CleanAirStrat Handout

Public Review of Clean Air Strategies
San Antonio region recorded violations the 8-hour ozone NAAQS during 2002-2004. During 2004, the
fourth highest value at CAMS 23 was 85 ppb and the fourth highest value at CAMS 58 was 89. The
average of the fourth-highest values 2002-2004 at each monitor is 91.7 ppb at CAMS 23 and 89.7 ppb at
CAMS 58. The Clean Air Plan states:
• If exceedances of the 1-hour average ozone NAAQS or exceedances and violations of the 8-hour
ozone NAAQS are recorded on local air quality monitors, further voluntary control strategies will be
considered by the AIR Committee, the TCEQ, and the EPA as they may result from the ongoing
public involvement process.
• After the date of finalization of the local SIP revisions, newly monitored exceedances and violations
will result in a public review of the control strategies in the SIP and a fresh call for implementation of
further and more effective voluntary control strategies from business, industries, local agencies and
citizens. This review is an important part of the public involvement process.
• Such an event-responsive review process clearly complements and gives fresh impetus to the public
involvement goals in the EAC. Such a review process allows local air quality planners the opportunity
not just to offer the public a strategy review and progress report, but to ask the public for a renewal of
their involvement in and commitment to the ongoing planning process in the context of new
exceedances of the air quality standards. Such a review process allows local businesses, industry
and other agencies further opportunity to implement fresh voluntary emission reduction methods.
• By responding to future exceedances and violations with a public review of control strategies and
their purpose, local elected officials, air quality planners, and the citizens themselves remain
committed to ongoing local air quality planning needs. Since new exceedances and violations are
grounds for a review of the plan, we give assurances to the reader of our common vigilance, in which
public participation is required.
The Air Improvement Resources Committee of the Alamo Area Council of Governments (AACOG) is the
local entity charged with oversight and coordination of the development of the Clean Air Plan for the San
Antonio Metropolitan Statistical Area. The Clean Air Plan is the San Antonio region’s local version of the
Early Action Compact. The elected officials in the AIR Executive Committee, the Chairman of the Texas
Commission on Environmental Quality, and the Administrator for Region 6 of the US Environmental
Protection Agency signed the Clean Air Plan for the San Antonio Metropolitan Statistical Area on
December 9, 2002.
It must be noted that this is a draft list, and does not represent a final list of clean air strategies. Other
strategies may be added to this list, as warranted and as technology provides new solutions. As the EAC
reporting requirement notes, this list provides a description of potential local Clean Air Strategies.
DRAFT
Creditable and Enforceable Clean Air Strategies
Significant Rule Currently
4-County Cost
On-Road Clean Air Strategies Cost Estimate Emission Available in
Emission Reduction Texas Efficient1
Reduction
Cost would be
None, but "X" pounds of NOx
1) Shift delivery operations of retail fleets to off minimal, but might
are shifted to a different time of
peak hours have a significant
the day.
impact on businesses
2) Commuter Trip Program
Cost would be
Would have to be a voluntary program (employers
> 200)?
Same as TDM programs
minimal X
618.1 lbs/d NOx2
(100% Reduction) $500/ton NOx2 to
3) Truck Stop Electrification to limit/restrict HDDV
idling (overnight idling of diesel trucks)
1.64 lbs/d/truck space Knoxville
EAC³
$1,660/ton NOx
Knoxville³
X
4,200 lbs/d Los Angeles³
4) Gasoline Sulfur reductions
Max level of 30 ppm, average level of 15 ppm 1,300 lbs/d NOx $31,873/ton
(May not be able to implement in this region – falls 460 lbs/d VOC (VOC & NOx) X X
under the same classification as lower RVP)
Cost per ton
5) Require alternative fuels for public fleets (some
Per 5,000 Vehicles (10 year program
funding available though SB5)
implementation)
Convert: $28-42K/
a) Liquefied Petroleum Gas (LPG) Trucks: 195.3 lbs/d VOC ton VOC
Applicability: Class 7 & 8 Trucks (Four or more No NOx reduction3 New: $4-14K/ton
axle single unit trucks; or four or less axle Buses: 50% reduced VOC & 13 VOC5
single trailer trucks); new buses lbs/d NOx4 New Buses: $19-40K/
ton NOx³
1
Any program that cost less then $13,000 max per ton. This value is based on the initial TERP funding limits.
2
Alamo Area Council of Governments, MOBILE6 analysis of a fleet of 10,000 HDDV
3
Alamo Area Council of Governments, Fuel analysis based on 5,000 vehicles, September 2002.
4
Tennessee EAC potential emission reductions (prepared by UT; 4/14/03). Draft report available online 10/15/04:
http://www.state.tn.us/environment/apc/eac/pdf/DrRpt041303.pdf
5
Alamo Area Council of Governments, Alternative fuels cost per ton conversion with 10 year program implementation, May 2003
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DRAFT
4-County Cost
On-Road Clean Air Strategies Cost Estimate Emission Available in
Emission Reduction Texas Efficient6
Reduction
New Buses: $19-
b) Compressed Natural Gas (CNG) New Buses: 50% reduced VOC 40K³/ton NOx
Applicability: New Buses, School buses, & 13 lbs/d NOx³ Convert: $16-19K/ton
medium duty diesel vehicles (i.e. Delivery Other: 372.3 lbs/d VOC (VOC & NOx)
services: USPS, FedEx, UPS, etc) 54.74 lbs/d NOx3 New: $13K/ ton (VOC
& NOx)5
Convert: $22K-28K/
c) Electric
280.9 lbs/d VOC ton VOC & NOx
Applicability: Non-highway, neighborhood
213.7 lbs/d NOx3 New: $10-40K/ton
vehicles < 35 mph
(VOC & NOx)5
Convert: $20-35K/
d) Ethanol
111.8 lbs/d VOC ton VOC & NOx
Applicability: OEM passenger vehicles (i.e.
130.5 lbs/d NOx3 New: $10-25K/ton
Cars and vans)
(VOC & NOx)5
e) Biodiesel - a renewable fuel for diesel
engines derived from natural oils like soybean
101.1 lbs/d VOC Retrofit: Little to none
oil
(11.0) lbs/d NOx7 (engines '94 and up) 8
Applicability: On-road diesel engines, some off-
road potential
Urban: 2.08 lbs/d NOx
f) Liquefied Natural Gas (LNG) – viable for Line Haul: 4.55 lbs/d NOx
only heavy duty diesel vehicles
Applicability: Class 7 & 8 Trucks Based on 40,000 (urban) &
120,000 (line haul) annual mi9
6) Vehicle Inspection/Maintenance Program - Reductions given for 2007, 4-County EAC Region
a) Tie tests in with license plate renewal to

