Per Year Emissions 0.0014 0.0353 0.0009 12,000



### COST AND COST-EFFECTIVENESS

According to Table 3, PHEVs give the highe st cost compared to CVs and HEVs. The retail prices range from $29,435 to $50,184 with engine horsepower of 105 hp to 129 hp. Besides, HEVs are more expensive than CVs with comparable specifications.G:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 7 Electri c Vehicles_051009.doc 

### Furthermore, in t h 

### e long-term scenario shown in Table 4, HEVs and PHEVs achieve lower cost-of-ownership over time whereas CVs maintain at the same retail price.

Table 3. Near-Term Scenario PHEV Specifications – Optimum DOH Vehicles 1
Vehicle Curb Mass (kg) Engine Power (kW/hp) Motor Power (kW/hp) DOH Battery Energy (kWh) P/E Ratio (1/h) SOC Window Retail Price (US$) CV 1429 122 / 163 -- -- -- -- -- $23,392 HEV0 1451 78 / 105 38 / 51 33% 1.5 33.4 37% $28,773 PHEV2 1451 78 / 105 38 / 51 33% 1.5 33.4 37% $29,435 PHEV5 1505 80 / 107 42 / 56 35% 3.6 15.9 39% $31,447 PHEV10 1571 82 / 110 44 / 59 35 6.9 8.6 41% $34,180 PHEV20 1678 85 / 114 47 / 63 35% 12.7 4.9 47% $38,935 PHEV30 1759 89 / 119 49 / 66 36% 17.2 3.8 53% $42,618 PHEV40 1824 91 / 122 51 / 68 36% 20.8 3.3 59% $45,655 PHEV50 1880 94 /126 52 / 70 36% 23.9 2.9 66% $48,162 PHEV60 1923 96 / 129 53 / 71 36% 26.4 2.7 73% $50,184



### Table 4. Long-Term Scenario PHEV Specifications – Optimum DOH Vehicles 1
Vehicle Curb Mass (kg) Engine Power (kW/hp) Motor Power (kW/hp) DOH Battery Energy (kWh) P/E Ratio (1/h) SOC Window Retail Price (US$) CV 1429 122 / 163 -- -- -- -- -- $23,392 HEV0 1412 77 / 103 36 / 48 32% 1.5 32.8 37% $26,658 PHEV2 1412 77 / 103 36 / 48 32% 1.5 32.8 37% $27,322 PHEV5 1445 78 / 105 41 / 55 34% 3.5 15.7 39% $28,365 PHEV10 1481 79 / 66 42 / 56 35% 6.6 8.5 41% $29,697 PHEV20 1531 81 / 109 43 / 58 35% 11.8 4.9 47% $31,828 PHEV30 1569 82 / 110 44 / 59 35% 15.9 3.7 53% $33,533 PHEV40 1598 83 / 111 45 / 60 35% 19.0 3.2 59% $34,839 PHEV50 1618 84 / 113 45 / 60 35% 21.6 2.8 66% $35,857 PHEV60 1636 84 / 113 46 / 62 35% 23.6 2.6 73% $36,681
CV: Conventional vehicles DOH: Degree-of-hybridization P/E Ratio: Power-to-energy ratio SOC: State-of-charge



### According to Toyota Senior Vice President Jim Wilson, an electric vehicle costs $20,000 more to build than a comparable gasoline- powered car despite years of research. CARB staff estimates a cost premium of between $8,000 and $20,000 for production of an electric zero emission vehicle (ZEV) with perf ormance characteristics inferior to those of a conventional vehicle. 2



### Table 5 illustrates the specification compar ison between zero emission light and heavyduty vehicles. The retail costs for light- duty vehicles range from $12,000 to $53,000 with horsepower from 5 hp to 72 hp. Zero emi ssion heavy-duty vehicles are still under development, so a cost comparison would not be worthwhile to make at this point.

2 http://www.rff.org/RFF/Documents/RFF-Resources-142-zeroemmis.pdfG:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 7 Electri c Vehicles_051009.doc 

### Table 5. Comparison between light and heavy-duty vehicles. Specification Manufacturer/Model Name Retail Cost Component Power Maximum Speed Light-duty Vehicles Miles Electric Vehicles XS 500 (full electric highway speed sedan) $35,000 3 Lithium-ion batteries 5.6 hp 105 mph

Miles Electric Vehicles ZX40ST ( Electric Truck) $18,400 2 72-volt electric motor and a 150- amphour battery pack . (50-60 miles per charge) 5.6 hp 25 mph

ZX40S (Electric Truck) $19,499 2 72-volt electric motor and a 150- amphour battery pack . (50-60 miles per charge) 5.6 hp 25 mph

ZENN (Model: NEV\LSV, 2-seat battery electric vehicle) $12,000– $16,000 4 Lead-acid batteries (30–50 miles per charge) 5 hp 25 mph

General Motors EV1 (Battery electric vehicles) $40,000 5 Gen II 1999, NiMH (150 miles per charge) 72 hp 80 mph

Honda EV Plus $53,000 4 12 V NiMH (80–110 miles per charge) 66 hp 80+ mph Toyota RAV4 EV $40,000 4 95 amp-hour NiMH battery pack (80- 120 miles per charge) 67 hp 78 mph

Toyota Prius Hybrid $19,995 6 274V NiMH battery pack 58 hp Heavy-duty Vehicles Navistar International $85,000 340 Volt Lithium Ion Battery 225 hp Balcon Electric Truck 7 $208,500



### To provide a cost comparison, a figure of $20,000 was used as the cost differential and a 15-year life was used resulting in an averag e annual capital cost of $1675 per year. If lower operating costs occur with these vehicles, then the cost differential is overstated.

The cost effectiveness for replacing late m odel vehicles with zero emitting vehicles however is expected to be quite high by dividing the $1675 by the annual emissions figures in Table 2. This results in a cost effectiveness of over $1 million per ton of emissions reduced for VOC and NOx separately. In order to bring th e cost effectiveness down to that of other strategi es, the relative cost of produc tion should be no more than $2,000 more per vehicle than conventional vehicl es to make the air quality benefit close to other mobile sources measures.

3 http://en.wikipedia.org/wi ki/Zero_emission_vehicle

4 http://en.wikipedia.org/wiki/ZENN

5 http://en.wikipedia.org/wiki/List_of_production_battery_electric_vehicles_(table)

6 http://en.wikipedia.org/wiki/Toyota_Prius

7 http://www.ens-newswir e.com/ens/may2008/2008-05-21-092.aspG:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 7 Electri c Vehicles_051009.doc 

### SUMMARY OF RESULTS

Expected Emission Reduction Measure # Name Description Affected Sources Affected Emissions (tpd) % tpd Est. Cost Effectiveness ($/ton)

7 Zero emission vehicles 10,000 ZEV on the road Onroad - LDGV 24 VOC, 16 NOx 0.15% VOC, 0.15%

NOx 0.04 VOC, 0.02 NOx, $0.7 million VOC + NOxG:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 11 Clean Diesel_051009.doc 

### Control Measure: #11, Cleaner Diesel Fuel Category: On-road Author: Chris Lindhjem, ENVIRON

DESCRIPTION

The cleaner diesel control measure would consis t of a change in diesel fuel from Texas Low Emission Diesel fuel (TxLED) to either cetane additive enhanced (CAE) or FischerTropsch (FT) diesel fuel. It is anticipated that, due to the nature of CAE and FT diesel technology, this program may not be a mandatory change to CAE or FT diesel, but may more likely be for a localized or demonstra tion project on specific Class 8b Heavy Duty Truck (HDT) fleets.

TxLED fuel contains less than 10 percent by volume of aromatic hydrocarbons and has a cetane number of 48 or greater. CAE diesel w ould consist of diesel to which additives were supplemented, producing a cetane number increase of 5 points with no changes in other parameters from TxLED fuel. FT diesel fuel would consist of typical FT fuel with a cetane number of 74 and an aromatic co ntent of 0.1 percent (Clark et. al., 1999).

IMPLEMENTATION FEASIBILITY

Large-scale production of Fischer-Tropsch fuel s are currently being researched by several oil companies (EPA, 2002), however, production is curr ently scarce and costly. Cetane additives are available for implementation; however, distribution issues would make it difficult to make the use of cetane enhancers mandatory over the entire HGB. Therefore, this measure was evaluated as a targeted m easure, consisting of replacing TxLED fuel in 10% of the heavy-duty truck fleet with either FT or CAE fuel.

PUBLIC ACCEPTANCE

This measure would require changes in diesel production associated with each technology. Increased costs associated w ith this production c ould potentially be burdensome for diesel manufactures that w ould need to change their operations to conform to new standards, as well as for diesel consumers due to increased diesel costs. It is expected that grant funding could ease this burden.

ANALYSIS

This measure was analyzed by comparing the emissions associated with current TxLED fuel for heavy-duty vehicles (including buses ) with FT and CAE diesel fuel. Emission reductions of 12% (Clark et. al. 1999) and 1.3% (EPA, 2003) were estimated for FT, and CAE fuel, respectively. Based on the on-road emissions inventory for 8-counties in theG:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 11 Clean Diesel_051009.doc 

### HGB nonattainment area (TCEQ 2008), heavy-duty diesel vehicles totaled about 19.7 tpd of NOx emissions, of which, 12.9 tpd was fr om Class 8 only. A reduction of 0.02 tpd and 0.15 tpd is estimated for the implementation of FT and CAE fuel in 10% of the Class 8 heavy-duty fleet, respectively.

The average emissions rates for Class 8a (33,000 to 60,000 lbs gross vehicle weight rating) and Class 8b are shown in Table 1. Al ong with the average fuel economy derived from the MOBILE6 technical documentation, th e emissions per gallon of fuel consumed was calculated.

Table 1. Heavy heavy-duty truck NOx emissions
Class 8a Class 8b Transit Bus Emission Rates g/mile g/mile g/mile NOx Emissions (g/mile) 2.773 1.422 4.739 Fuel Economy (mpg) 6.59 6.30 3.79 NOx Emissions (g/gallon) 18.271 8.960 17.962



### EMISSIONS AFFECTED

The emissions affected could include a ll diesel engines (about 19.7 tpd, prior to adjustments for ambient conditions and othe r emission reduction measures) or to the entire or portions (estimated here at 10%) of fleets of la rger Class 8 heavy-duty trucks that represent 12.9 tpd of NOx.

EMISSIONS BENEFIT

Estimated emission reductions from this measur e for the fleets representing 10% of Class 8, or if applied across all dies el vehicles operating in the area would range from 0.02 tpd NOx reduction with cetane additives on 10% of the fleet to 2.36 tpd for Fischer-Tropsch applied across all diesel vehicles.

COST AND COST-EFFECTIVENESS

Estimates from vendors indicate that cetane additives that increas e cetane levels of 5 points would cost approximately $0.08 per gallon.

The cost of Fischer-Tropsch fuels ranges from $0.10 (cost to produce) up to $0.25 per gallon (to deliver under current market condi tions) more than California Diesel (CEC, 2003) 1 

### . The cost of these fuels however has be en decreasing due to advances in the technology and economies of scale, and will continue to decr ease if demand increases as it is beginning to in California. In Califor nia, FT fuels are increasingly sold as a neat fuel or a blend stock to produce Cali fornia reformulated diesel fuel.G:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 11 Clean Diesel_051009.doc 

### The best (lowest cost) cost-effectiveness scenario applies to the low end of the FT cost to the 12 % NOx emission reduction for Class 8a (de livery type or short drayage vehicles). Using 10 cents a gallon and the emission rate s in Table 1, the NOx reduction would be $41,000 per ton of NOx reduced. The highest cost-effectiveness s cenario applies the cetane enhancement cost and benefit to the la rger Class 8b truck emissions resulting in a cost effectiveness of $623,000 per ton of NOx reduced.

SUMMARY OF RESULTS

Expected Emission Reduction Measure # Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effectiveness ($/ton)

11 Cleaner Diesel

Fuel Cetane Additive Enhanced or Fischer Tropsch Diesel Fuel Onroad – Class 8B

HDT or all HDDV 1.3 to 19.7 NOx 1.3% - 12% 0.02 – 0.15 or 0.25 –

2.36 $41,000 - $623,000



### REFERENCES

CEC (2003), “Reducing Califor nia’s Petroleum Dependence”, A Joint Report of the California Energy Commission and Calif ornia Air Resources Control Board, P600-03-005F, August 2003.

Clark, et. al. (1999), Clark, Nigel, Mridul Gautam, D onald Lydons, Chris Atkinson, Wenwei Xie, 1999, “On-Road Use of Fi scher-Tropsch Dies el Blends”, SAE Technical Paper Series, 1999-01- 2251, Washington D.C., April 1999.

EPA. 2002, “Fact sheet: Clean Alternativ e Fuels: Fischer-Tropsch”, EPA420-F-00-036, http://www.epa.gov/otaq/consumer/fuels/altfuels/420f00036.pdf

EPA (2003), “The Effect of Cetane Numb er Increase Due to Additives on NOx Emissions from Heavy-Duty Highway Engines, Final Technical Report”, EPA420-R-03-002, February 2003.G:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC Measure 22 school buses_051009.doc 

### 1 Control Measure: #22, Dedicated F unding for School Bus Replacement Category: On-road Author: Hazel Barbour

DESCRIPTION

Acceleration of the replacement of older buses in school district fleets through a fund dedicated to helping meet the costs of purchasing new bus es to replace the older buses. Buses that are replaced should be scrapped.

IMPLEMENTATION FEASIBILITY

Apart from TERP funds, there is very little funding available fo r school bus purchase, e.g. EPA school bus grants (made available in Texas through the Blue Skyw ays Collaborative) fund retrofits of diesel powered school buses, not ne w bus purchases; EPA’s Smartway Clean Diesel Initiative funds trucks (school buses are not included); and CM AQ funds which can be used for diesel retrofits or engine replacement are unlikely to be available to replace the complete vehicle.

Dedicated funding from TERP could be made ava ilable to HGAC in a format similar to the TERP block grants which the General Land Office and the Rail Road Commission have received to help fund purchase of natural gas and propane vehicles, respec tively, and these funds could be made available to school districts in all 8 counties in the HGB area. While it could be possible to consider utilizing Local Initiative Project funds (excess LIRAP funds) for this program, HGAC would be required to come up with 100% matchi ng funds, and, if Chambers, Liberty and Waller counties do not implement the I/M program, LIRA P funds cannot be utilized in these three counties.

Having one organization in the HGB area focuse d on providing funds for school bus purchases should make communication with the school di stricts easier and, in turn, make it less burdensome for districts to submit applications. However, for many school districts, as their student population grows resulting in the need for a larger school bus fleet, the desire is often to purchase new buses but not remove older buses for the fleet.

Implementation of this measure may need to be delayed until 2011/2012. To gain the most emissions reduction benefit, the aim should be to expedite the purchase of buses which meet the 2010 NOx standard of 0.2 grams/bhp-hr. Howeve r, at the point of writing, none of the manufacturers of school bus engi nes has announced the av ailability of an engine meeting this standard – it appears that Caterpillar will discontinue pr oduction of school bus engines completely and International is unlikely to pr oduce an engine to the 2010 standard until 2012. Even if a school district is cons idering using an alternative fuel such as LPG, it appears that General Motors, the only manufacturer of an LPG school bus engine, will discontinue production of this engine in 2010. Additi onally, if a TERP block grant for school bus replacement requires HGAC to operate under the current TERP requirements (cost effectiveness of $15,000 or less per ton NOx), it will be difficult to be able to offe r substantial sums toward the purchase of new buses which do not meet the 2010 NOx standard due to the relatively small number of miles driven by a school bus per year.G:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC Measure 22 school buses_051009.doc 

### 2 PUBLIC ACCEPTANCE

This measure should be well received by the public.

ANALYSIS

School districts are eligible to apply for TER P grants under the Replacement of On-road Heavy Duty Vehicles category. Grant re cipients are eligible for reimbursement of up to 80% of the eligible incremental costs for th e purchase or lease of the replacem ent vehicles, not to exceed an incentive amount that results in a cost-effectiv eness of $15,000 or less per ton of NOx reduced. The total incentive amount must not exceed 80% of the cost of the replacement vehicle minus the scrappage value received for the old vehicle (which TCEQ estimates at $1,000 per bus). Current estimate of the cost of a 75 passenger school bus meeting the 2010 NOx standard is around $90,000.

TERP rules require that the replacement bus must be certified to emit at le ast 25% less NOx than the bus being replaced. Any bus meeting the federal 2010 NOx standard (0.2 gms/bhp-hr) will emit 90% less NOx than a bus meeting the ea rlier 2004 NOx standard (2.0 gms/bhp-hr) and greater than 90% less NOx than buses manufact ured prior to 2004. Assuming that the cost effectiveness requirement of $15,000 or less per ton is retained in a program dedicated to school bus replacement and that such a program focuses on replacing a diesel powered bus with another diesel powered bus, an example scenario us ing the TERP calculation methodology could be as follows:

Purchase of one bus meeting the MY 2010 standards to replace one MY 1995 bus:

Original engine NOx emissi ons standard: 5.0 g/bhp-hr Replacement engine NOx emission standard: 0.2 g/bhp-hr Original engine conversion factor: 2.93 bhp-hr/mile Replacement engine conversion factor 2.99 bhp-hr/mile Annual miles traveled 20,000 1


### TXLed conversion factor 0.943 TXLed and Baseline NOx emission factor (g/mile) 5.0*0.943 = 4.715 4.715*2.93 = 13.81 g/mile Reduced NOx Emission factor (g/mile) 0.2*2.99 = 0.598 g/mile Grams/mile NOx reduction 13.212 Grams NOx reduced per year 264,240.0 gms NOx reduced per year 0.291 tons NOx reduction over activity li fe of 7 years 2.037 tons

1 20,000 is at the high end of school bus annual mileage.G:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC Measure 22 school buses_051009.doc 

### 3 To maintain the TERP requirement that cost e ffectiveness be $15,000 per ton or less of NOx, in this scenario the maximum amount per bus for which a school district could apply would be $30,450. The number of school buses at the end of the 2007 school year in the 70 school districts and charter schools in Harris, Brazoria, Fort Bend, Galveston, Montgomery, Chambers, Liberty and Waller counties was estimated by th e Texas Education Agency to be 8,574, with 31% (2,658) being greater than 10 years old. Assuming normal turnover from 2010 onwards would remove almost all of the remainder of th ese buses by 2018 (each ISD replacing an average of 10.5 buses per year); a dedica ted school bus fund could aim to accelerate the replacement of 25% of the fleet.

EMISSIONS AFFECTED

Emissions affected are on road h eavy duty diesel engine emissions.

EMISSIONS BENEFIT

The NOx benefit is estimated from replacing 25% of the current number of buses greater than 10 years old with buses meeting the 2010 HDDV NO x standard and assumes the average model year of the replaced buses to be MY 1995.

NOx reduction per year from 665 buses: 193.5 tons NOx reduction per day (using 250 day year): 0.774 tons per day Total NOx reduction over 7 years’ activity life for 665 buses: 1,354.6 tons

COST AND COST-EFFECTIVENESS

Maximum grant per bus to achieve cost effectiv eness not exceeding $15,000 per ton is calculated at $30,450. Total cost of the program at this level would be $20,249,250, not including HGAC administration costs of block grant.

SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Sources Affected Emissions (tpd) % tpd Est. Cost Effectiveness ($/ton)

22 Dedicated funding for school bus replacement Grant funding for school districts to replace 665 older buses. Onroad School Buses 2.25 NOx school bus emissions 34.4% 0.774 NOx $15,000 (not including HGAC admin costs)G:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC Measure 22 school buses_051009.doc 

### 4 

## REFERENCES

Texas Education Agency: school bus data as at end of school year 2006/2007 provided by Forecasting and Fiscal Analysis.

TCEQ: Texas Emission Reduction Plan (TERP); http://www.tceq.state.tx.us/im plementation/air/terp/erig.html (TCEQ Emissions Reduction Incentive Grants Program Technical Supplement No. 1)



### EPA Blue Skyways Collaborative, www.blueskyways.org

EPA Smartway Initiative: http://www.epa.gov/otaq/smartway/transport/what-smartway/financing-clean-diesel-info.htm

TX Health and Safety Code; 382.220: Use of Funding for Local Initiative Projects

Personal contact with Jim Murinchak, Hays CISD and Kouros Hafizi, Austin ISD.G:\HGAC\Reports\Final_051009\Appdx_F_051009\ BControlMeasure47-Pa rkPrice-EM_051009.doc 

### Control Measure: #47, Commuter Parking Pricing Category: On-road Author: Barbara Joy, Earth Matters

DESCRIPTION

Parking is generally free and abundant for most commuters. Among commuters who drive to work, only 5% pay the full cost of pa rking and another 9% pa y a subsidized rate. Parking is not priced at 98% of U.S. work locations. (Litman, 2006)

In Houston, paid parking is only common in a very few locations, namely Central Houston and a few large employment centers, like the Texas Medical Center. Commuters are most likely to pay all or part of the cost of parking in the Houston CBD. According to parking inventories from 2005, there are almost 75,000 structured parking spaces in downtown Houston and another 27,000 spaces in surface lots. In 2003, the average daily price of parking in downtown Houston was $8.00, with monthly unreserved spaces averaging $165.00 and reserved sp aces averaging $245.00 per month.

There are also 2,300 metered spaces downtow n, which may be replaced by 750 multiplespace metering machines which would allow fo r cell phone or pre-paid card payment and better tracking of utilization (according to a Houston Chronicle article dated 3/5/06). This new technology also allows for variable pricing by time of day and demand.

Changing the price of park ing can affect mode choi ce and reduce VMT by shifting commute and other trips to al ternative modes. A 2001 parking management plan prepared for Central Houston, Inc, called for “a comp rehensive city-sponsored and promoted program to promote alternative means of tran sportation to the central business district.” (Moore and Assoc. 2001) According to th e online TDM encyclopedia, Vaca and Kuzmyak (2005) found that the price elasticity of vehicle travel with respect to parking pricing ranges from –0.1 to –0.3 (meaning th at a 10% increase in parking price would typically be expected to reduce vehicle trips by 1% - 3%, depending on the location, availability of transit and HOV options, demographics, etc.

A recent Congressional Budget Office (CBO) 1 

### , prepared in January 2008 and at the request of the Ranking Member of the Senate Budget Committee relates rising gasoline prices to changes in how fast people drive, th e volume of highway traffic, and rail transit ridership.

In January 2003 the average retail price for a gallon of gasoline in the United States was $1.50. It was last below $2 per gallon in February 2005, and for much of 2007, prices topped $3 per gallon, spiking to ov er $4 a gallon in summer of 2008.

1 Effects of Gasoline Prices on Driving Behavior and Vehicle Markets. Congressional Budget Office January 2008.G:\HGAC\Reports\Final_051009\Appdx_F_051009\ BControlMeasure47-Pa rkPrice-EM_051009.doc 

### The CBO study showed that freeway motorists have adjusted to higher prices by making fewer trips and by driving more slowly. CBO analyzed data collected at a dozen metropolitan highway locations in California, along with data on gasoline prices in California, to identify changes in driving patterns. On weekdays in the study period, for every 50 cent increase in the price of gasoline, the number of freeway trips declined by about 0.7 percent in areas wher e rail transit is a nearby substitute fo r driving; transit ridership on the corresponding rail syst ems increased by a commensurate amount. Median speeds on uncongested freeways declined by about three-quarters of a mile per hour for every 50 cents the price of gasoline has increased since 2003.

The CBO study implies a short-te rm elasticity of 0.2, which is consistent with many other studies of price elasticity. An elasticity of 0.2 will be applied to the Houston CBD given the income levels, location, and availability of HOV lanes and commuter transit services.

ANALYSIS

At this time, the best data on parking charge s, employment, and parking availability is from Central Houston. Most employees work ing in downtown Houston pay for some or all of their parking. Parking fees are most feasible where an existing market and infrastructure exists, as in Central Houston. As such, parking pricing would take the form of a parking surcharge to existing fees. It is estimated that the average cost of parking in downtown Houston was $15.00 per day in 2005. At a 3% per year growth rate, this would translate to $22 per day. A surcharge of 25% would increase this average fee to $27.50 per day. Increases in parking fees are known to shift some numbers of commuters to alternative modes, including carpooling. As such, preferential parking for carpools and vanpools is also recommended because some commuters would seek to share parking costs by sharing a ride. For this analysis, the commuters that might be subject to a parking surcharge and offered preferential parking are assume d to be located in Central Houston, where employees are most likely to pay so me or all of their parking costs.

There is a total of 3,182,938 em ployees projected for the H ouston-Galveston region in 2018. According to H-GAC 2 

### there are expected to be 362,600 employees in the CBD, Greenway Plaza/Bellaire and Texas Medical Center in 2018. In order to convert employees to vehicles, with which to apply th e price elasticity factor, it is assumed that each 100 employees generates 77 vehicle tr ips (based on an assumed CBD commute mode split of 70% SOV, 15% HOV, 10% transit, and 5%bike/walk/telework/CWW/other). Thus, 362,600 employees are assumed to generate 279,202 round trip vehicle trips.

EMISSIONS ANALYSIS

The emissions analysis utilized the ba sic process suggested by the MOSERs methodology, as follows:

2 Personal Communication Sharon Ju, H-GAC and Barbara Joy, Earth Matters Nov 10, 2008.G:\HGAC\Reports\Final_051009\Appdx_F_051009\ BControlMeasure47-Pa rkPrice-EM_051009.doc 

### Variables: EF A 

### : Speed-based composite emission factor after implementation (NO x 

### , VOC, or CO) grams/mile)

EF B 

### : Speed-based running composite emission factor before implementation (NO x 

### , VOC, or CO) (grams/mile)

N VA 

### : Number of vehicles after implementation

N VB 

### : Number of vehicles before implementation

TEF AUTO 

### : Auto trip-end emission factor (NO x 

### , VOC, or CO) (grams/trip)

TL A 

### : Average auto trip length after implementation (miles)

TL B 

### : Average auto trip length before implementation (miles)

VMT A 

### : Vehicle trips after implementation

VMT B 

### : Change in VMT as a result of implementation

It was assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emi ssion factors and the a ssumption that access to alternative modes is not through SOV use.

In this analysis VMT B 

### is derived by multiplying the number of employee vehicle trips by the elasticity associated with a 25% increase in average da ily parking rates (from $22 to $27.50 per day) resulting in a switch to alternat ive modes that would result in vehicle trip reduction. Total driving costs effective in the decision to respond to pa rking prices are the variable weekly costs of driving: gasolin e and oil plus parking. Insurance costs are factored in a different way and are not assume d to affect the response to an increase in parking price for the pur pose of this analysis.

According to H-GAC 3 

### 2002 costs of driving were 11.8 cents per mile considering gasoline, oil and maintenance. At a compounded growth rate of 3 percent per year it is expected that driving costs will be 18.9 cents per mile. For a 40-mile round trip to and from work, parking costs in the baseline are 1.8 cents per mile ($22/ 40 mile round trip). Total variable driving costs are therefore 20.7 cents a mile before the parking price increase and 21.15 cents per mile after. The to tal percentage increas e is 2 percent.

By multiplying the estimated number of vehi cle trips (279,202) by a price elasticity of – 0.2 and a change of 2.2 percent, we derive a 0.44 percent trip reducti on; the vehicle trip reduction is therefore estimated to be 1,228 daily round trips. The VMT reduction

3 Personal Communication Gao Shixin, H-GAC and Barbara Joy, Earth Matters Nov 11, 2008.G:\HGAC\Reports\Final_051009\Appdx_F_051009\ BControlMeasure47-Pa rkPrice-EM_051009.doc 

### associated with this trip reduction is deri ved by multiplying the average round trip work length (40.0 miles) weekdays, yiel ds 35,086 miles of reduction per day.

Equation:

Daily Emission Reduction = C = VMT B 

### * EF A =



### 35,086 * 0.171 gram/mile NOx/454 = 13.2 lb/day, and 0.007 tpd NOx

and

35,086 * 0.231 gram/mile VOC/454 = 17.9 lb/day, and 0.009 tpd VOC.

COST EFFECTIVENESS

No data on costs for Houston is available. Ho wever, the cost associated with a surcharge and preferential parking program will largel y be program planning and enforcement. This annualized cost could be around $5,000 for planning and $25,000 for enforcement. However, the surcharge, or a portion of it, could be used to defray program costs, especially enforcement. Conservatively, however, it is assumed that $30,000 per year would be spent. Annual combined reductions of NOx and VOC would be 5.84 tons per year. Therefore cost effectiveness would be $5,137/ton.

COMMENTS

This evaluation is based on na tional elasticities a nd may be considered for use in ozone plan after review of key assumptions.

SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions (tpd) % Tpd Cost Effectiveness ($/ton)

47 Parking surcharge 25% surcharge on parking in Central Houston On-RoadLightduty vehicles 40.7 VOC 30.3 NOx 0.02 0.009 0.007 $5,137 VOC+NOx



### REFERENCESG:\HGAC\Reports\Final_051009\Appdx_F_051009\ BControlMeasure47-Pa rkPrice-EM_051009.doc 

### Litman, 2006, “Parking Pricing – Direct Charges for Using Parking Facilities” in the Online TDM Encyclopedia, http://www.vtpi.org/tdm/tdm26.htm , updated February 2006.

Vaca and Kuzmyak, 2005. “Parking Pricing and Fees ” Chapter 13, TCRP Report 95, Traveler Response to Transportation System Changes, Transit Cooperative Research Program, Transportation Research Board

.

Walter Moore and Associates, Inc., Downtown Parking Management Program Planning – Houston Texas, prepared for Cent ral Houston, Inc., January 23. 2001.G:\HGAC\Reports\Final_051009\Appdx_F_051009\BCont rolMeasure51ParkCas hOut-EM_051009.doc 

### Control Measure: #51, Parking Cash-Out Category: On-Road Author: Barbara Joy, Earth Matters Inc

DESCRIPTION

Parking cash-out is a program where certain employers who provide subsidized parking for their employees can offer a cash allowance in lieu of a free or subsidized parking space. California enacted a parking cash-out la w after studies showed cash allowances in lieu of parking encourage employees to find al ternate means of commuting to work, such as public transit, carpooling, vanpooling, bicyc ling, or walking. Parking cash-out offers the opportunity to improve air quality and reduce traffic congesti on by reducing vehicle trips and emissions. It can also reduce an employer’s parking demand and reduce parking costs, which are estimated to be $432 annually per suburban parking space and $1,598 per urban space provided. (Thornton, 2005)

According to the online TDM encyclopedia ( http://www.vtpi.org/tdm/tdm8.htm ) Don Shoup (1997) found that total vehicle trips de clined by 17% after Parking Cash Out was introduced at various urban and suburban worksi tes, as illustrated in Figure 1 (from the online encyclopedia). These automobile trip reductions tend to increase over time: one employer found that solo commuting continued to decline each year after Parking Cash Out was introduced, as more employees f ound opportunities to reduc e their driving and take advantage of the benefit.

76%

14%
6% 3% 63%

23%

9% 4%

0% 20% 40% 60% 80%

Drive Alone Car Pool Ride Transit Bike/WalkCommute Mode Share Before Cash Out

After Cash Out



### Figure 1. Cashing Out Impacts on Commute Mode (Shoup, 1997).



### Parking Cash Out results in reduced autom obile commuting and increases in carpooling, transit and non-motorized travel.

