Under the Clean Air Act, the Houston-Galveston area has been designated a nonattainment area for ozone, a pollutant created by two other types of air pollution: volatile organic compounds (VOCs) and nitrogen oxides (NOx).
The extent of Houston-Galveston’s nonattainment suggests that area regulators will have to implement a large number of strategies to reach compliance. But there are many possible pathways that lead to compliance, and the draft State Implementation Plan for Houston-Galveston is peppered with measures that have a history of weak performance and inefficiency.
Conventional regulatory control measures and mandatory behavioral control measures including construction bans, specialized fuel requirements, burdensome inspection programs, traditional permit systems, and other control-based approaches have been shown to lack flexibility, efficiency, and effectiveness, while also igniting social conflict.
Market-oriented strategies, by contrast, allow for flexibility in implementation, provide incentives for cooperation, and help reduce some administrative burdens when compared to conventional approaches. This study describes nearly three-dozen market-oriented or flexible strategies that show promise for assisting the Houston-Galveston area in reaching attainment.
Policymakers in the Houston-Galveston nonattainment area should consider the following:
- Vehicle Emissions Pricing is a process in which vehicle registration fees are based upon the level of emissions from the vehicle and annual distances driven. Variations on this theme include strategies to shift fixed-cost fees associated with vehicle ownership to mileage-based fees, providing some (albeit imperfect) connection between registration fees and pollution-generating activity.
- Emissions Trading reduces emissions from stationary sources, usually within a single industry and pertaining to a specific pollutant, by setting an overall emission cap for an entire area and allowing sources to trade emission credits based upon the costs and benefits as determined by each source. Some trading systems also allow for the generation of credits through mobile source reductions at facilities or in transportation fleets. These strategies help by limiting pollution and providing incentives to adopt cleaner technologies on an accelerated schedule.
- Alternative Permitting Approaches move away from the bean-counting approach of permitting each piece of polluting equipment by establishing facility-wide or even industry-wide emission limits and performance standards for specific industries or companies, thereby allowing them to meet the limits in cost-effective ways or buy and sell, rather than just trade, emission credits. Such alternative strategies have produced great success in several states, including New Jersey, Massachusetts, and Mississippi.
- Incentives for Adopting New Technologies (or removal of tax and regulatory barriers to introducing new technologies) can help accelerate the adoption of lower-polluting technologies, replace or retrofit high-polluting fleets, and provide incentives for improved operation of vehicles. Incorporating emission budgets or incentives into construction contracts, for example, could provide incentives for advancing vehicle turnover and off-road engine turnover or retrofit with newer technologies, reducing emissions. A wide range of mechanisms is available, and many have shown promise in other locations.
- Incentives or Pricing of Road Usage, including market-based HOV lanes or toll lanes, and time of day road (and parking) pricing can also be very effective in reducing emissions.
- More Efficient and Discerning Methods for Inspection and Maintenance Procedures can maintain improved emission levels at lower costs. Using new technology to find non-complying vehicles on the road, and focusing inspection efforts on that segment of vehicles expected to have higher emissions, or allowing emission check exemptions for newer vehicles can provide greatest benefit at lower administrative cost and lower inconvenience to (relative) non-polluters.
- Voluntary Employer Incentives Can Encourage Employees to Use Alternatives to Commuting, including parking cash-outs, tax incentives, and creative tradeoffs in benefits packages. Such approaches have performed well in other locations and provide incentives in the private sector and at needed times of day. Incentives can also be provided that encourage the viability of private automobile-sharing cooperatives that help make it practical to avoid automobile ownership for many.
Innovative market-oriented strategies should be among the most prominent strategies considered as regulators develop methods to reach attainment in the Houston-Galveston area. These approaches reduce emissions in a more efficient, equitable, and cost-effective manner than conventional command-and-control approaches.
Innovative strategies can increase compliance and help reduce the need for enforcement because they tend to be more self-enforcing. They allow and encourage flexibility and creativity in reducing emissions and reaching goals. Yet they do not impede the later introduction of other strategies if sufficient progress toward attainment is not met. Most importantly, market strategies can reduce overall costs of achieving attainment goals.
Table of Contents
Ground-level ozone is produced from a combination of nitrogen oxides (NOx), volatile organic compounds (VOCs), sunlight, heat, and other weather conditions. Since heat and sunlight play pivotal roles in the formation of ozone, May through September is designated as "ozone season." Controlling ozone formation is complicated because:
- NOx and VOCs come from a broad variety of sources;
- The climactic and geographic conditions contributing to ozone formation cannot be controlled; and
- The reaction produced by the above components varies with their proportions in the mixture.
A small quantity of NOx is generated by a variety of natural sources, such as lightning, volcanic activity, and soil microbes. However, most NOx sources are manmade, released as emissions from both stationary and mobile sources. VOCs are released from both organic sources, such as foliage, and human sources, such as industrial solvents.
For those areas that have ozone concentrations in excess of federal standards, the U.S. Environmental Protection Agency (EPA) requires the submittal of a State Implementation Plan (SIP), containing a list of proposed strategies addressing on-road and off-road mobile sources, and point-source strategies sufficient to reduce emissions to acceptable levels.
The eight-county Houston-Galveston area was designated a nonattainment area for exceeding ozone pollutant standards, was labeled "Severe II," and given a timetable of the year 2007 to reach attainment. A state implementation plan (SIP) was submitted to the EPA, providing structure and strategies for reducing emissions and reaching compliance.
While the Houston-Galveston area meets federal standards for sulfur dioxide, carbon monoxide, nitrogen dioxide, some classes of particulate matter, and lead, the Houston area exceeds federal standards in the emissions of volatile organic compounds (VOCs), compounds that contribute to the formation of ozone. The Clean Air Act requires a 15 percent reduction in these emissions from 1990 levels. The Houston-Galveston area also exceeds federal standards for nitrogen oxides (NOx), which are also ozone precursors.
While reducing the levels of VOC in the Houston-Galveston area would remove some ozone precursors, there would still be enough to cause a problem. What determines the extent of ozone formation in Houston-Galveston, then, is NOx.
Table 1 summarizes the situation for VOC and NOx in the Houston-Galveston area. The table shows that the highest percentage of NOx arises from point sources, followed by on-road and off-road generation sources, each of which contributes a substantial share to the overall NOx problems in the Houston-Galveston area.
(In Tons Per Day (TPD))
Source: Texas Natural Resource Conservation Commission, Houston/Galveston Nonattainment Area, tnrcc.state.tx.usairaqpeirsumhg.htm
1990 Base Case
|1990 Base Case Emissions|
|1999 SIP Budget for 2000|
Table 2 summarizes the highway emission problems in the Houston-Galveston area, and Table 3 shows the distribution of emissions for off-road construction equipment. As the tables show, Houston’s NOx problems are roughly half generated by stationary, or "point" sources, and half by mobile sources, both on- and off-road.
Source: U.S. EPA Region 6, personal communication to Lisa Skumatz from Guy Donaldson, 3/17/2000.
A variety of conventional strategies have been proposed to address Houston’s air-emission problems. These include:
- Permitting strategies;
- Land use or sprawl controls;
- Emission caps and budgets;
- Demand management and commuter alternatives;
- Incentives, pricing, and trading strategies;
- Reformulated fuels;
- Bans and Limits; and
- Inspection and maintenance, and others.
The elements listed in the proposed Houston-Galveston State Implementation Plan might well bring the area into compliance with federal standards. However, research suggests that several of these measures perform poorly in the real world, carry significant negative impacts, and would be better replaced with innovative alternative approaches to reducing emissions.
Negative impacts include significant infringement on individual autonomy and lifestyle choice; increased costs for energy, goods, and services; regional impacts on employment, economic competitiveness, and productivity; poor allocation of public health and environmental agency resources; and lost opportunities to address other social and environmental problems through resource misdirection.
Theory and experience suggest that innovative and market-oriented approaches could provide equal or better environmental performance, while causing less negative impacts.
Historically, the conventional agency approach to stationary-source control has centered on the issuance and enforcement of permits. In a permitting approach, various pieces of equipment (such as boilers, incinerators, etc.) are individually permitted based on the emissions they produce. Installation of new equipment or changes in equipment require a permit revision or new permit applications. Permit-oriented controls identified in the Houston-Galveston SIP include, for example, the requirement for Reasonably Available Control Technology (RACT) on all stationary source equipment inside the Houston-Galveston area.
However, research suggests that several of these measures perform poorly in the real world, carry significant negative impacts, and would be better replaced with innovative alternative approaches to reducing emissions.
But the permit-based approach has many problems, not the least of which is a tendency for permits to proliferate. As previous studies have documented, permit-based approaches suffer from three major problems:
- Permits focus on compliance, not performance. Permits regulate equipment and are merely a proxy for environmental improvement. While businesses are lost in the shuffle of paperwork and worried about compliance, they are less able to focus on how to best achieve actual emission reductions. Narrowly highlighting certain procedures or equipment isolates firms from the greater goal of environmental protection and deflects attention from pollution prevention and environmental innovation. On the agency side, permit writing and enforcement become ends in themselves, utilized for raising funds for the department or to track the success of a particular agency. Compliance, not performance, becomes the main focus for both the regulator and the regulated community.
- Permit programs are difficult to reform. Permits create constituencies with a vested interest in their continuance, and reform becomes a very difficult exercise. The pressures against reform come from many sides as well, including the environmental protection agencies and the businesses they regulate. In order to implement permits, permit-writers are trained in specific media, focusing their energies on air, water, or waste permits. They are well acquainted with their work and have standard operating procedures for performing their duties. Any perceived change to these procedures may be strenuously resisted. Businesses that must comply with these permits can also prove an obstacle to reform, as they may fear the uncertainties that come with change.
