EPA-90871-77-006
    METROPOLITAN
IDENVER AIR PROGRAM
      WORKPLAN
    NOVEMBER 1977
   US. ENVIRONMENTAL PROTECTION AGENCY
        REGION VIII
    AIR & HAZARDOUS MATERIALS DIVBON
      DENVER . COLORADO 8O295

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            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                     REGION VIII

                                 I860 LINCOLN STREET

                               DENVER COLORADO 8O2O3
REF:  8AH-A
 Interested Parties:

     Metropolitan Denver presently has the worst air quality problem in
 any of the six states covered by the Environmental  Protection Agency's
 (EPA) Region VIII.  This air quality problem is critical  because of the health
 effects and the number of people affected.  The situation is complicated
 by the fact that the emissions are mainly from automobile traffic and more
 straight-forward pollution control options are not applicable.  The severity
 of this air quality problem dictates that its solution be given the highest
 priority within the region.  The attached workplan represents the Region
 VIII perception of an approach to reduce air pollution in the Denver area
 to healthy levels.

     The workplan is most specific in the role EPA will  be playing; however,
 the problem must be addressed by a coordinated effort with responsibilities
 identified at each level of government.  For this reason, we are proposing
 that an "Action Plan" be jointly developed by local , State and federal
 agencies by the end of February.  Such a Plan should identify (1)  specific
 strategies; (2)  the role of each agency; and (3)  a specific schedule to
 accomplish the plan.  The Clean Air Act Amendments of 1977 specifically
 identify local governments as having a role in addressing transportation-
 related pollution issues, and the approach outlined here gives us this
 opportunity.

     This Regional Office will immediately undertake a program to try to
 reduce the vehicle miles traveled (VMT) by its own employees.  This effort
 will be aimed at improving transit ridership and vehicle occupancy.  A
 number of approaches utilizing incentives and disincentives will  be inves-
 tigated and implemented as appropriate.  In addition to  the reduction in
 VMT measures, the EPA will also address several  policy issues, including how
 best to coordinate with Colorado's State Implementation  Plan revision efforts
 and how to handle construction grant applications in non-attainment air
 quality areas.  Also, this agency, in conjunction with State and local  efforts,
will launch a major public involvement campaign.

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     The Regional Office program to reduce VMT will  be in  place  by February
1978.  The next major step will  be to implement a similar  program for other
federal agencies, since about 43,000 people in metro-Denver work for the
federal government.  Our current plans call for extensive  support to the
federal agencies, including assistance in formulating effective  carpool
matching programs, identifying potential  employer incentive programs and
other assistance as needed.  A major goal of the federal sector  portion
of the program is to set an example for the private  sector.

     The aforementioned efforts will constitute a start towards  cleaning up
metropolitan Denver's air problem.  The metropolitan air pollution problems
can only be solved through a coordinated effort with each  level  of government,
private business, and individual citizens giving the program a top priority.
                                     Alan Merson
                                     Regional  Administrator

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                                       EPA-908/1-77-006

                                       November 1977
METROPOLITAN DENVER AIR PROGRAM - WORKPLAN
                Prepared by

       Dale Wells     John Philbrook

       David Kircher  Charles Stevens

              Sally Rawlings
   U.S.  Environmental  Protection Agency
      Region VIII, Denver, Colorado

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                       DISCLAIMER

     This report has been reviewed by the Region VIII
Office, U. S. Environmental Protection Agency, and
approved for publication.  Mention of trade names or
commercial products does not constitute endorsement
or recommendation for use.
     Copies of this document are available to the public
through the National Technical Information Service,
Springfield, Virginia   22161

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                    Denver Air Program Workplan
                         Table of Contents
  I.   Introduction                                                        Page

      Goals and Objectives  .        ......     2
      Action Plan           .        ......     3
      Information Gathering .        ......     4


 II.   Program Design

      Public Involvement    •        •••-..     7

      Policy Development    •        •       •       .       .       .       .13

        A Construction Grants Policy
        A State Implementation Plan Policy

      Motor Vehicle Emission Control       •       •       .       .       .16

        High Altitude Emission Standards
        High Altitude Performance Adjustment
        Federal Vehicle Inspection/Maintenance
        Inspection/Maintenance

      Employer Incentives   •        •••...   23

        EPA Demonstration
        Federal Government Employee Incentive Program
        State/Local Government Employee Incentive Program
        Private Sector Employee Incentive Program

      Transportation Management     •      •      •      .      .      .29

        Headquarters Coordination
        Coordination with Departments  of Transportation and Energy
        Development of Federal Regulations
        The NEPA Process
        Coordination with RTD
        Coordination with Denver COG
        Transit Planning
        Coordination with Denver Planning and Traffic Engineering
        Bicycle Planning


III.   Appendices

      Appendix A:   Denver Air Program  Workplan Schedule and Flow Chart    40
      Appendix B:   Background      •       •       •       .       .       .44
      Appendix C:   Questionnaire   •       •       •       .       .       .47
      Appendix D:   Regulation 9    •       •       •       •       .       -54
                                i n

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INTRODUCTION

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                         GOALS AND OBJECTIVES


     The Denver air quality problem is one of the most severe in the
United States.  At least one study has shown Denver's carbon monoxide
problem to be the worst in the country.  Oxidant violations occur at
more than one of the six monitoring sites in Denver most days in the
summer, and Denver ranks in the worse 5 to 10 oxidant cities in the
country.  Particulate levels in Denver typically are more than 60%
over the annual average primary standard.  For all of the above pollu-
tants, the automobile is the primary cause.

     This work program is to be executed in  conjunction with the de-
signation of Denver as a "National Demonstration City for Air Quality."
We intend to undertake a program to improve  air quality in Denver to
set a national example.  The recommended program will be staged.  First
EPA will undertake a number of programs in the Regional Office to improve
transit ridership and vehicle occupancy to set an example.  As these
internal programs take shape we will involve the balance of the Federal
agencies in Denver and finally move the program into the private sector.

     The primary goal of this program is to  make a dramatic improvement
in air quality in the Denver metropolitan area in the next few years.  We
will be investigating every conceivable strategy for possible application
in Denver.   From this investigation we will  select for implementation those
strategies which seem to offer the most promise for improving air quality
and we will also consider what other benefits it might be reasonable to
expect from the imposition of those strategies.   Our overall objective will
be to reduce emissions.  To accomplish this  we will attempt to reduce travel,
increase auto occupancy and reduce emissions from individual automobiles.
Other benefits which we will emphasize in designing our program include cost
savings, energy savings, improving the urban life style and reducing travel
times.

     In conjunction  with our efforts in the  above areas we will launch a
major public involvement program.   We believe it necessary to increase EPA's
constituency and develop grass roots support for our programs.

     In summary, the real  goal of the Denver air quality program is to
improve human health conditions in the Denver area, and as a secondary benefit
hopefully to improve visibility through the  reduction of the emissions of the
particulate matter.
                                 -2-

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                          THE ACTION PLAN
     An Action Plan for Denver air quality will be developed by January
31, 1978.  The Action Plan is the primary output of the execution of
this work plan.  The plan will consist of specific work elements for
the implementation of a number of different programs.  There are three
major efforts which the program plan will cover.  These are:  Transporta-
tion Policy Management, Motor Vehicle Emission Control, and Employer
Incentives.  These three thrusts will constitute the main portion of the
Denver air program.  The plan will lay out, with some specificity, items
which will, beginning next February, be accomplished in each of these
three areas and will assign dates by which the items will be accomplished.
The period between mid-November and January will be spent developing
specific programs in these three areas, which we will begin implementing
early next year.  This work plan will not cover the specifics to be
accomplished in each of the three major program areas, but rather, will
lay out the items which we must accomplish to develop the specific
programs.  In other words, this document is a plan for a plan.   There are
three other efforts which cannot be included in any of the three major
work areas listed previously, but which are equally important.   The first
of these is the development of a consistent policy to deal with a con-
struction grants program in the Regional  office.  The goal of this program
will be to have, by January 31, 1978, a written policy specifying how we
will write construction grant conditions relating to air quality.

     Another very important policy area relates to the Colorado State
Implementation Plan (SIP).  The State of Colorado is in the process of
making significant revisions to the State Implementation Plan.   EPA's
efforts in the three program areas -employer incentives, transportation
policies, and motor vehicle emissions control - must fit closely with the
State Implementation Plan.  In some cases, we may wish to promulgate
strategies which EPA is carrying out.  In other cases, we may decide that
our programs are not appropriate for the State Implementation Plan.   In
any case, we need to establish a framework for making those decisions on
a case by case basis.   Hence, by January 31, 1978, we will have a written
policy regarding Action Plan strategies and the Colorado State Implementa-
tion Plan.  The third miscellaneous area which we must address is the
development of a mechanism to include Headquarters'  input into the process.
Each of these three areas will be discussed in greater depth later in this
chapter.

     As we begin the efforts to develop the Action Plan, we will simultaneously
launch a major public involvement program.  This program will run parallel to
all our efforts on a continuing basis until our program is complete.
                                  -  3 -

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                         INFORMATION GATHERING


      The efforts of the next three months will  largely be oriented
 gathering information.   Gathering this information will  allow us to draft
 the specific policies just discussed and to complete Action  Plan items
 for three major program areas.   This information  gathering process will
 lead to a minimum of six specific Action Plan items by the end of January.
 The first three of these items  will be specific plans and_timetables to
 implement the employer incentive program, the transportation policy
 program, and the motor vehicle  emission control  program.   The second
 three will be the construction  grant policy,  the  SIP policy, as well as  a
 formulized mechanism to involve EPA Headquarters  in the Denver decision
 making process.

      The information gathering  process will  consist of a  number of different
 efforts.  The primary effort will  be centered on  the development of a number
 of literature searches  in  the various  program areas.   It  is  vital  that we
 understand what has been done in other cities relating to our three program
 areas.   We must understand how  successful  air quality/transportation initia-
 tives have been and how they might relate to  the  Denver situation.  Much of
 this research will  be done by EPA personnel  here  in the regional  office.
 We will  also need a significant amount of legal research  in  order to enable
 us to determine what kinds of things in  each  of these three  major areas  we
 can legally require under  existing legislation, especially the Clean Air
 Act.   In many cases,  these efforts will  be breaking new ground, since many
 of the  poltey questions  that have  arisen  as a result of the  Clean  Air Act
 Amendments  have not yet  been addressed.

