Article View: ca.environment
Article #3391 Clean Air Plan
From: bm
Date: Fri, 10 Apr 1992 06:18
Date: Fri, 10 Apr 1992 06:18
3138 lines
143242 bytes
143242 bytes
The following is a copy of the State Air Resources
Board's review of the Bay Area Air Quality Management
District's "Clean Air Plan".
There will be a public hearing on the topic on April 30th. For those interested in attending the hearing,
contact bill michel for carpool info (bm@eng.sun.com).
Bill
State of California
AIR RESOURCES BOARD
PUBLIC MEETING TO CONSIDER THE APPROVAL OF
THE BAY AREA AIR QUALITY MANAGEMENT DISTRICT'S
1991 CLEAN AIR PLAN
Date of Release: March 30, 1992
To be Considered: April 30, 1992
Agenda Item No.: 92-5-1
This report presents the Air Resources Board (ARB or Board)
staff analysis of and recommendations on the Bay Area Air
Quality Management District's (AQMD or District) 1991 Clean Air
Plan (plan).
The plan was adopted by the District on October 30, 1991
and submitted to the Board for review on November 13,
1991. Under state law, ARB must determine the adequacy of each
plan within 12 months of receipt. Findings to be made by
the Board include: whether applicable control measures have
been incorporated, and whether expeditious progress will be made
toward attainment of the state standards.
The Bay Area AQMD is nonattainment for four of the state's
twelve ambient air quality standards: ozone (1-hour),
carbon monoxide (8-hour), and particulate matter (24-hour and
annual). The District also experiences visibility problems
but, like the rest of the state, is currently unclassified for
that standard.
Consistent with state law, the District's plan addresses
only ozone and carbon monoxide. Planning for
particulate matter and visibility reducing particles
has been deferred pending further direction from the State
Legislature. However, the strategies contained in the
plan are expected to reap benefits for all
nonattainment pollutants.
The plan predicts attainment of the state carbon
monoxide standard by approximately 1995. No forecast for
ozone attainment is provided due to data base and modeling
deficiencies. The plan does express the expectation that the
federal ozone standard will be attained by 1997, however.
The plan also indicates that population exposure to
unhealthful ozone levels will be halved by 1994.
The plan includes 50 proposed measures for stationary
and area sources. Of these, 21 are to be fully adopted
by the end of 1994. Initial action on six other multi-phase
measures will be accomplished during the same period.
The plan also contains 23 transportation control measures.
Each of these comprise several elements and will be
implemented in various stages, by various agencies,
throughout the decade. A key exception is the employer-based
trip reduction rule scheduled for District adoption in
1992.
The plan incorporates the Board's motor vehicle, fuels,
and consumer product regulations. Most of these are
reflected in the baseline emission inventory forecast;
future measures are discussed in the text of the plan. The
ARB measures, along with vehicle turnover, account for
approximately 75'Kl of the ozone precursor reductions claimed
in the 1987-1994 period. State measures account for almost
all of the carbon monoxide emission decreases in that
timeframe.
The plan satisfies most of the California Clean Air Act
requirements. The applicable control measures for serious
and severe nonattainment areas have been incorporated (the
self-assigned classifications for carbon monoxide and ozone,
respectively). Emission accounting and ranking of measures by
cost-effectiveness has been done. Transport mitigation
requirements set forth in ARB regulations are met.
The plan will not achieve five percent annual emission
reductions for either carbon monoxide, hydrocarbons, or
oxides of nitrogen. This is not a legal deficiency, however, if
the Board finds that the plan contains all feasible measures and
that the District is implementing those measures expeditiously.
In staff's view the plan generally meets these tests, with the
reservation noted below.
The transportation portion of the plan is a major step
forward, yet not as fully developed in some areas as state
law requires. Though all aspects of the Act have been
addressed, several individual measures lack essential details,
implementation milestones, or commitments from responsible
agencies. Therefore, the transportation strategies are only
partially approvable.
Staff is recommending that the Board approve all elements
of the plan found to conform with the California Clean Air
Act. This will enable work to proceed on completed elements.
Staff is recommending that the remaining portions of the plan be
conditionally approved, until such time as the needed changes
have been submitted. Schedules for completing plan
modifications will be proposed by staff at the public meeting,
after consultation with the District and other affected
agencies.
The primary issue surrounding the plan is whether it in
fact includes all feasible measures. As noted above, the
Bay Area must satisfy this test since its plan will not achieve
five percent annual emission reductions. "Feasible" is not
defined in the Act and must therefore be interpreted by the
Board. The interpretation recommended by staff is set forth in
the body of this report ("Evaluation of District Plan," Section
C.1). A contrary view, advanced by several environmental
groups, is set forth in the public comment section. The Board
will have to embrace one interpretation of feasibility in order
to make the statutorily required findings on this and other
district plans.
I. BACKGROUND
A. Development of the District Plan
The California Clean Air Act assigns lead responsibility
for plan preparation to each district. In the San
Francisco Bay Area, companion legislation directs the
Metropolitan Transportation Commission (MTC or Commission) to
prepare transportation control measures for inclusion in the
District's plan (AB 3791, Cortese; Chapter 1569, Statutes of
1988). The Commission provided those measures to the District
in December of 1990.
The Association of Bay Area Governments (ABAG) is not
legally obligated to participate under state law. However,
ABAG has extensive planning experience, was co-lead for federal
air quality planning between 1979 and 1987, and has signed a
memorandum of understanding with the District and MTC ensuring
continued coordination. ABAG's role in 1991 plan preparation
included development of population growth projections and
production of the draft plan.
A draft plan was released by the District in April 1991.
After a lengthy public comment period and multiple
@orkshops, the plan was substantially amended and re-issued. The
final plan was adopted by the District Board, unanimously, on
October 30, 1991.
B. Incorporation of State Measures
Although districts bear chief responsibility for writing
air quality plans, the contents reflect all actions being
taken to reduce air pollution. Efforts of other agencies,
changes in the marketplace, changes in societal behavior are
all accounted for -- to the extent that they affect emissions.
The Air Resources Board with its comprehensive motor
vehicle, fuels, mobile source, and consumer product
regulations is a major partner in every plan. The impact of
existing state regulations is represented in the baseline
emission inventory forecasts for each district. Recently
adopted and pending controls are assessed individually and may
be discussed in the text of district plans. Controls adopted
after District plan adoption but prior to ARB plan approval
will be identified in these staff reports and, where
appropriate, in the Board's final resolution.
In this instance, ARB regulations and the associated
turnover of the vehicle fleet account for most of the
claimed ozone precursor reductions before 1994 -- between
85-90%. By 1997, District measures will shift the balance to
60/40 for ozone precursors, with ARB providing the larger
share. By the year 2000, the balance will shift back to the
state, with ARB measures accounting for 73% of the total
decreases in ozone precursors.
State measures account for virtually all of the carbon
monoxide reductions between 1987 and 1995 (the projected
attainment year).
C. Mandates Governing Plan Review and Approval
The Board has primary responsibility under the Act for
overseeing the statewide planning effort. The ARB must
review and approve all attainment plans, ensure adequate
coordination and consistency between districts' control
strategies, monitor implementation, and generally track and
enforce compliance with the Act's provisions. The statutes
governing plan review contain both procedural and substantive
provisions. These are described, in turn, below. All legal
citations are for the California Health & Safety Code, unless
otherwise specified.
1. Procedural
District plans were to have been submitted to ARB for
review by July I of last year (40912). Whether on time or
delayed, the Board is given twelve months from receipt of each
plan to make its determinations (41503). In this case, a final
decision must be rendered by November 13, 1992.
All actions of the Board to approve or disapprove a
district's plan must be taken at a noticed public hearing
(41503.4), preceded by 45-day written notice (41502). The Board
must convene its hearing within the affected air basin, and must
conduct its review to include the plans of every district within
that basin (41503(b)).
If the Board deems any portion of the plan inadequate, it
must notify the district of those deficiencies in writing
(41503.2(a)). This action follows the public hearing, since the
Board must make those findings absent a delegation to ARB's
Executive Officer. The district is required to correct the plan
and submit the revision to ARB for approval.
The district may invoke a conflict resolution process if it
disagrees with ARB's findings of deficiency (41503.2(b)).
The Board is to invoke conflict resolution if the district's
plan revisions are still not adequate, in its judgment, to
remedy the identified deficiencies. A uniform conflict
resolution procedure was developed in May 1990 to guide this
process (see Appendix A).
Ultimately, ARB is required to amend deficient district
plans as it finds and determines necessary to comply with
the Act (41503.2(c)). Before taking this step, written 45-day
notice must be provided and a second hearing must be convened
within the affected air basin (ibid).
2. Substantive Requirements
The Board must ensure that district plans comply with the
Act and with any applicable provision of the Health &
Safety Code (41503.5). Most of the germane sections are in
Chapter 10 "District Plans to Attain State Ambient Air Quality
Standards," starting with section 40910. However, others are
scattered throughout the code (e.g., transportation, indirect
sources and area source control measures in sections 40716 and
40717), and some requirements are embedded in the plan review
procedures (41503-41503.5).
Some of the more important of the latter requirements are
these: the requirement that the combination of plans
within an air basin be adequate to attain state standards
throughout (41503(b)); the mandate to impose uniform controls
for the same emission sources within an air basin, unless the
district makes a particular demonstration (ibid); the link to
transport mitigation requirements established by the Board
(41503(b)); the requirement for all feasible controls where a
district is unable to project attainment or is unable to
achieve five percent annual emission reductions (41503(d) and
41503.1); and the mandates to attain state standards by the
earliest practicable date (41503(a)) and to adopt controls
expeditiously (41503.1).
II. EVALUATION OF THE PLAN
A. Technical Foundation and Analyses
1. Emission Inventory
The Act requires that district plans include consideration
of emission inventory characteristics, growth patterns
affecting emissions, and emission reductions occurring in, or
expected to occur in, the district (40913). ARB regulations
require that districts use a planning inventory provided by the
Board (Title 17, California Code of Regulations [CCR] Sections
70700- 70704) for the 1987 emissions baseline and future year
forecasts.
Staff believes that the Bay Area plan meets these
requirements. The plan describes the District's emission
inventory in detail and projects trends based on growth in
population, employment, industrial and commercial activity,
travel, and energy use. In addition, the ARB-provided emission
factors have been used for the 1987 baseline inventory and
future year forecasts.
RECOMMENDATION: Approve the emission inventory
elements of the Bay Area plan.
2. Air Duality Analysis
The Act requires districts to consider the present and
projected maximum pollutant concentrations, and the
distribution and frequency of state standard violations
(40913). These factors are discussed in the Bay Area plan.
The Act requires that district plans evidence attainment by
the earliest practicable date (40913, 41500(a), 41503(a)).
The.most common methods for making this demonstration are
photochemical modeling for ozone, and some sort of proportional
roll-back analysis for carbon monoxide. Both depend on
adequate data and confidence that the projections are
reliable.
The District's plan projects attainment of the state
carbon monoxide standard by approximately 1995. The main
factors leading to this result are the introduction of
wintertime oxygenated fuels and fleet turnover. Staff believes
that this assessment is accurate.
The Bay Area AQMD is unable to generate an attainment
demonstration for ozone at the present time. The District
undertook a considerable effort to apply the Urban Airshed
Model using extensive 1989 field studies. ARB staff and
computer resources were also dedicated to this effort.
Unfortunately, the data base and modeling results were not
adequate to support an attainment demonstration. The District is
therefore deferring the ozone analysis until more data can be
collected.
The law allows attainment demonstrations to be deferred,
provided that ARB concurs that projecting an attainment
date is impossible (41503(d)). When this occurs, the Board
must also determine whether the plan contains every feasible
control strategy or measure to ensure progress toward attainment
(ibid). The latter requirement is addressed in detail below.
Staff concurs that an attainment demonstration for ozone
cannot be provided at the current time. The modeling
difficulties experienced by the District were genuine,
unavoidable, and cannot be overcome prior to ARB action on the
plan. Staff is continuing to work with the District on modeling
improvements, to enable future compliance with the attainment
demonstration requirement.
RECOMMENDATION: Approve the carbon monoxide
attainment projection. Defer action on the ozone
attainment demonstration until sufficient data are
available to support a photochemical modeling
analysis.
3. Presumed Area Classification
The projected attainment dates for carbon monoxide and
ozone place the Bay Area AQMD in the serious and severe
categories, respectively. The plan presumes the more stringent
of the two categories and keys the control strategy accordingly.
While reporting both classifications would be more technically
correct, staff has no objection to this approach.
RECOMMENDATION: Approve the severe area
classification for the Bay Area District.
B. Proposed Control Measures
1. New Source Permitting
The Act requires that severe nonattainment areas adopt a
permitting program designed to achieve no net increase in
emissions. The program, embodied in a permit rule, applies to
all new or modified stationary sources (40920(a)(1)). ARB
transport mitigation regulations require the adoption and
implementation of a "no net increase" rule by July 1, 1991, in
identified upwind districts (see Other Mandated Elements
below). The Bay Area adopted amendments to its New Source
Review rule on July 17, 1991, to comply with these
requirements.
RECOMMENDATION: Find the District in compliance with
the 'no net increase' requirement for new and
modified permitted stationary sources.
2. Stationary Source Retrofit Measures
Severe nonattainment areas must consider the application of
best available retrofit control technology (BARCT) on all
existing sources in the district (40920(a)(1)). BARCT is defined
as "an emission limitation that is based on the maximum degree
of reduction achievable, taking into account environmental,
energy, and economic impacts by each class or category of
source" (40406). ARB's transport mitigation requirements have a
BARCT element as well (see Other Mandated Elements below).
The 1987 baseline emission inventory for the Bay Area AQMD
includes approximately 2,400 separate facilities, with a
total of 18,000 different emission sources (e.g., boilers,
combustion units, degreasing tanks, etc.). Retrofitting all of
them at once is clearly impossible, hence the District has
prioritized its efforts. Emphasis has been placed on emission
reduction potential, technological feasibility, and relative
cost-effectiveness, with the greatest weight falling on the
first factor. This is consistent with statutory direction that
priority be placed on expeditious progress towards healthful air
(40910).
