GUIDANCE FOR MOBILE EMISSION CREDIT
GENERATION BY URBAN BUSES
January, 1993
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PROGRAM FOR GENERATION OF EMISSION CREDITS BY URBAN BUSES
I . Foreword
The Clean Air Act, as amended in 1990, mandates market-based
approaches in certain Federal programs and encourages the use of
such approaches at the Federal, State, and local levels, as well as
by individual sources, to facilitate the attainment of the mandated
milestones and goals of Title I of the Clean Air Act Amendments.
In response to the Act, the Agency has proposed and issued rules
and guidance that incorporate the use of market-based measures in
Federal program areas such as acid rain reduction and clean fuel
fleet vehicle purchases.
To facilitate the development of market-based programs that go
beyond such Federal programs, the Agency is developina
comprehensive rules and guidance for States and individual sources
to follow in designing and adopting market-based programs in State
implementation Plans (SIP' a). The pending Economic Incentive
^ofT" ( iC'P) UleS draw upon the ^neral principles found in the
1986 Emission Trading Policy Statement (see 51 FR 43631 December 4
1986) while providing a broad framework for the development and use
of a wide variety of market-based control strategies. For States
to take credit in their SIP's for emission reductions based upon
such strategies, reductions must be quantifiable, enforceable,
surplus to other Federal and State retirements, permanent within
the timeframe specified by the program, and consistent with all
^£er0s? ry and Federal regulatory requirements. The proposed
!JL^"i*a-arH aPPl^le to aH types of sources including
stationary and mobile sources and define general regulatory
elements (e.g., program baseline, auditing procedures, enforcement
mt Sh°Uld be included ±« the design of market-based
In addition to these broadly applicable general rules, the
Agency is also developing a more narrowly focused document entitled
Guidance on the Generation of Mobile Source Emission Reduction
Credits specifically for the development of market-based programs
involving the use of emission reduction credits generated by mobile
sources. Such mobile source emission reduction credits (MERC's)
can be generated from surplus emission reductions over and above
Federal mobile source program requirements and can potentially be
used to substitute for stationary emission reduction requirements
The general guidance on the generation of MERC's mentioned above
addresses issues unique to emission reduction credits generated by
mobile sources, including the calculation of emissions baselines
tor participating sources, the projection of future emissions
levels, and the time-averaging of emission reduction credits that
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To exemplify how MERC's can be generated from a specific
category of mobile sources, the following guidance addresses clean
technology urban buses, and illustrates how surplus purchases
(i.e., beyond Federal program requirements) can be used to generate
emission credits in a mobile-stationary source trading program.
While market-based mobile source programs must be consistent with
the Economic Incentive Program Rules and the Guidance on the
Generation of Mobile Source Emission Reduction Credits, EPA does
not intend to limit flexibility and innovation beyond the
requirements found in these documents. The following guidance is
intended to identify key elements in the design of a clean
technology urban bus emission credit generation program, not to
limit state initiative, creativity, or flexibility in developing a
program which best meets the state's needs within the limits of
good environmental policy.
II. Introduction
EPA is developing innovative methods to encourage low emitting
and clean fuel technologies. As part of this initiative, market-
based incentive programs are an effective means to promote this
technology and to achieve the accompanying emission reductions.
The overall regulatory burden is reduced because participation by
industry is voluntary. Furthermore, it is reasonable to believe
that in a broad sense the reductions are cost effective since
industry would not become involved in the program if participation
was not viewed as economically attractive. Finally, by a voluntary
shifting of the compliance burden to the party with the lowest
cost, market based programs can reduce the cost of compliance for
the industry as a whole.
Urban buses represent a significant source of ground level NOx
and PM emissions within cities. To help address this problem EPA
has two programs to reduce the emissions from urban buses. The
first, which applies to urban bus engine manufacturers, involves
stringent NOx and PM emission standards for new urban bus engines.
These emission standards can be met on an every engine basis or in
combination with credit programs such as averaging, banking and
trading. The second program, which is presently in the proposal
phase, applies to fleet operators and involves in-use urban bus
engines. This program requires either application of retrofit
technology to reduce emissions of individual rebuilt urban bus
engines or a fleet emissions averaging program to reduce overall
fleet emissions from in-use urban bus engines through one or more
of several approaches.