Included with I/M program —
promote properly running vehicles
b) Deny registration to vehicles with repeated
emission test failures
6
7
Alamo Area Council of Governments, Fuel analysis based on 5,000 vehicles, September 2002.
8
Alamo Area Council of Governments, Alternative fuels cost per ton conversion with 10 year program implementation, May 2003
9
Weaver, Christopher S. P.E., Chan, Lit-Mian, Air Pollution Impacts and Revenue Implications of LNG Taxation. Final Report. Engine, Fuel, and Emissions
Engineering Inc. May 17, 1996
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Significant Rule Currently Cost
4-County
On-Road Clean Air Strategies Cost Estimate Emission Available in Efficient
Emission Reduction Texas 10
Reduction
8,760 lbs/d NOx $8,419/ton
c) On Board Diagnostics (OBDII)
8,300 lbs/d VOC 11 (NOx + VOC) 12 X X
d) Acceleration Simulation Mode (ASM) test 12,880 lbs/d NOx $10,620/ton
with OBD II 13,780 lbs/d VOC 13 (VOC & NOx) 14 X X X
8,900 lbs/d NOx $9,425/ton
e) Two Speed Idle with OBD II
11,940 lbs/d VOC 15 (VOC & NOx)16 X X X
f) Inspection/Maintenance at wholesale and
retail car lots. All cars have to pass vehicle
inspection before they are sold.
unknown unknown ? X
g) Maintenance / tune up programs for fleets 62 lbs/d NOx
and/or personal vehicles, and/or joint 58 lbs/d VOC $43,700/ton
recycling programs which include regionally- (Based on 1% participation (VOC & NOx)18
coordinated emissions testing fleet-wide)17
h) Vehicle recycling program with emissions
testing
i) Repair assistance Included with I/M program —
7) Remote Sensing / Detection
Involves surveillance and detection of high 28 lbs/d NOx $15,500/ton
emitters. These vehicles are then required to 1,114 lbs/d VOC19 (VOC & NOx)20
undergo inspection and repairs.
10
11
Alamo Area Council of Governments, Technical Report UPWP 3.8, October 2003
12
13
14
15
16
17
Alamo Area Council of Governments, Emissions Estimates derived from Sacramento strategies, August 2003
18
Sacramento Metropolitan Air Quality Management District, Clean Air Plan Update Potential Control Measure Overview. Online at:
http://www.airquality.org/cleanairplan/ws0306/ws0306Oview.shtml
19
Alamo Area Council of Governments, Emissions Estimates derived from Sacramento strategies, August 2003
20
Sacramento Metropolitan Air Quality Management District, Clean Air Plan Update Potential Control Measure Overview. Online at:
http://www.airquality.org/cleanairplan/ws0306/ws0306Oview.shtml
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4-County
Reduction
8) Smoking Vehicle Photo Radar –
Use Remote Sensors and license plate photos to
13 lbs/d VOC $324,633/ton VOC
identify smoking vehicles. Owners are sent letters
urging them to take their vehicles in for repairs.
9) Heavy Duty Diesel Vehicle (HDDV) inspections
Unknown – New
- Utilizes the "snap acceleration" or "free
acceleration" test for smoke measurement
Unknown – New technology
technology ?
10) Traffic Flow – Traffic Signals
a) Progressively timed traffic signals Depends on the project —
b) Adaptive traffic signals and signal timing Depends on the project —