The plan commits to retrofitting 17 source categories over
the next decade. In many cases, this involves revisions
to existing rules. In some cases, it involves more than one
revision. For example, the improved valve and flanges rule will
require leakless valves, improved inspection and maintenance,
and a more stringent definition of "leaks.' A total of 29
changes have been proposed for the 17 source categories.
Staff has reviewed the proposed control measures and has
found them to be generally acceptable.
The most serious concerns staff had after reviewing the
draft plan concerned the implementation schedules for
proposed rules. Staff was particularly concerned by the
schedules for NOx controls on stationary gas turbines and
electric power generating boilers. The District responded to
those concerns with an expedited schedule for NOx control in the
final plan.
RECOMMENDATION: Approve the BARCT proposals.
3. Area Source Controls
>> The Act requires that all nonattainment areas include
>> provisions to develop area source control programs (40918
>>et seq). 'Area source" is a catch-all category for numerous
>>small sources of pollution; for example, residential water
heaters or cans of spray paint. It also includes stationary
sources that are too small to be identified individually, and
large diffuse sources (like the application of pesticides or
cattle feed lots) that have no single emission point.
responsibility is not exclusive but tends to work out that
way, due to the federal waiver provisions and the
desirability of statewide uniformity. Statewide mobile source
controls are seen as more effective and more efficient in many
cases.
Districts and associated agencies generally focus on the
use of motor vehicles. In other words, these agencies
are striving to reduce the number of trips taken and/or the
number of miles driven through the application of
transportation control measures (TCMs). The Bay Area's
proposed TCMs are discussed in the next section.
Some districts are pursuing local mobile source controls
in addition to TCMs. These mobile source controls are
intended to complement and enhance the state's programs.
>> The Bay Area plan contains two such mobile source
>> measures: a citizen complaint program for smoking
>>vehicles; and a fleet rule which would require the use of
>>clean fuel vehicles. The former, scheduled for adoption
this year, is patterned after portions of the South Coast's
"Cut Smog" program. The fleet rule is proposed for adoption
during the next planning cycle (1995-1997).
>> Staff believes that both measures have merit. However,
>> care needs to be taken with local fleet rules so that
>>double-counting of emission reductions, conflicts with the
>>state's program, and other unintended adverse effects are
>>avoided. Staff is currently working with an ad hoc
>>committee of interested district representatives to fashion
>>a workable approach. The product of this effort should be
>>available in time to meet the Bay Area's proposed
>>schedule.
>> RECOMMENDATION: Approve the smoking vehicle
>> complaint program. Direct ARB staff to continue
>> working with districts on fleet rules, with the
>> objective of resolving implementation issues prior to
>> the next planning cycle.
6. Transportation Control Measures/System
Management
Perhaps the most challenging provisions of the
California Clean Air Act are those related to
transportation. The Act provides districts with much
greater authority and responsibility to mitigate the impact
of vehicular source emissions through the use of
transportation control measures (TCMs). To meet this charge,
districts have had to expand their expertise, break new
t6chnical ground, and obtain an unprecedented level of
cooperation from the many local, regional and state agencies
that are directly responsible for transportation, including
city and county governments.
>> The staff believes that the Bay Area agencies have
>> performed well in this area. The plan represents
>>significant progress in addressing the Act's transportation
>>requirements. However, further improvements in several
>>individual measures are needed before staff can reconrnend
>>that the Board
find the plan meets all the requirements of the Act. The
staff's analysis and recommendations are presented below.
The nature of TCMs is constantly evolving and the mix of
implementation responsibilities in the Bay Area, like other
urban areas, is incredibly complex. Given this, staff
encountered many circumstances during plan review where issues
had to be addressed for the first time. Staff recommendations
were reached only after extensive thought, dialogue, and
analysis. Through these recorrfnendations a number of policy
precedents are being proposed for the Board's consideration.
Among them are the criteria used to gauge TCM approvability.
>> Legal Requirements. The Act requires long term
>> nonattainment areas to meet three transportation
>>performance standards. As part of the strategy to reduce
>>pollution from motor vehicles, the plan must indicate how the
>>area will: 1) substantially reduce the rate of increase in
>>passenger vehicle trips and vehicle miles traveled; 2) attain
>>1.5 passenger vehicle occupancy during weekday commute hours by
>>1999; and 3) achieve no net increase in vehicle emissions after
>>1997. All nonattainment areas are required to include
>>reasonably available TCMs in their plans, and those unable to
>>achieve 5% annual emission reductions must include all feasible
>>TCMs (40918 et seq).
Criteria for Approval. Staff defined general criteria for
the overall transportation plan and more specific criteria
for the proposed measures. For the latter, staff assessed the
degree to which the TCMs satisfied both the explicit and
implicit requirements of the Act. Stated in the form of
questions, the criteria are:
0 Reasonably available TCMs -- has each one of the
general control
strategies deemed to be reasonably available for
transportation sources been addressed in some way?
(See below for definition of "reasonably available
TCMs.")
0 Reduced rate of growth in trips and trip length --
does the plan
contain sufficient TCMs to satisfy this requirement?
0 1.5 Average Vehicle Occupancy -- does the plan contain
sufficient
TCMs to achieve an average vehicle occupancy of 1.5
during peak periods by the year 2000?
0 Technical basis for each measure -- will it actually
reduce
emissions (or slow emission increases) if
implemented?
0 Extent of each measure -- is it substantive enough and
broad
enough to support the finding that reasonably
available TCMs have been included in the plan?
0 Definition of each measure -- is it well enough
defined so that
its implementation can be tracked in the annual
progress reports required by the Act?
0 Degree of comitment to each measure -- has the
implementing
agency accepted responsibility for implementing the
measure, and does that agency -have adequate legal
authority and resources to carry it out?
Staff's assessment of the Bay Area's compliance with
transportation performance performance standards is
summarized below. The evaluation of individual TCMs is
suffrnarized in Table 1 and presented in more detail in
Appendix B.
Reasonably Available TCMS. In previous guidance approved
by the Board, staff recommended that "reasonably available
TCMS" be interpreted to include six general strategies: 1) an
employer-based trip reduction rule; 2) trip reduction rules for
other sources (such as universities or entertainment venues); 3)
management of parking supply and parking prices; 4) a High
Occupancy Vehicle or HOV system plan; 5) a comprehensive transit
plan, which also addresses access; and 6) land use strategies to
minimize vehicle trips.
Staff believe that these general strategies comprise the
universe of "reasonably available" TCMS. They are the most
effective TCMs available today and it will take the better part
of this decade to design and implement them.
Staff finds that the Bay Area plan addresses all of the TCM
categories identified as reasonably available. Trip
reduction rules are addressed in TCMs #1, #2 and #16; parking
management is addressed in #22; the HOV system is addressed in
TCM #8; transit is addressed in TCMs #3-7; and, finally,
land-use is addressed in TCMs #18 and #19.
Staff has significant reservations about the specificity of
several measures. Thus, while the scope of the TCMs is
adequate to satisfy the "all reasonable TCMS" test, more depth
is required to find the TCMs fully approvable under the Act (see
Table 1 and Appendix B).
Reduced Rate of Growth in Trips and Trip Length. The
Metropolitan Transportation CorrFnission (MTC) is
predicting a significant decline in the regional growth of
vehicle miles traveled (VMT). This is a baseline projection,
which is expected to occur even if no additional measures are
implemented. Annual VMT growth in the 1990's is forecast at 1.4
percent for each 1 percent growth in population. This compares
to an annual VMT growth rate of 2.4 percent in the 1980's. MTC
estimates that full implementation of the plan will reduce the
VMT growth rate to 1.1 percent. Most of this impact would stem
from the proposed pricing measures.
Previous ARB guidance suggested that holding VMT growth
rate to the rate of population growth was an appropriate
goal and could constitute "a substantial reduction" as required
by the Act. In the Bay Area's case, both 1.4 and 1.1 percent
growth in VMT represent a substantial reduction over the current
growth rate. Staff believes that full implementation of
reasonably available TCMs and the downward trend in the VMT
growth rate is adequate to
meet this requirement of the Act. During its review of the
draft plan, staff suggested that MTC and the District develop a
monitoring plan to track the actual growth rate in VMT. That
plan has been submitted and is now under review by ARB staff.
1.5 Average Vehicle Occupancy (AVO). As noted above,
the Act requires the Bay Area to achieve an AVO of 1.5
during weekday commute hours by 1999. MTC estimates that the
plan will increase a.m. peak occupancy from a projected baseline
level of 1.43 in 2000 to an average of 1.54 by the same date.
Most of this impact is from pricing measures. Without such
measures, the Bay Area cannot demonstrate compliance with the
1.5 AVO requirement.
>> Staff concurs with MTC's assessment that the 1.5 AVO
>> requirement is very difficult to meet and that pricing
>>measures will probably be needed to achieve that ridership level
>>in the Bay Area. However, since neither the District nor MTC
>>possesses adequate legal authority to institute pricing
>>strategies, the AVO demonstration in the plan is theoretical.
>>Staff recommends that the Board withhold full approval of the
>>AVO demonstration until the means of implementation have been
>>identified and stronger commitments to the necessary measures
>>and actions have been made.
No Net Increase in Vehicle Emissions. The baseline
emission projections for the Bay Area AQMD indicate a
steady decline in motor vehicle emissions through the year
2000. This is in large part due to the combination of ARB
vehicle and fuel controls reflected in the plan. Staff believes
that this projection, plus the full implementation of
reasonably available TCMS, is more than adequate to comply with
this requirement.
RECOMMENDATIONS: Find that the plan addresses all
reasonably available TCMS, but that further definition
is needed for some measures. Approve those TCMs
identified in Table 1 that fully comply with the
Act's requirements. Conditionally approve those TCMs
where further actions are needed to comply with the
Act, upon receipt of a coninitment from the
responsible agency (primarily the District or MTC) to
adequately define the measures on an expeditious
schedule. It is envisioned that most of these
improvements will be commitments to near term actions
(in the next 6-12 months). However, a few may
require longer timelines.
Note: At the time this staff report was released, staff was
meeting with District and MTC representatives to determine if
an acceptable schedule to upgrade the incomplete TCMs could be
devised by the hearing date. If agreement is reached, the staff
will recommend the consensus schedule to the Board as part of
its action on the Bay Area plan.
Find that the plan satisfies the requirement for a
substantial reduction in the growth rate for trips and
trip length. Also find that the plan satisfies the
requirement for no net vehicle emission increases
after 1997.
Find that the plan does not currently satisfy the 1.5
AVO requirement, and recognize that a significant
amount of time will be needed to either develop
additional TCMs or to obtain the needed authority and
comitments for pricing measures that are essential
to achieving a 1.5 AVO by the year 2000.
7. Miscellaneous Control Measures
The Bay Area plan contains two unique "intermittent control
measures." The first of these would encourage citizens to
postpone discretionary activities, such as unnecessary trips and
noncritical maintenance (mowing or painting) during forecasted
ozone episodes. The second measure, aimed at industrial
sources, would require curtailment of non-production emission
generating work during episode conditions. Examples of such
activities include: maintenance coating, repairs of external
floating roof seals, uncontrolled soil aeration, and check out
of stand-by engines. Industry would also be asked to
voluntarily limit all other activity--including production--to
the extent they can during ozone episodes.
The voluntary citizens action program was endorsed by the
District Board and initiated last year. The voluntary
portion of the industrial curtailment program is scheduled for
District consideration this year, with the mandatory element
following in 1994.
Staff cannot confirm the emission reduction estimates for
these measures until some actual experience with the
programs is gained. (Note: the District agrees that the
effectiveness of these measures is difficult to verify and did
not include them in its calculation of average annual emissions
reductions.)
Staff believes the intermittent control concept is worthy
of investigation and is monitoring the Bay Area's efforts
with interest.
RECOMMENDATION: Endorse the investigation of
intermittent control strategies in the Bay Area plan.
Withhold approval of specific emission reduction
claims pending receipt of an acceptable demonstration
of their effectiveness.
C. Other Mandated Elements
1. Annual Emission Reductions
The Act states that each plan shall be designed to reduce
district-wide emissions by five percent (5%) per year,
unless an alternative measure of progress is employed (40914).
The District is not proposing an alternative method in the 1991
plan.
The 5% requirement applies to each nonattainment pollutant
and to each pollutant precursor covered by the plan. For
the Bay Area this includes reactive hydrocarbons, oxides of
nitrogen, and carbon monoxide.
A district plan may show a lesser rate of reduction if the
district is unable to reduce emissions by 5% per year.
However, three conditions must be satisfied before ARB can
approve a reduced rate: the Board must concur that the 5% rate
is unachievable; the plan must contain all feasible measures;
and the District must be pursuing an expeditious adoption
schedule (40914(b), 41503.1). The following sections provide a
lengthy discussion of these conditions.
ARB regulations require each district to display its
emission accounting in a clear and straightforward manner
(17 CCR, Sections 70700- 70704). The regulations also define
the time periods for emission averaging as: 1987-1994,
1995-1997, and 1998-2000. As discussed above, the regulations
further require that the state issued inventory be used in
district plans.
>> The combination of state and local measures in the Bay Area
>> plan falls short of mandated emission reductions. Instead,
>>the plan indicates cumulative hydrocarbon reductions of 4%
>>annually through 1994, declining to 3.8% per year in the next
>>reporting period, then dropping to 3.1% between 1998 and 2000.
>>[Note: staff expects all district plans to show a downward trend
>>in annual emission reductions through 2000, as opportunities for
>>large reductions are exhausted and growth pressures outpace
>>vehicle turnover.] For NOx, the District is forecasting 2.6%
>>average annual reductions through 1994, 3.4% per year reductions
>>after 1995, dropping back to 2.8% annual decreases after 1997.