These emission standards and other program requirements can
potentially be met through the use of either improved engine and
aftertreatment technology or the use of clean fuels. For ease of
reference in this document, these methods will collectively be
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referred to as "clean technologies". Both approaches show promise
for providing additional emission reductions, but as with most
emerging technologies they are somewhat more expensive than current
diesel-powered urban buses. In order to provide urban bus
operators with incentive to purchase clean technology urban buses,
EPA has developed a program which will allow trading of excess
urban bus emission reductions (credits) with other sources. As
background, this document will describe the regulatory programs and
current credit exchange programs for urban buses as mentioned
above, and then develop a credit generation program for new urban
buses and bus fleets which exceed emission requirements using clean
technologies.
Ill. Description of Currant Program*
A. Averaging, Trading and Banking Programs for Certification
The current averaging, banking and trading (AB&T) programs
apply to NOx and PM emissions from heavy duty engines (HDEs) .
Under these programs, credits may be generated and used only by
manufacturers of new engines. Urban bus engines meet the same HC,
CO, and NOx emission standards as other HDEs and are considered the
same as any other HDE within their primary intended service:class
for NOx AB&T purposes. However, there is a unique PM standard for
urban bus engines and PM AB&T programs are thus restricted to that
specialized subgroup. Cross-fuel credit exchanges (AB&T) are
allowed between petroleum and methanol-fueled urban bus engines and
EPA recently proposed to extend this program to the gaseous fuels
(CNG, LNG, and LPG) . The trading and banking rule lists the
equation for calculation of credits:
Cr = (Std-FEL)(CF)(UL)(Prod), where
Cr = total mass of emissions credit for family (grams)
Std = NOx or PM emission standard in g/bhp-hr
FEL = Family emission limit in g/bhp-hr
CF = Conversion factor for g/bhp-hr to g/mile;
CF = BSFC x Fuel Economy x Fuel Density
UL = useful life in miles
Prod = Number of engines of the particular family produced
In summary, under this program urban bus engine manufacturers
can generate NOx and/or PM credits for .use in current or future
certification or trading to other engine manufacturers. However,
their use is currently limited to new engine certification.
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B. Retrofit/Rebuild
EPA has proposed an urban bus retrofit/rebuild program aimed
at reducing emissions from older urban buses (57 FR 33141, July 27,
1992). As required by the Clean Air Act (CAA), the proposed urban
bus retrofit/rebuild program would apply to 1,993 and earlier model
year urban buses whose engines are rebuilt or replaced beginning
January 1, 1995. The CAA limits the program requirements to urban
buses operated in metropolitan areas with a 1980 population of
750,000 or more. EPA estimates that nearly 80 percent of the
nation's urban buses in approximately 100 cities could be affected
by the program. (See Table 1)
As proposed by EPA, urban bus operators would be allowed to
choose between two different retrofit/rebuild options to
demonstrate compliance.
Under the first option as proposed, a bus operator's engines
would have to meet a 0.10 grams per brake-horsepower (g/bhp-hr) FM
emission standard at time of rebuild or replacement, as long as
aftertreatment equipment certified to meet the standard can be
purchased for no more than $5,000. If no aftertreatment equipment
13 available that meets the 0.10 g/bhp-hr PM standard at. the cost
limit requirements, a bus operator would be required to install
equipment that has been certified to achieve a 25 percent or
greater emission reduction on that engine as long as such equipment
can be purchased for no more than $2,000. The 25 percent emission
reduction is based on the original certification emission standard
for the engine. If not certified to a PM standard, then the engine
must be rebuilt to the original configuration. If no equipment is
available that meets these requirements, a bus operator would be
required to rebuild an engine to its original configuration or a
configuration that has lower PM emissions than the original
configuration.
The second retrofit/rebuild option would be a fleet average
program that is designed to yield an emission reduction equivalent
to that expected from the performance based (retrofit technology)
option described above. Under the second option, using the
approach spelled out by EPA in the aforementioned proposal, a bus
fleet operator would calculate an annual target level for his fleet
(TLF) for PM emissions based on the fleet makeup and the
availability of control options. The fleet operator could then use
any combination of certified retrofit technology, replacement with
used lower emitting urban bus engines, and early retirement of
their urban buses such that the average fleet level attained (FLA)
for PM emissions is at or below the required target level (TLF)
noted above.
