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REPORT:

Rule 2202 Emissions Equivalency Task Force Status Report

SYNOPSIS:

This is the final report from the Emissions Equivalency Task Force (EETF). The Task Force had the responsibility of evaluating and recommending methods to make up the emissions shortfall caused by the permanent exemption of employers with fewer than 250 employees from Rule 2202.

RECOMMENDED ACTION:

Direct staff to implement the Emissions Equivalency Task Force recommendations to cover the emission reduction shortfall created by SB 432.

Barry R. Wallerstein, D.Env.
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 with 100 to 249 employees are no longer regulated by Rule 2202. This group of smaller worksites represents 64% of all 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 the regulation of 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 excess credits from the Rule 2202 Air Quality Investment Program.

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 emission reductions to offset the potential shortfall for 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 required emission reductions.

The Task Force has completed its work and is making the following recommendations to the Governing Board on strategies to make up the emissions shortfall created by SB432:

1. Use the following projection for estimating the potential shortfall:

Potential Shortfall Estimates
Tons/day

2. Work with the Mobile Source Air Pollution Reduction Committee (MSRC) to apply the NOx emission reductions generated by MSRC projects toward the potential shortfall.

3. To the extent feasible, the AQIP program should expend funds to meet the quarterly program goals as well as accumulate excess credits to be used to offset the potential shortfall.

4. Utilize the emission reductions from the funding of projects under the Carl Moyer Program to help offset the shortfall, if allowed by the California Air Resources Board.

5. Pursue the concept of reducing VOC through corporate donations of ERCs for this purpose.

6. Emphasize parking cash-out as a viable option under the Employee Commute Reduction Program Option of Rule 2202.

Comments Received

Comments were received from three agencies that participated in the Task Force: SCAG, Southern California Edison, and the City of Los Angeles.

SCAG - We recommend that the emissions shortfall be tabulated in the final document for all milestone, attainment and planning horizon years.

Staff Response
Since the shortfall is only a projection, it was estimated using the years contained in the emissions model: 2000 and 2010. The estimates are consistent with the 2010 planning horizon of the AQMP. Additionally, these estimates will be recalculated annually, after the completion of the annual surveys designed to track the emission shortfall over time.

City of Los Angeles

1. Staff should address the additional outstanding issues, such as the contractor's proportional share of the emission reductions from MSRC projects, treatment of voluntary strategies, and completed MSRC projects.

Staff Response

The method by which the MSRC receives its proportional share of emission reductions is at the discretion of the MSRC and provided for in guidance issued by the CARB. The Emissions Equivalency Task Force’s recommendations do not affect this issue. Contract language is currently being developed and discussed with the MSRC regarding the voluntary aspect of utilizing the emission reductions from MSRC projects toward the attainment demonstration. Reporting of current MSRC projects, which do not have extended reporting periods, will be reviewed to determine if the District can continue to use the emission reductions for future years over the life of the projects.

2. The annual reporting to the Governing Board on the actual shortfalls should include a status of action on the recommendations.

Staff agrees.

Southern California Edison - We agree that the best course of action is to aggressively make up the emissions gap with emissions reductions achieved from the MSRC program.

Comment noted.

Donald Shoup, UCLA, Institute of Transportation Studies

Submitted a minority report to the Board regarding the final draft proposal and requested the opportunity to address this issue at the Board Meeting. Dr. Shoup believes that employers should not provide greater incentives to solo drivers than to rideshare participants under Rule 2202. Further, he believes that occurrences of disparate incentives could provide an option to further reduce emissions.

Summary

The attached Final Report and Meeting Summary completes the work of the Emission Equivalency Task Force. The EETF has identified sources of emission reductions that appear sufficient to meet the NOx and CO shortfall. At this time it is unclear if VOC emissions reductions will be available to address the shortfall. Staff will continue to work toward identifying and implementing strategies to make up the shortfall created by SB 432.

Attachments

Emissions Equivalency Task Force Final Report

Rule 2202 Emissions Equivalency Task Force January 19, 1999 Meeting Summary

Comment Letters:

• Southern California Edison
• City of Los Angeles
• Southern California Association of Governments
• UCLA, Institute of Transportation Studies

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