Bryan W. Shaw, Ph.D., Chairman 

Buddy Garcia, Commissioner 

Carlos Rubinstein, Commissioner 

- . : ~~·.-> .:.\ \ .: I· 

!d:~ fJLr.;·u:i: 

. !· 

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

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

Protecting Texas bg Reducing and Preventing Pollution 

April6,2010 

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

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

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

A1 Armendariz, PhD, Regional Administrator 

U.S. Environmental Protection Agency- Region 6 

1445 Ross Avenue 

Dallas, Texas 75202-2733 . 

Dear Dr. Armendariz: 

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

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

(HGB) area. 

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

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

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

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

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

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

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

Ambient Air Quality Standard by June 15, 2019. 

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

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

Sincerely, 

B ~,;ktw.--· B~haw,PhD. Chairman 

BWS/jmm 

Enclosures 

cc: The Honorable Rick Perry, Governor ofTexas 

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

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

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

Public Hearings 

Odober 28-29, 2009 

Houston-Galveston-Brazoria (HGB) 

Attainment Demonstration SIP Revision 

for the 1997 Eight-Hour Ozone Standard 

Projed Number 2009-017-SIP-NR 

Volume 2 of2 
REVISION TO THE STATE IMPLEMENTATION PLAN 

FOR THE CONTROL OF OZONE AIR POLLUTION 

HOUSTON-GALVESTON-BRAZORIA 1997 EIGHT-HOUR OZONE STANDARD 

NONATTAINMENT AREA 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

P.O. BOX 13087 

AUSTIN, TEXAS 78711-3087 

Houston-Galveston-Brazoria Attainment Demonstration 

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

PROJECT NO. 2009-017-SIP-NR 

Adopted 

March 10, 2010 
xv

LIST OF APPENDICES 

Appendix Appendix Name

Appendix A Meteorological Modeling for the HGB Attainment Demonstration SIP 

Revision for the 1997 Eight-Hour Ozone Standard 

Appendix B Emissions Modeling for the HGB Attainment Demonstration SIP 

Revision for the 1997 Eight-Hour Ozone Standard 

Appendix C Photochemical Modeling for the HGB Attainment Demonstration SIP 

Revision for the 1997 Eight-Hour Ozone Standard 

Appendix D Reasonably Available Control Technology Analysis 

Appendix E Reasonably Available Control Measure Analysis 

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

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

ENVIRON International Corporation 

Appendix G Transportation Control Measures for the HGB Attainment 

Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard 

(Excerpt from Evaluation of Mobile Source Control Strategies for the 

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

Houston-Galveston Area Council, Prepared by ENVIRON International 

Corporation 

Appendix H Voluntary Mobile Emission Reduction Program for the HGB Attainment 

Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard 

(Excerpt from Evaluation of Mobile Source Control Strategies for the 

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

Houston-Galveston Area Council, Prepared by ENVIRON International 

Corporation 

Appendix I Corroborative Analysis for the HGB Attainment Demonstration SIP 

Revision for the 1997 Eight-Hour Ozone Standard 

Appendix J Recommendations for Best Management Practices to Control and 

Reduce Inadvertent Cargo Vapor Emissions in the Tank Barge 

Community 
APPENDIX 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 Reduction Programs (VMEPs) can be granted 

emissions credit in State Implementation Plans (SIP). As part of the SIP, the VMEP as 

identified and described; contains projections of emission reductions attributable to the 

program, along with relevant technical support documentation; commits to monitor, 

evaluate, and report the resulting emissions effect of the 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 voluntary measure, adopting a new voluntary measure, 

or revising the VMEP emission credits to reflect actual emission reductions, provided 

overall SIP commitments are met. For this VMEP commitment, H-GAC interprets this to 

mean that the individual components of the VMEP described here can be adjusted 

according to the funding, technology, or projects 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 the appropriate NAAQS. TCEQ has estimated 

that this 3% limit represents about 2.25 tpd NOx reduction for the 2018 attainment year. 

H-GAC estimated that 2.25 tpd could be attained for the VMEP program with the 

projected funding and organizational administration commitment. 

H-GAC has been administering VMEP programs for many years at least since 2003 and 

has instituted the inter-organization, public/private partnerships, and other arrangements 

to implement the VMEP projects. The funding for these emission reduction projects 

therefore will be derived from a wide variety of sources. H-GAC administers Congestion 

Mitigation and Air Quality (CMAQ), provides 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 outlined in Table 1. The emission reduction 

commitments identified at this time are the 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, and others), alternative 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 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 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 and its partners to 

meet the emission reduction goals that have been set for the region. It would, however, 

indicate that flexibility is needed to determine 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 commitments described in this report. 

Table 2. Weight of Evidence Emission Reduction Measures 

Strategy Description 

Continue current passenger 

vehicle 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 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. 
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- 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 

heavy-duty construction 

equipment 

Idle reduction either through the use of automatic shut-off devices or 

operator training 

This document consists of a general description of the measures that will be taken to 

reach the commitment for the voluntary mobile source emissions reductions program. 

Please refer to the Environ document for a detail description of each control measure. 
F-4 

VMEP Measures Description

Alternative Commuting 

There are various methods for reducing emissions 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, telework, and other employer options 

• Internet ride sharing 

• Vanpool programs 

• Improved low emission transit options 

All of these approaches are being implemented in the HGA nonattainment area and one 

or more of these options will be sufficient 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, parking, congestion, and vehicle miles traveled 

registration or insurance fees. 

Regional Traffic Flow Improvement 

Traffic signalization improvements, reversible lanes and intersection improvements are 

an ongoing part of the H-GAC plan and Transportation Implementation Plan (TIP). 

According to practice in evaluating CMAQ projects, as well as straightforward logic, 

traffic flow improvements encouraged by improved 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 return to about the same flow level as prior to 

the signal or other improvements (although better able to handle higher traffic volume). 

The emissions benefits from these improvements 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 fleet owners in introducing low-emission 

technology into their vehicle fleets (primarily heavy-duty trucks and buses) and their 

fueling infrastructure. Federal funds (Congestion Mitigation and Air Quality – CMAQ) 

are available for eligible projects using approved technology to reduce smog-forming 

 

1 ENVIRON (2009), “Evaluation of Mobile Source Control Strategies for the Houston-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/technology-neutral grant program that funds 

cost-effective engine retrofit, repower, replacement, conversion (to alternative fuels), or 

the establishment of publicly accessible alternative fuel infrastructure. Overhead and 

administrative costs are not eligible for funding. Eligible entities include any public or 

private fleets that primarily operate within the 8-county ozone non-attainment area 

(Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller 

counties). Both light- and heavy-duty vehicles are eligible; however, at this time, off-road 

vehicles are ineligible. Eligible vehicles must spend at least 75% of their operating hours 

within the 8-county ozone non-attainment area, and travel more than 12,000 miles/year. 

As a general rule, the replacement of the heaviest, oldest, and most used diesel engines 

will qualify for the most funding. 

H-GAC has been administering a Clean Vehicles program for several years now, and has 

initiated and completed many projects. Over the 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 emissions from off-road engines centering on 

replacement or retrofit with engines meeting lower emission standards and reduced 

activity especially idling. Table 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 straightening, voluntary fleet turnover 

measures may be implemented. 

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

emissions using a variety of programs providing cofunding incentive to offset the costs 

incurred. One of the most important methods for 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, 2009 
May 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 Potential 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 Emission Control Potential................................................................ 3-1 

Qualitative Review of Feasibility .......................................................................................... 3-2 

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

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

6. LOCAL SUPPORT OF FOR IMPLEMENTATION 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 Evidence 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 detailed evaluations summary................................................ 5-1 

Table 5-2. Non-road measures detailed evaluations summary.............................................. 5-4 

Table 5-3 Weight of evidence measures summary .............................................................. 5-5
May 2009 

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

APPENDICES 

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 Measures 

Appendix B: Written Comments from Stakeholders and their Respective Responses Regarding 

Master List Control Strategies 

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 Measures 

Appendix D: Written Comments from Stakeholders and their Respective Responses Regarding 

Short List Control Strategies 

Appendix E: Overview of the Transportation Control Measures to Be Included as Part of the 

Houston-Galveston-Brazoria Eight-Hour 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 Evaluations for Weight of Evidence Control Strategies 
May 2009 

G:\HGAC\Reports\Final_051109\Sec1_Bkgrd_051109.doc 1-1

1. BACKGROUND AND PURPOSE OF STUDY

This report documents a study performed by ENVIRON International Corporation on behalf of 

the Houston-Galveston Area Council (H-GAC). The study was conducted in support of 

development of an ozone attainment plan. ENVIRON International Corporation, in 

collaboration with subcontractors Earth Matters and Hazel Barbour, provided assistance in 

identifying, evaluating, and documenting mobile emission control measures in an attempt to 

determine a set of strategies to achieve emission reductions of volatile organic compounds and 

nitrogen oxides in the Houston-Galveston-Brazoria (HGB) nonattainment area. 

This initial work involved preparing and qualitatively evaluating a master list of mobile control 

strategies. H-GAC and its stakeholders began with the initial mobile 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 meetings is provided in Appendix A of this report along with a 

summary of written comments and responses supplied by the stakeholders, provided in Appendix 

B. ENVIRON and its subcontractors then reviewed the remaining master list strategies to 

estimate their applicability and potential for inclusion in a regional State Implementation Plan 

(SIP). Once this analysis was completed and a draft short list of quantified mobile control 

measures was assembled, further meetings were 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 received during this time and responses supplied 

by the stakeholders, provided in Appendix D. 

Background

The study was initiated by a request and support from the Texas Commission on Environmental 

Quality (TCEQ) to H-GAC for assistance in developing approvable mobile control strategies for 

the Houston-Galveston-Brazoria area toward attaining the ozone standard by the year 2018. The 

study was initiated to assist TCEQ in the development of the State 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 Houston-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 situation will likely result in changes to the emission 

reductions for the mobile control measures detailed in this report and could result in the 

reassessment of support for those strategies 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, reflect that flexibility is needed to determine 

and implement the most effective emission reduction methods under changing conditions. 
May 2009 

G:\HGAC\Reports\Final_051109\Sec1_Bkgrd_051109.doc 1-2

Anticipated situations which may require a reassessment of SIP control measures include but are 

not limited to: 

1) Changes to State or Federal fuel standards, 

2) Changes to State or Federal 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 overall process to develop the revised Ozone SIP for the year 2018. 

The primary objective of the study was to identify and evaluate feasible mobile 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 identifying 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 stakeholder input into these potential measures, and 

maintain regional planners and government officials in the process. 

Key tasks of this ENVIRON study included: 

1) Reviewing existing mobile emission inventory and previously evaluated 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 presenting findings to technical, policy and 

steering committees, 

7) Developing control strategies and submitting documentation to H-GAC. 

Although H-GAC is the regional transportation planning 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 control measures to include in the State 

Implementation Plan (SIP) submittal for the Houston-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 State 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_051109\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 passenger 

vehicle 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 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. 

Limitations on idling of heavyduty 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- 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 measures detailed in this report were developed 

using methodology in accordance with currently known State and Federal regulations. It is 
May 2009 

G:\HGAC\Reports\Final_051109\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 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 and its partners to meet the 

emission reduction goals that have been set for the region. It would, however, indicate that 

flexibility is needed to determine 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.

Organization of Report

The remainder of this report is organized as follows: 

Section 2, Mobile Control Measure Identification, 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 techniques used in the analysis. 

Section 4, Summary of All Mobile Measures Considered, presents an overview of the qualitative 

evaluation of all suggested measures displayed in tabular format. 

Section 5, Detailed Evaluation of Qualifying Mobile Measures includes summary results of 

quantitative evaluations of voluntary strategies for on-road and non-road mobile sources. 

Section 6, Local Support for Implementation of Mobile Measures details the steps taken to gain 

support for the quantitatively analyzed 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 comments 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 final Short List of Mobile Control Measures. 

Appendix D, presents stakeholder written comments 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 evaluation of each on-road control strategy. 
May 2009 

G:\HGAC\Reports\Final_051109\Sec1_Bkgrd_051109.doc 1-5

Appendix G, presents the quantitative evaluation of each non-road control strategy. 

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

G:\HGAC\Reports\Final_051109\Sec2_CM_ID_051109.doc 2-1

2. CONTROL MEASURE IDENTIFICATION

ENVIRON, in collaboration with H-GAC, used the master mobile source control measure list 

developed in 2006 as a starting point from which to identify measures for the HGB 

nonattainment area Ozone SIP strategies development. H-GAC solicited additional measures for 

the HGB area from local stakeholders including the Regional Air Quality Planning Committee 

(RAQPC) to ensure that all potential emission 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 more than once, although in different ways. 

In addition, many measures that would alone have 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 help 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 refined version of all ideas 

proffered to date to be considered for more detailed evaluation. The general categories included 

such diverse groupings as the clean vehicle programs, pricing measures for on-road mobile 

sources, incentive programs, public fleet measures, 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 was to identify the potential emissions reduction 

of the control measures. As noted, the initial evaluation was qualitative, as it was not feasible to 

model each of the individual control measures. The qualitative review outlined those measures 

that met the minimum criteria for inclusion in the SIP along with information about the affected 

pollutants and implementation considerations related to each measure. 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 section briefly summarizes the approaches and 

assumptions used in this analysis. 

Qualitative Review of Master List 

The primary qualifier for the SIP control measure 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/stateresources/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 retrofitted equipment through the useful life of the 

mobile source affected, but may not include measures 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 administered 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 requirement, EPA also requires that the measures be 

adequately supported by funding sources 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 criteria and the administrative oversight may not be 

obvious from the short description of each measure; 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 emission 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 demonstrate real emission reductions by showing 

funding, oversight, and verification of progress toward the emission reduction goal. For instance, 

the H-GAC Clean Cities and Clean Vehicles Program 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. Therefore voluntary programs may be considered for 

inclusion in a SIP if defined and funded properly. 

Qualitative Review of Emission Control Potential 

The qualitative review of the emission control potential for each measure relies on the basic 

understanding of the emission inventory. Control strategies for mobile sources rely on the basic 

understanding that diesel engines are a significant source 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 vehicles also contribute to the NOx emission 

inventory. Therefore, programs to reduce diesel engine and vehicle emissions primarily affect 
May 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 ranked, 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 summarizes 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. The measures are described qualitatively but not 

ranked in terms of potential benefit or cost effectiveness because inventories have not been 

finalized and often the program’s implementation has not be adequately defined. However, with 

stakeholder input, a list of measures deserving detailed evaluation could be selected from this 

list. 

The measures were not ranked by emission reduction potential for a number of reasons. The 

emission reduction potential depends on the level of implementation in most cases or the 

measure needs of greater detail in order to evaluate the potential. For non-road mobile sources, a 

2018 forecasted emission inventory is not available at this time to provide a relative assessment 

to compare between non-road source emission categories or to compare with those measures for 

on-road sources. Lastly, there has yet to be an emission 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 small reductions might be 

important if implementation is more aggressive than conceived, the source category is of larger 

importance than expected, or if the attainment goal does not require 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 denote which pollutant would be affected by the 

measure. 

Each measure is described in terms of what would be implemented and a further comment field 

discusses the implementation considerations and other unobvious factors affecting the measure. 
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc Table 4-1. On-road vehicle emission reduction measures. 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

1 17 Bicycle and 

pedestrian action groups 

Benefits from bicycle measures include 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. 

Bicycle and 

Pedestrian 

2006 Y + + Reporting requ

meet to claim comparison, dpotential of 20of 5 miles or letimes per wee

2 51 Clean Cities 

Technical Coalition 

An example program might be the NCTCOG program where entities participate in programs to purchase clean vehicles (light or heavy-duty) for their fleets. 

Clean Vehicle 

Programs 

2006 N The strategy, i

yet to be defin

3 54 Private sector clean 

fuel fleets 

This measure is patterned after the H-GAC Clean Cities Program where clean engines (whether alternatively fueled or no) are purchased for fleets to reduce emissions. 

Clean Vehicle 

Programs 

2006 Y + CMAQ funding 

successful proreductions. Sim

4 56 Close loopholes in 

the Texas Clean Fleet Program making fewer exemptions for fleets 

The Texas Clean Fleet Program was repealed by TCEQ, and because the Tier 2 light-duty and 2007 heavy-duty vehicle emissions standards have superceded the original proposal. 

Clean Vehicle 

Programs 

2006 N A revision and 

program needto evaluate the 

5 58 Fleet review, 

procurement and operations policies 

ENVIRON expects that this could be a voluntary version of a Clean Fleet Program where purchases would be directed to cleaner engines. 

Clean Vehicle 

Programs 

2006 Y + See Measure 

6 59 Public agency clean 

fleet program 

Commitment by public agencies to purchase cleanest possible fleet vehicles could be an element in funding or a voluntary commitment. 

Clean Vehicle 

Programs 

2006 Y + See Measure 

7 71 Electric Vehicles This measure is considered to 

include each of various options for the purchase and use of electric (zero emission) light-duty vehicles.

Clean Vehicle 

Programs 

2006 Y + + This measure 

only. 
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

8 99 Area-wide "Steer 

It/Clear It" program 

This program considers quick removal of vehicles from roadway in event of a stall or non-serious accident. The benefits of the program include better traffic flow reducing slow speed operations. 

Freeway 

Incident / 

Roadway 

Construction 

Management

2006 N The benefits o

traffic flow redbut the measupermanent. In incident-relateincluded in the 

9 100 Additional freeway 

service patrol 

Operation of additional lane miles of new roving tow truck patrols to clear incidents and reduce delay on freeways during peak periods. Reduces traffic congestion improving average vehicle speeds. 

Freeway 

Incident / 

Roadway 

Construction 

Management

2006 N See measure 

10 101 SAFEClear - 

Mandatory quick removal of disabled vehicles during peak periods 

Similar to Measures 8 and 9. Freeway 

Incident / 

Roadway 

Construction 

Management

2006 N See measure 

11 115 Cleaner diesel fuel There are diesel fuels that have 

improved performance even beyond the TxLED. This could include cetane additives or gas-toliquids diesel fuels. 

Fuel 

Standards 

2006 Y + EPA evaluatio

http://www.epa

12 127 Air quality 

information with driver training 

Include information on vehicle emissions and air pollution with new-driver and defensive-driving education. 

General Public 

Education and 

Outreach 

2006 N It would be diff

reduction bene

13 144 Divert trucks from 

nonattainment areas 

Require through-traffic trucks to travel around rather than through nonattainment areas. 

Goods 

Movement 

2006 N While this mea

benefits, it woudemonstrate e

14 146 Peak period truck 

bans on freeways and major arterials 

Ban on heavy duty trucks entering or exiting freeways during peak periods. 

Goods 

Movement 

2006 N This measure 

or implement. would through if any, and whincreases elseto hour benefitdifficult to claim 
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

15 147 Permit HOV lane 

use by qualifying low emission vehicles (LEV) 

Vehicles marked as low emitting would be allowed to use HOV lanes as an incentive for greater use. 

High 

Occupancy 

Vehicle (HOV) 

Lanes/Manag

ed Lanes 

2006 N Check HOV la

measure canndifficult to definqualify. It is unbe sufficient to emitting vehicl

16 150 Increase occupancy 

to three or more per vehicle 

Based on a review of the effectiveness of this measure in other parts of Houston (see comment column) the measure could be extended to other freeways. 

High 

Occupancy 

Vehicle (HOV) 

Lanes/Manag

ed Lanes 

2006 N This is a meas

in some parts freeways wherused. If implemented freeways woul

discussed with daily single ocvolumes deter

17 157 Single Occupant 

Vehicles (SOV) access to HOV and transit stations 

Provide direct freeway access to adjoining HOV or transit park-andride facilities to encourage use and expedite access. 

High 

Occupancy 

Vehicle (HOV) 

Lanes/Manag

ed Lanes 

2006 N See measure 

benefit such thqualitative supmodes. 

18 161 Managed lanes to 

accommodate some single occupant vehicles in HOV lanes 

In highly congested corridors where speeds are below 20 miles per hour on freeway lanes, permit limited use of HOV lanes by SOV using tolls or other limiting technique. 

High 

Occupancy 

Vehicle (HOV) 

Lanes/Manag

ed Lanes 

2006 N See measure 

19 163 Focus on finding and 

penalizing extreme high emitters 

(a) Improved remote sensing program, or (b) enhanced enforcement of the I/M program could reduce numbers of likely high emitting vehicles escaping testing through purchase of fraudulent stickers or avoiding the program completely. Penalize fraud not high emitters 

High-Emitting 

Vehicle 

Detection and 

Programs 

2006 N Questionable 

reductions (I/M but could prod
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

20 165 Rewards for 

reporting smoking or high emitting vehicles 

Rewards could be dollars or discounted I/M tests and/or repairs for those reporting smoking vehicles. 

High-Emitting 

Vehicle 

Detection and 

Programs 

2006 N See measure 

21 172 Scrappage/buy-back 

plan 

Monetary compensation for old vehicle scrappage. Increase the range of vehicles and heavy-duty truck engines targeted for replacement credit or subsidy. 

High-Emitting 

Vehicle 

Detection and 

Programs 

2006 Y + + Increased LIR

biennium) has replacement/syears now eligto have failed requires scrapvehicles/engin1998 bus for N

22 181 Dedicated funding 

for school bus replacement 

Clean Cities Clean Vehicle or TERP or EPA funding sources. This program specifically targets school bus fleets that trend toward older models. 

High-Emitting 

Vehicle 

Detection and 

Programs 

2006 Y + Currently usin

Program (SEP

23 186 Non-profit 

organization assistance program 

Investigate opportunities to partner with non-profit organizations to ensure high-emitting donation vehicles are not returned to the road and reused in an "as is" condition. 

High-Emitting 

Vehicle 

Detection and 

Programs 

2006 N Will reduce va

24 188 Enforce smoking 

vehicle reports and require repairs 

Link reports to vehicles' current I/M test status. Require vehicle to be retested. 

High-Emitting 

Vehicle 

Detection and 

Programs 

2006 N May enhance 

reduce smoke I/M test. Currediesels. 

25 191 Low-interest 

financing for low income and/or old vehicle trade-ins 

Financing made available to vehicle owners not eligible for LIRAP replacement option 

High-Emitting 

Vehicle 

Detection and 

Programs 

2006 N See measure 

26 193 Ban sale of highemitting vehicles Vehicles sold within I/M counties must have valid passing VIR High-Emitting Vehicle 

Detection and 

Programs 

2006 N Provides addit
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

27 194 Ban high-emitting 

vehicles in CBD 

Vehicles not allowed through check point if fail remote sensing scan, or if do not have a valid inspection sticker 

High-Emitting 

Vehicle 

Detection and 

Programs 

2006 N Difficult to imp

known about, driven around Additional RS 

28 195 Deny registration to 

vehicles with repeated emission failures 

This measure would require a legislative change. 

High-Emitting 

Vehicle 

Detection and 

Programs 

2006 N Registration a

doesn't subseqLIRAP, could rRecognized E

29 201 Communicate by 

radio best routes through area to avoid congestion 

Improvements of traffic flow would affect average speeds on roadways if there are alternate routes.. 

Intelligent 

Transportation 

Systems (ITS)

2006 N The benefits w

hour making it credit. Alternaand associate

30 202 Information 

telephone hotline for traffic conditions 

Improvements of traffic flow would affect average speeds on roadways. 

Intelligent 

Transportation 

Systems (ITS)

2006 N See measure 

31 207 Provide 

transportation conditions internet site 

Provide hotlink to local transportation conditions website or provide internal web page with transit, traffic, other conditions, schedules and directions to encourage use of modes other than driving alone. 

Intelligent 

Transportation 

Systems (ITS)

2006 N See measure 

32 208 Encourage bicycle 

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

Duplicate or supplemental measure. 

Intelligent 

Transportation 

Systems (ITS)

2006 Y + + See measure 

33 209 Dynamic message 

signs for control of truck movements 

Emissions benefits of truck movements are unclear. 

Intelligent 

Transportation 

Systems (ITS)

2006 N See measure 

34 210 Dynamic message 

signs for freeway traffic control 

Emissions benefits of freeway movements are unclear. Houston area has numerous dynamic message signs in any case. 

Intelligent 

Transportation 

Systems (ITS)

2006 N See measure 

35 211 Real-time display of 

estimated time of arrivals at bus stops 

Provide changeable message signing at bus stops noting ETA of the next buses arriving at the stop.

Intelligent 

Transportation 

Systems (ITS)

2006 N See measure 

unquantifiable on transit mea
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

36 212 Increase system 

surveillance 

The effect of this measure on traffic movements is not well defined. 

Intelligent 

Transportation 

Systems (ITS)

2006 N See measure 

37 214 Limit left turns on 

selected thoroughfares during ozone season 

This measure may show capacity improvements on selected roads allowing for better average speeds.

Ozone Action 

Day / Ozone 

Season 

2006 N May increase 

arterials The erequire develoto be banned, traveled as a rtravel speeds Cost of installi

38 218 Delay high 

emissions producing activities on ozone action days; delay activities for nonozone action days 

The program is ill defined, and any benefits experience in the nonattainment area may be offset by degradation downwind. 

Ozone Action 

Day / Ozone 

Season 

2006 N Involved ozon

to demonstrate strategy. 

39 227 Preferential parking 

for High Occupancy Vehicle (HOV) lane users and ride sharers; Free spaces, reserved spaces 

Incentive for ride sharing and reduced commuting alternative. Alternative commuting options include incentives, penalties, and other encouragements for alternatives to single occupancy vehicle commuting. This measure is for preferential parking incentives and would be one part of the overall program. 

Parking 

Management

2006 Y + + This measure 

a Commute SoIf the measure adding it to the enhancing rideopportunities. 

40 228 Preferential parking 

for High Occupancy Vehicle (HOV) lane users and ride sharers; Rate reduction 

Duplicate measure. Parking 

Management

2006 N See measure 

41 229 Preferential parking 

for High Occupancy Vehicle (HOV) lane users and ride sharers; Metered spaces 

Duplicate measure. Parking 

Management

2006 N See measure 
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

42 231 Free parking at parkand-ride facilities for 

High Occupancy Vehicle (HOV) lane and transit users 

Provide free parking at facilities served by transit; include costs elsewhere or subsidize. Include in weekly or monthly passes. 

Parking 

Management

2006 N Insignificant em

overlap with rioverflow at pacurrent cost st

43 235 Increase parking at 

transit centers or stops 

An incentive to use transit instead of personal vehicles, but not emission reduction measure itself.

Parking 

Management

2006 N Should provide 

discussion due transit centers 

44 236 Use direct ramps to 

connect park-andride lots with freeway system 

An incentive to use transit instead of personal vehicles, but not emission reduction measure itself.

Parking 

Management

2006 N Capital intensi

could be demo

45 237 Locate fringe 

parking and parkand-ride lots on approach routes and interchanges to central and other major business districts. 

An incentive to use transit instead of personal vehicles, but not emission reduction measure itself.

Parking 

Management

2006 N Capital intensi

could be demo

46 240 Provide parking at 

all major transit stations 

An incentive to use transit instead of personal vehicles, but not emission reduction measure itself.

Parking 

Management

2006 N Need to exam

47 241 Commuter parking 

pricing 

No free parking. Price increase would be applied to employees adjusted for vehicle occupancy so that carpoolers would not be subject to increased parking prices. 

Parking 

Management

2006 Y + + Utilize an anal

current price e50% increase parking centeran incentive ra

48 243 Parking space tax or 

surcharge 

Duplicate measure but perhaps a better name. 

Parking 

Management

2006 N Same as mea

49 246 Increase meter fees 

for on-street parking 

Unclear if the current availability and cost would affect vehicle travel. 

Parking 

Management

2006 N Baseline data 

not available. 
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

50 248 Eliminate employee 

parking subsidies 

Duplicate measure. As opposed to traditional parking cash-out, this program would operate on employer-owned parking. 

Parking 

Management

2006 N Determine num

parking spaceproviding themarea-specific acash-out equivfrom renting thother companidescription of 

51 249 Employee parking 

cash-out program 

A monetary incentive to ride share or use alternative commuting options. 

Parking 

Management

2006 Y + + Re-evaluate b

potential for recommuters. Oemission reduEvaluate with 

52 253 Smart Cards pay as 

you go parking 

Unclear if this measure represents an incentive to reduce vehicle travel. 

Parking 

Management

2006 N The incentive 

been identified

53 256 Reduce legal onstreet parking 

spaces in high congestion areas 

Effectively increasing road capacity to reduced stop and go progression improving arterial speeds. 

Parking 

Management

2006 N Increase avera

54 262 Limit peak period 

parking to vehicles with two or more occupants 

Use flextime, but permit only vehicles with two or more occupants to enter workplace parking facilities during peak periods. 

Parking 

Management

2006 N Unless this me

peak traffic wooverall vehicle difficult and themission likely 

55 271 Remove fuel 

subsidies 

Fuel prices and vehicle use have a direct correlation, but the specifics of this measure (price increase) need to be defined. 

Pricing 

Measures 

2006 Y + + The relationsh

vehicle use is recent gasolinresulting effecfuel taxes and 

56 273 Accelerated 

depreciation allowance for employer provided vanpool and bicycle facilities 

Incentive to provide alternative commuting options, but not an emission reduction measure by itself. 

Pricing 

Measures 

2006 N This measure 

determine cosincentives for or bike facilitiesufficient potequantified. 
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

57 275 Congestion pricing 

for major activity centers 

Charge vehicles to enter highactivity centers (retail/business districts, etc.) in cities, with higher prices charged during high-traffic hours. 

Pricing 

Measures 

2006 Y + + This measure 

conclusion wathan 0.01 tpd. many other co

raise a lot of im

58 277 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. 

Pricing 

Measures 

2006 Y + + This measure 

among the hig2006 analysis for the 2008 abeen implemeother areas, aeffect of recenneeds to be evchoice of the abe evaluated. 

59 287 Local or regional fuel 

taxes 

Fuel prices increases. Duplicate to measure 55. 

Pricing 

Measures 

2006 Y + + This is a more 

measure 55. Tbe defined but proportional to 

60 291 Vehicle miles 

traveled - based taxes 

Charge a tax or registration fee by vehicle miles traveled per year. 