c) Improved signal coordination (not just
Depends on the project —
improved intersection timing)
11) Grade separation Depends on the project —
12) Heavy-duty diesels limited-lanes restrict

May only be minimal
heavy-duty diesels from driving in certain Unknown: depends on the
costs for signs, but
areas/and or times. This would reduce people’s
exposure to toxic diesel fumes and reduce
restrictions. Reductions may be
minimal?
could impact ?
businesses
congestion.
13) Roadway bottleneck improvements (add
lanes, construct shoulders, etc)
14) Improve traffic flow through metered
entrances where entering main roads (i.e. Smart Depends on the project —
Roads) and ramp closures
21
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4-County
Reduction
$19,000/ton NOx
400 lbs/d NOx $13,000/ton VOC
15) Build High Occupancy Vehicle lanes (HOVs)
580 lbs/d VOC23 Road Cost: ?
$1,000,000/mile19
16) Access management (manage access into
new commercial developments)
17) Parking incentives for alt Fuel or Low
Small reduction in
Emissions Vehicles (Tier2 Bin 3 or cleaner
operating vehicles): park for free at meters or
Minimal reductions meter revenue; cost
of parking spaces
X
have designated parking spaces.
0.08 lbs/d NOx &
18) Parking Management with preference to $3,500/ton NOx
car/vanpool vehicles
0.11 lbs/d VOC
per car/vanpool space24
$2,500/ton VOC25 X
90 lbs/d NOx
19) Area-wide rideshare incentives 138 lbs/d VOC $16-158,000/ton NOx
per 1% reduction in VMT26
36 lbs/d NOx (Philadelphia) $46,500
20) Bike trails and bike racks at work sites
0.02 lbs/d per bike (Knoxville)27 (Philadelphia)28
22
23
Tennessee EAC potential emission reductions (prepared by UT; 4/14/03). Draft report available online
10/15/04:://www.state.tn.us/environment/apc/eac/pdf/DrRpt041303.pdf
24
25
26
Alamo Area Council of Governments, 2007 Emissions Inventory for the Alamo Area Council of Governments Region, September 2003.
27
28
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DRAFT
4-County
Reduction
Emission Reduction for
Minimal cost, but
Changing school year is 2,381
might be difficult for
21) Change school hours and/or school year days lbs/d NOx (for each day the
school year starts later)
schools to switch X X
school times
158 lbs/d VOC30
22) Buy and retire “junk” vehicles.
a) Require government fleets to retire vehicles. — —

