Local governments, community and business leaders, environmental groups, and concerned citizens in the Austin/San Marcos Metropolitan Statistical Area (A/SM MSA) want to implement programs to improve regional air quality. These groups want to take action now to assure continued attainment of the federal 1-hour standard for ground-level ozone. The O₃ Flex Agreement is the appropriate mechanism for achieving these goals and provides the flexibility to allow individual communities to pursue emission reduction strategies most appropriate to their circumstances. Therefore, local government signatories request that the U. S. Environmental Protection Agency (EPA) and the Texas Natural Resource Conservation Commission (TNRCC) agree to the terms set forth in this O₃ Flex Agreement and Memorandum of Agreement.

1.1 The O₃ Flex Agreement

EPA issued O₃ Flex Guidelines on June 21, 2001. The O₃ Flex Agreement is a voluntary local approach to encourage emission reductions that will keep an area in attainment of the 1-hour ozone standard, while also working toward the health benefits envisioned under the 8-hour ozone standard.

O₃ Flex is implemented through a Memorandum of Agreement (MOA) between EPA, the state environmental agency and local governments. By developing, signing, and maintaining the MOA, the local area will not be designated nonattainment for the 1-hour ozone standard for the term of the agreement, as long as the control measures are being implemented. EPA also plans to provide options for the 8-hour ozone standard, to the extent possible under provisions of the Clean Air Act, that recognize the efforts of areas that voluntarily achieve near-term emission reductions via the O₃ Flex Agreement.

A major advantage of the region’s participation in an O₃Flex Agreement is the flexibility afforded to the signatories in selecting emission reduction measures and programs which are best suited to local needs and circumstances. Recognizing the varied social and economic characteristics of Central Texas, not all measures can or should be implemented by every entity. Also, given constraints imposed by annual budget cycles, not all entities will be able to implement measures before the 2002 ozone season. Each of the signatory parties has reviewed the menu of programs described in Section 3.0 (Action Plan) and committed to implementing those strategies which are most appropriate and suitable given their individual capabilities and resources. A summary of selected programs and commitments is provided in Section 3.7.

It is the understanding of the signatories of the O₃ Flex Agreement that EPA is committed to doing all it can do within its authority to provide SIP credit for near-term, discretionary emission reduction measures to participants in the O₃ Flex Agreement. In Central Texas, these participants include local governments and area businesses. Examples of credits which may be applied include lowering the ozone concentration baseline used as a starting point in ozone attainment modeling, reducing the total amount of emission reductions needed for attainment, or in providing emission reductions needed for a State Implementation Plan (SIP) attainment demonstration. It is also understood that emission reductions achieved through individual measures will be donated to the regional O₃ Flex efforts and will not be available for use in an emissions banking/trading program, with one exception. The City of Austin’s electric utility (dba Austin Energy) intends to make additional NOx emission reductions beyond all state and federal requirements. These additional reductions are expected to result in the utility’s having excess allowances on a regular basis. While Austin Energy may eventually use these excess allowances in a banking/trading program, the utility will not sell the allowances within the five-county Central Texas region. The 2007 NOx reduction resulting from Austin Energy’s emission reduction program is, therefore, included in the total emission reductions to be achieved under this Agreement.

The signatories’ intent in entering into the O₃ Flex Agreement is to proactively implement and sustain air quality improvement strategies that are tailored to local conditions and are effective, practical, and measurable in reducing ground-level ozone concentrations. The Agreement should in no way be construed as a strategy to avoid or to defer a nonattainment designation under the 8-hour ozone standard. However, signatories urge EPA to adopt a policy of quickly restoring attainment status to areas that come into expedited compliance with the 8-hour standard as a result of an O₃ Flex Agreement.

1.2 How O₃ Flex Applies to Central Texas

Participation in an O₃ Flex Agreement is available for areas that:

· currently are designated attainment and are monitoring attainment of the 1-hour ozone standard, and

· currently monitor either violations or attainment of the 8-hour ozone standard.

Implementation of the O₃ Flex Agreement is intended to reduce emissions which produce ozone, O₃. Ozone is a form of oxygen with three atoms, instead of the usual two atoms. It is a photochemical oxidant and, at ground-level, is the main component of smog. Ozone is not emitted directly into the air but is formed through chemical reactions between natural and man-made emissions of volatile organic compounds (VOCs) and nitrogen oxides (NOx) in the presence of sunlight. High concentrations of ground-level ozone are damaging to human health and the environment. Reducing ozone levels requires reductions in ozone precursors, predominantly VOCs and NOx.

The Clean Air Act directs EPA to develop and enforce standards for ambient air quality adequate to protect public health. Ground-level ozone, the pollutant of concern in Central Texas, is one of the pollutants for which standards have been promulgated. Under the 1-hour ozone standard, exceedance of the standard occurs when measured peak ozone levels for any 1-hour period is 125 parts per billion (ppb) or higher. The standard is violated when 1-hour peak levels are at or above 125 ppb more than 3 days over a 3-year period.

