                               U.S. COAST GUARD
                                       
                  FINAL PROGRAMMATIC ENVIRONMENTAL ASSESSMENT
                                       
                                      FOR
                                       
          TRANSPORTATION WORKER IDENTIFICATION CREDENTIAL (TWIC)  -  
                                       
                              READER REQUIREMENTS
                                       
This U.S. Coast Guard Final Programmatic Environmental Assessment (FPEA) was prepared in accordance with U.S. Coast Guard Commandant's Manual Instruction Ml6475.1D and is in compliance with the National Environmental Policy Act of 1969 (Pub. L. 91-190) and the Council on Environmental Quality Regulations dated 1 July 1986 (40 CFR Parts 1500-1508).

This environmental assessment serves as a concise public document to briefly provide sufficient evidence and analysis for determining the need to prepare an environmental impact statement or a finding of no significant impact.  

This environmental assessment succinctly describes the proposed action, the need for the proposal, the alternatives, the environmental impacts of the proposal and alternatives, a comparative analysis of the action and alternatives, a statement of environmental significance, and lists the agencies and persons consulted during its preparation.

____________     ________________________________   Mr. Timothy O'Brien
Date                     Preparer					Environmental Analyst,                          
                                                CG-REG-1
                                                U.S. Coast Guard

____________     ________________________________   Mr. Gregory Kirkbride   
Date                     Environmental Reviewer                           Senior Environmental 										Analyst,                          
                                                CG-REG-1
                                                U.S. Coast Guard
				
In reaching my decision on the USCG's proposed policy action, I have considered the information contained in this FPEA on the potential for environmental impacts.


____________     ________________________________   Paul F. Zukunft, Admiral      
Date                      Responsible Official                      	Commandant
                                          U.S. Coast Guard


Table of Contents
Contents
Table of Contents	ii
List of Acronyms	vi
Executive Summary	1
1.0 Purpose and Need	1
1.1 Introduction	1
1.2 Description of Proposed Action	1
1.3 Purpose and Need for the Proposed Action	3
2.0 Alternatives	1
2.1 Scope of Work and Issues Considered	1
2.2 Alternative 1: No Action (Maintain the Requirements from the TWIC 1 Final Rule)	2
2.3 Alternative 2 (preferred): TWIC Readers at High-risk Ports Only	2
2.4 Alternative 3: All Container Facilities Deploying TWIC Readers in Mode 1 (Verification with No Use of Biometrics)	3
2.5 Alternative 4: All Container Facilities Deploying TWIC Readers in Mode 3 (Use of Biometrics)	3
2.6 Alternatives Considered but not Further Analyzed	3
2.7 Summary of Environmental Impacts of Proposed Action and Alternatives	4
3.0 Affected Environment	1
3.1 Physical Environment	1
3.1.1 Location of Port Facilities	1
3.1.2 TWIC Readers at Pilot Facilities	4
3.2 Air Quality	4
3.2.1 The Clean Air Act of 1970	4
3.2.2 Air Quality Designations	5
3.2.3 The General Conformity Rule and the De Minimis Thresholds	6
3.3 Ports and Current Air Quality Status	7
3.4 Environmental Resources and Issues Not Likely Affected by TWIC Readers	8
3.4.1 Installation and Operation of TWIC Readers at Port Entrances	8
3.4.2 Operation of TWIC Readers Aboard MTSA-regulated Vessels	9
3.4.3 Human Health and Safety	9
3.4.4 Energy	9
3.4.5 Land Use	9
3.4.6 Waste Impacts	10
3.4.7 Water Resources	10
3.4.8 Biological Resources	10
3.4.9 Historic Properties	10
3.4.10 Environmental Justice	10
3.4.11 Socioeconomics	10
3.4.12 Endangered Species	11
3.4.13 Climate Change	12
3.4.14 Noise	12
4.0 Environmental Consequences	1
4.1 Summary	1
4.1.1 Applicability of Models and Data Sets Used	1
4.1.2 Uncertainty of Data	2
4.1.3 EPA Data Sets	2
4.1.4 Number of Trucks in U.S. Container Ports	3
4.2 Analysis of Data	4
4.2.1 Idling Vehicle Pollution Calculations	4
4.3 Comparative Analysis of Proposed Action and Alternatives	8
4.3.1 Introduction	8
4.3.2 Alternative 1, No Action Alternative	8
4.3.3 Alternative 2 (preferred): TWIC Readers at High-risk Facilities Only	8
4.3.4 Alternative 3: All Container Facilities Deploying TWIC Readers in Mode 1 (Validation with No Use of Biometrics)	9
4.3.5 Alternative 4: All Container Facilities Deploying TWIC Readers in Mode 3 (Use of Biometrics)	11
4.4 Truck Idling Times and Potential Failure Rates	13
4.4.1 Summary of Potential Impact of Failure Rates	13
4.4.2 Sources of Failure	13
4.4.3 Range of Failures	14
4.4.4 Delays and the Clean Air Act of 1970	15
4.5 Cumulative Impacts	16
4.6 Mitigation of Potential Environmental Impacts	17
4.6.1 Changes in Truck Models and Fuels	17
4.6.2 Appointment Schedules for Truck Arrivals	17
4.6.3 Changes in Sequencing of Port Business and Security Operations	18
4.6.4 Temporary Suspension of Reader Use during High Traffic Events and Other Delays	19
5.0 Environmental Significance of Proposed Action	1
6.0 Identified Environmental Review and Consultation	1
7.0 References	1
8.0 Contacts	1
USCG Finding of No Significant Impact	1
Appendix A. Affected Environment at Ports	1
A.1 Florida	1
A.2 Los Angeles	3
A.3 Virginia	9
A.4 New York	10
A.5 Houston	13
A.6 Florida Ports	15
A.6.1 Port of Palm Beach and Port Everglades	15
A.6.2 Southeast Florida Airshed Maintenance Area: Regulatory History	15
A.7 The San Pedro Bay Ports: Port of Los Angeles and Port of Long Beach	16
A.7.1 California South Coast Air Basin (SoCAB)	16
A.7.2 Environmental Initiatives	17
A.8 Port of Hampton Roads, Virginia	18
A.8.1 Hampton Roads Nonattainment Area	18
A.8.2 Environmental Initiatives	18
A.9 Port Authority of New York and New Jersey	18
A.9.1 New York/New Jersey/Long Island Nonattainment Area	18
A.9.2 Drayage Truck Population	19
A.9.3 Environmental Initiatives	19
A.10 Port of Houston Authority	20
Appendix B. Sequencing of Activities at Port Facilities and Potential Implications for Alternative Analysis	1
Appendix C. Data Sets	1
C.1 TSA Data	1
C.2 Comparison of ICE Baseline Measures against the Visual Inspection Baseline Measure	2
C.2.1 Adjustment of Time for Visual Inspections in Mode 1	2
C.2.2 Calculation of Delay Time Difference	3
C.3 Emissions Data	4
C.3.1 U.S. Environmental Protection Agency Data	4
C.4 Data Calculations	6
C.5 Solving for Transaction Time	1
Appendix D. Air Quality Criteria.	1
Appendix E. Department of Homeland security (DHS) Approaches: US-VISIT Program Draft Environmental Assessment	1
E.1 Alternatives Considered (Including the No Action Alternative)	1
Appendix F. Memorandum from EPA on the Use of Moves Model and Data Application	1
Appendix G. Summary of Field Trips to Container Facilities and Observations by USCG Personnel	1
Appendix H. Marine Security Risk Analysis Model Description	3



List of Acronyms
AHP
Analytical Hierarchy Process
BMPs
Best Management Practices
CAA
Clean Air Act of 1970
CAAP
Clean Air Action Plan
CARB
California Air Resource Board
CCL
Canceled Card List
CFR
Code of Federal Regulations
DHS
Department of Homeland Security
DPEA
Draft Programmatic Environmental Assessment
EA
Environmental Assessment
EPA
U.S. Environmental Protection Agency
FONSI
FPEA
Finding of No Significant Impact
Final Programmatic Environmental Assessment
FR
Federal Register
GDP
Gross Domestic Product
GHGs
Greenhouse gases
HDDV
Heavy Duty Diesel Vehicle
ICE
Initial Capability Evaluation
MARSEC
MSRAM
Maritime Security
Maritime Security Risk Analysis Model 
MTSA
Marine Transportation Security Act of 2002
NAAQs
National Ambient Air Quality standards
NEPA
National Environmental Policy Act of 1969
NPRM
Notice of Proposed Rulemaking
NYNJLINA
New York/New Jersey/Long Island Nonattainment Area
OMB
Office of Management and Budget
OSHA
Occupational Safety and Health Administration
PACS
Physical Access Control System
PANYNJ
Port Authority of New York and New Jersey
PHA
Port of Houston Authority
PIN
Personal Identification Number
PM
Particulate matter
Pub. L.
Public Law
RA
Regulatory Analysis
SAFE Port Act
Security and Accountability For Every Port Act of 2006
SIPs
State Implementation Plans
SoCAB
California South Coast Air Basin
TEU
TSA
Tonnage Equivalent Unit 
Transportation Security Administration
TWIC
Transportation Worker Identification Credential
USACE
U.S. Army Corps of Engineers
U.S.C.
United States Code
USCG
United States Coast Guard
US-VISIT
United States Visitor and Immigrant Status Indicator Technology
VOC
Volatile organic compound 
VPA
Virginia Port Authority


Executive Summary

The Department of Homeland Security, United States Coast Guard (USCG), is implementing requirements for electronic readers for Transportation Worker Identification Credentials (TWIC) in compliance with the Maritime Transportation Security Act (MTSA) of 2002 and the Security and Accountability For Every Port Act of 2006 (SAFE Port Act).  The purpose of requiring electronic TWIC readers is to enhance the security of the nation's ports and vessels by ensuring that only persons who are valid TWIC-holders are granted unescorted access to secure areas on vessels and facilities.  It also implements the MTSA security card requirement, as well as the requirements of the SAFE Port Act for regulations on electronic TWIC readers for use with TWICs.  In a final rule known as TWIC  -  Reader Requirements, the USCG will require owners and operators of certain vessels and facilities regulated by the USCG under 33 CFR Chapter I, subchapter H to use electronic readers designed to work with TWIC as an access control measure.  This final rule will also implement additional requirements associated with electronic TWIC readers, including owner/operator recordkeeping requirements, and amendments to security plans previously approved by the Coast Guard to incorporate TWIC requirements.  

The TWIC is a tamper-resistant biometric credential that the Transportation Security Administration (TSA) issues to eligible maritime workers who require unescorted access to secure areas of MTSA-regulated vessels and facilities.  The face of the TWIC shows the holder's photograph, name, and TWIC expiration date, and the back shows a unique credential number, referred to as the TWIC Serial Number.  In addition, the TWIC stores two electronically readable reference biometric templates (i.e., fingerprint templates), a Personal Identification Number (PIN) selected by the TWIC-holder, a digital facial image, authentication certificates, and a Federal Agency Smart Credential-Number.  Security personnel on vessels and facilities are currently required to visually inspect the TWICs of individuals seeking access to secure areas to: (1) compare the photograph on the TWIC to the TWIC-holder; (2) ensure that the TWIC expiration date has not passed; and (3) check the other security features on the TWIC for signs of tampering or forgery.  The most reliable way to verify the TWIC-holder's identity and ensure that the TWIC is both valid and authentic is to use an electronic TWIC reader to scan the TWIC and also run a biometric (i.e., fingerprint) match on the TWIC-holder.

The final rule specifies which facilities or vessels are required to use TWIC readers.  That was done by using a risk-based hierarchy to determine which facilities or vessels fall into a high risk group, known as Risk Group A.  All non-Risk Group A facilities (which in the Notice of Proposed Rulemaking (NPRM) were called Risk Groups B and C) are not required to use TWIC readers.  Additionally, barge fleeting facilities are treated as other facilities are, and are not subject to the specific NPRM requirements in this final rule.  This Final Programmatic Environmental Assessment (FPEA) does not attempt to exactly replicate the regulatory language of the final rule or any other supporting documentation; the regulatory text, not the text of this report, is legally binding. 

We considered several alternatives in the development of the final rule.  These alternatives are based on several different combinations of facility and vessel populations facing TWIC reader requirements.  The considered alternatives are: 1) Alternative 1, the no action alternative, 2) Alternative 2, which uses TWIC readers only in high-risk vessels and facilities, 3) Alternative 3 which uses TWIC readers in all ports for validations only, without biometric matching, and 4) Alternative 4, which uses TWIC readers at all ports for both validation and biometric matching.  The selected alternative allowed the USCG to target the highest risk entities while minimizing the overall burden.  For a complete discussion of the alternatives, see Chapter 6 of the Final Regulatory Analysis (RA), also located in the docket for this rulemaking (USCG-2007-28915). 

This FPEA contains an evaluation of the implementation of the final rule for TWIC readers as well as an evaluation of the "no action" alternative.  We have evaluated container ports, since they are the only locations that are expected to incur truck delays and hence the idling that causes additional air emissions attributable to the final rule.  Additional emissions potentially impact local air quality.  This FPEA has been prepared in accordance with the requirements of the National Environmental Policy Act of 1969, as amended (NEPA, Pub. L. 91-190).  The final rule responds to public comments on the NPRM and alters some considerations, such as discussions of risk groups.  None of the changes from the NPRM to the final rule requirements impact this FPEA.  Additionally, the USCG did not receive any comments directly related to the Draft Programmatic Environmental Assessment (DPEA).  This FPEA has been adopted from the DPEA with editorial changes and with changes to ensure consistency between the RA and the FPEA.

Based on this analysis, the only potential impacts are to air quality.  While there are some positive or negative impacts for the four alternatives considered, these impacts are not significant, under any alternative.  Significant impact in this case is measured by whether additional air emissions would exceed de minimis amounts under the Clean Air Act of 1970 (CAA).  In order for impacts to be potentially significant, processing delays due to TWIC readers would have to be over 6 minutes per truck, even in Non-Attainment Areas under the CAA.  Data collected by TSA indicates that delays are expected to be under approximately 8 seconds.  Delays over 6 minutes per truck are unlikely, as discussed in the TSA study; in the unlikely event that there are long delays, they would arise from unusual circumstances (for instance, due to very high truck volume).  In that event, the final rule does provide that the Captain of the Port with the authority to temporarily suspend the TWIC reader requirements and to order the facilities to return to using the TWIC card as a visual verification device.

Using air quality models developed by the U.S. Environmental Protection Agency (EPA) and in consultation with EPA, four alternatives were analyzed with respect to potential environmental impacts on air quality at U.S. container ports: 1) Alternative 1, the no action alternative, 2) Alternative 2, which uses TWIC readers only in high-risk vessels and facilities, 3) Alternative 3 which uses TWIC readers in all ports for validations only, without biometric matching, and 4) Alternative 4, which uses TWIC readers at all ports for both validation and biometric matching.  Alternative 1 did not meet Congressional requirements and is only evaluated because it is required by NEPA.  Alternative 2 is the preferred alternative because it is the most effective for the purpose and need of the program, and there are no significant environmental impacts.  Alternative 3 appears to have the lowest environmental impacts (and may improve air quality) because it only uses TWIC readers for validation, and therefore does not have the truck delays from the biometric protocol.  Alternative 3 was not chosen because it does not meet the needs of the program.  The difference in air emissions between Alternative 3 and the no action alternative baseline is small enough that potential air quality improvements would be negligible if additional time is needed to reconcile unanticipated delays in the TWIC Reader process.  Even in the worst-case scenario of Alternative 4, as discussed above, impacts are insignificant.

Under the preferred alternative (Alternative 2), three Florida container facilities fall under the definition of "high risk," where TWIC readers will be used to determine the current validity of the card and the driver's identity (by matching the picture from the card with the driver, and by taking a biometric reading from the driver).  The impacts on air quality are insignificant as the emissions fall below the de minimis CAA levels.  

Cumulative impacts associated with additional air emissions are not considered significant since all analyses of air quality under the four FPEA alternatives show the addition to pollution due to the TWIC readers to be within the de minimis range.

As discussed in the RA, the benefits of the rulemaking include the enhancement of the security of vessels, ports, and other facilities by ensuring that only individuals who hold valid TWICs are granted unescorted access to secure areas.  TWIC readers will allow for enhanced verification of personal identity as well as validation of TWICs, both of which will improve access control at high risk MTSA-regulated vessels and facilities.  It also contributes to the removal of the current patchwork of credentials and reader technologies used throughout the maritime industry, and will serve to standardize the use of readers at high-risk facilities and vessels.  It will also implement the 2002 MTSA transportation security card requirement, as well as the 2006 SAFE Port Act electronic TWIC reader requirements, thereby ensuring compliance with those statutes.  TWIC readers will not address potential attacks from outside a target, attacks at lower risk facilities or the verification and validation of a duly issued TWIC obtained using fraudulent documents.  

1.0 Purpose and Need 

1.1 Introduction
The National Environmental Policy Act of 1969, as amended (NEPA, Pub. L. 91-190) is intended to help public officials make decisions that are based on an understanding of environmental consequences, and to take actions that protect, restore, and enhance environmental quality.  These decisions are to be based on accurate scientific analysis, expert agency comments, and public review and comment on readily available environmental information.  Federal agencies are obligated to follow the provisions of NEPA to identify and assess reasonable alternatives to the proposed action and make informed decisions that will avoid or minimize any adverse effects upon the quality of the human environment before proceeding with the proposed action.  The human environment under NEPA includes potential impacts on human health and the physical, chemical, and biological environment. 

THE objective of this Final Programmatic Environmental Assessment (FPEA) is to document the U.S. Coast Guard's (USCG's) approach to consideration of the potential impacts of the action on the human environment.  This FPEA contains an assessment of the potential for environmental impacts associated with installing and operating Transportation Worker Identification Credential (TWIC) readers.  As required under NEPA, the USCG will take one of the following two actions based on the FPEA: if it is determined that the Proposed Action will not have a significant impact on the human environment, a Finding of No Significant Impact (FONSI) will be issued; if it is determined that the Proposed Action may have a significant impact on the human environment, the USCG will prepare an Environmental Impact Statement to further analyze the identified impacts.

1.2 Description of Proposed Action
The USCG, as an agency within the Department of Homeland Security (DHS), is implementing requirements for electronic TWIC readers in compliance with the Maritime Transportation Security Act (MTSA) of 2002 and with the Security and Accountability For Every Port Act of 2006 (SAFE Port Act).  The principal statutory authority for the TWIC program, MTSA, requires the issuance of biometric transportation security cards to merchant mariners and to other workers requiring unescorted access to secure areas of vessels and port facilities.  46 U.S.C. 70105(a)-(f).  The SAFE Port Act supplemented various MTSA credentialing requirements including the implementation of a reader testing pilot program.  46 U.S.C. 70105(k). 

The TWIC 1 Notice of Proposed Rulemaking (NPRM, 71 FR 29396, May 22, 2006) proposed requirements for TWIC readers that were not included in the TWIC 1 Final Rule (72 FR 3492, January 25, 2007).  The TWIC Reader Advanced Notice of Proposed Rulemaking (ANPRM, 74 FR 13360, March 27, 2009) proposed that MTSA-regulated vessels, facilities, and Outer Continental Shelf (OCS) facilities be assigned to three risk levels.  The Maritime Security Risk Analysis Model (MSRAM), Analytical Hierarchy Process (AHP), and other factors were used to rank vessels and facilities as to the level of risk (see Appendix H).  The TWIC Reader NPRM proposed that vessels and facilities with the highest risk be required to fully utilize the security features, whereas vessels and facilities at the lower risk levels should be required to implement only some of the security features.  The final rule responds to public comments on the NPRM and alters some policies, such as proposed requirements for the risk groups.  In the NPRM there were three risk groups, Risk Groups A, B and C.  After full consideration of the public comments on the NPRM, the USCG revised the TWIC reader requirements by removing the requirement to use TWIC readers in Risk Group B; therefore Risk Group B and Risk Group C entities have no electronic TWIC inspection requirements.  We now refer to Risk Group A and Risk Group Non-A (which contains the previous Risk Groups B and C).  None of these changes impact this FPEA.  Additional details on the changes to the final rule from the NPRM are discussed in the RA, and in the preamble of the final rule, both available in the docket for this rulemaking (USCG-2007-28915).

The TWIC is a tamper-resistant biometric credential issued to eligible maritime workers who require unescorted access to secure areas of MTSA-regulated vessels and facilities.  In a final rule issued on January 25, 2007 (72 FR 3492), DHS, through the USCG and the TSA required such maritime workers to obtain a TWIC.  This requirement already forms part of the baseline for the NEPA analysis.  The 2007 rulemaking did not require owners and operators of vessels or facilities to purchase and install TWIC readers.  At that time, DHS concluded that TWIC reader requirements would follow in a later rulemaking after pilot testing TWIC readers in the maritime environment. 
      
TWIC readers obtain information from a TWIC's integrated circuit chip, and provide an accurate method for verifying the TWIC-holder's identity and ensuring the TWIC is authentic and valid.  Based in part on data from the pilot program conducted by DHS, the TWIC Reader NPRM proposed to require a limited population of regulated vessels and facilities to deploy TWIC readers as an access control measure.  These vessels and facilities would be required to use TWIC readers to scan the TWIC of each individual seeking unescorted access to secure areas at those locations.  The final rule maintains these requirements.

The main elements of a TWIC reader program would be the acquisition, installation, and integration of TWIC readers into current access control systems.  While the specific elements and configuration of the system would be left to the discretion of the owners or operators, the basic configurations would be to install TWIC readers at the access points of a vessel or facility, or to have portable TWIC readers available for use at the access points.

TWIC readers can be either fixed or portable.  Fixed TWIC readers are stationary and mounted at or near an access point.  Portable TWIC readers are hand-held and operated by security personnel at or near an access point.  Installation of fixed TWIC readers would potentially involve mounting the readers on existing or new wood or metal frames and plates, trenching and burying cables for power and communication, and some possible changing at facilities to accommodate the TWIC readers such as moving fencing and access points.  All other facility impacts would occur through administrative and computer coordination with new or existing access control systems.  At many of the facilities, the infrastructure is already in place, such that no new cables or installation would be needed.  In the cases where new cables are needed, installers would be expected to use power hand tools and some light industrial equipment, such as trenchers.  There would be some noise and air emissions during installation, which would be expected to take less than 1 day per reader.  Waste could consist of metal, wood, wiring, and debris from the installation site, such as asphalt, soil or concrete.  They would be of limited quantity, and would be involved in the preparation of a linear access area for a cable conduit.  They are not hazardous materials, and would be disposed of in on-site dumpsters and other waste systems.  Little or no maintenance is expected for the cable conduit; in the case of cable repairs, new cables could be pulled through established conduits with no noise impacts or air emissions, and with minimal waste effect from old cables.  It is not anticipated that any of the cable conduits will be installed in or near the marine side of the facility (since access will be from the land side).