b) Do what is necessary to allow cities to remove
the engines of abandoned high emitting
— —
vehicles (pre-1980) that are to be auctioned,
to include impounded or seized vehicles.
Cost
Area Strategies Emission Reduction Cost Estimate Emission Available in
Texas Efficient
Reduction
23) Adhesives and Sealants – Require control
measures equal to that of the South Coast AQMD
Rule 1168. Estimation based on additional 30%
reduction in emissions.31 Household adhesives
283 lbs/d VOC32
are included in the national consumer products
rule (12/10/98 compliance date; applies to
(30% reduction)
$1,500/ton VOC33 X
manufacturers), which achieved a 20% reduction
in VOC emissions. Rule 1168 applies to the end
user, which will be very difficult to enforce.
29
30
Texas Transportation Institute, San Antonio Metropolitan Statistical Area On-Road Mobile Source Modeling Emissions Inventories: 1999, 2007, and 2012, June 2003
- Bexar County Weekday emissions for HDSB (Heavy Duty Diesel School Buses) in 2007. The estimate is used currently in the 1999 photochemical model projection
31
Rule 1168: Adhesive and Sealant Applications, Available online at: http://www.aqmd.gov/rules/reg/reg11/r1168.pdf
32
33
Monterey Bay Unified Air Pollution Control District, “6.0 Control measures California. Online at: http://www.mbuapcd.org/index.cfm?Doc=292
Page 6 of 17 11/09/04
DRAFT
Cost
Texas Efficient
Reduction
24) Autobody Refinishing/Coatings Controls – A
federal rule requiring a 37% reduction in VOC
emissions has already been assumed. This
measure involves the adoption of a state rule for
non-attainment areas, which would further reduce
emission by 8%. The majority are under a permit
by rule (PBR), which includes the same coating
$2,500 to
VOC limits, transfer efficiency requirements, and
spray gun cleanup requirements as the Chapter
Less then 49 lbs/d VOC34
$12,500/ton35 X X
115 rules. Therefore, reductions would be limited
to the body shops that are not under PBR and
even then would be further limited by the fact that
the high-transfer efficiency HVLP spray guns have
become standard equipment in the industry since
the PBR was adopted in 1994.
25) RACT (Reasonably Available Control Most of the controls are listed in
Technology) Requirements for Area Sources other sections
26) Asphalt Roofing – also would produce less complaints from public because of reduce asphalt smell
a) Require asphalt kettles to have close fitting

