DECEMBER 1973
Prepared for
ENVIRONMENTAL PROTECTION AGENCY
REGION IX
SAN FRANCISCO, CALIFORNIA 94111
ENVIRONMENTAL
SERVICES
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This report was furnished to the Environmental Protection Agency by
TRW Transportation and Environmental Operations in fulfillment of Contract
Number 68-02-0048. The contents of this report are reproduced herein as
received from the contractor. The opinions, findings, and conclusions
are those of TRW and not necessarily those of the Environmental Protec-
tion Agency. Mention of company or product names does not constitute
endorsement by the Environmental Protection Agency.
t '
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TABLE OF CONTENTS
Page
1.0 SUMMARY AND INTRODUCTION 1
2.0 BACKGROUND INFORMATION 9
2.1 General Contingency Plan Elements 10
2.1.1 Episode Criteria 13
2.1.2 Control Strategies 15
2.1.3 Surveillance Procedures 17
2.1.4 Operational Procedures 17
2.2 Description of the Los Angeles Problem 18
2.2.1 Geography, Demography, and Climate .... 18
2.2.2 Overall Air Quality Levels 27
2.2.3 Air Pollution Control Agencies 31
2.2.4 Emission Source Inventory 34
2.2.5 The Potential for Air Pollution Episodes . . 37
2.2.6 Transportation Data Base 47
2.2.7 An Approximate Air Quality-Emission
Level Relationship 53
2.3 Special Contingency Plan Considerations for the
Los Angeles Area 60
References - Chapter 2 65
3.0 REVIEW AND EVALUATION OF EXISTING EMERGENCY EPISODE
PLANS 67
3.1 Local Air Pollution Control District Emergency
Plans 68
3.1.1 Plan Description . 68
3.1.2 Evaluation: Preventing Significant Harm
Levels 76
11
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Page
3.2 Air Resources Board - Air Pollution Emergency
Contingency Plan 79
3.2.1 Plan Description 79
3.2.2 Evaluation: Preventing Significant Harm
Levels 88
3.3 EPA Region IX Traffic Abatement Strategies .... 92
3.3.1 Plan Description 92
3.3.2 Evaluation: Alternative Traffic Abatement
Measures 95
References - Chapter 3 98
4.0 ALTERNATIVE CONTINGENCY PLAN ELEMENTS 99
4.1 Episode Criteria 99
4.1.1 Number of Episode Stages 99
4.1.2 Feedback vs. Forecasting Criteria ..... 100
4.1.3 Air Pollution Forecasting Capabilities for the
Los Angeles Basin 102
4.1.4 A Basic Dilemma 106
4.2 Control Strategies 107
4.2.1 Degree of Emission Reduction Required . . . 108
4.2.2 Locational Considerations 110
4.2.3 Alternative Control Measures Ill
4.3 Surveillance Procedures 113
4.3.1 Surveillance of Air Quality and Meteorology . 113
4.3.2 Surveillance of Strategy Implementation . . . 121
4.4 Operational Procedures 125
4.4.1 Legal Considerations 125
4.4.2 Implementation Organization 131
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Page
4.4.3 Communication Channels 138
4.4.4 Activity Phasing 140
References Chapter 4 145
5.0 SUMMARY OF ALTERNATIVE CONTROL MEASURE EVALUATIONS ... 147
5.1 Evaluation of Stationary Source Episode Control
Measures 149
5.2 Evaluation of Traffic Abatement Episode Control
Measures 156
5.2.1 Summary of Traffic Abatement Control
Measures 185
5.2.2 Recommended Control Measures for Inclusion in
Control Plan 186
References - Chapter 5 189
6.0 A PROPOSED EPISODE CONTINGENCY PLAN 190
6.1 Recommended Episode Criteria 191
6.2 Recommended Control Strategies 194
6.2.1 Control Strategy Applicability 198
6.2.2 Control Strategy Effectiveness 199
6.2.3 Implementation and Enforcement 199
6.2.4 Institutional Problems and Socio-Economic
Impact 204
6.3 Recommended Surveillance Procedures 206
6.4 Recommended Operational Procedures 207
6.5 Limitations of the Analysis 208
APPENDICES
A. EVALUATION OF INTERIM EMERGENCY ABATEMENT ACTIONS . A-1
A.I The Interim Emergency Abatement Actions ... A-l
A.2 Survey of Agency Participation A-8
iv
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Page
A.3 Survey of Agency Employee Participation A-13
A.4 State and Local Actions A-28
A.5 Impact of Abatement Action on Vehicle Mileage
Travelled (VMT) A-30
A.6 Public Reaction and Media Involvement A-37
References - Appendix A A-49
B-. THE PRELIMINARY EPA EPISODE CONTINGENCY PLAN FOR THE
METROPOLITAN LOS ANGELES AQCR B-l
B.I Effectiveness Evaluation of the Preliminary EPA
Contingency Plan B-4
B.2 Comparison of the EPA Plan to the Plan Proposed
by this Study B-20
References - Appendix B B-29
C. OXIDANT EPISODES IN THE METROPOLITAN LOS ANGELES AIR
QUALITY CONTROL REGION C-l
D. CALCULATION OF VMT REDUCTIONS ASSOCIATED WITH VARIOUS
TRAFFIC ABATEMENT MEASURES . . . D-l
References - Appendix D " D-21
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LIST OF TABLES
Page
2.1 Population and Land Area - Metropolitan Los Angeles AQCR 19
2.2 Population Projections: Counties Within the Metropolitan
Los Angeles AQCR 21
2.3 Employment in the Metropolitan Los Angeles AQCR 23
2.4 Air Quality at Selected Sites in the Metropolitan
Los Angeles Air Quality Control Region, 1972 ..... 29
2.5 An Approximate Emission Inventory for the Metropolitan
Los Angeles AQCR, 1973 - 1975 35
2.6 Alternative Hydrocarbon Reactivity Assumptions 36
2.7 Federal Significant Harm Levels for Oxidant,
Carbon Monoxide, and Nitrogen Dioxide 37
2.8 Comparison of Maximum Carbon Monoxide Levels in the
Metropolitan Los Angeles AQCR to the Federal Significant
Harm Levels, 1970 through 1972 40
2.9 Comparison of Maximum Nitrogen Dioxide Levels in the
Metropolitan Los Angeles AQCR to the Federal Significant
Harm Levels, 1970 through 1972 . . , 42
2.10 Oxidant Episodes Exceeding Federal Significant Harm Levels
in the Metropolitan Los Angeles Air Quality Control
Region (1-70 - 6-73) 44
2.11 Severe Oxidant Episodes in the Metropolitan
Los Angeles Air Quality Control Region 45
2.12 Average Weekday VMT in the LARTS Region - Total,
Freeway, Non-Freeway, and Rush-Hour 49
2.13 Distribution of Vehicle Trips and Total VMT by
Trip Type: Weekdays and Weekends '50
2.14 Average Weekday vs. Weekend Total Trips and VMT; 1973 51
2.15 Comparison of Weekday - Weekend VMT According to Trip Type .... 52
2.16 Current Automobile Occupancy Rates in the South Coast Basin. ... 53
2.17 Average Weekend Day and Weekday Max. Oxidant:
Four Stations, 7-62 to 6-64 .56
2.18 Average Daily Maximal One Hour Carbon Monoxide at
Three Stations, Weekends vs. Weekdays:
December - February, 1969-1972 .... 57
vi
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LIST OF TABLES (COND'T) p
2.19 Average Daily Maximal One Hour Oxidant at
Five Stations, Weekends vs. Weekdays:
June - September, 1970-1972 .................... 57
2.20 The Effect of VMT Reductions on Total Emission Levels
(For Base Year: 1974) ...................... 58
2.21 The Approximate Effect of Contingency Plan Emission
and VMT Reductions on Air Quality ................. 59
3.1 L. A. County APCD Alert Stages for Oxidant,
Carbon Monoxide, and Nitrogen Oxides ............... 69
3.2 Types of Stationary Sources Requiring Shutdown Plans -
Los Angeles County APCD ...................... 71
3.3 The Effect of Los Angeles County Shutdown Procedures
for Stationary Sources ...................... 72
3.4 Comparison of L. A. County APCD Alert Levels to the
Federal Significant Harm Levels .................. 77
3.5 ARB Contingency Plan Episode Criteria Levels ........... 80
3.6 ARB Contingency Plan - Example Traffic Abatement Measures ..... 83
3.7 OES Evaluation of Traffic Abatement Measures ........... 87
3.8 Comparison of the ARB Contingency Plan Alert Levels to the
Federal Significant Harm Levels .................. 89
3.9 Summary of EPA - Region IX Evaluations of Alternative
Traffic Abatement Measures ....................
4.1 Air Pollution Forecasting Capabilities for the
Metropolitan Los Angeles AQCR ................... 103
4.2 Brief Description of Alternative Control Measures ......... 112
4.3 Sources of Real -Time Air Quality and Meteorological
Data in the Metropolitan Los Angeles AQCR ............. 114
5.1 Description of the Categories for Control Measure Evaluation . . .148
5.2 Evaluation of Stationary Source Episode Control Measures ..... 150
5.3 List of Traffic Abatement Control Measures ............ 157
vi i
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LIST OF TABLES (COND'T)
Page
5.4 Evaluation of Traffic Abatement Episode Control Measures .... ,158
6.1 Episode Criteria for Oxidant 192
6.2 Episode Criteria for CO and N02 193
6.3 Proposed Control Strategies: VMT Reduction and
RHC Emission Reduction . .196
6.4 Proposed Control Strategies: VMT Reduction and
CO and NO Emission Reductions 197
A
6.5 Episode Levels Which Can Be Reduced To
Below Significant Harm Levels By The
Proposed Control Strategies 200
A-l Federal Agencies Participating in July 26
Air Episode Abatement Action A-2
A-2 Major Federal Agencies Without Plans -
Participation in July 26 Abatement Action A-10
A-3 Federal Agencies of the Employee Survey A-l4
A-4 Federal Employee Questionnaire Response Rate A-l7
A-5 Usual Mode of Travel - Federal Employees on
Administrative Leave July 26 A-l9
A-6 Change in Mode of Travel - Federal Employees
Which Were Urged to Share Transportation July 26 .A-20
A-7 Change in Vehicle Mileage Traveled - Employees on
Leave and Employees Encouraged to Share Transportation A-21
A-8 Nature of Trips Made by Federal Employees
on Leave July 26 A-23
A-9 Means by Which Federal Employees Were Notified to
Take Emergency Smog Abatement Actions A-25
A-10 Employee Reaction to Emergency Air Episode Plan -
Based on July 26 Action A-27
A-ll Total Daily Vehicle Count
Selected Stations in "42 Mile Freeway Loop" A-34
A-12 Morning Rush Hour (6-9 AM) Vehicle Count
Selected Stations in "42 Mile Freeway Loop" A-36
viii
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LIST OF TABLES (COND'T)
Page
B-l Preliminary EPA Contingency Plan for
Los Angeles - Episode Criteria B-2
B-2 Preliminary EPA Contingency Plan for
Los Angeles - Control Strategies B-3
B-3a Effectiveness of the Proposed EPA Plan:
VMT Reductions and RHC Emission Reductions B-5
B-3b Effectiveness of the Proposed EPA Plan:
VMT Reductions and CO and NOV Emission Reductions ts-b
X
B-4 Episode Levels Which Can Be Reduced To Below Significant
Harm Levels By The EPA Control Strategies B-8
B-5 Comparison of the EPA Control Strategies and the
Control Strategies Recommended by This Study ..• . B-22
C-l Oxidant Episodes in the Metropolitan Los Angeles
Air Quality Control Region C-2
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LIST OF FIGURES
Page
2.1 Feedback vs. Feedforward Episode Control Systems .......... 11
2.2 General Contingency Plan Elements for Air Pollution
Episode Control .......................... 15
2.3 Metropolitan Los Angeles AQCR ................... 20
2.4 1970 Employment in Southern California ............... 22
2.5a Air Flow Patterns - South Coast Air Basin (October 0000-0700 PST) . 25
2.5b Air Flow Patterns - South Coast Air Basin (October 1200-1800 PST) . 26
2.6 Comparison of Seasonal Pollution Patterns
Carbon Monoxide vs. Oxidant .................... 28
2.7 Location of Air Quality Monitoring Stations
(Metropolitan Los Angeles AQCR - 1970) ............... 30
2.8 Total RHC, CO, and NO Emissions in the Metropolitan
Los Angeles AQCR Under the Present Control Program ..... .... 38
3.1 County APCD Emergency Episode Operations .............. 74
3.2 ARB Emergency Episode Operations Organization ........... 85
4.1 Location of Real-Time Sources of Air Quality Data ......... 115
4.2 Los Angeles APCD - Organizational Structure
for Episode Control ....................... ..132
4.3 Argonne National Laboratory - Organizational Structure
for Episode Control ........................ 134
4.4 EPA Region IX - Organizational Structure
for Episode Control ........................ 137
4.5 Communications Channels as Outlined in
REOCC Operations Manual
4.6 Possible Modifications to Existing
Communications Channels ...................... 142
A-l Survey Questionnaire for Federal Employees on
Administrative Leave July 26 .................... A_1
A- 2 Survey Questionnaire for Federal Employees of
Agencies Encouraging Transportation Sharing ............ A-l 6
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LIST OF FIGURES (COND'T)
Page
A-3 "42 Mile Loop" A-33
A-4 Los Angeles Times Report on Abatement Action, Appearing
July 26, 1973 A-40
A-5 Los Angeles Times Report on Abatement Action, Appearing
July 27, 1973 A-41
A-6 Editorial from Evening Outlook, Appearing Saturday,
July 28, 1973 A-42
A-7 Editorial from Los Angeles Times, Appearing Friday,
July 27, 1973 A-43
A-8 KNXT Editorial Broadcast August 1 and 2, 1973 A-*S
A-9 Report on City Officials' Reaction, Valley News and
Green Sheet, Appearing Friday, July 27, 1973 A-46
A-10 Column from Washington Post, July, 1973 A-48
B-l Hourly Distribution of Recreational Trips in the
LARTS Study Area . B-27
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1.0 SUMMARY AND INTRODUCTION
This report presents the results of a study to develop an air
pollution episode contingency plan for the Metropolitan Los Angeles Air
Quality Control Region. The study is directed at formulating a plan
which will prevent oxidant, carbon monoxide, and nitrogen dioxide from
reaching the "significant harm levels" established by the Environmental
Protection Agency. An appropriate plan, consisting of episode initiation
criteria, control strategies, surveillance procedures, and operational
procedures, has been developed. This proposed plan is presented at the
conclusion of the report.
The present chapter summarizes the principal findings, conclusions,
and recommendations which have resulted from the study. The main text of
the report covers three basic areas. First, background information nec-
essary for formulating a contingency plan is compiled. Second, existing
emergency contingency plans are reviewed. Finally, a recommended contin-
gency plan is developed.
Chapter 2 provides the background information for the project.
General contingency plan requirements are reviewed, and specific informa-
tion relevant to the Los Angeles area is compiled. The latter includes
regional statistics, air quality data, an emission inventory, a transpor-
tation data base, and an air quality-emission level relationship.
Chapter 3 reviews and evaluates existing episode control programs.
Included are the county APCD emergency episode programs, the preliminary
California Air Resources Board contingency plan, the State Office of
1
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Emergency Services report on traffic control measures, and the EPA Region-IX
Task Force report on traffic abatement during episodes. A preliminary
episode control plan recently proposed by the EPA Region-IX is reviewed in
Appendix B. An effectiveness evaluation of the EPA control stategies is
performed, and a detailed comparison is made between the EPA plan and the
plan recommended by this study.
Chapter 4 discusses the alternatives which are available in
formulating a contingency plan for Los Angeles. Possible episode
criteria, control strategies, surveillance procedures, and operational
procedures are examined. A detailed review of alternative control
measures is performed in Chapter 5. Four stationary source controls
and twenty-four traffic abatement measures are evaluated as to enforce-
ment and implementation requirements, technical effectiveness.,
institutional problems, and socio-economic impact.
In Chapter 6, on the basis of the discussions of the previous two
chapters, a complete episode contingency plan is recommended. The
proposed episode criteria depend on air quality forecasts rather than
air monitoring feedback. The recommended control plan consists of
four stages which attain 0%, 16% 39%, and 64% RHC emission control,
respectively. The proposed surveillance and operational procedures
rely basically on existing capabilities.
Four appendices follow the main body of the report. Appendix A
provides detailed documentation on the results of the EPA actions taken
on 26 July 1973, when certain federal agencies instituted their traffic
abatement plans. Appendix B was described above. The other two
appendices contain support material for the main text.
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The findings, conclusions and recommendations which have resulted from
this study are listed below. The ordering of the list corresponds generally
to the organization of the text.
Findings and Conclusions
G The .40 PPM—4 hour average harm level is the binding
constraint of the three significant harm levels for
oxidant.It is exceeded, on the average, around 4 to 5
times per year in the early 1970's. The .60 PPM--2 hour
average and .70 PPM--1 hour average harm levels are very
rarely exceeded (possibly once every 5 to 10 years).
Furthermore, if the one or two-hour harm levels are
exceeded, the four-hour harm level is virtually certain
to also be violated.
o Violations of the CO or NO- signficant harm levels are
likely to never occur in tnis decade, (especially in
view of decreasing CO and NO emissions due to ongoing
control programs). The only harm levels which are even
remotely threatened of being exceeded are the eight-hour
average, 50 PPM CO level and the twenty-four hour average,
.50 PPM N02 harm level. The one and four-hour CO harm
levels and the one-hour N02 harm level are far below maximal
levels now found in the Los Angeles basin.
e An analysis of weekend/weekday air quality data and
emission levels reveals that to attain a given percentage
reduction in air pollutant concentrations on a certain
day requires a disproportionately greater reduction in
emissions for that day. For primary contaminants, this
is the result of residual pollutants remaining from the
previous day. For oxidant, this disproportionality
is even greater due to nonlinearities in the oxidant
precusor relation as well as to residual precursors.
• Local APCD plans have not been designed around federal
significant harm levels-and are not capable of preventing
harm levels from being exceeded for oxidant, CO, and
NO?. Oust lowering the APCD alert criteria would not
make their plans adequate for averting federal harm
levels. This is because the plans are based on feedback
criteria, while forecasting criteria are required,
especially for oxidant. The APCD emergency plans have
well-organized operational procedures for stationary
source control, but the mobile source program should be
made more definitive.
• The preliminary ARB contingency plan basically consists
of a guide for APCD's in reconstructing their own plans.
The ARB alert criteria are well below present APCD
criteria but they still are of the feedback variety.
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(The OES Report recommended forecast criteria, but
evidently the ARB has concluded that prediction
capabilities are inadequate.) Since the criteria
are of the feedback type, oxidant will very likely
not be prevented from exceeding harm levels. The
MF plan, by leaving jurisdiction basically up to
local APCD's, does not explicitly allow for region-
wide control. This seems to neglect the distinct
regional-transport character of the oxidant problem.
Finally, the actual control programs of the ARB plan
require further definition (this may be a result of
the preliminary nature of the ARB plan).
The OES Report gives a comprehensive survey of traffic
-abatement measures. It arrives at several general con-
clusions about episode plans which are in concurrence
with the present study. A few improvements which are
possible in the OES analysis of traffic abatement
measures are discussed in Chapter 3.
The EPA Region IX Report on Traffic Abatement Strategies
is not a complete contingency plan but rather a guide
for certain elements which should be included in a plan.
It also conducts a comprehensive analysis of episode
controls for traffic. Possible improvements in this
analysis are discussed in Chapter 3,
Feedback episode criteria, which call for controls when
air pollution actually reaches certain levels, are not
adequate for oxidant control. Forecasting criteria are
required because some lead time is needed to implement
most traffic abatement measures and because oxidant
levels do not respond well to shutting off emissions
after the early morning. However, obtaining reasonably
accurate forecasts on episode type days may be a difficult
problem. Measures which may help to increase forecast
reliability are discussed in Chapter 4.
Air monitoring data generated -in the Los Angeles Basin
is very adequate for air quality surveillance during
episodes. The main problem in air quality surveillance
is obtaining the measured data on a real-time basis.
The air monitoring, enforcement, source surveillance,
and.other capabilities of the local APCD's would be
very valuable in carrying out an episode contingency
plan. The traffic monitoring stations of the State Depart-
ment of Transportation would be able to provide useful
data on mobile source activity levels.
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The organizational structure of the EPA-Region IX
Regional Emergency Operations Control Center appears
to be generally adequate to administer the type of
contingency plan recommended by this study.
Of the three types of traffic abatement measures,
(direct controls on traffic, controls on traffic
support facilities, and controls on incentives to
drive), incentive control appears to be the best
form. Controls on traffic and/or traffic support
facilities are either ineffective or they present
extremely difficult enforcement and implementation
problems. Controls on incentives (e.g. work holidays)
can be effective and they do not present great enforce-
ment or implementation problems. However, the one
extremely negative aspect of incentive controls is the
economic disruption involved., Nearly all effective
traffic controls will rank low as to socio-political
acceptability.
Substantial controversy has resulted from the July 26,
1973 execution of an Interim Emergency Air Episode
Program in the Los Angeles Basin. Based on a survey
study of both agencies and employees participating in
this action (Appendix A), the following conclusions
seem appropriate:
1) The impact of the current plan (as measured by
the survey of the agenices and by an examination
of traffic data) is essentially insignificant in
in the sense of achieving reductions in total
vehicle mileage traveled.
2) The relatively low level of agency participation
in the plan stems from its unauthoritative
execution approach (voluntary and unilateral
among the participants).
3) Much of the adverse reaction to the action of the
26th was due to a minimal awareness of the interim
stature of the plan and the mechanisms now in
work to adopt a more comprehensive emergency plan
this fall.
4) Federal employees participating in administrative
leave plans appear to have made a conscious effort
to reduce vehicle travel during the abatement
action, (unlike the typical holiday pattern, no
substitute driving was indicated).
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The recently proposed EPA-Region IX contingency plan
provides for sufficient emission reductions to prevent
significant harm levels. The three stages of the plan,
(voluntary abatement, certain mandatory controls, and
a work holiday), result in 0%, 22%, and 64% RHC emission
reductions, respectively. A comparison of the EPA plan
to the plan proposed in this study points to neither one
being unambiguously superior to the other.
Recommendations
Consideration should be given to Devaluating the .40 PPM--
four-hour average oxidant harm level. All other federal
harm levels are rarely exceeded (at most once every few
years). The present four-hour harm level changes the nature
of the problem from an emergency plan to be instituted
very rarely to an episode control plan which is implemented
several times per year. It should be noted that there may
be a public outcry against disruptive control measures
which are instituted several times per year to prevent air
pollution episodes that have been experienced regularly
in the past with no major health problems generally
perceived by the public.
Predictive (forecasting) type episode criteria should be
used. They are a must for oxidant control. Since pre-
sently available forecasts can contain considerable error
and since they may not give results in the appropriate
form, some resources should be devoted toward improving
prediction capabilities. A preliminary forecasting scheme
based on previous day's air quality measurements is pro-
posed in Section 6.1.
Episode controls should be implemented for both stationary
and vehicular sources. Gasoline powered motor vehicles
must be controlled because they constitute the one major
source of RHC, NO , and CO emissions. Stationary sources,
although minor contributors, should be controlled because
curtailment is often much easier to implement than for
mobile sources. The control program recommended in Section
6.2 can be summarized as follows:
Stage I 1. Media Announcements and Voluntary Abatement
Stage II 1. Stage I
2. Ban Filling of Underground Service Station
Tanks
3. Control Specified Stationary RHC Sources
4. Ban Non-Critical Fleet Vehicles
5. Close Non-Critical Government Agencies
Stage III 1. Stage I
2. Operate on Sunday Status
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Stage IV 1. Stage I
2. Complete Work Holiday (Including Closing
Recreational Facilities)
• The vehicular episode controls for the advanced stages
basically consist of controls on incentives to travel. If
advanced alerts will be called very frequently, the economic
disruption of incentive controls may be intolerable. In
such a case, direct traffic controls (say by a "windshield
sticker" scheme) might be considered as an alternative.
• Cooperation and communication between County APCD's, the
State ARB, and the Federal EPA should be promoted. Each
type of agency has certain special capabilities that would
be valuable in operating an effective contingency plan.
If communication is not maintained, actions by one agency
could be duplicated by or even be counterproductive to
actions of another agency.
e Existing surveillance capabilities should be used whenever
possible. Local state, and federal air monitoring sites
provide adequate air quality data. More reliable procedures
should be formalized for obtaining the aerometric data
during episodes. Appropriate arrangements should be made
to obtain traffic count data from the California Department
of Transportation. Stationary source surveillance might
be conducted by existing, experienced local and state per-
sonnel, or a special EPA team could be organized.
• The EPA-Region IX REOCC appears capable of handling the
necessary operational procedures. However, a local EPA
communications center in the Los Angeles Basin during the
episode would prove useful.
e Recommendations evolving from the study (Appendix A) of
the interim emergency abatement action executed in the
Los Angeles Basin on July 26, 1973 are as follows:
1) Deliberate measures should be instituted to
shape positive public awareness and public
opinion with respect to the intentions and
objectives of the emergency air episode program.
2) Emergency air episode actions should not be
instituted when only partial and ineffective
abatement results are expected. This type of
result appears non-constructive in terms of
heightening any type of public awareness, and
in fact, appears to invite controversy and
negative reaction.
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3) The interim emergency plan should be strengthened
to include a significant number of agencies.
Abatement measures should be well-defined and a
forceful commitment to execute the measures accord'
ing to plan should be made.
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2.0 BACKGROUND INFORMATION
This chapter establishes the background information related to the
study. Section 2.1 presents an introductory overview of general
contingency plan elements, describing briefly how episode criteria,
control strategies, surveillance procedures and operational procedures
form the basis for an episode control plan.
Section 2.2 presents a detailed description of the Los Angeles air
pollution problem, citing many of its unique characteristics. Some of
this information is intended for readers unfamiliar with the Los Angeles
problem. In addition to reviewing much of the published data for the
region (e.g. population statistics, climatology, and historical air
quality data),this section provides an updating of certain necessary
data bases (e.g. emission inventories and traffic data). The potential
for air pollution episodes in the basin is thoroughly analyzed. Finally,
in section 2.2.7 a very approximate emissions - air quality relationship
is developed for episode control. This relationship is derived from an
analysis of weekday-weekend air quality data and emission levels. To
our knowledge, this is the first time such a relationship has been
formulated.
Section 2.3 summarizes the considerations which are most important
in the development of a contingency plan for the Los Angeles basin.
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2.1 GENERAL CONTINGENCY PLAN ELEMENTS
The purpose of an air pollution episode contingency plan is to prevent
damage to public health from excessive short term air pollution levels.
Contingency plan action is necessary when meteorological conditions cause
the concentration of air pollutants to reach levels which could result in
significant harm to residents of an area". In general, there are two ways
to lessen the health danger: first, by preventing the pollutants from ever
reaching danger levels, or second, by protecting the public from the effects
of such levels. Obviously, the second approach would be a monumental trsk
during severe episodes since it would be necessary to ensure that each and
every citizen were protected. Thus, practical considerations require pre-
venting air pollutants from ever reaching significant harm levels. This
can be accomplished by either controlling emissions sources or by attempt-
ing to disperse contaminants once they have entered the atmosphere. However,
it seems very unlikely that practical dispersion methods could be devised;
this would amount to changing the weather. For the present, emission con-
trols appear to be the most effective method for dealing with short-term
episodes. Appropriately, the EPA Administrator, in 40CFR 51.16, requires
state implementation plans to "provide for taking emission control actions
necessary to prevent ambient pollution concentrations from reaching levels
which would constitute imminent and substantial endangerment to health..."
In general, the basic configuration of an episode control plan can
assume one of two principle forms. The first involves feedback control,
the second is based on forecasting. The difference between these two types
of control can be best understood by viewing the air pollution problem as a
"control system", [19]. As shown in Figure 2.1, the air shed is the system,
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FEEDFORWARD
CONTROL
MECHANISM
CONTROL VARIABLES:
Emission Quantities,
Location & Timing
UNCONTROLLABLE INPUTS
/I \
METEOROLOGY: (Wind, Stability, Sun, etc.)
AIR SHED SYSTEM
FEEDBACK
CONTROL
MECHANISM
AIR POLLUTION
CONCENTRATIONS
Figure 2.1 Feedback vs. Feedforward
Episode Control Systems
Source: Seinfeld and Kyan, Reference [19].
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and pollutant concentrations are the basic system variables. The manipu-
lable inputs of this system are source emissions. The unmanipulable inputs
are the meteorological variables. The object of control policy is to pre-
vent air pollution concentrations from reaching a "dangerous" level.
Feedback control is based on air quality (system variable) measurements;
control mechanisms are activated when pollutant concentrations actually reach
certain levels. Measures then are instituted to prevent the concentrations
from going any higher. However, if the system does not respond quickly
enough, the concentrations might continue to increase and exceed significant
harm levels. On the other hand, feedforward (forecasting) control is based
on measuring inputs to the system (e.g. meteorology); controls are activated
according to predicted pollution levels. This allows more time for preven-
tive action.
The determination of which type of configuration is best for a particular
air pollution system depends entirely on the characteristics of that system.
For example, if the air shed responds relatively quickly to alterations in
emissions, an effective feedback plan can be established by setting the con-
trol trigger low enough to ensure that significant harm levels will never be
reached. However, if the control system is sluggish, then a plan using
feedback control would have to set trigger levels so low that emergency con-
centrations would be declared much more often than necessary. In such a
case, forecasting methods should be developed.
Although the actual configuration of an episode contingency plan
depends principally on the characteristics of the air quality control region
for which it is designed, there are several basic components which are
necessary to any episode plan based on emission control. These are
12
-------
1) episode criteria, 2) control strategies, (groups of control measures plus
enforcement and implementation specifications), 3) survei11 a n c e procedures,
and 4) operational procedures. Each of these basic components will be dis-
cussed below. Their place in the entire episode plan structure is summarized
in Figure 2.2.
2.1.1 Episode Criteria
A contingency plan must contain a set of criteria which cause the plan
to be put into action. These are known as episode criteria. These criteria
should be organized in stages of severity, more stringent controls being
activated for more advanced stages. EPA requirements specify that emergency
contingency parts of state implementation plans must have at least two stages,
[40 CFR 51.16(6)].
The episode criteria can take one of two forms depending on whether the
contingency plan is of a feedback or forecasting variety. Feedback criteria
cause the episode to be initiated once a certain level of pollutant concen-
tration is reached. Feedforward criteria cause control action to be initiated
once it is determined that conditions are such that pollutants will reach or
exceed significant harm levels. Feedback criteria are based on air quality
measurements, while feedforward criteria are usually based on meteorological
measurements.
Besides initiating action, episode criteria also establish the severity
of the episode. Feedback criteria determine the severity by setting up
different successive episode levels based on higher degrees of pollutant
concentration. Every time one of these levels is reached, a new stage or
phase of the episode begins. On the other hand, feedforward criteria deter-
mine severity according to how high uncontrolled pollutant concentrations
13
-------
CONTROL STRATEGY
(GROUP OF MEASURES)
6U
LU
CO
CO
LU
cr
LU
o
o
CO
CO
CO
UJ
CO
i
CO
UJ
ce:
3
o
|
CO
o
1—4
g
o
2:
LU
I
EPISODE CRITERIA
(INITIATION)
OPERATIONAL
PROCEDURES
SURVEILLANCE
PROCEDURES
:g jaBTMam^MaiigJEa^^aai i^^ajs^-sfc^ j tTS
METEOROLOGY
FEED FORWARD
'fj"iiTffilrlm*-V:y-'p
J***Waj4lL-IHID-^f1'TC!- -V-JjJ^E,
| AIR QUALITY
il
;
•
1
i
i
LU
U,
UJ
CO
CO
UJ
OL
Figure 2.2 General Contingency Plan Elements
-------
are expected to be. This predicted magnitude stipulates the episode stage.
As mentioned above, the actual plan configuration and the type of episode
criteria to be used depend upon the nature of the specific air basin under
consideration. However, it is possible to note some of the difficulties
which the two types of criteria encounter in general. First they must both
deal not just with maximal concentrations but also with various time averages
of concentrations, such as the .40 PPM (4 hr. avg.), .60 PPM (2 hr. avg.),
and .70 PPM (1 hr. avg.) federal oxidant harm levels. Feedback criteria must
insure that control stages are implemented in time to prevent exceeding any
of the harm levels for all the various averaging times. Feedforward mecha-
nisms must include forecasts for each time average. Second, there are ques-
tions of availability of measurements and/or technical problems. This is
much less of a problem for feedback criteria than for forecasting criteria.
Forecasting requires considerable meteorological data, and even with the best
available technical capabilities it may be inaccurate. Third, there is the
problem of establishing actual criteria levels which will make the plan ef-
fective without causing undue socio-economic disruption. This could be a
particularly important problem for feedback configured plans. The response
of the system may be so slow as to severely restrict the possibility of
effective action once the episode has started.
2.1.2 Control Strategies
At the heart of an episode contingency plan are the control strategies.
A control strategy consists of a set of control measures to be taken at a
particular stage of the episode along with implementation and enforcement
procedures for those measures. There are as many control strategies as there
are episode stages.
15
-------
Each measure associated with a control strategy is designed to alter
or control source emissions. Emission control can take one of several
forms, [27]. First, it can change the temporal distribution of emissions
as, for example, would a ban on waste incineration during daytime hours.
Second, it can change the spatial distribution of emissions. An example
would be the curtailment of vehicular traffic in the downtown area. Finally,
it can decrease total source emissions. The latter effect is the main thrust
of most control measures now in practice.
Besides a description of the actual control technique, each control
measure should stipulate how the control is to be implemented and enforc:d.
For example, a partial ban on automobiles could be implemented through a
license plate lottery, a windshield sticker program, or perhaps even by the
color of the car. Enforcement could be voluntary or involve penalties and
could be carried out by the police, national guard, or EPA field personnel.
All of these procedures must be specified in the measure.
There are several considerations which should be taken into account in
formulating control strategies. First, all control measures should be capable
of rapid institution and fairly immediate effects. Second, all measures
should be implementable from a legal point of view. There should be no
question of legality which would have to be tested in courts during the
episode. Third, for given effectiveness, measures should be designed to
minimize economic disruption and social-political impact. Finally, the
design of the strategy should be such that it will not fail (let pollutant
concentrations reach significant harm levels) under any forseeable circum-
stances. This necessarily means rating the effectiveness of a control
measure with a large degree of conservatism.
16
-------
2.1.3 Surveillance Procedures
The surveillance procedures necessary for the effective operation of an
air pollution episode control plan can be divided into two groups: air
quality and meteorology surveillance and strategy implementation surveillance
The first group of procedures provides the information needed to determine if
episode conditions exist and the severity of those conditions. It partly
consists of routine sampling of appropriate air quality and meteorological
parameters. During an episode it again consists of air quality and meteoro-
logical measurement, but on a much more frequent basis, so that the necessary
information is available to make use of in the contingency plan. The second
group of procedures is designed to determine the extent to which the imple-
mentation of control measures is successful. It includes observing other
agencies involved in the plan to ensure that they are fulfilling their
responsibilities as well as observing the effects of control measures on
various sources. These surveillance procedures help to provide the informa-
tion inputs necessary for the effective operation of the plan.
2.1.4 Operational Procedures
In order to ensure rapid and smooth execution of an episode contingency
plan, there must be contained within the plan itself a set of procedures
which explain how it is to be made operational during an air pollution
episode. These procedures should explain how responsibility is to be
delegated, how communications are to be handled, and how enforcement is to
be conducted. Further, they should indicate the necessary hardware needs,
like communications equipment to manage the implementation of various control
measures.
17
-------
Although much of the details of the operating procedures will depend
upon the actual makeup of the control strategy, it is possible to outline
some general areas which must be considered. Under the topic of responsi-
bility, clear lines of authority will have to be outlined so that there is
no question of who is responsible for enforcement, who is in charge of
communication, and particularly, who is responsible for confirming that
indeed an episode exists and insuring that controls are selected and
implemented. Also, the location of various personnel should be specified.
In the area of communication, guidelines must be drawn up explaining how
and when information concerning the episode is to be handled, how communica-
tion among various personnel is to be conducted, how questions concerning
the alert are to be dealt with, and how the public is to be made aware of
actions it must take. Under enforcement, the operational procedures should
indicate which agencies will be involved, how offenders will be determined
and dealt with, and when, if necessary, injunctions will be obtained. A
final area of importance involves personnel and equipment needs. The
necessary personnel requirements should be indicated, and equipment needs
should be listed along with other items which are to be prepared beforehand
(e.g. news releases).
2.2 DESCRIPTION OF THE LOS ANGELES PROBLEM
2.2.1 Geography, Demography, and Climate
Geography
The Metropolitan Los Angeles Air Quality Control Region, also known
as the South Coast Air-Basin, includes all of Orange and Ventura Counties
and portions of Los Angeles, Riverside, San Bernardino, and Santa Barbara
Counties. Geographically, the region is bounded by the Pacific Ocean on
18
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the west, by San Diego County on the south, and by a series of mountain
ranges on the north and east. Figure 2.3 gives a map of the basin and
illustrates its location within California, [2].
Demography
Around 10 million people, roughly one-half of California's population,
reside in the Metropolitan Los Angeles AQCR. Table 2.1 gives the distribu-
tion, by county, of population and land area within the region, [2], [7].
Los Angeles County, the most urbanized area of the region, includes 69% of
the regional population within 32% of the regional area. Orange County ranks
a distant second in population, with 16% of the regional total; however, its
population density is nearly that of Los Angeles.
Table 2.1. POPULATION AND LAND AREA - METROPOLITAN LOS ANGELES AQCR
County
Los Angeles
Orange
Riverside
San Bernardino
Santa Barbara
Ventura
Totals
California
Sources: State
County's Popul
in Basin - 1
6,890
1,565,000
342,000
565,000
153,000
411,000
9,926,000
20,218,000
of California,
% of County's
ation Population in
972 Basin
98.8
100.0
70.4
79.3
56.9
100.0
The Resources Agency,
Area in
Basin
(Mi2)
2,768
782
1,851
1,135
281
1,863
8,680
Population
Densi ty
(Persons/Mi^)
2,480
2,000
185
497
545
220
Air Resources Board,
The State of California Implementation Plan for Achieving and
Maintaining the National Ambient Air Quali
30, 1
State
Stati
972.
of California,
stical Abstract,
Department of Finance
1972.
ty Standards
, California
, January
19
-------
Location Of
Basin
SANTA
BARBARA
LOS ANGELES
£>
c
/
/
c
Figure 2.3. Metropolitan Los Angeles AQCR
Source: State" of~California, The Resources Agency, Air Resources Board,
The State of California Implementation Plan for Achieving and
Maintaining the National Ambient Air Quality Standards, Jan. 30, 19'I
20
-------
Table 2.2 summarizes the most recent population projections for the
region, [6]. As has been the typical pattern for Los Angeles, growth is
expected to be much greater in satellite areas than it will be in the central
Los Angeles area.
Table 2.2. POPULATION PROJECTIONS: COUNTIES WITHIN THE
METROPOLITAN LOS ANGELES AQCR (in millions)
Los Angeles
Orange
Riverside
San Bernardino
Santa Barbara
Ventura
Source: Population
Projections
1970
7.034
1.430
.461
.689
.258
.380
Research Unit,
of California
1975
7.255
1.688
.499
.750
.280
.451
Department
Counties to
1980
7.681
1.940
.573
.851
.315
.575
Approximate
Growth Rate
0.9%
3.1%
2.2%
2.2%
2.0%
4.1%
of Finance, Provisional
2000,
September 15, 1971.
The location and density of employment within Southern California is
illustrated in Figure 2.4, [25]. As was the case with population, the central
Los Angeles area contains the greatest concentration of employment. However,
in comparison to other metropolitan areas, the change in population and
employment density between Los Angeles and outlying areas is small. In
general, land use in Los Angeles has led to a sprawling, rather than concen-
trated, metropolitan area. The percentage of those employed by categories
is depicted in Table 2.3, [7]. Data are presented, for example, on the
percentage of workers in various levels of government.
21
-------
rv>
Figure 2.4. 1970 Employment in Southern California
I
L- ^-T,, „„„„,„„„
|i|3 \f|:
V| ' . * «-.«.«« » ;:••::
J .: : li 1^ _.^ _>^
:' - . ;•:; •:...<: • • • \ L '"' ...i— L!
1 "i$| «:
s
j
-. *
,1,
_.a. y _
T
REGIONAL STATISTICAL AREAS
SUB-COUNTY AfltAS
Stffif* Cft'fKIH jjttfitfrf* tf ffrtf/vr*/irt
Sub-Cou*, Af«c
BowAdcr? Lint
EMPLOYMENT
(persons employed/gross acre)
D . 01 -. 10
Ll3 .11-1.00
d 1.00-5.00
>s.oo
Source: Southern California Association of Governments, Employment Projections.
-------
Table 2.3
EMPLOYMENT IN THE METROPOLITAN LOS ANGELES AQCR
TOTAL CIVILIAN EMPLOYMENT 1973: 4,200,000
CATEGORY PERCENTAGE OF TOTAL EMPLOYMENT
CONTRACT CONSTRUCTING 3%
MANUFACTURING 25%
Nondurable Goods 8%
Durable Goods 17%
TRANSPORTATION & UTILITIES 5%
TRADE 20%
Wholesale 6%
Retail 14%
FINANCE, INSURANCE & REAL ESTATE 6%
SERVICES 17%
GOVERNMENT 14%
Federal 2-1/2%
State & Local 11-1/2%
TOTAL 100%
SOURCE: State of California, Department of Finance,
California Statistical Abstract, 1972
23
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Climate
The Metropolitan Los Angeles AQCR can be climatically classified as a
sub-tropical region. The total annual rainfall in the Basin is moderate
and occurs predominately in the winter season; oftentimes, the summer is
completely void of any precipitation. Although the coast can be moderately
cool, the inland valleys frequently experience very hot summers.
Wind patterns in the basin vary as a function of both time of day and
season. Typically, during the late spring, the summer, and the early fall,
a strong Seabreeze (4-8 mph) exists from late morning to evening; winds flow
from the west and sweep across the basin in an easterly manner, [22]. In
the evening, the winds stagnate and undergo a slight reversal; a very weak
land breeze (0-3 mph) exists. Figures 2.5a and 2.5b illustrate this pattern
\
for a typical October day, [2].
During the winter, the typical condition is a moderate daytime Seabreeze
and a moderate nighttime la^d breeze. Because of this balance, air masses
can remain in the basin for up to three days in the winter, whereas in the
summer, most of the basin on any day receives marine air from the Seabreeze,
[17], [22]. From day to day, the wind intensities and directions in these
typical patterns can vary. Also, atypical patterns, such as the strong
Santa Ana land breeze, periodically occur.
The differences in the winter and summer winds and precipitation are
just two aspects of a general winter-summer meteorological dichotomy that
exists in Southern California. Summer is characterized by high temperature,
intense solar radiation, and a persistent marine layer temperature inversion
that restricts vertical mixing. Winter has lower temperature and solar
radiation and a low, but weak nocturnal temperature inversion. As illustrated
24
-------
ro
en
Figure 2.5a. Air Flow Patterns - South Coast Air Basin (October 1200-1800 PST)
Source: State of California, The Resources Agency, Air Resources Board,
The State of California Implementation Plan for Achieving
and Maintaining the National Ambient Air Quality Standards,
January 30, 1972.
-------
X.
ro
cr>
» -a . \\y
'naf-df/j^^^L^^ ^
i -it^ ~-» iQi_^
•^^-^Jiis,^^^.—^^^ifc^^^^^^^^te^y-^v^j^^-^/
^_^, ---^^ _ --- _ ^- J^S^>_ ~ -^ ^^ -^ »-^,^ 3
^-~-—^ -—*"*—(T^—''^^C—"^—•~**4^-^--~s~ —^J^_^
^-^_i» -—- ••—^^c-—-~^-—*~~—^ov^-^^_!^»-'^—-^—^^-.—>v
--s ^"Jw-^^-^^rf-^^^---^—^^_xv^^—'-O«^._^v_^wx^i^.^.^^--w--^_^^_^O-"^j»H-.' *^s^y^jy--~—?ti^T_-'-*»-rf
^N^^^^^_^-x_«^^lI-^i^II---Il-^^ ' "<;'!LV_^-^^^^Z^^^~^ ^ ^"^-^-~-^^_^~ ^_^~^_^-s_x-
Figure 2.5b. Air Flow Patterns - South Coast Air Basin (October 0000-0700 PST)
Source: The State of California, The Resources Agency, Air Resources Board
The State of California Implementation Plan for Achieving and
Maintaining the National Ambient Air Quality Standards, January 30, 1972.
-------
in Figure 2.6 these weather patterns make winter the season for primary air
contaminants,* such as carbon monoxide, and summer the season for secondary
photochemical contaminants,* such as oxidant.
2.2.2 Overall Air Quality Levels
Air quality measurements taken in the Metropolitan Los Angeles AQCR
show the air pollution problem to be severe for all three of the contaminants
to be considered in this study, (oxidant, CO, and N02). The severity is
demonstrated by three indicators: (1) the geographic extent of the problem,
(2) the frequency of standard violations, and (3) the magnitude of the
standard violations.
Table 2.4 compares 1972 air quality levels for oxidant, CO, and N02 at
several selected stations in the basin to the National Ambient Air Quality
Standards. Figure 2.7 depicts the location of these air monitoring stations.
In 1972, oxidant levels exceeded the one-hour standard at every station. In
the central-eastern portion of the basin, (Azusa-Riverside), values 5 to 6
times the oxidant standard occurred several times. At these stations,
violations usually have occurred as many as 150 to 200 times per year. In
the basin as a whole, the oxidant standard typically has been exceeded 250
to 300 days per year.
The situation is only slightly better with CO. All stations except
Ventura exceeded the eight hour CO standard, and Ventura is just in compliance
In the central-coastal area, (Lennox-Reseda-Downtown-Anaheim-Pasadena), values
* Primary pollutants are those which are emitted directly into the atmo-
sphere, e.g. CO, HC, NO, SOp. Secondary pollutant are those which
result from chemical transformation processes involving primary pollutants,
e.g., N02, 03.
27
-------
30 ,
ro
CO
-—\
Q- 0.
D- 0_
f— -o
2: -1-
uj x
c_> o
2: c:
O o
c c
O KS
^a -a
S_ •!-
ra x
o o
10
CO
Oxidant
FIGURE 2.6. Comparison of Seasonal Pollution Patterns
Carbon Monoxide vs. Oxidant
(Average of Daily 1-hr. Maximum by Month:
Pasadena, 1970)
Source: Air Monitoring Logs of the Los Angeles County APCD
-------
Table 2.4. AIR QUALITY AT SELECTED SITES IN THE METROPOLITAN LOS ANGELES
AIR QUALITY CONTROL REGION, 1972
Station
Downtown L.A.
Lennox
Santa Barbara
Ventura County
Anaheim
Reseda
Pasadena
Azusa
Riverside
OXIDANT
Days Violating
Federal Standard
138
20
19
85
80
157
81
199
158
Maximum One
Hour Average
(PPM)
.25
.17
.10
.15
.35
.29
.38
.49
.50
CARBON MONOXIDE
Days Violating
Federal Standard
104
144
10
.0
50
98
43
6
98
Maximum Eight
Hour Average
(PPM)
34
33
f
16
8'6
34
37
34
i
I
14
25 1
NITROGEN DIOXIDE
Yearly Average
(PPM)
.078
.064
.02 - .03*
.02 - .03*
.046
.068
.076
.062
.04*
1 11
.08 1 I 9 1 .050
BU^aiga^s^Mu^&i^.'^^
* Estimated
Source.- California Air Resources Board, California Air Quality Data, Volumes II, III, IV, January 1971
through December 1972.
Air Monitoring Logs of the Los Angeles County APCD, Ventura County APCD, Riverside County APCD,
and Orange County APCD.
-------
co
o
Santa
Barbara
^ Full Station
* Partial Station
•fr NASN-EPA
Location Of
Basin
Pasadena
Azuza
Figure 2.7 Location of Air Quality Monitoring Stations
(Metropolitan Los Angeles AQCR - 197Q)
-------
up to 4 times the standard occurred. Lennox and Downtown Los-Angeles
exceeded the CO standard over TOO days in 1972.
The NCL pollution problem is the least severe of the three. The annual
average NCL standard was exceeded at most stations, but the excess was less
than 60%. The highest t^ levels occur in the central area, (.Downtown
Los Angeles - Pasadena).
The spatial distribution of each pollutant is consistent with the known
meteorology and emission source distribution. Since the marine layer inver-
sion ceiling is lowest near "the coast and since the central area has the
highest concentration of sources, carbon monoxide (a primary pollutant) is
greatest in the coastal to central area. N0? (an intermediate pollutant)*
is highest in the central basin, and oxidant (a secondary pollutant) is most
severe in the central to eastern portions of the basin. Both of these obser-
vations are consistent with the daily sea breeze blowing the polluted air
across the basin as photochemical reactions proceed. Santa Barbara and
Ventura experience the least pollution because they are relatively low in
source density and because they are not downstream of the most dense areas for
usual wind patterns.
2.2.3 Air Pollution Control Agencies
«,
There are basically three levels of government involved with air
pollution control in the Metropolitan Los Angeles AQCR: local Air Pollution
Control Districts (APCD's)at the county level, the California Air Resources
* N02 plays an intermediate role since it is first produced from the primary
contaminant, NO, but is then consumed as the photochemical reaction reaches
the end product stage.
31
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Board (ARB) at the state level, and the United States Environmental Protection
Agency (EPA) at the national level. Brief discussions of the major res-
ponsibilities and special capabilities of these agencies follows.
County APCD's
In California, County Air Pollution Control Districts (APCD's) have
local responsibility for air pollution problems. In the Metropolitan
Los Angeles AQCR there are six such agencies, corresponding to the six
counties partially or completely within the basin (see Table 2.1). The
oldest and largest of these is the Los Angeles County APCD, created by
the Air Pollution Control Act of 1947. The L.A. APCD's regulations as
well as its monitoring, calculational, permit, reporting, and enforcement
techniques have served as models for other California APCD's as well as
other agencies nationwide.
The primary responsibility of the local APCD's is to control
stationary sources of air pollution. This is done through a system of
regulations arid permit procedures. Inspection (source testing) and
enforcement operations are carried out to insure that the regulations
and permits are complied with. An engineering department is maintained to
support these efforts, [26].
Another APCD responsibility is to operate an air pollution emergency
alert system. (The next chapter will describe and evaluate this system
in detail.) Air monitoring programs have been established in each county
to support the alert function. The L.A. APCD maintains an extensive
monitoring system, with 12 full stations now in operation. The monitoring
data gathered by APCD stations provides important background data for
general air pollution control policy as well as the basic data for
alert warnings.
32
-------
The L.A. APCD also has become involved in air pollution research. It
presently maintains rather unique air quality analysis and meteorology
sections. The meteorology section has been concentrating recent efforts
on developing prediction capabilities for various pollutants. The oxidant
forecasting program has progressed very well, but predictions of other
pollutants, e.g. CO and NCL, are not yet reliable, [13].
The California ARE
The California Air Resources Board has responsibility for implementing
and enforcing the statewide air pollution control program. One ARB
function is to review, evaluate, and change (if necessary) local APCu
programs. At times, the ARB also provides certain APCD's with technical
services (air monitoring set-up, emission inventory compilation, etc.)
While the APCD's are concerned basically with stationary sources, the
ARB has primary responsibility for motor vehicle emission standards
and .accredits devices for the extensive California Used Car Retrofit
Program.
Other ARB functions include supporting research into the causes
and effects of air pollution, evaluating various plans as to air quality
impact, and performing certain basic technical studies. The ARB is
presently formulating a statewide air pollution episode contingency plan.
This preliminary plan will be described and evaluated in the next chapter.
The United States EPA
The Environmental Protection Agency is responsible for national environ-
mental programs. In air pollution, this responsibility basically trans-
lates to carrying out the provisions of the 1970 Federal Clean Air Act
(as amended). Accordingly, the EPA has promulgated national ambient air
quality standards (NAAQS) and has given the states a time table for
developing and implementing plans to achieve these standards. EPA
regulations also call for episode contingency plans to prevent "significant
33
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h-arm" air pollution levels from being reached. If the states do not
prepare satisfactory implementation plans, the EPA has the authority
to develop and carry out its own plan. The EPA is presently in the pro-
cess of evaluating and, where necessary, developing implementation
strategies for various air basins, including the Metropolitan Los Angeles
AQCR-.
2.2.4 Emission Source Inventory
Table 2.5 presents an approximate emission source inventory for
reactive hydrocarbons (RHC), CO, and NOV in the Metropolitan Los Angeler
A
AQCR. Percentage emissions for each source are given to the nearest %%.
Data are given for 1973. and projections are made through 1975 for the
following:
e Stationary Sources: Present APCD controls.
® Ljght Duty Motor Vehicles (LDMV's): The existing Federal
and California new car emission standards and the present
California ARB used car retrofit program for 1955-65 and
1966-70 vehicles.
« Heavy Duty Motor Vehicles (HDMV's) and Diesels: The present
Federal control program.
e Aircraft: The present Federal control program.
e Motorcycles: No controls.
Basically, Table 2.5 has been derived by projecting the 1970 California
ARB inventory, [3], and the 1970 L.A. County APCD inventory [21], to 1973
and 1975, while including the effect of various control programs. The data
for the projections, for the control effects, and for any corrections to the
inventory have been taken from references [14], [21], [27], [28], [29]. The
only very significant change in the ARB-APCD inventory is a change in hydro-
carbon reactivity assumptions; recent EPA results, 11], have been substituted
34
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for ARB-APCD reactivities in the mobile source and petroleum marketing
categories. The reactivity differences are summarized in Table 2.6.
• r* —
TABLE 2.5 AN APPROXIMATE EMISSION
- LOS ANGELES AQCR, 1973
STATIONARY SOURCES:
Petroleum Prod. & Refining
Petroleum Mrkting: Auto Tank Fill.
Petroleum Mrkting: Undgrd Tanks & Oth
Organic Indust. Surface Coating
Solvents kes. & uomm. burface loating
Dry Cleaning
Degreasing
Other
Steam Power Plants
Res., Comm., & Ind. Fuel Combustion
Other Stationary Sources
MOTOR VEHICLES:
Light Duty Motor Vehicles (LDMV's)
Heavy Duty Motor Vehicles (HDMV's)
Motorcycles
Diesels
OTHER MOBILE SOURCES:
Jet Aircraft
Piston Aircraft
Ships & Railroads
TOTAL PERCENTS
INVENTORY FOR THE
- 1975
PERCENT OF TOTAL
1973
RHC TCT NOx
k - 5k
8
.4 - k
2
2
k
Ik - -
2k - -
Ik
9k
1 1% k
58 87 65
8 7k 9
3 1%
1 k Ik
5 k k
2k ^k k
k - -
100% 100% 100%
METROPOLITAN
(to nearest 2%)
RHC
k
9
5
2k
2k
k
2
3
_
-
1
50
9
4
Ik
Sk
3
k
100%
1975
-or
_
-
-
-
-
—
-
-
_
-
2
83
Sk
2k
k
1
2
k
100%
NOX
6k
-
1
-
—
-
-
-
9
n
i
56
n
-
2
1
1
k
100%
TOTAL EMISSIONS, (TONS/DAY) 1
250 9000 1450
1100
7400 1
300
Table 2.5 shows that gasoline-powered motor vehicles (LDMV's, HDMV's
and motorcycles), constitute the largest source of all three emitted contam-
inants. In 1973, gasoline-powered vehicles account for 69% of RHC; 96% of CO;
35
-------
and 74% of NO . In 1975, they constitute 63% of RHC; 94% of CO;-and 67% of
X
NO LDMV's alone contribute 58% RHC; 87% CO; and 65% NOY in 1973. This
x A
shrinks to 50% RHC; 83% CO; and 56% N0v in 1975, because of the present
X
Federal and California new car controls and the present California ARB
retrofit program. Total emissions reduce from 1250 tons/day RHC; 9000
tons/day CO; 1450 tons/day NO in 1973 to 1100 tons/day RHC; 7400 tons/day
CO; and 1300 tons/day NO in 1975. This change is basically due to the
X
motor vehicle control programs.
TABLE-2.6. ALTERNATIVE HYDROCARBON REACTIVITY ASSUMPTIONS
SOURCE TYPE
Stationary Sources
Petroleum Production
& Refining
Petroleum Marketing
Organic Solvents
Others
Motor Vehicles
LDMV Exhaust
HDMV Exhaust
LDMV & HDMV Evaporative
Motorcycles
Diesels
Other Mobile Sources
Jet Aircraft
Piston Aircraft
ARB-APCD
REACTIVITY
10%
55%
20%
0-20%
75%
75%
55%
•t *•
10%
30%
75% Exhaust
55% Evaporative
REACTIVITY
USED HERE
(EPA)
10%
93%
20%
0-20%
77%
79%
93%
96% (2-Stroke)
86% (4-Stroke)
99%
90%
77% Exhaust
93% Evaporative
36
-------
Figures 2.8a, 2.8b, and 2.8c, summarize the trends in RHC, CO, and NO
A
emission levels from 1965 to 1980 under the present control program, [14],
[21], [29]. Notable reductions are being made for each contaminant during
/
the 1970's. To attain the NAAQS in the Los Angeles basin by 1975 or 1977
will require even greater reductions than indicated in Figure 2.8, especially
for RHC. Thus, one would expect even more controls to be initiated and even
further emission reductions to be achieved during this decade.
2.2.5 The Potential for Air Pollution Episodes
The purpose of this study is to formulate an episode contingency plan
which will insure that the federal "significant harm" levels for oxidant,
carbon monoxide, and nitrogen dioxide are "never reached" in the Metropolitan
Los Angeles AQCR. These levels, established by the EPA in the Code of Federal
Regulations - 40 CFR 51.16(a), are summarized in Table 2.7. The specifica-
tions include: one, two, and four hour oxidant averages; one, four, and
Table 2.7 FEDERAL SIGNIFICANT HARM
LEVELS FOR OXIDANT, CARBON
MONOXIDE, AND NITROGEN DIOXIDE
Pollutant Harm Level Averaging Time
Oxidant .70 PPM One Hour
.60 PPM Two Hours
.40 PPM Four Hours
Carbon 125 PPM One Hour
Monoxide 75 PPM Four Hours
50 PPM Eight Hours
Nitrogen 2.0 PPM One Hour
Dioxide .50 PPM Twenty-four Hours
37
-------
CO .
Z2!
O
co
CO
2000
o
00
~ZL
O
4 1000
CO
•z.
o
CO
CO
CO
z:
o
65
20,000
70
75
80
85
4 10,000
65
70
75
80
—4
85
CO
•z.
o
CO
to
X
o
Q
CO
z:
O
I- 2000
-L looo
65
70
75
80
-H
85
Figure 2.8 Total RHC, CO, and NO Emissions in the Metropolitan Los Angeles
AQCR Under the present Control Program (See Text,) 1965-1985
38
-------
eight hour carbon monoxide averages; and one, twenty-four hour nitrogen
dioxide averages.
Before formulating a contingency plan, it is useful to examine the
potential for air pollution episodes in the Los Angeles basin by answering
the question: How frequently would the "never to be reached, significant
harm" levels be attained without emergency controls? The answer to this
question may be very different for each contaminant; hence the three
pollutants will be discussed separately below.