- Permit programs create adversarial relationships with the regulated. The nature of the permitting process, the amount of paperwork that must be collected, and the need to obtain separate permits for each medium or process has fostered an adversarial relationship between businesses and governments. The first problem with the centralized nature of the permit system (especially in the case of federal regulations) is that the regulated and the regulators have little face-to-face contact. Little allowance is made for local conditions and/or extenuating circumstances, and businesses are forced into the preconceived mold of regulation by a distant agency. Permit writers tend to develop a skewed view of industry as well, seeing them in person only when there has been a violation. Suspicion and mistrust breed in this atmosphere.
Innovative permit approaches offer considerably greater promise than conventional permit-based approaches. Successful permit-reform programs have taken place in Massachusetts, New Jersey, and Mississippi. Each case illustrates the benefits of innovative approaches:
- Massachusetts. In Massachusetts, an excessive focus on permits led to a virtual collapse of agency resources. In 1996, the agency found itself administering no less than 16,000 individual permits. Although these permits covered equipment or processes in 10,000 companies, they only accounted for 5 percent of the state's total air pollution sources. The answer in Massachusetts was a switch from command-and-control permitting to industry-wide performance standards that applied to all applicable processes at all company facilities within a given sector. Results of the pilot project were startling. While most initial requests for participation in regulatory reforms had hovered around 30 percent to 35 percent, the Massachusetts "ERP," as it was called, received an 85 percent response rate. Moreover, 80 percent of all received applications were accurate, setting another record in Massachusetts’s regulatory history. Most importantly, compliance rates shot up. Under the ERP, the overall compliance rate of participating firms rose from 33 percent in spring 1996 to 78 percent in spring 1997. Furthermore, twelve of the eighteen firms involved in the pilot project reported a positive impact on their ability to implement pollution-prevention programs, and seven of the companies reported that compliance costs under the new regime were "insignificant," which was not previously the case under permit-based regulation.
- New Jersey. In New Jersey, excessive focus on permits had led to an anti-business climate that was described as "second only to California on a list of where not to manufacture chemicals in the U.S." Companies relocated to the South or out of the United States in order to escape the adverse business climate that the permit regimes had created. Manufacturing in New Jersey declined by 30 percent in the 1980s as compared to the 1970s, with the chemical industry alone losing 1,600 jobs in 1993. At its height, the New Jersey Department of Environmental Protection had more than 4,000 employees, more than three times the number of employees in the U.S. Department of Education, and more than half the number of the U.S. Department of the Treasury. The permit process involved long delays in issuing permits, spiraling costs, and uncertainty about the standards for compliance. This climate had the exact opposite effect of what was intended, as industry critics pointed out that the permit-approval process frequently delayed manufacturers from getting pollution-control equipment into service. The innovative answer in New Jersey was the adoption of facility-wide permits, a process begun in 1995. Under facility-wide permitting, the average time for permit processing dropped from 18 months to two months; 69 percent of the companies using a facility-wide permit predicted net cost savings because of the process; the average net benefit to the facilities was $6.3 million per year; and for every dollar spent in the process, there was a net savings of $5 to $8.
- Mississippi. In Mississippi, the problem with a permit-based approach was twofold. First, its fragmentary nature required separate and frequently redundant paperwork to be filed according to whether emissions were air, water, or soil. These single-medium permits were difficult for industries to track and comply with, and often led to the shifting of emissions from one medium to another, in a process described as "a regulatory shell game." A typical facility, furthermore, might have to work with six or seven separate permit writers within different media divisions, and an average of four permits was required for a facility. If public notice were required for a permit, the process could last over 120 days. Tracking permits was also a problem for Mississippi's Department of Environmental Quality, which, because of budget shortfalls, had to stop regulating 3,000 smaller wastewater dischargers and had to quit regulating smaller air emissions sources. In the face of these difficulties, Mississippi's Department of Environmental Quality is in the process of re-engineering itself, with a key component being a "one-stop" permit process that would cover all media for a given facility, and assign one "Permit Manager" to work with a given facility. Though the Mississippi approach faces challenges from both the EPA and environmental advocacy groups, and the program is still being built, the flexibility and benefits of such an approach seem promising.
Rather than implementing conventional permit-based approaches, the Houston-Galveston nonattainment area should consider several of the innovative permitting approaches described above, and listed in Tables 4-6, including facility-wide permitting, and industry-wide emission standards.
One strategy proposed as a way to reduce driving, and therefore, pollution, is growth management and control over land use, though studies suggest that these measures are themselves problematic.
The main focus of such strategies involves shortening and reducing vehicle trips or making mass transit very convenient. Some methods include guidelines about reducing cul-de-sacs that do not intersect with other streets (and therefore require "in" and "out" trips rather than connections), growth restrictions, and other strategies. Chicago and Portland have been active in growth management and land-use strategies; credit guidelines are being examined in California.
However, these strategies have significant drawbacks and may not be advisable for Houston:
- Growth management strategies do not provide immediate benefits. Rather, their benefits are realized 20 years out. This is not a time frame compatible with Houston’s situation. Further, the strategy significantly affects growth and development for a problem that occurs six hours a day.
- Based on the progress from the last 20 years in air quality, in that same 20-year horizon, technological changes in transportation are likely to have achieved the same or additional benefits at lower cost and without the social aspects of this type of social planning.
- These types of strategies seem ill suited to application in areas with different lifestyle priorities and resident characteristics that focus on decentralized living—including Texas.
Land-use strategies have functions beyond air quality—including maintaining urban cores, ensuring land-use diversity, maintaining green space, or other reasons. However, the near-term impacts in air emissions are minimal, so a case for land use strategies to achieve emission goals is weak.
Rather than implementing growth-management or land-use policies with known failings and little air-pollution-reduction power, the Houston-Galveston nonattainment area would benefit more from considering alternative strategies to promote alternative commuting. Providing and maintaining pedestrian walkways in cul-de-sac areas to allow pedestrians to easily walk through to buses and transit options (or commercial areas) on other streets is one such strategy that the Houston-Galveston nonattainment area might implement.
Two types of large-scale economic incentives that can produce emission reductions include emissions trading and emission fees. Both use an economic mechanism (using "price" to influence behavior) to reduce stationary source emissions, and once the environmental goal is set, can help achieve that goal at a lower social cost than mandatory reductions or command-and-control measures. Emission-trading regimes go beyond simply applying a flat economic pressure, however, and actively use market forces to find the lowest-cost emissions reductions within a boundary area.
Generally, these programs have the goal of reducing emissions, with their designs reflecting targets for certain times of day and certain types of emissions. The prices or limits are effective in providing incentives to achieve faster turnover of older equipment or more rapid adoption of new technologies. Of course, these strategies require monitoring of compliance and enforcement like other environmental regulatory approaches.
Rather than implementing growth-management or land-use policies with known failings and little air-pollution-reduction power, the Houston-Galveston nonattainment area would benefit more from considering alternative strategies to promote alternative commuting.
Historically, emissions fees have been less frequently implemented, largely for four key reasons:
- Emission fees are often viewed as taxes, particularly when revenue neutrality is not vigorously preserved;
- Fees perceived as taxes are generally less politically palatable;
- Emission-trading credits are more easily related to quantitative amounts of pollutants; and
- Emission fee levels may be harder to set properly to achieve the desired objective.
For these reasons, our discussion will focus on emissions-trading schemes. Emissions trading works like this: within a polluted area, a "cap" is established for a given pollutant (such as NOx or VOC), a reduction in that cap over a specified time is established, and credits are issued to existing businesses according to their emissions based on a baseline inventory. Usually, the cap is lowered periodically for facilities in the emissions-control area.
Some businesses will be able to generate emissions reductions meeting or exceeding the required reduction economically, while others, at the point of diminishing returns on emissions-control equipment, might not be able to reduce emissions enough to meet the reduction target. In order to continue operating, those businesses must buy surplus emission credits from others. The same holds for businesses that wish to expand, and for new businesses starting up.
The end result is that incentives are created for each facility to reduce emissions as far as possible. Those capable of generating surplus emissions credits can turn them into profit, while those who cannot may stay in business by buying emissions until new technology appears to let them reduce their emissions cost-effectively. The ever-increasing cost of credit acquisition in a shrinking market ensures that such facilities will not wait too long before installing new emissions-control equipment in order to end the required purchase of credits.
Emissions-trading programs have been used nationally with considerable success in the case of sulfur dioxide trading among electric utilities. In Los Angeles, a similar cap was established for VOC reductions.Emissions-trading programs might offer the Houston-Galveston region a chance at achieving emissions reductions while minimizing economic dislocation, and certainly warrant modeling and consideration for SIP inclusion as a replacement for less-effective measures.
The relative balance between NOx and VOC problems, and their ultimate contributions to ozone development varies across the eight-county Houston-Galveston area. Further, they can vary by region, time of day, and season, complicating the forecasts of patterns of ozone creation and the development of solutions for the Houston-Galveston air quality problems. These variations must also be taken into account in designing trading schemes if equitable and effective solutions are to be developed.
Finally, trading schemes depend crucially on a regulatory component. Without clear, measurable caps and enforcement, trading schemes will not be successful. Although environmental justice considerations have reduced enthusiasm for trading in some areas, and trading strategies are not always the panacea, they provide opportunities for reducing pollution at lower social cost.
Rather than emission fees, or similar levies, policymakers in the Houston-Galveston area should first consider emission-trading programs; emission budgets, quotas, or incentives embedded in construction contracts; and emission trading for off-road equipment based on equipment type and time of day.
Emissions-trading programs have been used nationally with considerable success in the case of sulfur dioxide trading among electric utilities.