The TWIC readers need not be larger than a device used to scan a credential the size of a credit card.  TWIC readers also operate with low power requirements, and have a compact footprint.  We do not expect other infrastructure elements to be affected, so that there are minimal or no potential impacts to any environmental resources from the installation and maintenance of TWIC readers at the facilities.  There could be some impacts on workers, but the only large population potentially affected is the truck operators entering container facilities.  The FPEA focuses on these facilities because there are millions of truck trips per year for these facilities and any impacts predicted there would far exceed any potential impacts from a few hundred trucks per day that may enter another facility (such as a cruise ship facility) for ship stores or maintenance.  The TWIC readers will also require some annual maintenance, and will frequently update computer elements such as the Canceled Card List (CCL) feature.

1.3 Purpose and Need for the Proposed Action
The purpose of requiring electronic TWIC readers is to enhance the security of the nation's vessels and facilities by ensuring that only persons who are valid TWIC-holders are granted unescorted access to secure areas.  It implements the MTSA security card requirement, as well as the requirements of the SAFE Port Act for regulations on electronic TWIC readers for use with TWICs.  Previous studies on homeland security have identified the need to protect these vessels and facilities from potential threats, as well as a need to avoid disruptions due to accidents and other events, such as chemical spills or extreme weather.  Without regulation, it is unlikely that owners and operators of "at-risk" U.S. vessels and port facilities will voluntarily incur the costs to develop, acquire, install, operate, and maintain approved and tested technology for access control.  This final rule provides for a national access control system that will perform identity authentication, credential authentication, and credential validation.  The preferred alternative discussed here and in the RA addresses this purpose and need.

2.0 Alternatives

National Environmental Policy Act of 1969, as amended (NEPA, Pub. L. 91-190) regulations require that a decision-maker consider a full range of reasonable alternatives to achieve the purpose and need of the program.  The first alternative is the no action alternative, in which the program is not implemented  -  which forms the baseline for the analysis and comparison of effects from the other alternatives.  Next, reasonable action alternatives are considered  -  ones that generally span the range of possibilities for the program.  While analyzing these alternatives, NEPA also requires that the U.S. Coast Guard (USCG) assess direct, indirect, and cumulative impacts.  Based on these analyses, a preferred alternative is then selected; this analysis seeks to find the alternative with the lowest environmental impact that also meets the purpose and need of the program.  This chapter analyzes four alternatives for the program and then provides a summary (Table 1).

2.1 Scope of Work and Issues Considered
The USCG considered several alternatives in the development of this final rule.  These alternatives are based on several different combinations of vessel and facility populations facing TWIC reader requirements.  The selected alternative allows the USCG to target the highest risk entities while minimizing the overall burden.  For a complete discussion of the alternatives, see Chapter 6 of the Final Regulatory Analysis (RA), also located in the docket for this rulemaking (USCG-2007-28915).

The full range of potential environmental issues resulting from electronic TWIC reader requirements were considered in this FPEA, but only those related to air quality were considered as potentially significant, and only those are analyzed in detail.  Other environmental issues were considered, but not evaluated for the purpose of this Final Programmatic Environmental Assessment (FPEA).  Those issues are discussed in Section 3.4 of this FPEA.  Because of the limited scale of potential impacts, carbon footprints, and the generation of greenhouse gases (GHGs), climate change is not expected to be affected by TWIC reader activities.

No environmental issues were identified in public comments to the Advance Notice of Proposed Rulemaking (ANPRM), the Notice of Proposed Rulemaking (NPRM), or the Draft Programmatic Environmental Assessment (DPEA).  In the preferred alternative, the USCG only considers high-risk (Risk Group A) vessels and facilities for electronic TWIC inspection requirements.  These high-risk locations are already highly developed environments and have few, if any, biotic resources located within them.  Therefore, there are no expected impacts on biological resources, including endangered species.  The USCG expects few, if any, terrestrial or aquatic resources to be affected by these activities.  

The USCG expects that socioeconomic impacts, if any, will be indirect, through potential delays to truck trips.  We expect potential economic impacts on port facilities, with special consideration of impacts on truck drivers, to be self-correcting, in that facilities will take measures to assure that throughput (and therefore business) is maintained at the facilities.  Other operations at the ports (those not involving trucks at container facilities), such as the use of maintenance vehicles and delivery of ship stores to cruise ships and passenger ferries, involve a relatively small number of vehicles compared to the large number of trucks used in the container ports (approximately 150 trucks per day for smaller operations compared to more than 4,000 trucks per day at large container ports).  Due to the low number of vehicles involved, the smaller operations were not analyzed.  Thus, the remainder of this FPEA focuses on the impacts at container facilities.

2.2 Alternative 1: No Action (Maintain the Requirements from the TWIC 1 Final Rule)
This alternative would require that no TWIC readers be used, and the regulated entities would continue to use TWICs as a visual identity badge for mariners and workers requiring unescorted access to secure areas.  The USCG rejected this No Action Alternative, since it would not meet the purpose and need to provide secure identity verification and card authentication and validation, and it would ignore Congressional intent for mandatory TWIC reader requirements where operationally feasible.  By forgoing TWIC reader technology, this alternative would exclude the use of the additional security features of the TWIC and would render the electronic and biometric access control features of the card useless.  However, analysis of the no action alternative is required under NEPA in order to evaluate the potential impacts of not taking any actions to implement the purpose and need of the activity.  Under this alternative, TWIC readers would not be used on any vessels or in any facilities, so there would be no potential positive or negative environmental impacts.

2.3 Alternative 2 (preferred): TWIC Readers at High-risk Ports Only
Under this alternative, vessels, facilities, and OCS facilities would be divided into two risk categories, as determined and presently classified by the Maritime Security Risk Analysis Model (MSRAM), Analytical Hierarchy Process (AHP), and other factors (see Appendix H).  The risk groups are designated as Risk Group A and "other" facilities.  Those vessels and facilities falling into the highest risk group (Risk Group A) would be required to use a TWIC reader to perform the biometric match (e.g., as proposed in the NPRM, this will likely be the use of fingerprints) and verify the authenticity and validity of the card at each entry.  Vessels and facilities in the other risk group will not be required to use TWIC readers.  Facility and vessel owners or operators are allowed to utilize either fixed or portable TWIC readers.  The USCG chose this alternative as the preferred alternative because it best meets the purpose and need of the program and has been found to have no significant environmental impacts.  In the current final rule, the USCG uses a risk-based approach for determining compliance.  A vessel or facility in the highest risk category will have more stringent requirements than those in lower-risk categories.  When TWIC readers are required, they are used in two modes.  Mode 1 is use of the TWIC reader to verify the TWIC, including status, expiration date, and visual verification of identity.  Mode 3 is Mode 1 plus a biometric reading to verify identity.  Modes 2 and 4 were not used in the analysis because they were not proposed in the NPRM or implemented in the final rule.	

In 2006, the Security and Accountability For Every SAFE Port Act of 2006 (SAFE Port Act) established a requirement to conduct a pilot program to test the business processes, technology, and operational impacts required to deploy TWIC readers at secure areas of the marine transportation system.  In addition, the USCG prepared an independent study of port congestion for the purpose of this FPEA.  Information from both the pilot study and from the USCG's independent study is incorporated into our analysis.

Under this alternative, all but three container facilities in the U.S. would be classified in the lower Risk Group.  Three container facilities in two Florida ports (Port of Palm Beach and Port Everglades) would be classified as Risk Group A.  Under this preferred alternative, only these container facilities would be required to deploy TWIC readers, and only these facilities would have potential environmental impacts from the TWIC readers.  

2.4 Alternative 3: All Container Facilities Deploying TWIC Readers in Mode 1 (Verification with No Use of Biometrics)
Under this alternative, TWIC readers would be required and used in accordance with the description in Alternative 2, with the exception that all container facilities (not just those assigned to Risk Group A) would be required to use them as visual identification and validation, but with no use of the biometric validation feature.  The USCG only considered container ports because they represent the major volume of truck traffic, which could impact air quality through their emissions.  The USCG ultimately rejected this alternative because it did not adequately fulfill the objectives of the program.  This alternative would result in minor improvements in air quality because the TWIC readers provide faster processing times than the visual credential check without the TWIC reader.  Under this alternative, there would be potential positive environmental impacts at container ports from reducing truck idling time at these facilities. 

2.5 Alternative 4: All Container Facilities Deploying TWIC Readers in Mode 3 (Use of Biometrics)
Under this alternative, TWIC readers would be required and used in accordance with the description in Alternative 3 (deployment of TWIC readers at all container facilities), but under this alternative, the TWIC readers would use Mode 3 at all facilities.  Thus, all facilities would be required to do both visual verification plus biometric validation.  This alternative would lead to potential environmental impacts at all container ports, and might trigger the need for mitigation under the Clean Air Act of 1970 (CAA).  A full discussion of a range of mitigation options is discussed in Section 4.3 of this FPEA.

2.6 Alternatives Considered but not Further Analyzed 
Risk-Based Approach from the TWIC ANPRM Plus Mandating TWIC Operational Procedures in Ports.
In this alternative, which is similar to Alternative 2, USCG would propose TWIC operational procedures to reduce potential environmental impact.  The USCG rejected this alternative because it would unduly reduce business flexibility and independence without adding additional benefit to the purpose and need of the TWIC Reader program.  Business operations need the flexibility to institute the most efficient and cost-effective processes.

2.7 Summary of Environmental Impacts of Proposed Action and Alternatives
Using air quality models developed by the U.S. Environmental Protection Agency (EPA), and in consultation with EPA, the USCG analyzed four alternatives with respect to potential environmental impacts on air quality at U.S. ports: Alternative 1, the no action alternative; Alternative 2, which uses TWIC readers only in high-risk ports; Alternative 3, which uses TWIC readers in all ports for validations only, without biometrics; and Alternative 4, which uses TWIC Readers at all ports for both validation and biometrics.  Alternative 1 did not meet Congressional requirements and was rejected.  Alternative 2 is the preferred alternative because it is the most effective for the purpose and need of the program, and because there are no significant environmental impacts.  Alternative 3 appears to have the lowest environmental impact (and potentially some minor improvements to air quality due to faster processing of truck entries with TWIC readers) because it only uses TWIC readers for validation and therefore does not have the truck delays due to the biometric protocol.  Alternative 3 was not chosen because it does not meet the needs of the program.  Additionally the potential benefits to air quality resulting from that alternative are negligible; the difference in air emissions between it and the baseline is only fractions of tonnes.  Furthermore, the potential air quality improvements may not fully occur if additional time is needed to reconcile delays in the TWIC reader process (i.e., the TWIC reader does not validate the driver due to the range of potential problems with cards, TWIC readers, or driver's biometrics).  Even in the worst-case scenario of Alternative 4, the potential air quality impacts would be considered insignificant under the CAA.  As a measure of the low impact from truck delays on air quality, as measured by the EPA model, the USCG is estimating delays of 2.5 to 2.75 seconds and we have calculated that delays would have to exceed 6 minutes per truck before air quality standards are violated even in the non-attainment areas.

The high-risk ports under Alternative 2 are three Florida facilities, where TWIC readers will be used to confirm current validity of the card, and the driver's identity (by matching the picture from the card with the driver, and by taking a biometric reading from the driver).  This is because the TWIC readers at Florida ports will be used in Mode 3 since it is a Risk Group A (high-risk) facility; Risk Group A vessels and facilities are required to use Mode 3 in this final rule.  .  The impacts on air quality are insignificant and fall within the de minimis CAA thresholds.  The USCG also expects that changes in facility operations will mitigate any impacts of delays on business operations.  It should be noted that the above changes in the facility operations are based on the Transportation Security Administration pilot studies.
BASED ON THE PURPOSE AND NEED OF THE TWIC READER PROGRAM AND THE INSIGNIFICANT ENVIRONMENTAL IMPACTS, ALTERNATIVE 2 IS RECOMMENDED AS THE PREFERRED ALTERNATIVE.
                Table 1. Summary of Alternatives for TWIC FPEA
Alternative
Facilities Affected 
Pro environmental concerns
Con environmental concerns
Choice 
1. No action (no TWIC readers) 
None
No environmental impact, required by NEPA 
Violates Congressional mandate and fails to utilize security features of TWIC

2. Container facilities as presently classified by MSRAM  -  TWIC readers at high-risk facilities only 
3 container facilities in 2 ports in Florida (as per MSRAM high-risk classification)
Impacts only in 2 ports, truck delays lead to insignificant air quality deterioration, no impacts in other ports
Other ports fail to gain minor improvement in air quality
Preferred choice: meets purpose and need of the TWIC Reader program; FPEA proposes FONSI
3. Use TWIC readers in Mode 1 (validation only) only at all container facilities
All container facilities  
Minor or no air quality improvements in all ports from current ambient conditions 
All container facilities not required to use Mode 1, due to security classification; implementation may require changes in business and security practices
Does not meet program need; lowest environmental impact 
4. Use TWIC readers in Mode 3 (validation plus biometric) only at all container facilities
All container facilities 
Insignificant air quality deterioration in all ports
All container facilities not required to use Mode 1, due to security classification; 
implementation may require greater changes in business and security practices due to longer delays at entrance

3.0 Affected Environment

The Proposed Action would occur at port facilities and on vessels throughout the United States and its territories, hence the broad scope, making this a Final Programmatic Environmental Assessment (FPEA).  The ports and vessels vary in size and economic importance.  The ports considered were all the facilities regulated under the Maritime Transportation Security Act of 2002 (MTSA) throughout the United States.  This FPEA addresses the security of entry to these ports on the land side by controlled access through the use of Transportation Worker Identification Credentials (TWICs) and TWIC readers.  The water side is generally regulated through MTSA procedures.  While it is expected that vessel access would be partially regulated through the use of TWIC readers, any potential environmental consequences are considered minimal and are not considered further in this FPEA.  

The primary potential environmental concern is a change in air quality from truck emissions due to possible delays, attributed to TWIC reader operations at the entrance to the facilities (as described in Section 1.2 of this FPEA).  Other environmental resources and issues that were considered but not analyzed are discussed in Section 3.4.  Related factors include the locations of the facilities in relation to ambient air quality, the sizes of the business operations (in terms of numbers and types of trucks involved), and the applicable State and Federal air quality regulations.  The United States Coast Guard (USCG) expects that air quality will be affected (positively or negatively) in all locations where TWIC readers are used.  This may or may not lead to violations of Federal air quality standards pursuant to the Clean Air Act of 1970 (CAA).  Port facilities where air pollution levels persistently exceed the National Ambient Air Quality standards (NAAQS), designated "nonattainment" under the CAA, would not be allowed to create additional air pollution unless there are acceptable offsets as specified in the CAA.  Other regions with acceptable air quality (known as attainment areas) may be allowed additional air pollution, including additional truck emissions. 

3.1 Physical Environment
3.1.1 Location of Port Facilities
While the port facilities are located along the entire coast and some inland waters of the United States, the 10 largest ports (listed in Table 2) encompass more than 85% of the truck-related traffic, and the top 15 ports account for 94% of the truck-related traffic.  The majority of trucks are for drayage  -  which is the movement of containers within the ports and between the ports and other facilities, including railroads and container terminals, and within storage yards.

In order to study the potential utility and impacts of TWIC readers, the Transportation Security Administration (TSA) conducted pilot studies on seven major sites (some with multiple facilities, as described in Table 3).  Legislation mandated that data from these sites be used to inform the TWIC reader rulemaking.

The data in Table 2 is derived from the U.S. Army Corps of Engineers (USACE, 2011).  The 10 largest ports account for 85% of all U.S. container traffic.  Ports that participated in the TSA pilot studies are highlighted in bold.

Table 2. North America Container Traffic Annual Port Ranking by TEUs (Tonnage Equivalent Units)
                                     2009
                          Continental U.S. Ports Only
Rank
Port
TEU
Subtotal
Cumulative %
1
The Port of Los Angeles
                                                                      6,748,995
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2
Port of Long Beach
                                                                      5,067,597


3
The Port Authority of New York and New Jersey
                                                                      4,561,527


4
Port of Savannah
                                                                      2,356,512


5
Port of Oakland
                                                                      2,050,030


6
The Port of Houston Authority
                                                                      1,797,198


7
Port of Hampton Roads (VA)
                                                                      1,745,228


8
Port of Seattle
                                                                      1,584,596


9
Port of Tacoma
                                                                      1,545,853


10
Port of Charleston
                                                                      1,181,353
                                  28,638,889
                                      85
11
Port of Miami
                                                                        807,069
 
 
 
 
 
 
 
 
 
 
12
Port Everglades
                                                                        796,160


13
The Jacksonville Port Authority
                                                                        753,647


14
Port of Baltimore
                                                                        525,296


15
Port of Wilmington (DE)
                                                                        259,964


16
Port of New Orleans
                                                                        229,067


17
Port of Wilmington (NC)
                                                                        225,176
                                  31,781,025
                                      94
18
Port of Philadelphia
                                                                        222,900
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
19
Port of Palm Beach
                                                                        199,393


20
Port of Gulfport
                                                                        198,900


21
Port of Boston
                                                                        187,094


22
Port of Portland
                                                                        174,203


23
Port of Mobile
                                                                        112,270


24
Port of San Diego
                                                                         95,515


25
Port Freeport
                                                                         74,466


26
Tampa Port Authority
                                                                         48,788


27
Port Panama City
                                                                         40,594


28
Port of Hueneme
                                                                         32,060


29
Port of Fernandina
                                                                         24,582


30
Port of Richmond
                                                                         24,380


 
                                     TOTAL
                                                                              
                                  33,670,413
                                      100

3.1.2 TWIC Readers at Pilot Facilities
TSA's studies on selected ports (Table 2) occurred in locations throughout the United States.  The USCG used this information to estimate waiting (idling) times for trucks at TWIC reader facilities in order to assess potential impacts on air quality in the U.S. and to estimate national and cumulative impacts associated with TWIC readers. 

            Table 3. TSA TWIC Reader Pilot Sites, 2011 (TSA, 2012)
                                  Region/Port
                                  Participant
                                   Category
                     Atlantic Northeast/Port of NY&NJ 
                                Brooklyn Marine
Break-Bulk

                                Maher Terminal
Container

                                 APM Terminal
Container

                              Staten Island Ferry
Large Passenger Vessel
                             Mid-Atlantic/Maryland
                               Watermark Cruises
Small Passenger Vessel/Towboat/other
                     Pacific Southwest/ Port of Long Beach
                                      BP
Petroleum

                                 APL Terminal
Container

                     SSA (Stevedoring Services of America)
Container

                      TTI ( Total Terminal International)
Container

                                  Sea Launch
Small Passenger Vessel/Towboat/other

                                 Metropolitan
Break-Bulk
                     Pacific Southwest/Port of Los Angeles
                                  Shell Norco
Petroleum

                              World Cruise Center
Large Passenger Vessel

                                 NuStar Energy
Petroleum
                               Gulf Coast/ Texas
                                  Brownsville
Break-Bulk, Petroleum
                         Pacific Northwest/Washington
                              Clipper Navigation
Small Passenger Vessel/Towboat/other
                    Mississippi Waterway System/Mississippi
                                Magnolia Marine
Small Passenger Vessel/Towboat/other


3.2 Air Quality
3.2.1 The Clean Air Act of 1970
The CAA requires the U.S. Environmental Protection Agency (EPA) to develop, implement, and enforce standards for air pollutants that can cause harmful effects on the public health and welfare.  EPA developed national concentration-based standards (the NAAQS) for pollutants that have been determined to affect human health and the environment.  The EPA defines ambient air in 40 CFR part 50 as "that portion of the atmosphere, external to buildings, to which the general public has access." 
   NAAQS limits were established for nine criteria air pollutants: ozone (O3), carbon monoxide (CO), nitrogen oxides (NOx), sulfur oxides (SOx), volatile organic compounds (VOC), particulate matter (PM), particulate matter equal to or less than 10 microns in diameter (PM10), particulate matter equal to or less than 2.5 microns in diameter (PM2.5), and lead (Pb).  The primary NAAQSs represent maximum levels of ambient air pollution that are considered protective of public health.  See additional details in Appendix D of this FPEA.  
   
Carbon monoxide is generated from motor vehicles and wood burning, and is considered a human health risk.  Nitrogen dioxide is a product of that combustion as well.  Organic gases react with nitrogen dioxide to form ground-level ozone, which causes low visibility and negative health effects, including respiratory disease and eye irritation.  Particulate matter is a component of smoke, including diesel engine exhaust, and it can have a variety of negative health effects, depending on its chemical composition.  Sulfur dioxide, which is generated from the burning of fossil fuels, causes damage to vegetation and reduces the health of humans and animals.  Airborne lead, which is generally produced by automobiles, can cause blood-related effects, and may also affect the central nervous and reproductive systems.

3.2.2 Air Quality Designations
   An attainment area is any area that meets (i.e., is in compliance with) the national primary or secondary ambient air quality standards for any criteria pollutant or all criteria pollutants (EPA, 2011e).
   
The CAA requires States to designate any area that does not meet NAAQSs for a criteria pollutant as a nonattainment area.  In order to improve air quality in non-attainment areas, states must draft a plan known as a State Implementation Plan (SIP) to show methods to improve the air quality.  The SIP outlines the measures that the State will take to improve air quality (EPA, 2011d).  SIPs often incorporate different strategies, such as the use of a permit system.  Each designated nonattainment area for O3 must be classified as marginal, moderate, serious, severe, or extreme, based on ambient O3 concentrations.  More than 40 U.S. ports nationwide are located in nonattainment areas for O3, PM, or both (EPA, 2011j). 

A maintenance area is an area that was once nonattainment but has achieved attainment for any or all NAAQSs (EPA, 2011d).  These maintenance areas must also develop a SIP in order to continue meeting NAAQSs standards and prevent "backsliding" to a nonattainment designation (EPA, 2011d).

For the purpose of this FPEA, we examined nonattainment and maintenance area compliance requirements since most of the ports described in the following sections are located within these designated areas.  Port Everglades and Port of Palm Beach, although located in attainment areas for all NAAQSs, have special compliance requirements under the now revoked 1-hour ozone standard and are subject to the SIP for this standard (as listed in Table A.6).

3.2.3 The General Conformity Rule and the De Minimis Thresholds
In November 1993, EPA promulgated a set of regulations known as the General Conformity Regulations, which apply to all Federal actions that are not related to highways and mass transit actions for which the Transportation Conformity Regulations apply (EPA, 2011b).  The General Conformity Rule ensures that the actions taken by Federal agencies in nonattainment and maintenance areas do not interfere with a State's plans to meet the NAAQSs (Landrum & Brown, Inc., 2008).  The General Conformity Rule applies only to Federal actions that are:

   * Federally funded or Federally approved;
   * Not a highway or transit project;
   * Not identified as "exempt" under the CAA and not identified on the approving Federal agency's "Presumed to Conform" list;
   * Located within a nonattainment or maintenance area; and 
   * Identified as a Federal agency's preferred alternative (Landrum & Brown, Inc., 2008)

The Rule establishes minimum values, referred to as de minimis thresholds (listed in Table 4), for the criteria and precursor pollutants.  If total project-related emissions equal or exceed the de minimis values, a General Conformity Determination must be prepared to demonstrate conformity to the SIPs.  The General Conformity Rule was considered for all alternatives, although only required to be applied to the preferred alternative.