Carbon Monoxide
It was shown earlier, (Table 2.4), that violations of the federal
air quality standard for carbon monoxide are large, frequent, and wide-
spread in the Metropolitan Los Angeles AQCR. The 9 PPM, 8 hour CO standard
typically has been violated around 150-225 days per year in the L.A. basin
during the late 60's and early 70's.* However, the "significant harm"
levels are much higher than federal air quality standards. Table 2.8
compares the significant harm levels to maximal carbon monoxide con-
centrations in the Metropolitan Los Angeles AQCR for 1970 through 1972.
Table 2.8 shows that the CO significant harm levels have not been
exceeded in the Los Angeles basin from 1970 through 1972. In fact, the
maximal recorded one hour CO level (54 PPM) is well below one half the one
hour harm level (125 PPM) and even well below the four hour harm level
(75 PPM). The eight hour CO harm level is the only one that appears to
be at all in danger of being exceeded. The nearest occurrence to a
* Actually, L.A. APCD records show a consistent violation frequency of
365 days per year prior to 1968. This is due to a flaw in air monitoring
practices for CO prior to April, 1968. Readings were high (by around
4 PPM on the average), with the actual error depending on absolute
humidity, [15].
39
-------
violation in 1970 -'1972 is a 36 PPM 8 hour CO concentration, only 28%
below' the 8 hour harm level (50 PPM).
It would be useful to examine monitoring data for CO even further in the
past, (say the 1960's and the late 1950's). However, prior to April 1968,
recorded CO data is considerably in error, [15J. Thus, we are restricted to
the recent past. The greatest one hour CO concentration since April 1968 is
65 PPM at Lennox in January 1969 [12]. This is still about one half the one
hour harm level. The greatest 8 hour recording is 42 PPM at Burbank in
December 1969, 16% below the 8 hour harm level.
Table 2.8 COMPARISON OF MAXIMUM CARBON MONOXIDE LEVELS
IN THE METROPOLITAN LOS ANGELES AQCR TO THE
FEDERAL SIGNIFICANT HARM LEVELS, 1970 THROUGH
1972
Averaging CO "Significant Maximum Five Values. 1970 - 1972
Time Harm" Level
54 PPM -
49 PPM -
1 m. 125 PPM 49 PPM -
48 PPM -
47 PPM -
4 m. 75 PPM
36 PPM -
33 PPM -
8 m. 50 PPM 33 PPM -
32 PPM -
32 PPM -
Reseda
Lennox
Lennox
Lennox
Lennox
October 1970
January 1971
November 1971
February 1970
December 1971
NOT AVAILABLE
Burbank
Reseda
Lennox
Burbank
Reseda
February 1970
November 1970
December 1972
January 1970
December 1972
Data Sources:
California Air Resources Board, California Air Quality Data
Volumes II, II & IV, January 1970 through December 1972.
Air Monitoring Logs of the Los Angeles County APCD.
40
-------
Based on Table 2.8, it appears that a violation of the one hour or four
hour CO harm level would be extremely rare at the CO emission levels of the
early 1970's. A violation of the eight hour CO harm level is more possible,
but even this would be very infrequent, (possibly once every 5 to 20 years).
As was shown in Figure 2.8, CO emission levels are rapidly declining, (it
may be significant that the maximum CO concentrations for 1970 - 1972 occurred
in 1970). By 1975 and 1980, CO emission levels should be 60% and 30%,
respectively, of the 1970 emission level. Furthermore, the emissions will
be slightly less concentrated since growth is occurring more in outlying
areas of the basin. These considerations indicated that it is highly
improbable that significant harm levels for CO will be reached in the
Metropolitan Los Angeles AQCR during this (or subsequent) decades.
Nitrogen Dioxide
The situation for nitrogen dioxide is similar to that for carbon
monoxide; although the annual mean NOp air quality standard is commonly
violated in the Los Angeles basin, exceeding the significant harm levels
appears highly unlikely. Table 2.9 compares the significant harm levels
to the maximal N02 levels recorded in the Metrpolitan Los Angeles AQCR
from 1970 to 1972.
Table 2.9 shows that N02 significant harm levels have not been
exceeded in the Los Angeles basin from 1970 to 1972. The maximal one
hour N02 concentration (.83 PPM) is less than one half the one hour
harm level. The maximum 24 hour N02 value (.35 PPM) is. 30% lower than the
twenty-four hour harm level (.50 PPM). On this basis, violations of the one
hour N0? level appear extremely improbable. Violations of the twenty-four
hour NOg harm level are more likely, but these would be very infrequent.
An examination of air monitoring data for the 1960's and late 1950's
41
-------
reveals that maximal one hour and twenty-four hour N02 values were near
or below those for the 1970-1972 period with six exceptions, [12]:
© 1.29 PPM for one hour (Downtown L.A., December 1958)
© 1.23 PPM for one hour (Burbank, December 1960)
© 1.00 PPM for one hour (Burbank, December 1959)
• .61 PPM for 24 hours (Burbank, January 1960)
g .47 PPM for 24 hours (Burbank, December 1959)
i .42 PPM for 24 hours (Lennox, October 1967)
Table 2.9. COMPARISON OF MAXIMUM NITROGEN DIOXIDE LEVELS
IN THE METROPOLITAN LOS ANGELES AQCR TO THE
FEDERAL SIGNIFICANT HARM LEVELS, 1970 THROUGH
1972
Averaging
Time
N0? "Significant
^Harm" Level
Maximum Five Values, 1970 - 1972
1 hr.
2.0 PPM
.83 PPM - Pasadena
.80 PPM - Downtown L.A.
.74 PPM - Downtown L.A.
,71 PPM -'Downtown L.A.
.67 PPM - Whittier
January 1970
January 1970
March 1971
July 1970
January 1972
24 hr.
,50 PPM
.35 PPM - Pasadena
.32 PPM - Whittier
.31 PPM - Burbank
.28 PPM - Downtown L.A.
.27 PPM - West L.A.
January 1970
January 1972
January 1970
January 1971
January 1971
Source: California Air Resources Board, California Air Quality Data,
Volumes_II, III & IV, January 1970 through December 1972.
Air Monitoring Logs of the Los Angeles County APCD.
42
-------
These are, respectively, the three highest one hour and twenty-four hour
NOp averages ever recorded in Los Angeles. The one hour maxima are still
far below the 2.0 PPM one hour harm level. The .61 PPM 24 hour average
in January 1960 is the only reported data exceeding the 24 hour harm
level (.50 PPM).
Based on these considerations > a violation of the one hour NO,, harm
level would be expected to occur almost never at the NO emission level of
^ " ~~~ J *"-—""'- J J — •"• j_... -. j. _ .A "~" ' ~ J
the early 1970's. Violation of the twenty-four hour harm level would be
extremely infrequent (possibly once every 5-20 years). As was shown in
Figure 2.9, NO emissions will decline considerably in the Los Angeles basin.
A
By 1975 and 1980, NO emission levels should be respectively 75% and 55% of
X
the 1970 emission level. Furthermore, the emission spatial distribution
will be slightly less concentrated. This leads to the conclusion that it is
very improbable that significant harm levels for NOg will be reached in the
Los Angeles basin during this (or subsequent) decades.
Photochemical Oxidant
The situation is much different with oxidant; the Los Angeles Metropolitan
AQCR is notorious for extremely high oxidant concentrations. Oxidant values
up to seven or eight times the federal air quality standard are known to
occur. Data has been gathered and is presented in Appendix C which compares
maximal one, two and four hour oxidant averages in the Metropolitan Los Angeles
AQCR to the federal "significant harm levels." Appendix C includes all days
in 1-70 through 6-73 with maximal one hour oxidant greater than or equal to
.40 PPM. In the Appendix, violations of significant harm levels are marked
with an asterisk. The data for these violation days are summarized in
Table 2.10.
43
-------
Table 2.10
OXIDAHT EPISODES EXCEEDING
FEDERAL SIGNIFICANT HARM LEVELS
IN THE METROPOLITAN LOS ANGELES
AIR QUALITY CONTROL REGION
(1-70 - 6-73)
Federal Significant Harm Levels
Date Station
Tuesday, 2 June 1970 Azusa
Pamcna
Tuesday, 2 June 1970 Azusa
Parnona
Wednesday, 24 June 1970 Redlands
Saturday, 4 July 1970 Pasadena
Thursday, 6 August 1970 Riverside
Azusa
Friday, 7 August 1970 Azusa
Riverside
Thursday, 10 Sept. 1970 San
Bernardino
Friday, 11 Sept. 1970 Azusa
Monday, 13 Sept. 1971 Riverside
Thursday, 29 June 1972 Riverside
Tuesday, 11 July 1972 Azusa
Wednesday, 6 June 1973 Upland
Friday, 8 June 1973 Fontana
Thursday, 21 June 1973 Downtown
Los Angeles
* Significant Harm Level Exceeded
Maximum
One Hour
Average
(PPM)
.70
.47
.47
.47
.47
.52
.45
.62
.49
.58
.48
.42
.47
.56
.45
.47
.60
.44
.52
Maximum
Two Hour
Average
(PPM)
.60
.46
.45
.46
.45
.47
.44
.59
.49
.54
.45
.42
.47
.47
.44
.44
.53
.44
.52
Maximum
Four Hour
Average
(PPM)
.40
.42*
.42*
.42*
.42*
.43*
.41*
.53*
.44*
.46*
.42*
.44*
.42*
.40*
.40*
.40*
.46*
.41*
.47*
NOTE:
Source: California Air Resources Board, California Air Quality Data.
Volumes II. Ill & IV, January 1970 through December 1972.
Air Monitoring Logs of the Los Angeles County APCD
" " " San Bernardino " "
" " " Riverside " "
" " " Orange " "
: Data in 1970 and 1971 from the UC Riverside station at Upland have
not been included in this table. That station frequently experienced
the highest oxidant concentrations in the basin; however, a data
analysis by the ARB has lead to the conclusion that the UCR Upland
data are unreliable.
44
-------
Table 2.10 indicates that in 1970-1973, the 1 hour harm level (.70 PPM)
and the 2 hour harm level (.60 PPM) were not exceeded. The maximum 1 hour
average was .62 PPM, and the maximum 2 hour average was .59 PPM, both at
Riverside, 6 August 1970. The 4 hour harm level (.40 PPM) was exceeded 14
times, (8 in 1970, 1 in 1971, 2 on 1972 and 3 in 1973). The maximal 4 hour
average was .53 PPM, again at Riverside, 6 August 1970.
Monitoring data prior to 1970 also has been examined, [12]. The three
highest one hour oxidant values that have been recorded prior to 1970 are
shown in Table 2.11.
I r\ui_i_ <- . i i .
SEVERE OXIDANT EPISODES IN
THE METROPOLITAN LOS ANGELES
AIR QUALITY CONTROL REGION
Federal Significant Harm Level
Station
Pasadena - July 1955
Downtown LA - Sept. 1955
Azusa - Aug 1967
*Significant Harm Level Exceeded
Maximum
One Hour
Average
(PRM)
.70
.74*
.68
.65
Maximum
Two Hour
Average
(PPM)
.60
.69*
.56
.58
Maximum
Four Hour
Average
(PPM)
.40
.58*
.44*
.48*
Appendix C and Tables 2.10 and 2.11 point toward the following conclusions:
• Violations of the 1 hour and 2 hour oxidant harm levels would tend
to be rare (say about every 5 to 10years)at 1970-1973 emission levels. The only
recorded violation of each occurred back in 1955,although the 2 hour harm level
was almost reached in 1967 (.58 PPM: Azusa, August) and 1970 (.59 PPM: Riverside,
August).
45
-------
e Violations of the 4 hour oxidant harm level (.40 PPM) are much
more common; they should be expected, on the average, almost 3 to 5 times
per year at the 1970 - 1973 emission level. In the past, the greatest excess
of the 4 hour harm level occurred at Pasadena in 1955, .58 PPM (45% excess).
In recent years,-the greatest excess has been in Riverside in 1970, .53 PPM
(33% excess). The second greatest level in recent years occurred in Downtown
Los Angeles in 1973, .47 PPM (18% excess].
© Even though the one and two hour harm levels might be (rarely)
exceeded, the 4 hour harm level appears to be the binding constraint^ My
days that approach the one or two hour harm level easily exceed the four hour
level. For instance, all recorded days with one hour level above .60 PPM or
two hour level above .55 PPM show a four hour level in excess of .44 PPM.
e As was shown in Figure 2.8, RHC and NO emission levels are
A
decreasing in the Los Angeles Basin. Violation of the one and two hour harm
levels will be even less likely in the future; they might not even occur.
Violation of the four hour harm level will continue to occur, but the fre-
quency and magnitude of these violations should decrease through this decade.
In summary, including consideration of decreasing emissions, the potential
for exceeding the federal "significant harm levels" for oxidant, CO, and
N02 in the Metropolitan Los Angeles AQCR is as follows:
®®@ It is extremely probable that the one and four hour CO harm levels
and the one hour N02 harm level will never be exceeded in this decade.
(subjectively one chance in 100 to 1000).*
These probabilities could be actually estimated by doing a statistical
analysis of past air monitoring data and by allowing for emission level
changes. However, such a detailed calculation is not within the scope
of this study.
46
-------
It is 1ikely that the eight hour CO harm level and twenty-four
hour N02 harm level will never be exceeded in this decade, (subjectively one
chance in 10 to 100).*
•e» It is possible that the one or two hour oxidant harm levels will
be exceeded in this decade, (subjectively one chance in two).
It is highly probable that the four hour oxidant harm level will
contin.ue to be exceeded. Violations are occurring an average of 3 to 5 times
per year in the early 1970's. The violation frequency should decrease con-
siderably by the end of the decade.
2.2.6 Transportation Data Base
Gasoline powered motor vehicles, (including auto tank filling at
service stations), account for 77% of RHC, 96% of CO, and 74% of NO
/^
emissions in the Metropolitan Los Angeles AQCR. An effective episode
contingency plan must include measures to abate traffic emissions. Later
in this study, a series of alternative transportation controls will be
evaluated. In order to determine the effectiveness of these controls, a
transportation data base is required.
The most extensive transportation data for Southern California has been
generated in the ongoing Los Angeles Regional Transportation Study (LARTS)
by the California Department of Transportation (DOT)**, [8], [9]. The LARTS
study area includes all of Los Angeles, Orange, and Ventura counties and the
western, most developed portions of Riverside and San Bernardino counties.
*These probabilities could be actually estimated by doing a statistical
analysis of past air monitoring data and by allowing for emission level
changes. However, such a detailed calculation is not within the scope
of this study.
**Formerly the Division of Highways.
47
-------
The boundaries do not coincide exactly with the Metropolitan Los Angeles
AQCR, (Santa Barbara County is omitted while portions of Los Angeles,
San Bernardino, and Riverside County are added). However, on the whole the
two regions are nearly equivalent; the population contained in each is
almost idential [28], It is therefore assumed here that the LARTS trans-
portation data is representative of the Metropolitan Los Angeles AQCR.
The LARTS project, as reported in the LARTS 1967 Base Year Report,
(1971), [8] , and the 1966 Base Year_ Calibration Report, (1972), [9] , has
surveyed approximately 2% of total daily trips in the LARTS region. This
survey has provided information on total trips taken, with breakdowns for
various types of trip categories. When combined with estimates of average
length for different trip types, [28], results can be obtained for vehicle
miles travelled (VMT).
Table 2,12 presents results for average weekday VMT. Total auto VMT
is presented along with percentages for freeway vs non-freeway and for
morning and afternoon rush hours. Values are given for 1967 (LARTS base
year), and projections have been obtained for 1980, [16], [28]. Linear
interpolation provides the values for 1973 and 1975. These results are
current in the sense that previous estimates, [28], have been modified to
include the latest correction factors, ([20], July 1973).
In formulating a contingency plan for Los Angeles air pollution
episodes, this study will later consider, as potential controls, measures
which eliminate various incentives to drive ("trip purposes"). In order
to ascertain the overall effect of these controls, it will be necessary
to know how total VMT is distributed according to various trip purposes.
Basic data on percentage of total trips by trip purpose has been provided
48
-------
by LARTS studies, [8], [9], [20], and by a System Development Corporation
survey, [18]. This data has been reviewed and reworked in other transpor-
tation studies, [16], [28], Unfortunately, very significant disagreements
exist among these various reports. After careful analysis of these differ-
ences, it has been concluded that, on the whole, recently corrected LARTS
data is most reliable. The SDC survey is based on a very small sample and
it contains a considerable bias since only employed drivers were included
in the survey. The other studies, [16], [28], have not benefited from very
recent LARTS correction factors. Thus LARTS data will serve as the basis
for most results given below.
Table 2.12 AVERAGE WEEKDAY VMT IN THE LARTS REGION -
TOTAL, FREEWAY, NON-FREEWAY, AND RUSH-HOUR
Year
1967
1973C
1975C
1980b
Total VMTa
•(Million Miles\
\ Per Day /
153
183
194
219
Freeway
45%
48%
49%
52%
Non-Freeway
55%
52%
51%
48%
• d
Morning
Rush Hour
(7:24 - 8:24)
10.5%
10.5%
10.5%
10.5%
Evening
Rush Hour
(16:24 - 17:24)
11.8%
11.8%
' 11.8%
11.8%
Computed from references [8], [20], and [28]
b Reference [28].
Linear interpolation.
Computed from reference [28].
49
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Table 2.13 presents the distribution of total vehicle trips and total
VMT by trip purpose. Values are given for average weekdays as well as
for average weekends. The notable and expected difference between weekdays
and weekends is a considerable decline in the percentage of work related
VMT, 42% to 18%.
Table 2.13
DISTRIBUTION OF VEHICLE TRIPS AND TOTAL VMT
BY TRIP TYPE: WEEKDAYS AND WEEKENDS
j '
Trip
Home -
Work -
Home -
Home -
Other -
Type
Work
Otherd
Shop
Other
Otherd
Average
Length
(Miles)
10
7 1/2
3
6 1/2
6
1
AVERAGE WE
i •
Percent Of
Vehicle Trips
21%
9%
14%
28%
28%
IEKDAY
Percent Ofc
Total VMT
32%
10%
6%
27%
25%
AVERAGE W
Percent Ofb
Vehicle Trips
9%
2%
20%
41%
28%
EEKEND
Percent Of(
Total VMT
15%
3%
10%
44%
2B%
Based on References [18] and [28].
Updated LARTS data, [8] and [20].
Calculated from average trip length and percentage by trip type.
Fleet vehicle travel is accounted for in these two categories.
Table 2.14 compares average weekday total auto trips and VMT to average
weekend values. These results have been obtained by combining data from
the LARTS and SDC surveys and by obtaining actual traffic counts from the
50
-------
Division of Highways (data was used from eight widely separated stations),
[11]. Table 2.14 shows that total auto trips decrease around 22% on weekends
while total VMT decreases around 30%. VMT declines more than total trips
because weekend trips generally occur more often in shorter trip categories.
Table 2.14 also shows that VMT reductions are significantly greater on
Sundays (36%) than on Saturdays (24%).
Table 2.14 AVERAGE WEEKDAY vs. WEEKEND TOTAL
TRIPS AND VMT; 1973
Average
Weekday
Average
Saturday
Average
Sunday
Average
Weekend
Total Autod
Vehicle Trips
Million Trips
Per Day
21.9
Percentage of Weekday
84%
72%
78%
Total Auto VMT
Million Miles
Per Day
183
Percentage of Weekday
b i
76%
64%
70%
Corrected LARTS data [3] and [20J-
Based on LARTS data, [8] and [20], SDC survey data [18] and
[28], and traffic counts obtained from the Department of Trans-
portation, [11].
51
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By combining Tables 2.13 and 2.14 into Table 2.15, some approximate
but significant conclusions can be made about substitute driving. To make
weekend and weekday values more comparable, Table 2.15 gives weekend and
weekday VMT in various trip categories, both as % of average weekday VMT.
Table 2.15 shows that VMT in the Home-Work and Work-Other categories decreases
by 30% (as a percentage of total weekday VMT) from weekdays to weekends.
VMT in the Home-Shop and Home-Other categories increases by a total of 5%.
Basically due to a decrease in business travel, VMT in the Other-Other^
category decreases by 5%. Now, the weekend decrease in total "commuter"
travel is probably around 26-28% (some of the decrease in Work-Other is
due to business). The resulting increase in Home-Shop, Home-Other, and
Other-Other trips resulting from this is probably around 5-7% (the 5%
mentioned above plus some increase in the Other-Other category that does
Table 2.15 COMPARISON-OF WEEKDAY - WEEKEND
VMT ACCORDING TO TRIP TYPE
Trip Type
Home - Work
'Work - Other3
Home - Shop
Home - Other
Other - Other9
TOTAL
VMT As % Of Average Weekday
Weekday
32%
10%
6%
27%
25%
100%
Weekend
10%
2%
7%
31%
20%
70%
Change
-22%
- 8%
+ 1%
+ 4%
- 5%
-30%
Fleet vehicles are accounted for in these two categories,
52
-------
not appear because of lessened business travel). Thus, as a first
approximation, a decrease in X% of commuter travel brings about a
corresponding Increase of around I/5X in substitute driving, so that
the overall decrease is only around 4/5X.
Table 2.16 presents LARTS data on average automobile occupancy rates,
[8]. Values are given for weekdays and weekends and for each of the trip
type categories. The striking feature of this table is the low average
occupancy rate, 1.1, of Home-Work and Work-Other trips.
Table 2.16 CURRENT AUTOMOBILE OCCUPANCY RATES IN THE
SOUTH COAST BASIN
Average
Weekend Day
Weekday
Home-
Other
2.0
1.7
Other-
Other
1.6
1.3
Work-
Other
1.1
1.1
Home-
Work
1.1
1.1
Home-
Shop
1.5
1.4
Total
1.8
1.4
Reference [ 8]•
2.2.7 An Approximate Air Quality-Emission Level Relationship
In order to ascertain the effectiveness of an episode contingency plan
(in preventing "significant harm" air pollution levels) one must know the
relationship between air quality and the emission level changes brought
about by the plan. This section develops an approximate relationship for
the Metropolitan Los Angeles AQCR.
In general, air quality-emission level relations for episode control
tend to be less than proportional. For example, a 30% reduction in emissions
on a given day tends to bring about less than a 30% improvement in air
53
-------
quality. This effect is due to residual pollution left from previous days
emissions. The greater the "background" pollution, the less will air quality
on a given day respond to emission reductions on that day. In Los Angeles,
the residual effect may be especially significant for CO and N02 episodes.
The highest CO and N02 levels occur during the winter months, (see Figure 2.6),
and an air mass can remain in the Los Angeles basin for up to two or three
days during the winter season, [17].
Photochemical oxidant is greatest during the summer and early fall.
Fortunately, during the summer, the strong sea breeze tends to sweep the
polluted air nearly completely across the basin on a daily basis. Although
oxidant episodes sometimes occur on successive days, this is usually because
the same meteorological pattern occurs on successive days and not because the
same air mass remains in the basin for long periods. However, residual
pollution is still significant. Further, with oxidant, there is a separate
important factor which leads to a less than proportional air qual ity-emis'sibn
level relationship. The non-linear chemical nature of the oxidant-hydrocarbon
relationship appears to be inherently a less than proportional dependence
when both RHC and NOX are reduced by the same percentage, [21], [24], [27].
In this study, in order to estimate how air quality will respond to
episode emission reductions, an analysis will be made comparing weekday
pollution levels for CO and oxidant to weekend levels. Table 2.14 showed
that VMT is 24%, 36%, and 30% lower on average Saturdays, Sundays, and
weekends than it is on weekdays*. Since CO emissions result almost entirely
There is also a spatial redistribution of traffic. On weekdays the
pattern is concentrated at central business districts. On weekends
the pattern is concentrated more at the beaches and outlying areas
54
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from traffic, it will be assumed that they are reduced as VMT. How
stationary sources of hydrocarbons change on weekends has not been docu-
mented. As a first approximation, it will be assumed here that total RHC
emission levels also change as VMT.
Only two existing sources were found comparing weekend to weekday
pollution levels in Los Angeles, [4], [23]. A 1966 paper by Shuck, Pitts
and Wan, [23], indicates that morning peak carbon monoxide levels in Downtown
Los Angeles were around 20% lower on weekends than on weekdays from 7-62
to 6-64. This paper also presents some data on average oxidant by day of
week. Calculations with this data have yielded the results shown in
Table 2.17 . Table 2.17 indicates that near the coast (with low max. oxidant)
there is little, if any, improvement on weekends. Possibly this is due to
a shift in traffic toward the coast. However, further inland (where
oxidant is greatest) there is significant improvement on weekends, around
10 to 15%. At each station except Lennox, pollution reductions are
slightly better on Sundays than on Saturdays.
The California Air Resources Board, [4], indicates that oxidant values
are around 15-17% lower on average Sundays than on average weekdays at
inland stations. These results are significant since they include ten years
of data for July through September.
To check these conclusions, data for 1970 through 1972 were examined
in the present study, [5]. CO data were taken for December, January, and
February, the months with maximal primary contaminants. Oxidant data were
taken for June through September. Tables 2.18 and 2.19 summarize the
results. Table 2.18 shows that for Lennox, Downtown Los Angeles, and
Pasadena, (three of the stations which experience the highest values for
55
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Table 2.17 AVERAGE WEEKEND DAY AND WEEKDAY MAX. OXIDANT:
FOUR STATIONS, 7-62 to 6-64
Station
Lennox
(Inglewood)
Downtown
Los Angeles
Pasadena
Azusa
Average Weekday
Value (PPM)
.08
.13
.17
.17
Average Week*
Percentage of A
Saturday
106%
96%
87%
90%
2nd Day As
^erage Weekday
Sunday
106%
94%
83%
86%
Average
Weekend-
Weekday
Change
+ 6%
- 5%
-15%
-12%
-a
c:
fO
QJ
O
(/)
Q
rO
V
Reference [23].
primary pollutants), weekend CO values averaged from 13-27% lower than weekday
values during this period. This tends to confirm the previous estimate of
20%. However, Table 2.19 shows that weekend oxidant values at inland stations
averaged only 6-11% lower on weekends than on weekdays. There is less of an
effect than the previously reported 10-17% change. Of course, the results in
Tables 2.18 and 2.19 can contain significant statistical error since the
sample size (around 50 weekend-weekday comparisons) is not very large.
Summarizing, at stations which experience maximal pollution levels,
CO concentrations tend to average approximately 20% lower on weekends and
oxidant concentrations tend to average approximately 15% lower on weekends.
Assuming a 30% reduction in emissions on weekends this indicates that, due
to residual pollution, episode control is only around 2/3 effective for
primary pollutants. Due to residual pollution and nonlinearities in the
56
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Table 2.18 AVERAGE DAILY MAXIMAL ONE HOUR CARBON MONOXIDE AT
THREE STATIONS, WEEKENDS vs. WEEKDAYS:
December - February, 1969-1972
Station
Lennox
Downtown
Los Angeles
Pasadena
Average Weekday
Value (PPM)
21
17
15
Average Weeker
Percentage of A\
Saturday
91%
73%
90%
d Value As
^erage Weekday
Sunday
83%
73%
82%
Average
Weekend-
Weekday
Change
-13%
-27%
-14%
Data obtained from California Air Resources Board, California Air Quality
Data, Vol. II, III, and IV.
Table 2.19 AVERAGE DAILY MAXIMAL ONE HOUR OXIDANT AT
FIVE STATIONS, WEEKENDS vs. WEEKDAYS:
June - September, 1970-1972
Station
Downtown
Los Angeles
Reseda
Pasadena
Azusa
Riverside
Average Weekday
Value (PPM)
11
15
21
23
23
Average Week
Percentage of Av
Saturday
105%
92%
94%
96%
92%
,end As A
'erage Weekday
Sunday
113%
94%
90%
92%
86%
Average
Weekend-
Weekday
Change
+ 9%
- 7%
- 8%
- 6%
-11%
"O
Q)
O
ro
-t->
CO
•i—
Q
CD
^
Data obtained from California Air Resources Board, California Air Quality
Data, Vol. II, III, and IV.
57
-------
oxidant-precursor relation, episode control is only around 1/2 effective for
photochemical pollutants. Accordingly, it will be assumed in this work that
on a given day, an X% reduction in CO or N0,,emissions will result in only a
.. . . ,t* .. .— .. -. . j/ • — • • — * A
An
reduction in
2/3X% reduction in CO and [^concentrations on that day.
RHC emissions on a given day will be assumed to bring about only 1/2X% reduc-
tion in maximal oxidant values on that day. It should be emphasized that
this is a very approximate relationship. It is only intended to be a "first
order", linear correction to account for some obvious and important non-
t
linearities in the air quality relationship for episode control.
By using the emission inventory presented in Table 2.5, VMT reductions
can be translated into emission reductions. In making this calculation the
effect on RHC emissions from auto tank filling at service stations should be
included, (i.e. reducing VMT by a given % reduces auto tank filling emissions
by the same %). These calculations have been performed and are presented in
Table 2.20. Using the approximate air quality-emission level functions
Table 2.20.
THE EFFECT OF VMT REDUCTIONS ON TOTAL EMISSION LEVELS*
(For Base Year: 1974)
VMT Reduction
Reduce LDMV VMT by X
Reduce HDMV VMT by X
Reduce both LDMV and HDMV
VMT by X
Correspond
RHC
.62X
.10X
.72X
ing Emission
CO
.85X
.08X
.93X
Reduction
NOX
.60X
.10X
.70X
*This includes the effect on RHC emissions at service stations
from vehicle tank filling.
58
-------
above, VMT reductions can also be translated into air quality improvements,
These results are presented in Table 2.21.
Table'2.21
THE APPROXIMATE EFFECT OF CONTINGENCY PLAN EMISSION
AND VMT REDUCTIONS ON AIR QUALITY
Emission Reduction
Reduce RHC Emissions by X
Reduce CO Emissions by X
Reduce NO Emissions by X
X
VMT Reduction
Reduce LDMV VMT by X
Reduce HDMV VMT by X
Reduce LDMV and HDMV
VMT by X
Correspond!' r
Oxidant
%X
--
--
g Pollutio
CO
__
2/3X
—
n Reduction
N02
—
—
2/3X
.SIX
.05X
.36X
.57X
.05X
.62X
.40X
.07X
.47X
59
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2.3 SPECIAL CONTINGENCY PLAN CONSIDERATIONS FOR THE LOS ANGELES AREA
Section 2.1 described the main elements of general contingency plans.
These were episode criteria, control strategies, surveillance procedures
and operational procedures. Of course, the details of these elements should
depend on the specific situation for which a contingency plan is formulated.
For instance, the details would be much different for an S02 episode plan in
Chicago than they would be for an oxidant plan in San Francisco.
Section 2.2 reviewed the air pollution problem in the Metropolitan
Los Angeles AQCR. This review has established certain special considerations
which should be accounted for in a contingency plan for Los Angeles. These
special considerations are summarized below.
Episode Criteria
• For oxidant, the plan should center around preventing the
.40 PPM four hour average harm level.* This level is exceeded
in the Metropolitan Los Angeles AQCR on the average around
3 to 5 times per year. The .60 PPM two hour average and the
.70 PPM one hour average are exceeded much less frequently.
Furthermore, it is virtually certain that if the one or two
hour averages are exceeded that the four hour average also will
be exceeded.
e
Forecasting (feedforward) type criteria should be adopted,
especially for oxidant. Vehicular traffic is the principal
source of all three types of emissions under consideration (RHC,
N0x and CO), and effective traffic abatement seems to require
*This assumes the EPA four-hour-average significant oxidant harm level for
oxidant is not changed.
60
-------
that an alert be called before the morning rush hour. For oxi-
dant alerts, forecasting is absolutely necessary. Even if sources
could be instantaneously shut down when oxidant started to reach
danger levels, oxidant levels still might continue to increase.
• Feedback criteria might be acceptable for CO and NQp. Forecasts
of CO and NCL levels are less accurate than forecasts of oxidant
levels. Also, CO and NOp levels respond more quickly to a source
shutdown. If an acceptable method of significantly reducing
traffic with little advanced notice could be derived, feedback
criteria for CO and NO^ could be sufficient. These issues, as
they pertain to CO and N0?, are not very critical, however, since
it is extremely unlikely that CO or N02 will ever reach signifi-
cant harm levels in this decade even without a contingency plan.
Control Strategies
o Control measures should be instituted for both stationary and
mobile sources. Vehicular emissions must be controlled because
they constitute the greatest single source category. Gasoline
powered motor vehicles (LDMV's, HDMV's, and motorcycles), account
for 77%* of RHC, 96% of CO, and 74% of N0v emissions in the
X
Los Angeles area. Stationary sources account for less of the
total; however, they are significant and they often represent
very concentrated sources of emissions. It is often simpler to
control a few concentrated sources than it is to control many,
j/
disperse'automobiles. Thus, stationary sources should be
is includes automobile tank filling at gas stations
61
-------
included although their aggregate contribution is much less
than mobile sources.
As indicated in Section 2.2.7, to attain a given percentage reduction
in air pollutant concentration on a given day, a disproportionately
greater percentage reduction in emissions is required on that day.
This is due to leftover or residual pollutants remaining from the
previous day's emissions. The magnitude of this residual and of
the disproportionality vary from day to day, depending on meteoro-
logical conditions. As a first approximation, it may be assumed
that an X% reduction in CO or NO emissions on a given day will
~ ~J~~ "~ X* """*~"~"—————
result in a 2/3X% reduction in CO and NO,, air pollution levels.
For oxidant, due to residual pollutants as well as to the non-
linearity of the precursor relationship (RHC—>-Oo formation) s
an X% reduction in RHC emissions on a given day will result in
only a 1/2X% reduction in oxidant levels.
Control measures should be implemented on.a region-wide basis,
with the exception of Ventura and Santa Barbara counties. Air
pollution in Ventura and Santa Barbara Counties is much less
severe than air pollution in the other four counties of the
Metropolitan Los Angeles AQCR, (See Table 2.3). In fact, air
pollution alerts should not be expected to occur in those two
counties. Furthermore, Ventura and Santa Barbara counties do
not contribute significant pollutants to the other four counties.
Thus, a division of the total region into a four county control
region (Los Angeles, Orange, Riverside and San Bernardino), with
Ventura or Santa Barbara to be added only under special conditions,
seems called for. However, any further subdivision of the
62
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region for episode control does not seem practical. Implementing
control on a subregion basis would require prediction of the
general trajectories of air parcels that will reach alert levels,
(control could then be initiated in the regions along the
trajectories). Reliable forecasting of this type seems doubtful.
The four county region should be treated as a whole (unless an
acceptable trajectory forecasting scheme is devised).
Surveillance Procedures
© Appropriate air monitoring surveillance can be maintained with
existing air monitoring stations. As shown in Figure 2.7,
numerous air monitoring stations exist in the Metropolitan
Los Angeles AQCR. The local APCD's, in particular, conduct
an extensive, continuous monitoring program. Adequate air
monitoring data is generated in the basin. The key problem
as to air quality surveillance might be to promote enough
cooperation between the various agencies involved so that
reliable communication channels are established.
9 For source activity surveillance, it may be possible to rely on
expanding present local and state programs during episodes.
The county APCD's have considerable experience in monitoring
stationary source activities. The California Department of
Transportation (DOT) maintains continuous traffic counts on
certain freeways and state highways. These facilities would
be extremely useful in monitoring source response during an
episode. Again, this will depend on establishing a cooperative
working association with local and state agencies.
63
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Operational Procedures
s A cooperative working relationship with local and state agencies
would be valuable in operating an episode contingency plan.
As mentioned above, county and state capabilities would be very
useful in monitoring air quality as well as surveying stationary
and mobile source activity levels. Cooperation also may be
fruitful in air quality forecasting and in control measure
enforcement and implementation.
© The overall episode program should be flexible and should be
changed as new information is obtained by its implementation.
The technical analysis which supports the contingency plan will
contain many uncertainties. This is especially true for the
Los Angeles area because of the complexity of photochemical
smog (hydrocarbon reactivities, oxidant-precursor relationships,
etc.) and because of the necessity to adopt rather stringent
and untested traffic control procedures. Once the plan is
actually tried, it may be found not to be effectual enough,
(in that it does not prevent significant harm levels). Alterna-
tively, it may be found overly effective (in that it reduces
pollution far below the harm levels but at a very high social
cost). The program should be flexible enough to allow changes
in the plan as warranted.
64
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REFERENCES - CHAPTER 2
1. Altshuller, A. P., "Recommendations on Reactive Hydrocarbons (Organics)
as Related to Photochemical Oxidant Formation", Working Paper - EPA
National Environmental Research Center, 1973.
2. California Air Resources Board, The State of California Implementation
Plan for Achieving and Maintaining the National Ambient Air Quality
Standards, January 30, 1972.
3. California Air Resources Board, California Emission Inventory, 1970,
July 1972.
4. California Air Resources Board, Personal Communication with Technical
Services Division, September, 1973.
5. California Air Resources Board, California Air Quality Data, Volumes III
and IV, January 1970 - December 1972.
6. California Department of Finance, Provisional Projections of California
Counties to 2000, September 15, 1971.
7. California Department of Finance, California Statistical Abstract, 1972,
Sacramento, California, 1972.
8. California Department of Transportation, LARTS Base Year Report, 1967
Origin - Destination Survey, December, 1971.
9. California Department of Transportation, California Statewide Transporta-
tion Study, 1966 Base Year Calibration Report, May, 1972.
10. California Department of Transportation, Advanced Planning Department,
District 7, Personal Communication, November 1972.
11. California Department of Transportation, Data Processing Department,
Personal Communication of Data Recorded by the Los Angeles Freeway
Surveillance and Control Project and by Monitoring of State Highways,
September, 1973.
12. County Air Pollution Control Districts (Los Angeles, Orange, Riverside,
and San Bernardino), Air Monitoring Logs for Oxidant, Carbon Monoxide,
and Nitrogen Dioxide.
13. Davidson, Arthur, Meteorologist - Los Angeles County Air Pollution
Control District, Personal Communication, August, 1973.
14. Environmental Quality Laboratory, Smog: A Report to the People of
the South Coast Air Basin, EQL Report No. 4, California Institute
of Technology, 1972.
65
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15. Foon, Julian, Data Processing - Los Angeles County Air Pollution
Control District, Personal Communication, August, 1973,
16. Gray, G. E., Watkins, R. 0., and Kirchner, F. F., Can Vehicle Travel
Be Reduced 20 Percent in the South Coast Air Basin? Report of the
California Deparment of Public Works to the California Air Resources
Board, January, 1973.
17. Holmes, R. G., Kauper, E. K., Street, A. B., and Taylor, J. R., "Air
Flow Studies of Days of Heavy Smog in Los Angeles", Presented at the
49th Annual Meeting of the Air Pollution Control Association, Buffalo,
New York, May, 1956.
18. Kearin, D. H. and Lamoureaux, R. L., A Survey of Average Driving
Patterns in the Los Angeles Urban Area, System Development Corporation
Technical Memo (TM(L) - 4119/000/01), February 1969.
19. Kyan, C. P. and Seinfeld, J. H. , "Real Time Control of Air Pollution",
AICHE Journal, Vol. 19, #3, 1973.
20. Los Angeles City Department of Traffic, Transportation Planning
Division, Staff Report: LARTS Trip Type Distributions, Supplement
Report, July 6, 1973.
21. Los Angeles County Air Pollution Control District, Profile of Air
Pollution Control, 1971.
22. Neiburger, Morris and Edinger, James, "Meteorology of the Los Angeles
Basin, "Report No. 1 of the Air Pollution Foundation (Los Angeles:
Southern California Air Pollution Foundation, 1954).
23. Schuck, E. A., Pitts, J. N., and Wan, J. K. S., "Relationships Between
Certain Meteorological Factors and Photochemical Smog", International
Journal of Air and Water Pollution, Vol. 10, 1966.
24. Schuck, E. A., et. al., "Relationship of Hydrocarbons to Oxidants in
Ambient Atmospheres", Journal of the Air Pollution Control Association,
Vol. 20, May 1970.
25. Southern California Association of Governments. Employment Projections
for the SCAG Area, (unpublished) November 1972.
26. Thomas, George, Engineering Department of the Los Angeles County Air
Pollution Control District, Personal Communication, August 1973.
27. Trijonis, John, An Economic Air Pollution Control Model - Application:
Photochemical Smog in Los Angeles County in 1975, Ph.D. Thesis,
California Institute of Technology, Pasadena, California, May 1972.
28. TRW Transportation and Environmental Operations, Transportation Control
Strategy Development for the Metropolitan Los Angeles Region, EPA
Contract No. 68-02-0048, January, 1973.
29. TRW Transportation and Environmental Operations, Air Quality Implementation
Plan Development for Critical California Regions: Summary Report, EPA
Contract No. 68-02-0048, July, 1973.
66
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3.0 REVIEW AND EVALUATION OF EXISTING EMERGENCY EPISODE PLANS
The severity of the California air pollution situation, especially in
the Los Angeles region where it is most acute, has prompted the formulation
of several emergency action plans for use in case of episode alert condi-
tions. Plans have been developed at the local, state, and federal levels,
by the APCD's, ARE, and EPA. This chapter reviews each of these three
programs, presenting -both merits and shortcomings of the plans.
The Los Angeles County APCD alert program is the oldest, and probably
most familiar, plan which has been developed for the region. In Section 3.1,
it is reviewed as being representative of abatement plans proposed by several
county APCD's. The ARE plan, as of this writing, is in draft stages and has
not been officially adopted; it is based in large part, on a technical support
study conducted by the California Office of Emergency Services (OES). Both
the preliminary ARE plan and the OES Report are discussed in Section 3.2.
Recently, EPA-Region IX designated a task force to examine traffic abatement
strategies and to submit a report on recommended actions. This report is
reviewed in Section 3.3.
»
In addition to the EPA-Region IX Task Force on Traffic Abatement During
Air Pollution Episodes Report, an actual contingency plan has recently been
formulated by EPA-Region IX. This is described in Appendix B. Also presented
in Appendix B are an effectiveness evaluation of the EPA strategies and a
comparison of the EPA contingency plan to a plan recommended by this study.
67
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3.1 LOCAL AIR POLLUTION CONTROL DISTRICT EMERGENCY PLANS
3.1.1 Plan Description
Presently, four counties in the South Coast Air Basin, Los Angeles,
Riverside, San Bernardino, and Santa Barbara have adopted contingency plans
for air pollution episodes, [1]. These plans are not designed to prevent
Federal significant harm levels but are rather designed "to prevent the
excessive buildup of air contaminants and to avoid any possibility of a
catastrophe caused by toxic concentrations of air contaminants", [6].
However, in the view of the APCD's, the possibility of such a "catastrophe"
really occurring is "extremely remote", [6]. The other two counties, Orange
and Ventura, are awaiting the preparation of the statewide contingency plan,
developed by the Air Resources Board, before they adopt emergency procedures,
[1J.
The Los Angeles APCD plan was the first and is the most complete of the
four plans so far adopted. It has served as the model, for both the San
Bernardino and Santa Barbara episode programs. The Riverside plan contains
no control phases and is basically just a community warning procedure. Thus,
the following discussion of local control plans will concentrate on the L.A.
APCD plan.
As mentioned above, an episode control contingency plan consists of
four basic elements: episode criteria, control strategies, operational
procedures, and surveillance procedures. The following is a description of
the local APCD emergency plans in terms of these four elements.
Episode Criteria
The L.A. APCD emergency air pollution program divides an episode into
three degrees of severity called alert stages, [6]. Each alert stage is
68
-------
defined by threshold concentrations of various air pollutants. These
thresholds, given in Table 3.1 are indicative of the health threat to the
general public. For example, in a first stage alert, pollutant concentra-
tions have supposedly reached a level "close to the maximum allowable
concentration for the population at large, a point where preventive action
is required". A second stage alert indicates that air contamination has
reached levels which are beginning to pose a serious health threat. A third
stage alert means pollutants exist in concentrations which are a "dangerous
health menace", [6]. These three stages form the basis for a simple feed-
back control system; various actions are taken whenever pollutant concentra-
tions actually reach certain levels.
TABLE 3.1. LA COUNTY APCD ALERT STAGES FOR OXIDANT,
CARBON MONOXIDE, AND NITROGEN OXIDES*
Pollutant
Oxidant
Nitrogen Oxides
Carbon Monoxide
First Alert
(PPM)
0.5
3
50
Second Alert
(PPM)
1.0
5
100
Third Alert
(PPM)
1.5
10
150
*The sum of nitrogen dioxide and nitric oxide.
Control Strategies
At each phase of the alert, certain actions are taken in order to reduce
pollutant concentrations. These control measures, which constitute a "control
strategy" for each stage, are presented below in outline form, [6]:
69
-------
I. First Stage Alert
1. Prohibit refuse incineration.
2. Request via the news media for voluntary cessation
of all non-essential vehicle use.
II. Second Stage Alert
1. Continue actions outlined under first stage alert.
2. Notify industries emitting contaminants responsible for the
alert to institute (pre-planned) shutdown procedures.
3. Close additional industrial and commercial establishments
and/or stop vehicular travel if the Air Pollution Control
Board and Emergency Action Committee deem it necessary.
III. Third Stage Alert
1. Continue actions outlined under first- and second-stage
alerts.
2. Take actions as deemed necessary and appropriate by the
Governor of California.
IV. Alert Termination
1. Verify that contaminant concentrations have fallen below
first stage alert criteria.
2. Verify that available meteorological and scientific data
indicate that pollutant concentrations will not immediately
rise above first stage levels.
3. Terminate episode if the above is true.
Stage II (measures 2. and 3.) and Stage III (measure 2.) institute the
principal active (as opposed to voluntary) control measures in the APCD plan.
Stage II, measure 2., implements pre-planned shutdown procedures for certain
70
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stationary sources which emit the alert-causing contaminants. The types of
industries requiring shutdown plans in Los Angeles County are summarized in
Table 3.2, [6].
TABLE 3.2. TYPES OF STATIONARY SOURCES REQUIRING
SHUTDOWN PLANS - LOS ANGELES COUNTY APCD
SOURCE TYPE EMISSIONS
Petroleum Refinery
Asphalt saturators, asphalt paving
man. plants
Bulk loading facilities for tank vehicles
Chem. plants reacting or producing
organic liquids or gases
Paint laquer, or varnish man. plants
Rubber tire man. or rubber machinery
plants
Automobile assembly
Metal melting, refining or smelting
Rock wool manufacturing plants
Glass or frit manufacturing plants
Fossil fuel fired steam generating plants
Container man. or container decorating plants
Large dry cleaning
Large printing plants
RHC
X
X
X
X
X
X
X
X
X
X
CO
X
X
X
NO
X
X
X
X
X
X
X
References: [6], [7]
Table 3.3 compares total emission reductions from these plans to total
stationary source emissions, [10]. Noting that much of total stationary
71
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source emissions result from disperse commercial and residential sources,
which are not controlled in the plan, the stationary shutdown procedures
have a considerable effect.
Table 3.3 THE EFFECT OF LOS ANGELES COUNTY SHUTDOWN
PROCEDURES FOR STATIONARY SOURCES
RHC
Contaminant
CO NO
x
Total Emissions from all mobile and
Stationary Sources (Metropolitan Los Angeles
AQCR, 1973)
Percentage of Total Emissions Resulting
from Stationary Sources, (Not counting auto
tank filling)
Percentage of total emissions reduced, by APCD
Shutdown Plans, (assuming LA County plan is
applied to whole basin)
1-rntons
1250day
14%
4~%
~ Q nnn tons
9)000 day
1 1/2%
1%
1450 JSDi
day
23 \m
5%
The emergency vehicular control program is not as well organized as the
stationary source program. At Stage II, the 300 companies which require
stationary source shutdown procedures will also be asked to implement a pre-
planned transportation control program (basically car pooling), [6]. This
is of very limited effectiveness, especially since action is not taken for
oxidant alerts until the afternoon of that alert. Also in Stage II, a "work
holiday" could be declared (this suffers from the same limitation), [10].
In Stage III, at the request of the Governor, a ban on all non-emergency
traffic might be called. Enforcement would be monitored by the Sheriff's
office and other police departments.
As to location, strategies are implemented strictly on a county by
county basis. That is, control action is taken in a given county when
pollutant levels in that.county reach an alert stage. There is presently
no mechanism for regional cooperation in episode control procedures. As
72
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mentioned previously, the strategies for San Bernardino and Santa Barbara
counties are essentially the same as for Los Angeles County.
Surveillance Procedures
The discussion of general contingency plans, (Section 2.1), described
three general surveillance requirements: air quality monitoring, source
surveillance, and overviewing other agencies. The surveillance procedures
of the APCD plan fall into two of these categories: air quality and source.
Each APCD is not concerned with the responses of other sub-agencies, since
there are none under it with air quality responsibilities.
The L.A. APCD monitors air quality through a permanent network of
continuous atomospheric sampling stations. Routinely, these stations
continually provide quite detailed data on air quality and meteorology.
No special monitoring techniques are automatically instituted in the event
that an episode occurs, [9], However, the APCD does possess the capability
to establish temporary stations, using mobile equipment, if it is deemed
necessary, [8].
Routine source surveillance is also conducted by the L.A. APCD. This
is the responsibility of the enforcement division. This division includes
uniformed enforcement officers in patrol cars as well as plain clothes
inspection engineers, [9]. During an alert, the APCD enforcement group
is put on special duty, and sheriff's officers as well as other police
can be called on for assistance.
Operational Procedures
The APCD emergency episode plan, as described in the LA County APCD
Rules and Regulations, contains fairly explicit operational procedures,
[6]. Figure 3.1 has been constructed to summarize the basic organizational
73
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HIGHWAY
PATROL
EMERGENCY ACTION
COMMITTEE
REQUEST
RECOMMENDATIONS
(phone)
A
ENFORCEMENT ASSISTANCE
f
(phone)
COUNTY
SHERIFF
(teletype,
V
radio)
LOCAL
POLICE
ANNOUNCE
(phone
W
*
*
ALERT
PUBLIC
MEDIA
SHERIFF
SUBSTATIONS
* *
GOVERNOR
QF
CALIF,
REQUEST STATE
OF EMERGENCY
(phone)
* * *
APCU
VOLUNTARY
ABATEMENT
CONTROL BURNING (media)
* * SHUTDOWNS
(private radio)
* #
POSSIBLE
DIRECT
MEASURES
W (unspeci fi ed)
MOTOR
VEHICLES
^ '
STATIONARY
SOURCES
* FIRST STAGE ALERT
** SECOND STAGE ALERT
* * * THIRD STAGE ALERT
Figure 3.1 County APCD Emergency Episode Operations
-------
structure and the communication channels. The phasing of operational
procedures is outlined below.
I. Preparation
1. Request shutdown plans from business, industrial and
commercial establishments emitting toxic contaminants.
2. Develop shutdown plans and vehicle abatement plans into
a coordinated control program.
3. Appoint a Scientific Committee to serve as a consulting
body to the APCD.
4. Appoint an Emergency Action Committee to advise the
Air Pollution control officer during an episode.
II. First Stage Alert
1. Notify sheriff and other law enforcement officers.
2. Notify stationary source of possible shutdown if
second stage alert is reached.
3. Notify public via media of alert to request cooperation.
4. If second stage alert appears eminent, notify Emergency
Action Committee and media.
III. Second Stage Alert
1. Notify appropriate stationary sources.
2. Supply necessary information to Emergency Action
Committee and receive recommendations.
3. Notify media.
4. Notify sheriff and other law enforcement officers of
necessary enforcement steps.
75
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IV. Third Stage Alert
1. Notify Governor of California to receive his recommendations
2. Notify media.
V. Termination
1. Notify sheriff.
2. Notify public via media.
3.1.2 Evaluation: Preventing Significant Harm Levels
The APCD emergency episode plan will not prevent oxidants, carbon
monoxide, and nitrogen dioxide from reaching federal "significant harm"
levels during an air pollution episode. The reason for this is simple.
The plan was not designed with the federal significant harm levels in mind.
Rather, it was constructed to avoid what local officials term an air
pollution "catastrophe" or "disaster". These levels differ considerably
from the significant harm levels established by the EPA.
Table 3.4 compares the APCD alert levels to the federal significant
harm levels. It can be seen that the APCD concentration specifications
are of a different type than federal specifications. The APCD criteria
are given in terms of instantaneous concentrations while the EPA's are
measured in terms of one to twenty-four hour averages. Also, the nitrogen
oxide levels are specified differently. The EPA uses NOp while the APCD
uses NO . In order to make the specifications more comparable, the APCD
A
levels have been adjusted to reflect a two-thirds conversion rate from
total NO to N09.
X c.
76
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TABLE 3.4. COMPARISON OF L. A.COUNTY APCD
ALERT LEVELS TO THE FEDERAL SIGNIFICANT HARM LEVELS
. Pollutant
Oxidant
Carbon
Monoxide
Nitrogen
Dioxide
LEVELS
Federal
Significant Harm
Level
.70 PPM 1 hour average
.60 PPM 2 hour average
.40 PPM 4 hour average
125 PPM 1 hour average
75 PPM 4 hour average
50 PPM 8 hour average
2.0 PPM 1 hour average
.50 PPM 24 hour average
APCD ALERT LEVELS
(PPM)*
Stage 1
0.5
50
**
2.0
Stage 2
1.0
100
**
3.3
Stage 3
1.5
150
**
6.6
* APCD Alert Levels are for instantaneous values.
** APCD criteria are for total nitrogen oxides-. It is assumed here
that maximal nitrogen dioxide levels are two-thirds of maximal
total nitrogen oxide levels. This assumption is supported by
air monitoring data in the Los Angeles region.
Examining Table 3.4 and noting that the first mandatory control stage
of the APCD plan is the second stage., (the first prohibits burning and calls
for voluntary traffic abatement), it becomes obvious that in most cases, the
APCD plan cannot prevent pollutants from reaching significant harm levels.
It is almost certain that if the oxidant concentration exceeds an instanta-
neous level of 1.0 PPM (the APCD second stage alert level) that it will have
already exceeded the .7 PPM-one hour, .6 PPM-two hour, or .4 PPM-four hour
significant harm levels. The same is true for carbon monoxide; the four
hour 75 PPM or the eight hour 50 PPM level will likely be exceeded by the
77
-------
time a second stage alert is declared. In fact, the only significant harm
level adequately covered by the second stage alert criteria appears to be
the 125 PPM CO concentration for one hour. This does not necessarily mean
the APCD plan is a poor plan; it is just a reflection of the fact that the
APCD plan was not designed to prevent federal significant harm levels.
However, it is doubtful that the APCD plan could be made much more effective
in preventing air pollutants from reaching significant harm levels by simply
lowering the criteria levels. The APCD plan is based on feedback criteria
rather than a forecasting system. As noted in Chapter 2, feedforward
(predictive) initiation criteria are essential for oxidant episodes;
reducing emissions after the concentration of oxidants has reached a
given level does not have significant effect on the continued short-term
accumulation of oxidant. Further, most transportation control measures
require a certain amount of time to implement; this again requires predictive
initiation criteria.
The APCD plan also has room for improvement since control measures are
presently well defined and operational only for certain stationary sources.
As noted in Table 3.3, preplanned shutdown procedures are available for
stationary sources which account for 4% of total RHC, 1% of total CO and
5% of total NO However, 78% of RHC, 99% of CO and 76% of NO are emitted
A
from transportation related sources, (including auto tank filling). Presently,
emergency control procedures for mobile sources are not as well organized
operationally as those for stationary sources. The mobile source control
procedure should improve however, due to present ARB-APCD work on contingency
plan development.
The APCD does have certain capabilities which would be very useful in
any contingency plan. For instance, it has an extensive, continuous air
78
-------
monitoring system for atmospheric surveillance. Also, the APCD maintains
an enforcement division, with a staff of approximately 100 officers, to
monitor source activity, [9]. Further, the APCD has an established, well
organized communications system along with a well defined set of operational
procedures for stationary source control. These capabilities are very
valuable assets for contingency plan action.
3.2 AIR RESOURCES BOARD - AIR POLLUTION EMERGENCY CONTINGENCY PLAN
3.2.1 Plan Description
The purpose of the ARB's emergency contingency plan is "to provide the
basis for taking action to prevent or abate air pollutant concentrations
from reaching levels which could endanger the public health", [2], Under
the plan, local air pollution control districts would have the primary
responsibility for taking the necessary steps to curtail polluting activities,
However, if the episode is so severe that it is beyond the local districts'
capability to control, then it becomes the responsibility of the state to
alleviate the conditions.
The Air Resources Board plan is based in part on a study conducted by
the California Office of Emergency Services, [3]. At present, the plan is
still in preliminary draft and as yet has not been adopted. The discussion
below is based on Preliminary Draft No. 2, dated July 23, 1973, [2].
Episode Criteria
The ARB emergency contingency plan breaks up an air pollution episode
into four stages of severity. As in the LACAPCD plan, these stages are
defined by threshold concentrations being reached (with expectancy of
persisting or increasing). Thus, the episode initiation criteria are
basically feedback criteria with only slight forecasting involved.
79
-------
Of the three pollutants to be considered in this report, only two,
oxidant and carbon monoxide, are considered in the ARE plan. N02 is omitted
The alert concentrations for oxidant and CO as well as the corresponding
"stages" are given in Table 3.5, [2].
TABLE 3.5
ARB CONTINGENCY PLAN EPISODE CRITERIA LEVELS
POLLUTANT
Photochemical
Oxidant
Carbon Monoxide
AVERAGING
TIME
1 Hour
1 Hour
12 Hours
HEALTH
ADVISORY
.20 PPM
40 PPM
20^PPM
ABATEMENT
STAGE 1
(ALERT)
.25 PPMa
50 PPMa
25 PPM
ABATEMENT
STAGE 2
(WARNING)
.40 PPMa
75 PPMa
35 PPM
ABATEMENT
STAGE 3
(EMERGENCY)
.60 PPMb
100 PPMb
50 PPM
Reached and expected to approach the next stage unless abatement action
taken.
'Reached and expected to persist for 1 additional hour unless abatement
action taken.
General descriptions of the episode stages are outlined below:
1. Health Advisory - Pollutant concentrations have reached or are
predicted to reach a level at which persons with respiratory or
coronary diseases should take precaution against exposure.
2. Alert - An alert is called when the concentration of pollutants
specified for this stage is reached and when it has been predicted
that air pollutant concentrations may reach the next stage.
80
-------
3. Warning - A warning is called when the concentration of pollutants
specified for this stage is reached and when it has been predicted
that air pollution concentrations may reach the next stage.
4. Emergency - An emergency is called when the conditions specified
for this stage are reached, (and in certain instances are expected
to persist for one hour).
A stage is assumed to be terminated whenever the concentration of
pollutants which caused the declaration of the episode has been
verified to have fallen below the threshold level for that stage
and pollutant concentrations are expected to continue down.
Control_ Strategies
The control strategies of the ARB contingency plan consist only of a
general outline of what types of control measures are to be taken at each
stage of the episode. It is left up to the local APCD's to come up with
actual control measures. The control strategies can be summarized as
follows:
I. Health Advisory (No real control action)
1. Notify persons with respiratory disease or coronary
ailments to take precautions.
II. Alert (Stage 1 - Voluntary Control)
1. Continue actions for first stage.
2. Initiate voluntary traffic and source abatement procedures.
III. Warning (Stage 2 - Mandatory Controls)
1. Continue actions of first and second stages.
81
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2. Initiate curtailment actions for stationary sources in
accordance with pre-established plans.
3. Initiate mandatory traffic abatement.
IV. Emergency (Stage 3 - Further Mandatory Controls)
1. Continue actions outlined under first, second and third
stages.
