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All milestone documents may be found at: CAPCO Air Quality News
1.1.3 How the EAC Applies to the A/RR MSA The MSA is designated attainment for the 1-hour ozone standard and continues to monitor attainment of that standard. The region has not exceeded the 1-hour standard since 1985. The MSA has intermittently monitored violations of the 8-hour ozone standard from 1998 through 2002 and is currently in attainment. (In order to comply with the 8-hour standard, each monitor’s three-year average of the annual fourth-highest 8-hour ozone reading must be less than 85 ppb.) As such, the region meets the criteria for participation in an EAC. Elected officials in the MSA entered into the EAC with EPA and TCEQ because monitored exceedances of the 8-hour standard indicate concentrations of ground-level ozone inconsistent with protecting public health and the environment.
1.1.4 Geographic Coverage of the CAAP
1.2 Public Involvement Program The involvement project had two goals: (1) to provide venues for participation by interested parties; and (2) to provide air quality information to the general public. Stakeholder involvement activities included those aspects of the project directly related to gathering input on the emission reduction strategies. Public involvement activities, while also soliciting input, focused on increasing public understanding of air quality issues and the EAC process. The local EAC signatory jurisdictions played a key role. They facilitated public participation by hosting public meetings. They also reviewed and selected CAAP strategies. The Clean Air Coalition, composed of one elected-official representative from each of the local EAC signatory jurisdictions, bore primary responsibility for CAAP development decisions. The EAC Task Force, composed of staff from local signatory jurisdictions, participating agencies, business and environmental groups, developed and recommended the initial CAAP for CAC and signatory consideration. The CAC met at least quarterly throughout the CAAP development process and continues to meet regularly. The EAC Task Force met twice monthly during CAAP development and continues to meet regularly. Both CAC and EAC Task Force meetings are open to the public. Additional information on the CAC and EAC Task Force is found in Appendices 1-4 and 1-5, respectively.
1.2.2 Stakeholder Involvement Activities These work groups continued to meet regularly throughout 2003. Each work group drafted a list of strategies to be considered for inclusion in the CAAP. Their work is the backbone of the plan development. Additional information on stakeholder involvement activities is found in Appendices 1-6 and 1-7.
1.2.3 Public Involvement Activities 1.3 Policy Statements The following statements reflect the positions of the local EAC signatories.
1.3.1 Fair Share
1.3.2 Regional Emission Reduction Measures and Implementation Barriers Typically, one city or county cannot tackle the issue alone. Indeed, "local" in this case covers a five-county region in Texas and 12 local governmental jurisdictions. It is important to note that the latter represent only a handful of the total number of governmental jurisdictions in the region. For example, while the City of Austin and Travis County are the only two EAC signatories from the county, there are more than 20 other municipalities with jurisdiction in Travis County alone. Each has authority over adoption of ordinances and regulations. Note that the State of Texas does not grant ordinance authority to counties. Consequently, it is almost impossible to implement regional emission reduction measures in the absence of state regulations; hence the need for the State Assisted Measures outlined in Chapter 5. The only alternatives to this approach require substantial legislative actions. These have been introduced in past legislative sessions and routinely defeated.
1.3.3 The Role of Transport in the CAAP The 2007 Base Case assumes substantial emission reduction measures will be implemented by federal, state, other local and private entities located outside the five-county A/RR MSA. For example, the model assumes the Houston/Galveston SIP will be successful in 2007 and that the ALCOA Consent Decree will be implemented no later than March 2007. While these assumptions are reasonable and necessary, their validity remains uncertain.
1.3.4 Texas Low Emission Diesel (Tx LED)
1.3.5 Proposed Mitigation Measures
1.3.6 Periodic Review
1.3.7 Modeling of Major New Sources
2.1 Overview Details for the development of the 1999 and 2007 EIs, developed per EPA and EAC guidance, are found in Appendices 2-1 and 2-2.
2.2 Point Sources
2.3 Area Sources These emissions fall below point source reporting levels and are too numerous or too small to identify individually. Emissions-estimate calculations use an established emission factor (emissions per unit of activity) multiplied by the incidence of the relevant activity or activity surrogate. Population is the most common activity surrogate. Others include gasoline sales, employment by industry type and acres of cropland. Bottom-up approaches estimate activity factors from surveys. Top-down approaches use generic activity factors based on national, state or county data. Emission factors can be a category-specific generic estimate or can be developed locally (e.g., based on product usage).
2.4 On-Road Mobile Sources The MSA EI uses EPA’s mobile emissions factor model, MOBILE6. Model inputs simulate vehicle fleet driving and include vehicle speeds by roadway type, vehicle registration by type and age, percentage of vehicles in cold and hot start and stabilized modes, percentage of miles traveled by vehicle type and age, and use of a vehicle Inspection and Maintenance Program (I/M), where applicable. Model inputs also include gasoline parameters such as sulfur content and Reid vapor pressure, temperature and humidity. Input parameters reflect local conditions to the extent possible. The MOBILE model emission factors multiplied by VMT estimates complete the emissions estimate. Future VMT estimates use the Capital Area Metropolitan Planning Organization (CAMPO) travel demand model for Hays, Travis and William-son Counties. Future VMT estimates for Bastrop and Caldwell Counties use a GIS-based highway performance monitoring system methodology developed by Texas Transportation Institute (TTI). The CAMPO travel model inputs include future population and employment estimates spatially allocated by traffic serial zone. Model inputs also include a roadway network of all regionally significant roads expected to be open and operational in the timeframe modeled. The spatial allocation of the population and employment estimates takes into account all new roads that will be open and operational in the timeframe modeled. This addresses development and induced demand created by new roads. The travel model estimates VMT associated with the transportation system as a whole. Because a change in one part of the transportation system often affects another part of the system (e.g., adding a new road may reduce VMT on another road), a system-wide analysis produces the best estimate of emissions associated with vehicles using existing and new roadways.