In 1997, EPA set a new standard for ground-level ozone in response to concerns that the 1-hour standard was inadequate to protect public health. EPA changed the standard to 85 ppb (the effective standard given rounding protocols) and introduced the “rolling 8-hour average” as the tool for measuring exceedances. The 8-hour average approach addressed the concern that longer periods of exposure were more of a health threat than exposures to 1-hour peak levels. Using the rolling average, EPA calculates the average reading over 8-hour blocks of time throughout a 24-hour time period to determine the highest 8-hour average for a given day. An exceedance of the standard occurs when this 8-hour average is 85 ppb or higher. The fourth highest 8-hour average for the year is averaged with the fourth highest readings for the previous two years. An area violates the 8-hour standard when the average for three consecutive years of these readings is 85 ppb or higher.

Central Texas is designated attainment for the 1-hour ozone standard and continues to monitor attainment of that standard. The region has not exceeded the 1-hour standard since 1985. However, Central Texas has experienced monitored violations of the 8-hour ozone standard in 1997-1999 and 1998-2000. As such, the region meets the criteria in EPA’s guidelines for participation in an O₃ Flex Agreement.

Because monitored violations indicate concentrations of ground-level ozone which are inconsistent with protecting public health and the environment, elected officials in the five-county Central Texas region (Bastrop, Caldwell, Hays, Travis, and Williamson counties) have agreed to consider entering into an O₃ Flex Agreement with EPA and TNRCC, with the intent of taking voluntary and prompt actions to improve air quality in the region. Resolutions to pursue development of an O₃ Flex Plan were unanimously approved by county commissioners courts in each of the five counties. City councils in Bastrop and Elgin (Bastrop County), Lockhart and Luling (Caldwell County), San Marcos (Hays County), Austin (Travis County), and Round Rock (Williamson County) also unanimously approved resolutions. A Letter of Intent, with these resolutions, was submitted to representatives from EPA Region VI and TNRCC on April 11, 2001.

1.3 Central Texas’ O₃ Flex Proposal

Government, business, and community leaders in Central Texas are committed to initiating effective and sustainable programs that will significantly improve air quality and will assure that the region stays in attainment of the 1-hour ozone standard. The first phase in achieving these goals is the O₃ Flex Agreement with TNRCC and EPA. To the extent practicable, O₃ Flex Agreement programs will be launched for the 2002 ozone season, and, in any event, no later than the 2003 ozone season. Descriptions of these programs and identification of the entities utilizing the various strategies are detailed in Section 3.0.

The second phase of the region’s air quality improvement program includes a regional commitment to continued air quality monitoring, photochemical modeling, and technical analyses to facilitate design and implementation of additional strategies for future years. Since 1996, ambient air monitoring has been conducted and emission inventories have been compiled for the region. Photochemical modeling of a 1995 episode has also been performed. Modeling and analyses of a 1999 high ozone episode are underway, with completed studies expected in early 2002. Results of this work are expected to enhance the region’s ability to select the most effective emission reduction strategies. MOBILE5 has been used for this work; analysts will use MOBILE6 [1] to evaluate mobile source emission reduction measures. Using the results of this additional technical work, interlocal agreements may be developed among the participants to carry out future programs and measures, or the signatories may choose to amend the existing O₃ Flex Agreement.

1.4 Geographic Coverage of the O₃ Flex Plan

The proposed O₃ Flex Plan applies to the five counties included in the Austin/San Antonio Metropolitan Statistical Area (A/SM MSA). These counties are Bastrop, Caldwell, Hays, Travis, and Williamson counties (Figure 1.1). The A/SM MSA is defined by the U.S. Office of Management and Budget (based on data generated by the U.S. Census Office) and is representative of the historical basis used by the EPA for defining nonattainment area boundaries. For Central Texas, using the defined MSA is a reasonable and suitable approach to setting the area’s O₃ Flex Plan boundaries. The predominant sources of anthropogenic VOC and NOx in the region are on-road, non-road, and area. The impacts of, and increases in, emissions from these sources are primarily related to the urban character of the region (e.g., population densities, urban/suburban growth, commuting patterns, etc.).

Figure 1.1

1.5 Signatory Government Entities

With EPA and TNRCC, the following local governments are signatories of the A/SM

MSA O3 Flex Plan Memorandum of Agreement (MOA):

City of Austin

City of Bastrop

City of Elgin

City of Lockhart

City of Luling

City of Round Rock

City of San Marcos

Bastrop County

Caldwell County

Hays County

Travis County

Williamson County

It is anticipated that additional local government signatories will be added to the A/SM MSA O₃ Flex Agreement.