2. If necessary, close or shut down all industry and business.
3. If necessary, take action under provisions of Peace Time
Emergency Plan of the Emergency Services Act.
V. Termination
1. Terminate control action as stages are terminated.
In addition to outlining what actions should be taken at each stage of
the episode, the ARB strategy further details what king of controls it
expects the local APCD's to develop. These can be divided into two groups;
stationary source curtailment controls and traffic abatement plans.
Stationary source controls are to provide for the immediate reduction of
industrial, business, or commercial activities which emit 100 tons/year
or more of pollutants. They must include source identification, location,
and emission estimates along with designation of whom to contact, shutdown
procedures, and shutdown time estimates. Traffic abatement plans are to
include specific actions to be taken at both the first and second stages.
They are to be directed at reducing the reasons for vehicular traffic rather
than direct traffic control. Examples of traffic abatement measures are
given in the ARB plan and are presented in Table 3.6.
82
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TABLE 3.6.
ARB CONTINGENCY PLAN - EXAMPLE TRAFFIC ABATEMENT MEASURES
STRATEGY
EPISODE STAGE
Voluntary Reduction in Traffic
1. Alert
Ban Government Vehicles
Close Admission to Public Recreation
Facilities
Close Government Offices*
Ban Fleet Vehicles - Excluding Gaseous
Fueled Vehicles
Close Admission to Private Recreation
Facilities
Close Admission to Regional Shopping
Centers
Close Schools and Colleges
Close Admission to "Downtown" Retail and
Service Business
Ban Delivery Service of all Non-Perishables
Ban Non-Essential Service Calls
Close Establishments with 100 or more
Employees*
2. Warning
Close Admission to All Other Retail and
Service Establishments
Close Industrial Sources
3. Emergency
Reference: [2]
Additional activities taken when prediction is available.
83
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Surveillance Procedures
In the area of surveillance procedures, the ARB provides only a minimum
amount of detail. It does indicate, however, that each local APCD should
maintain at least one air monitoring station within its jurisdiction. It
also states that ARB will monitor and provide all necessary meteorological
information. This lack of detail may be due to the preliminary nature of
the plan.
Operational Procedures
The state ARB plan provides for the organizational structure as
diagrammed in Figure 3.2. Again, the essential elements are the local
APCD's. Each APCD is the responsibility of an air pollution control officer
who may or may not be advised by an Emergency Action Committee. Coordina-
tion among the various APCD's is achieved through an Air Basin Coordinating
Council. Finally, all of this is overseen by the ARB and OES. They advise
the Governor and recommend what actions he should take, if any, under the
Emergency Services Act.
The ARB plan has outlined the following operational procedures in the
event of an episode.
I. Health Advisory
1. Notify all affected APCD's.
2. Notify all monitoring stations.
II. Alert
1. Activate ARB emergency action staff.
2. Notify all necessary personnel.
3. Monitor actions of local APCD.
84
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CO
01
OTHER LOCAL
APCD S
OES
MARE RECOMMENDATIONS
S EVALUATIONS
* *
NOTIFY
w
INFORM OF CURRENT STATUS
REOJJEST COOPERATION
EMERGENCY ACTIOi'J
COMMITTEE
OF EPISODE
GOVERNOR
OF
CALIF.
ARB
Recomrnendat ions
ENFORCEMENT ASSISTANCE
ANNOUNCE
ENFORCEMENT
AGENCIES
ALERT
PUBLIC
MEDIA
REQUESTS STATE
op EMERGENCY
*
* *
* * #
NOTIFY BOARD
OF EPISODE STATE
AP CiJ
VOLUNTARY
ABATEMENT
CURTAIL SOURCES
CONTROL OPEN BURNING
POSSIBLE DIRECT
MEASURES
(UNSPECIFIED)
MOTOR
VEHICLES
STATIONARY
SOURCES
« ADVISORY
#* ABATEMENT STAGES 1 AND 1 (ALERT ii WARNING)
* * * ABATEMENT STAGE 3 (EMERGENCY)
FIGURE 3.2. ARB EMERGENCY EPISODE OPERATIONS ORGANIZATION
-------
III. Warning - same as Alert
IV. Emergency
1. Notify Governor.
2. Same as above.
More detailed procedures are not well defined as yet, probably because
of the preliminary nature of the plan and because the burden of responsi-
bility is placed on the local APCD's.
OES Traffic Abatement Plan
Preliminary to the ARB formulating an episode contingency plan, a study
was conducted by the Air Pollution Emergency Traffic Control Planning
Committee of the California Office of Emergency Services, (OES), [3]. The
purpose of this study was to consider all possible traffic abatement
measures, to determine the possible effect of each upon the air pollution
problem, to organize the most promising measures into a traffic abatement
plan, and to make recommendations regarding implementation of such a plan.
The OES report served as part of the technical basis for the ARB plan, and
it will be reviewed briefly below.
The major portion of the OES study was devoted to an evaluation of the
cost and effectiveness as well as the enforcement and implementation prob-
lems associated with various traffic abatement measures. This evaluation,
summarized in Table 3.7, resulted in the following conclusions:
1. Prediction of air pollution episodes is essential to instituting
effective traffic abatement measures.
2. The most effective approach to traffic abatement is to eliminate
the incentive for travel. Significant enforcement problems would
be associated with any direct traffic controls.
86
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TABLE 3.7 OES EVALUATION OF TRAFFIC ABATEMENT MEASURES
co
STRATEGY
Work Holiday
Simple San on
Facilities 6.
Reta 1 1 Stores
Licence Plate
Lottery
Close Large
Business
Cormisrcial
Abatement
Plans
Windshield
Stickers
Offices (S.
Contractors)
Vehicles
Gas Rationing
Voluntary
Abatement
Mandatory Car
Pool Ing
Parking Tax
L\-'\t PtrHr
Close Gas
Close Soma Freeway
(Casol In*
Powered)
ENFORCEMENT
PROBLEMS
High
High
Some
High
High
Gov't
Contr.
Maybe
High
High
"1 • '
Public
Put sta.
high
High
ADMINISTRATION
COSTS
"
Low
"
High
High
High
Low
SAFETY
HAZARDS
"-
"
Storage
--
High gas
Low
"",""
3:
E
i- cy
Prod.
Prod.
Prod.
Pred,
Pred.
Pred.
Pred.
Pred.
Preferred
Pred.
Pred. pre
ferred
.ferred
ferred
PROBLEMS OF
INSTRUCTION
High
High bee.
of di f f.
opt ions
-TT7 /
-i
a-
o o
^ 0
< z
!
- -
o
z
z
o
< -1
< 3
Q- Q-
"
—
Some
Sorie
"5rr
OVERALL PUBLIC'S
^^ACCEPTABILITY
Med. to
High
Some
Some
Some
Some
High -e.<:
Present
EPA Hear-
ing
Hiqh
Mi " h
HInh
Mi gh
X
o
Q I—
- 31
S O
guaranteed
pay for
guaranteed
wages
Restrict
store -
put bus.
fami 1 les
Yes If no
guaranteed
wage ~lrg.
Against
large bus.
- guar.woge
Some
Wage
System of
A) lotment
wage
Or,; car
fami ly -
Gas. sla.
operator
Sonic
ADVERSE IMPACT
ON NON-MOTORISTS
High
Yes
o
^ s:
0 (—
L st Ess-
ential
services
List of
Exempt
Stores
Months
List of
Exempt
Year
List of
El igible
for rtg,
Exemp t
Year
•T-, •
Months
Month
.in.
-J <
< i—
-1 O
Pay - Hln.
Fine-No
Susp.
V F-
riages
Cuar.pay
no Susp.
- Mln, f inc
Guar.pay
•1 i n . F 1 ne
-Guar.wage
-Mln. fine
susp.
-Wo auth.
close
Agreement
with Fed.
-RT7T
T
""
LAWS
REQUIRED
Obi Iga-
tlon
lin. fin
W/out *u
, ,
MAX. POTENTIAL
V.H.T. REDUCTION
70*
6*
Var.
si -
85*
Var.
5* -
201
Var,
» -
70Z
Var. 85S
Max,
5* -
51 -
20*
m
Var.
60t
,55* >t.
p[home
5M
~7
Var.
5J LA
103; SF
n«,.
5'.
o
< 0
< K
70»
M
2J -
tot
5* -
20»
50> »t
MaK.
51 - o — o
M - 1 E <-
2o» ; "
s s
0 —
1/2*
5» - 10*
,. Pool -
151 >t.y
TW
• "hW "o"r
Scg.
10% SF
-------
3. When implemented, any traffic abatement
over a relatively broad traffic influence area, rather than upon a
smaller area from which pollutants are being emitted.
4. A traffic abatement plan should be progressive in nature both in
its anticipated benefits on pollutant levels and its anticipated
impact on the community. It should be implemented in stages as
necessary.
5. Local levels of government should initiate the first stages of
control. Only the most severe stage, involving declaration of an
emergency, would be instituted at the State level.
The OES report proposed a traffic abatement plan that is very
similar, in several respects, to the ARB plan, (particularly the
"example" traffic control strategy of Table 3.6). First, the OES
report, as the ARB plan, divides the episode strategies into four
levels of severity. Second, it used the same threshold criteria as the
ARB plan. Finally, the control actions to be initiated at each level
fit into the same kind of control philosophy as expressed by the ARB
(e.g., eliminate incentives to travel), with voluntary abatement at the
lowest level and progressing through increasingly disruptive measures
until at the highest level of severity, a complete work holiday is
declared.
3.2.2 Evaluation: Preventing Significant Harm Levels
A full evaluation of the ARB contingency plan, as to its potential for
preventing federal significant harm levels, is difficult since the plan still
is under preparation and parts of it have not yet been defined. Many details
in the ARB contingency plan have been left up to the local APCD's. After the
ARB and APCD's complete the plan, a more thorough evaluation will be possible,
88
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However, on the basis of the episode criteria, (compared to federal
significant harm levels in Table 3.8), it seems very unlikely that the ARB
contingency plan will prevent federal harm levels. First, there are no
episode criteria for N02. Second, although episode criteria exist for
oxidant and carbon monoxide which call for active control before federal
harm levels are exceeded* (this is ARB Stage 2; ARB Stage 1 has only volun-
tary control), these criteria are basically of the feedback variety. As
noted in the OES support-document for the ARB plan ancL.in Section 2.4 of
this report, forecast (feedforward) episode criteria are necessary to
effectively abate traffic. Furthermore, even if traffic could be reduced
on an instant's notice, a forecasting system would still be needed for
oxidant pollution. Because of the chemical-physical nature of photochemical
smog, once oxidant has started to increase, it can continue to increase even
if all emission sources are subsequently shut down.
Another area-where the current ARB draft plan could be improved is in
the provision of regional cooperation during alert conditions. Currently,
it appears this control is left up to the APCD's to initiate. As discussed
elsewhere, this neglects the regional character of the problem. For example,
it is doubtful that even drastic actions taken by Riverside County or
* The first active (as opposed to voluntary) control phase, Stage 2, is
called when the one hour oxidant average exceeds .40 PPM. This is below
the .40 PPM four hour, .60 PPM two hour, and .70 PPM one hour averages
specified as significant harm levels by the EPA. Stage 2 is called when
one hour average CO reaches 75 PPM or 12 hour average CO reaches 35 PPM.
These criteria are below the 125 PPM one hour average, 75 PPM four hour
average, and 50 PPM eight hour average CO harm level.
It should be noted that the second active control phase, Stage 3, is
below the one and two hour oxidant harm levels and the one hour CO harm
levels. However, Stage 3 is not activated in time to protect against the
.40 PPM 4 hour oxidant harm level nor the 75 PPM-4 hour and 50 PPM-8 hour
CO harm levels.
89
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TABLE 3.8
COMPARISON OF THE ARB CONTINGENCY PLAN
ALERT LEVELS TO THE FEDERAL SIGNIFICANT HARM LEVELS
POLLUTANT
Oxidant
Carbon
Monoxide
Nitrogen
Dioxide
FEDERAL SIGNIFICANT
HARM LEVELS - PPM
(Avg.
Time)
.70 - 1 Hour
.60-2 Hours
.40 - 4 Hours
125 - 1 Hour
75-4 Hours
50-8 Hours
2.0 - 1 Hour
.50 -24 Hours
ARB EPISODE CRITERIA (PPM)
HEALTH
(ADVISORY
.20/1 Hr.
Avg.
40/1 Hr.
Avg.
20/12 Hr.
Avg.
(1)
ALERT
Voluntary
Controls
.25a/l Hr.
Avg.
50a/1 Hr.
Avg.
25/12 Hr
Avg.
(2)
WARNING
Mandatory
Controls
.40a/l Hr.
Avg.
75a/l Hr.
Avg.
35/12 Hr.
Avg.
(3)
EMERGENCY
Mandatory
Controls
.60b/l Hr.
Avg.
100b/l Hr.
Avg.
50/12 Hr.
Avg.
None
aReached and expected to approach the next stage unless abatement action
taken.
Reached and expected to persist for 1 additional hour unless abatement
action taken.
San Bernardino County alone could prevent acute episode conditions which
originated from Los Angeles and/or Orange Counties. It is critical for
adequate episode control that a concerted and coordinated abatement plan be
instituted in all the counties either significantly contributing to the
emissions or. actually experiencing the alert conditions.
The ARB proposal presents only a general outline of the control
measures to be taken at each alert stage. In order to be complete, this
outline needs specific control measures to be chosen by the APCD's. However,
90
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the general control outline itself is well organized. A health advisory at
the first episode level is followed by voluntary abatement at the alert
level, mandatory control at the warning level, and drastic mandatory controls
at the emergency level. Controls for both stationary and mobile sources are
included. The recommended mobile source controls (Table 3.6) basically
involve eliminating incentives for travel. This is consistent with the OES
study which concluded that shutting off reasons for traveling would be the
most effective and enforceable type of traffic abatement strategy.
The OES study is not really a complete contingency plan and will not
be evaluated here as such. It is actually more of an analysis of various
alternative traffic abatement strategies. The OES analysis is a comprehen-
sive and useful study and has served as the basic technical support for the
ARB plan.
The OES evaluation of traffic controls includes consideration of factors
such as potential VMT reduction, preparation time requirements, implementa-
tion problems, socio-political effects, fairness, legal requirements and
problems, enforcement difficulties, safety hazards, and administration costs.
As noted above, this analysis was quite comprehensive. Only three slight
deficiencies are apparent. First, more detail might have been given on the
enforcement and implementation procedures to be attached to the traffic
abatement measures. Measures were evaluated as to implementation and enforce-
ment problems, but little description was presented on actual procedures.
Second, total economic costs associated with various control measures, (e.g.
the cost of shutting industrial or commercial establishments), were not
included as a point of evaluation. In many cases, this cost is order of
magnitudes greater than administrative costs (which were included). Third,
the sample calculations of VMT reduction in the OES report were slightly
91
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optimistic. This was partially the result of not allowing for "substitute
driving" when certain types of trips were foregone, (e.g. a 10% reduction
in commuter trips will really be partially cancelled by an increase in
recreational and shopping trips, this was not allowed for in the OES report).
Including these effects would lower certain OES VMT reduction estimates by
around 20%.* (e.g. instead of obtaining a 10% VMT reduction, the actual
reduction would only be around 8%).
The results of the present study basically agree with the first four
conclusions of the OES report (listed on page 86). However, the fifth con-
clusion, that local levels of government should initiate all but the last
(most severe) control stage seems to contradict the need for a regional
approach to oxidant control. As noted in the evaluation of the ARB plan,
controls initiated only by an individual county often will not be sufficient
to abate oxidant episodes in that county.
4
3.3 EPA REGION IX TRAFFIC ABATEMENT STRATEGIES
3.3.1 Plan Description
The Preliminary Report of the EPA Region IX Task Force on "Traffic
Abatement During Air Pollution Episodes" does not present per se an episode
contingency plan, [4]. Rather, it is more a discussion of the actions and
procedures necessary to put a contingency plan together. For example, while
there is a detailed description of possible alert criteria and procedures
for establishing such criteria, no actual episode criteria are presented.
The same is true for enforcement and communication. Thus, it is very
* In defense of the OES report, it should be noted that the OES study was
more interested in "order of magnitude effects". Twenty percent is not
a large correction, considering the error in estimates of VMT reduction.
,92
-------
difficult to analyze the report in the context of an actual air pollution
episode contingency plan. However, the report does present a detailed des-
cription and evaluation of proposed traffic abatement measures, and, based
on this, makes recommendations as to which abatement measures to use in a
contingency plan. This review of the Region IX Traffic Abatement Report
will concentrate on the analysis of proposed vehicle abatement measures.
The EPA Task Force has divided the evaluation of traffic abatement
measures into five categories. These are: effectiveness, enforceability,
cost, socio-political impact and time needed to implement. In all, fourteen
different measures were evaluated using the above criteria. The results of
the evaluation are summarized in Table 3.9. On the basis of this evalua-
tion, the Task Force arrived at the following recommendations:
1. Individual measures that can be implemented almost immediately
(in order of decreasing recommendation)
a. Mandatory car pooling on freeways.
b. Request closure of government agencies and contractors.
c. Limit availability of parking.
d. Special parking tax.
e. Close gas stations.
f. License plate lottery.
g. Ban all non-emergency vehicles.
h. Request voluntary abatement.
2. Individual measures which can be implemented by Spring 1973
(in order of decreasing preference)
a. Mandatory car pooling on freeways.
b. Limit availability of parking.
c. Request closure of government agencies and contractors.
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TABLE 3.9 SUMMARY OF EPA - REGION IX EVALUATIONS
OF ALTERNATIVE TRAFFIC ABATEMENT MEASURES
CONTROL MEASURE
DIRECT CONTROLS ON TRAFFIC
(1) Close major thoroughfares to
vehicles carrying less than
2 passengers
(2) Restrict road use according
to number of passengers in
vehicle
(3) Windshield sticker program
(4) License plate lottery
(5) Ban all non-emergency traffic
(6) Voluntary carpooling &
,work holidays
(7) Voluntary traffic reduction
INDIRECT CONTROLS ON TRAFFIC
(1) Limit availability of parking
(2) Close all public on and off
street parking
(3) Emissions abatement plans
(4) Close gas stations
(5) Special parking tax
HIGHLY INDIRECT CONTROLS ON TRAFFIC
(1) Closure of government agencies
to contractors
(2) Work holiday
EFFECTIVENESS
Good
Good
Good
Good
Good
Poor
Poor
Poor
Fair
Fair
Fair- Poor
Fair-Poor
Fair- Good
Good
ENFORCEABILITY
Good if Fines
are Sufficient
Good if Fines
are Sufficient
Dependent on
Amount of Fine
Dependent on
. Fine
Dependent on
Fine
Good
Good
Poor
Dependent on
Fine
Fair
Good
Good
Good
Good
COST
Minimal
Minimal
High
Minimal
High
High
Moderate
Minimal
Minimal
High
Moderate
to High
Minimal
Moderate
High
SOCIO-POLITICAL
IMPACT
Minimal
Minimal
Fair
Fair to Good
Poor
Good
Good
Poor
Poor
Good
Poor
Fair
Fair
Poor- Fair
TIME (NEEDED)
TO IMPLEMENT
Minimal
(few days)
Minimal
At Least a Year
Minimal
Minimal
Considerable
Minimal
Minimal
Minimal
Considerable
—
Minimal
Minimal
Minimal
VD
-------
d. Windshield sticker program.
e. Abatement plans for indirect emissions.
f. Close gas stations.
g. Special parking tax.
h. License plate lottery.
i. Ban on non-emergency vehicles.
j. Voluntary abatement only.
3. Combination of measures that can be used simultaneously
(in order of decreasing preference)
a. Mandatory car pooling on freeways and limit availability of
parking.
b. Work holiday and close gas stations.
c. Request closure of government agencies and contractors, special
parking tax, and limit availability of parking.
d. Request closure of government agencies and contractors and
close gas stations.
e. Mandatory car pooling on freeways, request closure of government
agencies and contractors, and limit availability of parking.
f. Mandatory car pooling on freeways, special parking tax, and
limit availability of parking.
g. Mandatory car pooling on freeways only.
3.3.2 Evaluation: Alternative Traffic Abatement Measures
Since the Preliminary Report of the EPA Region IX Task Force on Traffic
Abatement does not consist of an actual air pollution episode contingency
plan, this evaluation of the report will center on the task force's analysis
of alternative traffic abatement measures. In general, the analysis is both
fair and well organized. All principle measures which have been proposed up
95
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to now are thoroughly reviewed, with particular attention being paid to the
implementation and enforcement requirements of each. Also the criteria upon
which the task force judged each measure are well defined and meaningful.
However, there are several areas in which the report could be expanded.
These are discussed below.
Perhaps the major shortcoming to the task force's evaluation is that it
fails to quantify (even approximately) VMT reductions for most control measures
For example, in analyzing the effectiveness of mandatory car pooling, it
states that "a very significant reduction in the amount of traffic is bound
to result." On the other hand, it classifies the effectiveness of limited
parking availability as "doubtful." While these observations may be appropri-
ate, there is no indication as to how they were obtained. This, and the
general absence of quantified estimates make comparisons with other studies
difficult.
Another possible point of criticism is that the report seems to over
estimate the socio-political acceptability of using heavy fines as a whip
to force public cooperation with proposed abatement measures. It is usually
true that the stiffer the fine, the more effective the regulation will be.
However, an enforcement policy based on extremely heavy penalties may be very
unpopular. A case in point is the following statement on the enforceability
of mandatory car pooling, a measure which the report highly recommends:
"If a substantial number of vehicle operators violate these
driving restrictions, it will of course be impossible to
apprehend all of them. However, if 'enough' are apprehended
and end up paying heavy fines ($100+), there is bound
to be a significant deterrent effect in the future."
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Finally, the task-force report does not always include all of the
economic consequences of many of the proposed abatement measures, both in
terms of direct and indirect costs. For example, the report concludes that
the direct costs to implement mandatory car pooling on freeways is "almost
nil if sufficient cooperation is obtained from state and local law enforce-
ment officials." This may be true for the EPA, but it is certainly not the
case for state and local agencies which may already be hard put to meet the
demands placed on them by routine assignments. Another instance is its
assessment of the costs involved in closing governmental agencies:
"(a) Direct: There will be no direct cost for this strategy
other than the differential pay for essential employees.
"(b) Indirect: Some public services will be put off temporarily,
but flexibility in deadlines can be added to mitigate this
cost."
It is not mentioned that someone, either the public employees or the
tax payer, must bear the burden of wages and/or product foregone on those
days when a holiday is declared. This cost can be very large. There is
also the cost of increased flexibility, additional staff hours, etc.
97
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REFERENCES - CHAPTER THREE
1. California Air Resources Board, The State of California Implementation
Plan for Achieving and Maintaining the National Ambient Air Quality
Standards, 30 January 1972.
2. California Air Resources Board, Proposed Air Pollution Contingency Plan,
Preliminary Draft #2, 23 July 19717'
3. California State Office of Emergency Services, Air Pollution Emergency
Traffic Control Planning Committee, Traffic Abatement Plan for Air
Pollution Episodes, 1973.
4. Environmental Protection Agency, Region IX, Preliminary Report of the
EPA Region IX Task Force on Traffic Abatement During Air Episodes,
15 September 1972.
5. Foon, Julian, Data Processing - Los Angeles County Air Pollution Control
District, Personal Communication, August 1973.
6. Los Angeles County Air Pollution Control District, Rules and Regulations,
Part VII, Rules 150 - 164.
7. Los Angeles County Air Pollution Control District, Profile of Air
Pollution Control, 1971.
8. Los Angeles County Air Pollution Control District, Smog Alerts - School
and Health Smog Warnings, Special Services Division Publication #2,
May 1972.
9. Los Angeles County Air Pollution Control District, The APCD Enforcement
Program, Special Services Division Publication #3, May 1972.~
10. Los Angeles County Air Pollution Control District, Personal Communica-
tion with Engineering Division, August 1973.
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4.0 ALTERNATIVE CONTINGENCY PLAN ELEMENTS
Episode contingency plans contain four general elements: episode
criteria, control strategies, surveillance procedures, and operational
procedures. In formulating an actual contingency plan for a specific air
basin, certain alternatives will exist for each component. This section
discusses the principal alternatives for a South Coast Basin plan.
4.1 EPISODE CRITERIA
4.1.1 Number of Episode Stages
A contingency plan must contain a set of episode criteria which cause
various parts of the plan to be put into action. These criteria should be
organized into stages of severity, more stringent controls being associated
with more advanced stages. For a particular plan, the actual number of
stages should be chosen by balancing two opposing factors: adding more
stages increases flexibility; however, it decreases simplicity and may
make the plan more cumbersome to operate.
EPA requirements, [CFT 420.16(6)], specify that contingency plans
must have at least two stages. To choose only two stages in a plan seems
inflexible. This is particularly true for Los Angeles. It will be shown
later that a nearly complete shutdown of activities is required in the most
advanced stage if pollutant concentrations in excess of significant harm
levels are to be prevented. Five or more stages seem to violate the con-
straint of operational simplicity. Thus, three or four appears to be the
appropriate number of stages for a Los Angeles episode plan.
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In the plan recommended by this study (Chapter 6), the first stage will
essentially be voluntary control (no emission reduction assumed), while the
last stage will involve a shutdown of recreational facilities and all non-
critical business. To provide a more gradual transition between these
extremes, two (rather than one) intermediate stages will be included. Thus,
the proposed plan will contain four episode stages.
4.1.2 Feedback vs. Forecasting Criteria
Section 2.1.1 noted that episode criteria can be of two varieties,
feedback and forecasting. Feedback criteria are based on pollutants a.:tually
having reached certain levels. Forecasting criteria are based on prediction
that pollutants will reach emergency levels. Within the latter category, a
further distinction can be made. Some forecasts, (usually longer term ones,
say 1 to 2 days in advance), are based on predicting weather conditions and
then using certain procedures to determine expected pollutant concentrations
from expected weather conditions. Other forecasts, (usually shorter term
ones, say less than a day in advance), use present pollution levels and
expected changes in weather conditions (i.e. better, same, worse) to predict
upcoming pollution levels. The first might be called a future-weather type
forecast, while the second might be called a weather-change type forecast.
The weather-change type forecast tends to be more reliable since it deals
with predicting increments in meteorological conditions rather than predicting
absolute meteorological conditions.
Section 2.3 stressed the need for using forecasting (as opposed to
feedback) episode criteria in a contingency plan for Los Angeles
since advanced notice is required to implement most control measures.
100
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This is particularly true for traffic abatement measures, and motor vehicles
are the dominant source of pollution. For the control of oxidant, the
pollutant likely to cause nearly all episodes, forecasting appears to be
an absolute necessity. Due to the complex nature of photochemical smog,
oxidant levels can continue to rise (while sunlight is available) even if
all emission sources are instantaneously shut-down.
The one major problem with the forecast approach is that predictions
of air pollution levels are not very accurate. Forecast errors will
mean that on some days more controls than necessary will be implemented;
an alert may be called when no controls are needed. On other days, in-
sufficient controls will be put into effect; no alert may be called and
significant harm levels may be exceeded.
One possible way to eliminate the latter decision error would be to
use feedback criteria as a backup system. If the forecast fails to pre-
dict an alert, the feedback system could still activate controls when
pollution starts to reach danger levels. Such a system might be possible
for primary contaminant alerts, although it still would have to contend
with the great difficulty of implementing controls on short-term notice.
For oxidant there is the added consideration that oxidant can continue to
accumulate even if all sources are shut-down. All things considered, feedback
criteria seem totally inappropriate for oxidant control*
* Under certain conditions, feedback controls might actually be counter
productive to oxidant control! Nitric oxide, the bas-j c emitted form of
NO , actually consumes ozone, the basic component of total oxidant, when
the former is emitted tnto the atmosphere after intense sunlight has
waned. This accounts for the fact that overnight, ozone levels are
suppressed below the natural background level in the populated sectors
of the Los Angeles basin, while ozone remains high in the air that has
blown out of the basTn and into the desert. Thus, reducing the evening
traffic on the day of an episode might allow more oxidant to persist
into the evening. (On the other hand, reducing the evening traffic
would help reduce pollutant levels on the following day.)
101
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The overall viability of the contingency plan may be very sensitive
to the available forecasting capabilities. In order to assess the present
capabilities in the Los Angeles Basin, a study was made of agencies now
issuing air pollution forecasts. The results of this analysis are pre-
sented in the next section, 4.1.3.
4.1.3 Air Pollution Forecasting Capabilities for the Los Angeles Basin
Nearly all air quality predictions for the Metropolitan Los Angeles
AQCR are done on the local (county) level. The California Air Resources
Board conducts only a very limited amount of pollution forecasting for
Los Angeles. Although the National Weather Service issues "Air Stagnation
Advisories," no actual predictions of air quality levels are put out by
federal agencies.
Table 4.1 summarizes the air quality forecasting capabilities which
are now available for the Los Angeles Basin. This table supports the
following general conclusions:
9 Experience - A great deal of experience has been gained in
forecasting instantaneous oxidant maxima (peaks) slightly
more than a day in advance. In particular, the Los Angeles
County APCD has conducted such a program for more than
seven years. There are indications that all of the fore-
casters, relying on knowledge gained in the L.A. County APCD
program as well as their own experience, seem to have
approached an optimum "state of the art" for predicting
peak oxidant 26-30 hours in advance within the constraint
imposed by availability of meteorological data, [9 ],
[31].
Experience is rather limited in forecasting primary pollutan^t
concentrations and time averages of oxidant. The L.A. APCD
has been conducting an experimental program for predicting
peak primary contaminant levels but has found that such fore-
casts tend to be much less reliabile than peak oxidant fore-
casts. Predicting time averages of oxidant (say 1, 2, or 4
hours) should not be particularly difficult; wtth sufficient
time to adjust, meteorologists may"be able to forecast time averaged
oxidant with, less error than peak oxidant, [9], [15], [31].
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TABLE 4.1 AIR POLLUTION FORECASTING CAPABILITIES FOR THE METROPOLITAN LOS ANGELES AQCR
ORGANIZATION
AND PRINCIPAL
METEOROLOGISTS
Los Angeles County
APCD
Ralph Keith
Arthur Davidson
David Hartman
San Bernardino
County APCD
Mel Zeldin
Riverside County
APCD
Erwin Kauper
(Consul tant)
Ventura County APCD
Earl Taylor
California Air
Resources Board
Spencer Duchworth
Robert McMullen
EXPERIENCE:
YEARS HAVING
ISSUED FORECASTS
7 years for oxidant
An experimental
program for CO
and NO- has been
underway 2-1/2
years
2 years
1-1/2 years
1/2 year
1/2 year
LOCATIONS IN
BASIN FOR
WHICH FORECASTS
ARE ISSUED
10 monitoring locations
within the basin:
Downtown, Long Beach,
Reseda, West L.A. ,
Lennox, Burbank,
La Mirada, Pasadena,
Azusa, and Pomona
4 locations: San '
Bernardino, Upland, ;
Chi no, and Redlands
4 locations in Riverside
County within the basin:
Riverside, Hemet, Prado
Park, and Pern's
2 locations in Ventura
County: Ventura,
Inland Val leys
One Basin-wide figure
(predicted maximum)
FORECASTED
QUANTITIES
Instantaneous
peak oxidant
(Experimental
Program, In-
stantaneous
peak CO and NOj
Instantaneous
peak oxidant
Instantaneous
peak oxidant
Maximum 1 hour
average oxidant
Maximum 1 hour
average oxidant
TIME OF
FORECAST
10:00 in the
morning of the
previous day
10:00 in the
morning of the
previous day
2:00 in after-
noon of the
previous day
10:00 in the
morning of the
previous day.
Update at 4:00 pir
2:00 in after-
noon of the
previous day
ACCURACY
Oxidant -- Average error, all stations:
Yearly: .028 ppm
July-Aug.-Sept. : .05 ppm
"Worst days" : .1-.2 ppm
CO and N00 -- Relative error is much
"~ greater than for oxidant.
Accuracy is not much better
than using monthly averages
for the forecast. Average
yearly CO error at all sta-
tions is 5 ppm.
Oxidant -- Average error at
San Bernardino station:
Yearly: Approx.* .03 ppm
July-Aug.-Sept. :*. 05 ppm
"Worst days": . 1-.2 ppm
*The average error reported by the
San Bernardino APCD is less than the
figures given above. However, the
San Bernardino APCD uses a -OB ppm
prediction range, i.e. 0-.05 ppm, .05-
.10 ppm, etc. The reported errors have
been adjusted upward to approximately
indicate the error to be expected from
an exact prediction.
Oxidant -- Average error at
West Riverside:
Yearly: .05 ppm
Oxidant -- 85-95% of all predictions
are within ± .05 ppm
Oxidant -- Approximately 90% of all
predictions are within
t .05 ppm.
REFER-
ENCES
[3], [9],
and [29].
[31]
[15], [22]
&6]
[10]
o
u>
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o Locations - From the various APCD's, forecasts are available
at~20 locations throughout the basin. The only significant
omission is Orange County which uses the L.A. County forecast
for areas near the Orange County border, [9 ].
e Forecasted Quantities - Presently, the basic predicted
quantity is peak oxidant level; three APCD's, which account
for 18 of the 20 locations, forecast this parameter.
Ventura County and the State ARB use max. 1-hour oxidqnt.
The L.A. APCD is the only organization significantly involved
with forecasting primary pollutants; their experimental pro-
gram predicts instantaneous peaks for primary contaminants.
e Time of Forecast - Basic forecasting times range from 10:00 a.m.
(Los Angeles, San Bernardino, and Ventura) to 2:00 p.m.
(Riverside and the State ARB) of the previous day. One very
significant aspect about these times (as compared to later in the
afternoon) is that the basinwide maximal oxidant of the previous
day is not a known quantity to be used in the forecast. If the
previous day maximum were available, it should improve forecasting
accuracy, [9], [15].
e Accuracy - As noted above, most forecasters seem to have approached
a best state of the art for predicting peak oxidant one day in
advance given the available weather data. On a yearly basis, the
average error is slightly less than .03 PPM in Los Angeles County.
However, this includes many days of very low oxidant which are
very easily forecasted on an absolute basis. For the months
of highest oxidant, July-August--September, the average error
is around .05 PPM. For the "worst days", say maximum oxidant
values above .40 PPM, the average error tends to be around
.10-.20 PPM, [15], [29], J31J.
The L.A. APCD experimental program for forecasting primary con-
taminants has shown that the relative error in predicting maxi-
mum primary contaminant concentrations is considerably greater
than that in predicting maximum oxidant concentrations. This is
essentially because maximum primary contaminant concentrations
depend much more on local, small scale, meteorological fluctuations
than do oxidant concentrations; some of these fluctuations,
(e.g. wind direction away from high traffic areas), are difficult,
if not impossible, to predict a day in advance, [9j.
Since this study is concerned with episode control, the forecasts of
most interest are those for days of extremely high pollutant concentrations.
For these days, the existing forecasting capabilities lack the accuracy
which would be desired for instituting episode control measures which have
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great socio-economic impact. For episode type days, peak oxidant forecasts
tend to be around .1 to .2 PPM in error. Peak primary contaminant forecasts
are not reliable in general? As part of the overall episode control program,
ways should be sought to reduce these forecast errors. Possible methods of
increasing accuracy are the following:
e Instead of forecasting instantaneous peaks, time averaged con-
centrations, (one hour, two hour, four hour, etc.) might be
used. This should eliminate some of the error due to unpre-
dictable "noise" type fluctuations which affect the peak value.
For days of high oxidant, switching to time averages might
reduce the forecast error by as much as 10-25%. Using
long term averages would improve the relative accuracy of pri-
mary contaminant forecasts even more, [9], [31],
Switching to time averaged concentrations should not present
significant problems to the forecasting meteorologists, [9], [31].
Essentially, they would just need to gain the experience of
dealing with a new, and slightly different, parameter.
• Instead of using the forecast of the late morning or early
afternoon of the previous day, an oxidant episode control
plan might be based on a late afternoon forecast. The
meteorologist would then have the benefit of knowing the
previous day maximum. In the terminology of section 4.1.2
this would be a change from a future-w_eatKer type forecast
to more of a weather-change type forecast. Switching to
late afternoon should improve forecast accuracy somewhat, but
it should not be expected to result in a tremendous reduction in
error. The one institutional problem associated with using
a late afternoon forecast is that a significant change will
be required in the present operational time-table of the
forecasting agencies, [9], [14], [15]. Also, later forecasts will
imply less time for implementation of control strategies, (See
Section 4.4.4.).
• Prediction accuracy would also be improved if more detailed
meteorological information were made avilable to the fore-
casters, [9]. An example would be taking vertical soundings
at more locations and more frequently. However, instituting
a program to provide more comprehensive data on air pollution
weather factors would involve considerable costs.
* Fortunately, primary contaminant forecasts are less critical since primary
contaminants are extremely unlikely ever to reach significant harm levels in
Los Angeles.
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It should be emphasized that, although improvements in forecasting
accuracy can be obtained by the means outlined above, these improvements
will tend to be marginal. Even with all of the above measures taken, one
cannot realistically expect the oxidant prediction error on episode type
days to be reduced to .05 PPM or less. It appears that significant fore-
casting uncertainty on episode type days simply cannot be eliminated in
the short term.
4.1.4 A Basic Dilemma
The preceding sections indicate that episode control in Los Angeles
involves a fundamental dilemma. In order to prevent significant harm
levels, in particular for oxidant, forecasting-type episode criteria are
necessary. However, even if a major effort is undertaken to improve the
already advanced and experienced forecasting capabilities, very significant
errors will remain in forecasts for episode type days. These errors will
lead to corresponding errors in the amount of control which is called for
as compared to the amount of control which is necessary. On days when the
forecast proves to be overly optimistic, less stringent controls than neces-
sary may be implemented and the significant harm levels may be exceeded.
«
One way to avoid this would be to "over control" the system by instituting
very strict controls whenever there is any threat of high oxidant levels.
However, since threats of high oxidant levels are frequent in Los Angeles
and since the socio-economic impact of effective control measures is very
great (see Chapter 5), and "over control" policy might be totally unacceptable
to the public. With a more realistic policy, it seems that exceeding the
significant harm levels because of forecast errors will just have to be an
accepted possibility.
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In conclusion, it appears that an emergency control plan for Los Angeles
should be based on forecasting type episode criteria. This type of plan will
be recommended by the present study (Chapter 6). An attempt to improve pre-
diction accuracy should be made, but significant forecast error is inevitable
and exceeding the harm levels must be accepted as a possibility. If the fore-
casting system fails and significant harm levels are reached, it would appear
best to concentrate efforts on measures for protecting public health, (e.g.
by broadcasting warnings to stay indoors, by keeping children late at school,
etc.) rather than to attempt to reduce emissions during the episode.*
4.2 CONTROL STRATEGIES
Associated with each stage of an episode contingency plan is a control
strategy to be implemented at that stage. Each control strategy consists
of a group of control measures along with implementation and enforcement
procedures for those measures. Before adopting specific control strategies
for the Los Angeles contingency plan, certain issues must be resolved.
First, the degree of emission control required to prevent significant harm
levels must be determined. Second, location aspects of the plan, (i.e.,
basin-wide vs. subregional control), must be decided upon. Third, an
evaluation of various alternative control measures as to effectiveness
(VMT reduction and/or emission reduction), institutional obstacles (imple-
mentation and enforcement), and socio-economic impact (cost and equity)
* This was the major point made in a testimony by the San Bernardino
County APCD to the Air Resources Board on September 19, 1973 in re-
viewing the State Air Pollution Emergency Contingency Plan. The
San Bernardino APCD noted that some control measures taken during the
middle of an episode, (e.g. closing retail stores and sending people
frome or stopping traffic), might actually increase the public exposure
to pollutant levels.
107
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should be performed. Of the control measures which are effective enough
to prevent harm levels, those should be chosen which minimize institutional
and socio-economic problems.
Section 4.2.1 calculates the degree of emission control required for a
Los Angeles episode plan. Section 4.2.2 deals with locational considerations.
Alternative control measures are thoroughly evaluated in Chapter 5, leading
to recommendations for adopting specific strategies.
4.2.1 Degree of Emission Reduction Required
A contingency plan for the Los Angeles Basin should provide for
sufficient reductions in RHC, NO , and CO emissions to prevent oxidant, N0?,
s\ ^
and CO from exceeding significant harm levels during air pollution episodes.
Below, the degree of RHC emission reduction required to prevent harm levels dur-
ing the most severe anticipated oxidant episodes will be calculated.* This will
serve as the emission reduction objective for the most advanced control strategy
stage. It will be assumed that control strategies which yield sufficient
RHC reductions to prevent oxidant harm levels will also yield sufficient
NO and CO reductions (through the vehicular control part of the strategies)
A
to prevent N02 and CO harm levels. This assumption should surely be valid
since ambient CO and NOp levels are very much lower than oxidant levels
relative to the significant harm standards (see section 2.2.5) and since
CO and NO^ pollution levels are more sensitive to emission level changes
during episodes than are oxidant levels (see section 2.2.7).
* Theoretically, the maximum emission reduction to insure always preventing
harm levels is a 100% reduction because theoretically, meteorological con-
ditions could be so adverse as to produce harm level concentrations from
negligible emissions. In the text above, a more practical and operational
concept of maximum degree of control will be used.
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Sections 2.2.5 and 2.2.7 provide the basic information for calculating
the maximum degree of RHC control required to prevent significant harm
levels for oxidant. Section 2.2.5 noted that the .40 PPM - 4 hour harm
level is the "binding constraint" of the three oxidant harm levels (.40 PPM
4 hour, .60 PPM - 2 hour, and .70 PPM - 1 hour). That section also noted
that the greatest recorded excesses of all three harm levels occurred in
July 1955 at Pasadena, (.58 PPM - 4 hours, .69 PPM - 2 hours, and .74 PPM -
1 hour). From January-1970 through June-1973, only the 4 hour harm level
has been violated; the greatest excess has been .53 PPM - 4 hours at River-
side on August 6, 1970.
Figure 2.8 showed that overall emission levels are now undergoing
a considerable decrease in the Los Angeles Basin due to the new car and used
car retrofit and other control programs. Oxidant episodes in the future
are expected to be less severe than in the past. It should surely be
sufficient to plan for a maximum degree of control capable of reducing
a .58 PPM - 4 hour oxidant episode to the .40 PPM - 4 hour harm level
standard.*
Section 2.2.7 derived the very approximate relationship that an X%
reduction in RHC emissions on a given day would result in only about a
%X% reduction in oxidant levels on that day. This less than proportional
effect results from carryover precursors remaining from the previous day
as well as certain basic nonlinearities in the oxidant-hydrocarbon
* On an equivalent percentage basis, such a plan could reduce a ,86 PPM -
2 hour episode or a 1.0 PPM - 1 hour episode to the .60 PPM - 2 hour
and .70 PPM - 1 hour harm levels.
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relationship. Thus, a plan capable of abating a .58 PPM - 4 hour oxidant
episode, (the harm level is 30% less than this), must provide for a 60%
reduction in RHC emissions.
4.2.2 Locational Considerations
An air pollution control plan can be instituted on either a basin-wide
or subregional basis. For air pollution episodes in the Metropolitan Los
Angeles AQCR, it would seem useful to make special regional considerations
for Ventura and Santa Barbara counties. Air pollution in these counties is
much less severe than in the other four counties of the Los Angeles Basin
(see Table 2.4); in fact, it is not expected that air pollution emergencies
would ever occur in these two counties. Furthermore, because of lower emis-
sion source density in Santa Barbara and Ventura and because of the typical
wind flow pattern, Santa Barbara and Ventura do not contribute significantly
to air pollution in the other four counties. The effect of Santa Barbara and
Ventura on oxidant episodes, which typically occur in the central-eastern parts
of the basin, is practically nil. It does not appear worthwhile to make these
two counties institute control measures with severe socio-economic impact dur-
ing air pollution alerts occurring elsewhere in the basin. A division of the
total region into a four county control region (Los Angeles, Orange, Riverside,
and San Bernardino), with Ventura and Santa Barbara to be added only under
special circumstances, seems called for.
However, any further regional subdivision for episode control does not
seem practical. Air pollution alerts might occur in any of the other four
counties, and very significant interaction exists between emissions in the
coastal counties (Los Angeles and Orange) and pollution levels in the
inland counties (San Bernardino and Riverside). To try to implement con-
trol measures on a subregional basis within the four county area would
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require prediction of trajectories for air parcels that will reach alert
levels, (so that control could be initiated in the regions along the trajec-
tories). Reliable trajectory forecasting of this type is doubtful. Further
investigation into region subdivision deserves consideration, but until sub-
division is demonstrated as practical, it appears that the four county region
should be treated as a whole in an episode control plan.
4.2.3 Alternative Control Measures
This study will consider potential episode control measures for both
stationary and mobile sources. Control of vehicular sources must be in-
cluded since they constitute the greatest single source category. Gasoline
powered motor vehicles (LDMV's, HDMVs, and motorcycles), account for 77%*
of RHC, 96% of CO, and 74% of NO emissions in the Los Angeles Basin in
/\
1973 (see Table 2.5). Although they produce less total emissions,
stationary sources are significant. Further, they often are very con-
centrated sources, and it is usually easier to control a few concentrated
sources then it is to control many disperse vehicular sources. Thus,
stationary source control should also be considered.
Table 4.2 lists the alternative episode control measures which will
be considered in this study. These control measures will be thoroughly
evaluated in Chapter 5 as to effectiveness (VMT and/or emissions re-
duction), institutional problems (implementability and enforceability),
and socio-economic impact (cost and equity). The most promising measures
will be organized into proposed control strategies in Chapter 6.
* This includes vehicle tank filling at gas stations.
Ill
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TABLE 4.2 BRIEF DESCRIPTION OF ALTERNATIVE CONTROL MEASURES
STATIONARY SOURCE CONTROL MEASURES
1. Ban Filling of Underground Service Station Tanks - Filling underground service station tanks prohibited.
2. Shut Down Major Point Sources - All operations at EPA defined major point sources would be closed.
3a. Shut_Down_Majq£ Point Sources and Other APCD_Desia_nated Categories (Rule 155.2) - No Exceptions Granted - All operations covered by above
definitions would be closed.
3b. Shut Down Major Point Sources and Other APCD Designated Categories (Rule 155.2) - Exemptions Allowed - All operations covered by above
definitions - subject to shut down, unless previously granted an exemption from a review committee established for this function.
TRAFFIC ABATEMENT CONTROL MEASURES
Direct Controls on Traffic
1. Voluntary Traffic Abatement - An appeal for voluntary reductions in unnecessary travel.
2. Windshield Sticker Program - Traffic restricted on the basis of previously issued windshield sticker colors.
3. License Plate Lottery - Traffic restricted on the basis of license plate numbers.
4. Ban Non-Essential Government Vehicles - Travel by governmental vehicles restricted, unless 1t is of an essential nature.
5. Ban (Private) Fleet Vehicles - Travel by private fleet vehicles prohibited.
6. Ban (Private) Fleet Vehicles and Use of Vehicles for Commercial Purposes - Travel by private fleets and other vehicles 1n commercial use
prohibited.
7. Ban All Non-Emergency Traffic - All travel not of an emergency nature, e.g. health and safety related, would be banned.
8. Mandatory Car-Pooling on Freeways - Travel on freeways restricted on the basis of vehicle occupancy.
9. Mandatory Car-Pooling on Freeways and Major Thoroughfares - Travel on freeways and major thoroughfares restricted according to vehicle
occupancy.
10. Commercial Abatement Schemes - Commercial enterprises required to reduce travel directly or indirectly generated by their operations.
Controls on Traffic Support Facilities
11. Close Freeways, (or Certain Freeway Lanes) - Travel on freeways (or certain lanes of freeways) would be prohibited.
12. Limited Availability of Parking - On-street and/or off-street parking would be restricted.
13. Special Parking Tax - Tax for parking instituted wherever feasible.
14. Gasoline Rationing - Program of gasoline rationing instituted.
15. Close Gasoline Stations - All retail gasoline outlets closed.
Control on Incentives to Drive
16. ' Close (Non-Essential) Federal Agencies - All federal agencies engaged in non-essential activities would be closed.
17. Close (non-Essential) Government Agencies (Federal, State 5 Local) - All governmental agencies engaged in non-essential activities would be
closed.
18. Close Government Contractors - All governmental contractors engaged In non-essential ooerations would be closed.
19. Close Shopping Facilities at Regional Shopping Centers and Central Business Districts - Shut down all retail and business activities at regional
shopping centers and central business districts.
20. Close Recreational Facilities - Shut down all recreational facilities, such as amusement parks, bowling alleys, sporting events.
21. Uork Holiday for Major Firms - Declare a work holiday for all firms larger than a certain size.
22. Rotating Work Holiday for Major Firms - Formulate a rotating schedule of work holidays for firri larger than a certain size.
23. Operate on Sunday Status - All businesses would assume a Sunday status for work.
24. Complete Uork Holiday with Recreation Closed - All businesses and recreational facilities would be closed.
-------
4.3 SURVEILLANCE PROCEDURES
As explained in section 2.3, two different types of surveillance
procedures are necessary for the effective operation of an air pollution
episode control plan. The first, monitoring of air quality and meteoro-
logy, provides the basic atomspheric data for the plan. The atmospheric
surveillance should consist of routine measurements between episodes
with stepped up activity during alert situations. The second, control
strategy surveillance, provides information on how well the control
plan is being implemented. This consists of monitoring emission sources
to determine the effectiveness of control measures and observing other
agencies to determine the extent to which they are fulfilling their
responsibilities. For the Los Angeles area, there are several alternative
ways of providing the appropriate surveillance. These are discussed
below.
4.3.1 Surveillance of Air Quality and Meteorology
Air quality and meteorology is currently monitored in the
South Coast Air Basin by agencies on three different governmental
levels - local, state, and federal. At the local level are the various
county Air Pollution Control Districts. At the state level is the
Air Resources Board. At the federal level are the Environmental Pro-
tection Agency and the National Weather Service. The air quality and
meteorology monitoring capabilities of these organizations are reviewed
below and are summarized in Table 4.3.
County APCDs
In the overall California state air pollution control plan, county
APCD's have the principal responsibility for air quality monitoring.
In the Metropolitan Los Angeles AQCR there are five APCD's maintaining
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Table 4. 3 SOURCES OF REAL-TIME AIR QUALITY AND METEOROLOGICAL DATA
IN THE METROPOLITAN LOS ANGELES AQCR
SOURCE
Los Angeles County APCD
Orange County APCD
Riverside County APCD
San Bernardino County
' APCD
Ventura County APCD
California Air Resources
Board
Env. Protection Agency
(CHESS)
National Weather Service
TYPE OF DATA
OX CO NO NO? N0v HC S0? Meteorological
C- A £•
X X X X XX X
XX X X X X X
X
XX X X X X
XX XXX X
X
XX X X X X X
X
monitoring networks, Los Angeles County, Orange County, Riverside County,
San Bernardino County, and Ventura County. These districts routinely provide
various air monitoring data, and some conduct special services which would be
available during an air pollution episode.
The Los Angeles APCD maintains a telemetry network of twelve air quality
sampling stations located throughout the county (See Figure 4.1). They con-
tinuously monitor concentrations of the following contaminants: ozone (OJ,
nitric oxide (NO), nitrogen dioxide (N02), sulfur dioxide (SO-), carbon
monoxide (CO), and total hydrocarbons (THC). In addition, the stations also
monitor wind speed and direction, temperature, solar radiation, and relative
humidity. At the present time, however, the telemetry system is not considered
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FIGURE 4.1 LOCATION OF REAL-TIME SOURCES OF AIR QUALITY DATA
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
Aiuaa
Burbanlc
El Monte
Glesdora
La Hirada
Lennox
Long Beach
Loa Angeles
Nevhall
Pasadena
Pomona
Reseda
Santa Monica
Torrance
West Covlna
West Loa Angele
ORAMCE COUNTY
17. Anaheim
18. Garden Grove
19. La Uabra
RIVERSIDE COUNTY
20. Prado Park
21. Riverside- Magnolia
22. Rubidoux-Ml»«ion Blvd.
SAN BESJJAfiDlNO COUNTY
APCD •
ARB *
EPA B
23.
24.
25.
26.
27.
Chlno
Foncana
Red land.
Sao Bernardino
Upland
VENTUTIA COUNTf
28. CaiMrillo-Pal»
29. OJai
30. Santa Paula
31. Thousand Oaks
32. Ventura
115
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reliable, and data is normally read by hand off strip-chart recorders located
at the stations, [11].
Presently, the Orange County APCD maintains two air quality monitoring
stations which provide real-time (immediately available) data, one at Anaheim
and the other at La Habra (see Figure 4.1), [30]. Each measures the concen-
tration of oxidants, nitrogen dioxide, oxides of nitrogen, carbon monoxide,
and sulfur dioxide. In addition,the Anaheim station provides data on total
hydrocarbons (THC). This information along with wind speed and direction,
/
temperature, and humidity, is usually read and relayed over the phone by
technicians several times a day. During an episode more technicians could be
sent into the field to other stations to increase the flow of data.
The Riverside APCD has two air quality monitoring stations (see
Figure 4.1) which manually telemeter oxidant concentrations, [13], The
system is queried by phoning each station. In addition, these stations also
monitor carbon monoxide, nitrogen dioxide, oxides of nitrogen, hydrocarbons,
sulfur dioxide, wind (speed and direction) and temperature. However, at this
time they are not included in the telemetry system.
The San Bernardino APCD is presently installing a telemetry system to
relay air quality data gathered from five stations (see Figure 4.1) on a real-
time basis, [31]. Information on the concentrations of the following contam-
inants will be transmitted: oxidants, carbon monoxide, oxides of nitrogen,
nitrogen dioxide, hydrocarbons, and sulfur dioxide. At this time, no ,
telemetry of meteorological data is planned.
The Ventura APCD is now installing a telemetry system which will provide
both real-time air quality and meteorology data, [27]. Information will be
relayed on the concentrations of oxidants, carbon monoxide, oxides of nitrogen,
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nitrogen dioxide, and hydrocarbons, plus wind speed and direction. At the
present time three stations are included in the system. In addition, two
other stations also report data on a real-time basis (see Figure 4.1).
California ARE
At the state level, the California Air Resources Board monitors air
quality and meteorology. The ARB has just installed a pilot telemetry system
with connections to three stations in the South Coast Basin: Upland, Riverside
and El Monte. These stations measure oxidants, nitrogen dioxide, oxides of
nitrogen, carbon monoxide, total hydrocarbons, plus wind speed and direction.
While the system has the capability to relay eight pollutants along with wind
data, it is presently only being used to transmit oxidant concentrations, [16].
Besides the information received via the telemetry system, the
ARB routinely obtains data from several other sources, [21], The ARB sub-
scribes to the National Weather Service service A, service C and PONY
service. Reports on all hourly average concentrations for each pollutant
are received from all APCD's in the state. There is, however, a con-
siderable lag in processing the APCD data, 15 to 45 days. The ARB also
conducts its own aircraft soundings at Riverside to measure the vertical
stability of the atmosphere over the Los Angeles basin. In addition,
during an actual air pollution episode, the ARB maintains phone contact with
Us own stations In the affected area (on an hourly basis) and with the APCD
in the county where the episode is occurring.
EPA and NWS
At the federal level, the Environmental Protection Agency and the
National Weather Service provide air quality and meteorological data
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for the Los Angeles basin. The EPA operates a nationwide system of air
quality monitoring stations with six in the Los Angeles basin (see Figure 4.1).
These stations, known as CHESS stations, relay information concerning atmos-
pheric concentrations of ozone, carbon monoxide, nitrogen dioxide, oxides of
nitrogen, sulfur dioxide, and total hydrocarbons along with temperature and
dew point to Durham, North Carolina, [2]. From there, the data is available
by phone.* The NWS offers several meteorological services (via teletype) with
information relevant to the South Coast Basin, [20]. They are service A,
service C, and PONY service. Service A, while principally for aviation, pro-
vides hourly information on temperature, pressure, winds, etc., which is use-
ful in determining the overall meteorological condition of the basin. Service
C, which originates in Washington, discusses regional meteorological conditions
and issues broad based advisories, such as that for air stagnation. PONY
service, on the other hand, is a regional service (catering to the FAA)
designed to alert subscribers to the latest special observations, including
local air stagnation advisories. In addition to these services the NWS also
conducts balloon soundings twice daily at El Monte and Los Angeles International
Airport to determine vertical stability.
Having described the available monitoring capabilities, it is now
possible to review the atmospheric surveillance procedures of each
government agency as they pertain directly to air pollution episodes.
At the local level, air quality surveillance is conducted primarily
tn conjunction with the health warning programs of the county APCDs.
However, due to the time zone difference, data is normally available
only until 1:30 PM Pacific Time, when the EPA North Carolina operations
close. In unusual circumstances, this time limit can be extended, [2].
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Atmospheric pollutant concentrations are observed throughout the day to
insure that conditions have not deteriorated to alert levels. During an
episode, air quality levels are simply checked more frequently.
Essentially the same is true of the state procedures. The ARB continually
checks the telemetry from its three stations in the basin to determine if
pollutant concentrations are approaching alert levels and surveys meteorologi-
cal conditions to check if an episode is probable. If this data indicates
that an alert is imminent (or if the ARB is informed by an APCD that an episode
has occurred or is likely to occur), then an effort is made to obtain more
complete and up-to-date air monitoring data. Although there exist no formal
alert procedures, at least once per hour each ARB station in the basin is
called, and less frequently, the affected APCDs are phoned.
Surveillance at the federal level is conducted by EPA Region IX in
San Francisco. Each day, the Region IX meteorologist notes the peak pollut-
ant readings for the previous day from newspaper reports and calls the station
with the highest value to obtain relevant data, [14]. From the National
Weather Service, the Region IX office obtains a special forecast summary of
atmospheric conditions in the basin. If an episode appears probable, oxidant
data from the ARB is relayed by telecopier and telephone as it becomes avail-
able. In addition, data from the CHESS stations are obtained from Durham,
North Carolina, and the affected APCDs can be called to obtain data not
available from the ARB.
The above description of air monitoring capabilities indicates
that existing air quality and meteorological measurements in the South Coast
Bastn are quite adequate for supporting an episode contingency plan
operation; atmospheric monitoring data are generated on a continuous
basis at numerous sampling sites-. However, the discussion of surveillance
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procedures indicates that reliable methods for quickly obtaining all this
data (especially for the EPA) have not been instituted. Too much seems to
depend on extemporaneous phone calls to agencies which may not have adequate
time to deal with these calls due to their own activities with regard to the
episode or due to their routine duties.
EPA Region IX has indicated that the major problem in air quality
surveillance is to obtain the existing data. There are several possible
ways this could be improved. For one, a system could be established to
telemeter data directly from the monitoring stations to EPA headquarters in
San Francisco. Second, a regional center could be established in Los Angeles.
Air quality and meteorological data from all stations (APCD, ARB, and EPA)
could be telemetered to this station for processing and then relayed to EPA
Region IX headquarters over the telephone. Third, the EPA could attempt to
maintain phone contact with all affected APCDs. Finally the ARB could be
encouraged to establish real-time informational channels with the APCDs. in
the South Coast Basin and to act as the principal disseminator of data. EPA
Region IX could then establish well defined arrangements for the ARB to relay
appropriate data on a regular basis, (say by telephone).