>>For carbon monoxide, the plan shows 4% annual decreases through
>>1994, 4.5% average annual reductions after 1995, then 3.7%
>>annually after 1997. Forecasts beyond 2000 are not included in
>>the plan.
Staff believes the forecasted emission reductions represent
the maximum achievable rate of progress in the Bay Area,
given the specific facts and circumstances facing the District.
These are described in further detail in the following
sections.
RECOMMENDATIONS: Approve the District's emission
accounting as consistent with state regulations.
Approve the lesser rates of annual emission reductions
portrayed in the District's plan as the maximum
reductions possible and, as discussed in the next two
sections, as reflecting the expeditious adoption of
all feasible measures for the Bay Area.
2. All Feasible Measurer
As a district unable to achieve 5% annual emission
reductions, the Bay Area AQMD must demonstrate to ARB's
satisfaction that it has included every feasible measure in its
1991 air quality plan (40914(b)(2) and 41503.1). The District
asserts that it has.
The term "feasible" is not defined in the California Clean
Air Act. However, related environmental statutes offer
useful definitions and substantial precedent. The most relevant
of these are the Guidelines issued
to implement the California Environmental Quality Act (CEQA),
which define "feasible" as incapable of being accomplished in a
successful manner within a reasonable period of time, taking
into account economic, environmental, legal, social, and
technological factors" (14 CCR, Section 15364). Three aspects
of this definition bear emphasis: the results orientation,
the time parameter, and the consideration of social factors
(among several others).
Staff have encouraged all districts to give close
consideration to demonstrably achievable measures: the
bread and butter regulations that have been successfully adopted
and implemented in California. Last March, staff provided a
list of stationary and area emission source categories for
which regulations were clearly available and effective. The
staff list of feasible controls is by no means absolute.
Rather, it represents a starting point for each district's
analysis. Other measures may exist today which are also
feasible. New measures will undoubtedly be added over time as
districts' regulatory programs move forward.
The District's plan covers all the listed stationary and
area source categories which exist in the San Francisco
Bay Area. Current District regulations, plus the proposed
measures in the plan, ensure that all of the identified
categories will be controlled. The District has 15 additional
measures for stationary and area sources in its plan, which it
considers to be feasible and necessary for the Bay Area.
Staff's guidance to districts on transportation
strategie5.was to focus on reasonably available TCMS. As
discussed above, these are the most effective measures currently
available and will take a number of years to successfully
implement. Six broad control categories were identified.
Three of these were regulatory in nature: employer-based trip
reduction rules; management of parking supply and prices; and
>>trip reduction rules for other sources. The other three
>>measures affect the overall transportation system: plans for
>>high occupancy vehicle lanes; comprehensive transit plans;
>>and land use policies.
The Bay Area plan addresses all of the identified
transportation control categories. Though staff have
concerns with a number of the TCMs (as detailed above and in
Appendix B), staff believe the scope of the plan is sufficient
to satisfy the Act's feasibility requirements. Where TCMs are
deficient, it is for lack of specificity or
enforceability--not scope.
The time horizon for gauging feasibility is a decisive
factor. Since the Act calls for plan revisions every third
year after approval (40925), staff believes the most
appropriate horizon is the current planning cycle. Thus, what
has and can be accomplished between 1987 and 1994 is the
operative question. The District's intentions for future
planning cycles are instructive and revealing, but should not
form the basis for an "all feasible measures" determination
since the plan will inevitably be revised.
Staff interprets "accomplish" to mean adopt or otherwise
initiate emission controls. This is because the full
effectiveness of many measures will not be realized
immediately. For example: industrial source retrofits
take between two and five years, on average, to fully
implement; new car standards require a turn-over in the
vehicle fleet to achieve maximum reductions.
The Bay Area AQMD is proposing to adopt 26 stationary
and area source measures, one mobile source measure, and
4 transportation control measures by the end of 1994. Initial
and/or supporting action on 23 other multi-part measures
will be undertaken in the same period (funding and legislative
authority permitting, for some of the latter).
As mentioned previously, districts unable to achieve 5%
annual emission reductions must satisfy two tests: all
feasible measures and expeditious adoption. If the current
planning cycle is viewed as controlling, the question becomes:
'what pace of rulemaking activity is "expeditious" in this
timeframe?" Staff believes the determination of expeditious
progress is fact-driven and district-specific. Staff further
believes that the Bay Area plan satisfies the expeditious
adoption test. The rationale for this viewpoint is
described below.
The need to consider social factors adds weight to
local circumstances. Communities differ and may respond
differently to proposed measures. The composition of a
particular industry's workforce can produce special issues,
as the impacts of proposed controls are being considered.
Being different is not automatic grounds for rejecting measures
which are commonly, and successfully, applied elsewhere. It is
a legitimate factor to consider, however, in the context of
what is feasible and how quickly it can be achieved.
Staff believes the District plan sets forth an honest
appraisal of what can be accomplished in the near term
given the particular setting, history, infrastructure,
constituency groups, and popular concerns in the San Francisco
Bay Area.
RECOMMENDATION: Find that the District plan includes
'all feasible control measures' within the meaning of
the Act, and in consideration of the factors
affecting the selection of control measures within
the Bay Area.
3. Expeditious Progress/Expeditious Adoption
The Act generally requires expeditious progress toward
attainment (40910). Where districts are unable to achieve
5% annual emission reductions, the Act also requires
"expeditious adoption" of all feasible measures (40914(b)
>>and 41503.1). Staff has construed this to mean a steady pace of
>>rulemaking taking into consideration the difficulty, novelty,
>>and controversy associated with each regulation; procedural
>>requirements imposed by statute for the adoption of
regulations (including due process and review of
environmental and socioeconomic impacts); competing mandates
(e.g., toxic air contaminant controls which must be locally
adopted within 6 months of ARB approval); and district
resources.
What is expeditious varies by district, based on its
particular circumstances. The Bay Area AQMD is proposing to
adopt 36 stationary and area source measures between 1991 and
the end of 1994, about nine per year. This represents a
doubling of regulatory activity over the last four years, when
four to five measures per year was standard. Twelve of these
measures are brand new rules, which typically involve more work
than revisions to existing rules. Two measures involve the
reduction or elimination of exemptions, which tends to fall
hardest on small businesses and provoke significant
controversy.
In the same timeframe, the District is proposing to act as
lead on four transportation strategies, to assume a primary
role for three additional TCM's, and to offer support for six
of the remaining measures. All of the former represent
'cutting edge" work. Few models are available to emulate, and
those that are available are going through shake-down processes
of their own.
>> Many of the individual measures in the District's 1991 plan
>> will require considerable resources to develop.
>>Transportation strategies, inclusive of indirect source review
>>and employer-based trip reduction, are extremely controversial
>>in the Bay Area. Creating a program that is both effective and
>>minimally acceptable to the agencies, businesses and individuals
>>that must carry it out is a great challenge. The market-based
>>strategies require new statutory authority which will take
>>extensive lobbying, negotiations, and coordination to secure.
>>The proposed NOx controls for utility boilers present different
>>difficulties owing to the complexity of powerplants, the need
>>to coordinate equipment replacement with Monterey Bay Unified
>>and San Luis Obispo County (who are also proposing to regulate
>>PG&E), and the high cost of the retrofit technologies.
>>
Though not unique to the Bay Area, procedural requirements
are a critical part of the expeditious calculation. In
addition to due process requirements (40725-40728), new
legislation has imposed further time- consuming procedural
steps. Beginning this year, districts with a population of
500,000 or more are required to perform a socioeconomic analysis
on each regulation prior to adoption (AB 2061, Polanco; Chapter
794, Statutes of 1991). This clearly applies to the Bay Area.
Districts' responsibilities for environmental review has
gradually expanded over the past ten years, as air quality
regulations have raised energy, water, hazardous waste disposal,
hazardous material transport, and land-use concerns. It is no
longer uncommon to see a full environmental impact report on an
individual rule. Staff expects the trend toward broader, more
time consuming review to continue.
>> A significant political and practical issue facing all
>> districts this year is the depth and persistence of
>>California's economic downturn. Though signs of recovery are
>>beginning to emerge, the worst effects are still with us and
>>many expect the pace of recovery to be slow. Districts have to
>>be unusually sensitive during this period, and to consider
>>special compliance schedules or other options to mitigate
>>economic impacts. Costs that were absorbable in the past
>>decade may be temporarily less so, in certain
industries or by certain firms. Responding to these issues
as they arise will take additional time and creativity.
RECOMENDATION: Approve the Bay Area's proposed
schedule for rulemaking and related activities as
oexpeditiouso within the meaning of the California
Clean Air Act and given the particular circumstances
facing the Bay Area District.
4. Cost-Effectiveness Ranking and Determination
The California Clean Air Act requires districts to
assess the cost- effectiveness of proposed control
measures. Each plan must include a list that ranks
measures from the least to the most cost-effective
(40922). In addition, each district board must certify that its
plan is a cost-effective strategy for attaining state air
quality standards, prior to adoption (40913(b)).
The Bay Area AQMD has complied with the
cost-effectiveness ranking mandate to the extent possible.
Sixty-seven of the plan's 90 proposed controls are ranked
in Volume 1 (tables 7a and 7b, page 26). For the remaining 23
measures, there is insufficient information to complete a cost-
effectiveness assessment. -
>> Staff believes this partial ranking is adequate to
>> satisfy state law. Cost estimates at the planning stage
>>are often preliminary and incomplete. Unless another
>>district has adopted an identical rule, plan preparers must
>>rely on their experience with comparable rules, vendor
>>literature, and various studies. In some cases, cost data
>>simply does not exist. In others, no method has been developed
>>for quantifying emission impacts.
It is important to emphasize this is merely the first
step. As individual rules are taken up for development,
detailed data are gathered and more specific
cost-effectiveness analyses are performed. This ensures a
continuing emphasis on regulatory efficiency, as intended by the
Act.
The Bay Area has also made the required cost-effectiveness
determination. On October 30, 1991, the District Board
certified that the plan is a cost-effective strategy for
attaining state standards by the earliest practicable date
in Resolution 2050.
RECOMMENDATION: Find the District plan in
compliance with the cost-effectiveness
requirements.
5. ixansport Mitigation
The Act requires district plans to include any
transport mitigation requirements established by the Board
(40912). In December 1989, ARB identified the Bay Area AQMD as
the source of transport into Monterey Bay Unified air
district, the San Joaquin Valley, and the Broader Sacramento
Area. In August 1990, the Board adopted mitigation regulations
which require certain permitting and retrofit actions (17
CCR, Section 70600).
Specifically, the District was required to adopt and
implement a no net increase permitting rule by July 1,
1991. In addition, the District must adopt rules representing
BARCT for stationary sources that comprise 75% of the 1987
inventories for hydrocarbons and NOx. The BARCT requirement
must be met by January 1, 1994.
The plan demonstrates compliance with both requirements.
As noted above, a no net increase permitting rule was
adopted and implemented on July 17, 1991. For BARCT, the
District may be halfway there already. Over the past several
years, Bay Area regulations have been focused on stationary
sources of hydrocarbons. Consequently, the District believes
that most of its existing hydrocarbon rules represent BARCT.
Sources covered by these rules represent 85 percent of the
stationary source inventory. The District intends to revisit
these rules prior to 1994 to ensure that they do in fact achieve
the degree of control that currently represents BARCT.
For NOx emissions, the District has proposed new retrofit
control measures to meet BARCT requirements. These rules
will cover such sources as reciprocating engines, stationary
gas turbines, electric power generating boilers, large
boilers, steam generators, process heaters, and residential
water heaters. These and other sources amount to 83 percent
of the 1987 point source inventory. Therefore, adoption of the
new NOx control measures will comply with the transport
mitigation regulation provided the District adopts the level of
control representing BARCT at the time of rulemaking, which it
has committed to do.
RECOMMENDATION: Find the District in compliance with
the transport mitigation requirements.
6. Population Exposure
Long term nonattainment areas for ozone must address
population exposure in their plans. Specifically, each
severe area must include sufficient measures to reduce overall
population exposure 25%, 40% and 50% by 1994, 1997 and 2000,
respectively (40920(a)(4)). The baseline for this analysis is
the average level of exposure experienced between 1986-1988.
The District performed a preliminary modeling study to
assess the change in exposure over time. Using a
combination of conservative and simplifying assumptions, Bay
Area concluded that the plan would satisfy or exceed the Act's
requirements. The predicted exposure reduction for 1994
ranged from 49-81%, and ranged from 64-94% for the 1997
milestone date.
ARB staff believes that the method used by the District
to estimate population exposure is acceptable. Staff is
also confident that the analysis is qualitatively correct.
However, the underlying photochemical model is not as
reliable as it needs to be to draw firm, numerical conclusions.
Substituting actual data for some of the assumptions in the
analysis would also be highly desirable.
The District is working diligently to improve modeling
performance prior to the next plan revision. The District
has also committed to revisiting its population exposure
analysis, and intends to incorporate daytime population
patterns, more modeling results and more refined indoor/outdoor
exposure patterns at that time.
RECOMMENDATION: Approve the population exposure
analysis as the best information currently available.
Recommend that the District revisit this analysis in
the next update to the plan.
7. Intrabasin Uniformity
The Act requires that control measures for the same
emission sources be uniform throughout the affected air
basin to the maximum extent feasible (41503(b)). In the case
of the Bay Area AQMD, district boundaries are coterminous with
the entire air basin. Hence, uniformity is generally not a
problem for stationary and area source control measures.
The uniformity requirement may provoke issues when the
District delegates responsibility for TCM implementation to
local agencies. As this is done, the District may need to take
steps to ensure that local agencies are implementing the
measures consistently.
The District proposes to create model ordinances for the
proposed employer-based trip reduction and indirect source
review measures. As currently conceived, delegees will need to
meet certain standards of performance but will have discretion
in selecting the compliance method. Staff believes this
approach is consistent with the Act's uniformity requirement.
