Austin/
Round
Rock
MSA
Emissions
Reduction
Strategies
Clean
Air
Action
Plan
Technical
Report
Prepared
by
The
Capital
Area
Planning
Council
(
CAPCO)
on
behalf
of
The
Austin­
Round
Rock
MSA
Clean
Air
Coalition
Austin,
Texas,
March
2004
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
i
Executive
Summary
This
report
supports
the
requirement
outlined
in
the
Austin­
Round
Rock
Metropolitan
Statistical
Area
(
A/
RR
MSA)
Early
Action
Compact
(
EAC),
December
18,
2002
Memorandum
of
Agreement
Section
II
A.
1
Milestones,
Local
Emission
Reduction
Strategies
Selected,
January
31,

2004
for
the
Clean
Air
Action
Plan.
It
summarizes
the
control
measures
that
will
be
in
effect
for
the
attainment
demonstration.

Federal
Regulations
currently
or
expected
to
be
in
place
are
covered
in
Section
Two.
Existing
or
proposed
State
Regulations
are
covered
in
Section
Three.
These
measures
are
described
in
a
summary
format
and
are
addressed
further
in
the
Maintenance
for
Growth
report.

Section
Four
covers
the
local
measures
that
either,
(
A)
require
state
regulations
or
actions
for
implementation
and
enforcement
or,
(
B)
are
recommended
for
local
regulation,
agreement,
or
voluntary
arrangement
and
implementation.
A
discussion
including
who
is
affected
by
the
measure,
what
the
control
strategy
and
implementation
plan
is,
the
methodology
used
to
calculate
the
emission
reduction,
and
cost
estimates
for
each
control
measure
is
included
for
the
Table
A
measures.
The
amount
of
NOx
reduced
by
the
requested
state
regulations
is
estimated
to
be
about
12.73
tpd
and
the
VOC
reduction
about
23.64
tpd.
The
Table
B
measures
are
summarized
and
will
have
to
be
developed
further
by
the
local
adopting
authority.
Jurisdictions
may
select
from
Table
B
the
measures
that
will
complete
their
"
fair
share"
obligation
to
emission
reductions.
Estimation
on
the
amount
of
emissions
reductions
from
the
locally
instituted
measures
will
depend
on
how
they
are
implemented
by
each
jurisdiction.

The
total
NOx
and
VOC
reductions
are
10.6%
and
14.8%
respectively
of
the
2007
anthropogenic
emissions
for
the
A/
RR
MSA.
The
largest
NOx
reductions
are
coming
from
the
Power
Plants
at
7.08
tpd.
The
largest
VOC
reductions
come
from
the
Degreasing
Controls
and
Stage
1
Vapor
Recovery
Requirement
Change
at
6.38
and
4.88
tpd
respectively.
The
Inspection
and
Maintenance
program
in
Travis
and
Williamson
County
is
the
next
greatest
reduction
category
providing
2.89tpd
NOx
reduction
and
3.84tpd
VOC
reduction.
Table
ES­
1
provides
the
summary
of
local
reduction
measures
explained
in
this
document.

Emission
Reduction
Measure
Pollutant
Bastrop
Caldwell
Hays
Travis
Williamson
Total
NOx
n/
a
n/
a
0.30
2.16
0.73
3.19
VOC
n/
a
n/
a
0.35
2.80
1.04
4.19
NOx
0.01
0.00
0.01
0.13
0.03
0.19
VOC
n/
a
n/
a
n/
a
n/
a
n/
a
0.00
NOx
0.02
0.01
0.05
0.34
0.11
0.54
VOC
0.03
0.01
0.05
0.39
0.12
0.60
NOx
n/
a
n/
a
n/
a
n/
a
n/
a
0.00
VOC
0.16
0.19
0.63
2.83
1.08
4.88
NOx
n/
a
n/
a
n/
a
n/
a
n/
a
0.00
VOC
0.09
0.05
0.19
1.74
0.52
2.60
NOx
n/
a
n/
a
n/
a
n/
a
n/
a
0.00
VOC
0.03
0.01
0.03
0.66
0.18
0.91
NOx
n/
a
n/
a
n/
a
n/
a
n/
a
0.00
VOC
0.07
0.04
0.26
5.47
0.54
6.38
NOx
n/
a
n/
a
n/
a
n/
a
n/
a
0.00
VOC
0.00
0.00
0.00
0.03
0.01
0.05
NOx
n/
a
n/
a
n/
a
n/
a
n/
a
0.00
VOC
0.07
0.05
0.06
0.61
0.24
1.03
NOx
n/
a
n/
a
n/
a
n/
a
n/
a
0.00
VOC
0.11
0.05
0.17
1.74
0.81
2.87
NOx
0.10
0.04
0.19
1.19
0.48
2.00
VOC
n/
a
n/
a
n/
a
n/
a
n/
a
0.00
NOx
2.94
0.00
0.00
4.14
0.00
7.08
VOC
n/
a
n/
a
n/
a
n/
a
n/
a
0.00
NOx
0.03
0.02
0.07
0.45
0.15
0.72
VOC
0.04
0.02
0.07
0.54
0.17
0.83
NOx
3.11
0.07
0.61
8.43
1.50
13.72
VOC
0.59
0.42
1.81
16.80
4.72
24.34
NOx
12.52
5.88
17.42
69.70
22.85
128.38
VOC
8.58
17.23
13.87
93.87
31.17
164.72
NOx
24.8%
1.2%
3.5%
12.1%
6.6%
10.7%
VOC
6.9%
2.4%
13.1%
17.9%
15.1%
14.8%
*
Note
that
total
I/
M
reductions
without
Hays
County
are
estimated
to
be
2.89tpd
of
NOx
and
3.84tpd
of
VOC
Percent
Reduction
[%]
COUNTY
TERMS
Power
Plant
Reductions
GRAND
TOTAL
(
REDUCTIONS)
[
TPD]
Total
Anthropogenic
Emissions
[
TPD]
Cutback
Asphalt
Low
Reid
Vapor
Pressure
Gas
TERP
Low
Emission
Gas
Cans
Architectural/
Industrial
Coatings
Controls
Degreasing
Controls
Autobody
Refinishing
Controls
*
Inspection
and
Maintenance
(
I&
M)

Idling
Restrictions
on
Heavy
Diesel
Commute
Emission
Reduction
Program
Stage
I
Vapor
Recovery
Requirement
Change
Table
1­
1.
A/
RR
MSA
Local
Measures
Emission
Reductions
Summary
The
emission
distributions
over
the
counties
in
the
MSA
are
depicted
in
Figure
ES­
1
for
VOC
reductions
and
Figure
ES­
2
for
NOx
reductions.
Travis
County
will
be
providing
most
of
the
reductions
in
both
VOC
and
NOx
at
70%
and
61%
respectively.
Williamson
County
will
provide
a
19%
reduction
in
VOC
and
Bastrop
County
a
23%
reduction
in
NOx.
Emission
Reduction
Distribution
VOC
Travis
70%
Williamson
19%
Bastrop
2%
Caldwell
2%

Hays
7%

Total
VOC
Reduced:
25.6tpd
Figure
1­
1.
A/
RR
MSA
VOC
Emission
Reduction
Distribution.
This
assumes
I/
M
or
equivalent
reduction
program
in
Hays
County
Emission
Reduction
Distribution
NOx
Bastrop
23%

Caldwell
1%

Hays
4%

Travis
61%
Williamson
11%

Total
NOx
Reduced:
13.8tpd
Figure
1­
2.
A/
RR
MSA
NOx
Emission
Reduction
Distribution.
This
assumes
I/
M
or
equivalent
reduction
program
in
Hays
County
TABLE
OF
CONTENTS
Executive
summary..............................................................................................................
i
TABLE
OF
CONTENTS
...................................................................................................
iv
1
Introduction......................................................................................................................
1­
1
2
Federal
Reduction
Strategies
............................................................................................
2­
1
Non­
Road
Measures.............................................................................................................
2­
1
2.1
REFORMULATED
SURFACE
COATINGS...........................................................
2­
3
2.2
AUTO
BODY
REFINSHING
..................................................................................
2­
4
2.3
TIER
2
MOTOR
VEHICLE
EMISSION
REGULATIONS
......................................
2­
5
2.4
NATIONAL
LOW
EMISSION
VEHICLE
STANDARD.........................................
2­
6
2.5
HEAVY­
DUTY
DIESEL
ENGINE
RULE...............................................................
2­
7
2.6
STANDARDS
FOR
SMALL
SPARK­
IGNITION
HANDHELD
ENGINES............
2­
8
2.7
COMPRESSION
IGNITION
STANDARDS
FOR
VEHICLES
AND
EQUIPMENT
2­
8
2.8
EMISSIONS
STANDARDS
FOR
LARGE
SPARK
IGNITION
ENGINES
.............
2­
9
2.9
EMISSIONS
STANDARDS
FOR
SPARK
IGNITION
MARINE
ENGINES...........
2­
9
2.10
EMISSIONS
CONTROLS
FOR
LOCOMOTIVES
................................................
2­
10
2.11
ALCOA
CONSENT
DECREE...............................................................................
2­
12
3
State
and
Regional
Reduction
Strategies...........................................................................
3­
1
Sec.
..................................................................................................................................
3­
1
Category
..........................................................................................................................
3­
1
Reductions
in
2007
(
tpd)
..................................................................................................
3­
1
Area
Source:
....................................................................................................................
3­
1
On­
road
Source:
...............................................................................................................
3­
1
Non­
road
Source:
.............................................................................................................
3­
1
Point
Source:....................................................................................................................
3­
1
3.1
DEGREASING
UNITS............................................................................................
3­
1
3.2
GRANDFATHERED
PIPELINES
...........................................................................
3­
2
3.3
STAGE
1
VAPOR
RECOVERY..............................................................................
3­
2
3.4
STATE
LOW
EMISSION
DIESEL
PROGRAM......................................................
3­
3
3.5
ELECTRIC
GENERATING
UTILITY
NOX
REDUCTIONS..................................
3­
4
3.6
VOLUNTARY
EMISSIONS
REDUCTION
PERMIT
(
VERP)
................................
3­
4
3.7
HB
2912
Grandfathered
Requirements
.....................................................................
3­
5
3.8
CEMENT
KILN
NOx
LIMITS.................................................................................
3­
5
4
Local
Strategies................................................................................................................
4­
1
4.1
LOCAL
STRATEGIES
INTRODUCTION..............................................................
4­
1
4.2
TABLE
A
EMISSION
REDUCTION
MEASURES.................................................
4­
1
4.2.1
Inspection
and
Maintenance
(
A1)......................................................................
4­
2
4.2.2
Idling
Restrictions
on
Heavy­
Duty
Diesel
Engines
(
A2)..................................
4­
11
4.2.3
Commute
Emission
Reduction
Program
(
A3)..................................................
4­
14
4.2.4
Low
Emission
Gas
Cans
(
A4)
.........................................................................
4­
18
4.2.5
Stage
1
Vapor
Recovery
Requirement
Change
(
A5)........................................
4­
23
4.2.6
Degreasing
Controls
(
A6)
...............................................................................
4­
27
4.2.7
Autobody
Refinishing
Controls
(
A7)
..............................................................
4­
29
4.2.8
Cut
Back
Asphalt
(
A8)....................................................................................
4­
35
4.2.9
Low
Reid
Vapor
Gas
(
A9)
..............................................................................
4­
36
4.2.10
BACT
and
Offsets
for
New
or
Modified
Point
Sources
(
A10).........................
4­
40
4.2.11
Petroleum
Dry
Cleaning
(
A11)
.......................................................................
4­
40
4.2.12
Texas
Emission
Reduction
Program
(
TERP)
(
A12).........................................
4­
42
4.2.13
Power
Plant
Reductions
(
A13)
........................................................................
4­
47
4.3
TRANSPORTATION
EMISSION
REDUCTION
MEASURES
(
TERMS)
............
4­
50
4.4
TABLE
B
EMISSION
REDUCTION
MEASURES
...............................................
4­
52
4.4.1
Texas
Emission
Reduction
Program
(
TERP)...................................................
4­
57
4.4.2
Texas
Low
Emission
Diesel
(
TxLED)
for
Fleets
.............................................
4­
57
4.4.3
Transportation
Emission
Reduction
Measures
(
TERMs)
.................................
4­
57
4.4.4
Access
Management
.......................................................................................
4­
58
4.4.5
Alternative
Commute
Infrastructure
Requirements..........................................
4­
58
4.4.6
Drive­
Through
Facilities
on
Ozone
Action
Days.............................................
4­
58
4.4.7
Expedited
permitting
for
mixed
use,
transit
oriented
or
in­
fill
development.....
4­
59
4.4.8
Use
of
electric
or
alternative
fuels
for
airport
GSE..........................................
4­
59
4.4.9
ABIA
Airside
incentives
for
GSE
use
reduction..............................................
4­
59
4.4.10
Integrate
alternative
fuels
into
City's
aviation
fleet
..........................................
4­
60
4.4.11
Operate
alternative
fueled
surface
parking
lot
shuttle
buses.............................
4­
60
4.4.12
Use
existing
ABIA
alternative
fuel
infrastructure
for
off­
site
parking
shuttle
buses
4­
60
4.4.13
Low
VOC
Striping
Material............................................................................
4­
60
4.4.14
Landfill
Controls.............................................................................................
4­
61
4.4.15
Open
Burning
Restrictions
..............................................................................
4­
61
4.4.16
Tree
Planting
..................................................................................................
4­
62
4.4.17
Extend
energy
efficiency
requirements
beyond
SB5
and
SB7..........................
4­
62
4.4.18
Shift
the
electric
load
profile
...........................................................................
4­
62
4.4.19
Environmental
dispatch
of
power
plants..........................................................
4­
62
4.4.20
Clean
Fuel
Incentives......................................................................................
4­
63
4.4.21
Low
Emission
Vehicles
..................................................................................
4­
63
4.4.22
Adopt­
a­
School­
Bus
Program.........................................................................
4­
63
4.4.23
Police
Department
Ticketing...........................................................................
4­
63
4.4.24
EPA
Smart
Way
Transport
Program
...............................................................
4­
64
4.4.25
Business
Evaluation
of
Fleet
Usage,
Including
Operations
and
Right
Sizing
...
4­
64
4.4.26
Parking
Incentives
for
Alt
Fuel
or
Low
Emission
vehicles
..............................
4­
64
4.4.27
Commute
Solutions
Programs.........................................................................
4­
65
4.4.28
Direct
Deposit.................................................................................................
4­
65
4.4.29
e­
Government
and/
or
Available
Locations
......................................................
4­
65
4.4.30
Voluntary
use
of
APUs
for
locomotives
operating
in
Central
Texas
................
4­
65
4.4.31
Fueling
of
Vehicles
in
Evening
.......................................................................
4­
65
4.4.32
Urban
Heat
Island/
Cool
Cities
Program..........................................................
4­
66
4.4.33
Resource
Conservation
...................................................................................
4­
66
4.4.34
Increase
investments
by
Central
Texas
electric
utility
providers
in
energy
demand
management
programs
...................................................................................................
4­
66
4.4.35
Alter
production
processes
and
fuel
choices
....................................................
4­
67
4.4.36
Contract
provisions
addressing
construction
related
emissions
on
high
ozone
days
4­
67
4.4.37
Ensure
emission
reduction
in
SEPs,
BEPS
and
similar
agreements..................
4­
68
4.4.38
Ozone
Action
Day
Education
Program............................................................
4­
68
4.4.39
Ozone
Action
Day
Notification
Program.........................................................
4­
68
4.4.40
Ozone
Action
Day
Response
Program
............................................................
4­
68
4.4.41
Alternative
Fuel
Vehicles................................................................................
4­
68
4.4.42
Right
Sizing....................................................................................................
4­
69
4.4.43
5­
minute
Limit
on
Diesel
Idling
......................................................................
4­
69
4.4.44
Cleaner
Diesel
................................................................................................
4­
70
4.4.45
Vehicle
Maintenance
......................................................................................
4­
70
4.4.46
Vapor
Recovery
on
Pumps..............................................................................
4­
70
4.4.47
Low
VOC
Asphalt
..........................................................................................
4­
71
4.4.48
Low
Emission
Gas
Cans
.................................................................................
4­
71
4.4.49
Transit­
Oriented
Development
........................................................................
4­
71
4.4.50
Shaded
Parking...............................................................................................
4­
72
4.4.51
Landscaping
voluntary
start
at
noon
on
high
ozone
days
(
education
program).
4­
72
LIST
OF
FIGURES
Figure
1.
A/
RR
MSA
VOC
Emission
Reduction
Distribution
...................................................
iii
Figure
2.
A/
RR
MSA
NOx
Emission
Reduction
Distribution
.....................................................
iii
LIST
OF
TABLES
Table
1­
1.
A/
RR
MSA
Local
Measures
Emission
Reductions
Summary
....................................
ii
Table
2­
1
EPA­
ISSUED
RULES
Estimated
NOx
Reductions
........................................................
2­
1
Table
2­
2.
Federal
Non­
road
NOx
reductions...........................................................................
2­
2
Table
2­
3.
Federal
Non­
road
VOC
reductions
..........................................................................
2­
3
Table
2­
4.
Architectural
Coatings
VOC
Emission
Reduction
...................................................
2­
4
Table
2­
5.
Auto
Body
Refinishing
VOC
Emission
Reduction
..................................................
2­
4
Table
2­
6.
Federal
Tier
2
NOx
Reduction
................................................................................
2­
5
Table
2­
7.
Federal
Tier
2
VOC
Reduction................................................................................
2­
5
Table
2­
8.
Federal
NLEV
NOx
Reduction................................................................................
2­
6
Table
2­
9.
Federal
NLEV
VOC
Reduction...............................................................................
2­
7
Table
2­
10.
Federal
H­
D
Diesel
NOx
Reductions.....................................................................
2­
7
Table
2­
11.
Federal
H­
D
Diesel
VOC
Reductions
....................................................................
2­
8
Table
2­
12.
Locomotive
Rule
NOx
Emission
Reduction
........................................................
2­
11
Table
2­
13.
Annual
NOx
Reductions
from
Anticipated
Locomotive
Standards.......................
2­
11
Table
3­
1.
Summary
of
TCEQ­
Issued
Rules
for
Reduction
Strategies
......................................
3­
1
Table
3­
2.
NOx
reductions
from
degreasing
rule
......................................................................
3­
2
Table
3­
3.
Stage
1
VOC
emission
reduction.............................................................................
3­
3
Table
3­
4.
Utility
(
EGU)
NOx
Reductions
..............................................................................
3­
4
Table
3­
5.
Cement
Kiln
NOx
Reduction...................................................................................
3­
6
Table
4­
1.
I&
M
NOx
Emission
Reduction
..............................................................................
4­
7
Table
4­
2.
I&
M
VOC
Emission
Reduction...............................................................................
4­
7
Table
4­
3.
Run
and
Idle
Time
Derivation
*
From
TTI
..........................................................
4­
13
Table
4­
4.
Estimation
of
Heavy­
Duty
Fleet
Size
^
From
TTI
.................................................
4­
13
Table
4­
5.
Idling
Restrictions
NOx
Emission
Reduction
........................................................
4­
14
Table
4­
6.
Commute
Program
NOx
Emission
Reduction........................................................
4­
17
Table
4­
7.
Commute
Program
VOC
Emission
Reduction.......................................................
4­
17
Table
4­
8.
2007
State
Emission
Reductions............................................................................
4­
21
Table
4­
9.
Low
Emission
Gas
Can
VOC
emission
reduction..................................................
4­
22
Table
4­
10.
Gasoline
station
throughput.................................................................................
4­
24
Table
4­
11.
Stage
I
Rule
penetration
for
gas
stations
.............................................................
4­
24
Table
4­
12.
Expected
emission
reduction
from
Stage
I
Vapor
recovery
control
......................
4­
24
Table
4­
13.
Stage
I
controls
VOC
reductions
by
County
........................................................
4­
25
Table
4­
14.
Number
of
Retail
Gasoline
Tanks
and
Stage
I
Units
by
County
(
2003)................
4­
25
Table
4­
15.
Number
of
Tanks
Without
Stage
I
Capability,
by
Throughput
.............................
4­
26
Table
4­
16.
Annual
Costs
by
Throughput...............................................................................
4­
26
Table
4­
17.
Cost­
Effectiveness
by
Rule
Cut­
Off
Level
($/
Ton
VOC).....................................
4­
26
Table
4­
18.
Cold
Cleaning
Degreasing
VOC
Emission
Reduction.........................................
4­
28
Table
4­
19.
Comparison
of
VOC
Limits
of
the
Federal
Rule
and
SCAQMD.........................
4­
30
Table
4­
20.
Comparison
of
Characteristics
of
Paint
Spray
Equipment
for
Automotive
Refinishers
.....................................................................................................................
4­
33
Table
4­
21.
Autobody
Refinishing
VOC
Emission
Reduction
...............................................
4­
34
Table
4­
22.
Comparison
of
Control
Options,
Source:
U.
S.
EPA,
2002.
..................................
4­
34
Table
4­
23.
Asphalt
Paving
VOC
Emission
Reduction...........................................................
4­
36
Table
4­
24.
Low
Reid
Vapor
Pressure
VOC
Emission
Reduction...........................................
4­
38
Table
4­
25.
RVP
Cost
Calculations........................................................................................
4­
39
Table
4­
26.
TERP
NOx
emission
reduction............................................................................
4­
46
Table
4­
27.
Point
Source
NOx
emission
reduction
.................................................................
4­
49
Table
4­
28.
Point
Source
NOx
emission
reduction
by
County................................................
4­
49
Table
4­
29.
TERM
Projects
........................................................................................................
4­
51
Table
4­
30.
TERM
VOC
reduction
........................................................................................
4­
51
Table
4­
31.
TERM
NOx
reduction.........................................................................................
4­
52
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
1­
1
1
Introduction
The
Texas
Commission
on
Environmental
Quality
(
TCEQ)
and
the
Environmental
Protection
Agency
(
EPA)
are
working
with
communities
to
achieve
clean
air
as
soon
as
possible
by
entering
into
Early
Action
Compacts
(
EAC)
to
reduce
ground­
level
ozone
pollution.
The
EAC
provides
the
mechanism
for
local
emission
reduction
measures
to
be
considered
and
recommended
for
inclusion
in
the
State
Implementation
Plan.
This
document
provides
the
description
for
each
of
the
local
control
measures
under
consideration.
This
final
selection
of
measures
is
based
on
review
and
approved
by
local
stakeholders
and
officials
and
on
technical
demonstration
showing
attainment
of
the
8­

hour
ozone
standard
by
December
31,
2007.

Various
emission
reduction
techniques
can
effectively
reduce
ozone
precursors.

Emission
reduction
methods
employed
nationally
(
e.
g.,
automotive
emission
reductions),

statewide
and
regionally
(
emission
reductions
from
EGUs)
benefit
the
Austin
area,
but
more
reductions
are
needed
to
ensure
clean
air
for
the
region.
Ozone
precursors
include
Nitrogen
Oxides
(
NOx)
and
Volatile
Organic
Compounds
(
VOC)
from
vehicles,
electric
utilities
and
other
industrial,
commercial
and
residential
sources
that
burn
fuels.

Modeling
was
performed
to
indicate
the
amount
of
reductions
needed
in
the
area.
The
model
shows
that
up
to
80%
of
ozone
monitored
locally
has
been
transported
from
outside
the
area.
An
important
characteristic
of
NOx
emissions
is
that
they
can
be
transported
long
distances
and
cause
problems
far
from
the
original
emissions
source.

Emission
reductions
in
other
nonattainment
areas
will
not
only
beneficially
impact
the
Austin
area
but
will
also
provide
possible
solutions
for
local
emissions
sources.
TCEQ
is
encouraged
to
evaluate
new
major
sources
for
impact
on
ozone
background
levels
and
extend
local
strategies
to
a
larger,
regional
area.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
1­
2
The
Austin­
Round
Rock
MSA
includes
the
following
counties,
Bastrop
(
population
63
thousand),
Caldwell
(
35
thousand),
Hays
(
109
thousand),
Travis
(
851
thousand),
and
Williamson
(
290
thousand).
The
development
of
the
emission
reduction
strategies
for
this
area
has
proved
to
be
an
extremely
challenging
effort,
due
to
the
impact
of
emissions
transport
from
outside
of
the
area,
the
small
number
of
local
point
sources,
and
the
monitored
ozone
varying
so
closely
above
and
below
the
standard.
We
developed
a
technical
advisory
committee
and
created
working
groups
of
Area
Source,
Point
Source,

On­
Road,
and
Non­
Road
categories.
We
worked
with
stakeholders
to
consider
control
measures
that
can
reasonably
be
implemented
in
each
area.
Other
factors
that
were
considered
were
the
geographic
area
to
which
the
control
measure
could
be
applied,
the
implementation
dates,
and
resource
constraints
of
the
area.

Emission
reductions
were
calculated
by
applying,
where
applicable,
rule
penetration
(
RP),
rule
effectiveness
and
control
efficiency
factors.
Rule
penetration
represents
the
percentage
of
the
source
category
under
consideration
that
is
affected
by
a
certain
rule.

Rule
effectiveness
(
RE)
is
a
measure
of
the
expected
degree
of
actual
compliance
with
the
controls
specified
by
a
rule.
Control
efficiency
represents
expected
emission
reductions
due
to
process
change
or
control
implementation
from
the
source
that
complies
with
a
specific
rule.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
2­
1
2
Federal
Reduction
Strategies
The
Clean
Air
Action
Plan
(
CAAP)
projects
emission
reductions
from
the
following
federal
initiatives.
A
discussion
on
these
rules
is
presented
in
the
following
sections.

