HomeMy WebLinkAbout0301.091;1
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May 30, 1991
HONORABLE CITY COUNCIL
PLANNING COMMISSION
Pal. Alto, Callforol.
Drjft Bay Area '91 Clean Air plan (19} CAe)
Helber. of t~e Council and Commission:
REPORT IN BRIEf
Tbfs is an informational report and requires no Council actton. The report
s .... rlz.s t~e rec.nt blstory of air Q"olity in the Bay Area, the draft '91
C1.an Air Plan (CAP) pr.pared by the Bay Ar.a Air Quality Management District
(BAAQMD) in compliance with the C.llfornla Clean Air Act (CCAAJ, discusses in
general tl"l5 tne Plan's potential impacts for the C1ty~ and bighli9ht~ issues
raised by the Plan.
The '91 CAP was transmitted to the City Council and Pl.nning Commission on May
l3. 1991 (CMR:288:91). The '91 CAP will be scheduled for Council r.vi •• and
c .... nt wh.n the draft .nvironment.l Impact r.port i, avallabl.. Th. '9) CAP
and the broader issues of afr quality requirements and regionai transportation
planning are a part of the June 3, 1991 jOint Planning Commission and City
Council study se.slon.
BACKGROUNO
In )988, most urban are-as in California. had not attained eitner 'federal
i8bient .Ir quality standard, (AAQS) or the more stringent stat. standards.
Also, Congress was stalled on its efforts to reauthorize t~e federal Clean Air
Act. Tilerefore, tile California leghlature passed tile California Cl.on Air
Act (CCAA) ISher, AS 2595). which required a number of actions de.igned to
ilprove iir quality f! the state and to assure progress towards attainment of
st.te .Ir quality standards. Among other things, the bill required the State
Air Resources Board to:
J. EViluate the state's air basfns for attainment or nonattainment
with state ambient air Quality standards (AAQS};
2. Adopt regulations by January I, 1992 to achieve the •• ximum
technologically and eommercially feasible reduction in reactive
organiC cDOpounds (ROC);
3.
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Adopt and i~pleme"t BOt~r Yehitle in-use performance standards and
motor vehicle fuel specifications; an~
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4. By January l, 1992. take whatever actions necessary to achieve I
55 percent reduction fn emissions of organic gases, 15 percent
reduction in emisiions of nitrDgen oxides (HOxj, and the maximum
feasible reductions in particulates. carbon monoxide, and toxic
afr contaminants.
The bill 11so required air districts designated is nonattainment areas for
ozone, carbon monoxide, sulfur dioxide (S02J, and/or NOx to prepare a plan for
attaining and maintaining state AAQS for the nonattainment pollutants and to
re~iew every Ifr discharge permit for compliance ~ith existing district rul~s
ind regulations before renewal.
In 1988, the legislature ,Iso passed AB 3971 (Cortese). which required the Bal
Ar ... Air Qualitl IIanagement ~istrict (BAAIIMD) to work cooperati",.ly wit~ the
Metropolitan Transportat;on Commission (HTC) and the Assoc;otion of Bay Area
Governments (ABAGJ to prepare t adopt, implement, and enforce transportation
control ... sures (TC/I) for the ,ttainment of lir Qu,lity standards. The bill
;150 required afr districts to estimate, by June 30, 1989, the quantity of
emission reductions frem transportation sources necessary to attain and
maintol. state and federo' AAQS.
BAY AREA AIR QUALITY
Bay Area air quality is generllty good, has dramatically improved over t~e
past 20 years. and wll1 continue to improve over the period covered by the 191
CAP, even if no additional control programs ITe adopted. San FranCisco lS the
fOU1~~ largest ~tropo11tan area fn the United States, and yet had fewer
violations/year/ml11ion population (0.57} of the one hour federal ozone
standard than any of the other fourteen largest metropolitan areas in the
United States and t~. t~i"d lowest total number of violations. Among
CalifoTBil urban ar!as. only the San Diego area has fewer ~iolations than the
Bay Area of t~e carbon ~onoxide standard.
Motor vehicle emiss;on. have st.adill decreased over t~e past fifteen le,rs,
despite unprecedented growth in auto ownership and use. Figures la. lb and Ie
show t~e decline in the number of days that the state and federal ozone limits
were exceeded in the Bay Area. ~Quntain View an~ Redwood (;ty.