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The final rule will include these points, but may make changes
to provide for costs other than equipment which transit operators
mu.st consider.
These two programs serve as the starting basis for a program
to permit credit generation for urban buses. This program is
discussed below.
IV. Emission Credit Generation Program for Urban Buses
A. Overview
Under this program, operators of urban buses may generate
credits in two ways . The first stems from the averaging, trading
and banking regulations and applies to purchases of new urban
buses. The second stems from the retrofit/rebuild requirements,
and applies to any retrofitted clean technology bus which is used
to meet either the performance based option or the TLF option for
complying with the retrofit/rebuild requirements. The specifics of
these programs are discussed below.
B. Purchase of New Urban Buses
Any clean technology urban bus which is purchased by a fleet
operator may receive NOx and/or PM emission credits in the amount
that the urban bus has lower emissions than the then applicable
NOx/PM urban bus emission standards. As is discussed below, credit
calculations would be based on actual VMT for the clean technology
bus in any given year. These emission credits would accrue over
the bus useful life (until retirement or rebuild) . If there are no
rebuilds involved, credit generation could not exceed the average
urban bus lifetime of fifteen years (see Table 2) . However, in
most cases the first rebuild occurs after 5 years of use (about
220,000 miles); after this the bus must qualify for credits under
the retrofit/rebuild program. Regardless of when retirement or any
subsequent rebuild occurs, credit generation is based on the
presumption that the bus is meeting the emission standards at all
times prior to that point.
additional provision is suggested to promote the early
retirement of higher emitting urban buses. Referring to the data
in Table 2, if a new clean technology urban bus is used to replace
an older urban bus which is retired early, the clean technology bus
could generate emission credits in the amount that the clean
technology bus NOx and PM emissions are lower than the retired bus
NOx and PM emissions. These benefits would accrue for the years
that the old urban bus would have been in operation.
Under this approach, credit generation would be calculated
differently for the years when the new bus life overlaps with the
presumed remaining life of the old bus than for the years afterward
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I
when the old bus is presumed to have been retired. This method
requires reliance on the expected VMT of the old urban bus as shown
in Table 2 and the credit calculation methodology as explained in
Section VII below. For the overlapping years credit calculation
would involve two steps. The first step would depend on the
difference between the emission standard applicable to the old bus
and the new bus for the overlapping miles of Table 2. The second
step, 'if applicable, would depend on the difference between the
emission standard applicable to the new bus and the family emission
limit of the new bus and the actual mileage of the new bus.
Credits for the remainder of the new bus life (after the old bus is
presumed to have been retired) , would be calculated as in the first
paragraph of this section using actual new bus VMT.
Of course, as is mentioned in element 9 below, credits cannot
be generated under this method if the retired bus is also used to
achieve compliance under the requirements of the retrofit/rebuild
program.
TABLE 2
EXPECTED URBAN BUS VMT BY YEAR OF OPERATION
YEAR OF OPERATION
1
2
3
4
5*
6
7
8*
9
10
11*
12
13
14
15
EXPECTED VMT
45,000
4S,000
' 44,000
42,000
41,000
38,000
36,000
35,000
33,000
29,000
25,000
25,000
. 25,000
25,000
25,000
* «xp»ct«d rebuild point
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C. 1995 Retrofit/Rebuild Urban Buses
As mentioned above, under the CAA 1995 urban bus
rebuild/retrofit programs, there are two options for compliance.
The first, the retrofit/rebuild option, is a performance based
program which is implemented on a per bus basis. Under this option
an urban bus operator may receive emission credits for retrofitting
an old urban bus using clean technology. This program would apply
to both PM and NOx. Emission credits would be the amount the
individual urban bus was below the 1995 retrofit/rebuild emission
PM standard and the original configuration NOx emission standard.
Credit calculations would use the actual VMT of the bus as it is
used, not Table 2.