Table
2­
1
EPA­
ISSUED
RULES
Estimated
NOx
Reductions
Sec.
Category
Reductions
in
2007
(
tpd)
Area
Source
measures:
VOC
NOx
2.1
2.2
 
Architectural
and
Industrial
Maintenance
Coatings
 
Auto
Body
Refinishing
1.44
0.52
n/
a
n/
a
On­
Road
measures:
2.3
2.4
2.5
 
Tier
2
Vehicle
Emission
Standards
 
National
Low
Emission
Vehicle
Program
 
Heavy­
Duty
Diesel
Engine
Rule
5.71
1.70
0.34
16.79
3.01
11.78
Non­
Road
measures:
2.7
2.8
2.9
210
2.11
 
Small
Spark­
Ignition
Handheld
Engines
 
Emissions
from
Compression­
Ignition
Engines
 
Emissions
from
Nonroad
Large
Spark­
Ignition
Engines,
and
Recreational
Engines
 
Recreational
Marine
Standards
 
Locomotives
9.27
n/
a
3.48
2.28
Point
Source
Measures:
2.12
 
ALCOA
Consent
Decree
n/
a
54
Total
18.98
91.34
Non­
Road
Measures
"
Nonroad"
is
a
term
that
covers
a
diverse
collection
of
engines,
equipment,
vehicles,
and
vessels.
Sometimes
referred
to
as
"
off­
road"
or
"
off
highway,"
the
nonroad
category
includes
outdoor
power
equipment,
recreational
vehicles,
farm
and
construction
machinery,
lawn
and
garden
equipment,
marine
vessels,
locomotives,
and
many
other
applications.

The
NONROAD
model
was
run
to
evaluate
the
reductions
of
federal
regulations
relating
to
certain
non­
road
equipment
operating
in
the
A/
RR
MSA.
The
method
was
to
(
1)
run
the
State
of
Texas
for
a
typical
ozone
season
weekday
in
2007
and
then
(
2)
turn
off
all
federal
regulations
being
implemented
after
the
year
1999.
This
provided
a
percentage
of
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
2­
2
reductions
for
hydrocarbons
(
VOC)
and
oxides
of
nitrogen
(
NOx)
which
was
then
applied
to
the
local
inventory
as
shown
in
Table
2­
2
and
Table
2­
3
respectively.

Due
to
the
nature
of
the
NONROAD
model,
it
was
not
directly
possible
to
estimate
the
impact
of
any
specific
EPA
regulation,
such
as
"
Phase
II
Small
Handheld
Equipment."

This
is
because
the
model
uses
engine
technology
families
as
opposed
to
specific
rules
(
e.
g.,
M2,
TIER2
GANO4)
and
because
with
the
more
recent
regulations,
manufacturers
are
allowed
to
introduce
cleaner
engines
on
a
schedule
depending
on
horsepower,

milestone
year,
and
corporate
averaging
credits.
Therefore,
the
emissions
reductions
in
sections
2.6
through
2.9
are
shown
as
a
total
of
9.27
tpd
VOC
and
3.48
tpd
NOx
in
Table
2­
1.
However,
it
is
easy
to
grasp
the
general
trends
in
categories
such
as
residential
lawn
and
garden
equipment
or
recreational
marine
engines,
which
are
dominated
by
singlescope
rules.
1
Equipment
Base
2007
NOx
(
tpd)
Federally
Controlled
NOx
(
tpd)
Net
Reduction
NOx
(
tpd)
Reduction
Agricultural
2.37
2.20
0.17
7.2%
Commercial
1.66
1.49
0.17
10.0%
Construction
12.73
10.60
2.13
16.7%
Industrial
5.40
5.00
0.40
7.4%
Commercial
Lawn
&
Garden
2.78
2.25
0.53
19.1%
Residential
Lawn
&
Garden
0.28
0.21
0.07
25.7%
Recreational
Vehicles
0.08
0.07
0.01
12.5%
Total
25.33
21.85
3.48
13.7%

Table
2­
2.
Federal
Non­
road
NOx
reductions
1
ERG
memo
Percentage
Reductions
Using
the
NONROAD
Model,
February
27,
2004
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
2­
3
Equipment
Base
2007
NOx
(
tpd)
Federally
Controlled
NOx
(
tpd)
Net
Reduction
NOx
(
tpd)
Reduction
Agricultural
0.30
0.28
0.02
7.6%
Commercial
2.41
1.61
0.80
33.2%
Construction
2.10
1.52
0.58
27.8%
Industrial
1.41
1.20
0.21
14.9%
Commercial
Lawn
&
Garden
13.96
7.46
6.50
46.5%
Residential
Lawn
&
Garden
2.77
1.76
1.01
36.4%
Pleasure
Craft
0.52
0.41
0.11
21.6%
Recreational
Vehicles
2.79
2.75
0.04
1.3%
Total
26.26
16.99
9.27
35.3%
Table
2­
3.
Federal
Non­
road
VOC
reductions
2.1
REFORMULATED
SURFACE
COATINGS
Rule
40
CFR
59,
National
Volatile
Organic
Compound
Emission
Standards
for
Architectural
Coatings,
restricts
the
VOC
content
of
architectural,
industrial
maintenance,
special
industrial,
and
highway
markings
surface
coatings.
This
measure
affects
makers
of
architectural,
industrial
maintenance,
special
industrial,
and
highway
markings
surface
coatings.
Compliance
is
required
by
September
13,
1999,
or
March
10,

2000.
According
to
the
most
recent
EPA
guidance
the
final
rule
is
expected
to
yield
a
20%
reduction
in
VOC
emissions
from
Architectural
and
Industrial
Maintenance
(
AIM)

coating
sources.
This
estimate
includes
a
control
efficiency
of
20%,
rule
penetration
and
effectiveness
of
100%.

Reductions
for
AIM
coatings
are
achievable
through
product
reformulations,
product
substitution,
and
consumer
education.
Reformulations
include
altering
the
components
of
the
coating
to
achieve
a
lower
VOC
content,
replacing
VOC
solvents
with
water
or
alternative
non­
VOC
solvents,
and
increasing
the
solids
content
of
the
coating
thereby
reducing
the
volume
applied.
Product
substitution
is
accomplished
by
replacing
higher­

VOC
coatings
with
currently
available
lower­
VOC
coatings.
Consumer
education
will
provide
information
on
the
relative
cost
of
lower­
VOC
coatings
and
encourage
careful,

efficient
use
of
such
products.
Specific
VOC
content
limits
included
in
the
regulatory
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
2­
4
negotiations
are
not
yet
published.
Table
2­
4
provides
an
estimate
on
the
reductions
this
rule
will
provide
the
A­
RR
MSA.

Table
2­
4.
Architectural
Coatings
VOC
Emission
Reduction
2.2
AUTO
BODY
REFINSHING
In
40
CFR
Part
59,
Subpart
B,
National
Volatile
Organic
Compound
Emission
Standards
for
Automobile
Refinish
Coatings,
the
EPA
set
forth
policy
on
the
creditable
reductions
to
be
assumed
from
the
national
rule
for
auto
body
refinishing.
The
provisions
of
the
rule
apply
to
automobile
refinish
coatings
and
coating
components
that
are
manufactured
on
or
after
January
11,
1999
for
sale
or
distribution
in
the
United
States.
These
reductions,

presented
in
Table
2­
5,
represent
a
37%
reduction
from
current
emissions
with
an
assumption
of
100%
rule
efficiency
(
presuming
the
coating
application
instructions
were
being
followed)
and
penetration.

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
Reduction
(
tpd)
Percent
Reduction
(%)

AREA
SOURCES:

Autobody
Shops
SCCs:
2401070000,

2401001025
&

2401005000
National
Volatile
Organic
Compound
Emission
Standards
for
Auto
Body
Refinishing
Austin­
Round
Rock
MSA
(
5
Counties)
0.90
0.57
0.33
37.0%

Table
2­
5.
Auto
Body
Refinishing
VOC
Emission
Reduction
Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
Reduction
(
tpd)
Percent
Reduction
(%)

AREA
SOURCES:

Architectural
Coatings
SCC:
2401008000,

2401001000,

2401001001,

2401001005,

2401001006,

2401001010,

2401001011,

2401001015,

2401001020
National
Volatile
Organic
Compound
Emission
Standards
for
Architectural
Coatings
Austin­
Round
Rock
MSA
(
5
Counties)
7.18
5.74
1.44
20.0%
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
2­
5
2.3
TIER
2
MOTOR
VEHICLE
EMISSION
REGULATIONS
The
U.
S.
EPA
promulgated
a
rule
on
February
10,
2000
(
40
CFR
Parts
80,
85
and
86,
Air
Pollution;
Tier
2
Motor
Vehicle
Emission
Standards
and
Gasoline
Sulphur
Control
Requirements;
Diesel
Fuel
Quality
Controls)
requiring
more
stringent
tailpipe
emissions
standards
for
all
passenger
vehicles,
including
sport
utility
vehicles
(
SUVs),
minivans,

vans
and
pick­
up
trucks.
These
regulations
also
require
lower
levels
of
sulfur
in
gasoline,

which
will
ensure
the
effectiveness
of
low
emission­
control
technologies
in
vehicles
and
reduce
harmful
air
pollution.

The
new
tailpipe
and
sulfur
standards
require
passenger
vehicles
to
be
77
to
95
percent
cleaner
than
those
built
before
the
rule
was
promulgated
and
will
reduce
the
sulfur
content
of
gasoline
by
up
to
90
percent.
The
new
tailpipe
standards
are
set
at
an
average
standard
of
0.07
grams
per
mile
for
NOx
for
all
classes
of
passenger
vehicles
beginning
in
2004.
This
includes
all
light­
duty
trucks,
as
well
as
the
largest
SUVs.
Vehicles
weighing
less
than
6000
pounds
will
be
phased­
in
to
this
standard
between
2004
and
2007.

These
reductions
are
presented
in
Table
2­
6
for
NOx
and
Table
2­
7
for
VOC.
They
are
estimated
to
be
a
35.7%
reduction
or
a
net
16.79
tpd
of
NOx
and
15.3%
or
a
net
5.71
tpd
for
VOC
in
the
A/
RR
MSA.

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
NOx
Emissions
(
tpd)
2007
Controlled
NOx
Emissions
(
tpd)
Net
Reduction
(
tpd)
Percent
Reduction
(%)

LDGVs
+
LDGT
NLEV
II
(
Tier
2)
Austin­
Round
Rock
MSA
(
5
Counties)
47.01
30.23
16.79
35.7%

Table
2­
6.
Federal
Tier
2
NOx
Reduction
Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
Reduction
(
tpd)
Percent
Reduction
(%)

LDGVs
+
LDGT
NLEV
II
(
Tier
2)
Austin­
Round
Rock
MSA
(
5
Counties)
37.23
31.52
5.71
15.3%

Table
2­
7.
Federal
Tier
2
VOC
Reduction
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
2­
6
The
significant
environmental
benefits
of
this
program
would
come
at
an
approximate
cost
to
consumers
of
less
than
$
100
for
cars
and
$
200
for
light
duty
trucks.
EPA
estimates
the
program
will
cost
industry
about
$
5.3
billion.
In
contrast,
health
and
environmental
benefits
are
estimated
to
be
$
25.2
billion.

2.4
NATIONAL
LOW
EMISSION
VEHICLE
STANDARD
Under
the
National
Low
Emission
Vehicle
(
NLEV)
program
(
40
CFR
Parts
9,
85,
and
86,

Control
of
Air
Pollution
From
New
Motor
Vehicles
and
New
Motor
Vehicle
Engines:

State
Commitments
to
National
Low
Emission
Vehicle
Program),
auto
manufacturers
have
agreed
to
comply
with
tailpipe
standards
that
are
more
stringent
than
EPA
can
mandate
prior
to
model
year
(
MY)
2004.
These
federally
implemented
programs
affect
light­
duty
vehicles
and
trucks.

Once
manufacturers
committed
to
the
program,
the
standards
became
enforceable
in
the
same
manner
that
other
federal
motor
vehicle
emissions
control
requirements
are
enforceable.
The
program
went
into
effect
throughout
the
Ozone
Transport
Region
(
OTR)
in
model
year
1999
and
will
be
nationwide
in
model
year
2001.
The
National
Low
Emission
Vehicle
Program
requires
more
stringent
exhaust
emission
standards
than
the
Federal
Motor
Vehicle
Control
Program
Tier
I
(
or
Phase
I)
exhaust
standards.

These
reductions
are
presented
in
Table
2­
8
for
NOx
and
Table
2­
9
for
VOC.
They
are
estimated
to
be
a
9.1%
reduction
or
a
net
3.01
tpd
of
NOx
and
5.1%
or
a
net
1.7
tpd
for
VOC
in
the
A/
RR
MSA.

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
NOx
Emissions
(
tpd)
2007
Controlled
NOx
Emissions
(
tpd)
Net
Reduction
(
tpd)
Percent
Reduction
(%)

LDGVs
+
LDGT
NLEV
I
Austin­
Round
Rock
MSA
(
5
Counties)
33.24
30.23
3.01
9.1%

Table
2­
8.
Federal
NLEV
NOx
Reduction
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
2­
7
Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
Reduction
(
tpd)
Percent
Reduction
(%)

LDGVs
+
LDGT
NLEV
I
Austin­
Round
Rock
MSA
(
5
Counties)
33.23
31.52
1.70
5.1%

Table
2­
9.
Federal
NLEV
VOC
Reduction
2.5
HEAVY­
DUTY
DIESEL
ENGINE
RULE
Under
the
Heavy­
Duty
Diesel
Engine
Rule
(
40
CFR
Parts
85
and
86,
Emissions
Control,

Air
Pollution
From
2004
and
Later
Model
Year
Heavy­
Duty
Highway
Engines
and
Vehicles;
Light­
Duty
On­
Board
Diagnostics
Requirements,
Revision;
Final
Rule
Friday,

October
6,
2000),
truck
manufacturers
must
comply
with
tailpipe
standards
that
are
more
stringent
by
2004
for
all
diesel
vehicles
over
8,500
pounds.
These
federally
implemented
programs
affect
heavy­
duty
diesel
engines
used
in
trucks.
The
standards
are
enforceable
in
the
same
manner
that
other
federal
motor
vehicle
emissions
control
requirements
are
enforceable.
The
new
standards
require
diesel
trucks
to
be
more
than
40
percent
cleaner
than
today's
models.

The
second
phase
of
the
program
will
require
cleaner
diesel
fuels
and
even
cleaner
engines,
and
will
reduce
air
pollution
from
trucks
and
buses
by
another
90
percent.
EPA
expects
to
issue
the
final
rule,
to
take
effect
in
2006­
2007,
for
the
second
phase
of
the
program
by
the
end
of
2003.

These
reductions
are
presented
in
Table
2­
10
for
NOx
and
Table
2­
11
for
VOC.
They
are
estimated
to
be
a
41%
reduction
or
a
net
11.78
tpd
of
NOx
and
30%
or
a
net
.34
tpd
for
VOC
in
the
A/
RR
MSA.
This
includes
fleet
turnover,
which
will
continue
to
reduce
emissions
over
time.

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
NOx
Emissions
(
tpd)
2007
Controlled
NOx
Emissions
(
tpd)
Net
Reduction
(
tpd)
Percent
Reduction
(%)

HDDV
2004
HDDV
standards
Austin­
Round
Rock
MSA
(
5
Counties)
40.50
28.73
11.78
41.0%

Table
2­
10.
Federal
H­
D
Diesel
NOx
Reductions
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
2­
8
Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
Reduction
(
tpd)
Percent
Reduction
(%)

HDDV
2004
HDDV
standards
Austin­
Round
Rock
MSA
(
5
Counties)
1.48
1.14
0.34
30.0%

Table
2­
11.
Federal
H­
D
Diesel
VOC
Reductions
2.6
STANDARDS
FOR
SMALL
SPARK­
IGNITION
HANDHELD
ENGINES
The
rules
for
small
spark­
ignition
handheld
engines
are
codified
in
40
CFR
Part
90
Control
of
Emission
from
Nonroad
Spark­
Ignition
Engines
at
or
Below
19
Kilowatts.
In
July
1995,
EPA
finalized
the
first
federal
regulations
affecting
small
nonroad
SI
engines
at
or
below
19
kilowatts
(
kW),
or
25
horsepower.
The
regulations,
commonly
known
as
"
Phase
1,"
took
effect
for
most
new
handheld
and
nonhandheld
engines
beginning
in
model
year
1997
and
expected
to
result
in
a
32
percent
reduction
in
HC
emissions
from
these
engines.
For
the
nonhandheld
categories,
Class
I
engines
are
used
primarily
in
walk
behind
lawnmowers
and
Class
II
engines
are
used
primarily
in
lawn
and
garden
tractors.

For
the
handheld
categories,
Class
III
and
IV
engines
are
used
primarily
in
residential
equipment
such
as
string
trimmers,
leaf
blowers
and
chainsaws.
Class
V
engines
are
used
primarily
in
commercial
equipment
such
as
chainsaws.

The
Phase
2
handheld
engine
standards
will
result
in
a
70
percent
reduction
in
HC+
NOx
emissions
from
these
engines
beyond
the
32
percent
reduction
from
the
Phase
1
standards.
The
Phase
2
standard
began
with
the
2002
model
year.
This
reduction
in
HC+
NOx
emissions
will
be
accompanied
by
an
overall
reduction
in
fuel
consumption.

2.7
COMPRESSION
IGNITION
STANDARDS
FOR
VEHICLES
AND
EQUIPMENT
This
rule
is
addressed
in
63
Federal
Register
56968
(
October
23,
1998)
and
codified
in
40
CFR
Part
89
Control
Of
Emissions
From
New
And
In­
use
Nonroad
Compression­
ignition
Engines.
Non­
road
diesel
engines,
also
referred
to
as
non­
road
compression­
ignition
engines,
dominate
the
large
non­
road
engine
market.
Examples
of
non­
road
equipment
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
2­
9
that
use
diesel
engines
include:
agricultural
equipment
such
as
tractors,
balers,
and
combines;
construction
equipment
such
as
backhoes,
graders,
and
bulldozers;
general
industrial
equipment
such
as
concrete/
industrial
saws,
crushing
equipment,
and
scrubber/
sweepers;
some
lawn
and
garden
equipment
such
as
garden
tractors,
rear
engine
mowers,
and
chipper/
grinders;
material
handling
equipment
such
as
heavy
forklifts;
and
utility
equipment
such
as
generators,
compressors,
and
pumps.

On
October
23,
1998,
EPA
adopted
more
stringent
emission
standards
for
NOx,
VOC's
and
particulate
matter
(
PM)
for
now
non­
road,
compression­
ignition
engines,
to
be
phased
in
over
several
years
beginning
in
model
year
1999.

2.8
EMISSIONS
STANDARDS
FOR
LARGE
SPARK
IGNITION
ENGINES
This
rule
is
covered
in
40
CFR,
Subchapter
U,
Part
1048
Control
of
Emissions
from
New,

Large
Non­
road
Spark­
ignition
Engines.
It
controls
VOC
and
NOx
emissions
from
several
groups
of
previously
unregulated
nonroad
engines,
including
large
industrial
spark­
ignition
engines,
recreational
vehicles,
and
diesel
marine
engines.
This
applies
to
manufacturers
or
importers
of
new,
spark­
ignition,
nonroad
engines,
including
anyone
who
manufactures,
installs,
owns,
operates,
or
rebuilds
any
of
the
engines.

The
new
EPA
requirements
vary
depending
upon
the
type
of
engine
or
vehicle,
taking
into
account
environmental
impacts,
usage
rates,
the
need
for
high
performance
models,

costs
and
other
factors.
The
emission
standards
apply
to
all
new
engines
sold
in
the
United
States
and
any
imported
engines
manufactured
after
these
standards
begin.

Controls
on
the
category
of
large
industrial
spark­
ignition
engines
are
first
required
in
2004.
Controls
on
the
other
engine
categories
are
required
beginning
in
years
after
2005.

2.9
EMISSIONS
STANDARDS
FOR
SPARK
IGNITION
MARINE
ENGINES
Provided
in
a
program
update
titled
Reducing
Air
Pollution
from
Non­
Road
Engines
(
EPA420­
F­
03­
011,
April
2003)
are
plans
for
controlling
exhaust
VOC
emissions
from
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
2­
10
new
spark­
ignition
(
SI)
gasoline
marine
engines,
including
outboard
engines,
personal
watercraft
engines,
and
jet
boat
engines.
Of
nonroad
sources
studied
by
EPA,
gasoline
marine
engines
were
found
to
be
one
of
the
largest
contributors
of
hydrocarbon
(
HC)

emissions
(
30%
of
the
nationwide
nonroad
total).

EPA
is
imposing
emission
standards
for
2
 
stroke
technology,
outboard
and
personal
watercraft
engines.
This
will
involve
increasingly
stringent
HC
control
over
the
course
of
a
nine­
year
phase­
in
period
beginning
in
model
year
1998.
By
the
end
of
the
phase­
in,

each
manufacturer
must
meet
an
HC
and
NOx
emission
standard
that
represents
a
75%

reduction
in
HC
compared
to
unregulated
levels.
These
standards
do
not
apply
to
any
currently
owned
engines
or
boats.

2.10
EMISSIONS
CONTROLS
FOR
LOCOMOTIVES
Federal
Register
Vol.
63,
No
73
(
April
16,
1998),
40
CFR
Parts
85,
89,
and
92,
Emission
Standards
for
Locomotives
and
Locomotive
Engines,
sets
NOx
standards
for
locomotive
engines
remanufactured
and
manufactured
after
2001.
This
program
includes
all
locomotives
originally
manufactured
from
2002
through
2004.
It
also
applies
to
the
remanufacture
of
all
engines
built
since
1973.
Regulation
of
the
remanufacturing
process
is
critical
because
locomotives
are
generally
remanufactured
5
to
10
times
during
their
total
service
lives,
which
are
typically
40
years
or
more.

Three
separate
sets
of
emissions
standards
have
been
adopted,
with
the
applicability
of
the
standards
dependent
on
the
date
a
locomotive
is
first
manufactured.
The
first
set
of
standards
(
Tier
0)
applies
to
locomotives
and
locomotive
engines
originally
manufactured
from
1973
through
2001,
any
time
they
are
manufactured
or
remanufactured.
The
second
set
of
standards
(
Tier
1)
apply
to
locomotives
and
locomotive
engines
originally
manufactured
from
2002
through
2004.
These
locomotives
will
be
required
to
meet
the
Tier
1
standards
at
the
time
of
manufacture
and
at
each
subsequent
remanufacture.
The
final
set
of
standards
(
Tier
2)
apply
to
locomotives
and
locomotive
engines
originally
manufactured
in
2005
and
later.
Electric
locomotives,
historic
steam­
powered
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
2­
11
locomotives
and
locomotives
manufactured
before
1973
do
not
significantly
contribute
to
the
emissions
problem
and,
therefore,
are
not
included
in
the
regulation.
Table
2­
12
provides
an
estimate
on
the
reductions
this
rule
will
provide
the
A­
RR
MSA.
).
A
rule
penetration
and
effectiveness
of
100%
and
control
efficiency
of
43.2%
is
assumed.

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
NOx
Emissions
(
tpd)
2007
Controlled
NOx
Emissions
(
tpd)
Net
Reduction
(
tpd)
Percent
Reduction
(%)

NONROAD
MOBILE
SOURCES:

Locomotives
SCC:
2285002000
Federal
Rule
Austin­
Round
Rock
MSA
(
5
Counties)
5.28
3.00
2.28
43.2%

Table
2­
12.
Locomotive
Rule
NOx
Emission
Reduction
The
following
table
provides
the
estimated
annual
NOx
emission
reductions
for
years
1999
through
2010.
Because
it
takes
forty
or
more
years
for
the
locomotive
fleet
to
turn
over,
NOx
emissions
will
continue
to
decline
well
beyond
2010.

Calendar
Year
NOx
1999
0.0%

2000
­
7.9%

2001
­
15.9%

2002
­
23.9%

2003
­
32.0%

2004
­
40.2%

2005
­
41.8%

2006
­
42.5%

2007
­
43.2%

2008
­
43.9%

2009
­
44.6%

2010
­
45.3%

Table
2­
13.
Annual
NOx
Reductions
from
Anticipated
Locomotive
Standards
These
numbers
are
based
on
a
draft
of
the
proposed
locomotive
standards.
States
are
permitted
to
take
credit
for
them
in
their
SIP
submittals.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
2­
12
2.11
ALCOA
CONSENT
DECREE
On
April
9,
2003,
the
Justice
Department,
and
the
Environmental
Protection
Agency
announced
a
major
Clean
Air
Act
settlement
with
Alcoa
Inc.
that
resolved
violations
of
the
Clean
Air
Act's
New
Source
Review
(
NSR)
and
Prevention
of
Significant
Deterioration
(
PSD)
requirements.
Under
the
settlement,
Alcoa
has
committed
to
install
pollution
controls
that
will
result
in
major
reductions
of
harmful
air
pollutants
annually
and
will
fund
several
beneficial
environmental
projects.
Within
twelve
(
12)
months
of
the
issuance
of
the
Permit
Amendment
(
September
2003),
Alcoa
shall
select
one
of
the
three
pollution
reduction
options
set
forth
below
for
the
Existing
Sandow
Units,
and
shall
notify
the
TCEQ
in
writing
as
to
which
option
Alcoa
has
selected
for
these
Units:

a.
the
continued
utilization
of
the
Existing
Sandow
Units,
and
the
installation
of
pollution
control
equipment
at
these
Units
in
compliance
with
Paragraphs
51
through
59
of
the
Consent
Decree
("
Option
A");

b.
the
installation
of
Replacement
Sandow
Units
for
the
Existing
Sandow
Units,
with
the
installation
and
operation
of
pollution
controls
as
required
by
the
State
Permitting
Process,
in
compliance
with
Paragraphs
60
through
67
of
the
Consent
Decree
("
Option
B");
or
c.
the
shutdown
of
the
Existing
Sandow
Units,
in
compliance
with
Paragraph
68
of
the
Consent
Decree
("
Option
C").