RECOMMENDATION: Find the plan in conformance with
the uniformity requirement. Direct the District to
monitor the effectiveness of delegated measures in
achieving a uniform degree of emissions control.
8. Public Education
The Act requires that all district plans include provisions
for public education programs to promote actions which
reduce emissions from transportation and area sources (40918).
As noted above, the Bay Area has a unique citizen advisory
program designed to curb discretionary, air polluting activities
during smog episodes. Its inauguration in 1991 drew substantial
press coverage and a discernible, positive response from local
residents.
The Bay Area also has a public relations campaign to teach
people about single occupancy vehicles' impacts, and to
direct them towards transportation alternatives. The campaign
was started last year; the District is currently seeking funds
to continue it on a long term basis.
RECOMMENDATION: Find that the District plan includes
provisions for public education.
9. Contingency Measures
The Act requires that contingency measures be included in
each district's plan (40915). These are to be implemented
upon a finding, by the ARB, that the district is failing to
achieve interim goals or to maintain adequate progress toward
attainment (41503.3).
As noted above, the Bay Area AQMD is proposing to adopt
all feasible measures on an expeditious schedule.
Contingency measures are very difficult to define in this
context since additional measures are, by definition, infeasible
during the current planning cycle.
In lieu of a list of contingency measures, the District is
proposing a contingency procedure. To wit: when a plan
measure cannot be adopted or implemented (for whatever
reason), the District will do everything possible to accelerate
the adoption and implementation of subsequent rules. The annual
progress reports will detail all efforts made in this regard.
Staff believes a procedural approach is appropriate for
districts facing the all feasible measures/expeditious
adoption test. However, the generality of the District's
proposal leaves much to be desired. At a minimum, an early
warning system should be in place so the Bay ' Area will have a
genuine opportunity to accelerate the adoption of other
(measures.
The District has also corrrnitted to an ongoing
re-prioritization process. Should measures not in the plan
be identified as feasible, capable of achieving significant
reductions, and more cost-effective than measures already in the
plan, they will be added to the District's annual rulemaking
calendar with a priority that reflects their superiority (or
inferiority) to measures awaiting adoption.
Staff strongly supports the ongoing assessment of
priorities and the addition of new, feasible measures to
district plans. The Board may wish to caution the Bay Area,
though, that revised schedules which delay or suspend existing
commitments need to be handled as plan revisions and submitted
to ARB for approval.
RECOMMENDATION: Conceptually approve the procedural
approach to contingency measures in the Bay Area
plan; seek further detail as to how it will be
effectively implemented. Clarify the conditions under
which plan revisions are necessary.
10. Environmental Review
The California Environmental Quality Act (CEQA) requires
that each project be assessed for potential significant
effects on the environment. This mandate applies to air
quality plans. The Bay Area AQMD, like several
other urban districts, opted to prepare a full environmental
impact report (EIR) on its 1991 plan. (Some districts,
particularly rural districts with straightforward and limited
control plans, elected to issue negative declarations or
mitigated negative declarations, instead.) The final EIR was
certified by the District Board on October 30, 1991. Further
environmental documentation will be prepared during the adoption
process for individual rules and regulations, as necessary.
RECOMMENDATION: Find that the District has met its
obligations under CEQA.
III. ENVIRONMENTAL IMPACTS
The ARB's role in evaluating the environmental impact
of air quality
plans is limited. Under CEQA, districts act as the lead
agencies for preparation of environmental documents. The ARB is
thus a responsible agency, and, in that capacity, reviews the
environmental documents prepared by the districts and makes
appropriate findings as required by the Public Resources Code
sections 21081 and 21081.6, where applicable.
Staff have reviewed the EIR for the Bay Area 1991 Clean Air
Plan and find that it accurately describes the potential
environmental impacts of the plan. Staff concurs with the
District's findings.
IV. PUBLIC COMMENTS
A. Directed to the District
>> Public participation in District plan development,
>> refinement and adoption was extensive. Last Spring, the
>>District held eight public workshops which were attended by
>>approximately 300 persons. A total of 53 people testified at
>>the first hearing on the draft plan in July 1991. Prior to
>>final adoption, the District received and responded to 224
>>comment letters.
At the final hearing on the plan, testimony was presented
by 54 speakers. The overwhelming majority of commentators
expressed support, though often wanting parts of the plan
strengthened. Several speakers also expressed the hope that
>>there would be flexibility in how measures were implemented.
>>
>> Many witnesses expressed concern about TCMS. Caltrans
>> objected to highways being deemed an indirect source,
>>indicating that current air quality assessment procedures make
>>this redundant. The Building Industry Association argued that
>>residential projects should not be considered an indirect
>>source, either, since they respond to growth pressures rather
>>than create them. The Bay Area Industrial Park Association
>>requested that indirect source measures be withdrawn from
>>consideration entirely.
Several employers and employer groups were concerned about
TCM 2, the employer-based trip reduction control measure.
The National Association of
Industrial Office Parks sought an exemption for office
complexes. Other representatives wanted maximum employer
flexibility (e.g., the Business Air Quality Policy
Committee).
>> Considerable support was expressed for market-based control
>> measures by both environmental and business
>>organizations. However, the organization 'People of Color for
>>the Environment" urged that the plan be rejected because
>>the pricing measures were financially regressive, and
>>because the impact of other measures on minorities and
>>low-income groups had not been sufficiently analyzed.
>>
>> The second major area of concern was whether the plan
>> satisfies the Act's performance standards. The Sierra
>>Club Legal Defense Fund urged rejection on the basis that
>>all feasible measures were not included. The American Lung
>>Association urged the Bay Area board to include additional
>>strategies in order to achieve the five percent annual emissions
>>reduction target.
B. Directed to the Air Resources Board
>> Prior to release of this report, staff received oral
>> and written comments from several environmental groups
>>including: the Coalition for Clean Air, Natural Resources
>>Defense Council, Citizens for a Better Environment (CBE), and
>>the Sierra Club's Legal Defense Fund and San Francisco Bay
>>Chapter.
>>
>> These groups are uniformly concerned with the quality
>> of TCMs in district plans, particularly those of the Bay
>>Area and South Coast AQMDS. Noting that the motor vehicle
>>inventory is substantially underestimated, these groups argue
>>that transportation measures should receive the greatest
>>attention and priority. These groups find many of the proposed
>>TCMs to be overly general and potentially unenforceable, and
>>believe this is grounds for finding district plans deficient
>>under the "all feasible measures" test of the Act.
>>
>> The interpretation of feasibility advanced by these
>> groups is an objective standard, applicable to all
>>districts in all circumstances. They would start from a
>>larger list, incorporating any air quality measure
>>proposed, adopted or implemented by anyone, anywhere in the
>>world. All such measures would be presumptively feasible, and
>>districts would bear a heavy burden of proof for excluding them
>>from their plans. As stated in the preceding chapter,
>>staff's list of feasible measures is both preliminary and
>>open-ended so more controls can, and inevitably will, be
>>added over time. There is a fundamental difference between a
>>universal presumption and a case-specific determination,
>>however. Staff recommends that the Board endorse the
>>latter.
These groups' interpretation of feasibility is not bound
to the time horizon of the current planning cycle.
These groups appreciate that not every measure can be
adopted before 1994 (though they have a different opinion
about where the dividing line is). However, they see value
in
placing longer term measures in the plan--i.e., ntier 2" and
'tier 3"--so that districts are thinking ahead, and so that
debate over the next plan revision is appropriately shaped.
Staff's position is not directly in conflict with this goal. It
is not necessary to fail the 1991 plans to get districts to
think past 1994. Virtually all of the transportation strategies
are geared to the middle-to-long term. Furthermore, ARB's
emission accounting regulations require at least a preliminary
analysis through the year 2000, so districts, industry,
environmental groups, and the public know what lies ahead.
Staff will report and respond to additional comments on the Bay
Area plan at the April 30, 1992, hearing.
V. SUMKARY OF STAFF RECOMMENDATIONS
1. Approve the emission inventory elements of the Bay Area
plan.
2. Approve the carbon monoxide attairunent projection. Defer
action on the
ozone attainment demonstration until sufficient data area
available to support a photochemical modeling analysis.
3. Approve the severe area classification for the Bay Area
District.
4. Find the District in compliance with the ano net increase'
requirement
for new and modified permitted stationary sources.
5. Approve the BARCT proposals.
6. Find that the plan contains provisions to develop an area
source
control program.
7. Find that the District plan contains provisions to develop
an indirect
source control program.
S. Approve the smoking vehicle ccxnplaint program. Direct ARB
staff to
continue working with districts on fleet rules, with the
objective of resolving implementation issues prior to the
next planning cycle.
9. Find that the plan addresses all reasonably available TCMS,
but that
further definition is needed for some measures. Approve
those TCMs identified in Table 1 that fully comply with
the Act's requirements. Conditionally approve those TCMs
where further actions are needed to comply with the Act,
upon receipt of a commitment from the responsible agency
(primarily the District or MTC) to adequately define the
measures on an expeditious schedule. It is envisioned that
most of these improvements will be commitments to near
term actions (in the next 6-12 months). However, a few
may esquire longer timelines.
Note: At the time this staff report was re7eased, staff was
meeting with District and MTC representatives to determine if
an acceptable schedule to upgrade the incomp7ete TCMs could be
devised by the hearing date. If agreement is reached, the staff
will recommend the consensus schedule to the Board as part of
its action on the Bay Area p7an.
Find that the plan satisfies the requirement for a
substantial reduction in the growth rate for trips and trip
length. Also find that the plan satisfies the requirement
for no net vehicle emission increases after 1997.
Find that the plan does not currently satisfy the 1.5 AVO
requirement, and recognize that a significant amount of
time will be needed to either develop additional TCMs or to
obtain the needed authority and commitments for pricing
measures that are essential to achieving a 1.5 AVO by the
year 2000.
10. Endorse the investigation of intermittent control
strategies in the Bay
Area plan. Withhold approval of specific emission
reduction claims pending receipt of an acceptable
demonstration of their effectiveness.
11. Approve the District's emission accounting as consistent
with state
regulations. Approve the lesser rates of annual emission
reductions portrayed in the District's plan as the maximum
reductions possible, and as reflecting the expeditious
adoption of all feasible measures for the Bay Area.
12. Find that the District plan includes all feasible measures
within the
meaning of the Act, and in consideration of the factors
affecting the selection of control measures within the Bay
Area.
13. Approve the Bay Area's proposed schedule for rulernaking
and related
activities as nexpeditiousa within the meaning of the
California Clean Air Act and given the particular
circumstances facing the Bay Area District.
14. Find the District plan in compliance with the
cost-effectiveness
requirements.
15. Find the District in compliance with the transport
mitigation
requirements.
16. Approve the population exposure analysis as the best
information
currently available. Recommend that the District revisit
this analysis in the next update to the plan.
17. Find the plan in conformance with the uniformity
requirement for
regional pollutants. Direct the District to monitor the
effectiveness of delegated measures in achieving a uniform
degree of emissions control.
18. Find that the District plan includes provisions for public
education.
20. Conceptually approve the procedural approach to contingency
measures in
the Bay Area plan; seek further detail as to how it will be
effectively implemented. Clarify the conditions under
which plan revisions are necessary.
21. Find that the District has met its obligations under
CEQA.
Appendix A
PLAN REVIEW PROTOCOL
Onoer Lhe California Clean Air Act, the Air Resources Board is
responsible for reviewing and approving all district plans. The
Act requires that the ARB and districts develop a "uniform
conflict resolution procedure" before any district submits a
plan for attainment of state standards. ARB is considering the
appropriateness of regulation to implement the procedure.
Applicable sections of the Act are attached for reference.
It is ARB's intention to address and resolve differences as
early in the planning process as possible. The Board will
strive to provide clear guidance and communicate its
expectations prior to local adoption of plans. The protocol
below includes several steps prior to formal conflict
resolution to achieve that o b j e c t i v e .
Review of Draft Plans
1. Draft plans prepared by districts will be submitted to the
ARB's Office of Air Quality Planning and Liais'o'h (OAQPL)
as soon as available, but no less than 30 days before the
local hearing date.
2. OAQPL and Division staff will communicate comments to the
district by telephone, followed by written comments prior
to local plan adoption.
Review of Final Plans
Districts will submit final plans to OAQPL as soon as
possible after local adoption.
2. ARB will evaluate the final plans for compliance with all
applicable requirements.
3. ARB will prepare a notice indicating intent to approve or
disapprove the plan (or portions thereof). ARB will
provide its staff report and recommendations on each plan
to the affected district(s), as soon as available but no
less than 30 days before the Board hearing.
Board Action
1. All actions of the ARB to approve, revise and approve, or
disapprove district attainment plans will be taken at a
noticed public hearing.
2. The Board will approve a@cedtable plan portions by
resolution.
3. The Board will identify plan deficiencies by resolution
and transmit those findings to the district. Concurrently,
the Board will notice its intent to amend the plan within
90 days, if deficiencies are not corrected.
4. The district shall correct the deficiencies identified by
the
Board and submit its revised plan for approval. The
district may request initiation of Conflict-Resolution
procedures in lieu of revising its plan, if it does not
concur with the Board's findings.
Conflict-Resolution
1. Upon district request, the Board will designate a conflict-
resolution committee.
2.' The committee shall consist of representatives of the
affected district and ARB, and may include other parties (e.g.,
COG'S, transportation agencies) upon mutual consent.
3. The committee will meet and confer within 30 days of the
Board's finding of deficiencies and shall report its
conclusions back to the Board within 60 days.
4. The Board will give substantial consideration to consensus
recommendations of the conflict resolution committee in
determining whether a second opportunity to amend the plan
locally should be provided and, if not, what modifications
should be made by the Board.
Attachment
APPLICABLE SECTIONS OF THE CALIFORNIA CLEAN AIR ACT
41503.2 (a) If the state board concludes that a district's
plan does not meet the requirements of
Section 41503, the state board shall notify the
dstr7cl' of all deficiencies in writing. The
dis.,-Ict shall correct the
deficiencies....... and
shall submit its revised plan to the state board
for approval.
