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Stop Sprawl
Bay Area Air Quality

The following is the text of a letter written to the EPA.  Following the text are specific proposals for cleaner air in the Bay Area.

The Sierra Club wants to thank the Environmental Protection Agency for its proposal, printed in the 19 December 1997 Federal Register, to redesignate the San Francisco Bay Area as non-attainment for ozone and for the 60 day public comment period.

The Sierra Club urges the EPA to complete redesignation to non-attainment due to the Bay Area’s repeated exceedence of federal health-based ozone standards. The region violated federal 1-hr ozone standards two days after being redesignated as attainment on 21 June 1995. In 1995 and 1996 the region violated federal standards 17 times. Each violation required exceeding the federal permissible ozone level four times at the same monitor within three years. The 1987 EPA-sponsored Santa Clara Valley Integrated Environmental Management Project estimated that even if the federal 1-hr ozone standards were met, ozone levels would still cause 500 to 3,600 asthma attacks annually in Santa Clara Valley alone, 99,000 cases of eye irritation, and 63,000 to 86,000 respiratory restricted activity days. Ozone levels in Alameda County exceed those in Santa Clara County.

The Bay Area Air Quality Management District will soon be developing a plan to further reduce emissions in order to meet the new 8-hr federal ozone standards. Any emissions reductions resulting from redesignation to non-attainment now should facilitate the region’s meeting the new 8-hr standards.

At nearly half of total emissions, motor vehicles are a major concern to the Sierra Club. Even with tighter emissions controls and enhanced Smog Check, the impacts of continued increase in vehicle miles traveled and congestion are troubling. Recent tunnel studies indicate that emissions from vehicles are at least 60% higher than predicted from tailpipe studies. These emissions may not be amenable to reductions from tailpipe controls. Increased VMT drives up energy consumption, increasing transport and refining of crude, and transport of gasoline and diesel fuel--all sources of pollutant emissions. These operations and increased VMT raise global climate change emissions. These impacts mandate adoption of Transportation Control Measures to reduce driving. Even TCMs for which we can only calculate modest emissions reductions within 2 to 5 years could yield much needed and much larger reductions in the longer term.

The Sierra Club remains concerned about the transport of Bay Area emissions, especially NOx, to non-attainment downwind areas like the San Joaquin Valley. We urge the EPA not to relax implementation of NOx controls.

We have attached a list of emissions control measures that should give the emissions reductions adequate to meet federal standards. These measures include adoption into the federal State Implementation Plan the measures in the state Clean Air Plan. Since the District adopted the state CAP in December 1997, there can be no question of the feasibility of implementation. We include proposals to increase the effectiveness of some of the CAP measures. Redesignation of the region to non-attainment will assist in assembling the political will to implement these proposals.

The Sierra Club has not necessarily endorsed each one of these measures.

Warmest personal regards,

 

 

Dr. John Holtzclaw

 

Table 1. Actions To Achieve Federal 1-hour Ozone Standards

Action

Pollutant Reductions

Jurisdiction

1. Smog Check II covering all cars 1966 and newer. 12 tons/day ROG

15 tons/day NOx (BAAQMD 98).

Legislature, BAAQMD
2. Adopt and implement the Bay Area ‘97 Clean Air Plan and Triennial Assessment into the State Implementation Plan, with the following modifications:

 

B5 (b) Tighten tanker off-loading procedures.

C6 (d) Eliminate upstream leakage and enclose waste water ponds to prevent evaporation.

C7 (c) Decrease flared gas, install improved flares and better monitor flares.

D5 (c) Require cement plant kilns to burn natural gas rather than old tires.

TCM #3. Add: City transit-first policies, with bus shelters and bulbs (bus stop sidewalk extensions the width of the parking lane so buses don’t have to pull into the driving lane after passenger boarding), real-time bus arrival information, and traffic signal overrides.