Of these four alternatives, the last appears preferable. The first two
would be enormously expensive and would force the EPA to do all of its own
data analysis and hence greatly increase its work load. The third presents
problems of reliability and availability especially during episode conditions
when APCD manpower is already hard pressed to meet its own demands. The last
alternative would keep EPA Region IX out of data processing and encourage
closer cooperation and coordination between the ARB and APCDs. Further, it
would provide a large body of data all at one location and would simplify
overall communication problems.
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In summary, the problem of air quality and meteorology surveillance in
the Metropolitan Los Angeles AQCR is not so much due to lack of data as it
is due to difficulties experienced in attempting to obtain the data on a
real-time basis. It would appear that new procedures such as those mentioned
above are necessary in order to facilitate smoother dissemination of
information.
4.3.2 Surveillance of Strategy Implementation
Strategy implementation surveillance consists of two parts, agency
surveillance and source surveillance. Agencies with responsibilities for
air pollution episode control must be observed to determine the extent to
which they are fulfilling these obligations. Source surveillance determines
the degree of compliance with the controls which have been instituted and
provides basic information for enforcing these controls as well as for
planning additional actions.
Agency Surveillance
Under present state regulations and plans, the primary responsibility
for episode control lies with the county APCDs. Until a Third Stage Alert
is called (defined by the extremely high and unprobable atmospheric levels
of 1.5 PPM for oxidant or 150 PPM for CO, Table 3.1), at which time the
Governor is requested to declare a state of emergency and take appropriate
action, no basin wide cooperation is provided for. No single APCD has super-
visory responsibilities concerning the actions of any other APCD, and
although the various APCDs sometimes cooperate in the exchange of informa-
tion during an air pollution episode, there are no established procedures
for reporting activities to one another. A Basin Coordinating Council exists
for the basin, but this Council is not normally called into action during an
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episode. Thus, on the regional level, there are no procedures for monitoring
the actions of the various APCDs during an alert.
On the state level, the Air Resources Board has general authority to
survey the activities of the individual APCDs. However, during episodes
there is no actual requirement for APCDs to report to the ARB. In practice,
during alert situations, the ARB keeps in fairly close telephone contact
(approximately on an hourly basis) with the affected APCDs and acts in an
advisory role, [1]. If it is determined that an APCD is not adequately
coping with the situation, the ARB can take direct control, but only after
24 hours notice. Thus, even at the state level no formal procedures presently
exist for appraising the actions of all APCDs in the South Coast Basin during
an alert.
It should be noted that regulations and legislation are pending concerning
regional air pollution control in Los Angeles and concerning episode contin-
gency plans in California. These may significantly change certain responsi-
bilities and thus alter the surveillance pattern outlined above.
At the federal level, the Environmental Protection Agency, through the
Regional Offices, has responsibility to take action during an episode either
in the absence of an acceptable State or local program or in the case that
the State or local program is not applied with sufficient effectiveness.
EPA Region IX must observe the activities of the APCDs and ARB during an air
pollution episode in the South Coast Basin to insure that adequate controls
are instituted. At least three alternative forms of agency surveillance are
open to Region IX. First, Region IX could use field personnel for on-the-
scene observations of actions by all APCDs and the ARB. These personnel
would report back to EPA headquarters at regular intervals. Second, Region IX
could maintain telephone contact with all the APCDs and the ARB and obtain verbal
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descriptions of all activities from the state and local personnel.
Finally, the EPA might leave it up to the ARB to monitor local APCD
activities and obtain reports of both state and local actions from the
ARB alone. For the EPA, the last approach is most practical in terms
of communications simplicity and administrative cost.
Source Surveillance
The source surveillance procedures of an air pollution episode plan
must deal with both stationary sources and mobile sources. Since the
former basically involve emissions at certain well defined locations
while the latter involve emissions from diffuse traffic throughout the
basin, different procedures might be applicable to the different
source types. Thus, the existing surveillance alternatives for stationary
and mobile sources will be discussed separately below.
In the California air pollution control program, County APCDs have
the responsibility for stationary source surveillance and enforcement,
both in the overall air quality control program and during episodes.
The surveillance procedures are fairly uniform among all the APCDs in
the Los Angeles Basin. Each APCD maintains a staff (from 4 to 100) of
trained enforcement personnel, [7]. These investigators routinely patrol
particular areas within their county, make unannounced spot checks, and
respond to complaints filed by citizens. To supplement this capacity,
the ARB has a staff of approximately fifty people who respond to sur-
veillance requests by individuals or APCDs, [17].
The APCD and ARB enforcement personnel are trained in visual
observation and source sampling techniques. During an episode, this
level of expertise is not really required since sources basically have
to be checked for shut down and not for compliance with standards. Thus,
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although the familiarity with source locations would make APCD and ARB
personnel very valuable in stationary source surveillance during an episode,
source surveillance could be conducted by any well-trained personnel.
Presently, the only agency in the Los Angeles Metropolitan Air Quality
Control Region capable of moni'toring traffic on a real-time basis is the
California Department of Transportation (DOT) - District 07. As part of the
Los Angeles Area Freeway Surveillance and Control Program, it conducts
traffic counts on a forty-two mile loop encompassing portions of the
Santa Monica, San Diego, and Harbor Freeways (see Figure A.3 in Appendix A),
[4]. These counts are used to compute average speeds which are in turn used
to detect accidents and congestion. During the day, this traffic data is
accumulated at five minute intervals. Around midnight, all five minute
traffic data for the entire loop is printed out. This is the only volume
data currently available except by operator interrogation of a particular
system station, [5]. It would not be exceedingly difficult to set up a
procedure for obtaining instantaneous traffic volume estimates through an
appropriate computer interrogation subroutine. The DOT has indicated that
it should be able to provide the EPA with qualitative estimates of traffic
volume on the loop. Further, officials have indicated that these estimates
should give a fairly good representation of the total traffic picture in
the L.A. area.
If cooperation can be obtained from county and state officials, it
would be more practical to rely on the existing surveillance procedures of
the APCDs for stationary sources and the DOT for traffic rather than to
attempt to institute a whole new surveillance program. The programs
discussed above are very expensive to implement, and duplication of effort
should be avoided.
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4.4 OPERATIONAL PROCEEDURES
4.4.1 Legal Considerations
Preliminary to discussing alternative operational procedures for an
episode contingency plan, it is useful to review the existing structure
of legal authority and responsibility. In the Metropolitan Los Angeles
AQCR, episode control action can by law be exercised at three different
governmental levels - local, state, and federal. The nature and extent
of the legal authority at each level to implement emission control measures
will be discussed below. Particular attention will be given to whether
or not the power exists to regulate vehicular traffic, especially through
such indirect methods as closing gas stations, regional shopping centers,
recreational facilities, etc., and to the question of liability for lost
wages and profit.
Local
Section 24198 of the California State Health and Safety Code establishes
the county Air Pollution Control District as the focus for local air pol-
lution control, [23]. Section 24260 authorizes the governing boards of
these districts, (e.g., county supervisors), to "make all needful orders,
rules and regulations necessary or proper to accomplish the purposes of the
[Act] . . . ". It further provides that "... the air pollution control
districts, (e.g. , their governing board, in general the County Boards of
Supervisors), to "make and enforce such orders, rules, regulations as will
reduce the amount of air contaminants released within the district."
Violations of any such rule or regulation are made misdemeanors under Health
and Safety Code Section 24281. Thus, in view of this broad authority to
reduce air pollution, it appears that a rule or regulation enacted to imple-
ment an emission reduction measure whether it involved direct or indirect
control of traffic would be valid.
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However, the actual regulations which have been enacted under the
provisions of the Health and Safety Code may not have sufficient scope for
large scale, indirect vehicle control. Typical is Rule 158 of the Los Angeles
Air Pollution Control District which states that "The Air Pollution Control
Officer may . . . order the closing of any industrial, commercial, or busi-
ness establishment and stop vehicular traffic . . . , if, in the opinion of
the Air Pollution Control officer, the continued operation of such establish-
ment or vehicle contributes to the further concentration of any air contami-
nant, the concentration of which caused the declaration of the 'alert'.",
[19]. This separation of causation (i.e., there is no acknowledgment of the
link between the operation of an establishment and the operation of motor
vehicles) along with the provisions in Rule 154.1 that episode control plans
should not interfere "with the operations of public utilities or other pro-
ductive, industrial, business, and other activities, which are essential to
the health and welfare of the public or result in irreparable injury to any
means of production or distribution" makes it questionable if any large scale
form of indirect control, such as a work holiday, could be locally instituted.
However, APCD rules do not apparently rule out the possibility of using
more specific forms of indirect control. For example, closing heavy
industry would certainly be permissible under Rule 154.1, paragraph a,
which states the Air Pollution Control Officer may give written notice
to the owner or operator of such industrial, business, or commercial
establishment or activity to submit . . . plans for immediate shutdown
or curtailment, in the event of an air pollution emergency, all of the
sources of hydrocarbons . . . , including vehicles owned or operated
by such person, his agents or employees in the scope of the business or
operation of such establishment or activity." Further, since control
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action is being taken in the context of curtailing a specific short
term public health menace, there is no indication that local government
would be liable for any lost wages or profit, £24].
State
At present, the State of California may implement air pollution
episode control in one of two ways. The first is by superceding the
authority of a local Air Pollution Control District through the Air
Resources Board. The second way is to have the Governor declare a
state of air pollution emergency. Both are discussed below.
Pursuant to the Mulford-Carrell Air Resource Act, Chapter 7,
section 39273, each Basinwide Air Pollution Control Coordinating Council
(composed of members or appointees from each APCD board) is required to
submit a basinwide air pollution control plan to the ARB designed to
meet or exceed air quality standards established by the board for that
basin, [24]. If this plan is not submitted or if it is not enforced,
section 39274 of the act provides that "the board may take any appropriate
legal action to enforce such a plan, including emission standards and
enforcement procedures therein." Further, section 39274 states "the
Board shall also have the authority to take in any county air pollution
control district any action or function the district is authorized to take."
Thus, if the Board requires as part of the basinwide plan an episode
control program, it may assume control over the program whenever the
program is not being implemented or enforced by local authorities. More-
over since the ARB is empowered with all the authorities of the local Air
Pollution Control Districts, it should be able to implement both direct
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and indirect types of vehicle regulation and should not be liable for lost
wages and profits.
As mentioned above, the second way in which the State may promulgate
episode control is through the declaration of an air pollution emergency.
According to Government Code Section 8625, the Governor may proclaim a state
of air pollution emergency "in any area affected or likely to be affected
thereby when:", [25]
a) He makes a determination that conditions of disaster
or extreme peril to human safety and property caused
by air pollutants are likely to be beyond the control
of the services, personnel, equipment and facilities
of any local government body; and either
b) He is requested to do so (i) by the mayor or chief
executive of a city (ii) or the board of supervisors
or the chief executive of a county; or
c) He finds that local authority is inadequate to cope
with the air pollution emergency.
It should be noted that section 8625 states clearly the Governor may
declare an air pollution emergency not only when the conditions above
exist, but also when they are likely to exist. This allows action to
be taken on a forecast basis.
Once an air pollution emergency has been declared, the Governor may
assume "complete authority over all agencies of the state government and
the right to exercise within the area designated,all police power vested
in the state" (section 8627). Furthermore, he may commandeer or use
private property or personnel, if necessary, to aid in abating the
emergency. However, the state must then pay the reasonable value of
property or personnel services used (section 8572).
Thus, it appears that the Governor's extraordinary powers during
an air pollution emergency clearly would support both direct and indirect
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traffic control measures. In addition,if private property and services
are not actually taken over or commandered by local or state govern-
ment officials in order to implement an episode control plan, then,
no compensation is required for lost wages or profits. However, should
a particular type of business be singled out for control, or if a
person's (or business') service or property are commandered by the
State\ reasonable compensation is probably necessary, [3].
Federal
The Federal government, through EPA Region IX, may implement
emission reduction measures on the basis of two different sections of
the Clean Air Act as amended (December 31, 1970), [6]. They are:
A. Section 113, (a)(2) - Federal Enforcement
Section 113 (a)(2) allows the Administrator of EPA to enforce a
state implementation plan (including episode control programs)" when-
ever, on the basis of information available to him, . . . [he] finds
that violations . . . are so wide spread that such violations appear to
result from a failure of the State ... to enforce the plan effactivity
..." He would do so by:
1) notifying the state,
2) allowing thirty days for the state to begin enforcing
the plan; and if the state fails to do so
3) announcing this publicly and commencing federal enforce-
ment
Section 113 (a)(2) also provides that ". . . the Administrator may
enforce any requirement of such plan with respect to any person -
(A) by issuing an order to comply with such requirement,
(B) by bringing a civil action . . . ."
129
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B. Section 303 Emergency Powers
This section states "... the Administrator upon receipt of
evidence that a pollution source or combination of sources (including
moving sources) is presenting an imminent and substantial endangerment
to the health of persons, and that appropriate State and Local authorities
have not acted to abate such sources, may bring suit on behalf of the
United States ... to immediately restrain any person causing or
contributing to the alleged pollution to stop the emission of air
pollutants causing or contributing to such pollution or to take such
other action as may be necessary."
From the above descriptions,it is clear that the actual legal
authorities which sections 113 and 303 grant the EPA are somewhat
different in nature. The authority provided under section 113 is more
long term. It does not require convincing a judge, and allows action
to be taken before there is an imminent and substantial endangerment to
health. However, it also requires a longer time to invoke (30 days).
In addition, the EPA would be enforcing a state plan which may or may
not allow indirect forms of VMT reductions and which may or may not
have certain kinds of compensatory obligation connected with it.
(Section 110(c) does, however, allow the EPA to promulgate plans or
portions thereof when it finds the State's plan unacceptable). Section 303,
on the other hand, grants the EPA short-term authority to implement
episode controls. Under its provisions, the EPA may take action
against both stationary and moving sources. Further, it appears to
allow for both direct and indirect forms of traffic regulation. How-
ever, it also means that a judge must be convinced that not only does
130
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an imminent and substantial endangerment to health exist but that state and
local officials have failed to act properly and that the injunctive action
being sought is indeed appropriate and correct.
Thus, it appears that the EPA has the legal authority to implement
both direct and indirect episode control measures in the South Coast Basin.
This authority is certainly granted under Section 303 and most likely could
be incorporated by means of Section 112 in conjunction with Section 110.
Further, it also appears, at least as far as the Clean Air Act is concerned,
that the EPA will not be liable for lost wages and profits. In addition, this
exemption from liability also seems to extend down to state and local levels.
4.4.2 Imp!ementation Organization
In order for an air pollution episode control plan to be implemented
effectively, it must be supported by an organizational structure capable of
sustaining four different kinds of operations: surveillance, strategy
selection, enforcement, and communications. This section briefly describes
three alternative approaches to the design of just such an organizational
structure. They were developed by, respectively, the Los Angeles County
Air Pollution Control District, the Argonne National Laboratory (for the
City of Chicago), and Region IX of the Environmental Protection Agency.
Los Angeles APCD
The supporting organization for the Los Angeles APCD episode control
plan consists of six different parts (see Figure 4.2). They are the air
pollution meteorologist, the Air Pollution Control Officer, the Emergency
Action Committee, the Air Pollution Control Board, the Director of
Enforcement, and the Special Services Division. The function of each
is outlined below, [18], [19]:
131
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AIR POLLUTION
METEOROLOGIST
co
AIR POLLUTION
CONTROL BOARD
AIR POLLUTION CONTROL
OFFICER
-Ess,
DIRECTOR OF ENFORCEMENT
I
SPECIAL SERVICES DIVISION
EMERGENCY ACTION
COMMITTEE
Figure 4.2
Los Angeles APCD Organizational Structure for Episode Control
-------
1. Air Pollution Meteorologist -- The task of the meteoro-
logist is to provide a real-time assessment and short
range (up to 36 hours) forecast of the state of the
atmosphere.
2. Air Pollution Control Officer (APCO) -- As shown in
Figure 4.2 , the Control Officer is the key figure in
the control operation. He must select the appropriate
control strategies and supervise all personnel to in-
sure that the controls are being implemented properly.
3. Emergency Action Committee -- This committee advises
the APCO as to which control strategies are most
appropriate. It consist of ten members with training
or knowledge in air pollution, medicine, business,
and law enforcement.
4. Air Pollution Control Board -- The Control Board
(L.A. County Board of Supervisors) reviews the
actions of the APCO and must grant concurrence
before he may take certain steps to abate the
episode.
5. Director of Enforcement -- The Director is responsible
for initiating episode abatement and activities and oversees
surveillance and enforcement.
6. Special Services Division -- This Division handles all
the necessary communication with the media, public
agencies, schools, etc.
Thus, in this particular organizational configuration, surveillance is
handled by the air pollution meteorologist and the Director of Enforce-
ment, strategy selection by the Air Pollution Control Officer, enforce-
ment by the Director of Enforcement, and communications by the Special
Services Division.
Argonne National Laboratory
Argonne National Laboratory has modelled its episode control
organization for the City of Chicago after the dispatching setup used
by many utilities. As Figure 4.3 shows, there are three functional roles
the air pollution meteorologist, the control strategist, and the tactical
dispatcher. A brief description of each role is presented below, [8]:
133
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AIR POLLUTION
METEOROLOGIST
AIR POLLUTION
CONTROL STRATEGIST
1
CO
AIR POLLUTION
TACTICAL RESPONSE COORDINATOR
Argonne National Laboratory
Figure 4.3
Organizational Structure for Episode Control
-------
Air Pollution Meteorologist -- The task of the meteorologist
is to produce a real-time assessment and short-range
(12-36 hours) forecast of the state of the atmosphere
in the basin and to translate these evaluations into
air quality predictions which can be employed directly
in the selection of control strategies.
Control Strategist -- The control strategist seeks to
impose the minimum degree of control that is practical
and consistent with the prevention of significant
harm levels. He does this by integrating the air quality
report and forecast provided by the meteorologist with an
assessment of the current status of significant emission
sources within the basin. He is,in effect.master planner
and policy maker.
Tactical Coordinator — The primary responsibility of the
tactical coordinator is to insure that the control strategy
selected by the strategist is carried out. He must monitor,
direct, and deploy the various surveillance and enforcement
units available to him. He must also manage communications,
acting as a liason between the control strategist and the
public.
It is obvious from the above description that Argonne has taken a more
simple approach to the problem, preferring to concentrate responsibility
in three key positions, rather than delegate it-to a larger number of
people as done by the LAAPCD and (as will be seen below) by EPA Region
IX. All four key types of operations can be handled by the Argonne
organizational structure.
Region IX EPA
Region IX has chosen to take a team approach to the problem of organi
zation structure. Responsibility is divided among five specialist teams,
[28]:
135
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1. Surveillance Response Team
2. Technical Control Strategy Response Team
3. Public Affairs Response Team
4. Communications Response Team
5. Legal Enforcement Response Team
The activities of these teams are supervised and coordinated by the
Emergency Response Coordinator whose responsibility it is to decide
what actions if any the EPA will take during the episode, (see Figure 4.4).
The functions of the various Special Response Teams are as follows:
Surveillance Response Team -- During episode operations
this team will be responsible for data acquisition. It
will analyze data and prepare special advisory reports.
Technical Control Strategy Response Team -- The function
of this team is to develop and maintain control strategies
and emission reduction plans. It will also help determine
the need for legal action.
Public Affairs Response Team -- The Public Affairs Response
Team will handle all releases of information to the public.
Communications Response Team -- This team will coordinate
all communications for EPA operations during the episode.
Legal Enforcement Response Team -- The Legal Enforcement
Response Team will handle all legal aspects of the episode
control operation, including legal briefs, depositions,
expert witnesses, etc.
In addition to this, the Surveillance, Technical Control Strategy, and Legal
Enforcement Response Teams are responsible for providing a representative
who will act for his team.
Evaluation
Since none of the organizational structures has operated under actual,
prolonged episode conditions, it is very difficult to evaluate,and thus,
compare relative effectiveness. All that can be said at this time is that
136
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EMERGENCY RESPONSE
COORDINATOR
PUBLIC AFFAIRS
RESPONSE TEAM
LEGAL ENFORCEMENT
RESPONSE TEAM
TECHNICAL CONTROL
RESPONSE TEAM
SURVEILLANCE
RESPONSE TEAM
COMMUNICATIONS RESPONSE TEAM
ON SCENES
COORDINATOR
RESPONSE TEAM
REPRESENTATIVES
Figure 4.4
EPA Region IX Organizational Structure for Episode Control
137
-------
on paper at least,each of the three structures does contain provisions for
handling the four essential operations mentioned above: surveillance,
strategy selection, enforcement, and communication.
4.4.3 Communication Channels
Several different types of communication are essential for EPA
Region IX to manage effectively an air pollution episode plan for the
Metropolitan' Los Angeles AQCR. They are:
a) Communication with headquarters
b) Communication with personnel at the scene of the
episode
c) Communication among personnel at the scene of the
episode
d) Communication with the ARB and local APCDs
e) .Communication with other government agencies,
commercial firms, industry, and business
f) Communication with the public.
This section will discuss possible channels for dealing with these
communications and methods for establishing them.
First, it is useful to review the provisions for communications that
Region IX has already incorporated into its Regional Emergency Operations
Control Center (REOCC). According to the REOCC Operation Manual, all
communications are to be handled by the Center's Communications Response
Team (CRT), [28]. It is its job to receive and route all incoming calls,
maintain a log for incoming calls, coordinate dissemination of information,
and provide a buffer zone for internal REOCC Operations. In addition to the
CRT, the REOCC also maintains a Public Affairs Response Team (PART) whose
function it is to disseminate information to the press and the public and
to answer inquiries from them. Finally, there are provisions in REOCC for
138
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two On-Scene Coordinators (OSC). During an episode,one of them is sent to
the ARB and the other to the local episode area. One of their principal jobs
is to assist in the transmission of data and information back to the REOCC.
Generally speaking, the REOCC Operations Manual defines fairly well the
possible channels of communication. However, it does leave open the question
of whether the channels should exist at the regional (EPA Region IX) level,
the local level, or both. It also fails to specify exactly what means of
communication should be used, (radio, telephone, etc.). These possibilities
are considered in more detail below for each type of required communication:
a) Communication with headquarters -- Since this will involve
only the highest level decisions (i.e., federal versus non-
federal control), it should-be conducted at the regional
level only, via the Communications Response Team. Telephone
should be sufficient.
b) Communications with personnel at the scene of the episode --
Presently field personnel would maintain direct telephone
contact with the CRT. For a small number of field personnel
this seems adequate. However, for any substantial field
operations program, it would appear more practical to send
representatives of the CRT into the field to establish a
local -communications center. At this time, direct radio
contact seems unnecessary and too expensive.
c) Communications among personnel at the scene of the episode --
Currently, any formal communications among field personnel
must be routed through the CRT at the regional control center.
If a local communications center were established, this could
be handled through the local center.
d) Communication with the ARB and local APCDs -- At present,
the CRT maintains telephone contact with the APCDs and ARB.
This is enhanced by the presence of On-Scene Coordinators,
both at the state level and at affected APCDs. In the
past, it has been noted that as the episode becomes more
severe, it is increasingly difficult to maintain reliable
contact with those agencies. More reliable, pre-planned
telephone communication should be arranged.
139
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e) Communication with other government agencies, commercial
firms, industry, and business -- Two options appear to
exist. First, communication can be channeled through a.
field representative or second, it can go directly to
the regional control center via the CRT with regional
operations dispatching field representatives only when
necessary. The REOCC Operations Manual is unclear as
to what is intended. However, the second option appears
preferable, since the control operation is being run at
the regional level. Telephone seems to be the only
feasible means of establishing communications. A toll
free number for inquiries seems advisable.
f) Communication with the public -- Presently, all
communication with the public would be handled by
the PART at the regional control center. The problem
with this is that public action is taken at the local
level, not the regional level. The dissemination of
information may be unnecessarily slow since the impor-
tant media representatives are at the local level.
An alternate approach would be to send representatives
of PART into the field to hold press conferences and
to locally coordinate communications to the media and
to the public (via the media). Again a pre-established
toll free number for inquiries seems to be advisable.
Figures 4.5 and 4.6 schematically show communications ch'annels as they
now exist along with the improvements suggested above. It should be noted
that a local communications center necessarily implies extra planning and
effort. In all likelihood, prior arrangement would have to be made with
agencies in potential trouble areas to provide for certain needs (e.g.,
office space). However, the benefits of such a center may outweigh the
difficulties.
4.4.4 Activity Phasing
A final aspect of the air pollution episode contingency plan which needs
to be considered is the actual sequencing of the control operation activities.
Since the plan must be implemented on short notice, twenty-four to thirty-six
hours, proper timing is critical; failure to complete one step could negate
the whole operation.
140
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REGIONAL EMERGENCY
OPERATIONS CONTROL
CENTER
EPA
HEADQUARTERS
PUBLIC
AFFAIRS
RESPONSE
TEAM
ON-SCENE
COORDINATORS
( ON-SCENE A
I COORDINATORS/
FIELD X f FIELD
REPRESENTATIVE) (REPRESENTATIVE
LOCAL
APCDs
THER GOV't
AGENCIES,
INDUSTRY, ETC
Figure 4.5
Communications Channels As Outlined in REOCC Operations Manual
-------
ro
REGIONAL EMERGENCY
OPERATIONS CONTROL
CENTER
EPA
HEADQUARTERS
PUBLIC
AFFAIRS
RESPONSE
TEAM
LOCAL
COMMUNICATIONS
CENTER
ON-SCENE
COORDINATORS
ON-SCENE
COORDINATORS
FIELD
REPRESENTATIVE
FIELD
EPRESENTATIVE
THER GOV't
AGENCIES,
INDUSTRY, ETC
LOCAL
APCD's
Figure 4.6
Possible Modifications to Existing Commum"cations Channels
-------
Episode control can be divided into three phases - the initiation phase,
the control phase, and the termination phase. Each of these phases consists
of a series of activities which must be completed before the operation can
advance to the next phase. In addition to this, there are also certain time
constraints which the various phases must meet. The activities and time
constraints for each phase are descussed below.
Initiation Phase
When the air pollution meteorologist forecasts that air quality will
deteriorate to episode levels, control operations enter the initiation
phase. In this phase, the severity of the episode must be determined and
an appropriate control strategy chosen. Once this has been done, the choice
must be made public so that those affected may take the necessary actions.
Strategy selection should be completed, at the latest, by 4:00 to 5:00 PM
the previous evening in order to make the evening news as an emergency
announcement. However, even earlier strategy selection would be very helpful
in control implementation. Selection at 1:00 to 2:00 PM would allow more
time for proper notification of radio and television broadcasters. An
11:00 AM selection would be able to make the evening newspapers. If
employee/employer coordination is required in the control strategy, a
•4
2:00 - 3:00 PM deadline appears reasonable, [12].
A very important trade-off is involved in scheduling the strategy
selection phase. With a very late deadline, (say late afternoon), imple-
mentation and proper public notification will be difficult; however, a
weather-change type forecast (based on knowing the previous day maximum
oxidant level) can be used. With an early deadline, (say around noon),
many implementation and public notification problems will be alleviated,
143
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but a less accurate, future-weather type forecast must be used. It is
recommended that this trade-off be investigated to determine if the gains
in forecast accuracy are worth the loss in operating time associated with
a late afternoon deadline. A compromise alternative, which might prove to
be more effective, would be to start control implementation based on a
late morning forecast and then to alter certain aspects of the strategy
according to the late afternoon forecast.
Control Phase
With the announcement of the control strategy, operations enter the
control phase. The first half of this phase is devoted to the implementation
of control measures. By the time the work day begins (six A.M.) all necessary
activities required to implement the measures should be completed. In the
second half, attention is turned to enforcement and surveillance which con-
tinue into the afternoon of the episode day.
Termination Phase
In the morning or afternoon of the episode day, as the meteorologist
compiles his forecast for the next day, the third phase of the operation
begins. In this phase, officials must determine whether to continue control
into the next day or to terminate control. At the same time, they should
continue to oversee the enforcement of the measures already implemented.
The time constraints for this phase of the activities are similar to those
of the initiation phase.
144
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REFERENCES - CHAPTER FOUR
1. Adrian, Robert, California Air Resources Board, Personal Communication,
September 1973.
2. Ayerson, R., Surveillance and Analysis Division, EPA-Region IX,
Personal Communication, September 1973.
3. California State Office of Emergency Services, Air Pollution Emergency
Traffic Control Planning Committee, Traffic Abatement Plan for Air
Pollution Episodes, 1973.
4. California Transportation Agency, Department of Public Works, Division
of Highways-07, Los Angeles Area Freeway Surveillance and Control
Project, 1973.
5. California Transportation Agency, Department of Public Works, Division
of Highways-07, Los Angeles Area Freeway Surveillance and Control
Project Service Programs, 1972
6. Clean Air Act of 1970, "Clean Air Amendment," (P.L. 91-604).
7. County Air Pollution Districts, Personal Communications, September 1973.
8. Croke, E. J., e_t aj_, Chicago Air Pollution Systems Analysis Program,
Fourth Quarterly Progress Report, Argonne National Laboratory,
ANL/ES-CC-004, pp. 226-250.
9. Davidson, Arthur, Meteorologist - Los Angeles County Air Pollution
Control District, Personal Communication, September 1973.
10. Duckworth, Spencer, Meteorologist - California Air Resources Board,
Personal Communication, September 1973.
11. Foon, Julian, Data Processing - Los Angeles County Air Pollution
District, Personal Communication, September 1973.
12. Garetz, William, Surveillance and Analysis Division, EPA-Region IX,
Personal Communication, September 1973.
13. Hernandez, Tony, Acting Director of Technical Services - Riverside
County Air Pollution Control District, Personal Communication,
September 1973.
145
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14. Hopper, Charlotte, Meteorologist - EPA-Region IX, San Francisco,
Personal Communication, September 1973.
15. Kauper, Erwin, Consulting Meteorologist - Riverside County Air
Pollution Control District, Personal Communication, September 1973.
16. Kinosian, John, Director of Technical Services, California Air
Resources Board, Personal 'Communication, September 1973.
17. Leonard, Robert, Enforcement Division - California Air Resources
Board, Personal Communication, September 1973.
18. Los Angeles County Air Pollution Control District, Smog Alerts - School
and Health Smog Warnings, May 1972.
19. Los Angeles County Air Pollution Control District, Rules and Regulations,
Part VII.
20. Lust, Don, Air Pollution Meteorologist - National Weather Service,
Personal Communication, September 1973.
21. McMullen, Robert, Meteorologist, California Air Resources Board,
Personal Communication, September 1973.
22. Riverside County Air Pollution Control District, Personal Communication,
September 1973.
23. State of California. Health and Safety Code, Division 20, Chapter 2.
24. State of California, Health and Safety Code, Division 26,
"Mulford-Carrel! Air Resources Act".
25. State of California, Government Code, Title 2, Division 1, Chapter 7,
"California Emergency Services Act."
26. Taylor, Earl, Meteorologist - Ventura County Air Pollution Control
District, Personal Communication, September 1973.
27. Tuff, Douglas, Ventura County Air Pollution Control District, Personal
Communication, September 1973.
28. United States Environmental Protection Agency, Region-IX, Regional
Emergency Operations Control Center Operations Manual.
29. Wachtenheim, A. and Keith, R., "Forecasting Ozone Maxima for Los Angeles
County; Los Angeles County Air Pollution Control District Paper #69-78,
June 1969.
30. Wells, Ora, Director of Enforcement - Orance County Air Pollution
Control District, Personal Communication, September 1973.
31. Zeldin, Mel, Meteorologist - San Bernardino County Air Pollution
Control District, Personal Communication, September 1973.
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5.0 SUMMARY OF ALTERNATIVE CONTROL MEASURE EVALUATIONS
The following sections present summaries of the control measure
evaluations performed during this study. Included in each summary is an
assessment of the technical effectiveness, institutional obstacles, and
socio-economic impacts associated with each measure. The control measures
fall into two general classes — stationary source controls (Section 5.1)
and traffic abatement controls (Section 5.2). In an attempt to be concise
and to provide a uniform format for evaluating the control measures, each
summary has been given in tabular form. Table 5.1 gives a brief explana-
tion of the categories included in the evaluation. Results are given in
Tables 5.2 and 5.4. Basically, the assessments are organized as follows:
CONTROL MEASURE EVALUATION SUMMARY
•
I. Control Measure Description
A. General
B. Implementation Procedure
C. Enforcement Plan
II. Technical Effectiveness
A. Total VMT Reduction (Vehicular Controls Only)
B. Total Emissions Reduction
III. Institutional Obstacles
A. Implementation
B. Administrative Cost
C. Enforcement Procedure
147
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Table 5.1 DESCRIPTION OF THE CATEGORIES FOR CONTROL MEASURE EVALUATION
CONTROL MEASURE NO.
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
CO
General Description: Overall des-
cription of control measure, who
it affects and under what con-
ditions .
Implementation Procedure: Des-
cription of key steps in imple-
mentation of the control measure.
For the most part, actions to be
taken to establish the necessary
regulations or in case of impend-
ing alert.
Enforcement Plan: Description
of program envisioned.for sur-
veillance, monitoring, and
enforcement of the controls.
Total VMT Reduction: Total re-
duction anticipated in VMT and
a breakdown of which types of
vehicles are affected by the
control measure.
Total Emissions Reduction: Re-
duction expected in emissions
of RHC, CO, and NO . Percentage
expressed as a fraction of the
total emission inventory. The
effect on RHC emissions from the
filling of vehicle gas tanks at
service stations is included in
the reduction estimate.
Implementation: Discussion of
obstacles anticipated in imple-
mentation of the control measure.
Depending on the measure, these
are expected to range from minimal
to moderate to signi ficant to sub-
stantial , in increasing difficulty.
Direct Economic Cost: Cost
incurred by the community in
terms of loss wages, salaries,
Business, and productivity.
Other costs include various
taxes not collected.
Administrative Cost: Estimate of
cost required to establish necess-
ary personnel, paperwork, media
campaign, etc. to administer the
program. Time, money, and labor
costs will range from minor to
moderate to high expenditures.
Other Cost Considerations: In-
cludes decreased efficiency of
business or governmental
operations, inconvenience and
nuisance costs of foregone or
wasted trips, lost opportunities,
etc.
Enforcement Procedure: Problems
envisioned in enforcing control
measure assuming prior implemen-
tation. Included are problems of
effective surveillance and mon-
itoring. Range given from minimal
to substantial.
Equity: Deals with issue of dis-
crimination among certain groups,
companies, etc. Can be either
direct (intentional) or indirect
(unintentional, subtle).
-------
IV. Socio-Economic Impacts
A. Direct Economic Impacts
B. Other Cost Considerations
C. Equity
Critical to the successfulness of an abatement strategy is the technical
effectiveness of each control measure. Detailed calculations of the VMT
reductions associated with traffic abatement control measures are given in
Appendix D.
5.1 EVALUATION OF STATIONARY SOURCE EPISODE CONTROL MEASURES
Stationary sources, excluding automobile tank filling, accounted for
approximately 14 percent of the total RHC emissions during 1973, (See Table 2.5)
For purposes of reducing these emissions during an episode alert, a number of
control measures offer some potential. The three evaluated in this section
appear to be the most promising:
1) Ban Filling of Underground Service Station Tanks
2) Shut Down Major Point Sources
3) Shut Down Major Point Sources and Other APCD Designated
Categories (Rule 155.2)
a) No Exceptions Granted
b) Review Committee Established - Exemptions Allowed Upon
Approval of Review Committee
Table 5.2 presents a brief summary of these measures. Although minor,
these source categories do contribute a significant amount of emissions -- 2
to 4 percent each of the total RHC. Despite relatively equal contributions
from these source categories, substantial differences exist in both the
149
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Table 5.2 EVALUATION OF STATIONARY SOURCE EPISODE CONTROL MEASURES
CONTROL MEASURE MO. 1
Ban Filling of Underground
Service Station Tanks
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
General Description:
Prior to and during an emergency
episode, the filling of under-
ground service station tanks
would be prohibited (except for
those with vapor recovery systems)
Implementation Procedure:
1) Obtain a complete listing of
all service stations in the
area and all bulk terminals
serving them; notify both
groups of the proposed control
regulations.
2) Exempt service stations (i.e.
those with vapor recovery sys-
tems) must apply for and have
received permission to fill
tanks during an alert.
3) Establish communication chan-
nels to be used during alert.
Enforcement Plan:
1) Organize teams to be used for
random surveillance and moni-
toring of the program.
2) Violations of the filling ban
to be cited and subject to
fine.
Emission Reduction:
(Percent of Total)
RHC
CO
NOy
Implementation: Moderate.
Direct Economic Cost: Minor.
Dependent on large part on coope-
ration of service station dealers
and bulk terminal operators.
Strong private interest at work,
i.e. oil companies. Complaints of
discrimination likely with finger
pointing to the automobiles as
source of pollution. Shut down
not expected to be overly dis-
ruptive.
Only a fraction of service
stations would be affected, and
presumably little reduction in
gasoline sales would result.
Largest impact would be to spec-
ific stations "caught" without
gasoline for the day(s).
Administrative Cost: Moderate.
Mainly cost of obtaining lists and
informing operators of service
stations and terminals of control
measure. Cost also associated
with reviewing and granting
exemptions and organizing required
communication links.
Other Cost Considerations:
Service stations caught without
gasoline would also lose business
in other retail areas (e.g.
servicing, auto accessories,
repairs).
Enforcement Procedure:
With approximately 15,000 service
stations in the basin, monitoring
could be a very formidable task.
It appears easier to monitor bulk
terminals. Overall, a reasonable
enforcement procedure could be
developed.
Equity:
Singles out service stations as a
potential stationary source for
control. Furthermore, it affects
older service stations since only
newer stations are likely to be
equipped with vapor recovery sys-
tems.
-------
Table 5.2 EVALUATION OF STATIONARY SOURCE EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. Z
Shut Down Major RHC Point Sources
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
General Description:
During an emergency episode, all
major RHC point sources, as
defined by the EPA and listed
by the APCD, to shut down.
Implementation Procedure:
1) Require all companies listed
by the APCD as major RHC point
sources to submit emergency
abatement plans for review
and approval.
2) Establish communication
channels for use in notifying
affected companies.
Emission Reduction:
(Percent of Total)
RHC
Enforcement Plan:
1) Organize surveillance and
monftorfng teams for random
inspections during alert
period to ensure compliance.
2) Offenders to be cited and
subject to fines. Blatant
offenses subject to legal
cease and desist orders.
CO
NOV
Implementation: Substantial.
Major resistance to be expected by
nearly all firms. Certain indus-
tries, e.g. refineries, require
several days to start up and shut
down and emit more pollutants at
these times than under normal
operations. Lobbying interests of
these groups should not be under-
estimated in the political arena.
Direct Economic Cost: Variable.
Dependent on compliance received
from affected companies. Strictly
enforced, the economic impact of
curtailed production at many of
these facilities would be quite
high. In some cases a. complete
shutdown disturbs several days
because of down and up time.
Administrative Cost: Moderate to
Other Cost Considerations:
High.
Cost of enlisting cooperation of
companies affected, obtaining
abatement plans, reviewing and
approving abatement plans, etc.
will be considerable. Substantial
effort will be required to "sell"
this program.
In some instances, the costs are
disproportionate to actual shut
down time. For example, a few
hours disruption in a refinery may
upset the routine for several days.
For products already in short
demand, e.g. gasoline, such an
inconvenience may be more costly
than dollar value of the goods
lost.
Enforcement Procedure: Substantial.
While only about twenty companies
are affected, they represent many
of the wealthiest and most influen-
tial groups. Two main problems
will be:
1) conscious violation of companies
willing to pay fines and
2) obtaining cease and desist court
orders in time to make a percep-
table difference in pollution.
Equity:
Singles out the major point
sources while not controlling
many other significant source
categories.
-------
Table 5.2 EVALUATION OF STATIONARY SOURCE EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 3a
Shut Down Major Point Sources & Othe
APCODesignated Categories - No
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
cn
ro
ueneral Description:
During an emergency episode, the
following facilities would be
shut down:
1) All major RHC point sources as
defined by the EPA, and
2) All other facilities covered
by the LACAPCD's Rule 155.2
Implementation Procedure:
1) Obtain complete listing of all
affected facilities from the
local APCD, as well as shut
down plans developed for
APCD emergency alert program.
2) Establish communication chan-
nels for use in notifying
affected companies. Effort
would be minimized by coordi-
nating efforts with the APCD.
Enforcement Plan:
1) Organize surveillance and moni-
toring teams for random
inspections during alert
period to ensure compliance.
2} Offenders to be cited and sub-
jected to fines. Obvious and
intentional violations subject
to legal cease and desist
orders.
Total VMT Reduction:
Emission Reduction:
(Percent of Total]
RHC
CO
NOV
Implementation: Substantial.
Direct Economic Cost: Variable
Major resistance expected from
nearTy every firm and private
interest involved. Problem of
rapid shut down in some industries
e.g. refineries) which require
several days to close down. Close
cooperation and support required
from local APCD to effectively
implement this control measure.
Dependent on compliance and
cooperation of the affected
facilities. Strictly enforced,
the economic impact of curtailed
production at many of these
facilities would be quite high.
In numerous instances, a complete
shut down disturbs several days
due to start up time.
Administrative Cost: High.
A large number of facilities are
affected requiring a very good and
rapid communication system.
Assisting and ensuring the
development of company abatement
plans will be a formidable task.
Other Cost Considerations:
Many of the disruptions and in-
conveniences far exceed the simple
dollar value of the goods.
Enforcement Procedure: Substantial
Since so many companies are
affected, successful implemen-
tation is largely dependent on
cooperation of the companies.
Violations would be difficult to
detect and monitor. Many com-
panies might be willing to pay
the fines imposed rather than
shut down.
Equity:
Focuses on major point sources
and other APCD categories for
control while not controlling
many other smaller sources
which also make significant
contributions.
-------
Table 5.2 EVALUATION OF STATIONARY SOURCE EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 3b
Shut Down Major Potnt Sources &
Qther APCD Designated Categories
t) esc nation:
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
cn
CO
During an emergency episode, the
following facilities would be
shut down, unless prior approval
for exemption had been granted.
Such exemptions would be reviewed
and granted by a review committee:
1) All major potnt sources as
defined by the EPA, and
2) All other facilities covered
by the LACAPCD's Rule 155.2
(see LACAPCD Rules and
Regulations).
Implementation Procedure:
1) Obtain complete listing of all
affected facilities from the
local APCD, as well as shut
down plans developed for APCD
emergency alert program.
2) Establish communication chan-
nels for use in notifying
affected companies. Effort
would be minimized by coordi-
nating efforts with the APCD.
3) Establish review committee for
evaluating request for
exemption to abatement actions
Enforcement Plan:
1) Organize surveillance and moni
toring teams for random
inspections during alert
period to ensure compliance.
2) Offenders to be cited and sub-
ject to fines. Obvious and
intentional violations subject
to legal cease and desist
orders.
Total VMT Reduction:
Emission Reduction:
(Percent of Total]
RHC
CO
N0y
Implementation: Substantial
Major resistance expected from
nearly every firm and private
interest involved. Problem of
rapid shut down in some industries
(e.g. refineries) which require
several days to close down. Close
cooperation and support required
from local APCD to effectively
implement this control measure.
Direct Economic Cost: Variable
Dependent on compliance and
cooperation of the affected
facilities. Strictly enforced,
the economic impact of curtailed
production at many of these
facilities would be quite high.
In numerous instances, a complete
shut down disturbs several days
due to start up time. The impacts
are lessened considerably if
exceptions are granted to hardship
cases, e.g. cases where shutdown
for one day will disrupt activities
nvpr ypry Inng ppHnHc .
Administrative Cost: High
A large number of facilities are
affected requiring a very good and
rapid communication system.
Assisting and ensuring the
development of company abate-
ment plans will be a formidable
task, as will be the review
for exemptions requested.
Other Cost Considerations:
Many of the disruptions and in-
conveniences far exceed the simple
dollar value of the goods.
Enforcement Procedure: Substantial
Since so many companies are
affected, successful implemen-
tation is largely dependent on
cooperation of the companies.
Violations would be difficult to
detect and monitor. Many com-
panies might be willing to pay
the fines imposed rather than
shut down.
Focuses on major point sources and
other APCD categories for control
while not controlling many other
smaller sources which also make
significant contributions.
Questions of inequity are also
possible in granting of exemp-
tions. Special interests and
lobbying groups may influence
review committee.
-------
institutional obstacles and socio-economic costs associated with the
respective control measures.
Controlling the filling of underground service station tanks, primarily
through control at the 50 or so bulk terminals within the basin, appears as
one of the more equitable and least disruptive control measures under consid-
eration. While the service stations are isolated for control, the impacts
are expected to be minor for several reasons:
e - Among service stations, there is no intended discrimination,
since the normal filling schedules are relatively fixed on
varying days and times of the week.
» The number of stations affected is expected to be a small
percentage of the total since under normal conditions,
service stations get filled about once or twice a week.
Most stations fill their underground tank with approxi-
mately one day's supply still in the tanks. Thus, in
case of an alert, it is expected that only a fraction of
stations would be scheduled for a refill and significantly
less would actually be completely depleted and have to shut
down during the day.
e Sufficient gasoline supplies would be available , v -
basinwide so that any motorists wishing to purchase
gasoline could do so.
The control of "major RHC point sources," as defined by the EPA and
listed by the Los Angeles APCD, presents a number of problems related to
institutional obstacles, technical difficulties, and socio-economic impacts.
The companies affected represent many of the most influential groups in the
area; any plans to shut down their operations can be expected to stir up
major opposition from private interests. In addition, certain types of
operations, e.g. refineries, require more than a day to either completely
shut down or to start up. From a technical standpoint, attempts to close
these facilities down on very short notice could result in more emissions
being emitted due to the inherent inefficiencies associated with these
procedures, [3].
154
-------
In addition to the "major RHC point sources" (of which there are
approximately 20), other smaller but significant RHC sources have been
listed by the L.A. County APCD as important emitters, (see Table 3.2).
If these source categories, named in Rule 155.2 (L.A. County's Rules and
Regulations), were also effectively controlled, approximately 4 percent
of the total RHC would be eliminated. For reasons analogous to those
given under "major point source" control, institutional and technical
problems arise with any attempts to completely shut down all the companies
affected by Rule 155.2 on short notice, i.e. granting no exceptions.
Because of these difficulties, a more acceptable approach to controlling
these sources would be to establish an Emergency Review Board to review
applications for waiver or exemption to episode controls. Since the
major sources and other listed companies presently file for permits to
operate, an additional question could be added to the normal permit
petition to allow certain facilities to request a waiver to the shut down
proceedings during an alert. The requests would be reviewed and granted
only in case of technological problems (e.g. lengthy shut down or start
up times, emitting more pollutants during a shut down) or for companies
providing essential goods and services. While reducing the overall effec-
tiveness of this control slightly (estimated now to reduce total RHC by
approximately 3 percent), significant gains are made in reducing the socio-
economic impacts of the control measure.
In conclusion, it is recommended that two stationary source control
measures be incorporated into the final episode control plan:
• Ban filling of underground service station tanks
o Shut down major point sources and other APCD designated
categories (Rule 155.2) with exemptions granted upon
approval of a review committee.
155
-------
This recommendation is based on an attempt to impose reasonably effective
technical controls with as modest a disruption and socio-economic impact as
possible. It also attempts to trade-off the ease of implementation (i.e.
institutional obstacles) with control strategy complexity (i.e. number of
control measures). Successfully implemented, it is estimated that approxi-
mately 7 percent of the total RHC in the basin can be eliminated.
5.2 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES
Gasoline powered motor vehicles, including auto tank filling at service
stations, accounted for 77% of the RHC emissions in the Metropolitan
Los Angeles AQCR during 1973, (see Table 2.5). Numerous alternative traffic
abatement measures can potentially be used to limit emissions from this
major source during air pollution episodes. Among these are twenty-four
which have been evaluated in this study and which include those considered
in the OES Report and the EPA Region IX Study, (see Table 5.3), [1], [2].
Table 5.4 presents a qualitative evaluation of the alternative traffic
abatement measures. The control measures are separated into three groups:
Direct Controls on Traffic (Control Measures 1-10), Controls on Traffic
Support Facilities (Control Measures 11-15), and Controls on Incentives
to Travel (Control Measures 16-24). As noted previously, most of these
evaluations represent a qualitative summary of the measures based upon
available information. The VMT reductions associated with each measure are
determined in Appendix D.
Table 5.4 indicates that nearly all traffic abatement measures present
significant institutional obstacles and have quite disruptive socio-economic
impacts. Clearly, though, certain measures will result in more problems than
others. The only measure with good socio-political acceptability is "Voluntary
Abatement", but in reality this turns out to be no control measure at all.
156
-------
DIRECT CONTROLS ON TRAFFIC
1. Voluntary Traffic Abatement
2. Windshield Sticker Program
3. License Plate Lottery
4. Ban Non-Essential Government Vehicles
5. Ban (Private) Fleet Vehicles
6. Ban (Private) Fleet Vehicles and Use of Vehicles for Commercial Purposes
7. Ban All Non-Emergency Traffic
8. Mandatory Car-Pooling on Freeways
9. Mandatory Carpooling on Freeways and Major Thoroughfares
10. Commercial Abatement Schemes
CONTROLS ON TRAFFIC SUPPORT FACILITIES
11. Close Freeways (or Certain Freeway Lanes)
12. Limited Availability of Parking
13. Special Parking Tax
14. Gasoline Rationing
15. Close Gasoline Stations
CONTROLS ON INCENTIVES TO DRIVE
16. Close (Non-Essential) Federal Agencies
17. Close (Non-Essential) Government Agencies (Federal, State & Local)
18. Close Government Contractors
19. Close Shopping Facilities at Regional Shopping Centers (RSC's) and
Central Business Districts (CBD's)
20. Close Recreational Facilities
21. Work Holiday for Major Firms
22. Rotating Work Holiday for Major Firms
23. Operate on Sunday Status
24. Complete Work Holiday With Recreation Closed
157
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES
CONTROL MEASURE NO. 1
Voluntary Traffic Abatement
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
en
00
General Description: An appeal
to the publicfor voluntary car-
pooling, use of public transit,
and a reduction in optional auto
travel; promotion of alternative,
non-polluting forms of travel --
walking, bicycling.
Implementation Procedure:
1) Media compaign to inform public
of the pollution problem and
the necessity of taking control
action. In particular, speci-
fic and detailed health warn-
ings are necessary for suscep-
tible groups—young, old,
asthmatics, etc.
2) Special announcements informing
the public of an impending
episode and urging them to take
appropriate steps.
3) Public service spots on TV and
radio to assist people in
arranging carpools, etc,
Enforcement Plan:
None - strictly a voluntary
program.
Total VMT Reduction:
Negligible to 5%.
Most likely negligible.
Applicable to LDMV's.
Emission Reduction:
(Percent of Total..]
RHC
CO
negl.-
NO
X
negl.-
Implementation: Minimal.
Direct Economic Cost: Minor.
urrent APCD emergency alert
Drogram needs only to be modified
and extended. Expansion should
emphasize public awareness.
Since control actions are
voluntary, costs incurred are
voluntarily "donated" to air
pollution cause. Voluntary
control cannot be anticipated
to invoke significant response
or economic cost.
Administrative Cost:
Minor.
Other Cost Considerations.: Minor.
Costs result primarily from an
expanded media campaign. Some
costs may be donated by media
stations as a public service.
Program can be readily instituted
with, existing agency organization.
Reasoning for other monetary,
opportunity, or inconvenience
costs similar to above.
Enforcement Procedure: None.
Since the program is voluntary,
no enforcement procedures are
required.
Equity:
Since the program 1s voluntary,
no legal discrimination is
involved.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 2
Windshield Sticker Program
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
in
10
General Description: Window
stickers ot various colors would
be issued to vehicle owners on the
basis of emissions. During an
episode,, and depending on its
severity, traffic bans would be
placed on vehicles with certain
colored stickers. Alternatively,
colors could be issued randomly,
and color bans could be rotated so
as to eliminate discrimination.
Implementation Procedure:
1) Issue window stickers at some
appropriate time during the
year, e.g. during annual
registration.
2) Inform the public as to the
nature of the restrictions
which will be imposed during an
episode.
3) Restrict auto travel on the
basis of windshield sticker
color and episode severity.
Enforcement Plan: [_aw enforce-
ment officers would see that
stickers are indeed displayed
and that vehicles are operated in
accordance to the restrictions.
Offenders subject to citations
and/or fines.
Total VMT Reduction:
Flexible. Maximal is 50-85%
depending on implementation
and enforcement procedures.
Applicable to LDMV's, HDMV's
and diesels.
Emission Reduction:
(Percent of Total]
RHC
45 - 70$
(maximal)
CO
50 -
(maximal)
NO,
35-60^
(maximal',
Implementation: Moderate.
In addition to an extensive media
campaign to inform the public of
the program, an additional layer
of paperwork is added to the
State's Dept. of Motor Vehicles.
A staggered registration system
would ease paperwork bottlenecks,
but create other problems —
adjusting to new system.
Direct Economic Cost: Moderate.
Dependent on number of vehicles
and people affected which is
dependent on the severity of the
episode. Impact primarily on
lost wages and productivity of
individuals and businesses with
no alternative modes of travel.
Administrative Cost: Moderate to
High. Additional incremental
cost for DMV to execute this
program would be significant.
Cost involves organizing
classification system and
exemptions to be allowed,
issuance of stickers and
insuring that the proper
sticker is attached to the
right vehicle.
Other Cost Considerations:
Will have some impact on
reducing the services and
efficiency of public and private
business operations.
Enforcement Procedure: Significant
Two major enforcement problems --
identification of violators and
time required to cite violators.
Identification can only be made
at close range, must differentiate
similar looking stickers, account
for out-of-state vehicles, etc.
Assuming widespread violations,
only a small fraction could ever
be cited.
Equity: Sticker colors based
on emissions discriminate
against poor who own the oldest
vehicles, drive less and for
more essential purposes. Colors
issued randomly are clearly
more equitable in this sense.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 3
License Plate Lottery
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
cr>
O
General Description: All vehicles
with license plates having speci-
fied last digits are banned from
driving during the episode alert.
The effect on traffic reductions
is varied by banning more than
one number, in accordance to the
severity of the pollution problem.
Implementation Procedure:
In the event of an impending
episode, the number(s) on those
cars to be banned is widely
publicized through the media.
Conceivably this could be done
at the beginning of the alert
season, similar to the military's
draft lottery.
Enforcement Plan: Law enforce-
ment officers would ensure that
only allowed vehicles were in
use in accordance to the restric-
tions. Offenders subject to
citations and/or fines. Addi-
tional staffing required during
alert period.
Total VMT Reduction:
Flexible. Maximal is 50-85%
depending on implementation
and enforcement procedures.
Applicable to LDMV's, HDMV's
and diesels.
Emission Reduction:
(Percent of Totalj
RHC
45 - 70
{maximal
CO
50-80*
(maximal)
NOX
35 - 60%
(maximal)
Implementation:
Minimal
Direct Economic Cost: Moderate.
Involves informing the public
sufficiently in advance so that
alternate plans can be made for
those vehicles affected.
Dependent on number of vehicles
and people affected which is
dependent on the severity of the
episode. Impact primarily due
to lost wages and productivity
of individuals and businesses
with no alternative modes of
travel.
Administrative Cost: Minor.
Other Cost Considerations:
Cost of media campaign to inform
the public of the program.
Some impact on reducing
efficiency of business and
governmental operations.
Enforcement Procedure: Significan
Two major problems are identifica-
tion of violators and time re-
quired to issue citations. Only
an insignificant number of viola-
tors could ever be cited due to
the manpower available for enforc
me nt.
Equity: Subtle form of discri-
mination to one car families,
who are more likely to be banned
from auto use than multiple car
families. Since lower income
groups are more likely to own
only one car, this discriminates
against the poor
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 4
Ban Non-Essential Govt. Vehicles
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
CTl
General Description:
All travel by government-owned
vehicles would be banned except
for emergency
Implementation Procedure:
1) A complete description of all
vehicles covered under the
proposed ban would be pub-
lished. Exemptions would be
carefully rev-iewed and allowed
only for critical needs or
services.
2) Operators of all affected
vehicles would be notified in
event of an impending episode.
Enforcement Plan:
1) Cooperation with all agencies
involved would be solicited
and established well in
advance.
2) During an alert, all agencies
would be contacted again to
ensure cooperation and pro-
gram effectiveness.
3) Offenders would be reported
to responsible governmental
agency.
Total VMT Reduction:
1-1/2 percent.
Applicable to LDMV's and
HDMV's.
Emission Reduction:
(Percent of Total!
RHC
CO
NOX
Implementation: Moderate.
Small, well-defined vehicle
population is involved with
established lines of communica-
tion. Key to success of program
is enlisting cooperation of all
agencies involved initially.
Direct communication channels
during alerts should be readily
available and pose no major
problems.
Direct Economic Cost: Minor to
Moderate.
Dependent on number and types
of agencies closed or slowed
down. Losses primarily those
of wages and productivity of
affected individuals.
Administrative Cost: Moderate.
All affected agencies required
to establish contingency or
action plans for alerts. Plans
must be widespread to individuals
actually affected. List of
exempt vehicles or categories
must be established.
Other Cost Considerations:
Decrease in efficiency of
governmental operations.
Secondary impacts accrue to
private businesses who have
to deal with governmental
operations. Inconvenience
and opportunity costs felt
by patrons of affected services.
Enforcement Procedure: Moderate.
Dependent on good faith coopera-
tion and enforcement by local
agencies involved. Consistent
and effective action by agencies
involved appears to pose some
problems
Cost borne primarily by
governmental agencies. Some
cost borne by groups which
must deal with the govern-
mental operations.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 5
Ban (Private) Fleet Vehicles
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
Ol
ro
General Description:
Travel by private fleet vehicles
(10 or more vehicles registered
in one name) would be banned
unless previously exempted.
Examples of exempt categories
might be taxis and transit
vehicles, deliveries of perish-
ables, delivery to essential
services (e.g., hospitals) and
emergency utility services.
implementation Procedure:
1) Arrive at a working definition
of exempt categories or fleets.
2) Establish an exempt fleet
vehicle identification system
e.g. window sticker.
3) Encourage and promote contin-
gency planning by affected
fleets.
4) Establish communication
channels to be used in the
event of an impending episode.
Enforcement Plan:
Law enforcement personnel would
cite operators of fleet vehicles
driving illegally. Other enforce-
ment teams would spot check
establ isnments maintaining large
fleets to ensure compliance with
ban. Violators would be subject
to legal action.
Total VMT Reduction:
5% of LDMV VMT
30% of HDMV VMT
Emission Reduction:
(Percent of Total)
RHC
CO
NO,
Implementation: Moderate.
Direct Economic Cost: Moderate.
Fleet vehicle ownership data
would have to be obtained and
updated from the DMV. All
affected fleets would have to
be notified, exemptions given
where appropriate, and instructed
as to proper response. Soliciting
cooperation from ail groups
appears to pose some problems.
Cost borne by companies whose
fleets are banned and include
loss of business, productivity
of employees, salaries, etc.
Wholesale trade in Los Angeles
County amounts to about $50
mi 11 ion per day.
Administrative Cost: Moderate.
Identifying all fleets, classify-
ing vehicles by exempt status,
informing companies involved of
alert responses. Cost to
companies include contingency
planning with enforcement agency.
Other Cost Considerations:
Loss of goods and services to
individuals and companies
dealing with companies owning
large fleets.
Enforcement Procedure: Moderate
to Significant.
Dependent on cooperation of
affected groups. Problems exist
in recognizing and citing banned
vehicles. Spot checking estab-
lishment lots is difficult, due
to the numerous locations
involved.