Air pollution activities that are generally less than the designated amount, as indicated in the type of area in Table 4, are not considered significant or in violation of standards.
                                       
             Table 4. De Minimis Levels under the CAA (EPA, 2011c)
Pollutant
Area Type 
Tonnes/Year
Ozone (VOC or NOx)
Serious nonattainment
                                                                             50

Severe nonattainment
                                                                             25

Extreme nonattainment
                                                                             10

Other areas outside an ozone transport region
                                                                            100
Ozone (NOx)
Marginal and moderate nonattainment inside an ozone transport region
                                                                            100

Maintenance
                                                                            100
Ozone (VOC)
Marginal and moderate nonattainment inside an ozone transport region
                                                                             50

Maintenance within an ozone transport region
                                                                             50

Maintenance outside an ozone transport region
                                                                            100
Carbon monoxide, SO2 and NO2
All nonattainment & maintenance
                                                                            100
PM10
Serious nonattainment
                                                                             70

Moderate nonattainment and maintenance
                                                                            100
Lead (Pb)
All nonattainment & maintenance
                                                                             25

3.3 Ports and Current Air Quality Status
The same concentration of pollutants may have differential effects in different locations because geographic and local climatic factors influence air quality dynamics.  For example, the Port of Los Angeles in southern California has a history of poor air quality resulting from a combination of dense human population and ambient air conditions, such as poor air circulation and warmer temperatures.  In contrast, a port with strong breezes and ample rainfall may not experience such poor air quality even when emissions may be elevated.  For example, high ozone levels in Florida only occur on a limited number of days per year, typically during spring through early fall, when hot weather conditions are most conducive to ozone formation (FDEQ, 2011). 

In recognition of the role that seaports can play in worsening already poor air quality, several U.S. ports have enacted programs to reduce adverse impacts (Port of Seattle 2010; see also Section 4.6.  Efforts include mandating the use of newer trucks (which have lower emissions), retrofitting diesel engines on on-site equipment, promoting use of cleaner fuels, improving operational efficiency to reduce engine idling, providing shore-side electric power hook-ups to reduce ship auxiliary emissions, imposing speed limits on arriving and departing vessels, and purchasing new equipment with engines that meet stricter standards (American Association of Port Authorities, 2011 #2364).  The Port of Los Angeles has shifted some operations to nighttime hours to reduce traffic congestion and emissions from idling engines (Sharma 2009).

The top ten port facilities in the U.S. are in non-attainment areas.  This FPEA uses these facilities as representative of air quality and includes: the Port Authority of New York and New Jersey (PANYNJ); the Port of Los Angeles and Long Beach (LA/LB) in California; the Port of Houston, Texas; and the Port of Hampton Roads in Virginia. 

Two ports examined in this FPEA that are excluded from this "non-attainment" group are the Port of Palm Beach and the Port Everglades, which are located in Palm Beach and Broward Counties, respectively.  These ports are located in the Southeast Florida airshed designated as attainment for all NAAQSs.  However, the airshed was designated an ozone maintenance area in 1995 under the now revoked 1-hour ozone standard.  The maintenance plan, which established the strategy for control and reduction of ozone emissions, remains effective through 2015 (Landrum & Brown, 2008).  This airshed is also obligated to comply with the SIP for the revoked 1-hour standard for ozone. 

Additional details on the ports are contained in Appendix A. 

3.4 Environmental Resources and Issues Not Likely Affected by TWIC Readers
The impacts of each alternative on the following resources were considered but not evaluated because they did not appear to have the potential for significant environmental impact based on the description of the TWIC reader program in Section 1.2 of this FPEA.  

3.4.1 Installation and Operation of TWIC Readers at Port Entrances
A full description of the TWIC Reader program is found in Section 1.2 of this FPEA, and a description of the operation of facilities using TWIC readers is found in Section 4.2.1.3.  The operation of TWIC readers at ports may result in longer vehicle queues (primarily for trucks), and a resultant increase in transportation-related air emissions during idling.  However, the increase in idling time attributable to TWIC readers themselves is minor, in the magnitude of seconds, and is likely to have minimal environmental effects on air quality.  Most of any vehicle queuing is expected to occur due to cargo manifest checks, vehicle safety checks, or delays from attempted unauthorized entry.   

The installation of TWIC readers will likely be on vessels and existing structures at port and facility entrance gates.  Small amounts of airborne particles may be produced as a result of installation activities.  Other possible short-term impacts to air quality from installation activities include CO and NOx emissions resulting from fossil fuel-burning installation equipment, and emissions of reactive organic gases and hazardous air pollutants from paints, thinners, and other solvents used during installation.  Quantities of these pollutants will likely be negligible.  

The use of best management practices (BMPs) during installation can keep emissions to negligible levels for workers and the surrounding area.  Examples of BMPs for installation activities include shrouding areas to prevent dust, use of low-VOC coating systems, aural protectors for workers installing the TWIC readers, and proper tuning of installation equipment with engines.  Noise and soil disruption should be minimal.  As a result, the environmental impacts of TWIC reader installations, as well as maintenance of the facilities, should be minimal.  

3.4.2 Operation of TWIC Readers Aboard MTSA-regulated Vessels
Based on the current operation practices of MTSA-regulated vessels entering the United States via sea ports-of-entry, there is no anticipated environmental impact expected with implementation of TWIC readers on vessels, from the action alternatives presented in this analysis.  While vessel implementation may change operation procedures, the USCG does not anticipate significant programmatic environmental consequences of these changes, because the vessel's processes will continue to be managed and operated within the existing physical environment of the vessel.  In addition, vessels will likely be moored at the ports-of-entry and not loitering, and hence they would not be expected to increase air and water emissions in coastal zones as a result of implementing TWIC readers.  Therefore, the USCG does not anticipate any impacts to the natural environment as a result of TWIC reader implementation on vessels.

3.4.3 Human Health and Safety
TWIC readers are not expected to have any significant impacts on human health and safety in that the TWIC reader programs will cause only minor infrastructure changes and emission changes to large, existing ports (see Section 1.2).  Similar physical access controls are already installed and used in the port setting, and based on observations from USCG site visits, there were no observations of potential human health and safety issues.  

3.4.4 Energy
Current energy use at port entrances includes energy for facility management and for technology such as computers and physical access controls.  Vehicles also consume energy while idling at gate entrances.  The power requirements of a TWIC reader are minimal and similar to other Facility Access Control systems that are already used in ports (see Section 1.2).  Based on observations from USCG site visits, no observations of energy impacts were observed.  Thus, there is little to no potential to significantly impact the environment by additional energy use for the alternatives reviewed.   

3.4.5 Land Use  
TWIC readers are not expected to affect land use in ports (see Section 1.2).  Based on observations from USCG site visits, construction and installation impacts are minimal and will mostly use existing infrastructure to support TWIC readers.  Many ports already use a physical access control system, and TWIC readers will replace or supplement them.  At a national level, the USCG does not expect these impacts to be significant.

3.4.6 Waste Impacts
Because of the relatively minor construction activities and equipment replacements associated with each alternative (see Section 1.2), this TWIC reader program will generate minimal solid waste or electronic waste, and the USCG expects few or no impacts. 

3.4.7 Water Resources 
For purposes of this analysis, the Coast Guard considered potential to increase impervious surfaces and atmospheric deposition of particulates as it relates to possible construction activities or air quality impacts resulting from the action alternatives compared to those in the No Action Alternative.  While the USCG expects minor construction activities and possible runoff from these activities (see Section 1.2), and while there is also minor atmospheric deposition to water bodies associated with air emissions, the USCG does not expect significant surface or groundwater impacts. 

3.4.8 Biological Resources
Impacts to biological resources can occur directly when individuals or habitats are disturbed or destroyed, or indirectly, through changes to food, water, or air.  Because of the relatively minor construction activities expected with each alternative (see Section 1.2), and a minor change in vehicle wait times, with a likely low impact on air quality, no significant biological resource impacts are anticipated.  The USCG does not expect direct impacts from TWIC readers.

3.4.9 Historic Properties
Installation of TWIC readers will be performed in areas where construction and development likely has already taken place within a port facility.  Historic properties are not expected to be located in these areas, and USCG site visit observations confirm this (see Appendix G).  If so, the installation of these TWIC readers will not result in the construction or the significant modification of buildings, and will likely occur only at outside locations.  Therefore, there is no potential for impact to historic properties.

3.4.10 Environmental Justice
Since installation and implementation of TWIC readers are limited to existing, highly developed industrial sites, and since the environmental impacts are expected to be de minimis, no populations, including minority populations and Tribal governments, are expected to suffer disproportionately high or adverse impacts. 

3.4.11 Socioeconomics
The MTSA-regulated ports and facilities that will fall within the TWIC reader program occur along the entire coast and some inland waters of the U.S., in a zone that covers more than 4 million square miles (the largest in the world), along a shoreline more than 95,000 statute miles in length (Kildow et al., 2009).  The coastal areas of the United States support a significant portion of the economy, including employment, recreation, tourism, commerce, and energy production (NOAA, 2010).  The U.S. coastal and ocean economies represent the dual nature of economic activity that takes place within the coastal states (coastal economy) and economic activity that actually depends on the ocean (the ocean economy).  The 30 coastal and Great Lakes States together account for 83% of the U.S. economy, and together they generate a gross domestic product (GDP) larger than that of any other nation (Kildow et al., 2009).  The four major components of the combined coastal and ocean economies are recreational fishing, commercial fishing, ports, and energy production (NOAA, 2010 SOTC).

The coastal economy is predominantly urban, with more than 80% of the residents in coastal States living within a metropolitan area.  Typical urban problems, such as overcrowding, high cost of living, pollution, and traffic congestion, occur in these coastal settings (Kildow et al., 2009).  The ocean economy is dominated by place-dependent tourism and recreation, supporting 1.7 million jobs in 2007.  In 2007, more than 69 million people were employed in coastal counties, and wages paid to employees totaled about $3.4 trillion (Kildow, 2009).  Marine transportation generates the second-largest GDP in the ocean economy.  Maritime shipping has been increasing in recent years, and is expected to continue to grow; it is estimated that much of the marine transportation economy is closely related to the land portion of the container port operations, including truck and rail operators.  Other sectors of the ocean economy include shipbuilding, harvesting living resources, mineral extraction, and marine construction (Kildow et al., 2009).  

The tourism, recreation, transportation, and shipbuilding sectors come together in the burgeoning cruise ship industry, where the United States is the worldwide leader.  From 2000 to 2005, the number of global cruise passengers increased by more than 30 percent.  In 2006, 75% of global cruise ship passengers began their trip in a U.S. port, half of them in Florida.  In fact, Florida supports more than 40% of embarkations worldwide.  The size of cruise ships, the number of passengers, and the frequency of trips have all increased in the last few years (Kildow et al., 2009). 

The TWIC reader program is not expected to have a significant impact on the socio-economic environment.  Some jobs may be shifted and some temporary disruption of traffic flow may occur during implementation of the TWIC readers, but once the system reaches steady state, effects should be minor when compared to maintaining the status quo.  In a similar manner, the addition of some security features and amendments to facility security plans are not expected to have significant impacts on the socio-economic environment, since they are minor changes to already existing programs and procedures.

3.4.12 Endangered Species
No endangered species are known to exist in the secure zone in port areas, which are already highly perturbed.  A list of known endangered species in each region of the United States has been reviewed and is available in USCG files.  None of these species are known to exist in the three Florida facilities, or in other potential areas that might be potentially affected under other alternatives.  Terrestrial resources are highly urbanized, and would not be affected further by the proposed alternatives.  TWIC readers are expected to have little or no impact on aquatic resources (see Section 1.2).  Therefore the USCG we conclude that no effects on endangered species are expected. 

3.4.13 Climate Change
Because of the limited scale of potential impacts, carbon footprints and the generation of greenhouse gases (GHGs), and thus climate change, are not expected to be impacted by the activities required by this final rule.  GHGs generated by additional truck idling are reduced or unaffected in all but two ports.  In the two affected ports, emissions are under 25,000 tonnes/year, which is the threshold of concern for GHGs and their impact on climate change; in the most damaging alternative, the container ports would generate less than 17 tonnes of CO2 per year. 

3.4.14 Noise
Noise pollution, characterized by the excessive degree of unwanted sound, has become an increasingly important environmental concern for port managers (NoMEPorts, 2008).  Many ports around the world operate 24 hours a day, generating noises that can adversely affect nearby sensitive areas such as commercial offices or private dwellings.  Ports, especially those in urbanized settlings, tend to be noisy (diBella et al., 2008).  Sustained sources of noise common at most ports include loading and unloading operations, vessel engine noise, pumps, fans, and generators.  Other sources of noise that are not directly generated by port operations but that contribute to the overall noise levels in the vicinity include vehicular, shipping, and railroad travel near the port. 

It does not appear that there is significant additional noise associated with the TWIC reader program, since trucks must stop at port access points with or without the TWIC reader program.  There is some minimal additional noise associated with the idling of the trucks, but this is expected to be self-correcting and will not contribute significant additional noise to the port areas.
   

   
   
   
4.0 Environmental Consequences
4.1 Summary

Using the methodologies and data described below, the U.S. Coast Guard (USCG) analyzed the potential impacts of a Transportation Worker Identification Credential (TWIC) reader program with respect to the potential environmental impacts of the four alternatives (described in Chapter 2) on the affected environment (described in Chapter 3).  Essentially, the USCG compared increased truck emissions from any increased idling caused by the use of TWIC readers were to ambient air quality conditions and to standards under the Clean Air Act of 1970 (CAA). 

Based on these analyses, it appears that potential environmental impacts from the TWIC reader program will be insignificant.  For the preferred alternative, except for three facilities at two Florida ports, entry operations at all container ports are expected to be faster and result in lower truck emissions, which will in turn lead to improved air quality.  In the three Florida ports, processing delays, if they occur, will result in additional air quality emissions.  However, these emissions will occur in areas that are classified as attainment under the CAA, and the emissions will not result in any significant increase in air pollution.  The emissions do not reach the de minimis thresholds under the CAA.  The USCG also expects that these ports will offset any delay times due to the need to maintain truck throughputs to maintain business processes, and thus even the minimal increases in truck emissions may be avoided. 

4.1.1 Applicability of Models and Data Sets Used
In order to estimate the potential environmental impacts of the proposed alternatives, the USCG used three primary data.  First, data from the TWIC pilot study, conducted by the Transportation Security Administration (TSA), provided information on truck traffic and processing times for entry to pilot port facilities with and without TWIC readers used in Modes 1 and 3 that is, with and without biometrics (TSA study, 2011).  Second, studies on congestion and operations were conducted through a contractor and provided supplemental data on mitigation operations for impacts.  Third, studies provided by the U.S. Environmental Protection Agency (EPA) on data related to drayage at U.S. ports informed estimates of total truck traffic at specific port facilities, idling times, as well as diesel emission rates for trucks idling at these facilities (EPA 2011 a-j).  Additional details on the data sets appear in Appendix C.  

Based on data from the TSA pilot studies, delays due to TWIC reader operations are expected to be 1.75 seconds per transaction in Mode 1 and 8.36 seconds in Mode 3 (see Appendix C).  The USCG adjusted these transactions times as discussed below for the purpose of this analysis.  For the purposes of calculating a transaction time when using TWIC readers in Mode 1, we added these 3 seconds to the 1.75 seconds for a Mode 1 transaction, resulting in 4.75 seconds for a complete verification.  Thus, according to the calculations in this Final Programmatic Environmental Assessment (FPEA), a Mode 1 transaction is 1.25 seconds faster than a visual inspection without using the TWIC reader.  The baseline for Mode 3 is the Mode 3 transaction time of 8.36 seconds minus the visual impact time of 6 seconds, for a net Mode 3 transaction time of 2.36 seconds.  This means that a Mode 3 read is 2.36 seconds slower than a visual inspection without a TWIC reader.

4.1.2 Uncertainty of Data
Although these data sets represent an initial effort to estimate potential processing times, and hence, potential delay times associated with TWIC reader use, they are based on a limited set of facilities and the full confidence limits or uncertainty associated with these numbers is not known.  The confidence limits in Appendix C, Figure 2 are derived from these limited data sets and may not represent the full range of these values.  Based on discussions with port facility managers, it would appear that there is a wide range of delay times at different ports around these average values (see Appendix G of this FPEA).  There were sometimes shorter processing times when the TWIC was used in Mode 1, generally after truck drivers had become familiar with the systems and initial system conditions were stabilized.  One port facility manager reported that the TWIC program speeded the facility's operation and enhanced its security (including a drop in theft on the site, see Appendix G).  Conversely, one facility manager reported that there was a 17% failure rate, with resulting delays, in Mode 3 (i.e., when using of biometric scans), and another reported that there were longer delays in the entire process in cold weather, with obstacles such as removing gloves to perform biometric validation (see Appendix G).  At another interview with a port facility it was reported that during very high truck traffic on one day, the pilot program needed to be suspended in order to avoid long delays at the facility (see Appendix G).  This was attributed to start up and training issues, and not to the operation of the TWIC reader itself.  The analysis in this FPEA is based on the assumption that these data represent valid average processing times for TWIC reader operations nationwide.

4.1.3 EPA Data Sets
The EPA has collected data on freight truck operations at major U.S. ports through the SmartWay Transport Partnership (EPA 2011g).  Under the program, "Emission Reduction Strategies for Drayage Fleets," EPA developed data on rates of air emission for a fleet of trucks from different model years, tailored to specific port operations.  For instance, the Ports of Los Angeles (LA) and Long Beach (LB) require trucks from 2007 or later model years, effective January 2012, and therefore have smaller total unit emissions than other ports.  EPA developed a general model for trucks in U.S. ports (other than LA/LB) using data derived for the Port of Houston, as shown in Table 5.

Older trucks have much higher air emission rates.  This weighted average was used for all container port calculations, except for Port of LA, where a weighted average using newer trucks follows the state mandate banning trucks older than 2007 (see Section 3.3.1 for an additional description of air pollutants associated with emission rates).

Table 5. EPA Estimates of Emissions Rates from Diesel Truck While Curb Idling (EPA, 2011g)


                             Emission rate [g/hr]
Model year
% Trucks entering the port
NOX
PM2.5
THC
CO
                                                                       pre-1990
                                                                          3.55%
                                                                         181.98
                                                                           4.21
                                                                          15.41
                                                                          37.45
                                                                           1990
                                                                          0.65%
                                                                         140.55
                                                                           4.21
                                                                          15.41
                                                                          37.45
                                                                      1991-1993
                                                                          5.14%
                                                                         132.14
                                                                           4.21
                                                                          15.41
                                                                          37.45
                                                                      1994-1997
                                                                         24.25%
                                                                         132.14
                                                                           6.44
                                                                          15.41
                                                                          37.45
                                                                           1998
                                                                          9.84%
                                                                         110.96
                                                                           6.16
                                                                          15.41
                                                                          37.45
                                                                      1999-2002
                                                                         36.91%
                                                                         146.37
                                                                           6.16
                                                                          15.41
                                                                          37.45
                                                                      2003-2006
                                                                         13.48%
                                                                          53.84
                                                                           5.56
                                                                          10.07
                                                                          32.06
                                                                      2007-2009
                                                                          6.09%
                                                                          26.92
                                                                           0.30
                                                                           2.01
                                                                           6.41
                                                                           2010
                                                                          0.09%
                                                                           6.43
                                                                           0.19
                                                                           1.11
                                                                           3.53

Weighted Average rate
                                                                         120.05
                                                                           5.60
                                                                          13.86
                                                                          34.80

The EPA studies also developed data on operational characteristics such as the number of truck legs at a port on an annual basis, idling time for these trucks, and on the air quality at the ports, in association with the CAA program (EPA, 2011j).  These data are summarized here and discussed in greater detail in Chapter 5 and Appendix C of this FPEA.

4.1.4 Number of Trucks in U.S. Container Ports
The number of trucks in the major U.S. ports (Los Angeles, New York City, Houston, the Port of Virginia, Port of Palm Beach, and Port Everglades) was calculated from the EPA study by dividing the average annual Tonnage Equivalent Unit (TEU) count by the average TEU per container to calculate the number of trucks entering the port per year (EPA, 2011g).  The same process was used to calculate the Port of Palm Beach and Port Everglades, except that there was no information on the average TEU per container for these ports, so that the average TEU per container for the ports with data was used; TEU counts were from fiscal year 2011 (USACE, 2011).  The average annual truck traffic ranged from 8,468,921 trucks at the Port of Los Angeles, to 466,604 at Port Everglades.


Table 6. Number of Trucks U.S. Port Facilities During Latest Year Available for Each Port (derived from EPA, 2011g and USACE, 2011)
U.S. Port
# of trucks per year
LA (2007)
                                                                      8,468,921
Port of Virginia (2007)
                                                                      1,223,199
NY (2007)
                                                                      3,098,892
Houston (2007)
                                                                       633,5,42
Port of Palm Beach (2011)
                                                                        121,521
Port Everglades (2011)
                                                                        466,604
                                       
4.2 Analysis of Data
In order to estimate potential impacts on air quality due to truck idling (due to TWIC processing times), we calculated emissions data for each criteria pollutant at the affected ports.  Using guidance from EPA (EPA, 2011g) through several studies on "Transportation Conformity," the USCG used an annual standard.  Estimates were made under the scenarios associated with four alternatives for the actions, which represented the high-, mid-, and low-case scenarios of additional air pollution added to ambient air conditions for each port.  The analysis of this comparison then considered whether the port location was within a CAA attainment or non-attainment area.  In the analyses, air quality conditions at these major ports were analyzed and utilized in the calculations because they are the largest U.S. ports with the most truck traffic, and are located in areas with poor air quality (see Table A.6 .  Thus they are used as conservative representatives of conditions at other U.S. ports.  Significant impacts, if any, at these ports will likely be higher than impacts at other ports that are smaller and, in many cases, have better air quality.    

4.2.1 Idling Vehicle Pollution Calculations
 4.2.1.1 Formula for Calculation
To calculate the impacts on air quality due to truck idling time attributed to each TWIC reader mode, the USCG used the formula below.  This calculation provides the change in the amount of air pollution from trucks due to the use of TWIC readers. 







The results from equations above (i.e., estimated additional tonnes of air pollution for that facility) are then compared to information on ambient air quality to estimate potential air quality impacts as a result of changes to transaction times.  See Appendix C for details.

 4.2.1.2 Air Emission Rates
Air Emission rates were calculated by using EPA's mobile source emission model MOVES (Motor Vehicle Emissions Simulator), which estimates a range of pollutant criteria in gram-per-hour emission rates for curb-idling of drayage trucks (EPA Model).  These were then converted into average annual tonnes per year for each criteria pollutant.  One assumption in assessing the TWIC readers' impact on traffic delay is that the TWIC readers will only impact curb idling times (EPA, 2011j).  Emission rates used were port-specific rates that were calculated from the weighted average of model years for that port and are provided in Table 3, above.  The calculations for the Port of LA/LB use a different weighted average because the California Clean Trucks Program states that all truck models at ports must be 2007 or later, which is reflected in Table 7.

