GUIDELINE SERIES
                  OAQPS NO.  1.2-002
            GUIDANCE FOR WRITING OF
          TRANSPORTATION CONTROL PLANS
        rm ..   ^~
US. ENVIRONMENTAL PROTECTION AGENCY
   Office  of Air Quality Planning and Standards

      Research Triangle Park, North Carolina

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 /BJECT:    Transportation Controls
       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
         Office of Air Quality Planning and Standards
         Research Triangle Park, North Carolina 27711
                                                    DATE:
March 12, 1973
FROM:
TO:
Ronald A. Vcnezia, Chief
Land Use Planning Branch
                                     XV* i/
Air and Water Program Directors
Regions I-X

     At the Kansas City regional meeting on February 9, 1973,  it was
indicated that the OAQPS would assist the Regions with guidance in
the preparation of transportation control plans that must be proposed
and promulgated by EPA.

     A review of the SIP task schedule sent to you on February 23
points out the extremely short time period available for the prepara-
tion of EPA plans after a decision is made as to whether or not the
State plan is acceptable.  To fully think out, prepare, review, and
announce on June 15 an EPA plan proposal with only one month lead
time is very difficult.  To assure adequate preparation and review of
EPA proposed plans, the following is recommended.

     The regional offices should prepare a contingency EPA proposal
for transportation controls in each Region requiring these controls
to meet NAAQS by 1975.  OAQPS 1.2-002, "Guidance for Writing Transpor-
tation Plans," is provided to assist the Regions in writing the plans.
This information should serve only as a guide.  EPA policy on use
of gasoline rationing and the extent to which states will be required
to enforce EPA promulgated regulations are not yet finalized.   There-
fore, to the extent sample regulations imply a particular enforcement
policy or a preferred strategy, they should be considered preliminary
until further policy guidance is recommended.

     Included is a list of items that should be included in the pream-
ble.  It is important that all these points be covered for the prepara-
tion of a comprehensive preamble.  Preambles for Regions' proposals
will be coordinated by the Land Use Planning Branch for the single
preamble to cover all EPA plans proposed on June 15.  The Land Use
Planning Branch is developing an additional listing of strategies and
priorities which can be used in EPA plans, and will attempt to
identify preferred strategies that would be most appropriate for EPA
proposal and promulgation in each Region.

     Close attention should be given to  the memorandum "Enforceability
of Transportation Control Strategies," 3-2-73, Shutler to Regional Air
and Water Programs Division Directors.   Mr. Graham prepared an excellent
analysis of the potential for state and/or Federal enforcement.  It is
intended that the sample plan be modified to suit each particular
Region using Mr. Graham's work and the preferred strategies from the
 EPA Form 1320.6 (Rev. 6-72)

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Land Use Planning Branch.  This information will be available
March 20.  At that time the Region should review the proposal,
determine if it suits regional needs and prepare an  outline of the
"back-up" EPA plan for each AQCR.   This will be held in reserve to
finalize as an EPA'proposal if states do not submit an adequate plan.

     Mr. Frick, of OGC, is preparing a document on the basis for ex-
tensions to meet the NAAQS.  It is expected it will be available by
March 20.

     The following policy issue papers are now in preparation by the
Land Use Planning Branch for consideration by the Administrator.
These issues will become an integral part of EPA policy to achieve
transportation controls.

     1.  Should an EPA promulgated plan make maximum use of
         gasoline rationing?  How much rationing can be
         effected without severe community impact?

     2.  Should EPA write regulations to force the states to
         act or should EPA act directly?

     It  is anticipated that we will be able to discuss these issues
in some  depth at the March 20 meeting.  A decision will be reached
as soon  as possible.

     An  evaluation report must be prepared for transportation and or
land use plans that are received from the States.  The Land Use
Planning Branch has prepared a checklist (OAQPS 1.2-003) which can be
used in  the evaluation of the plans and serve as the basis of writing
the evaluation report.  A copy of this report should be sent to the
Land Use Planning Branch no later than May 15, 1973.

     For your review of the S.tate plans, your attention is called to
the following references:

     1.  "Requirements for Preparation, Adoption and Submittal of
         Implementation Plans."  (36 FR 15486) August 14, 1971.

     2.  "Criteria for Review of Transportation Control Measures."
         OD/OAQPS January 30, 1973.

     3.  "Proposed Transportation Control Measures."  (38 FR 1464)
         January 12, 1973.

     If you have further questions on transportation controls, please
contact  the Land Use Planning Branch (919) 688-8291 or 8270.