As analysts have shown in numerous reports, behavioral transportation control measures (TCM), transportation demand management (TDM) programs, and commuter alternative programs have serious limitations. These programs are:
- Largely Ineffective. The biggest problem with vanpool, rideshare, and park-and-ride transit programs is that few people find them a suitable alternative to individual mobility. In most households, transportation flexibility has become a critical element in maintaining quality of life, in going to work, taking children to school, shopping, socializing, and so on. Trip chaining, the linking of trips that serve personal and work needs, is also increasingly important in people's transportation choices. Consequently, programs reliant on changing people’s driving behavior produce little benefit. Employer rideshare programs in California, for example, were found to produce less than a 1 percent reduction in vehicle miles traveled, less than a 1 percent reduction in trips taken, and less than a 1 percent reduction in hydrocarbon emissions.
- Poorly Targeted. Since most TCM and TDM strategies focus on commuter trips, they can only affect a relatively small percentage of the overall transportation-related emissions. Based on experience in Los Angeles, studies show that work trips to major employment sites (of 100 or more employees) only account for about 40 percent of total work-related travel. Work-related travel, in turn, only represents approximately 26 percent of all trips and 32 percent of vehicle miles traveled on an average annual basis. Thus, programs like vanpooling, park-and-ride lots, and so on can only affect about 10 percent of daily trips, and 13 percent of daily vehicle miles traveled. Full attainment of a 25 percent increase in average vehicle ridership would produce only a 2 to 3 percent reduction in trips, and perhaps a 3 to 4 percent decrease in daily vehicle miles traveled (VMT). These statistics indicate that in Los Angeles (and probably in the Houston-Galveston area), only about 7 percent of ozone precursor emissions come from vehicles used for commuting to and from work.
However, Houston’s air quality problem is severe enough that even strategies that on their face show relatively marginal impacts must be considered seriously. With strong economic incentives for changing commuting patterns, some of these strategies can be a useful part of attainment plan. Innovative alternatives to such measures center on the creation of competitive, market-based, flexible alternatives to solo driving.
Despite the general limitations of this approach, several options show promise, and are included in Tables 4-6 for consideration in the Houston-Galveston area. Particularly promising are several programs that provide strong employer incentives to encourage commuting alternatives. Because they can be applied to many levels of employers, such programs may provide good options for the Houston-Galveston area:
- Federal Activity in Employer Incentives. There has been considerable activity at the federal and state levels, with several Eastern states adopting measures to encourage commuting alternatives. The Federal Transportation Equity Act for the 21st Century encourages commuter choice, and employers can offer employees a choice of pre-tax salaries or pay the cost of transit up to $65 without tax implications as qualified benefits. Another provision allows for employers to offer cash in lieu of employer-provided parking spaces up to a maximum of $175 per month, which is viewed as additional income to the employee. These benefits can be compounded, and the parking "cash out" can apply to teleworkers.
- State Activity in Employer Incentives. Maryland has inaugurated a 50 percent tax credit to employers that pay the cost for employee transit passes (up to $60/month), and these benefits can be taken in combination with the federal incentives. The benefits can be taken against income, franchise, or insurance premium taxes in the state to exempt the employer from withholding tax on these benefits, to improve the level of accountability, and to assure that the benefit and paper trail is with the employer, not the employee. Maryland is also working to expand the credit to guarantee emergency rides home, a program that evidence indicates has not been abused. California has parking cash out provisions: one in eight employees took advantage of the program, and transit ridership reportedly doubled, car- and vanpooling increased, as did other alternatives. Washington offers a $60 per year employee credit (which also applies to walking or biking). Other states are working on telework tax credits, accelerated depreciation on home office equipment, and other strategies to encourage nontraditional commuting. New Jersey has an employer trip-reduction emission-credit program through which employers submit a three-page plan outlining their trip reduction plans. This program provides emission credits, which can be bought and sold.
The biggest problem with vanpool, rideshare, and park-and-ride transit programs is that few people find them a suitable alternative to individual mobility.
A number of other alternatives to traditional SOV driving are also showing promise in other parts of the nation and internationally:
- Rubber-tire Transit. Rather than focus on the expansion of costly rail systems with low carrying capacity, areas seeking to create attractive alternatives to single-occupant driving would do well to explore the potential of rubber tire transit: expanded bus services running along dedicated busways, through bus tunnels, and along rights-of-way now used by or reserved for light rail systems. Studies have repeatedly shown that such rubber tire systems can outperform rail in terms of cost, number of passengers carried, speed of travel and flexibility.
- Private Shuttle Van System. Beyond expansion of public bus systems, research by Reason Public Policy Institute (Reason Public Policy Institute ) has explored the promise of a decentralized, on-demand network of private shuttle vans as a means of reducing solo driving. A network of such shuttles, operating over a highway system featuring high-occupancy vehicle (HOV) or toll lanes (HOT) would be more likely to produce an increase in average vehicle occupancy than any number of other traditional transportation control measures or mass transit systems. This system, or systems like it, are in use both in foreign countries, and have been used successfully here in the United States. Examples include the jitney system of Atlantic City, and the more limited airport shuttle services which have exploded since their introduction in the early 1980s.
- Automobile Sharing Programs. Several private firms have begun to offer automobile-sharing arrangements that provide ways to maintain the convenience of driving at lower costs than owning a private vehicle. In Switzerland, Canada, and several places in the United States (San Francisco, Seattle, Portland), companies maintain a fleet of automobiles dispersed in garages in neighborhoods throughout the city. Members can reserve use of the car at reservation centers or through the Internet, and a special credit card gives them access to the garage and car. The firms advertise that the use of the automobiles provides convenience at half the cost of owning an automobile; the economics for the Swiss program demonstrated savings for drivers traveling less than 7,000 miles per year. The firms are growing quickly (the Swiss program grew 50 percent the first year and 30 percent the second year). The market has grown beyond environmental consumers because of the convenience and demonstrated cost savings. The programs are called BART station car and City Car Share in San Francisco, Flexco/Flexcar in Seattle, CarSharing Portland in Portland, Mobility CarSharing in Switzerland, and other names elsewhere.
Though too often applied poorly, employer incentives, commuter alternatives, and pricing incentives to encourage nontraditional commuting offer benefits in changing the overall economics associated with commuting. Policymakers in the Houston-Galveston area should consider employer tax incentives or credit programs for encouraging telecommuting or commuter alternatives; incentives or removal of regulatory impediments for automobile-sharing companies or cooperatives; market-based shuttle van transit systems; or limiting or shifting hours for government workers.
Employer incentives, commuter alternatives, and pricing incentives to encourage non-traditional commuting offer benefits in changing the economics associated with commuting.
Economic strategies—pricing and incentives—can be effective in encouraging adoption of different technologies or activities more rapidly than they may have been adopted otherwise. Well-designed strategies can help reflect costs that are not commonly reflected in market prices, including environmental considerations and other externalities. These types of incentives can help adjust decision-making toward socially preferable solutions.
However, although theoretically very powerful and equitable, there are some concerns associated with implementing economic strategies. These include:
- There is often a lack of political will to implement economic instruments or adopt serious measures to avert air impacts;
- Sometimes the illusion of progress is given when, actually, measures are only being debated, not sincerely implemented;
- Governments sometimes find ways to undermine permits and economic strategies through special exceptions;
- Economics may not always represent the best overall strategy; other disciplines and priorities should also be considered in decision-making; and
- Economic instruments can sometimes disadvantage the poor, and "middle class" activities may not change at all (e.g., they will continue to buy and drive higher-polluting vehicles).
However, if these difficulties can be avoided, economic strategies provide benefits at lower social cost and help preserve choice and creativity in developing solutions to problems. Economics can provide a constant pocketbook reminder about tradeoffs. In addition, economic strategies can help get past barriers and bring in pricing to try to account for or internalize negative impacts on the environment.
Effective strategies could work to affect driving patterns through:
- Increasing the variable cost of driving (and reducing the fixed costs) through strategies like reformulating vehicle fees or insurance to a cost-per-mile;
- Increasing the costs of driving single-occupancy vehicles or reducing the relative costs of high-occupancy vehicles;
- Peak-period pricing to better reflect the total costs of driving at particular times of day or year; and
- Differential fees to reflect the fact that some vehicles contribute more to the emissions problems than others—either higher polluting vehicles or those that are driven more.
Economics can provide a constant pocketbook reminder about tradeoffs.
An enhancement on these strategies would be to provide incentives through tradable credits that could apply to emission budgets or trading schemes.
One example of an economic strategy would be to institute direct emission pricing for automobiles. In such a system, annual vehicle registration fees would be based on a combination of distances driven and the emission characteristics of the vehicle. Such pricing would create incentives both to limit needless travel and for the purchase of lower-emitting vehicles. Economists have studied vehicle-emission pricing and shown it to be a promising approach to air pollution, which ties individual choice to individual consequences. Researchers at Resources for the Future found that "even under uncertainty, fees are more efficient than the command and control policy." An EPA guide for the implementation of such a program is already in print.
A report prepared for the EPA by consulting groups ICF Incorporated and Apogee Incorporated used information from numerous studies to assemble a summary of the effects of various transportation-pricing measures on travel demand and emissions. The report mentioned the following strategies and impacts:
- Employee Parking Fees. Increases of $1.35 to $2.75/day in short- and long-term parking fees were effective at decreasing vehicle miles traveled (VMT) to worksites between 12 and 39 percent, and decreased single occupancy vehicles (SOV) by 66 percent to 81 percent.
- Differential Parking Fees. Strategies that increased SOV parking from $1.60 to $5 per day or decreased HOV rates up to $2 per day (or provided $42 transit subsidies) were effective in achieving 19 to 31 percent reductions in vehicle trips community-wide.
- Fuel Taxes. Surcharges from $0.40 to $2 per gallon led to a 1 to 7 percent decrease in VMT, trips, VOC, CO and NOx, and a 1.4 to 25.7 percent decrease in carbon dioxide.
