2007 NAAQS for Ozone RIA

Federal Highway Administration

Received 6/13/07

 

                    Chapter 2, page 1, second paragraph under “2.1
Ozone Chemistry,” next to last sentence.  “In urban areas with a
high population concentration, ozone is often VOC-limited due to the
high density of traffic with NOx emissions.”  What is the basis for
this statement?  Many inventories also show a high percentage of NOx
emissions from other sources such as off-road engines and power plants,
especially in the future.
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                    Chapter 2, page 2, first paragraph.  “and at X
latitude.”  What does “X” stand for?  How does this relate to the
previous sentence that states that the effect of latitude is strongest
in the winter?

 

                    Chapter 2, page 3, first paragraph.  “Solvent
use and highway vehicles are the two main sources of VOCs, with roughly
equal contributions to total emissions.   Emissions of VOCs from highway
vechicles account for roughly two-thirds of the transportation-related
emissions.”  Why is this placing such a strong emphasis on highway
vehicles, which were only 27% of emissions nonanthropogenic emissions in
2002.  Industrial processes were greater at 46%.  The list of sources of
VOC emissions should be complete and subjective terms should not be
used, and the year of data should be cited.  Instead a data driven
description should be given such as “in 2002, solvents were XX% of VOC
emissions, on-road vehicles were XX%, nonroad vehicles were XX%.”  

 

                    Chapter 2, page 3, second paragraph.  “The two
largest sources of NOx are electric power generation plants and motor
vehicles.  Emissions of NOx therefore are highest in areas having a high
density of power plants and in urban regions having high traffic
density.  Once again, why is this placing such a strong emphasis on
highway vehicles?  What is the basis for this statement?  In 2002,
nonroad vehicles were 20% of emissions.   The list of sources of NOx
emissions should be complete and subjective terms should not be used,
and the year of data should be cited.  Instead a data driven description
should be given such as “in 2002, solvents were XX% of VOC emissions,
on-road vehicles were XX%, nonroad vehicles were XX%.”

 

                    Chapter 3, page 2, first paragraph under “3.1
Establishing the Baseline.”  “However, in developing the baseline it
was important to recognize that there are several areas that are not
required to meet the current standard by 2020.”  This is not correct. 
Currently, only the South Coast area in California has a maximum
attainment date past 2020.  If this is the only area, then terms such as
“several” and “some” should not be used in this section.  If
this section is anticipating that areas will be bumped-up to higher
classifications, then this should be discussed, or the discussion in
Chapter 4, pages 8-9 for the two California areas referenced.  However,
this should also be consistent with Chapter 4, page 8, second paragraph
which states “The analysis assumes that all but one
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                    Chapter 3, page 3, table 3.1.  It is recommended
that this table be divided to differentiate between national rules and
the less certain strategies presented in the PM NAAQS RIA.  We have
expressed several concerns regarding the strategies in the PM RIA, and
those strategies should be clearly separated from national rules both in
the title of the table(s) and in the body.

 

                    Chapter 3, page 7, first paragraph.  This
paragraph details that on-road controls are assumed to be applied
statewide for several states.  Is this reasonable to assume?  In
addition, it assumes a 75% penetration for diesel retrofits and idling
elimination in California, and a 25% penetration elsewhere.  What is the
basis for this assumption?  How is this reasonable, especially in
California?

 

                    Chapter 3, page 11, first paragraph.  “The
baseline predicted that 10 counties would not meet the current ozone
standard in 2020, even after inclusion of all known controls.”  As
currently designated and classified, all counties except for the 4 in
the South Coast are supposed to demonstrate attainment by at the latest
2013.  How do these counties relate to current classifications and SIPs
for the current standard that are due by June 15, 2007?  Are any of
these 10 counties in areas with submitted SIPs that show attainment
prior to 2020? 

 

                     Chapter 3, page13, Table 3.4.  This table
details increased penetration of on-road SCR and DPF from 25% to 75%,
and continuous Inspection and Maintenance (OBD).  What is the basis for
these assumptions?  How are they reasonable?

 

                    Chapter 3, pages 21-23.  What are the time frames
(years) of these reductions?

 

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 nonroad rules, and the residual tons.

 

                    Chapter 5, page 4, section 5.1.1.3.  “Cost
information for mobile source controls was taken from studies conducted
by EPA…”  These studies should be specifically referenced and cited.
 Also, it appears that “Appendix 6?” should be “Appendix 5.”

 

                    Chapter 6, incomplete.  This Chapter,
“Incremental Benefits of Attaining Alternative Ozone Standards
Relative to the Current 8-hour Standard,” is missing.

 

                    Chapter 8, incomplete.  “This chapter will
explain the results and the limitations of the analysis.”  However,
only four tables and no text are included.

 

                    Chapter 9.  This file is titled Chapter 9, but
the text is titled and numbered as Chapter 8.  The outline for the RIA
shows that the “Statutory and Executive Order Impact Analyses” are
Chapter 9.

 

                    Appendix 3, page 11, section 3.2.1, second
paragraph.  States, “We looked at options of applying this measure to
50% and 100% of the fleet…”  However, this does not seem to be
consistent with Chapter 3, which discusses 25% and 75% market
penetration.

 

                    Appendix 3, page 12, last paragraph.  Where are
the “interviews with component manufacturers” documented?  There
should be a specific reference to which manufacturers were interviewed,
when, and the topic of discussion.

 

                    Appendix 5, pages 4-5.  There seems to be a fault
in the logic applied in the development of continuous I/M costs.  The
cost comparison seems to compare the same fleet of vehicles, i.e., it
assumes that the same number of vehicle will be subject to continuous
I/M that are subject to remote I/M.  However, this logic appears flawed
in that the RIA seems to apply continuous I/M over entire States.  This
application is much wider than current I/M programs.  To have a fair
discussion of costs, the RIA needs to include an analysis of the number
of vehicle that would be subject to the continuous I/M, compared to the
remote I/M.

 

                    Appendix 5, page 5-6.  As we commented on the PM
NAAQS RIA, this RIA also 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 more true for
MIRTs, but what reasonable control measures could force the installation
of MIRTs?  Capital costs, especially in the case of TSEs, would most
likely be placed upon public entities that would not recoup the fuel
savings.

 

                    Appendix 5, page 7.  “Reduce Gasoline RVP from
7.8 to 7.0 in Remaining Nonattainment Areas.  Cost-Effectiveness of
Measure:  Cost per ton will be $5,700 to $36,000/ton VOC.”  What is
the basis of this estimate?  What is the source of the data?  This needs
to be discussed and referenced.