The second retrofit/rebuild option is an averaging program
that is set up to provide the bus fleet operators greater
compliance flexibility while still yielding an emission reduction
equivalent to that expected from the performance based option
outlined above. Under the second option, a bus operator would
calculate an annual target level for a fleet (TLF) for PM emissions
based on the makeup of the operator's urban bus fleet. The bus
operator could use any combination of certified retrofit equipment
(clean fuel or low emitting technology) and early retirement of
their urban buses such that the average fleet level attained (FLA)
for PM emissions is at or below the target level (TLF) noted above.
Under this option, it is possible that a company may elect to
surpass their TLF requirement by retrefitting/rebuilding additional
urban bus engines using clean technology or other means. If this
is the case, and the company is below its TLF, then any clean
technology urban buses in the fleet, after the fleet meets the TLF
emission level, may be used for credit generation by declaring that
the extra clean technology buses are not to be included in the TLF
calculation (a TLF opt-out bus). However, the fleet must meet its
TLF_ with the remainder of the buses in the fleet. This is
equivalent to allocating credits on a per engine basis as under the
performance based option above and credits for opt-out buses will
be calculated similarly. As was the case for that option, this
program would only apply to PM and NOx emissions.
Under either option, credits are calculated using the
appropriate actual VMT and emission differences. Table 2 values
will not be used.
In summary, there are three ways in which urban bus engines
can potentially generate NOx and PM emission credits:
- purchase of new, clean technology urban bus engines certified
to levels below the emission standards.
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retrofit of in-use urban bus engines with clean technology
kits certified to levels below the applicable retrofit/rebuild
PM emission standards and the original configuration NOx
standard.
TLF opt-out urban bus engines using retrofit clean technology
certified to below applicable standards as above for PM and
NOx.
V. Program Elements
In an overall sense, credits for urban bus NOx and PM
emissions will be generated as discussed above. Suggested elements
of a program that would allow clean technology urban buses to
generate emission credits are described below. It will be up to
the states to develop a-proposal to integrate the overall concepts
described above and these general elements into a specific program.
ELEMENT I. Credit-generating urban buses must be in addition
to those required to be purchased by statute or
must be certified to lower emission standards.
Clean technology urban bus engines may generate emission
credits under one of the three options listed above. Emission
reductions must be beyond those required by the new bus emission
standards or those of the retrofit/rebuild program. This element
is necessary to ensure that credits reflect actual excess emission
reductions.
ELEMENT 2. Clean technology buses may operate on clean
alternative fuels or on petroleum-based fuels
Since the focus of this program is on allowing the use of
clean technology urban buses to generate emission credits, it is
not necessary to require that the .affected urban buses run on any
particular fuel. It is only necessary that the urban bus emit at
a level lower than the then applicable urban bus PM and/or NOx
emission standard or that required in the retrofit/rebuild program.
At the same time, it should be noted that urban buses which run on
clean alternative fuels (e.g., electricity, gaseous fuels, and neat
alcohol) will tend to be inherently cleaner and thus potentially
generate more emission credits than those that run on conventional
petroleum-based fuels or fuel blends relying more on advanced
emission control technology.
ELEMENT 3. Clean alternative fuel vehicles need not be
dedicated fuel vehicles.
EPA is not averse to including dual-fuel, flexible-fuel, or
hybrid electric urban bus engines in a credit generating program.
However, urban buses which operate on more than one fuel complicate
the calculation of tradeable credits. Since different fuels
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produce different emission rates, it is necessary to verify how
much time the urban bus operates on each fuel in order to calculate
the correct amount of emission reduction.
Therefore, any program that includes dual-fuel, flexible- fuel,
or hybrid electric vehicles must include a provision to ensure that
vehicle miles on each fuel can be calculated reliably. This will
ensure that the calculation of the credit more closely reflects the
actual reduction in emissions from operation on both fuels. One
way to ensure accurate reporting is by equipping urban bus
refueling facilities with "fuel keys," which act to track, by
computer, the fuel type dispensed to each urban bus. Such a
system can be expanded to permit coding of appropriate mileage
records, to enable accurate calculation of vehicle miles traveled
on each fuel. Any system which accurately distinguishes between
the different fuels used and vehicle miles travelled would be
acceptable. The ideal system would have minimal reliance on human
factors. Fuel and/or additive purchase receipts adequate to cover
the mileage claimed may also be required.
ELEMENT .4. Urban buses can be new or converted.