In a later report, (Shoup, 2001), Shoup notes th at employer-paid parking is the most common tax-exempt fringe benefit offered to workers in the United States, and that 95 percent of American automobile commuters pa rk free at work. He notes that case studiesG:\HGAC\Reports\Final_051009\Appdx_F_051009\BCont rolMeasure51ParkCas hOut-EM_051009.doc 

### and statistical models suggest that, compar ed with driver-paid parking, employer-paid parking increases the number of cars driven to work by about 33 percent.

ANALYSIS

At this time there is little data upon whic h to support an anal ysis for the HoustonGalveston area. The number of employees who have free or subsidized parking at their worksites is unknown. However, employees who pa y all or some of the cost of parking are generally located in Central Houston a nd the Texas Medical Center. In addition, the precise number of employers who require empl oyees to pay or offer subsidized parking could be eligible for this program is unknown. Parking cash-out tends to work best where employers lease parking for their employees (c reating the incentive to participate). For this analysis, the commuters th at might be offered parking cash-out are assumed to be located in Central Houston or the Texas Medi cal Center. This analys is uses a hypothetical example in which 25 percent of downtown and medical center employees are offered a cash payment in lieu of free or heavily subsid ized parking. It is also assumed that the results in California are app licable to Houston, since ther e are no other case studies available. Therefore it is suggested that this analysis not be used as a formal control measure until there is some basis upon whic h to support a projected emission reduction.

There are a total of 3,182,938 employees project ed for the Houston-Galveston region in 2018. In 2004, there were 145,318 employees in Central Houston and 65,300 in the Texas Medical Center. With a growth rate of 3.0% (based on Central Houston, Inc. projections), this would equate to 318,579 employees in 2018. If 25%, or 79,645, of them are provided with parking cash out payments and there is a 17 percent reduction in each of their drivealone travel to work, the following emission reductions could be achieved.

EMISSIONS ANALYSIS

The emissions analysis utilized the ba sic process suggested by the MOSERs methodology, as follows:

Variables: EF A 

### : Speed-based composite emission factor after implementation (NO x 

### , VOC, or CO) grams/mile)

EF B 

### : Speed-based running composite emission factor before implementation (NO x 

### , VOC, or CO) (grams/mile)

N VA 

### : Number of vehicles after implementation

N VB 

### : Number of vehicles before implementation

TEF AUTO 

### : Auto trip-end emission factor (NO x 

### , VOC, or CO) (grams/trip)G:\HGAC\Reports\Final_051009\Appdx_F_051009\BCont rolMeasure51ParkCas hOut-EM_051009.doc 

### TL A 

### : Average auto trip length after implementation (miles)

TL B 

### : Average auto trip length before implementation (miles)

VMT A 

### : Vehicle trips after implementation

VMT B 

### : Change in VMT as a result of implementation

It was assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emi ssion factors and the a ssumption that access to alternative modes is not through SOV use.

In this analysis, VMT B 

### is derived by multiplying the number of employees offered parking cash-out (79,645) by their average round trip work length (40.0 miles) and applying a 17 percent reduction for an average of 4 out of 7 days per week (to account for weekends, holidays, vacations, and that few a lternative mode users use alternative modes every day; this part of the calculation assures that the estimate is an average daily reduction over any day of the week.

Equation:

Daily Emission Reduction =

C = VMT B 

### * EF A =



### 309,478 * 0.171 gram/mile NOx/454 = 116 lb/day, and 0.058 tpd NOx

and

309,478 * 0.231 gram/mile VOC/454 = 157 lb/day, and 0.079 tpd VOC.

COST EFFECTIVENESS

No data on costs for Houston is available. However, given employer savings on reduced parking lease costs, the cost to employers coul d be neutral (i.e., cost of the cash out equal or even less than the parking lease cost savi ngs. Depending on program structure, cost per ton could be as low as $0.

COMMENTS

This evaluation is based on hypothetical assump tions and data for this program and may be considered for use in ozone plan after review of key assumptions.G:\HGAC\Reports\Final_051009\Appdx_F_051009\BCont rolMeasure51ParkCas hOut-EM_051009.doc 

### SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions (tpd) % Tpd Cost Effectiveness ($/ton) 51 Parking Cash-Out Cash-Out for 25% of Central Houston and TMC employees On-RoadLightduty vehicles 40.7 VOC 30.3 NOx 0.2 0.2 0.08 0.06 Parking cashout costs equal to or less than employer parking lease savings



### REFERENCES

Shoup, 2001. “Parking Cash Out (Chapters 1 and 22-28 from the manuscript of) The High Cost of Free Parking”. Donald Shoup, Chair, Department of Urban Planning Director, Institute of Transportation Studies.

Shoup, 1997. Donald Shoup, “Evaluating the Eff ects of California’s Parking Cash-out Law: Eight Case Studies,” Transport Policy , Vol. 4, No. 4, 1997, pp. 201-216.

Thornton, 2005. “Beating the Park ing Crunch: How to Reduce Traffic, Expand Parking Supply, Save Money and Improve Employer Commutes,” Facilities Management Journal, May/June 2005, pp. 38-39.G:\HGAC\Reports\Final_051009\Appdx_F_051009\BCont rolMeasure55-FuelS ubsidy-EM_051009.doc 

### Control Measure: #55, Remove Fuel Subsidies – Fuel Pricing Category: On-road Author: Barbara Joy, Earth Matters

DESCRIPTION

The cost of gasoline in the U.S. spiked so high throughout most of 2008 that consumers had to make dramatic changes in their driving behavior. Unprecedented numbers turned to transit,bicycling and other alternative modes to avoid the pump prices. In this context it is nonintuitive but a well-established fact that gasoline prices in the U.S. are implicitly subsidized to a large extent through not incorporating many of the costs of gasoline into the prices. For example, a 1998 report by the 

### International Center fo r Technology Assessment 1 

### found that gas prices would rise from the 1998 aver age $1.25/gallon to $5.60 to $15.14 if they included subsidies such as tax subsidizati on of the oil industry; government program subsidies; protection costs involved in o il shipment and motor vehicle services; environmental, health, and social costs of ga soline usage; and other externalities. The report notes: “The majority of people paying just over $1 for a gall on of gasoline at the pump has no idea that through increa sed taxes, excessive insurance premiums, and inflated prices in other retail sectors that that same gallon of fuel is actually costing them between $5.60 and $15.14. When the price of gasoline is so drastically underestimated in the minds of drivers, it becomes difficult if not impossible to convince them to change their driving habits, accept alternative fuel vehicles, or consider progressive residential a nd urban development strategies”.

The German Technical Corporation (GTZ), an international cooperation enterprise for sustainable development with worldwide ope rations, has compiled de tailed reports on international gasoline prices. From this co mpilation it can be seen that international fluctuations in fuel prices are enormous. Generally oil producing countries have significantly lower prices than seen elsewh ere, while non-oil produc ing countries that attempt to include external costs of gasoline use have much higher prices when compared with U.S. pump prices. Th eir full report can be found at http://www.gtz.de/en/dokumente/en-int ernational-fuelprices-part2-2007.pdf

. 

### The report finds that European, Chinese, Mexican and repres entative South American countries such as Brazil that attempt to incorporate the real cost of gasoline use into gasoline prices charge up to 2.5 times the amount charged in the U.S. for a gallon of gas.

This analysis estimates the reduction in dr iving that would occur if subsidies were reduced to the extent they appear to be in th e U.K. The U.K. charges more than twice the amount per gallon as is charged in the U.S ., according to the GTZ study cited above. The Center for Technology Assessment estimate is that prices would quadruple, at a minimum if all subsidies were incorporated into gasoline prices.

1 The Real Price of Gasoline: An An alysis Of The Hidden External Costs Consumers Pay To Fuel Their Automobiles. Kimbrell et al, 1998.G:\HGAC\Reports\Final_051009\Appdx_F_051009\BCont rolMeasure55-FuelS ubsidy-EM_051009.doc 

### ANALYSIS

The H-GAC travel model estimates total daily VMT in the Houston metropolitan region at 176,669,720 miles per day, including all vehicl e categories and travel from within as well as from without the region but traveling through it. This analysis assumes that the price of driving in terms of gasoline was increased by a f actor to roughly represent the differences amongst other countries that incorporate more of th e external costs into their gasoline prices.

Table 1. International Fuel Prices in 2006, in U.S. Dollars of Several Countries (source: GTZ, 2007 – see above-referenced web site for full report).

Country Price per Gallon of Gas in 2006 U.S. $2.38 Canada $3.18 Brazil $4.77 Mexico $2.80 Russia $2.91 China $2.61 U.K. $6.17 Germany $5.87 France $5.60 Spain $4.35



### There is no empirical basis upon which to dete rmine whether any of these prices would fully or best represent U.S. non-subsidized pr ices. A simple average was determined to be a reasonable rough estimate of an exam ple price upon which to base the following analysis. The simple (non-population and non-factor-weighted) average of the above prices is $4.06 per gallon, or 171 percent of U.S. prices. It should also be noted that oilproducing countries such as Venezuela, Kuwa it, and Iran cited in the same report by GTZ found prices ranging from 11 – 83 cents per gallon.

A 170 percent increase, using a price elasticity of -0.2, would result in a VMT reduction of 34 percent. It is as yet unknown whether the elasticity findings in the literature would apply across-the-board to so large an incr ease in prices. The price increase from September 2007 to September 2008 was about the same; however studies of the effect are not yet publicly available. Th erefore a correction f actor of 0.5 similar to that applied for ozone action day programs in the U.S. is a pplied to the results to add conservatism pending additional data on driving responses to very substantial price changes.

With the correction factor it is estimated th at a 17 percent decrease in VMT would result from a removal of fuel subsidies in the U.S. It is further assumed that this decrease would only be realized by passenger vehicles. Although vehicles such as line haul trucks would be expected to also make changes, avai lable elasticity values in the literature have focused on passenger travel. For conservatism it is assumed that heavy-duty travel is not affected.G:\HGAC\Reports\Final_051009\Appdx_F_051009\BCont rolMeasure55-FuelS ubsidy-EM_051009.doc 

### Using the above approach, it is estimated th at removal of fuel subsidies would reduce VMT by 27,203,228 miles per day in the region.

EMISSIONS ANALYSIS

The emissions analysis utilized the ba sic process suggested by the MOSERs methodology, as follows:

Variables: EF A 

### : Speed-based composite emission factor after implementation (NO x 

### , VOC, or CO) grams/mile)

EF B 

### : Speed-based running composite emission factor before implementation (NO x 

### , VOC, or CO) (grams/mile)

N VA 

### : Number of vehicles after implementation

N VB 

### : Number of vehicles before implementation

TEF AUTO 

### : Auto trip-end emission factor (NO x 

### , VOC, or CO) (grams/trip)

TL A 

### : Average auto trip length after implementation (miles)

TL B 

### : Average auto trip length before implementation (miles)

VMT A 

### : Vehicle trips after implementation

VMT B 

### : Change in VMT as a result of implementation

It was assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emi ssion factors and the a ssumption that access to alternative modes is not through SOV use.

In this analysis VMT B 

### was derived as described above by multiplying the percentage change in travel (17%) by daily light duty ve hicle travel in the region. The resulting reduction is 27,203,228 miles per day.

Equation:

Daily Emission Reduction =

C = VMT B 

### * EF A =G:\HGAC\Reports\Final_051009\Appdx_F_051009\BCont rolMeasure55-FuelS ubsidy-EM_051009.doc 

### 27,203,228 * 0.171 gram/mile NOx/454 = 10,246 lb/day, and 5.1 tpd NOx

and

27,203,228 * 0.231 gram/mile VOC/454 = 13,841 lb/day, and 6.9 tpd VOC.

COST EFFECTIVENESS

The program shifts costs from external to inte rnal so, if applied corr ectly should result in revenue positive results.

COMMENTS

This evaluation is based on national short-term elasticities and may be considered for use in ozone plan after review of key assumptions

SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions % Tpd Cost Effectiveness ($/ton) 55 Remove fuel subsidies Internalize implicit fuel subsidies into the price of gasoline On-RoadLightduty vehicles 40.7 VOC 30.3 NOx 17 6.9 5.1 <$100/tonG:\HGAC\Reports\Final_051009\Appdx_F_051009\ BControlMeasure57-C onPrice-EM_051009.doc 

### Control Measure: #57, Congestion Pricing Category: On-road Author: Barbara Joy, Earth Matters

DESCRIPTION

Congestion pricing or congestion charges is a system of surcharging users of a transportation network in peri ods of peak demand in order to reduce traffic congestion. By providing drivers a financia l incentive to take mass transi t or other alternative modes during congested times or to shift their time of travel, internationally congestion pricing is a popular way to manage the number of ve hicles on the road. The application on urban roads is limited to a small number of citi es, including London, Stockholm, Singapore and Milan, as well as a few smaller towns. Four ge neral types of systems are in use; a cordon area around a city center, with charges for passi ng the cordon line; area wide congestion pricing, which charges for being inside an area ; a city center toll ring, with toll collection surrounding the city; and corridor or single fac ility congestion pricing, where access to a lane or a facility is priced.

Implementation of congestion pricing has reduced congestion in urban areas, but has also sparked criticism and public discontent. Critic s maintain that conge stion pricing is not equitable, places an economic burden on neighboring communities, has a negative effect on retail businesses and on economic activity in general, and is just another tax.

August 2007, the United States Department of Tr ansportation selected five metropolitan areas to initiate congestion pr icing demonstration projects under the Urban Partnerships Congestion Initiative, for $1 billion of fede ral funding. The five current projects under this initiative are; Golden Gate Bridge in San Francisco, State Road 520 serving downtown Seattle and communities to its ea st, Interstate 95 between Miami and Fr. Lauderdale, Interstate 35 West serving downtown Minneapolis and a variable rate parking meter system in Chicago, which replaced New York City after it left the program in 2008 after nearly implementing a program they were calling the PlaNYC 2030 Sustainability Initiative.

H-GAC evaluated a congestion pricing pr ogram for a downtown area in 2006 and concluded that the program would result in ve ry small emission reductions and for a very high price because of feasibility and mobility is sues. However the area is in the process of converting HOV lanes to “HOT” lanes, a plan to expand current High Occupancy Toll (HOT) activities on Katy and Northwest Freew ays and add tolling to the other four HOV lanes to develop an integrated network of HOT lanes. Plans are being developed to optimize the entire network of HOV lanes on Ho uston using value pricing, to provide the maximum benefits for Houston travelers through reduced congestion and delays.

Specifically, meetings were held in late August 2008 in all five affected corridors regarding the proposed redesigna tion of 83 miles of Houston' s existing reversible High Occupancy Vehicle (HOV) lanes to automa ted High Occupancy Toll (HOT) lanes. HOTG:\HGAC\Reports\Final_051009\Appdx_F_051009\ BControlMeasure57-C onPrice-EM_051009.doc 

### lanes are HOV lanes that can be used by Single Occupant Vehicles (SOVS) for a fee or toll only at times when normal HOV traffic flow is light.

Under the plan METRO would redesignate fi ve of its existing HOV corridors: IH 45 North, US 59 North, IH 45 South, US 59 South and US 290 to HOT Lanes. The project will entail the design, instal lation and operation of new electronic toll collection, optical monitoring equi pment and observation booths.

ANALYSIS

This measure was evaluated by Texas A&M University and found very small emission benefits. IT is expected that using some sort of traffic simulation model would yield some results although this requires a detailed analysis of exactly what mode travelers would be using if there were no HOT lane. Fo r example, what percentage got off the bus to go SOV on the HOT lane and are therefore caused added pollution.

Because ridesharing benefits are accounted for in other analyses and it is unclear whether the net effect would be a reduction or an increas e in emissions from the current case, it is suggested that this measure n eeds a separate study to dete rmine how to account for air quality benefits.G:\HGAC\Reports\Final_051009\Appdx_F_051009\Co ntrolMeasure59-Fuel Taxes-EM_051009.doc 

### Control Measure: #59, Local or regional fuel taxes Category: On-road Author: Barbara Joy, Earth Matters

DESCRIPTION

Taxes on transportation fuels have been advocat ed as a way to reduce pollution, conserve energy, and for certain countries reduce depe ndence on imported o il for foreign policy reasons. Placing high taxes on fossil fuels ma kes alternative (and often less polluting) fuels such as natural gas, bi odiesel, or electric batteries more attractive, and put price pressure on manufacturers a nd consumers to choose more fuel-efficient products and processes. In a November 16, 2008 Op-Ed in the New York Times, for example, Dr. Daniel Sperling of the Univers ity of California at Davis argue s that a variable tax based on a price floor of $3.50 per gallon should be assessed and the proceeds used to help bail out the auto industry which, as a condition of receiving these funds, would have to agree to build more fuel efficient vehicles. Dr. Sp erling notes that at current average prices of $2.50 a gallon the variable tax would raise $17 b illion in one month – more than half the $25 billion bail-out under discus sion. And within a year of sustained $2.50 a gallon gas, the revenue would reach $140 billion – enough to begin repairing our roads and implement other needed transportation measures.

Proponents advocate that automobiles should pa y for the roads they use and argue that the user tax should not be appl ied to mass transit projects. Critics argue transportation fuel taxes are a regressive tax, because lo w-income people pay a higher proportion with respect to their income, and transportation (to work, school, etc.) is not always an avoidable expense.

The federal gas tax in the U.S. is 18.5 cents per gallon. Additional State taxes, according

to http://www.taxadmin.org/fta/rate/motor_fl.html , based on January 2008 data, range from 8 cents/gal in Alaska to 36 cents a gall on in Washington State. In Texas gas taxes are 20 cents/gal.

Taxes in Canada, Europe and other countries are much higher. As of 2007, according to Wikipeida, Canadian taxes are 61 cents a gallon in the Yukon to $1.15 a gallon in Vancouver. In Europe gas taxes range from $3.80 a gallon in Britain to over $5 a gallon in Germany, the Netherlands, and Norway.

ANALYSIS

The H-GAC travel model estimates total daily VMT in the Houston metropolitan region at 176,669,720 miles per day, including all vehicl e categories and travel from within as well as from without the regi on but traveling through it. It is assumed that VMT from external trips is about 4.8 million miles per day, based on external percent of trips, which is 2.7 percent. The analysis assumes that the fuel taxes are being increased in theG:\HGAC\Reports\Final_051009\Appdx_F_051009\Co ntrolMeasure59-Fuel Taxes-EM_051009.doc 

### Houston area alone so that external trips are not affected. In add ition it is assumed that about 10% of the VMT would go to bordering co unties to obtain gasolin e at lower prices. Therefore VMT of 154,202,748 is potentially re ducible from raising gasoline taxes.

This analysis assumes that the tax on ga soline was increased to be equivalent to Vancouver, Canada. 2008 average U.S. pr ices of $3.85 per gallon in mid-2008 were representative and currently (November 2008) th ey were about $2.40 in the Gulf States at the end of October 2008. The fluctuations this past year make it more difficult than usual to predict what prices may be in 2018.

For the purpose of analysis it is assumed that the average price this summer is the base from which a higher gasoline tax equivalent to the tax in Vancouver is assessed. Subtracting the current taxes of 18.5 cents fede ral and 20 cents a gallon in Texas from the Vancouver taxes of $1.15, the increase woul d amount to 76.5 cents per gallon, or a 21 percent increase in 2008. It is further assu med that this approach would result in the same percentage increase in 2018 since we cannot predict taxes or gasoline prices.

Using a gasoline price elasticity of 0.2, a 21 percent increase in gasoline costs would reduce travel by 4 percent, or 6,168,110 miles per day.

EMISSIONS ANALYSIS

The emissions analysis utilized the ba sic process suggested by the MOSERs methodology, as follows:

Variables: EF A 

### : Speed-based composite emission factor after implementation (NO x 

### , VOC, or CO) grams/mile)

EF B 

### : Speed-based running composite emission factor before implementation (NO x 

### , VOC, or CO) (grams/mile)

N VA 

### : Number of vehicles after implementation

N VB 

### : Number of vehicles before implementation

TEF AUTO 

### : Auto trip-end emission factor (NO x 

### , VOC, or CO) (grams/trip)

TL A 

### : Average auto trip length after implementation (miles)

TL B 

### : Average auto trip length before implementation (miles)

VMT A 

### : Vehicle trips after implementation

VMT B 

### : Change in VMT as a result of implementationG:\HGAC\Reports\Final_051009\Appdx_F_051009\Co ntrolMeasure59-Fuel Taxes-EM_051009.doc 

### It was assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emi ssion factors and the a ssumption that access to alternative modes is not through SOV use.

In this analysis VMT B 

### was derived as described above by multiplying the percentage change in travel (4%) by daily light duty ve hicle travel in the region. The resulting reduction is 6,168,110 miles per day.

Equation:

Daily Emission Reduction =

C = VMT B 

### * EF A =



### 6,168,110 * 0.171 gram/mile NOx/454 = 2,323 lb/day, and 1.2 tpd NOx

and

6,168,110 * 0.231 gram/mile VOC/454 = 3,138 lb/day, and 1.6 tpd VOC.

COST EFFECTIVENESS

The program would be revenue positive; th erefore costs per ton are less than zero.

COMMENTS

This evaluation is based on national short- term elasticities and broad assumptions regarding the appropriate percenta ge increase in gas taxes. It may be considered for use in ozone plan after review of key assumpti ons. The feasibility of implementing this measure is low.

SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions % Tpd Cost Effectiveness ($/ton) 59 Fuel Taxes Increase fuel taxes to be equivalent to those in Vancouver Canada, resulting in a 21 percent increase in fuel price On-Road– Lightduty vehicles 40.7 VOC 30.3 NOx 4 1.6 1.2 <$100/tonG:\HGAC\Reports\Final_051009\Appdx_F_051009\ BControlMeasure60-VM T-Tax-EM_051009.doc 

### Control Measure: #60, VMT Tax Category: On-Road Author: Barbara Joy, Earth Matters Inc

DESCRIPTION

A tax on miles traveled is a measure potenti ally useful for reducing miles traveled. Under this measure, a charge would be le vied for each mile driven. In name and application the measure differs from gasoline taxes or removal of fuel subsidies but it works the same way. Most scenarios envisi on this charge being collected during the annual registration process based upon the difference between the previous year’s odometer reading and the current reading. Th is is a key difference between VMT taxes and changes to fuel subsidies or increases in gasoline taxes, which are levied every time a vehicle is refueled. While there are poten tial difficulties with collecting accurate odometer readings, such as odometer roll-over, odometer malfunction, and tampering, it is expected that most readings would be accurate enough to successfully implement this measure. Some states such as California and Oregon have been c onsidering such a tax also because gasoline taxes are not enough to keep pace with needs for road maintenance and capacity improvements, especially given the trend toward more fuel efficient and hybrid vehicles.

One major benefit of this and other pricing programs is that it affects all categories of travel. Most measures aimed at reducing travel and associated emissions focus on commute travel, which represents about 25 – 30 percent of total travel in a given region. This measure would affect both commute and non commute travel. It is assumed that it would only affect travel in passenger vehicles; travel by ve hicles such as heavy duty trucks is not as readily affected by a change in price per mile.

This analysis evaluates the potential effect of this program were a 5 cent per mile VMT tax imposed on area drivers, with the excepti on of emergency vehicles, delivery vehicles, and high occupancy vehicles su ch as vanpools or taxis. Ba sed on current gasoline, oil, vehicle maintenance and insu rance costs grown at 3 per cent per year from 2008 to 2018, it is assumed that driving costs will be about 31 cents per mile in 2018. A 5 cent per mile VMT tax would represent a 16 percent increase in driving costs at a 31 cent per mile rate.

BACKGROUND FOR EMISSION REDUCTION BENEFITS

There have been a number of estimates of the potential effects of mileage charges and similar programs involving changes in the price of driving. Harvey and Deakin utilized a modified transportation model called the S TEP model initially developed for the San Francisco Bay Area to evaluate a variety of pricing measures on driving behavior. The model was applied to four different areas in California, based on 1990 land use and priceG:\HGAC\Reports\Final_051009\Appdx_F_051009\ BControlMeasure60-VM T-Tax-EM_051009.doc 

### data. Table B-21 of their appendix 1 

### contains a list of cen ts per mile charges and associated percent travel reduction. For example these range from 2.3 to 19.7 percent changes in VMT for mileage fees ranging from one to ten cents for 1991 in Los Angeles.

These values were updated by Todd Littman (see http://www.vtpi.org/tdm/tdm79.htm, Table 1 ) to account for inflation between 1991 and 2001, as follows:

Table 1. Mileage Fees and Percent Travel Reduction. Mileage Fee (cents) Travel Reduction (percent) 1 1.8 2 3.5 3 5.1 4 6.7 5 8.2 6 9.7 7 11.2 8 12.5 9 13.8 10 15.2



### While the values were originally developed for California using a transportation model, they may be applicable to other areas. Th e Appendix written by Deakin and Harvey does not contain details about assumptions regard ing elasticities, the num ber of people subject to a given measure, base pr ices, base transportation netw ork characteristics and other inputs necessary for replicating the analysis fo r another area such as Houston. The values are reportedly based on generalized elasticity coefficients that include combined values of travel time, vehicle costs, to ll prices, fuel taxes, transit fa res, and parking prices. Some researchers quoted by Littman in http://www.vt pi.org/tdm/tdm11.htm such as Lee (2000) estimated the elasticity of vehicle travel with respect to total price (including fuel, vehicle wear and mileage-related owners hip costs, tolls, parking fees and travel time, which is equivalent to generalized costs) is –0.5 to –1.0 in the short run, and 1.0 to –2.0 over the long run. The Harvey Deakin estimates are e quivalent to a price el asticity of 0.4, which is slightly below the lower range noted a bove by Lee (“Demand Elasticities for Highway Travel,” HERS Technical Documents , FHWA ( www.fhwa.dot.gov ), 2000). However it is in line with the average long te rm elasticity of demand with respect to gasoline price of 0.4.

1 

### Greig Harvey and Elizabeth Deakin, “The STEP Analysis Package: Description and Application Examples,” Appendix B, in Apogee Research, Guidance on the Use of Market Mechanisms to Reduce Transportation Emissions , USEPA (Washington DC; www.epa.gov/omswww/market.htm ), April 1997G:\HGAC\Reports\Final_051009\Appdx_F_051009\ BControlMeasure60-VM T-Tax-EM_051009.doc 

### ANALYSIS AND RESULTS

The methodology uses a short-term gasoline price elasticity of 0.2 in order to be consistent with the analyses for fuel taxes and removal of fuel subsidies (measures 55 and 59). It is assumed that a 5 cent per mile f ee is assessed. This fee is hypothetical for the purpose of providing an estimate of potential emission reductions intended primarily to determine whether a VMT tax is an appro ach that would yield sufficient emission reductions to merit additional and more intens ive evaluation. The am ount of this fee is loosely based on the concept that 10 cents is the per-mile char ge levied by most vehicle leasing companies for exceeding pre-set mileage limits and that this fee would be set at less.

The H-GAC travel model estimates total daily VMT in the Houston metropolitan region at 176,669,720 miles per day, including all vehicl e categories and travel from within as well as from without the regi on but traveling through it. It is assumed that VMT from external trips is about 4.8 million miles per day, based on external percent of trips, which is 2.7 percent. The analysis assumes that the VMT tax is being a ssessed in the Houston area alone so that external trips are not affected. In addition it is assumed that an additional 10% of the VMT is from vehicles registered outside the modeling area. Therefore VMT of 154,202,748 is potentially reducible from levying a VMT tax.

Since a VMT tax of 5 cents per mile repres ents a 16 percent increase in the cost of driving and the price elasticity of driving with respect to pr ice is 0.2 we estimate that a 3.2 percent in VMT will result from a VMT ta x set at this value. This would be equivalent to 4,934,488 miles of travel reduced per day.

EMISSIONS ANALYSIS

The emissions analysis utilized the ba sic process suggested by the MOSERs methodology, as follows:

Variables: EF A 

### : Speed-based composite emission factor after implementation (NO x 

### , VOC, or CO) grams/mile)

EF B 

### : Speed-based running composite emission factor before implementation (NO x 

### , VOC, or CO) (grams/mile)

N VA 

### : Number of vehicles after implementation

N VB 

### : Number of vehicles before implementation

TEF AUTO 

### : Auto trip-end emission factor (NO x 

### , VOC, or CO) (grams/trip)

TL A 

### : Average auto trip length after implementation (miles)G:\HGAC\Reports\Final_051009\Appdx_F_051009\ BControlMeasure60-VM T-Tax-EM_051009.doc 

### TL B 

### : Average auto trip length before implementation (miles)

VMT A 

### : Vehicle trips after implementation

VMT B 

### : Change in VMT as a result of implementation

It was assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emi ssion factors and the a ssumption that access to alternative modes is not through SOV use.

In this analysis VMT B 

### was derived as described above by multiplying the percentage change in travel (3.2%) by daily light duty ve hicle travel in the region. The resulting reduction is 4,934,488 miles per day.

Equation:

Daily Emission Reduction =

C = VMT B 

### * EF A =



### 4,934,488 * 0.171 gram/mile NOx/454 = 1,859 lb/day, and 0.9 tpd NOx

and

4,934,488 * 0.231 gram/mile VOC/454 = 2,511 lb/day, and 1.3 tpd VOC.

COST EFFECTIVENESS

The program would be revenue positive; th erefore costs per ton are less than zero.

COMMENTS

This evaluation is based on national short- term elasticities and broad assumptions regarding the appropriate VMT tax and the resu lting percentage incr ease in driving costs per mile. In addition it is assumed that a co st levied only once per year would have the same effect in percentage terms as a cost levied each time a motorist refueled. The validity of this assumption is unknown. The measure may be considered for use in ozone plan after review of key assumptions. The feasibility of implementing this measure is untried; limited attempts have been made in Oregon but none elsewhere in the U.S. though the measure has been consider ed by many other nonattainment areas.G:\HGAC\Reports\Final_051009\Appdx_F_051009\ BControlMeasure60-VM T-Tax-EM_051009.doc 

### SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions % Tpd Cost Effectiveness ($/ton) 60 VMT Tax Levy a VMT tax of 5 cents per mile On-Road – Light-duty Vehicles 40.7 VOC 30.3 NOx 3 1.3 0.9 <$100/tonG:\HGAC\Reports\Final_051009\Appdx_F_05100 9\Measure 75_83 Tra ffic_051009.doc 

### Control Measure: Traffic signalization improveme nts, intersection improvements, Reversible traffic lanes (Measures 75, 76, 77, 78, 79, 80, 81, 82, and 83) Category: On-Road Author : Chris Lindhjem, ENVIRON

DESCRIPTION

Traffic signalization improveme nts, reversible lanes and intersection improvements are an ongoing part of the H-GAC plan and Tran sportation Implementation Plan (TIP). According to practice in eval uating CMAQ projects, as well as straightforward logic, traffic flow improvements encouraged by im proved intersections or traffic signals provide benefits for 2 – 5 years (3 years was used for this analysis) before latent demand and growth in traffic cause the facility to retu rn to about the same flow level as prior to the signal or other improvements (although bette r able to handle higher traffic volume). Table 1 provides a list of propos ed projects that are being cons idered under this strategy.

Table 1. Initial list of proposed traffic improvement projects. County Name Project Type Location Project Description

Harris Traffic Signal Improvements Various Locations in Harris County Precinct 4 Arterial Traffic Management System Build Out (Fiber Connectivity And Communications)

Harris Traffic Signal Improvements Various Locations in Harris County Precinct 1 Improve Traffic Flow Along Various Precinct 1 High Demand And Congested Arterials Through Traffic Signal System Enhancements

Harris Incident Management Systems Various Install Traffic Signal Communications (Fiber, Wireless, Hardware, Etc.)