1.6 Participating Groups and Agencies

In addition to the government signatories, the following organizations also participated in the development of this O₃ Flex Agreement. Several of these participants, denoted by the asterisk, have also made commitments to implement control measures (See Section 3.7). Information on the groups listed below is provided in Appendix A.

*Capital Area Metropolitan Planning Organization (CAMPO)

*Capital Metropolitan Transportation Authority

*Capital Area Planning Council (CAPCO)

Central Texas CLEAN AIR Force

Clean Air Coalition of Central Texas

Clean Air Partners

Environmental Defense

Greater Austin Chamber of Commerce

*Lower Colorado River Authority

*Texas Department of Transportation (TxDOT), Austin District

*Texas Department of Transportation (TxDOT), Headquarters Office

*Texas Natural Resource Conservation Commission, Austin Headquarters Office

University of Texas at Austin

1.7 Intent, Objectives, and Commitments of the A/SM MSA O₃ Flex Agreement

It is the intent of the signatories that, through their participation in an O₃ Flex Agreement, effective and sustainable air quality improvement strategies will be implemented for the A/SM MSA. Through these strategies, the signatories intend that regional air quality will remain in attainment of the 1-hour ozone standard and have the additional health benefits envisioned under the 8-hour standard. The signatories recognize that the O₃ Flex Agreement does not preclude the A/SM MSA being designated as nonattainment under the 8-hour standard at some future point.

The specific objectives of the A/SM MSA O₃ Flex Plan are to:

· Provide long-term maintenance of the 1-hour ozone standard

· Provide health benefits envisioned under the 8-hour ozone standard

The signatories and participants of the A/SM MSA O₃ Flex Plan commit to:

· Implement, to the extent practicable, emission reduction measures for the 2002 ozone season and no later than the 2003 ozone season. These measures will reflect the circumstances and resources of the individual signatory entities and other participants.

· Continue to conduct air quality monitoring and air dispersion or photochemical modeling.

· Evaluate additional emission reduction measures based on updated photochemical modeling and technical analysis programs.

· Develop and update regularly the area’s emissions inventories.

· Implement effective contingency measures if violations of the 1-hour ozone standard occur.

1.8 Expected Agreement Duration

The signature date of the MOA is the start date of the agreement’s term. The agreement remains in effect until December 31, 2007.

1.9 Conditions for Modification or Early Termination

This agreement may be modified or terminated by mutual consent of all signatory parties. Any signatory party may withdraw from the agreement if provisions of the agreement are not carried out by the other signatory parties. This agreement may be modified at any time. It may also serve as the basis for further negotiations as needed to meet the Clean Air Act requirements under the 8-hour standard.

2.0 Background

TNRCC has provided funding since 1995 to allow the A/SM MSA to be very proactive in air quality planning activities. Funding has also been provided for these efforts by the Capital Area Metropolitan Planning Organization (CAMPO). Air quality planning activities have focused on monitoring, emission inventory development, and photochemical modeling. Sections 2.1 and 2.2 provide information on monitored ozone levels in the area. Section 2.3 describes the emissions inventory work, and Sections 2.4 and 2.5 summarize the modeling work and observed trends.

2.1 Air Quality Monitoring – Number and Location of Monitors

TNRCC has been monitoring air quality in Austin since the mid-1970’s. The first Continuous Air Monitoring System (CAMS) in the area was located at Parmer Lane and MoPac (CAMS #25) in northwest Austin. A second monitor was added in 1993, also in northwest Austin at Murchison Junior High School, 3724 North Hills Drive (CAMS #3). In 1997, because of its proximity to a heavily-traveled highway intersection, the Parmer Lane monitor was re-located to a site in far northwest Travis County near Cedar Park (12200 Lime Creek Road, CAMS #38). Two additional monitoring stations were set up in Caldwell and Fayette counties in 1998 to assist in gathering information on area background ozone levels. These are CAMS #62 (Caldwell County, near the San Marcos Airport) and CAMS 601 (Fayette County). Figure 2.1 shows the location of ozone monitoring stations.

In 1996, air quality data were also gathered by using a specially-equipped van to transport monitoring equipment to areas around Georgetown (northern Williamson County), San Marcos, and Austin-Bergstrom International Airport (southeast Travis County). In addition to monitoring ozone concentrations, NOx

Figure 2.1

concentrations were monitored continuously along with wind speed and direction. Approximately 300 VOC samples were also collected during this period. This data collection effort found that, on ozone action days, highest levels of ozone were often registering outside Travis County and confirmed that on some, but not all ozone action days, air entering the region had high levels of ozone and ozone precursors. Additional data support the observation that the region’s highest ozone levels are typically experienced when winds are out of the north/northeast or from the south/southeast.