Attachments
OAQPS 1.2-002
OAQPS 1.2-003

cc:  Transportation representatives

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                                                            March 12, 1973
                           OAQPS NO.  1.2-002







                       Guidance for Writing of




                     Transportation Control Plans






       This appendix includes the following sections:






  I.   Items to be Included in the Preamble




 II.   Suggested Wording for Opening of Preamble




III.   Sample Wording for Possible Regulations




 IV.   Current Studies and Guidelines Applicable to Plan Preparation

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              I.  Items to be included in Preamble






     The preamble to the control regulations should contain the following




items:




     1.  Percent pollutant reduction required:  a statement as to the




         percent reduction required of oxidants or carbon monoxide




         to meet the national primary ambient air quality standard




         by May 31, 1975.



     2.  Background:  a brief description of the history and legislation




         leading to the requirement for EPA to promulgate a control plan,




         (See Section II).  Also a description of the topography and




         meteorology of the region in question and a statement describing




         the reason (health basis) for the NAAWS.  Describe the base air




         quality data and compare it with the national standards.




     3.  Transportation and/or land use control alternates:  describe the




         control strategies available for the region in question such




         as (a) stationary source controls (restrictions on organic solvent




         use, gasoline vapor recovery systems for service stations, a




         change in the substance used for degreesing operations, and a




         vapor recovery system that prevents evaporation of solvents from




         dry cleaning operations;) (b) hardware type mobile source controls




         (inspection and maintenance, retrofit and fuel conversion,




         evaporative controls to prevent evaporation of gasoline during




         the filling of the gas tank; (c) reduction of vehicle miles




         traveled (increased use of mass transit, increased car pooling,




         gasoline rationing, increasing cost of motor vehicle use, limiting




         the number of automobiles registered, land use controls or a




         combination of these.)  /

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     4.  The specific transportation and/or land use control strategy

         proposed to meet NAAQS by May 31, 1975.

     5.  Include a table summarizing the effect of each element of the

         proposed strategy as is shown on page 2196 of the January 22,

         1973 proposed plan for Los Angeles, 38 FR (2194).


For the following items see the January 22, 1973 Federal Register:


     6.  Discuss legal and administrative procedures to implement the

         plan.

     7.  Include compliance schedules.

     8.  Discuss surveillance and monitoring procedures.

     9.  Economic and social impact of the  (name of Region)  transportation

         and/or land use plan.

    10.  Direct costs to the public.

    11.  Effect on the economic fabric of the community.

    12.  Tax revenue implications.
                «; "/
    13.  Summary of impacts.

    14.  EPA efforts to mitigate the effects of proposed regulations

    15.  The need for mass transit  (if applicable).

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           II.   Suggested Wording for Opening of Preamble

                  ENVIRONMENTAL PROTECTION AGENCY
                         [40 CFR Part 52]
         Approval and Promulgation of Implementation Plans
                 Notice of Proposed Rule Making
     On May 31, 1972 (37 FR 10842), pursuant to section 110 of the Clean
Air Act and 40 CFR Part 51, the Administrator approved, with specific
exceptions, State plans for implementation of the national ambient air
quality standards.  On this date, the Governor of 	
was advised that in order to complete the requirements of § 51.11 (b)
and 51.14, a transportation and/or land use control strategy was to be
submitted to the Administrator by February 15, 1973.
     On January 31, 1973, the United States Court of Appeals for the
District of Columbia Circuit found that the Administrator did not conform
to the strict requirements of the Clean Air Act of 1970 in permitting
several states to delay submission of transportation control portions
of their implementation plans until February 15, 1973, and in granting
extensions until mid-1977 for attainment of the national primary ambient
air standard without following the procedures established in Section
110 (3) 42 V.S.C. S 1857 c-5 (e).  Accordingly the court ordered that the

Administrator rescind the extension granted the states for implementation
of the transportation and/or land use control portion of their imple-
mentation plans.  The affected states were required to submit a control plan
by April 15, 1973.  The plan was to show attainment of the national ambient

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air quality standards for oxidant and/or carbon monoxide as expedltlously
as possible but no later than May 31, 1975.
     On this day the Administrator approved, with specific exceptions,
transportation and/or land use control plans submitted in response to
the January 31, 1973 court order.  This proposal results from the failure
of the State of 	 to submit an acceptable control
plan for the attainment and maintenance of the national primary ambient
air quality standard for oxidants and/or carbon monoxide.