(b) If the district does not concur....... or the
state board determines that the district's plan
revisions are inadequate....... the state board
and the district shall attempt to resolve the
differences within three months of the
board's disapproval. The state board and the
districts shall develop a uniform conflict
resolution procedure....... prior to any
district's submittal of its attainment plan to
the state board.
(c) If a conflict between the state board
and district
cannot be resolved, the state board shall
take all of the following actions:
(1) conduct a public hearing
in the air basin (2).......
provide 45-day written notice....... (3) . . .
revise the district's plan as 7t finds
and determines necessary.
-'?1503.4 All actions of the state board to approve, revise
ana
approve, or disapprove a district's attainment plan or
plan revision shall be taken at a noticed public h e a
r i n g .
41503.5 The state board shall ensure that a district's
plan and
plan revisions meet the requirements -of th7s part and
of Part 3 (commencing with Section 40000), and that
every reasonable action is taken to achieve the state
ambient air quality standards....... by the earliest
practicable date.
Flow Chart for Plan Approval
local adoption
ir acceptable Board hearinc
deflclent
d i s t r I c t district
concurs does not concur
local plan revision onflict-resolution
90 I days
-T
Board hearing to amend ti-ie Piat-i, as t)ecessary
APPENDIX B
1991 BAY AREA AIR QUALITY ATTAINMENT PLAN ARB ANALYSIS OF
TRANSPORTATION CONTROL MEASURES
Volumes I & II (Appendix F)
INTRODUCTION
The Bay Area '91 Clean Air Plan (CAP) includes 23
transportation control measures (TCMs). This set of
measures was developed by the Metropolitan Transportation
Commission (MTC) and adopted with some modifications by the Bay
Area Air Quality Management District. The plan as revised has
not been adopted by MTC or the Association of Bay Area
Governments (ABAG).
Two of the TCMs are scheduled for District adoption as new
rules: TCM 2 (Employer-based Trip Reduction) and TCM 16
(Indirect Source Review). The other TCMs are to be implemented
by other agencies.
Implementation of the adopted TCM program is divided into
two phases. In general, Phase 1 measures are described
with more specific detail, and include milestones, completion
dates and funding commitments. Some measures lack information
on project scope, baseline data, key assumptions, analysis
methods and effects on travel.
Phase II measures are less specific. They generally
describe the goals, target group, estimated costs and
emission reductions of measures. Potential implementing
actions by lead agencies are discussed, but there are no
commitments for funding, timelines or milestones for
monitoring. The project scope is incomplete, and the background
data is often limited.
Pursuant to state law, district plans must evidence a
substantial degree of specificity and commitment to
implementation for all reasonably available measures. In
essence: AM is going to do @ by @. For complex or
multiyear projects, intermediate milestones for the planning
cycle are also needed. Commitment is shown for TCMs 2 and 16
by District adoption of this plan and District authority to
implement these two measures. Commitment to implement the
remaining measures is less clear, and varies by measure.
In order to evaluate effectiveness of the plan as well as
the individual TCMS, travel characteristics of the current
transportation system as well as the individual TCMs should be
identified. For transportation control measures, such
indicators include the quantity of trips, vehicle miles
traveled, location and duration of congestion, average vehicle
occupancy during commute hours and the transportation system
infrastructure. Forecasts of changes expected in each factor
over time are needed to successfully track the implementation of
the measures. Much of this information cannot be found in the
plan.
Staff does not believe that the transportation control
measures portion of the plan, as described in Appendices B
and F, are adequate at this time to meet all of the requirements
of the California Clean Air Act, and cannot
be unconditionally approved by the Air ROsources Board. Needed
additional information to be supplied for each measure, as well
aS the transportation system, is identified in the following
section.
TRANSPORTATION CONTROL MEASURES
Descriptions of the transportation control measures in the
Plan are included in Volume II (Appendix F). Volume II
describes how the TCM plan was developed, linkages among the 23
measures, and information on each TCM regarding purpose,
background, scope, travel market, costs, impacts, implementation
and impediments to the plan.
The projected reductions in the baseline 1997 on-road
vehicle emissions for ROG, NOx and CO for Phases 1 and 2
are stated as a percentage reductions for each TCM. A technical
report, Transportation Control Measures for the San Francisco
Bay Area: Analyses of Effectiveness and Costs (October 1991),
provided background information on modeling method, assumptions
and findings for the Plan. The report, prepared by Greg Harvey
and Betty Deakin for the BAAQMD, (Harvey-Deakin report) is cited
as a reference in the ARB analysis.
Additional information is included in Volume I. Table 4:
REDUCTION IN EMISSIONS AND VEHICLE TRAVEL FOR TCMs
suntnarizes the projected changes in the percentage and tons/day
of the criteria pollutant (RHC, NOx, CO) and the travel
indicators (vehicle trip, VMT). The pro,jected 1997 on-road
inventory includes: 137 tons/day (RHC), 222 tons/day (NOx) and
1939 tons/day (CO).
Most TCM implementation plans are conceptual, and they do
not contain enough specific information to be monitored.
Exceptions to this general evaluation are the two District rules
that are to be developed and adopted: TCM #2 and TCM #16.
Commitments from participating agencies, including a scope of
work, timelines, milestones and budgets to achieve the expected
results need to be provided for most of the other measures.
A shortfall of $500-$600 million dollars per year to
implement the Phase 2 programs is identified in the Revenue
Measures summary of the TCM plan (page F-3). This is a
substantial amount to be met by TCM #21. The Plan assumptions
that the TCM program will be implemented are not supported by
the existing revenues that have been identified to date.
Recent passage of the Federal Intermodal Surface
Transportation Efficiency Act (ISTEA) has provided new
flexibility in the use of revenues from the federal gas tax.
The combination of new federal, state and local revenues need to
be reexamined as funding sources for a revision of TCM #21.
Local government sales tax measures and congestion management
programs may also implement TCM activities.
Preparation of multimodal planning guidelines and lists of
"Jump Start" projects for early transportation programing
are opportunities to explore which TCMs may be funded with new
state and federal revenues. ARB staff recommends that high
priority be given these unfunded Phase 2 projects in
these decisions. Funding commitments should be reflected in the
upcoming state and regional Transportation Improvements Programs
(TIPs).
Additional ARB staff corrrnents regarding the individual
TCMs have been grouped in the following categories:
o Employer Based Trip Reduction o Mobility
Improvements o Traffic Operations System (TOS) o User
Incentives o Indirect Source Review o Implementation
Support o Revenue Measures o Pricing Measures o
Intermittent Measures
Specific coarnents on these measures are as follows:
TCM #2 Employer-Based Trip Reduction Rule
TCM #2 is projected reduce emissions by 3.57% (RHC), 3.67%
(NOx) and 3.76% (CO) by the adoption of a BAAQMD rule that
would affect 75% of the workforce and require employers to
develop programs equivalent to $3.00 daily parking charges with
subsidies for ridesharing, transit and other alternatives to
solo commuting.
Governmental administrative costs of $5 million per year
may be met by employer fees. Cities and counties that
develop equivalent trip reduction ordinances may be designated
to administer the plan. It is proposed that the rule
development be integrated with the trip reduction/demand
management element of local congestion management programs.
Clearly, TCM #2 is an ambitious measure, and staff believes
that it will be be effective in reducing emissions.
However, additional information on the assumptions and methods
used in calculating impacts should be included in the plan to
document the projected effectiveness.
The actual measure will be designed in the district's
rulemaking process. The plan does provide a clear
commitment by the district to implement TCM #2, an action for
which it has adequate authority. Future funding is assured
because the District can levy fees necessary to implement the
program.
ARB staff recommends that TCM #2 be fully approved, while
concurrently recommending that additional information on
the projected changes in actual numbers of vehicle trips,
vehicle miles traveled (VMT) and emission reductions be provided
to supplement the percentage changes reported in the
Harvey-Deakin study (A-3, B-3, C-1, D-1).
140BILITY IMPROVEMENTS
TCM #3 Improve Areawide Transit Service
TCM #3 is divided into funded (Phase 1) and unfunded (Phase
2) actions. Phase 1 includes continuation of
post-earthquake BART service (FTCM 17b), extending Caltrain
to Gilroy and expanding service from 54 to 66 tra' ins per
day (FTCM 19) and encouraging transit operators to do market
analyses and to convert bus fleets to clean fuel vehicles.
Projected emission reductions from Phase 1 are: 0.46% (RHC &
NOx) and 0.44% (CO).
Unfunded Phase 2 activities are projected to yield
additional emission reductions: 1.00% (RHC) and 0.90%
(NOx & CO). Estimated annual costs of expansion of rail
service ($100 million) and bus service ($140 million) do
not have identified revenue sources for the expanded measure.
The cost estimates for Phase 2 include both the
capital costs for rails and bus equipment and operating
shortfalls. An increase of 33 percent in funding and ridership
capacity is projected in the Harvey Deakin report (pages
A-3,4; B-3,4,5; C-1, D-1).
TCM #3 is an ambitious measure, and ARB staff believes
that it could provide significant emission reductions.
However, additional information is needed to establish the
degree of emission reduction and related impacts on
regional mode split, vehicle trips, VMT and vehicle
occupancy that are projected. Program activities in Phase 1
need to specify the lead agency, budget, timetable,
milestones and expected effects on transit operations.
Preliminary ARB staff review of the 1992-2000 Short
Range Transit Plans for transit operators indicates that
current expansion plans for the regionwide bus fleet, after
deducting planned bus replacements, is less than one
percent. Therefore, further review of this objective is
needed, in light of the additional flexibility for use of
state and federal transportation funds that has been provided
in recent legislation. The multimodal guidelines being
developed should address transit spending priorities.
The Metropolitan Transportation Commission (MTC) support of
transit expansion as a high priority for the Regional
Transportation Plan (RTP) is encouraging. We recommend that
the transit projects included in the State Transportation
Improvement Program be identified for Phase 1 projects.
The long range RTP plans for bus and rail service should be
cited as Phase 2 assumptions.
>> The ARB staff recommends that this measure be
>> conditionally approved, provided that MTC, county
>>congestion management agencies, Caltrans and regional
>>transit providers commit to an expeditious schedule to
>>provide the following data regarding Phase 2:
>>
>>0 Documentation regarding calculation of emission reduction
>>impacts, 0 Clear commitment by participating agencies to
>>implement the measure, 0 Additional data needed to clarify
>>when the measure will be implemented, 0 Additional details
>>that define the target performance goals, and
>>
>>0 A funding program that is adequate to implement the
>>measure.
TCM #5 Improve Access to Rail and Ferries
Existing funding sources are expected to provide an
unstated amount of support to improve access to rail and
ferries in connection with other TCM activities and
projects. This Phase 1 of TCM #5 is projected to reduce
emissions by 0.02% (RHC, NOx) and 0.03% (CO).
Phase 2 activities would include timed-transfer access
to mass transit at an estimated total cost of $50 million
per year with a projected emission reduction of: 0.30%
(RHC, NOx) and 0.25% (CO). (See Harvey-Deakin report,
pages A-5, A-6, B-6, C-1, C-2, D-3.)
ARB staff believes that this measure could help increase
the modal shifts and therefore reduce emission reductions
from motor vehicles. There is, however, the potential for the
'double-counting" of the emission reductions from access
improvements funded as part of other TCM activities or
programs. Additional information needs to be provided on the
assumptions, calculation methods and projected impacts on
emissions and related travel indicators (e.g., regional vehicle
trips, VMT) to fully evaluate the proposed measure.
Work efforts by various transportation agencies that
could contribute to the Phase 1 implementation are
identified (page F-19). The plan does not contain enough
specific information on what actually will be done so that the
measure can be monitored. Additional information needs
to't;e provided regarding the lead agencies, resource
commitments, timelines, milestones, and projected ridership
changes for both Phases 1 and 2.
The ARB staff recommends that this measure be
conditionally approved, provided that MTC and all
identified service providers commit to an expeditious schedule
to provide:
0 Documentation regarding calculation of emission
reduction impacts, 0 Clear commitment by participating
agencies to implement the measure, 0 Additional data needed
to clarify when the measure will be implemented, 0
Additional details that define the target performance goals, and
0 A funding program that is adequate to implement the
measure.
TCM #6 Improve Intercity Rail Service
TCM #6 is projected to reduce emissions by 0.05% (RHC
& NOx) and 0.04% (CO) in Phase I due to the initial
intercity rail service of three daily roundtrips in the
Auburn-Sacramento-San Jose Corridor (Federal TCM 18). The
funding for rolling stock (over $107.4 million) and operations
($7 million) were available. The ridership in early 1992
has exceeded expected numbers.
Daily service is projected to expand to 10 roundtrips
by 1999/2000 with an additional emission reduction of
0.04% (RHC & NOx) and 0.03% (CO). in Phase 2. This goal was
based on the ARC 132 (Hannigan) Rail Corridor Upgrade Study.
Institutional agreements and additional funding will be needed
to reach this goal. The additional costs were not
identified. (See pages A-6, B-6, C-2, D-4 of Harvey-Deakin
report.)
ARB staff believes that expansion of intercity rail
service to the Bay Area could be effective in reducing
emissions. Additional information on the assumptions and
methods used in calculating impacts on emissions and travel
indicators affected by greater rail use (e.g. regional
mode splits, vehicle trips, VMT, vehicle occupancy). Given
the initial popularity of the service, the rate of ridership
growth and emission reductions may prove to be underestimated.
As a minimum, it seems possible that the Phase 2 emission
reductions are low, because they are not proportional to the
increases in daily train trips.
The plan does not contain enough specific information on
implementation steps so that the measure can be monitored.
Additional information needs to
be provided regarding the lead agencies, resource
commitments, timelines, milestones, and projected ridership
changes for both Phases 1 and 2.