      Another major  category  in  the information gathering  process will  be
 interviews.   It will  be  necessary  to interview federal, state and  local
 agencies  here in  the  Denver  area.   Interviewees will  include the Federal
 Highway  Administration,  the  Department of  Interior,  Department of  Energy,
 Department  of Housing and  Urban  Development,  Denver Regional  Council  of
 Governments,  Urban  Mass  Transportation Administration,  Denver Planning
 Office,  and  various  local  elected  officials.

     The  primary  purpose of  this effort will  be to  increase  the knowledge
 of  regional  EPA  personnel who work  in  the  Denver  Air Program regarding what
 things are being done in the  Denver  area which might have a  direct bearing
 on Action Plan activities.   In addition,  there is  a great necessity to
 avoid duplication of effort with other federal, state and local  agencies.
 For example there are a number of ongoing  efforts  in  the  area of carpooling
which EPA would not wish to duplicate.  EPA personnel must understand  the
 nature and extent of these programs  to avoid  duplicating  the  efforts of the
Air Pollution Control Division or  Denver's Health  Department.
                                  -4-

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     Interviews will also be conducted with Headquarters personnel  who have
expertise in the transportation area.  Primarily, we will  be contacting the
Office of Transportation and Land Use Policy and the Office of Air  and Waste
Management to solicit  their suggestions and input.  Additionally,  it is
necessary to interview state and local agencies in selected other states.
As an example, the Association of Bay Area Governments has accomplished a
number of things through the 201 Construction Grant process which we have
not yet accomplished in this Region.  Grant conditions have been written
to require the grantees to get involved in air quality planning.  It is
essential that we draw on expertise developed  by other state and local gov-
ernments where appropriate.

     Large amounts of information will be gathered and assimilated  in this
initial phase of the Action Plan development.  For that reason,  it  is impor-
tant to establish an information handling system.  We expect to  work with
the EPA regional library to develop efficient means of retrieving the infor-
mation which we will be collecting.  EPA personnel have already  made arrange-
ments for shelf space in the library to store information  relative  to the
Denver program.  This information will be available for use by persons
assigned to the Denver Air Pollution Program on an overnight basis.   Other
than that, the material will not be allowed to be removed  from the  library
area.
                                   - 5 -

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PROGRAM DESIGN
     -  6  -

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               PUBLIC INVOLVEMENT
"Generally, the public understands...(the direct
relationship) between automobile use and air pol-
lution in the region.  Less well comprehended are
such factors as the health hazards and property
risks of air pollution, the effect of land use
patterns or influences of capital investment
decisions on transportation, air quality and
energy.   Perhaps least clear to the public are
the methods by which citizens could become in-
volved in working toward solutions to these inter-
woven problems in a meaningful way, although many
people are genuinely concerned about the health
and welfare of future urban populations."
                         ROMCOE Forum - Summer 1977
"We have met the enemy and he is us."
                         Pogo
                        - 7  -

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 Introduction

      Success  in  the implementation  of a major effort  to clean  up the air
 in  the Denver metropolitan  region  is  highly  dependent on  some  form of
 public participation and  support at each step in  its  development.   More
 simply, only  the public can make it work.

      Public involvement in  this effort may be based on  the  following premises:

      1.  The  quality of air in  Denver is frequently poor.   The public J
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Information

     The public involvement program will require a broad range of
factual and policy information.  Much of this will come from our
own staff, but outside sources will be utilized.  Information
"packages" are needed on topics such as:

     1.  The physical environment - topography, meteorology,
         plants, man-made structures, air quality data and
         the like.

     2.  History of Denver Air - the product of an investigation
         into the past trends in the nature and concentration of
         pollutants (e.g. domestic coal-burning) and the history
         of past concerns and actions to correct the problem.
         There is a considerable body of information available in
         newspaper files, libraries, historical societies, aerial
         photo files and in personal experiences (senior pilots,
         weather types, etc.).  (This study will be done by a
         graduate student in local history).
         Relevant experiences - a twofold search for useful  data
         for public presentation, and for useful techniques  in
         applying our program (e.g.  San Diego air, 1976 Olympics,
         RTD campaigns).
     4.   Technical data - nature and sources (point and mobile)
         of pollutants, successes and failures of controls,  micro-
         climatic characteristics of urban air, etc.

     5.   Cost data - economics of vehicle operation and maintenance
         comparative costs of transportation modes, etc.

     6.   Advanced systems - accumulation of information for  public
         presentation on future transportation technologies  (a long-
         range view to complement short-range actions).

     7.   Particulate sources - an investigation of the potential  for
         a metropolitan-wide effort to reduce visible particulates
         originating from unplanted surfaces (streets, sidewalks,
         vacant lots, rights-of-way).   Such an effort would  require
         broad community action.

     8.   Psychology of the automobile - a critical review of experience
         and literature, quite possibly requiring a citizen  survey.

     9.   Health - Douglas Costle said "we have created a  huge health
         effects research laboratory."  We need to examine current
         knowledge with assistance from qualified people.  We are
         planning a national  health/air seminar.   We  may  wish to
         support specific studies.
                                - 9 -

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Resources

     Considerable effort will  be made to identify and work with
supportive private and public  organizations  and individuals.
This will be an interactive process, as we will need to learn of
current efforts paralleling ours and to fit  the pieces together.
These are good people willing  and anxious to work with us.   This
effort is partially under way  now.

     We envision, as part of the public involvement program,  the
formation of advisory groups (formal or otherwise)  of health
experts, of citizens, and perhaps from industry and local  govern-
ments.

Methods

     Essential to the operation  of this program will  be an  appropriate
mix of methods of communication  with the public.   It  will  be  necessary
to work very closely with the  Regional  public affairs staff,  and to
rely on their expertise in techniques  and timing,  and to rely on their
participation in the actual  operation  of the public involvement program.

     Methods will  include:

     1.   Materials - the production  of publications,  films  (including
         time-lapse cinematics), posters, buttons,  bumper stickers,
         T-shirts  and the like).   The  publications  will  include simple
         folders on various  topics,  but we are  also exploring the
         preparation of a Citizen's  Manual which would provide some
         depth on  such items as  altitude, I/M,  health, transportation
         alternatives, etc.  Full  use  will be made  of PSA slots on
         radio and TV, with  "tag-on"  spots suggesting that the
         audience  write AIR, EPA,  BOX	for further information.

     2.   Presentations -  speakers  and  participants  in meetings, panels,
         and perhaps debates will  be necessary.   Care must  be taken to
         ensure that a proper mix  is maintained - neighborhood groups
         (including  core  city),  service clubs,  Scouts, technical  groups,
         church groups,  garden clubs,  whatever.   Inasmuch  as  public
         input  is  of highest importance,  dialogue must be  sought; the
         town meeting  concept is  useful.

     3.   Visual monitoring - use of  photography,  traffic aircraft,  etc.
         The public's  visual awareness  must  be  kept open,  and  refined.

     4.   PSI -  we  have  progressed  in obtaining  media  cooperation  in  the
         use of the  Pollutant Standard  Index.   Further efforts  will  be
         required  to provide the service  which  the  media has requested
         (hourly PSI?, weekend data, video tapes supplementing  the  index,
         etc.).  State air staff cooperation  is  evident, although some
         financial assistance may be need to  support added service.
                               - 10 -

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     5.  Pollutant monitoring - we will examine the possibility of
         utilizing mobile and/or personal monitoring to dramatize
         actual individual exposures (e.g. commuter trip, Bronco
         practice field).

     6.  Education - preparation and presentation of suitable in-
         formation for schools and colleges in the Denver area.
         This is a supportive resource that we have neglected in
         the past.  Never underestimate the capacity and power of
         a student ("the children are watching" - they are learning
         from our example).

     7.  Joint efforts - many of these efforts will benefit from
         joint sponsorship with other groups or agencies.  This
         process will add strength and avoid duplications on
         certain facets of the program.

     8.  Independence Day - the desirability of an Air Pollution
         Independence Day (July 1978?) will be further explored.
         On this day, people would be asked to make special efforts
         to pool, ride the bus, bike, or walk.  Downtown displays
         and speakers would be available.  Possibly the proposed
         16th Street Mall could be simulated by excluding traffic
         on the planned route.

     9.  Survey - it may be desirable to undertake a citizen
         {driver? voter? youth?) opinion survey of:

               1.  Willingness to change, adapt, pay.

               2.  Attitudes and perceptions.

               3.  Importance of personal transportation.

Program Implementation

     In a very real sense, the program is already under way, with or
without our input.  The public is being informed and is responding.
It is important in the operation of the Regional effort to avoid the
image of EPA charging in on a white horse to start something, when
efforts are going on.  Our strong commitment,  however, does provide
a new focus for action.

     We will be carrying out our own activities - many of them
simultaneously with other efforts.   We need to be sensitive to public
opinion, and our program must be open, informative and accessible.
                                - 11 -

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     In as much as our first automobile travel reduction "module" is aimed
at EPA employees, we will begin to involve these people immediately.  The
emphasis will be on the need for this segment of Denver's population to
set an example which will produce results.   We will use:

      1.   Questionnaire - to obtain information on commuting habits
          planned for distribution by Monday, November 28.

      2.   Materials - available brochures,  films (brown-bag sessions-
          DOT films), posters,  handout sheets, etc. (initial distribu-
          tion at Trinity meeting).

      3.   Slogan contest - to be announced  at Trinity meeting.

      4.   Progress reports - it is important that our people be informed
          on our efforts and on the results of their efforts.   An employee
          newsletter, along with Trinity  meetings, will  be  used.

      5.   Employee input - case experiences or suggestions  will be welcome
          at any time.   It is proposed that the EPA employee participation
          program be introduced at the next Trinity Church  meeting.

     Experience in the  development and implementation of the EPA commuter
program will  provide valuable information for the operation  of  the all-
Federal and  all-other programs.
                                   -12-

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                       POLICY DEVELOPMENT
     Two major policy issues must be addressed during the initial
phase (first three months) of the Denver Air Program:  (1) an EPA
construction grants policy and (2) an agreed upon State/EPA State
Implementation Plan policy.  These policies are essential ingredients
of the Denver Air Program since they will ensure consistency between
programs (Construction Grants and the Air Program) and between actions
of the various groups responsible for developing measures to improve
Denver's air quality.

