South Coast Air Quality Management District

Rule 2202 - On-Road Motor Vehicle Mitigation Options Program Status Report

SYNOPSIS: 

On December 8, 1995, the Board adopted Rule 2202 - On-Road Motor Vehicle Mitigation Options and requested that staff provide an annual status report to the Board. This report provides an overview of the Rule 2202 program activities during the year 2000.

COMMITTEE: 

Mobile Source, December 7, 2001, Reviewed

RECOMMENDED ACTION:

Receive and file.

Barry R. Wallerstein, D.Env.
Executive Officer

SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
GOVERNING BOARD
 

CHAIR:                                                                         WILLIAM A. BURKE, Ed.D.
                                                                                        Speaker of the Assembly Appointee

VICE CHAIR:                                                               NORMA J. GLOVER
                                                                                        Councilmember, City of Newport Beach
                                                                                        Cities Representative, Orange County

Rule 2202 - On-Road Motor Vehicle Mitigation Options
Status Report

Introduction

Operations

Rule Program Activity

Outreach

Purpose

Employee Transportation Coordinator Training

Quarterly Informational Sessions

Transportation Programs Internet Page

AQIP Assistance

Transportation Consultants/Transportation Management Associations/Employers Roundtable

Employee Rideshare Events

Compliance Program

Conclusion

Introduction

Rule 2202 – On-Road Motor Vehicle Mitigation Options, requires employers with 250 or more employees on a full- or part-time basis to implement an emission reduction program to reduce emissions related to employee commutes during the morning peak hours (6:00 AM to 10:00 AM).

This program status report for Rule 2202 - On-Road Motor Vehicle Mitigation Options is divided into three sections:
 

Operations:	This section includes details of the success of the emission reduction options and the Air Quality Investment Program (AQIP) in achieving the emission reduction goals established under Rule 2202. This section also provides an overview of Rule 2202 operations and activities by worksite and corresponding emission reductions.
Outreach:	This section describes Rule 2202 Employee Transportation Coordinator (ETC) training, Quarterly Information Sessions, Transportation Programs Internet Page, and Technical Assistance efforts.
Compliance:	This section describes the audit activities for Rule 2202 and also describes the incentive benefits available under the "High Average Vehicle Ridership (AVR) No-Fault Audit" service.

Implementation and effectiveness of Rule 2202 is dependent upon all of these activities.

Operations

Rule Program Activity

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 to 250 employees per worksite on a permanent basis. Accordingly, worksites with 100 to 249 employees are no longer regulated by Rule 2202. When Rule 2202 was adopted in December 1995, there were 4,863 worksites that were subject to the Rule. As a result of the compliance threshold being raised from 100 to 250 employees per worksite, there are currently 1,435 worksites subject to Rule 2202.

Employers may at their own discretion elect one of the following programs to be in compliance with Rule 2202:

1. Emission Reduction Strategies (ERS): The Rule’s emission reduction strategy option allows employers to meet their emission reduction target (ERT) by utilizing various alternative strategies such as mobile source emission reduction credits generated by Rule 1610 - Old-Vehicle Scrapping, Rule 1620 - Clean Off-Road Mobile Equipment, or other Mobile Source offset programs; Peak and Non-Peak Commute Trip Reductions; Vehicle Miles Traveled (VMT) Reductions; and other emission reduction strategies.
   
   
2. Air Quality Investment Program (AQIP): This option allows employers an alternative to implementing emission reduction strategies. Employers may elect to participate in a triennial compliance option and invest $125 per employee reporting to the worksite in the peak window; or annually invest $60 for each employee reporting to work in the peak window. The AQIP is used to meet projected quarterly emission reduction targets.
   