- Emissions Fees That Vary by Vehicle Efficiency. Surcharges of one cent to five cents per highway mile led to decreases of 2 to 7 percent in VMT; 2 to 12 percent in peak period vehicle hours traveled; 8 to 37 percent in daily VOC, 4 to 17 percent in daily NOx; 8 to 20 percent in daily carbon monoxide; and 3 to 7 percent in daily PM10.
- Emissions Fees That Vary by Vehicle Miles Traveled. Fees of $200 to $1,200 per year per vehicle led to reductions of 1 to 7 percent in trips, 14 to 37 percent in VOC, 13 to 35 percent in carbon monoxide, and 5 to 18 percent in Nox.
- At-the-pump Charges Based on Vehicle Miles Traveled. Based on estimates for west coast metropolitan areas, the ICF/Apogee study finds VMT fees of one cent to five cents per mile would lead to decreases of 9.3 to 11 percent in VMT, 8.6 percent in trips (10 percent shift to transit), 4.5 to 8.6 percent decrease in carbon monoxide, 4.1 to 9.1 percent decrease in VOCs, 5 to 8.6 percent in NOx, 9.4 percent in carbon dioxide, and 11 percent in PM10.
- Pay-as-you-go Car Insurance. Changing insurance to a per mile fee between 10 cents and 40 cents per gallon led to estimates of a 32 million metric ton/year reduction in carbon emissions.
- Roadway Congestion Pricing Fees. Work by the Puget Sound Regional Council estimated that congestion fees between 5 cents and 30 cents per mile, depending on the level of congestion, time of day, and other factors could lead to the following reductions: 5 to10 percent in peak period VMT, 0 to 2 percent in NOx, 0 to 7 percent in VOC, and 2 to 3 percent in PM10.
Many strategies might work to provide pricing or other signals to promote less driving, use of lower-polluting vehicles, or increased fleet turnover.
Note that in some cases, relatively large surcharges were necessary to effect even minor changes in behavior—transportation choices can be fairly inelastic. However, given that Houston needs to achieve a significant amount of reduction immediately, these strategies show strong promise because they can be achieved quickly—more quickly than larger fleet transformations or widespread adoption of new technologies.
Many strategies might work to provide pricing or other signals to consumers that would alter their choices toward less driving, use of lower-polluting vehicles, or increased fleet turnover. Related strategies were also included under the section on transportation demand management strategies. Before defaulting to command-and-control measures, policymakers in Houston should seriously consider strategies such as:
- Employer tax incentives or credit programs for encouraging telecommuting or commuter alternatives;
- Incentives or removal of regulatory barriers for automobile sharing companies or cooperatives;
- Competitive, private-sector shuttle van transit systems;
- Limitations or shifts of hours for government workers;
- Market-based HOV or toll lanes;
- Time-of-day congestion pricing for roads;
- Time-of-day or congestion parking pricing;
- Emission pricing based on miles driven or emission levels of vehicles (on- and off-road);
- Time-of-day pricing for use of high-emitting vehicles (off-road, construction);
- Mileage-based pricing for insurance or vehicle fees;
- Incentives and pricing at airports;
- Credits for scrapping old automobiles;
- Credits or incentives for vehicle, engine, or fleet replacement, or for adopting alternative fuels (on- and off-road); and
- Credits or incentives for implementing new emission-reducing technologies or infrastructure including:
- Truck-stop electrification
- After-market emission-reduction technologies, or after-market retrofits for heavy duty equipment
- Technologies that reduce cold-start emissions
- Ozone-eating catalysts in vehicles and air conditioners
- Improved gas cans (off-road)
Rather than focus on picking specific fuel formulations, policymakers in Texas non-attainment areas (including Houston-Galveston) should explore innovative ways of fostering a more rapid vehicle fleet turnover.
The saga of California's experimentation with reformulated gasoline will probably become a textbook case of the absence of both a holistic vision and foresight by federal and state environmental planners. Reformulated fuels were mandated over a variety of objections, ranging from estimated high costs to predicted and claimed adverse health impacts of oxygenates. While questions of cost and health impacts are disputed, what is not disputed is the fact that the main oxygenate added to produce California reformulated gasoline (a chemical called MTBE) has created a serious controversy over its potential to cause groundwater pollution. Most importantly, oxygenates such as MTBE seem to have little effect upon urban air quality, particularly NOx emissions. In a report by the National Science and Technology Council, MTBE was found to produce a small reduction in carbon monoxide, but reductions in VOC levels were offset by increases in the production of toxic aldehydes, and the more critical NOx emissions were either unchanged, or actually increased with the use of oxygenated fuels.
Rather than focus on picking specific fuel formulations, policymakers in Texas nonattainment areas (including Houston-Galveston) should explore innovative ways of fostering a more rapid vehicle fleet turnover. Super-Ultra Low Emission Vehicles are within two years of the market, and moving them into the vehicle fleet quickly could have a far greater year-round impact on emissions than reformulated fuels, with less chance for unintended health or environmental consequences. Market-based incentives such as reduced vehicle registration fees and sales taxes for fuel-efficient vehicles could encourage the purchase of newer vehicles that put out fewer emissions using conventional gasoline. Several of these strategies are included in our recommendations and are detailed in the sections on economic incentives or elsewhere.
Although mandating changes, such as lower speed limits or limits on construction-hours, often appear to provide direct and immediate benefits at costs that seem no higher than the cost of the paper to print them, the experience from these types of strategies is less convincing.
Expensive enforcement agencies and procedures are needed;
- Many would argue that the California experience in improving air quality provided clear lessons that approaches that attempt to change people's behavior rarely work;
- Such measures are usually divisive and are more expensive than options that allow flexibility in achieving objectives (e.g., market-based strategies); and
- They expose what should be a transparent and objective air quality protection process to accusations of social engineering.
A speed-limit reduction policy constitutes one such type of policy to effect behavioral change, which, besides being likely to spark social discord, is based on questionable assumptions about the relationship between vehicle acceleration and emissions. While the effect of reducing the speed limit might be a small NOx reduction in certain vehicles, the overall impact of slowing the flow of traffic will keep all vehicles running longer, as more time will be needed to complete a trip. It is not clear that current models of emissions are a function of speed, and the overall impact of speed reductions on the total vehicle fleet of both light and heavy-duty vehicles do not adequately capture the complexity of the speed/emissions tradeoff. Such uncertainty constrains sound policymaking, in that it invites unintended adverse consequences, inefficiently utilizes resources, and endangers the public's willingness to accept more reasonable emission-control policies. Moreover, lower speed limits on freeways in the Houston-Galveston area will be very difficult to patrol due to the high volume of traffic. Law enforcement agencies are unlikely to obtain the additional budget funding necessary to this end. Further, the public may be unwilling to allow resources to be transferred from efforts to control serious crime to highway patrol.
Bans on the use of heavy-duty construction/mining diesel equipment during the morning hours represent another behavioral constraint that is likely to trigger significant social discord and quality-of-life impacts through increased costs of construction. Not only can market options provide better, cheaper, and more effective alternatives to the ban; this particular type of ban can lead to other problems, including increases in highway construction costs, traffic congestion, traffic accidents and fatalities, mobile source air pollution, and nighttime noise. In addition, there are questions regarding the models of the air emissions and health gains associated with the strategy, concrete integrity might be affected, and other quality of life and economic impacts would result—making such a ban is questionable on several bases.
Policymakers in Houston might consider several basic strategies of this type where they are not already in place. These include traffic signal synchronization and similar strategies to reduce idling and congestion-related emissions, with signals timed to guide traffic at preferred speeds, and traffic diversion options. During specific periods, the city may need to divert high-emitting diesel vehicles to routes around the city rather than through it.
Inspection and maintenance (I/M) programs embody the idea that some mechanism must be put into place to ensure that light-duty vehicles are kept in non-polluting condition. This basic idea is reasonable. Air pollution from vehicles degrades air quality and may impose potential harm upon other individuals who must breathe polluted air. Therefore, motorists have an obligation not to impose this harm on others. However, the specific mechanisms embodied by traditional I/M program requirements have produced dubious benefits, sometimes at high cost.
Agency claims of high I/M program effectiveness are common. The EPA claims enhanced I/M programs can yield a 28 percent overall emission reduction. California agencies, long considered to be on the "cutting edge" of air pollution control methods, put forward similar claims. The California Air Resources Board has claimed that Smog Check programs in California led to a 25 percent overall reduction in automobile emissions statewide since the late 1980s. The California South Coast Air Quality Management District (SCAQMD) has a more specific breakdown, predicting that enhanced I/M programs will result in a 28 percent reduction in VOCs, a 31 percent reduction in carbon monoxide (CO), and a 9 percent reduction in NOx. Finally, prior to implementation of enhanced I/M in Arizona, the EPA predicted reductions of 35 percent for VOCs and a 7 percent reduction in NOx.
However, benefits from enhanced I/M programs appear to fall far short of earlier predictions. While some studies suggest that enhanced I/M does result in some emission reductions, reductions are as much as 50 percent lower than predicted achievements.
A recent study, examining the effectiveness of California’s enhanced vehicle inspection and maintenance program used data from vehicles which were tested at their regularly scheduled time, and then again before transfer of ownership found that actual emission reductions were only 5 percent for HC and NOx, and 20 percent for CO, up to two months after the regularly scheduled test.
In terms of absolute performance, I/M program effectiveness has been studied by researchers at Resources for the Future (RFF) for the Arizona area. While EPA predicted a 35 percent reduction in VOC, the RFF researchers documented only a 13 percent reduction. EPA predictions were considerably closer to reality for NOx reductions. Where EPA predicted a 7 percent reduction in NOx, the RFF researchers documented an 8 percent reduction.