The ARB staff recommends that Phase 1 be approved and that
Phase 2 of this measure be conditionally approved, provided
that MTC, Caltrans, rail transit providers, and any
affected congestion management agencies commit to an
expeditious schedule to provide:
0 Documentation regarding calculation of emission reduction
impacts, 0 Clear commitment by participating agencies to
implement the measure, 0 Additional data needed to clarify
when the measure will be implemented, 0 Additional details
that define the target performance goals, and 0 A funding
program that is adequate to implement the measure.
TCM #7 Improve Ferry Service
TCM #7 is a measure with two phases. Phase 1 includes the
funded projects to continue post-earthquake ferry service
between Oakland/Alameda and San Francisco Ferry (Federal TCM 17)
with an operating subsidy of $750,000, and $10 million is
available in the 1994-97 period for Wallejo ferry
improvements. The projected reductions in emissions from Phase
1 are 0.02% (RHC) and 0.01% (NOx & CO).
Phase 2 is projected to reduce emissions by another 0.03%
(RHC & NOx) and 0.02% (CO). At an additional cost of $10
million per year, new ferry service would be provided between
San Francisco and Berkeley/Richmond, and between the Oakland and
San Francisco airports. Feeder bus service to ferries would be
included. (See TCM #5) Privately-operated ferries servicing
Port Sonoma and Harbor Bay Isle are also being considered.
(See Harvey-Deakin report, pages A-6, A-7, B-7, C-2,
The implementation section provides useful arrangements in
Phase 1. An increase in annual million person-trips per year
by the mid-1990s, improvements, is cited from a MTC study for
the Ferry Service Plan.
D-4.)
detail on costs and funding ridership from 2.7 to 4.0 given
ferry service
SB 2169 (Kopp) Long Range
ARB staff believes that expansion of ferry services could
be effective in reducing emissions. The plan does not
provide enough information on the assumptions and methods
used in calculating impacts on emissions and regional travel
indicators affected by greater ferry use (e.g., regional mode
splits, vehicle trips, VMT, vehicle occupancy), so more
information needs to be provided.
The ARB staff reconynends that Phase 1 of this measure be
approved, and that Phase 2 be conditionally approved
provided that MTC, ferry operators and any affected congestion
management agencies commit to an expeditious schedule to
provide:
0 Docunentation regarding calculation of emission reduction
impacts, 0 Commitment by participating agencies to implement
Phase 2 projects, 0 Additional data needed to clarify when
the measure will be implemented, 0 Additional details that
define the target performance goals, and 0 A funding program
that is adequate to implement the measure.
TCM #9 Construct Carpool/Express Buslanes on Freeways
TCM #8 is a two-phase expansion of the existing
80-lane-mile HOV lane system in the Bay Area. Construction
of 220 directional HOV lane-miles (Federal TCM 20) is to be
financed from the $500 million in funding for HOV projects
included in the 1988 State Transportation Improvement Program
(STIP). This expansion is projected to reduce emissions by
0.23% (RHC), 0.22% (NOx), and 0.20% (CO).
Phase 2 is projected to reduce emissions by 0.41% (RHC),
0.40% (NOx) and 0.38% (CO) with the construction of another
190 HOV lane-miles that are proposed in the 2005 HOV Lane
Master Plan. MTC is to work with Caltrans in the design and
funding of HOV facilities, study HOV support facility needs,
and seek funding for additional express bus service in HOV lane
corridors. The total costs, funding sources and work plans to
implement these Phase 2 projects are not stated in the plan.
(See Harvey-Deakin report, pages A-7, A-8, B-7, C-2, D-4.)
ARB staff believes that expansion of the HOV facilities
could be effective in reducing emissions. HOV lanes can
provide time savings incentives to users that would enhance the
effectiveness of the TCM plan as a whole. However, ARB staff
questions whether all routes where HOV lanes would be feasible
strategies to reduce congestion and emissions have been included
in the existing masterplan. For example, over half of the HOV
system is to be located in Santa Clara County.
The August 1990 report to MTC, 2005 HOV Program
Prioritization, outlined an action program that could
result in completing the remaining 190 lane-miles in the master
plan by 2005. ARB staff believes that each of the 16
unfunded HOV projects should be reviewed as recommended with
special attention to the following projects:
0 CC-80 between Willow and the Carquinez Bridge in Contra
Costa County
0 SCL-Capitol Expressway between Almaden and I-680 in
Santa Clara County
0 SCL-237 between Route 85 and U.S. 101 in Santa Clara County
0 SCL-Almaden Expressway between Haney Road and Ironwood in
Santa Clara
County
0 CC-4 between Route 242 and Hillcrest in Contra Costa County
0 SON-101 between Marin County line and Washington in Sonoma
County
0 CC-680 between Route 4 and the Benecia Bridge in Contra
Costa County
0 ALA-92 from Clearwater to 1-880 in Alameda County
0 SCL/ALA-680 from Montague to Route 238 in Alameda County
0 SCL-87 from I-280 to US-101 in Santa Clara County
In addition, ARB staff recommends that all
capacity-increasing construction projects be evaluated as
possible additions to the 2005 HOV Lane Master Plan to provide a
more comprehensive HOV system. Funding opportunities to
identify and construct new HOV lanes in the system may now be
available under the provisions of new State and Federal
legislation regarding uses of gas tax revenues. Revisions in
the criteria used in selecting priority projects for the 1992
STIP should be considered to meet the TCM implementation
schedules.
The plan does not contain enough specific information on
implementation steps so that the measure can be fully
monitored. Additional information needs to be provided
regarding the lead agencies, resource commitments, timelines,
milestones, and projected changes in HOV use due to funded and
unfunded projects completion.
The plan also fails to provide enough information on the
assumptions and methods used in calculating impacts on
emissions and regional travel indicators affected by the
expanded HOV system (e.g. regional mode splits, vehicle trips,
VMT, vehicle occupancy), so more information needs to be
provided.
The ARB staff recommends that this measure be conditionally
approved, provided that MTC, Caltrans, and county
congestion management agencies 0 Documentation regarding
calculation of emission reduction impacts, 0 Commitment by
participating agencies to implement the measure, 0 Additional
data needed to clarify when the measure will be implemented,
0 Additional details that define the target performance
goals, and 0 A funding program that is adequate to implement
the measure.
TCM #9 Improve Bicycle Access and Facilities
>> TCM #9 includes programs to encourage bicycle use for
>> short trips of various types. A target was added by the
>>District to the MTC-adopted measure that set the goal of
>>increasing the bicycle mode share during comute hours from 1.3%
>>in 1980 to 3.0% by 1997.
The projected emission reduction for Phase 1 is 0.01% (RHC,
NOx, CO), based on continued expenditure of $3 million per
year for bikeway projects in the region. New guidelines are to
be drafted by MTC for local applications for these funds for
Fiscal Year 1993-94.
Unfunded bicycle projects in Phase 2 are projected to
reduce emissions by 0.02% (RHC & NOx) and 0.03% (CO) at an
estimated cost of $5 million per year. Proposed funding sources
included new State revenues and coordination of plans with
Caltrans and transit operators to include provisions for
bicycles. (See Volume II, and Harvey-Deakin report pages A-9,
A-16, B-7, B- 8, C-2, D-5.)
Information is lacking on how the 3% goal for bicycle use
is projected to affect future predictions of emission
reduction, VMT and vehicle trips. A schedule and budget for
implementation by responsible agencies is needed. Other sources
of revenue should be discussed as possible funding sources.
>> The conceptual target for 3% peak period bicycle trips is
>> ambitious, and ARB staff believes that increases in bicycle
>>use could be effective in reducing emissions. The plan does not
>>provide enough information on the assumptions and methods used
>>in calculating impacts on emissions and regional travel
>>indicators affected by more bicycle use (e.g., regional mode
>>splits, vehicle trips, VMT), so more information needs to be
>>provided.
The plan does not contain enough specific information on
implementation
steps so that the measure can be monitored. Additional
information needs to be provided regarding the lead agencies,
resource commitments, timelines, milestones, and projected
ridership changes for both Phases 1 and 2.
The ARB staff recommends that Phase 1 of this measure be
approved and Phase 2 be conditionally approved, provided
that MTC, Caltrans, and county congestion management agencies
commit to an expeditious schedule to provide:
0 Documentation regarding calculation of emission reduction
impacts, 0 Commitment by participating agencies to implement
the measure, 0 Additional data needed to clarify when the
measure will be implemented, 0 Additional details that define
the target performance goals, and 0 A funding program that is
adequate to implement the measure.
TCM #10 Improve Youth Transportation
TCM #10 is designed to reduce travel and emissions related
to the transportation of children and youth. School trips
account for an estimated 2%-3% of weekday vehicle miles
traveled in the Bay Area. Transportation of children and youth,
outside of school hours, is also addressed.
TCM #10 is projected to reduce emissions by: 0.14% (RHC &
NOx) and 0.16% (CO) at a cost of $11 million dollars
annually. Projects to attain these reductions were placed in
Phase 2 because no funding was identified. Projects include:
$5 million for discount transit tickets, $5 million for school
bus service and $1 million to promote ridesharing among
students.
Information is lacking on how the measure is projected to
affect future predictions of mode split, vehicle trips,
VMT and average vehicle occupancy. A schedule and budget for
implementation by responsible agencies is needed.
This is a modest supporting measure that ARB staff believes
would help decrease the emissions from vehicle trips by
parents or youthful drivers for transportation to school and
after-school activities due to more schoolbus and public
transit ridership. There is, however, a potential problem with
the "double-counting" of emission reductions if these service
improvements are being funded as part of another TCM program or
activity. (See TCM #13)
Additional information needs to be provided on the
assumpti4ns, calculation methods and projected impacts on
emissions and related travel indicators (e.g. regional mode
splits, vehicle trips, VMT, vehicle occupancy) to fully evaluate
the proposed measure.
The plan does not contain information on specific proposals
with an action plan that can be monitored. No funding
sources are identified beyond what may provided by new State
legislation. Recent passage of State and Federal gas tax
legislation that allows more local discretion may provide a
source of funding for this measure. Additional information
needs to be provided regarding the lead agencies, resource
commitments, timelines, milestones, and projected outcomes of
this measure.
The ARB staff recommends that this measure be
conditionally approved, provided that MTC, District, RIDES
and transit providers commit to an expeditious schedule to
provide:
0 Documentation regarding calculation of emission reduction
impacts, 0 Comrritment by participating agencies to implement
the measure, 0 Additional data needed to clarify when the
measure will be implemented, 0 Additional details that
define the target performance goals, and 0 A funding program
that is adequate to implement the measure.
TRAFFIC OPERATIONS SYSTEMS
TCM #11 Install Freeway Travel Operations System (TOS)
TCM #11 will reduce congestion-related emissions by
improving the flow of traffic on regional freeways.
Many traffic operational improvements are to be included in
Caltrans Traffic Operations System (TOS).
Phase 1 implementation of the TOS Segment I on
freeways near the Bay Bridge are predicted to reduce
emission by: 0.42% (RHC), 0.35% (NOx) and 0.65% (CO). The
cost, schedule and funding source for Phase I (FTCM 26)
are stated.
Phase 2 of the Caltrans TOS is predicted to reduce
emissions by 1.40% (RHC), 1.10% (NOx) and 1.80% (CO).
The plan notes that small increases in vehicle trips
(0.10%) and VMT (0.15%) are expected from the fully
completed 216-mile TOS system when it is in full operation.
(See pages A-11, A-12, B- 10, B-11, C-3, D-6, D-7 of the
Harvey-Deakin report.)
This is an ambitious measure to improve traffic flow
on freeways and arterials in the Bay Area. ARB staff
believe that reducing congestion by providing reducing hours
of delay due to incidents and excess demand can both have
emission benefits. Recent ARB research has provided new
information regarding the relationships between vehicle
accelerations and emission rates. Further research on how
total emissions from metered ramps and mainline freeway
operations is underway, so it is possible that emission
reductions from this measure may need revision at a future
update of the TCM plan.
Additional information should be provided on the
assumptions, calculation methods and projected impacts
on emissions and related travel indicators (e.g. regional
mode splits, vehicle trips, VMT, vehicle occupancy) to fully
evaluate the effectiveness of the proposed measure.
The plan does not contain information on a specific
action plan that can be monitored. Caltrans is
identified as the funding source, and MTC is to cooperate in
developing the TOS ramp metering component and seeking funding
to install electronic toll collection on the Bay Bridge (See TCM
#20). More complete information needs to be provided
regarding the funding sources, resource commitments,
timelines, milestones, and completion dates for TCM #11.
The ARB staff recommends that this measure be
conditionally approved, provided that MTC, Caltrans
and any county congestion management agencies that are
affected commit to an expeditious schedule to provide:
0 Documentation regarding calculation of emission
reduction impacts, 0 Commitment by participating
agencies to implement the measure, 0 Additional data
needed to clarify when the measure will be implemented,
0 Additional details that define the target performance
goals, and 0 A funding program that is adequate to
implement the measure.
TCM #12 Improve Arterial Traffic Management
TCM #12 includes improvements to arterial travel flow due
to signal timing programs, bus flow improvements and
Caltrans' "smart streets" programs. This measure continues an
ongoing program to extend retiming programs to new traffic
signals (FTCM #24) and to maintain them in good operating
condition (FTCM #25). The use of arterials as reliever routes,
or usmart streets" is related to the TOS operating system (see
TCM #12).
This measure is projected to reduce emissions by 0.20%
(RHC), 0.25% (NOx) and 0.30% (CO) in Phase 1. When funded,
Phase 2 actions are predicted to further reduce emissions by:
0.23% (RHC), 0.52% (NOx) and 0.33% (CO). The completed measure
is also predicted to result in small increases in vehicle trips
(0.03%) and VMT (0-02%). Annual costs are of this ongoing TCM
program are estimated at $6 million per year, and the plan is
unclear regarding when the costs and benefits are projected to
occur. (See pages A- 13, B-12, B-13, C-3, D-7 of the
Harvey-Deakin report.)