Harris Traffic Signal Improvements Harris County Precinct 3 Improve Traffic Flow Along Various Precinct 3 High Demand And Congested Arterials Through Traffic Signal System Enhancements

Harris Traffic Signal Improvements Various Locations In Harris County Precinct 2 Arterial Traffic Management System Build Out (Fiber Connectivity And Communications)

Brazoria Traffic Signal Improvements FM 524: Entrance To Phillips Refinery For Work Consistent Of The Modernization Of Existing Traffic Signals

Galveston Traffic Signal Improvements FM 2351: At Westwood Elementary Install Traffic Signal And Turn Lanes

Harris Traffic Signal Improvements Various Install Advanced Traffic Control Devices At HATSS Intersections To Bring These Intersection Up To Coh Standards And Improve Traffic Mobility And Signal Progression At Critical Locations (See Attachment). Equipment Deployed May Include: Vids (Video Vehicle Detection System) Pedestrian Control Devices (ADA Ramps, Ped. Heads, Pushbuttons) Dynamic "No Left Turn" Signs

Harris Traffic Signal Improvements Various Install Traffic Management Operations Equipment Phase 2

Harris Traffic Signal Improvements Various Install Traffic Management Operations Equipment Phase 2G:\HGAC\Reports\Final_051009\Appdx_F_05100 9\Measure 75_83 Tra ffic_051009.doc County Name Project Type Location Project Description

Harris Traffic Signal Improvements Various Houston Intelligent Corridors For Transportation Efficiency (ICTE)

Fort Bend Traffic Signal Improvements 5th St. At Present St New Stand-Along Traffic Signal Utilizing Video Imaging Vehicle Detection System (VIVDS) And 3M Opticom Priority Control System For Emergency Vehicles

Fort Bend Traffic Signal Improvements Kirkwood Rd At Cash Rd Install Traffic Signal

Fort Bend Traffic Signal Improvements Cash Rd At HCC Campus Install Traffic Signals At Intersection

Galveston Traffic Signal Improvements SH 87: Harbor View East Of 6th St Install Arterial Traffic Management System

Montgomery Freeway Management Systems IH 45 N N. Of Creighton Rd FM 1488 Install Computerized Transportation Management System

Harris Incident Management Systems Washburn Tunnel Traffic Management And Information System Work Order #14

Fort Bend Traffic Signal Improvements SH 6 At FM 1092 / University Blvd Reconfigure And Upgrade Traffic Signal System At Intersection (RCTSS)

Fort Bend Traffic Signal Improvements SH 6 At Glenn Lakes Blvd. Reconfigure And Upgrade Traffic Signal System At Intersection (RCTSS)

Harris Traffic Signal Improvements N. Main / Alexander Texas Ave To Baker Rd Texas Ave To McKinney Traffic Signal Synchronization

Fort Bend Traffic Signal Improvements FM 1092 At Cartwright Rd Reconfigure And Upgrade Traffic Signal System At Intersection (RCTSS)

Galveston Traffic Signal Improvements Broadway St. 6th St to 61st St Upgrade Traffic Signals & Synchronization

Harris Traffic Signal Improvements Various Locations In Harris Co. Precinct 2 Harris County Signal Interconnect Project, Phase 2, Precinct 2: Project 1

Harris Other FM 2920 FM 2978 and Kuykendahl Install Ethernet Equipment To Interconnect Traffic Signal Video & Data Communications With Regional Traffic Center (Transtar)

Harris Freeway Management Systems NASA 1 IH 45 between SH 146 Install Computerized Transportation Management System

Fort Bend Other SH 6 In Sugarland At Various Locations Computerized Lane Assignments

Harris Incident Management Systems FM 2920 IH 45 Kuykendahl Install Vivds, Pan Tilt Cameras And Dynamic Message Signs At Major Intersections

Fort Bend Traffic Signal Improvements Various Locations In Missouri City Intelligent Transportation System: Upgrade All Traffic Signals To Provide Regionalized Traffic Flow

Harris Traffic Signal Improvements Various Locations In Harris Co. Precinct 1 Harris County Signal Interconnect Phase 2 Precinct 1-Project 1

Harris Traffic Signal Improvements Various Locations In Harris Co. Precinct 4 Harris County Signal Interconnect Phase 2 Precinct 4-Project 1

Fort Bend Traffic Signal Improvements SH 6 Signal Improvements At IntersectionsG:\HGAC\Reports\Final_051009\Appdx_F_05100 9\Measure 75_83 Tra ffic_051009.doc County Name Project Type Location Project Description

Harris Traffic Signal Improvements City Of Houston City Of Houston RCTSS Program: Improve Traffic Control Devices

Harris Traffic Signal Improvements Various Locations In Harris Co. Precinct 3 Harris County Signal Interconnect Project, Phase 2, Precinct 3: Project 1

Harris Traffic Signal Improvements City Of Pasadena City Of Pasadena Signal Program
Fort Bend Other 111 Gillingham Ln. Sugar Land Traffic Management Center

Harris Incident Management Systems IH 10 W & US 59 SW Houston CBD SH 99 & SH 6 Traffic Incident Management (Phase I): Utilize Its Technology, Including Helicopters W/ Real Time Cameras/Microwave Transmitters/Motorcycle Police Units/Marked Vehicles/Dedicated Response Trucks

Harris Other Midtown/Downtown Houston CBD Communications System

Harris Traffic Signal Improvements Various Arterials Harris County RCTSS Program Phase 3

Harris Traffic Signal Improvements Various Locations In Harris County ITS For High Demand Arterial Streets, Harris County Phase 4 RCTSS



### METHODOLOGY AND EMISSIONS ANALYSIS

Traffic improvement projects (under the gene ral strategy called Inte lligent Transportation Systems, ITS) are to improve traffic operations. These proj ects would primarily provide better flow of traffic, reducing stop and go and increased idling especially at intersections.

Emissions Analysis

The primary measure of the benefit of the proj ect is improvements in the average speeds. Improvement in flow of traffic can be measur ed as average travel speed for freeways in miles per hour before and after the implementa tion of an ITS project and delay reductions in vehicle-hours (to estimate reduced idlin g) plus speed improvements for arterial roadways.

The emission factors are determined in units of kilo-grams/mile for freeways before and after the project is implemented. If data is not available through a simulation of the traffic flow, standard estimations, or any other mean s, then the default estimate is to use the assumption that the average speed will improve from 30-MPH to 35-MPH on Freeways and 20-MPH to 25-MPH on Arterials. The idling benefits were determined using the idling emission factor in kilo-g rams/hour (The idling emission factor is determined using the grams/mile for 2.50-MPH idling speed multiplied by 2.50-MPH.) and the delay reduction in vehicle-hours. For freeways, the difference in emission factors (grams/mile) multiplied by vehicles-miles of travel (V MT) will give emission benefits in kilograms/day.G:\HGAC\Reports\Final_051009\Appdx_F_05100 9\Measure 75_83 Tra ffic_051009.doc 

### Cost Effectiveness

The cost of this measure based on the sample list of proposed projects was based on the estimated cost and benefit of those projects. The total cost of t hose proposed projects were $230,527,658.

COMMENTS

This evaluation is based on the cost and ev aluation of the proposed projects outlined in this summary. The proposed projects are based on next three years of projects that will be let, but there could be significantly more projects let over a three-year period. For this summary, it was assumed that twice the money and benefit would be available during the period of 2015 – 2017.

SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions

% TPD Cost Effectiveness ($/ton)

75 – 83 Traffic Flow Improvements Traffic signal timing OnRoad 44.6 tpd VOC 51.7 tpd

NOx 4.6 VOC

3.6 NOx 2.0 VOC

1.8 NOx $220,065 VOC $239,958 NOx $114,791 VOC+NOxG:\HGAC\Reports\Final_051009\Appdx_F_051009\BContro lMeasure85-ReduceTrans itFares-EM_051009.doc 

### Control Measure: #85, Reduced Transit Fares Category: On-Road Author: Barbara Joy, Earth Matters Inc

DESCRIPTION

Transit fare decreases can incr ease transit ridership and en courage some individuals who are currently solo drivers to use transit for some travel. This switch reduces vehicle miles of travel and air pollution emissi on associated with this travel.

The transit system in the Houston area is run mostly by METRO; some service is provided by other agencies and often c oordinated through the efforts of local Transportation Management Organizations (TMOs). METRO provides local bus, express bus, Commuter bus, trolley services in the Texas Medical Center, and rail services for the Houston area.

On November 2, 2008, METRO raised transit fare s in the Houston area for the first time since 1994. Bus and rail passengers now pay 25 cents to $1 more to ride, and this is only the first of three annual fare increases planned by the transit agency. Under the hikes, local bus and rail fares were increased by 25 cents to $1.25. Park and Ride fares rose according to how much riders travel. For exam ple, Park and Ride users in Missouri City saw fares go from $1.50 to $2; Katy Park and Ride customers pay $4.50, up $1 from current fares.

The increase comes after METRO did away with its complex system of discounts and passes last year in favor of a Quic k Card, or Q Card, payment system.

The following fares are now applicable, according to the METRO web site at http://www.ridemetro.org/FareInfo/Default.aspx

.

Table 1. Transit Fares in Houston Area Effective November 2, 2008.



### Fare Zone Chart

Routes Fare Discounted Fare Students, Seniors, Disabled
Local / METRORail $1.25 $0.60
Park & Ride Zone 1 $2.00 $1.00
Park & Ride Zone 2 $3.25 $1.60
Park & Ride Zone 3 $3.75 $1.85
Park & Ride Zone 4 $4.50 $2.25G:\HGAC\Reports\Final_051009\Appdx_F_051009\BContro lMeasure85-ReduceTrans itFares-EM_051009.doc 

### All fares are rounded to the near est nickel, dime, or quarter.

According to the H-GAC transportation modeling department 1 

### 379,606 person trips are made by transit in the region on an aver age day out of a total of 22,115,558 trips, representing 1.7% of daily trips. Assuming th is percentage is roughl y equivalent to miles traveled, we estimate that 3,003,385 miles per day are taken via transit.

ANALYSIS AND EMISSION RESULTS

Assessing the effect of reduced transit fares on travel can be accomplished using transit elasticity. Elasticities are an economic measure of the percentage change in use of a good or service given a percentage ch ange in another variable such as price. Demand elasticity is expressed as the amount of demand for a good that will change given a percentage change in price. For example, a demand elas ticity of 0.50 tells us th at a 10% change in price would lead to a 5% change in demand. Transit use can increase for changes in variables such as transit servic e and transit fares. Transit us e is most elastic with respect to transit service and then transit fare. Ho wever, transit use alone is not necessarily a measure of a corresponding decrease in ve hicle travel. For example, according to (Litman, 2005), transit use has a low-end short- term elasticity of 0.20 for transit use with respect to fare, and a low-end short-term elasticity of 0.03 of auto use with respect to fare. What this means is that a 50 percent d ecrease in transit fares would be expected to increase transit use by 10 pe rcent but only a 1.5 percent decr ease in auto use. This difference is due to the fact that the decr eased transit fares will attract many non-vehicle owners and drivers while also convincing a few vehicle drivers to switch from their car to transit at least some of the time.

The emissions analysis uses the following key variables:

• The current transit use is 379,606 people per day.

• The current fare averages $2.95 per trip 2



### .

• The commuter route fares are lowered to $2.00 (the average annual fare for a person using service twice per day 260 da ys per year). Fares for other transit services such as METRORail are decreased by the same percent.

• The percentage change in fare is 32 percent.

• The high range short-term elasticity of auto us e with respect to transit fare is used. It is 0.10. If the program operates for th ree years before emission benefits are estimated, then longer range elasticity should be used. The long range elasticity of auto use with respect to tr ansit fares ranges from 0.15 to 0.30.

• The average trip distance is 15 miles (work trips are 20 miles and non-work trips are generally around 10 miles)

• For this analysis,

1 Personal Communication, Shixin Gao, H-GAC and Barbara Joy, Earth Matters November 10, 2008.

2 This is based on a simple average of standard commuter route fares for the 4 zones.G:\HGAC\Reports\Final_051009\Appdx_F_051009\BContro lMeasure85-ReduceTrans itFares-EM_051009.doc 

### • Average light duty vehicle composite emission factor for NOx for same day is 0.171 grams per mile

• Average light duty vehicle composite emi ssion factor for VOC for same day is 0.231 grams per mile

The following utilizes the basic proce ss suggested by the MOSERs methodology, as follows:

Variables: EF A 

### : Speed-based composite emission factor after implementation (NO x 

### , VOC, or CO) grams/mile)

EF B 

### : Speed-based running composite emission factor before implementation (NO x 

### , VOC, or CO) (grams/mile)

VMT A 

### : Average Daily Change in VMT as a result of decreased transit fares = Current daily transit ridership * average trip distance * % change in fare * elasticity of auto use with respect to transit fare = 379,606 * 15 * .32 * .1 = 182,211.

It is assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of compos ite emission factors.

In this analysis VMT A 

### was derived above.

Equation:

Daily Emission Reduction =

C = VMT A 

### * EF A =



### 182,211* 0.171 gram/mile NOx/453.6 = 68.6 lb/day, and 0.03 tpd NOx

and 182,211 * 0.231 gram/mile VOC/453.6 = 2.7 lb/day, and 0.05 tpd VOC.

COST EFFECTIVENESS

If current ridership is 379,606, revenues from fares are approximately (using the assumptions above) $1,119,838/day, or $409 milli on a year. With the new fares the ridership would increase by approximately 12,147 people per day, to a total daily ridership of 391,753. Fares at this ridership are $783,507 a day, or about $286 million per year. Planning for transit service increa ses and administration costs are not known at this time.G:\HGAC\Reports\Final_051009\Appdx_F_051009\BContro lMeasure85-ReduceTrans itFares-EM_051009.doc 

### Total annual costs in transit fare decr eases alone are $123 million and total annual emission reductions of NOx and VOC combines are 29 tons per year. Therefore a rough estimate of cost effectiveness is 4.2 million dollars per ton.

COMMENTS

This evaluation is based on hypothetical assump tions and data for this program and may be considered for use in ozone plan after review of key assumptions.

SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions % Tpd Cost Effectiveness ($/ton) 85 Decreased transit fares 32% decrease in transit fares On-Road: Commute Vehicles 40.7 VOC 30.3 NOx 0.1 0.05 0.03 >$1 millionG:\HGAC\Reports\Final_051009\Appdx_F_051009\BC ontrolMeasure90-SubB usService-EM_051009.doc 

### Control Measure: #90, Subscription Bus Service Category: On-Road Author: Barbara Joy, Earth Matters Inc

DESCRIPTION

There are many types of subscription bus se rvices offered in the Houston and other metropolitan areas. The analysis presented here focuses on a subscription bus service catering to those that are least likely to us e transit – white collar workers whose work load would make a quiet stress-free ride to work with internet access offered very attractive. Among the major obstacles to tran sit use are limitations in service between residential and employment areas. If transit service were designed specifically for certain residential areas to highly used but somewh at underserved employme nt areas, transit use could increase substantially. An example of such a service would be between the Katy areas to downtown areas such as the Texas Medical Center.

There are a number of potentia l services that could assist in transit use between such areas, including personalized rapid transit, su bscription bus service, business first buses, easier access between Metro and other services such as those provided by TREK (such as a universal card), and personalized transit pl anning. There is a lik elihood of some pentup or latent demand for transit service that specifically serves individuals because of time spent in traffic, gas prices, maintenance and pa rking costs that can be significantly offset by using an alternative mode of transportation such as transit. For example, personalized transit planners, somewhat like personal shoppers, could assist individuals by showing them how to easily use transit from one point to another (such as home to work, work to lunch spots or meeting locations, and work to home). Such a service could even be provided online. In addition, some buses c ould be equipped with fold-down tables and wireless internet connections (for example through cell-phone companies) so that people could work while on the buses, and feeder shut tles could bring people from transit stops directly to work centers.

This measure evaluates the benefits of a hypothetical and ambitious program that would provide these services. It is assumed that 100 new business buses (buses equipped with fold-down tray tables and wireless internet) seating 35 people each providing service directly from neighborhoods to specific wo rk locations would operate four trips per morning and four per evening. Service would also be augmented by the addition of 100 shuttle buses to provide service between current METRO stops and (1) under-served residential area too far from tran sit centers or park and ride lots to utilize them; and (2) employment areas in downtown Houston whic h currently do not have sufficient transit access. The shuttle buses are assumed to seat 15 people each and ope rate six trips each morning and six each evening. For the purpose of simplicity it is assumed that currently planned expansions to METRO service woul d accommodate the extra ridership created by the shuttle services. If this measure re sults in emissions si gnificant enough to merit further review, this assumption, along with the others would need to be refined.G:\HGAC\Reports\Final_051009\Appdx_F_051009\BC ontrolMeasure90-SubB usService-EM_051009.doc 

### METHODOLOGY AND EMISSIONS ANALYSIS

This analysis is based upon the hypothetical scenario described above and an assumption that after a year of marke ting, the development of an eas y-to-use internet personal planning site, and fine-tuning th e routes that the vehicles wi ll be 80% full on an average day.

The emissions analysis uses the following key variables:

• There are 100 buses seating 35 people opera ting four round trips (per person) per day; at 80% capacity th is is equivalent to 11,200 people per work day;

• There are 100 shuttle buses seating 15 pe ople operating 6 round trips (per person) per day; at 80% capacity this is e quivalent to 7,200 people per work day.

• It is assumed that 100% of shuttle use is due to new transit users who did not previously use transit because it did not provide a viab le way to their place of employment or their home.

• The average work trip distance is 40 miles round trip

• The business buses travel 40 miles for each round trip, or 160 miles each day per bus; new emissions due to these buses is therefore based upon an average weekday mileage of 16,000 miles.

• The shuttle buses are assumed to travel 10 miles per round trip, or 60 miles per day per shuttle; new emissions due to th e shuttles is therefore based upon an average weekday shuttle m ileage of 6,000 miles.

• Average light duty vehicle composite emission factor for NOx in 2018 is 0.171 grams per mile

• Average light duty vehicle composite emission factor for VOC is 0.231 grams per mile.

• Average shuttle bus emissions are represented by the MOBILE6 category HDDV6 and are 1.0 grams per mile of NOx and 0.18 grams per mile of VOC in 2018.

• Average transit bus emissions are repr esented by the MOBILE6 HDDBS category and are 4.74 grams per mile NOx and 0.36 grams per mile VOC in 2018.

The following utilizes the basic proce ss suggested by the MOSERs methodology, as follows:

Variables

EF A 

### : Speed-based composite emission factor for passenger vehicles (NO x 

### , VOC, or CO) grams/mile)

EF B 

### : Speed-based running composite emission factor for transit vehicles (NO x 

### , VOC, or CO) (grams/mile)G:\HGAC\Reports\Final_051009\Appdx_F_051009\BC ontrolMeasure90-SubB usService-EM_051009.doc 

### VMT A 

### : Average Daily Change in passenger VMT as a result of increased transit service VMT B: 

### Average Daily Change in transit vehicle VMT as a result of increased transit service

Emissions changes from vehicle trips and associated start emissions are evaluated through the use of compos ite emission factors.

In this analysis

VMT A 

### is 18,000 new transit users * 40 mile av erage round trip work distance = 736,000 miles per weekday.

VMT B 

### is SUM(VMT for business buses and VMT for shuttle buses) = 22,000 miles/day.

Equation:

Daily Emission Reduction from passenger vehicles =

C = VMT A 

### * EF A =



### 736,000 * 0.171 gram/mile NOx/453.6 = 277.2 lb/day, and 0.14 tpd NOx

and 736,000 * 0.231 gram/mile VOC/453.6 = 374.5.4 lb/day, and 0.19 tpd VOC.

Daily emission increase from increased transit vehicles

= 16,000 * 4.74 gram/mile NOx = 167 lb/day and 0.08 tpd NOx; 16,000 * 0.36 gram/mile VOC = 12.7 lb/day and 0.01 tpd VOC

and 6,000 * 1.0 gram/mile NOx = 13 lb/day and 0.006 tpd NOx. Total NOx increase is 0.09 tpd NOx.

= 6,000 * 0.36 gram/mile VOC = 4.8 lb/day and 0.002 tpd VOC. Total VOC increase is 0.01 tpd.

The net emission decrease is 0.05 tpd NOx and 0.18 tpd VOC.

COST EFFECTIVENESS

Costs of the program are estimated based upon hour ly fees paid to transit vehicle leasing companies used in Houston such as AFC. Based on a conversation w ith Trek, these costs are $54.85/hour to cover the dr iver, the vehicle and other costs such as fuel and insurance. Both the business buses and the shuttles would operate from 4:30am to aboutG:\HGAC\Reports\Final_051009\Appdx_F_051009\BC ontrolMeasure90-SubB usService-EM_051009.doc 

### 8 pm to provide the number of round trips described, or about 16 hours per day. At 260 weekdays per year the gross cost will be $45,635,200/year before marketing and administration. Because of the convenience of the business buses, it is assumed that each rider would pay a round-trip fare of $5 and that shuttle riders would pay a round-trip fare of $2. Therefore fare revenue would be $18,304,000. It is possible that additional revenue could be generated by selling ad space on the interior walls of the buses and shuttle vehicles. This is not currently done in the Houston area but is in many other urban areas and can be a significant source of revenue. For this analysis it is assumed that no advertising revenue would occur and that marketing/internet costs are insignificant compared with the operation of the vehicles. Therefore net costs are $27.3 million dollars per year.

Annual combined NOx and VOC benefits ar e 59.8 tons. Cost effectiveness is $456,500/ton.

COMMENTS

This evaluation is based on hypothetical assump tions and data for this program and may be considered for use in ozone plan after re view of key assumptions. The use of 100 of each type of bus is intended to assist in scaling the emissions estimates should other possibilities for implementation be considered.

Also key is that the emission factors used in the analysis are emission factors with currently programmed federal and other cont rol measures such as Tier 2 tailpipe standards. Other measures are being evalua ted for the H-GAC region, such as California LEV (low emission vehicles), cleaner fleets and wider applic ation of the Inspection and Maintenance program. If these or other similar programs were implemented, the emission factors used to evaluate programs af fecting the amount of travel (such as this one) would be smaller – each mile driven woul d be at a lower emission rate and therefore each mile not driven would not reduce emissions as much as it would have without the additional measures.G:\HGAC\Reports\Final_051009\Appdx_F_051009\BC ontrolMeasure90-SubB usService-EM_051009.doc 

### SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions % Tpd Cost Effectiveness ($/ton) 90 Subscription bus service Business buses, shuttle services, personalized transit On-Road 40.7 VOC 30.3 NOx 0.4 0.2 0.18 0.05 $456,500G:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 92 Transit Options_051009.doc 

### Control Measure: #92, 99, 145, Public Transit Improvements Category: On-road Author: Chris Lindhjem, ENVIRON

DESCRIPTION

There are three measures related to transit options in the list of measures that could produce measurable emissions reductions shown below.

• Electrified buses

• Light rail expansion

• Hybrid buses

The electrified buses or light rail require infrastructure im provements (overhead catenary or rail construction), but would result in an elimination of the engine emissions on those routes served.

The hybrid buses available have two main a dvantages in that no new (other than the buses themselves) infrastructu re is required and reduced fu el consumption. The main disadvantage is that a fraction of emissions reductions (about 25%) would be applied to already low emissions new bus engine emissi ons. Therefore, the emission reduction in tons per year would be lower than that for projects implemented through 2007.

IMPLEMENTATION FEASIBILITY

Light rail has been built in Houston starting with the ope ning in 2004 of 7.5 miles of a system. The planned and potential expansi on beyond the current network would require significant investment as well as id entifying the best possible routes.

The use of electrified buses with an overhead catenary system has not been employed in Houston. The cost would presumably be lo wer than the light rail option, but it is unknown how much this option would cost. The bus es that can run in electric or diesel mode would not necessarily be fixed to the electrified system, but would be specialty purchases.

Hybrid buses are an attractive option because th ey are in effect identical in operation to conventional buses. The emissions difference between a new conventional bus and a hybrid one will be small once the NOx standard is fully implemented in 2010. But the fuel savings may be sufficiently significant to offset the extra cost of the hybrid system.G:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 92 Transit Options_051009.doc 

### PUBLIC ACCEPTANCE

The light rail or other options to bus routes have been ex tensively vetted throughout the process of designing the system. But there have been discussions and lawsuits about the placement and design of the new system.

Hybrid buses are a seamless transition fr om the conventional bus service. Often passengers would not know the difference.

ANALYSIS

The analysis uses the forecast transit bus em issions and emissions rates to compare with the alternatives to transit buses or the use of the hybrid technology buses.

EMISSIONS AFFECTED

The transit bus emissions forecasted for 2018 are expected to be 0.05 tpd VOC and 0.98 tpd NOx. Transit buses typically have a 12-year life, and the most stringent NOx emission standard will have full effect by 2010, so most buses in-use in 2018 will meet that low NOx standard.

EMISSIONS BENEFIT

The current rail system offsets 346 bus trip s per day along the 7.5 mile route would be equivalent to 0.001 tpd VOC and 0.012 tpd of NOx emissions for the average fleet of buses in 2018. The planned and potential expa nsion of the network could be up to an order of magnitude increase by 2018, and coul d include commuter rail as well as lightrail.

Hybrid buses usually recover enough energy during braking and allow the engine to operate at peak efficiency to effect a 25% reduction in fuel consumption and emissions. Using the average emission rate figures in Table 1, a 2018 model year bus traveling 50,000 miles a year would have 0.012 tpd VOC and 0.044 tpd NOx benefit.

Table 1. Transit bus emission rates.

Model Year VOC (g/mile) CO (g/mile) NOx (g/mile)
1994 0.21 2.79 21.82
1995 0.21 2.79 21.84
1996 0.21 2.79 21.86
1997 0.21 2.79 21.86
1998 0.21 2.79 17.47
1999 0.21 2.79 17.47
2000 0.21 2.79 17.47G:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 92 Transit Options_051009.doc Model Year VOC (g/mile) CO (g/mile) NOx (g/mile)
2001 0.21 2.79 17.47
2002 0.21 2.79 16.61
2003 0.21 2.79 14.04
2004 0.22 2.79 9.90
2005 0.22 2.79 9.90
2006 0.22 2.79 9.90
2007 0.22 0.29 5.75
2008 0.22 0.29 5.72
2009 0.22 0.29 5.69
2010 0.22 0.29 0.81
2011 0.22 0.29 0.81
2012 0.22 0.29 0.81
2013 0.22 0.29 0.81
2014 0.22 0.29 0.81
2015 0.22 0.29 0.81
2016 0.22 0.29 0.81
2017 0.22 0.29 0.81
2018 0.22 0.29 0.81



### COST AND COST-EFFECTIVENESS

The cost of the current light -rail system was $324 million for th e initial 7.5 mile system. With an expected life of 30 years, the a nnual cost was estimated at $16.5 million. This does not count the operating or maintenance co st of the light-rail or the cost benefit compared with buying and operating buses (p revious operations estimated to involve about 16 buses) along the same route. The cost effectiveness for the system is quite high (about $3 million per ton of VOC and NOx reduced) if basing the light rail benefit solely on the air emissions reduced. This is due to the expected low emission rate from the future year buses, and not counting alternative benefits such as congestion relief, increase ridership, or lower maintenance costs. Not count ed in the benefits is the potential for rail to encourage greater ridership than the altern ative bus routes, but comparison data on rail and bus ridership has not yet been made available.

Hybrid buses have historically cost $200,000 more than conventional buses and typically produce a 25% reduction in emissions and fu el consumption. Other sources (SF Metro, 2008) note $150,000 cost and 30% improvement. The fuel consumption benefit would however be significant, and depending upon th e fuel cost could pay for the higher purchase price over the life of the vehicle. But using the $200,000 figure and a 12-year life, the annualized cost for the hybrid bus is about $20,000 per year resulting in a cost effectiveness of $350,000 per ton of VOC and NOx reduced. This high cost estimate assumes the highest cost, lowest benefit, and does not consider other improvements in fuel or operating costs. Mode l year 2009 trucks would be e xpected to have almost ten times the benefit.G:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 92 Transit Options_051009.doc 

### SUMMARY OF RESULTS

Expected Emission Reduction Measure # Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effectiveness ($/ton)

92, 99 Light rail or electrifying routes Increased electric grid

powered

transit Transit Buses 0.05 VOC 0.98 NOx 1 – 10% 0.012 – 0.12 NOx <$3 million

145 Hybrid Buses New energy saving technology Transit Buses 0.05 VOC 0.98 NOx 25% 0.23 NOx <$350,000



### REFERENCES

METRO. 2008, “The Facts: METRORail on Main Street,” http://www.metrosolutions.org/go/doc/1068/112217/

San Francisco Metro, hybrid bus fact sheet, http://www.sfmta.com/cms/mfleet/hybrids.htmG:\HGAC\Reports\Final_051009\Appdx_F_051009\BContro lMeasure102-FreeCircSer vice-EM_051009.doc 

### Control Measure: #102, Free Circulato r Service to Major Generators Category: On-Road Author: Barbara Joy, Earth Matters Inc

DESCRIPTION

This measure would provide free shuttle/tran sit services connecting remote areas with major activity generators. Among the major obstacles to transit use are limitations in service between residential and employment ar eas. If transit se rvices were designed specifically for certain reside ntial areas to highly used underserved employment areas, transit use could increase substa ntially. An example of such a service would be between the Katy area to downtown areas such as th e Texas Medical Center , Bellaire, Greenway Plaza, or the central business district.

This measure evaluates the benefits of a hypothetical and ambitious program that provides free services between residential areas and downtown employment centers. According to H-GAC 1 

### there are 998,992 jobs at the following downtown employment centers in 2018.

Table 1. Employment Centers and Employment in 2018

Employment Center 2018 Employment Bellaire/Pin Oaks 19,837 Brookhollow 49,843 CBD 146,600 Clear Lake/NASA 42,444 Galleria 141,801 Greenspoint 94,052 Greenway Plaza 60,416 Medical Center 135,749 Northwest Crossing 53,225 Sharpstown 38,512 The Woodlands 30,379 West Houston 105,335 Westchase 80,799



### It is assumed that 1,500 new shuttles seat ing 15 people each would provide service directly from under served residential neighbor hoods to the above employment centers. This hypothetical scenario would service slight ly over ten percent of the employment at the centers listed above.

1 H-GAC 11/10/08. Personal communication Sharon Ju, H-GAC and Barbara Joy, Earth Matters.G:\HGAC\Reports\Final_051009\Appdx_F_051009\BContro lMeasure102-FreeCircSer vice-EM_051009.doc 

### ANALYSIS

This analysis is based upon the hypothetical scenario described above and an assumption that after a year of marke ting, the development of an eas y-to-use internet personal planning site, and fine-tuning the routes that the vehicles wi ll be 90% full on an average day.

EMISSION ANALYSIS

The emissions analysis uses the following key variables:

• There are 1,500 buses seating 15 people operating five round trips (per person) per day; at 90% capacity this is equi valent to 101,250 people per work day;

• It is assumed that 100% of shuttle use is due to new transit users who did not previously use transit because it did not provide a viab le way to their place of employment or their home.

• The average work trip distance is 40 miles round trip

• The shuttles travel 40 miles for each round trip, or 160 miles each day per shuttle; new emissions due to these buses is therefore based upon an average weekday mileage of 240,000 new miles by shuttle buses.

• Average light duty vehicle composite emission factor for NOx in 2018 is 0.171 grams per mile

• Average light duty vehicle composite emission factor for VOC is 0.231 grams per mile.

• Average shuttle bus emissions are represented by the MOBILE6 category HDDV6 and are 1.0 grams per mile of NOx and 0.18 grams per mile of VOC in 2018.