Except 1~ San Jose and Vallejo. state carb~n mono~1de standards wlll b~ met by
1994. pr1.arily due to stricter vehicle inspection and maintenance programs
and the contfnufng intrDd~ct1Dn of cleaner Cirs into the Ba~ Area's ~tor
vehicle population. However. it will take up to 75 percent reductions of
hydrocarbons and NOx eeiss10ns to meet state ozone standards.
Ozone levels above the standards are of concern because of ozon!'s adverse
health effects on sensitive populations such as children, t~e elderly, or
indiYlduals with respiratory cond;t;~ns. In Southern California, researchers
bave found irreversible 1ung damage in young people from e~posure to levels of
ozone above tne federal standard. Carbon monOXide is a ~e11·known poison that
combines with t~e ~.moglobin 1, red blood cells, crippling the blood's ability
to corrl oxygen to the body's cells.
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DAYS ABOVE ONE HOUR OZm,[ LIMITS
figure 1a
65 6667 6B 69 70 71 72 7.3 74 75 76 77 78 79 s:: 8; 82 : . .'l 134-,:,~ 805 87 M 23 &,)
Cl STATE
Figure Ib
656567613 69 70 71 72 73'475 H 77 78 7';t SO 81 13] 83 54 8.:, 85 87 S8 Sg 90
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DAYS ABOVE ONE HOUR OZONE Li~"!TS
F!e(l .. oC'~ C.lt (ii"65-nHn) ,. ,---------------------~----
c
Data used in preparing these figures is ~ttached to this staff report
as -Bay Area Ozone Trends.-
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I •• plt~ of t~e continued improvemeots In air Quality, ~ealth-bas.d ambient
aIr quality standards are violated at tImes In some parts of the Bay Area.
In the Bay Are., the state ozone standard is violated frOB 10-20 ti .. s!year,
usuIll, on hot $~r days; and th~ state car~on monoxfde standard is e~ceeded
fro. 5·]0 t1.es/yeaf on cold winter ni9hts in San Jose, San Francisco, and/or
Vallejo. No urbanized are. in ealifornl, meets the ,tate ozone standard of o. g ppm.
SOURCES OF AIR POlLUTANTS
Ozone is generJl1y formed from precur$~rs known as reactive hydrocarbons
(RHC} and NOx, while carbon DOnolide I. produced by Incomplete combustion.
Motor vehicles are the single 11'gest source for all these pollutants; the
second largest category of RHC emission sources is natufal sourC6S such 15
vegetation, while combustion sources other tnan motor vehicles (i.e.,
priaar11y wood burning stoves) are the second ~fghest source category of NO~
and carbon monoxide.
AIR QUALITY STANDARDS
The state AAQS for ozone Is .09 parts per million (ppa); t~e federol AAQS Is
.12 ppo based on lone hour o.erage. The st.te carbon monoxide AAQS Is 9 ppm
iyeraged oyer 8 hours and 20 ppm averaged over I hour, while the federal
standards are 9 .nd 35 ppm respectively. To be io compliance with the
standards t an area needs to never violate the established levels. As
Identified i~ figures la, Ib and Ie, the number of days When violations occur
has decre.sed from the 1960s and 1970 •.
THE SAN fRAllCISCO BAY AREA '91 CLEAN 4lR PLAN
eecause the Bay Area will not .. et state AAQS for ozone by 1997 and does not
currentl1 .eet the carbon monoxide standard, tne State Air Resources Board has
designated the B~ Area as a ·severe-nonattainment area. The tCAA requires
the BAAQMO to prepare and adopt a plan by June 30, 1991 (actual plan adoptlOJ,
Is likely to occur In July or August .fter review of the Droft EIR on the '91
Clean Air flan) designed to reduce tnese pollutants 5 percent e.eh year by
1~lementfng all feasible emission reduction Measures. Require~nts for the
Bay Area Include:
Reasonably available controls on all sources;
No net fncrease permit system for new st.tfonary sourceSi
Retrofit controls on existing statfonary sources;
Traff.c cD~trol measures to achieve 1.5 ave-rige vehicle occupancy
during commute hours by 1999;
No net increase in vehicle emfssfons after 1997i
Indfrect source and area source control progr~ms;
PubliC educatlon program;
tow emission motor vehicles for fleetsj and
Reduction fn populatiDn exposure to ozone.