Less than
lids that limit the temperature at which such
kettles may operate. (25% reduction)
48 lbs/d VOC36
$500/ton VOC37 X
b) Require afterburners on all kettles, virtually
193 lbs/d VOC38
eliminating VOC emissions. See
http://www.corporateroofing.com/News.html
Nearly 100% reduction
$5,500/ton VOC39 X
34
35
36
37
Sacramento Metropolitan Air Quality Management District, Clean Air Plan Update
38
39
Sacramento Metropolitan Air Quality Management District, Clean Air Plan Update
Page 7 of 17 11/09/04
DRAFT
Cost
Texas Efficient
Reduction
27) Graphic Arts Controls – Require certain
printers to use control devices and low-pressure
VOC materials to reduce VOC emissions. (< 20%
reduction in emissions)
The offset printers for which add-on controls
May have no reductions
would be required (i.e., those using heatset inks)
already have add-on controls in place due to NSR
$7,569.66/ton VOC40 X
permitting and opacity requirements. (If not
controlled, the high-boiling point solvents would
condense in the cooler air and form a visible
plume.)
28) Wood Furniture Coating Operations – A complex series of coating steps and application methods are
involved in finishing wood products. Coatings are usually applied in the following order: stain, wash coat,
filler, sealer, highlight coat, and topcoat. Emissions occur primarily from the solvents used during the coating
process.
a) Reduce VOC emissions from wood coating
operations by the requiring the use of low-
VOC coating, more efficient application
techniques, and the use of low-VOC cleanup
solvents. Also, add-on emission control 148 lbs/d VOC41
$2,500 to
equipment, such as carbon absorption or (based on an estimated 10%
$20,000/ton VOC42
incineration systems, could be used. The reduction)
Wood Furniture MACT (40 CFR 63, Subpart
JJ) has parallel requirements, so some of the
desired reductions may have already been
made.
40
http://www.dnr.state.ga.us/dnr/environ/plans_files/plans/sip_table3-7.pdf
41
42
Page 8 of 17 11/09/04
DRAFT
Cost
Texas Efficient
Reduction
b) Regulation 5 (Ch 115) for wood coating
operations SCC 2401015000
The Chapter 115 wood parts & products limits 148 lbs/d43 $2,500 to
are not difficult to meet and will achieve (10% reduction) $20,000/ton VOC? X
probably in the 10 – 15% range based on the
estimates for DFW and HGA in 1996.
Operations would
c) Spray technique training
recover any training
(8-10% reduction) MACT has requirements for
large wood manufacturing currently. Also,
Insignificant reductions costs due to the
reduction in materials
X
extensive training is already required.
used.44
29) Rate of Progress Controls/Chapter 115
account for reduced VOC by improving
techniques and/or regulations (may include
Architectural Coatings, Automotive Aftermarket
Coatings, High Performance Maintenance, and/or
Other Specific Purpose Coatings); VOC %
Reduction: Surface Coating categories a concern
is that if such a rule is implemented in a small
geographic area, it is too easy for people to get
non-compliant materials across the county line.
30) Floating Roof Petroleum Storage Tanks.

Control: Require a tight-fitting secondary seal on
most floating-roof storage tanks. All floating roof
$15,000 to
storage tanks are already required by NSPS 0 lbs/d VOC
$50,000/ton45
Subpart Kb and/or NSR permits to have primary
and secondary seals, so the potential reduction
may be 0 lbs.
43
44
North Carolina Division of Pollution Prevention and Environmental Assistance, Incentives and Techniques for Pollution Prevention in Furniture Coating Operations.
Online at: http://www.p2pays.org/ref/01/00017.htm#Operator
45
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Cost
Texas Efficient
Reduction
31) Degreasing / Surface Cleaning / Solvents
Controls - Adopt a solvent-based standard similar 3,778 lbs/d VOC47
to the SCAQMD Rule 1122 or 25 gram/liter VOC
Limit (75% reduction from uncontrolled
(assuming Chapter 115 is in
place)
$1,400/ton VOC48 X X
degreasing)46
32) Petroleum Dry Cleaners. Control: Require