Table 7. EPA Estimates of Emissions Rates (g/hr) for Diesel Truck in Los Angeles/Long Beach Ports (EPA, 2011k)
 
                                 Emission Rate
Model Year
CO 
NOx 
PM2.5 
                                                                           2007
                                                                        3.52628
                                                                        26.9216
                                                                       0.016486
                                                                           2008
                                                                        3.52628
                                                                        26.9216
                                                                       0.016486
                                                                           2009
                                                                        3.52628
                                                                        26.9216
                                                                       0.016486
                                                                           2010
                                                                        3.52628
                                                                        6.42787
                                                                       0.016107
                                                                           2011
                                                                        3.52628
                                                                        6.42787
                                                                       0.016107
Weighted Average rate
                                                                        3.52628
                                                                      18.724108
                                                                       0.016335
                                       
To calculate the potential impacts on emissions from delays resulting from the implementation of TWIC readers, this FPEA used information on emissions, measured in tonnes per year, from EPA's 2007 Drayage Truck Report.  This FPEA used a port's TEUs per facility per year and divided it by the port's average TEUs per container.  This calculates the number of containers that enter the port each year, with one container per drayage truck.  The number of truck entries (TEU divided by average TEU per container) is then multiplied by the time associated with the impact of the TWIC reader.  This is separated into the transaction times of Mode 1 (1.75 seconds) and Mode 3 (8.36 seconds) (TSA Report)). 

 4.2.1.3 Assumptions
For the analysis, to express the difference in processing time between the baseline (which is visual inspection only, analyzed at 6 seconds in the TSA Report) and the delays in different modes several assumptions were made as discussed in detail in Appendix C and presented in Chapter 4 of this FPEA.  These include:

   1.          A Mode 1 Initial Capability Evaluation (ICE) transaction still requires a visual identification matching the photograph on the TWIC to the TWIC-holder.  There is some time saved in having the TWIC-holder flash a picture of the approved driver, with a camera display showing the driver and allowing the guard or video attendant to compare both images.  USCG subject matter experts estimated that it takes 3 seconds for this visual process when using a TWIC reader.  For the purposes of calculating a transaction time when using TWIC readers in Mode 1, the FPEA added these 3 seconds to the 1.75 seconds for a Mode 1 transaction, resulting in 4.75 seconds for a complete verification.  Thus, according to these calculations, a Mode 1 transaction is 1.25 seconds faster than a visual inspection without using the TWIC reader. 
         
   2.          The ICE transaction time reported for a Mode 3 transaction is 8.36 seconds.  However, a Mode 3 TWIC read does not require any visual inspection because it uses biometric (i.e., fingerprint) matching and, thus, 6 seconds per transaction (the time for a visual inspection as reported by TSA) is avoided.  In a Mode 3 transaction for an environmental analysis a potential impact from a baseline is analyzed.  The baseline for Mode 3 is the Mode 3 transaction time of 8.36 seconds minus the visual impact time of 6 seconds, for a net Mode 3 transaction time of 2.36 seconds.  This means that a Mode 3 read is 2.36 seconds slower than a visual inspection without a TWIC reader. 

   3.          An additional discussion on the impacts of TWIC reader failure rates (i.e., times when the TWIC reader transaction does not work) on these calculations is contained in Section 4.4.  When failures occur, additional time is needed to rectify the program, which adds additional time for truck idling.  The estimates of transaction times from TSA assume that most transactions will be successful and that most future failures will be minimized as technologies are improved.

   4.          Our analysis did not consider additive delays on following trucks because this initial analysis showed non-significant impacts.

   5.          The data is ICE data that was conducted to evaluate transaction times for processing data by the TWIC reader (TSA, 2012).  These data do not take into account total transaction times, which include the whole process of retrieving the card from the user and taking time to insert it in the TWIC reader.  For the NEPA analysis, we are comparing the additional time needed for use of the TWIC reader (and potential delays due to that use) against an existing baseline.  Since some facilities use other cards for access to secure areas, their use is included in the existing baseline transactional time.  Thus the net time for the use of the TWIC reader is fully accounted for in the ICE data.

In calculating potential impacts associated with delays from TWIC readers, the USCG considered which delays are specifically attributable to TWIC reader use, and which are associated with other sources.  We must first consider how the truck operations occur at a port facility.

When a truck arrives at the access point of a port facility, a series of operations begins.  Initially, the truck passes through a radiation detector.  Next, it enters a portal and several processes begin.  First, in California (and potentially in other ports), the model year of the truck is verified for compliance with California's truck model requirement.  Next, at most ports, a driver has to stop the vehicle and retrieve a port pass or other identification from their truck or pocket, and have it available for processing.  In some ports, a local port security program has the driver place the card in a TWIC reader, and in other cases the driver shows it to a guard.  In the process of placing a card in the TWIC reader, the driver has to put it in the proper orientation, which was observed to sometimes take several attempts, depending on the driver's experience with the facility. 

It would not be expected that the process of retrieving the identification/port card and placing it on a TWIC reader would require any more time, whether it is a TWIC or non-TWIC.  If a TWIC reader process is not already in place in a facility, the use of a new TWIC reader process would have some impact on entry time, but since TWIC readers are becoming a standard item in many ports, their use or non-use was not considered as a delay factor in the procedures and results reported by the TWIC reader pilot studies.

Another consideration is the relationship between processes that use the TWIC reader and those that involve visual verification of the card.  In the case where a TWIC is used for verification of identity instead of a port identification card, it is expected that the processing time would be equal and there would not be a delay due to the TWIC reader.  The TSA data have estimated the visual identification step to take 6 seconds.

In the case in which the TWIC is used in association with a TWIC reader (used in Mode 1 for verification), it is estimated by USCG subject matter experts that the visual identification step would take 3 seconds.  This is less than the 6 seconds required for visual inspection without the TWIC readers.  This lesser time occurs because the guard now only has to verify the photo to the TWIC-holder, as opposed to the conducting verification, authentication, and validity checks; card authenticity and validity are now checked by the TWIC reader.  The TWIC is then processed to check the validity of the card, and eventually to check it against a watch list and other databases, which takes approximately 1.75 seconds, with the total ICE transaction lasting approximately 4.75 seconds.  Thus, based on the TSA data, the TWIC reader saves 3 seconds for visual identification (6 seconds is reduced to 3 seconds) and adds 1.75 seconds for database processing in this step, compared to an operation without the TWIC reader.

Finally, in the mode in which the TWIC reader is used both for visual identification and biometric verification, the biometric step is additional when compared to current port security operations; the TWIC reader in that case adds approximately 8 seconds to the entry process, according to the TSA data.  It has, however, saved 6 seconds in visual identification time, resulting in a net delay, compared to the baseline, of approximately 2 seconds. 

4.3 Comparative Analysis of Proposed Action and Alternatives
4.3.1 Introduction
As presented in Table 1, four alternatives were analyzed with respect to potential environmental impacts on air quality at U.S. ports.  Alternative 2 is the preferred alternative because it appears to meet the purpose and need of the program and there are no significant environmental impacts on air quality.  Alternative 3 appears to have the lowest environmental impacts (with potentially some minor improvements to air quality) because it only uses TWIC readers in Mode 1 (validation only) and therefore does not have the truck delays due to the Mode 3 (biometric) protocol for Alternative 2.  However, the difference is small (see below) and the potential air quality improvements of Alternative 2 may not fully occur if additional time is needed to reconcile instances when the TWIC reader process fails (i.e., the TWIC reader does not clear the driver due (depending on the alternative considered) to the range of potential programs with cards, TWIC readers or the driver's biometrics).  

It is noted that even in the worst-case scenario of Alternative 4, air quality impacts are predicted to be insignificant.  As an indication of the low impact from truck delays on air quality, as measured by the EPA model, delays would have to exceed 6 minutes per truck before air quality standards are violated, even in the non-attainment areas.

4.3.2 Alternative 1, No Action Alternative
Under the No Action Alternative (Alternative 1), TWIC readers will not be deployed.  Therefore, there will be no potential environmental impacts attributable to the TWIC readers.  However, air emissions-generating vehicle queues could still result from required identification checks, freight manifest examinations, and other activities.  It would be expected that these activities would increase due to economic growth at the facilities and result in negative impacts on air quality at MTSA-regulated facilities.  No quantitative assessment can be made at this time due to uncertainties on growth in these facilities (which would be the basis for an analysis on impacts on air quality).   

4.3.3 Alternative 2 (preferred): TWIC Readers at High-risk Facilities Only
4.3.3.1 Result
Under this alternative, TWIC readers will only be used in facilities classified as Risk Group A as defined in the final rule.  Two container ports (containing three facilities) in Florida have this classification.  Thus only the container terminals of Port Everglades and the Port of Palm Beach will be required to use TWIC readers in biometric mode.  This requires the use of a TWIC reader's Mode 3, which has an estimated processing time of 8.76 seconds.  As discussed in Section C.2.2, this means that the use of Mode 3 is 2.76 seconds slower than visual inspection.  These data was then used to calculate potential increases in air quality at these facilities.  At all other ports, TWIC readers will not be required and no environmental impacts at these facilities are anticipated.

In the Florida ports it is estimated that additional air emissions due to TWIC Reader delays will be minimal (Table 8).  The increased emissions would be well below the de minimis thresholds established by the CAA as significant air quality deterioration; in fact, additional pollution is calculated at less than 0.04% (in the largest increase of a pollutant) compared to the de minimis thresholds.
                                       
Table 8. Criteria Pollutant Emissions for Port of Palm Beach and Port Everglades, 10[-3] (0.001) tonnes per year under Alternative 2
                                  Pollutant 
                                     NOx 
                                     SOx 
                                      PM 
                                     THC 
                                      CO 
                                     CO2 
                                   U.S. Port
                                       
                                       
                                       
                                       
                                       
                                       
                              Port of Palm Beach 
                                     10. 
                                    0.006 
                                     0.44 
                                     1.10 
                                     2.77 
                                     62. 
                               Port Everglades 
                                     41. 
                                    0.022 
                                     1.72 
                                     4.26
                                     10.7 
                                     2.40 
                             De minimis threshold 
                                   100,000 
                                   100,000 
                                   100,000 
                                     N/A 
                                   100,000 
                                     N/A 
                                        
 4.3.3.2 Air Quality Impacts

The de minimis threshold or the emissions limit for the ozone precursors VOC and NOx for maintenance areas is 100 tonnes per year for both pollutants (Table 6).  According to the calculations in Table 7 above, the emissions in both ports are significantly lower than the de minimis threshold for the pollutant NOx.  Alternative 2 (the preferred alternative) is below the de minimis level and, therefore, no General Conformity Determination would be required for the proposed action and no further analysis is required (as discussed previously in Section 3.2.3).

The Proposed Action for this FPEA meets all the criteria applicable to the General Conformity Rule and therefore the Rule applies.  The values for each alternative are compared to the values in Table 6, the de minimis thresholds.  The preferred alternative is not expected to exceed the de minimis threshold emissions and therefore no further analysis is required under the CAA.  

4.3.4 Alternative 3: All Container Facilities Deploying TWIC Readers in Mode 1 (Validation with No Use of Biometrics)
   4.3.4.1 Result
Under this alternative, all ports in the U.S. would be required to use TWIC readers in validation mode (Mode 1), which has a processing time of 1.75 seconds.  This time, plus an added 3 seconds required for matching the photograph with the TWIC-holder, gives the average time of a Mode 1 transaction a total of 4.75 seconds.  A transaction based on visual inspection alone requires 6 seconds, based on the TSA data.  With the TWIC reader the total time is 4.75 seconds, resulting in a reduction of 1.25 seconds over the visual inspection alone.  This information was used to calculate the amount of pollution reduced in the major ports of Houston, Los Angeles, New York/New Jersey, and Port of Virginia. 

Information on emission rates of sulfur-oxide and carbon dioxide for model years 2007-2011 were not provided, and were excluded in Table 9.
                                       
Table 9. Criteria Pollutant Emissions in Listed Ports, in 10[-3] (0.001) tonnes per year, under Alternative 3
                                  Pollutant 
                                     NOx 
                                      SOx
                                      PM 
                                     THC 
                                      CO 
                                     CO2 
                                   U.S. Port
                                       
                                       
                                       
                                       
                                       
                                       
                                      LA 
                                     -5.5 
                                     N/A 
                                    -0.048 
                                     N/A 
                                    -10.3 
                                     N/A 
                                  Port of VA 
                                    -51.2 
                                    -0.031 
                                    -2.38 
                                    -5.89 
                                    -14.8 
                                    -3,310 
                                      NY 
                                     -130 
                                    -0.079 
                                    -6.02 
                                    -14.9 
                                    -37.4 
                                    -8,400 
                                   Houston 
                                    -26.5 
                                    -0.016 
                                    -1.23 
                                    -3.05 
                                    -7.66 
                                     -172 
                             De minimis threshold 
                                   100,000 
                                   100,000 
                                    70,000 
                                     N/A 
                                   100,000 
                                     N/A 
                                        
Analysis of the criteria pollutants at four major container ports indicates that there would be minimal decreases in air pollution at these facilities (Table 9).  It should be noted that these air quality improvements may not occur if there are additional truck delay times due to a need to reconcile TWIC reader failures. 

   4.3.4.2 Air Quality Impacts
Ports considered under alternative 3 are representative for most of the container traffic in the United States.  These ports are located in different regions with diverse environmental and climatic conditions.  The Ports of Los Angeles/Long Beach and the Port Authority of New York and New Jersey are both located in areas considered nonattainment areas for particulate matter.  All ports under this alternative are located in nonattainment areas for the current ozone standard; however, Port of Hampton Roads is currently subject to a maintenance plan for the 1997 8-hour ozone standard.

The de minimis threshold or emissions limit for areas considered moderate nonattainment or maintenance for particulate matter is 100 tonnes per year (Table 6).  For serious nonattainment of the particulate matter standards, the de minimis threshold is 70 tonnes per year (Table 6).  According to calculations in Table 8 above, particulate matter emissions from truck idling due to TWIC reader processing times at ports located in nonattainment or maintenance areas for this criteria pollutant are significantly lower than the de minimis thresholds. 

The maximum emissions threshold or de minimis limit for ozone is 100 tonnes per year and the minimum emissions limit is 25 tonnes per year.  Calculations in Table 8 above show that emissions of the ozone precursor, NOx, resulting from truck idling due to TWIC reader processing times at ports located in nonattainment or maintenance areas for ozone are significantly lower than the ozone (NOx) de minimis thresholds. 

Thus, potentially under this alternative, air quality would be improved compared to the preferred alternative, although it would be a change of less than 1%.  This improvement may not be realized if there are significant additional delays due to failures in TWIC reader transactions, as discussed in Section 4.4.

4.3.5 Alternative 4: All Container Facilities Deploying TWIC Readers in Mode 3 (Use of Biometrics)
   4.3.5.1 Result
Under this alternative, all containers terminals would be required to use a biometric read of a TWIC to gain entry.  This requires the use of a TWIC reader's Mode 3, which has a processing time of 8.36 seconds.  A transaction based on visual inspection only requires 6 seconds for the security features of the TWIC to be identified.  This means that the use of Mode 3 is 2.36 seconds slower than visual inspection (see Section C.2.2).  This information is used to calculate the amount of pollution reduced in the major ports of Houston, Los Angeles, New York, and Hampton Roads, Virginia, which constitutes 84% of container traffic in the United States.  

Information on emission rates of sulfur-oxide and carbon dioxide for model years 2007-2011 were not provided and were excluded in Table 10.

Table 10. Criteria Pollutant Emissions for Listed Ports, in 10[-3] (0.001) tonnes per year, under Alternative 4.
                                   Pollutant
                                      NOx
                                      SOx
                                      PM
                                      THC
                                      CO
                                      CO2
                                   U.S. Port
                                       
                                       
                                       
                                       
                                       
                                       
                                      LA 
                                     104 
                                     N/A 
                                     0.09 
                                     N/A 
                                     19.6 
                                     N/A 
                                  Port of VA 
                                     96.6 
                                     0.059
                                     4.49
                                     11.1 
                                     27.9 
                                    6,260. 
                                      NY 
                                     245 
                                    0.148 
                                     11.4 
                                     28.2 
                                     70.7 
                                    15,900 
                                   Houston 
                                     50.0 
                                    0.030 
                                     2.33 
                                     5.76 
                                     14.5 
                                    3,240. 
                             De minimis threshold 
                                   100,000 
                                   100,000 
                                    70,000 
                                     N/A 
                                   100,000 
                                     N/A 
                                        
Analysis of the criteria pollutants at four major container ports indicates that there would be minimal increases in air pollution at these facilities (Table 10), and that they would not contribute additional air emissions under the de minimis limits of the CAA.  The increased emissions would be well below the de minimis thresholds established by the CAA as significant air quality deterioration; in fact, additional pollution is less than 0.1% (in the large increase) compared to the de minimis limits.
 4.3.5.2 Air Quality Impacts
Ports considered under Alternative 4 are representative for most of the container traffic in the United States.  These ports are located in different regions with diverse environmental and climatic conditions.  The Port of Los Angeles and the Port Authority of New York and New Jersey are both located in areas considered nonattainment areas for particulate matter.  All ports under this alternative are located in nonattainment areas for the current ozone standard; however, Port of Hampton Roads is currently subject to a maintenance plan for the 1997 8-hour ozone standard.

The de minimis threshold or emissions limit for areas considered moderate nonattainment or maintenance for particulate matter is 100 tonnes per year (Table 6).  For serious nonattainment of the particulate matter standards, the de minimis threshold is 70 tonnes per year (Table 6).  According to calculations in Table 9 above, particulate matter emissions from truck idling due to TWIC reader processing times at ports located in nonattainment or maintenance areas for this criteria pollutant are significantly lower than the de minimis thresholds. 

The maximum emissions threshold or de minimis limit for ozone is 100 tonnes per year and the minimum emissions limit is 25 tonnes per year.  Calculations in Table 9 above show that emissions of the ozone precursor, NOx, resulting from truck idling due to TWIC reader processing times at ports located in nonattainment or maintenance areas for ozone are significantly lower than the ozone (NOx) de minimis thresholds. 

4.4 Truck Idling Times and Potential Failure Rates
An analysis was also conducted to estimate the potential increase or decrease in truck idling time due to the use of TWIC readers, compared to baseline conditions.  Truck idling times are changed less than 0.1% due to these operations (Table 11).

The overall idling time is not limited to gate entry, but it is an estimate from EPA's Drayage Report of total number of hours drayage trucks spend idling over the course of a year.

Table 11. Comparison of Drayage Truck Idling Times as a Result of TWIC Readers and of Overall Idling Times in Four Major Ports
                                       
                             # of trucks per year
                        Mode 1 Idle Time delta (hours)
                        Mode 3 Idle Time delta (hours)
                           Overall Idle Time (hours)
                                   U.S. Port
                                       
                                       
                                       
                                       
                                      LA
                                   8,468,921
                                     +2941
                                     -6116
                                   7,707,571
                               Port of Virginia
                                   1,223,199
                                     +425
                                     -883
                                   2,491,249
                                      NY
                                   3,098,892
                                     +1076
                                     -2238
                                   4,458,614
                                    Houston
                                    633,542
                                     +220
                                     -458
                                   1148,904

4.4.1 Summary of Potential Impact of Failure Rates

Failure rates (i.e., times when the TWIC reader transaction does not work) of the TWIC reader can potentially increase air pollution at the ports.  However these failures would have to lead to delays in an average of 4 minutes before air pollutant levels would exceed de minimis levels (see Section 3.2.3 and Table 4).  When failures occur, additional time is needed to rectify the program, which adds additional time for truck idling.  The estimates of transaction times from TSA assume that most transactions will be successful and that most future failures will be minimized as technologies are improved. 

4.4.2 Sources of Failure
A failure occurs when a TWIC reader transaction does not process correctly, which leads to denial of entry to a truck to a port facility.  The range of such failures are shown in Table 12.  A failure can be technical, which can include an incorrect reading and can result from some problem with the TWIC itself, mis-alignment of the card in the TWIC reader, a problem with the TWIC reader not capturing the card information or some computer processing error.  Administrative failures can occur, and they in fact may be successes of the program (the first two "failures" are actually successes; in these two conditions, the card should be rejected, so the TWIC readers are performing as expected), but can result in future delays.  By success we mean that the TWIC reader transaction may alert the facility to an expired card, a match with a watch list or other reasons to deny entry to a truck driver.  Finally other administrative failures can result because of incomplete, missing or incorrect information in the database.  These successful transactions, along with the next five failures, are captured in the 17% failure rate identified in the TWIC pilot.  While it would be expected that failure rates would be reduced as technology improves and with additional experience with the program, some failures would be expect to continue.  The next issue is the delay times related to these failures.

                  Table 12. Invalid TWIC Reader Transactions
Failure Mode
Description
1. Card on Canceled Card List (CCL)
Card listed on TSA's CCL. This is not technically a failure, as the card cannot be legally used.
2. Card Invalid
Card not a legitimate TWIC. This is not technically a failure, as the card cannot be legally used.
3. Biometric Failure
Card not able to be matched to biometrics.
4. Card Failure
Card unable to be read in contactless mode.
5. Otherwise Unreadable Card
Card otherwise not able to be read.
6. User Error
TWIC-holder misuses reader.
7. Reader Failure
TWIC reader not able to process TWICs.

Since the TWIC pilot did not decompose these failures further in the data provided, we assume a uniform distribution across the seven failure modes (2.43% for each).  Of the seven types of invalid TWIC reader transactions, we focus on the two that will identify previously undetected unreadable TWICs.  These two card failure modes are identified in Table 12 as "4. Card Failure" and "5. Otherwise Unreadable Card."  We estimate these two failure modes account for approximately 5% of invalid transactions.  

4.4.3 Range of Failures 

The TSA pilot study has resulted in a database in which the transaction time for a successful transaction is known and for which a range of values are available (see Appendix C).  However neither the rates of failures, a quantifiable estimate of the sources of the failures, nor the average delay time associated with the failures is known.  The USCG conducted a series of field visits to observe conditions and processes at four of the ports; information was also collected from facility operators (Appendix E).  While the information is anecdotal, it was reported and we observed failure rates of 12 percent at one facility  -  and that facility reported that with one type of TWIC reader (subsequently rejected) that failures were 70 percent.  We also learned that in many cases to resolve the failure, a truck needs to move to a second station and it was estimated that transaction could take at least several minutes (in some cases a truck is turned around and has to exit the facility to resolve the issue). 