2.5 Non-Road Mobile Sources
2.6 Biogenic Sources 2.7 Emissions Summary Sources of man-made NOx for the 1999 base case EI comprise 58% on-road, 20% point, 17% non-road and 5% area. Table 2.7-1. Total daily (weekday) NOx emissions in 1999 from anthropogenic sources in the MSA
Sources of man-made VOC for the 1999 EI comprise 55% area, 30% on-road, 13% non-road and 2% point. Table 2.7-2. Total daily (weekday) VOC emissions in 1999 from anthropogenic sources in the MSA
Sources of man-made NOx for the 2007 base case EI comprise 48% on-road, 21% non-road, 23% point and 8% area. Table 2.7-3. Total daily (weekday) NOx emissions in 2007 from anthropogenic sources in MSA
Sources of man-made VOC for the 2007 base case EI comprise 64% area, 21% on-road, 12% non-road and 3% point. Table 2.7-4. Total daily (weekday) VOC emissions in 2007 from anthropogenic sources in the MSA
3.1 Introduction With near-nonattainment area funding from the Texas legislature, the Capital Area Planning Council (CAPCO) coordinated development of three photochemical model base cases, including a 1999 South and Central Texas high ozone episode. These provide a means of projecting air quality conditions to the year 2007 and test emission reduction measure efficacy in the anticipated attainment year. The year 2007 coincides with the expected attainment dates for Dallas-Fort Worth and Houston. Because ambient ozone levels in the MSA are affected by transport, selecting a date in which emission reduction strategies are in place for other large urban areas is an important modeling consideration. The meteorological model processes meteorological data for each day in the episode. The episode being modeled uses its own, day-specific, EI. The base case comprises the set of meteorological data and the episode’s EI. The photochemical model is run and evaluated. If model performance, as evaluated by comparing model prediction to observed air pollution concentrations, is not acceptable, the meteorological modeling results and the EI are evaluated to determine if these data can be refined. Once the model performance is acceptable, precursor sensitivity modeling can be performed. For future years, the base case emissions are replaced with emissions projections for the future year. The model is rerun with the future emissions to establish the future ozone patterns and to determine adequate emission reduction strategies.
3.2 Episode Selection The conceptual model allowed staff to identify candidate episodes for modeling. The MSA has identified and modeled two episodes, July 7-12, 1995 and September 13-20, 1999. In response to TCEQ and EPA guidance, the CAAP is based on the September 1999 episode. The September 13-20, 1999 modeling episode fulfills the requirements of both EPA draft guidance and the EAC Protocol. The episode is a good example of the predominant type of high ozone episode described in the conceptual model for the Austin area. The episode covers, for both Austin and San Antonio, one cycle for ozone with two initialization days and six high ozone days. The episode includes two weekend days (September 18th and 19th) so emission reduction strategies can be evaluated with different emission characteristics. An important consideration in selecting this episode was the high ozone concentrations observed throughout South and Central Texas. Thus, Austin, San Antonio, Corpus Christi, and Victoria, along with TCEQ, could combine resources to develop a new episode focusing specifically on conditions associated with high ozone in South and Central Texas.
3.3 1999 Meteorological Model Meteorological inputs to the September 1999 episode used the Fifth Generation Pennsylvania State University/National Center for Atmospheric Research Mesoscale Model (MM5). The final MM5 application for the September 13-20,1999, modeling episode, known as Run5g, was the culmination of individual simulations and sensitivity studies performed during 2001-2003. Both Austin and San Antonio use this model for their EAC work. Details may be found in Appendix 3-1.
3.4 1999 Modeling Emissions Inventory
3.5 1999 Base Case Development
3.6 1999 Photochemical Model Base Case and Performance Evaluation Performance for both 1-hour and 8-hour predicted ozone concentrations used the seven monitors in the San Antonio, Austin, San Marcos, and Fayette County networks. Because the monitoring network in Central Texas is not dense, analysts evaluated performance based on data from all stations rather than on monitors grouped by cities. Statistical evaluation of the 1-hour model performance uses the following metrics: unpaired peak accuracy, average paired peak accuracy, bias in peak timing, normalized bias and normalized error. EPA has performance criteria for the unpaired peak accuracy, normalized bias and normalized error statistics. The 1-hour modeling for the seven Central Texas monitors meets all of these criteria. The evaluation of model performance for 8-hour averaged ozone attainment demonstrations is being applied for the first time in many areas and could be subject to future modifications. In recognition of this, analysts used the following three different methodologies in selecting predicted ozone concentrations to compare to observed value:
2. The predicted daily maximum ozone concentration within grid cells ‘near’ a monitor that is closest in magnitude to the observed daily maximum at the monitor; and 3. A bilinear interpolation of predicted daily maximum ozone concentration around the monitor location. EPA recommends that the normalized bias and fractional bias be less than 20% of mean observed 8-hour daily maximum concentrations. Regardless of the approach used to select the predicted maximum concentration, both metrics for the Austin September 13-20 CAMx model fall well within these criteria. 3.7 Future Case Modeling Future Case modeling used projected 2007 emission inventories with the meteorological data and CAMx configuration developed for the successful Base Case. Inputs followed EPA’s Draft Guidance on the Use of Models and Other Analyses in Attainment Demonstrations for the 8-Hour Ozone NAAQS (1999) and their Protocol for Early Action Compacts (2003). Photochemical modeling is an iterative process. The emissions inventories used in the model are often refined to better predict emissions. The modeling for the future case has been performed with six versions of the 2007 emissions inventory, each with minor modifications or improvements. This modeling provides results that are close to the standard of 85 ppb, but in four cases the design value has been slightly below the standard (84.8 ppb, 84.5 ppb, 84.55 and 84.91 ppb) and in two cases the design value has been slightly above the standard (85.6 ppb and 85.08 ppb). It is likely that the 2007 emissions inventory for the Houston/Galveston area will be modified by TCEQ in the near future, which may affect future case model values. Results of future case modeling are too close to the standard to provide meaningful conclusions about the area’s likelihood of demonstrating attainment by 2007 without local emission reduction measures. 3.8 Calculation Methodology for Relative Reduction Factors and Future Design Values The EPA methodology calls for multiplying "current" year design values by relative reduction factors (RRF) from a photochemical model in order to estimate future design values. The calculation is carried out for each monitor site that measured ozone during the current year. In addition, a screening calculation identifies grid cells with consistently high ozone and estimates scaled design values for these screening cells. The screening cells account for any areas where modeled ozone is consistently high, but not captured by the monitoring network. The attainment test passes if all the future year scaled design values are less than 85 ppb (the results are truncated to the nearest integer). Additional information on the RRF is included in Appendix 3-2. Various sensitivity model runs were made using the 1999 base case. Sensitivity runs for the 2007 future case will be completed in February 2004. These include across-the-board precursor reductions to indicate the sensitivity to reductions of VOC, NOx and combinations of both. Also, zero-out modeling was performed using the 1999 base case. Zero-out runs using the 2007 future case will be completed in February 2004. Zero-out runs remove the anthropogenic emissions from certain source areas to evaluate transport from other areas and to establish the impact of local emissions. The "current" year is determined by comparing two design values; one for the years that straddle the year for which the latest emission inventory was developed (1999) and the other for the year for which attainment of the standard was determined (2002). The current year is the year that has the higher design value. A current year is determined for each monitor site. The current year for the EAC CAAP is 1999 as shown in Table 3.1 Table 3.1 Current Year for Austin EAC