TCM #4. Add SF Int'l Airport "people mover" to joint CalTrain-BART station within 1 mile of air terminals and include in regional rail agreement; eliminate BART extension past SFIA to Millbrae; extend East Bay light rail across the Bay Bridge to the Transbay Terminal.

TCM #7. Add: Ferry service from SF to Berkeley and Martinez.

 

The Plan claims its measures add to:
51 tons/day ROG
17 tons/day NOX
But some measures may already be in fed. SIP (St Impl Plan)

Unknown additional reduction in emissions.

Unknown additional reduction in emissions.


Unknown additional reduction in emissions.


Unknown additional reduction in emissions.


Unknown additional reduction in emissions.

 


Unknown additional reduction in emissions.

 

 

Unknown additional reduction in emissions.

 

BAAQMD, MTC, legislature, Caltrans, cities, counties, CMAs, transit operators
2. Clean Air Plan modifications (continued):

TCM #8. Eliminate construction of new HOV lanes where not definitely demonstrated, with analysis of lanes and induced land use changes, that the change does not’t increase vehicle miles traveled; and can guarantee that these lanes can’t be changed to mixed-flow. This prohibition does not cover conversion of existing mixed-flow lanes to HOV and construction of guaranteed bus-only lanes.

TCM #9. Add: Bike rental/repair/parking at transit stations; financial incentives to encourage walking and biking rather than driving to stations; loaner bikes to monthly ticket holders. Shift highway safety funds to pedestrian and bicycle safety; test drivers on driving safely with bicycles and pedestrians. Change the vehicle code to allow pedestrians and bicyclists to treat stop signs and red lights as *yield* signs. Awards for employees who walk or use bikes.

TCM #12. Change bullet 3 to "Continue and expand local signal timing programs to slow through vehicular traffic and improve walking and bicycling conditions."

 

TCM #13. Add guaranteed ride home.

TCM #15. Add: Sliding scale development fees, lower for projects located in location efficient areas or providing better pedestrian, bicycle or transit facilities; with the revenues used for public transit, pedestrian and bicycle projects.

TCM #17. Add: Clean fueled (e.g. compressed natural gas, hybrid or fuel cell) public transit buses, cabs, delivery vans and trucks. EV charging stations or rebates to purchasers of EVS.

 

 

 

 

 

 

Unknown additional reduction in emissions since emission-reducing projects are retained.

 

 


Unknown increase in reductions, but increased bicycling will reduce emissions.

 

 

 


Unknown increase in reductions since slower through traffic will encourage modal shifts, which with increased walking and bicycling will reduce emissions.


Unknown additional reduction in emissions.

Harvey predicted a 1.7% reduction in VMT (3.6 tons/day ROG, 5.0 tons/day NOX) from doubled transit service.



Each CNG bus replacing a new diesel removes the equivalent of 17 to 33 cars (Hwang). Every EV that replaces a gasoline-powered car in the SF Bay Area reduces reactive organic hydrocarbon emissions by 89 - 119 kg over the lifetime of the car and NOX emissions by 109 - 120 kg (Hwang).

 

BAAQMD, MTC, legislature, Caltrans, cities, counties, CMAs, transit operators

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2. Clean Air Plan modifications (continued):

TCM #18. Mandate Parking Cash-Out for employees. Parking Benefit Districts, wherein residents get stickered on-street parking with non-residents charged more, with the revenues used for neighborhood-approved projects, can defray opposition to parking spill-over onto streets.

 

 

 

 

TCM #18. Mandate Full-cost parking charges at commercial centers TCM #18. (downtowns, shopping centers, strip malls, etc.), with the revenues used to improve transit service, provide transit passes to the low income, and provide secure bicycle parking. Price the parking fees to account for all public and social costs.

 

 

TCM #18. Add: BART parking charges of $3/day; using the funds to reduce fares and improve rail and feeder bus service. Parking Benefit Districts can mitigate spill-over impacts.