4.4.4 Delays and the Clean Air Act of 1970

As discussed in Section 4.2, impacts on air quality from additional pollution are considered significant if they exceed the de minimis levels for annual pollution loads for the priority pollutants.  Thus, emissions that are less than the standards mean that a region is still in compliance with the requirements of the CAA.  Given the available information on failure rates or associate increases in idling times for trucks, we have no reliable estimate of the failure rates or the average time that might be needed to resolve the failure.  Therefore, we have no quantifiable measure for estimating impacts on air quality.  Instead we suggest two approaches: 1) Bounding range of delays that would allow compliance with CAA and 2) use of mitigation measures. 

Based on the analysis of air quality impacts of idling during successful transactions, we have shown (Tables 7, 8, and 9) that additional air pollution ranges from 100 to 1,000 times lower than de minimis levels.  Therefore failure rates would have to result in average delays that are 100 to 1,000 times longer before there would be a significant impact on air quality.  In fact, it is estimated for NOx that the delays with TWIC readers would have to increase from the present average times of 2.3 and 4.7 seconds to over 6 minutes on average.  While some delays for individual trucks could approach six minutes if there is a TWIC reader failure, these are expected to be infrequent and would not increase the average delay times by the magnitude needed to have an impact on air quality.

To calculate the time that TWIC reader failures would have to add to transaction times in order to have a significant impact on air quality, the emissions level was set at the de minimis threshold of 10 metric tonnes, and the transaction time was calculated that would achieve that level.  The level of 10 metric tonnes is a conservative de minimis level, which can be up to 100 metric tonnes.  For the purpose of this exercise, the Port of New York and the criteria pollutant NOx was selected.  The following equation was used to solve for transaction time difference.  









For the second approach, the use of mitigation measures, a discussion of a range of options is presented in Section 4.6.  Based on both the approaches it would appear that failure rates would have to result in extensive delays before there would be significant impacts on air quality.

4.5 Cumulative Impacts
Cumulative impacts are those impacts on the human environment that result from "the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency or person undertakes such other actions" (40 CFR 1508.7).  These impacts either may directly or indirectly affect environmental resources.  According to guidance from the President's Council on Environmental Quality, past actions considered in cumulative impacts analysis should be identified and considered in the context of scoping for the analysis.  For the purposes of this analysis, document research, site visits, and internal and external data gathering were conducted to inform the assessment of the environmental baseline at test sites.  Past actions, whether physical modifications, technological upgrades, or changes in operations at the ports, were considered in the context of the dynamic baseline.

Ports already are operationally constrained environments and they vary in infrastructure, technologies, environmental contexts, and surrounding land uses.  However, ports have been continually adapting to the changing security environment within these constraints.  Numerous factors, including land traffic volume, affect the ability of ports-of-entry to manage changes and improvements in system efficiency, which can be offset by such factors as decisions to screen a greater percentage of travelers.  Currently, the busiest land ports-of-entry are maintained at carrying-capacity threshold, primarily through management practices administered locally, but also through the use of State-mandated programs.  The USCG expects that these management practices and Federal, State, and local requirements will continue to keep environmental impacts at or below the current levels, since they are focused on reducing emissions and improving future air quality.  

Even with some ports at carrying capacity, the national implementation of TWIC readers is not expected to have cumulative impacts in the foreseeable future on resources driven by traffic, since the alternatives considered (with the exception of the No-Action Alternative, Alternative 1) would likely result in negligible increase in traffic.  Some temporary disruption of traffic flow may occur during implementation of the TWIC readers, but once the system reaches steady state, effects should be modest, when compared to maintaining daily operations.  

Cumulative impacts associated with additional air emissions are not considered significant since all analyses of air quality under the four FPEA alternatives show increased pollution within the de minimis threshold range.  GHGs generated by additional truck idling are reduced or unaffected in all but two ports.  In the 2 affected ports, emissions are under 25,000 tonnes/year, which is the threshold of concern for GHGs and their impact on climate change; less than 17 tonnes per year of CO2 is potentially generated in the worst case analysis of the container ports. 

4.6 Mitigation of Potential Environmental Impacts
During our analysis of potential impacts on air quality due to truck idling, we considered approaches to mitigate these impacts.  While the USCG does not intend to direct industry or to restrict their flexibility, we have reviewed efforts that industry could consider.  These include: 1) Changes of truck model years to newer trucks, 2) appointment schedules for truck arrivals, and 3) changes in sequencing of port business and security operations. 

4.6.1 Changes in Truck Models and Fuels
Ports on both the East and West Coast have instituted programs to require the use of lower polluting newer model drayage trucks.  This includes the Port of New York/New Jersey (EPA 2008) and in the Port of Los Angeles/Long Beach (EPA, 2008), since trucks represent significant air pollution sources in those non-attainment areas.  The NY/NJ Clean Air Strategy Program (NY/NJ, 2011) has not been fully implemented and when fully in place this program is expected to result in significant improvement in air quality.

The Clean Trucks program in LA/LB has been in effect since 2000 and has been very successful.  By January 2012, all trucks entering the port will be required to be of model year 2007 or later.  Since these newer model trucks have significantly lower emissions (Table 3) than older models, this has resulted in air emissions from trucks being 5 to 50 times lower (LB Ports, 2011).  Thus the LA/LB program appears to be a very useful mitigation technique for reducing air pollutants from drayage trucks.

There are a wide range of other environmental initiatives in place in the LA/LB area that may be applicable to other U.S. ports, such as the Vessel Speed Reduction Program, the Alternative Maritime Power initiative, and the California Air Resources Board's regulatory strategies for port-related sources.  These strategies would be expected to be applicable to other ports and to be useful, if needed, to reduce any impacts of TWIC readers at other ports.

Other ports, such as Port Everglades, are considering starting clean truck programs as a consequence of programs elsewhere.  While the air quality in Port Everglades is attainment, that Port is concerned that older truck models, which are no longer allowed in West Coast ports, just as they will not be allowed in the future in the NY/NJ port, may relocate to areas where they are allowed to operate, and have the potential to increase air pollution.  All U.S. ports now have the benefit of improved air quality associated with the use of low sulfur fuels, which has been mandated for trucks nationally.

4.6.2 Appointment Schedules for Truck Arrivals
Several port facilities have recognized that appointment schedules for trucks is a useful technique to reduce the "bunching" of trucks at certain times  -  and thus reducing delays in trucks entering the facilities.  Among the major ports, LA/LB has reported that this program has not been effective and continues to rely on the Clean Trucks Program.

By contrast, the NY/NJ ports, through their scheduling program, have reported that reduced delays and improved safety near the highway exits to the ports (NY/NJ Ports, 2011).  The program moves truck arrivals from peak times during the day to less crowded times.  We have no information about the acceptability of the program to the truckers, but believe that the benefit of quicker entry would help them economically, since they are paid for each trip into the port.

4.6.3 Changes in Sequencing of Port Business and Security Operations
Based on discussions with industry (Appendix E) and through our analysis study on congestion (Appendix E) the USCG considered changes in port business and security operations that might reduce delays and thus serve as mitigation for potential air pollution.  While business decisions are up to industry; this section is put forward as another example of potential mitigation techniques.

In general, port managers have indicated that they are open to flexibility in their operations that will accommodate security programs and allow them to reduce delay times.  As observed by USCG personnel during site visits, all indicated that there is a goal at the ports to minimize turnaround times for trucks.  In NY/NJ port operators seek to have the time from entry to exit of trucks under 1 hour; LA/LB operators have a goal of 40 to 50 minutes.  They all commented that longer delays would hurt their business.  In the case of the TSA TWIC pilot program in LA/LB, the initial program set-up resulted in longer delays, and the TSA and port security managers were able to reach an agreement that during times of excessive delays, the port managers were authorized to switch from TWIC readers to using TWICs as visual identification badges.  While it is anticipated that these start-up issues would be resolved and that the full TWIC reader program could be implemented, that agreement showed the need for flexibility in order not to negatively impact business operations at the port.

The first consideration is the current operations at the ports.  Based on our observations and the congestion study (Appendix B), there are three standard sequences for port operations.  All security operations are performed prior to entry of trucks into the ports.  As discussed in Appendix B, the patterns observed are:

Sequence one: all security and business operations are done at an initial entry point; Sequence two: Security operations are completed and then truck goes to a second location for business transactions; Sequence three: security operations are done in stages, and business transactions are done in stages.

Port managers have reported that they may consider (and have found useful in the past) changes in the number of entry portals, changes in configuration at the portals, increasing or reducing the number of gates operated by security personnel, and changes in software and hardware to accommodate operations.  Participants in TWIC pilot programs have reported that their experience gained during those programs has been valuable and that they estimate that a learning curve without that experience might be as long as several years.  Those groups that did not participate in TWIC pilot programs indicated that the startup of new programs for TWIC readers would extend over several years (Port Everglades, 2011).

While methodology was not specifically addressed, combining security functions (including implementation of TWIC reader programs) with business operations was seen as possible by port operators; their major concern was coming to agreement with labor on acceptable practices (Appendix E).  Mandatory program elements might be more acceptable in labor agreements.  However, at least one port operator indicated that these considerations in labor agreements would not be expected to be a major issue.

4.6.4 Temporary Suspension of Reader Use during High Traffic Events and Other Delays
In the event that high traffic volumes or other delays occur, the use of the readers may temporarily be suspended at the approval of the Captain of the Port and the security system could use the TWIC as visual identity badges, as is currently done at the facilities.  These events have the potential to back up traffic into highway ramps and other access points or to increase idling times for trucks and therefore need to be avoided.  In the event of possible high failure rates for readers temporary suspensions can avoid long idling times for trucks, which in turn could lead to additional air pollution.


5.0 Environmental Significance of Proposed Action

The primary resource area that has the most potential to be affected by the implementation of the TWIC readers is air quality.  Impacts to air quality were examined as a result of expected changes in traffic and truck wait times at port entrances.  Air quality is expected to be unaffected in all ports, except for three facilities in Florida and those impacts are insignificant.  The preferred alternative is not the alternative with the least environmental impact, but has no significant impacts.  Due to cost and implementation issues, installing TWIC readers only in high-risk facilities is preferred.  No environmental justice or socioeconomic impacts are expected to result from the action.  No potential impacts to energy, land use, waste, water, biological resources, health and safety, or historic properties are anticipated for the preferred alternative.

6.0 Identified Environmental Review and Consultation

This environmental assessment adopts the information and conclusions contained in several other reports and studies which were coordinated with agencies and persons who provided constructive input.  The U.S. Coast Guard (USCG) also reviewed the consistency of the approach to the analysis in this Final Programmatic Environmental Assessment (FPEA) to other activities in the Department of Homeland Security (DHS) (see Appendix E of this FPEA).

Homeland Security - Transportation Worker Identification Credential Reader Pilot Program

The purpose of this report is to convey the findings of the Transportation Worker Identification Credential (TWIC) Reader Pilot Program (TWIC pilot).  This document is intended to satisfy the reporting requirements of Section 104 of the Security and Accountability for Every Port Act of 2006 (SAFE Port Act, Pub. L. 109-347) and the USCG Authorization Act of 2010, which requires DHS to submit the findings of the pilot program with respect to technical and operational impacts of implementing a transportation security reader system; any action that may be necessary to ensure that all vessels and facilities to which this section applies are able to comply with such regulations; and an analysis of the viability of equipment under the extreme weather conditions of the marine environment.  The Department of Homeland Security managed the TWIC pilot through the participation of the Transportation Security Administration (TSA). 

Booz Allen Hamilton - Port Facility Congestion Study

This was a collaborative study between Booz Allen Hamilton and USCG Headquarters staffs, with additional support and subject matter expertise provided by USCG Area, District, and Sector Prevention staffs.  The USCG is required to comply with the National Environmental Policy Act of 1969, as amended (NEPA, Pub. L. 91-190), Executive Order 12866 on Regulatory planning and Review, and the Regulatory Flexibility Act (5 U.S.C.).  As a part of that compliance effort, the USCG explored cost and operational effects of maritime congestion factors related to Physical Access Control Systems (PACSs) and gate security.  This report concluded a six-month study of the analytical formats and models of maritime worker/truck/vessel congestion factors and their impacts, as related to PACSs.  Further, this study evaluated the impact of existing electronic PACS readers on congestion at selected port facilities, to determine the economic and environmental impact of potential regulations in the future.  

Environmental Protection Agency and US Federal Highway Administration - DrayFLEET: EPA SmartWay Drayage Activity and Emissions Model and Case Studies

This was a collaborative study between the U.S. Environmental Protection Agency and the U.S. Department of Transportation to examine drayage operations within U.S. ports.  The report generated a comprehensive model on drayage truck movements within a port to help officials estimate factors such as emissions, costs, and throughput, and can adjust for specific variables such as technology, traffic flow, and amount of tonnage received.  The report uses specific case studies in the ports of LA/Long Beach, NY/NJ, Houston, and the Port of Virginia as examples of how to use the DrayFLEET model and provides a breakdown of drayage patterns for each port.  

Department of Homeland Security, US-VISIT program (as discussed in Appendix E of this FPEA).
7.0 References 

American Association of Port Authorities (AAPA). (2009). World Port Rankings - 2009. Retrieved 2011, from American Association of Port Authorities Web site: http://aapa.files.cms-plus.com/PDFs/WORLD%20PORT%20RANKINGS%202009.pdf

Broward County Board of County Commissioners. (2011). About Us. Retrieved 2011, from Port Everglades Web Site: http://www.porteverglades.net/about-us/

Cannon, J. S. (2009). Container Ports and Air Pollution. Retrieved 2011, from Consenseus: http://www.consenseus.org/pdf/2009PortStudy.pdf

CH2M Hill, The Four Gates Company, & John C. Martin Associates. (2006, February). Port of Palm Beach Master Plan 2005-2015. Retrieved 2011, from http://www.portofpalmbeach.com/business-opportunities/master-plan/downloads/031506_ppb_masterplan.pdf

EPA. (2008). DrayFLEET: EPA SmartWay Drayage Activity and Emissions Model and Case Studies. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/smartway/documents/partnership/trucks/drayage/final-dray-fleet-report.pdf

EPA. (2011a). Air and Radiation: National Ambient Air Quality Standards (NAAQS). Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/air/criteria.html

EPA. (2011b). General Conformity: Basic Information. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/air/genconform/background.html

EPA. (2011c). General Conformity: De Minimis Levels. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/air/genconform/deminimis.html

EPA. (2011d). General Conformity: Frequent Questions. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/air/genconform/faq.html#10

EPA. (2011e). Green Book. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/oaqps001/greenbk/define.html

EPA. (2011f). Green Book: Currently Designated Nonattainment Areas for All Criteria Pollutants. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://epa.gov/oaqps001/greenbk/ancl.html

EPA. (2011g, August 30th). Green Book: Currently Designated Nonattainment Areas for All Criteria Pollutants. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/oaqps001/greenbk/ancl.html#CALIFORNIA

EPA. (2011h, August 31st). Green Book: Nonattainment Status for Each County by Year for Florida. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/oaqps001/greenbk/anay_fl.html

EPA. (2011i). Ground-Level Ozone. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/glo/

EPA. (2011j). Nonroad Engines, Equipment, and Vehicles: Frequently Asked Questions about the Emission Control Area Process. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/nonroad/marine/ci/420f09001.htm

EPA. (2011k, August 30th). The Green Book Nonattainment Areas for Criteria Pollutants. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/oaqps001/greenbk/

EPA. (2011l). Ground-level Ozone. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/glo/

EPA. (2011m). Particulate Matter: Basic Information. Retrieved, 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/pm/basic.html

EPA. (2011n). Email from Prashanth Gururaja, June 20.

Florida Deparment of Environmental Protection (FDEQ). (2011). Air Quality Monitoring: Ozone Standard. Retrieved November 2011, from Florida Department of Environmental Protection Web site: http://www.dep.state.fl.us/air/air_quality/ozone_standard.htm

Greenhouse Gas (GHG) and Criteria Air Pollutant (CAP) Emission Inventory (EI) for the Port Authority of New York & New Jersey. (2010, June). Retrieved 2011, from The Port Authority of New York and New Jersey Web site: http://www.panynj.gov/about/pdf/2008-GHG-Inventory-Summary.pdf

Homeland Security. (2006, April). US-Visit Programmatic Environmental Assessment on Potential Changes to Immigration and Border Management Processes. Retrieved 2011, from U.S. Department of Homeland Security Web site: http://www.dhs.gov/xlibrary/assets/usvisit/US-VISIT_FPEA_041006.pdf

Homeland Security. (2006, April). US-Visit Programmatic Environmental Assessment on Potential Changes to Immigration and Border Management Processes. Retrieved 2011, from U.S. Department of Homeland Security Web site: http://www.dhs.gov/xlibrary/assets/usvisit/US-VISIT_FPEA_041006.pdf

Landrum & Brown, Inc. (2008, April). Fort Lauderdale-Hollywood International Airport Environmental Assessment. Retrieved 2011, from Broward.org: http://www.broward.org/Airport/Community/Documents/appendix_a.pdf

National Oceanic and Atmospheric Administration. (2003, February). U.S. National Oceanic and Atmospheric Administration Web site: http://www.glerl.noaa.gov/res/Programs/nsmain.html.  

Port of Los Angeles. (2010). Environment - Air Quality Monitoring. Retrieved 2011, from The Port of Los Angeles Web site: http://www.portoflosangeles.org/environment/air_quality.asp

PANYNJ (Port Authority of New York & New Jersey). (2011a). Transportation Greening. Retrieved 2011, from The Port Authority of New York & New Jersey Web site: http://www.panynj.gov/about/transportation-greening.html?tabnum=2

PANYNJ (Port Authority of New York and New Jersey). (2011b). Environmental Initiatives at the Port of New York and New Jersey. Retrieved 2011, from The Port Authority of New York and New Jersey Web site: http://www.panynj.gov/about/port-initiatives.html

Port of Palm Beach. 2010. Financial Statements with Independent Auditors' Report Thereon. Retrieved September 2011, from the Port of Palm Beach Web site: http://www.portofpalmbeach.com/administration/financial-information/downloads/Audit_Report_2010_Port_of_Palm_Beach_District1303478162.pdf

Ross & Associates. (2009, October 21st ). A Clean Air Strategy for the Port of New York & New Jersey. Retrieved 2011, from The Port Authority of New York and New Jersey Web site: http://www.panynj.gov/about/pdf/CAS-FINAL.pdf

San Pedro Bay Ports . (2010-2011, June 1st). Historical Data - past air quality data for ozone. Retrieved from The San Pedro Bay Ports Clean Air Action Plan: http://caap.airsis.com/HistoricalDetail.aspx

Starcrest Consulting Group, LLC. (2007, July). The Porth of New York and New Jersey Heavvy-Duty Diesel Vehicle Emissions Inventory. Retrieved 2011, from The Port Authority of New York & New Jersey Web site: http://www.panynj.gov/about/pdf/The-Port-of-New-York-and-New-Jersey-Heavy-Duty-Diesel-Vehicle%20Emissions-Inventory.pdf

Starcrest Consulting Group, LLC. (2008, November). 2006 Baseling Multi-Facility Emissions Inventory of Cargo Handling Equipment, Heavy-Duty Diesel Vehicles, Railroad Locomotives and Commercial Marine Vessels. Retrieved 2011, from The Port Authority of New York & New Jersey Web site: http://www.panynj.gov/about/pdf/2006-BASELINE-MULTI-FACILITY-EMISSIONS-INVENTORY.pdf

Starcrest Consulting Group, LLC. (2009, January). 2007 Goods Movement Air Emissions Inventory at the Port of Houston. Retrieved 2011, from The Port of Houston Authority Web site: http://www.portofhouston.com/pdf/environmental/PHA-GM-AirEmissions-07.pdf

Starcrest Consulting Group, LLC. (2010). Port of Los Angeles Inventory of Air Emissions - 2009. Retrieved 2011, from Port of Los Angeles Web site: http://www.portoflosangeles.org/DOC/REPORT_Air_Emissions_Inventory_2009.pdf

TSA (U.S. Transportation Security Administration). (2012). Transportation Worker Identification Credential Reader Pilot Program, Final Report, February 27.

USACE, 2011.  (container statistics).

US Coast Guard. 2014. Transportation Worker Identification Credential (TWIC)  -  Reader Requirements. Final Rule. Regulatory Analysis and Final Regulatory Flexibility Analysis. USCG-2007-28915.

Virginia Department of Environmental Quality (DEQ). (2009). Maps of the Recommended Nonattainment Areas. Retrieved 2011, from Virginia Department of Environmental Quality Web site: http://www.deq.state.va.us/air/pdf/air/emissions/Enclosure_II.pdf



8.0 Contacts
The U.S. Coast Guard has been in contact with:

   1) U.S. Environmental Protection Agency experts on Clean Air Act issues related to U.S. ports,
   2) Officials and private operators at the Port of Los Angeles and Long Beach,
   3) Officials and private operators at the Port of New York and New Jersey, and
   4) Officials and private operators at the Port of Miami and Port Everglades.

Specific contact information is available upon request.



USCG Finding of No Significant Impact 
                                      FOR
 Transportation Worker Identification Credential (TWIC)  - Reader Requirements

This action has been thoroughly reviewed by the USCG and it has been determined, by the undersigned, that this project will have no significant effect on the human environment. This finding of no significant impact is based on the attached USCG prepared environmental assessment as well as materials which are incorporated therein by reference.  The Final Programmatic Environmental Assessment (FPEA) has been determined to adequately and accurately discuss the environmental issues and impacts of the proposed action and provides sufficient evidence and analysis for determining that an environmental impact statement is not required. 




___________	           ____________________________
		          Mr. Ed  Wandelt 
Date 		          Environmental Reviewer 			
                                  Chief, Office of Environmental Management 

I have considered the information contained in the FPEA, which is the basis for this FONSI. Based on the information in the FPEA and this FONSI document, I agree that the proposed action as described above, and in the FPEA, will have no significant impact on the environment.




___________              ______________________________
			Paul F. Zukunft, Admiral
Date 			Responsible Official 
            Commandant, U.S. Coast Guard 



	Appendix A. Affected Environment at Ports 

This appendix reviews and summarizes current air quality conditions in the major ports of New York and New Jersey, Los Angeles, Houston, and Florida (Port Everglades and Port of Palm Beach).  This information on ambient conditions in these areas was compared in the analysis to diesel emissions from trucks that may be impacted by Transportation Worker Identification Credential (TWIC) reader regulations.