Figure 2.1

2.2 Indications of Status of Air Quality in Central Texas

The data indicate that measurements of ground-level ozone in the A/SM MSA over the past 26 years have, in some years, reached unacceptable levels. Figure 2.2 shows the area’s highest 1-hour ozone levels for the period 1974 through 2001. The 1-hour ozone standard was exceeded in 1974, 1976, 1979, 1980, and 1985. The 1-hour ozone standard has not been exceeded in the A/SM MSA since 1985. Figure 2.3 illustrates 1-hour ozone design value trends since 1978.

Figure 2.4 shows the four highest ozone measurements using 8-hour averaging for 1998, 1999, 2000, and 2001. Based on a rolling 3-year average of the fourth highest readings, the A/SM MSA violated EPA’s 8-hour standard in 1999, 2000, and 2001. Eight-hour design value trends since 1980 are shown in Figure 2.5.

Figure 2.2

Figure 2.3

Figure 2.4

Figure 2.5

The number of high ozone days (1-hour and 8-hour) since 1994 is provided in Table 2.1. Although the A/SM MSA has not exceeded the 1-hour ozone standard since 1985, there have been exceedances of the 8-hour ozone standard. Table 2.2 lists the dates and ozone levels for these exceedance days for the 1994 through 2001 ozone seasons.

Table 2.1. Central Texas – Number of High Ozone Days

	1-hour Maximum		8-hour Average
	³ 95 ppb	³ 105 ppb	³ 75 ppb
1994	5	1		12
1995	21	4		33
1996	3	0		6
1997	8	4		23
1998	8	4		15
1999	18	8		34
2000	13	3		20
2001	2	0		14

Source: TNRCC

Table 2.2

8-hour Exceedances – 1994 through August 31, 2001

Year Date Reading in ppb

1994	August 12 August 16 September 19 October 1	88 88 88 89
1995	June 14 June 21 June 22 July 10 July 11 August 4 September 2 September 3 September 4 September 8 September 9 September 11	89 97 89 89 89 88 90 90 91 85 85 88
1996		-0-
1997	April 17 June 2 June 3 August 26 September 29 October 2	86 87 91 97 85 95
1998	May 8 June 15 August 29 August 30 September 3 September 4	85 86 88 92 92 95
1999	August 5 August 6 August 7 August 16 August 20 August 21 August 30 August 31 September 1 September 2 September 16 September 17 September 18 September 19 September 20 September 24 October 1 October 13	103 97 89 96 92 97 94 93 92 88 85 99 99 101 87 88 97 87
2000	April 26 July 24 August 1 August 2 August 13 September 1 September 2 September 3 September 5 September 18 September 30	85 86 85 86 88 88 89 87 97 100 86
2001	May 23	85

Source: TNRCC

2.3 Emission Inventories - Suspected or Confirmed Sources of Pollutants Contributing to Ozone Formation

In 1995, City of Austin Air Quality staff, with funding provided by the Capital Area Metropolitan Planning Organization (CAMPO), compiled an emissions inventory for the area based on 1992 data. This inventory indicated combined NOx and VOC emissions could be attributed as follows:

On-Road Motor Vehicles 43%

Off-Road Motor Vehicles 33%

Area Sources 18%

Point Sources 6%

In 1998 an updated 1996 Emissions Inventory was developed using EPA-approved methodologies (e.g., EPA’s NON-ROAD Model and BEIS 2.3) and incorporating area VMT and population growth projections for the on-road and area source categories. Point sources were inventoried using the TNRCC Point Source database. In early 2001, the 1996 Emissions Inventory was projected to 2007 based on the July 1995 episode. A draft Inventory for 1999 was also prepared in 2001 (Appendix B). Tables 2.3 and 2.4 summarize the estimated emission percentages by category in the 5-county A/SM MSA.

Table 2.3

NOx Emissions in 5-County A/SM MSA

(Average Ozone Season Weekday)

Source Category 1999 EI tons per day (tpd)

On-Road	39%	83.5
Non-Road	23%	48.9
Point	23%	47.5
Area	3%	5.9
Biogenics	12%	24.9
Total	100%	210.7

Table 2.4

VOC Emissions in 5-County A/SM MSA

(Average Ozone Season Weekday)

Source Category 1999 EI tons per day (tpd)

On-Road	9%	48.2
Non-Road	5%	29.9
Point	1%	3.7
Area	15%	86.6
Biogenics	70%	394.1
Total	100%	562.5

2.4 Data Analysis and Modeling

In 1995, the Texas Legislature approved funding, through the TNRCC, to assist the state’s near nonattainment areas in implementing technical studies and designing strategies to improve air quality. In addition to operating and maintaining the monitoring network, these funds were used to initiate photochemical modeling analyses for the A/SM MSA. In consultation with TNRCC and based on EPA criteria, a July 9-12, 1995 ozone episode was chosen for detailed analysis and modeling. This episode is characterized by high 1-hour ozone levels (>100 ppb) and light winds (< 3 mp) out of the south-southeast in both Austin and San Antonio. Photochemical grid modeling for the Austin/San Antonio area and this episode was developed by Environ Corporation and the University of Texas at Austin, Center for Energy and Environmental Resources (UT) using the Urban Airshed Model (UAM-IV) and data from a 1992 Austin-area Emissions Inventory.