_ converted urban buses/engines are eligible to generate
credits as long as they comply with the same provisions and
emission standards which apply to new urban buses.
Retrofit /rebuild conversions must be certified in accordance with
the provisions of the urban bus retrofit/rebuild program and meet
the appropriate emission standards and durability requirements.
ELEMENT 5. Urban buses should pass an annual I/M test.
A test is desirable to insure the vehicle is running correctly
in use. Urban buses should pass an annual emissions performance
check where available. States may require a decentralized testing
program if they desire, or require other means, such as in house
testing, to insure compliance.
ELEMENT 6. Credits will be calculated annually, preferably on
a calendar year basis .
This element is necessary to ensure that the generation of
credits coincides on a time period basis with the purchase, use,
and compliance decisions which normally occur. The normal model
year for heavy-duty engines is the calendar year and credits for
trading can easily be determined on a yearly basis. Furthermore,
the parameters for that year should be the same as used in credit
use programs to simplify enforcement, ensure consistency, and
discourage gaming. Therefore, for the. purpose of calculating
emission reduction credits, vehicle miles traveled will be measured
from January 1 through December 31 of each year for each credit
generating vehicle in service, and the credit will be calculated
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for that period. However, other annual periods would probably be
acceptable depending on state preference.
ELEMENT 7. Credits shall be calculated on a pollutant specific
basis.
This program will focus on reductions in emissions from NOx,
and PM. Testing must be conducted to show that no other regulated
pollutant emission rates increase; in cases of pollutants for which
there is no standard, emissions must not be worse than those of
urban bus engines of the model year not in the program. Credits
may not be generated for urban bus HC and CO emissions due to the
fact that HC and CO emissions from current diesel urban bus engines
(the dominant technology now in use) are already significantly
below the respective standards.
ELEMENT 8. Credits can only be generated by urban buses which
states choose to include in the program.
Urban buses are a special sub-category of heavy-duty engines.
The federal emission standards apply to all urban buses while the
retrofit/rebuild program applies only to urban bus fleets in the
larger metropolitan areas. States have the option of choosing
whether to participate in the program and whether to extend the
credit program to all urban buses used within their state
regardless of whether or not they are in an area covered by the
retrofit/rebuild program. This potentially increases the pool of
credits available.
ELEMENT 9. Urban bus engines used in the certification AB&T
programs or in TLF calculations cannot also
generate credits for trading.
The AB&T credit exchange programs are designed to be used by
engine manufacturers during certification. To avoid . double-
counting, new clean technology urban bus engines which generate
credits for certification cannot also be claimed by the bus fleet
operators to generate credits for this trading program. The
ownership of these credits must be determined between the engine
manufacturer and the bus fleet owner and records kept.
Retrofit clean fuel technology urban bus engines cannot be used in
the TLF calculation and also generate credits under this program.
To generate credits they must be declared as TLF opt-out engines.
VI. Conversion Factor Requirements
Credit generation and transactions will likely be based on
mass emissions. However, heavy-duty engine testing produces
emission rates in terms of g/bhp-hr. These emission rates in
g/bhp-hr need to be converted into g/mile figures to facilitate
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calculating the equivalent mass of emission reductions for purposes
of trading with other sources. Thus bhp-hr/mile conversion factors
need to be developed for vehicle/engine configurations which are to
be used to generate credits. Because the bhp-hr/mile conversion
factor is engine specific, it must be developed experimentally by
testing. For new or retrofit/rebuild urban bus engines using clean
technology, this calculation may be done using the information
developed as part of the certification process as is prescribed in
the heavy-duty AB&T programs.
VII. Cradit Calculation
Credits will be calculated based on the number of miles
traveled by each vehicle each year, adjusted by the degree to which
the vehicle is cleaner than a conventional vehicle. States may c]
calculate credits in one of two ways: projected or year-end, as 3|
described below. A state's choice of method will depend on the
needs of its program. However, under either method, the state must
have a method to verify that credits given reflect actual emissions
savings.
The projection method of credit calculation ensures that
credits are used during the same year they are generated.