(a.) Design value for 1998, 1999 and 2000 3.9 Base 2007 Model Results As of February 25, 2004, the results for the base 2007 EI for Austin are shown in Table 3.2. For the EAC CAAP the current year was 1999. Table 3.2 Model results for base 2007 modeling with the September 1999 Episode
· Truncate this number to the nearest integer to compare to the standard of 85 ppb. Any design value less than 85 ppb indicates attainment of the 8-hour ozone standard. 3.10 Emission Reduction Measure Modeling Results The modeling used various combinations of emission reduction measures or strategies. Each strategy was applied to the base 2007 EI; the resulting EI was modeled. Then the RRF for each control strategy at each monitor site was determined. It was multiplied by the appropriate current year design value to estimate the corresponding design value for 2007. The list of modeled emission reduction measures is in Table 3.3 (see Chapter 5 for a discussion of each measure), the summary of the measures is in Table 3.4 and the modeling results for each measure are shown in Table 3.5. Table 3.3 List of Modeled Emission Reduction Measures in MSA
Table 3.4 List of Emission Reduction Measures Modeled for Each Strategy
Table 3.5 Model Results for Emission Reduction Measures Applied to Base 2007 EI with the September 1999 Episode
The design values for the years that straddle 1999 were used as the "current" year to estimate the design value for 2007. These design values were the highest measured in the Austin area at both monitors. More recent monitoring provides lower design values and the latest design values for the years straddling 2002 do not exceed the standard. Since the worst-case design values were used in this CAAP, it is important to put these values into perspective. An analysis of historical trends of monitoring in the Austin area indicates that a design value of 89 ppb is the highest ever measured. Analysis of potential 8-hour ozone design values in Austin, based on historical monitoring data, indicated that the most likely 2003 design value (i.e., for the years 2002-2004) is 87 ppb. Analysis of the various metrics related to the meteorological conditions indicates that the conditions favorable to formation of high ozone occurred more often than normal during 1999 and less often than normal in 2001. The selection of the "current" year is based on the date of the most recent emissions inventory. If an emissions inventory were prepared for 2002, then the current year would be 2002, which has a maximum design value of 84 ppb.
4.1 Trends in Ozone Monitoring Data in Austin Since the EAC addresses 8-hour ozone concentrations, these analyses will be performed for 8-hour time periods. A number of analysis metrics can be used to evaluate trends in ozone concentrations. Among these are the highest concentration, the second highest concentration, the third highest concentration and the fourth highest concentration. At each monitor the annual 8-hour ozone design value is calculated over three consecutive years. It is the average of the fourth highest daily 8-hour ozone concentration measured over each of the three consecutive years. The area-wide design value is the highest of the design values for all of the monitors in the area. The average for the design value is truncated and if that value is greater than or equal to 85 ppb, the standard is exceeded.
4.2 Analysis of Potential 8-Hour Ozone Design Values for 2003 in Austin Based on Historical Monitoring Data Ozone formation is also correlated with emissions of ozone precursors. It is sensitive to the daily temporal and spatial variation of these emissions. It is not possible to predict the future daily emissions that may cause high ozone. In general, it is appropriate to assume that the average daily emissions for the next year will be similar to those of the previous year, but it is not possible to predict future daily emissions with much precision. Because it is difficult to predict ozone concentrations in future years based on monitored concentrations in past years, we cannot use trend analysis to predict the fourth highest concentration for 2004. However, we can assume that ozone concentrations for 2004 are likely to be similar to those measured in a previous year. In fact, we can ask the question, if 2004 were similar to each year during the 1997 through 2003 period, what would the 2003 design value be? Historical data collected at the Audubon and Murchison monitoring stations during the 1997 through 2003 monitoring period have been used to estimate the 2003 8-hour design value for the Austin area. This analysis assumes that 2004 is equally likely to be similar to any year between the 1997 through 2003 period. At Audubon the 2003 design value is likely to be below the 85 ppb standard and between 80 ppb and 87 ppb. Using the average of the fourth highest values, the design value for 2003 would be 82 ppb. In only one case of the seven cases would the design value exceed 83 ppb. Similarly, at Murchison the 2003 design value is likely to be above the 85 ppb standard and between 83 ppb and 88 ppb. Using the average of the fourth highest values between 1997 and 2003 the design value for 2003 would be 87 ppb. Five of the seven cases would have a design value of 85 or higher. However, the reader is cautioned that this is a rather simplistic analysis guided by the available historical ozone monitoring data. In 2004, the emissions, and/or the large-scale weather patterns that determine the frequency of occurrence of daily local meteorological conditions that favor high ozone concentrations, could be quite different from any previous year.
4.3 Meteorological Conditions for the 1999 Episode On page eight of EPAs "Frequently Asked Questions on Implementing the DRAFT 8-Hour Ozone Modeling Guidance to Support Attainment Demonstrations for Early Action Compact (EAC)" there is a reference to EPA’s "Recommended Approach for Performing Mid-course Review of SIP’s To Meet the 1-Hour NAAQS For Ozone." The referenced document provides guidance on approaches that can be used to evaluate the meteorological conditions that occurred in 2001, 2002 and 2003 compared to those that occurred in the past.
The following metrics that relate to 8-hour ozone measurements were recommended:
· highest daily concentration for each year, · second highest daily concentration for each year, · fourth highest daily concentration for each year and · design value for each three year period. The values for each of these metrics from 1997 to 2003 are shown in Table 4.1 Table 4.1. Values for Meteorological Monitoring Metrics in the Austin Area.
·All monitors The seven-year average for the annual high, second high and fourth high is about 3 ppb higher than the corresponding averages for 2001, 2002 and 2003. The average design value is 87 ppb compared to the 2002 design value of 84 ppb. It is clear from these data that the values for the above metrics for 2001, 2002 and 2003 are lower than normally observed over the period from 1997 to 2003. In 2001 the values for each of these metrics was the lowest during the period from 1997 to 2003, indicating that the meteorology or other conditions this year were not as conducive for ozone formation as for other years during the analysis period. Using a design value including data from the year 2001 may yield an estimated design value for 2007 that would be lower than normally observed in the area. To compensate for this difference in meteorology for 2001, all of these metrics indicate that the 2002 design value of 84 ppb should be increased to 87 ppb for an appropriate design value for estimating the design value for 2007. Furthermore, these data suggest that 1999 was a year when the meteorology was conducive to ozone formation more often than in any of the other years during the analysis period. Thus, it would follow that use of a design value using the data from 1999 would yield an estimated design value for 2007 that would be much higher than normally observed in the area.