The low effectiveness of traditional I/M programs has been attributed to several technical phenomena, including inconsistent behavior of vehicle emission-control systems and post-test deterioration of emission control systems or system repairs. Others argue, however, that the biggest obstacles to success of all I/M programs are behavioral, resulting from the misguided incentives inherent in a system that revolves around the necessity of passing an annual (or biennial) test. Such programs generate incentives to "pass the test," but they do not create behavioral incentives for motorists to maintain clean vehicles year-round. As Charles Lave, an economist at the University of California, Irvine, puts it: "Such periodic testing is akin to a program that tries to "control" drunken driving by scheduling drivers for a breathalyzer test every two years." Traditional I/M programs also create incentives for fraudulent actions on the part of emission-test facility personnel, and for tampering.
As Charles Lave, an economist at the University of California, Irvine, puts it: "Such periodic testing is akin to a program that tries to "control" drunken driving by scheduling drivers for a breathalyzer test every two years."
An optimal system for cleaning up on-road vehicles is one that pays attention to incentives for motorists to keep their cars clean. Traditional I/M programs fail to do this, as do conventional enhanced I/M of the sort proposed for the Houston-Galveston area. A better program would focus on identifying and remediating high-polluting vehicles, as well as motivating motorists to invest in enduring repairs.
The Houston-Galveston SIP takes a strong step forward with its proposed implementation of remote sensing and on-board diagnostics to detect high-emitting vehicles. However, an adjunct program that would further refine the focus of inspection and maintenance on the small number of high emitters should be considered. Beyond the identification of high-emitting automobiles, several techniques can be used to identify clean cars, which can subsequently be exempted from annual inspection, thus reducing the load on the planned dynamometer test centers, and saving motorists time and money. Cars less than 6 years old have very low failure rates, and can be exempted from annual testing without fear of missing significant emitters. Remote sensors can also be used to identify clean cars older than 6 years old, and those cars can also be exempted from annual testing. The feasibility of using remote sensors to erect such a "clean-screen" program has been demonstrated in pilot projects in Ontario, Canada; Greeley, Colorado; and Phoenix, Arizona.
Focusing only on identifying the high-polluting vehicles would allow more attention to be paid to actually repairing these cars. Classification as an extreme emitter should be based on the relative contribution to the pollution problem, not through reference to a vehicle's variance from its ideal lowest-emission state. There is, of course, no "bright line" that determines what vehicles should qualify as extreme emitters. In part, setting the extreme-emitter cut-off point would depend upon how much emission reduction one was attempting to achieve and which universe of vehicles was likely to actually be repairable. Also, such cut-offs might be revised over time as vehicles become cleaner and cleaner, should continued mobile-source emission-reductions be necessary.
Policymakers should consider several alternatives to traditionally implemented enhanced inspection and maintenance for Houston. These alternatives include clean-screening and high-emitter detection with remote sensing; emission check buy-out; and an air quality improvement program, allowing polluters to pay into a fund used to reduce pollution elsewhere.
Stationary Sources: Table 4 lists and outlines market-oriented stationary source measures which can help the Houston-Galveston area achieve emission reductions effectively and efficiently while avoiding approaches that tend to be punitive, inflexible, and inefficient, such as specific equipment permitting and specific technology mandates.
Mobile Sources: Tables 5 and 6 list and outline the market-oriented and innovative measures that can help the Houston-Galveston area achieve emission reductions efficiently and effectively while avoiding conventional mobile source approaches that have many well-known limitations, such as mass transit, centralized vehicle inspection and maintenance, mandatory employer rideshare programs, mandated fuel substitutions or reformulation, vehicle technology standards, etc. Instead, Houston should promote more innovative approaches, designed to speed fleet turnover and adoption of new technologies or lower-polluting operations, encourage alternatives, and improve efficiencies of regulations. These are outlined below. Table 5 addresses strategies for on-road sources; Table 6 summarizes strategies for off-road emissions.
|Facility-wide permitting||In facility-wide permitting, the regulatory focus is on the total emissions of a facility, rather than individual pieces of equipment. The New Jersey Department of Environmental Protection introduced facility-wide permitting in 1995, producing environmental benefits while giving facilities the flexibility they need to comply with environmental regulations and provide environmental protection while remaining competitive.||New Jersey|
|Industry-wide emission standards||Industry-wide emission standards apply the facility-wide permitting model to entire industries. Rather than setting emission caps individually for each facility, industry-wide emission standards replace equipment permitting for an entire industry. Industry-wide emission standards have been successfully demonstrated in Massachusetts, where the Environmental Results Program showed that industry-wide permitting could produce greater compliance and greater environmental benefits than the traditional approach to piecemeal permitting.||Massachu-setts|
|Emission-trading programs||In emission-trading programs such as the national SO2 trading program, or the RECLAIM VOC (volatile organic compound) trading program, an emission cap is established over an area, emission rights are established, and a system is designed to allow trading in those emission rights between firms within the capped area. California’s Bay Area Air Quality Management District has also implemented an emission pricing regime, allowing trading in Bay Area Emission Reduction Credits. One relatively untapped option would allow trades between mobile and stationary sources, for example, through automobile repair-assistance or scrappage trading programs.||California Air Quality Manage-ment District
|Self-audit and cleanup incentives||Another approach to attaining better environmental performance is to encourage firms to voluntarily adopt environmental management and information programs, such as the ISO 9000 standards, the CERES principles, the GEMI principles, and others. Such an approach has been adopted in Oregon, with the Green Permits/Environmental Management Systems Incentives Project (EMSIP). One other example is the CMA Responsible Care initiative.||Oregon|
|Incentives for retrofit of gener-ators for peak power units||There have been demonstration projects that show potential to reduce NOx emissions for diesel applications including generators. This includes SCR (selective catalytic reduction) strategies for peak power generators, and are available for new and retrofit models.|
|Broad-based energy and resource- efficiency programs||In Toronto, they have adopted a Greenhouse Gas (GHG) Pilot Trade program that provides credits for an array of energy and resource conserving activities that help reduce energy use and thus power production and emissions. Credits are provided for efficient street lighting, landfill gas recovery, waste reduction and recycling, water conservation, carbon sequestration (tree planting), community greening, building code amendments, bicycle infrastructure, land use for energy efficiency, alternate cooling technologies, and transportation demand management strategies.||Toronto, Ontario, Canada|
|Connected street system or pedestrian pass-throughs||Portland has street design guidelines that require streets to intersect within particular distances and restricts cul-de-sacs (which waste gas by requiring drivers to backtrack out the streets to progress). Where cul-de-sacs and similar developments exist, pedestrian walkways or pass-throughs are encouraged to assure pedestrians can use short cuts to get to mass transit or shopping areas. Oregon has other sprawl strategies; options and credit programs are being implemented or studied in Chicago and California||Portland, OR|
|On-Road Strategies that Speed Fleet Turnover|
|Credits for scrapping old automobiles||In California, credits have been made available for removing old automobiles from operation—automobiles that have a disproportionately negative impact on air quality. These schemes have been successful in removing high-polluting vehicles from service (although there have been some glitches in the system), and the credits have been used to offset more expensive emission retrofits for industry in the state. Overall, this has helped reduce emissions at a lower social cost.||California|
|Expanded or enhanced credits for purchase / replacement of vehicles / engines||A credit system, similar to those established for scrapping high-polluting automobiles, could be established for replacing high emitting automobile or diesel engines with lower polluting engines (e.g., alternative fuels, diesel hybrid engines, etc.) could be established. The credits would be performance-based in their values (rather than technology based), could allow for alternative fuels (where appropriate). The credits could be banked, applied against other retrofit opportunities, or traded/sold. These could be established for the range of polluting engines found in the H-G area, including automobiles and trucks, as well as off-road sources like marine and recreational vehicles. This credit should apply to purchase / upgrade of automobiles, construction equipment, diesel vehicles, marine equipment, and other engines.||California|
|Credits for replacement / retrofit of fleets and airport vehicles||Credits for replacement and upgrading of fleet vehicles—particularly government fleets, which can represent a significant share of vehicles—can help achieve the goals for the Houston-Galveston area. This may be achieved through replacement with more efficient engines, or use of alternative fuels. Proxies for current fleet levels may be established based on fuel consumed or other indicators and fleet age to reduce the administrative burden. Incentives should be provided for automobile, truck, and other fleets (garbage trucks, etc.). Upgrades and alternative fuels at airports (in transit vehicles, airline fleets, etc.) can be very effective in reducing pollutants at an already stressed environment. Again, the credits would be performance-based in their values (rather than technology based), and could be banked, applied against other retrofit opportunities, or traded/sold. Note that the South Coast Air Quality Management District in California is considering acting on their legal authority to potentially regulate all publicly owned fleets and require alternative fuels or low emission fleets to reduce emissions. This includes diesel, airport, and other fleets.||California, Massachu-setts|
|On-Road Strategies that Speed Adoption of New Technologies|
|Legalization of after-market emission reduction technologies||EPA-favored inspection and maintenance programs focus on returning the tested vehicles to the exact operating condition that they had when they were new, right down to requiring original equipment. After-market emission-reduction devices exist that allow cars and off-road diesel equipment to perform better than when they were new. Inspection and Maintenance protocols should focus on getting the best performance out of each car, not simply the performance it had when new.|
|Credits for truck stop electrification||The South Coast Air Quality Management District in California has rules that allow credits for truck stop electrification. Trucks would be retrofitted with on-board equipment to allow the truck to plug into an electrical outlet rather than idling the diesel engine. Credits could be offered to the trucks and potentially to the truck stop operators. These credits could go to the trucks or fleets, or potentially to third parties that need credits and are willing to pay for the retrofits. The credits could be banked, traded, sold, etc. Some monitoring would be required to assure that the drivers use this option. This technology is on the shelf, but has not been implemented widespread, nor has anyone applied for the credits in California, to date.||California|