Estimated
reductions
for
these
options
are
90%
of
NOx
or
about
54
tpd.
The
company's
Rockdale
facility,
located
northeast
of
Austin,
Texas,
is
the
nation's
largest
emitter
of
sulfur
dioxide
(
SO2)
and
nitrogen
oxides
(
NOx)
from
the
non­
utility
source
category,

according
to
EPA's
1999
National
Emissions
Inventory
that
was
released
in
October
2001.
These
emissions
were
generated
for
the
three
coal­
fired
electric
generating
industrial
boilers
that
support
the
smelter
operations
at
Rockdale
and
are
addressed
in
the
agreement.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
2­
13
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
3­
1
3
State
and
Regional
Reduction
Strategies
Sec.
Category
Reductions
in
2007
(
tpd)
Area
Source:
VOC
NOx
3.1
Degreasing
Units
1.96
n/
a
3.2
HB
2914
Grand
fathered
Pipelines
TBD
TBD
On­
road
Source:
3.3
Stage
1
Vapor
Recovery
3.72
n/
a
Non­
road
Source:
3.4
Low
Emission
Diesel
TBD
TBD
Point
Source:
3.5
SB
7
EGU
NOx
Reductions
n/
a
10.09
3.6
SB
766
Voluntary
Emissions
Reduction
Permit
TBD
TBD
3.7
HB
2912
Grandfathered
Requirements
TBD
TBD
3.8
Cement
Kiln
NOx
Limits
n/
a
2.16
Total
(
not
including
TBD)
9.4
12.25
Table
3­
1.
Summary
of
TCEQ­
Issued
Rules
for
Reduction
Strategies
State
and
regional
reduction
strategies
are
from
state
implemented
rules
that
apply
to
the
A/
RR
MSA.
Rules
that
apply
but
were
listed
in
the
emission
reduction
strategies
are
Gasoline
Volatility
(
30
TAC
§
114.302),
Non­
Road
Large
Spark­
Ignition
Engines
(
30
TAC
114,
Subchapter
1,
Division
3),
and
Gas­
fired
water
heaters,
small
boilers,
and
process
heaters
(
30
TAC
117,
Subchapter
D,
Division
1).
There
is
no
category
or
direct
method
to
calculate
the
rule
application.

3.1
DEGREASING
UNITS
Under
30
TAC
106.454
Degreasing
Units,
anyone
obtaining
a
state
air
permit
for
a
degreasing
unit
is
required
to
meet
with
§
115.412
and
§
115.415
as
of
November
1st,

2001.
These
rules
cover
operating
procedures,
solvent
use
and
storage,
ventilation,
and
record
keeping.
Given
the
projected
population
growth,
this
existing
rule
affects
our
future
inventory
by
10.1%.
(
Table
3­
2).
The
assumptions
used
in
the
calculation
were
100%
rule
effectiveness,
50%
rule
penetration
and
85%
control
efficiency.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
3­
2
Table
3­
2.
NOx
reductions
from
degreasing
rule
3.2
GRANDFATHERED
PIPELINES
The
new
ruling
of
the
grandfather
permitting
portion
of
HB
2914
will
be
added
to
30
TAC
Chapter
116,
Subchapters
H
&
I.
The
implementation
will
address
reciprocating
internal
combustion
engines
connected
to
a
pipeline.
It
requires
50%
reduction
in
NOx
and
up
to
50%
reduction
in
VOC
in
East
Texas.
It
also
requires
up
to
20%
reduction
in
NOx
and
VOC
in
West
Texas.
It
allows
averaging
of
reduction
between
engines
connected
to
a
pipeline.
The
Oasis
Pipeline
in
Caldwell
County
is
effected
by
this
rule.

3.3
STAGE
1
VAPOR
RECOVERY
30
TAC
115,
Subchapter
C,
Division
2
Filling
of
Gasoline
Storage
Vessels
(
Stage
1)
for
Motor
Vehicle
Fuel
Dispensing
Facilities,
was
adopted
on
June
30,
1999.
These
rules
apply
to
the
BPA,
El
Paso,
HGA,
and
DFW
ozone
nonattainment
areas
and
in
95
counties,
including
the
A/
RR
MSA,
in
the
eastern
and
central
parts
of
Texas.
These
rules
regulate
the
filling
of
gasoline
storage
tanks
at
gasoline
stations
by
tank­
trucks.
To
comply
with
Stage
I
requirements,
a
vapor
balance
system
is
typically
used
to
capture
the
vapors
from
the
gasoline
storage
tanks
that
would
otherwise
be
displaced
to
the
atmosphere
as
these
tanks
are
filled
with
gasoline.
The
captured
vapors
are
routed
to
the
gasoline
tank­
truck,
and
are
processed
by
a
vapor
control
system
when
the
tank­
truck
is
subsequently
refilled
at
a
gasoline
terminal
or
gasoline
bulk
plant.
The
rules
reduce
VOC
emissions
that
are
precursors
to
ground­
level
ozone
formation,
resulting
in
ground­
level
ozone
reductions.

The
effectiveness
of
Stage
I
vapor
recovery
rules
depend
on
the
captured
vapors
being:

(
1)
effectively
contained
within
the
gasoline
tank­
truck
during
transit;
and
(
2)
controlled
Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
Reduction
(
tpd)
Percent
Reduction
(%)

AREA
SOURCES:

Degreasing
(
All
Degreasing
Categories)
VOC
degreasing
controls
on
new
sources
(
permit
rules)
Austin­
Round
Rock
MSA
(
5
Counties)
16.32
9.38
6.94
42.5%
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
3­
3
when
the
transport
vessel
is
refilled
at
a
gasoline
terminal
or
gasoline
bulk
plant.

Otherwise,
the
emissions
captured
at
the
gasoline
station
will
simply
be
emitted
at
a
location
other
than
the
gasoline
station,
resulting
in
no
reduction
in
VOC
emissions
despite
the
Stage
I
requirements.
It
is
estimated
that
the
A/
RR
MSA
will
see
a
27%

reduction
from
the
2007
baseline
emissions
due
to
this
rule
(
Table
3­
3).
).
A
rule
penetration
of
37.5%,
rule
effectiveness
of
80%
and
control
efficiency
of
90%
was
assumed.

Table
3­
3.
Stage
1
VOC
emission
reduction
3.4
STATE
LOW
EMISSION
DIESEL
PROGRAM
This
strategy
implements
a
state
LED
fuel
program
(
30
TAC
114.313
designated
alternative
limit)
requiring
fuel
producers
and
importers,
beginning
April,
2005
to
ensure
that
all
diesel
fuel
used
in
110
East
Texas
counties,
including
the
A/
RR
MSA,
for
both
on­
road
and
non­
road
use
does
not
exceed
500
ppm
sulfur,
contains
less
than
10.0%
by
volume
of
aromatic
hydrocarbons,
and
has
a
minimum
cetane
number
of
48.
Alternative
diesel
fuel
formulations
that
achieve
equivalent
emission
reductions
may
also
be
used.

The
state
LED
fuel
program
also
requires
that,
beginning
June
1,
2006,
the
sulfur
content
be
reduced
to
15
ppm
sulfur
in
both
on­
road
and
non­
road
diesel
fuel
in
110
East
Texas
counties.
The
fuel
required
by
the
state
LED
fuel
program
will
have
a
lower
aromatic
hydrocarbon
content
and
a
higher
cetane
number
in
each
gallon
of
diesel
than
required
by
current
federal
regulations
for
on­
road
diesel.
Due
to
a
provision
in
the
rule
allowing
refiners
to
receive
credit
for
alternate
emission
reductions,
some
benefits
of
NOx
reductions
may
not
be
realized
during
the
final
two
years
of
this
plan.
Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
Reduction
(
tpd)
Percent
Reduction
(%)

AREA
SOURCES:

Stage
I
Refueling
SCC:
2501060053
Stage
I
VRS
on
125k
Gas
Stations
Austin­
Round
Rock
MSA
(
5
Counties)
13.79
10.07
3.72
27.0%
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
3­
4
3.5
ELECTRIC
GENERATING
UTILITY
NOX
REDUCTIONS
Senate
Bill
7,
enacted
by
the
76th
Legislature,
restructured
electric
utility
service
in
Texas.
Owners
of
grandfathered
facilities
that
generate
electric
energy
for
compensation
were
required
to
apply
for
an
electric
generating
facility
(
EGF)
permit
from
the
commission
by
September
1,
2000.
The
legislation
provided
that
initial
issuance
of
these
permits
allow
for
notice
and
comment
hearing
proceedings,
not
contested­
case
evidentiary
hearings.
The
legislation
does
not
allow
for
amendments
to
EGF
permits.

Renewal
of
these
permits
requires
notice,
comment,
and
opportunity
for
a
contested
case
hearing.
Table
3­
4
shows
the
expected
NOx
reductions
due
to
this
measure.
).
A
rule
penetration
and
effectiveness
of
100%
and
control
efficiency
of
50%
is
assumed.

Table
3­
4.
Utility
(
EGU)
NOx
Reductions
3.6
VOLUNTARY
EMISSIONS
REDUCTION
PERMIT
(
VERP)

The
Voluntary
Emission
Reduction
Permit
(
VERP)
program
is
found
under
30
TAC
116
Subchapter
H,
Division
4.
In
1999,
the
76th
Texas
State
Legislature
used
the
CARE
Committee's
recommendation
as
the
basis
for
Senate
Bill
766
(
SB
766),
which
directed
the
TCEQ
to
develop
rules
containing
incentives
for
the
voluntary
permitting
of
grandfathered
facilities.
The
TCEQ
adopted
rules
to
implement
the
VERP
program
on
December
16,
1999.
The
owners
and
operators
of
a
number
of
grandfathered
facilities
took
advantage
of
the
incentives
offered
by
the
VERP
program
and
submitted
VERP
applications
for
their
grandfathered
facilities.
Additionally,
the
owners
and
operators
of
other
grandfathered
facilities
submitted
permit­
by­
rule
registrations
and
other
new
source
review
permit
applications
to
permit
their
grandfathered
facilities.
The
deadline
to
apply
for
a
VERP
was
August
31,
2001.
Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
NOx
Emissions
(
tpd)
2007
Controlled
NOx
Emissions
(
tpd)
Net
Reduction
(
tpd)
Percent
Reduction
(%)
Point
Sources
(
EGUs):
ID#:
BC0015L,
BC0082T,
BC0083R,
HK0108C,
TH0004D,
TH0006W,
TH0104V,
Senate
Bill
7
NOx
reduction
Austin­
Round
Rock
MSA
(
5
Counties)
31.11
21.02
10.09
32.4%
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
3­
5
3.7
HB
2912
Grandfathered
Requirements
The
mandatory
permitting
requirements
of
HB
2912
are
the
culmination
of
legislative
efforts,
beginning
in
1997,
to
permit
or
otherwise
authorize
all
grandfathered
facilities.

House
Bill
2912
created
four
new
types
of
permits
for
grandfathered
facilities:
existing
facility
permits,
small
business
stationary
source
permits,
EGF
permits,
and
pipeline
facilities
permits.
House
Bill
2912
also
mandated
the
dates
by
which
grandfathered
facilities
must
apply
for
a
permit
and
have
controls
operational
or
submit
a
shutdown
notice.
Grandfathered
facilities
that
are
addressed
by
an
application
for
a
VERP
are
not
required
to
comply
with
the
provisions
of
HB
2912
for
grandfathered
facilities.
However,

grandfathered
facilities
that
withdraw
their
VERP
applications
and
elect
to
submit
a
permit
application
for
an
authorization
under
HB
2912
will
forfeit
those
incentives,

including
eligibility
for
amnesty
from
enforcement.
This
rule
will
be
under
30
TAC
116
Subchapter
H
Permits
for
Grandfathered
Facilities,
Divisions
2
and
3.

3.8
CEMENT
KILN
NOx
LIMITS
30
TAC
117
Subchapter
B,
Division
4
Cement
Kilns,
applies
to
each
portland
cement
kiln
in
Bexar,
Comal,
Ellis,
Hays,
and
McLennan
Counties
except
as
specified
in
§
117.265
and
§
117.283
(
relating
to
Emission
Specifications;
and
Source
Cap).
It
establishes
emission
limits
on
the
basis
of
pounds
of
NOx
per
ton
of
clinker
produced
for
cement
kilns
placed
into
service
before
December
31,
1999.
These
limits
are
based
on
the
NOx
emissions
averaged
over
each
30
consecutive
day
period,
and
vary
depending
on
the
type
of
cement
kiln.
For
each
preheater­
precalciner
or
precalciner
kiln
in
Hays
County,
2.8
lbs/
ton
of
clinker
produced
is
specified
in
Role
117.283.
It
is
expected
a
27%
reduction
in
NOx
will
be
seen
where
this
rule
is
applicable.

The
reduction
from
Texas
Lehigh
Cement,
as
incorporated
in
TCEQ
permit
no.
3611D,

will
go
from
7.2
tpd
of
NOx
to
5.04
tpd
for
a
total
of
2.16
tpd
reduction
or
30%.
This
is
given
in
Table
3­
5.
The
2007
emission
was
adjusted
using
a
growth
factor
to
the
final
value
5.24
tpd.
All
non­
EGU
were
grown
using
growth
factors
from
the
EGAS
model
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
3­
6
(
by
TCEQ).
A
rule
penetration
and
effectiveness
of
100%
and
control
efficiency
of
30%

is
assumed.

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
NOx
Emissions
(
tpd)
2007
Controlled
NOx
Emissions
(
tpd)
Net
Reduction
(
tpd)
Percent
Reduction
(%)
Point
Sources
(
TX
LEHIGH
C.):
HK0108C
NOx
reduction
Austin­
Round
Rock
MSA
(
5
Counties)
7.20
5.04
2.16
30.0%

Table
3­
5.
Cement
Kiln
NOx
Reduction
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
1
4
Local
Strategies
4.1
LOCAL
STRATEGIES
INTRODUCTION
The
June
2003
EAC
milestone
identified
and
described
potential
local
emission
reduction
strategies.
The
milestone
report,
and
subsequent
revisions,
organizes
the
measures
into
two
tables.
The
measures
in
Table
A
apply
to
all
or
most
jurisdictions
in
the
A/
RR
MSA.

They
will
require
state
regulation.
The
Table
B
measures
are
self­
selected
by
the
jurisdictions
with
each
choosing
at
least
three
for
implementation.
These
are
in
addition
to
continuing
O3
Flex
commitments.
Jurisdictions
may
choose
to
enhance
an
existing
O3
Flex
measure.
Included
in
this
section
is
a
Transportation
Emission
Reduction
Measure
(
TERM)
that
will
be
implemented
by
various
local
jurisdictions
through
an
agreement
with
the
Capital
Area
Metropolitan
Planning
Organization
(
CAMPO).

4.2
TABLE
A
EMISSION
REDUCTION
MEASURES
NOx
Reductions
(
tpd)
VOC
Reductions
(
tpd)
A1
Inspection
and
Maintenance
(
I&
M)
3.19
4.19
A2
Idling
Restrictions
on
Heavy
Diesel
0.19
0.00
A3
Commute
Emission
Reduction
Program
0.27
0.30
A4
Stage
I
Vapor
Recovery
Requirement
Change
0.00
4.88
A5
Low
Emission
Gas
Cans
0.00
1.97
A6
Degreasing
Controls
0.00
6.38
A7
Autobody
Refinishing
Controls
0.00
0.05
A8
Cutback
Asphalt
0.00
1.03
A9
Low
Reid
Vapor
Pressure
Gas
0.00
2.87
A10
BACT
and
Offsets
for
New
or
Modified
Point
Sources
TBD
TBD
A11
Petroleum
Dry
Cleaning
0.00
1.06
A12
Texas
Emission
Reduction
Program
(
TERP)
2.00
0.00
A13
Power
Plant
Reductions
7.08
0.00
Total
(
Does
not
include
TBD)
12.73
23.64
Emission
Reduction
Measures
(
State
Regulations)

Table
A.
Recommended
Measures
requiring
State
Regulations
of
Actions.
Note:
The
I&
M
program
assumes
participation
from
Hays
County.
Without
Hays
Co
participation
reductions
are
2.89tpd
and
3.84tpd
of
NOx
and
VOC
respectively.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
2
This
section
describes
each
of
the
control
measures
appearing
in
Table
A.
Each
control
measure
is
described
and
emission
reduction
calculations
are
presented
in
the
remainder
of
this
chapter.
Actual
implementation
dates
and
regulation
names
were
supplied
by
the
state.
Actual
emission
reductions
may
vary
slightly
from
the
estimates
appearing
in
this
chapter
since
these
estimates
are
based
on
EPA
guidance,
and
not
necessarily
actual
data
from
the
in­
situ
emission
control
measures.
CAPCO
contracted
with
ERG,
Inc.
to
provide
technical
support
in
quantifying
emissions
and
evaluating
regulatory
and
other
implementation
issues.

Table
A
measures
require
state
regulations
or
actions
for
implementation
and
enforcement.
They
will
be
implemented
no
later
than
December
31,
2005.
(
Power
plant
reductions
and
TERP
will
begin
phasing­
in
no
later
than
December
31,
2005.)
The
semiannual
review
reports
will
track
and
document
Table
A
measures.

4.2.1
Inspection
and
Maintenance
(
A1)

SOURCE
TYPE
AFFECTED
Program
participants
are
owners
of
2
to
24
year
old
gasoline
vehicles,
safety
inspection
station
owners
and
operators,
vehicle
repair
facilities,
TCEQ,
DPS
and
counties
that
choose
to
administer
(
or
contract
with
another
entity
to
administer)
a
LIRAP
program.

The
program
does
not
apply
to
motorcycles
or
slow
moving
vehicles,
as
defined
by
Section
547.001,
Transportation
Code.
Test
on
resale
is
required
for
all
vehicles
from
non­
I/
M
program
counties
that
are
sold
and
registered
in
the
I/
M
program
counties.
Per
state
statute,
vehicles
belonging
to
students
at
public
universities,
but
registered
in
non­

I/
M
program
counties,
must
participate
to
receive
campus­
parking
privileges.

CONTROL
STRATEGY
The
I/
M
program
requires
all
subject
gasoline
vehicles
2
to
24
years
old
registered
and
primarily
operated
in
the
I/
M
program
counties
(
Hays,
Travis
and
Williamson)
to
undergo
an
annual
emissions
inspection
test
in
conjunction
with
the
annual
safety
inspection.
Emissions
inspection
tests
are
conducted
at
all
safety
inspection
stations.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
3
The
entire
vehicle
safety
and
emissions
inspection
should
be
completed
in
about
20
minutes
from
the
time
the
vehicle
is
driven
into
the
inspection
bay.
If
a
vehicle
fails
the
emissions
inspection
test,
the
items
of
failure
will
be
indicated
on
the
Vehicle
Inspection
Report.
The
vehicle
should
be
repaired
and
returned
to
the
same
inspection
station
with
15
days
for
a
free
re­
test.
A
passing
emission
inspection
test
(
or
test
waiver)
is
required
in
order
to
renew
vehicle
registration
or
to
receive
a
safety
inspection
sticker.

IMPLEMENTATION
The
I/
M
program
was
evaluated
to
be
applied
in
Travis,
Hays
and
Williamson
Counties.

As
of
the
plan
submittal
date
(
3/
31/
04)
the
City
of
San
Marcos
had
voted
not
to
participate
in
the
I/
M
program,
thus
eliminating
Hays
County
form
program
applicability.

The
I/
M
Program
counties
exercise
the
flexibility
offered
to
EAC
areas
in
Senate
Bill
1159
and
request
that
TCEQ
adopt
a
rule
including
the
MSA's
I/
M
Program
in
the
state
program.
Periodic
program
evaluations
will
determine
if
any
revisions
or
modifications
are
needed.
The
plan
must
be
implemented
no
later
than
December
31,
2005.

The
OBDII
testing
program
will
be
used
to
test
1996
model
year
and
newer
vehicles.
All
1996
and
newer
vehicles
less
than
14,000
pounds
(
passenger
cars,
pickup
trucks,
sport
utility
vehicles)
are
equipped
with
OBD
systems.
The
OBD
system
monitors
emission
performance
components
to
ensure
that
the
vehicle
runs
as
cleanly
as
possible.
The
system
also
assists
repair
technicians
in
diagnosing
and
fixing
emission­
related
problems.

If
a
problem
is
detected,
the
OBD
system
illuminates
a
"
Check
Engine"
or
"
Service
Engine
Soon"
warning
lamp
on
the
vehicle
instrument
panel
to
alert
the
driver.
The
system
will
store
information
about
the
detected
malfunction
so
that
a
repair
technician
can
accurately
find
and
fix
the
problem.

Model
year
1996
and
newer
vehicles
are
required
to
meet
EPA
specifications
for
collection
and
transfer
of
emissions
control
data
during
each
driving
cycle.
The
Diagnostic
Link
Connector
(
DLC)
cable
on
the
emissions
test
analyzer
is
hooked
up
to
the
DLC
located
in
the
vehicle.
When
the
vehicle's
OBD
system
has
checked
the
emissions
control
systems
and
detected
a
problem
with
the
vehicle,
this
information
is
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
4
stored
in
the
vehicle's
on­
board
computer.
The
OBD
test
transmits
this
data
to
the
analyzer
and
the
vehicle
will
fail
the
inspection.
The
inspection
report
will
indicate
which
emissions
control
systems
were
checked
and
display
the
description
of
the
fault
codes
retrieved
from
the
vehicle.

The
Two­
Speed
Idle
testing
program
will
be
used
to
test
1995
model
year
and
older
vehicles.
The
TSI
test
uses
a
tailpipe
probe
exhaust
gas
analyzer
to
measure
VOC
and
CO
while
the
vehicle
is
idling
at
a
low
and
a
high
rate.

The
I/
M
program
includes
a
high
emitter
program
to
identify
vehicles
that
are
significantly
exceeding
federal
vehicle
emission
standards.
On­
road
remote
sensing
equipment
will
be
used
to
identify
high­
emitting
vehicles
in
the
three
I/
M
program
counties
or
those
commuting
from
contiguous
counties.
The
van­
installed
on­
road
testing
equipment
is
strategically
placed
to
capture
auto
emissions
from
single­
lane
traffic
in
an
acceleration
mode.
Vehicles
identified
as
high
emitters
must
be
tested
using
the
ageappropriate
OBDII
or
TSI
test
within
30
days
of
notification
and
be
repaired,
if
necessary.
A
passing
test
result
(
or
test
waiver)
will
be
needed
to
renew
vehicle
registration.

The
following
waivers
and
extensions
will
be
available
to
all
qualifying
vehicle
owners
through
the
Texas
Department
of
Public
Safety
(
DPS):

Individual
Vehicle
Waiver
 
In
order
to
address
unusual
cases
where
a
vehicle
cannot
meet
emissions
standards,
an
Individual
Vehicle
Waiver
may
be
issued
to
a
vehicle
owner
whose
vehicle
has
failed
its
initial
emissions
inspection
and
reinspection
and
in
which
at
least
$
600
in
emissions
related
repairs
have
been
performed
by
a
registered
repair
facility.

Low
Mileage
Waiver
 
A
Low
Mileage
Waiver
may
be
issued
to
a
vehicle
owner
whose
vehicle
has
failed
both
its
initial
emissions
inspection
and
the
reinspection
and
in
which
at
least
$
100
in
emissions
related
repairs
have
been
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
5
performed.
The
vehicle
should
have
been
driven
less
than
5,000
miles
in
the
previous
inspection
cycle
and
anticipate
being
driven
fewer
than
5,000
miles
before
the
next
required
safety
inspection.

Parts
Availability
Time
Extension
 
A
Parts
Availability
Extension
may
be
issued
for
30,
60
or
90
days
to
a
vehicle
owner
whose
vehicle
fails
the
initial
emission
inspection
and
needs
time
to
locate
necessary
vehicle
emissions
control
parts.

Low
Income
Time
Extension­
A
Low
Income
Time
Extension
may
be
issued
to
a
vehicle
owner
whose
vehicle
has
failed
its
initial
inspection
and
re­
inspection,
and
the
applicant's
adjusted
gross
income
is
at
or
below
the
federal
poverty
level.

Counties
that
implement
a
vehicle
emissions
inspection
program
may
elect
to
implement
the
Low
Income
Repair
Assistance,
Retrofit,
and
Accelerated
Vehicle
Retirement
Program
(
LIRAP).
Vehicle
owners
whose
vehicles
fail
the
emissions
inspection
and
who
meet
eligibility
requirements
may
receive
assistance
through
this
program.
The
assistance
can
pay
for
emissions
related
repairs
or
be
used
toward
a
replacement
vehicle
if
they
choose
to
retire
the
vehicle.
Note
that
in
case
of
the
vehicle
replacement
additional
emission
reductions
may
be
expected
when
newer
vehicles
are
purchased
but
are
not
quantified.
The
assistance
program
is
funded
through
a
portion
of
the
emissions
inspection
fee.
The
program
is
administered
through
a
grant
contract
between
TCEQ
and
each
participating
county.
Only
5%
of
the
grant
contract
funds
may
be
used
for
the
administrative
costs
of
the
program.
Assistance
is
limited
to
no
more
than
$
600
for
repairs
or
$
1,000
toward
replacement
of
the
vehicle.

In
order
to
be
eligible
for
LIRAP,
the
vehicle
owner's
total
family
income
must
be
less
than
or
equal
to
twice
the
amount
of
the
Federal
Poverty
Guidelines
for
designated
family
units.
(
At
this
writing,
$
24,240
for
a
family
of
two
and
$
36,800
for
a
family
of
four).
A
vehicle
is
eligible
for
repair
assistance
if
it
failed
the
emissions
inspection
within
30
days
of
application,
is
currently
registered,
and
has
been
registered
in
the
program
area
for
the
two
years
preceding
application,
and
it
passes
the
safety
inspection
portion
of
the
test.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
6
Repairs
must
be
performed
at
a
DPS­
recognized
repair
facility.
Vehicle
retirement
eligibility
requirements
are
the
same
as
for
vehicle
repairs,
except
the
vehicle
must
have
passed
a
safety
inspection
within
15
months
of
the
application.

ESTIMATED
EMISSION
REDUCTION
MOBILE6.2
was
used
to
estimate
NOx
and
VOC
emission
rates
for
vehicles
operating
in
each
of
the
3
counties,
for
a
typical
ozone
season
weekday
in
2007.
Emission
rates
were
then
combined
with
VMT
values
to
estimate
emissions
in
tons
per
day,
for
the
uncontrolled
base
case,
the
standard
state
program,
and
the
alternative
control
options
listed
above.