            III.   Sample Wording  for  Possible  Regulations

       The  following  sample  regulations  should be modified  to  fit  the  AQCR
  in  question.   This  also  includes  the paragraph numbering  system.  Example
  regulations  follow  the format shown in (38 FR 2194) dated January 22, 1973.
       a.   The preferred approach to  be  used by EPA in  promulgating regula-
           tions  such as those on gasoline  rationing (Section  II f) have not
           been finalized.   Therefore these regulations and the strategy
           implied by their  use may be revised as EPA policy on preferred
           strategies and  enforcement are further developed.
       b.   Subpart  (name  of state)   .
           Section	 is  amended by adding  paragraphs  	
           through 	,  as follows:  S 52 	control strategy and
           regulations:  Photochemical oxidants and/or  carbon  monoxide,
           	AQCR.

           Regulation for  control of  evaporative emissions.
       (1)   For purposes  of this  paragraph:
       (i)    "Evaporative control device" means a device installed on a
             motor vehicle to prevent the escape of gasoline vapor from
             the gasoline  tank and carburetor.

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(11)  "Registered" as applied to a motor vehicle, means that such



      motor vehicle,                               is duly licensed



      for general operation on public roads or highways by the



      appropriate agency of the Federal Government or by the State.



(2)    This regulation Is applicable In those portions of 	



      Counties contained within the Metropolitan 	



      Air Quality Control Region (AQCR) in the State of
      The requirement of this regulation shall be effective




      commencing up to	.



 (3)  Prior to    (date)    , an evaporative control device of at



      least 85 percent efficiency which is approved by the



      Administrator shall be properly installed, in good working



      order, and in operation on all registered light-duty



      gasoline-powered vehicles of model years 1966 through 1969




      and all registered heavy-duty gasoline vehicles of model



      years 1966 through 1972.  Approved evaporative control



      devices shall be installed on a schedule determined by the



      Administrator.



(4)   After    (date)    , the following shall apply in the areas



      specified in paragraph (b) (2), of this section:



      (i)  The State of	 shall not register light-duty



           vehicles which do not comply with the provisions of



           paragraph (b) (3) of this section.



      (11)  No owner of light-duty vehicles shall operate or allow



            the operation of such vehicles which do not comply with




            the provisions of paragraph (b) (3) of this section.

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c.  Regulation for gaseous fuel conversion.
    (1)   For purposes of this paragraph:
    (i)    "Fleet vehicle" means any one of ten (10)  or more light-and
          heavy-duty vehicles operated by the same person (s)  or
          business and used principally in connection with the same
          occupation or related occupations.
    (11)   "Gaseous fuel" means liquified  or pressurized petroleum
          or natural gaseo which are used as  fuel  for light-duty
          vehicles.
    (2)    This regulation is applicable in those portions of 	
          Counties contained within the Metropolitan	Air
          Quality Control Region (AQCR) in the State of	.
          The requirements of this regulation shall be effective
          commencing on   (date) .
    (3)    All registered gasoline-powered fleet vehicles  of model years
          prior to 1975 shall be equipped for and operated on gaseous
          fuel by the effective date of this regulation.   Conversion of
          such fleet vehicles for use of gaseous fuel  shall be on a
          schedule determined by the Administrator.
    (4)    After   (date)    , the following shall apply in the areas
          specified in paragraph (c) (2) of this section:
          (i)  The State of	 shall not register vehicles
               which do not comply with the provisions of paragraph
               (b) (3) of this section.

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             (11)  No owner of fleet vehicles shall operate or allow the



                   operation of such vehicles which do not comply with the



                   provisions of paragraph (c) (3) of this section.




d.     Regulation for yearly inspection and maintenance.



       (1)  For purposes of this paragraph:



            "Inspection and maintenance" means a program to reduce



            emissions from In-use vehicles through Identifying vehicles



            that need emissions control related maintenance and requiring



            that maintenance be performed.



       (2)  This regulation is applicable in those sections of 	



            Counties contained within the 	Air Quality



            Control Region (AQCR) in the State of 	.  The



            requirements of this regulation shall be effective commencing




            on   (date)    .



       (3)  All registered gasoline-powered light- and heavy  duty vehicles



            shall be Inspected annually for emissions and, as necessary,



            maintained by the owner in order to pass the Inspection.  This



            shall be done by personnel, facilities and procedures which shall



            be proposed and promulgated by the Administrator.



       (A)  After    (date)    , the following shall apply in the areas



            specified in paragraph (d) (2) of this section:




            (1)   The State of	 shall not register light-duty



                  vehicles which do not comply with the provisions of



                  paragraph (d) (3) of this section and procedures promul-



                  gated pursuant thereto.