     The specific details for this activity are presented on the
program element forms which follow.
                                  13 -

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Program Element:    Policy  Development
Activity:   Construction Grant  Policx
Objective:   Insure that Construction Grants Program is consistent

   achieving  air  quality goals	      .—
                        Activity Description
        Construction Grants are awarded to local municipalities or sanitation
   districts  for the purpose of planning, designing and constructing or up-
   grading sewage treatment plant capacity.  In many cases this additional
   capacity provides for growth in a metropolitan area.  EPA must decide if
   it wants to participate in funding excess capacity which will provide for
   growth in  an area that has increasing violations of air quality standards.
   If air quality standard violations result from excessive automobile travel,
   it may be  determined that a geographical area should not have additional
   sewage treatment capacity made available until such time as  limits on the
   use of the automobile are imposed.  A precedent was recently established
   in Region  VIII by imposing conditions on a Step One 201 facility grant.
   We now need to develop a framework necessary to make that same determina-
   tion for other facilities.   EPA has prepared a draft Environmental Impact
   Statement for eight proposed sewage treatment plants in the  Denver area.
   We will be making funding and sizing decisions on these plans shortly.  We
   must have our grant condition policy established before these decisions
   are made.

        The development of a construction grant policy would begin with
   general guidance from the Regional Administrator.  A task force established
  would be made up of representatives from the Construction Grants Program,
   Environmental  Evaluation Branch,  Air Program and EPA Headquarters Personnel.
   The task force would prepare drafts, circulate them to interested parties
  within the Regional  Office,  obtain comments from the all involved and
  finalize the policy after concurrence from the Regional Administrator.

       We propose  to produce a draft policy within three weeks of the
  initiation  of the program to develop the January 31 Action Plan for Denver.
  We expect  to have completed  and formalized the policy by the time imple-
  mentation  of the  Denver  Action  Plan begins in February of 1978.
                                   - 14 -

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Program Element:   Policy Development
Activity:  State Implementation Plan (SIP) Policy
Objective:  To define which programs will become a part of the SIP

  and to  assure consistency between EPA, State and local activities.
                         Activity Description
       A State  Implementation Policy must be developed in order to interface
  State efforts, federal efforts and local efforts.  The primary mechanism
  or vehicle for this interface  must be the State Implementation Plan.  The
  State of Colorado  is required  to have an approved implementation plan to
  attain and maintain all air quality standards.  The current Transportation
  Control Plan  (TCP) which  is a  subset of the State Implementation Plan (SIP)
  is deficient  and is being revised through the Air Quality Maintenance Plan-
  ning process.  The State  has completed their Air Quality Maintenance Analysis
  and is now gearing up  to  develop the new SIP revisions.

       Obviously, many of the activities contemplated to be accomplished by EPA
  in this work  plan may  also be  in the planning stage at the State Agency.  In
  order to improve State/EPA coordination, a policy regarding what items in the
  EPA program should be  included in the State Implementation Plan, what items
  are important for  the  -State to pursue, and what items are important for EPA to
  pursue must be formulated.  The ultimate output of this task should be docu-
  mented and jointly signed by the Air Pollution Control Commission and repre-
  sentatives from the Environmental Protection Agency as well as the Denver Air
  Quality Advisory Committee formulated by the Governor.  One appropriate
  mechanism to  develop such a document is to form a committee made up of
  representatives of the State Air Pollution Commission, the Air Pollution
  Control Division,  local governments, and the Environmental Protection Agency's
  Denver Task Force.

       We propose to have a draft of an agreement approximately six weeks after
  initiation of the program.  The final document will be signed on or before
  January 31, 1978.  The development of such a policy should preclude duplication
  of efforts by EPA, state  and local agencies.  It also may provide a mechanism for
  EPA to move ahead with promulgations in a number of areas so that items will be
  included in the SIP at an early date.

       It is vital that  we  give  considerable thought to those items to be included
  in the State  Implementation Plan in light of the recent Clean Air Act Amendments
  of 1977-   Sections 174, 175 and 176 of the Amendments give EPA and other federal
  agencies very significant powers regarding federal funding of any projects in
  non-attainment areas and  must  be an integral part of our SIP policy.
                                     15 -

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                       MOTOR VEHICLE  EMISSION  CONTROL
      Although there have been  emission  standards  for new  cars  since
 the 1968 model  year,  compliance  with  those  standards was  not required
 at  high altitudes.  At Denver's altitude,  the  higher ratio of fuel to
 air causes poor driveability and greatly  increased  emissions.  There
 is not enough oxygen  in the combustion  chamber  to ignite  all the fuel,
 or in the exhaust system for a catalytic  converter  to react.   The  result
 is that emissions at  high altitude  are  approximately twice that of sea-
 level .

      On October 18, 1974 EPA promulgated  regulations (39  FR 37300) for
 the certification of  1977 and  later vehicles  intended for sale above
 4,000 feet in elevation.   The  regulations required  that new vehicles be
 tested under high altitude conditions.  The regulations allow  manufacturers
 the alternative to design vehicles  intended for use at high altitude with
 (1) fixed calibrations  capable of meeting emission  standards only  at high
 altitude, or (2)  automatically variable calibrations capable of meeting
 emission standards at both low and  high altitude  without adjustment or
 modification.  A \ehicle model not  intended for sale at high altitude did
 not require high  altitude certification,  and  initial sale of such  vehicles
 for high altitude use was prohibited.

      Most manufacturers chose  to certify  vehicles with fixed calibrations
 for high altitude, since this  is the  least expensive option.   Thus, 1977
 vehicles were certified for use  either at sea-level or for 5,200 feet
 (the altitude specified for high altitude certification), and  most
 vehicles certified for  one altitude do not meet standards at the other
 altitude.

      Only about  2.5%  of all  cars  sold in  the  United States are sold at
 high altitude.   Because of limited  projected  sales  of certain  models and
 options,  manufacturers  simply  did not bother  to certify many vehicles for
 high altitude,  thus limiting the diversity of cars  provided for sale in
 Denver.   As  a result, some individuals purchased  vehicles at low altitude
 which  were not  designed  for  use  or modification for use at high altitude.
 There  is  no  assurance that used  1977  vehicles sold  in Denver will  be
 adjusted,  or will  be  capable of  being adjusted, for high altitude.

     Thus,  the  intended  impact of the EPA regulation on reducing emissions
 was  not  completely  realized and  the public blamed EPA for not  having a
 full selection of  new models and  options.  New car  dealers at  high
 altitude also claimed they  had lost sales.

     The Clean Air Act Amendments of  1977, Public Law 95-95, revoked EPA's
 high altitude regulations  until  the 1981 model year.  EPA may  implement
 high altitude requirements  from  the 1981 model year to the 1983 model
year pursuant to Section  202 (f)   of the Clean Air Act.   However,  such
 requirements cannot require more  control  than a 90% reduction  from  1970
model year vehicle emissions at  high  altitude.  Beginning  in  1984,  all
 light duty vehicles must meet the statutory emission standards  (0.41 HC,
3.4 CO, and 1.0 NOJ regardless  of altitude.
                  A

                                  -  16 -

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     EPA can only require that vehicles are built to meet the emission
standards when properly maintained and operated.  EPA's testing of in-use
vehicles at low altitude indicates that the Federal motor vehicle control
program is not obtaining the expected emission reductions because of im-
proper adjustments and lack of proper maintenance.  Inspection and Main-
tenance (I/M) of in-use vehicles has been shown to be the most cost-
effective way to insure that vehicles are properly maintained.  The
Colorado program includes only 1977 and later model year vehicles because
it was the consensus of the Colorado decision-makers that, since these
are the vehicles required to meet emission standards at high altitude,
they are the only group of vehicles for which sufficient emission re-
ductions could be gained to make a program worth considering.  The mor-
atorium on high altitude compliance may cause postponement of the Colo-
rado I/M program.

      The reason for the moratorium on high altitude certification seems
to be that new car dealers at high altitude claimed severe hardship due
to loss of sales, since manufacturers did not offer many models and options
at high altitude.  EPA has been aware of the problems caused by limited
model and option availability in high altitude areas.  Meetings were
held by EPA and the National Automobile Dealers Association with the high
altitude dealers, and EPA personnel visited many individual dealers through-
out the high altitude area.  While it is true that there has been some
loss of sales, the claims of severe hardship are untrue.  In addition,
the limited availability has not been caused by the inability of the man-
ufacturers to meet emission standards at high altitude, but largely by
marketing decisions based on the fact that only 2.5% of nationwide sales
are at high altitude.  Limited EPA testing of in-use 1977 high-altitude
certified vehicles indicated that such vehicles were cleaner than their
sea-level counterparts.  High Altitude Certification for the entire line
of vehicles sold at sea-level would have been no more expensive than for
those actually certified.  The EPA regulations required only one test ve-
hicle per engine family and emission control system combination.  The models
and options which were certified for high altitude in 1977 represent nearly
all engine families, and so the addition of other models and options would
probably not have required additional test vehicles.  The actual  cost for
certification would not have changed significantly.

     The Clean Air Act Amendments also require "High Altitude Performance
Adjustments."  The motor vehicle manufacturers are required to provide
instructions for each class or category of vehicles for which there are
Federal  emission standards.  The instructions should specify the vehicle
and engine adjustments and modifications necessary to insure emission
control  performance at different altitudes, pursuant to regulations
promulgated by the Administrator.  The promulgation of such regulations,
coupled  with an inspection/maintenance program to insure that the
appropriate modifications are made, could reduce emissions from 1968
through  1975 model  year vehicles by 25 to 50 percent.
                                   -  17  -

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     We will not pursue the provision for "New Motor Vehicle Emission
Standards in Non-attainment Areas," Section 177 of the Act as amended.
States with non-attainment areas may adopt the California Emission  •
Standards if they have an approved non-attainment area SIP revision.
The standards must be adopted by both California and the State two years
before the effective model year.  Since we are now in the 1978 model
year, the first year which could be subject to the California standards
would be the 1981 model year.  Promulgation of high altitude emission
standards is provided for by the Clean Air Act for the 1981 model year,
and high altitude standards would be more effective than adoption of
the California standards.

     In summary, there are four activities of the Motor Vehicle Emission
Control Program:

     (1)  The development of high altitude emission standards for new
          vehicles to be effective with the earliest possible model year.

     (2)  The development of regulations to require the manufacturers to
          provide high altitude performance adjustments for vehicles not
          certified to meet emission standards at high altitude.

     (3)  Federal Vehicle Inspection/Maintenance to obtain early emission
          reductions from Government Owned Vehicles and additional experience
          for running an area-wide I/M Program.