According to this method, credits are estimated and allocated at
the beginning of the year they are generated, based on an estimate
of how many miles the vehicle will travel that year. Then, at the
end of the year, the states must follow up with a verification
procedure based on actual vehicle miles traveled, to verify that
estimated emission reductions are the same actual emission
reductions. States using this method must provide a remedy to
correct estimation errors
The year-end method of credit calculation can be used to avoid
the extra burden and paperwork associated with the verification
procedure required by the first method. In the year-end'method, jj
states calculate and allocate credits at the end of the year, based |f
on actual vehicle miles traveled. Under this method, emission It
credits are used during the year after they are generated. &
. . . ' H
Under either program, credits are to be calculated according
to the following formula, in grams per year of each pollutant. For
the two different methods of calculation, VMT represents either
estimated or actual mileage, depending on which method is used and,
if the first method is used, whether the calculation is the
beginning of the year estimate or the year-end verification.
To calculate the credits generated by the purchase of a new
urban bus or retrofit/rebuild of an old- urban bus, the following
formula will be applied for each pollutant.
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IU x [(engine imp) x CF x VMT] - credit [grams/year]
where
(engine imp) = (applicable NOx/PM standard) - (Family
Emission Limit to which the urban bus is
actually certified) applicable standard
depends on the model year and whether the
engine is generating credits as a new or
retrofit/rebuild model
VMT = vehicle miles traveled in one year (actual or
estimated, depending on the method of credit
calculation adopted)
CF = conversion factor (BSFC x Fuel Econ x Fuel
Density), where
BSFC = brake specific fuel consumption
IU = adjustment to account for the emissions
difference caused by calculating credits
based on standards or FELs rather than in use
performance
The heavy-duty engine AB&T program uses the concept of Family
Emission Limit (FEL) as a surrogate for the emission standard for
credit generating/using engine families. A similar concept will be
applied here; credits will be calculated based on the difference
between the emission standard and the FEL not the difference
between the emission standard and the engine certification level.
Presumably, the FEL will be greater than the certification level to
account for deterioration, variability, etc.
In these calculations it is necessary to take into account the
emissions performance of buses in use relative to the performance
predicted by the emission standards/FELs alone. Changes can occur
for several reasons. These include differences in low mileage
targets with more stringent standards/FELs, unexpected
deterioration in the emission control system efficiency,
malmaintenance, hardware defects, and tampering. The credits
calculation includes a term (IU) to adjust for the effects of these
factors. Present best estimates are that IU should have a value of
0.79 for NOx and 0.6 for PM. However, it should be noted that
there are only a few certified urban bus engine families and
identifying one NOx and PM value to apply to the entire group is
problematic especially if the potential exists for a broad range in
values depending on the fuel or technology used. As more data
becomes available these values are subject to change.
When electric vehicles are used, the credit calculation may
need to be adjusted to account for additional NOx and PM emissions
related to generating electricity. Such a calculation will need to
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take into consideration how electricity is generated in that area.
It will be up to the affected states to determine the size of the
offset, depending on local electricity generating factors.
VIII. Special Issues
A trading program such as the one described in this document
poses at least two special problems. The first is that credits
could be given for an urban bus that does not actually have reduced
emissions. The second is the case when urban buses are driven
additional miles to generate extra credits.
The first case, when an urban bus is given credits even though
it does not have reduced emissions, is the more serious problem.
This may occur if the bus is not properly maintained and/or it is
defective. Since it is proposed that credits be calculated based
on the projected in-use emission levels derived in part from the
standards to which the engine is certified, and not on actual
emissions from an emission test on each engine, this problem would
be discovered only as a result of emission tests/inspections of
that urban bus configuration.
While urban bus emission failures would seriously undermine
the credit program, EPA does not believe it will occur at such a
rate that more than annual tests should be retired. All new 1994
and later bus engine families will be part of an EPA in use testing
program as required by the Clean Air Act. Since urban buses will
ideally be subject to some in use test, EPA believes that it is
unlikely that credits would be allocated for urban buses that fail
to reduce emissions. Credits are calculated annually and most
emission failures would be brought to the attention of the owner
during that year through the test programs. In cases where an
urban bus configuration fails an emission test/inspection, those
urban buses would either not be allocated credits for that year, or
would be allocated a prorated share of credits based on actual
emissions. In cases where a formal state I\M program is not
available, a substitute program may be acceptable. Similarly
emission credits would need to be adjusted if the engine is
involved in an emission recall program.