A.1 Florida

           Figure A.1. Current Ozone Levels in Florida (FDEQ, 2011)



         Table A.1. Projections of Anthropogenic VOC and NOX Emissions
                          (Tonnes/day) (75 CFR 29674)
Year
                                   Broward 
                                  Palm Beach
Total
 
                                      VOC
                                                                           2002
                                                                         245.84
                                                                         211.64
                                                                         778.11
                                                                           2005
                                                                         226.61
                                                                         193.09
                                                                         715.99
                                                                           2008
                                                                         207.37
                                                                         174.55
                                                                         653.87
                                                                           2009
                                                                         200.95
                                                                         168.36
                                                                         633.16
                                                                           2011
                                                                            201
                                                                         166.83
                                                                         631.91
                                                                           2014
                                                                         201.07
                                                                         164.52
                                                                         630.04
                                                                           2018
                                                                         201.16
                                                                         161.45
                                                                         627.52
 
                                      NOX
                                                                           2002
                                                                         238.82
                                                                         159.79
                                                                         648.62
                                                                           2005
                                                                         201.95
                                                                         136.85
                                                                         557.81
                                                                           2008
                                                                         165.09
                                                                         113.92
                                                                         466.99
                                                                           2009
                                                                          152.8
                                                                         106.27
                                                                         436.72
                                                                           2011
                                                                         140.98
                                                                          96.99
                                                                         402.61
                                                                           2014
                                                                         123.25
                                                                          83.06
                                                                         351.44
                                                                           2018
                                                                          99.62
                                                                          64.48
                                                                         283.21
                                       

                                       
A.2 Los Angeles
                                       
Figure A.2. Los Angeles South Coast Air Basin Boundary (Starcrest Consulting Group, LLC, 2010)
                                       
                                       
                                       

Figure A.3. Locations of Air Quality Monitoring Stations in Port of Los Angeles and Port of Long Beach (San Pedro Bay Ports, 2011)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       

Figure A.4. Port of Los Angeles Daily O3 (8-hour) Emissions Observations (Terminal Island Monitoring Station, June 1[st] 2010  -  June 1[st], 2011) (San Pedro Bay Ports, 2010-2011)
                                       



Figure A.5. Monthly Average PM10 Concentrations at the Port of Los Angeles January  -  December 2010 (The Port of Los Angeles, 2010)
                                       
                                       
                                       

Figure A.6. Monthly Average PM2.5 Concentrations at the Port of Los Angeles (The Port of Los Angeles, 2010)
                                       
                                       
                                       
Figure A.7. Annual Average PM2.5 Concentrations at the Port of Los Angeles (The Port of Los Angeles, 2010)
                                       
                                       
                                       
Table A.2. Port of Los Angeles Port-wide Emissions Comparison, tonnes per year and % Change (Starcrest Consulting Group, 2010)
Pollutant
PM10
PM2.5
DPM
NOx
SOx
CO
Year






2009
                                                                            511
                                                                            436
                                                                            467
                                                                         11,244
                                                                          2,432
                                                                          2,777
2008
                                                                            805
                                                                            690
                                                                            736
                                                                         15,577
                                                                          3,822
                                                                          3,826
2007
                                                                            777
                                                                            673
                                                                            682
                                                                         17,052
                                                                          3,553
                                                                          4,036
2006
                                                                          1,140
                                                                            975
                                                                          1,040
                                                                         19,262
                                                                          6,026
                                                                          4,658
2005
                                                                          1,062
                                                                            908
                                                                            974
                                                                         16,812
                                                                          5,552
                                                                          4,093
Previous Year (2009-2008)
                                                                           -37%
                                                                           -37%
                                                                           -37%
                                                                           -28%
                                                                           -36%
                                                                           -27%
CAAP Progress (2009-2005)
                                                                           -52%
                                                                           -52%
                                                                           -52%
                                                                           -33%
                                                                           -56%
                                                                           -32%
                                       
                                       

A.3 Virginia

Figure A.8. Hampton Roads 2008 8-hour Ozone Standard Nonattainment Area (VDEQ, 2009)
                                       

                                       
                                       
                                       

A.4 New York
                                       
                                       
Figure A.9. New York/New Jersey/Long Island Nonattainment Area (Starcrest Consulting Group, LLC, 2008)
                                       
                                       
                                       
                                       

                                       
Table A.3. Criteria Pollutant Emission Summary by Source Category for New York Ports, 2006 (Starcrest Consulting Group, LLC, 2008)
Pollutant
                                      NOx
                                     PM10
                                     PM2.5
                                      VOC
                                      CO
                                      SO2
Source Category
                                       
                                       
                                       
                                       
                                       
                                       
Cargo Handling Equipment 
                                     1,402
                                      93
                                      86
                                      124
                                      465
                                      219
Heavy-Duty Diesel Vehicles 
                                     1,935
                                      59
                                      54
                                      87
                                      564
                                      26
Railroad Locomotives 
                                      286
                                      10
                                       9
                                      20
                                      44
                                      32
Ocean-Going Vessels 
                                     3,691
                                      348
                                      279
                                      165
                                      319
                                     3,270
Harbor Craft 
                                      486
                                      26
                                      24
                                      18
                                      41
                                      50
Total PANY Emissions 
                                     7,800
                                      537
                                      452
                                      413
                                     1,434
                                     3,597
NYNJLINA Emissions 
                                    445,285
                                    178,451
                                    42,441
                                    522,245
                                   2,840,374
                                    170,044
PANYNJ Percentage 
                                     1.8%
                                     0.3%
                                     1.1%
                                     0.1%
                                     0.05%
                                     2.1%
                                       
                                       
Table A.4. Comparison of Regional and Marine Terminal HDDV Emissions, in tonnes per year (Starcrest Consulting Group, LLC, 2008)
                                       
                                       
Pollutant                                            VOC                CO                   NOx                      PM10                    PM2.5
                                      SO2
New York and New Jersey
                                       
Geographical Extent/Source
                                       
New York and New Jersey 
                                   1,174,315
                                   7,444,713
                                   1,086,959
                                   1,241,436
                                    427,474
                                    674,616
NYNJLINA 
                                    531,178
                                   3,265,051
                                    473,677
                                    392,916
                                    144,915
                                    263,236
PONYNJ HDDV 
                                     81.27
                                    639.78
                                     2,059
                                     42.40
                                     41.13
                                     36.51
Percent NYNJLINA Emissions 
                                     0.02%
                                     0.02%
                                     0.43%
                                     0.01%
                                     0.03%
                                     0.01%
                                       
                                       
                                       

Figure A.10. Model Year Distribution of Trucks Visiting the PANYNJ (Starcrest Consulting Group, LLC, 2008)
                                       
                                       

A.5 Houston
                                       
Table A.5. Port of Houston Authority 2007 Port Associated Maritime-Related Emissions, tonnes per year (Starcrest Consulting Group, 2009)
Pollutant
NOx
SO2
PM10
PM2.5
CO2
CO
Source






Ocean-going vessels
                                                                          2,386
                                                                          3,296
                                                                            296
                                                                            237
                                                                        195,580
                                                                            222
Heavy-duty diesel-fueled vehicles
                                                                          2,357
                                                                              2
                                                                             56
                                                                             54
                                                                        257,980
                                                                            640
Cargo handling equipment
                                                                          1,020
                                                                             22
                                                                             63
                                                                             61
                                                                        112,618
                                                                            363
Locomotives
                                                                            885
                                                                             18
                                                                             33
                                                                             32
                                                                         56,120
                                                                            148
Harbor vessels
                                                                             68
                                                                              2
                                                                              3
                                                                              3
                                                                          5,276
                                                                             19
Total
                                                                          6,716
                                                                          3,340
                                                                            450
                                                                            386
                                                                        627,574
                                                                          1,392
                                       
                                       

Figure A.11. 2007 Port of Houston Authority Associated Maritime-Related Sources compared to 2005 HGB Nonattainment Area NOx Emissions (Starcrest Consulting Group, 2009)
                                       
                                       
                                       
                                       
                                       
   Table A.6. Port Profiles and Air Quality Status (Derived from EPA, 2011g)
                                    Port(s)
                        Maintenance/Nonattainment Area
                                 Pollutant(s)
Port of Los Angeles
South Coast Air Basin (SoCAB) Nonattainment Area
8-hr Ozone (VOC and NOx)
Particulate Matter (PM10 and PM2.5)
Port Authority of New York and New Jersey
New York/Northern New Jersey/Long Island Non-Attainment Area (NYNJLINA)
8-hr Ozone (VOC and NOx)
PM2.5
Hampton Roads
Hampton Roads Maintenance Area/ Hampton Roads Nonattainment Area
1997 8-hr Ozone standard/2008 8-hr Ozone standard
The Port of Houston Authority
Houston-Galveston-Brazoria Nonattainment Area
8-hr Ozone (VOC and NOx)
Port of Palm Beach
Port Everglades
Southeast Florida Maintenance Area/Attainment for all NAAQs
1-hour Ozone (revoked). Area under maintenance plan until 2015


A.6 Florida Ports
We focused on Florida ports because they are the ports in the preferred alternative which have been designated as Risk Group A and will, therefore, require the use of TWIC readers in Mode 3.  Thus these areas needed to be considered quantitatively for potential effects due to truck delays as a result of TWIC readers proposed for these locations in the preferred alternative.

A.6.1 Port of Palm Beach and Port Everglades
The Port of Palm Beach is located in Palm Beach County, Florida.  It is the fourth-busiest container port in Florida and the nineteenth-busiest in the United States.  The Port is a major nodal point of the shipment of bulk sugar (domestic usages), molasses, cement, utility fuels, water, produce, and break-bulk items.  The Port also supports nearly half a million cruise passengers taking day trips in the Atlantic, and a growing ferry service to the Bahamas (CH2M Hill, The Four Gates Company, and John C. Martin Associates, 2006).

Port Everglades is located in Broward County, in the heart of Greater Fort Lauderdale and the City of Hollywood, Florida.  It is one of the busiest cruise ports in the world and a leading container port in Florida.  The Port is South Florida's main seaport for receiving petroleum products including gasoline and jet fuel. The Port is among the top 15 container traffic ports in the United States (Broward County Board of County Commissioners, 2011).

Port Everglades and Port of Palm Beach are located in Broward County and Palm Beach County, respectively.  These counties are located in the Southeast Florida Airshed, which includes Broward, Miami-Dade, and Palm Beach counties.  The Airshed is currently in attainment for all federally-regulated standards (NAAQSs) (EPA, 2011h).  However, the Airshed is under the now revoked 1-hour ozone maintenance plan to ensure that the area remains in attainment for the current ozone standard for at least 10 years.  Figure A.1 presents the current ozone compliance values in Florida.  Broward County is in attainment for the current 75 ppb ozone standard at 60 ppb, while Palm Beach County is in attainment at 63 ppb.  Both counties are in attainment for all other NAAQSs (EPA, 2011h).

A.6.2 Southeast Florida Airshed Maintenance Area: Regulatory History
The Southeast Florida Area was designated nonattainment for the 1-hour ozone standard on November 6, 1991.  On November 8, 1992, the State of Florida submitted a request to re-designate the Southeast Florida Area to attainment for the 1-hour ozone standard. Florida also submitted the required 1-hour ozone monitoring data and maintenance plan ensuring this area would remain in attainment of the 1-hour ozone standard for at least 10 years.  On February 24, 1995, the Southeast Florida Area was designated attainment for the 1-hour ozone standard.  The Southeast Florida maintenance plan went into effect in April 1995 and was later updated to cover additional years such that the entire maintenance period was for at least 20 years after the initial re-designation of the area to attainment (75 FR 29671-29677).

On April 30, 2004, the U.S. Environmental Protection Agency (EPA) designated and classified areas for the 1997 8-hour ozone standard and published a final rule for implementation of the 1997 8-hour ozone standard. The Southeast Florida Area was designated as attainment for the 1997 8-hour ozone standard, effective June 15, 2004.  The areas designated as attainment were consequently required to submit a 10-year maintenance plan under section 110(a)(1) of the Clean Air Act of 1970, as amended (CAA), and the published final rule implementing the 1997 standard.  On July 2, 2009, the State of Florida submitted State Implementation Plan (SIP) revisions containing the 1997 8-hour ozone maintenance plan for Southeast Florida.  The purpose of this plan is to ensure continued attainment and maintenance of the 1997 8-hour ozone standard in the Southeast Florida Area until 2018 (75 FR 29671-29677).  

Based on data provided in the latest EPA-approved SIP for Southeast Florida it is demonstrated that the area is in attainment for the 1997 8-hour ozone standard and it is expected to continue attainment.  Table A.1 demonstrates decreasing levels of the ozone precursors VOC and NOx through 2018 and thus continued attainment for both the 1997 8-hour ozone standard and, consequently, the current 2008 8-hour ozone standard (75 CFR 29671-29677).  Even though the Southeast Florida Area is considered attainment for the 8-hour ozone standard, it is still subject to compliance with the now revoked 1-hour ozone maintenance measures till 2015. 

A.7 The San Pedro Bay Ports: Port of Los Angeles and Port of Long Beach
The Port of Los Angeles and neighboring Port of Long Beach together share the San Pedro Bay and are jointly known as the San Pedro Bay Ports.  The Ports comprise a significant regional and national economic engine for California and for the United States (Starcrest Consulting Group, LLC, 2010).  The San Pedro Bay Ports both ranked, in 2009, among the top 20 ports for the most container traffic in the world (American Association of Port Authorities, 2009).

A.7.1 California South Coast Air Basin (SoCAB)
The Ports are located within the California South Coast Air Basin (SoCAB, Figure A.2), which is the air basin that contains the largest urban area in the western US It has California's largest cities and the most industry, making it the most polluted air basin of the state (Starcrest Consulting Group, LLC, 2010).  The SoCAB is a non-attainment area for the national 8-hour ozone standard, PM10, and PM2.5 (EPA, 2011g).

Air quality monitoring stations have been placed throughout the San Pedro Bay Ports (Figure A.3).  There are currently six monitoring stations, which provide daily readings on emissions levels for all criteria pollutants.  Figure A.4 presents the daily observations from June 2010 to June 2011 for ozone.  Readings from the Terminal Island Monitoring Station suggest that ozone levels in Port of Los Angeles are lower than both the current ozone federal standard (0.075 ppm) and the California standard (0.07 ppm).  Readings for ozone levels from other monitoring stations are very similar to the levels shown by the Terminal Island Monitoring Station and do not exceed the federal standard. 

Figure A.5 presents the monthly average PM10 concentrations at all the monitoring stations in Port of Los Angeles for 2010.  Readings suggest that while PM10 levels at the beginning of 2010 have mostly exceeded the state standard (20 ug/m[3]), they have not exceeded the Federal standard (150 ug/m[3]).  As shown in Figure A.5, PM10 levels start to decrease in September.

Figure 6 presents the monthly average PM2.5 concentrations at all monitoring stations in the Port of Los Angeles.  Readings show that levels of PM2.5 at the Port do not exceed the state and Federal standard in 2010.  In addition, readings at all monitoring stations show that levels of PM2.5 at the Port of Los Angeles have decreased in the last 5 years (Figure A.7).  In fact, as shown in Table A.2, levels of all criteria air pollutants, according to readings from all monitoring stations in the Port of Los Angeles, decreased significantly from 2005  -  2009.

These observations demonstrate that while the San Pedro Bay Ports are located within a non-attainment area, emissions from the ports are mostly in attainment with the Federal standards for most criteria pollutants.  The progress that the San Pedro Bay Ports have made in reducing their emissions is, for the most part, a result of their joint initiative to develop and implement port-wide measures and programs to achieve their emissions reductions goals. 

A.7.2 Environmental Initiatives
In November 2006, the San Pedro Bay Ports adopted their landmark Clean Air Action Plan (CAAP), designed to reduce health risks and emissions associated with port-related operations while allowing port growth to continue.  In order to track port commitment to cleaner air, the Port of Los Angeles develops annual inventories of port-related sources starting with the 2005 Inventory of Air Emissions, which is the CAAP baseline.  The San Pedro Bay Ports CAAP initiative proposes to curb port-related air pollution from trucks, ships, locomotives and other equipment by at least 45% in 5 years.  The CAAP is the boldest air quality initiative by any seaport, consisting of wide-reaching measures to significantly reduce air emissions (Starcrest Consulting Group, LLC, 2010). 

As anticipated cargo volumes increase in the upcoming years, the reduction trend may not continue at the same rate experienced over the last few years.  However, continued implementation of several significant emission reduction programs, such as the Port's Clean Truck Program, Vessel Speed Reduction, Alternative Maritime Power Program, and the California Air Resource Board's (CARB's) regulatory strategies for port-related sources, is expected to substantially mitigate the impact of resumed cargo growth (Starcrest Consulting Group, 2010).

For heavy-duty vehicles, implementation of the Port's Clean Truck Program has resulted in a significant turnover of older trucks to newer and cleaner trucks.  The percentage of 2007+ model year trucks increased from about 4% in 2008 to 16% in 2009 (population-weighted basis).  The average age of the Port-related truck fleet was 10.9 years in 2009 compared to 12.1 years in 2008.  In terms of the calls made by these trucks to terminals, the call-weighted average age in 2009 was 6.9 years as compared to 11.6 years in 2008.  This indicates that a large number of newer trucks made proportionally more calls than their older counterparts (Starcrest Consulting Group, 2010).

A.8 Port of Hampton Roads, Virginia 
The Port of Hampton Roads, Virginia is the oldest continuously operating port system and the seventh-largest container port in the United States.  The combined ports of Norfolk, Newport News, and Plymouth along the banks of the James and Elizabeth rivers near the mouth of Chesapeake Bay comprise the Port of Hampton Roads.  Roughly 1,700 container ships visit Hampton Roads each year.  About 1,200 trucks and 4 trains leave the port carrying containers every day.  The port is managed by the Virginia Port Authority (VPA), a State government agency (Cannon, 2009). 

A.8.1 Hampton Roads Nonattainment Area
The Port of Hampton Roads is located in the Hampton Roads Nonattainment Area for the current 8-hr Ozone standard (Figure A.8).  However, it is under a maintenance plan for the 1997 8-hour Ozone standard.  The maintenance plan is effective until 2018 and helps the state achieve attainment levels (72 CFR 30490). 

A.8.2 Environmental Initiatives
In May 2005, the VPA formally adopted an environmental policy statement committing the VPA to strive to meet four environmental objectives.  The environmental protection program at Hampton Roads has focused on replacing the existing diesel engines in its vehicle fleet of cargo-handling equipment, generally older and more polluting models, with newer engines that comply with stricter emissions standards for on-road vehicle applications.  In October 2007, the VPA partnered with the EPA to launch a pilot program that offers low-cost financing to purchase diesel trucks with more emission-efficient engines or to retrofit older models for efficiency (Cannon, 2009).

A.9 Port Authority of New York and New Jersey
The Port of New York and New Jersey (PANYNJ) is the largest on the east coast, the third-largest in the U.S., and among the ten largest in the world.  It provides almost immediate access to one of the country's wealthiest regions and rail and truck access to half the nation (Starcrest Consulting, LLC, 2008).  It ranks 21 among the top-25 ports in the world for 2009 container traffic (AAPA, 2009).
A.9.1 New York/New Jersey/Long Island Nonattainment Area
PANYNJ is located in the New York/Northern New Jersey/Long Island Nonattainment Area (NYNJLINA) which includes 17 counties across the States of New Jersey and New York (Figure A.9).  The NYNJLINA boundary, recognized by the Regional Air Team, coincides with the EPA determination that this area has levels of ozone that "persistently exceed the national ambient air quality standards" (EPA, 2011).  In addition, in 2005 EPA determined that much of this area does not meet the current national air quality standards for PM2.5 (Starcrest Consulting Group, LLC, 2008).  Figure A.9 presents the NYNJLINA.  The area in blue represents nonattainment for PM2.5 while the area surrounded by the red dots represents the nonattainment area for 1997 8-hr Ozone.

Table A.3 presents criteria pollutant emissions by source category, the total PANYNJ emissions, the total emissions in the NYNJLINA in tonnes per year, and the percentage that the PANYNJ emissions make up of the total NYNJLINA emissions.  Heavy Duty Diesel Vehicles-related emissions for VOC, an ozone precursor, are minimal compared to NOx emissions, also an ozone precursor, which is the second-highest emission level in 2006.  Levels of PM2.5 emissions from heavy-duty diesel vehicles are not as significant. 

A 2007 report from PANYNJ, "Heavy Duty Diesel Vehicle (HDDV) Emissions Inventory," was developed to quantify emissions from heavy-duty diesel trucks that serve major marine terminal operations within PANYNJ.  Table A.4 compares statewide emissions, NYNJLINA emissions and emissions from heavy duty diesel vehicles within PONYNJ (Starcrest Consulting Group, LLC, 2008).  The results of the HDDV study indicate that emissions from HDDVs vehicles serving the marine terminals within the PANYNJ represent a small percentage of the total emissions within the NYNJLINA (Starcrest Consulting Group, LLC, 2008).  NOx emissions are probably the most significant contribution to the NYNJLINA emissions from HDDVs, although under 1% of NYNJLINA emissions.  It is also the most notable of the criteria pollutants because of its importance as an ozone precursor and the New York City area's continuing nonattainment area status within PANYNJ (GHG and CAP EI for the PANYNJ, 2010).

A.9.2 Drayage Truck Population 
A 2008 survey of drayage trucks conducted at PANYNJ includes model year distribution of the fleet of trucks serving the Port Authority terminals and an estimate of the total number of trucks in various model year groups.  Model year is an important characteristic of drayage trucks because newer trucks usually have lower emissions than older trucks since newer trucks are subject to stricter emission standards. 

Figure A.10 illustrates the percentage of trucks of each model year from the survey sample used in the report.  The most common model years are 1999 and 2000, which together account for slightly more than 25% of the trucks surveyed.  The average model year is 1998, which is 10 years old, and the median model year is 1999, which is 9 years old.  Only about 0.03% of trucks visiting the PANYNJ are model year 2007 or newer. 

A.9.3 Environmental Initiatives
PANYNJ has developed a Clean Air Strategy for the Ports of New York and New Jersey.  One of the main concerns is to significantly reduce nitrogen oxide (NOx) and particulate matter (PM) pollution, as well as greenhouse gases (GHG) (PANYNJ, 2011).  The 2009 completed Drayage Truck Characterization Survey will be used to prioritize actions to address truck emissions, with the overall goal of phasing out the oldest, most polluting trucks first (Ross & Associates, 2009).

PANYNJ and its marine terminal tenants have completed an initial phase of truck-related emissions reductions with a range of voluntary actions. For instance, tenant terminals have installed electronic gates, relocated gates, and extended gate hours to reduce air emissions associated with truck delays and congestion.  To begin the next phase of action, the Port Authority has begun the preliminary analysis needed to assess long-term improvements in the age of trucks calling the port, and to consider structural changes in the trucking business model (Ross & Associates, 2009). 

A.10 Port of Houston Authority
Known as a leader among U.S. ports, the Port of Houston is the 14[th]-largest port in the world, and is ranked first in the U.S. in foreign waterborne tonnage and second in the U.S. in total tonnage.  The port is located in the Houston-Galveston-Brazoria (HGB) eight-county area, classified by the EPA as an ozone nonattainment area.  Port of Houston Authority (PHA) launched the implementation of the Clean Air Strategy Plan in 2009. 

The PHA's associated emissions contribution is 3.1% to the overall 2005 HGB nonattainment area for NOx.  Emissions contributions from PHA HDDVs to the nonattainment area are 1.1 percent. 

On-terminal (as opposed to on-road) HDDV emissions are 10% of total HDDV emissions for NOx, PM and CO2, 30% of the CO emissions, and 1% of the SO2 emissions (Starcrest Consulting Group, LLC, 2009).  The on-road and on-terminal HDDV emissions associated with PHA facilities contribute 3.1% of NOx emissions, 5.6% of PM10 emissions, and less than 1% each of CO and SO2 emissions to the HGB nonattainment area HDDV emissions (Figure A.11).						