ERG
obtained
link­
level
activity
data
for
Travis,
Williamson,
and
Hays
Counties
from
the
Texas
Transportation
Institute
(
TTI).
These
link
files
included
hourly
speed
and
VMT
estimates
by
vehicle
type,
for
each
link
in
the
area,
for
the
September
2007
modeling
episode.
MOBILE6
input
file
data
were
obtained
from
CAMPO.
The
CAMPO
data
included
county
level
registration
distributions
and
diesel
sales
fractions
(
from
2002
TxDOT
data),
and
ambient
temperatures
and
humidity
levels
obtained
from
the
TCEQ.

The
MOBILE6.2
hourly
emission
factor
outputs
were
combined
by
roadway
and
vehicle
type
with
the
link­
level
activity
data
to
estimate
total
24­
hour
mass
emissions
for
the
region.
Different
control
scenarios
were
specified
corresponding
to
each
of
the
cases
listed
above.
The
MOBILE6.2
input
files
and
VMT
link
files
are
available
from
ERG.

The
I/
M
program
is
expected
to
reduce
NOx
emissions
by
3.19
tons
per
day
and
VOC
emissions
by
4.19
tons
per
day
(
Table
4­
1
and
Table
4­
2).
The
I/
M
program
will
also
reduce
toxic
emissions,
some
of
which
are
known
carcinogens.
It
will
encourage
proper
vehicle
maintenance,
which
may
result
in
fuel
savings
for
some
vehicle
owners.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
7
Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
NOx
Emissions
(
tpd)
2007
Controlled
NOx
Emissions
(
tpd)
Net
NOx
Reduction
(
tpd)
Percent
Reduction
(%)
ONROAD
MOBILE:
All
Light
Duty
vehicles
&
Heavy
Duty
Gasoline
Vehicles
(
LDV,
HDGV)
Inspection
and
Maintenance
(
I&
M)
Hays,
Travis
Williamson
31.12
27.93
3.19
10.3%

Table
4­
1.
I&
M
NOx
Emission
Reduction
Note:
The
I&
M
program
assumes
participation
from
Hays
County.
Without
Hays
Co
participation
reductions
are
2.89tpd
of
NOx.

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
VOC
Reduction
(
tpd)
Percent
Reduction
(%)
ONROAD
MOBILE:
All
Light
Duty
vehicles
&
Heavy
Duty
Gasoline
Vehicles
(
LDV,
HDGV)
Inspection
and
Maintenance
(
I&
M)
Hays,
Travis
Williamson
30.33
26.14
4.19
13.8%

Table
4­
2.
I&
M
VOC
Emission
Reduction
Note:
The
I&
M
program
assumes
participation
from
Hays
County.
Without
Hays
Co
participation
reductions
are
3.84tpd
of
VOC.

ESTIMATED
COST
ERG
developed
bottom­
up
estimates
for
test
fees
using
their
in­
house
I/
M
fee
calculator.

The
fee
calculator
develops
a
cash
flow
to
calculate
the
fee
required
to
assure
a
fair
return
on
capital
and
operations
costs
over
a
10­
year
program
operations
period.
The
calculator
is
dynamic,
accounting
for
growth
in
the
overall
fleet,
as
well
as
changing
proportions
of
OBD
and
ASM/
TSI
populations.
(
E.
G.,
OBD
populations
increase
with
time,
while
pre­

OBD
fleets
decrease,
allowing
for
partial
liquidation
of
under­
utilized
ASM/
TSI
equipment
over
time.)
The
key
parameters
used
in
the
different
testing
scenarios
are
listed
below.
Note
that
all
estimates
are
incremental
to
the
time
and
effort
associated
with
safety
tests.
Ultimately,
the
test
fees
are
determined
by
TCEQ.

Baseline
cost
assumptions:

 
3,120
hrs
of
operation/
station
per
year
 
Inspector
$/
hr
­­
$
12
(
OBD/
TSI),
$
12
(
ASM),
all
@
30%
loading
 
Test
time
­­
20
minutes
for
ASM,
15
minutes
for
TSI,
10
minutes
for
OBD
 
Bay
space
lease
cost
­­
$
32/
sf/
yr
(
only
applied
when
test
lane
is
in
use
­­
assumes
alternate
revenue
generating
activities
will
occur
in
that
area
when
not
testing)
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
8
 
Wholesale
capital
cost
­­
$
31,000
ASM,
$
12,000
TSI,
$
8,000
OBD
(
Combined
OBD/
TSI
system
­­
$
14,000)

 
ASM
installation
­­
$
4,000
(
in­
ground)

 
Annual
interest
rate
for
equipment
financing
­­
12.5%

 
Warranty
­­
$
2,700
per
yr
ASM,
$
2,000
TSI
 
Utilities
­­
$
1,200
/
yr
ASM,
$
100
TSI
 
Span
gases
­­
$
384
/
yr
ASM,
$
250
TSI
 
Zero
gases
­­
$
0.45
per
TEST
ASM
and
TSI
 
Computer
link
­­
$
1.00
per
test
 
Program
Administration
and
Enforcement
­­
$
2.50
per
vehicle
($
2.00
to
DPS
High
Emitter
Program,
$
0.50
for
TCEQ
audits/
enforcement)

 
Discount
Rate
­­
6%

 
Inflation
Rate
­­
4%

 
Equipment
depreciation
­­
10%

 
Real
wage
rate
increase
­­
2%

 
Corporate
Income
Tax
rate
­­
34%

Using
these
input
parameters
ERG
estimated
the
following
test
fees,
assuming
1
free
retest
is
allowed
after
repairs.
Any
costs
associated
with
Low
Income
Repair
Assistance
Program
(
LIRAP)
subsidies
are
not
included
in
these
estimates.

 
OBD
Only
­­
$
11.972
 
TSI
Only
­­
$
14.52
 
ASM
Only
­­
$
25.91
 
OBD
+
TSI
­­
$
16.69
Note
that
these
independent
estimates
are
quite
close
to
the
official
state
fees
of
$
27.00
for
ASM,
and
$
14.00
for
TSI
(
in
El
Paso),
but
substantially
different
than
the
$
21.00
fee
for
OBD
(
without
LIRAP).

Repairs
Repair
costs
for
the
different
type
of
test
failures
were
based
on
results
from
a
number
of
I/
M
programs
across
the
country.
ERG
took
a
rough
mid­
point
value
from
the
available
data
to
estimate
costs
for
each
test
type.
For
OBD,
the
state
of
Wisconsin
reported
repair
costs
at
$
227
per
OBD
failure
for
2003,
while
the
TCEQ
reported
an
average
of
$
397.

Both
Oregon
and
California
reported
approximately
$
300
per
OBD
repair,
which
was
2
OBD
fees
also
account
for
TSI
testing
of
the
~
2.5%
of
1996
and
older
vehicles
that
cannot
be
tested
using
OBD
equipment,
due
to
instrument
non­
communication
and/
or
a
not­
ready
sensor
status
­­
these
vehicles
receive
a
TSI
test
instead.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
9
used
in
the
ERG
estimates.
Repair
costs
for
loaded
transient
test
failures
(
including
IM240,
IM147,
and
ASM)
ranged
from
~$
200
in
Arizona
to
$
440
in
Texas.
TSI
repairs
were
based
on
2003
California
data.
Average
repair
costs
by
test
type
are
summarized
below.

 
OBD
­­
$
300
 
TSI
­­
$
135
 
ASM
­­
$
300
ERG
assumed
repairs
would
only
have
a
one­
year
lifetime,
so
these
figures
correspond
directly
to
annual
program
costs.
3
Inconvenience
Costs
ERG
estimated
the
amount
of
extra
time
needed
to
comply
with
program
requirements,

considering
travel
time
to
and
from
the
test
facility,
likely
wait
times
before
the
test,

actual
test
time,
and
time
required
to
obtain
needed
repairs
and
subsequent
retests.
While
test
time
is
available
from
several
I/
M
programs,
estimates
for
the
other
categories
are
not
available
and
had
to
be
estimated
by
ERG
staff.
4
ERG
assumed
that
OBD
and
TSI
stations
would
be
relatively
numerous
and
easily
accessed
by
Austin
area
motorists.
For
example,
in
order
to
meet
anticipated
demand
and
to
keep
wait
times
down
during
peak
periods
(
lunch
and
after
work),
ERG's
I/
M
fee
calculator
estimates
that
125
stations
offering
OBD
and
TSI
testing
will
be
needed
in
the
three
county
area
in
2007.
Therefore
ERG
assumed
20
minutes
of
additional
travel
time
to
and
from
these
stations.
The
expected
high
number
of
stations
should
also
keep
wait
times
low,
assumed
to
be
five
minutes
on
average
for
TSI
and
OBD.

3
Although
repair
lifetime
is
unknown,
this
assumption
is
consistent
with
the
state
requirement
for
annual
testing.
4
Wait
times
are
often
also
tracked
by
I/
M
station
operators,
but
these
times
are
highly
dependent
on
the
number
of
stations,
specific
locations,
and
other
local
factors,
and
therefore
could
not
be
used
with
confidence
for
the
yet
to
be
designed
Austin
program.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
10
Given
the
higher
cost
of
entry
associated
with
ASM
testing,
ERG
assumed
fewer
stations
would
be
available
to
serve
the
pre­
OBD
population
than
under
TSI.
Accordingly,
ERG
assumed
30
minutes
of
travel
time
and
10
minutes
of
wait
time
on
average
for
ASM
testing.

ERG
used
data
from
TCEQ's
I/
M
database
to
estimate
average
test
times
for
the
three
options
­­
20
minutes
for
ASM,
15
minutes
for
TSI,
10
and
minutes
for
OBD.

The
time
required
for
repair
is
likely
to
vary
according
to
test
type.
Since
many
TSI
failures
simply
require
air/
fuel
adjustments
and
related
tune­
ups,
which
are
relatively
quick,
ERG
assumed
an
average
of
2
hours
for
these
repairs.
However,
vehicles
failing
OBD
or
ASM
for
high­
NOx
emissions
may
often
require
new
catalysts
or
other
complex
repairs.
Therefore
ERG
assumed
3
hours
on
average
for
OBD
and
ASM
repairs.

ERG
calculated
the
total
motorist
time
required
for
program
compliance
for
each
of
these
options
using
the
above
assumptions,
as
well
as
estimates
of
total
vehicle
tests
(
from
local
registration
records)
and
failure
rates
obtained
from
TCEQ.
Given
the
uncertainty
in
the
value
of
this
time,
ERG
did
not
monetize
inconvenience
costs.
5
The
emissions
test
fee
(
set
by
TCEQ)
is
expected
to
be
no
more
than
$
20
in
Travis
and
Williamson
Counties.
The
safety
inspection
fee
is
$
12.50,
so
the
combined
inspection
cost
is
not
expected
to
exceed
$
32.50.
Testing
equipment
costs
(
estimated
at
$
15,000
per
station)
are
recouped
through
fee.
The
equipment
includes
the
Two­
Speed
Idle
(
TSI),
the
On­
Board
Diagnostic
(
OBD)
analyzer
testing
system,
gas
cap
tester
and
2­
D
Bar
Code
scanner.

REFERENCES
U.
S.
Environmental
Protection
Agency,
"
Inspection/
Maintenance
Program
Requirements,"
Final
Rule,
57
Federal
Register
52950
(
November
5,
1992).

5
A
very
conservative
calculation
could
use
the
existing
minimum
wage
rate
for
the
opportunity
cost
of
leisure
time
($
5.15/
hr).
Under
these
assumptions
program
cost
effectiveness
values
increase
by
a
modest
amount
­­
~$
3,000
to
$
5,000
per
ton
of
NOx
+
VOC.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
11
U.
S.
Environmental
Protection
Agency,
"
I/
M
Costs,
Benefits,
and
Impacts
Analysis,"
Draft,
February
1992.
ERG,
Inc.,
Technical
Support
Documentation:
Emission
Control
Strategy
Evaluation
for
the
Austin/
San
Marcos
(
A/
SM)
MSA
EAC
Clean
Air
Action
Plan
(
CAAP),
January
26,
2004
4.2.2
Idling
Restrictions
on
Heavy­
Duty
Diesel
Engines
(
A2)

SOURCE
TYPE
AFFECTED
Owners
and
operators
of
heavy­
duty
diesel
vehicles,
MSA
county
and
municipality
law
enforcement
agencies
or
designees
are
affected
by
this
measure.

CONTROL
STRATEGY
This
measure
restricts
engine
idling
of
vehicles
with
a
gross
vehicle
weight
rating
of
more
than
14,000
pounds
to
five
consecutive
minutes.
Exemptions
are
allowed
for
vehicles
with
a
gross
vehicle
weight
rating
of
14,000
pounds
or
less;
that
are
forced
to
remain
motionless
because
of
traffic
conditions
over
which
the
operator
has
no
control;

are
being
used
as
an
emergency
or
law
enforcement
vehicle;
when
the
engine
operation
is
providing
power
for
a
mechanical
operation
other
than
propulsion;
when
engine
operation
is
providing
power
for
multiple
passenger
heating
or
air
conditioning
while
occupied
by
passengers;
when
the
engine
is
being
operated
for
maintenance
or
diagnostic
purposes,
or
when
the
engine
is
being
operated
solely
to
defrost
a
windshield.

Alternative
methods
of
providing
power
to
the
vehicle
are
currently
available.
Truck
stop
electrification
allows
the
vehicle
operator
to
access
electricity
as
a
power
source.
Small
generators,
which
emit
less
and
are
commercially
available,
can
be
used
as
auxiliary
power
sources.

IMPLEMENTATION
This
measure
will
apply
throughout
the
MSA.
To
implement
this
measure,
the
MSA
requests
TCEQ
adopt
the
measure
through
rulemaking
applicable
in
the
MSA
and
authorize
MSA
county
and
municipality
law
enforcement
agencies,
or
other
county
and
municipality
entities,
to
enforce
the
measure.
The
plan
must
be
implemented
no
later
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
12
than
December
31,
2005.
In
the
event
TCEQ
designates
program
responsibility
to
a
local
entity,
the
TCEQ
and
EPA
will
make
every
reasonable
effort
to
provide
adequate
funding
for
program
administration.

ESTIMATED
EMISSION
REDUCTION
ERG
used
a
methodology
previously
developed
for
the
TNRCC
(
now
TCEQ)
to
estimate
NOx
emission
reductions
from
such
a
rule
in
the
Houston
area.
6
Following
this
methodology,
to
calculate
fleet
idle
emissions
for
Heavy­
duty
diesel
vehicles
(
HDDV)
and
heavy­
duty
gasoline
vehicles
(
HDGV)
in
the
five­
county
Austin
area
it
was
necessary
to
first
obtain
the
number
of
vehicles
in
each
county,
as
well
as
to
estimate
the
average
vehicle
idle
time
for
each
county.
Average
vehicle
idle
time
was
estimated
by
using
a
SAS
program
that
read
in
mileage
accumulation
rates
(
MAR),
by
age,
from
the
MOBILE6.2
default
values.
For
both
HDDV
and
HDGV
vehicles,
an
average
MAR
was
calculated
using
data
from
each
of
the
eight
applicable
MOBILE6.2
vehicle
types.
The
program
also
read
in
registration
distribution
data
for
each
county
from
TxDOT
records,
and
weighted
the
distribution
using
county
VMT
data
obtained
from
TTI.

For
each
county,
average
MARs
were
ratioed
by
the
registration
data
and
summed
to
obtain
an
annual
mileage
accumulation
rate
by
vehicle
age,
which
in
turned
was
used
to
calculate
average
VMT
per
day.
Using
the
average
VMT
per
day
and
the
average
speed
(
also
read
in
from
the
TTI
data),
the
average
run
time
per
vehicle
was
deduced.
The
average
idle
time
was
assumed
to
be
25%
of
the
average
run
time
for
diesels,
and
23%

for
gas
vehicles,
based
on
heavy­
duty
engine
certification
cycles
(
see
ERG
Memo
to
TNRCC).
Finally
the
number
of
vehicles
in
each
county
was
obtained
by
dividing
the
total
fleet
VMT
(
obtained
from
TTI
data)
by
the
average
VMT
per
day
calculated
above.

6
ERG
Memo
to
Hazel
Barbour,
Texas
Natural
Resource
Conservation
Commission
Re:
Determination
of
NOx
Benefits
from
Proposed
Idle
Shut­
Off
Rule,
February
2001.
Estimates
were
included
in
the
latest
HGA
SIP
revision.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
13
Idle
emission
factors
(
g/
mi)
were
then
obtained
from
MOBILE6.2
output.
7
An
average
idle
speed
of
3.1
mph
(
per
model
defaults)
was
used
to
convert
the
idle
emission
factor
to
g/
hr.
This
value,
along
with
the
number
of
vehicles
in
each
county
and
their
appropriate
average
idle
time
were
used
to
calculate
fleet
idle
emissions.
Note
that
two
idle
events
per
day
were
assumed
for
the
purposes
of
the
calculation.
The
output
from
the
intermediate
and
final
calculation
steps
are
summarized
in
the
tables
below.

Vehicle
Type
County
Group
Avg
Vehicle
Speed*
(
mph)
Avg
VMT/
day
Avg
Run
Time
(
minutes)
Avg
Idle
Time
(
minutes)

Bastrop
39.6
129.4
196.06
49.02
Caldwell
41.1
130.1
189.93
47.48
Hays
44.2
131.9
179.05
44.76
Travis
35.9
131.6
219.94
54.99
HDDV
Williamson
43.7
131.1
180.00
45.00
Bastrop
39.6
54.06
81.91
18.84
Caldwell
41.1
54.06
78.92
18.15
Hays
44.2
54.06
73.38
16.88
Travis
35.9
54.06
90.35
20.78
HDGV
Williamson
43.7
54.06
74.22
17.07
Table
4­
3.
Run
and
Idle
Time
Derivation
*
From
TTI
Vehicle
Type
County
Group
Total
Fleet
VMT^
(
mi/
day)
Avg
VMT/
day
VMT
Fraction*
Number
of
Vehicles
Bastrop
133,043
129.4
1.000
1,028
Caldwell
69,365
130.1
1.000
533
Hays
311,744
131.9
0.431
1,019
Travis
2,171,524
131.6
0.820
13,531
HDDV
Williamson
678,264
131.1
0.733
3,792
Bastrop
33,727
54.06
1.000
624
Caldwell
16,773
54.06
1.000
310
Hays
65,220
54.06
0.520
627
Travis
464,313
54.06
0.851
7,309
HDGV
Williamson
151,015
54.06
0.788
2,201
Table
4­
4.
Estimation
of
Heavy­
Duty
Fleet
Size
^
From
TTI
Note:
VMT
fraction
reduced
to
account
for
IH
35
pass­
through
traffic
(
no
idle
time
anticipated
 
extended
Class
8
idle
events
excluded
from
analysis)

7
Unlike
MOBILE5b,
MOBILE6
does
not
provide
explicit
idle
emission
factors
in
grams
per
hour.
EPA
guidance
suggests
using
the
emission
rate
for
the
lowest
speed
bin
available,
and
converting
to
g/
hr.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
14
An
assumed
rule
penetration
of
100%
and
effectiveness
of
80%
(
per
TCEQ)
were
used
to
calculate
the
reductions
shown
in
Table
4­
5.

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
NOx
Emissions
(
tpd)
2007
Controlled
NOx
Emissions
(
tpd)
Net
NOx
Reduction
(
tpd)
Percent
Reduction
(%)

ONROAD
MOBILE:
Heavy
Duty
Diesel
&
Gas
Trucks
(
HDV
)
Idling
Restrictions
Austin­
Round
Rock
MSA
(
5
Counties)
31.82
31.63
0.19
0.6%

Table
4­
5.
Idling
Restrictions
NOx
Emission
Reduction
ESTIMATED
COST
At
this
time
we
do
not
have
a
cost
estimate.
However,
the
measure
will
result
in
fuel
savings.

REFERENCES
ERG,
Inc.,
Technical
Support
documentation:
Emission
Control
Strategy
Evaluation
for
the
Austin/
San
Marcos
(
A/
SM)
MSA
EAC
Clean
Air
Action
Plan
(
CAAP),
February
17,
2004
4.2.3
Commute
Emission
Reduction
Program
(
A3)

SOURCE
TYPE
AFFECTED
All
employers
with
200
or
more
employees
per
location
throughout
the
MSA,
TCEQ
(
or
its
designated
local
agent),
Clean
Air
Partners
Program,
CAMPO
Commute
Solutions
Program,
CAPCO.

CONTROL
STRATEGY
The
Commute
Emission
Reduction
Program
requires
every
existing
or
future
employer
with
200
or
more
employees
per
location
to
submit
a
detailed
plan
to
TCEQ
or
local
designee
that
demonstrates
how
the
employer
will
reduce
the
equivalent
of
their
NOx
and
VOC
commute
related
emissions
by
10%.
The
10%
reduction
requirement
may
be
met
by
reducing
emissions
at
least
3%
per
year
until
the
10%
reduction
is
achieved.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
15
Employers
may
choose
to
reduce
commute
or
any
other
business
related
emissions
that
occur
at
the
location
with
200
or
more
employees
as
long
as
the
aggregate
emissions
reductions
are
equivalent
to
10%
of
their
commute
related
emissions
for
NOx
or
VOC.

IMPLEMENTATION
To
implement
this
measure
the
MSA
requests
that
TCEQ
adopt
a
rule
applying
this
measure
in
the
MSA.
TCEQ
or
their
local
designee
will
be
responsible
for
implementation
and
enforcement
of
the
program.
The
plan
must
be
implemented
no
later
than
December
31,
2005.

Commute
related
emissions
may
be
calculated
using
a
baseline
of
the
annual
average
number
of
employees
at
that
location
in
2003,
2004
or
the
expected
annual
average
number
of
employees
for
a
new
employer
location
and
assuming
all
employees
drove
to
work
alone.
The
annual
average
number
of
employees
multiplied
by
the
average
round
trip
commute
(
22.6
miles)
equals
the
number
of
employee
miles
traveled.
Employee
miles
traveled
multiplied
by
the
MSA's
commute
MOBILE6
emission
factors
for
VOC
and
NOx
equals
the
VOC
and
NOx
commute
emissions.
The
MOBILE6
emission
factors
may
be
for
the
analysis
year,
2007
or
any
other
year
deemed
appropriate
by
the
TCEQ.

The
MSA
average
round
trip
commute
mileage
may
be
used
or
an
employer
may
choose
to
use
employee
specific
round
trip
commute
mileage.
A
calculation
guidance
packet,

including
emission
factors
will
be
developed
and
made
available
to
employers.

The
plan
will
include
details
on
how
the
commute
related
emissions
were
calculated,
how
and
when
the
10%
of
total
VOC
and
NOx
reductions
will
be
achieved,
as
well
as
how
the
reductions
will
be
maintained
over
time.
Alternative
plans
that
detail
either
how
the
employer
will
achieve
and
maintain
a
verifiable
employee
commuter
average
vehicle
occupancy
(
AVO)
of
1.2
or
achieve
and
maintain
verifiable
participation
in
the
Clean
Air
Partners
Program
at
a
10%
reduction
level
will
also
be
accepted.

All
employers
with
200
or
more
employees
at
a
single
location
will
register
with
TCEQ
or
local
designee
by
December
31,
2004
or
within
60
days
of
beginning
operations
for
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
16
new
locations.
All
plans
must
be
submitted
to
TCEQ
or
local
designee
by
March
31,

2005
or
within
120
days
of
beginning
operations
for
new
locations.
TCEQ
or
local
designee
will
approve
all
plans,
or
inform
the
employer
of
any
plan
deficiencies
by
July
31,
2005
or
within
4
months
of
plan
submittal
for
new
locations.
In
the
event
that
plan
deficiencies
occur,
employers
will
have
60
days
from
the
date
of
notification
of
such
deficiencies
to
revise
and
resubmit
their
plans.
TCEQ
or
local
designee
will
approve
or
reject
the
revised
plan
within
30
days
from
the
date
of
re­
submittal.

Employers
will
report
on
the
plan's
implementation
and
results
semi­
annually
in
conjunction
with
the
MSA's
EAC
semi­
annual
report.
Reporting
periods
are
May
1
through
October
31
and
November
1
through
April
30.
Copies
of
the
Commute
Emission
Reduction
Program
report
are
due
to
TCEQ
or
local
designee
and
CAPCO
by
November
30th
and
May
31st
respectively.
In
the
event
that
the
semi­
annual
reports
indicate
that
the
planned
emission
reductions
are
not
being
achieved
and
maintained,
TCEQ
or
local
designee
may
request
that
the
employer
revise
their
plan
accordingly.

In
the
event
TCEQ
designates
program
responsibility
to
a
local
entity,
the
TCEQ
and
EPA
will
make
every
reasonable
effort
to
provide
adequate
funding
for
program
administration.
Both
the
Clean
Air
Partners
Program
and
the
CAMPO
Commute
Solutions
Program
provide
free
tools
and
information
that
may
be
useful
in
complying
with
this
measure.
The
Commute
Solutions
Program
provides
employee
transportation
coordinator
training
and
Commute
Solutions
Fairs
for
alternatives
to
drive­
alone
commutes,
while
Clean
Air
Partners
provides
tools,
expertise
and
experiences
of
member
employers.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
17
ESTIMATED
EMISSION
REDUCTION
Expected
reductions
from
this
measure
are
0.27
tons
per
day
NOx
and
0.30
tons
per
day
VOC
(
Table
4­
6
and
Table
4­
7).
An
assumed
rule
penetration
of
100%
and
effectiveness
of
80%
were
used
to
calculate
the
reduction.
Some
workday
rush
hour
congestion
may
be
reduced
if
employers
select
and
implement
commute
emission
reduction
measures.

The
measure
will
also
encourage
business
practices
that
improve
air
quality.

Table
4­
6.
Commute
Program
NOx
Emission
Reduction
Table
4­
7.
Commute
Program
VOC
Emission
Reduction
ESTIMATED
COST
At
this
time
we
do
not
have
a
cost
estimate.
Administrative
costs
to
employers
and
the
Clean
Air
Partners
will
vary
according
to
the
participation
level.
However,
the
measure
will
result
in
fuel
savings.