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10 April. the District released, dr.ft plan, called the '91 Clean Air Pl.n
('91 CAP). for public conoent. The DIstrIct held several loform.tionol
werkshops 10 lote April/early May on the CAP. will releose 0 draft
En,iromoent,l lapact Report (fIR) for public re,lew sometime i. June. and will
hold. public hearing on both the draft CAP and draft fIR in July.
Hjghlights of thf '91 Clean Air Plan
Th~ draft Plan includes 51 additional controls on stationary and mobile
source' ond includes Traffic Control Measures to be Implemented In three
phases. These seas~re$ were chosen after evaluating their effectiveness,
technical feasibility, cost, cost-effectiveness, feasible implementation
schedules, legal and institutional issues, fil'l.anthl constraints,
enforceability. public acceptance, and other positive and r.egative impacts.
Stltlonary Source Controls
The proposed De.,ures. listed on Table 8. p.ges 47-54 of the Plan, will
control e.isslons from the following stationary sources:
Surface coating and solvent use lAI-A19Ji
fuels/organiC liquids storage .nd distribution (al-1);
Refinery and chemical plant processes (Cl-el);
fuel combustion (HOx sources} (OI·De);
Other industrlal/commerci.l processes (El-E4); and
Other stationary sources (fl-f4).
Also inc1uded I. the Stationary Source Cootrol Measures (Table 8 of the Pl.n)
are the follOWing measures which also relate to mobile sources:
Intermittent transportation control measures (GI-G4); and
Motor yehicles (HI-H4).
Hobll. Source Control.
The '91 tAP includes mobile sour'e cootrols already .dopted by the C.liforni.
Air Resources Board (CARB) since 1987 such as improYements to smog check
programs, requirements for on-board diagnostic systems, 'ertific~tion
procedures for aftermarket catalytic converter, a revised light-duty
IftenDarket pa~t5 progr~st amended emissi~n control system warranty
requ1rements, a smoKe enforcement program for heavy dut)' diesel venfcTes,
vehicle recall regulations, and regulations for low-emission vehicle and
engine. The '91 CAP fs 11so ;mp1e~e~ting certifications of new and used
i.ported vehicles, revising emission standards for lig~t-d~ty vehicles a~d gas
and diesel-powered heavy-duty engine and prescribing n~ dies~l fuel Quality
standards and reYl~ed test procedures. CARS js also developing more stringent
standards for new and used vehlc1es and engines, enforcement measures of
emfssion standards for alternative fuel retrofit syste~s, and new gasoline
specIfications. Other regul.tlons being studied by CARB to be proposed after
1992, but not included in the '91 CAP, are for further improvements to the
SDog check programs. inspections for light-duty dies.l yehicles .nd fleet
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be,vy·duty trucks, Tttrof1ts for buses and trains, 10. emission standards for
heavy-duty engines, control of off-cycle emissions, i.d fl.et average
standards fOT low emls,ion vehicles sold in California after 2003_ Mobil.
souTte controls also •• e included in a Trifflc Control Mei,"reS (TCM) Plan
Implemented I. three phase •• s listed below:
P.ase I: 'Reasonably A.ail.ble TeMs' based on •• istinS luthorlty and
funding (1991· 1994)
Ph.s. II: 'Additional Mobility Traffic Operations and Incentl.es Package'
requires new leglslati,e authorlty/fundi'g (1994-1991)
Phase Ill: -Market Based l(Ms,-req~lres authorizing legisl&t{an, except
p.r~Ing •• nagement (1997 or lat.r·-specific implementation dat.s
.re u.ncertain)
Phase. 2 and 3 need the DOst effort to carry out. Pha.e 1, especially, i.
uncertain, due to ttle need to educate the publ fc and deve' op consensus on the
pricing Issues, and to instttute the required legl.l.tlve chang.s. MIt ha.
led the regional effort to develop the reM ,omponent of the '91 CAP. The TeM
component has been refined oye~ the tQurse of the past year, with input from l
broad cross sectfon of Bay Area busi~es5. enVironmental, governmental and
public Interest groups. The following Figure 11 from page 60 of the '91 CAP
lists the TOMs Included I. each phase. The following paragraphs provide.