|Incentives for ozone-eating catalyst for air conditioners and automobiles||A catalyst that converts ozone (O3) to oxygen (O2) upon contact provides advantages by reducing ozone in the environment. This technology has been applied to automobile radiators and to air conditioners. The technology is purported by the manufacturer to convert 75 percent of the ozone that flows across the automobile radiator, and 80 percent of the air passing across the air conditioner condensers. The technology works at room temperature, but efficiencies increase at equipment operating temperatures. Volvo automobile company has installed the equipment in about 230,000 vehicles to date, and other auto companies are considering the technology. Estimates of the cost per ton of emissions (NOx or VOC) vary depending on source. In December 1999, this technology became eligible for federal Tier II automobile OEM credits; California Air Resources Board (CARB) was the first to adopt credits in November 1998. The manufacturer (Englehard Corporation) is examining credits for stationary sources in Texas and federally.||Federal, California|
|Incentives for retrofits for revised fuels or technologies to improve diesel operations||Incentives could be developed to encourage adoption of new or retrofit technologies that reduce emissions in on- and off-road vehicles. There have been demonstration projects that show potential to reduce NOx emissions for diesel and large-emitting vehicles, including construction applications. This includes SCR (selective catalytic reduction) strategies for generators for construction units (and peak power units), and in some trucks. The truck models perform best in new equipment rather than retrofit, although the generators can be successfully retrofitted. Emulsified diesel fuel also shows promise, including marine applications. Increasing the cetane level in the diesel fuel (e.g. through additives) –shortens the time between compression and ignition and improves cold start emissions. Some municipalities are specifying 5 percent improvements in NOx and 1 cent per gallon cost increases to get PM10 reductions.|
|On-Road Strategies that Modify Operations or Equipment or Behaviors|
|Market-based HOV or toll lanes, or time-of-day congestion pricing on roads||Time-of-day pricing on roads has been implemented elsewhere to help reduce emissions during crucial hours. Examples include the SR91 "Hot Lane" in Orange County, California. The preferred design would be revenue neutral. Such approaches would also facilitate the evolution of private transit alternatives, such as extensive networks of Shuttle Vans.||California|
|Direct emission pricing based on emission levels and miles driven||The most efficient way to target on-road emissions would be to price them directly, through a system of emission charges levied based upon the emission characteristics of the car, and the miles it is driven. Such systems have been studied extensively, as in the Los Angeles REACH task force and the California Air Resources Board statewide working group on market-based measures. The hurdles to implementing direct emission pricing of automobiles are more political than technological.||Los Angeles, California|
|Mileage-based insurance pricing and vehicle fees||Automobile insurance pricing might be modified to increase the component assigned based on the miles driven. This has the effect of increasing the variable cost and decreasing the fixed cost of driving. One insurance company in Houston has been reported to be considering or testing this option. It may, however, be expected to have only a limited effect, considering that recent significant increases in gasoline prices have had virtually undetectable impacts on driving. However, the concept may have merit when combined with other "fixed costs" including potentially annual vehicle taxes, etc.||Houston|
|Traffic control measures to reduce congestion-related emissions||Such measures might include traffic signal synchronization, additional tolled road construction, incentives to promote telecommuting and flexible work-hours, and could include time-of-day congestion pricing in certain circumstances.||Portland, other|
|Incentives or credits for modifying diesel vehicle operation||Incentives could be provided that would help manage truck diesel emissions by managing diesel speed, and the path vehicles take through Houston. For example, trucks might need to be diverted on an episodic basis to alternate roads that run "around" Houston, rather than through it. Firms or fleets that agree to permanent rerouting might be another target, but abuse might be a consideration.|
|Incentives to Encourage Alternatives in Commuting|
|Market-based shuttle van transit systems||Mass transit programs are promoted as a method of reducing vehicle use and vehicle emissions by providing alternatives to solo driving. But traditional mass transit programs are largely ineffective at cleaning the air, and may actually make the problem worse by increasing traffic congestion. Reason Public Policy Institute has developed an alternative transit plan, which uses privately owned and operated shuttle vans running over a highway system with either High Occupancy Vehicle lanes, or High Occupancy / Toll lanes. Shuttle transit has been shown to be competitive with mass transit in some foreign countries. In the United States, consumers have experience with van shuttle transit in the form of hotel shuttles, airport shuttles, tourist shuttles, and employment-related vanpooling.||U.S. and international|
|Limiting or shifting hours for government workers||Limiting or shifting hours for some kinds of workers can cause difficulties in terms of safety and cost. However, shifting and limiting hours for most types of government workers may be more effective than other sectors, and may have far fewer secondary impacts. These workers may be shifted from 12 noon to 8 pm shifts or may be provided incentives to do so; additionally, incentives for teleworking (including easier home office tax considerations, etc.) may assist the Houston area in meeting attainment levels.|
|Employer tax incentives or credit programs for encouraging telecommuting or commuter alternatives||Government can offer tax incentives for employers to modify benefits packages for employees to encourage transportation alternatives—including car/vanpooling, walking, biking, mass transit, etc. The federal "Commuter Choice" program (National Transportation Equity Act for the 21st Century) provides pre-tax benefits for paying up to $65 of transit, or cash outs of up to $175/mo for parking spaces. This is currently in use, and some states have enhanced these benefits, including Maryland, California, Washington, and others. Options for rides home for emergencies must be available, and evidence indicates there is not abuse of the system. These incentives for telecommuting can either stand alone and be offered by Texas government, or be offered by companies and used as partial offsets in an emission trading regime. New Jersey has an employer trip reduction emission credit program, and employers submit three page plans outlining the trip reduction plan and get emissions credits that may be bought and sold.||Maryland, California, Washington, Federal, elsewhere|
|Time-of-day / congestion parking pricing||Parking pricing can be set much higher during periods during which driving is to be discouraged in order to encourage use of mass transit, off-peak time driving, or use of multiple occupancy vehicles. In addition, parking prices can be set much higher for SOVs and much lower for HOVs. Employer parking buy-out strategies are addressed elsewhere.|
|Incentives for establishing automobile sharing companies or cooperatives||In several locations in the US, Canada, Switzerland, and other locations in Europe, a private company maintains a fleet of automobiles dispersed in garages in neighborhoods throughout the cities. Members/users can make a reservation for a car at reservation centers or through the Internet. They have a special credit card, and the card then provides them access to the site, the garage, and even the ignition of the car. They can drop the car off at any site when they are done. The US firms suggest savings of half the cost of standard automobile ownership; the Swiss example states the economics demonstrate savings for drivers that drive less than 7,000 miles per year. In Switzerland, the business grew 50 percent the first year and 30 percent the year after. Initially, they assumed their market would be the environmental community, but they have found that the cost-effectiveness has spread users to the population at large. Their new marketing campaigns are planned as mass market, not niche environmentalists. http://www.flexcar.com||Seattle/ King County, Washington, Portland, San Francisco, Vancouver BC, Switzerland, Paris, other.|
|Improve efficiencies of regulation|
|Clean screening and high-emitter detection with remote sensing||A minority of cars on the road produces the majority of mobile-source pollutants given off by the entire vehicle fleet. Rather than subject a mostly-clean vehicle fleet to scheduled emission testing with costly, stationary dynamometer equipment, we suggest programs that use lower-cost mobile emission detectors to allow repair efforts to focus on the high emitters, the core of the automobile emissions problem. Clean screening uses both roadside sensors and an understanding of new-car emission characteristics to exempt the bulk of the on-road vehicle fleet from the need for inconvenient, and sometimes costly annual emission testing. Cars less than four years old are unlikely to be high emitters. Studies suggest they are less than 1 percent of the high emitters on the road. Exempting cars newer than four years old removes a large percentage of the vehicle fleet from the test regime, allowing the concentration of effort on the remaining, more-likely high emitters. Using remote sensors to detect which of the cars older than 4 years is clean can also be done with high accuracy, allowing yet more focus on the remaining high-emitters. Finally, roadside sensing of high emissions allows the car to be repaired immediately. An annual test does nothing to repair cars that break a month after their last annual test. Those cars can emit at high levels for another 11 months, even 2 years, before being repaired.|
|Emission check buy-out||In California, as an example, owners may pay a fee to avoid smog checks for the first five years of owning a new car. This can be an appropriate strategy because the minority of pollution is emitted from new automobiles, and the problem is disproportionately one generated from older vehicles. By paying a fee to bypass the checks (e.g. $4/vehicle in some areas), the fee can be used to lower fees for other vehicles, or other appropriate uses may be made with the funds (contributions to a "smog fee/fund"). This strategy assures that similar emissions will be realized, but at lower cost in terms of administration, time waiting, inconvenience, and inappropriate retrofits to new automobiles.||California|
|Air quality improvement program||Some agencies have implemented schemes that allow polluters to pay money to avoid meeting their emission requirements, and the funds are used to help reduce pollution through other strategies. This is, in essence, government moderated trading. This strategy can be effective, but direct trading is preferable, without government middlemen. This program has been implemented in South Coast Air Quality Management District in California, and the funds are redistributed through an RFP process to try to fund a variety of innovative strategies that lead to emission reductions.||California|
|Direct emission pricing based on emission levels and duration of use for registered high-emitting equipment||Though this approach has not been implemented or modeled in depth, there is no theoretical obstacle to the application of emission-pricing approaches to major off-road mobile sources such as generators, cement mixers, tractors, bulldozers, etc. It is likely to be politically preferable to mandated fuel type—for example, requiring all such vehicles to use natural gas, ethanol, or other fuels.|