REFERENCES
Commute
Solutions
www.
commutesolutions.
com
Clean
Air
Partners
www.
cleanairpartnerstx.
org
Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
NOx
Emissions
(
tpd)
2007
Controlled
NOx
Emissions
(
tpd)
Net
NOx
Reduction
(
tpd)
Percent
Reduction
(%)
ONROAD
MOBILE:
Light
Duty
Vehicles
(
LDV)
Commute
Emission
Reduction
Program
Austin­
Round
Rock
MSA
(
5
Counties)
30.29
30.02
0.27
0.9%

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
VOC
Reduction
(
tpd)
Percent
Reduction
(%)
ONROAD
MOBILE:
Light
Duty
Vehicles
(
LDV)
Commute
Emission
Reduction
Program
Austin­
Round
Rock
MSA
(
5
Counties)
31.55
31.25
0.3
1.0%
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
18
4.2.4
Low
Emission
Gas
Cans
(
A4)

Portable
gasoline
containers,
usually
called
"
gas
cans,"
can
be
a
significant
source
of
urban
air
emissions.
The
emissions
arise
from
containers
that
spill,
leak,
and/
or
allow
permeation,
and
are
measured
as
volatile
organic
compounds
(
VOC).

SOURCE
TYPE
AFFECTED
Residential
and
commercial
lawn
and
garden
users
of
gas
cans
will
be
affected
by
this
measure.
Recreational
vehicles
(
e.
g.,
all­
terrain
vehicles
and
off­
road
motorcycles,
and
recreational
marine
vehicles)
are
included
in
a
limited
capacity.

CONTROL
STRATEGY
A
mandate
that
all
new
gas
containers
purchased
in
the
region
meet
spill­
proof,
low
emission
standards
is
suggested.
While
we
have
a
fairly
good
grasp
of
emissions
from
refueling
motor
vehicles,
gas
can
emissions
are
highly
uncertain
at
this
time.
The
California
Air
Resources
Board
(
CARB)
was
instrumental
in
developing
a
methodology
to
quantify
emissions
from
gas
cans,
and
now
several
states
including
Texas
are
considering
using
the
CARB
method
to
help
determine
the
need
for
a
"
no­
spill"
gas
can
regulation.

Historically,
gas
can
emissions
were
part
of
the
emissions
inventory
for
non­
road
equipment
such
as
lawn
mowers,
chainsaws,
trimmers
("
weed
whackers"),
and
other
portable
power
equipment.
The
1992
Non­
Road
Equipment
and
Vehicle
Emissions
Study
(
NEVES)
8
considered
refueling
emissions
as
a
function
of
gasoline
consumption,

and
included
algorithms
for
spillage
and
vapor
displacement.
The
draft
NONROAD
model9
has
the
same
algorithms,
which
are
used
to
estimate
this
part
of
the
VOC
emissions
inventory.
A
major
improvement
in
the
NONROAD
model
over
the
NEVES
was
to
separate
commercial
and
residential
equipment,
as
commercial
equipment
tend
to
be
used
during
the
week
and
residential
equipment,
which
are
more
numerous
in
terms
of
numbers
of
engines,
tend
to
be
used
fewer
hours,
mainly
on
the
weekends.
Therefore,
we
8
U.
S.
EPA.
1991.
Nonroad
Engine
and
Vehicle
Emission
Study
 
Report.
EPA­
460/
3­
91­
02.
9
http://
www.
epa.
gov/
otaq/
nonrdmdl.
htm
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
19
have
adapted
our
surveys
and
methods
to
include
commercial
and
residential
gas
can
emissions
separately.

The
main
emphasis
of
this
research
is
on
lawn
and
garden
uses
of
gas
cans.
Lawn
and
garden
is
the
largest
category
in
the
NONROAD
model
that
is
refueled
entirely
by
gas
cans.
Recreational
vehicles
(
e.
g.,
all­
terrain
vehicles
and
off­
road
motorcycles)
are
also
refueled
by
gas
cans,
but
their
usage
is
not
nearly
as
high
as
that
for
lawn
and
garden
equipment.
Recreational
marine
engines
(
e.
g.,
outboard
motorboats
and
personal
watercraft)
can
be
refueled
by
portable
gasoline
containers,
but
pressurized
marine
gas
tanks
are
much
more
common
than
the
ubiquitous
"
gas
can."
Finally,
some
construction,

commercial,
agricultural
and
logging
equipment
may
be
refueled
with
gas
cans,
but
NONROAD
assumes
that
these
types
of
equipment
are
all
refueled
at
the
gas
pump.
10
Future
updates
to
this
analysis
could
include
a
small
expansion
factor
to
account
for
gasoline
container
emissions
from
these
other
source
categories.

IMPLEMENTATION
Preferably
state
rule,
developed
by
TCEQ,
applicable
in
all
five
counties.
It
is
recommended
that
TCEQ
implement
the
measure
in
the
eastern
half
of
the
state
no
later
than
December
31st
2005.

The
TCEQ
is
considering
a
rule
that
would
phase­
in
new
gas
cans
by
effectively
eliminating
most
of
the
gas
cans
in
the
"
open"
condition,
eliminating
refueling
(
but
not
transport)
spillage,
and
reducing
many
of
the
remaining
categories
such
as
permeation
because
of
new
gas
can
design
parameters.
Presumably,
such
a
gas
can
rule
would
apply
to
sales
of
new
containers.
Therefore,
we
estimated
the
useful
life
of
a
gas
can
to
be
four
years,
using
the
CARB
default.
If
a
rule
were
implemented
in
2003,
it
would
take
until
2008
for
the
existing
gas
cans
to
be
replaced
by
gas
cans
of
the
new
design.

10
U.
S.
EPA.
1998.
Refueling
Emissions
for
Nonroad
Engine
Modeling.
Report
No.
NR­
013
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
20
Using
the
NONROAD
age
distribution
curve,
we
estimated
that
approximately
94
percent
of
the
gas
cans
would
be
replaced
by
the
2007
ozone
season.
This
estimate
is
consistent
with
the
Commercial
survey
finding
that
40%
of
businesses
plan
to
replace
some
or
all
of
their
current
containers
in
the
next
year.
In
addition,
the
residential
survey
found
that
14%
of
these
cans
had
been
replaced
during
the
previous
year.
Assuming
linear
attrition
rates,
this
translates
to
a
7­
year
turnover
cycle
for
these
cans
as
well
(
e.
g.,

2003
through
2009).
However,
to
the
extent
that
residential
gas
can
attrition
is
non­
linear
(
as
is
the
case
with
most
dynamic
populations),
potential
benefits
from
a
gas
can
rule
would
be
diminished
somewhat.
11
The
next
step
is
to
apply
reduction
estimates
to
the
uncontrolled
2007
emissions.
Any
reductions
would
be
"
negative
emissions"
that
could
be
attributed
to
the
effect
of
the
TCEQ
rule
 
and
ultimately
applied
as
potential
State
Implementation
Plan
credits.

CARB
estimated
percentage
reductions
for
all
five
categories
of
gas
can
emissions.
12
Although
we
do
not
know
the
content
of
a
new
gas
can
rule
to
be
adopted
in
Texas,
if
approved,
we
can
make
some
educated
guesses
about
the
efficiency
of
such
as
"
Gas
Can
Rule."
After
careful
consideration,
we
applied
rule
penetration
(
RP)
and
rule
effectiveness
(
RE)
to
the
CARB
reduction
estimates,
expressed
as
control
efficiency
(
CE),
as
follows:

Reduction
(%)
=
CARB
(
CE)
*
RE
*
RP
Equation
1
The
RP
adjusts
reductions
slightly
lower
because
the
rule
may
not
apply
to
100
percent
of
the
new
gas
can
sales,
and
is
probably
more
like
90
percent.
The
RE
is
an
adjustment
that
says
that
the
rule
might
only
be
followed
80
percent
of
the
time.
The
product
of
RP
and
RE
is
72
percent;
this
factor
was
then
applied
to
the
CARB
reduction
estimates
where
deemed
to
be
appropriate.
These
kinds
of
adjustments
are
typical
when
dealing
with
the
U.
S.
Environmental
Protection
Agency.
Table
4­
8
includes
the
assumptions
that
11
It
would
require
multiple
years
of
retirement
data
to
generate
a
more
realistic
scrappage
curve,
however.
12
CARB,
1999.
"
Initial
Statement
of
Reasons
for
Proposed
Rule
Making:
Public
Hearing
to
Consider
the
Adoption
of
Portable
Fuel
Container
Spillage
Control
Regulations."
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
21
include
the
default,
stated
CARB
reductions,
which
were
then
modified
by
applying
rule
effectiveness
and
rule
penetration.

Emission
Type
Total
Emissions
Percent
Reductions
­
California
Percent
Reductions
­
Texas
Reductions
(
Tons
per
day
of
VOC)

Diurnal
52.55
70.0%
50.4%
24.94
Transport
Spillage
5.75
100.0%
0.0%
0.00
Refueling
Spillage
9.89
100.0%
72.0%
6.71
Displacement
3.40
40.0%
0.0%
0.00
Total
77.69
34.72
Table
4­
8.
2007
State
Emission
Reductions
Note
that
potential
reductions
were
not
applied
to
two
sources:
transport
spillage
and
valor
displacement.
This
decision
was
not
based
on
actual
testing
but
rather
because
common
sense
dictates
that
a
no­
spill
gas
can
would
still
have
emissions
during
refueling
operations
(
the
effect
on
vehicles
in
transit
is
not
clear,
either).
It
is
quite
possible
that
CARB
also
over­
predicted
diurnal
emission
reduction
percentages,
but
there
is
no
evidence
to
dispute
these
claims
at
this
time.

EXPECTED
EMISSIONS
REDUCTIONS
Based
on
a
total
of
13.4
tons
per
day
in
the
MSA,
the
potential
reductions
add
up
to
2.6
tons
per
day
(
Table
4­
9).
There
may
be
more
(
or
less)
reductions
depending
on
how
the
envisioned
gas
can
rule
is
written
and
implemented.
This
analysis
evaluated
the
potential
VOC
reductions
resulting
from
adoption
of
TCEQ's
draft
Portable
Fuel
Container
rule.

The
proposed
rule
assumes
that
replacement
containers
would
meet
CARB
standards.

ERG
used
the
statewide
emission
reduction
estimates
previously
developed
in
support
of
TCEQ's
rulemaking
effort
to
estimate
potential
reductions
in
the
five­
county
area.
13
This
analysis
provided
county­
level
baseline
emissions
estimates
for
2007.
For
the
five­

13
ERG,
"
Emissions
from
Portable
Gasoline
Containers
in
Texas,"
Final
Report,
prepared
for
TRNCC,
August
30,
2002.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
22
county
area
this
comes
to
1.01
tons
per
typical
ozone
season
weekday
for
commercial
uses,
and
4.18
tons
per
day
for
residential
uses.

The
prior
report
also
estimated
that
replacement
cans
meeting
new
rule
requirements
would
result
in
an
overall
reduction
of
62.4%
per
unit.
Recent
survey
results
indicated
that
commercial
users
replace
their
gas
cans
almost
annually.
14
And
EPA's
NONROAD
emission
factor
model
indicates
a
4
year
turnover
cycle
for
residential
gas
cans.
So
assuming
that
such
a
rule
is
adopted
in
early
2004,
essentially
all
portable
gas
cans
will
be
replaced
by
the
2007
evaluation
period,
resulting
in
a
reduction
of
0.63
tons
per
day
from
commercial
uses,
and
1.97
tons
per
day
for
residential
uses
(
2.60
tons
of
VOC
per
day
total).

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
VOC
Reduction
(
tpd)
Percent
Reduction
(%)
AREA
SOURCES:
Lawn
and
Garden
Equipment
(
Commercial&
Residential)
Low
Emission
Gas
Cans
Austin­
Round
Rock
MSA
(
5
Counties)
13.40
10.80
2.60
19.4%

Table
4­
9.
Low
Emission
Gas
Can
VOC
emission
reduction
COSTS
Costs
for
the
program
were
estimated
assuming
an
$
11
incremental
price
for
the
larger
commercial
cans,
and
$
8
for
residential
cans,
as
per
the
CARB
Rulemaking
documentation.
The
total
number
of
effected
commercial
companies
was
determined
from
Texas
Comptroller
records
for
lawn
and
garden
services
in
the
region
(
734
as
of
2002).
The
previous
ERG
survey
for
TCEQ
also
found
that
the
average
number
of
gas
cans
owned
by
commercial
interests
was
10.5.
These
data
were
combined
to
estimate
a
total
annual
incremental
cost
of
$
84,777
per
year,
and
a
cost­
effectiveness
of
$
368
per
ton
for
commercial
gas
can
use.

For
residential
uses
ERG
found
that
each
single­
family
household
(
number
obtained
from
Census
data)
would
own
1.35
portable
gas
cans
on
average.
Accounting
for
turnover
rates,
incremental
costs,
and
the
number
of
households
in
the
region,
we
estimate
an
14
Personal
communication
with
Marilyn
Good,
Texas
Nursery
and
Landscape
Association,
August
2002.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
23
annual
cost
of
$
1,363,890
(
4­
year
annualized
cost),
and
a
cost­
effectiveness
of
$
1,899/
ton
of
VOC
for
the
residential
sector.

REFERENCE
ERG,
Inc.,
Technical
Support
Documentation:
Emission
control
Strategy
Evaluation
for
the
Austin/
San
Marcos
(
A/
SM)
MSA
EAC
Clean
Air
Action
Plan
(
CAAP),
February
17th,
2004
4.2.5
Stage
1
Vapor
Recovery
Requirement
Change
(
A5)

SOURCE
TYPE
AFFECTED
Service
stations
that
pump
over
25,000
gallons
of
fuel
per
month
and
fuel
dispensing
facilities
in
the
MSA
will
be
affected
by
this
measure.

CONTROL
STRATEGY
Stage
I
vapor
recovery
is
already
in
place
in
the
Austin
region
for
service
stations
that
pump
over
125,000
gallons
of
fuel
per
month.
This
measure
would
require
Stage
I
on
service
stations
pumping
25,000
gallons
per
month,
thus
increasing
the
number
of
service
stations
using
the
system.
Stage
I
reduces
VOC
emissions
during
fuel
transfer
from
the
tanker
truck
to
the
underground
storage
tank
through
a
special
vapor
recovery
system.

IMPLEMENTATION
Preferably
a
modification
to
state
rule
30
TAC
115,
Subchapter
C,
Division
2
Filling
of
Gasoline
Storage
Vessels
(
Stage
1)
for
Motor
Vehicle
Fuel
Dispensing
Facilities,

developed
by
TCEQ,
applicable
in
all
five
counties.
The
plan
must
be
implemented
no
later
than
December
31,
2005.

Within
the
A/
RR
MSA
there
are
approximately
41
sites
(
94
tanks)
that
are
not
equipped
with
Stage
1
Vapor
Recovery
equipment.
This
is
only
10%
or
less
of
the
total.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
24
Table
4­
10.
Gasoline
station
throughput
EXPECTED
EMISSION
REDUCTION
The
Stage
I
Vapor
recovery
control
has
a
potential
of
4.88
tpd
VOC
reductions
(
assuming
participation
in
all
five
counties).
A
Stage
I
control
efficiency
of
95%
(
EPA
453/
R­
94­

002a
/
Stage
I
NESHAP),
rule
penetration
of
64.4%,
and
rule
effectiveness
(
RE)
of
80%

was
assumed.
The
MSA
gasoline
sales
shown
in
Table
4­
10
were
used
to
derive
rule
penetration
(
RP)
as
presented
in
Table
4­
11.
The
expected
emission
reductions
from
Stage
I
Vapor
recovery
control
are
presented
for
each
county
by
percentage
in
Table
4­
12
and
in
tons
per
day
in
Table
4­
13.

Table
4­
11.
Stage
I
Rule
penetration
for
gas
stations
Table
4­
12.
Expected
emission
reduction
from
Stage
I
Vapor
recovery
control
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
25
Table
4­
13.
Stage
I
controls
VOC
reductions
by
County
ESTIMATED
COST
To
estimate
costs,
ERG
used
estimates
developed
for
TNRCC's
1999
Stage
I
RACT
analysis.
Key
costs
include
purchase
and
installation
of
Stage
I
equipment
($
1,750/
station
 
high
end
estimate),
and
annual
operating
costs
per
station
($
368
 
high
end
estimate).
Next,
these
unit
costs
were
combined
with
data
from
the
TCEQ's
PST
database
to
obtain
area­
wide
costs.
15
The
following
presents
the
estimated
number
of
gasoline
storage
tanks
in
each
county,
derived
from
the
PST
database.
The
database
also
provided
a
field
indicating
if
a
particular
tank
was
equipped
for
Stage
I
recovery
(
Table
4­
14).
16
County
Total
Without
Stage
I
Bastrop
201
137
Caldwell
108
74
Hays
235
130
Travis
1,736
1,080
Williamson
596
330
Table
4­
14.
Number
of
Retail
Gasoline
Tanks
and
Stage
I
Units
by
County
(
2003)

Using
the
average
number
of
tanks
per
station
without
Stage
I
equipment
(
4.0
­­
from
the
PST
database),
and
the
number
of
stations
by
throughput
presented
above,
the
target
number
of
tanks
was
determined,
as
shown
below
(
Table
4­
15).

15
http://
www.
tnrcc.
state.
tx.
us/
permitting/
r_
e/
par/
pstregis/
pstregisquery2.
html.
16
Recent
data
indicate
that
the
number
of
tanks
equipped
with
Stage
I
equipment
may
be
even
higher,
(
upwards
of
90%),
thereby
lowering
costs
and
improving
cost­
effectiveness
even
further
 
personal
communication,
Scott
Johnson,
1­
27­
04.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
26
gal/
mo
Bastrop
Caldwell
Hays
Travis
Williamson
<
9,999
3
2
3
22
7
10,000
­
24,999
21
11
20
165
50
25,000
­
49,999
42
23
40
335
102
50,000
­
124,999
71
38
67
558
170
Table
4­
15.
Number
of
Tanks
Without
Stage
I
Capability,
by
Throughput
Using
these
figures,
annual
costs
were
then
calculated.
Initial
capital
and
installation
costs
were
annualized
over
a
5­
year
period
at
10%
for
this
purpose.
Annual
costs
by
throughput
category
are
presented
below
(
Table
4­
16).

gal/
mo
Bastrop
Caldwell
Hays
Travis
Williamson
<
9,999
$
2,489
$
1,659
$
2,489
$
18,252
$
5,808
10,000
­
24,999
$
17,423
$
9,126
$
16,593
$
136,892
$
41,482
25,000
­
49,999
$
34,845
$
19,082
$
33,186
$
277,931
$
84,624
50,000
­
124,999
$
58,905
$
31,527
$
55,586
$
462,942
$
141,040
Total
$
113,661
$
61,394
$
107,854
$
896,017
$
272,953
Table
4­
16.
Annual
Costs
by
Throughput
Cost­
effectiveness
was
then
determined
for
cumulative
costs
and
benefits
for
the
different
rule
cut­
off
levels,
as
on
Table
4­
17.

Cut­
Off
Bastrop
Caldwell
Hays
Travis
Williamson
MSA
Average
all
$
1,501
$
1,477
$
822
$
910
$
812
$
925
>
10,000
$
1,473
$
1,438
$
805
$
894
$
797
$
908
>
25,000
$
1,305
$
1,267
$
709
$
790
$
705
$
803
>
50,000
$
1,028
$
986
$
555
$
621
$
554
$
630
Table
4­
17.
Cost­
Effectiveness
by
Rule
Cut­
Off
Level
($/
Ton
VOC)

REFERENCES
Title
30,
Part
1,
Chapter
115,
Subchapter
C,
Division
2
Filling
Of
Gasoline
Storage
Vessels
(
Stage
I)
For
Motor
Vehicle
Fuel
Dispensing
Facilities,
§
115.227
Exemptions
ERG,
Inc.,
Technical
Support
Documentation:
Emission
control
Strategy
Evaluation
for
the
Austin/
San
Marcos
(
A/
SM)
MSA
EAC
Clean
Air
Action
Plan
(
CAAP),
February
17th,
2004
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
27
4.2.6
Degreasing
Controls
(
A6)

A
degreaser
is
any
equipment
designed
and
used
for
holding
a
solvent
to
carry
out
solvent
cleaning
operations
including,
but
not
limited
to,
batch­
loaded
cold
cleaners,

open­
top
vapor
degreasers,
conveyorized
(
in­
line)
degreasers,
and
air­
tight
and
airless
cleaning
systems.
Solvent
cleaning
machines
are
used
to
dry
materials
and
remove
soils,

such
as
grease,
wax,
and
oil
from
metal
parts,
circuit
boards,
sheet
metal,
assemblies,
and
other
materials.
Emissions
of
VOC
primarily
result
from
air/
solvent
interface
losses
(
e.
g.,
evaporation
and
subsequent
release
from
the
machine)
and
workload
losses
(
e.
g.,

carry­
out
of
solvent
on
parts).

SOURCE
TYPE
AFFECTED
The
metalworking
industries
are
the
major
users
of
solvent
degreasing.
These
include
automotive,
electronics,
plumbing,
aircraft,
refrigeration,
and
business
machine
industries.
The
printing,
chemical,
plastics,
rubber,
textiles,
glass,
paper,
and
electric
power
industries
also
use
solvent
degreasing
operations.
This
category
does
not
include
dry
cleaning.

CONTROL
STRATEGY
Cold
cleaning
was
the
largest
degreasing
emissions
in
the
inventory
and
the
one
we
targeted.
In
cold
cleaning,
the
part
is
dipped
into
or
sprayed
with
solvent.
To
reduce
the
amount
of
solvent
evaporation,
control
requirements
including
equipment
and
operating
procedures
shall
be
required.

IMPLEMENTATION
Under
30
TAC
106.454
Degreasing
Units,
anyone
obtaining
a
state
air
permit
for
a
degreasing
unit
is
required
to
meet
with
§
115.412
and
§
115.415
as
of
November
1st,

2001.
It
is
requested
that
TCEQ
extend
state
rule
30
TAC
115,
Subchapter
E,
Division
1,

§
§
11.412,
115.413,
115.415­.
417,
117.419
to
the
Austin/
Round
Rock
MSA.
Therefore
the
extension
of
this
rule
would
only
apply
to
operations
permitted
prior
to
November
1st,

2001.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
28
The
National
Degreasing
rule
(
Halogenated
Solvent
Cleaning
NESHAP)
only
covers
those
degreasers
using
one
of
the
listed
six
halogenated
HAPs
(
methylene
chloride,

perchloroethylene,
trichloroethylene,
1,1,1­
trichloroethane,
carbon
tetrachloride,
and
chloroform).
Therefore,
the
national
rule
does
not
regulate
other
degreasing
solvents
that
may
be
VOCs,
but
not
HAPs.

EXPECTED
REDUCTIONS
It
is
estimated
that
50%
of
the
market
is
in
compliance
with
the
current
rules.
This
was
based
on
the
fact
that
one
large
degreasing
supplier
is
estimated
to
have
50%
of
the
market
in
the
MSA
and
is
in
compliance
with
the
current
rules.
The
remaining
50%

creates
a
potential
for
reduction
from
the
2007
baseline.
Degreasing
controls
are
expected
to
reduce
VOC
emissions
by
6.38
tons
of
VOC
per
day.
An
estimated
control
efficiency
of
85%
(
TCEQ
estimate),
rule
efficiency
of
80%
(
EPA
default),
and
rule
penetration
of
100%
was
used
to
in
this
calculation.
Table
4­
18
presents
the
degreasing
emissions
in
2007.

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
VOC
Reduction
(
tpd)
Percent
Reduction
(%)
AREA
SOURCES:
Degreasing
(
Cold
Cleaning)
SCCs:
2415300000,
2415360000,
2415355000,
2415330000,
2415320000,
2415305000,
2415325000,
2415340000,
2415345000,
2415365000,
2415310000,
2415335000
Degreasing
Reduction
Measures
Austin­
Round
Rock
MSA
(
5
Counties)
9.38
3.00
6.38
68.0%

Table
4­
18.
Cold
Cleaning
Degreasing
VOC
Emission
Reduction
COSTS
At
this
time
we
do
not
have
a
cost
estimate.
However,
the
measure
is
expected
to
save
money
in
transitioning
from
solvent­
based
cleaners
to
aqueous.
There
is
additional
cost
savings
in
reduced
solvent
evaporative
losses.

References
South
Coast
Air
Quality
Management
District
(
SCAQMD),
1997.
Final
Staff
Report
for
Proposed
Amendments
to
Rule
1122
­
Solvent
Degreasers.
June
6,
1997.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
29
SCAQMD,
2002.
South
Coast
Air
Quality
Management
District
Rule
1122
­
Solvent
Degreasers.
Amended
December
6,
2002.

4.2.7
Autobody
Refinishing
Controls
(
A7)

The
autobody
refinishing
category
is
the
repairing
of
worn
or
damaged
automobiles,
light
trucks,
and
other
vehicles,
and
refers
to
any
coating
applications
that
occur
subsequent
to
those
at
original
equipment
manufacturer
(
OEM)
assembly
plants.
The
majority
of
these
operations
occur
at
small
body
shops
that
repair
and
refinish
automobiles.
Emissions
of
VOC
results
from
the
paint
solvents,
thinning
solvents,
and
solvents
used
for
surface
preparation
and
cleanup.

SOURCE
TYPE
AFFECTED
Facilities
performing
autobody
refinishing
operations
are
classified
with
the
Standard
Industrial
Classification
(
SIC)
code
7532
(
establishments
primarily
engaged
in
the
repair
of
automotive
tops,
bodies,
and
interiors,
or
automotive
painting
and
refinishing)
(
EIIP,

2000).

CONTROL
STRATEGY
Adopt
California
Autobody
Refinishing
Control
standards
to
reduce
VOC
emissions
from
this
source
by
45%.
Rule
requires
lowering
the
VOC
content
of
the
products
used,

improving
the
application
technique
so
that
less
coating
is
used
and
controlling
the
use
of
clean­
up
solvents
(
proper
handling
of
gun
cleaning
and
clean­
up
solvents).
Emissions
occur
at
all
three
process
stages
(
surface
preparation,
painting
and
equipment
cleaning)

due
to
evaporation
of
solvents
in
the
primers,
paints
and
other
coatings,
and
in
the
cleaning
solutions.