EPA believes that the second .case, where a bus is driven
additional miles to generate credits, is unlikely to occur. The
additional costs of generating those credits, in both fuel and
time, may not be worth the extra credits generated. Furthermore,
if urban bus operators allocate more miles to their credit
generating bases and fewer to their other buses for the purpose of
generating more credits, this is in keeping with the spirit of both
programs, which is to generate fewer emissions. Urban bus
operators that adopt this strategy are entitled to the extra
credits they generate.
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However, to ensure against misrepresentations, states may
consider comparing miles traveled on a year-to-year basis, to
detect unlikely increases in number of miles traveled. Audits of
mileage and fuel use records may also be used as a check against
tampered odometers on vehicles.
IX. Administration of th« Program
As noted above, states would be required to design and
administer their own programs. However, EPA advises that all state
programs contain elements and methods of calculation similar to
those described above to ensure that emission reductions are being
achieved. If a state does not follow this guidance, it must
demonstrate that the emission reductions are achieved.
Finally, it should be noted that the states in which the
program will be run have the ultimate responsibility of ensuring
that both the urban bus credit generating provisions and trading
programs are implemented in accordance with their respective
requirements.
r
TABLE - 1
Areas Affected by the Urban Bus Retrofit/Rebuild Program
Area
1'980
Population
Albany-Schenectady-Troy N.Y.
Atlanta (Marietta) , Ga.
Baltimore, Md.
Birmingham (Bessemer) , Al.
Boston-Lawrence-Salem Ma. -N.H. CMSA
- Boston (Cambridge, Framingluun, Lynn, Waltham) PMSA
- Brockton PMSA
- Lawrence-Haverhill PMSA
- Lowell PMSA
- Nashua N.H. PMSA
T- Salem-Glouchest«r PMSA
Buffalo-Niagra Falls, N.Y. CMSA
- Buffalo PMSA
- Niagra Falls PMSA
Charlotte-Gastonia-Rock Hill
N.C.-S.C.
835,880
2,138,231
2,199,531
883,946
3,971,376
1,242,826
971,391
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Chicago-Gary-Lake 111. -Ind. -Wis . CMSA
- Aurora-Elgin 111. PMSA
- Chicago (Evanston, Chicago Heights) 111. PMSA
- Gary-Hammond (East Chicago) , Ind. PMSA
- Joliet 111. PMSA
Kenosha, Wis. PMSA
Lake County (North Chicago, Waukegan only)
Cincinnati, Oh. -Ky . -Ind. CMSA
- Cincinnati, Oh.-Ky.-Ind. PMSA
- Hamilton-Middletown, Oh. PMSA
Cleveland- Akron-Lorraine, Oh. CMSA
- Akron (Barberton, Kent) PMSA
- Cleveland PMSA
- Lorain-Elyria, PMSA
Columbus, Oh.
Dallas-Forth Worth Tx. CMSA
- Dallas (Denton, Irving) PMSA
- Fort Worth-Arlington PMSA
Dayton-Springfield Oh.
Denver-Boulder, Co. CMSA
- Coulder— Longmont PMSA
- Denver PMSA .
Detroit-Ann Arbor, Mi. CMSA
- Ann Arbor PMSA
- Detroit (Dearborn, Pontiac, Port Huron) PMSA
Greensboro-Winston-Salem-High Point, N.C.
Hartford-New Britain-Middletown Ct. CMSA
- Bristol PMSA
- Hartford PMSA
- Middletown PMSA
- New Britain PMSA
Honolulu, Hawaii
Houston-Galveston-Brazoria, Tx. CMSA
- Brazoria PMSA
- Galveston-Texas City PMSA
- Houston (Baytotm) PMSA
Indianapolis/ Ind.
Kansas City, Mo.-Ks. CMSA
- Kansas City (L«*tr«n*orth, Olathe) , Ks . PMSA
- Kansas City, Mo. PMSA
Los Angeles-Anaheim-Riverside, Ca. CMSA
- Anaheim-Santa Ana PMSA
- Los Angeles-Long Beach (Burbank, Pasedena, Pomona, Palm
Springs) PMSA
- Oxnard-Ventura PMSA
- Riverside-San Bernardino PMSA
Louisville, Ky.-lnd.