Since the program is directed
at fleet owners, it discimi-
nates against this group of
vehicle owners.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 6
Ban (Private) Fleet Vehicles and
Use of Vehicles for Comml. Purpos^j
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
General Description:
Travel by vehicles for commer-
cial purposes would be banned.
This measure essentially extends
the fleet vehicle ban to all
commercial travel. Certain
categories would be exempt (see
"Ban Private Fleet Vehicles").
Total VMT Reduction:
7-102 of LUMV VMT
50 - 75% of HDMV VMT
Depending on enforcement
procedures.
Implementation Procedure:
1) Arrive at a working defini-
i tion of exempt vehicles.
Q-, 2) Establish an exempt vehicle
to identification program.
3) Encourage and promote contin-
gency planning by the affected
vehicle owners.
4) Establish communication
channels to be used in the
event of an impending episode.
Emission Reduction:
(Percent of Total)
RHC
Enforcement Plan:
Law enforcement officers would
site offenders. Alternatively,
spot checks could be made at
select commerical establishments.
CO
10 - 15%
NOV
9 - 13%
Implementation: Significant.
A large scale effort would be
required to properly identify
the vehicles to be affected.
Informing these owners of the
program and soliciting their
cooperation would be a formidable
task.
Direct Economic Cost: High.
Since most businesses would be
at least partially affected,
economic activity in the region
would be greatly reduced.
Daily economic activity in Los
Angeles SMSA is approximately
$160 mi 11 ion.
Administrative Cost: Moderate
to High.
Identifying all vehicles to be
subject to control, granting
exemptions equitably, informing
companies of proper response in
event of an alert, and encourag-
ing public support of the
program would require a
significant level od effort.
Other Cost Considerations:
Since both public and private
business and governmental
operations are affected, a
high inconvenience cost is
incurred by the public for
loss of goods and services.
Enforcement Procedure: Significant)
Main difficulty is one of identi-
fying violators. In some cases,
commercial vehicles are indis-
tinguishable from other vehicles.
Also, some commercial vehicles
are used for private family uses
as wcl1.
Singles out fleets and commer-
cial vehicles for ban, thus
affecting private businesses
heavily. Businesses with large
fleets or auto dependence are
affected most. Large businesses
may suffer more than small ones.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 7
Ban All Non-Emergency Traffic
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
O1
General Description:
Travel by all non-essential
vehicles would be banned.
Transportation related vehicles,
such as buses and taxis would
be exempted. Exceptions would
be reserved primarily for
vehicles used for health and
safety -- fire and police pro-
tection, medical services
(doctor's cars, ambulances), etc
Implementation Procedure:
1) Define categories of vehicles
to be exempted.
2) Establish review committee
for additional vehicles to
be included.
3) Establish identification pro-
gram for all exempt vehicles
(e.g. stickers).
4) Set up communication channels
to be used in the event of
an impending episode.
Enforcement Plan:
Only those vehicles identified as
exempt would be allowed to drive
during the alert. Offenders
would be cited by law enforce-
ment officers and subject to
prosecution and/or fines.
Total VMT Reduction:
50 - 85%, depending on
implementation and enforce-
ment procedures.
Applicable to LDMV's, HDMV
and diesels.
Emission Reduction:
(Percent of Total!
RHC
45 -
CO
50 -
NOX
35 - 60%
Implementation: Moderate to
Significant.
Since all cars are excluded
unless exempted, one would anti-
cipate many individuals applying
for exemptions on the basis of
their "essential" travel. Review
and distribution of exemptions
will be a difficult task. Mas-
sive media campaign for public
would also be required.
Direct Economic Cost: Very High.
Since nearly all businesses
and governmental operations
would be significantly cur-
tailed, economic activity
would be only a fraction of
what it normally is. Costs
could conceivably exceed $100
million for a one day shutdown.
Administrative Cost: Moderate.
Consists mainly of program to
identify key exempt categories,
review requests for exemptions
and publicize program to public
so that contingency planning can
be made.
Other Cost Considerations:
Since public and private
businesses and governmental
operations are affected, a
high social cost for incon-
venience and lost opportunity
is incurred. Impact of fore-
going goods and services
normally offered is very
significant.
Enforcement Procedure: Moderate.
Depends heavily on public co-
operation. !f widespread viola-
tions were to occur, enforcement
manpower would be grossly inade-
quate to cite more than a few
violators. Many short trips
could be expected to be in vio-
lation of the ban.
Costs borne relatively evenly
by public in general. No
obvious economic advantage
given to any individuals or
groups.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURC NO. 8
Mandatory Carpooling on Freeways
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
General Description:
Freeway access and use would be
restricted on the basis of the
number of occupants in the
vehicle. For example, use could
be limited to vehicles with
four or more occupants.
Implementation Procedure:
1) Inform public of details of
~-* the plan (i.e., number of
y, passengers required, vehicles
exempted, etc.)
2) Encourage the public to make
carpooling arrangements prior
to the episode.
3) Establish communication
channels to be used prior to
alert.
4) Organize surveillance system
to monitor program effective-
ness .
Enforcement Plan:
1) Establish enforcement plan --
personnel required, assign-
ments, access points to be
monitored.
2) Offenders would be subject to
citations and/or fines.
Total VMT Reduction:
2 - 5% (two people per
vehicle),
4 - 10% (three people per
vehicle), depending on
implementation and enforce-
ment procedures.
Applicable to LDMV's
Emission Reduction:
(Percent of Total]
RHC
1 - 37o
(2 people)
2-1/2 - 6%
(3 people)
CO
1-1/2 - 47(
(2 people)
3-1/2 -
8-1/2%
(3 people)
N0y
1 - 3%
(2 people)
2-1/2 - £%
(3 people
Implementation: Moderate.
Fairly extensive media campaign
would be required to inform the
public initially and also prior
to an impending episode alert.
Direct Economic Cost: Minor
Sufficient flexibility exists
in the program that most people
would not be significantly
impacted economically.
Administrative Cost: Minor to
Moderate.
Dependent on the extent of pub-
licity necessary to adequately
inform the public of the program.
Other Cost Considerations:
Inconvenience of finding car-
poolers or alternative travel
route will probably exceed
economic cost incurred.
Enforcement Procedure: Moderate
to Significant.
Extensive monitoring of approxi-
mately 1500 entrance points to
freeway system needed for effec-
tive enforcement. Widespread
violations could not be stopped
due to limited enforcement man-
power
No obvious or implied discri-
mination associated with this
control measure.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 9
Mandatory Carpooling on Freeways
-and Major Thoroughfares
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
cn
cr>
General Description:
Travel on freeways and major
thoroughfares would be banned
on the basis of vehicle occup-
ancy. For example, use of main
arteries and freeways could be
reserved for vehicles with three
or more persons.
Implementation Procedure:
1) Inform public of details of
the plan (i.e. number of
passengers required, vehicles
exempted, etc.)
2) Encourage public to make car-
pooling arrangements prior
to the episode.
3) Establish communication
channels to be used for
impending alerts.
4} Organize surveillance system
to monitor program effective-
ness.
Enforcement Plan:
1) Determine personnel required,
assignments and access points
to be monitored in case of
alert.
2) Offenders to be subject to
citations and/or fines.
Total VMT Reduction:
7 - 15% (2 persons per
vehicle),
15 - 35% (3 persons per
vehicle), depending on
implementation and enforce-
ment procedures.
Applicable to LDMV's.
Emission Reduction:
(Percent of Total)
RHC
4 - 9%
(2 people)
9 - 22%
(3 people)
CO
6 - 13%
(2 people)
13 - 3C%
(3 people)
NOv
4 - .9%
(2 people)
9 - 22%
(3 people)
Implementation: Moderate to
Significant.
Extensive media campaign required
to inform public of program,
their options during an alert,
etc. Publicity required to make
program elements and objectives
know as well as during an impend-
ing alert.
Direct Economic Cost: Minor to
Moderate.
Dependent largely on public
response to control. Flexi-
bility still exists in the
system to accomplish most trip
purposes, if sufficiently moti-
vated. Costs likely to be
proportional to trips foregone
by public.
Administrative Cost: Moderate to
High.
In addition to costs for media
campaign considerable effort
would be required to determine
which main arteries are to be
included in the traffic ban.
Other Cost Considerations:
Social costs incurred will be
high due to many "loopholes"
which exist in this measure.
Nuisances created will encour-
age violations; limited enforce-
ment capability will largely
be wasted since it will be
grossly inadequate for the
task.
Enforcement Procedure: Substantial
Monitoring this program would
require tremendous manpower
requirements, not available
from normal law enforcement
agencies. Violations would be
widespread and either largely
undetected or ignored.
No obvious or implied discrimi-
nation associated with this
control measure.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 10
Commercial Abatement Schemes
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
CTl
General Description:
A traffic abatement plan would
be required from business,
industrial, and commercial forms
to reduce their work related VMT
by a specified amount. These
plans could then be implemented
on a programmed basis depending
on the severity of the episode.
Total VMT Reduction:
Flexible.
Maximum: 35%, calling
"Work Holidays"
0-15%*, keeping business
operational
*depending on enforcement
and implementation
procedures.
Applicable to LDMV's and
HDMV's.
Implementation Procedure:
1) Establish criteria for firms
to be affected by control
measure.
2) Require traffic abatement plan
be submitted for review and
approval according to estab-
lished criteria.
3) Set up review committee to
approve/disapprove plans.
4) Assist companies in writing,
plans and solicit their active
support in case of implementa-
tion.
Emission Reduction:
(Percent of Total]
RHC
Enforcement Plan:
1) Set up enforcement teams to be
sent out into the field for
spot checking individual firms
for compliance.
2) Companies found to be in vio-
lation would be subject to
citations and/or fines.
0-10%
(business
kept oper-
ational )
CO
0 - 13%
(business
kept oper-
ational )
0-10%
business
kept oper-
ational)
NOX
Implementation: Significant.
A large effort would be required
to define companies affected,
inform them of plan requirements,
assist them in writing abatement
plans, review plans, correct
deficiencies, etc.
Direct Economic Cost: Minor to
Moderate.
Dependent on good faith response
of companies affected. Also,
dependent on the severity of
control required and the con-
tingency plans developed by
the firms.
Administrative Cost: High.
Other Cost Considerations:
In addition to publicizing the
program, the actual reviews,
approvals/disapprovals would
require considerable effort. In
all likelihood, many companies
would not submit plans placing
additional strain on the enforce-
ment agency.
Could reduce the efficiency of
business operations involved;
resulting in some degree of
inconvenience.
Enforcement Procedure:
Given all plans were submitted
and approved (a formidable enfor-
cement task in itself), actual
monitoring during an episode
would be extremely difficult.
Implementation is largely depen-
dent on good faith action of
companies. Violators would be
difficult to detect.
Singles out work related travel
in commercial institutions of
a given size, thereby impacting
large businesses the most.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 11
Close Freeways (or Certain Free-
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
General Description:
Access to freeways (or certain
freeway lanes) would be closed
to all but emergency and trans-
portation related vehicles.
Implementation Procedure:
1) Develop media campaign to
, inform public of control
en proposed.
0° 2) Determine exempt categories
or vehicles not subject to
ban.
3) Establish communication'
channels to be used for
impending episode.
4) Organize surveillance and
monitoring program -- check
points, personnel required,
etc.
Enforcement Plan:
1) Establish enforcement teams
to either prevent entrance
to freeways or patrol free-
ways during alert for viola-
tions.
2) Offenders to be subject to
citations and/or fines.
Total VMT Reduction:
Doubtful, very possibly an
increase.
Emission Reduction:
(Percent of Total)
RHC
CO
N0y
Implementation: Moderate.
Direct Economic Cost: Minor.
Fairly extensive media campaign
required to inform the public
initially of the program and also
prior to an impending alert.
Closing freeways leaves exten-
sive street system available
for travel. Most travel may
take longer or be less direct
but will still take place on
surface streets, implying a
minor economic impact will
result.
Administrative Cost: Minor to
Moderate.
Dependent on the extent of pub-
licity necessary to adequately
inform the public of the program.
Also, cost of setting up surveil-
lance, monitoring, and enforce-
ment procedures.
Other Cost Considerations:
High social cost from nuisance
and inconvenience of having
to use surface streets for
travel. Increased congestion,
noise and accidents likely to
take place.
Enforcement Procedure: Moderate
to Significant.
Extensive monitoring of approxi-
mately 1500 entrance points or
of 700 some miles of freeway.
More difficult to enforce if
certain lanes are to be designate
Subtle form of discrimination
to those more dependent on
freeways, e.g., commuters
who travel long distances,
businesses who make frequent,
long deliveries, etc.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 12
Limit Availability of Parking
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
General Description:
The supply of on and off street
parking would be limited to a
previously determined level as
an incentive for carpooling and
the use of public transit. For
example, off-street parking
facilities could only fill to
1/4 their capacity and all on-
street parking would be pro-
hibited.
Implementation Procedure:
1) Establish which facilities
(and streets) are to be
affected and to what extent.
2) Notify off-street parkirvg
lots of the proposed plans.
3) Encourage alternative modes
of travel.
Enforcement Plan:
Law enforcement personnel to
spot check parking facilities
to ensure compliance. Offenders
to be subject to citations and/
or fines.
Total VMT Reduction:
Doubtful, very possibly
an increase
Emission Reduction:
(Percent of Total}
RHC
CO
N0y
Implementation: Significant.
Thousands of off-street facili-
ties exist and many more spaces
exist on street. Determining
how and what facilities should
be controlled and to what extent
will be a formidable task.
Direct Economic Cost: Moderate.
Parking revenues in the Los
Angeles CBD exceed $100,000
daily. Adding other parking
revenues collected as well as
economic activity curtailed
due to lack of parking, the
costs become significant.
Administrative Cost: High.
Widespread publicity of the pro-
gram, contacting affected facili-
ties, and enlisting active sup-
port of this program will be
most difficult.
Other Cost Considerations:
Lack of parking will obviously
decrease the efficiency of
business operations, who must
find alternative transportation,
forego the trip, or look for
other parking.
Enforcement Procedure: Significant
Due to the large number of faci-
lities involved, compliance is
heavily dependent on good faith
cooperation. Large scale resist-
ance to this measure would make
enforcement practically
impossible.
Parking lot owners singled
out to bear large cost; also,
subtle form of discrimination
to businesses which place
heavy reliance on good park-
ing facilities for attracting
customers, i.e., shopping
centers.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURC NO. 13
Special Parking Tax
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
Genera] Description:
A special parking tax on sur-
charge would be levied on
motorists during the episode.
The tax would be high enough
to encourage use of alternate
transportation or to carpool.
Implementation Procedure:
1) All on-street and metered
parking would be banned
during an alert episode.
2) All public and private lot
operators would be required
to collect a predetermined
tax for each vehicle entering
the parking facilities.
Revenues collected would go
to the government, much like
a sales tax.
Enforcement Plan:
1) Enforcement and surveillance
teams would be sent out to
spot check collection proceed-
ings and note revenues being
collected.
2) Other teams would ensure
revenues were properly turned
over to the government.
Total VMT Reduction:
Very uncertain. Possibly
as much as 20% but
possibly negligible.
Emission Reduction:
(Percent of Total;
RHC
0 -
CO
0 - 17%
NO,
0 - 12%
Implementation: Significant to
Substantial.
Many problems are foreseen for
each phase of the implementa-
tion -- notifying all parking
lots of the program, ensuring
collection of parking tax,
turning over all collected
revenues.
Direct Economic Cost: Moderate.
Dependent on public response
to incentive. If a significant
VMT reduction was achieved, the
economic impact on businesses
could be high.
Administrative Cost: High.
Many additional layers of paper-
work required to properly execute
this program. Could potentially
become a bureaucratic nightmare.
Other Cost Considerations:
Dependent on public response
to incentive. For large VMT
reductions, the social costs
of trips foregone or lost
opportunities would be high.
If many chose to pay the tax,
the economic cost would be
more appreciable.
Enforcement Procedure: Substantial
Many ways to violate this pro-
gram, most of which are undetect-
able with the normal enforcement
agencies. Widespread corruption
could be expected with any signi-
ficant sums of money collected.
Clearly discriminates against
the poor who are least able
to afford additional auto
operating costs.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO.
Gasoline Rationing
General Description: Prior to
and during an emergency episode,
the purchase and sale of gasoline
would be limited. A variety of
actual implementation procedures
are available.
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
Implementation Procedure:
1) Establish distribution system
for rationing coupons to be
used to purchase gasoline
during an alert.
2) Initiate mass media campaign
to acquaint public to controls
proposed.
3) Establish communication
channels to gasoline dealers
in case of impending episode.
Enforcement Plan:
1) Organize surveillance teams
to ensure compliance to regu-
lations during alerts.
2) Enlist support by major dis-
tributors to implement controls
3) Violators to be subject to
citations and/or fines.
Total VMT Reduction:
Flexible
Maximum: 10% 1st day
20% 2nd day
50% 3rd day
Emission Reduction:
(Percent of Total)
RHC
Maximum
11 Day 1
14% Day 2
35% Day 3
Maximum
% Day 1
% Day 2
47% Day 3
CO
NOX
Maximum
7% Day 1
14% Day 2
35% Day 3
Implementation: Substantial.
Large effort would be required
to set up the program, distribute
coupons, inform the public and
service stations, etc.
Direct Economic Cost: Largely
dependent on public response to
the measure. A short rationing
program cannot be expected to
curtail much travel. A longer
rationing program could severly
affect some businesses. In any
case, gasoline sales would suffer.
Administrative Cost: High.
An entire new program would have
to be organized, with significant
amounts of bookkeeping, paperwork,
etc.
Other Cost Considerations: High
social cost expected from the
creation of illegal activities,
e.g. counterfeiting coupons, black-
markets, hoarding gasoline.
Enforcement Procedure: Substantial
Prior experience during World War
II has shown the difficulty of
attempting to enforce such a
measure. More than 6000 service
stations exist in L.A. County pre-
senting a formidable enforcement
problem.
Equity: Dependent on implemen-
tation procedures. Rationing
schemes generally impact the
poor most since they are not
as likely to resort to black
market supplies, bootleggers,
etc. Service station owners are
clearly discriminated against.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURC NO. 15
Close Gasoline Stations
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
General Description: Retail
gasoline service outlets would
be closed during an episode.
Total VMT Reduction:
10% 1st day
20% 2nd day
50% 3rd day
Applicable to LDMV's and HDMV's.
Implementation Procedure:
1)
2}
3)
Obtain complete listing of
affected stores.
Have media campaign to these
owners to instruct them of
their required response during
an alert.
Establish communication pro-
cedures to be used in case of
an impending alert.
Emission Reduction:
(Percent of Total)
RHC
Enforcement Plan:
1) Organize surveillance and
enforcement teams to be
used to monitor compliance
to the control regulations.
2) Violators to be subject to
citations and/or fines.
7% Day 1
14% Day 2
35% Day 3
CO
9% Day 1
19% Day 2
47% Day 3
NOX
7% Day 1
14% Day 2
35% Day 3
Implementation: Moderate to
Significant. Major effort required
would be publicity campaign to in-
form service station owners and
public of the program.
Direct Economic Cost: Moderate.
Cost accrue primarily from lost
of business at service stations --
gasoline sales, repair services,
auto accessories, etc. Presumably
much of this would be made up when
the service stations reopened.
Administrative Cost: Moderate.
Involves primarily cost of in-
forming all the stations involved
and establishing proper communi-
cation channels for execution of
the plan.
Other Cost Considerations: Loss
of service station related
services offered. Could result
in additional safety hazards.
Enforcement Procedure: Significan
Due to the large number of
stations involved, compliance
would be largely dependent on
good faith, cooperation of
service stations. It would
be difficult to detect more
than a few violations.
Equity: Singles out service
station owners for control ; cost
borne almost exclusively by this
group.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURC NO. 16
Close (Non-Essential) Federal
Agencies
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
co
General Description: A general
work holiday would be in force for
federal employees performing non-
essential services (i.e. not
emergency, health, or safety
related).
Total VMT Reduction:
Applicable to LDMV's.
Implementation Procedure:
1) A working definition of
agencies and personnel to be
affected would be drafted.
Agencies would be informed
of the emergency actions pro-
posed.
2) Cooperation in the program
would be actively solicited
and encouraged to ensure pro-
gram effectiveness.
3) Establish communication chan-
nels to be used in case of
alert.
Emission Reduction:
(Percent of Total)
RHC
Enforcement Plan:
Surveillance teams would be
organized to spot check com-
pliance during the episode.
CO
NOX
Implementation: Moderate.
Primarily a problem of notifying
and coordinating the implemen-
tation by the affected agencies.
Good communication and cooperation
key to successful execution of
plan.
Direct Economic Cost: Moderate.
Heavily dependent on invoked re-
sponse during alert. Cost would
be government goods and services
not offered during the alert.
Administrative Cost: Moderate.
Encouraging and assisting each
affected agency to formulate
abatement plans. Cost primarily
one of publicity and communication
both prior to and during an
emergency episode.
Other Cost Considerations: Social
cost of decreased efficiency in
governmental operations. Incon-
venience cost for trips foregone
or wasted due to closed facilities.
Enforcement Procedure: Moderate.
Dependent on cooperation of
affected agencies. Widespread
violations, intentional or other-
wise, would be difficult to pre-
vent.
Equity: Singles out federal
faci 1 ities for work "holiday!1
Hay invoke outcries of free
loafing of federal employees
at taxpayer's expense.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 17
Close (Non-Essential) Government
Agencies (Federal, State. & Local!
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
General Description: A general
work holiday would be in force
for all governmental employees
performing non-essential services
(i.e. not related to emergency,
health, and safety).
Implementation Procedure:
1) A working definition of
agencies and personnel to be
affected would be drafted.
Agencies would be informed
of the emergency actions
proposed.
2} Cooperation in the program
would be actively solicited
and encouraged to ensure
program effectiveness.
3) Establish communication chan-
nels to be used in case of an
alert.
Enforcement Plan:
Surveillance teams would be
organized to spot check com-
pliance during the episode.
Total VMT Reduction:
5%*
Applicable to LDMV's.
*Add 1% if public school
closure is to be included.
Emission Reduction:
(Percent of Total ]
RHC
3%
CO
NOv
Implementation: Significant.
primarily a problem of notifying
nd coordinating the implemen-
tation of the many affected agencie
iOod cooperation and communication
re key to the successful execution
f the plans.
Direct Economic Cost: High.
Heavily dependent on invoked
response of agencies affected
during the alert. Cost would
be loss of governmental goods
and services normally offered.
Administrative Cost: Moderate
Other Cost Considerations: Social
to High. Encouraging and assist-
ing the affected agencies to
formulate abatement plans. Cost
primarily one of publicity and
coninunication, both prior to and
during an emergency episode.
cost associated with decreased
efficiency in governmental oper-
ations. Inconvenience cost for
trips foregone or wasted due to
closing of federal facilities.
Enforcement Procedure: Moderate
to Significant. Dependent on
cooperation of affected agencies.
Widespread violations, intentional
or otherwise, would be difficult
to prevent. Problem of enforce-
ment, in part due to the number
of agencies and personnel affectec
Equity: Singles out governmental
agencies for a work holiday. May
invoke outcries from private bus-
inesses of wasting public funds,
taxes, etc.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 18
Close Government Contractors
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
en
General Description:
A work holiday would be declared
for employees of governmental
contractors performing non-essent-
ial services (i.e. emergency,
health, safety).
Implementation Procedure:
1) A working definition would
have to be formulated for
which companies would be
affected.
2) Companies covered in traffic
ban requested to draw up con-
tingency plans.
3) Communication channels estab-
lished for alerting companies
affected.
4) Publicity campaign developed
for companies employees
affected.
Enforcement Plan:
1) Include additional clause in
government contracts that
abatement plans be developed.
2) Surveillance teams would be
organized to spot check com-
pliance during the alert
periods.
Total VMT Reduction:
Applicable to LDMV's.
Emission Reduction:
(Percent of Total)
RHC
CO
NOv
Implementation: Minimal to
Moderate.
Some precedence available; similar
provisions (i.e. job discrimi-
nation) have been included in
contacts before.
Direct Economic Cost: High.
Estimated that about one million
employees would be affected. Cost
would either be borne by individ-
uals or the government and include
salaries, loss of productivity.
services curtailed, etc.
Administrative Cost: Moderate.
Cost associated with modifying
contracts to include additional
clause(s). Time and effort to
review abatement plans of govern-
ment contractors and establish
necessary communication links for
program implementation.
Other Cost Considerations:
Decreased efficiency of govern-
men-contracted facilities, loss
of goods and services normally
given, etc.
Enforcement Procedure: Moderate.
Equi ty:
Enforcement would be tied into
contracts where penalties for
violations would be clearly
delineated. Enforcement teams
would randomly spot check con-
tractors for violations.
Singles out employees of govern-
mental contractors. Complaints
of wasted tax dollars likely to
occur
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 19
Close Shop. Facilities at Regional
Shop. Ctrs. & Central Bus. District
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
cr>
General Description:
Prior to and during an emergency
episode, the regional shopping
centers and central business dis-
tricts would be closed in an
attempt to reduce travel.
Implementation Procedure:
1} Determine which facilities are
to be included in shut down.
2) Organize publicity campaign to
inform public and businesses
of areas to be affected.
3) Establish communication
channels for informing busi-
nesses of impending shut down.
Enforcement Plan:
1) Organize surveillance and
monitoring teams to spot
check closed areas during
alert.
2) Violators to be subject to
citations and/or fines.
Total VMT Reduction:
Applicable to LDMV's and HDMV's
Emission Reduction:
(Percent of Total}
RHC
CO
NOX
Implementation: Significant.
Direct Economic Cost: High.
Considerable effort required for
all phases of this measure --
determining which areas to close,
organizaing publicity campaign,and
establishing communication
channels.
laxable retail sales for the air
basin in 1971 were about $60
million per day, a large snare
of which conies from the areas to
be affected.
Administrative Cost: Moderate.
Involves primarily determing and
contacting all the affected busi-
nesses of concern; also, providing
for an effective surveillance pro-
gram.
Other Cost Considerations:
High social cost of attemping
to close an indirect source while
leaving many alternative option
open, e.g. neighborhood and local
shopping centers. Could create
traffic jams and safety problems
at local stores.
Enforcement Procedure: Moderate
to Significant.
Dependent on favorable cooperation
of many businesses affected. It
would be difficult to detect
significant numbers of violations
Singles out indirect source, I.e.
businesses in shopping centers
and CBD's, for control, which
will likely force a considerable
activity to other alternatives --
neighborhood and local stores.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURC NO. 20
Close Recreational Facilities
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
General Description:
Prior to and during an episode,
recreational facilities would be
closed to discourage vehicle
travel. This measure would be
used primarily in conjunction
with other types of work holidays
to minimize substitute travel.
Total VMT Reduction:
7%%
Applicable to LDMV's.
Implementation Procedure:
1) Arrive at working definition
of facilities to be covered
1n shut down.
2) Notify all affected facilities
of shut down procedures.
3) Establish communication chan-
nels for contacting facilities
4) Ban all parking within set
distance of beaches, parks,
etc.
Emission Reduction:
(Percent of Total)
RHC
Enforcement Plan:
1) Organize surveillance and en-
forcement teams to monitor
program effectiveness.
2} Violators to be subject to
citations and/or fines.
CO
NOV
Implementation: Moderate to
ignificant.
Some problem at defining facilities
:o be covered, as well as trying to
3revent access to or parking at
>ublic facilities.
Direct Economic Cost: Moderate.
Primarily the loss of income to
owners of recreational facilities.
Administrative Cost: Moderate.
Other Cost Considerations:
Significant effort required to
inform public and affected busi-
nesses of episode plan.
Social cost of not having re-
creational facilities available
as an outlet for extra time
available; important for younger
age groups who may resort to
less constructive activity --
vandalism, pranks, crime.
Enforcement Procedure: Moderate
to Significant.
Due to the large number of parks,
beaches, and private recreational
facilities, it would be difficult
to prevent violations in any
significant numbers. Parking bans
especially would be difficult to
enforce.
Singles out recreational facilities
to bear bulk of economic cost of
this control measure.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 21
Work Holiday for Major Firms
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
General Description:
All firms which employ more than
a specified number of workers (100)
would be closed to reduce work-
related travel.
Total VMT Reduction:
11%
Applicable to LDMV's and HDMV's
Implementation Procedure:
1) Arrive at working list
^J of firms covered 1n this
Co exclusion.
2) Notify firms of abatement plan
and assist in firms developing
individual contingency action.
3) Establish communication chan-
nels to be used in case of an
alert.
Emission Reduction:
(Percent of Total)
RHC
Enforcement Plan:
1) Organize surveillance and en-
forcement teams to spot check
and monitor program effective-
ness.
2) Violators to be subject to
citations and/or fines.
CO
10%
NOV
Implementation: Significant.
Primarily a problem of enlisting
cooperation of all firms, publici-
zing the program, and coordinating
the shut down. Important elements
will be good communication and
advance publicity.
Direct Economic Cost: High.
In addition to wage and salaries
the productivity of approximately
one million employees would be
affected.
Administrative Cost: High.
Cost of notifying the companies
involved will be formidable, both
initially in regard to the program
and prior to an impending alert.
Other Cost Considerations:
All the goods and services offered
by major firms would be curtailed;
as a secondary impact, all firms
dependent on major firms would
likewise be affected.
Enforcement Procedure: Substantia
Due to the large number of firms
involved, effectiveness is depen-
dent on good faith cooperation of
companies involved. Widespread
violations would be difficult to
detect or prevent.
Singles out major firms to bear
bulk of the direct cost of this
control. Depending on circum-
stances, employees, company, or
both will share cost.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 22
Rotating Work Holiday For
. Major Firms
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
ID
General Description:
All firms which employ more than
a specified number of employees
(100) would be closed in alert
situations on a rotating schedule
to reduce work-related travel.
Implementation Procedure:
1) Arrive at working list
of firms covered in this
exclusion.
2) Notify firms of abatement
plans and assist in firms
developing individual con-
tingency action.
3) Establish communication
channels to be used 1n case
of an alert.
Enforcement Plan:
1) Organize surveillance and en-
forcement teams to spot check
and monitor program effective-
ness.
2) Violtaors to be subject to
citations and/or fines.
Total VMT Reduction:
2.2% - 1/5 of Major Firms
4.4% - 2/5
6.6% - 3/5
8.8% - 4/5
11% - All
Applicable to LDMV's and HDMV's.
Emission Reduction:
(Percent of Total)
RHC
Fract.
of
Firms
1W 1/5
3°i 2/5
4%% 3/5
6% 4/5
7'i% Al 1
CO
2%
4%
6%
8%
10%
Fract
of
Firms
1/5
2/5
3/5
4/5
All
3%
Fract.
of
Firms
V5
2/5
3/5
4/5
All
Implementation: Significant.
Primarily a problem of enlisting
cooperation of all firms, publici-
zing the program, and coordinating
the shut down. Important elements
will be good communication and
advance publicity.
Direct Economic Cost: High.
In proportion to the number of
firms involved. Consist mainly
of wages, salaries, and lost
productivity of persons not
working.
Administrative Cost: High.
Cost of notifying the companies
involved will be formidable, both
initially in regard to the program
objectives and prior to an im-
pending alert. Added cost of
explaining rotation schedule to
avoid excessive shut-down or non-
compliance.
Other Cost Considerations:
Decreases efficiency of normal
business activities of region.
Since many firms are closed while
others are open, many transaction^
which normally take place will be
disrupted.
Enforcement Procedure:Significant.
Large number of firms still in-
volved, making monitoring a
difficult task with limited
personnel. Widespread vio-
lations still would be difficult
to detect or prevent.
Equity:
Still singles out major busi-
nesses to bear major cost of
control measure.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
00
o
CONTROL MEASURE NO. 23
Operate on Sunday Status
General Description:
A work holiday would be declared
in which all persons would assume
their normal Sunday schedules.
The intent 1s to reduce work
related travel for the majority
of business, industrial, commer-
cial, and governmental employees.
Implementation Procedure:
1) Notify public at large of
proposed program, especially
encouraging no substitute
travel during the alert;
2) Establish an effective, com-
munications channel with
normal mass media avenues
for broadcasting impending
episode.
Enforcement Plan:
1} Organize surveillance teams
to spot check and monitor
compliance to control regu-
lations.
2) Offenders would be subject to
citations and/or fines.
EFFECTIVENESS
Total VMT Reduction:
35-40%
Applicable to LDMV's and
HDMV's
Emission Reduction:
(Percent of Total!
RHC
25-302
CO
33-38%
NO,
25-30%
INSTITUTIONAL OBSTACLES
Implementation: Moderate to
Significant.
Almost completely depender* an
effective mass media campa.yn and
favorable community response.
Administrative Cost: Minor to
Moderate.
Primarily the cost of communi-
cating the program to the public;
presumably much of the radio and
TV time could be gotten free as a
community public service.
SOCIO-ECONOMIC IMPACTS
Direct Economic Cost: Very High.
Proportional to firms affected,
and includes lost business,
salaries, wages, and lowered
productivity. Probably an in-
crease in some businesses, e.g.
recreational and shopping
facilities. Total lost wages
may be up to $50 mi VI ion.
Other Cost Considerations:
Disruption cost of an unanticipated
work holiday for many businesses in
community.
Enforcement Procedure: Significant
to Substantial.
Dependent largely on community
cooperation. Many businesses, com
panies, etc. would make monitoring
difficult. Violations would be
difficult to detect and prevent.
Equity:
Singles out businesses, companies
and agencies which operate on
Monday-Friday (or Saturday)
schedule. Provides a "bonus"
to facilities, e.g. recreational,
shopping, which are normally
open on Sundays.
-------
Table 5.4 EVALUATION OF TRAFFIC ABATEMENT EPISODE CONTROL MEASURES - continued
CONTROL MEASURE NO. 24
Complete Work Holiday With
. Recreation Closed
EFFECTIVENESS
INSTITUTIONAL OBSTACLES
SOCIO-ECONOMIC IMPACTS
00
General Description:
A complete shut down of all normal
businesses and institutions, un-
less they are of an emergency or
essential nature, i.e. hospitals,
fire, police, etc. An attempt to
induce people to stay home because
of no work, snooping, or recreate
ion available.
Implementation Procedure:
1) Notify public at large of pro-
posed control measure.
2) Actively solicit public sup-
port for program.
3) Establish communication chan-
nels to be used for impending
emergency.
Enforcement Plan:
1) Organize surveillance teams,
to monitor program effective-
ness.
2) Violators to be subject to
citations and/or fines.
Total VMT Reduction:
75%
Applicable to LDMV's fcHDMV's,
Emission Reduction:
(Percent of Total)
RHC
55%
CO
70%
NOX
55%
Implementation: Substantial.
Dependent largely on favorable
public response. Adequate
aublicity and communication are
critical to successful execution
of this measure.
•Direct Economic Cost: Very High.
This measure would virtually
bring the economic activity of
the community to a halt. Costs
would run 50-100
millions of dollars in loss wages,
business, productivity, services,
etc.
Administrative Cost: High.
Substantial effort would be re-
quired to inform everyone of this
program, and to convince them
that the requested actions on
their part are needed for effect!v(
control of the pollution.
Other Cost Considerations:
Indirect socio-economic impacts
are staggering. Would result
in almost a complete disruption
of all normal community activities.
Enforcement Procedure: Substantial
Completely dependent on favorable
community response. Violations
would be nearly impossible to
stop and could be widely antici-
pated.
Equity:
Activities of groups such as
young and elderly who do not
contribute to the pollution might
be curtailed. Loss wages felt
harder by the poor. Ultimately,
however, all in the conmunity will
bear the costs.
-------
Of the three general groups of measures, Controls on Traffic Support
Facilities, appear to be the least desirable type of control. "Controls on
Parking" and "Closing Freeways" rate poor in effectiveness; these controls
may actually lead to an increase in traffic emissions. They also rank poorly
as to institutional obstacles and socio-economic impact considerations.
"Rationing Gasoline" can be somewhat effective, but it is extremely poor
in the realm of public acceptability and implementation and enforcement
problems. "Close Gas Stations", the most attractive of this group of controls,
is nearly equivalent to gas rationing. It involves fewer enforcement-
implementation problems than gas rationing, but results in slightly more
economic disruption. However, it too ranks extremely poor as far as social
and political acceptance. Overall, it seems that more attractive measures
are available among direct controls and incentive controls than under support
facility controls; the latter group will thus be eliminated from the present
discussion.
There are ten different control measures listed under Direct Controls
on Traffic. The first of these, "Voluntary Abatement", essentially has no
effect. The last control "Commercial Abatement Schemes", unless they involve
massive shutdowns (in which case they come under "Incentive Controls"), are
also of very limited effectiveness due to the lack of enforcement for car-
pooling and public transit aspects of these plans. Review of the implementa-
tion of federal agency abatement plans on July 26, 1973 reveals that negligible
increases in carpooling and public transit ridership occurred among the
agency employees. A new scheme would have to be developed for enforcing
commercial abatement plans if this were to be considered a viable alternative.
"Banning All Non-Emergency Traffic" is rated as a less desirable alter-
native than a similar measure which controls incentives to travel. The most
182
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severe control on travel incentives -- work holiday plus closing of shopping
and recreational facilities -- can yield VMT reductions which are equivalent
to a traffic ban. Yet, the travel incentive control has fewer enforcement-
implementation problems and is more palatable socially and politically than
a complete traffic ban. Both cause severe economic disruption. Other factors
being equal, the indirect approach, i.e. disincentives to driving, is con-
sidered more acceptable than direct regulation, i.e. traffic bans.*
"Banning Fleet Vehicles" is a somewhat acceptable alternative. Although
this measure also presents certain implementation-enforcement problems and
causes some economic disruption, it is effective and ranks relatively high
in public/private acceptability. Per car controlled, this method has
considerable impact since fleet vehicles are generally driven more miles
per day than non-fleet vehicles. The main problems associated with this
measure are compiling a list of exempt fleets, e.g., emergency vehicles,
and setting up an implementation and enforcement program. These problems
appear to be workable and thus, this control will be part of the recommended
program.
"Banning Fleet Vehicles and Vehicles for Commercial Use" is more effec-
tive than just "Banning Fleet Vehicles"; however, it presents much greater
institutional problems and has a greater economic cost. Because of the very
significant implementation and enforcement problems in attempting to single
out all (non-essential) commercial vehicles, it appears that the extra effec-
tiveness of banning all commercial vehicles is not worth the extra difficulties
Only a fleet vehicle ban will be recommended here.
* Actually, the one advantage of a traffic ban is that it might be put
into effect sooner. However, this discussion assumes a predictive
type alert system is available.
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"License-Plate Lottery", "Mandatory Carpooling", and "Windshield Sticker
Program", are the direct controls remaining to be discussed. These controls
are similar in that only vehicles satisfying certain conditions (e.g. having
certain last license numbers, having certain numbers of passengers, or having
certain colored stickers) will be allowed to operate during an episode. These
controls present obviously difficult implementation and enforcement problems,
and all three rank very low in public acceptability. Each of the controls
could be effective if adequately enforced, and they all minimize economic
disruption by allowing businesses to remain open. Of the three, the "Wind-
shield Sticker Program" is apparently the best. Several states, for example,
have instituted windshield sticker programs in connection with annual safety
inspections. It is also likely to be less confusing than the "Lottery"; as
such, it should be more enforceable and effective. "Windshield Stickers" also
\
appear to be better than the two "Mandatory Carpooling" measures. The latter
are less organized and can create an extremely confused situation. Although
"Windshield Stickers" is apparently better than either a "Lottery" or "Mandatory
Carpooling," the probability of difficult enforcement problems must be empha-
sized. Even more, the outcry of many members of the public to not being able
to drive because they have a certain type of car should not be underestimated.
The third general type of traffic abatement strategy, Controls on
Incentives to Travel. solves certain problems but creates one major problem.
Incentive controls involve shutting down reasons for traveling. A plausible
order might be: government offices, then government contractors, then
specific industries, shopping areas, and recreational facilities, and finally
a complete work holiday. This provides a program of flexible impact, ranging
from a few percent VMT reduction to more than 70% VMT reduction for a complete
work holiday. The implementation and enforcement problems, while still
184
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considerable, are somewhat less than those associated with most other schemes
discussed. For example, they are much less than corresponding problems for a
"Windshield Sticker Program." Overall social acceptance to this type of con-
trol probably compares favorably to other schemes with considerable VMT
impact. However, the problem introduced by incentive control plans is major
economic disruption. It is estimated that a complete work holiday for one
day would cost around $50 million. The economic disruption per VMT reduction
gained is the principal drawback to the "Shut-Down" approach.
5.2.1 Summary of Traffic Abatement Control Measures
In summary, an examination of the alternatives available for traffic
abatement reveals a number of problems. Nearly all the control measures
would encounter considerable implementation and enforcement difficulties.
Most measures under consideration also result in a certain amount of economic
and/or social disruption. The most formidable institutional obstacles will
be dealing with private interests affected by different measures and the
political forces which exist at all levels of government -- local, regional,
state, and federal.
Recognizing that any plan which is to be effective at controlling an
episode will have these disruptive elements in it, one can only hope to
examine the trade-offs in an attempt to minimize the negative impact of a
control plan. With these considerations in mind, certain traffic abatement
controls are recommended below for inclusion in the staged implementation
plan for emergency alert situations. These controls are basically of the
"incentive to drive" type. It is emphasized that the recommendations basically
come from a subjective value judgment weighting economic disruption,
(primarily from incentive controls), with problems of enforcement,
185
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implementation, social, and institutional acceptability. Obviously, in an
area of such controversy, it is likely that different individuals (or groups)
will evaluate the situation differently.
Finally, it should be noted that this judgment is a function of the
frequency with which alerts are called. If advanced alert stages are called
often -- five or ten times per year -- the economic disruption associated
with "incentive controls" may be intolerable. In this case it might be
preferable to try to implement another type of control program, e.g.
"Windshield Stickers". If complete alerts are called very infrequently, a
complex "Windshield Sticker" program looks less attractive and incentive
controls become more acceptable. Thus, if the .40 PPM - 4 hour "harm level"
were to be modified, so that alerts were called less frequently, incentive
type controls would become even more attractive.
5.2.2 Recommended Control Measures for Inclusion in Control Plan
In an attempt to identify several control measures with increasing
effectiveness in reducing total VMT (and thus RHC emissions), four measures
are recommended for inclusion in a staged implementation control plan.
Listed in order of increasing emission control effectiveness (and increasing
socio-economic impact), the control measures are:
e Ban (Private) Fleet Vehicles - (Control Measure No. 5).
e Close (Non-Essential) Governmental Agencies (Federal,
State, and Local) - (Control Measure No. 17).
• Operate on Sunday Status - (Control Measure No. 23).
• Complete Work Holiday with Recreation Closed - (Control
Measure No. 24).
The selection of these four controls is in part dictated by attempts
to minimize administrative costs and procedures. Thus, groups have been
186
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selected for controls which are readily identifiable, and few new operational
definitions have been added. This avoids extensive public knowledge-publicity
campaigns.
The California Department of Motor Vehicles (DMV) has extensive
information on private fleet vehicles (i.e. ten or more vehicles registered
under one name). It would be relatively straightforward to get a complete
listing of the fleets, their location, number of cars in each fleet, etc.
This information could then serve as a basis for notifying the affected
groups of the control measure requirements. Due to the disproportionate
share of mileage which fleets account for, prohibiting their travel during
an episode should have a perceptible impact on the problem.
Closing governmental agencies is another means of eliminating a
significant fraction of VMT. While this measure invariably invokes out-
cries of wasted taxpayer money, it presents far fewer problems than attempt-
ing to close down private enterprises. It also circumvents some of the
complaints voiced during the July 26, 1973 shutdown of federal facilities --
i.e. giving a work holiday to federal employees only and not all governmental
employees. Lastly, this measure is attractive because it affects a sizable
group of easily definable commuters in agencies where well established channels
of communication already exist and a spirit of cooperation can generally be
enlisted.
The control measure calling for Sunday status has several desirable
features -- it is operationally simplistic and inherently incorporates large
portions of other, more cumbersome control measures. No new procedures or
working definitions have to be developed. With adequate publicity, few indivi-
duals would not know what was expected of them. Without notifying many
187
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agencies, schools, fleets, etc., operating on Sunday status would automatically
curtail almost all of their activities because of normal work schedules. '
The severest control measure proposed, a complete work holiday with
recreational facilities closed, is used as a last resort primarily for its
technical effectiveness. As previously noted, very significant socio-
economic disruptions are associated with this control. However, it also
appears that no other alternative will be able to sufficiently reduce RHC
emissions to the levels required to protect public health from significant
harm levels when particularly high concentrations of photochemical oxidants
are predicted to occur.
188
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REFERENCES - CHAPTER FIVE
1. California State Office of Emergency Services, Air Pollution Emergency
Traffic Control Planning Committee, Traffic Abatement Plan for Air
Pollution Episodes, 1973.
2. Environmental Protection Agency, Region IX, Preliminary Report of the
EPA Region IX Task Force on Traffic Abatemen~During Air Episodes,
15 September 1972.
3. Verleger, P. K., Counsel for Western Oil and Gas Association, Statement
before the California Air Resources Board, Los Angeles, 18 September 1973
189
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6.0 A PROPOSED EPISODE CONTINGENCY PLAN
Alternative formulations of the four basic elements of an episode
contingency plan for the Metropolitan Los Angeles AQCR have been described
and evaluated in Parts 4. and 5. of this report. On the basis of this
discussion, a specific plan is recommended below. Section 6.1 deals
with episode criteria. Section 6.2 proposes a four stage control pro-
gram and describes the effectiveness, implementation-enforcement
procedures, institutional problems, and socio-economic impact associated
with the control strategies. Recommended surveillance and operational
procedures are presented in Sections 6.3 and 6.4, respectively.
Finally, to put the uncertainess in the results into perspective,
Section 6.5 discusses the limitations of the analysis.
Overall, the episode criteria and control strategies recommended
here are similar to those in a contingency plan recently developed by
EPA- Region IX. The EPA plan is presented in Appendix B. However,
certain differences do exist between the two plans, particularly in
the intermediate control strategy stage. Part 2 of Appendix B compares
the two plans and discusses the relative advantages and disadvantages
of each.
190
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6.1 RECOMMENDED EPISODE CRITERIA
The need to use forecasting as opposed to feedback episode criteria
for a Los Angeles contingency plan was stressed in Section 4.1.2. For
one, advanced notice is required to effectively implement traffic abate-
ment measures. Secondly, for controlling oxidant, the pollutant likely
to cause nearly all episodes, forecasting appears to be an absolute
necessity because oxidant levels can continue to rise during the day
even if emission sources are instantaneously shut down.
Section 4.1.2 distinguished between two types of air quality fore-
casts: future-weather type forecasts for more than a day in advance and
shorter term, weather-change type forecasts. For the Los Angeles episode
plan, it is recommended that control strategy selection be completed
at the latest by 4:00 or 5:00 P.M. of the previous day so as to make the
evening news. A 4:00 or 5:00 P.M. deadline would allow the forecast to
be made in the late afternoon of the previous day. Since previous day
maximal oxidant is likely to be known at this time, a weather-change type
prediction technique would be possible. The episode criteria recommended
below will be of the weather-change, forecasting type. However, it should
be noted that to allow for more implementation time, it may prove desirable
to use an earlier, (late morning), future-weather type forecast. The
trade-offs of operating time vs. forecast accuracy deserve further
investigation.
Table 6.1 and 6.2 list the proposed episode criteria. Table 6.1 is
for oxidant. Criteria are given for both the present .40 PPM - 4 hour
average harm level, (the binding constraint of the three existing harm
levels; see Section 2.2.5), as well as for the recently proposed
.60 PPM - 1 hour average substitute. Table 6.2 gives criteria for CO
191
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Table 6.1
EPISODE CRITERIA FOR OXIDANT
a) For the Present .40 PPM (4-Hour Average) Harm Level
Previous Day
Max. Four Hour
Average Oxidant
(with no
control*)
(PPM)
.00 - .27
.28 - .33
.34 - .38
.39 - .44
.45 - .50
.51 +
Alert Stage to be Called
Forecasted Change in Max. 4-Hour Average Oxidant
Much
Lower
-
-
-
-
I
I
Lower
-
-
-
I
II
II
Same
-
-
I
II
III
IV
Higher
-
I
II
III
IV
IV
Much
Higher
I
II
III
IV
IV
IV
b) For the Proposed .60 PPM (1-Hour Average) Harm Level
Previous Day
Max. One Hour
Average Oxidant
(with no
control*)
(PPM)
.00 - .39
.40 - .49
.50 - .57
.58 - .65
.66 - .75
.76+
Alert Stage to be Called
Forecasted Change in Max. 1-Hour Average Oxidant
Much
Lower
-
-
-
-
I
I
Lower
-
-
-
I
II
II
^
Same
-
-
..o
r^
fur)
;' iv ;
Higher
-
I
II
III
IV
IV
Much
Higher
I
II
III
IV
IV
IV
* If controls were in effect during the previous day, the previous day
maximal oxidant level should be adjusted upward to reflect a "no control"
value before using these tables.
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Table 6.2
EPISODE CRITERIA FOR CO AND N02
For the 50 PPM (8-Hour Average) CO and .50 PPM (24 Hour Average) N02 Harm
Levels
Previous Day
Max. 8-Hour
Average CO
(with no
control*)
0 - 39
40 - 46
47 - 54
55 - 66
67+
Alert Stage to be Called
Forecasted Change
Previous Day
Max. 24-Hour
Average NO^
.00 - .39
.40 - .46
.47 - .53
.54 - .61
.62+
Much
Lower
-
-
-
I
I
Lower
-
-
I
II
II
Same
-
I
II
III
IV
Higher
-
II
III
IV
IV
Higher
I
III
IV
IV
IV
* If controls were in effect during the previous day, the previous day
maximal pollution levels should be adjusted upward to reflect a "no control1
value before using this table.
193
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and NO . These are based on the 8 hour CO harm level and the 24 hour NO^
harm level which appear to be binding over the other CO and N02 significant
harm standards, (Section 2.2.5).
The episode criteria call for control stages I through IV to be
implemented under various conditions. These control strategies will be
presented in the next section. The effectiveness of each control stage
in abating episodes, (given later in Table 6.5), is consistent with the
episode criteria as they appear in Tables 6.1 and 6.2
It should be emphasized that the recommended episode criteria ar°
intended to be general guides for control strategy selection rather than
rigid regulations. The director of the episode program should be allowed
some flexibility. This is particularly true in regard to the "Much Lower"
and "Much Higher" predictions. For instance, in Table 6.la, a previous day
4 hour oxidant level of .50 PPM along with a forecasted change of "Much
Lower" still calls for a Stage I alert (voluntary abatement). However, if
the "Much Lower" forecast is due.to the fact that a rainstorm is descending
on the basin, it would not be appropriate to call any alert at all. Con-
versely, different actions might be taken with a "Much Higher" forecast
depending on just "how much higher" is really expected. However, since it
t
may prove administratively difficult to make a firm decision to call an
episode, flexibility should be allowed more in calling for over control
than in calling for under control.
6.2 RECOMMENDED CONTROL STRATEGIES
On the basis of the discussions thus far, this section recommends a
control plan which has the required technical effectiveness to prevent sig-
nificant harm levels with minimal implementation problems and socio-economic
194
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disruptions. A four stage alert plan is proposed with control ranging from
essentially zero emission reductions (Stage I) to approximately 64% reduction
in RHC emissions (Stage IV). Two intermediate stages (Stages II and III)
would reduce RHC emissions by about 16% and 39% respectively.
In many ways, the strategies recommended here are similar to those in
a contingency plan developed by EPA-Region IX; in other respects, distinct
differences exist, (see Appendix B for a detailed comparison). The rationale
for the strategies recommended here is detailed forthwith, along with the
specifics of the plan.
Tables 6.3 and 6.4 summarize the control measures proposed for each
of the four stages. Also presented are the VMT reductions and emission
reductions which can be expected for each measure and strategy. Table 6.3
gives RHC emission reductions; Table 6.4 is for CO and NO
/^
Stage I consists of a press release and a request for voluntary
abatement. This "passive" control is included in all subsequent stages.
Stage II has four active (mandatory) controls, a ban on filling of under-
ground service station tanks, control of stationary RHC sources, a ban on
non-essential fleet vehicles, and closure of non-critical government
agencies. Stages III and IV have only one active control each, operating
on Sunday status and a complete work holiday (including recreational shut
down) respectively. This overview of the plan highlights one of the
\.i
attractive features of the strategies -- their relative simplicity. In
view of the massive communications, surveillance, administrative, and
enforcement problems associated with episode control, it is highly desirable,
if not essential, to formulate simple strategies which are operationally as
easy to implement as possible. Complicated strategies are likely to fail
due to an inability to effectively implement the control measures.
195
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Table 6.3
PROPOSED CONTROL STRATEGIES:
VMT REDUCTION AND RHC EMISSION REDUCTION
pggSSSSME
! Stage
I
rr
III
IV
*Add
m«Xi^VS^smamr^!i-Jmaa^^M'^m^ii^mmKw^w^^^^s^<:
Control Strategy
1. Media Announcement & Request
for Voluntary Reduction of
Vehicle Use & Emissions
1. Stage I Actions
2. Ban Filling of Underground
Service Station Tanks
3. Shut-down Major RHC Point
Sources & Other RHC Source
Categories Designated by the
APCD- (Exemptions Allowed)
4. Ban (Private) Non-Critical
Fleet Vehicles
5. Close (Non-Essential)
Government Agencies
1. Stage I Actions
2. Operate on Sunday Status
1. Stage I Actions
2. Complete Work Holiday
with Recreation Closed
Inc
VMT
negl .
negl .
—
5%-LDMV
30%-HDMV
5%*-LDMV
negl .
40%-LDMV
& HDMV
negl .
75%-LDMV
& HDMV.
:remental Rec
RHC Emi
Vehicular
negl .
negl .
—
6%
3%
negl .
29%
negl .
54%
lila&SSfaiiiSiSiiiiiSBSfiiEi
uctions [
ssions 1
Stationary i
[
negl.
negl .
4%
3%
negl .
10%
*wB»E!fciiiIX£iiJ.i -3
negl .
i
1
i
64%
.VH^W***-!-^
1% if public school closure is to be included.
cr>
-------
Table 6.4
PROPOSED CONTROL STRATEGIES:
VMT REDUCTION AND CO AND NOV EMISSION REDUCTIONS
A
Stage
I
II
in
,y
Control Strategy
1. Media Announcement & Request
for Voluntary Reduction of
Vehicle Use & Emissions
1 . Stage I Actions
2. Ban Filling of Underground
Service Station Tanks
3. Shut-down Major RHC Point
Sources & Other RHC Sources
Designated by the APCD-
( Exemptions Allowed)
4. Ban (Private) Non-Critical
Fleet Vehicles
5. Close (Non-Essential )
Government Agencies
1 . Stage I Actions
2. Operate on Sunday Status
1. Stage I Actions
2. Complete Work Holiday
with Recreation Closed
^umjmjatjtijiMLJAi^Arakma^
Increment
VMT
negl .
negl .
--
5%-LDMV
30%-HDMV
5%*-LDMV
negl .
40%-LDMV
&
HDMV
negl .
7 5%-LDMV
&
HDMV
;al Redu
Emiss
CO
negl .
negl .
N/A
7%
4%
negl .
37%
negl .
70%
ctions
ions
M°x
negl .
negl .
N/A
6*
3%
negl . |
I
negl. 1
52%
Cun
VMT
negl .
10%-LDMV
30%-HDMV
40%-LDMV
&
HDMV
75%-LDMV
HDMV
gS^SS^SSSMEL
nulative Re
CO
Emissions
negl.
11%
37%
70%
ductions 1
NO i
Emissions i
negl . 1
9% I
28% i
52% I
-n.-ffl-i-,i^>^iJLL^j*'l3Ji^.^flilIF;,v-i--i ^
*Add 1% if public school closure is to be included,
-------
Since this control plan is tied to forecasting episode criteria,
the more severe stages involve controls with more general scope than previous
stages, but they are not necessarily derived from previous stages by
"tacking on" additional measures. The latter approach, where each
stage calls for all the measures of the previous stages, is more suited
to feedback type criteria. However, each successive stage in the
recommended plan does encompass nearly all the effects of the previous
stages. For instance, the work-holiday certainly includes all of the
Sunday status measure. Operating on Sunday status in turn covers the
filling of underground service station tanks and government agency
closure and includes most of the effects of banning fleet vehicles and
shutting stationary RHC sources.
6.2.1 Control Strategy Applicability
As discussed in section 2.2.2, the severest oxidant problem in the
Los Angeles Basin occurs predominantly in the Los Angeles, Orange,
Riverside and San Bernardino Counties. Since air quality is never
expected to reach alert levels in either Santa Barbara or Ventura
Counties, the proposed control strategies for the Basin would usually
exclude them. These two counties are neither the sources of a large
share of precursors nor the receptors of high levels of pollutants.
Present and projected growth patterns in these areas for the near term
are not likely to change this situation significantly. They should
be included in the episode controls only when very special conditions
occur.
The control strategies have been developed for weekday abatement
actions. It is not anticipated that alert levels of pollution will occur
during the weekend. During the period since 1970, only one out of about
198
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twenty alert incidents has occurred on a weekend (see Table 2.10), and
this occasion was under unusual circumstances. It occurred on a holiday
(Saturday, July 4, 1970) when one would expect an unusually heavy amount
of traffic to have taken place both during and prior to the holiday (i.e.
Friday evening). Even then, though, the emergency level only exceeded
the harm level by about 10 percent.
6.2.2 Control Strategy Effectiveness
Of primary importance in any contingency plan formulation is the
technical effectiveness which is to be expected from the control measures.
Depending on the severity of the impending alert, the programmed control
strategies allow for reductions of approximately 0, 16, 39, and 64 percent
of RHC emissions during Stages I-IV, respectively. Reductions from indi-
vidual control measures were presented in Tables 6.3 and 6.4.
Table 6.5 summarizes the effectiveness of the various proposed
strategies and presents the episode levels which can be abated by each
stage. Analysis of air quality data [Section 2.2.5) suggest that Stages I,
II, and III are the only alerts which may have to be called in this
decade and then only because of oxidant pollution. It is highly unlikely
that any CO or N02 harm level or a Stage IV oxidant level will ever be
reached.
6.2.3 Implementation and Enforcement
The implementation and enforcement aspects of the proposed abatement
strategies will, in all likelihood, present some of the most difficult
problems of the program. With the exception of the Stage I abatement
actions, which are voluntary, the subsequent control strategies all have
direct impacts or numerous public and private groups. The magnitude of
199
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Table 6.5 EPISODE LEVELS WHICH CAN BE REDUCED
TO BELOW SIGNIFICANT HARM LEVELS BY
THE LAPSED CONTROL STRATEGIES
Stage
I
II
III
IV
Emission Reductions
RHC CO NO.,
negl .
16>2%
39%
64%
negl .
12%
37%
70%
negl .
9h%
28%
52%
Episode Levels whic
Oxidant**
.40-4 hr. .60-1 hr,
.40
.435
.50
.59
.60
.65
.75
.88
h Can Be A
CO**
50-8 hrs.
50
54
66
94
Dated (PPM)
NO/*
.50-24^hrs
.50
.53
.61
.77
* These results are based on the approximate air quality-emission level
relationship developed in Section 2.2.7. Oxidant concentrations are
assumed to be reduced by % of the amount of RHC emission reduction on
the day of the episode. CO and NO- concentrations are assumed to be
reduced by 2/3 of the-amount of CO and NO emission reductions on the
day of the episode.