     (4)  Inspection/Maintenance of in-use vehicles to insure that the
          new vehicle emission standards continue to be effective.
                                     -18-

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Program Element:   Motor Vehicle Emission Control


Activity:    High Altitude Emissions Standards
Objective:   Reduction of emissions from new cars
                         Activity Description


     Efforts to promulgate high altitude emission standards for new
vehicles should begin as soon as possible.  The Colorado Congressional
delegation should be briefed on the necessity to reinstate EPA's high
altitude certification program with the 1979 model year.  The
feasibility of meeting the 1979 standards at high altitude has already
been demonstrated, since the same standards were in effect with the
1977 model year.  To minimize the impact on the buying public, the Act
should be amended to require that all models and options sold at low
altitude should be certified for high altitude.  To minimize the economic
impact, the requirement  for sale of only new vehicles which have been
certified for high altitude could be limited to areas with a requirement
for an inspection/maintenance program in the SIP.  Parallel with the
legislative effort, EPA's Office of Mobile Source Air Pollution Control
should be urged to draft the appropriate regulations.
                                   -19-

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Program  Element:    Motor Vehl'c1e Bn1ss1on Contro1
Activitv    Hl'gh altitude performance adjustment
 -..   _       Reduction of emissions from 1968-1983 cars not certified
 Objective: 	—
 for  high altitude.
                         Activity Description
      EPA  now has the authority (Sec. 215 CAA) to require that motor vehicle
manufacturers design and submit adjustments and modifications to lower
emissions for 1968 and later vehicles not designed for high altitude.
Headquarters should be urged to promulgate such regulations as soon as
possible.

      Emission benefits of I/M Programs for pre-1974 model year vehicles by
EPA and Colorado have shovyn disappointingly low benefits because such
vehicles were never designed or adjusted to meet standards at high altitudes,
1975  and  1976 vehicles have shown greater benefits from I/M but high
altitude performance adjustments would increase the effectiveness for all
1968  through 1976 model year vehicles.  The approximate results of high
altitude testing of a simple high altitude device are shown below:

                             Model Year         Emission reduction

I/M alone                    1968 - 1974        11% HC      14% CO

I/M alone                    1975 - 1976        21% HC      24% CO

I/M w/modification           1968 - 1974        20% HC      50% CO

I/M w/modification           1975 - 1976        30% HC      60% CO

     Similar or greater benefits could be expected from 1977 through 1984
model  year vehicles which are not certified for high altitude.  (Even
with a high altitude certification program, many of the in-use vehicles
in the Denver area will be low altitude vehicles purchased outside the
high altitude area).   Requiring installation of high altitude performance
adjustments by new car dealers prior to initial  registration through I/M
will  be investigated.
                                   -20-

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Program Element:   Motor Vehicle Emission Control


Activity:   Federal Vehicle Inspection/Maintenance
Objective:  Reduction of Emissions from Federal Vehicles
                         Activity  Description
       Information on inspection/maintenance in general and on the
  Federal sector vehicle emission related maintenance practices would
  be gathered during the first three months of the program. This phase
  would culminate in the proposal of a federal vehicle I/M Program by
  the end of April, 1978.

       The Federal I/M Program would begin to be set up in October of
  1978.  Actual vehicle testing should begin no later than January 1,
  1979, one year prior to the start of the full scale Denver Regional
  I/M Program.  The Federal I/M effort would provide early reductions
  in emissions not otherwise obtained, and would also provide valuable
  experience for running the area-wide program.
                                    -21-

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Program Element:  Mntnr VphirlP Fmicci
                                      nn
Activity:  Jnspprt inn/Ma intpnanrp
Objective:  Maint.PnanrP of maximum emissinn redtirt.inn  through augmentation

of Colorado's  I/M Program.	.	



                        Activity  Description

      The Colorado I/M Program is  to begin  in  January  of  1980,  and will
 affect 1977 and later model  year  vehicles.  The enabling legislation
 requires that the legislature approve any  emission  standards,  and
 requires the resolution of several  questions  regarding the  I/M Program:
 the cost and effectiveness of I/M under high  altitude conditions, the
 durability of catalytic converters  on in-use  vehicles, and  the effective-
 ness of I/M on high mileage  1975  and 1976  vehicles.

      The Office of Mobile Source  Air Pollution  Control,  Region VIII,  and
 the State of Colorado are cooperating in a test program  to  answer these
 questions.   The data from the present and  past  high altitude test pro-
 grams, test programs concerning I/M at sea-level, and the experiences of
 other states with I/M programs  in actual operation must  all  be pulled
 together to develop and support a viable I/M  Program  for Denver.

      Denver is a non-attainment area for carbon  monoxide and oxidants,
 and  thus SIP revisions must  be developed under  Section 172  of  the Act.
 A requirement of such a SIP  revision is  that  it "provide for the  imple-
 mentation of all  reasonably  available  control measures as expeditiously
 as  practicable."

      The high altitude test  programs have  shown  that, for 1968 through
 1976 vehicles undergoing  both high  altitude modifications and  I/M, the
 emission reductions  are similar to  those now  being  credited by EPA to
 I/M  at sea-level.   Colorado,  however,  does  not  presently plan  to  cover
 such vehicles  in  their I/M Program;  only 1977 and later  model  year
 vehicles will  be  affected.   Thus, the  present Colorado I/M  Program does
not  provide  for  all  reasonably available control measures;  most of the
emissions would  be  left uncontrolled.

      Another  issue  arises from the  fact  that  Colorado plans a  de-
centralized  private  garage program,  less effective  in terms  of  quality
control  than  a centralized inspection  program.   Most  of  the  ongoing I/M
programs  in other states are centralized (Arizona's is operated by a
private  contractor,  Oregon and New  Jersey  have  state-run  programs).  The
principle reason that  Colorado chose a decentralized  system is  that the
safety inspection  are  now carried out  by private garages.  The  issue of
centralization   vs.. decentralization  should be  reconsidered in the
augmentation of Colorado's I/M Program.

                                    - 22  -

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                          EMPLOYER  INCENTIVES
     An employer  incentive program offers potential  in the short term
for decreasing air pollution  in the  Denver metropolitan area.  The
purpose of an employer  incentive program  is to encourage employees to
share rides and ride mass transit to and  from work.  Thirty seven
percent of the trips in  the Denver metropolitan area are work related,
hence a successful program can accomplish a great deal.

     There are a  number  of incentives which can be provided to employees
by their employers.  For example, employers can offer carpool matching
services, provide information on bus routes, and implement vanpooling
programs.  Employers can directly subsidize programs such as preferential
free or reduced-rate parking  for members  of carpools and vanpools and
reduced public transit  fares.  In Denver  some employers subsidize as
much as 50% of the cost  of riding public  transit.

     Everyone associated with an employer incentive  program derives
benefits.  The employee  who participates  has an opportunity to reduce his
commuting costs,  to conserve  valuable energy resources and to help reduce
air pollutant emissions.  The employer benefits from improved public re-
lations and saves operating costs by reducing the amount of parking that
he must provide adjacent to his facility.  The general public benefits
because air quality is  improved, and general traffic congestion and other
negative social impacts  of our transportation system are minimized.

     There are a  number  of ongoing efforts in Denver related to employer
incentives.  Regulation  9 of  the Air Pollution Control Commission in
Colorado established employer requirements for carpool matching.  That
Regulation is attached as Appendix D.  The program has been successful for
some employers who were  interested,  however the manpower to implement it
properly has not  been available.

     The EPA Employer Incentive Program as it is presently conceived con-
sists of four separate stages.  The  first stage involves the demonstration
of the effectiveness of  the various  kinds of employer incentives within the
EPA Region VIII Office.  The demonstration program will attempt to show
other Denver metro area  employers what can be done through employer incen-
tives.   We will (1) attempt to initiate an EPA vanpooling program (2) improve
EPA's carpooling matching program (3) provide extensive information on
transit availability to  employees and (4) provide various kinds of incentives
including but not limited to free parking spaces for carpoolers and vanpoolers

     During the second stage of this program the EPA demonstration efforts
will be expanded to the  entire federal community in  Denver.  There are 43,000
civilian and military federal  employees in the Denver metropolitan area.  We
will expand our efforts  begun during the EPA demonstration into the total
federal  community.  This will  require the establishment of a larger staff of
                                 -23-

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EPA employees due to the labor intensive nature of this kind of service.
In the third phase of the employer incentive program EPA will  encourage
employer incentives for state and local  government employees.   The final
stage of the program involves the expansion of the employer incentives to
private employers.  The third and final  stages of the employer incentive
programs are envisioned to be a combined EPA,  state and local  effort.

     In the remainder of this section the four stages of the EPA Employer
Incentive Program will  be discussed in greater detail.   The emphasis will
be on the numerous questions that must be answered over the three months
during Phase one of the Denver Air Program.

     The next three months will help us  to more clearly define each of
the four stages of an employer incentive effort.   It is nearly impossible
for us to describe, in  this document, our specific efforts  in  Stages 2-4.
Our efforts over the next three months can be  quite clearly defined since
we have done enough preliminary work to  identify  the major  options available
to us.   Although Stages 2-4 are discussed below,  one  must realize at the
outset that these discussions are tentative and that the in-depth investi-
gations of the next three months and the EPA demonstration  may substantially
alter our course.
                                  -24-

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Program Element:  Employer Incentives
Activity:  EPA Demonstration and Ihformatlon Gathering (Stage 1)

Objective:   Gather Information on Carpool incentives and reduce EPA

  Employee vehicle miles traveled
                         Activity  Description
       Since the EPA Demonstration is an integral part of our internal "learning"
  process it is difficult to separate it from basic information gathering in any
  meaningful way.  At least during Stage 1 and 2 (EPA demonstration and Federal
  Program), teams of EPA professionals will spend considerable time in employers'
  offices gathering data and establishing  incentives, ie., implementing a program.
  It is this basic approach that will be developed and refined during Stage 1.

       The major unanswered questions at this point are:   (1) Uhat employer in-
  centives to encourage ride-sharing (vanpooling and carpooling)  and transit usage
  are available? and (2) Which of these can be implemented in light of the various
  constraints (legal, economic, institutional, and so on)?  The efforts over the
  next three months will be geared toward  answering these two questions.

       Our information gathering will begin with a review of basic reports dealing
  with the subject.   This review will reveal  the most successful  programs, which
  will be investigated further.

       Concurrently with the information gathering process,  EPA Region VIII  employ-
  ees will be asked to complete a questionnaire concerning their  commuting habits.
  (See Appendix C for a copy of this questionnaire)   The  results  of this  question-
  naire will be used for a number of purposes.  First, the summary information ob-
  tained from the results will  indicate to us which specific incentives to pursue
  for the EPA demonstration.   Second, the  results will help  us categorize individual's
  commuting habits such that we can provide the most service to individuals  currently
  driving alone.   Finally,  the  knowledge gained from the  responses will enable us to
  improve the questionnaire itself and to  streamline techniques for analyzing it.