TCM #18. Add: Work-Near-Home Trust Fund. Employer contributes to a local trust fund, which distributes funds to people who reside within the walking distance. The money is for rents or mortgages. The employer gets to reduce parking.

 

 

MTC very conservatively evaluated PCO for employees at $3/day; the higher actual parking rates at most locations could increase PCO’s effectiveness. For comparison, studies in the San Francisco area (Harvey) and LA (Cameron) predict that a $3/day employee parking charge alone would reduce regional VMT 1.5% (3.2 tons/day ROG, 4.4 tons/day NOX)*. Studies in DC (Replogle) and NY (Tri-State) predict that PCO would decrease regional VMT 3.0% and 1.9%, respectively. EPA predicts that a $3/day employee parking charge would reduce ROG 2.3% (4.9 tons/day) and NOX 2.2% (6.5 tons/day). EPA is working on guidance for SIP credit for parking cash out.

Harvey predicted a 4.9% reduction in regional VMT (10.3 tons/day ROG, 14.5 tons/day NOX) from a 1 c/min charge for non-work parking, and a 1.7% reduction in VMT (3.6 tons/day ROG, 5.0 tons/day NOX) from doubled transit service. The magnitude of transit service improvements from these revenues should be evaluated to estimate the impacts on VMT. Impacts of driving costs and transit improvements may be additive, or more if symbiotic.



Unknown additional reduction in emissions.

 


Unknown additional reduction in emissions.

 

 

 

 

 

MTC can limit transportation funding to cities and counties which implement PCO; CMAs can mandate PCO and reduce parking spaces employers are required to provide.

 

Cities, subject to MTC pressure.

 

 

 

 

 

 

BART, but MTC can limit funds to them to get compliance.

2. Clean Air Plan modifications (continued):

TCM #18. Add: Increase all bridge tolls to average at least $3, free for HOVs with 3+ persons and congestion priced; with the revenues used to improve transit service and give equal "rebates" to all low income adults making trans-bay trips by auto, foot, bicycle or transit.

 

 

 

 

TCM #18. Add: Airports: charge $3 for auto drive-throughs; tax airport parking with the revenues used for high speed rail and CalTrain; replace diesel baggage and maintenance vehicles with electric; and congestion price landing fees.

TCM #18. Add: Regional gas tax or sales tax on gasoline sufficient to eliminate subsidies to motor vehicle use; and pay-at-the-pump auto insurance. Use gas tax revenues to improve transit service, give equal "transportation rebates" to all low income adults independent of their auto use, provide youth transit passes, and provide secure bicycle parking.

 

 


TCM #18. Add: Publicly available analyses of the full costs of all transportation projects (including health and environmental costs, free parking and other subsidies), and who pays these costs.

 

Harvey predicted a 2.4% reduction in regional VMT (5.1 tons/day ROG, 7.1 tons/day NOX) from a $3(?) toll, and a 1.7% reduction in VMT (3.6 tons/day ROG, 5.0 tons/day NOX) from doubled transit service. The magnitude of transit service improvements from these revenues should be evaluated to estimate the impacts on VMT. Impacts of driving costs and transit improvements may be additive, or more if symbiotic. EPA has just published guidance on transportation pricing and another is due out soon.

 


Unknown additional reduction in emissions.

 


Harvey predicted a 4.5% reduction in regional VMT (9.5 tons/day ROG, 13.3 tons/day NOX) from a $1/gal gas tax, so a 10 c/gal tax might reduce VMT by 0.45%, and a 1.7% reduction in VMT (3.6 tons/day ROG, 5.0 tons/day NOX) from doubled transit service. EPA predicted 7.1% decrease in ROG (15.0 tons/day) and 6.9% decrease in NOX (20.3 tons/day) from $2 additional gas tax. The magnitude of transit service improvements from these revenues should be evaluated to estimate the impacts on VMT. Impacts of driving costs and transit improvements may be additive, or more if symbiotic.