4.4 Selection of Current Year for Estimating Future Year Design Values Based upon the EPA guidance and the data shown in figure 4.3, the current year is 1999 with design values at Audubon of 89 ppb and at Murchison of 87 ppb. If Austin were to prepare an emissions inventory for 2002, then the current year would be 2002 with design values at Audubon of 80 ppb and at Murchison of 84 ppb.
4.5 Transport Peak ozone concentrations for the Austin area from the Base Case with the interim 2007 projected emission inventory ranged from 88 ppb to 98 ppb for the 8-hour average. Peak zero-out concentrations ranged from 58 ppb to 72 ppb for the 8-hour average. Similar zero out modeling was performed with the September 13-20, 1999 episode with the 2007 emissions inventory used for the EAC. The peak 8-hour ozone values ranged from 77 ppb to 92 ppb. Peak zero-out concentrations ranged from 70 ppb to 85 ppb for the 8-hour average. Additional similar zero out modeling was performed using a much older 2007 emissions inventory. The episodes modeled were September 5-11, 1993, June 18-22, 1995 and June 30-July 4, 1996. Table 4.2 shows the number of days each area made a significant impact (difference of greater than or equal to 2 ppb) on the Austin area for each of these episodes. This indicates that there is a significant amount of transport from these areas into the Austin area. Table 4.2 Summary of Number of Days that Emissions from Other Areas are Transported into the Austin Area
Another analysis that can be performed with the zero-out modeling is to determine the maximum concentration before the zero-out, and the maximum concentration after the zero-out, of local emissions. This quantifies the difference in maximums that the local emissions make and also provides insight into the magnitude of the ozone in the area that is due to transport. A summary of these data for the September 13-20, 1999 episode is shown in Table 4.3 Table 4.3. Impact of zero-out of Austin anthropogenic emissions on the Austin Area.
5.1 Introduction
5.2 Federal Reduction Strategies Federal Area Source Measures:
Federal On-Road Measures:
Federal Non-Road Measures:
Federal Point Source Measures:
5.3 State and Regional Reduction Strategies State Area Source Measures:
HB2914 - Grandfathered Pipeline Facilities
State On-Road Source Measures:
· 30 TAC 115, Subchapter C, Division 2 Filling Of Gasoline Storage Vessels (Stage I) For Motor Vehicle Fuel Dispensing Facilities State Non-Road Source Measures:
5.4 Local Strategies
5.4.1 Introduction ¹ Per the Early Action Compact document, signed December 18, 2002, "All control measures will be incorporated by the state into the State Implementation Plan and submitted to the EPA for review and approval." Austin/Round Rock MSA Clean Air Action Plan (CAAP)
5.4.2 State Assisted Measures Chart 5.4.2 CAC Approved State Assisted Measures
The CAC approved these recommendations by vote on January 14, 2004. 5.4.2.A1 Inspection and Maintenance (I/M) Program Program Summary/Explanation NOTE: [This I/M program is designed for use in the MSA’s three urbanized counties (Hays, Travis and William-son). Implementation is contingent upon approval from the commissioners’ court of each county and from the city council of the largest city in each county. The commissioners’ courts in Hays, Travis and William-son Counties, in unanimous votes, have given preliminary approval; the city councils in Austin and Round Rock, in unanimous votes, have given preliminary approval. The City of San Marcos has voted (four to two, with one council member absent) to delete I/M from the draft list of recommended measures. The CAC has requested that the City of San Marcos commit to alternative measures for on-road emissions reductions. These measures would replace the reductions lost to Hays County because of the decision by the San Marcos City Council. The plan will be revised when the alternative measures are finalized. The following summary describes the program as originally intended.] The I/M program requires all subject gasoline vehicles 2 to 24 years old registered and primarily operated in the I/M program counties (Hays, Travis and William-son) to undergo an annual emissions inspection test in conjunction with the annual safety inspection. Emissions inspection tests are conducted at all safety inspection stations. The entire vehicle safety and emissions inspection should be completed in about 20 minutes from the time the vehicle is driven into the inspection bay. If a vehicle fails the emissions inspection test, the items of failure will be indicated on the Vehicle Inspection Report. The vehicle should be repaired and returned to the same inspection station with 15 days for a free re-test. A passing emission inspection test (or test waiver) is required in order to renew vehicle registration or to receive a safety inspection sticker. The program does not apply to motorcycles or slow moving vehicles, as defined by Section 547.001, Transportation Code. Test on resale is required for all vehicles from non-I/M program counties that are sold and registered in the I/M program counties. Per state statute, vehicles belonging to students at public universities, but registered in non- I/M program counties, must participate to receive campus parking privileges. The emissions test fee (set by TCEQ) is expected to be no more than $20 in Hays, Travis and William-son Counties. The safety inspection fee is $12.50, so the combined inspection cost is not expected to exceed $32.50. Testing equipment costs (estimated at $15,000 per station) are recouped through fee. The equipment includes the Two-Speed Idle (TSI), the On-Board Diagnostic (OBD) analyzer testing system, gas cap tester and 2-D Bar Code scanner. The OBDII testing program will be used to test 1996 model year and newer vehicles. All 1996 and newer vehicles less than 14,000 pounds (passenger cars, pickup trucks, sport utility vehicles) are equipped with OBD systems. The OBD system monitors emission performance components to ensure that the vehicle runs as cleanly as possible. The system also assists repair technicians in diagnosing and fixing emission-related problems. If a problem is detected, the OBD system illuminates a "Check Engine" or "Service Engine Soon" warning lamp on the vehicle instrument panel to alert the driver. The system will store information about the detected malfunction so that a repair technician can accurately find and fix the problem Model year 1996 and newer vehicles are required to meet EPA specifications for collection and transfer of emissions control data during each driving cycle. The Diagnostic Link Connector (DLC) cable on the emissions test analyzer is hooked up to the DLC located in the vehicle. When the vehicle’s OBD system has checked the emissions control systems and detected a problem with the vehicle, this information is stored in the vehicle’s on-board computer. The OBD test transmits this data to the analyzer and the vehicle will fail the inspection. The inspection report will indicate which emissions control systems were checked and display the description of the fault codes retrieved from the vehicle. The Two-Speed Idle testing program will be used to test 1995 model year and older vehicles. The TSI test uses a tailpipe probe exhaust gas analyzer to measure VOC and CO while the vehicle is idling at a low and a high rate. The I/M program includes a high emitter program to identify vehicles that are significantly exceeding federal vehicle emission standards. On-road remote sensing equipment will be used to identify high-emitting vehicles in the three I/M program counties or those commuting from contiguous counties. The van-installed on-road testing equipment is strategically placed to capture auto emissions from single-lane traffic in an acceleration mode. Vehicles identified as high emitters must be tested using the age-appropriate OBDII or TSI test within 30 days of notification and be repaired, if necessary. A passing test result (or test waiver) will be needed to renew vehicle registration. The following waivers and extensions will be available to all qualifying vehicle owners through the Texas Department of Public Safety (DPS):