Lower­
VOC
Coatings
The
South
Coast
Air
Quality
Management
District
(
SCAQMD)
performed
studies
on
the
feasibility
of
using
lower
VOC
content
coatings
than
the
federal
rule.
SCAQMD
determined
that
each
of
the
coating
categories
in
the
Federal
rule
could
be
lowered
to
reduce
overall
VOC
emissions.
They
determined
that
these
lower
VOC
coatings
are
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
30
currently
available
on
the
market
and
compatible
with
existing
coatings.
Table
4­
19
compares
the
VOC
limits
between
the
two
rules.

Coating
Category
VOC
Limits
from
Federal
Rule
(
grams/
liter)
VOC
Limits
from
SCAQMD
(
grams/
liter)

Pretreatment
Wash
Primer
780
600
Primer/
Primer
Surfacer
580
250
Primer
Sealer
550
­

Single/
2­
Stage
Topcoats
600
420
Topcoats
of
3
or
more
stages
630
540
Metallic
Topcoat
­
520
Multi­
colored
topcoats
680
­

Specialty
Coatings
840
­

Table
4­
19.
Comparison
of
VOC
Limits
of
the
Federal
Rule
and
SCAQMD
The
publications
from
U.
S.
EPA
Design
for
the
Environment
and
Office
of
Pollution
Prevention
and
Toxics
described
additional
emission
control
measures.
The
options
included
higher
transfer
efficiency
application
equipment,
automated
equipment
cleaning
and
equipment
maintenance,
work
practices,
and
spray
booths
with
emission
controls.

Application
Equipment
The
two
most
common
coating
application
tools
are
conventional
spray
guns
and
high
volume
low
pressure
(
HVLP)
spray
guns.
In
conventional
spray
guns,
a
low
volume
of
air
is
pressurized
and
forced
through
the
spray
nozzle.
The
paint
or
coating
is
atomized
in
the
air
at
the
nozzle
throat.
Air
is
supplied
by
an
air
compressor
during
spraying
operations.
With
a
conventional
spray
gun,
paints
or
coatings
are
typically
atomized
with
air
pressures
of
approximately
450
kPa
(
65
psig).
The
major
disadvantage
to
conventional
spray
guns
is
the
excessive
spray
mist
and
overspray
fog
due
to
the
high
pressure
used
at
the
nozzle.
This
excessive
overspray
results
in
a
low
transfer
efficiency
(
the
ratio
of
the
amount
of
coating
solids
deposited
onto
the
surface
of
the
coated
part
to
the
total
amount
of
coating
solids
that
exit
the
spray
gun
nozzle).
Studies
have
shown
conventional
spray
gun
transfer
efficiencies
as
low
as
20
percent.
A
low
transfer
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
31
efficiency
results
in
increased
material
usage,
increased
cost,
and
higher
mist
particle
emissions
(
U.
S.
EPA,
2002).

HVLP
spray
guns
use
a
high
volume
of
air
to
atomize
the
coatings
at
a
relatively
low
air
pressure
(
69
kPa
(
10
psig))
at
the
spray
nozzle.
Some
HVLP
spray
guns
are
gravity
assisted,
with
the
paint
cup
above
the
atomization
nozzle,
and
some
are
"
suction"
or
"
siphon
cup"
spray
guns,
with
the
cup
below
the
nozzle.
With
siphon
cup
HVLP
spray
guns,
a
controlled
air
pressure
is
used
to
meter
the
flow
of
paint
into
the
orifice
where
atomization
occurs.
HVLP
spray
guns
typically
have
a
higher
transfer
efficiency
than
conventional
spray
guns
(
e.
g.,
up
to
65
percent),
but
cost
more
to
purchase
(
U.
S.
EPA,

2002).

A
third
type
of
application
tool
is
an
electrostatic
spraying
system.
The
transfer
efficiencies
of
these
systems
are
between
60
and
90percent
and
are
widely
used
in
U.
S.

automotive
assembly
plants.
Air­
powered,
electrostatic
spray
guns
function
in
essentially
the
same
way
as
electrostatic
spray
guns.
Although
transfer
efficiencies
for
powder
spray
guns
are
similar
to
wet
spray
guns,
the
powder
can
be
reused
and
these
systems
can
operate
with
powder
utilization
rates
of
up
to
98
percent.
Neither
of
these
systems
are
practical
for
refinishing
systems;
however,
for
the
following
reasons:
(
1)
prohibitively
high
cost
of
electrostatic
spray
guns,
(
2)
large
amount
of
coating
contained
in
the
hose
connecting
electrostatic
spray
gun
to
pot,
which
must
be
removed
when
changing
colors,

(
3)
high
curing
temperatures
required
for
powder
systems
(
i.
e.,
resulting
in
damage
to
other
vehicle
components),
and
(
4)
grounding
methods
required
for
electrostatic
systems
in
an
OEM
environment
cannot
be
duplicated
for
automobile
refinishing
(
U.
S.
EPA,

1997).

Other
paint
spray
equipment
are
compared
in
Table
4­
20;
however
the
most
commonly
used
application
equipment
for
autobody
refinishing
facilities
are
conventional
and
HVLP
guns
(
U.
S.
EPA,
1997).
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
32
IMPLEMENTATION
Preferably
state
rule,
developed
by
TCEQ,
applicable
in
all
five
counties.
The
plan
must
be
implemented
no
later
than
December
31,
2005.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
33
Table
4­
20.
Comparison
of
Characteristics
of
Paint
Spray
Equipment
for
Automotive
Refinishers
Performance
Characteristics
Type
of
Painting
System
Advantages
Disadvantages
System
Transfer
Efficiency
(%)
Cost
Range
($)
Population
of
Shops
Using
Equipment
Conventional
Low
cost
Low
maintenance
Excellent
material
atomization
Excellent
operator
control
Quick
color
change
capabilities
Coating
can
be
applied
by
syphon
or
under
pressure
Uses
high
volume
of
air
Develops
excessive
spray
dust
and
overspray
fog
Does
not
adapt
to
high
volume
material
output
(
economics
of
scale)

Low
transfer
efficiency
Pressure
fuel
systems
require
high
volumes
of
coatings
20
to
40
up
to
350
Specific
population
data
is
unknown.

Some
states
have
mandated
the
use
of
HVLP
systems
by
automotive
refinishers.

High
Volume
Low
Pressure
Low
blowback
and
spray
fog
Will
apply
high­
viscosity
high
solid
coatings
(
low
VOC
coatings)

Relatively
easy
to
clean
Can
be
used
for
intricate
parts
Good
operator
controls
High
initial
cost
Slower
application
speed
with
some
coatings
Does
not
fully
atomize
some
coatings
Higher
maintenance
costs
Requires
operator
training
At
least
65
500­
1000
64%
of
all
shops
Low
Volume
Low
Pressure
Low
blowback
and
spray
fog
Will
apply
high­
viscosity
high
solid
coatings
Easy
to
clean
Can
be
used
for
intricate
parts
Good
operator
controls
Needs
less
air
compression
then
HVLP
Lower
energy
requirements
High
initial
cost
Slower
application
speed
than
HVLP
Does
not
fully
atomize
some
coatings
Higher
maintenance
costs
Requires
operator
training
Still
relatively
new
to
the
market
At
least
65
500­
1000
Population
data
is
unknown
Powder
Coating
Almost
zero
VOC
emissions
Excess
or
waste
powder
can
often
be
melted
Powder
can
be
applied
to
hot
or
cold
parts
Ideal
for
robotic
application
Applied
in
single
coal
system
Economical
for
long
runs
of
a
few
colors
Generally,
capital
equipment
outlay
is
greater
than
for
conventional
coatings
High
energy
usage
due
to
high
temperature
ovens
Some
powders
require
temperatures
as
high
as
500
°
F
for
curing
Not
suited
for
every
application
(
parts
that
can
not
tolerate
high
temperature
plastics,
rubber,

upholstery)
Up
to
95
5000­
10,000
Population
data
is
unknown
Powder
coating
systems
are
used
primarily
in
OEM
operations.

Source:
U.
S.
EPA,
May
1997.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
34
ESTIMATED
EMISSION
REDUCTION
An
OTAG
Technical
Support
Document
calculated
a
Future
Control
Efficiency
(
FCE)
of
53%
based
on
coatings
reformulation
and
high­
volume,
low­
pressure
(
HVLP)
spray
equipment.
The
limits
set
by
TCEQ
rules
reduce
the
Austin
MSA
emissions
by
45%.

CAPCO
estimated
that
by
2007
emissions
from
autobody
refinishing
would
be
202
tons
per
year.
Therefore,
the
additional
8%
reduction
is
approximately
100
tons
per
year
or
0.05
tpd
(
Table
4­
21).

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
VOC
Reduction
(
tpd)
Percent
Reduction
(%)
AREA
SOURCES:
Autobody
Shops
SCCs:
2401070000,
2401001025
&
2401005000
Autobody
Refinishing
Controls
Austin­
Round
Rock
MSA
(
5
Counties)
0.64
0.59
0.05
8.0%

Table
4­
21.
Autobody
Refinishing
VOC
Emission
Reduction
ESTIMATED
COST
Table
4­
22
below
compares
the
potential
emission
reduction
techniques
and
their
estimated
cost
to
the
facilities.

Potential
Control
Options
Potential
Emissions
Reduction
(%)
Control
Option
Estimated
Cost
1.
Low­
VOC
coating
products
1.
SCAQMD
has
VOC
limits
that
are
about
30%
lower
than
the
federal
rule
1.
The
cost
should
be
low
because
these
coating
are
available
since
the
SCAQMD
facilities
are
using
them
and
should
be
approximately
the
same
cost
as
the
federal
rule
compliant
coatings.

2.
High
Volume
Low
Pressure
(
HVLP)
spray
guns
2.
HVLP
spray
guns
have
>
25%
better
transfer
efficiency
than
conventional
spray
guns
and
result
in
less
VOC
emissions
and
uses
40­
55%
less
coating
than
conventional
spray
guns.
2.
Conventional
guns
are
about
$
350
and
HVLP
guns
are
~$
500.
Use
less
amount
of
coatings.
The
same
air
compressor
can
be
used.

Table
4­
22.
Comparison
of
Control
Options,
Source:
U.
S.
EPA,
2002.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
35
REFERENCES
U.
S.
EPA,
2002.
Design
for
the
Environment
(
DfE).
Isocyanate
and
Volatile
Organic
Compound
Emissions
from
Auto
Refinishing
Facilities
(
Draft
Final)
,
U.
S.
Environmental
Protection
Agency,
Washington,
DC,
September
2002.
U.
S.
EPA,
1997.
Office
of
Pollution
Prevention
and
Toxics
(
OPPT).
Automotive
Refinishing
Industry
Isocyanate
Profile,
U.
S.
Environmental
Protection
Agency,
Washington,
DC,
May
1997
Emission
Inventory
Improvement
Program
(
EIIP),
2000.
Volume
III:
Chapter
13
­
Auto
Body
Refinishing.
Prepared
for:
Area
Sources
Committee
Emission
Inventory
Improvement
Program,
Research
Triangle
Park,
NC.
January
2000.

4.2.8
Cut
Back
Asphalt
(
A8)

SOURCE
TYPE
AFFECTED
Asphalt
Suppliers
and
Paving
Contractors
are
largely
affected
by
this
measure.
The
Texas
Department
of
Transportation
will
also
be
affect
through
their
contracts.

CONTROL
STRATEGY
The
use
of
conventional
cutback
asphalt
containing
VOC
solvents
for
the
paving
of
roadways,
driveways,
or
parking
lots
is
restricted
to
no
more
than
7.0%
of
the
total
annual
volume
averaged
over
a
two­
year
period
of
asphalt
used
by
or
specified
by
any
state,
municipal,
or
county
agency
who
uses
or
specifies
the
type
of
asphalt
application.

When
asphalt
emulsion
is
used
or
produced,
the
maximum
VOC
content
shall
not
exceed
12%
by
weight
or
the
following
limitations,
whichever
is
more
stringent:

A.
0.5%
by
weight
for
seal
coats;

B.
3.0%
by
weight
for
chip
seals
when
dusty
or
dirty
aggregate
is
used;

C.
8.0%
by
weight
for
mixing
with
open
graded
aggregate
with
less
than
1.0%
by
weight
of
dust
or
clay­
like
materials
adhering
to
the
coarse
aggregate
fraction
(
1/
4
inch
in
diameter
or
greater);
and
D.
12%
by
weight
for
mixing
with
dense
graded
aggregate
when
used
to
produce
a
mix
designed
to
have
10%
or
less
voids
when
fully
compacted.

Exemptions:
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
36
1.
asphalt
concrete
made
with
cutback
asphalt,
used
for
patching,
which
is
stored
in
a
long­
life
stockpile
(
longer
than
one­
month
storage);
and
2.
cutback
asphalt
used
solely
as
a
penetrating
prime
coat.

IMPLEMENTATION
This
measure
would
restrict
the
use
of
cut­
back
asphalt
in
the
MSA
through
a
TCEQ
rule
revision
(
Chapter
115,
Subchapter
F,
Division
§
§
115.510,
115.512,
115.513,
115.515
­

115.517,
115.519)
to
include
the
MSA
counties
in
the
requirements
of
these
sections.
The
plan
must
be
implemented
no
later
than
December
31,
2005.

EXPECTED
EMISSION
REDUCTIONS
A
conservative
rule
efficiency
of
80%
and
rule
penetration
of
80%
were
used
in
this
calculation.
Together
with
an
efficiency
of
60%,
this
brings
the
total
reduction
to
38.4%.

Therefore,
the
expected
emission
reductions
from
this
measure
are
1.03
tons
per
day
VOC
(
Table
4­
23).
There
is
no
NOx
reduction
for
this
measure.

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
VOC
Reduction
(
tpd)
Percent
Reduction
(%)

AREA
SOURCES:
Asphalt
Aplications
SCC:
2461020000
Cutback
Asphalt
Restrictions
Austin­
Round
Rock
MSA
(
5
Counties)
2.68
1.65
1.03
38.4%

Table
4­
23.
Asphalt
Paving
VOC
Emission
Reduction
ESTIMATED
COST
At
this
time
we
do
not
have
a
cost
estimate.

4.2.9
Low
Reid
Vapor
Gas
(
A9)

SOURCE
TYPE
AFFECTED
Fuel
refiners
and
suppliers
will
be
directly
affected.
Gas
stations
and
consumers
will
be
indirectly
affected
by
increased
costs
of
the
fuel.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
37
CONTROL
STRATEGY
The
Clean
Gasoline
program
limits
the
amount
of
sulfur
per
gallon
of
gasoline
and
reduces
evaporative
emissions
from
vehicles
or
storage/
transfer
facilities
by
limiting
Reid
Vapor
Pressure
(
RVP).
The
Reid
vapor
pressure
requirement
would
be
lowered
from
7.8
to
7.0
in
the
MSA
during
ozone
season
(
daylight
savings
time),
significantly
reducing
locally
generated
VOC.

IMPLEMENTATION
To
implement
this
measure,
the
MSA
requests
that
TCEQ's
existing
rule
30
TAC
Chapter
114
Subchapter
H,
Division
1,
be
revised
as
above.
The
MSA
encourages
TCEQ
to
expand
implementation
of
this
measure
to
the
eastern
half
of
the
state.
The
plan
must
be
implemented
no
later
than
December
31,
2005.

ESTIMATED
EMISSION
REDUCTION
ERG
evaluated
the
benefits
and
costs
associated
with
reducing
gasoline
RVP
from
7.8
to
7.0.
ERG
used
a
5­
county
aggregate
MOBILE6
input
file,
with
I/
M,
and
area­
specific
registration
and
VMT­
by­
hour
distributions,
to
estimate
fleet­
average
VOC
emission
rates
at
both
RVP
levels.
The
incremental
reduction
of
0.05
grams
per
mile
was
then
applied
to
total
fleet
VMT
in
2007
obtained
from
CAMPO
(
44,507,511),
to
obtain
total
emission
reductions
of
2.29
tpd.

Similarly,
NONROAD2002
was
then
run
for
all
non­
road
gasoline
equipment
types
in
the
area
(
using
default
populations
and
activity),
at
both
RVP
levels.
Results
indicated
a
0.17
tpd
reduction
in
VOC
from
these
engines.

Total
emission
reductions
from
both
on
and
non­
road
applications
come
to
2.87
tpd
for
the
5­
county
region
in
2007
(
Table
4­
24).
Note
that
in
conjunction
with
the
I/
M
program
those
reductions
would
be
lower
(
2.46
tpd).
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
38
Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
VOC
Reduction
(
tpd)
Percent
Reduction
(%)
ALL
ON
ROAD
&
NON
ROAD
MOBILE
Low
RVP
Gasoline
(
7.0)
Austin­
Round
Rock
MSA
(
5
Counties)
89.65
86.78
2.87
3.2%

Table
4­
24.
Low
Reid
Vapor
Pressure
VOC
Emission
Reduction
ESTIMATED
COSTS
In
order
to
estimate
potential
costs,
estimates
of
fuel
use
were
required.
Gallons
of
gasoline
sold
per
day
in
the
5­
county
region
were
developed
separately
for
the
Stage
I
Refueling
Control
analysis
(
see
below),
and
came
to
1,967,048
gal/
day.
Non­
road
gasoline
engine
fuel
use
was
obtained
directly
from
the
NONROAD2002
outputs,
and
came
to
76,117
gal/
day
for
the
region
in
2007.

Next,
estimates
of
the
incremental
costs
per
gallon
of
fuel
were
necessary.
Delivered
fuel
prices
will
include
the
additional
cost
of
any
blending
process
changes.
In
addition,

depending
upon
the
specific
blending
process
used,
additional
licensing
fees
may
need
to
be
paid
to
UNOCAL
for
patent
rights
(
UNOCAL
patent
393).

First,
actual
blending
process
changes
were
assumed
to
be
relatively
inexpensive,
at
approximately
1
cent
per
gallon,
based
on
EPA's
1996
Regulatory
Impact
Analysis
for
the
Phase
II
RFG
Rulemaking.
However,
precise
costs
are
difficult
to
determine,
as
the
blending
costs
will
vary
by
region
and
fuel
provider.

ERG
attempted
to
obtain
"
real­
world"
price
information
from
other
regions
of
the
country
with
similar
low
RVP/
conventional
gas
fuel
programs.
However,
it
was
determined
that
the
Atlanta
and
Birmingham
Alabama
fuel
programs,
both
with
7.0
RVP
requirements,
were
also
coupled
with
low
sulfur
requirements,
rendering
them
inappropriate
points
of
comparison.
ERG
also
attempted
to
obtain
incremental
cost
information
for
the
low
RVP
program
in
El
Paso
but
has
been
unsuccessful
at
the
time
of
this
writing.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
39
Potential
license
fee
costs
are
also
difficult
to
determine
precisely.
According
to
the
UNOCAL
website
(
http://
www.
unocal.
com/
rfgpatent/
rfgnews.
htm)
some
refiners
may
find
it
possible
to
"
blend
around"
their
patent
specifications
altogether.
However
local
stakeholders
have
indicated
that
their
crude
stocks
would
require
them
to
purchase
a
license
from
UNOCAL
in
order
to
meet
a
7.0
RVP
limit.
17
Assuming
an
additional
licensing
fee
would
be
applied
to
the
fuel
prices,
UNOCAL
indicates
this
fee
would
vary
from
1.2
to
3.4
cents
per
gallon,
depending
on
fuel
volumes.
Therefore
ERG
combined
actual
cost
and
license
fee
estimates
for
a
range
of
2.2
to
4.4
cents
per
gallon
for
the
total
incremental
costs
per
gallon
for
this
analysis.

Using
this
cost
range,
and
combining
with
the
fuel
sales
totals
for
the
region
and
emission
reduction
estimates,
we
obtain
the
following
cost
and
cost­
effectiveness
estimates
for
this
measure.
(
Note
that
annual
costs
assume
180
days/
year.)

TPD
Reduction
$/
Yr
(
low)
$/
Yr
(
high)
$/
ton
(
low)
$/
ton
(
high)
Bastrop
0.09
$
371,007
$
742,014
$
22,163
$
44,326
Caldwell
0.04
$
199,094
$
398,187
$
27,652
$
55,304
Hays
0.15
$
658,193
$
1,316,386
$
24,707
$
49,414
Travis
1.49
$
4,896,989
$
9,793,978
$
18,210
$
36,420
Williamson
0.68
$
1,665,902
$
3,331,804
$
13,570
$
27,141
Total
2.46
$
7,791,185
$
15,582,370
$
17,617
$
35,234
Table
4­
25.
RVP
Cost
Calculations
REFERENCES
ERG,
Inc.,
Technical
Support
documentation:
Emission
Control
Strategy
Evaluation
for
the
Austin/
San
Marcos
(
A/
SM)
MSA
EAC
Clean
Air
Action
Plan
(
CAAP),
February
17,
2004
17
Personal
communication,
Bill
Oswald,
Flint
Hills
Resources,
February
2004.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
40
4.2.10
BACT
and
Emission
Balancing
for
New
or
Modified
Point
Sources
(
A10)

SOURCE
TYPE
AFFECTED
New
sources
throughout
the
MSA
planning
to
emit
100
tons
or
more
per
year
of
NOx
are
affected
by
this
measure.

CONTROL
STRATEGY
Require
Best
Available
Control
Technology
(
BACT)
and
1:
1
emission
balancing
for
all
new
point
sources
that
would
emit
100
tons
per
year
or
more
of
NOx
only.
Emission
balancing
would
require
emission
reductions
from
existing
sources
to
be
used
for
offsetting
new
allowable
emissions.
When
a
stationary
point
source
aggregate
emission
of
VOC
reaches
twice
the
1999
baseline
an
offset
requirement
will
be
evaluated.

IMPLEMENTATION
Preferably
state
rule,
developed
by
TCEQ,
applicable
in
all
five
counties
and
implemented
by
Spring
2005.

ESTIMATED
EMISSION
REDUCTION
The
emissions
reduction
cannot
be
estimated
at
this
time.
Implementation
dates
on
the
power
plant
reductions
are
as
in
the
2005
to
2006
time
frame.

ESTIMATED
COSTS
The
costs
are
dependent
upon
the
facility
to
be
built
or
modified
and
the
availability
of
balancing
emissions.

4.2.11
Petroleum
Dry
Cleaning
(
A11)

SOURCE
TYPE
AFFECTED
Commercial
Petroleum
Solvent
Based
Dry
Cleaners
will
be
affected
by
this
measure.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
41
CONTROL
STRATEGY
The
commercial
dry
cleaning
category
(
SIC
7216)
includes
numerous
storefront
operations,
most
of
which
have
a
single
dry
cleaning
machine.
The
MSA
also
has
some
of
industrial/
institutional
cleaning
operations
(
SIC
7218).
These
larger
operations
primarily
use
laundry
detergents
rather
than
solvents,
as
all
the
industrial
cleaners
surveyed
by
CAPCO
reported.
Laundry
facilities
have
no
VOC
emissions.

Coinoperated
dry
cleaning
(
SIC
7215)
has
become
completely
obsolete
and
can
be
withdrawn
from
the
emission
inventory.

Over
85%
of
all
commercial
dry
cleaners
currently
use
perchloroethylene
(
PERC)
as
the
solvent.
In
1996,
PERC
was
excluded
from
the
EPA's
definition
of
VOC
because
of
its
negligible
photochemical
reactivity
(
FR,
1996).

Most
of
the
remaining
15%
of
dry
cleaners
use
some
form
of
VOC
solvent.
Of
these
machines,
almost
all
use
solvents
referred
to
as
synthetic
hydrocarbons.
Some
dry
cleaning
machines
manufactured
in
the
1950s
and
1960s
used
naptha
solvents,
such
as
Stoddard
solvent.
It
is
possible
(
but
unlikely)
that
one
or
two
cleaners
in
the
MSA
may
still
be
using
such
older
equipment,
which
emitted
much
more
VOC
than
contemporary
machines
using
synthetic
hydrocarbons.

In
the
CAPCO
inventory,
VOC
emissions
from
dry
cleaning
category
in
2007
were
estimated
as
1,150
tons
per
year.
It
is
possible
there
might
be
a
shift
in
the
industry,
due
to
new
fee
issues
imposed
by
Texas
HB
1366,
resulting
in
increased
VOC
solvent
use.

As
a
conservative
assumption
the
2007
inventory
could
be
as
high
as
the
1999
inventory
(
1,199
tpy).

IMPLEMENTATION
Adopt
the
Texas
state
rule,
30
TAC
115,
Subchapter
F,
Division
4
Petroleum
Dry
Cleaning
Systems,
used
in
DFW
and
Houston.
This
regulates
the
operation
of
a
dry
cleaning
facility
by
complying
with
dryer,
filtration
system,
and
fugitive
emission
requirements.
It
will
also
address
any
current
PERC
users
looking
to
switch
to
a
VOC
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
42
solvent
due
to
the
new
fee
issues
imposed
by
Texas
HB
1366.
The
plan
must
be
implemented
no
later
than
December
31,
2005.

ESTIMATED
EMISSION
REDUCTION
The
expected
emission
reductions
from
this
measure
range
from
0
to
1.06
tons
per
day
VOC,
depending
on
the
amount
of
actual
and
expected
petroleum
dry
cleaning
occurring
in
the
MSA.
Emission
reductions
from
this
measure
are
not
currently
included
in
the
CAAP.
The
measure
is
included
to
mitigate
possible
future
growth
in
dry
cleaning
emissions.

ESTIMATED
COSTS
The
costs
depend
on
the
type
of
system
a
dry
cleaner
would
switch
to
if
they
abandoned
using
PERC.
Therefore,
we
cannot
calculate
any
costs
at
this
time.

REFERENCES
Federal
Register
(
FR),
1996.
February
6,
1996.
SCAQMD,
2002,
Final
Staff
Report:
Proposed
Amendment
Rule
1421,
Appendix
D,
Table
1,
October
2002.