   
3. Employee Commute Reduction Program (ECRP): Employers may elect to implement an ECRP that will be reasonably likely to result in achieving their AVR goal within three years. Employers choosing to implement an ECRP under Rule 2202 are required to designate an ETC who is responsible for developing, implementing, monitoring, and marketing an ECRP to their employees. The designated ETC is required to attend a one-time 16-hour, AQMD-certified training course that discusses the implementation of a trip reduction program, submittal requirements, and a review of Rule 2202.

The Rule’s emission reduction strategy option allows employers to supplement their ECRP by utilizing various alternative strategies to meet their target or to completely replace their ECRP with new emission reduction strategies. Furthermore, employers may use the ECRP exemption for their worksite and voluntarily retain their trip reduction program. From the previous year of 1999, the number of commute-window employees in AQIP increased from 17,125 to 34,929; in ECRP decreased from 497,477 to 448,623; and in ERS decreased from 192,577 to 180,922.

Table 1 illustrates the current level of participation in the available compliance options under Rule 2202 in 2000.

The net effect of Rule 2202 during 2000 resulted in estimated emission reductions as shown in Table 2.

The collected monies under the AQIP option are placed in a restricted account to fund programs that will result in equivalent emission reductions. The level of employer participation determines the dollar amount of the AQIP fund and the emission reduction target that the program must achieve. The AQMD reviews and evaluates projects on a quarterly basis for funding. Project funding is based on cost-effectiveness and the ability to deliver emission reductions equal to or greater than the emission reduction target for that quarter.

During 2000 the AQIP funded 13 projects which included old-vehicle scrapping, tugboat re-powering, and the retiring of Regulation XIII emission reduction credits. This resulted in meeting the 2000 emission reduction targets for all Rule 2202 pollutants. For the 2000 calendar year there were 113 worksites affecting 34,929 employees. The emission reduction targets and the emission reductions from funded projects are summarized in Table 3.

Table 3. AQIP - Emission Reductions
(January 1, 2000 - December 31, 2000)
 

Outreach

Purpose

When the Board adopted Rule 2202, it was anticipated that there was a need to streamline some of the historically-offered transportation training programs. The following is a summary of outreach efforts that have been made in the form of training, workshops, and meetings designed to meet the needs of the regulated community and other interested parties.

Employee Transportation Coordinator Training

Employers choosing to implement ECRP under Rule 2202 are required to designate an ETC who is responsible for developing, implementing, monitoring, and marketing an ECRP to their employees. The designated ETC is required to attend a one-time 16-hour, AQMD certified training course that discusses the implementation of a trip reduction program, plan submittal and a review of Rule 2202.

Previously the training program was outsourced to training contractors with the last training contract ending on December 31, 1999. In February 2000, the Board directed staff to conduct the Rule 2202 ETC Training rather than contracting for this service. Subsequently, the first training was held March 1-2, 2000 and continues on a monthly basis. A total of 15 classes were held beginning March 1, 2000 through December 6, 2000. Eight classes were held at the AQMD with the remaining offered at various locations throughout the Basin. During this period 292 persons were trained and certified.

Quarterly Informational Sessions

In addition to the ETC Training, Transportation Programs staff conducts Quarterly Informational Sessions to provide the regulated community and its affiliates the most current information on the status of Rule implementation and showcase the most successful strategies being used by employers to meet the requirements of the Rule. Employers are also given an opportunity to discuss strategies that improve their programs, clarification of rule requirements, assistance in program development, and answers to any technical or policy questions they may have.

Transportation Programs Internet Page

The Transportation Programs Internet Website has enabled the public and the regulated community to access and download information (rules, reports, workshop notices, RFPs, etc.) previously available only on paper. Electronic posting of these materials provides quicker, more comprehensive access to program information and has assisted in the efforts to reduce the need for printing or mailing various documents. The Website also provides an easily available point of access for the public to ask questions or request information from the Transportation Programs staff. The Website has provided an additional outlet for providing information in a timely manner to the regulated public. The Web site has received favorable response from users who have encouraged the continued support of this program as a real-time source of Transportation Programs documents and announcements.