Pricing 

Measures 

2006 Y + + Like measure 

measurable apamount of the to determine th

61 295 Increase tolls during 

peak traffic periods 

The application higher costs only during peak hours are likely to have an insignificant impact on regional vehicle travel. The Houston area peak period is too long to permit more than small incremental travel changes outside the peak . 

Pricing 

Measures 

2006 N Based on the 

Houston regioapplicability nobecome more likely to be smnumber of toll would be appl

62 298 No tolls for buses 

and vanpools 

An incentive to use transit instead of personal vehicles, but not emission reduction measure itself.

Pricing 

Measures 

2006 N Possibility that 

would provide employers to p

63 300 Increased speeding 

fines 

Increase amount of fines for exceeding existing speed limits over 45 miles per hour; use additional funds generated to fund vehicle replacement of other emission-reduction programs. 

Speed 2006 N This measure 

MOBILE modedifficult to evalthe effect; for e65 mph would 
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

64 302 Aggressive driving 

enforcement 

 Speed 2006 N This would not 

permanent meMeasure 65 or 

65 304 Lower speed limit in 

urban area to 55 miles per hour 

The MOBILE model estimates lower emissions if freeway free flowing speeds of cars and especially heavy-duty trucks are reduced. 

Speed 2006 Y + This measure 

because it reqapproach wouroads where henforcement p

66 311 Reduce speed to 55 

miles per hour for commercial trucks 

Lower freeway speeds of trucks lower emissions more than lower speeds for light-duty vehicles. 

Speed 2006 Y + Historically, Te

different speed Although it curfor certain free

67 316 Incentives for infill 

and redevelopment 

Several measures to plan communities for lower vehicle travel. This would entail that the development be compact (to encourage walking and bicycling) and convenient to transit. 

Sustainable 

and TransitOriented 

Development

2006 Y + + Evaluate poten

projections of Combine with especially 137"umbrella" me

68 319 Local medical 

facilities 

Increase the number of local “neighborhood” facilities for routine medical procedures 

Sustainable 

and TransitOriented 

Development

2006 N Evaluate VMT 

be a percentagto-other. The from the traverecent trip survinsignificant or reduce commu

69 321 Encourage or 

require complementary uses in close proximity in all developments or development areas 

Apply Planned Use Development (PUD) concept by area, requiring a mix of complementary uses in each square mile or other development area in accordance to a sub-area, locally developed plan. 

Sustainable 

and TransitOriented 

Development

2006 N See measure 

70 323 Comprehensive 

design guidelines for activity centers 

Comprehensive design guidelines for layout of schools, neighborhoods and other activity centers to maximize walkability and minimize the need for shortdistance automobile trips. 

Sustainable 

and TransitOriented 

Development

2006 N See measure 
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

71 324 Locate personal 

business support centers at park-andride facilities (convenience businesses) 

Business location selection results for numerous reasons. 

Sustainable 

and TransitOriented 

Development

2006 N The headway 

too short to justhese facilitiesinstallation and additional ince

72 326 Co-locate event 

centers and major transit centers and stations 

Local event centers at sites of major transit centers to ensure high level of service. 

Sustainable 

and TransitOriented 

Development

2006 N This measure 

very capital intcause a perceutilize transit to events so wortfacilities, but n

73 327 Daycare and other 

services 

Daycare, other convenience services at park-and-ride lots and transit stations. 

Sustainable 

and TransitOriented 

Development

2006 N Many employe

develop a quaemployees witand quantify edriving childrea percentage ocare provided 

74 328 Ban left turns Effectively increasing road 

capacity to reduced stop and go progression improving arterial speeds. 

Traffic Flow 

Improvements

2006 N May increase 

arterials. Evalua database of the additional well as changeincreasing the signs would be 

75 342 Reversible traffic 

lanes 

Increased capacity in commuting direction. 

Traffic Flow 

Improvements

2006 N 

76 350 Local intersection 

signal improvements 

Effectively increasing road capacity to reduced stop and go progression improving arterial speeds. 

Traffic Flow 

Improvements

2006 Y + + Increase avera

77 351 Traffic signal 

equipment or software updating 

Effectively increasing road capacity to reduced stop and go progression improving arterial speeds. 

Traffic Flow 

Improvements

2006 Y + + Increase avera
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

78 352 Emphasis on major 

route traffic signalization; through route traffic platooning 

Effectively increasing road capacity to reduced stop and go progression improving arterial speeds. 

Traffic Flow 

Improvements

2006 Y + + Increase avera

79 354 Real-time traffic flow 

management 

Traffic signals that change timing/cycles to accommodate real-time traffic conditions. 

Traffic Flow 

Improvements

2006 Y + + Increase avera

80 355 Adaptive traffic 

signals and signal timing 

Effectively increasing road capacity to reduced stop and go progression improving arterial speeds. 

Traffic Flow 

Improvements

2006 Y + + Increase avera

81 357 Light emitting diode 

(LED) traffic signal replacement 

It is unclear how this measure could reduce emissions. 

Traffic Flow 

Improvements

2006 N 

82 358 Two-phase signals Traffic Flow 

Improvements

2006 N Increase avera

83 360 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. 

Traffic Flow 

Improvements

2006 Y + + Increase avera

84 366 Prohibit drive-thru 

service during ozone season 

The measure might be difficult or onerous to implement. 

Traffic 

Management

2006 Y + This measure 

that is historica

85 371 Reduce transit fares Incentive to use transit instead of 

vehicles. 

Transit 2006 Y + + Evaluate chan

selected time increases to drevenue would capacity to conresults in a sm

86 374 Peak/off-peak transit 

fares 

Duplicate measure. Transit 2006 N See measure 

87 376 Personalized rapid 

transit 

Duplicate measure. Transit 2006 N See measure 

88 377 Transit schedule 

coordination 

 Transit 2006 N Effect too sma

additional tran
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

89 393 Guaranteed ride 

home 

Incentive for transit use, not a reduction measure itself. 

Transit 2006 N This measure 

enhance ridesrecommended individually. 

90 403 Subscription bus 

service 

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 are far from residences. 

Transit 2006 Y + + A transit enha

attract transit ucustomized tramay be particuthe attainment subsidized thrthe use of fundsuch as VMT tin terms of bot

91 407 Business First 

enhanced buses 

Provide buses with laptop/Internet links, telephone and other business amenities. Similar to measure 90. 

Transit 2006 N An incentive fo

measure by itsmeasure 90. 

92 414 Electrify bus routes Fixed routes with catenary electric 

delivery. This could be a significant change in current operations. 

Transit 2006 Y + Direct emissio

buses. This cbecause the roconsiderations substations), aneed to be con

93 422 Monthly transit pass 

programs 

Already implemented and difficult to predict the increase transit ridership as a result. 

Transit 2006 N Already implem

further reduce 

94 423 Eliminate trips - Free 

transit from remote sites 

This measure is ill defined especially on how reduced vehicle mileage is attained. 

Transit 2006 N This measure 

emission redu

95 424 Provide an off-peak 

unlimited-ride daily pass 

May already be implemented in large measure through the monthly pass program. 

Transit 2006 N Evaluate exten

offered in curr

96 426 Uniticket programs This is an incentive not a vehicle 

travel reduction measure. 

Transit 2006 N Largely includ

program. 

97 428 Simplified fare 

collection 

Difficult to show that this is an incentive for greater transit usage.

Transit 2006 N Not quantifiab

98 430 Public transportation 

- Special fares 

The measure needs to be refined in terms of the incentives and participants in the program. 

Transit 2006 N Not quantifiab

data. 
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

99 433 Accelerate rail 

expansion 

Increase transit capacity. Rail evaluations would need to have specific proposals and market analysis. 

Transit 2006 Y + + If specificity on 

be provided by measure could 

100 436 Commuter Rail Combine regional and light 

passenger rail measures. 

Transit 2006 N See measure 

101 437 High-speed rail Specially designed regional 

passenger rail. 

Transit 2006 N See measure 

102 438 Free circulator 

service to major generators 

Free shuttle/transit service connecting remote areas with major activity generators. Increase transit capacity. 

Transit 2006 Y + + If the descripti

major employmmeasure could Recommend aspecificity with Specificity refegenerators, nuand their frequ

103 441 Provide High 

Occupancy Vehicle (HOV) shuttle between company facilities 

Effectiveness of the measure depends on the number of companies and shuttles operating.

Transit 2006 N Evaluate numb

multiple locatiowith frequent temployees. Th

104 446 Teleconferencing of 

meetings 

The available benefit is unclear. Travel 

Demand 

Management: 

Business 

Operations 

2006 N Evaluate poten

standpoint. Malready to exteand due to advtechnology. 

105 453 Mandated peak 

spreading 

Require business hours to be staggered to spread peak traffic over a wider time period and reduce congestion. 

Travel 

Demand 

Management: 

Business 

Operations 

2006 N The peak in H

other urban artimes). Less ospreading exis

106 459 Mandatory or 

voluntary compressed work week 

The benefits of this program could be included with a variety of commute reduction options. This represents one alternative of the reduced commuting options. 

Travel 

Demand 

Management: 

Business 

Operations 

2006 Y + + This measure 

weekly trips by a mandatory athe latter baseemployer praccompressed w
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

107 460 Subscription buses 

or buspooling 

Duplicate measure. Travel 

Demand 

Management: 

Business 

Operations 

2006 N See measure 

108 461 Internet 

ridematching services 

Real-time ridematching offered via a Website, by an employer, or by a third party (sponsored by city or transportation authority). 

Travel 

Demand 

Management: 

Business 

Operations 

2006 Y + + Evaluate 2008 

NuRide – the cfor H-GAC whmatching for rievaluate the eexpected to grHoustonians oservices such erideshare, etcincreases nee

109 462 Purchase vans for 

vanpools 

Commute reduction along with the opportunity to buy cleaner vans. 

Travel 

Demand 

Management: 

Business 

Operations 

2006 Y + + With or supple

110 463 Mandate or 

encourage vanpooling and carpooling 

One of many commute reduction measures already included in the list. 

Travel 

Demand 

Management: 

Business 

Operations 

2006 N Mandate not fe

already providprogram. 

111 465 Mandatory or 

voluntary flextime program (daily start and end time) 

Temporal allocation of vehicle travel, but not a reduction measure itself. 

Travel 

Demand 

Management: 

Business 

Operations 

2006 N As normally co

employees to Because of the Houston this mquantifiable ef

112 470 Pay or other 

financial incentive for not driving 

Employer pays employees who do not drive a monthly stipend; employees who drive receive no corresponding benefit. 

Travel 

Demand 

Management: 

Business 

Operations 

2006 Y + + It may be more 

measures, parThis type of mconnection witeffectiveness o
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

113 471 Employer tax credit 

or deduction 

Institute a tax credit or deduction for employees that regularly use a non-single occupancy vehicle mode for commuting and/or for employers, based on number of employees that commute using non-SOV 

Travel 

Demand 

Management: 

Business 

Operations 

2006 N Recommend q

respect to imptransportation workplaces arincentives. Burequire survey reduction. 

114 475 Incentives for Best 

Workplaces for Commutes Designation 

Already implementing in Houston Travel 

Demand 

Management: 

Business 

Operations 

2006 N Review status 

funding no lon

115 477 Trade equivalent 

jobs to be closer to work 

For employees of the same company but at different worksites, identify opportunities to "trade jobs" or worksites to reduce commute distance. 

Travel 

Demand 

Management: 

Business 

Operations 

2006 N Employees wh

order to save t

116 484 Personalized travel 

planning 

Based on rider's origin and destination(s), personalized travel plan of transit routes and connections provided via website or telephone service. 

Travel 

Demand 

Management: 

Business 

Operations 

2006 N Difficult to reac

individuals, hasustain that chemissions. Prenhance existmeasures liste

117 487 Telecommuting 

incentives or mandates 

The measure is ill defined and is duplicative of other measures. 

Travel 

Demand 

Management: 

Business 

Operations 

2006 N Mandates not 

measures into from Commute 

118 496 Regional Vanpool 

programs 

Could add more to current Houston vanpooling program, but a duplicate measure. 

Travel 

Demand 

Management: 

Regional 

Applications 

2006 N See measure 

119 499 Share hybrid 

vehicles 

Shared vehicles among a group of owners 

Travel 

Demand 

Management: 

Regional 

Applications 

2006 N No evidence th

emissions beccould be drive
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

120 500 Encourage pooled 

ownership of single occupant vehicles for local midday travel 

Encourage pooled ownership of cars, trucks; e.g., one neighborhood collectively owns an SOV for periodic use. 

Travel 

Demand 

Management: 

Regional 

Applications 

2006 N No evidence th

emissions beccould be drive

121 501 Car Sharing 

Programs (Flexcar) 

Car-sharing programs. We give our members the key to new cars, trucks, and minivans located across a metropolitan region. You pay an hourly rate, and the company pays for the car, insurance, gas and a reserved parking spot! 

Travel 

Demand 

Management: 

Regional 

Applications 

2006 N No evidence th

emissions beccould be drive

122 503 Rideshare matching, 

transit marketing and information programs 

This measure could be included as part of a larger strategy to reduce commuting by single occupancy vehicles. 

Travel 

Demand 

Management: 

Regional 

Applications 

2006 N Reporting requ

measure be a 

123 504 Rewards for 

reducing total vehicle miles traveled in a city or region 

It is unclear how this measure would reduce vehicle miles traveled or how it would be measured. 

Travel 

Demand 

Management: 

Regional 

Applications 

2006 N 

124 551 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 California LEV II program includes new fleet average emissions standards as well as CO2 reductions. A fleets mandate in addition to the Cal. LEV II standards would have a much lower impact. 

Vehicle 

Emission 

Standards 

2006 Y + + TCEQ and sev

the California VOC and NOx http://www.cdp

minutes/2007/

http://www.flch

ergy/DEP_CA7.pdf This wou

125. 
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

125 553 Adopt California 

standards for vehicle emission rates 

Public and Publicly contracted fleet rules or Statewide. 

Vehicle 

Emission 

Standards 

2006 Y + + Benefit small i

PM and CO2 battempts at staII failed. If reqordinance or cneed to be pur

126 576 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. 

Vehicle Idling 2006 Y + Idling reductio

have a small im

127 587 Heavy-Duty Vehicle 

Border Inspection Program for AB 1009 (Pavley 2004) 

HD commercial vehicles engines must meet US HDDV standards in place at the time of manufacture and must display valid emission control label. 

Vehicle 

Inspection and 

Maintenance

2006 Y + Smoke check 

would require remote sensincorrelates with emissions from 

128 589 More frequent 

emissions tests for taxi cabs 

Require taxi fleets to be tested twice per year to get license to operate. 

Vehicle 

Inspection and 

Maintenance

2006 N Allow taxis ove

LIRAP (c.f. cuvehicles) to pr

129 592 Augment truck and 

bus highway inspections with community-based inspections (HDV8) 

HD vehicles are inspected to detect mal-maintenance and tampering and to measure smoke emissions in mixed-use communities. 

Vehicle 

Inspection and 

Maintenance

2006 Y + MY 93-98 refla

reductions alreemissions modeasy to implemNOx reduction

130 594 Addition of HDGV2B 

weight class vehicles to inspection and maintenance program 

The inspection criteria would need to be defined more precisely for these vehicle types. 

Vehicle 

Inspection and 

Maintenance

2006 N Pre MY 96 veh

Would need to dynos. OBDII 

131 598 More frequent 

testing for vehicles that repeatedly fail inspection tests 

EPA has not quantified the benefit of more frequent testing. 

Vehicle 

Inspection and 

Maintenance

2006 N No modeled b

these vehicles least require reRepair Facility

132 601 Extend or expand 

light-duty diesel engine inspection and maintenance program 

The technology has yet to be defined for inspection of these vehicle types. 

Vehicle 

Inspection and 

Maintenance

2006 N Impractical to 

cut points ava
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

133 604 If the largest city in a 

county takes part in a testing program, the entire county must opt-in. 

Current I/M legislation for nonattainment areas is based on counties. EAC area requirement is for county along with the largest municipality. 

Vehicle 

Inspection and 

Maintenance

2006 Y + + The benefits a

counties not a

134 623 Mandated no drive 

days 

An extreme measure to prohibit vehicle travel include only if needed. 

Vehicle 

Operations 

Management

2006 Y + + Important to ev

last resort mea

135 628 Voluntary no drive 

day programs 

Such a voluntary vehicle travel reduction program needs to be defined more precisely. 

Vehicle 

Operations 

Management

2006 N This would be 

of individuals vwould require benefit. 

136 629 License plates 

determine access to vehicle use (odd/even driving days) 

Duplicate measure. Vehicle 

Operations 

Management

2006 N See measure 

137 630 Encourage/Mandate 

Livable Centers 

Includes a host of ideas to reduce vehicle travel. 

Sustainable 

and TransitOriented 

Development

2008 Y + + Combine with 

one package oplanning. Evalspreadsheet-bby H-GAC for scenarios defiH-GAC and citdifferent spreacurrently avail

138 631 DPS-like emissions 

sensors in HCTRA toll booths - enhanced smoking vehicles program 

Program is ill defined in terms of the technology and how it would interact with the current inspection program. 

Vehicle 

Inspection and 

Maintenance

2008 N If we are looki

remote sensinFor smoke, hig

139 632 Enhanced 

enforcement for Smoking Vehicles Program - vehicle impounding for violators (like Dallas Emissions Enforcement Pilot Program) 

Link to I/M test status: encourage local police to enforce existing smoking vehicle legislation 

High-Emitting 

Vehicle 

Detection and 

Programs 

2008 Y + May reduce nu

test. Real versNCTCOG esti80% not 96% 
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

140 633 Limit left turns on 

selected thoroughfares at all times 

Duplicate measure. Traffic Flow 

Improvements

2008 N See measures 

141 634 Higher registration 

fees for high emissions vehicles 

The measure needs to be refined to include emissions standards and emitter status. 

Pricing 

Measures 

2008 N The implemen

addressed carand inspection 

142 635 Prime parking for 

vanpools/carpools/hybrids 

Duplicate measure. Parking 

Management

2008 N See measure 

143 636 Hybrid cars parking 

meter fee exemption 

Hybrid light-duty vehicles cannot demonstrate much emission reduction, and this measure merely provides an incentive for their use. 

Parking 

Management

2008 N Hybrid vehicle

standards as o

144 637 Use of taller highway 

barriers to reduce “rubbernecking” 

This measure would affect free flowing vehicle speeds. 

Freeway 

Incident / 

Roadway 

Construction 

Management

2008 N The benefits o

demonstrate. 

145 638 Increased use of 

hybrid buses 

Hybrid heavy-duty vehicles have been funded to date in current air quality programs. 

Transit 2008 Y + Benefits of this 

is relatively coemissions redconsumption is operator. 

146 639 Initiate a flexbike 

service to encourage bicycling 

Duplicate measure. Bicycle and 

Pedestrian 

2008 N See measure 

147 640 Creation of regional 

government idling restriction MOU 

Idling is usually a small portion of the emissions from vehicles. 

Vehicle Idling 2008 Y + + Demonstration 

148 641 Industry idling 

restrictions 

Idling is usually a small portion of the emissions from vehicles. 

Vehicle Idling 2008 Y + + Demonstration 

See measure 

149 642 More stringent I/M 

cut points 

Cut points only relevant to MY 95 and older vehicles, number of which reduces considerably each year, making this less effective. 

Vehicle 

Inspection and 

Maintenance

2008 Y + + Decreasing be

each calendar encourage mo
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID 

Old 

ID Control Strategy Description Category 

Year 

Added 

EPA 

PQSE VOC NOx 

150 643 Accelerate 

development and construction of mass transit projects 

Capacity improvements to mass transit combined with other bus and rail measures. 

Transit 2008 N Very capital in

agencies in teincreases. 

Table 4-2. Non-road vehicle emission reduction measures. 

ID Control Strategy Description 

Year 

Added

EPA

PQSE VOC NOx C

1 Aircraft emission standards New emission standards for aircraft 

engines fall under international and Federal rules. 

2001 N These are covered by in

local measure would no

2 Ordering lowest emission 

engines 

Fleet management of aircraft flying into HGB. 

2001 N These are covered by in

local measure would no

3 Changes in general conformity to 

make provisions more realistic; Allow equipment turnover to count 

General conformity is a criteria to meet by new projects and not included in SIPs 

2001 N This is not an emissions 

should be taken for low

4 Modify regulations so credits can 

be generated for general conformity 

General conformity is a criteria to meet by new projects and not included in SIPs 

2001 N This is not an emissions 

5a Enhanced Texas Emission 

Reduction Program (TERP) 

The TERP program has been responsible for significant NOx reductions to date 

2005 Y + The TERP program cou

realities of emission conother mobile source catstandards that have bee

5b Extend TERP to 2018 Current TERP legislation provides 

funding for the program until 2012. 

 Y + Proactively extending th

ensure that this funding region is required to me

6 Aftermarket Technology and Fuel 

Additive Research Program 

EPA approval of aftermarket and fuel technologies would be necessary. 

2001 N Fuel additives not credi

creditable, if they pass may include cetane impneed to be better definereductions creditable fo

7 Improve inventory of construction 

equipment; Log hours of actual equipment operation 

Activity reduction of nonroad equipment. 

2001 N Equipment activity redu

a reduction occurred anconsidered permanent. 
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID Control Strategy Description 

Year 

Added

EPA

PQSE VOC NOx C

8 Government construction 

incentives 

This measure is considered to include money, tax relief, or proposal preference to firms using clean equipment. 

2005 Y + Incentive for the use of 

has been attempted incthe reporting requiremebenefit lead to less use benefits than were expe

9 Develop air quality best 

management practices (BMPs); Use BMPs to manage emissions from construction sites, construction vehicles & wind-blown dust 

The BMP could include a clean equipment use clause. 

2005 N The program needs to b

use and types of equipmreporting burdens to juswould be onerous. 

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

operator training. 

2005 Y + Many states have regul

idling. The benefits of thupon the implementatio

programs, but generally small but cost effective. 

11 Water injection for diesel engines Engine and Fuel Technology 2001 Y See 5 TERP, measure 12 Alternative-fueled equipment for 

all equipment types 

Engine and Fuel Technology 2001 Y See 5 TERP, measure 

13 Alternative fuel heavy-duty 

equipment 

Engine and Fuel Technology 2001 Y See 5 TERP, measure 

14 Lean NOx catalyst Engine and Fuel Technology 2001 Y See 5 TERP, measure 15 Early introduction of low-NOX 

engines 

Engine and Fuel Technology 2001 Y See 5 TERP, measure 

16 Selective catalytic reduction 

(SCR) 

Engine and Fuel Technology 2001 Y See 5 TERP, measure 

17 Compression ignition standards 

for vehicles and equipment 

Engine Standards 2001 N EPA has already implem

nonroad equipment. 

18 Spark ignition standards for 

vehicles and equipment 

Engine Standards 2001 N Small and large spark-ig

by EPA rulemakings. 

19 Lower sulfur fuels Fuel Standards 2001 N No VOC or NOx benefit b

sulfur gasoline by 2004, off-road diesel by 2012. 

20 Texas Low Emission Diesel 

(TxLED) 

Fuel Standards 2001 N Implemented 

21 Lawnmower exchange; Trade in 

old gas powered equipment for discounts on zero emission models 

A retirement program for old and malfunctioning lawn and garden equipment. 

2005 Y + The benefits of such a pr

focus primary on VOC rerestricted to lawnmowers equipment such as smalThe overall benefits woucould be cost effective. 
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID Control Strategy Description 

Year 

Added

EPA

PQSE VOC NOx C

22 Lawnmower recycling programs 

(rebate program); replace gas mowers with electric 

Duplicate measure. 2005 Y See 21 

23 Promote use of cleaner lawn and 

garden equipment such as loweremission four-stroke and electricpowered equipment 

Duplicate measure. 2001 Y See 21 

24 “Buy a Clunker” concept for small 

gas equipment 

Duplicate measure. 2001 Y See 21 

25 Disincentives such as fines if 

caught mowing during Ozone Alerts 

Operational restriction. 2001 N This is not a permanent 

demonstrate complianc

26 Ban equipment such as twostroke engines Operational restriction. 2001 N This would preempt Fed27 No-mowing days Operational restriction. 2005 N This is not a permanent 

demonstrate complianc

28 Grass cutting; Public works will 

delay cutting grass till 6 pm on ozone action days 

Operational restriction. 2005 N This is not a permanent 

demonstrate complianc

29 Landscape ordinance for 

nonresidential areas 

This measure would need to be included in permits, building zoning, or municipal rules. 

2005 Y + This measure refers to 

that reduces the need fosuch as lawnmowers anconsumption as well. Thdifficult to administer an

30 Use of auxiliary power units 

(APUs) for locomotives operating; Controls for locomotives are preempted by Federal law, but voluntary controls might have some success 

This measure is equivalent to an antiidling measure either through the use of devices or operator training. 

2005 N Automatic idle shut-off d

equipment. This measularger railroads on a voefforts. 

31 Accelerated purchase of Tier 2, 

3, and 4 locomotive engines or remanufactured existing locomotives 

An accelerated fleet turnover measure would need to be implemented on a voluntary basis because of federal preemption. 

2005 Y + This measure has been 

existing and future locoa remanufacturing provoperation today. The ruquickly with incentives freplacement of older enprogram. 

32 Electrification of rail Rail electrification is nearly 

exclusively a passenger rail option, such as the Houston light rail line. 

2005 N This option may be ava

other passenger rail optreductions would be les
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID Control Strategy Description 

Year 

Added

EPA

PQSE VOC NOx C

33 Efficiency improvements on InUse Class 1 Rail Equipment 

(R11) 

This measure would improve rail connections, eliminate at grade road and rail crossings. 

2005 Y + Rail improvements migh

shown that locomotive ireduced. Usually these and congestion relief be

34 Limitations on idling of 

locomotives 

Duplicate measure. 2005 N Automatic idle shut-off d

equipment and reductioSimilar to measure 30. 

35 Portable engine fleet turnover This measure addresses nonroad 

engines assigned to a specific industrial facility. 

2008 Y + Includes registration an

equipment to more recesmall portion of the noncategories. http://www.arb.ca.gov/p

36A Low Sulfur Fuel for Marine 

Vessel Main and Auxiliary Engine 

Low sulfur fuels provide a modest NOx reduction with large particulate and SOx emissions reductions. 

2008 Y + California is proposing t

Port of Los Angeles as http://www.arb.ca.gov/p

m

36B Harbor Craft Fleet Management Harbor craft include tugs, ferries, 

supply, excursion, and other smaller commercial marine vessels. The measure would seek to accelerate the fleet turnover to remanufactured existing and Tier 3 and 4 engines. 

2008 Y + The California rule if fin

proposed format would turnover of harbor craft emission standards. Covoluntary measure to rehttp://www.arb.ca.gov/p

37 Cargo Handling Equipment Fleet 

Management 

Cargo handling equipment includes nonroad equipment used at intermodal (ports and rail) facilities to move freight. The California rule includes retrofit or fleet management with the use of newer engines to comply. 

2008 Y + Encourage accelerated 

used at ports and intermhttp://www.arb.ca.gov/p

38 Clean Fuel Option: Expand 

TxLED Use. 

The use of TxLED could occur in source categories not currently required to implement the fuel use including marine and other engines. 

 N The use of TxLED is alr

marine and locomotive affected by the Texas rehttp://www.tceq.state.tx

diesel.html#Draft

39 Provide full funding for the 

National Retrofit Program 

EPA has set up the mechanism for providing grants to reduce emissions from off-road equipment under the National Clean Diesel Campaign, http://www.epa.gov/cleandiesel/

2008 Y + The funding varies by y

competitive from all statrelatively small when ap
May 2009 

G:\HGAC\Reports\Final_051109\Sec4_Sum_051109.doc 

ID Control Strategy Description 

Year 

Added

EPA

PQSE VOC NOx C

40 Allow private companies to apply 

for NRP grants 

Clean equipment grants program. 2008 Y + Further investigation int

required to determine thare determined by EPA

41 Allow NRP grants to cover 

incremental costs for TERP or CMAQ retrofits 

Supplemental funding for other existing funding programs. 

2008 N The use of TERP funds 

possible, but would makapplications more compstate funding however dreduction. 

42 Establish emissions trading 

program for nonroad vehicles (DERC) 

Emission trading for stationary sources applied to mobile sources. 

2008 N Verification of emission 

difficult. 

43 Allow use of TERP funds for 

administrative costs. Specifically, this can be used to help small companies without the time or resources to apply and track retrofits 

TERP revisions. 2008 N The TCEQ would find th

review of the enabling leto determine if TCEQ is administrative funding. not reduce emissions. 

44 Provide cooperative grant 

assistance to encourage small companies (<20 employees) who do not have the resources to manage grants alone to apply for TERP 

TERP revisions. 2008 N This measure might be 

staffing at TCEQ or the The emission reduction with increase participatiitself. 

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. 

Clean Port initiative including on-road and nonroad source categories. 

2008 Y + A port related approach 

reductions, but the progdefined. The strategies measures listed. 

46 Adopt policies and programs to 

increase the number of clean construction machines used on public works projects. 

Clean construction equipment. Duplicative measure. 

2008 Y See Measures 8 and 9 
May 2009 

G:\HGAC\Reports\Final_051109\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 that qualify as emission reduction measures under 

EPA guidance by the 2015 – 2018 time frame. The master 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 measures 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 which 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 summaries with full descriptions of the measure, 

implementation issues, public reaction, and analysis 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 

ID Control Strategy Description ($/ton) 

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 $2,100k 
May 2009 

G:\HGAC\Reports\Final_051109\Sec5_Eval_051109.doc 5-2 

Emission 

Reduction 

Potential (tpd) 

Cost Effectiveness 

ID Control Strategy Description ($/ton) 

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 $18k 
May 2009 

G:\HGAC\Reports\Final_051109\Sec5_Eval_051109.doc 5-3 

Emission 

Reduction 

Potential (tpd) 

Cost Effectiveness 

ID Control Strategy Description ($/ton) 

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 $350k 
May 2009 

G:\HGAC\Reports\Final_051109\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 equipment 

such 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 minimize 

emissions 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 

Controls 
May 2009 

G:\HGAC\Reports\Final_051109\Sec5_Eval_051109.doc 5-5 

Table 5-3. Weight of evidence measures summary.