The following utilizes the basic proce ss suggested by the MOSERs methodology, as follows:

Variables

EF A 

### : Speed-based composite emission factor for passenger vehicles (NO x 

### , VOC, or CO) grams/mile)

EF B 

### : Speed-based running composite emission factor for transit vehicles (NO x 

### , VOC, or CO) (grams/mile)

VMT A 

### : Average Daily Change in passenger VMT as a result of increased transit service VMT B: 

### Average Daily Change in transit vehicle VMT as a result of increased transit serviceG:\HGAC\Reports\Final_051009\Appdx_F_051009\BContro lMeasure102-FreeCircSer vice-EM_051009.doc 

### Emissions changes from vehicle trips and associated start emissions are evaluated through the use of compos ite emission factors.

In this analysis

VMT A 

### is 101,250 new transit users on an averag e work day * 40 mile average round trip work distance = 4,050,000 miles per wee kday, or 2,892,857 miles per average day.

VMT B 

### is VMT for shuttle buses = 240,000 miles/day.

Equation:

Daily Emission Reduction from passenger vehicles =

C = VMT A 

### * EF A =



### 2,892,857 * 0.171 gram/mile NOx/453.6 = 1,090 lb/day, and 0.54 tpd NOx

and 2,892,857 * 0.231 gram/mile VOC/453.6 = 190 lb/day, and 0.09 tpd VOC.

Daily emission increase from new shuttle buses

= 240,000 * 4.74 gram/mile NOx = 2,505 lb/day and 1.25 tpd NOx; 240,000 * .36 gram/mile VOC = 12.7 lb/day and 0.006 tpd VOC

The net emission effect is an increase in NOx of 0.71 tons per day and a decrease of 0.08 tpd VOC.

COST EFFECTIVENESS

This measure results in a net increase of NOx an d is by that fact alone not considered cost effective and is not recommende d for further consideration.

COMMENTS

This evaluation is based on hypothetical assump tions and data for this program. Other assumptions could result in different results.G:\HGAC\Reports\Final_051009\Appdx_F_051009\BContro lMeasure102-FreeCircSer vice-EM_051009.doc 

### SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions % Tpd Cost Effectiveness ($/ton) 102 Free shuttle service to employment centers Free shuttle service to employment centers On-RoadLightduty vehicles 40.7 VOC 30.3 NOx <0 0.08 VOC NOx Increase of 0.71 Not cost effectiveG:\HGAC\Reports\Final_051009\Appdx_F_05100 9\BControlMeasure 106-CWW-EM_051009.doc 

### Control Measure: #106, Compressed Work Week Program Category: On-Road Author: Barbara Joy, Earth Matters Inc

DESCRIPTION

Compressed work weeks are among the most effective of transportation demand management measures. Many Houston ar ea employers currently already have compressed work week programs. The way most programs work is that employees either have a 4/40 schedule or a 9/80 schedule. A 4/40 schedule means they work four ten hour days per week and have one day off. A 9/80 schedule means the employees work 9 hours a day and take one day off every two weeks. Most programs operate on a 4/40 schedule.

Currently the H-GAC alternative work sc hedules program, which operates under the umbrella of the Commute Solutions progr am, helps employers implement several measures including telecommuting, carpooli ng, vanpooling, alternative parking and compressed work weeks. A program specifi cally aimed at increasing the amount of compressed work weeks through a mandatory program is not currently in place but could be implemented as a part of the overall ozone attainment plan.

ANALYSIS

The purpose of this analysis is based upon the need to determine what programs, if implemented in a highly ambitious manner, might yield sufficient emission reductions to be further considered for inclusion in the 8-hour ozone attainment plan. The analysis presented here explores the potential effect s of a very ambitious compressed work week program targeting 20 percent of Houston area employees for a 4/40 program.

EMISSIONS ANALYSIS

There are a number of variables important fo r evaluating the emissi on benefits of this measure. These are as follows:

• Total employment projecte d by H-GAC for 2018 is 3,183,000 1 

### . The above-cited figure of 20% would be 636,600 employees.

• The average round trip work distance fo r Houston area employees is 40 miles; therefore daily VMT reduction on a co mpressed work week day is 25,464,000 and on an average day (1/7 th 

### of the miles) would be 3,637,714 miles per day.

• Average light duty vehicle composite emission factor for NOx in 2018 is 0.171 grams per mile

1 http://www.h-gac.com/rds/forecasts/documents/Pop_employment_Counties_Region.pdfG:\HGAC\Reports\Final_051009\Appdx_F_05100 9\BControlMeasure 106-CWW-EM_051009.doc 

### • Average light duty vehicle composite emission factor for VOC in 2018 is 0.231 grams per mile

The emissions analysis utilized the ba sic process suggested by the MOSERs methodology, as follows:

Variables: EF A 

### : Speed-based composite emission factor after implementation (NO x 

### , VOC, or CO) grams/mile)

EF B 

### : Speed-based running composite emission factor before implementation (NO x 

### , VOC, or CO) (grams/mile)

VMT B 

### : Change in vehicle miles traveled as a result of implementation = number of compressed work week employees * round trip distance * 1/7 (one day every 7).

It was assumed that emission factors and trip length before and after implementation are the same. Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emission factors.

Equation:

Daily Emission Reduction =

C = VMT B 

### * * EF A =



### 3,637,714 * .171 gram/mile NOx/453.6 = 1,370 lb/day, and 0.69 tpd NOx

and

3,637,714 * 0.231 gram/mile NOx/453.6 = 1,851 lb/day, and 0.93 tpd VOC.

COMMENTS

This evaluation is based on hypothetical assump tions and data for this program and may be considered for use in ozone plan after revi ew of key assumptions. The feasibility of achieving a 20% participation rate from all H ouston area employees has not been studied. Cross effects of a 20% compressed work week share on alternative modes such as transit, vanpooling and ridesharing have not been ev aluated. Therefore if all these programs were implemented, emission benefits could not simply be added up without some accounting for the relationships between the programs.G:\HGAC\Reports\Final_051009\Appdx_F_05100 9\BControlMeasure 106-CWW-EM_051009.doc 

### COST EFFECTIVENESS

Costs for this hypothetical program are not known. Costs to employers should be minimal and benefits in the form of decr eased turnover, reduced parking demand, and possibly fewer sick days would be expected to offset costs. Current outreach/advertising and marketing costs for the Commute Soluti ons program are $2.5 million annually. If we conservatively assume half would be sp ent on compressed work weeks alone, and evaluate annual combined NOx and VOC reductions of 584 tons per year then cost effectiveness would be Annual NOx emission benefits are daily benefits * 260 workdays per year, or 598 tons per year. This would result in an estimated cost effectiveness of $2,140 per ton.

This evaluation is based on hypothetical assump tions and data for this program and may be considered for use in ozone plan after review of key assumptions.

SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions (tpd) % Tpd Cost Effectiveness ($/ton) 106 Compressed Work Week Mandate 20% of area employees on a 4/40 schedule On-RoadLightduty vehicles 40.7 VOC 30.3 NOx 2.3 0.93 0.69 $2,140G:\HGAC\Reports\Final_051009\Appdx_F_051009\BC ontrolMeasure108-ride share-em_051009.doc 

### Control Measure: #108, Internet ridematching services Category: On-Road Author: Barbara Joy, Earth Matters Inc

DESCRIPTION

An H-GAC ridesharing program was kicked off in August of 2005, which utilizes computer-based methods similar to other onlin e travel programs su ch as Travelocity. The program is internet based and uses the consultant NuRide, Inc. ( http://www.nuride.com ), the nations first incentive-bas ed rideshare network. NuRide’s innovative online program lets individuals use NuRide’s patent-pending technology to find the ideal partner with whom to share a si ngle ride for work or pleasure. Subscribing to the philosophy that people sharing rides provi de a valuable servic e to their community, NuRide offers its members rewards each time they use the ridesharing program. By accumulating "NuRide Miles," members earn enough points to acquire gift cards and gift certificates from a variety of corporate spons ors such as Old Navy, TGI Fridays, Macy’s and many other familiar retailers and restaurants.

The program’s incentives to ridesharers are si gnificant enough to have made the program grow from a few hundred carpoolers to n early 5,000 in August 2008. The incentives mentioned above earn points at dozens of partic ipating retailers. Points are only earned when, for each ridesharing day, ridesharers ma tch themselves with an online carpool and fill out a survey form (all ridesharers must f ill out the survey or none will receive credit). Other incentives are the ease and conven ience, as well as a “cool factor”.

It should be noted that in addition to NuRide, there are several other internet based carpooling websites. eRideshare.com is the leading carpool/ridesharing website, according to Yahoo and Google. It has been recognized as "Best of the Net" by About.com, and was featured in Al Gore's book An Inconvenient Truth as a way to Take Action. There are also GoLoco, Zimride (which uses a facebook application), Mycarpools.com and CarpoolWorld.com. These internet sites saw enormous growth during 2008 while gas prices were rising. Specific statistics on Houston for all ridesharing sites are not available.

ANALYSIS

Between September 2007 and August 2008 the NuRide program grew 55%. This analysis is based upon the assumption that the program, together with the other programs mentioned above, continues to grow at this rate through 2018. If it does, there will be 376,757 carpoolers in the Houston region. It is assumed carpools average 2.7 people per vehicle and those carpoolers rideshare an aver age of twice per week at an average trip distance of 15 miles.G:\HGAC\Reports\Final_051009\Appdx_F_051009\BC ontrolMeasure108-ride share-em_051009.doc 

### EMISSIONS ANALYSIS

The emissions analysis utilized the ba sic process suggested by the MOSERs methodology, as follows:

Variables: EF A 

### : Speed-based composite emission factor after implementation (NO x 

### , VOC, or CO) grams/mile)

EF B 

### : Speed-based running composite emission factor before implementation (NO x 

### , VOC, or CO) (grams/mile)

TEF AUTO 

### : Auto trip-end emission factor (NO x 

### , VOC, or CO) (grams/trip) VT B: 

### Number of new carpoolers.

AVR: Average vehicle ridership in carpools

TL B 

### Trip Length

It was assumed that emission factors and trip length before and after implementation are the same. Emission changes from vehicle trips and associated start emissions are evaluated through the use of composite emi ssion factors and the a ssumption that access to the carpool is not through SOV use.

Note that if there are 2.7 peopl e per carpool and one is a driver not reducing mileage, each carpool has, on average 1.7 people that are actually reducing their driving behavior. Therefore of the 376,757 carpoolers, 237,217 are actually reducing travel.

Equation:

Daily Emission Reduction =

C = VT B 

### * ((AVR-1)/AVR) * TL B 

### * 2* Frequency * EF A =



### 237,217 * 15 * 2 * 2/7 * 0.171 gram/mile NOx/453.6 = 766 lb/day, and 0.38 tpd NOx

and

237,217 * 15 * 2 * 2/7 * 0.231 gram/mile NOx/453.6 = 1,035 lb/day, and 0.52 tpd NOxG:\HGAC\Reports\Final_051009\Appdx_F_051009\BC ontrolMeasure108-ride share-em_051009.doc 

### COST EFFECTIVENESS

NuRide’s budget for 2005 – 2006 fiscal year was $400,000 but the program, as planned, is moving towards being self-sustaining. It is expected that well be fore 2018 the costs of the program will be limited to reporting costs. Conservatively we estimate the combined reporting and administrative costs to H-GAC to be $100,000 in 2018.

Annual emission benefits are 98.55 tons and th e cost effectiveness would therefore be $1,014 per ton.

COMMENTS

This evaluation is based on hypothetical assump tions and data for this program and may be considered for use in ozone plan after review of key assumptions.

SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions % Tpd Cost Effectiveness ($/ton) 108 Internetridematching NuRides plus other internet ridematching services grow at same rate NuRides grew between 2007 and 2008. On-RoadLightduty vehicles 40.7 VOC 30.3 NOx 1.3 0.52 0.38 $1,014G:\HGAC\Reports\Final_051009\Appdx_F_051009\ Control Measure 109 Vanpoo_051009.doc 

### Control Measure: #109, Vanpooling Category: On-Road Author : Chris Lindhjem, ENVIRON

DESCRIPTION

H-GAC administers a vanpooling program that consists of ongoing efforts to reduce congestion by providing alternative trans portation through trip sharing with vanpools. The program began operation in 1996 and is funded using Surface Transportation Program (STP) funds, METRO local funds and employer incentives, which provide reduced monthly costs to participating employees. As of August 2008 the vanpool program had 755 vans and 7,846 riders with an average of 10.4 riders per van. The vanpools average 54.6 miles per day (round trip).

The VMT reduction resulting from these vanpool ers will be about 54.6 miles per day, or about 100 million miles per year, assuming a 260- day work year. As vanpools are driven about 11 million miles per year to offset the 111 million miles that would have been driven in passenger vehicles.

IMPLEMENTATION FEASIBILITY

The approach here is to use the current pr ogress of the vanpooling program to determine the benefit of the program in 2018.

PUBLIC ACCEPTANCE

This program has been popular, but it has been heavily subsidized and marketed to date. The riders gain the benefit of reduced fuel costs and deteriora tion of their personal vehicles.

ANALYSIS

The analysis is straightforward in that the emissions of single occupancy vehicles (SOV) are subtracted by the emissions from vans.

EMISSIONS AFFECTED

The primary emission affected by this m easure are the light-duty single occupancy vehicles shown in Table 1.G:\HGAC\Reports\Final_051009\Appdx_F_051009\ Control Measure 109 Vanpoo_051009.doc 

### Table 1. On-road weekday emissions 8-County totals (tpd).

Pollutant Light-duty Heavy-Duty Gasoline Heavy-Duty Diesel Total On-road Vehicles VOC 40.69 0.80 3.15 44.64 CO 691 13 5 709 NOx 30.31 1.88 19.67 51.69



### EMISSIONS BENEFIT

The emissions analysis used the basic em ission calculation for the average light-duty (commute vehicle) and the van used in the primary commute, as follows:

Variables: EF A 

### : C omposite emission factor for commute vehicle (NO x 

### , VOC, or CO) grams/mile for the average light-duty vehicle

EF B 

### : Van (LDGT4) emission factor (NO x 

### , VOC, or CO) (grams/mile)

Emissions changes from vehicle trips and associated start emissions are evaluated through the use of composite emi ssion factors shown in Table 2.

Table 2. On-road emission factors 8-County totals (g/mile). Personal Vehicles Average Light-Duty Average Van LDGT4 Average Pollutant G/mile G/mile VOC 0.23 0.20 CO 3.92 3.83 NOx 0.17 0.27



### Example Calculation:

Daily Emission Reduction = VMT A 

### * EF A 

### – VMT B 

### * EF B



### 82 grams per day NOx benefit per van = 10.4 passengers * 54.6 miles * 0.171 gram/mile NOx – 54.6 mi les * 0.267 gram/mile

COST AND COST-EFFECTIVENESS

The total subsidized cost of the prog ram has been $3,113,427 for the 12 months ending June 2008. Based on a 260 day work year, annual benefits for all vans are forecast to be 26 tons VOC and 18 tons NOx in 2018. The cost effectiveness would be $120,000/ton for VOC and $175,000/ton for NOx and $71,000 per t on of VOC + NOx for the air quality benefits alone. Vanpool programs are also ad ministered for congestion relief benefit andG:\HGAC\Reports\Final_051009\Appdx_F_051009\ Control Measure 109 Vanpoo_051009.doc 

### the benefit of removing 7,100 vehicles fr om the commuting peaks has not been incorporated into the cost benefit.

SUMMARY OF RESULTS

Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions VOC / NOx % tpd Est. Cost Effectiveness ($/ton) 109 Vanpooling Vanpool Light-duty On-road 41 / 30 tpd 0.4 / 0.2 0.1 / 0.07 $71,000 for VOC + NOxG:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 126 Reduced Idling_051009.doc 

### Control Measure: #84, 126, 147, 148, Reduced Idling Category: On-road Author: Chris Lindhjem, ENVIRON

DESCRIPTION

Idling of vehicles is inherently an ine fficient operation that can produce unwanted air pollutants. Idling however also occurs duri ng normal driving and other operations such as when the engine powers necessary accesso ries including for example man-lifts or concrete tumblers. Therefore it is not possi ble to eliminate all idling. But idle reduction programs are interesting because the costs are typically low and may be a net savings to the owner/operator of the vehicle while also reducing air emissions.

IMPLEMENTATION FEASIBILITY

There are several methods that have been attempted to reduce idling of vehicles; primarily from heavy-duty trucks that ofte n idle while the driver is off-duty or performing other duties nearby. There are two basic methods: a voluntary approach where alternatives to idling are provided, and a punitive (fines) method where no idle zones are posted and poli ced to eliminate idling.

PUBLIC ACCEPTANCE

A voluntary program can achieve enthusiastic support because infrastructure to reduce fuel costs can be paid for from public f unding. A requirement to eliminate idling would be difficult to administer, but would have a larger impact on emissions.

ANALYSIS

In the strictest implementation, idling more than 5 minutes would be prohibited except for normal operations whether or not an altern ative to idling exists. This could affect all heavy-duty vehicles whether delivery / retail vehicles or other vehicle functions.

The EPA (2004) guidance estimates that up to 3.4% of Class 8 truck NOx emissions could be reduced through reduced long durati on idling programs. This presumably sets up the maximum benefit for programs such as the IdleAire truck stop electrification project funded by TERP.

For light-duty vehicles at drive-thru operati ons, it would be difficult to gauge how much that would be. For an extraordinary total, even if an astound ing 10% of the HGB population of 5,628,101 idled 10 extra minutes in a single occupancy vehicle, theG:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 126 Reduced Idling_051009.doc 

### resulting emissions increase would be 0.16 tpd VOC and 0.04 tpd NOx. This calculation used the emission rates in Table 1 for pa ssenger cars and light-duty gasoline trucks.

Table 1. Idle emission rates for light-duty gasoline vehicles in 2018.

Vehicle Type VOC (g/hr) CO (g/hr) NOx (g/hr) LDGV (passenger cars) 1.56 10.55 0.38 LDGT1 (Light-duty trucks) 1.70 11.01 0.36
LDGT2 1.82 12.49 0.53
LDGT3 1.16 9.58 0.37
LDGT4 1.22 10.03 0.57



### EMISSIONS AFFECTED

The EPA guidance on reduced id ling includes an upper end es timate of 3.4% of area NOx due to extended idling. For the all diesel and gasoline trucks the NOx emissions are 21.6 tons per day, and for the larger Class 8 truc ks (the subject of the EPA guidance) the NOx emissions are 13.2 tons per day for a weekday in 2018.

EMISSIONS BENEFIT

If idle reduction programs can be expande d to all heavy-duty vehicles, then 0.73 tpd could be reduced. The long duration idli ng reduction for Class 8 maximum would be 0.45 tpd of which 0.33 tpd was credited to the IdleAire TERP project expected to last through 2020.

COST AND COST-EFFECTIVENESS

The TERP program to supply idle reduction technology in the HGB area was estimated to reduce NOx emissions at $1,200 per ton. This truck stop electrification project however targets the most readily available and likel y largest source of id ling trucks, and so reducing idling in other areas would pr oduce less benefit for the investment.

It is not possible to estimate the lost revenue and cost of prohibiting drive-thru operations during ozone episodes or for the summer seas on when ozone events would likely occur.G:\HGAC\Reports\Final_051009\Appdx_F_051009\Cont rol Measure 126 Reduced Idling_051009.doc 

### SUMMARY OF RESULTS

Expected Emission Reduction Measure ID Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effectiveness ($/ton)

126, 147, 148 Idle limits forheavyduty vehicles Idle Reduction Programs Heavyduty vehicles 13.2 – 21.6 3.4 0.45 – 0.73 $1,200

84 Prohibit drive-thru service during

ozone

season Idle Reduction Program Light-duty vehicles 40.7 VOC 30.3 NOx 0.4% VOC 0.1% NOx 0.16 VOC 0.04 NOx Unknown



### REFERENCES

EPA. 2004. “Guidance for Quantifying and Us ing Long Duration Truck Idling Emission Reductions in State Implementation Pl ans and Transportation Conformity,” Office of Transportation and Air Qual ity,” EPA420-B-04-001, January 2004, pg. 12 http://www.epa.gov/SmartwayLogistics/documents/420b04001.pdf

.G:\HGAC\Reports\Final_051009\Appdx_F_051009 \HGAC Measure 127 Mex trucks_051009.doc 

### Control Measure: #127, Heavy Duty Vehicle Border Inspection Program Category: On-road Author: Hazel Barbour

DESCRIPTION

This measure would build on the safety inspecti on procedures now in place at Texas/Mexico border crossings using remote sensing to identify high emitting vehicles.

IMPLEMENTATION FEASIBILITY

DPS regulations require that HDDVs undergo sa fety inspections at border crossings (HDDV inspections are also carried out at weigh stations throughout the st ate). Current Texas legislation allows emissions testing of diesel vehicles if TCEQ determines that an inspection program would minimize emissions (HSC.382.2.2(i)). Of the more than four million trucks that crossed the border from Mexico into the United States in 2003, 68 percent enter through Texas Ports of Entry. 

### However, most of these Mexican trucks are currently restricted to operating within the designated commercial zones loca ted around the border cities. In these zones, which stretch 20 miles on both sides of the Mexican border, dray age trucks cross the border from Mexico to depots where their load is transferred to US trucks for onward transportation.

The only current exceptions to this restriction ar e a very small number of Mexican carriers that were grandfathered in and those carriers taking part in a pilot program implemented by US DOT. This 12 month program began in September 2007 and allows up to 100 carriers from each country to operate beyond the desi gnated commercial zones if their trucks have effective safety controls in place. However, at the point of wr iting, funding to continue the program has not been appropriated and the future of e xpanding the ability of Mexican trucks to operate outside of the 20 mile commercial zones is unclear. According to the Council on Hemispheric Affairs, at the halfway point of the program, “more than twice as many US truckers (680 trips) had exercised their extended privileges in comparison to their Mexican counterpa rts (325 trips)”.

I 

### n order for implementation of emissions inspec tions at Texas border crossings to have any identifiable impact on emissions of pollutants in the Houston-Galveston-Brazoria area, the current restriction on allowing Mexican trucks to operate more widely in the US than in the designated commercial zones must be permanently lifted. Until then, the measure has little relevance for the HGB. Additionally, when the border is eventually fully open to Mexican trucks, it is still to be expected that the transition from the curr ent drayage system will be very gradual (Border Transportation Studies Review, TTI Aug 2005).

Heavy Duty Remote Sensing Devices (HDRSD) studies have demonstrated the potential for using remote sensing to measure total emissions of in-use NO (from which NOx can be deduced) and VOC, but more work still has to be done to establish reliable pa ss/fail remote sensing cutpoints.G:\HGAC\Reports\Final_051009\Appdx_F_051009 \HGAC Measure 127 Mex trucks_051009.doc 

### PUBLIC ACCEPTANCE

Reducing emissions from diesel trucks is a strategy which is generally well received by the public. The Teamsters, Public Citizen, and Sie rra Club are opposed to opening the border to Mexican trucks.

ANALYSIS

Opening the Texas/Mexico borde r to through truck traffic may result in increased Mexican plated trucks passing through the HGB area. Results from the cross border truck study carried out at Nogales showed little difference between emissions from trucks based on where they are registered i.e. in Mexico or the US. Howeve r, it should be noted that the Nogales study was conducted in 2006, prior to the pilo t program allowing the limited number of long haul trucks to cross the border. Thus, almost all of the cro ss border traffic in the study would be drayage traffic. In the study, using a cutpoint of 144 gms/gal NO (approx 10.7 gm/bhp-hr NO) equivalent to approximately 13.4 gms/bhp-hr NOx, a bout 10% of the trucks at the border were flagged as potential high emitters. 95% of the trucks scanned were class 8 HDDVs.

While remote sensing at the border is implem entable, until pass/fail NOx emissions cut points are agreed upon, it is difficult to adequately estimate potential emissions reductions achievable using this testing methodology. However, i 

### t is possible to identify whether or not MY 1993-98 HDDVs manufactured in the US and sold in Mexico have NOx defeat devices in place (see the Consent Decree between the truck manufacturers and EPA) by usi ng remote sensing to identify NOx levels higher than would be expected in these model year trucks. EPA estimates that the emissions benefit from bringing a truck engine with a NOx defeat device back into compliance with the federal standard is approximately 2 gr ams/bhp-hr, equivalent to 6.06 grams/mile. As of September 2007, of the 1.1 million trucks in the affected US population, EPA estimated that 9.5% of the trucks had been reflashed with th e low NOx kit. In th e Nogales truck study approximately 300 MY 1993-98 vehicles were sens ed (approximately 16% were Mexican plated trucks, 74% dual plated trucks, a nd 10% US plated trucks). For the purposes of analyzing this measure, it is assumed that 90.5% of these truc ks have the NOx defeat device in place. As required by the Consent Decree, th e cost of reflashing MY 1993-98 tr ucks is borne by the engine manufacturers.

Environmental Systems Products Inc (ESP) estim ates that a 6 month remote sensing pilot program would cost $789,458.

For the purposes of analyzing this measure, the writer is not able to make an assessment of the number of long haul trucks which will travel through the HGB area in the eventuality of the Texas/Mexico border becoming fully open to cross border traffic.

EMISSIONS AFFECTED

NOx emissions from on-road heavy duty diesel emissions for the 8 county HGB area of 19.97 tpd.G:\HGAC\Reports\Final_051009\Appdx_F_051009 \HGAC Measure 127 Mex trucks_051009.doc 

### EMISSIONS BENEFIT

Emissions benefit was calculated from re-flashing 272 class 8b HDDVs using EPA’s estimate of 2 grams/bhp-hr NOx reduction per vehicle (6.06 grams/mile). The average Class 8b annual mileage of 75,343 was deduced from the vehicle registration distributi on in Harris County and the MOBILE6 mileage accumulation.

NOx reduction per vehicle: 0.503 tons per year Total NOx reduction: 136.8 tons per y ear or 68.3 for 6 month pilot project Tons per day NOx reduction (assumi ng 250 day year): 0.547 tons per day

COST AND COST-EFFECTIVENESS

The only cost readily available is ESP’s estimate of $789,458 for a 6 month remote sensing pilot program. The cost of the NOx reflash is not in cluded as this should be borne by the engine manufacturers. It is assumed that approxima tely the same number of MY 93-98 HDDVs will be identified as in the Nogales truck study. Cost effectiveness is therefor e calculated as $11,542 per ton of NOx reduced.

SUMMARY OF RESULTS

Expected Emission Reduction Measure ID Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effectiveness ($/ton)

127 Heavy duty border vehicle inspection program Use of remote sensing at Texas border crossing(s) to identify high emitting vehicles – pilot program On-road HDDV NOx emissions 19.67 tpd NOx 2.74% 0.547 tpd NOx from 272 MY 1993- 98 vehicles $11,542 per ton NOx



### REFERENCES:

Council on Hemispheric Affairs: www.coha.org

.
Texas Transportation Institute, Texas A&M Univer sity: Border Transportation Studies Review, Aug 2005.

M J Bradley and Associates: Cross Border In-U se Emissions Study for Heavy Duty Vehicles, Nogales, AZ, September, 2006.

Environmental Systems Products Inc (ESP): Re mote Sensing proposal for Diesel Emission Control Evaluation, Nov 2008

US EPA: Anne Wick, Vehicl es and Engines Team Leader; wick.anne@epa.gov

.G:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC measure133 IM_051009.doc 

### Control Measure: #133, Expand the emission s testing program to 3 counties not currently included in the program Category: On-road Author: Hazel Barbour

DESCRIPTION

This measure would extend implementation of the vehicle emissions inspection (I/M) program to Chambers, Liberty and Waller c ounties. While initial TCEQ regulations required that the ASM/OBD program be im plemented in these counties in 2004, the county judge and commissioners’ court of each of the three counties petitioned TCEQ to remove the requirement.

IMPLEMENTATION FEASIBILITY

Current legislation (HSC 382.302(a)) allows fo r counties not required to implement an I/M program to opt-in as fo llows: (petition to TCEQ) mu st be made by a resolution adopted by the governing body of the particip ating county and the governing body of the most populous municipality in the county. Im plementation of the Low Income Repair and Assistance Program (LIRAP) is not a re quirement of I/M program implementation, thus counties wishing to implement LIRAP are also required to opt in to this program in a similar manner.

If an I//M program is proposed for the three counties, the issue of whether to only test MY 1996 and newer vehicles (i.e. OBD test) or to also include the ASM test requirement for older vehicles will need to be addresse d. Current estimates of ASM/OBD analyzer costs range from $32,000 - $40,000. OBD-only analyzer costs range from $7,000 to $9,000. It is unlikely that the program coul d be in place in the three counties until 2010/11 at the earliest. By that point, it is estim ated that only 6% of subject vehicles will be MY 95 and older (data from ENVIRON, 2006) and that number will drop further every year. Given the increasingly smaller num ber of vehicles subjec t to tailpipe testing, it may be difficult to convince all of the 47 exis ting safety inspection stations in the three counties to pay the costs of purchasing ASM/OBD test equipment. An alternative to ASM testing would be the two speed idle test which does not require the use of a dynamometer and thus is cheaper to install and operate, but repairing failed vehicles to pass this test would only achieve VOC reductions from the MY 1995 and older vehicles.

In a program area where both ASM and OBD testing is required, current rules (TAC Title 37, Part 1, Chapter 23, Subchapter G, 23.95) al low waivers to be granted to inspection stations to offer OBD only testing (known as a low volume waiver). An inspection station operating under such a waiver is limited to perfor ming 1200 emission inspections per year (each month, the inspection station is allocated 100 emission tests). If the I/M proposal requires all 2-24 year old gasoline vehicles registered in the three counties to be tested, it could be possible to implement th e program in the first years by granting lowG:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC measure133 IM_051009.doc 

### volume waivers to all 47 inspections stations (thus allowing them to continue to offer safety inspections) and require that MY 95 a nd older vehicles be either tested at an ASM/OBD inspection station in one of the fi ve existing I/M program counties or at a DPS referee station. Alternatively, a very sma ll number of inspection stations within the three counties could be allowed to offer bot h ASM and OBD testing with the remainder being granted low volume waivers. In all the above scenarios, it is assumed the test fee for both the ASM and OBD tests would be the sa me as in the existing five HGB counties, i.e. $27.00 (plus $12.50 safety inspection fee). A program adopted in the thre e counties could feasibly only require MY 1996 and newer vehicles to be subject to emissions testing (using OBD). In this case, there may be an equity issue regarding the test fee in relation to the existing program in the original five counties where MY1995 and older vehicles must be tested. The $27.00 emissions test fee was originally based on the costs of ASM tes ting. However, current legislation in HSC 382.202 (h) does allow TCEQ to set different test fees for different counties.

PUBLIC ACCEPTANCE

Past history indicates there may be opposition to this measure at the county level. If the proposal is to only require MY 1996 and newer vehicles to be teste d, concerns could be raised regarding allowing the oldest most highly polluting vehicles to avoid emissions testing. Adopting a fee lowe r than $27.00 in an OBD only program may increase general public acceptance but may cause a degree of unrest in the adjacent counties currently implementing ASM/OBD.