|Time-of-day pricing for use of high-emitting equipment||Though this approach has not been implemented or modeled in depth, there is no theoretical obstacle to the application of time-of-day pricing approaches to major off-road mobile sources such as generators, cement mixers, tractors, bulldozers, etc. Under time-of-day pricing, equipment that emits high levels of criteria pollutants could be used freely during times when emissions were not likely to lead to air quality violations, but priced to influence reduced use during periods of air pollutant formation or concentration.|
|Emission trading for off-road emission based on equipment type and time of day||Though this approach has not been implemented, there is no theoretical obstacle to the application of emission-trading approaches to off-road mobile sources. Under an emission-trading system, a cap would be established on the total use-time of high-emitting, off-road equipment, and permits would be initially allocated to firms according to existing commitments. Permit depreciation would ensure an overall decrease in emissions from such equipment from year to year, while allowing firms to trade such permits would ensure that emission reductions were made in the most economically efficient manner.|
|Emission budgets, quotas, or incentives for reduced emissions in association with construction contracts||In this option, construction contracts would each have assigned an emission quota or budget that the contractor can meet using tradeoffs they determine to be most cost-effective or efficient. Firms may choose to meet the quota by limiting or shifting construction hours, shifting seasons for construction, by retrofitting heavy vehicles or purchasing lower emitting equipment, or other measures. Another enhancement on this option would be to institute a certification program for construction firms that have fleets that exceed desirable ratios of good to poor emission vehicles. There could also be incentives or credits for using "Good Construction Partners" on projects. We are not currently aware of either of these options in operation anywhere, but few areas are in the same situation as Houston-Galveston.|
|Incentives and pricing at airports||Boston’s Logan airport has taken a phase approach, implementing voluntary measures and incentives to encourage adoption of alternative fuels for the variety of vehicles and fleets at the airport. This has taken the form of 25 percent discounts on ground-access fees, and considerations of discounted rents and other rates and charges. This, coupled with the recent increases in diesel/gasoline prices has led to significant changes in the proportion of natural gas vehicles in fleets like ground support, de-icing, fueling, etc. In addition, they modified the taxi queuing area to eliminate idling. Instead of vehicles inching up to their place in line, they modified the space to allow parallel parking lines that are released one line at a time (like ferry lines), allowing vehicles to be turned off during the wait. If the problem is big enough, Houston-Galveston regulators can work with other agencies with regulatory responsibilities to amend any considerations that limit approaches.||Boston|
|Incentives / discounts / distribution programs for improved gas cans||Gas cans for fueling garden equipment, snowmobiles, chain saws, and other uses contribute to air pollution through spills, open-cap evaporation, and evaporation through the can. It has been estimated that each can may contribute 5 pounds of VOC per year and other emissions. Nozzles with advanced designs eliminate this source. Several areas (including California Air Resources Board, Louisiana, Connecticut) have gotten involved in offering SIP credits or have in place programs that encourage their use, ban purchase of old-style cans, provide trade-in benefits or credits, etc. Estimates are that it is a relatively cheap source of pollution reduction, costing on the order of $1,000 per ton of reductions. CARB calculated very large reductions from this source.||California, Louisiana, Connecticut|
|Incentives for after-market retrofit for heavy duty equipment||Incentives could be developed to encourage adoption of new or retrofit technologies that reduce emissions in on- and off-road vehicles. There have been demonstration projects that show potential to reduce NOx emissions for diesel and large-emitting vehicles, including construction applications. This includes SCR (selective catalytic reduction) strategies for generators for construction units (and peak power units), and in some trucks. The truck models perform best in new equipment rather than retrofit, although the generators can be successfully retrofitted. Emulsified diesel fuel also shows promise, including marine applications. Increasing the cetane level in the diesel fuel (e.g. through additives) –shortens the time between compression and ignition and improves cold start emissions. Some municipalities are specifying 5 percent improvements in NOx and 1 cent per gallon cost increases to get PM10 reductions.|
As mentioned, Houston-Galveston has significant problems in NOx. In determining the best package of methods to address these nonattainment problems, the government should enforce the outcome of cleaner air rather than implement draconian regulatory controls such as the construction ban, burdensome inspection/maintenance programs, reformulated fuels, or other strategies. Rather than implement such traditional permit-based approaches to stationary source control, an approach that is fraught with difficulties, innovative approaches such as facility-wide permits, industry-wide permits, and emissions trading should be modeled and included in the Houston-Galveston SIP, replacing less effective measures. Such alternative permitting strategies have produced great success in several states, including New Jersey, Massachusetts, and Mississippi.
Given their history of failure and resource wastefulness, mandatory behavioral controls such as mandatory reductions in the speed limit and mandatory restraints on the allowable times for use of construction equipment should be avoided. Both of these proposals, further, are based on a limited understanding of the nature of the emissions to be reduced, and the probability of successful reduction. Such uncertainty makes environmental policy unreliable, risks negative unintended consequences, and diverts limited resources.
Rather than proceed with the elements of the Houston-Galveston SIP that have well-established limitations and negative social and economic impacts, TNRCC should, at the very least, model the potential effectiveness of the innovative approaches discussed here, as well as other innovative approaches that have been studied elsewhere, but that are beyond the scope of this study.
Rather than implement traditional permit-based approaches to stationary source control, innovative approaches such as facility-wide permits, industry-wide permits, and emissions trading should be modeled and included in the Houston-Galveston SIP, replacing less effective measures.
Rather than implement traditional mobile source controls of limited effectiveness and high cost (such as enhanced I/M, reformulated fuels, vanpool, transit, and other similar measures), innovative approaches such as shuttle van transit and vehicle emission pricing should be modeled and included in the Houston-Galveston SIP, replacing less effective measures.
Given their history of failure and resource wastefulness, mandatory behavioral controls, limits, or bans should be avoided as they tend to be more disruptive, inhibit creative solutions, and lead to higher social cost than economic or market strategies.
Preferable strategies are "market-based" and allow for flexibility and innovation in their application.
Vehicle Emissions Pricing uses economic concepts by basing vehicle registration fees on the level of emissions from the vehicle and annual distances driven. Other proxies include strategies to redesign fixed-cost fees associated with vehicle ownership and operation into mileage-based fees, providing disincentives to driving more vs. less.
Emissions Trading reduces emissions from stationary sources, usually within a single industry and pertaining to a specific pollutant, by setting an overall "cap" for an entire area and allowing sources to trade emission credits based upon the costs and benefits as determined by each source. These strategies help by limiting pollution and providing incentives to adopt cleaner technologies on an accelerated schedule.
Industry-wide and facility-wide Permitting would establish similar limits and performance standards for specific industries or companies, thereby allowing them to meet the limits in cost-effective ways or buy and sell, rather than just trade, emission credits. Such alternative strategies as above have produced great success in several states, including New Jersey, Massachusetts, and Mississippi.
Specific incentives for adopting new technologies can help move forward the ultimate adoption of new technologies, replace or retrofit high-polluting fleets, and provide incentives for improved operation of vehicles. As another example, incorporating emission budgets or rewards/preferences into a wide variety of construction contracts can also provide incentives for advancing vehicle turnover or retrofit with newer technologies, reducing emissions. A wide range of mechanisms is available and many have shown promise in other locations.
Employer incentives to encourage employees to use alternatives to commuting, including parking cash-outs, tax incentives, and creative tradeoffs in benefits packages show strong promise in other locations, and provide incentives in the private sector and at needed times of day. This shows particular promise because it addresses workers at both large and smaller agencies and companies, helping provide widespread assistance in reducing emissions and provides benefits at sensitive times of day. Incentives can also be provided that encourage the viability of private automobile-sharing cooperatives that help make it practical to avoid automobile ownership for many.
Incentives or pricing to change commuting patterns, including market-based HOV lanes or toll lanes, and time of day road (and parking) pricing can also be very effective in reducing emissions.
More efficient and discerning methods for inspection and maintenance procedures can maintain improved emission levels at lower costs. Using new technology to find noncomplying vehicles on the road, and focusing inspection efforts on that segment of vehicles expected to have higher emissions (older vehicles), or allowing emission check buy-outs for newer vehicles can provide greatest benefit at lower administrative cost and lower inconvenience to (relative) nonpolluters.
Market and incentive strategies can lead H-G to attainment in a more efficient, equitable, and cost-effective manner. These strategies should be considered for addition, substitution, or inclusion in the list of strategies for Houston-Galveston. Market strategies tend to be self-enforcing and can increase compliance and help reduce the need for enforcement. Most importantly, market strategies allow flexibility and tend reduce the overall (personal and societal) costs of achieving attainment goals.
Dr. Kenneth Green directs the Environmental Program at the Reason Public Policy Institute, a nonprofit, nonpartisan public policy research organization based in Los Angeles. Dr. Green has published several studies on urban air pollution policy, including Rethinking EPA's Proposed Ozone and Particulate Standards, Checking Up on Smog Check, Looking Beyond ECO and Defending Automobility, a Critical Examination of the Environmental, Social Costs of Auto Use.
Dr. Lisa A. Skumatz is an economist and Principal of the research and consulting firm Skumatz Economic Research Associates, Inc. (SERA), 1511 Third Avenue, Suite 1000, Seattle, Washington, 98101, Phone: 206/624-8508. Dr. Skumatz has conducted extensive research on market-based and other incentives in solid waste, and specializes in program evaluation and cost-effectiveness analysis for recycling/solid/hazardous waste, energy conservation, and water conservation programs. Among other assignments, she was an invited participant in the Yale Center for Environmental Law and Policy’s "Environmental Reform: The Next Generation Project," which focused on market-based incentives in environmental policy. She has written several policy papers for Reason Public Policy Institute on solid waste and rate issues.
Kenneth Green, D.Env., Rethinking EPA’s Proposed Ozone and Particulate Standards, Policy Study No. 224 (Los Angeles: Reason Public Policy Institute, June 1997).