4.2.12
Texas
Emission
Reduction
Program
(
TERP)
(
A12)

The
77th
Texas
Legislature
established
the
Texas
Emissions
Reduction
Plan
(
TERP)

through
the
enactment
of
Senate
Bill
5
in
2001.
However,
the
program
was
not
fully
funded
until
the
78th
Legislature
enacted
HB
1365
in
2003.
TCEQ
expects
to
have
about
$
115­
120
million
in
revenue
in
FY
2004,
of
which
approximately
$
104
million
will
be
available
for
the
Emissions
Reduction
Incentive
Grants
Program
(
see
below).
Those
figures
are
expected
to
increase
in
each
of
the
subsequent
fiscal
years
through
FY2008,

averaging
a
total
of
$
150
million
each
year.

The
primary
purpose
of
the
TERP
is
to
replace,
through
voluntary
incentive
programs,

the
reductions
in
emissions
of
NOx
that
would
have
been
achieved
through
mandatory
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
43
measures
that
the
Legislature
directed
the
TCEQ
to
remove
from
the
SIP
for
the
Dallas/
Fort
Worth
(
DFW)
and
Houston/
Galveston
(
HGA)
ozone
nonattainment
areas.

TERP
funding
is
also
expected
to
be
available
to
help
achieve
reductions
in
counties
located
in
the
state's
other
two
nonattainment
areas
and
in
designated
near­
nonattainment
areas,
where
air
quality
is
approaching
nonattainment
levels.

SOURCE
TYPE
AFFECTED
Owners
and
operators
of
heavy­
duty
diesel
equipment
will
be
affected
by
this
measure.

The
program
is
available
to
all
public
and
private
fleet
operators
that
operate
qualifying
equipment
in
any
of
the
five
counties.

CONTROL
STRATEGY
The
reduction
strategy
is
to
secure
all
available
TERP
incentives/
grants
for
equipment
and
fuels
in
the
A/
RR
MSA.
Available
incentives/
grants
cover
the
incremental
cost
of
cleaner
diesel
on­
road
and
off­
road
engines
and
equipment,
cleaner
fuel
needed
for
the
equipment
and
clean
fuel
infrastructure.

IMPLEMENTATION
The
TERP
program
was
established
to
provide
monetary
incentives
for
projects
to
improve
air
quality
in
the
states'
non­
attainment
areas.
The
fund
consists
of
fees
and
surcharges
applied
to
certain
vehicles
and
equipment
when
they
are
purchased,
leased,

inspected,
or
registered
in
Texas.
The
amount
of
the
funds
available
for
grants
during
each
year
may
vary
depending
upon
the
amount
of
revenue
received,
as
well
as
the
appropriations
made
to
the
program.
Each
year,
the
TCEQ
will
issue
notices
and
information
regarding
the
grants,
including
information
on
the
amount
of
funds
available.

The
TERP
includes
the
following
financial
incentive
and
assistance
programs
intended
to
address
the
goals
of
the
plan:

The
Emissions
Reduction
Incentive
Grants
Program
is
administered
by
the
TCEQ.
The
program
provides
grants
to
eligible
projects
in
"
affected
counties,"
as
delineated
in
HB
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
44
1365,
to
offset
the
incremental
cost
associated
with
activities
to
reduce
emissions
of
NOx
from
high­
emitting
mobile
diesel
sources.

The
types
of
projects
that
may
be
eligible
for
these
grants
include:

 
On­
Road
Heavy­
Duty
Vehicles
(
8,500
lb
or
more)
Purchase
or
lease,
Replacement,
Re­
power,
Retrofit
or
add­
on
of
emission­
reduction
technology
 
Non­
Road
Equipment
Purchase
or
lease,
Replacement,
Re­
power,
Retrofit
or
add­
on
of
emissionreduction
technology
 
Marine
Vessels
Purchase
or
lease,
Replacement,
Re­
power,
Retrofit
or
add­
on
of
emissionreduction
technology
 
Locomotives
Purchase
or
lease,
Replacement,
Re­
power,
Retrofit
or
add­
on
of
emissionreduction
technology
 
Stationary
Equipment
Purchase
or
lease,
Replacement,
Re­
power,
Retrofit
or
add­
on
of
emissionreduction
technology
(
i.
e.
Oil
and
Gas
Compressors)

 
Refueling
Infrastructure
(
for
qualifying
fuel)

 
On­
Site
Electrification
and
Idle
Reduction
Infrastructure
 
On­
Vehicle
Electrification
and
Idle
Reduction
Infrastructure
 
Use
of
Qualifying
Fuel
 
Demonstration
of
New
Technology
The
Heavy­
Duty
Motor
Vehicle
Purchase
or
Lease
Incentive
Program
is
a
statewide
program
also
administered
by
the
TCEQ.
Under
this
program,
the
TCEQ
may
reimburse
a
purchaser
or
lessee
of
a
new
on­
road
heavy­
duty
(
over
10,000
lb)
vehicle
for
incremental
costs
of
purchasing
or
leasing
the
vehicle
in
lieu
of
a
higher­
emitting
dieselpowered
vehicle.
The
vehicle
being
purchased
or
leased
must
be
EPA­
certified
to
meet
certain
designated
lower
emissions
standards
for
NOx.
This
program
has
yet
to
be
implemented
and
available
funds
have
been
allocated
to
the
Emissions
Reduction
Incentive
Grants
Program.

The
Light­
Duty
Motor
Vehicle
Purchase
or
Lease
Incentive
Program
is
similar
to
the
Heavy­
Duty
Program,
and
provides
incentives
statewide
for
the
purchase
or
lease
of
light­
duty
(
less
than
10,000
lb)
motor
vehicles
that
are
certified
by
the
EPA
to
meet
a
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
45
lower
emissions
standard
for
NOx.
The
incentive
program
will
be
administered
by
the
Texas
Comptroller
of
Public
Accounts
but
is
currently
unfunded.

According
to
the
TERP
guidance,
an
activity
is
not
eligible
if
it
is
required
by
any
state
or
federal
law,
rule,
or
regulation,
memorandum
of
agreement,
or
other
legally
binding
document.
However,
this
restriction
does
not
apply
to
an
otherwise
qualified
activity
regardless
of
the
fact
that
the
state
implementation
plan
assumes
that
the
changes
in
equipment,
vehicles,
or
operations
will
occur,
if
on
the
date
the
grant
is
awarded
the
change
is
not
required
by
any
state,
federal,
law,
rule,
or
regulation,
memorandum
of
agreement,
or
other
legally
binding
document.
The
program
guidance
outlines
additional
restrictions
and
describes
other
eligible
activities.

The
TERP
program
will
require
a
review
of
each
project
funded.
Contracts
will
contain
provisions
that
allow
the
state
to
recapture
grant
money
for
the
failure
to
achieve
emission
reductions.
Furthermore,
if
the
performing
party
fails
to
comply
with
the
requirements
of
the
contract,
the
TCEQ
may
require
that
all
or
a
portion
of
the
reimbursement
funds
be
returned
or
repaid.
The
TCEQ
will
complete
a
contractor
evaluation
in
accordance
with
the
provision
that
will
be
outlined
in
the
grant
contract.

This
evaluation
will
be
used
to
track
the
compliance
and
effectiveness
of
contractors
and
grant
recipients
in
administering
contacts
with
the
TCEQ.

ESTIMATED
EMISSION
REDUCTIONS
AND
COSTS
Emission
reductions
from
the
TERP
program
depend
upon
two
factors:
the
availability
of
appropriate
heavy­
duty
fleets
in
a
given
area,
and
the
voluntary
participation
of
fleet
owners
and
operators
in
the
program.

Since
we
cannot
know
a
priori
what
types
of
emission
reduction
projects
will
be
funded
in
the
Austin
area,
or
at
what
level
of
participation,
we
assumed
that
projects
and
participation
levels
could
be
gleaned
from
looking
at
previously
approved
TERP
applications
in
the
DFW
and
HGA
regions.
ERG
obtained
the
summary
for
Grants
awarded
from
FY
02
through
FY
03
to
obtain
emission
reduction
and
cost­
effectiveness
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
46
estimates
for
TERP
projects
in
these
regions.
Next,
we
excluded
projects
that
were
clearly
not
representative
of
the
TERP
projects
expected
in
the
Austin
area.
This
included
removing
projects
involving
port/
maritime
activities,
as
well
as
funding
for
TxLED
projects.
18
Next
ERG
assumed
that
the
in
the
first
year
(
2004),
funding
would
most
likely
go
to
"
low­
hanging
fruit"
projects
 
i.
e.,
projects
sponsored
by
large,
centrally
fueled
and
maintained
public
fleets
such
as
Cap
Metro.
We
assumed
these
projects
would
employ
technologies
like
those
already
adopted
by
DART
and
Houston
Metro,
such
as
EGR
retrofits.
Projects
funded
in
subsequent
years
were
assumed
to
be
similar
to
the
remaining,
privately
submitted
TERP
applications
from
DFW
and
HGA.

Total
emission
reductions
were
estimated
using
a
top­
down
approach.
$
91M
should
be
available
for
heavy
diesel
retrofit
and
replacement
projects
in
2004
for
the
entire
TERP
region.
In
addition,
according
to
TCEQ
equipment
population
estimates,
the
Austin
region
is
home
to
approximately
6.9%
of
the
TERP
area's
heavy­
duty
on­
road
fleet,
and
5.1%
of
the
TERP
area's
construction
equipment
fleet.
Assuming
a
relatively
even
split
between
on­
and
off­
road
projects,
we
used
a
6%
figure
as
a
basis
for
allocating
available
funds
to
the
Austin
region
(~$
5.5M).
Table
4­
26
shows
the
expected
distribution
of
emission
reductions
among
the
five
counties
within
the
A/
RR
MSA.

Table
4­
26.
TERP
NOx
emission
reduction
18
Due
to
restrictions
under
the
TxLED
Alternative
Compliance
Program,
TxLED
will
not
be
eligible
for
TERP
funding
in
the
Austin
area,
although
it
is
eligible
in
all
other
TERP
areas.
COUNTY
2007
NOx
Uncontrolled
[
tpd]
2007
NOx
Controlled
[
tpd]
NOx
Reduction
[
tpd]
Percent
Reduction
(%)
Bastrop
2.03
1.93
0.10
5.1%
Caldwell
1.50
1.46
0.04
2.7%
Hays
4.29
4.10
0.19
4.4%
Travis
28.93
27.74
1.19
4.1%
Williamson
11.03
10.55
0.48
4.3%

Total
47.78
45.78
2.00
4.2%
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
47
Next
ERG
calculated
the
average
dollar
per
ton
cost
of
previously
funded,
representative
TERP
projects
for
the
first
and
subsequent
years
of
the
program.
This
came
to
$
4,300
per
ton
of
NOx
for
year
one
projects,
and
$
8,600
per
ton
for
subsequent
year
projects.

Assuming
the
Austin
area
funds
projects
at
the
6%
level
as
described
above,
this
translates
to
3.5
tpd
of
NOx
in
year
1,
and
1.75
tpd
of
NOx
in
years
2
and
beyond.
(
Note
that
yearly
emission
reduction
totals
were
divided
by
365
to
estimate
daily
totals.
To
the
extent
that
activity
is
more
heavily
weighted
toward
weekdays,
these
figures
would
be
even
higher.)

To
be
conservative,
a
yearly
estimate
of
2.0
tpd
of
NOx
was
assumed
for
the
2007
modeling.
Note
that
this
assumes
that
most
projects
would
only
have
only
a
one
year
life,

and
the
effects
are
not
cumulative.
While
this
is
realistic
for
fuel­
based
projects,
we
expect
significant
cumulative
benefit
resulting
from
multi­
year
retrofit
projects.

REFERENCE
TCEQ,
http://
www.
tnrcc.
state.
tx.
us/
oprd/
sips/
terp.
html
ERG,
Inc.,
Technical
Support
Documentation:
Emission
control
Strategy
Evaluation
for
the
Austin/
San
Marcos
(
A/
SM)
MSA
EAC
Clean
Air
Action
Plan
(
CAAP),
February
17th,
2004
4.2.13
Power
Plant
Reductions
(
A13)

SOURCE
TYPE
AFFECTED
Electrical
generating
utilities
in
the
A/
RR
MSA
and
surrounding
areas
will
be
affected
by
this
measure.
Austin
Energy
and
UT
commitments
cover
all
units
within
the
five
counties.
Additionally,
Austin
Energy's
and
LCRA's
Fayette
Power
Project
(
Sam
Seymour)
in
Fayette
County
is
covered.
The
Lost
Pines
1
facility,
operated
by
LCRA's
subsidiary
Gentex,
will
be
governed
by
the
existing
TCEQ
permit.

CONTROL
STRATEGY
Reduce
NOx
emissions
from
power
plants
as
follows:
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
48
Austin
Energy
­
AE
would
accept
a
cap
of
1,500
tons
per
year
on
total
NOx
emissions
from
all
of
its
units
combined
(
Decker,
Holly
and
Sand
Hill).

The
cap
would
be
in
place
at
least
through
2012.
As
AE
brings
new
units
on
line,

additional
NOx
emission
reductions
at
existing
units
would
be
made
in
order
to
comply
with
the
cap.
AE
will
achieve
this
cap
through
a
combination
of
NOx
reduction
technologies
at
their
existing
plants,
retirement
of
older
generating
units,
increased
utilization
of
renewable
energy
and
energy
efficiency.

LCRA
­
LCRA
is
considering
taking
a
cap
on
the
emissions
from
all
of
its
plants
in
the
5­

county
area.
The
final
level
of
this
cap
is
yet
to
be
defined,
but
would
be
no
greater
than
current
emissions.
LCRA
would
likely
follow
the
precedent
it
set
at
the
Lost
Pines
Power
Park
and
offset
NOx
emissions
from
any
new
power
plant
it
built
in
the
five
counties.
A
flexible
permit
that
requires
interim
NOx
emission
caps
by
2005
and
a
final
NOx
cap
by
2012
covers
the
Fayette
Power
Project
(
co­
owned
with
Austin
Energy).
Early
performance
data
on
controls
installed
at
one
unit
show
actual
emissions
are
20­
30%

below
the
interim
cap.
LCRA
will
consider
lowering
or
accelerating
the
caps
required
by
the
flexible
permit.

The
University
of
Texas
at
Austin
­
UT
will
reduce
the
allowable
annual
NOx
emissions
from
its
grandfathered
units
by
75%.
The
historical
potential
NOx
emission
from
these
units
is
1,388
tons
per
year.
Under
a
Voluntary
Emission
Reduction
Permit
with
the
TCEQ
the
University
will
limit
NOx
emissions
from
grandfathered
units
to
341
tons
per
year.
The
University
will
meet
these
reduced
emissions
levels
by
limiting
operating
hours
on
certain
equipment
and
by
installing
10­
year
BACT
controls
on
other
equipment.
A
proposal
to
add
controls
to
Boiler
#
7
by
December
2004
and
Boiler
#
3
by
December
2005,
depends
on
funding.
However,
they
will
be
modified
no
later
than
March
1,
2007.

Boilers
#
1
and
2
operating
hours
will
be
limited
to
2,500
hours
a
year.
Combustion
turbine
generator
(
CTG)
#
6
will
limited
to
3,000
hours
of
operation
on
a
rolling
12­

month
basis.
After
March
1,
2007
CTG
#
6
will
be
limited
to
1,500
hours
of
operation
on
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
49
a
rolling
12­
month
basis.
The
University
will
continue
to
operate
its
permitted
unit
(
Gas
turbine/
boiler
#
8)
as
usual;
this
unit
has
average
NOx
emissions
of
394
tons
per
year.

IMPLEMENTATION:

These
measures
would
best
be
implemented
by
agreed
order
for
Austin
Energy
AE
and
LCRA
or
permit
for
UT.
The
expected
implementation
dates
for
LCRA­
Sim
Gideon
is
12/
31/
05
and
Fayette
Power
Plant
is
12/
31/
06.
It
is
expected
that
UT
will
to
be
done
before
2005.

ESTIMATED
EMISSION
REDUCTION
The
estimated
emission
reduction
for
this
measure
is
7.08
tpd
of
NOx
(
Table
4­
27).
A
breakdown
by
county
is
provided
in
Table
4­
28.
The
UT
reductions
cannot
be
counted
for
here
because
they
were
not
accounted
for
in
the
September
1999
episode
modeling.

However,
it
is
expected
that
257
pounds
per
day
of
VOC
will
be
reduced.

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
NOx
Emissions
(
tpd)
2007
Controlled
NOx
Emissions
(
tpd)
Net
NOx
Reduction
(
tpd)
Percent
Reduction
(%)

POINT
SOURCES
EAC
Point
Source
Reductions
Austin­
Round
Rock
MSA
(
5
Counties)
32.11
25.03
7.08
22.0%

Table
4­
27.
Point
Source
NOx
emission
reduction
COUNTY
2007
NOx
Uncontrolled
[
tpd]
2007
NOx
Controlled
[
tpd]
NOx
Reduction
[
tpd]
Percent
Reduction
(%)
Bastrop
7.65
4.71
2.94
38.5%
Caldwell
2.51
2.51
0.00
0.0%
Hays
10.90
10.90
0.00
0.0%
Travis
11.04
6.90
4.14
37.5%
Williamson
0.08
0.08
0.00
0.0%

Total
32.19
25.10
7.08
22.0%

Table
4­
28.
Point
Source
NOx
emission
reduction
by
County
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
50
ESTIMATED
COST
The
costs
vary
as
to
the
facility
and
the
control
changes
implemented
to
achieve
the
reductions.

REFERENCES
Ramon
Alvarez,
PhD.,
Environmental
Defense
4.3
TRANSPORTATION
EMISSION
REDUCTION
MEASURES
(
TERMS)

SOURCE
TYPE
AFFECTED
Participants
in
the
TERMs
program
are
local
jurisdictions
and
implementing
agencies
in
the
MSA
and
CAMPO.

CONTROL
STRATEGY
TERMs
are
transportation
projects
designed
to
reduce
vehicle
use,
improve
traffic
flow
or
reduce
congested
conditions.
A
transportation
project
that
proposes
to
add
a
singleoccupancy
vehicle
(
SOV)
roadway
capacity
is
not
considered
a
TERM.
General
categories
of
TERMs
include
traffic
signal
synchronization
and/
or
improvements,
bicycle
and
pedestrian
facilities,
high­
occupancy
vehicle
lanes,
intersection
and
traffic
flow
improvements,
park
and
ride
lots,
intelligent
transportation
system
(
ITS)
and
transit
projects.

TERMs
are
similar
to
transportation
control
measures
(
TCMs),
except
that
TCMs
apply
to
nonattainment
areas.
TCMs
are
included
in
the
SIP
and
subject
to
transportation
conformity
requirements.
The
A/
RR
MSA
O3
Flex
and
EAC
CAAP
TERMs
are
not
subject
to
nonattainment
SIP
or
transportation
conformity
requirements.
TERMs
help
reduce
roadway
congestion
and
provide
opportunities
for
alternatives
to
single
occupant
vehicle
travel.
They
encourage
people
to
travel
(
and
exercise)
by
biking
and
walking.

IMPLEMENTATION
Various
jurisdictions
and
implementing
agencies
committed
to
numerous
TERMs
in
the
MSA's
O3
Flex
Agreement.
Additional
TERM
commitments
have
been
made
for
the
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
51
EAC
CAAP.
A
total
of
467
TERM
projects
have
been,
or
will
be,
implemented.
The
listed
O3
Flex
and
EAC
CAAP
TERMs
have
various
implementation
dates,
but
all
will
reduce
emissions
in
2007
and
some
will
reduce
emissions
beyond
2007
as
well.
Some
jurisdictions
committed
to
additional
TERMs
to
be
implemented
after
2007.
These
will
contribute
to
continued
attainment
past
2007.
A
project­
specific
list
of
O3
Flex,
EAC
CAAP
and
continued
attainment
TERMs
is
found
in
the
Appendices
to
Chapter
5
of
the
CAAP.
The
list
provides
locations,
project
limits,
implementation
dates,
and
emission
reductions
for
all
TERMs.
A
summary
of
the
O3
Flex
and
EAC
CAAP
TERMs,
and
the
expected
emission
reductions,
is
presented
in
Table
4­
29.

TERMs
by
Project
Type
2007
VOC
Reductions
(
lbs/
day)
2007
NOx
Reductions
(
lbs/
day)
Intersection
Improvements
448.82
374.95
Signal
Improvements
797.30
705.14
Bicycle/
Pedestrian
Facilities
69.88
62.54
Grade
Separations
5.94
5.28
Park
and
Ride
Lots
98.26
87.99
Traffic
Flow
Improvements
159.43
145.98
ITS
41.32
41.32
Transit
35.10
14.51
Total
(
lbs/
day)
1656.05
1437.71
Total
(
tons/
day)
0.83
0.72
Table
4­
29.
TERM
Projects
ESTIMATED
EMISSION
REDUCTION
The
expected
2007
emission
reductions
are
0.83
tons
per
day
VOC
and
0.72
tons
per
day
NOx.
(
Table
4­
30
and
4­
31)

Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
VOC
Emissions
(
tpd)
2007
Controlled
VOC
Emissions
(
tpd)
Net
VOC
Reduction
(
tpd)
Percent
Reduction
(%)

ONROAD
MOBILE:
All
OnRoad
Mobile
Sources
TERMS
Austin­
Round
Rock
MSA
(
5
Counties)
33.79
33.79
0.83
2.5%

Table
4­
30.
TERM
VOC
reduction
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
52
Emissions
Category
Control
Strategy
Area
Affected
by
this
rule
2007
Uncontrolled
NOx
Emissions
(
tpd)
2007
Controlled
NOx
Emissions
(
tpd)
Net
NOx
Reduction
(
tpd)
Percent
Reduction
(%)

ONROAD
MOBILE:
All
OnRoad
Mobile
Sources
TERMS
Austin­
Round
Rock
MSA
(
5
Counties)
62.18
61.46
0.72
1.2%

Table
4­
31.
TERM
NOx
reduction
ESTIMATED
COST
There
are
no
cost
estimates
for
the
TERM.

4.4
TABLE
B
EMISSION
REDUCTION
MEASURES
The
Early
Action
Compact
Task
Force
recommends
further
consideration
of
the
following
voluntary
measures,
with
the
understanding
that
they
may
or
may
not
be
quantifiable
commitments
despite
their
expected
emission
reductions.
Some
of
the
measures
listed
below
are
currently
being
implemented
in
some
areas
in
the
A/
RR
MSA
and
could
be
expanded
for
further
reductions.

The
following
is
a
key
to
the
regional
actions
EAC
signatories
have
committed
to
regarding
inclusion
of
the
voluntary
emission
reduction
measures.

O
=
O3
Flex
commitment
E
=
EAC
commitment
E+
=
increased
EAC
commitment
from
original
O3
Flex
commitment
O,
E
=
jurisdiction
confirmed
O3
Flex
commitment
when
selecting
Table
A
measures
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
53
Emission
Reduction
Measure
City
of
Austin
Travis
County
City
of
Round
Rock
Williamson
County
City
of
San
Marcos
Hays
County
City
of
Bastrop
City
of
Elgin
Bastrop
County
City
of
Lockhart
City
of
Luling
Caldwell
County
Texas
Emission
Reduction
Program
(
TERP)
E
E
E
E
Texas
Low
Emission
Diesel
(
TxLED)
for
Fleets
E
E
E
Transportation
Emission
Reduction
Measures
(
TERMs)
O,
E+
O,
E+
O,
E+
O,
E+
O,
E+
E
E
Access
Management
E
E
E
Alternative
Commute
Infrastructure
Requirements
E
E
E
Drive­
Through
Facilities
on
Ozone
Action
Days
E
E
Expedited
permitting
for
mixed
use,
transit
oriented
or
in­
fill
development
E
E
Airport
Clean
Air
Plan,
includes:
O
 
Use
of
electric
or
alternative
fuels
for
airport
GSE
O,
E
 
ABIA
Airside
Incentives
for
GSE
use
reduction
O,
E
 
Integrate
alternative
fuels
into
City's
aviation
fleet
O,
E
 
Operate
alternative
fueled
ABIA
surface
parking
lot
shuttle
buses
O,
E
 
Use
existing
ABIA
alternative
fuel
infrastructure
for
off­
site
parking
shuttle
buses
O,
E
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
54
Emission
Reduction
Measure
City
of
Austin
Travis
County
City
of
Round
Rock
Williamson
County
City
of
San
Marcos
Hays
County
City
of
Bastrop
City
of
Elgin
Bastrop
County
City
of
Lockhart
City
of
Luling
Caldwell
County
Low
VOC
Striping
Material
O,
E
O
O
O
O
E
E
O,
E
Landfill
Controls
Open
Burning
Restrictions
E
E
E
Tree
Planting
O,
E
O
O
O,
E+
O
E
E
E
O,
E
Extend
energy
efficiency
requirements
beyond
SB5
and
SB7
E
Shift
the
electric
load
profile
E
Environmental
dispatch
of
power
plants
E
Clean
Fuel
Incentives
Low
Emission
Vehicles
O,
E
O
O
O
O,
E
O
Adopt­
a­
School­
Bus
Program
E
Police
Department
Ticketing
E
EPA
Smart
Way
Transport
Program
Business
Evaluation
of
Fleet
Useage,

Including
Operations
and
Right
Sizing
E
E
E
Parking
Incentives
for
Alt
Fuel
or
SULEV
vehicles
Commute
Solutions
Programs,
may
include
O,
E
E
 
Compressed
Work
Week
O,
E
O
O
O
O
 
Flexible
Work
Schedule
O,
E
O
O
 
Carpool
or
Alternative
Transportation
Incentives
O,
E
 
Transit
Pass
Subsidized
by
Employer
O,
E
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
55
Emission
Reduction
Measure
City
of
Austin
Travis
County
City
of
Round
Rock
Williamson
County
City
of
San
Marcos
Hays
County
City
of
Bastrop
City
of
Elgin
Bastrop
County
City
of
Lockhart
City
of
Luling
Caldwell
County
 
Teleworking
(
full
time)
O,
E
 
Teleworking
(
part
time)
O,
E
O
Direct
Deposit
O,
E
O
O
O
O
O,
E+
E
O
E
O
e­
Government
and/
or
Available
Locations
O,
E
O
E
O,
E+
O
Voluntary
use
of
APUs
for
locomotives
operating
in
Central
Texas
Fueling
of
Vehicles
in
the
Evening
O,
E
O
O
O
O,
E+
O
O,
E
O
O
Urban
Heat
Island/
Cool
Cities
Program
E
Resource
Conservation
O,
E+
O
O
O
O
O,
E+
O
Increase
investments
by
Central
Texas
electric
utility
providers
in
energy
demand
management
programs
E
Alter
production
processes
and
fuel
choices
Contract
provisions
addressing
construction
related
emissions
on
high
ozone
days
E
Ensure
emission
reductions
in
SEPs,
BEPs
and
similar
agreements
E
E
E
Ozone
Action
Day
Education
Program,

includes:
O,
E
O
O
O
O
O,
E+
O,
E
O,
E
O
O,
E
O
O
 
Employee
Education
Program
O
O
O
O
O
O
O
O
O
O
O
O
 
Public
Education
Program
O
O
O
O
O
O
O
O
O
O
O
O
Ozone
Action
Day
Notification
Program
O
O
O
O
O
O
O
O
O
O
O
O
Ozone
Action
Day
Response
Program
O,
E
E
O
E
E
O
Alternative
Fuel
Vehicles
O
O
O
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
56
Emission
Reduction
Measure
City
of
Austin
Travis
County
City
of
Round
Rock
Williamson
County
City
of
San
Marcos
Hays
County
City
of
Bastrop
City
of
Elgin
Bastrop
County
City
of
Lockhart
City
of
Luling
Caldwell
County
Right
Sizing
O
O
O
5­
minute
Limit
on
Diesel
Idling
O
O
O
O
O
O
Cleaner
Diesel
O
O
O
O
O
O
O
O
Vehicle
Maintenance
O
O
O
O
O
O
O
O
Vapor
Recovery
on
Pumps
O
O
Low
VOC
Asphalt
O
O
O
Low­
Emission
Gas
Cans
O
O
O
O
O
O
O
O
Transit­
Oriented
Development
O
Shaded
Parking
O
O
Landscaping
voluntary
start
at
noon
on
high
ozone
days
(
education
program)
E
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
57
4.4.1
Texas
Emission
Reduction
Program
(
TERP)

CONTROL
STRATEGY
Secure
all
available
TERP
incentives/
grants
for
equipment
and
fuels
in
the
five
county
area.
Available
incentives/
grants
cover
the
incremental
cost
of
cleaner
diesel
on­
road
and
off­
road
engines
and
equipment,
cleaner
fuel
needed
for
the
equipment
and
clean
fuel
infrastructure.
This
control
strategy
is
covered
in
detail
in
section
4.2.13.