7,937,326
1,401,491
2,834,062
1,243,833
2,930,516
942,083
1,618,461
4,752,820
851,851
1,013,508
762,565
3,101,293
1,166,575
1,433,458
11,497,568
956,756
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Memphis, Tenn. -Ark. -Miss .
Miami-Fort Lauderdale, Fla. CMSA
- Fort Lauderdale-Hollywood-Pompano Beach PMSA
- Miami-Haileah (Miami Beach) PMSA
Milwaukee-Facine (Waukesha) , Wi . CMSA
- Milwaukee PMSA
- Racine PMSA
Minneapolis-St. Paul, Mn.-Wi.
Nashville, Tn.
New Haven-Waterbury-Meriden, Ct.
New Orleans (Slidell) , La.
New York-Northern New Jersey-Long Island, N.Y.-
N.J.-Ct.
- Bergen-Paasaic, N.J. PMSA
- Bridgeport-Milford, Ct . PMSA
- Danbury, Ct. PMSA
- Jersey City (Hoboken) , N.J. PMSA
- Middleaex-Someraet-Hunterdon (Mew Bruswick, Perth Amboy) ,
N.J. PMSA
- Monmouth-Ocean, N.J. PMSA
- Nassau-Suffolk, N.J. PMSA
- New York, N.Y. PMSA
- Newark, N.J. PMSA
- Norwalk, Ct . PMSA
- Orange County, PMSA
- Stamford, Ct . PMSA
Norfolk-Virginia Beach-Newport News (Hampton,
Portsmouth, Suffolk) , Va.
Oklahoma City (Norman, Shawnee) , Okla.
Philadelphia-Wilmington-Trenton, Pa. -N.J. -Del. -
Md. CMSA
- Philadelphia (Norristown) , Pa. -N.J. PMSA
- Trenton (Camden) , N.J. PMSA
- Vineland-Milville-Bridgeport, N.J. PMSA
- Wilmington, Del.-N. J.-Md. PMSA
Pheonix (Mesa-Scottsdale-Tempe) , Az.
Pittsburg-Beaver Valley, Pa. CMSA
- Beaver County PMSA
- Pittsburg (McK««aport) PMSA
Port land- Vancouver, Or.-Wa. CMSA
- Portland, Or. PMSA
- Vancouver, Wa. PMSA
Providence-Pawtucket-Fall River, R.I. -Ma. CMSA
- Fall River, R.I. -Ma. PMSA
- Pawtucket-Woonsocket-Attleboro, R.I. -Ma. PMSA
- Providence, R.I. PMSA
913,472
2,643,981
1,570,275
2,137,133
850,505
761,337
1,256,256
17,539,324
1,160,311
860,969
5,680,768
1,509,052
2,423,311
1,297,926
1,083,139
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Richmond-Petersburg, Va.
Rochester, N.Y.
Sacramento, Ca.
St. Louis-East St. Louis-Alton, Mo. -111. CMSA
- Alton-Granite City, 111. PMSA
- East St. Louis-Belleville, 111. PMSA
- St. Louis (St. Charles), Mo. -111. PMSA
Salt Lake City-Ogden, Utah
San Antonio, Tx.
San Diego (Escondido) , Ca.
San Francisco-Oakland-San Jose, Ca. CMSA
- Oakland (Berkely, Livermore) PMSA
- San Francisco PMSA
- San Jose (Palo Alto) PMSA
- Santa Cruz PMSA
- Santa Rose-Petaluma PMSA
- Vallejo-Fairfield-Mapa PMSA
Seattle-Tacoma, Wa. CMSA
- Seattle (Auburn, Everett) PMSA
- Tacoma PMSA
Tampa-St.-Petersburg-Clearwater Fla.
Washington, D.C.-Md.-Va.
- Washington D.C.
- Frederick Md.
- Arlington Vi.
761,311
971,230
1,099,814
2,346,998
910,220
1,071,954
1,861,840
3,606,100
2,093,112
1,613,603
3,250,822
Note:. Affected Areas Include all consolidated metropolitan statistical areas
(CMSAs) or metropolitan statistical areas (MSAs) with a 1980 population of
750,000 or more.
G:\srpb\passavan\bus.jl3
Last reviewed by G. Passavant:1/13/93
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