UAM-IV and the July 9-12, 1995 episode were used in 1998 to conduct a series of sensitivity analyses with the 1995 base case inventory gauging the effect of various NOx- and VOC-reduction scenarios on ozone levels (“Urban Airshed Modeling for Central Texas,” University of Texas at Austin, Center for Energy and Environmental Resources and the Austin Transportation Study, November 1998). The analyses examined ozone reductions under both the 1-hour and 8-hour ozone standards. This preliminary modeling indicated that reductions in both NOx and VOCs would produce reductions in ozone levels and that these pollutant reductions needed to be in the 25%-30% range to produce a 5-10 ppb reduction in peak ozone concentrations.

In 1999, the UAM-IV and July 9-12, 1995 data base were incorporated into CAMx (Comprehensive Air Quality Model, with extensions) and an updated (1996) area Emissions Inventory was published. Data from a Dallas/Ft. Worth episode (June 19-21, 1995) were also adapted in CAMx for the Austin area. A model performance evaluation revealed that the July 1995 episode does meet EPA model performance criteria, while the June 1995 episode did not. As a result, the July 1995 episode has been the basis of subsequent 2007 future case modeling and sensitivity analyses as data for a 1999 episode is being developed.

In 2000, again with funding provided by the Texas Legislature for the state near nonattainment areas, the Capital Area Planning Council (CAPCO) contracted with Environ and UT to conduct additional photochemical modeling. The work included development of a 2007 future case emissions inventory for the A/SM MSA which incorporates growth factors and implementation of state and federal controls. CAPCO also contracted with the Alamo Area Council of Governments (AACOG) to prepare a 1999 Emissions Inventory. Four of the near nonattainment areas receiving funding (Austin, Corpus Christi, San Antonio, and Victoria) are pooling their state funds to develop and evaluate a September 1999 episode. Environ has developed the base case for this episode.

The photochemical modeling for the July 1995 episode has been performed using meteorological data from a previous study developed for the Ozone Transport Assessment Group study and the meteorological model results have not been refined for the area. The emissions inventory for this modeling was based on existing data and generic estimates instead of A/SM MSA specific surveys. Model performance is adequate, but this evaluation was based on a very limited set of monitoring data. Furthermore, the conceptual model developed for the A/SM MSA indicates that there are additional meteorological conditions that should be modeled for the Austin area in order to cover the conditions that are most often correlated with high ozone in the area. Specific recommendations may be found on pages ES-12 and ES-13 of the attached report on modeling (Appendix C)

Emission levels have been projected from 1995 to 2007 and modeled. From 1995 to 2007 the 1-hour and 8-hour predicted concentrations increase as shown in Table 2.5. The modeling results shown here do not include effects of potential local emission reduction measures. University of Texas staff are in the process of developing the 2007 future case from the September 1999 base case episode which will account for local emission reductions, as well as additional state and federal measures, if applicable.

Table 2.5

1-Hour and 8-Hour Predicted Ozone Concentrations – 2007

max 1-hour max 1-hour max 8-hour max 8-hour

1995 base case 2007 base 1995 base case 2007 base

(ppb) (ppb) (ppb) (ppb)

July 9 115.1 123.8 92.3 96.1

July 10 117.7 119.9 96.0 96.5

July 11 107.9 115.1 87.6 87.7

July 12 124.0 125.0 n/a 92.0

125 ppb is the 1-hour concentration used for comparison to the 1-hour standard.

85 ppb is the 8-hour concentration used for comparison to the proposed 8-hour standard.

n/a =not available

Environ has completed development of the 1999 episode base case. Staff are working on refinements to the 1999 emissions inventory and plan to have this work complete by May 2002. During the summer, the mobile source inventory will be updated using MOBILE6. The model will be performance-tested again in the fall.

2.5 Observations and Trends

Air quality monitoring, emission inventory preparation, and photochemical modeling for the A/SM MSA have provided considerable insight into the nature of the region’s air quality situation. NOx emissions in the region are predominately from On-Road and Non-Road sources. Biogenics comprise the largest source of VOCs in the five-county area as a whole, but anthropogenic sources of VOCs dominate the urban areas where highest ozone concentrations occur. Studies also show that biogenic sources of VOCs in rural area do not contribute significantly (~1 ppb) to ozone formation unless high levels of NOx (either through transport or from rural sources) are also present. [2]

Highest ozone levels occur in August and September with wind patterns typically southwesterly to northerly in the morning or northeasterly to southeasterly in the afternoon. While elevated background levels from ozone transport contribute to ozone concentrations in the area, local sources make a significant enough contribution to produce high ozone levels and exceedances of the 8-hour standard in the A/SM MSA.