Appendix B. Sequencing of Activities at Port Facilities and Potential Implications for Alternative Analysis

Port facility operations have been studied by the U.S. Coast Guard (USCG) with the assistance of a contractor (Booz et al., 2011) in which they made observations on processing of security and other business functions (container custody transfers, safety checks, compliance with schedules, etc., Booz et. al, p. 9).  Their information confirmed that there is no "typical" port facility.  In general, the requirements and processes for arriving vehicles prior to gaining unescorted access to the port facility included:

      * Security screening of inbound vehicles.  When a truck arrived at the terminal for an import load, the driver communicated with security either through direct (face-to-face) communication with a security guard (or port police officer) who was physically located at the gate; or a more technology-centric process involving a combination of intercoms and cameras that enabled security staff to confirm, from a remote location, that the driver possessed a valid Transportation Worker Identification Credential (TWIC) and port-issued identification, and that those were matched to the driver's identity.  Once the officer verified the identity of the driver, verified their need for legitimate access to the facility (often a valid port-issued card served this purpose), determined that the driver was alone in the vehicle (either via Q&A or visual inspection of the vehicle cab/sleeper if required by State law) and had no other suspicions, the truck was allowed to proceed towards the interchange.
   
      * Business processing of vehicles/cargo inside port facilities (interchange transactions).  In addition to security gates at the entrances to port facilities, "business processes" are also an integral part of commerce operations at port facilities.  While the specific functions performed at interchanges varied by facility, the most common functions performed included conducting transfer of custody of cargo from the truck to the facility (for inbound trucks), providing locations and directions to truckers to drop-off cargo for subsequent transfer to a ship, checking for "holds" on cargo being imported to the U.S. (e.g., Customs or Department of Agriculture checks), conducting vehicle safety checks, etc.  These business processes may be labor intensive (e.g., gate operations personnel checking cargo manifests, chassis numbers and other paperwork prepared by a shippers prior to arrival at the gate), and sometimes resulted in diversion of the vehicle to a customer service area to resolve discrepancies.  The trucks were allowed to proceed to the transfer location on the yard (or depart the facility in the case of outbound trucks) when discrepancies were resolved and business processing was completed.  The location of the business processing at facilities also varied by facility.  At some facilities business processing occurred at the same gate as the security screening of drivers.  However, a number of facilities used secondary "Interchange" gates on the interior of the facility to manage business processes associated with cargo transfer operations.  These interchange gates were most often used for trucks carrying cargo into a terminal, but could also be used for outbound trucks.  More often, trucks exiting a facility were subjected to screening at exit gates...." 
                                          Booz et al., pp. 9-10

Nine facilities were selected for the study and the sequence of each operation is summarized in Table B.1.

     Table B.1. Analysis of Sequence of Port Entry Operations (Booz, 2011)
Facility/type
First step
Second step
Third step
Fourth step

Fifth step
Large container/
Mid-Atlantic

      
Truck enters queue
Port police officers check TWIC and port cards visually
Union Laborers conduct Interchange transaction and check chassis and container for road ability
Truck enters terminal







Medium container/
Mid-Atlantic
Truck enters queue
Port police Officers check TWIC and port cards using a proximity reader, cameras, and intercom
Union Laborers conduct Interchange transaction and check chassis and container for road ability
Truck enters terminal

Small-medium container/
Mid-Atlantic
Trucks pulls up to gate
Driver provides TWIC to Security Guard, who visually inspects and compares picture to driver
Security Guard places TWIC on proximity reader and computer display in guard shack shows picture of TWIC and confirms both driver identity and destination of vehicle within port facility
Gate opens automatically and truck enters terminal

Large break-bulk and car/
Mid-Atlantic
Truck pulls up to one of two sets of automated kiosks, depending on destination terminal
Driver picks up phone that rings automatically inside Security Guard booth
Remote cameras provide a video feed to the Security Guards showing the license plate, chassis numbers and the driver
Driver passes name, license number to Security Guard, who verifies that both the driver and vehicle are registered in eModal
If driver is registered in eModal or visiting the port for the first time, the kiosk prints out an access pass and river proceeds to terminal
Break bulk and container/
Southeast 
Truck pulls up to guard shack where security guard visually checks drivers/TWICs
Driver advances to PACS pylon, speaks via phone to gate agent located remotely, who uses remove cameras to inspect the chassis number and Driver's license number
Driver pulls under canopy to confirm the Interchange transaction and have the chassis and container checked for safety and reliability
Truck pulls into terminal

Break-bulk and container/
Southeast 
Truck pulls up and hands TWIC and port card to Gate Attendant
Gate Attendant processes in choice of three ways: 1) magnetic strip swipe linked to computers, 2) use handheld scanner, or 3) manually input
Gate Attendant visually checks the TWIC to verify the photo and expiration date
Trucks pulls into terminal

Small container/
Southeast
Truck pulls up and hands TWIC and port card to attendant
Gate Attendant processes in choice of three ways: 1)  magnetic strip swipe linked to computers, 2) use handheld scanner, or 3) manually input
Gate Attendant visually checks the TWIC to verify the photo and expiration date
Trucks pulls into terminal

Small Container/
Southeast
A single entry gate does security checks, port ID validation, TWIC validation, cargo, cargo custody transfer, trailer road ability and sleeper cab inspection




Large break-bulk and container/
Southeast
Driver pulls up to gate
Driver inserts port card into a swipe reader and TWIC into a video slot
Officers by remote use intercom and cameras to confirm identity of truck, container and chassis
Driver advances to privately operated interchanges



Analysis:  Review of the nine sample ports shows three general sequences (Table B.2):

* Sequence one: all security and business operations are done at an initial entry point (two sites),
* Sequence two: Security operations are completed and then truck goes to a second location for business transaction (four sites), or
*  Sequence Three: security operations are done in stages, and business operations are done in stages (three sites).
      
It is not known to what extent these are a representative sample of the entire array of more than 3,000 port facilities, but there does appear to be both variability and flexibility in the way that entry procedures are administered.  The implication with respect to security is addressed separately, but it appears that no trucks are allowed to enter a facility without first conducting a security review, which is usually a visual inspection of credentials, but sometimes involves TWIC readers for local port identification materials.  It would be expected that the utilization of TWIC readers will cause some delay in the processing of security information at truck entry.  

Implication for alternative analysis:  

In order to avoid potential delays, alternative approaches and the framework for alternative procedures may be considered.  However, there is limited information at this point on which to base a firm plan.  The basic approach would be to either provide additional access/entry points to speed processing and avoid backups at the present entry points or to consider doing security in stages.  For instance, the facilities might preserve the present security arrangements, but add an additional step in which TWICs would be read by TWIC readers and processed while business transactions are being conducted.  While this might have an advantage of avoiding processing delays at the entry of the facility, it would lead to additional resource requirements to create appropriate infrastructure (at the least, TWIC reader stations) and the implementation of administrative procedures. 

While there is the potential advantage of avoiding processing delays at the entry of the facility by changing business practices and thus mitigating any potential adverse environmental impacts, in the present situation, as shown in Table B.2, security arrangements are performed outside the facility before business practices.  Thus a change in sequencing might lead to additional resource requirements to create appropriate infrastructure (at the least, TWIC reader stations), changes in site perimeter designations, moving fences, etc., and the implementation of administrative procedures.  These are discussed in greater detail in Chapter 3 of the FPEA.

               Table B.2. Patterns of truck entry to facilities

Location of activity


Facility
Outside
Inside
General Pattern
1
security
business
2
2
security
business
2
3
security/destination
business
3
4
security/eModal
business
3
5
security/business
none
1
6
security
business
2
7
security
business
2
8
security/business
none
1
9
security/business
business
3



Appendix C. Data Sets

This section describes the data assumptions, formulas and calculations used in the U.S. Coast Guard's (USCG's) Final Programmatic Environmental Assessment (FPEA) for the potential impacts to air quality. 
C.1 TSA Data  
Data were derived from information at the Transportation Security Administration (TSA) pilot sites (Table 3).  TSA evaluated processing times for facilities using Transportation Worker Identification Credentials (TWIC) readers in an Initial Capability Evaluation (ICE) by measuring throughput, which is defined as the time taken for an ICE participant TWIC-holder to obtain entry as indicated by a TWIC reader response.  The time to pass through an access point was not included for ICE.  As reported by TSA, the time to complete a visual inspection when in Mode 1 was not included.  Based on data from the TSA pilot studies, delays due to TWIC reader operations are expected to be 1.75 seconds per transaction in Mode 1 and 8.36 seconds in Mode 3, and those are the TWIC reader baseline throughputs from ICE (Table C.1).
ICE was performed as a series of anticipated operational scenarios.  System implementation for ICE was relegated to the prospective TWIC reader vendor.  For ICE, the vendor system implementation was presumed by TSA to represent a preferred configuration for their TWIC reader.  ICE TWIC-holders were selected as participants based on their familiarity with the use of their TWIC for all TWIC reader modes of operation a TWIC reader might support.  TSA permitted either real or simulated Physical Access Control System (PACS) to be used during TWIC reader evaluation.  The prospective TWIC reader vendor was allowed to optimize the TSA's Canceled Card List (CCL) checking feature.

Table C.1. TWIC reader ICE Throughput Baseline in Seconds Per Transaction by Mode of Operation (TSA, 2012)[*]
                                  TWIC Reader
Mode 1
                                    Mode 3
                                     Fixed
                                     1.75
                                     8.36








   * Modes refer to operational steps: Mode 1 is use of the TWIC reader to verify the TWIC, including status, expiration date and visual verification of identity. Mode 3 is Mode 1 plus a biometric reading. 


C.2 Comparison of ICE Baseline Measures against the Visual Inspection Baseline Measure
C.2.1 Adjustment of Time for Visual Inspections in Mode 1
The time for visual inspections without use of TWIC reader is estimated at 6 seconds by TSA (TSA, 2011).  When the TWIC is used in Mode 1, it is estimated by subject matters experts that visual inspections take 3 seconds.  Visual inspection time using TWIC readers replaces the time that facilities would take to do a visual inspection of site-specific identification cards used for that specific facility.  The total idling time in Mode 1 is 1.75 seconds plus 3 seconds for a total of 4.75 seconds.  Thus, the event of doing a visual inspection in Mode 1 on the TWIC saves time and reduces idling time for the trucks 1.25 seconds.  Mode 3 adjustment was to remove 6 seconds from the processing time as described below.
ICE throughput in Mode 1 was compared to the visual inspection time of 6 seconds (which was reduced to approximately 3 seconds when the TWIC was used, since the card use eliminated some of the processing time for the security guard).  Note that a full identity verification was not performed in ICE for Mode 1, to ensure an accurate measure of TWIC reader transaction times.
Mode 1 provides enhanced security over visual inspection using many automated cross checks, including a cancel card check against the CCL.  In Mode 3, for fixed TWIC readers, processing time was 2.36 seconds slower than visual inspection.  In Mode 3 the TWIC reader checks that the "TWIC holder is the intended bearer of the TWIC" (TSA, 2011).
Throughputs for Mode 3 reflect the time a TWIC-holder needed to properly place their finger on a biometric sensor; a contributor in the final throughput value.  Further, ICE observed that even for experienced TWIC-holders, placement of their finger on the biometric sensor would occasionally result in a failure to attain a biometric match, thereby requiring a second attempt or additional time to resolve the issue.

A comparison of the range of TWIC reader ICE throughput results per TWIC reader mode of operation, against the visual inspection throughput baseline, is illustrated in Figure C.2.  The blue vertical lines indicate the range of minimum ICE throughput to maximum ICE throughput for each TWIC reader mode of operation.  Thus they are measures of the confidence limits for these mean values in the pilot studies.  As shown in Figure C.2, calculating the simple average for each TWIC reader mode of operation indicates that Mode 1 is faster than visual inspection.  There was a wide variance in ICE throughput for Mode 3.  The line at 6 seconds indicates the baseline time, i.e., the time it takes to do a visual inspection without a TWIC reader.
                                       

Figure C.2. ICE Throughput Results in Seconds for TWIC Readers (based on TSA, 2011)
                                       
                                       
C.2.2 Calculation of Delay Time Difference
For the analysis, to express the difference in processing time between the baseline (which is visual inspection only, analyzed at 6 seconds, in the TSA Report) and the delays in different modes the following assumptions are made in the FPEA as summarized below:

            1.  A Mode 1 transaction still requires a visual identification matching the photograph on the TWIC to the TWIC-holder.  There is some time saved in having the TWIC-holder flash a picture of the approved driver, with a camera display showing the driver and allowing the guard or video attendant to compare both images.  USCG subject matter experts estimated that it takes 3 seconds for this visual process when using a TWIC reader.  For the purposes of calculating a transaction time when using TWIC readers in Mode 1, the FPEA added these 3 seconds to the 1.75 seconds for a Mode 1 transaction, resulting in 4.75 seconds for a complete verification.  Thus, according to these calculations, a Mode 1 transaction is 1.25 seconds faster than a visual inspection without using the TWIC reader. 
         
            2. The total ICE transaction time reported for a Mode 3 transaction is 8.36 seconds.  However, a Mode 3 TWIC read does not require any visual inspection because it uses biometric (i.e., fingerprint) matching and, thus, 6 seconds per transaction (the time for a visual inspection as reported by TSA) is avoided.  In a Mode 3 transaction for an environmental analysis a potential impact from a baseline is analyzed.  The baseline for Mode 3 is the Mode 3 transaction time of 8.36 seconds minus the visual impact time of 6 seconds, for a net Mode 3 transaction time of 2.36 seconds.  This means that a Mode 3 read is 2.36 seconds slower than a visual inspection without a TWIC reader. 

Table C.2 TWIC Reader ICE Transaction Time Difference (Seconds) Compared to Visual Inspection[*]
                                  TWIC Reader
Mode 1
                                    Mode 3
                                     Fixed
                                     -1.25
                                     +2.36
                * Minus refers to time saved in the transaction
                                            
                                            
                                            
                                            
                                            
                                            

C.3 Emissions Data

C.3.1 U.S. Environmental Protection Agency Data
The U.S. Environmental Protection Agency (EPA) provided a weighted average of emissions based on the composition of model years of trucks entering the port.  These averages are used to calculate emissions in the Port of New York, Houston, Hampton Roads, Port of Palm Beach, and Port Everglades.

The data in Table C.3 were derived from an EPA study Houston, and were used as the standard for all but California ports (EPA, 2011n).

Table C.3. EPA Dataset that has a Weighted Average Emission Rate per Truck for an Average Port in the U.S.


Pollutant Type Emission rate [g/hr]
Model year
% Trucks entering the port
NOX
PM
THC
CO
pre-1990
3.55%
181.98
4.21
15.41
37.45
1990
0.65%
140.55
4.21
15.41
37.45
1991-1993
5.14%
132.14
4.21
15.41
37.45
1994-1997
24.25%
132.14
6.44
15.41
37.45
1998
9.84%
110.96
6.16
15.41
37.45
1999-2002
36.91%
146.37
6.16
15.41
37.45
2003-2006
13.48%
53.84
5.56
10.07
32.06
2007-2009
6.09%
26.92
0.30
2.01
6.41
2010
0.09%
6.43
0.19
1.11
3.53

Weighted Average rate 
120.05
5.60
13.86
34.80

EPA also provided data for weighted averages for ports in California.  Under California's Clean Truck Program, trucks models must be 2007 or newer.  These weighted averages are used to calculate emissions in the ports of LA and Long Beach.  THC and CO were not provided for these ports (EPA, 2011n), and so they are not included in Table C.4 below.

Table C.4. EPA Dataset that has a Weighted Average Emission Rate for an Average Port in California

                             Emission Rate [g/hr]
Model Year
CO 
NOx 
PM 
                                                                           2007
                                                                        3.52628
                                                                        26.9216
                                                                       0.016486
                                                                           2008
                                                                        3.52628
                                                                        26.9216
                                                                       0.016486
                                                                           2009
                                                                        3.52628
                                                                        26.9216
                                                                       0.016486
                                                                           2010
                                                                        3.52628
                                                                        6.42787
                                                                       0.016107
                                                                           2011
                                                                        3.52628
                                                                        6.42787
                                                                       0.016107
Weighted Average rate
                                                                        3.52628
                                                                      18.724108
                                                                       0.016335


C.4 Data Calculations

The following formula is used to estimate emissions from major ports. 









       Table C.5. Sources of Values Used in Emission Data Calculations 
Inputs
Sources of Values
# of TEU per year 
EPA 2008 (LA, Hampton Roads, NY, and Houston), AAPA 2009 (Everglades), and Port of Palm Beach. 2010 (Palm Beach)
Average TUE per container 
EPA 2008 
Delay time difference 
Table C.2
Criteria pollutant 
Tables C.3 (Average Port) and C.4 (California Port)


An example of the use of this formula is as follows:










The number of TEUs divided by the average TEU per container is to estimate the number of trucks per year.  The number of trucks is then multiplied by the transaction time difference and converted into hours.  This is then converted into hours and is multiplied by each criteria pollutant weighted average to get grams, which are converted into metric tonnes.  This provides each criteria pollutant emitted as expressed as metric tonnes per year.  

The following tables show results of calculations.  Total yearly emissions of the major ports of LA/Long Beach, Hampton Roads, Port of New York, Houston, Port of Palm Beach and Port Everglades are calculated using equation and values designated in the equation above.  See Chapter 4 of this FPEA for a discussion of the results. 


For each value shown below in Table C.6, the sources are designated in the equation above.  The total ICE transaction time difference is multiplied by each criteria pollutant weighted average rate to give the total criteria pollutant (expressed as grams) reduced per year. The LA port is a combination of the Port of LA and Long Beach and uses criteria pollutant values from Table C.4.  The remainder of the ports uses criteria pollutant values from Table C.3.  

       Table C.6. Mode 1 Emission Calculations of Four Major U.S. Ports
                                    Mode 1
                                    # TEU 
                                   per year
                                       
                           Average TEU per container
                                       
                                  # of Trucks
                                   per year
                                       
         Mode 1 Total ICE transaction time difference (hours per year)
                                       
                               NOx (g) per year
                                       
                               SOx (g)  per year
                                       
                               PM (g)  per year
                                       
                               THC (g)  per year
                                       
                               CO (g)  per year
                                       
                                  CO2 (g)   
                                   per year
                                       
                                 Input/Output
                                     Input
                                     Input
                                     Input
                                     Input
                                    Output
                                    Output
                                    Output
                                    Output
                                    Output
                                    Output
                                      LA
                                  15,667,504
                                     1.85
                                   8,468,921
                                     2,941
                                    55,060
                                      N/A
                                      48
                                      N/A
                                    10,369
                                      N/A
                                 Hampton Roads
                                   2,128,366
                                     1.74
                                   1,223,199
                                      425
                                    51,179
                                      31
                                     2,378
                                     5,887
                                    14,780
                                   3,314,104
                                      NY
                                   5,299,105
                                     1.71
                                   3,098,892
                                     1,076
                                    129,658
                                      79
                                     6,026
                                    14,913
                                    37,445
                                   8,396,060
                                    Houston
                                   1,020,002
                                     1.61
                                    633,542
                                      220
                                    26,508
                                      16
                                     1,232
                                     3,049
                                     7,655
                                   1,716,502



Table C.7. Grams from Previous Table Converted into Metric Tonnes (1 metric tonne = 106 grams)
                                   U.S. Port
                                      NOx
                                      SOx
                                      PM
                                      THC
                                      CO
                                      CO2
                                      LA
                                    0.05506
                                      N/A
                                   0.000048
                                      N/A
                                   0.010369
                                      N/A
                                 Hampton Roads
                                   0.051179
                                   0.000031
                                   0.002378
                                   0.005887
                                    0.01478
                                   3.314104
                                      NY
                                   0.129658
                                   0.000079
                                   0.006026
                                   0.014913
                                   0.037445
                                    8.39606
                                    Houston
                                   0.026508
                                   0.000016
                                   0.001232
                                   0.003049
                                   0.007655
                                   1.716502
                             De minimis threshold
                                      100
                                      100
                                      70
                                      N/A
                                      100
                                      N/A



For each value shown below in Table C.8, the sources are designated in the equation above.  The total ICE transaction time difference is multiplied by each criteria pollutant weighted average rate to give the total criteria pollutant (expressed as grams) emitted per year.  The LA port is a combination of the Port of LA and Long Beach and uses criteria pollutant values from Table C.4.  The remainder of the ports uses criteria pollutant values from Table C.3.  

       Table C.8. Mode 3 Emission Calculations of Four Major U.S. Ports
                                    Mode 3
                                      TEU
                                   per year
                                       
                           Average TEU per container
                                       
                                Trucks per year
                                       
         Mode 3 Total ICE transaction time difference hours per year)
                                       
                               NOx (g) per year
                                       
                                   SOx (g) 
                                   per year 
                                PM (g) per year
                                       
                               THC (g) per year
                                       
                                    CO (g) 
                                   per year
                                       
                                   CO2 (g) 
                                   per year
                                       
                                 Input/Output
                                     Input
                                     Input
                                     Input
                                     Input
                                    Output
                                    Output
                                    Output
                                    Output
                                    Output
                                    Output
                                      LA
                                  15,667,504
                                     1.85
                                   8,468,921
                                     5,552
                                    103,953
                                      N/A
                                      91
                                      N/A
                                    19,577
                                      N/A
                                 Hampton Roads
                                   2,128,366
                                     1.74
                                   1,223,199
                                      802
                                    96,626
                                      64
                                     4,490
                                    11,114
                                    27,905
                                   6,257,029
                                      NY
                                   5,299,105
                                     1.71
                                   3,098,892
                                     2,031
                                    269,690
                                    244,795
                                    11,376
                                    28,157
                                    70,696
                                  15,851,761
                                    Houston
                                   1,020,002
                                     1.61
                                    633,542
                                      415
                                    55,136
                                      30
                                     2,326
                                     5,756
                                    14,453
                                   3,240,755


Table C.9. Grams from Previous Table Converted into Metric Tonnes (1 metric tonne = 10[6] grams)
                                   U.S. Port
                                      NOx
                                      SOx
                                      PM
                                      THC
                                      CO
                                      CO2
                                      LA
                                     0.104
                                      N/A
                                    0.00009
                                      N/A
                                    0.0196
                                      N/A
                                 Hampton Roads
                                    0.0966
                                   0.000059
                                    0.00449
                                    0.0111
                                    0.0279
                                     6.26
                                      NY
                                     0.245
                                   0.000148
                                    0.0114
                                    0.0282
                                    0.0707
                                     15.9
                                    Houston
                                     0.05
                                    0.00003
                                    0.00233
                                    0.00576
                                    0.0145
                                     3.24
                             De minimis threshold
                                      100
                                      100
                                      70
                                      N/A
                                      100
                                      N/A


For each value shown below, the sources are designated in the equation above.  The total ICE transaction time difference is multiplied by each criteria pollutant weighted average rate to give the total criteria pollutant (expressed as grams) emitted per year.  Specific information on average TEU per container for these ports was unavailable so for the purpose of this analysis, an estimated 1.7 TEU per container was based on EPA 2008 data.  