brief description of the TCMs_
Pha5. 1 TCIIs
[~I.y.r-B •• ed Trip Reduction (TCH. 1 and 2): The purpose of these me.sures
i. to requiTe employers to I.stltute strategies which reduce employee <omowte
vehicle trips. MIC will develop. model trIp reduction ordinance for this
purpose. Palo Alto and other 'olden Triangle cities have already adopted a
trip reduction ordinance, which will probably mlet many of the requirements of
these TCMs. The Santa Clara County Congestion ~anagement Program, and those
of other countl.s, will also require the development of trip reduction
ordinances for all cities. MTC will ensure that all these various
requirements are coordinated.
Indirect Soure. R.vi .... (TCII 16): Indirect sources are 1or9. attractor. of
vehicle trips. such as large residential developments, companies, retail
busfnesses. and sports facilities, both eXisting and new. Under thfs TeM.
indirect sources would be subject to review of site planning elements such as
maxl.um parking 11.lts, design of bike routes and parting, and provision of
sidewalks aod transit stops, possibly resulting in changes to the site plans
of d.velo~nts, and added costs.
~Qbilfty I~r.veaent (TC~s 4. 1. 8, 9. 11): These measures relate to the
provfsiDn of increased transportation facilities, especially for modes other
than single-occupant ~rlvlng. They include expedited new rail extensions;
e~pans10n of ferry servfce to San francisco; expansion of the High Occupancy
¥ehlcle (HOW} lane syst .. on freeways; Increased mil,age of bicycle lane.,
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0" re~ , Figure 11 ·TeM Plan: January 1991
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Ph .. e1 -ReuonIbIy Available rCMa
.-.... IIINIIfII/IJIoItfy IDI/ IUndInfI
EmpiGyIr_T~p_ ..
(TCJII 1.11 .e....,._ .... _
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Indi .... 5ooIi:o_
(1CJl II, . Now_
• e .. .,_
_I!y IPooWY Mi<!adI
(TCM.4, 1," g. 1'1
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• HOY ..
• 8i<ydo-· -.,IOS
Impl"""""" support
• ""'"' _ .. (TC.lW)
• 1lMIop ............. _ ........
........ (TCIoI',' · _~"'-'.AIr~_(TCIoI'·1
• ~~-.. • .... -(TCIoI"1 · -am;
PhiS. 2 -Addltlonel MobilHy. Tralfle Operation. end
Incentives Package
AI/fqIJ". _II/lfDIMIN IUIIIt/tiIyIfIftII
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(TCIII 3-",
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• EIIpMti new r •• IM. · ~"""Io,.a.,.....,.. · """"'" """ ..... '-""Y11I ·HOV( __
• 1licyOo ......... ..
• StudenI ......... ian
T_OpInlon ..."."..'
(TCIrI& fI, tZ)
• Frwway R:ldenI ~
• AMriII •• "" •• , •••
U ... , ..... _
(TCIII13. 14. "I
• Tflnal t.er.a.dlon
• V...",.rI 1oIiI'oI-
I CIrpooI., P !, "1OtI!!_
ImpIomanIllon Suppon
• Eopn prliIa _ion (1(:11, ~
• Ao. __ (TCIoI1l11ooo-..... goo Ia. ~llridiItloll
• _ .... _ (TC.II2O)
0' i,'~ITMD.IJI'IP~!t;jJL :
PhaH 3 -MIIbI BaNd rCMa
.RIqIiIU IIIIIIoIfIIrIO IIQ/III .....• ..."
ptttItrg-,
Pr1r:1ng SIJ,IIgtn
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p~ths. and routes; e~pa"ded capability to take bicycles an transit vehicles;
prov'.'on for bIcycle. t. cross ,II B.y bridges; and InstillatIon of Ciltrans'
Trafffc Operatiol'is S1ste .. on freeways. which see-ks to r.edu.:e tnffic:
congestion by ramp metering, traffic surveillance, and incide-nt management.
I~leoe.tltio. Support (TCHs 17. 18. 19. 21): Thes. measures relit. to the
lople.entatlon of supporting actIvities such .s educ.tional prograMs whIch
pro.ote Ilternatfve trlnsportation modes; providing new revenue sources for
the .abIlity-related TeNs. such as increased bridge tolls. car reglstratl.n
f.es, and gas tlX; requirement for an air quality ole .. nt In ,II general
plans; and enco~rageaent of higher-density zoning near transit stations.