ANALYSIS

This measure was analyzed by comparing em issions in the three counties with and without an ASM/OBD I/M pr ogram using MOBILE6. The I/M program was modeled assuming ASM testing at phase-in cutpoints. It was assumed that the emissions test fee for all subject vehicles will be $27.00 and that this fee covers the inspection station costs and the LIRAP costs. The number of subject vehicles in the 3 counties was estimated out to 2018 by taking the total number of subject vehicles for Chambers, Liberty, and Waller in the 2003 SIP revision (89,251) and growing that nu mber out by the 3% fleet turnover rate used in MOBILE6. In the 2006 five county I/M program, the ASM failure rate was 9.5% and OBD 5.4% (TCEQ). Given the higher failure rate for OBD vehicles expected as these vehicles age out to 2015- 2018, an overall program failure rate of 8.5% has been used. Given that the emissions inspection fee for the new program will include an element to cover the LIRAP costs, additi onal costs have not been added to account for uptake of LIRAP funds for repair and repla cement of vehicles in the proposed new 3 county program area (the average LIRAP repa ir and replacement costs over the years 2015-2018 are estimated to be $447,732).G:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC measure133 IM_051009.doc 

### EMISSIONS AFFECTED

On road weekday emissions from light duty gasoline vehicles in Chambers, Liberty and Waller counties: NOx, 3.32 tpd; VOC 2.66 tpd.

EMISSIONS BENEFIT

Modeled emission reductions in 2018 from implementing the program in the three counties: NOx, 1.26 tpd; VOC, 0.85 tpd. A tool was developed by TCEQ to approximate the HGB area emissions using a single MOBILE6 model run. This tool was used with a MOBILE6 model run using the I/M program in adjoining counties applied to these three counties.

COST AND COST-EFFECTIVENESS

Cost effectiveness is calculated as the aver age total cost of the program for the years 2015-2018 divided by the annual emissions reductions in 2018 (tons per day multiplied by 250). The average annual program cost in cluding LIRAP costs was estimated to be $3,938,914. VOC: $16,912 per ton NOx: $11,028 per ton VOC plus NOx: $6,813 per ton

SUMMARY OF RESULTS

Expected Emission Reduction Measure ID Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effectiveness ($/ton)

133 Expansion of the I/M program to Chambers, Liberty and Waller Counties Remaining three HGB nonattainment area counties (Chambers Liberty and Waller) opt in to I/M Light and Heavy duty gasoline vehicles VOC - 2.66 NOx - 3.32 VOC 32% NOx 38% VOC 0.85; NOx 1.26 VOC $16,912 NOx $11,028;

NOx+VOC $6,813



### REFERENCES

Texas Health and Safety Code (HSC)

Texas Administrative Code (TAC)G:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC measure133 IM_051009.doc 

### Personal contact with Carl Nord, En vironmental Systems Products (ESP)

Personal contact with Danny Knauth, Texas Department of Public Safety.

ENVIRON 2006. “Low Income Repair a nd Assistance Program Evaluation and Improvement, Prepared for the Houston Advanced Research Center, H72AB, September 2006.

Texas State Implementation Plan Revisi on, Oct 8, 2003; Rule Log No: 2003-034-114-A1

Graciela Lubertino, H-GAC, personal communication.G:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC Measure 149 IM cutpoints latest_051009.doc 

### Control Measure: #149, More Stringent I/M Cut Points Category: On-road Author: Hazel Barbour

DESCRIPTION

This strategy would impact Model Year 1995 and older gasoline vehicles subject to Acceleration Simulation Mode (ASM) testing in the Hous ton-Galveston-Brazoria (HGB) area vehicle inspection and maintenance (I/M) program. Vehicles older than 24 years old are not subject to any I/M testing and vehicles above 8,500 lbs GVW R and 4-wheel drive vehicles that cannot be tested on a dynamometer are subject to two-sp eed idle testing (which does not capture NOx emissions). The cutpoints currently in use that determine whether a vehicle passes or fails the ASM test are the original EPA phase-in cutpoints. The emissions reductions included in the HGB SIP are modeled using this data. EPA expect ed programs to eventually transition to more stringent final cutpoints, which are included in the MOBILE6 model. Using the final cut-points could result in failure rates sim ilar to those found in enhanced I/ M programs such as centralized IM 240 testing and could include a high percentage of false failures. EPA issued a memo in August 2002 releasing revised fina l cutpoints for ASM testing ba sed on real world experience, which more strongly target only tr ue failures. These alternative final cutpoints receive the same level of credit in MOBILE6 as the previous EP A final ASM cut-points. In addition, it might be useful to reexamine the exemption for vehicles 24 years and older to capture all vehicles that would benefit from maintenance.

IMPLEMENTATION FEASIBILITY

Modifications to the current ASM analyzer soft ware will be required to incorporate the new cutpoints. Once the analyzer manufacturers ha ve the new software available, this can be downloaded to all the ASM analyzers within 2/ 3 weeks. The current number of inspection stations offering ASM testing in the 5 counties is 966. (Note: if the HGB ar ea wishes to adopt the more stringent cutpoints, it is likely that th e DFW area will also do this.) ESP, which has sold 598 ASM analyzers into the HGB program (a number of the stations have more than one ASM test lane) has estimated a cost of $75,000 for the software update and download to their analyzers for both the HGB and DFW areas.

In 2006 the average ASM failure rate was 9.5% of the subject vehicles. Implementing revised final cutpoints is likely to resu lt in a higher failure rate amon g MY 1995 and older vehicles than currently experienced with vehicles tested at phase -in cutpoints, which will in turn mean a higher percentage of older vehicles fail ing and requiring repair. While it is difficult to find a reliable estimate of the expected increase in the percen tage of vehicles failing the ASM test, as the number of MY 1995 and older vehicles drops annuall y, the absolute number of failing vehicles is likely to fall accordingly.

In 2008, it is estimated that 15% of the fleet is MY 1995 and older. By 2011, it is estimated that 6% of the fleet will be MY 95 and older (ENVIRON, 2006). If the age range subject to I/M testing remains as 2-24 year old vehicles, then by 2018 there will be a very small number of these age range vehicles whic h are MY 1995 and older and elig ible for ASM testing. For inspection stations offering both ASM and OBD te sting, it may become increasingly uneconomic to continue to have to pay up to $4,000 per year for a maintenance contract for the emissionsG:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC Measure 149 IM cutpoints latest_051009.doc 

### analyzer and dynamometer. Thus, the availability of ASM testing for these older vehicles may become very limited (note: curre nt TCEQ/DPS rules allow inspect ion stations to be granted a waiver from offering ASM testing to be able to offer OBD testi ng only, if the stations agree to conduct less than 1200 OBD tests per year: TAC Title 37, Part 1, Chapter 23, Subchapter G, 23.95).

PUBLIC ACCEPTANCE

General acceptance of the revised cutpoints should not be a problem as the majority of subject vehicles are MY 1996 and newer. However, as the percentage of MY 1995 and older vehicles drops, the burden of the potentially higher failur e rate will fall more heavily on lower income vehicle owners. Repairing the oldest vehicles to pass the ASM test at the more stringent cutpoints may prove problematic. The increas ed funding now available under LIRAP should, however, mitigate these repair costs to some ex tent and may encourage more vehicles to be scrapped if they can’t be repaired - thus fu rther reducing the number of MY 1995 and older vehicles in the fleet. It should also be noted that the owner of a vehicle at least 10 years old may be eligible for financial help to replace a vehicle even if that vehicle has not failed the emissions

test.

ANALYSIS

The emission reductions were calculated using MOBILE6 to model moving the program in the five counties from phase-in to revised final cutp oints and modeling the program with the waiver rate of 3%. To estimate the impact on the number of vehicles failing more stringent ASM cutpoints and the resulting potential number of additional vehicles, which could be replaced through LIRAP, an additional 1 percent of MY 1995 and older vehicles were assumed to fail the test (it is difficult to find accurate estimates of the increased failure rate). As by 2018 the only vehicles subject to ASM testing will be 22-24 years old, the emi ssion reduction benefits from the vehicles estimated to be replaced at an additi onal 1% failure rate (ave rage 201 per year from 2015-2018) are estimated to very small, i.e. 2.8 pounds per year NOx and 1.1 pounds per year VOC.

EMISSIONS AFFECTED

Emissions affected are onroad light and heavy- duty gasoline vehicle emissions in Harris, Brazoria, Galveston, Fort Bend and Montgomery counties.

EMISSIONS BENEFIT

Estimated emission reductions in the 5 county HGB area are as follows based on the use of a modeling tool supplied by TCEQ to allow changes in MOBILE6 r uns and calculate approximate area-wide emissions totals. The benefit of the I/M program change would result in 2018: NOx 0.13 tpd and VOC 0.12 tpd.G:\HGAC\Reports\Final_051009\Appdx_F_051009\HGAC Measure 149 IM cutpoints latest_051009.doc 

### COST AND COST-EFFECTIVENESS

Based on the emission reductions modeled for 2018 and the average annual costs covering repair and replacement for an additional 1% of vehicles failing the ASM te st (current failure rate is 9.5%), the estimated total annual cost of this measure is $1,1 28,199.6 and the cost effectiveness per ton of NOx is $20,268; per ton of VOC, $25, 232; and per ton of VOC and NOx combined, $11,281.

Additional assumptions applied in calculating cost effectiven ess: the number of MY 1995 and older vehicles drops by 16% per year (from HA RC/Environ LIRAP report); cost of software modifications to all the ASM analyzers fo r HGB area only, approximately $75,000 (does not include any costs to upgrade the VID); average LIRA P repair cost of $517 used as the repair cost for all failing vehicles; and 18.9% of failing vehicles are replaced (percentage taken from 2007 HGAC LIRAP data).

SUMMARY OF RESULTS

Expected Emission Reduction Measure # Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effectiveness ($/ton)

149 More stringent I/M cutpoints Changing to EPA’s revised final cutpoints for ASM test for MY 1995 and older vehicles. On-road light and heavy duty gasoline vehicles in 5 counties VOC - 37.2 NOx - 26.9 VOC 0.32 NOx 0.48 VOC 0.12 NOx 0.13; VOC $25,757 NOx $23,776

VOC and NOx $12,363



### REFERENCES

EPA memorandum, August 16, 2002 from Greg ory Green, Director Certification and Compliance Division, to EPA Re gional Air Division Directors, entitled “Revised Final cutpoints for ASM 5015 and 2525”.

Dave Sosnowski, State Measures and Conform ity Group, EPA Office of Transportation and Air Quality.

ENVIRON 2006. “Low Income Repair and Assi stance Program Evaluation and Improvement, Prepared for the Houston Advanced Research Center, H72AB, September 2006.

Chad Lenz, TCEQ I/M team, 2006 correspondence.

Carl Nord, Environmenta l Systems Products (ESP).

Danny Knauth, Texas Department of Public Safety.

Graciela Lubertino, HGAC personal communication.

### APPENDIX G

Detailed Evaluations for Non- Road Control StrategiesG:\HGAC\Reports\Final_051009\Appdx_G_051009\ Control Measure 5b Locomotive_051009.doc 

### Control Measure: #5, Voluntary Retrof it/Replacement Program - Locomotive (and other replacement retrofit funding, Measures 39 and 40) Category: Nonroad Author: Chris Lindhjem, ENVIRON

DESCRIPTION

Voluntary retrofit and replacement programs ha ve been used across the US to reduce emissions using a variety of co-funding incenti ve programs to offset the costs incurred.

In Texas, the popular TERP program has been successful in providing co-funding for many emission reduction projects of many different types of emission sources, including, on-road trucks, construction and off-road equi pment, marine vessels, and locomotives. To date, about $300 million of projects have b een approved in the HGB area from 2002 through 2008 with most of the funding occurring in the 2004 through 2008 period. Because the most recent projects have ju st been approved, not all of the emission reductions have been reali zed and are still pending.

In addition, there are other funding sources for control strategy projects including the EPA grant program run by a local collaborative ( http://www.blueskyways.org/ ). The EPA funding program was relatively limited at $5,000,000 in 2008 ( http://www.blueskyways.or g/pdf/clean-diesel-FY08.pdf ) for the states of Arkansas, Louisiana, New Mexico, Oklahoma, Texas, Iowa, Kansas, Missouri, Nebraska, and Minnesota. Nationally this program wa s funded at $49.2 million in 2008, of which, $27.6 million was available for National Clean Diesel Funding Assistance Program. Half of the National Clean Diesel Funding Assist ance Program is dedicated to public fleets. Other monies were distributed to the Stat es, research, and a re volving loan program.

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

This measure describes the issues and poten tial for locomotive replacement projects.

IMPLEMENTATION FEASIBILITY

The TERP program has worked well by co-f unding fleet improvements for on-road and off-road vehicles and equipment. TCEQ has developed the organization and principles to administer the program formalizing the appl ication process and providing assistance to owner/operators in implementing the emission re duction projects. The industrial owners of equipment have been ent husiastic participants of th e program, and provide a large portion of the program funds.G:\HGAC\Reports\Final_051009\Appdx_G_051009\ Control Measure 5b Locomotive_051009.doc 

### PUBLIC ACCEPTANCE

The current funding mechanism has been acceptable to nearly all parties, but the cost effectiveness goals may need to be reconsider ed to continue to have the program fully subscribed. The continued funding with the current mechanism will require legislative and executive support.

ANALYSIS

One of the most effective emission reducti on projects is the re placement of older locomotive engines with those meeting the lower emission standards. So the basis of this analysis is to compare emission rates from the older engines to the new locomotive standard in order to estimate an emission reduction potential.

EPA announced final emission standards for locomotive engines (EPA, 2008) which included an analysis of the expected benef it of normal fleet turnover and the additional benefit of the EPA rule. The emission standa rds include a retrofit of existing equipment as well as new engine emission standards. Existing Tier 0, 1, and 2 engines will be subject to retrofit at the ti me of remanufacture; so the existing engines will be rebuilt gradually throughout their remaining usef ul life regardless of incentives.

The emissions standards and projected EPA em ission factors are shown in Tables 1a and 1b, depending on the duty cycle chosen to ce rtify the engines: either line-haul or switching engine duty cycles. The duty cycle for line-haul engines typically leads to lower emissions on a gram per horsepower- hour (hp-hr) basis because the switching engine duty cycle has a consid erable idling time (no hp-hr generated) and lower power modes where the engine operates inefficiently. In some cases the uncontrolled emissions are much lower than some of the emission st andards, so no emission reduction would be expected from some of the standards especially for HC and CO emissions.

Table 1a. Locomotive – Emission standards (g/hp-hr) for line-haul (duty cycle) engines.

Emission Standard Applicable Year HC (g/hp-hr) CO (g/hp-hr) NOx (g/hp-hr) PM (g/hp-hr) Uncontrolled Emissions Pr e-1973 0.48 1.28 13.0 0.32 Tier 0 – original 1973 – 2001 1.00 5.0 9.5 0.60 Tier 0 – final 1 2008 / 2010 1.00 5.0 8.0 0.22 Tier 1 – original 2002 – 2004 0.55 2.2 7.4 0.45 Tier 1 – final 1 2008 / 2010 0.55 5.0 7.4 0.22 Tier 2 – original 2005 0.30 1.5 5.5 0.20 Tier 2 – final 1 2013 0.30 1.5 5.5 0.10 Tier 3 2012 – 2014 0.30 1.5 5.5 0.10 Tier 4 2 2015 0.14 1.5 1.3 0.03 1. These are retrofit standards at the time of rebu ild and phased in as retrofit kit availability allows. 2. The Tier 4 NOx standard can be a 1.4 NOx + HC standard. The NOx standard may be delayed until 2017.G:\HGAC\Reports\Final_051009\Appdx_G_051009\ Control Measure 5b Locomotive_051009.doc 

### Table 1b. Locomotive – Emission standards for switching (duty cycle) engines.

Emission Standard Applicable Year HC (g/hp-hr) CO (g/hp-hr) NOx (g/hp-hr) PM (g/hp-hr) Uncontrolled Emissions Pr e-1973 1.01 1.83 17.4 0.44 Tier 0 – original 1973 – 2001 2.10 8.0 14.00 0.72 Tier 0 – final 1 2008 / 2010 2.10 8.0 11.80 0.26 Tier 1 – original 2002 – 2004 1.20 2.5 11.00 0.54 Tier 1 – final 1 2008 / 2010 1.20 2.5 11.00 0.26 Tier 2 – original 2005 0.60 2.4 8.10 0.24 Tier 2 – final 1 2008 / 2013 0.60 2.4 8.10 0.13 Tier 3 2011 - 2015 0.60 2.4 5.00 0.10 Tier 4 2 2015 0.14 2.4 1.30 0.03 1. These are retrofit standards at the time of rebu ild and phased in as retrofit kit availability allows. 2. The Tier 4 NOx standard can be a 1.4 NOx + HC standard. The NOx standard may be delayed until 2017.



### EMISSIONS AFFECTED

Table 2 shows the approximate summary em issions for non-road equipment emissions for 2018. The actual emissions may vary from day to day (such as weekday and weekend day) and depend upon whether the implementati on of control strategies, such as TERP and TxLED, have or should be included in th e estimates. Table 2 should be considered as reasonable estimates rather than exact figures.

Table 2. Approximate 2018 baseline nonroad mobile source missions inventory. Summer Weekday Emissions (tons) Aggregate Equipment Category Equipmen t Population NO X VOC CO Agricultural Equipment 5,972 1.85 0.22 2.46 Airport Ground Support Equipment 975 0.39 0.05 0.53 Commercial Equipment 256,241 6.50 10.95 425.19 Construction and Mining Equipment 97,192 19.07 4.34 64.34 Industrial Equipment 39,145 5.87 0.89 21.99 Lawn and Garden Equipment 1,664,135 2.12 17.98 300.42 Logging Equipment 2,154 0.05 0.13 1.75 Pleasure Craft 129,479 1.47 14.91 31.95 Railroad Equipment 126 0.05 0.01 0.04 Recreational Equipment 79,794 0.27 4.55 40.26 Underground Mining Equipment 0 0.00 0.00 0.00 8-County HGB Total General Nonroad 2,275,213 37.64 54.02 888.92 8-County HGB Total Spark-Ignition Nonroad 2,150,612 9.35 50.79 874.80 8-County HGB Total Diesel Nonroad 124,601 26.59 1 3.23 14.12 Locomotive – Line Haul N/A 15.77 0.84 2.49 Locomotive – Switching N/A 22.43 1.51 3.38 Harbor craft N/A 13.40 0.29 3.32
OGV – transit N/A 18.36 0.54 1.88
OGV – dwell N/A 13.69 0.35 2.42
Aircraft N/A 8.85 2.55 29.72
All nonroad mobile sources 128.43 60.1 932.13 1 – 6% lower diesel nonroad NOx emissions than TCEQ provided to approximate the TxLED emission reduction not included in the submittal.G:\HGAC\Reports\Final_051009\Appdx_G_051009\ Control Measure 5b Locomotive_051009.doc 

### EMISSIONS BENEFIT

Table 3 indicates most recent information on the benefit and cost per project from the TERP program in the HGB area. The most typical project was to replace current equipment that would not necessarily be replaced otherwise. However, regardless of the inflation rate, the new engine costs are expect ed to increase because of the new emissions standards, so the current TERP figures may underestimate the cost of future projects. Also, some TERP projects combine two or more categories of project types. The figures here can vary depending upon the size of the engine and other considerations. The figures in Table 3 are approximate and may change as the projects are implemented and reviewed.

Table 3. TERP implemented and pending projects in HGB.

Project Type Total Cost Number of Projects Cost per Project Total NOx Reduced (tpd) NOx Reduction per Project (tpy) Locomotive $75,996,969 116 $655,146 7.29 22.95 Marine $39,216,837 400 $98,042 5.99 5.46 Non-road $81,284,069 1,995 $40,744 7.86 1.44 On-road $103,974,922 1,867 $55,691 10.63 2.08



### The projects for locomotives have focused on switching engine replacement projects because the railroads may not be able to gua rantee that the line-haul locomotives would be used a majority of the time within the area. Because the focus has been on switching engines and the program has been successful replacing more than 100 switching engines, it is difficult to know how many more switching engines can be replaced. The predominant locomotive project is the replacem ent of switching engine s with a specially designed locomotive that already meets the Ti er 3 NOx emissions levels or below. The next significant change in NOx emissions for new locomotives based on the Tier 4 emission standards is not slated to occur unt il 2017, and that standa rd is subject to a technology review, so Tier 4 engines may not be wide ly available until the 2018 timeframe for the state implementation plan.

Given the review of locomotive emission in HGB (ERG, 2006, http://files.harc.edu/Projects/AirQuality/Projects/H018.2003/H18FinalReport.pdf ), approximately 206 switch locomotives were sa id to exist in HGB. Forecasting to 2018, then about 250 switching engines would be operating in HGB in 2018.

To the extent that Tier 3 compliant switching en gines are available, th en about half of the switching engines could be replaced with lower emitting engines. The benefit in emissions (shown in Table 1b) between replaci ng a Tier 0-final engine (with 1.2 and 11.8 g/hp-hr VOC and NOx emission rates) is half th at of replacing a pre-controlled switching engine (at 1.0 and 17.0 g/hp-hr VOC and NOx) with a Tier 3 engine that would have 0.6 and 5.0 g/hp-hr emission rates. It is most likely that the pr e-controlled engines were theG:\HGAC\Reports\Final_051009\Appdx_G_051009\ Control Measure 5b Locomotive_051009.doc 

### ones that were replaced in the TERP program, but by 2018 most locomotives will need to have been rebuilt to Tier 0 emission standards.

One issue is how many more switching engine s can be replaced with low emissions switch engines because the lower emitting switch ing engines available at the time of this writing at the end of 2008 have limited ma ximum power. Often switching engines are used for some line-haul duty and so must ha ve sufficient power fo r that duty as well. Therefore, arbitrarily half of the rema ining maximum penetr ation rate (roughly 58 locomotives) was chosen as a lower limit of what could be achieved.

COST AND COST-EFFECTIVENESS

Table 3 indicated the cost and cost effectiven ess of the TERP projects to date and inform the forecast for future projects.

The TERP locomotive cost effectiveness of pr ojects to date has been less than $5,000 per ton of NOx reduced. Using the TERP cost and emission reduction per project and an average project life of 10 years, the averag e cost effectiveness would be estimated at about $3,500 per ton of NOx reduced. However, if the remaining switching locomotives meet the Tier 0 standards under the expected rebuild schedule, then the benefit for the replacement program would be half of that for the TERP program to date resulting in a lower cost effectiveness of about $7,000 per ton reduced.

If Tier 4 compliant engines become availa ble, then the cost effectiveness for the additional NOx and PM reduction equipment (from Tier 3 to Tier 4 EPA, 2008) is estimated to be about $50,000 to $80,000 more per engine for original engine manufacturers. Using the lower figure the cost effectiveness for the added equipment would be $13,000 per ton of VOC and $2,000 per t on of NOx for Tier 4 compared with the Tier 3 standard.

Because about half of the switching engines have been replaced and the remaining ones would probably already meet the Tier 0 standard s resulting in half the individual benefit, the potential emission reductions would be a bout half as large as has already been realized in the TERP program. Because not a ll switching engines might be available for replacement, a lower emission reduction potential was chosen.

SUMMARY OF RESULTS

Expected Emission Reduction Measure # Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effective-ness ($/ton) 3 Switch Locomotive Replacement Engine Off-road 1.5 VOC 22.4 NOx 10 - 15% 2 - 3.5 $3,500 - $7,000G:\HGAC\Reports\Final_051009\Appdx_G_051009\ Control Measure 5b Locomotive_051009.doc 

### REFERENCES

EPA. 2008. “Regulatory Impact Analysis: Control of Emissions of Air Pollution from Locomotive Engines and Marine Compression-Ignition Engines Less than 30 Liters per Cylinder,” EPA420-R-08-001, March 2008.G:\HGAC\Reports\Final_051009\Appdx_G_051009\ Control Measure 5b Marine_051009.doc 

### Control Measure: #5, Voluntary Retrofit/Replacement Program – Marine (and other replacement retrofit funding, Measures 39 and 40) Category: Nonroad Author: Chris Lindhjem, ENVIRON

DESCRIPTION

Voluntary retrofit and replacement programs ha ve been used across the US to reduce emissions using a variety of programs providi ng cofunding incentive to offset the costs incurred.

In Texas, the popular TERP program has been successful providing cofunding for many emission reduction projects of many di fferent types including on-road trucks, construction and off-road equipment, marine vessels, and locomotives. To date, about $300 million of projects have been approve d in the HGB area from 2002 through 2008 with the most of the funding occurring in the 2004 through 2008 period. Because the most recent projects have just been appr oved, not all of the emission reductions have been realized and are still pending

In addition, there are other funding sources for control strategy projects including the EPA grant program run by a local collaborative ( http://www.blueskyways.org/ ). The EPA funding program was relatively limited at $5,000,000 in 2008 ( http://www.blueskyways.or g/pdf/clean-diesel-FY08.pdf ) for the states of Arkansas, Louisiana, New Mexico, Oklahoma, Texas, Iowa, Kansas, Missouri, Nebraska, and Minnesota. Nationally this program wa s funded at $49.2 million in 2008 of which $27.6 million was available for National Clean Diesel Funding Assistance Program. Half of the National Clean Diesel Funding Assistance Progr am is dedicated to public fleets. Other monies were distributed to the States, research, and a revolving loan program.

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

This measure describes the issues and potential for marine engine replacement projects.

IMPLEMENTATION FEASIBILITY

The TERP program has worked well by co-f unding fleet improvements for on-road and off-road vehicles and equipment. TCEQ has developed the organization and principles to administer the program formalizing the appl ication process and providing assistance to owner/operators in implementing the emission re duction projects. The industrial owners of equipment have been ent husiastic participants of th e program, and provide a large portion of the program funds.G:\HGAC\Reports\Final_051009\Appdx_G_051009\ Control Measure 5b Marine_051009.doc 

### PUBLIC ACCEPTANCE

The current funding mechanism has been acceptable to nearly all parties, but the cost effectiveness goals may need to be reconsider ed to continue to have the program fully subscribed. The continued funding with the current mechanism will require legislative and executive support.

ANALYSIS

One of the most important methods for emi ssion reduction projects is to replace older vehicles and equipment with those meeting the lower emission standards. The retrofit projects often use technol ogies employed on new engines to meet the lower emission standards. So the basis of this analysis is to compare emission rates from the older with the new vehicles and equipment in order to estimate an emission reduction potential. The TERP program focuses on diesel emissions fr om on-road and off-road vehicles and equipment.

EPA recently announced proposed emission st andards for marine engines (EPA, 2008) that include an analysis of th e expected benefit of normal fleet turnover of the final rule. The emissions rates for baseline engines prio r emission control, and current and proposed emission standards shown in Table 1a a nd 1b for two representative tug propulsion engines. The actual standards and emission f actors are more complicated because they depend upon the engine size and whether it is used for propulsion or auxiliary power.

Table 1a. Emission standards (g/kW-hr) for Category 1 diesel marine engines (Sample engine: Caterpillar 3500 series, 4 liter/cylinder, <35 kW/l, 600 to 1000 kW).

Emission Standard Applicable Year HC (g/kW-hr) CO (g/kW-hr) NOx (g/kW-hr) PM (g/kW-hr) Baseline 1 (uncontrolled) <2000 0.27 1.5 10 0.30 Tier 1 2000 None None 10.5 None Tier 2 2007 5.0 7.2 0.20 Tier 3 2012 Included in NOx std. 5.0 5.8 0.11

Tier 4 2017 0.19 5.0 1.8 (HC+NOx) 0.04

1 Baseline are the precontrolled average emission rates det ermined by EPA, not official emission standards.



### Table 1b. Emission standards for Category 2 diesel marine engines (Sample engine: EMD-645, 10 liter/cylinder, <2000 kW).

Emission Standard Applicable Year HC (g/kW-hr) CO (g/kW-hr) NOx (g/kW-hr) PM (g/kW-hr) Baseline 1 (uncontrolled) <2000 0.50 1.1 13.2 0.72 Tier 1 2000 None None 11.4 None Tier 2 2007 5.0 7.8 0.27 Tier 3 2013 Included in NOx std. 5.0 6.2 0.14

Tier 4 2016 0.19 5.0 1.8 (HC+NOx) 0.04

1 Baseline are the precontrolled average emission rates det ermined by EPA, not official emission standards.G:\HGAC\Reports\Final_051009\Appdx_G_051009\ Control Measure 5b Marine_051009.doc 

### EMISSIONS AFFECTED

Table 2a shows the approximate summary emissions for nonroad equipment emissions for 2018 and Table 2b shows a more detailed summary of the harbor craft emissions. The actual emissions may vary from day to day (such as weekday and weekend day) and depend upon whether the implementation of c ontrol strategies, such as TERP and TxLED, have or should be included in th e estimates. Tables 2a and 2b should be considered as reasonable estimates rather than exact figures.

Table 2a. Approximate 2018 baseline nonroad mob ile source missions inventory. Summer Weekday Emissions (tons) Aggregate Equipment Category Equipmen t Population NO X VOC CO Agricultural Equipment 5,972 1.85 0.22 2.46 Airport Ground Support Equipment 975 0.39 0.05 0.53 Commercial Equipment 256,241 6.50 10.95 425.19 Construction and Mining Equipment 97,192 19.07 4.34 64.34 Industrial Equipment 39,145 5.87 0.89 21.99 Lawn and Garden Equipment 1,664,135 2.12 17.98 300.42 Logging Equipment 2,154 0.05 0.13 1.75 Pleasure Craft 129,479 1.47 14.91 31.95 Railroad Equipment 126 0.05 0.01 0.04 Recreational Equipment 79,794 0.27 4.55 40.26 Underground Mining Equipment 0 0.00 0.00 0.00 8-County HGB Total General Nonroad 2,275,213 37.64 54.02 888.92 8-County HGB Total Spark-Ignition Nonroad 2,150,612 9.35 50.79 874.80 8-County HGB Total Diesel Nonroad 124,601 26.59 1 3.23 14.12 Locomotive – Line Haul N/A 15.77 0.84 2.49 Locomotive – Switching N/A 22.43 1.51 3.38 Harbor craft N/A 13.40 0.29 3.32
OGV – transit N/A 18.36 0.54 1.88
OGV – dwell N/A 13.69 0.35 2.42
Aircraft N/A 8.85 2.55 29.72
All nonroad mobile sources 128.43 60.1 932.13 1 – 6% lower diesel nonroad NOx emissions than TCEQ provided to approximate the TxLED emission reduction not included in the submittal.



### Table 2b. Approximate 2018 baseline detailed harbor craft emissions inventory (tons per day). Vessel Type NOx VOC CO Assist Tugboats 2.24 0.03 0.6
Ferries 1.17 0.03 0.3
Towboats 8.66 0.19 2.1 Dredges 0.43 0.01 0.1 Dredges 0.93 0.03 0.2
Total 13.40 0.29 3.3G:\HGAC\Reports\Final_051009\Appdx_G_051009\ Control Measure 5b Marine_051009.doc 

### EMISSIONS BENEFIT

Table 3 indicates most recent information on the benefit and cost per project from the TERP program in the HGB area. The most typical project was to replace current equipment that would not necessarily be replaced otherwise. However regardless of the inflation rate, the new engine costs are expect ed to increase because of the new emissions standards, so the current TERP figures may underestimate the cost of future projects. Also, some TERP projects combine two or mo re categories of project types, and the figures here can vary depending upon the size of the engine and other considerations. The figures in Table 3 are approximate and may change as the projects are implemented and reviewed.

Table 3. TERP implemented and pending projects in HGB.