ID Control Strategy Description 

OR* 

21 

Continue current passenger 

vehicle 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. 

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- vehicle 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 measure 
May 2009 

G:\HGAC\Reports\Final_051109\Sec6_LocalSup_051109.doc 6-1

6. LOCAL SUPPORT FOR IMPLEMENTATION OF MOBILE MEASURES 

Throughout the development of the final control strategy short lists H-GAC worked with 

Houston-Galveston-Brazoria area government and business stakeholders not only to develop 

appropriate control strategies to meet the SIP requirements, but also to recruit stakeholders 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 Meeting with Tug Boat Operators, 

- December 8, 2008: Stakeholder Public Meeting, 

- December 15, 2008 Stakeholder Meeting with Construction, 

- December 15, 2008: Stakeholder Meeting 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 Meeting with Airports and Airlines, 

- January 8, 2009: Stakeholder 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 with Harris County Fleet Managers, 

- January 27, 2009: Stakeholder Meeting 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 Montgomery 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-road sources. Communications 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 will continue to pursue these 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 Measures 
G:\HGAC\Reports\Final_051009\Appendix A_051009.doc -1

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 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 Lubertino (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 information 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 industry 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 the 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 flights. 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 may be hard to quantify. H-GAC recommended 

sharing information with TCEQ because there may be methods for quantifying those 

efforts, or ways may be found to do so if the 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 stakeholders 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 presentations have not been given despite 

efforts on the part of H-GAC and airport-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 (Williams Brothers), Jeff Greene (Durwood Greene 

Construction), Dale Kornegay (BorTunCo), Peck Boswell (BRH Garver Const.), Herb Young 

(Smith & Company), AP Boyd (AGC of Texas), 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 Brown (TCEQ), Anusuya Iyer (TCEQ), 

Charles Airiohuodion (TxDOT), Shelley Whitworth (H-GAC), Graciela Lubertino (H-GAC), 

Andrew DeCandis (H-GAC), and Kelli Angelone (H-GAC). 

TCEQ presented information concerning the emissions inventories for the construction industry 

for the years 2000, 2002, and 2005. H-GAC presented information on the suggested construction 

mobile control strategies and also on third-party TERP grants. 

 Comments and concerns included: 

1) Industry representatives asked if the entire Non-Road Draft Master Control Strategies list 

could work as a VMEP. TCEQ and H-GAC replied 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 improvements for the industry need to be short-term 

research that brought technologies 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 industry; 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 some 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 Williams (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 emissions 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 grant, that H-GAC is going to be awarded, be 

available for other groups beside the ones that requested it? Parties not listed on thirdparty TERP grants are still eligible to apply for those funds. 

2) Proposal of a control strategy to help railroads in the Houston-Galveston-Brazoria region 

obtain auxiliary power units would not be helpful because they are only effective for 

railroads in cold climates. 

3) The larger railroads have idle-reduction technologies 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 TCEQ’s eligibility formulas 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 (WGMA), Owen Parker (Dannenbaum), Charles 

Airiohoudin (TxDOT), Christine Harris (Kinder Morgan), Kevan McGregor (Shell), Jim Guidry 

(Kirby Corp), Lisa McMicheal (Port of Freeport), Stuart Mueller (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 emissions inventories for the ports industry for the 

years 2000, 2002, and 2005. H-GAC presented information 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 available to those in the 

ports industry, rendering that suggested control strategy obsolete unless it needs to be 

documented. 

2) General concern was expressed regarding the clarity of the control strategies and 

industry’s ability to provide meaningful comment. H-GAC has since then ‘cleaned up’ 

and offered further guidance and description 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 emissions inventories for the ports industry for the 

years 2000, 2002, and 2005. H-GAC presented information on the suggested ports mobile 

control strategies and on third-party TERP grants. H-GAC mentioned that the marine sector had 

the largest projected growth in regional NOx emissions. 

Comments and concerns included: 

1) Industry representatives asked TCEQ 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 projected growth data from the ports would be skewed because 

most industry growth would be on the trucking side. H-GAC wondered if projected 

growth was still available because that data would be helpful for inclusion in the 

emissions inventories. 

3) One example put forth by H-GAC as an emissions reduction technology was ship stack 

scrubbers. Industry representatives said that was a good example but scrubbers do not 

reduce NOx particulate matter. 

4) Industry representatives mentioned the California law governing foreign ocean-going 

vessels and their emissions was overturned by the Supreme Court. 

5) Two control strategies industry inquired about were the “California Marine Vessel Main 

and Auxiliary Engine Rule” and the “California Harbor Craft Rule”. H-GAC explained 

that these were included by TCEQ at a previous meeting. It was added that industry 

might want to enter into a Memorandum 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 strategies 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), Don Brandon (Chambers County), Marie 

Herndon (City of Prairie View) 

Staff members present: Brian Christian (TCEQ:SBLGA), Theresa 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 photochemical modeling that is used in the HGB 

nonattainment region. TCEQ also gave a presentation about the purpose and services available 
G:\HGAC\Reports\Final_051009\Appendix A_051009.doc A-2 

for local governments and small businesses through 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 transportation 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 concentration 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 because it is in the HGB region and closely tied 

economically and geographically to the counties, 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 noncompliance with government law in the SIP? 

Yes. The paperwork involved with the SIP 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 industrial mobile non-road sources and the timeline for 

SIP submission. For the industrial equipment emission estimations, the inventories take into 

account EPA programs and regular fleet turnover; so accelerated turnover 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%. Forklifts 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 timeline for the development of the mobile source 

control strategies for the SIP. 

HGAC cannot mandate reductions and must rely on voluntary emission reductions 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 voluntary 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 asked about the information sources for the inventories 

generation, to which TCEQ answered that they 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 (mostly gasoline engines), but 

they will find out. 

3) TCEQ stated that the distribution 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 businesses 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 figure out how to make up those reductions with 

another of our programs. 

6) Are there any other control strategies for ‘Industrial Mobil’ besides electric forklifts? 

There are control strategies that involve cleaner 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 allowed 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 like DERA? There is concern that with the 

new regions that will be drawn by EPA and 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 funding, but we missed the proposal deadline for 

DERA. It’s important to remember that agencies such as HGAC must also find places to 

supply administrative funding as well, which is a huge challenge in itself. 

9) Can private industry make use of TERP? 

H-GAC is planning to help with TERP funding by using the third-party agreement. 

10) What about the requirement in TERP about destroying vehicles? It is a lot of capital to 

lose and turn over in a short time (TERP requires you buy new vehicles and destroy the 

old vehicles within 90 days). 

If you are interested in committing to accelerated fleet turnover, we cannot help you fund 

it if you do not destroy the engines or vehicles, 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 Strategies
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-1 

The comment periods for the Draft On Road Control Strategy List and the Draft Non Road 

Master Control Strategy List was Friday, May 23, 2008 to Tuesday, August 5, 2008. Written 

comments were received by: 

Mail: Transportation Department, Air Quality 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 Issues, 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” table. 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_051009\Appendix B_051009.doc B-2 

B.1.1.1 Comment from BNSF 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 locomotive operations to reduce idling 

Note that auxiliary power units (APUs) are best suited for use in colder climates. BNSF typically 

deploys the APU units on switch engines that operate in areas such as Chicago and Denver. For 

example, the EcoTrans K-9 APU is used to provide electrical power to immersion heaters for 

lube oil and the main engine water. The south Texas climate would minimize the use of the 

APU. In the colder, winter months, the APU would 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. Currently, 15 switch engines have ZTR SmartStart units installed. 

The SmartStart unit monitors the “health” of critical 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 temperature, the main engine is restarted instead of 

using a smaller engine to provide auxiliary electrical power or heat. 

As information, all new line haul locomotives that BNSF is purchasing come with idle reduction 

technology installed at the factory. 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 locomotives will begin. Tier 4 

locomotives, employing catalytic after treatment technology 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 removed 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_051009\Appendix B_051009.doc B-3 

H-GAC ID Number 32 – Electrification of Rail Switching Yards 

The electrification of rail facilities is not practical for several reasons. First, the cost of 

undertaking such an effort would require massive expenditures of capital 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. Second, there is no large scale production of high 

horsepower locomotives that use external electrical power. Lastly, the implementation of this 

strategy would take many years to fully implement. 

HGAC ID Number 33 – Efficiency Improvements on In-Use Class 1 Rail Equipment 

BNSF requested further clarification from HGAC on this implementation 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_051009\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 regulation. We applaud TCEQ, the Council of Governments, and the 

business community for all the efforts to reduce 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 effective implementation of the rules as they are 

currently drafted. The concerns include rail safety issues, employee productivity, preventing 

locomotive freezing, unnecessary requirements when we already are reducing emissions, and 

extreme recordkeeping requirements. The ramifications 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 Administration (FRA) requires that the braking 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 pressure air is supplied by a compressor that is 

powered by the locomotive engine. Depending on the length of train, it could take at least an 

hour of engine idle time to generate enough air pressure 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 into the path of other trains, cars or locomotives. 

Every time that a switch engine is shutdown, BNSF 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 several of the cars must also be 

engaged. This is a laborious process that involves spinning a large wheel that activates the 

brakes. When the switch engine is started again for movement, the process has to be reversed. 

The increased physical exertion on employees required to set brakes dozens of times during an 

eight hour shift could possibly lead to safety concerns. 
G:\HGAC\Reports\Final_051009\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 power 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 unnecessary discomfort and danger during periods of 

abnormally cold weather. 

Reduced Rail Facility Productivity 

As was shown above, the act of shutting off a switch engine is not as simple as pressing a button 

and “walking-away.” Even the smallest engines 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 turned off and isolated while others must be left 

on or closed. According to BNSF 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 take 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 the shutdown procedure dozens of times per day, 

causing significant delays to the movement of freight. 

Trains that operate on our network have critical, highly sensitive time schedules that require 

strict adherence. This allows BNSF to maximize the utilization of its infrastructure and train 

crews. If a train can not leave a terminal due to congestion caused 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. Worth may be assigned to another train leaving 

Amarillo when it arrives. If the train from Ft. Worth 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-attainment area, and actually increasing locomotive 

emissions instead of decreasing them. 

Locomotive Freeze Protection 

Unlike most internal combustion 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 water 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, causing significant damage. Because of this, locomotive engines are 

equipped with an automatic dump system for the radiator water when it nears the freezing point. 
G:\HGAC\Reports\Final_051009\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 idle 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 addressing this issue by adding after market idle 

control technology to a number of switch engines. 

TERP Funded Idle Reduction Equipment 

BNSF applied in 2003 for funding under the Texas Emissions Reduction Program (TERP) for 

the installation of idle reduction technology on approximately 30 switch engines in the DFW 

area. The application was successful and $333,000 was granted. 

The switch engines are being equipped with the ZTR SmartStart system. With this technology, 

several critical locomotive operating parameters, such as air pressure and cooling water 

temperature, are continuously monitored by the ZTR system. If all of the parameters are within 

an acceptable range, the locomotive is automatically 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 have 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 engines 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 installed 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. This technology primarily addresses unnecessary 

locomotive idling that occurs. 

Increased Recordkeeping Requirements 

The recording of every shutdown event for every 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 this information really is necessary, 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 locomotives to Tier 0 levels. This reduces the nitrogen oxide 

emissions by 33 percent from the uncontrolled levels. 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 train resistance and thereby reduces emissions from 

the engine. 

Conclusions 
G:\HGAC\Reports\Final_051009\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 SmartStart idle reduction units installed. This 

equipment is designed to identify unnecessary idling 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 locomotives will be used in and through the DFW area. 

BNSF, with assistance through the TERP, will bring four hybrid switch engines into use in the 

DFW area, which will lead to eliminating four older traditional switch engines. 

With these technological improvements and additions, 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 and 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_051009\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 the mobile source control measures for the 

Houston-Galveston-Brazoria 8-Hour Ozone State 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 will 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 older 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 will already be counted on 2018 

inventories. This analysis will be made during the latter part of this year. 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-9 

Throughout the latter part of 2008, H-GAC will work 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 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.hgac.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 willing to make their own commitments to reduce air 

pollution within the 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 Manager
G:\HGAC\Reports\Final_051009\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 viability according to EPA. We 

submit the Marine Exhaust Scrubber (exhaust 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, Environment 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 guidelines 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 questions 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.com
G:\HGAC\Reports\Final_051009\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 the mobile source control measures for the 

Houston-Galveston-Brazoria 8-Hour Ozone State 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 control strategies. We have considered your request 

and have added this measure to the Final Master List which is being submitted to TCEQ. 

Throughout the latter part of 2008, H-GAC will work 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. 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 willing to make their own commitments to reduce 

air pollution within the 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 Manager 
G:\HGAC\Reports\Final_051009\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, shelley.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 improvements for our community, region and 

state. The Port Authority was an active participant in assessing and assisting 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 measures 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 through voluntary measures and continues to be 

supportive of the TERP program. 

Specific Listed Control Measures 

Below are some specific comments on control measures identified by H-GAC in the short list. 

These comments are based on what the Port Authority gleaned from the description provided in 

the spreadsheet and through a limited amount of research conducted 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 TERP funding; however, some could 

have significant operational, technical, 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 projects and will continue to participate in such projects in the 

future. The Port Authority believes this program is the most successful method at finding costeffective emission reductions for non-attainment regions. The Maritime Industry has had 
G:\HGAC\Reports\Final_051009\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 development of this program to create a more userfriendly application and reporting process for all interested parties. 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 limitations in the manufacturing 

industry and funding process of the program. 

#31 – Accelerated Equipment Turnover; Tier 2 or Tier 3 Non-road Engines 

The Port Authority has been accelerating equipment turnover through its own initiatives through 

the purchase of Tier II equipment at the Barbours Cut and Bayport Container Terminals. The 

Port Authority supports the accelerated 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 expressly prohibits state or local rules that impose 

emissions control standards on new non-road engines. The Act implicitly extends this 

preemption to all other non-road engines (new and old), and provides that only California may 

apply to EPA for authorization to adopt and enforce standards or controls (at least as protective 

as federal standards) governing such engines or equipment. A state with an approved nonattainment plan may thereafter adopt standards identical to California’s, after notice to EPA and 

a statutorily required two-year 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 the 1-hour SIP. The rule was challenged by the 

Engine Manufacturer’s Association in the U.S. District Court for the Western District of Texas 

(Engine Manufacturers Association v. Robert 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 deprives the state of jurisdiction over such matters. At the same time, 

the rules were replaced legislatively with TERP. 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 significantly relevant court decision, the U.S. Supreme Court overturned local air 

rules that would have required certain private fleet operators in the greater Los Angeles area to 

purchase or lease low-emitting or alternative-fuel vehicles when adding or replacing fleet 

vehicles (Engine Manufacturers Association v. South 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 (there was not a requirement to accelerate the 

retirement and replacement of older, more polluting vehicles). The Supreme Court concluded 

that the rules were emissions standards and preempted under the Clean Air Act. The Court was 

not willing to draw a distinction between regulations that compel manufacturers to meet new 

emissions limits (e.g., mandate the sale or production of certain types of vehicles 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 emissions characteristics of an automobile. 
G:\HGAC\Reports\Final_051009\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 listed 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 extent 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 sizes. Below is a California Air 

Resources Board (CARB) list of CARB certified alternative fueled off-road engines. 

Since alternative fueled engines are not available in larger engine sizes, the use of such engines 

is restricted to equipment such as forklifts and yard hustlers. Although alternative fueled engines 

for yard hustlers are available, the Port Authority understands that the technology does not make 

practical sense for this application. Using an alternative fueled yard hustler requires more 

frequent refueling, adds significant 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 new 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 unit, the extra maintenance 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 cost of the alternative fuel 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 catalytic reduction (SCR) technology. The Port Authority would like to 

express its concern over this control 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 engine 
G:\HGAC\Reports\Final_051009\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 and operation; 

• A significant legal impediment exists regarding the adoption of a NOx reduction systems; 

and 

• The compatibility of NOx reduction systems with other control strategies such as diesel 

emulsions, fuel additives, etc. has not been evaluated. 

It is the Port Authority’s understanding that only one SCR has been verified to date —and that 

verification only applies to one engine size. The SCR is manufactured 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 verification, the Port Authority has significant reservations about the 

viability of SCR on equipment operating with transient loads. The Port Authority’s experience 

with an SCR was burdened with significant operational problems. 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 loading 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, replacement of injectors, and urea. 

In addition to technical problems, HGAC and TCEQ 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 adopting 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 this issue, it is apparent that a control 

measure requiring an equipment operator to achieve a certain emissions level by using an SCR or 

other type of emission control 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 Best Management Practices 

The Port Authority already includes extensive environmental conditions in its new construction 

contracts. The Port Authority has spent millions of dollars to minimize air quality construction 

impacts. Some of the best management practices have included clean engine technologies, 

cleaner fuels/additives, extensive dust suppression requirements, innovative construction 

techniques, monitoring, recordkeeping, 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 Calculator on the Port Authority’s federal permitted 

projects. Contractors assess air quality impacts and provide proposed mitigation measures on 

projects via the NOx calculator. The Port Authority procures contracts through competitive 

sealed proposals and air mitigation efforts are part of that process. 
G:\HGAC\Reports\Final_051009\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, instead of simply adopting the TxDOT 

program. 

#42/10 – Limitations on Idling of Heavy-Duty Construction Equipment 

The Port Authority supports and actively participates in an idling limitation in its large 

construction contracts, as well as its own voluntary idling program. Tenants and users are 

informed of the need to reduce idling through signs, 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 reduction efforts and would potentially support a 

mandatory rule enforced by TCEQ or another regulatory 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 benefit of such a program compared to the cost. 

The Port Authority is also unsure of the willingness of companies to participate. 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 portable 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 portable engine owners in Texas will voluntarily enter 

into this program considering the significant administrative 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 engines to operate under a permit-by-rule if certain 

criteria are met. The permit-by-rule ensures that portable engine owners comply with air quality 

standards without subjecting the owners (and the agency) to unduly burdensome administrative 

exercises that do not provide significant 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 manufacturer 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 portable 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_051009\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 use of cleaner fuels across all sectors, the Port 

Authority has potential concerns about the viability 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 diligence 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 commercial marine sector. Two California Ports 

(Los Angeles and Long Beach) are currently implementing a pilot program to cover the 

incremental cost for vessels to voluntarily 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 program for feasibility and transferability. 

Below are some of the Port Authority’s specific concerns. 

This control measure is being considered in California largely as a particulate matter and SO2 

control, not a NOx control. Unlike Texas, portions of California are non-attainment for the fine 

particulate matter standard. The projected particulate matter reductions from this rule are 75%, 

but only 6% for NOx. Although particulate matter 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 tankage restrictions for the vessels. For this reason, 

the auxiliary engine rule is considerably less helpful, viable, and cost-effective for the Houston 

8-hour Ozone SIP. 

Statistics show that few ships frequently call on the Port of Houston. 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 rule would allow alternative 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 resulting program may have 

significant practical and legal implications. 

As discussed above, no studies have been performed or stakeholders engaged to assess the 

viability and effectiveness of this strategy in Texas. CARB has yet to complete its own rule 
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development which started several years ago. CARB has spent considerable time and resources 

developing the rule. CARB’s assessment includes thousands of pages describing fuel availability 

estimates, cost information, technical considerations, legal evaluations, public comment, 

business comments, etc. It is doubtful that H-GAC, TCEQ, and stakeholders could review 

necessary considerations under 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 electric 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 third 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 distillate 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 likely 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 calling on the Port of Houston are foreign 

flagged (only about 9% visiting 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 (preempting states from adopting state 

or local engine standards) 

o Section 110(a)(5) of the Clean Air Act (restricting indirect source review 

programs) 

• Case law 

o U.S. v. Locke, 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 Court upheld petitioner’s argument that 

Washington’s standards invaded areas 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 vessels was premature. In its rule, EPA 

stated that, “We [EPA] do not need to decide now whether we have the 

discretion to include foreign vessels under the non-road provisions of the 
G:\HGAC\Reports\Final_051009\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 powers 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 Angeles to purchase low-emitting vehicles. 

The Supreme Court held that a “standard” under the Clean Air Act’s 

preemption language in Section 209 is any mandate governing the 

emissions characteristics of an automobile. Based on this precedent and 

related case law, the Supreme Court would likely hold that a state or local 

marine emissions cap is invalid since 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 these terms are not used in Section 

3.27, which establishes the permit requirements, their definitions indicate 

that the Legislature intended to regulate 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 mootness, the Federal District Court 

held that a state regulation banning the use of construction equipment 

during the morning hours and a regulation requiring the purchase of new 

equipment were “engine standards” and therefore preempted by Section 

209(e) of the Federal Clean Air Act. 

In addition, the Port Authority would be concerned if this rule was adopted only in the Houston 

region. If it became cheaper or less prohibitive for vessels to use other ports in the Gulf Coast 

(which might be facing their own air quality issues), that cargo could be displaced to neighboring 

ports. The displaced cargo will then likely 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 resources and make efforts to ensure these more 

stringent standards are approved. The Port Authority and the American Association of Port 
G:\HGAC\Reports\Final_051009\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 emissions 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 operated 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 Authority has also encouraged its tenants to use 

cleaner engine technologies through TERP application assistance, education programs, and 

tenant meetings. The Port Authority already has a fleet turnover program for its’ equipment and 

that of tenants that heavily relies on TERP funding availability. 

While the Port Authority supports voluntary measures to reduce emissions from cargo handling 

equipment such as TERP, the Port Authority has potential concerns about the viability of a 

mandatory measure—especially if the rule is intended 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 conduct 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 legal). The State of California has yet 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 Administrative Law until September 2006. Until the State 

of California adopts the rule, receives 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, additional outreach meetings occurred, a cargo 

handling equipment survey was conducted, site visits happened. Based on H-GAC’s current 

schedule, the off-road short list is scheduled for one generalized stakeholder meeting. The Port 

Authority believes that significant 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 considerations. 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 become available), or retrofitted with a verified 

control that meets the same level of reductions. Numerous questions need to be addressed 

including cost, feasibility, availability of new engines (especially 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 that 
G:\HGAC\Reports\Final_051009\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 consideration 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 issue could arise if one 

port was subject to the requirement while another port was not. If it became less costly for a 

shipper to send goods to another port, those goods could be redirected 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 Houston 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 initial comments on the short list of non-road control strategies. 

The Port Authority will continue to evaluate and investigate these measures, as well as, others to 

develop practical and feasible solutions in reducing 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 Manager 
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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 measures for the HoustonGalveston-Brazoria 8-Hour Ozone State 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 28/5 – Enhanced Texas Emission Reduction Program (TERP): The 

TERP program is operated under the jurisdiction of the Texas Commission on 

Environmental Quality (TCEQ). Because of this, TCEQ will offer a separate response to 

address this comment. 

• Non-road Measure 31 – Accelerated Equipment Turnover; Tier 2 or Tier 3 Non-road 

Engines: H-GAC thanks you for continuing to participate 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 this 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 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)), and 55 (Reformulated Fuels for 

Off-road Vehicles): We appreciate your comments regarding the implementation of 

alternative engine and fuel technologies in port operations. H-GAC will use this 

information to create a refined version of this list in the latter part of this year. 

• Non-road 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 Best Management Practices): HGAC thanks you for voluntarily working to improve 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 voluntary idling reduction program. 

• Non-road Measure 87/35 – ARB Portable Engine Registration and Rulemaking: H-GAC 

appreciates your comments will use this information to create a refined version of this list 

in the latter part of this year. 

• Non-road Measure 88/36 – California Auxiliary Engine Rule: H-GAC thanks you for 

your continuing work to reduce emissions from ocean going vessels that are entering and 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-23 

leaving the port. 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. 

• Non-road Measure 89/37 – California Cargo Handling Equipment Rule: H-GAC thanks 

you for your continuing work to reduce emissions 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 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 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.hgac.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 willing to make their own commitments to reduce air 

pollution within the 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 Manager 
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B.1.4.1 Comment from Sierra Club

SIERRA 

CLUB 

FOUNDED 1892 

June 10, 2008 

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://tcxas.sierraclub.org/houston/ 

RfC'O ,JUN 1 6 2008 

Endosed are the comments of the Houston Regional Group and Lone Star 

Chapter of the Sierra Club (Sierra Club) regarding our initial input for the OnRoad/Non-Road Mobile Source Control Strategies Catalogs (Control Measures) 

for the Houston-Galveston-Brazoria (HGB) Eight-Hour Ozone State 

Implementation Plan (SIP). 

The Sierra Club is disappointed that HGAC has once again not fully explained 

what each control measure (CM) is. There are some CMs with explanations but 

even these are incomplete 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 emission reductions from each CM, approximate cost of each CM, and 

availability of each CM based on technological feasibility and statutory and 

regulatory requirements. 

Without this kind of specific information the public is just guessing as to what 

CMs would be best and that it 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 truly participate it 

must be educated about the options. These two catalogs inadequately educate 

the public so that it can review, comment on. understand the proposal and 

provide reasonable feedback. 

SIP Planning Process 

The Sierra Club has been very disappointed with the SIP planning process over 

the past few years. The SIP planning process has removed from consideration 

CMs that were viable and should have been analyzed. We feel the SIP planning 

process was not operated with a good faith effort. At a minimum the SIP 

planning process should adhere to the following principles: 
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1. Locate hazardous freeway areas for possible improvements, sharp tums, 

dover leafs, etc. 

4) The Sierra Club recommends that the following Freeway System 

Infrastructure CMs be studied in a detailed qualitative and quantitative 

assessment, analysis, and evaluation and rule effediveness analysis. 

1. Limit road and highway improvements to those benefiting transit and high 

occupancy vehicle lanes. 

2. Shift highway funds to transit. 

3. No new peripheral highways or loops. 

5) The Sierra Club recommends that the following Fuel Standards CMs be 

studied in a detailed qualitative and quantitative assessment, analysis, and 

evaluation and rule effectiveness analysis. 

1. Federal ultra lower sulfur diesel. 

2. California diesel fuel. 

3. Reformulated fuels for off-road vehicles 

6) The Sierra Club recommends that the following General Public Education 

and Outreach CMs be studied in a detailed qualitative and quantitative 

assessment, analysis. and evaluation and rule effectiveness analysis. 

1. Educate public about fuel savings from property inflated tires, regular tune-ups, 

and driving speed. 

2. Celebrity volunteers for ozone alert announcements. 

3. Air quality Information with driver training. 

4. Air quality public outreach. 

7) The Sierra Club recommends that the following Goods Movement CMs be 

studied in a detailed qualitative and quantitative assessment, analysis, and 

evaluation and rule effectiveness analysis. 

1. Designated truck routes. 

2. Dedicate truck lanes. 

3. Require short-haul trucks to use alternative fuels. 
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10. Enforce smoking vehicle reports and require repairs. 

11 . New vehicfe discounts for old vehicle trade-ins. 

12. Low-interest financing for low income and or old vehicle trade-ins. 

13. Transit passes/credit in exchange for old vehicle scrappage. 

14. Ban sale of high-emitting vehicles. 

15. Deny registration to vehicles with repeated emission failures. 

16. Increase parking at transit centers or stops. 

17. Provide parking at all major transit stations. 

1 0) The Sierra Club recommends that the following Part<ing Management CMs 

be studied in a detailed qualitative and quantitative assessment. analysis, and 

evaluation andl rule effectiveness analysis. 

1. Preferential parking for HOV lanes users and ride sharers; rate reduction. 

11) The Sierra Club recommends that the following Pricing Measures CM:S be 

studied in a detailed qualitative and quantitative assessment, analysis, and 

evaluation andl rule effectiveness analysis. 

1. We are against cheaper gasoline prices during evening hours. 

2. We oppose encouraging having muhiple cars. 

3. State and local exemptions for pooling/transit subsidies. 

4. No tolls for buses and van pools. 

12) The Sierra Club recommends that the following Speed CMs be studied in a 

detailed qualitative and quantitative assessment, analysis, and evaluation and 

rule effectiveness analysis. 

1. Aggressive driving enforcement. 

2. The Sierra Club supports leaving the speed limits as they are but 

implementing aggressive enforcement to bring down average speeds. There are 

far too many drivers who drive at 10-20 milesfhour over the posted speed limit. 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-33 

13) The Sierra Club recommends that the following Sustainable and TransitOriented Development CMs be studied in a detailed qualitative and quantitative 

assessment. analysis, and evaluation and rule effectiveness analysis. 

1. Manage location of new growth to limit additional sprawl. 

2. Incentives for infill and redevelopment. 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. Mixed use development ordinance and zones. 

4. Encourage or require complementary uses in close proximity in all 

developments or development areas. 

14) The Sierra Club recommends that the following Traffic Flow Improvements 

CMs be studied in a detailed qualitative and quantitative assessment, analysis, 

and evaluation and rule effectiveness analysis. 

1. We are against freeway bottleneck improvements that add lanes instead of 

focus on transit. 

2. Prohibit truck use of right lanes for loading on bus and bike routes. 

3. Pedestrian mall route diversion. 

15) HGAC needs an entire program dealing with traffic management and a suite 

of alternatives that will be implemented to resolve the problem. The Sierra Club 

recommends that the following Traffic Flow Improvements CMs be studied in a 

detailed qualitative and quantitative assessment, analysis. and evaluation and 

rule effectiveness analysis. 

1. Require two or more occupants per vehicles to enter designated congested 

activity centers during am and pm peak traffic periods. 

2. Require two or more occupants per vehicle to enter designated congested 

activity centers all day. 

3. Subsidize transit service. 

4. More transit access near universities and airports. 

5. Accelerate rail expansion. 

6. Light Rail. 
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7. Commuter Rail. 

8. High-speed rail. 

9. We support the specific, localized, allowance of jitneys. This is not mentioned 

as an alternative. 

10. We support putting Metro and other public buses on propane or oth.er lower 

polluting fuels. 