** As noted in Section 2.2.5, the .40 PPM-4 hr. oxidant level, the 50 PPM-
8 hr. CO level, and the .50 PPM-24 hr. N02 level appear to be the
"binding constraint" significant harm levels for each of the three
pollutants. (There are three oxidant and CO harm levels and two N0?
harm levels.) The .60 PPM-1 hr. oxidant level has been proposed as
an alternative to the 4-hr, oxidant harm level.
the implementation and enforcement problems increase with each successive alert
stage. These problems are discussed below for each alert stage individually.
STAGE I - The intent of the proposed voluntary abatement actions is
to create public awareness of the air pollution episode. Basically,
the controls called for are similar to the actions solicited by the
local APCD during a first stage smog alert. Since no mandatory actions
are required and a similar program is in existence, no implementation
difficulties are anticipated. In a similar vein, no enforcement pro-
cedures are necessary.
STAGE II - Each of the four control measures proposed for this
strategy will require rather detailed implementation planning. The
stationary source controls would be most readily implemented through
200
-------
the local APCDs, who have established working relationships with the
majority of primary emitters. A potential difficulty may be enlisting
the cooperation of local APCDs, some of which have their own abatement
plans developed.
Underground filling of service tanks would be most effectively
curbed at the bulk terminals, a process which would require obtaining
a listing of such stations and informing them of the pollution abate-
ment schemes. Each bulk terminal in turn, would be responsible for
informing the stations it serviced. While requiring advanced pub1 •'city,
the information aspects of implementing this control do not appear to be
overly cumbersome.
The successful implementation of control for major point sources
and other designated source categories will be difficult for several
reasons. First, a fairly large number of such firms exist, employing
a sizeable number of employees. Many of the firms are politically
influential and can be expected to lobby extensively. In other cases,
plans for shut down procedures, already submitted to the local APCD's,
may or may not be acceptable to the EPA enforcement personnel. Some
firms, due to the nature of their product, would face extreme
difficulty in trying to rapidly shut down. Because of this, it is
deemed essential that a review committee be established to allow certain
operations exemption from the controls. Enforcement of stationary
source compliance is likely to be hampered by firms willing to risk
-.
violating the regulations and paying fines.
The implementation of the Stage II traffic abatement measures
require an extensive effort to inform all of the groups involved and
will depend heavily on a cooperative spirit from the affected agencies.
201
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Banning private fleets will most certainly result in negative economic
impacts. Therefore, it is likely that many fleet vehicle owners will
either object to imposed constraints or not comply when they are in
effect. In the latter case, enforcement will pose problems because
of the many fleets which would need monitoring. Identification of the
fleet vehicles may also pose enforcement problems.
Notification of the fleets affected can probably be most readily
accomplished by utilizing the records of the Department of Motor
Vehicles. One inequity present which cannot be easily eliminated is
the out-of-state fleet vehicles which accumulate significant mileages
within the basin.
Closing all governmental agencies will pose problems of a different
nature. For these groups successful implementation is dependent on the
individual plans drawn up by each agency. Actual implementation pro-
ceedings are highly dependent on an efficient and widespread communication
system to all the agencies involved. Without uniformly understood
instructions, the situation can become somewhat chaotic.
STAGE III - The key to successful implementation of this control.
strategy is adequate publicity of the program's goals and requirements,
i.e., to operate everything on Sunday status. Since no new working
definitions are introduced, most individuals should require no special
instructions. Sunday status has an additional advantage in that
normally the largest share of the individuals affected by Stage II con-
trols are similarly impacted by a Sunday status measure. For example,
all governmental agencies are closed on Sundays; also, service station
filling does not take place on Sundays. As before, successful imple-
mentation is largely dependent on voluntary compliance with the proposed
202
-------
regulations. Due to the extensiveness of controls, monitoring activities
could, at most, survey a fraction of the total number of companies under
control. Widespread violations, intentional or otherwise, would be
difficult to apprehend and prevent.
From an administrative viewpoint, the Sunday status control measure
is very attractive. The only question a company needs to ask is what
its normal Sunday routine is and to execute those activities; in most
cases, it should be either nothing or very little. It must be borne
in mind, however, that the communications necessary are directly pro-
portional to the number of individuals affected. The latter stages of
alerts affect so many individuals that effective communication is
crucial to the success of the program.
STAGE IV - The formulation of a fourth stage alert or maximum con-
trol has been dictated mainly by the technical effectiveness requirements.
Implementation and enforcment of a complete work holiday with recreation
closed will be extremely difficult to execute. The requirements would
essentially call for shutting down nearly all normal activities. The
implementation of this stage would require wide public acceptance and
willingness to cooperate. To achieve such cooperation would require
a very extensive mass media campaign.
While the general public is very concerned about air pollution, it
has become accustomed through the years to living with these conditions.
In view of the recently improving air quality trends, the public might
object strongly to taking abatement actions now for conditions which
used to occur relatively frequently and consistently, years ago.
203
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6.2.4 Institutional Problems and Soclo-Economic Impact
Any .attempts to implement and enforce strategies such as those
proposed will inevitably encounter a series of institutional problems
and result in numerous socio-economic impacts. Wherever possible,the
formulation of specific strategies has attempted to avoid these
difficulties. Institutional problems can potentially arise in a
number of areas -- local, regional, state, and federal government or
public and private business enterprises. Socio-economic impacts may
be felt by institutions or individuals. In either situation, the
associated impacts increase with the higher stages of alert action
called for. To be more definitive, these problem areas are discussed
in more detail according to stages or alert.
STAGE I - Since the abatement actions called for are entirely
voluntary, only minor impacts are expected from this stage of alert.
Institutional obstacles, likewise, are anticipated to be minor due to
the existent emergency alert level program initiated by the local
APCD's for Stage I alerts. In essence, the actions called for the pro-
posed Stage I abatement,are the same as the L.A. County APCD plan for
first stage alerts. The primary emphasis at this level is individual
abatement action, and socio-economic impacts are expected to be
minimal.
STAGE II - In comparison to Stage I actions, the controls called
for in this stage affect numerous institutions and affect tens of
thousands of individuals. Since certain groups have been isolated for
control, e.g. bulk terminal operators, major stationary sources, fleet
vehicle owners, and governmental agencies, it is certain that
institutional objections will be raised. Moreover, the loudest
204
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objections are most likely to be voiced by those groups suffering the
largest impacts. For governmental employees granted a work holiday,
charges of wasted governmental funds and tax dollars are likely to
be levied. Many fleet vehicle owners will also complain of unreasonable
controls and/or severe economic impacts on private business. Since
the larger businesses are most likely to own fleets, this group will
suffer more economically from Stage II controls. On the other hand,
these businesses are also most likely to be able to absorb the costs
of the control actions. Due to a lack of previous experience, it is
difficult to predict where and in what form, objections are likely to
be voiced.
STAGE III - The incremental impact from the Stage II to Stage III
control measures are very substantial. Operating on Sunday status
affects many more individuals and private enterprises. Economically,
a great impact would definitely be felt regionally. As a result,
institutional obstacles are also likely to be more significant. The
importance of an effective mass media campaign cannot be overemphasized
for minimizing the institutional objections likely to be raised.
Because of the economic impacts which would accrue, especially to the
private sector, violations of the controls would be expected. It
appears that these problems would be most efficiently dealt with well
in advance of any declared alerts, namely through soliciting public
cooperation to the proposed controls.
STAGE IV - It is projected that only in an extreme situation
would it be necessary to declare a fourth stage alert. The socio-
economic impacts of an effectively implemented fourth stage alert are
staggering. The anticipated impacts are of such a magnitude that it
• 205
-------
is questionable whether the public would tolerate them. More probable
would be the public's tolerance to the severe air pollution -- levels
which the public has previously endured with little more than vocal
objections. The principal obstacle facing any attempts to implement
such harsh actions is the lack of a precedent for it. Never has any area ever
responded, as it is proposed, to air pollution levels which have been experi-
enced before without generally apparent serious effects on health. It remains
to be seen whether such an abatement action can, in fact, be implemented.
6.3 RECOMMENDED SURVEILLANCE PROCEDURES
The four stage control program outlined above will require two
different types of surveillance procedures. The first, monitoring of
air quality and meteorology, will provide the basic atmospheric data
for the plan. The second, control strategy surveillance, will provide
information on how well the control program is being implemented.
Recommended procedures for both kinds of surveillance are presented
below.
As the description of air monitoring capabilities in section 4.3.1
pointed out, existing air quality and meteorological measurements in
the Los Angeles basin are adequate for the kind of episode control plan
envisioned. The main problem is that reliable methods for quickly
disseminating this data (especially to the EPA) have not been imple-
mented. Section 4.3.1 examined several ways, including the installation
of a real-time telemetry network and the development of a regional data
processing center, in which the situation could be improved. It was
concluded, however, that (at least for the present) the best way to
206
-------
conduct air quality surveillance is to let the California Air Resources Board
act as the principal disseminator of information, based on real-time informa-
tion links with the APCDs in the Los Angeles Basin.
Strategy implementation surveillance consists of two parts, agency
surveillance and source surveillance. As discussed in 4.3.2, agency surveil-
lance can be conducted in several different ways - by field personnel, by
telephone contact with all the agencies, or through telephone contact with
the ARB alone. For the EPA, the last approach appears most practical in terms
of communications simplicity and administrative cost. The most extensive
stationary source surveillance program now existing is that of the APCDs.
The ARB also has some stationary source monitoring capabilities. The
California Department of Transportation has a very useful traffic monitoring
system. At present, (if possible), it seems more practical to rely on the
existing procedures developed by these agencies,(described in section 4.3.2),
y
than to institute a whole new program. Programs like these are very expensive,
and duplication of effort should be avoided. Efforts should be made, however,
to organize well defined channels of communication to EPA Region IX.
6.4 RECOMMENDED OPERATIONAL PROCEDURES
The operational procedures of an episode contingency plan involve
three aspects. They are organizational structure, communication channels,
and activity phases. Each of these has been discussed in Section 4.4; only
a brief synopsis will be given below.
The organizational structure which will support the proposed plan must
be capable of sustaining four different kinds of operations: surveillance,
strategy selection, enforcement, and communication. Section 4.4.2 has
reviewed three different kinds of organizational structure, including the
207
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EPA Region IX Regional Emergency Operations Control Center (REOCC), and has
found all of them adequate to support the needed operations. There seems
to be no reason why the proposed plan should not fit smoothly into the
existing operations of the REOCC.
In section 4.4.3 several different types of communication are identified
as essential to episode control operation. These include communication with
the ARB, APCDs, field personnel, and public. EPA Region IX appears to have
provided adequate channels for handling all types of essential communica-
tion. As section 4.4.3 points out, however, it may be advantageous to
incorporate some kind of local communications center into the REOCC structure.
Section 4.4.4 suggests that episode control operations can be viewed
as consisting of three phases: an initiation phase, a control phase, and
a termination phase. For operations in the L.A. Basin, it is recommended
that the initiation phase be completed no later than 4:00 to 5:00 P.M. of
the day before actual control measures are implemented. The control phase
would last from 6:00 P.M. of the previous day until 4:00 or 5:00 P.M. when
the operation would enter the termination phase. In this phase, officials
would decide whether to continue control measures or to terminate the episode.
6.5 LIMITATIONS OF THE ANALYSIS
In developing an episode contingency plan, many simplifying assumptions
and approximations must be made. Certain simplifications will be rather
crude due to the very limited nature of relevant data. These errors in
approximations lead to uncertainty in the final results.
A considerable effort was made in the present study to eliminate as
much uncertainty as possible. For instance, in compiling the basic informa-
tion for traffic controls, a thorough review of available transportation
208
-------
data was conducted. The latest additions to this data base, as well as the
latest reported correction factors to previous data, were included in the
analysis. Conflicting results in different transportation studies were
resolved by direct contact with the authors. Air quality data was similarly
reviewed and scrutinized. In two cases it was discovered that monitoring
results were not reliable. In organizing an emissions inventory, checks
were made against several existing inventories to insure that no signifi-
cant and inexplicable discrepancies existed. Although a very approximate
air quality-emission level relationship has been used, this relationship
was developed from an analysis of air monitoring and emission data rather
than just arbitrarily assumed.
However, many uncertainties could not be resolved, either because the
relevant data were unavailable or because the effort involved would well
exceed the scope of the project. Thus, many unknowns remain. The results
of this study should be interpreted with these possible errors in mind.
The main areas of uncertainty are briefly summarized below:
Hydrocarbon Reactivity Assumptions
The issue of hydrocarbon reactivity is a very uncertain area in
air pollution control. Several reactivity scales have been developed.
Although these scales generally agree on many hydrocarbon compounds,
very significant disagreement exists concerning others. The present
study uses recent EPA reactivity results for mobile sources and APCD-
ARB reactivities for stationary sources (except for gasoline marketing
where EPA factors are used).
Under nearly all alternative reactivity assumptions, gasoline
powered motor vehicles are the dominant RHC source in Los Angeles.
209
-------
Thus, the implications of traffic control are much the same under
different reactivity assumptions. However, alternative reactivity
indices can lead to major changes in the estimated contributions from
stationary sources, (from around 10% to 25%). This, in turn, leads to
considerable uncertainty in the overall effectiveness of stationary
source control.
Compliance with Traffic Abatement Measures
From the transportation data base used in this report, fairly
accurate estimates can be made of the amount of VMT associated with
various activities (e.g. recreation, work, shopping, government work,
fleet vehicle travel, major firm work, etc.). The VMT reduction from
completely eliminating these activities, (not counting substitute
driving), is thus fairly certain. However, much uncertainty exists
in the amount of compliance to be expected from an attempt to eliminate
these activities. Compliance will depend on the degree of public
knowledge and acceptance as well as the impact of enforcement and
implementation procedures. Much of this will not be known until the
measures are actually tried.
Substitute Driving
Related to the previous qualification is the Issue of substitute
driving. When certain activities are shut down, VMT related to these
activities is cancelled, but extra VMT may be created in other categories
For instance, in Section 2.2.6 it is estimated that eliminating work re-
lated VMT on weekends results in an increase in other types of travel
amounting to about 1/5 of the cancelled work VMT. However, during an
air pollution alert, public consciousness may well prevent people from
210
-------
doing extra driving in non-cancelled activities. This effect was, in-
fact, indicated by a poll of the federal employees on leave during the
July 26, 1973 alert. Assuming the results of the poll are unbiased,
the federal employees exhibited no (and possibly negative) overall sub-
stitute driving.
Whether positive, negative, or any substitute driving can be ex-
pected from the general public during an air pollution alert is not
known. To be conservative, the normal weekend substitute driving effect
was included in the VMT reduction calculations made in this report.
Air Quality Forecasting
A basic dilemma encountered in this study concerned the necessity
of using forecasting episode criteria for a contingency plan to be
effective. However, forecasts on episode type days are not very reliable
Ways of improving forecast accuracy are discussed in Section 4.1.3. It
is not certain how much forecast reliability can be improved. Further,
it is not certain how much forecast errors will inhibit the overall
utility and consistent application of the contingency plan program.
The Air Quality-Emission Level Relationship
An air quality-emission level relationship for episode control has
been developed here by comparing average weekend/weekday pollution
reductions and emission reductions. This result accounts for residual
pollutants and non-linearities in the oxidant-precuser relation in a
very approximate way. Two separate uncertainties are involved in
applying the relation to any given episode. First, the relation is
not exact, even on an average basis. Second, the effect of residual
pollutants depends on specific meteorological conditions, and thus it
211
-------
changes somewhat from episode to episode. Fortunately, most oxidant
episodes occur in the rather consistent summer-fall meteorological
pattern for Los Angeles (strong daily sea breeze and weak nocturnal
land breeze). Although the air quality relation developed here is
a "first approximation," it should provide a very significant improve-
ment over arbitarily assumed relations, (e.g. proportional roll-back).
212
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APPENDIX A
EVALUATION OF INTERIM EMERGENCY ABATEMENT ACTIONS
(July 1973)
This Appendix provides a brief evaluation of the Federal interim
emergency air episode program, and is based mainly on the alert action
of the 26th of July, the sole occasion the "previous day prediction" plan
has been instituted.
A.I The Interim Emergency Air Episode Plan
Scheduled for adoption this fall, the air pollution emergency
contingency plan will be in operation too late to be applied during
the majority of the 1973 smog season experienced in the Los Angeles
Air Basin. In the meantime, the EPA has been charged (under the Clean
Air Amendments of 1970) with implementing an interim emergency episode
program. In establishing such a program the EPA has requested each of
the federal agencies located in the Los Angeles Air Basin to submit a
voluntary air pollution episode emergency abatement plan. At the time
of this writing (two months following the request), 45 of 90 federal agencies
contacted had submitted a proposed interim plan. The abatement actions of
these plans are to be voluntarily executed by the respective agencies when
smog episodes are either forecast by the EPA (corresponding to an
oxidant-level prediction of .40 PPM), or when they occur without
previous day forecast. The plan of action for a previous day pre-
diction" is usually quite different from the "same day" episode in that
more decisive action is generally planned when the episode is predicted
the day before its occurrence. Table A-l is a summary of the partici-
pating federal agencies and the voluntary abatement plans they have
submitted for a previous day alert prediction. The plans are comprised
A-l
-------
Table A-l, Federal Agencies Participating in July 26 Air Episode Abatement Action
AM'iln All!?
HAIOUACTEH'.,
LOr.A' IT!
,; •, 'WM ,,JdM
nT.rrr
417 3, Httl Str^t
? CrfSarl^nt Of *h*
'' ',. Secret Service)
jl? '. 3rrir.(; Street
Los Anqdei. Calif
4 U.S. Forest Service
lolela. Calif
o i. cosul Servlc*
P 0 Bo* 3399
6 Long be*c^ l*av*l
ifttfiyarC
Lorvi teach, Cal If.
7 U.S. District Court
Los Angeles. Calif.
8 U.S Department of
Justice (FBI }
} 1000 W1 lihlre Blvd.
Los Angles, Calif.
9. National Aeronautics
(NASA)
10 Deparbnent of The
Air Force
4727 Kllshlre Blvd.
LOS Angeles, Calif.
N ippfb (j
<•',['.<•'
• "KO'cr
1390
77
139
7000
350
750
appro* )
39
93
U.A;'' ILtHFNT', Of
MCCKIM ABflTEMl'IT
PlAfi 'JJfiwiTTtL TO EP/
- me ^'0/e^ to o*
tr.vtl curt^)^
hol idaj
,.p to 75t of tmD|oyefi
on *orli loed priority
Travel to work
encouraged to be via
bicyde, on foot, or
public transportation,
* Three different plani
(condition 1,213)
of var/lr.9 degree* of
activity curti1!»>ent
depending on severity
of smog anticipated
and priori ty of
«m.
Urge employees to use
car pools.
• Urge employees to me
c«r pools irnl public
transportation.
23 ejnp)oje«i to t*
5 *mploye« to b<
assigned on hoi 1day.
Reduction of 1875
VKT from curtfltl«nt
of department vehicle
uSBOe
[>l',DH Of EUCUTIO'.
filC1 PCL^^D
tOMHfNH
flan oil/ DArual I/
""!•';«" s"r un"rt
(rwde Initially
lat- Tjpsrh/, t^-P
^galn lale rfecinf'^^/',
Plan fully eMPcute^.
EPPLC'Lt', 0V
*C.1'IMr.*P/T!/E
LE*,'[ 0^1: ro
^C.' 'OH
•!».,«
None
None
V'tDuCMOr. OF V-r
0r CijPTAH."[',T
Oc OrnciH VCHJO-t
IjS^A
Cu--talUd aopro- JO" ,
minimal.
None. (Nature of
utll liatlon of
vrhlcle travel.;
Horn (Katun- of
work requires
department to b*
In ful 1 pfwretlon. )
wEL/JtT[Ofi Of ^T
£' CAR POOL 1 10.
p';6L 1C
TRAM5PO?~AT1DM
Neil^ible.
H^gl iqifle
ooo 1 s ignored.
Ke^Holble
Nenli^ible
^«!UE T°:P'
= [Du(.LL- £Y
'.ANCLLLA-:OJI -jf t'JP.UC
JlilT: 70 AuE'lCr
OD-.ervO
,»n, «n-., „„»„
'tort ••orr.a! na-iber
of visitation cr>ntarts
•tone. '11 scheduled
appolnti^ents and usgal
carried out .
-',:;< ' PlA'.TIfj'l
• , ; i - [ ? : '-. At
/WHMl ,i A:.'l /,-
n-.jnt-nen!. p^'.ud^OS )r0r n>;^a ar,d
-.^ ,e-,Pn,r«n, p^rts-.Kd ar-,rjr.-
™ -,ni
-------
Table'A-1. Federal Agencies Participating in July 26 Air Episode Abatement Action (Continued)
or IMTE»EIIT «c:io; CXECLTUD J'JIY 26-
AGENCV AND
HEADQUARTERS
LOCATION
11 . Federal Aviation
Administration (FAA)
Los Angelas , Calif.
12. National Transportation
Safety Board
Los Angeles, Calif.
13. Bureau of Indian Affair!
300 H Los Angeles St.
Los Angeles, Calif,
14. Ofrice of Information
1016 N McCadden PI .
Los Angeles , Cal If.
15. U.S. Geological urvey
Los Angflei, Cal f,
16 Department of Th Army
Los Angeles, Cal f,
i7. U.S. Government Small
Sasinei* Administration
649 S Broad-ay
Los Angeles, Calif.
18 U.S. Marine Corps
El Tore (Santa Ana)
Calif.
19. U.S. Department of
Justice
Los Angeles, Cal!f.
20. U.S. Savings Bonds
Division
11000 Ul hhtre 8)vd,
Los Angeles, Ca] f.
?1 . Securities and Exchange
31? N Spring St.
Los Angeles, Cal f.
NUMBER Of
AGCNCV
EMPLOYES
1400
8
20
134
10
1790
160
D.OOO
80
15
40
MAIN CLEMENTS OF
INTERIM ABATEMENT
PLAN SUBMITTED TO EPA
• 700 employees to be
on leave.
Encouragement of car
pools and curtailment
usage.
18 employees to be on
holiday; remaining to
arrive at work by
car pool
Comander 1n charge
to be taken. Among
personnel will take
Approximately 15
employees to be placed
car pools.
146 wi01oy«s to bo
on hoi iday.
* Up to 4250 military
personnel on hoi Iday.
Most of 1500 civilian
personnel on hoi Iday.
curtailment of fedaral
vehicle usage.
Approximately 64
employees to be on
hoi id^y.
All IS employees to
be on holiday.
Al 1 40 e-nployeej to
be on holiday.
DECREE OF EXECUTION
AND RELATED
COMMENTS
Plan not Implemen ed.
Th s age cy li wi h-
ho d ng articlpa Ion
un 1 th CPA Inl iates
ma d tor and col active
pa t dp lion of 11
ag n les.
t had not yet been
pproved by comwndtng
nnounced (Plan was
ubmltteO to EPA 2$ July.)
Plan Implemented only
part ally. Short not ce
made execution di ff Ic 1 1
nd severity of e*pec e«J
eld sufficient by Oe t.
f Defenie to warrant
ull act on.
EI-PLOVECS OH
ADMINISTRATIVE
LEAVE DUE TO
ACTION
Token number.
REDUCTION OF VMT
6T CURTAILMENT
OF OFFICIAL VCHICLC
USAGE
None
0 fklal vehicle use
c rtatled slightly
b t quant 1 ff cat ton
o VMT is indeter-
REDUCTiON OF VMT
BY CAR POOLING,
PUBLIC
TRAhSPORTATlOS
None
None
negl fq'blt
NUHBER OF
VEHICLE TRIPS
REDUCED Br
CANCELLATION OF PUBLIC
VISITS TO AGENCY
'tone
'i^np
None. (Visitation travel
(although pot substantial)
»as carried out as usual
AGFNCY PEACTIO^
TO AIP EPISODE
AMTEuEtfT ACTION'
Feel EPP nas taken e fectlve a proach
by r questing unilate al volurt r-y abats-
nxtnt actions, and oil of the f oerjl
aqcn lei. Instead, I is felt hat EPA
fo^ these across '.He board.
favoraoU attitude rega-dlng concept
be f-vident in initial abdtc^nt efforts -
enforced within the agency
DISRUPTION OF
AGENO OUSJNG
ACTjOfl
Non . (However,
-------
Table A-l. Federal Agencies Participating in July 26 Air Episode Abatement Action (Continued)
—!?••
Board
" ^:r™°'
]'J, ', f.rry it.
,'J , S Civil jfrvlce
851 ' Broadway
Los Angeles . Call f
MOOO WiKMre BUJ
Los Ar-eles. Lal it.
2!. n. s General Actouit'ng
Office
iLXJ N, Los Angpli", Si
LCI Angeles, Call'
^H U S. Denartr>ent of
II 000 Wt'shlrc 0Kd.
29. Internal ct>veiui? Service
30C ,'i Los Anyeles St.
Los Anrslf, . CjHf.
* Wes—n Regional
300 N. Los Angeles St.
Los Angeles, CaHf
31 . U.S Forest Service
Pasadena. CaHf.
(Eur«au of Alcohol ,
Tobacco, and Ffreat-ws)
(Headquarters In
•!K,
37
101
'30
!26
2100
3
00
00
OF MAIN ELfO.'T' OF
IIITEP1K ACATEMEMT
ES PLA,'I 'jUUHJTTED TO EP1
be on holiday-
33^10,..^ to b, on
"^rrtr^ r'™tn~
Car -jools and public
hoi iday. Use of rotor
[tools tjrtal led.
Al 1 employee! (45} to
be nn hoi iday.
90 employeas lo be on
hoi Iday.
Appro, ImatMy 81
Other enployees urged
of transportation to
reduce V«T.
* All (£100) enoioyee-,
to be on hoi iday.
All (31 ) ernnloyees
to go on hoi iday.
Several nwasures t«1ng
lak?n as part of ongoing
program to reduce
pollution (I) conversto
of vehklei to dleiel an
LPG fuel ; (2) closing al
burnlnij dumps . will als
encourage c.ir pools.
Some employees to taVe
leave. Others to exer-
cise Individual discre-
tion (n curtal 1 ing
vehicle ntleag«
t
DEGPEE OF EXECUTION
AND RLI/-TF.D
COMMENT:
Plan only partially
could not justify the
execution and the
EPA directives. In
difficulties also
Plan fully executed.
E^PL^fCT j OH
ADMINISTRATIVE
LCPVE DUE TO
ACTION
Nore
2100
PEDUCT10N OF VHT
Br CURTf.uvrNT
OF OFFICIAL VEHICLE
r,/,r,E
•njtely fcO" reduc' Ion
0' motor pool
activity
^DO>~O» t""a tel ^ 25,000
REDUCTION OF V^T
6' CAR POOLI'IG,
PUBLIC
TRA'tS^ORTAI ION
Not Aprllcable
JULY ?6
VEHICLE TRIP'j
REDUCED ov
CANCELLATION OF PUULIC
VISITS TO AGCNCY
SCO
AGENCY REACT ION
TO AIR EPISODt
ABATrMFHT ACTION*
ty.
D1 a polntmtnt was expressed regard) g
r.o f slon about onrDttiMnt to eptsod
c 1 rr on preyed ng day (Wednesday) This
e poor tone, o^e concern also no ed
•3 n les (EPA, A CO, ARB}. Agency r -
nls^r -'" "" be'""!" "™C"' ""
*
-
t
DISRUPTION OF
AGLNCT DURING
ACM UN
Intern \ o-srup-
signif cance.
Backlo generate
--Mjft -o»l^.
-------
Table A-l. Federal Agencies Participating in July 26 Air Episode Abatement Action (Continued)
AGENCY AND
HEADQUARTERS
LOCATION
33. Department of The
Air Force
Los Angeles Office
of Information
11000 WlUhtre Blvd.
Los Angeles, Cal If.
34. Agricultural Research
Service
P.O. Bo« 2326
Riverside, Calif.
J5. Naval Regional
Procurement Office
312 N. Spring St.
Los Angeles. Calif.
36. Department of The Navy
(Navy flecruHIng UistMc
4727 Uthhlre Blvd.
Los Angeles. Calif.
37. General Service-.
Administration
Los Angeles. Calif.
38. Forest Service
San Bernardino. Calif.
Immigration and
Natural Izatlon Service
Terminal Island
40. Defense Contract Audit
Agency
1340 W, Sixth St.
Los Angeles. Calif.
Regional Office
Los flngeles, Cal If.
UMBER 0
AGENCY
MPLOYEE
e
66
109
162
)
542
113
527
iHAIN ELEMENTS OF
INTERIM ABATEMENT
PLAN SUBMITTED TO EPA
Car pools and publ 1c
organized.
5fl employees to be
placed on hoi Iday.
Commanding supervisors to
takp Initiative 1n forma-
tion of car pools,
110 emoloyees to bo
placed on hoi Iday , Use
of government vehicles
curtailed.
• 365 employees to go on
hoi Hay. Government
vehicle usage to be
be urged for employees
not on hoi Iday.
Encourage car pools,
eliminate vehicle
trips where possible.
car pools and use of
publ 1c transportation
whure possible.
Employees requested to
form car pools or use
puhltc transportation.
roent. Use of public
pools to be encouraged.
AD government vehicle
DEGREE OF EXECUTION
AND RELATED
COMMENTS
Plan partially
executed. Internal
approval of plan had not
agenc Instituted
plan ue to short
notic "previous
given late Wednesday.)
EMPLOYEES ON
ADMINISTRATIVE
LEAVE DUE TO
ACTION
(these were al 1
aytlme empl yees'
Note that 4 0 of
chedule. T Is
11 be alte ed In
ar future, hw-
er, when o ly
0 employee
11 work th
ght assignment)
None
REDUCTION OF VHT
BY CURTAILMENT
OF OFFICIAL VEHICLE
USAGE
Approximately 3000
miles.
Very mlno reduction.
of work ( aw enforce-
majority f travel
Approximately 1500
miles.
REDUCTION OF VM7
BY CAR POOLING,
PUBLIC
TRANSPORTATION
No e. (a pools
no emph s ed due to
ve y 1 1m t dflytlme
tr vel 1 rpoois).
Negl Iglble. Approxl -
or carpools - t Is
creased due to ngolnq
Negl 1 giiile
NUMBER OF
VEHICLE TRIPS
REDUCED 8V
CANCELLAT ION OF PUBLIC
VISITS TO AGENCY
None. Observed normal
number of walMn contacts.
None observed - normal
*•"• /'°™<' '«'»".,
AGENCY REACTION
TO AIR EPISODE
ABATEMENT ACTION*
Close proximity f this aqenc to
Federal Informal on Center (r cinl-
enl of numerous omplalnts an In-
enlsode alert ac Ions. Gpner 1 con-
Agency record 1) hanrony between
2) a local spotesnwn for fPA br availa-
ble during actions, and 3) jn emergency
publ Ic net'di,
Basically lyrical reaction tr "holiday'
holiday ipUure wuuld include vehicle
liglitncnt to abatement objectives Qe
wishes to participate 1n smog alert
.let ions
DISRUPTION OF
AGfHCY CORING
ACTION
No dls uplinn apparent.
(full xecutlon of pUn
not ei ected to cause
to nat re gf work -
hacklo Is quickly
None
slant la) backlog pro-
t' I Cm .
cn
-------
Table A-l. Federal Agencies Participating in July 26 Air Episode Abatement Action (Continued)
- DESCRIPTION OF ABATEMENT ACTION EXECUTED JULY 26
A&ENCY AND
HLADQUARTERS
LOCATION
«?, Ve;erans Acjnl nl stra I ton
Supply Subdepot
*'47 5. Eastern A«.
Bell . Calif.
43 Veterans Administration
Reqlon*! Hrdlcal Dlstrlc
of Southern Col ( fomtt
Us Angrles, Calif,
44 Marine Corps Pub He
Affair! Office
11000 WUshlre Blvd.
Los Angeles. Cal If.
air episode abatement
plans.
All agencies of
predicted major (T
slgnlf 1carx:e (baled re
on submitted 93
abatement plan). ag
tmt
am
ag
su
ab
Pi
IUMBER 0
AGE NO
:WLOYEE
30
9050
6
9.345
h j
pre ents
t o all
enc
ployment
ong those
snc ei
bral ttng
ilefwnt
ns.)
MAIN ELEMENTS OF
INTERIM ABATEMENT
PLArt SUBMITTED TO EPA
ran 2B to 8 for
rrlval at work place.
ancel all use of
government vehicles.
' urtal) flpency vehicle
saqc to mlnlnum.
ncouragp Curtailment
f private vehicle use.
4 employed to be given
holiday. Official
vehicle usage to bo
cancelled.
14,540 erooloyeei to be
on holiday. Car pools
and public transporta-
tion to b* urged .
curtailed extensively.
13,650 employe*! to b«
on hoi 1day (thli
represents 941 of all
employees to be on
holiday during full
Implementation epfso by uch of agffnclei *bove.
Thtie plsnj w-re obUlnrd for evaluation fro* the EPA Regional Office.
Denotes agenclei xMch are of Mjor significance In overall air pollution epliod* f«^r*l abatownt plan.
•Kajor jlgnlflcifKe' Is assigned on the basis of total matter «p'oy«i •«! ttsgre* of atatanent action planned.
The igencles of major significance were Included In th« telephone Survey of this study.
-------
mainly of three types of abatement measures:
1) Administrative leave to employees.
2) Curtailment of official vehicle use, and
3) Encouragement to share vehicle travel by carpooling
or use of public transportation.
As can be seen in Table A-1-, the measure of administrative leave varies
markedly among those agencies submitting plans.
Total employment of the 45 agencies submitting smog episode abate-
ment plans was 42,407, or about 36% of the 118,000 federal employees
in the South Coast Air Basin [A-l]. The majority of the agency abate-
ment plans provide for implementing some degree of administrative leave.
Complete execution of each separate agency plan would result in a
"holiday" for 14,540 employees throughout the South Coast Basin.
A.1.1 Initiation of the Plan
On Wednesday afternoon (July 25, 1973), the EPA contacted the
various agencies submitting plans, requesting they implement their
Emergency Air Episode Plan. The EPA request was supported by the
announcements of Gordon Elliot, chairman of the Federal Executive Board
in Los Angeles. In addition, announcements of the intended air episode
abatement implementation were carried over television networks, the
radio, and newspapers. This "previous day" advisory presumably
allowed the various agencies to initiate advance telephone notification
to all employees targeted for participation in the abatement action.
In addition to the action planned for Thursday July 26, the EPA
had also attempted to initiate an action for the 25th. The advance
notification provided by the EPA in this instance (late Tuesday evening)
was insufficient to allow a "previous day prediction" action to be taken
A-7
-------
In fact, due to the lateness of the notification, the Federal Executive
Board in Los Angeles refused to support a full fledged abatement action
recommending instead that a "present day" abatement action be imple-
mented on the 25th. As a result of the uncertain format in directives,
only a partial abatement action was voluntarily implemented by the
federal agencies on the 25th. Because the abatement effort of the
25th was minimal and unrepresentative of the potential mobilized "present
day" version of the federal air episode abatement plan, the scope of this
investigation did not include an evaluation of the actions taken by
agencies during this day.
A.2 Survey of Agency Participation
Presumably only those agencies which had already submitted air-
episode abatement would have participated in the July 26th air pollution
abatement action. The degree of action executed by these agencies on
the 26th was determined by telephone interviews with the air pollution
episode coordinators (or other cognizant officials) of the respective
agencies. The participating level of those agencies which had not
submitted plans was also briefly evaluated in this telephone interview.
Additional information regarding individual employee participation was
obtained by means of a questionnaire survey which will be discussed
in the next section.
The telephone inquiry of each agency was constructed to reveal:
e The level of commitment demonstrated by the agency
in carrying out the submitted plan.
§ The number of employees on leave.
e The reduction of VMT due to curtailment of official
vehicle usage, and by sharing of commuter travel in
carpools and public transportation.
A-8
-------
• The reduction in normal number of vehicle trips achieved
by cancellation of public visits to the agency.
• The degree of disruption experienced by the agency during
the action.
• The agency opinion and reaction to the overall emergency
air episode action.
• The operational problems associated with implementation
action.
Due to time constraints imposed on the study, only 14 of the 45
agencies submitting emergency abatement plans were included in the
telephone survey. This limited sampling was justified on the basis of
the significance of the selected agencies in terms of: 1) their over-
all employment numbers, and 2) the apparent strength of their abatement
plan. The 14 agencies represent a combined employment force of 39,345,
or 93% of the combined employment from all agencies submitting abatement
plans. According to a tabulation of the proposed abatement strategies
(Table A-l), 94% of all employees expected to be on leave during a
full implemented emergency abatement action are employed by the 14
agencies in the interview survey.
A.2.1 Results of the Agency Survey
Table A-l provides the summary of the inquiries made to the selected
major agencies which had not submitted air episode abatement plans
before July 26. The results confirm clearly the assumption that
agencies in this category did not participate significantly in the
abatement order.
Table A-1 provides a summary of the inquiries made to the selected
agencies. Several findings were apparent. It can be seen that the
majority of agencies surveyed did not participate in full accord with
their submitted plan. The more disruptive the submitted plan, the less
A-9
-------
Table A-2. MAJOR FEDERAL AGENCIES WITHOUT PLANS - PARTICIPATION IN JULY 26 ABATEMENT ACTION
Agency and
Headquarters Location
Number
of Agency
Employees
In Basin
Notification Received
Requesting Action on 26th
Action Taken by Agency
Defense Contract Administration
Services Region
11099 S. LaCienega Blvd.
Los Angeles
2448
Received telegram requesting
action by EPA on 26th.
Received no official advance
notification except by
news media.
Essentially none.
Commander chose to continue
work routines as usual.
A plan is now being prepared
for jiext air episode
prediction.
>
CD
Naval Station
Long Beach
1000
No official notification received.
Only knowledge of proposed action
was by newspaper and TV
announcements.
No action was taken.
This agency will be phased
out in June, 1974, and
probably will not formulate
plan in interim
Naval Underseas Center
3202 E. Foothill Blvd.
Pasadena
570
EPA telephoned on afternoon of 25th
to issue "previous day" episode
prediction. Telegram from EPA
was received on 26th.
Agency encouraged employees
to use public transportation
and car pools. Official
government use of vehicles
was rescheduled when possible
(40 vehicle trips to
San Diego cancelled).
-------
THE INTERIM FEDERAL EMERGENCY AIR EPISODE ACTION
This questionnaire 1s being circulated to determine the effect of the emergency smog episode abatement actions 1n the Los Anoeles Basin on July 26 1973-
The action consisted of federal agencies participating In a voluntary plan aimed at reducing vehicle mileage In the basin. Some of the agencies were shut
down, while others encouraged their employees to share rides to work. Many agencies curtailed official vehicle usage.
Tne f1n^ air pollution ewsrgency air episode plan 1s scheduled for adoption this fall. Until it is adopted, the Interim version of the plan (as
implemented July 26) will be applied. Because the Interim plan consists primarily of participation by only the federal agencies, its Impact is minimal
compared to the expected final version. However, the actions taken during July 26, and specifically the overall behavior of federal employees with a role
in the plan, will provide the Environmental Protection Agency (EPA) with Important Indicators which will be helpful in formulated the final emergency air
episode plan. Your caraful and anonymous responses to this questionnaire are an essential ingredient in providing the EPA with some of the accurate
Indicators needed.
The questionnaire 1s being conducted for the EPA by TRH. It has been distributed randomly among several employees of your agency '
be entirely anonymous_. and all returns are to be maintained 1n TRW's possession. Please return your response by folding this postaged qu<
Indicated, and mailing. y
Please dispose of any Inquiries you may wish to make by phoning George Richard. (213) 535-1592, or
Environmental Operations Group.
The answers are to
iestionna1re as
John Trljonis (213) 535-1571. of the TPW
How do you normally travel to work. (If your mode of travel differs
during week, please respond for Thursday. Note that the emergency *
action was called on a Thursday). - -.. • . JB»
If you normally 90 to work In your own vehicle, estimate the total
miles of commute and work-related driving (to work, at work, return
home) you would usually accomplish on a Thursday. i rm ,
How were you notified you should not report to work? •
Please state briefly your reaction to the air episode abatement
action (I.e., do you think the current plan has any value, should
It be used again, what are Its weak points, how can 1t be
Improved, etc.)?
1. a. Alone (or w1th fami1v member) In a personal motor vehicle
b. In personal vehicle with family ntember who uses vehicle during day
c. By carpool (with one or more other persons travplina to work)
d. Public transportation
e. Walk
f. Bicycle
o. Other (airplane, boat, roller skates, etc.)
Estimate the miles of driving you and your family would normally do •
on a Thursday 1n all your family vehicles (this includes normal
driving to work, work-eelated driving, shopping trips, escort trips, ,
visits, etc.). jfr
Estimate actual miles of family driving 1n family vehicles durina
the day of the smog abatement action (Thursday, July 26, 1973). —s^-,
Which of the following describe the purpose of trips you made 1n
your vehicle during the July 26 smog episode abatement action. —H
miles
miles
les
5.a. For shopolno
b. For recreation
c. For social visits
d. Alternate work
e. Other
f. Did not make any trips
6.a. Telephone at home
b. Announcament at work the day before
c. Not officially notified, made decision based on news media
d. Telegram at home
e. Other (please describe)
Figure A-l. Survey Questionnaire for Federal, Employes on Administrative Leave July 26
-------
THE INTERIM FEDERAL EMERGENCY AIR EPISODE ACTION
This questionnaire Is being circulated to determine the effect of the emeraency smoa episode abatement actions in the Los Anqeles Basin on July 26, 1973.
The action consisted of federal agencies participating In a voluntary plan aimed at reducing vehicle mileage 1n the basin. Some of the agencies were shut
down, while others encouraged their employees to share rides to work. Many aqendes curtailed official vehicle usage.
The final air pollution emergency air episode plan Is scheduled for adoption this fall. Until 1t Is adopted, the Interim version of the plan (as
Implemented July 26) will be applied. Because the Interim plan consists primarily of participation by only the federal agencies, Us Impact 1s minimal
compared to the expected final version. However, the actions taken during July 26, and specifically the overall behavior of federal employees with a role
In the plan, will provide the Environmental Protection Agency (EPA) with Important Indicators which will be helpful 1n formulating the final emergency air
episode plan. Your careful and a_nonymou_^ responses to this questionnaire are an essential Ingredient in providing the EPA with some of the accura_te_
1ndicators needed. ~
The questionnaire Is being conducted for the EPA by TRW. It has been distributed randomly among several employees of your agency. The answers are to
be entire]^ anonymous, and all returns are to be maintained in TRW's possession. Please return your response by folding this postaaed questionnaire as
1ndicaTed, and mai11ng.
Please dispose of any Inquiries you may wish to make by phonlna George Richard (213) 535-1592, or John Trljonis (213) 535-1571, of the TRW
Environmental Operations Group.
1
2.
3.
4.
5.
6.
7.
How do you normally travel to work. (If your mode of travel differs
during the week, please respond for Thursday, Note that the emergency
On the day of the air episode action, how did you travel to work? — **»-
If you normally go to work In your own vehicle, estimate the total
Estimate the miles of driving you and your family would normally do
on a Thursday In all your family vehicles (this includes normal drivinq
to work, work-related driving, shopping trips, escort trips, visits)-£a*
Estimate actual miles of family driving 1n family vehicles during the
day of the smog abatement action (Thursday, July 26, 1973). - s>
How were you (or were you?) requested to participate in sharing of
Please state briefly your reaction to the air episode abatement action
(I.e., do you think the current plan has any value, should it be used
again, what are its weak points, how can it be Improved, etc.)?-"**"
• i ..
• b.
• c.
• 1:
• f .
• q-
*2. «•
• b.
• c.
• I:
• f.
• g.
e
• 3.
•
•* 4.
t
"* 5
8 6. «
. b.
c.
•
»
. d.
• 7.
•
•
Alone (or with family member) in a personal motor vehlc
In personal vehicle with family member who uses vehicle
By carpool (with one or more other persons traveling to
Public transportation
Walk
Bicvcle
..... , .
In personal vehicle with family member who uses vehicle
By carpool (with one or more other persons traveling to
Public transportation
Walk
Bicycle
Other (alrnlane, boat, roller skates, etc.)
mi les
miles
miles
le
during day
work)
dunna day
work)
By company request the day before the action
I was not aware of any such requests
No particular request was made for the dav of the action, however
the company is promoting an ongoing program to encourage car-pooling
and publ ic transportation
By news media and previous understanding of my company's emergency
action plan
Figure A-2.
Survey Questionnaire for Federal Employees of Agencies
Encouraging Transportation' Sharing
-------
reported receiving a large number of telephone inquiries regarding their
open/close status on the day of the abatement order.
Few agencies (except for those that shut down) noted significant
changes in their contact activity with walk-in clients on the 26th, although
numerous telephone inquiries were made the same day to ascertain the open/
close status of some agencies. At the two major agencies with shut down
abatement procedures, the cancelled number of walk-in visitations was
estimated at approximately 7500. Agency disruption produced by abatement
action depends on the degree of execution of the abatement plan, the
abatement plan itself, and the nature of service provided by the agency.
Almost all agencies reported minimal disruption of their operations on the
26th. However, several of these agencies (those with a proposed plan
including significant administrative leave) conceded a full execution of
their proposed plan would generate appreciable disruption and cause
irreconcilable problems in the short term.
A.3 Survey of Agency Employee Participation
The successful implementation of the federal agency emergency air
pollution abatement plans depend on the conscious behavior of the individual
employee to voluntarily reduce their personal vehicular travel. Hence, those
employees on administrative leave-the day of the action were expected to stay
home and minimize their travel in family vehicles, and the employees of
agencies advocating transportation sharing as an abatement measure were
expected to take public transportation or travel in a carpool to work.
The actual specific actions which were executed voluntarily by
federal employees in the July 26 abatement action were determined by a
survey of individual employees of the major participating federal agencies.
The selection of the five major agencies for this survey was based on
A-13
-------
their demonstrated committment to implement their submitted abatement
plan. These agencies, their overall employee working force, and their
abatement plan, are tabulated in Table A-3 below.
TABLE A-3. FEDERAL AGENCIES OF THE EMPLOYEE SURVEY
Federal Agency
No. of Employees
Emergency Abatement Plan
Internal Revenue Service
Department of Health,
Education and Welfare
Federal Bureau of
Investigation
Veteran's Administration
(Regional Medical District)
2100
1140
750
9050
Employees on Leave
Employees on Leave
Transportation Sharing
(Car Pooling, Public
Transportation)
Transportation Sharing
Of all the federal agencies employing an administrative leave policy
the day of the abatement action, the two selected in the employee survey
accounted for 86-1/2 percent of the entire work force on leave. Of all
the plans of encouragement to participate in sharing of transportation,
the three selected represent agencies of major committment to the plan.
The survey was conducted with the use of brief and anonymous
questionnaires distributed randomly among several employees of each of
the selected agencies. Two separate questionnaires were formulated. For
those employees on leave, the questionnaire (see Figure A-l) was structured
to provide information about the following specific items:
© The employee's normal mode of travel to work
e The usual vehicular travel the employee and his family are
responsible for on Thursdays
e The vehicular travel (mileage and trip purpose) the employee
and his family were responsible for during the July 26 smog
abatement action
e The means by which the employee was notified to participate in
the July 26 abatement action
e The employee's personal reaction to the air episode abatement
action.
A-14
-------
likely was its full execution. Of a total of 13,650 employees targeted
for leave under full implementation of all federal agencies' voluntary
emergency episode plans, only 3,379 (25%) were absent from work on the
26th of July.
The reasons given for failure to fully implement proposed abate-
ment actions were varied, but could generally be accounted to the
following:
» The confusion and uncertainty which had been generated
by the initial attempt of the EPA to direct a "previous
day" action for the 25th (see previous sections).
Additional uncertainties were generated by apparent
disharmony among the various air pollution agencies
(see section A.6!2) as conveyed by the media. Amid the
resulting uncertainty, several agencies reported they
were unable to justify a complete execution of their
plan.
o Internal administrative details remained to be resolved
before full execution of the plan was possible.
o Action was withheld pending resolution of conflicts
created by the unilateral and voluntary plan submittals.
Almost all agencies reported a carry-through with a gesture to
encourage carpooling or other form of ride-sharing. In general,
however, spokesmen for the various agencies estimated the effect of
encouragement to participate in carpooling and public transportation
as negligible.
It was assumed by most contacts that the well established travel
habits of employees could not be altered on the short-term notice typical
of previous day abatement mobilization attempts. An effort to confirm
these agency impressions by seeking public transit passenger data only
revealed that daily passenger counts are not recorded in the Rapid Transit
District [A-2]. However, a spokesman for the Rapid Transit District was
A-n
-------
quoted in the newspapers as saying there were no apparent significant
increases in bus ridership during the 26th.
The majority of agencies reported activating a program which limited
official vehicle travel. It appeared that this measure caused very minor
inconvenience since almost all of the cancelled trips were reschedulable
in nature. The quantification of vehicle mileage reduction due to this
measure consisted of very rough estimates, since suitable data was lacking
in most cases. Many agencies reported an intention to maintain more complete
information of their abatement efforts during future episode alerts.
All of the participating agencies contacted in the telephone survey
reported they had received the request to implement the "previous day"
abatement plan from the EPA on the afternoon of July 25. This notification
was received by telephone in advance of agency closing hours, allowing each
of the agencies the opportunity to inform employees of the air episode order.
Nearly all of those agencies contacted also received a confirming telegram
from the EPA, in most cases on the day following the July 25 telephone
announcement. These direct communications were clearly understood by the
participating agencies, and all agencies contacted reported minimal problems
in informing employees of the air episode abatement order. By contrast, the
press releases were not as clearly understood, and many of the agencies
reported that numerous employees became uncertain regarding their proper role
in the action after being in touch with the news media. The confusion which
developed concerned the question of administrative leave. When it was
reported by the news media on the eve of the action that federal agencies
would be closed the following day, many employees expecting to report to work
began to wonder whether their agency would be participating in the leave
policy. The general public was also confused, and many of the agencies
A-12
-------
The other questionnaire, distributed among those employees of agencies
whose plan consisted of encouragement to share transportation, was
similarly constructed (see Figure A-2).
All questionnaires contained a brief but informative preamble designed
to enlighten the respondent regarding the purpose and importance of the
survey. The anonymity of the questionnaire returns was stressed in an
effort to solicit honest and abundant responses. The responses were pre-
postaged for return directly to the survey headquarters to avoid possible
complications of agency involvement.
A.3.1 Results of the Employee Survey
The survey questionnaire distribution and return rate were as shown
in Table A-4 below. The highest return rate was achieved by employees of
the Internal Revenue Service (86%). The low return rate of the Veteran's
Administration was probably due largely to the belated distribution of
questionnaires within this agency. Consequently it was expected that a
substantial number of returns would continue to be received from this
agency after the due date of this writeup.
Table A-4. FEDERAL EMPLOYEE QUESTIONNAIRE RESPONSE RATE
Employee Number of
Abatement Questionnaires % of Questionnaire
Federal Agency Measure Distributed Returns
Internal Revenue Employees 100 86.0
Service on Leave
Department of Health, Employees 110 62.7
Education & Welfare on Leave
Federal Bureau of Car Pooling, 100 68.0
Investigation Public Transportation
Veteran's Car Pooling, 200 20.0
Administration Public Transportation
(Regional Medical
District)
A-17
-------
Because the questionnaires were directed at two distinct employee
groups (those on leaves and those encouraged to share transportation), the
results were tabulated according to the same distinction. These survey
findings are discussed in the next sections.
A.3.1.1 Usual Mode of Travel
To determine the actions of the individual employees expected to
participate in the smog abatement plan, it was necessary to establish first
the usual mode and extent of vehicular travel of these affected employees.
Background information regarding usual mode of travel was tabulated from
responses to the initial items of the questionnaire, and is shown, for
each of the response groupings, in Table A-5 and A-6. Since a large
majority of the respondents drive alone to work in their own personal
vehicle, it is clear that voluntary abatement actions on July 26 could have
a significant effect on vehicle mileage traveled by those in the affected
agencies. This reduction could be achieved either by the administrative
leave plan, or by the increased sharing of transportation.
In those agencies in which employees were requested to share trans-
portation to work, minimal action appears to have been taken by the
employees to effect an implementation of their agency plan (see Table A-6).
On the day of the emergency smog abatement action, practically all employees
responding to the questionnaire reported no change in their normal mode of
travel to work. For those employees on administrative leave the day of the
abatement order, the expected change in vehicular travel was, of course,
substantial (see next section).
A.3.1.2 Reduction in Usual Vehicle Mileage Traveled (VMT)
The amount of reduced vehicle travel which each of the employee
response groups accounted for on July 26 is tabulated in Table A-7. The
A-18
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Table A-5. USUAL MODE OF TRAVEL - FEDERAL EMPLOYEES ON ADMINISTRATIVE LEAVE JULY 26
Federal Agency
Internal Revenue Service
Department of Health
Weighted Average
Mode of Travel to Work (Frequency of Responses Expressed in Percent of Total
Returns Responding to Item)
a) Alone in
Personal
Motor Vehicle
84.9
82.3
83.8
b) In Personal
Vehicle with
Family Member
Who Uses Vehicle
During Day
1.1
4.4
2.3
c) By
Carpool
11.6
4.4
8.9
d) Public
Transportation
2.3
4.4
3.1
e) Walk or
Bicycle
0
2.9
1.1
Weighted averages are calculated based on the proportion of employees an agency contributes to the overall
number of federal employees reportedly participating in the particular type of abatement plan.
-------
Table A-6. CHANGE IN MODE OF TRAVEL - FEDERAL EMPLOYEES WHICH WERE URGED TO SHARE TRANSPORTATION JULY 26
Federal Agency
Federal Bureau of
Investigation
Veteran's
Administration
Regional Medical
District
Weighted
Average
Date
Usually
July 26
Usually
July 26
Usually
July 26
Mode of Travel to Work, Usual, and on July 26. (Frequency of Responses
Expressed in Percent of Total Returns Responding to Item)
a) Alone in
Personal
Motor Vehicle
64.2
61.2
57.5
60.0
57.9
60.1
b) In Personal
Vehicle with
Family Member
Who Uses Vehicle
During Day
2.9
2.9
0
0
.2
.2
c) By
Carpool
29.8
32.8
17.5
15.0
18.4
16.3
d) Public
Transportation
0
0
20.0
20.0
18.5
18.5
e) Walk or
Bicycle
3.0
3.0
5.0
5.0
4.8
4.8
I
[S3
O
Weighted averages are calculated based on the proportion of employees an agency contributes to the overall
number of federal employees reportedly participating in particular type of abatement plan.
-------
Table A-7. CHANGE IN VEHICLE MILEAGE TRAVELED - EMPLOYEES ON LEAVE AND EMPLOYEES ENCOURAGED TO SHARE TRANSPORTATION
Federal Agency
Internal Revenue
Service
Department of
Health, Education
and Welfare
Weighted Average
(Employees on Leave)
Federal Bureau of
Investigation
Veteran's Adminis-
tration, Regional
Medical District
Weighted Average
(Employees in Ride
Sharing Program)
Main Element of
Abatement Plan
Employees on
Leave
Employees on
Leave
Employees on
Leave
Sharing of
Transportation
Encouraged
Sharing of
Transportation
Encouraged
A
Usual Miles of
Work-Related
Driving (Thurs-
days) in
Personal Vehicle
34.4
18.5
28.6
51.5
14.5
17.4
B
Usual Overall
Miles of Driv-
ing (Thursdays)
by All Vehicles
in Family
54.7
41.7
49.9
77.0
33.4
36.7
C
Total Miles of
Travel for All
Vehicles in
Family on
July 26
16.5
22.5
18.6
73.2
30.3
33.5
Reduction in
Normal VMT
(B-C)
38.2
19.2
31.3
3.8
3.1
3.2
|
J
1. Mileage figures represent averages of return responses for the designated categories above.
2. Weighted averages are calculated based on the proportion of employees an agency contributes to the overall
number of federal employees reportedly participating in the particular type of abatement plan.
-------
survey results show that employees who were on leave reduced the usual
overall travel of vehicles in their family by approximately the usual
amount of work related travel they normally account for. Hence, employees
who were on leave July 26 did not appear to generate any substitute travel
in place of their normal work related driving. (If anything, the results
indicate that they also drove less other types of trips.) This trend was
in distinct contrast to the expectancy for holiday or weekend travel, when
employees off from work usually do more non-work driving than they do on a
workday. This substitute driving usually amounts to about 20 percent of
their work related VMT.
Table A-8 summarizes the nature of vehicle trips taken by the
employees on leave, and tends to explain why substitute driving (in place
of work related travel) was minimal. Only 4.3% of all trips were executed
for recreational purposes, and 42.1% of all employee respondents made no
trips at all.
Employees working for agencies which encouraged transportation
sharing as the main element of their emergency abatement plan, achieved
a very minor reduction in the normal travel of their vehicles. Table A-7
demonstrates the almost negligible (9% reduction) effect on VMT for
agencies attempting a carpooling and ride-sharing abatement plan on
July 26. This reduction apparently was due to the agency's program
to curtail work-related vehicle travel during working hours, since the
survey clearly showed that there was no increase in car pooling efforts
July 26. This confirms the findings achieved in the telephone survey of
agencies discussed earlier in Section 1.2. It is interesting to note,
however, that employees of those agencies featuring a ride-sharing plan
A-22
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Table A-8. NATURE OF TRIPS MADE .BY FEDERAL EMPLOYEES ON LEAVE JULY 26
CO
Federal Agency
Internal Revenue Service
Department of Health,
Education and Welfare
Weighted Average
Purpose of Vehicle Travel on July 26. (Frequency of Responses Expressed in
Percent of Total Returns Responding to Item)
a) For
Shopping
31.4
25.0
29.1
b) For
Recreation
3.5
5.9
4.3
c) For
Social Visits
1.2
1.5
1.3
d) Alternate
Work
3.5
7.4
4.9
e) Other
22.1
22.0
22.1
f) Did Not Make
Any Trips
41.9
42.6
42.1
Weighted averages are calculated based on the proportion of employees an agency contributes to the overall
number of federal employees reportedly participating in the particular type of abatement plan.
-------
were normally in car pools much more often than those respondents of the
survey on an administrative leave plan (see Tables A-5 and A-6). It
appears that many respondents of the survey were already somewhat instru-
mental in reducing VMT on a continuing basis, by joining in car pools and
sharing commute mileage.
A.3.1.3 Notification of Federal. Employees to Take Action
The manner in which federal employees were notified for
participation in the July 26, as determined by responses to item #6 of
the survey questionnaire, is tabulated in Table A-9. The survey results
suggest that those employees who participated in the administrative leave
policy were far more aware of their expected role in the abatement action
than were those employees of agencies advocating transportation sharing.
In fact, it appears that about one half of the latter employees were
completely unaware of their implied responsibility for the July 26 action
This data would help to explain the finding noted earlier that increased
car pooling (and subsequent VMT reduction) was practically negligible
among those employees responding in the survey. Table A-9 also suggests
that agencies exercising the administrative leave policy were successful
in providing widespread advance awareness of the upcoming "holiday" to
its attentive (and responsive) audience.