Sensitivity modeling on the July 1995 episode with the 1995 base case inventory shows that ozone concentrations in the area around the Murchison monitor (CAMS 3) increase as NOx reductions are made until large amounts of NOx are reduced, while VOC reductions do reduce ozone concentrations in this area. The reverse is true at the Audubon monitor (CAMS 38) where NOx reductions are more effective than VOC reductions in lowering ozone levels.

Precursor response studies with the 1995 base case inventory were conducted by UT Austin in February 2001 to determine how reductions in anthropogenic NOx emissions, VOC emissions, and a combination of NOx and VOC reductions affected peak ozone concentrations predicted by the photochemical model. The studies indicate that a combination of NOx and VOC reductions were more effective than NOx or VOC reductions applied separately.

Additional precursor response studies were conducted using the projected 2007 future case from the July, 1995 episode. These studies reduced NOx and VOC emissions from point sources, area/non-road sources, and on-road sources by 22.5 tons per year each. Reductions in mobile (on-road and non-road) sources with reductions in area source emissions appear to be more effective than reductions in point sources. In addition, on all days of the episode, NOx and NOx/VOC reductions between 25% and 35% produced peak predicted 8-hour average ozone concentrations below 85 ppb.

3.0 Action Plan – Emission Reduction Strategies and Resources

The objective of the O₃ Flex Agreement is to keep the A/SM MSA in attainment of the 1-hour ozone standard. The A/SM MSA is also committed to achieving the health benefits envisioned under the federal 8-hour ozone standard. Although preliminary modeling indicates that the region is likely to stay in attainment of the 1-hour standard through 2007, the following strategies will be implemented to ensure compliance with that standard. To the extent practicable these strategies will be implemented for the 2002 ozone season, but in any event, these strategies will be in place for the 2003 ozone season and will reduce emissions through 2007. Not all of the strategies can be implemented by all of the signatory agencies or other participants, and parties responsible for implementation have selected programs that are consistent with reaching the participants’ common air quality improvement goals, given varying levels of resources and capabilities.

Emission reductions provided in this document are based on the control measure commitments of the signatories and participating agencies only (see Appendix E for programs specifics for each of the signatories and participating agencies). Section 3.1 describes the commitments by employers in the region to take voluntary actions to reduce NOx and VOC emissions with an emphasis on reducing commuter vehicle miles traveled. Projects designed to reduce emissions associated with the region’s transportation system are described in Section 3.2. Section 3.3 provides information on the region’s clean fuels and equipment programs. Local government initiatives (e.g., airport operations, power plants, etc.) are described in Section 3.4. Signatories and participants in the O₃ Flex Agreement recognize the importance of providing the general public with the information needed to take individual air quality improvement actions and have committed to strong educational and public outreach strategies. These efforts are included as Section 3.5. In addition to the emission reduction strategies, the A/SM MSA has several programs in place which will serve as valuable technical and logistical resources for implementing the strategies. Section 3.6 provides information on these programs. Sections 3.7 and 3.8 contain tables summarizing the strategy commitments of the various O₃Flex Agreement participants.

The emissions reductions from the O₃ Flex commitments have, in general, been quantified for the period 1999 through 2007. Many strategies were quantified for 2002 as well. In all cases where the program commitments were quantified, conservative assumptions were used. For example, employee VMT reductions were calculated at a conservative home-to-work round-trip of 22.6 miles. Some strategies, although directionally sound, have not been quantified because of insufficient data or lack of methologies. Some strategies were initiated prior to 1999 (e.g., vanpools, telework, compressed work week) and will continue at or above pre-1999 levels. For these pre-1999 programs, a second set of emission reduction numbers are provided and labeled “Total Emission Reductions” to reflect the inclusion of reductions since the programs’ introduction. However, only the emission reductions quantified for the 1999-2007 period are being claimed as part of this O₃ Flex Agreement. Emission reductions in 2007 to be achieved through the commitments outlined in this O₃ Flex Agreement these emission reductions are:

VOC 2.3 tons per day

NOx 6.7 tons per day

3.1 Strategies to Reduce Commuter Vehicle Miles Traveled (VMT)

In the A/SM MSA, on-road vehicles are the single largest source of emissions producing ground-level ozone. Although significant improvements in vehicle emission control technology have been made and are expected in the future, the region has also experienced population growth which is expected to continue. Implementing programs which encourage the use of alternatives to the single-occupant vehicle commute is a key strategy. Commuters are encouraged to choose alternatives to the single-occupant vehicle commute—carpooling, vanpooling, transit, telework. Employers may offer direct-deposit for payroll to eliminate employees’ need to make a trip to the bank. Flextime and alternative work schedules are also encouraged.