Ralph Keeney and Kenneth Green, D.Env., Estimating Fatalities Induced by Economic Impacts of EPA’s Ozone and Particulate Standards, Policy Study No. 225 (Los Angeles: Reason Public Policy Institute, June 1997).
Anne E. Smith et al., Costs, Economic Impacts, and Benefits of EPA’s Ozone and Particulate Standards, Policy Study No. 226 (Los Angeles: Reason Public Policy Institute, June 1997).
Kenneth Green, D.Env., Innovative Approaches for Meeting the Georgia Ozone Challenge (Atlanta: Georgia Public Policy Foundation, February 1999).
- Per the Clean Air Act Amendments (CAAA), for exceeding the National Ambient Air Quality Standard (NAAQS).
- Texas Natural Resource Conservation Commission (TNRCC), Air Quality in Houston-Galveston-Brazoria, GI-185B, companion document, 5/98.
- Christopher A. Hartwell, Simplify Simplify: Alternative Permitting at the State Level, Policy Study No. 253 (Los Angeles: Reason Public Policy Institute, February 1999).
- Ibid. p. 3
- Barry Rabe, "Facilitywide Permits and Environmental Regulatory Integration: Lessons from New Jersey," National Environmental Enforcement Journal, (April 1997)
- Hartwell, Simplify, Simplify.
- Nita McCann, "Pollution control wants $1 million to maintain progress," Mississippi Business Journal, April 4, 1996, p. 9.
- For a good discussion of the pros and cons of emission trading programs see Robert W. Hahn, "A Primer on Environmental Policy Design," in Fundamentals of Pure and Applied Economics (New York: Harwood Academic Publishers, 1989); T.H. Tietenberg, Emission Trading (Washington, DC: Johns Hopkins University Press, 1995); and Robert N. Stavins, Transaction Costs and Markets for Pollution Control (Washington, DC: Resources for the Future, Inc, Spring 1995).
- This may make feasible some of the trading schemes of weighted emission trading of ratios of VOC and NOx proposed in work by Gary Dorris, Stratus Consulting in Boulder, Colorado, as discussed in an interview by Lisa A. Skumatz, March 13, 2000.
- Not to be confused with technological transportation demand management initiatives such as traffic-signal synchronization, which have proven to be highly effective and cost-efficient.
- For an overview, see Kenneth Green, Looking Beyond ECO, Alternatives to Employer-Based Trip Reduction, Policy Study 185 (Los Angeles: Reason Foundation, March 1995).
- Alan E. Pisarski, Commuting in America II: The Second National Report on Commuting Patterns and Trends (Washington, DC: Eno Transportation Foundation, Inc, 1996).
- Costs and Effectiveness of Transportation Control Measures (TCMs): A Review and Analysis of the Literature, National Association of Regional Councils (NARC), January 1994.
- Kenneth C. Orski, "Evaluation of Employee Trip Reduction Programs Based on California's Experience with Rule 1501, An Informal Report of the Institute of Transportation Engineers," Resource Papers for the 1994 ITE International Conference, January 1994.
- Kenneth Green, Looking Beyond ECO, Alternatives to Employer-Based Trip Reduction, Policy Study 185 (Los Angeles: Reason Foundation, March 1995).
- This summary of federal and state activity in commuter choice is summarized from very helpful discussions with Scot Spencer, Environmental Defense, interview with Lisa A. Skumatz, March 16, 2000.
- Thomas A. Rubin and James E. Moore II, Better Transportation Alternatives for Los Angeles, Policy Study No. 232 (Los Angeles: Reason Public Policy Institute, September 1997); Thomas A. Rubin and James E. Moore II, Rubber Tire Transit: A Viable Alternative to Rail, Policy Study No. 230 (Los Angeles: Reason Public Policy Institute, August 1997).
- Robert W. Poole Jr., Shuttle Vans: The Overlooked Alternative, Policy Study No. 176 (Los Angeles: Reason Public Policy Institute, April 1994).
- Michael Doherty, "Concerns about Market Instruments," Selling Clean Air Workshop Proceedings (British Columbia, Canada: Public Interest Advocacy Center, October 15-16, 1998).
- Winston Harrington, Virginia McConnell, and Anna Alberini, Economic Incentive Policies under Uncertainty:The Case of Vehicle Emission Fees (Washington, DC: Resources for the Future, August 1996).
- U.S. EPA, Office of Policy, Planning and Evaluation, Guidance on the Use of Market Mechanisms to Reduce Transportation Emissions, Almost Final Draft (Washington, D.C., May 1996).
- Ibid. The EPA / ICF report was well documented and provided citations for each of the numbers.
- National Science and Technology Council, Committee on Environment and Natural Resources, Interagency Assessment of Oxygenated Fuels (Washington, D.C., June 1997).
- For a more detailed discussion of the limitations of this option, see Kenneth Green, Headed for Costly Failure: An Analysis of the Dallas-Fort Worth Clean Air Plan (San Antonio, Texas: Texas Public Policy Foundation, 1999).
- US DOT and US EPA, Clean Air Through Transportation: Challenges in Meeting National Air Quality Standards (Washington D.C., August 1993), p. 19.
- California Air Resources Board, California Air Quality, A Status Report (Sacramento, California, 1991).
- South Coast Air Quality Management District, 1994 Air Quality Management Plan, Appendix IV-B, District's Mobile Source Control Plan (Diamond Bar, California, 1994) p. MON-7.
- Winston Harrington et al., The Enhanced I/M Program in Arizona: Costs, Effectiveness, and a comparison with Pre-regulatory Estimates (Washington, DC: Resources for the Future, June 1999).
- Tom Wenzel, et al., Evaluation of the Enhanced Smog Check Program: A Report to the California Inspection and Maintenance Review Committee (Sacramento, California: California Inspection and Maintenance Review Committee, June 19, 2000). (www.smogcheck.org/smogweb/IMRC/).
- Huel C. Scherrer and David B. Kittelson, I/M Effectiveness as Directly Measured by Ambient CO Data, SAE Technical Paper Series (Washington, D.C.: SAE International, February 1994).
- Patrick Bedard, "Still Smoggy After All These Years," Car and Driver, (April 1995), p. 107.
- Gary A. Bishop, Donald H. Stedman and Lowell Ashbaugh, "Motor Vehicle Emissions Variability," Technical Paper, Journal of the Air and Waste Management Association, Volume 46, (July 1996). See also Jerry Aroesty, et al. Restructuring Smog Check: A Policy Synthesis (Draft) (Santa Monica, California: Rand Corporation, October 1994), p. 7.
- Joel Schwartz, Smog Check II Evaluation, Part II: Overview of Vehicle Emissions (Sacramento, California: California Inspection and Maintenance Review Committee, June 2000). (http://www.smogcheck.org/smogweb/IMRC/).
- Arizona Department of Environmental Quality, Exemption of Vehicles from I/M Requirements in the Phoenix Area: The Arizona Clean Screen Program (Phoenix: Radian International, LLC, December 1996).
- Hartwell, Simplify, Simplify, http://www.newenvironmentalism.org/comflex.htm#newjersey.
- Ibid, http://www.newenvironmentalism.org/comflex.htm#massachusetts.
- Ibid., http://www.newenvironmentalism.org/comflex.htm.
- Alexander Volokh et al., Environmental Information: The Toxics Release Inventory, Stakeholder Participation, and the Right to Know, Policy Study No. 246 (Los Angeles: Reason Public Policy Institute, December 1998), http://www. newenvironmentalism.org/comflex.htm#oregon.
- These suggestions were provide by Coralee Cooper of NESCAUM, interview by Lisa A. Skumatz, May 5, 2000.
- See presentation by Ralph Torrie, Torrie Smith Associates in Panel 3, Case Studies of "Selling Clean Air Workshop Proceedings," October 15-16, 1999, Vancouver, Canada, http://felix.vcn.bc.ca/wcelpub/1000/12729.htm.
- Retrofits have been very effective in the Boston/Logan Airport, for example. Interview by Lisa A. Skumatz with Doug Wheaton, Logan Airport, March 17, 2000.
- Kenneth Green, Checking Up on Smog Check: A Critique of Traditional Inspection and Maintenance Programs, Policy Study No. 227 (Los Angeles: Reason Public Policy Institute, March 1997), http://www.Reason Public Policy Institute .org/environment/ps222. html.
- Note that large-scale commercial/industrial air conditioner applications (stationary applications) can also process considerable quantities of air.
- Interview with Chuck Knott of Englehard Corporation, by Lisa A. Skumatz, May 22, 2000.
- These suggestions were provide by Coralee Cooper of Northeast States for Coordinated Air Use Management (NESCAUM), interview by Lisa A. Skumatz, March 14, 2000, www.nescaum.org.
- Progressive Insurance, according to Deann Upson, United States Environmental Protection Agency, interview by Lisa A. Skumatz, March 14, 2000
- Poole Jr., Shuttle Vans: The Overlooked Alternative, http://www.Reason Public Policy Institute .org/transportation/ps230.html.
- A Maryland study shows use 1.15 times per year, according to transportation specialist Scot Spencer of Environmental Defense, interview by Lisa A. Skumatz, March 16, 2000.
- Green, Checking Up on Smog Check, http://www.Reason Public Policy Institute .org/environment/ps222. html.
- According to Doug Wheaton at Logan Airport, they have not increased the fees for non-compliers, but have only provided reductions, stressing the revenue recovery some, but revenue neutral subsidies could be used. Interview by Lisa A. Skumatz, March 17, 2000.
- These suggestions were provide by Coralee Cooper of Northeast States for Coordinated Air Use Management (NESCAUM). Interview by Lisa A. Skumatz, May 5, 2000, www.nescaum.org.