PIIa •• 2 TtN'
WobilifT I~ro .... nts (TCHs 3-10): These represent. more ambitious and
costly stage of the DebilIty Improvements described under Phase 1_ Included
here are increased areawide bus service; continued expansion of rail service t
'err1 seryfcI, HOY lanes, and bfcycle acceSSi improved Iccess to rail
stations, such as more parkln9~ bus service, bicycle access, and prfvate
shuttle~; new rail service fn the A~burn-Sacrimento-San Jose Ccrr1dor; and
assIstance in $c~ool transportation for grades ~-12_
Traffic Oper.tio. W.n.g .... t (TeNs 11, 19): These measures call for continued
expinslon of the TraffIc Operitlons System for freeway; and implementatIon of
traffic management strategfes for arterial streets, such as signal tfming
progra.s t trlnsit bus 5ignll preemption~ and assignment of -freeway reliever
status.
Us,r Incentires (TeNs 13~ 1f, 15): These include reduced transit fares,
provision of vanpoo1 lfabt11ty insurance; and provision of financial
1ncentfves for 3~ person carpools, suc~ as gasoline vouchers or direct
payments t. carpoolers.
I~I ... nt.tion Support (TeNs 1" 20. 21): These Include the education and
revenue progr~s of Pnase It plus t~e undertaking Df varlOus demonstration
proJects to further develop stritegies that will ultiMately be required to
achieve t~e clean air standards, such as projects in telec~uting, congestion
prfcing, and electric and alternative f~El vehicles.
"'as. 3 TCNS
Tnese TeMs consist of pricIng strategies that would reduce vehicle trips and
redfstribute them to less congested time periods of the day. These incl~de:
SIIIog fees, .hich directly rel.te to the imount of pollution produced by
individual drivers;
Gas tax increases as I surrogate for emissions produced;
Toll .. ads and congestl.n prICing of roadways and bridges (varying by
time of day) to reflect tne fact tnat existing fees do not c.ver the
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tohl costs to bu11d and lIainta";n roads or tfle costs of hu.1th impacts
imposed on society; and
Provision of monthly esployee tr.,el .110.onces (to be used by ~mployees
as tney wish for any purpose, whether related to transportation or not).
coupled wIth employee parkIng fees •• s • way of correcting' .ubsidy to
the automobile.
The fees collected by these program. (except the parkIng fees} would be u.ed
to .ake transportation improvements f~ the region. such as fmpro~ed transit
service, subsidies to low income ~ouseh~ldst rettrfng of older vehicles, and
other programs.
[xpacted Leyels of Emissions Reduct1?n 1f '9] Cteln Afr plan is Adopted
Projections of fQture conditions incorporate ABAG/s regional grQwth
projections and MTC'. transportation data. If the control. In the Plan .re
adopted and implemented. they are expected. by the year 2000. to reduce 8ay
Are. RHC e.isslons by 90 tons/day (17 percent) from tne 1987 boseline. and NOx
by 115 tons/day (22 percent}. (Table 6. page 31}. resulting In an improvement
of ozone iir quality of less than 10 percent to between 0.13 and 0.1. ppm.
Traffic control measures aCCDunt for about 40 pp.~cent of the expected
emissions reductions. Table I shows the relotive contribution of TCM
fmplementit~on for the total predicted ozone precursor emiSSions reductions.
TABLE I
COMPARISON Df ESTIMATED OZONE PRECURSOR
EMISSIONS REDUCTIONS FROM TCMs AND '91 CAP
TONS IDAY RED\JCfD J!IK
PI1ase I (By 1994) B
PI1 •• e II (By 1997) 22
Phase III (By 2000} 35
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45
ICM TOTAL '91 CAP TOTAL % PUE TO IeMs
17 57 29.8ZX
51 119 42.86%
BO 205 39,OZX
By 1994, carbon monoxide star.dards in almost all Say Area communities ~ill be
~t, with Maximum values expected to be about 10 ppm (versus t~e state
standard of 9 ppp and the federal standard of 12 ppm) for. few days each year
in San JOSE and Vallejo.