            (ii)  No owner of light-duty vehicles shall operate or allow



                  the operation of such vehicles which do not comply with



                  the provisions of paragraph (d) (3) of this section.

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       Regulation  for  oxidizing catalyst.



       (1) For  purposes  of  this paragraph:



           "Oxidizing  catalyst" means  a device installed in the exhaust



           system  of the vehicle that  utilizes a catalyst and,  if



           necessary,  an air pump to reduce emissions of hydrocarbons and



           carbon  monoxide  from that vehicle.



       (2)   This regulation is applicable  in those sections of  	
             Counties contained within the	AQCR in the state



             of 	.  The requirements of this regulation shall



             be effective commencing on   (date)	.



        (3)   All registered gasoline-powered light- and heavy   duty motor



             vahicles of model years 1966 through 1974,  shall  be equipped



             with an appropriate oxidizing catalyst exhaust retrofit in



             accordance with paragraph (e) (2)  of this section, approved




             by the Administrator.



        (A)  Aftez ,	,  the  following shall  apply. in the areas



            specified  in paragraph  (e)  (2)  of  this  section:




             (i)   The  State of  ._    	 shall not  register  light-



                  duty vehicles which do  not comply with  the provisions



                  of paragraph  (e)  (3) of this section.



            (ii)  No owner of light-duty  vehicles shall operate or allow



                  the operation of such vehicles which do not  comply with



                  the provisions of paragraph  (e)  (3) of  this  section.



f.      Regulation for purchase of gasoline.



       (1)  For purposes of this paragraph:




       (i)  "Control period" means a portion of a calendar year in which



            gasoline sales are regulated.

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(11) "Retail outlet" means any service station, filling station,



     garage, store or other place of business at which gasoline



     Is transferred directly to consumers in the regular course



     of business.



(2)  This regulation is applicable in those portions of 	
     Counties contained within the	Air Quality Control



     Region (AQCR) in the State of	•        The




     requirements of this regulation shall be in effect commencing



       (date)    and shall remain in effect through    (date)



     The regulation shall be effective in the same control periods



     during each calendar year thereafter, until such time as the



     Administrator determines the regulation to be no longer



     necessary for the attainment and maintenance of the national



     standard for photochemical oxidants (hydrocarbons and/or



     carbon monoxide.)



(3)   During the control periods, as specified in paragraph (f)




     (2) of this section, the sale of gasoline to retail outlets



     and to the owners and operators of motor vehicles shall be



     controlled by directions of the Administrator, EPA.



(4)   The amount of gasoline to be controlled shall be determined



     by the Administrator no later than 30 days prior to the



     effective date of a control period.  This determination shall



     be based on the hydrocarbon emission reduction required for



     the attainment and maintenance of the national standard for



     photochemical oxidants and/or carbon monoxide in the AQCR.

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g.     Volatile organic compound loading facilities.
       (1)  This regulation is applicable in those portions of
                          Counties contained within the 	
            Air Quality Control Region (AQCR) in the State of
            	.      The requirement of paragraph (g) (2) of
            this section shall be effective commencing 	
       (2)  No person shall load or allow the loading of volatile organic
            compounds having a vapor pressure of 1.5 pounds per square
            inch absolute or greater, under actual storage conditions,
            into any tank truck or trailer, railroad tank car, loco:mctive,
            aircraft, stationary storage tank with a capacity greater
            than 5 gallons from any loading facility unless such tank or
            loading facility is equipped with a vapor collection and
            disposal system, or its equivalent, properly installed, in
            good working order, and in operation.  Loading shall be
            accomplished In such a manner that all displaced vapor and air
            will be vented only to the vapor disposal system.  A means
            shall be provided to prevent liquid organic compound drainage
            from the loading device when it is removed from the hatch, or
            to accomplish complete drainage before such removal.  The
            vapor disposal portion of the system shall consist of one
            of the following:
            (i)   An absorber system or condensation system with a minimum
                  recovery efficiency of 90 percent by weight of all the
                  volatile organic compound vapors and gases entering such
                  disposal system.