16) HGAC needs an entire program dealing with traffic management and a suite 

of alternatives th.at will be implemented to resolve the problem. The Sierra Club 

recommends that the following Transit CMs be studied in a detailed qualitative 

and quantitative assessment, analysis, and evaluation and rule effectiveness 

analysis. 

1. Subsidize transit service. 

2. Implement seamless public transit, connectivity. 

17) HGAC needs an entire program dealing with traffic management and a suite 

of alternatives th.at will be implemented to resolve the problem. The Sierra Club 

recommends that the following Travel Demand Management - Business 

Operations CMs be studied in a detailed qualitative and quantitative 

assessment. analysis, and evaluation and rule effectiveness analysis. 

1. We support a mandatory employer trip reduction program for all employers 

who employ 20 or more people. This is not mentioned as an alternative. 

18) The Sierra Club recommends that the following Travel !Demand 

Management - Schools and Colleges CMs be studied in a detailed qualitative 

and quantitative assessment, analysis, and evaluation and rule effectiveness 

analysis. 

1. Restrict student drivers to high schools. 

19) Th.e Sierra Club recommends that the following Vehicle Engine 

Modifications CMs be studied in a detailed qualitative and quantitative 

assessment, analysis, and evaluation and rule effectiveness analysis. 

1. Engine software upgrade (DHV4) or low NOx software upgrade. 

20) The Sierra Club recommends that the following Vehicle Idling CMs be 

studied in a detailed qualitative and quantitative assessment, analysis, and 

evaluation and rule effectiveness analysis. 
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2008 HGAC On-Road Source Control Measures 

The following are the On-Road Source CMs from the 2008 HGAC catalog that 

the Sierra Club wants to be fully qua!ltitatively and qualitatively analyzed and 

presented to the public and decision-makers for review, comment. and 

understanding of the SIP proposal. 

1. #54, Private sector clean fuel fleets. 

2. #56, Close loophole sin the Texas Clean Fleet Program making fewer 

exemptions for fleets. 

3. #59, Public agency clean fleet program. 

4. #1 44, Divert trucks from non-attainment areas. The Sierra Club 

recommends a new CM, Construct and designate truck only lanes. 

5. # 147, Permit HOV lane use by qualifying low emission vehicles (LEV). The 

Sierra Club does not support this CM because it does not get people to 

change their one person/one car mode of transportation and works against 

other forms of transportation that carry more than one person. 

6. #157, Single Occupant Vehicles (SOV) access to HOV and tra.nsit stations. 

The Sierra Club does not support this CM because it does not get people to 

change their one person/one car mode of transportation and works against 

other forrns of transportation that carry more than one person. 

7. #161, Managed lanes to accommodate some single occupant vehicles in HOV 

lanes. The Sierra Club does not support this CM because it does not get 

people to change their one person/one car mode of transportation and 

works against other forms of transportation that carry more than one 

person. 

8. #163, Focus on finding and penalizing extreme high emitters. 

9. #165, Rewards for reporting smoking or high emitting vehicles. 

10. #172, Scrappage/buy-back plan. 

11. #181 , Dedicated funding for school bus replacement. 

12. #188, Enforce smoking vehicle reports and require repairs. 

13. #191 , Low interest financing for low income and or old vehicle trade-ins. 

14. #193, Ban sale of high emitting vehicles. 
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36. #487, Telecommuting incentives or mandates. 

37. #496, Regional vanpool programs. 

38. #551 , 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. 

39. #553, Adopt California standards for vehicle emission rates. 

40. #576, Limitations on idling of hea\1)' duty vehicles. 

41. #587, Hea\1)' duty vehicle border inspection program for AB 1009. 

42. #601 , Extend or expand light duty diesel engine inspection and maintenance 

program. 

43. #632, Enhanoed enforcement for smoking vehicles program - vehicle 

impounding for violators (like Dallas Emissions Enforcement Pilot Program). 

44. #635, Prime parking for vanpools, carpools, hybrids. The Sierra Club 

recommends that hybrids be removed from this CM since they continue one 

person/one vehicle Ira nsportation. 

45. #638, Increased use of hybrid buses. 

46. #639, Initiate a flex-bike service to encourage bicycling. 

47. #642. More stringent liM cut points. 

48. #643, Accelerate development and construction of mass transit projects. 

2008 HGAC Non-Road Source Control Measures 

The following are the Non-Road Source CMa from the 2008 HGAC catalog 

that the Sierra Club wants to be fully quantitatively and qualitatively analyzed and 

presented to the public and decision-makers for review, comment, and 

understanding of the SIP proposal. 

1. #1 , Aircraft emission standards. 

2. #2, Ordering lowest emission engines. 
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3. #9, Develop air quality best management practices (BMPs); use BMPs to 

manage emissions from construction sites, construction vehides, and wind-blown 

dust. 

4. #1 0, Limitations on idling of heavy duty construction equipment. 

5. #11, Water injection for diesel engines. 

6. #14, Lean NOx catalyst. 

7. #15, Early introduction of low NOx engines. 

8. #16, Selective catalytic reduction (SCR). 

9. #21, Lawnmower exchange: trade in old gas powered equipment for discounts 

on zero emission models. 

10. #22, Lawnmower recycling programs (rebate program): replace gas mowers 

with electric. 

11 . #23, Promote use of cleaner lawn and garden equipment such as lower 

emission four stroke and electric powered equipment. 

12. #24, Buy a Clunker concept for small gas. equipment. 

13. #26, Ban equipment such as two stroke engines. 

14. #30, Use of auxiliary power units (APUs) for locomotives operating; controls 

for locomotives are r~mpted by federal law. bu1 voluntary controls might have 

some success. 

15. #31, Accelerated purchase of Tier II locomotive engines. 

16. #32, Electrification of rail switching yards. 

17. #34, Limitation on idling of locomotives. 

18. #36, California Marine Vessel Auxiliary Engine Rule. 

19. #37, California Cargo Handling Equipment Rule. 

20. #38, Clean fuel option: expand TxLED use. The use of TxLED could occur 

in source categories not currently required 1o implement the fuel use including 

marine and other engines. 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-40 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-41 
G:\HGAC\Reports\Final_051009\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 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 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.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 Manager 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-43 

B.2.1 Comment from Angel Brothers Enterprises, Ltd.

Angel Brothers Enterprises, Ltd. 

5210 West Road 

P.O. Box 570 

Baytown, Texas 77522-0570 

Pbone 281.421.5721 

Fax 281.421.5796 

www.angelbrothers.com 

July 25, 2008 

Houston Galveston Area CouncU 

3555 Timmons Ln., Suite 120 

Howrton, l){. 77027 

Attn: Board of Directors 

Fax#: 832-681-2551 

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

Dear H-GAC Board Member: 

Angel Brothers 

Povtng and Utility Conlroorors 

An Equal.()ppottunity Employer 

My name is Duane M. Gatlin, Sr. and I am Vice President of Angel Brothers Enterprises. 

Ltd., and we are a member in good standing with the Association of General Contractors 

("AGC") and the Houston Contractors Association ("HCA"). 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. 

Attachment 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-44 

B.2.2 Comment from Balfour Beatty Infrastructure Inc.

Balfour Beatty 

Infrastructure Inc. 

July 28, 2008 

Houston Galveston Area Council 

3555 Timmons Lane, Suite 120 

Houston, TX 77027 

Attn: Board of Directors 

Fax#: 832-681-2551 

Email: Mary.Spain@h-gac.com 

Dear H-GAC Board Member: 

Balfour Beatty Infrastructure, Inc. 

Southwest Region 

170 I Directors Boulevard 

Suite 1010 

Austin, Texas 78744 

Tel 512-707-0797 

Fax 512-707-0798 

My name is William L. Miller, I am the Sr. Vice President, of Balfour Beatty 

Infrastructure, Inc. and we are 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 

support for the positions listed on the attached document concerning off road emission control 

strategies and urge you to support these positions as well. 

William L. Miller 

Sr. Vice President 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-45 

B.2.3 Comment from Beyer Construction, LLP

BEYER 

CONSTRUCTION, LLP 

12200-B Duncan Road 

Houston, Texas n066 

(28 t) 587-5900 

Fax (281) 587-5948 

July 29, 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 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 General 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 emission control strategies and urge you to 

support these positions as 

Attachment 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-46 

B.2.4 Comment from Cravens Partners, Ltd.

U,'.* 

21728 Fairgrounds Rood • Hempstead. TX 77445 • Tel. 713-JOQ-1530 • Fox: 713-30Q-1531 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 Contractors and/or the Houston Contractors Association. 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. 

William H. Cravens 

President · 

Cravens Management. LLC 

General Partner 
G:\HGAC\Reports\Final_051009\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 Membet: 

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 positions as well. 

Sincerely, 

~ady 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-48 

B.2.6 Comment from Highway Pavement Specialties, Inc.

UI,.UiJIJJV 

niUUWitl 

PA~MENT SPECIALTIES, INC. 

August 4, 2008 

Houston ~~lveston Area Council 

3555 Timmons Ln.; Suite 120 

Houston, 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 positions 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_051009\Appendix B_051009.doc B-49 

B.2.7 Comment from J.D. Abrams, L.P.

J.D. ABRAMS, LP. 

EXECUTIVE OFFICES 

Ill CONGRESS AVENUE, SUITE 2400 

AUSTIN, TEXAS 78701 

PH. 512·322·4000 FAX 512·322·4018 

Houston Galveston Area Council 

3555 Timmons Ln., Suite 120 

Houston, TX. 77027 

Attn: Board ofDirectc:irs 

Fax#: 832-68l-2551 

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

Dear H-GAC Board Member: 

HOUSTON AREA 

13020 DONEGAL WAY 

HOUSTON, TEXAS 77047 

PH. 713·734-6499 FAX 713·734·6722 

My name is William DuglJay. I am the Houston Area Manager for J.D. Abrams, L.P. 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 concenring off road emission control strategies 

and urge you to support these positions as well. · 

Cc: Jon Abrams 

Tracy Schieffer, President Texas Chapter AGC 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-50 

B.2.8 Comment from NBG Constructors

NBG CONSTRUCTORS, INC. 

General Contractor 

9702 Synott Road 

Houston, Texas 77083 

(281) 495-0842 Fax (281) 495-0960 

7/28/2008 

Houston Galveston Area Council 

3555 Timmons Ln., St 120 

Houston, Texas 77027 

Attn: Board of Directors 

Fax# 832-681-2551 

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

Dear H-GAC Board Member: 

My name is David E. Boehm I am an owner ofNBG Constructors, Inc. and I am a member 

in good standing with the Association of General Contractors and the Houston Contractors 

Association. I am writing today to express my full support for the positions listed on the 

attached document concerning off road emission strategies and urge you to support these 

positions as well. 

David E. Boehm, Vice President 

NBG Constructors, Inc. 
G:\HGAC\Reports\Final_051009\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. BOX 2671 

CONROE, TEXAS 77305 

PHONE (936) 756-6960 

FAX (936) 756-6903 

Plant Locations: 

Conroe (936) 756·2722 Huntsville (936) 291 ~169 

Montgomery(936) 597·6669 Cleveland (261) 4>!2-2722 

July 28, 2008 

Houston Galveston Area Council 

3555 Timmons Ln., Suite 120 

Housron, TX 77027 

ATIN: Board of Directors 

Fax#: 832-681-2551 

Email: M111y.Spajn@b-gac.com 

Dear H-GAC Board Member: 

My name is Gene Smith I am the owner/ proprietor of Pavers Supply Co. A local Construction 

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

writing roday to express my full support for the positions listed on the attached document concerning 

off road emission control strategic:$ and urge you to support these positions as well 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-52 

B.2.10 Comment from Prime Eco Group

PRIME ECO GROUP 

Ecology Thru Technology ... 

Houston Galveston Area Council 

3555 Timmons Ln , Suite 120 

Houston, TX. 77027 

Attn: Board of Directors 

Sent by e-mail 

Dear H-GAC Board Member: 

My name is Felipe J. Guzman I am the general manager/proprietor of Prime Eco Group, Inc, a 

manufacturer of environmental chemicals for the Construction industry, and 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 support for the positions listed on the attached document concerning off road 

emission control strategies and urge you to support these positions as well 

As a company dedicated to conservation and the research I development of environmental alternatives 

for concrete and asphalt paving, we understand the necessity of environmental initiatives at the state 

level for Texas drivers and taxpayers. 

Very Sincerely, 

Felipe J. Guzman 

General Manager 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-53 

B.2.11 Comment from Smith & Company

SMITH & COMPANY 

ROADS-BRIDGES-HIGHWAYS-ASPHALT PAVING 

''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 

Email: 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 Smith 
G:\HGAC\Reports\Final_051009\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 Construction 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 

President 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-55 

B.2.13 Comment from William Brothers Construction Company, Inc.

Williams Brothers Construction Company, Inc. 

P.O. Box 66428~ Houi.ton. Te,1as 77266 

Phnntt: 713 .. 622·9821 FIUC: 713 .. 520·5247 

July 25, ZOGB 

Houston Galveston Area Coundl 

3555 Tlmmon!> Ln., Suire 120 

Houston, 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!hMgac.oom 

8 pages 

My name is Robert c. (Bob) l.llnham, lam vice president of WIIJiarTLS Br<Jthers Construction Company (a 

Houston-based nrm) and the fil'!l1 is member in gOQ(I stamding With \he As$0Ciated Gen""'l Qmtractors of 

Texas (AGC of Te~as) and the Houston Contractors As.sociotlon (~ICA), 

1 have been per.;onally tnvolved wlth the dean air Issue 111 Houston and how It relates 10 our IndUstrY for 

over 12 years. A few of my credentials: I am a current 1nember of HGAC's RAQPC, I am a Past 

Pre.sldent of the Houston Construction fndustry Coalition and the AGC or Te><as. I have served as tile 

Chairman of! he Highway Division of t~e. AGC of America and as t~e Chalnnan of AGC of Texas 81>1 AGC 

or America's Environmental Committees. Former Speaker Pete Laney appointed me to the. TERI' Advisory 

Board ~ere I ,selVecJ t\Vo yeats as the vice chair. I have participated in the West Coast, Mid-Atlantic. and 

Blue Skyways Collaboratives. I have spoken at several EPA National Oean Diesel Cllmpalgn conferences. 

WIDiams Brothers Construction Is an active TERP grantee With oVer 300 TERP projects. 

I am persona ill( disturbed a boot the pr·ocess llmeline. Modell no has not been accomplished. 

Subsequently, the region docs not know the amount of emission reductions necessary to reach 

al:ta1nment. Businesses do not make dedslons without a target or projected outcome. The region Js 

undertaking a decision-making process wi01out a target. This Is unwise. Unnecessa1y regional ecot~om c 

dampers may result from following this type of process, 

As a ~ey participant in the development of these positions, as a leader Ill our Industry, and as a slbject 

matter expert, 1 am writing today to express rny lull support for the loouslly positions listed on the 

attached doC\Jrnent concerning oiF road emi.ssion control strategies. Some of tile responses are 

unfortunately vague due to the lad< oF Information available obout U1e a<tual strategy being co dere , 

J am a>nOdent In the veracity of the comments aoo positions. J tto~ y urge you to consider and 

SUP!>Of t Ulenl. 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-56 

B.2.14 Comments on Draft Off Road Strategies

COMMENTS ON DRAFT OPP ROAD STRATEGIES: 

# Industry Categ01y/Strategy # Conuuents 

Position 

5 Support Cleaner Equipment Industry supports T ERP but offers the follm.ving conunentary as methods to improve the program: 

Requirements & 

Incentives Expectation from TERP in its current configuration are TOO HIGH based on a number of factors: 

1) Statutory limits on emission thresholds for technology 

2) Shifting of excessive funds to research 

3) EPA control of teclmology certification 

4) CARB & others lack of concern re{(arding NOx as a p ollutant o f concern when testing new 

teclmologies 

5) Limitations in the manufacturing industry 

6) Funding 

As a result, program changes are needed to expand success. St!ggested improvement to TERP: 

I. l'v!aximize. small business 12articij2ation in TERP 

TI1e TERP grant program requires significant, complex air emissions calculations. Though viewed as 

necessary for stringent audit and verification procedures, these requiren1ents serve as a deterrent to 

small business participation. 

a. Redefine "small business" to SBA standards in lieu of TCEQ standards for the purpose of 

administering TERP so that more. firms can be eligible for assistance directly from the TCEQ. 

b. :Modify TERP mles so t11at third parties (public, private, profit, non-profit) can se..tVe as a cooperative 

or collective for the purpose of grant applications. Small firms can JOin the co-op and receive the 

benefits by tl1e co-op submitting TERP applications on behalf of a group. 

C. lvfodify TERP mles so that certain repair shops or dealer maintenance facilities can be prequalified by 

a grant process to install retrofits or repm.vers on equipment brought in for repairs. A "coupon" 

process could be utilized obligating the equipment owner to all of the required reporting procedures 

without an application. 

Require all public entities with capital improvement programs in affected counties to provide TERP 

outreach as a part of the project advertisement protocols regardless of the media outlet. 

2. Lower the 30°Lo threshold requirement in TERP for retrofit projects. 

The 30% threshold has been a barrier to teclu1ology development Reconunend lowering to 10%. 

The tlueshold could be "graduated" witl1 a lower threshold permitted if the cost effectiveness is 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-57 

# Industry Category/Strategy # Cotnn1ents 

Position 

excellent. 

3. LO\ver the averagl; cost effectiveness of TERP 11rojects 

Cost and price are fundamental concepts of economics. Cost is a fimction o f efficiency in the 

manufacturing process_ Emission technologies have high productio n costs due to res earch and 

development, manufacnuing inefficiencies, and slow certification protocols. Price is a function of 

sup ply and demand. There is a demand for these technologies with extremely limited supply. To 

lower the cost effectiveness of TERP projects, a business climate should be c reated that p romotes 

both lower cost and lowe.r price for emission reduction technology. 

T o remedy/ mitigate the adverse economic factors for the delivery of emission technology t o the 

market, we recommend: 

•) Develop and implement criteria for the expansion of entities, public or private, that can 

b) 

''erify I certify the emission standard of new technology in a manner accept able to the USE P A 

Speed up / streamline th e USE PA technology verification/ certification p rocess_ 

c) The USEPA must begin to accept state agency or third party verification/ c ertification of emissions 

technology. 

d) These broad based program changes \Vill!ower the cost to p roduce and de liver new technology to 

the market. It will increase ccmpetition in the market thus increasing supply and lowering price . 

TI1e net effect \Viii be 10\ver cost effectiveness thresholds for funue TERP projects_ 

4. Manufacturer limitations - Regardless on the amount of money available th:rough TERP o r any 

similar progran1, there are physical constraints \Vith '\\rhich we must contend. 

a) TI1e manufacnuing industry capacity - It took decades to produce the off-mad fleet cll!ren tiy being 

operated_ If ti1e manufacturers comp letely stopped new work and produced new engines for ti1e 

existing fleet, it would take decades to make this happen_ 

b) Engineering feasibility - E ngines cannot be arbitrarily swapped out Support systems have to be 

evaluated and redesigned to acconunodate the newer type engines_ Sometimes the newer engines 

just won>t fit_ Subsequently, "repowering" equipment is not a "silver bulletn to cure all of our 

p roblems_ 

8 Support Cleaner Equipment Incentive based approaches are supported by industry. Not enough details exist on this item to provide 

Requirem en ts & any substantive comment. 

Incentives 

6 Support Cleaner Equipment Good if focus is short term de1iverables. Researchers have n ot been adequately controlled to date 

Requirem ents & 

Incentives 

8 Support Construction E quipment Govemment contracting incentives - The T:xD OT incen tive program was dev eloped jointly <vith 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-58 

# Industry Categoty/Strategy # Con1n1eJ1ts 

Position 

& Operations industry and would be supported. Increases in the amount of incentives to be earned should be 

considered. 

9 Support Construction Equipment This activity is already underway by USEP A. I have been a participant in the process. It '.'ill yield low 

& Operations cost reductions BUT there will be opposition by the NIMBY faction. BMPs has some potential but 

most address PM and not N Ox. 

10 Support Construction Equipment A prohibition on extended idling of diesel engines is an effective emiss.ion reduction strategy dtat can be 

(Qualified) & Operations supported by the industry. Depending on the application, limits can be established on how long diesel 

engines should be allowed to idle. 

1) That the TCEQ work wid1 dte indusuy to develop recommended idling limits for \'llriotlS types of 

diesel engine applications. 

2) Subsequently, TCEQ to adopt a no-idling nile based upon the agreed application-based limits. 

Idling restrictions are generally supported by industry so long as there is no cost increases such as ta.'<es. 

SH OULD APPLY TO ON & OFF ROA.D 

11- Support Engine & Fuel Engine technologies - after market devices will be supported only under a voluntaty mode such as 

14 (Qualified) Technology TERP; Mandates will be litigated 

15- Support Engine Standards . USEPA engine standards are supported on their current time line 

16 (Qualified) 

. Normal attrition of the older fleet must be allowed to occur on the normal business investment cycle 

ruiless supplemented. by a voluntary program snell as TERP 

19- Support Fuel Standards Fuel strategies are supported so long as ce.rtain criteria are met: 

20 (Qualified) 

. Adequate ad\'llnce testing is conducted to insure no adverse affects on the diesel engine or any of its 

con1ponents. 

. Adequate testing to insure no Joss of power occurs in the engine output Loss of power will require 

the utilization of larger equipment to perform d1e same task thtlS defeating the purpose of or 

reducing the effectiveness of the strategy. 

. Adequate testing to insure no loss of fuel efficiency. Loss of fuel efficiency will cause more fuel to be 

consumed to produce d1e same anlOllllt of work dltlS defeating the purpose of or reducing the 

effectiveness of the strategy. 

. Adequ~te testing to insure. ther e. are no toxicity issues. As employers, the industry is concerned with 

employee exposure and the creation of additional environmental hazards. 

. Research and plan d>e in1plementation to insure adequate fuel supply . 

. Research and plan the implementation to protect contractors in fixed price contracts from increased 

fuel prices. 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-59 

OTHER POTENTIAL SIP CREDIT 

1. Federal (US EPA) Retrofit Program - In the 2005 Energy Bill1 , Senator Voinovich introduced and passed an amendment that p rovides S I billion for the 

retrofit of diesel engines. 

c) Push for full funding and appropriation by the Congress. 

d) The TCEQ and the State of Te1ms apply for their fair share of this funding. 

e) Obtain a commitment from the USEPA for a minimum gu aranteed ftmding level for Texas retrofit projects. Tilis guaranteed ftmding level could 

included in the SIP in the same manner as TERP. 

t) The ftmding would either be included in the TERP progran1 or managed separately. 

2. Congestion i'vlitigation and Air Quality Fund (Ci\ILA.Q Fund) - TI1e reauthorization of the federal llighway bill, SAFETEA-LU', included revisions that pern 

the use of the CJ'.;IAQ Fund for enlission reduction projects for non-road equipment. Previously, these ftmds had been linlited on only on-road emission 

reduction projects. 

a) Work with the USDO T and FHWA to expedite guidance and policy for the implementation of tllis new provision. 

b) \\lork with TxDOT to expedite implementation of the new policy. 

c) Obtain a commitment from TxDOT on the amount of monies to be spent annually from Ci\ILA.Q on non-road enlission reduction projects. 

d) Advertise and p romote the program through local Metropolitan Planning Orgatlizations. 

e) Include the comnlitted ftmding levels from Cv1AQ on e.nlission reduction projects in the SIP in the same manner as TERP. 

3. Emissions Banking and Trading Program 

a) Emissions trading progran1 should be modified to facilitate the inclusion of non-road source reductions. 

b) The trading progran1 will work similiu to an incentive program with the company making an investment in clean air teclu1ology and is left with 

credits that can accrue value depending on the market 

1 H.R.6, Subtitle G, Sectiot" 791 - 797 2 H.R.3 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-60 

The following table is a. list of proposed control strategies that that are opposed by the civil constmction inclushy and have been 

removed from the list by RAQPC. We would strongly oppose any reconsideration of these items as possible control strategy 

altemati ves. 

30 Neutral CleaneL Equipment No comment 

Requirements & 

Incentives 

31 Oppose Cleaner Equipment Accelerated Fleet Turnover - Litigated and defeated in the 1 Hr SIP. Only acceptable to the industry 

Requirements & under a volunta.<y measure funded by TERP. 

Ince.ntives 

33 Oppose Cleaner Equipment Operating restrictions - will be opposed; Previously litigated and overturned 

Requirements & 

Incentives 

34 & Oppose Construction Equipment Conditions of approval for new construction 

35 & Operations 

Backdoor appro aches to achie1re #31 and # 33; \Vill be opposed; Pernlits for new construction will create 

more govemme,nt; Emissions limits on projects - not technically feasible due to lack of expertise 

Unacceptable for the following reasons: 

1) Death on econonlic growth 

2) Lack of competent technical expertise to do this intelligently 

3) \\'i'ill be used as a vehicle by some factions to stop gro\vth 

4) \\'i'ill require a new bureaucracy to establish a permitting process. Permits would be the only 

mechanism to n1ake this enforceable. 

Contract-Based control strategies \vill: 

. D isenfranchise contractors 

. Reduce con1petition 

. Increase the cost of construction 

Furthermore, there is significant legal precedent prohibiting the use of such measures: 

• For states other than California and all political subdivisions, §209(e) of the federal Clean Air 

Act preen1pts any en1ission-related state or local standrurd or other requiren1ent on new or nonnew vehicles, but allows {(opting in>' to California's regulations. 

0 §209 Protects Vehicle Consumers. As the Supreme Court held in Ei\ll" v. SCAQi';ID, 

541 U.S. 246 (2004), by limiting the state and local governments to choose between 

EPA's national standards and California's standards, Congress intended §209 to 

protect both vehicle manufacnuers and consumers from vehicle standards that fail to 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-61 

meet the stamtory crite£ia (e.g., teclulical and econonlic feasibility, leadtime). 

o §209 Preempts In-Use Controls. §209(d) expressly reserves states' authority over inuse motor-vehicles (such as Ca£POol lanes). By contrast, as the U.S. District Court in 

Austin held in EMA v. Huston, 190 F.Supp.2d 922, 927 & n.3 (\VD . Tex. 2001), 

§209(e) preempts all emission-related controls for nonroad vehicles, '.'ith no savings 

clause for in-use nonroad vehicles . 

• Under some statutes, courts recognize a "market-participant'"' exception to otherwise-applicable 

federal preemption. In Cardinal To\\~ng v. City of Bedford, 180 F.3d 686, 693 (5th Cir. 1999), 

the Fifth Circuit adopted a two-part test to deternline when a government action falls on the 

"proprietary'' side of the regulatory-proprietary distinction: 

o Exception Reflects Typical, Efficient Behamor. Does the action essentially reflect a 

private party's typical eh"'~or in efficient procurement? 

o Exception Is Narrow. Does the action's narrow scope suggest a goal to address a 

specific proprietary problem, rather than to encourage a general policy? 

o J·v!andatoty contract-based measures fail both halves of the Cardinal Towing test: 

(1) their greater expense makes them the very opposite of a private party's interest in 

efficient procurement of sernces; and (2) they are not narrowly tailored to projectspecific criteria but instead are obviously intended to address a general policy of 

reducing statewide emissions, partictilarly for regional pollutants like ozone 

precursors. 

• To qualify under Clean Air Act §110, mandatory contract-based controls must be federally 

enforceable by EPA, the state, and the public. Whether voluntary or mandatoty, reductions 

must also be quantifiable, surplus, permanent, and adequately supported. Contract provisions 

fail in aspect to: 

o Federally Enforceable. Like private market participants, government contracts cannot 

impose punitive liquidated-damages clauses in contracts. Priebe & Sons v. U.S., 332 

U.S. 407,411 (1947). 

o Not Quantifiable. To qualify as quantifiable, an e.nlission reduction must be capable of 

({reliable and replicable" measuretnent, and it cannot be impractical to determine 

compliance \Yith the published limit 

o Reductions Are Not Permanent. To qualify as pennanent, an enlission reduction must 

exist throughout the time that the State Implementation Plan relies on it) unless the 
G:\HGAC\Reports\Final_051009\Appendix B_051009.doc B-62 

state replaces it {e.g., by another emission reduction or SIP revision). 

37 Oppose Construction Equipment Contract control clauses - l\ifandates will be opposed~ Voluntat.y incentives will be supported 

& Operations 

38 Oppose Construction Equipment Bid preferences will: 

& Operations 

1) Disenfranchise contractors 

2) Drive up the cost of constn1ction e..xponentially 

3) Violate numerous procurement statutes 

4} \Vould be litigated by numerous constn1ction associations 

40 Oppose Construction Eqttipment Half day construction schedules - NOI See Comments on #31 

& Operations 

43 Oppose Construction EqttipmeJ1t Share eqttipment ~ Conunents resenred w 1til more info is available~ Sounds impractical and stupid. 

& Operations 

44 Oppose Construction Eqttipme.nt Tags on equipment - no benefit and high cost; If intent is m bundle with #31 & #33 - will be opposed 

& Operations 

58- Oppose General Operations . #58 - NO; see conunents on #33 

62 Management . #59 - NO; see conunents on #35 

. Any restrictions on the use of equipment will be opposed; previously litigated and overnuned 

85 Oppose Stationary Engines . See comments on #31-35 

87 Oppose Cleaner Equipment ARB portable engine standards 

Requirements & 

Incentives Adoption of CA engine standards was discussed during the I Hr SIP development. It removes a great 

deal of future control away from Texas (HGB.-1.) if the adoption occtus. Any funue CA changes would 

have to be irnn1ediately adopted by Te..'<as. Recommend against. 

INDUSTRY GUIDIN G PRINCIPLES 

Litigation will be supported on any strategy (on-wad or off-road) that contains any of the following including any hybrid/ variation of: 

a) Eqttipment use restrictions 

b) Early fleet tumover or existing fleet obsolescence 

c) Mandated equipment modification or replacement 

d) A1.1y standard that undermines the federal role in diesel engine standards 

e) Bid preferences o r restrictions 
G:\HGAC\Reports\Final_051009\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 the mobile source control measures for the 

Houston-Galveston-Brazoria 8-Hour Ozone State 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 Texas Emission Reduction Program (TERP): The 

TERP program is operated under the jurisdiction of the Texas Commission on 

Environmental Quality (TCEQ). Because of this, TCEQ will offer a separate response to 

address this comment. 