A.3.1.4 Employee Reaction to Plan
The final item of the survey questionnaire provided an open ended
outlet for respondents to express their opinions with regard to various
aspects of the emergency abatement action. The responses received were
varied and abundant. Less than six percent of the questionnaire returns
were without some type of written response on this item. Many of the
comments were of a repetitious nature and were classifiable by their
A-24
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Table A-9. MEANS BY WHICH FEDERAL EMPLOYEES WERE NOTIFIED TO TAKE EMERGENCY SMOG ABATEMENT ACTIONS
Federal Agency
Internal Revenue
Service
Department of
Health, Educa-
tion, and
Welfare
Federal Bureau
of
Investigation
Veteran's
Administration,
Regional Medical
District
Main
Element
of Agency
Emergency
Action
Plan
Employee
Leave
Employee
Leave
Trans-
portation
Sharing
Trans-
portation
Sharing
Manner of Notification. (Frequency of Response Expressed in Percent of
Total Returns Responding to Item)
a) Announcement
at Work the Day
Before Action
80.0
82.3
19.1
2.5
b) Telephone
At Home
10.4
10.3
0
0
c) By News Media
and Previous
Understanding of
Agency's Emergency
Action Plan
1.1
4.4
7.4
25.0
d) No Particular
Notifications were
Made for the Day of
the Action; However
Agency is Promoting
Ongoing Program
Encouraging Car-
pooling and Public
Transportation
0
0
29.4
20.0
e) Was Not
Aware of any
Notification
0
0
41.2
50.0
f) Other
8.1
2.9
2.9
2.5
I
ro
-------
general content. The response categories appearing to be most predominant
in theme were established from a tabulation of all returns, and are shown,
with corresponding response frequencies, in Table A-10.
It is clear that federal employees who participated in the
"holiday" type action exhibit a high regard for the value of the current
emergency abatement plan. Whereas approximately 70 percent of these
"holiday" participants thought the current plan had positive or potential
value, only about 35 percent of those federal employees participating under
the transportation sharing action thought the plan to be of value. In other
distinctions between the response of the two employee groups, it is seen
that employees exercising the responsibility of administrative leave
July 26 were far more inclined to suggest improvements for the current
plan when they believed it had value. Participants in the transportation
sharing campaign were greater advocates of rapid transit, as ten percent
of these respondents (compared to three percent of the employee groups on
leave July 26) recommended its development as the most feasible and
effective smog abatement measure.
The general reactions of federal employees illustrated in Table A-10
supports to a certain extent the social consciousness demonstrated by
each of the two employee groups in exercising voluntary actions to reduce
vehicle travel on July 26. The employee group on leave appeared to have
accounted for substantially less vehicle travel than would have been
expected of employees in the usual "holiday" situation (see Section
A.2.1.2 and Table A-7), indicating this employee group imposed deliberate
self-restraints to help achieve the goals of the abatement action.
Conversely, the employee groups which was urged to share vehicle travel
demonstrated almost negligible change in their usual travel behavior in
A-26
-------
Table A-10. EMPLOYEE REACTION TO EMERGENCY AIR EPISODE PLAN - BASED ON JULY 26 ACTION
(Frequency of Responses Expressed In Percent of Total Returns Responding to Item)
Federal Agency
Bureau of
Internal Ravenue
Department of
Health, Education
and Welfare
Federal Bureau
of Investigation
Veteran's
Administration
(Regional
Medical District)
Main Element of
Abatement Plan
Employee
on Leave
Employee
on Leave
Transportation
Sharing
Transportation
Sharing
Current Plan
Has Little
or No Value
9.3
17.6
33.8
27.5
Current Plan
Has Positive
or Potential
Value
69.7
72.1
33.8
37.5
Plan Should be
Extended to
Include Greater
Participation
(Private
Businesses &
All Government
Aqencies
44.1
32.3
13.2
15.0
Current Plan
has Weakness
In that it
Depends
Heavily on
Voluntary
Action of
Individuals
to Curtail
Personal
Vehicle
Travel
8.1
10.2
7.3
7.5
Organization,
Forecasting,
and News Media
Treatment
Should be
Improved to
Make Plan
Effective
15.1
14.7
2.9
22.5
Rapid Transit
or Adequate
Public
Transportation
the
Only Answer
3.4
2.9
10.2
10.0
NO
Response
3.4
2.9
8.8
10.0
Other
24.4
14.7
22.1
15.0
I
ro
-------
terms of mode of travel. This group did accomplish a nine percent
reduction in vehicle travel, due presumably to the agency's active program
to curtail all work-related vehicle travel during working hours.
A.4 State and Local Actions
A.4.1 Actions by the California Air Resources Board
The California Air Resources Board (CARB) assumes the responsibility
of supervisor and coordinator to the various air pollution control districts.
The ARB receives information from air monitoring stations and advises the
districts regarding expected pollution levels. When a smog siege is fore-
casted in a given district, the ARB coordinates the activation of emergency
district programs. The advisors are prepared by 9:30 am for a "same day
prediction" and by 2 pm for a "following day prediction."
Preceding the emergency air episode action of July 26, the ARB
received information indicating that sub-emergency levels of pollution
were expected for the 26th. The ARB advised the districts on the
afternoon of Wednesday (July 25) that lesser values were expected for -
Thursday, and that emergency district programs would probably not be
required as they were in some districts on July 25.
A.4.2 Actions by the APCD's
Each of the Air Pollution Control Districts (APCD's) is responsible
for executing its own distinct emergency air episode abatement program.
Emergency episode plans defining alert stages and actions originated in
Los Angeles County and have been followed since 1955. First stage
actions in the various districts include banning of burning of combustibles,
voluntary curtailment of vehicle trips, and notification of industry through
the district's emergency radio network of the alert and need to prepare
A-28
-------
for shutdown. More severe second stage actions, initiated upon
increasing pollution levels, involve shutdown of industrial operations
and,possible control of motor vehicle operations.
Since air pollution levels on July 26 were considerably less than
the first stage levels required for activation of any of the separate
APCD emergency abatement programs, no actions were taken by the APCD's
of the basin.
A-29
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A. 5 IMPACT OF ABATEMENT ACTION ON VEHICLE MILEAGE TRAVELED (VMT)
The reduction of VMT due to the emergency air episode action was
estimated in two ways: 1) based on information obtained from the
Agency and Employee surveys and 2) vehicle traffic count data obtained
from the California Department of Transportation (DOT).
A.5.1 VMT Reduction as Determined from Agency Interviews and Employee
Surveys
Through a series of assumptions based on pertinent transportation
studies, and a utilization of the Agency interview findings (see Table A-l),
the result of the various abatement actions executed on July 26 may be
may be expressed in terms of the reduction of VMT attributable to the
action.
For the case of administrative leave, the VMT reduction due to
federal employees absent from work was calculated on the basis of
mileage figures tabulated from the employee survey results (see Section
1.3.1.2). These survey findings indicate that each employee on leave
was responsible for a reduction in vehicle travel (July 26) of about
31 miles. Hence the percentage VMT reduction achieved by the 3379
employees absent from work is
3379 x 31
(Basin total weekday VMT) x 10° = '055%
Total weekday VMT in the Basin is 183,000,000 (see Table 2-12).
Total VMT reductions attributed to a new sharing of commuter travel
was also calculated on the basis of the employee survey results. The
survey indicated that employees of agencies encouraging ride-sharing
accounted for a mileage reduction of about 3 miles each. Hence the
percentage VMT reduction achieved by the approximate 22000 employees
A-30
-------
urged by their agency to participate in this plan is
22.000 x 3
183,000,000
_
x IUU ~ '
The total estimated decrease in Basin daily weekday VMT due to
curtailment of official vehicle usage was determined from the agency
survey to be approximately 37,000. This may be expressed in percentage
reduction of overall weekday Basin VMT as
37>OQO x 100 = .020%
183,000,000
The percentage decrease in overall daily weekday Basin VMT
attributed to cancellation of some 7,500 customer visits to those
agencies which were shut down during the abatement action, was esti-
mated as follows:
% VMT _ [no. of cancelled ) (average trip] [partial cancellation] ,,
Reduction ~ \ visits / x \ length / \ adjust, factor / x '
(overall weekday Basin VMT)
- 7,500 x 6.5 x % ,nn _ nny
" 183,000,000 x 10° ' '013%
In the above calculation, 6.5 (Table 2.13) is the average trip length
in the "Home to Other" category for driving patterns studied in Los
Angeles. An adjustment factof or % was assumed in recognition of the
fact that only a portion of the cancelled agency visits account for
full cancellation of vehicle trips.
The overall estimated percentage by which Basin daily weekday VMT
was reduced due to abatement actions taken on July 26 is
A-31
-------
.055 + .036 + .020 + .013 = .12%
'employees^ /car \ /official ^ /cancellation^
/customer
wisits
:employees\ /car \ /official \
on leave j (pooling)! vehicle J
' \ / \curtailment/
Most of this reduction was achieved by the shut down actions of the
Department of Health, Education and Welfare and the Internal Revenue
Service (from both employees and customers staying..home). Had all
other agencies carried out their emergency air episode plans as
submitted, the expected reduction in Basin VMT would have been in-
creased four times (based on a linear proportioning of number of
employee leaves versus VMT reduction). Carrying the hypothetical
projection further by conjecturing an air episode action in which all
federal agencies participate according to plans along the lines of
those now submitted, one would expect a .7% VMT reduction.
A.5.2 VMT Decrease as Determined from Traffic Count Data
Typical Thursday traffic patterns were considered by evaluating
vehicle counts (obtained from DOT) from the "42 mile" freeway loop
(Figure A-3). Vehicle-counts for more extensive coverage of the
Basin transportation facilities were not yet available at the time of
this study. Traffic patterns on the 42-mile loop were presumed to be
somewhat indicative of overall basin VMT, although the limitations of
this assumption are easily recognized. Table A-ll documents the
vehicle count of the loop at various selected locations for a number of
Thursdays in nearby temporal proximity to the July 26 air pollution
episode action. The data show relatively small fluctuations in the
average of the aggregated loop traffic count from one Thursday to the
next. For example, corresponding to the four dates of Table A-ll, the
A-32
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SANTA MONICA FREEWAY
Note: Arrows indicate the
location of monitoring
stations
Figure A-3, "42 Mile Loop"
Source: California State Department of Transportation
A-33
-------
Table A-ll
TOTAL DAILY VEHICLE COUNT
SELECTED STATIONS IN "1»2 MILE FREEWAY LOOP"
DATE
June 28
July 12
July 19
Aug 2
July 26
15E
102000
1023003
100200
100400
101000
SANTA
24E
130200
130900
128700
129200
129000
MONICA
15W
106200
105400
104500
105900
107200
24W
138100
137500
135900
136000
137600
FREEWAY
13N
97200
100300
98000
97800
97500
& FREEWAY STATION
HARBOR
24N 13S
114200 88*400
115400 88700
115000 88100
111900 87200
1 12200 88000
24S
1 10500
109300
109500
105100
107200
4N
98100
99100
97500
98200
97600
SAN
27N
88300
84200
86700
86400
OVERALL
STANDARD
84100
DIEGO
4S
90600
90400
91200
89900
AVERAGE
DEVIATION
91400
275
97900
100000
100500
100800
99600
AVERAGE
ALL FWY'S
105100
105300
] 01*700
104100
104700
540
104400
3>
co
a. Figures for July 12 were adjusted to represent all lanes of fwy when available data contained traffic counts
for all but one lane of traffic.
Data for July 5 was not included due to its temporal proximity to a national holiday, which, it was felt, would
cause it to be unrepresentative of normal Thursday traffic.
Source: State of California, Department of Transportation, 500 South Vermont, Los Angeles, California.
-------
standard deviation for the average vehicle count in the loop is only
540 vehicles/day, or just .5% of all vehicles counted daily in the
loop. In comparing the vehicle count data for July 26th to the average
Thursday traffic count, it is seen that the July 26 count value is well
within the expected normal variation for a Thursday vehicle count.
Hence the transportation data indicate that a significant reduction
in vehicle count did not occur in the 42 mile loop on July 26, and that
any reductions in VMT due to the July 26 abatement actions would not
be discerned in the data. Actually, the fact that typical Thursday
vehicle counts fluctuate relatively little (as evidenced by a .5%
stand deviation), would suggest that measurements of the 42 mile loop
could serve as a sensitive indicator to traffic control measures to
reduce VMT. However, this sensitivity is not tuned fine enough to
discern the .12% VMT reduction estimated by the results of the agency
interview survey.
In another tabulation of transportation traffic counts (Table A-12)
on the freeway loop morning rush-hour vehicle counts were examined for
typical Thursday traffic preceding the July 26 air episode action.
The expected fluctuation in morning rush hour vehicle count is sub-
stantially greater than that observed for the daily variation (Table A-ll),
In comparing the vehicle count data for July 26 to the average Thursday
traffic count, it is seen that the July 26 count value is well within
the expected normal variation for a Thursday morning traffic count on
both the Harbor and San Diego Freeway portions of the loop. However,
it can be seen that morning traffic counts for July 26 on the Santa
Monica Freeway section were significantly less than usual. This decrease
A-35
-------
Table A-12.
MORNING RUSH HOUR (6-9 AM) VEHICLE
COUNT, SELECTED STATIONS
IN "A2 MILE FREEWAY LOOP"
DATE
June 28
July 12
July 19
Overal 1 Average
Standard Devia
July 26
HUNDREDS OF VEHICLES
HARBOR
(Northbound)
195
202
197
198
2.9
197
SAN DIEGO
(Northbound)
212
210
209
210
1.3
209
SANTA MONICA
(Eastboard)
213
212
213
213
.6
200
Values in table are average of 5 stations for each of freeways. The
apparent low value for traffic volume on July 26 for the Santa Monica
Freeway is due, at least mainly, to a traffic accident, which caused
appreciable conjestion.
Source: State of California
Department of Transportation
550 So. Vermont
Los Angeles, California
A-36
-------
was due in all likelihood to a traffic accident and the subsequent
traffic congestion.[A-3] Discounting the vehicle counts on the
Santa Monica Freeway, it is clear that any reductions in morning rush
hour VMT due to the July 26 abatement actions are not discernible in
the data.
The data from the freeway loop suggest there is little need to
examine further data or invest more time in quantifying the July 26
abatement actions in terms of its effect on overall vehicle usage in
the Basin. It is improbable that the effects of the action can be
measured since the resulting changes are within the usual daily vari-
ations. Suffice it to say that the impact of the actions were un-
doubtedly insignificant in the sense of air pollution abatement.
A.6 PUBLIC REACTION AND MEDIA INVOLVEMENT
The significance of the July 26th air episode action in terms of
public reaction and attention received from the media was appreciable.
The following sections provide a summary of this activity.
A.6.1 Agency Reaction
Table A-l includes a summary of the attitudes and recommendations
voiced by respondents of the agency survey interview. These reactions
may be broadly summarized as follows:
• Skepticism is prevalent regarding the effectiveness of
limited administrative leave as a pollution control
measure to decrease Basin VMT. Recommendations are that
employee leave be enforced throughout all agencies, along
with accompanying controls to ensure substitute motor
travel does not occur.
0 Most agencies appear to feel the overall emergency air
episode implementation is poorly administrated. Recom-
mendations for improvements include educating for
increased awareness, more definitive abatement alert
action announcements, better harmony between the air
pollution agencies, and stronger committment and
leadership by the EPA.
A-37
-------
In general it appears that much of the discontent over the current
emergency episode program is a derivative of its interim status. The
interim approach, calling for a voluntary submittal of abatement plans
from the federal agencies, is a temporary stopgap until a more complete
emergency air episode program is adopted later this fall. This interim
perspective is evidently absent as common public knowledge. Consequently,
it was found that many of the criticisms of the July 26 action were
directed at the failure of the, plan to be comprehensive, definitive,
all inclusive, and mainly, authoritative. During the interview survey,
several respondents (usually the agency air episode coordinator)
indicated that the July 26th action demonstrated the futility of de-
pending on voluntary individual agency committment in affecting
positive encompassing action. These respondents called on the EPA to
define and direct appropriate abatement control measures, and to enforce
these collectively among all agencies. In one case, an agency (the
FAA) had withheld its participation on July 26th and future abatement
actions pending a decision by the EPA to issue more definitive direc-
tives. It is evident, based on the nature of these complaints, that
the inherent weaknesses of an interim stopgap have been responsible
for many of the inadequacies so apparent in the program at this time.
The future adoption of the State's plan later this year should
alleviate some of the problems now being experienced. In the meantime
it would seem that greater effort towards shaping awareness of the
interim nature of the present plan could result in more positive public
opinion of the entire emergency air episode abatement program.
A-38
-------
A.6.2 Reaction from the Media
The implementation of the Emergency Episode Plan by the federal
agencies drew much attention in the local newspapers. Figures A-4 and
A-5 are representative articles demonstrating local newspaper reporting
on the action. In general the reporting was consistent with information
obtained in this study. The major contradiction of fact concerned the
number of federal employees absent on leave during the 26th. Based on
interviews with the Federal Executive Board during the action, most
reports carried information that an estimated 25000 federal employees
were-out of work due to the action. The survey of agencies, however,
in this study, indicated less than 4000 persons out of work.
In addition to the comprehensive reporting of the July 26th action,
a number of editorials appeared in the media. Figures A-6, A-7, A-8
demonstrate the tone conveyed by these editorials. As can be seen, the
emergency action generated substantial controversy, with both affirmative
and negative positions being expressed throughout the media.
The evening outlook (Figure A-6), in an editorial July 28, issued
the criticism that the EPA abatement action was irresponsible, and
accomplished little in the way of air pollution abatement while at the
same time costing taxpayers millions of dollars. (It was noted that
this cost occurred on a day in which the predicted conditions changed,
such that heavy smog failed to materialize.) The editorial referred
to "an estimated 100,000 federal employees out of work," and noted it
was unrealistic they would stay home according to the intent of the
abatement plan.
In a Los Angeles Times editorial (Figure A-7), the action was
said to have performed a valuable service by demonstrating what will
A-39
-------
V., v
Vv
K '** i *> 0 • ' |C\
m li i-vG
BY DICK MAIS'
__ THta Hid Writer
Federal arencies in five Southern California counties \Yedr.esday \vere
Ejked to c'.osc ih^r cfi'jces or curb activities today because of extremely
;>h daytime smog level* expected a', many in": and citiei.
I: \viilte ;he first time the recently
.f she K:-.\i
r.c.1" i.i S
T.-c p^
fc^cr:! Err.errcncy Air
n is 10 be pui into cffccL
;:-:'. Hi. :n--._ nf fhe
^t of ihr rrr:~.~-Tl rfiice
irr-.cr;al Pro'.cciion A;-
Frcr.tlico.
actually c;!l- only fnr
rjr'-.iij all xmncrc.-.'.'.r-- SLio^.obilc
ir.i\^J. u.-e cf »xc!jlnn o.'.':cc forcci,
pr-i ur^rcs c--cr.iiii ncr.v.r.-.c-I to MM
pc-V:c u-j-i-porutior; cr c^r pools (n-
x'.ccc r.f ihcir own vehicles to cora-
.r.i;;e Troir. home to work.
fr. .-:<:! C;:.L.-S will be clo/ca today.
r.".V,;i .'-.ii,i t!:ci~c arc mo:t thjn
K- '/ 3-J f^ric-rs! cr-.jTlr.yci ;;i t"ic
S«..'h Co;jt Air K-^:.i \\ hich in.-
rir ,c5 Lo.> An^cir5. \'i*rtura. Or-
rrpc. Tijvcriidc aua San Ecrnirdino
cojr.ifci
XumUcr Affected Unknown
]--;!:o:t i^:'! he could re: estimate
hf.iV jr.ir.y ..xcrai cmp:o*--cs \vouM
re.r.oln ai r.xr.e, cxi.^L-.ln^ that of-
/.cr. s'.a.'fir.^ requiremenis for to'lay
v/orc Jc.rl to the ciscreucn o;" ageaxry
hecc'.s.
Many ac^rxie* sub*er,uen'ly an-
Eo-inc^d oi":"iccs wilJ CJOSG toJay,
The Jrtprr.i.1 Rever.ue Service paid
*H ;:.> r.j!~. .*. ;r four ;c'jTj":^5 — Los
: '. , c!?s. £: n ?,irr.rrd:no. ^trcrs:dc
C1: :~^L — •••I.i tc c^o*c.i io-':iy.
• JiiS r..V,c-.s in Southern. CaU-
. . M .li rrrric.n oncn,
. - ..-o. K.r.r.cl], Social Secuntv
'. •*..•;!; be ci^-C'j.
."..ce t--oxc=r.;i.: in Lcs
.
7.-j .-,.:~c!ct city sr.d cojr.iy of-
,.c:~- v/::i ;-c,r.;.n cpcn, hov.-cver,
;^l:cjnie:i for tr.ofe entires fiiid.
?":s;e offices *I.so viii V-e open.
owever, Cov. Rta^an ordered »r.
Smog Emergency
to Close Fedora
Agsncies Today
Continued from Fint Pe;«
LT..t!ciflate hah to use of state vehi-
cles except for enerjcr.cies in ihe
sraos-plajjcd pans of Southern Cal-
ifornia,
The governor's order covers
dou-mou-n Los An^cics. eastern Lit*
An^c'.us Coun'.y and Rivcitice ino
Sen Bernardino Coar.uc5.
Herb Camribcll, circttnr nf the
zUtc Orfice of Ecu^cncy Son-ices.
aljsn vrgcd mo'.crUu in the Scuih-
!s.nd to cut back on nane^s-cr.uJi 1
drivL":^,
The federal air epLsxie order was
isr-ed on the second cay of or.c o'
the wui-st sno-2 sjejcs of the year.
Jn Lo5 Ar.gcle* Cour.'.y, the ozone
ctMST snared u> .49 pans per nuUion.
jurt short of the ^0 level for a first
tU^c alert,
The .40 rciriing was recorded at
the A r Po:!uiio3 Conirol D'.stnci'a
'Ez.'-l Son Gabriel Va'.lcy station.
It v.-ss the i^cccr.J highest oi;cne
reiriir^ fn Los .nJi^clc-s COT my fo
far this year. Tne piuk r.zone c^unt
50 far v/as .0? pprn recorded in Ccn-
iral Los Ange'.e» on June 21.
Fii»l-SU*e Alerts
First - !>ta;e f^r.c^ alerts were
issue:] in tc:h >±n E.'rnsrciino and
pjver>:.'> ccur.ues during tne day.
Top oxidant counts included:
UpL^d; .-VS pn.T.; Konuna. ..rj5; San
Bcrnjrcino, .."iC, snd Tdverside, .32.
At the San Bernardino County
riiic.- of Upland, Forruna, Ki^im
and SOT Bernardino, shcrifrj<
Per=or.s v/ho hao ^Jiherca esn
.-iricv, o!".:5 and in ph^ppm^ areas
\vcre ur^cd n s'.ay 5n.-;cc a buiidinj
"or ih.c-fr hor.ics and r.oL to use ihtir
autoranbi'.cs.
"I; v.-c.^ £ove:h:E5 like a \V~orIi
War II £ir raid \varr.ir.5," a startlei
resident o.r L'p^r.d E^id.
The ^r.io; c:.ur/.sjn San BornaitJf-
r.o County a!-o \vc-rc the second hi;h-
e.-t reiis'.cred ;his yen.-. Th* h:gh-
oil :o cjis \v5s .t6 p^m at Up!snd
on J'jr.e 6.
At Riverside, v/hc-re srr.oz, alerts
are ca'.lcd v/hcn the oxiJan: co-ni
reaches .27, thj C4:h elm of the >ter
v/£s i-"jcd. Tht prcv;n;i« day thre«
»ep4ra:c alms \.xrc c^'^ed there.
5-ciiofiI Warning
In Lns A^eJcs. the A:r Po!!-tt»o
Cor. 'ml Dl^ir.Cv i-;--Jcd the itird c®i-
•?cui:\'e school ind hcal'.h v.-arr.tB^
for ;!~e S.~r. >*crrirnn. S^n Gabriel
zr..1 Porr.oro-V.'alnui. valleys. •
Mrx:r.TJ-n r-iG^.e !e\v's io.'iav will
rarj.-? oci^ccp. ,-i ) ',o .i'i p;i^*. in ihfi
Sen GLLivid nr.t^ Pomona vaP.cys, the
APCD r :d. Oz. r.c Ic-.c:? of between
.10 to .'J> sri- cv>'-c.tc'd in '.he ian
>'crr.sr/J3 Vfll'.cy and a hi^h reading
nf ^!5 wis 'nrcr^rL for hem the otft-
Lr?,l ar.ri s',i:,h.-.~>.t rficnori^.
Roocrt i',. L-n-rie, ar'jng a:r po!-
lu.i^T t.ir.Tji o-fjccr, >ai^ lhal 4c^
s^.og- " i-vp'.s j'rrn V.*cyr.c>c:iy's r.f^h
iht APCD nifice *-LS urcin^ lik*l
aj.l lir.rcco.-saL-y moLor vehicle Lrav-
ti b« cjru:"cc today.
Figure A-4
Los Angeles Times Report on Abatement Action, Appearing
July 26, 1973
A-40
-------
-So Do 25,
Federal Workers Get Day Off in Move to Cut Traffic but
Freeways Are Still Clogged; Supervisors Protest Holiday
BY FICHARD WEST
Tltnei StaH Wnltr
An estimated ?\000 federal em-
ployes in five Southern California
counties were given Thursday off
because of an expeclPd sipgp of hea-
vy smog that never materialized.
Thp undprstanrtinp was that the
workprs \VPVP tr> stay home and kp*>p
their cars off the road in an effort to
rut down the amount of pollutant-
in the air.
Put police and the California
Highway Patrol said that despite the
fpdpral action, streets and freewa\3
were as crowded as ever. In fart,
they said, traffic was a little heavier
than usual in some areas.
The Los Angelea County Boaid of
Snpenisnrs protested to President
Nixon that the federal action was a
shocking example of bureaucratic
misuse of public powers.
And Los Angeles Mayor Tom
Bradley said the rity has no inten-
tion of automatically following the
lead of the federal government in or-
dering municipal workers to stay
home during smog crises.
First of Its Kind
The action, the first of ils kind
taken under the new federal Emer-
ppnrv Air Kpisode Plan, involved
HS.nOO federal workers in I he South
Coa=t Basin, which is made up of
Los Angcfps, Ventura. Orangp,
Riverside and San Bernardino conn-
tip.'.
It closed down all Inlprnal Rev-
enue Service offices in this area PX-
cept in Ventura County and all So-
| cial Security Administration offices
Jin the Los Angeles Basin.
In addition, it drastically curtailed
operations of the Department of
Hpslth. Education and Welfare, the
Department r-f LaTor. the Sm-ii
i
Ru^tnPss Administration, 'he Feder-
al Trade Commission and the Equal
Employment rommis=inn.
Thp:e agencies opetal»d will- «nl"
s'kflpfon suffs:
Goidnn Kllmlt, chaitrrun nf thr
Federal F.vpru'ivp Board here, an-
nounced late Thursday that im-
pro\ ing air pollution cnndiiion-"
will permil "all fedn-al agcnnF-; and
m-lallalions in the South Coa-i R.i
sin to rplurn to their normal \\ork
schedules" today.
It \\a- Klliotl \\hn announced
Wednesday afternoon lhai. ih« ppi-
sode plan would go into effect here
Thursday at the request of the re-
gional office of the federal Environ-
mental Protection Agency in San
Francisco.
This ujs after fir^t-stdgc tiling
alerts had been called in ltivei.-.iiie
rind San Bernardino counties and
the smog level had reached .-10 parts
of ozone per million pans of air in
the east San Gabriel Valley.
The Air Pollution Control District
lud forecu.it heavy smog ior >ome
areas of the l.os Angeles l-Ja^iii
Thursday.
During the night, however, hri.-k
ocean breezes swept in and did away
•,vith the meteorological conditions
conducive to heavy smog.-The on-
shore flow of marine air also held
down temperature?, resulting in
moderate, pleasant weather Thurs-
day.
Light Readings
Peak smog readings were light to
moderate in the ba^in Thursday.
They included .111 in central IMS An-
geles. .20 in east San Fernando Val-
ley, .17 in the Pomona-Walnut Val-
ley and .23 in the east and west sec-
tions of San Gabriel Valley.
1-evels forecast for today include
2.~p in the inland valleys and .15 in
.p'ilral l^is Angeles.
The pleasant weather lured
f-oivus totaling an estimated -12J.OOO
10 the beaches of Los Angeles and
Gr:ni-p counties.
Aim'.-P'nerit parks such as DI-UPV-
I.IMI:'. lion Country i-afari. Magic
^.•"i.nt.-iin aiul Knotl's Berrv I'otiii
;r!K"»ned no >igniiicant o>op in ^t-
-••:-.'j,-i e bee.iuie of ihc .-mug «:irn
men!-.
snd 1m-
putilic
Kenneth llahn. u ho wrote thf
protect mouon whu-h the board rii-
ivi-ted to Mr. NJMin and Russell K.
Train, ihjinnnn of the Council on
Knvironmental Quality, comment,-,!
"Probably i,me out of 10 of the-o
federal employes work m air-mnd,
tioned offices. l'Jvcrvbod\ in pri\;,ie
business has to work and pay taxes
to pay the salaries of the-e feileral
employes,"
Ilahn's motion said. ''A nim-h
greater contribution toward soli MI;
the problems of air pollution an Id
be made by the federal goiernmcr.t
by vigorouslv pursuing ef- • I
forts toivanl control of ]i",i|
»;tlo exhaust emissions."
Bradley said tha cily
"xvould have to confer with
the APOD first on the
health aspect before tak-
ing any action" similar to
tha federal government's
episode plan.
But, he added, "1 don't
know what the future will
hold. It may get so bad ve
will have to take drastic
action."
Elliott, ho\ve\er. defend-
ed the federal action, say-
ing the "federal family"
use of parking lots and
cars decreased considera-
bly Thursday as workers
took to car pools and pub-
lic transportation.
V spokesman for the Ra-
pid Transit. District said
Thursday afternoon It v.,is
too early to come up i\uh
;be number of persons rid-
ing buses during the da;-',
but that there was no Indi-
cation of any significant
increase.
At the downtown Los
Angeles Federal Office
Building, 330 N. IMS An-
geles St. about 2,800 of
the 5.000 persons who
work there look the dav
off. Almost all of the 2.300
employes at the U.S.
Courthonip. :'.12 N. Spring
bl, reported to woik.
Kmcrqcnry I'se
Ciiy. (uillllv and st,,!e
ofhces were all open, but
(Jov. fJeagau ordered a
halt to the u^e of slate \P-
hicles except in emergen-
cies.
Elliott said reaction to i
future smog alerts could j
be made more effective if
all levels of government |
developed mutual goals j
and r,kir,~
•e '-an pet all of our
in federal, S'^te,
and local gnvprn-
-s to strut u-in?
-Mutilation .;nd
,-'\ cry woi km1.; ,
day. ii"i. m-t riming MTIOC;
slens. v.e will have t.ikeii
a grot ftnda lowrud abat- j
tus; the Mini'* problem," he
5.ini ;
Klliotl pr.,i-cd a'l fcdor.il :
fluencies tor '* 'ving '-land- i
hy plans re.nly ami ljkin.2 !
'quick, posit u « action" io '
meet the smog alert. i
"Thou-ands of feileral i
f m p 1 o v e s u^ed ]niblic :
1 rail-port.1110:1 instead of j
their "wn automobiles and
lode in car pools," he said. .
In San Bernard inn, I
API. D meteorologist Koi>
Mankcr said tha use o( '
sneakcr-eqinpiied helicon- ]
tcrs to warn j>eople of the
smog danger had resulted
in "a lot of confusion and
panic "
''We are trying to get t^e
radio and newspapers to .
explain that the world is '
not coming to an end or t
that we are in danger of
annihilation," he said.
"It's just a warning to
the elderly people, the
children and those with
le-piratory and heart con-
ditions to take it easy and
fclay in the house."
The helicopter warnings
were broadcast Tuesdai-
and AVennesday but not
Thursday.
Inland smog readings
Thursday included .iO at
Kontana. .30 at Upland. .21
st San Bernardino, .2S at
Riverside and .30 at Per-
lis.
Comparatively moderate
temp eratures prevailed
Thuadav, with highs ol S!)
degrees at I^os Anircles (,'h -
i-: 'Center, 9:i at l;i\er~ide
and 08 at San I'ernavdm".
The cooling trend will
ointinue, the forecaster
ta'd, wiih high tempera-
tures at Los Angeles Civjo
Center today and Satur-
cav in the low SOa.
Figure A-5
Los Angeles Times Report on
Abatement Action, Appearing July 27,
1973
A-41
-------
0
o
r -J
It was both wasteful and ir-
responsible for the federal
government to order the closing
of most federal offices in
Southern California Thursday
because of predicted heavy smog"
that day.
It was a public relations stunt,
of course, to dramatize the
seriousness of the smog problem
— as though Southern Califor-
nians aren't aware of that alrea-
dy. But it cost the taxpayers a lot
of money needlessly, and was
violative of the obligation of
government agencies to serve the
people. . -•. t/,-
The bureaucrats in the San
Francisco office of the Environ-
mental Protection Agency, where
the idea was dreamed up, said
"closing the offices would mean
about ICO.CGO federal employes
wouldn't have to drive to and
from work,— and thus wouldn't
contribute to" the predicted high
smog levels.
. • But anyone with any
sense would kssw t&at
vs, ^ n
pie, given an unexpected day off
with pay on a hot, smoggy day,
wouldn't stay home'if they could
help it. They'd go to the beaches
or mountains. And JJ they
couldn't escape El Monte, or
West Los Angeles, or wherever
they might live, they would likely
make a lunch date with someone
in an air-conditioned restaurant,
or go to the movies, or run down
to the hardware store to get the
washer to fix the leaky faucet.
So it's highly unlikely there
was any substantial reduction in
federal" employe car use Thurs-
day.
>
But while the estimated 100,000
affected federal employes were
having their day off, they were
'still earning their $35 or $-10 a day.
So it probably cost the taxpayers
about $4 million in lost services of
the federal agencies involved.
The punchline to all this is that
the predicted heavy smog Thurs-
day didn't materialize. Weather
£&$$& changed 'sufficiently to
Angeles basin.
Figure A-6
Editorial from Evening Outlook,
Appearing Saturday, July 28, 1973
A-42
-------
Clear Warnings on Smog
Five Southern California, comities have now ex-
perienced their first Federal Emergency Air Epi- -
socle Plan. Because nearly one-fourth of the 100,-
000 federal employes in the five counties were not
required to report for work, there were several
1'nousund fewer autos on the highways. And there
'was less smog than the day before, whep first-
stage smog alerts were called in some areas.
Whether the Environmental Protection Agency's
plan to reduce smog by closing offices and curbing
activities was responsible for the drop in the ozone '
content is debatable. Robert G. Lur.che, Los An- _
geles County air pollution control officer, says the,
Air Pollution Control .District had informed EPA-
that there would be no emergency smog conditions
for two days in a row. But the drastic federal
action did perform a valuable service. It provided
a dramatic demonstration of what the future
holds if a continuing effort at upgrading our
air st-ancVdi'ds is not successful.
Tho. federal emergency plan was activated
.Thursday when the ozone count the day before
reached .49 pail per million in section-of Los
Angeles, just short of the .50 count required for
a first-stage alert. But first-stage alerts were is-
sued in Sa-n Bernardino, and Riverside counties,
where first-alert requirements arc lower. Even
Los Angeles County issued school and health
warnings for some areas. And Gov. Reagan or- •
dered a halt to the use of slate vehicles in" the
South Coast Air Basin except for emergencies.
Although Los Angeles city and county govern-
ment offices remained open and private industry
conducted business as usual, the partial federal
shutdown should not be taken as a stunt. Eventual-..
ly, unless the dangerous air pollution is 'conquered,.>
all government agencies and private industry may.,
be forced to shut when the ozone count hits un-.
healthy heights.
The federal response to our polluted air should
spell out yet another warning. With motor vehicles
responsible for 909o of contaminants in the air, we
must place harsh controls on the private auto and
develop alternative modes of transportation. Right
now, the only possible alternative lies in the-devel-
opment of an. adequate mass transportation sys-
tem. '.•'•-'
Figure A-7
Editorial from Los Angeles Times,
Appearing Friday, July 27, 1973
A-43
-------
be required as future abatement actions if air quality cannot be im-
proved sufficiently. The editorial explained that the action of the
24th represented a necessary and rational response to the degradation
of air quality, and it pointed out the need to place more stringent
pollution controls on the private auto, and to develop alternative
menas of transportation. The only possible alternative, the editorial
concludes, lies in the development of an adequate mass transportation
system.
Based on contacts with the major television networks, it was
determined only KNXT issued an editorial in response to the action of
the 26th. The KNXT statement (Figure A-8) was sharply critical of the
EPA emergency air episode plan, and also warned that it is only a pre-
view of the ultimate smog plan of the EPA which calls for a shutdown
of the Basin by 1977. The editorial added further caution that the
EPA has the power to enforce their plans, and that this agency cannot
be trusted with this authority. It was suggested that decisions for
shut down action during emergency air pollution episodes should be made
by local and state authorities.
The critical tone voiced by the media and the federal agencies was
shared by the Los Angeles County Board of Supervisors (See Figure A-9).
Supervisor Hahn objected to the "holiday" given to a select number of
employees in the federal government, while the taxpayers were required
to work. Mayor Bradley voiced doubts of the plan, saying the City
would not arbitrarily follow the action of the federal government, and
that the decision to shut down city offices would depend on consultations
with the County Air Pollution Control District regarding health hazards.
A-44
-------
Subject: The EPA Smog Holiday
Broadcast: August 1 and 2, 1973
The free holiday for Fedora! employees last week was not just a one-time publicity stunt
for the Environmental Protection Agency. It was just the beginning of a plan by EPA to
cail a holiday every time they decide smog is bad.
As you know, smog was heavy in a few areas of the basin last Wednesday. For a while,
weather men said it would be worse on Thursday, so the EPA requested that Federal
agencies close.
The fact that the anticipated first-stage alert failed to occur on Thursday is unimportant.
The really critical thing is that under the Clean Air Act of 1970, known as the Muskie
Bill, the EPA aces have authority to c~ii for a shutdown of Federal agencies. They can
do so whenever ozone levels reach that arbitrary IcveJ set by the EPA, which happens to
be 20% below the first alert stagejn Los Angeles County.
What happened Thursday v/as nothing compared to the ultimate plan of EPA for the basin.
You tl.ir.k you're having trouble finding gasoline? Just wait until the EPA tries to clo.se all
gasoline stations, and block freeways, and perhaps even to close some industry.
It can come to that because bureaucrats of the EPA have decided on a smog plan which we
• tr.ink couid shut down the LOJ Angeles basin by 1977. Their own director, the head of
EI'A, said the plan could ban all cars from the streets in Los Angeles by 1977.
Apparently a lot of people think the plan is just talk, but it's not. The EPA has the power
anclit is tneir pian. V.'hat happened Thursday was just an example of their power, and it
should be a clear signal to Congress - and to Senator Muskie - that the EPA can't be trusted
WJth •nuijonry. Y/iien ti^ci-JOi"5: !:f? n'.-jiK' 19 ^ill:P CiO^T: fQf vIYiCi'tiTick^ iH^e decision^
shouia be maue oy local uad ataio autnorities.
Figure A-8
KNXT Editorial
Broadcast August 1 and 2, 1973
A-45
-------
Los Angeles County
Board of Supervisors yes-
terday objected to the day
off given to most local fed-
eral government employes
because of high smog lev-
els.
One supervisor called
the day off shocking and
said p u blic employes
should not have a "Roman
holiday" v/hen the tax-
payers have to work.
On a motion by Super-
visor Kenneth Hahn (Sec-
ond district), the Board
expressed its disapproval
of the s hutdown and
urged a day off to solve
the smog problem.
Requested by EPA
Hahn was the nx>st vo-
cal critic of the shutdown
and held a news confer-
ence after the Board meet-
ing to further expouse his
objectiqns.
The shutdown was tak-
en at the request of the
regional office of the Envi-
r o n m e n tal Protection
Agency in San Francisco
to help alleviate the high
smog lefels expected yes-
terday.
Included in the shut-
down area were Los Ange-'.
les, Orange, Riverside and
San Bernardino Counties. :
Hahn said that federal
employes with the day off
probably went to the i
beach and used their cars'
more than if they had'
gone to work.
Asked if he would favor'
such a shutdown if the-'
smog situation got worse'
Hahn replied, "Let them
suffer with the rest of us.'1
Bradley Comments ;
Later, Mayor Torn Brad--
ley was asked at an infor-
mal news conference if he-
thought city offices would'
ever be shut down be-
cause of smog.
"We don't know what
the future will hold," said
Bradley, adding that pol-
lution might "get so bad"
that this could become
necessary..
"But we-would not arbi-:'
trarily follow the action of/
the federal government,"
the Mayor said.
Bradley said he woul..
not close city offices will;
out consulting with th.
County Air Pollution Cor!
abcut healti'
Figure A-9
Report, on City Officials' Reaction,
Valley News and Green Sheet,
Appearing Friday, July 27, 1973
A-46
-------
The tone of reaction demonstrated in national publications was
markedly different than that exemplified in the local press. During
a communication with the Washington Post [A-4], it was conveyed that
national publications are somewhat removed from the local problems of
the Los Angeles Basin, and consequently do not reflect an evaluative
tone. The column in the Washington Post, shown as Figure A-10,
reflects this minimal degree of attitude presumption. Several of the
national publications (such as the New York Times)were even less
committal by omitting coverage entirely.
A-47
-------
THE WASHINGTON POST
The Federal Diary
While Washington's most
powerful unregistered lobby
^ ^ ling mixed results in a five-
' 'CT/d county area around Los Ange-
g les. which has nearly 97.000
federal employees. There are
3-50,000 civil servants in the
D.C. area.
Since Wednesday when L.A.
air pollution hit danger levels.
federal agencies have been
trying to coordinate an EPA
I If air pollution problenisj.tJiat1e:de^aT.^opet^tions
I continue, as seems likely, the | hampered By-reduced mongc,
1 EPA will attempt to make; and problems of coordination
Washington a model compli-: between inter-dependent agjn-
' ance area, since government is! ties working different hours
; the major industry here and a I The Los Angeles pollution
! federal no-driving edict would ; alert plan, which may be tie
of
have more clout, and effect, in forerunner
area
inspired plan of last May. It
calls for voluntarv curtailment
- the federal carpool commu- .5rgovernment .induced venicle
nity — struggles for Parklng.^raffic
spaces with the Environmen-, ' As of late yesterday on]y
tal Proleclion Agency, Uncle . ,wo California agencies. Social
Sam already has been forced ! Security Administration and
by smog to shut down most ' ttle Internal Revenue Service,
operations in southern Califor-;had completely shut down.
nja I Post offices, federal courts,
_„. ... the U.S. marshal's office and
EPA wants to eliminate or Los Ans,eies citv and
reduce cut-rate parking— 57.50 . offjces \vere
to S15 a monlii-in or near • ske)elon crews working. ..]t is
tederal agencies here. Idea is bcin£; run something like a
lo force more one-passenger snow7 emergency here - one
drivers inlo c.rpools or buses. \Vashington-based official
Rep. Joel T. Broyhill (R-\a). plained.
who represents a major bed
county
open, but had
a similar pfo-
jthe metropolitan area than | gram for Washington, v&s
i anywhere else. • presented to the Federal Exec-
! In trying to tackle federal' utive Board there on May" 22.
commuters, EPA will have Hs'FEBs include top officials
work cut out here. ' from all federal offices within
Despite attempts by* Presi- given geographic areas. <|
dents and the Budget Bureau Working on a crash ba|s,
'to stagger working hours initheFEBgot agencies to adcjpt
!Washington, this city, morel air-pollution closing plans. «y
1 than most, retains its 9 a.m. to-June 25, less than a month §e-
j5 p.m. patterns. Dependence!fore they were actually calted
, on the automobile has been'into play. The plan also calls
fostered by suburban living for the shutdown of fedejal
patterns and inadequacy 01 parks and beaches, and elimi-
mass transportation. nation of all but essentjal
In private-industry domi- travel in government-owned
' nated towns, staggered hours: cars. Such action in the Wain.
are standard. If a factory ington area could damage
owner says everyone will be in,tourist-generated businesses?
ex-
Employees who don't at 7 a m. then that is the start- Jobs: Commerce needs«i a
have to come in, or those with :ing time.
room commuter community, is heallh problems are urged lo |
fighting the plan on behalf of :stay home» He said a ]iberjd,
is constituents. 'annual leave policy, meaning ! with sizable protests from fed-! or 9 registered nurses, GS? 9
In what could be a hand-:it could be granted on-the-spot1
wriiing-on-the-wall exercise,'rather than in advance, is in
the federal government is hav-! effect there.
Grade 8 secretary and GSJ 5
Attempts to stagger working: clerk-typist. Call 967-3615. ^
'hours here always are met I D.C. Village wants GS 5« 7
eral workers who, as citizen-!physical-occupational thcfa-
voters, call their congressmen. I pists a,nd GS 12-14 medical #>£-
The congressmen in turn warnlficers. Call 629-8466. j
Figure A-10
Column from Washington
Post, July 1973
A-48
-------
REFERENCES - APPENDIX A
A-l Federal employment total (118,000) from official statements of
Gordon Elliot, Federal Executive Board, quoted in numerous local
newspapers July 26, 1973.
A-2 Private communication with Rapid Transit District, September 1973.
A-3 Private communication with Los Angeles Transportation Department,
August 1973.
A-4 Private communication with Washington Post staff, August 12, 1973.
A-49
-------
APPENDIX B
THE PRELIMINARY EPA EPISODE CONTINGENCY PLAN FOR
THE METROPOLITAN LOS ANGELES AQCR
EPA Region IX is presently in the process of constructing an episode con-
tingency plan for the Metropolitan Los Angeles AQCR. Preliminary versions of
episode criteria and control strategies have been formulated; these are
summarized in Tables B-l and B-2, respectively.
This appendix performs two separate analyses of the preliminary EPA plan.
First, in section B.I, the effectiveness of the proposed EPA control strategies
is computed. VMT reductions are determined for the traffic abatement measures,
both without considering substitute driving and with accounting for substitute
driving and overlapping reductions from the various measures. Using the
results of section 2.2.4, the VMT reductions are translated into percentage
emission reductions. Expected emission reductions are also estimated for
stationary source controls.
Second, in section B.2, the EPA plan is evaluated in comparison to the
contingency plan proposed in this study, (Chapter 6). It is noted that the
two plans are very similar overall. The only major differences are that
the EPA plan contains three episode stages (as opposed to four in the plan
proposed here) and that two control measures in the intermediate control
stage do not coincide. The relative advantages and disadvantages of each
plan are discussed, leading to the conclusion that neither plan can be
unequivocably recommended over the other. The choice of which plan is
preferable depends on how the relative advantages of each are weighted.
B-l
-------
Table B-l PRELIMINARY EPA CONTINGENCY PLAN FOR
LOS ANGELES - EPISODE CRITERIA
a For Present Significant Harm Lev^
Recorded Oxidant Level
.30 PPM-1 hour Avg.
or
.35 PPM-instantaneous
.35 PPM-1 hour Avg.
.40 PPM-1 hour Avg.
or
.50 PPM-instantaneous
.40 PPM-1 hour Avg.
.43 PPM-1 hour Avg.
or
1.00 PPM-instantaneous
Meteorological
Forecast for Next Day
Worsening
Worsening
Same
Worsening
Same
Is
Control Stage to be
Called on Next Day
I
II
III
b. For Significant Harm Level of .60 PPM-1 Hour Average
Recorded Oxidant
Level (1 Hour Average)
.45 PPM
.50 PPM
.55 PPM
.55 PPM
.60 PPM
Meteorological
Forecast for Next Day
Worsening
Worsening
Same
Worsening
Same
Control Stage to be
Called on Next Day
I
II
III
B-2
-------
TABLE B-2 PRELIMINARY EPA CONTINGENCY PLAN FOR LOS ANGELES-CONTROL STRATEGIES
1) Press release is issued by EPA, Region IX, containing:
a) Description of the air quality situation
b) Health warning
c) Request for car-pooling
d) Request for the elimination of all unnecessary use of gasoline powered devices
(e.g. lawnmowers)
e) Request for the elimination of all unnecessary use of motor vehicles by businesses and
by the general public
f) Request for the use of public transportation wherever possible
g) Request for elimination of open burning
h) Statement that cooperation will help prevent the necessity of EPA taking more stringent
control measures to abate the episode
2) Voluntary Co-operative elimination of non-critical business travel of Federal, State and Local
government operations and commercial businesses.
Stage II
1) All Stage I actions
2)* Mandatory closing of admission to all public and private recreational areas (e.g. beaches,
parks, amusement parks, theaters, clubs, and bowling alleys).
Those parks which allow camping will not admit additional campers, although those which
were previously established at camping sites will be allowed free access.
3)* Mandatory cancellation of all recreational events (e.g. ball games, boxing and wrestling matches,
track meets, automobile and boat races, other spectator sports, concerts and plays.)
4)* Mandatory termination of use of non-critical fleet vehicles. A "fleet" is ten or more vehicles
with commercial plates and under common ownership. Ban on the renting of cars and trucks.
Certain critical activities (and one innocuous activity) will be exempted. They will include
those listed below among others:
a) Use of emergency vehicles (e.g. ambulances, fire and police vehicles, and any vehicle
used in a medical, fire or police emergency)
b) Normal operation of limousines and mass transit vehicles (except when used for sightseeing
purposes, which use is prohibited)
c) Deliveries of gasoline to maintain essential services (e.g. police stations, fire stations
and ambulance services)
d) Deliveries of perishable goods and foodstuffs and essential drugs and medical supplies
e) Use of vehicles by public utilities for emergency repairs and services (e.g. gas leaks
and power failures)
f) Use of vehicles for purposes involving the national security, where such use is necessary
and cannot in good prudence be delayed
g) Operation of vehicles powered by gaseous fuels (e.g. liquified petroleum gas)
5)* Mandatory closure of all non-critical activities of Federal, State, and local government
operation, including administrative leave for non-essential personnel.
6)* AIT businesses with more than 100 employees are to reduce their operations drastically so as to
reduce substantially the emissions of air pollutants which they generate (directly and indirectly).
a) Examples of drastic reductions in operations include:
1) elimination of all production activities (whether of a manufacturing or of a service
nature) that result directly in emissions of "reactive hydrocarbons" (as defined by
EPA). Examples: petroleum, gasoline refining and transfer (except by retailer to
customer), dry cleaning, painting,
11) other actual production activities may continue but all peripheral activities should
cease: such "peripheral activities" would include:
(1) routine clerical activities
(ii) marketing activities
(1ii) loading, transfer and transport except of "critical" or highly perishable commodities
such as: foodstuffs, medicine, fuels for domestic consumption or for power generation,
etc.
b) Exemptions from the above requirements will be granted to certain businesses and agencies
whose activities are of "critical" nature such as:
1) normal police and fire services
ii) normal operation of ambulance services
ill) normal sales of drugs and medical aids by pharmacies
iv) normal operations of medical aid facilties (hospitals, clinics, etc., including such
facilities for animals)
v) normal sales of foodstuffs by foodstores
vi) minimal necessary operating, maintenance and repair activities of public utilities (power,
water, communications)
vii) normal operations of mass media (newspapers, television, radio, magazine)
viii) critical operations of those businesses or portions thereof directly involved in vehicle
use exempted under item 4 and/or with responsibility for deliveries necessary for such use.
Stage III.
1) All Stage I actions
2)* All Stage II actions
3)* Cjose all non-critical businesses.
* Mandatory action
B-3
-------
B.I. EFFECTIVENESS EVALUATION OF THE PRELIMINARY EPA CONTINGENCY PLAN
This section determines the effectiveness of the contingency plan con-
trol strategies proposed by EPA Region IX. The analysis draws heavily on
basic data presented in the main text of this report. Sections 2.2.4 and
2.2.5 provide the emission inventory and transportation data base used in
the effectiveness calculations. Section 2.2.1 gives some of the basic
employment information. Tables and results from these sections will be
referred to throughout the following analysis.
The effectiveness of some traffic control measures in the EPA plan
has been determined elsewhere in this report (Chapter 5 and Appendix).
At the risk of repetition, these calculations are repeated here to keep
the discussion of the EPA plan intact.
Table B-3 presents the results of the effectiveness evaluation for
the EPA plan. Table B-3a is for RHC control; Table B-3b applies to CO and
NO^. The first column lists the control measures, organized into the
appropriate episode stages. More comprehensive descriptions of the control
measures are given in Table B-2. The second column of Table B-3 gives
incremental VMT reduction including the effect of substitute driving and
overlapping reductions from other control measures. The number in paren-
theses does not include the substitute driving and overlap effects. The
third column gives the incremental emission reduction for each control
measure, broken down according to stationary and vehicular sources. Emission
reductions from auto tank filling at service stations are included in the
vehicular category. Finally, the last two columns give cumulative VMT
and emission reductions for each stage of the control plan.
B-4
-------
Table B-3a
EFFECTIVENESS OF THE PROPOSED EPA PLAN:
VMT REDUCTIONS AND RHC EMISSION REDUCTIONS
KHWUfCmOH
Stage
I
BB^BIGE^^BES
II
III
Control Strategy
1. Press Release
2. Voluntary Reduction of
Vehicle Use & Emissions
1 . Stage I Actions
2. Close Recreational Areas
3. Close Recreational Events
4. Ban (Private) Non-Critical
Fleet Vehicles
5. Close Non-Critical
Government Agencies
6. Reduce Direct & Indirect
Emissions from Private
Businesses with more than
100 Employees
1 . Stage I Actions
2. Stage II Actions
3. Close All Non-Crittcal
Businesses
Incremental VMT
Reduction
negl .
negl .
7%%-LDMV
5%-LDMV
30%-HDMV
5%-LDMV***
(6%*)
3%-LDMV
(4%%-LDMV*)
(9%-HDMV*)
negl .
34%%- HDMV
54^%-LDMV**
40%%-HDMV**
Incremental RHC i Cumulative
Emission Reduction 1 VMT
Veh. I Stat.i Total i
negl .
negl .
4%%
6%
3%
2%%
negl .
16%
38%**
1
1
negl . negl .
negl . negl .
i
r • —
-- ' 4%%
1
4% ' 10%
I
-- | 3%
1
2% ' 4%%
1
1
I
1 £
negl . negl .
i P
i |
6% 1 22%
i
negl .
20^-LDMV
34%%-HDMV
i
1 I 75%-LDMV
4%** 1 42%** i &
i 1 HDMV
aaiaga'BcssasBaEaiBiaa
Reductions
RHC
Emissions
negl .
22%
64%
^?!^^^S3^a^^3L^^S^ill
* Not including substitute driving and overlap with other control measures.
** In this case, cumulative effect was calculated and then incremental effect
was determined by subtracting Stage II results.
*** Add 1% if public school closure is'to'be included.
-------
Table B-3b
EFFECTIVENESS OF THE PROPOSED EPA PLAN:
VMT REDUCTIONS AND CO AND NO EMISSION REDUCTIONS
X
r»~i rffl <'M- fla«h»ji.
Stage
I
II
^BiBJBHEi^S^
Ill
Control Strategy
1. Press Release
2. Voluntary Reduction of
Vehicle Use & Emissions
1. Stage I Actions
2. Close Recreational Areas
3. Close Recreational Events
4. Ban (Private) Non-Critical
Fleet Vehicles
5. Close Non-Critical
Government Agencies
6. Reduce Direct &
Indirect Emissions from Priva
Businesses w/more than 100
Employees
1. Stage I Actions
2. Stage II Actions
3. Close All Non-Critical
Businesses
^^a.,Wl^; LXJt.M J s .it.^ dkmLaiJaU'AflA.g
Incremental VMT
Reduction
negl .
negl .
negl .
7%-LDMV
5%-LDMV
30%-HDMV
5%-LDMV***
(7%%*)
3%-LDMV
te 4%%-HDMV
(4%°/-LDMV*)
(9%-HDMV*)
negl .
20%%-LDHV
34%%-HDMV
54ia%-LDMV**
40%%-HDMV**
li5S,&ma£Eakis&Z}iC
Increment
Redu
CO
negl .
negl .
negl.
6%%
7%
4%
3%
negl .
2Qh%
49^%**
'ife JYl^ftSSfe-', ;*;?tej«3SiaaaB£
al Emission
:tion 1
NO
E
negl.
negl.
\
negl .
4%%
6%
3%
2%%
negl .
16%
36*2% **
Cum
VMT
negl.
negl.
20%%- L
34%% H
75% LD
&
HD
^52£^£2S
jlative Redi
CO
Emissions
negl .
negl .
DMV
20^%
DMV
MV 70%
MV
s-ssssEisssRSsssarasra
^y^"l?."^^Ta.- TF^^h^SlJl
ctions
NOX
Emissions
negl .
negl .
m at!Aia.iai^!*aaii«n!j«.
16%
52%
^uaaisagm^ffjunf
**
***
Not including substitute driving and overlap with other control measures.
In this case, cumulative effect was calculated and then incremental effect
was determined by subtracting Stage II results.
Add 1% if public school closure is to HP -in^i.iri^
-------
Table B-4 indicates the severity of the episodes that can be handled
by the various stages of the EPA plan. For oxidant, the pollutant of most
interest, it is seen that a .45 PPM (4 hr. avg.) oxidant episode can be
reduced to below the significant harm level by Stage II. Stage III can handle
episodes which would produce oxidant as high as .59 PPM (4 hr. avg.) with
no control. If the oxidant harm level is changed to .60 PPM (1 hr. avg.),
Stage II can control episodes up to .68 PPM (1 hr.), while Stage III can
abate episodes up to .88 PPM (1 hr.). Rather severe potential excesses of the CO and
N02 harm levels can also be prevented from reaching harm levels. Of course,
as noted in Section 2.2.5, CO and N0? episodes are extremely unlikely to occur
ever in this decade.
The effectiveness analysis for each of the proposed EPA control measures
follows:
STAGE I
1. Press Release
2. Voluntary Reduction of Vehicle Use and Emissions
Controls based solely on voluntary cooperation are likely to have
negligible effect on VMT and on stationary source emissions. The
purpose of Stage I is basically to provide certain prerequisites for
the later control stages, (health warnings, media announcements, pub-
lic relations, etc.)
Past experience in Los Angeles and San Francisco indicates that
essentially no discernable VMT reductions results from request for
voluntary traffic abatement, [B-3], [B-5]. However, in the future,
with a more extensive and better organized media campaign, some VMT
changes might be possible. It is difficult to estimate just how much
B-7
-------
Table B-4
EPISODE LEVELS WHICH CAN BE REDUCED TO OR BELOW
SIGNIFICANT HARM LEVELS BY THE EPA CONTROL STRATEGIES
Stage
I
II
III
eaaoKnaatuL aai
1
EMISSION REDUCTION 1
E
RHC
negl .
22%%
64%
CO
negl .
21%%
70%
NO
x I
1
negl . I
1
15%% 1
i
52% 1
EPISODE LEVELS WHICH CAN BE ABATED* (PPM)
Ox id
.40-4 hr.
.40
.45
.59
tevatssia&u&imWiSigaiffw*
ant**
.60-1 hr.
.60
.68
.88
auaagiMfcaiiiB^ toUsfeaxsKSBSiisats
CO**
.50-8 hrs.
50
58
94
:«^:!TO!K5*^liV,.;%!t'At«iS*Jui;.'-J!k>ia!i,
NO?.**
.50-24 hrs.
.50
.56
.77
;jA'J»!s»s,«MS*.i*fe«'«S!iiWSESSJra!
