Department of Transportation Comments on draft PM 2.5 NAAQS RIA:

Generally, DOT is concerned that the costs of mobile source emissions
may be under stated.  The RIA seems to make a number of assumptions
about the cost of national rules that have yet to be developed, and
about local measures that air agencies may not have control over, such
as modal split of travel.  

Table 1-8: The previous RIA version had total annualized costs for the
15/35 standard for Mobile Sources at $1.5 billion. The new RIA version
has this total as $60.39 million. While we have received an explanation
from EPA as to the changes made in this table, we feel that a further
explanation of how costs are calculated should be included in the RIA,
especially explaining in more detail why mobile sources National Rules
are zero and how incremental costs of residual nonattainment were
calculated.

Pages 3-9 and 6-25.  "No fugitive dust controls or other PM10 controls
to be applied except in a case where there is a critical need or where
such sources are major contributors to PM2.5 concentrations.  We applied
such controls only in California where the extent of nonattainment was
so high that we applied every known control available."  There appears
to be no discussion on the costs of fugitive dust controls.  Were
fugitive dust controls on paved and unpaved roads, as well as on
transportation construction projects, used in the attainment strategy
for California?  If so, how were the costs/ton calculated?  Also if so,
what was the basis for any such calculations?

3-25 and 6-18: Under the discussions of pre-proposal mobile source
emission standard and fuel rules that are expected to affect the
regulatory impact of this rule, we are concerned that EPA is assuming
that the cost of these future rules are not attributed to the cost of
the PM NAAQS but rather to the cost of the individual future rules.  DOT
would like to see a discussion of how compliance with these rules might
alter the regulatory impact of these PM standards, recognizing the
preliminary nature of the pre-proposal regulations. 

Pages 3-28, 3-29.  The diesel retrofit measure includes targeting 50%,
then 100%, of all heavy-duty engines, except 5% of the nonroad fleet. 
What is the basis for using such high percentages?  What sort of control
measure(s) could actually achieve this as the majority of these engines
are privately owned?  

Pages 3-29, 6-22.  The RIA relies on "intermodal transfer," which is
basically an assumption that a percentage of freight movement in the
future could be shifted from trucks to rail.  What is the basis for
assuming that this is an achievable target?  What sort of control
measures(s) could actually achieve this as goods movement is
predominately controlled privately?  Will the capacity of the future
rail system be able to accommodate this? Even if the 1% shift is
achievable, how does EPA make the jump that this would equate in 1%
decrease in truck emissions and a .4%/.3% increase in rail emissions? 
What methodology is used?

Page 4-35.  "The source apportionment studies highlight the importance
of mobile sources and suggest that we may not have fully captured the
air quality benefits associated with controlling these sources."   The
does not seem to be a conclusive statement.  Is EPA actually making a
conclusion here?  If not, this should not be part of the conclusions
section.

Page 6-4.  "Cost information for mobile source controls was taken from
studies conducted by EPA for previous rulemakings and studies conducted
for development of voluntary and local measures that could be used by
state and local programs to assist in improving air quality."  The RIA
should specifically cite and reference each study used.

Page 6-20.  The C-E study is linked to on this page.  However, the RIA
should more specifically cite and reference the study (ies) being used
here.

Page 6-20.  The C-E study is discussed here as showing 2.3 times higher
emissions factors than are currently in MOBILE6.2, and EPA plans to
integrate this information into MOVES.  However, "...states and local
governments will continue to use MOBILE6.2 to estimate highway vehicle
emissions for SIP and conformity purposes."  This appears to be setting
up a huge mismatch between PM2.5 SIPs and future conformity analyses
after the release of MOVES.  Changes of this magnitude in MOVES need to
be discussed thoroughly with DOT, while under development, and well in
advance of the release of MOVES.

Page 6-20.  "...we believe that technology and installation costs are
likely to decrease by 2015 and 2020."  What is EPA's basis for this
statement?  This seems counterintuitive.  Is this based on existing data
that shows a downward trend in the costs of this type of technology?  

Page 6-21.  The RIA identifies anti-idling measures as a "no cost"
strategy.  This seems overly simplistic.  Although fuel savings could
offset capital costs, it does not reflect how control measures could be
adopted to actually achieve these reductions.  This may be truer for
APUs, but what reasonable control measures could force the installation
of APUs?  Capital costs, especially in the case of TSEs, would most
likely be placed upon public entities that would not recoup the fuel
savings.

Page 6-22.  The RIA identifies "intermodal transport" measures as a "no
cost" strategy.  This seems overly simplistic.  Although fuel savings
could offset capital costs, it does not reflect how control measures
could be adopted to actually achieve these reductions.  Capital costs
would most likely be placed upon public entities or rail owners that
would not necessarily recoup the fuel savings.    

DOT has no comments on the revised Executive Summary, offers an
additional comment on the "Document Compare":

Page 7.  "The application of area source control technologies in these
analyses assume that a constant estimate for emission reduction is
reasonable despite variation in the extent or scale of application (e.g.
amount of hot asphalt applied to an unpaved road).  To the extent that
there are economies of scale in area source control applications, we may
overstate the emission reductions estimated by these analyses."  Paving
of unpaved roads is not an area source control, but actually should be
considered a mobile source control as road dust should be included in
the on-road inventory.