• Non-road Measure 6 – Aftermarket Technology and Fuel Additive Research Program:

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 8 – Government 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 idling of heavy-duty construction equipment:

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 Measures 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 16 (Selective catalytic 

reduction (SCR)): These measures all require revisions to the TERP program which is 

operated under the jurisdiction of the Texas Commission on Environmental Quality 

(TCEQ). Because of this, TCEQ will offer 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_051009\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 removed from the final version of the Master. 

Additionally, your letter suggested the addition of several new measures to the current list of 

control measures: 

• Use the Federal (USEPA) Retrofit 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 Mitigation 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 measure. 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 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 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.hgac.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 willing to make their own commitments to reduce air 

pollution within the 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 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 Measures
G:\HGAC\Reports\Final_051009\Appendix C_051009.docG:\HGAC\Reports\Final_051009\Appendix C_051009.doc 

C-1

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 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 Consultancy), 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 Angelone (HGAC), Ben Finley (HGAC), Connie 

Chao (HGAC), Mary Schuwerk (HGAC) 

TCEQ Presentation: Discussion of Inventories 

TCEQ presented three handouts regarding the emissions inventories 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 control strategies agreed upon were not the same as what the airport 

industry ended up using to reach the target reductions. 

The “Airports/Airlines Emissions Inventory” handout precipitated discussion regarding the 

emissions growth projections. 

PUBLIC COMMENTS: 

1) Jacobs Consultancy pointed out that 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 officially 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_051009\Appendix C_051009.doc C-2 

a. Continental answered that they had 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 increase in one area and decrease in the other, 

which means that the same growth factors 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 strategies 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 between 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 factors like the economy or 

the effects of 9/11. They would like to see 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 industry 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 upgrade at Intercontinental Airport that 

would be affected by this, and all that the industry is asking for is accuracy because 

projects like this cannot occur without general 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 grants available in the nation, 9 have gone to 

HAS. In general conformity, HAS will be putting together air quality mitigation 

programs. 

 As for the EDMS, a lot of the defaults are bogus. For example, preconditioned air 

as a control strategy is very effective but the EDMS defaults do not reflect 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 with owning emission reductions from now on. 

We want to cooperate with TCEQ and HGAC on a voluntary basis, not through rulemaking. 
G:\HGAC\Reports\Final_051009\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 all those years are not for the attainment 

SIP, they are for the RFP SIP. 

12) TCEQ said that all the airport data would have to be backed up by more data. TCEQ has 

to agree on the methodology used for the airport inventory, and so TCEQ needs to see the 

inventory to begin dealing with that. The appendix is not something 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 airlines want or will agree to. 

a. Jacobs Consultancy said that it did not want to misrepresent what was being said 

as also representing what the airlines wanted. 

14) Continental Airlines asked why calculations used 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 just is not used that way. 

TCEQ Presentation: TCEQ SIP Timeline 

TCEQ presented a handout showing 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 stakeholders 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 the 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 will 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 3rd Party TERP program allows local government (such as the airports) to apply for 

TERP grants without having to compete with the whole state. CMAQ funding is for on-road 
G:\HGAC\Reports\Final_051009\Appendix C_051009.doc C-4 

vehicles such as airport shuttles. SEP is currently only available for school bus funding, but 

HGAC is working to make that funding available to local governments. 

ACTION ITEM: TCEQ 

1) TCEQ should retrieve the demonstration documents 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 general conformity and reference. 

ACTION ITEM: Industry 

1) Airports representatives and TCEQ should get together on Mondays 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 with 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 Schmid (UP), Peter Conlon (KCS), Steve 

McNealy (KCS), Carl Akins (KCS), Mike Clift (BNSF), 

Staff Present: 

Donna Huff (TCEQ), Koy Howard (TCEQ), Shelley Whitworth (H-GAC), Graciela Lubertino 

(H-GAC), Kelli Angelone (H-GAC), Connie Chao (H-GAC), Chris Lindhjem (Environ) 

Environ Presentation: Overview of SIP Process and Control Strategy Discussion 

Environ reviewed the process by which control strategies were gathered into a master list of 

every possible strategy, then narrowed into a short 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, straightening routes, grade separation, upgrading 

technology such as bearings 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_051009\Appendix C_051009.doc C-5 

b. KCS answered that they probably had no switching engines in the Houston area, 

they have just through-service 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 would be a decrease in fuel 

efficiency, which would cancel out some efficiency gains. 

MOU/MOA Discussion:

H-GAC wanted to discuss potential agreements that could be made for emission reductions with 

railroad stakeholders. Railroads/ locomotive emissions 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 crossing 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 being 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 project delays, which H-GAC said that they 

did not want either, and that a VMEP agreement should not hold up a project in 

any way. 

3) UP commented that many times projects for environmental benefits had been ‘forgotten’ 

by the public, and that sometimes, they could 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 VMEP 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 are not attractive to industry. Suggestions were 

given for whom to talk to about leased locomotives. 

5) PTRA detailed their inventory—24 units never 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 reductions 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 they were expected to 

do them on their own. 

a. H-GAC answered that projects for MOAs 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_051009\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 Martin (Vollmer PR), Chris Lindjhem (Environ) 

Staff Present: 

Shelley Whitworth, Graciela Lubertino, Kelli Angelone, Connie Chao, Mary Schuwerk, J. Ben 

Finley, Andrew DeCandis 

Environ Presentation: Overview of SIP Process and Control Strategy Discussion 

Environ reviewed the process by which control strategies were gathered into a master list of 

every possible strategy, then narrowed into a short 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 manufacturer to bring out a Tier 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, vessels, and equipment. 

4) Possibilities for marine VMEPs were discussed by PoHA 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 thinks 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 as 
G:\HGAC\Reports\Final_051009\Appendix C_051009.doc C-7 

California. Our wind patterns would not necessarily push ship emissions further ashore, 

whereas California east-west winds would do that. 

7) Texas Petrochemical Society asked about 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 companies’ records would be used. 

8) Melanie Oldham asked about behavior-based measures such as reduced 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 and 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 general, which might help with the public’s 

behavior. She mentioned that she had made her concerns known to her state 

representative, Dennis Bonnen. Ms. Oldham expressed frustration with the 

situation in Brazoria County. 

9) Russell Lehrman commented that his area of town 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 near his home all day and night. 

10) HSC commented that for his organization to give respectable feedback on the draft Short 

List report, H-GAC would need to provide more time for review before holding a 

meeting, and H-GAC should consider more carefully their invitation list. H-GAC 

responded that the usual public notice procedures 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-used 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 control measures should have. ‘P’ stands for 

Public acceptance, ‘Q’ stands for Quantifiable, ‘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 underestimates 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 estimates provided in Mobile6. HSC recommended that instead of 

lowering the speed limit, enforce the one already in place. 

14) HSC recommended that dedicated truck lanes, 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_051009\Appendix C_051009.doc C-8 

15) HSC mentioned that the previous standards 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 inclusions to the Control Strategy Report: “route-traffic 

platooning”, adaptive traffic signals, and a glossary for the report. 

17) Nancie Andersonelaborated on her situation about the ill effects of the trucking emissions 

and noise within her neighborhood, and asked that H-GAC do whatever it can to help the 

situation. 

18) Mr. Lehrman made further comments regarding his concerns about the dairy plant and 

asked for suggestions for amending the situation. 

a. H-GAC assured Mr. Lehrman and Ms. Anderson that their concerns would be 

addressed, and their complaints 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 regarding 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 and Control Strategy Discussion. 

Environ reviewed the process by which control strategies were gathered into a master list, then 

narrowed into a short list of feasible strategies. The strategies that were considered for the 

Houston-Galveston-Brazoria region’s State Implementation Plan (SIP) are voluntary control 

measures that have stakeholder support. 

H-GAC Discussion: Control Strategies (See handouts, (“Control Measure: Construction 

Contracting Incentives, Measure 8” and “Control Measure: Construction and other offroad idle reduction, Measure 10”) 
G:\HGAC\Reports\Final_051009\Appendix C_051009.doc C-9 

ENVIRON and H-GAC reviewed the two off-road construction strategies from the short list and 

asked for comments and recommendations from industry representatives. 

PUBLIC COMMENTS: 

1) Williams Brothers said that the suggested 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-based approach would be supported by industry, 

but we will be asking people to do things that 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 benefits will be 

limited. The Regional Air Quality Planning Committee’s Policy Subcommittee had some 

recommendations for what the dollar amounts should be for the incentive. 

a. Environ commented that yes, this was true: publicly-funded 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 retrofit 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 off-road idle-reduction”, Environ commented 

that anti-idling was very cost-effective. 

a. H-GAC asked how idling reductions would be estimated by industry groups. 

b. Environ said that reduced hours could 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. Concerns regarding this measure are that 

conflicting information would come out of attempting to estimate this because 

what industry groups say their usage is would be compared to TCEQ’s model, and 

they would not match. 

7) H-GAC asked if you could look at old projects where equipment was leased on a timebasis? 

a. Williams Brothers replied that they rent 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 companies that 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 reductions before the fuel price increase, 

would that be acceptable for documentation? 
G:\HGAC\Reports\Final_051009\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 reduction 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 looked 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 certified, they would have to talk to the 

manufacturer of some equipment they are testing out. 

2) Williams Brothers recommended that emphasis 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 model 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 like 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-prohibitive. 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 equipment industry groups still owned. 

a. Williams Brothers estimated 10%. 

b. H-GAC commented that if it was replaced, it would get more usage. 
G:\HGAC\Reports\Final_051009\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 projects that could be 

left open for technology that would 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 beneficial 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 industry 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 groups to coordinate on possible MOUs. 

ACTION ITEM: Industry Groups

1) Industry representatives should look into who 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), Linda Henry (PoHA), Kenneth Kidwell (Shippers 

Stevedoring Company, (SSC) USA), Shareen Larmond (West Gulf Maritime Association 

(WGMA)), Chris Lindhjem (Environ), Lisa McMichae (Port of Freeport), Chuck Moss (Oxid, 

LP), Rebecca Rentz (Bracewell & Giuliani) 

Staff Present: 

Kelli Angelone (H-GAC), Connie Chao (H-GAC), Ben Finley (H-GAC), Graciela Lubertino (HGAC), Mary Schuwerk (H-GAC), Shelley Whitworth (H-GAC), Lola Brown (TCEQ), Koy 

Howard (TCEQ), Donna Huff (TCEQ), 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 retrofit and replacement of marine engines as the 

primary means to reduce emissions. By replacing older engines and equipment with those 

meeting lower emission standards, NOx and VOC emissions are drastically reduced. EPA has 
G:\HGAC\Reports\Final_051009\Appendix C_051009.doc C-12 

announced new emission standards for marine engines 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 focus on harbor craft (tugboats, 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, other 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 specific 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 will require more time than the January 

2009 deadline allowed them to devise a MOU/MOA. 

b. Bracewell & Giuliani asked a clarification 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, stakeholders 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 where 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 (which 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 exhaust to collect and treat emissions). 

3) What is each marine stakeholder 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 control measures for the site. 

b. Port of Houston: It is a partially landlord 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 are also a big source of pollution 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 process 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 represented but was anticipated that no emissions 

inventory had been started. 

4) H-GAC suggested that maybe PoHA could try an anti-idling 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 idle out of financial constraint. At one 

time 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_051009\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 themselves 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 Lubertino (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 explained 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 operates under Union Pacific. 

2) ExxonMobil said they have mostly harborcraft and tankers docking and operating around 

their pier. 

a. They were advised by H-GAC that those should be considered for possible 

VMEPs. 

3) ExxonMobil did not know for sure whether their 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 industry to reduce because they 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 monitor 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 their handful of construction equipment 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_051009\Appendix C_051009.doc C-14 

ACTION ITEM: H-GAC 

1) HGAC should send to the industrial mobile stakeholders some sample MOAs from the 

last SIP. 

2) H-GAC should look into the 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-effectiveness 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 Karnes (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 Memoranda 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 previously set aside as possibilities for MOUs and as a starting point 

for generation of further possible strategies. 

QUESTIONS/ COMMENTS: 

1) H-GAC asked industry groups which of the strategies provided might be feasible, and if 

none were feasible, were there any that industry representatives could suggest? 

a. Industry groups expressed doubt in their ability to make significant 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 GSE as part of the last SIP agreement. 

Airlines stated that they estimate that most of the equipment left is the equipment 

that must stay diesel-fueled because electric 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 last airports/airlines meeting.]

a. TCEQ and industry representatives confirmed that the airports and airlines had 

definitely made the reductions they had said they would do in the last MOU. 
G:\HGAC\Reports\Final_051009\Appendix C_051009.doc C-15 

3) H-GAC asked industry about the feasibility reduced-idling policies for 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 affect that. They also said that airport 

shuttles would be something that the airport parking lots would be the people to 

contact for that. Airlines representatives would prefer to focus on the ground 

support equipment, whose operations they have the ability to affect.

4) Industry representatives said that 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 helpful to see the revised inventory first, which 

TCEQ was still assembling. 

a. TCEQ was not sure when the document would be available, but knew that they 

were supposed to receive the last of the airport data January 9th, then would be 

reviewing the data themselves for the next week or so. The data had to be 

reinserted into the model January 29th.

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 about possible gate electrification. 

a. Industry groups said that was a possibility for MOU. 

ACTION ITEMS: 

1) Airports should get their inventory 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 and 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 (Brazoria County), Lanie Platt (DOW-Freeport), Ken 

Gathright (PoHA), Dana Blume (PoHA), Russell Lehrman, Marcie Anderson, Elvia Cardinal 

(TxDOT), Charles Airiohoudion (TxDOT), Madonna Lorraine (TxDOT), Charles Stillman 

(Texas Climate Emergency), Matthew Tejada (GHASP), Donna Huff (TCEQ), Theresa Pella 

(TCEQ), Lola Brown (TCEQ), Helen Vollmer (Vollmer PR), Lori Martin (Vollmer PR), Chris 

Lindjhem (Environ) 
G:\HGAC\Reports\Final_051009\Appendix C_051009.doc C-16 

Staff Present: 

Shelley Whitworth, Graciela Lubertino, Kelli Angelone, 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 and Control Strategy Discussion 

H-GAC reviewed the health effects and costs of air pollution, progress that 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 that small emission reductions when put 

together can make for effective control measures. 

b. HSC would still like to see the EPA criteria ‘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 disappointed that adequate law enforcement 

is not emphasized because speed enforcement would be good for the environment 

and for safety. 

e. HSC recommends that H-GAC monitor emissions 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 emissions 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 refer to smoking vehicles, HSC finds 

these contradictory and would like to see 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 kind 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 information 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 decide what should be done. 

2) Russell Lehrman, resident of Houston, northeast of downtown 

a. Mr. Lehrman was concerned that #60, travel-based taxes, would not apply to 

idling vehicles, which he thought it should. He thought it might be a good idea to 

have idling-based taxes because of the 65 vehicles 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 plant near his home does have one or two 

APUs, but it is still expanding the ‘parking lot’, so it is not having enough of an 

effect. 
G:\HGAC\Reports\Final_051009\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 (Harris County Attorney’s Office), Nick Finan (City of Texas City), 

Charles Dean (Harris County), Perri D’Armond (Greater Fort Bend EDC), Don Brandon 

(Chambers County), DeWight Dopslauf (Harris County Purchasing), Ann Werlein (Fort Bend 

County), Ken Gathright (Port of Houston Authority), Stacie Henderson (City of Sugar Land), 

Luis Rodriguez (City of Sugar Land), Dolly Arons (City of Shoreacres), Kerry Collins-Leggett 

(City of Alvin), Gail Miller (Harris County Precinct 2 Commissioner Sylvia Garcia’s Office), 

Larry Buehler (City of Alvin), Jim Wigihton (Brazoria 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-Position 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 and Voluntary Control Strategies 

Shelley Whitworth, H-GAC Air Quality Program Manager, described the State Implementation 

Plan and gave an overview of the process. The purpose is to reduce emissions through state and 

local controls. Nitrogen oxide (NOx) and Volatile Organic Compounds (VOC) levels were 

estimated in a TCEQ modeling emissions inventory in 2005 and predicted for 2018. Currently, 

8-hour ozone design values have a downward trend 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. Government agencies are encouraged to take more 

voluntary measures to reduce emissions. Recommended on-road voluntary control measures are: 

Alternative commuting, regional traffic flow improvement, and vehicle retrofit and replacement. 

Recommended non-road voluntary control measures are: Engine replacement and retrofit 
G:\HGAC\Reports\Final_051009\Appendix C_051009.doc C-18 

programs, government construction incentives, limits on construction idling, promoting cleaner 

garden and lawn equipment. Some local actions that government can take are to support on-road 

and non-road voluntary control measures, enact ordinances promoting livable centers and multiuse developments, support increased transit service, expand the use of natural gas in vehicle 

fleets, add bicycle and pedestrian control strategies, increase fleet turnover 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. The stations were the following: Fleet Turnover, 

Support Commute Solutions, Airport Control Strategies, 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. The 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 availability 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 Strategies 
G:\HGAC\Reports\Final_051009\Appendix D_051009.doc D-1

The comment periods for the Draft On-Road Control Strategy List and the 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 Quality 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 entirety. 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 idea that in the short run only Natural Gas will solve our energy 

and pollution problems. For the next ten years or so I suggest 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 appliance refueling compressor at some considerable 

expense. The City of Lake Jackson 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 fueling pump I believe it 

would pay for itself eventually. During this last period of high gasoline prices I was still fueling 

my car for less that $1.50 per GGE, including the electricity 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 stations available. At present, there are two Clean 

Energy CNG stations in Houston that I am aware of. 

Thanks for considering my suggestion, 

Jim Blocher
G:\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 applying for a grant(s) under the Clean Vehicles 

program. 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 alternative fuels), or the establishment 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 Manager 
G:\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, SEEN 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 Dow 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 while 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 You
G:\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). Since your comments deal with the monitoring 

of point source emissions at industrial plants, a subject not directly related to the mobile 

source SIP process, your comments have been forwarded to the Texas 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/airquality/sip/default.aspx

Sincerely, 

Shelley Whitworth 

Air Quality Program Manager
G:\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 anything 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 airborne dust is so heavy from the plant on State 

Hwy 3 in Webster (between NASA Parkway and Medical Center Blvd.) that it appears to be a 

heavy fog. Yet it is obvious where it is coming from. Airborne dust particles can cause 

breathing problems among some people. 

 

I would like to see some controls on airborne dust from industrial plants 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 those standards? If there are ordinances, is there any enforcement 

of them? 

 

The plant I referenced also has high noise levels at many hours, but since no one controls noise 

pollution except an unenforced city ordinance in Webster, then that aspect of an industrial plant 

is uncontrolled except maybe for some OSHA hearing protection rules for the employees at the 

plant. 

 

Thanks for reading. 

 

Leo Waltz 

P.O. Box 580037 

Houston, TX 77258-0037 

281-316-2255 
G:\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). Since your comments deal with airborne dust at 

industrial plants, a subject not directly related to the mobile source SIP process, your 

comments have been forwarded to the Texas 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/airquality/sip/default.aspx

Sincerely, 

 

 Shelley Whitworth 

 Air Quality Program Manager 
G:\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, Cheryl; 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 modes, but I heartily disagree with the choice of 

data inputs, and therefore with the conclusions. Basically, I think 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 projects 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 bicycling 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 the 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 cars, all you need to do is build 

infrastructure and it will get used. That is not the situation 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 current Harris County stance) 

• enforcing speed limits, and lowering 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 endanger cyclists (running stops signs and lights, 

and riding in the dark without lights, and riding against traffic) 

 

What is the cost of these types of actions? The "encouraging" actions are almost free. Strongly 

enforcing speed limits, DWI, and distracted driving should be done anyway, and those costs 

should not be borne by cyclists, but generally. The 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 bicycle educational program that governments widely promote to the 

public. Writing tickets for traffic violations by cyclists could be revenue 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 BikeHouston
G:\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). Your comments about the cost effectiveness for

bicycle-pedestrian projects are greatly appreciated. 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 projects We agree with you that additional 

education and encouragement as well as additional enforcement of safety rules already in 

place will promote increased bicycle and pedestrian activities and bring further emission

reductions due to increased usage of already 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 enforceable) and were not 

able to be added to the short list of control measures. 

We do value your input and we encourage you and the whole bike community to 

become involve in our Transportation Improvement Program (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 Manager 
G:\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 paper 
G:\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. 

2 
G:\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. 

3 
G:\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. 

4 
G:\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. 

5 
G:\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. 

6 
G:\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. 

7 
G:\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. 

8 
G:\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 

Air 

Brandt 

Lone 

Quality 

Star 

Mannchen 

Chapter 

Issue Chair 

of the 

V -~-/ 

Sierra Club 

f ~ 

Chair, Air Quality Committee 

Houston Regional Group of the Sierra Club 

5431 Carew 

Houston, Texas 77096 

713-664-5962 

brandtshnfbt@juno.com 

9 
G:\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 State Implementation Plan (SIP). The Texas 

Commission on Environmental Quality (TCEQ) and 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 objective 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 organic 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 available 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 reference 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 developing control strategies for the SIP, to 

improve local air quality, and comply with federal regulations. Satisfaction of these 

criteria is necessary to generate an emission reduction that is creditable in the SIP. 

Emission reductions are “Permanent” if they can be ensured that no emission increase 

(compared emissions in the absence of the project) occur over the time the emission 

reductions are relied upon in the SIP. They are “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 their precursors. They are “Quantifiable” if they can be 

reliably measured or determined, and if these determinations can be independently 

verified and replicated. Emission reductions 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 professional judgment based in professional 

experience, research, and identification of Control 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 satisfy 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 professional experiences, knowledge of best 

practices, research of the ingenuity and 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 account for those measures which you have 

commented on For the questions or comments 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 measures and suggestions of measures to 

include. H-GAC will follow the public participation 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 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 continue 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 Manager
G:\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 Short List. We have received your port and

marine control strategy comments and will transfer them to the appropriate agencies. 

Your comment expressed support for increasing marine engine control standards,

promoting the use of clean fuels for marine vessels, and the creation of clean air action 

plans for local ports. We will take this support into account when creating the Final 

Short List for submittal to the Texas Commission on Environmental Quality. You can 

follow the progress and see a 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 Manager 
G:\HGAC\Reports\Final_051009\Appendix D_051009.doc D-24

7.1 Comment from Carol Caul

685 N Post Oak Ln 

Houston TX 77024-4606 

Phone: 713-680-2500 

Email: carolcaul@energybusiness.com 

January 14, 2008 

Transportation Department, Air Quality Section 

Houston-Galveston Area Council 

P.O. Box 22777 

Houston, Texas 77227-2777 

Email: airquality@h-gac.com; fax: (713) 993-4508. 

Dear Air Quality Section: 

Following are my comments on a few of the voluntary and mandatory 

items in HGAC's quantified Short List Control Measures for inclusion in our 

SIP. 

COMMENTS ON HGAC SHORT LIST CONTROL MEASURES 

FOR INCLUSION IN TEXAS SIP 

HGAC should be certain to review proposed legislation 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 creates a new 

category of tax credit bonds to finance State a nd local government initiatives designed to 

reduce 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 the 
G:\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 close 
G:\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 where 
G:\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: 713-680-2500 
G:\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 Measures Short List. The Texas Commission on 

Environmental Quality (TCEQ) and H-GAC continue to examine a wide range of voluntary 

control measures. Your letter commented specifically 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 rather 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. Alternatively, pay as you drive insurance can be implemented by insurance 

providers as a service to their customers. Because of this difference, the pay as you drive 

insurance measure will remain a part of the Final SIP Control 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 taken from data in the Regional 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 cannot be implemented locally, it is not 

included in the “short list”. 

• Fuel reformulations & vehicle 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 systems / idling – mandatory and voluntary: H-GAC is currently working 

with government and business entities within the Houston-Galveston-Brazoria region to 

develop both the infrastructure (such as truck stop electrification or the installation of 

auxiliary power units), the regulatory structure, and the Memoranda of Agreement 

necessary to implement these control measures as part of the SIP.
G:\HGAC\Reports\Final_051009\Appendix D_051009.doc D-35

• Electric vehicles: H-GAC recognizes the practical 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. 

• Stations and facilities for alternative & new fuels: H-GAC appreciates your comments. 

• Compressed work schedules: H-GAC appreciates your comments and has already 

lumped this control measure and teleworking with other commute solution control 

strategies. 

• Heavy Duty Vehicle Border Inspection Program 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.aspx

Sincerely,

   

       Shelley Whitworth

Air Quality Program Manager

 
G:\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 PHA 
G:\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 & Sediment 
G:\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 State 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 examine a wide range of voluntary 

control measures. Your letter commented specifically on several aspects of non-road control 

measure number 45. Responses to each of these points follow: 

• Clean Port Initiative: Thank you for your comment. The Houston-Galveston Area 

Council supports implementation of air quality 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 reductions for this measure would be reduced 

accordingly. 

• OGV Auxiliary Engine & Main 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 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 Manager 
G:\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 recycle 
G:\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.com 
G:\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.3 
G:\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 replacement of internal combustion engine vehicles 

with electric vehicles. H-GAC agrees with your assessment that by adjusting the measure 

to focus on replacing all weight and duty vehicles with electric 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 control measures at the H-GAC SIP website: 

http://www.h-gac.com/taq/airquality/sip/mobile/default.aspx 

Sincerely, 

 

 Shelley Whitworth 

 Air Quality Program Manager 
G:\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, 151

h Floor • Houston, TX 77002-1700 • Phone: 713-755-5101 • Fax: 713-755-8924 
G:\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-139 
G:\HGAC\Reports\Final_051009\Appendix D_051009.doc D-48

( 1980) (County prohibition against the purchase of foreign automobiles where the 

purchase was subject to competitive bidding requirements was found to be invalid). 

Given this, specific legislative revisions in the purchasing requirements may be needed 

(e.g. Tex. Loc. Gov't Code Chapter 262). 

Where a construction project is federally funded (or potentially federally funded) and is 

located in the non-attainment area, Harris County Flood Control District already requires 

contractors to upgrade all pre-Tier2 construction equipment drive trains and engines at a 

rate of at least 20% of the fleet per year and to use low nitrogen oxides (NO,) emissions 

technology. The contractor and subcontractors are also required to apply for funds 

through the Texas Emission Reduction Plan (TERP) Incentive Grants Program to modify 

or purchase diesel equipment with low NO, diesel emissions technology. 

Landscape Ordinance, ld. 29. Under platting requirements, Harris County has adopted 

landscaping requirements for residential and commercial development for unincorporated 

areas. The regulations provide standards for planting trees and shmbs and installing 

landscaping buffers. These regulations are adopted under authority provided in Tex. 

Gov't Code § 232.101 . Harris County regulations further protect Harris County greenery 

by offering incentives to property owners who preserve and take care of existing trees on 

private properties. 

(See hltp://www.eng.hctx .net/permits/pdli'landscape rC!.!S info packa!.!e.pd l). 

Readability for the Public. For readers not familiar with the technical aspects of the SIP 

(and who may be trying to get a grasp of what, why, and how the evaluations came to the 

conclusions included in the various summaries and how the cost-effectiveness of 

proposed control measures compares to what is currently being done or not being done), 

the report needs to provide more information on these aspects. Providing a list of 

acronyms used in the document and their definitions would also be helpful. A key part of 

the report is Section 5 which will be most referenced and should be easy to understand. 

The description column seems to offer for each control strategy either an objective, 

definition, or tactic, but it is not consistent. 

We look forward to actively participating in developing an effecti ve SIP and 

bringing the HGB region into attainment with the 8-hour ozone National Ambient Air 

Quality Standard (NAAQS) as expeditiously as practicable. We appreciate your 

consideration of our comments. If you have any questions, or if we can provide any 

additional infonnation, please cont act, Snehal R. Patel, Senior Assistant County 

Attomey, at 713-755-8284. 

~lJ;tj ~ J. M"~"' H;ll, F;n;t A;,;" '"' 

/ S"'h"l R. P"ol, Soo;oc A;,;"'"' 

Harris County Attorney's Office 
G:\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 Control 
G:\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, 15th 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 Measures Short List. The Texas Commission on 

Environmental Quality (TCEQ) and 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: 

• 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 common 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 account for your suggestion. 

• Electric Vehicles, Id. 7: H-GAC recognizes the practical 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 Lane Users, Ids. 39 and 47: Since this is a voluntary 

measure, it is not necessary that all entities within 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 does not disqualify this 

measure from inclusion in the SIP 
G:\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 encourages them to enter into an MOA so 

that their reduction efforts can be properly cataloged in the SIP. 

• Mandatory or Voluntary Compressed 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 efforts 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 offering this control measure to the entities of the region. 

• Limitations on Idling of Heavy-Duty Vehicles, Id. 126: As noted in your comment, TCEQ 

does promote this control measure in other metropolitan areas throughout 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 control measure. H-GAC is currently working 

with jurisdictions within the Houston-Galveston-Brazoria 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 these 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 participate 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 Whitworth 

 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 Submittal
G:\HGAC\Reports\Final_051009\Appendix E_051009.doc E-1 

Transportations Control Measures (TCMs) were reviewed 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 current Transportation Improvement Plan (TIP) for 

the Houston-Galveston-Brazoria for possible designation with TCM status in the SIP. Once 

projects were singled out for inclusion, project sponsors were notified and agreed to upgrading 

their project(s) to TCM status. The Technical Advisory Committee and H-GAC staff reviewed 

the responses to these notifications and narrowed the possible candidates to the attached list. 
G:\HGAC\Reports\Final_051009\Appendix E_051009.doc 

RECOMMENDED TRANSPORTATION CONTROL MEASURE PROJECTS

CSJ # MPO ID # Sponsor Street Description 

NOx 

Emission 

Reduction 

(tons/day) 

0912-72-145 11972 

Greater Southeast Management District Holman 

Pedestrian Improvements 0.0001862 

0912-72-146 11973 

Greater Southeast Management District 

Elgin, Ennis, Alabama 

Pedestrian Improvements 0.0004562 

0912-72-147 11006 

Uptown Houston Association Westheimer 

Pedestrian / Transit Improvement Program 0.0137628 

0912-71-544 2930 City of Houston 

Columbia Tap Rail to Trail Construct Bikeway 0.0002721 

0912-71-801 10350 City of Houston 

Columbia Tap Union Station Trail 

12' Wide Concrete Shared Use Path with 5’ Bike Lane 0.0005840 

0912-71-655 6085 City of Houston 

Terry Hershey Park

West Houston OnStreet Bikeway Network (Phase 2) 0.0001653 

Total 0.0154266
APPENDIX F 

Detailed Evaluations for On-Road Control Strategies 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\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 encouraging 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 investment, interagency coordination and best 

practices in developing facilities 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, the Houston-Galveston region also has one of 

the highest rates of crashes involving motorists and bicyclists in Texas. 