Project Type Total Cost Number of Projects Cost per Project Total NOx Reduced (tpd) NOx Reduction per Project (tpy) Locomotive $75,996,969 116 $655,146 7.29 22.95 Marine $39,216,837 400 $98,042 5.99 5.46 Non-road $81,284,069 1,995 $40,744 7.86 1.44 On-road $103,974,922 1,867 $55,691 10.63 2.08



### The TERP project for marine vessels have fo cused on harbor craft, which include tugs, excursion, and supply vessels because these vess el are more likely to spend most of their time within the area. Nearly all of the pr ojects involve repowering propulsion and/or auxiliary engines with those meeting lower em ission standards. The Tier 3 engines are at the time of this writing just coming in to production for Category 1 (lower engine displacement per cylinder) affording addi tional NOx reductions below the current program benefits. The implementation schedule for Tier 3 Category 2 and Tier 4 Category 1 and 2 engines woul d make it difficult to use these lower emission engines ahead of the 2018 time frame. Some tugs, the pr imary target of the TERP funding to date, use Category 1 and others use Category 2 engines for the primary propulsion power. So the benefits of the projects may be hamp ered by the availability of lower emission Category 2 engine designs.

The marine TERP projects dramatically incr eased starting in 2005. Th e individual project (a replacement engine) resulted in about 5.5 tpy of NOx reduction. The next step in emission standard is the produc tion of Tier 3 engines in 2013 to 2014 timeframe with the very low emission Tier 4 standards not occurring until 2016 – 2017.

It is difficult to determine the remaining marine projects available for retrofit or replacement, but an estimate can be made using the EPA (2008) estimates of age distribution. Based on the median life for Category 1 of 17 years and 23 years for Category 2, the remaining engines of model y ear 2006 or earlier (Tier 1 or older) were estimated to be 36% of the Category 1 and 51% of the Category 2 engines. Based on approximate emission rates of Tier 1 compared to Tier 2 and later e ngines, the fraction ofG:\HGAC\Reports\Final_051009\Appdx_G_051009\ Control Measure 5b Marine_051009.doc 

### NOx emissions from Tier 1 and older m odels would be about 60% of future 2018 emissions, and an engine replacement program therefore (using the 13.4 ton per day NOx from harbor craft) could addre ss at most about 8 tpd of the harbor craft emissions. To the extent that the TERP program has already replaced upwards to 400 engines to date, it may not be clear how many more projects could be affected.

Comparing the Tier 3 with the Tier 1 emissi on rates provides a potential 45% reduction is possible or 4 tons per day of NOx as an uppe r limit. Arbitrarily half of this maximum penetration rate was chosen as a lo wer limit of what could be achieved.

COST AND COST-EFFECTIVENESS

Table 3 indicated the cost and cost effectiven ess of the TERP projects to date and inform the forecast for future projects.

The TERP marine project cost effectiven ess to date ranges from $1,000 to $9,000 per ton of NOx reduced. The average cost effec tiveness of about $2,500 for TERP projects was calculated from the TERP summary table co st of $100,000 and 5.46 tpy NOx benefit per engine replacement and an average project life of 8 years.

SUMMARY OF RESULTS

Expected Emission Reduction Measure # Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effective

-ness ($/ton) 3 Marine vessels Replacement Engine Off-road 0.3 VOC 13.4 NOx 15 - 30% 2 – 4 $2,500



### REFERENCES

EPA. 2008. “Regulatory Impact Analysis: Control of Emissions of Air Pollution from Locomotive Engines and Marine Compression-Ignition Engines Less than 30 Liters per Cylinder,” EPA420-R-08-001, March 2008.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Co ntrol Measure 5b O ffroad_051009.doc 

### Control Measure: #5, Voluntary Retrofit/Replacement Program – Nonroad (and other replacement/retrofit funding, Measures 39 and 40) Category: Nonroad or onroad (see on-road measure #3) Author: Chris Lindhjem, ENVIRON

DESCRIPTION

Voluntary retrofit and replacement programs ha ve been used across the US to reduce emissions using a variety of programs providi ng cofunding incentive to offset the costs incurred.

In Texas, the popular TERP program has been successful providing cofunding for many emission reduction projects of many di fferent types including on-road trucks, construction and off-road equipment, marine vessels, and locomotives. To date, about $300 million of projects have been approve d in the HGB area from 2002 through 2008 with the most of the funding occurring in the 2004 through 2008 period. Because the most recent projects have just been appr oved, not all of the emission reductions have been realized and are still pending

In addition, there are other funding sources for control strategy projects including the EPA grant program run by a local collaborative ( http://www.blueskyways.org/ ). The EPA funding program was relatively limited at $5,000,000 in 2008 ( http://www.blueskyways.or g/pdf/clean-diesel-FY08.pdf ) for the states of Arkansas, Louisiana, New Mexico, Oklahoma, Texas, Iowa, Kansas, Missouri, Nebraska, and Minnesota. Nationally this program wa s funded at $49.2 million in 2008 of which $27.6 million was available for National Clean Diesel Funding Assistance Program. Half of the National Clean Diesel Funding Assistance Progr am is dedicated to public fleets. Other monies were distributed to the States, research, and a revolving loan program.

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

This measure describes the issues and poten tial for construction and offroad engine replacement projects.

IMPLEMENTATION FEASIBILITY

The TERP program has worked well by co-f unding fleet improvements for on-road and off-road vehicles and equipment. TCEQ has developed the organization and principles to administer the program formalizing the appl ication process and providing assistance to owner/operators in implementing the emission re duction projects. The industrial owners of equipment have been ent husiastic participants of th e program, and provide a large portion of the program funds.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Co ntrol Measure 5b O ffroad_051009.doc 

### PUBLIC ACCEPTANCE

The current funding mechanism has been acceptable to nearly all parties, but the cost effectiveness goals may need to be reconsider ed to continue to have the program fully subscribed. The continued funding with the current mechanism will require legislative and executive support.

ANALYSIS

One of the most important methods for emi ssion reduction projects is to replace older vehicles and equipment with those meeting the lower emission standards. The retrofit projects often use technol ogies employed on new engines to meet the lower emission standards. So the basis of this analysis is to compare emission rates from the older with the new vehicles and equipment in order to estimate an emission reduction potential. The TERP program focuses on diesel emissions fr om on-road and off-road vehicles and equipment.

The EPA has been setting emission standards fo r diesel (compression-ignition) engine for some time with the first set of standards shown in Table 1a. In 2004, EPA (2004) set new emission standards for Tier 4 non-road engi nes to be phased in primarily from 2011 through 2015 1 

### as shown in Table 1b. Emission standards for NOx and PM will dramatically reduce emissions in future year s as the fleet turns over to new equipment models. The reduction in particulate and NOx emissions will be more dramatic when the ‘Final’ standards shown in Table 1b occur effectively mandating particulate filters and aftertreatment for NOx that could either be selective catalytic reduction or other NOx reducing catalyst.

Table 1a. Tier 1, 2, and 3 Emission standards for new diesel engines g/kW-hr (g/hp-hr).

Engine Power Tier Model Year NMHC+ NO X CO PM Tier 1 2000 10.5 (7.8) 8.0 (6.0) 1.0 (0.75) Tier 2 2005 7.5 (5.6) 8.0 (6.0) 0.80 (0.60) kW<8 (hp<11) Tier 3 2008 --- --- 0.40 (0.30) Tier 1 2000 9.5 (7.1) 6.6 (4.9) 0.80 (0.60) Tier 2 2005 7.5 (5.6) 6.6 (4.9) 0.80 (0.60) 8 ≤ kW<19 (11 ≤ hp<25) Tier 3 2008 --- --- 0.40 (0.30) Tier 1 1999 9.5 (7.1) 5.5 (4.1) 0.80 (0.60) 19 ≤ kW<37 (25 ≤ hp<50) Tier 2 2004 7.5 (5.6) 5.5 (4.1) 0.60 (0.45)

Tier 1 1998 9.25 (6.9) NO X 1.3 (1.0) HC None None (smoke) Tier 2 2004 7.5 (5.6) 5.0 (3.7) 37 ≤ kW<75 (50 ≤ hp<100) Tier 3 2008 4.7 (3.5) 5.0 (3.7) 0.40 (0.30)

1 EPA Tier 4 Emission Standards for Non-road Diesel Engines: http://www.epa.gov/nonroaddiesel/2004fr.htmG:\HGAC\Reports\Final_051009\Appdx_G_051009\Co ntrol Measure 5b O ffroad_051009.doc Engine Power Tier Model Year NMHC+ NO X CO PM

Tier 1 1997 9.25 (6.9) NO X 1.3 (1.0) HC None None (smoke) Tier 2 2003 6.6 (4.9) 5.0 (3.7) 75 ≤ kW<130 (100 ≤ hp<175) Tier 3 2007 4.0 (3.0) 5.0 (3.7) 0.30 (0.22)

Tier 1 1996 9.25 (6.9) NO X 1.3 (1.0) HC 8.5 0.54 (0.4) Tier 2 2003 6.6 (4.9) 3.5 (2.6) 130 ≤ kW<225 (175 ≤ hp<300)
Tier 3 2006 4.0 (3.0) 3.5 (2.6) 0.20 (0.15)

Tier 1 1996 9.25 (6.9) NO X 1.3 (1.0) HC 8.5 0.54 (0.4) Tier 2 2001 6.4 (4.8) 3.5 (2.6) 225 ≤ kW<450 (300 ≤ hp<600) Tier 3 2006 4.0 (3.0) 3.5 (2.6) 0.20 (0.15)

Tier 1 1996 9.25 (6.9) NO X 1.3 (1.0) HC 8.5 0.54 (0.4) Tier 2 2002 6.4 (4.8) 3.5 (2.6) 450 ≤ kW ≤ 560 (600 ≤ hp ≤ 750) Tier 3 2006 4.0 (3.0) 3.5 (2.6) 0.20 (0.15)

Tier 1 2000 9.25 (6.9) NO X 1.3 (1.0) HC 8.5 0.54 (0.4) KW>560 (hp>750) Tier 2 2006 6.4 (4.8) 3.5 (2.6) 0.20 (0.15)



### Table 1b. Federal Tier 4 new engine emission standards for diesel offroad engines.

1 Manufacturers have the option of comply ing with the Tier 4 standards over a two year period at 50% per year using banked Tier 2 credits or over a three year period at 25% pe r year without the use of Tier 2 credits. The three year phase-in period is shown. The 2014 model year cannot extend beyond December 30, 2014, when the 3 year phase-in option is used.

2 Manufacturers may comply with the standards during the transitional implementation years using either a phase-in / phase-out approach or by using the Alternate NOx approach . The three year 25% alternate NOx standard is shown in the table. The two year 50% phase-in NOx standard would be 2.3 g/kW-hr.

3 Engine families in this power category may alternately meet Tier 3 PM standards from 2008-2011 in exchange for introducing final PM standards in 2012.

Engine

HP Tier 4 Standard Model Year PM (g/kW-hr) NMHC+NOx (g/kW-hr) NMHC (g/kw-hr) NOx (g/kw-hr) CO (g/kw-hr)
Interim 2008 0.30 7.5 25-50 3 Final 2013 0.03 4.7 5.5

Interim 2008 0.30 50-75 Final 2013 0.03 4.7 5.0

Phase-in 0.19 0.40 Phase-out 4.7 Or/ alt NOx 2012-2014 1

3.4 2 75-100

Final 2015 0.02 0.19 0.40 5.0

Phase-in 0.19 0.40 Phase-out 4.0 Or/ alt NOx 2012-2014 1

3.4 2 100-175

Final 2015 0.02 0.19 0.40 5.0

Phase-in 0.19 0.40 Phase-out 4.0 Or/ alt NOx 2011 2.0 175-750

Final 2014 0.02 0.19 0.40 3.5

Interim 2011 0.1 0.40 >750 Final 2015 0.04 0.19 3.5 3.5G:\HGAC\Reports\Final_051009\Appdx_G_051009\Co ntrol Measure 5b O ffroad_051009.doc 

### EMISSIONS AFFECTED

Table 2 shows the approximate summary emissions for nonroad equipment emissions for 2018. The actual emissions may vary from da y to day (such as weekday and weekend day) and depend upon whether the implementati on of control strategies, such as TERP and TxLED, have or should be included in th e estimates. Table 2 should be considered as reasonable estimates rather than exact figures.

Table 2. Approximate 2018 baseline nonroad mobile source missions inventory. Summer Weekday Emissions (tons) Aggregate Equipment Category Equipmen t Population NO X VOC CO Agricultural Equipment 5,972 1.85 0.22 2.46 Airport Ground Support Equipment 975 0.39 0.05 0.53 Commercial Equipment 256,241 6.50 10.95 425.19 Construction and Mining Equipment 97,192 19.07 4.34 64.34 Industrial Equipment 39,145 5.87 0.89 21.99 Lawn and Garden Equipment 1,664,135 2.12 17.98 300.42 Logging Equipment 2,154 0.05 0.13 1.75 Pleasure Craft 129,479 1.47 14.91 31.95 Railroad Equipment 126 0.05 0.01 0.04 Recreational Equipment 79,794 0.27 4.55 40.26 Underground Mining Equipment 0 0.00 0.00 0.00 8-County HGB Total General Nonroad 2,275,213 37.64 54.02 888.92 8-County HGB Total Spark-Ignition Nonroad 2,150,612 9.35 50.79 874.80 8-County HGB Total Diesel Nonroad 124,601 26.59 1 3.23 14.12 Locomotive – Line Haul N/A 15.77 0.84 2.49 Locomotive – Switching N/A 22.43 1.51 3.38 Harbor craft N/A 13.40 0.29 3.32
OGV – transit N/A 18.36 0.54 1.88
OGV – dwell N/A 13.69 0.35 2.42
Aircraft N/A 8.85 2.55 29.72
All nonroad mobile sources 128.43 60.1 932.13 1 – 6% lower diesel nonroad NOx emissions than TCEQ provided to approximate the TxLED emission reduction not included in the submittal.



### EMISSIONS BENEFIT

On-road benefits have been described in on -road control strategy m easure number 3 that include TERP and congestion mitigation and air quality or other funding programs for on-road vehicles. Therefore this control strategy description fo cuses on the off-road

measures.

Table 3 indicates most recent information on the benefit and cost per project from the TERP program in the HGB area. The most typical project was to replace current equipment that would not necessarily be replaced otherwise. However regardless of theG:\HGAC\Reports\Final_051009\Appdx_G_051009\Co ntrol Measure 5b O ffroad_051009.doc 

### inflation rate, the new engine costs are expect ed to increase because of the new emissions standards, so the current TERP figures may underestimate the cost of future projects. Also, some TERP projects combine two or mo re categories of project types, and the figures here can vary depending upon the size of the engine and other considerations. The figures in Table 3 are approximate and may change as the projects are implemented and reviewed.

Table 3. TERP implemented and pending projects in HGB.

Project Type Total Cost Number of Projects Cost per Project Total NOx Reduced (tpd) NOx Reduction per Project (tpy) Locomotive $75,996,969 116 $655,146 7.29 22.95 Marine $39,216,837 400 $98,042 5.99 5.46 Non-road $81,284,069 1,995 $40,744 7.86 1.44 On-road $103,974,922 1,867 $55,691 10.63 2.08



### The TERP program has gained more emissi on reductions from construction and other smaller nonroad engine projects than mari ne or locomotive source categories. The projects include primarily construction equipment of various types, forklifts, and other types.

The average project benefit has been about 1.5 tpy of NOx reduction per project mostly representing Tier 2 and 3 engine replacements of in-use equipment. The next set of emission standards for Tier 4 engines are to be fully implemented by 2015. Until then the current TERP program projects using Tier 3 engines, which likely represents the predominant project types for the foreseeable fu ture until the Tier 4 engines are produced.

As with other off-road meas ures, it is difficult to determ ine how many more projects can occur and how much emission reduction can be attained. By 2018, the precontrolled (typically 1995 and earlier model year) and Tier 0 (1996 to the Tier 1 implementation date) engines will largely have been retire d from operation, leaving the replacement of Tier 1 engines as the primary target of a replacement program. This can reduce the per project benefit by to as little as one-third th e benefit of replacing a precontrolled engine.

COST AND COST-EFFECTIVENESS

Table 3 indicated the cost and cost effectiven ess of the TERP projects to date and inform the forecast for future projects.

The TERP projects had a project life of 5 or 7 years with the $41,000 per project price and 1.44 tpy NOx reduction resulted in a cost effectiveness of about $5,000 per ton per project on average. However, if the benefits of each project were reduced to one third (replacing Tier 1 with Tier 3 instead of precont rolled with Tier 3 engines), then the cost effectiveness could be 3 times higher.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Co ntrol Measure 5b O ffroad_051009.doc 

### SUMMARY OF RESULTS

Expected Emission Reduction Measure # Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effective

-ness ($/ton) 3 Nonroad Equipment Replacement or Retrofit Engine Off-road 3.2 VOC 26.6 NOx 10% 2.5 $5,000 – $15,000



### REFERENCES

EPA. 2008. “Regulatory Impact Analysis: Control of Emissions of Air Pollution from Locomotive Engines and Marine Compression-Ignition Engines Less than 30 Liters per Cylinder,” EPA420-R-08-001, March 2008.

EPA. 2004. “Clean Air Nonroad Diesel - Tier 4 Final Rule,” United States Environmental Protection Agency, http://www.epa.gov/nonroaddiesel/2004fr.htm

.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control M easure 8 Construction incentives_051009.doc 

### Control Measure: #8, Construction Contracting Incentives Category: Nonroad Author: Chris Lindhjem, ENVIRON

DESCRIPTION

An incentive program or a requirement for publicly-funded (including just captive state, county, and municipal fleets of off-road equi pment) or all constr uction projects could effect emission reductions by encouraging fleet turnover to those m eeting lower emission standards. A TxDOT plan provides an exam ple of an incentive program. Alternatively, many other states and localities have suggest ed or implemented emission standard (by model year) requirements for construction contracts. (EPA, 2008, http://www.epa.gov/diesel/construction/contract-lang.htm ) While some areas target NOx control and others PM control, the incentiv es or requirements for new equipment based would control both pollutants.

IMPLEMENTATION FEASIBILITY

Based on a review of the contracting clause s to date, there are two basic methods, a voluntary or incentive approach and a fixe d requirement for clean equipment. The incentive approach raises the cost to the State or local government contracts by offering an incentive, and the requirement raises the cost on the construction firm to maintain a clean fleet that would likely be pass ed on to the cost of the project.

PUBLIC ACCEPTANCE

The general public is unlikely to be affected by this strate gy. The cost of incentives would need to be considered carefully becau se the contracting costs could increase and greater than expected by restricti ng how many contract ors could qualify.

ANALYSIS

TxDOT (2004) issued a contracting incentive to enc ourage the use of advanced emission controlled engines in equipmen t used for road constructi on projects. Th e incentive was described as shown in Table 1 with Table 2a describing the model y ear of equipment for each Tier. The incentive provided by TxDOT could be realized without a special purchase of new equipment or engines.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control M easure 8 Construction incentives_051009.doc 

### Table 1. TxDOT clean engine incentive and calculated benefit.

Engine Tier Monthly Incentive ($/hp)
Tier 1 0.50 Tier 2 0.75 Tier 3 1.0



### Table 2a. Emission standards for new compression-ignition engines in g/kW-hr (g/hp-hr). 

### Engine Power Tier Model Year NMHC+ NO X 

### CO PM Tier 1 2000 10.5 (7.8) 8.0 (6.0) 1.0 (0.75) Tier 2 2005 7.5 (5.6) 8.0 (6.0) 0.80 (0.60) KW<8 (hp<11) Tier 3 2008 --- --- 0.40 (0.30) Tier 1 2000 9.5 (7.1) 6.6 (4.9) 0.80 (0.60) Tier 2 2005 7.5 (5.6) 6.6 (4.9) 0.80 (0.60) 8 ≤ kW<19 (11 ≤ hp<25) Tier 3 2008 --- --- 0.40 (0.30) Tier 1 1999 9.5 (7.1) 5.5 (4.1) 0.80 (0.60) Tier 2 2004 7.5 (5.6) 5.5 (4.1) 0.60 (0.45) 19 ≤ kW<37 (25 ≤ hp<50) Tier 3 2013 4.7 (3.5) --- 0.03 (0.02)

Tier 1 1998 9.25 (6.9) NO X 1.3 (1.0) HC None None (smoke) Tier 2 2004 7.5 (5.6) 5.0 (3.7) 37 ≤ kW<75 (50 ≤ hp<100) Tier 3 2008 4.7 (3.5) 5.0 (3.7) 0.40 (0.30)

Tier 1 1997 9.25 (6.9) NO X 1.3 (1.0) HC None none (smoke) Tier 2 2003 6.6 (4.9) 5.0 (3.7) 75 ≤ kW<130 (100 ≤ hp<175) Tier 3 2007 4.0 (3.0) 5.0 (3.7) 0.30 (0.22)

Tier 1 1996 9.25 (6.9) NO X 1.3 (1.0) HC 8.5 0.54 (0.4)
Tier 2 2003 6.6 (4.9) 3.5 (2.6) 130 ≤ kW<225 (175 ≤ hp<300) Tier 3 2006 4.0 (3.0) 3.5 (2.6) 0.20 (0.15)

Tier 1 1996 9.25 (6.9) NO X 1.3 (1.0) HC 8.5 0.54 (0.4)
Tier 2 2001 6.4 (4.8) 3.5 (2.6) 225 ≤ kW<450 (300 ≤ hp<600) Tier 3 2006 4.0 (3.0) 3.5 (2.6) 0.20 (0.15)

Tier 1 1996 9.25 (6.9) NO X 1.3 (1.0) HC 8.5 0.54 (0.4)
Tier 2 2002 6.4 (4.8) 3.5 (2.6) 450 ≤ kW ≤ 560 (600 ≤ hp ≤ 750) Tier 3 2006 4.0 (3.0) 3.5 (2.6) 0.20 (0.15)

Tier 1 2000 9.25 (6.9) NO X 1.3 (1.0) HC 8.5 0.54 (0.4) kW>560 (hp>750) Tier 2 2006 6.4 (4.8) 3.5 (2.6) 0.20 (0.15)



### The TxDOT measure becomes dated as the fleet turnover and the Tier 4 emission standards begin to take effect as shown in Table 2b. The incentive might not affect any emission reduction compared to normal turnover of equipment as it is replaced. The incentive of Tier 4 engines is required to demonstrate significant emission reduction compared to the average fleet age distributi on in 2018. By 2018, half of the equipment in use could meet Tier 4 final standards under normal turnover.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control M easure 8 Construction incentives_051009.doc Table 2b. Federal and State Tier 4 new engine emission standards for diesel offroad engines.

1 Manufacturers have the option of comply ing with the Tier 4 standards over a two year period at 50% per year using banked Tier 2 credits or over a three year period at 25% pe r year without the use of Tier 2 credits. The three year phase-in period is shown. The 2014 model year cannot extend beyond December 30, 2014, when the 3 year phase-in option is used.

2 Manufacturers may comply with the standards during the transitional implementation years using either a phase-in / phase-out approach or by using the Alternate NOx approach . The three year 25% alternate NOx standard is shown in the table. The two year 50% phase-in NOx standard would be 2.3 g/kW-hr.

3 Engine families in this power category may alternately meet Tier 3 PM standards from 2008-2011 in exchange for introducing final PM standards in 2012.



### The Northeast Clean Diesel Collaborative (N EDC) (EPA, 2008) suggested an alternative approach where in the most straightforward approach mandates that Tier 4 equipment be used. Replacing older equipment with Tier 4 equipment wo uld reduce emissions significantly even though th e older equipment may repr esent the minority of the equipment.

EMISSIONS AFFECTED

TCEQ estimated construction equipment em issions by construction category based on local survey data collected as shown in Tabl e 3. This permits the investigation of what fraction of the construction activity that public funding can affect.

Engine

HP Tier 4 Standard Model Year PM (g/kW-hr) NMHC+NOx (g/kW-hr) NMHC(g/kwhr) NOx(g/kwhr) CO(g/kwhr)
Interim 2008 0.30 7.5 25-50 3 Final 2013 0.03 4.7 5.5

Interim 2008 0.30 50-75 Final 2013 0.03 4.7 5.0

Phase-in 0.19 0.40 Phase-out 4.7 Or/ alt NOx 2012-2014 1

3.4 2 75-100

Final 2015 0.02 0.19 0.40 5.0

Phase-in 0.19 0.40 Phase-out 4.0 Or/ alt NOx 2012-2014 1

3.4 2 100-175

Final 2015 0.02 0.19 0.40 5.0

Phase-in 0.19 0.40 Phase-out 4.0 Or/ alt NOx 2011 2.0 175-750

Final 2014 0.02 0.19 0.40 3.5

Interim 2011 0.1 0.40 >750 Final 2015 0.04 0.19 3.5 3.5G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control M easure 8 Construction incentives_051009.doc 

### Table 3. Construction equipment emission esti mates before TxLED NOx reduction of about 6% applied for 2018. Non-Road Equipment Subsector Summer Weekday Emissions (tons) Diesel Construction Equipment (DCE) & Non-DCE Equipment Population VOC CO NO X DCE - Agricultural Activities 817 0.01 0.05 0.14 DCE - Boring & Drilling Eq uipment 20,431 0.22 1.02 2.42 DCE - Brick & Stone Operations 91 0.01 0.03 0.05 DCE - City & County Road Construction 311 0.01 0.04 0.10 DCE - Commercial Construction 5,625 0.26 1.05 2.32 DCE - Concrete Operations 1,318 0.04 0.23 0.35 DCE - County-Owned Construction Equipment 2,301 0.13 0.49 1.18 DCE - Cranes 101 0.00 0.02 0.03 DCE - Heavy Highway Construction 191 0.00 0.02 0.04 DCE - Landfill Operations 3,162 0.05 0.24 0.61 DCE - Landscaping Activities 79 0.01 0.02 0.05 DCE - Manufacturing Operat ions 5,381 0.14 0.63 1.20 DCE - Municipal-Owned Construction Equipment 149 0.03 0.04 0.11 DCE - Transportation/Sales/ Services 1,375 0.05 0.26 0.33 DCE - Residential Construction 2,320 0.16 0.64 1.15 DCE - Rough Terrain Forklifts 744 0.04 0.17 0.29 DCE - Scrap/Recycling Oper ations 6,387 0.16 0.87 2.20 DCE - Skid Steer Loaders 346 0.01 0.05 0.17 DCE - Special Trades Construction 75 0.01 0.02 0.05 DCE – Trenchers 175 0.01 0.04 0.09 DCE - TxDOT Construction Equipment 187 0.02 0.03 0.10 DCE - Utility Construction 3,428 0.29 0.57 2.25 DCE - Mining & Quarry Operation 4,024 0.13 0.79 1.18 DCE – Off-Road Tractors, Miscellaneous Equipment, & All Equipment Under 25 Horsepower 12,869 0.45 2.59 2.34 Diesel Subtotal 71,886 2.27 9.90 18.74 Diesel Public and Publicly-Funded 3,139 0.20 0.63 1.52 Gasoline and Spark-Ignition Construction Equipment 25,306 2.07 54.44 0.33 Total Construction 97,192 4.34 64.34 19.07



### EMISSIONS BENEFIT

The emission benefit for public and publicly funded contracts is limited (assuming City & County, County-Owned, Heavy-Highway, M unicipal-Owned, and TxDOT equipment are included) to 1.4 tpd (with TxLED benefit applied) of NOx emissions. A significantly larger emission reduction could be affected if more construction categories could be included.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control M easure 8 Construction incentives_051009.doc 

### The maximum benefit that could be attain ed is if, by 2018, all equipment used in construction meets Tier 4 st andards. As an example, dozer emissions in 2018 using normal turnover were compared with the dozer emissions if all equipment rapidly turned over to Tier 4 equipment. This example re sulted in an expected emission reduction of 17% for VOC and 66% for NOx despite the fact that pre-Tier 4 equipm ent is expected to represent less than 50% of equipment by 2018.

COST-EFFECTIVENESS

EPA (2004) estimated that the cost effectiv eness of Tier 4 nonroad engines would be about $1,000 per ton of NOx and VOC combined. This approach assumes that fleet owners would plan their fleet purchases so that a forced re placement would not occur and the initiative would merely affect the relativ e purchase price of new equipment. This would be considered a low cost scenario.

As an alternative high cost estimate, one coul d consider the cost of replacing a Tier 3 engine with a Tier 4 engine. For an exampl e, based on the TERP results (outlined in Measure 5), the cost of replacement projec ts for nonroad engines has been averaging $40,744 with an average life of 7 years. The em ission reduction of a Tier 4 dozer instead of a Tier 3 results in about 0.01 tpy VOC and 0.33 NOx resulting an average cost effectiveness of about $19,000 per ton benefit using the TERP 3% rate of return.

SUMMARY OF RESULTS

Expected Emission Reduction Measure # Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effectiveness ($/ton) 8 Emission Reduction Contract Incentives with or without Public Funding Encourage lower emitting engines Nonroad Construction – Public Funded Projects 1.4 – 18 0 – 60% 1 or

more $1,000 - $19,000G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control M easure 8 Construction incentives_051009.doc 

### REFERENCES

EPA (2008), Summaries of clean contracting incentives, http://www.epa.gov/diesel/construction/contract-lang.htm

EPA (2004), Final Regulatory Analysis: Cont rol of Emissions from Nonroad Diesel Engines,” Office of Transportation and Air Quality, EPA420-R-04-007, May 2004.

TxDOT (2004), Special Specification 5018, “I ncentive for Using Non-Road Diesel Equipment Powered by EPA Tier 1, 2 or 3 Diesel Engines in Nonattainment and Affected Counties,” December 7, 2004.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control meas ure 21 Lawn and Garden Exchange_051009.doc 

### Control Measure: #21, 22, 23, 24 Lawn & Garden Exchange and Rebate Program Category: Off-road Author: Chris Lindhjem , ENVIRON

DESCRIPTION

Nonroad measures 21 through 24 address progra ms designed to promote the use of clean lawn and garden equipment. The primary benefit of these programs will be to reduce VOC and CO emissions.

There are at least two examples of a repl acement/purchase program to replace gasoline equipment with electric versions including several in California ( http://www.aqmd.gov/tao/lawnmower.html

, http://airquality.org/mobile/m owdown/mowdowngeneral.shtml ) and the Central Texas program ( http://www.cleanairforce. org/2008MowingFlyer.pdf ). These programs have worked out many of the issu es related to transfer of ownership and determining appropriate incentives.

IMPLEMENTATION FEASIBILITY

In order to change behavior, it might be he lpful to provide a reba te or incentive for choosing clean equipment. It is important to design the rebate program to maximize the use of the clean equipment and not merely lower costs to consum ers who were already considering clean equipment or replacing engine s that already exceed their useful life. But by subsidizing the cost of an electric version and scrapping a working gasoline version, it would discourage the owner from also purchasing anothe r gasoline version.

PUBLIC ACCEPTANCE

The programs outlined here appear to be successful and fully subscribed based on this year’s results.

ANALYSIS

To understand the impact of clean engines with the best example bei ng electric lawn and garden equipment, residential leaf blowers and lawn mowers gasoline were used as the example equipment replaced. In 2018, the fleet of leaf blowers and lawn mowers will produce emissions as shown in Tables 1 a nd 2 from a default NONROAD model run for HGB. Most leaf blowers are modeled such that they do not last longer than 5 years, and lawn mowers 6 years on average in residen tial use. Most lawn and garden programs focus on lawn mowers, but Table 1 shows that the lifetime emissions fr om leaf blowers isG:\HGAC\Reports\Final_051009\Appdx_G_051009\Control meas ure 21 Lawn and Garden Exchange_051009.doc 

### about half that of lawnmowers in Table 2, and so with a prop ortional incentive be candidates for replacement programs.

Table 1. Residential leaf blowers (1 – 3 hp) emissions (grams/year).