Benef;ts and Costs of Implementation of th~ '91 CAP
The direct benefit. listed by the authors of the Plan will be cl.aner air.
reduced respiratory related Illnesses, improved .arker productivity and lower
aedfcal costs. Other benefits listed include enhanced visibility, reduced
Igrfcultural and materials damage, lower energy consumption, and improved
traffic condit;o~s.
Direct and indirect costs are substantta1. Bay Area direct costs for
compl!.nce with the two previous federal plans enacted jn 1970 and 1977 have
cost appro.!m.tely $1 billIon since 1979. Cost estimates for meeting the
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federal ozone standard were at SJOO millIon annu.lly. Today's costs for
Impleeentlng the proposed new controls In the '~l CAP are likely to be much
blgher due to Inflation, the effect of diminishing returns ., each Incremental
decrease in ozone reqyires ~uc~ bf9~er decreases in precursor emissions. a~d
the increased e~phasis on transportation related ~asures ~;c~ will increase
costs significantly.
RelatiqnshIp of (9) CAP to federj' Clean Afr Act
Most C,llfornla Clean Air Act requirements .re mo"" stringent than the
provl,lon. of the Federal Clean Air Act, and the '91 CAP should satisfy
feder,l requlreeents. In three .r.as, the federal legislation I. more
stringent:
Requirements for i~troductton and use of ·clean fuels-(e.g.,
compressed natufal gas. methanol. and ethanolj in =otor ~ehic1e$
and especially requirements for operators of fleets;
Enhanced veh1tTe inspection and maintenance equal in effectIveness
to an annual vehicle insp~ction program; and
Controls on I variety Df volatile toxic $u~stances.
The state will upd.te their Implementation plan to incorporate compliance with
the new federal legislation. The upd.te, due In 19~1-93, is expected to
exten,lvely use the proposals contained I. the '91 CAP.
Potent'al Effects on City facilities and Operations
Many of the proposed control measures could Iffect City oper~tions and
1acilitles. Beca"se the specific regul.tions have not yet been fOrDUlated and
there has been i~suffic1ent t1me for staff to evaluate potentill impacts, a
complete .nalysls of the Plan's effect on City operations and facilities Is
not feasible at t~1s time. However, staff has identified some of the ~asures
that will potenti,lly affect City oper.tlons. These are listed by
Departaent/Oivlslon or Activity In attached Table II. Major potenlial impacts
on the City appear to Include:
Accelerated replacement of the Regional Water Quality Control
Plant's (RWQCP) jncinerator from the current estimate of
replaceaent no earlier than 2000i
Retrofit Dr replacement of reciprocating engine equipment suc~ as
11'lft1 IIOWers;
Conversion or replatement of vehlcles in the tity's fleet in order
to .eet clean fuel standards; and
Disruption of services and facllity operations because of
Yoluntarl or mandatory -no drive-days.
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In addition, the potential ex1.ts for t~e Cily to have conflicting .n~
potentially difficult to resolve regul.tory requirements from regional
ogencles for oper,tlon of tho l.ndfill .nd the RWQCP.
ISSUES
[n reviewing t~e '91 CAP, I number of key issues !merged.
I. There is , v,lld public po11cy i.sue regarding whether some of the
costs (ft.onctl1, procedural and political} "snclated w1th the
'91 CAP are worth t~e a;r quality fmpro~ement5 to be gained.
As noted 1n the Pl.n and d1scussed in this report, the Bay Are.
has reasonably good liT quality; will meet state and federal
carbon monDxfde standards 'With iii continuation of current efforts;
Will ~et federal Olone stand.rds with additional efforts but will
not .eet state standards; future violations of state and
especially federal standards are likely to not Dccur very often
and generally occur in scattered locatfons; and the cost of
1.pl~nt1ng the '~I CAP will be substanti,l. Essenti,lly, nearly
all ~f the identifiable and reasonably feasible source control
1mpro~ements have been or are being made. A strong effort to meet
state Olone standards ~ill tDvolve aggressive efforts to have
people drive their aut~mobiles less for both commute and
noncommute trips. To be effective, City staff be1ieves t~at tnese
efforts will have t. be disruptive and mandatory (e.g., bigher gas
tax. parking fees, no drfve days) rather than voluntary. Given
how close the Bay Area Is to meeting federal and state standards
and the cost involved in aeet1ng tne more restrictive state ozone
standards, perhaps consideration s~ould be given to having state
standards be consistent with the feder' 1 Cl.an Air Act.