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

Jackson, La Porte, Missouri City, Pasadena, Sugar Land, and The Woodlands. H-GAC 

plans to continue to work with local entities to identify projects that further the 

development of local bikeway networks as part of the overall regional transportation 

system. 

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

bicyclist commuters: the Texas Medical Center in Houston and the University of Texas 

Medical Branch (UTMB) in Galveston. The 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 telecommute). The 430 walking trips and the 379 

biking trips represent 0.9% and 0.8% respectively of all trips. 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 concentration 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 staff indicate that over 1,000 bicyclists 

now commute to the Texas Medical 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 bicycle and 5.3% walking trips. These are much 

higher than the regional average of 0.3% by bicycling and 2.1% by walking. 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\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, the high cost of driving, and the efforts of 

bicycle and pedestrian action groups. According 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 20181. 

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 percent of these employees bike to work an 

average of 3.5 miles each way. This would mean 21,978 people per day are commuting 

by bicycle by 2018 and reducing 153,845 miles of travel 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 basic process suggested by the MOSERs 

methodology, as follows: 

Variables: EFA: Speed-based composite emission factor after 

implementation (NOx , VOC, or CO) grams/mile) 

EFB: Speed-based running composite emission factor before 

implementation (NOx , 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_051009\BControlMeasure1-Bike-EM_051009.doc 

NVA: Number of vehicles after implementation 

NVB: Number of vehicles before implementation 

TEFAUTO: Auto trip-end emission factor (NOx , VOC, or CO) 

(grams/trip) 

TLA: Average auto trip length after implementation (miles) 

TLB: Average auto trip length before implementation (miles) 

VMTA: Vehicle trips after implementation 

VMTB: 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 emission factors and the assumption that access 

to alternative modes is not through SOV use. 

Equation: 

Daily Emission Reduction = 

C = VMTB * EFA = 

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 over 41 pedestrian and bicyclist projects, representing an 

investment in nearly of $87 million. The 2025 RTP, with subsequent amendments, 

contains an additional 61 pedestrian and bicyclist projects with a projected cost in excess 

of $96 million. In addition, a number of local governments have made significant local 

funding commitments to bikeway development in their current Capital Improvements 

Programs. The cost effectiveness evaluation assumes that a $200 million investment is 

made to implement all pedestrian and bicycle projects in the TIP and RTP and local 

plans, and that this investment 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_051009\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 

Measure Reduction 

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 

$390,625 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control 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 turnover 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 replace 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 including on-road trucks, construction and offroad equipment, marine vessels, and locomotives. 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 emission reductions have been realized and are 

still pending 

IMPLEMENTATION FEASIBILITY 

Programs of this type have been successfully established in Houston, Los Angeles, and 

Sacramento. The program implementation relies on a partnership between the 

transportation planning organization, H-GAC, and TxDOT and FHWA to properly 

distribute CMAQ dollars. H-GAC has dedicated staff time to administer the program 

addressing funding, preparing contracts, conducting 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 participation and has lowered the cost per emission 

reduction during the 2005 fiscal year from previous years.

ANALYSIS 

The benefit of a voluntary retrofit or replacement program targeted at emission reductions 

in the 2015 - 2018 timeframe would center on the replacement of trucks with those 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control Measure 3 Clean Cities_051009.doc 

meeting the 2010 emission standards that call 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 HC1 CO NOx PM HC+NOx Opacity 

1974-78 --- 40.0 --- --- 16.0 No 

1979-83 1.5 25.0 --- --- 10.0 No 

1984-871 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 0.52 15.5 2.03 0.10 2.52 Yes 

2007 (50% of Fleet) <0.5 15.5 ~1.1 0.01 --- Yes 

2010 0.142 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 and 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 alternative fueled vehicles, hybrid-electric drive 

trains, and clean diesel engines. These projects produced NOx, PM, and some VOC 

emission reductions. Individual truck replacement/retrofit projects funded by CMAQ in 

the Houston area in 2008 averaged approximately $20,000 to $40,000 per vehicle with 

typical clean engine costs running at about $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 expected 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, 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\Control 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 area. 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 factors, registration distribution, 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 0.1050
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control 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 emission 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 case 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 about 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 and 2008 truck respectively used a project 

(remaining useful) life of 5 years for the 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 expected to range from $11,000 to $25,000 per ton of 

NOx removed. Some small VOC benefit would 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 emission 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. Cost 

Effectiveness 

($/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-road 

Heavyduty 

Vehicles 

21.6 5 – 12% 1 – 2.5 $11,000 - 

$25,000 NOx 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control 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\Control Measure 7 Electric Vehicles_051009.doc 

Control Measure: #7, Zero Emission (Electric) Vehicles

Category: On-road 

Author: Chris Lindhjem, ENVIRON

DESCRIPTION 

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

percentage of zero emission vehicles (ZEVs) or zero emitting travel through the use of 

plug-in hybrids or other vehicles. This could occur through new purchases or a 

replacement program for existing vehicles. 

IMPLEMENTATION FEASIBILITY 

A study completed by National Renewable Energy Laboratory compares the near- and 

far-term scenario of specifications and retail prices between conventional 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 distance in miles that a fully 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 cycle 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). Electric vehicles have been developed, but are 

generally only applicable for limited range applications. 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 consumers for such specialty vehicles. The 

program could target specific niches to partially achieve emission reductions. Options 

include targeting public or private 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\Control Measure 7 Electric 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 of VOC and 30 tpd of NOx 2018 on-road lightduty emissions in the eight-county HGB ozone 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 conventional 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 emissions 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 highest 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\Control Measure 7 Electric Vehicles_051009.doc 

Furthermore, in the 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 Vehicles1 

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 Vehicles1 

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 performance characteristics inferior to those of 

a conventional vehicle.2

Table 5 illustrates the specification comparison 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 emission 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.pdf 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control Measure 7 Electric 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) 

$35,0003 Lithium-ion batteries 5.6 hp 105 mph 

Miles Electric Vehicles 

ZX40ST (

Electric Truck) 

$18,4002 72-volt electric motor and a 150-amphour battery pack. (50-60 miles per 

charge) 

5.6 hp 25 mph 

ZX40S (Electric Truck) $19,4992 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–

$16,0004

Lead-acid batteries (30–50 miles per 

charge) 

5 hp 25 mph 

General Motors EV1 

(Battery electric vehicles) 

$40,0005 Gen II 1999, NiMH (150 miles per 

charge) 

72 hp 80 mph 

Honda EV Plus $53,0004 12 V NiMH (80–110 miles per charge) 66 hp 80+ mph 

Toyota RAV4 EV $40,0004 95 amp-hour NiMH battery pack (80-

120 miles per charge) 

67 hp 78 mph 

Toyota Prius Hybrid $19,9956 274V NiMH battery pack 58 hp 

Heavy-duty Vehicles 

Navistar International $85,000 340 Volt Lithium Ion Battery 225 hp 

Balcon Electric Truck7 $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 average 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 model 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 the cost effectiveness 

down to that of other strategies, the relative cost of production should be no more than 

$2,000 more per vehicle than conventional vehicles to make the air quality benefit close 

to other mobile sources measures. 

 

3 http://en.wikipedia.org/wiki/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-newswire.com/ens/may2008/2008-05-21-092.asp 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control Measure 7 Electric 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 + NOx 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control 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 consist 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 demonstration project on specific Class 8b Heavy Duty 

Truck (HDT) fleets. 

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

cetane number of 48 or greater. CAE diesel would consist of diesel to which additives 

were supplemented, producing a cetane number increase of 5 points with no changes in 

other parameters from TxLED fuel. FT diesel fuel would consist of typical FT fuel with 

a cetane number of 74 and an aromatic content of 0.1 percent (Clark et. al., 1999). 

IMPLEMENTATION FEASIBILITY 

Large-scale production of Fischer-Tropsch fuels are currently being researched by several 

oil companies (EPA, 2002), however, production is currently 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 measure, 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 with this production could potentially be 

burdensome for diesel manufactures that would 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 the 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control 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 from 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. Along with the average fuel economy derived 

from the MOBILE6 technical documentation, the 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 all diesel engines (about 19.7 tpd, prior to 

adjustments for ambient conditions and other emission reduction measures) or to the 

entire or portions (estimated here at 10%) of fleets of larger Class 8 heavy-duty trucks 

that represent 12.9 tpd of NOx.

EMISSIONS BENEFIT 

Estimated emission reductions from this measure for the fleets representing 10% of Class 

8, or if applied across all diesel 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 increase 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 conditions) more than California Diesel (CEC, 

2003)1

. The cost of these fuels however has been decreasing due to advances in the 

technology and economies of scale, and will continue to decrease if demand increases as 

it is beginning to in California. In California, FT fuels are increasingly sold as a neat 

fuel or a blend stock to produce California reformulated diesel fuel.

 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control 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 (delivery type or short drayage vehicles). 

Using 10 cents a gallon and the emission rates in Table 1, the NOx reduction would be 

$41,000 per ton of NOx reduced. The highest cost-effectiveness scenario applies the 

cetane enhancement cost and benefit to the larger Class 8b truck emissions resulting in a 

cost effectiveness of $623,000 per ton of NOx reduced. 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

# 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 California’s Petroleum Dependence”, A Joint Report of the 

California Energy Commission and California Air Resources Control Board, 

P600-03-005F, August 2003. 

Clark, et. al. (1999), Clark, Nigel, Mridul Gautam, Donald Lydons, Chris Atkinson, 

Wenwei Xie, 1999, “On-Road Use of Fischer-Tropsch Diesel Blends”, SAE 

Technical Paper Series, 1999-01-2251, Washington D.C., April 1999. 

EPA. 2002, “Fact sheet: Clean Alternative Fuels: Fischer-Tropsch”, EPA420-F-00-036, 

http://www.epa.gov/otaq/consumer/fuels/altfuels/420f00036.pdf

EPA (2003), “The Effect of Cetane Number 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 Funding 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 buses to replace the older buses. Buses that are 

replaced should be scrapped. 

IMPLEMENTATION FEASIBILITY 

Apart from TERP funds, there is very little funding available for school bus purchase, e.g. EPA 

school bus grants (made available in Texas through the Blue Skyways Collaborative) fund 

retrofits of diesel powered school buses, not new bus purchases; EPA’s Smartway Clean Diesel 

Initiative funds trucks (school buses are not included); and CMAQ 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 available 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, respectively, 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% matching funds, and, if Chambers, Liberty and Waller 

counties do not implement the I/M program, LIRAP funds cannot be utilized in these three 

counties. 

Having one organization in the HGB area focused on providing funds for school bus purchases 

should make communication with the school districts 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. However, at the point of writing, none of the 

manufacturers of school bus engines has announced the availability of an engine meeting this 

standard – it appears that Caterpillar will discontinue production of school bus engines 

completely and International is unlikely to produce an engine to the 2010 standard until 2012. 

Even if a school district is considering 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. Additionally, 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 offer 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 TERP grants under the Replacement of On-road Heavy 

Duty Vehicles category. Grant recipients are eligible for reimbursement of up to 80% of the 

eligible incremental costs for the purchase or lease of the replacement vehicles, not to exceed an 

incentive amount that results in a cost-effectiveness 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 least 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 earlier 2004 NOx standard (2.0 gms/bhp-hr) and 

greater than 90% less NOx than buses manufactured 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 using 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 emissions 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 20,0001

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 life 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 effectiveness 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 the 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 these buses by 2018 (each ISD replacing an average 

of 10.5 buses per year); a dedicated school bus fund could aim to accelerate the replacement of 

25% of the fleet. 

EMISSIONS AFFECTED 

Emissions affected are on road heavy 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 NOx 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 effectiveness 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/implementation/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-ParkPrice-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 parking and another 9% pay 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 spaces averaging $245.00 per month. 

There are also 2,300 metered spaces downtown, which may be replaced by 750 multiplespace metering machines which would allow for 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 parking can affect mode choice and reduce VMT by shifting 

commute and other trips to alternative modes. A 2001 parking management plan prepared 

for Central Houston, Inc, called for “a comprehensive city-sponsored and promoted 

program to promote alternative means of transportation to the central business district.” 

(Moore and Assoc. 2001) According to the 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 that 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, the 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 over $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-ParkPrice-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 where rail transit is a nearby substitute for driving; transit 

ridership on the corresponding rail systems 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-term 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 charges, employment, and parking availability is 

from Central Houston. Most employees working 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 assumed to be located in Central 

Houston, where employees are most likely to pay some or all of their parking costs. 

There is a total of 3,182,938 employees projected for the Houston-Galveston region in 

2018. According to H-GAC2 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 the price elasticity factor, it is assumed that 

each 100 employees generates 77 vehicle trips (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 basic 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-ParkPrice-EM_051009.doc 

Variables: EFA: Speed-based composite emission factor after 

implementation (NOx , VOC, or CO) grams/mile) 

EFB: Speed-based running composite emission factor before 

implementation (NOx , VOC, or CO) (grams/mile) 

NVA: Number of vehicles after implementation 

NVB: Number of vehicles before implementation 

TEFAUTO: Auto trip-end emission factor (NOx , VOC, or CO) 

(grams/trip) 

TLA: Average auto trip length after implementation (miles) 

TLB: Average auto trip length before implementation (miles) 

VMTA: Vehicle trips after implementation 

VMTB: 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 emission factors and the assumption that access 

to alternative modes is not through SOV use. 

In this analysis VMTB is derived by multiplying the number of employee vehicle trips by 

the elasticity associated with a 25% increase in average daily parking rates (from $22 to 

$27.50 per day) resulting in a switch to alternative modes that would result in vehicle trip 

reduction. Total driving costs effective in the decision to respond to parking prices are the 

variable weekly costs of driving: gasoline and oil plus parking. Insurance costs are 

factored in a different way and are not assumed to affect the response to an increase in 

parking price for the purpose of this analysis. 

According to H-GAC3

 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 total percentage increase is 2 percent. 

By multiplying the estimated number of vehicle trips (279,202) by a price elasticity of –

0.2 and a change of 2.2 percent, we derive a 0.44 percent trip reduction; 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-ParkPrice-EM_051009.doc 

associated with this trip reduction is derived by multiplying the average round trip work 

length (40.0 miles) weekdays, yields 35,086 miles of reduction per day. 

Equation: 

Daily Emission Reduction = 

C = VMTB * EFA = 

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. However, the cost associated with a surcharge 

and preferential parking program will largely 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 national elasticities and may be considered for use in ozone 

plan after review of key assumptions. 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

ID Name Description 

Affected 

Source 

Affected 

Emissions 

(tpd) % Tpd 

Cost 

Effectiveness 

($/ton) 

47 

Parking 

surcharge 

25% 

surcharge 

on parking in 

Central 

Houston 

On-Road 

Lightduty 

vehicles 

40.7 VOC 

30.3 NOx 

0.02 0.009 

0.007 

$5,137 

VOC+NOx 

REFERENCES
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure47-ParkPrice-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 Central Houston, Inc., January 23. 2001. 

 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure51ParkCashOut-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 law after studies showed cash allowances in 

lieu of parking encourage employees to find alternate means of commuting to work, such 

as public transit, carpooling, vanpooling, bicycling, or walking. Parking cash-out offers 

the opportunity to improve air quality and reduce traffic congestion 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 declined by 17% after Parking Cash Out was 

introduced at various urban and suburban worksites, 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 found opportunities to reduce 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/Walk

Commute Mode Share

Before Cash Out

After Cash Out

Figure 1. Cashing Out Impacts on Commute Mode (Shoup, 1997). 

Parking Cash Out results in reduced automobile commuting and increases in carpooling, 

transit and non-motorized travel. 

In a later report, (Shoup, 2001), Shoup notes that 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 park free at work. He notes that case studies 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure51ParkCashOut-EM_051009.doc 

and statistical models suggest that, compared 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 which to support an analysis for the HoustonGalveston area. The number of employees who have free or subsidized parking at their 

worksites is unknown. However, employees who pay all or some of the cost of parking 

are generally located in Central Houston and the Texas Medical Center. In addition, the 

precise number of employers who require employees 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 (creating the incentive to participate). For 

this analysis, the commuters that might be offered parking cash-out are assumed to be 

located in Central Houston or the Texas Medical Center. This analysis 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 subsidized parking. It is also assumed that the 

results in California are applicable to Houston, since there 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 which to support a projected emission reduction. 

There are a total of 3,182,938 employees projected 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 basic process suggested by the MOSERs 

methodology, as follows: 

Variables: EFA: Speed-based composite emission factor after 

implementation (NOx , VOC, or CO) grams/mile) 

EFB: Speed-based running composite emission factor before 

implementation (NOx , VOC, or CO) (grams/mile) 

NVA: Number of vehicles after implementation 

NVB: Number of vehicles before implementation 

TEFAUTO: Auto trip-end emission factor (NOx , VOC, or CO) 

(grams/trip) 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure51ParkCashOut-EM_051009.doc 

TLA: Average auto trip length after implementation (miles) 

TLB: Average auto trip length before implementation (miles) 

VMTA: Vehicle trips after implementation 

VMTB: 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 emission factors and the assumption that access 

to alternative modes is not through SOV use. 

In this analysis, VMTB 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 alternative 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 = VMTB * EFA = 

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 could be neutral (i.e., cost of the cash out equal 

or even less than the parking lease cost savings. Depending on program structure, cost per 

ton could be as low as $0. 

COMMENTS

This evaluation is based on hypothetical assumptions 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\BControlMeasure51ParkCashOut-EM_051009.doc 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

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-Road

Lightduty 

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 Effects of California’s Parking Cash-out 

Law: Eight Case Studies,” Transport Policy, Vol. 4, No. 4, 1997, pp. 201-216. 

Thornton, 2005. “Beating the Parking 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\BControlMeasure55-FuelSubsidy-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 for Technology Assessment1

 found that 

gas prices would rise from the 1998 average $1.25/gallon to $5.60 to $15.14 if they 

included subsidies such as tax subsidization of the oil industry; government program 

subsidies; protection costs involved in oil shipment and motor vehicle services; 

environmental, health, and social costs of gasoline usage; and other externalities. The 

report notes: “The majority of people paying just over $1 for a gallon of gasoline at the 

pump has no idea that through increased 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 and urban development strategies”. 

The German Technical Corporation (GTZ), an international cooperation enterprise for 

sustainable development with worldwide operations, has compiled detailed reports on 

international gasoline prices. From this compilation it can be seen that international 

fluctuations in fuel prices are enormous. Generally oil producing countries have 

significantly lower prices than seen elsewhere, while non-oil producing countries that 

attempt to include external costs of gasoline use have much higher prices when compared 

with U.S. pump prices. Their full report can be found at 

http://www.gtz.de/en/dokumente/en-international-fuelprices-part2-2007.pdf. The report finds 

that European, Chinese, Mexican and representative 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 driving that would occur if subsidies were 

reduced to the extent they appear to be in the 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 Analysis Of The Hidden External Costs Consumers Pay To Fuel Their 

Automobiles. Kimbrell et al, 1998. 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure55-FuelSubsidy-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 vehicle 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 factor to roughly represent the 

differences amongst other countries that incorporate more of the 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 determine whether any of these prices would 

fully or best represent U.S. non-subsidized prices. A simple average was determined to 

be a reasonable rough estimate of an example 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, Kuwait, 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 increase 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. Therefore a correction factor of 0.5 similar to that applied for 

ozone action day programs in the U.S. is applied to the results to add conservatism 

pending additional data on driving responses to very substantial price changes. 

With the correction factor it is estimated that 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, available 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\BControlMeasure55-FuelSubsidy-EM_051009.doc 

Using the above approach, it is estimated that removal of fuel subsidies would reduce 

VMT by 27,203,228 miles per day in the region. 

EMISSIONS ANALYSIS

The emissions analysis utilized the basic process suggested by the MOSERs 

methodology, as follows: 

Variables: EFA: Speed-based composite emission factor after 

implementation (NOx , VOC, or CO) grams/mile) 

EFB: Speed-based running composite emission factor before 

implementation (NOx , VOC, or CO) (grams/mile) 

NVA: Number of vehicles after implementation 

NVB: Number of vehicles before implementation 

TEFAUTO: Auto trip-end emission factor (NOx , VOC, or CO) 

(grams/trip) 

TLA: Average auto trip length after implementation (miles) 

TLB: Average auto trip length before implementation (miles) 

VMTA: Vehicle trips after implementation 

VMTB: 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 emission factors and the assumption that access 

to alternative modes is not through SOV use. 

In this analysis VMTB was derived as described above by multiplying the percentage 

change in travel (17%) by daily light duty vehicle travel in the region. The resulting 

reduction is 27,203,228 miles per day. 

Equation: 

Daily Emission Reduction = 

C = VMTB * EFA = 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure55-FuelSubsidy-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 internal so, if applied correctly 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 

Measure Reduction 

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-Road 

Lightduty 

vehicles 

40.7 VOC 

30.3 NOx 

17 6.9 

5.1 

<$100/ton 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure57-ConPrice-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 periods of peak demand in order to reduce traffic congestion. 

By providing drivers a financial incentive to take mass transit 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 vehicles on the road. The application on urban 

roads is limited to a small number of cities, including London, Stockholm, Singapore and 

Milan, as well as a few smaller towns. Four general types of systems are in use; a cordon 

area around a city center, with charges for passing 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 facility 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. Critics maintain that congestion 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 Transportation selected five metropolitan 

areas to initiate congestion pricing demonstration projects under the Urban Partnerships 

Congestion Initiative, for $1 billion of federal 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 east, 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 program for a downtown area in 2006 and 

concluded that the program would result in very small emission reductions and for a very 

high price because of feasibility and mobility issues. 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 Freeways 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 Houston 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 redesignation of 83 miles of Houston's existing reversible High 

Occupancy Vehicle (HOV) lanes to automated High Occupancy Toll (HOT) lanes. HOT 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure57-ConPrice-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 five 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, installation and operation of new electronic toll 

collection, optical monitoring equipment 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. For 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 increase in emissions from the current case, it is 

suggested that this measure needs a separate study to determine how to account for air 

quality benefits. 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\ControlMeasure59-FuelTaxes-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 advocated as a way to reduce pollution, conserve 

energy, and for certain countries reduce dependence on imported oil for foreign policy 

reasons. Placing high taxes on fossil fuels makes alternative (and often less polluting) 

fuels such as natural gas, biodiesel, or electric batteries more attractive, and put price 

pressure on manufacturers and 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 University of California at Davis argues 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. Sperling notes that at current average prices of 

$2.50 a gallon the variable tax would raise $17 billion in one month – more than half the 

$25 billion bail-out under discussion. 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 pay for the roads they use and argue that 

the user tax should not be applied to mass transit projects. Critics argue transportation 

fuel taxes are a regressive tax, because low-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 gallon 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 vehicle categories and travel from within as 

well as from without the region 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 the 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\ControlMeasure59-FuelTaxes-EM_051009.doc 

Houston area alone so that external trips are not affected. In addition it is assumed that 

about 10% of the VMT would go to bordering counties to obtain gasoline at lower prices. 

Therefore VMT of 154,202,748 is potentially reducible from raising gasoline taxes. 

This analysis assumes that the tax on gasoline was increased to be equivalent to 

Vancouver, Canada. 2008 average U.S. prices of $3.85 per gallon in mid-2008 were 

representative and currently (November 2008) they 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 federal and 20 cents a gallon in Texas from the 

Vancouver taxes of $1.15, the increase would amount to 76.5 cents per gallon, or a 21 

percent increase in 2008. It is further assumed 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 basic process suggested by the MOSERs 

methodology, as follows: 

Variables: EFA: Speed-based composite emission factor after 

implementation (NOx , VOC, or CO) grams/mile) 

EFB: Speed-based running composite emission factor before 

implementation (NOx , VOC, or CO) (grams/mile) 

NVA: Number of vehicles after implementation 

NVB: Number of vehicles before implementation 

TEFAUTO: Auto trip-end emission factor (NOx , VOC, or CO) 

(grams/trip) 

TLA: Average auto trip length after implementation (miles) 

TLB: Average auto trip length before implementation (miles) 

VMTA: Vehicle trips after implementation 

VMTB: Change in VMT as a result of implementation 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\ControlMeasure59-FuelTaxes-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 emission factors and the assumption that access 

to alternative modes is not through SOV use. 

In this analysis VMTB was derived as described above by multiplying the percentage 

change in travel (4%) by daily light duty vehicle travel in the region. The resulting 

reduction is 6,168,110 miles per day. 

Equation: 

Daily Emission Reduction = 

C = VMTB * EFA = 

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; therefore costs per ton are less than zero. 

COMMENTS

This evaluation is based on national short-term elasticities and broad assumptions 

regarding the appropriate percentage increase in gas taxes. It may be considered for use 

in ozone plan after review of key assumptions. The feasibility of implementing this 

measure is low. 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

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/ton 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure60-VMT-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 potentially useful for reducing miles traveled. 

Under this measure, a charge would be levied 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 envision this charge being collected during the 

annual registration process based upon the difference between the previous year’s 

odometer reading and the current reading. This 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 potential 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 considering 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 vehicles 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 exception of emergency vehicles, delivery vehicles, 

and high occupancy vehicles such as vanpools or taxis. Based on current gasoline, oil, 

vehicle maintenance and insurance costs grown at 3 percent 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 STEP 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 price 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure60-VMT-Tax-EM_051009.doc 

data. Table B-21 of their appendix1 contains a list of cents 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. The Appendix written by Deakin and Harvey does 

not contain details about assumptions regarding elasticities, the number of people subject 

to a given measure, base prices, base transportation network characteristics and other 

inputs necessary for replicating the analysis for another area such as Houston. The values 

are reportedly based on generalized elasticity coefficients that include combined values 

of travel time, vehicle costs, toll prices, fuel taxes, transit fares, and parking prices. Some 

researchers quoted by Littman in http://www.vtpi.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 ownership 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 equivalent to a price elasticity of 0.4, which 

is slightly below the lower range noted above 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 term 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 1997 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure60-VMT-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 fee 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 approach that would yield sufficient emission 

reductions to merit additional and more intensive evaluation. The amount of this fee is 

loosely based on the concept that 10 cents is the per-mile charge 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 vehicle categories and travel from within as 

well as from without the region 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 assessed 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 represents a 16 percent increase in the cost of 

driving and the price elasticity of driving with respect to price is 0.2 we estimate that a 

3.2 percent in VMT will result from a VMT tax 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 basic process suggested by the MOSERs 

methodology, as follows: 

Variables: EFA: Speed-based composite emission factor after 

implementation (NOx , VOC, or CO) grams/mile) 

EFB: Speed-based running composite emission factor before 

implementation (NOx , VOC, or CO) (grams/mile) 

NVA: Number of vehicles after implementation 

NVB: Number of vehicles before implementation 

TEFAUTO: Auto trip-end emission factor (NOx , VOC, or CO) 

(grams/trip) 

TLA: Average auto trip length after implementation (miles) 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure60-VMT-Tax-EM_051009.doc 

TLB: Average auto trip length before implementation (miles) 

VMTA: Vehicle trips after implementation 

VMTB: 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 emission factors and the assumption that access 

to alternative modes is not through SOV use. 

In this analysis VMTB was derived as described above by multiplying the percentage 

change in travel (3.2%) by daily light duty vehicle travel in the region. The resulting 

reduction is 4,934,488 miles per day. 

Equation: 

Daily Emission Reduction = 

C = VMTB * EFA = 

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; therefore 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 resulting percentage increase in driving costs 

per mile. In addition it is assumed that a cost 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 considered by many other nonattainment areas. 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure60-VMT-Tax-EM_051009.doc 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

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/ton 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Measure 75_83 Traffic_051009.doc 

Control Measure: Traffic signalization improvements, 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 improvements, reversible lanes and intersection improvements are 

an ongoing part of the H-GAC plan and Transportation Implementation Plan (TIP). 

According to practice in evaluating CMAQ projects, as well as straightforward logic, 

traffic flow improvements encouraged by improved 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 return to about the same flow level as prior to 

the signal or other improvements (although better able to handle higher traffic volume). 

Table 1 provides a list of proposed projects that are being considered 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 2 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Measure 75_83 Traffic_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 Intersections 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Measure 75_83 Traffic_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 general strategy called Intelligent Transportation 

Systems, ITS) are to improve traffic operations. These projects 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 project is improvements in the average speeds. 

Improvement in flow of traffic can be measured as average travel speed for freeways in 

miles per hour before and after the implementation of an ITS project and delay reductions 

in vehicle-hours (to estimate reduced idling) 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 means, 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-grams/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 (VMT) will give emission benefits in kilograms/day. 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Measure 75_83 Traffic_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 those proposed projects 

were $230,527,658. 

COMMENTS

This evaluation is based on the cost and evaluation 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+NOx 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure85-ReduceTransitFares-EM_051009.doc 

Control Measure: #85, Reduced Transit Fares 

Category: On-Road 

Author: Barbara Joy, Earth Matters Inc 

DESCRIPTION 

Transit fare decreases can increase transit ridership and encourage some individuals who 

are currently solo drivers to use transit for some travel. This switch reduces vehicle miles 

of travel and air pollution emission 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 coordinated 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 fares 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 example, 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 Quick 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 $2.25 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure85-ReduceTransitFares-EM_051009.doc 

All fares are rounded to the nearest nickel, dime, or quarter. 