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     (11)   A vapor handling system which directs all vapors to a
           fuel gas system.
     (ill)  Other equipment of at least 90 percent efficiency,
           provided plans for such equipment are submitted to  and
           approved by the Air Pollution Control Officer.
     Intermediate storage vessels may be used prior to disposal
     of vapors under paragraph (g) (2) (l),(li), or (ill),
     provided they are so designed as to prevent release of
     vapors at any time during use.
(3)   Notwithstanding paragraph (g) (2) of this section, no person
     loading or allowing the loading of the above Specified
     compounds in the above.specifled storage vessels from the
     above specified loading facilities, any of which were in
     existence on the effective date of this regulation, or in
     the procere of being installed for use on said effective  date,
     shall be subject to the provisions of paragraph (g) (2)
     of this section until     (date)    .  Provided however,
     that such person is hereby required to file on or before
       (date)      a compliance schedule with the Administrator
     showing how the person will bring this operation into
                                                     •
     compliance with paragraph (g) (2) of this section on or
     before   (date)   .  Failure to file such compliance
     schedule or abide by its iterms shall render the
     prohibition contained In paragraph (g) (2) of this section
     immediately applicable to such person on      (date)	,
     or on the date of said person's failure to abide by said
     compliance schedule, whichever Is later.

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    Control of drycleaning solvent evaporation.
    (1)   For the purposes of this paragraph:
          "Dryeleanlng operation" means that process by which an
          organic solvent is used in the commercial cleaning of
          garments and other fabric'materials.
    (2)   This regulation is applicable in those portions of
          	 Counties contained within the
          Air Quality Control Region (AQCR) in the State of
          	:	.  The requirements of this regulation'shall
          be effective commencing on   (date) .
    (3)   No person shall operate a drycleaning operation unless the
          uncontrolled organic emissions from such operation have
          been reduced at least 85 percent.
     (4)  Drycleaning operations emitting less than three (3) pounds
          per hour and less than 15 pounds per day are exempt from
          this regulation;
     (5)  If incineration is used as a control technique, 90 percent
          or more of the carbon in the organic compounds being
          incinerated must be oxidized to carbon dioxide.
1.   Degressing operations.
     (1)  For the purpose of this paragraph:
          "Degreasing" means the operation of using an organic solvent
          as a surface cleaning agent prior to fabricating, surface
          coating, electroplating or any other process.

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                                 13
     (2)  This regulation is applicable  in  those portions of
          Counties contained within  the     .  ' •  -   :.   ^ir Quality
                               ~ t*>,'-    ""^"^""""i^T™^TiTTT^T1  • '•.'••'  "•''*•• "'<

          Control Region  (AQCR)  in the State  of  ••   'i    _   :--
          The requirements of  this regulation shall be effective
                                              \      '       '        ;

          commencing on   (date)  .               x


     (3)  No person shall use  trichloroethylene (TCE)  degreaser as a


          degreasing solvent.


j.   Organic Solvent Usage.


     Contact the Land Use Planning Branch for additional information


     on this subject.  Work  is currently being done to revise


     Appendix "B" of the August 14,  1971,  Federal  Register.   36 F.R.


     (15486.)




 IV.  Current Studies and Guidelines Applicable to Plan Preparations




The EPA has published the following  studies  and guidelines:


      a.  "Prediction of the Effects of  Transportation Controls on Air


          Quality in Major Metropolitan  Areas" and "Evaluating Controls


          to Reduce Motor Vehicle Emissions  in Major Metropolitan Areas,"


          November 1972.  Both  of these  documents  are  generally known as


          the "Six Cities Study."


      b.  "Transportation Controls to Reduce Motor Vehicle Emissions in


          Major Metropolitan Areas," December,  1972.   This document is a


          summary of 14 cities  that were studied with  the view of


          recommending specific transportation control strategies.


          Separate reports for  each of the 14 cities will also be


          available alo^g with  the Six Cities Study and the  document

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                           14
    listed in b above from the Office of Technical Information and
    Publications, Research Triangle Park, North Carolina 27711.
c.  "Control Strategies for In-Use Vehicles," November, 1972.  This
    report is available from EPA, Mobile Source Pollution Control
    Programs, 401 M St.S.W., Washington, D.C. 20460.
d.  "Proposed Transportation Control Plans," Federal Register
    (38 FR 1464) January 12, 1973.
e.  "An Air Pollution Impact Methodology for Airports and
    Attendant Land Use," dated January, 1973.  Copies available
    from Land Use Planning Branch, EPA, Research Triangle Park,
    North Carolina 27711.
f.  "Criteria for a Review of Transportation Control Measures"
    OD/OAQPS Memo, January 30, 1973.
g.  "An Interim Report on Motor Vehicle Emission Estimation" Kircher
    and Armstrong, October, 1972 and available from the Land Use
    Planning Branch, EPA, Research Triangle Park, North Carolina 27711.

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