       The incentives to be investigated include:

       (1)  Parking  for High  Occupancy Vehicles
       (2)  Vanpooling for EPA  employees
       (3)  Carpool  matching
       (4)  On-site  bus  ticket  sales
       (5)  Expansion of RTD  route/schedule information
       (6)  Investigation of  EPA downtown  shuttle
       (7)  Provision of additional  services/amenities for bikers

       The EPA  demonstration  is scheduled  to  be in  place  by  2/28/78.

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Program Element:   Employer Incentives
Activity:  Federal  Employee Incentive Program (Stage 2)	

Objective:   Reduce federal employee work  trip  vehicle-mi1es-traveled_
                         Activity Description
       The lessons learned during tne  EPA demonstration  program will  be
  useful  in implementing incentives  applicable  to  the  entire  federal
  community.   There are several  essential  elements  of  this  program.   First,
  the techniques for gathering  data  on  employee commuting  habits and
  summarizing that data must be computerized.   In  addition, carpool  and
  vanpool  matching as well  as transit  route  information  services must be
  computerized.   Furthermore, EPA must  provide  the  staff resources  to do
  the job  and to provide continuing, permanent  followup.

       As  in  the EPA demonstration,  the Federal  program  (Stage 2) will
  begin with  a questionnaire (after  "public"  awareness efforts,  described
  elsewhere).   The data from this questionnaire will be  analyzed and  a
  program  will  be tailored  to each federal facility based  on:   (1)  commuting
  habits  of the employees,  (2)   location  and  size  of the facility,  (3)  at-
  titude of the management  and  employees,  (4)   previous  efforts  to  encourage
  ride-sharing by the facility  and (5)   physical aspects  of the  facility
  (parking provided,  distribution of employees  within  the  facility,  etc.)

       In  addition to those incentives  listed previously for  the EPA  demon-
  stration, other possibilities  for federal facilities are  to:

       1.   Introduce  parking fees for single  occupant  vehicle  parking at
           government owned installations.
       2.   Allocate all  close-in  federally-owned parking  spots  to high
           occupancy  vehicles.   Relocate  other  parking facilities further
           away  from  offices than they  presently are.
       3.   Investigate  RTD  subscription  bus service from  residential  areas
           to  high density  Federal employment centers.   This  could  be com-
           bined  with  staggered work hours or flexitime  to  provide  the  needed
           RTD bus capacity.
       4.   Provide regular  low-polluting  circulator service to  handle travel
           on  federal facilities.
       5.   Work with  RID to  improve regular bus  service  to all  federal  employ-
           ment centers.  Use work schedule changes as appropriate  to
           facilitate RTD activities.
       6.   Develop  a  system  to involve new out-of-town employees  moving  to
           Denver  in a  ride-sharing program.  Provide transit/carpool/vanpool
           information  to assist  persons  in choosing a residential location.
       7.    Develop, along with GSA, a plan for  locating new federal  office
           space such that VMT is minimized.

      The   Federal incentive program is scheduled for complete implementation
 by 7/1/78.

                                   -26-

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Program Element:    Employer  Tnr.prvMvp<;
Activity:   State  and  Local Government Employee  Incentive Program  (Stage 3)

Objective:    Reduce  State  and  local  government employee work trip

    vehicle-miles-traveled	



                         Activity  Description
         It  is  difficult  10 be  very  specific  regarding this  program at
    this  early  date.  The general  concept  is  to extend the successful
    aspects  of  the  Federal  government incentive program to State and
    Local  government  employees.  Nearly all of the specific  items discussed
    under the  EPA Demonstration  and  the Federal Program are  applicable to
    other governmental  bodies.   There may  be  other possibilities as well,
    because, for example, restrictions on  use of  State or  local  government
    owned motor vehicles  may differ  from federal  restrictions.

         EPA certainly  has  a major role to play in the Stage 3 program.
    That  role  is basically  to serve  as a catalyst and technical resources to
    State and  local governments  thus  EPA staffing should remain the same as
    Stage 2.   Hopefully we  can  create a cooperative local/state/federal
    effort to  implement a Stage 3  program  with the State taking the lead on
    State employees and local governments  taking  the lead with local employees
    Cooperation developed under this  program  is an essential for the final
    stage of the employer incentive  program-private employer incentives.

         Assuming a cooperative Federal/State/Local effort,  this program
    could be totally  implemented on  or before 12/31/78.
                                    - 27 -

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Program Element:   Employer Incentives
Activity:    Private Employer  Incentive Program (Stage 4)

Objective:  Reduce  private sector  employee work trio vehic1q-™ilgs

    traveled
                        Activity Description

        Stage 4 should begin with two givens.  First, Regulation 9
    should be supported through greater enforcement and/or expanding the
    scope of the regulation.  Second, it is conceivable that private
    employers will have voluntarily adopted various incentives as a result
    of  Stages 1-3.  Since we intend to "get out the word" on our program,
    others may follow.

        If the EPA concept of providing on-site assistance to employees
    (a  kind of consulting service) is extended to some or all private
    employers, then EPA staffing will have to be expanded to help provide
    the service.  Similar expansions in state/local government staffing will
    be  necessary.  Intergovernmental personnel transfers (e.g. IPA's) may be
    desirable.  To better manage Stage 4 and other parts of the Denver Air
    Program, an innovative locally-based agency with employees detailed from
    local/state/federal government may become a real option.   All of these
    events appear too distant to accurately predict at this point in time.
    We  should be in a much better position to be specific in six months to
    a year.
                                   -  28 -

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                        TRANSPORTATION MANAGEMENT
     This  section of  the Action Plan might well be entitled "miscellaneous
VMT  reduction efforts."  Some of  the items to be  investigated will ulti-
mately  be  included  in the  SIP in  accordance with  the SIP Policy to be
developed  as another  work  element, and others will not.  The work to be
done under this work  plan  will define what items  will be included.

     Several specific work efforts are introduced below, which will be
further developed in  the coming months.  There are numerous planning and
construction efforts  in the  Denver Area which must be interfaced with EPA's
activities to reduce  VMT in  the metro area.

     There are a number of reasons why it is necessary, if not essential,
to have a  formal mechanism to interact with the EPA headquarters personnel.
Perhaps the most important reason is that there are a number of people in
the  EPA headquarters  who have valuable experience in transportation and
air  quality.  The Regional Office would like to be in a position to draw on
this planning expertise.   Furthermore, since we have relatively new legisla-
tion (the  Clean Air Act Amendments of 1977), there are a number of legal
questions  which center on  EPA's authority in the  area of transportation
control planning.   Involving headquarters on a continuing basis should
ensure  that the Denver program maintains a high level of visibility with
the  Administrator and his  staff as well as with involved Assistant
Administrators.  There is  no doubt that the Regional Office will need
additional  manpower from headquarters, on a temoorarv or Dprmanpnt basis,
to assist  regional  personnel.

     The involvement  of headquarters is essential if Denver transportation
projects that benefit air  quality are to receive  preferential  funding.
Although such projects are already afforded priority funding under the
Clean Air  Act Amendments of  1977, a successful demonstration requires a
commitment to additional funds for Denver.

     Another very important  reason for headquarters involvement will  be
centered on the necessity  to interact with other  federal agencies at a
policy  level.  Our  headquarters personnel, particularly in Office of
Transportation and  Land Use  Policy, have developed policy level  contacts
with other federal agencies  such as the Department of Transportation.
The support of these other federal agencies is a necessity if we are to
accomplish  our objectives.  The Regional  Office must also directly
coordinate with Regional Offices of other Federal Agencies such as the
Departments of Energy and  Transportation,  and with local and State
transportation agencies.

     An area which will be investigated in the coming three months is the
possibility of developing  regulations which would apply to new and existing
Federal indirect sources of air pollution and to new and existing sources
of volatile organic materials which are owned or controlled by the
Federal government;

                                  - 29 -

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Program Element:   Transportation Management
Activity:  Headquarters Coordination
Objective:   Obtain assistance and program support
                         Activity Description
       By the end of January we will  have  established the formal  mechanism
  for this coordination.   We will  develop  specific work groups both at the
  policy and staff levels.   We fully  expect to  have manpower commitments
  from headquarters to insure that those people assigned to the work groups
  will have sufficient time available for  the Denver air effort.   Specific
  work will be assigned to each of the various  groups and dates and mile-
  stones will be associated with the  tasks.   The following is a list of
  organizations in headquarters which will be involved in our coordination
  efforts.

       1.  Office of Transportation and Land  Use Policy
       2.  Office of General  Counsel
       3.  Mobile Source  Enforcement  Division
       4.  Office of Air  and Waste Management
       5.  Office of Air  Quality and  Planning Standards
       6.  Office of Mobile Source Air Pollution Control
       7.  Office of the  Administrator
       8.  Construction Grants Office
       9.  Office of Federal  Activities

       Involving headquarters  on a continuing basis should ensure that the
  Denver program maintains  a  high  level  of visibility with the Administrator
  and his staff as well as  other involved Assistant Administrators.  There
  is no doubt that the Regional  Office will need additional  manpower from
  somewhere to complete the program and plan  and on schedule.  With a policy/
  management level  commitment  to the  Denver demonstration the regional  office
  would expect to be able to  obtain   additional  manpower from headquarters
  on a temporary or permanent  basis to assist regional  personnel.
                                    -  30  -

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Program  Element:    Transportation Management
Activity:  Coordination with Departments of Transportation and Energy

Objective:  Reduction of Transportation Emissions	
                         Activity  Description


     In the Region VIII area the Federal Highway Administration personnel
are very receptive to progressive transportation planning.  Hence, there are
many things which have been accomplished in the Denver area relating to air
quality and transportation through the previously discussed process man-
dated by 23 USC 109(j).  Our Denver Task Force will expect to improve our
coordination with both the Federal Highway Administration and the newly
created Department of Energy in the next three months.  The initial work
plan goal will be to increase EPA's understanding of the possibility of
developing multi-agency support for the implementation of transportation air
quality strategies in Denver.  As a simple example the Department of Energy
has available funding to support vanpooling programs for reduction of energy
consumption.  This program has not been pursued in the Regional Office simply
because of a lack of manpower.
                                     31 -

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Program Element:   Transportation Management
Activity:  Development of Federal Indirect Source and Organic Substance Reg.

Objective: Reduction of Emissions from Federal Facilities
                         Activity Description

     Indirect sources of air pollution are locations such as football stadia,
federal activity centers, etc.  which attract large quantities of motor
vehicle  traffic.  Indirect sources do not generate air pollution by them-
selves but the automobiles that bring the people to use the facilities do.
The Clean Air Act Amendments of 1977 give EPA specific authority to regulate
other federal agencies which are building indirect sources.  Considerable
research is necessary in this area to determine the nature and extent of
EPA's authority, as well as the best regulatory mechanism.  This item will
be extensively investigated, and early in 1978 a recommendation will be pre-
pared regarding EPA's approach  to developing regulations in this area.  The
schedule includes dates for proposing a federal regulation and adopting that
regulation.