operators of dry cleaning facilities that use
Stoddard, a petroleum-based solvent, to control
VOC emissions by at least 50 % by use of
activated carbon absorption or other appropriate 348 lbs/d to 1,433 lbs/d VOC49
$2,500 to $12,500/
means. Also includes operating requirements to
control fugitive VOC Emissions
(based on estimations for
Houston MSA)
ton VOC50 X X X
Would be based upon the petroleum solvent dry
cleaners contingency measures in Chapter 115,
§§115.552 – 115.559. If implemented, the rule is
estimated to achieve a 50% reduction.
46
47
48
South Coast Air Quality Management District, Regulation Adopted to Slash Emissions from Solvent Tanks, July 1997. Online at:
http://www.aqmd.gov/news1/Archives/rule1122.html
49
50
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Cost
Texas Efficient
Reduction
33) Metal Parts and Products Coating. Limit VOC
content of the coating or use add-on emission
control equipment (carbon absorptions and
incineration systems for 30% reduction) Will be
based on implementation of Chapter 115,
§§115.421 – 115.429. Longstanding BACT for
502 lbs/d VOC51 $5,000 to
NSR permitting is add-on controls for sources with
VOC emissions greater than 40 tpy (unmanned
(reduction may be less) $20,000/ton VOC52 X
booths) or 80 tpy (manned booths). The
miscellaneous metal parts & products MACT (40
CFR 63, Subpart MMMM, final compliance date:
8/29/06) is expected to result in reductions as
well.
34) Wastewater/Sewage Treatment –

Under Review
51
52
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Cost
Texas Efficient
Reduction
Maybe 0 lbs. reductions No cost53, but would
35) Open Burning Restrictions: Amend/adopt
because there is no burning of move emissions to
regulations to ban open burning of brush from
land clearing, trimmings from landscaping, and
household trash on days with
winds < 6 mph or days > 26
non-AQHA days
(another option would
X X
household trash on Air Quality Health Alert Days.
mph. be to burn after 6pm)
36) Require household waste to be compost or
shredded instead of burning when possible
unknown unknown ? X
36) Emulsified Asphalt: ban emulsified asphalt
that contains 12% diluents by weight or greater 3,438 lbs/d VOC if maximum
VOC54(diluents of intermediate volatility generally
in the kerosene boiling point range) TCEQ Rule
non-water diluents content is
set at 12% 56
Low cost X X X
§115.51255.
37) Cutback Asphalt: Almost Complete ban on
cutback asphalt operations containing VOC
1,629 lbs/d VOC59
solvents57 (the diluents are generally in the
gasoline or naphtha boiling point range) TCEQ
(90% Reduction)
No cost. X X X
Rule §115.51258.
53
Policy Study No. 226, June, 1997. “Costs, Economic Impacts, and Benefits of EPA’s Ozone and Particulate Standards” Available online:
http://www.rppi.org/environment/ps226.html
54
Similar to Vermont rule “Chapter c: Air Pollution Control” Available online: http://www.epa.gov/region1/topics/air/sips/vt/2003_VT_Subsection5_253_15.pdf
55
Texas Natural Resource Conservation Commission. Chapter 117 – Control of Air Pollution from Nitrogen Compounds. Available online:
http://info.sos.state.tx.us/pls/pub/readtac$ext.ViewTAC?tac_view=5&ti=30&pt=1&ch=115&sch=F&div=1&rl=Y
56
57
Similar to “Rule 420. Cutback Asphalt Paving Materials” in California. Available online: http://www.arb.ca.gov/drdb/slo/suphtml/s420.htm
58
Texas Natural Resource Conservation Commission. Chapter 117 – Control of Air Pollution from Nitrogen Compounds. Available online:
http://info.sos.state.tx.us/pls/pub/readtac$ext.ViewTAC?tac_view=5&ti=30&pt=1&ch=115&sch=F&div=1&rl=Y
59
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Texas Efficient
Reduction
38) Landfill Emissions: require the use of gas
collection system (GCCS). The gas would be
Maybe 0 lbs/d VOC61
control by open flare control device, reduces the
(All open landfills already
total collected gas emissions by 98%, and/or rout
to a gas treatment system, which processes the
require this equipment by
$1,323/ton VOC62 X X
permit)
collected gas for subsequent use or sale. 115.152
– 115.153, 115.155-157, 115.15960
39) Aeration of Contaminated Soil and Removal of