           Table C.10. Mode 3 Emission Calculations of Florida Ports
                                    Mode 3
                                 TEU per year
                                       
                           Average TEU per container
                                       
                                    Trucks
                                       
           Mode 3 Total ICE transaction time difference (hours/year)
                                       
                               NOx (g) per year
                                       
                                   SOx (g) 
                                   per year
                                       
                                PM (g) per year
                                       
                               THC (g) per year
                                       
                                    CO (g) 
                                   per year
                                       
                              CO2 (g)   per year
                                       
                                 Input/Output
                                     Input
                                     Input
                                     Input
                                     Input
                                    Output
                                    Output
                                    Output
                                    Output
                                    Output
                                    Output
                              Port of Palm Beach
                                    206,585
                                      1.7
                                    121,521
                                      80
                                     9,599
                                       6
                                      446
                                     1,104
                                     2,772
                                    621,614
                                Port Everglades
                                    796,160
                                      1.7
                                    468,329
                                      307
                                    36,995
                                      22
                                     1,719
                                     4,255
                                    10,684
                                   2,395,645

Table C.11. Grams from Previous Table Converted into Metric Tonnes (1 metric tonne = 106 grams)
                                   U.S. Port
                                      NOx
                                      SOx
                                      PM
                                      THC
                                      CO
                                      CO2
                              Port of Palm Beach
                                    0.0106
                                   0.000006
                                   0.0004446
                                    0.0011
                                    0.00277
                                     0.622
                                Port Everglades
                                    0.0406
                                   0.000022
                                    0.00172
                                    0.00426
                                    0.0107
                                      2.4
                             De minimis threshold
                                      100
                                      100
                                      100
                                      N/A
                                      100
                                      N/A
                                       
C.5 Solving for Transaction Time
In Chapter 4 of this FPEA, an estimate of time TWIC readers needed to add to transaction times in order to have a significant impact on air quality, the output of emissions was set at 10 metric tonnes to solve for transaction time.  For the purpose of this exercise, the Port of New York and the criteria pollutant NOx was selected.  The following equation was used to solve for transaction time difference.  









Appendix D. Air Quality Criteria.
Table D.1. National Ambient Air Quality Standards under the Clean Air Act (EPA, 2011a)
                                       
                               Primary Standards
                              Secondary Standards
                                   Pollutant
                                     Level
                                Averaging Time
                                     Level
                                Averaging Time
Carbon 
Monoxide
9 ppm 
(10 mg/m[3]) 
8-hour [(1)] 
                                     None 

35 ppm 
(40 mg/m[3])
1-hour [(1)]

Lead
0.15 ug/m[3] [(2)]
Rolling 3-Month Average
                                Same as Primary
Nitrogen 
Dioxide
53 ppb [(3)]
Annual 
(Arithmetic Average)
                                Same as Primary

100 ppb
1-hour [(4)] 
                                     None 
Particulate 
Matter (PM10)
150 ug/m[3]
24-hour [(5)]
                                Same as Primary
Particulate 
Matter (PM2.5)
15.0 ug/m[3]
Annual [(6)] 
(Arithmetic Average)
                                Same as Primary

35 ug/m[3]
24-hour [(7)]
                                Same as Primary
Ozone
0.075 ppm 
(2008 std) 
8-hour [(8)] 
                               Same as Primary 

0.08 ppm 
(1997 std) 
8-hour [(9)] 
                               Same as Primary 

0.12 ppm
1-hour [(10)] 
                                Same as Primary
Sulfur 
Dioxide
0.03 ppm [(11)]
(1971 std)
Annual 
(Arithmetic Average) 
                                   0.5 ppm 
                                 3-hour [(1)] 

0.14 ppm [(11)]
(1971 std)
24-hour [(1)]



75 ppb [(12)]
1-hour
                                     None 
[(1)] Not to be exceeded more than once per year.
[(2)]Final rule signed October 15, 2008. The 1978 lead standard (1.5 ug/m[3] as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved. 
[(3)] The official level of the annual NO2 standard is 0.053 ppm, equal to 53 ppb, which is shown here for the purpose of clearer comparison to the 1-hour standard.
[(4)] To attain this standard, the 3-year average of the 98th percentile of the daily maximum 1-hour average at each monitor within an area must not exceed 100 ppb (effective January 22, 2010).
[(5)] Not to be exceeded more than once per year on average over 3 years.
[(6)] To attain this standard, the 3-year average of the weighted annual mean PM2.5 concentrations from single or multiple community-oriented monitors must not exceed 15.0 ug/m[3].
[(7)] To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor within an area must not exceed 35 ug/m[3] (effective December 17, 2006).
[(8)] To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.075 ppm (effective May 27, 2008). 
[(9)] (a) To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.08 ppm. (b) The 1997 standard - and the implementation rules for that standard - will remain in place for implementation purposes as EPA undertakes rulemaking to address the transition from the 1997 ozone standard to the 2008 ozone standard. (c) EPA is in the process of reconsidering these standards (set in March 2008).
[(10)] (a) EPA revoked the 1-hour ozone standard in all areas, although some areas have continuing obligations under that standard ("anti-backsliding"). (b) The standard is attained when the expected number of days per calendar year with maximum hourly average concentrations above 0.12 ppm is <= 1.
(11) The 1971 sulfur dioxide standards remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.
[(12)] Final rule signed June 2, 2010. To attain this standard, the 3-year average of the 99th percentile of the daily maximum 1-hour average at each monitor within an area must not exceed 75 ppb.

Appendix E. Department of Homeland security (DHS) Approaches: US-VISIT Program Draft Environmental Assessment

In April 2006, the U.S. Department of Homeland Security (DHS) analyzed potential changes to the immigration and border management processes in the United States Visitor and Immigrant Status Indicator Technology (US-VISIT) Final Programmatic Environmental Assessment (FPEA), which resulted in a Finding of No Significant Impact (FONSI) (DHS, 2006).  The US-VISIT Program was established to develop entry and exit processes and integrate immigration data and processes with other DHS agencies.  The FPEA examined the environmental impacts of implementing strategic, high-level changes to the immigration and border management environment.  The Proposed Action in the FPEA examined implementation of a system (such as a biometrically-based system, i.e., finger scans) capturing the unique identity of travelers.  The goals of US-VISIT are to enhance the security of U.S. citizens and visitors to the U.S., facilitate legitimate travel and trade, ensure the integrity of the U.S. immigration system, and protect the privacy of visitors to the United States.  Of all the immigration and border management facilities, land border ports of entry are the places where changes in processes and infrastructure are more likely to affect the environment and are therefore the focus of the US-VISIT FPEA.

US-VISIT took a programmatic approach to the analysis because no matter where implemented, the proposed actions have common timing, common impacts, common alternatives, common methods of implementation and common subject matter.  The programmatic analysis will inform policy and strategy development for modifying plans or systems in order to minimize potential environmental impacts.  This approach allows decision-makers to prepare tiered analyses to discuss the particular resources and potential impacts at site-specific locations or for specific initiatives and to allow for implementing the appropriate mitigation, monitoring and adaptive management techniques before moving forward with specific proposals on the ground.  For example, if an area is in non-attainment or maintenance in terms of air quality requirements, coordination with the appropriate state agency will be sought.  Subsequent tiered analyses would evaluate air quality impacts at the site-specific level.  The FPEA considered the following alternatives:

E.1 Alternatives Considered (Including the No Action Alternative)

No-Action Alternative (as required by NEPA):
   * Calls for current processes for assessing individuals and planned improvements and/or increases facilities, infrastructure, technology and staff to continue at the current rate without significant change.
   * Entry, exit and status processes would continue as they are today.


Hybrid Alternative (preferred alternative):
   * Involves a blend of technology and physical resource solutions that would be used to meet the purpose and need.
   * Involves a combination of installing information technology with remote scanners, TWIC readers, biometrics and some physical construction.
   * Involves changes in immigration processes, such as establishing procedures to assign a unique identity to individuals and to standardize data collection.
   * Involves new applications of existing technologies, such as fingerprinting, and the use of new technologies.
   * Involves the construction or expansion of facilities, such as centralized facilities for data analysis and some exit-related infrastructure.  It could also include the addition of special lanes at land border crossings.

Physical Border Alternative:
   * Requires interaction with a government official at every encounter.
   * Expansion of existing ports of entry to meet demand for increased data collection.
   * Introduce exit processes that mirror current entry processes as well as the associated physical infrastructure.
   * Constructing or reconstructing immigration and border management facilities, expanding lanes and roads at entry and exit points.
   * Adding additional processes and personnel to meet the purpose and need.

Virtual Border Alternative:
   * Seeks to move processes abroad and use information technology and automated processes such as remote TWIC readers and smart chips to increase data acquisition and analysis, and to improve status determination on individuals.
   * Relies on decentralized acquisition of data (mostly abroad) and integrated databases.
   * Most immigration and border management processes currently taking place at land border ports of entry would be moved and combined with processes that occur at other facilities overseas and in the United States, resulting in a dispersion of processes away from the land border.
Appendix F. Memorandum from EPA on the Use of Moves Model and Data Application


MEMORANDUM

From: 	Prashanth Gururaja
      U.S. Environmental Protection Agency
      Office of Transportation & Air Quality
      2000 Traverwood Dr.
      Ann Arbor, MI 48105
      734.214.4771

To: 	Jon C. Cooper
	Office of Standards Evaluation and Development CG-523
	US Coast Guard
	Washington, DC 20593

Date: July 29, 2011

Subject: Emissions Impacts of TWIC

This memo explains our assistance to you concerning the TWIC 2 process.

Background:  

The US Coast Guard (USCG) is in the process of developing a rule-making for the Transport Worker Identification Cards (TWIC) Card Reader program, an element of a security program to protect US ports. This program is being done in association with the Transport Security Agency (TSA) of Department of Homeland Security.  To support that process the CG-5231 program is preparing an Environmental Assessment for that rule. It is anticipated that the TWIC Reader program will result in delays while the cards are being processed by the TWIC Reader system. These delays are being quantified through a pilot study by the TSA at selected US ports.  These delays have been measured to be between 1 to 24 seconds in most facilities. It is then anticipated that these delays will result in idling of trucks during this period, resulting in additional air emissions during that period.

The USCG has asked us to assist them in the technical application of models and information on air quality from the US EPA on this issue. We have discussed these matters through emails and a telephone conversation and now explain our methodology.





Methodology: 

Our office at EPA has developed a mobile source emissions inventory model, Motor Vehicle Emissions Simulator (MOVES), which estimates vehicle emissions for a broad range of pollutants at various scales.  MOVES is the most comprehensive mobile source emissions inventory model in use today.  It has been peer-reviewed by technical experts and vetted by a multitude of stakeholders, including state/local environmental and transportation agencies, industry, and environmental groups.  It is the model states are required to use when developing their State Implementation Plans to minimize air pollution from the mobile source sector.  

A component of the inputs to MOVES is gram-per-hour emission rates for different operating modes.  One of these operating modes is curb idling.  Curb idling is vehicle idling occurring during normal driving patterns.  For combination long-haul trucks, there is also an extended idling operating mode, which is discretionary overnight idling for the purposes of providing climate control or powering electrical devices.  For the purpose of the TWIC problem, we assume that any delays from just that program will result in additional time of truck curb idling only.   Therefore, the issue is how to quantify any emissions associated with that idling.

I identified data on curb idling for Class 8 diesel vehicles (the types of vehicles that would be expected at port facilities).  These data, which are default inputs in MOVES, quantify emission rates in g/hr for nitrogen oxides (NOx), particulate matter (PM), total hydrocarbons (THC), and energy consumption rates in kJ/hr.  These rates are stratified by model year group and age group.  Since curb idling is an independent operating mode in MOVES, there is no need to run the actual model to come up with an emission factor for this problem.  The appropriate factors can be queried from the existing default input tables.  In fact, running MOVES and using MOVES output would be inappropriate since the output is generally fleet-wide in nature and combines all operating modes within the selected scale and geography.  


To estimate average emission rates while idling, we prepared an estimate of the composition of trucks of various model years that would be expected. This table was based on a study that we are in the process of completing for the Port of Houston. In that study, we obtained from the Port of Houston model year information of trucks entering the port over a twelve-month period from 2008 to 2009. While the results of that study are being finalized, we are confident that these data are a reasonably representative sample of trucks that would be expected at that port.  As a simplifying assumption and due to lack of nationwide port data, we considered this model year mix as a reasonable representation of the entire country's ports.  

We have presented our tables on the mixture of model years and our calculation of weighted average emission rates to you in a previous email, and we have reproduced the results in Table 1 below.

Table F.1. EPA Estimates of Emissions Rates from Diesel Truck while Curb Idling
                                       


                             Emission rate [g/hr]
Model year
Port entrances
NOX
PM
THC
CO
                                                                       pre-1990
                                                                          3.55%
                                                                         181.98
                                                                           4.21
                                                                          15.41
                                                                          37.45
                                                                           1990
                                                                          0.65%
                                                                         140.55
                                                                           4.21
                                                                          15.41
                                                                          37.45
                                                                      1991-1993
                                                                          5.14%
                                                                         132.14
                                                                           4.21
                                                                          15.41
                                                                          37.45
                                                                      1994-1997
                                                                         24.25%
                                                                         132.14
                                                                           6.44
                                                                          15.41
                                                                          37.45
                                                                           1998
                                                                          9.84%
                                                                         110.96
                                                                           6.16
                                                                          15.41
                                                                          37.45
                                                                      1999-2002
                                                                         36.91%
                                                                         146.37
                                                                           6.16
                                                                          15.41
                                                                          37.45
                                                                      2003-2006
                                                                         13.48%
                                                                          53.84
                                                                           5.56
                                                                          10.07
                                                                          32.06
                                                                      2007-2009
                                                                          6.09%
                                                                          26.92
                                                                           0.30
                                                                           2.01
                                                                           6.41
                                                                           2010
                                                                          0.09%
                                                                           6.43
                                                                           0.19
                                                                           1.11
                                                                           3.53

Average rate -->
                                                                         120.05
                                                                           5.60
                                                                          13.86
                                                                          34.80






Volatile organic compounds (VOC) are a subset of THC.  For pre-2007 model years, you can assume VOC emission rates equal to THC emission rates.  Because the use of diesel particulate filters (DPFs) in diesel trucks changes the VOC-to-THC ratio, a ratio of 0.5327 should be used to estimate VOC emission rates for model years 2007 and later, which are equipped with DPFs.  This ratio was determined from the Advanced Collaborative Emissions Study (ACES) directed by the Health Effects Institute and Coordinating Research Council, with participation from a range of government and private sector sponsors.  

CO2 and SO2 do not vary by model year group in MOVES.  They are both based off of the curb idling energy rate of 107,131 kJ/hr for Class 8 diesel vehicles.  For diesel fuel, we can assume a heating value of 138,451 kJ/gallon, a CO2 content of 10,084 g/gallon, and a density of 6.9 lb/gallon.  EPA limits sulfur content in diesel fuel to 15 ppm mass.  Also, for every lb of sulfur in the fuel, you get 2 lb of SO2 in the exhaust (i.e. one mole of sulfur in the fuel yields one mole of SO2 in the exhaust).  These assumptions and calculations are described by the equations below.



It would appear that using these weighted average emission rates along with data on idling times for trucks (due to TWIC) would allow you to calculate quantities of pollutants at each facility (for which you have data). 

You can also make some estimates on future scenarios by changing the ratio of trucks' model years for the purpose of your analysis. So, for instance, you might have a higher percentage of model year 2010 trucks and lower percentage of pre-1990 model year trucks. 

As we discussed, I suggest that you speak with other specialists to assess how to analyze the above data with respect to air quality impacts. Using geographic specific ambient air quality in the port areas you have studied will allow you to make predictions on potential increases in pollutants to those areas. 
Appendix G. Summary of Field Trips to Container Facilities and Observations by USCG Personnel


FACILITY/LOCATION
DATES
OBSERVATIONS
Port of Los Angeles and Long Beach
21-23 September 2011
Participated in TWIC pilot program. USCG were told that TSA reported delay times were optimistic and that there were failure rates with contact TWIC readers of up to 12% and 70% with contactless TWIC readers; technology needed improvement. Other facilities liked TWIC program and found it led to a drop in theft do to screening of TWIC eligible individuals.
Observed some longer processing times due to need for training of drivers on how to insert cards, etc.
Port managers advised that there were no significant biological or historical resources to be impacted by TWIC readers.
Port of New York and New Jersey
27-29 July 2011
Participated in TWIC pilot program. One facility reported massive delays during TWIC pilot and need to ask for exemption during rush times for trucks; delays during shift changes at pedestrian gates; one facility reported that it would be difficult to institute process changes to accommodate TWIC readers, if required.
Port managers advised that there were no significant biological or historical resources to be impacted by TWIC readers.
Port of Baltimore
12 January 2012
Facilities had no experience with TWIC readers, but due to relatively large number of entry points, facilities reported that there would be significant expense and training needed if TWIC readers were required.
Port of Miami and Everglades
26-27 October 2011
Due to configuration of Port Everglades, it appeared that a large number of TWIC portable readers would be needed if required by regulation (as is presently planned by TWIC reader program office. Facilities reported that they were need up to 3 years to upgrade facilities and do training to implement a TWIC reader program. No experience in pilot program with TSA.
Port managers advised that there were no significant biological or historical resources to be impacted by TWIC readers.
                                       

Appendix H. Marine Security Risk Analysis Model Description
As discussed in the Final Programmatic Environmental Assessment (FPEA), Transportation Worker Identification Credential (TWIC) reader deployment to specific facilities is determined by a risk-based analysis.  This analysis under the Marine Security Risk Analysis Model (MSRAM) assigns three levels of risk groups: Risk Groups A, B, and C and are defined as shown in Figures H.1 and H.2.  This material was developed for the Advanced Notice of Proposed Rulemaking (ANPRM) and further studied for the Notice of Proposed Rulemaking (NPRM) and the final rule.

At the direction of the Office of Management and Budget (OMB), the U.S. Coast Guard (USCG) tasked the Homeland Security Institute (HSI) to conduct an independent peer review of its TWIC implementation analysis.  This included an independent verification and validation of the reader requirements development process.  This involved a verification and validation of the MSRAM-based risk hierarchy presented in the ANPRM.  Based in part on the findings and recommendations of this study, the USCG adjusted the applicability of the reader requirements from the ANPRM in the NPRM.  As the HSI report shows, the distinction between Risk Groups A and B, based on the Analytic Hierarchy Process (AHP) is well defined, with Risk Group A scores greater or equal to a specified threshold.  The distinction between Risk Groups B and C is not as clear as that between A and B, with entities in both Risk Group B and Risk Group C having AHP scores lower than the threshold.  As such, for the final rule, we have removed the reader requirements for Risk Group B and will focus only on the requirements for Risk Group A.  Figure H.3 below shows the rank-ordered AHP scores for all 68 TWIC asset categories.  Current risk groupings considered in the TWIC report are also displayed.  As discussed in the final rule Regulator Analysis, the Coast Guard considered the costs and benefits when deciding which facilities should be required to install readers and concluded that the level of risk, discussed as consequence, associated with targets in Risk Groups B and C does not warrant the investment in readers.  In contrast, facilities in Risk Group A have significantly higher risk and can be more cost-effectively protected through this rule.

              Figure H.1. Risk Groups for MTSA-regulated Vessels
--------------------------------------------------------------------------------
Risk Group A 
--------------------------------------------------------------------------------
(1) Vessels that carry Certain Dangerous Cargoes (CDC) in bulk;
--------------------------------------------------------------------------------
(2) Vessels certificated to carry more than 1,000 passengers; and
--------------------------------------------------------------------------------
(3) Towing vessels engaged in towing barges subject to paragraphs (1) or (2).
--------------------------------------------------------------------------------

--------------------------------------------------------------------------------
Risk Group B
--------------------------------------------------------------------------------
(1) Vessels that carry hazardous materials other than CDC in bulk;
--------------------------------------------------------------------------------
(2) Vessels subject to 46 CFR chapter I, subchapter D, that carry any flammable or combustible liquid cargoes or residues;
--------------------------------------------------------------------------------
(3) Vessels certificated to carry 500 to 1,000 passengers; and
--------------------------------------------------------------------------------
(4) Towing vessels engaged in towing a barge or barges subject to paragraphs (1), (2), or (3). 
--------------------------------------------------------------------------------

--------------------------------------------------------------------------------
Risk Group C
--------------------------------------------------------------------------------
(1) Vessels carrying non-hazardous cargoes that are required to have a vessel security plan;
--------------------------------------------------------------------------------
(2) Vessels certificated to carry fewer than 500 passengers;
--------------------------------------------------------------------------------
(3) Towing vessels engaged in towing barges subject to paragraphs (1) or (2);
--------------------------------------------------------------------------------
(4) Mobile Offshore Drilling Units; and
--------------------------------------------------------------------------------
(5) Offshore Supply Vessels (OSVs) subject to 46 CFR chapter I, subchapters L or I.

            Figure H.2. Risk Groups for MTSA-regulated Facilities*
--------------------------------------------------------------------------------
Risk Group A
--------------------------------------------------------------------------------
(1) Facilities that handle CDC in bulk; and
--------------------------------------------------------------------------------
(2) Facilities that receive vessels certificated to carry more than 1,000 passengers.
--------------------------------------------------------------------------------

--------------------------------------------------------------------------------
Risk Group B
--------------------------------------------------------------------------------
(1) Facilities that receive vessels that carry hazardous materials other than CDC in bulk;
--------------------------------------------------------------------------------
(2) Facilities that receive vessels subject to 46 CFR chapter I, subchapter D, that carry any flammable or combustible liquid cargoes or residues.
--------------------------------------------------------------------------------
(3) Facilities that receive vessels certificated to carry 500 to 1,000 passengers; and
--------------------------------------------------------------------------------
(4) Facilities that receive towing vessels engaged in towing a barge or barges carrying hazardous materials other than CDC in bulk, crude oil, or certificated to carry 500 to 1,000 passengers. 
--------------------------------------------------------------------------------

--------------------------------------------------------------------------------
Risk Group C
--------------------------------------------------------------------------------
(1) MTSA-regulated facilities that receive vessels carrying non-hazardous cargoes that are required to have a vessel security plan; 
--------------------------------------------------------------------------------
(2) Facilities that receive towing vessels engaged in towing a barge or barges carrying non-hazardous cargoes;
--------------------------------------------------------------------------------
(3) Facilities that receive vessels certificated to carry fewer than 500 passengers. 
--------------------------------------------------------------------------------

--------------------------------------------------------------------------------
* OCS facilities subject to 33 CFR part 106 fall into Risk Group B.

     Figure H.3. Rank-ordered AHP Scores, with Current TWIC Risk Groupings





