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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.
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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.
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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).
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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.
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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.
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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.
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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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