According to the H-GAC transportation modeling department1

 379,606 person trips are 

made by transit in the region on an average day out of a total of 22,115,558 trips, 

representing 1.7% of daily trips. Assuming this percentage is roughly 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 change 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 elasticity of 0.50 tells us that a 10% change in 

price would lead to a 5% change in demand. Transit use can increase for changes in 

variables such as transit service and transit fares. Transit use is most elastic with respect 

to transit service and then transit fare. However, transit use alone is not necessarily a 

measure of a corresponding decrease in vehicle 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 decrease in transit fares would be expected to 

increase transit use by 10 percent but only a 1.5 percent decrease in auto use. This 

difference is due to the fact that the decreased 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 trip2

. 

• The commuter route fares are lowered to $2.00 (the average annual fare for a 

person using service twice per day 260 days 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 use with respect to transit fare is used. 

It is 0.10. If the program operates for three years before emission benefits are 

estimated, then longer range elasticity should be used. The long range elasticity 

of auto use with respect to transit 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\BControlMeasure85-ReduceTransitFares-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 emission factor for VOC for same day is 

0.231 grams per mile 

The following utilizes the basic process suggested by the MOSERs methodology, as 

follows: 

Variables: EFA: Speed-based composite emission factor after 

 implementation (NOx , VOC, or CO) grams/mile) 

EFB: Speed-based running composite emission factor before 

implementation (NOx , VOC, or CO) (grams/mile) 

VMTA: 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 composite emission factors. 

In this analysis VMTA was derived above. 

Equation: 

Daily Emission Reduction = 

C = VMTA * EFA = 

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 million 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 increases and administration costs are not known at 

this time. 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure85-ReduceTransitFares-EM_051009.doc 

Total annual costs in transit fare decreases 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 assumptions 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 million 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure90-SubBusService-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 services offered in the Houston and other 

metropolitan areas. The analysis presented here focuses on a subscription bus service 

catering to those that are least likely to use transit – white collar workers whose work 

load would make a quiet stress-free ride to work with internet access offered very 

attractive. Among the major obstacles to transit use are limitations in service between 

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

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

could increase substantially. An example of such a service would be between the Katy 

areas to downtown areas such as the Texas Medical Center. 

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

areas, including personalized rapid transit, subscription bus service, business first buses, 

easier access between Metro and other services such as those provided by TREK (such as 

a universal card), and personalized transit planning. There is a likelihood of some pentup or latent demand for transit service that specifically serves individuals because of time 

spent in traffic, gas prices, maintenance and parking costs that can be significantly offset 

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

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

them how to easily use transit from one point to another (such as home to work, work to 

lunch spots or meeting locations, and work to home). Such a service could even be 

provided online. In addition, some buses could be equipped with fold-down tables and 

wireless internet connections (for example through cell-phone companies) so that people 

could work while on the buses, and feeder shuttles could bring people from transit stops 

directly to work centers. 

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

provide these services. It is assumed that 100 new business buses (buses equipped with 

fold-down tray tables and wireless internet) seating 35 people each providing service 

directly from neighborhoods to specific work locations would operate four trips per 

morning and four per evening. Service would also be augmented by the addition of 100 

shuttle buses to provide service between current METRO stops and (1) under-served 

residential area too far from transit centers or park and ride lots to utilize them; and (2) 

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

access. The shuttle buses are assumed to seat 15 people each and operate six trips each 

morning and six each evening. For the purpose of simplicity it is assumed that currently 

planned expansions to METRO service would accommodate the extra ridership created 

by the shuttle services. If this measure results in emissions significant enough to merit 

further review, this assumption, along with the others would need to be refined. 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure90-SubBusService-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 marketing, the development of an easy-to-use internet personal 

planning site, and fine-tuning the routes that the vehicles will be 80% full on an average 

day. 

The emissions analysis uses the following key variables: 

• There are 100 buses seating 35 people operating four round trips (per person) per 

day; at 80% capacity this is equivalent to 11,200 people per work day; 

• There are 100 shuttle buses seating 15 people operating 6 round trips (per person) 

per day; at 80% capacity this is equivalent 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 viable 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 the shuttles is therefore based upon an 

average weekday shuttle mileage 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 represented 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 process suggested by the MOSERs methodology, as 

follows: 

Variables 

EFA: Speed-based composite emission factor for passenger 

vehicles (NOx , VOC, or CO) grams/mile) 

EFB: Speed-based running composite emission factor for transit 

vehicles (NOx , VOC, or CO) (grams/mile) 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure90-SubBusService-EM_051009.doc 

VMTA: Average Daily Change in passenger VMT as a result of 

increased transit service 

VMTB: 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 composite emission factors. 

In this analysis 

VMTA is 18,000 new transit users * 40 mile average round trip work distance = 736,000 

miles per weekday. 

VMTB is SUM(VMT for business buses and VMT for shuttle buses) = 22,000 

miles/day. 

Equation: 

Daily Emission Reduction from passenger vehicles = 

C = VMTA * EFA = 

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 hourly fees paid to transit vehicle leasing 

companies used in Houston such as AFC. Based on a conversation with Trek, these costs 

are $54.85/hour to cover the driver, the vehicle and other costs such as fuel and 

insurance. Both the business buses and the shuttles would operate from 4:30am to about 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure90-SubBusService-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 are 59.8 tons. Cost effectiveness is 

$456,500/ton. 

COMMENTS

This evaluation is based on hypothetical assumptions and data for this program and may 

be considered for use in ozone plan after review 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 control measures such as Tier 2 tailpipe 

standards. Other measures are being evaluated for the H-GAC region, such as California 

LEV (low emission vehicles), cleaner fleets and wider application of the Inspection and 

Maintenance program. If these or other similar programs were implemented, the 

emission factors used to evaluate programs affecting the amount of travel (such as this 

one) would be smaller – each mile driven would 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\BControlMeasure90-SubBusService-EM_051009.doc 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

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 

$456,500 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control 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 improvements (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 advantages in that no new (other than the 

buses themselves) infrastructure is required and reduced fuel consumption. The main 

disadvantage is that a fraction of emissions reductions (about 25%) would be applied to 

already low emissions new bus engine emissions. 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 opening in 2004 of 7.5 miles of a 

system. The planned and potential expansion beyond the current network would require 

significant investment as well as identifying 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 lower than the light rail option, but it is 

unknown how much this option would cost. The buses 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 they 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\Control Measure 92 Transit Options_051009.doc 

PUBLIC ACCEPTANCE 

The light rail or other options to bus routes have been extensively 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 from the conventional bus service. Often 

passengers would not know the difference. 

ANALYSIS 

The analysis uses the forecast transit bus emissions 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 trips 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 expansion of the network could be up to an 

order of magnitude increase by 2018, and could 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 17.47
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control 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 the initial 7.5 mile system. 

With an expected life of 30 years, the annual cost was estimated at $16.5 million. This 

does not count the operating or maintenance cost of the light-rail or the cost benefit 

compared with buying and operating buses (previous 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 counted in the benefits is the potential for rail 

to encourage greater ridership than the alternative 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 fuel consumption. Other sources (SF Metro, 

2008) note $150,000 cost and 30% improvement. The fuel consumption benefit would 

however be significant, and depending upon the 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. Model year 2009 trucks would be expected to have almost ten 

times the benefit. 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control Measure 92 Transit Options_051009.doc 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

# 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.htm 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure102-FreeCircService-EM_051009.doc 

Control Measure: #102, Free Circulator Service to Major Generators 

Category: On-Road 

Author: Barbara Joy, Earth Matters Inc 

DESCRIPTION 

This measure would provide free shuttle/transit services connecting remote areas with 

major activity generators. Among the major obstacles to transit use are limitations in 

service between residential and employment areas. If transit services were designed 

specifically for certain residential areas to highly used underserved employment areas, 

transit use could increase substantially. An example of such a service would be between 

the Katy area to downtown areas such as the 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-GAC1

 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 seating 15 people each would provide service 

directly from under served residential neighborhoods to the above employment centers. 

This hypothetical scenario would service slightly 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\BControlMeasure102-FreeCircService-EM_051009.doc 

ANALYSIS 

This analysis is based upon the hypothetical scenario described above and an assumption 

that after a year of marketing, the development of an easy-to-use internet personal 

planning site, and fine-tuning the routes that the vehicles will 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 equivalent 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 viable 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 process suggested by the MOSERs methodology, as 

follows: 

Variables 

EFA: Speed-based composite emission factor for passenger 

vehicles (NOx , VOC, or CO) grams/mile) 

EFB: Speed-based running composite emission factor for transit 

vehicles (NOx , VOC, or CO) (grams/mile) 

VMTA: Average Daily Change in passenger VMT as a result of 

increased transit service 

VMTB: Average Daily Change in transit vehicle VMT as a result 

of increased transit service 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure102-FreeCircService-EM_051009.doc 

Emissions changes from vehicle trips and associated start emissions are evaluated 

through the use of composite emission factors. 

In this analysis 

VMTA is 101,250 new transit users on an average work day * 40 mile average round trip 

work distance = 4,050,000 miles per weekday, or 2,892,857 miles per average day. 

 

VMTB is VMT for shuttle buses = 240,000 miles/day. 

Equation: 

Daily Emission Reduction from passenger vehicles = 

C = VMTA * EFA = 

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 and is by that fact alone not considered cost 

effective and is not recommended for further consideration. 

COMMENTS

This evaluation is based on hypothetical assumptions and data for this program. Other 

assumptions could result in different results. 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure102-FreeCircService-EM_051009.doc 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

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-Road 

Lightduty 

vehicles 

40.7 VOC 

30.3 NOx 

<0 0.08 VOC 

NOx 

Increase of 

0.71 

Not cost 

effective 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure106-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 area 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 schedules program, which operates under the 

umbrella of the Commute Solutions program, helps employers implement several 

measures including telecommuting, carpooling, vanpooling, alternative parking and 

compressed work weeks. A program specifically 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 effects 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 for evaluating the emission benefits of this 

measure. These are as follows: 

• Total employment projected by H-GAC for 2018 is 3,183,0001

. The above-cited 

figure of 20% would be 636,600 employees. 

• The average round trip work distance for Houston area employees is 40 miles; 

therefore daily VMT reduction on a compressed work week day is 25,464,000 and 

on an average day (1/7th 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.pdf
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure106-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 basic process suggested by the MOSERs 

methodology, as follows: 

Variables: EFA: Speed-based composite emission factor after 

 implementation (NOx , VOC, or CO) grams/mile) 

EFB: Speed-based running composite emission factor before 

implementation (NOx , VOC, or CO) (grams/mile) 

VMTB: 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 = VMTB * * EFA = 

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 assumptions and data for this program and may 

be considered for use in ozone plan after review of key assumptions. The feasibility of 

achieving a 20% participation rate from all Houston 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 evaluated. 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_051009\BControlMeasure106-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 decreased turnover, reduced parking demand, and 

possibly fewer sick days would be expected to offset costs. Current outreach/advertising 

and marketing costs for the Commute Solutions program are $2.5 million annually. If we 

conservatively assume half would be spent 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 assumptions and data for this program and may 

be considered for use in ozone plan after review of key assumptions. 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

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-Road 

Lightduty 

vehicles 

40.7 VOC 

30.3 NOx 

2.3 0.93 

0.69 

$2,140 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure108-rideshare-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 online travel programs such as Travelocity. 

The program is internet based and uses the consultant NuRide, Inc. 

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

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

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

to the philosophy that people sharing rides provide a valuable service to their community, 

NuRide offers its members rewards each time they use the ridesharing program. By 

accumulating "NuRide Miles," members earn enough points to acquire gift cards and gift 

certificates from a variety of corporate sponsors such as Old Navy, TGI Fridays, Macy’s 

and many other familiar retailers and restaurants. 

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

grow from a few hundred carpoolers to nearly 5,000 in August 2008. The incentives 

mentioned above earn points at dozens of participating retailers. Points are only earned 

when, for each ridesharing day, ridesharers match themselves with an online carpool and

fill out a survey form (all ridesharers must fill out the survey or none will receive credit). 

Other incentives are the ease and convenience, 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 average of twice per week at an average trip 

distance of 15 miles. 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure108-rideshare-em_051009.doc 

EMISSIONS ANALYSIS

The emissions analysis utilized the basic process suggested by the MOSERs 

methodology, as follows: 

Variables: EFA: Speed-based composite emission factor after 

 implementation (NOx , VOC, or CO) grams/mile) 

EFB: Speed-based running composite emission factor before 

implementation (NOx , VOC, or CO) (grams/mile) 

TEFAUTO: Auto trip-end emission factor (NOx , VOC, or CO) 

 (grams/trip) 

VTB: Number of new carpoolers. 

AVR: Average vehicle ridership in carpools 

TLB 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 emission factors and the assumption that access 

to the carpool is not through SOV use. 

Note that if there are 2.7 people 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 = VTB* ((AVR-1)/AVR) * TLB * 2* Frequency * EFA = 

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 NOx 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\BControlMeasure108-rideshare-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 before 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 the cost effectiveness would therefore be 

$1,014 per ton. 

COMMENTS

This evaluation is based on hypothetical assumptions and data for this program and may 

be considered for use in ozone plan after review of key assumptions. 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

ID Name Description 

Affected 

Source 

Affected 

Emissions % Tpd 

Cost 

Effectiveness 

($/ton) 

108 Internet 

ridematching 

NuRides plus 

other internet 

ridematching 

services grow 

at same rate 

NuRides grew 

between 2007 

and 2008. 

On-Road 

Lightduty 

vehicles 

40.7 VOC 

30.3 NOx 

1.3 0.52 

0.38 

$1,014 

 
G:\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 transportation through trip sharing with vanpools.

The program began operation in 1996 and is funded using Surface Transportation 

Program (STP) funds, METRO local funds and employer incentives, which provide 

reduced monthly costs to participating employees. As of August 2008 the vanpool 

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

vanpools average 54.6 miles per day (round trip). 

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

about 100 million miles per year, assuming a 260-day work year. As vanpools are driven 

about 11 million miles per year to offset the 111 million miles that would have been 

driven in passenger vehicles. 

IMPLEMENTATION FEASIBILITY 

The approach here is to use the current progress 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 deterioration 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 measure 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 emission calculation for the average light-duty 

(commute vehicle) and the van used in the primary commute, as follows: 

Variables: EFA: Composite emission factor for commute vehicle (NOx, VOC, 

or CO) grams/mile for the average light-duty vehicle 

EFB: Van (LDGT4) emission factor (NOx, VOC, or CO) 

(grams/mile) 

Emissions changes from vehicle trips and associated start emissions are evaluated 

through the use of composite emission 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 = VMTA * EFA – VMTB * EFB

82 grams per day NOx benefit per van = 10.4 passengers * 54.6 miles * 0.171 

gram/mile NOx – 54.6 miles * 0.267 gram/mile 

COST AND COST-EFFECTIVENESS 

The total subsidized cost of the program 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 ton of VOC + NOx for the air quality 

benefits alone. Vanpool programs are also administered for congestion relief benefit and 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control Measure 109 Vanpoo_051009.doc 

the benefit of removing 7,100 vehicles from the commuting peaks has not been 

incorporated into the cost benefit. 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

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 + NOx 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control 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 inefficient operation that can produce unwanted air 

pollutants. Idling however also occurs during normal driving and other operations such 

as when the engine powers necessary accessories including for example man-lifts or 

concrete tumblers. Therefore it is not possible 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 often 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 policed to eliminate idling. 

PUBLIC ACCEPTANCE 

A voluntary program can achieve enthusiastic support because infrastructure to reduce 

fuel costs can be paid for from public funding. 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 alternative 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 duration 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 operations, it would be difficult to gauge how much 

that would be. For an extraordinary total, even if an astounding 10% of the HGB 

population of 5,628,101 idled 10 extra minutes in a single occupancy vehicle, the 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control 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 passenger 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 idling includes an upper end estimate 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 trucks (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 expanded to all heavy-duty vehicles, then 0.73 tpd 

could be reduced. The long duration idling 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 likely largest source of idling trucks, and so 

reducing idling in other areas would produce 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 season when ozone events would likely occur. 
G:\HGAC\Reports\Final_051009\Appdx_F_051009\Control Measure 126 Reduced Idling_051009.doc 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

ID Name Description 

Affected 

Sources 

Affected 

Emissions 

(tpd) % Tpd 

Est. Cost 

Effectiveness

($/ton)

126, 147, 

148 

Idle limits 

for 

heavyduty 

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 Using Long Duration Truck Idling Emission 

Reductions in State Implementation Plans and Transportation Conformity,” 

Office of Transportation and Air Quality,” 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 inspection 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 safety inspections at border crossings (HDDV 

inspections are also carried out at weigh stations throughout the state). 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 located around the border cities. In these zones, which stretch 20 

miles on both sides of the Mexican border, drayage 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 are 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 designated commercial zones if their trucks have effective safety 

controls in place. However, at the point of writing, funding to continue the program has not been 

appropriated and the future of expanding 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 counterparts (325 trips)”. 

In order for implementation of emissions inspections 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 current 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 pass/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 Sierra Club are opposed to opening the border to 

Mexican trucks. 

 

ANALYSIS 

Opening the Texas/Mexico border 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. However, it should be noted that the Nogales study was 

conducted in 2006, prior to the pilot program allowing the limited number of long haul trucks to 

cross the border. Thus, almost all of the cross 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, about 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 implementable, 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, it 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 using 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 grams/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 the low NOx kit. In the Nogales truck study 

approximately 300 MY 1993-98 vehicles were sensed (approximately 16% were Mexican plated 

trucks, 74% dual plated trucks, and 10% US plated trucks). For the purposes of analyzing this 

measure, it is assumed that 90.5% of these trucks have the NOx defeat device in place. As 

required by the Consent Decree, the cost of reflashing MY 1993-98 trucks is borne by the engine 

manufacturers. 

Environmental Systems Products Inc (ESP) estimates 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 distribution in Harris County and 

the MOBILE6 mileage accumulation. 

NOx reduction per vehicle: 0.503 tons per year 

Total NOx reduction: 136.8 tons per year or 68.3 for 6 month pilot project 

Tons per day NOx reduction (assuming 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 included as this should be borne by the engine 

manufacturers. It is assumed that approximately the same number of MY 93-98 HDDVs will be 

identified as in the Nogales truck study. Cost effectiveness is therefore 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 University: Border Transportation Studies Review, 

Aug 2005.

M J Bradley and Associates: Cross Border In-Use Emissions Study for Heavy Duty Vehicles, 

Nogales, AZ, September, 2006. 

Environmental Systems Products Inc (ESP): Remote Sensing proposal for Diesel Emission 

Control Evaluation, Nov 2008 

US EPA: Anne Wick, Vehicles 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 emissions 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 counties. While initial TCEQ regulations 

required that the ASM/OBD program be implemented 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 for counties not required to implement an 

I/M program to opt-in as follows: (petition to TCEQ) must be made by a resolution 

adopted by the governing body of the participating county and the governing body of the 

most populous municipality in the county. Implementation of the Low Income Repair 

and Assistance Program (LIRAP) is not a requirement 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 addressed. 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 could be in place in the three counties until 

2010/11 at the earliest. By that point, it is estimated 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 number of vehicles subject to tailpipe testing, 

it may be difficult to convince all of the 47 existing 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) allow 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 performing 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 the program in the first years by granting low 
 

G:\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 and older vehicles be either tested at an 

ASM/OBD inspection station in one of the five existing I/M program counties or at a 

DPS referee station. Alternatively, a very small number of inspection stations within the 

three counties could be allowed to offer both 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 same as in the existing five HGB counties, 

i.e. $27.00 (plus $12.50 safety inspection fee). 

A program adopted in the three 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 testing. 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 tested, concerns could be 

raised regarding allowing the oldest most highly polluting vehicles to avoid emissions 

testing. Adopting a fee lower 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 emissions in the three counties with and 

without an ASM/OBD I/M program 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 number 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, additional costs have not been added to account for 

uptake of LIRAP funds for repair and replacement of vehicles in the proposed new 3 

county program area (the average LIRAP repair 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 average 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 including 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, Environmental Systems Products (ESP) 

Personal contact with Danny Knauth, Texas Department of Public Safety. 

ENVIRON 2006. “Low Income Repair and Assistance Program Evaluation and 

Improvement, Prepared for the Houston Advanced Research Center, H72AB, 

September 2006. 

Texas State Implementation Plan Revision, 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 Houston-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 GVWR and 4-wheel drive vehicles that cannot be 

tested on a dynamometer are subject to two-speed 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 expected 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 similar 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 final cutpoints for ASM testing based on real world experience, 

which more strongly target only true failures. These alternative final cutpoints receive the same 

level of credit in MOBILE6 as the previous EPA 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 software will be required to incorporate the new 

cutpoints. Once the analyzer manufacturers have 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 area wishes to adopt 

the more stringent cutpoints, it is likely that the 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 result in a higher failure rate among 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 failing and requiring repair. While it is difficult to find a reliable 

estimate of the expected increase in the percentage of vehicles failing the ASM test, as the 

number of MY 1995 and older vehicles drops annually, 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 which are MY 1995 and older and eligible for ASM testing. For 

inspection stations offering both ASM and OBD testing, it may become increasingly uneconomic 

to continue to have to pay up to $4,000 per year for a maintenance contract for the emissions 
 

G:\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: current TCEQ/DPS rules allow inspection stations to be granted a 

waiver from offering ASM testing to be able to offer OBD testing 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 failure 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 increased funding now available under LIRAP should, 

however, mitigate these repair costs to some extent and may encourage more vehicles to be 

scrapped if they can’t be repaired - thus further 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 cutpoints 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 emission reduction benefits from the 

vehicles estimated to be replaced at an additional 1% failure rate (average 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 runs 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 test (current failure rate is 

9.5%), the estimated total annual cost of this measure is $1,128,199.6 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 effectiveness: the number of MY 1995 and 

older vehicles drops by 16% per year (from HARC/Environ LIRAP report); cost of software 

modifications to all the ASM analyzers for HGB area only, approximately $75,000 (does not 

include any costs to upgrade the VID); average LIRAP 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 Gregory Green, Director Certification and 

Compliance Division, to EPA Regional Air Division Directors, entitled “Revised Final 

cutpoints for ASM 5015 and 2525”. 

Dave Sosnowski, State Measures and Conformity Group, EPA Office of Transportation and Air 

Quality. 

ENVIRON 2006. “Low Income Repair and Assistance Program Evaluation and Improvement, 

Prepared for the Houston Advanced Research Center, H72AB, September 2006. 

Chad Lenz, TCEQ I/M team, 2006 correspondence. 

Carl Nord, Environmental Systems Products (ESP). 

Danny Knauth, Texas Department of Public Safety. 

Graciela Lubertino, HGAC personal communication. 
APPENDIX G 

Detailed Evaluations for Non-Road Control Strategies 
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 5b Locomotive_051009.doc 

Control Measure: #5, Voluntary Retrofit/Replacement Program - Locomotive 

(and other replacement retrofit funding, Measures 39 and 40)

Category: Nonroad 

Author: Chris Lindhjem, ENVIRON 

DESCRIPTION 

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

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

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

many emission reduction projects of many different types of emission sources, including, 

on-road trucks, construction and off-road equipment, marine vessels, and locomotives. To 

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

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

Because the most recent projects have just been approved, not all of the emission 

reductions have been realized and are still pending. 

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

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

funding program was relatively limited at $5,000,000 in 2008 

(http://www.blueskyways.org/pdf/clean-diesel-FY08.pdf) for the states of Arkansas, 

Louisiana, New Mexico, Oklahoma, Texas, Iowa, Kansas, Missouri, Nebraska, and 

Minnesota. Nationally this program was funded at $49.2 million in 2008, of which, 

$27.6 million was available for National Clean Diesel Funding Assistance Program. Half 

of the National Clean Diesel Funding Assistance Program is dedicated to public fleets. 

Other monies were distributed to the States, research, and a revolving loan program. 

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

other programs. 

This measure describes the issues and potential for locomotive replacement projects. 

IMPLEMENTATION FEASIBILITY 

The TERP program has worked well by co-funding fleet improvements for on-road and 

off-road vehicles and equipment. TCEQ has developed the organization and principles to 

administer the program formalizing the application process and providing assistance to 

owner/operators in implementing the emission reduction projects. The industrial owners 

of equipment have been enthusiastic participants of the 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 reconsidered 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 reduction projects is the replacement 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 benefit of normal fleet turnover and the additional 

benefit of the EPA rule. The emission standards 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 time of remanufacture; so the existing engines will be rebuilt 

gradually throughout their remaining useful life regardless of incentives. 

The emissions standards and projected EPA emission factors are shown in Tables 1a and 

1b, depending on the duty cycle chosen to certify 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 considerable 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 standards, 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 Pre-1973 0.48 1.28 13.0 0.32 

Tier 0 – original 1973 – 2001 1.00 5.0 9.5 0.60 

Tier 0 – final1 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 – final1 2008 / 2010 0.55 5.0 7.4 0.22 

Tier 2 – original 2005 0.30 1.5 5.5 0.20 

Tier 2 – final1 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 rebuild 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 Pre-1973 1.01 1.83 17.4 0.44 

Tier 0 – original 1973 – 2001 2.10 8.0 14.00 0.72 

Tier 0 – final1 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 – final1 2008 / 2010 1.20 2.5 11.00 0.26 

Tier 2 – original 2005 0.60 2.4 8.10 0.24 

Tier 2 – final1 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 rebuild 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 emissions 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 implementation of control strategies, such as TERP 

and TxLED, have or should be included in the 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 

Equipment

Population NOX 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 26.591 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 expected 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 guarantee 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 replacement of switching engines with a specially 

designed locomotive that already meets the Tier 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 until 2017, and that standard is subject to a 

technology review, so Tier 4 engines may not be widely 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 said 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 engines are available, then about half of the 

switching engines could be replaced with lower emitting engines. The benefit in 

emissions (shown in Table 1b) between replacing a Tier 0-final engine (with 1.2 and 11.8 

g/hp-hr VOC and NOx emission rates) is half that 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 pre-controlled engines were the 
G:\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 engines can be replaced with low emissions 

switch engines because the lower emitting switching engines available at the time of this 

writing at the end of 2008 have limited maximum power. Often switching engines are 

used for some line-haul duty and so must have sufficient power for that duty as well. 

Therefore, arbitrarily half of the remaining maximum penetration 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 effectiveness of the TERP projects to date and inform 

the forecast for future projects. 

The TERP locomotive cost effectiveness of projects 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 average 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 available, 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 ton 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 standards resulting in half the individual benefit, 

the potential emission reductions would be about half as large as has already been 

realized in the TERP program. Because not all switching engines might be available for 

replacement, a lower emission reduction potential was chosen. 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

# 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 - $7,000 
G:\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 have been used across the US to reduce 

emissions using a variety of programs providing 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 different types including on-road trucks, 

construction and off-road equipment, marine vessels, and locomotives. To date, about 

$300 million of projects have been approved in the HGB area from 2002 through 2008 

with 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 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.org/pdf/clean-diesel-FY08.pdf) for the states of Arkansas, 

Louisiana, New Mexico, Oklahoma, Texas, Iowa, Kansas, Missouri, Nebraska, and 

Minnesota. Nationally this program was funded at $49.2 million in 2008 of which $27.6 

million was available for National Clean Diesel Funding Assistance Program. Half of the 

National Clean Diesel Funding Assistance Program is dedicated to public fleets. Other 

monies were distributed to the States, research, and a revolving loan program. 

There may be additional funding sources available 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-funding fleet improvements for on-road and 

off-road vehicles and equipment. TCEQ has developed the organization and principles to 

administer the program formalizing the application process and providing assistance to 

owner/operators in implementing the emission reduction projects. The industrial owners 

of equipment have been enthusiastic participants of the 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 reconsidered 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 emission reduction projects is to replace 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. 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 from on-road and off-road vehicles and 

equipment. 

EPA recently announced proposed emission standards for marine engines (EPA, 2008) 

that include an analysis of the expected benefit of normal fleet turnover of the final rule. 

The emissions rates for baseline engines prior emission control, and current and proposed 

emission standards shown in Table 1a and 1b for two representative tug propulsion 

engines. The actual standards and emission factors 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) 

Baseline1

(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 determined 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) 

Baseline1

(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 determined 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 control strategies, such as TERP and 

TxLED, have or should be included in the estimates. Tables 2a and 2b should be 

considered as reasonable estimates rather than exact figures. 

Table 2a. Approximate 2018 baseline nonroad mobile source missions inventory. 

Summer Weekday Emissions (tons) Aggregate Equipment 

Category 

Equipment

Population NOX 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 26.591 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 3.3
G:\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 expected 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, 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 focused on harbor craft, which include tugs, 

excursion, and supply vessels because these vessel are more likely to spend most of their 

time within the area. Nearly all of the projects involve repowering propulsion and/or 

auxiliary engines with those meeting lower emission standards. The Tier 3 engines are at 

the time of this writing just coming into production for Category 1 (lower engine 

displacement per cylinder) affording additional NOx reductions below the current 

program benefits. The implementation schedule for Tier 3 Category 2 and Tier 4 

Category 1 and 2 engines would make it difficult to use these lower emission engines 

ahead of the 2018 time frame. Some tugs, the primary 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 hampered by the availability of lower emission 

Category 2 engine designs. 

The marine TERP projects dramatically increased starting in 2005. The individual project 

(a replacement engine) resulted in about 5.5 tpy of NOx reduction. The next step in 

emission standard is the production 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 year 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 engines, the fraction of 
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 5b Marine_051009.doc 

NOx emissions from Tier 1 and older models 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 address 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 emission rates provides a potential 45% reduction is 

possible or 4 tons per day of NOx as an upper limit. Arbitrarily half of this maximum 

penetration rate was chosen as a lower limit of what could be achieved.

COST AND COST-EFFECTIVENESS 

Table 3 indicated the cost and cost effectiveness of the TERP projects to date and inform 

the forecast for future projects. 