ARB staff believe that improvements to arterial traffic
flow can provide some emission reduction benefits with
little creation of new travel demand when the improvements are
made in areas where land development has already occurred.
Improvements that favor the flow of buses, such as bus/HOV
lanes, bus traffic signal preemption and relocation of bus
stops, would have the highest benefit.
More detailed information needs to be provided on the
physical facilities and the measure's emissions and related
travel indicators (e.g., regional vehicle trips, VMT, vehicle
speeds) to fully evaluate the effectiveness of the proposed
measure.
The plan contains useful detail on the signal retiming
program scope, funding source and schedule. More complete
information needs to be provided regarding the funding
sources, resource corrfnitments, timelines, milestones, and
completion dates for TCM #12.
The ARB staff recommends that Phase 1 of this measure be
approved and Phase 2 be conditionally approved, provided
that MTC, Caltrans and any county congestion management agencies
that are affected commit to an expeditious schedule to provide:
0 Documentation regarding calculation of emission reduction
impacts, 0 Commitment by participating agencies to implement
the measure, 0 Additional data needed to clarify when the
measure will be implemented, 0 Additional details that
define the target performance goals, and 0 A funding program
that is adequate to implement the measure.
USER INCENTIVES
TCM #13 Transit Use Incentives
TCM #13 consolidates and expands upon the transit use
incentives included elsewhere in the TCM plan. Proposed
projects include: selective fare reductions, an expanded ticket
distributions system, improved coordination of fares among
transit operations (FTCM #21) and a regional toll-free transit
information number.
Phase 1 actions appear to be funded as part of the MTC
work program. The costs are not defined, but the emission
reductions predicted are: 0.11% (RHC & NOx) and 0.09% (CO).
When funded, Phase 2 activities are predicted to further reduce
emissions by: 0.21% (RHC & NOx) and 0.22% (CO).
Costs for the full program are estimated at $18 million
dollars per year. Projects would include: $10 million for
selective fare subsidies; $5 million for feeder bus service to
rail and ferries and $3 million for 'transit stores" based on
the Berkeley TRIP model. The plan states that such subsidies
would help address the "equity" concerns regarding revenue
generating (TCM #21) and pricing measures (TCM #22) included in
the TCM plan. (See Volume II and Harvey-Deakin report, pages
A-14, B-14, B-15, C-3, C-4, D-7, D-8.)
This measure would expand transit subsidies somewhat beyond
those proposed elsewhere in the TCM plan. The ARB staff
believes that financial incentives can provide motivation to
change travel modes, and thus help reduce vehicle emissions.
However, because of the overlap between TCM #13 and other TCM
activities, care should be taken to avoid "double-counting" of
the benefits and costs of programs, such as: youth and
children's transit fares subsidies (TCM #10), feeder buses to
rail and ferries (TCM #5), and "transit stores"that are part of
an employer trip reduction plan (TCM #1, TCM #2).
Additional information needs to be provided on how the
projected emission reductions have been calculated before
the effectiveness of this measure can be fully evaluated. This
would include: the assumptions, calculation methods and
projected effects of Phases 1 and 2 on vehicle emissions and
related travel indicators (e.g. regional mode splits, vehicle
trips, VMT, vehicle occupancy and transit ridership on services
affected by the TCM #13 programs).
The plan contains general descriptions of the activities to
be included, and additional detail on the 1991 work
programs and budget items of agencies that are participating in
Phase 1 activities (MTC, RIDES, transit operators). The funding
included $80,000 in State transportation funds and transit
operator support.
The proposed Phase 2 activities are not defined in a manner
that can be monitored for performance, and they are
contingent on future funding from revenue sources that were
unavailable when the measure was drafted (TCM #21). New revenue
sources have been provided by State and Federal legislation, and
we recommend that they be evaluated as possible ways of
funding the transit use incentives in a timely fashion. More
complete information needs to be provided for Phase 2 actions
regarding the funding. sources, resource corrrnitments,
timelines, milestones, and expected completion dates.
The ARB staff recommends that this measure be conditionally
approved, provided that MTC, Caltrans and any county
congestion management agencies that are affected commit to an
expeditious schedule to provide:
0 Documentation regarding calculation of emission reduction
impacts, 0 Commitment by participating agencies to implement
the measure, 0 Additional data needed to clarify when the
measure will be implemented, 0 Additional details that define
the target performance goals, and 0 A funding program that is
adequate to implement the measure.
TCM #14 Vanpool Liability Insurance
TCM #14 would seek to increase the rates of vanpool
formation and retention by offering a publicly-financed or
subsidized vanpool liability insurance program. Vanpools
currently serve less than one percent of Bay Area Commuters, and
liability insurance costs of $2,500-$3,000 per year appear to be
a factor in the declining rate of growth for this transportation
mode.
Phase I consists of a RIDES study to determine how this
program can stimulate growth of vanpooling in the Bay
Area. It is to be conducted in FY 1991-92 within their funded
work program.
Implementation in Phase 2 is contingent on securing funding
for the program. Estimated costs are $2.1 million per year
for full public funding. but the actual costs would depend on
the scope of the program and the level of subsidy that was
provided. The emissions reductions predicted from establishing
a vanpool liability insurance program are: 0.02% (RHC & NOx)
and 0.01% (CO). (See Volume II and Harvey-Deakin report, pages
A-15, B-15, C-4, D-8.)
TCM #14 lacks information on the assumptions, data and
methods used to calculate costs and effectiveness of this
measure. As with other support measures, it is important to
avoid "double-counting" of the vanpool emission reductions.
I,nformation is also lacking on projected effects on future mode
sPlit, vehicle trips, VMT and average vehicle occupancy.
If the Phase 1 study findings are positive, the funding
opportunities though new and existing revenue sources
should be reexamined. For example, transportation management
associations (TMAS) might be asked to participate in a joint
benefit program of this nature. Local discretion has been
increased regarding uses of gas tax and vehicle registration
surcharge fees.
This measure would remove or reduce an identified
disincentive to vanpool use, and the ARB staff believes
that the cost reduction would add motivation for greater vanpool
use, and thus help reduce vehicle emissions. However, because
of the overlap between TCM #14 and other TCMs that include
vanpool elements, care should be taken to avoid
"double-counting" of the benefits and costs of this program.
Examples include measures to reduce single-occupant vehicle
trips through employer trip reduction plans (TCM #1, TCM #2).
Additional information needs to be provided on how the
projected emission reductions have been calculated before
the effectiveness of this measure can be fully evaluated. This
would include: the assumptions, calculation methods and
projected effects of Phase 2 implementation on vehicle emissions
and related travel indicators (e.g. regional mode splits,
vehicle trips, VMT, vehicle occupancy and future vanpool numbers
and ridership).
The measure is not defined in a manner that can be
monitored for performance, and more complete information
needs to be provided as the Phase 2 program is developed
regarding the funding sources, resource commitments,
timelines, milestones, and expected completion dates. We
realize that funding has not yet been identified, and
implementation is contingent on securing funds from revenue
sources that were unavailable when the measure was drafted (TCM
#21). New revenues, provided by recent State and Federal
legislation, will now need to be evaluated as possible ways of
funding a lower cost insurance program. Another funding source
might be a jointly financed program with participation by
transportation management organizations, as a benefit for
employer members.
The ARB staff recommends that this measure be fully
conditionally approved, provided that MTC, RIDES and the
District commit to an expeditious schedule to provide:
0 Full documentation regarding calculation of emission
reduction impacts, 0 Clear coninitment by participating
agencies to implement the measure, 0 Additional data needed
to clarify when the measure will be implemented, 0 Additional
details that define the target performance goals, and 0 A
funding program that is adequate to implement the measure
TCM #15 Provide Carpool Incentives
TCM #15 would support legislation to increase the Federal
tax deductions for employees of transit and ridesharing
subsidies, and to change State and federal tax policies that
allow employers to deduct the costs of providing free or
subsidized employee parking a business expense. No costs or
emission reduction benefits are identified for these Phase 1
activities that are to be included in the funded MTC and
District work programs.
Future Phase 2 projects of this measure include both
private employer incentive programs and a new regional
carpool subsidy program to be designed by MTC and RIDES.
Employers would pay cash incentives to employees in the
private plans (See TCM #1, TCM #2), while the mmobility package'
revenues expected from TCM #21 are proposed as the funding
source for the RIDES carpool subsidy program. Costs are not
given because they would vary by the types of subsidy programs
what were developed. However, the Phase 2 emission reductions
are projected as 0.20% (RHC & CO) and 0.30% (NOx). (See Volume
II and Harvey-Deakin report, pages A-15, B-15, C-4, D-8, D-9.)
This support measure contains both public and private
subsidy programs, and it is unclear if any separation has
been made in calculations of the future emission reduction
effects. The ARB staff believes that financial incentive
programs can encourage mode switching, and thus reduce vehicle
emissions. Care must be taken to avoid "double-counting' of
emissions where TCM plan objectives overlap. This type of
confusion may have occurred in this measure.
Additional information needs to be provided regarding the
assumptions, data and methods used to calculate costs and
effectiveness of this measure. Information is also needed
regarding the projected effects on future mode split, vehicle
trips, VMT vehicle occupancy and projected changes in the number
of carpools and carpool person-trips.
The plan does not define the Phase 2 measure in a way that
can be monitored for measure implementation. More
information needs to be provided on the Phase 2 program scope
and implementation plans for the two subsidy programs. (e.g.,
activity schedule, lead agencies, timetable, milestones, costs
and revenue sources). Funding options for the regional carpool
subsidies need to be reexamined in light of current State and
Federal programs. Local discretion has also been increased
regarding uses of gas tax and vehicle registration surcharge
fees.
The ARB staff recommends that this measure be conditionally
approved, provided that MTC, RIDES and the District commit to
an expeditious schedule to provide:
0 Full documentation regarding calculation of emission
reduction impacts, 0 Clear commitment by participating agencies
to implement the measure, 0 Additional data needed to clarify
when the measure will be implemented, 0 Additional details that
define the target performance goals, and 0 A funding program
that is adequate to implement the measure.
INDIRECT SOURCE REVIEW
TCM #16 Indirect Source Control Program
TCM #16 includes the adoption of District rules to
regulate new and existing development. Non-work trips
are the stated target for the measure.
The initial rule that will affect only new and modified
land development is projected to reduce emissions by 0.7%
by 1997. Full implementation of TCM #16 will include a second
rule that affects existing land uses as well, and the long-term
projections of reduction in vehicle miles traveled (VMT) are
stated to be as much as 10 percent by 2005 or 2010 with similar
projections made for emission reductions (RHC, NOx, CO). (See
Volume II and the Harvey-Deakin report, pages A-16, B-16, C-4
and D-9.)
Clearly, TCM #16 is an ambitious measure, and ARB staff
believes that it will be be effective in reducing
emissions. However, additional information on the assumptions
and methods used in calculating impacts must be provided for
review to document the projected effectiveness.
The plan states that the TCM #16 emission reduction
projections will not overlap with reductio'ns projected for
high densities near transit (TCM #18). Similarly,the focus on
non-work trips appears to be taken to avoid overlap with TCM
#2, the Employer Trip Reduction Rule. To the degree that
home-work trips are made by persons working for small firms that
are not not covered by TCM #2, some underestimation of trips
diverted from this employee subgroup could occur in projecting
future emission reductions.
The plan does not contain sufficient information to fully
evaluate the scope of the rule to be developed. Given
that the actual measure will be designed in the district's
rulemaking process, it is not necessary to resolve this issue in
the plan itself. The plan does provide a clear commitment by
the district to implement TCM #16 by the adoption of rules to
reduce the vehicle emissions impacts from new and existing land
uses, an action for which it has adequate authority. Future
funding is assured because the District can levy fees necessary
to implement the program.
ARB staff recommends that TCM #16 be approved. The scope
and projected emission reductions will be refined in the
rule adoption process.
IMPLEMENTATION SUPPORT
TCM #17 Conduct Public Education
The purpose of this measure is to inform people regarding
the current status of air quality in the Bay Area and
inform them on individual actions to better air quality.
No additional emission reduction credit is claimed for this
support program. The BAAQMD Public Outreach Steering
Committee will help develop and implement an ongoing public
education program throughout this plan.
The initial costs of this campaign are $250,000, and this
expense was funded by an EPA grant. The BAAQMD is seeking
sources of funds to continue and expand the program.
Information is lacking on the final scope of the
continuing public education program with milestones and
budget.
ARB staff recommends that Phase 1 of this measure be
approved and Phase 2 be conditionally approved, while
concurrently recommending that additional information be
provided to fully document the future program objectives,
schedule and budget for the District program to implement the
public education requirements of the Act.
TCM #18 Zoning for High Densities Near Transit Stations
TCM #18 is designed to reduce vehicle trips and increase
transit ridership by promoting high density, mixed-use
development in the area of transit stations. The targeted areas
are located around the rail extensions included in TCM #4,
Expedite and Expand Regional Rail Agreement.
Emission reductions are projected to be reduced by 0.05%
(RHC, NOx, CO) in Phase 2, and annual costs of $500,000
are estimated to prepare site plans for transit station.
Phase I activities would take place within existing
budgets, including: the evaluation of transit-oriented
development patterns for the Bay Area for the Regional
Transportation Plan (MTC), seeking of funds for preparation of
specific area plans for transit stations (MTC, transit
agencies) and cities and counties will be encouraged to plan
for high density, mixed-use development near transit by the
District to implement TCM #18, as well as TCM #16 (indirect
source review) and TCM #19 (air quality elements). (See Volume
II and Harvey-Deakin report, pages A-17, B-16, B-17, C-4, D-9.)
The plan bases the emission reduction on obtaining extra
funding needed to prepare site plans for transit station
development. A decrease in vehicle trips is expected to occur
that is beyond the scope of related TCMs in the plan. ARB
staff agrees with the conclusion that some increase in TCM
plan effectiveness is reasonable, due to this measure.