     We will  investigate the possibilities of relocating existing federal
facilities to other outstate areas for purposes of air quality improvement in
Denver.  The General  Services Administration will be encouraged to increase
the role of air quality in making decisions about acquisition of new federal
office space.

     It may be necessary for EPA to develop a Federal  regulation to control
new and existing emissions of volatile organic substances from Federal
Facilities.  The schedule included in this document also indicates that the
Denver Task Force will prepare  specific recommendations regarding new
regulations in this area.

     As a result of this activity, EPA will develop and promulgate federal
regulations for any of the above areas which are determined to need them.
                                    - 32 -

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Program Element:    Transportation Management
Activity:    The NEPA Process
Objective:   Reduction in Transportation Emissions
                         Activity  Description
        Most of the accomplishments of the area in transportation control
   for air quality have occurred as a direct result of National  Environmental
   Policy Act.  Historically, beginning in 1970 and 1971,  EPA has suggested
   alternatives to reduce air pollution impacts from transportation-related
   projects in the Denver area.  As a result of our comments and those of
   other environmentally oriented groups, we have managed to get a number  of
   studies commissioned and some projects actually built.  EPA comments on
   the South Santa Fe Environmental Impact Statements have produced a
   significant commitment for high occupancy vehicle treatment in that corridor.
   Likewise we have the same commitment regarding potential ramp metering
   projects and possible carpool lanes on 1-70 and 6th Avenue.  The Denver
   Task Force will attempt to assemble a unified policy for environmental
   impact statement reviews in the metro area.  This should be of some assistance
   to those preparing EIS's in that it would eliminate some of the variability
   in the EPA decision making process.
                                   - 33 -

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Program Element:  Transportation Management
Activity:    Coordination with RTD
Objective:  Decreased Auto Use
                        Activity Description
        The Denver Task Force will  develop improved liaison with the
   Regional Transportation District which will hopefully allow us to
   include items in the Action Plan that will improve ridership and
   bus service and hence make bus trips more attractive.  Employer
   incentives for improving transit patronage have already been discussed
   in a different chapter of this work plan.   The area of investigation
   which will be intensified under this work plan element relates to con-
   struction improvements in RTD's  facilities, and the acquisition of
   additional buses or vans as well as the development of preferential
   treatment for buses.  We do not know at this point the extent to
   which we can assist the Regional Transportation District in these
   specified areas.  However, we hope to develop a specific action plan
   items to assist RTD in the fulfillment of both our missions.
                                -  34 -

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Program Element:   Transportation  Management
Activity:     Coordination  with  Denver  COG
Objective:    Transportation  Emissions  Reduction
                         Activity Description
         The  Denver Regional  Council  of Governments  has  committed to redeveloping
    the  long  range transportation plan  for the  Denver  area.  This process  is called
    "the plan restatement."   The  process  is  separated  into two  phases.  The first
    phase involves modification  in  a  minor way  of  the  existing  transportation
    plan to reflect fiscal  realities.   Several  highway projects have been  deleted
    because there  does  not  appear to  be sufficient funding to complete those
    projects  in  the near future.   Other projects are being modified or deleted as
    a  result  of  citizen complaints  or other citizen  actions.  Once this "pared
    down"  plan is  complete,  it will  be  evaluated using transportation and  air
    quality models to determine whether or not  there will be air quality viola-
    tions associated with its completion.   This concludes Phase I of the restate-
    ment process.   At that  point, if  there are  projected air quality violations
    in the future, the  plan  will  be completely  reworked.  If the decision  is
    ultimately made to  completely rework the transportation plan, the Denver Task
    Force will make every attempt to  heighten its  involvement in the plan  restate-
    ment.  The goal  of  this  work  element will be to  assign highest priority to
    those projects which have some  hope of improving air quality as they are built.

         The  long  range transportation  plan  of  the Council of Governments  includes
    a  TSM element  made  up of "transportation control plan like" strategies and
    projects.  FHWA has available funding for these  projects and is emphasizing
    the  importance of their  completion  to solving  the  air pollution problem.

         In the  coming  months the Denver Task Force  will become more familiar
    with the  existing Transportation  Management Systems  Plan and will formulate
    a  program to encourage  implementation of transportation strategies which are
    important in solving the air  pollution problem.  EPA will use its legal power
    to attempt to  insure that TSM elements are  built ahead of large new highway
    projects.  Some of  the type projects  that are  currently included in the
    transportation systems management element include  vanpooling, new construction
    or modification of  existing roadways  to accommodate  preferential treatment for
    high occupancy vehicles,      bus  shelters and  other  improvements to the
    transit system.
                                   - 35 -

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Program Element:    Transportation Management	


Activity:   Transit Planning for New Residential Areas

Objective:   Decreased Auto Use	
                        Activity  Description

        The EPA Regional Office will develop a work element in the
   Action Plan which will  establish a transit planning consulting
   office, either in the regional  office or in conjunction with
   Regional Transportation District.  The function of the office will
   be to provide recommendations to the developers on how they can
   provide transit service in conjunction with RTD and encourage the
   new residents of the development to commute to and from work in
   other than a single occupancy vehicle.  This same group will
   also investigate the possiblity of modifying federal, state and
   local regulations for zoning and planning and building permits so
   that the guarantee of transit service and the commitment to that
   service can be made prior to the issuance of certificates of
   occupancy being issued.
                                    -  36  -

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Program Element: 	Transportation Management	


Activity:    Coordination with Denver Planning and Traffic Engineering

Objective:     Reduction of Transportation Emissions
                         Activity  Description

     Coordination and liaison will  be improved in the coming months  between
the EPA Regional Office, the Denver Planning Office, the City Traffic
Engineering Office.  It is not clear at this point, what specific end this
improvement and coordination may serve.  However, it is  a well  known fact
that the City Traffic Engineering Department has almost  total autonomy over
traffic engineering in the Denver area.  As an example,  if it were decided
to convert specific streets in Denver to streets for bicycles,  the City
Traffic Engineering Department would have only to put up signs  and advertise
the changes.   The Denver Task Force will pursue efforts  to make traffic
engineering changes for air pollution outside federal or state mandates
which might apply to the city.
                                    - 37 -

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Program Element:
Activity:     Riryrlo Planning
Objective:   nprrpaspri Aiit.n Ike
                        Activity  Description
        Denver has had for some time, a long range bicycle path plan.
   The plan has been partially implemented (50%) and has been successful,
   however, it has been largely oriented toward pleasure bicyling, rather
   than commuter bicycling.  A number of groups in the Denver metro area
   have now developed a heightened interest in establishing a bi.cycling
   system, to allow people to commute to and from work on their bicycles.
   The EPA Regional Office will investigate several ideas which have been
   proposed to improve commuter bicycling in the area.  These include
   employer incentives which have been previously discussed and the dedica-
   tion of specific streets to bicycling only.  Likewise EPA will attempt
   to plan commuter education programs for bicylists and to encourage a
   structural improvement of the transportation system to allow increased
   compatabil ity with the bicyclists.  These items include, in addition to
   better bicycle paths, bicycle handling facilities on some transit
   vehicles, development of safe storage for bicycles at park & ride lots,
   and selected bus stops and the provision of amenities such as showers
   and locker rooms by large employers.
                                   -  38  -

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APPENDICES
   - 39 -

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                               APPENDIX A
                  DENVER AIR PROGRAM WORK PLAN SCHEDULE
     The schedule on the following two pages  is intended to provide the
reader with a general  idea of the proposed timeframe for implementing the
major programs which are being proposed to clean up Denver's air.   There
are a number of different efforts which will  all  be developed simultane-
ously but somewhat independently.  Since the  first stage of the program
involves data gathering and scoping each of the various  efforts,  in some
instances, it is difficult to associate dates certain with the various
stages of the effort.   In some cases,  the various stages of a specific
effort will not be defined until  early 1978 at the completion of the data
gathering process.  For example,  the staged program for  development of
employer incentives is more easily characterized than the activities of
the Transportation Management Policy Group.  The data gathering effort
will largely determine the activities  of the  latter.
                                   -  40 -

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                DENVER AIR PROGRAM SCHEDULE
Activity
No.
1
2
3
4
5
6
7

8
9
10
11
12
Completion
Date
11/14/77
11/15/77
11/18/77
11/21/77
11/23/77
11/28/77
11/29-12/9/77

1/31/78
1/31/78
1/31/78
2/28/78
2/28/78
Activity
Description
Brief Regional Administrator
Draft Work Plan
Final Work Plan
Informal Briefing for Colo. APCD
Brief Regional Administrator
McGinnis Presentation on Work Plan
Briefings for Outside Organizations:
FRC Governor's office
GSA Congressional delegations
DOT/IPG Chambers of Commerce
DOE APCC and DRCOG
HUD Citizens Groups
HEW McNichols
DOD HQ-EPA
DQJ Interested State Agencies
Action Plan Program Finalized
Internal EPA Organization in Place
Complete Policies on SIP and Construction
Grants and Develop Mechanism for HQ Input
EPA Internal Demonstration Fully Implemented
Announcement of EPA Demonstration &
13
3/01/78
Forthcoming Federal  Agency Program

Initiate Activities  of Transportation
Management Policy Group
                             -  41  -

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Acti vi ty
No.
14
15
16
17
18
19
20
21
22
23
24
25
26
27
Completion
Date
3/15/78
3/15/78
3/15/78
4/01/78
4/30/78
7/01/78
7/05/78 (approx.
8/01/78
10/01/78
12/31/78
12/31/78
4/01/79
1/01/80
1/01/80
Activity
Description
Final Design of Public Awareness Program
Address Neighborhood Groups
Implement Public Awareness Program
Propose Federal Indirect Source Regulation
Propose Implementation of Federal I/M
Program
Federal Agency Incentive Program in Place
)Air Pollution Independence Day
Finalize and Implement Federal Indirect
Source Regulation
Begin Implementation of Federal I/M Program
State and Local Incentive Program in Place
Propose Augmentation of State I/M Program
Finalize Augmented I/M Program
Implement Augmented I/M Program
Private Employer Incentive Program in Place
- 42 -

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 November  18,  1977
    Policy
 Formulation
 Feb.  1,  1978
                                 [RETREAT]