Model Year Area Population VOC CO NOx 2009 0 1,148 1,251 17 2010 699 1,148 1,251 17 2011 2,134 1,148 1,251 17 2012 3,907 1,148 1,251 17 2013 6,767 1,148 1,251 17 2014 21,230 1,148 1,251 17 2015 25,524 1,135 1,234 17 2016 28,092 1,088 1,178 17 2017 30,100 1,040 1,121 17 2018 31,836 989 1,065 17 Avg. Lifetime 5,095 5,518 81



### Table 2. Residential lawn mowers (3 – 6 hp) emissions (grams/year).

Model Year Area Population VOC CO NOx 2007 2,101 2,008 1,646 10 2008 5,884 1,580 16,973 56 2009 10,340 1,580 16,973 56 2010 15,497 1,580 16,973 56 2011 23,093 1,580 16,973 56 2012 38,925 1,580 16,973 56 2013 88,492 1,580 16,973 56 2014 99,402 1,562 16,347 56 2015 107,595 1,536 15,495 56 2016 114,110 1,507 14,528 56 2017 120,234 1,473 13,381 56 2018 125,834 1,428 11,885 56 Avg. Lifetime 9,071 88,615 333



### EMISSIONS AFFECTED

Table 2 shows the approximate summary emissions for nonroad equipment for 2018. The actual emissions may vary from day to day (such as weekday and weekend day) and depend upon whether the implementation of c ontrol strategies, such as TERP and TxLED, have or should be included in the estimates because TERP projects to date may exceed their project life by 2018. Table 2 should be considered as reasonable estimates rather than exact figures.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control meas ure 21 Lawn and Garden Exchange_051009.doc 

### Table 2. Approximate 2018 baseline nonroad mobile source missions inventory. Summer Weekday Emissions (tons) Aggregate Equipment Category Equipmen t Population NO X VOC CO Agricultural Equipment 5,972 1.85 0.22 2.46 Airport Ground Support Equipment 975 0.39 0.05 0.53 Commercial Equipment 256,241 6.50 10.95 425.19 Construction and Mining Equipment 97,192 19.07 4.34 64.34 Industrial Equipment 39,145 5.87 0.89 21.99 Lawn and Garden Equipment 1,664,135 2.12 17.98 300.42 Logging Equipment 2,154 0.05 0.13 1.75 Pleasure Craft 129,479 1.47 14.91 31.95 Railroad Equipment 126 0.05 0.01 0.04 Recreational Equipment 79,794 0.27 4.55 40.26 Underground Mining Equipment 0 0.00 0.00 0.00 8-County HGB Total General Nonroad 2,275,213 37.64 54.02 888.92 8-County HGB Total Spark-Ignition Nonroad 2,150,612 9.35 50.79 874.80 8-County HGB Total Diesel Nonroad 124,601 26.59 1 3.23 14.12 1 – 6% lower diesel nonroad NOx emissions than TCEQ provided to approximate the TxLED emission reduction not included in the submittal.



### EMISSIONS BENEFIT

Table 1 and 2 provides the lifetime average em ission rates for the example equipment due to be replaced by electric versions. Replac ing 6000 lawnmowers with electric versions results in 0.037 tpd VOC benefit.

COST AND COST-EFFECTIVENESS

Most programs provide an incentive of $100 to $165 per lawn mower replaced. Using the 6-year average life and be nefit, the annualized cost effectiveness for VOC and NOx (but most of the benefit is in terms of VOC), ranges from $11,000 to $18,000 per ton of emissions reduced.

Replacing 6000 lawnmowers would cost about $600,000 ($100,000 a year starting in 2013) to $1 million.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control meas ure 21 Lawn and Garden Exchange_051009.doc 

### SUMMARY OF RESULTS

Expected Emission Reduction Measure ID Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effectiveness ($/ton)

21 Off-road Idle Small Engine Replacement Replacement or Clean Engine Purchase Off-road engines

Lawn and Garden 18.0 VOC 2.1 NOx 0.2 0.04 $11,000 - $18,000G:\HGAC\Reports\Final_051009\Appdx_G_ 051009\Control Measure 33 Locomotiv e Freight Efficiency_051009.doc 

### Control Measure: #33, Rail Efficiency Category: Nonroad Author: Chris Lindhjem, ENVIRON

DESCRIPTION

This strategy suggests projects that might improve rail effi ciency requiri ng less activity from line-haul locomotives. Some measures to effect this improvement could be public/private partnerships while others might be implemented by the railroads.

Railroads have been improving their effi ciency through technology and operational measures. The technologies include wheel and rail lubrication, better bearings, more efficient engines, perhaps other technologies yet to be identified. The operation changes include idle reduction, improved aerodynamics, longer trains, and improved training and evaluation of engineers to reduce braki ng, idling, and other inefficient operations.

IMPLEMENTATION FEASIBILITY

Efficiency measures need to be defined in more detail in order to determine the improvement in emissions. The additional be nefits (reduce fuel consumption, safety, or others) beyond air quality benefits would accoun t for some of the cost of the measures, and the level of investment by public or pr ivate entities would n eed to be negotiated.

PUBLIC ACCEPTANCE

If public funds are used to improve the rail network, there may be competing interests that will require officials to prioritize projects. However, benefits of freight efficiency improvements can be widespread.

ANALYSIS

This measure was assumed to primarily affect the mainline rail operations and therefore the line-haul locomotives.

EMISSIONS AFFECTED

Improving the rail network or the tec hnology or operation of moving freight will primarily affect the line-haul locomotive emissions. Voluntary retrofit/replacement programs as described in offroad measure #5 can address yard-switching engines. Linehaul locomotives therefore represent a unique source moving the bulk of the rail freightG:\HGAC\Reports\Final_051009\Appdx_G_ 051009\Control Measure 33 Locomotiv e Freight Efficiency_051009.doc 

### on the main rail lines. TCEQ estimated emissions from these locomotives as 0.8 tpd VOC and 15.8 tpd NOx in the HGB in 2018.

EMISSIONS BENEFIT

The rail efficiency in terms of freight moved per gallon of fuel consumed is a measure of how improvements in operations can improve emissions. The major railroads operating in the Houston area have been improving their efficiency in the range of 1% to 2% per year over the past 5 years as shown in Fi gure 1. The reasons for these efficiencies probably lie in both technology and operational changes.

Figure 1. Rail efficiency historical trends



### The focus of this strategy is to see what sort of improvements need to be made to continue improve efficiencies. The changes could include rail network improvements to avoid congestion (such as double-tracking wher e locomotives would otherwise need to brake and idle while awaiting ot her trains), free flow operations to avoid closing local roadways (such as through grade separation pr ojects), regrading or straightening routes (to reduce mileage and fuel cons umption), or other projects.

The types of projects that would improve ra il efficiency would be specific to the route and current or forecast activity conditions. Al so, some projects may have other benefits 300 320 340 360 380 400 420 440 460 480 500

2001 2002 2003 2004 2005 2006 2007 2008

YearLine-Haul Revenue Freight Efficiency (ton-mile/gallon)

BNSF

KCS

UPG:\HGAC\Reports\Final_051009\Appdx_G_ 051009\Control Measure 33 Locomotiv e Freight Efficiency_051009.doc 

### than air quality including safety, such as for grade separation, and reduced road congestion by removing traffic that w ould otherwise be handled by trucks.

COST AND COST-EFFECTIVENESS

The cost and cost effectiveness of rail improvement projects will be unique to each project. The project proponents would include the rail operators (railroads), and local, state, and federal transporta tion planners each of whom may provide funding and see benefits beyond air quality. Therefore the level of cofunding will be negotiated on a project-by-project basis. Als o, it will not be possible to segr egate the air quality benefit from other benefits of each project. Theref ore, it is not possible to estimate the cost and cost effectiveness of these measures.

SUMMARY OF RESULTS

Expected Emission Reduction Measure # Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effectiveness ($/ton)

33 Rail Efficiency Improved rail network and grade separation Line-haul Locomoti

ves 0.8 VOC 15.8 NOx 5 – 10 0.8 – 1.6 tpd

NOx N/A



### REFERENCE

AAR (2008), “Analysis of Class I Railroads,” http://pubs.aar.org/pubstores /displayitem.aspx?id=13G:\HGAC\Reports\Final_051009\Appdx_G_051009\Co ntrol Measure 45 Clean Port_051009.doc 

### Control Measure: #36, 45 Clean Port Initiative Category: Nonroad Author: Chris Lindhjem, ENVIRON

DESCRIPTION

This measure seeks to adopt a plan that e ffects emission reductions from HGB area ports and private terminals. The plan could cover several or all emissions sources associated with marine activity include water and shor eside activities as outlined by EPA’s Clean Ports USA ( http://www.epa.gov/otaq/diesel/ports/index.htm ). But the focus in this description is the larger ocean-going vessel strategies because smaller commercial marine and shoreside (nonroad, locomotive, and truc king) port initiative s are described in nonroad measure 5.

A program might use California ports plans as a model of what might be accomplished. The most widely sample plan is that for the Ports of Long Beach and Los Angeles who have adopted the San Pedro Bay Ports Clean Air Action Plan (CAAP), a plan aimed at significantly reducing the heal th risks posed by air pollution from port-related ships, trains, trucks, terminal equipment and harbor craft. ( http://www.cleanairacti onplan.org/about/default.asp ) The primary purpose of this California plan is the reduc tion particulate matter emissions where the primary purpose of the HGB plan might be VOC and NO x reduction for ozone attainment.

The plan described here will focus on the larger ocean-going vessels (OGV) because initiatives for other port sources revolve around the volunt ary retrofit/replacement programs described in this report under measure 5.

IMPLEMENTATION FEASIBILITY

There are several complexities in impl ementing measures related to OGV control techniques including that most OGV are foreign flagged creating potential legal obstacles, interport competition (higher fees may be a competitive disadvantage), and other concerns with operating a port under unique costs or operating restrictions. The administration of program would fall to the po rts or the state, and the methods used to enforce the program still needs to be defined.

PUBLIC ACCEPTANCE

While the general public may encourage emi ssions improvement from ships, the costs incurred and effects to business may be less well known.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Co ntrol Measure 45 Clean Port_051009.doc 

### ANALYSIS

There are several approaches suggested in the CAAP that include and are more aggressive than the California state regulat ions. One focus of the CAAP is the large ocean-going vessels with several measures outlined here.

• Large Ocean-Going Vessels (OGV)

o OGV Vessel Speed Reduction (VSR)

o Reduction of At-Berth OGV Emissions

o OGV Auxiliary Engine & Main Engine Fuel Standards

o OGV Main and Auxiliary Engine Emissions Improvements

The CAAP also addresses other emission sour ces that have been addressed in other measures, especially nonroad measure 5 eval uated in this report. The cargo handling equipment (CHE) would fall under the categor y of all nonroad engi nes though to date it mostly applies to forklifts, construction, and other similar equipment.

• Clean truck program

• Performance Standards for cargo handling equipment (CHE)

• Performance Standards for Harbor Craft

• Locomotive Initiatives (low emitti ng locomotives, idle reduction)

At issue is the potential implementation of international emission standards and national initiatives associated with marine vessels affecting the larger deep-draft ocean-going vessels. The international standards descri bed below include provisions for low sulfur fuel and engine emission controls worldw ide with additional c ontrols near regions defined by nations as sensitive to OGV pollu tion. The United States championed by EPA is applying to define the US as a sensitive region requiring such emissions controls.

Based on proposals to ‘Interna tional Convention for the Pr evention of Pollution from Ships (MARPOL) Annex VI’ this year, a prog ressive reduction in sulphur oxide (SOx) emissions from ships is proposed with the global sulphur cap reduced initially to 3.5% (from the current 4.5%) effec tive from 1 January 2012; then progressively to 0.5 %, effective from 1 January 2020, subject to a f easibility review to be completed no later than 2018. ( http://www.imo.org/environment/ma inframe.asp?topic_id=233#annexvi ). In addition, the sulphur dioxide emission contro l area (SECA) sulfur levels would be lowered from 1.5% currently to levels compar able to the CARB regulations starting with 0.5% sulfur in 2010 and 0.1% in 2015, or a few years later than the CARB regulations.

The initial MARPOL Annex VI engine sta ndards resulted in a minimal NOx reduction compared to the baseline emission factors a nd had no effect on PM. However, the Marine Environment Protection Committ ee (MEPC) of the International Maritime Organization (IMO) has agreed to proposed amendments to the MARPOL Annex VI regulations to reduce NOx emissions from engines be ginning in 2011 with a 14.4 g/kW-hr and 3.4 g/kW-hr in an Emission Control Area (ECA ) in 2016 compared with 17 g/kW-hr starting with vessels built in 2000.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Co ntrol Measure 45 Clean Port_051009.doc 

### EMISSIONS AFFECTED

The emissions inventory for marine vessels is shown in Table 1.

Table 1. Approximate 2018 baseline marine vessel missions inventory Summer Weekday Emissions (tons) Aggregate Equipment Category NO X VOC CO Harbor craft 13.40 0.29 3.32
OGV – transit 18.36 0.54 1.88
OGV – dwell 13.69 0.35 2.42



### EMISSIONS BENEFIT

Vessel Speed Reduction

Vessel speed reduction effects emission reducti ons by slowing vessels down substantially lowering the engine load. Unless the engine is at very low loads, the emissions per mile is a function of the vessel speed squared, so slowing the vessel speeds by 30% will reduce emission by half.

Vessel speed reduction may be more effective near Los Angeles where vessels pass close to shore for a significant porti on of their travel in the area. As shown in Figure 1, most traffic to Galveston Bay (the darkening of the route indicates more traffic) proceeds directly in and out to the Gulf. Within the Galveston Bay, vessels speeds are already low, therefore the vessel speed reduc tion would affect emissions we ll out in the Gulf and may not affect local air quality as much as might be expected.

Figure 1. OGV emissions near the Texas coast.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Co ntrol Measure 45 Clean Port_051009.doc 

### The emission inventory for OGV supplied by TC EQ was insufficient to determine how much of the transit emissions could be affected by vessel speed reduction.

Reduction of At-Berth OGV Emissions

Vessels use auxiliary engine primarily to provide electrical power while docked. These engines are largely uncontrolled diesel engi nes with high emission rates. Two approaches exist to reduce emissions at dock: shoresid e (plug-in) grid power provided, and use of hood or bonnet that routes the exhaust to a scru bber system that is either barge mounted or shore-based.

There may be limitations to how much berthi ng emissions may be affected by shoreside power. For vessels that do not often visit, it may not be po ssible or cost effective to retrofit the vessel to allow a plug-in device. Also, some ve ssels have significant boiler emissions due to steam requirements (tha t cannot be supplied by shore power) and include, for example, some tankers that use steam-driven pumps to load and unload liquid products. Shoreside power requires time (roughl y an hour at each end of the vessel call) to bring shore grid power online to the ve ssel including time to physically connect the power lines and balancing th e vessel power grid. So shor eside power could reduce the engine emissions at berth to about 2 hours per call.

OGV Auxiliary Engine & Main Engine Fuel Standards

A fuel switch to lighter fuels has been suggested primarily to reduce sulfur and particulate matter emissions, but would have some benefit for NOx emissions as well. Shown in Table 1 are the relativ e emission rates showing that the use of distillate fuels result in about a 6% NOx reduction.

Table 1. Emission factors for OGV engine emissions by engine and fuel type. (ICF, 2006).

Engine Type Fuel VOC (g/kW-hr) CO (g/kW-hr) NOx (g/kW-hr) Slow speed 2-stroke Residual 0.6 1.4 18.1 Slow speed 2-stroke Distillate 0.6 1.4 17.0 Medium speed 4-stroke propul sion Residual 0.5 1.1 14.0 Medium speed 4-stroke propul sion Distillate 0.5 1.1 13.2 Medium speed 4-stroke aux iliary Residual 0.4 1.1 14.7 Medium speed 4-stroke aux iliary Distillate 0.4 1.1 13.9



### The distillate fuel in Table 1 represents diesel fuel prior to any additi onal controls such as was implemented with TxLED fuel. So us e TxLED could reduce NOx further by another 6%.

Not all auxiliary engines use residual fuel, and ARB (2005) estimated that about 29% of merchant vessels use residual fuel in auxiliary engines and only 8% of passenger vessels.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Co ntrol Measure 45 Clean Port_051009.doc 

### OGV Main and Auxiliary Engine Emissions Improvements

A large NOx emission reduction benefit could be effectuated by using engine controls either designed into the engine or as an aftertreatment devi ce that could be used only near sensitive air quality areas.

The proposed Tier II international standard of 14.4 g/kW NOx (or 15% control) for slow speed engines from 17.0 might result from retrof it of engines, while the Tier III standard of 3.4 g/kW-hr (or 80% control) would likely re quire an aftertreatment device. The Tier II standards would be on vessels build in 2011 - 2015, and Tier III would be for those built in 2016 and later. The age distribution then becomes an important consideration to estimate the emission reduction, and to provide an approximate example we used 30% of vessels of 2011 - 2015 and newer by 2018 while only 10% would be 2016 and newer by 2018 using an average life of 20 years. Th is would result in about a 12.5% emission reduction in 2018.

COST AND COST-EFFECTIVENESS

Vessel Speed Reduction

The costs with regard to ve ssel speed reduction are associated with the added time that the products are in tran sit instead of sold and vessel’s crew is on duty. This can be difficult to determine, but could still be signi ficant. For instance, a one-hour delay of all foreign freight passing through the Port of Houston Authority (about $120 billion of marine-borne freight moved through POHA in 2007 according to the Comprehensive Annual Financial Report for 2007) at 3% per year rate of return would cost about $400,000 in lost revenue. However there would be a savings of fuel used by slowing the vessels. At this point, there is no clear method to estimate th e cost of slowing the vessels during a portion of their transit.

Reduction of At-Berth OGV Emissions

ARB (2007) conducted a detailed evaluation of their rule to reduce emissions from OGV at port. The costs effectiveness depends upon the number of calls that each vessel would make to justify the cost of vessel retrofit, a nd the auxiliary loads of that vessel while in port. California highly values the PM em ission reduction, but ignoring the PM benefits the cost effectiveness for only the NOx reduction from shoreside power was estimated to range from $11,000 - $80,000 per ton of NOx reduced.

OGV Auxiliary Engine & Main Engine Fuel Standards

ARB (2005) conducted a detailed evaluation of their rule to reduce emissions from OGV with fuel changes. California highly valu es the PM emission reduction, but ignoring the PM benefits the cost effectiveness for the NOx reduction from shoreside power was estimated to be about $80,000 per ton of NOx reduced.G:\HGAC\Reports\Final_051009\Appdx_G_051009\Co ntrol Measure 45 Clean Port_051009.doc 

### OGV Main and Auxiliary Engine Emissions Improvements

A cost study for implementing the internati onal standard for engine controls was not conducted. The costs will be incurred not just for the added research and equipment used on new engines, but also maintenance cost of control equipment and perhaps a fuel penalty with low NOx designs. The engine de signs have not yet been finalized so the cost is not known at this time.

SUMMARY OF RESULTS

Emission Reduction Potential Measure # Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. CostEffectiveness ($/ton) 45 Clean Port Plan Vessel Speed Reduction (Transit only) OGV – transit Less than 0.54 VOC 18.36 NOx 25% est. 4 NOx Unknown (PM benefits not counted) 45 Clean Port Plan Reduction of AtBerth OGV Emissions OGV – dwell 0.35 VOC 13.69 NOx 50% 0.2 VOC

6.8 NOx $11,000 - $80,000 (PM benefits not counted) 36 Clean Port Plan OGV Auxiliary Engine & Main

Engine Fuel Standards OGV – All 0.89 VOC 32.05 NOx 6 – 11% 1.9 – 3.5 NOx $80,000 (PM benefits not counted)

45 Clean Port Plan OGV Main and Auxiliary Engine Emissions Improvements OGV – All 0.89 VOC 32.05 NOx 12.5% 4 Unknown Engine designs not yet available



### REFERENCES

ARB (2005), “Emission estimation methodology for ocean-going vessels, Appendix D,” Regulatory Support Document for the Rule making To Consider The Adoption Of Proposed Regulations To Reduce Emissions From Auxiliary Diesel Engines And Diesel-Electric Engines Operated On Ocean-Going Vessels Within California Waters And 24 Nautical Miles Of Th e California Baseline, December 8, 2005

ARB (2007), Technical Support Document: In itial Statement Of Reasons For The Proposed Rulemaking to Reduce Emissions from Diesel Auxiliary Engines on Ocean-Going Vessels while At-Berth at a California Port, October 2007.

ICF (2006), “Current Methodologi es and Best Practices in Preparing Port Emission Inventories,” Final Report, Pr epared for EPA, April 4, 2006.

### APPENDIX H

Detail Evaluations for Weight of Evidence Control StrategiesG:\HGAC\Reports\Final_051009\Appdx H_051009\Contro l measure 10 Construction idling_051009.doc 

### Control Measure: #10, Construction and other off-road idle reduction Category: Off-road Author: Chris Lindhjem , ENVIRON

DESCRIPTION

Idling is an inefficient use of equipment in general and generates unnecessary emissions. Idling however cannot be avoided in all cases, such as during normal work when work is performed intermittently, and the time to rest art the engine would be considered an annoyingly significant delay. This measure woul d seek to limit excessive idling when equipment is not required immediately. Suggested periods for limiting idling could be as little as 15 minutes maximum. Many on-road tr ucks have factory-installed engine shut down devices that automatically shut down the engine after a set period, or devices could be added to existing equipment.

To implement this measure, idle shut-off de vices could be employed with idle timers set to a period that would not cause typical opera tional problems. But operator training could provide significant idle reduction perhaps beyond idle shut-off devices.

IMPLEMENTATION FEASIBILITY

Engine shut off devices coul d be part of a cofunded oppor tunity, but operator training could be another opportunity for reduced idli ng time. There may be other methods to incorporate idling or fuel consumption into the accounting of each contract involving offroad equipment activity.

PUBLIC ACCEPTANCE

The measure would be easiest to implement as a funded idle shut-off device to avoid lengthy operator training. The general public w ould not often realize when equipment is idling excessively.

ANALYSIS

Analysis of this measure is based on estimated time in idle and relative emissions rates while at idle. Base on the EPA test procedure for off-road engines, it is estimated that nonroad engines are at idle 15% of the time they are in operation. Using emission results for a Tier 1 engine (see EPA, NONROA D model documentation, 2005) as shown, for example, in Table 1, the idle emissions are re sponsible for 1.4% of all emissions. Not all engines operate with the same profile as th e 8-mode testing cycle shown in Table 1 and so may idle more or less than that show n. On the other hand, it is not possible toG:\HGAC\Reports\Final_051009\Appdx H_051009\Contro l measure 10 Construction idling_051009.doc 

### eliminate all engine idling as some of the idle time occurs in short duration intervals between non-idle modes that oc cur during normal operations.

Table 1. Mode weightings and emissions by mode for a sample engine.

Mode Time Weighting Speed Torque NOx (Tier 1 Engine) (g/hour) Emissions Fraction 1 0.15 Rated 100% 1,626 24.9% 2 0.15 Rated 75 1,220 18.7% 3 0.15 Rated 50 784 12.0% 4 0.1 Rated 10 231 2.4% 5 0.1 Intermediate 100 1,740 17.8% 6 0.1 Intermediate 75 1,342 13.7% 7 0.1 Intermediate 50 898 9.2% Idle 0.15 0 0 92 1.4%



### Applying the idle emission reduction per centage, 1.4%, to all nonroad equipment, excluding locomotive and aircraft addressed under different measures, the expected emission reductions would total 1 tpd in emission reduction. Because not all idling can be addressed as noted above and not all engine s may be cost effectively retrofitted with automatic engine shut-offs, a 50% effectivenes s criteria was applied to determine a more reasonable, lower estimate of actual emission reduction.

EMISSIONS AFFECTED

Table 2 shows the approximate summary emissions for nonroad equipment for 2018. The actual emissions may vary from day to day (such as weekday and weekend day) and depend upon whether the implementation of c ontrol strategies, such as TERP and TxLED, have or should be included in the es timates because TERP projects to date may exceed their project life by 2018. Table 2 should be considered as reasonable estimates rather than exact figures.

Table 2. Approximate 2018 baseline nonroad mobile source missions inventory. Summer Weekday Emissions (tons) Aggregate Equipment Category Equipmen t Population NO X VOC CO Agricultural Equipment 5,972 1.85 0.22 2.46 Airport Ground Support Equipment 975 0.39 0.05 0.53 Commercial Equipment 256,241 6.50 10.95 425.19 Construction and Mining Equipment 97,192 19.07 4.34 64.34 Industrial Equipment 39,145 5.87 0.89 21.99 Lawn and Garden Equipment 1,664,135 2.12 17.98 300.42 Logging Equipment 2,154 0.05 0.13 1.75 Pleasure Craft 129,479 1.47 14.91 31.95 Railroad Equipment 126 0.05 0.01 0.04 Recreational Equipment 79,794 0.27 4.55 40.26G:\HGAC\Reports\Final_051009\Appdx H_051009\Contro l measure 10 Construction idling_051009.doc Summer Weekday Emissions (tons) Aggregate Equipment Category Equipmen t Population NO X VOC CO Underground Mining Equipment 0 0.00 0.00 0.00 8-County HGB Total General Nonroad 2,275,213 37.64 54.02 888.92 8-County HGB Total Spark-Ignition Nonroad 2,150,612 9.35 50.79 874.80 8-County HGB Total Diesel Nonroad 124,601 26.59 1 3.23 14.12 1 – 6% lower diesel nonroad NOx emissions than TCEQ provided to approximate the TxLED emission reduction not included in the submittal.



### EMISSIONS BENEFIT

Overall, the per-project benefit is estimated at 1.4% based on the estimate that equipment idles for 15% of the total time the engine is used. To the extent th at the equipment idles more than that, the benefit of the project coul d be greater. However, we need to consider that some idling would occur during normal operations (when engine shut off would cause an unnecessary burden on the operators) and only a fraction of the fleet that could implement controls, resulting in half of the estimated bene fits. The VOC benefits were not estimated because the predominant sour ce of VOC emissions are small gasoline nonroad engines, and so would not be ab le to demonstrate idle reductions.

COST AND COST-EFFECTIVENESS

The benefit of idle reduction would almost alwa ys be positive in term s of monetary gain. Only in the case where the engine is not often used would the return on the capital cost of added equipment result in a net cost, and in that case operator training would be a better option.

SUMMARY OF RESULTS

Expected Emission Reduction Measure # Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effectiveness ($/ton)

10 Off-road Idle Reduction Engine shut down devices

or operator

training Off-road engines 36 NOx 0.7 0.25 NOx ~ $0G:\HGAC\Reports\Final_051009\Appdx H_051009\HGAC Measure 21 Scrappage_051009.doc 

### Control Measure: #21, Scrappage buy-back plan Category: On-road Author: Hazel Barbour

DESCRIPTION

This measure would build on the existing Low In come Repair Assistance Program (LIRAP), implemented as part of the AirCheckTexas Vehicle Emissions Tes ting program (I/M) by increasing the number of on road light duty gaso line vehicles scrapped, and would also make separate funds available to he lp with purchase of new on road heavy duty diesel vehicles (HDDV) to replace old, highl y polluting vehicles.

IMPLEMENTATION FEASIBILITY

LIRAP is implemented in Brazoria, Harris, Fo rt Bend, Galveston and Montgomery counties and not in Chambers, Liberty and Waller which do not currently have an I/M program in place. Funds appropriated to repair and replacement assistance under LIRAP cannot be used to fund replacement/scrappage of diesel vehicles as these vehicles are not required to be emissions tested in the I/M program. Thus, it will be necessary to establish or use other sources of funding to be able to provide compensation for replacing and sc rapping heavy duty diesel vehicles. However, as funds for diesel scrappage would not come fr om an I/M related source, a diesel scrappage buy back program could be implemented in the 8 county HBG area.

Given the increased funding made available fo r LIRAP in the 2007 Texas legislative session, there is already a considerable increase in the uptake of funds to scrap gasoline vehicles which fail the I/M test, or which may have passed the I/M test but are over 10 years old. In FY 2007 (Sept 1, 2006 – Aug 31, 2007), 4% of the redeemed LIRAP vouchers were used to replace vehicles. After the changes to the program took effect in December 2007, the percentage of vouchers redeemed to replace vehicles in FY 08 ro se to 74%. However, it should be noted that of the total number of 13,044 vouchers issued in FY 08, 4,307 vouchers we re voided as unused. On the assumption the same percentage of these vouchers could have been used for replacement as the percentage of redeemed vouchers, 3,188 a dditional vehicles could have been replaced. According to HGAC, one of the major problems in increasing the number of participants whose vehicles may be eligible for replacement/scrappage is that owners cannot qualify for financing to purchase a replacement vehicle based on their income or credit history.

PUBLIC ACCEPTANCE

Removing old, high emitting vehicles from the road is a strategy that has been generally well received by the public.

ANALYSIS

The increased LIRAP funding available for replaci ng a vehicle and the higher income eligibility levels have greatly increased the number of vehicles being replaced and scrapped in 2007/08. However, the majority of the users for replacement have had incomes between 200-300% of theG:\HGAC\Reports\Final_051009\Appdx H_051009\HGAC Measure 21 Scrappage_051009.doc 

### poverty levels (the new income eligibility level a dded in 2007). On the assumption that owners of the 3188 vouchers which were not redeemed n eed help in addition to receiving the vehicle replacement amounts offered in the program ($3,000 fo r a car, current model year or up to three model years old; $3,000 for a truck, current model year or up to two model year sold; $3,500 for hybrid vehicle, current or previous model yea r), one solution could be to seek legislative approval to use excess funds collected through the $6 LIRAP fee on every On-Board Diagnostic (OBD) test to set up a revolving loan fund to provide low intere st loans. Total LIRAP funds collected will increase every year as the number of MY 1996 and newer vehicles subject to the OBD test increases. If Chambers, Liberty and Waller come into the I/M program, this would increase the numbers of vehicles that could be replaced through the program (See Measure 133).

Funds are available to help with the purchase of new heavy duty diesel vehicles to replace and scrap older vehicles through the TERP program . Additional outreac h on TERP to smaller trucking companies, which may have older vehi cles, could be implemented through the Texas Motor Transportation As sociation and at truck stops, etc.

In addition to TERP funding, US EPA’s Smartway Clean Diesel Finance Program could provide the ability to establish a low interest loan pr ogram for new truck purch ase or the purchase of used, pre-2007 heavy-duty trucks retrofitted w ith an EPA verified emission control technology, with the requirement that the new purchase repl ace a truck that is sc rapped. The EPA grant could be used to leverage additional funds by bo rrowing from another lend ing institution, such as the Houston Green Bank. In this way, because the EPA funds are at 0 percent interest, the blended fund can offer potential tr uck purchasers a loan at lower in terest rates if they meet the program requirements.

The purchase of older light duty and/or heavy duty vehicles for scrappage could also be offered as a Supplemental Environmental Project (SEP) to companies in violation of environmental regulations, with the resulting em ission reductions being treated as State Implementation Plan (SIP) credit.

In 2007, approximately 440 on-road HDDVs in th e HGB area were replaced with a new or newer on-road vehicle using TERP funds (thus 4 40 HDDVs were scrapped). In 2018, it is estimated that 9,305 of the 30,656 Class 8(a) and 8( b) heavy duty vehicles in the 8 county HGB area will be over 10 years old. If it is assumed the program can encourage an additional 50% (220) per year to take advantage of the funding offered, then the number of these vehicles over 10 years old can be reduced by over half. Iden tification of highly po lluting HDDVs which may be good candidates for scrappage an d replacement could be carried out through the use of remote sensing devices at DPS weigh stations.