CO
I
03
**
These results are based on the approximate air quality-emission level relationship developed in
Section 2.2.7. Oxidant concentrations are assumed to be reduced by 1/2 of the amount of RHC
emission reduction on the day of the episode. CO and N0? concentrations are assumed to be
reduced by 2/3 of the amount of CO and NO emission reductions on the day of the episode.
y\
As noted in Section 2.2.5, the .40 PPM - 4 hr. oxidant level, the 50 PPM - 8 hr. CO level, and
the.50 PPM - 24 hr. .NO^ level appear to be the "binding constraint" significant harm levels
for each of the three pollutants. (There are three oxidant and CO harm levels and two NO-
harm levels.) The .60 PPM - 1 hr. oxidant level has been proposed as an alternative to tne
.40 PPM - 4 hr. harm level.
-------
traffic reduction might be attained. It is conjectured here that the
maximum possible effectiveness of voluntary control would be 5%.
Since VMT reductions from voluntary cooperation and very doubtful,
no actual reductions will be claimed for Stage I in the effectiveness
evaluation for the whole plan.
STAGE I:
Total VMT Reduction: Negligible to 5%.
Most likely negligible.
Applicable to LDMV's.
Emission Reduction: RHC CO NO
/^
Vehicular Sources negl. negl. negl.
Stationary Sources negl. negl. negl.
STAGE II
1. Stage I Actions
2. Close Public and Private Recreation Areas
3. Cancel All Recreational Events
Control measures 2. and 3. of Stage II will be combined in the effective-
ness evaluation; total VMT reduction will be estimated for closing all
recreational facilities. It is much more difficult Jto estimate the
effectiveness of closing "recreational areas" and "recreational events"
separately.
According to the LARTS survey data described in Section 2.2.6, (modified
according to recent corrections), [B-7], recreation accounts for 7.2% of
total weekday vehicle trips in the Los Angeles Basin, [B-3]. The indepen-
dent results of an SDC survey, [B-9], indicate that around 11% of total
weekday trips are for recreational purposes. The basic reason for this
B-9
-------
discrepancy between the two surveys involves the definition of "recreation".
LARTS data distinguished between "recreation" and "social-entertainment"
trips, while the SDC study includes both under "recreation". Thus,
the difference between SDC and LARTS estimates reflects "social-entertain-
ment" trips.
For the purpose of evaluating measures 2. and 3. of Stage II, "recreation"
should include "entertainment" since theaters, playhouses, clubs, etc.
are to be closed. However, most "social" trips should not be included.
Assuming around one-half of "social-entertainment" trips are for enter-
tainment," 9% of total weekday trips are accounted for by the appropriate
definition of "recreation".
Recreational trips basically occur in the "Home-Other" and "Other-Other"
LARTS categories, [B-3]. The average trip length in these categories is
about 6-6% miles, (See Table 2.13). However, it is expected that re-
creational trips would be longer than average trips in the "Home-Other"
and "Other-Other" categories. Recreational trips to the beach, sporting
events, amusement parks, fairs, etc. would probably average at least as
long as "Home-Work" type trips, (10 miles). This effect would only be
partially cancelled by recreational trips to clubs, bowling alleys,
theaters, etc., which would probably average about the same as "Home-Shop"
type trips, (3 miles). It is arbitrarily assumed here that the average
length of a recreational trip is 7 miles.
With total recreational trips representing 9% of average weekday trips
and having an average length of 7 miles, the maximum possible effect of
control measures 2. and 3. would be
B-10
-------
100% X 100% x 6.71miles (average length of all trips = ™ of weekday VMT
in basin)
However, it is extremely unlikely that all recreational trips will be
cancelled by the regulations. Certain facilities may not be covered,
and "pleasure driving" may still lead to some recreational traffic.
It is assumed here that adequate implementation and enforcement will
eliminate 80% of total recreational VMT. This means that
.80 x 9%% - 7%% of total weekday VMT will be affected.
Total VMT Reduction: 7%%
Applicable to LDMV's.
Emission Reduction: RHC CO NO
/\
Vehicular Sources 4% 6%% 4%%
Stationary Sources — — —
4. Ban (Private) Non-Critical Fleet Vehicles
For the purpose of making effectiveness calculations, the fleet vehicle
ban is assumed to apply to private (as opposed to governmental) fleets
only. Elimination of non-essential public fleet traffic occurs as part
of control measure 5., closure of non-critical governmental agencies.
Presently, 430,000 vehicles are contained in private fleets of ten or
more operating in the Metropolitan Los Angeles AQCR, [B-l], [B-ll]. It is
not known how many of these are in categories listed as exempt by the EPA,
(emergency vehicles, mass transit vehicles, essential and emergency
services, perishable deliveries, and gaseous fueled vehicles). Here,
B-ll
-------
it is arbitrarily assumed that 1/3 of the vehicles are exempt. Thus,
290,000 vehicles are affected by control measure 4.
Assuming that the HDMV-LDMV ratio is 20%-80% in these fleets, [B-10], then 58,000
HDMV's and 232,000 LDMV's are contained in non-exempt fleets. These
represent 25% and 4% of total basinwide HDMV's and LDMV's, respectively.
Since fleet vehicles tend to be used more intensively than non-fleet
vehicles, (about 25% more, [B-2], [B-10]), the affected vehicles will account
for around 30% of HDMV VMT and around 5% of LDMV VMT.
It is assumed that the fleet vehicle ban will also eliminate the
stationary source RHC emissions resulting from the filling of
underground service station tanks. This service presently accounts for
4% of total RHC emissions in the Los Angeles Basin, (see Table 2.5).
It should be noted that over the next few years, vapor recycle systems
will be installed to control emissions from underground tanks. These
systems will eliminate most emissions from this source. Shut-down
during episode will then produce practically no further effect.
Total VMT
Emission
Reduction:
Reduction:
Vehicular Sources
Stationary Sources
RHC
6%
4%
5% of
30% of
CO
7%
LDMV
HDMV
VMT
VMT
NO
6%
X
5. Closure of Non-Critical Government Agencies
Government agencies account for 13% of total employment in the Los
Angeles Basin, (see Table 2.3). Assuming that 90% of these employees
will be classified as non-essential and noting that work related VMT
B-12
-------
accounts for 50% of total weekday VMT, (Section 2.2.6), around
.13 x .9 x 50% = 6% of total VMT will be eliminated by government
agency shutdown.
As noted in Section 2.6, a decrease in total VMT by "X" (by less
work related driving) normally brings about a "1/5X" increase in other
types of driving so that the total VMT reduction is only "4/5X". Thus,
allowing for substitute driving, the total VMT reduction from closing
government agencies would be 4/5 x 6 = 5_% of total VMT.
It may be that public schools would also be closed as a result of
control measure 5. Estimates of trips related to all schools vary from
around 1% to as high as 3% of total, basinwide trips. The 1% figure
results from an SDC survey, [B-9], but it may be low since the SDC
survey is biased toward working members of the population. The 3%
result comes from a LARTS report, [B-3]. Here it is assumed that 2%
of total trips are related to attendance at public schools. Since
many school related trips may be very short, (e.g. trips to local
elementary and secondary schools), school type trips will probably
average less in length than total basinwide trips. Thus, it is
assumed that only ~\%% of total basinwide VMT results from travel
to public schools.
Adding the VMT reductions from the closure of government agencies
and schools, the total VMT reduction from control measure 5. is 7h%_
without considering substitute driving. Using the 4/5 factor to
account for substitute driving would reduce this to 6%. It is
interesting to note that this estimate agrees almost exactly with
traffic reductions detected by the Los Angeles Freeway Surveillance
and Control Project during the Truman and Johnson Memorials, [B-5].
B-13
-------
Total VMT Reduction: 5%*
Applicable to LDMV s
(6%, not considering
substitute driving)
Emission Reduction: RHC CO NOX
Vehicular Sources 3% 4% 3%
Stationary Sources --- -- -"
* Add 1% if public school closure is to be included
6. Reduce Direct and Indirect Emissions from Private Businesses with More
Than 100 Employees
It is very difficult to perform a definitive quantification of the
effectiveness of control measure 6. Certain phrases in the regulation,
such as "reduce substantially" and "peripheral activities", may be
subject to somewhat wide interpretation. No detailed information is
available on which specific employees and which specific operations
of the firms will be affected. Below, estimates of vehicular and
stationary source emission reductions will be derived by using certain
simplifying assumptions.
Vehicular Sources:
Private firms with more than 100 employees account for around 2B%
of total employment in the Los Angeles Basin, [B-5]. As noted in
Section 2.6, around 50% of average weekday VMT is work related.
Based on an examination of LARTS and SDC data, it appears that
around 38% is "commuter" type travel (home-work, work-home, work-shop,
etc.) while about 12% is "on the job" or "business" travel, [B-3], [B-9]
Thus, commuter type travel to firms of more than 100 employees should
account for around .29 x 38% = 11% of total VMT, while business related
B-14
-------
travel in these firms should be around .29 x 12% = 3%% of total VMT.
The amount of commuter travel eliminated by control measure 6.
will depend basically on the number of employees who stay home due to the
measure. Carpooling would also decrease commuter travel, but mandatory
carpooling is difficult to implement and voluntary carpooling is not reliable
The number of employees who will not report to work as a result of
the control measure is not known; it will depend on the working definitions
of "production" and "peripheral activities". It is expected that most
firms would attempt to minimize the number of employees scheduled for
leave, so that the number who do stay home will depend on how strictly
the stipulations of the measure are enforced. It is assumed here that
a program can be implemented wherein % of the employees in the affected
firms will be on leave.
Control measure 6. is intended to affect "business related" travel
more than "commuter" travel. Marketing and most transport activities
will supposedly be cancelled. The amount of business related travel
that is actually eliminated will depend on the working definition of
"critical transport"; it also will be sensitive to the amount of
enforcement attached to the measure. It is assumed here that % of
the business travel in firms of more than 100 employees will be
eliminated.
Without accounting for substitute driving and overlapping reductions
of other control measures measure 6 will produce the following VMT
reduction:
B-15
-------
% of the employees in % x 11% = 2-3/4% of LDMV VMT
affected firms on leave
% of business related 1%% of LDMV VMT*
travel eliminated 9% of HDMV VMT*
However, as noted in Section 2.6, substitute driving should decrease
the "employee leave" VMT reduction by about 1/5, so that it would be
only 4/5 x 2-3/4% = 2%% of total VMT. Also, the fleet vehicle ban would
overlap with the business related travel restrictions of measure 6.
The fleet vehicle ban apparently eliminates about % of the total
business related travel in the basin. Thus, about % of the reductions
in business travel claimed for measure 6. would already be achieved by
measure 4. This reduces the effectiveness of measure 6. to
h x 1%% = 3/4% of LDMV VMT and % x 9% = 4%% of HDMV VMT. Thus,
accounting for substitute driving and overlapping effects from control
measure 4, the VMT reductions expected from measure 6. are
e 3% of LDMV VMT and
• 4%% of HDMV VMT.
The VMT reductions can be translated into percentage emission
reductions by using Table 2.20, (note that the effect on emissions
from auto tank filling at service stations is to be included in the
vehicular source category). The results are
• RHC Emission Reduction: 2%%
e CO Emission Reduction: 3%
• NO Emission Reduction: 2%%
f\
* The VMT reduction for "business related" travel is broken down into
LDMV's and HDMV's as in control measure 4. for fleet vehicles.
B-16
-------
Stationary Sources:
The portion of measure 6. pertaining to stationary source control
is rather ambiguous. In fact, a self-contradiction appears to exist
since the measure applies only to firms with more than 100 employees,
yet "dry cleaning" is included as one of the industries to be
controlled. Even the largest dry cleaning companies tend to employ
well less than 100 employees, [B-8].
Another problem may result from the inclusion of petroleum
refineries in the control measure. Refinery operations are difficult
to shut-down, and the shut-down process itself may actually lead to
extra emissions. Because of such problems, a review committee, with
power to grant variances, should be established before a,definitive
Itst of affected industries is promulgated.
Control measure 6., through control of marketing transport, will supposedly
eliminate the transfer of gasoline to service stations. This would amount to
a 4% reduction in RHC emissions, (see Table 2.5). The other sources to be
controlled have not been well defined so that expected emission reductions
can only be estimated. It is assumed here that the impact on other
sources will be the same as shutting down all "major point sources" of reac-
tive hydrocarbons. The effectiveness of this measure, evaluated in Section 5.2,
is estimated to be 2% of total RHC emissions. Thus, the total reduction in
RHC emissions associated with measure 6. is 6%.
It should be noted that the 4% reduction in RHC emissions from
eliminating the filling of underground service station tanks is
also attained by control measure 4., ("Ban Private Fleet Vehicles").
B-17
-------
Thus, allowing for overlap of other control measures, the stationary
source effectiveness of control measure 6. only amounts to 2% of
total RHC emissions.
Total VMT Reduction:
3% of LDMV VMT
4%% of HDMV VMT
(4%% LDMV and 9% HDMV,
not counting substitute
driving and overlap of
control measure 4.)
Emission Reduction:
Vehicular Sources
Stationary Sources
RHC
2%%
2%
CO
3%
N0
STAGE III
1. All Stage I Actions (denoted as III.l below)
2. All Stage II Actions (denoted as III.2 below)
3. Close All Non-Critical Business (denoted as III.3 below)
Considerable overlap exists between Stage II, (measure 2. of Stage III),
and measure 3. of Stage III. In fact, measures 4., 5., and 6. of Stage II
are somewhat redundant when included as part of Stage III. Much of
measure II.4., banning fleet vehicles, would be a result of measure
III.3. Measure II.5., closing government agencies, also seems to be
a natural part of measure III.3. Measure II.6., commercial abatement
plans, is superfluous if measure III.3. is instituted.* The only con-
trol measure of Stage II that is not part of measure III.3. is the
* A possible exception is that measure II.6. may shut-down certain
stationary RHC sources that might not be closed under measure
III.3.
B-18
-------
closure of recreational facilities. In order to eliminate this re-
dundancy, Stage III could alternately be defined as
1. All Stage I Actions (denoted as 11 I.I below)
/
2. Close All Non-Critical Business (Work Holiday), Close
Recreational Facilities, and Shut-Down Major Stationary
RHC Sources (denoted as II\ .?' hP1nW)
This definition would have a nearly identical effect as the original
Stage III, but it would be operationally simpler since most of
State II measures would not have to be implemented separately.
The new definition also happens to correspond with an easier way
of calculating the effectiveness of Stage III. Instead of computing
the incremental effect of measure III.3. and adding this to the effect
of measure III.2, (Stage II), the total, cumulative effect of Stage III
(as embodied in measure III.2 ) can be calculated at once. This effective
ness calculation is performed below.
Stage III would drastically reduce incentives to drive by closing
all government agencies and industry except for "essential employees",
all trade and other commercial businesses except for "essential trade
and services", and all recreational facilities. The only traffic re-
maining would be from operating emergency vehicles, commuting of
essential employees, travelling for "essential trade or services,"
and driving for recreational and social purposes other than those
related to actual recreational facilities. It is estimated that
this strategy would achieve around a 75% reduction in total weekday
VMT, [B-5], [B-6].
B-19
-------
Stage III would also significantly affect stationary source emissions.
A 4% reduction in total RHC emissions would result from cancelling under-
ground service station tank filling. Eliminating dry cleaning, in-
dustrial and commercial painting, and certain other business uses of
organic solvents would reduce RHC emissions by around 6%, (see
Table 2.5).
The cumulative effect of Stage III would thus be as follows:
STAGE III
Total VMT Reduction: 75%
Applicable to LDMV's and HDMV's
Emission Reduction RHC CO NOY
/\
Vehicular Sources 54% 70% 52%
Stationary Sources 10% — —
B.2. COMPARISON OF THE EPA PLAN TO THE PLAN PROPOSED BY THIS STUDY
This section compares the episode criteria and control strategies
proposed by EPA Region IX with those recommended by this study and
discusses the relative advantages and disadvantages of each plan. The
episode criteria and control strategies for the EPA plan were given in
Tables B-l and B-2, respectively. For the plan recommended here, they
were presented in Sections 6.1 and 6.2.
Examining Table B-l reveals that the EPA episode criteria are of the
weather-change forecasting variety. That is, they are based on the present
day value along with a prediction of better, same, or worsening weather
conditions for the next day. This is the same type of episode criteria
B-20
-------
recommended in this study, (Section 6.1).* The criteria recommended here
differ in that a finer grid of present day concentration ranges and fore-
casted weather changes (e.g. much better, better, same, worse, much worse)
is used. However, this difference just reflects the fact that the control
strategy recommended here has more stages. Overall, the episode criteria
for the two plans are very similar. They are both set to call controls at
about the same level, and they are both of the same (forecasting) variety.
Table B-5. compares the control strategies of the two plans. The
three EPA stages correspond to voluntary reductions, certain mandatory
controls, and a complete work holiday, respectively. It can be seen that
EPA stages I and III are essentially equivalent to Stages I and IV of the
control plan recommended by this study. Thus, for both plans, the first and
last stages attain negligible and 64% RHC reductions, respectively. The
two control plans differ only in that the recommended plan has tw_g_
intermediate stages (between voluntary abatement and the work holiday)
and in that some of the control measures in the intermediate stages are
not the same. Considering that 27 alternative control measures were
considered prior to recommending a plan in this study, the two plans are
actually quite similar.
EPA Stage II essentially covers all of the measures in "recommended"
Stage II. Both contain "ban private fleets" and "close government agencies."
* The reader is also referred to Section 4.1 for a discussion of four
alternative varieties of episode criteria, (feedback type, future-weather
forecast type, weather-change forecast type, and combination feedback-
forecast type).
B-21
-------
TABLE B-5 COMPARISON OF THE EPA CONTROL STRATEGIES AND THE
CONTROL STRATEGIES RECOMMENDED BY THIS STUDY
EPA PLAN
PLAN PROPOSED IN CHAPTER 6
Stage
Control Strategy
Incremental
RHC
Reduction
Cumulative f
RHC I
Reduction 1
CD
t
ro
IND
Stage
iJElUllBauM
Control Strategy
Incremental
RHC
Reduction
Cumulative !
RHC i
Reduction ]
t
1!
1.
2.
Press Release
Voluntary Reduction of
Vehicle Use & Emissions
negl .
negl .
aJDLJJJUUBJJ
II
1. Stage I Actions
2. Close Recreational Areas
3. Close Recreational Events
4. Ban (Private) Non-Critical
Fleet Vehicles
5. Close Non-Critical
Government Agencies
6. Reduce Direct & Indirect
Emissions from Private
Businesses w/More than
100 Employees
negl .
4%%
10%
3%
4%%
maninfBiaiwttrKw -a
22%
III
1. Stage I Actions
2. Stage II Actions
3. Close All Non-Critical
Business
negl .
221
kn
64%
1'
1. Media Announcement &
quest for Voluntary
Reduction of Vehicle
& Emissions
Re-
Use
negl .
|
j
j
negl. \
v.
II
iiJJKLMJWIHJl
n**Af9i.t\.K<f.™*™e™>rf-'-W'^w*
1 . Stage I Actions
2. Ban Filling of Underground
Service Station Tanks
3. Shut-down Major RHC Point
Sources & Other RHC Source
Categories Designated by the
APCD - (Exemptions Allowed)
4. Ban (Private) Non-Critical
Fleet Vehicles
5. Close (Non-Essential )
Government Agencies
.uMun.ia .am,iimM-mjjH-
negl .
4%
3%
6%
3%
BaixsaiaiaHBXziaauj'.&MB*:'^
1
16%
ITT T
i.
2.
Stage I Actions
Operate on Sunday Status
negl.
39%
1
39% 1
1 . Stage I Actions
2. Complete Work Holiday with
Recreation Closed
)jfl«rf.aaam>BHijau»<^.
negl .
64%
S5&&S&&3U33&&232S5
64%
-------
"Ban filling of underground service station tanks," (recommended measure
H-2), is covered by measure II.4. of the EPA plan. "Shut down stationary
RHC sources," (recommended measure 11.3), is mostly covered by EPA measure
II.6. However, EPA Stage II adds "close recreation" and "traffic abatement
plans for firms with more than 100 employees." This makes the Stage II
RHC reduction 22% for the EPA plan, while it is only 16% for "recommended"
stage II.
Although it has a slightly less stringent second stage, the recommended
plan adds another intermediate stage which consists of "operating on Sunday
status." This attains most of the reductions in "recommended" Stage II,
(even without implementing the specific measures of that stage), and adds
further vehicular and stationary source abatement to bring the total RHC
emissions reduction to 39%.
As indicated in Section 6.0, neither the EPA nor the recommended plan
appears to be unambiguously better. Each plan has certain advantages, and
each has certain disadvantages. The choice of which plan to prefer depends
on how the relative benefits of each are weighted. Some of these advantages
are noted and discussed below.
Advantages of the EPA Plan
• One point that may favor the EPA plan is that it contains
three control stages rather than four. This may make the plan
operationally simpler. It also seems to be more consistent
with the rather large forecasting error that exists for episode
type days, (see Section 4.1.). Having four stages adds flexibility.
However, the benefits of measured flexibility cannot really be
B-23
-------
reaped if forecasts are not reliable. Forecast inaccuracy may
make it difficult to know which of three stages is really appropriate
for a given day. In such cases having four stages to select from
may be a useless complexity.
• The second major advantage of the EPA plan is that it attains
siightly more emission reduction per unit economic cost than does
the recommended plan in the intermediate control stage. As noted
above, the first 16% RHC reduction for both plans essentially
comes from the same control measures. The EPA plan then attains
an extra 6% RHC reduction in the intermediate stage by closing
recreational facilities and by instituting a commercial traffic
abatement plan for major firms. The next intermediate stage in the
recommended plan attains an extra 23% reduction (Bringing the
total to 39%) by "operating on Sunday status." The economic cost
per unit emission reduction is less if recreation is closed and
major firms follow traffic abatement plans (in which they remain
open and producing) than it is if firms are required to close as
on a Sunday. However, the total cost effectiveness difference
between the plans is not very large since the first 16% reductions
for each plan have similar cost-effectiveness and since recreation
shut-downs and commercial traffic abatement schemes do involve
considerable economic costs themselves.
Advantages of the Recommended Plan
• The principle advantage of the recommended plan is that the control
measures seem to be organized into stages that are operationally
B-24
-------
simpler and easier to implement. The two "extra" control measures
in the EPA intermediate stage, close recreation and commercial
traffic abatement schemes, appear to create more difficult enforce-
ment and implementation problems than do the other control measures
in the EPA Stage II. It will take quite an administrative program
to effectively institute commercial traffic abatement schemes,
and closing all recreational events and areas may present even greater
problems. The "extra" intermediate control stage in the recommended
plan, "operate on Sunday status", may be very severe as to economic
impact; however, it appears to be relatively easy to administer
(assuming the legal authority to call a control in this specific
form exists).
The proposed plan also contains operational simplicity in that
Stages III and IV supplant all previous mandatory controls with
just a single, more comprehensive control. Thus, in supplementing
Stage III, there is no need to also implement the measures of
Stage II. In implementing Stage IV, Stage II and Stage III measures
need not be instituted. This organization of control strategies
fits well with the forecast type episode criteria which are used on
the plan, (having continuous, sequential staging of controls is
most appropriate for feedback type criteria).
As noted in the effectiveness calculation of Section B.I, control
measures 2. and 3. of EPA Stage III overlap considerably. In
fact it does not make sense to implement certain aspects of
measure II.2. (such as commercial traffic abatement plans) when
B-25
-------
measure 111.3. will be in effect (a work holiday). As shown in
Section B.I., this redundancy can be eliminated and operational
simp!icites can be increased by eliminating measure III.2. and
modifying the definition of measure III.3. If this is don.e., EPA
Stage III corresponds more closely to Stage IV of the recommended plan
Another possible advantage of the recommended plan involves the
way recreational closure is used as a traffic abatement measure.
In the recommended plan, recreation remains open until thr last stage,
when a complete work-holiday is instituted. The recreational shut-
down then has the very significant effect of reducing substitute
driving which would occur as the result of the work holiday.
In the EPA plan, recreation is closed in Stage II, (before the work
holiday), as well as in Stage III, (with a work holiday). In Stage
II, recreational shut-downs achieve around a lh% VMT reduction and
a 4%% RHC reduction. This total reduction is considerable. However,
it should be noted that most recreational driving (about 2/3) occurs
in the afternoon and evening on weekdays, (see Figure B.I). Since
the morning (and possibly early afternoon) traffic is most important
to oxidant production, the effect of recreational closure will be
considered less significant than indicated by the total emission
reduction. With this consideration in mind, recreational shut-
downs become much less attractive as an initial control measure.
It seems more appropriate to close recreation in the final stage
as a deterrent to substitute driving during the work holiday.
B-26
-------
f—I—I—I—I—*•—I—I—I
12
12
HOUR
Figure B.I Hourly Distribution of Recreational
Trips In The LARTS Study Area
Source: Reference [B-3]
B-27
-------
It was previously noted that the -simplicity of three stages (as
oppossed to four) seemed to favor the EPA plan and that a three
stage plan was more consistent with the rather large forecasting
errors which now exist on episode type days. However, if forecasting
on episode type days could be improved considerably, so that the
flexibility of a four stage plan could be better put to use, then
a four stage approach might be preferable. Whether or not fore-
*
casting can be sufficiently improved is not known.
* Three possible methods of measures forecast accuracy are described in
Section 4.1.3.
B-28
-------
REFERENCES - APPENDIX B
B-l. California Air Resources Board, Personal Communication of Data
Received from the Department of Motor Vehicles on Fleet Vehicle
Population, October 1972.
B-2. California Air Resources Board, Personal Communication of Data
Received from the Highway Patrol on Fleet Vehicle Use, October 1972.
B-3. California Department of Transporation, LARTS Base Year Report,
1967 Origin-Destination Survey, December 1971.
B-4. California Department of Transportation, Los Angeles Freeway
Surveillance Control Project Data, August 1973.
B-5. California Office of Emergency Services, Air Pollution Emergency
Traffic Control Planning Committee, Traffic Abatement Plan for
Air Pollution Episodes, 1973.
B-6. Environmental Protection Agency, Region IX, Preliminary Report of
the EPA Region IX Task Force on Traffic Abatement During Air
Episodes, 15 September 1972.
B-7. Los Angeles City Department of Traffic, Transportation Planning
Division, Staff Report: LARTS Trip Type Distribution, Supplemental
Report, July 6 1973.
B-8. Kandlar, Howard, California Dry Cleaning Company, Personal
Communication, Los Angeles, October 1973.
B-9. Kearin, D. H. and Lamoureaux, R. L., A Survey of Average Driving *
Patterns in the Los Angeles Urban Area, System Development Corpora-
tion Technical Memo (TM(L) - 4119/000/01), February 1969.
B-10. Motor Vehicle Manufacturers Association, 1973 Motor Truck Facts,
Detroit, Michigan, 1973.
B-ll. TRW, Transportation and Environmental Operations, Transportation
Control Strategy Development for the Metropolitan Los Angeles
Region, EPA Contract No. 68-02-0048, January 1973.
B-29
-------
APPENDIX C
This appendix presents data on recent oxidant episodes in the
Metropolitan Los Angeles AQCR. Table C.I lists the date and location of
all occurences of oxidant greater than .40 PPM - one hour average from
January 1970 to June 1973. The maximum one, two, and four hour average
oxidant are given for each date and location. Violation of the significant
harm levels are indicated by an asterisk, (these days are summarized in
Table 2.10 of the main text). During the period under consideration,
only the .40 PPM - four hour average harm level was exceeded. Such episodes
occurred fourteen times; the greatest excess of the harm level was .53 PPM -
four hour average at Riverside on 6 August 1970. On this date, at Riverside,
the maximum one and two hour oxidant averages in the period under considera-
tion also occurred, .62 PPM and .59 PPM, respectively.
C-l
-------
Table C.I
OXIDANT EPISODES IN THE
METROPOLITAN LOS ANGELES
AIR QUALITY CONTROL REGION
(1-70 to 6-73)
Federal Significant Harm Levels
Date Station
Saturday, 16 May 1970 Pasadena
Azusa
Monday, 1 June 1970 Pasadena
Azusa
Pomona
Tuesday, 2 June 1970* Azusa
Pomona
Pasadena
Saturday, 16 May 1970 Pasadena
Azusa
Monday, 1 June 1970 Pasadena
Azusa
Pomona
Tuesday, 2 June 1970* Azusa
Pomona
Pasadena
Saturday, 20 June 1970 Redlands
Wednesday, 24 June 1970* Redlands
Riverside
Thursday, 25 June 1970 Pomona
Azusa
Redlands
Riverside
Maximum
One Hour
Average
(PPM)
.70
.46
.42
.44
.43
.41
.47
.47
.46
.46
.42
.44
.43
.41
.47
.47
.46
.43
.52
.45
.48
.47
.45
.41
San Bernardino .40
Thursday, 2 July 1970 Azusa
Saturday, 4 July 1970* Pasadena
Azusa
Pomona
Thursday, 16 July 1970 Azusa
Newhall
Monday, 27 July 1970 Riverside
Thursday, 6 August 1970* Riverside
Azusa
*Significant Harm Level Exceeded
.48
.45
.42
.40
.42
.41
.46
.62
.49
Maximum
Two Hour
Average
(PPM)
.60
.44
.40
.41
.42
.37
.46
.45
.43
.44
.40
.41
.42
.37
.46
.45
.43
.40
.47
.43
.46
.38
.45
.39
.38
.37
.44
.39
.39
.41
.40
.43
.59
.49
Maximum
Four Hour
Average
(PPM)
.40
.38
.36
.35
.36
.31
.42*
.42*
.395
.38
.36
.35
.36
.31
.42*
.42*
.395
.39
.43*
.36
.34
.30
.37
.36
.32
.34
.41*
.38
.35
.35
.38
.36
.53*
.44*
C-2
-------
Table C.I (continued)
OX1DANT EPISODES IN THE
METROPOLITAN LOS ANGELES
AIR QUALITY CONTROL REGION
(1-70 to 6-73)
Federal Significant Harm Levels
Date Station
Friday, 7 August 1970* Azusa
Riverside
Monday, 24 August 1970 Azusa
Wednesday, 9 Sept. 1970 Redlands
San Bernarc
Thursday, 10 Sept. 1970* San Bernar.
Azusa
Pomona
Friday, 11 Sept. 1970* Azusa
San Bernar
Wednesday, 16 Sept. 1970 Azusa
Pasadena
Thursday, 17 Sept. 1970 Pasadena
Friday, 18 Sept. 1970 Pasadena
Tuesday, 22 Sept. 1970 Pomona
Wednesday, 8 Sept. 1971 Riverside
Saturday, 11 Sept. 1971 La Habre
Riverside
Monday, 13, Sept. 1971* Riverside
Pasadena
Azusa
Anaheim
Thursday, 29 June 1972* Riverside
Azusa
Tuesday, 11 July 1972* Azusa
Riverside
Thursday, 13 July 1972 Azusa
Friday, 28 July 1972 Riverside
Fontana
San Bernar
La Habre
Significant Harm Level Exceeded
Maximum
One Hour
Average
(PPM)
.70
.58
.48
.48
.44
lino .44
Jino .42
.44
.42
.47
dino .40
.50
.45
.40
.41
.40
.42
.42
.40
.56
.53
.48
.42
.45
.40
.47
.41
.49
.50
.42
dino .42
.40
Maximum
Two Hour
Average
(PPM)
.60
.54
.45
.44
.42
.40
.42
.43
.40
.47
.39
.45
.40
.40
.40
.35
.40
.39
.35
.47
.46
.46
.33
.44
.39
.44
.39
.46
.44
.37
.31
.37
Maximum
Four Hour
Average
(PPM)
.40
.46*
.42*
.38
.36
.34
.44*
.395
.36
.42*
.36
.39
.34
.34
.34
.28
.37
.36
.29
.40*
.35
.38
.25
.40*
.37
.40*
.33
.38
.34
.29
.22
.31
C-3
-------
Table C.I
(continued)
OXIDANT EPISODES IN THE
METROPOLITAN LOS ANGELES
AIR QUALITY CONTROL REGION
(1-70 to 6-73)
Federal Significant Harm Levels
Date Station
Tuesday, 22 August 1972 Riverside
Thursday, 31 August 1972 Riverside
Saturday, 30 Sept. 1972 Riverside
Tuesday, 5 June 1972 Upland
Wednesday, 6 June 1973* Upland
Fontana
Friday, 8 June 1973* Fontana
Monday, 18 June 1973 Upland
Saturday, 23 June 1973 Fontana
Upland
Thursday, 21 June 1973* Downtown
Los Angeles
* Significant Harm Level Exceeded
Maximum
One Hour
Average
(PPM)
.70
.45
.40
.42
.43
.60
.45
.44
.45
.45
.42
.52
Maximum
Two Hour
Average
(PPM)
.60
.39
.36
.40
.42
.53
.44
.44
.43
.41
.37
.52
Maximum
Four Hour
Average
(PPM)
.40
.36
.32
.36
.38
.46*
.37
.41*
.38
• .36
.32
.47*
Data Sources:
NOTE:
California Air Resources Board, California Air Quality Data,
Volumes II, HI and IV, January 1970 through December 1972.
Air Monitoring Logs of the Los Angeles County APCD
11 " " San Bernardino " "
11 " " Riverside " "
' Orange " "
This table includes all days and stations with max one hour oxidant
greater than or equal to .40 PPM. Data in 1970 and 1971 from the UC
Riverside station at Upland have not been included. That station
frequently experienced the highest oxidant concentrations in the
basin; however, a data analysis by the ARB has lead to the conclusion
that the UCR Upland data is unreliable.
C-4
-------
APPENDIX D
CALCULATION OF VMT REDUCTIONS ASSOCIATED WITH
VARIOUS TRAFFIC ABATEMENT MEASURES
Chapter 5 of the text evaluates alternative control measures for air
pollution episodes in the Metropolitan Los Angeles AQCR. Table 5.4
summarizes the effectiveness, institutional obstacles, and socio-economic
impact associated with the implementation of 24 different traffic abate-
ment schemes. This appendix documents the VMT reductions expected from
each measure (effectiveness).
Below, the various traffic abatement measures are evaluated in the
order of their appearance in Table 5.4. Of course, for each measure, the
expected VMT reduction depends on the specific implementation and enforce-
ment activities associated with it. Detailed descriptions of each traffic
control measure, including implementation and enforcement procedures,
can be found in Table 5.4.
DIRECT CONTROLS ON TRAFFIC
1. Voluntary Traffic Abatement
This "non-active" control is likely to have negligible effect on VMT.
Its purpose in an entire control strategy should be to provide certain
prerequisites for direct control, (media campaign, special announcements,
etc.)
Past experience in Los Angeles and San Francisco indicates essentially
no change in total VMT resulting from such a measure [D-4], [D-5]. However, it
is possible that a more extensive and better organized public relations
effort on the media might bring about some discernable reductions. Without
making provisions for workers to be paid if they choose to stay home (in
which case this comes under "Work Holiday"), the maximal effectiveness
should be less than 5%.
D-l
-------
It is assumed that voluntary abatement would be effective only for
LDMV's and not for HDMV's or diesels.
Total VMT Reduction: Negligible to 5%.
Most likely negligible.
Applicable to: LDMV's
2. Windshield Sticker Program
The effectiveness of the windshield sticker program varies
depending on the number of sticker colors that are banned from travel. The
theoretical maximal potential reduction, with full public knowledge, full
acceptance, and adequate enforcement, is 85-90% of total VMT (all but emer-
gency vehicles), [D-5], [D-6]. The actual maximal reduction would depend on
the actual degree of knowledge, acceptance, and enforcement. Considering these
problems, the State Office of Emergency Services Committee estimates around
a 50% maximum, [D-5].
The strategy can be applied to LDMV's, HDMV's and diesels.
Total VMT Reduction: Flexible. Maximal is 50-85% depending on
implementation and enforcement procedures.
Applicable to: LDMV's, HDMV's, and diesels.
3. License Plate Lottery
Like the Windshield Sticker Program, the License Plate Lottery provides
for variable effectiveness. In this case, traffic reductions depend on how
many "last license plate numbers" are banned. The EPA Region IX Task Force
on Traffic Abatement, [D-6], reports the following maximal traffic reductions
per quantity of "last numbers" banned: (The EPA results have been modified
D-2
-------
to reflect an overall maximum VMT reduction of 85%, corresponding to all
non-emergency vehicles.)
"Last Numbers'
Maximal
Banned
1
2
3
4
5
6
7
8
9
10
VMT Reduction
negligible
4%
8%
13%
21%
30%
42%
55%
68%
85%
Of course, as with "Windshield Stickers", the maximum reduction is
likely to be less than 85% due to problems of public knowledge and acceptance,
and to considerable enforcement difficulties. Public compliance with "license
plate lottery" might be less than with "Windshield Stickers" because of the
apparently more arbitrary nature of the former. Enforcement also might be
more difficult, (it would be harder to discriminate between vehicles in
general and emergency auto use, e.g., doctor's cars, in particular).
Total VMT Reduction:
Applicable to:
Flexible. Maximal is 50-85% depending on
implementation and enforcement procedures.
LDMV's, HDMV's and diesels.
D-3
-------
4. Ban Non-Essential Government Vehicles
In 1973, there are around 100,000 government vehicles operating in the
Metropolitan Los Angeles AQCR, [D-10]. Assuming 75% of these would be
classified as non-essential, 75,000 would be banned from travel. This
would constitute 1.2% of the total 6.2 million LDMV's and HDMV's in the
basin, [D-10]. Since public and commercial type vehicles tend to travel more
miles per day than private vehicles, [D-2], [D-10], it is assumed that the total VMT
reduction would be around 1%%. It is assumed that LDMV's and HDMV's are
equally affected by this measure.
Total VMT Reduction: 1%%
Applicable to: LDMV's and HDMV's
5. Ban (Private) Fleet Vehicles
There are presently around 430,000 vehicles contained in private fleets
of ten or more which operate in the Metropolitan Los Angeles AQCR, [D-l], [D-10].
It is not known how many vehicles would fall in exempt categories (taxis and
transit vehicles, delivery of perishables, essential deliveries, and
emergency utility service). It is arbitrarily assumed that 1/3 of the
vehicles would be exempt. This implies that 290,000 vehicles would be
included.
Assuming 20% of these are HDMV's [D-9], then 25% of the total 240,000
HDMV's in the basin and 4% of the total 5,900,000 LDMV's in the basin are
contained in non-exempt private fleets. Since fleet vehicles tend to
be used more intensively than non-fleet vehicles, it is assumed that a 30%
reduction in HDMV VMT and a 5% reduction in LDMV VMT is attainable through
D-4
-------
this strategy. This result is very close to an independent estimate of 5%
total VMT reduction by the OES Report, [D-5].
Total VMT Reduction: 5% of LDMV VMT
30% of HDMV VMT
6. Ban (Private) Fleet Vehicles and Use of Vehicles for Commercial Purposes
As with the fleet vehicle ban, insufficient data are available to
accurately assess the effect of banning vehicles for commercial use. An
estimate will be made here by using data on numbers of trucks (HDMV's) in
various use categories compared to the number in fleets, [D-9]. These data
will provide a ratio of VMT by trucks (both fleet and non-fleet) in com-
mercial use as compared to VMT by trucks in fleets only. A similar ratio
will then be assumed for LDMV's and the effectiveness of Strategy 6. will
be obtained by appropriately factoring the effectiveness of Strategy 5.,
(which was for fleet vehicles only).
In commercial and industrial categories, (other than personal trans-
portation and agriculature), around 60% of total trucks are not contained
in fleets of ten or more, [D-9]. Assuming that the same percentage of
non-fleet commercial trucks will be exempt as are fleet trucks, this implies
flr\°i+A.r\°/
that strategy 6. is 5/2, ( 40% ). as effective as strategy 5. for trucks
(HDMV's). It is possible that the ratio of non-fleet to fleet LDMV's in
commercial use is less than the ratio for trucks. To be somewhat conservative,
it will be assumed that strategy 6. is only twice as effective as strategy 5.
for LDMV's.
Thus, with the approximate factoring of strategy 5., the effectiveness
of the present strategy is 5/2 x 30% = 75% for HDMV and 2x5%= 10% for LDMV.
D-5
-------
This result agrees rather well with a totally independent OES Report result,
[D-5]. Combining the OES fleet and commercial vehicle strategies in the
appropriate way, one obtains an estimated 12% VMT reduction.
Strategy 6. will present much greater enforcement problems than the
more simple fleet-vehicle ban. The actual effectiveness of this strategy
may be significantly less than calculated. Thus, the VMT reductions below
contain ranges indicating uncertainty due to possible enforcement difficulties.
Total VMT Reduction 7 - 10% of LDMV VMT :
i
50 - 75% of HDMV VMT |
Depending on enforce-
ment procedures.
7. Ban All Non-Emergency Traffic
Banning all traffic except for essential vehicles and emergencies has a
maximum potential effectiveness of 85-90%, corresponding to all non-emergency
traffic. The actual reduction will depend on public knowledge and acceptance
as well as degree of enforcement. The OES Report anticipated around a 50%
reduction, [D-5].
Total VMT Reduction: 50-85%, depending on implementation and
enforcement procedures.
Applicable to: LDMV's, HDMV's and diesels.
8. Mandatory Car-Pooling on Freeways
From Table 2.16, average auto-occupancy in the Los Angeles Basin is
around 1.4 persons per vehicle on weekdays. From Table 2.12, freeways
account for 48% of total VMT. Assuming carpooling causes an extra 10%
D-6
-------
driving in picking up passengers) and that the same drivers use the freeway,
the total % VMT reduction would be
A VMT(%) = 48% (1 -
where NFOR is the new freeway occupancy rate, [D-10J. If NFOR could be increased
to 2, the total VMT reduction would be 11%. If NFOR were increased to 3, the
total VMT reduction would be 23%. Reductions in number of passenger trips
might yield even greater VMT reductions.
However, it is likely that many people would use surface streets
rather than carpool and use the freeway. This would negate some of the
above effect. These drivers would be likely to travel longer and produce
extra emissions. These effects are likely to cancel at least 50% of the
above VMT reductions to around 5% (2 people per car) and 10% (3 people per
car), respectively.
Depending on public awareness and acceptance and the level of enforce-
ment, actual VMT changes could be less than half the above estimates.
Total VMT Reduction: 2-5% (two people per vehicle),
4-10% (three people per vehicle),
Depending on implementation and
enforcement procedures.
Applicable to: LDMV's
9. Mandatory Carpooling on Freeways and Major Thoroughfares
It will be assumed here that 90% of all vehicles use freeways and
"major thoroughfares", (this will actually depend on how the later is defined).
Average auto occupancy is 1.4 persons per vehicle. Assuming an average increase
of 10% in trip length is required to accomodate carpoolers, then the total
D-7
-------
change in VMT due to changing the average occupancy rate, AOR, is
AVMT(%) = 90% (1 - K1 X 1>4) .
AOR
Increasing AOR to 2 leads to a 20% reduction. An average of 3 persons per
vehicle leads to a 44% reduction. If passenger trips also decrease, even
greater VMT reductions might occur.
In contrast to the freeway carpooling increase above, there will be
much less possibility for drivers to escape the intent of the regulation
by taking alternative routes. However, drivers who do attempt this would
likely travel much longer and cause traffic jams; both of these effects
would increase emissions from those vehicles. Both effects would depend
on the definition of "major thoroughfare". It will be assumed that with
full enforcement and public awareness, maximal VMT reductions will be around
15% and 35% respectively for 2 and 3 persons per vehicle.
However, enforcement cannot be completely thorough, and there will
certainly be public non-awareness and non-cooperation. This may reduce the
VMT changes by one-half or more.
Total VMT Reduction: 7-15% (2 persons per vehicle),
15-35% (3 persons per vehicle),
depending on implementation and enforce-
ment procedures.
Applicable to: LDMV's
D-8
-------
10. Commercial Abatement Schemes
The traffic reduction obtainable from commercial abatement schemes is
variable according to the number of schemes that are called upon for imple-
mentation. Weekday, work related VMT, (see Table 2.13), accounts for around
50% of total VMT, (32% Home-Work , 10% Work-Other, and around 8% Other-Other).
To eliminate nearly all work related travel,would basically require that
all non-essential employees stay home. This would then be basically a
"Work-Holiday", resulting in around a 35% VMT reduction. To keep businesses
operational, the VMT reduction would have to come basically from carpooling,
increased transit ridership, and elimination of certain postponable business
trips. Around one-half of work related VMT, 25% of total VMT, might be
eliminated in this manner.
Unfortunately, very difficult enforcement problems are inherent in
using commercial abatement schemes for increasing carpooling and transit
ridership, and for decreasing business trips. As indicated in Appendix A,
experience with federal employees indicates that lacking enforcement,
the effectiveness of such schemes (without giving work holidays) is minimal.
Enforcement and implementation difficulties are likely to severly limit
the reductions that can actually be obtained. A 15-20% maximum seems plausible
considering these difficulties.
Total VMT Reduction: Flexible.
Maximum: 35%, calling "Work Holidays"
0-20%*, keeping business operational
* depending on enforcement and implementation
procedures.
D-9
-------
CONTROLS ON TRAFFIC SUPPORT FACILITIES
11. Close Freeways (or Certain Freeway Lanes)
Closing freeways (or certain freeway lanes) to all but emergency and
transit vehicles would achieve some positive effects by discouraging person
trips and by encouraging a shift toward transit ridership. However, this
effect would be counterbalanced by an increase in VMT due to longer trips
per auto and by an increase in emissions per mile due to traffic congestion.
Overall, the strategy is likely to cause an increase in emissions.
Total VMT Reduction: Doubtful, very possibly an increase.
12. Limited Availability of Parking
Limiting parking spaces could theoretically reduce VMT by discouraging
some person trips and by encouraging the use of carpools and mass transit.
In practice, drivers may just "take the chance" of finding parking or
park illegally. Actual increases in VMT may be produced by extra driving
in search of parking and by some commuters who may have another family
member to drive them to work and later pick them up (thus doubling their
normal trip distance).
Total VMT Reduction: Doubtful ,very possibly an increase.
13. Special Parking Tax
A "special parking tax" scheme may be more effective than "limited
parking availability" since it can be conducted in such a way as to provide
the driver with more certain implications about the outcome of his decisions.
That is, it could be made apparent to the driver that he will have to pay an
D-10
-------
extra $20 to park Downtown (whereas "limited parking availability" just
means he may or may not find a place to park). This greater certainty
of parking penalty should provide a stronger incentive for carpooling
and public transit usage.
However, there still may be a counterproductive tendency due to in-
creased driving in search of places not covered by the tax and due to some
persons being driven to work by non-working family members. Many people,
of course, will just decide to pay the burden of the tax (and complain
later).
The OES report estimates about a 20% VMT reduction for this strategy,
(with a 50% possible maximum). In light of the above, the OES estimate
appears optimistic.
Total VMT Reduction: Very Uncertain.
Possibly as much as 20%
but possibly negligible.
14. Gasoline Rationing
A gasoline rationing scheme, based on a "coupon number system", provides
a flexible means of reducing traffic by controlling fuel use. Estimates
of maximum effectiveness for this scheme vary widely. The EPA Region IX
report assumes a 20-50% VMT reduction; the OES report gives 5%, 10% and
25% for the 1st, 2nd, and 3rd days respectively. The maximum effectiveness
is estimated below as follows:
The average vehicle miles travelled per day per car is 30 miles, [D-10].
Assume that an average vehicle can travel 180 miles per full tank of gas,.
D-ll
-------
(12 gallons, 15 miles per gallon). Further assume that on the average,
for every full tank of gas used, a driver stops for gas 1% times
(i.e. drivers do not use one full tank per gas stop). Then, the
average driver stops once every 4 days for gas.
On the first day of gas rationing, a maximum of 25% effectiveness is
thus plausible (not counting the psychological effect of the danger of
running out of gas). However, of the people who stop for gas each day,
not all need to. Much of this 25% probably consists of drivers who
have enough gas to continue that day. Also, some people have access to
two cars, and will use the one with more gas. A 10% maximum effective--
ness is thus assumed here for the first day. This should increase to
around 20% to 50% by the second and third days.
Total VMT Reduction: Flexible
Maximum: 10% 1st day
20% 2nd day
50% 3rd day
Applicable to: LDMV's and HDMV's
15. Close Gasoline Stations
The effectiveness of closing gasoline stations is equivalent to the
maximum effectiveness of a gas rationing scheme. As estimated in 14, above,
this is a 10%, 20%, and 50% VMT reduction the 1st, 2nd, and 3rd days,
respectively.
Total VMT Reduction: 10% 1st day
20% 2nd day
50% 3rd day
Applicable to: LDMV's and HDMV's
D-12
-------
The effect of this strategy will be found by adding together estimates
for the reduction in shopping, sales-service, and work trips.
Shopping: The LARTS and SDC surveys, [D-3], [D-7] indicate that around 20%
of total vehicle trips in the LARTS region are shopping related. Since
only around 15% of all shopping trips are to RSC's and CBD's, only
20% x .15 = 3% of total vehicle trips will be affected by this strategy.
Assuming an average trip length of 4.6 miles to or from a CBD or RSC,
[D-5], the total VMT change from reduced shopping trips would be
10W * 10%0% xl.fmiles (average length of all ' a of total VMT
trips in the basin)
Sales-Service: Based on Los Angeles CBD data, [D-5], [D-ll], it is assumed
that for typical retail establishments, sales and service trips are around
20% of shopping trips to these establishments. Assuming that a sales-
service trip is slightly longer than a shopping trip, around %%_ of total
VMT,(2% x.20 x 1 ), is accounted for by sales-service trips to retail
establishments in the RSC's and CBD's.
Employment: Retail trade accounts for around 14% of total employment in the
Los Angeles basin. Since only around 15% of such employees are in RSC's
and CBD's, only .15 x 14% = 2% of total employment in the basin will be
affected by this strategy. Work-related VMT is around 50% of total basfn-
wide VMT. Thus, .02 x 50% = ]%_ of total VMT will be eliminated by
employees staying home. This reduction actually will be slightly less
due to substitute driving.
D-15
-------
Adding together the traffic reductions from shopping, sales-service,
and employment, the total effectiveness of closing retail outlets in
RSC's and CBD's is 2% + %% + 1% = 3%% of total VMT.
Total VMT Reduction: 3h% \
t
Applicable to: LDMV's and HDMV's
20. Close Recreational Facilities
LARTS survey data, (modified according to recent corrections, see
Section 2.2.6) indicates that recreation accounts for 7.2% of total
weekday vehicle trips in the Los Angeles basin, [D-3.]. The results
of an SDC (System Development Corporation) survey, [D-7], indicate that
around 11% of total weekday trips are for recreational purposes. The
basic reason for the discrepancy between the two surveys involves the
definition of "recreation". In both studies the basic trip destinations
and origins can be classified as "Work", "Home", "Shop", and "Other",
and in both studies recreation is part of the "Other" category. However,
within the "Other" category, the LARTS study separates out "recreation"
and "social-entertainment", while the SDC study includes both of these
under "recreation". Thus, the difference between SDC and LARTS
estimates basically reflects "social-entertainment" trips.
For the purpose of the present study, "recreation" should include
"entertainment" since the control "Close Recreational Facilities" includes
theaters, playhouses, clubs, etc. It will be assumed that 9% of total
weekday trips are accounted for by this definition of recreation.
Recreational trips basically occur in the "Home-Other" and "Other-
Other" categories. The average trip length in these categories is
D-16
-------
CONTROLS ON INCENTIVES TO DRIVE
16. Close (Non-Critical) Federal Agencies
As noted in Table 2.3, federal agencies accout for 2%% of the total
4.2 million people employed in the Metropolitan Los Angeles AQCR. It will
be arbitrarily assumed that 95% of federal employees can be classified as
"non-critical" As noted in Table 2.13, 50% of weekday VMT is work related:
(32% Home-Work, 10% Work-Other, and 8% Other-Other). Thus, the decrease
in work traffic due to federal agency shut-down should be .025 x .95 x 50% = 1.2%
of total VMT.
Section 2.6 noted that a decrease in work related VMT by "X" brings
about a "1/5X" increase in other types of driving so that the total reduction
in VMT is only "4/5X". Thus, allowing for substitute driving, the total VMT
reduction from closing federal agencies would be 1%.
Total VMT Reduction: 1%
Applicable to: LDMV's
17. Close (Non-Critical) Government Agencies (Federal, State & Local)
As noted in Table 2.3 , government agencies account for 13% of the total
employment in the Los Angeles Basin. It is assumed that 90% of these employees
will be classified as non-critical (more state and local employees will
be "essential" than federal employees because of police, fire, ambulance,
and other services). Noting that work related VMT accounts for 50% of total
A
VMT, (Table 2.13), around .13 x .9 x 50% = 6% of total VMT will be eliminated
by government agency shut-down. Correcting for substitute driving, the
actual VMT reduction will be around 5%.
D-13
-------
If public school closure is included in this strategy, 1% to
extra VMT reduction will be obtained, (see Appendix B).
Total VMT Reduction: 5%*
Applicable to: LDMV's
* Add 1% if public school closure
is to be included.
18. Close Government Contractors
It is difficult to obtain estimates of how many people are employed by
government contractors. Based on indications in the OES and Region IX
reports, [D-5], [D-6], it will be arbitrarily assumed that 20% of the total
basinwide employees work for government contractors. Assuming 95% of these
employees are "non-essential" and noting that 50% of total VMT is work
related, the effectiveness of this strategy would be around
.20 x .95 x 50% = 9%% of total VMT. Correcting for substitute driving
(as in 16. above), the actual reduction would be around 7 %.
Total VMT Reduction: 7%%
Applicable to: LDMV's
19. Close Shopping Facilities at Regional Shopping Centers (RSC's) and
Central Business Districts (CBD's)
This strategy will be assumed to apply to 48 regional shopping centers
and 6 central business districts which have been identified in the Los Angeles
basin, [D-5], [D-8]. These RSC's and CBDls respectively account for $2.2
and $.74 billion of the total $20 billion annual retail sales volume in the
Los Angeles basin, [D-5]. Together, they thus account for (2.94/20) x 100% = 15%
of total retail sales volume.
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about 6-6% miles (see Table 2.]3). However, it is expected that
recreational trips would be longer than non-recreational trips in the
Home-Other and Other-Other categories. Recreational trips to the beach,
sporting events, amusement parks, fairs, etc. would probably average at
least as long as Home-Work trips (10 miles). This effect would only
partially be cancelled by recreational trips to clubs, bowling alleys,
theaters, etc., which would probably average about the same as Home-Shop
trips (3 miles). It is assumed here that the average length of a recreational
trip is 7 miles.
With total recreational trips representing 9% of average weekday
trips and having an average length of 7 miles, the maximal possible effect
of "Close Recreational Facilities" would be
100% x 100^ x Smiles (average length of all = *& of weekda* VMT'
trips in basin)
However, it is extremely unlikely that all recreational facilities will
be covered by the regulations (i.e. certain facilities may be neglected).
Also some recreation . may just involve "pleasure driving" and this
would not be covered. With adequate implementation and enforcement
procedures it is assumed that 80% of recreational driving can be
eliminated. This would mean that 7%% of total weekday VMT would be
effected.
Total VMT Reduction:
Applicable to: LDMV's
D-17
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21. Work Holiday for Major Firms
Private firms with 100 or more employees account for around 29% of
total employment in the Los Angeles basin [D-5]. Assuming 95% effectiveness
among these employees, (some workers will be classified as "essential" and
there may be certain notification problems with others), around 27%% of
total employment in the basin will be affected by the closure of these firms,
Since work related traffic accounts for around 50% of total VMT on an
average weekday, .275 x 50% = 13.8% of total VMT will be eliminated.
Substitute driving will negate 1/5 of this decrease (see section 2.6).
Thus, the expected VMT decrease, allowing for substitute driving, should
be 11%.
Total VMT Reduction: 11%
Applicable to: LDMV's and HDMV's
22. Rotating Work Holiday for Major Firms
This control measure is essentially the same as control measure #21
except flexibility has been added in that anywhere from 1/5 to all of the
firms with 100 or more employees may be closed. The range of possible
VMT reductions thus is 2.2% to 11%
Total VMT Reduction:
Applicable to:
2.2%
4.4%
6.6%
8.8%
11%
LDMV
1/5 of Major Firms
- 2/5
- 3/5 "
- 4/5
- All
s and HDMV's
D-18
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23. Operate on Sunday Status
According to this strategy, a "Sunday" type holiday would be called in
order to reduce incentives to drive. Most industry and commerce would be
off work, and retail outlets would be closed or would operate on a Sunday
schedule, but recreational facilities would be open. The VMT reduction
normally achieved on a Sunday is 36% of weekday VMT. This is less than
would be expected from the cancelling most weekday work and shopping trips
due to substitute driving, particularly for recreational purposes.
By calling a "Sunday" on a weekday, less than a 36% VMT reduction might
be expected due to incomplete public knowledge and other reasons for
non-compliance. However, this effect would be counterbalanced by extra VMT
reductions due to the lack of time to plan the substitute driving trips
normally taken on a Sunday. Also, as a show of good public concern, many
retail and recreational facilities might close even though they do not
normally close on Sundays. It is estimated that calling a "Sunday holiday"
with appropriate penalties for non-complying industrial and commercial
establishments, should achieve a 35-40% reduction from normal weekday VMT
levels.
Total VMT Reduction: 35-40%
Applicable to: LDMV's and HDMV's
24. Complete Work Holiday with Recreation Closed
A complete work holiday would entail closing all industry except for
"essential employees", closing all retail and other commercial businesses
D-19
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except for "essential services", and closing recreational facilities (as in
control measure 20). The only traffic remaining would be from operating
emergency vehicles, commuting of essential employees, driving for "essential
services" and driving for recreational and social purposes other than those
related to actual recreational facilities. It is estimated that this
strategy would achieve around a 75% reduction in total weekday VMT, [D-5],
[D-6].
Total VMT Reduction: 75%
Applicable to: LDMV's and HDMV's
D-20
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REFERENCES - APPENDIX D
D-l. California Air Resources Board, data concerning fleet vehicle
population received from- the Department of Motor Vehicles,
personal communication, October 1972.
D-2. California Air Resources Board, data concerning fleet vehicle
use received from the Highway Patrol, personal communication,
October 1972.
D-3. California Department of Transportation, LARTS Base Year Report,
1967 Origin-Destination Survey, December 1971.
D-4. California Department of Transportation, Data Processing Depart-
ment, Los Angeles Freeway Surveillance and Control Project,
personal communication, September 1973.
D-5. California State Office of Emergency Services, Air Pollution
Emergency Traffic Control Planning Committee, Traffic Abate-
ment Plan for Air Pollution Episodes., 1973.
D-6. Environmental Protection Agency, RegionIX, Preliminary Report
of the EPA Region IX Task Force on Traffic Abatement During
Air Episodes, 15 September 1972.
D-7. Kearin, D. H. and Lamoureaux, R. L. , A Survey of Average Driving
Patterns in the Los Angeles Urban Area, System Development
Corporation Technical Memo (TM(L) - 4119/000/01), February 1969.
D-8. Los Angeles Times, Marketing Research Department, Los Angeles
Shopping Centers 1971-1972.
D-9. Motor Vehicle Manufacturers Association, 1973 Motor Truck Facts,
Detroit, Michigan, 1973.
D-10. TRW Transportation and Environmental Operations, Transportation
Control Strategy Development for the Metropolitan Los Angeles
Region, EPA Contract No. 68-02-0048, January 1973.
D-ll. Wilber Smith and Associates, Los Angeles Central Business District
Parking Study, 1967.
D-21
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