1 WORK PLAN i
i — — . — i 	 	 — - J
— T
EPA
Employer
Incentive
Program

1
Info !
Gathering!

                       Preferred  Parking
                       Vanpooling
                       Carpool  Matching
                       On Site  Bus  Ticket sales
                       •Expand RTD route/sched  info
                       Consider EPA shuttle
                      Services for bicyclists
                            ]  Public   .
                            |Awareness{
                                 /
 Employer
 Incentives ]

Continue  EPA Prog.
.Initiate  Federal  prog.
-Work with State  and  local
 officials, expand to private
 sector  (SIP)
-Federal  I/M
-Hi  Alt.  Emission  Stds.
-Regs for hi-alt.  perform-
 ance adjustments
LTie into State I/M (SIP)
_TSM elements
-RTD liaison
^-Transit planning
-Indirect source regs.
-Bicycle routes
-NEPA process
_Tie into SIP
January  1980  Denver program in place for public and private sectors,
                                 - 43 -

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                               APPENDIX B
           Transportation Control Plan Development Background
     In response to the Clean Air Act of 1970 and the timetables specified
therein for the development of transportation related portions of the State
Implementation Plan, the Air Pollution Control  Division of the State Health
Department of Colorado wrote the original  transportation control plan for
Denver.  This plan contained a number of different measures including bus
and carpool lanes, inspection and maintenance,  retrofits, improvements to
the mass transit system, and the development of a bikeway program.  Subse-
quent to that action, EPA promulgated two  additional  regulations so that
the approved adopted State Implementation  Plan  for Colorado would show
attainment of the national ambient air quality  standards by 1977.  These
two additional strategies were gasoline rationing and vapor recovery for
the transfer of petroleum products.

     Very little progress has been made toward  implementing the original
transportation control plan.  Progress to  date  includes the demonstration
bus lane pair on Lincoln and Broadway and  some  plans  to install ramp
metering devices on 1-70 and 6th Avenue.   The first two stages of a vapor
recovery program including bulk terminals  and gasoline service stations
have been implemented.  The Air Pollution  Control Division is  implementing
certain portions of the Air Pollution Control Commission Regulation No. 9.
This regulation requires incentive programs for carpools and high occupancy
vehicles to be carried out by all  employers of  more than 50 people in the
Denver area.   The program is, in place and  most  employers have  submitted
plans.   It is not yet known how successful  the  Division's efforts have been
because they have not had sufficient staff to analyze adequately the accom-
plishments of the various carpooling incentive  programs planned by Denver
area employers.   Two other portions of that same regulation require the
development of a parking management plan for Denver and the development of
a Park & Ride plan.  Both these plans are  to be implemented according to
the regulation.   However, the Denver Regional Council  of Governments made
a commitment only recently to get involved in parking management.  RTD's
Park & Ride program is developing, however, the District maintains that
they are not developing the Park & Ride program because of Regulation 9,
but rather because it is a program that does further  mass transit.

     The retrofit program has essentially  been  dropped.  The legislature
has, however, finally made a commitment to an idle mode inspection/mainten-
ance program in  the Denver area beginning  in 1980 which would  inspect and
require maintenance on 1977 and later model year automobiles.
                                 -  44  -

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     A few of the mass transit improvements to which commitments were
made in the original Transportation Control Plan have been implemented.
However, the Regional Transportation District does not have a total
commitment to the development of a "bus only" system.  The District
believes that early acquisition of too many buses could preclude fixed
line transportation options in the future.

     The bikeway program is approximately 50 percent implemented, how-
ever, it is primarily oriented toward pleasure bicycling rather than
reducing VMT through the encouragement of the use of the bicycle as a
mode to travel to and from work.

     The Air Pollution Control Commission and Division have committed
to a total rewrite of the existing transportation control plan as a
result of the federal requirement that theState  develop an air quality
maintenance plan for the Denver metropolitan area.  This air quality
maintenance plan will, at some point in the future, take the place of
the transportation control plan that is currently on the books, but
largely being ignored.  The air quality maintenance planning process
involves two steps.  The first is analyzing existing air quality and
projecting the future air quality to allow comparisons to the ambient
standards to be made.  If violations are noted, a plan must be developed
in the second stage of the process to insure that air quality will be
maintained at or below the standards in the future.  The analysis of the
Denver metro area is complete, and the maintenance planning process is
now beginning.  This process must be an integral part of the EPA's
activities in the Denver metro area to improve air quality.

     It is important to understand the historical perspective which
caused transportation control plans throughout the country to fail.
Many court cases were filed against the Environmental Protection Agency
shortly after the transportation control plans were approved by this
agency.  These court cases have proceeded through the judicial system
and three were ultimately heard before the Supreme Court   However no
hard decision was made by the court relative to EPA's authority to
require transportation control measures, and in fact, the most signi-
ficant issues were remanded back to lower courts.  Because of the time
consuming nature of the judicial processes, we are not liKely to have
clear-cut definitions of EPA's authority in transportation control
planning area for some years to come.  Thus, our efforts should be
concentrated in the areas where our legal authority is clear.  One of
the main purposes of the Denver air quality demonstration program will
be to show what kind of strategies can be implemented by a federal agency
to solve urban air quality problems.  Hopefully, many of the answers
which we derive from this program will be applicable in other urban areas.
Because of the foregoing, our initial thrust will be aimed at the
federal enclave in Denver.  There are approximately 43,000 federal
employees in Denver including the military.  If we can make a significant
                                - 45 -

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change in the commuting habits of the average Denver federal or military
employee, we should have some positive effects on air quality.  Our
successes and failures in this program will allow us to develop strategies
which can then be implemented by EPA and the State in the private sector.
                                    - 46 -

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                     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
SUBJECT. Denver Air Program Questionnaire
  FROM:  8AH_A

        EPA Region VIII Employees
             The Air Branch is beginning a program to provide a new service to
        employees of EPA Region VIII.  We hope to provide special  service to
        employees who:

                                  CARPOOL OR MIGHT WISH TO
                               .   WISH TO VANPOOL
                                  WISH TO RIDE THE BUS IF...
                               .   WISH TO BICYCLE TO WORK IF...

             The reason for this program is obvious.  We want to set a community
        example by doing what we can to REDUCE AIR POLLUTION IN DENVER!

             If this voluntary effort works well at EPA, we plan to extend the
        concept to the rest of the 43,000 federal employees in Denver area.

             To help us get started, please take a few minutes to  complete the
        attached questionnaire.

             In accordance with the intent of the Privacy Act of 1974, we need to
        provide you with some general information regarding this questionnaire.
        First, the questionnaire is completely voluntary.  Your responses will  be
        seen only by the Denver Task Force members and the undersigned and reported
        only as summary statistics for the entire agency.  We may, however,  provide
        specific information to you based on your response.  For example, we may
        provide names of individuals who live near you who desire  to form a carpool.

             DON'T WORRY - You won't be graded on the "ecological  quality" of your
        work trip.   We really need your frank answers to put together a good program
        for our employees.

             Please return the completed questionnaire to your Branch Secretary  by
        Wednesday,  November 30, 1977.  If you have any questions or comments, call
        Dale Wells, Dave Kircher, John Philbrook, Chuck Stevens or Sally Rawlings
        at extension 3711.   Thank you.
                                         /Oavid A.  Wagoner, Din^ctc/r
                                          Air & Hazardous Matervutfs Division
EPA Fo
      I3?n I, 
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                        DENVER AIR PROGRAM

                       EMPLOYEE QUESTIONNAIRE
1.   NAME
2.   RESIDENCE
    ADDRESS
3.  ONE-WAY DISTANCE FROM RESIDENCE TO LINCOLN TOWERS
4.  PLEASE INDICATE THE APPROXIMATE LOCATION OF YOUR RESIDENCE WITH
    AN "X" ON THE MAP BELOW
                                DENVER, COLORADO
                                 -  48  -

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5.   CHECK THE WAY(S) YOU TRAVEL TO WORK DURING AN AVERAGE WEEK.

    (IF YOU ADD THE NUMBERS BY EACH OF THE BOXES YOU HAVE CHECKED
     THE TOTAL SHOULD BE FIVE)
TAKE BUS:
D5 DAYS
Q4 DAYS
fj3 DAYS
[J2 DAYS
CM DAY
DRIVE ALONE:
D5 DAYS
DA DAYS
C|3 DAYS
Q2 DAYS
di DAY
CARPOOL :
D5 DAYS
D4 DAYS
D3 DAYS
G2 DAYS
Dl DAY
                 BICYCLE:                     WALK:

                   d5  DAYS                     G 5  DAYS

                   Q4  DAYS                     d 4  DAYS

                   n 3  DAYS                     d 3  DAYS

                   d 2  DAYS                     d 2  DAYS

                     1  DAY                          ]  DAY
                               - 49 -

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6.   WHEN YOU DRIVE  ALONE TO WORK, WHAT ARE YOUR MAJOR REASONS?
      DWORK HOURS DO  NOT COINCIDE WITH BUS SCHEDULE OR CARPOOLING.
      DMUST DROP  OFF/PICK UP CHILDREN AT SCHOOL OR DAY CARE.
      DBUS SERVICE  IS UNAVAILABLE'OR TOO INCONVENIENT.
      DENJOY DRIVING  ALONE.
      DNEED TO  DRIVE  ONE OR TWO DAYS PER WEEK TO TAKE CARE OF
         PERSONAL BUSINESS (e.g. ERRANDS ON THE WAY HOME)
      DOTHER (SPECIFY)	.
7.   WHEN YOU DRIVE  ALONE, WHAT  IS YOUR DAILY PARKING COST?
                                   - $1.35
                             D$1-40 OR MORE
                                - 50 -

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8.   WHICH OF THE FOLLOWING EXPRESS YOUR ATTITUDE ABOUT THE BUS
    SERVICE AVAILABLE TO YOU FOR TRAVELING TO AND FROM WORK-
    (CHECK SEVERAL, IF YOU WISH)

      D BUS SERVICE IS ACCEPTABLE.

      D BUS TAKES TOO LONG TO GET ME TO AND FROM WORK.

      D BUS STOP IS TOO FAR AWAY FROM MY HOME.

      n TOO MANY TRANSFERS.

      G BUS IS TOO UNCOMFORTABLE (e.g. I HAVE TO STAND UP FREQUENTLY)

      D BUS SCHEDULE IS UNRELIABLE.

      D TOO FEW BUSES RUN TO AND FROM MY RESIDENCE.

      D BUS IS TOO EXPENSIVE.

      D DO NOT LIKE TO SIT (OR STAND) NEXT TO STRANGERS.