Low Mileage Waiver - A Low Mileage Waiver may be issued to a vehicle owner whose vehicle has failed both its initial emissions inspection and the re-inspection, and in which at least $100 in emissions related repairs have been performed. The vehicle should have been driven less than 5,000 miles in the previous inspection cycle and anticipate being driven fewer than 5,000 miles before the next required safety inspection. Parts Availability Time Extension - A Parts Availability Extension may be issued for 30, 60 or 90 days to a vehicle owner whose vehicle fails the initial emission inspection and needs time to locate necessary vehicle emissions control parts. Low Income Time Extension- A Low Income Time Extension may be issued to a vehicle owner whose vehicle has failed its initial inspection and re-inspection, and the applicant’s adjusted gross income is at or below the federal poverty level. Counties that implement a vehicle emissions inspection program may elect to implement the Low Income Repair Assistance, Retrofit, and Accelerated Vehicle Retirement Program (LIRAP). Vehicle owners whose vehicles fail the emissions inspection and who meet eligibility requirements may receive assistance through this program. The assistance can pay for emissions related repairs or be used toward a replacement vehicle if they choose to retire the vehicle. The assistance program is funded through a portion of the emissions inspection fee. The program is administered through a grant contract between TCEQ and each participating county. Only 5% of the grant contract funds may be used for the administrative costs of the program. Assistance is limited to no more than $600 for repairs or $1,000 toward replacement of the vehicle. In order to be eligible for LIRAP, the vehicle owner’s total family income must be less than or equal to twice the amount of the Federal Poverty Guidelines for designated family units. (At this writing, $24,240 for a family of two and $36,800 for a family of four). A vehicle is eligible for repair assistance if it failed the emissions inspection within 30 days of application, is currently registered, and has been registered in the program area for the two years preceding application, and it passes the safety inspection portion of the test. Repairs must be performed at a DPS-recognized repair facility. Vehicle retirement eligibility requirements are the same as for vehicle repairs, except the vehicle must have passed a safety inspection within 15 months of the application. The I/M program will be applied in Travis, Hays and William-son Counties. NOTE: Periodic program evaluations will determine if any revisions or modifications are needed. If the I/M Program, as implemented, does not achieve the desired effects or is determined to be unnecessary, any participating jurisdiction can petition TCEQ to terminate the program.
Implementation Considerations
Program Participants
Expected Reductions
Additional Benefits 5.4.2.A2 Idling Restrictions on Heavy-Duty Diesel Engines
Program Summary/Explanation Exemptions are allowed for vehicles with a gross vehicle weight rating of 14,000 pounds or less; that are forced to remain motionless because of traffic conditions over which the operator has no control; are being used as an emergency or law enforcement vehicle; when the engine operation is providing power for a mechanical operation other than propulsion; when engine operation is providing power for multiple passenger heating or air conditioning; when the engine is being operated for maintenance or diagnostic purposes, or when the engine is being operated solely to defrost a windshield. Alternative methods of providing power to the vehicle are currently available. Truck stop electrification allows the vehicle operator to access electricity as a power source. Small generators, which emit less and are commercially available, can be used as auxiliary power sources.
Area of Application
Implementation Considerations
Program Participants
Expected Reductions
Additional Benefits 5.4.2.A3 Commute Emission Reduction Program Program Summary/Explanation The Commute Emission Reduction Program requires every existing or future employer, public or private sector, with 200 or more employees per location to submit a detailed plan to TCEQ or local designee that demonstrates how the employer will reduce the equivalent of their NOx and VOC commute related emissions by 10% within three years. Employers will set interim goals to ensure they reach the 10% goal within the time frame. Employers may choose to reduce commute or any other business related emissions that occur at the location with 200 or more employees as long as the aggregate emissions reductions are equivalent to 10% of their commute related emissions for both NOx and VOC. The plan will include details on how the commute related emissions were calculated, how and when the 10% total emissions reductions (in any combination of VOC and/or NOx) will be achieved, as well as how the reductions will be maintained over time. Alternative plans that detail how the employer will achieve and maintain a verifiable employee commuter average vehicle occupancy (AVO) of 1.2 will be accepted. Verifiable participation in the CLEAN AIR Force’s Clean Air Partners Program at a 10% reduction level will also be accepted. Commute related emissions may be calculated for locations with 200 or more employees using a baseline of the annual average number of employees at that location in 2003, 2004 or the expected annual average number of employees for a new employer location and assuming all employees drove to work alone. For Clean Air Partners, the emissions baseline for new participants is either the year they joined or a baseline that is defined by the Partners program. The annual average number of employees multiplied by the average round trip commute (22.6 miles) equals the number of employee miles traveled. Employee miles traveled multiplied by the MSA’s commute MOBILE6 emission factors for VOC and NOx equals the VOC and NOx commute emissions. The MOBILE6 emission factors may be for the analysis year, 2007 or any other year deemed appropriate by the TCEQ. The MSA average round trip commute mileage may be used or an employer may choose to use employee specific round trip commute mileage. A calculation guidance packet, including emission factors will be developed and made available to employers. All employers with 200 or more employees at a single location will register with TCEQ or local designee by December 31, 2004 or within 60 days of beginning operations for new locations. All plans must be submitted to TCEQ or local designee by March 31, 2005 or within 120 days of beginning operations for new locations. TCEQ or local designee will approve all plans, or inform the employer of any plan deficiencies by July 31, 2005 or within 4 months of plan submittal for new locations. In the event that plan deficiencies occur, employers will have 60 days from the date of notification of such deficiencies to revise and resubmit their plans. TCEQ or local designee will approve or reject the revised plan within 30 days from the date of re-submittal. Plans must be implemented no later than December 31, 2005 or within 1 year from the date of registration for new locations. Employers will report on the plan’s implementation and results semi-annually in conjunction with the MSA’s EAC semi-annual report. Reporting periods are May 1 through October 31 and November 1 through April 30. Copies of the Commute Emission Reduction Program report are due to TCEQ or local designee and CAPCO by November 30th and May 31st respectively. In the event that the semi-annual reports indicate that the planned emission reductions are not being achieved and maintained, TCEQ or local designee may request that the employer revise their plan accordingly. In the event TCEQ designates program responsibility to a local entity, the TCEQ and EPA will make every reasonable effort to provide adequate funding for program administration. Both the Clean Air Partners Program and the CAMPO Commute Solutions Program provide free tools and information that may be useful in complying with this measure. The Commute Solutions Program provides employee transportation coordinator training and Commute Solutions Fairs for alternatives to drive-alone commutes, while Clean Air Partners provides tools, expertise and experiences of member employers. Information on the Commute Solutions and Clean Air Partners programs can be found at Commute Solutions and Clean Air Partners.