Underground Storage Tanks – establish
requirements that limit aeration (20% reduction)63
60 lbs/d VOC64 Unknown ?
40) Low VOC Striping Material (traffic markings):
require use of reformulated striping material in
place of solvent-based paint with a VOC content
of less then 0.70 pounds per gallon (water-based 1 lb/d VOC65
paint, thermoplastics, preformed tapes,
permanent markers, etc.) Goes beyond the
(estimation is for 11%
reduction66)
?
national architectural & industrial maintenance
rule (9/11/99 compliance date; applies to
manufacturers)
Cost
Non Road Strategies Emission Reduction Cost Estimate Emission Available in
Texas Efficient
Reduction
41) Require alternative landscape and natural No SIP Credits, but would
vegetation instead of mowing reduce emissions
Minimal Cost X
60
A 98% reduction can be achieved by applying “Municipal Solid Waste Landfills, 115.152 – 115.153, 115.155-157, 115.159” Available online:
http://www.tnrcc.state.tx.us/oprd/rules/pdflib/115b.pdf
61
62
Environmental Protection Agency “40cfr parts 9, 51, 52, and 60” Available online: http://www.envinfo.com/caain/landfill.html
63
64
65
66
Similar to Wisconsin's rule (NR 422.17) Available online: http://www.epa.gov/fedrgstr/EPA-AIR/2001/June/Day-22/a15619.htm and
http://www.legis.state.wi.us/rsb/code/nr/nr422.pdf
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Texas Efficient
Reduction
42) Road Maintenance/Construction agreements for AQHA days
Minimal Cost, but
a) Clean Contractor: roadway maintenance 155 lbs/d VOC
contracts exclude Air Quality Health Alert days. 1,321 lbs/d NOx67
may have significant
X
Minimal Cost, but
b) Construction restrictions during
lunchtime/limited midday hours
Varies with agreement may have significant
?
43 Require commercial airports to implement an alternative fuels plan governing tenants.
Saving per ton NOx
537 lbs/d NOx reduced;
a) Encourage electric ground support equipment 158 lbs/d VOC68 GSE $8,000-$13,000 inc/
(GSE) and other alternative fuel vehicles (estimation is for 100% baggage tug; X X
reduction) savings offset cost in
1-2 years69
b) Use electric or cleaner technology APUs –
gate electrification
c) Single-engine taxi for aircraft
d) GSE engine/unit retirement
44) Promote use of cleaner lawn and garden equipment such as lower- emission four stroke and electric
powered equipment (currently done by CPS)
Less then 151 lbs/d NOx