2. City staff has serious reservations about the quality of the data
and re1ated air quality mode1ing .fforts of the Bay Area Air
Quality Management District.
Staff was 1ntrigued by the '91 CAP's lack of pre-19S1 data other
than the annual days of oz~ne and carbon monoxide violations on
page 10 and 11 of the Plan. A request to the B.y Area Air Quality
H.nag ... nt District (BAAQMD) for pre-i9B7 daily emission
statistics. to compare with the information on page 16 t 23, 24 and
25, resulted in explanations that all of the data is based on
worst case DOdeling ind no comparable pre-19S7 data is available.
In 1985, the City underto:>k an extens;~e carlHln ltioMxide
monitoring program as part of the preparator~ work for thE
Citywide land Use and Trinsportation Study (see attached pages
from CHR:241:6}. The City's monitoring was done in close
cooperation with BAAQHO staff, and t~e data was collected during
one of the worst (if not the worst) cold air inversion per~od of
the 1980s. lnter.sllngly, the data collected showed far lower
OIR:301: 91
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levels of carbon monoxide than the BAAQMD's air quality models
Indlc.ted should be pr.sent.
Finally. nuaerous conwer$atf~ns over the past decade with planning
st.ff of other eay Are. jurisdictions and environment.l planning
consultants have yielded the gener.l conclusion th.t the
District's MOdels in their (OCYS O~ worst Clse calculations
overst.te the severity of .Ir quality ,onditions.
3. T~e '91 CAP should address restrictions on t~e use of wood burnlng
stoye$~
The Plan notes. In Figures 4 and 5 on pages 12 and 13. that
Coobustion Sources (I ••.• "mostly wood-burning") is the second
highest SOUTce of nitrogen oxides and carbon monoxide. The Plan'S
Source Contr~l Measures, other than possibly t~e reference to
reducing the .. iss!ons from residential furnaces (it .. 08. page
52). do not add,~ss regulating wood burning .tove.. Confronted
wttb measures suc~ as potential parking fees, no drive d~s and
higher gasoline taxes. the control of wood burning .tov •• appears
to be a log1cal area for regfonal regulation.
4. The '91 CAP and Draft Regional Transportation Plan illustrate the
need for a nore integrated regional land use/transportation/air
quality pl.nning process.
SUItIARY
Tbls report has discu.sed the '91 Cle.n Air Plan recently Issued by the BAAQMO
for public cooment. Implementation of t~e '91 CAP will significantly .ffect
public pol fey decisions over the next few years. The proposed measures iQ the
Plan have potent'al impacts on other regional programs, on operations and
facilities already under other regulitory programs and on land u •• planning.
Thero will .1.0 be .Ignificant economic impact.. In addition. BAAQHO clearly
stated that -no practical strategy for meeting the state ozone standard was
ident;f;ed~· NevertheT&ss, the Plan's authors beli!ve that the federal ozone
standard Ind the state carbon monoxide standards will be met by implementatian
of the Plan.
This report has been prepared to facilitate Council discussion of the subject,
and no Council actfon is requested It this time. Staff will c~ntin~e to
DOnitor development. and will ageodize the ,ubject .fter the Oraft EIR has
been released for publfc review and comment.
Respectfully .ubmitted.
~~ -~ .1'<.--
1lO1!lS MAEZ
Environaental Protection
Coordinator
CItR:301:91
p:\CMR\Cl •• nair.c.r
KENNETH R. SCHREIBER
Director of Planning and
Community EnY;r~n~nt
5/30/91
Page 13
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Asoistont City Konoger
AttachOlents: I) Pages I, 2, Ind 3 of CKR:241:6
2) Bay Are. Ozone Trends
3) T.bl. II, Potenti.l Effects of '91 Clean Air Plan
Control Measures on Clty Operations
4) Glo •• ,ry
cc: Chris Brittle, KTC
TOIl Perardi, BAAQMl)
Mlchlel E •• nhoe, CKA
U1R:30) :91
p:\UIR\Cleanalr.cmr S/30/9)
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