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Program Participants
Expected Reductions
Additional Benefits 5.4.2.A4 Low Emission Gas Cans
Program Summary/Explanation
Area of Application
Implementation Considerations
Program Participants
Implementation Date
Expected Reductions
Additional Benefits 5.4.2.A5 Stage 1 Vapor Recovery Requirement Change
Program Summary/Explanation
Area of Application
Implementation Considerations
Program Participants
Expected Reductions
Additional Benefits 5.4.2.A6 Degreasing Controls
Program Summary/Explanation
Area of Application
Implementation Considerations
Program Participants
Expected Reductions
Additional Benefits 5.4.2.A7 Autobody Refinishing Controls
Program Summary/Explanation
Area of Application
Implementation Considerations
Program Participants
Expected Reductions
Additional Benefits 5.4.2.A8 Cut Back Asphalt
Program Summary/Explanation The use of conventional cutback asphalt containing VOC solvents for the paving of roadways, driveways, or parking lots is restricted to no more than 7.0% of the total annual volume averaged over a two-year period of asphalt used by or specified by any state, municipal, or county agency who uses or specifies the type of asphalt application. When asphalt emulsion is used or produced, the maximum VOC content shall not exceed 12% by weight or the following limitations, whichever is more stringent:
B. 3.0% by weight for chip seals when dusty or dirty aggregate is used; C. 8.0% by weight for mixing with open graded aggregate with less than 1.0% by weight of dust or clay-like materials adhering to the coarse aggregate fraction (1/4 inch in diameter or greater); and D. 12% by weight for mixing with dense graded aggregate when used to produce a mix designed to have 10% or less voids when fully compacted. Exceptions:
2. cutback asphalt used solely as a penetrating prime coat.
Area of Application
Implementation Considerations
Program Participants
Expected reductions
Additional Benefits 5.4.2.A9 Low Reid Vapor Gas
Program Summary/Explanation
Area of Application
Implementation Considerations
Program Participants
Expected Reductions
Additional Benefits 5.4.2.A10 BACT and Offsets for New or Modified Point Sources
Program Summary/Explanation
Area of Application
Implementation Considerations
Program Participants
Implementation Date
Expected Reductions
Additional Benefits 5.4.2.A11 Petroleum Dry Cleaning
Program Summary/Explanation
Area of Application
Implementation Considerations
Program Participants
Expected Reductions
Additional Benefits 5.4.2.A12 Texas Emission Reduction Program (TERP)
Program Summary/Explanation The primary purpose of the TERP is to replace, through voluntary incentive programs, the reductions in emissions of NOx that would have been achieved through mandatory measures that the Legislature directed the TCEQ to remove from the SIP for the Dallas/Fort Worth (DFW) and Houston/Galveston (HGA) ozone nonattainment areas. TERP funding is also expected to be available to help achieve reductions in counties located in the state’s other two nonattainment areas and in designated near-nonattainment areas, where air quality is approaching nonattainment levels. The TERP includes the following financial incentive and assistance programs intended to address the goals of the plan: The Emissions Reduction Incentive Grants Program is administered by the TCEQ. The program provides grants to eligible projects in "affected counties," as delineated in HB 1365, to offset the incremental cost associated with activities to reduce emissions of NOx from high-emitting mobile diesel sources. The types of projects that may be eligible for these grants include:
Replacement Re-power Retrofit or add-on of emission-reduction technology
Replacement Re-power Retrofit or add-on of emission-reduction technology
Replacement Re-power Retrofit or add-on of emission-reduction technology
Replacement Re-power Retrofit or add-on of emission-reduction technology
Replacement Re-power Retrofit or add-on of emission-reduction technology infrastructure Oil and Gas Compressors · Refueling Infrastructure (for qualifying fuel) · On-Vehicle Electrification and Idle Reduction Infrastructure · Use of Qualifying Fuel · Demonstration of New Technology The Heavy-Duty Motor Vehicle Purchase or Lease Incentive Program is a statewide program also administered by the TCEQ. Under this program, the TCEQ may reimburse a purchaser or lessee of a new on-road heavy-duty (over 10,000 lb) vehicle for incremental costs of purchasing or leasing the vehicle in lieu of a higher-emitting diesel-powered vehicle. The vehicle being purchased or leased must be EPA-certified to meet certain designated lower emissions standards for NOx. This program has yet to be implemented and available funds have been allocated to the Emissions Reduction Incentive Grants Program. The Light-Duty Motor Vehicle Purchase or Lease Incentive Program is similar to the Heavy-Duty Program, and provides incentives statewide for the purchase or lease of light-duty (less than 10,000 lb) motor vehicles that are certified by the EPA to meet a lower emissions standard for NOx. The incentive program will be administered by the Texas Comptroller of Public Accounts but is currently unfunded.