However, additional information 'is needed for full review of
the emission reductions and overall TCM plan impacts.
The ARB staff recommends that this measure be conditionally
approved, provided that the MTC, District and transit
agencies corrfnit to an expeditious schedule to provide:
0 Documentation regarding calculation of emission reduction
impacts, 0 Commitment by participating agencies to implement
the measure, 0 Additional data needed to clarify when the
measure will be implemented, 0 Additional details that
define the target performance goals, and 0 A funding program
that is adequate to implement the measure.
TCM #19 Air Quality Elownt for General Plans
TCM #19 encourages all cities and counties to include an
Air Quality Element in their General Plan to ensure that
air quality issues are integrated into lower planning and
decision-making.
This support measure would expand the District efforts to
have local governments in the Bay Area adopt these elements
which began in 1986. District efforts include revision of
existing guidelines, the support of state legislation to mandate
Air Quality Elements in general plans and expanded assistance to
cities and counties in preparing the elements. The adoption of
an element will be a condition of delegation for administration
of the future indirect source rules (TCM #16). (See Volume II.)
ARB staff commends that District for the leadership that it
has shown in providing leadership in developing this form
of local support by cities and counties. The plan points out
the beneficial effects of having an adopted air quality element
in General Plans in the promotion of sound planning and policies
at the local level, and by supporting the implementation of
other TCMs in the Clean Air Plan. ARB staff agrees with this
assessment. The District experience in promoting this approach
will produce information of value to other districts, and it is
recommended that progress reports be made on this measure.
ARB staff recommends that TCM #19 be accepted as an
uncredited measure in support of the Act.
TCM #20 Conduct Downstration Programs
TCM #20 will provide demonstration programs and studies to
encourage innovative approaches to reducing vehicle travel
and emissions. Topics listed as examples include:
telecommuting, congestion pricing/electronic license plate
evaluation and electric or natural gas carpools.
The scope of these activities will depend on available
funding. The estimated costs are $500,000 per year. No
additional emission reduction credit is claimed for these
small-scale projects.
Additional detail on how these activities will be included
in the work programs of participating agencies would be
desirable. Timelines, budgets and work products for adopted
studies and demonstrations should be provided.
ARB staff recommends that TCM #20 be accepted as an
uncredited measure in support of the Act, while
concurrently recommending that additional information be
provided to fully document the assumptions and experience in
implementing the demonstration projects that are included in
the measure.
REVENUE @URES
TCM #21 Implownt Revenue Measures
TCM # 21 is designed to secure the additional revenue
needed to fully fund the mobility improvement measures in
the TCM plan. Added revenues of $500-$600 million per year are
needed to meet this funding shortfall. (See Volume II; Volume
I, page 19; and the Harvey-Deakin report, pages A-19, B- 17,
B-18, C-4, D-10.)
Three of the five revenue measures have been approved.
These Phase 1 elements include:
1) an increase of $.09 per gallon in the State
gasoline tax, 2) an increase to $1.00 for all bridge
tolls, and 3) passage of AB 434 authorizing vehicle
registration fee
increases of up to $4 per vehicle
Action has not been taken on legislation to increase bridge
tolls to $2.00. Legislation to further increase gasoline
prices by $.14 per gallon in the region seems unlikely to be
approved.
TCM #21 is a critical measure in determining the success of
the TCM program as a whole. The implementation of many
other measures is contingent on new revenues. The $.14 regional
gas tax, or some alternative source is projected to raise $420
million per year to meet the TCM funding shortfall.
We recommend that this measure be revised to reflect the
amount of new revenues now available for Bay Area projects
due to passage of the first three funding proposals. New
Federal funding is also available. The recent passage of the
Intermodal Surface Transportation Efficiency Act (ISTEA) has
provided new flexibility in use of future Federal gas tax
revenues, and this revenue source should also be included in
reviewing this measure. Given these laws, TCM #21 could
logically be recast as a commitment to apply new state and
federal monies to help implement unfunded measures.
A second concern is the potential for the "double-counting"
of the emissions reductions. More information on the
assumptions, data and methods used in the calculation of the
emission reductions need to be provided for full review of the
emission reductions claimed for these revenue measures.
The ARB staff recommends that this measure not be approved,
until it has been revised to reflect recent changes in
state and federal law.
PRICING 14EASURES
TCM 022 Implement Narket-Based Pricing Measures
TCM #22 is a package of pricing measures that are
intended to reduce motor vehicle emissions and traffic
congestion by increasing the cost of driving significantly. An
estimated $3.3 billion dollars per year would be raised if all
assumed pricing proposals were to be adopted. These user costs
could be used to fund improvements in transit and other TCMs to
meet concerns over the negative impacts on low income
travelers ("equity issue") or could be rebated to Bay area
residents to mitigate adverse economic impacts of pricing.
This is the most ambitious measure in the TCM plan,
and it is projected to have large impacts on
vehicle use and emissions when implemented. TCM #22 is
projected to achieve a 14.6% reduction in motor vehicle
trips and a 13.7% decrease in vehicle miles travelled
(VMT), as compared to baseline levels projected by traffic
models for the year 2000. The projected emission reductions
are: 20.6% (RHC), 15.5% (NOx), and 22.5% (CO).
The emission reductions assumptions in the plan are
based on the impact of the increased costs alone.
Additional benefits that would be realized if the new
revenues supported other parts of the TCM plan are not
counted. The plan estimates the following revenue would
be generated from the measure:
21a. Smog-Based Vehicle Registration Fees ... Would
raise $500 million
per year based on an average $125 fee per vehicle
21b. Regionwide Freeway and Arterial Congestion
Pricing ... Would raise
$354 million per year at $.10 per mile ($90 per
vehicle)
21c. Regionwide Non-Work Parking Charge of $0.60 per
Hour ... Would
raise $690 million year with $3.00 daily
cap in low density areas
21d. Gas Tax Increase of $2 per Gallon ... Would
raise $1.8 billion per
year ($450 per vehicle)
21e. Regionwide Worksite Parking Charges of $3.00 per
Day ... This
charge is part of TCM #2, so no added
revenue or emissions occur
Financial disincentives are powerful motivation to consider
mode changes, if reasonable alternatives are available.
The ARB staff believes that the degree of change in travel
habits due to pricing appears reasonable, but that the
likelihood of passing the full range of pricing programs grouped
in this measure is low.
The description of the MTC and District activities
during Phase 1 does not contain specific schedules,
budgets or milestones that can be monitored for
performance. Additional information needs to be provided
on any work programs to develop legislation, seek public
support and design project applications of the five pricing
strategies.
The plan lacks a detailed plan for developing support for
legislation and for the implementation of these measures,
including funding commitments, milestones, and phased
implementation. Although there is a great deal of support from
Bay Area business associations and environmental organizations
for these pricing measures, opposition is expected to any action
that would substantially increase the cost of owning and
operating an automobile, especially from low income groups. ARB
staff notes that this issue is addressed in the USER
INCENTIVES measures to some degree (TCM #13, TCM #15).
The plan states that the new fees would be implemented in
stages, such as TCM #21 as an initial objective.
Therefore, there appears to be some overlap in the emission
reduction estimates that needs to be addressed. The funding
shortfall that TCM #21 addresses could be met in this manner,
because TCM #22 would use the revenues to fund TCMs with the
greatest air quality benefits, and to provide a fund or programs
to reduce impacts on low income households (e.g. subsidized
transit passes (TCM #13), improved transit service (TCM #3, TCM
#5), and income tax credits).
>> Given the need for additional legal authority for most of
>> these measures, the ARB staff can not recommend that the
>>emission reductions associated with this measure, or its effect
>>on vehicular occupancy, be approved for inclusion if the plan.
>>Staff concurs that pursuit of this measure is very worthwhile,
>>and recommends that MTC and the district develop a work plan to
>>pursue the needed legal authority, and include a commitments in
>>the plan to execute this work plan.
INTERMITTENT 14EASURES
TCM #23 Ozone Excess aNo Drive Days' (Voluntary)
TCM #23 is a voluntary, intermittent program to encourage
drivers to eliminate unnecessary trips, use alternative
modes or chain trips on high ozone days. It is related to CM
#Gl, Citizen Postponement of Discretionary Activities and TCM
#17, Enhance Public Education.
The initial experience with this program in September
1991 suggested that it could have high potential on high
ozone days. If a 5% compliance rate could be achieved,
emission reductions are projected of 7 tons/day RHC and 11
tons/day NOx. No enforcement or monitoring methods are
available and no emission reduction credit is claimed in the TCM
plan.
ARB staff recommends that TCM #23 be accepted as an
uncredited measure in support of the Act, while
concurrently recommending that additional information be
provided to fully document the District assumptions and
experience in implementing this intermittent, voluntary
program.
Bay Area 1991 Clean Air Plan
TCM Strategies Reasonably Adequately Resources ARB Sta
Available Defined Commited Recommen
1- Expand Employer Assistance Programs OK OK OK A
2- Employer-Based Trip Reduction Rule OK OK OK A
3- Improve Areawide Transit Service
Phase 1 OK OK OK A
Phase 2 OK OK I CA
4- Expedite and Expand Regional Rail Service
Phase 1 OK OK OK A
Phase 2 OK OK I CA
5- Improve Access to Rail and Ferries
Phase 1 OK I I CA
Phase 2 OK I I CA
6- Improve Intercity Rail Service
Phase 1 OK OK OK A
Phase 2 OK OK I CA
7- Improve Ferry Service
Phase 1 OK OK OK A
Phase 2 OK OK I CA
8- Construct Carpool/Bus Lanes on Freeway
Phase 1 OK OK OK A
Phase 2 OK OK I CA
Legend: 'OK' Adequate 'A' Approve '(a)'= Need data
" I ' Incomplete "CA"= Conditional Approval '(b)'= Need data
"N/A'= Not Applicable "AC'= Accept Commitment "(c)'= Possible "d
Table 1 - Evaluation of Transportation Control Measures in t
Bay Area 1991 Clean Air Plan
TCM Strategies Reasonably Adequately Resources ARB S
Available Defined Commited Recommen
9- Improve Bicycle Access and Facilities
Phase 1 OK OK OK A
Phase 2 OK I I CA
10- Improve Youth Transportation
Phase 2 OK OK CA
11- lnstallFreewayTravelOperationsSystem
Phase 1 OK OK OK A
Phase 2 OK OK I CA
12- lmproveArterialTrafficManagement
Phase 1 OK OK OK A
Phase 2 OK OK I CA
13- Transit Use Incentives
Phase 1 OK OK OK A
Phase 2 OK I I CA
14- Vanpool Liability Insurance
Phase 1 OK OK OK A
Phase 2 OK I I CA
15- Provide Carpool Incentives
Phase 1 OK OK OK A
Phase 2 OK I I CA
Legend: 'OK' Adequate "A" Approve "(a)'= Need data
" I ' Incomplete 'CA"= Conditional Approval "(b)'= Need data
"N/A"= Not Applicable 'AC'= Accept Commitment "(c)'= Possible "d
Table 1 - Evaluation of Transportation Control Measures in t
Bay Area 1991 Clean Air Plan
TCM Strategies Reasonably Adequately Resources ARB St
Available Defined Commited Recommen
16- Indirect Source Control Program OK OK OK A
17- Conduct Public Education
Phase 1 OK OK OK A
Phase 2 OK OK CA
18- High Density Near Transit
Phase 2 OK OK CA
19- Air Quality Elements for General Plans
Phase 1 OK OK OK A
20- Conduct Demonstration Projects
Phase 1 OK OK OK A
Phase 2 OK OK I AC
21- Implement Revenue Measures
Phase 1 OK OK I AC
Phase 2 1 1 1 AC
22- Market-Based Measures
Phase 1 N/A I i AC
Phase 2 N/A I I AC
23- Ozone Excess 'No Drive Days' (voluntary) OK OK OK A
Legend: 'OK' Adequate "A" Approve '(a)'= Need data
" I " Incomplete"CA"= Conditional Approval"(b)"= Need data
'N/A"= Not Applicable "AC"= Accept Commitment "(c)'= Possible "
Table 1 - Evaluation of Transportation Control Measures in t
Bay Area 1991 Clean Air Plan
DESCRIPTION OF CODES USED IN STAFF RECOMMENDATIONS
REGARDING TRANSPORTATION CONTROL MEASURES
"A" = Full approval based on:
y Air District has full authority to adopt rule and levy fees to fund implementation of control mea
o Other agency has made funding or other commitments for full implementation of control meas
o Control measure is a continuation of existing support activities with identified funding source
"CA" = Conditional approval based on:
o Air District has an adopted control measure that can onlyt be implemented by another agency
o Credit for future emission reductions is conditional, based on commitment of resources by oth
"AC" = Acceptance of commitment based on:
y Legal authority to implement control measure does not currently exist
y Air District and other responsible agencies need to continue development of measure
o Emission reductions credit is deferred until resource commitments are made to implement m
--
Bill Michel
bm@eng.sun.com These views are my own, not Sun's.
Technical Details
Message-ID:
<kuacpgINNjle@exodus.Eng.Sun.COM>Path:
arc1-ca.pugleaf.net!sparky!uunet!sun-barr!news2me.ebay.sun.com!exodus.Eng.Sun.COM!bike2work.Eng.Sun.COM!bmShow Full Headers
Complete Article Headers
Path: arc1-ca.pugleaf.net!sparky!uunet!sun-barr!news2me.ebay.sun.com!exodus.Eng.Sun.COM!bike2work.Eng.Sun.COM!bm From: bm@bike2work.Eng.Sun.COM Newsgroups: ca.environment Subject: 91 Clean Air Plan Message-ID: <kuacpgINNjle@exodus.Eng.Sun.COM> Date: 10 Apr 92 06:18:24 GMT Reply-To: bm@bike2work.Eng.Sun.COM () Distribution: ba Organization: Sun Microsystems, Inc. Mt. View, Ca. Lines: 3138 NNTP-Posting-Host: bike2work