None by itself, but would help to defray opposition to proposals that would increase the cost of driving.

MTC; state enabling legislation required.

 

 

 

 

 

FAA; state legislation may be required.

 

MTC, with county votes can enact 10 c/gal tax now. State legislation needed for higher tax increases.

3. Eliminate highway construction and redirect the funds into cost-effective transportation projects. The RAFT 1994 RTP alternative evaluated by MTC included this along with employee PCO and cost-effective land use (urban limit lines; low-rise walkups to high-rises, with ground-level shopping and incentives for mixed-use development, at transit centers). MTC calculated that, compared to their RTP, the RAFT alternative would accomplish:

6% reduction in VMT; 13% in congestion

19 tons/day CO

1.8 tons/day ROG

2.8 tons/day NOX

3.3 tons/day PM10

However, based upon the BAAQMD’s estimate of 1997 emissions from on road motor vehicles,* these might be:

12.7 tons/day ROG

17.7 tons/day NOX

And recent studies suggest that auto emissions of ROG are 60% higher than those assumed in MTC’s analysis, so reductions in emissions would be another 60% higher.

* Reduction calculation based upon 1997 emissions from on road motor vehicles of 211 tons/day ROG and 295 tons/day NOX (BAAQMD 97).

MTC; additional operating funds needed (see 2); federal ISTEA changes may be needed. On land use: Cities and counties, but MTC can limit transportation funding to those implementing these policies.
4. Electrify freight railroads . Unknown additional reduction in emissions. ICC, BAAQMD funding.
5. Refineries and chemical plants:

(a) Ban venting of pressure relief valves to the atmosphere.

(b) Improve tank roof design, require vapor recovery, improve fittings and control tank cleaning emissions.

(c) Adopt most stringent standards identified by SCAQMD to reduce boiler emissions of Nox

(d) Eliminate exemption of "non-repairable" valves, flanges, pumps and compressors.

Refer to Communities for a Better Environment comments. BAAQMD.
6. Control emissions from small stationary energy sources like natural gas fired boilers, i.c. and diesel engines. Unknown additional reduction in emissions. BAAQMD
Notes:

ABAG = Association of Bay Area Governments

BAAQMD = Bay Area Air Quality Management District

BART = Bay Area Rapid Transit District

CARB = California Air Resources Board

CNG = compressed natural gas

EPA = U.S. Environmental Protection Agency

EV = electric vehicle

MTC = Metropolitan Transportation Commission

NOX = nitrogen oxides

PCO = Parking cash-out

PM10 = Particulates

RAFT = Regional Alliance For Transit

ROG = reactive organic gases

RTP = MTC’s Regional Transportation Plan

TOG = total organic gases

VMT = vehicle miles traveled

References:

BAAQMD 97, Bay Area 97 Clean Air Plan, Sept, 1997.

BAAQMD 98, "Policy Issue Paper," attached to agenda for BAAQMD Legislative Committee meeting of 7 January 1998, augmented by Ellen Garvey, APCO.

Michael Cameron, Transportation Efficiency: Tackling Southern California's Air Pollution and Congestion, Environmental Defense Fund, Oakland CA, 1991, Table 3.

CARB, Transportation Pricing Strategies for California: An Assessment of Congestion, Emissions, Energy, and Equity Impacts, 1996.

Greig Harvey, TCM Task Force, Metropolitan Transportation Commission, Oakland CA 1989.

R Hwang, et al, "Driving Out Pollution," Union of Concerned Scientists, 1997.

EPA, Opportunities to Improve Air Quality through Transportation Pricing Programs, 1997.

Michael Replogle, Transportation Management Strategies For the Washington DC Region, Environmental Defense Fund, Washington DC, August 1993, p 7 (year 2000).

Tri-State Transportation Campaign, Citizens Action Plan, A 21st Century Transportation System, New York City, April 1994, p 66 (year 2007).


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