Area of Application
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Program Participants
Implementation Date
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Additional Benefits 5.4.2.A13 Power Plant Reductions
Program Summary Austin Energy -AE has committed to:
· Voluntarily offset the emissions from all other AE-owned non-SB-7 units by reducing emissions from the Holly and Decker units. This effectively includes these units into the 1500-ton emission cap. This cap would be in effect at least through the year 2012. · As new units are brought online, they will be included in this effective cap and their emissions will be offset by additional emission reductions from the Holly and Decker facilities. · AE will achieve this cap through a combination of installing NOx reduction technologies at the Holly and Decker facilities as well as the retirement of their older generating units. AE has committed to permanently shut down Holly Units 1 and 2 by 31 December 2004 and Holly Units 3 and 4 by 31 December 2007. · In order to comply with this effective cap, in addition to the emission rate reductions produced at the Holly and Decker facilities, additional emission reductions will be produced by the increased utilization of renewable energy resources as well as increased use of energy efficiency measures. Lower Colorado River Authority LCRA plans to contribute to the A/RR MSA Early Action Compact by taking the following voluntary actions:
· Commit to offset NOx emissions associated with any new fossil fuel facility sited in the five-county EAC region with equivalent NOx reductions in the same five counties. In addition, LCRA and Austin Energy, as partners in the Fayette Power Project (FPP), located in Fayette County agree to:
Although these facilities have not been identified as significant contributors to high ozone levels in the Austin Area, LCRA is taking the above voluntary actions in support of the Austin/Round Rock Early Action Compact and to further demonstrate our commitment to air quality protection. The University of Texas at Austin - UT will reduce the allowable annual NOx emissions from its grandfathered units by 75%.
· The University will meet these reduced emissions levels by limiting operating hours on certain equipment and by installing 10-year BACT controls on other equipment. Controls are proposed for Boiler #7 in 2004 and Boiler #3 in 2005. · The University will continue to operate its permitted unit (Gas turbine/boiler #8) as usual; this unit has average NOx emissions of 394 tons per year.
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Additional Benefits 5.4.3 Locally Implemented Emission Reduction Measures Locally Implemented EAC measures build on those in the O3 Flex Agreement. Appendix 5-1 (comprising the ERG Report and the CAPCO Emission Reduction Strategies Milestone Technical Report) contains quantification of these measures; more detailed descriptions appear in Appendix 5-2, or as referenced. (For a listing of the original O3 Flex commitments, see Appendices 5-2a and b.) Chart 5.1 lists each signatory’s commitments. Signatories interpret and implement these measures according to their needs and abilities. With the exception of the Transportation Emission Reduction Measures (TERMs), the CAAP neither quantifies these reductions nor includes them in its modeling. In addition to the self-selected measures, the region started Ultra Low Sulfur Gasoline in May 2004. It is used throughout the MSA. Chart 5.1 - Locally Implemented EAC and O3 Flex Emission Reduction Measures
Legend:
The geographic area of the Locally Implemented commitments is the area covered by the jurisdiction making the commitment. Estimated emission reductions from Locally Implemented measures are at least 1 tpd NOx and 1 tpd VOC. The CAAP includes modeled reductions from the TERMs only. 5.4.4 Transportation Emission Reduction Measures (TERMs) TERMs are transportation projects designed to reduce vehicle use, improve traffic flow or reduce congested conditions. A transportation project that adds single-occupancy vehicle (SOV) roadway capacity is not considered a TERM. General categories of TERMs include intersection improvements, traffic signal synchronization improvements, bicycle and pedestrian facilities, high-occupancy vehicle lanes, major traffic flow improvements, park and ride lots, intelligent transportation system (ITS) and transit projects. TERMs are similar to transportation control measures (TCMs), except that TCMs apply to nonattainment areas. TCMs are included in the SIP and subject to transportation conformity requirements. The A/RR MSA O3 Flex and EAC CAAP TERMs are not subject to nonattainment SIP or transportation conformity requirements. Various jurisdictions and implementing agencies committed to numerous TERMs in the MSA’s O3 Flex Agreement. Additional TERM commitments have been made for the EAC CAAP. A total of 467 TERM projects have been, or will be, implemented. The listed O3 Flex and EAC CAAP TERMs have various implementation dates. All TERMS will reduce emissions in 2007, while some will contribute to continued attainment past 2007. A project-specific list of O3 Flex, EAC CAAP and continued attainment TERMs is found in Appendix 5-3. The list provides locations, project limits, implementation dates, and emission reductions for all TERMs. A summary table of the O3 Flex and EAC CAAP TERMs, and the expected emission reductions, is below.
Area of Application
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Expected Reductions
Additional Benefits
5.4.5 Participating Organizations
· Clean Air Partners (Appendix 5-5) · Clean Cities (Appendix 5-6) · TxDOT (Austin District) · TxDOT (State) · TCEQ
5.4.6 Additional Considerations
· Adopt-a- School-Bus - Implemented under the auspices of the CLEAN AIR Force. In 2003, the CLEAN AIR Force of Central Texas brought the Adopt-A-School Bus Program to the Central Texas region. This program is an EPA initiative to partner with communities, businesses, educational leaders, and heath care professionals to reduce children’s exposure to diesel exhaust and to improve air quality in our communities. The program operates as a private/public nonprofit grant program-making funds available to local school districts to replace and retrofit their aging, diesel bus fleets with new cleaner technology buses and fuels. This program will also support anti-idling guidelines in school districts. The Adopt-A-School Bus Program grant opportunity is open to all school districts in the five county region of Travis, Hays, William-son, Caldwell and Bastrop. A projected replacement of 200 school buses over the course of three years could realize a reduction of approximately 80 tons/year of NOx. Another component of the Adopt-A-School Bus Program is a supplemental environmental project in which funds will be used to retrofit or replace aging school buses in Milam, Lee and Bastrop Counties. With these two programs combined, both PM and NOx emissions from older school buses will be reduced in our region. · Tree Planting Guide - This initiative involves specifying low VOC emitting trees in local lists of regionally appropriate plantings. A collection of initiatives compiled for further study appears in Appendix 5-7.
Staff has evaluated the anticipated future growth of the region to ensure that the area will remain in attainment of the 8-hour standard for the time period 2007 through 2012 and 2015. This evaluation included analysis of population growth and its effect on on-road mobile emissions and area sources, and new and planned new point sources. This chapter is a summary of the analysis.
Area Sources The population of the region has been growing for the past 60 years and is expected to continue to grow through 2012. Table 6.1 Population Growth (CAPCO Regional Forecast 2000 to 2030, REMI, 2003) As the population increases, so will the economic activity in the region. Though the economy of the region has slowed in recent years, the overall trend from 1999 through 2012 continues to show an increase. Table 6.2 Total manufacturing employment forecast (CAPCO Regional Forecast, REMI, 2003) With this increase in population and economic growth in the region, emissions from area sources are expected to increase only 14.2% from 1999 to 2012. Table 6.3 Area Source Emission Trends Break Down (Tons per Day), CAPCO
For more details, please see the report, Emissions Inventory Comparison and Trend Analysis for the Austin-Round Rock MSA: 1999, 2002, 2005, 2007, & 2012 in Appendix 6-1.