AQIP Assistance

As part of the AQIP program, staff has continued their effort to elicit proposals for possible funding. Program opportunity notices are sent to all interested individuals and to all companies in the Rule 2202 database. The general public is noticed through ads in newspapers. Potential bidders are identified through the Los Angeles County MTA and the Caltrans Directories of Certified Minority, Women, Disadvantaged and Disabled Veterans Business Enterprises; the Inland Area Opportunity Pages Ethnic/Women Business & Professional Directory; the AQMD's listing of certified minority vendors; and the AQMD purchasing mailing list. Copies of the request for proposals are mailed to the Black and Latino Legislative Caucuses and various minority chambers of commerce and business associations. Information regarding the AQIP can also be found on the AQMD's Internet Website [http://www.aqmd.gov, "Transportation Programs" icon].

Staff holds quarterly bidders' conferences in order to inform prospective bidders about program details. Additionally, staff routinely meets with prospective bidders to review draft proposals and advise prospective bidders of missing information and other sources of information or funding that would be appropriate for inclusion in their proposals.

The estimated AQIP dollar amount and emissions targets are posted on the AQMD’s Website one week prior to the bid submittal deadline to give prospective bidders the most recent information available upon which to base their bid. All bidders who have attended the quarterly bidders' conference are also faxed the same information. Staff makes every effort to insure that bidders have the best information available to produce quality proposals.

Transportation Consultants/Transportation Management Associations/Employers Roundtable

Transportation Programs staff works cooperatively with Transportation Consultants, Transportation Management Associations (TMA), and several multi-site employers, and hosts regular meetings to provide updated information on AQMD programs and activities.

Employee Rideshare Events

Transportation Programs staff attends and participates in numerous rideshare events throughout the entire Basin.

Compliance Program

A specialized inspection team familiar with the details and history of developing and implementing emission reduction programs carries out Rule 2202 compliance. Compliance review of a worksite may originate as a result of complaints from the public, staff requests, and/or random selection. The compliance activity for Rule 2202 during 2000 resulted in 186 compliance audits, 81 Notices to Comply, and 21 Notices of Violation.

Part of the continuing effort to encourage compliance is the "High AVR No-Fault Audit" program. This program is designed specifically for worksites that have reached or exceeded their target AVR. It is a way of giving recognition to companies implementing successful ECRPs. Companies that pass their audit have their plan-filing fee waived. During the year 2000, 33 companies qualified for the "High AVR No-Fault Audit" incentive program.

An integral part of Rule 2202 is the use of mobile source emission reduction credits from Regulation XVI. This program is instrumental in supplying emission reduction credits to employers for compliance with the various strategies in Rule 2202 and the AQIP. The compliance team has the responsibility to insure that the resulting emission credits are creditable. The review process of Rule 1610 – Old Vehicle Scrapping program elements range from audits of vehicle data records, the tracking of emission credit generations and transactions, to the field monitoring of the visual and functional tests of vehicles entering the program. Continued field enforcement of the vehicle intake process has resulted in the audit of 100% of all vehicles. Compliance staff reviewed the processing of 3,128 vehicles during 2000.

Conclusion

This status report for Rule 2202 - On-Road Motor Vehicle Mitigation Options discusses recent program activity in the areas of operations, outreach, and compliance. The implementation and effectiveness of Rule 2202 is dependent upon the combined efforts of AQMD staff in all of these activities.

Rule 2202 has continued to make strides toward reducing mobile source emissions through the combined use of alternative emission reduction programs, traditional trip reduction programs, the AQIP, and compliance auditing.

Program efforts to reach the regulated community have been further augmented by having a Transportation Programs Web site. Through the combined efforts of staff, information regarding the Rule 2202 options and other programs, technical assistance continues to be accessible and available in a timely manner.

This success has been achieved by giving added flexibility to employers through multiple compliance options, reducing administrative costs, and providing greater accessibility to information.

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