4.4.2
Texas
Low
Emission
Diesel
(
TxLED)
for
Fleets
CONTROL
STRATEGY
Purchase
and
use
Texas
Low
Emission
Diesel
in
on­
road
and
non­
road
vehicles
and
equipment.

4.4.3
Transportation
Emission
Reduction
Measures
(
TERMs)

CONTROL
STRATEGY
Implement
transportation
projects
and
programs
that
reduce
emissions.
Projects
and
programs
include
improved
transit
options
and
level
of
service,
intersection
improvements,
grade
separations,
signal
synchronizations
and/
or
improvements,
peak
and/
or
off­
peak
traffic
flow
improvements,
park
and
ride
facilities,
bike/
ped
facilities,

high
occupancy
vehicle
lanes,
rail,
demand
management,
intelligent
transportation
systems
etc.
Many
TERMS
are
already
planned
and
funded.
CAMPO
has
issued
a
call
for
projects
that
may
provide
funding
for
additional
TERMS.
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4.4.4
Access
Management
CONTROL
STRATEGY
Adopt
access
management
regulations
or
guidelines
for
new
or
re­
development.
TxDOT
has
proposed
guidance
available.
Access
management
includes
managing
roadway
access
by
limiting
the
number
and
location
of
allowable
curb
cuts
and
driveways,
consolidating
access
to
multiple
business
through
one
main
driveway,
side
road
etc.
Access
management
reduces
congestion,
vehicle
delay
and
associated
emissions.

4.4.5
Alternative
Commute
Infrastructure
Requirements
CONTROL
STRATEGY
Require
all
new
non­
residential
developments
of
25,000
sq.
ft
or
more
and
developments
that
increase
their
square
footage
25%
or
more
and
have/
expect
100+
employees
on
the
site
to
include
bicycle
commuting
facilities
(
parking/
racks
and
showers)
and
preferential
carpool/
vanpool
parking
spaces.

4.4.6
Drive­
Through
Facilities
on
Ozone
Action
Days
CONTROL
STRATEGY
Require
or
encourage
businesses
with
drive­
through
facilities
to
post
signs
on
Ozone
Action
Days
asking
customers
to
park
and
come
inside
instead
of
using
the
drive­
through
facilities.
Encourage
the
public
to
comply.
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Strategies
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March
2004
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4.4.7
Expedited
permitting
for
mixed
use,
transit
oriented
or
in­
fill
development.

CONTROL
STRATEGY
Provide
an
expedited
permitting
process
and/
or
other
incentives
for
mixed
use,
transit
oriented
or
in­
fill
development.
Developments
would
have
to
meet
certain
performance
criteria
in
order
to
qualify
for
expedited
permitting.

4.4.8
Use
of
electric
or
alternative
fuels
for
airport
GSE
CONTROL
STRATEGY
This
category
includes
new
and
in­
use
ground
support
equipment
(
GSE)
used
in
airport
operations.
GSE
perform
a
variety
of
functions,
including:
starting
aircraft,
aircraft
maintenance,
aircraft
fueling,
transporting
cargo
to
and
from
aircraft,
loading
cargo,

transporting
passengers
to
and
from
aircraft,
baggage
handling,
lavatory
service,
and
food
service.
The
Air
Transportation
industry
has
informed
Central
Texas
that
they
will
oppose
any
requirements
on
their
industry.

4.4.9
ABIA
Airside
incentives
for
GSE
use
reduction
CONTROL
STRATEGY
ABIA
has
begun
and
will
complete
the
addition
of
building
supplied
power
and
preconditioned
air
for
all
aircraft
parked
at
the
gate.
This
will
eliminate
the
need
to
run
on­
board
auxiliary
power
units
(
APUs),
and
air­
conditioning
(
ACUs)
and
ground
power
units
(
GPUs)
by
the
air
carriers
if
they
will
participate.
It
is
not
clear
if
we
can
mandate
their
use,
or
if
it
will
need
to
be
on
a
voluntary
basis.
Implementation
might
require
creating
incentives
or
use
restrictions.
Estimated
0.16
tpd
NOx
reduction.
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2004
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4.4.10
Integrate
alternative
fuels
into
City's
aviation
fleet
CONTROL
STRATEGY
Begin
replacement
of
Aviation
Fleet
equipment
with
propane
fuel
starting
FY2003.

Purchase
of
10
propane
pro­
turf
mowers,
and
4
propane
non­
road
truck­
alls.
Planned
purchases
at
this
time.
Future
replacement
is
subject
to
budget
provisions.

4.4.11
Operate
alternative
fueled
surface
parking
lot
shuttle
buses
CONTROL
STRATEGY
ABIA
currently
operates
29
propane
buses
for
passenger
service
between
the
terminal
and
the
parking
lots.
Averages
25,000
gallons
of
propane
per
month.
Estimated
60%
NOx
reduction.
Take
credit
for
current
operations.

4.4.12
Use
existing
ABIA
alternative
fuel
infrastructure
for
off­
site
parking
shuttle
buses
CONTROL
STRATEGY
Propane
fueling
infrastructure
is
available
at
ABIA
that
could
be
used
to
refuel
off­
site
parking
shuttle
buses.
Encourage
or
mandate
these
services
to
shift
to
propane
by
2005.

Estimated
60%
NOx
reduction.

4.4.13
Low
VOC
Striping
Material
CONTROL
STRATEGY
Require
use
of
reformulated
striping
material
products
(
i.
e.,
water­
based
paints
or
thermoplastic)
to
achieve
VOC
reductions.
Traffic
marking
activities
refer
to
the
striping
of
center
lines,
edges,
and
directional
markings
on
roads
and
parking
lots.
VOC
emissions
from
traffic
marking
vary
depending
on
the
marking
material
used,
and
the
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2004
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frequency
of
application.
Generally,
there
are
six
different
types
of
traffic
marking
materials
(
EIIP,
1997a):
1)
solvent­
based
paint;
2)
water­
based
paint;
3)
thermoplastics;

4)
field­
reacted
systems;
5)
preformed
tapes;
and
6)
permanent
markers.
Solvent­
based
paints
typically
are
the
least
expensive
among
the
material
types,
but
produces
the
highest
VOC
emissions.
Alternative
techniques
may
have
none
or
negligible
VOC
emissions,

but
the
materials
and
equipment
are
typically
more
expensive.
However,
cheaper
techniques
may
also
require
multiple
applications
in
comparison
to
more
costly
techniques.
Traffic
markings
using
conventional
paints
(
solvent­
and
water­
based)
will
need
to
be
applied
annually,
while
the
use
of
thermoplastics
can
last
between
5
and
9
years
(
Utah
DOT,
2003).

4.4.14
Landfill
Controls
CONTROL
STRATEGY
Adopt
control
strategy
for
municipal
solid
waste
landfills
based
upon
the
EPA's
New
Source
Performance
Standard
(
NSPS)
and
Guidelines.
A
municipal
solid
waste
landfill
is
a
disposal
facility
in
a
contiguous
geographical
space
where
household
waste
is
placed
and
periodically
covered
with
inert
material.
Landfill
gases
are
produced
from
the
aerobic
and
anaerobic
decomposition
and
chemical
reactions
of
the
refuse
in
the
landfill.
Landfill
gases
consist
primarily
of
methane
and
carbon
dioxide,
with
volatile
organic
compounds
making
up
less
than
one
percent
of
the
total
emissions.
Although
the
percentage
for
VOC
emissions
seems
small,
the
total
volume
of
gases
is
large.

4.4.15
Open
Burning
Restrictions
CONTROL
STRATEGY
Amend
and/
or
adopt
regulations
to
ban
the
open
burning
of
such
items
as
trees,
shrubs,
and
brush
from
land
clearing,
trimmings
from
landscaping,

and
household
or
business
trash,
during
the
peak
ozone
season.
It
reduces
VOCs
and
NOx.
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2004
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4.4.16
Tree
Planting
CONTROL
STRATEGY
Implement
landscaping
ordinances
to
require
additional
urban
tree
planting.
Reforestation
improves
air
quality
and
energy
efficiency.

4.4.17
Extend
energy
efficiency
requirements
beyond
SB5
and
SB7.

CONTROL
STRATEGY
Require
additional
energy
efficiency
measures
beyond
SB5
and
SB7,
such
as
building
design,
revisions
to
codes
and
standards,
and
energy
management
programs
for
large
commercial
facilities.
Additional
energy
efficiency
measures
could
provide
significant
reductions
in
energy
demand
and
demand­
related
emissions.

4.4.18
Shift
the
electric
load
profile
CONTROL
STRATEGY
Require
commercial
facilities
to
develop
overnight
the
reservoir
of
cold
water
needed
to
meet
air
conditioning
needs
the
following
day.
Total
energy
consumption
and
emissions
are
not
reduced,
but
the
emissions
are
not
generated
during
the
day,
reducing
the
potential
for
ozone
formation.

4.4.19
Environmental
dispatch
of
power
plants
CONTROL
STRATEGY
To
meet
peak
demands,
this
strategy
would
involve
"
ramping
up"
power
generation
facilities
that
are
either
cleaner
than
normally
used
or
located
away
from
high
NOxproducing
areas
(
e.
g.,
plants
in
Bastrop
and
Marble
Falls
rather
than
the
Decker
or
Holly
Street
plants
in
downtown
Austin).
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March
2004
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4.4.20
Clean
Fuel
Incentives
CONTROL
STRATEGY
Encourage
and/
or
provide
incentives
to
implement
fuels
that
are
cleaner
than
conventional
gasoline
and
diesel,
including
alternative
fuels,
lower
sulfur
gasoline
and
low
sulfur
diesel.

4.4.21
Low
Emission
Vehicles
CONTROL
STRATEGY
Encourage
and/
or
provide
incentives
for
the
purchase
and
use
of
Tier
2
Bin
3
or
cleaner
vehicles
for
fleets
and
private
use.

4.4.22
Adopt­
a­
School­
Bus
Program
CONTROL
STRATEGY
Encourage
local
school
districts
to
participate
in
this
CLEAN
AIR
Force
sponsored
program
to
replace
or
retrofit
old
diesel
school
buses
with
new,
cleaner
buses.

Replacements
and
retrofits
are
implemented
using
50%
corporate
sponsorship
funds
and
50%
school
district
funds.
EPA
provides
seed
money
to
the
CLEAN
AIR
Force
for
a
fundraiser
and
program
administration.

4.4.23
Police
Department
Ticketing
CONTROL
STRATEGY
Implement
aggressive
police
enforcement
by
local
agencies
of
speed
limits
55
mph
or
more
and
smoking
vehicle
restrictions.
If
the
smoking
vehicle
is
fixed
within
60
days,
the
ticket
could
be
waived.
A/
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Reduction
Strategies
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March
2004
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4.4.24
EPA
Smart
Way
Transport
Program
CONTROL
STRATEGY
EPA
sponsored
voluntary
partnership
with
freight
carriers
and
shippers
to
reduce
fuel
consumption
and
emissions
through
strategies
such
as
idle
reduction,
improved
aerodynamics,
improved
logistics
management,
automatic
tire
inflation
systems,

widebase
tires,
driver
training,
low­
viscosity
lubricants,
reduced
highway
speed
and
lightweight
vehicle
components.
Participating
carriers
and
shippers
will
meet
voluntary
performance
goals
and
track
progress.
EPA
will
provide
a
calculation
and
tracking
software
tool
and
technical
support.
Several
carriers
and
shippers
have
already
signed
up.

4.4.25
Business
Evaluation
of
Fleet
Usage,
Including
Operations
and
Right
Sizing
CONTROL
STRATEGY
Evaluate
and
improve
the
efficiency
of
fleet
usage,
including
using
alternative
or
clean
fueled
vehicles,
using
the
cleanest
vehicle
appropriate
for
the
job,
consolidating
and
coordinating
trips,
etc.

4.4.26
Parking
Incentives
for
Alt
Fuel
or
Low
Emission
vehicles
CONTROL
STRATEGY
Provide
parking
incentives
for
Tier2
Bin
3
or
cleaner
vehicles.
These
clean
vehicles
could
be
allowed
to
park
for
free
at
parking
meters,
have
designated
parking
spaces.
This
would
encourage
the
use
of
these
cleaner
vehicles.
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March
2004
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4.4.27
Commute
Solutions
Programs
CONTROL
STRATEGY
Encourage
and
provide
tools
to
implement
Commute
VMT
reduction
programs
(
e.
g.

Teleworking,
compressed
work
week,
carpooling/
vanpooling,
bus
fares,
subsidized
transit
pass,
flextime,
carpool
or
alternative
transportation
incentives
etc.).
The
Commute
Solutions
program
provides
information
and
tools
to
implement
these
programs.
Could
be
used
to
support
a
commute
emission
reduction
regulation.

4.4.28
Direct
Deposit
CONTROL
STRATEGY
Offer
employees
direct
deposit
potentially
saving
at
least
one
vehicle
errand
per
pay
period.

4.4.29
e­
Government
and/
or
Available
Locations
CONTROL
STRATEGY
Provide
web­
based
services,
both
for
information
and
transactions,
and/
or
multiple
locations
for
payments,
etc.,
Reduces
VMT
and
associated
emissions.

4.4.30
Voluntary
use
of
APUs
for
locomotives
operating
in
Central
Texas
CONTROL
STRATEGY
Controls
for
locomotives
are
pre­
empted
by
Federal
law,
but
voluntary
controls
might
have
some
success,
since
using
Auxiliary
Power
Units
(
APUs)
also
decreases
fuel
costs
to
the
railroad
companies.
CSX
has
been
considering
the
use
of
APUs
to
reduce
fuel
use.

4.4.31
Fueling
of
Vehicles
in
Evening
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CAPCO
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2004
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CONTROL
STRATEGY
Promote
fueling
vehicles
after
peak
hot
periods
of
the
day
have
passed
during
ozone
season.

This
does
not
reduce
NOx
emissions
but
moves
the
high
emissions
time
frame
to
later
hours.

4.4.32
Urban
Heat
Island/
Cool
Cities
Program
CONTROL
STRATEGY
Develop
and
implement
Urban
Heat
Island
(
UHI)
mitigation
strategies.
Since
ozone
forms
at
higher
temperatures,
the
purpose
of
this
strategy
is
to
keep
the
city
as
cool
as
possible,
through
vegetation,
cool
roofing
and
light
colored
pavement.

4.4.33
Resource
Conservation
CONTROL
STRATEGY
Expand
and
quantify
ongoing
resource
conservation
programs
(
materials
recycling,
water
and
energy
conservation,
etc.).

4.4.34
Increase
investments
by
Central
Texas
electric
utility
providers
in
energy
demand
management
programs
CONTROL
STRATEGY
This
measure
would
involve
the
development
of
energy
demand
management
programs
in
areas
outside
the
Austin
Energy
service
area.
Austin
Energy
offers
financial
incentives
to
commercial
and
residential
customers
for
installation
of
energy
efficient
appliances
and
technologies
and
they
report
a
good
correlation
between
their
demand
programs
and
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March
2004
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reduced
emissions
at
their
power
plants.
This
measure
would
encourage
other
utility
providers
in
the
region
to
develop
similar
programs.

4.4.35
Alter
production
processes
and
fuel
choices
CONTROL
STRATEGY
This
strategy
involves
exploring
opportunities
to
improve
efficiency,
to
make
changes
in
certain
combustion
processes,
and/
or
to
alter
fuel
choices
where
cost­
effective.
Some
point
sources
in
the
area
(
e.
g.,
Austin
White
Lime)
are
using
natural
gas
for
cost
reasons.

Given
their
production
processes,
using
natural
gas
results
in
higher
NOx
emissions
than
using
coal.
Representatives
have
expressed
interest
in
examining
their
production
process
and/
or
revisiting
their
fuel
choices,
particularly
during
the
ozone
season.
Other
point
sources
such
as
LeHigh
Cement
are
also
looking
at
rescheduling
and
fuel
changes
to
reduce
NOx.

4.4.36
Contract
provisions
addressing
construction
related
emissions
on
high
ozone
days
CONTROL
STRATEGY
Public
contracts
may
include
provisions
to
limit
construction
activities
and
equipment
operation
on
high
ozone
days.
A
specified
number
of
these
high
ozone
days
would
be
built
into
the
contract.
While
controversial,
it
is
one
of
the
only
ways
to
target
non­
road
construction
emissions.
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March
2004
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4.4.37
Ensure
emission
reduction
in
SEPs,
BEPS
and
similar
agreements
CONTROL
STRATEGY
Ensure
that
the
primary
impact
of
all
air
quality
related
SEPs,
BEPs
or
similar
agreements
applicable
to
the
EAC
area,
is
to
reduce
emissions
and
improve
air
quality.

EPA
and/
or
TCEQ
would
consult,
to
the
extent
possible,
with
the
local
EAC
signatories
when
developing
any
air
quality
related
environmental
mitigation
agreement,
such
as
a
SEP,
BEP
or
other
similar
agreement.

4.4.38
Ozone
Action
Day
Education
Program
CONTROL
STRATEGY
Implement
a
public
ozone
education
program,
including
ozone
action
days
and
recommended
actions.

4.4.39
Ozone
Action
Day
Notification
Program
CONTROL
STRATEGY
Entities
will
notify
employees
of
ozone
action
days
the
day
before
and
encourage
employees
to
reduce
emissions.

4.4.40
Ozone
Action
Day
Response
Program
CONTROL
STRATEGY
Implement
a
program
of
specific
emission
reduction
measures
taken
on
ozone
action
days.

4.4.41
Alternative
Fuel
Vehicles
CONTROL
STRATEGY
A/
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Emissions
Reduction
Strategies
CAPCO
March
2004
4­
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A/
SM
MSA
participants
to
the
O3
Flex
Agreement
are
committed
to
encouraging
the
expanded
use
of
alternative
fuels
and
alternative
fuel
vehicles
among
the
owners
and/
or
operators
of
fleets
of
15
vehicles
or
more.
To
qualify
as
an
alternative
fuel
vehicle,
the
vehicle
must
operate
75%
of
the
time
on
one
of
the
federal
Energy
Policy
Act
fuels.

Approved
alternative
fuels
are
compressed
natural
gas
(
CNG),
liquefied
natural
gas
(
LNG),
liquefied
petroleum
gas
(
LPG),
electricity,
methanol,
ethanol,
and
biodiesel
(
at
a
minimum
20%
mix).
Alternative
fuels
reduce
NOx
and
VOCs
at
varying
levels
and
are
an
appropriate
strategy
for
reducing
or
even
eliminating
emissions.
Credits
are
available
under
the
federal
Energy
Policy
Act
(
EPAct)
for
use
of
alternative
fuels.
Bastrop
Independent
School
District
has
chosen
to
use
biodiesel
at
a
20%
mix
with
an
additive
to
reduce
NOx
as
their
future
fuel
of
choice.
The
school
district
runs
a
fleet
of
92
buses.

4.4.42
Right
Sizing
CONTROL
STRATEGY
In
addition
to
alternative
fuels
and
alternative
fuel
vehicles,
signatories
and
participants
have
incorporated
selection
of
the
right
size
vehicle
for
a
given
use
into
their
fleet
operation
policies.

4.4.43
5­
minute
Limit
on
Diesel
Idling
CONTROL
STRATEGY
Participating
entities
will
direct
vehicle
operators
under
their
employ,
or
on
their
property
or
worksite,
to
limit
vehicle
or
equipment
engine
idling
to
no
more
than
five
consecutive
minutes.
Exemptions
may
be
made
for
emergency
or
law
enforcement
vehicles
on
active
duty,
vehicles
or
equipment
that
must
operate
the
engine
to
perform
job
duties
(
such
as
providing
power
for
a
mechanical
operation
or
heating
and
air
conditioning
for
multiple
passenger
vehicles),
and
vehicles
or
equipment
that
are
being
operated
for
maintenance
or
diagnostic
purposes.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
70
4.4.44
Cleaner
Diesel
CONTROL
STRATEGY
Capital
Metro,
the
cities
of
Austin,
Bastrop
and
Elgin,
Travis
County
and
the
Austin
Independent
School
District
have
agreed
to
purchase
a
diesel
product
that
is
believed
to
reduce
particulate
matter
and
increase
overall
efficiency.
Use
of
this
fuel
increases
engine
performance,
with
corresponding
air
quality
benefits
through
fuel
efficiency.
While
reductions
of
NOx
emissions
from
this
product
are
not
quantifiable
at
this
time,
the
commitment
to
this
fuel
represents
a
good­
faith
effort
on
the
part
of
these
entities
to
purchase
the
best
currently
available
diesel
fuels.

4.4.45
Vehicle
Maintenance
CONTROL
STRATEGY
In
addition
to
alternative
fuels
and
alternative
fuel
vehicles,
signatories
and
participants
have
incorporated
regular
maintenance
in
a
manner
that
will
minimize
emissions,
into
their
fleet
operation
policies.

4.4.46
Vapor
Recovery
on
Pumps
CONTROL
STRATEGY
In
addition
to
alternative
fuels
and
alternative
fuel
vehicles,
signatories
and
participants
have
incorporated
upgrading
private
pumps
with
vapor
recovery
systems,
into
their
fleet
operation
policies.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
71
4.4.47
Low
VOC
Asphalt
CONTROL
STRATEGY
VOC
emissions
reductions
can
be
achieved
by
using
medium­
cure
and/
or
rapid­
set
asphaltic
concrete
materials
and
water­
based
or
thermoplastic
striping.
Examples
of
the
medium
and
rapid­
cure
asphalt
are
HFRS­
2P
(
rapid­
set)
and
SSI
(
medium­
cure).

Participating
entities
that
are
responsible
for
building
and/
or
maintaining
roadways
in
the
region
will
commit
to
use
these
types
of
materials
whenever
feasible.
Exceptions
may
be
granted
for
emergency
repairs.

4.4.48
Low
Emission
Gas
Cans
CONTROL
STRATEGY
Gasoline­
powered
lawn
and
garden
equipment
are
a
significant
source
of
VOCs
in
the
region.
A
particularly
effective
control
measure
is
the
use
of
nonpermeable,
spill­
proof
gasoline
containers.
An
estimated
0.2
tons
per
day
of
VOC
reductions
could
result
from
100%
use
in
the
commercial
sector.
Several
of
the
A/
SM
MSA
signatories
have
selected
this
measure
to
include
in
their
commitments.

4.4.49
Transit­
Oriented
Development
CONTROL
STRATEGY
Local
governments
implement
development
criteria
either
requiring
or
providing
incentives
for
sprawl
reduction
such
as
vertical
zoning,
mixed
use
zoning,
enhanced
mobility
choices,
reducing
distances
between
home
sites,
work
sites,
and
service
sites.

These
types
of
development
criteria
will
reduce
the
impacts
of
new
development
on
air
quality.
A/
RR
MSA
Emissions
Reduction
Strategies
CAPCO
March
2004
4­
72
4.4.50
Shaded
Parking
CONTROL
STRATEGY
In
addition
to
alternative
fuels
and
alternative
fuel
vehicles,
signatories
and
participants
have
incorporated
shaded
parking
for
fleet
vehicles,
to
the
extent
possible,
into
their
fleet
operation
policies.

4.4.51
Landscaping
voluntary
start
at
noon
on
high
ozone
days
(
education
program)

CONTROL
STRATEGY
Outreach
to
local
stakeholders
will
include
education
and
encourage
voluntary
implementation
of
delaying
landscape
work
until
noon
on
high
ozone
days.