Depends on the
a) Require alternative fuels by public entities to and 1,807 lbs/d VOC70
Number of
use cleaner equipment with a phase in period (estimation is for 100%
equipment.
reduction)
67
Alamo Area Council of Governments, 1999 Emissions Inventory for the Alamo Area Council of Governments Region, August 2001
68
69
DFW Ozone Control Strategies, NCTCOG. http://www.dfwcleanair.com/ozone/102299/strategies.html
70
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Texas Efficient
Reduction
Cost would be
b) Suspend activity of gas and diesel powered
minimal, but
equipment on Air Quality Health Alert days
(Enforcement????)
Depends on which Equipment
businesses may be X
impacted
45) Alternative fueled equipment (construction,
etc.)
Depends on Type of fuel X
$35-$1,900 per
46) Accelerated equipment turnover; Tier 2 and
Tier 3 non-road engines
engine;
$500-$600/ton NO x71
X
47) Ban Gasoline ATVs, Minibikes, and Off-road 4,776 lbs/d VOC
motorcycles during ozone season 88 lbs/d NOx
No Cost X X
48) Accelerated purchase of “Blue Sky” engines
(Tier 3)
Governmental/Legislative Strategies/Land Use Cost
Emission Reduction Cost Estimate Emission Available in
Strategies Texas Efficient
Reduction
49) Smart Growth (No SIP credit, but other benefits)
a) Co-locate businesses and multi-use
services
Difficult to quantify Minimal cost ? X
b) Limited Annex Areas Difficult to quantify Minimal cost X
50) Urban Heat Island/Cool Cities Program –
Since ozone forms at higher temperatures, the
purpose of this strategy is to keep the city as cool
as possible, through vegetation, cool roofing, and No SIP Credits, but would
light colored pavement. Houston has attempted reduce emissions
Minimal cost ? X
to get SIP credit for UHI mitigation, but modeling
is difficult and EPA has not recognized the validity
of those models.
51) Reduce evaporative emissions through
shaded parking
Difficult to quantify Minimal cost X
71
DFW Ozone Control Strategies, NCTCOG. http://www.dfwcleanair.com/ozone/102299/strategies.html
Page 15 of 17 11/09/04
DRAFT
Governmental/Legislative Strategies/Land Use Cost
Emission Reduction Cost Estimate Emission Available in
Strategies Texas Efficient
Reduction
$0
52) Municipal compliance with Int’l Energy Depends on the number of Energy cost savings
Conservation Codes (IECC) Buildings would recover any X X
equipment costs
$0
53) Industrial/Commercial/ Residential compliance
Depending on how many Energy cost savings
with IECC – Consider expanding energy efficiency
(EE) codes
companies would recover any X
equipment costs
Cost
Point Source Strategies Emission Reduction Cost Estimate Emission Available in
Texas Efficient
Reduction
Depends on the
54) Emission balancing program for new sources project and the
in the 4-county region (more then 100 tons?)
Depending on the project
minimum required X X
SER dollar amount
Reduce NOx if less polluting
55) Environmental Dispatch of Power Plants: Unknown, Depends
facility.
“ramping up” power generation facilities that are on the plant and cost
either less polluting or located away from high
Transfers the creation of
emission to another region
of power from the ? ?
NOx producing areas to meet peak demands. grid
during peak demand
No net Emission reductions, $141,700/ton NOx if
56) Power provided through existing grid
transfers the creation of power is available on
(compared w/project 3rd coal-fired plant)
emission to another region the grid
Page 16 of 17 11/09/04
DRAFT
Cost
Point Source Strategies Emission Reduction Cost Estimate Emission Available in
Texas Efficient
Reduction
57) Scaling back Power Plant production during
air quality health alerts (unknown where the
required power would then be produced).
Practical? It is a very complex process to
shutdown and start-up a power plant. This $99,100/ton NOx if
process takes several hours. The emissions from No net Emission reductions, power is available on
a shut down are much higher then normal transfers the creation of the grid ($80 per MW
operations. The control units do not operate as emission to another region and 0.00081 tons of
efficiently (or not at all) at lower temperatures NOx per MW)
during the start-up or shutdown process. Also, the
local power operators do not have control over the
level of power they produce. The power output is
mandated and required by the state.
58) Replace New Coal Power Plant with combine 9,448 lbs/d NOx in 2012 (no
cycle gas impact in 2007)
$204,802/ton NOx72 X
72
Verified by CPS
Page 17 of 17 11/09/04

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Public Review of Clean Air Strategies

a) Tie tests in with license plate renewal to

a) Progressively timed traffic signals Depends on the project —

b) Adaptive traffic signals and signal timing Depends on the project —

12) Heavy-duty diesels limited-lanes restrict

a) Require government fleets to retire vehicles. — —

a) Require asphalt kettles to have close fitting

30) Floating Roof Petroleum Storage Tanks.

32) Petroleum Dry Cleaners. Control: Require

34) Wastewater/Sewage Treatment –

39) Aeration of Contaminated Soil and Removal of

d) GSE engine/unit retirement

Less then 151 lbs/d NOx

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