The TERP marine project cost effectiveness to date ranges from $1,000 to $9,000 per ton 

of NOx reduced. The average cost effectiveness of about $2,500 for TERP projects was 

calculated from the TERP summary table cost 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\Control Measure 5b Offroad_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 have been used across the US to reduce 

emissions using a variety of programs providing 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 different types including on-road trucks, 

construction and off-road equipment, marine vessels, and locomotives. To date, about 

$300 million of projects have been approved in the HGB area from 2002 through 2008 

with 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 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.org/pdf/clean-diesel-FY08.pdf) for the states of Arkansas, 

Louisiana, New Mexico, Oklahoma, Texas, Iowa, Kansas, Missouri, Nebraska, and 

Minnesota. Nationally this program was funded at $49.2 million in 2008 of which $27.6 

million was available for National Clean Diesel Funding Assistance Program. Half of the 

National Clean Diesel Funding Assistance Program is dedicated to public fleets. Other 

monies were distributed to the States, research, and a revolving loan program. 

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

other programs. 

This measure describes the issues and potential for construction and offroad engine 

replacement projects. 

IMPLEMENTATION FEASIBILITY 

The TERP program has worked well by co-funding fleet improvements for on-road and 

off-road vehicles and equipment. TCEQ has developed the organization and principles to 

administer the program formalizing the application process and providing assistance to 

owner/operators in implementing the emission reduction projects. The industrial owners 

of equipment have been enthusiastic participants of the program, and provide a large 

portion of the program funds. 
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 5b Offroad_051009.doc 

PUBLIC ACCEPTANCE 

The current funding mechanism has been acceptable to nearly all parties, but the cost 

effectiveness goals may need to be reconsidered 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 emission reduction projects is to replace 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. 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 from on-road and off-road vehicles and 

equipment. 

The EPA has been setting emission standards for 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 engines to be phased in primarily from 2011 

through 20151

 as shown in Table 1b. Emission standards for NOx and PM will 

dramatically reduce emissions in future years 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+ 

NOX 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) NOX

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.htm
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 5b Offroad_051009.doc 

Engine Power Tier 

Model 

Year 

NMHC+ 

NOX CO PM 

Tier 1 1997 

9.25 (6.9) NOX

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) NOX

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) NOX

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) NOX

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) NOX

KW>560 1.3 (1.0) HC 8.5 0.54 (0.4) (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 complying 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% per 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 25-503 

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 

2012-20141 

3.4 75-100 2

Final 2015 

0.02 

 0.19 0.40 

5.0 

Phase-in 0.19 0.40 

Phase-out 4.0 

Or/ alt NOx 

2012-20141 

3.4 100-175 2 

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 3.5 
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 5b Offroad_051009.doc 

EMISSIONS AFFECTED 

Table 2 shows the approximate summary emissions for nonroad equipment emissions for 

2018. The actual emissions may vary from day to day (such as weekday and weekend 

day) and depend upon whether the implementation of control strategies, such as TERP 

and TxLED, have or should be included in the 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 

Equipment

Population NOX 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 26.591 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 measure number 3 that 

include TERP and congestion mitigation and air quality or other funding programs for 

on-road vehicles. Therefore this control strategy description focuses 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 the 
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 5b Offroad_051009.doc 

inflation rate, the new engine costs are expected 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, 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 emission reductions from construction and other 

smaller nonroad engine projects than marine 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 future until the Tier 4 engines are produced. 

As with other off-road measures, it is difficult to determine 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 retired 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 the benefit of replacing a precontrolled engine. 

COST AND COST-EFFECTIVENESS 

Table 3 indicated the cost and cost effectiveness 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 precontrolled with Tier 3 engines), then the cost 

effectiveness could be 3 times higher. 
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 5b Offroad_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 Measure 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 equipment) or all construction projects could 

effect emission reductions by encouraging fleet turnover to those meeting lower emission 

standards. A TxDOT plan provides an example of an incentive program. Alternatively, 

many other states and localities have suggested or implemented emission standard (by 

model year) requirements for construction contracts. (EPA, 2008, 

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

control and others PM control, the incentives or requirements for new equipment based 

would control both pollutants. 

IMPLEMENTATION FEASIBILITY 

Based on a review of the contracting clauses to date, there are two basic methods, a 

voluntary or incentive approach and a fixed 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 passed on to the cost of the project. 

PUBLIC ACCEPTANCE 

The general public is unlikely to be affected by this strategy. The cost of incentives 

would need to be considered carefully because the contracting costs could increase and 

greater than expected by restricting how many contractors could qualify.

ANALYSIS 

TxDOT (2004) issued a contracting incentive to encourage the use of advanced emission 

controlled engines in equipment used for road construction projects. The incentive was 

described as shown in Table 1 with Table 2a describing the model year 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 Measure 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+ 

NOX 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) NOX

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) NOX

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) NOX

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) NOX

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) NOX

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) NOX

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 distribution 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 Measure 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 complying 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% per 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 (NEDC) (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 would reduce emissions 

significantly even though the older equipment may represent the minority of the 

equipment. 

EMISSIONS AFFECTED 

TCEQ estimated construction equipment emissions by construction category based on 

local survey data collected as shown in Table 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 25-503 

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 

2012-20141 

3.4 75-100 2

Final 2015 

0.02 

 0.19 0.40 

5.0 

Phase-in 0.19 0.40 

Phase-out 4.0 

Or/ alt NOx 

2012-20141 

3.4 100-175 2 

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 3.5 
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 8 Construction incentives_051009.doc 

Table 3. Construction equipment emission estimates 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 NOX 

DCE - Agricultural Activities 817 0.01 0.05 0.14

DCE - Boring & Drilling Equipment 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 Operations 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 Operations 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, Municipal-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 Measure 8 Construction incentives_051009.doc 

The maximum benefit that could be attained is if, by 2018, all equipment used in 

construction meets Tier 4 standards. 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 resulted in an expected emission reduction of 

17% for VOC and 66% for NOx despite the fact that pre-Tier 4 equipment is expected to 

represent less than 50% of equipment by 2018. 

COST-EFFECTIVENESS 

EPA (2004) estimated that the cost effectiveness 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 replacement would not occur and 

the initiative would merely affect the relative purchase price of new equipment. This 

would be considered a low cost scenario. 

As an alternative high cost estimate, one could consider the cost of replacing a Tier 3 

engine with a Tier 4 engine. For an example, based on the TERP results (outlined in 

Measure 5), the cost of replacement projects for nonroad engines has been averaging 

$40,744 with an average life of 7 years. The emission 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 - 

$19,000 
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 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: Control of Emissions from Nonroad Diesel 

Engines,” Office of Transportation and Air Quality, EPA420-R-04-007, May 

2004. 

TxDOT (2004), Special Specification 5018, “Incentive 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 measure 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 programs designed to promote the use of clean 

lawn and garden equipment. The primary benefit of these programs will be to reduce 

VOC and CO emissions. 

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

equipment with electric versions including several in California 

(http://www.aqmd.gov/tao/lawnmower.html, 

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

program (http://www.cleanairforce.org/2008MowingFlyer.pdf). These programs have 

worked out many of the issues related to transfer of ownership and determining 

appropriate incentives. 

IMPLEMENTATION FEASIBILITY 

In order to change behavior, it might be helpful to provide a rebate 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 consumers who were already 

considering clean equipment or replacing engines 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 another 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 being 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 and 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 residential use. Most lawn and garden programs 

focus on lawn mowers, but Table 1 shows that the lifetime emissions from leaf blowers is 
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control measure 21 Lawn and Garden Exchange_051009.doc 

about half that of lawnmowers in Table 2, and so with a proportional 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 control 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 measure 21 Lawn and Garden Exchange_051009.doc 

Table 2. Approximate 2018 baseline nonroad mobile source missions inventory. 

Summer Weekday Emissions (tons) Aggregate Equipment 

Category 

Equipment

Population NOX 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 26.591 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 emission rates for the example equipment due 

to be replaced by electric versions. Replacing 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 benefit, 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 measure 21 Lawn and Garden Exchange_051009.doc 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

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 - $18,000 
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 33 Locomotive Freight Efficiency_051009.doc 

Control Measure: #33, Rail Efficiency 

Category: Nonroad 

Author: Chris Lindhjem, ENVIRON

DESCRIPTION 

This strategy suggests projects that might improve rail efficiency requiring less activity 

from line-haul locomotives. Some measures to effect this improvement could be 

public/private partnerships while others might be implemented by the railroads. 

Railroads have been improving their efficiency through technology and operational 

measures. The technologies include wheel and rail lubrication, better bearings, more 

efficient engines, perhaps other technologies yet to be identified. The operation changes 

include idle reduction, improved aerodynamics, longer trains, and improved training and 

evaluation of engineers to reduce braking, idling, and other inefficient operations. 

IMPLEMENTATION FEASIBILITY 

Efficiency measures need to be defined in more detail in order to determine the 

improvement in emissions. The additional benefits (reduce fuel consumption, safety, or 

others) beyond air quality benefits would account for some of the cost of the measures, 

and the level of investment by public or private entities would need 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 technology 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 freight 
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 33 Locomotive 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 Figure 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 where locomotives would otherwise need to 

brake and idle while awaiting other trains), free flow operations to avoid closing local 

roadways (such as through grade separation projects), regrading or straightening routes 

(to reduce mileage and fuel consumption), or other projects. 

The types of projects that would improve rail efficiency would be specific to the route 

and current or forecast activity conditions. Also, 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

Year

Line-Haul Revenue Freight Efficiency (ton-mile/gallon)

BNSF

KCS

UP
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control Measure 33 Locomotive Freight Efficiency_051009.doc 

than air quality including safety, such as for grade separation, and reduced road 

congestion by removing traffic that would 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 transportation 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. Also, it will not be possible to segregate the air quality benefit 

from other benefits of each project. Therefore, it is not possible to estimate the cost and 

cost effectiveness of these measures. 

SUMMARY OF RESULTS 

Expected 

Emission 

Measure Reduction 

# 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=13 
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control 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 effects emission reductions from HGB area ports 

and private terminals. The plan could cover several or all emissions sources associated 

with marine activity include water and shoreside activities as outlined by EPA’s Clean 

Ports USA (http://www.epa.gov/otaq/diesel/ports/index.htm). But the focus in this 

description is the larger ocean-going vessel strategies because smaller commercial marine 

and shoreside (nonroad, locomotive, and trucking) port initiatives 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 health risks posed by air pollution from port-related ships, 

trains, trucks, terminal equipment and harbor craft. 

(http://www.cleanairactionplan.org/about/default.asp) The primary purpose of this 

California plan is the reduction particulate matter emissions where the primary purpose of 

the HGB plan might be VOC and NOx 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 voluntary retrofit/replacement 

programs described in this report under measure 5. 

IMPLEMENTATION FEASIBILITY 

There are several complexities in implementing 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 ports or the state, and the methods used to 

enforce the program still needs to be defined. 

PUBLIC ACCEPTANCE 

While the general public may encourage emissions improvement from ships, the costs 

incurred and effects to business may be less well known. 
G:\HGAC\Reports\Final_051009\Appdx_G_051009\Control 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 regulations. 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 sources that have been addressed in other 

measures, especially nonroad measure 5 evaluated in this report. The cargo handling 

equipment (CHE) would fall under the category of all nonroad engines 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 emitting 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 described below include provisions for low sulfur 

fuel and engine emission controls worldwide with additional controls near regions 

defined by nations as sensitive to OGV pollution. The United States championed by EPA 

is applying to define the US as a sensitive region requiring such emissions controls. 

Based on proposals to ‘International Convention for the Prevention of Pollution from 

Ships (MARPOL) Annex VI’ this year, a progressive 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%) effective from 1 January 2012; then progressively to 0.5 %, 

effective from 1 January 2020, subject to a feasibility review to be completed no later 

than 2018. (http://www.imo.org/environment/mainframe.asp?topic_id=233#annexvi). In 

addition, the sulphur dioxide emission control area (SECA) sulfur levels would be 

lowered from 1.5% currently to levels comparable 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 standards resulted in a minimal NOx reduction 

compared to the baseline emission factors and had no effect on PM. However, the Marine 

Environment Protection Committee (MEPC) of the International Maritime Organization 

(IMO) has agreed to proposed amendments to the MARPOL Annex VI regulations to 

reduce NOx emissions from engines beginning 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\Control 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 

Aggregate Equipment Summer Weekday Emissions (tons)

Category NOX 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 reductions 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 portion 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 reduction would affect emissions well 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\Control Measure 45 Clean Port_051009.doc 

The emission inventory for OGV supplied by TCEQ 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 engines with high emission rates. Two approaches 

exist to reduce emissions at dock: shoreside (plug-in) grid power provided, and use of 

hood or bonnet that routes the exhaust to a scrubber system that is either barge mounted 

or shore-based. 

There may be limitations to how much berthing emissions may be affected by shoreside 

power. For vessels that do not often visit, it may not be possible or cost effective to 

retrofit the vessel to allow a plug-in device. Also, some vessels have significant boiler 

emissions due to steam requirements (that 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 (roughly an hour at each end of the vessel call) 

to bring shore grid power online to the vessel including time to physically connect the 

power lines and balancing the vessel power grid. So shoreside 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 relative 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 propulsion Residual 0.5 1.1 14.0 

Medium speed 4-stroke propulsion Distillate 0.5 1.1 13.2 

Medium speed 4-stroke auxiliary Residual 0.4 1.1 14.7 

Medium speed 4-stroke auxiliary Distillate 0.4 1.1 13.9 

The distillate fuel in Table 1 represents diesel fuel prior to any additional controls such as 

was implemented with TxLED fuel. So use 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\Control 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 device 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 retrofit of engines, while the Tier III standard 

of 3.4 g/kW-hr (or 80% control) would likely require 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. This would result in about a 12.5% emission 

reduction in 2018. 

COST AND COST-EFFECTIVENESS 

Vessel Speed Reduction 

The costs with regard to vessel speed reduction are associated with the added time that 

the products are in transit instead of sold and vessel’s crew is on duty. This can be 

difficult to determine, but could still be significant. 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 the 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, and the auxiliary loads of that vessel while in 

port. California highly values the PM emission 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 values 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\Control Measure 45 Clean Port_051009.doc 

OGV Main and Auxiliary Engine Emissions Improvements 

A cost study for implementing the international 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 designs have not yet been finalized so the 

cost is not known at this time. 

 

SUMMARY OF RESULTS 

Emission 

Reduction 

Measure Potential 

# Name Description 

Affected 

Sources 

Affected 

Emissions 

(tpd) % Tpd 

Est. Cost 

Effectiveness 

($/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 Rulemaking 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 The California Baseline, December 8, 2005 

ARB (2007), Technical Support Document: Initial 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 Methodologies and Best Practices in Preparing Port Emission 

Inventories,” Final Report, Prepared for EPA, April 4, 2006. 
APPENDIX H 

Detail Evaluations for Weight of Evidence Control Strategies 
G:\HGAC\Reports\Final_051009\Appdx H_051009\Control 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 restart the engine would be considered an 

annoyingly significant delay. This measure would seek to limit excessive idling when 

equipment is not required immediately. Suggested periods for limiting idling could be as 

little as 15 minutes maximum. Many on-road trucks have factory-installed engine shut 

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

be added to existing equipment. 

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

to a period that would not cause typical operational problems. But operator training could 

provide significant idle reduction perhaps beyond idle shut-off devices. 

IMPLEMENTATION FEASIBILITY 

Engine shut off devices could be part of a cofunded opportunity, but operator training 

could be another opportunity for reduced idling 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 would 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, NONROAD model documentation, 2005) as shown, for 

example, in Table 1, the idle emissions are responsible for 1.4% of all emissions. Not all 

engines operate with the same profile as the 8-mode testing cycle shown in Table 1 and 

so may idle more or less than that shown. On the other hand, it is not possible to 
G:\HGAC\Reports\Final_051009\Appdx H_051009\Control 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 occur 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 percentage, 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 engines may be cost effectively retrofitted with 

automatic engine shut-offs, a 50% effectiveness 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 control 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. 

Table 2. Approximate 2018 baseline nonroad mobile source missions inventory. 

Summer Weekday Emissions (tons) Aggregate Equipment 

Category 

Equipment

Population NOX 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
G:\HGAC\Reports\Final_051009\Appdx H_051009\Control measure 10 Construction idling_051009.doc 

Summer Weekday Emissions (tons) Aggregate Equipment 

Category 

Equipment

Population NOX 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 26.591 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 that the equipment idles 

more than that, the benefit of the project could 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 benefits. The VOC benefits were 

not estimated because the predominant source of VOC emissions are small gasoline 

nonroad engines, and so would not be able to demonstrate idle reductions. 

COST AND COST-EFFECTIVENESS 

The benefit of idle reduction would almost always be positive in terms 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 

Measure Reduction 

# 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 ~ $0 
G:\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 Income Repair Assistance Program (LIRAP), 

implemented as part of the AirCheckTexas Vehicle Emissions Testing program (I/M) by 

increasing the number of on road light duty gasoline vehicles scrapped, and would also make 

separate funds available to help with purchase of new on road heavy duty diesel vehicles 

(HDDV) to replace old, highly polluting vehicles. 

IMPLEMENTATION FEASIBILITY 

LIRAP is implemented in Brazoria, Harris, Fort 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 scrapping heavy duty diesel vehicles. However, 

as funds for diesel scrappage would not come from 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 for 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 rose to 74%. However, it should be noted that 

of the total number of 13,044 vouchers issued in FY 08, 4,307 vouchers were 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 additional 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 replacing 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 the 
G:\HGAC\Reports\Final_051009\Appdx H_051009\HGAC Measure 21 Scrappage_051009.doc 

poverty levels (the new income eligibility level added in 2007). On the assumption that owners 

of the 3188 vouchers which were not redeemed need help in addition to receiving the vehicle 

replacement amounts offered in the program ($3,000 for 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 year), 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 interest 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 outreach on TERP to smaller 

trucking companies, which may have older vehicles, could be implemented through the Texas 

Motor Transportation Association 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 program for new truck purchase or the purchase of 

used, pre-2007 heavy-duty trucks retrofitted with an EPA verified emission control technology, 

with the requirement that the new purchase replace a truck that is scrapped. The EPA grant 

could be used to leverage additional funds by borrowing from another lending 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 truck purchasers a loan at lower interest 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 emission reductions being treated as State Implementation Plan 

(SIP) credit. 

In 2007, approximately 440 on-road HDDVs in the HGB area were replaced with a new or 

newer on-road vehicle using TERP funds (thus 440 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. Identification of highly polluting HDDVs which may 

be good candidates for scrappage and replacement could be carried out through the use of remote 

sensing devices at DPS weigh stations. 

Emissions reductions from scrapping an additional 3188 light duty gasoline vehicles were 

calculated using MOBILE6 emissions factors for light duty gasoline vehicle 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 trucks in the HGB area in 2007 was 0.959. For the 

purposes of this calculation it was assumed that 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 gasoline emissions in the 5 county HGB area and on 

road heavy duty diesel emissions 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 reductions 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 incentive ($3,000) to replace and scrap the estimated 

3188 light duty gasoline vehicles 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 grant awarded per vehicle being $59,655. 

Total cost of replacing 220 HDDVs is estimated 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 $6,818 
G:\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 Transportation Association (TMTA): www.tmta.com 

TCEQ Texas Emission Reduction Plan (TERP) data: www.tceq.state.tx.us 

US EPA Smartway program: www.epa.gov
G:\HGAC\Reports\Final_051009\Appdx H_051009\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 Insurance (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 mileage drivers are, in essence, subsidized by 

lower mileage drivers since all are charged the same premiums after accounting for 

driving history related to accidents and traffic 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 September 21, 2008 article in the Baltimore Sun1, 

participating motorists can save an average 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 are other benefits. According to a recent 

Brookings Institution Hamilton Project study2, Economist Aaron Edlin estimates benefits 

to insurance companies for reduced accidents to be roughly $33 per vehicle (and even 

that is only a temporary gain until other firms match its new policies), while the social 

benefits from reduced accidents and congestion alone would be roughly $118 per vehicle. 

As noted by (Litman, 2005), in these programs existing rating factors are incorporated so 

higher-risk motorists pay more per unit than 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 percent of total travel in a given region. 

This measure would affect both commute and non-commute travel. 

 

1

 http://www.baltimoresun.com/news/traffic/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 2008 
G:\HGAC\Reports\Final_051009\Appdx H_051009\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 choice 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 the potential benefits of mileage programs and 

similar programs involving changes in the price of driving. These estimates range from 

1.8 to about a 20 percent reduction in driving per individual in the program. The sources 

of these estimates include: 

1. Todd Littman’s “Distance-Based Vehicle Insurance 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 the Mile Auto Insurance”, 1999 

Economic Policy Institute; and, most recently, 

4. Brookings Institution Hamilton Project, July 2008 the 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 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 price data. Table B-21 of their appendix3

contains a list of cents 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: 

 

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 1997 
G:\HGAC\Reports\Final_051009\Appdx H_051009\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 change 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 are 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 categories of emissions, including start, 

tailpipe, evaporative, running loss, etc. 

All results are expressed as tons per day reduction and percent 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_051009\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-GAC5, 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 in 2018. The combination of 

variable driving costs plus insurance 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 the independently derived Brookings Institution 

study. 

Emissions Analysis

The emissions analysis utilized the basic process suggested by the MOSERs 

methodology, as follows: 

Variables: EFA: Speed-based composite emission factor after 

implementation (NOx , VOC, or CO) grams/mile) 

EFB: Speed-based running composite emission factor before 

implementation (NOx , VOC, or CO) (grams/mile) 

NVA: Number of vehicles after implementation 

NVB: Number of vehicles before implementation 

TEFAUTO: Auto trip-end emission factor (NOx , VOC, or CO) 

(grams/trip) 

TLA: Average auto trip length after implementation (miles) 

TLB: Average auto trip length before implementation (miles) 

VMTA: Vehicle trips after implementation 

VMTB: 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 participating in a pay-as-youdrive program then 11,841,405 miles 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_051009\BControlMeasure58-PAYD-EM_051009.doc 

Equation: 

Daily Emission Reduction = 

C = VMTB * EFA = 

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 produce a net savings in money, meaning they 

are exceptionally cost effective. The Brookings study cited earlier estimates $50 to $60 

billion dollars per year in savings from less driving, fewer accidents, and lower costs. 

Therefore it is assumed that the net cost of this program would be negative. 

In summary it is expected that cost effectiveness 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 ozone plan after review of key assumptions, 

expected emission reductions and 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_051009\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 control measures such as Tier 2 tailpipe 

standards. Other measures are being evaluated for the H-GAC region, such as California 

LEV (low emission vehicles), cleaner fleets and wider application of the Inspection and 

Maintenance program. If these or other similar programs were implemented, the 

emission factors used to evaluate programs affecting the amount of travel (such as this 

one) would be smaller – each mile driven would 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. 

SUMMARY OF RESULTS: 

Expected 

Emission 

Measure Reduction 

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-Road 

Lightduty 

vehicles 

40.7 VOC 

30.3 NOx 

7 3.0 

2.2 

<$4,000 
G:\HGAC\Reports\Final_051009\Appdx H_051009\Control 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 inefficient operation that can produce unwanted air 

pollutants. Idling however also occurs during normal driving and other operations such 

as when the engine powers necessary accessories including for example man-lifts or 

concrete tumblers. Therefore it is not possible 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 often 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 policed to eliminate idling. 

PUBLIC ACCEPTANCE 

A voluntary program can achieve enthusiastic support because infrastructure to reduce 

fuel costs can be paid for from public funding. 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 alternative 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 duration 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 operations, it would be difficult to gauge how much 

that would be. For an extraordinary total, even if an astounding 10% of the HGB 

population of 5,628,101 idled 10 extra minutes in a single occupancy vehicle, the 
G:\HGAC\Reports\Final_051009\Appdx H_051009\Control 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 passenger 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 idling includes an upper end estimate 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 trucks (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 expanded to all heavy-duty vehicles, then 0.73 tpd 

could be reduced. The long duration idling 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 likely largest source of idling trucks, and so 

reducing idling in other areas would produce 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 season when ozone events would likely occur. 

SUMMARY OF RESULTS 
G:\HGAC\Reports\Final_051009\Appdx H_051009\Control Measure 126 Reduced Idling_051009.doc 

Expected 

Emission 

Measure Reduction 

ID Name Description 

Affected 

Sources 

Affected 

Emissions 

(tpd) % Tpd 

Est. Cost 

Effectiveness

($/ton)

126, 147, 

148 

Idle limits 

for 

heavyduty 

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 Using Long Duration Truck Idling Emission 

Reductions in State Implementation Plans and Transportation Conformity,” 

Office of Transportation and Air Quality,” EPA420-B-04-001, January 2004, pg. 

12 http://www.epa.gov/SmartwayLogistics/documents/420b04001.pdf. 
G:\HGAC\Reports\Final_051009\Appdx H_051009\BControlMeasure137LivableCenters-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 conserve resources by reinvesting in existing 

infrastructure and reclaiming historic buildings. By designing neighborhoods that have 

shops, offices, schools, churches, parks, and other amenities near homes, communities 

are giving their residents and visitors the option of walking, bicycling, taking public 

transportation, or driving as they go about their business. A range of different types of 

homes makes it possible for senior citizens to stay in their homes as they age, young 

people to afford their first home, and families 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 competitive, creates business opportunities, and 

improves the local tax base. 

EPA developed the Smart Growth Implementation 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 and create a high quality of life. In 

October 2008 the program selected three cities: receive Smart Growth Implementation 

Assistance from a team of private-sector experts: Capitol Region Council of 

Governments, Connecticut; Miami-Dade County, Florida; and New York City, New 

York. 

While Houston is not participating in the SGIA program at this time (they did receive an 

SGIA grant in 2006), the area has expressed interest in evaluating the potential effects of 

these measures on travel activity and emissions. The Community and Environmental 

Planning section of H-GAC developed a spreadsheet 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, walking distance to the center, the density of 

residents and employees, the number of residents who both work and live in the center, 

job density, number of dwelling units; the share of auto in all non-work trips for residents 
G:\HGAC\Reports\Final_051009\Appdx H_051009\BControlMeasure137LivableCenters-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/biking 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 carpool (for residents). Note that this 

description includes a representative list of examples in order to provide a flavor; a full 

description of inputs can be provided upon review of the spreadsheet which is available 

on request. Values used in the spreadsheet are derived from the 2006 American 

Community Survey for Harris County, the 2001 National Household Transportation 

Survey (http://nhts.ornl.gov/2001/pub/STT.pdf), and the 2000 census1, as well as from 

engineering judgement generally based on values 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 town, 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 centers based upon an evaluation of aerial 

photographs overlayed by grids performed 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 process suggested by the MOSERs methodology, as 

follows: 

EMISSIONS ANALYSIS

The emissions analysis utilized the basic process suggested by the MOSERs 

methodology, as follows: 

Variables: EFA: Speed-based composite emission factor after 

implementation (NOx , VOC, or CO) grams/mile) 

EFB: Speed-based running composite emission factor before 

implementation (NOx , 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\BControlMeasure137LivableCenters-EMUpdate_051009.doc 

NVA: Number of vehicles after implementation 

NVB: Number of vehicles before implementation 

TEFAUTO: Auto trip-end emission factor (NOx , VOC, or CO) 

(grams/trip) 

TLA: Average auto trip length after implementation (miles) 

TLB: Average auto trip length before implementation (miles) 

VMTA: Vehicle trips after implementation 

VMTB: 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 region in 2018. A 1 

percent reduction would be equivalent to a reduction of 1,600,190 miles per day. 

Equation: 

Daily Emission Reduction = 

C = VMTB * EFA = 

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\BControlMeasure137LivableCenters-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 assumptions 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-Road 

Lightduty 

vehicles 

40.7 VOC 

30.3 NOx 

1.0 0.41 

0.30 

Unknown 
G:\HGAC\Reports\Final_051009\Appdx H_051009\HGAC Measure139 Smoking vehicles_051009.doc 

Control Measure: #139, Enhanced enforcement 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 the emissions inspection status of smoking 

vehicles to be checked. Owners of smoking vehicles displaying a valid inspection sticker 

would be fined. Smoking vehicles not having 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 emitting vehicles with fictitious or counterfeit 

state inspection and/or registration stickers from the roadways and was not linked to 

reports of smoking vehicles. The pilot program attempted to establish the percentage of 

impounded vehicles that cannot be found in the vehicle registration or inspection and 

maintenance databases. 

For Measure 139 to be most effective, in addition to smoking vehicles, vehicles seen by 

law enforcement officers to have potentially fraudulent stickers should be pulled over. 

IMPLEMENTATION FEASIBILITY 

Texas Transportation Code (TTC) Section 547.605(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 fully dissipating. An offense 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 pull over a vehicle which is smoking, and under 

TTC Section 548.603, have the right to impound the vehicle if a stolen, fictitious or 

counterfeit state inspection sticker is displayed. 

For each county in which the program is implemented, 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 participating 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 vehicles 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 stolen, 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 being impounded,. However, later investigation 

discovered that of the 360 passing inspections, 172, or 47.8% appeared to have received 

an incorrect inspection consisting of clean scanning, clean piping, wrong test type being 

conducted, or inspectors not being truthful about insurance. Thus, the emissions benefit 

for the program was estimated for the 188 vehicles that were repaired and received a 

valid inspection. 

Based on an average obtained from a sample set 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 tons 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 implementation 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 difference between 3% waiver rate and 0% was 

modeled for Harris County only using the current inventory.

EMISSIONS BENEFIT 

Assuming there may be considerable overlap 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 county pilot program numbers the tons per day 

emissions reductions in the 8 precincts in Harris county provide at a minimum the 

following tons per day reductions from repairing 1504 vehicles in a 3 month period to be 

in compliance with the I/M test standards: 

 VOC Reduction = 0.031 tons per day, 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 emissions 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 reduction calculations do not account for 

the actions which would be taken from following up the 172 vehicles which were 

improperly emissions tested 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 Operations Coordinator, NCTCOG 

Dallas Emissions Enforcement Pilot Program (DEEP), Final Report, March 1, 2007, 

NCTCOG