Emissions reductions from scrapping an addi tional 3188 light duty gasoline vehicles were calculated using MOBILE6 emissions factors for light duty gasoline vehi cle types 1 through 5. The NOx and HC factors and annual VMT for types 1 and 2 (passenger cars, SUVS) were averaged as were the factors and VMT for types 3, 4, and 5 (all light duty trucks). Remaining useful life for the replaced vehicles was estimated at 3 years. While this is not a requirement in the LIRAP program, this is the life of a mobile emission reduction credit (MERC). The ratio of passenger cars and SUVs to all light duty tr ucks in the HGB area in 2007 was 0.959. For the purposes of this calculation it was assumed th at 50% of the scrapped vehicles would be passenger cars and SUVs, and 50% light duty trucks.G:\HGAC\Reports\Final_051009\Appdx H_051009\HGAC Measure 21 Scrappage_051009.doc 

### EMISSIONS AFFECTED

Emissions affected are on road light duty gasoli ne emissions in the 5 county HGB area and on road heavy duty diesel emissi ons in the 8 county HGB area.

EMISSIONS BENEFIT

Increasing LDGV scrappage by a minimum of 3188 vehicles per year would achieve emissions reductions of 0.09 NOx tpd or 23.16 tons per year, and HC 0.186 tpd or 46.69 tons per year.

By increasing scrappage of HDDVs by 220 per year, the average NOx emission reductions per vehicle (based on averaging the emissions redu ctions from 330 of the 440 vehicles replaced under using TERP funds in 2007)) is estimated to be 1.1 tpd or 275 tons per year. The total NOx reduction of 1,925 tons is based on a project life of 7 years as used in the TERP calculations.

COST AND COST-EFFECTIVENESS

The total costs of providing the LIRAP incentiv e ($3,000) to replace and scrap the estimated 3188 light duty gasoline vehi cles is estimated to be $9,564,000. Assuming the average continuing useful life of the scrapped vehicles if they had not been scrapped to be 3 years, the cost effectiveness per ton of NOx is estimated to be $137,651 and per ton of HC, $68,280.

The TERP grant funds awarded to the 440 Houston-Galveston area HDDVs in 2007 range from around $15,000 up to $110,000, with the average gr ant awarded per vehicle being $59,655. Total cost of replacing 220 HDDVs is estim ated to be $13,124,100. Cost effectiveness is calculated to be $6,818 per ton.

SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Sources Affected Emissions (tpd) % tpd Est. Cost Effectiveness ($/ton)

21 Scrappage Buy Back Plan Monetary compensation for scrappage of old vehicles, including HDDVs. On-road LDVs in 5 county HGB area and HDDVs in the 8 counties LDGVs NOx 26.88 VOC: 37.22: HDDVs NOx 19.67 VOC 3.14 LDGVs NOx 0.33 VOC 0.49: HDDVs NOx 5.59 LDGVs NOx 0.09 VOC 0.186: HDDVs NOx 1.1 LDGVs NOx $137,651 VOC $68,280: HDDVs: NOx $6,818G:\HGAC\Reports\Final_051009\Appdx H_051009\HGAC Measure 21 Scrappage_051009.doc 

### REFERENCES

Graciela Lubertino, HGAC; LIRAP statistics for FY 07 and 08.

Texas Motor Transportati on Association (TMTA): www.tmta.com

TCEQ Texas Emission Reduction Plan (TERP) data: www.tceq.state.tx.us

US EPA Smartway program: www.epa.govG:\HGAC\Reports\Final_051009\Appdx H_05100 9\BControlMeasure58- PAYD-EM_051009.doc 

### Control Measure: #58, Pay As You Drive Insurance Programs Category: On-Road Author: Barbara Joy, Earth Matters Inc

DESCRIPTION

Pay-As-You-Drive (PAYD) Vehicle Insuran ce (also called Distance-Based Vehicle Insurance and Mileage-Based Insurance) is a program whereby a vehicle’s insurance premiums are based directly on how much it is driven during the policy term. The way car insurance is currently structured, high mil eage drivers are, in essence, subsidized by lower mileage drivers since all are charge d the same premiums after accounting for driving history related to accidents and tra ffic violations. If you drive 5,000 miles per year you are charged the same premium as someone driving 50,000 miles per year. In pay-as-you-drive programs. driving more causes higher charges and driving less causes lower charges. According to a Septem ber 21, 2008 article in the Baltimore Sun 1



### , participating motorists can save an averag e of about 40% on their annual insurance premiums. More and more areas in the U.S. are offering this program; currently (11/08) it is offered in Alabama, Michigan, Minnesota , New Jersey, and Oregon. In Texas, pilot programs have or are operating in various metropolitan areas such as Dallas.

In addition to reductions in VMT there ar e other benefits. Ac cording to a recent Brookings Institution Hamilton Project study 2 

### , Economist Aaron Edlin estimates benefits to insurance companies for reduced accident s to be roughly $33 per vehicle (and even that is only a temporary gain until other firm s match its new policies), while the social benefits from reduced accidents and congest ion alone would be r oughly $118 per vehicle. As noted by (Litman, 2005), in these programs ex isting rating factors are incorporated so higher-risk motorists pay more per unit th an lower-risk drivers. For example, a $375 annual premium becomes 3¢ per mile, and a $1,250 annual premium becomes 10¢ per mile. An average U.S. motorist would pay about 6¢ per mile. Studies based on individual’s response to changes in the price of auto use show that significant travel and associated emission reductions can be realized through these programs.

One major benefit of this and other pricing programs is that it affects all categories of travel. Most measures aimed at reducing travel and associated emissions focus on commute travel, which represents about 25 – 30 pe rcent of total travel in a given region. This measure would affect both commute and non-commute travel.

1 http://www.baltimoresun.com/news/traffi c/bal-id.insurance21sep21,0,155432.story 2 Pay-As-You-Drive Car Insurance: Transportation

, Climate Change

, Regulation

, U.S. Economy

, Environment Jason E. Bordoff, Policy Director, The Hamilton Project . Democracy Journal, Issue #8, Spring 2008G:\HGAC\Reports\Final_051009\Appdx H_05100 9\BControlMeasure58- PAYD-EM_051009.doc 

### In 2001 the Texas legislature passed House Bill 45 that allowed Texas insurance companies to offer mileage-based insurance. However this law had a sunset provision and expired in September 2005. Companies in Texas and in all other states can still voluntarily offer the cents-per-mile c hoice under existing insurance law.

This analysis evaluates the potential effect of this program were it subscribed to by 50 percent of Houston area drivers.

ANALYSIS

There have been a number of estimates of th e potential benefits of mileage programs and similar programs involving changes in the pri ce of driving. These estimates range from 1.8 to about a 20 percent reducti on in driving per individual in the program. The sources of these estimates include:

1. Todd Littman’s “ Distance-Based Vehicle Insu rance Feasibility Costs and Benefits” , 2001, Victoria Transport Policy Institute; 2. Harvey and Deakin’s 1997 Appendix to the report “ Technical Methods for Analyzing Pricing Measures to Reduce Transportation Emissions” by EPA and FHWA; 3. Baker and Barrett’s “ The feasibility of Pay by th e Mile Auto Insurance”, 1999 Economic Policy Institute; and, most recently, 4. Brookings Institution Hamilton Project, July 2008 t he Impact of Pay-As-YouDrive Auto Insurance in California by Jason E. Bordoff and Pascal J. Noel

. 

### Harvey and Deakin utilized a modified transportation model called the STEP model initially developed for the San Francisco Ba y Area to evaluate a variety of pricing measures on driving behavior. The model was applied to four different areas in California, based on 1990 land use and price data. Table B-21 of their appendix 3 

### contains a list of cents per mile charges a nd associated percent travel reduction. For example these range from 2.3 to 19.7 percent changes in VMT for mileage fees ranging from one to ten cents for 1991 in Los Angeles.

These values were updated by Todd Littman (see http://www.vtpi.org/tdm/tdm79.htm, Table 1 ) to account for inflation between 1991 and 2001, as follows:

3 

### Greig Harvey and Elizabeth Deakin, “The STEP Analysis Package: Description and Application Examples,” Appendix B, in Apogee Research, Guidance on the Use of Market Mechanisms to Reduce Transportation Emissions , USEPA (Washington DC; www.epa.gov/omswww/market.htm ), April 1997G:\HGAC\Reports\Final_051009\Appdx H_05100 9\BControlMeasure58- PAYD-EM_051009.doc 

### Table 1. Mileage Fees and Percent Travel Reduction. Mileage Fee (cents) Travel Reduction (percent) 1 1.8 2 3.5 3 5.1 4 6.7 5 8.2 6 9.7 7 11.2 8 12.5 9 13.8 10 15.2



### The figures presented here are reasonably consistent with those presented in the Brookings study, which found an 8 percent reduction for participants. 4



### ANALYSIS AND RESULTS

The methodology uses the cents per mile changes noted by Littman (2001) and quoted in Table 1 above.

Assumptions include the following:

• Emission factors for MOBILE6 for 2018 are used;

• Elasticity of driving demand with respect to a one percent cha nge in price is -0.4, using a medium term elasticity value.

• Insurance prices in 2018 are 12 cents per mile;

• Only light duty passenger vehicles ar e affected by the program – delivery vehicles, line haul trucks and the like are not;

• Daily light duty vehicle miles traveled in 2018 for the H-GAC nonattainment area are 160,018,988.

• NOx emission factor for light duty vehicles is 0.171 grams per mile;

• VOC emission factor for light duty vehicles is 0.231 grams per mile;

• VOC and NOx emissions include all categ ories of emissions, including start, tailpipe, evaporative, running loss, etc.

All results are expressed as tons per day reduction and per cent of total on-road vehicle emissions reduced.

4 More specifically they found that there would be an 8 percent reduction nationwide if all motorists were on a pay-as-you-drive system.G:\HGAC\Reports\Final_051009\Appdx H_05100 9\BControlMeasure58- PAYD-EM_051009.doc 

### It is assumed that 2018 insurance rates, if assessed in the manner they are now, would average 12 cents per mile. Given expected savings of 40% from moving to a pay-as-youdrive program, costs would be reduced from 12 cents to 7.2 cents per mile for each participant.

According to H-GAC 5 

### , 2002 costs of driving were 11.8 cents per mile considering gasoline, oil and maintenance. At a compounde d growth rate of 3 percent per year it is expected that driving costs will be 18.9 cen ts per mile in 2018. The combination of variable driving costs plus in surance costs would be 30.9 cents per mile in the absence of a pay-as-you-drive program and 26.1 cents per mile with one. Using an elasticity of -0.4 it is estimated that the program would result in an 7.4 percent reduction in travel per participant, which is consistent with th e independently derive d Brookings Institution study.

Emissions Analysis

The emissions analysis utilized the ba sic process suggested by the MOSERs methodology, as follows:

Variables: EF A 

### : Speed-based composite emission factor after implementation (NO x 

### , VOC, or CO) grams/mile)

EF B 

### : Speed-based running composite emission factor before implementation (NO x 

### , VOC, or CO) (grams/mile)

N VA 

### : Number of vehicles after implementation

N VB 

### : Number of vehicles before implementation

TEF AUTO 

### : Auto trip-end emission factor (NO x 

### , VOC, or CO) (grams/trip)

TL A 

### : Average auto trip length after implementation (miles)

TL B 

### : Average auto trip length before implementation (miles)

VMT A 

### : Vehicle trips after implementation

VMT B 

### : Change in VMT as a result of implementation

Total light duty travel in 2018 is estimated by the H-GAC transportation model to be 160,018,988. If 50 percent of this travel is by motorists participati ng in a pay-as-youdrive program then 11,841,405 mile s of travel would be reduced by this program.

5 Personal Communication Gao Shixin, H-GAC and Barbara Joy, Earth Matters Nov 11, 2008.G:\HGAC\Reports\Final_051009\Appdx H_05100 9\BControlMeasure58- PAYD-EM_051009.doc 

### Equation:

Daily Emission Reduction =

C = VMT B 

### * EF A =



### 11,841,405 * 0.171 gram/mile NOx/454 = 4,460 lb/day, and 2.2 tpd NOx

and

11,841,405 * 0.231 gram/mile VOC/454 = 6,025 lb/day, and 3.01 tpd VOC.

COST EFFECTIVENESS

PAYD insurance programs may actually produc e a net savings in money, meaning they are exceptionally cost effective. The Br ookings study cited earlier estimates $50 to $60 billion dollars per year in savings from less driv ing, fewer accidents, and lower costs. Therefore it is assumed that the net co st of this program would be negative.

In summary it is expected that cost effec tiveness will be less than $4,000/ton which is the highest ranking for cost effectiveness.

COMMENTS

This evaluation is based on a combination of hypothetical assumptions and data for this program and may be considered for use in oz one plan after review of key assumptions, expected emission reductions a nd potential implementation approaches. If more refined analysis is conducted it may provide additional accuracy to evaluate the measure based on price elasticities and estimates of expected costs per mile for driving.G:\HGAC\Reports\Final_051009\Appdx H_05100 9\BControlMeasure58- PAYD-EM_051009.doc 

### Also key is that the emission factors used in the analysis are emission factors with currently programmed federal and other cont rol measures such as Tier 2 tailpipe standards. Other measures are being evalua ted for the H-GAC region, such as California LEV (low emission vehicles), cleaner fleets and wider applic ation of the Inspection and Maintenance program. If these or other similar programs were implemented, the emission factors used to evaluate programs af fecting the amount of travel (such as this one) would be smaller – each mile driven woul d be at a lower emission rate and therefore each mile not driven would not reduce emissi ons as much as it would have without the additional measures.

SUMMARY OF RESULTS: Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions % Tpd Cost Effectiveness ($/ton)58 Pay-AsYou-Drive (PAYD) Insurance PAYD participation at 50 percent of LDV activity On-RoadLightduty vehicles 40.7 VOC 30.3 NOx 7 3.0 2.2 <$4,000G:\HGAC\Reports\Final_051009\Appdx H_051009\Cont rol Measure 126 Reduced Idling_051009.doc 

### Control Measure: #84, 126, 147, 148, Reduced Idling Category: On-road Author: Chris Lindhjem, ENVIRON

DESCRIPTION

Idling of vehicles is inherently an ine fficient operation that can produce unwanted air pollutants. Idling however also occurs duri ng normal driving and other operations such as when the engine powers necessary accesso ries including for example man-lifts or concrete tumblers. Therefore it is not possi ble to eliminate all idling. But idle reduction programs are interesting because the costs are typically low and may be a net savings to the owner/operator of the vehicle while also reducing air emissions.

IMPLEMENTATION FEASIBILITY

There are several methods that have been attempted to reduce idling of vehicles; primarily from heavy-duty trucks that ofte n idle while the driver is off-duty or performing other duties nearby. There are two basic methods: a voluntary approach where alternatives to idling are provided, and a punitive (fines) method where no idle zones are posted and poli ced to eliminate idling.

PUBLIC ACCEPTANCE

A voluntary program can achieve enthusiastic support because infrastructure to reduce fuel costs can be paid for from public f unding. A requirement to eliminate idling would be difficult to administer, but would have a larger impact on emissions.

ANALYSIS

In the strictest implementation, idling more than 5 minutes would be prohibited except for normal operations whether or not an altern ative to idling exists. This could affect all heavy-duty vehicles whether delivery / retail vehicles or other vehicle functions.

The EPA (2004) guidance estimates that up to 3.4% of Class 8 truck NOx emissions could be reduced through reduced long durati on idling programs. This presumably sets up the maximum benefit for programs such as the IdleAire truck stop electrification project funded by TERP.

For light-duty vehicles at drive-thru operati ons, it would be difficult to gauge how much that would be. For an extraordinary total, even if an astound ing 10% of the HGB population of 5,628,101 idled 10 extra minutes in a single occupancy vehicle, theG:\HGAC\Reports\Final_051009\Appdx H_051009\Cont rol Measure 126 Reduced Idling_051009.doc 

### resulting emissions increase would be 0.16 tpd VOC and 0.04 tpd NOx. This calculation used the emission rates in Table 1 for pa ssenger cars and light-duty gasoline trucks.

Table 1. Idle emission rates for light-duty gasoline vehicles in 2018.

Vehicle Type VOC (g/hr) CO (g/hr) NOx (g/hr) LDGV (passenger cars) 1.56 10.55 0.38 LDGT1 (Light-duty trucks) 1.70 11.01 0.36
LDGT2 1.82 12.49 0.53
LDGT3 1.16 9.58 0.37
LDGT4 1.22 10.03 0.57



### EMISSIONS AFFECTED

The EPA guidance on reduced id ling includes an upper end es timate of 3.4% of area NOx due to extended idling. For the all diesel and gasoline trucks the NOx emissions are 21.6 tons per day, and for the larger Class 8 truc ks (the subject of the EPA guidance) the NOx emissions are 13.2 tons per day for a weekday in 2018.

EMISSIONS BENEFIT

If idle reduction programs can be expande d to all heavy-duty vehicles, then 0.73 tpd could be reduced. The long duration idli ng reduction for Class 8 maximum would be 0.45 tpd of which 0.33 tpd was credited to the IdleAire TERP project expected to last through 2020.

COST AND COST-EFFECTIVENESS

The TERP program to supply idle reduction technology in the HGB area was estimated to reduce NOx emissions at $1,200 per ton. This truck stop electrification project however targets the most readily available and likel y largest source of id ling trucks, and so reducing idling in other areas would pr oduce less benefit for the investment.

It is not possible to estimate the lost revenue and cost of prohibiting drive-thru operations during ozone episodes or for the summer seas on when ozone events would likely occur.

SUMMARY OF RESULTSG:\HGAC\Reports\Final_051009\Appdx H_051009\Cont rol Measure 126 Reduced Idling_051009.doc Expected Emission Reduction Measure ID Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effectiveness ($/ton)

126, 147, 148 Idle limits forheavyduty vehicles Idle Reduction Programs Heavyduty vehicles 13.2 – 21.6 3.4 0.45 – 0.73 $1,200

84 Prohibit drive-thru service during

ozone

season Idle Reduction Program Light-duty vehicles 40.7 VOC 30.3 NOx 0.4% VOC 0.1% NOx 0.16 VOC 0.04 NOx Unknown



### REFERENCES

EPA. 2004. “Guidance for Quantifying and Us ing Long Duration Truck Idling Emission Reductions in State Implementation Pl ans and Transportation Conformity,” Office of Transportation and Air Qual ity,” EPA420-B-04-001, January 2004, pg. 12 http://www.epa.gov/SmartwayLogistics/documents/420b04001.pdf

.G:\HGAC\Reports\Final_051009\Appdx H_051009\BContro lMeasure137LivableCenters-EMUpdate _051009.doc 

### Control Measure: #137, Encourage/Mandate Livable Centers Category: On-Road Author : Barbara Joy, Earth Matters Inc

DESCRIPTION

Communities across the country are developing creative strategies aimed at preserving natural lands and critical environmental areas, protecting water and air quality, and reusing already-developed land. They conser ve resources by reinvesting in existing infrastructure and reclaiming historic build ings. By designing ne ighborhoods that have shops, offices, schools, churches, parks, and other amenities near homes, communities are giving their residents a nd visitors the option of wa lking, bicycling, taking public transportation, or driving as they go about th eir business. A range of different types of homes makes it possible for seni or citizens to stay in their homes as they age, young people to afford their first home, and familie s at all stages in between to find safe, attractive and affordable homes. Through smart growth approaches that enhance neighborhoods and involve local residents in development decisions, these communities are creating vibrant places to live, work, and play. The high quality of life in these communities makes them economically competi tive, creates business opportunities, and improves the local tax base.

EPA developed the Smart Growth Implemen tation Assistance (SGIA) program in response to communities' requests for help in achieving their development goals. Through this program, EPA provides technical assistance from private- sector experts to helping communities find the best tools and resources for planning growth in ways that sustain environmental and economic progress an d create a high quality of life. In October 2008 the program select ed three cities: receive Smart Growth Implementation Assistance from a team of private-se ctor experts: Capitol Region Council of Governments, Connecticut; Miami-Dade C ounty, Florida; and Ne w York City, New York.

While Houston is not participat ing in the SGIA program at th is time (they did receive an SGIA grant in 2006), the area ha s expressed interest in eval uating the potential effects of these measures on travel activity and emissions. The Community and Environmental Planning section of H-GAC developed a spreadsh eet to assist in the evaluation of these measures, focusing on four types of centers:

1. Neighborhood Centers 2. Town Centers 3. Regional Centers 4. City Centers

Considered for each center are the acreage, wa lking distance to the center, the density of residents and employees, the number of reside nts who both work and live in the center, job density, number of dwelling units; the share of auto in all non-work trips for residentsG:\HGAC\Reports\Final_051009\Appdx H_051009\BContro lMeasure137LivableCenters-EMUpdate _051009.doc 

### of a center when the non-work destination is in the same center; the share of transit in all non-work trips for residents of a center when the non-work destination is in the same center; the share of walking/bi king in all non-work trips for residents of a center when the non-work destination is in the same center; the percent of commuter trips (for residents) accounted for by SOV; and average people in a ca rpool (for residents) . Note that this description includes a representa tive list of examples in orde r to provide a flavor; a full description of inputs can be provided upon review of the spr eadsheet which is available on request. Values used in the spread sheet are derived from the 2006 American Community Survey for Harris County, th e 2001 National Household Transportation Survey ( http://nhts.ornl.gov/2001/pub/STT.pdf ), and the 2000 census 1 

### , as well as from engineering judgement generally based on va lues observed in the Houston or similar areas or inferred where data sources did not exist.

ANALYSIS

This analysis is based upon a hypothetical scenario in which the Houston area successfully completes a large number of to wn, regional, and urban core centers as follows:

Table 1. Base Case (actual current centers) and Modeled (2018) Number of Centers. Neighborhood Center Town Center Regional Center Urban Core

2005 82 23 3 1 2018 87 28 4 1



### The base case is the actual number of cen ters based upon an evaluation of aerial photographs overlayed by grids performe d by the Community and Environmental Planning section of H-GAC. The 2018 values are hypothetical. More or fewer centers could be feasible and completed depending on a variety of factors.

The following utilizes the basic proce ss suggested by the MOSERs methodology, as follows:

EMISSIONS ANALYSIS

The emissions analysis utilized the ba sic process suggested by the MOSERs methodology, as follows:

Variables: EF A 

### : Speed-based composite emission factor after implementation (NO x 

### , VOC, or CO) grams/mile)

EF B 

### : Speed-based running composite emission factor before implementation (NO x 

### , VOC, or CO) (grams/mile)

1 Personal communication October 23, 2008. Meredith Dang, H-GAC and Barbara Joy Earth Matters.G:\HGAC\Reports\Final_051009\Appdx H_051009\BContro lMeasure137LivableCenters-EMUpdate _051009.doc 

### N VA 

### : Number of vehicles after implementation

N VB 

### : Number of vehicles before implementation

TEF AUTO 

### : Auto trip-end emission factor (NO x 

### , VOC, or CO) (grams/trip)

TL A 

### : Average auto trip length after implementation (miles) TL B 

### : Average auto trip length before implementation (miles) VMT A 

### : Vehicle trips after implementation

VMT B 

### : Change in VMT as a result of implementation

The spreadsheet estimates that the above centers would result in a 1 percent reduction in area-wide trips. It is assumed that the same percentage applies to VMT. There are 160,018,988 daily miles of travel by light duty vehicles in the re gion in 2018. A 1 percent reduction would be equivalent to a reduction of 1,600,190 miles per day.

Equation:

Daily Emission Reduction =

C = VMT B 

### * EF A =



### 1,600,190 * 0.171 gram/mile NOx/454 = 603 lb/day, and 0.30 tpd NOx

and

1,600,190 * 0.231 gram/mile VOC/454 = 814 lb/day, and 0. 41 tpd VOC.G:\HGAC\Reports\Final_051009\Appdx H_051009\BContro lMeasure137LivableCenters-EMUpdate _051009.doc 

### COST EFFECTIVENESS

The cost of this measure is unknown and unquantifiable without planning for specific projects.

COMMENTS

This evaluation is based on hypothetical assump tions and data for this program. Other assumptions could result in different results.

SUMMARY OF RESULTS Expected Emission Reduction Measure ID Name Description Affected Source Affected Emissions

% Tpd Cost Effectiveness ($/ton)

137 Encourag e/mandat e livable centers Mix of town, regional and urban core centers On-RoadLightduty vehicles 40.7 VOC 30.3 NOx 1.0 0.41 0.30 UnknownG:\HGAC\Reports\Final_051009\Appdx H_051009\HGAC Measure139 Smoking vehicles_051009.doc 

### Control Measure: #139, Enhanced enfo rcement for Smoking Vehicles Program Category: On-road Author: Hazel Barbour

DESCRIPTION

This measure would encourage local law enforcement officers to enforce existing smoking vehicle legislation and enable th e emissions inspection status of smoking vehicles to be checked. Owners of smoking ve hicles displaying a va lid inspection sticker would be fined. Smoking vehicles not ha ving a valid inspection sticker would be impounded if the sticker were found to be fraudulent.

The measure would be modeled on the Dallas Emissions Enforcement Pilot Program put in place by North Central Texas Council of Governments (NCTCOG). This program was established to identify and remove high emitti ng vehicles with fictitious or counterfeit state inspection and/or regist ration stickers from the roadways and was not linked to reports of smoking vehicles. The pilot progra m attempted to establish the percentage of impounded vehicles that cannot be found in th e vehicle registrati on or inspection and maintenance databases.

For Measure 139 to be most effective, in a ddition to smoking vehicles, vehicles seen by law enforcement officers to have potentially fraudulent stickers shoul d be pulled over.

IMPLEMENTATION FEASIBILITY

Texas Transportation Code (TTC) Section 547.60 5(d) states that “Except when travel conditions require the downshifting or use of lower gears to maintain reasonable momentum, a person commits an offense if the person operates, or as an owner knowingly permits another person to operate, a vehicle that emits: (1) visible smoke for 10 seconds or longer; or (2) visible smoke that remains suspended in the air for 10 seconds or longer before fu lly dissipating. An offens e under this section is a misdemeanor punishable by a fine of up to $350 for each violation. Thus, law enforcement officers have the right to pu ll over a vehicle which is smoking, and under TTC Section 548.603, have the right to impound th e vehicle if a stolen, fictitious or counterfeit state inspecti on sticker is displayed.

For each county in which the program is im plemented, collaboration will be necessary between the County Judge, County JP, County Constable, and Texas Department of Public Safety.

It will also be necessary to provide partic ipating law enforcement agencies access to the I/M Vehicle Identification Database (VID) so that the smoking vehicle’s I/M test status can be investigated at the point of pulling over the vehicle.G:\HGAC\Reports\Final_051009\Appdx H_051009\HGAC Measure139 Smoking vehicles_051009.doc 

### Although the owners of diesel vehicles can be fined for exhibiting visible smoke, they are not subject to I/M testing. Thus, there is no requirement to reduce VOC or NOx emissions and no easy way to quantify VOC or NOx benefits from repairing the vehicles to reduce smoke.

PUBLIC ACCEPTANCE

Dealing with smoking vehicles has general public approval. The measure may be more controversial with regard to impounding ve hicles generally owned by low income families.

ANALYSIS

The emissions reductions for the program are achieved by having out of compliance vehicles come into compliance with the emissions standards in the I/M program.

The Dallas Pilot Project was implemented in one precinct of Dallas County. Of the over 1000 vehicles pulled over during the 3 months of the Dallas pilot project, 541 vehicles were identified driving with st olen, fictitious or counterfeit state inspection certificates and impounded. Of the impounded vehicles, 360 or 66.5% received a passing inspection certificate usually within 60 days of be ing impounded,. However, later investigation discovered that of the 360 passing inspections , 172, or 47.8% appeared to have received an incorrect inspection consis ting of clean scanning, clean piping, wrong test type being conducted, or inspectors not bei ng truthful about insurance. Thus, the emissions benefit for the program was estimated for the 188 vehi cles that were repaired and received a valid inspection.

Based on an average obtained from a sample se t of MY 1995 and older vehicles that were repaired through the program, NCTCOG estimated the following emissions reductions per vehicle from passing the I/M test:

• Average VOC reductions of 0.0060 tons per year per vehicle

• Average NOx reductions of 0.0632 t ons per year per vehicle.

Reductions directly contributed to the Dallas Pilot program i.e. to the 188 vehicles that were legitimately repaired and passed the emissions test: VOC Reduction = 188 vehicles x 0.0060 = 1.128 tons per year NOx Reduction = 188 vehicles x 0.0632 = 11.88 tons per year

Tons per day reductions from 188 vehicles (weekday emissions): VOC Reduction = 0.004 tons per day NOx Reduction = 0.047 tons per day

The measure is analyzed assuming implementa tion in the 8 Constable Precincts in Harris County.G:\HGAC\Reports\Final_051009\Appdx H_051009\HGAC Measure139 Smoking vehicles_051009.doc 

### EMISSIONS AFFECTED

The emissions affected are the 3% on road light duty gasoline emissions from vehicles in the Harris County I/M program, which are assumed to be waived from testing. However, realistically this rate is under 1%. The di fference between 3% waiver rate and 0% was modeled for Harris County only using the current inventory.

EMISSIONS BENEFIT

Assuming there may be considerable overl ap between smoking gasoline vehicles and vehicles not in compliance with the emissions test, and that all other factors remain the same, extrapolating from the Dallas count y pilot program numbers the tons per day emissions reductions in the 8 precincts in Harris county provid e at a minimum the following tons per day reductions from repair ing 1504 vehicles in a 3 month period to be in compliance with the I/M test standards:

VOC Reduction = 0.031 tons per da y, or 1.937 tons for the three months NOx reduction = 0.376 tons per day or 23.5 tons for the three months

Estimating for a 12 month period based on the Dallas numbers, 6016 vehicles could be repaired to be in compliance with the emissi ons test. This number would be well within the number of vehicles accounted for in the 3% waiver rate.

COST AND COST-EFFECTIVENESS

Cost effectiveness is assessed from the costs of the Dallas 3 month pilot program. It is to be expected that full implementation would achieve more cost effective results.

Of the total cost of $265,000 NCTCOG estimated for the 3 month pilot program in one precinct in one county, $250,000 was accounted for as in-kind administrative oversight support from NCTCOG and county staff and in -kind law enforcement contribution. The remaining $15,000 costs were covered by an EPA grant. Cost effectiveness per ton of pollutant reduced for the 3 month period:

VOC Reduction = $136,809 NOx Reduction = $ 11,276 VOC and NOx combined = $ 10,417

NOTE: the cost effectiveness and emissions redu ction calculations do not account for the actions which would be taken from following up the 172 vehicles which were improperly emissions te sted following impoundment

.G:\HGAC\Reports\Final_051009\Appdx H_051009\HGAC Measure139 Smoking vehicles_051009.doc 

### SUMMARY OF RESULTS

Expected Emission Reduction Measure ID Name Description Affected Sources Affected Emissions (tpd) % Tpd Est. Cost Effectiveness ($/ton)

139 Enhanced Enforcement for Smoking Vehicles Program Local law officer enforcement of smoking

vehicle legislation and check on vehicle inspection

status Harris Co.LightDuty Gasoline vehicles VOC 0.30 NOx 0.42 Harris County only VOC 10 NOx 8.9 0.031 VOC 0.038 NOx VOC $136,809 NOx 11,276 VOC+NOx $10,417



### REFERENCES

Jody Purvis, Air Quality Oper ations Coordinator, NCTCOG

Dallas Emissions Enforcement Pilot Progr am (DEEP), Final Report, March 1, 2007, NCTCOG