CARPOOLING

Emission Reductions from A/SM MSA O₃ Flex Commitments (lbs. per day)

2002 2007

VOC	6.9	6.9
NOx	6.0	6.3

DIRECT DEPOSIT

Emission Reductions from A/SM MSA O₃ Flex Commitments (lbs. per day)

2002 2007

VOC	N/A*	70.94
NOx	N/A*	70.00

*Not Available

COMPRESSED WORK WEEK

Emission Reductions from A/SM MSA O₃ Flex Commitments (lbs. per day)

2002 2007

VOC	132.7	129.2
NOx	110.3	114.6

Total Emission Reductions from A/SM MSA O₃ Flex Commitments (lbs. per day)

(includes pre-1999 implementation)

2002 2007

VOC	208.6	195.5
NOx	175.5	175.6

FLEXIBLE WORK SCHEDULES

Emission Reductions from A/SM MSA O₃ Flex Commitments (lbs. per day)

2002 2007

VOC	9.4	12.9
NOx	-0.5	-0.7

Total Emission Reductions from A/SM MSA O₃ Flex Commitments (lbs. per day)

(includes pre-1999 implementation)

2002 2007

VOC	61.9	60.1
NOx	-3.1	-3.3

3.1.1 Clean Air Partners Program

During the summer of 1999, volunteer members of the CLEAN AIR Force (a non-profit organization representing area governments, businesses, and community interests working on air quality issues) began actively recruiting major employers in the area to implement corporate air quality improvement programs. As emissions from on-road vehicles are the single largest sources of NOx and CO emissions in the region, efforts to encourage alternatives to the single-occupant vehicle commute were a major focus of the commitments sought from employers. In the fall of 2000, six corporations agreed to join the Clean Air Partners program, developed a menu of strategies, and signed Memoranda of Understanding with the CLEAN AIR Force to reduce, over a three-year period, employee VMT (or emission reduction equivalents) by 10%. These charter members are:

Advanced Micro Devices

Intel

Motorola

Samsung

Solectron

Vignette

An on-line reporting system has been developed to allow participants in the program to report regularly on their VMT reduction progress. This on-line reporting process will also make broad regional participation in the program possible.

Many other area businesses and entities are designing air quality improvement initiatives and have expressed interest in becoming Clean Air Partners. The Greater Austin Chamber of Commerce Clean Air Task force has committed to enroll 10% (approximately 250 employers) of its membership in the Clean Air Partners Program by the summer of 2002. The University of Texas, with Capital Metro, has launched a program to increase transit ridership and vanpooling among faculty and staff. Faculty and staff will be able to ride any Capital Metro bus at no charge by showing UT identification. Free parking for carpools and vanpools is also being made available as part of the Capital Metro/UT program.

The Clean Air Partners program is being expanded to include an array of additional air quality improvement measures which achieve emission reductions comparable to the percentage in employee VMT reduction. These measures include restrictions on engine idling by vendors and delivery services, accelerated replacement of company fleet vehicles with electric or other LEVs, voluntarily switching to low-emission fuels, and establishing flexible work hours to reduce traffic congestion. Commitments to implementation will be formalized in written MOUs between the Partners and the CLEAN AIR Force. A new category—Clean Air Advocate—has been added for employers who devote significant time and resources to support the program, but, because of size or other factors, may be unable to make commitments to implementing control measures. As a result of this expanded program, eight new employers have joined the charter partners:

Emerson Process Management

Turner Collie & Braden

Transportation Management Group

URS Corporation

Greater Austin Chamber of Commerce

The Austin Idea Network

Zilliant

Hangers Cleaners

Emission Reductions: Members of the Clean Air Partners program are in the process of quantifying their emission baselines. Once these baselines are established, Partners will select their program commitments from the array of emission reduction strategies and calculate their respective emission reductions. Emission reductions achieved will be included in the biannual reporting to EPA and TNRCC pursuant to this agreement.

3.1.2 State Telework Program

The State Energy Conservation Office (SECO), a division of the Texas Comptroller of Public Accounts, oversees an extensive and comprehensive effort to establish telework programs for state agencies and other area employers. SECO provides a full range of services to assist employers—training for managers and teleworkers, sample telework policies and reporting forms, program workbooks and manuals, and technology security assistance. A video describing telework and its advantages is also available through SECO. SECO also monitors the success of telework programs. In a recent report to the state legislature, SECO documented supervisor-assessed increases in productivity for teleworkers of as much as 30%. This type of success has contributed to the increased acceptance of telework programs among managers in both the public and private sectors.

