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REPORT:

Rule 2202 Emissions Equivalency Task Force Status Report

SYNOPSIS:

This is the first in a series of reports on the efforts of the Rule 2202 – On-Road Motor Vehicle Mitigation Options Emissions Equivalency Task Force. This Task Force is charged with evaluating and recommending methods to make up the emissions shortfall caused by the permanent exemption of worksites with fewer than 250 employees from Rule 2202 compliance.

COMMITTEE:

Mobile Source, September 25, 1998, Reviewed

RECOMMENDED ACTION:

Receive and file this report.

Barry R. Wallerstein, D.Env.
Acting Executive Officer

Background

On June 19, 1998, Senate Bill 432 (Lewis) was signed into law and took effect immediately as an urgency measure. The legislation set the compliance threshold of Rule 2202 - On-Road Motor Vehicle Mitigation Options to 250 employees per worksite on a permanent basis. Accordingly, worksites that have between 100 and 249 employees are no longer regulated by Rule 2202. This represents 64% of the worksites that would have been regulated at the 100 employee threshold.

Although these worksites are exempt from Rule 2202, the adopted 1997 Air Quality Management Plan (AQMP) includes the mobile source emissions from worksites with 100 or more employees as part of the South Coast Air Basin attainment goals. During 1997, the exemption of the smaller worksites resulted in a shortfall of emissions reductions that were offset by purchasing credits with Rule 2202 Air Quality Investment Program monies. However, for 1998 and beyond, other measures will be necessary to address potential shortfalls.

Staff requested input from interested parties to review possible sources of mobile source emissions to offset the shortfall in emission reductions from 1998 and beyond. To facilitate this process, the Rule 2202 Emissions Equivalency Task Force was formed to investigate and make recommendations to the Governing Board regarding the best approaches for achieving the requisite emission reductions. The Task Force roster is attached.

The Task Force first met on Thursday, September 3, 1998. At this meeting the changes to Rule 2202 and the resulting emissions shortfall were discussed. Potential sources of emissions credits were reviewed and discussed by Task Force attendees. The sources discussed cover such areas as: MSRC (AB2766) contracts in context of the State Implementation Plan (SIP); expansion of the Rule 2202 Air Quality Investment Program (AQIP); development of fleet rules for passenger and heavy duty vehicles; acceleration of re-powering school buses with alternative fuel engines; and, enhancing the Cut Smog Program. The focus of this meeting centered on how to quantify emission reductions realized from existing projects through an overall set of activities or actions which when comprehensively taken together will make up for the shortfall.

During the second meeting on Wednesday, September 16, 1998, the Task Force focused on projects that were identified at the last meeting as areas that were most likely to result in viable emission reduction credits. These areas included: MSRC programs and emission reduction quantification; CARB's Mobile Source Control Programs; the President's executive order for federal fleets’ use of alternative fuels; and current legal initiatives such as Proposition 7 and AB1368 (Villaraigosa) / SB1857 (Brulte).

The MSRC program was reported to result in significant quantifiable emission reductions that may be appropriately used for offsetting the emissions shortfall. However, it may be necessary to account for project implementation lead time. Furthermore, projects may result in differing levels of emissions such as higher NOx and lower ROG and CO reductions. CARB's Mobile Source Control Programs are currently identified as further potential control measures that the AQMD may consider in the future. The legal initiatives, Proposition 7 and AB1368 (Villaraigosa) / SB1857 (Brulte), offer potential emission reduction credits, however, this is dependent on credit quantification and allocation.

The programs discussed all offer potential emission reductions. The use of the mobile source emission credits may require additional research to determine the most suitable methods for their allocation. MSRC projects could most likely provide the requisite NOx credits over the long term. CO reductions credits may be available once attainment has been achieved through CARB's mobile source control programs. However, there is still a need to explore additional mechanisms that will address obtaining ROG emission credits.

The Task Force is scheduled to meet again on Wednesday, October 14, 1998 to further discuss the various mechanisms that the AQMD may need to achieve the mobile source emission reductions to meet the Rule 2202 shortfall.

Staff will be reporting back to the Governing Board in December with additional information.

Attachment

Rule 2202 Emissions Equivalency Task Force Membership Roster

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