      D OTHER (SPECIFY) _



9.   WHICH ONE OF THE FOLLOWING BEST EXPRESSES YOUR ATTITUDE TOWARD
    CARPOOLING?

      fj CARPOOLING IS AN ACCEPTABLE WAY TO TRAVEL TO AND FROM WORK.

         CARPOOLING IS TOO STRUCTURED TO CONFORM WITH MY LIFE STYLE
      ,— ,
      L-1
         OR WORK SCHEDULE.

         CARPOOLING IS UNCOMFORTABLE (EITHER PHYSICALLY OR MENTALLY).

         CARPOOLING IS OKAY, BUT I PREFER THE BUS.

         CARPOOLING IS IMPRACTICAL FOR ME BECAUSE OF WHERE I LIVE.

         OTHER (SPECIFY) __
                             - 51

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10.   HOW MANY PEOPLE ARE IN YOUR CARPOOL (INCLUDE YOURSELF)?

                             D3
                             D4
                             D5
                             Q 6 OR MORE
                             n NOT APPLICABLE

11.   ARE THE MEMBERS OF YOUR CARPOOL —
                             D RELATIVES ONLY
                             D NON-RELATIVES ONLY
                             D RELATIVES AND NON-RELATIVES
                             DNOT APPLICABLE

12.   ARE THE MEMBERS OF YOUR CARPOOL ALL EPA EMPLOYEES?
                             DYES
                             DNO
                             D NOT APPLICABLE

13.   WHEN YOU DRIVE FOR YOUR CARPOOL, HOW MUCH DO YOU PAY FOR
     PARKING?
                             DO* (EXCLUDING PARKING TICKETS!)
                             D 5* - 50*
                             D55<£ - $1.35
                             D$1.40 OR MORE
                             QNOT APPLICABLE

                             - 52 -

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14.   WHAT BUS  ROUTE(S) NUMBERS DO (OR COULD)  YOU  RIDE?
       DEXPRESS           DLOCAL          QDON'T KNOW
15.   DOES THIS  BUS  RIDE INVOLVE TRANSFERRING  FROM ONE BUS TO
     ANOTHER BUS?
       DYES              DNO             QNON APPLICABLE
16.   HOW FAR IS  YOUR RESIDENCE FROM THE BUS  STOP?
                           DO - 1/4 MILE
                           Dl/4 TO 1/2 MILE
                           Dl/2 MILE TO 1  MILE
                           Dl MILE TO 5 MILES
                           DMORE THAN 5 MILES
                           DNON APPLICABLE

17.   HOW DO  (OR  WOULD) YOU GET TO THE BUS STOP?
                           DWALK
                           DDRIVE ALONE
                           DCARPOOL
                           DDRIVEN BY ANOTHER FAMILY MEMBER
                           DBICYCLE
                           GOTHER (SPECIFY) 	
18.   ANY  OTHER  COMMENTS
                               - 53 -

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            APPENDIX D
The Control ©f Automotive
Air PoSiution Through  the
Eracoajragesraent of  public
Transportation  and
      r Vehicle
    Colorado Air Pollution Control Commission
               54 -

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                                REGULATION NO.  9

                     The Control 'of Automotive  Air Pollution
             through Motor Vehicle Restraints and the  Encouragement
                    of Public Transportation and Carpooling
 I.   AREA OF APPLICATION;

           This Regulation  No.  9 shall apply to the Metropolitan Denver Air
      Quality Control Region, which includes the counties  of  Adams,  Arapahoe,
      Boulder, Denver,  Douglas,  Jefferson,  Clear Creek,  and Gilpin.

II.   PREFERENTIAL TREATMENT OF BUSES;

      A.   By September 1,  1974 (in cooperation with the Denver Regional
           Council of Governments,  the State Department  of Highways  and
           each city and county government  within the Metro Denver Air
           Quality Control  Region)  the Regional Transportation District
           (R.T.D.) shall develop and submit to the Commission a feasi-
           bility study for demonstrating preferential treatment for
           buses and carpools within the Metro Denver Air  Quality control
           Region.  By July 1,  1975, R.T.D. shall in the same manner develop
           and submit to the Commission a regional plan  for establishing
           preferential treatment for buses and carpools within this region.
           This plan shall  include implementation steps, time schedules, and
           costs for implementing this plan by January 1,  1976.

           After the Commission holds a public hearing on  and adopts the
           plan, each party so  identified in the plan as responsible for
           a portion of it  shall implement  that portion.

           in connection with the plan, R.T.D. shall demonstrate to  the
           Division that implementation of  the preferential treatment of
           buses will not increase the potential for additional motor
           vehicle traffic  within the affected area.

      B.   By October 1, 1974,  in cooperation with the Denver Regional
           Council of Governments,  the State Department  of Highways, and
           major local business and employment center Associations,  the
           Regional Transportation District (R.T.D.) shall develop and
           submit to the Commission a plan  for automobile  intercept  park-
           ing facilities and express bus service to employment and
           business centers. Said plan shall include an implementation
           time schedule and an evaluation  of the effect of plan imple-
           mentation upon reducing vehicle  miles traveled  (V.M.T.).
           After the Commission holds a public hearing and adopts the
           plan, each party so  identified in the plan as responsible
           for a portion of it  shall implement that portion.

                                      -  55 -

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       C.   With respect  to the  requirements  of Sections  11.A.  and  II.B.
            of this regulation,  R.T.D.  shall  by October 1 of  each year
            submit plan revisions  and additions for  improving the effec-
            tiveness of adopted  plans.

III.   EMPLOYER PLAN REQUIREMENTS  FOR CARPOOLING AND MASS TRANSIT INCENTIVES;

       A.   By November 1,  1974, the Denver Regional Council  of Governments
            shall submit  to the  Commission a  proposal to  establish  a  uniform
            carpooling locator service  for the  Denver metropolitan  area.

       B.   By February 1,  1975, all public and private employers which employ
            more than two hundred  fifty (250) employees at one  time in any one
            plant or other  business location  shall submit an  affidavit, or
            plan, to the  Division  on forms provided  by the Division.   This
            affidavit shall be signed by an authorized company  employee.   The
            affidavit shall state  that:  1)   The locator  service developed as
            per Section III.A of this regulation will be  provided by  the
            employer for  use by  all interested  employees; or  that:  21  another
            carpooling locator service  of equal or greater effectiveness  will
            be used. In  the case  of an alternative  locator service,  the
            employer must submit for approval by the Division a plan  describing
            the system and  effectiveness of it.   The affidavit, or  plan,  shall
            provide the following:

            1.   That the carpooling locator  service must be  fully
                 implemented by  April 1, 1975.

            2.   That the carpooling locator  service shall be for the
                 purpose  of matching people to  facilitate the trans-
                 porting  of two  (2) or  more persons  per vehicle.

           •3.   A description of  employee incentives to  encourage  the
                 use of carpooling; such as^  free or reserved  parking
                 adjustments  in  favor of carpooled vehicles where
                 employee parking  is provided,  imposition of  parking
                 charges  on non-carpooled vehicles,  or other  incentives.

            4.   A description of  measures to encourage employees to  use
                 bicycles and public transportation;  such as, posting
                 information for employees as to the availability of
                 bicycle  lanes and public transportation  to and from
                 the place  of employment; and providing incentives  for
                 use of same  (reimbursement of  fares for  use  of public
                 transportation, provision of secure and  convenient
                 parking  for bicycles,  and/or other  similar fringe
                 benefits).

       C.   The Requirements  of  Sectior III.B shall  apply to  all public and
            private employers which employ more than fifty  (50) employees at
            one time in any one  plant or ether  business location exactly
            six months later than  the ti-.:? requirements of Section  III.B
            (plan submittal by August 1,  '575 and carpooling  locator  service
            implemented by  October 1, 19   .

                                         - 56 -

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      D.   All employers  regulated by this  Section III  shall,  on an annual
           basis coinciding with the plan submittal date,  submit on a  torn
           provided by the Division a brief'progress report  as  to the  effec-
           tiveness of implementing measures  as  required  in  this Section  III.

IV.    MOTOR VEHICLE PARKING;

           By March 1,  1975, the Denver Regional Council  of  Governments  (in
      cooperation with the State Department of Highways and  Regional Transportation
      District (R.T.D.) shall provide written advice to the  Commission as to  the
      relationship, if any, between restricting  the construction of new parking
      spaces in the Denver area and reducing  vehicle miles traveled.   It  shall
      also recommend to the Commission parking requirements  that may stimulate
      the use of public transportation and  decrease single passenger vehicle  miles
      traveled.
                                         - 57 -

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1EPA-°9R0T8N/T-77-006
                                                            3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
                                                            5. REPORT DATE
  Metropolitan Denver's Air  Program - Workplan
                                                             November  14,  1977
6. PERFORMING ORGANIZATION CODE

 8AH-A	
8. PERFORMING ORGANIZATION REPORT NO
7. AUTHOR(S)
   Dale Wells, John Phil brook,
   Dave Kircher, Charles  Stevens,  Sally Rawlings
9. PERFORMING ORGANIZATION NAME AND ADDRESS
   Denver Task Force
   Air  & Hazardous Materials  Division
   Environmental Protection Agency  Region VIII
   1860 Lincoln St., Denver,  Colorado  80295
10. PROGRAM ELEMENT NO.
 None
11. CONTRACT/GRANT NO.
 None
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
 Workplan-Nov. 15- Feb.  28,  19/7
                                                            14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT


        This workplan describes  the tasks to be accomplished by the Denver Task Force
   to  develop an "Action Plan" to solve Air Pollution  problems in Denver.   The work
   described in this report  falls into four major  categories:  (1)  development of an
   Employer Incentive program  to increase commuter vehicle occupancy;   (2)  development
   of  an enhanced motor vehicle  emission control program for Denver;  (3)   development
   of  methods to improve transportation efficiency by  providing preferential  treatments
   for  bicycling and high occupancy vehicles; and (4)   development of  new policies to
   deal  with requests for construction grants for  sewage treatment projects in non-
   attainment areas and development of an SIP policy for the Action Plan.   The workplan
   also  specifies an EPA program to heighten public awareness of air  problems and
   solutions in Denver.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS/OPEN ENDED TERMS  C. COSATI Field/GlOUp
  Transportation Planning
  Motor  Vehicle Emissions
  Employer Incentives
  Transportation Control Plans
  Public Awareness
 8. DISTRIBUTION STATEMENT
                                              19. SECURITY CLASS (This Report)'
              21. NO. OF PAGES
                   60
                                              2O. SECURITY CLASS (Thispage)
                                                                          22. PRICE
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE
                                           -58-

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