Twenty-seven Texas state agencies have active teleworking programs. The State Auditor’s report to the Legislature shows that, between September 1997 and February 1999, 1,182 state employees teleworked for at least one day a week and some employees (e.g., Protective and Regulatory Services case workers) worked full-time from their homes, saving the state several thousands a year in office space costs. Statewide, estimated pollution reductions between 1997 and 1999 from the state teleworking program are estimated as:

2.8 tons of hydrocarbons

21.4 tons of carbon monoxide

1.5 tons of nitrogen oxide

352.8 tons of carbon dioxide

In Central Texas, approximately 1,500 state employees are currently teleworking one or more days per week. As technological and security issues are rapidly being resolved, the interest in setting up telework programs has increased and is expected to continue to grow. The TNRCC has set a goal of increasing its teleworkforce from the current 4% to 15% by 2004, bring the statewide TNRCC total to 450.

TELEWORKING

Emission Reductions from A/SM MSA O₃ Flex Commitments (lbs. per day)

2002 2007

VOC	0.7	1.6
NOx	0.7	1.7

Total Emission Reductions from A/SM MSA O3 Flex Commitments (lbs. per day)

(Includes pre-1999 implementation)

2002 2007

VOC	4.2	4.6
NOx	4.2	4.9

3.1.3 Capital Metro Vanpool Program

In 1999, the Capital Metro Board of Directors revised its vanpool policy to allow vanpool operations outside its service area. Commuters are eligible to join or form vanpools as long as one leg of the commute begins or ends in the service area. The in-service area fare for the vanpooler is $25 per month. The fare covers fuel , insurance, van maintenance, and free access to bus routes. Guaranteed-ride-home service is provided at an additional $5 per year. Awareness of the benefits of vanpooling has generated considerable interest, to the extent that Capital Metro has initiated an emergency purchase of additional vans to accommodate requests, 10 new vans in 2001 and an additional 15 in 2002. During 2000, Capital Metro, with the support of the Commute Solutions Partners, through presentations, working directly with corporate management, and hosting of over 50 employer-based transportation fairs, increased the number of vanpools (5-15 passengers each) from 110 to 130, carrying a total of 789 passengers. Area employers with significant numbers of operating vanpools include TNRCC, Motorola, Advanced Micro Devices, and Farmers Insurance. All of the Clean Air Partners are committed to increasing the number of vanpools formed for their employees.

CAPITAL METROPOLITAN TRANSPORTATION AUTHORITY

VANPOOL PROGRAM

Emission Reductions from A/SM MSA O₃ Flex Commitments (lbs. per day)

2002 2007

VOC	6.58	18.39
NOx	5.69	17.02

Total Emission Reductions from A/SM MSA O3 Flex Commitments (lbs. per day)

(Includes pre-1999 implementation)

2002 2007

VOC	37.72	45.29
NOx	32.65	41.92

3.2 Transportation Emission Reduction Measures

Transportation emission reduction measures (TERMs) are similar to transportation control measures (TCMs), except that TCMs apply to nonattainment areas. TCMs are included in the State Implementation Plan (SIP) and subject to transportation conformity requirements. For the purposes of the O₃ Flex Plan, TERMs will comply with the Federal Clean Air Act description of TCMs, but are not subject to nonattainment SIP or transportation conformity requirements.

In general, TERMs are transportation projects that are designed to reduce vehicle use, change traffic flow or reduce congestion conditions. A transportation project that adds single-occupancy vehicle (SOV) roadway capacity or is based on improvements in vehicle technology or fuels is not considered to be a TERM for O₃ Flex Plan purposes. General categories of TERMs include traffic signal synchronization and/or improvements, bicycle and pedestrian facilities, high-occupancy vehicle lanes, intersection improvements, park and ride lots, and transit projects.

Numerous TERMs have been identified that have been, or will be, implemented in the five-county area. Phase 1 TERMs are those projects that will reduce emissions for the 2002/2003 ozone season. Many Phase 1 TERMs will also reduce emissions through 2007 and are included in the Phase 2 total 2007 emissions reductions. Phase 2 TERMs are those measures implemented after 2003 that will reduce emissions in 2007 and those Phase 1 TERMs that will still be reducing emissions in 2007. Many TERMs will reduce emissions for several years after implementation, and so will reduce emissions after 2007 as well. A project specific list of Phase 1 and Phase 2 TERMs is found in Appendix D, which provides locations, project limits, implementation dates, and emission reductions for all TERMs.

Table 3.1 summarizes the TERMs. Emissions reduction estimates are based on information from the CAMPO 2007 travel demand model forecast and associated information, which accounts for population, employment, VMT, and transportation system growth through 2007.

Table 3.1

Transportation Emission Reduction Measures (TERMs)

Project Type	Phase I		Phase II
Project Type	VOC Reductions (lbs/day)	NOx Reductions (lbs/day)	VOC Reductions (lbs/day)	NOx Reductions (lbs/day)
Intersection Improvements	973. 495	163.452	1231.185	186.674
Signal Improvements	1097.905	92.094

Table 3.1

Project Type