On-Road Mobile Sources VMT Screen: Because on-road mobile emissions account for a significant amount of the region’s ozone forming emissions, the region has focused much of its attention on growth in that area. It was, therefore, reasonable to perform a test to determine if the future planned transportation system will contribute increasing or decreasing amounts of NOx and VOC. One test that uses readily available data is a review of the relative change in VMT, also referred to as a VMT "screen". Staff has chosen to use the VMT screen that EPA originally developed for its proposed transitional ozone classification. The VMT screen tests if any expected increase in VMT in a future year will be offset by technology and control measures. That is, that the expected associated emissions in a future year will not exceed the associated emissions of the base year. The current CAMPO long-range transportation plan is based on VMT for the years 1997, 2007, 2015 and 2025. TxDOT supplied the1999 VMT. The "VMT Screen" for years 2007 and 2015 of the plan, Mobility 2025 (Appendix 6-3), gave the following results. Table 6.4 Emission Reductions in VMT from 1999 to 2015, with and without I/M
VMT in the three-county region is expected to increase 40% from 1999 to 2007 and 90% from 2007 to 2015. The associated NOx will decrease by so much during those years that it will be as though there were a 31.7% decrease in VMT from 1999 to 2007 and a 68.4% decrease from 1999 to 2015. Additional, though less substantial, decreases will be realized from the region’s implementation of an I/M program in Travis, William-son and Hays Counties in 2005 (35.2% and 74.8%). Also, VOC will be reduced by 29.6% from 1999 until 2007 and 48.2% from 1999 to 2015. Reductions of VOC will also be greater with the I/M program (38.4% and 58.8%). The expected increases in population and the planned expansion of the roadway system will contribute to an increase in VMT, but will not cause on-road emissions to exceed 1999 levels. Because Bastrop and Caldwell Counties are outside the CAMPO boundaries, and because they will not participate in the I/M program, a separate VMT screen was conducted for the aggregate 5-county region. The results are similar to those realized for the CAMPO area. Table 6.5 Emission Reductions in VMT from 1999 to 2015
VMT is expected to increase in the five-county region by 36% from 1999 to 2007 and 79.3% from 1999 to 2015. Without I/M in the five-county region, NOx from VMT is expected to decline by 33.3% from 1999 to 2007 and 69.9% from 1999 to 2015. The VOC will also decline (31.3% and 51.1%). Again, the expected increases in population and the planned roadway system that will contribute to an increase in VMT will not contribute to emissions exceeding the amount of 1999 on-road emissions. One conclusion from this analysis is that the currently planned roadway system will not exacerbate the production of ozone in the MSA through 2015. The details of all calculations are included in Appendix 6-2b. Emissions Comparisons: Another way to evaluate VMT and associated emissions is to compare the estimated emissions for future years to the base year emissions. Multiplying the emission factor by the VMT results in an estimate of the daily emissions associated with on-road travel. This evaluation shows a decrease in both NOx and VOC emissions, despite an increase in VMT. Emission factors for each year were calculated by CAMPO staff using MOBILE6 and included appropriate local data where available. Emissions factors are typically expressed in grams/mile. Multiplying the emissions factor times the VMT results in the grams of emissions, either NOx or VOC. Because the emissions inventory is expressed in tons per day, the resultant grams of on-road emissions were converted to tons by dividing the number of grams by 454 grams/lb and then by 2000 lbs/ton. Please refer to Appendix 6-2 a & b for more details. Table 6.6 Emission Reductions from 1999 to 2015
Both evaluation techniques, the VMT screen and comparison of emissions, show large enough decreases in on-road emissions to more than offset the anticipated growth in VMT through 2015. These decreases in emissions will be even greater once the I/M program is implemented.
Point Sources Table 6.4 Point Source Emissions from EGU, A/ RR MSA and Surrounding Area
A uniform change for 2002 and 2005 was assumed and 2012 is expected to stay unchanged based on feedback from power plant stakeholders. Table 6.5 Point Source Emissions from NEGU
Backup documentation for the above may be found in Appendix 6-4.
THE CONTINUING PLANNING PROCESSCAPCO and CAMPO staff will analyze air quality and related data and perform necessary modeling updates annually. In addition to the data sources used for the above analyses, staff may add information from The Central Texas Sustainability Indicators Project (CTSIP). The CTSIP is a nonprofit organization that tracks 40 key indicators (e.g., water pollution, air quality, density of new development) that show the economic, environmental and social health of our MSA. The results of all these analyses will be reported in the June semi-annual reports beginning in June 2005. Using similar methods as for the above maintenance for growth analysis, staff will evaluate:
2. all relevant actual new point sources; and 3. impacts from potential new source growth. Future Transportation Patterns: As part of the Mobility 2030 plan development process CAMPO staff will perform the VMT screen for years 2007 and 2017. The screen will test to be sure that any expected increase in VMT over the planning horizons will be offset by technology and control measures, that is, that the expected associated emissions will not exceed the associated emissions of the base year (1999). As part of this analysis, the emission factors will be reviewed and updated as necessary. Review of the emission factors includes checking and updating the fleet mix. This test will also be performed prior to adoption of any CAMPO long-range transportation plan update or amendment that significantly increases VMT. New Point Sources and Potential New Point Sources: In addition to the VMT screen and review of area sources, staff will include a list and impact analysis of the relevant new and potential new point sources. Staff will obtain data on these relevant new and potential new point sources from TCEQ. The annual analysis will determine the adequacy of the selected control measures. After review by the appropriate elected officials, these measures will be adjusted if necessary.
All signatories and implementing agencies will review EAC activities twice yearly. The semi-annual review will track and document, at a minimum, control strategy implementation and results, monitoring data and future plans. CAPCO, or its designee, will file reports with TCEQ and EPA by June 30 and December 31 of each reporting year. Reporting periods will be May 1 to October 31, and November 1 to April 30, to allow for adequate public notice and comment. CAPCO has primary responsibility for report generation. CAPCO will provide appropriately detailed technical analysis for all semi-annual review reporting. The metrics detailed in Appendix 7-1 provide an example, but their use is subject to staffing and funding constraints.
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